A coordinated set of talking points for neighbors who plan to comment at the Narberth Planning Commission hearing on the proposed 4A district amendments.
Before You Speak: Why Planning Commission Testimony Is Different
Planning Commission testimony is a different game than Borough Council testimony, and the audience-shaping matters.
Council is political. Council members take votes that can be challenged at the ballot box and are responsive to community sentiment.
Planning Commission is technical and advisory. It produces a written recommendation that becomes part of the official record.
Three practical implications follow:
Factual gaps and procedural defects matter most. These are what survive into a Court of Common Pleas appeal under the Pennsylvania Municipalities Planning Code (MPC). Emotional appeals don’t preserve issues for appeal — specific objections to specific provisions do.
Questions on the record can be more powerful than statements. A pointed question forces the Commission either to answer (creating record) or refuse to answer (also creating record — and a useful talking point at Council).
Coordinate across speakers. With limited time per speaker (typically three minutes), testimony is dramatically more effective if 5–8 neighbors divide the talking points among themselves rather than each trying to hit everything.
What follows is a structured set of talking points, ordered roughly from strongest to most situational. Use them as a menu — assign topics across speakers in advance.
1. Comprehensive Plan Consistency
This is the single strongest legal hook in the entire toolkit.
MPC § 606 requires that zoning ordinances be enacted “in accordance with” a comprehensive plan. Pennsylvania courts have read this requirement loosely — strict consistency is not required — but a record showing that the proposed amendment contradicts specific comprehensive plan policies is meaningful both procedurally and politically.
What to do:
- Pull specific quoted policies from the Narberth 2040 Comprehensive Plan that emphasize preservation of neighborhood character, historic context, walkability scaled to existing fabric, and protection of small-scale residential blocks.
- Read those policies aloud verbatim, then describe how the proposed 4A amendments work against each one.
- Get this exact phrase on the record: “This amendment is not in accordance with the Narberth 2040 Comprehensive Plan with respect to [specific policy], and the Borough has not provided a written rationale reconciling the inconsistency.”
Direct question to ask:
What is the Commission’s written analysis of how the proposed 4A amendments are in accordance with the Comprehensive Plan? Will that analysis be included in the Commission’s formal recommendation?
If the Commission has not produced such an analysis, that absence is itself the talking point.
2. Procedural Deficiencies and Notice Issues
The MPC sets specific procedural requirements for zoning amendments that are mechanical but enforceable. Procedural defects can void an ordinance under MPC § 1002-A.
Issues to put on the record:
Notice content under MPC § 609. Has the published notice fully and accurately described the substance of the proposed amendments, including the by-right vs. conditional use change and the height increase? An ambiguous or incomplete notice is grounds for challenge.
Public availability of the full text under MPC § 610. Is the complete text of every proposed amendment publicly available, including any associated regulating diagrams, definitions changes, and cross-references? Is it available in physical form at Borough Hall as well as online? If the only access route to key documents requires a Microsoft account or similar credentialed login, that is a meaningful access barrier worth naming on the record.
County Planning Commission referral under MPC § 609(e). A proposed amendment must be submitted to the Montgomery County Planning Commission at least 30 days before the public hearing. Has that been done? Is the County’s response on the record? If not, this is a hard procedural defect.
30-day appeal window awareness. State on the record:
The public reserves the right to challenge any procedural defect within the 30-day window provided by the MPC following final action.
This signals to the Commission that the opposition is tracking compliance carefully.
3. The Absence of Site-Specific Studies
A district-wide upzoning that allows by-right 45-foot, 4-story development at the most prominent gateway parcels — including 198 Elmwood directly across from the train station, and the other corner-lot parcels along the South Side — should be supported by concrete analysis. Form-based regulating diagrams show the abstract rule, not the concrete result.
Studies that should exist but appear to be missing:
- Maximum build-out massing studies for the highest-impact parcels under the maximum allowable envelope
- A traffic impact analysis for the South Side using the projected build-out density, particularly at the train station crossing and the constrained side streets
- A school district capacity letter from Lower Merion School District reflecting the projected unit count
- A water and sewer capacity letter from the relevant water utility and from Lower Merion’s sewer system
The explicit request:
I request that the Planning Commission’s recommendation include either (a) the foregoing studies or (b) a written explanation for why the Commission considers them unnecessary.
Either response advances the public’s interest in a complete record.
4. The By-Right vs. Conditional Use Change
Most public discussion focuses on the height and density numbers, but the procedural change from conditional use to by-right is arguably the single most consequential provision in the entire amendment.
Under conditional use: every project receives individual public review, neighbor notification, and Planning Commission scrutiny against specific standards.
Under by-right: an application that meets the dimensional standards is approved administratively, with:
- No public hearing on individual projects
- No notice to abutting property owners
- No discretion to require traffic mitigation, design modification, or context-sensitive massing
- No record-creating opportunity for community input on each development
The talking point:
The proposed shift from conditional use to by-right approval is the elimination of a public-process safeguard, not a technical reform. It removes the community’s only formal voice in evaluating individual projects on their merits.
Ask whether the Commission has weighed the loss of that public process against the claimed benefits of streamlined development.
5. Test the Parking Numbers
Reduced parking requirements are usually defended on transit-oriented-development grounds. That argument has surface plausibility for Narberth (the train station is right there), but it is testable.
Specific challenges:
What is the actual mode share? SEPTA Paoli/Thorndale Line ridership data is publicly available. What percentage of South Side residents currently commute by rail? A 0.7-space-per-unit ratio implicitly assumes roughly 30% car-free households. Is that supported by American Community Survey commute-mode data for Narberth?
Where will overflow parking go? South Side streets are already constrained. Has the Borough conducted a parking utilization study showing existing occupancy by block-face during peak overnight hours? If not, the ratio is an assumption, not an empirical finding.
Visitor and service parking. A 0.7 ratio covers residents only. Where does visitor parking, contractor parking, delivery, and rideshare staging go? Onto already-saturated public streets.
The framing:
The 0.7 ratio is a policy choice, not a technical calculation. The Commission should require a parking impact study before recommending it.
6. The Gateway Parcels — 198 Elmwood and the Corners
This argument connects the abstract amendment to a concrete and emotionally resonant site. The points to make:
198 Elmwood is the single most prominent parcel in the rezoning area — directly across from the train station, on a corner, at the highest-traffic civic gateway in the borough.
The site historically held the Baptist Church of the Evangel, an 1891 stone church that anchored the South Side neighborhood for more than 130 years. The current zoning treatment of this parcel determines what visitors see when they arrive in Narberth by train.
The proposed 4A standards would permit a 45-foot, 4-story by-right structure on this parcel with no public review of its design, scale, or relationship to the train station and to the historic district across Haverford Avenue.
The argument:
If the Borough’s intent is to encourage station-area development that reflects Narberth’s character, the gateway parcels deserve special standards — overlay design review, height step-downs at corners, or required public review at minimum — not the same by-right administrative approval that applies to interior parcels.
7. The Historic District Interface
Narberth has a Historic District Overlay covering parts of the downtown core. The South Side abuts but mostly sits outside that overlay. The amendment as written allows by-right 45-foot construction immediately adjacent to lower-scale historic-district fabric.
Question to ask on the record:
What design review or transition standards apply at the boundary between the proposed 4A district and the Historic District Overlay? Will the Commission recommend transition height-stepping at this boundary?
Reference the Secretary of the Interior’s Standards for Rehabilitation, which establish that new construction adjacent to a historic district should respect the scale and rhythm of existing fabric. By-right 45-foot envelopes adjacent to a 25-foot streetscape do not meet that standard.
8. Test the Economic Claims
The Borough’s case for upzoning likely includes some version of: increases housing supply, supports affordability, generates tax revenue, supports downtown businesses. Each of these claims is testable.
Affordability. New construction at 45 feet near a train station in a high-demand market will produce market-rate housing, not affordable housing. Pennsylvania does not authorize mandatory inclusionary zoning, and the proposed amendment does not include voluntary inclusionary incentives.
What specific provisions of the amendment will produce price-restricted affordable units, and how many?
If the answer is “none,” the affordability rationale should be removed from the public discussion.
Tax revenue. New housing produces both tax revenue and tax demand — school services, sewer, fire, police, road wear. Has the Borough done a fiscal impact analysis comparing projected revenue to projected service cost, including the Lower Merion School District impact (which is the largest cost-driver for any new residential unit)? If not, the revenue argument is unsupported.
Downtown vitality. Has the Borough surveyed downtown businesses about whether their constraint is foot traffic from new residents or parking access for existing customers? These point in opposite directions — adding residents helps the first, hurts the second.
9. Constructive Alternatives
Pure opposition is harder to sell than opposition-plus-alternative. Even if the alternatives are not your real preference, putting them on the record reframes the opposition as constructive rather than reflexive.
Targeted upzoning rather than district-wide. Apply the new standards only to specific identified parcels through a redevelopment overlay, not to the entire 4A district.
Retain conditional use review. Increase allowable density and height but keep the conditional use process so each project receives individual scrutiny.
Tier the height standards. 45 feet on Haverford Avenue frontage stepping down to 35 feet mid-block, and to existing 30 feet at the rear lot lines. This is standard form-based code practice.
Require a phased approach. Apply the new standards to a defined geography for a defined period, evaluate outcomes, and extend only after review. Sunset provisions are standard zoning practice and entirely legal under Pennsylvania law.
Pause for the Comprehensive Plan update. If a Comprehensive Plan update is on the horizon, ask why a major upzoning is being adopted before that plan is updated.
10. The Specific Ask
Close every coordinated testimony with a specific request. Vague opposition is easier to dismiss than concrete demands.
I request that the Planning Commission either delay its recommendation pending [specific studies] or include in its recommendation a written finding that those studies are unnecessary, with the Commission’s stated reasoning.
I request that the Commission recommend a continuance of the public comment period to allow neighbors adequate time to review the materials provided and the regulating diagrams.
I request that the Commission’s written recommendation address each of the substantive comments received, rather than aggregating them, so that the record reflects the Commission’s reasoning on each issue.
That last request matters: a Commission recommendation that summarily dismisses public comment is procedurally weaker than one that engages with comments individually.
Delivery and Tactics
A few things that are easy to overlook in the moment.
State your name and street address at the outset. This establishes standing — that you are an aggrieved party with a property interest within the affected area — which preserves your right to appeal under MPC § 1002-A.
Submit written comments alongside oral testimony. Bring a printed copy for the secretary and request that it be entered into the record. Oral testimony alone is sometimes paraphrased in minutes; written comments survive verbatim.
Reference specific section numbers when you can. “Section 500-XX of the Code” is more credible than “the height limit.” If you don’t know the exact section, “the proposed amendment to the height standard for the 4A district” is fine.
Preserve objections for appeal. A line like “I object to this amendment on the grounds previously stated and reserve all rights under the MPC” takes five seconds and matters legally.
Film the meeting if permitted. Confirm Borough policy on recording in advance. A transparent recording is your protection against meeting minutes that mischaracterize testimony.
Attack the proposal, not the people. Critique the analysis, the process, the absence of evidence — not Planning Commission members or staff personally. This matters both for civility and for credibility with Council later.
Stay until the end. Commissions sometimes schedule controversial items late in the agenda assuming opponents will leave. Stay through the vote and any subsequent discussion. The post-vote conversation often reveals issues you will want to know about.
A Word on Coordination
If the opposition has 8 or 10 people speaking, pre-assign topics so coverage is complete and redundancy is minimal. One person takes Comprehensive Plan consistency. Another takes procedural notice. Another takes parking. Another takes the gateway-parcel framing. And so on.
Pre-coordinated testimony from a clearly organized group is harder to dismiss than the same content delivered as scattered individual complaints. It signals to the Commission — and to the press, if any are present — that this is a serious, technical opposition, not generic NIMBY noise.
This guide is for informational purposes only and is not legal advice. Anyone planning to participate substantively in the rezoning challenge should consult a Pennsylvania-licensed land use attorney.