HomeMy WebLinkAboutSubmittals at 07.20.2022 PZAB Mtg - MDAD Correspondencee5,01\kiA± .d '\- - r- c rd
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MIAMI DADE AVIATION DEPARTMENT
CORRESPONDANCE
FROM: Miami -Dade Aviation Department between Miami Airline Liaison Office,
Miami International Airport and City of Miami Planning Department.
Nunez, Efren
Subject: FW: MDAD's CRC Comments for Miami Freedom Park June 8th Meeting
Attachments: MAAC Freedom Park Letter12-10-19.pdf; Memo to MDAD Freedom Park Update April 8
2022.pdf; Response Letter to ALO 7-5-22.pdf; Miami Freedom Park Preliminary LOD
01-22-2020.pdf
From: Ramos, Jose A. (Aviation) <JRAMOS( FIyMIA.com>
Sent: Tuesday, July 12, 2022 10:59 AM
To: Hull, Lakisha <LHull@miarnigov.com>; Snow, David <dsnow@miamigov.com>; Ellis, Jacqueline
<JEIIisPmiamigov.com>; Garcia -Pons, Cesar <cgarciaponsPrniamiRov.com>
Cc: Finol, Ana (Aviation) <AFinol@FlyMlA.com>; Riaz, Ammad (Aviation) <ARiaz cr FIyMIA.com>; Bergeron, Renee
(Aviation) <RBergeron@FlyMlA.com>; Escarral(gtlaw.com
Subject: MDAD's CRC Comments for Miami Freedom Park June 8th Meeting
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Good morning:
Thank you for inviting the Aviation Department (MDAD) to participate in the City's June 8,
2022 virtual CRC meeting concerning the proposed Miami Freedom Park project. Due to the
proposed project's proximity to Miami International Airport (MIA), and as a concerned
stakeholder, MDAD appreciates being involved in the City's review process and welcomes
opportunities to provide comments as the project evolves. Now that the City of Miami
Commissioners have approved the location of the project, MDAD stands ready to continue to
assist the City with its review and approval process of the structures so the City may ensure
that the proposed stadium and its commercial buildings achieve compatibility with airport
operations and zoning requirements prior to construction and the issuance of permits.
The initial data submittal to MDAD from the developer's representatives in 2019 was limited
to just a few points for a proposed stadium, with the proposed commercial buildings omitted
from the review request. It is always MDAD's desire to analyze any development proposal
holistically. Without having information concerning the commercial component, in the
interest of completeness, MDAD provided comments for 131-acre parcel (see attached
Preliminary LOD). Most of MDAD's concerns and recommendations referenced in this letter
are still applicable. Of critical importance to MDAD is how the developer will address
anticipated traffic congestion, the use of lights for the stadium complex and airport zoning
impacts. MDAD has requested a declaration of restrictions from the developer, which among
other things, prohibits certain uses and events. MDAD would like to have that draft covenant
to review as soon as possible. As discussed during the June 8th CRC meeting, MDAD requests a
revision of the stadium elevation plans to include GPS coordinates for the proposed
i
elevations. Also, MDAD continues to have concerns with proposed commercial structures
which may be located within MIA's Outer Safety Zone (OSZ). The 131-acre Miami Freedom
Park site is partially contained within MIA's OSZ. Within the OSZ, new residential construction,
educational facilities, hospitals, religious facilities, and other buildings for public assemblage,
shall be prohibited. In no event shall these prohibitions be varied.
For your information, attached please find communications from MIA's Airport Liaison Office
(ALO) which outline the airlines' concerns with the project and MDAD's response. May this
email and the attached documents serve as MDAD's comments to the June 8th CRC
meeting. Should you have any questions, please do not hesitate to contact me.
Jose A. Ramos, R.A.
Division Director Aviation Planning, Land -Use and Grants
Miami -Dade Aviation Department
P.O. Box 025504
Miami, FL 33102-5504
305-876-8080 Phone
305-342-9514 Cell
305-876-7630 Fax
jramosaflyM IA.com
www.iflvMlA.com
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2
MIAMI AIRLINE LIAISON OFFICE
r+:.y .01 Sandra Cisneros — Officer -in -Charge 2045 W. North Ave, Ste 2B 312.498.4170
Chicago IL, 60647
December 10, 2019
Mr. Jose A. Ramos
Division Director
Aviation Planning
Miami Dade Aviation Department
Miami International Airport
P.O. Box 025504
Miami, FL 33102-5504
VIA ELECTRONIC MAIL
RE: Miami Freedom Park Development
Dear Mr. Ramos,
I am writing on behalf of the Miami Airport Affairs Committee (MAAC) to provide the Miami Dade Aviation
Department (MDAD) with airline (including air cargo carrier) comments and to request additional
information regarding the Miami Freedom Park Development (Freedom Park). We have outlined initial
concerns expressed by the airlines based on the available information for the proposed Freedom Park and
the data presented at the MDAD-hosted meeting held on Tuesday, November 5, 2019.
The chief concern of the airlines is the potential for Freedom Park to adversely impact their ability to
operate flights safely without the loss of operational capacity or efficiency and to impede roadway access
to Miami International Airport (MIA) for passengers and employees. The proposed Freedom Park would
be located less than one mile east of Runway 9-27, Miami International Airport's (MIA's) longest runway.
This runway is especially critical for the many long haul operations departing MIA. To ensure operational
safety, Runway 9-27's extended centerline must remain clear of obstructions as per FAA regulations and
at this point it is not clear whether the Freedom Park development complies with this requirement. In
addition, it is unclear whether or not Freedom Park will present obstructions to the One -Engine -
Inoperable surface for all aircraft in the airlines' respective fleets. Beyond flight operations concerns, the
airlines are also alarmed by the proximity and expected high volume of roadway traffic to Freedom Park
and the expected congestion that could impede or delay access to MIA by passengers and airport
employees. A number of destinations from MIA, including to South America, may have only one daily
frequency, increasing the adverse impact to customers who miss a flight due to surrounding traffic
congestion. Flight operations could be delayed or cancelled if crew or support staff cannot gain timely
access to MIA.
The following is a list of operating concerns compiled from airline input and requests for information
regarding the proposed Freedom Park:
Operating Concerns:
• Miami ATC often uses a vector from the runway to avoid thunderstorm cells on departure. The
stadium and additional buildings will restrict the available open departure headings, limiting
capacity.
Page 2 of 3
• Development of the stadium and facility may encourage further potentially disruptive
development around the airport
• Payload impacts from ancillary lighting, obstacle clearance, or alternate runway
• Structural heights should not impede departure or arrival minimums or have any impact to
revenue cargo
• Light interference to pilots during night operations and potential for laser events
• Restrictions which may be proposed to mitigate noise with the development of the proposed
soccer stadium; instead noise levels associated with normal flight operations should be expected
at the stadium
The potential for increased drone activity, as evident at other stadiums in the country; drone
usage is difficult to prevent and police
• Event day vehicular traffic causing traffic delays to the airport and blocking airport access on Le
Jeune Road
• Potential for construction cranes to create obstructions, adversely affecting operations and
impacting minimums; communication of crane UP/DOWN status will be critical
• Potential for structures to interfere with navigational signals
• Banner towing impacting air traffic arrivals and departures at MIA
• Evaluation of proposed roofing material of Freedom Park structures should be required to ensure
no light, including sunlight, is reflected into aircraft cockpits
• Helicopter traffic
• Potential loss of efficiency due to temporary flight restrictions during VIP events
This preliminary list of concerns may be amended as additional information, analyses, studies are provided
for review and/or airline participation surrounding the development of the stadium.
Requests for Information:
• A comprehensive traffic study analyzing current traffic, anticipated traffic at the airport and, upon
completion, anticipated traffic related to the proposed Freedom Park
• A copy of an airspace analysis and any airspace related coordination between the FAA and MDAD
• Proposed structure plans and renderings for all facilities at Freedom Park with GPS coordinates
and structure heights
• The construction schedule and phasing for Freedom Park with details on how construction will be
coordinated with MDAD and the airlines
• An expected usage analysis of Freedom Park, inclusive of expected games and events
• 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
• Benchmark analyses and impacts of other airports with nearby stadiums
• Recently approved MIA Zoning Amendment documents
Outlined below are observed impacts at other airports with a stadium nearby:
• LAX- The roof at the new Los Angeles Rams Stadium in Inglewood has been determined to cause
multiple radar issues including duplicate targets for the same aircraft and inaccurate targets.
After one year of debate and troubleshooting, the stadium finally agreed to purchase a secondary
radar for LAX airport.
• LAS- The new Las Vegas Raiders football stadium in downtown Las Vegas presents a significant
impact to vehicular access to McCarran Airport LAS. The Raiders and LAS have not yet reached
an agreeable solution for this problem.
Page 3 of 3
PHX- FAA discovered they did not have the authority to prevent Arizona State University from
detonating fireworks during football games at Sun Devil Stadium. PHX TRACON facility was forced
to shut down landing access to the south runway complex at PHX due to firework usage.
• SJC- San Francisco 49ers stadium in Santa Clara creates routine concerns for flight crews due to
bright lights.
The MAAC looks forward to continued engagement with MDAD and other airport stakeholders to ensure
safe airport operations and reasonable access to the airport in light of the proposed Freedom Park.
Respectfully,
Sandra Cisneros
Miami Airline Liaison Office
CC:
MAAC Chairperson, Kendra Kennedy
MIA MAAC
Ken Scarborough, Planning Technology, Inc.
Lenore Diamond, American Airlines
Airline
Liaison
Office
Miami Airline Liaison Office
Miami International Airport
To: Miami -Dade County Aviation Department (MDAD)
From: Miami International Airport Airline Liaison Office (MIA ALO)
Date: April 8, 2022
Subject: Freedom Park Assessment from FAA Determination Letter — Update to the ALO letter
dated December 10, 2019
The MIA ALO has reviewed the documents provided from the FAA and there isn't any specific analysis we
can perform that would provide any additional information than what the FAA has included. As we
interpret these documents the FAA has determined that the proposed light poles on the stadium which
are the highest penetration to the PART 77 and other surfaces at the MIA do not represent any hazard to
air navigation, other than requiring certain conditions relating to lighting them etc. The FAA has identified
that some of the proposed lighttowers on top of the stadium do violate some Part 77 surfaces, specifically:
• The MIA Horizontal Surface by 1 foot (for 9 of the proposed lights)
• MIA Runway 9/27 Transitional Surface by 1 foot (2 of the 14 lights)
They also identified an obstruction to the TERPS criterial that increases minimum instrument flight
altitudes and specifically the Departure Surface. In their further analysis they state these obstructions
would not increase the departure minimums and specifically no increase to the ceiling, visibility or climb
rate. Typically, the airlines can best advise on the degree of impact to their operations from an obstacle
particularly as it relates one engine out departure surface impacts (sometimes the required climb gradient
can result in payload reductions or affect the range of the aircraft when using that runway). Where we
have seen this before such as at ORD we typically have passed the obstruction information onto the
airlines themselves for their subject matter experts and engineering departments to run through their
models and determine how significant the impact would be.
There are some other items that could be issues in the future once the stadium is in place or during its
construction, issues we have previously raised with MDAD and the BCC with our first letter of concerns
dated December 10, 201.9. First related to traffic during stadium events since the location is directly
adjacent to the primary public entrance to the airport which likely will increase congestion and from an
environmental standpoint could result in increased emissions that could reflect negatively on the airport
in future EA/EIS type analysis or drive additional mitigation measures. Lighting — depending on the
orientation of the lights, materials used in construction of the stadium etc. there is the possibility that
even though the lights would be aimed down into the stadium they could have reflection or other issues
that would be distracting to pilots on approach to Runway 27 and possibly other runways as well. Potential
temporary impacts during construction — The FAA has analyzed the completed final points of the
structure, there will be a separate airspace analysis required to evaluate temporary impacts due to
Page 2 of 2
construction. It is likely that construction of the stadium will require the use of cranes whose height will
exceed that of the final lights. Depending on the location of these cranes there could be impacts to
operations at MIA and on Runway 9/27 from the cranes that would be more significant than what results
from the completed building. These are difficult and/or challenging to identify or assess at this time,
without more specific information on the height and locations of the cranes.
Our recommendation is effectively for the airlines to socialize this issue with subject matter experts
related to operational procedures that may need to be modified based on the FAA's determination letter,
MDAD's concerns, and the ALO's initial assessment.
Respectfully,
•
Sandra Cisneros
MIA ALO
IAINO I TGRNAT!QNAL AIRPORT
Commercial Airport:
Miami international Airport
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Dacia-CaillorTralttiTrg F Tritlisr6birAirport
Miami Homestead General Aviation Airport
Miami EAecrutive Airport
Miami-Opa Lucka Ex1...crrlive Airport
July 5, 2022
Ms. Sandra Cisneros
Miami International Airport Airline Liaison Office (MIA AL,O)
5200 NW 21 st Street, Terminal E
2nd Floor, Room # E2573
Miami, FL 33122
Miami -Dade Aviation Department
R.O. Box 025504
Miami, Florida 33102
T 305-876-7000 F 305-876-0948
www. m f i1 flit -a i rport. com
RE: Status of Miam 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 an 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 e 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
Fetter 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 low 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. Alt 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 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 ail 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
a 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://miamifreedomoark.com. Currently, the City's Masterpian / 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. Benchrnark 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 rooks forward to continued dialog with the Airlines Liaison Office to ensure that the
project is as complementary with airport arid flight operations as much as possible. Should you
have jestions, please feel free to contact me at 305-876-8080,
Jos ' A. Ramos, R.A., LEED AP
Divi ion Director Aviation Planning, Land -Use & Grants
C: K. Pyatt
A. Finol
J. Marin-Urrea
J, Deblois
A. Riaz
R. Bergeron
MIAMI
INTERNATIONAL AIRROAE
Coronierctat Airport;
Miami intertratioire Airport.
General Aviation Airports:
Dade -Cater Trint ping A Trartgition Airport
MIa Homestead Geporat Aviation Airport
Miami Executive Airport
tiAl.rtnti•ON I ocira Fvi4No Airport
January 22, 2020
Ms, Katie Doyle
Capitol Airspace Group
5400 Shawnee Road, Suite 304
Alexandria, V.A 22312
Miami -Dade Aviation Department
P.O. Box 025.504
Miami, Florida 33102
T 305-876-7000 F 305-876-0948
www.miami-airport.com
miamidade.gov
RE: Determination Number DN-1.942-294'7 Preliminary Land-Use/Airspace Analysis for the
131-Acre Site of the Proposed "Mimi Freed.orn Park" project located at 1400 NW 37
Avenue, Miami, FL 33137 (Folio Ntunber0-1-3132-000-0080)
Dear Ms. Doyle:
The Miami -Dade Aviation Department (MDAD) is in receipt of your submittal for a. preliminary
land-use/airspace analysis and determination for a proposed soccer -stadium to be located. on a
portion of the 131-acre City of Miami owned Melreese Golf Course and Country Club. The site
is roughly bounded by .NW 42 Avenue, NW 14 Street, NW 37 Avenue and South -of NW 21
Street and the address is 1.400 NW 37 Avenue. in Miami, Florida. In addition to the 25,000-seat
stadiurn, it has been reported that the Miami Freedom. Park, designed by AxquitectOnica, will
include 750 hotel rooms, at least 1 million. square feet of office, retail and conunercial space,
numerous soccer and 58 acres allocated. for a .public park.. The proposed stadium would
have a range of heights with the highest point having a maximum elevation of 160 feet Above
Mean Sea Level (AMSL). The site is located immediately east of Miami...International Airport
(MIA) beneath. a flight path of aircraft landing on MIA's Runway 27 or departing from. Runway
9. As such, it would experience frequent and direct overflights from commercial air traffic at
very low altitudes..
In the interest of completeness, MDAD is providing the following preliminary comments for the,
131-acre parcel:
Land Use Review:
Any proposed development this close in proximity -to MIA warrants special attention in the
planning process, as it is important to assess any potential safety issues; avoid any potential
restrictions on airport operations; and to provide for quick and efficient access to the airport for
Ms. Katie Doyle
January 22, 2020
Page 2
all users. All land uses adjacent to MIA must be compatible to ensure that their capacity and
function are complementary with airport and flight operations.
Please be advised that the site is partially or fully impacted by the following airport land use and
noise compatibility restriction zones referenced in Article XXXVII of Chapter 33 of the Code of.
Miami -Dade County Airport Zoning (Airport Zoning Code), Sec. 33-333:
The 131-acre Miami Freedom Park site is partially contained within the Outer Safety Zone
(OSZ). Within the OSZ, new residential construction, educational facilities, hospitals, religious
facilities, and other buildings for public assemblage, shall be prohibited. In no event shall these
prohibitions be varied with respect to MIA. It is provided, however, that aviation -related
schools, hotels and motels and their ancillary uses, and structures used in connection with public
transportation shall not be subject to this prohibition. Uses prohibited in the Critical Approach
Zone (CAZ) shall also be prohibited in the OSZ.
The sketch submitted by the developer depicts only the stadium with no other information except
for building elevation points. The sketch locates the stadium adjacent to the OSZ. Even though
the stadium appears to be outside of the OSZ, the fact that it abuts a safety zone is concerning.
Before MDAD can evaluate the impacts, the applicant must submit floor plans inclusive of all
corridors, circulation and ancillary spaces for the proposed stadium. MDAD is tasked with
protecting the public health, safety and welfare by limiting the type and densities of land use
activities in high risk safety areas near runway ends. The FAA entrusts MDAD to be the
enforcing agency and do all within its powers to not permit incompatible uses in close proximity
to the airport. By accepting federal grants, MDAD agrees to maintain and operate the airport in a
safe and efficient manner. Acceptance of the grant invokes certain conditions and assurances
with which MDAD must comply. FAA Grant Assurance Number 21 states that the sponsor "will
take appropriate action, to the extent reasonable, including the adoption of zoning laws, to
restrict the use of land adjacent to or in the immediate vicinity of the airport to activities and
purposes compatible with normal airport operations, including landing and takeoff of aircraft."
MDAD relies heavily on grants from the FAA to develop and operate MIA. To encourage the
encroachment of incompatible uses may jeopardize future grants.
It should be noted that the airlines have expressed concern with the anticipated high volume of
roadway traffic to Miami Freedom park as well as the expected congestion that could impede or
delay MIA passengers and airport employees. Scheduled flight operations could be cancelled if
crew or support staff cannot gain timely access to MIA. 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. MDAD must do everything it can to protect MIA's
capacity. Capacity planning typically relates to standard operating conditions. If operating
conditions are not optimal, then they have a negative impact on capacity. When MIA is operating
Ms. Katie Doyle
Tanuary 22, 2020
Page 3
at levels near to its theoretical capacity, then any disruption results in delays. These delays have a
significant cost, thus reinforcing the need to maximize capacity,
The 131-acre Miami Freedom Park site is partially contained within the Critical Approach
Zone (CAZ). The following uses shall be prohibited within this zone: Hospitals, stand-alone
emergency rooms, urgent care facilities, skilled nursing facilities, assisted living facilities, adult
day care facilities, day nurseries, and educational facilities, excluding aviation -related schools;
establishments or uses that emit smoke, gases, or dust in quantities or densities sufficient to
jeopardize the safe use of the airport; establishments or uses that create electrical interference
with radio communications between the airport and aircraft; make it difficult for aircraft pilots
and tower control operators to distinguish between airport lights, aircraft and others; result in
glare in the eyes of aircraft pilots using the airport, or tower control operators; impair visibility in
the vicinity of the airport; or otherwise endanger the landing, taking off, or maneuvering of
aircraft; landfills, as defined in section 403,703, Florida Statutes; and any associated uses that
attract or sustain birds and bird movements. In no event shall these prohibitions be varied.
In light of the above Code imposed restrictions, MDAD has serious concerns that the proposed
soccer stadium lighting, the proposed numerous practice fields' (an estimated 24 acres) lighting,
and LED screens/scoreboards will create visual distractions for pilots. Miami Freedom Park's
publicly advertised promotional renderings emphasize large luminous LED panels and glowing
lights emanating from the stadium. Light emissions are often caused by lights that shine upwards
in the flight path. A pilot's ability to identify an airport during low-level flight altitudes can be
hindered by emissions during evening hors, storm events or times of reduced visibility such as
fog. Bright lights, including laser lights are a major concern because they are distracting and can
cause a blurred or momentary loss of vision for pilots as they pass from darkness into well -lit
areas. The lights and glare from the stadium could prevent controllers from seeing aircraft on the
final approach to Runway 27 or even taxiing in the South Terminal Area. There may also be
potential safety concerns with the stadium's use of signage, fireworks, and helicopters.
The publicly advertised promotional renderings of the stadium appear to depict an illuminated
roof or reflective roof. The assumed reflective nature of the roof is also a serious concern for
MDAD. Glare produced from reflective surfaces can blind or distract pilots during low-level
flight operations. 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 roofs 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.
The 131-acre site is fully contained in the 65-to-74 DNL Noise Compatibility Restriction
Zone. The 65-to-74 DNL Zone is a contour depicting concentrations of aircraft noise around an
airport based on clay and night noise levels averaged over a year at 65-to-74 decibels, New
residential construction and educational facilities shall incorporate at least a 25-decibel outdoor -
to -indoor Noise Level Reduction (NLR) into design and construction.
Ms. Katie Doyle
January 22, 2020
Page 4
Airspace ;Review:
Our review of the plans and data provided finds that the range of architectural elevations,
referenced in the table below, with a maximum elevation of 160' AMSL/NAVD88 for the
proposed project, does not conform to the requirements of the Airport Zoning Code. The height
reference is an estimated height provided by you on behalf of the developer, therefore this letter
is issued on a preliminary or advisory basis. The impacts are noted in the fallowing table:
LOCATION
HEIGHT
REQUESTED
MAXIMUM
CODE
ALLOWED
HEIGHT
EXCEEDS MIA
HEIGHT ZONING
BY:
Pt, 1
Lat: 25° 47' 37.08"
160 ft. AMSL
160 ft. AMSL
Long: 80° 15' 43.23"
Pt. 2
Lat: 25° 47' 37.31"
160 ft. AMSL
160 ft. AMSL
Long: 80° 15' 36.63"
Pt. 3
Lat; 25° 47' 34.05"
160 ft. AMSL
138.19 ft. AMSL
21.81 ft. AMSL
Long: 80° 15' 35,93"
Pt, 4
Lat: 25° 47' 32.68"
140 ft. AMSL
138.75 ft. AMSL
.L.25 ft. AMSL
Long; 80° 15' 35,62"
Pt, 5
Lat: 25° 47' 30.89"
114 ft, AMSL
115.17 ft:. AM.SL
Long: 80°15' 35.24"
Pt.6
Lat: 25° 47' 29.74"
103 ft. AMSL
103,25 ft. AMSL
Long: 80° 15' 41.64"
Pt. 7
Lat: 25° 47' 32.00"
135 ft. AMSL
123.81 ft. AMSL
11.19 ft. AMSL
Long: 80° 15' 42.13"
Pt, 8
Lat: 25° 47' 33.72"
160 ft. AMSL
123.16 ft. AMSL
36.84 ft. AMSL
Long: 80° 15' 42.50"
The developer is required to lower the height of the proposed stadium to be in compliance with
the Airport Zoning Code, The Miami Freedom Park site is outside of any Airport Height
Variance Eligible Areas, so no height variances are allowed. Miami -Dade County's
Ms. Katie Doyle
January 22, 2020
Page 5
Comprehensive Development Master Plan Aviation Subelement Policy Objective AV-3 requires
MDAD to minimize hazards and obstructions to airspace and ground operations so as to protect
the safety and welfare of aircraft users/operators and residents of Miami -Dade County in order to
assure the economic vitality, safety, efficiency and capacity of the airport system.
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 7460-1, The form is available through the FAA website: https://oeaaa.faa.gov
where the contractor may e-file the information. Because ofthe development proximity to MIA,
this office will also need to review and approve the construction cranes heights and locations
associated with this construction project.
Based on the information provided, MDAD cannot approve the current submission of the project
since the proposed structure exceeds MDAD's established airport zoning height restrictions at
the referenced locations. In addition, the proposed stadium lights may create a visual distraction
which can threaten the safety of aircraft operations. MDAD maintains that any proposed
development in close proximity to MIA must be compatible with airport operations and cannot
compromise safety or airport viability. In order to properly analyze the project, MDAD will need
the developer to resubmit the data and plans to reflect the development for the entire site. MDAD
will not be able to provide a final determination on the project until the following occurs:
1. The developer submits a fully developed site plan which depicts the stadium, numerous
soccer practice fields and lighting, and ancillary mixed -use development. The stad.ium's
corridors, circulation and ancillary spaces for the proposed stadium must be completely
outside the OSZ.
2. The developer reduces the height ofthe stadium so that it complies with Article XXXVII
of Chapter 33 of the Code ofMiami-DadeCounty Airport Zoning.
3, The FAA issues "Determination of No Hazard to Air Navigation" for the stadium.
4. The project is required to comply with all applicable federal, state and local aviation
regulations, including the Airport Zoning Code.
5. MDAD respectfully requests a proffered covenant running with the land in the re -
submittal application package. The teims 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 low altitudes
which may create an uncomfortable environment for both fans and players alike.
® The entire stadium inclusive of all corridors, circulation and ancillary spaces
must be outside of the Outer Safety Zone.
Ms. Katie Doyle
January 22, 2020
Page 6
• 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
Any real estate transactions of the parcel are subject to the airport land use and noise
compatibility restriction area disclosure statement refenced in the Airport Zoning Code.
All construction cranes for this project at this location must be filed by the construction
contractor using FAA form 7460-1, The form is available through the FAA wcbsite:
https://oeaaa.faa.gov where the contractor may e-file the information. Because of the
development proximity to MIA, this office will also need to review and approve the construction
cranes heights and locations associated with this construction project.
Please note that the airspace review process is governed by two different regulations: the Airport
Zoning Code and Federal Regulation Title 14 Part 77. The FAA has its own airspace evaluation
requirements, and issues airspace determinations for structures and cranes based on the particular
facts then presented before the FAA. MDAD determines whether the County's height
limitations are met, and the FAA determines whether FAA building, marking and height
requirements are met. It is the responsibility of MDAD to administer and enforce the regulations
prescribed in the Airport Zoning Code.
As per the Code of Miami -Dade County, Chapter 33, Article XXXVII, Airport Zoning Section
33-336 - Conflicting Regulations:
"Nothing contained in this article shall be interpreted to conflict with or supersede any
federal regulation pertaining to the control of airport hazards, except in those instances in
which this article imposes lower height limitations or more stringent restrictions upon the
use of land or water than are imposed or required by other County ordinance or
resolution, or federal rules or regulations, in any of which instances the provisions of this
article shall govern. Furthermore, please note that upon completion of this project, no
Certificate of Use or Certificate of Occupancy shall be issued by Miami -Dade County
Ms. Katie Doyle
January 22, 2020
Page 7
until approval is obtained from MDAD certifying that the structure was built no higher
than the height approved by this letter. The approval shall be issued by this office after
submittal by applicant of the required information as outlined in Section 33-349(A)(2)."
The analysis in this letter is based, in part, 0.11 the information you provided which includes the
stadium location with eight points to indicate the height of the structure at specific locations.
Any changes in building locations/layouts or heights Will void this analysis. Any future
cons -notion o.r alteration, including an increase to heights requires separate notice to the FAA
and MDAD.
MDAD respectfully requests that you resubmit the project to MDAD to include a revised site
plan depicting the stadiurn with its ancillary .mixed -use development as well. as addressing our
comments. This preliminary determination expires one year from the date of issuance unless
extended, revised or terminated by MDAD's Aviation Planning, Land -Use and Grants Division.
Any requests for an extension of the effective period of this determination rnust be submitted by
the applicant prior to the expiration date. At such time,. staff wi.i re-evaluate the application or
structure to determine if any significant changes to the structure and/or to the review criteria
have occurred. MDAD's Aviation Planning, Land -Use and Grants Division will then decide if
the determination in this letter may be eligible for an. extension of the effective period.
Should ys eve any questions, please feel free to contact me at 305-S76-8080.
os, R.A., LEED AP
ector Aviation Planning, Land -Use & Grants
C; • L. Sola
K. Pyatt
P. Hernandez
A. Riaz
D. Murray
Dennis Kerbel, County Attorney's Office
Nathan Kogan, Department of Regulatory & Economic Resources
Jerzy Bell, Department of Regulatory &..Economic Resources
Francisco J. Garcia, City of Miami Planning and Zoning Department
Jacqueline Ellis, City of Miami Planning & Zoning Department
Elren. Nunez, City of Miami Planning & Zoning Department
Jacob Keirn, City of Miami Planning & Zoning Department