DRB Appeal - 42 Collins AveGolden Dreams Condominium Association, Inc.
65 Washington Avenue ~ ~,
Miami Beach, Florida 33139 - ~; ~,
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December 2, 2008 r ~ ~'
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City Clerk ~_- .~:
City of Miami Beach °' :~'
1700 Convention Center Drive 4 ~
Miami Beach, Florida 33139
Re: Appeal of Design Review Board decision regarding 42 Collins Avenue,
File no. 21790.
Dear Mr. Clerk:
Please consider this letter to be our appeal of the decision of the Design
Review Board ("DRB") in the above referenced matter. In so appealing we
state as follows:
1. This appeal is being brought in accordance with section 118-
262 of the Citys Land Development Regulations (`LDRs").
2. Golden Dreams Condominium Association, Inc. (the "Golden
Dreams") is an affected person and has standing to file this appeal
because it lies within the mailed notice area for this matter and because a
representative of the Association (and unit owner) provided testimony in
this matter before the DRB.
3. Golden Dreams Condominium is a 24 unit, 2-story, walk-up,
open courtyard type building that lies immediately to the west of 42 Collins
Avenue, directly across an alley.
4. This appeal is being brought based on Golden Dreams being
denied procedural due process and because the DRB did not base its
decision on substantial competent evidence.
5. Golden Dreams is filing this appeal because it did not have
notice of, and had no opportunity to comment on, the emergency standby
generator that is intended to be a part of the 42 Collins Avenue project.
Golden Dreams is concerned about the exhaust gas and noise that will be
generated into the alley that is shared by 42 Collins Avenue and Golden
Dreams.
6. The Golden Dreams building is glazed with jalousie windows
which do not keep noise or significant smells from penetrating the units. At
such time as electrical power in the area may be lost (due to a hurricane,
etc.), the unit owners would be forced to resort to leaving the windows open
for needed ventilation.
7. With a generator running 24 hours a day exhausting both fumes
and noise in a significant-y enclosed alley after an event such as a
hurricane, the residents of Golden Dreams will suffer from the effects of the
noise and fumes without respite.
8. Even under normal circumstances. the generator will likely have
to be "exercised" at least weekly for maintenance purposes--imposing
noise and fumes on Golden Dreams residents at those times.
9. The plans submitted for DRB consideration did not illustrate the
emergency standby generator. At the initial DRB hearing in this matter,
Golden Dreams appeared at the hearing to voice its concerns with the
project. It did not mention the generator because the applicant's submitted
plans did not include a generator. Because Golden Dreams felt that the
board and staff significantly addressed its concerns at the first DRB
meeting, it did not appear at the continuation hearing. The plans submitted
for the continuation hearing did not illustrate or otherwise mention the
generator.
10. But for a DRB board member asking the applicant if there was
to be a generator in the project during board discussion after the public
hearing was closed (during the continuation hearing), and but for a Golden
Dreams unit owner watching the televised hearing, Golden Dreams would
still not be aware that a generator was planned for the project-- a generator
intended to exhaust into the alley adjacent to Golden Dreams
condominium.
11. The generator implicates section 118-251(6) and (11) of the
City's design review criteria.
12. Because the applicant did not illustrate the generator in the
submitted application plans, Golden Dreams was not given notice and an
opportunity to be heard on this issue-- thereby denying Golden Dreams
procedural due process.
13. Because the issue of the generator did not even come up for
discussion until late in the continuation hearing, not even allowing for staff
analysis, and because there was absolutely no evidence in the record
before the DRB that the generator, as intended in the project, would
conform to sections 118-251(6) and (11) of the design review criteria, the
DRB could not have based its decision on substantial competent evidence
regarding this issue.
Because Golden Dreams, an affected person, was denied procedural
due process, and because the DRB did not base its decision based on
substantial competent evidence, Golden Dreams respectfully requests that
the City Commission grant this appeal, and remand this matter back to the
DRB where parties affected by the project's proposed generator may
provide testimony to the DRB and allow the DRB to make its decision
based on substantial competent evidence, including input from the affected
neighbors.
Respectfully,
Golden Dreams Condominium
Association, Inc.
Isabel Fine, President
cc: James Rauh, Esq.