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Exhibit A
CITY OF MIAMI OMNI CRA PROPOSED EX1 WEST GROVE ARES FINDING OF NECESSITY October, 2017 .. VSCA- ]A FLVVIA y'> ; � M.A - CANDIA Q _ VELARDE l - u 40TH m ©pp PEACOCK G�7 O Y c y ALTARA_ . SHIPPING SAN LOFT ORANGE ii DAY PERCIVAL OAK FROW i=LpRiaA m GRAND WASHINGTON Ighl I n v z O PERCIVAL OAK = a m SNIPPING I ❑a y n- m r o m "Al m S DAY } n F7 TTI r _ CY � T PERCIVAL a LAMB o FROW FLORIDA THOMAS THOMAS < � THOMAS a WILLIAM WILLIA#ui m CHARLESua CHARLES- �I L l.i_�!s_Lt- L m CLES -, EPANKtIN-- T- LLLL- a-1� � 1�--I.'. Y KC-YMfll1AT' 4 4 al MARLER L. -- LQCUAT 11L11-L�� _ . . r- is 41P*17. I S 1 LLL PMG Associates, Inc. SECTION 1 INTRODUCTION 1.1 HISTORY AND PURPOSE This document represents the analysis of the Finding of Necessity (FON) for the expansion of the OMNI Community Redevelopment Area (CRA) in the City of Miami. This expansion is proposed to better serve the community and to further address the concerns of the neighborhoods. Based on the requirements of State Law, this FON addresses the proposed expansion area only. The FON for the original OMNI CRA was completed in 1987 and the district has received several updates and expansions over the years. This expansion adds the area known as West Grove to the OMNI CRA. Exhibit 1-1 depicts the OMNI CRA as currently comprised. Exhibit 1-2 provides the boundaries of the West Grove expansion area. The West Grove area is approximately 960 acres and contains 1,828 parcels. The proposed CRA expansion is generally the area east of the Dixie Highway, south of the Bird Road, west of McDonald Street, and north of Franklin/Marler Avenues. An additional triangular portion of the district is west of Dixie Highway bordered on the west by 39 Street. EXHIBIT 1-1 — EXISTING OMNI CRA BOUNDARY MAP a AlW TN 7 gyp NE 2d7k ST'y' f - CRA q NW PI Tff Sr. NEN TEST NW RaN raw• xNn r w t.'� �x . � +� �aaxnsr Logond x x w f V +Is � U !A 4 .� � -, NVV1T7F1 ST iT T 4 7 :H a r n - �.i+' ��g - N�VE .. lr NW1 p� ; VENETIAN W n` "i s r. oe .VENEnAN GSWY vr Ts �f•0 'RAhP -�. NW 4A TNS NE TN VAC RTHUR $K`y 1 : ` .r i •R NW 4iTH TER , NW i4.TM $T NE17 TN�.T I :G� `�`NW 9iNr57 d NW.•9TH T 'F� $ � '9 $T � L�,7� R�G �; "NW 8iF1 ST x Nw FrN s g - o g jr7 8 • i� .. «. ...r+ .. �rTH 57� F s;�R:�i�f� _ "75,.e, �. �.. Miami -Dade County Page I 1 EXHIBIT 1-2 PROPOSED WEST GROVE EXPANSION OF THE OMNI CRA — H2—� FLUVIA N 97 t M fi CANCIA Q _ --- YELARC�. !. IFT 49TH I� xx-; PEACOCK �y SHIPPING tilla SHIPPINGc s m v x v q SAN LOREN DAY U- � 6AY +� r1 f PERCIVAL PERCIVAL d y j G) PERCIVAL G7 £J OAK OAK j FROW fIT O FROW 0 —0)(-0 o FLORIDA rn z 'GRAND WASHINGTON r THOMAS o n c O WILLIAM T CHARLES m 0D CHARLES z z ��-'� KUMQUAT Source: City of Miami T I- ELS LL E- L0 THOMAS THOMAS ¢ a a � a WILLIAM m CHARLES FRANKLIN f •Tr�`i��l I �- I Page 12 Land uses in the area are predominantly Residential (66.9%) with a notable amount of Vacant Residential parcels (11.1%). Commercial/Industrial properties are represented by 6.7% of the total number of parcels. An inventory of the 1,828 parcels is provided in Table 1-1. TABLE 1-1 NUMBER OF LAND PARCELS IN WEST GROVE AREA Land Use Number of Parcels Commercial Condo 38 Commercial 71 Common Area/Park 2 Condominium 412 Duplex 145 Governmental 58 Industrial 13 Institutional 40 Multi Family 61 Parking 12 Reference 89 Single Family 605 Townhouse 20 Utilities 1 Vacant Commercial 54 Vacant Industrial 4 Vacant Land Condo 2 Vacant Residential - MF 12 Vacant Residential - SF Total 189 1,828 Source: Miami -Dade County Property Appraiser The population of West Grove is estimated at 5,284 in 2017. There are 2,554 dwelling units in the area. The entire City of Miami maintains a population of 444,777 within 205,175 dwelling units. Other facilities in the study area include: Parks • Elizabeth Virrick Park • Ambrister Park • Coconut Grove Mini Park AKA Billie Rolle Domino Park • Charlotte Jane Memorial Park (Cemetery) Page 13 Schools • Francis Tucker Elementary • St Albans Child Enrichment Center • Coconut Grove Montessori School • George Washington Carver High School Government Buildings • Miami Dade Human Services • Miami Dade Water and Sewer Facility • Miami Dade WASD offices • Coconut Grove Playhouse • US Postal Service • City of Miami Fire/Rescue Training Center 1.2 METHODOLOGY Consistent with State Law, the Finding of Necessity examines the character of the area and measures statistics and other documentation to determine if the conditions of slum and blight have been met, as described in Florida Statutes 163. Part III section 163.340 (7)(8). This analysis will examine each of the criteria and determine if the proposed area meets these conditions. The analysis of the conditions that exist in the proposed CRA area was conducted using data available from documented sources throughout the community. Agencies within the City of Miami and Miami -Dade County were contacted and data was supplied to examine the characteristics of the community. Additional research was conducted through field observations and photographic evidence to underscore the findings. Each of the criteria as established by State Law will be discussed separately and the data sources used for the analysis will be described in each section. 1.3 LEGAL REQUIREMENTS The requirements of the FON are established in Section 163.340 of the Florida Statutes and are described as follows: Slum Determination 163.340 (7) "Slum area" is defined as an area having physical or economic conditions conducive to disease, infant mortality, juvenile delinquency, poverty, or crime because there is a predominance of buildings or improvements, whether residential or nonresidential, which are impaired by reason Page 14 of dilapidation, deterioration, age, or obsolescence, and exhibiting one or more of the following factors: (a) Inadequate provision for ventilation, light, air, sanitation, or open spaces; (b) High density of population, compared to the population density of adjacent areas within the county or municipality; and overcrowding, as indicated by government -maintained statistics or other studies and the requirements of the Florida Building Code; or (c) The existence of conditions that endanger life or property by fire or other causes. Blight Determination 163.340 (8) "Blighted Area" is defined as an area in which there are a substantial number of deteriorated, or deteriorating structures, in which conditions, as indicated by government -maintained statistics or other studies, are leading to economic distress or endanger life or property, and in which two or more of the following factors are present: (a) Predominance of defective or inadequate street layout, parking facilities, roadways, bridges, or public transportation facilities; (b) Aggregate assessed values of real property in the area for ad valorem tax purposes have failed to show any appreciable increase over the 5 years prior to the finding of such conditions; (c) Faulty lot layout in relation to size, adequacy, accessibility, or usefulness; (d) Unsanitary or unsafe conditions; (e) Deterioration of site or other improvements; (f) Inadequate and outdated building density patterns; (g) Falling lease rates per square foot of office, commercial, or industrial space compared to the remainder of the county or municipality; (h) Tax or special assessment delinquency exceeding the fair value of the land; (i) Residential and commercial vacancy rates higher in the area than in the remainder of the county or municipality; 0) Incidence of crime in the area higher than in the remainder of the county or municipality; (k) Fire and emergency medical service calls to the area proportionately higher than in the remainder of the county or municipality; Page 15 (1) A greater number of violations of the Florida Building Code in the area than the number of violations recorded in the remainder of the county or municipality; (m) Diversity of ownership or defective or unusual conditions of title which prevent the free alienability of land within the deteriorated or hazardous area; or (n) Governmentally owned property with adverse environmental conditions caused by a public or private entity. Page 16 SECTION 2 SLUM CONDITIONS 2.1 ANALYSIS OF SLUM CONDITIONS The conditions that define "Slum" as outlined in Florida State Statues 163.340(7) in the potential CRA area are found in the following factors. In order for a proposed CRA area to qualify as having slum conditions, the area must have at least one of three factors. (a) Inadequate provision for ventilation, light, air, sanitation, or open spaces; The conditions of inadequate housing can be categorized through the determination of "Unsafe Structures" as determined by the Florida Building Code. Data collected from the City of Miami reveals that the proposed CRA expansion area has 32 "Unsafe Structures" designated within its borders. These citations cover the full range of conditions including inadequate ventilation, substandard housing and improper maintenance of the buildings. These 32 structures represent 2.2% of all structures in the district. City-wide, Miami has 1,328 cases of Unsafe Structures which represents .65% of the total number of structures in the City. The listing of Unsafe Structures is provided in Table 2-1 TABLE 2-1 LISTING OF UNSAFE STRUCTURES BY ADDRESS 3087 Ohio Street 3091 Plaza Street 3174 Elizabeth Street 3200 Thomas Avenue 3242 Charles Avenue 3341 Florida Avenue 3364 Grand Avenue 3375 Grand Avenue 3383 Thomas Avenue 3389 Charles Avenue 3400 Florida Avenue 3401 Grand Avenue 3410 Hibiscus Street 3412 Florida Avenue 3425 Jefferson Street 3432 Grand Avenue 3437 Elizabeth Street 3460 Florida Avenue 3490 Main Highway 3500 Main Highway 3506 Florida Avenue 3520 Grand Avenue 3574 William Avenue 3575 Thomas Avenue 3606 Thomas Avenue 3620 Thomas Avenue 3631 Thomas Avenue 3649 Thomas Avenue 3658 Thomas Avenue 3678 William Avenue 3758 Frow Avenue 3804 Florida Avenue Page 17 Examples of Unsafe Structures Exhibit 2-1, 3174 Elizabeth Street Exhibit 2-2, 3658 Thomas Street Exhibit 2-3, 3410 Hibiscus Street Exhibit 2-4, 3490 Main Highway Exhibit 2-5, 3412 Florida Avenue Exhibit 2-6, Coconut Grove Playhouse Page 18 (b) High density of population, compared to the population density of adjacent areas within the county or municipality; and overcrowding, as indicated by government - maintained statistics or other studies and the requirements of the Florida Building Code. Density patterns can be measured by the amount of developed acres of land or by the amount of population per square mile. The City of Miami covers approximately 35.87 square miles within its boundaries. Based on a population of 444,777, the density of persons per acre in the City of Miami is 19.37. For the potential CRA expansion area, the population of 5,284 lives within approximately 960 acres for a density of 5.50 persons per acre. (c) The existence of conditions that endanger life or property by fire or other causes. A review of the data from the City of Miami Fire Rescue Department reveals that in 2016, the proposed expansion area had a total of 2,117 calls for fire and emergency service. Based on the population of 5,284, this equates to 400.64 calls per one thousand population. For the entire service area of the City of Miami Fire Rescue during the same time, the population of 444,777 generated 100,583 calls for fire service, which is 226.14 calls per one thousand population. Page 19 EXHIBIT 2-1 DISTRIBUTION OF FIRE/RESCUE CALLS Fire Rescue Calls (208j • EMSCWls(1909) oar 0� FT dee Frnw as Lw•swrvs 0 0.125 0.25'..•••N 0.51% es 2.2 RESULTS OF ANALYSIS The proposed area meets criteria (a) and (c) of section 163.340(7) of the State Statutes. Page 110 SECTION 3 BLIGHT CONDITIONS 3.1 ANALYSIS OF BLIGHT CONDITIONS The requirements under State Statutes 163.340(8) for designation as "Blighted" note that the area must have a substantial number of deteriorated, or deteriorating structures, in which conditions, as indicated by government -maintained statistics or other studies, are leading to economic distress or endanger life or property. One method of illustrating "Blight" is through photographic evidence. Field observations were used to examine the area and photographs were taken of the conditions. Exhibits 3-1 through 3- 20 are a representative sample of the conditions in the area. Deteriorated Residential Exhibit 3-1 Exhibit 3-3 Exhibit 3-2 Exhibit 3-4 Page 111 Deteriorated Mixed Use Exhibit 3-5 Deteriorated Commercial Exhibit 3-6 Deteriorated Fences - Tp?Exhibit 3-7 Page 112 Deteriorated Drainage Mkkl Exhibit 3-8 Exhibit 3-9 Exhibit 3-10 Deteriorated Driveways Exhibit 3-11 Exhibit 3-12 Page 113 Exhibit 3-14 Deteriorated Roadways Exhibit 3-15 Exhibit 3-16 Deteriorated/Absent Sidewalks Exhibit 3-17 Exhibit 3-18 Page 114 Exhibit 3-19 Exhibit 3-20 3.2 Blight Criteria Analysis (Must meet 2 of the 14 items) Each of the 14 criteria will be examined in this section. (a) Predominance of defective or inadequate street layout, parking facilities, roadways, bridges, or public transportation facilities; For economic purposes, the street layout should enable customers to reach businesses easily and for trade among business to be conducted directly and efficiently. The most significant roadway is Dixie Highway which bisects the district. The diagonal nature of the road separates the commercial properties from the east and the west side of the Highway. EXHIBIT 3-21 DEPICTION OF DIXIE HIGHWAY Source: Google Maps Page 115 There are a number of streets in the district that provide inefficient layout and travel access through the area. An example is illustrated in Exhibit 3-22 which depicts the facts that many streets do not flow through the area. Examples are Day, Percival, Oak, Frow and Florida Avenues which a driver must make two 90 degree turns to travel down the street. EXHIBIT 3-22 AERIAL PHOTOGRAPH OF STREET LAYOUT Source: Google Maps Public Transit is provided through six Miami -Dade Transit System fixed routes that serve the area. In addition, the Miami Trolley and the Metrorail system also serve West Grove. The Route maps for the Transit systems are found in Appendix A. (b) Aggregate assessed values of real property in the area for ad valorem tax purposes have failed to show any appreciable increase over the 5 years prior to the finding of such conditions; Page 116 Data from the Miami -Dade County Property Appraiser's Office was obtained to examine the change in Taxable Value for the properties located in the proposed CRA area and compare them to the entire City's experience. TABLE 3-1 CHANGE IN TAXABLE VALUES - POTENTIAL CRA AREA AND CITY OF MIAMI Source: Miami -Dade County Property Appraiser Although the proposed expansion area has evidenced a significant amount of Taxable Value increase over the past five years, this growth is limited to a handful of properties. Several sites such as Modera (Apartment Building), Sheraton Hotel, Miami Green (Condominium Office) and Aviva (Apartment Building) have accounted for the vast majority of this growth. The rest of the West Grove area has lagged behind the overall growth in the City. (c) Faulty lot layout in relation to size, adequacy, accessibility, or usefulness; The conditions that generate faulty street layout would also contribute to a faulty lot layout. Most of the property is in a grid system with a standard lot layout. The diagonal feature of Dixie Highway does generate some odd shaped lots in the Industrial/Commercial Triangle in the northwest section of the district. The development of commercial properties has not been hindered by this layout. There is little connectivity between the areas east and west of Dixie Highway. The location of the Metrorail Station in this vicinity negates any issues created by this lack of connectivity. (d) Unsanitary or unsafe conditions; The City of Miami Building Code Division has determined that 32 buildings in the potential area are "Unsafe Structures" and have cited these properties for the condition of the buildings. Table 2-1 lists the properties designated as Unsafe Structures. Another environmental issue exists with the impacts from the closed City of Miami Incinerator property. The site has received remedial actions deigned to clean up the property and remove any hazardous materials. Existing facilities located on the site where the incinerator stood include Arbrister Park and the City of Miami Fire/Rescue Training Facility. A group of residents have filed a lawsuit against the City of Miami for negative health impacts that they attribute to the old facility. This lawsuit has recently been filed (September 27, 2017) and has not been resolved. Page 117 EXHIBIT 3-23 CITY OF MIAMI FIRE/RESCUE TRAINING FACILITY (e) Deterioration of site or other improvements; Listed in Table 3-2 are the necessary improvements to the infrastructure within the potential area boundaries. These improvements total approximately $19.6 million. TABLE 3-2 INFRASTRUCTURE IMPROVEMENT NEEDS (estimates) Item Quantity Unit CostTotal Install Sidewalk 31,402 SY $75 $ 2,355,150 Install Curb and Gutter 56,524 LF $35 $ 1,978,340 Install Drainage 29,762 LF $75 $ 2,232,150 Structures 200 EA $5,000 $ 1,000,000 Roadway Restoration 125,610 SY $60 $ 7,536,600 Design and Contingency 30% $ 4,530,672 TOTALIMPROVEMENTS Source: Florida Technical Consultants Page 118 (f) Inadequate and outdated building density patterns; Density patterns can be measured by the amount of developed acres of land or by the amount of population per square mile. The City of Miami covers approximately 35.87 square miles within its boundaries. Based on a population of 444,777, the density of persons per acre in the City of Miami is 19.37. For the potential CRA expansion area, the population of 5,284 lives within approximately 960 acres for a density of 5.50 persons per acre. (g) Falling lease rates per square foot of office, commercial, or industrial space compared to the remainder of the county or municipality; Lease rates have not been declining and are generally on a par with other similar areas of the City of Miami. Three data sources were used to determine the lease rates and the real estate activity in the area. These sources are: • Trulia.com • MLS • Loop.net Additionally, the information was verified through field investigation. (h) Tax or special assessment delinquency exceeding the fair value of the land; The Miami -Dade Tax Collectors Office is the source of the Tax Delinquency figures for all of Miami -Dade County including the potential area. Data representing the tax delinquencies for the past year were acquired and analyzed for this study. One of the questions regarding the designation of blight is if the area has property with tax delinquencies that exceed the fair value of the properties within the boundary. The analysis indicates that there are only a few delinquent tax files in the area. (i) Residential and commercial vacancy rates higher in the area than in the remainder of the county or municipality; Overall, there are relatively few vacancies in the potential area and these rates are not more extensive than through the remainder of Miami -Dade County. Three data sources were used to determine the vacancy rates and the Real Estate activity in the area. These sources are: • Trulia.com • MLS • Loop.net Additionally, the information was verified through field investigation. Page 119 0) Incidence of crime in the area higher than in the remainder of the county or municipality; Crime data was obtained from the City of Miami Police Department who maintains statistics for municipal boundary. Data from Part 1 and Part 2 crimes that encompass the potential CRA expansion as well as the entire City were obtained to determine the incidence of crime. For the past year, the total number of Emergency and Priority calls for the potential CRA area was derived from the posted statistics. To better compare these numbers, they were divided by the population to arrive at a per capital figure of calls per one thousand population. Table 3- 43provides the analysis. TABLE 3-3 POLICE CALLS PER CAPITA Source: City of Miami Police Department (k) Fire and emergency medical service calls to the area proportionately higher than in the remainder of the county or municipality; A review of the data from the City of Miami Fire Rescue Department reveals that in 2016, the proposed expansion area had a total of 2,117 calls for fire and emergency service. Based on the population of 5,284, this equates to 400.64 calls per one thousand population. For the entire service area of the City of Miami Fire/Rescue Department during the same time, the population of 444,777 generated 100,583 calls for fire service, which is 226.14 calls per one thousand population. (1) A greater number of violations of the Florida Building Code in the area than the number of violations recorded in the remainder of the county or municipality; The City of Miami Code Enforcement Division is responsible for overseeing the monitoring and enforcement of the Building Codes and other regulations regarding the use of property. Data for the past year was obtained and reviewed to assess the number of Code violations within the potential CRA expansion boundary and the total for the City of Miami. Table 3-4 lists the figures and analysis for the Code violations in the area. Exhibit 3-24 is a graphic representation of the number of violations in the area. Page 120 TABLE 3-4 CODE VIOLATION Source: City of Miami Code Enforcement EXHIBIT 3-24 ILLUSTRATION OF DISTRIBUTION OF CODE VIOLATIONS Source: City of Miami (m) Diversity of ownership or defective or unusual conditions of title which prevent the free alienability of land within the deteriorated or hazardous area, Currently there are 261 Vacant Parcels in the proposed district. Most of these properties are designated for Single Family Residential use. The ownership of these parcels is diverse and does not provide an apparent opportunity to assemble properties. Page 121 Y J • y Z • M • • r ' a r • •r • Y • •' :•r♦ r• • rr r r •r r ••. .' • • • y • y • •y M M r r# • r. yy • . r rty * � M • 1• . y . y i i• •• • • ♦ ` e • Source: City of Miami (m) Diversity of ownership or defective or unusual conditions of title which prevent the free alienability of land within the deteriorated or hazardous area, Currently there are 261 Vacant Parcels in the proposed district. Most of these properties are designated for Single Family Residential use. The ownership of these parcels is diverse and does not provide an apparent opportunity to assemble properties. Page 121 (n) Governmentally owned property with adverse environmental conditions caused by a public or private entity, An environmental issue exists with the impacts from the closed City of Miami Incinerator property. The site has received remedial actions deigned to clean up the property and remove any hazardous materials. Existing facilities located on the site where the incinerator stood include Arbrister Park and the City of Miami Fire/Rescue Training Facility. A group of residents have filed a lawsuit against the City of Miami for negative health impacts that they attribute to the old facility. This lawsuit has recently been filed (September 27, 2017) and has not been resolved. 3.3 RESULTS OF ANALYSIS The proposed area meets the following criteria of section 163.340(8) of the State Statutes. • Deteriorated Structures • Section a, Inadequate street layout • Section d, Unsanitary or unsafe conditions • Section e, Deterioration of site or other improvements • Section j, Incidence of crime in the area higher • Section k, Fire and emergency medical service calls to the area proportionately higher • Section 1, A greater number of violations of the Florida Building Code • Section m, Diversity of ownership or defective/unusual conditions of title • Section n, Governmentally owned property with adverse environmental conditions Page 122 SECTION 4 PUBLIC INPUT A Public Input meeting was held on Saturday October 7, 2017 at 8:00 AM at Greater St. Paul's AME Church in West Grove. The meeting was conducted as part of the regular Ministerial Alliance monthly community input session. A total of 56 persons attended the meeting and contributed to the discussion regarding the potential CRA and the needs of the community. The Consultant Team defined the process and discussed preliminary findings of the FON. A second session was held at the regular Homeowners and Tenants Association (HOATA) meeting on October 23, 2017 at 6:30 PM. The discussion also revolved around the process for expanding the OMNI CRA and the needs of the community. Page 123 SECTION 5 SUMMARY AND RECOMMENDATIONS 5.1 SUMMARY Sections 2 and 3 of this report identify the criteria for designation as "slum" and "blight" based on Florida Statutes. Each of the criteria was examined individually to assess the conditions and determine if the requirements under State law has been satisfied. Tables 5-1 and 5-2 the criteria for slum and blight found in the potential area. TABLE 5-1 SLUM CRITERIA (a) Inadequate provision for ventilation, light, air, sanitation, or Meets criteria open saces b High density of population Does not meet criteria (c) The existence of conditions that endanger life or property Meets criteria by fire or other causes TABLE 5-2 BLIGHT CRITERIA Page 124 DescriptionCriteria ed Strictures 9W" a Predominance of defective or inadequate street layout Meets criteria Meets criteria (b) Assessed values of real property in the area have failed to show any appreciable increase Does not meet criteria c Faulty lot layout Does not meet criteria (d) Unsanitary or unsafe conditions - Meets criteria e Deterioration of site or other improvements Meets criteria Inadequate and outdated building density patterns Does not meet criteria (g) Falling lease rates per square foot of office, commercial, or industrials ace Does not meet criteria (h) Tax or special assessment delinquency exceeding the fair value of the land Does not meet criteria (i) Residential and commercial vacancy rates higher in the area than in the remainder of the City Does not meet criteria Incidence of crime in the area higher Meets criteria (k) Fire and emergency medical service calls to the area proportionately higher Meets criteria 1 A greater number of violations of the Florida Building Code Meets criteria (m) Diversity of ownership or defective/unusual conditions of title Meets criteria (n) Governmentally owned property with adverse environmental conditions Meets criteria Page 124 This summary notes that the potential area meets two of the three of the "Slum" criteria and 8 of the 14 specific "Blight" criteria. In addition, the potential area has a substantial number of deteriorated structures as evidenced by Exhibits 2-1 through 2-6, and 3-1 through 3-20. 5.2 RECOMMENDATIONS The potential CRA expansion area of West Grove meets the criteria established under State Statutes to be designated as "slum" and "blight". The area meets two of the three of the criteria to be designated as slum (one is required), and eight of the criteria to be designated as "blight" (only two are required). The area also meets the "blight" requirement of existence of deteriorated structures. It is recommended that the City Commission approve the Finding of Necessity for the OMNI CRA expansion to include West Grove, as expressed in Exhibit 1-2. 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