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Executive Summary
This document outlines the Township of Robbinsville's Housing Element and Fourth-Round Fair Share Plan (2025-2035), prepared in accordance with New Jersey's Fair Housing Act. The plan addresses the Township's obligation to provide its fair share of affordable housing, focusing on both cumulative obligations from previous rounds and prospective needs. Key components include strategies to address rehabilitation, prior round, third-round, and fourth-round obligations, and to achieve a mix of affordability levels and unit sizes. The plan complies with the amended Fair Housing Act, including guidelines from Administrative Directive #14-24.
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--- Document: Fair Share Housing Plan (2025) Document ---
This document has been prepared in accordance with N.J.S.A 52:27D-310 and
the Fair Housing Act P.L.1985, c.222
The Township of Robbinsville
Housing Element
and
Fourth-Round
Fair Share Plan
(2025-2035)
The County of Mercer
Date Prepared
Adopted On
_______________________
______________________
Mayor
David Fried
Planning Board
Frank Cettina, Chair
Daniel Jackson, Vice Chair
Bill Berdan
Michael Brennan
Harsh Bhatt
Vincent J. Calcagno
Michael Caputo
Christine Ciaccio
Kathy Goodwine
Ravi Patni
Danielle Spilatore
Sanjot Savant
Regina Wilder
Land Use Board Attorney:
Jerry Dasti, Esq.
Township Planner:
Stuart Wiser
Land Use Board Secretary:
Tianna Thompson
Administrative Officer:
Tianna Thompson
It is certified that all copies of this document are in conformance with the one signed and sealed by
Christine Cofone, P.P, License #5517
_______________________________________
Prepared by:
Cofone Consulting Group, LLC
Christine Cofone, AICP, PP | Justin Auciello, AICP, PP | Amanda D’Addario, AICP
52 Reckless Place
Red Bank, NJ 07701
732-933-2715
ccofone@cofoneconsulting.com
TABLE OF CONTENTS
I.
Introduction
1
A.
Executive Summary & Introduction
1
B.
Summary of Judicial and Legislative Background of Affordable Housing in New Jersey
2
C.
Affordability Requirements
3
D.
Housing Element and Fair Share Plan Requirements
5
II.
The Housing Plan Element
8
A.
Analysis of Housing Stock
8
Age of Units
8
Condition of Units
9
Purchase and Rental Value
11
B.
Projected Housing Stock
12
C.
Municipality’s Demographic Characteristics
13
Population
13
Population Age
14
Household Income Level
14
Household Type
15
D.
Employment Characteristics
16
III.
Fair Share Plan
17
A.
Introduction
17
B.
Cumulative Fair Share Obligation
17
C.
Addressing the Townships Rehabilitation Obligation
19
D.
Addressing the Township’s Affordability Assistance Obligation
19
E.
Prior Round Obligation
19
F.
Third-Round Obligation
20
G.
Fourth-Round Obligation
21
1.
Site Suitability Analysis
23
2.
Group Homes
31
3.
Creditworthiness of Existing Affordable Housing Units
32
4.
Compliance Analysis
32
5.
Very Low / Low / Moderate Income Requirements
32
6.
Preservation of Multigenerational Family Continuity
33
7.
Mandatory Set Aside Ordinance
33
8.
Development Fee Ordinance
33
9.
Spending Plan
34
10.
State Development and Redevelopment Plan Consistency
35
11.
Consideration of Lands Appropriate for Affordable Housing
36
12.
Cost Generation
36
13.
Monitoring
37
2
IV.
Appendix
38
A.
All Zoning Amendments
B.
Affordable Housing Ordinance
C.
Set Aside Ordinance
D.
Development Fee Ordinance
E.
Affirmative Marketing Plan
F.
Spending Plan
G.
Resolution of Intent
H. Copies of Resolutions
I.
2017 Housing Element Plan
J.
2018 Housing Element Plan
K.
Rehabilitation Completion Status Information
The Township of Robbinsville
Housing Element and Fair Share Plan – 2025
1
I.
Introduction
A. Executive Summary & Introduction
In 1975, the New Jersey Supreme Court decision of Southern Burlington NAACP
v. Mount Laurel Township ruled to outlaw exclusionary zoning, and required all
New Jersey municipalities to provide their “fair share” of affordable housing. This
decision was borne out of the recognition and acknowledgement that “disparities
in wealth, health, and general well-being are inextricably linked to housing access,
making residential segregation a public health issue” according to the Fair Share
Housing Center. From the Mount Laurel decision, came the Mount Laurel Doctrine,
which mandates that municipalities must utilize their zoning powers to provide their
share of the region's affordable housing.
In New Jersey, affordable housing is defined as units reserved for households
earning no more than 80% of the regional median income. With limited exceptions,
each unit must remain affordable for at least 30 years—and 40 years for Fourth-
Round rental units—typically through a deed restriction. Each qualifying unit earns
one credit toward a municipality’s obligation, with certain units eligible for bonus
credits, offering more than one credit per unit. Municipalities must also ensure a
mix of affordability levels (very-low, low, and moderate income) and unit sizes
(one-, two-, and three-bedroom) to meet compliance standards.
This housing plan focuses on addressing the Township’s obligations for the Fourth-
Round of affordable housing, as defined by an amendment to the Fair Housing Act
enacted in March 2024. This round covers the period from July 1, 2025, through
June 30, 2035. Because one of the two primary components of the affordable
housing obligation is cumulative, this plan also includes strategies to satisfy
obligations from previous rounds. As a result, readers will recognize that several
elements from the Township’s Third-Round Housing Element and Fair Share
Plan—adopted by the Planning Board on April 10, 2023—are carried forward here.
The 2024 amendments to the Fair Housing Act initiated a structured process with
specific deadlines, requiring close coordination between the Township’s
Governing Body and the Planning Board. These actions are necessary for any
municipality seeking to comply with the Mount Laurel Doctrine, which mandates
that all New Jersey municipalities provide a fair share of affordable housing for
both current and future residents.
To determine the number of affordable housing units each municipality must
provide, the Division of Community Affairs performs calculations based on existing
deficient housing, each region's Income Capacity Factor, the municipal population,
existing land capacity, and the local capacity to accommodate growth. The
purpose of this Housing Element and Fair Share Plan is to outline how the
Township of Robbinsville intends to meet its constitutionally mandated affordable
housing obligation.
2
B. Summary of Judicial and Legislative Background of Affordable Housing in
New Jersey
New Jersey’s affordable housing framework is grounded in the landmark Mount
Laurel decisions, which require municipalities to provide realistic opportunities for
low- and moderate-income housing. The 1983 Mount Laurel II ruling introduced
the builder’s remedy, allowing higher-density developments with affordable units
even on non-zoned sites.
In response, the Legislature enacted the Fair Housing Act (FHA) in 1985,
establishing the Council on Affordable Housing (COAH) to manage municipal
compliance. COAH administered three planning rounds. The first two (1987–1993
and 1993–1999) assigned municipalities both rehabilitation and projected growth
obligations—now known as the "prior round." The Third-Round (1999–2025)
attempted to link housing obligations to development through a “growth share”
model, which was later invalidated by the courts. COAH’s failure to adopt new rules
led the New Jersey Supreme Court to deem the agency defunct in 2015,
transferring jurisdiction to the courts. Municipalities now secure plan approval
through declaratory judgment actions, protecting them from builder’s remedy
litigation.
In 2017, the Court determined that the 1999–2015 "gap period" generated a
separate housing obligation. Together with rehabilitation, prior round, and
prospective need, this gap-period need forms today’s cumulative housing
requirement. Subsequent legislative updates have strengthened the framework.
The 2008 FHA amendments eliminated regional contribution agreements and
introduced requirements for very low-income housing. In 2020, new transparency
measures required all affordable units to be listed publicly.
Most notably, Public Law 2024, Chapter 2, permanently dissolved COAH and
assigned the Department of Community Affairs (DCA) the task of calculating
Fourth-Round obligations for 2025–2035. While these figures are advisory, the law
established a court-based Affordable Housing Dispute Resolution Program and
imposed stricter standards for Housing Element and Fair Share Plans, including
site suitability analysis, verification of affordability controls, and evidence of
realistic unit delivery.
Administrative Directive #14-24, issued in December 2024, further defined these
requirements, mandating that municipalities document zoning, affordability
mechanisms, unit feasibility, and implementation strategies through formal
ordinances and resolutions.
3
C. Affordability Requirements
Under New Jersey’s Fair Housing Act (FHA), affordable housing is defined as a
dwelling—whether for sale or rent—that falls within the financial reach of very-low,
low-, or moderate-income households, as determined within each designated
housing region. Robbinsville is located in Region 4, which comprises Mercer,
Monmouth, and Ocean counties.
Moderate-income households are those earning more than 50% but less than 80%
of the regional median income. Low-income households earn 50% or less of the
regional median. Very-low-income households, a subset of the low-income
category, are defined as those earning no more than 30% of the regional median
income.
Pursuant to the Uniform Housing Affordability Controls (UHAC) at N.J.A.C. 5:80-
26.3 et seq., rent and sale prices for affordable housing must align with defined
income thresholds. Maximum rent must be affordable to households earning no
more than 60% of the regional median income, while the average rent must be
affordable to those earning no more than 52%. For ownership units, the maximum
sale price must be affordable to households earning up to 70% of the median
income, with the average sale price affordable to those earning no more than 55%.
Regional median income figures are established annually by the U.S. Department
of Housing and Urban Development (HUD) and serve as the basis for setting
affordable rents and sale prices. Following Mount Laurel IV, income limits are now
set by Court Order.
Income limits for all units included in the Township’s Housing Element and Fair
Share Plan—excluding those governed by federal programs—shall be updated
annually upon HUD’s publication of revised median incomes, using the following
process:
● Regional income limits for Region 4 (which includes Monmouth, Mercer,
and Ocean Counties) shall be based on a weighted average of
uncapped Section 8 income limits published by HUD. This is calculated
by multiplying HUD’s median income for a four-person household by the
number of households in each county per the latest Census, summing
these products across the region, and dividing by the total number of
households in Region 4. The result is the weighted regional median
income for a household of four.
● Income limits for affordable housing shall be set as follows: 80% of the
regional weighted median income for moderate-income households,
50% for low-income households, and 30% for very low-income
4
households. These limits are adjusted by household size using HUD
multipliers and may not fall below the previous year’s levels.
● The Regional Asset Limit, used to determine applicant eligibility under
N.J.A.C. 5:80-26.16(b)3, shall also be updated annually. The Township
will calculate the percentage increase in income limits year over year
and apply the same percentage to adjust the Regional Asset Limit. This
limit, too, shall not decrease from the prior year.
● For 2024, income limits for all housing regions in New Jersey—
including Region 4—were developed jointly by the Affordable Housing
Professionals of New Jersey (AHPNJ) and Fair Share Housing Center
(FSHC), using the methodology described above. These court-
approved limits will be applied to Robbinsville. See Table 1 for the 2024
income limits for Region 4.
Table 1
Maximum Gross Income by Household Size for Housing Region 4
Household Size
Very-Low
Low
Moderate
1
$27,311
$45,519
$72,830
2
$31,213
$52,022
$83,234
3
$35,115
$58,524
$93,639
4
$39,016
$65,027
$104,043
5
$42,137
$70,229
$112,367
6
$45,259
$75,431
$120,690
7
$48,380
$80,633
$129,013
8
$51,501
$85,836
$137,337
Source: Affordable Housing Professionals Of New Jersey (Ahpnj) ‐ April 12, 2024, 2024 Affordable Housing Regional Income Limits
By Household Size Prepared By Affordable Housing Professionals Of New Jersey.
Https://Ahpnj.Org/Member_Docs/Income_Limits_2024_Final.Pdf
The following tables present illustrative 2024 gross rents and sale prices. These
figures are for demonstration purposes only and do not reflect adjustments for
utility allowances (rentals) or variables such as mortgage rates, taxes, or other
financing factors (sales).
Table 2
Illustrative 2024 Affordable Gross Rents for Region 4
Household Income Levels
1 Bedroom
2 Bedroom
3 Bedroom
Moderate
$2,060
$2,475
$2,850
Low
$1,280
$1,545
$1,785
Very Low
$770
$925
$1,071
Source: 2024 Affordable Housing Pricing Calculator prepared by Affordable Housing Professionals of New Jersey
5
Table 3
Illustrative 2024 Affordable Gross Sales for Region 4
Household Income Levels
1 Bedroom
2 Bedroom
3 Bedroom
Moderate
$190,029
$229,913
$267,137
Low
$133,053
$161,541
$188,130
Very Low
$118,909
$144,448
$168,378
Source: 2024 Affordable Housing Pricing Calculator prepared by Affordable Housing Professionals of New Jersey.
D. Housing Element and Fair Share Plan Requirements
Under the Municipal Land Use Law (N.J.S.A. 40:55D-1 et seq.), every municipal
master plan must include a housing element to support its zoning ordinance.
Pursuant to the amended Fair Housing Act, (N.J.S.A. 52:27D-310), this Housing
Element and Fair Share Plan includes the following components:
a. An inventory of the municipality’s housing stock by age, condition,
purchase or rental value, occupancy characteristics, and type, including
the number of units affordable to low- and moderate-income households
and substandard housing capable of being rehabilitated;
b. A projection of the municipality’s housing stock, including the probable
future construction of low- and moderate-income housing, for the next ten
years, taking into account, but not necessarily limited to, construction
permits issued, approvals of applications for development, and probable
residential development of lands;
c.
An analysis of the municipality’s demographic characteristics, including,
but not necessarily limited to, household size, income level, and age;
d. An analysis of the existing and probable future employment
characteristics of the municipality;
e. A determination of the municipality’s present and prospective fair share
of low- and moderate-income housing and its capacity to accommodate
its present and prospective housing needs, including its fair share of low-
and moderate-income housing, as established pursuant to section 3 of
P.L. 2024, c.2 (C.52:27D-304.1);
f.
A consideration of the lands most appropriate for construction of low- and
moderate-income housing and of the existing structures most appropriate
for conversion to, or rehabilitation for, low- and moderate-income
housing, including a consideration of lands of developers who have
expressed a commitment to provide low- and moderate-income housing;
g. An analysis of the extent to which municipal ordinances and other local
factors advance or detract from the goal of preserving multigenerational
family continuity as expressed in the recommendations of the
Multigenerational Family Housing Continuity Commission, adopted
pursuant to paragraph (1) of subsection f. of 23 section 1 of P.L.2021,
c.273 (C.52:27D-329.20); and
6
h. An analysis of consistency with the State Development and
Redevelopment Plan, including water, wastewater, stormwater, and
multi-modal transportation based on guidance and technical assistance
from the State Planning Commission.
In addition to FHA requirements, this Fourth-Round HEFSP complies with the
standards outlined in Administrative Directive #14-24, issued by the Administrative
Office of the Courts on December 13, 2024:
1. One of the requirements for a final HEFSP is the inclusion of detailed site
suitability analyses, based on the best available data, for each of the un-
built inclusionary or 100 percent affordable housing sites in the plan as
well as an identification of each of the sites that were proposed for such
development and rejected, along with the reasons for such rejection.
2. The concept plan for the development of each of the selected sites should
be overlaid on the most up to date environmental constraints map for that
site as part of its analysis. When the detailed analyses are completed,
the municipality can see what changes will be needed (either to the
selected sites or to their zoning) to ensure that all of the units required by
the settlement agreement will actually be produced. If it becomes
apparent that one (or more) of the sites in the plan does not have the
capacity to accommodate all of the development proposed for it, the
burden will be on the municipality either to adjust its zoning regulations
(height, setbacks, etc.) so that the site will be able to yield the number of
units and affordable units anticipated by the settlement agreement or to
find other mechanisms or other sites as needed to address the likelihood
of a shortfall.
3. The final HEFSP must fully document the creditworthiness of all of the
existing affordable housing units in its HEFSP and to demonstrate that it
has followed all of the applicable requirements for extending expiring
controls, including confirmation that all of the units on which the controls
have been extended are code-compliant or have been rehabilitated to
code-compliance, and that all extended controls cover a full 30-year
period beginning with the end of the original control period.
Documentation as to the start dates and lengths of affordability controls
applicable to these units and applicable Affordable Housing Agreements
and/or deed restrictions is also required. Additionally, the income and
bedroom distributions and continued creditworthiness of all other existing
affordable units in the HEFSP must be provided.
7
4. The HEFSP must include an analysis of how the HEFSP complies with
or will comply with all of the terms of the executed settlement agreement.
Once the HEFSP has been prepared, it must be reviewed by Fair Share
Housing Center and the Program’s Special Adjudicator for compliance
with the terms of the executed settlement agreement, the FHA and
Uniform Housing Affordability Controls (“UHAC”) regulations. The
HEFSP must be adopted by the Planning Board and the implementation
components of the HEFSP must be adopted by the governing body.
The HEFSP must also include (in an Appendix) all adopted ordinances and
resolutions needed to implement the HEFSP, including:
1. All zoning amendments (or redevelopment plans, if applicable).
2. An Affordable Housing Ordinance that includes, among other required
regulations, its applicability to 100 percent affordable and tax credit
projects, the monitoring and any reporting requirements set forth in the
settlement agreement, requirements regarding very low income housing
and very low income affordability consistent with the FHA and the
settlement agreement, provisions for calculating annual increases in
income levels and sales prices and rent levels, and a clarification
regarding the minimum length of the affordability controls (at least 30
years, until the municipality takes action to release the controls).
3. The adoption of the mandatory set aside ordinance, if any, and the repeal
of the existing growth share provisions of the code.
4. An executed and updated Development Fee Ordinance that reflects the
court’s jurisdiction.
5. An Affirmative Marketing Plan adopted by resolution that contains
specific directive to be followed by the Administrative Agent in
affirmatively marketing affordable housing units, with an updated COAH
form appended to the Affirmative Marketing Plan, and with both
documents specifically reflecting the direct notification requirements set
forth in the settlement agreement.
6. An updated and adopted Spending Plan indicating how the municipality
intends to allocate development fees and other funds, and detailing (in
mini manuals) how the municipality proposes to expend funds for
affordability assistance, especially those funds earmarked for very low-
income affordability assistance.
8
7. A resolution of intent to fund any shortfall in the costs of the municipality’s
municipally sponsored affordable housing developments as well as its
rehabilitation program, including by bonding if necessary.
8. Copies of the resolution(s) and/or contract(s) appointing one or more
Administrative Agent(s) and of the adopted ordinance creating the
position of, and resolution appointing, the Municipal Affordable Housing
Liaison.
9. A resolution from the Planning Board adopting the HEFSP, and, if a final
Judgment is sought before all of the implementing ordinances and
resolutions can be adopted, a resolution of the governing body endorsing
the HEFSP.
II.
The Housing Plan Element
A. Analysis of Housing Stock
Age of Units
Table 4 below reflects that the housing stock in the Township comprises 6,084
total units, with the majority of residential development occurring between 1980
and 1999. Specifically, 1,592 housing units (26.2%) were constructed during the
1980s, followed closely by 1,738 units (28.6%) built in the 1990s, indicating a
period of substantial residential growth. An additional 1,260 units (20.7%) were
developed between 2000 and 2009, while more recent construction from 2010 to
2019 accounts for only 334 units (5.5%). Older housing comprises a smaller
portion of the overall stock, with units built prior to 1980 representing less than 20%
combined. Notably, there have been no new housing units reported as constructed
in 2020 or later. This distribution suggests that while the Township experienced its
most significant residential expansion in the late 20th century, new construction
activity has slowed in the last decade.
9
As per the 2023 American Community Survey 5-Year Estimates, in Robbinsville,
361 units (5.9%) of the housing stock were built before 1960. This is generally an
important indicator in calculating Robbinsville's Rehabilitation Share and explains
why Robbinsville's Present Need (substandard housing) Share is 40 units. While
age of housing stock is one indicator, it is noteworthy that homes do not need to
be 50-years or older to be eligible for participation in the rehabilitation program.
Condition of Units
The first step the Division of Community affairs took in calculating the present need
and deficient Low- and Moderate- Income Occupied Housing was calculating the
“Present Need”. Present need is defined by the Affordable Housing Law as “the
number of substandard existing deficient housing units currently occupied by low-
and moderate-income (LMI) households”
As per the DCA affordable housing obligations for 2025-2035 Methodology and
Background, the third-round municipal present need calculations used three
factors to calculate present need:
“the number of housing units lacking complete kitchen facilities, the number
of units lacking complete plumbing facilities, and the number of
overcrowded units. Moreover, the Affordable Housing Law explicitly defines
“deficient housing units” as housing that is over 50 years and overcrowded,
that lacks complete plumbing, or that lacks complete kitchen facilities.”
In the fourth-round, the DCA used similar methodology with the same indicators
(lacking kitchen facilities, lacking plumbing facilities, and overcrowded units).
Table 4
Age of Housing Units
Dates of Construction
Structures
Percent (%) of Total
1939 or earlier
153
2.5%
1940 to 1949
109
1.8%
1950 to 1959
99
1.6%
1960 to 1969
379
6.2%
1970 to 1979
420
6.9%
1980 to 1989
1,592
26.2%
1990 to 1999
1,738
28.6%
2000 to 2009
1,260
20.7%
2010 to 2019
334
5.5%
2020 or Later
0
0.0%
Total Housing Units
6,084
100%
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year
Estimates - “Selected Housing Characteristics”
10
However, in the fourth-round the DCA also took into consideration the age of
the housing, utilized more detailed and municipal level data (as opposed to
county level) therefore the information was representative of actual conditions,
as well as accounting for any overlaps to provide more accurate and fair
information.
•
The U.S. Census defines an overcrowded unit as “one occupied by 1.01
persons or more per room (excluding bathrooms and kitchens). Units
with more than 1.5 persons per room are considered severely
overcrowded.”
•
Plumbing Facilities: Inadequate plumbing sufficient for rehabilitation is
indicated by incomplete plumbing facilities, i.e., lack of hot and cold
piped water, flush toilet or bathtub/shower.
•
Kitchen Facilities: Inadequate kitchen facilities signaling rehabilitation
are indicated by the non -presence of kitchen facilitates within the unit,
or the non-presence of one of three components: a sink with piped
water, a stove or a refrigerator.
As reflected above, according to the US Census Bureau 2023 ACS Survey, there
are an estimated 58 total occupied units that are considered overcrowded, with
Table 5
Person Per Room
Persons Per Room
Total Occupied
Units
Owner Occupied Units Renter Occupied Units
1.01 to 1.50
46
32
14
1.51 to 2.00
0
0
0
2.01 or more
12
0
12
Total
58
32
26
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year Estimates - “Selected Housing
Characteristics”
Table 6
Plumbing Facilities
Total Units
With Complete Plumbing Facilities
5,895
Lacking Complete Plumbing Facilities
9
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year
Estimates - “Selected Housing Characteristics”
Table 7
Kitchen Facilities
Total Units
With Complete Kitchen Facilities
5,849
Lacking Complete Kitchen Facilities
55
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year
Estimates - “Selected Housing Characteristics”
11
more “severely overcrowded” (2.01 persons per room or more) units being renter
occupied (12 units). Moreover, there are 9 units lacking complete plumbing
facilities, and 55 units lacking complete kitchen facilities.
Purchase and Rental Value
Approximately 77% of the housing units within Robbinsville Township are owner
occupied, whereas 23% of the housing units are renter occupied.
Table 6
Owner Occupied Housing Unit Values
Number of Units
Percentage
Less than $50,000
163
3.1%
$50,000 to $99,999
68
1.3%
$100,000 to $149,999
89
1.7%
$150,000 to $199,999
158
3.0%
$200,000 to $299,999
666
12.5%
$300,000 to $499,999
1,345
25.2%
$500,000 to $999,999
2,636
49.4%
1,000,000 or more
209
3.9%
Total
4,812
100%
Median Value $523,500
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year Estimates
The owner-occupied housing market consists of 4,812 units, with nearly half
(49.4%) valued between $500,000 and $999,999. The next largest category
includes homes valued between $300,000 and $499,999, comprising 25.2% of the
total. Approximately 12.5% of units fall within the $200,000 to $299,999 range,
while homes valued below $200,000 collectively make up 9.10% of the market.
High-value homes exceeding $1 million account for 3.9% of the total. The median
home value is $523,500, indicating that more than half of the homes are valued
above this amount.
Table 8
Total Occupied Housing Units
Number of Units
Percentage
Owner Occupied
4,812
82%
Renter Occupied
1,092
18%
Total
5,904
100%
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year
Estimates - “Selected Housing Characteristics”
12
Based on table 9 above, the majority of renter-occupied housing units in the
Borough fall within the mid- to upper-range rent categories. Specifically, 32.9% of
units have a gross monthly rent between $1,500 and $1,999, followed closely by
31.0% of units renting for $2,000 to $2,499. An additional 14.4% of units fall within
the $1,000 to $1,499 range, while only 9.7% of units are rented for less than $1,000
per month. High-end rentals—those with rents of $2,500 or more—account for a
combined 7.9% of the rental market. Notably, no units were reported to rent for
less than $500. Approximately 4.1% of occupied units reported no rent paid. The
median gross monthly rent across all occupied rental units is $1,863.
Anecdotally, the prior figure appears to be low. To develop a more accurate
estimate of average rental costs within the Township, fifteen properties were
evaluated using rental platforms such as Zillow, Apartments.com, Realtor.com,
and Trulia. The data indicate that the overall average monthly rent for one- to three-
bedroom units is approximately $2,358. When examining individual unit types, the
average monthly rent is $1,869 for a one-bedroom unit, $2,456 for a two-bedroom
unit, and $2,750 for a three-bedroom unit as of May 2025.
B. Projected Housing Stock
According to the 2025 Year-to-Date building permit summaries provided by the
New Jersey Labor Market and Workforce Development division, sourced by the
U.S Census bureau, the Township of Robbinsville authorized 30 total single-family
units to be built in 2024. The Township of Robbinsville authorized 0 units to be built
that were multi-family. However, as per resolution number 2025-060, the Township
of Robbinsville has accepted their DCA calculated affordable housing obligation,
and fully intends to satisfy that obligation within the fourth-round.
Table 9
Occupied Units Paying Rent
Gross Monthly Rent
Number of Units
Percentage
Less than $500
0
0%
$500 to $999
106
9.7%
$1,000 to $1,499
157
14.4%
$1,500 to $1,999
359
32.9%
$2,000 to $2,499
339
31.0%
$2,500 to $2,999
16
1.5%
$3,000 or more
70
6.4%%
No Rent Paid
45
4.1%
Total
1,092
100%
Median Value $1,863
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year Estimates
13
Robbinsville will address the future construction of low-and-moderate income
housing as outlined in the Fair Share Plan section herein.
C. Municipality’s Demographic Characteristics
Population
As illustrated in Table 10 below, Robbinsville Township has experienced steady
population growth over the last century, with several notable periods of rapid
expansion. Significant growth occurred in the 1950s and 1970s, when the
population increased by 35 percent and 53.6 percent, respectively. The 1990s saw
the population rise by nearly 67 percent, and the early 2000s continued this trend
with a 76.7 percent increase. These decades of rapid growth were followed by a
slower pace in the 2010s, with a 32.8 percent increase from 2000 to 2010, and a
more modest 13.4 percent growth from 2010 to 2020.
According to the U.S. Census data, Robbinsville Township's population in 2010
was 13,642, and by 2020, it had grown to 15,476. The historical data shows that
Robbinsville Township will likely experience a period of more stable growth moving
forward. The projected population increase over the next several decades is
expected to be more modest, following the trends of slower growth observed in
recent years. Table 1, Robbinsville Township Population Characteristics 1900-
2020 illustrates these trends, highlighting a continued but slower pace of
population growth in the Township.
Table 10
Robbinsville Township Population Characteristics 1900-2020
Year
Population
% ±
1900
1,157
2.80%
1910
1,090
−5.8%
1920
1,161
6.50%
1930
1,347
16.00%
1940
1,365
1.30%
1950
1,843
35.00%
1960
2,156
17.00%
1970
3,311
53.60%
1980
3,487
5.30%
1990
5,815
66.80%
2000
10,275
76.70%
2010
13,642
32.80%
2020
15,476
13.40%
Source: United States. Bureau of the Census Historical Data, 2023 American Community Survey 5-Year Estimates;
Robbinsville Township was formerly named Washington Township of Mercer County (2007) Washington Township
population data was utilized.
14
Population Age
As illustrated in Table 11, the age cohort breakdown of Robbinsville Township
residents shows some notable differences when compared to Mercer County as a
whole. Robbinsville has a higher percentage of school-aged children, particularly
in the 5 to 9 years and 10 to 14 years age groups, with 7.7% and 8.7%,
respectively, compared to 5.4% and 7.1% in Mercer County. Additionally,
Robbinsville has a higher proportion of adults aged 40 and above, especially in the
40 to 44 years and 45 to 49 years age ranges, where Robbinsville's percentages
are 9.3% and 9.7%, respectively, compared to 7.4% and 6.6% in Mercer County.
These differences suggest that Robbinsville has a higher number of families with
children and a more substantial middle-aged adult population. A breakdown of the
population by age for Robbinsville and Mercer County is provided below.
Household Income Level
As measured in the 2017 ACS five-year estimates, Robbinsville Township had a
higher median household income than Mercer County as a whole. The median
household income in Robbinsville was $118,190, which is significantly higher than
Table 11
Population Comparison By Age
Robbinsville
Township
Mercer County
Number
Percentage
Number
Percentage
Under 5 years
547
3.5%
21,033
5.5%
5 to 9 years
1,181
7.7%
20,521
5.4%
10 to 14 years
1,342
8.7%
26,935
7.1%
15 to 19 years
1,241
8%
26,452
6.9%
20 to 24 years
589
3.8%
26,496
6.9%
25 to 29 years
460
3%
22,837
6%
30 to 34 years
738
4.8%
23,709
6.2%
35 to 39 years
801
5.2%
21,396
5.6%
40 to 44 years
1,432
9.3%
28,358
7.4%
45 to 49 years
1,503
9.7%
25,229
6.6%
50 to 54 years
1,363
8.8%
25,834
6.8%
55 to 59 years
1,444
9.4%
22,927
6%
60 to 64 years
1,067
6.9%
26,572
7%
65 to 69 years
712
4.6%
20,395
5.3%
70 to 74 years
405
2.6%
16,733
4.4%
75 to 79 years
196
1.3%
10,156
2.7%
80 to 84 years
214
1.4%
8,324
2.2%
85 years and over
197
1.3%
7,764
2%
Total
15,432
100%
381,671
100%
Median Age
41
-
40.2
-
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year Estimates
15
the County's median income of $80,776. Approximately 9.6% of households in
Robbinsville had an income of less than $35,000, while around 63.4% of
households had an income greater than $100,000. Furthermore, over 24% of
Robbinsville households earned more than $200,000 annually, which is notably
higher than the County's proportion of high-income households. This indicates a
relatively affluent population within Robbinsville compared to Mercer County as a
whole.
Table 12
Households by Income in 2023
Robbinsville Township
Mercer County
Number
Percentage
Number
Percentage
Less than $10,000
159.408
2.7
9067.996
6.20
$10,000 to $14,999
100.368
1.7
4095.224
2.80
$15,000 to $24,999
289.296
4.9
6727.868
4.60
$25,000 to $34,999
153.504
2.6
8775.48
6
$35,000 to $49,999
301.104
5.1
14479.542
9.90
$50,000 to $74,999
531.36
9.0
18721.024
12.80
$75,000 to $99,999
324.72
5.5
14187.026
9.70
$100,000 to $149,999
832.464
14.1
26033.924
17.80
$150,000 to $199,999
1068.624
18.1
15503.348
10.60
$200,000 or more
2131.344
36.1
28812.826
19.70
Less than $10,000
159.408
2.7
9067.996
6.20
$10,000 to $14,999
100.368
1.7
4095.224
2.80
Median income (dollars)
$162,813
$96,152
Mean income (dollars)
$184,169
$133,495
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year Estimates
Household Type
Family households are classified by the U.S. Census Bureau as two or more persons
living in the same household, related by blood, marriage, or adoption. As shown in the
table below, 63% of all households in Robbinsville Township are family households,
with an average household size of 3.15 persons. Of these, 55% are married-couple
families, 6% are female householder families with no husband present, and 2% are
male householder families with no wife present. Non-family households make up 19%
of the total, with 17% consisting of individuals living alone.
16
Table 13
Households by Type in 2023
Household Type
Number
Percent
Total Households
5,904
100
Family Households (families)
3,694
63
Married-couple family
3,224
55
Female householder, no husband present
340
6
Male householder, no wife present
130
2
Nonfamily households
1,118
19
Householder living alone
1,005
17
Householders 65 years and over
358
6
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year Estimates
D. Employment Characteristics
There are an estimated 8,449 Robbinsville Township residents over the age of 16
that make up the Townships labor force. There is a near-balanced workforce
gender distribution with females holding more positions. The top three industries
employing the highest percentage of the workforce are Professional, scientific, and
technical services (15.92%) with 1,345 employees, Finance and insurance
(13.49%) with 1,140 employees, and Health care and social assistance (11.29%)
with 954 employees.
Table 14
Employed Persons 16 Years and Over
Industry
Total No. of
People
Male
Female
Percent of
Total
Agriculture, forestry, fishing, hunting & mining
12
12
0
0.14%
Construction
314
213
101
3.72%
Manufacturing
888
494
394
10.51%
Wholesale Trade
223
117
106
2.64%
Retail Trade
559
358
201
6.62%
Transportation and Warehousing
279
245
34
3.30%
Utilities
133
110
23
1.57%
Information
316
155
161
3.74%
Finance and Insurance
1,140
734
406
13.49%
Real estate and rental and leasing
52
31
21
0.62%
Professional, scientific and technical services
1,345
793
552
15.92%
Management of companies and enterprises
40
17
23
0.47%
Administrative and support and waste management
services
301
64
237
3.56%
Educational services
663
200
463
7.85%
Health care and social assistance
954
203
751
11.29%
Arts, Entertainment and Recreation
201
106
95
2.38%
Accommodation and food services
287
101
186
3.40%
Other services except public administration
167
69
98
1.98%
Public administration
575
345
230
6.81%
Total
8,449
4,367
4,802
100%
Source: United States. Bureau of the Census, 2023 American Community Survey 5-Year Estimates
17
III.
Fair Share Plan
A. Introduction
In March 2024, Governor Murphy signed P.L.2024, c.2—landmark legislation
aimed at ensuring every New Jersey municipality meets its constitutional obligation
to provide affordable housing. The law requires municipalities to update their
Master Plans and revise zoning and land use regulations to support both the
creation of new affordable housing and the rehabilitation of substandard units.
This section of Robbinsville’s Housing Element and Fair Share Plan outlines how
the Township will meet its Fourth-Round obligations, which include both Present
Need and Prospective Need. Present Need—also known as the Rehabilitation
Share—is recalculated each round using census data to estimate the number of
substandard homes currently occupied by low- and moderate-income households.
Based on updated methodology in the amended Fair Housing Act, statewide
Fourth-Round need is set at 84,698 units. Of that, Region 4 (Mercer, Monmouth,
and Ocean Counties) is responsible for 13,822 units, with allocations made to each
municipality, including Robbinsville.
According to the DCA, Robbinsville’s Fourth-Round obligation includes 40 Present
Need units and 336 Prospective Need units. The Township formally accepted
these numbers by way of resolution, resolution number 2025-060 included in
Appendix G.
B. Cumulative Fair Share Obligation
The Township of Robbinsville has a “Present Need” affordable housing obligation
of 40 units, and a “Prospective Need” affordable housing obligation of 336 units for
the 2025 – 2035 Fourth-Round. By way of resolution (Resolution Number 2025-
060) on January 30, 2025, the Township accepted both the present and the
prospective need unit obligations.
Prior to the acceptance of the Fourth-Round obligation, the Township had entered
a Court-approved settlement agreement on October 17, 2018 that stipulated the
Fair Share obligation for the period of 1987 through July 1, 2025, which included
a Present Need of 16 units for rehabilitation, a Third-Round obligation (1999-2025)
of 638 units, and a Prior Round obligation (1987-1999) of 293 units.
As reflected in the Townships 2018 Housing Element and Fair Share Plan, and the
Third Amended Settlement Agreement dated February 22, 2018, Robbinsville
successfully created sufficient realistic opportunities for the provision of low- and
moderate-income housing through July 1, 2025 to satisfy its Fair Share Housing
Obligation up until this Fourth-Round. (the 2017 and 2018 HEFSP are attached
within this document under Appendix I).
18
Present Need refers to “the number of substandard existing deficient
housing units currently occupied by low- and moderate-income
households.” A “deficient housing unit” is “housing that (1) is over fifty years
old and overcrowded, (2) lacks complete plumbing, or (3) lacks complete
kitchen facilities.” Robbinsville’s Present Need obligation is 40 units.
Prior Round Obligation covers the cumulative affordable housing
requirement for new construction from 1987 through 1999, encompassing
both the First and Second Rounds of planning. This obligation framework
was upheld by the New Jersey Supreme Court in 2013. Robbinsville’s Prior
Round obligation, as calculated by COAH, is 293 units.
Third-Round Obligation includes two components: the “gap period” from
1999 to 2015, during which no valid affordable housing regulations were in
place, and the Prospective Need from 2015 to 2025, reflecting projected
demand over a ten-year period beginning in July 2015. In 2001, COAH
formally extended the duration of housing rounds from six to ten years.
Mercer County’s Third-Round Gap and Prospective Need figures were established
by Judge Mary C. Jacobson in the March 8, 2018 decision Opinion on Fair Share
Methodology to Implement the Mount Laurel Affordable Housing Doctrine for the
Third-Round. This ruling—commonly referred to as the “Jacobson Methodology”—
set a binding framework for municipalities in Mercer County and was later
extended statewide through amendments to the Fair Housing Act. Under this
methodology, Robbinsville was assigned a Third-Round obligation of 638 units.
Prospective Need refers to projected housing demand based on expected
development and population growth in a region or municipality.
Robbinsville’s Fourth-Round Prospective Need, as determined by the New
Jersey Department of Community Affairs (DCA) using the methodology
detailed in its October 2024 report, is 336 units.
Table 15 presents the break-down of the Cumulative 1987-2025 Obligation,
totaling 1,307.
Table 15
Cumulative 1987-2035 Obligation
Fourth-Round
Present Need
40
Prospective Need
336
Third-Round
638
Prior Round
293
Total Cumulative Obligation (1987-2035)
1,307
19
C. Addressing the Townships Rehabilitation Obligation
In satisfying it’s present need of 40 units to be rehabilitated, the Township of
Robbinsville operates an affordable housing rehabilitation program that provides
eligible applicants with deferred payment, 0% interest loans of up to $20,000 that
require no monthly payments but do require repayment of the loan principal when
the home is sold or title transferred. Rehabilitation focuses on major systems and
code violations.
Since April 1, 2010, Robbinsville has completed the rehabilitation of seven units.
The remaining nine units will be fulfilled either through an existing contract with
Community Action Services or by utilizing credits from rehabilitation efforts related
to the Mercer Mobile Home Park. All rehabilitated units are required to meet
applicable code standards, have a minimum investment of $10,000 per unit, and
remain affordable for at least ten years. Refer to Appendix K for rehabilitation
completion information to date.
D. Addressing the Township’s Affordability Assistance Obligation
In order to address the Township’s affordability assistance obligation, the
Township has an Emergency Repair/Energy Efficiency Assistance program for the
affordable housing properties in Robbinsville. This is done as affordability
assistance. This helps currently recertified income eligible owners of affordable
units, homeowners that would not have the funds necessary to keep their
properties up to code. The township provides loans up to $20,000 that are interest
free, no monthly payments and are forgiven if the homeowner remains in the
affordable property for 6 years.
E. Prior Round Obligation
For the Prior Round Obligation, Robbinsville was required to provide 293
affordable housing units, which includes a 73-unit rental obligation. The Township
has met this obligation through a combination of for-sale units, group homes, rental
developments, and regional contribution agreements. Foxmoor developments
provided a substantial portion of the for-sale units, while Project Freedom added
35 general occupancy rental apartments. Group homes across various sites
contributed 24 bedrooms. Additionally, Robbinsville had entered into a regional
contribution agreement with Trenton, resulting in 11 rental units being credited to
the Prior Round. The Township also received a seven-unit reduction through a
substantial compliance credit.
For further information on the prior round, refer to Appendix I attached within this
document.
20
F. Third-Round Obligation
The Third-Round Obligation, established through a settlement agreement with Fair
Share Housing Center, required Robbinsville to provide 638 affordable units by
2025. This includes 160 rental units and allows for a maximum of 159 age-
restricted units. Further, 13 percent of all units constructed after July 1, 2008, must
be reserved for very low-income households.
To date, Robbinsville has already built or preserved 333 units toward this
obligation. These include affordable rentals in Sharbell’s Town Center and
Springside developments, extended affordability controls at Foxmoor, affordable
sales units at Sharbell Union Lofts, additional RCA units, and multiple group
homes. An assisted living facility, Rose Hill, also contributes with 14 Medicaid
Waiver apartments.
Table 16
Project Name
Type
Number of Units
Sharbell (Town Center)
Family Rentals
26
Foxmoor
Extend Controls – Family Sales
181
Sharbell Union Lofts
Family Sales
8
RCA*
13 Rentals / 4 Non Rentals
17
Foxmoor
Family Sales
31
203 Robbinsville-Edinburg
Group Home
4
165 Robbinsville-Edinburg
Group Home
4
Sharbell Springside
Family Rentals
38
Rose Hill
Medicaid Bedrooms
14
154 Robbinsville-Allentown
Group Home
4
14 Vahlsing
Group Home
4
2230 Route 22
Group Home
2
Total
333 (Built)
*Applied pre July 1, 2008 portion of the Third Round Obligation
To meet the remainder of its obligation, Robbinsville has added 146 more
affordable units. A major component of this strategy involved acquiring 70 units at
the Mercer Mobile Home Park. Additionally, Robbinsville intends to develop 45
family rental units as part of a mixed-use redevelopment project at Town Center
South, under a plan led by Capodagli Property Company. This project replaces
previously considered sites and will contribute significantly toward meeting
affordable family rental needs. Furthermore, 19 new group home bedrooms will be
created throughout the Period of Repose, and two smaller projects—Robbinsville
Commons II and a site at 2320 Route 33—will yield a total of 12 additional family
rental units.
21
To fulfill its 638-unit requirement, Robbinsville also relies on 159 rental bonus
credits, earned primarily through the inclusion of family rentals and group homes.
The combined total of built units, proposed developments, and bonus credits
reaches 649 units, slightly exceeding the target obligation by 11 credits.
The Township’s plan fully complies with income targeting and family housing
requirements. At least 260 of the units are allocated for low or very low-income
households, surpassing the required 240. Of the rental units, 172 are affordable,
with 121 designated for families. In total, 412 units in the plan are family-oriented,
well above the minimum threshold. Robbinsville has ensured that no more than 25
percent of all affordable units across the Prior and Third-Round obligations are
age-restricted.
Table 17 below illustrates how the Township has intended to meet its 638 unit
obligation.
For further information on the third-round, refer to Appendix I attached within this
document.
G. Fourth-Round Obligation
The Township is fulfilling its affordable housing obligation through a multifaceted
approach, which includes proposed inclusionary housing projects, the application
of carryover credits from prior affordable developments, the extension of
affordability controls on existing inclusionary units, and the use of development
bonuses for transit-oriented, age-restricted, and group home projects.
As previously stated, the DCA calculated that the Township of Robbinsville has a
“Present Need” affordable housing obligation of 40 units, and a “Prospective Need”
affordable housing obligation of 336 units for the 2025 – 2035 Fourth-Round.
Table 17
Project Name
Type
Number of Units
Mercer Mobile Home Park
Family Sales
70
Town Center South (Project
Freedom)
Family / Disabled
Rentals
52 out of 72 total Family/ Disabled
Rentals
Group Homes (New)
Bedrooms
19
Town Center
Family Rentals
5
Market to Affordable
Family Sales
3
Robbinsville Commons II (King)
Family Rentals
7
Total
157 (Proposed)
Rental Bonus
159
Grand Total
649
22
The Township has approved, or been working to approve a number of sites to
contribute to satisfying the 336-unit obligation, as well an ongoing rehabilitation
program that provides interest free loans of up to $20,000 with no monthly
payments and repayment is deferred until the homeowner sells the home, to
address the 40 units under present need.
Table 18 below illustrates how the Township intends to meet their 336 unit
obligation to satisfy the Fourth-Round.
Table 18
Fourth-Round Proposed Projects
Project Name
Block
Lot(s)
No. of Affordable Units
Project Status
Mercer Mobile
Home Park
1
59.01
70
Fully Approved per Consent
Order
Sharbell Gordon
Simpson
21
27.01 & 27.02
56
Board Approval; In
Resolution Compliance
Kushner Capodagli
1
65.02
38
Named Redeveloper. Town
is committed to the
Amendment to make this an
As-of-Right Development.
Resolution No. 2024-129;
2024-187
Gordon Road AHA
21
27.03
6
Group Homes
N/A
N/A
27
Extension of
Controls
N/A
N/A
66
All are being taken pursuant
to Judge Jacobsons
directives in Third-Round
Total Before Bonuses
263
Transit Bonus for MMHP
15
Age Restricted Bonus for Kushner Capodagli
28
Municipal Sponsored Bonus
3
Group Homes Bonus
27
Overall Total
336
Fourth-Round Prospective Need
336
As reflected above, the Townships Fourth-Round Prospective Need obligation is
336 units. The following table illustrates the formulas that summarize the minimum
or maximum number of Fourth-Round bonuses, affordable family rental units,
senior units, low-income, and very low-income units:
23
1. Site Suitability Analysis
One of the requirements for a final HEFSP is the inclusion of detailed site suitability
analyses, based on the best available data, for each of the un-built inclusionary or
100% affordable housing sites in the plan. In accordance with the Council on
Affordable Housing’s site suitability criteria found at N.J.A.C. 5:93-1.3, all sites to
be used for affordable housing purposes must be “available, approvable,
developable, and suitable,” as follows:
• “Available site” means a site with clear title, free of encumbrances which
preclude development for low- and moderate-income housing.
• “Approvable site” means a site that may be developed for low- and
moderate-income housing in a manner consistent with the rules or
regulations of agencies with jurisdiction over the site. A site may be
approvable although not currently zoned for low- and moderate-income
housing.
• “Developable site” means a site that has access to appropriate water and
sewer infrastructure, and is consistent with the applicable area wide water
quality management plan (including the wastewater plan) or is included in
an amendment to the area wide water quality management plan submitted
to and under review by the DEP.
• “Suitable site” means a site that is adjacent to compatible land uses, has
access to appropriate streets and is consistent with the environmental
policies delineated in N.J.A.C. 5:93-4.
In addition to the above qualifications, it is also sound planning for sites to be
consistent with the State Development and Redevelopment Plan. Sites that are
located in “Planning Area 1: Metropolitan” or “Planning Area 2: Suburban” of the
State Development and Redevelopment Plan, or are located in an existing sewer
service area, are the preferred location for municipalities to address their fair
share obligations.
The following pages provide a site suitability analysis for each of the proposed
Table 19
Requirement
Maximum Bonuses
84
.25 x (obligation) = .25 x 336 =
84
Minimum Family Rental Units
132
.50 x (obligation – maximum bonuses) = .50 x (336 - 84)
131.5
Maximum Senior Units
76
.30 x (obligation – maximum bonuses) = .30 x (336 - 84)
75.6
Minimum Low-Income
132
.50 x (obligation – maximum bonuses) = .50 x (336 - 84)
131.5
Minimum Very Low-Income
33
.13 x (obligation – maximum bonuses) = .13 x (336 - 84)
32.76
Minimum Very Low-Income Family Rental Units
132
.50 x (required very low-income units) = .50 x (336 - 84)
131.5
24
sites that will be included within the Township’s Fourth-Round.
Sharbell Gordon, LLC
Project Location: Block 26, Lots 6.02, 6.03, & 6.04; Block 21, Lot 27.01 & 27.02
Project Proposal: Sharbell Gordon, LLC proposes a mixed-use development
containing 206 garden apartments, 100 townhome units, with a shopping center
market and retail component. For purposes of this housing plan, the
development proposes a set aside of 56 affordable units.
Site Suitability Analysis:
• Available: There is no title or deed restriction encumbrances or other
hindrances that would preclude an inclusionary development.
• Approvable: The proposed development is supported by local, regional, and
state planning policies. The overall site is located within the State Planning
Area “PA2 - Suburban Planning Area”. Block 26, Lots 6.02, 6.03, & 6.04 are
currently vacant, and contain no buildings or significant structures. A
manmade reservoir exists central to the overall site. Block 21, Lots 27.01,
& 27.02 contain a manmade reservoir. Surrounding the property are single-
family and multi-family residential developments, with limited commercial
properties to the north, east, and west, along US Route 130. The addition
of a mixed-use shopping center, retail and residential development would
SOURCE: GOOGLE EARTH AERIAL IMAGERY DATED APRIL 2022,
BOUNDARY IS APPROXIMATE, NOT EXACT
25
complement the existing development of the area, fostering a diverse and
synergistic relationship between uses while meeting all applicable
regulatory requirements for development approval.
• Developable: Per publicly available information provided by NJDEP GIS
Maps modified Agricultural Wetlands, as well as Herbaceous Wetlands
exist within isolated portions of the site. These conditions exist on only a
percentage of the site within an isolated area, which does not hinder
development. The presence of wetlands on a site does not render the site
“un-developable”. The applicant is able and willing to comply with all state
regulations regarding the presence of wetlands. Additionally, the site is not
within a flood zone.
The site is located approximately 120 feet southeast of the Aqua NJ -
Hamilton Square water service area; located within the Jersey Central
Power & Light service area for electricity; located within the Public Service
Electric and Gas Co. service area for natural gas; and located within the
Hamilton Township Department of Water Pollution Control for Sewer
Service. The Township of Hamilton has confirmed sewer capacity within a
letter dated November 22, 2024. Therefore, there are utility services that
are already provided, or can be provided to the site to accommodate the
development.
• Suitable: The proposed inclusionary development would be compatible with
the existing residential properties within the surrounding area, as well as the
highway commercial businesses along Route 130. Additionally, the site
includes direct access to Route 130, which provides access to other local
and state highways such as Route 206, I-195 and I-295. The site is large
enough to accommodate the required number of parking spaces for the
development. From a site planning perspective, there is an appropriate
amount of open space proposed on the site, which is clear evidence of the
site not being or appearing overdeveloped.
In addition to site suitability, the developer of the affordable housing project will
be required to meet the applicable requirements of UHAC:
• Administrative Entity: In compliance with Article 28-17 of the Township
Code and applicable state regulations, the Township will require the
residential developer to retain a qualified administrative agent. This agent
will be responsible for overseeing the affordable housing program at the
development, including affirmatively marketing the units, verifying
applicant income eligibility, applying a minimum 40-year affordability
control on rental units, and managing the long-term compliance and
administration of the units. These responsibilities will be carried out in
accordance with the requirements of N.J.A.C. 5:93-1 et seq. and N.J.A.C.
5:80-26.1 et seq.
26
• Low/Moderate Income Split: In accordance with the Uniform Housing
Affordability Controls (UHAC) set forth in N.J.A.C. 5:80-26.1, at least 50%
of the affordable units produced will be designated for low-income
households. Additionally, no less than 13% of all affordable units will be
reserved for very low-income households, ensuring compliance with state
mandates.
• Affirmative Marketing: All affordable units will be marketed in accordance
with the affirmative marketing requirements outlined in N.J.A.C. 5:93-1 et
seq. and N.J.A.C. 5:80-26.1 et seq., to ensure fair and broad outreach to
eligible populations.
• Controls on Affordability: The Township’s agreement with the site
developer will mandate that all affordable units be subject to deed
restrictions ensuring affordability for a minimum of 30 years, in accordance
with the provisions of N.J.A.C. 5:93 et seq. and the Uniform Housing
Affordability Controls (UHAC) outlined in N.J.A.C. 5:80-26.1.
• Bedroom Distribution: The configuration and distribution of bedrooms
within the affordable units will adhere to the standards established under
the Uniform Housing Affordability Controls (UHAC).
Kushner Capodagli – Autumn at Robbinsville
SOURCE: GOOGLE EARTH AERIAL IMAGERY DATED JUNE 2022, BOUNDARY IS APPROXIMATE
27
Project Location: Block 1, Lot 65.02
Project Proposal: Capodagli Property Company, LLC proposes an inclusionary
housing development that will provide 250 age-restricted affordable housing
units. For purposes of this housing plan, the development proposes a set aside
of 38 affordable units.
Site Suitability Analysis:
•
Available: There is no title or deed restriction encumbrances or other
hindrances that would preclude an inclusionary development.
•
Approvable: The proposed development is supported by local, regional,
and state planning policies. The site is located within the State Planning
Area “PA2 - Suburban Planning Area”. Currently, the site is vacant, and
contains no buildings or significant structures. Surrounding the property are
single-family and multi-family residential developments, and Robbinsville
Town Center located to the north. commercial development exists to the
east and west along Route 33. The addition of an inclusionary residential
development would provide the area with diverse housing options, that
support the surrounding commercial uses.
•
Developable: Per publicly available information provided by NJDEP GIS
Maps Deciduous Wooded Wetlands exist along small portions of the east,
south, and west property lines. Additionally, Freshwater Forested / Shrub
Wetlands exist isolated to the eastern portion of the site. As noted, these
conditions exist on only a percentage of the site within isolated areas,
which does not hinder development. The presence of wetlands on a site
does not render the site “un-developable”. The applicant is able and willing
to comply with all state regulations regarding the presence of wetlands.
Additionally, the site is not within a flood zone. Additionally, the site is not
within a flood zone.
The site is located within the Aqua NJ - Hamilton Square water service
area; located within the Jersey Central Power & Light service area for
electricity; located within the Public Service Electric and Gas Co. service
area for natural gas; and located within the Hamilton Township Department
of Water Pollution Control for Sewer Service. Therefore, there are utility
services that are already provided to accommodate the development.
•
Suitable: The proposed inclusionary development would be compatible
with the Town Center, as well as the existing residential and commercial
properties within the surrounding area. Additionally, the site includes direct
access to New Jersey Highway 33, which provides access to other local
and state highways such as Route 130, Route 206, I-195 and I-295.
In addition to site suitability, the developer of the affordable housing project will
28
be required to meet the applicable requirements of UHAC:
• Administrative Entity: In compliance with Article 28-17 of the Township
Code and applicable state regulations, the Township will require the
residential developer to retain a qualified administrative agent. This agent
will be responsible for overseeing the affordable housing program at the
development, including affirmatively marketing the units, verifying
applicant income eligibility, applying a minimum 40-year affordability
control on rental units, and managing the long-term compliance and
administration of the units. These responsibilities will be carried out in
accordance with the requirements of N.J.A.C. 5:93-1 et seq. and N.J.A.C.
5:80-26.1 et seq.
• Low/Moderate Income Split: In accordance with the Uniform Housing
Affordability Controls (UHAC) set forth in N.J.A.C. 5:80-26.1, at least 50%
of the affordable units produced will be designated for low-income
households. Additionally, no less than 13% of all affordable units will be
reserved for very low-income households, ensuring compliance with state
mandates.
• Affirmative Marketing: All affordable units will be marketed in accordance
with the affirmative marketing requirements outlined in N.J.A.C. 5:93-1 et
seq. and N.J.A.C. 5:80-26.1 et seq., to ensure fair and broad outreach to
eligible populations.
• Controls on Affordability: The Township’s agreement with the site
developer will mandate that all affordable units be subject to deed
restrictions ensuring affordability for a minimum of 30 years, in accordance
with the provisions of N.J.A.C. 5:93 et seq. and the Uniform Housing
Affordability Controls (UHAC) outlined in N.J.A.C. 5:80-26.1.
• Bedroom Distribution: The configuration and distribution of bedrooms
within the affordable units will adhere to the standards established under
the Uniform Housing Affordability Controls (UHAC).
29
Gordon Road Affordable Housing Alliance
It should be noted that this site was represented within the prior round, but
ultimately was not utilized to satisfy the Township’s obligation, not because it was
not suitable, but because the Township elected to pursue “other housing options”
as per the 2017 Housing Element Plan found within APPENDIX I. Therefore, it
was established that this site meets the site suitability criteria for inclusionary
housing.
Project Location: Block 21, Lot 27.03
Project Proposal: Gordon Road Affordable Housing Alliance proposes an
inclusionary housing development that will provide 6 single-family affordable
housing units.
Site Suitability Analysis:
• Available: There is no title or deed restriction encumbrances or other
hindrances that would preclude an inclusionary development.
• Approvable: The proposed development is supported by local, regional, and
state planning policies. The site is located within the State Planning Area
30
“PA 4B – Rural Environmentally Sensitive”. Currently, the site is vacant, and
contains no buildings or significant structures. Surrounding the property are
single-family and multi-family residential developments, with limited
commercial properties to the north, east, and west, along US Route 130.
The addition of a mixed-use shopping center, retail and residential
development would complement the existing development of the area,
fostering a diverse and synergistic relationship between uses while meeting
all applicable regulatory requirements for development approval.
• Developable: Per publicly available information provided by NJDEP GIS
there are no wetlands that exist on the site, and the site is not within a flood
zone.
The site is located approximately 1,087 FT southeast of the Aqua NJ -
Hamilton Square water service area; located within the Jersey Central
Power & Light service area for electricity; located within the Public Service
Electric and Gas Co. service area for natural gas; and located within the
Hamilton Township Department of Water Pollution Control for Sewer
Service. Therefore, there are utility services that are already provided, or
can be provided to the site to accommodate the development.
• Suitable: The proposed inclusionary development would be compatible with
the existing residential properties within the surrounding area, as well as the
highway commercial businesses along Route 130. Additionally, the site is
located approximately 993 FT southeast of Route 130, which provides
access to other local and state highways such as Route 206, I-195 and I-
295.
In addition to site suitability, the developer of the affordable housing project will
be required to meet the applicable requirements of UHAC:
• Administrative Entity: In compliance with Article 28-17 of the Township
Code and applicable state regulations, the Township will require the
residential developer to retain a qualified administrative agent. This agent
will be responsible for overseeing the affordable housing program at the
development, including affirmatively marketing the units, verifying
applicant income eligibility, applying a minimum 30-year affordability deed
restriction for sales units, and managing the long-term compliance and
administration of the units. These responsibilities will be carried out in
accordance with the requirements of N.J.A.C. 5:93-1 et seq. and N.J.A.C.
5:80-26.1 et seq.
• Low/Moderate Income Split: In accordance with the Uniform Housing
Affordability Controls (UHAC) set forth in N.J.A.C. 5:80-26.1, at least 50%
of the affordable units produced will be designated for low-income
households. Additionally, no less than 13% of all affordable units will be
31
reserved for very low-income households, ensuring compliance with state
mandates.
• Affirmative Marketing: All affordable units will be marketed in accordance
with the affirmative marketing requirements outlined in N.J.A.C. 5:93-1 et
seq. and N.J.A.C. 5:80-26.1 et seq., to ensure fair and broad outreach to
eligible populations.
• Controls on Affordability: The Township’s agreement with the site
developer will mandate that all affordable units be subject to deed
restrictions ensuring affordability for a minimum of 30 years, in accordance
with the provisions of N.J.A.C. 5:93 et seq. and the Uniform Housing
Affordability Controls (UHAC) outlined in N.J.A.C. 5:80-26.1.
• Bedroom Distribution: The configuration and distribution of bedrooms
within the affordable units will adhere to the standards established under
the Uniform Housing Affordability Controls (UHAC).
2. Group Homes
Table 20 below outlines the group home projects developed throughout the
Township, reflecting the community’s ongoing commitment to providing
supportive housing options. Various organizations—including Eden Acres, Eden
Autism, Community Options, Advancing Opportunities, Arc Mercer, Serv, and
Hillside Development—have established group homes of varying sizes, with
capacities ranging from small two-bedroom residences to larger facilities. These
homes have been incorporated across multiple affordable housing rounds, with
many providers participating in more than one round. The projects listed
contribute a total of 27 bedrooms toward the municipality’s Fourth Round
affordable housing obligation, highlighting a continued investment in inclusive and
supportive residential opportunities.
Table 20
Group Home Projects
Block
Lot
Provider
No. of
Bedrooms
Prior
Round
Third
Round
Fourth
Round
22
25
Eden Acres
6
4
2
2
28.03
6
Eden Acres
4
4
-
-
25.06
42
Eden Acres
4
4
-
-
28.08
2
Eden Autism
4
-
4
-
28.01
2
Eden Autism
4
-
4
4
3.44
1.01 C0615
Eden Autism
2
-
2
-
30
24
Eden Autism
4
-
4
-
6
23
Community Options
4
4
-
-
3.01
6.18 C191
Community Options
2
2
-
-
5
11
Advancing Opportunities
4
4
-
-
34
9
Arc Mercer
4
-
4
-
32
28.10
8
Arc Mercer
4
4
-
-
5
2.02
Serv
4
-
4
-
5
2.02
Serv
52
28
24
-
5
25.02 C131
Community Options
2
-
-
2
8.01
58
Eden
5
-
-
5
8.01
58
Eden
28
24
8.04
11
Eden
4
-
-
4
5.02
1
Arc Mercer
6
-
-
6
28.12
6
Hillside Development
4
-
-
4
Total Fourth Round
27
3. Creditworthiness of Existing Affordable Housing Units
The Township of Robbinsville has continued to utilize the State’s Affordable
Housing Monitoring System (AHMS, formerly CMT), in accordance with the
requirements of the Fair Housing Act and recent amendments under P.L. 2024,
c.2. The Township remains in full compliance with its statutory obligations related
to the reporting of affordable housing unit activity and Affordable Housing Trust
Fund revenues and expenditures. Robbinsville will continue to use this State-
administered system as the primary method for meeting its annual reporting
requirements and ensuring transparency and accountability in the administration
of its affordable housing program.
4. Compliance Analysis
The Township of Robbinsville has consistently demonstrated a commitment to
advancing the development of affordable housing. This Housing Element and
Fair Share Plan outlines the comprehensive strategies and mechanisms the
Township will implement to fulfill its cumulative affordable housing obligation.
5. Very Low / Low / Moderate Income Requirements
In accordance with the amended Fair Housing Act (P.L. 2008, c.46),
municipalities are required to ensure that a minimum of 13% of all affordable
housing units approved and constructed (or planned for construction) after July
17, 2008, are reserved for very low-income households. Furthermore, under the
most recent amendment to the Fair Housing Act (P.L. 2024, c.2), codified at
N.J.S.A. 52:27D-329.1, at least 50% of the very low-income units intended to
fulfill Fourth-Round Prospective Need must be designated for families with
children. To meet these obligations, the Township will incorporate deed
restrictions into any development or redevelopment agreement involving
affordable housing to ensure that units are made available to households earning
no more than 30% of the area median income. Additionally, subject to the
availability of affordable housing trust funds, the Township may allocate
resources through its Spending Plan to support small-scale developers in
33
delivering very low-income units. The specific terms of such financial support will
be outlined in individual developer or redeveloper agreements.
6. Preservation of Multigenerational Family Continuity
Pursuant to the amended Fair Housing Act, the Housing Element and Fair Share
Plan must include an analysis of how municipal ordinances and local factors
support or hinder the goal of preserving multigenerational family continuity, as
outlined in the recommendations of the Multigenerational Family Housing
Continuity Commission (P.L.2021, c.273; N.J.S.A. 52:27D-329.20). The
Commission’s stated objective is to enable senior citizens to remain in the homes
of extended family members, thereby strengthening multigenerational living
arrangements.
As of April 2025, the Commission has not issued formal recommendations.
Nonetheless, a review of the Robbinsville Land Use Ordinance indicates that the
municipality supports this goal. The Township defines “family” in the Land Use
Ordinance as: “One or more persons related by blood, marriage, civil union,
domestic partnership, adoption or guardianship, or not more than six persons not
so related occupying a dwelling unit and living as a single housekeeping unit.”
This definition clearly permits senior citizens to reside with younger generations.
Accordingly, the Township’s Ordinance advances, rather than detract from,
multigenerational family continuity.
7. Mandatory Set Aside Ordinance
The Mandatory Set Aside Ordinance adopted and included as Exhibit F in the
Third-Round HEFSP will be repealed due to the unintended consequences of
such ordinance. More specifically, there are occasions where prospective
residential housing developers retreated from pursuing projects due to the
requirements of the ordinance. Had those developments been permitted to move
forward without an affordable housing set aside but rather a contribution, much
needed infusions into the Affordable Housing Trust Fund would have been
realized. As such, in accordance with the agreement reached with Fair Share
Housing Center, the Ordinance will be repealed.
8. Development Fee Ordinance
Robbinsville first adopted its development fee ordinance in 2011, with the most
recent amendment adopted in 2017 (refer to Appendix I). The ordinance is
codified at §142-96 of the Township Code. It authorizes the collection of
residential development fees equal to 1.5% of the equalized assessed value of
new residential construction and additions, and non-residential development fees
equal to 2.5% of the equalized assessed value of new non-residential
construction and additions. Once the New Jersey Department of Community
34
Affairs (DCA) and the New Jersey Housing and Mortgage Finance Agency
(HMFA) finalize their proposed rule changes—anticipated no earlier than June
30, 2025—the Township will prepare an updated development fee ordinance.
This revised ordinance will be consistent with the forthcoming regulations under
N.J.A.C. 5:99, the expected 2025 updates to the Uniform Housing Affordability
Controls (UHAC), any applicable Council on Affordable Housing (COAH) rules
not superseded by the new DCA or UHAC regulations, and will also reflect the
terms of the court-approved Third-Round agreement with the Fair Share Housing
Center (FSHC).
9. Spending Plan
Following the finalization of rule proposals by the New Jersey Department of
Community Affairs (DCA) and the New Jersey Housing and Mortgage Finance
Agency (HMFA)—which is not expected prior to June 30, 2025—the Township
will develop an updated Spending Plan. This plan will be prepared in accordance
with DCA’s anticipated new regulations under N.J.A.C. 5:99, the forthcoming
2025 amendments to the Uniform Housing Affordability Controls (UHAC), and
any existing Council on Affordable Housing (COAH) regulations that remain
applicable and are not superseded by the new DCA or UHAC rules. Additionally,
the updated Spending Plan will incorporate provisions necessary to comply with
the terms of the court-approved Third-Round agreement with the Fair Share
Housing Center (FSHC).
The forthcoming Spending Plan will outline projected revenue sources, the
process for revenue collection, and the intended allocation of those funds. It will
be developed in accordance with the applicable substantive rules. All funds
collected will be deposited into the Township’s Affordable Housing Trust Fund
and may be utilized to support eligible affordable housing activities, including but
not limited to:
• New construction of affordable housing units and related development
costs;
• Extensions or improvements of roads and infrastructure directly serving
affordable housing development sites;
• Acquisition and/or improvement of land to be used for affordable housing;
• Purchase of affordable housing units for the purpose of maintaining or
implementing affordability controls;
• Maintenance and repair of affordable housing units;
• Repayment of municipal bonds issued to finance low- and moderate-
income housing activity; and
• Any other activity as specified in the approved spending plan.
A minimum of 30% of development fee revenues – excluding those expended
after July 17, 2008, when affordability assistance became a statutory
35
requirement under the Fair Housing Act – must be allocated toward providing
affordability assistance for low- and moderate-income households residing in
affordable units identified in the municipality’s Fair Share Plan. Of that portion, at
least one-third must specifically support very low-income households.
Additionally, no more than 20% of the annual development fee revenue may be
used for administrative purposes. This includes, but is not limited to,
compensation and benefits for municipal staff or payments to consultants
engaged in the preparation or implementation of rehabilitation programs, new
construction initiatives, housing elements and fair share plans, or affirmative
marketing strategies. It should be noted that the 30% affordability assistance
requirement may be subject to change, pending adoption of new regulations
currently under consideration by the New Jersey Department of Community
Affairs (DCA) or the New Jersey Housing and Mortgage Finance Agency
(HMFA). The Township will comply with any revisions to the applicable legal and
regulatory framework once they are enacted.
In order to address the Township’s affordability assistance obligation in Round
4, the Township will continue its Emergency Repair/Energy Efficiency Assistance
Program for the affordable housing properties in Robbinsville. This helps the
current owners of affordable units that would not have the funds necessary to
keep their properties up to code. The Township provides loans to currently
income eligible owners of affordable properties up to $20,000 that are interest
free, no monthly payments and are forgiven if the homeowner remains in the
affordable property for 6 years.
10. State Development and Redevelopment Plan Consistency
This Housing Element and Fair Share Plan aligns with the 2001 State
Development and Redevelopment Plan (SDRP) and the draft proposed update.
The projects and zoning strategies outlined herein create a realistic opportunity
for the development of affordable housing. In accordance with the SDRP,
Planning Area 2 (PA2)—the Suburban Planning Area is prioritized for providing
much of the state’s future development, and concentrating growth in Centers and
compact areas. Robbinsville is located within PA2, rendering it a suitable and
consistent location for affordable housing development. Advancing affordable
housing in PA2 furthers the SDRP’s overarching objective of concentrating
growth in established centers with existing infrastructure.
36
The Township of Robbinsville Planning Areas Map
11. Consideration of Lands Appropriate for Affordable Housing
The properties identified in this plan, as well as in the previous Housing Element
and Fair Share Plan (HEFSP) for the Third-Round, has been determined by the
Planning Board—through careful analysis and evaluation—to offer the most
viable opportunity for redevelopment into multi-family and mixed-use inclusionary
development to help satisfy Robbinsville’s affordable housing obligations.
12. Cost Generation
The Township has reviewed its Land Development Ordinance and related land-
use provisions to identify and eliminate any unnecessary cost-generating
standards. No such provisions have been identified to date. To ensure continued
Source: New Jersey Department of State Office of Planning Advocacy Locator Map
37
compliance, development applications involving affordable housing will be
reviewed for consistency with the Township Code, the Residential Site
Improvement Standards (N.J.A.C. 5:21-1 et seq.), the Municipal Land Use Law
(N.J.S.A. 40:55D-40.1 through -40.7), and the Fair Housing Act's prohibition on
unnecessary cost-generating features.
The Township will comply with the procedural requirements set forth in N.J.A.C.
5:93-10.1(a) and (b), as well as with N.J.A.C. 5:93-10.3 and -10.4 concerning
special studies and escrow accounts for development applications containing
affordable housing.
13. Monitoring
Pursuant to the requirements set forth in N.J.S.A. 52:27D-329.2 and 329.4, as
amended by P.L. 2024, c.2, the Municipality will submit an annual report by
February 15 of each year during the Fourth-Round. This report will be filed
through the New Jersey Department of Community Affairs’ (DCA) newly
established Affordable Housing Monitoring System (AHMS). The submission will
include a comprehensive accounting of all affordable housing units completed or
under construction in the preceding calendar year, along with a record of all
residential and non-residential development fees collected, interest accrued, and
other revenues deposited into Township’s Affordable Housing Trust Fund during
that period. The Township will also provide a detailed report on all expenditures
from the trust fund, including specific amounts, purposes, and the remaining fund
balance as of December 31 of the prior year.
Additionally, the Township—or any other interested party—may initiate a realistic
opportunity review through the AHMS Program at the midpoint of the Fourth-
Round certification period. Public notice will be required, and the review will
include an evaluation of any inclusionary development site listed in this Housing
Element and Fair Share Plan that has not received preliminary site plan approval
by the midpoint of the 10-year cycle. In the event such a review is initiated, the
Township may identify and propose one or more alternative sites, along with
detailed development plans, that offer a realistic opportunity to deliver the same
number of affordable units and meet the standards of the Fair Housing Act and
Mount Laurel doctrine.
38
IV.
Appendix
A. All Zoning Amendments
B. Affordable Housing Ordinance
C. Set Aside Ordinance
D. Development Fee Ordinance
E. Affirmative Marketing Plan
F. Spending Plan
G. Resolution of Intent
H. Copies of Resolutions
I. 2017 Housing Element Plan
J. 2018 Housing Element Plan
K. Rehabilitation Completion Status Information
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