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number of employees and contract workers --all of whom need housing whether they are full are part-time. There should not be a distinction made between persons designated as employees or paid on a contract basis where both are working primarily on site. Making that distinction further encourages business enterprises to hire people on a contract basis rather than on an employment basis---encouraging a less stable labor market. 4 Re' Triggering the application of these requirements on 100 full time emplovee equivalent units: I object to the use of this single point trigger for determining whether there is an affordable housing requirement, furthermore this single point trigger seems exceedingly high. The trigger point of "Individual industrial enterprises generating more than one hundred employees on a full- time equivalent basis' should be revised to a sliding scale for all industrial developments, and as stated above, without regard to whether the person is hired as an employee or on contract and without regard to whether on full time or part-time status. Instead, consider applying the requirement of affordable housing on a sliding scale to all industrial enterprises with more than 4 employees including both full and part-time employees as well as persons paid on a contractual basis for work primarily pertormed on the site. Rationale: If a sliding scale were used, each industrial enterprise would contribute to the affordable housing shortage on a proportionate basis on its level of impact and not have a single trigger point determination. Single trigger points work to artificially determine the size of an enterprise because the developer/employer will make a point to set up this enterprise so as to stay below that trigger regardless of whether doing so makes good business sense otherwise. It does not make sense to exempt out all industrial enterprises because they are not one of the "superbigboys" so to speak. There is an affordable housing crisis on this island, and either the County Council takes that crisis seriously or it does not. 5. Re' Section 2 "Credits Required": The organization of this "Credits Required" section is confusing and so are the subparts (i),(ii), and(iii) to subsection (B). It is not clear how sections (A) and (B) correspond. Section (A) designates the requirement for a type of development, that is "Individual industrial enterprises generating etc". Is there some other type of development that needs to be referenced as well, e,g. "multiple individual developments' or is that really what subpart (B) is talking about. It appears that (B) instead has to do with the TIMING of an approval of an industrial use --i.e. rezonings or plan approvals etc. This section should be redrafted for parallel construction. Suggest that section 11-4(d) be reorganized as follows with subheadings: along these lines: (d) Requirements for Industrial uses. (1) Affected industrial uses: The industrial uses that must...etc (2) Calculation of affordable housing credits for industrial enterprises Individual industrial enterprises and all other developments that include one or more individual industrial enterprises. must earn one affordable housing credit for every 4 lobs created (or for whatever number of jobs you want to designate). (3) Timing of the Calculation of affordable housing credits: (i) At the time of the initial rezoning When the calculation of affordable housing credits is made at the time of the initial rezoning then the potential to generate iobs shall be assumed to be one emplovee for each 1000 square feet of floor space for whatever calculation you decide upon but it sure would be great if you kept that method of calculation simplel (ii) At the time of any plan approval whether for a tentative subdivision PUD (planned unit development) or for a variance or otherwise the potential iob designation shall be assumed to be one emplovee for each 1000 sauare feet of floor space. 6 Re' Determining affordable housing at the stage of final subdivision review secition 11-