The Miami City Commission voted in 2023 to require that public land lost to development be replaced. But one resident who championed the law says city records suggest commissioners were unaware of last-minute changes that neutered the legislation’s intent.
Editor’s Note: Elvis Cruz is a longtime Morningside resident and civic activist focused on zoning, parks and government accountability.
David Villano’s excellent Nov. 17, 2025 story detailed how the City of Miami used a not-on-the-agenda “substitution memo” to eviscerate the “No Net Loss” ordinance for park land. That ordinance was supposed to require replacing – with newly acquired land – any park land lost to any other use (like the 73 acres at the former Melreese golf course when it was turned over to the soccer stadium scam).
During the public hearing for the first reading of the ordinance at the Miami City Commission on Sept. 14, 2023, I gave a PowerPoint presentation you can see here, in which I warned against using city-owned land to circumvent the intent and spirit of the law. As per the city’s verbatim minutes (page 12) I said, “Pre-existing public land should not be allowed to count for no net loss of park land.”
Immediately following my comments, Commissioner Reyes spoke up.
Commissioner Reyes: “…thank you for bringing this up because I agree with you. We have to be a little bit more strict on how we are going to deal with our no net loss because this language could repeat another Melreese in which every single parcel, even land that belonged to the City of Miami, was converted into park to pay for the park loss. And we cannot accept that anymore, because they made a shamble, they made a mockery of no net loss.”
Commissioner Covo: “I’m in agreement.”
Commissioner Reyes soon spoke again: “…public land, City-owned property, was converted to park in order for that mockery that was done with Melreese, in order to show that there was some replacement of park land. And the only thing that we were doing, we were paying with our own land, the land that we lost, the park land that we lost. And I want to avoid that. I want that to make very — be very clear in the language that any City of Miami owned land cannot be converted. Or that the zoning cannot be changed into park in order to pay for a land that has been a park land that has been lost because that’s what you did. That’s what you did with Melreese.”
I was quite pleased to have Commissioners Reyes and Covo in agreement.
However, evidently, little did they or I know that only two days before that meeting a “substitution memo” from then-City of Miami Planning Director Lakisha Hull, and signed by City Manager Art Noriega, had been submitted to the city clerk with language that eviscerated the proposed ordinance by allowing for exactly what I and Commissioner Reyes spoke against, with Commissioner Covo’s concurrence: using existing city-owned land to offset lost park land.
It gets worse.
At second reading on Oct. 12, 2023, the agenda did have the substitution memo attached, along with the substitute legislation that contained the eviscerating language which would allow the city to use already existing city-owned land to offset lost park land.
But a deeply disturbing thing happened during the discussion on the item. From the verbatim minutes (page 50), it’s clear that Commissioners Reyes and Carollo were not aware of the changed language, as they spoke of making sure that the city would receive new land “from the persons that are utilizing our parks for development.”
Commissioner Reyes: “What is a shame that this was — it wasn’t enforced when we gave up the re — what I want is to be very strict that if any park land is going to be used for any other purpose but parks, that no net loss and the City of Miami should get some — I mean, the same amount of land that it’s losing from the persons that are utilizing our parks for development.”
Vice Chair Carollo: “So, we’re both on the same page and this ordinance is okay for what we want and stated here, correct?”
Commissioner Reyes: “Yes.”
Lakisha Hull (Director of Planning): “Commissioner Carollo, that’s correct. Lakisha Hull, for the record.”
Vice Chair Carollo: “Thank you.”
Lakisha Hull: “This legislation helps us to better enforce our policy on no-net-loss. So whenever there’s a rezoning, we’re going to use this legislation to be able to support the rezoning of that to a CS park land space, sir.”
Vice Chair Carollo: “Sure, okay.”
Notice that Reyes and Carollo echo what Reyes said at first reading, and again here at second reading: that the city should receive NEW land from the developers to replace any park land lost to development. The planning director then says that is correct, even though the substitution memo that she herself wrote says otherwise.
Moreover, City Manager Art Noriega – who signed the substitution memo – was sitting on the dais at both first and second readings and knew all about the changed legislation but said nothing to clarify any confusion or misrepresentation.
Commissioners Reyes and Carollo clearly believed that what they affirmatively stated on the record at a City Commission meeting – and was confirmed by the Planning Director – would prevail.
Did Planning Director Lakisha Hull knowingly mislead the Commission? It certainly appears that way, which would be actionable under the Miami-Dade County and City of Miami Citizens’ Bill of Rights.
It will be interesting to see what our newly appointed Inspector General Tony Diaz has to say.
Lastly, the official videos of these events are even more convincing than the transcripts. Click here to watch first reading, starting at 1:47:41 on the timeline. Watch the second hearing here, starting at 2:43:46 on the timeline.
Editor’s note: Former City of Miami Planning Director Lakisha Hull — who now holds a similar position in Prince George’s County, Maryland — has not responded to multiple requests for comment from the Spotlight regarding the City Commission’s 2023 approval of Miami’s “no net loss” ordinance.
