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LAW OFFICES OF
SWEETAPPLE, BROEKER & VARKAS, P.L.
DOUGLAS C. BROEKER, P.A,
44 W. FLAGLER STREET - SUITE 1500
MIAMI, FLORIDA 33130
Telephone (305) 374-5623
Facsimile (305) 358-1023
ATTORNEYS:
ROBERT A. SWEETAPPLE *, **
DOUGLAS C. BROEKER
ALEXANDER D. VARKAS, JR.
KADISHA D. PHELPS
ASHLEIGH M. GREENE
ALEXANDER D. VARKAS, III
BERKLEY SWEETAPPLE VITALE
* BOARD CERTIFIED BUSINESS LITIGATION ATTORNEY
** BOARD CERTIFIED CIVIL TRIAL ATTORNEY
Miami City Commission
c/o Hearing Boards
3500 Pan American Drive
Miami, Florida 33133
June 22, 2016
SWEETAPPLE & VARKAS, P.A.
20 S.E. 3"O STREET
BOCA RATON, FLORIDA 33432
Telephone (561) 392-1230
Facsimile (561) 394-6102
PARALEGALS:
CYNTI-IIA BAILEY
DEBORAH SMITH
MERLANDE MOISE
CARLA M. MIRO
Please Reply to Miami Office Email;
Doug@broekerlaw.com
Kadisha(Ebroekerlaw,com
Ashleigh f_,broekerlaw.com
Merlande@broekerlaw.com
CarlaNbroekerl aw. com
Re: 545 NE 55 Terr — Construction of a New Single Family Home
Dear Commissioners:
This is an appeal of the decision of the Historic and Environmental Preservation Board
("HEPB") with regard to the currently proposed construction on the vacant lot at 545 NE 55th
Terrace, Miami, Florida [June 7, 2016 Agenda Item HEPB.4.] This Appeal is on behalf of my
wife, Melanie and me, as residents at 538 NE. 55th Terrace, and our neighbors, Judy Miller &
Caroline R. Meek at 537 NE 55th Terrace; Obdulio Menendez & Maria De Los A. Menendez at
555 NE 55th Terrace; Anthony M. O'Rourke at 530 NE 55th Terrace; Sahara M. Portales at 531
NE 55th Terrace; Jesus I. & Sandra I. Menendez at 511 NE 55th Terrace; Christopher & Kara
Culbert at 560 NE 55th Terrace; and Maria T. Fernandez at 520 NE 55th Terrace; I am including
a list of property owners within 500 feet and HOA Associations. I am handling this Appeal pro
bono, so I am not acting as a Lobbyist.
The proposed construction is within the Morningside Historic District. This Historic
District has been in place since 1984 and enforcement efforts by the City have served to preserve
the unique architectural character of this neighborhood. For all of us who have lived here during
this timeframe (1985 is when Melanie and I bought our house), we have been held to very high
standards of maintenance, design and other aesthetic aspects of our homes. When we re -roofed,
we needed approval for the type and shade of tile. When we repainted, we needed approval for
the color. When we changed the windows, we needed approval for the design and were required
to change several windows to casements, and add muntin bars to many. When we changed our
Miami City Commission
June 22, 2016
chain -link fence for a more attractive metal fence, we still needed approval and design changes
were required.
In light of the consistent efforts of City administrations over 30 years to preserve the
architectural integrity of this Historic District, it is shocking to us that the HEPB would approve
the design of a house with incongruous massing and design features in the midst of historic
homes of architectural significance. As set forth in the Momingside Civic Association's
Architectural Review Committee's letter to HEPB dated June 4, 2016 which is attached, the
design cues on the proposed home are not fully developed and unified in a cohesive manner. The
front facade contains' very few architectural features and embellishments or elements. The
massing on the front facade is lacking in architectural cues, features or embellishments, has
limited glass window visible, excessive or monotonous use of materials, and lacks appropriate
roof lines. Also, the scupper design will likely result in unsightly staining of this massive wall
facade in the coming years. Finally, the full two-story front facade is inappropriately massed
along the front setback line.
that:
Your staff, in its Report and Recommendation, a copy of which is attached hereto, stated
"Both the 1964 Venice Charter and the Secretary of the Interior Standards
for Historic Preservation that were first issued in 1977, state that new
construction in historic districts be differentiated from the original historic
fabric. New construction projects should not duplicate a style from the
past, but should rather compliment with the use of materials found within
the district as well as architectural features that are common in the
surroundings. Additionally, it is important that new construction projects
fit in with the overall sense of scale of the district, and compliments its
surroundings with appropriate massing and setbacks."
We believe that this design does not fit in with the overall sense of scale of the District and does
not complement its surroundings with appropriate massing, setbacks, materials or features. We
note that the staff report to the HEPB stated that the "the subject property is a 9,000 sq. ft.
undeveloped lot." In fact, the property is a 6,600 sq. ft. lot. The lot is unusually narrow.
Moreover, this 3500 sq. ft. proposed home is substantially larger than all of the surrounding
homes, most of which are on significantly larger lots. For example our home, which is across the
street, is less than 3000 sq. ft. and is on an 11,825 sq. ft. lot. This oversized home on a small lot,
massed to just have a wall at the front, all essentially on the front lines, is not the correct massing
for this particular lot.
At the meeting, Members of the HEPB commented that the project looked like it incorporated a
"hodgepodge" or "smorgasbord" of features from other Morningside homes [which, together,
might not present a project congruous with the historic district.] In response, the staff advised the
board multiple times that new construction in a historic district must be "differentiated" from
existing structures. In fact, the Secretary of Interior's Standards for new buildings in historic
districts (Standard 9) require new construction to be "differentiated and compatible" so that new
designs harmonize with their historic settings. We believe inadequate weight was given to the
LAW OFFICES OF SWEETAPPLE, BROEKER & VARKAS,
44 W. FLAGLER STREET, SUITE 1500, MIAMI, FLORIDA 33130
2
Miami City Commission
June 22, 2016
compatibility issue; criteria were not considered that enable new buildings to be designed in a
manner that is consistent with the character of a historic district regardless of architectural style.
This proposal is not good for the City, or for the neighborhood. Many of us have worked
very hard on many aspects of our greater neighborhood, to enhance the quality of life. As a
result, property values have increased significantly. This translates to increased property tax
revenue for the City. We are very concerned that destroying the historic character and integrity
of the Morningside Historic District will result in a decrease in property values which would
mean a decrease in revenue to the City, as well.
The Morningside neighborhood has 5 blocks of houses that are outside of the Historic
District and where such designs might be appropriately constructed. However, within the
Historic District, this design is incongruous and inappropriate. We ask you to accept our appeal
and vacate the decision of the HEPB.
Thank you for your consideration to this matter.
Sincerely,
DOUGLAS C. BROEKER, ESQ.
DCB/
Enclosures
cc: Megan Schmidt, Preservation Officer, City of Miami
Jose Esparza and Egdalis Blanco de Esparza
55 Terr Momingside LLC
c/o German Brun, AIA
DEN Architecture
1477 S.W. 14th Terrace
Miami, FL 33145
Property Owners within 500 feet (labels provided herewith)
LAW OFFICES OF SWEETAPPLE, BROEKER & VARKAS, P.L.
44 W. FLAGLER STREET, SUITE 1500, MIAMI, FLORIDA 33130
3
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Architectural
June 4th, 2016
SSOCI ation
Review Committee
David Holtzman
Robert Graboski
Naomi Burt
Elvis Cruz
Cyril Bijaoui
City of Miami Planning and Zoning — Preservation Officer & Historic Board Members
444 SW 2nd Avenue, 3rd Floor
Miami, FL 33130
Subject: - 545 NE 55 Terr — Construction of a New SngIe Family Home
Dear Preservation Board,
The Morningside Civic Association's (MCA) Architectural Review Committee (ARC) has reviewed the
subject COA for this proposed new, approximately 3500 sq. ft singly family home on a 6,660 sq. ft.
interior lot (incorrectly stated as 9,000 sq. ft. in the Staff Report).
Firstly, we would like to thank the applicant for reaching out and meeting with the ARC for input prior to
submitting their application. The ARC provided feedback, and the applicant did try to incorporate some
of those ideas into the plans that are now before you. Staff after making a thorough review of this
application has recommended the approval of the plan as submitted. Unfortunately, the ARC does not
agree with this position.
The proposed home is modern in design with cues coming from several design styles found in
Morningside which range from Art Deco and Streamline Moderne style for the building massing with
details crossing over into the Spanish Mediterranean and Mission style. Unfortunately, those cues are
not fully developed in a unified or cohesive manner in this application. The main architectural features
and embellishments are limited to an eyebrow which frames an open brick latticework wall enclosing
the front entry porch next to a flush panel garage door, a second story window covered with brick lattice
work and balcony with stucco railing and eyebrow. The front facade is capped with a stucco band and
the higher parapet for equipment is beyond.
When bolding at successful versions ofmodern architecture, the visual interest and fanciful nature of
the style is apparent even to the layman. These rich homes contain elements such as opposing
structural boxes, differing facade elevations, heights and setbacks, walls textured finishes, structural
projections, exposed structural beams or columns, and many others elements that when brought
together, create a well thought ,out and unified design.
Nehave the following recommendations and request that the HEPBoard defer the approval ofthis item
for the applicant to consider the neighborhood concerns that we feel will improve the design:
• Takinga cue from the massing of art deco or streamline architecture where a corner of the front
facade may incorporate oradius rather than90 degree corner and could heincorporated into
the moabwxe-a"omrmer,
* The South Fron1fugode has limited glass window visible and' the fenestration is an 'important
feature of the residential building mass where we request more open window glass visible.
• The concrete block and stucco balcony railing and parapets add to the mass of this home and
another material could beused tobreak upthe stucco wall expanse.
• Themassing ofmultiple flat roof parapets behind one another at multiple heights with little or
nodetiiOs�whemmumercqk test. a beftesroof line
• The scuppers on the balcony above the garage tends tonot age well nnmmodern home due to
the rain in our climate, it is suggested to perhaps drain to the East rather than to the South to
avoid water stains.
* The ARC and immediate neighbors to the East and West would like to see o better
representation of modern architecture with o more residential massing, fenestration and roof
line incorrporated suthat itwill make hmore congruous xvKhintbehistoric district and less Vf
what is being perceived as a cold 'square-ish! rectangular concrete box with screens.
In Suo,nf�ranry, we hope our commentary is constructive and results inthe evolution ofthis design into
something that is not only great for the Mornings|de neighborhood, but vastly improved fGr the
applicant as well.
.Architectural Review Committee