R5G-Short Term Rental Of Apartment Units Or Townhomes-Flamingo Park -Exposito-COMMISSION ITEM SUMMARY
Condensed Title:
Amending Section 142-1111, "Short Term Rental Of Apartment Units Or Townhomes," To Allow An
Extension Of Time For A lications Due To Governmental Error.
Key Intended Outcome Supported:
Maintain strong growth management policies.
Supporting Data (Surveys, Environmental Scan, etc.): While nearly half, 47.6%, suggested the
effort put forth by the City to regulate development is "about the right amount," nearly one-third, 29.6%,
indicated "too little" effort is being put forth by the City in this area.
Issue:
Should the City Commission amend the City Code to allow an extension of time for applications for
short term rental due to overnmental error?
Item Summary/Recommendation:
FIRST READING
The owner of 751 Meridian Avenue submitted an application to the Florida Department of Business &
Professional Regulation (DBPR), Division of Hotels and Restaurants in September 2009 for a
Transient Apartment license. Through an error by DBPR, the application was processed as non
transient, rather than a transient license. The property has also been issued a resort tax account by
the City. When the City adopted the "Short Term Rental of Apartment Units or Townhomes"
ordinance allowing such rentals in the Flamingo Park Neighborhood, the owners of 751 Meridian
Avenue were not able to obtain the required Certificate of Use to comply with the restrictions in the
ordinance due to the State error when issuing the license, nor were they notified of the applicable
deadlines and did not become aware of the deadlines until they had passed.
At the September 21, 2011 LUDC meeting, the Committee discussed this issue and by a vote of 3-0,
moved to refer an amending ordinance to the Planning Board, but with the restriction that an extension
of time be limited to 60 days after adoption of the ordinance and only because of governmental error in
issuing the proper license.
The Administration recommends that the City Commission approve the proposed ordinance on first
reading and set a second reading public hearing for the March 21, 2012 meeting.
At its December 13, 2011 meeting, the Planning Board reviewed the proposed ordinance and by a
vote of 4-1 2 members absent recommended that the Cit Commission a rove the ordinance.
Financial Information:
Source of Amount Account
Funds: 1
D 2
3
OBPI Total
Financial Impact Summary:
In accordance with Charter section 5.02, which requires that the "City of Miami Beach shall consider
the long-term economic impact (at least 5 years) of proposed legislative actions," this shall confirm
that the City Administration evaluated the long-term economic impact (at least 5 years) of this
proposed legislative action, and determined that there may be a measurable impact on the City's
budget by enacting the proposed ordinance as there should be a slight revenue increase in Resort
Taxes.
MlAMIBEACH 349
r>s&-AGENDA ITEM _f'\ ___ _
DATE 2-~-{2.-
~ MIAMI BEACH
City of Miami Beach, 1700 Convention Center Drive, Miami Beach, Florida 33139, www.miamibeachfl.gov
TO:
FROM:
DATE:
COMMISSION MEMORANDUM
Mayor Matti Herrera Bower and Members of the City Commission
Jorge M. Gonzalez, City Manager~
February 8, 2012 o-u FIRST READING
SUBJECT: Short Term Rental of Apartment Units or Townhomes
AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF THE
CITY OF MIAMI BEACH, FLORIDA, AMENDING THE LAND
DEVELOPMENT REGULATIONS OF THE CODE OF THE CITY OF
MIAMI BEACH, BY AMENDING CHAPTER 142 OF THE CITY CODE,
"ZONING DISTRICTS AND REGULATIONS," ARTICLE IV,
"SUPPLEMENTARY DISTRICT REGULATIONS," DIVISION 3,
"SUPPLEMENTARY USE REGULATIONS," BY AMENDING
SECTION 142·1111, "SHORT TERM RENTAL OF APARTMENT
UNITS OR TOWN HOMES," TO ALLOW AN EXTENSION OF TIME
FOR APPLICATIONS DUE TO GOVERNMENTAL ERROR;
PROVIDING FOR REPEALER, SEVERABILITY, CODIFICATION,
AND AN EFFECTIVE DATE.
ADMINISTRATION RECOMMENDATION
The Administration recommends that the City Commission approve the proposed
ordinance on first reading in its current, limited form and set a second reading public
hearing for the March 21, 2012 meeting. The Administration does not support expanding
the scope of the proposed ordinance.
BACKGROUND
This item was referred by the City Commission to the Planning Board at its October 19,
2011 meeting (City Commission item C4A), following an earlier referral to and review by
the Land Use and Development Committee at its September 21, 2011 meeting, at the
request of Commissioner Exposito (May 11, 2011 City Commission Item C4D). The item
seeks a recommendation on a proposed amendment to the recently enacted Ordinance
2010-3685, "Short Term Rental Of Apartment Units Or Townhomes -Flamingo Park
Neighborhood," which contains provisions and regulations governing those properties to
be legalized for short term rental in that neighborhood. The time periods specified in the
ordinance are as follows:
Time periods to apply for short-term rental approvals.
(1) Owners demonstrating compliance with subsections (b)(1) or (2) above, shall
apply for a certificate of use permitting short-term rental as detailed in subsection 142-
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City Commission Memorandum
Short term rentals
February 8, 2012 Page2
1111 (d) within a time period of six months from the effective date of this section (June
19, 201 0), or be deemed ineligible to proceed through the process specified herein for
legalization of short-term rentals.
(2} Within three months of the effective date of the ordinance enacting this section
(June 19, 2010), eligible owners shall apply to obtain all necessary approvals to comply
with the Florida Building Code, Florida Fire Prevention Code and with all other applicable
life safety standards.
(3} Compliance with the applicable requirements of the Florida Building Code and
Florida Fire Prevention Code shall be demonstrated by October 1, 2011, or rights to
engage in short-term rental under this section shall be subject to restrictions and/or
limitations as directed by the building official and/or fire marshal. This subsection shall
not prevent these officials from undertaking enforcement action prior to such date.
The deadline for applications to legalize short-term rentals has now passed. Eligibility
for this provision was determined by a specific set of criteria; for apartment buildings of
four or more units, or for four or more apartment units in one or more buildings under the
same resort tax account, the criteria are as follows:
In order to demonstrate current, consistent and predominant short-term renting, the
property must comply with all of the following:
a. Have been registered with the city for the payment of resort tax and made resort
tax payments as of March 1 0, 201 0; and
b. Have had City of Miami Beach Resort Tax taxable room revenue equal to at least
50 percent of total room revenue over the last two-year period covered by such
payments; and
c. Have been registered, with the State of Florida as a transient apartment or resort
condominium pursuant to Chapter 509, Florida Statutes, as of March 1 0, 2010.
After these criteria were developed, staff identified all those properties that would qualify
under these provisions, and developed a list of these properties for review by the
Commission during the process of adoption. After the ordinance was adopted, a letter
was sent to those properties on the list informing them of the passage of the ordinance
and the requirements and deadlines associated with the new provisions.
Recently, Mr. Simon Ferro, attorney for the owners of the apartment building at 751
Meridian Avenue made inquiries at the Planning Department regarding the short-term
rental ordinance, after the property was cited by Code Compliance for short-term rentals
without a license. Mr. Ferro has determined that the property would have met all the
criteria of the ordinance, but for the fact that the State of Florida mistakenly issued them
a license for non-transient apartments, even though they had applied previously for
transient apartments. Because they had received the wrong license, they were not on
the list and not specifically notified about the passage of the ordinance and applicable
deadlines. Mr. Ferro has requested that his client be allowed to seek licensing under the
ordinance, as his client's property otherwise meets all of the criteria to qualify based
upon payment of resort taxes, and other licensing requirements. As deadlines of the
ordinance cannot be waived by City staff; any exemption would require additional
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City Commission Memorandum
Short term rentals
February 8, 2012
legislation to reference such a case.
ANALYSIS
Page3
The owner of 751 Meridian Avenue submitted an application to the Florida Department
of Business & Professional Regulation (DBPR), Division of Hotels and Restaurants in
September 2009 for a Transient Apartment license. Through an error by DBPR, the
application was processed as non transient, rather than a transient license. The
property has also been issued a resort tax account by the City. When the City adopted
the "Short Term Rental of Apartment Units or Townhomes" ordinance allowing such
rentals in the Flamingo Park Neighborhood, the owners of 751 Meridian Avenue were
not able to obtain the required Certificate of Use to comply with the restrictions in the
ordinance due to the State error when issuing the license, nor were they notified of the
applicable deadlines and did not become aware of the deadlines until they had passed.
At the September 21, 2011 LUDC meeting, the Committee discussed this issue and by a
vote of 3-0, moved to refer an amending ordinance to the Planning Board, but with the
restriction that an extension of time be limited to 60 days after adoption of the ordinance
and only because of governmental error in issuing the proper license. This amending
ordinance was referred to the Planning Board by the City Commission at its October 19,
2011 meeting.
PLANNING BOARD
At its December 13, 2011 meeting, the Planning Board reviewed the proposed ordinance
and by a vote of 4-1 (Stolar opposed, Veitia and Fryd absent) recommended that the
City Commission approve the ordinance.
At this meeting, an attorney representing another property owner made a request to
modify the proposed ordinance to include another property that was not able to avail
itself of the benefits of the already approved ordinance. The case was. presented as
impediments that did not include governmental errors as the cause for the delay. The
Board voted 3-2 (Stolar & Tobin opposed, Veitia & Fryd absent) on this new proposal;
however, the motion failed.
FISCAL IMPACT
In accordance with Charter section 5.02, which requires that the "City of Miami Beach
shall consider the long-term economic impact (at least 5 years) of proposed legislative
actions," this shall confirm that the City Administration evaluated the long-term economic
impact (at least 5 years) of this proposed legislative action, and determined that there
may be a measurable impact on the City's budget by enacting the proposed ordinance
as there should be a very slight revenue increase in Resort Taxes.
CONCLUSION
The Administration recommends that the City Commission approve the proposed
ordinance on first reading and set a second reading public hearing for the March 21,
2012 meeting. This recommendation of approval is only for the very limited ordinance
before the Commission as written, and would not extend to any modification which would
expand the scope of the ordinance to other properties, which the Administration would
not recommend.
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City Commission Memorandum
Short term rentals
February 8, 2012 Page4
Pursuant to Section 118-164(3) when a request to amend the land development
regulations does not change the actual list of permitted, conditional or prohibited uses in
a zoning category, the proposed ordinance may be read by title or in full on at least two
separate days and shall, at least ten days prior to adoption, be noticed once in a
newspaper of general circulation in the city. Immediately following the public hearing at
the second reading, the city commission may adopt the ordinance. An affirmative vote
of five-sevenths of all members of the City Commission shall be necessary to enact any
amendment to these land development regulations.
JMG/JGG/RGUML
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"SHORT TERM RENTAL OF APARTMENT UNITS OR TOWNHOMES"
Flamingo Park Neighborhood
ORDINANCE NO.----
AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF
THE CITY OF MIAMI BEACH, FLORIDA, AMENDING THE LAND
DEVELOPMENT REGULATIONS OF THE CODE OF THE CITY OF
MIAMI BEACH, BY AMENDING CHAPTER 142 OF THE CITY
CODE, "ZONING DISTRICTS AND REGULATIONS," ARTICLE IV,
"SUPPLEMENTARY DISTRICT REGULATIONS," DIVISION 3,
"SUPPLEMENTARY USE REGULATIONS," BY AMENDING
SECTION 142-1111, "SHORT TERM RENTAL OF APARTMENT
UNITS OR TOWNHOMES," TO ALLOW AN EXTENSION OF TIME
FOR APPLICATIONS DUE TO GOVERNMENTAL ERROR;
PROVIDING FOR REPEALER, SEVERABILITY, CODIFICATION,
AND AN EFFECTIVE DATE.
WHEREAS, the City Commission has determined through the adoption of
ordinance no. 2010-3685, among other things, that there is a potential for harm if
transient rentals are permitted without regulations protecting against adverse
external effects of such use or prohibited in certain instances; that multifamily or
townhome unit owners' sense of community and privacy would be compromised by
unregulated and unrestricted commercial and transient use of units in multifamily
buildings and neighborhoods; that multifamily or townhome unit owners have
reasonable expectations of a community of permanent neighbors and owners and
the privacy such a community entails; that the privacy and ambience of such
multifamily or townhome residential buildings and areas are materially undermined
by unregulated and unrestricted transient rentals; that the values associated with
multifamily or town home residential areas can only be preserved by very limited and
controlled commercial and transient use of residences, if at all; and
WHEREAS, based upon the factors listed above, any relaxation of the current
land development regulations with respect to short term rentals in multifamily zoning
districts had to be limited in size and scope to specifically defined neighborhood
areas, and deemed that within the Flamingo Park and Espanola Way Historic
Districts, a limited number of short term rental uses, which can demonstrate a
current and consistent history of short-term renting, may be approved by the City
under certain specified conditions, if subject to regulation that would protect the
enjoyment, character and value of apartment or townhome residential
neighborhoods, buildings and units; and
WHEREAS, the City Commission found that such regulations are consistent
with and further the public health, safety and welfare of the City and adopted
Ordinance No. 2010-3685 on June 9, 2010 wherein short term rental of apartment units
or townhomes under certain specified conditions is permitted; and
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WHEREAS, an owner of a short term rental property in the Flamingo Park
neighborhood who otherwise qualified under the ordinance sought to apply for the
appropriate city licenses, but was denied the opportunity due to a license processing
error by a state governmental agency; and
WHEREAS, the amendment proposed herein is necessary to allow the
appropriate city licenses to be issued overcoming the other governmental license
error; and
WHEREAS, the City Attorney has opined that this amendment would not
jeopardize the status of City Ordinance 2010-3685 creating section 142-1111, which
was grandfathered under Section 509.032(7)(b), Florida Statutes (2011).
NOW, THEREFORE, BE IT ORDAINED BY THE MAYOR AND CITY
COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA:
Section 1. City Code Chapter 142, "Zoning Districts and Regulations," Article
IV, "Supplementary District Regulations," Division 3, "Supplementary Use
Regulations," Section 142-1111, "Short Term Rental of Apartment Units or
Townhomes" is hereby amended as follows:
Sec. 142-1111. Short Term Rental of Apartment Units or Townhomes.
* * *
(c) Time periods to apply for short-term rental approvals.
{1) Owners demonstrating compliance with subsections (b)(1) or (2) above,
shall apply for a certificate of use permitting short-term rental as detailed
in subsection 142-1111 (d) within a time period of six months from the
effective date of this section (June 19, 201 0}, or be deemed ineligible to
proceed through the process specified herein for legalization of short-term
rentals.
{2) Within three months of the effective date of the ordinance enacting this
section (June 19, 2010), eligible owners shall apply to obtain all
necessary approvals to comply with the Florida Building Code, Florida
Fire Prevention Code and with all other applicable life safety standards.
{3) Compliance with the applicable requirements of the Florida Building Code
and Florida Fire Prevention Code, shall be demonstrated by October 1,
2011, or rights to engage in short-term rental under this section shall be
subject to restrictions and/or limitations as directed by the building official
and/or fire marshal. This subsection shall not prevent these officials from
undertaking enforcement action prior to such date.
~) Applications under this Ordinance may be accepted until 60 days after
adoption of this subsection (insert date). upon demonstration to the
Planning Director that a government licensing error prevented timely filing
of the application.
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Section 2. Repealer.
All ordinances or parts of ordinances and all section and parts of sections in conflict
herewith be and the same are hereby repealed.
Section 3. Codification.
It is the intention of the City Commission, and it is hereby ordained, that the
provisions of this Ordinance shall become and be made part of the Code of the City
of Miami Beach, as amended; that the sections of this Ordinance may be re-
numbered or re-lettered to accomplish such intention; and that the word "ordinance"
may be changed to "section" or other appropriate word.
Section 4. Severability.
This ordinance is severable; if any provision hereof is held void or unconstitutional in
a final decision by a court of competent jurisdiction, the balance of the ordinance,
and the remainder of Ordinance 2010-3685 creating City Code section 142-1111,
shall remain valid.
Section 5. Effective Date.
This Ordinance shall take effect ten days following adoption.
PASSED and ADOPTED this __ day of ____ 2012.
ATTEST:
CITY CLERK
MAYOR
APPROVED AS TO FORM
AND LANGUAGE
0~ AND FOR EXECUTION
. J 131 JJ.2.
1 y Attorney~ ~
First Reading:
Second Reading:
Verified By:
Richard G. Lorber, AICP
Acting Planning Director
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