HomeMy WebLinkAboutSubmittal-Miami Neighborhoods United Analysis of Miami 21's Final Draft of August 3, 2009Miami Neighborhoods United
Analysis of Miami 21's Final Draft of August 3, 2009
Tuesday, September 1, 2009 — Q:50 pm
Miami Neighborhoods United, a coalition of 18 neighborhood associations. was formed to
preserve and protect Miami's single-family and duplex neighborhoods. Miami 21, in section
2.1.2. declares its first conservation goal as being "preserving neighborhoods". This analysis of
Miami 21 was done with the same goal in mind.
A brief summary of MNU's position on the Miami 21 Atlas.
First and foremost, by far the most important aspect of Miami 21 is the zoning atlas. In order to
preserve and protect neighborhoods, MNU has long advocated a 35 foot height limit along
commercial corridors outside downtown, with certain specific exceptions such as the Civic
Center and the Airport Lake area (Between LeJeune and Red Road, North of NW 7 Street.)
M21 proposes an excellent concept with T40 zoning, as this is a 3 -story height limit which 1�1
the logical zoning category to have along commercial corridors, especially where they abut low
density single-family and duplex neighborhoods. W '
MNLi strongly urges our commissioners to implement T4 zoning along any commercial corridor
that abuts any currently zoned single-family or duplex neighborhood. Up -zoning a single family
or duplex property to circumvent the T4 zoning should not be allowed.
An analysis of the Miami 21 CODE and MNU's position.
In general, the code appears to have many examples where objective critoria have been
substituted for subjective criteria, under the guise of flexibility. This can lead to major problems
vis-a-vis inconsistent protection of neighborhoods.
In this analysis, any text or paraphrasing from the Miami 21 code is in regular type, with
MNU's analysis comments in italics.
ITEM 1:
I.13. Building height is measured in stories.
II1.7 3.5.1 Unless otherwise specified herein, the Height of Buildings shall be measured in
Stories.
o-oi315c! - vn�`� H7a srs oF
0+ R u jr S . 3, ?-00?
Submitted into the public
record in connection with
item SP.1 SP.2 & SP.3 on 09-04-09
Priscilla A. Thompson
City Clerk
2
I11.7 3.5.2 A Story is a Habitable level within a Building of a maximum fourteen (14) feet in
Height from finished floor to finished floor. Basements are not considered Stories for the
purposes of determining Building Height. A ground level retail Story may exceed this limit
up to a total height of twenty-five (25) feet. A single floor level exceeding fourteen (14) feet, or
twenty-five (25) feet at ground level retail, shall be counted as two (2) Stories. Where the first
two stories are retail, their total combined Height shall not exceed thirty-nine (39) feet and the
first floor shall be a minimum of fourteen (14) feet in Height.
MNU strongly opposes this concept. Building heights should be measured in feet, in addition to
the maximum number of stories allowable. Use 25 / 14 only in downtown, 15 / 10 elsewhere, as is
the standard.
And why an arbitrary minimum of 14 for the ground level retail?
V.21 The below drawing shows a T5 building abutting T3. Same in V.31 with T6.
Man SIDE d REAR T3
The above draia'ing shows the first and second door of the T3 as having the same height as the
T5, but M21 proposes allowing a 25 foot first/loor, and 14 foot floors above that. The drawing
needs to be redone to show 25/14, up against a 9 foot tall house, currently standard for most
single family homes. The drawing, below, shows M21 's real dimensions and why it is
inappropriate to have 25 and 14 foot high floors outside the CBD.
Submitted into the public
record in connection with
item SP.1. SP.2 & SP.3 on 09-04-09 2
Priscilla A. Thompson
City Clerk
ISS FEET
IF
r 9RfX1MD r_DAIt I r GRA !Ir FL{y0q 1
�:-. -- su+nLSFiwnr
MAW21 • TSBUI MNG FUSE - WAM12T • T" BUILDING
X u
Above you see the real effect .121 's proposed 25 i 1 4 floor heights would have on a
neighborhood.
I
3
Suggestion: Apply the 25 and 14. foot maximums only in downtown. Outside downtown, make it
15 and 1 D feet. From it -hat Elizabeth Plater-Zyberk (the Miami 21 consultant) has said, 2511.1
would not be economic cilli, feasible outside of an intense commercial area anyway, so there would
be no harm in limiting it that way.
ITEM 2:
Page I.13 The phrase "by right" is used throubliout the entire document, but it should be
replaced with "allowablebecause nothing in Miami 21 is "by right" or "as of right ", as we
have been told by Planning Dept staff and as is verified in other places in the ,Miami 21 code,
such as:
11.9 2.2.4.1 In their interpretation and application, the provisions of this Miami 21 Code
shall be the minimum requirements or maximum limitations, as the case may be,
adopted for the promotion of the public health, safety, morals or general welfare.
Even though the definition of "by right" we ntrons zoning review and approval, to the average
citizen, "by right" conveys a sense of undeniable buildable rights, contrary to the definition given
in M21. Most specifically, "by right" should not apply to building heights.
ITEM 3:
Submitted into the public
record in connection with
item SPA, SP.2 & Sp- 3 on 09-04-09 3
Priscilla A. Thompson
City Clerk
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MAW21 • TSBUI MNG FUSE - WAM12T • T" BUILDING
X u
Above you see the real effect .121 's proposed 25 i 1 4 floor heights would have on a
neighborhood.
I
3
Suggestion: Apply the 25 and 14. foot maximums only in downtown. Outside downtown, make it
15 and 1 D feet. From it -hat Elizabeth Plater-Zyberk (the Miami 21 consultant) has said, 2511.1
would not be economic cilli, feasible outside of an intense commercial area anyway, so there would
be no harm in limiting it that way.
ITEM 2:
Page I.13 The phrase "by right" is used throubliout the entire document, but it should be
replaced with "allowablebecause nothing in Miami 21 is "by right" or "as of right ", as we
have been told by Planning Dept staff and as is verified in other places in the ,Miami 21 code,
such as:
11.9 2.2.4.1 In their interpretation and application, the provisions of this Miami 21 Code
shall be the minimum requirements or maximum limitations, as the case may be,
adopted for the promotion of the public health, safety, morals or general welfare.
Even though the definition of "by right" we ntrons zoning review and approval, to the average
citizen, "by right" conveys a sense of undeniable buildable rights, contrary to the definition given
in M21. Most specifically, "by right" should not apply to building heights.
ITEM 3:
Submitted into the public
record in connection with
item SPA, SP.2 & Sp- 3 on 09-04-09 3
Priscilla A. Thompson
City Clerk
4
111.24 3.14.1 The bonus shall not be available to properties in a T6 Zone if the property
abuts a T3 Zone.
Good, but should be modified to apply, to all properties currently zoned T3, so as to al'ord
progressive up -zoning in the future. Also, perhaps this should also apply to CS?
ITEM 4:
1 ,0;
1'.27: Article 4, Table 12, "Design Review Criteria"
As the planning &IcPartincnt %>'icl;: stated, in writinrr, "Section 1305 as referred to in Ordinance
11000 will be incorporated in its entirety within the Miami 21 zoning code revisions. " This is
simply not true: it has been changed very much from how it appears in 11, 000, where it runs for 9
pages, while in X1121 it is only, one page long. Also, section 1306, from 11, 000, should also be
included in M21, because 1306 g!ves�t�e cip,the authority, to enforce 1305.
All of 1305 and 1306 .should be included in M21.
ITEM 5:
Drastic changes to 11,000's "GI ordinance " are mac c, in M21.
V.43 5.7.2.6 In the event that a Civic Institution Zone ceases to be used for Civic
Institution Uses, it shall be developed either in accordance with the regulations of the
most restrictive Abutting Transect Zone or by process of rezoning, subject to the
limitations of the Comprehensive Plan.
On the same top] c. from another area of M21:
VI1.30 7.1.2.8 Amendment to Miami 21 Code
a. Successional Zoning.
1. When a Cl zoned property ceases to be used for Civic functions, the
successional rezoning is determined by identifying the lowest Intensity
Abutting Transect Zone, and rezoning to that Zone's next higher Ilitensity
Zone.
These sections weaken the GI ordinance, which states:
11,000, Section 401, under G/I Government and Institutional:
Submitted into the public
record in connection with
item SPA, SP.2 & SP.3 on 09-04-09 4
Priscilla A. Thompson
City Clerk
5
Uses ancillary to these [ government / institutional ] uses are allowed to a maximum density and
intensity equivalent to the least intense abutting zoning district, subject to the same limiting
conditions.
To preserve the intent ofthe GI ordinance, the successional zoning in X121 should be the same as
the least intense abutting, not the new higher.
We also need language to prevent a CI property from carving out apiece of property in order to
insulate them from abuniirg transect zones, such as was attempted at Mercy.
ITEM 6:
V.5 5.3.2 For T3 -R and T3 -L, second story lot coverage shall not exceed thirty
percent (30%).
Good far those two transects, but it does not apply to T3-0, so it would still allow duplex
McMansions, as has been happening in Coconut Grove. Should be changed to include T3-0.
ITEM 7:
111.12 b. Deferral period, revocation of permit: notice of revocation.
A deferral may be allowed for up to five (5) years without provision for renewal except
upon application for a new Waiver. All applications for deferral shall be reviewed and
approved by the Planning Director before issuance by the Zoning Administrator.
What are the objective criteria for the deferral? Now does this protect the deferral process from
favortism / politic,v ? Isn't it currently only 2 years:' Make it 2 years.
ITEM 8:
111. 18 3.9.1 Special Area Plans
10. Flexible allocation of development capacity and Height, excluding Density on
individual sites within the Special Area Plan shall be allowed so long as the capacity or
Height distribution does not result in development that is out of Scale or character with
the surrounding area, and provides for appropriate transitions.
.i r... -r, •,, tivr. r._. h %rr:-irS without nrn,.lt,.,_ .- .
Submitted into the public
record in connection with
item SPA, SP.2 & SP.3 on 09-04-09 5
Priscilla A. Thompson
City Clerk
CI
"1,7exible allocation of development capacity and height" —what exactly does that mean? Who
decides it, and using what criteria? This can lead to problems, especially if it is abutting or
adjacent to T3.
"not... out of Scale or character" sounds good, but again, who decides if something is out of
scale or character? The same planning dept that recommended approval of the Mercy condo
lowers?
ITEM 9:
IVA Table on Lot Occupation:
Maximum lot area is 40,000 square feet..
40, 000 sf as a maximum in T5 is too much. M21 originally suggested 30k. Suggestion: Take it
back to 30K as a T5 inem
Building height in T5 is a minimum of 2 stories.
Why are single story buildings not+allowed in, T5? -.This -would make it more expensive to build a
minimum -sized building. What about restaurants and gas stations? Every single -story building in
T5O commercial areas would then become a non -conforming use.
ITEM 10:
IVA Table on Lot Occupation:
There is a zero side and rear setback in T5 abutting T5 or higher.
Wouldn't this allow windowless apartments? Where would you plant trees? This is in conflict
with LEED.s, which advocates sunlight. Similarly:
1.19: Note this definition:
Habitable Space: Building space which Use involves human presence with direct
view of the
enfronting streets or public or private Open Space, excluding Parking Garages, self-
service
storage facilities, warehouses, and display windows separated from retail activity.
now is that compatible with the zero side and rear setbacks allowed in TS? How can tw- '-
by -side buildings, up against each other with zero setback have windows between them?
Submitted into the public
record in connection with
item SPA, SP.2 & SP.3 on 09-04-09
Priscilla A. Thompson
City Clerk
7
MNU's position is that zero -setback T5 buildings should only be allowed in downtown ars cts. (Is
downtown defined as the area bordered by the Miami River, Biscayne Bay, 1-95 and 1-395?)
ITEM 11:
V11.3 Article 7
The "Permitting Process Diagram" on this page has eliminated public hearings for Iarge building
projects - No more MUSPs. If there is no waiver, warrant, exception, � �iriance or zoning change
involved, they are "by right" and get a building permit.
This is an outrageous limiting of public involvement. Just as before, public hearings and city
commission approval should be required of any large building. Suggested criteria: any building
over 3 stories and or =� units should have a public hearing.
ITEM 12:
V1 1.15 7.1.2 Permits Permits issued in error shall convey no rights to any party. The
Zoning Administrator shall require corrections to be made unless construction has
commenced on that portion of the construction that was permitted in error.
V11.43 7.1.3.6 Approvals granted in error do not authorize violation of this Code;
corrections required.
a. An approval issued in error shall not confer any rights to construction or
occupancy, and upon a finding that a permit has been so issued, it shall be
revoked unless construction has commenced on that portion of the construction
that was permitted in error.
I his is improper and could lead to abuse of the system, or allow bad construction to stand. We
need protection against hurried construction on an error, like a stop -work order if the permit is
being challenged.
ITEM 13:
V1I.17 7.1.2.2 c. The Board shall determine whether the administrative determination
is upheld or rescinded. The ruling of the Planning, Zoning and Appeals Board may be
further appealed to the City Commission, and must be filed with the Office of Hearing
Boards within fifteen (15) calendar days of the Board's issuance of its ruling.
Submitted into the public
record in connection with
Illi �,�,I�l� i e'- item SPA, SP.2 & SP.3 on 09-04-09 7
Priscilla A. Thompson
City Clerk
8
The above paragraph .should include "De Novo " afier the word "appealed". so that appeals to
the City Commission are de novo appeals, as is currently the case, as is stated in Miami 21 for
PZAB appeals. Suggested language: "An appeal of 'a planning determination, if sought, shall be
de novo."
Another problem with this same section:
Before appeal of any action to the City Commission, the appellant is required to
have exhausted administrative remedies by appearing on the record at the
hearing before the Planning, Zoning and Appeals Board. In addition to
requirements of the Hearing Boards Office, the filing of the appeal shall state the
specific reasons for such appeal, together with payment of any required fee. The
appeal may be filed only by the applicant or any person who appeared of record
at the Planning, Zoning and Appeals Board hearing on the decision being
appealed and who is aggrieved by the action of the Planning, Zoning and
Appeals Board.
This is onerous, and much more restrictive than the current. Anyone should be allowed to appeal
do novo to the citycommission, ommisslon, even if they dill not appear at the PZAB or are "aggrieved",
whatevcr that would be interpreted to mean. Who decides who is aggrieved? The city?
Important note: the same situation applies to 7.1.2.3, and other sections, such as Warrant,
Waiver, Exception and Variance, which have similar language.
ITEM 14:
VII.20 7.1.2.4 4. A Warrant shall be valid for a period of two (2) years during which a
building permit or Certificate of Use must be obtained.
It should be one year, as it was before, It was changed in the M21 red -line version Nov 5, 2008.
Note that the same situation applies to other sections, such as Warrant, Waiver, Exception, and
Variance, which have similar language
Appeals to PZAB and City Commission should he free, not the current $500.
ITEM 15:
VI1.21 7.1.2.5
I
This section includes a listing of 25 d�jerent waiveable deviations from the code. In general, there
is too match power to waive requirements administratively, such as parking. This makes it
difcultfor the public and neighborhoods to protect themselves. There shoidd be public hearin(,s
at PZAB for the 25 waiveable items in this section, not just public notice and an administrative
decision.
Appeals to PZAB and City Commission should be free, not the current $500.
ITT:M 16:
NOTICE requirements:
V11.23 c. F=a;!uFe to give RGtiGe undeF this GeGtien shall ..
Fortunatelv, this outrageous sentence has been struck from the many places it appears
throughout the article, wherever notice is mentioned as you see above. It would have alloivcd
the city to not give notice, without penalty, Suggestion: Leave the sentence in, but strike the
word "not" from each and every occurrence, like this:
Failure to give notice under this section shall ne� invalidate a decision on a Waiver.
That sentence would sc°rve as a stronger protection against notice.failures, as happened in the
past ii-ith Buena Vista East. That it-ould force the city to actually do their job and give proper
notice.
Notice that this should apply to administrative decisions, warrant, waiver, exceptions and
variances; anything that requires a public notice.
ITEM 17:
VII.42 7.1.3.5 d. Modifications to special permits and Variances approved under a
previous code.
1. An applicant may modify a special permit approved under a previous zoning
code, as a minor modification through the Warrant process, if the
components being modified will after modification be in compliance with this
Code, even though the remainder of the approved development plan is not in
full compliance with this Code. The special permit may be amended with
modifications that the Planning Director determines not to be minor, and
variances may be modified according to the following procedures:
a. Cass I Special Permits shall be amended pursuant to Chapter 62 of the
10
City Code.
b. Class II Special Permits shall be amended as a Warrant.
c. Special Exceptions and Major Use Special Permits shall be amended as
an Exception
d. Variances may be modified as a Variance.
This loophole should not be allowed: Class 2 and MUSPs should h(we to reapply or go to public;
hearing, or both.
ITEM 18:
VI1.42 7.1.3.5 3. The expiration date for any Class II Special Permit, Major Use Special
Permit
or Variance approved under the Zoning Ordinance 11000 in effect immediately prior to
the date of adoption of this Miami 21 Code may, upon application to the Director by the
owner, be extended from its original expiration date as follows:
a. Class II Special Permits, Special Exceptions and Variances shall be
permitted no more than one (1) time extension for a period not to exceed
twelve (12) months.
b. Major Use Special Permits shall be permitted no more than two (2) time
extensions for each time extension period not to exceed twenty-four (24)
months.
YYhat criteria is there for determining if the extension should be granted? Is it totally at the
discretion of the Director? No public involvement? This is not fair, as there is nothing to
prevent special-interest group influence.
Extensions to previously approved Class 2 permits, Variances, MU.SPs and Spacial Excep!ions
should have to reapply or go to public hearing, or both.
ITEM 19:
VI1.44 7.1.4.1 Intent
The intent of this section is to establish procedures to ensure procedural due process
and maintain citizen access to the local government decision-making process for the
review of certain applications that require quasi-judicial hearings. These procedures
shall be appiied and interpreted in a manner recognizing both the legislative and
judicial aspects of the local government decision-making process in quasi-judicial
hearings. Failure to observe the procedures set out herein shall not provide a
separate cause of action to challenge the decision of the decision-making board.
10
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This is a denial of due process. Is this even legal? The city doesn't even have to follow its own
rules? The boldface sentence should be stricken.
ITEM 20:
111.11 3.6.7 The applicant shall submit plans which demonstrate how the remaining
parking may be accommodated in the event that the housing becomes market rate
housing at some time in the future.
Suggestion: Change the "may" above to "will ".
ITEM 21:
II.7 2.2.1.1 - Zoning Ordinancel 1000 will still apply to Midtown and Miami World Center,
although the M21 appeals process, which decreases public involvement, would also apply.
It makes no sense to have two different zoning ordinances at the same time. JV17y are these two
private projects being given special treatment?
ITEM 22:
111.25 3.14.3 The proposed bonus Height and FLR shall be permitted in exchange for
contribution to the City for the following public benefits: affordable/workforce housing, Public
Parks and Open Space, Green Buildings, Brownfields, and Civic Space or Civil Support space.
The City shall establish a Miami 21 Public Benefits Trust Fund for the cash contributions for
Affordable/ Workforce Housing, Public Parks and Open Space, and Green Building certification
shortfall penalty made under this section. The City Commission, upon the manager's
recommendation, shall annually decide the allocation of funds from the Trust Fund collected
under this section. All cash contributions thus allocated by the Commission to support
affordable/ workforce housing shall be deposited in the Affordable Housing Trust Fund
for expenditures pursuant to the guidelines adopted by the City Commission. All cash
contributions thus allocated by the Commission to support Parks and Open Space shall
be deposited in the Parks and Open Space Trust Fund,,set forth in Chapter 62 of the City
Code, to be expended in accordance with the guidelines outlined therein.
Suggestion: Post an on-line spreadsheet of the various trusi. fund contributions / balances / uses.)
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ITEM 23:
V.17 and V. 24 5.5.1 and 5.6.1
j. Maximum Lot size as shown in Illustration 5.5 (and 5.6) may be increased by
Exception for Uses that serve the Neighborhood.
What are "uses that serve the neighborhood?" That is vague, undefined and open to
convenient interpretation. M21 should either disallow exceptions to the max lot size, or
define criteria for the exception.
ITEM 24:
V.42 5.7.1.4 In Civic �paccs, Buildings shall conform to regulations of the most restrictive
Abutting Transect Zone, except as shown by City of Miami's Parks and Public Spaces Master
Plan. Other adjustments to the regulations shall be approved by process of Exception.
Not sure what is on the Parks anti Public Spaces Master Plan, but what exactly is meant by
"Other adjustments to the regulations shall be approved by process of Exception"? _ gnirt. the
door is left open for potentially undesirable changes.
ITEM 25• 0/ 1010 How(-
VI.'_' 6.4.1 Personal Wireless Service Facility allowed in T3 to 35 feet. T4 to 60 feet.
35 foot tall antennae should not be allowed in T3.
ITEM 26:
ITEM 27:
VII.25 7.1.2.6 3. Projects equal to or less than two hundred thousand (200,000)
square feet of floor area shall be reviewed by the Planning Director and the Zoning
Administrator without need for review bythe Coordinated Review Committee,
unless the Planning Director and Zoning Administrator determine that review
bythe Coordinated Review Committee is necessary.
200,000 sq feet is the size of two Home Depots! The cutoff should be 30,000 square
feet. Anything above that should go to the CRC, even for an Exception.
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ITEM 28:
VII.-:, 7.1.2.8 7. Waiver of time limits. The time limits set forth in this subsection g.
may be waived by a vote of at
least three (3) members of the City Commission when such action is deemed
necessary to prevent injustice or to facilitate development of the city in the
context of the adopted Comprehensive Plan, or any portion thereof.
This is similar to:
VI1.44 7.1.3.8 Resubmission and Withdrawal of Applications Requiring Public
Hearing.
a. Whenever an application has been denied, the city shall not thereafter consider
the same application for any part or all of the same property for a period of
eighteen (18) months from the date of the denial.
b. Whenever an applicant has voluntarily withdrawn an application after the
application has been scheduled for a public hearing, the city shall not thereafter
consider the same application for the same property for eighteen (18) months
from the date of the withdrawal.
c. The time limits set by paragraphs a. and b. above may be waived by a vote of not
less than three (3) members of the decision making body when such action is
deemed necessary to prevent injustice or to facilitate development of the city in
the context of the adopted Comprehensive Plan, or portion thereof.
This is subjective and vague, as it could apply to anti item.
All development is already required to be in the context of the comp plan. Time limits should not
be waiveable, to protect the public interest.
ITEM 29:
VIIAI 7.1.3.5 Modifications to Applications Requiring Public Hearing
a. Modifications to applications after processing begins.
An applicant may modify an application filed with the Office of Hearing Boards
after processing begins and prior to the public hearing if the modifications are not
substantial. Otherwise, a new application must be made and fee paid. Whether a
proposed modification is substantial shall be determined by the Zoning
Administrator, according to whether the requested modification requires a
Variance or Exception.
.1 :.'Jptvu or portiw► t �,
There should be objective criteria fur the determination of "substantial ", notjust the opinion of
the Zoning Administrator. A modification can be substantial tii,*ithotit requiring a variance or
exception.
ITEM 30:
ITEM 31:
ITh.M 32:
VII.46 7.1.4.4 c.The official file shall be available for inspection during normal
business hours.
Suggested addition: and be posted on-line at least 6 days prior to the meeting.
ITEM 33:
VII.48 7.1.4.6 Rules of Evidence
f. Documentary evidence may be presented in the form of a copy of the original, if
available. A copy shall be made available to the Decision-making body and to the
staff no later than two business days prior to the hearing on the application.
Note the 2 day deadline. It should be at least 6 days, to require posting on a Friday for a
commission meeting the following Thursday. It should also require submission to the public
folder and on-line posting.
ITEM 34:
V11.49 7.1.4.8 The record
All evidence admitted into the record ai the hearing, and the adopted development
order of the Decision-making body shall be maintained by the City Clerk in a hearing
file for a period of at least forty-five days (45) from issuance of the decision.
Should also be posted on-line for at least 10 years afterwards.
ITEM 35:
14
14
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V11.49 7.1.5 Appeals
There is no mention of an appeal fee. It is currently 5500. The public should not hmv to pay to
appeal an issue to their appointed or elected officials.
ITEM 36:
V.42 5.7.1.3 One or more Buildings may be built in each Civic Space. Building floor area shall
not exceed twenty-five percent (25%) of the lot area of the Civic Space, and shall
support the principal use of the Civic Space.
25% is too much park land to become a building. Suggestion: Only 5% of a park should be
allowed to be covered hY a building. (Why does M21 call parks "Civic Space"? Why not still call
them Parks, PR?)
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