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It appears that the current proposals reflect good intentions. However, imposing <br /> <br /> these requirement will pose undue hardship on agricultural producers in Hawaii <br /> County. <br /> SWCDs and NRCS have always actively supported efforts to publicize and <br /> address the flood problems on the Big Island, especially for West Hawaii. The <br /> rapid expansion, on the Kona coast, of housing development, and intensified <br /> grading and land modification by new farmers in the past ten years, has raised <br /> concerns from the SWCDs, NRCS and other partners. Proponents of wise <br /> management of floodplain resources in West Hawaii have advocated for 1) <br /> detailed mapping of the floodways and flood zones, 2) strict enforcement of <br /> existing floodplain ordinances, 3) responsible conservation planning for farms <br /> <br /> and ranches, including limitations on grading and opening of forested upper <br /> <br /> watershed areas, 4) a more open process for review of subdivision and <br /> <br /> development plans. <br /> It appears the drafters of the current proposals intend to resolve the flood issues <br /> by two strategies, 1) prevent any runoff from new developments and farms, from <br /> rainstorms up to and including the 1 % event, from leaving the property and 2) <br /> requiring all new or altered drainageways and watercourses to provide a 100- <br /> year storm capacity. Neither is likely to be physically or economically feasible for <br /> farmers or developers. Neither is a requirement of the National Flood Insurance <br /> Program administered by FEMA. <br /> We recommend FEMA's National Flood Insurance Program and its model <br /> ordinances should be used to guide the improvement of the County of Hawaii's <br /> Floodplain Management Program. The relatively unique and pressing flood <br /> management issues in West Hawaii should be addressed with more detailed <br /> mapping and identification of the flood hazards, better enforcement of the <br /> existing regulations, and more transparency in the application and approval <br /> process for land modification and development. <br /> Next Steos <br /> While the current goal is to prevent the proposed ordinance changes from being <br /> approved, the long term goal should be the reduction of flood threats throughout <br /> the Big Island and, especially, in West Hawaii. Reiterating, flood management <br /> issues in West Hawaii should be addressed with more detailed mapping and <br /> identification of the flood hazards, better enforcement of the existing regulations, <br /> and more transparency in the application and approval process for land <br /> modification and development. <br /> In addition, the important conservation work carried out by the Soil and Water <br /> Conservation Districts and NRCS to reduce floodwater discharge, erosion, and <br /> <br /> flood damage should be recognized. Particular mention in the stormwater <br /> <br />