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and Members, Board of County Commissioners From: Daniella Levine Cava

STAFF RECOMMENDATION
At the September 4, 2019, Board of County Commissioners (Board) meeting, Resolution No. R-967-19 was adopted by Board members directing the County Mayor or County Mayor�s designee to prepare a report analyzing the potential impacts to Miami International Airport (MIA) from the development of stadiums, hotels, or commercial space on the International Links Melreese County Club. The Resolution references potential impacts to traffic, road closures, aviation and airport operations, Federal Aviation Administration (FAA) requirements, commercial and environmental impacts as well as costs to MIA to mitigate such impacts.

As part of my operation to catch up on the backlog of items, we are bringing you reports that were pending from the previous administration. This memorandum highlights the findings of the reports prepared by the Aviation Department, the Regulatory and Economic Resources Department, and the Transportation & Public Works Department (attached as Exhibits A, B, C and D) by summarizing the potential impacts of the elements listed above prior to the �coronavirus disease 2019� (COVID-19) pandemic, as the long term impacts of the pandemic are unknown.

Miami-Dade Aviation Department (MDAD)

A. Aviation and Airport Operations Impacts and FAA Considerations � Exhibit A

MDAD�s report on the proposed International Links Melreese County Club development is based on publicly published information, which shows a site plan consisting of a 25,000-seat soccer stadium, hotels, practice fields, and commercial retail space.

On December 3, 2019, the Capitol Airspace Group filed with MDAD a request on behalf of the developer for a MDAD-issued �Preliminary Airspace and Land-Use Letter of Determination.� The filing included the submittal of a specific use survey with eight points (GPS Coordinates), along with one architectural elevation associated with the proposed soccer stadium. Other than this preliminary information, to date no additional drawings, or site plans with the proposed locations of the development have been submitted to MDAD. As mentioned previously, the concerns bulletined below are based on publicly available information and artistic renderings. The Capitol Airspace Group also informed the Aviation Department that it was concurrently filing with the FAA for a federal airspace determination.

MDAD consulted with both airline partners and air cargo carriers for additional input on the potential operational and safety effects of the proposed development. The following is a summary of concerns voiced by MDAD, the airlines and cargo operators.

* Compliance with Miami-Dade County Code in that four of the eight GPS Coordinates of the proposed stadium would be too high and penetrate the obstacle clearance surfaces described in the Code, in addition, they would also penetrate the standard departure surfaces prescribed by the FAA. On April 1, 2020, MDAD received notice that the height of the four points that would have been too high will be redesigned (i.e., reduced) to bring the stadium into compliance with the new, more restrictive height requirements of the Airport Zoning Code. This statement has not yet been corroborated by the Aviation Department.
* Compliance with the compatibility criteria specified in the Miami-Dade County Code as it relates to land use within three different zones, the Outer Safety Zone, the Critical Approach Zone and the 65-74 DNL Noise Compatibility Zone.

1. The Outer Safety Zone prohibits new residential construction, as well as the construction of educational facilities (excluding aviation-related schools and structures used in connection with public transportation), buildings for public assemblage, hospitals and religious facilities. Because the stadium is a building for public assemblage, it must be located outside the Outer Safety Zone. The preliminary sketch submitted shows that the stadium is located adjacent to the Outer Safety Zone. The Code does not permit variances from these restrictions in the Outer Safety Zone.
2. The Critical Approach Zone prohibits construction of hospitals, stand-alone emergency rooms, skilled nursing facilities, adult day care facilities, day nurseries, and educational facilities (excluding aviation-related schools) and uses that emit smoke, gases, or dust in quantities sufficient to jeopardize the safe use of MIA. The Code does not permit variances from these restrictions in the Critical Approach Zone. The proposed development site is partially contained within this Zone.
3. The 65-74 DNL Noise Compatibility Restriction Zone dictates that all new uses shall incorporate at minimum a 25-decibel outdoor-to-indoor noise level reduction into design and construction. The proposed development site is fully contained within this Zone.

* Visual impacts to pilots and air traffic controller personnel resulting from lighting and glare from the proposed stadium, practice fields, and other associated support facilities.
* Reduction in MIA�s air traffic capacity due to potential airspace restrictions during sporting and other events.
* Airspace conflicts with helicopters, blimps, drones, and banner tower operations associated with the proposed stadium and its uses.
* Aircraft operational impacts during the prolonged construction due to the presence of cranes within the arrival and departure paths of MIA�s longest runway, Runway 9-27.
* Conflicts with aircraft operations due to the use of lasers and pyrotechnics during stadium activities and events.
* Impact to FAA�s communications or navigation facilities including but not limited to radio coverage, radio transmissions and electrical interference of navigational aids. These impacts would be discovered after construction is completed and would be resolved at the expense of the developer.

It should be noted that MDAD is not able to quantify the costs that would be incurred to mitigate the various impacts described herein. However, the developer would need to consider a design and development budget for any mitigation they would be responsible for.

B. Commercial Impacts - Exhibit B

MDAD has determined that if the proposed development includes the construction of a new hotel with conference rooms that use modern technology, there could be an impact to MIA, as there is limited modern technology available in meeting rooms currently being used inside airport property and in surrounding areas. This impact can be mitigated through the implementation of projects scheduled in MDAD�s Capital Improvements Program, which includes the development of two new hotels within MIA�s perimeter with meeting space rooms in at least one of the hotels with state-of-the-art conference room solutions. Because MIA�s customer base is predominantly the traveling public, business travelers planning an overnight stay in Miami would select an on-site MIA hotel as a convenient meeting place as long as modern technology is available in the business conference rooms.

MDAD provides shuttle services out of MIA to the Dolphin Mall and other retail destinations for passengers. MDAD is confident that the construction of food and beverage and retail stores at the proposed development site will have a minimal impact to MIA, if any. This is largely because passengers typically prefer to shop and eat at post security locations inside the airport as their time at MIA is limited. Ordinarily, domestic and international passengers do not shop in areas located away from the airport the day they travel.

Regulatory and Economic Resources Department

C. Environmental Impacts � Exhibit C

The proposed development site has documented on-site solid waste, as well as soil and groundwater contamination. At this time, the Division of Environmental Resources Management (DERM) has no record of off-site contamination associated with the subject site. However, if additional site assessment activities reveal off-site contamination impacts that originate from the above referenced site, the City (as the party responsible for site rehabilitation) will be required to address and remediate those off-site impacts. Furthermore, due to the existing on-site solid waste and soil contamination, any redevelopment of the subject site will require further coordination with DERM. Any plans for proposed redevelopment will require prior DERM review and approval to ensure proper handling and/or disposal of contaminated material. This will include conditions for proper site management to ensure hazardous materials (solid waste and contaminated soils) are not allowed to impact off-site properties, including but not limited to the MIA property.

Any proposal for stormwater system improvements expansion/redesign at the subject site (e.g., during any proposed development) will also require DERM review and approval. At that time, DERM technical staff will conduct a thorough review to ensure that any proposed stormwater system modifications comply with Miami-Dade County Code and that applicable regulations are adhered to in order to ensure that stormwater is properly managed and that stormwater is properly managed and that discharges will not disperse the groundwater contaminate plume to offsite properties. Additionally, such stormwater improvements will require groundwater monitoring to verify that no off-site dispersion of said contaminates occur.

Transportation & Public Works Department


D. Traffic & Road Closures � Exhibit D

After review of the Miami Freedom Park and Soccer Village Traffic Study (Study) dated June 2019, the Transportation & Public Works Department (DTPW) expressed concern with a number of factors in the Study including but not limited to: 1) the Study area is limited to the vicinity of the site, 2) the traffic data for the Study was collected in 2018 while the SR 836/Dolphin Expressway was undergoing construction in the vicinity of the Study, 3)�the Study showed lower traffic counts at on- and off-ramps from SR 836 on LeJeune Road and those in the vicinity of the Miami Intermodal Center compared to the historical Florida Department of Transportation (FDOT) traffic count data, 4) 10 of the 28 intersections in the Study area are approaching capacity under existing conditions and/or future conditions, and 5) traffic volumes from FDOT Traffic Online website indicates that�SR-836/Dolphin Expressway in the Study area is approaching capacity. Based on these concerns and others outlined in DTPW�s report attached in Exhibit D, it was concluded that insufficient information has been provided in the Study to address the concerns of the Board as stated in Resolution No. 967-19, rather, DTPW recommends that a new detailed study encompassing a larger area would need to be prepared by the developer since much of the study depends on the scope and intensity of the development they are proposing. �

Pursuant to Ordinance No. 14-65, this memorandum shall be placed on a Board meeting agenda for review.



c: Geri Bonzon-Keenan, County Attorney
Office of the Mayor Senior Staff
Lester Sola, Aviation Director
Jennifer Moon, Chief, Office of Policy and Budgetary Affairs
Yinka Majekodunmi, CPA, Commission Auditor
Eugene Love, Agenda Coordinator
Melissa Adames, Acting Director, Clerk of the Board