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HomeMy WebLinkAboutSubmittal-David Winker-PowerPoint Presentation on StandingSubmitted into the public record for item(s) PZ.6 and PZ.7, on 05-27-2021, City Clerk Intervenors Meet Legal Standard for Intervention DAVID J. WINKER., P.A. 3058018700 dwinker@dwrlc.com 7226 7232 'Submittal -David Winker-PowerPoint Presentation on Standing Submitted into the public record for item(s) PZ.6 and PZ.7, on 05-27-2021, City Clerk What is the Issue? Comprehensive plan/Future Land Use Map amendments that will result in transforming residential lots at 3227, 324711 3257, and 3277 Charles Avenue and 3256 and 3270 William Avenue in the West Grove into commercial development Submitted into the public record for item(s) PZ.6 and PZ.7, on 05-27-2021, City Clerk Who wants to Intervene? Residents who live within 500 ft of the subject property AERIAL Submitted into the public record for item(s) PZ.6 and PZ.7, ePlan ID- PZ-18-337 on 05-27-2021, City Clerk COMPREHENSIVE PLANNING AMENDMENT fN AND 3256 AND 3270 WILLIAM AV • Signed opposition �1 Stirrup owned 0 125 250 500 Feet 0 Non residential Subject Property Developer managed MIAMI 21 §7.1.4.3(e) Intervenor shall whose interests in the Submitted into the public record for item(s) PZ.6 and PZ.7, on 05-27-2021, City Clerk mean a person proceeding are adversely affected in a manner greater than those of the general public. Submitted into the public record for item(s) PZ.6 and PZ.7, on 05-27-2021, City Clerk Cityof Miamiguidance The City of Miami itself has "previously opined that an `aggrieved party' for standing in zoning matters was a resident that lived within 500 feet of the property" to challenge the proposed zoning action." Miami -Dade County v City of Miami, No. 18- 000032-AP-01 (Fla. Cir. Ct., Dec. 3, 2018). adverse affects greater Submitted into the public record for items PZ,6 and PZ,7 pubi i than eneralcon 05-27-2021, City Clerk g • noise • traffic near intervenor-s homes due to the influx of more cars coming in and out of the property for construction and then hotel use • parking pressure on Charles and William Ave • traffic safety • increased tailpipe emissions due to traffic congestion and waiting cars affecting air quality adverse affects greater Submitted into the public record for item(s) PZ.6 and PZ.7, public than eneral on 05-27-2021, City Clerk g • diminution of value • hotel changes character of neighborhood • depletion of affordable housing options in the neighborhood • displacement of neighbors due to the failure of the Applicant to bring the project into consistency with the housing -related goals and objectives of the Miami Comprehensive Neighborhood Plan Submitted into the public record for adverse affects gre a to r on 05-27-2021,(City C erkitems) PZ.6d PZ than general public • increase in water displacement and flooding, as permeable land is paved over/covered with impermeable structures • reduction in tree canopy • decreased walkability Pichette v. City of North Miami, 643 So. 2d 1165, 1166 (Fla. 3d DCA 1994); and Carlos Estates, Inc. v. Dade Cty., 426 So. 2d 1167, 1169 (Fla. 3d DCA 1983). Submitted into the public record for item(s) PZ.6 and PZ.7, on 05-27-2021, City Clerk Interest thangeneralpublic Intervenors live next door to Subject Property and the negative effects are specific to the Intervenors and are "greater than the general interest in community well being." Florida Rock Prop. v. Keyser, 709 So. 2d at 177.