The Rochester ZAP draft is the next step in updating the zoning code to align with the Rochester 2034 Comprehensive Plan, which calls for Rochester to have a diversity of transportation choices and investments in quality infrastructure for walking, biking, rolling and public transportation. Better mobility, equity and safety should be key drivers of decision-making for zoning.The zoning code will last a generation and this is the opportunity to set Rochester on a path toward more walkable, wheelchair accessible, bikeable, transit-centered and human scale development. We believe a new zoning code should promote more equitable, smarter use of the City’s land and provide a path for a less car-centric, sustainable version of Rochester.


Ways to Provide Input to the Rochester ZAP Draft:

Upcoming Public Hearings:

Two public hearings before the Rochester Environmental Commission will be held on the following dates. Verbal comments will be accepted at these hearings:          

  • 6: 30 p.m., Tuesday, Dec. 5, 2023, at City Council Chambers at City Hall, 30 Church St.
  • 6:30 p.m., Wednesday, Jan. 17, 2024, in City Council Chambers at City Hall, 30 Church St.

Comment Online: Comments will be accepted through Wednesday, Jan. 31, 2024.

  1. Go to: 
  2. Click on Submit Your Comment
  3. This will open a Google Form. Enter your email, name and zip code. 
  4. Under “What would you like to comment on?” Select “Draft Code” and click Next.
  1. Select the Article You Wish to Comment on. For general comments, we recommend using Article 1. Title, Purpose, & Applicability. 

You may also submit comments by mail to:

Matthew Simonis, Manager of Zoning
City Hall – Room 125B
30 Church Street
Rochester, NY 14614

Talking Points / Suggested Comments: 

Article 1 and Article 2: 

  • Higher density is good for walkability, wheelchair accessibility, bikeability and public transportation coverage

A walkable, wheelchair accessible, bikeable and transit-centered city is built on dense neighborhood-level amenities and a dense urban core. The draft plan provides positive upzoning changes along certain transit corridors, but it can do more to encourage maximal use of these areas to provide for residents’ neighborhood needs:

  1. While previous plans may have defined transit corridors in the City, zoning should look at possible uses and density within a larger radius of transit stops (such as ¼ mile) or consider a larger definition of the transit corridor. For example, rather than zoning the one parcel on either side of the street, consider zoning 2-4 parcels deep along the transit corridor. 
  2. The City should conduct a review of intersections that are well served by public transit and consider maximal zoning of those intersections to support the addition of transit-centered amenities at or near bus stops. 

Article 4: Residential Districts

  • Low Density Residential

Consider allowing duplexes and accessory dwelling units (ADUs) based on special permits. Make the size requirements for ADUs more flexible.

  • Medium Density Residential

Consider allowing dwelling units within a mixed-use building based on special permits, especially along public transit corridors. Revise ADU requirements to be more flexible. 

Article 5: Mixed Use and Commercial Districts

  • Place a Moratorium on New Gas Stations, Drive-Thrus and Carwashes

We recommend the City of Rochester join other cities such as Santa Rosa and Petaluma, CA11 to place a moratorium on new gas stations22, not only due to their long-term harmful impacts on the environment and residents’ health, but also to hasten the transition to electric vehicles. In addition, we call for a moratorium on new drive-through restaurants and banks and carwashes. These types of businesses place priority on vehicle drivers passing through neighborhoods, and the frequent in-and-out traffic increases danger for pedestrians and cyclists. Minimizing the number of these businesses will also help support the City’s carbon reduction goals by reducing the consumption of gasoline and the fuel wasted idling in drive-through queues.

Article 8 and 9:

  • Add an indoor or sheltered, secure, bicycle parking requirement for Open Space Districts and Industrial/Regional Commercial Zones

City of Rochester residents who use their bicycle to commute to jobs deserve a safe, secure and protected space to store their bicycles during the work day. Open Space Districts should offer bicycle parking to encourage recreational use and accommodate festival traffic.

Article 15:

  • Eliminate car parking minimums city-wide, not just in commercial areas

We recommend that the City of Rochester join the 46 North American cities that have eliminated parking mandates all together, including Buffalo and Canandaigua. Rochester could even join similarly-sized Greensboro, NC in becoming car-optional by 20403 through greater transit investments. Eliminating them from commercial zones is a good step forward, as is the reduction of required parking for apartment buildings over 20 units. However, more can be done. Findings from Buffalo and other cities following the elimination of parking minimums show that parking was overprovisioned even in residential areas4. As a result of eliminating parking minimums, within 4 years Buffalo built 1,000 new homes that wouldn’t have otherwise existed55. This recommendation should have no impact on ensuring ADA-compliant car parking is provided per ADA regulations.

  • Eliminate the residential requirement that car parking must be on the same parcel (15.4.A.1)

Shared car parking lots offer a way to reduce the space required to accommodate single-occupancy vehicles and is consistent with the City’s goals of reducing single-occupancy vehicle trips.  Developers may also offer tenants a subscription to a car storage provider such as Premium Parking.

  • Eliminate the Transportation Access Plan (TAP) Requirement in favor of a requirement to adhere to the Rochester CAMP

Transportation Demand Management has shown some positive results in large metro areas, but the current proposal for Transportation Access Plans in Rochester’s zoning code runs the risk of creating hundreds of unrelated plans and having some unintended consequences. The TAP article 15.2 includes a dual mandate to reduce single-occupancy vehicle trips and also avoid placing undue burden on the public infrastructure. While these dual mandates may be workable on an individual project, the sum of hundreds of TAPs developed for isolated projects will create a patchwork of unrelated plans. Instead, the zoning code should set out a vision for transportation that encourages human-scale active transportation. The City should explore requiring developers to demonstrate adherence to CAMP plans and to explore updating the CAMP with a master plan on public transportation infrastructure that aims to meet the demands of an upzoned, denser Rochester over the next decade.

  • If the City opts to keep TAP requirements in the code, raise the minimums set to trigger it

Occupancy limits of 75 or more require developers to make a TAP, making even small projects adhere to this requirement. In addition, we recommend removing the second clause of the TAP requirement that sends a conflicting message about the purpose of the Transp Access Plans. The ZAP should be clear that TAPs should support alternative modes (not more parking spaces. Finally, we believe the City should eliminate the TAP requirement on Central District and transit corridors.

Article 19 and Article 20:

  • Site Plan Review Requirements for TAPs should include public notice and public comment. 

If TAPs are required to be developed as part of Level A Site Plan Reviews, the TAP should be made public and subject to comment. Short of this, they should be published as part of public domain for review by neighborhood residents. Hundreds of TAPs developed over the next decade will not help Rochester develop a sustainable and equitable transportation system if residents and advocates do not know what measures developers have taken to promote active transportation and public transit.

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