2008-3598 OrdinanceORDINANCE NO. 2008-3598
AN ORDINANCE OF THE MAYOR AND CITY
COMMISSION OF THE CITY OF MIAMI BEACH
AMENDING CHAPTER 142, "ZONING DISTRICTS AND
REGULATIONS," OF THE CITY CODE, BY AMENDING
DIVISION 2, "RS-1, RS-2, RS-3, RS-4 SINGLE-FAMILY
RESIDENTIAL DISTRICTS," BY ADDING NEW SECTION
142-109 ENTITLED "COMMERCIAL USE OF SINGLE
FAMILY HOMES PROHIBITED"; PROVIDING FOR
REPEALER, SEVERABILITY, CODIFICATION AND AN
EFFECTIVE DATE.
WHEREAS, the City's land development regulations ("LDRs") restrict
certain residential properties to residential and compatible accessory uses, and
commercial uses on such properties are prohibited, except that the LDRs allow
film and print permits, garage sales and home based businesses at such
properties; and
WHEREAS, the LDRs in section 114-1, define commercial uses as: "any
activity where there is an exchange of goods or services for monetary gain. Such
activities include but are not limited to, retail sales, offices, eating and drinking
establishments, theaters and similar uses."
WHEREAS, the Administration has reviewed these provisions, among
others, and interpreted them to provide that activities in single family homes
similar to those identified in the definition of commercial uses are prohibited by
the land development regulations. These types of activities include the owner
renting out his or her home for a party or event, or receiving other "monetary
gain" for such use of the home. They also include the offering for sale from the
home of goods, property or services by businesses that more appropriately
should be engaged in these activities in commercial zoning districts; and
WHEREAS, the Code Compliance Division has reported numerous
instances of residential properties being used as party houses, where the house
is used for a commercial enterprise for parties instead of as a single family
residential use; and
WHEREAS, when a single family residence is used as a party house, or
other form of commercial gathering, excessive numbers of guests, vehicles and
noise are generated, causing inappropriate adverse impacts on the surrounding
residences and residential neighborhood; and
WHEREAS, the City has a substantial interest in maintaining the
aesthetics, character and tranquility of its residential neighborhoods, as well as in
regulating traffic flow; this ordinance directly advances these interests; and this
ordinance is narrowly tailored to serve those interests; and
WHEREAS, such parties and commercial events are more appropriately
held in the commercial districts of the City at venues that are designed for such
numbers of persons, with the impacts resulting therefrom more appropriately
mitigated; and
WHEREAS, the City Commission recognizes that owners or lessees of
property often hold private parties where they or someone in their household will
receive gifts from attendees, and it is not the intent of this ordinance to, and this
ordinance does not, prohibit such gifts when the gifts are not compensation for
the commercial use of the property, and not a required admittance fee, and such
parties are excluded from the definition of commercial use; and
WHEREAS, the City Commission recognizes that attendees of private
parties often bring food or beverages to assist in party planning or preparation,
and it is not the intent of this ordinance to, and this ordinance does not, prohibit
such bringing of food or beverages when they are not compensation for the
commercial use of the property, and not a required admittance fee, and such
parties are excluded from the definition of commercial use; and
WHEREAS, the City Commission recognizes that the individual casual
sale of personal property to or from visitors to the property or through the Internet
does occur, and it is not the intent of this ordinance to, and this ordinance does
not, prohibit such casual sales.
WHEREAS, Code Compliance has also reported that houses for sale are
also being used for the advertising of various commercial products, which are
sometimes displayed to and visible to the public street in front of the house; and
WHEREAS, the City Commission finds that open houses for the purpose
of promoting the sale or lease of a single family residence to potential buyers or
renters are uses that may be permitted in single family neighborhoods if
regulated to minimize their adverse impacts; and
WHEREAS, while residents are entitled to enjoy the use of their single
family homes consistent with the applicable regulations in the single family
residential districts, in order to ensure and protect the enjoyment, character and
value of the single family residential neighborhoods and homes, the provisions
herein are hereby adopted; and
WHEREAS, this proposed ordinance seeks to codify the Administration's
interpretation and to provide a structured framework for enforcement of the
interpretation.
NOW THEREFORE, BE IT ORDAINED BY THE MAYOR AND CITY
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COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA:
Section 1. That Section 142-109, "Commercial Use Of Single Family Homes
Prohibited," of the Miami Beach City Code, is hereby created as follows:
Sec. 142-109. Commercial Use Of Single Family Homes Prohibited.
(a) Intent and Purpose:
The land development regulations restrict residential properties to residential and
compatible accessory uses. Commercial uses on residential properties are
prohibited, with limited exceptions. While residents are entitled to enjoy the use
of their property consistent with the applicable regulations, in order to ensure and
protect the enjoyment, character and value of residential neighborhoods and
buildings, the provisions herein are established.
(b) Definitions:
"Use of residential property" or "use of the property" in this ordinance shall mean
occupancy of residential property for the purpose of holding commercial parties,
events, assemblies or gatherings on the premises.
(c) Regulations:
(1) Accessory use of residential property shall be deemed commercial and
not permitted, except as otherwise provided for in the Code, if:
a. Compensation to Owner. The owner, lessee or resident receives
payment or other consideration, e.g., goods, property or services, in
excess of $100 per party or event for the commercial use of the
property, including payment by any means, direct or indirect, including
security deposits; or
b. Goods, property or services offered or sold. Goods, propert r~or
services are offered for sale or sold on or at the property, during use of
the property; however, this subsection shall not apples
All of the goods, property or services offered are donated to or
for charitable, religious or political organizations or candidates for
public office, that have received 501(c)(3) or other tax exempt status
under the U.S. Internal Revenue Code, as amended. or in accordance
with applicable election laws; or
All of the proceeds from sales are directly payable and paid to
charitable, religious or political organizations or candidates for public
office, that have received 501(c~(3) or other tax exempt status under
the U.S. Internal Revenue Code. as amended, or in accordance with
applicable election laws. An organization or candidate may reimburse
donors for goods or property donated; or
(iii) The sale is of the property itself or personal property of the
owner or resident (excluding property owned by a business), and if
publicly advertised, comply with subsection (3) below.
iv) Notwithstandina the restrictions in subsections (1)b(i)-(iii
limited commercial use of the property by the owner or resident for the
sale of goods, property or services shall be allowed under the following
criteria. The event:
A. Is by private invitation only, not publicly advertised;
B. Creates no adverse impacts to the neighborhood;
C. The activity and its impacts are contained on the property;
D. Parking is limited to that available on-site, plus eleven (11)
vehicles legally self-parked near the property, with no busing
or valet service; and
E. Frequency is no greater than one event per month; or
c. Admittance fees. Use of the property by attendees requires an
admittance or membership fee or a donation, excluding donations
directly payable and paid by attendees to charitable, religious or
political organizations or candidates for public office, that have
received 501(c)(3) or other tax exempt status under the U.S. Internal
Revenue Code, as amended, or in accordance with applicable election
laws.
Signs or Advertising. Signs or other forms of advertising in connection
with goods, property or services offered in connection with commercial
use of the property, including the actual goods, property (except real
property and structures thereon) or services, shall not be visible from the
public right-of-way. This section shall not be construed to~rohibit the
display of real estate for sale or lease signs for the property. Advertising
that promotes activities that violate this ordinance shall be deemed a
violation of the ordinance, with such violations determined per event and
not per advertisement.
(3) Real Estate Open Houses. The following events are permitted: Open
houses (open to the public) organized for the purpose of promoting the
sale or lease of the residence where the open house is located to
potential buyers or renters, or events organized by the listing agent limited
to licensed real estate brokers and/or agents, subject to the following
b. No charging admittance fees.
c. Events described in this subsection must end by 8:00 p.m
(d) Enforcement:
(1) Violations of this section shall be subject to the following fines The
special master may not waive or reduce fines set by this ordinance.
a. If the violation is the first violation: $2,500.00;
b. If the violation is the second violation within the preceding 18
months: $7,500.00;
c. If the violation is the third violation within the precedincL 18
months: $12,500.00;
d. If the violation is the fourth or greater violation within the
preceding 18 months: $20,000.00.
Fines for repeat violations shall increase regardless of location.
(2) In addition to or in lieu of the foregoing, the City may close down the
commercial use of the property and/or seek an injunction against activities or
uses prohibited under this section.
(3) Any city police officer or code compliance officer may issue notices for
violations of this ordinance, with alternative enforcement as provided in
section 1-14 and Chapter 30 of this Code. Violations shall be issued to the
homeowner, and/or to any realtor, real estate agent, real estate broker, event
planner, promoter, caterer, or any other individual or entity that facilitates or
organizes the prohibited activities. In the event the record owner of the
property is not present when the violation occurred, a copy of the violation
shall be provided to such owner.
(4) Charitable, religious or political organizations or candidates for public
office shall receive one courtesy notice in lieu of the first notice of violation
only, after which fines will accrue starting with the first violation as prescribed.
No courtesy notice in lieu of first notice of violation shall be available if a
courtesy notice in lieu of first notice of violation has already been granted in
the preceding eighteen (18~ month period, regardless of location.
(5) The City recognizes peoples' rights of assembly, free expression, religious
freedom, and other rights provided by the state and federal constitutions. It is
the intent of the City Commission that no decision under this ordinance shall
constitute an illeaal violation of such rights, and this ordinance shall not be
construed as such a violation.
(6) The city manager or designee may adopt administrative rules and
procedures to assist in the uniform enforcement of this ordinance.
~) No variances shall be granted from this section. This section does not
authorize commercial activities in residential neighborhoods that are otherwise
prohibited or regulated by applicable law, unless expressly provided for herein.
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. This ordinance does
not repeal or affect the opinion of the Planning Director that prohibits the rental
for less than six months of single- or multi-family residences in any district that
does not expressly authorize such transient occupancy.
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
renumbered or relettered to accomplish such intention; and that the word
"ordinance" may be changed to "section" or other appropriate word.
SECTION 4. Severability.
If any section, subsection, clause or provision of this Ordinance is held
invalid, the remainder shall not be affected by such invalidity.
SECTION 5. Effective Date.
This Ordinance shall take effect ten days following adoption.
PASSED and ADOPTED this 13th day of February, 2008.
~ ~
ATT ST:
M YOR
~~,~ ~(~~~.- Matti H. Bower
CfTY CLERK
Robert Parcher
First Reading: January 16, 2008
Second Reading: February 13, 2008
Verified by:
APPROVED AS TO
FORM AND LANGUAGE
~~ & FOR EXECUTION
Attorney Date
ge~3: Gdmez, AICP
nning Director
Undersc~'e denotes new language
T:WGENDA\2008\February 13\Regular\Comm Use Sngl Fam home ORD Second Reading as amended FINAL.doc
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COMMISSION ITEM SUMMARY
Condensed Title:
An Ordinance Of The Mayor And City Commission Of The City Of Miami Beach Amending Chapter 142, "Zoning Districts And
Regulations," Of The City Code, By Amending Division 2, "Rs-1, Rs-2, Rs-3, Rs-4 Single-Family Residential Districts," By Adding
New Section 142-109 Entitled "Commercial Use Of Single Family Homes Prohibited"; Providing For Repealer, Severability,
Codification And An Effective Date,
Intenaea outcome 5u
Increase satisfaction with neighborhood character.
Supporting Data (Surveys, Environmental Scan, Etc. Residents identified addressing noise as one of the changes that would
make Miami Beach a better place to live, work, play or visit. Residents in South Beach had the second lowest percentage of all
resident groups that felt that the amount of noise in their neighborhood on a typical day was the right amount (67%), but had the
highest percentage (23%) of residents indicating traffic is the main reason for the noise. In addition, 67% of residents in South
Beach felt that parking availability was too little or much too little.
Issue:
Shall the Mayor and Commission approve on second reading an ordinance that amends the existing Land Development
Re ulations to re ulate commercial activities in sin le famil residential districts?
Item Summar /Recommendation:
SECOND READING PUBLIC HEARING
The land development regulations define, in section 114-1 of the City Code, "commercial uses" as "any activity where there is an
exchange of goods or services for monetary gain." Such activities include but are not limited to, retail sales, offices, eating and
drinking establishments, theaters and similar uses." The regulations for single family residential zoning districts, RS-1, RS-2, RS-3
and RS-4, provide in section 142-101, "Purpose," that the districts "are designed to protect, and preserve the identity, image,
environmental quality, privacy, attractive pedestrian streetscapes, and human scale and character of the single-family
neighborhoods and to encourage and promote new construction that is compatible with the established neighborhood context."
Section 142-102 requires that the only main permitted uses in these districts be single-family detached dwellings. Sections 142-104,
"Accessory Uses" and 142-905, "Permitted accessory uses in single-family districts," only permit accessory uses to be those
customarily associated with single family dwellings, listed as "decks, swimming pools, spas, ornamental features, tennis courts," and
family day care facility, guest quarters and home based businesses.
The Administration has reviewed these provisions, among others, and interpreted them to provide that activities in single family
homes similar to those identified in the definition of commercial uses are prohibited by the land development regulations. These
types of activities include the owner renting out his or her home for a party or event, or receiving other "monetary gain" for such use
of the home. They also include the offering for sale from the home of goods, property or services by businesses that more
appropriately should be engaged in these activities in commercial zoning districts. This proposed ordinance seeks to codify the
Administration's interpretation and to provide a structured framework for enforcement of the interpretation.
It is a fundamental expectation, as well as a zoning requirement, that the single family designation serve to promote and protect the
nature of the residential neighborhood and typical residential use, not these types of commercial uses.
It is recommended that the Ma or and Commission a rove the item on second readin .
Advisory t3oard Recommendation:
On May 8, 2006, the Land Use and Development Committee (LUDC) forwarded the proposed ordinance for community input. The
proposed ordinance was subsequently referred to Planning Board (PB) for review at their meeting of November 28, 2006. The PB
forwarded the proposed ordinance to Commission with recommended amendments. The proposed ordinance and PB
recommendations were considered by LUDC on December 11, 2006, with proposed revisions made to adopt the PB
recommendatoins. The LUDC forwarded the proposed ordinance to the Commission with additional changes. The ordinance was
approved on first reading on January 17, 2007, and referred back to LUDC for additional review. Changes were recommended at
LUDC relating to charitable events. The item was opened and continued on second readin .
Financial Information:
Source of # Amount Match Amount /Source
Funds:
1
City staff currently monitors potential commercial uses. Additional costs to engage in research to support any investigation of a
violation may occur; those costs are unknown at this time. However, it should be noted that the City incurs expenses at this time
.associated with the replacement of damage to Swale and other ri ht-of-way improvements.
City Clerk's Office Leg'slative Trac
Hilda M. Fernandez, Asst. City Manager
Sign-Offs:
Department Director ~ %
T:WGENDA\2008\February 13\Reg
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nt City Manager _I City Manager
ngl Fam hone
AGENDA ITEM I?S E
>~ATE Z ° 1.x...4 ,t•
m MIAMI BEACH
City of Miami Beach, 1700 Convention Center Drive, Miami Beach, Florida 33139, www.miamibeachfl.gov
COMMISSION MEMORANDUM
TO: Mayor Matti H. Bower and Members of the City commission
FROM: Jorge M. Gonzalez, City Manage .
DATE: February 13, 2008 SECOND READING
PUBLIC HEARING
SUBJECT: AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI
BEACH AMENDING CHAPTER 142, "ZONING DISTRICTS AND REGULATIONS," OF
THE CITY CODE, BY AMENDING DIVISION 2, "RS-1, RS-2, RS-3, RS-4 SINGLE-
FAMILYRESIDENTIAL DISTRICTS," BY ADDING NEW SECTION 142-109 ENTITLED
"COMMERCIAL USE OF SINGLE FAMILY HOMES PROHIBITED"; PROVIDING FOR
REPEALER, SEVERABILITY, CODIFICATDN AND AN EFFECTIVE DATE
ADMINISTRATION RECOMMENDATION
Approve the ordinance on second reading.
BACKGROUND
The land development regulations define, in section 114-1 of the City Code, "commercial uses" as "any
activity where there is an exchange of goods or services for monetary gain. Such activities include but are not
limited to, retail sales, offices, eating and drinking establishments, theaters and similar uses." The regulations
for single family residential zoning districts, RS-1, RS-2, RS-3 and RS-4, provide in section 142-101,
"Purpose," that the districts "are designed to protect, and preserve the identity, image, environmental quality,
privacy, attractive pedestrian streetscapes, and human scale and character of the single-family
neighborhoods and to encourage and promote new construction that is compatible with the established
neighborhood context." Section 142-102 requires that the only main permitted uses in these
districts be single-family detached dwellings. Sections 142-104, "Accessory Uses" and 142-905, "Permitted
accessory uses in single-family districts," only permit accessory uses to be those customarily associated with
single family dwellings, listed as "decks, swimming pools, spas, ornamental features, tennis courts," and
family day care facility, guest quarters and home based kalsinesses.
The Administration has reviewed these provisions, among others, and interpreted them to provide that
activities in single family homes similar to those identified in the definition of commercial uses are prohibited
by the land development regulations. These types of activities include the owner renting out his or her home
for a party or event, or receiving other "monetary gain" for such use of the home. They also include the
offering for sale from the home of goods, property or services by businesses that more appropriately should
be engaged in these activities in commercial zoning districts. This proposed ordinance seeks to codify the
Administration's interpretation and to provide a structured framework forenforcement of the interpretation.
It is a fundamental expectation, as well as a zoning requirement, that the single family designation serve to
promote and protect the nature of the residential neighborhood and typical residential use, not these types of
commercial uses.
RECAP -NATURE OF THE PROBLEM
The attached article from BizBashFla (AttachmentA) illustrates the appeal ofthese large single family homes
for this commercial uses (note: BizBash is a national web site/resource for event and meeting planners). The
Page 2 of 7
Commercial Use of Single Family Home
article references the use of private homes for promotional and specialevents. While events are known to
occur during non-major event periods, even on weekdays, historically there has been an increased number
scheduled around major event weekends, such as the last Super Bowl, the annual Winter Music Conference,
Art Basel Miami Beach and the Boat Show, to name a few. As demonstrated in the attachments to the
agenda item on January 16, 2008, these parties at private residences (such as the Star Island location
referenced) often compete with events at popular, large nightclubsand other assembly venues in the City.
Also at the time of the first reading, the administration provided, for illustrative purposes, a sampling of parties
held in single family homes, including examples of events held during the Boat Show in 2005 (presented by
International Yachtsman Magazine, with additional sponsors Tiffany, Mercedes, Bacardi, etc.; as well as an
invitation for an event coordinated by Land Rover that had been scheduled for a private home on San Marino
Island. These events (similar to others that we have identified) served exclusively to launch particular
products on behalf of large commercial entities, with the homes rented for purposes of hosting the events.
In addition to the prohibition of the commercial use, the size and frequency of these private, commercial
parties often create a significant intrusion and undue burden on the surrounding residential neighborhoods.
These impacts have been discussed at Commission and Committee meetings and include, among others,
inadequate or illegal parking; increased vehicular traffic; Noise; Destruction/litter of the public right-of-way;
Higher than usual pedestrian traffic; Frequency of events; and demand on Staff resources. Examples of these
impacts, as well as the City's current efforts to mitigate these impacts, were included in the agenda item on
first reading, which is requested to be incorporated into the record. In addition, as previously noted, the Land
Use and Development Committee (LUDC) will be considering other options to address certain adverse
impacts from large assembly uses of single family homes. The development of options seeks a balance that
allows our residents the full enjoyment of their homes to which they are entitled, while addressing the
significant impact large events have on our residential neghborhoods.
RECAP -CURRENT PROCESSES
The Code Compliance Division has been proactive in identifying and responding to events that appear to
have a commercial intent and characteristic, and have issued violations as appropriate. Internal processes
are in place and have been adjusted as needed to ensure that information is shared among City departments
that are advised of events that require City support (valet approval, off duty police, etc), to determine if they
meet the commercial use standard. For example, regular notification is made to all involved departments
(Parking, Neighborhood Services/Code Compliance Division, TCD/Film and Special Events Division, Police,
etc.) of all requests for valet permits, off-duty police, fireworks, etc., related to events at a single family home.
In addition, the Code Compliance Division regularly conducts web searches to identify homes being used for
commercial purposes, with efforts increased during major events periods. When clearly prohibited events
have been identified, the Administration has provided notice to the homeowner, and has ensured that the
event is closed down and/or has issued the appropriate violation. Violations are issued pursuant to section
114-4(1) and (3) of the Code, which refers to uses not permitted in specific districts. In addition, injunctive
relief has been requested and granted with assistance from the City Attorney's office. The past year has
included adjudications for homeowners who received violations for commercial use of single family homes, as
well as preventing several illegal events from occurring. The determination to request that an event notbe
held is done after significant due diligence by staff to ensure there is sufficient evidence of a commercial use.
When sufficient evidence cannot be obtained, it has been past practice to permit an event to occur. However,
it should be noted that violations can and have been issued after events when documentation supports that
an illegal, commercial event has occurred.
LEGISLATIVE HISTORY
The item was initially referred for discussion in 2006 to the LUDC following resident complaints to the City
regarding large parties held in these residential neighborhoods where it was believed that the home was
rented to a third party, or payment or other consideration was otherwise given to the homeowner, for the use
of their home for the event. In some instances, these events were advertised and open to the general public,
often for paid admission. While some residences were believed to be used for this purpose on a regular
basis, other homes were being offered for commercial or business promotional purposes, such as product
launches. In addition, there were concerns raised that on some occasions the use of a private single family
home for a charitable purpose (e.g. to benefit a charitable cause) was used as a mechanism to camouflage a
Page 3 of 7
Commercial Use of Single Family Home
commercial event, or the frequency of the charitable events at a particular home was adversely impacting
residential neighborhoods. It should also be noted that concerns were also raised about real estate open
houses that assumed a commercial nature with the inclusion of sponsored activities
Because this is an amendment of the Land Development Regulations, the ordinance considered on January
17, 2007 was previously referred by the Commission to the Planning Board for their review and consideration.
The Planning Board discussed the item during their meeting of Tuesday, November 28, 2006, and a public
hearing on the matter was held. Numerous members of the public were present and spoke. The item was
moved by the Planning Board for consideration by the Commission with specific recommendations; those
recommendations were considered by the Commission at its meeting on January 17, 2007, and incorporated
accordingly. The proposed ordinance is substantially the same as the ordinance approved by the Planning
Board and/or less restrictive than the ordinance they initially considered.
Following Committee review and input, on January 17, 2007, the Mayor and City Commission considered and
approved on first reading a proposed amendment to the Land Development Regulations relating to the use of
single family residences for commercial activities. The item elicited significant interest from members of the
public. At that time, the item was referred to the LUDC for additional review prior to its consideration at
second reading, including further discussion relating to parking impacts and the use of single family homes
for charitable events, as well as other comments made during the first reading. Following LUDC review, the
item was opened and continued on second reading in March, April, May, July and October.
Due to the time elapsed between first and second reading, and to ensure that sufficient public notice was
provided to all interested parties, on January 16, 2008 the Commission approved on first reading an
ordinance that would amend the Land Development Regulations to prohibit the commercial use of single
family homes, except for commercial uses already permitted in the code, and scheduled a second reading,
public hearing. That first reading ordinance focused on the issue of commercial uses, as non-permitted uses.
In order to address the impacts created not just from illegal commercial events, but also large private events
at single family homes, the Commission referred a discussion on potential amendments to the parking
ordinance to the LUDC; referred a discussion on short term rental of single family homes to the LUDC; and
referred proposed additional amendments to the land development regulations to the Planning Board.
PROPOSED ORDINANCE
The proposed ordinance has been developed to further define and address the major issues surrounding the
commercial use of single family homes, and is designed to focus this ordinance specifically on the issue of
commercial uses of private homes, respond to concerns relating to the ordinance being overbroad and
provide a framework for the City to address this concern. The City has already established criteria for certain
non-residential uses of single family homes (e.g. film and print shoots, garage sales, etc.); those authorized
commercial activities are not affected by the proposed ordinance
As mentioned during the Commission meeting of January 16, 2008, the proposed ordinance approved on first
reading on January 16, 2008 contained most of the significant components of the item approved on January
17, 2007, except additions, deletions or changes as noted below.
• Section 142.109 (a) Intent and Purpose: Clarifying language is incorporatedinto the paragraph.
• Section 142.109 (b) Definitions: This has been added to provide a definition for "use of residential
property" and "use of property"
• Section 142-109 (c) Regulations: This section has been further defined and streamlined to focus on the
primary issues relating to commercial use. As stated, any payment or other consideration (to include
goods, property or services) provided to the homeowner for the use of the property would constitute a
commercial use. An amount of $100 has been established as a threshold.
• Charitable, political and religious events: The ordinance approved on January 17, 2007 created specific
requirements for the use of a home by a charitable or fundraising organization, as well as incorporating
voluntary noticing of large political gatherings and political fundraising events, premised on the impact of
these events on the neighborhood. Options considered and discussed prior to and during last year's first
reading included limitations on the number of charitable events permitted in a calendar year, or
Page 4 of 7
Commercial Use of Single Family Home
establishing thresholds to determine which charitable events should be regulated (e.g. based on
occupancy, on parking availability, etc.). The inclusion of language was intended to - in addition to
responding to concerns regarding the frequency and impact of these typically large events -also address
concerns that while it is easy to identify charitable events when they are wholly sponsored and
coordinated by charitable organizations, there were occasions where commercial events included a
"charitable donation" in what was believed as an attempt to legitimize an otherwise commercial activity.
As you can note, the proposed ordinance does not include or recommend any restrictions or suggest
noticing, as these impacts can and should be addressed as we would impacts from any other large event.
However, it is important to clarify that while charitable, political and religious social events in single family
homes are not considered commercial uses, any payment (or other consideration) to a homeownerforthe
use of their home for the charitable, political or religious social event would constitute a commercial use.
In other words, the donation of the use of a home for a charitable, political or religious event would not
constitute a commercial activity; it would be a commercial activity if the home were "rented" or other
compensation was provided to the homeowner for the use of their home for the aforementioned activities.
Payments/donations to attend a charitable, religious or political social event must be made to the
charitable, religious or political organization or candidate. The proposed ordinance narrowlyfocuses the
issue on whether an event is commercial. Rental of the home for a social event transforms the home into
the equivalent of a catering hall, which is notaccepted residential activity.
• Section 142.109 (c) 3 -Language is included to address the issue of signage and other advertising
relating to events on residential property.
• Section 142.109 (c) 4 -Open Houses: The proposed ordinance continues to incorporate specific
provisions for open houses. These are intended to address concerns with events that have been called
open houses, but have taken on the characteristics of commercial events. As noted, open houses could
not be held after 8:00 p.m.; this does not impact private showings. Language has been incorporated to
ensure that meetings of realtors at listed homes were not prohibited under this ordinance.
• Section 142.109 (d) Enforcement -the proposed ordinance continues to incorporate a specific fine
schedule that establishes certain fines for violations. As proposed, these fines cannot be mitigated or
waived by the Special Master if a violation of the ordinance is established. It should also be noted that
language remains so that violations may be issued to the homeowner, realtor, caterer, event planner or
anyone that facilities or organizes prohibited commercial uses of a home.
The level of the first violation is intentionally reduced to account for the possibility that the homeowner
was not aware of the City's regulations regarding commercial use. The proposed ordinance incorporates
a fine schedule with significantly accelerated fines. This is in response to continued comments from
residents regarding the necessity for a penalty schedule that would serve as a deterrent, especially when
it is speculated that many of the rental rates for these commercial activities generate far more in revenue
for the homeowner. As proposed, the initial fine would be $2,500, followed by a quickly increasing fine
schedule of $7,500 for a second offense in a calendar year; $12,500 for a third offense in a calendar year;
and $20,000 for fourth and subsequent offenses in a calendar year.
This section also provided for a courtesy notice for charitable, religious or political organizations for first
violations of the ordinance.
During the January 16, 2008 Commission meeting, the Commission made suggested modifications to the
proposed ordinance and referred the proposed ordinance to the LUDC prior to its consideration on Second
Reading on February 13, 2008, including a discussion on the fine/penalty schedule being proposed.
ADJUSTMENTS TO ORDINANCE SINCE FIRST READING
At the direction of the Commission during the first reading of the ordinance, the item was discussed at the
LUDC meeting of January 23, 2008, at which time the Committee members were presented with the
proposed ordinance reflecting the modifications approved by the Commission on January 16, 2008. These
modifications included:
• The term "commercial" added throughout the ordinance to clarify that we are referring to commercial
uses of single family homes.
Page 5 of 7
Commercial Use of Single Family Home
• Language clarifying the types of charitable, religious and/or political events not affected by certain
provisions of this ordinance was added. Specifically, charitable, religious and/or political
organizations that are recognized as tax exempt, or that follow applicable election laws, would be
exempt from Section 142-109 (c) (1) (b) (i-iii). However, other sections are applicable, such as the
prohibition for a charitable, religious and/political organization or candidate to pay for the use of the
property.
• New Section 142-109 (c) (1) (b) (iv), to address the Commission's desire to permit certain commercial
uses of a de minimis nature. The intent was to ensure that the typical Tupperware or Avon party
continued to be permitted, especially as these events are small in nature and generally have little to
no impact on the neighborhood. In developing this language, staff has been mindful of existing
provisions in our City Code relating to home-based businesses. A copy of Section 142-1411 - "Home
based business office" is provided for your reference (Attachment B). As included in Section 142-109
(c) (1) (b) (iv) of the attached ordinance, the sale of goods, property or services would be permitted,
as follows:
o Are private, by invitation-only events, not publicly advertised
o Present no adverse impact to the neighborhood, and all of the activities are completely
contained on the property. This would include no pedestrian overflow, etc.
o Parking for attendees is available on-site and/or legal self-parking does not exceed eleven
(11) vehicles legally parked adjacent to the property, with no valet or shuttling permitted (six
cars on two sides of street, less space for a driveway)
o The frequency is no more than one event per month
o All other provisions of the ordinance apply, including no payment/compensation forthe use of
the property, and no admittance fee charged. In addition, provisions delineated in (c) (2)
relating to signs and advertising, apply.
o No violation of the home-based business ordinance is permitted.
• Language added to Section 142-109 (c) (2) - "Signs or Advertising" to clarify that any penalties are
per event, not per sign.
• Anew Section 142-109 (c) (6) added to reflect that administrative rules and procedures may be
adopted to assist in the uniform enforcement of thisordinance.
• Adjustments to language as read into the record on January 16, 2008, such as amending subsection
(c)(1)b, "are offered for sale", to insert "or sold"; amending subsection (c)(1)b (i) to change "are
donated by" to "are donated to or for"; amending subsection (c)(1)b(iii) to read: "the sale is of the
property itself or personal property of the owner or lessee"; and amending subsection (c)(3) to
substitute "goods, property," for "products"
The LUDC accepted this additional language and, further, approved the fine/penalty schedule as proposed in
the ordinance submitted for first reading. As previously noted, the provision granting charitable, religious or
political organizations one courtesy notice in lieu of a first violation is included in the ordinance (Section 142-
109 (d) (4)). Further recommendations on this provision are noted below.
In addition, the Committee requested that staff meet with interested persons relating to their comments made
at the LUDC meeting. A meeting was held on January 29, 2008 with the attorneys that presented their
concerns at the Committee meeting, as well as residents from the Sunset I and II homeowners association.
The meeting provided a good opportunity for staff to hear the concerns of all parties and determine if
additional adjustments to the ordinance should be recommended, especially for purposes of providing clarity;
the attendance of all those present was greatly appreciated. Attachment C is the document provided to staff
by Attorney Alex Hecklerat the meeting, and that formed he basis of discussion for the meeting.
There were nine (9) specific items detailed in the letter from Mr. Heckler. The responses to the issues, and
any recommendations, are addressed below:
1) Enforceability - We do not recommend that a process be created requiring homeowners to provide
the City with any documentation relating to an event. A homeowner is free to contact the City for
clarification on this or any other ordinance, and we would continue to encourage that. Further, there is
no evidence that the City has preuously, or would in the future, "arbitrarily" shut down an event.
Page 6 of 7
Commercial Use of Single Family Home
2) Penalties -There are two specific recommendations: that the Special Master should be able to
mitigate the fines; and that any appeals of the Special Master are made to the Commission. In terms
of the latter, Chapter 30, the provision in the City Code relating to the Special Master, already
provides relief for any appeals of a decision of the Special Master. We do not recommend that
appeals be heard by the City Commission. In terms of the former, the currently proposed penalty
schedule provides for a lower fine on first violation than on subsequent violations to address the issue
of first-time offenders that presumably did not know of this ordinance. As the ordinance currently
provides for a waiver for charitable, religious or political organizations, then the violation would have
been issued for other commercial uses. Should the commission wish to consider any level of
mitigation, it would be recommended that it only be permitted for the first offense, and that a re-set of
the fine/penalty schedule then not occur for a period of (36) months (e.g. not permitting a mitigation of
another first offense for a period of 36 months). It should be noted that the residents present did not
recommend a mitigation of any fines, and indicated concerns with what they expressed was a fine
schedule that was still too low. It should also be noted that the current, proposed ordinance allows for
a reset of fines by calendar year. Guidance is requested from the Commission on whetherthis should
be adjusted to an eighteen (18) month rolling period.
3) Open Houses -The proposed ordinance does not impact private showings, or the ability for a
homeowner to host a private dinner party or social event relating to the sale of the home, but rather
focuses on the standard and widely known/accepted concept of an "open house" -namely, that it is
advertised as open to the public. As such, clarifying language has been added to this section of the
ordinance. Resident representatives at the meeting, who are also registered realtors, expressed no
concern with the Open House language, as Open Houses are traditionally concluded prior to 8:00
p.m.
4) Right of Assembly: Our legal department has approved the current language.
5) Connection to other ordinances -This is a matter relating to form; our legal department has approved
the current language.
6) Record owner not subject to enforcement for valid leasehold -While this was not discussed at length,
the ordinance as written references throughout the severability of responsibility. For example, 142-109
(c) (1) (a) references that compensation to the "owner, lessee or resident" for use of property is not
permitted. In addition, Section (d) (3) references that violations may be issued to "any other individual
or entity that facilitates or organizes the prohibited activities," which would include persons other than
the homeowner.
7) Charitable gifts may be paid back -While the reimbursement by the charity to a donor is not a
payment to the homeowner for the use of the property, we have added language in (142-109 (c) (1)
(b) (ii) to reflect that "An organization or candidate may reimburse donors for goods or property
donated."
8) Clarify the warning citation -All warnings, as well as violations, are tracked via the Code Compliance
Division's database system. However, please note that we have included language to clarify that a
courtesy notice in lieu of violation cannot be provided if a courtesy notice in lieu of violation has been
provided in the preceding 18 months.
9) Tupperware Parties -The intention of the language added is to address the occasional multi-level
marketing party. However, this language is not intended to circumvent the existing home-based
business ordinance. We believe the guidelines are intended to reduce adverse impacts. The number
of cars listed is consistent with ordinances in atleast five (5) other municipalities that have likewise
attempted to mitigate the impact from assembly uses in residential neighborhoods.
The staff was also provided a letter from attorney Richard Freeman with his observations and
recommendations relating to the ordinance (Attachment D). As you will note, these comments, among others,
focus mainly on adverse impacts created by commercial events in single family homes. As you are aware, the
LUDC will be considering options to address adverse impacts from assembly uses independent of this
ordinance. However, it is staff's continued position that the rental of a home for a commercial event, payment
to attend a commercial event or the sale/display of goods at an event, are not consistent with the character of
a single family residential neighborhood, regardless of theextent of adverse impacts.
Lastly, in staff's review of the ordinance in preparation for second reading, and in subsequent to comments
Page 7 of 7
Commercial Use of Single Family Home
made by both the attorneys as well as the residents at the meeting, the following adjustments to the
ordinance have also been made:
• Added additional "whereas" clauses and/or provided additional language for "whereas" clauses;
• The term "during the use of the propert~l' was added to Section 142-109 (c) (1) (b) for clarity;
• Section 142-109 (c) (1) (b) (i-iii) and (c) (1) (c) -the term "or candidates for public office" was added
to all references to exemptions applicable for "charitable, religious and political organizations." In
addition, the term "or in accordance with applicable election laws" was also added to these sections
for further clarification;
• Language addressing the concern relating to the reimbursement of donors for goods and services
has been added to 142-109 (c) (1) (b) (ii);
• Language has been added to 142-109 (c) (1) (b) (iii) to clarify what may be sold by a resident, to
address concerns relating to classified ad sates, etc. during a use of the property.
• Clarifying language was provided for 142-109 (c) (1) (b) (iv) to ensure we have addressed the intent of
this section, which is to provide for certain commercial sales when there is a de minimis impact.
Again, the rental of the home or the charging of an admittance fee for this type of an event would be
considered a violation of the ordinance.
• Clarifying language was added to Section 142-109 (c) (2) to limit the placement of actual goods and
property where they can be observed from the public rightof-way;
• Language was added to 142-109 (c) (3) - "Open Houses" to clarify that we are referring to standard
open house that is open to the public. In addition, 142-109 (c) (3) (c) clarified that events had to
conclude by 8:00 pm
• The fine and penalty schedule currently remains as presented at first reading. However, guidance is
requested on two issues: whether mitigation of fines should be permitted, and whether the fines
should reset in a rolling manner, and with a longer time frame
o Mitigation of fines by Special Master: as previously noted, it has been the recommendation of
staff that no mitigation be available, especially as the first fine is a smaller amount than
subsequent fines. However, if the Commission wishes to consider mitigation, then it would be
recommended that it only be allowed for the first violation, and only if the first violation did not
occur within at least 36 months of a priorviolation.
o The ordinance currently provides that the fine and penalty schedule resets every calendar
year. When addressing the noise ordinance, there was much discussion about the calendar
year re-set, with a conclusion to have the fine schedule be "rolling" every 18 months. This
option is proffered for your consideration. Please note that if mitigation is considered for a first
violation, we are recommending that the period be doubled to 36 months before mitigation can
be considered on a first violation again.
• We have included language to clarify that a courtesy notice in lieu of violation cannot be provided if a
courtesy notice in lieu of violation has been provided in the preceding 18 months.
• We have added language in 142-109 (e) referencing the applicability of existing laws.
FISCAL IMPACT:
City staff currently monitors potential commercial uses. Additional costs to engage in research to support any
investigation of a violation may occur; those costs are unknown at this time. However, it should be noted that
the City incurs expenses at this time associated with the replacement of damage to swale and other right-of-
way improvements.
CONCLUSION
The intent of this proposed ordinance is to strike a balance between the rights of our residents to the
enjoyment and use of their homes, while protecting the residential character of the City's residential
neighborhoods. The proposed ordinance addresses the primary issues relating to the commercial use of
single family homes, implements a fine schedule to serve as a deterrent to the use of single family homes for
commercial purposes and clarifies certain permitted commercial and non-commercial uses.
T WGENDA\2008\February 13\Regular\Comm Use Sngl Fam home MEMO 2st rdg 2 13 08.doc
BiZBashFla: Ideas and Resources for Special Events and Meetings
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IDEAS AND RESOURCES FQR SPECIAL EVENTS AND NEETIN6S Thursday 08AE.Db 8:40PM
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Private Mansions Suggest Prestige
With so many cool spaces in Florida, how does one find just the right place to
impress corporate clients and guests? When it really counts, and you need more
than a hotel, restaurant or even a yacht, try the current hot spot: a private mansion.
Many event professionals find these spaces to be unique, stylish and clandestine.
Often, these mansions are located on private islands such as La Gorce, Star,
Hibiscus and Fisher Islands, or in upscale neighborhoods, adding to the grandeur of
the overall event. More than ample space helps to encourage multiple themes,
moveable feasts or a different d8cor or color scheme per room. And since most offer
lavish pools, balconies and tertacea, the party can spill over to the outdoors.
The Winter Party, one of South Florida's most visible events far the gay community,
Florida RSS Feed
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MY'~ooI. holds a private cocktaU party each year as pert of the weeklong fastivfUes. This year,
a committee co~citair knew the owner of a luxurious home on Pina Tree Drive, a ritzy
Ail BiZBash RSS Feed street in Mia The owner agreed to donate the home to serve as the private
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x'~'"""-'r t venue Ili Hu ins. ne of the event planners for Winter Parry, has been
produc n ergs-sca a events in private homes for severe) years in California, relying
on friends and word of mouth to secure the exclusive locations. "Often, the owners
wilt want to show off their homes or art coilectiona, and they feel a sense of pride in
` knowing that they're contributing to a cause," he said. The Winter Party private
cocktail party featured a pool lwy, male models in bikinis, a jazz band and art which
we -llsingthe private home created a very intimate feel "sal tsa Palley
o al mote She worked closely with the Winter Party committee o n u
the right venue.
On the same street, Villa Vecchia has been home to fashion shows for many
designers Including Jean Paul GaulUer and Luca Luca. Marysol Patton of the
Patton Group plans all of the fashion industry events that take place at Villa
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Vecchia, which a close friend-who happens to own the home-grac
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of style.
• Pete Dtaz Productions
• Designs by Sean
• Parafernalia Productions
• Room Service
• DECO Productions
• EventSource internatlonat
• Unique Option LLC
• Wizard Connection Inc.
• conceptBAiT Inc.
BECOME A MARKETING PARTNER
[ittt°;REwsa
• ActivlUes/ExpeHences
• CateringiFood Services
• DecoNDesignlFlowers
• Entertainment
• Event Planning S MarkeUng/MeeUng
PtanninglPR
• Event ProductionlAudlovlsual Services
• GIfts/Premiums/Awards
• Hotel AccommodaUOna
• Industry Resources
• InvttaUona/SignagelPrinting
• PhotogrephyMdeography
• Planning ToolslSoftware
• Rentals/Props
• SecuritylFire Servicesflnsurence
• Staffing
• Trade Show Services
• Trenaportatlon
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Vanessa Lopez of the~~A9ee~_n_ccYY says using exclusive Villa Ferrari on Palm Island
for an InternaHona! aYcFitsman magazine party allowed her to create three
different areas. "One area provided an amazing nighttime view, an indoor area and
one that showcased various Hosts," she said. "There was a Latin jazz band and
violinists set up throughout" She adds that it was a great way for advertisers to
participate; for example, a cigar company who advertises in the magazine set up a
cigar-rolling station in one of the empty rooms. The International Yachtsman party,
which took place during the Mlaml International Boat Show, had a dock in the
back where two mega-yachts were docked and open for patrons to peruse and
potenttaliy buy. By utilizing mansions, which are also often up for sale, events can
do double duty as real estate open houses. But obtaining a mansion isn9 as simple
as it sounds. "We do need to be somewhat discerning "said tan c reactor
and partner of Majestic Properties, which lists Ville Ferrari. ach week we get
offers for film and music video shoots, or to rent the space for charities and special
events. We have to make sure the event matches the image of Villa eF re'~ri."-
Naturally, the owner must trust the agent to rent to the right people for the right
reasons. There is always risk of damage. But once scored, k is a planner's paradise.
Usually unfurnished, plannere and designers have carte blanche to build from the
ground up-from furniture and d9cor to sound systems and lighting. "Usually there
are high-end vendors Involved," McMEnn adds. "it really behooves the sellers of the
house as well as the planners to be associated with high-end names and places."
-Charfla Orllz
SEND THIS STORY TO A FRIEND
MORE EVENT REPORTS
mhtml: file://C:\Documents%20and%20Settings\mazgie\M~~i~lODocuments\MW\PHS%20Board\Rentals\...
9/14/2005
165
Palm Island, was used for the
InfemaUonal Yachtman magazine
Villa Ferrell was used to keep
guests moving throughout the
property.
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parties? Check this out: {. ~ ~`~``~'
This weekend, starting on Thursday, ~~.
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giving away guest list passes to the top
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celebrity parties this weekend. They're ~_:;:°~
giving out a pair of passes every half hour
from Thursday to Saturday, 2pm to 7pm, ~ ~' i
{ in the adidas Originals store (226 8th St @
Collins). That means a lot of chances to ~r~~ ~~
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August 23, 2005 in VMAs ~ Permalink ~ l
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Ion Henri Pervilhac
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.• i~~antickets.com :.
Fernandez, Hilda
From: noisecontrol [noisecontrol@the-beach.net]
Sent: Wednesday, August 24, 2005 12:24 AM
To: margie Willensky; Sklar, Max; Guzman, Vivian; Mazer, James; Lorber, Richard
Cc: Fernandez, Hilda
Subject: commercial uses at 35 North Hibiscus .,,,
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....~,...,w.
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is Willcall -Pick up tickets at event (Free)
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8/24/2005
281
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ATTACHMENT B
Sec. 142-1411. Home based business office.
(a) Notwithstanding any provision to the contrary herein contained, offices for certain
businesses, professions or occupations may be maintained within residentially zoned
areas as provided herein. Any person engaged in a business, profession or occupation
who chooses to conduct said business, profession or occupation from his or her
personal, permanent, primary residence shall, prior to conducting such business,
profession or occupation, apply for and receive an occupational license for a home
based business office. Said applicant shall list his or her home address as a place of
business and must, at all times, comply with the following criteria:
(1) Home based business office activities shall be accessory and clearly incidental to
the primary single family residence or apartment unit.
(2) Home based business office activities shall occur entirely within the single family
residence or apartment unit.
(3) Employees, in addition to the person engaged in the business, profession or
occupation of the home based business office as provided above, shall reside at
the subject single family residence or apartment unit as a permanent resident;
for purposes of this section, a "permanent resident" shall mean a person residing
in a single family residence or apartment unit for no less than six months per
calendar year.
(4) No goods or services shall be dispensed, sold, distributed or provided directly
from the single family residence or apartment unit, except for those transmitted
by telephone, computer modem, facsimile or other similar electronic means, with
the exception of one business pickup by courier per day in addition to regular
U.S. Postal Service. Bulk mailing shall not be allowed.
(5) The aggregate of deliveries of any kind required by, received by, or made in
connection with a home based business office at a single family residence or
apartment unit shall not exceed one business delivery by courier per day in
addition to regular U.S. Postal Service.
(6) No inventory or storage of materials, goods, products or supplies shall be
permitted at the single family residence or apartment unit, except those minor
supplies necessary for the operation of the home based business office.
(7) No materials, goods, products or supplies shall be displayed for sale or kept as
samples at the subject single family residence or apartment unit, except those
which can be readily transported in a hand carried sample case.
(8) No customer, client, business associate, sales person, assistant or other
nonresident shall be permitted to visit the home based business office for
purposes of transacting business.
(9) The exterior of the single family residence or apartment unit shall not be altered
in any manner to attract attention to the home based business office or the
residence as a place of business.
(10) No signs indicating the presence of the home based business office shall be
located on or about the single family residence or apartment unit.
(11) No noise, odor, smoke, hazard or other nuisance of any type shall arise from the
conduct of the home based business office.
(12) The operation of a home based business office shall not cause any increase in
parking at the single family residence or apartment unit or vehicular traffic to and
from the single family residence or apartment unit.
(13) No vehicle with the name of a home based business office business shall be
parked or stored on the site, except in a closed garage.
(14) The conduct of a home based business office shall not result in an increase in
demand on city services as compared to the average typical residence of the
same size.
(15) Home based business office activities may be advertised or publicized provided
that the address of the single family residence or apartment unit shall not be
referenced, and further provided that any advertisement or publication shall not
in any manner invite, attract or draw persons to the single family residence or
apartment unit in which the home based business office is located.
(b) A home based business office which does not satisfy all of the above standards at all
times during operation shall be prohibited and no license shall be issued to an applicant
whose business operation would violate said standards.
(c) All home based business offices shall be required to obtain and maintain an
occupational license from the city, at an annual fee of $25.00.
(d) The city, upon probable cause to believe that there is a violation of one or more of the
provisions of this section, may seek permission from the code compliance special
master to inspect a property in order to assist in making a finding as to whether or not
there is a violation; the city shall not inspect a property without the aforedescribed
permission.
(e) A home based business office shall have no parking requirement in addition to the
requirement for the single family residence or apartment unit.
(f) Nothing contained herein shall be deemed to authorize, legalize, or otherwise permit a
home based business office that is otherwise prohibited by a legally enforceable
restrictive covenant, association document or other instrument or restriction on such
use.
(Ord. No. 98-3109, § 3(6-221.), 5-20-98)
Secs. 142-1412--142-1420. Reserved.
ATTACHMENT C
S_H~L TATS
BOWEN
LLP
ATTORNEYS AND COUNSELLORS AT LAW
ALEXANDER P. HECKLER
Member Florida Bar
(954) 847-3858 Direct Telephone
(954) 527-7958 Direct Facsimile
January 29, 2008
VIA HAND DELIVERY
Ms. Hilda Fernandez
City of Miami Beach
1700 Convention Center Drive
Miami Beach, FL 33139
Re: Miami Beach "Commercial Use" Ordinance
Dear Ms. Fernandez:
E-MAIL ADDRESS:
aheckler@shutts.com
Thank you for your dedicated and deliberate efforts to include. our organization and
feedback into the review process for the City's proposed "Commercial Use" ordinance. We have
reviewed the most recent draft of the ordinance, and are pleased that the City addressed so many
of our concerns in the current version. Specifically, we are delighted that the City has clarified
that gi$s and other customary exchanges are not "commercial" transactions in and of themselves
in connection with social gatherings. Likewise, we see significant improvements related to the
sale of personal property, advertising and other areas of concern we expressed heretofore.
The purpose of this letter is to briefly touch on our remaining areas of concern in the
hopes that the final ordinance will be effective at eliminating "party houses" while at the same
time affirming and protecting the customary rights and social privileges of homeowners. Thus,
we address the following areas of concern:
1. Enforceability
One area of concern that remains is enforceability. We have noted that you have
included a provision allowing for the City Manager to create additional rules to enforce the
ordinance: we believe this is a positive step. However, we believe more is needed. For example,
one criticism we have expressed relates to the determination of a "private" gathering versus a
"commercial" gathering. We would suggest that a homeowner should be provided the
opportunity, upon request from Code enforcement (prior to or during the event), to sign. an
affidavit that the event is not a "commercial use" within the meaning of the ordinance, that he or
she has retained occupancy and control of the premises, and that the event is by private invitation
FTLDOCS 5287397 1
200 EAST BROWARD BOULEVARD SUITE 2100 FORT LAUDERDALE, FLORIDA 33301 TELEPHONE (954) 5245505 FACSIIvIB-E [954) 5245506 WEBSTT'E: www.shutts.com
MIAM[ FORT LAUDERDALE WEST PALM BEACH ORLANDO TAMPA TALL4HP.SSEE AMSTERDAM LUrvUUrv
Ms. Hilda Fernandez
January 29, 2008
Page 2
only. Such a provision would protect homeowners from having private gatherings arbitrarily
shut down without cause.
2. Penalties
An additional concern we have is that the penalties cannot be modified by a Special
Master. While we understand the City's desire to be heavy-handed, the ordinance itself has not
been tested and the circumstances of enforcement. are not yet clear. Particularly in light of the
fact that non-commercial parties have in the past been mistaken for "commercial" uses, we
would request that the ordinance include a provision for appeal, and to empower a Special
Master to reduce fines based upon the circumstances. Likewise, homeowners should be allowed
to make a final appeal to the City Commission to ensure due process. We do not object to
making a fine non-waivable where a special magistrate finds that a homeowner charged
admission fees for entrance to anon-charity event, or where a homeowner is found to have
profited from throwing a party open to the general public.
Likewise, we suggest that the City consider a penalty provision that would reimburse a
homeowner for costs incurred if the City is found to have shut down anon-commercial party in
error. The costs for hosting social gatherings are often extensive, and such a penalty would
provide disincentive for code enforcement to "act first and ask questions later".
3. Open Houses
As we explained in our previous correspondence, the proposed restrictions upon Open
Houses are overly broad because they restrict a resident's ability to throw social gatherings to
sell the home. At the very least, we would suggest that the ordinance should clarify that
homeowners may have "Closed House" parties open to potential buyers by invitation after.8:00
PM. This would allow the owners of larger homes to open their doors to a concentration of
potential qualified buyers without restriction and at a convenient time for the prospective
purchasers. Moreover, we would suggest that the complete ban on the display of goods or
services at open-houses is overly broad and should be limited to the display of goods or services
visible from the right of way.
4. Right of Assembly
Currently, the ordinance states that "The City recognizes peoples' rights of assembly, free
expression, religious freedom, and other rights provided by the state and federal constitutions. It
is the intent of the City Commission that no decision under this ordinance shall constitute an
illegal violation of such rights, and this ordinance shall not be construed as such a violation."
We believe this statement should instead state "this ordinance is not intended to interfere
with, or abrogate those rights, and no decision under this ordinance shall be made in violation of
those rights."
FTLDOCS 5287397 1
SHUTI'S & BOWEN LLP
MIAMI FORT LAUDERDALE WEST PALM BEACH ORLANDO TALLAHASSEE AMSTERDAM LONDON
Ms. Hilda Fernandez
January 29, 2008
Page 3
5. Connection to Other Ordinances
Our research indicates that many other ordinances reference related ordinances within the
City Code. The City may wish to reference that there are existing ordinance provisions
regulating appropriate professions, noise, parking and accessory commercial uses (e. g. film
permits) contained within the code.
6 Record Owner Not Subiect to Enforcement for Valid Leasehold
Additionally, we believe the ordinance should recognize that there are valid leaseholds
(i.e. greater than six months) which should protect a homeowner from liability under the
ordinance and subject the tenant alone to enforcement proceedings. A landlord does not control
the property or his tenant during a legal, long-term leasehold and should be absolved of actions
taken without his or her knowledge.
7 Charitable Gifts Maybe Paid Back
As discussed at the last meeting, we would request that the ordinance be clarified to allow
a charity to reimburse auction donors for the value of items sold at auction or by raffle, as is
often customary for charitable events.
8 Clarify the Waming~Citation
While we approve of the intention behind the code provision allowing citation officers to
present a warning to charities, we believe this provision may now be irrelevant in light of new
additions exempting most charitable events and actions. If the City believes charities are still
likely to run afoul of the ordinance, we would request that the process for issuing and tracking
warnings be clarified so that it is transparent to all residents and homeowners.
9. Tupperware Parties
Finally, we are grateful that the City chose to allow limited direct sales such as
Tupperware Parties as acceptable accessory uses. However, we believe the restrictions on
parking and timing are vague and difficult to enforce (i.e. how does a Code Enforcement officer
determine whether there are 11 cars or 15 cars?). We would instead focus on adverse impacts,
and state that such parties shall not have an adverse impact upon the neighborhood (i.e. violate
noise or parking ordinances).
FTLDOCS 5287397 1
SHVITS & BOWEN LLP
MIAND FORT LAUDERDALE WEST PALM BEACH ORLANDO TALLAHASSEE AMSTERDAM LONDON
Ms. Hilda Fernandez
January 29, 2008
Page 4
In sum, the ordinance has made great strides, and we appreciate being included in the
review process. We look forward to meeting with you soon.
Sic ely,
S S B WE LLP
Alexander P. Heckler
Partner
FI'LDOCS 5287397 1
SHUTTS & BOWEN LLP
MIANII FORT LAUDERDALE WESC PALM HEACH ORLANDO TALLAHASSEE AMSTERDAM LONDON
ATTACHMENT D
~~
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~~ '
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1. The City's Land Development Regulations restrict certain residential properties to residential and
compatible accessory uses. Hence, the seminal question: WHAT IS A COMPATIBLE
ACCESSORY USE OF A SINGLE FAMILY HOME IN A DISTRICT THAT IS ZONED RS-1, RS-2,
RS-3 OR RS-4?
2. Certain "commercial uses" of single family homes in residential districts are allowed pursuant to
certain permits and regulations, such as movie filmings, photography shoots, garage sales, and
home-based offices; hence, the existing Code does recognize that NOT EVERY commercial
activity is, or should be, prohibited in single family residential districts.
3. If the Administration wanted to prohibit all activities in single family residential neighborhoods
that had "an adverse impact on the neighborhood," then private parties would be prohibited if
they created an adverse impact; but that would be depriving homeowners from enjoying the use
of their homes and properties.
4. Movie filmings, photo shoots and garage sales can have adverse impacts on single family
neighborhood, but such "events" are transient rather than permanent events; hence, the impact is
not continuous.
5. The problem with "commercial uses" in single family residential neighborhoods is the potential
for "continuous, adverse impacts on the neighborhood."
6. The Fifth Whereas Clause of the proposed legislation refers to "excessive numbers of guests,
vehicles and noise" from "party houses," and the "adverse impacts on the surroundi~
residences and residential neighborhood..."
7. The Sixth Whereas Clause refers to party houses, and states that "such parties should be more
appropriately held in the commercial districts of the City at venues that are designed for such
numbers of persons, with the impacts resulting therefrom more appropriately mitigated."
8. The Tenth Whereas Clause refers to "open houses" and states that they are permitted uses "if
regulated to minimize their adverse impacts."
9. The Eleventh Whereas Clause refers to the need to "ensure and protect the enjoyment, character
and value of the single family residential neighborhoods and homes...," implying that whatever
materially and continuously adversely impacts the enjoyment of a single family home should be
prohibited. If the objective were to prohibit any parties or events that had an adverse impact on
the neighborhood, whether or not commercially-related, that would be unacceptable.
10. The clear implication is that the proposed legislation is designed to prohibit parties and events
where there is a material, (perhaps continuous), adverse impact on the neighborhood of a single
family zoned residential district.
11. NOT EVERY "commercial use" of a single family home in a residential neighborhood produces
an "adverse impact on the surrounding neighborhood." The definition of "commercial use"
connotes many kinds of activities, not all of which would necessarily have an adverse impact on
the neighborhood:
a. An all-night fast food, drive-thru restaurant located in an RS-1, RS-2, RS-3 or RS-4 zoned
neighborhood would probably have an adverse impact on the neighborhood.
b. An auto body shop would probably have an adverse impact on such a neighborhood.
c. A Tow Truck Car Pound would probably have an adverse impact on such a
neighborhood.
d. But a retired consultant who occasionally receives clients at home would probably NOT
have an adverse impact on such a neighborhood; hence, certain home-based businesses
are permitted, but even the "home-based business" rules are flawed.
e. A single family home rented to a reclusive lessee would probably not have an adverse
impact on such a neighborhood.
12. Conversely, neighborhoods like PHS, the Sunset Islands, North Bay Road, Pinetree Drive, La
Gorce Island, Allison Island and the Venetian Islands ARE regularly and continuously subjected
to the adverse impacts of:
a. Private Home construction and re-construction noise, and construction vehicles parked
every which way, often beginning at 7 a.m. and continuing into the weekends.
b. Municipal road construction and road improvement noise, and municipal vehicles
parked every which way, often beginning at 7 a.m. and continuing into the weekends
c. Utility vehicles performing routine maintenance, parked every which way.
d. Garbage Collection Vehicles making unconscionable noise, often beginning at 7 a.m.
e. Wild, private home parties that have no commercial use components, with the attendant
traffic, haphazard parking and noise, continuing into the wee hours of the morning.
13. Indeed, large, disorganized private parties can. cause far greater adverse impacts on the
surrounding neighborhood-in terms of parking problems; right of way problems; noise
problems; and traffic problems--than an organized and regulated event that has comes within the
proposed definition of a "commercial use."
14. NOT EVERY single family residential neighborhood on Miami Beach is sequestered from
commercial use, and commercial activity:
a. 515 Street and Cherokee Avenue
b. 47th Street and Pinetree Drive
c. The residential streets parallel to Arthur Godfrey Road
15. So I have the following Proposed Changes to the Proposed Ordinance:
a. I would entitle this Ordinance "Adverse Impacts on Single Family Homes Residential
Neighborhoods Prohibited."
b. Section 142-109(a):
"The land development regulations restrict residential properties to residential and
compatible accessory uses. Commercial uses on residential properties are deemed
incompatible accessory uses, and therefore prohibited, if they create a material,
continuous, adverse impact on the surrounding neighborhood. Residents are entitled
to enjoy the use of their property; however, certain guidelines need to be established
to preserve the nature of residential communities:
c. Section 142-109(b) Definitions:
"Use of residential property" or "use of the property" in this ordinance shall mean
occupancy of residential property for the purpose of holding commercial parties, events,
assemblies or gatherings on the premises ("Party" or "Event").
d. Section 142-109(c) Regulations:
"Accessory use of residential property shall be deemed commercial and not permitted,
except as otherwise provided for in the Code, if:
a. Compensation to Owner. The owner, lessee or resident receives payment or
other consideration, e.g. goods, property or services, in excess of [Increase
from $100 to $1,000] per Party or Event -for the use of the property,
incljuding payment by any means, direct or indirect, including security
deposits.
b. Admittance Fees. Use of the property by attendees requires an admittance
or membership fee or a donation, excluding donations directly payable and
paid by attendees to charitable, religious or political organizations that have
received Section 501(c)(3) or other tax exempt status under the U.S. Internal
Revenue Code, as amended.
"Accessory use of residential property may be deemed commercial and not permitted,
except as otherwise provided for in the Code, if:
c. Goods, property or services offered or sold. Goods, property or services
exceeding [Increase from $100 to $1,000] are offered for sale or sold on or at
the property; ...
a. ...
b. ...
c. ...
d. Notwithstanding the above restrictions...[eliminate sub-paragraphs
"D" and "E."
d. Enforcement:
(1) Violations of this section shall be subject to the following fines. [Delete
the sentence that provides for MANDATORY FINES without
discretion by the Special Master].
(2) In addition to or in lieu of the foregoing, the City may [Eliminate "close
down the commercial use of the property and/or] seek an injunction
against activities or uses clearly prohibited under this section.
(3) Any city police officer or code compliance officer may issue notices for
violations of this ordinance [Eliminate "...with alternative enforcement as
provided in section 1-14 and Chapter 30 of this Code]
e. [Eliminate "No variances shall be granted from this section."]
SECTION 2. Repealer [Eliminate].
m MIAMIBEACH
CITY OF MIAMI BEACH
NOTICE OF PUBLIC HEARING
NOTICE IS HEREBY given that a second reading and public hearings 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,
February 13, 2008, to consider the following:
10:20 a.m.
An Ordinance Amending Section 41-50 Of Chapter 41, Article V Of The Code Of The City Of
Miami Beach Relating To Resort Tax; Requiring That, As Of The Effective Date Provided Therein,
Resort Tax May Be Filed And Paid Online At No Charge, And Any Manual Filing And/Or Payment
Transaction Will Be Assessed A $25.00 Processing Fee.
Inquiries may be directed to the Finance Department at (305) 673-7466.
10:30 a.m.
An Ordinance Amending Miami Beach City Code Chapter 2, Article VII, Division 2 Thereof Entitled
"Officers, Employees And Agency Members," Section 2-459 "Certain Appearances Prohibited"
By Establishing Post Public Service Lobbying Restrictions For Agency Members.
Inquiries may be directed to the Legal Department at (305) 673-7470.
5:00 p.m.
An Ordinance Amending The Land Development Regulations Of The Code Of The City Of Miami
Beach, By Amending Chapter 118, "Administration And Review Procedures," Article X, "Historic
Preservation", Division 3, "Issuance Of Certificate Of Appropriateness/Certificate To Dig/
Certificate Of Appropriateness For Demolition", By Amending Section 118-562 To Clarify And
Update Certain Procedures And Requirements Pertaining To The Issuance Of A Certificate Of
Appropriateness For Demolition. And By Amending Section 118-564 To Modify The Evaluation
Criteria For A Certificate Of Appropriateness For Demolition.
Inquiries may be directed to the Planning Department at (305) 673-7550.
5:01 p.m.
An Ordinance Amending Chapter 142, "Zoning Districts And Regulations," Of The City Code, By
Amending Division 2, "RS-1, RS-2, RS-3, RS-4 Single-Family Residential Districts," By Adding
New Section 142-109 Entitled "Commercial Use Of Single Family domes Prohibited".
Inquiries may be directed to the City Manager's Office at (305) 673-7010.
INTERESTED PARTIES are invited to appear at this meeting, 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, 1st Floor, City Hall, Miami Beach, Florida 33139. Copies of these
ordinances are available for public inspection during normal business hours in the City Clerk's
Office, 1700 Convention Center Drive,1st Floor, City Hall, and Miami Beach, Florida 33139. This
meeting may be continued and under such circumstances additional legal notice would not be
provided.
Robert E. Parcher, City Clerk
City of Miami Beach
Pursuant to Section 286.0105, Fla. Stat., the City hereby advises the public that: 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 inaccessible 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 (305) 604-2489 (voice), (305)673-7218(TTY)
five days in advance to initiate your request. TTY users may also call 711 (Florida Relay
Service).
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