American Outdoor Advertising, LLC v. Edison Township Zoning Board of Adjustment

New Jersey Superior Court Appellate Division·Decided August 17, 2026·No. A-0278-24·Unpublished

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION

DOCKET NO. A-0278-24

AMERICAN OUTDOOR ADVERTISING, LLC,

Plaintiff-Appellant,

v.

EDISON TOWNSHIP ZONING BOARD OF ADJUSTMENT,

Defendant-Respondent.

Argued June 4, 2026 ‒ Decided August 17, 2026 Before Judges Marczyk and Bishop-Thompson.

On appeal from the Superior Court of New Jersey, Law Division, Middlesex County, Docket No. L-

5750-23.

Keith A. Loughlin argued the cause for appellant (Inglesino Taylor, attorneys; John P. Inglesino, of counsel and on the briefs; Keith A. Loughlin, on the briefs).

Scott D. Salmon argued the cause for respondent (Jardim Meisner Salmon Sprague & Susser PC,

attorneys; Scott D. Salmon, of counsel and on the briefs; Bhavini Tara Shah, on the briefs).

PER CURIAM In this prerogative writs matter, plaintiff American Outdoor Advertising, LLC (AOA) appeals from the September 10, 2024 order affirming defendant Edison Township Zoning Board of Adjustment's (Board) denial of its variance application and dismissing its complaint in lieu of prerogative writs with prejudice. Having considered the arguments, the record, and the applicable legal principles, we reverse and remand for a new determination by the Board.

I.

AOA is a limited liability company that builds and operates billboards throughout the United States. On March 29, 2022, AOA applied to the Board requesting preliminary and final site plan approval to install a double-sided, 100 foot high, 672-square-foot (fourteen feet by forty-eight feet) digital billboard with LED lighting on the northeast side of a leased industrial site at 740 Old Post Road in Edison. The 6.4-acre site contains several one-story self- storage buildings. The property is located within the L-I Light Industrial Zone District (L-I Zone) and both fronts and adjoins the northbound side of the New Jersey Turnpike (I-95), a twelve-lane interstate highway.

A-0278-24

The application also sought a "(d)(6)" height variance to permit a 100-

foot height where the maximum building height is fifteen feet. In addition, several bulk or "(c)" variances were sought: approval for a two-sided sign where only one sign face is permitted; an increase in maximum sign area from 250 square feet to the proposed 672 square feet; a reduction in the required front yard setback from the street line to ten feet from I-95; and a reduction in the required rear or side yard setback from forty feet to fifteen feet.

The proposed billboard measured 672 square feet, which is the standard size approved by the New Jersey Department of Transportation (NJDOT). An outdoor advertising permit was issued by the NJDOT, valid from May 16, 2022, through May 15, 2023. The permit, however, expressly stated it did not relieve AOA from obtaining local approvals.

The Edison Township Zoning Ordinance § 37-62.11 governs signs in the L-I Zone. Edison, N.J., Code § 37-62.11 (1999). Specifically, section (b)(3)(a), Freestanding Signs in L[-]I Zone (1999)1 stated:

1 The ordinance was amended on May 8, 2024, and subsection (b)(3)(a) was modified to address signs in commercial districts. Subsection (b)(3)(b) addresses freestanding sign and now reads:

(b). Freestanding signs shall be permitted as follows:

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Freestanding or billboard signs advertising products or services not sold on the premises, freestanding or billboard signs advertising or directing your attention to another premises, and any other sign unrelated to the premises on which the sign is erected, shall only be permitted in the L[-]I [Z]one. No such sign shall exceed fifteen . . . feet in height; such signs shall be only one-sided; and such signs shall not exceed two hundred fifty . . . square feet in area, and no sign permitted by this subsection shall be erected within two thousand five hundred . . . feet of any other sign permitted in this subsection.

While subsection (b)(3)(b), "[n]o signs permitted by [(b)(1)] shall encroach upon the required front yard, rear yard[,] or side yard setbacks."

1. No freestanding sign shall exceed fifteen . . . feet in height; the maximum width of any one . . . side of the sign shall not exceed twenty . . . feet and the total square footage of any such sign shall not exceed . . .

[]200[] square feet in area or one . . . square foot for each five . . . feet of street frontage, whichever is less. The total area of all signs on the subject property shall not exceed []500[] square feet in area in the aggregate, and the signs shall not be closer to one another than . . . []1,600[] feet.

2. Such signs shall be set back at least fifteen . . .

feet from the street line and no such sign shall encroach upon the required side yard or rear yard setback.

[Edison, N.J., Code § 37-62.11 (1999) (amended 2024).]

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The Board held four public hearings on AOA's application: September 20 and November 22, 2022; January 17 and February 21, 2023. During the September hearing, AOA presented its application through Tiago Duarte, a professional engineer. As Duarte provided testimony about the billboard face, the message, or compliance with NJDOT standards, Chair Rosemary Feterik interjected, announcing the Board would not approve the application as submitted with respect to the proposed flip time for changing messages on the digital billboard, stating:

I can stop you right there. This [B]oard does not – we don't have to go – because the [NJ]DOT says every [two] seconds, this [B]oard has never given [two]

seconds. The least amount of time this [B]oard has given has been [five] minutes.

So[,] if we're not on the same page, it doesn't pay to carry – to keep going . . . forward. But if you think you're going to get [two] seconds, this [B]oard is not going to give you [two] seconds . . . .

AOA objected to Feterik's statements and requested her recusal at the November hearing; however, she declined to recuse herself.

Duarte testified the proposed height of the billboard was necessary because the site sits approximately twenty-five feet lower than I-95, and mature trees—ranging from thirty to forty feet tall—surround the area. As a result, the billboard needs to be positioned above the tree line to ensure A-0278-24

visibility. He noted the nearest residential properties were 650 to 900 feet away. Duarte presented a lighting exhibit demonstrating that beyond a 500 - foot radius from the billboard, there would be no appreciable change in ambient light levels, and at 300 feet, the impact would be minimal. He concluded the proposed billboard would not impact existing site operations, impervious surface, drainage, or traffic conditions.

Justin Taylor, a professional traffic operations engineer, testified concerning the traffic safety assessment for the project. He explained that studies by the Federal Highway Administration (FHWA) and NJDOT found digital billboards do not negatively impact traffic safety, and the proposed eight-second flip time would be both safe and efficient. Taylor presented a site visibility study, concluding the billboard would be visible to northbound and southbound motorists at optimal distances, but would not be legible until approximately 500 feet away. He testified the average driver views a billboard for one second, with an average fixation time of 0.4 seconds—both below the threshold for distraction. Taylor also testified the eight-second flip time is standard, and the billboard's location and design would not create any safety concerns for traffic.

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