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Memo Luft Consulting, Inc.
Luft Consulting, Inc. 1717 Windward Way Sanibel Island Florida. 33957 Ph. 239-395-2215 Fax. 239-395-1787 Memo To: Lucia Dougherty, Esq. From: Jack Luft CC: Date: May 17, 2006 SUBMITTED INTO THE PUBLIC RECORD FOR ITEM3' ON 9-7-06 . Re: Consistency of Herald Square MUSP with Miami Comprehensive Neighborhood Development Plan In reviewing the Herald Square development proposal of the Terra Group for the Miami Herald property, I find that in my best professional opinion, the Future Land Use Map change to Restricted Commercial and the companion zoning change to SD-6, is consistent with the following Goals, Objectives and Policies of the Miami Comprehensive Neighborhood Development Plan: Future Land Use Element: Goal LU-1: Maintain a land use pattern that (1) protects and enhances the quality of life in the city's residential neighborhoods; (2) fosters redevelopment and revitalization of blighted or declining areas; (3) promotes and facilitates economic development and the growth of job opportunities in the city; (4) fosters the growth and development of downtown as a regional center of domestic and international commerce, culture and entertainment; (5) promotes the efficient use of land and minimizes land use conflicts; and (6) protects and conserves the city's significant natural and coastal resources. FINDING: The Land Use and Zoning Change removes an obsolete liberal commercial district that is intended to serve industrial and warehousing uses and conflicts with the CRA redevelopment plan for the area that promotes residential and local serving retail and entertainment compatible with the Performing Arts Center thereby protecting the quality of life in an emerging center city neighborhood. The elimination of incompatible uses fosters redevelopment and investment in a blighted area, adds retail and service sector use jobs and promotes the public use of the area as a cultural arts district. Policy LU-1.1.1: Development orders authorizing new development or redevelopment that results in an increase in the density or intensity of land use shall be contingent upon the availability of public facilities and services that meet or exceed the minimum LOS standards adopted in the CIE. • Page 1 ��d FINDING: The City and County staff reviews and Large Scale Development Committee review of the build -out of proposed uses affirms that all facilities, utilities and services for the area comply with Level of Service Standards in the CIE. 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. FINDING: The existing Future Land Use category of General Commercial does not promote neighborhood related services and restricts residential and residential serving uses. The proposed change supports expansion of neighborhood retail and services. 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 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 generally east of the Palmetto Expressway and including all of the City of Miami. Within this area, the concentration and intensification of development around centers of activity shall be emphasized with the goals of enhancing the livability of residential neighborhoods and the viability of commercial areas. Priority will be given to infill development 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 standards set forth in Policies TR-1.1.2 and 1.1.3 of the Transportation Element of the MCNP. FINDING: The site is within a designated Urban Infill Area and is designated an Urban Central Business District (28-24.014(10), F.A.C. with direct service by the Metromover extension of the Metrorail Rapid Transit System and is within a Regional Activity Center as designated by the Miami -Dade Comprehensive Plan. Objective LU-1.2: Promote the redevelopment and revitalization of blighted, declining or threatened residential, commercial and industrial areas. FINDING: The site is within a State designated area of slum and blight and is a Redevelopment District Tax Increment District. The adopted OMNI redevelopment plan for the area calls for the proposed change in Future Land Use and Zoning to Restricted Commercial and SD-6 zoning. 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 maintenance of real property. Declining neighborhoods are defined as areas characterized by the prevalence of structures having minor deficiencies, a general need for improvements in real property, • Page 2 '.c s c -E > ° aro73 c 1 E > C ©Q v §-Wc1' szu () :LI significant declines in real property values, high vacancy rates in commercial structures and increasing difficulty in obtaining insurance. Neighborhoods threatened with decline are defined as areas characterized by significant but infrequent property maintenance neglect, an aging housing stock, declining property values, general exodus of traditional residents and influx of lower income households. FINDING: The majority of surrounding lands are vacant and underdeveloped with aging structures and disinvestment in property and facilities widespread within the Redevelopment District. Policy LU-1.2.3: The City's residential, commercial and industrial revitalization programs will continue to place highest priority on protecting neighborhoods threatened with declining conditions, second priority to reversing trends in declining areas, and third priority to removing blighted conditions, and the City will continue its efforts to secure federal and state aid in developing comprehensive redevelopment programs FINDING: As a designated area of slum and blighting conditions, the proposed change of the FLUM to Restricted Commercial with remove the potential for incompatible uses in the Liberal Commercial category thereby protecting existing residential uses from encroachment of industrial and highway commercial uses inappropriate to a mixed use pedestrian district featuring the performing arts. Policy LU-1.2.4: The City will continue to adhere to its established policies regarding Community Redevelopment Districts and will continue to implement plans for the Omni and Southeast Overtown/Park West as Community Redevelopment Districts. FINDING: The proposed changes are consistent with the Omni Redevelopment Plan. Objective LU-1.3: The City will continue to encourage commercial, office and industrial development within existing commercial, office and industrial areas; increase the utilization and enhance the physical character and appearance of existing buildings; and concentrate new commercial and industrial activity in areas where the capacity of existing public facilities can meet or exceed the minimum standards for Level of Service (LOS) adopted in the Capital Improvement Element (CIE). Submitted Into the public record in connection with item P2. 3£q on Rl _D6 Priscilla A. Thompson City Clerk FINDING: This proposed change in Future Land Use and Zoning will encourage the concentration of high density residential and commercial uses in an area designated for Central Business District uses. Policy LU-1.3.1: The City will continue to provide incentives for commercial redevelopment and new construction in the Edison Center, Latin Quarter, Little Haiti, Little River Industrial District, River Corridor, Design District, Grand Avenue, Flagler • Page 3 Street, the River Quadrant, the Omni Area Redevelopment District, and Southeast Overtown/Park West (N.W. 3 Avenue) and other areas where such redevelopment will contribute to the improvement in the built environment. Such incentives may be offered through the building facade treatment program, Community Development Block Grant (CDBG) funds, and other redevelopment assistance programs. FINDING: The proposed Land Use and Zoning change will allow for increased densities and intensities that will be incentives for major redevelopment of aging and obsolete uses (printing plants and low rise office structures that block public access to the waterfront. Policy LU-1.3.5: The City will continue to promote through land development regulations, the creation of high intensity activity centers which may be characterized by mixed -use and specialty center development, particularly in, but not limited to, the Edison Center, Grove Center, Latin Quarter, Little Haiti, River Corridor, Design District and the Civic Center. The extension of commercial land uses along the entire length of significantly traveled roadways will be discouraged. FINDING: The existing Future Land Use designation of General Commercial restricts and discourages mixed uses and high density development. The proposed change will remove these limitations. Policy LU-1.3.7: The City will continue to use the City's Enterprise Zone and Tax Increment Financing district strategies to stimulate economic revitalization, and encourage employment opportunities. FINDING: The proposed changes will encourage higher value development that will generate substantial tax increment revenues to the Omni District needed to fund public infrastructure improvements. Objective LU-1.4: Continue the growth of Downtown Miami, expand its role as a center of domestic and international commerce, further its development as a regional center for the performing arts and other cultural and entertainment activities and develop an urban residential base. Submitted Into the public record in connection with item p2- 3f y on 11 - be, Priscilla A. Thompson City Clerk FINDING: The proposed land use change will promote residential and service retail uses that complement and strengthen the Performing Arts Center activities. Policy LU-1.4.1: The City will continue to identify special use districts and direct public sector regulatory, financial and promotional efforts toward reinforcing the identity and cohesiveness of each district. FINDING: The proposed change to the SD-6 special use district better serves the planned neighborhood and arts uses. The existing C-2 District is a highway strip • Page 4 commercial district that serves industrial and transportation related uses and is incompatible with the planned nature of the Omni / Performing Arts area. Policy LU-1.4.3: The City will continue to promote an active pedestrian sidewalk environment along the ground floor frontage of buildings on "pedestrian streets" through land development regulations. FINDING: The current Land Use and Zoning designations promote truck transportation and distribution activities that conflict with the desired pedestrian character of the area. The SD-6 District requires pedestrian amenities and spaces. Policy LU-1.4.4: The City will continue to support Miami -Dade County in construction of a regional performing arts center in downtown. FINDING: The proposed changes eliminate a liberal commercial use and quasi - industrial category that conflicts with the new Performing Arts Center. Policy LU-1.4.10: The City will continue to develop modifications to existing regulations with the intent of providing greater flexibility in the design and implementation of mixed -use developments within the general downtown area and particularly along the Miami River. FINDING: The proposed land use and zoning districts promote mixed uses and the existing land use and zoning districts restrict both mixed use and more flexibility in the design of high density development. Policy LU-1.4.12: The City will continue to implement the Downtown DRI development orders for downtown and Southeast Overtown/Park West, and seek approval for future increments of development in a timely manner. FINDING: The proposed land use and Zoning changes are consistent with the DRI Development Orders for the Downtown and the Omni Redevelopment Districts. Policy LU-1.5.1: Development orders in the city will be consistent with the goals, objectives and policies contained in the Natural Resource Conservation and Coastal Management elements of the Miami Comprehensive Neighborhood Plan. FINDING: The existing land use and zoning districts promote non -water dependent or related uses that are inappropriate for this waterfront site. The Proposed changes require development consistent with the Shoreline Ordinance and public access requirements for the Bayfront. Goal 3: Encourage urban redevelopment in identified Urban Infill Areas and Urban Redevelopment Areas. Submitted Into the public record in connection with item PZP2�y on 3L2 ° Priscilla A. Thompson City Clerk • Page 5 FINDING: The proposed land use and zoning changes are consistent with the Omni Redevelopment Plan which specifically promotes redevelopment in the Omni Redevelopment Area. Objective 3-1: Promptly review and act on petitions for land use plan amendments and rezoning of property in Urban Infill Areas or Urban Redevelopment Areas to facilitate redevelopment. FINDING: This proposed land use and zoning change corrects an incompatible land use condition that has existed in the area for over fifty years. The changes allow for greater infill densities and intensities to replace obsolete, incompatible, underdeveloped uses and vacant lands. Policy LU-3.1.2: Create Regional Activity Centers if appropriate in Urban Infill Areas and Urban Redevelopment Areas to facilitate mixed -use development, encourage mass transit, reduce the need for automobile travel, provide incentives for quality development and give definition to the urban form. The permitted uses and density and intensity of uses within a RAC shall be governed by the underlying future land use map designations of the subject property, except as otherwise limited by the designation of the RAC in the comprehensive plan. A designated RAC shall routinely provide service to, or be regularly used by, a significant number of citizens of more than one county; contain adequate existing public facilities as defined in Rule 9J-5, F.A.C., or committed public facilities, as identified in the capital improvements element of the City's comprehensive plan; and shall be proximate and accessible to interstate or major arterial roadways. FINDING: By promoting residential and mixed uses of high densities and intensities, the proposed changes promote use of mass transit and greater pedestrian activity in the area. Regional Activity Centers Regional Activity Center (RAC). A Regional Activity Center designation is intended to encourage and promote large-scale development and redevelopment as well as small parcel infill development and redevelopment that facilitates a balanced mix of land uses by providing maximum flexibility for development and redevelopment activities. In accordance with Chapter 28-24.014(10)(b)2, F.A.C., a Regional Activity Center in the City of Miami shall be a compact, high intensity, high density multi -use area designated as appropriate for intensive growth as an urban infill or urban redevelopment area by the City and may include: residential use; commercial; office; cultural and community facilities; recreational and entertainment facilities; hotels or motels; transportation facilities; utilities; and appropriate industrial activities. The major purposes of this designation are to facilitate mixed -use development, encourage mass transit, reduce the need for automobile travel, provide incentives for quality development and give definition to the urban form. • Page 6 Submitted Into the public record in connection with item P2. aE c} on 9, `J - .06 Priscilla A. Thompson City Clerk High Density Multifamily Residential: Areas designated as "High Density Multifamily Residential" allow residential structures to a maximum density of 150 dwelling units per acre, subject to the detailed provisions of the applicable land development regulations and the maintenance of required levels of service for facilities and services included in the City's adopted concurrency management requirements. Higher densities may be allowed as shown for these specially -designated areas: Little Havana Target Area 200 units per acre Southeast Overtown/Park West 300 units per acre Brickell, Omni, and River Quadrant 500 units per acre FINDING: The existing land use and zoning categories restrict residential densities to less than 150 units per acre. This is contrary to the Omni Redevelopment Plan which supports the proposed changes to Restricted Commercial and SD-6 zoning which allow for Comprehensive Plan designated densities of up to 500 units per acre. Policy HO-1.1.9: 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 Land Use Policy LU-1.1.10 and Transportation Policy TR-1.5.2.) FINDING: The site of the proposed land use and zoning change is abuts a Metromover Station at 15th Street and NE Bayshore Drive and will allow for high density residential uses within walking distance of regional mass transit service. Policy HO-1.1.10: The City will continue to develop policies and procedures, including the provision of zoning bonuses, which aid the private sector in assembling land for major residential projects, and develop informational programs that promote the awareness of redevelopment opportunities. FINDING: The proposed land use and zoning changes provide incentives for large scale redevelopment in the form of Major Use Special Permits that facilitate high density redevelopment. Goal HO-2: Achieve a livable city center with a variety of urban housing types for persons of all income levels. FINDING: The proposed land use and zoning changes encourage high density residential uses that make set -asides for affordable housing and diverse designs of housing units possible that are currently restricted by the liberal commercial zoning that currently discourages and limits residential uses. Objective HO-2.1: Achieve a livable downtown with a variety of urban housing types for persons of all income levels. • Page 7 Submitted Into the public record in connection with item PZ.3t-4 on Priscilla A. Thompson City Clerk FINDING: By allowing flexible site design and higher densities, the proposed land use and zoning districts support wide variation in unit size, orientation (street level, internal, view oriented, etc.) spatial configuration (loft, live -work, luxury, efficiency, townhouse, penthouse, etc.) and costs. Policy HO-2.1.1: The City will continue to protect and enhance existing viable neighborhoods by retaining existing residential zoning. FINDING: The subject site is bordered on the north and west by high density residential zoning. The current liberal commercial / quasi -industrial use provisions of the existing General Commercial category threaten existing nearby residential uses with incompatible activities and uses that undermine the neighborhood character. Policy HO-2.1.2: The City will continue to revise residential zoning district regulations to provide greater flexibility for the design and development of a variety of contemporary housing types and mixed -use development with the application of new higher density zoning. FINDING: The proposed SD-6 zoning district is tailored to support innovative building designs and diverse space -use configurations of residential space. Policy HO-2.1.3: The City will continue to assure that necessary support services, institutions and amenities are available to existing neighborhoods. FINDING: The General Commercial Use category that currently exists promotes regional transportation and industrial services. The proposed land use change to Restricted Commercial promotes neighborhood convenience services and essential goods vendors that serve residential uses. Policy HO-2.1.4: The City will continue to promote development of new, high quality, dense urban neighborhoods along the Miami River, in Central Brickell and in Southeast Overtown/Park West through Special District (SD) zoning. FINDING: The Omni Redevelopment area, which abuts the Southeast Overtown / Park West CRA. District complements this land use type with the SD-6 District for high density residential uses. Objective PW-1.1: Land development regulations will ensure that approval of development or redevelopment will not be granted unless and until there exists adequate potable water transmission capacity to serve that development. • Page 8 FINDING: All development orders must meet concurrency review. Submitted Into the public record in connection with item 1"z.34(4on 9-1- Peo' Priscilla A. Thompson City Clerk Goal TR-1: Maintain an effective and cost efficient traffic circulation network within the City of Miami that provides transportation for all persons and facilitates commercial activity, and which is consistent with, and furthers, neighborhood plans, supports economic development, conserves energy, and protects and enhances the natural environment. FINDING: The current Land Use and Zoning supports trucking and industrial distribution activities inappropriate for a high density residential district and pedestrian area. The proposed changes will promote use of the public mass transit system and pedestrian networks that interconnect public uses and residential and commercial activities. Objective TR-1.1: All arterial and collector roadways under County and State jurisdiction that lie within the City's boundaries will operate at levels of service established by the respective agency. All other City streets will operate at levels of service that are consistent with an urban center possessing an extensive urban public transit system and characterized by compact development and moderate -to -high residential densities and land use intensities, and within a transportation concurrency exception area (TCEA). The City will monitor the levels of service of all arterial and collector roadways to continue to develop and enhance transportation strategies that promote public transit and minimize the impacts of the TCEA. Submitted Into the public record in connection with item f z- t4 on a - n -Ob Priscilla A. Thompson City Clerk FINDING: All development orders must comply with transportation concurrency requirements at the corridor level. Policy TR-1.1.1: 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 and zoning classification of Conservation, as an Urban Infill Area pursuant to Miami -Dade County's designation of an Urban Infill Area lying generally east of the Palmetto Expressway and including all of the City of Miami. Within this area, the concentration and intensification of development around centers of activity shall be emphasized with the goals of enhancing the livability of residential neighborhoods and the viability of commercial areas. Priority will be given to infill development 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 standards set forth in Policies TR-1.1.2 and TR- • Page 9 1.1.3 of the Transportation Element of the MCNP. (See Land Use Policy LU-1.1.11.) FINDING: This proposed land use and zoning change will eliminate an incompatible district (General Commercial and C-2) that adversely effects livability of the adjacent SD-6 high density residential special district. 1.1.2.3: Where express bus transit and/or rapid rail transit service on minimum 20- minute headways is available parallel to and within'/a mile of the facility, the facility shall operate at no greater than 150 percent of capacity. FINDING: Both express bus and rail transit services exist within 150 feet of the subject site. Policy TR-1.1.13: New development in downtown shall be required to contribute its fair share toward the mitigation of regional roadway impacts as provided for by the Development Order implementing the downtown and Southeast Overtown/Park West Developments of Regional Impact. FINDING: All new development will pay impact fees to offset mitigation costs of development impacts. Policy TR-1.4.2: The City will develop a streetscape design program that will guide landscaping, lighting and construction of sidewalks and bicycle paths along city streets, and such improvements will be coordinated with major repairs and renovation of city streets. FINDING: The proposed SD-6 District requires compliance with the CRA redevelopment plan urban design standards. Policy TR-1.5.8: Prior to the submittal of the 2005 EAR, the City will amend its land development regulations and public facility improvements to ensure a stronger interface between the development or redevelopment of neighborhood activity centers and the public transportation system by establishing design guidelines for connectivity and transit infrastructure to be incorporated into the development/redevelopment. FINDING: The current Land Use and Zoning districts offer no incentive or standards that support public transit whereas the SD-6 District explicitly sets forth design guidelines embodied in the CRA Redevelopment Plan. Policy TR-1.5.12: The City, through its Intergovernmental Coordination Policies, will support Miami -Dade County in its implementation of individual projects in order to achieve the Regional objective to increase the average daily share of transit ridership by 30 percent of total person trips In addition, by the 2005 EAR submittal, the City will coordinate with Miami -Dade Transit to develop the appropriate data collection needs of transit ridership to ensure a baseline can be established to support the City's person -trip capacity level of service measurements and to support Miami -Dade Transit's efforts to • Page 10 Subn-iitted Into the public` record in cpnnect pn ith item on 91 c, Priscilla A. Thompson City Clerk improve transit services. FINDING: The change of Land Use and Zoning will increase densities and intensities of development that are needed to support transit services. Objective PR-1.1: Increase public access to all identified recreation sites, facilities and open spaces including the Miami River and beaches and enhance the quality of recreational and educational opportunities for all age groups and handicapped persons within the city's neighborhoods. FINDING: The existing Land Use and Zoning permits non -water dependent and non -water related uses. The proposed changes promote residential uses and commercial services in conjunction with expanded public shoreline improvements to enhance public access and use of the Bayfront. Policy PR-1.1.11: Where appropriate and in the interest of public safety and promotion of outdoor recreation opportunities on environmentally sensitive areas, future land development regulations will require non -water dependent or related development or redevelopment to maintain public access to the coastal and Miami River shorelines. (See Coastal Management Policy CM-2.1.1.) FINDING: The existing development of the subject site complies with the General Commercial and C-2 District historical standards and as such offers limited access to the Bayfront. The only means of correcting this historical deficiency is through redevelopment incentives which the proposed land use and zoning changes provide. Objective PR-1.4: Ensure that future development and redevelopment pay an equitable, proportional share of the cost of public open space and recreational facilities required to maintain adopted LOS standards. Submitted Into the public record in connection with item Pz.3� on °l= Priscilla A. Thompson City Clerk FINDING: All development orders will require impact fees to assure sufficient recreation facilities for the general pubic are provided. Policy PR-1.4.1: The City will continue to use developer contributions, including development impact fees, to help fund the cost of public open space and recreational facilities needed to serve new development or redevelopment. FINDING: The proposed changes will increase the standards for on -site recreational and open space amenities in addition to impact fees. Policy PR-1.5.6: As depicted in the Waterfront Master Plan and programmed in the CIE, the City will provide a continuous network of public parks and major attractions along the downtown waterfront. • Page 11 FINDING: The proposed land use and zoning changes will require water dependent and related uses that must incorporate public access to the waterfront and the provision of active use edges with retail services to enhance the pedestrian environment. Policy PR-1.5.10: The City will continue to encourage development of urban street promenade linkages with widened sidewalks, high quality materials, landscaping, lighting, graphics and furnishings. FINDING: The proposed change in Land Use and Zoning will provide incentives to replace the current development of the waterfront that blocks and limits public views and access to the waterfront. Policy PR-1.5.11: The City will continue to work toward improvement of the landscaping and pedestrian -oriented amenities along major boulevards, including Biscayne Boulevard, Brickell Avenue, and North 1 Avenue, to create distinctive images and unifying elements between downtown districts. FINDING: The proposed Land Use and Zoning changes will provide incentives to create pedestrian plazas and gallerias that extend the public street environment through private lands to the waterfront as proposed in the Redevelopment Plan for the area. Goal PR-3: Encourage the development of high quality cultural arts facilities and programs within the city. FINDING: Essential to the public enjoyment and participation in the Performing Arts Center. program of the area will be the redevelopment of surrounding blocks to provide retail and pedestrian oriented nightlife activities around the PAC halls that extend the public leisure and recreational experience. The proposed land use and zoning changes will promote such uses that are currently restricted. Objective PR-3.1: The city will continue to develop a clearly defined and functioning cultural arts district within the downtown area, and a world -class cultural performing arts facility is being built within the city and will be completed by the year 2001. Submitted Into the public record in connection with item?2. 3t. 4 on 61.1 -D(0, Priscilla A. Thompson City Clerk FINDING: The Omni redevelopment plan is specifically designed to promote a greater performing arts and entertainment district on adjacent blocks. The special district SD-6 is the primary mechanism for accomplishing this and is the proposed zoning for the subject site. Policy PR-3.1.1: Land development regulations within downtown permit and encourage the development of a cultural arts district within downtown as specified in the City's • Page 12 Downtown Master Plan, and the City will continue to support development of such a district. FINDING: As for Objective PR-3.1 Policy PR-3.1.2: The City supports Miami -Dade County in construction of the new downtown Performing Arts Center, which is being built in conformity with the Downtown Master Plan, and with appropriate shares of state, county and private sector funding. FINDING: The City has regulatory power over land development and can best support the PAC by assuring all new development proximate to it is compatible in use and design. The proposed SD-6 District is the primary means of accomplishing this. Goal CM-2: Ensure adequate public access to Biscayne Bay and the city's shoreline. FINDING: The redevelopment of the existing office structure which blocks views and access to the shoreline is a main goal of the CRA plan for the area. The incentives provided by the proposed land use and zoning changes will facilitate this. Submitted Into the public Objective CM-2.1: Prevent the net loss of, and, where record in connection with feasible, increase, physical and visual public access to item '1>2.on 9,1 - ob Biscayne Bay and the city's shoreline. Priscilla A. Thompson FINDING: The Redevelopment plan calls for the redevelopment of the subject City Clerk site to open access and expand public use of the waterfront and recommends the proposed land use and zoning changes as the primary means of encouraging this redevelopment. Policy CM-2.1.1: Where appropriate and in the interest of public safety, future land use and land development regulations will require non -water dependent or related development or redevelopment to maintain public access to the shoreline. (See Parks, Recreation and Open Space Policy PR-1.1.11.) FINGING: As for PR-1.1.11 Policy NR-3.2.2: Support those elements of the Miami -Dade County Comprehensive Development Master Plan that encourage the use of Metrorail and Metromover by directing high density new development or redevelopment first to areas nearest Metrorail and Metromover stations, and those land use policies that do not foster the proliferation of employment centers in the suburban areas of the county. (See Transportation Objective TR-1.5 and associated policies.) • Page 13 FINDING: The proposed changes in land use and zoning provide for a development framework of regulations that reinforce the designation of the area as a "Urban Central Business District" with high densities and mixed uses. Objective CI-1.3: Ensure that future development and redevelopment pay an equitable, proportional share of the cost of public facilities required to maintain adopted LOS standards. FINDING: All development orders must comply with provision of the costs of public facilities required to maintain adopted LOS standards. Submitted Into the public record in connecti•n with item .-z won q 11 04, Priscilla A. Tho pson City Clerk • Page 14