COM 0598.012 2006-2008 - Laserfiche WebLink

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HLPC Testimony 22 August 2007 Re: Bill 151 Specific concerns identified then and subsequently, include and are not limited to: • Chapter 27: Section 27-10 which is not proposed to be amended, currently reads in part that "The degree of flood protection required by this chapter is considered reasonable for regulatory purposes and is based on scientific and engineering considerations." In the session on technical issues, DPW representatives distributed ahand-out which stated the "Goal of this proposed ordinance is to have the Hawaii County Code adopt requirements that exceed the minimum needed to participate in the National Flood Insurance Program." HLPC is fully supportive of adopting additional requirements to ensure compliance with and participation in the National Flood Insurance Program (NFIP), and understand that these additional NFIP requirements were imposed after considerable scientific and engineering review by many participants including and not limited to; Federal Emergency Management Administration (FEMA), U.S. Army Corps of Engineers (ACE), and National Resources & Conservation Services (NRCS). HLPC is also committed to work with the County to identify and adopt additional requirements that exceed NFIP compliance if warranted. However to date, the authors of Bill 151 have offered no scientific and engineering considerations to support the need to "adopt requirements that exceed the minimum needed to participate in the National Flood Insurance Program." Previous efforts to amend Chapter 27 via Bill 51 were challenged by this lack of "scientific and engineering considerations' and the authors of Bill 151 have repeated this flaw which serves to underscore additional concerns noted as follows. • Section 27-5. Applicability. Bill 151 proposes to amend this section by stating that this chapter shall apply to: "All areas within Zone X -shaded (moderate hazard) and Zone X -not shaded (minimal hazard)." Zone X -not shaded affects 98% of the island/County of Hawaii yet no "scientific and engineering considerations" have been introduced to support inclusion of Zone X as an area of special flood hazard. This absence of scientific and engineering considerations begs to question whether this inclusion qualifies to be "considered reasonable for regulatory purposes." • Section 27-18. Standards for construction. Bill 151 proposes to amend this section's heading to Standards for construction in special flood hazard areas. While Zone X -shaded and not shaded are not called out specifically in the amended section in Bill 151; language in Section 27-5 states that Chapter 27 shall apply to "All areas within Zone X...." Page 2 of 4