Supporting Documentation · Oct 15, 2026
Interpretation submission 73026
da34d56eac574e3406a02e49ae14331b6ce25daa73bc37a7639f1f7e5e692092Indexed text
mbled, pre-plated, or held under a heat lamp for immediate pickup as in a conventional fast-food format. The open kitchen also allows guests to see food prepared to order, which is characteristic of a full-service or fast-casual restaurant model rather than a fast-food operation. 2. Dine-In Operations This location will offer a full dine-in experience. Guests who dine in are served on reusable plateware with metal silverware, not disposable wrappers or containers — directly contrary to the Zoning Code's definition of a Fast Food Restaurant. We are traditional casual dining with our sales average of 83% Dine-In and 17% Drive-thru. 3. To-Go Packaging and Sustainability For off-premises orders, Just Salad uses packaging engineered to minimize environmental impact rather than standard disposable fast-food containers. As of the company's most recent sustainability audit, roughly 91% of Just Salad's disposable food-service packaging is made from recycled and/or renewable materials, and 663 Lexington Avenue 2nd Floor, New York, NY 10022 212.244.1111
approximately 90% is recyclable, reusable, or compostable. Just Salad was the first U.S. restaurant chain to carbon-label its full menu, and offers a “Climatarian” menu filter highlighting the lowest-carbon-footprint items, along with a utensil opt-out option for delivery and pickup orders. These practices reflect an operating philosophy centered on reducing waste, which is inconsistent with the disposable-packaging model contemplated by the Fast Food Restaurant definition. 4. Dietary Restriction Accommodations Because every item is built to order from individual components, Just Salad's menu readily accommodates vegan, vegetarian, gluten-free, dairy-free, and other dietary needs without a separate kitchen process or special order, guests simply select ingredients matching their restrictions. The menu clearly identifies plant-based and allergen-relevant items, and full ingredient and allergen information is available to guests in-store and on the Just Salad app. This individualized, guest-directed approach to food preparation is a further point of distinction from a fast-food model, where menu items are standardized and offer little to no ability to accommodate individual dietary restrictions at the point of order. 5. Quality of Ingredients Just Salad's kitchens receive fresh produce, proteins, and grains that are prepared, portioned, and cooked in- house daily; nothing is delivered to the store frozen or pre-cooked for immediate service. The menu is refreshed seasonally to incorporate fresher, higher-quality produce as it becomes available, and includes offerings highlighted for lower environmental impact under the company's carbon-labeling program. This emphasis on freshly prepared, restaurant-quality ingredients, rather than shelf-stable or par-cooked fast-food components, is consistent with a traditional restaurant kitchen model. 6. Seating A copy of the proposed store layout is enclosed as Exhibit B. The layout provides for 26 interior dine-in seats, reflecting Just Salad's intent to operate this location as a genuine dine-in restaurant destination and not solely a pickup or drive-thru point of sale. 7. Drive-Thru Ordering and Wait Times The proposed drive-up window is an accessory use to the restaurant, consistent with the Township's approval of our site plan, and is not a substitute for counter or dine-in service. Because each order is prepared
drive-up window is an accessory use to the restaurant, consistent with the Township's approval of our site plan, and is not a substitute for counter or dine-in service. Because each order is prepared fresh at the time it is placed rather than assembled from pre-made inventory, guests using the drive-up window experience a wait time comparable to placing a made-to-order meal inside the restaurant, materially longer than the rapid, ready-to-eat service contemplated by the Fast Food Restaurant definition. Based on comparable Just Salad drive-thru locations, average order time at the window is approximately 3 minutes and 20 seconds, and we are glad to provide operational data from comparable Just Salad drive-thru sites if helpful to your review. 8. Overall Ethos Just Salad's mission is to make everyday health and sustainability accessible, and every element of the guest experience, the open kitchen, made-to-order preparation, reusable serviceware and packaging, dietary transparency, and emphasis on fresh ingredients, is built around that mission rather than around speed-of- service or disposability. This ethos is shared with other made-to-order, build-your-own restaurants operating within the same shopping center, such as Chipotle and Jersey Mike's, which similarly prepare food to each customer's specification rather than offering premade, ready-to-eat items. 663 Lexington Avenue 2nd Floor, New York, NY 10022 212.244.1111
For the reasons above, Just Salad's model of operation is fundamentally distinct from the Zoning Code's definition of a Fast Food Restaurant: 1. Made-to-Order Preparation: Just Salad does not sell premade or ready-to-eat food. Every salad and bowl is prepared individually, from scratch, based on each customer's specific selection of ingredients, proteins, and dressings at the time of order. 2. Fresh Daily Preparation: All ingredients are prepared fresh daily in-house. Nothing arrives at our location frozen or pre-cooked, a standard more akin to a traditional restaurant kitchen than a fast-food model. 3. Meaningful Preparation Time: Because each item is made to order using freshly prepared ingredients, customers experience a wait time that is inherently longer than that of a typical fast-food establishment, where items are pre-made and simply retrieved for the customer. 4. Dine-In Experience with Non-Disposable Serviceware: Just Salad offers a dine-in option for guests, served on real plateware and silverware rather than disposable wrappers or containers directly contrary to the Code's definition of a Fast-Food Restaurant. We respectfully submit that Just Salad does not fall within the definition of a Fast-Food Restaurant under the West Orange Zoning Code and should be classified as a Restaurant. We welcome the opportunity to provide any additional information or documentation, including operational data from comparable Just Salad locations, that may be helpful for your review. We can be reached at (314) 277-3575 or jrichter@justsalad.com. Thank you for your time and consideration. Respectfully, Jennifer Richter Director, Project Development 663 Lexington Avenue 2nd Floor, New York, NY 10022 212.244.1111
July 15, 2026 Ms. Genice Gary-Adams Zoning Official Township of West Orange 66 Main Street West Orange, NJ 07052 RE: honeygrow, West Orange Plaza Block 152.01, Lots 1445 & 1445.05 Dear Ms. Gary-Adams: I write to you as the Senior Real Estate Manager for honeygrow, a fast-casual brand based in Philadelphia, PA. I understand that there may still be some confusion regarding our use, although we understood this matter to be settled, prior to executing the lease agreement for the above referenced location in West Orange Plaza. Please accept this correspondence as our emphatic denial of defining our use as “fast-food”. honeygrow offers healthy, creative, and craveable stir-fry, salads, and honeybars. While we do offer a menu of suggested items, guests are free to customize each as they like and can create their own dishes as they like. This allows us to meet each of our guests wherever they are on their wellness journey and allows us to accommodate the dietary preferences, restrictions, or needs of each guest. High quality ingredients are prepared daily to maintain optimal freshness and nutrition, and our proprietary noodles, sauces, and dressings are locally sourced. Each meal is freshly prepared to-order. Only incidental offerings, such as bottled beverages, Terra chips, brownies, and focaccia bread, could be considered “ready-to-eat”. Guests may place orders online, through third-party platforms such as DoorDash, through the honeygrow app, or in-restaurant at the kiosks, for dining-in or taking-out. Dining-in serve ware is not disposable, and meals are not “served in or on disposable wrappers, containers, or plates”. Containers for those meals being taken out are responsibly sourced and recyclable. Orders are prepared as they are received, regardless of the means of ordering, and the wait time is generally about 7-10 minutes, exceeding the wait time experienced at a fast-food location. A majority of our guests, regardless of the means of ordering, choose to dine-in. honeygrow places as much emphasis on the built design as the culinary experience. A clean, modern dining room, accommodating 25 – 50 guests, depending on the size of the location, shares the “front of house” with an open kitchen designed to provide guests with transparency as they can see orders being prepared. Custom fixtures and warm lighting, with bright, playful murals and
shares the “front of house” with an open kitchen designed to provide guests with transparency as they can see orders being prepared. Custom fixtures and warm lighting, with bright, playful murals and energizing 1624 Locust Street, 6th Floor, Philadelphia, PA 19103 | 215-545-1206 www.honeygrow.com
music, create spaces for our team and our guests to enjoy an authentic hospitality experience, which is a foundational cornerstone of our brand. Consistently delivering an outstanding guest experience while also building real connections with the communities in which we chose to locate has driven our growth over the last five years. We have already committed significant resources to this location and have high expectations of our success here as part of the West Orange community. We respectfully request that the Township consider the above to clarify the interpretation of the zoning code to properly classify honeygrow as a fast-casual brand and allow us to proceed with our location in West Orange Plaza. Sincerely, honeygrow, LLC Jennifer S. Leonard Senior Real Estate Manager 1624 Locust Street, 6th Floor, Philadelphia, PA 19103 | 215-545-1206 www.honeygrow.com
PARKER MIDDLETON parker.middleton@cava.com July 20, 2026 Ms. Genice Gary-Adams Zoning Official Township of West Orange 66 Main Street West Orange, NJ 07052 RE: Zoning Board Approval Request Township of West Orange, NJ Existing Zone P-C, Planned Commercial Dear Ms. Gary-Adams, I am writing on behalf of CAVA Mezze Grill, LLC (“CAVA”) in connection with its proposed lease and operation of a CAVA restaurant at 235 Prospect Avenue, West Orange, NJ 07052 (the “Property”). CAVA respectfully requests a determination that the proposed use is a “Restaurant,” not a “Fast Food Restaurant,” under Section 25-4 of Ordinance No. 2436-15 § 2; Ordinance. No. 2357-12 § 25-4 of the Township of West Orange, New Jersey Zoning Code (the “Code”). This request is based on the actual, site-specific operating plan described below, including the location's dine-in focus, made-to-order food preparation, emphasis on fresh ingredients, and accessory take-out component. The Code defines “Fast Food Restaurant” to “mean the retail sale of ready-to-eat foods and beverages for on and/or off premises consumption, whenever the foods and beverages are available upon a short waiting time, and orders are placed by the customer at a counter, and primarily served in or on disposable wrappers, containers or plates, and where there is a seating capacity of more than 15 individuals. This does not include restaurants which have ‘take-out’ as accessory to a traditional restaurant.” To be sure, the Fast Food Restaurant definition is conjunctive: it links multiple operational elements with the word “and,” and it expressly excludes a restaurant whose take-out business is accessory to a traditional restaurant. The proposed CAVA does not satisfy all of these elements, and indeed, its take-out business is accessory. Accordingly, the proposed use falls within the Code's “Restaurant” definition 1 only. I. EXPLANATION OF PROPOSED CAVA CONCEPT AND OPERATIONS A. Menu and Culinary Program CAVA is a Mediterranean restaurant concept centered on complete meals rather than standardized, pre- wrapped food. Its menu includes fresh, chef-curated meals and build-your-own bowls and pitas. A guest typically selects a greens and/or grains base, one or more dips or
rather than standardized, pre- wrapped food. Its menu includes fresh, chef-curated meals and build-your-own bowls and pitas. A guest typically selects a greens and/or grains base, one or more dips or spreads, a protein, vegetables and other toppings, and a dressing sauce. The proposed location will offer more than 38 ingredients, allowing more 1 “Restaurant” is defined under the Code to “mean a public establishment which serves food and drink primarily or exclusively for consumption on the premises and is not a 'fast food restaurant' as defined in this chapter. For the purposes of this chapter, a 'bar' shall also be deemed a 'restaurant' only if food is prepared, served and consumed on the premises."
Page | 2 than 17.4 billion possible combinations. The menu is therefore designed around individualized meal composition, flavor pairing, and dietary choice - not the rapid handoff of a small number of uniform, preassembled items. At the proposed location, grains are cooked; proteins are grilled or roasted; pita warmed; dips are portioned; and many of the toppings, marinades, dressings and beverages made in-house. Certain proprietary dips, spreads, and dressing bases are produced in CAVA's food-production facilities to maintain recipe integrity and consistency with the final preparation, heating, portioning, assembly, and finishing occur in the restaurant. B. Made-to-Order, Customizable, Customer-Facing Preparation In-person guests order through a customer-facing, open-kitchen service line. A team member begins the meal only after the guest selects a chef-curated item or provides customization instructions. We offer an assembly-line, not counter, ordering format. The guest interacts with team members at successive stations while the meal is assembled and finished in view. The process permits changes in portion, ingredients, sauces, and toppings, subject to food-safety and recipe standards. Food is not selected from a rack of pre-wrapped entrees held for immediate sale. The off-premises component is accessory to the dine-in restaurant. It uses the same kitchen, menu, staff, and food-preparation systems; it occupies only 45 square feet of the premises; and it is subordinate to the dining room and on-premises operation. The site will not include exterior ordering lanes or substantial driver waiting area. The digital system is an additional ordering channel; it does not convert the dining room or customer-facing kitchen into a take-out establishment. In addition to the internal pickup area, the proposed location will offer its guests a convenient mobile order drive-thru pickup window. The mobile order pickup window is exclusively for the pickup of previously placed orders and no orders are taken nor any currency exchanged at the window. This is precisely the circumstance addressed by the final sentence of the Fast-Food Restaurant definition: a restaurant is not converted into a prohibited fast-food use merely because it offers take-out as an accessory service. Indeed, full-service restaurants similarly offer take-out as an accessory service, whether through
File revisions (1)
- Sep 29, 2026
da34d56eac576,837,619 bytes