Documents and Exhibits submitted for the Record in Opposition - Submitted by Alan S. Zimmet, Esq.
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CLEARWATER DEVELOPMENT BOARD HEARING
Hearing Date:
Case Number:
Owner/Applicant:
Address:
September 16, 2008
FLD2008-02002
Belleview Biltmore Owner, LLC
1590 Gulf Boulevard
DOCUMENTS AND EXHIBITS SUBMITTED FOR THE RECORD
IN OPPOSITION TO APPLICANT'S FLEXIBLE DEVELOPMENT REQUEST
Submitted by:
Alan S. Zimmet, Esq.
Zimmet, Unice & Salzman, P.A.
2570 Coral Landings Blvd, Suite 20 I
Palm Harbor, FL 34684
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Table of Contents
Sue Murphy, AICP Opinion Letter dated August 15,2008................................ ............. 1
Resume of Sue Murphy, AICP.................................................................. ............ 4
Relevant Sections: Clearwater Community Development Code........................................ 6
Hotel Room to Restaurant Seat Ratios.. ......................................... .............. ..... ...... ...7
Photograph of Cabana Club Parking Lot taken on March 28, 2008....... .... ............. ......... ..... 8
Photograph of Cabana Club Parking Lot taken on April19, 2008.. .............. ..................... ...9
Photograph of Cabana Club Parking Lot taken on May 25, 2008................. ....................... 10
Current View of Cabana Club Property............ ...... ..... .......... ............. .............. ........ 11
View of Cabana Club Property with Proposed Hotel Superimposed................................... 12
Qualifications of Ronald A. Oxta1, MAl.............. ........... .......................................... 13
View of Cabana Club Property from 1591 Gulf Boulevard (The Harbour South).............. ...... 16
View 1 of Cabana Club Property from 1621 Gulf Boulevard (The Isle of Sand Key).... ........... 17
View 2 of Cabana Club Property from 1621 Gulf Boulevard (The Isle of Sand Key). . .... . . . . . . . .. 18
View of Cabana Club Property from 1586 Gulf Boulevard (Cabana Club Condominiums)........ 19
View 1 of Cabana Club Property from 1600 Gulf Boulevard (Dan's Island North).............. ...20
View 2 of Cabana Club Property from 1600 Gulf Boulevard (Dan's Island North). . . . . . ... . . . . . .... 21
View 3 of Cabana Club Property from 1600 Gulf Boulevard (Dan's Island North)................. 22
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f) & '" (A)niultina t;...()UP~ Inc.
August 15,2008
Alan S. Zimmet, Esq.
Zimmet, Druce, Salzman & Heyman, P.A.
2570 Coral Landings Blvd., Ste 201
Palm Harbor, FL 34684
Subject: Belleview Biltmore Cabana Club, ] 590 Gulf Blvd., Clearwater, FL
Dear Mr. Zimmet:
As requested, I have analyzed all of Legg Mason's submittals, the City of Clearwater's
Community Development Code (the Code) and existing conditions on the site in regard
to the above-noted request for flexible development approval.
,In my professional opinion as a land use planner, the proposed project is simply trying to
put too much development such a small parcel of land. This is evidenced by the number
and extent of deviations from the Code that are necessary to allow this development.
Merely, because the Code's density limitations allow a 38 room hotel, does not mean that
a 38 room hotel can meet the Code's other development regulations applicable to this
property. Not only is the applicant in need of the deviations to fit the 38 room hotel, they
are trying to squeeze in an oversized restaurant.
The applicant is claiming that the 4,981 s.f. restaurant shown on their plans, in addition to
the 1,096 sf. bar and grill by the pool area, is accessory to the 38 room hotel. If this claim
is accurate, the Code would not require any additional parking to be provided for the
restaurant uses, beyond the 18 spaces that are being provided in addition to the 38
required to serve the hotel. The applicant states that they are providing 56 spaces. Three
of these spaces are handicapped spaces so they cannot be legally used by the general
public.
Accessory uses are defined in the Code to be subordinate to the principal use and on the
same property. They are also defined to be subordinate in extent relative to the principal
use. The ratio of restaurant seats to hotel rooms demonstrates that this restaurant is not
subordinate to nor is it intended to serve mainly the guests of the 38 room hotel.
A survey of many quality hotels in this area shows that the average ratio of seats to hotel
rooms is 0.97. The Cabana Club is proposed to have 4.34 seats for each hotel room,
which is approximately 450 percent higher than the average for the hotels surveyed. A
copy of the survey results is enclosed.
ti()1 Wed I:udld Avenue · Tampa. nmda noo~
Vh: (SI:1) WI~ · r=ax: (SI.)) ~<Xl')1
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Alan Zimmet, Esq.
Page Two
The applicant also claims that the restaurant is accessory to the Belleview Biltmore,
which is approximately 6 miles away in the Town of Bellair. The City's definition of
"accessory use" requires that the accessory use be located on the same site as the
principal use. In my opinion, this 'Only makes sense from a land use planning standpoint,
since the parking provided 6 miles away will not meet the needs created by the 4,981 sf.
restaurant proposed on Sand Key. Therefore, it is my opinion that under the Code, the
proposed restaurant is not an accessory use to the proposed hotel.
Despite the recently submitted shared parking analysis prepared by Tim Haahs on behalf
of the applicant, there is clearly not enough parking available to serve both the hotel's
needs and that of the restaurant. The study proposes valet parking in a manner that
violates the Section 3. 1404(C) of the Code. It also relies on a 70 percent internal capture
of trips as a resort and assumes that only 24 of the 38 hotel rooms will be occupied. That
translates into approximately 48 people using 70 percent (116 seats) of the 165 restaurant
seats.
Under the shared parking provisions of the Code, there is a table that states that both
overnight accommodations and restaurants need 100% of their required parking at the
same time, between the hours of 6 pm and midnight. Therefore, the greatest demand for
the two proposed uses of this site are during the same exact hours.
If one space is utilized for each hotel room, there are 18 spaces remaining for a 4,981 sf.
restaurant, a 1,096 sfbar and grill, hotel cars such as the airport van and delivery vans,
guests of the hotel users, and any of the Belleview Biltmore's estimated 900 guests who
are encouraged to use the beach facility. Three of the total number of spaces provided
are handicapped spaces, not available for general public use. While the applicant
indicates that they will shuttle Belleview Biltmore Hotel guests and employees to the site,
they are not going to be able to prohibit them, especially, Belleview Biltmore Hotel
guests, from driving there and needing a place to park.
As you can see from the enclosed photographs, there is not enough parking now for just
the existing restaurant. The applicant is proposing seven parking spaces more than the
existing development, even though they are adding 38 hotel rooms. Under the Flexible
Standards in the Code, 35-75 parking spaces would have to be provided for the new
restaurant use. While the Comprehensive Infill Criteria is more flexible, there is still the
need to provide parking based on the need being created by the use, and the Flexible
Standards provide a guideline for doing so.
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Alan Zimmet, Esq.
Page Three
Also, the layout of the proposed parking lot does not meet minimum code requirements
for stacking. The minimum requirement is 40 feet from the road, and the site plan shows
approximately 20 feet. This creates a traffic safety issue if cars back up onto Gulf Blvd.
trying to enter the Cabana Club. This standard, as well as the other standards referenced
from the Code, are enclosed.
In order to approve comprehensive infill projects, the City must find that the proposal
meets the enclosed Comprehensive Infill Criteria contained in Section 2-704 of the Code.
The first review criterion is whether or not the development or redevelopment is
otherwise impractical without deviations from the use and/or development standards set
for in the zoning district. Because the applicant is seeking to overdevelop the site,
numerous deviations from the code have been requested. However, there are several
commercial uses that could be practically fit on this site and be developed without the
need for numerous deviations.
Criterion 5 requires that the proposed use will not substantially alter the essential use
characteristics of the neighborhood. Also, all of the criteria in number 6 must be met for
approval of flexibility as to use, lot width, required setbacks and off-street parking.
Criterion 6b requires the design, scale, and intensity of the proposed develop support the
established character of the area.
As already discussed, in my professional opinion, the intensity of the project is not
compatible with, nor does it support, the established character of this area, which is
residential. The proposed development is too intense for the size of the parcel so
deviations from flexible standards are being requested for setbacks, height, and lot width
and there is insufficient parking proposed for the intensity of the uses planned for the site.
The lack of parking will have a negative impact on the surrounding properties. The
existing restaurant already has been cited for cars parking illegally in the fire lane or
driveway, pictures demonstrate that the parking situation on site violates Code
requirements and the proposed parking layout also violates stacking requirements.
In conclusion, it is my opinion that the proposed development does not meet the criteria
for infill development under the City's Community Development Code.
Sincerely,
\J I -' , ,
/ " O' I" I : ,(" . ,',
"~I . . " . I !
Sue Murphy, AICP ;..
President
Encs.
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RESUME FOR SUE ANN MURPHY, AICP
OVERVIEW OF EXPERIENCE:
Sue Ann Murphy is a Land Use Planner specializing in Entitlement Issues, including
Rezoning, Comprehensive Plan Amendments, Large Scale, Multi-jurisdictional Project
Entitlements, Traditional Neighborhood Developments, Permitting, Developments of Regional
Impact, Development Agreements, Ordinance Preparation, Grant Writing, and Expert Witness
for Land Use Matters and related issues. She is President ofP&M Consulting Group, Inc., in
Tampa, Florida.
Sue has been actively involved in Smart Growth and assists numerous retailers and
shopping center developers in dealing with growth related matters and helping them with long
range planning, entitlements and permitting. She currently chairs the Smart Growth
Subcommittee of the International Council of Shopping Centers ("ICSC") and was the ICSC
2006 Dean of the University of Shopping Centers' School of Economics. Sue is the former
ICSC Southeast United States Director of Government Relations and is actively involved in the
development of several large scale, mixed use and residential projects in Florida.
Present Position:
President ofP&M Consulting Group, Inc.
501 West Euclid Avenue
Tampa, Florida 33602
(813) 503-8900
Former Positions:
1980:
1981 - 84:
1984 - 85:
1985 - 89:
1989 - 2001:
2001 - 2006:
Assistant to the Mayor of Oldsmar.
Planning Supervisor, City of Tampa, Florida
Hillsborough County Zoning Hearing Master and President of Sue
Murphy & Associates
Department Head of Planning and Landscape Architecture for
Greenhorne & O'Mara, Inc.
Planning Director for the law firm of Rudnick & Wolfe
(Currently DLA Piper)
Senior Planner for the law firm of Ruden, McClosky, Smith, Schuster &
Russell
President, P&M Consulting Group, Inc.
2006 - present:
Education:
B.A. in Fine Arts, University of Maryland, 1976
M.A. in Geography, University of South Florida, 1980
Specialty Education:
Residential Design, Harvard University, Graduate School of Design, 1988
Design of Stormwater Systems, City of Tampa Engineering, 1982
Professional License:
American Institute of Certified Planners (AICP) since 1989
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RESUME FOR SUE ANN MURPHY
Committees:
State Board of Directors of Florida Home Builders, 1985-89
Chair, Zoning Advisory Task Force, Hillsborough County 1985
Board of Directors, National Association of Industrial and Office Parks, 1986-96
Florida Governmental Affairs Chair, International Council of Shopping Centers ("ICSC"),
1992-94; 2004-05
Southeast United States Chair of Government Relations, ICSC 1998-2000
Chair, Smart Growth Task Force, ICSC 2000-present
Dean, University of Shopping Centers, ICSC, 2005-06
Chair, Florida ICSC Conference, 2004
Teaching experience:
Instructor: University of South Florida, Geography Department
Guest lecturer at University of Miami Law School. Taught course on property rights and
entitlements with Mark Tobin, Principal of Brigham Moore, LLP
Guest lecturer at University of Florida. Taught course on Growth Management
Courses/Seminars/Teaching Positions for International Council of Shopping Centers
Dean of University of Shopping Centers, School of Economics, Wharton School,
Philadelphia
University of Shopping Centers, School of Economics, taught course on Smart Growth
Law Conferences: Conducted seminars on Redevelopment and Adaptive Reuse, and a
seminar on Dealing With Neighborhood Opposition to Development Projects
Florida Conferences: Conducted seminars on Growth Management, Negotiation of
Entitlements, and New Urbanism
Centerbui1d Conferences: Taught seminars and workshops on Growth Management,
Negotiation of Entitlements, and Impact Fees
National Convention: Conducted a General Session on Retailers Role in Smart Growth
Representative Clients:
Centex Homes
Leucadia Financial Corporation
Kimco Realty Corporation
Publix Super Markets, Inc.
Teachers Retirement
Sembler Company
General Motors Corporation
RMC Property Group
McDonalds Corporation
Mobil Oil Corporation
Page 2 of 2.
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RELEVANT SECTIONS: CLEARWATER COMMUNITY DEVELOPMENT CODE
Definition of "Accessory Use": Accessory Use means a use which: (1) is subordinate to and serves a
principal use; (2) is subordinate in area, extent and purpose to the principal use served; (3) contributes to the
comfort, convenience or necessities of the users or occupants of the principal use; and (4) is located on the
same lot as the principal use.
Section 2-701: Commercial
The intent and purpose of the Commercial District is to provide the citizens of Clearwater with convenient
access to goods and services throughout the City without adversely impacting the integrity of residential
neighborhoods, diminishing the scenic quality of the City or negatively impacting the safe and efficient
movement of people and things within the City of Clearwater.
Section 3-1404(C) Off Street Parking Spaces: Availability
All required parking spaces, including appropriate access thereto, shall remain unobstructed and available for
use in accordance with their purpose.
Section 3-1405 Shared Parking
When any land, building, or area is used for two or more uses which are listed below, the minimum total
number of required parking spaces shall be determined by the following:
Multiply the minimum required parking spaces for each individual use, excluding spaces reserved for use by
specified individuals or classes of individuals, by the appropriate percentage listed in the Table below for
each of the designated time periods and the resulting minimum required parking spaces in each of the five
vertical columns for the table. The minimum parking required is the highest sum of the vertical columns.
USE TIME PERIOD
6:00 pm - Midnight
Overnight Accommodations 100%
Restaurant 100%
Section 3-1401(C) Parking:
The community development coordinator may require an applicant to prepare a parking demand study in
conjunction with a request to make deviations to the parking standards. Prior to the preparation of such
study, the methodology shall be approved by the community development coordinator and in accordance
with accepted traffic engineering principals. The findings of the study will be used in determining whether
or not deviations to the parking standards are approved.
Section 3-1406(B) Stacking Spaces
Provisions must be made for stacking and transition of incoming traffic from a public street, such that traffic
may not back up into the public street system.....
(2) The minimum distance between all other rights-of-way and the first space or aisleway in a parking lot
shall be as outlined in the following table:
NUMBER of SPACES
MINIMUM STACKING
DISTANCE
51 or more
40 feet
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HOTEL ROOM TO RESTAURANT SEAT RATIOS
Number of Number of Seats per Room
Hotel Name Rooms Restaurant Ratio
Seats *
Belleview Biltmore (Existing) 394 240 0.60
Seats/Room
494 1.16
Belleview Biltmore (Proposed) 425 (indoor & Seats/Room
outdoor)
Sheraton Sand Key 390 344 0.88
Seats/Room
Marriott Sand Key 220 254 1.15
Seats/Room
Sand Pearl Clearwater Beach 253 172 0.67
Seats/Room
Vinoy Renaissance 347 330 0.95
Seats/Room
Don Cesar Beach Resort 277 330 1.19
Seats/Room
Ritz Carlton Naples 450 548 1.21
Seats/Room
AVERAGE "RESTAURANT SEATS PER HOTEL ROOM" RATIO 0.97
Seats/Room
PROPOSED CABANA CLUB HOTEL 38 165 4.34
447% of the Average Ratio Seats/Room
* Based upon the total number of restaurant and bar seats for each establishment.
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OXTALREALEsrAIE
Advi~()l:S1,h'1('.
QUALIFICATIONS OF RONALD A. OXTAL. MAl
EDUCATION:
YEAR
Northeast High School, Philadelphia, Pennsylvania
1975
Temple University, Philadelphia, Pennsylvania
Bachelor of Business Administration (Real Estate)
1979
REAL ESTATE EDUCATION:
Appraisal Institute
- National USPAP Update Course 2008
- Florida Superior Trainee Roles and Rules 2008
- Florida State Law Update for Real Estate Appraisers 2008
- Introduction to GIS Applications for Real Estate Appraisal 2008
- Business Practices and Ethics 2007
- Online Appraising From Blueprints and Specifications 2007
- Online Appraisal of Nursing Facilities 2007
- Online Analyzing Operating Expenses 2007
- Residential Market Analysis and Highest & Best Use 2006
- National USPAP Update Course 2006
- FREAB Course: ACE # 0007293-Florida State Law for Real Estate Appraisers 2006
- FREAB Course: ACE #007559-What Clients Would Like Their Appraisers to Know 2006
- National USPAP Update Course 1400 2004
- Analyzing Distressed Real Estate 2004
- Evaluating Commercial Construction 2003
- The Emerging (Mark To) Market: Valuation for Financial Reporting Purposes 2003
- Florida Law Update For Real Estate Appraisers 2002
- The Appraiser as an Expert Witness: Preparation and Testimony 2002
- Appraisal Consulting 2002
- Regression Analysis in Appraisal Practice 2001
- Appraisals and Real Estate Lending 2001
- USPAP/Florida Law 2000
- Attacking and Defending an Appraisal in Litigation 2000
- Evolution of Capital Markets 1999
- Partial Interest Valuation - Divided 1999
- USPAP/Law for Appraisers 1998
- Appraising from Blueprints and Specifications 1998
- Eminent Domain Conference 1997
- Florida Condemnation Valuation & Appraiser Liability 1997
- Litigation Skills for the Appraiser: An Overview 1997
- The Internet and Appraising 1997
- Standards of Professional Practice 1996
- USP AP Core Law Update 1996
- Continuing Education Seminars 1996
- Continuing Education Seminars 1995
- Continuing Education Seminars 1994
- Understanding Limited Appraisals 1994
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QXTAL REALEsrAlE
Advis()l:S~hl('.
- USP AP Core Law Update
- Appraisal Review Income Properties
- Standards of Professional Practice Part A
- Standards of Professional Practice Part B
- The Appraiser's Legal Liabilities
- Capitalization Theory & Techniques Part B
- Appraisal Regulation of Federal Banking Agencies
- Litigation Valuation
- Appraising for Pension Fund Portfolios Seminar
- Standards of Professional Practice (update)
- R-41c Seminar
- Continuing Education Classes and Seminars
- Comprehensive Examination
- Real Estate Investment Analysis
- Case Studies in Real Estate Valuation
- Valuation Analysis & Report Writing
- Capitalization Theory & Techniques Part 1
- Capitalization Theory & Techniques Part 2
- Capitalization Theory & Techniques Part 3
- Standards of Professional Practice
- Residential Valuation
- Basic Valuation Procedures
1994
1993
1992
1992
1991
1991
1990
1989
1988
1987
1986
1986
1985
1985
1984
1984
1983
1983
1983
1983
1979
1979
Society of Real Estate Appraisers
- Applied Income Property Valuation
- Income Property Valuation
- R-2 Examination
- Principals of Real Estate
- Narrative Report Writing Seminar
- Income Approach Seminar
1983
1982
1981
1981
1980
1980
EMPLOYMENT HISTORY:
Oxtal Real Estate Advisors, Inc. (Tampa, Florida)
President
From January 1,2001, to Present
R+E Marketing Consultants, Inc. (Tampa, Florida)
Principal
From July 1, 1986, to Present
R+E Marketing Consultants, Inc. (Tampa, Florida)
Senior Associate
From March, 1982, to June 30, 1986
Williams Appraisal Service (Tampa, Florida)
Associate
From September, 1980, to March, 1982
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OXTALREALEsrATE
Adtis~Ol:Sl, 111C'.
Edward G. Ireland, RM, SRA (Philadelphia, Pennsylvania)
Associate
From May, 1978, to September, 1980
COURT TESTIMONY/EXPERT WITNESS:
U.S. Bankruptcy Court (Various Jurisdictions)
Hillsborough County Circuit Court
Pasco County Circuit Court
Hernando County Circuit Court
Pinellas County Circuit Court
U.S. District Court - Eastern District of Virginia
U.S. District Court - Southern District of Florida
DESIGNATIONS:
MAI-
Member, Appraisal Institute. Currently Certified. Member No. 7212
Florida -
Certified General Appraiser #RZ265
Georgia -
Certified General Appraiser CG004203
LICENSES:
Real Estate Broker State of Florida
MEMBERSHIPS:
Appraisal Institute, West Coast Florida Chapter
Real Estate Investment Council (REIC)
Regional Ethics and Counseling Panel
National Association of Convenience Stores
Mortgage Bankers Association of America
International Council of Shopping Centers
Association of Eminent Domain Professionals
EXPERIENCE:
Mr. Oxtal has the experience in the following property types to meet the competency
provision requirements of USP AP. Analysis and appraisal of residential, commercial, industrial
and special purpose properties, including subdivisions, PUDs, business parks, condominiums and
condominium conversions, apartments, shopping centers, office buildings, golf courses, tennis
clubs, mobile home parks, restaurants, hotels and warehouses. Experience also includes highest
and best use studies, market studies, partial interest valuations, and trial testimony in eminent
domain and bankruptcy matters. Mr. Oxtal also has experience in development, brokerage,
leasing and financing matters.
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