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HomeMy WebLinkAboutSubmittal Miami neighborhood UnitedWA Policy LU -1.1.7: Land development regulations and policies will allow for the provision of adequate neighborhood shopping, recreation, day care, entertainment, and other neighborhood oriented support activities. Policy LU -1.1.8: The City's Planning Department will be responsible for coordinating the City's land development regulations and policies with those of Miami -Dade County and adjacent municipalities. Policy LU -1.1.9: The City will maintain low to moderate density uses in the West Flagami area of the city (as shown on Figure 111.1 of Volume II — Data and Analysis of the MCNP) as necessary to protect the secondary aquifer recharge area. (See Natural Groundwater Aquifer Recharge Policy AR -1.2.1.) Policy LU -1.1.10: The City's land development regulations will encourage high-density residential development and redevelopment in close proximity to Metrorail and Metromover stations, consistent with the Station Area Design and Development Plan for each station. (See Transportation Policy TR -1.5.2 and Housing Policy HO -1.1.9.) Objective LU -1.2: Promote the redevelopment and revitalization of blighted, declining or threatened residential, commercial and industrial areas. Policy LU -1.2.1: The City defines blighted neighborhoods as areas characterized by the prevalence of older structures with major deficiencies and deterioration, high residential vacancies, widespread abandonment of property, litter and poor Miami Comprehensive Neighborhood Plan Goals Objectives Policies June 2006 Policy LU -1.1.11: The City hereby adopts designation of the City, excluding Virginia Key, Watson Island and the uninhabited islands of Biscayne Bay that have a land use UJ and zoning classification of Conservation, as shown on "Attachment A," as an Urban �Infill Area pursuant to Miami -Dade County's designation of an Urban Infill Area lying Q generally east of the Palmetto Expressway and including all of the City of Miami. �—' U_ Within this area, the concentration and intensification of development around centers O ® of activity shall be emphasized with the goals of enhancing the livability of residential �9 neighborhoods and the viability of commercial areas. Priority will be given to infill Odevelopment on vacant parcels, adaptive reuse of underutilized land and structures, ® and the redevelopment of substandard sites. Maintenance of transportation levels of ® service within this designated Urban Infill Transportation Concurrency Exception Area shall be in accordance with the adopted Transportation Corridors level of service F- standards set forth in Policies TR -1.1.2 and 1.1.3 of the Transportation Element of the �--- C � MCNP. co Policy LU -1.1.12: In order to encourage the development and maintenance of � educational facilities in the City of Miami, the City's Land Use policies permit schools in F— GO CL all land use classifications except Conservation, Restricted Parks and Recreation, and Industrial. During pre -development program planning and site selection activities, the City shall coordinate with Miarni-Dade Public Schools and continue to seek, where feasible and mutually acceptable, to co -locate schools with other facilities such as parks, libraries, and community centers to the extent possible. Objective LU -1.2: Promote the redevelopment and revitalization of blighted, declining or threatened residential, commercial and industrial areas. Policy LU -1.2.1: The City defines blighted neighborhoods as areas characterized by the prevalence of older structures with major deficiencies and deterioration, high residential vacancies, widespread abandonment of property, litter and poor Miami Comprehensive Neighborhood Plan Goals Objectives Policies June 2006 Statutes & Constitution :View Statut... Smshine t Page 1 of 4 SUBMITTED INTO THE PUBLIC RECORD FOR SelecE Year: 2006 ITEM p_? �ONJ,_gjo-, . The 2��G Florida Statutes Title XI Chapter 163 View Entire COUNTY ORGANIZATION AND INTERGOVERNMENTAL INTERGOVERNMENTAL Chapter RELATIONS PROGRAMS 163.2517 Designation of urban infill and redevelopment area. -- (1) A local government may designate a geographic area or areas within its jurisdiction as an urban infill and redevelopment area for the purpose of targeting economic development, job creation, housing, transportation, crime prevention, neighborhood revitalization and preservation, and land use incentives to encourage urban infill and redevelopment within the urban core. (2)(a) As part of the preparation and implementation of an urban infill and redevelopment plan, a collaborative and holistic community participation process must be implemented to include each neighborhood within the area targeted for designation as an urban infill and redevelopment area. The objective of the community participation process is to encourage communities within the proposed urban Will and redevelopment area to participate in the design and implementation of the plan, including a 'visioning' of the urban core, before redevelopment. (b)1. A neighborhood participation process must be developed to provide for the ongoing involvement of stakeholder groups including, but not limited to, community-based organizations, neighborhood associations, financial institutions, faith organizations, housing authorities, financial institutions, existing businesses, businesses interested in operating in the community, schools, and neighborhood residents, in preparing and implementing the urban infill and redevelopment plan. 2. The neighborhood participation process must include a governance structure whereby the local government shares decisionmaking authority for developing and implementing the urban infill and redevelopment plan with communitywide representatives. For example, the local government and community representatives could organize a corporation under s. 501(c)(3) of the Internal Revenue Code to implement specific redevelopment projects. (3) A local government seeking to designate a geographic area within its jurisdiction as an urban Will and redevelopment area shall prepare a plan that describes the infill and redevelopment objectives of the local government within the proposed area. In lieu of preparing a new plan, the local government may demonstrate that an existing plan or combination of plans associated with a community redevelopment area, Florida Main Street program, Front Porch Florida Community, sustainable community, enterprise zone, or neighborhood improvement district includes the factors Listed in paragraphs (a) -(n), including a collaborative and holistic community participation process, or amend such existing plans to include these factors. The plan shall demonstrate the local government and community's commitment to comprehensively address the urban problems within the urban infill and redevelopment area and identify activities and programs to accomplish locally identified goals such as code enforcement; improved educational opportunities; reduction in crime; neighborhood revitalization and preservation; provision of infrastructure needs, including mass transit and multimodal linkages; and mixed-use planning to promote multifunctional redevelopment to improve both the residential and commercial quality of life in the area. The plan shall also: (a) Contain a map depicting the geographic area or areas to be included within the designation. http://www.leg.state.fl.us/Statutes/in... 4/12/2007 Miami Neighborhoods United June 14, 2006 Mayor Manuel Diaz Commissioner Johnny Winton, Miami 21 Chair Ms. Elizabeth Plater-Zyberk, DPZ Dear Mayor, Comm. Winton, and Ms. Plater-Zyberk, '#Z SUBMITTED INTO THE PUBLIC RECORD FOR ITEMpz..?- ON&),-'t-tJ0-1. Regarding MIAMI 21, Miami Neighborhoods United has two areas of Major Concern. Both concerns require expanding the schedule of public participation in the MIAMI 21 process to include the other three quadrants for selected portions of the Project, NOW. I. MIAMI 21 is addressing: A.) East Quadrant Specific Changes and B.) Generic Changes and Methodology Changes to the Zoning Ordinance and other Ordinances. The Generic Changes and Methodology Changes are going to have impact city-wide. Once approved for the first Quadrant, they will not be materially changed by planned work in the remaining quadrants of the City. We are referring to the following types of changes: Generic Changes Consolidated Uses Definitions Building Functional Uses by Transect Transect Zoning Category Regulations Massing Studies T -Zone Development capacity Transitions Between T -Zones Methodology Changes Public Input Processes, including: Administrative Procedures Transect Building Functional Uses Future Adjustments to T -Zones, generic Future Adjustments to T -Zones, location specific MNU strongly requests that these generic and methodology changes be presented to the remaining quadrants for public discussion and comment at this time — BEFORE any proposals proceed to the Planning Advisory Board. The initial proposals are receiving feedback currently from the First Quadrant, causing re- considerations and several adjustments. Having made those adjustments, the revised proposals must be re -presented to the East Quadrant and the generic and methodology changes must also be presented to citizens and professionals in the other three quadrants for their input and additional potential improvements. To proceed without the participation of the other Quadrants is totally inappropriate. H. DPZ has made clear that there will be changes to several other Articles, such as Article 9. Changes to these other Articles have not been presented to the public. MNU assumes that there will also be major amendments to the Miami Comprehensive Neighborhood Plan (MCNP). Drafts of necessary amendments have not been made available either. The current schedule does not contemplate the distribution and public participation/discussion concerning the many issues to be raised by the changes to the other Articles and the MCNP. In conclusion, the schedule must be modified to provide for City-wide public participation in these changes. These generic or methodology changes, other article changes and the MCNP amendments must be discussed with and have input from the other three Quadrants. We trust that you will take appropriate action to provide for and encourage public input city- wide and with reasonable time -frame, given the complexity of these issues. Sincerely, Hadley C. Williams SUBMITTED INTO THE President PUBLIC RECORD FOR cc: City Commissioners ITEMpz_�-Department of Community Affairs ® ce >S 0 - Press Contacts fit of AMallit, June 29, 2000 Mr. 14adley Williams. President .Miami Neighborhcvds United '1441 Trapp Avenue Miami, FL 33133 Dear Mr, Wi I I i ams* KA ")NNI(nA SUBMITTED INTO THE PUBLIC- RECORD FOR ITEMPz> ON � ae o� Thank you for your letter dated June 14. 2006 expressing your concerns about Miami 27 1. The Miami? I process is unprecedented where all stakeholders, regardless of quadrant location, are able to submitcomments, questions, and input through to website completely dedicated to thisas a C d project. The website enjoy over.5.00 daily visits h n, S w re over 225 questions, has recorded over 120 comments, and has received over 101) "find your quadrant" inquiries, This is in addition to the numerous telephone calls directed to the Wami� 21 hothricand walk-ins gTeeted by the Planning Departme t.- Overall. Miami 21 2. has received more feedbackand public participation than any other project of th is magnitude. The: ffvdback received has not been exclusive to the East Quadrant, In addition. Miami 211 has -received extensive media coN,-cra W, anddiscussions at difficrent public hearings, which provides a general awareness to all City residents. Public meetings have been extremely well attended, again not only by Last Quadrant residents, as the interest for _'Viami 21 is citywide anti not quadrant specific. The City ot'Miaini welcomes everyone to submit their input liar generic and methodology changes, however. the East Quadrant remains the principal target as this area is being directly affected by the current studies and proposals. Please keep in mind, that in addition to the abwve-mentioried efforts, the final phase of Miami 21 is intended:to finalize the regulations after all four quadrants have been completed. P1 A V,4 1 N(; OD 100,1ENT, jj�:'. VV j!0 1fd 1"'ocal 'Mow, I i Miami Neighborhoods l3nited letter Pages 2 We will hold additional public meetings in the next few months to present additional material that is currently being developed, where everyone is welcome to participate. Dates have not yet been scheduled. We count an Miami Neighborhoods United, an organization inclusive ofmany neighborhood organizations, to continue to disscminate nfun-nation to their members and Irick forward to your continued participation and support AGS.l lg. 4ca !Mayor Manuel A. Liar Miami 2t file SUBMITTED INTO THE PUBLIC RECORD FOR ITEWz.,,)- ON 6 0, . DUANY PLATER-ZVRERK & COMPANY AKCWTECTS AND TOWN PLANNERS June 29, 2006 Mr. Hadley Williams President Miami, Neighborhoods United 2441 Trapp Avenue Miami, FL 33133 Dear Mr. Williams: SUBMITTED INTO THE PUBLIC RECORD FOR ITEM a ONv of . We appreciate your involvement and the specific concern expressed in your lefter of June 14. As the d"uments evolve for the East Quadrant we are adjusting the schedule to, be as thorough as possible. Also, we will adjust all parts of the documents as needed as we progress through the remaining quadrants. Your statement in paragraph one: .."tvill not be materially changed by planned work in the remaining quadrants of the City," is not true. I hope this allays your concern on this matter. The final phase of Miami 21 is intended to finahzc the regulations after all four quadrants have been completed. Sincerely, 'WT,a� P-10VA Elizabeth Plater-Zyberk M I AM I W A'.04 I N 6 T ON C H P, V L 0 TT U 102.3 5c4ahwcsi 21th Avenuc Miami, Flo da 33135 lct: 005,1644-1423 Fay. (305) 644:1021 WWW Ap.com ,-T Planning Advisory Board Meeting — April 4, 2007 The following statements were made during presentations and discussions with the PAB: 1. Lourdes Slazyk, referring to the Miami 21 Code: "The structure is done already. The other quadrants are only the map ...." 2. Ana Gelabert-Sanchez, referring to what will happen in the remaining quadrants: "The Code will be the same." SUBMITTED INTO THE PUBLIC RECORD FOR ITEM ez_a ON & as 161 . EAST QUADRANT DRAFT IN PROGRESS EXISTING CODE mcw rnnc CODE DEVELOPABLE CAPACITY TABLES DEVELOPMENT CAPACITY CONSOLIDATION TABLE SUMMARY LEGEND FLR ■ Floor Lot Ratio AOR = As of Right GFA = Groaa Floor Area PB = Public Benefit DEV = Development UL a Unlimited B.13 SUBMITTED INTO THE PUBLIC RECORD FOR ITEM P2_a ON G ae o, . Wdeloa Oala: 0731.06 <:; DUANY PLATER•ZYBERK & COMPANY /3$ Z?1 J4 .V2 WWM Lim Miami Neighborhoods United Miami 21- Items of Concern May 18, 2007 Miami Neighborhoods United proposes that many major modifications be made to the Miami 21 Project. All of the Items of Concern have been raised in prior public meetings with Duany Plater-Zyberk or the City Commission. I. Authority Issues. Does the City Commission have authority to approve Miami 21, or must a `shared decision making authority' per FL 163.2517(2) approve? The whole City of Miami is declared an Urban Infill Area in the Miami Comprehensive Neighborhood Plan (MCNP), Policy LU - 1.1.11, which has been the justification for the whole City being designated, improperly, as a transportation concurrency exception area. Clearly Miami 21 is an urban infill and redevelopment plan. II. Comprehensive Plan Issues. 2. The city is currently over -zoned, causing much of the `out of context' development and prohibiting a rational geographic focus of infrastructure investments. Estimated `built -out' population of current zoning is over two million inhabitants (or approximately six times the current population of the City). Miami 21 is a 50 year or longer-term plan. It is fine to have that long range plan, but the City needs a 7 Year Plan with a Future Land Use Map and zoning which are consistent with its ability to fund infrastructure for incremental density and consistent with needs for water management, sewage, affordable housing, transportation, parking, schools, and public safety. A 15 Year Plan consistent with a "long term concurrency management system" per FS 163.3177(2) would also be appropriate. The City must make detailed estimates of the maximum population density under the current zoning, population projections for 7 years and 15 years, and plan accordingly in Miami 21. This will possibly entail considerable down -zoning. This requirement is clarified in HB7203-03-e3, 163.3177(3)(d) and (e). Please see MNU's estimated maximum population calculations in the Appendixes. 3. Although the Miami 21 proposed Code has received public input from the East Quadrant only, both DPZ and the City Planning Department have stated publicly at PAB meetings that "the Code is finished" and only the Miami 21 Atlas has to be prepared for the remaining Quadrants. There are two major problems with this: A. Citizens of the three other quadrants have not participated actively (nor been invited to do so in focus or other small group or neighborhood gatherings) in the public process to develop the proposed Code, in violation of FS 163; SUBMITTED INTO THE PUBLIC RECORD FOR ITEM nz_a ON 6-�-o�. B. Citizens and neighborhoods in the remaining three quadrants are concerned about what will be happening with development in their quadrants while the Atlas for their respective areas are being prepared. MNU insists that: A. the Code not be approved until there has been extensive public input from the citizens of the other three quadrants and the Code be approved and implemented for all four quadrants simultaneously. B. If the Code is approved for the East Quadrant as proposed, it should ALSO be applied to the other three quadrants as follows: all permits applied for in those quadrants in which the Miami 21 Code has not been implemented will have to conform to the more restrictive of Ordinance 11,000 or the Miami 21 Code (using the Old to New Conversion charts from Miami 21). Any conflicts will be resolved through a request for Variance under 11000. 4. Our analysis indicates that the so-called `conversion' of current zoning does not result in similar developed square footage, rather substantial increases in square footage result. The `conversion' is greatly complicated by the current Gross Lot Area. Even if the current units per acre density limits in the current Comprehensive Plan are maintained, the huge increase of square footage in commercial, office, and other non-residential space will mean an even greater increase of necessary infrastructure — with no known means of financing. Reversion to the Net Lot Area, exercising the policing powers of the City, would help solve the over - zoning problem. DPZ originally was going to start with a the structures in existence `on the ground' (instead of the current zoning) and were going to use Net Lot Area. Miami 21 should be revised to follow these original guidelines. See FS 163.3177. 5. Our analysis also indicates that the `conversion' is greatly complicated by using the current Gross Lot Area as the basis. Significant inequities, originally created in 1985 when Gross Lot Area calculations replaced Net Lot Area calculations, will be exacerbated further, with buildable areas again increasing or decreasing (relatively) depending on new `averages' - originally caused by frontage of roads, water, open space, etc. MNU believes strongly that reversion to the Net Lot Area would cure many of the problems of inequity being compounded with the proposed `conversion' and is the simplest methodology, used throughout the rest of the United States. 6. Provisions to protect the neighborhoods per the Miami Comprehensive Neighborhood Plan (MCNP) and in Code Sections 1305 are going to be effectively eliminated (and technically deleted with 11000). Their future application is immaterial given the Atlas and design principles codified in Miami 21. This is not acceptable. These protections must be on-going and the public must have continuous input to make corrections. Please see MNU proposed amendments (prepared by Barbara Bisno). 7. The Transportation Plan (including proposed parking facilities essential for overflow of reduced parking in mixed use developments) has no details as to implementation or financing (required per FS339.175(6). How can Miami 21 b critical details? SUNIOMOsINTO THE PUBLIC RECORD FOR ITEM n.,ri ONG-dq-p�. 8. Miami 21 continues to rely on the prior declaration of the whole City as a "transportation concurrency exception area" in violation of FS 163.2517(1), (3), and (3)(i). FS 163.3180 includes requirements relating to "transportation concurrency management areas" and designation of exception areas. The City must include detailed designations with supporting data as part of the EAR Amendments. There is no evidence that Miami 21 looks forward to those requirements effectively. 9. There are no Impact Fees included for non-residential development and the recently approved Impact Fees for residential development will not begin to provide for the cost of incremental infrastructure required. Impact Fees for local parks must be implemented also. See FS 163.3180(2)(b). 10. Affordable and Workforce Housing are a major issues for the City and are not addressed explicitly as part of the Miami 21 Plan. There should be specific measures to require the development of Affordable and Workforce Housing as integral components of Miami 21. The impact fees and bonuses which are related to Affordable and Workforce Housing are grossly insufficient and the bonuses allowed in the higher density T -Zones of the East Quadrant are not necessary for the economics of new developments in those areas. See 163.2517(3). 11. Height limitations in use and accepted as fundamental to maintain the integrity of residential neighborhoods are being violated. III. Process Issues. 12. There appears to be a lack of formal inter -governmental reviews or approvals of Miami 21. No evidence has been presented that the South Floida Water Management District, FEMA (evacuations, safety), Fire, MPO, , M -D transportation, FDOT, M -D School District or other governmental agencies have reviewed and accepted/approved the proposed Plan. 13. The proposed approval process for new development removes appropriate Notice provisions and effective public input (see MNU amendments prepared by Barbara Bisno). The proposed PAZB(?) has a minority component representing the public or neighborhoods. There are no `Checks and Balances" in this system. If the Miami 21 design goals are working, there will be little interference by the public. 14. The formal review procedure for Miami 21 itself, to make adjustments to the Plan as problems arise with the actual implementation, does not provide for changes initiated by the public or a group of citizens, nor does it provide for changes to the Code. These are imperative and public input in the review process must be guaranteed. The City Charter should also be modified to provide for initiation of MCNP and ordinance changes by the public or a group of citizens. SUBMITTED INTO THE PUBLIC RECORD FOR ITEM ON o 15. The Miami 21 Plan continues to change, based on postings to the Miami2 Lorg website. There has been insufficient time and notice for the public to be made aware, analyze and comment on the on-going changes. IV. Land Development Regulation Issues. 16. Use of the terminology "As of Right" and "Allowed by Right" give the appearance of bestowing `vested rights' or economic value on property, possibly decreasing the policing powers of the City to downzone and possibly affecting the value of a property in a future `taking' by the City for public benefit. This also contradicts the language of 2301. Please suggest other terms. 17. The Miami 21 code over -simplifies the requirements of our City in a variety of ways. Conversion of the Gross Area allowances (versus Net Area) are oversimplified and will have major detrimental impact on lower density neighborhoods, by allowing significantly greater square footage development which is out of scale/height/context with existing neighborhoods. Use of T-4, T-5 and T-6 designed for high density, urban core are not appropriate for medium density and low density neighborhoods in the City. DPZ has refused to respond to requests for modified versions of T-4, T-5 and T-6 for medium density and low density sections of the City. This would also apply to T-3, if our requested amendments to 3.10 prepared by Barbara Bisno are not accepted. 18. The Miami 21 Atlas violates in several areas the principles of new urbanism and the current zoning code context and other requirements, in that in may cases contiguous T zones are not "transitional", so there are clear violations of sections 1305 and 2301. T-5 and T-6 lots often abut T-3. A T-3 neighborhood next to a transit corridor should be protected by having that corridor designated a T-4. The Miami 21 Atlas often creates the transition by up -zoning into the T-3 neighborhoods. 19. Transfer Development Rights (TDR) should be available only for limited use, such as to preserve historic buildings. It is unlikely that there will be sufficient supply or demand to adopt TDR's broadly, but in any case, in areas where height limits and TDRs are being enacted, the height limits shall not be predicated on the TDRs — so that if the TDR program is not successful the height limits are still in place. Please refer to the Appendixes attached for additional background information relating to the Items above. Attachments SUB-MITTED INTO THE PUBLIC RECORD FOR ITEMI� ONo o, . CITT-tg of Ontarat"o, PF -DRO G. HERNANDEZ, P.E. CITY MANAGER June 21, 2007 Miami Neighborhoods United c/o Mr. Hadley Williams, President 1665 SW 23 Street Miami, FL 33145 Dear Member of Miami Neighborhoods United: —�p F.0 1 90X 330708 MIAMI, FORIDA 33233-0708 (305)250-5400 FAX (305) 250-5410 SUBMITTED INTO THE PUBLIC RECORD FOR ITEM-L-.L_ON c, I want to thank you for giving me the opportunity to meet and discuss your concerns as they relate to the Miami 21 planning process and the City's Comprehensive Plan. As I stated at our meeting on May 29, 2007, I agree with your objectives and vision of protecting and enhancing our neighborhoods as we face unprecedented growth in our city. Our neighborhoods have always been our strongest assets. I believe that I was able to respond to many of your concerns at our meeting however there were a few outstanding issues that needed additional information; these are addressed below, Miami Comprehensive Neighborhood Plan (MCNP) The concerns you raised regarding the Comprehensive Plan have been noted and will be considered as we continue to move forward with that effort. As you know, the Final Revised Evaluation and Appraisal Report (EAR) of the Comprehensive Plan was completed and approved by the City Commission in November of 2005. The process of preparing and adopting the necessary amendments to the Comprehensive Plan will be commencing shortly and I assure you that it will involve more than adequate public participation. Miami 21 With .respect to the Miami 21 efforts, the process has already consisted of over 100 meetings with numerous groups from all segments of the community, including 25 public meetings. From the discussion at our recent meeting, it seems that there are still several outstanding issues that your organization has concerns with that are contrary to those of our Miami 21 team. One such issue has to do with notice provisions. Please note that the section of Miami 21 that deals with notice has been amended to reflect and address these issues in the most effective manner as recommended by our consultants and staff. The one outstanding issue that our Miami 21 team does not concur with MNU is the expansion of the notice area to a 2,500 -foot radius for Special Area Plans. In the previous draft of Miami 21, administrative Special Area Plans were incorporated. The Special Area Plans section of the code has since been modified so that all of them will have to go through a public hearing process. The process includes posted notices on the property and newspaper notices in addition to the mail notices, notices to homeowner associations and postings on the web. We believe that this is a broad enough base for adequate notice and therefore do not recommend changes. A major concern that was raised at our meeting related to Miami 21 was that of height as it relates to stories. The Miami 21 team has proposed a 14 -foot height as a maximum for each story (with the exception of single family residences) in order to allow more flexibility in design. The 14 -foot height is also consistent with LEED (Green building) Certification in that the slightly higher floor to ceiling height allows for better air circulation and is therefore more energy efficient. They do not recommend reducing that height. Another issue you raised was the language used in Miami 21 that allows certain things "by right", or, "as of right." Again, the Miami 21 team does not recommend changing this language. It is important to both the neighborhood groups as well as private property owners that the Miami 21 Code be clear and predictable. A property owner has to be able to have a clear indication of what he/she can do on their property just as a neighbor is entitled to have a clear indication of what can be built next door to their property. This language provides that clarity. Finally, I heard a very clear message from your group regarding your desire for the Miami 21 Code to retain the standards of 1305 from the 11000 code. It is very important for you to understand that the former 1305 standards were "design" review criteria, and the Miami 21 Code is a form based for which such standards are already built in. The form based code provides for safeguards in transitions in bulk and scale, appropriate fagade treatments, liners on parking garages along primary streets, etc. In short, the Miami 21 Code has incorporated the standards of 1305 into the code itself. There is no need to retain the 1305 criteria in the Miami 21 Code. In addition, please note that the most recent draft of the Miami 21 Code has retained referrals to the Urban Development Review Board (UDRB) in order to ensure that other aspects of design continue to receive review. I hope that I have been able to respond to your most pressing concerns in this letter and look forward to continuing to work closely with your organization as our planning efforts move forward. L er Pedro G. ez, P.E. City Manager SUBMITTED INTO THE PUBLIC RECORD FOR ITEM Fz.:;o- ON Cc: Ana Getau ert-Sanchez, Director, Planning Department 2