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Page 22: Item F still includes for jurisdiction lands over 10% and a 40% lot coverage by impervious surfaces. It also makes a statement about development containing its own runoff without determining a standard. In the absence of a standard it is not clear if we are containing a 10 year storm, 25 year or 100 year storm unless we assume it is a 25 year storm based on other language in the draft. This vagueness increases director's discretion which adds uncertainty and additional risk to the process. Page 22-24: This section adds an additional freeboard requirement to construction between 1-3 feet. This affects the type of construction that is feasible and requires an additional elevation of structures. This affects handicapped accessibility, design and construction costs for buildings within these zones. There is no basis for the proposed amendment. Page 25: Within zone X there are requirements to add a 1-2 feet elevation of the lowest floor from the adjacent grade. First, it is not clear what adjacent grade means (within the project site next to the building or in reference to adjacent parcels of land). If it is on the project site it will then prohibit slab on grade construction and require arbitrary elevation of structures in zone X by one to two feet. This also adds to construction costs and creates problems with handicapped accessibility. To me there is no rationale behind the required increase in freeboard elevation for all the zones. As I have said in previous presentations, a case by case professional analysis is better than a blanket condition over such a vague zone as zone X. Page 30: The draft raises the new storm drainage standards to cone-hour 24 hour storm event. While this may not be excessive, it is a change in increased stringency without a good rationale for it. It still seems to me that the whole effort of Ms. Ford's amendments to this bill tries to fix a problem resulting primarily from illegal grading with a change in regulatory standards. It is like using a screwdriver to pound in a nail. It is the wrong solution to the problem it is trying to address. Page 31: The first paragraph gives the flood plain administrator the authority to require a higher standard than a 25 year storm event. While I do not have any specific problem with giving the director more discretion it is a little disconcerting to have this increase in authority without placing some criteria or guidelines for such discretion. Is it for safety, uncertainty of the facts, unique conditions or simple whim? It does not state the basis for any of the changes (i.e. why a 25-year event) say. I think criteria should be added. Respectfully submitted, GROUP 70 INTERNATIONAL, INC L~ George Atta, AICP Principal Planner for La'ipala Heights Group 70 International, Inc. • Architecture • Planning • Intedor Design • Building Diagnostics • Assets Management • Environmental Seances 925 Bethel Streel, 5th Floor • Honolulu. HawaYi 96813-0307 • Ph (808) 523-5866 • Fax (808) 523-5874 • w.xv.group70int.ram • mail~group70intcom