Amend the ReCode: An Opportunity to Structurally Improve Equity, Sustainability, and Resilience

The Troy City Council will soon be considering adopting a new zoning code, the laws that shape how Troy is developed in the future. The zoning code is the set of rules that developers must abide by, and the zoning code is, arguably, the strongest way the community can influence what their community looks like, feels like, and how it physically works.

The new zoning code, as proposed, is a huge step in the right direction for working people over the current code. It takes large steps to increase the ability of low-income people and people of color by lowering barriers to opening businesses that meet the needs of their communities and adding affordable housing options in wealthier parts of the city, among other things.

However, the zoning falls short of many of the laudable goals and metrics it sets for itself by retaining single-family exclusive districts and low intensity development. We believe that the council should remove single-family exclusive districts and the lowest intensity zone (labeled as Neighborhood I) because this type of development:

  • Limits equity and housing affordability: single-family exclusive zoning is historically racist and classist, and was used to keep black families from moving to white neighborhoods. Allowing multi-family units alongside single-family ones can improve opportunity for affordable housing and diversity of both race and income levels in our community .(
  • Damages environmental sustainability: the proposed code does encourage more environmentally sustainable development in parts of the city (mostly concentrated near the Hudson and South of Lansingburgh), but allowing low intensity and single use development areas still causes environmental harm. Additional vehicle trips and related pollution, energy inefficient buildings, and more inflict harm on all of us, whether we live in these typically more wealthy areas or not. (
  • Causes traffic deaths and injuries: the code has a number of provisions to encourage the improvement of the safety of people walking, biking, or rolling. However, it does not strike at the root cause of most traffic violence: the necessity to drive for nearly every trip created by low intensity and exclusively single-family development. The more vehicles on our streets and trips taken, the more traffic deaths and injuries we see. Reducing this type of development will save lives. (
  • Creates fiscal imbalance and inequality: more compact development improves the city’s financial resilience by collecting more tax revenues per acre, and allowing us to build and maintain cheaper infrastructure and services per capita. By keeping single-family exclusive and low intensity zones, the more dense, typically lower-income neighborhoods will continue to subsidize the lower-density, typically wealthier areas in the city’s budget, increasing the cost of living for renters and encouraging displacement. (

An additional issue is that while the proposed code encourages more mixed use development in more of the city – which increases the quality of life (convenient to grab something from the corner store) and reduces pollution (no need for a vehicle trip) – the code then undercuts this effort by including a buffer around convenience stores so that two stores can’t be across the street (or even down the block) from each other. This means that if the store closest to you doesn’t have the item you need, you may end up walking quite far, which encourages people to simply drive to the store. It also has the effect of granting those store owners who may not be great neighbors something of a local monopoly – making it impossible for competition to offer an alternative. 

Given the social, environmental, health, and fiscal cost of single-family exclusive and low intensity development, it is incumbent on the council to remove this kind of zoning from Troy’s zoning code. The cost of inaction – and half measures – are real and born by the most vulnerable of us. We, the undersigned, call for the Troy City Council to remove the exclusionary and harmful single-family exclusive use districts and the lowest density zones, as well as the convenience store buffer from the proposed code.

Stephen Maples

Mark Speedy

Renee Rhodes

Chel Miller

Anthony Olivares

Peyton Whitney

Dan Phiffer

Dylan Rees

Dara S.

David Banks

Line Kristine Henriksen

Ethan Warren

Rafael varela

Xan Plymale

Kristoph DiMaria

Caroline Nagy

Jack Letourneau

Rindle Glick

Rhea Drysdale

Daniel Graham

Marie H.

Zachary Guthrie

Troy Partnership for Black Lives Statement on the Recent Police Killing of a Community Member

(A note from Troy DSA: Joining the Troy Partnership for Black Lives, we have signed onto this letter expressing our collective outrage at Troy Police killing a community member in a car crash last week and TPD’s ongoing history of reckless, dangerous behavior—this is police violence. The full text of the statement is included below.)

We, the Troy Partnership for Black Lives, join our community in outrage to learn that another life has been lost due to the reckless driving of a Troy Police officer. Our deepest condolences and support go out to his family, friends, colleagues, and community. When will this City hold the Troy Police Department accountable for the violence they perpetuate on the very community they are supposed to protect and serve?   

Troy is not any different than Memphis or Atlanta where police officers have murdered Black and Brown people. On Wednesday, February 22nd just before 1:00 a.m., a Troy Police officer crashed into the car of a valued community member and father of newborn twins. The Troy Police Department has a history of failing to respect the lives of our community and neighbors, especially the lives of Black and Brown community members. This murder indicates that the Troy Police Department has not changed the practices and culture that have led to the loss of life in the past. Just like other times when Troy police have violated the rights and the lives of our community members, the first response of city and police officials is denial of responsibility, often including false information, before a thorough investigation can be completed. This was the response that began the cover-up of the police murder of Edson Thevenin in 2016 by the Troy Police, Rensselaer County DA, the Troy City Council, and Mayor Madden. 

The Troy Police officer was reportedly traveling at high speed through a dangerous intersection. Regardless of the outcome of the investigation, the officer acted with depraved indifference because his job as an officer and his responsibility as a human being was to do whatever was necessary in order not to harm or kill anyone with the lethal weapon of his car. The severity of the crash shows the sheer negligence of the officer, who drove with absolutely no concern for the safety of residents or the laws of New York State for emergency personnel. Unfortunately, this is not isolated behavior on the part of the TPD. 

Troy PD has a history of reckless accidents:

  • February 22, 2023 – Hoosick and 15th St – TPD killed a local father and respected worker
  • February 2023 – TPD entered an intersection speeding without a siren or slowing and nearly hit a car with a mother and her infant
  • October 2021 – Middleburg St and 6th Ave – TPD ran a red light and totaled a car in the intersection
  • June 2021 – 5th Avenue in Lansingburgh – TPD ran a red light and totaled a car in the intersection, but ticketed the driver for failure to yield
  • January 2020 – TPD ran a red light totaling a work van in an intersection that sent the small business owner and father to Albany Medical Center with serious expenses, missed work, and a ticket for failing to yield to an officer despite video surveillance showing that TPD failed to slow while approaching a blind intersection
  • July 2009 – a 5-year-old boy was killed by a TPD officer driving an unmarked SUV in South Troy 

Long-standing community demands for deep changes in Troy policing policy and practices have been ignored by Mayor Madden, the Troy City Council, Troy Police, and the Rensselaer County DA for years. Troy needs accountability and transparency led by those who are directly impacted by police violence and negligence. This includes: 

  • an end to over-policing of Black and Brown communities, 
  • an end to harassment of Black and Brown youth, 
  • community-based alternatives to law enforcement in response to mental health and other crises, 
  • investments in resources for our communities instead of more investment in police – for example, getting the lead out of the water of all Troy households while prioritizing the most vulnerable households.

Instead of listening to the voices of community leaders, the city has offered us public relations campaigns to protect the Troy Police and City rather than the lives in our community. Just this month, the New York Civil Liberties Union won a lawsuit against the Troy Police Department for refusing to provide police officers’ disciplinary records as required by a recent reform to New York State law. 

We do not want a kinder, gentler face on police violence. We do not want our taxes to fund TPD’s $19.5 million dollar budget. We want our children and families to be safe and community well-being to be prioritized by the entire city. We want Black Life to matter by divesting from police and investing in the support systems the community actually needs. 


Troy for Black Lives
Democratic Socialists of America, Troy Chapter
Community Rising Project
Equality For Troy
Members of Ad Hoc Troy
Troy Area Labor Council AFL-CIO

Letter to Fred Miller of Kaleel Jamison Consulting Group

We recently received a request from Fred Miller of Kaleel Jamison Consulting Group, asking to join one of our meetings to promote the work they’ve done with Troy Police Department.

We are not interested. This is our full response.

Dear Fred,

We received your request to come to our meeting “to share information about our work with the Troy Police Department and the May event … and answer any questions. We only need 10-15 minutes on your agenda.” 

You’ve done work with the City of Troy and the Troy Police Department for two years with no community involvement until now. To presume that 10-15 minutes to talk at our membership about your solutions to problems we were never originally consulted on underscores that this is nothing but a public relations campaign to whitewash the Troy Police Department’s long history of reckless and hateful violence. 

We are not interested in exposing our members or the community to your pro bono work to overhaul the TPD’s reputation. We are connected to this community as residents, students, workers, parents, and neighbors. When we received this invitation, our first step was to check who else you’ve included in this long process up to now. We were made aware that you have not reached out to prominent Black-led organizations, and your work has lacked transparency and real outreach. By removing the voices of those most impacted by police violence, you told us everything we need to know about your event.

You are not welcome in our space, because you represent cops, not the people of Troy. Cops hurt the people in our community. This is a fact. The Times Union’s editorial board released a statement today on the city’s secrecy around police disciplinary records, and the long history of violence against Black and Brown people in Troy. Meanwhile all media outlets are covering how an officer killed a young man while driving recklessly through a dangerous intersection.

The people in our communities do not need to be subjected to your PR campaign about emotionally disturbed persons training and six new community officers. The City and TPD have repeatedly ignored years of outreach, activism, political involvement, social justice work, requests from leaders and non-profits, an executive order from the NYS governor, and the cries of 11,000 people in the streets of Troy.

We provided our recommendations publicly in the past. We’d like to know how many of those were considered in your work. You can share the status of that free labor in writing.

Troy DSA encourages anyone who received a similar invitation to boycott this meeting in May. 

-Troy DSA

Challenging Troy’s RECODE Proposal

Part I: Falling Short

The proposed Troy zoning code, ReCode Troy, is a missed opportunity to make a real impact on our code. The revisions, as they stand, are at least marginally an improvement on our existing zoning code. They’re even an improvement compared to many municipal codes in the area. But what they lack is the follow-through in the vision they paint for the future of Troy. In fact, while the code itself cites climate change and a high-quality urban environment as part of its purpose statement, it falls short in a few, critically important ways.

First, the Single-Family use districts – and Neighborhood I zones in the quasi-form-based code proposed here – are systemically racially discriminatory and classist, contribute to a tremendous amount of traffic violence, and is essentially climate change denial in land use form. 

While the purpose statement did not address social equity and racial justice, it should have. The issue is too important to the residents of Troy, and our regulation of land use has a direct impact on these issues. The connection between single-family zoning and redlining is well established (The Color of Law by Richard Rothstein to name but one among many, many other books, academic articles, essays, and other research). Additionally, the exclusion inherent in single-family zoning that disproportionately affects people of color also extends to anyone of lesser means – excluding them from living closer to jobs, recreation, commercial opportunities, natural resources, schools, and other community resources. 

This land use means that the working class (which are disproportionately people of color) must travel farther to access these resources – to the extent that they are allowed to at all. The farther travel means even higher costs of driving and further reliance on vehicles that are expensive to operate and maintain. It means longer transit trips that are exacerbated by the sprawling form of development encouraged by single-family zoning. It means more dangerous bike, pedestrian, and driver journeys from frustrated and distracted drivers that are compelled to slog through endless traffic promoted by this zoning. 

These extended journeys also highlight how single-family zoning is climate denial in land use form – it requires nearly everyone to drive everywhere. Since even short walking or bike trips feel unsafe because the development pattern prioritizes vehicle movement, most people drive – continually adding more and more carbon, brake and tire dust, and other pollutants into our neighborhoods. 

Single-family zoning also is incredibly inefficient. From the amount of energy needed to heat, cool, light, and generally operate larger, detached houses to the horrendously polluting lawn equipment, loosely regulated application of pesticides and fertilizer, and the tremendous amount of fresh water applied to larger lawns, the single-family zoning that encourages this type of built environment is simply unacceptable with the climate crisis now in the single digit years away from irreversible tipping points leading unimaginable death, suffering, and strife. With all of us collectively staring down the barrel of such a future, how can we tolerate doing more of the same things that got us into this mess any longer? To begin to improve a situation, we have to stop doing the behavior that got us into it.

While a zoning code cannot – on its own – solve the climate crisis, it actually does play a massive role. We can stop making things worse, and perhaps even begin to reverse some of the damage that we’ve collectively inherited. Just as important, we can also stop reproducing structures rooted in racism and classism. We should simply not have any single-family districts or Neighborhood I zones in the city of Troy.

It’s important to remember that a zoning ordinance is not (as we sometimes think about it) a document about what we want to see where. It is a document about what cannot be where. Single-family dwellings can still be built in all of the residential zones (aside from the Downtown and Waterfront Mixed Use districts). Single-family districts (and Neighborhood I zones) are exclusionary to large swathes of the residents of Troy – both current and future – and compounds this social ill with safety and ecological ills at the same time. In 2022, we should have the courage, and vision, to say that Troy has progressed beyond exclusion, carnage, and denial. Troy should be leading the way for the region, state, and country by embracing an equitable, livable, and sustainable future. We should meet this moment with the urgency that the climate crisis requires, the resolve that inequity demands, and the boldness that our future promises.

Part II: Double Fault

While the Single-Family districts and Neighborhood I zones are where the draft zoning falls the most short of an equitable, safe, sustainable, and livable Troy, there are other issues. While the Two-Family and Multi-Family districts don’t impart the same level of exclusion that single-family districts impose, there are exclusionary aspects included within these districts as proposed. 

Two-family dwellings are certainly better than single-family, but, when combined with the Neighborhood I intensity zone, it’s not that much of an improvement. It’s not clear what the Two-Family district accomplishes as compared to the Multi-Family or Mixed-Use districts in the same intensity zones other than being exclusionary. Two-family (and even single-family) housing would still be permitted in both, if the developer so chose. It’s exclusion for the sake of exclusion, we can, and should move on from such structural harm.

Additionally, the exclusion of nearly all commercial activity in the Two-Family and Multi-Family districts further raises the barrier to entry for low-income populations and people of color to entrepreneurship. With the existence of old storefronts in proposed residency-exclusive districts, the City is taking opportunities for these communities to access lower cost spaces to conduct neighborhood commercial business, while at the same time foreclosing opportunities to repair and reanimate these spaces. The exclusion of nearly all commercial uses in these districts also increases the likelihood that residents will drive to commercial areas – undermining the market for smaller, local business and adding to the twin evils of car-centered development: traffic violence and pollution. Further, this exclusion of neighborhood retail impacts basic livability. The ability to access basic grocery items from a bodega, grab a sandwich from a deli, a cup of coffee from a coffee shop, or drop off some laundry at laundromat right around the corner from one’s home would all be denied to large chunks of Troy – with some residents needing to walk several blocks (possibly a half mile or more in some cases) to reach an area where these commercial activities might be located.

The three residency-exclusive districts are simply unnecessary, and are actually harmful to the residents of Troy. Eliminating Two-Family and Multi-Family districts, and instead adopting Mixed-Use 1 as the default use district (with perhaps some edits to things like small bars or gas stations requiring Special Use Permits) would result in a more equitable, sustainable, and livable Troy.

Part III: By A Thousand Cuts

To make the critique of the remainder of the code more efficient, the issues are bulleted below. 

  • Site Plan Review
    • Doesn’t require review for single/double family structures, but does for multi-family. There should be parity – allow for multi-family exemption as well in Neighborhood II/III/IV or require for single/double
    • Exemption for 5 additional parking spaces would mean 10 spots for up to 6 bedrooms. Remove exemption all together or at least tie to # of bedrooms (i.e. any more than 1 space per bedroom must submit a site plan)
    • Says the Planning Commission may hold a public hearing, leaving the possibility that projects that deserve a public hearing may not get it. Establish standards (or at least guidance) for when there must be a public hearing
  • Variances
    • The variance criteria is restrictive. While this is not bad, per se, use variance has been offered as a remedy by current elected officials to potential future non-conforming uses. The variance criteria is unlikely to allow uses like neighborhood retail (i.e. coffee shops, bodegas, laundry facilities, day care) in the Single, Double, and Multi Family districts – even when there are existing out-of-use store fronts that could provide lower barriers to entry for such small businesses in those districts. Even the act of seeking a variance is adding to costs and erecting barriers, especially when it’s not clear what the compelling public interest is in not allowing such uses
  • Powers and duties of Zoning Board of Appeals
    • Unclear what threshold, if any, is needed for adoption in the case of a rehearing
      • If a rehearing is needed – why would the standard be different?
    • Attendance section doesn’t address attendance
      • Should be *some* sort of standard and provision for removal based on attendance and/or training
  • Penalties
    • While it may be customary to include imprisonment in penalties, it’s hard to understand what the public utility would be to imprison someone for zoning violations
    • This is an opportunity to impose a schedule of income-based fines. Established systems use “day fines” – scaling fines to increments of the violators daily income
  • Accessory Dwelling Units
    • It should be noted that the inclusion of accessory dwelling units (ADUs, or granny flats) is a step in the right direction, and should absolutely be lauded. The inclusion of ADUs as a permissible use in nearly all residential districts is a feature that should remain, but we should also acknowledge that this is insufficient to overcome the social, safety, and environmental destruction that single-family districts inflict
  • Neighborhood Zones:
    • The lot width requirement in Neighborhood II zone should be reduced or eliminated for many of the same reasons mentioned in Section I and II of this document above
    • Neighborhood II should be the lowest acceptable intensity in the city of Troy
    • Neighborhood III and IV are not meaningfully different and should be combined to the standards of Neighborhood IV, with the addition of allowing porches. The new combined zone should be applied to more of the city – it’s a flexible intensity and should balance existing character while allowing more density in more places
    • There are a few typographical errors in the Development Intensity Zone lot development standards (graphics not agreeing with text in Neighborhood II, V)
    • It seems incongruous that Neighborhood IV has a minimum of 2 stories, but Downtown Edge has just 1? Whether an error or not, to be adjacent to the Downtown core – where 8 story (100’) buildings are allowed – to allow anything less than 3 stories in the Downtown Edge is perplexing. Further, the Downtown Edge should probably allow up to (at least) 6 stories. The basic idea in form-based codes is that development gets more intense the closer to the core, and this doesn’t really do that effectively
    • Again, the Downtown Core somehow allows a 1 story building – seemingly at odds with the purpose of a form-based code. With a variance system in place, it’s hard to imagine the point of setting the minimum so low in the Downtown Core
  • Adult Uses
    • The prohibition of more than one adult use per lot, the 750 foot buffer between lots supporting adult uses, and the 250 foot buffer from the many other uses are overly burdensome and antithetical to dense urbanism that is promoted throughout the rest of the document. Having more than one use per lot is convenient to customers and residents, provides agglomeration effects to the businesses, and results in less driving and contributes to walkability. The 750 foot buffer, for similar reasons, should be dropped altogether – or at least reduced
    • The 250 foot buffer to the long list of other uses is likely to be a de facto prohibition of adult uses entirely – particularly to the dense development pattern of the majority of Troy. This buffer should be reduced, and the list of uses that must have a buffer should also be pared down (cemeteries, community centers, parks, and public recreational facilities in particular defy compelling explanation for their inclusion on such a list)
    • Similarly, the provision regarding the observation of business activity is overly broad. In particular, the use of “relating to any sexual act or any part of the sexual anatomy” and the application to “any display, decoration, sign, show, window, or other opening” could reasonably be interpreted to ban just about anything that these businesses could reasonably display at all. How would the business let the public know about its existence/location without running afoul of the zoning ordinance? 
    • The existence of sexuality-related commerce doesn’t need to be – and shouldn’t be – shameful. Using the zoning ordinance to regulate adult uses as proposed is ham-fisted, and should use a lighter touch. The city council can always regulate these businesses with stand-alone regulations to address it the manner it deserves – well-thought out, supportive of the workers at these businesses, safe, and without shaming sex itself
  • Agriculture
    • Provision regarding composting for community gardens is overly restrictive as many smaller lots would be unlikely to be able to comply with this provision. It’s also not clear why this restrictive zoning regulation is better to deal with potential issues than an education/demonstration/simple certification requirement
    • The requirement of a Site Plan for smaller urban farms is overly burdensome, and a threshold establishing that smaller operations should be exempt from this provision, or complete a simplified version – particularly with respect to the equipment needed and frequency and duration of chemicals/pesticide application as conditions (that may not be within the control of the business owner) may change that alter these answers
    • Requiring that no “dust or odors [be] detectable off the property” is prima facie absurd for a farming operation. There will be odors and dust, but are they any more of a nuisance than the odors coming from other unregulated uses, or simply the neighbors trash? By what standard will a determination of “detrimental to the public health, safety, or welfare” be made?
    • How will prohibiting slaughter of chickens or rabbits be enforceable? Why is a prohibition – and resulting fine – better for the public good than simply requiring education/certification?
  • Cannabis dispensaries/retail, tobacco, hookah, vaping establishments
    • The buffers from public parks, schools, or religious institutions are too large and restrictive. It’s particularly not clear why parks should be included in this list as it is legal to smoke in certain parts of parks
    • The buffer from other establishments of this type is both confusing and inappropriate. It’s not clear what the “type” is referring to in this provision – 500 ft between tobacco establishments or between any one of these establishments. The buffer is onerous under any interpretation, but particularly with the latter. Dense, walkable cities tend to have industry districts, and that is a benefit to residents
  • Convenience Stores
    • The 500 foot buffer requirement in this section is antithetical to the concept of convenience. It’s not guaranteed that any particular store will carry the items that one needs or desires, and this buffer ensures that residents are inconvenienced. Allowing variety and different stores to cater to different customer bases should be encouraged, not discouraged. Having convenience stores at the same intersection is a boon to livability! This is easily the most anti-urban provision of the additional regulations on use, it should be eliminated
  • Home-based businesses
    • The hours for client visits are too restrictive, client visits should be allowed to terminate as late as 10pm
  • Parking, loading and transportation
    • Off-street parking
      • While establishing maximums, rather than minimums, is an excellent move, the maximums established by Schedule C are simply too high – especially since applicants can petition for 20% more. Dropping these maximums by 20%, establishing a “or one parking space per bedroom, whichever is lower” provision as-of-right, and maintaining the ability to petition for 20% of the new lower threshold is an appropriate balance
    • EV charging
      • Extend requirements for any surface lot to have at least one charging station and a ratio of 1 charging station per 3 spaces for any use district containing residential uses – while the other uses should retain the 1 to 10 ratio. With the proliferation of EVs, their share of total vehicles will necessitate far more charging infrastructure moving forward
    • Bike Parking
      • Extend the requirement for short term bike parking to any surface lot, and require a minimum of three bike spots – a three-bike rack is simple enough to install, in terms of materials, labor, and space
      • Increase the minimum rate of long term bike parking for multi-family residential and community residential by one space
  • Public space enhancements and placemaking elements
    • This provision is great, even if it’s not terribly strong. One way to improve this would be to prohibit the use of hostile architecture in these elements, as they are cruel, inhumane, and harm all users of public space
  • Stormwater management standards
    • Single- and two- family dwellings should not be exempt from the urban runoff control provisions as such dwellings can collectively be a large source of runoff. The smaller impact of individual disturbances shouldn’t exempt the activities when there is such a potential for their collective impact to be quite large
  • Sidewalks
    • Despite being mentioned 57 times in the document, there doesn’t seem to be a direct, explicit requirement to build sidewalks. If there isn’t, then one should be established
    • To think a bit bigger, Troy should consider a municipal sidewalk program – where the city assists with creation and maintenance of sidewalks throughout the city, particularly with snow removal in winter. Such a program could assist with financing of derelict or missing portions of the sidewalk network, as well as conduct repairs and maintain accessibility during all seasons. The benefits would be most acutely felt among those mobility impairments – both temporary and permanent, but would also be tremendously beneficial to anyone making their way around the city. While such a program could be more fleshed out in other parts of the code or other legislation, there may be an opportunity to support a program via zoning through permanent easements, incentives, or some combination of mechanisms.
  • Director of Code Enforcement Powers
    • While there is some ability to appeal to the Zoning Board of Appeals, the Director is also charged with delivering the appeal – which seems like an issue to someone who is seeking relief from a Director that is acting in bad faith/abusing authority. A non-exhaustive list of the Director’s duties/powers:
      • Issuing a CO for partial occupancy
      • Issuing a temporary CO 
      • Determining whether an alteration to the exterior of the principal structure qualifies for exemption to Site Plan requirement
      • Exemption to Site Plan requirement
      • Revoke Special Use Permit
      • Boundary/lot line adjustments that “do not result in the creation of any additional buildable lot(s); or the creation of any non-conforming lot, structure, or use; or the creation of any new public or private street”
      • Override a stay of enforcement during appeal
      • Issue temporary permits for structures or uses
      • Decides when violation is corrected and time frame for correcting
      • Power to waive violation fee
      • Issue appearance tickets
      • Initiate court actions
      • Interpret district and zone boundary lines
      • Transmit appeals to ZBA
    • Providing a means to appeal directly to the ZBA, the ability of the ZBA to discipline (or recommend it to the council) the Director of Code, and empowering/requiring the ZBA/Director of Code to employ outside experts on subject matters beyond its expertise (i.e. hydrology, agriculture, transportation planning) would all be ways to balance the enormous power given to the Director.