HomeMy WebLinkAboutMiami International Airport Airline Liaison Office response to April 8, 2022 memo - Letter dated 07-05-2022Fl
MIAMI INTERNATIONAL A[RPORT
Commercial Airport:
Miami International Airport
General Aviation Airports:
Dade -Collier Training & Transition Airport
Miami Homestead General Aviation Airport
Miami Executive Airport
Miami-Opa Locka Executive Airport
July 5, 2022
Ms. Sandra Cisneros
Miami International Airport Airline Liaison Office (MIA ALO)
5200 NW 21 st Street, Terminal E
2nd Floor, Room # E2573
Miami, FL 33122
Miami -Dade Aviation Department
P.O. Box 025504
Miami, Florida 33102
T 305-876-7000 F 305-876-0948
www,rT1 ami-airport.com
RE: Status of Miami Freedom Park Project and Response to April 8, 2022 Memo
Dear Ms. Cisneros:
miamidade.gov
This is to acknowledge receipt of your memo dated April 8, 2022, in which you identified the
airlines' issues concerning the Miami Freedom Park (°MFP") project, a proposed soccer stadium
and commercial development to be located on City of Miami property at 1400 NW 37 Avenue.
The Miami -Dade Aviation Department ("MDAD") understands and shares the airlines' concerns.
The purpose of this letter is to show the actions MDAD has taken to address these issues and
provide you with the available project related documents you requested.
As you may be aware, on April 28, 2022, the City of Miami ("the City") commissioners voted 4-1
in support of the Miami Freedom Park project. Your memo states that the airlines have concerns
that the project may adversely affect their ability to operate flights safely without the loss of
operational capacity or efficiency and impede roadway access to Miami International Airport
(MIA). In addition, you state that the airlines have expressed concerns over potential light
impacts which may emanate from the project's roofing material as well as the potential for
construction cranes to create obstructions which would adversely affect flight operations.
Furthermore, the memo mentions the airlines' concerns over stadium events which may
generate helicopter traffic, banner towing, lasers and light interference, drone usage and
potential noise mitigation regulations which may impact flight operations.
Due to the proposed project's proximity to MIA, MDAD has carefully monitored the status of the
proposed project through media reports and has taken a proactive approach to analyzing the
conceptual plans and conducting airspace analyses based on the available information provided
by the developer's representatives. On July 2, 2019, MDAD met with the developer's
Ms. Sandra Cisneros
July 5, 2022
Page 2
representatives from Greenberg Traurig and Arquitectonica to discuss the project and its
impacts. In that meeting, MDAD explained that the proposed development must be compatible
with airport operations and cannot compromise safety or airport viability. The developer is well
aware that all uses on the parcel are required to comply with federal, state and local aviation
regulations, including the Code of Miami -Dade County, Chapter 33 as it pertains to airport
zoning.
On November 5, 2019, MDAD hosted a meeting with the airlines, to discuss the potential
impacts of the proposed project. On January 22, 2020, MDAD issued its preliminary letter of
determination which identified issues and made recommendations. On February 20, 2020, at
the County mayor's request, MDAD finalized a report which addresses potential impacts to
airport operations, primarily focusing on aircraft operations, airspace, and land use compatibility.
On June 7, 2022, MDAD participated in the kick-off traffic methodology meeting. MDAD
provided the attorneys representing the developer a copy of your April 8th memo as well a list of
its own concerns. On June 8, 2022, MDAD participated in the City's virtual Coordinated Review
Committee ('CRC") Meeting providing comments regarding the proposed elevation and site
plans. A subsequent update on the status of the project will be submitted to the Board of
County Commissioners on July 7, 2022.
It should be noted that most the airlines' concerns regarding traffic, stadium lighting, event
impacts and construction cranes were outlined in MDAD's Preliminary Airspace and Land -Use
Letter of Determination and subsequent analytical report.
Concerning traffic congestion, MDAD's preliminary letter of determination states "As per Miami -
Dade County's Comprehensive Development Master Plan Aviation Subelement Policy AV 4A,
MDAD must give priority consideration to on -site and off -site roadway capacity enhancements
that provide or will improve airport access. As such, MDAD expects the developer to mitigate
traffic impacts especially to the main access points at MIA which must remain unimpeded. The
traffic for the stadium must not disrupt airport operations." MFP is conducting a traffic
methodology study. MFP held the kick-off meeting for the traffic methodology study on June 7,
2022 with representatives from the Florida Department of Transportation, the Miami
Expressway Authority, the City and MDAD. Your April 8, 2022 memo along with MDAD's
comments regarding traffic concerns were presented to Ms. Iris Escarra, the attorney
representing the developer, after the meeting.
Concerning lighting, MDAD's preliminary letter of determination states "the developer will need
to evaluate the angle of reflection from the stadium relative to the angle of approach/departure
that aircraft may take upon ascent and descent from a runway surface. Additionally, the amount
of sun exposure to the roof's reflective surface may also have a negative impact. The developer
must be able to demonstrate to MDAD that all lighting associated with the .stadium and practice
fields does not negatively impact airport operations."
Ms. Sandra Cisneros
July 5, 2022
Page 3
Concerning stadium event impacts, MDAD's preliminary letter of determination states "MDAD
respectfully requests a proffered covenant running with the land in the re -submittal application
package. The terms of the covenant should include, but not be limited to the following:
• An avigation easement. MDAD cannot be responsible for noise generated from frequent
and direct overflights of commercial air traffic at very !ow altitudes.
• The entire stadium inclusive of all corridors, circulation and ancillary spaces must be
outside of the Outer Safety Zone.
• The architect's plans must illustrate mitigation of any light emissions for the stadium,
numerous practice fields, and video boards.
• The exterior of the stadium and roof are required to contain materials that are not
reflective or can degrade the airport's surface radar signals and strength.
• Prohibition of drone, radio -controlled aircraft and balloons, restrictions on helicopter,
blimps and banner towing aircraft, prohibition of fireworks, smoke machines and laser
light shows.
• Prohibition of establishments or uses that emit smoke, gases or dust in quantities or
densities sufficient to jeopardize the safe use of the airport.
• The stadium's electronic gear cannot interfere with radar, voice communications and
other navigational aids to aircraft.
• Prohibition of any associated uses that attract or sustain birds and bird movements.
• Provide traffic mitigation"
As for the potential for construction cranes to create obstructions, MDAD stated in its
preliminary letter of determination, "MDAD and aviation industry stakeholders are concerned
with the impact to aircraft operations from 1-2 years of construction cranes for the stadium and
its mixed -use development. All construction cranes for this project at this location must be filed
by the construction contractor using FAA form 7460-4. MDAD will also need to review and
approve the construction cranes heights and locations associated with this construction project."
The following list contains your request for project related records. The attachments contain the
current project information, which may be subject to future revisions. Please note, at this time,
not all the records you have requested are available.
1. A comprehensive traffic study analyzing current traffic, anticipated traffic at the airport
and, upon completion, anticipated traffic related to the proposed Freedom Park (See
attached Exhibit 1: Traffic Report and Summary, Methodology and MDAD's Comments
from Methodology Kick -Off Meeting).
2. A copy of an airspace analysis and any airspace related coordination between the FAA
and MDAD (See attached Exhibit 2: MDAD-Issued Preliminary Airspace Land Use Letter
of Determination, Drawing Comparing Points Studied by MDAD and FAA, MDAD's
Ms. Sandra Cisneros
July 5, 2022
Page 4
Objection Letter to FAA, MFP's Revised Survey, MDAD Analysis of Revised Elevations,
Memo to MDAD Director).
3. Proposed structure plans and renderings for all facilities at Freedom Park with GPS
coordinates and structure heights (See attached MFP's CRC Submittal 5-26-22
drawings specifically: A-16 — Height Limitations, A-61 & A-62- Stadium Elevations and
A-73 — Parking Garage Elevations). The elevations and locations of the proposed
commercial buildings were not included in the project book. Note, during the June 8,
2022 City of Miami virtual CRC Meeting, MDAD requested a revision of the stadium
elevation plans to include GPS coordinates for the proposed elevations.
4. The construction schedule and phasing for Freedom Park (See attached Exhibit 4: PPD-
2, Economic Impact Analysis) with details on how construction will be coordinated with
MDAD and the airlines. According to the June 2020 Economic Impact Analysis (Exhibit
PPD-2) the phases of the proposed development are estimated to occur over a 7- to 10-
year development period (although the stadium is estimated to be completed within 36+
months from project commencement). The attorney for the developer provided the
following tentative schedule for the City's Masterplan/SAP Approval:
• City of Miami Staff Review pending — 2-4 months
• Traffic Report re -submittals, coordination with City, County, State — 8-10 months
• Coordinated Review Committee (CRC) — June 8, 2022
• City Public Hearings; Urban Design Review Board (UDRB), Planning Zoning
Appeals Boards (PZAB), City Commission First Reading, State of Florida DEO
Review, City Commission Second Reading, approximately 6-8 months
(estimated dates if no deferrals by the Boards).
• Special Area Plan Approval — estimated First. Quarter of 2023
• FAA re -submittal of stadium points — after SAP Approval — within 2 weeks
• MDAD re -submittal of complete package — upon receipt of FAA approval
MDAD's updated report is based on the most recent printed information made available
to the public through a Special Area Plan ("SAP") Concept Book, which was published
on June 20, 2020, and updated on May 7, 2021. It can be viewed at:
https://miamifreedompark.com. Currently, the City's Masterplan / SAP Approval includes
detailed site plan for the Stadium and Garage only. All other buildings are depicted for
demonstrative purposes. The SAP anticipates that each subsequent building will need to
independently pursue its only site plan review process for compliance with the Code. All
construction cranes for this project at this location must be filed by the construction
contractor using FAA form 7460-1. MDAD will also need to review and approve the
construction cranes heights and locations. Upon completion of the project, no Certificate
of Use or Certificate of Occupancy shall be issued by Miami -Dade County until approval
is obtained from MDAD certifying that the structure was built no higher than the height
approved.
Ms. Sandra Cisneros
July 5, 2022
Page 5
5. An expected usage analysis of Freedom Park, inclusive of expected games and events
has not been provided.
6. Confirmation that the construction will comply with the FAA's Advisory Circular 150-5300
13A, the One -Engine -Inoperable surface, and all Miami -Dade County Ordinances.
Please see the attached MDAD-Issued Preliminary Airspace and Land Use Letter of
Determination which states that the developer must comply with federal, state and local
aviation regulations.
7. Benchmark analyses and impacts of other airports with nearby stadiums. (See MDAD's
January 22, 2020 'DRAFT Airspace and Land Use Impacts from Proposed Miami
Freedom Park Development" (Pages 18-24). These draft case studies were developed
by MDAD's airspace consultant while preparing MDAD's report.
8. Zoning Ordinances and maps (see attached).
MDAD looks forward to continued dialog with the Airlines Liaison Office to ensure that the
project is as complementary with airport and flight operations as much as possible. Should you
have uestions, please feel free to contact me at 305-876-8080.
C:
Ramos, R.A., LEED AP
ion Director Aviation Planning, Land -Use & Grants
K. Pyatt
A. Finol
J. Marin-Urrea
J. Deblois
A. Riaz
R. Bergeron