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My name is Keith Kato, I am the Executive Director of the Hawaii Island Community Development Corporation, a SOlc3 non-profit corporation whose mission is to provide affordable housing for low and moderate income residents of the island of Hawaii. I am here today to testify on Bill 151 relating to floodways. There can be no disagreement that protection from flooding is a desirable outcome and that there are various means of protection each of which comes with its own costs. Two areas aze of particulaz concern in Bill 151. First, is the requirement that finished floors be at least 1 foot above the adjacent grade. This requirement will make compliance with the ADA requirements more difficult and would be detrimental to our senior rental complexes. For example, our Kailua-Kona Hualalai Elderly Phase 3 project would have to have steeper entry walks to meet the higher floor elevations. This would require hand rails along the walkways due to their steepness. The costs of the handrails would have been $90,000 for the thirty units. We had this priced out. Since the construction costs were already high this added expense would require reductions elsewhere, most likely eliminating ceiling fans, outdoor seating benches, and some trees and shrubs from our landscaping. The unfortunate part is that the raising the floor elevation also makes it more difficult for our seniors to get into their units and does not solve any problems since the entire property is graded to prevent water from entering the units to begin with. We would be implementing a solution for which we do not have a problem. As to stipulating a 25 year intensity storm for drainage calculations, let's looks at an example. We aze planning a 24 unit subdivision in North Kohala for our self help builders. Our engineer has designed the project based on the standazd 10 year intensity flood requirements and re-analyzed it incorporating the proposed 25 year intensity requirement. The difference is significant. The additional drainage facilities would increase the costs by roughly $70,000, as much as the infrastructure cost of an additional lot. A solution offering better flood protection would be to dispose of the run-off into the adjacent gulch. These costs are particulaz to this subdivision in North Kohala. Other subdivisions in other locations will have different costs depending on the general intensity of rainfall, the porosity of the ground, and the difficulty of construction. hi general this will mean higher costs in high rainfall areas and higher costs in azeas with dirt due to its slow percolation. This points to the Hamakua coast, from the Wailuku River to Upolu Point as being significantly impacted by the proposed change. For windward areas on Mauna Loa flows, from Hilo to Kumukahi to Volcano it also means higher costs due to the high rainfall and rocky ground. 598.5 Ref. Ta rtl~t; Ref. Dote. 9ppj