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o©~_ Castle & Cooke 100 Kahelu Avenue Hawaii ~ Mililani, Hawaii 96789-3997 P.O, Box 898900 Mililani, Hawaii 96789-8900 JUne 1, 2007 (808) 548A811 Fax (808) 548-6670 The Honorable Pete Hoffman Council Chair & Presiding Officer Hawai i County Council 25 Aupuni Street Hilo, HI 96720 RE: BILL 51 (DRAFT 3) - Hawai i County Council Meeting, Friday, June 1, 2007 - 9AM Aloha Chair Hoffman and councilmembers: I am Richazd Mirikitani, Vice President and General Counsel of Castle & Cooke Homes Hawaii, Inc. ("Castle & Cooke"), testifying in opposition to Bi1151 because of the negative impacts it may have on property owners and because of discrepancies raised by the State Department of Land and Natural Resources, the County of Hawaii Department of Public Works and other professional trade organizations. Castle & Cooke supports the improvements to storm water management and applauds the county's effort to update Hawai' i County Code to comply with the National Flood Insurance Program (NFIP). However, we strongly believe there ought to be more time for the administration and other stakeholders to analyze the potential impact of proposed changes to the county code, particulazly since several discrepancies have been raised regarding the current version of this bill. Because state and local governments aze modernizing their respective flood control management practices to become compliant with NFIP standazds, the Federal Emergency Management Agency (FEMA) recognizes that outreach to affected property owners, and a wide range of professional and service groups is an important element to providing valuable input in this process. For example, communities azound the country have participated in Flood Map Modernization, an effort led by FEMA to create updated, digital flood hazard maps in partnership with state, regional and local government agencies as well as with stakeholder groups. Map Modemization has been conducted with the cooperation and support of the organizations including builders, realtors, insurers, planners, and citizens groups. To ensure that stakeholders were actively involved in the process, and understood the effects that map changes might have, some counties formed a Stakeholder Advisory Group. This type of group has also aided in formulating an outreach plan, reviewed material and has helped educate stakeholders and constituents about the coming changes. Castle & Cooke Hawaii consists of the Hawaii subsidiaries of Castle & Cooke, Inc, which include Castle & Cooke Homes Hawaii, Inc.,Castle & Cooke Properties, Inc., Qstle & Cooke Resorts, LLC and other subsidiaries