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<br /> JUL 13 20C7 10:30flM ROTH KIHURR LLP 808 324 6078 p.2 <br /> July 11, 2007 County of Hawaii -Bill 51, Draft #5 Page 2 of'6 <br /> comments liom the civil engineering community in regazds to issues ofhydrolo);y and NFIP <br /> cotnpliance. <br /> Below is a brief analysis of seven items that we consider highly problematic: <br /> Item #1. See Page 6: <br /> Section 27-5. Appdcabllity. <br /> (b) This chanter shall apply to other areas of IIood hazard: <br /> (1) Zone X -shaded (moderate hazardl <br /> (2) Zone X -not shaded (minimal hazard) <br /> We recommend that all of the language above in (b) be deleted. Zone X (shaded) and Zone <br /> X (not shaded) are not considered "Special Flood Hazazd Areas" as indicated in the Legend <br /> on 'he FIRM maps issued by FEMA. An unintended consequence is that the entire Island of <br /> Hawaii could be defined as a flood hazazd azea. This might result in property ownars being <br /> req aired by lending institufions to buy flood insurance instead of it being an option. I3uc to <br /> the potential conflict with Federal law, in-depth analysis needs to be conducted in regards to <br /> this issue. <br /> Item #2. See Page 27: <br /> Section 27-18. Standards for construction. <br /> Standards for construction within areas of special flood hazazds aze establishrd as <br /> fol I~>ws: <br /> (d) Elevation and floodproo6ng. <br /> (5) Within Zone X (shaded): <br /> (A) For new conskvction, the lowest floor shall be elevated_at least two <br /> teat above the highest adiacent grade. <br /> B) New rnnstruction shall be required to provide adeauate drainage <br /> paths around structures on slopes to guide floodwater around and <br /> away from proposed structures. <br /> (C) Improvements to repetitive loss structures, and substantial <br /> improvements shall rnmply with the standards of section 27-24.1 <br /> Standards for Zone X. <br /> (6) Within Zone X (not shaded): <br /> (A) For new construction. the lowest floor shall be elevated_at least oue <br /> foot above the highest adiacent grade. _ <br /> (B) New construction shall be reauired to provide adeau.ate drainage <br /> paths around structures on slopes to gpide floodwater around and <br /> away from proposed structures. <br /> P,O. Box 624 Holualoa, HI 96725 808-987-6146 kimuraCalum.mit.edu <br /> <br />