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HomeMy WebLinkAboutSubmittal-Jean Luc Adrien-Third Amended Statement of Objections and EvidenceSubmitted into the public f on record3���1 I�r it (s) P�. �C itylClerk Please see attached Family Action Network Movement's (FANM) "Third Amended Statement of Objections & Evidence on Magic City Innovation District Special Area Plan." Below, please find a very brief summary of the statement. Within the statement. text in red delineates any new text changed or added since last submission. General Concerns: • The $31 million deal that has been negotiated in the revised Development Agreement must be closely scrutinized and assessed for its value to the City of Miami: o There is a lack of on -site affordable and workforce housing o $31 million is less than the estimated $41 million value of the housing benefit the Developer intended to provided in the previously proposed benefits package.' • Speculation and price distortion of residential properties in Little Haiti is increasing: o Data compiled the the University of Florida's Shimberg Center for Housing Studies suggest that speculation in Little Haiti, devastated by a high number of distress sales (foreclosure or tax deed related sales), is on the rise.' • Nothing has been presented to evaluate the potential environmental impacts of this project • The City must considering the impact of approved and pending SAPs together. To analyze them individually would be to ignore the cumulative impact of all projects together on the surrounding neighborhood with respect to such key things as traffic, displacement and density. The Magic City SAP is Inconsistent with the Miami Comprehensive Neighborhood Plan & the Miami 21 Zoning Code • Pursuant to Florida statute, the standard for determining the legality of comprehensive plan amendment is consistency. The chart on pages 7-11 of this Statement of Objections summarizes the Comp Plan Analysis and adds commentary based on changes that have taken place since the date of the analysis, including a column addressing the revised February 2019 Regulating Plan. • The Planning and Zoning Department staff submitted a Staff Analysis ("Zoning Analysis") for the zoning change, which approved the project and found it consistent with the zoning code subject to heavy conditions. This Statement of Objections offers a discussion of that analysis, which incorporates a granular critique of the Regulating Plan. There are numerous conditions prescribed by the Planning and Zoning Department staff incorporated into the ordinance that the City Commission will vote on. Some of these conditions appear to be contradictory to the revised DA and Regulating Plan. These inconsistencies must be addressed before the Commission votes on this ordinance. See Neisen Kasdin Powerpoint Presentation, submitted into the public record for the November 15, 2018 hearing on PZ items 1, 2, and 3, attached to this Statement as Appendix B, (the estimated value of the housing benefit the Developer intended to provided is listed as $41 million). 2 See Little Haiti Neighborhood Data Update (March 2019) by the Shimberg Center for Housing Studies ("Shimberg Data"), University of Florida is attached to this Statement as Appendix C. 41615vbtotta`- JtAr W(. tfltt Oi (AJtc+ion1 ahp �1nl�tntC 411d Submitted into the public record for it m(s) Z. on 5/ f 1 1 , Ci lerk THIRD AMENDED STATEMENT OF OBJECTIONS AND EVIDENCE ON MAGIC CITY INNOVATION DISTRICT SPECIAL AREA PLAN CITY OF MIAMI COMMISSION - PLANNING :.& ZONING MEETING MARCH 28, 2019 Agenda Items PZ 1, 2. ;i and/or 5, 6, 7 (First Readina.T) The Family Action Network Movement (FANM')l +)n behalf of itself and its members, submits the following Statement of Objections and Evidence in the quasi-judicial proceedings related to the Magic City innovation District Special Area Plan ("Magic City SAP") application presented by MCD Miami, q_,E:C ("Developer"). The first reading on this application for a Comprehensive Plan amendment, rezoning and approval is on the City of Miami Commission Planning and Zoning agenda for March 28, 2019. There is a procedural irregularity with respect to the items related to the Magic Cite SAP application, as it appears twice on the March 28, 2019 atgenda as PZ 1, 2. and 3 under one set of file ID numbers that traveled with the application since it came before the hearing boards- and again as PZ i, 6 and 7 (4667, 4668, 4716) under another set of tile ID numbers (5579, 5580. 5581) that were generated following the February 28, 2019 hearing that adjourned vvithout a vote. It is not clear which items will proceed forward given that the agenda items and their attachments appear to be identical,. thus this statement of objections and evidence should apply to and travel with the items that the Miami City Commission, should it decide to advance the items to second reading, votes to move forward.' A separate letter requesting intervenor status with facts and legal argument supporting FANM and its members' legally cognizable interests' that entitle them to intervenor status was submitted initially on September 24, 2018 and was resubmitted with amendments for the hearings scheduled thereafter. Though the intervenor status request will not take place on March 28, 2019 due to scheduling concerns of the requestors+ counsel, the letter has been wholly amended and was submitted to the Clerk on March 7, 2019 with exhibits and is attached hereto as Appendix A. This statement incorporates by reference all facts and arguments presented therein. A. INTRODUCTION FANM and its members are deeply concerned about the Magic City SAP application as currently proposed. While it boasts a number of exciting prospects for Miami, it does not do enough to Family Advocacy Network Movement, Inc. (FANM) is a Florida Not -For -Profit corporation located at 100 NE 841h Street, Miami, FL 33138 in Little Haiti. FANM has a long-standing commitment to meeting the needs of low to moderate -income families and children since 1991 throueh counseling, wrap around services, access to health care, community outreach/ education, job training/economic development, financial literacy, organizing & advocacy services. fibs is not the only procedural inegnlaritt that plagues this Item We have raised hefbre and raise main due proec . concerns to ,ar in . the fact that the bearings on the application before the t roan Design: Reeje'.t. Board (1IDRB) and the Planning and Zoning Appeals Board (PIAB )" t.;v ins in the SAP approsal trot:es; that should rake place on ditihrent days in order to give the public ample tune to adequately prepare i r vOtto tune lundantentafly different inquiries into the spplicairon weme ollapsed into one day On July tS, 201 S, the 1_lDR,B hettrittgtook plate ui an aus.ii.:n room of Miami City !tall tsscithunt adegriatc notice o1 the room chance[ in the afternoon. "rhe P/AB hearing v,es scheduling for the evening imntedratcly following the 1)DRB hearing, essentially presuming that the item would move tbrui:d without objection or quulitiwi.ori to the P/AB hettrimz step i herewere s tr?uall no nretriber Of the public present at the t li)RB incetinn both because the change in the meeting room was not conspicuously posted and the scheduling or the two hearings in the same day made it almost impossible (Or members of the public he able to ahead both. As stated in the Intervenor Status Request stihmitte<i on March 7.2010, multiple FANM members live or own businesses in the area surrounding the SAP property whose interests any impacted by this potential reconmg Fact, retarding the interests of at least one inembei ,r.r presented therein, with declarations. 1 Submitted into the p blic record for it m(s) Y --3� on _ 3/Z� / 11 City Clerk address the tremendous impact it will have on the surrounding neighborhoods, and on Little Haiti in particular. Eight years since the passage of Miami's form -based zoning code, Miami 21, we are witnessing the danger of the Special Area Plan, a zoning mechanism that allows any property owner with over nine (9) contiguous acres of land to bypass the zoning code and essentially rewrite the code that governs their property. The stated intent for this mechanism is to encourage streamlined, master - planned developments subject to increased process to encourage dialogue with the community. However, we see that as large scale development proposals creep into well -established neighborhoods like Little Haiti, far from the urban center downtown, Miami's cultural history is increasingly under threat. The economic pressure on land prices and rental rates caused by large SAPs can be dramatic, driving displacement of low-income, vulnerable residents and small business tenants. If not done right, with the proper mitigating policies tailored to the specific area, these developments can transform the character and demographics of a neighborhood in one fell 4 swoop. With one SAP already approved in Little Haiti5 and two large scale SAP applications pending over a 15-block stretch along NE 2nd Avenue,6 there is ample cause for alarm. This is what makes it imperative that we approach the Magic City SAP application in a measured, well-informed manner. This development has great precedential value for the other SAPs that may arise in the area. and for large scale developments in neighborhoods across Miami. As this Statement will show, the project is inconsistent in numerous ways with the Miami Comprehensive Neighborhood Plan (MCNP) and with the Miami 21 zoning code. The scale, density and intensity of the project are grossly out of proportion with the surrounding neighborhood, such that its impacts will ripple out far beyond the bounds of the SAP area in terms of traffic, noise, environmental impact and dramatic building height increases in a neighborhood largely zoned for building height no greater than five stories. Furthermore, the project risks deeply altering the housing affordability of Little Haiti as to land prices and rental rates, its demographics and cultural heritage. If it is passed as is. without mechanisms like on -site affordable housing to mitigate its potential impacts, it also risks running afoul of the federal Fair Housing Act. Notwithstanding the ,serious concerns and objections presented in this statement regarding the substance and process of the Magic City SAP application, the $31 million deal that has been negotiated in the revised Development agreement (DA) must be closely scrutinized and assessed for its value to the City of Miami. Some specific aspects/questions that must be resolved before moving forward with the project include: • Lack of on -site affordable and workforce' housing: • $31 million is less than the total value of benefits for the previously proposed benefits package. In .fact, in the Developer's Attorney Nelsen Kasdin's Powerpoint presentation submitted into the public record for the November 15, 2018 hearing on P7 items 1, 2, and https://www.miamiherald.com/news/local/community/miami-dade/article 126501109.html Miami Jewish Home and Hospital, located off of NE 2" Avenue across from what is now Design Place. While this SAP is also a significant development, the density and building heights (maximum 8 story buildings) proposed are far less than what is being proposed by Magic City and Eastside Ridge. The present pending Magic City SAP and the Eastside Ridge SAP at 54fh and NE 2" � Avenue. If it is to be workforce, it should not be set at an income level that will exceed current market rate, or in the 60-100% AMI range. 2 Submitted into the public record or it: m(s) t. A on 3 i C lerk 3, the estimated value of the housings benefit the Developer intended to provided is listed as $41 million. See Neisen Kasdin Powerpoint Presentation at 23. attached hereto as Appendix 13. • The payment schedule of any funds to be given as community benefits through the DA should disburse more money up front, and any forthcoming monies should be disbursed by calendar year, not as building permits are issued to ensure that there is clarity on when new payments will come and that the existing residents actually benefit from the money placed into the to -be -formed f...ittte Haiti Community Revitalization 'Trust. While theoretically there is value to establishing such a public trust, transparency and accountability must be paramount in its establishment. • An arbitrary calculation of total benefit amount, in exchange for allowing Developer to build to its full requested development capacity. If they are allowed to build to full capacity without tying the actual development to firm, enforceable commitments (like on -site affordable housing), the City will likely be granting more value in entitlements than it is receiving from this deal. c $4.03/square foot figure is not the product of any reasoned methodology about how to ensure a cash -in -lieu payment is adequate for the goals of community benefits„ such as inclusionary housing. • Even if we were to assume the $31 million dollars were being disbursed all at once and all dollars were to be spent on affordable housing, at a very conservative estimate of the construction cost of each housing unit at $150,000 per unit, the full amount of the benefit will produce only 207 units. This is compared to the 21 % total number of affordable/workforce units previously offered, which would have yielded a total 552 units (out of 2,630 proposed units). These $31 million should not replace but rather complement the on -site affordable and workforce (no greater than 100% AMI) units. • "Affordable"' is mentioned only once in the March 2019 DA in a provision with a long list of things for which the Little Haiti Community Revitalization Trust may be used. and is never mentioned in the revised Regulating Plan --- making it clear that the Developer is not intending to make this project inclusive on the premises. These are but a few glaring concerns that can be identified concerning the negotiated $31 million benefit. Clearly, this deal needs to be reworked for it to even begin to mitigate the significant impact that the development will have on the surrounding neighborhoods. B. BACKGROUND The proposed project, the Magic City SAP, is located within the neighborhood of Little Haiti. This project stands to impact not just the immediate surroundings of the SAP area, but the whole neighborhood of Little Haiti as defined by the census tract8, and particularly the area within the officially -designated bounds of Little Haiti.9 Data compiled the the University of Florida's Shimberg Center for Housing Studies suggest that https://statisticalatlas.coni/neighborhood/Florida/Miami/Little-Haiti/Population https://www.miamiherald.com/news/local/community/miami-dade/article80151417.html 3 Submitted into the public record fpr iteln(s) on C. Jerk speculation in Little Haiti, devastated by a high number of distress sales (foreclosure or tax deed rei,licd sale.;). is on the rise. Nledian property sales prices of single family homes have gone up in the period of 2010-2018 (Q2). 50°0 of all parcels zoned for residential use have been u1' ect to at least one sale in that same period. and owner -occupied residential properties decreased 10'!4, across the census tracts that make up the Little llaiti neighborhood. The detailed analysis ill the Little Haiti Neighborhood Data Update ([\larch 2019) by the Shimbere ('enter for Housing Studies ("Shirnberg Data''). L'niv-ersity of Florida is attached hereto as Appendix C. A large percentage of the tract of land that makes up the Magic City SAP area comes from what was formerly the Magic City Trailer Park, which was eventually closed and cleared of its 40 or so mobile homes in 2015.10 While the Developer presents this property as an "abandoned" trailer park. see Appendix B at I I. but for the purchase of the property by one of the major partners in this development project. Robert Zangrillo, the mobile homes then affordable to low-income residents might still he there. Other properties in the area were gradually acquired over time. resulting in the 17.75 acre assemblage that is now the subject of this SAP rezoning and Comprehensive Plan Amendment application. this speculation and price distortion of residential properties in Little Haiti will only he intensified a project the size and scale of the ylaeie City SAP. The density and intensity proposed in the application — approximately 2,630 residential units, 432 hotel rooms) 1 (or 201,600 square feet), 2,208,540 square feet of office space12, 520,970 square feet of commercial space, 119,610 square feet of expo space, 6,061 parking spaces, 215,493 square feet of civic space and additional 370,000 square feet for surplus parking (or 8,164,140 square feet total development on 17.75 acres) — is grossly out of proportion with the surrounding neighborhood and stands to permanently alter the lives of the residents and business owners in Little Haiti. Specific impacts include: • increased traffic caused by the proposed commercial, residential and entertainment uses of the property; • introduction of nuisances into the neighborhood, including noise, multiple alcoholic beverage establishments allowed in proximity to religious institutions and schools; • increased load on the public infrastructure, including roads, schools, potable water and utilities; • transformation of the skyline from one with few buildings higher than three stories to one with towering buildings jutting out of a relatively small area; and • a change in rental rates and land 2prices in a neighborhood populated by predominantly low to moderate income households' • a change in demographics of the Little Haiti neighborhood due to displacement and failure to pass policies to prevent outflux of low-income people of color due to rising housing costs. Nothing has been presented to evaluate the potential environmental impacts of this project. It is http://biscaynetimes.com/index. php?option=com_content&view=article&id=2051:the-passing-of-a-neighborhood&catid=50: community- news&ltemid=258 This number has varied between documents. 12 This number has varied between documents. 12 According to a 2015 Needs Assessment, 70% of Little Haiti residents are low to moderate income. See Planning Department Comprehensive Plan Amendment Staff Analysis ("Comp Plan Analysis") at 9. 4 Submitted into the public record for ite (s) on 3/1,V \ q . Ci lerk puzzling that an environmental impact statement is not a condition of approval of zoning/land use changes of this magnitude, but rather remains listed only as a condition of the issuance of a building permit. At the same time, the Developer has not proposed sufficient resiliency measures beyond the simple statement that the land happens to be located along a coastal ridge that is of relatively higher elevation. The revised DA and Regulating Ilan fall woefully short of the measures needed to mitigate the above -mentioned impacts on the surrounding neighborhood. The City can hardly justify granting what amounts to a windfall in development capacity by allowing the SAP rezoning and Comprehensive Plan amendments as presently written without realizing better, more enforceable and clearer benefits for the community. To do any Tess at a time when the City is facing a deep affordability crisis, overburdened roads and climate change issues would be to invite future problems that the City will be left to clean up without adequate resources. indeed, the fact that the most recent revised Regulating Plan and DA eliminate all reference to on - site affordable or workforce housing is deeply concerning. Not only does this raise potential fair housing issues. but it also fails to account for the reality of climate change and sea level rise in Miami that make inclusionary housing an essential climate adaptation measure that must be implemented for projects of this size and proposed density. As the maps on pages 14 and 15 of the Shimberg Data indicate, a large portion of Little Haiti sits on higher elevation in relation to the neighborhoods to the east; the City must begin making policy decisions that reflect the reality. that as sea level rises. these areas of the city are going to be in higher demand and more residents of all incomes and racial backgrounds - must have access to them to live and work. Finally, the other approved or pending SAPs in Little Haiti will intensify the impact of the Magic City proposal.14 (See Map 1 on next page) The SAPs (approved and pending1s) should not be analyzed individually but in relation to one another. To analyze them individually would be to ignore the cumulative impact of all projects together on the surrounding neighborhood with respect to such keys things as traffic, displacement and density. And yet, the Magic City SAP is moving quickly through a process purportedly designed to maximize community input without properly engaging in a community -wide dialogue about the nature of the project and without taking into adequate consideration the previously -voiced request that the City of Miami consider the impact of the projects together.16 �3nc, the Desinn District SAP is also technically it the Census tract of Little Haiti_ tee have included it in Map I though it is a farther d .,tancc from the project t11 question. As of the submission of this document the status of the Archbishop Curkey Noire Dame 1.110 School propert}' remams gtte5Uon. so tia.e h;tvc not htghiightcd it in Map i as a forthcoming SAP '6 While a member of the City start appeered to testify at the t-dhrttaty 28, 2010 hearing that the Cih is con,td,;i elf ±hr,c Na I's tog ther. the documentation containing the staffs anuissts does not mentiotl this or present am findings with respect lioo this application must dianiii,e n} account for proposed intense developnteni i!t the areas surrounding the Magic Cat} SAP urea. 5 Submitted into the puieic on record ! Z�ti19(S) Y LCity clerk BAIT Map / — SAPS approved and pending in/around the Little Haiti neighborhood (based on Census tract) C. THE MAGIC CITY SAP IS INCONSISTENT WITH THE MIAMI COMPREHENSIVE NEIGHBORHOOD PLAN Pursuant to Florida statute, the standard for determining the legality of comprehensive plan amendment is consistency. "A development order or land development regulation shall be consistent with the comprehensive plan if the land uses, densities or intensities, and other aspects of development permitted by such order or regulation are compatible with and further the objectives, policies, land uses, and densities or intensities in the comprehensive plan and if it meets all other criteria enumerated by the local government." Sec. 163.3194(3)(b), Fla. Stat. (2018) (emphasis added). 6 Submitted into the p bile record f r ite (s) on Ci lerk The statute goes on to define "consistent": A development approved or undertaken by a local government shall be consistent with the comprehensive plan if the land uses, densities or intensities, capacity or size, timing, and other aspects of the development are compatible with and further the objectives, policies, land uses, and densities or intensities in the comprehensive plan and if it meets all other criteria enumerated by the local government. Sec. 163.3194(3)(b), Fla. Stat. (2018) (emphasis added). By this standard, based on the substantial and competent evidence presented below, it is clear that the project is not consistent with the comprehensive plan. (a) The Planning and Zoning Department's Comprehensive Plan Amendment Staff Analysis identifies multiple inconsistencies of the proposal with the Miami Comprehensive Neighborhood Plan. In the Staff Analysis attached to the Comprehensive Plan Amendment agenda item ("Comp Plan Analysis"), the City of Miami Planning Department found certain changes to be inconsistent with several criteria under MCNP. A Department memorandum was issued on October 26, 2018, finding that some of the inconsistencies have been cured, but there are still gaping holes. do updated analysis has been submitted despite unresolved concerns regarding the consistency of elements previously found inconsistent. In addition, since the Regulating Plan has been significantly altered (removing, for example, any provisions of affordable or workforce housing on -site or even within a certain radius of the SAP area), this analysis must be updated to serve as adequate substantial and competent evidence. The following chart summarizes the Comp Plan Analysis and adds commentary based on changes that have taken place since the date of the analysis, including a column addressing the revised February 2019 Regulating Plan: MCNP Criterion Staff Analysis Staff Finding July 2018 Staff Finding October 2018 November 2019 Application Comments March 2019 Comments on new DAIRegutating Plan Objective LU-1.3 — Unclear whether new inconsistent Consistent, given that We still have questions about Concern remain>. encouraging industrial General whether the "select commercial, office and activity will be concentrated Commercial land use allows light industrial uses" allowed under the industrial in an area for select light General Commercial development where this capacity currently exists industrial uses. land use resolve the issue of the overall depletion of the land in Miami with the "Light industrial" designation as the uses will have to be in close proximity to other uses such as residential, retail and lodging uses. 7 Submitted into the public record for it (s) 7,. I .Z 3 on City Jerk Policy LU- 1.1.3 — protection from encroachment Developer is changing 15+ acres of Light Industrial land to Restricted Inconsistent Consistent In addition to the concerns about the Light Industrial land uses, the lack of information (i.e., an Concern remains. .fhe level of commercial, retail, ente riairtntent and of Commercial in environmental impact residential ;; ti ,,. incompatible the Future statement) makes it foreseen bx a project land uses, adverse Land Use Map — this is found difficult to assess what potential adverse „I' this sire will have a significant impact on impacts on to be an environmental or the surrounding surrounding encroachment ecological impacts the neighborhoods of neighborhood of Restricted project will have on Little Haiti and Palm s. degradation Commercial the surrounding Grove in terms of of into the Light neighborhood. Not traffic, noise.. environment, ecology Industrial FLU designation clear that the traffic impact is sufficiently mitigated. The environmental impact statement should be submitted before second reading to present a clearer picture of what the environmental impact may be if the project is developed as proposed. pollution. nuisance and other impacts that come with high density mixed use development in an area that had previously been occupied by low intensity housing (mobile home park) and light industrial warehouses. Objectives Current Inconsistent Inconsistent — According to their The inconsistency LU-4.1, 4.2, 4.3 — mixed application is requesting should be offering a Regulating Plan, the 7% affordable units remains, and in fact intensifies, as any income higher density percentage of and 14% workforce mention of affordable developments and but envisions by its dwelling units, not habitable units promised need not be on -site. The or workforce housing set asides have been affordable Economic space. Regulating Plan does completely removed and attainable Impact not specify where the from the Regulating housing Analysis that 100% of its residents will have an income of $75,000 affordable housing should be built (and it could also be a payment in lieu) and the workforce housing need not be built on- site either, only within 1,500 feet of the SAP area. Furthermore, workforce housing should be out of the question altogether for this neighborhood since, if HUD AMI is used and the Developer opts to build the units at 140% AMI (as opposed to the 120% AMI that the City asked to be the Plan and DA. In fact, affordable housing is but one of a long list of things that the $31 million dollar sum total benefit might pay for. Given that there is only a guarantee of $6 million up front with all other future money ($35\1I contingent on square footage allowance per building permit_ it is quite possible that very little affordable/workforce housing will he created. It is the 8 Submittted in'or itto the plu lie on record Iqs) upper limit of the workforce allowance but the Developer has refused to accept), rents will be set at rates far above local market rate. (About $2066 for a 1 BR17 as opposed to the approximately $1200 current market rate for IBR apartments) prevailing standard that affordable and workforce housing Ix provided on -site to reduce the per unit cost of producinS3 that housing off -site. In addition, provision of on -site affordahie: workforce housing helps address fair housing issues. Goal HO-1 — Need for Inconsistent Consistent -- See above. For the Staff Analysis needs increase the affordable "The scale of development to he revised to supply of housing in Developer is proposed, 7% is not an account for the safe, affordable Little Haiti is well- making provisions for adequate amount. Further, the language reinoval of affordable workforce and sanitary documented affordable and about where the !Sousing set asides housing for workforce housing will be front the DA and extremely housing in an located and whether it Regulating Plan. '1ihe low-, very area of the city will be actual units application is low-, low- with a great built or a cash inconsistent ‘,vi111 this and moderate- income households need for this type of housing." contribution in lieu is unclear. Need more specificity; public benefits offered in exchange for bonus height should be focused on on -site affordable housing, not workforce. \IC\P goal. Goal HO-2 Livable city Plan is walkable and Consistent, however No comment. October 2018 analysis does not address this See above. Ibis finding. should be center with hospitable to Developer and the concerns inconsistent. as variety of multiple must think remain. Developer leas urban modes of further on removed reference to housing types for persons of transportation, but analysis affordability component to The failure to make a true commitment to affordable co - workforce housing set all income assumes all the residential building on -site asides in its levels in a walkable, mixed use residents will earn $75,000 while program, since residential affordable or workforce housing (as reflected in the documents. .1 cash - to-ikll payment structured as development purporting to component is Development indicated in the above target incomes based on a Agreement and comment on in the range of $55,000- household income of Regulating Plan) makes it unclear and Objectives I: 1. =4.1, 4.2 and 4.3 does not 75,000 $75,000 in the project's Economic Analysis doubtful that this development will truly be mixed income. There also need to be more specific provisions providing housing for the cure the inconsistency because affordable housing is but one of many uses for the funds. Moreover, the funds are inadequate and are not based on " Florida Housing Finance Corporation SHIP Program Income Chart: http://www.floridahousing.org/docs/default-source/developers-and- properry-mana gers/com pl iance/l imits/2018-sh i p-inc ome-rent-limits-3-30-18-eff-4-1-18. pd f? sfvrsn=71 f1347 b_2 9 ;'r,hmitted into the puLiiC rL'cord f r item(s) �Z,2 3 on 3 j 7 / I Ci y tlerk elderly. See also above comment on workforce housing. any rnethodoloil) or - analysis to ensure That a minimum number of units will be built. Though still inadequate. this protect would be more consistent with the \1CNP if it offered the 7'0 affordable (at ( O k A MI or below t and 1=1°z3 workforce (at 80°,o or 100 ArvII or belowl on -site in addition to the cash payment. Policy TR- 1.1.1 - On transit corridor on NE Consistent with The staff analysis is not adequate on this Concern remains, Concentratio 2"d Avenue. qualifications point as it does not n and Access to regarding correct the assumption intensificatio commuter rail Light that there will be a n of is anticipated Industrial commuter rail in the development around to become reality in the land. future to calm traffic. centers of near future. By the City's transit activity. Redevelops idle site. oriented development map and plans, there is no station planned or likely possible for the Magic City area (since there are planned stations at 79th Street/Little River and Midtown/Design District). While buses and bike lanes exist, it is not clear they can absorb the additional proposed density Policy TR- Presents infill Consistent The original staff Concern remains. 1.1.4 — infill redevelopment analysis is flawed. Still inconsistent. close to to take Transit along NE 2nd multimodal advantage of Avenue is primarily by transportation transit corridor bus, trolley or jitney. It options on NE 2"d Avenue is not clear that the density proposed can be adequately served by these options to truly reduce dependency on automobiles. 10 Submitted into the public record [or t9m�(s) 3 on 2 I . ci ierk TR-1.5.2 — transportation control Developer focuses on road network, Inconsistent — not enough detail Consistent - TCMs have been accepted We remain concerned about vehicular traffic to be generated by this Concerts remains. Still inconsistent. measures (TCMs), transit bicycle infrastructure. While by the Office of Capital Improvements development. Bicycle, pedestrian and bus shelter infrastructure is ; traffic emus }l sand, is not helpful without dedicated resources to discount and improvement and "a welcomed but will not implement the fare subsidy programs, etc. for bicycling, need true TCMs to Transportation Sufficiency Letter was make a reasonable dent in the traffic concerns, given findings of the study additional City resources should not reduce vehicular congestion. written on August 21, 2018 memorializing the Developer's TCMs as acceptable. This cures the staff report's findings of inconsistency." Miami's climate. Still have questions about the extent to which the traffic impact has been measured alongside other development that may come to the area. be drawn upon to absorb the naatixr externalities created by this project. Policy TR- SAP is Inconsistent— Looped in with Remains unresolved. Concern remains. 2.2.9 — designed for need to Criteria 11 on Still inconsistent. transportation people in provide for TCMs with no Analysis now finds the systems income ranges more specific project consistent on accessible to $55,000- inclusive of finding on this this point, however the those in need 75,000, but workforce is drawn from an area with high poverty rates. members with various incomes, abilities, etc. point. argumentation in the October 2018 memo doesn't address the question about inclusivity. No discounts or fare subsidies are contemplated in the DA. The finding on this policy should remain inconsistent. In the original analysis the Staff ultimately recommended approval of the project subject to the conditions attached to the rezoning item, but it is not clear that the conditions adequately resolve the issues raised in the above analysis, particularly with respect to the housing, transportation and equity criteria. Indeed, the Comp Plan Analysis itself concludes by noting "Staff has genuine concerns about the current proposal under the goals, objectives, and policies of the Miami Comprehensive Neighborhood Plan. A quickly diminishing inventory of FLU designations that support activities that have potential to provide the most diverse opportunities for incomes that are above the median income is a grave concern of the Planning Department."18 In a subsequent October 2018 memorandum, PZ staff found that some of the inconsistencies had been cured, but 'x Comp Plan Analysis at p 21. 11 Submitted into the pu lic record for ite (s) Z . 13. 3 on _;j_� Cif)/ clerk we continue to have concerns that inconsistencies persist as to the lack of adequate measures to ensure that this development is truly an inclusive, mixed income project. Moreover, since the isetl Regulating Plan (February 22. 2019 version) and DA (March IF, , 2010 version) do not Make explicit provisions for affordable and workforce housing. the analysis and findings must he rev.iced. Aotahll. as mentioned above. all references to the word "affordable- have been removed frF�;ii the revised Regulating Plan altogether. and the only reference to affordable and workforce 1i�.tt€;Mg in the revised 1.)A is in a laundry list of uses lorthe $31 million provision. These revisions n<_tl,e the project's inconsistencies with the v1CNP Housing Goals clear. Furthermore, Staff must revisit the assumption that a commuter rail will come to the area, which served as the basis of the consistency finding for TR ] .1. ] . (b) The scale of the development and minimal attempts to mitigate impact on the surrounding community demonstrate further inconsistency with the MCNP. The sheer size and density of the proposed Magic City SAP are staggering and out of scale for the surrounding neighborhood. The U.S. Census counted 28,346 residents in the neighborhood occupying 9,289 households»9 As stated above, this project will add 2,630 new residential units, a 28% increase in density. Given this massive increase, it is vital that we interrogate who this project seeks to attract to the neighborhood, and who, in turn, would be displaced and denied the opportunities that come with increased public and private investment in the neighborhood. Per the Developer's own application, this development is not being built for City of Miami residents, much less current Little Haiti residents. In fact, their economic impact analysis assumes that more than "half of the tenants within Magic City Innovation District will relocate from outside of the City."20 in that same analysis, the developer purports to be targeting households with incomes between $55.000-$75,000 (though the total residential income in is calculated based on 100% residents at the $75,000 level).L1 Median Household Income for the City of Miami is $31,600, and $24,800 for the Little Haiti area. By these numbers, it would take three Little Haiti families to afford just one apartment at the proposed Magic City SAP. The proposed micro -units could hardly accommodate such an arrangement. The standard of affordability for housing is thirty percent of income,-_ This means that for the rent of the Developer's targeted demographic to be affordable (at the $75,000 level ), rent would have to be capped at $1,875 per month across the entire development. And yet the Developer has withdrawn all commitments to provide even workforce housing. This is puzzling because if the development were truly targeting people with an income of $55,000-75.000, there would be more efforts to set rents at rates affordable to this population. The highest end of the workforce allowance (140°AMi) targets a household with a median income of $73,220 (based on 2018 HUD AMI level for Miami -Dade County - $52,3002'). vvhich falls within the income bracket of https//statisticalatlas.com/neighborhood/Florida/Miami/Little-Haiti/Population Lambert Advisory. LLC, Economic Impact Analysis: Magic City Innovation District (June 2018) at p 5. -' Id. https://www.huduser.gov/portal/glossary/glossary_a.html http://www.miamidade.gov/housing/income-limits.asp 12 Submitted into the pu he record fix it m(s) iL.' on 3Li /,y. City �lerk Magic City's desired tenants. The developer should plot be able to.evade comrllitment to build units on -site that ensure inclusive housing within the SAP area. At the same time, median rent for a one -bedroom apartment in Little Haiti was measured as $1,200 as of February 2018.24 Given the likely distortion that Magic City's over 2,600 units priced at income levels significantly higher than Little Haiti's median income will cause in the neighborhoods, it is imperative to include units on -site within the SAP area that are affordable to the surrounding community, at or below 60% AMI. A cash .ontributiorl in lieu will not go as far as brick. and mortar units, since land prices are increasing in the neighborhood. The prevailing hest practice for inclusionary housing is to provide units on -sue."' As mentioned in the above chart. though still inadequate, this project Nvould be more consistent with the MCNP if it offered the 7°%i; affordable (at 60% AMI or below) and 14"o workforce (at 80° or 100% AtiMI or below) on -site in addition to the cash payment. This vvould advance the goals of developing integrated mixed income and attainable housing for multiple income lev els. On -site alTordablelworkforce housing quotas have been found to be more successful than other federal housing subsidies in producing income -integrated housing.the wav that race overlays with income level in Miami, as discussed further below). this kind of polic.\--makinzs, is also necessari. to ensure that the rezoning does not have a disparate impact on a protected class under the federal Fair Housinlz Act, (c) The project does not meet prevailing criteria for an "innovation district" Planning and Zoning staff engage in an important and pointed discussion in the Comp Plan Analysis querying whether what is being proposed is truly an innovation district. The Analysis cites 12 guiding principles for innovation districts compiled by the Brookings Institute.27 While this project attempts — in narrative form — to check some of the points from the list, there are significant holes, including a firm partnership with an educational institution28, a true commitment to diversity and inclusion and forward thinking on affordability. We have particular doubts as to these latter two, which we discuss further in the subsection (c) below. Furthermore, while we understand that comparing different campuses with different configurations is imperfect, the difference in the density between the proposed Magic City SAP and other innovation districts (cited in Developer's application) is marked: Project Land area (in acres) Square Feet of Development Magic City SAP 17.75 8.16M Kendall Square (Cambridge) 24 (of 43) 4.15M South Lake Union (Seattle) 206 9M IDEA District (San Diego) 95 6.68M https://www.zumper.com/blog/2018/02/mapping-miami-neighborhood-rent-prices-winter-20l 8/ -' See, e.g., Vince Wang, What Do We Know About lnclusionary Housing? Lessons from a National Survey of Programs, Grounded Solutions Network http://inclusionaryhousing.org/designing-a-policy/onsite-development/ 26 /d. Comp Plan Analysis at p 10. The Developer has alluded to conversations with Florida International University, but the Development Agreement does not inspire confidence as to a commitment to securing an anchor educational institution, as it cites only "good faith" efforts to secure such a partnership. 13 Submitted into the p brie record or it (s) Vt. \ i +-� on 3 Ci,� clerk Midtown Innovation District (Atlanta 1.2 square miles (768 acres) 6.86M + 7,600 residential units Spring District 36 3M office space + 2000 residential units Indeed, the Analysis also cites the Brookings warning to guard "against across-the-board rezoning for increasing density, proximity, and mixing of uses due to the effect such zoning changes have on land prices.-9 This is precisely our concern, and the very reason why we ask for more measured approaches to zoning and density increases. At the very least, we should take the time to play out the consequences of approving such a large project at one time. (d) The project is inconsistent with additional criteria in the MCNP. The Staff is right to be concerned about this project. In addition to the criteria listed in the above table, there are other key criteria that the Staff did not include in its analysis that show further areas where the project is inconsistent with the MCNP. Policy LU-1.3.2 — "making available commercial loan funds for rehabilitation and small business loans and seed moneys, particularly to local minority businesses and encouraging the maximum participation... of...property owners and residents of the areas." • While Paragraph 16(0(4) of the Development Agreement (DA) includes a quota for subcontracts to go to community business enterprises or community small business enterprises (CBEs, CSBEs), there is no hard requirement, and no mention made of minority, women owned or disadvantage business entities (MBEs, WBEs, DBEs). • Though Paragraph 16(g) of the DA also provides for 20% of the retail merchandising units to be dedicated to Little Haiti businesses or residents, there is no subsidy, seed money or other support offered to incentivize participation of local resident businesses that may be the most vulnerable to displacement. Policy LU-1.3.8 — 'foster or develop and implement job training, vocational, and educational programs to assist the City's existing and future residents...support minority and semi -skilled residents of the city...." • The internship program in the revised DA is welcome. However, to ensure that local residents have access to the jobs created by the project, including construction and permanent ,jobs, there should also be explicit training opportunities that are tied to the specific labor demands of the project and its contractors. In addition, the language to make good faith efforts to partner with an accredited educational institution is overly vague and does not commit the Developer in any way to providing educational or training programs so that residents can benefit from the job opportunities created by the developments. • Though there is a loose commitment in Paragraph 16(11(1)(0 of the DA to local hiring according to a zip code schedule, there is no language specifying the time periods fir recruitment or binding the Developer to a certain percentage of local hires (and providing Comp Plan Staff Analysis at p 1 1. 14 Submitted into the priapic record f r ite (s) 't. 1 1, 3 on Citly �1erk training opportunities/training center to meet that percentage). While the monitoring contract is helpful, there should he requirements about transparency. frequency ofreporting and any enforcement penalties if the commitments are not met. Policy LU-1.3.14 — "City will continue to enforce urban design guidelines...which shall be consistent with the neighborhood character, history, and function, and shall be in accordance with the neighborhood design and development standards adopted...." Objective L U-1.5 — "Land development regulations will protect the city's unique natural and coastal resources, its neighborhoods, and its historic and cultural heritage." • This project is grossly out of proportion to the surrounding neighborhood. While Developer has accepted to adhere to the Little Haiti Creole Design Guidelines for properties along NE 2nd Avenue, the overall height, density and use of the property is not consistent with the neighborhood character, history and function. Simply including cosmetic design elements along NE 2nd Avenue is not enough to reflect the historic Haitian and Caribbean roots of the neighborhood. • Traffic remains a big concern. As indicated above. simply conducting a traffic calming study will not be helpful without dedicated resources to implement the findings of the study. Additional City resources should not be drawn upon to absorb the negative externalities created by this project. • The virtual elimination of Floor Lot Ratio (FLR) as a standard to measure intensity in the Regulating Plan is of deep concern and reveals a severe inconsistency with this provision. Policy LU-1.6.7 — "The City will provide adequate opportunity for public comment regarding zoning changes and variances within neighborhoods." • As mentioned in FN 2 above and as the community raised as an objection at the Urban Design Review Board (UDRB) meeting, the scheduling of the UDRB hearing for the same day as the Planning and Zoning Appeals Board (PZAB) hearing prevented meaningful community input at both events. Generally, these processes take place on two different days, giving time for the Developer to resolve any comments by the UDRB before the PZAB hearing. An ask we would have raised at the UDRB hearing (a need for a community wide meeting to evaluate design elements and other aspects of the project) was nullified by the fact that we had to present before a different board later on the same day. This appears to flout the spirit of the SAP approval process that includes multiple steps for the very purpose of soliciting feedback from the public and incorporating that into the project's ultimate design. D. THE MAGIC CITY SAP IS INCONSISTENT WITH THE MIAMI 21 ZONING CODE. The Planning and Zoning Department staff also submitted a Staff Analysis ("zoning Analysis") for the zoning change, which approved the project and found it consistent with the zoning code subject to heavy conditions. The below is a discussion of that analysis, which incorporates a granular critique of the Regulating Plan. Overall, we are deeply concerned that the revised 15 Submitted into the public record f r ite s) Q Z. \ ? 3 on Cilty Clerk l cgulatilig flan (as of February 22. 2019) eliminates any mention of public benefits for a liolesale cash in lira pa}naent. This is neither based on any informed methodology about the amount that should be proffered in exchange for building to the full development capacity requested. nor does it account for the specific provisions the Developer must make on-srze to mitigate the impact on the surrounding neighborhood. (a) The original Zoning Analysis30 missed some critical inconsistencies and incompatibilities with Miami 21, and should be updated to account for the Sander the revised Regulating Plan and DA, the passing of this projects rezoning will allow- the Developer- to build to maximum height requested based on a .S4.03 per square foot allocation as building permits are issued. eliminating the by -right and bonus height framework for incentivizing public benefit provisions. Given that these revisions may have a significant effect on the PZ analysis and its findings, the analysis should be revised. Comments as they pertain to Article 3, Miami 21 If the Developer is allowed to build to the maximum height, the tallest buildings in the MC1D-1 (maximum 20 stories) and MCID-2 zones (maximum 25 stories) will still tower over neighboring lots.. including 1-3 L, single-family or duplex residential areas to the east. The FEC train tracks are not an adequate buffer from the noise, traffic and other impacts the development may bring. A limit on building height should he contemplated and calculated according to the cumulative effect of this SAP together with other applications in the area. The recommendation by the PZ Staff to retain D-1 zoning on some parcels would also help reduce the intensity of development proposed while still offering a dynamic range of uses. We echo the Staff's concern about accessibility of the Open Space to the public, even with the expanded hours. There are few entry points into the area, and as the Regulating Plan is written, it appears that restaurant patios and other uses serving the surrounding businesses will dominate the area surrounding the walkway. It is not clear that there will be ample public space that is not oriented towards clients, customers or tenants of the development property. Furthermore, the Developer retains exclusive right to determine programming, landscaping and design of the area, which also raises questions about whether this Open Space is truly at the disposal of the public. Developer should not get the same amount of bonus height for space that is not in fact public. The tree preservation and relocation, however, are welcomed. The public art should reflect the culture and history of the Little Haiti neighborhood. At present, under the DA Paragraph 28, the Developer has sole discretion over the art chosen for the park and exempts itself from any requirements for paying a public art fee. While the development may propose artistic elements, there is no reason this Developer should be exempted from that fee. Furthermore, the Developer should specify that a percentage of that art that may be commissioned from local artists. In addition to the community providing input into the Historic Lemon City/Little Haiti Creole District Design Guidelines (which should apply beyond just the properties fronting Starr Analysis and Maps ("Zoning Analysis"), File ID 4459, pp 8-13. 16 Submitted into the ublic record or it s) yZ.. 1 1 on/�, City Clerk onto NE ?n`t Avenue), there should he some public input into the art that will he displayed in the civic space if it is truly going to he dedicated to the public. ii. Comments as they pertain to Article 7, Miami 21 Criteria 1 cited in the original Zoning Analysis asks whether the proposed amendment furthers the goals, objectives and policies of the MCNP, Miami 21 and other city regulations, and whether there is a need and justification for the proposed changes?' Though the Planning and Zoning Department found the project to be consistent with the above criteria, as Section B above noted, there is substantial and competent evidence, including the Planning and Zoning Department's own analysis, to show that the project and its proposed FLUM changes are not consistent with the Comprehensive Plan. The elimination of affordable and workforce housing allocations only exacerbates the projects inconsistency with the MCNP. Similarly, while the Staff Analysis indicates that the project is consistent with Miami 21, to the extent that the project continues to have several concerning inconsistencies with the MCNP and The Regulating Plan does not "emphasize compatibility with the Little Haiti neighborhood" but rather spells serious disruptions to the character, use and density of the neighborhood. (b) Elimination of Floor Lot Ratio One specific concern includes elimination of Floor Lot Ratio (FLR) as the measurement of intensity. Under Miami 21, Sec 3.4.2, FLR is to be used to calculate intensity, but the Regulating Plan creates its own criteria (Lot Coverage, Setbacks, Height and Floorplate standards) that appear to still be overly vague. Are the measures of total Floor Area for the different zones of the project in DA Paragraph 8(c) combined with the Article 4, Table 2 numbers enough of a measure to substitute FLR as a measure of intensity? While Developer may say eliminating FLR is necessary to have more flexibility with floorplates, it appears to throw off the ability to regulate intensity altogether. There are many other measures that are tied to FLR. Even so, Regulating Plan in some places has eliminated mention of FLR and retained it in other, inconsistent places. (c) There are multiple other concerning elements of the Regulating Plan i. Micro -Units What is the purpose? If not to increase affordability, then is it to decrease the costs for the developer while increasing density? As per the Regulating Plan, micro -units may have a common kitchen and living areas. This appears akin to dormitory -style living. It may reduce the costs of development but are not likely to actually be affordable. " Zoning Analysis at 13. 17 Submitted into the public record f r item s) L. 1 Z 5 on 3 Z / i City Clerk As indicated above, the hard bargaining we had seen from the Developer32 to reduce the commitment of workforce units is bewildering given the fact that we are dealing with 50% of residential units as micro -units. If we take 140% of HUD -defined AMI ($52,300) and use the Florida Housing Finance Corporation's 2018 Income Limits and Rent Limits, the rent for a one bedroom apartment would be $2,066. That certainly is out of proportion to the current market rate of $1,200 and thus we must infer that these micro -units will not address the affordability crisis in Miami. Finally, in the Article 4 Tables of the Regulating Plan, the MCID Zones are allowed a density of 150-1,000 dwelling units per acre, which is staggering. There has to be more clarity on this aspect. ii. Parking reductions because Regulating Plan claims that SAP is in a transit oriented development (TOD) area. The SAP area is located along a transit corridor, but not in a TOD area, which is defined under Miami 21 as being %2 mile from a transit node. Based on the map created to track TOD in Southeast Florida, there is no planned station for the Magic City/Little Haiti area.33 See Map 2 on the next page. Instead, there is a planned station at 79th Street/Little River approximately 1.8 miles to the north of the SAP area and a planned station approximately 1.2 miles south of the SAP area. The standard spacing for a commuter rail is 2-8 miles,34 making it highly improbable that a commuter rail station will eventually come to the Magic City SAP in the near future. Add to this the uncertainty of the funding and bureaucratic approvals of the project and the probability sinks lower. As a result, all references or policies dependent on the commuter rail project being in a TOD area should be removed. Similarly, the map included as Diagram 11 of Article 4 is misleading because the Developer drew in the station they want to build even though the current Miami 21 TOD diagram does not have that station included.35 Article 4 Tables proposed by the Developer include significant parking reductions (50-80%) based on being in a TOD area. This does not make sense based on the above. /.e., the initial application included no provision for affordable housing and only a vague reference to workforce housing until the Planning and Zoning Department prevailed upon them to include 7% affordable at 60% AMI or below and just 14% at 60-140% AMI. h ttp://ww w.c itie sthatwork. com/tod-i nventory-and-map-2017-update-draft/ http://www.fdot.gov/roadway/CSI/W2/TransitFundamentals.pdf Official map on file with the City Clerk 18 Submitted into the p blic record or ite (s) 'Z. It 1l 3 . on , City Clerk Map 2 ARTICLE 4. DIAGRAM 11 TRANSIT ORIENTED DEVELOPMENT SEI I PUIVRE METRIMit. I aaaewrCS VIIIMETCAtt nALIII= ocr act,imm T6Al111 06nxr STOPS raj runine-ovenrimeos tnilLasrwmsHED lit WU Ua-. 21 P.17i Caayrn aimilEmi r Da .7.1!. iii. SAP Permits While we understand the desire for a more streamlined process, the City might want to look more closely at whether there are elements that would require more process than what is required to obtain an SAP Permit. 19 Submitted into the pg�i ; record fP r it l' m(s) on 3/ Z��. City 'Clerk (d) Developer should not be able to obtain Alcoholic Beverage Establishment permits without going through the requisite processes li is of particular concern that ten (10) Alcohol Service Establishment permits are being requested to be granted by right pursuant to Sec. 21 of the Development. Agreement, bypassing the need to obtain a warrant or exception under Miami 21 or Chapter 4 of the City Code..-1 hat provision also .:litninatees distance requirements from churches, schools and other establishments under the ,Miami f_ yule. Waiver of requirements under the Cite of Miami Code of Ordinances should not be alloyed to be accomplished through the Development Agreement. How has the Developer proven that this exception is warranted, especially since the prescribed process for obtaining liquor licenses is completely routed through the documents that structure this SAP? There has been nothing Submitted by the Developer that proves that these establishments are either necessary for the relfare of the community or will not create greater nuisance than benefit for the surrounding neighborhood. (e) The Magic City SAP does not advance the purposes of Miami 21 The Staff Analysis found that the proposal maintains many of the goals of Miami 21, however, several aspects of this project raise questions about whether these goals are truly being met. First of all, since "a primary purpose of [Miami 21] is to implement the Comprehensive Plan," the inconsistencies listed in Section B above apply to the rezoning analysis as well. Under Sec. 2.1.1(b), the purpose of Miami 21 is "to promote the public health, safety, morals, convenience, comfort, amenities, prosperity, and general welfare of the City and to provide a wholesome, serviceable, and attractive community." For the reasons mentioned in this submission, there is ample reason to question whether this project truly promotes these aspects in the City of Miami. The project certainly projects out creative space making and mixed uses, with a potential to catalyze new things in Miami. The question is, for whom? We must ask ourselves this question when a development like the Magic City SAP comes to a neighborhood like Little Haiti where 70% of the population is low- to moderate income, and where over 2/3 of the residents are renters. As presently configured. the Magic City SAP, in both substance and process, undermines the purpose and intent of Miami 21. This is evident given the revised Regulating Plan that has completely eliminated a public benefits scheme including all provisions regarding affordable housing, a revised DA that makes vague. unenforceable promises regarding jobs. housing and other community benefits and the Developer's active resistance to holding an open, community - wide meeting on the project. The writing in of parking reductions tied to the project being a transit oriented development project, for example, is one way that the project sees itself as unbound by the regulations of Miami 21. (t) If City does not require specific inclusionary housing allowances, granting this SAP application vyill make the City run afoul of the federal Fair Housing Act While the current community is 73.4% Black, Black households are underrepresented in the income brackets targeted by the developer (55,000-75.000, per the Developer's own economic impact analysis). making up roughly 17% of .Miami -Dade County's households at that level. 20 Submitted into the puplic roecor� fpr itetn(s) Yti, � 2, 3 (j City Clerk Failure to take these tier ogrttphics into; account will Inevitably Lead to a sweeping dernographic change of Little Haiti and an uprooting:of the Haitian-AmeCiea'n community from its cultural home. presenting a potential fair housing issue due to the disparate impact a project like this xvoufd have on Black residents ot'the neighborhood, a protected class under the U.S. Fair housing Act.' It is particularly concerning that this displacement coincides tivith new public investments in roads, schools, and other infrastructure that promise to turn Little Haiti into a neighborhood of opportunity. Residents that have long suffered neglect and disinvestment in their neighborhood may not even be able to remain to enjoy what benefits these infrastructure improvements bring. (g) Developer has not adequately met certain conditions c' provided enough evidence for the City: Commission to make the requisite findings for approval of this project. there are numerous conditions prescribed by the Planning and Zoning Department staff incorporated into the ordinance that the City Commission ssion will vote on. Some of these conditions appear to he contradictory to the revised DA and Regulating Plan. for example, the ordinance states that the by -right height of the MCIL)-2 designated buildings be limited to 12 stories (with 13 stories potential bonus height), but the Developer has eliminated this framework of by- right/bonus height altogether. These inconsistencies must be addressed before the Commission votes on this ordinance. In particular, the proposed ordinance (File ID #5580 - for PZ 6 and File ID #4668 for IV 2) states that the City Commission must: make the following findings: the Magic C ity SA1' is consistent with the Miami Comprehensive Neighharhood Plan_ us amended; 2. The Magic Cite SAP conibrms t0 the require.nenis of the Miami 21 Code: 3. the Magic City S.'P yvill have a favorable inttpact on the economy of the City; 4. The Magic City SAP will efficiently use public transportation Facilities' 5. Any potentially adverse effects of the development Will be mitigated through comp' cc :vitlt (lz 01 the Magic City SAP as stated herein: 6. the Magic City SAP will efficiently use existing public and civic spaces: Fhe Magic City SAP will not negatively impactthe eticironmeni or any natural re ores of the tits: $. "Fite Magic City S LAP will not adv erscly affect living conditions in the neighborhood: 9. The Magic City SAP will not adversely affect public safety. and 10, fhe public welfare twill be served by the Magic City SAP, c conctmon For all the reasons stated in this document, and in particular the significant changes to the benefits offered in the revised DA and Regulating Plan that necessarily must alter the findings of the PL 36 See Inclusive Communities v. Texas Department of Community Affairs, 135 S. Ct 2507 (2015). See also, 42 U.S.C. §3604 et seq. 21 Submitted into the public 1 record f9r itep�(s) I Z, 1, t, 3 on City Staff analysis. and the Cit\ Commission cannot reasonably' make these findings. There simply is not enough substantial and competent evidence to support more than one of these findings -- in particular those related to the consistency with the MCNP, the mitigation of adverse effects. the ilupact�; on the environment (which have not been quantified in the application of of/) and public v\eltire (especially -riven the exceptions granted for alcoholic beverage establishments and waiver of distance requirements from schools and churches). For these reasons. the project must be significantly altered or otherwise denied. E. CONCLUSION In general, while it could he positive that the Developer is willing to offer money as one way of mitigating the issues with this project, there are certain elements that money alone cannot resolve, and the money that is offered should be in some fair proportion to the entitlements being granted. We know that this development will be looked to as an example of SAPs to come, and therefore, it is important to ensure that the documents that govern the project are adequately examined and brought into line with the Goals, Objectives and Policies of the MCNP, the intent of the Miami 21 zoning code and in alignment to the vision of a future Miami that is both resilient and inclusive. As it is, we do not have a project that substantially advances any of those things. For the foregoing reasons, FANM and its members present this evidence related to the Magic City SAP development and ask that the City Commission take a much finer look at the content of the project and work with the community to secure greater, more appropriate benefits before approving the SAP. By: eena Jagannath, Esq. Florida Bar No.: 102684 meena:a communityjusticeproject.com 3000 Biscayne Boulevard, Suite 106 Miami, FL 33137 Dated: March 26, 2019 22 Jerk A pp: rid i x A 3000 BISCAYNE BLVD. SUITE 106 MIAMI, FL 33137 March 7, 2019 VIA EMAIL Mr. Todd B. Hannon, City Clerk City of Miami 3500 Pan American Drive Miami, FL 33133 Submitted into the public record for it s) i• 3 on SPA l ► . • City Clerk Re:Re: Intervenor Status Request for proceedings related to Magic City Innovation District Special Area Plan Dear Mr. Hannon: Please see attached request for intervenor status on behalf of Family Action Network Movement (FANM) and individual FANM member Eugenie Alexandre (nee Eugenie Daseme) pursuant to Sec. 7.1.4.3 of the Miami 21 Zoning Code in the quasi-judicial proceedings related to the Magic City Innovation District Special Area Plan rezoning and Comprehensive Plan (FLUM) Amendment applications. FANM and its members, including Mrs. Alexandre residing or located near the proposed project have legally recognizable interests that stand to be adversely affected in numerous ways by the massive development coming to the neighborhood and the Magic City SAP in particular. Intervenor status is the proper vehicle by which they can make their concerns heard at the hearing in an organized, coherent manner. Thank you and please do not hesitate to contact me with any questions. Best regards, gannath COMMUNITYJUSTICEPROJECT.COM Submitted into the public record for itepi(s) on L3 C erk INTERVENOR STATUS REQUEST FOR MAGIC CITY INNOVATION DISTRICT SPECIAL AREA PLAN AND COMPANION COMPREHENSIVE PLAN AMENDMENT APPLICATIONS CITY OF MIAMI COMMISSION - MARCH 14, 2019 STATEMENT OF FACTS 1. FANM is a social services nonprofit with a membership base located in Little Haiti on 100 NE 84th Street, Miami, FL 33138, dedicated to educating and providing for the needs of low to moderate -income families and children in South Florida, and in particular in Little Haiti, since 1991. 2. To maintain proximity to its member base and the community it serves, FANM's office has always been located in the Little Haiti neighborhood, including at the following addresses immediately preceding the current location: 7900 NE 2nd, Miami, FL 33138 from 2003 to 2005; 8325 NE 2nd Ave, Miami, FL 33138 from 2005 to 2009; 181 NE 82nd St, Miami, FL 33138 from 2009 to 2014; 7900 NE 2nd Ave, Miami, FL 33138 from 2003 to 2005; 181 NE 82nd Street, Miami, FL 33138 from 2009 to 2014; and 100 NE 84th St, Miami, FL 33138 from 2017 to Present. 3. A significant part of the mission of FANM has been preserving and improving the existing Little Haiti community for the current residents, small businesses and workers. See Fanm Ayisyen Nan Miami, Inc. (FANM) Mission attached hereto as Exhibit A, ("FANM is located in the heart of Little Haiti... FANM's mission is, 'to empower Haitian women and their families socially, economically, and politically, and to facilitate their adjustment to South Florida and the United States."). 4. Its activities to accomplish these goals include a full range of social services, community education, community mobilization and advocacy. 5. For the past several years, the organization has seen the Little Haiti community and its clients adversely affected and threatened by erasure from unbridled development. 6. Most recently the organization has seen the community threatened by the impacts of the proposed Magic City Innovation District SAP ("MCID SAP"). 7. The proposed development is grossly out of scale, character and density of the surrounding neighborhood and is inconsistent with the Miami Comprehensive Neighborhood plan. See Second Amended Statement of Objections and Evidence on MCID SAP & Expert Witness Statement (Appendix B to Statement of Objections) attached hereto as Exhibit B. 8. With its members residing or doing business in Little Haiti facing displacement due to rent increases, business closures and other hardships brought on by the economic pressures exerted by existing and prospective large scale development including the MCID SAP, FANM has had to expend scarce organizational resources in serving 1 Submitted into the public record fpr itei(s) QZ on City Clerk members' mounting needs while also engaging at the systemic level in the time- consuming and complex land use and zoning processes associated with SAPs and other developments. 9. Currently, FANM has 30 members residing in the zip codes associated with the Little Haiti neighborhood, namely 33137, 33138, 33127 and 33150. In addition, approximately 200 beneficiaries of FANM's services reside in these same zip codes, including children participating in FANM's youth programs. See Declaration of Marleine Bastien, (Appendix A to Statement of Objections), attached hereto as Exhibit C. 10. The organization believes that the MCID SAP poses a serious threat to its members, its client base, its ability to fulfill its mission, and indeed, its very existence in Little Haiti. 11. The MCID SAP and the consequent relocation and displacement of individuals through dramatically increasing housing and business rental costs will undermine the community that Little Haiti is dedicated to serve. 12. The MCID SAP has already impacted FANM's financing and resources. In 2018, FANM has been forced to dedicate approximately 13% of the time of its Executive Director, 30% of the time of one its Community Organizer, and 33% of the time of its Communications Director to accomplish tasks related to responding to the MCID SAP (a $39,740 total valuation of staff time), and other staff members have also expended time that could have otherwise been used for activities advancing FANM's mission and support the Little Haiti community. 13. Since learning of the MCID SAP proposal plans in 2017, FANM began hosting community meetings and canvassing to assess the needs and priorities of members and local residents in connection with this project. Over the course of the last 10 months alone, FANM has hosted at least 13 meetings with time devoted to educating community rnembers about the Magic City Innovation District SAP Application process generally, and of the accompanying potential adverse impacts of the development. See Meeting Flyers and Meeting Agendas attached hereto as Exhibit D. 14. FANM has written at least two opinion editorials, spent time researching MCID SAP and speaking with the media about their and their members' concerns, , in order to educate a broader audience of the community of adverse impact of the Magic City Innovation District SAP Application. See Miami Herald Op-Eds attached hereto as Exhibit E. 15. As a result of these activities it had to take on to address the additional stress factors the MCID SAP was causing its members and beneficiaries living and working around the SAP area, FANM has seen at least a 25% capacity reduction of the above referenced staff to attend to the other needs of its community, such as their work advocating for renewal of Temporary Protected Status for Haitians living in the United States. 16. Mrs. Eugenie Alexandre (nee Eugenie Daseme) has been a member of FANM for over two years and owns a home at 320 NE 55th Street, Miami, FL 33137. She, her husband 2 Submitted into the public record f-r ite s) 9 Z. \ L 3 on I City iClerk Mr. Alexandre, and her family live Tess than ten blocks directly south of the MCID SAP area. They are concerned that their interest in their home, and the ability of future generations to enjoy the home they worked hard for,will be negatively impacted. They learned about the project through their membership in FANM and seek to protect their interests in their home, their neighbor and the character of the neighborhood. See Declaration of Eugenie Alexandre attached hereto as Exhibit F. LEGAL STANDARD There are two primary sources of authority that confer standing on parties aggrieved by zoning decisions or Comprehensive Plan amendments: the Miami 21 zoning code and the case law relating to zoning changes and Sec. 163.3215 of the Florida Statutes. Each standard is laid out below, as to an individual intervenor and an organizational intervenor claiming standing both on behalf of its members and on behalf of its own interests. (a) Legal standard under Miami 21 Zoning Code and Case Law 17. According to Sec 7.1.4.3(d) of the Miami 21 zoning code, "intervenor shall mean a person whose interests in the proceeding are adversely affected in a manner greater than those of the general public." 18. Intervenor status is equivalent to conferring standing as a party in the proceeding, distinct from "participants" who are members of the general public. Sec. 7.1.4.3(0, Miami 21. 19. Any affected resident, citizen or property owner of a governmental unit can have standing to challenge a zoning ordinance. Town of Bay Harbor Islands v. Driggs, 522 So. 2d 912, 916 (Fla. 3d DCA 1988). 20. In Renard v. Miami -Dade County, the Florida Supreme Court established the prevailing tests for standing in zoning -related challenges. The Court defined an "aggrieved or adversely affected person having standing to sue [as] a person who has a legally recognizable interest which is or will be affected by the action of the zoning authority in question." Renard v. Dade County, 261 So. 2d 832, 837 (Fla. 1972). 21. The Court then provided a non -exhaustive list of factors that may be considered in determining the sufficiency of the parry's interest for the purpose of conferring standing, including: the proximity of his property to the property to be zoned or rezoned, the character of the neighborhood, including the existence of common restrictive covenants and set -back requirements, and the type of change proposed. The fact that a person is among those entitled to receive notice under the zoning ordinance is a factor to be considered on the question of standing to challenge the proposed zoning action, but it is not dispositive. Id. ("Persons having sufficient interest to challenge a zoning ordinance may, or may not, be entitled to receive notice of the proposed action under the zoning ordinances of the community.") 3 Submitted into the p blic record f r iterpls , on // City Jerk 22. For example, the definite interest requirement for standing was present when the adverse impact of a zoning resolution constituted of "decreased traffic safety and water pressure, and increased population in the neighborhood school." Carlos Estates, Inc. v. Dade Cry., 426 So. 2d 1167, 1169 (Fla. 3d DCA 1983). (i) Legal standard for organization to claim standing on behalf of its members' interests 23. It is well -established authority from the U.S. Supreme Court that organizations may establish standing on behalf of their members. In order to have associational standing, an organization must show that: "(a) its members would otherwise have standing to sue in their own right; (b) the interests it seeks to protect are germane to the organization's purpose; and (c) neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit." Hunt v. Washington State Apple Advert. Commit!, 432 U.S. 333, 343 (1977). 24. All members' interests need not be at risk for an organization to establish associational standing. See Arcia v. Fla. Sec'y of State, 772 F.3d 1335, 1342 (11th Cir. 2014) ("In order to sue on behalf of its members, organizational plaintiffs need not establish that all of their members are in danger of suffering an injury. Rather, the rule in this Circuit is that organizational plaintiffs need only establish that "at least one member faces a realistic danger" of suffering an injury."); see also Alumni Cruises, LLC v. Carnival Corp., 987 F. Supp. 2d 1290, 1300 (S.D. Fla. 2013) ("To qualify for [associational] standing, an organization must establish that (1) at least one of its members would have standing to bring an individual claim regarding the challenged practice...") (citing Hunt). (ii) Legal standard for organization to claim standing on behalf of its own interests 25. Notwithstanding the above, under local case law, for an organization to have standing, in addition to its members' legally recognizable interests, it must have its own definite interests that will be affected by a zoning ordinance. See Chabau v. Dade Cty., 385 So. 2d 129, 130 (Fla. 3d DCA 1980); Fla. R. Civ. P. 1.210. 26. An organization must show that it will either suffer a special injury, or that it has a special interest in the outcome of an action. In short, the organization must show that her injury would be "different in degree and kind from that suffered by the community at large." See U.S. Steel Corp. v. Save Sand Key, Inc., 303 So. 2d 9, 12 (Fla. 1974). 27. The U.S. Supreme Court has found that an action that causes or threatens to cause an organization to allocate scarce resources away from their other activities to respond creates a judicially cognizable injury. See Havens Realty Corp. v. Coleman, 455 U.S. 363, 379 (1982) ("Such concrete and demonstrable injury to the organization's activities —with the consequent drain on the organization's resources —constitutes far more than simply a setback to the organization's abstract social interests.") 4 Submitted into the p--oiic record f r ite (s) Z, Z.on C lerk (b) Legal standard for standing under Sec. 163.3215 Fla. Stat. to challenge development orders inconsistent with the comprehensive plan 28. In addition, Sec. 163.3125 gives standing to aggrieved or adversely affected parties to challenge the consistency of a development order with a comprehensive plan. Sec. 163.3215(2) defines an "aggrieved or adversely affected party" as: any person or local government that will suffer an adverse effect to an interest protected or furthered by the local government comprehensive plan, including interests related to health and safety, police and fire protection service systems, densities or intensities of development, transportation facilities, health care facilities, equipment or services, and environmental or natural resources. 29. The adversely impacted interest of the party may be shared with the community in general, but must exceed in degree that of the general public. Id. 30. Organizations that have a primary purpose that includes protecting the interests at stake in a comprehensive plan violation may also claim standing under the statute, because such organizations are well-disposed to supplement the record with information intended to protect a specific interest that is at stake. See Save Homosassa River All., Inc. v. Citrus County, Fla., 2 So. 3d 329, 337-38 (Fla. 5th DCA 2008) INDIVIDUAL FANM MEMBERS HAVE STANDING TO CLAIM INTERVENOR STATUS UNDER BOTH JURISPRUDENCE AND FLORIDA STATE STATUTE 31. Individual FANM members with legally recognizable interests that stand to be impacted by the proposed MCID SAP zoning and Comprehensive Plan Amendments, of whom Mrs. Alexandre is but one example, may claim standing under the legal standard for intervenors laid out in the Miami 21 zoning code and jurisprudence defining who has standing to sue in a rezoning matter. 32. FANM's individual members, including Mrs. Alexandre, may also claim standing under Florida statute Sec. 163 to protect their interests at stake if an inconsistent comprehensive plan change is made. The statute was intended to allow for more liberal standing requirements. See. e.g., City of Ft. Myers v. Splitt, 988 So. 2d 28, 32 (Fla. 2d DCA, 2008). 33. Based on the above Renard standard as well as the more liberalized standard under 163.3215 Fla. Stat., FANM's members, including Mrs. Alexandre, have standing. 34. Here, Mrs. Alexandre, with her address at 320 NE 55th Street, Miami, FL 33137, is a member of FANM and is an affected homeowner in close proximity to the MCID SAP area proposed to be rezoned. Her home, where she lives with her family, is located approximately five blocks south of the SAP area, between NE 3rd Avenue and NE 4th Avenue, which will turn into a major thoroughfare with the improvements proposed in 5 Submitted into the p blic record fpr ite (s) . on V Li/ ICI . City Jerk the MCID SAP application. She and her husband are concerned about the largely unquantified impacts the development will have on them, including environmental and traffic concerns, as well as concerns that the project will be out of the scale and character of the existing neighborhood, where they have lived for almost twenty years. See Declaration of Eugenie Alexandre attached hereto as Exhibit F. 35. Mrs. Alexandre is just beyond the notice zone from the MCID SAP area as it has been drawn using a 550 foot radius' by the Applicant's consultants, RDR Miami (the accuracy of which we have not yet verified), but this is merely one factor to consider when weighing Mrs. Alexandre's request. Under Renard, The fact that a person is among those entitled to receive notice under the zoning ordinance is a factor to be considered on the question of standing to challenge the proposed zoning action. However, since the notice requirements of the many zoning laws throughout the State vary greatly, notice requirements are not controlling on the question of who has standing. 261 So. 2d 832, 837. 36. If the notice zone factor is taken together with other factors that courts can use in evaluating impact for the purpose of gaining standing --character of the neighborhood, type of zoning change, as well as noise and traffic impact --it is clear that a development proposed to sit on 17.75 acres of land with 8,164,140 square feet of projected development capacity in a neighborhood where the existing buildings are primarily single family homes, 15-20 foot warehouses and 25-foot commercial storefronts (see Expert Witness Statement attached hereto as Exhibit G) will cause impacts beyond the 500 foot notice zone that is standard for all rezonings regardless of the size of the development. 37. As Mrs. Alexandre's home is approximately five blocks south of the southernmost MCID property within the MCID SAP area), the changes in the character, use and density of the neighborhood caused by the proposed rezoning and Comprehensive Plan Amendment (See also Exhibit G), as well as increased traffic and increased population density make it such that she and her family will suffer an impact greater than that of the general public. 38. Additionally, based on the above facts as well as the inconsistencies with the Miami Comprehensive Neighborhood Plan that the proposed project has failed to cure, (see ¶¶ 52, 53, and 57 infra) Mrs. Alexandre certainly meets the requirements for standing under Sec. 163.3215(2) Fla. Stat. 39. Thus, as Mrs. Alexandre, FANM member, meets both the Renard v. Miami -Dade County standing standard and the requirements under Sec. 163.3125 Fla. Stat., she should be conferred standing as intervenor in the Magic City Innovation District SAP Application proceeding. 1 Under Sec. 7.1.2.8 (c)(1)(d) of Miami 21, the prescribed notice zone requirement is for properties within 500 feet of the subject property. 6 Submitted into the public on record for 31Zit/ 1q(s) . �Z City Clerk FAMILY ACTION NETWORK MOVEMENT HAS STANDING AS INTERVENOR BOTH ON BEHALF OF ITS MEMBERS AND ON ITS OWN BEHALF, DUE TO ITS LEGALLY RECOGNIZABLE INTEREST IMPACTED BY THE MAGIC CITY INNOVATION DISTRICT SAP APPLICATION (a) FANM has Representational Standing 40. Based on the above -detailed legal standard, FANM need only show that one of its members' interests will be adversely impacted by a rezoning in a manner greater than the general public. 41. Mrs. Alexandre has demonstrated that she meets the intervenor standard under the criteria laid out under the Renard test. 42. As FANM need only show that one of its members' interests are at stake and it has done so as argued above, FANM should be granted associational standing. See Arcia v. Fla. Sec'y of State, 772 F.3d 1335, 1342 (l lth Cir. 2014); see also Alumni Cruises, LLC v. Carnival Corp., 987 F. Supp. 2d 1290, 1300 (S.D. Fla. 2013). (b) FANM should be granted intervenor status as an organization with a special injury and special interest in the outcome of this rezoning 43. FANM should be granted intervenor status as an organization based on its own interests that have been adversely impacted since the submission of the MCID SAP application. See Chabau v. Dade Cry., 385 So. 2d 129, 130 (Fla. Dist. Ct. App. 1980); Fla. R. Civ. P. 1.210. 44. To show special injury or special interest at stake, an organization need only show that her injury would be "different in degree and kind from that suffered by the community at large." See U.S. Steel Corp. v. Save Sand Key, Inc., 303 So. 2d 9, 12 (Fla. 1974). 45. The use of scarce resources that would otherwise go towards serving other needs of its members is a judicially cognizable injury sufficient for organization's to claim standing. Havens Realty Corp. v. Coleman, 455 U.S. 363, 379 (1982) 46. FANM has a special interest in the outcome of the MCID SAP rezoning process based on the quantity of resources it has had to expend both to attend to members' needs that have arisen as a result of development pressures in the Little Haiti neighborhood and to educate the community as to the potential impacts of a development of this size. 47. The attached exhibits indicate that FANM has had to use significant resources holding meetings, canvassing, mobilizing community members for public hearings and conducting other activities in response to concerns regarding the size and scale of the MCID SAP application and the impact it will have on the Little Haiti neighborhood as a whole. See Meeting Flyers and Meeting Agendas attached hereto as Exhibit D. 7 Submitted into the pukl record for ite� (s) 1 1.11) on Siti / l q . City Clerk 48. This community education and advocacy have been necessary in order to fulfill FANM's organizational purpose. In that vein FANM staff has: • Over the course of the lastl0 months, hosted at least 13 meetings to educate community members about the Magic City Innovation District SAP Application process generally, and of the accompanying adverse impact of the development. See Meeting Flyers and Meeting Agendas attached hereto as Exhibit D. • Written 2 opinion pieces in the Miami Herald to educate a broader audience of the community' of adverse impact of the Magic City Innovation District SAP Application. • Expanded significant staff time, as outlined previously, in community education and advocacy regarding the adverse impact of the Magic City Innovation District SAP Application. 49. FANM will have to continue expending scarce organizational resources on time- consuming and complex land use and zoning processes associated with MCID SAP, and subsequent campaigns to prevent erasure of the Haitian community due to this development, when they could otherwise be serving members" mounting needs. 50. Therefore, due to FANM's special injury and special interest in the outcome of the Magic City Innovation District SAP Application, it has organizational standing as intervenor in the Magic City Innovation District SAP Application. (c) FANM has standing on behalf of itself under Sec. 163.3215, Florida Statutes 51. FANM has significant concerns about the changes in scale, character, use and density envisioned in the proposed MCID SAP rezoning and Comprehensive Plan Amendment applications. While some documents have changed since the submission of the Second Amended Statement of Objections and Evidence, attached hereto as Exhibit B, that submission includes significant objections and evidence regarding the inconsistency of the proposed project with the Miami Comprehensive Neighborhood Plan (MCNP). All objections and evidence applicable to the present amended application are incorporated herein by reference. 52. In fact, the removal of any reference to on -site affordable or workforce housing and enumerated benefits exacerbate an identified inconsistency with at least one Goal (Goal HO-1) under the MCNP. 53. Sec. 163.3125 confers standing on aggrieved or adversely affected parties to challenge the consistency of a development order with a comprehensive plan. Sec. 163.3215(2) defines an "aggrieved or adversely affected party" as any person or local government that will suffer an adverse effect to an interest protected or furthered by the local government comprehensive plan, including interests related to health and safety, police and fire protection service systems, densities or intensities of 8 Submitted into the public record fp r it m(s) P Z. I L 3 on V Z1 f ) 4 . City +Clerk development, transportation facilities, health care facilities, equipment or services, and environmental or natural resources. 54. The adversely impacted interest of the party may be shared with the community in general. but must exceed in degree that of the general public. Id. 55. As noted above, the standing provision in the statute was adopted to create a more liberal standing requirement for challenges to development orders that may be inconsistent with the city's comprehensive plan. Indeed, as one court noted, "It has repeatedly been acknowledged that the standing provisions of section 163.3215 were adopted to liberalize the standing requirements that would otherwise be applicable." City of Ft. Myers v. Splitt, 988 So. 2d 28, 32 (Fla. 2d DCA, 2008). 56. FANM has previously raised numerous concerns about the inconsistency of the proposed land use changes with the MCN P because of the number of its members in the Little Haiti neighborhood, its own long-time advocacy work in the Little Haiti neighborhood and because of its commitment to protecting the interests of those low to moderate income families who face potential displacement, tax increases, traffic impacts, environmental impacts and other impacts if a project of this scale were to be approved. 57. FANM's long-standing work in Little Haiti and on behalf of Little Haiti residents make it uniquely positioned to advocate for the community's interests and to present evidence that will supplement the record on potential impacts the project will have on the surrounding neighborhood. See Save Homosassa River All., Inc. v. Citrus County, Fla., 2 So. 3d 329, 337-38 (Fla. 5th DCA 2008) 58. It is clear that under Sec. 163.3215 FANM may claim organizational standing. For all the foregoing reasons, FANM as an organization on behalf of itself and its members, as well as Mrs. Alexandre as an individual have demonstrated that they should be granted intervenor status in the MCID SAP rezoning and Comprehensive Plan Amendment proceedings before the City Commission. By: Dated: / March 7, 2019 9 Submitted into the p blic record or it m(s) Z. on Z`� �1 q ity Clerk Appendix B Submitted into the public record for item(s) PZ.1,2,3 , on 11/15/2018 . City Clerk INNOVATION DISTRICT 4716 4667-Submittal-Neisen Kasdin-Magic City Power Point Presentation 4668 Submitted into the puJlic record for item (s) L on 3 / 7, / 1 c1 . City blerk KEY TEAM MEMBERS pPLAz Ui PAKT14EKS Plaza Equity Partners development and investm Anthony Burns and George leading, full -service development company. Previous successes inci & Residences, The Palms in Po Hollywood Beach, Paramount District, and Ocean House in ivliar Neighborhood. 1 is a forward -think' management and development fi company has completed over transactions since 2005 and:i�a since 2011 as one of the top 25 commercial by South Florida Business Journal. estate it market=' rgement Yacht Club. Palms in dgewater Guth of Fifth # estate 'brokerage, unded by Tony Cho. The n in real estate zed every year real estate firms D foci fob prei biliit vain inve Jet.cac Submitted into the public rd for n(s) PZ.1.2.3 11i't /2018 City Clerk used private. investor t:; real ;estate .invest aer s .Giobalis cui `a td investments in. ems tof` Trtirittei< and ge is a' Montr al ' based e to (Cirque du lelij. related to the .technology, arts, se+ tors as rarer as initiatrves wi iental :i par l une;; Rou creativity and entrepreneurship` and will have a central the c,ration and creative direction of Magic City's art entertainment district. toundea .t focuses on projects ertainrnent°and real • e in, and Submitted into the public record for it m(s) Z,. ` 7.L�j on � for / r (\ . Ci�y C;1erk Submitted into the public record for item(s) PZ.1,2,3 , on 11/15/2018 . City Clerk CREATING THE MAGIC CITY INNOVATION DISTRICT: THE MAISON ALCAN EXPERIENCE (MONTREAL, QC) • Hub for projects and startups focused on digital entertainment content creation and technology. • integrates new construction with restoredl/renovated buildings in the heart of dawntown Montreal#. • Home to prestigious tenants such as Electronic Arts (EA); headquarters of Lune Rouge and Lune Rouge Creative Hub. motorsport N:ETWOR LUNE ROUGE ofij1nt Submitted into the public record or it/�m(s) Q Z.\ 113 on l q City Clerk Submitted into the public record for item(s) PZ.1,2,3 on 11/15/2018 . City Clerk DRAGON GLOBAL CONFIRMED TENANTS oSnubmitteicl, record f r ite s) into the pric ce5 . CityClerk Submitted into the public record for iiem(s) 13,2,3 on li/P/4718 QtyQrk SITE OVERVIEW: BEFORE/AFTER OUTDATED, VACANT LOW-RISE WAREHOUSE riniCeICITY 404/44:41(!itiolt;1 Submitted into the p blic record it m(s) Z Z on City lerk PROJECTED ECONOMIC • Job Creation • 11,680 direct and indirect full-time jobs. 30 annual short-term construction jobs. ▪ $640 million in direct and indirect annual wages. SubtnitLed into the public record far itent(s) P.Z,12,3 on 11/i5/2018 City Clerk • Taxes and Revenues • $42 million in permit and impact fees. • $188 million in annual local expenditures by the District's residents, guests, hotel visitors, retail patrons, and office workers. • $37.6 million in .marginal annual ad valorem taxes. • $14.3 million City of Miami ad valorem taxes. $1.3 million in annual Hotel Bed Tax Revenue. • $4.0 million in total sales tax collections, !"�FCtI ci-ty LITTLE HAITI NEIGHBORHOOD Magic Innovation District 1.5% Submitted into the public record f r ite s) on City lerk SITE OVERVIEW: NEIGHBORHOOD CONTEXT Submitted into the public record for item(s) PZ.1,2,3 , on 11/15/2018 . City Clerk SITE OVERVIEW: OLD LEMON CITY TRAIN STATION Submitted into the public recon ord fpr � it m(s) City Clerk Submitted into the public record for item(s) PZ.1,2,3 on 11 /15/2018 . City Clerk SITE OVERVIEW: HISTORIC DUPUIS BUILDING LEMON CITY PHARMACY — ..DR. DUPUIS OFFICE DStt- 111'.Ti4tyn,8 ttaa31t¢.,' flans. $.'IA €t) $ .--[3r yist:, t:tsrd iA'Ytd. (9, i,PRxc,,r• grAdaa 'N'g Or,' 1ch f Tie.8r s S erS t9._af.K,ntbrisy Yn Id19N #IC t o, has-Fra-.;-sice in -n ti,-r1,n:n ratne lrutllinq iir#iiBQ--ltfa, .Carflttg w i a� -'# c 1aY-q,.g ed n Chien 8,10 ns noe oS th3., !t t !� uy st fes w 1# Li r;e npi'ikls as .2 oJ.ocd to 12: go? f} dc.-(:oumty r: di ul al Mfr. Pea.ud409, t w9R !to 1(3 u, yrlja'a Yr err ";eutl.t e.+h in ks79g He dFl t , Yv th thi': e ins aStmst«olri' in the no Y 1u4 t." ,YhC regarssid "eP ,aa a whiix .me x+cyisxt 1n811.- la 1902 Uufu r has a new attire: an 111C {forme '01 4-tenn1. 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CityMClerk SITE OVERVIEW: ABANDONED MAGIC CITY TRAILER PARK Submitted into the public record for item(s) PZ.1,2,3 on 11 / 15/2018 . City Clerk MAGIC CITY Submitted into the public record fpr it9m(s) Q L. \-I L ?) . on 3�zt1 I q Cit) Clerk SITE OVERVIEW: EXISTING CONDITIONS AERIAL. 5ubtlitttd into the pubVic record. For item(s) PL.1�2r on 11 /'1 S12O18 . Citti' Clerk Submitted into the piplic record foi ite7(s 1 Z on City Clerk PLANNING & DESIGN: TING CONDIT�NS Submitted into the public 3 record for item(43 on 11/15/2018 . PLANNING & DESIGN: MASTER PLAN FOR THE MAGIC CITY INNOVATION DISTRICT M. Submitted into the public (s) COMO f UMW, INKOLVISS Pooretrmee izzzzRWi(MR/GE ppnYictmcpFl,cpPD Submitted into the public record for item(s),. PZ.1,2,3 on 11/15/2018 : City Clerk CIAQK CITY MRQVA DM OfitR1CT Submitted into the pu lic record I) r iten(s) on • City clerk PLANNING & DESIGN: SAP CAMPUS ZONES Submitted into the public record for item(s) PZ.1,2,3 , on 11/15/2018 . City Clerk MIMIC CITY k$Ov*n.p 94Etq 4tT Submitted into the mblic record or it m(s) 3 on City Clerk PLANNING & DESIGN: TERMINATED VISTAS *VVIZt7Zalikijitiii; pOZ:0 :IP E; 11Z Submitted into the public record for item(s) PZ.1,2,3 on 11/15/2018 City Clerk LSE MARCHE DUPUIS. AT NE 2No AVE Submitted into the public record f r ite (s) on C ry Clerk Submitted into the public record for itpm(s) 2'7.1,2,3 on 11/15/ 2018 _ City Clerk T1f1QiK CITY •Y599+.rip• 9•Pff,�r PROMENADE DU GRAND BOIS AT NE 2ND AVE Submitted into the public record or i em(s) (1Z. on City Clerk Submitted into the public record for item(s) PZ.1,2,3 , on 11/15/2018 . City Clerk MAI( CITY Submitted into the _� puJ je \ 12 record for ite s on 3 City Clerk PROMENADE DU GRAND BOIS AT NE 3RD AVE Submitted into the public record for item(s) PZ on 11/15/2018 C riiiCalc, CITY Submitted into the p blic record f' r ite (s) 3 on _ MI I_q _ • i Cllerk cr COMMUNITY OUTREACH EFFORTS Since August 2017, MCID has worke has met with representative Notre Dame D'Haiti Catho Buena Vista East Histor Association • Buena Vista East Neighborhood Association • Buena Vista Stakeholders • Chef Creole • Circle of Brotherhood • Community Justice Pro • CRA North Miami • Downtown Little Haiti St FANM ▪ Fullei Fresh. • Haitian American Chamber of Commerce of Florida • Haitian Cultural Arts Alliance • Haitian American Communit Development Corp ith the _cam nation • Little Haiti Stakeholders Association xperienc Lamle leaiti Cu,lturliriipleysid is t1 to Footballi b nef LuisE Little Haiti NET ©fie Future Rc Little River Business District • Haitian C tihe ri M,apou ook or u gru�nch .. l* 2hid Ave Pai Ne bors and Submitted into the public ..record -on 2111j tod Little Haiti Optimist flub re . purce Palm Grove Neighborhood Tradyson son Lakou La Association Seul Dieu;, n rice Health `Clinic Sant La Haitian Community C • Sounds of Little Haiti/Tra • E: + nter • Nolen Catering Lakou COMMUNITY OUTREACH EFFORTS addition to meeting with representatives from a wide range of comm a`h lye collaborative development process with the residents and businesses Submitted into the pu lic record for ite (s) on �%ig City Clerk Submitted into the.vublie record for items) un fl/15j• gust^ S, 17, the i plicant hosted a community open house at the Haiti Cultural Cent, followed by a ur of.the SAFe in ed;and attended. COMMUNITY OUTREACH EFFORTS Community outreach timeline contin • On January 30, 2018, the Applicar place from 5:00 — 8:00 PM. Ove Between February— A ►r along NE 2nd Avenue betw seed a community open house at the W ndividuals were invited and 60 attende theApplicant team conducted exte n NE 54th and NE 62nd Streets. On June 4, 20.18, the Applicant hosted an on -site commur from 5:00-8:00 PM. Over 400 people were invited and 100+ a • From June 11-13, 2018, the Applicant took members of the Li Maison-Alcan located in downtown Montreal. The purpose of example of the Magic City innovation District's potential. On September 24, 2018'and nthNo18, the, community stakeholders to discuss the project and listen to their reque Submitted into the public record or it-m(s) Q 1. ► Z on 3ZX %19 City)Clerk Submitted into the public record for item(s) P1:1,2,3 on. V/15/2O18 • Overall, the Applicant has been committed to &robust dialogue with the community and th'local organita about the Magic City Innovation District SAP to ensure that the proposed SAP master plan er Graces the ric culture that has been thriving in. Little Haiti for decades and that the proposed development helps to improve the quality of life for residents in the surrounding neighborhood and throughout the City of Miami. Ni1Q CITY" •U)OYflT e 1 YFIT.EC'Y Submitted into the public record fjor it `i (s) Q t. 't / Z(.� on City Clerk comNituNtry BENEFITS Wor orce and affordable housing engine; providing a combined 219 or force and a corrpr►nent. Estimated at $41 Million i stabl shin a high sells jobs program'f©r the ocal community with a her dr. ati© 4 catalyst for commercial revitalization in Little Haiti. P o yarn for , ai �sinesses;and entrepreneur p. Y 3: roe des � public c vac/open space �- more hal :do bie thesi s � % zo i -acre P enade;:d pro sedgy ssn `` c�bma�[t��r�a stainn rzitlg t venue; ianir N au ifieation a d, + si n concept stud . rn�cved pedestrian and bic cle lr frastru ure,::new iami "role. stops. .Improvements -to existing pubtie rights -of way; NE 3rd end • N '4th Avenue expnsion Environments end ust na r It r grams .e., recyclin noise mi l ati n, EE e ievitalization and ai tivat on d the historic DuPuis Bu iding. Additional harkin.:,corn unity: Submitted into the public ecord for item(s) PZ.1,2,3 1I i2Q1i , City Clerk THANK YOU Submitted into the public record f r ite(s) on ity Clerk Submitted into the public record for item(s) PZ.1,2,3 on 11/15/2018 . City Clerk Appendix C Submitted into the pupjc record fpr ite>Xl(s) — Y (. on I t J 1 Cit, Clerk Little Haiti Neighborhood Data Update Shimberg Center for Housing Studies, University of Florida March 2019 I. Neighborhood Property and Sales Data For this report, Little Haiti is defined as the area bounded by 36th Street on the south, 87th Street on the north, Northwest 6th Avenue on the west, and Northeast 4th Avenue on the east. The neighborhood boundaries coincide almost identically with Census tracts 14.01, 14.02, 20.01, 20.03, 20.04, 22.01, and 22.02. Figure 1 on the following page is a map of neighborhood and tract boundaries. Property sales data cover the full years 2010-2017, 1st quarter 2018, and most sales in 2nd quarter 2018. For brevity, we refer to the period as "2010-2018" below. Unless another data source is noted, please cite "Shimberg Center analysis of Florida Department of Revenue, Name -Address -Legal and Sales Data File" as the source of data from this report. Sales volume has been high for both single family and small multifamily properties in the neighborhood, including extensive tax deed and foreclosure -related activity. Little Haiti is made up of 6,197 land parcels. Of these, 4,850 parcels are classified for residential use: 2,546 single family homes, 1,776 2-9 unit multifamily properties (mostly duplexes), 441 vacant residential parcels, 66 multifamily properties with 10 or more units, 18 condominiums, and three parcels with other residential uses such as boarding houses. During 2010-2018, there were 5,334 sales of residential parcels in the neighborhood. This includes repeat sales and transactions split into more than one recorded sale. In all, 2,429 unique residential parcels sold at least once. Specifically, sales included: • Single family: 2,587 sales involving 1,188 unique parcels. Of these, 819 sales of 616 unique parcels were arm's length sales. Most of the rest (1,450 sales of 841 parcels) were likely some type of distress sale, either related to foreclosures or sale of the tax deed.' • Multifamily 2-9 unit: 2,175 sales involving 956 unique parcels. Arm's length transactions (702 sales) were outnumbered by potential foreclosure and tax deed sales (1,171 sales). • Vacant residential parcels: 510 sales of 248 unique parcels. Of these, 177 were arm's length sales and 262 were potential foreclosure and tax deed sales. Sales were most active in Census tract 22.02, in the southwest corner of the neighborhood (see Figure 11). There were 1,677 sales of 747 unique parcels during 2010-2018. ' Sales with qualification codes submitted by the county property appraiser to Florida Department of Revenue as follows: 11—Corrective deed, quit claim deed, or tax deed; Deed bearing Florida Documentary Stamp at the minimum rate prescribed under Chapter 201, F.S.; Transfer of ownership where no doc stamps were paid; 12— Transfer to or from financial institutions; Deed stating "in Lieu of Foreclosure" (including private lenders. These classifications are generally proxies for foreclosures, tax deed sales, and other distress -related transactions. More research would be needed to determine whether there is another reason for this classification for any individual sale. Figure 1. Little Haiti Neighborhood Boundaries and Census Tracts 2 Submitted into the pudic on record bi'Lj /V 1 • �Cit}S Clerk Sales prices increased dramatically beginning in 2013 and 2014. Figures 2 and 3 on the following pages show the increase in median sales price per property and per square foot over the 2010-2018 study period. The graphs and discussion below include only arm's length transactions, which best reflect market prices in the neighborhood. Per square foot prices refer to the property price divided by the square footage of the building living area (not land area). For single family: • Price increases started in 2014 • Median property sale price: $77,000 in 2013, $217,000 in 2018 (252 percent increase) • Median price per square foot: $61 in 2013, $184 in 2018 (202 percent increase) For multifamily 2-9 unit properties: • Price increases started in 2013 • Median property sale price: $75,000 in 2012, $271,500 in 2018 (262 percent increase) • Median price per square foot: $42 in 2012, $157 in 2018 (274 percent increase) Sale prices were highest in Census tract 22.01 in the southeastern corner of the neighborhood. For sales in 2017-2018, median single family home price was $480,000, or $298 per square foot. Median multifamily 2-9 unit sale price was $575,000, or $282 per square foot. (See Figure 10). Land use type changed for 10 percent of land parcels in the area. The most common changes were reclassification of single family/small multifamily parcels to vacant residential or commercial status, and swaps from vacant residential to vacant commercial. Land use for 633 of Little Haiti's 6,197 parcels changed between 2010 and 2018. The reclassifications were not concentrated in any particular Census tract. The most common reclassification was changing from occupied to vacant residential status: • 76 single family parcels changed to vacant residential • 51 multifamily 2-9 unit parcels changed to vacant residential Only 10 parcels changed in the opposite direction, from vacant residential to occupied residential use. Eight of these were vacant parcels that were reclassified as single family. During this same time, land use classifications for 80 parcels changed from residential to commercial use. Most of these were reclassified as vacant commercial land: • 39 vacant residential parcels changed to vacant commercial • 19 multifamily 2-9 unit parcels changed to vacant commercial • 13 single family parcels changed to vacant commercial Changes in the opposite direction were much less common. Thirteen commercial properties changed to residential use, including ten vacant commercial lots and parking lots that were reclassified as vacant residential land. 3 Figure 2. Median Sales Price, Single Family and Multifamily 2-9 (arm's length), Little Haiti, 2010-2018 $350,000 0 0 O 0 o. o $300,000 w h r; N w $250,000 -- 0 0 0 0 0 0 o L 4, $200,000 ^ - w $150,000 o 0 $100,000 -- r` t 4, $50,000 $0 0 0 o 0 0 0 0 in o o ,n F 44 1 49. 44 I I 2010 2011 2012 0 0 2013 0 o '2 0 cei C) 0 2014 4 2015 0 0 0 ai r> N 0 w 2016 2017 2018 (partial) Submitted into the pub le record fqr ite�}�(s _ Q ti • ll 1, _ on I Z% / 1 • City Clerk • Single Family ■ Multifamily (2-9) Submitted into the public recordfpr itepi(s) on Figure 3. Median Sales Price per Square Foot, Single Family and Multifamily 2-9 (arm's length), Little Haiti, 2010-2018 $200 $180 - --- $160 $140 - $120 $100 $80 $60 4i $40 $20 10 co 44 2011 2012 2013 2014 5 44 CO 0, 4} 2015 2016 o 4, o 4, 2017 2018 (partial) • Single Family ■ Multifamily (2-9) lerk Submitted into the public record ) ottJi9City .erk Owner occupancy of single family homes dropped from 64 to 54 percent during 2010-2018. Homes are classified below as owner occupied if the parcel has a homestead tax exemption. Non -homesteaded properties are categorized as investor owned or second homes. Owner occupancy of single family homes fell steadily during in the study period. As Figure 4 shows, in 2010, 1,684 out of 2,619 single family parcels were homesteaded (64 percent). In 2018, 1,375 out of 2,546 single family parcels were homesteaded (54 percent). Figure 4. Single Family Parcels by Owner Occupied (Homestead) Status Single Family Parcels % Owner Occupied 64% 62% 61 % 59% 57% 55% 54% 54% 54% 2,500 2,000 1,500 1,000 500 0 2010 2011 2012 2013 2014 2015 2016 2017 2018 • Owner Occupied • Investor/2nd Home The figures on the following pages summarize the parcel and sales data at the Census tract level. 6 $200 $150 II. Census Tract Data Summaries Figure 5. Tract 14.01 $250,000 Median Sale Price O O O O $200,000 0 o iA O $150,000 'f O O co Submitted into the pufiic record f ite (s) i,,. \ ti 3 on j Cit}� Clerk 813 residential sales (353 unique parcels); 215 arm's length 282 single family home sales (127 unique parcels); 75 arm's length 414 multifamily 2-9 unit sales (172 unique parcels); 108 arm's length 90 vacant residential sales (41 unique parcels); 23 arm's length Single family owner occupancy rate: 2010 - 63%; 2018 - 52% Median Price per Square Foot O ts► '� $1004,, o O $100,000 O co tsr O to, N . i d►:111 in 0,0000 o v K o v K O 0 0 0 0 0 N N N N N N Single Family Multifamily (2-9) 7 r> ,o co 6 4 p 3 0 0 N N N N N c) ,o co 6 4 r 0 0 0 N N N Single Family Multifamily (2-9) Figure 6. Tract 14.02 $450,000 $400,000 $350,000 $ 300,000 $250,000 $ 200,000 $150,000 $100,000 $50,000 $0 Median Sale Price 0 Let o, 0 0 'aq Let b9 �O ,o co O 4- t\ O O O N N N 1 co 0 0 0 0 0 49. M mo co O 4 O O O N N N Single Family Multifamily (2-9) Submitted into the public record f r ite (s) 'i,,, j t on 3 Ci Jerk 507 residential sales (248 unique parcels); 165 arm's length 197 single family home sales (98 unique parcels); 61 arm's length 235 multifamily 2-9 unit sales (114 unique parcels); 84 arm's length 55 vacant residential sales (26 unique parcels); 12 arm's length Single family owner occupancy rate: 2010 - 63%; 2018 - 56% $200 $150 $100 $50 $0 8 Median Price per Square Foot co N 69 1 Single Family 0 CO 0 M 'o co O 4 n o o O N N N Multifamily (2-9) Submitted into the public record r it m(s) Q Z.. 1 t on 5IL�Jt9. City Cilerk Figure 7. Tract 20.01 492 residential sales (219 unique parcels); 111 arm's length 175 single family home sales (82 unique parcels); 41 arm's length 262 multifamily 2-9 unit sales (113 unique parcels); 60 arm's length 51 vacant residential sales (20 unique parcels); 9 arm's length Single family owner occupancy rate: 2010 - 62%; 2018 - 50% $250,000 $ 200,000 $150,000 $100,000 $50,000 $0 O O O O ch v> Median Sale Price O O O O O O 16 O O O tt) •a •O O O it) W N l'0'l !!! Single Family Multifamily (2-9) $200 $150 $100 9 Median Price per Square Foot It) $50 — $0 0' 1 •a w ■ ch CO cn 2 co cn •o co o v r o v 3 3 3 3 3 3 N N N N N N Single Family Multifamily (2-9) Submitted into the pupc on orrec/i,`d� �iterr(s� . City2 1e k Figure 8. Tract 20.03 793 residential sales (339 unique parcels); 225 arm's length 312 single family home sales (133 unique parcels); 82 arm's length 409 multifamily 2-9 unit sales (166 unique parcels); 123 arm's length 71 vacant residential sales (39 unique parcels); 20 arm's length Single family owner occupancy rate: 2010 - 61 %; 2018 - 50% $300,000 $250,000 $200,000 $150,000 $100,000 $50,000 $0 Median Sale Price 0 0 0 vi CO yr 0 0 0 0 0, o .sr 0 0 to .sr II I M 4O 00 O O O N N N 0 0 o_ N ur C) No co O 4 _h O O O N N N Single Family Multifamily (2-9) $200 $150 $100 $50 $0 10 Median Price per Square Foot 00 O 4 O O O N N N O O N Single Family Multifamily (2-9) Figure 9. Tract 20.04 $300,000 $250,000 $200,000 $150,000 Median Sale Price 0 0 0 0 in o w 0 0 0 O $100,000 $50,000 $0 m O 4 g O O O N N N O O 0 te 0 N ,o C $200 r> o m O 4 g O O O N N N Single Family Multifamily (2-9) •$150 $100 11 $50 $0 ,o Submitted into the p lie record t'yor it (s) Z . t on 3/ tV� . Cit� Clerk 542 residential sales (243 unique parcels); 154 arm's length 165 single family home sales (75 unique parcels); 54 arm's length 297 multifamily 2-9 unit sales (131 unique parcels); 82 arm's length 76 vacant residential sales (33 unique parcels); 16 arm's length Single family owner occupancy rate: 2010 - 49%; 2018 - 41 % Median Price per Square Foot M .a N 'a co O 4 _h O O O N N N Single Family Multifamily (2-9) Figure 10. Tract 22.01 Median Sale Price $700,000 $600,000 $500,000 $400,000 0 0 $300,000 Lei co $200,000 $100,000 $0 0 0 0 O 0 O ,O co O 4 O O O N N (V Single Family ,o sr 0 0 O h 49 f ) .o co O 4 O O 0 N N N Multifamily (2-9) Submitted into the public record or it m(s) Q Z, \ t on I City Clerk 510 residential sales (280 unique parcels); 197 arm's length 321 single family home sales (171 unique parcels); 127 arm's length 143 multifamily 2-9 unit sales (76 unique parcels); 56 arm's length 42 vacant residential sales (29 unique parcels); 12 arm's length Single family owner occupancy rate: 2010 - 69%; 2018-63% $350 $300 $250 $200 $150 $100 $50 $0 12 Median Price per Square Foot CO M N CO o• N .o co O 4 n O O O N N N co O N CO N cn ,o m O 4 t\ O O O N N (V Single Family Multifamily (2-9) Figure 11. Tract 22.02 $ 350,000 $ 300,000 $ 250,000 $ 200,000 $150,000 $100,000 $50,000 $0 Median Sale Price O O O ts► O O. 9. M .a co O R O O O N N N Single Family , Submitted into the pitlic record fpr it s) L. I °ia� on �l �,t� , Cily Clerk 1,677 residential sales (747 unique parcels); 532 arm's length 1,135 single family home sales (501 unique parcels); 361 arm's length 415 multifamily 2-9 unit sales (184 unique parcels); 136 arm's length 125 vacant residential sales (60 unique parcels); 34 arm's length Single family owner occupancy rate: 2010 - 67%; 2018 - 55% Median Price per Square Foot o • $250 Lcrji N $200 O O O ri m Multifamily (2-9) $150 $100 0 $50 $0 c, 43 m O 4 n O O O N N N Single Family 13 0 N M 43 c0 O 4 f\ O O O N N N Multifamily (2-9) Submitted into (s) on o; the public record �j/ Li / t't • P CitytC leek 111. Elevation Maps Figures 12 and 13 show the elevation of land above sea level in the city of Miami and in Little Haiti, respectively. The maps shows that the southern and southwestern portions of the neighborhood are part of a band of higher elevation land that stretches on either side of the I-95 corridor. The northern portion of Little Haiti is on lower ground, mostly under two meters elevation. Figure 12. City of Miami Elevation Map, in Meters above Sea Level City of Miami Elevation Map 0 meters 0.01 .2 meters 2.01 - 5 meters 5.01 - 10 meters IIII 10.01:y 26 meters Little Haiti Major Highways Data Source: U.S. Geological Survey, Earth Resources Observation and Science Data Center 14 Figure 13. Little Haiti Elevation Map, in Meters above Sea Level Submitted into the public record f r ite (s) Z. I Z on 3 Ci lark Little Haiti Elevation Map o meters 0.01- 2 meters 2.01- 5 meters al 5.01-10meters JIM 10,01- 2e meters. """--- Major Roads E:zf Census Tracts ERG Data Source: U.S. GeologicalSurvey, Earth Resources Observation and Science Data Cen ter 15