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Ines Marrero-Priegues
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ines.marrero@hklaw.com
April 7, 2010
VIA HAND DELIVERY
Ms. Ana Gelabert Sanchez
Planning Director
City of Miami
444 S.W. 2"d Avenue
Miami, Florida 33130
Re: FDG Flagler Station II, LLC / Application for Official Vacation and Closure of a Public
Right of Way for portions of NW 4th Street east of NW 1" Avenue and portions of
"old" NW 1St Avenue between NW 5th Street and NW 8th Street.
Dear Ms. Gelabert:
This firm represents FDG Flagler Station II, LLC ("FDG"), the owner of certain lands in
the City of Miami and the applicant requesting the official vacation and closure of right of way
for portions of NW Ott' Street east of NW 1St Avenue and portions of "old" NW 1st Avenue,
between NW 5th Street and NW 8' Street.
FDG is the owner of approximately 8.3 acres of land located between NW 1St Street and
NW 8th Street, and between the MetroRail Rapid Transit corridor and NW 1St Avenue (the "Plat
Property"). A brief history of the site will not only explain the reasons for the vacation of right
of way and platting of the lands but will also serve as explanation of the public benefit of this
application.
In 1988, the owner of the Plat Property applied for a Major Use Special Permit for an
office building and a replat of the Plat Property (the "1988 Plat"). Both the MUSP and the 1988
Plat were approved by the City Commission but the office building was, never built and, more
importantly, the 1988 Plat was never recorded. The 1988 Plat was never recorded because prior
to recordation, it was discovered that Miami -Dade County (the "County") owned certain rights in
NW 2nd Avenue, which the 1988 Plat sought to vacate. The County's position was that the City
could not vacate this right of way without the County's consent and approval. The parties were,
at that time, unable to reach an agreement regarding certain pedestrian easements required by the
County in consideration for its consent to the vacation of the NW 2nd Avenue.
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Ms. Ana Gelabert Sanchez
April 7, 2010
Page 2
In the interim, without the 1988 Plat having been recorded, the City improved rights of
way as if the 1988 Plat had been a legal plat, including the creation of new tracts and the
vacation and relocation of streets and rights of way. In fact, the current location of NW l st
Avenue exists where the 1988 Plat proposed it. It should be noted that Gran Central paid the
City of Miami in excess of $650,000 to relocate the utilities to the existing location of NW 1St
Street and also paid $1.4 million dollars to acquire property that was necessary for the street re-
alignment. The only thing that was never accomplished was the recording of the plat.
During the last twenty years, the City and the predecessors to FDG have spent
innumerable hours and resources with the City and the County to determine a way in which to
legally record a plat 120 days after its approval, as established in the City Code. We would be
remiss not to thank past and present members of the City Attorney's office as well as past and
present members of the City's Public Works Department for their support and collaboration and
technical support throughout this process. We have also reached agreements with Miami -Dade
County relative to the N.W. 2nd Avenue easement issues that initially caused the problem. In the
end, due to innumerable technicalities and title and surveying complexities, it was determined
that, while cumbersome, the most legally complete way to remedy this problem would be to file
for new plat, including the closure and vacation of the rights of way requested in this application.
It is with this background that we respectfully request that the right of way- for those
portions of NW 1St Avenue and NW 4th Street that were originally intended to be closed and/or
relocated by the 1988 Plat, be vacated and closed in connection with the new plat.
On January 7, 2010, the City's Plat and Street Committee considered this request for
vacation and closure of the streets and voted 7-0 in favor of the vacation and closure request. In
support of their approval, the Committee considered and recognized the following public
benefits from the requested street closure and vacation:
1. The previous owners paid $1.4 million dollars to the City for the
relocation of NW 1st Avenue;
2. The new, relocated NW 1st Avenue provides wider widths and better
roadways;
3. The relocated right of way allowed for the creation of the Metrorail
corridor;
4. The re -platted parcels create better tracts for development;
5. The realignment of NW 1st Avenue has already occurred and this
application merely maps on paper what has already happened on the streets;
6. The previous alignment of NW 1st Avenue does not provide any public
purpose;
Ms. Ana Gelabert Sanchez
April 7, 2010
Page 3
7. The Fire Department, Police Department and all other service vehicles
have excellent access to the sites;
S. The existing alignment, roads and sidewalks provide better pedestrian and
vehicular circulation.
Based on the foregoing, we respectfully request your favorable review and
recommendation of our request. Should you have any questions, please do not hesitate to
contact me.
Sincerely,
I9'sarrer riegues
cc: Mr. Jose Gonzalez
Ms. Estrella Manso
John R. Hall, P.E.