Troy's New Unified Development Code: Form Over Function?
Vol. IV, No. 25 - The Noticable Shift in Our Town's Development Philosophy
Troy’s proposed Unified Development Code looks less like the zoning code residents have known for years and more like a code built around form, design, and physical outcomes.
That may sound technical, but the shift is easy to see. The current zoning code sorts the city into a long list of districts and then spells out, often in exhausting detail, what uses are allowed in each one. The draft UDC cuts that structure down substantially. According to the city’s transmittal memoto the Planning Commission, the existing code has 20 zoning districts and 220 different use types. The draft UDC reduces that to 14 districts and 86 use categories. That is not a small edit. It is a different way of thinking about land use regulation.
Under the older code, the central zoning question was often simple: what exactly is this use, and is it listed in this district? The code leaned heavily on use separation. Retail here. Industrial there. Residential somewhere else. District by district, use by use, the code tried to answer nearly everything in advance.
The draft UDC still regulates land use. It still prohibits some uses outright, and it still imposes use-specific standards on others. But the code’s center of gravity appears to be shifting. Instead of treating use as the only thing that matters, the draft pays much more attention to how a building looks, how it sits on a site, how it meets the street, where the parking goes, whether mechanical equipment is screened, and whether the overall design fits the city’s preferred image.
That is where the form-based comparison becomes useful.
A traditional function-based code is mostly concerned with what happens inside a building. A more form-based approach is more concerned with what the building contributes to the public realm. In other words, the question becomes less “What is the tenant doing?” and more “What kind of place does this building create?” Troy’s draft UDC is not abandoning use regulation, but it is clearly placing more weight on the physical form of development than the old code did.
The newly proposed Gateway Overlay is one of the clearest examples. Its stated purpose is to guide architects and designers and to establish “a minimum expected level of architectural quality” for new or remodeled commercial buildings along major corridors. The standards then get very specific. Buildings should generally be parallel to the street. Main entrances must be emphasized with design features such as canopies, arcades, raised parapets, or display windows. Facades must use approved materials like brick, stone, stucco, or cement board. Long building walls must be broken up with offsets, material changes, or pilasters. Flat roofs must use parapet walls and cornice treatments to conceal them.
And yes, Troy’s draft goes so far as to require screening of roof-mounted mechanical equipment. The code says building walls, parapets, or roof systems must be designed to conceal rooftop mechanical equipment from adjacent properties and public rights-of-way. In the Gateway Overlay, it also requires both ground-mounted and roof-mounted mechanical equipment to be screened from view. That is not really about land use in the old-fashioned sense. That is about appearance, streetscape, and the visual quality of the built environment.
The city’s own memo points in the same direction. Staff say the districts are now organized around “land use intensity, neighborhood character, and development form,” and that the new mixed-use district is meant to allow complementary uses to coexist, in many cases within the same building. That language matters. It suggests the city is becoming less interested in obsessively separating every activity into its own narrow silo and more interested in shaping the character of the places where those activities occur.
Even the administrative structure of the draft reinforces this change. The memo says uses will be regulated through standardized use matrices, while the code itself gives the City Staff significant authority over uses with additional standards and over unlisted uses that are deemed similar and compatible. At the same time, the UDC expands site standards, architectural standards, overlay districts, and public-benefit requirements like the “close-knit factor.” That means more of the regulatory conversation may move away from simply identifying a use and toward evaluating whether a proposal fits the city’s design expectations and planning priorities.
That shift has consequences.
On the positive side, it can create more flexibility. If the city has fewer use categories and fewer districts, property owners may have more room to adapt buildings over time without needing a full legislative rewrite every time the market changes. It can also produce better-looking corridors and more coherent development patterns if the standards are applied consistently.
But the tradeoff is that a more form-oriented code often gives staff and appointed bodies more discretion. When the code focuses on compatibility, character, architecture, and design quality, the answer is not always as simple as checking whether a use is listed in a chart. Judgment starts to matter more.
That may be the real story in Troy’s draft UDC. It is not simply shorter or more modern. It reflects a deeper philosophical shift. The old code was more focused on function: what a property is used for and where that use belongs. The new code still cares about use, but it seems increasingly focused on form: how development looks, how it fits, and what kind of physical environment it creates for the public. That is not a full form-based code. But it is clearly a step in that direction.
The Troy Planning Commission will undertake their first review of the Unified Development Code tomorrow, Thursday, June 18th at 4:00 p.m. in Commission Chambers. Consultants from American Structurepoint, the consultants the helped draft the code will provide a presentation. Members of the public are encouraged to attend the meeting.
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