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Aaron S.Y. Chung, Council Chair <br />and Members of the County Council <br />County of Hawaii <br />Page 6 <br />The recommended use of the Project District application process and development of an <br />associated conceptual master plan in accordance with the Village Design Guidelines is <br />the only way to fully achieve with the preferred development pattern of the Kahului- <br />Puapua`a Village TOD articulated in the CDP. <br />The applicant also stated that conditions of approval of the requested rezone <br />amendment ordinance could further implement the TOD concept. First, the applicant <br />suggested a condition of approval could designate the project area as a "Neighborhood <br />TOD" site, which would act as a policy statement guiding the development of adjacent <br />parcels should they ever request an entitlement change. A second condition of approval <br />would require Plans for Plan Approval to comply with the Village Design Guidelines <br />articulated in the CDP. According to the applicant, these proposed conditions would <br />allow the Planning Department to guide the gradual development of the TOD with <br />multiple owners, without the need of a master developer or master plan. <br />The Director feels that the CDP has already identified the property and <br />surrounding areas as a Neighborhood TOD, so this does not need to be done through <br />conditions of approval of individual rezone ordinances. Furthermore, this scheme would <br />unnecessarily create a new development process through separate zoning ordinances, <br />when a more appropriate, community -vetted, comprehensive master planning process has <br />already been established in the CDP for development within a TOD. Additionally, the <br />proposed process would shift the burden to the County to act as a de facto project <br />manager for development across multiple parcels by having to monitor implementation <br />conditions of multiple rezone ordinances rather than one Project District ordinance and <br />associated master plan as recommended by the CDP. Furthermore, the existing RM -2.5 <br />zoning limits density to 2,500 square -feet per residential unit and excludes commercial <br />uses. Therefore, the mixed -uses and densities recommended for TOD cores cannot be <br />established under the current zoning. <br />Finally, the applicant indicated that the requirement of a Project District is <br />unworkable as the combined size of parcels making up the project area is approximately <br />29.85 acres (14.872 acres for Suffolk Investments, LLC and 14.973 acres for Pua`a <br />Development, LLC respectively), which is less than the minimum 50 acres required by <br />code for a Project District. <br />Based on a review of County Real Property Tax (RPT) and State Department of <br />Commerce and Consumer Affairs (DCCA) records, the subject 14.872 -acre property is <br />owned by Suffolk Investments, LLC. Pua`a Development, LLC is the only listed <br />managing member of Suffolk Investment, LLC. Pua`a Development, LLC also owns all <br />