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CONCLUSION <br /> We have reviewed the most recent provisions of Bill 151, Draft 2, and have <br /> communicated with professional engineers, the Hawaii community and developers. <br /> Based on this review, LURF is strongly opposed to Bill 151, Draft 2 in its present <br /> form, for reasons including, but not limited to, the following: <br /> • Bill 151 includes additional arbitrary requirements which are not based on <br /> scientific or engineering principles, practices and considerations; <br /> • The additional arbitrary requirements far exceed the requirements of the <br /> Natlonal Flood Insurance Program ("NFIP") and other federal and state <br /> requirements; <br /> • The additional arbitrary requirements will result in additional professional and <br /> construction costs which will be passed on and could result in price <br /> increases too high for Hawaii County residents who are first-time home <br /> buyers and small businesses. <br /> • The additional arbitrary requirements unreasonably restrict the use of private <br /> property; and <br /> • The additional arbitrary requirements thus constitute an unconstitutional taking <br /> of land." <br /> Based on the above, LURF respectfully requests that Bill 151, Draft 2 be killed, <br /> as it is not in the best interests of the Hawaii community. LURF continues, <br /> however, to fully support the intent of the original Bill 51 - to ensure compliance with <br /> various federal and state regulations, and respectfully recommends that the Council <br /> pass Bill 51, Draft 5, which exclusively addresses the requirements necessary for <br /> compliance with the NFIP. <br /> Thank you for the opportunity to express our views on this matter. <br /> Cc: Corporation Counsel, County of Hawaii <br /> <br /> J:\Counties\County of Hawaii\Bill 51\071106 Bill 151 LURF Testimony.doc <br /> 3 <br /> <br />