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<br /> JUN 28 2007 6:57PM ROTH KIMURR LLP 808 324 6078 p.2 <br /> Juoe 26, 2007 County of Hawaii - Bitl SL Page 2 of 2 <br /> Mary qualified professionals have submitted over 30 pages of commentary in regazds to Bi115] <br /> to aid in your review of the Bill and we have participated in the ad hoc committee in this regard. <br /> We have reviewed Bi1151 Proposed Draft #5, An Ordinance Amending Chapter 27 Flood <br /> Control, and still see great problems with the added language that goes beyond NFIP <br /> compliance. We are particulazly opposed to the revised definition: "Floodplain or flood-prone <br /> area" means any land azea susceptible to being inundated by water (which includes the entire <br /> Isla~td of Hawaii) from any source...".2 Properties that have ntinirnal threat of flooding will now <br /> be subject to this chapter of the Code. For example due to the revised defmition, there will be no <br /> stru~:tural fill allowed anywhere on the entire Lsland of Hawaii3. We are also opposed to: <br /> "Require that all new subdivisions and developments, regardless of the Flood Zone, provide for <br /> stornwater nmoff detention to at least the 100-year-storm event on that property or pazcel, for <br /> later release at a restricted rate after the storm subsides"". This will result in a dam-like structure <br /> at tte bottom of every parcel on the entire Island of Hawaii to collect water for later release. A <br /> typi:al drywell or catchbasin will not work to detain stormwater as these drainage systems <br /> percolate water into the ground immediately. To trigger this requirement, understand that the <br /> deft rition of developments is basically any man made change to real estate. These aze only two <br /> exatnples of many that begin to illustrate the problems with Bi1151 Proposed Drafr #S. <br /> We are greatly concerned with the September 2007 deadline to have Chapter 27 amended so that <br /> the County is compliant with the National Flood Insurance Program. We have four <br /> recetnrrtendations. First, the Council needs to bring forth a revised bill that is stripped of all <br /> mandates that have not been properly analyzed and recommended by licensed professionals so <br /> that the County can be in compliance with NFIP. Second, identify instances where problem <br /> flooding has occurred. Third, hire qualified consultants to analyze why flooding occurred in <br /> those instances and present their findings to the public. Fourth, move forward with legislation <br /> anrLor capital improvement projects that aze aimed directly at the true problems. <br /> We thank you for the opportunity to be a member of the ad hoc committee and welcome any <br /> dialogue with you as we continue to work together to improve Bill 51. <br /> Sincerely, <br /> American Institute of Architects, Hawaii Island Section, Executive Committee <br /> Robert Nespor, AIA President Robin Inaba, AIA Vice-President <br /> Johu Dinmore, AIA Treasurer Karl Kimura, AIA Secretary ~ ~ <br /> Cletnson I.arrt, AIA Past-President John Parazette, AIA Past-Treasurer <br /> Terrance Cisco, AIA Director Peter Vincent, AIA President -AIA Honolulu <br /> Terry Dunlap, AIA Bill 51 ad hoc committee member <br /> Richazd Myers, AIA Chair, Building Science and Performance Committee of AIA Honolulu <br /> CC' Wes[ Hawaii Today, Hawaii Tribune Herald, Honolulu Advertiser, Ma}'or Harry Kim <br /> z Ibid ,page 9, Secfion 27-12 "Flood plain or flood-prone area" <br /> 3Ibid, page 4, Section 27-4 (q (5) <br /> Ibid, page 4, Section 27-4 (j) <br /> 5 Ibid, page 8, Section 27-12 "Development" <br /> PA. Box 624 Holualoa, HI 96725 808-987-6146 kimura@alum.mit.edu <br /> <br />