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require the establishment of the depth of the "100-year flood" An agricultural subdivision or erection of agricultural structures may require preparation of a flood study. (Sec. 27-20(b), (d), and (e)) Developments and farms will need to retain and handle the runoff from the "one-hundred year" storm. I think this part of the proposal is generally unattainable. (Sec. 27-20(g)) Discussion of Effects to Farmers. Ranchers and other Acricultural Producers The immediate impact of the proposed ordinances to farmers and ranchers is unclear. Certainly, new farms and developments in West Hawaii would be put under the requirements of the new ordinances if passed. The requirement for existing operations to comply with the water retention requirement or mapping of the 100-year flood depth may overload the County engineering sections. It would be expected that permits for new structures or modifications to streams and watercourses would trigger the need for the flood management improvements on existing operations. Review and approval of Conservation Plans by the Soil and Water Conservation Districts (SWCDs) may require a review for compliance with the stormwater ordinances. Cooperators may opt out of their conservation plans if it triggered the need to install the proposed compliance measures. The requirement for 100-year flood capacity in watercourses may be interpreted to conflict with the NRCS capacity standards for water control structures. Until the effects of this change are more closely examined, it appears the size of these water control structures will increase in size in order to meet the capacity requirements thereby possibly taking agricultural lands out of production. In addition, it is doubtful that the NRCS financial assistance programs will fund the additional costs to comply with the County requirements. Unless the County provides financial assistance to agricultural operators to meet this proposed requirement, the farmer will inevitably bear the burden for the additional costs and potential loss of productive agricultural lands. The additional costs to farmers and rancher imposed by compliance with the stormwater ordinances will add to the already difficult financial position of the agricultural producers brought on by higher energy and feed/nutrient costs. It is likely that many operations will not financially survive. The result of fewer farmers and ranchers will be higher food costs to the public, less food security for the state, and more open land brought onto the market for non-agricultural development. Discussion on the Process to Improve Floodolain Management