HomeMy WebLinkAboutSubmittal-David Winker-PowerPoint Presentation on StandingSubmitted into the public
record for item(s) PZ.6 and PZ.7,
Intervenors Meet Legal
on 05-27-2021, City Clerk
Standard 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, 32471 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
N ADDRESSES: 3227, 3247, 3257, AND 3277 CHARLES AV
AND 3256AND 3270 WILLIAM AV
Signed opposition
iStirrup owned
0 125 250 500 Feet
i 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 Mguidance
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.
000032-AP-01 (Fla. Cir. Ct., Dec. 3, 2018)6
adverse Submitted into the public
record for item(s) PZ.6 and PZ.7,
thangeneralpublic
on 05-27-2021, City Clerk
• 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
than general public
• diminution of value
• hotel changes character of neighborhood
Submitted into the public
record for item(s) PZ.6 and PZ.7,
on 05-27-2021, City Clerk
• 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
housing -related goals and objectives of the Miami
Comprehensive Neighborhood Plan
the
Submitted into the public
r f f r r on 05-27-2021,(City Cerk d PZ 7,
adve se a ects eatefor items) PZ.6
g
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.
(Fla. 3d DCA 1994); and Carlos Estates, h
Cty., 426 So. 2d 1167, 1169 (Fla. 3d DCA
2d 11651P 1166
ic. v. Dade
1983).
Submitted into the public
record for item(s) PZ.6 and PZ.7,
on 05-27-2021, City Clerk
Interest greater than enera u is
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.