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LTC 303-2022 Favorable Ruling in Appeal of HPB Approval of Delano Hotel Project In Re 1685 Collins Avenue (the Delano)303-2022 /\Al/i/\/\1 CH OFFICE OF THE C ITY ATTORNEY LTC No. ______ _ LETTER TO COMMISSION TO: Mayor Dan Gelber and Members of the City Commission FROM: Rafael A. Paz , City Attorney ~ DATE: July 26 , 2022 SUBJECT: Favorable Ruling in Appeal of HPB Approval of Delano Hotel Project In Re: 1685 Collins Avenue (the "Delano") The purpose of this L TC is to advise you of the City's recent victory in an appeal from the Historic Preservation Board 's approval of a Certificate of Appropriateness for the Delano. I am pleased to inform you that Special Magistrate Craig Coller affirmed the HPB's approval of the Delano renovation project in the case of In re : 1685 Collins Avenue, Miami Beach, Florida. With its prominent location in the Collins Avenue hotel corridor , the Delano is a crown jewel of Art Deco architecture and an important part of Miami Beach history . The building , designed by architect B. Robert Swartburg , was substantially redesigned by architect Philippe Stark in 1994. On February 24 , 2022 , the HPB approved a Certificate of Appropriateness for the applicant's contemporary reinterpretation of the original design , honoring and reviving original architectural aspects while also upgrading the property to comply with the Americans with Disabilities Act. Two neighboring hotels appealed the HPB's decision , seeking to delay the renovation by arguing that the HPB failed to comply with the City Code's procedural and zoning requirements . After considering the parties' briefs and arguments, Special Magistrate Coller ruled that all of the objectors ' arguments were waived and/or lacked merit. The City's case was litigated entirely in -house by Deputy City Attorney Nick Kallergis , First Assistant City Attorney Henry Hunnefeld , and Senior Assistant City Attorney Freddi Mack , with Freddi Mack presenting the argument on behalf of the Historic Preservation Board . A copy of the Special Magistrate's 30-page Order is attached . Feel free to contact me or Chief Deputy City Attorn ey Robert Rosenwald for f urther information about this or any City litigation matter. BEFORE THE SPECIAL MAGISTRATE FOR THE HISTORIC PRESERVATION BOARD IN RE: 1685 COLLINS AVENUE MIAMI BEACH, FLORIDA ORDER CASE NO. SM 2022-003 HPB FILE NO. 17-0176 This Order addresses the appeal taken by FBJ Sagamore, LLC's ("Sagamore") and Di Lido Beach Hotel Corporation's ("Ritz") (collectively, "Appellants") from the order of the Historic Preservation Board (Board), dated February 24, 2022, approving Appellee/Applicant Beach Hotel Associates LLC's ("Applicant," or "Appellee") application for a Certificate of Appropriateness with conditions. The Project The subject property located at 1685 Collins Avenue is improved with a contributing building formally known as the "Delano Hotel" ("Property" or "Hotel). The original design by Architect B. Robert Swartburg in 1948 had been substantially redesigned by Architect Philippe Stark in 1994. The Applicant sought approval for "a contemporary reinterpretation of 1 the original design which honors and revives original aspects such as the recreation of the dining room in the back of the first floor of the mezzanine" and with a scope "including the reconstruction of original floor plates, modification to the rear cabana building and site improvements." Vol. 1 at A. 00011, A.000062-661 ("Project"}. As a contributing historic property within the Ocean Drive/Collins Avenue Historic District, the proposed modifications required the approval of a Certificate of Appropriateness. In general, Applicant's proposed plan seeks to: restore some of the Hotel's classic elements including original interior floor plates and octagonal columns, activate a fourth-level roof into a usable terrace; improve landscaping to enhance the view from a pedestrian's perspective; and upgrade the property to comply with American Disability Act requirements. As is typical with many projects subject to public hearing, the Applicant's first letter of intent and initial plans submitted in October of 2021, (Vol. 1 at A.000050-61; Vol. 2 at A.000194-320} were subsequently revised in December of that year. Vol. 1 at A.000062-66; A.000326-482. Indeed, the initial submission contained request for variances related to proposed ADA ramps and variances related to dune preservation overlay, oceanfront 1 The Special Magistrate, unless otherwise indicated, will use the references provided in Appellants' appendix. 2 bulkhead setback, open space, and view corridor in the rear yard of the property. Vol. 1 at A.00053-57. The Applicant in its revised application was able to avoid such variances. It is the revision submitted in December of 2022 that is subject of this review, the initial submission being wholly irrelevant. Also, very typical of projects subject to public hearing, this property's proposed site plan contains hashed out areas, that while v isible, are clearly intended to show no changes to the exist ing property. Department Recommendation As noted in its report, "[S]taff recommends the application be approved subject to the conditions enumerated in the attached draft Order, which address the inconsistencies w ith the aforementioned Certificate of Appropriateness criter ia. [Emphasis original]" Vol. 1 A. 000019. The proposed modifications were addressed in Staff's report. 2 Regarding the front yard and porch modifications, Staff was in support of a new driveway configuration including a reduction in paving and a narrowing of curb cuts. The Staff was also in support of the proposed landscaping noting that, "[t]he dense hedges are proposed to be removed and replaced with low landscape materials. These modifications are a welcome improvement over 2 Staff's recommendation and its conditions for approval are consistent with its findings regarding required review criteria. Id. at p. A.000012-000017. 3 current conditions and will open views to the historic front fa9ade and will enhance the porch area and will enhance the pedestrian experience along this portion of Collins Avenue." Id. at 000018. Staff noted that within the front porch area, the existing terrazzo steps and porch floor are proposed to be retained and restored. Also, ramps are proposed to connect Collins Avenue to the front stair landing up to the porch level, and from the left side of the porch area to the lobby level. An additional ramp to maintain the original symmetric design is planned on the right side. These ramps will be finished in terrazzo to match the existing area. Id. The Staff had no objection to modifying existing windows in the front fa9ade to convert them to doors next to existing doors. Staff observed that the proposal to change the front planter to a water feature would be a change from the original design. Accordingly, as a condition of approval , Staff required that the shape of the planter would be maintained. Id. Indeed, Staff's condition appears as part of the Board's final order. Section I C. 1.c. Id at p.000002. Regarding the lobby and mezzanine modifications, the Applicant is proposing to renovate and partially restore the existing lobby compatible with the existing architecture including the restoration of the octagon columns, which had been mostly obscured by the Phillipe Stark reconstruction in 1994. Staff did have concerns regarding the terrazzo flooring to determine if the 4 existing floor underneath the wood floors introduced by Stark could be restored. Staff required that if the terrazzo floor was beyond repair that a new terrazzo floor match the existing. Id. at p. 000018-19. The Staff's condition appears as part of the Board's order at Section I. C. 1. d. Id. at p.000002. The Staff recommendation observed that the most "notable" modification was the reintroduction of the original mezzanine bridge that had been demolished in Stark's 1994 renovation . Staff cited to a recent Miami Beach code amendment that allowed the Board to approve such a restoration even if the site is nonconforming as to floor area ratio (FAR). With respect to this aspect of the development, the recommendation provides: "Staff is extremely supported of reintroduction of the mezzanine bridge and that the Board approve the reintroduction introduction of this original floor plate." Id. at p.000019. As to the proposed renovations of the rear dining room and 4th floor terrace, Staff indicated that the Stark 1994 renovation removed the angled portion of the dining room at the ground level except for the wall parallel to 18th Street. Applicant's proposal is to reconstruct portions of the original exterior wall and the roof to expand the outdoor covered dining area. The recommendation provides: "Staff is supportive of the reintroduction of this area as it will contribute to the better understanding of the original design . The roof 5 of the expanded dining area will connect to the existing 4th level roof terrace and is proposed to contain a shallow pool and, cabanas and dining area." Id. Staff also addressed the modifications of the 2-story rear cabana structure and rear yard, which included, among other things, replacement of doors and windows, the extension of a 4-foot wall to hide mechanical equipment, hardscape and landscape improvements, and several outdoor bar counters. Staff indicated, that "it had no significant concerns with the modification proposed and believes that the overall design is appropriate for casual beachfront dining.'' Id. However, Staff did raise a concern that the "cabanas located along the south property line do not appear to comply with required setbacks." Id. The Board's order contained a specific condition that addressed this issue. Under Section I. C.1.h. the order states: "Cabanas and associated paving shall comply with required minimum setbacks." Id at p.000002 Also, certain catch all provisions of the order address the entire development regarding any inconsistencies with the City of Miami Beach Code, includ i ng Section I. C.1.g. that requires consistency with the Dune Preservation Overly District for all proposed improvements, and Section Ill. K. that provides, "Nothing in this order authorizes violation of the City Code or other applicable la'-'¥, nor allows a relaxation of any requirement or standard 6 set forth in the City Code." Id. at p. 000002, 000005. Finally, is this provision in the order, "The issuance of approval does not relieve the applicant from obtaining all other required Municipal, County and/or State reviews or permits, including final zoning approval." Id. at p. 000005 Staff concluded its analysis of the Project as follows: "Staff has no objection to the modifications proposed as they will not have an adverse impact on the Contributing building and do not require the demolition of any significant architectural features. In summary staff is supportive of the proposed project as noted below." Id. at p.000019. Hearing before the Board Notice and the Exclusion requirement of Late Filed Objections An extensive hearing was held before the Board on February 8, 2022. Transcript pp. 1-583 . That hearing was noticed by mail on January 6, 2022. Appellee City of Miami Beach ("City") Appendix p. SA001. That notice in pertinent part provides: "Members of the public wishing to submit audio visual materials are requested to submit such materials via email as an attachment to planningaudiovisual@miamibeachfl.gov no less than three days prior to the 3 The transcript is included in Volume 3 of Appellants' appendix and references will simply refer to the transcript page number rather than Appellants' Volume and numbering. 7 meeting." [Emphasis supplied] Id. Similar language appears in the advertisement of the meeting that the record shows was published in "Neighbors" on December 26, 2001. Vol. 1 A.000007. Also, the advertised notice, but not in the mailed notice states as follows: These applications have been filed with the Planning Department for review by the Historic Preservation Board and will be considered pursuant to the Board's authority in accordance with Sec. 118-102 of the City's Land Development Regulations. Written comments may be addressed to the Historic Preservation Board via email at HPB@miamibeachfl.gov by 5:00pm three business days before the meeting .... Finally, regarding other types of written materials, both the notice and the advertisement for the meeting states as follows: "Members of the public who wish to provide testimony and/or submit evidence in support or in opposition to an item scheduled to be heard may appear in person and will be required to wear facial coverings and observe social distancing consistent with CDC guidance ... " Id. The language of the notice as when material should be filed is relevant because the Appellants did not follow the directions of the advertised notice, but rather filed their notice on a Sunday, February 7th the day before the hearing that was held on Monday, February 8th•4 4 The City, joined by the Applicant, argues that the notice/advertisement requires the exclusion of Appellants last minute written submission of arguments submitted the day before the hearing date. While such late filing 8 Testimony City Staff presented its recommendation in support of the application. Transcript at pp. 3-5. Counsel for the Applicant made a full presentation covering all aspects of the proposed redevelopment. Specifically, the Applicant's architect and landscape architect explained the details of the renovation. Id. at pp. 13-18. Their testimony was consistent with the detailed analysis that Staff had presented in their recommendation. Vol 1 pp. A.00000019. As previously noted, the Appellants represented by counsel filed a letter of objection consisting of seven pages on a Sunday, the day before the hearing held Monday, February 8th. Id. at A.000139-000145. Appellants passed this letter to the Board members as part of their objection to the application. Transcript at p. 21. Counsel chose not to provide as part of his presentation, an explanation of the points raised in the letter. "So rather than spending a lot of time going into the details on my objections, I provided in may be poor practice, the notice states no penalty for failure to comply, such as excluding all such materials from, consideration . While the exclusion of last- minute filings is a laudable goal, it should far more explicit and ideally part of the City's Code. See, e.g., Section 33-311(0), Code of Miami-Dade County Florida. Of course, even if the filing is not excluded, it does not excuse the objector from .detailing the objections before the Board. This issue is discussed in more detail later in this Order. 9 writing, and I'll provide another copy into the record." He describe in very general terms, issues covered in the late filed written objections: We are also submitting a copy of this letter into the record. The letter raises issues related to the project, not complying with regulations of the zoning district, not complying with the certificate of appropriateness requirements, and also not complying with the variance laws. To save the time before this board, it laid out all the numerous conditions, existing and proposed, which do not comply with the zoning code and other non-compliant code issues, which are related to the application. I note that the original request for ten variances was withdrawn, but the non-conforming zoning violations remain in the plans. [Id. at p. 22.] Counsel for the Appellants did raise in his presentation before the Board, that the plan fails to show the location of loading spaces, which the Appellants' counsel argued was a traffic issue. Id. Additionally, Appellants' counsel asserted there was, an: " ... increase of a 331-person occupancy on the fourth level that was never there before. There's no indication of a requirement to a CUP, nor is there any evaluation of traffic in the file, usual and customary when a project has substantial changes that affect the uses, or modify the uses, or change uses in different locat ions. It's usually required to be documented into the file and a matter of public record .... " [Id. at p.23.] At this point of the proceedings counsel for the Appellants was asked if he needed more time. Id. He responded, "I'm going to need one more minute. I will be done." Id. At which point, counsel continued to raise concerns regarding the rooftop pool area. "It seems like there's a substantial increase in 10 occupancy use. So this is the type of -exactly the type of thing that should go to the CUP, but isn't properly documented in the file. So it needs to be done." Id. at p.24. Counsel also raised an issue of the pool area and noise and the impact that it could have on his clients. Id. With that, the Appellants completed their presentation before the Board. In contrast to the Appellants' objection was the support the Applicant receive from nearby properties. Counsel for the National Hotel, who identified that his client the owner Daphnie Dray was present, advised the Board that the National Hotel located at 1677 Collins Avenue is right next door to the Delano. Id. at p. 25. He noted that his client supports the plan and stated, "Like any good neighbor, the Delano proposes a plan that is sensitive to its adjacent properties, neighbors, as well as the surrounding historic district, and that's why we urge you to approve this application for the certificate of appropriateness." Id. Ms. Dray the owner of the National Hotel testified as well: So I just wanted to say hello to everyone, and thank you for your talent to keep Miami Beach what it is. This is amazing, and I want really to thank the team of Mr. Goldstein to present such and an amazing renovation. Miami is going to be so--that's really-I'm just very emotional because I'm very surprised of what Mr. Robbins [Appellants' counsel] came to say because the only people that are really going to be impacte<:f by those renovation (sic) is the National Hotel, but we are so free and so happy to have this historical building that is 11 going to be renovated in such an amazing way, that we are approving the project and thanking you to approve it as well. Thank you very much. [Id. p. at 26.] The Board heard from another close neighbor of the Delano, the Shelborne Hotel, represented by Sangro Sher from Claro Development. He testified that he met with the applicant reviewed their information and is in support of the "very tasteful renovation." Id. at p. 27. He concluded his remarks by stating : "So I wanted to tell you that another proximate and close neighbor feels strongly that this is something that should be approved and moved forward. So I hope you can do that." Id. Also in support of the application was the Miami Design Preservation League, represented by Mr. Daniel Giraldo. He testified: Now it's great to see this new life for the Delano, which still will maintain its historic integrity, but also be certain of the things that were done in the Stark time will be kind of refreshed and brough back to the original. So we're very happy with those aspects of the project. Also, its great to see a historic property being renovated without a large tower, which we're seeing more and more of around town. So we do commend the applicants for their efforts, and we look forward to the Delano being restored and reopened soon. [Id. at p. 26-27] The Applicant and City Staff responded to the presentation by Appellants' counsel. Regarding Appellants' claim of increased occupancy due to the rooftop pool renovation, the Applicant's representative testified: MR. KASDEN: If I may just respond briefly? Two things--and I'll 12 deal with the occupancy issue. The occupancy issue is one that, if there is a change in occupancy, it would be dealt with through a CUP at the planning board. But I will tell you, there is no proposal to increase the overall occupancy of the property. [Emphasis supplied][/d. p. 40.] Ms. Tackett, City of Miami Beach Staff representative, provided further information regarding increased occupancy: And just to further that, we will be reviewing their occupancy, their seat count, which areas are open to the _public, which areas are for hotel guests only, during the building permit review process. If they trigger a requirement for a conditional use permit, through the planning board, due to their occupancy, they will be heard at the planning board, but that's not the purview of this board, but that is definitely part of the review during the permitting. [Id. at 40-41.] Ms. Tackett also addressed Appellant counsel's other argument asserted at the public hearing regarding the lack of loading spaces: The loading spaces --again, because they're not intensifying at this point --at least, we don't believe this is an intensification of use. There're no new hotel units, right? They're all existing. And there's no change of use. Right now, you have a hotel with accessory restaurant and alcoholic beverage establishment. Because there is no change of use that we've identified, there's no requirement for loading. If they go through a conditional use process, the planning board would be reviewing circulation loading in their operational plan, as part of that review. But, at this point, you know, from staff's perspective, it does not appear that loading spaces or a waiver from the loading requirements is required. [Emphasis supplied] [Id. at p. 41.] At the conclusion of the hearing, the Board voted unanimously to 13 approve the Certificate of Appropriateness. Id. at p. 57 -58. This appeal followed. Standard of Review At the outset, it is important to set forth the limited nature of the review before the Special Magistrate. Miami Beach Code, Section 118-9(c)(4) provides that in the review an order of the Historic Preservation Board, the Special Magistrate must determine whether: (a) procedural due process was accorded, (b) the essential requirements of law were observed, and (c) the decision was supported by substantial competent evidence. The City's code, although an appeal, has mimicked the review provided from what ordinarily would be a review from an administrative decision to circuit court known as "first tier certiorari" review. See Broward Cty. v. G.B. V. Int'/, 787 So. 2d 838 (Fla. 2001}; City of Deerfield Beach v. Vail/ant, 419 So. 2d 624 (Fla. 1982); Haines City Community Development v. Heggs, 658 So. 2d 523 (Fla. 1995). A local government's quasi-judicial decision must be upheld if there is any competent substantial evidence supporting it. Dorian v. Davis, 87 4 So. 2d 661 (Fla. 5th DCA 2004 ); Eckler v. Orange County, 763 So. 2d 545 (Fla . 5th DCA 2000) (holding that a quasi-judicial determination by a local government should be upheld if any valid reason is supported by the record). 14 In Dusseau v. Metro. Dade County Bd. of County Com'rs, 794 So. 2d 1270, 1275-76 (Fla. 2001), the Florida Supreme Court clarified that: The sole issue before the court on first-tier certiorari review is whether the agency's decision is lawful. The [circuit] court's task ... is simple: The court must review the record to assess the evidentiary support for the agency's decision. Evidence contrary to the agency's decision is outside the scope of the inquiry at this point, for the reviewing court above all cannot reweigh the "pros and cons" of conflicting evidence. While contrary evidence may be relevant to the wisdom of the decision, it is irrelevant to the lawfulness of the decision. As long as the record contains competent substantial evidence to support the agency's decision, the decision is presumed lawful and the court's job is ended. [Emphasis supplied] Accord, Town of Manalapan v. Gyongyosi, 828 So. 2d 1029, 1034 (Fla. 4th DCA 2002); see also Fla. Power & Light Co. v. City of Dania, 761 So. 2d 1089, 1093 (Fla. 2000) (holding that where the circuit court "substituted its judgment for that of the City ... the circuit court departed from the essential requirements of the law"); City of Hialeah Gardens v. Miami-Dade Charter Found., Inc., 857 So. 2d 202, 206 (Fla. 3rd DCA 2003) (holding that reweighing the evidence is synonymous with failing to observe the essential requirements of the law). In reviewing the City's decision on "first tier" certiorari "the circuit court's [or in this case the Special Magistrate's] task is to review the record for evidence that supports the agency's decision, not that rebuts it -for the court cannot reweigh the evidence. [Emphasis original]" Broward Cty. v. G.B. V. Int'/, 15 787 So. 2d 838, 846 n.25 (Fla . 2001 ); See Haines City Cmty. Dev. v. Heggs, 658 So. 2d 523, 530 (Fla. 1995). Appellants were Afforded Due Process Appellants have not argued nor demonstrated that they were not given notice or did not have the opportunity to be heard. See Carillon Cmty. Residential v. Seminole Cnty, 45 S . 3d 7, 9(Fla. 5th DCA 2010)("The 'core' of due process is the right to notice and an opportunity to be heard. LaChance v. Erickson, 533 US 262 (1998) [parallel citations omitted]"). Appellants cla im [not argued before the Board and therefore waived] that they were denied "due process" because the Board approved a site plan that had hash marks to indicate where work was not done. Appellants' Initial Brief at p.19 . This, of course, has nothing to do with procedural due process. Indeed, in advance of the hearing, Appellants were aware of the hash marked site plan as evidenced by their belatedly filed objections the Sunday before the Monday morning Board hearing. They had the opportunity to be heard on this issue but failed to raise the issue in their presentation before the Board. Accordingly, the Appellants had notice of the hash marked areas and were given the opportuniy but chose not to be heard on this issue. Cf. Davis Islands Civic Ass'n v. City of Tampa, No. 05-5809, 2006 WL 408058, at *2-*4( Fla. 13th Jud. Cir. c ·t. Jan. 25, 2006 (alleged deficiencies in, and amendments 16 made to, site plans did not violate due process where objectors had the ability to review the plans and "received a full and fair opportunity to voice their concerns and be heard"). Board's Decision Supported by Substantial Competent Evidence, and Essential Requirements of Law were Observed Department Recommendation and Staff Testimony Constitute Substantial Competent Evidence The Department's recommendation together with the testimony of the Department representative Ms. Tackett, alone constitutes substantial competent evidence to support the Historic Preservations Board's approval of the Certificate of Appropriateness. 5 See Village of Palmetto Bay v. Palmer Trinity Private Sehl., Inc., 128 So. 3d 19, 26-27 (Fla. 3rd DCA 2012) (staff report recommendation, in which "all applicable criteria" were reviewed, constitutes competent substantial evidence); City of Hialeah Gardens v. Miami-Dade Charter Found., Inc., 857 So. 2d 202, 205 (Fla. 3rd DCA 2003) (testimony of professional staff, when based on professional experiences and personal 5 Of course, the testimony in support of the Project from the owners of the National and Shelborne Hotels that are directly impacted by the proposed renovation, provided additional substantial competent evidence and in stark contrast to the impacts that Appellants asserted, which facilities as counsel noted "was down the block." Transcript at p.22. 17 observations and information in application and site plan constitute competent substantial evidence). Late Filed Objections, While Not Excluded from the Hearing, Did Not Relieve the Obligation of Appellants to Present to the Board their Specific Objections The Appellants have raised certain issues jn opposition to the Certificate of Appropriateness in its late filed memorandum delivered on Sunday, before the Board's Monday morning hearing. As noted in Footnote 4 to this Order supra, the City, joined by the Applicant, believe that according to the instructions in the mailed notice and advertisement of the hearing, that this document should be excluded from consideration. The notice and advertisement are not explicit in that the instructions do not provide that the filing is required three days prior to the hearing, otherwise the material will be excluded from the hearing. Time limits without penalties for failure to comply are viewed as directory. See, e.g., Brown v. Pumpian, 504 So. 2d 481, 482 (Fla. 1st DCA 1987) ('[A]s a general rule statutes setting the time when a thing is to be done are regarded as merely directory, where no provision restraining the doing of it after that time is included and the act in question is not one upon which court jurisdiction depends.") Notwithstanding that the late filed material is not excluded from the hearing, it did not relieve Appellants' obligation to explicitly detail every 18 objection and factual basis for it in their presentation before the Board. The purpose of which, is to give the Board and Staff (as well as the Applicant) an opportunity to consider and respond to those objections. Appellants vague references to, "not complying with regulations of the zoning district, not complying with the certificate of appropriateness requirements, and also not complying with the variance laws code violations," was wholly insufficient to preserve error. Transcript at p.22. Additionally1 Appellants merely referencing their 11 th hour filing stating, "To save time before this board, it laid out all numerous conditions, existing and proposed, which do not comply with the zoning code and other non-compliant issues, which are related to the application" is equally vague and wholly insufficient to preserve error. Id. It is a fundamental principal of appellate review that issues not specifically raised before the lower tribunal may not be raised for the first time on appeal. Commission on Ethics v. Barker, 677 So. 2d 254 (Fla. 1996); Fredericson v. Levinson, 495 So. 2d 1156, 1158 (Fla. 5th DCA 1986). This requirement applies equally to appeals from administrative tribunals . First City Savings Corp. of Texas v. S & B Partners, 548 So. 2d 855 (Fla. 5th DCA 1989) ( condemning the practice of "sand bagging" local government bodies by withholding issues until after decision-making is final); See Clear Channel Communications v. North Bay Village, 911 So. 2d 188, 190 (Fla. 3rd DCA 2005) 19 ("The purpose for requiring a contemporaneous objection is to put the trial judge [in the case the Board] on notice of a possible error, to afford an opportunity to correct the error early in the proceedings, and to prevent a litigant from not challenging an so that he or may later use it as a tactical advantage."); Ferguson v. State, 417 So. 2d 639, 642 (Fla. 1982) (holding that objections must be made with sufficient specificity to apprise the trial judge [ or in this case the Board] of potential error and to preserve the point for appellate for appellate review, general objections are insufficient); See Fort Lauderdale Board of Adjustment v. Nash, 413 So. 2d 855 (Fla. 4th DCA 1982); Dade County v. Marca, S.A. 326 So. 2d 183 (Fla. 1976). The Florida Supreme Court has articulated the rationale for raising objections before the administrative body in a zoning context, which equally applies here: The administrative boards usually provided for the consideration and review of zoning problems are made of local people, having the advantage of full local information as to the reasons behind the various zoning regulations. Their findings, while not conclusive, are indeed helpful in the ultimate determination of the rights of the parties, Moreover, the inequalities of a zoning ordinance, if called to the attention of such local administrative boards. May frequently be adjusted at that level. Such boards should, at least, be given an opportunity to afford relief, or state their reasons for not doing so. De Carlo v. Town of West Miami, 49 So. 2d 596, 597 (Fla. 1950) 20 Accordingly, the Special Magistrate finds that those matters in Appellants' objection letter not expressly raised in the presentation before the Board were waived. In this case, the only matters that were specifically brought to the attention of the Board were the objection that there was no loading area shown and the concern that a rooftop pool area that would accommodate 331 persons (characterized by the Appellants as an increase in occupancy) would require a potential conditional use permit and an evaluation of traffic. Transcript at p. 23. 6 Appellants Preserved Objections are Without Merit Both objections were clearly without merit based on the testimony of the Applicant and Staff. First, as to a required loading area, Ms. Tackett explained that the development did not create an intensification of use as there are no additional hotel units, and that there was no change of use identified and thus no requirement for loading . She noted that if the Applicant is ultimately required to go through a conditional use permit, the Planning Board, which would have jurisdiction, "would be reviewing the circulation loading in their operational plan as part of that review." Transcript at 41. 6 Appellants' counsel did suggest that this use "could' cause a problem with noise, however, that concern was not shared by the Applicant's proximate neighbors the National or the Shel borne Hotels. Id at p. 24-27. 21 Second, the Appellants' concern regarding impacts from what it termed a 311 increase in occupancy from the pool deck was also without merit. The Applicant's representative stated: "If there is a change in occupancy, it would be dealt with through a CUP at the planning board. But I will tell you there is no proposal to increase the overall occupancy of the property. [Emphasis supplied] Id. at p.40. Ms. Tackett testified that Staff would be "reviewing their occupancy, their seat count, which areas are open to the public, which areas are for hotel guests only during the building permit review process." Id, She advised that if the Applicant triggers a conditional use process that would be heard by the Planning Board not this Board. Id. This is consistent with the conditions of approval in the Board's order. "Nothing in this order authorizes violation of the City Code or other applicable law, nor allows a relaxation of any requirement or standard set forth in the City Code" Board's order Section Ill. K. Vol. 1 at p. A .000005. Also, "The issuance of the approval does not relieve the applicant from obtaining all other required Municipal, County and/or State reviews and permits, including final zoning approval" Id. 7 7 As the City points out in it answer brief at p.31 Section 118-561 of the City Code expressly empowers the Board to impose reasonable conditions on its approval. That provision provides in pertinent part: "Violation of such conditions and safeguards, when made a part of the terms under which the certificate of 22 Appellants Non-Preserved Objections Are Also Without Merit While the Special Magistrate has determined that all other objections not specifically raised by the Appellants in their presentation before the Board are waived, for efficiency of further review of this matter, the Special Magistrate addresses those waived claims. Traffic Analysis not Required Appellants raise that Section 118-562(b )(9) of the City Code requires that this Project as a commercial project that exceeds 5000 square feet, requires a transportation analysis prepared by a traffic engineer. Besides not arguing this section of the City Code before Board, this citation and argument is not even included in the late filed objection letter. 8 appropriateness is granted, shall be deemed a violation of these land development regulations." 8 Appellants only mention of "evaluation of traffic was in the context of 331- person rooftop pool deck, which Appellants characterized as an increase in occupancy. Transcript at p.23. The Applicant countered there was no proposal for an increase in occupancy [Id. at 40], and Staff noted that they will be reviewing their seat count and "[i]f they trigger a requirement for a conditional use permit, through the planning board, due to their occupancy, they will be heard by the planning board, but that not within the purview of this board, but that is definitely part of the review during the permitting." Transcript at p. 40- 41. 23 The City disagrees with Appe11ants' interpretation of this section of the City Code. The City asserts that this section of the City's Code does not mandate a transportation plan for every proposed project, but only if the project would increase intensity or add 5000 square feet. In this case, there is no increase in intensity or occupancy. The City argues that this is essentially a renovation project, and the Project is "functionally 'grandfathered' in and no new analysis is necessary." City's Answer Brief at p.36. The City cites to the chart which is part of this record reflecting no increase in occupancy. Vol. 2. at A.000331. The governing rule of law is that an agency's interpretation of a statue or regulation that the agency is charged with administering will be given great deference by the courts and will not be overturned unless clearly erroneous or contrary to law. See Murciano v. State 208 So. 3d 130 (Fla 3rd DCA 2016); Metropolitan Dade County v. P. J. Birds Inc., 654 So. 2d 170, 175 (Fla . 3rd DCA 1995). Legal Envtl. Assistance Found., Inc. v. Board of County Comm'rs of Brevard County, 642 So. 2d 1081, 1083 (Fla. 1994).9 In this case the Special Magistrate finds that the City's interpretation of the Section 118-562(b)(9) of 9 In 2018 the Florida Constitution amended Article V creating Section 21 limiting State agency deference when interpreting state laws and rules. This limitation does not apply to local agencies interpreting municipal enactments. 24 the City Code should be given deference as the interpretation is not clearly erroneous or contrary to law. Indeed, Appellants' interpretation would require that any historic renovation project where there is no intensification or increase in occupancy would require a traffic study merely due to the size of the renovation, which is an absurd result. See In re Estate of Snyder, 333 So. 2d 519, 520-521(Fla. 4th DCA 1976)("1fthe language of a statute employed admits of two constructions, one of which makes the enactment mischievous if not absurd, and the other renders it reasonable and wholesome, the construction leading to an absurd result should be avoided. [Citation omitted]") No Setback Violations or Other Variances Permitted The Appellants argue that the plans demonstrate setback violations or that the site plan permits other variances such as a variance to the Dune Overlay Protection Area. The order provides, however, "No variances have been applied for as part of this application." Board's order Section 11. Additionally, Section Ill. K. of the Board's order provides "Nothing in this order authorizes a violation of the City Code or other applicable law nor allows a relaxation of any requirement or standard set forth in the City Code." 10 Indeed, 10 The City points out that the Board's order provides in Section I. B. 1 that the plan "Is not consistent with Certificate of Appropriateness Criteria 'bin Section 118-564(a)(3) of the Miami Beach Code," and for this reason subsequent conditions of the order requires correction. 25 where Staff found that the Applicant had certain encroachments in the Dune Preservation Overlay District, as a condition of approval, the Applicant was required to make corrections. Board's order Section I C.1.g. Also, because Staff was concerned with the cabanas and setbacks, the Board's order requires that "Cabanas and associated paving shall comply with the minimum required setbacks." Board's order Section I.C. h. Staff did note that there were valid permits from the 90's for work that today would not be permitted in the oceanfront overlay. As such, previously permitted work could remain, but Staff noted that the Applicant had agreed to comply with one hundred percent of the current requirements for the Dune Preservation Overlay District. Transcript at p. 45. Appellants assert that their evaluation of the site plan demonstrates that the ADA walkways are within the setback, which would require variances. Staff and ultimately the Board's order apparently disagree with Appellants' assessment, and in any event, the Board's order permits no deviation from the City Code. This really ends the inquiry for the Special Magistrate as the Special Magistrate only looks to see if the record contains substantial competent evidence to support the Board's decision, which it does. 26 Moreover, as the City points out, Section 142-1132( o )( 11) provides: "Walkways in required yards may exceed these restrictions when approved through the design review or certificate of appropriateness procedures, as applicable, and pursuant to chapter 118 article VI, of the city Code." Accordingly, even if the Appellants were right about the setback encroachments, which they are not based on substantial competent evidence, encroachments are permitted through this process. Hash Marks on the Site Plan do not Make it Incomplete The site plan contains hash marks to designate areas where work was not proposed to be done on the Project. The Appellants complain that this somehow violates procedural due process, which it does not as fully explained in this order. See Due Process section of this Order supra. Appellants also argue that the existence of the hash marks on the site plan somehow violates a requirement that an applicant shall include a "complete site plan." Appellants' Initial Brief at p.17. Appellants further argue that existence of the hash marks somehow removes those portions from the site plan. But, as the Applicant correctly points out, "The hash marks showing the portion of the rear yard work that is not within the scope of the Application 27 are fully transparent-they do not obscure the information of the reference plan sheets." Applicant's Answer Brief p.20. The Applicant at this page of its answer brief provides a part of the site plan that includes the hash marks and states, "Setbacks, structures, and other required details are clearly visible through the shaded area of the drawing. There is no legitimate argument that the HPB [Board] was precluded from reviewing and considering the complete site plan as Appellants argue." Id. 11 The Special Magistrate agrees with the Applicant's assessment of the hash marks. The City points out in its Answer Brief that in accordance with the provisions of Section 118-562(b) that the decision of whether an application is complete for purposes of scheduling a matter is a discretionary determination . That section in pertinent part provides that an application "[s]hall include such 11 This issue could have been fully vetted at the hearing and Staff and the Appellees could have responded, as well as the Board having the opportunity to evaluate. This is the real problem of Appellants not specifically presenting this objection and numerous others before the Board. This is why the courts require objections be specifically presented to the administrative body or they are waived. At oral argument Appellants' counsel argued that he merely referenced his late filed objections rather specifically presented to the Board because he was only given three minutes. There is nothing in the record to support that limitation. To the contrary, when asked how much more time he needed, counsel responded by saying "only one more minute." Transcript at p .23. 28 information and attached exhibits as the board and the planning department determine are needed to allow for complete evaluation ... " Clearly Staff had adequate information from the site plan to make a complete evaluation for the purpose of making a recommendation, and the Board had adequate information from the site plan to make a decision on the Certificate of Appropriateness. The narrow scope of review in this case does not permit the Special Magistrate to substitute the Special Magistrate's judgement on this matter. Fla. Power & Light Co. v. City of Dania. Conclusion 12 The Special Magistrate finds that in this case the Appellants were afforded due process, that there was substantial competent evidence to support the decision of the Board, and the essential requirements of law were observed. Those objections that the Appellants specifically brought to the attention of the Board were without merit. Those objections not specifically 12 The Appellants, a week prior to oral argument, filed a motion to strike an email located at page S. 00034-35 of the Appellee, Beach Hotel Associates LLC's Supplemental Appendix and Index on the basis that this was not part of the record. The Special Magistrate ordered that the matter be taken up at oral argument. On oral argument, the Appellee did represent that this was not admitted into evidence as part of the record before the Board. The Special Magistrate, however, has not relied on this evidence in rendering a decision this case and accordingly dismisses this motion on the basis of mootness. It should be noted that the proper way to seek to supplement the record is by way of a separate motion served on all parties. 29 presented to the Board, but merely referenced to the Board by Appellants referring to a memorandum filed on Sunday prior to the Monday hearing were waived. Notwithstanding that waiver, the Special Magistrate has reviewed those waived objections and have found them to be without merit. Accordingly, the Historic Preservation Board's decision is AFFIRMED. Dated: June 25, 2022 ~~ Craig.C~ Special Magistrate Copies to: Cynthia L. Neves, Clerk of the Special Magistrate All counsel of record 30