March 6, 2013

Graphic Representations, Massing Designs Should Be Admitted as Evidence in Appeal

To the Editor:

With AvalonBay (AB) appealing the Planning Board’s denial of its application, the new Planning Board and Princeton Council are considering their response. New members of the Council and the Planning Board have a responsibility to review the public record of Board Hearings of the AvalonBay project, especially the graphic representations and massing designs shown by local architects. Words like “monolith” came alive — so also “scale” and street “frontage.” After seeing these visuals, everyone understood the overwhelming mass of the development. Urban planner Peter Steck argued that the plans required multiple c- and d- variances. Forty residents spoke; 38 of them opposed the project.

The illustrations are central to comprehending the radically disruptive character of AvalonBay’s wedge in the Witherspoon Street corridor. AB didn’t present a single visualization of its 367,808 sq. ft. apartment building in the context of the neighborhood of two-story houses, which would have revealed the cookie-cutter design’s inconsistency with the neighborhood in scale and character. The Board criticized the lack of visuals in its memorializing resolution, with attorney Muller writing that AvalonBay didn’t provide the Board with “accurate and sufficient information” (page 36).

AvalonBay’s appeal claims that the ordinance language is “vague”. But the visual presentations demonstrate clearly that AB’s plans don’t comply with this language and that the language is thus enforceable. Princeton’s attorneys should ask Judge Jacobson to admit the visualizations into evidence. Any legal deliberations of AvalonBay’s appeal would be flawed without them.

Wendy Ludlum

South Harrison Street