HomeMy WebLinkAboutSubmittal-URS Technical MemorandumTECHNICAL MEMORANDUM
REVIEW OF APPLICATIONS FOR BROWNFIELDS DESIGNATIONS
CITY OF MIAMI
November 20, 2013
prepared by The Goldstein Environmental Law Firm, One Southeast Third Avenue, Suite 2120,
Miami, Florida 33131, dated February 22, 2013.
Brownfields Sites and Brownfields Area
"Brownfield sites" means real property, the expansion, redevelopment, or reuse of which may be
complicated by actual or perceived environmental contamination. (Section 376.79(3), F.S.)
"Brownfield area" means a contiguous area of one or more brownfield sites, may not be contaminated,
and which has been designated by a local government by resolution. Such areas may include all or
portions of community redevelopment areas, enterprise zones, empowerment zones, other such
designated economically deprived communities and areas, and Environmental Protection Agency -
designated brownfield pilot projects. (Section 376.79(4), F.S)
None of the redevelopment sites that are proposed for brownfields designation are contaminated. If the
permitting agencies had perceived any environmental contamination on the three sites proposed for
designation, there would have been delays and additional restrictions on the property for construction
such as limits on dewatering.
There are three (3) reported contaminated sites in the applications for the brownfields designation. The
attached Figure show their locations in reference to the redevelopment projects requested for
brownfields designation.
1. CITGO site at 190 SW 8th Street for the designation of 850 SW 2"d Avenue, Vista Grande
Apartments and 144-152 SW 8th Street, West Brickell View Apartments
2. Former Exxon station at 702 SW 2"d Avenue for the designation of 850 SW 2nd Avenue, Vista
Grande Apartments and 144-152 SW 8th Street, West Brickell View Apartments
3. BP/Brickell Trading Post fueling station at 1245 SW 2"d Avenue for the designation of 1026 SW
2nd Avenue, West Brickell Towers
Another 1000 gallon diesel UST at 1105 SW 2"d Avenue has been reported by the applicant but only
as a potential source of contamination for 1026 SW 2nd Avenue, West Brickell Towers.
None of the contaminated sites reported above have been known to contaminate the redevelopment
projects, and have responsible parties to further assess them or remediate them under the State funded
program or otherwise. The West Brickell View Apartments project that is closest to the CITGO property
is under the state -funded petroleum cleanup program. This project did not present any evidence of
contamination from the CITGO site during the Phase II environmental assessment completed by the
13- ex) 74g
/.� - 0072/, . /11 # / tii% T&Chr)ll / Submitted into the public
pp f1Z mem0vandvh-) record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
Wage
TECHNICAL MEMORANDUM
REVIEW OF APPLICATIONS FOR BROWNFIELDS DESIGNATIONS
CITY OF MIAMI
November 20, 2013
developer. It is not uncommon for Miami -Dade County Department of Regulatory and Economic
Resources (RER) to request drainage plans for any redevelopment or construction projects in the
immediate vicinity of contaminated sites. We do not believe the request to review drainage plans from
RER was any reason to cause any "complications" for the redevelopment project.
Legislative Intent
The Brownfields Redevelopment Act (Act) was established by the Florida Legislature in 1997 (Chapter
97-277, L.O.F.). The primary goals of the Act were to reduce public health and environmental hazards on
existing commercial and industrial sites that are abandoned or underused due to these hazards; create
financial and regulatory incentives to encourage voluntary cleanup and redevelopment of sites; derive
cleanup target levels and a process for obtaining a "No Further Action" letter; and provide the
opportunity for Environmental Equity and Justice. The goal was to address properties that presented
conditions of blight on the local community.
When the Florida Legislature first enacted the Florida Brownfields Redevelopment Act, their key findings
and declarations, as stated in the Section 376.78 were:
Section 376.78(1), Florida Statutes: The reduction of public health and environmental hazards on
existing commercial and industrial sites is vital to their use and reuse as sources of employment, housing,
recreation, and open space areas. The reuse of industrial land is an important component of sound land
use policy for productive urban purposes which will help prevent the premature development of
farmland, open space areas, and natural areas, and reduce public costs for installing new water, sewer,
and highway infrastructure.
Section 376.78(2), Florida Statutes: The abandonment or underuse of brownfield sites also results in the
inefficient use of public facilities and services, as well as land and other natural resources, extends
conditions of blight in local communities, and contributes to concerns about environmental equity and
the distribution of environmental risks across population groups.
Section 376.78(8) Florida Statutes: The existence of brownfields within a community may contribute to,
or may be a symptom of, overall community decline, including issues of human disease and illness, crime,
educational and employment opportunities, and infrastructure decay. The environment is an important
element of quality of life in any community, along with economic opportunity, educational achievement,
access to health care, housing quality and availability, provision of governmental services, and other
socioeconomic factors. Brownfields redevelopment, properly done, can be a significant element in
community revitalization.
3IPage
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21113
Todd B. Hannon
TECHNICAL MEMORANDUM
REVIEW OF APPLICATIONS FOR BROWNFIELDS DESIGNATIONS
CITY OF MIAMI
November 20, 2013
Brownfields Designation Process
Section 376.80(2)(b)(1-5), Florida Statutes, states that a local government shall designate a brownfield
area under the provisions of this act provided that:
1. A person who owns or controls a potential brownfield site is requesting the designation and has
agreed to rehabilitate and redevelop the brownfield site;
2. The rehabilitation and redevelopment of the proposed brownfield site will result in economic
productivity of the area, along with the creation of at least 5 new permanent jobs at the
brownfield site...; However, the job creation requirement shall not apply to the rehabilitation
and redevelopment of a brownfield site that will provide affordable housing...;
3. The redevelopment of the proposed brownfield site is consistent with the local comprehensive
plan and is a permittable use under the applicable local land development regulations..;
4. Notice of the proposed rehabilitation of the brownfield area has been provided to neighbors
and nearby residents of the proposed area to be designated, and the person proposing the area
for designation has afforded to those receiving notice the opportunity for comments and
suggestions about rehabilitation...;
5. The person proposing the area for designation has provided reasonable assurance that he or she
has sufficient financial resources to implement and complete the rehabilitation agreement and
redevelopment of the brownfield site.
URS Review of Applications for Designation as Brownfields
URS conducted a review of the applications and supporting documentation, as listed in this
memorandum. Our review indicates that the applications support the criteria for the designation of the
three (3) parcels as brownfields areas; however, they do not meet the intent of the legislature and their
key findings when the Act was established, for the following reasons:
1. Urban infill is already occurring in the Brickell West area without brownfield designations. There
is no evidence of blight in the local community.
2. Currently, 2,190 units are planned or underway in immediate vicinity, and resources are not
underutilized.
3. Area already experiencing significant development without the need any regulatory or financial
incentives available from the brownfields designation process.
4. Redevelopment activities do not indicate anything beyond normal risks faced by a developer in
urbanized area.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
4IPage
TECHNICAL MEMORANDUM
REVIEW OF APPLICATIONS FOR BROWNFIELDS DESIGNATIONS
CITY OF MIAMI
November 20, 2013
The following is a summary of the sales history qualified by the Property Appraiser's Office as a result of
examination of the deed.
1. Property Location: 144 SW 8th Street
Folio: 0102050701060
Proposed Development Site: 144-152 SW 8th Street, West Brickell View Apartments
Sales Date
Amount
9/2012
$1,625,000
10/1999
$400,000
9/1990
$337,600
9/1971
$23,000
The history of sales for this parcel clearly indicates that it has significantly appreciated in value
over the years with no indication of abandonment or underutilization of the property.
2. Property Location: 152 SW 8`h Street
Folio: 0102050701070
Proposed Development Site: 144-152 SW 8th Street, West Brickell View Apartments
Sales Date
Amount
9/2012
$1,625,000
11/1999
$380,000
11/1977
$52,000
The history of sales for this parcel clearly indicates that it has significantly appreciated in value
over the years with no indication of abandonment or underutilization of the property.
3. Property Location: 850 SW 2nd Avenue
Folio: 0102050801150
Proposed Development Site: 850 SW 2nd Avenue, Vista Grande Apartments
Sales Date
Amount
9/2012
$3.500,000
10/2003
$2,500,000
11/1998
$900,000
The history of sales for this parcel clearly indicates that it has significantly appreciated in value
over the years with no indication of abandonment or underutilization of the property.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11 21 13
Todd B. Hannon
Wage
TECHNICAL MEMORANDUM
REVIEW OF APPLICATIONS FOR BROWNFIELDS DESIGNATIONS
CITY OF MIAMI
November 20, 2013
4. Property Location: 1026 SW 2nd Avenue
Folio: 0141380510110
Proposed Development: 1026 SW 2nd Avenue, West Brickell Tower Apartments
Sales Date
Amount
10/2012
$950,000
8/2010
$365,000
3/2005
$136,667
12/1988
$170,000
6/1974
$80,000
4/1973
$70,000
The history of sales for this parcel clearly indicates that it has significantly appreciated in value
over the years with no indication of abandonment or underutilization of the property.
Conclusions and Recommendations
Based on our review of the applications received by the City of Miami for designation of the three (3)
parcels described above, URS is providing the following conclusions and recommendations:
1. None of the three (3) parcels provide any evidence of contamination on -site or presented
conditions of blight to the surrounding community prior to commencement of redevelopment
activities. In fact, the sale prices, based on the County Property Appraiser's web site, have
steadily been increasing through the years;
2. Based on the number of planned, approved and on -going redevelopment activities taking place
in the Brickell West area, there do not appear to be any need for regulatory or financial
incentives that are provided by the Florida Brownfields Redevelopment Act.
3. The documentation provided by the applicant meets the criteria for designation of the three (3)
parcels as brownfields area, based on Section 376.80(2)(b)(1-5), Florida Statutes; however, in
URS' opinion, they do to meet the intent of the Florida Brownfields Redevelopment Act, as
provided in Section 376.78, Florida Statutes.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
Wage
TECHNICAL MEMORANDUM
REVIEW OF APPLICATIONS FOR BROWNFIELDS DESIGNATIONS
CITY OF MIAMI
November 20, 2013
Based on these observations, URS believes that the three (3) parcels under consideration for designation
as brownfields do not meet the legislative intent of Section 376.78, Florida Statutes. We are, therefore,
recommending that the applications be denied.
Prepared by:
VA-4, L....,„)(T-:
Vivek "Vik" Kamath, P.E.
URS Corporation
7650 Corporate Center Drive, Suite 400
Miami, Florida 33126
Tel: 305.884.8900
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
7IPage
CITGO"
19O S W; 8th Street
Former Exxon Station ' �e
702SW2nAvenue,
it
iY
nn sc , - -
152 SW 8th'Street
144 SW 8th'Street
-AZT I (Feet i
0 100 200 400 600 800
Requests for
Brownfield Area
Designation per
Florida Statutes
376.77-86
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
What Are Brownfields?
Redevelopment tool for blighted properties
that results in:
Economic and Community Development
Increase Property values
Reduction of Public Health and
Environmental Hazards
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
Florida Brownfields
Redevelopment Act
Established by the Florida Legislature in 1997
as Chapter 1997-277, Laws of Florida, with
primary goals:
To reduce public health and environmental
hazards on existing commercial and
industrial sites that are abandoned or
underused due to these hazards;
To create financial and regulatory incentives
to encourage voluntary cleanup and
redevelopment of sites.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11L21/13
Todd B. Hannon
Brownfield Program Benefits
"It is the intent of the Legislature that brownfield
redevelopment activities be viewed as opportunities to
significantly improve the utilization, general condition and
appearance of these sites." F.S. 376.84 Brownfield Redevelopment Economic Initiatives
Florida's Brownfield program offers businesses and developers
financial incentives to clean up and redevelop a brownfield site
including:
• Sales Tax Credit on building materials
• $2,500 Job Bonus Refund
• State Loan Guarantees
Brownfield Area benefits administered by Enterprise Florida, Inc.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
Florida Brownfield Redevelopment Act
Florida Statutes 376.77 - 376.86
Definitions:
o "Brownfield sites" means real property, the
expansion, redevelopment, or reuse of which may be
complicated by actual or perceived environmental
contamination. (376.79(3) F.S.)
"Brownfield area" means a contiguous area of one or
more brownfield sites, may not be contaminated, and
which has been designated by a local government by
resolution. Such areas may include all or portions of
community redevelopment areas, enterprise zones,
empowerment zones, other such designated
economically deprived communities and areas, and
Environmental Protection Agency -designated
brownfield pilot projects. (376.79(4)F.s.)
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
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City Brownfield
Designated Area
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
Brownfields Designation Process
Section 376.80(2)(b)(1-5), Florida Statutes "A local government shall
designate a brownfield area under the provisions of this act
provided that:"
1. A person who owns or controls a potential brownfield site is requesting the designation and has
agreed to rehabilitate and redevelop the brownfield site;
2. The rehabilitation and redevelopment of the proposed brownfield site will result in economic
productivity of the area, along with the creation of at least 5 new permanent jobs at the
brownfield site...; However, the job creation requirement shall not apply to the rehabilitation and
redevelopment of a brownfield site that will provide affordable housing...;
3. The redevelopment of the proposed brownfield site is consistent with the local comprehensive
plan and is a permittable use under the applicable local land development regulations.;
4. Notice of the proposed rehabilitation of the brownfield area has been provided to neighbors and
nearby residents of the proposed area to be designated, and the person proposing the area for
designation has afforded to those receiving notice the opportunity for comments and suggestions
about rehabilitation...;
5. The person proposing the area for designation has provided reasonable assurance that he or she
has sufficient financial resources to implement and complete the rehabilitation agreement and
redevelopment of the brownfield site.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
Legislative Intent
F.S. 376.78(1-9), "Legislative Intent - The Legislature finds
and declares the following:"
(1) "The reduction of public health and environmental hazards on existing commercial and
industrial sites is vital to their use and reuse as sources of employment, housing, recreation,
and open space areas..." - Urban infill already occurring in the Brickell West area
without brownfield designations.
(2) "The abandonment or underuse of brownfield sites also results in the inefficient use of
public facilities and services, as well as land and other natural resources, extends conditions
of blight in local communities..." - Currently 2,190 units planned or underway in
immediate vicinity and resources are not underutilized.
(3) "Incentives should be put in place to encourage responsible persons to voluntarily develop
and implement cleanup plans without the use of taxpayer funds..." - Area already
experiencing significant development.
(4) "Site rehabilitation should be based on the actual risk that contamination may pose to the
environment and public health..." - Facts surrounding properties do not indicate
anything beyond normal risks faced by a developer in urbanized area.
(9) "Cooperation among federal, state, and local agencies, local community development
organizations, and current owners and prospective purchasers of brownfield sites is required
to accomplish timely cleanup activities and the redevelopment or reuse of brownfield sites." -
City was unaware of developer's intent to request designation until after
construction had commenced.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
CT ST
C2t 3fl2Pv
SW 12TH S i ..
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
1448152SNSET
SISSOFISISIN PLANWP110 DEPAR SENT
800 >>ema
RIOIYS OISIEdT'.81 L 1u 162 111nal11 ST 1026 S W 2 ST Ss0 !W 2 AY.IOm
Legend
WEST BRICKELL PROJECTS 21113
tutus mil 2.111M11sasNsile1 UMW
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- Ott r bawl - lww+rY Ier
11.111 wYe1WTv. lwordrer.um saes
144-152 SW 8th Street
West Brickell View Apartments
Affordable Housing development currently under
construction - 64 one and two bedroom units
(master building permit issued 8 / 31 / 2012) .
First Inspection (Foundation) done on
12/ 1 /2012.
Brownfield designation request received on
December 28, 2012.
Previous structures consisted of restaurant and
audio retail store (demolition permit issued
9/28/2012).
Located adjacent to a contaminated gas station with groundwater
plume not affecting subject property. No documentation provided of
contaminated groundwater infiltrating.
Miami Dade Department of Regulatory and Economic Resources
(RER) requested drainage plans during permitting process. This is
their standard procedure whenever there is construction or
redevelopment in the vicinity of contaminated sites.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
1026 SW 2nd Avenue
West Brickell Tower Apartments
3 Affordable housing development under
construction, 32 one & two bedroom
units (master building permit issued
9/5/2012).
o Previous structures consisted of
residential apartment units (demolition
permit issued 12/ 11 /2012).
o Brownfield designation request received
on December 28, 2012.
0 No evidence of threat to or groundwater
contamination on subject property.
o Miami Dade Department of Regulatory
and Economic Resources (RER) did not
acknowledge any onsite contamination
during permitting process.
to
1
kit
Ada
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/13
Todd B. Hannon
11
850 SW 2nd Avenue
Vista Grande Apartments
o Affordable Housing development under
construction 89 one and two bedroom
units(master building permit issued
8/31/2012).
Previous structures consisted of
residential apartment units (demolition
permit issued 9/28/2012).
o Brownfield designation request
received on December 28, 2012.
o No evidence of threat to or
groundwater contamination on subject
property.
o Miami Dade Department of Regulatory
and Economic Resources (RER) did not
acknowledge any contamination issues
during permitting process.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11 21 13
Todd B. Hannon
Conclusion
The three (3) parcels being considered for
designation as brownfields do not meet
Legislative Intent per Section 376.78, FS.
There is no evidence that the parcels proposed for
designation as brownfields were:
o Abandoned or underused resulting in the inefficient use of
public facilities and services, as well as land and other natural
resources;
or
o Presented conditions of blight in the local community.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11 21 13
Todd B. Hannon
Recommendation
It is recommended that the applications
be denied since they do not meet
legislative intent and all the provisions of
the Brownfields Redevelopment Act.
Submitted into the public
record in connection with
item PH5., PH.6 & PH.7 on 11/21/1 3
Todd B. Hannon