HomeMy WebLinkAboutSubmittal-Melissa Tapanes-Llahues-Response to Mayoral Veto LetterSubmitted into the public
record fr itFm(s)
on %
City Clerk
BGRCOw RADGLL FERNAN DEZ & LARKI N
ZONING, 1_ANED USE ANS ENVIRONMENTAL LAW
DIRECT LINE: (305) 377-6220
E -Mail: JBercow0brzoninglawcom
VIA HAND -DELIVERY
September 11, 2019
City of Miami City Commissioners
3500 Pan American Drive
Miami, Florida 33133
Re: Response to Mayoral Veto of the City Commission's Rezoning of
240 SF 14 Street, Babvlon International, Inc.
Dear City Commissioners:
We represent Babylon International, Inc. (the "Applicant") with regard to the
rezoning of the property located at 240 SE 14 Street in Miami, Florida (the "Property")
We submit this response to Mayor Francis Suarez's veto (the "Veto") of the City
Commission's rezoning of the Property from T6 -8-R to T6 -24b-0. After five (5) years
and over $1.6 million dollars spent fighting for the proper zoning district, the Veto is an
unfounded political tactic, and we hereby ask the City Commission to override the Veto.
The Commission should override the Veto because:
• The Veto incorrectly categorizes the Applicant's request;
• It overlooks the express authority and findings of the City Commission;
• It is based on a partial and biased review of the record;
• It contradicts itself; and
• It violates procedural due process.
The Veto message ignores that this rezoning_ is a direct result of an error in the draft
Miami 21 zoning mans.
The Veto message starts with the adoption of the professional recommendation of
the City staff yet does not take into account that even the professional staff found that the
current zoning on the Property is improper and was a mistake emanating from the
adoption of Miami 21.
It is undisputed that under the prior Zoning Code, Ordinance 11000, the Property
was zoned "O" for Office. However, all of the draft maps utilized during the community
SOUTHEAST FINANCIAL CENTER - 200 SOUTH BISCAYNE BOULEVARD, SUITE 850 - MIAMI, FLORIDA 33131
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PHONE. 305.374.5300 - FAX. 305.377.6222 - WWW.BRZONINGLAW.COM
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Submitted into the public
cord for item(s) M\(, �
City of Miami City Commissioners record
Clerk
September 11, 2019 on
Page 2 of 7
outreach and public hearing process in consideration of the adoption of Miami 21
incorrectly marked the Property as "R-4" Multifamily Residential.' This error led to the
Property being downzoned to T6 -8-R when Miami 21 was enacted.
Since 1983 the Property was treated differently than those that front Brickell Bay
Drive. The City of Miami Neighborhood Comprehensive Plan Future Land Use Map, the
Residential Density Increase Area, and the Brickell Established Setback Area, all group
the Property with the properties to the north and west. Those other properties are all
zoned T6 -48A-0 as a result of enactment of Miami 21. During the introduction and
passage of Miami 21, the Property was improperly grouped with the properties fronting
Brickell Bay Drive that were zoned R-4, and so included in the T6 -8-R Transect. Staff has
recognized this error from 2014 to the present, and the Applicant requested this rezoning
to correct it. The City Commission's rezoning of this Property also recognized this error
yet still provided for a transition in zoning districts by approving T6-24-0.
Comparing the prior and current zoning code is speculative, like comparing
apples -to -oranges. There are some regulations that cannot be compared. However, there
are two major factors that can clearly be compared, were compared on the record, and
justify the Property's T6 -24b -O zoning: height and uses.
Under Ordinance 11000, the Property had unlimited height. As the Applicant
demonstrated, the Property is not buildable above the eighth story due to Miami 21
setback regulations. Maintaining the Veto will fail to restore the unlimited height (or any
height over eight stories) under Ordinance 11000. Ordinance 11000 also permitted non-
residential uses on the Property, such as office. Without the zone change approved by
the Commission, the Property is restricted to residential uses. Both factors deprive the
Property of significant rights. The Applicant presented evidence of these differences on
the record, they were considered by this Commission, and merit overriding the Veto.
In summary, the Veto fails to address the corrective nature of the Applicant's
rezoning request properly.
The Veto message fails to address the exv_ rens authority granted to the Citv
Commission to correct mavving errors.
According to Section 7.1.2.81, the Planning, Zoning and Appeals Board ("PZAB")
must show that it considered and studied the application with regards to (a) the goals,
objectives, and policies of the Comprehensive Plan, and (b) the need and justifications for
the change. For re -zonings particularly, the PZAB must consider the following criteria:
1 Draft Miami 21 Zoning Atlas Maps are available online at
httv://www.ndanid2l.org,/zoninizatIas East Archives.asv
B GRCOW RADELL F roRNAN DEZ & LARKI N
ZONINO. LANG USE AND ENVIRONMENTAL 4AW
City of Miami City Commissioners
September 11, 2019
Page 3 of 7
Submitted into the public
record f r, itr(s) M� ,
on / " :, s City Clerk
"a change may be made only to the next intensity Transect Zone or by a Special Area
Plan, and in a manner which maintains the goals of this Miami 21 Code to preserve
Neighborhoods and to provide transitions in intensity and Building Height." This code
section is expressly intended to address the City's growth and evolution over timet. By
contrast, the Babylon rezoning is intended to correct a mapping error dating back to when
Miami 21 was adopted.
Section 2.2.5.2 of Miami 21 recognizes that the City Commission has the authority
to take corrective action in zoning matters. Specifically, Section 2.2.5.2 provides that
"where a Transect Zone designation is not indicated for an area in the Miami 21 Atlas,
the area shall be construed to be zoned as the most restrictive Abutting Zone, until
corrective action shall be taken by the City Commission." This provision grants the City
Commission the power to correct errors where a property has no effective Miami 21
zoning Transect. Due to a lack of procedural due process the Property effectively does
not have a Miami 21 zoning designation. Since the Miami 21 rezoning failed to provide
the Property with a legal zoning designation, Miami 21 expressly grants the City
Commission authority to correct zoning atlas errors without regard to successional
zoning for properties such as the Babylon.
The Planning Department's recommendation and the Veto message fall short in
addressing the mapping correction and the process to correct mapping errors pursuant
to Miami 21. This analysis was considered and studied at length during the PZAB
hearing on May 1, 2019, and two separately noticed City Commission hearings on June
27, 2019 and July 25, 2019.3 In Ordinance 13855, the City Commission expressly found
that adoption of Miami 21 was a denial of due process as applied to the Property, and the
rezoning to T6-2413-0 is a corrective action that maintains the goals of the Miami 21 Code
to preserve neighborhoods and provide transitions in intensity and building height. The
Mayor's reasoning for the Veto is not based on the correct application of the law and is
merely the substitution of his judgment and desires based on the neighbors' intensive
lobbying 4
The Veto is based on a vartiai and biased review of the record.
The Mayor was not present at any part of the discussions at the three public
hearings where this rezoning request was considered. He did not state that he has read
Z Section 7.1.2.8g.2 of Miami 21 allows the City Commission to approve a rezoning to a less intense transect
zone than requested. If all rezonings were to address growth and were limited to the next intensity Transect
Zone, there would be no need for this authority to City Commission to approve a less intense transect.
3 Ordinance record available online at
htto://miamifl.iom2.com/Citizens/Detail LeeEile.asvx?II-5900&hiQhlisthtTerms-5900.
4 We note that the Mayor's Special Counsel, Eddy Leal, is an owner in a neighboring building and has
publicly and privately strongly opposed this rezoning.
BERCOW RADcLL FcRNANDEZ & LARKIN
ZONINO. LAND USE ANM LNVIIiONMENTAL LAW
City of Miami City Commissioners
September 11, 2019
Page 4 of 7
Submitted into the public
record fqr it (s) Av.'i
on �� / j i{ City Clerk
the entire record. At his press conference on August 2, 2019, the Mayor stated that he
based the Veto solely on the record, but referenced his time as a City Commissioner and
listed people in support of the Veto who were not present at any of the hearings and did
not speak on the record. The Veto states that "[tlhis professional recommendation was
supported by the evidence presented at the July 25, 2019 Commission Meeting, the
remarks of the District Commissioner for the surrounding neighborhood, and an
overwhelming majority of the neighbors surrounding Babylon" Clearly, the Mayor's
Veto ignores two (2) prior public hearings, on May 1, 2019 and June 27, 2019, the remarks
of four (4) voting Commissioners, and the Applicant's presentation.
The Mayor added that he is protecting people's quality of life because that was
part of his platform running for Mayor. With this, he showed that the Veto is based on
political concerns: it was heavily influenced by people who did not testify before the City
Commission, denying both the Applicant and the City Commission the opportunity to
question these people and understand the basis for their opposition, and whether that
opposition is based on factors not consistent with the City Code.
The Veto is contradictory and conclusory.
The supposed impact on the neighbors, espoused by the Mayor, is unfounded. The
Mayor provided no evidence that showed how a theoretical development at this site
would impact the quality of life of the Brickell neighborhood. In fact, the Property's
density is exactly the same for T6-8, T6-12, T6-24, and T6-48: 500 dwelling units ver acre15
The Planning Department's recommendation notes that this is where the most intensity
and highest density are intended to be located in the City. At the Mayor's press
conference, he stated that Brickell is the "densest, highest populated part of the City. It
has plenty of zoning capacity, and by -the -way will continue to grow." The Mayor failed
to note that the Property would have the same density, and thus the same impacts,
regardless of whether it is zoned T6-24 as the Commission approved, T6-12 as the
Planning Department recommended, or the result of the Veto at T6-8.
As stated in the Planning Department's recommendation and the Veto message,
the Property has always been a transitional space between the properties that face SE 14
Street and those that face Brickell Bay Drive. The T6-12 Transect is not transitional.
Practically, it limits the Property to the same capacity as the T6-8 Transect, denying the
Applicant's property rights as discussed above.
The Veto states that T6-24 is out of scale with the remaining zoning in the
immediate area. All of the properties to the north and east are zoned T6-48, which is
5 The Property is located in the Restricted Commercial Future Land Use category and the Residential
Density Increase Area.
BERCOW RADELL FERNANDEZ 5 LARKIN
ZONING, LANG USE AND ENVIRONMENTAL LAW
City of Miami City Commissioners
September 11, 2019
Page 5 of 7
Submitted into the public
record for item(s)
on City Clerk
significantly more intense than the approved T6-24 Transect. Both T6-48 and the
approved T6-24 are consistent with the Future Land Use Map. The neighboring Emerald
condominium, home to many of the objectors, has been constructed with 27 stories, three
(3) more than permitted under the T6-24 transect.6 The Mayor claims that T6-24 is not
compatible with the area, but fails to explain the nuances of the Code and Comprehensive
Plan.
The Veto also references traffic issues, but cites no traffic analysis. A City-wide
issue, such as traffic, that is not supported by evidence cannot be considered competent
substantial evidence. Case law is well settled that "traffic congestion is not sufficient
justification for the retention of an unsuitable or unreasonable zoning classification,"
Moreover, since the permitted density under T6-24 is the same as T6-8 or T6-12, there
should be no appreciable difference in traffic impacts as a result of the rezoning.
The Veto is based on internally contradictory statements and conclusory findings.
It leaves the Property with T6 -8R, an admittedly improper zoning transect.
The Veto violates the Applicant's vrocedural due process rights.
The Veto violates the Applicant's procedural due process in two specific ways: (1)
lack of notice for the press conference held in the Mayor's office to announce and discuss
the Veto, and (2) a denial of an opportunity to cross examine the objectors who influenced
the Mayor and to present evidence to overcome those objectors' objections. As a result,
basic fairness has been ignored.8
The Applicant never received notice of the press conference to announce the Veto.
The objectors received notice and were given clear instructions on the location and time
of the press conference. See Exhibit A, Veto Notice Email. The Mayor afforded himself
an opportunity, on a public stage, to present his reasoning and answer questions to
expound on the Veto without providing equal opportunity to the Applicant. There was
no opportunity for the Applicant to cross-examine the Mayor or those in attendance who
the Mayor expressly referenced as supporting his decision. A quasi-judicial decision
must be based on the record, a record created in open forum and with opportunity for
cross examination and the presentation of opposing evidence. This press conference and
the discussions between the Mayor and the objectors cannot be added to the record.
6 It should be remembered that the Property is restricted to twenty-four (24) stories based on a voluntarily
proffered Covenant, so in perpetuity the current owner and future owners cannot take advantage of Public
Benefits program to exceed this height.
7 See Debes v. City of Key West, 690 So.2d 700,702 (Fla. 3d DCA 1997).
B See Jennings v. Dade Cty., 586 So. 2d 1337 (Fla. 3d DCA 1991).
BGRCOW RADELL FcRNANDEZ & LARKIN
ZONJP44a. LANG U9E A14q ENVIRONMENTAL LAW
Submitted into the public
City of Miami City Commissioners record f r item(s) i\ 11!
September 11, 2019 on ��� i City Clerk
Page 6 of 7
Furthermore, it is clear that the press conference was merely an announcement of
the Mayor's decision to issue the Veto, and that the veto message itself had already been
drafted -- without any notice, and without any opportunity for the Applicant to present
evidence or cross examine those who were providing information to the Mayor. Almost
immediately following the City Commission's decision, the Mayor began receiving ex -
parte emails from the public, with allegations and arguments, requesting that the Mayor
exercise his veto authority. See Exhibit B, Requests for Veto. The Mayor did not disclose
these emails and the Applicant was denied the opportunity to cross examine the authors
of those emails or to present contrary evidence. In short, the Mayor made a decision in a
quasi-judicial process without providing any of the due process required for quasi-
judicial decision making.
This is not the first time a City of Miami Mayor "engaged in ex parte
communications ... during the ten day veto period..." See The Viwayans v. City of Miami,
15 Fla. 1. Weekly Supp. 657a (Fla. 11th Cir. Ct. App. Div. May 7, 2008). In that case Mayor
Diaz negotiated with the applicant during the veto period to gain additional concessions.
The Eleventh Circuit Court held that the Mayor should have discussed the matter
...within the scope of the public quasi-judicial process and required public hearing
and notice.... the Mayor's communications all took place after the hearings had
concluded, away from public earshot, and therefore violated Petitioner's due
process rights...
The result of the due process violation in this case -- an actual veto -- is much more
egregious than the attempted negotiations in The Viwayans. Mayor Suarez had multiple
ex parte communications during the ten day veto period, without required public hearing
and notice, and "away from public earshot," and therefore violated due process.
Florida law provides that ex -parte communications with the decision makers on
quasi-judicial decisions are inherently improper and are presumed prejudicial. There is
no exception for a veto of a quasi-judicial decision. The Mayor received numerous emails,
and had numerous members of the public in attendance at the August 2, 2019 press
conference. The Mayor stated they were there in support of the Veto, which he only
would have known if he had previously spoken with them. They stood behind the Mayor
and gave the appearance that they too were making this decision. The Mayor dearly
accepted input from these neighbors. The Mayor never disclosed these ex -parte
communications. It violates due process for the Mayor to base his decision on ex -parte
contacts from neighbors who did not testify before the Commission, were not subject to
cross examination by the Applicant, and were not required to answer questions from the
Commissioners. It violates due process to deny the Applicant an opportunity to present
contrary evidence to overcome the statements by the objectors.
BERCOW RADELL F`-RNANDEZ & LARKIN
ZONING. LANG USE ANO ENVIRONMENTAL LAW
City of Miami City Commissioners
September 11, 2019
Page 7 of 7
Submitted into the public
record f ite7(s)
on `� 1, q I. City Clerk
The effects of these ex -parte communications are presumed to be prejudicial
unless the decision -maker proves to the contrary by competent evidence.9 The Mayoral
Veto is a vote by a public official, who has already made a decision, without any process
to remove the presumption of prejudice from ex -parte communications.10 It is not
possible now to remove the presumption of prejudice of the Veto.
The Mayor's Veto, and the manner in which it occurred, denied the Applicant due
process and denied the Commission the opportunity to hear from these other neighbors
and evaluate their objections.
Conclusion. The Veto is a pure political ploy that comes at the expense of the
Applicant's property rights. This is a further attempt to bleed the Applicant of time and
money, and delay viable use of the Property.
For the reasons set forth in this letter, we respectfully request that the City
Commission vote to override the Veto, thus reaffirming the corrective action that Miami
21 expressly grants to the City Commission, and restoring rights taken when Miami 21
was enacted.
CC: Mayor Francis Suarez
City Attorney Victoria Mendez, Esq
Melissa Tapanes Llahues, Esq.
Thomas Robertson,, Esq.
Emily K. Balter, Esq.
Francisco Martinez-Celeiro
Max Martinez
Alicia Garcia
9 Pursuant to Florida Statute Section 286.0115, a municipality may remove the presumption of prejudice
from ex -parte communications by establishing a process to disclose ex -parte communications. Disclosures
must be made before or during the public meeting at which a vote is taken on such matters, so that persons
who have opinions contrary to those expressed in the ex -parte communication are given a reasonable
opportunity to refute or respond to the communication.
io Those individuals in support of the Veto did not register as Iobbyists, in accordance with Section 2-654
of the City Code of Ordinances, and are not subject to the disclosure requirements, in accordance with
Section 2-618 of the City Code of Ordinances.
BcRCOW RADcLL FcRNANDGZ & LARKIN
ZONING. LANG USE ANO ENVIFIONMENTAL LAW
Submitted into theP ub 'c
recon ord . 1 ? tet 1 . City Clerk EXHIBIT A
From: Irina Leibowitz <irina_leibowitz@hotmail.com>
Sent: Thursday, August 1, 2019 6:01 PM
To: Abigael Mahony
Subject: Fw: GREAT NEWS EVERYONE!
Attachments: Veto.pdf
CAUTION: This is an email from an external source. Do not click links or open attachments unless you
recognize the sender and know the content Is safe.
FYI. Thanks for your help.
Best
From: Emerald at Brickell <manager@emeraidatbrickelicondo.com>
Sent: Thursday, August 1, 201912:14 PM
To: Irina Leibowitz <irina_leibowitz@hotmail.com>
Subject: GREAT NEWS EVERYONEI
3i Emerald at Brickell
218 SE 14th St.
Miami, FL 33131
1
J
GREAT NEWS EVERYONE!
Hello everyone!
Tomorrow at 10 AM Mayor Suarez will veto the commission's approval of the
Babylon's rezoning request.
It is CRITICAL that all residents come to the press conference being held at the
mayor's office at City Hall at 10:00 AM to show support for the Mayor and his veto.
The cameras will be there, so we need to show significant numbers of support. No one
has to speak, you just need to be there and cheer.
The Mayor is squarely on the side of the residents and is doing all he can to ensure they
are protected. If the veto holds up to the inevitable challenge from the commission, then
the Babylon's application is denied and they go back to their original zoning of T6 -8-R
and cannot apply for rezoning for another 18 months and will have to start the process all
over again.
This would be a huge win for us and we would not have to pursue any further legal
action.
Submitteri ;"tom +>,..
record_tgr ue �, ��
on ,/ i i City Clerk
Again, we need as many bodies as possible there to show our support. We want to make
it perfectly clear that the neighborhood supports the Mayor as much as the Mayor is
supporting us.
Please call us at 305-416-6046 with any questions or to RSVP.
Thank you!
Submitted into the pub is
on City Clerk
' IAY loam
AT (ITY HALL
Mayor Francis Suarez will be vetoing
the Babylon up -zoning at a press
conference on August 2nd and we need
to show our support with significant
numbers of people.
This is
huge for us. If the
veto stands, the Babylon
property
will
go
back
to T6 -8-R.
So please
find
time to
be
there.
Submitted into the public
record fl 1itq(s)
qgMVcity clerk EXHIBIT B
From: 1901Emerald < 1901 emerald @gmail.com >
Sent: Wednesday, July 31, 2019 10:41 AM
To: fsuarez@miamigov.com
Subject: Babylon -Veto item PZ -9 from 7/25 Commisioners Meeting
CAUTION: This is an email from an external source. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
SUBJECT. Please Veto item PZ -9 from 7/25 Commissioners Meeting
Dear Mayor Suarez,
We are writing to ask that you to exercise your right to veto item PZ -9 that passed the second reading at the
Commissioners Meeting on July 25th.
The up -zoning of the property at 240 SE 14th Street from T6 -8-R to T6-24-130 is in clear violation of the Miami 21 Code. It
also goes against the expert recommendation of the City's Planning Department and is in complete contradiction to the
wishes of the neighborhood. The commission provided no legal basis for their decision and with this arbitrary passage of
non -successional zoning have broken Miami 21 and opened the floodgates to predatory developers to do the same thing
around the city.
We ask that you to veto this item and uphold the City's own law and protect the quality of life of the residents in this
neighborhood and around your city.
Best regards,
Christian Beyerlein
R
Submitted into the pub is
record f r ite (s) M.
on I ( City Clerk
11111111111 11111 111111111111111111111 I
11 1 1 1 1 I II IIIIIIIIIIIII 111111 1 II III 1
From:
Enrique Herrero <eherrero@herreroandsons.com>
Sent:
Wednesday, July 31, 2019 4:16 PM
To:
fsuarez@miamigov.com
Subject:
FW: Email Request to Mayor Suarez - Veto PZ -9 (Babylon Item)
CAUTION: This is an email from an external source. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Emerald at Brickell
218 SE 14th St.
Miami, FL 33131
Email Request to Mayor Suarez - Veto PZ -9 (Babylon Item)
SUBJECT: Please Veto item PZ -9 from 7/25 Commissioners Meeting
Dear Mayor Suarez,
We are writing to ask that you to exercise your right to veto item PZ -9 that
passed the second reading at the Commissioners Meeting on July 25th.
The up -zoning of the property at 240 SE 14th Street from T6 -8-,R to T6 -24 -BO
is in clear violation of the Miami 21 Code. It also goes against the expert
recommendation of the City's Planning Department and is in complete
contradiction to the wishes of the neighborhood The commission provided no
legal basis for their decision and with this arbitrary passage of non -
successional zoning have broken Miami 21 and opened the floodgates to
predatory developers to do the same thing around the city.
1
Submitted into go'
record fr ite (s),
on Q City Clerk
We ask that you to veto this item and uphold the City's own law and protect
the quality of life of the residents in this neighborhood and around your city.
Best regards,
Enrique Herrero (concerned Brickell Bay Area Resident).
You are our elected official us the residents of the Brickell
Area and need your help.
Submitted into the public
recordfqr ite}'?(s) . �'J ,
on I' I / ► y . City Clerk
From: Niraj Mehta <niraj.h.mehta@gmail.com>
Sent: Wednesday, July 31, 2019 10:11 AM
To: fsuarez@miamigov.com
Subject: Please Veto item PZ -9 from 7/25 Commissioners Meeting
CAUTION: This is an email from an external source. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Dear Mayor Suarez,
We are writing to ask that you to exercise your right to veto item PZ -9 that passed the second reading
at the Commissioners Meeting on July 25th.
The up -zoning of the property at 240 SE 14th Street from T6 -8-R to T6 -24 -BO is in clear violation of
the Miami 21 Code. It also goes against the expert recommendation of the CiVs Planning Department
and is in complete contradiction to the wishes of the neighborhood. The commission provided no legal
basis for their decision and with this arbitrary passage of non -successional zoning have broken Miami
21 and opened the floodgates to predatory developers to do the same thing around the city.
We ask that you to veto this item and uphold the City's own law and protect the quality of life of the
residents in this neighborhood and around your city.
Best Regards,
Niraj Mehta, MD
Creative Director, Making Moves Universal, LLC
Radiation Oncologist, 21st Century Oncology, Miami, Florida
Choreographer/Speaker/Writer
Submitted Into the public
record Irite (s)
on C1711, 11 City Clerk
From: Pablo Jane Martin <pjanemartin@me.com>
Sent: Wednesday, July 31, 2019 10:16 AM
To: fsuarez@miamigov.com
Subject: Please Veto item PZ -9 from 7/25 Commissioners Meeting
CAUTION: This is an email from an external source. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Dear Mayor Suarez,
We are writing to ask that you to exercise your right to veto item PZ -9 that passed the second reading at the
Commissioners Meeting on July 25th.
The up -zoning of the property at 240 SE 14th Street from T6 -8-R to T6 -24 -BO is in clear violation of the Miami
21 Code. It also goes against the expert recommendation of the City's Planning Department and is in complete
contradiction to the wishes of the neighborhood. The commission provided no legal basis for their decision and
with this arbitrary passage of non -successional zoning have broken Miami 21 and opened the floodgates to
predatory developers to do the same thing around the city.
We ask that you to veto this item and uphold the City's own law and protect the quality of life of the residents in
this neighborhood and around your city.
Best regards,
Pablo Jane Martin
Submitted into the pubic v
record f r it m(s) M
on I City Clerk
From: Regina Koenig <regina_koenig@hotmail.com>
Sent: Wednesday, July 31, 2019 2:35 PM
To: fsuarez@miamigov.com
Subject: PLEASE VETO ITEM PZ -9 FROM 7/25 Commissioners Meeting
CAUTION: This is an email from an external source. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Dear Mayor Suarez,
We are writing to ask that you to exercise your right to veto item PZ -9 that passed the second reading at the
Commissioners Meeting on July 25th.
The up -zoning of the property at 240 SE 14th Street from T6 -8-R to T6-24-130 is in clear violation of the Miami 21
Code. it also goes against the expert recommendation of the City's Planning Department and is in complete
contradiction to the wishes of the neighborhood. The commission provided no legal basis for their decision and with
this arbitrary passage of non -successional zoning have broken Miami 21 and opened the floodgates to predatory
developers to do the same thing around the city.
We ask that you to veto this item and uphold the City's own law and protect the quality of life of the residents in this
neighborhood and around your city.
Best regards,
Regina Koenig
829-619-0802
Submitted into the public
record fr it m(s) Kv, ,
on 9 717,E q City Clerk
From: Ramesh Tipirneni <ramtneni@icloud.com>
Sent: Friday, August 2, 2019 5:53 AM
To: fsuarez@miamigov.com
Subject: Please Veto item PZ -9 from 7/25 Commissioners Meeting
CAUTION: This is an email from an external source. Do not click links or open attachments unless you
recognize t e sen,, er and know the content is safe . , „ 1 11
SUBJECT.- Please Veto item PZ -9 from 7/25 Commissioners Meeting
Dear Mayor Suarez,
We are writing to ask that you to exercise your right to veto item PZ -9 that
passed the second reading at the Commissioners Meeting on July 251h.
The up -zoning of the property at 240 SE 14th Street from T6 -8-R to T6 -24 -BO
is in clear violation of the Miami 21 Code. It also goes against the expert
recommendation of the City's Planning Department and is in complete
contradiction to the wishes of the neighborhood. The commission provided no
legal basis for their decision and with this arbitrary passage of non -
successional zoning have broken Miami 21 and opened the floodgates to
predatory developers to do the same thing around the city.
We ask that you to veto this item and uphold the City's own law and protect
the quality of life of the residents in this neighborhood and around your city.
Best regards,
Ramesh Tipirneni
Resident and owner of apartment on 218 SE 14th street, 33131
Submitted into the public
record f r it (s)
on I City Clerk
From: Silvia Soto Avella <spsotoave@gmail.com>
Sent: Wednesday, July 31, 2019 10:36 AM
To: fsuarez@miamigov.com
Subject: Please Veto item PZ -9 from 7/25 Commissioners Meeting
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Dear Mayor Suarez,
I, Silvia Soto, resident of 218 SE 14TH St (33131), am writing to ask that you to exercise your right to veto
item PZ -9 that passed the second reading at the Commissioners Meeting on July 25th.
The up -zoning of the property at 240 SE 14th Street from T6 -8-R to T6 -24 -BO is in clear violation of the
Miami 21 Code. It also goes against the expert recommendation of the City's Planning Department and is in
complete contradiction to the wishes of the neighborhood. The commission provided no legal basis for their
decision and with this arbitrary passage of non -successional zoning have broken Miami 21 and opened the
floodgates to predatory developers to do the same thing around the city.
I ask that you please veto this item and uphold the City's own law and protect the quality of life of the
residents in this neighborhood and around your city.
Best regards,
Silvia Soto Avella
Submitted into the pub is
record fi itym(s) �
on 9/ 1 L/ 1 q City Clerk
From: Lourdes Delgado <cmpea@me.com>
Sent: Wednesday, July 31, 2019 10:14 AM
To: fsuarez@miamigov.com
Subject: Please Veto item PZ -9 from 7/25 Commissioners Meeting
CAUTION: This is an email from an external source. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Dear Mayor Suarez,
We are writing to ask that you to exercise your right to veto item PZ -9 that passed the second reading
at the Commissioners Meeting on July 25th.
The up -zoning of the property at 240 SE 14th Street from T6 -8-R to T6 -24 -BO is in clear violation
of the Miami 21 Code. It also goes against the expert recommendation of the City's Planning
Department and is in complete contradiction to the wishes of the neighborhood. The commission
provided no legal basis for their decision and with this arbitrary passage of non -successional zoning
have broken Miami 21 and opened the floodgates to predatory developers to do the same thing around
the city.
We ask that you to veto this item and uphold the City's own law and protect the quality of life of the
residents in this neighborhood and around your city.
Best regards,
Lourdes M. Delgado
cmneana.me.com
(305) 903-4191
Submitted into the public
record for�Dlq
m(S)
on a1 I City Clerk
From: Jorge luis Negrin <nglsimpleart@icloud.com>
Sent: Wednesday, July 31, 2019 7:44 PM
To: fsuarez@miamigov.com
Subject PZ -9. Veto
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sender and know the content is safe.
Veto the Babylon please.
Sent from my iPhone
Submitted into the public
record for item(s) my ,
on / City Clerk
11 1 1111 1 oil 11111 11 1111 1 m1 1 111111
From: Suarez, Francis (Mayor) <fsuarez@miamigov.com>
Sent: Friday, August 2, 2019 10:14 PM
To: David Eskra
Subject: Re: I support your Veto
Ty David.
Francis Suarez
Mayor
City of Miami
3500 Pan American Drive
Miami, FL 33133
305-250-5300
fsuarez miamigov.com
On Aug 2, 2019, at 9:42 PM, David Eskra <davideskranq,gmail.com> wrote:
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Dear Mr. Mayor,
Just want to say as I resident of Miami (the Roads) I fully support your Veto
of the development at the Babylon Apt building. The proposed project, as
you note, is completely out of character with the neighborhood. Good call.
Sincerely,
David Eskra
I