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A Letter to Planning CouncilCITY OF MIAMI BEAOH CITY HALL 1700 CONVENTION CENTER DRIVE MIAMI BEACH FLORIDA 33139 OFFICE OF THE CITY MANAGER May 13, 2004 TELEPHONE: (3~__} 673-7010 FAX: (305) S73-77~2 Carolyn Dekle Executive Director South Florida Regional Planning Council 3440 Hollywood Boulevard, Shite 140 Hollywood, FL 33021 Dear Ms. Dekle: The purpose of this letter is to transmit the City of Miami Beach's comments on the Notification of Proposed Change filed for the expansion of the Downtown Development of Regional Impact (DRI) district boundaries to include the northwest quadrant of Watson Island. On May 5, 2004, the Miami Beach City Commission held a public hearing to solicit public input regarding this NOPC and adopted the attached resolution. For several years, the Mayor and City Commission of Miami Beach have expressed serious concern regarding the impacts of the proposed developments on Watson Island. The NOPC expands the boundaries of the DRI to include a significant development program on Watson Island, not previously contemplated on the Island, which will further exacerbate the adverse impacts already realized to date. The Mayor and City Commission of Miami Beach feel this is an extremely important issue for our barrier island's future sustainability. MacArthur Causeway is the key linkage between Miami Beach/South Beach and the mainland, which makes it a key infrastructure asset to the region's economy. Recent developments on Watson Island (i.e. Parrot Jungle and the Children's Museum) have already demonstrated adverse traffic impacts on the MacArthur Causeway, and inevitably, additional impacts will result from the proposed Island Gardens project as well as the proposed FTAA Headquarters and other development planned on Watson Island. Throughout this DRI process, City of Miami Beach staff has stayed in contact with Council staff, and, as eady as February 2002, the City of Miami Beach communicated its desire to participate with the City of Miami on discussions related to Watson Island and participate on the Stakeholder Council formed by the City of Miami. Miami Beach has never been informed of any meetings of the Stakeholder Council to address our ongoing concerns. Included as attachments to this letter are: 1. Commission Memorandum dated May 5, 2004 2. Commission Resolution adopted May 5, 2004 3. Summary of comments from May 5, 2004 Public Hearing 4. DMJM & Harris, Consultant to the City of Miami Beach, Review of "Transportation Assessment Proposed Boundary Change to the Downtown Miami DRI Increment I1" Report, dated May 12, 2004 5. Urban Environmental League Letter dated March 31,2004 6. City of Miami Beach correspondence to the City of Miami, dated February 7, 2002 As part of the City's review of the NOPC, the attached Commission Memorandum includes comments relative to Boundary Expansion, Land Use, Build Out Date, Transportation Methodology, Transportation Assessment, Comprehensive Plan, Development Moratoriums, and the FTAA. I have summarized our initial findings below, and additional information pertaining to each finding is provided in the attached memorandum. I would especially call your attention to item 5, which clearly demonstrates that the Transportation Assessment did not analyze all of the roadway segments that were identified in the Council's Final Pre-Application Summary. A summary of the relevant issues and areas of concern are as follows: 1. The NOPC appears to be a substantial deviation as defined in 380.06(19)(e)(3), because land area, on which new development is proposed, is being added to the DRI and has not previously been reviewed. 2. The change in the number of hotel rooms approved in Increment II may be a substantial deviation as defined in 380.06(19)(b)(11), because the increase is greater then 5% and greater than 75 units. It must be determined if this is considered a substantial deviation. 3. The Build Out Dates identified in the NOPC (May 20, 2014) appear inconsistent with the Development Order and City of Miami Resolution 02-107 (May 28, 2009. 4. Based on the Build Out Dates identified in the NOPC of May 20, 2014, does the law at the time of application submittal apply and thus, dictate such an extended Build Out Date as a substantial deviation? 5. It appears that the Transportation Consultant did not analyze the study area defined by the South Florida Regional Planning Council, and rather than review the impact on all North, South, East and West roads in Miami Beach (as specified in the pre-application summary), only studied the impact on the MacArthur Causeway and Alton Road. 6. Additional analysis and detailed information is required to determine the traffic impact the project will have on Miami Beach roadway segments. 7. The City of Miami Beach is unable, at this time, to determine whether al__l committed developments in Miami Beach were analyzed, or only committed developments on 5th Street and on Alton Road were analyzed as part of the traffic analysis. Therefore, the City requests a copy of all committed developments that were reviewed. 8. The public notice for two Watson Island comprehensive plan amendments on the Island Gardens site is clearly a proposed change to the comprehensive plan for the project and would appear to contradict the statement in the NOPC that comprehensive plan amendments are not required by the proposed change. Can it be clarified if the proposed change to the comprehensive plan may not be a "required change" for the project to proceed, and therefore the response in Number 11 of the NOPC is correct? 9. Do the moratoriums and issues related to them affect roadways that are impacted by the Downtown DRI and have any bearing on the traffic analysis and/or substantial deviation review? 10. Does the proposal of Watson Island as one of two preferred sites for the Secretariat of the FTAA have any bearing on the proposed change and the substantive deviation review of impacts on areas that are affected by the Downtown DRI? Additionally, the City engaged DMJM Harris, as the .City's transportation consultant, to review the Transportation Assessment in the NOPC. The City's consultant concurs with the City's findings in number 5 above, that the Transportation Assessment did not analyze the study area, as defined by the Planning Council's Final Pre-Application Summary. The consultant concludes that their "review found various sources for discrepancies throughout the report with various degrees of impact. Discrepancies that need to be addressed and corrected due to their systematic impact to the overall project are: 1. Definition of Build-out Year, 2009 or 2014 and subsequent corrections to the analysis. 2. Selection of appropriate growth year factor (2.5% to 5%) for the Miami Beach area and the MacArthur Causeway and subsequent corrections to the analysis. 3. Use the FDOT standard Maximum Service Volume (MSV) and level of service for Mac^rthur Causeway and subsequent corrections to the analysis. 4. Include all committed trips to the roadway system and assess the impacts on MacArthur Causeway and the intersection of 5th Street at Alton Road." I appreciate the opportunity to provide you with the City of Miami Beach's comments on the NOPC to the Downtown Miami DRI. The NOPC has significant impacts on Miami Beach and we appreciate, in advance, your attention and diligence in reviewing the City's comments, the consultant report and public input contained herein. If you need additional information, or have any questions, please contact me at 305-673-7010. Sincerely, rge M. Gonzalez City Manager C: Honorable Mayor and City Commissioners, City of Miami Beach Honorable Mayor and City Commissioners, City of Miami Joe Arriola, City Manager, City of Miami Ken Metcalf, Florida Department of Community Affairs Dana Nottingham, Director, Downtown Development Authority Ryan Bayline, Shutts & Bowen Attachments (6)