HomeMy WebLinkAboutSubmittal-Public Comments Submitted Online for the May 25, 2023 City Commission MeetingCity of Miami Commission Report -Public Comments for
May 25, 2023
Public Comment for May 25, 2023, Regular City Commission Meeting
May 25, 2023 2:57 PM MDT
Public Comment
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Abig Rem 114 PZ. May 25, 2023 Re: PZ.2 (12858) Dear City of Miami Commission, The People's Economic and
ail ing NW 2 Environmental Resiliency (P.E.E.R.) Group advocates for economic and environmental sustainabitity in
25th #128 Miami through a community Lawyering approach that shifts power back to marginalized communities. We
Stre 58 partner and work side- by -side with community groups to advocate for our vision of justice, which
et, Land recognizes the need for structural and systemic change that empowers vulnerable populations, provides
Mia Use equitable access to benefits, and advances restorative protection from harm. We write to you today to
mi - object to PZ.2 (Fite ID 12858). I. WE NEED CORRECTIVE ACTION IN MIAMI. Over the Last decade,
FL Vario Greater Miami has experienced exponential growth in its population and real-estate development. This
3312 us - growth is attributable to a myriad of factors including, but not Limited to, an influx of foreign investors; a
7 Little form -based planning and zoning code which favors high -density, mixed -use developments; and an
Bah emerging trend favoring transit -oriented development and walkable communities. These trends exacerbate
ama the gentrification of Low-income communities and, as a result, displace vulnerable communities. We know
s of that the need for proactive and corrective action in Miami is particularly acute. Miami now has the most
Coc expensive housing market in the country with over 85% of median income going towards homeownership
onut costs for the average city resident. In fact, 6 in 10 employed adult residents are housing cost -burdened,
Grov spending more than 30% of their incomes on housing. Cost -burdened households are incredibly
e susceptible to population displacement based on minor variations in the market price for rent. More
specialty, in the West Grove, "decades -Long disinvestment and disenfranchisement have resulted in the
reduction of its housing stock, the degradation of its character, and the displacement of its community."
We know that access to stable housing disrupts the vicious cycle of poverty and mitigates vulnerability to
natural disasters, making Low-income communities more resilient in the face of socioeconomic and
environmental challenges. As the woad continues to face the interconnected crises of the COVID-19
pandemic, climate change, and Large-scale wealth inequality, the City of Miami has an opportunity to set a
global example by adopting and implementing innovative solutions to housing challenges that foster true
stability for aLL. We have an opportunity now to do better and write a different story. II. DISPLACEMENT
VULNERABILITY AND MITIGATION TOOL The threat of displacement can be addressed by providing for
meaningful participation in project development and approvals and by implementing anti -displacement
strategies to protect historically disenfranchised communities. Thus, alongside community partners, the
Environmental Justice Clinic ("EJC") at the University of Miami School of Law developed the Displacement
Vulnerability and Mitigation TooL (" DVMT" or "Tool."). The TooL aims to forecast the risk of displacement that
a proposed development will Likely cause and to equip community stakeholders —including real-estate
developers, municipalities, and Local communities —with research -informed strategies to mitigate potential
displacement. Part I of the DVMT utilizes mapping analysis software to aggregate data on the surrounding
community and of a proposed development, capturing both a visual and numerical snapshot of the
existing community composition. The demographic data is sourced via the American Community Survey,
Miami -Dade GIS Data Hubs, and the USGS, and includes community -specific population data and
community environmental data so that the TooL can accurately map the Link between development and
displacement. In Part II, an automated code analyzes this data using statistically based calculations of
each population's susceptibility indicators to determine a community's vulnerability to displacement. Based
on this vulnerability analysis, Part III identifies mitigation efforts that stakeholders can employ to address
the potential displacement. For this comment, PEER Group partnered with the EJC to run an analysis on
the proposed development for PZ.2 (Fite ID 12858). Our findings are below. III. DVMT ANALYSIS West
Coconut Grove is a historic Afro -Caribbean and African -American community, originally inhabited by
Bahamian settlers. The West Grove's proximity to Downtown Miami and its central Location between the
highly desirable East Coconut Grove and Coral Gables has Led to rapid gentrification in recent years. In
Part I of the TooL, we aggregate specific Census Tract Level data regarding the existing property upon
which the new development is being proposed, the neighboring community and the anticipated property
uses. For the proposed development in this case, Census Tract 00720 was selected. For the Census Tract,
14070-Submittal-Public Comments Submitted Online for the May 25, 2023 City Commission Meeting
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data shows that 72% of the population is Black, the Median Household Income is $43,696, which is well
below the Area Median Income for Miami -Dade County, and the majority of residents are renters.
Additionally, over 25% of households fall below the poverty level. The proposed development is 9 feet
above sea Level and the area has been designated a "Minimal Flood Hazard" area by the United States
Federal Emergency Management Agency. Based on the data, in Part II, we analyze the data to assess a
populations susceptibility to displacement. The DVMT reties on a variety of indicators to assess a
populations susceptibility (age, race, education, income, infrastructure, environment, etc.). This analysis
produces a final susceptibility score that is then placed on a four -tier susceptibility spectrum: very
susceptible, susceptible, moderately susceptible, and Least susceptible. Calculations are based on a
statistically -based assessment using the normal distribution curve. Normal distribution approximates many
natural phenomena and is an excellent reference for probability problems such as the DVMT. Using these
measurements, we were able to understand how each susceptibility factor translates into calculating the
total percentage vulnerability of a population. The demographic characteristics were based on a scale of 0-
8 'points' using the percentages of normal distribution statistics. This project scored a 57% which denotes
a community that is "susceptible" to displacement. In Part III, based on the susceptibility, the DVMT
provides mitigation strategies. Because the West Grove community has already experienced gentrification
and displacement, it is especially important that protections are in place for remaining residents.
Therefore, it would be advisable that the community negotiate various mitigation strategies; for example,
the construction of one-to-one affordable housing on -site or one -to -three affordable housing construction.
The rapid development that the West Grove has already experienced is Likely to transform the nature and
fabric of the community and will Likely price out existing residents. Thus, investments into Pathways to
Homeownership Funds could allow displaced residents to become homeowners in other more affordable
communities. In addition, the community may negotiate that a certain number of construction and
development full- time employment opportunities are secured for the existing community residents. IV.
OPPOSITION TO ORDINANCE The Commission should vote no on PZ.2 (Fite ID 12858). Specifically, Fite
ID 12858's proposed rezoning of Assemblage A that wilt result in unnecessary Loss of housing
opportunities in the West Grove. Currently, five of the seven Lots in Assemblage A are zoned as residential.
Fite ID 12858 proposes that these five residential Lots be rezoned to commercial. A commercial Lot would
directly conflict with the Low -density residential nature of the neighborhood. Further, as shown by the
above analysis, the West Grove neighborhood is susceptible to displacement, thus taking away potential
housing opportunities wilt surely have adverse effects. It is vital to the Long-term residents of the West
Grove that these Lots remain residential. These Lots should be used to mitigate already existing housing
shortages instead of creating further housing disparities. The best use of the Lots between Washington and
Thomas Avenue is affordable housing. The recent West Grove Affordable Housing Blueprint authored by
PLusurbia Design sums up what the Commission should do - "Stop approval of developer requests to
change Land use from residential to commercial, in other words, keep residential Land residential." Here,
we have an opportunity to add affordable housing to a community that desperately needs it. This
opportunity is completely Lost if PZ.2 (Fite ID 12858) is approved in current form. Thank you for the
opportunity to comment. Sincerely, Abigail Fleming, Esq. Staff Attorney P.E.E.R. Group 678-602-0509
End of Report