BIE - Minimum Hotel Unit Size Requirements (3/18/2025)
City of Miami Beach, 1700 Convention Center Drive, Miami Beach, Florida 33139, www.miamibeachfl.gov
TO: Mayor Steven Meiner and Members of the City Commission
FROM: Eric Carpenter, City Manager
MEETING DATE: April 23, 2025
SUBJECT: BUSINESS IMPACT ESTIMATE
MINIMUM HOTEL UNIT SIZE REQUIREMENTS
AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH,
FLORIDA, AMENDING THE MIAMI BEACH RESILIENCY CODE, BY AMENDING CHAPTER 7,
ENTITLED “ZONING DISTRICTS AND REGULATIONS,” ARTICLE I, ENTITLED “GENERAL TO
ALL ZONING DISTRICTS,” BY AMENDING SECTION 7.1.5, ENTITLED “UNIT SIZES,” AT
SUBSECTION 7.1.5.2, ENTITLED “UNIT SIZE STANDARDS,” BY MODIFYING THE MINIMUM
LODGING AND HOTEL UNIT SIZES CITY-WIDE; BY AMENDING CHAPTER 7, ENTITLED
“ZONING DISTRICTS AND REGULATIONS,” ARTICLE II, ENTITLED “DISTRICT
REGULATIONS,” BY AMENDING SECTION 7.2.4, ENTITLED “RM-1 RESIDENTIAL
MULTIFAMILY LOW INTENSITY,” AT SUBSECTION 7.2.4.3, ENTITLED “DEVELOPMENT
REGULATIONS (RM-1)”; BY AMENDING SECTION 7.2.5, ENTITLED “RM-2 RESIDENTIAL
MULTIFAMILY, MEDIUM INTENSITY,” AT SUBSECTION 7.2.5.3, ENTITLED “DEVELOPMENT
REGULATIONS (RM-2)”; BY AMENDING SECTION 7.2.6, ENTITLED “RM-3 RESIDENTIAL
MULTIFAMILY, HIGH INTENSITY,” AT SUBSECTION 7.2.6.3, ENTITLED “DEVELOPMENT
REGULATIONS (RM-3)”; BY AMENDING SECTION 7.2.10, ENTITLED “CD-1 COMMERCIAL,
LOW INTENSITY DISTRICT,” AT SUBSECTION 7.2.10.3, ENTITLED “DEVELOPMENT
REGULATIONS (CD-1)”; BY AMENDING SECTION 7.2.11, ENTITLED “CD-2 COMMERCIAL,
MEDIUM INTENSITY DISTRICT,” AT SUBSECTION 7.2.11.3, ENTITLED “DEVELOPMENT
REGULATIONS (CD-2)”; BY AMENDING SECTION 7.2.12, ENTITLED “CD-3 COMMERCIAL,
HIGH INTENSITY DISTRICT,” AT SUBSECTION 7.2.12.3, ENTITLED “DEVELOPMENT
REGULATIONS (CD-3)”; BY AMENDING SECTION 7.2.13, ENTITLED “MIXED USE
ENTERTAINMENT DISTRICT,” AT SUBSECTION 7.2.13.3, ENTITLED “DEVELOPMENT
REGULATIONS (MXE)”; BY AMENDING SECTION 7.2.14, ENTITLED “NORTH BEACH TOWN
CENTER-CORE DISTRICT (TC),” BY MODIFYING SUBSECTION 7.2.14.4, ENTITLED
“DEVELOPMENT REGULATIONS (TC),” TO MODIFY THE MINIMUM LODGING AND HOTEL
UNIT SIZE; AND BY MODIFYING SUBSECTION 7.2.14.6, ENTITLED “TOWN CENTER-
CENTRAL CORE (TC-C) DISTRICT,” BY REMOVING “MICRO-HOTEL” AS A PERMITTED USE,
ALONG WITH ASSOCIATED REFERENCES; BY AMENDING SECTION 7.2.15, ENTITLED
“PERFORMANCE STANDARD DISTRICT (PS),” AT SUBSECTION 7.2.15.2, ENTITLED
“RESIDENTIAL PERFORMANCE STANDARDS DISTRICTS (R-PS),” TO MODIFY THE
MINIMUM LODGING AND HOTEL UNIT SIZE; AND BY AMENDING SUBSECTION 7.2.15.3,
ENTITLED “COMMERCIAL PERFORMANCE STANDARDS DISTRICTS (C-PS),” TO MODIFY
THE MINIMUM LODGING AND HOTEL UNIT SIZE; AND PROVIDING FOR CODIFICATION,
REPEALER, SEVERABILITY, APPLICABILITY; AND AN EFFECTIVE DATE.
Is a Business Impact Estimate Required?
X Yes ☐ No (If no, please check one of the boxes below)
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Business Impact Estimate
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If one or more boxes are checked below, this means the City of Miami Beach has
determined that a Business Impact Estimate for the above-referenced Ordinance is not
required by State law.
☐ The proposed Ordinance is required for compliance with Federal or State law or
regulation; ☐ The proposed Ordinance relates to the issuance or refinancing of debt; ☐ The proposed Ordinance relates to the adoption of budgets or budget
amendments, including revenue sources necessary to fund the budget; ☐ The proposed Ordinance is required to implement a contract or an agreement,
including, but not limited to, any Federal, State, local, or private grant or other
financial assistance accepted by the City; ☐ The proposed Ordinance is an emergency ordinance; ☐ The Ordinance relates to procurement; or ☐ The proposed Ordinance is enacted to implement the following:
a. Private applications for comprehensive plan amendments and land
development regulation amendments;
b. Development orders, development permits, and development agreements;
c. Sections 190.005 and 190.046, Florida Statutes, regarding community
development districts;
d. Section 553.73, Florida Statutes, relating to the Florida Building Code; or
e. Section 633.202, Florida Statutes, relating to the Florida Fire Prevention Code.
If none of the above exceptions apply, this Business Impact Estimate is hereby provided
in accordance with Section 166.041(4), Florida Statutes.
1. Summary
A summary of the proposed ordinance and its purpose is more fully set forth in the
Commission Memorandum accompanying the ordinance, as well as in the recitals
to the ordinance itself, provided at First Reading and attached hereto.
2. An estimate of the direct economic impact of the proposed Ordinance on private, for-
profit businesses in the City of Miami Beach, if any:
(a) An estimate of direct compliance costs that businesses may reasonably incur;
The proposed ordinance does not apply to existing, legally established
businesses.
(b) Any new charge or fee imposed by the proposed Ordinance or for which businesses
will be financially responsible;
The proposed ordinance does not apply to existing, legally established
businesses.
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(c) An estimate of the City’s regulatory costs, including estimated revenues from any new
charges or fees to cover such costs.
The proposed ordinance would generate no more than nominal additional
regulatory costs, which may be associated with administration activities by
applicable City departments.
3. Good faith estimate of the number of businesses likely to be impacted by the proposed
Ordinance:
The proposed ordinance does not apply to existing, legally established
businesses.
4. Additional comments:
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COMMISSION MEMORANDUM
TO:Honorable Mayor and Members of the City Commission
FROM:Eric Carpenter, City Manager
DATE:February 26, 2025 9:25 a.m. First Reading Public Hearing
TITLE:MINIMUM HOTEL UNIT SIZE REQUIREMENTS
AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF THE CITY OF
MIAMI BEACH, FLORIDA, AMENDING THE MIAMI BEACH RESILIENCY CODE,
BY AMENDING CHAPTER 7, ENTITLED “ZONING DISTRICTS AND
REGULATIONS,” ARTICLE I, ENTITLED “GENERAL TO ALL ZONING
DISTRICTS,” BY AMENDING SECTION 7.1.5, ENTITLED “UNIT SIZES,” AT
SUBSECTION 7.1.5.2, ENTITLED “UNIT SIZE STANDARDS,” BY MODIFYING THE
MINIMUM LODGING AND HOTEL UNIT SIZES CITY-WIDE; BY AMENDING
CHAPTER 7, ENTITLED “ZONING DISTRICTS AND REGULATIONS,” ARTICLE II,
ENTITLED “DISTRICT REGULATIONS,” BY AMENDING SECTION 7.2.4,
ENTITLED “RM-1 RESIDENTIAL MULTIFAMILY LOW INTENSITY,” AT
SUBSECTION 7.2.4.3, ENTITLED “DEVELOPMENT REGULATIONS (RM-1)”; BY
AMENDING SECTION 7.2.5, ENTITLED “RM-2 RESIDENTIAL MULTIFAMILY,
MEDIUM INTENSITY,” AT SUBSECTION 7.2.5.3, ENTITLED “DEVELOPMENT
REGULATIONS (RM-2)”; BY AMENDING SECTION 7.2.6, ENTITLED “RM-3
RESIDENTIAL MULTIFAMILY, HIGH INTENSITY,” AT SUBSECTION 7.2.6.3,
ENTITLED “DEVELOPMENT REGULATIONS (RM-3)”; BY AMENDING SECTION
7.2.10, ENTITLED “CD-1 COMMERCIAL, LOW INTENSITY DISTRICT,” AT
SUBSECTION 7.2.10.3, ENTITLED “DEVELOPMENT REGULATIONS (CD-1)”; BY
AMENDING SECTION 7.2.11, ENTITLED “CD-2 COMMERCIAL, MEDIUM
INTENSITY DISTRICT,” AT SUBSECTION 7.2.11.3, ENTITLED “DEVELOPMENT
REGULATIONS (CD-2)”; BY AMENDING SECTION 7.2.12, ENTITLED “CD-3
COMMERCIAL, HIGH INTENSITY DISTRICT,” AT SUBSECTION 7.2.12.3,
ENTITLED “DEVELOPMENT REGULATIONS (CD-3)”; BY AMENDING SECTION
7.2.13, ENTITLED “MIXED USE ENTERTAINMENT DISTRICT,” AT SUBSECTION
7.2.13.3, ENTITLED “DEVELOPMENT REGULATIONS (MXE)”; BY AMENDING
SECTION 7.2.14, ENTITLED “NORTH BEACH TOWN CENTER-CORE DISTRICT
(TC),” BY MODIFYING SUBSECTION 7.2.14.4, ENTITLED “DEVELOPMENT
REGULATIONS (TC),” TO MODIFY THE MINIMUM LODGING AND HOTEL UNIT
SIZE; AND BY MODIFYING SUBSECTION 7.2.14.6, ENTITLED “TOWN CENTER-
CENTRAL CORE (TC-C) DISTRICT,” BY REMOVING “MICRO-HOTEL” AS A
PERMITTED USE, ALONG WITH ASSOCIATED REFERENCES; BY AMENDING
SECTION 7.2.15, ENTITLED “PERFORMANCE STANDARD DISTRICT (PS),” AT
SUBSECTION 7.2.15.2, ENTITLED “RESIDENTIAL PERFORMANCE
STANDARDS DISTRICTS (R-PS),” TO MODIFY THE MINIMUM LODGING AND
HOTEL UNIT SIZE; AND BY AMENDING SUBSECTION 7.2.15.3, ENTITLED
“COMMERCIAL PERFORMANCE STANDARDS DISTRICTS (C-PS),” TO MODIFY
THE MINIMUM LODGING AND HOTEL UNIT SIZE; AND PROVIDING FOR
CODIFICATION, REPEALER, SEVERABILITY, APPLICABILITY; AND AN
EFFECTIVE DATE.
RECOMMENDATION
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The Administration recommends that the Mayor and City Commission (City Commission) approve
the subject ordinance at First Reading and schedule a Second Reading public hearing for April
23, 2025.
BACKGROUND/HISTORY
On June 26, 2024, at the request of Commissioner Kristen Rosen Gonzalez, the City Commission
referred a proposal to modify minimum hotel unit size requirements (C4 O) to the Land Use and
Sustainability Committee (LUSC) and the Planning Board. On October 14, 2024, the LUSC
discussed the item and recommended that the Planning Board transmit an ordinance to the City
Commission in accordance with the following:
1. Remove the 85% and 15% thresholds for minimum hotel unit size in all applicable zoning
districts and establish a uniform minimum hotel unit size of 335 square feet, exclusive of
established exception areas.
2. Remove the current allowance of micro-hotel units, with a minimum unit size of 175 square
feet, in the TC-C district.
ANALYSIS
Citywide, the following are the current regulations applicable to the minimum unit size for hotel
units, as set forth in the LDRs:
85% of hotel units within a site have a minimum unit size of 335 square feet and 15% of hotel
units within a site have a minimum unit size of 300 square feet.
For contributing hotel structures, located within an individual historic site, a local historic
district or a national register district, which are renovated in accordance with the Secretary of
the Interior Standards and Guidelines for the Rehabilitation of Historic Structures as amended,
retaining the existing room configuration and sizes of at least 200 square feet shall be
permitted. Additionally, the existing room configurations for these hotel structures may be
modified to address applicable life-safety and accessibility regulations, provided the 200
square feet minimum unit size is maintained, and provided the maximum occupancy per hotel
room does not exceed 4 persons.
For hotel units within rooftop additions to contributing structures in a historic district and
individually designated historic buildings the minimum unit size is 200 square feet.
The following are the exceptions to the above noted minimum hotel unit size requirements:
RM-2 District:
For hotel structures located within the Collins Park District generally bounded by the erosion
control line on the east, the east side of Washington Avenue on the west, 23rd Street on the
north, and 17th Street on the south: 200 square feet.
CD-2 District:
For hotel structures located within the Collins Park District generally bounded by the erosion
control line on the east, the east side of Washington Avenue on the west, 23rd Street on the
north, and 17th Street on the south: 200 square feet.
For a property formerly zoned HD the minimum hotel unit size for is 250 square feet, provided
that the property does not exceed 25,000 square feet as of March 23, 2019.
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For properties on Washington Avenue from 5th Street to 16th Street: For new hotel construction
or conversion to hotel use, the minimum hotel room unit size may be 175 square feet, provided
that:
1. A minimum of 20 percent (20%) of the gross floor area of the hotel consists of hotel
amenity space that is physically connected to and directly accessed from the hotel. Hotel
amenity space includes the following types of uses, whether indoor or outdoor, including
roof decks: restaurants; bars; cafes; hotel business center; hotel retail; screening rooms;
fitness center; spas; gyms; pools; pool decks; and other similar uses customarily
associated with a hotel. Bars and restaurants shall count no more than 50 percent (50%)
of the total hotel amenity space requirements.
2. Windows shall be required in all hotel rooms and shall be of dimensions that allow
adequate natural lighting, as determined by the historic preservation board.
CD-3 District:
For hotel structures located within the Collins Park District generally bounded by the
erosion control line on the east, the east side of Washington Avenue on the west, 23rd
Street on the north, and 17th Street on the south: 200 square feet.
For new hotel units within attached or detached additions to contributing buildings on the
north side of Lincoln Road, between Pennsylvania Avenue and Lenox Avenue, with at
least 5 percent (5%) of the total floor area dedicated to amenity space: 200 square feet.
TC-C District:
Hotel units: 300 square feet.
Micro-hotel units: 175 square feet, provided that a minimum of 20% of the gross floor area
of the building consists of amenity space that is physically connected to and directly
accessed from the micro-hotel units without the need to exit the parcel.
Currently, most new hotel rooms in the city are required to have a minimum unit size of 335 square
feet. As recommended by the LUSC, the proposed ordinance removes the current allowance for
up to 15% of hotel units within a project to have a minimum unit size of 300 square feet. This
would ensure that all new hotel rooms, other than those within the exception areas noted above,
would be at least 335 square feet. Additionally, as further recommended by the LUSC, the
provision for micro-hotel units (minimum unit size of 175 square feet) has been removed from the
TC-C district.
Lastly, as a clean-up to the CD-1 regulations, where hotel use is not permitted, references to hotel
units and minimum hotel unit sizes has been eliminated.
PLANNING BOARD REVIEW
On February 4, 2025, the Planning Board held a public hearing and transmitted the proposed
ordinance to the City Commission with a favorable recommendation (6-0).
APPLICATION FEE WAIVER
The subject amendment is proposed on a comprehensive, citywide basis, and not on behalf of a
private applicant or third party. Pursuant to section 2.4.1.c of the Land Development Regulations
of the City Code, amendments to the City Code require the payment of the applicable fees in
section 2.2.3.5, 2.2.3.6, and appendix A to the City Code. These fees may be waived by a five-
sevenths (5/7ths) vote of the City Commission, based upon one or more of the following
circumstances:
1. The City Commission determines that the proposed amendment is necessary due to a change
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in federal or state law, or to implement best practices in urban planning, or based on
circumstances unique to the proposed amendment.
2. Upon the written recommendation of the City Manager acknowledging a documented financial
hardship of a property owner(s) or developer(s).
3. If requested, in writing, by a non-profit organization, neighborhood association, or homeowner's
association for property owned by any such organization or association, so long as the request
demonstrates that a public purpose is achieved by enacting the applicable amendment.
The Administration recommends that the City Commission waive the applicable fees based on
circumstances unique to the proposed amendment.
FISCAL IMPACT STATEMENT
No Fiscal Impact Expected
Does this Ordinance require a Business Impact Estimate? Yes
(FOR ORDINANCES ONLY)
If applicable, the Business Impact Estimate (BIE) was published on:
See BIE at: https://www.miamibeachfl.gov/city-hall/city-clerk/meeting-notices/
FINANCIAL INFORMATION
Not Applicable
CONCLUSION
The Administration recommends the following:
1. 1.The City Commission approve the subject ordinance at First Reading and schedule a
Second Reading public hearing for April 23, 2025.
2. In accordance with section 2.4.1.c.1 of the Land Development Regulations of the City Code,
the City Commission waive the applicable fees based on circumstances unique to the
proposed amendment.
Applicable Area
Citywide
Is this a “Residents Right to Know” item,
pursuant to City Code Section 2-17?
Is this item related to a G.O. Bond
Project?
Yes No
Was this Agenda Item initially requested by a lobbyist which, as defined in Code Sec. 2-481,
includes a principal engaged in lobbying? No
If so, specify the name of lobbyist(s) and principal(s):
Department
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Planning
Sponsor(s)
Commissioner Kristen Rosen Gonzalez
Co-sponsor(s)
Commissioner David Suarez
Condensed Title
9:25 a.m. 1st Rdg PH, Minimum Hotel Unit Size Requirements. (KRG/DS) PL 5/7
Previous Action (For City Clerk Use Only)
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