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which Stafford had requested and was denied.45 While analogizing to Nollan and Dolan, the court reasoned: It is enough to say that we can find no meaningful distinction between the condition imposed on Stafford and the conditions imposed on Dolan and the Nollans. All were based on general authority taking into account individual circumstances. Dolan's request for a variance was denied. The Town was authorized to grant, and did grant, exceptions to the general requirement that roads abutting subdivisions be improved to specified standards. Stafford applied for an exception and was refused, but the Town nevertheless considered whether an exception was appropriate.4~ Moreover, a number of other jurisdictions, like the United States District Court for the Eastern District of Virginia, Washington, and Ohio, also apply Dolan to legislative exactions, but have not explicitly decided the issue.47 The Hawaii appellate courts have not decided this issue, and indeed, in In re Water Use Permlt Applications,48 the Supreme Court of Hawaii declined to address it, stating that "[w]e need not address the additional question whether and to what degree Nollan and Dolan extend beyond land dedications to include monetary exactions such as those presently at issue."49 as /d at 624. td at 641 (footnotes omitted). The ordinances of the County of Hawaii which require affordable housing requirements, do not provide for variances from such requirements. Thus, the applicability of the analysis in Town afFdower Mound v. Stafford Estates Ltd. Partnership, 135 S.W.3d 620, 641 (Tex. 2004) (footnote omitted), is questionable. See Nat'l Assn of Home Burlders v. Chesterfield County, 907 F. Supp. 166, 168 (E. D. Va. 1995), afPd, 92 F.3d 1180 (4th Cir. 1996); Home Builders Assn v. City ofBeavercreek, 729 N.E.2d 349, 356 (Ohio 2000); Trimen Dev. Co. v. Krng County, 877 P.2d 187, 194 (Wash. 1994) (en banc). °8 94 Hawaii 97, 9 P.3d 409 (2000). av Id at 184 n.102, 9 P.3d at 496 n.102 (citations omitted). 12