Loading...
2013-28160 Reso RESOLUTION NO. 2013-28160 A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, GRANTING AN APPEAL REQUEST FILED BY W. TUCKER GIBBS, P.A., ON BEHALF OF SUNSET ISLANDS 3 AND 4 PROPERTY OWNERS, INC. AND OLGA LENS, OF THE DESIGN REVIEW BOARD'S ORDER RELATIVE TO DRB FILE NO. 22889 FOR 1201-1237 20TH STREET, PALAU AT SUNSET HARBOR WHEREAS, a process for review by the Mayor and City Commission of decisions rendered by the Design Review Board ("DRB") when requested by an applicant or any affected person has been established under Section 118-262 of the Miami Beach City Code; and WHEREAS, Palau Sunset Harbor, LLC was the applicant for a proposed 5-story, mixed- use development project, which was approved by the Design Review Board on October 2, 2012 and the Order for such approval was rendered on October 8, 2012 (DRB File No. 22889, 1201- 1237 20th Street— Palau at Sunset Harbour); and WHEREAS, a request for a re-hearing of the DRB decision pertaining to File No. 22889, which was requested by MAC SH, LLC, and Sunset Islands 3 and 4 Property Owners, Inc, was denied by the Design Review Board on December 4, 2012 and the Order for such denial was rendered on December 10, 2012; and WHEREAS, W. Tucker Gibbs, P.A., on behalf of Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens, requested a review of the Design Review Board order rendered on October 8, 2012, pertaining to the proposed 5-story, mixed-use development project, (DRB File No. 22889, 1201-1237 20th Street— Palau at Sunset Harbour). WHEREAS, pursuant to Section 118-262, the review by the City Commission is not a "de novo" hearing; it must be based upon the record of the hearing before the Design Review Board. Furthermore, Section 118-262 (b) provides: In order to reverse, or remand for amendment, modification or rehearing any decision of the Design Review Board, the City Commission shall find that the Design Review Board did not do one of the following: 1) provide procedural due process; 2) observe essential requirements of law, or 3) base its decision upon substantial, competent evidence; and WHEREAS, Section 118-262(a) requires the appellants to file with the City Clerk a written transcript of the hearing before the Design Review Board two weeks before the scheduled public hearing on the appeal; the transcript and associated material were transmitted to the Mayor and City Commission via LTC; and WHEREAS, on January 16, 2013, the City Commission set the hearing for this appeal to be held on March 13, 2013, and the City Clerk was directed and did notice such hearing; and WHEREAS, on March 13, 2013 the City Commission heard the parties, and pursuant to the argument given, the written materials submitted, and having been duly advised in the premises determined that the October 2, 2012 decision of the Design Review Board did result in, respectively, 1) a denial of due process and 2) a departure from the essential requirements of law; and WHEREAS, on March 13, 2013 a motion was made by the City Commission to grant the appeal by W. Tucker Gibbs, P.A., on behalf of Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens of the October 2, 2012 decision of the Design Review Board pertaining to DRB File No. 22889; and WHEREAS, the Commission finds that the record of the proceedings below does not reflect whether proper disclosures of ex-parte contacts by DRB board members if any, were made at the October 2, 2012 meeting, as required by City Code section 2-512, and the record does not reflect that adequate discussion and review occurred of the important view corridors associated with this project, as required by Design Review criterion 118-251(a) (12); and WHEREAS, the motion to grant the appeal and remand for further proceedings before the Design Review Board, to allow the Board members to make the appropriate disclosures of ex-parte contacts, if any, as required by City Code section 2-512, and to further discuss and review the important view corridors, as required by Design Review criterion 118-251(a) (12), was made and seconded, and approved by a vote of 6-1. NOW THEREFORE BE IT RESOLVED THAT the Mayor and City Commission hereby grant the appeal filed by W. Tucker Gibbs, P.A., on behalf of Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens and remand the October 2, 2012 decision of the Design Review Board pertaining to DRB File No. 22889 back to the Board for further proceedings consistent with this decision. PASSED and ADOPTED this 13th day of March, 2013. ATTEST: ZIA �P.• "' "' '9 I ERREWA B WER �S YOR RAFA GRANADO, CITY CL INCORP ORATED' APPROVED AS TO �°� FORM & LANGUAGE CH 2e &-F R XECU � _y r e ey Dat Filed with the Clerk of the City Commission on 4/30/13 (byb.Cardillo ). F:\ATTO\HELG\LITIGATION\Palau\Palau Project DRB File No.22889 Appeal-RESO 3-13-2013 FINAL.docx Page 2 of 2 COMMISSION ITEM SUMMARY Condensed Title: A resolution, pursuant to Section 118-262 of the City Code,to review the Design Review Board order relative to DRB File No. 22889, rendered on October 8, 2012, as requested by W. Tucker Gibbs, PA on behalf of Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens, as affected persons. Key Intended Outcome Supported: N/A Item Summa /Recommendation: Pursuant to City Code Section 118-262,W.Tucker Gibbs, PA on behalf of Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens, as affected persons, is requesting that the City Commission review a Design Review Board decision rendered on October 8,2012(DRB File No.22889)pertaining to the approval of a 5- story, mixed-use development project located at 1201-1237 20th Street— Palau at Sunset Harbour. On January 16, 2013, the City Commission set the public hearing for March 13, 2013 to review the order of the Design Review Board pertaining to DRB File No. 22889 (1201-1237 20th Street — Palau at Sunset Harbour). Based upon the issues raised in the petition,the Administration recommends that the City Commission deny the appeal. Advisory Board Recommendation: The Design Review Board approved the subject development project on October 2, 2012, subject to the conditions of the Final Order. Financial Information: Source of Amount Account Funds: 1 2 3 OBPI Total Financial Impact Summary: City Clerk's Office Legislative Tracking: Richard Lorber or William Cary Sign-Offs: Department Director Assistant City Wriager Cit Manager T:\AGENDA\2013\March 13\Palau Project DR F a No.22889 Appeal-SUM 13.docx AGENDA ITEM �7 MIAMIBEACH DATE 3 ® MIAMI BEACH City of Miami Beach, 1700 Convention Center Drive,Miami Beach,Florida 33139,www.miamibeachfl.gov COMMISSION MEMORANDUM TO: Mayor Matti Herrera Bower and Members of the City C mission FROM: Kathie G. Brooks, Interim City Manager/�� DATE: March 13, 2013 PUBLIC HEARING SUBJECT: Palau Appeal A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, [GRANTING OR DENYING] AN APPEAL REQUEST FILED BY W. TUCKER GIBBS, P.A., ON BEHALF OF SUNSET ISLANDS 3 AND 4 PROPERTY OWNERS, INC. AND OLGA LENS, OF THE DESIGN REVIEW BOARD'S ORDER RELATIVE TO DRB FILE NO. 22889 FOR 1201-1237 20TH STREET, PALAU AT SUNSET HARBOR. ADMINISTRATION RECOMMENDATION Based upon the issues raised in the petition, the Administration recommends that the City Commission deny the appeal. BACKGROUND On October 2, 2012, the Design Review Board (DRB) approved DRB File No. 22889, pertaining to a 5-story, mixed-use development project located at 1201-1237 20th Street — Palau at Sunset Harbour. On October 23, 2012 a "Petition for Rehearing" was filed by MAC SH, LLC, and Sunset Islands 3 and 4 Property Owners, Inc. Such re-hearing request was considered by the DRB on December 4, 2012. Following denial of a motion to continue the hearing (which failed due to a tie vote), and denial of a motion to deny the Petition for Rehearing (which failed due to a tie vote), there being no further motions, it was determined by the attorney for the Board that the last decision of the Board stands as the decision of the Board (which was for approval of the application). Pursuant to City Code Section 118-262, W. Tucker Gibbs, P.A., on behalf of Sunset Islands 3 and 4 Property owners, Inc. and Olga Lens, as affected persons, filed a "Request For City Commission Review of the Design Review Board Decision" ("Request") rendered on October 8, 2012 (DRB File No. 22889) pertaining to the approval of Palau project. Section 118-262 of the Miami Beach City Code allows the applicant, the City Manager on behalf of the City Administration, the Miami Design Preservation League, Dade Heritage Trust or an 'Affected Person,' to seek review of any order of the Design Review Board by the City Commission. For purposes of Section 118-262, an "affected person" shall mean either: (i) a person owning property within 375 feet of the applicant's project reviewed by the board, or Commission Memorandum Palau Appeal—Public Hearing March 13, 2013 Page 2 of 4 (ii) a person that appeared before the design review board (directly or represented by counsel), and whose appearance is confirmed in the record of the design review board's public hearing(s)for such project. The Request alleges that the definition of 'affected person' has been satisfied because the named appellants appeared at the hearing before the DRB. (Request para. 4). Pursuant to Section 118-262 of the Miami Beach Code, the review by the City Commission is not a "de novo" hearing, and it must be based upon the record of the hearing before the DRB. Section 118-262(b) states the following: In order to reverse, or remand for amendment, modification or rehearing any decision of the Design Review Board, the City Commission shall find that the Design Review Board did not do one of the following: 1) provide procedural due process, 2) observe essential requirements of law, or 3) base its decision upon substantial, competent evidence. In order to reverse or remand a decision of the DRB, a 5/7th vote of the City Commission is required. ANALYSIS The DRB's review of the subject project was based upon the information and exhibits submitted by the applicant, and the Board had before it the recommendation for approval with proposed conditions presented by its professional staff in the form of a comprehensive staff report, all of which constitute competent, substantial evidence in support of the decision. The Board agreed with the staff recommendation in the report. The Request claims that several issues justify reversal or remand. This is not the case, as all issues raised were discussed and considered by the DRB as outlined below. The Petition raises the following arguments on appeal: 1. DRB members failed to disclose ex parte communications as required by sections 2-511 through 2-513 of the City Code. (at Petition, page 14). 2. Palau failed to meet its initial burden to show that it met DRB review criteria requiring that it created or maintains important view corridors. (at Petition, page 18). 3. The DRB failed to evaluate the elimination and/or diminution of four view corridors as required by section 118-251(a)(12). (at Petition, page 19). 4. The design review staff report fails to address specific criteria requiring a building's massing to create or maintain important view corridors is not competent and substantial evidence of compliance with that review criteria (at Petition, page 21). 5. The DRB improperly delegated to design review staff its authority to evaluate and approve plans pursuant to DRB review criteria (at Petition, page 23). These issues are each discussed below. 1. FAILURE TO DISCLOSE EX-PARTE COMMUNICATIONS AS REQUIRED BY SECTION 2-511 THROUGH 513 OF THE CITY CODE Commission Memorandum Palau Appeal—Public Hearing March 13, 2013 Page 3 of 4 Ex-parte communications were discussed at the August 7, 2012 meeting. At the beginning of the Board discussion, the Board Chairman indicated "We have met, most of us have met with your team to go over the project," Transcript at p. 150, (referring to the Palau development team), and another Board member individually indicated that she had not met with the applicant (see Transcript at p. 170). These statements by Board members satisfied the disclosure requirement in the City Code. If Appellants wanted the "reasonable opportunity to refute or respond to the communication," as provided by Section 2-512(a)(4), they should have taken this opportunity at the hearing. Further, if they thought ex parte contacts had occurred but had not been disclosed, they should have raised this possibility and objected at the hearing. Otherwise, this objection should be considered waived. 2. FAILURE TO MEET ITS INITIAL BURDEN TO SHOW THAT IT MET DRB REVIEW CRITERIA REQUIRING THAT IT CREATED OR MAINTAINS IMPORTANT VIEW CORRIDORS. Appellants assert that "the applicant has the initial burden to show that it has met the DRB approval requirements," and "Palau failed to meet that burden by its failure to address the DRB review criteria and how it met each of those standards." Petition at 18. Palau, however, satisfied the requirement to meet its initial burden by providing the plans that showed which view corridors were provided and to what extent. There is no requirement that a separate document or explanation be provided showing how each design review criteria is satisfied. With respect to view corridors, the plans themselves are evidence of such proof. 3. THE DRB FAILED TO EVALUATE THE ELIMINATION AND/OR DIMUNITION OF FOUR VIEW CORRIDORS PURSUANT TO SECTION 118-251(a)(12). Section 118-251(a)(12) provides: "The proposed structure has an orientation and massing which is sensitive to and compatible with the building site and surrounding area and which creates or maintains important view corridor(s)." First, it is important to understand that not all view corridors are protected. View corridors across or over another person's or entity's property are not always protected. View corridors in setback areas, or along sidewalks are likely protected. Each one is evaluated on its own merits. Views to the water from the adjacent property across the Palau property is not a protected view corridor, and a property owner does not have an inherent right to water views through another owner's property. All relevant view corridors referenced in the Petition were discussed and reviewed by the DRB. The Board, at the August 7, 2012 meeting, did require that the northeast corner of the building be further setback in order to lessen the impact on the historic Sunset Island bridge, this change was made in the plans presented to the Board for the October 2, 2012 meeting, and the change fully satisfied the Board's request. The Board's review and discussion of views in the plans satisfied the design review criterion on this point. 4. THE DESIGN REVIEW STAFF REPORT FAILS TO ADDRESS SPECIFIC CRITERIA REQUIRING A BUILDING'S MASSING TO CREATE OR MAINTAIN IMPORTANT VIEW CORRIDORS IS NOT COMPETENT AND SUBSTANTIAL EVIDENCE OF COMPLIANCE WITH THAT REVIEW CRITERIA. Commission Memorandum Palau Appeal—Public Hearing March 13, 2013 Page 4 of 4 The staff evaluation contained in the staff report is competent substantial evidence. It is fact based, because it is based on a review of the application and its accompanying plans and surveys and accompanying documents, and is based upon field inspections, and thus is competent substantial evidence upon which the DRB can base its decision under Florida law. City of Hialeah Gardens v. Miami-Dade Charter Foundation, Inc., 857 So.2d 202, 204-05 (Fla. 3d DCA 2003) ("the Chief of Police, the Director of Public Works, and the Chief Zoning Official, gave specific fact-based reasons for their recommendations that the application be rejected."); Metropolitan Dade County v. Sportacres Development Group, 698 So.2d 281, 282 (Fla. 3d DCA 1997) ("maps, reports and other information which, in conjunction with the testimony of the neighbors, if believed by the Commission, constituted competent substantial evidence."); Dade County v. United Resources, Inc., 374 So.2d 1046, 1050 (Fla. 3d DCA 1979) ("recommendations of professional staff'); Norwood-Nor/and Homeowner's Assn v. Dade County, 511 So.2d 1009, 1013 (Fla. 3d DCA 1987) ("Dade County Development Impact Committee report"); Metropolitan Dade County v. Fuller, 515 So.2d 1312, 1314 (Fla. 3d DCA 1987) ("staff recommendations"). 5. THE DRB IMPROPERLY DELEGATED TO DESIGN REVIEW STAFF ITS AUTHORITY TO EVALUATE AND APPROVE PLANS PURSUANT TO DRB REVIEW CRITERIA. The inclusion of conditions in the DRB Order that allows staff to make specific decisions on plans to be submitted is not an unlawful delegation of authority. These are minor matters within the scope of staff's authority, including materials, finishes, glazing (windows), railings, architectural projections, landscaping, walkways, fences, facades between buildings, and the compliance of the applicant with a condition imposed to enlarge a plaza and connect to a walkway. The DRB need not involve itself in every minor detail of the design of a proposed development. These matters are included in board orders to emphasize staffs review of them when the project is submitted for building permit. Unlawful delegations arise when insufficient standards are set out for the implementation of delegation by the person to whom authority was delegated. The design review criteria remain the standards against which either the Board at the time of design review approval, or the design review staff at time of building permit, and are sufficient to provide a lawful delegation of authority on these minor points. A review of the transcripts for the DRB hearings indicates that the DRB observed the essential requirements of law, made its determinations based on substantial, competent evidence, and afforded all parties involved due process. Additionally, the Board held public hearings during which members of the public were afforded the opportunity to testify and present evidence. Based upon all of the competent, substantial evidence submitted, the Board determined that the proposed project would meet the Criteria for Design Review Approval in Section 118-252 of the Code, subject to the conditions in the Final Order. CONCLUSION Based upon the issues raised in the petition, the Administration recommends that the City Commission deny the appeal. KGB/JGG/GMH/RGL/TRM T:\AGENDA\2013\March 13\Palau Project DRB File No 22889 Appeal-MEMO 3-13-2013 rev2.docx MIAMI BEACH City Clerks Office MEMORANDUM TO: Mayor Matti Herrera Bower and Members of the City Commission FROM: Rafael E. Granado, City Clerk - DATE: February 27, 2013 SUBJECT: Petition to Reverse Design Review Board (DRB) Decision Relative to File 22889, Palau Sunset Harbor. Attached is the Petition to Reverse Design Review Board Decision regarding Palau Sunset Harbor filed by W. Tucker Gibbs, Esq., attorney for The Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens. In addition, Mr. Gibbs has filed a lengthy Appendix (Volumes I & II), consisting of 352 pages, which has been be placed in your iPad Dropbox and linked to the City's webpage. If you would like a printed copy of the Appendix, please call me at 305.673.7411 or email me at rafaelgranado(cD_miamibeachfl.gov. If additional parties file pleadings on this matter, they will be forwarded to you as well. This item is scheduled to be heard by the City Commission on March 13, 2013, at 5:01 p.m. as item R7A - A Resolution [Granting Or Denying] An Appeal Request Filed By W. Tucker Gibbs, P.A., On Behalf Of Sunset Islands 3 And 4 Property Owners, Inc. And Olga Lens, Of The Design Review Board's Order Relative To DRB File No. 22889 For 1201-1237 20th Street, Palau At Sunset Harbor. REG/Ic F:\CLER\$ALL\LILIA\DRB-Palau.docx We ore cornmilled to providing oxcpUent public service and snfr�h,,to ail who live, work, and ploy in our vibrant, tropical, historic cornnnrnity, BEFORE THE MIAMI BEACH CITY COMMISSION DESIGN REVIEW BOARD FILE 22889 IN RE: PALAU SUNSET HARBOR All of Lots 22, 23, and 24, and the north 70 feet of Lots 25 and 26, Block 15A, Island View Addition According to the Plat Thereof as Recorded in Plat Book 9, Page 144 of the Public Records of Miami- Dade County 1201-1237 20`h Street, Miami Beach, Florida PETITION TO REVERSE DESIGN REVIEW BOARD DECISION The Sunset Islands 3 and 4 Property Owners, Inc. ("Sunset") and Olga Lens ("Lens") (collectively "neighbors"), pursuant to section 118-262, City of Miami Beach Land Development Regulations, requests that the City of Miami Beach City Commission ("commission") at its March 13, 2013 meeting reverse the decision of the Miami Beach Design Review Board ("DRB") to grant the application for design review approval for the Palau Sunset Harbor development (DRB File No. 22889) ("Palau development"), or in the alternative remand the matter back to the DRB with instructions for review consistent with the requests herein. 1 INTRODUCTION Palau Sunset Harbor, LLC, ("Palau" or "applicant") applied for DRB approval for the Palau development, a large mixed use project proposed for property it owns at 1201-1237 20`h Street, Miami Beach. The project would abut a well-established single-family residential neighborhood. The Palau development would not only destroy important view corridors to the water and from 201h Street to the historic Sunset Islands bridge but also block abutting neighbors' views even more than does the Sunset Harbor townhouses immediately to its west. Given the virtually unanimous objection to the project by its residential neighbors, no one was surprised that the Palau application consumed hours of contentious public hearings before the DRB. During the DRB review process not one neighbor spoke in favor of this massive development. Furthermore, the DRB decision-making process included: procedural error, a failure to correctly apply the law and on a key issue a failure to base its decision on competent substantial evidence. At the core of any quasi-judicial body's review of an application is the basic guarantee that the process is fundamentally fair.' DRB members failed ' The city commission's review of this matter pursuant to section 118-262 also fails to provide a party seeking its review with the due process one would expect in a quasi-judicial proceeding. In this process, the party initiates the commission's review by filing the petition (if represented by counsel) and must file "appropriate legal briefs" setting forth argument and facts in support 2 to make required disclosures of meetings with Palau representatives prior to the meetings of August 7 and October 2, 2012. Such ex parte communication is contrary to a fair and impartial quasi-judicial hearing process and a breach of the city's obligation to provide basic procedural due process. The failure of the applicant and design review staff to address compliance with the specific DRB review criteria, and the failure of the order to show compliance with those criteria shows that the DRB did not observe the essential requirements of law when it approved the application. This warrants reversal of the DRB decision. of its case. The petitioner must show that the DRB failed to provide due process, or did not observe the essential requirements of law, or failed to base its decision on competent substantial evidence. This mirrors the process and review standards of an appellate court. But that is where the similarities end. In an appellate proceeding, the petition is followed by a response to the arguments in the petition from the other side and that response brief is followed in many cases by a reply to those arguments. This process insures that all parties (and the court) know and understand all the arguments. This is transparent and open process that is fair and provides all parties procedural due process. Therefore, it leads to few if any surprises to either side. The Miami Beach process guarantees a closed and opaque process and is designed to keep information away from the petitioner. Here, the city and the applicant have all the information regarding the petitioner's arguments. But because there is no reciprocal obligation for the city or applicant to provide a response to the petition, the petitioner has no information regarding the city or applicant's arguments. The city commission is equally in the dark. All of this makes for a process that is skewed toward one side. That is a process that fails to meet the standards of basic fairness in order to afford all parties a fair, open and impartial hearing. In that hearing the "...the opportunity to be heard must be meaningful, full and fair, and not merely colorable or illusive." Rucker v City of Ocala, 684 So. 2d 836, 841 (Fla. 1st DCA 1996). 3 Design review staff's conclusory statements on compliance with required review standards without any stated factual basis are not competent substantial evidence. Therefore, the DRB decision and order regarding the project's compliance with all the review criteria is not based on competent substantial evidence. The DRB has no authority to delegate to city staff any of its duties to evaluate and make final determinations about whether the application meets DRB review criteria. This authority is vested only in the DRB, but that board through its order incorrectly delegated that power to the city's design review staff. These fundamental failures on the part of the DRB warrant the reversal of that board's approval of the Palau application. PARTIES Sunset represents its members who are property owners on both Sunset Island 3 and Sunset Island 4 across the waterway from the proposed Palau development site. Its members include property owners within 375-feet of the site. Lens owns the property at 2000 North Bay Road, across Sunset Drive from and within 375-feet of the proposed Palau development site. 4 Palau owns the property located at 1201-1237 201h Street, Miami Beach, Florida. It applied for and received DRB approval for the Palau development on that site. On August 7, and October 2, 2012, the DRB held a publicly-noticed, quasi-judicial hearing and reviewed the application for design review approval for the Palau development. At that hearing the neighbors individually and through counsel appeared before the Design Review Board. Exhibit N, 68:15-70:1, 93:5-94:5, 71:10-77:11, 182:9-184:11, August 7, 2012 Transcript. Exhibit O, 56:14-59:23, 60:10-70:10, 72:7-76:12, 103:17-104:19, 130:21-146:12, October 2, 2012 Transcript Volume 1. FACTUAL BACKGROUND In late 2011, Palau applied to develop the property abutting the Sunset Islands and its historically-designated entrance. Exhibit A, Aerial map of area. The applicant proposed a bulky, 5-story, 109,279 square-foot (including approximately 13,056 square feet of commercial space) mixed-use development on this CD-2 (Commercial Medium Intensity zoning district)- zoned site. Exhibit B, Planning Board Staff Report, April 24, 2012. The Palau site abuts RS-3 (property on N. Bay Road and Sunset Drive) and RS-4 (Sunset Island 4) single family residential neighborhoods to the east 5 and north and RM-3 multi-family property (Sunset Harbour Townhomes) to the west. Exhibit C, Zoning Map. At the planning board the applicant sought a conditional use approval to allow development exceeding 50,000 square-feet plus the use of mechanical parking lifts, among other things. Exhibit D, Planning Board Staff Report, April 24, 2012. Faced with strong neighborhood opposition, the planning board continued the matter several times. Neighbors sought a project that was less bulky and more in scale with the abutting single-family residential neighborhood. In particular, the neighbors cited the monolithic massing of the building and requested that the board require increased setbacks and more articulation to lessen the impact of the massive structure on its neighbors. Ultimately on May 22, 2012, the planning board approved the conditional use for a modified development with a specific condition relating to Design Review Board approval: "5. The applicant shall work with Design Review Staff to further modify the proposal to address the following, subject to review and approval of the Design Review Board: (a) Pulling back the massing, east of the World Savings Bank property, with emphasis on upper floor setback and the northeast corner of the building and adding more green space. 6 (b) Further modifying the ground floor area along the canal (terraces) to minimize the hardscape and increase the amount of open, landscaped area at grade level. (c) Adding more canopy trees for increased shade to the landscape plan particularly along Sunset Drive. Also work with Sheryl Gold on this item. (d) Removing parking on Sunset Drive. (e) Reducing encroachment on the line of sight from Sunset Island 4. (f) Working with Public Works staff to limit u-turns at the guardhouse." Exhibit D, August 7; 2012 Design Review Board Staff Report. With this directive from the planning board, the applicant made revisions to its plan and submitted it to the Design Review Board. That board held its initial hearing on the application on August 7, 2012. At that hearing the neighbors focused on the zoning code charge to the DRB to examine development plans for consistency with the criteria in section 118-251 regarding aesthetics, safety and function of the structure and the physical attributes of the project in relation to the site, adjacent structures and the surrounding community. According the DRB review criteria, the development must not have a negative impact on adjacent neighborhoods. Under these standards, the developer must eliminate or mitigate aspects of the proposed project that adversely affect the surrounding area. 7 Neighbors presented expert testimony addressing the impacts of the project on the adjacent properties. Their expert and the city's design review staff found that the project failed to meet eight of the fifteen applicable standards. Exhibit E Alvarez Power Point Presentation, and Exhibit D, August 7, Design Review Board staff report). Neighbors also submitted a transcript of the expert testimony of University of Miami Professor of Architecture Francois Le Jeune at the May 22, 2012 Planning Board hearing on Palau's conditional use application. Professor Le Jeune stated that the project should be redesigned to reduce its mass and scale and maintain the view corridor from West Avenue toward the water and Sunset Island 4. Exhibit F, Excerpt of Francois Le Jeune Testimony, May 22, Planning Board hearing. In their discussion of the DRB's neighborhood compatibility criteria the neighbors addressed the Palau project's impacts on the historic Sunset Islands neighborhood and the historic Sunset Island Bridge. In particular, the neighbors cited the 1996 Historic Designation Report. The report discussed the importance of"sensitive new construction" in the context of the neighborhood's character, which is defined by the elements of scale, proportion, massing, materials and details. Exhibit G Designation Report, 21. The report also examined "compatibility with the character of the Historic Sunset Islands Neighborhood," which positively influences proportion and 8 scale, massing and materials. Id., 22. In particular, the report noted: "When there is a combination of structural building types surrounding a project site, scale and proportion of the buildings closest to the proposed construction should be observed." Id. The DRB voted to continue the item to its October 2 meeting based on the staff recommendation for a continuance so that the applicant could address staff's concerns about the proposal. Prior to the October 2, 2012, DRB hearing, planning department staff had asked neighbor representatives to provide it with their concerns and how those concerns could be resolved. The neighbors submitted a proposed resolution approving the application with conditions. The proposed resolution set forth specific findings and the following conditions for approval: a. The entire length of the building abutting and east of the World Savings Bank property shall be set back an additional 15 feet. b. The entire length of the fifth floor of the northern side of the building facing Sunset Island No. 4 shall be set back an additional ten feet. c. The entire length of the eastern portion of the building along Sunset Drive shall be stepped back as follows: i. First floor an additional ten feet (current proposed setback plus ten feet); 9 ii. Second and third floors an additional five feet (current proposed setback plus 15 feet); iii. Fourth and fifth floors an additional five feet (current proposed setback plus 20 feet). Exhibit H, Sunset Islands 3 &4 Proposed Resolution, October 2012. Design review staff included the proposed resolution as an attachment to the October 2, 2012 staff report, noting that the neighboring residents continue to have serious concerns with the application. Exhibit I, 7, Staff Report, Design Review Board, October 2, 2012. In its analysis staff discussed one proposed finding regarding the comparison of the Palau project with the Sunset Harbor Townhomes development to its west but failed to address the other findings and conditions, including those relating to the Sunset Drive view corridor and the proposed setbacks. Id. The applicant presented its revised plans to the DRB at the October 2, 2012 hearing. Design review staff determined that these plans adequately responded to their concerns and recommended approval of the application. Notwithstanding the staff's position, the neighbors addressed the failure of the application to adequately address three of the DRB review criteria that focus on neighborhood compatibility: a. Criteria 6 requires that the proposed structures must be compatible with adjacent structures and enhance the appearance 10 of surrounding properties. Yet neither the applicant nor the design review staff explained how this massive project is compatible with the abutting single-family properties and in what way it "enhanced" the appearance of these properties. b. Criteria 7 states that the site plan layout must show efficient arrangement of land uses, especially the relationship with the surrounding neighborhood, impacts on adjacent buildings and lands, pedestrian sight lines and view corridors. But the plan for the project shows that existing site lines and view corridors are degraded or eliminated. The applicant did not address how it met this criterion. Design review staff also did not discuss or address and how the revised plans met this criterion in their written report2 or in their presentation. c. Criteria 12 says that the massing and orientation of structures must be sensitive to and compatible with the surrounding area and also create or maintain important view corridors. However, the massing and placement of the building fails to "create or maintain" important view corridors as it degrades the view corridor along Sunset Drive from 20`h Street to the historic entrance to Sunset Islands 3 and 4. Neighbors proposed a simple solution that would meet the three criteria at issue: Step back the proposed building along Sunset Drive an additional ten feet at the ground floor, an additional five feet on the second and third floors 2 The staff report merely stated that the criterion is "satisfied". Exhibit I, 3. 11 i and an additional five feet on the fourth and fifth floors. Exhibit H, 2, Proposed Resolution. On October 8, 2012, the board rendered its order granting design review approval to the Palau pursuant to design review criteria set forth in section 118-251 of the Miami Beach Land Development Regulations and subject to conditions set forth therein. On October 23, 2012, Sunset and another entity petitioned the DRB to rehear the matter pursuant to section 118-261. On December 4, 2012, with only four of the seven members present, the DRB considered the petition for rehearing: a. The DRB considered and denied a motion to continue the hearing by a 2-2 tie vote. b. Without hearing argument or testimony and without any presentation of evidence the DRB considered and denied a motion to deny the petition for rehearing by a 2-2 tie vote. c. There were no further motions. Therefore, the DRB counsel interpreted the DRB rules to determine that the last decision of the DRB shall stand and the request for rehearing be denied even though there was not a majority vote for such denial of the rehearing. The DRB Order denying the rehearing was rendered on December 10, 2012, and Neighbors filed their request for city commission review of the 12 DRB decision pursuant to section 118-262. The city commission subsequently set the request for hearing on its March 13, 2013 agenda. STANDARD OF REVIEW This city commission's standard of review requires a determination of whether (1) the proceedings before the DRB afforded procedural due process; (2) the DRB observed the essential requirements of the law; and (3) the DRB's decision was supported by competent substantial evidence. Sec. 118- 262(b), Miami Beach Land Development Regulations. ARGUMENT The DRB consideration of this matter was characterized by procedural errors. Its order fails to show that it correctly applied the DRB criteria and that its decision was supported by competent substantial evidence: a. The failure to disclose ex parte communications pursuant to sections 2-511 through 513 of the Miami Beach Code of Ordinances is a failure to provide procedural due process and a failure of the DRB to observe the essential requirements of law in its evaluation of the Palau development application. 13 b. The applicant failed to meet its initial burden.to show that it met the DRB review standards, warranting reversal of the DRB approval. c. The failure of the DRB to evaluate the elimination and/or diminution of four view corridors pursuant to section 118-251(a) (12), is a failure to observe the essential requirements of law. d. A staff report and presentation, which failed to examine or address the specific requirement for "the proposed structure" to have "an orientation and massing... which creates or maintains important view corridors" is not competent substantial evidence of compliance with that review criteria. e. The DRB improperly delegated to design review staff its authority to evaluate and approve plans as meeting DRB review criteria. DRB Members Failed to Disclose Ex Parte Communications as Required by Sections 2-511 through 2-513 of the City Code Section 2-511 defines a prohibited ex parte communication as any written or oral communication with any member [of a city quasi-judicial board], which may directly or indirectly influence the disposition of an application, other than those made on the record during a public hearing. Section 2-512(a) establishes a procedure "for all ex parte communication" with a board member of a quasi-judicial board, such as the Design Review Board. Section 2-512(a)(1) requires that "[t]he subject matter 14 of any ex parte communication, together with the identity of the person, group or entity with whom the communication took place, shall be disclosed and made a part of the record on file with the city prior to final action on the matter." Section 2-512(a)(4) requires that "[a]ny ex parte communication or activity regarding a pending quasi-judicial matter and not physically made a part of the record on file with the city and available for public inspection prior to the public meeting on the matter shall be orally stated and disclosed on the record at the public meeting prior to the vote on the matter ..." Based on information and belief, prior to the Design Review Board's hearings on the Palau matter (August 7, and October 2, 2012) representatives of the applicant Palau Sunset Harbor, LLC, met with and communicated with a member or members of the Design Review Board regarding the disposition of the Palau application. Design review staff acknowledges that such communication did indeed take place. And staff states that such meetings were disclosed by the chairman who stated at the August 7, 2012 meeting: "We have met -- most of us have met with your team to go over the project. We have heard everything everybody has to say here." Exhibit N, Transcript 150:14-19. 15 According to design review staff this general statement by the chair is a disclosure for all DRB members (despite lack of any legal authority for the chairman to speak for DRB members on their ex parte communications) and meets the code's requirement for "[t]he subject matter of any ex parte communication, together with the identity of the person, group or entity with whom the communication took place, shall be disclosed and made a part of the record." Exhibit L, 3, Staff Report, Design Review Board, December 4, 2012. This is a fundamental misreading of the code and law in that it assumes that the chairman has knowledge of each DRB member' ex parte communications. The chairman as a matter of law cannot speak for the members of the DRB regarding their ex parte communications. Such knowledge only can be gained either through ex parte discussions, discussions with staff, or discussions with fellow DRB members. Therefore, this staff interpretation itself is an admission by the chair of a violation of the "Sunshine Law," which prohibits communication between two or more DRB members (including through third parties) on issues related to official DRB business. Section 286.011, Fla. Stats. 3 Palau accepts staff's interpretation that the chairman's statement is an accurate disclosure of the board members' ex parte communications. Exhibit M, 5, Palau Response to Petition for Rehearing. 16 Astoundingly, Palau erroneously claims that the incorporation of the August 7, hearing record at the October 2, 2012 DRB hearing applies to the disclosure of ex parte communications made after that August 7 meeting. This mocks any idea that this quasi-judicial process was fundamentally fair and that neighbors and other participants in this process had adequate notice of these post August 7 communications. At best, the chairman's "disclosure" is limited to himself. At worst it is a violation of the Sunshine Law. In either event the chairman failed to disclose the subject matter of this communication, or the identity of the person, group or entity with which the communication took place. And no other board member made these required disclosures. According to section 2-512(b) without such disclosure a presumption of prejudice arising from that/those ex parte communication(s) remains attached to that communication. These non-disclosed ex parte communications and the attached presumption of prejudice effectively impacted the neighbors' ability to obtain a fair hearing and denied them procedural due process. Furthermore, this direct violation of the city code and state law (if you accept staff's and Palau's position that the chairman spoke for the entire board when he made his "disclosure" statement) is a failure of the DRB to observe the essential requirements of law. (See also: Jennings v. Dade Cotcnty, 589 So.2d 1337, 17 1339 (Fla. 3d DCA 1991). "Upon proof that a quasi-judicial officer received an ex parte contact, a presumption arises... that the contact was prejudicial. The aggrieved party will be entitled to a new and complete hearing before the commission [here, the DRB] unless the defendant proves that the communication was not prejudicial."). Palau Failed to Meet Its Initial Burden to Show That It Met DRB Review Criteria Requiring That it Created or Maintains Important View Corridors In the DRB review of the development proposal, the applicant has the initial burden to show that it has met the DRB approval requirements. Irvine v. DLCval Cozcnty Planning Commission, 495 So.2d 167 (Fla.1986). These requirements are set out in sections 118-251 through 264 of the Miami Beach Land Development Regulations. However, Palau failed to meet that burden by its failure to address the DRB review criteria and how it met each of those standards. In particular, the applicant did not present any evidence that it complied with Section 118-251(a) (12). That criteria requires a showing that the orientation and massing of the proposed structure is (among other things) compatible with the surrounding area and that it "creates or maintains important view corridors." In its presentation the applicant failed to show that it complied with this requirement. 18 That failure warrants reversal of the DRB's approval of the application. The DRB Failed to Evaluate the Elimination and/or Diminution of Four View Corridors as Required by Section 118-251(A) (12) Section 118-251(a) requires the DRB to include the examination of architectural drawings for consistency with specific criteria with regard to the aesthetics, appearances, safety, and function of the proposed structure "and physical attributes of the project in relation to the site, adjacent structures and surrounding community." Section 118-251(a) (12) states: "The proposed structure has an orientation and massing which is sensitive to and compatible with the building site and surrounding area and which creates or maintains important view corridor(s)." Emphasis added. There is no indication in the record (including the transcripts or staff recommendations) or the final order of the Design Review Board to show that the proposed Palau development has an orientation and massing that "creates or maintains" important view corridors. The orientation and massing of the Palau building eliminates four existing view corridors: (1) the West Avenue view corridor to the waterway that extends between the World Bank property and the Sunset Harbor Townhomes; (2) the view corridor to the waterway that extends between the 19 World Savings building and the existing incomplete structure to its east; (3) the view corridor to the waterway that extends between the existing incomplete structure and the Mark's Cleaners building to the east; and (4) the view corridor along Sunset Drive, from 20`h Street to the historic Sunset Islands Bridge. Furthermore, the orientation and massing of the proposed Palau building diminishes the existing view corridor along Sunset Drive, from 20`h Street to the historic Sunset Islands Bridge. The failure of the board to apply correctly section 118-251(a) (12), which requires the orientation and massing of the structures to "create or maintain important view corridors," is a failure to observe the essential requirements of law. Both design review staff and Palau state that the DRB considered "view corridors" and required "that the northeast corner of the building be further setback in order to lessen the impact on the historic Sunset Island bridge." According to staff and Palau this change "fully satisfied the Board's request." Exhibit L, 2 December 4, 2012 Design Review Board Staff Report. But this DRB request was never characterized as preserving an important view corridor. It was a response to the building's impact on the historic bridge 20 itself, not the view corridor along Sunset Drive from 201h Street to the historic bridge. In fact, there is no reference in the testimony presented by the staff or the developer at the October 2, 2012 hearing connecting this chan ge in the plans to the creation or maintaining of important view corridors. There is no mention of the Sunset Drive view corridor by the staff or Palau representatives at either the August 7, or October 2, 2012 DRB hearings. The Design Review Staff Report Fails to Address Specific Criteria Requiring a Building's Massing to "Create or Maintain Important View Corridors" and is Not Competent and Substantial Evidence of Compliance With That Review Criteria. Competent substantial evidence is defined as that evidence relied upon to sustain the ultimate finding that is "sufficiently relevant and material that a reasonable mind would accept it as adequate to support the conclusion reached." De Groot v. Sheffield, 95 So.2d 912, 916 (Fla. 1957). Competent substantial evidence is not opinion unsubstantiated by facts. City of Apopka v. Orange County, 299 So.2d 657, 660 (Fla. 4th DCA 1974). The failure of the applicant and city staff to present evidence to the board that the Palau development meets the specific requirements of section 118-251(a) (12) -- that the orientation and massing of the structures creates or maintains important view corridors -- is a failure to present competent 21 substantial evidence to the DRB to support its decision that the Palau development is consistent with that standard. The October 2, 2012 staff report's statement that criteria 12 was "satisfied" is not competent substantial evidence of that assertion because it is opinion with no stated factual basis. Any claim of deference to design review staff's interpretation of the design review criteria fails where the staff has not even addressed a key component of the criteria at issue. Note that the staff report of October 2 only states that the criteria is "satisfied." There is no reference or mention of"view corridor" in the staff report despite the clear language of the provision requiring that the building create or maintain important view corridors. Deference to the staff's interpretation is not unlimited, and the city commission's role is not unquestioning. This is especially true where there is no mention of"view corridor" in the context of this criterion in the staff report or in the transcripts of the DRB hearings. Furthermore, any deference claimed by staff or Palau is overcome by a showing that there has been a departure from the essential requirements of law. Bell South Telecommunications v. Johnson, 708 So.2d 594, 597 (Fla. 1998). Here the DRB failed to apply the correct law by failing to apply each of the elements of criteria 12 -- in particular the requirement to create or 22 maintain important view corridors. When the agency's construction clearly contradicts the unambiguous language of a rule, the construction is clearly erroneous and cannot stand. Woodley v. Department of Health and Rehabilitative Services, 505 So.2d 676,678 (Fla. ls` DCA 1987). See also, Legal Environmental Assistance Foundation, Inc. v. Board of County Commissioners of Brevard County, 642 So.2d 1081, 1083-1084 (Fla. 1994). The DRB Improperly Delegated to Design Review Staff Its Authority to Evaluate and Approve Plans Pursuant to DRB Review Criteria. The city commission has delegated certain authority to the DRB to approve design review applications subject to specific criteria set forth in section 118-251. This authority, spelled out in sections 118-251 through 265, does not allow the DRB to delegate to design review staff its responsibility and duty to make decisions based on those criteria. 4 Yet that is what the DRB did when it approved the Palau development. According to the final order of the DRB, it approved the project subject to conditions, including: 4 While section 118-260 authorizes the planning director to approve, approve with conditions or deny an application for eight specific issues all associated with minor public improvements, and rehabilitation, alterations and demolition of structures or portions of structures, it does not authorize the DRB to delegate its authority to approve an application (or any portion of an application) for new development such as the Palau project. 23 a. The final design and details, including materials, finishes, glazing, railings, and any architectural projections and features, shall be provided in a manner to be reviewed and approved by staff. Emphasis added. Exhibit I, 2, October 2, 2012 Design Review Board Staff Report. b. The final design and details, including landscaping, walkways, fences, and architectural treatment of west elevation facing the former bank building shall be provided, in a manner to be reviewed and approved by staff. Emphasis added. Exhibit I, 2, October 2, 2012 Design Review Board Staff Report. c. The plaza at the northeast corner of the site shall be further studied and enlarged to improve its visibility and functionality, and shall be added to the waterfront walkway easement for public access, subject to the review and approval of staff. Emphasis added. Exhibit I, 3, October 2, 2012 Design Review Board Staff Report.. While there is authority for the DRB to prescribe conditions of approval, there is no authority for the DRB to delegate its review and approval authority for new development to staff. Section 118-264, Land Development Regulations. Each of these conditions transforms design review decisions into staff-level determinations, without any authority in the land development regulations. Florida law provides that a legislature may not delegate the power to 24 i make law or the right to "exercise unrestricted discretion in applying the law." Sims v. State, 754 So.2d 657, 668 (2000). The DRB, without any legislative authority, gave staff the power to approve plans as a condition of DRB approval. That power is reserved to the DRB and cannot be delegated absent specific legislative authority. There is no such authority in the city code. Therefore, the DRB order is invalid because the DRB review is incomplete. Any changes to the plans must be approved by the DRB and not staff. While staff may review these plans and make recommendations, it is the DRB that has the sole authority to approve new development for compliance with the design criteria. This final DRB review has not occurred. For this reason, this order must be quashed. CONCLUSION The neighbors request the city commission to (a) review the decision of the DRB and (b) reverse or in the alternative, remand this matter to the DRB with instructions that the DRB require additional setbacks along Sunset Drive as set forth herein . 25 Furthermore, neighbors seek a waiver and refund of the filing fees for the rehearing and appeal, both of which would not have been necessary, had the DRB process been proper to afford them a full and fair hearing. Respectfully Submitted, W. TUCKER GIBBS, ESQ. Attorney for Neighbors P.O. Box 1050 Coconut Grove, Florida 33133 Tel (305) 448-8486 Fax (305) 448-0773 Email: tucker @wtgibbs.com W. TUCKER WBBS 26 RESOLUTION NO. A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, [GRANTING OR DENYING] AN APPEAL REQUEST FILED BY W. TUCKER GIBBS, P.A., ON BEHALF OF SUNSET ISLANDS 3 AND 4 PROPERTY OWNERS, INC. AND OLGA LENS, OF THE DESIGN REVIEW BOARD'S ORDER RELATIVE TO DRB FILE NO. 22889 FOR 1201-1237 20TH STREET, PALAU AT SUNSET HARBOR WHEREAS, a process for review by the Mayor and City Commission of decisions rendered by the Design Review Board when requested by an applicant or any affected person has been established under Section 118-262 of the Miami Beach City Code; and WHEREAS, Palau Sunset Harbor, LLC was the applicant for a proposed 5-story, mixed- use development project, which was approved by the Design Review Board on October 2, 2012 and the Order for such approval was rendered on October 8, 2012 (DRB File No. 22889, 1201- 1237 201h Street— Palau at Sunset Harbour); and WHEREAS, a request for a re-hearing of the DRB decision pertaining to File No. 22889, which was requested by MAC SH, LLC, and Sunset Islands 3 and 4 Property Owners, Inc, was denied by the Design Review Board on December 4, 2012 and the Order for such denial was rendered on December 10, 2012; and WHEREAS, W. Tucker Gibbs, P.A., on behalf of Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens, has requested a review of the Design Review Board order rendered on October 8, 2012, pertaining to the proposed 5-story, mixed-use development project, (DRB File No. 22889, 1201-1237 20th Street— Palau at Sunset Harbour). WHEREAS, pursuant to Section 118-262, the review by the City Commission is not a "de novo" hearing; it must be based upon the record of the hearing before the Design Review Board. Furthermore, Section 118-262 (b) provides: In order to reverse, or remand for amendment, modification or rehearing any decision of the Design Review Board, the City Commission shall find that the Design Review Board did not do one of the following: 1)provide procedural due process; 2)observe essential requirements of law, or 3)base its decision upon substantial, competent evidence; and WHEREAS, Section 118-262(a) requires the appellants to file with the City Clerk a written transcript of the hearing before the Design Review Board two weeks before the scheduled public hearing on the appeal; the transcript and associated material were transmitted to the Mayor and City Commission via LTC; and WHEREAS, on January 16, 2013, the City Commission set the hearing for this appeal to be held on March 13, 2013, and the City Clerk was directed and did notice such hearing; and WHEREAS, on March 13, 2013 the City Commission heard the parties, and pursuant to the argument given, the written materials submitted, and having been duly advised in the premises determined that the October 2, 2012 decision of the Design Review Board [did or did not] result in, respectively, 1) a denial of due process, 2) a departure from the essential requirements of law, nor 3) a decision that was not based upon substantial, competent evidence; and WHEREAS, on March 13, 2013 a motion was made by the City Commission to [grant or deny] the appeal by W. Tucker Gibbs, P.A., on behalf of Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens of the October 2, 2012 decision of the Design Review Board pertaining to DRB File No. 22889; and WHEREAS, the motion to [affirm or reverse] the decision of the Design Review Board was made and seconded, and approved by a vote of NOW THEREFORE BE IT RESOLVED THAT the Mayor and City Commission hereby [grant or deny] the appeal filed by W. Tucker Gibbs, P.A., on behalf of Sunset Islands 3 and 4 Property Owners, Inc. and Olga Lens and [reverse or affirm] the October 2, 2012 decision of the Design Review Board pertaining to DRB File No. 22889. PASSED and ADOPTED this day of March, 2013. ATTEST: MATTI HERRERA BOWER MAYOR RAFAEL GRANADO, CITY CLERK APPROVED AS TO & LA AGE & FO EX CUT ON 2 25;113 rney to T:\AGENDA\2013WIarch 13\Palau Project DRB File No.22889 Appeal-RESO 3-13-2013.docx THE MIAMI HERALD I MiamiHeraldtom NE THURSDAY,FEBRUARY 7,2013 1 5ME MIAMI BEACH CITY OF MIAMI-BEACH NOTICE OF PUBLIC HEARING. NOTICE IS HEREBY given that a public hearing will be held by the Mayor and City Commission of the- City of Miami Beach, Florida, in the-Commission Chambers, 3rd floor, City Hall, 1700 Convention Center Drive, Miami Beach, Florida,-.on Wednesday, March-13, 2013, at 5:01 p^ Pursuant To Section 118-262 Of The City Code, For An Appeal Filed By W.Tucker Gibbs, P.A., On Behalf Of Sunset Islands 3 And 4 Property Owners, Inc. And.Olga Lens, Of The Design Review Board's Order Relative To DRB File'No.22889 For 1201-1237 20th Street,Palau At Sunset Harbor Inquiries may be directed to the Planning Department at(305)673-7550. Parties to the appeal.are invited to appear at this hearing, or be represented by an agent, or to express their views in writing addressed.to the City Commission,c/o the City Clerk, 1700 Convention Center Drive, 1 st Floor,City Hall, Miami Beach,Florida 33139.The review shall be based on the record of the hearing before the Design Review Board, shall not be a de novo hearing, and no new, additional testimony shall be taken.This hearing may be opened and continued and under such circumstances-additional legal notice would not be provided. Rafael E.Granado,City Clerk . City of Miami Beach Pursuant to Section 286.0105, Fla. Stat., the City hereby advises the public t6ai:'if a person decides to appeal any decision made by the City Commission with respect to any.matter considered at its meeting or its hearing,such.person must ensure that a verbatim record of the proceedings is made, which record includes the testimony and evidence upon which the appeal is to be based. This notice does not constitute consent by the City for the introduction or admission of otherwise inadmissible or irrelevant evidence, nor does it authorize challenges or appeals not otherwise allowed by law. To request this material in accessible format, sign language interpreters, information on access for persons with disabilities, and/or any accommodation to review any document or-participate in any City-sponsored proceeding, please contact us five days in advance at (305) 673-7411(voice) or TTY users may-also call the Florida Relay Service'at 711. Ad#763 THIS PAGE INTENTIONALLY LEFT BLANK