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<br /> Honorable Pete Hoffman, Chairperson <br /> <br /> Testimony In Opposition To bill 51, Draft 4 <br /> <br /> 7/6/2007 <br /> <br /> Page 2 of 3 <br /> 3. The Council has not presented facts to support the claim of a severe island-wide flooding <br /> crisis. We believe that there should be more investigation on the severity and frequency <br /> of flooding on the island including analysis of injuries, deaths and property damage. A <br /> cost benefit analysis should be undertaken before imposing even stricter island-wide <br /> flood control regulations. Before assuming that the proposed amendments will cure the <br /> flooding crisis, a study should be undertaken by professionals to determine causes of <br /> flooding and make recommendations on mitigation measures that may alleviate some of <br /> the problems. It is important to remember that tax dollars will be used to construct and <br /> maintain additional drainage measures imposed by this ordinance. The Council has an <br /> obligation to the taxpayers to assure that the increased costs will have a net benefit. It <br /> may be that tax dollars are better spent on regional improvements to specific areas that <br /> are currently experiencing frequent flooding. <br /> 5. The Council has failed to demonstrate that developments designed with the current <br /> standards are experiencing frequent flood damage. There are large undeveloped areas <br /> above the urban areas that contribute a large amount of water to flooding situations. <br /> There are existing flood control measures undertaken by the Soil Conservation Service <br /> and NRCS such as the diversions above Kainaliu that have been successful in mitigating <br /> frequent flooding. It is the Council's duty and obligation to the taxpayers to investigate <br /> whether additional flood mitigation projects would be a better use of taxpayer dollars <br /> than the measures proposed in the amendments. <br /> 6. The proposed amendments were made without review by the Department of Public Works <br /> or any other professionals. It was Teamed at the ad hoc committee meeting that the <br /> proposed amendments and definitions were cobbled together from the Intemet and the <br /> Council's interpretation of FEMA documents. As engineers, we believe that background, <br /> education and experience are required to properly interpret FEMA documents and items <br /> related to drainage and hydrology found on the Internet. It is disconcerting that the <br /> Council feels they are qualified to make extensive amendments to a code that deals with <br /> engineering issues without concurrence or consultation with the Public Works <br /> Department or any other professional engineers. Without a rigorous engineering <br /> analysis, it is impossible to predict whether much of what is being proposed in drafts <br /> beyond draft 1 put the citizens of this community at greater risk, rather than improving <br /> public health and safety as is it's apparent intent. <br /> 7. Because the proposed amendments make the code difficult to interpret and apply, we feel <br /> that it will be subject to legal challenges that will have a severe impact on many people, <br /> including the taxpayers who must pay for the County attorneys who will be called upon <br /> to defend the code. <br /> Hawaii Soeiety of Professional Engineers <br /> <br /> a state society of the National Society of Professional Engineers <br /> <br /> Kona-Kohala Chapter • do 755749 Kalawa Street • Kailua-Kona, H196740 <br /> <br />