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HomeMy WebLinkAboutCity Staff Memo Re Amended Staff Analysis & Applicant's ResponseCITY OF MIAMI, FLORIDA INTER -OFFICE MEMORANDUM TO: Francisco J. Garcia DATE: October 25, 2018 Director, Planning Department FROM: Sue Trone Chief, Comprehensive Planning FILE: SUBJECT: Magic City Innovation District SAP Comprehensive Plan Amendment Staff Analysis and Applicant's Addressing of Inconsistencies REFERENCES: Staff Analysis ENCLOSURES: INTRODUCTION AND BACKGROUND The application submitted for the Future Land Use Map (FLUM) change necessary for the consideration of the SAP application for the Magic City Innovation District was analyzed by the Community Planning Division for the Planning, Zoning, and Appeals Board (PZAB) hearing of July 18, 2018. The staff report presented for this hearing resulted in an analysis that utilized 14 criteria from the Miami Comprehensive Neighborhood Plan (MCNP) based on its goals, objectives and policies. At that time, the report found an equal number of consistencies and inconsistencies. The staff report urged careful consideration of the conditions recommended with the companion rezoning item in the SAP application, which would cure the inconsistencies. This memo addresses changes to the application which have occurred in the time which has passed since the PZAB hearing, curing inconsistencies to the proposed comprehensive plan amendment. SUMMARY OF INCONSISTENCIES The staff report seven inconsistencies with the MCNP that can generally be characterized in the following ways: (1) Depleting the City of industrial land uses; (2) Working counter to the City's goals for affordable housing solutions; (3) Missing opportunities to support Transportation Control Measures; and (4) Proposing development without paying an equitable, proportional share for the cost of parks. DEVELOPER RESPONSES Since the July 18 hearing at PZAB, the Applicant has worked diligently to address the inconsistencies with the MCNP. Staff finds that, as of the date of this memo, six of seven criteria are now consistent. The table below summarizes the criteria by identifying the Goal, Objective, or Policy referenced from the MCNP and how the Applicant has addressed the inconsistency. Summary of Inconsistent Findings for the Magic City FLUM Application as of July 2018 and Current Findings (October 2018) Criteria that were found to Summary of relevant Goal, Objective or Policy from MCNP Current findings since Applicant redress be Inconsistent at PZAB July 2018 October 2018 Objective LU-1.3(Criteria 2) Policy LU-1.1.3 (Criteria 3) Encouragement of commercial, office, and industrial development in areas that already have such development, including the encouragement of industrial activity where existing public facilities can meet or exceed minimum standards for LOS; Protection of all areas of the city from encroachment of incompatible land uses.... Objective LU-4.1, LU-4.2, LU- Objectives LU-4.1 through LU-4.3 establish percentages of 4.3 (Criteria 4) housing stock to be built for mixed -income developments, for elderly populations with limited incomes, and low- and workforce populations. Goal HO-1 (Criteria 5) Policy TR-1.5.2 (Criteria 11) Policy TR-2.2.9 (Criteria 12) Objective PR-1.5 (Criteria 13) Goal HO-1 esta blishes the basic need for increasing the supply of affordable housing, especially for extremely low - through low-income populations through new housing and rehabilitating existing housing. PolicyTR-1.5.2 Requires new developments to implement new transportation control measures to promote reduction in vehicular traffic. PolicyTR-2.2.9 establishes a standard in which the City considers income, age, ability, and car ownership throughout the city when developing transportation systems and facility improvements to increase affordable travel options. Objective PR-1.5 established Park Impact Fees. The Development Agreement prior to PZAB proposed that the Developer would be credited this impact fee. The Applicant's original application was to change all land in the 16.08-acre area to Restricted Commercial. At PZAB, the Applicant changed the request to General Commercial. General Commercial as a Future Land Use designation allows some select light industrial uses. General Commercial cures these inconsistencies. These are now CONSISTENT. The Applicant's development agreement provides for affordable housing and workforce housing a provision 16. These provisions are presented as percentages of "Habitable Space of Dwelling Units." In a 16+ acre area that will go from having zero dwelling units to over 2,600 dwelling units, within a study area in which the majority of households have incomes under $10,000. The applicant is not expected to match all the percentages of the referenced objectives because those objectives are citywide; however, dedicating habitable space for income restricted units will not meaningfully address this inconsistency as a proffer from the Applicant to reserve enumerated dwelling units. These criteria remain INCONSISTENT. The Applicant is making provisions for affordable and workforce housing in an area of the city with a great need for this type of housing. This goal is now CONSISTENT. The Applicant has worked with the City and offered Transportation Control Measures (TCMs) which have been accepted by the Office of Capital Improvements. A Transportation Sufficiency Letter was written on August 21, 2018 memorializing the Applicant's TCMs as acceptable. This cures the staff report's findings of inconsistency. This criteria is now CONSISTENT. The reference to Park Impact Fee credits have been deleted from the Developer Agreement. This cures the inconsistency. This criteria is now CONSISTENT. CONCLUSION The table above shows that the Applicant has brought all criteria into consistency except Criteria 4, relating to Objective LU-4.1, Objective LU-4.2, and Objective LU-4.3, which pertain to mixed -income, affordable housing dwelling units for elderly populations, and low- and workforce- housing dwelling units. A portion of the SAP is income restricted by habitable space; however, to cure this inconsistency, the Planning Department would look for the Applicant to proffer percentages of dwelling units. Staff in the Community Planning Division are available to assist if any questions arise.