HomeMy WebLinkAboutAdditional Comments 03-5-08 and 3-19-08 - 3-31-08Additional Comments on the Draft EAR
Public Comment Consultant / City Response
March 5, 2008 Letter from Fran Bohnsack to Ms. Arva Parks
1 Goal CM-3: Provide an adequate supply of land for water I The City of Miami has made changes to the Coastal Management Element
dependent uses. pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
2 Objective CM-3.1: Allow no net loss of acreage devoted to The City of Miami has made changes to the Coastal Management Element
water dependent uses in the coastal area of the City of Miami, pursuant to Florida Statute 163.3178. None of these amendments were
including along the banks of the Miami River. precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
Policy CM-3.1.1: Future land use and development regulations The City of Miami has made changes to the Coastal Management Element
will encourage water dependent uses along the shoreline, pursuant to Florida Statute 163.3178. None of these amendments were
including the banks of the Miami River. precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
March 5, 2008 Letter from Eric Buermann to the PAB
4 Not Deleting Comp Plan "Policy PR-1.5.8: Expand the existing This comment has been addressed in Objective PR-2.2 and its related policies,
Jose Marti Park to provide additional recreational opportunities and has been broadened to include all existing parks and recreational facilities.
for the area's residents, workers, and visitors."
Concurring with City Commissioner Sanchez' recommendation
made during a public hearing regarding the EAR
recommended amendments to the Comp Plan, to insert City
support for citywide Water Taxi / Water Bus services within the
Transportation element of the Comp Plan.
Waterborne transportation has been addressed in Policy TR-1.5.9B.
Not deleting PR-1.4.1 and PR-1.4.2 regarding development
impact fees for parks and insert the EAR based amendment
for the sections.
As directed by the PAB and City Commission when
considering the EAR in December 2004, inserting
"Fisherman's Wharf' in PR-6.1.3 to become consistent with
PR-6.1.4.
8
This comment has been addressed in Objective PR-1.5 and its related policies.
The requested modification has been made in Policy PR-6.1.3.
March 5, 2008 Comments from Index Cards
Why is there not at least the skeleton of an Economic Addressed in the additional proposed Goals, Objectives and Policies submitted
Element? With a target date for completion? —Hadley to the City.
Williams
Future projected build out is where one predicts what a likely
density is for a given area. In other words, the number of
expected units per acre, for a precise area. This might be 10,
20, or 30 years into the future. Planning claims they cannot
yet, when I ask "why" since they did this and used the results
to support the streetcar, do they now tell me this cannot be
done? 5 months later, Planning has not answered this
This comment has been noted.
Page 1
10
Public Comment
question, I wrote them. Not quantifying projected densities
allows vague and too general policies. Quantifying, like
"future projected densities", allows the policies to too easily
accommodate special interest needs rather than interests of
the residents at large. So please ask Planning (1) why were
you recently able to create "projected future build outs", but
now claim this is "impossible" to do? —Richard Strell
When will a draft of the recommended "Historical and Cultural
Element" be available for review? —Unknown
11
Consultant / City Response
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City.
Why is the following not included in the Comp. Plan Policy
LU-1.1.5: "An applicant for a change in zoning or land use
regulation shall give notice of the application, of the decision
or recommendation of the planning staff, and of [illegible] of
the planned change subsequent to the decision or
recommendation to all property owners within 500 feet of and
registered neighborhood associations in the [illegible] adjacent
NET areas on the subject property." —Barbara Bisno
12
13
14
15
This language is appropriate for the City's Zoning Ordinance, not the MCNP
EAR -based Amendments.
The Central Business District (map on pg. 12) allows
"residential facilities...to a maximum density of 1,000 dwelling
units per acre..." The "high density multifamily residential"
designates "special -designated areas" (top of pg. 21) with 200,
300, and 500 units per acre. See the map on pg. 24.
Comparing the two maps, they are the same areas. Which
maximum density applies? —Hadley Williams
Reference #67 from "Actions Taken to Address Public Input"
refers to the Port of Miami River (not "the ports"). The action
taken refers to a different text amendment, not the EAR based
amendments. —Unknown _
My question was —you did it for the streetcar —why can't you
now? —Unknown I
Why is Transportation Policy TR-1.5.8(G) not in the Land Use
Element (pg. 53 bottom)? Cross-reference. —Unknown
16
The "Central Business District" designation permits 1,000 dwelling units per
acre regardless of where it is located. The Residential Density Increase Areas
apply only to the "High Density Multifamily Residential" designation and other
categories where the residential density is stated to be equivalent to this
category, which are presently "Major Institutional, Public Facilities,
Transportation, and Utilities"; "Restricted Commercial" & "Office".
This comment has been noted.
This comment has been noted.
Policy TR-1.5.8(G) reads as follows:
G. Residential development around a rapid transit station should have a
density of at least 15 dwelling units per acre (du/ac) within'/4 mile walking
distance from a station and 20 du/ac or higher within 700 feet of the station
at least 10 du/ac between'/4 and'% mile walking distance from the station.
Business and office development intensities around a rapid transit station
should produce at least 75 employees per acre within'/4 mile walking distance
from the station, 100 employees per acre within 700 feet, and at least 50
employees per acre between'/4 and '% mile walking distance from the station.
March 5, 2008 Comments from PAB Members
The Housing Element is missing some policies supporting I In response to this comment, the Economic consultant will follow-up with the
Page 2
and
Public Comment
Consultant / City Response
17
special needs housing.
What exactly is the minimum LOS in Policy LU-1.1?
18 In Policy LU-1.1.3, what is "divide or fragment"?
19
PAB member who made this comment.
This comment has been addressed in the Capital Improvements Element.
This comment has been noted.
March 6, 2008 and March 12, 2008 E-mails Between Brett Bibeau and Larissa Brown
BBibeau: Per your request last night, I'm emailing you the
following friendly reminder. Miami River Commission
respectfully recommends inserting "Fisherman's Wharf" into
PR-6.1.3 in order to become consistent with PR-6.1.4.
20
March 19, 2008 [Transcribed] Hand Wri
LU-1: Line 2 — Residential protection removed. Why?
Line 3 — Blighted or declining areas — what standards are used
to define (a) blighted (b) declining?
21
LU-1.1: Line 3 (LOS) and to the end — where are these
standards in the Capital Improvements Element? Please
show them to me.
22
LBrown: I took a look at the two policies you reference below. PR-6.1.4
mentions the Fisherman's Wharf concept for the riverside district, as it is a
reinstatement of the earlier PR-1.5.5 as requested by the Commission.
However, I interpret PR-6.1.3 as being about the park itself — the recreation
activities in the park, enhanced interpretive activities around the historic
buildings that have been moved into the park, and the idea of linking park
activities to the public spaces that will be part of "Lummus Landing" on the
river. I do not see a Fisherman's Wharf as being inside the park, so it doesn't
seem appropriate to me to include language on Fisherman's Wharf in that item.
Fisherman's Wharf was not included in the original PR-1.5.4 item that you
asked to be reinstated and whose language is exactly the same as the current
PR-6.1.3.
LBrown [second email]: I consulted with the Parks Department and they told
me that Lummus Landing will be owned and managed by them, which makes
me more comfortable about including the Fisherman's Wharf language in the
item as you requested. (The proposed Miami 21 CS zoning can cover both
publicly owned and privately owned spaces.) So, I don't see any problem with
including the language in PR-6.1.3.
tten Comments from PAB Member Nina West
Addressed in LU-1.2.1
LU-1.1.2: Lines 3 & 4 — Comment — please respond. Anything
can be consistent with a plan that has neither measurable
goals and objectives nor standards.
Definition of an established neighborhood.
Addressed in CI-1.2.2, CI-1.2.3
This policy includes the provision for monitoring progress as a means of
measuring the accomplishment of goals, objectives and policies as set forth.
Addressed in new policy LU-1.1.5.
23
LU-1.1.4: Why was this policy measure (10%) removed?
The policy has been structured to be broadly inclusive, allowing it to effectively
address multiple issues at varying scales. Quantitative means to determine the
effectiveness and accomplishment of issues at hand vary from problem to
problem, and do not necessarily prioritize current or pressing issues. For
example, ten percent performance standards for code violations such as weed
non -removal may not necessarily equate to the keeping of dilapidated and
unsecured structures.
Page 3
24
Public Comment
LU-1.1.11: Third DCA says no urban infill designation for
waterfront — please comment on how this court case affects
this policy along the river?
25
Consultant / City Response
This is a legal issue and within the purview of the City Attorney, not the MCNP.
LU-1.1.11: City of Miami per -person trip methodology is not
used in the rest of the U.S. and this method of counting
transportation impact has done nothing to improve traffic
congestions in the city.
You mention bicycle transportation as a way of alleviating
some auto traffic — but there is nothing in the CIP concerning
bike lanes downtown.
The City of Miami originated the person -trip methodology for the measurement
of local level of service on a transportation facility to address the multi modal
transportation infrastructure that characterizes the City of Miami. The
methodology was designed to address existing demand and capacity to move
people on the transportation system primarily using the roadway network and
the transit system, while other modes such as pedestrian and bicycle facilities
were also included to a lesser degree. The methodology was designed to
evaluate each transportation mode alone, or in combination with others, as
applicable to the particular transportation facility. The Miami Comprehensive
Neighborhood Plan (adopted as Ordinance 10544 on February 9, 1989)
established under Policies TR 1.1.2 and TR 1.1.3 that within designated
Transportation Corridors, the capacity of all transportation modes would be
used in the measurement of future, peak hour level of service standards. The
City of Miami "Methodology for Calculating Peak Hour Person -Trip Capacity"
was incorporated into the Transportation Element of the MCNP under Policies
TR 1.1.2 and TR 1.1.3 on January 24, 1991 (adopted as Ordinance 10832),
and was separately published as a report entitled "Transportation Corridors:
Meeting the Challenge of Growth Management in Miami', September 1990.
Multi -modal level of service standards which recognize transit service as a
function of the capacity of the transportation system) are adopted in many
counties throughout the State of Florida (i.e. Miami -Dade, Broward and Polk
Counties to name a few), however no other county or city in Florida has a
premium transit system similar to the combined effect of Tri-rail, Metro -rail and
Metro -mover, which makes the use of the person -trip methodology a viable
concurrency management tool for the City of Miami. The CIP is updated
annually. Policy TR-1.4.3 addresses the development of a streetscape design
program by the City to guide the placement of landscaping, lighting, sidewalks
and bicycle paths along City Streets in coordination with major repairs and
street renovations.
26
27
LU-1.3.10: This rare measurable goal in the MNCP [sic] is
removed. Why?
LU-1.3.14: Lines 4 and 5 — where are these "neighborhood"
design and development standards found in the code?
The policy has been structured to be broadly inclusive, allowing it to effectively
address multiple issues at varying scales. Quantitative means to determine the
effectiveness and accomplishment of issues at hand vary from problem to
problem, and do not necessarily prioritize current or pressing issues. Inclusion
of new language that requires annual reporting is an effective method to
measure policy success.
Addressed in the City of Miami Design Standards and Guidelines.
Page 4
Public Comment
28 Currently the only standards by "neighborhood" is [sic] the
NCD and historic requirements. Where are the standards for
Shenandoah and Little Haiti, etc.?
LU-1.4.4: Delete — performing arts center is built
Consultant / City Response
Policy LU-1.4.4 was stricken in lieu of this comment.
29
LU-1.4.8: This is elective enforcement — is this legal?
30
31
32
The policy is not selective, but covers a large number of properties in various
categories.
LU-1.4.10: Line 4, particularly along the Miami River— how
does this fit with recent 3R DCA rulings? _
LU-1.6.4: Line 5 — Where are these adopted minimum
standards to be found? Since many of our Trans. Corridors
have a standard of F — does this mean that auto traffic impacts
will not be [illegible] concerning these changes to the zoning
ordinance?
LU-1.6.8: This policy need not be here as it does nothing.
Please define "appropriate".
Encourage vs. require is an arbitrary decision. Fairness?
Equal treatment? Please explain.
This is a legal issue and within the purview of the City Attorney, not the MCNP.
Addressed in CI-1.2.3
The requested modification has been made in Policy LU-1.6.8.
33
LU-1.6.10: Line 4 — bicycles — we have no bicycle lanes
downtown — no money set aside in CIP Plan and do not
control county and state roads.
The CIP is updated annually. Co-ordination issue between City and County has
been addressed.
34
LU-2.4.3: Change public interest to public benefit. That is a
standard that is easily understood and can be met.
The phrase "public interest" was changed to "public benefit" to address this
comment.
35
36
37
38
LU-2.4.3: Return the number — do we own 9? How many do
we own?
LU-3: What is the point if the City defines itself as totally urban
infill? Does this mean encourage redevelopment everywhere?
LU-3.1.2: RAC is a new designation. These areas will have
high density and intensity and will require both green space
and open space. Please make this a requirement.
Page 12: UCBD Map — cannot read — please replace it with a
larger and readable map.
The number 9 was reinserted subsequent to the March 19, 2008 PAB
Workshop.
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City.
The requested modification has been made in Policy LU-3.1.2.
This map was improved to address your comments.
39
40
Page 14: RAC Map — need FLUM with these RA Centers
included — need large enough and colored and legible street
number boundaries.
Page 18: Paragraph 2 — eliminate the decision making of
Planning & Zoning Authority as well as the City Commission
concentrating all power in the hands of the Planning Director.
This map was improved to address your comments.
The Planning Director shall make a finding and the finding may be appealed by
specifying the grounds thereof and filing the appeal with an officer or agent
designated by the city manager. The officer or agent designated by the city
manager shall promptly transmit the notice of appeal to the zoning
administrator or the director of the department of planning, building and zoning,
Page 5
# Public Comment
Consultant / City Response
as the case may be. The officer from whom the appeal is taken shall forthwith
transmit to the zoning board all the materials constituting the record upon which
the decision appealed from was taken.
41
Page 18: Paragraph eliminates up to 25% of all public park
spaces by 25% - too much concrete.
42
Page 21: Paragraph 3 — Office — Line 5 — There is no standard
for "adequate" and this determination should be made by the
Planning Authority with the consent of the adjacent or
proximate existing residents who will be required to share their
existing services and amenities. Enormous FAR.
43
Page 21: Paragraph 4 — Major Institutional Public...etc. —
same comment as paragraph 3 — again enormous FAR
Revisions to the Future Land Use interpretation language were made that are
consistent with language in the parks master plan and clearly distinguish
between public park/recreation and commercial recreation areas. Previous
language allowed up to 0.65 FAR, which, since most building in parks is one-
story, allowed up to 2/3 of the area to be covered with buildings. The new
language provides for a 40% reduction while still preserving some flexibility that
is needed to encompass a system that includes small, urban parks where 25%
for a small support, recreation or cultural structure may be appropriate. The
parks master plan contains many recommendations on procedures to ensure
public participation in park design and improvements, so that the specifics of
each case can be taken into account. A policy document like the MCNP needs
to allow for some flexibility in specific implementation.
Addressed and also within CI-1.2.3
Addressed in CI-1.2.3
44
Page 22: Paragraph 3 — Restricted Commercial — same
comments as pg. 21, paragraphs 3 and 4
Addressed in CI-1.2.3
45 Page 24: Need legible map with legible boundaries
This map was improved to address your comments.
46
47
Page 25: Paragraphs 3 and 4 both work live and live work
should be allowed in Historic and Conservation neighborhoods
to encourage both preservation and adaptive reuse.
HO-1: Last line — The [sic] have a greater need for very low
income housing and this needs to be defined in some way.
This can be addressed in the proposed Historical and Cultural Element.
Addressed
48
49
HO-1.1: Due to limited resources the City need not fund high
end development amenities and capital improvements. This
category should pay impact fees.
The City does not fund, but creates an incentive program for affordable
housing.
HO-1.1.10: Please include very low and low income as
defined by HUD in each of these paragraphs.
The requested modification has been made in Policy HO-1.1.10.
50
HO-1.2.4: As an alternative to the "public sector provision" —
what is the current "public sector provision" and why is one
superior to the other? Why not use both?
The requested modification has been made in Policy HO-1.2.4.
51 HO-1.2.5: Please provide the definition that is referenced.
52
The requested modification has been made in Policy HO-1.2.5.
HO-1.5: Why "provide for" instead of "provide"? The City
should provide assistance for alternative housing close to
The requested modification has been made in Policy HO-1.5.
Page 6
Public Comment Consultant / City Response
public transportation. Development projects should be
required to include some of the displaced through
development regulation and should be required to contribute
financially to allow for relocation. Please comment.
53 HO-2.2.1: Please add in line 4 after "variety of urban housing The requested modification has been made in Policy HO-2.2.1.
types for persons of all incomes, especially those of low low
'sic] income". If you disagree — please explain.
54 SS-1.3.1: According to Miami Dade WASA actual measured There is more water input for irrigation, pool, and miscellaneous activities
consumption of City of Miami residents is 157 gallons per requiring higher water levels then sewer output levels.
capita per day. Why is the LOS standard for sewage
transmission lines only 100 gallons per capita per day?
55 SS-1.3.4: This policy should not be changed. Without City The City does not issue permits, WASA does. The City will monitor the
permits — we will not be able to monitor these impacts. If you permitting outside of the City boundaries as described in the policy.
do not agree — please state how you will acquire this important
knowledge.
56
SS-2: Reasonable protection is not defined — what would any The 2005 EAR does not require any modifications to this policy.
City [illegible] think is reasonable?
57
SS-2.1.1: Please define periodically, i.e. "every 3 to 5 years"
or whatever you believe is a reasonable period of time.
58
The 2005 EAR does not require any modifications to this policy.
SS-2.2.2: Last line — Please put in a number to measure what
they are doing now and what is the goal.
The 2005 EAR does not require any modifications to this policy.
59
60
61
SS-2: Line [illegible] — please define "reasonably protect".
What is the City's standard for reasonable protection in this
goal?
SS-2.1.1: Line 3 — periodically has no meaning — please put
time frame to fit with CIP budgeting and budget protections.
This was a criticism of the EAR by DCA — which was
supposed to be remedied by the CIP and CIP budget.
SS-2.1.3: Line one "concurrency management system" —
please provide a copy of the concurrency management
system for review.
The 2005 EAR does not require any modifications to this policy.
The requested modification has been made in SS-2.1.1.
The concurrency management system is laid out in Policy CI-1.2.2 and the
associated policies.
62
SS-2.2.1: Systems are deemed to be the only feasible
solution. What standard and methodology will be used to
make the determination? Are positive drainage systems
contemplated in the CIP budget and budget projections?
The 2005 EAR does not require any modifications to this policy.
63
SS-2.2.2: Line 2 "should be encouraged" does not constitute a
rational policy. Please amend this by deleting should be
encouraged and change to "will" plus time frame. Please
insert current frequency of cleaning and what the future
frequency we wish to attain. There should also be an
ordinance to fine business and home owners who sweep their
The 2005 EAR does not require any modifications to this policy.
Page 7
Public Comment
Consultant / City Response
sidewalk debris into the storm drains.
64
SS-2.2.6: Please explain the reason you do not require quality
The 2005 EAR does not require any modifications to this policy.
control structures in commercial parking areas. Parking lots
and garages produce enormous amounts of water pollutants
and should require these structures.
65
SS-2.4.1: What is the current impact fee charged for storm
water drainage and what percentage of the system is currently
financed by the impact fee? What percentage of the
construction, reconstruction improvement, and extension of
the storm water utility system will the City deem to be fair and
equitable in the future and what standard will be used to
compute this? Please insert the ordinance reference that
establishes this criteria into this MNCP [sic] policy section.
The 2005 EAR does not require any modifications to this policy.
66
SS-2.5.1: Please reference land development ordinance /
regulation that enforces the standard. Please provide this
ordinance / regulation to me.
The 2005 EAR does not require any modifications to this policy.
67
SS-2.6.2: Line 2 NPDES — please provide this permit
Paragraph 3 — please explain what you mean by this
paragraph
The 2005 EAR does not require any modifications to this policy.
68
AR-1.1.1: Last line — definition and standard for "cost efficient"
The 2005 EAR does not require any modifications to this policy.
69
AR-1.2: Line 3 — please define and give standard for adequate
The 2005 EAR does not require any modifications to this policy.
70
Page 40 — Potable Water— MNCP [sic] calls for water lines
with 200 gallon per person per day capacity, but sanitary
sewer capacity of 100 gallons per person per day — please
rectify this inconsistency or explain why 150-200 gallons in
only requires 100 gallon capacity out
There is more water input for irrigation, pool, and miscellaneous activities
requiring higher water levels then sewer output levels.
71
PW-1.2.1: Line 1 — please provide reference for Concurrency
Management System ordinance and provide same to PAB for
review.
The City has no "Concurrency Management"ordinance. The authority
underlying its concurrency management system is contained in its
Comprehensive Plan and land development regulations. The City is
incorporating additional concurrency management language through its school
concurrency amendments, recently adopted by the City.
72
SW-1.1.1: LOS standard — how was this arrived at and how
does this compare with cities of similar size?
The requested modification has been made in Policy SW-1.1.1.
73
SW-1.3.3: Please put a measurable frequency — what is done
now and what should be expected in the future. This impacts
water quality.
Currently the City conducts street sweeping seven days a week. The City is
broken down into zones. Each zone is swept between 2 to 3 times per week,
primarily at night. An additional frequency is to achieve approximately 100
person hours per week. Regular monitoring is conducted.
74
SW-1.4.1: Please put time frame such as "within one year will
evaluate, etc...."
Language could be incorporated to review on a regular basis.
75
I TR-1.1.1: Please provide a list of these major transportation
Major intersections are typically the intersections of the east -west and north -
Page 8
Public Comment
corridors with a legible map where the streets and cross
streets can be read. The existing FLUM shows a major
corridor running E& W (and in some areas N & S) every five
blocks. Allowing for buffer transactions as described in the
land use section — these SF neighborhoods will [illegible] to
exist. How do you respond to this comment?
Line 10 "major intersections" — please insert a legible map
showing these major intersections.
Second to last line — Per Person Trip Methodology — this
method of measuring traffic impacts is used in no other city of
our size in the U.S. This method of measurement should be
done away with as no development that has done a traffic
study has ever been shown to impact the current traffic — yet
most major roadways are impassable for more than 4 hours
each day.
The City has often promised they would use another method
and to respond to the EAR concerns at public meetings this
method should be replaced now.
Please ask the consultants to respond with alternate methods
used elsewhere for review by the PAB.
Consultant / City Response
south section -line and half section -line roadways. Major transportation
corridors are also typically those same section -line and half section -line
roadways. The City currently maintains a functional classification map to
categorize the local and regional roadway network, identifying State, County,
and local jurisdiction of roadways within the City of Miami, and to show
classification as an arterial, collector, or local street. We are currently working
with the City to update a map depicting the transportation corridors. Maps
TR-1 and TR-2 were prepared by the City during the EAR process as part of
the Transportation Element Data and Analysis (November 2004) to identify the
number of travel lanes and functional classification for all highways, major
roadways and local streets in the City of Miami.
The City of Miami originated the person -trip methodology for the measurement
of local level of service on a transportation facility to address the multi modal
transportation infrastructure that characterizes the City of Miami. The
methodology was designed to address existing demand and capacity to move
people on the transportation system primarily using the roadway network and
the transit system, while other modes such as pedestrian and bicycle facilities
were also included to a lesser degree. The methodology was designed to
evaluate each transportation mode alone, or in combination with others, as
applicable to the particular transportation facility. The Miami Comprehensive
Neighborhood Plan (adopted as Ordinance 10544 on February 9, 1989)
established under Policies TR 1.1.2 and TR 1.1.3 that within designated
Transportation Corridors, the capacity of all transportation modes would be
used in the measurement of future, peak hour level of service standards. The
City of Miami "Methodology for Calculating Peak Hour Person -Trip Capacity"
was incorporated into the Transportation Element of the MCNP under Policies
TR 1.1.2 and TR 1.1.3 on January 24, 1991 (adopted as Ordinance 10832),
and was separately published as a report entitled "Transportation Corridors:
Meeting the Challenge of Growth Management in Miami", September 1990.
Multi -modal level of service standards which recognize transit service as a
function of the capacity of the transportation system) are adopted in many
counties throughout the State of Florida (i.e. Miami -Dade, Broward and Polk
Counties to name a few), however no other county or city in Florida has a
premium transit system similar to the combined effect of Tri-rail, Metro -rail and
Metro -mover, which makes the use of the person -trip methodology a viable
concurrency management tool for the City of Miami.
Please note that in addition to the Person -Trip Methodology, the City of Miami
analyzed the vehicular only traffic conditions for the arterial and collector
roadway network (inclusive of the section -line and half section -line roadways)
as part of the EAR Process during the preparation of the Transportation
Page 9
Public Comment
Consultant / City Response
Element Data and Analysis (November 2004). As part of the development
review process, the City continues to require applicants to provide vehicular
only traffic analyses for portions of the City where transit service is not
rovided.
Policy TR-1.1.2.1 refers to the adopted level of service standard on roadways
where no transit service exists, so this policy does not reflect the PAB
member's written concern.
TR-1.1.2.1: Who walks % mile in July and August? The
elderly and very young cannot without exposing themselves to
serious health hazards. Transit must be '/ mile or less to be
accessible.
TR-1.1.2.2: Who walks % mile in July and August? The
elderly and very young cannot without exposing themselves to
serious health hazards. Transit must be mile or less to be
accessible.
The level of service standard provided under Policy TR-1.1.2.2 is consistent
with the adopted level of service standard maintained by Miami -Dade County
pursuant to page 11-11 of the Transportation Element of the Miami -Dade County
CDMP where the adopted level of service standard is 120% of capacity for
those roadways located parallel to and within % mile of a transit route which
operates with a minimum of 20 minute headways. _
TR-1.1.2.3: Who walks'/2 mile in July and August? The The level of service standard provided under Policy TR-1.1.2.3 is also
elderly and very young cannot without exposing themselves to consistent with the adopted level of service standard maintained by Miami -
serious health hazards. Transit must be mile or less to be Dade County pursuant to page 11-11 of the Transportation Element of the
Miami -Dade County CDMP where the adopted level of service standard is
150% of capacity for those roadways located parallel to and within % mile of
Commuter Rail or Express Bus transit service which operates with a minimum
of 20 minute headways.
Alternative transportation modes are mobility choices for all modes other than
the single occupant vehicle. Policy TR-1.4.3 addresses the development of a
streetscape design program by the City to guide the placement of landscaping,
lighting, sidewalks and bicycle paths along City Streets in coordination with
major repairs and street renovations. Map TR-6 was prepared by the City
during the EAR Process as part of the Transportation Element Data and
Analysis (November 2004) to depict existing bicycle facilities citywide. The City
is currently engaged in a Bicycle Facilities Study to enhance bicycle
connectivity.
This comment is noted.
accessible.
TR-1.1.4: Line 10 — incentives for alternative transportation
modes. Question (1) What are these? (2) If bicycles are used
as an alternative — where are the provisions planning and
funding for bike lands in downtown?
TR-1.1.8: New garages both City owned and [illegible] be
required to be built with storm water retention structures for
run-off to protect the potable water supply from the bay and
keep pollutants out of the rivers.
TR-1.1.15: Line 4 — what method / standard will be used to
define "appropriate"? Who will make this determination?
TR-1.4.1 and TR-1.4.2: [These policies] are inconsistent
The City is authorized to manage the downtown parking supply pursuant to
Section 14-182 (b), (c), (d) and (e) of the City Code.
These policies are not inconsistent. TR-1.4.1 addresses the prevention of
impacts to city residential streets as the indirect result of County or State
roadway improvement projects. TR-1.4.2 reflects the general state policy to
protect the interregional and interstate functions of the FIRS roadway system
by encouraging local traffic to use alternatives to this system consisting of 1-95,
Page 10
# Public Comment
83
TR-1.4.5: Please include in line 6 after the word "street", and
local residents and Homeowner Associations.
Consultant / City Response
I-395/SR 836, I-195/SR 112, and SR 826 within or adjacent to the City of
Miami. Use of other state roadways and county roadways would be the
alternatives to the FIRS system.
The requested modification has been made in Policy TR-1.4.5.
84
85
86
TR-1.5: After the word "service" in line 8, add "and will provide
local circulator service to feed Miami -Dade County transit
stops."
The Objective as proposed gives the City and the County the flexibility to
determine the appropriate transit mode needed to service a particular transit
demand, and the City has the ability to "support" the County in the provision of
transit service through direct participation or planning as they are currently
doing with various projects throughout the City (ie. in the development of local
circulator service for the Health District and in the development and design of
the Miami Streetcar).
TR-1.5.1: After modes line 4, add "and will provide circulator
service in areas where the population is transit disadvantaged
and will encourage and provide [illegible] money for start-up
private jitney services in all areas of the City to encourage the
use of mass transit and reduce dependence on individual
automobile use especially in the downtown core and along
existing densely populated corridors."
TR-1.5.2: Line 5 on page 52 — after protecting adjacent
neighborhoods from incompatible development add in height,
density, intensity, use, and scale.
The policy has been modified to add a portion of the requested changes, while
maintaining the flexibility to respond to improved connections between transit
modes without dictating the specific type of mode. Policy TR-1.5.9A addresses
private jitney transit services.
The requested modification has been made in Policy TR-1.5.2.
87
88
TR-1.5.7: Line 6 — Southeast Bayshore Drive to Metromover —
since SE Bayshore Drive is already connected through bus
service and this is a stable residential area. This upgrade of
service will encourage increased density and will [illegible] the
surround stable neighborhoods in Coconut Grove. Land use
regulations in this area should not be changed to increased
densities. Please delete Bayshore Dr. Funds for planning
and increased mass transit are scarce and should be used in
areas where the residents are transit disadvantaged.
This policy also supports increased residential densities in the
area of Mercy Hospital and the Catholic High School next
door. I am sure the Catholic church will be happy to sell their
properties as soon as the density is increased.
TR-1.5.8.G.: These densities will obliterate Silver Bluff, Golden
Pines, and parts of North and Central Coconut Grove to name
a few neighborhoods. What, if any, protections are you
offering these property owners? How will this affect their
quality of life?
Based upon a further review of the PAB member's comment, the reference to
Southeast Bayshore Drive to Metromover refers to connectivity in the Brickell
area of Downtown Miami, between Southeast Bayshore Drive and Metromover,
and does not refer to Coconut Grove from Bayshore Drive to Metrorail. While
the requested modification was made in Policy TR-1.5.7 in the MCNP
document dated 3-24-08, the change should in fact not be made.
TR-1.5.8.G identifies residential density and employment standards that are
intended to promote pedestrianism and transit usage through the design review
of projects located at and around rapid transit stations. These standards are
not meant to conflict with other underlying land use policies such as the
proposed modifications to LU-1.1.11 or TR-1.1.1 where the protection of single
Page 11
Public Comment
How many square feet per employee are you [illegible]? How
does a City [illegible] figure out how big each office building
will be?
Consultant / City Response
family residential is established as a priority.
89
TR-1.5.11: Line 2 — delete seek (another qualifying word with
no standard)
The requested modification has been made in Policy TR-1.5.11.
90
TR-1.5.12: Why should the taxpayers money be used to pay
for very expensive consultants to develop weekday peak hour
transit ridership data to ensure that a baseline can be
established to support the City's per person trip methodology
when we should be counting vehicles per trip as is done
everywhere else. Please comment.
This policy has been misunderstood by the PAB member. Miami -Dade Transit
collects and maintains the ridership data, and the policy modifications have
been drafted to ensure that the City coordinates with MDT to obtain this
information so that it can best be used by the City to quantify existing ridership
using the transit system during peak travel hours (ie. morning and evening rush
I hours).
91
TR-1.7.1: This policy has not been adhered to in the past. Will This comment has been noted.
it be in the future?
92
TR-1.8.2: Line 3 — Why 5 years? Could it be a longer period of
time?
I The five year time frame corresponds to other planning horizons in the region
such as the update to the MPO Long Range Transportation Plan which occurs
every five years.
93
PA-1.1.2: Line 2 - By changing the language from ensure to
encourage the City is once again failing to commit to
economic improvement for the Port. The Port competes
w/other ports — especially in Ft. Lauderdale and failure to
ensure an adequate amount of commercial and industrial land
puts the City at an economic disadvantage.
This is a legal issue and within the purview of the City Attorney, not the MCNP.
94
PA-1.1.3, PA-1.1.4, and PA-1.1.5: Removal of these policies
will detract from the economic viability of the Port. Please
have the economic consultant respond.
This is a legal issue and within the purview of the City Attorney, not the MCNP.
95
PA-3.1.1: residential uses are incompatible with industrial port
uses and will destroy the economic viability of marine port
uses. Please have the economic consultant respond.
This is a legal issue and within the purview of the City Attorney, not the MCNP.
96
PA-3.3.1: Please delete new language as this weakens the
authority of the Miami River Commission which has been
constituted by the State of Florida to protect the river and its
marine industry.
This is a legal issue and within the purview of the City Attorney, not the MCNP.
97
Page 61: Parks Recreation Open Space
Please add green space to title.
In planning practice, "green space" is not a separate entity from parks,
recreation and open space but included within those categories.
98
Goal PR-1: Add green space to objective after open space
In planning practice, "green space" is not a separate entity from parks,
recreation and open space but included within those categories.
99
PR-1.1.3: Please put this policy back into the MNCP [sic].
Addressed in PR-1.5 and PR-1.5.1
100
PR-1.1.6: Why has this policy been removed?
Addressed in PR-3.3. and PR-3.3.2
101
Objective PR-1.1.1: [sic] Why will this objective require 7 years
to be met?
Assuming that Objective PR-1.1 is the subject of the questions (not Policy
1.1.1) — acquisition of land and establishment of parks in underserved areas of
Page 12
# Public Comment
102
103
PR-1.1.1: Why were the words "in principle" not deleted from
the Parks Master Plan when the City Commission agreed to
and voted to delete these words when they unanimously voted
for the Parks Master Plan? Please correct this oversight now.
PR-1.1.2: Please distribute copies of these maps — Please
have legible copies
104
PR-1.1.4: I strongly object to green and open space being
reduced by up to a total of 25% when we have so few acres
per person available in the City. This would reduce the LOS of
1.13 acres per person 1000 residents to 0.85 acres per 1000
residents of open recreation and green space.
105
106
PR-2.1.1:
Consultant / City Response
an urban area takes coordination, the ability to take advantage of market and
other opportunities, and, after land is acquired, time to design and establish the
parks.
This is not a comprehensive plan issue.
The maps are in Chapter 5 of the Parks and Public Spaces Master Plan and
also in a separate, large -format appendix prepared for the final plan document.
The PAB received a draft version of the parks master plan which contained
these maps and voted to approve it. The final plan has been available online
and continues to be online at www.miamiparksplan.org, which can be accessed
through the city web site as well.
All park systems have some parks that include buildings to support use of the
parks and a number of highly -regarded urban park systems include museums
and other cultural assets, from San Diego to New York. For the purposes of
comprehensive planning, LOS includes all park acreage, including buildings
and parking lots, as well as open/green space. This policy does not refer to a
25% lot coverage rule. That reference is from the revisions to the MCNP
section on interpretation of the future land use map. A brief discussion of the
rationale for those revisions is provided at Comment 54 above.
The parks master plan recommends an LOS measure based on access and
funding rather than on acreage, an approach that is more appropriate for urban
park systems and increasingly used by park planners, but is not easily
incorporated in the traditional concurrency systems arising from the suburban
development model that underlies the Florida concurrency system. This policy
is in the MCNP to provide for a short period (until January 2009) to devise a
way to use the new access- and funding -based LOS as a concurrency
measure that will provide criteria and a mechanism for private sector
developers to show when the LOS requirement for parks has been met..
Cultural facilities bring a net loss of green and open As noted earlier, all park systems include some buildings and impervious
space and this policy does not limit their footprint by a surfaces on parks. This policy focuses on eliminating the use of park land for
percentage number which might be more than an acceptable municipal or other purposes that are not related to recreation or culture. It
number to the residents. establishes the principle that the stock of public park land will not be diminished
by non -park uses and that the amount of building will be limited. As a policy
matter, specific limitations are not suitable in this section and should be
resolved in zoning or other ordinances (e.g., conservation land should have
greater use limitations than other types of park land).
The procedures referenced in this policy, as described in the parks master
plan, provide for an alternatives evaluation process for any proposed
PR-2.1.1: Line 6 and 7 - Please change to public referendum
as public procedures may not be even include a vote by the
Page 13
Public Comment
City Commission
Consultant / City Response
conversion of public park land; public hearings by the PAB, the proposed new
Parks and Recreation Advisory Board, and the City Commission; a
supermajority vote of the Commission; and replacement of park land taken for
other uses by land of similar conservation, park or recreation value. This is a
more rigorous process than public referendum.
107
PR-2.2.3: Please add and until sundown in the summer at
least 2 weekday evenings per week so working parents can
bring their children to swim.
108
PR-3.2.4: Please explain? How will this be enforced?
109
110
PR-3.2.9: Please provide the Master Plan for review. With
appropriate legible maps.
This level of detail is not suitable for a comprehensive plan policy statement.
PR-3.2.10: Please add including access to private parking
garage at fees that are comparable to those established by
the Miami Parking Authority throughout the City.
111
112
PR-3.2.11: Line 4 — change those developments that require
to all development and redevelopment will require.
This is currently enforced on the downtown stretch of the Miami River by the
public setback requirement that is part of the permitting process and would
similarly be enforced through zoning and permitting requirements for future
development of non -water dependent uses. Enforcement of public access after
construction has to be through periodic monitoring of the space to see that it
has not been privatized, which can be promoted by requiring signage to notify
users that these are public spaces.
As noted earlier, the PAB received the draft plan and the final plan is available
at www.miamiparksplan.org.
This should be addressed through agreements with the developer/parking
operator.
This language comes from the previous plan and was not recommended for
change under the EAR process. The only new language is the last sentence
about monitoring for continued public access.
PR-3.2.11: Line 6 — after Policy CM 2.1.8 add before a
building permit will be issued.
The point of this sentence is that monitoring should occur after permitting and
construction so that private uses and barriers do not begin to creep into the
public space.
113
PR-4.1.2: Line 3 Add and scientific polling surveys every 5
years (since the EAR cycle is 7 years by FL statute)
Assuming this is for PR-4.1.1.: Changes made. Policy PR-4.1.1: The City will
use participant evaluation surveys at the completion of recreational programs
to evaluate program success, and online public opinion surveys at least once
every three years and scientific surveys at least once every seven years to
identify needed and desired programs.
114
PR-5.1.3: Line 4 after publicly available add and a process for
public comments by the residents of the City.
Addressed in PR-5.2.1 where a new Parks and Recreation Advisory Board is
described with the role of advising on capital plans and designs, which would
occur in a public forum with public comment.
115
PR-5.1: After facilities add and City residents and City
residents [sic] neighborhood parks
Assuming that the comment is on PR-5.1.4: This policy is about making sure
that, among other things, "groups that sponsor programs that use City facilities"
contribute appropriately (with funds or otherwise) for their use of facilities that
are paid for by the city for public use. For example, privately sponsored sports
leagues use fields that the city maintains.
116
PR-5.2.2: Line 3 Change five to three. If a program is not
working after 3 years, it should be eliminated.
Changes made. Policy PR-5.2.2: The City will survey City residents to monitor
preferences, needs and satisfaction with the park system on a regular basis, at
Page 14
Public Comment
Consultant / City Response
117
PR-5.2.3: Line 1 after develop add implement. We have had
many plans developed which are settling gathering dust all
over this City. Plans w/no implementation in a timely fashion
need expensive revisions or are re -done.
118
PR-5.2.4: Line 3 0 delete 'ideally'.
minimum through evaluations of all recreational programs by program
participants to evaluate program success; online public opinion surveys at least
once every three years; and scientific surveys every seven years (starting from
the Parks Master Plan survey of 2006).
This comment has been noted, and will be addressed in the next draft.
The requested modification has been made in Policy PR-5.2.4.
119
PR-6.1.2: Please provide Virginia Key Master Plan for review
120
PR-6.1.4: Please define "Cafe District" and this currently in
1100? Define "marine service center'.
121
PR-6.2.1: Line 2 after materials add shade trees 4" dia
[illegible].
122
The Virginia Key Master Plan is available online at
http://www.edsaplan.com/VirginiaKey/home.html
City to respond.
Changes made. Specific dbh size is not suitable for a policy document. Policy
PR-6.2.1: The City will continue to encourage development of urban street
promenade linkages with widened sidewalks, high quality materials, shade
trees, landscaping, lighting, graphics, and furnishings.
Page 75: Purpose of this map?
The map has a red line through it — it is deleted in the amended version
123
Goal CM: After of natural resources add especially water
quality
124
125
CM-1.1: After Little River add the stormwater outfall of
Biscayne Bay
The City of Miami has made changes to the Coastal Management Element
pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
The City of Miami has made changes to the Coastal Management Element
pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
CM-1.1.2: Sentence # 2 on line 3. Who determines the need
for positive drainage system — What authority and by what
criteria? What is budgeted for this now?
The City of Miami has made changes to the Coastal Management Element
pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
126
CM-1.1.3: Line 2 Please describe the "committee" Does this
committee have a name — who are the members?
Infrastructure improvements funding is not adequately
addressed. The City is responsible for all storm water sewers
— where is this addressed in the CIP budget? This is not a
County function.
127
The City of Miami has made changes to the Coastal Management Element
pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
CM-1.3: Please define 1. blighted, 2. declining, 3. threatened.
What are the standards used for each?
128
CM-2.1.1: Line 4 after access should be added with bay walks
The City of Miami has made changes to the Coastal Management Element
pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
The City of Miami has made changes to the Coastal Management Element
Page 15
Public Comment
and open space
Consultant / City Response
pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
129 CM-4.1.2: Add including all current and any future FEMA
regulations
The City of Miami has made changes to the Coastal Management Element
pursuant to Florida Statute 163.3178. None of these amendments were
Lprecipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
130
CM-4.1.5: Who will perform this analysis? And the review?
And who will be responsible for enforcement? Please
incorporate ordinance reference.
131 CM-4.1.9: What is the current evacuation plan and where can
it be found. Please reference the current plan.
The City of Miami has made changes to the Coastal Management Element
pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
The City of Miami has made changes to the Coastal Management Element
pursuant to Florida Statute 163.3178. None of these amendments were
precipitated by the EAR and are therefore outside the scope of the EAR -based
Amendments.
132
NR-1.1.2: Line 4 and 5. Please reference by ordinance or
regulation.
This comment has been noted.
133
NR-1.1.6: After net loss of public access add and public use
The requested modification has been made in Policy NR-1.1.6.
134
NR-1.2.4: line 6 "feasible". Please provide a standard for The 2005 EAR does not require any modifications to this policy.
feasible or delete this modifier.
March 19, 2008 Recorded Comments from PAB Chairperson Arva Parks
135
Include a 1-2 year time frame for adopting an Economic Addressed in the additional proposed Goals, Objectives and Policies submitted
Element and a Historical and Cultural Element into the MCNP. to the City.
136
Define "neighborhoods" and create a map showing the
neighborhoods. This map should go into a Historical and
Cultural Element.
137 Please review the Urban Infill designations.
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City.
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City.
138
Not all corridors are the same. Not every corridor needs high
densities.
This comment has been noted.
139
Please review the intensities in residential neighborhoods.
Chapter 9J-5, FAC, identifies the need for establishment of standards for
densities or intensities of use for each future land use category. The City's
interpretation is to maintain densities measures for residential land uses and
intensity measures for non residential land uses. Measures are also identified
in the City's Zoning Ordinance.
140 Include definitions, standards, and specific time frames.
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City under Goal LU-5.
141
Provide the public with periodic updates of what has been
accomplished in Miami.
142 The changes to the Major Institutional, Public Facilities,
This comment has been noted.
It unclear how the changes to the Major Institutional, Public Facilities,
Page 16
Public Comment
Transportation and Utilities section violate the spirit of the so
called Grovenor Ordinance that was passed unanimously by
the City Commission and the Planning Board.
Consultant / City Response
Transportation and Utilities violate the spirit of the Grovenor Ordinance, as the
last paragraph in the subject -section clearly establishes a link to the Zoning
Ordinance and states that all development shall be subject to the detailed
provisions of the applicable land regulations.
The types of implementing requirements in the "Grovenor Ordinance" are
typically detailed in the Zoning Ordinance. The MCNP provides the City's land
planning policy framework. The Zoning Ordinance implements the detailed
requirements.
March 19, 2008 Comments from Karen McGuire, AICP for Miami Neighborhoods United
143
Objective 1.1: This policy assumes that the City is an entire
urban center. How can the City effectively monitor when the
person trip methodology is double dipping E+ J20 E+ J50 and
additionally ramping up the vic ration. VIC = V * 1.41C*1.6 An
additional policy should be in place to evaluate the efficacy of
the person trip methodology. The City had said that a study
would be done regarding the Vehicle occupancy rate. Kittleson
had reported it to be 1.2. Therefore the 1.6for capacity seems
arbitrary.
The City is currently re-evaluating the vehicle occupancy standards utilized in
the Person -Trip Methodology. Alternative standards were utilized by the City
during the EAR Process as part of the Transportation Element Data and
Analysis (November 2004), and these standards were subsequently updated
by FDOT during their review of the City's Person -Trip Methodology and the
EAR. The vehicle occupancy standard developed by FDOT reflects a rate of
1.23 persons per vehicle for existing occupancy developed using travel
characteristics from the 2000 census data (compared to 1.4 persons per
vehicle resulting from surveys conducted by the City in 1989). The practical
capacity of the private vehicle is still under review by the City. Standards for
vehicle occupancy are being developed in coordination with FDOT.
144
Policy: 1.1.1. Question: How will Redevelopment of Corridors
be encouraged to be located at major intersection of
Commercial Corridors. How will this be achieved? A target
date for review of single family status should be inserted. Ten
years?
The underlying land use on the Future Land Use Plan map identifies those
locations at major intersections where non-residential development is
permitted. Single-family is protected pursuant to the language proposed under
TR-1.1.1.
145
146
147
Policy: 1.1.2 This policy is confusing. The methodology should
be expressed more clearly. E+ 100% of person trip
methodology where no Mass transit exists. (The person trip
should be explained within the document and not just
reference the other document)
Policy: 1,1,2,2 [sic]: The policy should read --Where bus transit
exists with transit service with minimum 20 minute headways
within 114 of the facility shall operate at no greater than 120
%. (No one walks a half a mile to a bus)
The policy is clear. The adopted LOS standard is E (at 100% of capacity)
unless other provisions apply pursuant to TR-1.1.2.2, TR-1.1.2.3 and TR-1.1.3.
Policy: 1.1.2.3 States that "Where express bus transit and or
Premium transit service on minim 20 minute headways is
available parallel to and within 1/2 mile of the facility the facility
shall operate at no greater than 150%.". An express bus that
The level of service standard provided under Policy TR-1.1.2.2 is consistent
with the adopted level of service standard maintained by Miami -Dade County
pursuant to page 11-11 of the Transportation Element of the Miami -Dade County
CDMP where the adopted level of service standard is 120% of capacity for
those roadways located parallel to and within % mile of a transit route which
operates with a minimum of 20 minute headways.
The level of service standard provided under Policy TR-1.1.2.3 is consistent
with the adopted level of service standard maintained by Miami -Dade County
pursuant to page 11-11 of the Transportation Element of the Miami -Dade County
i CDMP where the adopted level of service standard is 150% of capacity for
Page 17
Public Comment
Consultant / City Response
148
sits in the same traffic as other vehicles and does not have
designated right-of-way is not premium transit. Beside that the
1/2 mile allowance at E+ 150 should just be around the
stations, or express bus stops with designated right of way not
along the entire line.
Policy: 1.1.3.3 FIRS and SIS within the City limits should be
identified. What are the performance measures and strategies
for protecting these facilities? Map should be included LOS
MAP for entire City should also be included.
those roadways located parallel to and within % mile of Commuter Rail or
Express Bus transit service which operates with a minimum of 20 minute
headways.
Map TR-3 was prepared by the City during the EAR Process as part of the
Transportation Element Data and Analysis (November 2004) to depict the
limited access facilities citywide inclusive of the FIRS and SIS facilities. Map
TR-8.1 was prepared by the City during the EAR Process as part of the
Transportation Element Data and Analysis (November 2004) to address
vehicular level of service.
149
Policy: 1.1.4 This policy states that the City will continue to do
studies regarding multimodal transportation etc. Performance
measures and target date need to be are provided, such as
the following:
A sidewalk inventory will be undertaken by June 2009. Current
sidewalks are at 80% of neighborhoods. The City will improve
2% per year.
Ridership and bus loadings are at 80% of capacity at peak
hour Ridership will be increased within the City by 3%
annually, through the promotion of TDM strategies and in
cooperation with MDT The City will cooperate with MDT to
provide an annual status report.
The comment is noted. The City has already prepared or partnered in the
following specific neighborhood studies, each with their own set of
recommendations and implementation measures.
• Coconut Grove Area Traffic Study
• Health District (Civic Center) Implementation Plan
• Health District Comprehensive Traffic Study
• Orange Bowl Traffic and Parking Assessments
• Flagler Street Marketplace/Flagler Street two-way conversion
• Miami Downtown Transportation Master Plan
• Watson Island Traffic Master Plan
• Miami River Multimodal Corridor Study (prepared for the MPO and the
Miami River Commission with the City of Miami)
• Miami River Greenway Plan
• Miami Design District -Little Haiti District Planning Study/Master Plan
• Miami Design District Design Guidelines
• NE 36th Street Traffic Study prepared for the MPO with involvement
from the City of Miami
• FEC Corridor Master Plan (includes the Buena Vista Yard, now
Midtown Miami)
• 1-395 Project Development & Environment (PD&E) Study (more
analysis underway)
• NW/NE 79th Street Livability Study (completed) and PD&E Study (not
completed)
• Flagler Street PD&E Study
• DuPont Plaza Traffic Circulation PD&E Study (more analysis
underway)
• Brickell Avenue PD&E Study (completed)
• Overtown (Dover Kohl) Master Plan
Page 18
Public Comment
150 TR 1.1. 9 Need performance measures to ensure that
transportation Control measures are effectively providing
transportation alternative to vehicles and that the needs of
business and residents are not being negatively effected.
Consultant / City Response
Section 14-182 (d) of the City Code already includes a monitoring and
compliance procedure and obligation for the Transportation Control Measures
Plan.
151
152
TR 1.1.11: Where is the current parking study? This should be
in place by the time of the EAR amendments. This baseline
report shows how effective TDM policies have been
TR 1.1.12: Peak hour Ramp loading should be part of this
analysis
The comment is noted.
The comment is noted.
153
TR 1.1.13 When should new development throughout the City
be subject to transportation mitigation fees? Is this
proportionate share which only applies to the Downtown DRI
or is this a new impact fee? If the whole area is a TCEA aren't
the developers exempt from mitigation fees? What about
instituting a transit fee on high density transit corridors?
154
All development located within the City of Miami is subject to the payment of
transportation impact fees to Miami -Dade County. Development located within
the Downtown Miami DRI and the SEOPW DRI are also subject to the payment
of Transportation Mitigation Fees as outlined in Article 13 of the City Code and
as mandated by each of the two DRI approvals. Developments located within
the TCEA are not exempt from the payment of fees. In fact, the City of Miami
assesses impact fees for all effected properties pursuant to Section 13-6 of the
City Code.
TR: 1 1.19 As part of the multimodal initiative the City should
do a sidewalk, bike path and connectivity analysis to see
where there are existing deficiencies and what the existing
connectivity to transit within the buffer parameters may be and
how barriers or degraded facilities can be removed or
improved. Performance measure should be applied with
reporting timeframes. Ex. The City shall conduct a connectivity
analysis to gauge the existence of sidewalks and roads that
connect with the designated buffer for public transportation.
This study will be done by _ and updated biannually.
155
156
Map TR-6 and Map TR-7 was prepared by the City during the EAR Process as
part of the Transportation Element Data and Analysis (November 2004) to
depict existing bicycle and pedestrian facilities citywide. Existing bicycle level
of service and existing pedestrian level of service also was calculated using the
FDOT methodology from the 2002 Quality/LOS Handbook, and was presented
in Map TR-9 and Map TR-10. The City is currently engaged in a Bicycle
Facilities Study to enhance bicycle connectivity.
TR-I.1.20 Are PTP funds and traffic impact mitigation fees only
to be provided for the RAC. What about other high density
areas that may develop in and along transit Corridors? Will
these also be eligible for impact and PTP funds?
Objective TR-I.2: Identify transportation development
Corridors in Conjunction with MD County to determine where
high density growth is anticipated and to determine whether
additional right of way requirements should be instituted for
provision of multimodal infrastructure such as designated bus
lanes, additional sidewalk widths 12', bike or service lanes.
PTP funds are not only provided for the RAC, however Policy TR-1.1.20 was
specifically drafted to support the Buena Vista Yards RAC and to specifically
address the resources to support the infrastructure to serve the RAC.
These issues are addressed under TR-1.2.1, TR-1.2.2, TR-1.7.1 and TR-1.7.2.
157
Objective TR. 1.4: Parking analysis should also be included.
Parking is addressed under TR-1.1.8, TR-1.1.9, TR-1.1.10, TR-1.1.14, TR-
1.1.15 and TR1.1.16.
158
Policy TR 1.5.3 What about a park and ride facility with
Structured Parking. Need to provide info how the effectiveness
Structured parking serving Metro -rail already exists in the Health District, and is
planned for the Civic Center area. Stakeholders are presently working with the
Page 19
159
Public Comment
of these strategies will be evaluated.
TRI. 5. 6 Please reevaluate the "premium transit" definition.
Consultant / City Response
City of Miami and the MPO to evaluate areawide transportation issues,
strategies to maximize transit ridership, strategies to improve pedestrian and
transit corridors, local circulator transit service, Miami Streetcar connections,
streetscape improvements and regional transportation access.
Premium transit is the terminology used by the MPO in the adopted Miami -
Dade County Year 2030 Long Range Transportation Plan to address a wide
range of urban commuter rail, BRT or light rail transit systems.
160
Policy TR-1.5. 7 All public transportation systems are
addressed but the most "premium" is omitted, which is the
FEC corridor line which should be on top of the city's list. This
line will provide premium service From Palm Beach County to
Downtown Miami.
161
Policy TR-1.5.7 has been modified to include the FEC Corridor connection to
Downtown.
TR-1.5.8 F. Car servicing businesses should be added such
as carwashes and auto repair.
This comment is noted, however one perspective on car servicing businesses
and auto repair is that if these uses are located within '/4 mile of a rapid transit
station, then patrons can drop off their cars for repair, and take transit to work.
162
Policy TR-1.5.12: Need performance measure and date when
baseline report should be achieved. That information should
already be available.
No performance measure needed. The City will coordinate with MDT
immediately to obtain the weekday peak hour transit ridership data.
163
Policy TR-1.5.13 The City needs to coordinate with the County
regarding the LU of the downtown. All transportation
infrastructure has been centralized there because it was the
business hub. LU's and City zoning for mixed use should
encourage and promote business development and
construction in the downtown area.
This comment is noted. Many provisions in the MCNP already promote
business development and construction in the downtown area, especially
Objective 3.2 addressing the Urban Central Business District (UCBD)
Designation. See also the land use density and intensity incentives provided
for the CBD and properties located within the UCBD.
164
Summary of recommendations:
1. Clarification of the adopted LOS standards
2. Enforcement of Transportation Demand Management
strategies. And ensure that tenant board is responsible after
developer no longer manages the facility.
3. Coordination with MDT on the expansion and improvement
of headways of the bus transit system
4. Coordination with MDT to improve connections between
transit modes
5. Provision of performance measures for achieving mobility in
the TCEA.
6. Provide true multimodal options by providing support and
investment in pedestrian and bike path amenities.
6. Evaluate long range right -of -way needs for the provision of
transit in high density corridors
7. Coordination with FOOT to ensure that Transportation
improvement minimize the intrusion of commuter traffic on
1. Clarification of adopted LOS standards are addressed in TR-1.1.2, TR-1.1.3,
CI-1.2.2 and CI-1.2.3.
2. Enforcement of TDM strategies are addressed in TR-1.1.5 and TR-1.1.9.
3. Coordination with MDT is addressed in TR-1.1.4 and TR-1.1.6.
4. Coordination with MDT is addressed in TR-1.5.1, TR-1.5.12 and TR-1.5.13.
5. Achieving improved mobility in the TCEA is addressed in TR-1.5.8 and in
new policy LU-1.1.13.
6. Support and investment in pedestrian and bicycle amenities is addressed in
TR-1.4.3 and TR-1.5.8.
6. Transit right-of-way needs are addressed in TR-1.7.2.
7. Coordination with FDOT is addressed in TR-1.4.1.
Page 20
Public Comment
residential streets
Consultant / City Response
March 19, 2008 Comments from Grace Garrido for Coral Gate Homeowners' Association
165 Coral Gate is the first Planned Unit Development in the City of
Miami. Our homes were built between 1948 and 1950. All but
two are still standing. One was lost to fire; one was lost to
Ordinance 9500 transitional use zoning and is now used as an
office, but it is still zoned R-I. Because this EAR is also
preparing the way for Miami 2J, we wish to ensure the
preservation of Coral Gate as it stands.
166
167
This comment has been noted.
LU-1.1.3 (4) degradation.. transition and buffering
requirements that do not diminish the amount of area
encompassing the adjacent/abutting single family
neighborhoods. Wording in red be added. We would like to be
sure that we don't automatically upzone any properties in
Coral Gate.
The same addition in LU-1.6.9; HO-1.1.5; HO-1.1.17 and TR-
1.1.1.
168
LU-1.1.11 - Refers to Single Family Residential on the MCNP
Future Land Use Map but how does this change when we
have T3 zoning?
Same question in the "Interpretation of the future Land Use
Plan Map" Only the present zoning classifications are referred
to.
169
The requested modification has been made in Policy LU-1.1.3
The requested modification has been made in Policy LU-1.6.9, Policy HO-
1.1.5, and Policy HO-1.1.17
This is a Zoning amendment request, and outside of the MCNP EAR -based
amendments.
LU-1.1.2.3 "redevelopment and revitalization.... specific
neighborhood and area plans."
How is "Neighborhood" defined? (There is no glossary of
terms.) and
LU-I.3.1 - "in accordance with neighborhood design" What's a
neighborhood? Because the five blocks of Coral Gate from 32
Ave. to 37 Ave. along S.W. 2! ST. are very different from the 3
to 4 blocks of S.W. 21 St. from S.W. 27 Ave to S.W. 30 Ave.
Addressed in new policy LU-1.1.5.
170
LU-1.3 - "encourage the development of well -designed, mixed
use neighborhoods... "
How does the City intend to protect established
neighborhoods and at the same time accomplish development
of well -designed, mixed use neighborhoods? Do they not
violate their own intent by professing to do both without
including areas that are excepted from the imposition of
mixed -used neighborhood rules.
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City. Addressed in the new policy LU-1.1.5.
171
LU-1.6.5 States that the City will continue to use "Special
Districts? Should not the NCO be mentioned here also?
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City.
Page 21
172
Public Comment
HO-1.1.8 - "City will protect and enhance existing viable
neighborhoods."
What would be an enhancement? If the neighborhood is
viable. does it need to be enhanced?
Consultant / City Response
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City.
March 19, 2008 Comments from Miami River Marine Group, Inc.
173
174
175
176
Not Deleting Comp Plan "Policy PR-I.5.8: Expand the existing
Jose Marti Park to provide additional recreational opportunities
for the area's residents, workers, and visitors."
Concurring with City Commissioner Sanchez' recommendation
made during a public hearing regarding the EAR
recommended amendments to the Comp Plan, to insert City
support for citywide Water Taxi / Water Bus services within the
Transportation element of the Comp Plan.
Not deleting PR 1.4.1 and PR 1.4.2 regarding development
impact fees for parks and insert the EAR based amendment
for the sections. _
As directed by the PAB and City Commission when
considering the EAR in December 2004, inserting
"Fisherman's Wharf' in PR 6.1.3 to become consistent with PR
6.1.4.
This comment has been addressed in Objective PR-2.2 and its related policies,
and has been broadened to include all existing parks and recreational facilities.
Water borne transportation has been addressed in Policy TR-1.5.9B.
This comment has been addressed in Objective PR-1.5 and its related policies.
This requested modification has been made in Policy PR-6.1.3.
March 19, 2008 MNU Overview on MCNP EAR -based Amendments
177
1. The time -frame scheduled by the City for public input is too
short. We have been requesting your Board (the designated
Agency) and the City Administration to establish a Project to
work on these Amendments for over two years.
The very first task undertaken by the City in preparing for the EAR
Amendments was to request citizen participation through an Advisory
Committee made up of representatives appointed by each District City
Commissioner so that feedback on the amendment language (and on public
outreach) could be facilitated during the EAR amendment process. The very
first task undertaken by the Consultant Team preparing the EAR Amendments
was the analysis of MNU comments submitted to the City dated October 6,
2005 (as part of the EAR process) and the drafting of responses to these
comments to indicate which of these comments would be incorporated into the
amendments to the goals, objectives and policies of the MCNP. This
information was submitted to the Advisory Committee (which included key
MNU representatives) on December 21, 2007. On January 18, 2008, a first
draft of the EAR Amendments was submitted to the Advisory Committee, with a
follow-up draft submitted on January 28, 2008 to incorporate the GOP's for the
Park and Recreation Element. The Advisory Committee met with City Staff and
the Consultant Team to discuss issues of concern, process and timeframe on
November 1, 2007, January 8, 2008 and February 1, 2008. At the February 1,
2008 meeting, committee members from the Upper East Side and from Miami
River Commission provided specific comments to the draft GOP's, and
requested that modifications be made to address their concerns. The MNU
Page 22
178
Public Comment
2. Notwithstanding the commitment of the City in 2005 that
EAR -based Amendments would not be restricted to issues
raised in the EAR, the City is now maintaining that those are
the only Amendments they will consider at this time.
Consultant / City Response
I representative generally discussed issues related to population projections,
density and single-family residential, but did not offer specific language
modifications to the drafted GOP's. The Consultant Team requested
comments from MNU on the drafted GOP's ASAP since a new draft of the EAR
Amendments would be provided at the conclusion of the Public Outreach
program in order to incorporate comments received from the public. The City
Staff and Consultant team had already simultaneously begun a public outreach
program consisting of 10 public workshops held on Jan. 29, 30, 31, Feb. 4, 5,
6, 7, 11, 12, 13, at which the MNU representative attended at least four of
these workshops. Requests for feedback on the drafted GOP's from MNU
went unanswered. None were provided during the March 5, 2008 public
workshop held with the Planning Advisory Board. Feedback was finally
received 6.5 weeks after the February 1, 2008 Advisory Committee meeting,
with comments received at the March 19, 2008 workshop held with the
Planning Advisory Board, after which the Consultant Team only had 3 days to
turn around revised GOP's to incorporate comments received by the PAB and
by the public during the March 19, 2008 workshop.
The EAR amendments include numerous changes to GOP's based upon
issues raised through the Public Outreach process, and through feedback
received at the PAB workshops which address numerous changes not required
by the EAR recommendations. The drafting of new optional comprehensive
plan elements cannot be accomplished within the timeframe established to
complete the EAR amendments. The City has committed to undertaking
additional comprehensive plan modifications after the EAR amendments are
adopted, through the standard twice per year opportunity afforded by the City
to amend their comprehensive plan.
179
3. Information requested from the City is not being provided.
Additional informational requests related to land use and transportation were
received by the City on February 16, 2008. The Consultant team immediately
began responding to the information requested. An initial submittal of
information was provided to MNU representatives on March 4, 2008. See
below the complete responses to information requested.
180
181
4. We are generally pleased with the work on the Parks,
Recreation and Open Space Element, although it needs some
more work and Measurable Objectives need to be added.
5. Land Use Element. We have recommended definition of
two types of neighborhoods, essentially "Suburban
Neighborhoods" and "Urban Neighborhoods", in order to
properly differentiate protections for Suburban Neighborhoods
from unnecessary density, mixed uses, etc. appropriate for
Urban Neighborhoods. The consultants agreed at a
Committee Meeting to work on this, but notwithstanding
This comment has been noted.
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City.
Page 23
182
Public Comment
follow-up, nothing has been done. Many additional changes
have to be made in various elements to distinguish Policies for
Suburban Neighborhoods from Policies appropriate for Urban
Neighborhoods.
6. The Transportation Element needs a significant amount of
work. Please see our DRAFT "MCNP Transportation Element
Issues" and "Excerpts from .... Case Studies". The latter points
out many policies and levels of measurement which should be
included in the Transportation Element.
Consultant / City Response
This comment has been noted.
183
7. MNU has been recommending since 2004 that an optional
Economic Element and Historic Preservation Element, among
other option Elements be included in the Amendments. No
such Elements are included. MNU is working on a draft
Economic Element.
184
Addressed in the additional proposed Goals, Objectives and Policies submitted
to the City.
8. MNU is continuing to work on the various Elements and will
be submitting additional suggestions and requests to the
Planning Dept.
This comment has been noted.
MCNP Transportation Element Issues Draft March 16, 2008 Work In Progress
185
I. Major Issues
A. The City's Future Land Use Map (FLUM) is not in
coordination with the CIE, the TIP or the Long Term
Transportation Plan. FS 163 and related Rules and Best
Practices from DCA (Transportation Concurrency Best
Practices Guide - TCBPG) assume that the current, approved
FLUM is properly supported by a financially feasible capital
improvements plan (5 year or 10 year), and therefore all focus
on proposed amendments to the FLUM and the impact of
corresponding increased density and intensity. In the case of
Miami, we believe that the current FLUM is grossly in excess
of the current and planned infrastructure capacities. This is not
in line with the "current situation" assumed in the statue,
nevertheless, the TCBPG on page 102, in the Appendix:
Evaluating the Impacts of Comprehensive Plan Amendments
and pp 104-109 "Guidelines for Evaluating Comprehensive
Plan Amendments" specify use of "existing and proposed
future land use map (FLUM) designations using the maximum
density/intensity of the existing and proposed land use
classification ...". Our calculations using a County property
records database of all lots in the City with their current Use
designation could result in a population of 2 million or more
(current population approximately 360,000). With Miami 21
I The standard methodology to evaluate Comprehensive Plan Amendments
which propose a change to the land use designation on the Future Land Use
Plan Map (FLUM) does specify a comparison between the maximum allowable
use for the underlying (existing) land use designation, compared to the
maximum allowable use under the proposed land use designation. This
comparison is used to evaluate the impacts of a proposed land use plan map
change on the demand for parks, potable water, sanitary sewer, solid waste,
stormwater, transportation and water supply. This approach is followed both by
the City of Miami in their review of land use plan map changes, and by Miami -
Dade County in their review of proposed land use plan map changes.
Page 24
Public Comment
heading toward more mixed use and more built -out square
footage, intensity will increase substantially.
186 B. Urban Infill Area (UIA) and Transportation Concurrency
Exception Area (TCEA) Designations
I. The City claims that the County has declared the whole City
is a UIA and a TCEA and the City has no choice.
187 2. Miami -Dade County and the MPO say that the City is free to
designate, or not, one or more UTA's or TCEA's.
188 3. The "TCEA Case Studies" document refers to "activity
centers" of "high intensity, mixed -use", similar to the definition
in: "FS 163.3 1 80(5)(b)5. An urban service area specifically
designated as a transportation concurrency exception area
which includes lands appropriate for compact, contiguous
urban development, which does not exceed the amount of
land needed to accommodate the projected population growth
at densities consistent with the adopted comprehensive plan
within the 10-year planning period, and which is served or is
Consultant / City Response
The Urban Infi11 Area (UIA) and Transportation Concurrency Exception Area
(TCEA) was established by Miami -Dade County pursuant to Amendment No.
94-2 and includes the UIA and the TCEA for the municipalities of Aventura,
Hialeah, Miami, Miami Beach, Miami Gardens, Miami Lakes, Miami Shores,
Miami Springs, North Miami Beach, Palmetto Bay, Pinecrest and South Miami.
The City of Miami amended the MCNP in the year 1999 pursuant to Ordinance
11864 to designate the City of Miami as an Urban Infill Area consistent with the
actions taken by Miami -Dade County to establish the TCEA. The City of Miami
then amended the MCNP in the year 2000 pursuant to Ordinance 11961 to
exclude (from the UIA) Virginia Key, Watson Island and the uninhabited islands
of Biscayne Bay having a "conservation" land use and zoning classification. In
the year 2003, the City of Miami amended the MCNP to respond to the
recommendations from the 1995 EAR and reaffirmed the UIA. To respond to
the concerns raised during the EAR amendment process, Policy LU-1.1.13 has
been submitted to the PAB for their consideration to include with the EAR
amendments, an obligation on behalf of the City to review and evaluate the
areas designated Urban Infill Area (UIA) and/or Transportation Concurrency
Exception Area (TCEA) to determine at a minimum the following: the
appropriateness of the areas included in the UIA and/or the TCEA; the benefits
and/or disadvantages resulting from the inclusion or exclusion of these areas
within the UIA and/or the TCEA; the strategies to support mobility and
alternative modes of transportation within those areas included in the UIA
and/or the TCEA; and the strategies to address urban design and network
connectivity to improve mobility within those areas included in the UIA and/or
the TCEA.
The City of Miami can re-evaluate the designation of lands as an UIA and as a
TCEA, and therefore, Policy LU-1.1.13 has been submitted to the PAB for their
consideration to include with the EAR amendments as an obligation on behalf
of the City to review and evaluate the areas designated Urban Infill Area (UIA)
and/or Transportation Concurrency Exception Area (TCEA).
Once again, the City of Miami can re-evaluate the designation of lands as an
UIA and as a TCEA, and therefore, Policy LU-1.1.13 has been submitted to the
PAB for their consideration to include with the EAR amendments as an
obligation on behalf of the City to review and evaluate the areas designated
Urban Infill Area (UIA) and/or Transportation Concurrency Exception Area
(TCEA).
Page 25
Public Comment
planned to be served with public facilities and services as
provided by the capital improvements element." (emphasis
added)
189 4. The MCNP must be revised to remove the whole City as a
TCEA and designate appropriate "activity centers" as new
TCEA's, consistent with the MPO Long Term Transportation
Plan and the Long Term Water & Sewer facilities plan. This
will require Amendments to the Transportation Element to
concur with the requirements of FS I63.3180(5)(d), (e), and (f)
as also mentioned in the Transportation Planning "Efficient
Transportation Decision Making Process" paper of DCA
(attached).
190 5. Transportation Concurrency Management Areas should
also be designated as per FS 163.3180(7). This concept was
Consultant / City Response
The Transportation Concurrency Exception Area was created by the Florida
Legislature pursuant to Section 163.3180(5)(a), F.S., where the Legislature
recognized that under limited circumstances dealing with transportation
facilities, countervailing planning and public policy goals might come into
conflict with the requirement that adequate public facilities and services be
available concurrent with the impacts of development. The Legislature
determined that often the unintended result of the concurrency requirement for
transportation facilities resulted in the discouragement of urban infill
development and redevelopment. Such unintended results were found to be in
direct conflict with the goals and policies of the state comprehensive plan.
Therefore, exceptions from the concurrency requirement for transportation
facilities were permitted as provided by Section 163.3180(5)(a), F.S.
At the present time, the "whole City" is not included in the TCEA as referenced
above. Recognizing the concerns expressed during the EAR amendment
process, Policy LU-1.1.13 has been submitted to the PAB for their
consideration to include with the EAR amendments as an obligation on behalf
of the City to review and evaluate the areas designated Urban Infill Area (UIA)
and/or Transportation Concurrency Exception Area (TCEA).
At the present time, compliance with Section 163.3180(5)(d),(e) and (f) is
addressed pursuant to Section 163.3180(5)(g). Miami -Dade County, as the
recipient of the TCEA, must show compliance with these sections. Miami -Dade
County, through the establishment of the People's Transportation Plan, the
half -percent sales surtax, the Citizens' Independent Transportation Trust
(CITT) and the MPO Long Range Transportation Plan (LRTP) have already
taken major steps toward mitigating impacts to the Strategic Intermodal System
(SIS) roadways. The LRTP provides for an East-West Premium Transit
Corridor which will promote alternative travel modes and will mitigate vehicular
impacts to SR 836. The LRTP provides for the Kendall Link Premium Transit
Corridor which will promote alternative travel modes and will mitigate vehicular
impacts to SR 836, SR 821, SR 874 and SR 878. The LRTP provides for the
FEC Premium Transit Corridor which will promote alternative travel modes and
will mitigate vehicular impacts to 1-95. The LRTP provides for the South Link
Premium Transit Corridor which will promote alternative travel modes and will
mitigate vehicular impacts to SR 821, SR 874 and SR 878.
The City of Miami can evaluate the appropriateness of Transportation
Concurrency Management Areas as a tool to promote infill development and
Page 26
# Public Comment
supposed to be incorporated in the Transportation Element as
the "Miami Intermodal Transportation Plan (MTI)", which
apparently has never been completed.
191 6. We do not understand whether or how FS 163.3 1 80(8)
applies in the case of the City of Miami.
192 7. We do not understand how FS 163.3 180(9) applies to the
City of Miami. Assuming there are several designated and
approved TCEA's there should also be a Tong -term
concurrency management system in coordination with the
County and MPO, which could enforce limitations on
redevelopment if appropriate.
Consultant / City Response
redevelopment, and can incorporate the Transportation Concurrency
Management Areas (as applicable) during the evaluation of the Urban Infill
Area and the Transportation Concurrency Exception Area pursuant to Policy
LU-1.1.13 which has been submitted to the PAB for their consideration to
include with the EAR amendments.
Section 163.3180(8), F.S. provides a transportation concurrency "vesting" to
existing development undergoing redevelopment equal to 110 % of the
transportation impacts calculated based upon the existing use. Only the
increment of new development impacts for redevelopment sites (above the
_ 110%) shall be assessed for transportation concurrency.
The adoption of a long term transportation concurrency management system
pursuant to Section 163.3180(9), F.S. is not mandatory. At the present time,
long term transportation planning is orchestrated through the MPO Long Range
Transportation Plan (LRTP) which establishes the long term cost -feasible
transportation priorities for the county for the years 2005 through 2030. The
LRTP is updated every five years to re-evaluate transportation trends and the
need for additional or modified transportation improvements.
The comments are noted.
193 C. The TCEA Case Studies have a great many
recommendations for the Transportation Element of the
MCNP. Why are they being ignored? See attached "Summary
of Case Study Recommendations"
194 II. Significant Issues
A. The "person -trip" methodology used by the City does not
comply with:
I.) FS163.3180 (I)(b) "Local governments shall use
professionally accepted techniques for measuring level of
service for automobiles, bicycles, pedestrians, transit, and
trucks. These techniques may be used to evaluate increased
accessibility by multiple modes and reductions in vehicle miles
of travel in an area or zone. The Department of transportation
shall develop methodologies to assist local governments in
implementing this multimodal level -of -service analysis." or
2.) TCBPG p104 Guidelines for Evaluating Comprehensive
Plan Amendments).
195 As stated in the "Transportation Corridors: Meeting the
Challenge of Growth Management in Miami" Revision I,
September 1990 on page 9: "Finally, it should be stressed that
the Transportation Corridor is a new and innovative approach
to dealing with the urban transportation policy dilemma - as
In compliance with Section 163.3180(1)(b), vehicular, transit, bicycle and
pedestrian levels of service were evaluated by the City of Miami during the
EAR Process as part of the Transportation Element Data and Analysis
(November 2004). Vehicular capacity measurements were performed by the
City of Miami using the roadway capacities as provided by FDOT in the latest
edition of the 2002 Quality/Level of Service Handbook. Vehicular capacities
and vehicular levels of service were based upon Table 4-4 - FDOT Generalized
Peak Hour Two -Way Volumes for Florida's Urbanized Area. Pedestrian and
bicycle levels of service were also based upon the criteria provided by FDOT in
the 2002 Quality/Level of Service Handbook, in conjunction with data and level
of service measurements provided by the Miami -Dade County MPO. Transit
capacities and transit demand applicable to corridors with transit service were
calculated using service headway and ridership data from Miami -Dade Transit.
Factors used to calculate persons per vehicle were based upon the Southeast
Florida Regional Travel Characteristics Study.
As previously stated above, vehicular, transit, bicycle and pedestrian levels of
service were evaluated by the City of Miami during the EAR Process as part of
the Transportation Element Data and Analysis (November 2004). Vehicular
capacity and level of service measurements were based upon Table 4-4 -
FDOT Generalized Peak Hour Two -Way Volumes for Florida's Urbanized Area.
Page 27
Public Comment
with all new ideas, it lacks refinement and much more
research, testing, analysis, and evaluation need to be done
with it." Miami is believed to be the only jurisdiction in Florida,
and possibly the whole United States, which uses this
methodology. The DCA recommends and the MPO/County
are using DOT capacity measurement standards and "Mode
Split" (TCPBG p 85 and p. 108) modeling. The City should use
the same LOS standard and performance measurement as
the County. Mode Split methodology should assist with better
planning for the various modes of transportation available in
each sector.
196 B. We wish to verify whether the County and the MPO have
received from the City all small scale MCNP Amendments and
information on all redevelopment growth, in order to properly
calculate the both vested and cumulative pending trips when
assessing necessary growth in capacities.
197 C. Why is there not provision for at least some Proportionate
Fair Share Mitigation or Impact Fee funding to support the
increases in density in the City? Incentive to increase density
in activity centers has considerable merit, but not to the total
exclusion of the impact of the growth on scarce infrastructure
resources.
Consultant / City Response
Pedestrian and bicycle levels of service were also based upon the criteria
provided by FDOT in the 2002 Quality/Level of Service Handbook. Transit
capacities and transit demand applicable to corridors with transit service were
calculated using service headway and ridership data from Miami -Dade Transit.
Factors used to calculate persons per vehicle were based upon updated
standards from the Southeast Florida Regional Travel Characteristics Study.
The City of Miami's level of service (LOS) standards are consistent with Miami -
Dade County. The level of service standard provided under Policy TR-1.1.2.1
is consistent with the adopted level of service standard maintained by Miami -
Dade County pursuant to page 11-8 and page 11-11 of the Transportation
Element of the Miami -Dade County CDMP where the adopted level of service
standard is E (at 100% of capacity) unless other provisions apply pursuant to
TR-1.1.2.2, TR-1.1.2.3 and TR-1.1.3.
The level of service standard provided under Policy TR-1.1.2.2 is consistent
with the adopted level of service standard maintained by Miami -Dade County
pursuant to page 11-9 and page 11-11 of the Transportation Element of the
Miami -Dade County CDMP where the adopted level of service standard is
120% of capacity for those roadways located within % mile of a transit route
which operates with a minimum of 20 minute headways.
The level of service standard provided under Policy TR-1.1.2.3 is consistent
with the adopted level of service standard maintained by Miami -Dade County
pursuant to page 11-9 and page 11-11 of the Transportation Element of the
Miami -Dade County CDMP where the adopted level of service standard is
150% of capacity for those roadways located parallel to and within % mile of
1 extraordinary transit service such as commuter rail or express bus.
This comment is noted.
All development located within the City of Miami is subject to the payment of
transportation impact fees to Miami -Dade County. Development located within
the Downtown Miami DRI and the SEOPW DRI are also subject to the payment
of Transportation Mitigation Fees as outlined in Article 13 of the City Code and
as mandated by each of the two DRI approvals. All other developments
located within the City of Miami are subject to the payments of impact fees
pursuant to Section 13-6 of the City Code. The intent of Section 13 of the City
Code is to impose impact fees, payable at the time of building permit issuance,
Page 28
Public Comment
Consultant / City Response
in order to fund capital improvements, capital facility capacity and capital
equipment needed to address demand for public facilities attributable to new
development. This article is not intended to authorize imposition of fees related
to capital facility or equipment needs attributable to existing development. This
article is intended to allow new development in compliance with the
comprehensive plan and to provide a mechanism for new development to help
address the burdens created by new development.
February 16, 2008 Comments from Hadley Williams
198
Policy LU-1.1.3: Please provide references to the sections of
the current ordinances which provide specifically for protection
from: encroachment, adverse impacts.
The City of Miami Zoning Ordinance controls and protects neighborhoods from
encroachment and adverse impact through its zoning districts.
Article 4 (Zoning Districts) of the City of Miami Zoning Ordinance establishes
an R-1 (Single -Family Residential) district that intends to protect
neighborhoods by limiting density to one unit per typical lot size. This category
allows a maximum density of approximately nine units per net acre.
Article 8 (NCD Neighborhood Conservation Districts), Section 800.1 of the City
of Miami Zoning Ordinance states that the purpose of the NCD is to "Protect
neighborhoods or districts that have significant architectural and historic merit
and a distinct character but that do not qualify for historic district status or have
lost some of their integrity through incompatible additions and new
development."
The City of Miami Zoning Ordinance is available online at www.municode.com.
199
Policy LU-1.1.4: Please provide the" code enforcement
strategies and initiatives" referred to.
200
201
Policy LU-1.1.9: Figure 111.1 of Volume 11- Data and
Analysis of the MCNP)
Article 21 (Administration, Enforcement, Violations, and Penalties), Section
2108 of the City of Miami Zoning Ordinance addresses code enforcement
strateg ies.
Penalties of code violations are outlined in the succeeding section, Section
2109 (Penalties).
Policy LU-1.1.10: Station Area Design and Development Plan
for each station
A hard copy of the Data and Analysis of the MCNP may be obtained from the
City of Miami Planning Department.
The Miami -Dade County Code of Ordinances outlines the Station Area Design
and Development Plan process in Section 33C-2(d). Such plans are
authorized by Miami -Dade County Resolution No. R-829-77.
Pursuant to the provisions of Chapter 33 of the Miami -Dade County Code of
Ordinances and Resolution No. R-867-76, the County has enacted six
Page 29
Public Comment
Consultant / City Response
ordinances accepting Station Area Design and Development studies: No. 80-
129 (Earlington Heights), No. 81-29 (Martin Luther King, Jr.), No. 81-30
(Dadeland North), No. 81-31 (Brownsville), No. 81-32 (Northside), and No. 82-
12 (Dadeland South).
Policy LU-1.1.11: What, specifically, are the "centers of
activity"? Maps. Please define "livability" and the specific
"goals of enhancing the livability" with references
Generally, centers of activity are located at the intersection of section and half -
section line corridors where lands are currently designated for commercial
and/or multi -family use as shown on the City of Miami Future Land Use Map
January 2008. Centers of activity also exist along major thoroughfares such as
Biscayne Boulevard and US 1 where these corridors intersect section and half -
section line corridors on lands currently designated for commercial and/or
multi -family use as shown on the City of Miami Future Land Use Map January
2008.
"...enhancing the livability of residential neighborhoods" means ensuring that
neighborhoods are attractive places to live, play, visit, raise a family, retire, and
enjoy diversity.
MCNP Goals, Objectives, and Policies designed to enhance livability are as
follows:
Page 30
Public Comment
Consultant / City Response
Future Land Use Element
Goal LU-1
Objective LU-1.1
Policy LU-1.1.3
Policy LU-1.1.7
Objective LU-1.2
Objective LU-1.3
Policy LU-1.3.10
Policy LU-1.3.15
Policy LU-1.4.3
Objective LU-1.5
Policy LU-1.6.10
Policy LU-3.1.2
Various points under the "Regional Activity
Centers" heading
Various points under the "Buena Vista Yards
Regional Activity Center" heading
Various points under the "Interpretation of the
Future Land Use Plan Map" heading
Ports, Aviation and Related Facilities Element
Objective PA-2.1
Policy PA-3.1.1
Coastal Management Element
Goal CM-1
Policy CM-2.1.7
Goal CM-5
Capital Improvements Element
Goal CI-1
Housing Element
Policy HO-1.1.3
Policy HO-1.2.6
Policy HO-1.2.7
Goal HO-2
Objective HO-2.1
Transportation Element
Goal TR-1
Policy TR-1.1.4
Policy TR-1.1.5
Policy TR-1.1.9
Policy TR-1.1.12
Policy TR-1.1.18
Policy TR-1.2.2
Objective TR-1.4
Policy TR-1.4.1
Policy TR-1.4.4
Page 31
Policy TR-1.4.5
Policy TR-1.5.8
Policy TR-1.5.9
Parks, Recreation and Open Space Element
Objective PR-1.1
Policy PR-1.1.2
Objective PR-1.4
Policy PR.1.4.1
Policy PR-1.4.2
Policy PR-1.4.3
Policy PR-1.4.4
Policy PR-1.4.5
Goal PR-2
Goal PR-3
Objective PR-3.1
Policy PR-3.1.1
Policy PR-3.1.2
Policy PR-3.1.3
Objective PR-3.2
Policy PR-3.2.1
Policy PR-3.2.2
Policy PR-3.2.5
Policy PR-3.2.6
Policy PR-3.2.8
Policy PR-5.1.6
Policy PR-5.1.7
Goal PR-6
Objective PR-6.1
Policy PR-6.1.2
Policy PR-6.1.3
Objective PR-6.2
Policy PR-6.2.1
Policy PR-6.2.2
Policy PR-6.2.3
Goal PR-7
Objective PR-7.1
Policy PR-7.1.1
Goal PR-8
Objective PR-8.1
Policy PR-8.1.1
Policy PR-8.1.2
Goal PR-9
Objective PR-9.2
Policy PR-9.2.1
203
Public Comment
Objective LU-1.2: Please identify for us those areas in the City
which are "blighted, declining or threatened residential,
commercial and industrial areas". We have noted the map of
Brownfield areas covering a large portion of the City and do
not understand how many neighborhoods designated are
Brownfield area included. Please explain.
Consultant / City Response
Those areas in the City which are "blighted, declining or threatened residential,
commercial and industrial areas" are the areas which fit the definitions found in
Policy LU-1.2.3, as follows:
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, 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.
The location of these areas changes over time as the conditions in the
neighborhoods change. The neighborhoods within the existing Community
Redevelopment Areas have been identified as areas in the City which are
"blighted, declining or threatened residential, commercial and industrial areas".
204
Policy LU-1.2.3: Please identify exactly where in the MCNP
"the adopted Consolidated Plan, Fiscal Years 2004-2009,
adopted redevelopment plans, specific neighborhood and area
plans" are incorporated by reference in the MCNP. Please
provide a list of all "adopted redevelopment plans" and
"specific neighborhood and area plans".
205
Policy LU-1.3.1: Please provide maps and references to each:
"designated Neighborhood Development Zones (NDZ), the
Empowerment Zone, the Enterprise Zone, the Brownfield
Redevelopment Area, Commercial Business Corridors, and
other targeted areas".
The City of Miami Consolidated Plan for FY 2004-2009
(http://www.miamigov.com/communitydevelopment/ConPlan) designated areas
in the City that are most distressed and in need of the most assistance as
"Neighborhood Development Zones" (NDZs). The NDZs are as follows:
• Allapattah
• Coconut Grove
• Edison/Little River/Little Haiti
• East Little Havana
• West Little Havana
• Model City
• Overtown
• Wynwood
Smaller, more specific geographic areas (called "Model Blocks") are detailed in
the Consolidated Plan.
A map of the Neighborhood Development Zones can be found under the
"Maps" section of the City of Miami Consolidated Plan at:
http://www.miamigov.com/communitvdevelopment/ConPlan/index.htm
A map of the Enterprise Zone can be located on the City of Miami website at:
Page 32
Public Comment
Policy LU-1.3.4: Please provide a list of "job training/job
placement programs offered to youths (full time and summer
terms) and low-income persons".
Policy LU-1.3.5: A.) Please define and identify specifically
existing and planned "high intensity activity centers". B.) "Such
activity centers will be in accordance with the Comprehensive
Neighborhood Plan and neighborhood design and
development standards adopted as a result of amendments to
the City's land development regulations and other initiatives"
In accordance with what Policy of the MCNP? Why aren't the
neighborhood design and development standards set as
Policies in the MCNP?
Policy LU-1.3.8: What are the specific objectives of training for
"support minority and semi -skilled residents"?
Policy LU-1.3.9: What "small geographic areas that have
special opportunities and/or potential for Redevelopment"?
Please identify, including on a map.
a
Policy LU-1.3.10: What "neighborhood improvement and code
enforcement strategies and initiatives"? Please provide details
including measurable standards in use.
Policy LU-1.3.14: Please identify all "urban design guidelines".
Consultant / City Response
http://www.miamigov.com/economicdevelopment/pages/Businesslncentives/En
terpriseZone.asp
The Brownfield Redevelopment Area map can be found on the City of Miami
website at:
http://www. miamigov.com/economicdevelopment/pages/Brownfields/Brownfield
sMap.asp
A map of the Empowerment Zone can be found on the Miami -Dade County
GIS Portal website at:
http://gisims2.miamidade.gov/CServices/CSMap.asp?Cmd=DUMMY&ShowWh
at=702
ACCESS (Assets, Capital, Community, Education, Savings, and Success)
Miami (http://www.accessmiamilobs.com/) offers "One Stop Centers" which
assists residents with job placement and job guidance (among other services)
specifically for low-income persons. Residents may visit these centers in
person (which have free computer access) or may dial 311 for guidance. The
ACCESS Miami website also provides a searchable database of local job
opportunities.
This item is being researched with City Staff.
The specific objective is to provide job training and educational opportunities
for the City's unemployed and underemployed residents so that may be
employed in jobs leading to their economic independence.
This item is being researched with City Staff.
This item is being researched with City Staff.
The City of Miami has an Urban Development Review Board
(http://www.miamigov.com/planning/pages/Boards/Boards.asp) whose
objective is to "evaluate projects and recommend actions to be taken by the
Director of Planning based on principles of urban design." The Urban
Page 33
Public Comment
Consultant / City Response
Development Review Board typically meets the third Wednesday of every
month at Miami City Hall.
Architecture and Urban Design Guidelines can be found in Article 6, Section
628.9 of the City of Miami Zoning Ordinance.
A copy of the City of Miami Design Standards and Guidelines can be obtained
from Edelberto Perez at (305)416.1413.
212 Policy LU•1.4.2: Please identify, including maps, all existing
and planned "management districts"
The Miami Downtown Development Authority (DDA) is an existing
"management district". The DDA programs and boundaries can be reviewed
on their website www.miaimidda.com.
213
Policy LU•1.4.7: Please provide the "design and development
objectives for downtown". We would also appreciate knowing,
if not clear in the objectives themselves, how these objectives
are measured for enforcement.
Design and development objectives for downtown can be found in the City of
Miami Zoning Ordinance which is the implementing document. See Article 6
SD Special District General Provisions and other Articles in the Zoning
Ordinance.
These "objectives" are "measured" by staff ensuring that the project design and
development conform to these requirements.
214
Policy LU-1.4.11: What specifically are the objectives to
accomplish with the policy to "streamline the development
application for development approvals to simplify and
standardize"?
Development applications are reviewed by many individuals and departments
within the City. Projects with different uses vary in the type of information
needed to complete the application. In addition, each department requires
different forms of information to complete its review of the application. One of
the objectives of this policy is to provide the applicant a clear set of rules and
requirements to properly complete the application and ensure that all
departments have the data and analysis needed to complete their review.
215 Policy LU•1.5.2: Can you please provide .pdf files or links to
.pdf files of referenced "Miami -Dade County's Waterfront
Charter Amendment, Shoreline Development Review
Ordinance, and the rules of the Biscayne Bay Aquatic
Preserve Management Area, and other appropriate
requirements regarding waterfront access and management".
216 Goal LU•2: Can you please provide a definition of "adaptive
reuse"?
The Shoreline Development Review Ordinance can be found in Article 3,
Section 33D-31 of the City of Miami Zoning Ordinance.
Rules of the Biscayne Bay Aquatic Preserve Management Area can be found
online at: http://www.dep.state.fl.us/coastal/downloads/18-18.pdf
Adaptive reuse is generally defined as a process that adapts old buildings for
new uses while retaining their historic features.
217
Goal 3: (Goal LU 3?): What is the purpose of including "Urban
Redevelopment Areas"? Is this a mis-quote of the term "Urban
Infill and Redevelopment Areas"?
The phrases "Urban Infill and Urban Redevelopment Areas" and "Urban Infill
and Redevelopment Areas" are meant to be interchangeable.
218
219
Policy LU.3.1.2: Are any additional "Regional Activity Centers"
planned? If so, please identify specifically.
Policy 3.1.3: Please explain this Policy.
No additional Chapter 380, Florida Statutes, Regional Activity Centers are
currently under review.
The Downtown Miami Master Plan is a defined boundary that is co -terminus
with the dark areas shown on the Urban Central Business District Map on page
12 of the Draft MCNP dated February 28, 2008. Portions of the area within the
Page 34
Public Comment
220 Policy TR•1.1.1: Please provide the "Appendix TR-1 of the
MCNP",
221 Policy TR.1.1.2: We would appreciate examples of 1.1.2.1
through 1.1.2.3.
Consultant / City Response
Downtown Master Plan are included in approved Development of Regional
Impacts (DRI). Policy 3.1.3 designates the area of the Downtown Miami
Master Plan as an Urban Central Business District to increase the threshold for
projects required to through the DRI process which are not within an existing
DRI. A description of increased DRI thresholds for the Urban Central Business
District can be found on page 13 of the Draft MCNP dated February 28, 2008.
The first EAR recommendation (TR-1) suggested that the adopted Person -Trip
Methodology be included in a designated Appendix to the Transportation
Element. In response to the EAR recommendation, new Appendix TR-1 was
suggested. A recent review of the 1990 published version of the Person -Trip
Methodology revealed that it was excerpted from the Transportation Element
from the Miami Comprehensive Neighborhood Plan 1989-1990, and therefore it
was already a part of the plan. Additional research found that the City of Miami
originated the person -trip methodology for the measurement of local level of
service on a transportation facility, which could consist of a roadway, transit
service, pedestrian corridor, bikeway, or any other transportation mode alone
or in combination with others. The Miami Comprehensive Neighborhood Plan
(adopted as Ordinance 10544 on February 9, 1989) established under Policies
TR 1.1.2 and TR 1.1.3 that within designated Transportation Corridors, the
capacity of all transportation modes would be used in the measurement of
future, peak hour level of service standards. The City of Miami "Methodology
for Calculating Peak Hour Person -Trip Capacity" was incorporated into the
Transportation Element of the MCNP under Policies TR 1.1.2 and TR 1.1.3 on
January 24, 1991 (adopted as Ordinance 10832), and was separately
published as a report entitled "Transportation Corridors: Meeting the Challenge
of Growth Management in Miami", September 1990. A separate Appendix to
the Transportation Element is no longer being pursued since the Person -Trip
Methodology is already part of the MCNP and is already utilized by the City as
a separately published report. A pdf copy of the 1990 version of the Person -
Trip Methodology is attached herein titled Transportation Corridors: Meeting
the Challenge of Growth Management in Miami.
Example of 1.1.2.1: Where no public transit service exists along a roadway
undergoing level of service evaluation and review, only the capacity of the
roadway will be utilized to determine compliance with the adopted level of
service standard. Where no transit service exists for the roadway, the adopted
level of service is E, which equates to a numerical value equal to 100% of the
roadway capacity. Pursuant to the City of Miami "Methodology for Calculating
Peak Hour Person -Trip Capacity", the level of service of the roadway can be
expressed in a volume to capacity ratio based upon the vehicular volume of the
roadway segment compared to the vehicular capacity of the roadway segment,
or the person -trip volume of the roadwa segment compared to the •erson-tri
Page 35
Public Comment
Consultant / City Response
capacity of the roadway segment. Pursuant to the 1990 version of
"Transportation Corridors: Meeting the Challenge of Growth Management in
Miami', vehicle trips are converted to person -trips using a vehicle occupancy
ratio of 1.4 persons per vehicle, and vehicle capacity is converted to person -trip
capacity using the vehicle occupancy ratio of 1.6 persons per vehicle.
Example of 1.1.2.2: Where bus transit service exists on a roadway operating
with 20-minute headways or better, and transit service is available parallel to
and within %/2 mile of the roadway segment undergoing level of service
evaluation and review, the capacity of both the roadway and the transit service
shall be utilized to determine compliance with the adopted level of service
standard. Where transit exists with at least 20 minute headways, the adopted
level of service for the transportation facility shall be 120 percent of capacity (or
120% of level of service E). The evaluation of level of service shall include
both the vehicular volume of the roadway segment (converted to person -trips)
and the person -trip volume of the transit service, compared to the vehicular
capacity of the roadway segment (converted to person -trips) and the person -
trip capacity of the transit service. Current data would be evaluated to
establish the existing vehicular traffic for the peak hour period. Current transit
ridership information would evaluated to determine the ridership data for the
peak hour period. A series of calculations would be applied to establish the
person -trip capacity of the transit service using the service frequency of each
transit route and the capacity of the transit vehicle to accommodate riders. The
volume to capacity person -trip ratio would be calculated to determine
compliance with the adopted level of service standard at 120% of level of
service E.
Example of 1.1.2.3: Where express bus and/or premium transit service exists
on a roadway operating with 20-minute headways or better, and express bus
and/or premium transit service is available parallel to and within '/2 mile of the
roadway segment undergoing level of service evaluation and review, the
capacity of both the roadway and the transit service shall be utilized to
determine compliance with the adopted level of service standard. Where
express bus and/or premium transit exists with at least 20 minute headways,
the adopted level of service for the transportation facility shall be 150 percent of
capacity (or 150% of level of service E). The evaluation of level of service shall
include both the vehicular volume of the roadway segment (converted to
person -trips) and the person -trip volume of the express bus and/or premium
transit service, compared to the vehicular capacity of the roadway segment
(converted to person -trips) and the person -trip capacity of the express bus
and/or premium transit service. Current data would be evaluated to establish
the existing vehicular traffic for the peak hour period. Current transit ridership
Page 36
Public Comment
Consultant / City Response
information would evaluated to determine the ridership data for the peak hour
period. A series of calculations would be applied to establish the person -trip
capacity of the transit service using the service frequency of each transit route
or transit mode and the capacity of the transit vehicle to accommodate riders.
The volume to capacity person -trip ratio would be calculated to determine
compliance with the adopted level of service standard at 150% of level of
service E.
Example of 1.1.2.1: Where no public transit service exists along a roadway
undergoing level of service evaluation and review, only the capacity of the
roadway will be utilized to determine compliance with the adopted level of
service standard. Where no transit service exists for the roadway, the adopted
level of service is E, which equates to a numerical value equal to 100% of the
roadway capacity. Pursuant to the City of Miami "Methodology for Calculating
Peak Hour Person -Trip Capacity", the level of service of the roadway can be
expressed in a volume to capacity ratio based upon the vehicular volume of the
roadway segment compared to the vehicular capacity of the roadway segment,
or the person -trip volume of the roadway segment compared to the person -trip
capacity of the roadway segment. Pursuant to the 1990 version of
"Transportation Corridors: Meeting the Challenge of Growth Management in
Miami', vehicle trips are converted to person -trips using a vehicle occupancy
ratio of 1.4 persons per vehicle, and vehicle capacity is converted to person -trip
capacity using the vehicle occupancy ratio of 1.6 persons per vehicle.
Example of 1.1.2.2: Where bus transit service exists on a roadway operating
with 20-minute headways or better, and transit service is available parallel to
and within % mile of the roadway segment undergoing level of service
evaluation and review, the capacity of both the roadway and the transit service
shall be utilized to determine compliance with the adopted level of service
standard. Where transit exists with at least 20 minute headways, the adopted
level of service for the transportation facility shall be 120 percent of capacity (or
120% of level of service E). The evaluation of level of service shall include
both the vehicular volume of the roadway segment (converted to person -trips)
and the person -trip volume of the transit service, compared to the vehicular
capacity of the roadway segment (converted to person -trips) and the person -
trip capacity of the transit service. Current data would be evaluated to
establish the existing vehicular traffic for the peak hour period. Current transit
ridership information would evaluated to determine the ridership data for the
peak hour period. A series of calculations would be applied to establish the
person -trip capacity of the transit service using the service frequency of each
transit route and the capacity of the transit vehicle to accommodate riders. The
volume to capacity person -trip ratio would be calculated to determine
compliance with the adopted level of service standard at 120% of level of
Page 37
Public Comment
Consultant / City Response
service E.
Example of 1.1.2.3: Where express bus and/or premium transit service exists
on a roadway operating with 20-minute headways or better, and express bus
and/or premium transit service is available parallel to and within % mile of the
roadway segment undergoing level of service evaluation and review, the
capacity of both the roadway and the transit service shall be utilized to
determine compliance with the adopted level of service standard. Where
express bus and/or premium transit exists with at least 20 minute headways,
the adopted level of service for the transportation facility shall be 150 percent of
capacity (or 150% of level of service E). The evaluation of level of service shall
include both the vehicular volume of the roadway segment (converted to
person -trips) and the person -trip volume of the express bus and/or premium
transit service, compared to the vehicular capacity of the roadway segment
(converted to person -trips) and the person -trip capacity of the express bus
and/or premium transit service. Current data would be evaluated to establish
the existing vehicular traffic for the peak hour period. Current transit ridership
information would evaluated to determine the ridership data for the peak hour
period. A series of calculations would be applied to establish the person -trip
capacity of the transit service using the service frequency of each transit route
or transit mode and the capacity of the transit vehicle to accommodate riders.
The volume to capacity person -trip ratio would be calculated to determine
compliance with the adopted level of service standard at 150% of level of
service E.
222
Policy TR.1.1.4: A.) What happened to the Miami Intermodal
Transportation (MIT) plan?
B.) Please provide a list of all "specific neighborhood
transportation plans" and five specific plans,
C.) Please provide the "detailed standards for transportation
facilities and services that will complement neighborhood
development, redevelopment, and conservation".
D.) Please provide the Miami Downtown Transportation
Master Plan.
1 Examples of specific neighborhood Plans are listed below.
• Coconut Grove Area Traffic Study
• Health District (Civic Center) Implementation Plan
• Health District Comprehensive Traffic Study
• Orange Bowl Traffic and Parking Assessments
• Flagler Street Marketplace/Flagler Street two-way conversion
• Miami Downtown Transportation Master Plan
• Watson Island Traffic Master Plan
• Miami River Multimodal Corridor Study (prepared for the Miami -
Dade MPO and the Miami River Commission with the City of Miami)
• Miami River Greenway Plan
• Miami Design District -Little Haiti District Planning Study/Master Plan
• Miami Design District Design Guidelines
• NE 36th Street Traffic Study prepared for the Miami -Dade Metropolitan
Planning Organization with involvement from the City of Miami
• FEC Corridor Master Plan (includes the Buena Vista Yard, now Midtown
Page 38
Public Comment
Policy TR-1.1.5: Is the Transportation Control Measures
ordinance and the MCNP going to be amended to that the
Transportation Control Measures ordinance is applicable
outside of downtown?
Policy TR-1.1.6: Please provide "the People's Transportation
Plan" and the County's "Transit Oriented Development
Policies" or links to them.
Consultant / City Response
Miami)
• 1-395 Project Development & Environment (PD&E) Study (more analysis
underway)
• NW/NE 79th Street Livability Study (completed) and PD&E Study (not
completed)
• Flagler Street PD&E Study
• DuPont Plaza Traffic Circulation PD&E Study (more analysis underway)
• Brickell Avenue PD&E Study (completed)
• Overtown (Dover Kohl) Master Plan
Standards for design and construction of transportation facilities vary in
accordance with the functional classification of the facility as well as with
ownership. For its municipal streets, the City of Miami uses the "Engineering
Standards for Design and Construction" handbook dated December 2005 and
published by the Department of Public Works. The Florida Department of
Transportation's Roadway Design Office develops and provides policies,
procedures, criteria and standards for the design and construction of roadways
and bridges under state jurisdiction. Similarly, Miami -Dade County Public
Works Department has developed guidelines and standards for design and
construction of facilities under County jurisdiction. The above publications can
be made available to the public by contacting the respective agency.
A link to the Downtown Miami Transportation Master Plan was found on the
MPO's website. See below. A pdf copy of the 19 meg file can also be obtained
from City Staff.
http://www.co.miami-dade.fl.us/mpo/m10-downloads-docs.htm#dtmp
A Transportation Control Measures Plan is regularly included in the
development impact traffic studies provided as part of the Major Use Special
Permit Application Process and as part of some Class II Applications located
outside of downtown.
The Citizens' Independent Transportation Trust (CITT) is the 15-member body
created to oversee the People's Transportation Plan funded with the half -
percent sales surtax. See the Zink to the Miami -Dade CITT website:
http://www.miamidade.gov/citt/
The Miami -Dade County MPO documents and studies which promote the
County's Transit Oriented Development Policies are provided in the attached
lin ks:
Page 39
Public Comment
Consultant / City Response
http://www.co.miami-dade.fl.us/mpo/docs/MPO newsletter 2007 tod.pdf
http://www.miamidade.pov/mpo/mdcfictodd/index.htm
225
Policy TR•1.1.7: Please provide "Appendix TR-2 of the
MCNP".
There will not be an Appendix TR-2 in the MCNP. The City will instead
maintain a current annual listing of the MPO Transportation Improvement
Projects located and funded within the City limits, the Long Range
Transportation Plan projects located within the City limits and the transit routes,
stations and service improvements located within the City limits. This list is
currently being updated to reflect TIP 2008, the 2030 LRTP and the 2007
Transit Development Program.
226
Policy TR-1.1.10: What happened to "depict existing and
planned future major parking facilities on appropriate maps"?
A Separate TR Objective concerning Parking must be added
with Policies.
IThe City currently maintains the location of existing major parking facilities
(citywide) on their GIS system. In addition, Map TR-3 was prepared by the City
during the EAR Process as part of the Transportation Element Data and
Analysis (November 2004) to depict significant parking facilities.
227
Policy TR.1.1.104: What streets have been or are planned to
"relocate"?
The Downtown Transportation Master Plan identifies a program of phased
improvements for Downtown, some of which include proposed changes to local
streets.
228
Policy TR-1.1.15: Please provide a reference link to "the
powers of the City's Off -Street Parking Authority Department"
See Section 23 — Department of Off -Street Parking - found in Subpart A of the
City Charter addressing the City of Miami Off -Street Parking Department and
Off -Street Parking Board.
229
Policy TR-1.1.16: Please provide a link to Downtown Miami
Transportation Management Initiative (TMI). Also, please
provide current "TMD strategies for City employees".
A link is provided to South Florida Commuter Services, the clearinghouse
agency in South Florida which specializes in transportation demand
management strategies, programs and implementation. The TDM strategiesfor
City employees is being researched with City staff.
http://www.1800234ride.com/
230
Policy TR-1.4.5: Please provide "Characteristics and The list of designated Urban Streets is provided in Policy TR-1.4.5.
standards for such streets" and "Characteristics and standards
for such streets". Please also provide a list of streets being
considered for designation of "urban street".
231
Policy TR-1.5.6: Please provide a map and list of "existing and
planned transit corridors" and "nodes around rapid transit
stations"
Map TR-5 and Map TR-11 were prepared by the City during the EAR Process
as part of the Transportation Element Data and Analysis (November 2004) to
depict the corridors with existing Metrobus Transit Routes and the location of
Passenger/Freight rail facilities.
232
Policy TR.1.5.8: Please provide identification of all "large
employment centers", including on a map.
"Large employment centers" is a general term used under TR-1.5.10 to refer to
areas in the City of Miami which are currently zoned for CBD, office,
commercial and industrial uses where greater concentrations of employment
can be expected to occur. In addition, Map TR-4 was prepared by the City
Page 40
Public Comment
Consultant / City Response
during the EAR Process as part of the Transportation Element Data and
Analysis (November 2004) to depict the location of Major Trip Generators and
Attractors inclusive of parks, arenas, stadiums, museums, ports, airports,
hospitals and downtown employment.
233
Policy TR.1.5.10: Please provide examples of "transit ridership
data".
234 Policy TR.1.5.1 : Please provide a link to the current "Five
Year Transit Development Program (TOP)"
235
Policy TR.1.6.1: Please provide links to the "Florida
Department of Transportation (FOOT) Five -Year
Transportation Improvement Program Plans and the
Metropolitan Planning Organization's Long Range
Transportation Plan Update"
236
Policy TR-1.8.1: What is the definition of "major
thoroughfares"? Please provide a link to the City Public
Works Manual.
MDT currently publishes daily and monthly Transit Ridership Reports — see
attached link to the November 2007 Ridership Technical Report. The policy is
being amended to request peak hour transit ridership data from Miami -Dade
Transit.
http://www.miamidade.gov/transit/library/pdfs/rtr/2007-
11 Ridership Technical Report.pdf
The Year 2007 MDT Transit Development Program (FY 2008 — FY 2012) is not
available online, nor is it available as a pdf (we have checked with Miami -Dade
Transit staff). Hard copies of the 2007 TDP can be obtained from:
Miami -Dade Transit located at 701 NW 1st Court, 15th Floor, Miami, FL 33136
Maria C. Batista, Principal Planner, Miami -Dade Transit - 786-469-5245 office
John Garcia, Principal Planner, Miami -Dade Transit — 786-469-5252 office
The MPO TIP 2008 is a 12.3 meg file which is available for download from the
Miami -Dade County MPO Website — see attached links:
http://www.co.miami-dade.fl.us/mpo/m10-plans-tip.htm
http://www.co.miami-dade.fl.us/mpo/docs/MPO tip 2008 final.pdf
The MPO Long Range Transportation Plan to the Year 2030 is a 30 meg file
which is available for download from the Miami -Dade County MPO Website —
see attached links:
http://www.co.miami-dade.fl.us/mpo/docs/MPO Irtp 2030 final 20050107.pdf
http://www.co.miami-dade.fl.us/mpo/m10-plans-Irtp.htm
"Major thoroughfares" is a general term used under TR-1.8.1 which refers to
section -line, half -section line or quarter section -line roadways which may be
classified as either arterial or collector roadways in accordance with the FDOT
functional classification system. The Public Works Manual refers to the
document titled "Engineering Standards for Design and Construction",
published by the Department of Public Works and dated December 2005,
covering the minimum requirements for the design and construction of
subdivision improvements. This document can be reviewed by contacting the
Page 41
Public Comment
Consultant / City Response
237
Public Works Department.
March 19, 2008 Comments from Becky Roper Matkov, Executive Director for Dade Heritage Trust
If the time pressures to advance the EAR -based amendments Addressed in the additional proposed Goals, Objectives and Policies submitted
to the State do not allow the formulation and adoption of an to the City.
appropriate Historic and Cultural Element, then please
consider adding to those amendments a time -certain date by
which this will be accomplished. We suggest April
2009 as a deadline by which this important task be
accomplished and pledge our assistance and participation in
the process.
238
239
March 19, 2008 Comments
Goal LU-1
... and (7) protects the integrity and quality of the City's
existing neighborhoods by insuring public notice, input and
appellant rights regarding changes in existing zoning
regulations.
Objective LU-1.5 Land development regulations will protect
the city's unique natural and coastal resources, its
neighborhoods, and its historic and cultural heritage. _ _
Policy LU-1.5.3 Notice of applications to change current
zoning regulations generally and on a parcel(s) of land as well
as decisions and recommendations on said applications of the
zoning or planning administrators and planning/zoning boards
and committees mailed by the property owner seeking the
change to property owners within 500 feet of the subject
property and to registered neighborhood/homeowner
associations within the NET (Neighborhood Enhancement
Team) districts will serve to protect neighborhoods. Failure to
give such notice shall negate any changes to the zoning
regulations.
240
Read on Behalf of Barbara Bisno
Notice requirements are appropriately a part of the city code of ordinance, not
the MCNP, and are regulated in part by state law. The language proposed in
the comment goes beyond what is required by either state law or the existing
city code. Therefore, the consultants recommend that this comment not be
included.
This comment is identical to Objective LU-1.5 in the MCNP. It is unclear what
the concern/comment may be.
Notice requirements are appropriately a part of the city code of ordinance, not
the MCNP, and are regulated in part by state law. The language proposed in
the comment goes beyond what is required by either state law or the existing
city code. Therefore, the consultants recommend that this comment not be
included.
Page 42