HomeMy WebLinkAboutCOM 0998.007 2006-2008
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SLIMOCARLSMmi.COM OUR REFERENCE NO.:
05BB225-1
April 7, 2008 0
VIA HAND DELIVERY 0 n
C.
Honorable Angel Pilago, Chair = .a
and Members of the Committee on Planning
Hawaii County Council
333 Kilauea Avenue, Second Floor y- rv
Hilo, HI 96720 ro
Re: Kohala LLC - Bill No. 237
Tax Map Key No. (3) 5-9-001: 008 (37.88f acres) at North Kohala, Hawaii
Planning Director-Initiated Downzoning Change of Zone (REZ 07-000067)
From RS-15 District to RA-5-a District. and Repeal of Ordinance No. 97-102
Dear Chair Pilago and Members of the Committee on Planning:
We represent Kohala LLC, the owner of the above referenced property located in North
Kohala (the "Subject Property On April 1, 2008, upon immediately being informed of the
Committee on Planning agenda for April 8, 2008, I submitted a letter informing the Committee
on Planning that Kohala LLC and I would be unable to attend. We requested deferral to the next
meeting scheduled for April 21, 2008. By letter dated April 4, 2008, Chairman Angel Pilago
informed our office that despite our request, he would recommend that full discussion and action
be taken on the above-referenced matter at the April 8, 2008 meeting. As I cannot attend the
Committee on Planning meeting, I wish to submit this written testimony and again request that
Kohala LLC be allowed to make its full presentation on this important matter at the next
scheduled meeting on April 21, 2008.
We are writing to inform you of serious legal issues that will arise should the Hawaii
County Council approve the Planning Director's request to downzone the Subject Property from
RS-15 to RA-5a and repeal Ord. No. 97-102 (collectively the "Downzoning"). The proposed
Downzoning is illegal, the procedures followed to effect the proposed Downzoning are illegal,
and the failure to consider reasonable alternatives to the proposed Downzoning is likewise
illegal. We appreciate your consideration of these issues and believe that after consultation with
Corporation Counsel, you and the other members of the Hawaii County Council, will agre at~ A
Gomm. No. ' I
Ref. Tol fro i Ow ~
Ref. Dote
HONOLULV KAPOLEI HILO KONA MAN GUAM SAIPAN LOS ANGELES
Honorable Angel Pilago, Chair
April 7, 2008
Page 2
the numerous legal defects with the proposed Downzoning mean that the Council cannot comply
with the Planning Director-Initiated Downzoning at this time.
The Downzoning is illegal for the following reasons: (a) it amounts to a taking without
compensation; (b) it is a violation of Kohala's rights of substantive due process; (c) it is a
violation of Kohala's rights of procedural due process and possibly in violation of Kohala's rights
to equal protection under the laws; and (d) it contravenes Hawaii's Environmental Protection
Act, Chapter 343, Hawaii Revised Statutes.
1. Taking Without Compensation
Currently Kohala has the right to develop 50 single family lots on the Subject Property.
Under the Downzoning, Kohala would be able to develop no more than 7 single family lots. In
other words, in enacting the Downzoning the Council would make Kohala suffer an 85%
reduction in the number of permitted lots, a huge taking of Kohala's property interests. This
matter is best explained by Professor David L. Callies, property law professor at the William S.
Richardson School of Law and published author of numerous books and articles on the law of
takings. Please see Professor Callies' letter to me, dated March 25, 2007, enclosed herein as
Exhibit A.
II. Substantive Due Process Violations
The right of substantive due process (protected under the U.S. and Hawaii State
Constitutions) means that an individual is protected from unfair and arbitrary governmental
action. Governments cannot be discriminatory and apply laws with an "evil eye" or
"an unequal hand." The Downzoning smacks of bias; it is unfair, irrational and arbitrary, and if
passed will give rise to Kohala's claim for denial of its rights of substantive due process.]
Why is Kohala being targeted as the sole landowner to face such an involuntary
downzoning? The County simply does not do this. In fact, over the past 8 years, the County has
not processed any involuntary downzonings. According to the Planning Director, the last
involuntarily downzonings occurred in 1982, more than 25 years ago, and even those 1982
downzonings were in response to the General Plan amendment in 1979. This history is more
fully described in my letter of March 18, 2008, to Chairman Rodney Watanabe and copied to
you. Since Kohala's first appearance in front of the Planning Commission in July 2007, we have
been asking "why Kohala LLC?" Seven months later, with the benefit of a lot more research into
the Planning Department's files, we still do not understand why the Planning Director has
decided to make Kohala LLC the sole target for the Downzoning.
i A very recent Ninth Circuit decision made clear that property owners have independent causes of action
with respect to takings claims and due process claims. In other words, Kohala is free to file an action on its takings
claim (taking of property without just compensation) separate from any due process claim (victim of irrational and
arbitrary land use regulations). See Crown Point Development, LLC v. City of Sun Valley, 315 F.3d 851 (9th Cir.
2007).
Honorable Angel Pilago, Chair
April 7, 2008
Page 3
A. Nothing Has Changed
Because of the 1979 General Plan amendment, the 1982 downzonings made sense. The
General Plan designation of the properties had changed to less intensive uses and the
downzonings were enacted to bring the properties into compliance with the amended General
Plan. Such is the proper procedure the County must follow when passing downzoning
ordinances. However, in Kohala's case there was no General Plan amendment to trigger the
Downzoning. Despite the opportunity to amend the General Plan in 2005, the LUPAG
designation of the Subject Property is the same today as it was when Ord. 97-102 was passed;
mostly Low Density Urban with a portion of Extensive Agriculture and a swath of Open along
the shoreline. Nothing has changed, therefore the Downzoning is illegal 2
The State Land Use designation for the Subject Property is, as it was at the enactment of
Ord. No. 97-102, Urban. Therefore, the Low Density Urban LUPAG designation is appropriate
and accordingly was not changed during the 2005 General Plan amendment. In contrast,
property directly to the north (TMK No. (3) 5-9-003: 001), is within the State Land Use
Conservation District. Thus, in 2005 it was recognized that the Extensive Agriculture LUPAG
designation was not appropriate, and it was changed to Conservation. See E-6 on North Kohala
map 2 and Bill 163, enclosed herein as Exhibit B. Similarly, property to the south was changed
from Medium Density Urban to Low Density Urban (See E-5). Most importantly, the Subject
Property was not touched. If the County truly believed that RS-15 zoning was no longer
appropriate, why did it fail to alter the LUPAG designations in 2005, when obviously it was
scrutinizing the zoning and LUPAG designations in the surrounding areas?
Today, just like in 1997, the Subject Property is identified as an area of Natural Beauty
under the General Plan. Obviously that designation is consistent with RS-15 zoning, otherwise
Ord. 97-102 would never have been enacted. In his Background Report, the Planning Director
attempts to support the Downzoning by explaining that the surrounding properties are zoned A-
sa. What he fails to mention is that the surrounding properties were zoned A-5a in 1997, when
Ord. 97-102 was enacted. See Zoning Map attached to Ord. 97-102, enclosed herein as Exhibit
2 In 1997 the Planning Director made specific findings that the Kohala LLC proposed 50-lot RS-15 zoned
residential subdivision complied with the General Plan:
The proposed development is consistent with the County General Plan and
Zoning Code. The proposed project does conform to the General Plan Land Use
Patten Allocation Guide (LUPAG) Map, which designates this area for Low
Density Urban. Lot Density designation refers to single family residential in
character, ancillary community and public uses and convenience type
commercial uses. This designation does not refer to density limitations however,
this designation generally has been at a density of 4 units per acre. The average
density relating to the proposed request (50 lots over 38+ acres) would amount
to 1.5 units per acre. Therefore, it is determined that the request is consistent
with the urban form depicted on the LUPAG Map for this area of North Kohala.
See SMA Permit No. 379 at 4.
Honorable Angel Pilago, Chair
April 7, 2008
Page 4
C. The Planning Director's Background Report insinuates that the Downzoning will somehow
be more consistent with the Natural Beauty goals under the 2005 General Plan. The General
Plan's Natural Beauty goals are exactly the same today as they were when Ord. 97-102 was
enacted. The same can be said for the Natural Beauty Standards. The Natural Beauty policies
are almost identical today as they were in 1997, and the minor changes cannot fairly be called
significant, especially in light of the overall maintenance of the entire Natural Beauty section.
111. Procedural Due Process and Equal Protection
The Council may not pass laws without following proper procedures. Alarmingly, from
the start, the Downzoning has been pushed along with less than scrupulous regard for public
notice or landowner notice requirements. These issues are set forth more fully in my letter to the
Planning Commission dated December 7, 2007, and to County Clerk Jarman, dated February 1,
2008, copies of which are enclosed herein as Exhibits D and E respectively. Procedural
irregularities give rise to Kohala's claim that its rights to procedural due process have been
violated.
Uneven application of County procedures and disregard of Kohala's numerous attempts
to find a workable solution to address the Planning Director's concerns, raise questions over
whether Kohala is being provided equal protection under the laws. Despite its strong legal
position, Kohala remains open to working with the County to find a legal and fair way of
addressing the concerns raised in the Planning Director's Background Reports. Kohala has
offered to voluntarily bring its permitted lot count from 50 to 25. To date, Kohala's attempts
have been rebuffed, strengthening its belief that the Downzoning is not a fair and rational
legislative action, but rather an irrational, isolated and targeted attack.
IV. Non-Compliance with Haw. Rev. Stat. § 343 Requirements
By the Planning Director's own words, an environmental assessment must be prepared
prior to this proposed Downzoning. Therefore, the Downzoning cannot be enacted until an
EA/EIS is conducted. See Planning Director's memorandum to County of Hawaii staff dated
October 3, 2007, enclosed herein as Exhibit F. The Planning Director's memorandum states
that:
[A] rezoning or a county council state land use boundary
amendment is not the type of approval that will create the need for
an EA, because state law defines the EA trigger as an "agency
action", and the county council is not an "agency" under Chap.
343. It is not part of the executive branch of government.
However, a rezoning is almost invariably followed by a
subdivision or plan approval, which is an "agency action."
Because Chap. 343 says that an EA should be done at the earliest
practicable time, if a rezoning has a "trigger" for an EA, and if it is
Honorable Angel Pilago, Chair
April 7, 2008
Page 5
not exempt, and if the rezoning is going to be followed bya
subdivision or plan approval, then the EA should be done prior to
the rezoning. In the case of a rezoning that would not be followed
by a subdivision or plan approval (which is probably rare), no EA
will be required, even if there is a trigger. (Emphasis added.)
Exhibit F at 3.
By the Planning Director's admission, it is anticipated that the Downzoning would be
followed by a subdivision of the Subject Property into 7 lots. Therefore, processing of an EA
pursuant to the requirements of HRS Chapter 343 must be conducted prior to the Downzoning
being enacted by the Council. Failure to follow stated County procedure with respect to
rezonings and the preparation of an EA will only further Kohala's claims of substantive and
procedural due process violations.
V. Conclusion
We respectfully request that the Planning Committee take these serious issues into
consideration. The proposed Downzoning is illegal, unfair and unnecessary. Kohala has
demonstrated a willingness to work in collaboration with the County to find acceptable and legal
development criteria for the Subject Property. However, in the absence of any such
collaboration, Kohala has also demonstrated a willingness to fight hard to retain its valuable and
Constitutionally protected rights. At a minimum we ask you and the Council to defer action on
the proposed Downzoning at least until the required EA has been prepared.
Very truly yours,
Steven S. . Li
SSL/ghs
Attachment(s)
cc: Kohala LLC
Amy Self, Esq., Attorney for the Planning Director
Casey Jarman, Esq., County Clerk
Lincoln Ashida, Esq., Corporation Counsel
4816.0888-8322.2
' See, Planning Director's Background Report, at 7 (July 10, 2007): "More specific viewplane controls could be
established if an Special Management Area permit is applied for (Subdivision of the property to 5-acre lots would
still need an SMA Permit)." (emphasis added); Planning Director Getter to Committee on Planning, dated March 5,
2008, at 2, "The most important reason to rezone the property to RA-5a is to limit the total amount of development
to preserve some of the open space in the area. This would be much easier to do in a development of seven homes,
as would be allowed under the RA-5a zoning, rather than fifty homes." (emphasis added.)
Steven S.C. Lim
Carlsmith Ball LLP
121 Waianuenue Ave.
P.O. Box 686
Hilo, Hawaii 96721
March 25, 2008
In Re: Kohala LLC Property
Dear Steve,
You have asked that I review certain documents, memoranda and
correspondence in connection with the proposed development by Kohala LLC of a 50-lot
single-family home development on a parcel containing approximately 37 acres in the
County of Hawaii. I understand that the State Land Use Commission has classified the
land in the urban district and the County has classified the land in the RS-15 Single
Family Residential district, but that the County, at the insistence of the County Planning
Director, may soon reclassify the parcel as RA-5a, Residential and Agricultural district.
The result would be to reduce the number of allowable single-family lots from at least
501 to 7. I further understand that Kohala LLC purchased the subject parcel shortly after
it was rezoned to its present classification, and that the parcel is being reclassified
ostensibly because of the lapse - nearly 5 years ago - of a zoning condition requiring the
landowner to obtain final subdivision approval for the proposed 50-lot residential
development within five years of the said rezoning. Lastly, I further understand that the
applicable plans for said parcel are virtually unchanged from the date - more than 10
years ago - that the County reclassified the parcel to its present zoning district, that the
principle reasons given by the Planning Director (besides the lapse of the subdivision
condition) have mainly to do with open space, view preservation and natural beauty, but
that the County Planning Commission found that the proposed 50-lot development would
"not have any adverse environmental or ecological effect" nor any "substantial adverse
impacts on the surrounding area" and would in fact be "consistent with the objectives and
policies of Chapter 205A, HRS, relating to Coastal Zone Management" during the
course of evaluating - and granting - a request for a coastal zone special management
area permit, also approximately 10 years ago.
There are at least two principle problems with the proposed downzoning
which decreases the allowable residential density by over 85%: the downzoning raises (1)
serious partial regulatory taking issues under the 5`h Amendment to the U.S. Constitution,
and (2) serious substantive due process of law issues under the 14`h Amendment to the
U.S. Constitution. The documents you provided also indicate that the County's actions
with respect to Kohala LLC may give rise to grave procedural due process issues under
' Although approximately 107 lots would be pemtined on the 38-acre property under RS-15 zoning,
I understand that the actual pemnitted density under Ordinance 97-102 and SMAP No. 379 is 50 lots.
EXHIBIT A
Steven S.C. Lim
March 25, 2008
Page 2
the 14th Amendment. However, this analysis will briefly address the takings and
substantive due process issues only.
Partial Takings.
The taking of private property without compensation is unconstitutional
under the Fifth Amendment to the U.S. Constitution ("...nor shall private property be
taken for public use, without just compensation.'). While arguably drafted principally to
protect private landowners from physical takings without compensation, since at least
1922 and the decision of the U.S. Supreme Court in Pennsylvania Coal Co. v. Mahon
260 U.S. 393 (1922) a regulation of land which goes "too far" is also a taking for which
government must pay compensation.
A partial taking by regulation occurs when a land use regulation deprives a
landowner of use and value beyond the normal reduction, if any, caused by the necessary
exercise of the police power for the health, safety and welfare of the people, but stops
short of depriving the owner of all economically beneficial use. The government's
rationale for the regulation and the economic effect of the regulation on the landowner
are critical factors which a reviewing court weighs in deciding whether a landowner has
suffered a partial taking of property.
When the County Planning Director suggests - as he does several times in
the documents which I reviewed - that the U.S. Supreme Court found no regulatory
taking so long as there was a single house permitted on a parcel of land, he vastly
overstates the reach of the case he cites: Palazzolo v. Rhode Island, 533 U.S. 606 (2001).
Such a single-house use defeats only a total or "categorical" regulatory taking claim
under Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (1992). As the Lucas case
suggested in footnote eight of its opinion, an owner who has suffered less than a full
deprivation of economically beneficial use "...might not be able to claim the benefit of
our categorical formulation, but, as we have acknowledged time and again, '[tjhe
economic impact of the regulation and the extent to which the regulation interfered
with the distinct investment-backed expectations' are keenly relevant to the takings
analysis generally."
The case cited by the Court, and from which it quotes above is Penn
Central Transportation Co. v. New York City. 438 U.S. 104 (1978), in which the Court
set out the framework for deciding partial regulatory taking cases. The Court suggested
"several factors" which have "particular significance" when it engages in "these
essentially ad hoc, factual inquiries":
1. The economic impact of the regulation on the claimant and, particularly, the
extent to which the regulation has interfered with the distinct, investment-
backed expectations;
2. The character of the governmental action;
Steven S.C. Lim
March 25, 2008
Page 3
3. Whether the taking is physical or if "the interference arises from some public
program adjusting the benefits and burdens of economic life to promote the
common good."
Penn Central, 438 U.S. at 124.
Adjusting the benefits and the burdens - the relevant part of the third
criteria - is probably of little importance after Lucas given the Court's language there
excoriating regulation which merely confers a public good and for which the Court
clearly states the public as a whole should pay rather than a single landowner. From some
of the language which the Planning Director uses, and given some of the material he
cites, one is left with the impression that this sort of "public good" is what he would
prefer to accomplish if he could. That leaves the economic effect on the landowner and
the character of the government's action as the primary focus of a partial regulatory
taking case.
In the present situation, it is difficult to avoid concluding that Kohala LLC
had distinct investment-backed expectations to build at least 50 homes on 50 lots, as
approved by the Planning Commission under the aforementioned SMAP. In other words,
the economic effect on the landowner is substantial, and its distinct - indeed, quite
reasonable under the circumstances - investment-backed expectations would be dashed
should the County downzone the parcel as recommended by the Planning Director.
Certainly the Court has used the investment-backed expectation standard
in conjunction with the other Penn Central standards, thus holding in Hodel v. Irvin. 481
U.S. 704 (1987) that the 1983 Indian Land Consolidation Act took property without
compensation even though the plaintiff had no investment-backed expectations
whatsoever, because the Court deemed the economic impact on the plaintiff otherwise
"substantial" and the character of the governmental action "extraordinary." Hodel. 481
U.S. at 709.
The "character of the government action" standard has "morphed" into
something different from the Court's original meaning in Penn Central. As the Hodel
case cited in the preceding subsection indicates, it no longer means whether the taking
was physical or regulatory (what the Court arguably meant in Penn Central) but rather the
police power basis for the governmental action. Thus, the "extraordinary" nature of the
governmental action in Hodel helped persuade the Court that a partial regulatory taking
had occurred. So also a court in Maine emphasized the importance of the character of the
governmental police power action in preserving sand dunes (citing Penn Central) in
Fichter ex rel v. State Board of Environmental Protection, 2000 WL 33676710
(Me.Super.).
In the present case, all the reasons posited by the Planning Director in
favor of the downzoning of the subject parcel are related to the general welfare, rather
Steven S.C. Lim
March 25, 2008
Page 4
than health and safety, as noted in this letter's opening paragraphs. This is the weakest
leg of the police power - welfare - as well as the least defensible - aesthetics/views. As
the California court of appeals noted in its decision in the First Lutheran case on remand,
courts are willing to balance the equities more in favor of government when the
challenged regulation is for health and safety purposes rather than welfare, and in favor
of the landowner when the challenged regulation is for welfare purposes rather than
health and safety. For all these reasons, Kohala LLC can make a very good case for a
partial regulatory taking of its property without compensation in violation of the Fifth
Amendment under the Penn Central standards and criteria which govern such partial
takings according to the U.S. Supreme Court in Lucas and Palazzolo.
Due Process.
At the heart of a claim for denial of substantive due process is protection
against arbitrary and capricious governmental actions regardless of the process used to
implement such actions. In other words, regardless of the "trigger" that leads the County
Planning Director to seek downzoning of the subject parcel - the running of the 5-year
time period for obtaining subdivision approval - rezoning is essentially a legislative act
that must be done fairly, rationally and without bias. Thus, for example, if it is true that
Kohala LLC stands virtually alone in the class of landowners subject to such rezonings
because it is the only landowner whose property has so been downzoned over landowner
objections, then the process does not appear either fair or rational. The irrationality and
unfairness of the proposed downzoning is further demonstrated by the fact that it has not
been preceded by any parcel-specific changes to the General Plan, despite the fact that
the County of Hawaii did a wholesale amendment to the General Plan in 2005. From the
materials you provided, I understand that the series of downzonings that took place in the
County of Hawaii in the early 1980s was in response to such a General Plan amendment
in 1979.
Questions over fairness were at the heart of at least two U.S. Supreme
Court cases finding government regulation unconstitutional on fairness grounds, one
explicitly on substantive due process grounds, and one implicitly so. In Eastern
Enterprises v. Anfel, 524 U.S. 498 (1998) the Court held that economic regulation could
effect a taking of property. Justice Kennedy's concurring opinion was based on the
ground that the petitioner had been deprived of its substantive right to due process
because of the large financial burden placed on the petitioner. In City of Monterey v. Del
Monte Dunes at Monterv. Ltd., 526 U.S. 687 (1999) the Court expressed concern about
the significantly protracted manner in which the petitioner's applications for development
were treated by the City, even though it ultimately decided the case on Fifth Amendment
taking grounds. It is therefore reasonable to characterize the County of Hawaii's singling
out of Kohala LLC as a situation which at least raises significant substantive due process
issues of fairness and rationality, particularly since, as noted in the opening paragraph of
this letter, virtually nothing about the parcel and its present zoning classification has
Steven S.C. Lim
March 25, 2008
Page 5
changed over the past 10-plus years, with the exception of the naming of a 5-year time
period. This is hardly the stuff of rational bases upon which to make a legislative
determination for a change in zone classification resulting in a drastic density decrease
from 50 lots and residences to seven.
If I can be of further assistance in defining applicable constitutional and
legal principles to this matter, let me know.
avid L. Callies, FAICP, ACREL
Kudo Professor of Law
William S. Richardson School of Law
The University of Hawaii at Manoa
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EXHIBIT B
NORTH KOHALA DISTRICT
North Kohgla 1 Man ffCI to E-3)
E-1 Intensive and Extensive Agriculture to Rural
Location: Halawa
Rationale: To recognize the current State Land Use Rural District at Halawa.
E-2 Urban Expansion Area to Low Density Urban
Location: North side of Hawt
Rationale: The lands between Rawt and the Kohala High and Elementary School
are more suited for Low Density Urban uses
E-3 Intensive Agriculture to Low Density Urban
Location: West of Kahei House Lots in Hawi
Rationale: The area is used for single family residential uses, therefore, the Low
Density Urban designation is more appropriate for the area.
North Kohals 2 Map (E4 toE-J)
E4 Extensive Agriculture to Rural
Location: Portion of the Kohala Estates Subdivision
Rationale: This portion of the Kohala Estates Subdivision is residential-
agricultural in character and will therefore fit the description of Rural.
E-3 Medium Density Urban to Low Density Urban
Location: Kohala Makai area situated northwest of the North and South Kohala
district boundary
Rationale: The area was subdivided into single family residential sized lots.
BILL 163 DRAFT 1
1/16/2002
12
E-6 Extensive Agriculture to Conservation
Location: Along the makai side of Akoni Pule Highway in the vicinity of the
Koha/a Ranch entrance
Rationale: The area is currently within the State Land Use Conservation
District.
E-7 Extensive Agriculture and Urban Expansion to Conservation
Location: South of Mahukong the majority being makai of Akom Pule Highway
Rationale: The area is currently within the State Land Use Conservation
District.
13
NORTH KOHALA DISTRICT
North Kohala 1 Map (E-1 to E-3)
E-1 Intensive and Extensive Agriculture to Rural
Location: Halawa
Rationale: To recognize the current State Land Use Rural District as Halawa.
Modification: Intensive and Extensive Agriculture to Rural Agriculture
E-2 Urban Expansion Area to Low Density Urban
Location: North side of Hawi
Rationale: The lands between How and the Kohala High and Elementary School are more
suited for Low Density Urban uses.
E-3 Intensive Agriculture to Low Density Urban
Location: West of Kahei Houselots in Hawi
Rationale: The area is used for single family residential uses, therefore, the Low Density Urban
designation is more appropriate for the area
E-3a Initiation: Intensive Agriculture to Rural-Agriculture
Location: Malin Ridge
Rationale: Subdivision has one-sere lots similar to RA Designation
North Kohala 2 Mao (E-4 to E-7)
E-4 Extensive Agriculture to Rural
Location: Portion of the Kohala Estates Subdivision
Rationale: This portion ofthe Kohala Estates Subdivision is residemial-agricultural in character
and will therefore fit the description of Rural
Modification: Extensive Agriculture to Rural Agriculture
E-5 Medium Density Urban to Low Density Urban
Location: Kohala Makai Area situated northwest of the North and South Kohala district
boundary
Rationale. The area was subdivided into single family residential sized lots.
E-6 Extensive Agriculture to Conservation
Location: Along the makai side ofAkoni Pule Highway in the vicinity of the Kohala Ranch
entrance
Rationale: The area is currently within the State Land Use Conservation District.
E-7 Extensive Agriculture and Urban Expansion to Conservation
Location: South of Mahukona, the majority being makai ofAkoni Pule Highway
Rationale: The area is currently within the State Land Use Conservation District
BILL 163 DRAFT 2
6/4/2004
9
NOTE: REFER TO DRAFT 2 LUPAG, FACILITIES AND OTHER MAPS
BILL 163 DRAFT 3
11/10/2004
COUNTY OF HAWAII GENERAL PLAN • 82
COUNTY OF HAWAII STATE OF HAWAII
BILL NO. •(9~
n
ORDINANCE NO. 9:' 102
AN ORDINANCE AMENDING SECTION 2S-8-7 (NORTH AND SOUTH KOHALA
DISTRICTS ZONE MAPI ARTICLE 8, CHAPTER 2S (ZONING CODE) OF THE HAWAII
COUNTY CODE, BY CHANGING THE DISTRICT CLASSIFICATION FROM
AGRICULTURAL (A-Sa) TO SINGLE FAMILY RESIDENTIAL (RS-15) AT KAHUA 1ST,
NORTH KOHALA, HAWAII, COVERED BY TAX MAP KEY S-9-01:08.
BE IT ORDAINED BY THE COUNCIL OF THE COUNTY OF HAWAII:
SECTION 1. Section 254-7, Article 8, Chapter 25 (Toning Code) of the Hawaii County
Code, is amended to ghop the district classiRcadon of property described hereinafter as
follows:
The district classification of the following area situated at Kahus 134 North
Kohals, Hawaii, shall be Single Family Residential (RS-15):
Beginning at a point at the North caner of this piece of land, being also the East
corner of portion of Government land of Pahimhiaa and on the Southwesterly side of
Kawaihae Mahukom Road, Section II. Project No. A-270-01-62, the com*= tes of
which referred to Hawaii State Plane Coordinate System Zone 1 being 4S3,109.73 feet
North and 37S,771.74 fat East, and running by true azimuths referred to the Meridian of
Government Survey Triangulation Station "PIN PILP' and measured clockwise Rom
South:
1. 3220 00' 30.5" 24.31 fat along the Southwesterly side
of Kawaihae Mahukona
Road;
2. 52° 00' 30.5" 20.00 feet along the Southwesterly side
of Kawatlm Mahukona
Road:
3. 322° 00' 30.5" 550.00 feet along the Southwesterly side
of Kawalm Mabukona
Road;
4. 524 00' 30.5" 10.00 fat along the Southwesterly side
of Kawsihae Mahulwna .
Read, EXHIBIT C
A f•
A•20• A-20•
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A *a A -50 A-I. A-9• A 1.
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A-f• A I. "•f" .•b
AKONI PULE HIGHWAY
7s p7ey+ ww
433101.73 N ¦r
375,771.74 E
'HAWAII STATE PLANE
COORDINATE SYSTEM. A - f•
ZONE 1"
A-f. A•f.
AGRICULTURAL (A°5a)
TO SINGLE FAMILY
RESIDENTIAL (RS-15)
AREA: 37.880 ACRES
AMENDMENT TO THE ZONING CODE
AMENDING SECTION 25-8-7• (NORTH AND SOUTH KOHALA DISTRICTS ZONE MAP) ARTICLE 8,
CHAPTER 25 (ZONING CODE) OF THE HAWAII COUNTY CODE. BY CHANGING THE DISTRICT
CLASSIFICATION FROM AGRICULTURAL (A-5a) TO SINGLE FAMILY RESIDENTIAL (RS-15) AT
KAHUA 1ST, NORTH KAHALA, HAWAII.
PREPARED BY : PUNNING DEPARTMENT
COUNTY OF HAWAII
TMK : 5-9-01: a APRIL 14• 1997
EXHIBIT "A' IOp^"`''Ap^OLDI
s i
CARLSMITH BALL LLP
A Lmrrm LAER.[IY LAw PArmusHw
121 WALANuEmE AvENuE
P.O. Box 686
HR.O, HAWAII 96721-0686
TELEPH"808.935.6644 FAx808.935.7978
W W W.CARLSMT174 COM
SUMSCARESMUH.COM OUR REFERENCE NO.:
OSM25.1
December 7, 2007
William Graham
Chairman, Hawaii County Planning Commission
Aupuni Center
101 Pauahi Street
Suite 3
Hilo, Hawaii 96720
Re: Scheduled December 12, 2007 Planning Commission Continued Hearing on:
(1) Planning Director Initiated Change of Zone (REZ 07-000067), Repeal of Ord.
No. 97-102 and Revocation of SMA Use Permit No. 379; and
(2) Kobala LLC Initiated Amendment to Condition C of Ord No. 97-102 and
Amendment to Condition 4 of SMA Use Permit No. 379
Dear Mr. Graham:
I am writing to inform you of an error in the noticing and scheduling of the Planning
Commission's (the "Commission") hearing on the above referenced matters to December 12,
2007. Kohala LLC ("Kohals") never agreed to the December 12, 2007 hearing date as required
under the Stipulation to Continue August 31, 2007 Hearing ("Stipulation"), a copy of which is
enclosed herein as Exhibit A• filed by Kohala and the Planning Department (the "PD") August
30, 2007. In addition, we are not aware of the Commission's approval of the December 12, 2007
hearing date, also required under the Stipulation. In short, the PD's unilateral announcement that
the next hearing will be held on December 12, 2007 came as a complete surprise to Kohala,
although, in light of the PD's arbitrary and aggressive actions in this matter perhaps nothing
should come as a surprise at this point. In light of the procedural defects related to the failure to
comply with the Stipulation, and other concerns detailed herein, Kohala believes the
Commission cannot hear the above referenced matters on December 12, 2007, and that the
proposed hearing must be continued.
Under the Stipulation, Kohala and the PD agreed to continue the Commission hearing
"from August 31, 2007 to the Planning Commission hearing tentatively scheduled to be held in
West Hawaii on October 19, 2007, subject to continuance to a later date in West Hawaii by
agreement of the parties and approval by the Planning Commission." (emphasis added.) This
continuance was approved by a 6/0 vote of the Commission on August 31, 2007. See Hearing
EXHIBIT D
William Graham
December 7, 2007
Page 2
Transcript August 31, 2007 at p. 8, a copy of which is enclosed herein as Exhibit B (hereinafter
the "8!31/07 Transcript"); see also the Commission's letter dated September 21, 2007, a copy of
which is enclosed herein as xhibit C notifying Kohala of the Commission's vote to continue
and stating "We will notify you of the details of the continued hearing when they are confirmed."
Kohala never agreed to the abruptly scheduled December 12, 2007 hearing date; selection
of December 12 appears to be Planning Director Christopher Yuen's unilateral decision. Mr.
Yuen never informed Kohala of his intention to seek a December hearing date. Therefore, Mr.
Yuen's letter: dated November 15, 2007 and received by my office on November 19, 2007,
copies of which are enclosed herein as Exhibits D and Fes, informing Kohala of his decision to
schedule the zoning and SMA matters for the December 12, 2007 hearing continue the series of
unpleasant surprises Mr. Yuen has sprung on Kohala, starting with his May 31, 2007 letter
informing Kohala of his unprecedented intent to seek a downzoning and revocation of SMA
Permit No. 379. W. Yuen's May 31 letter was not preceded by so much as a phone call to
Kohala regarding his intentions. Similarly, no contact preceded Mr. Yuen's November 15 letters
to Kohala.
The Stipulation required Kohala and the PD to agree to the date of the next Commission
hearing. Kohala never agreed to December 12, 2007. In fact, email correspondence between
Kohala and Norman Hayashi of the PD evidence that the PD understood the Stipulation's
requirement for both parties to agree to the next hearing date, and that the PD would not take
action until Kohala suggested a date for the next Commission hearing. See entails enclosed
herein as ExMhit Furthermore, there is nothing documenting the Commission's approval of
the December 12, 2007 hearing as required under the Stipulation.
In addition to non-compliance with the Stipulation, other procedural defects should
prevent the Commission from holding the December 12, 2007 hearing. Mr. Yuen's letter
informing Kohala of the December hearing was provided too late to comply with Hawaii County
Code § 25-243 (Amendments initiated by the council and director), which provides as follows:
Notice to owners of any properties specifically subject to the
proposed amendment shaU be provided by mail from the director,
no later than thirty days prior to the commission's public hearing
on the amendment.
Hawaii County Code § 25-2-43(d).
In order for the parties to participate in the Commission's public hearing on December 12,
2007, Kohala, as an owner of property specifically subject to the proposed amendment, should
have received Mr. Yuen's notice of the upcoming hearing no later than November 12, 2007 (30
days prior to December 12, 2007). However, Mr. Yuen's notice letter to Kohala is dated
November 15, 2007. See Exhibit E. In this instance Mr. Yuen's attempt to use the element of
surprise to gain an advantage over Kohala has backfired, as the November 15, 2007 letter failed
to provide Kohala requisite notice.
William Graham
December 7, 2007
Page 3
Compliance with Hawaii County Code § 25-243 (d) would be of less concern if the
parties had agreed, either through a stipulation or otherwise, to a date certain for the
Commission's continued hearing. However, nothing in the Stipulation, the 8/31/07 Transcript, or
subsequent communications with the PD, set forth a date for the next Commission hearing.
Thus, Mr. Yuen's failure to properly notice Kohala of the December 12, 2007 hearing means the
Commission must continue these matters at the December 12, 2007 hearing. i
Had Mr. Yuen provided Kohala proper thirty days notice, as required under Hawaii
County Code § 25-243 (d), Kohala could have prepared the proposed Findings of Fact,
Conclusions of Law and Decision and Order contemplated under the Stipulation Re Submittal of
Proposed Findings of Fact, Conclusions of Law and Decision and Order, filed with the
Commission on August 16, 2007 (the V&0 Stip"), a copy of which is enclosed herein as
E 'bit G. Under the D&O Sdp the deadline to file proposed Findings of Fact was extended
from August 17, 2007 to no later than twenty (20) calendar days
prior to the final action by the Planning Commission on the
Planning Director Initiated Revocation of Special Management
Area (SMA) Use Permit No. 379, and Applicant Kohala LLC's
request for Amendment to Condition 4 Special Management Area
Use Permit No. 379.
l The expectation that the next Commission hearing would be agendized at least thirty days
in advance was articulated at the August 31, 2007 Commission hearing. Obviously a minimum
of thirty days' notice would be required to allow sufficient time for the submittal of proposed
Findings of Fact Please forgive the length of the following quotation, but it evidences the
Commission's understanding of the interplay between the proposed findings of Fact and the
timing of the next Commission hearing.
LIM: That's correct We submitted a stipulation regarding
submittal of proposed findings of fact, conclusions of law and
decision and order which was signed by the attorney for the
Planni g Director on August 15 and by myself on August, I think
it's 10 or 16'", I can't tell which one. But basically that conforms
with what Mr. Torigoe has represented in that the Chapter 91-11.
Section 91-11 proposed findings would be, we would consider the
Planning Director's background and recommendation as being the
Planning Director's proposed decision. And then we would have
an extension of the deadline within which to submit any other
findings of fact which would probably be primarily the applicant's
from August 17, 2007 to not later than 20 calendar days prior to
the final action by the Planning Commission on this matter. And
that's all laid out in the stipulation.
' Kohala also questions whether the PD complied with the public notice provisions under Hawaii County
Code § 25-2-43 (c), which requires notice of a public hearing to be published in at least two newspapers,
once a week for three consecutive weeks, with the last notice at least ten days prior to the hearing.
William Graham
December 7, 2007
Page 4
r
GRAHAM: Okay. Thank you, Mr. Lim.
IWASHITA: Mr. Chair?
GRAHAM: Yes, Commissioner Iwashita?
IWASHITA: Just thinking about it, the way the deadline is
worded I guess I'm a little concerned is, how we're doing ahead of
time when the final action by this body is going to be and if we use
that, you know, to measure the time back
LIM: Typically what we're expecting was, you know, we don't
know how long the hearing is going to last in between the final
action. And I think that we were trying to estimate out that it
usually takes the Planning Staff, they usually start setting up the
age a at least 30 days ahead of time, so we would know what the
date would be.
IWASHITA: Oh, so we're continuing this to October 17th. Does
d4 now mean that the, I believe that's the date, so it's September
27 or something like that? Is that
LM [sic]: Well, we're expecting that we're going to have
some discussions with the Planning Director on this matter. So it
may be that it gets continued further, and that's why the stipulation
has that additional, you know, continuance.
GRAHAM: Just to try to be clear on this - then if I'm It ri
ri ght then we're sort of assuming at this point that when you refer
to the final decision tentatively we're talking about the October
meeting but that we're not cementing it to that at this point
because there will be further discussions between you and the
Planning Director, is that correct?
LIM: That is correct.
GRAHAM: Thank you.
IWASHITA: So for the moment it is the 27'h or 20 days before
the 17 . That's, okay.
8/31/07 Transcript at p. 7-8 (emphasis added.)
Had Mr. Yuen followed the requirements under the Stipulation regarding agreement of
the parties and approval of the Commission, all parties would have had sufficient time to prepare
proposed Findings of Fact for the Commission's review. However, rather than contacting Kohala
to determine a mutually acceptable hearing date, Mr. Yuen unilaterally selected December 12,
2007 for the hearing and then failed to timely notify Kohala of this decision. Mr. Yuen's later-
than-last-minute notification ensured that compliance with the D&O Stip was impossible.
William Graham
December 7, 2007
Page 5
i
In addition to the problems arising from Mr. Yuen's insufficient notice, Kohala wishes to
highlight Mr. Yuen's bad faith negotiations with Kohala. Although the Commission and Kohala
anticipated potential resolution of the zoning and SMA matters through discussions between my
office and Mr. Yuen, Mr. Yuen apparently thought otherwise. My office made numerous
attempts to schedule a meeting with Mr. Yuen, making email requests on the following dates:
July 23, 2007, August 31, 2007, September 10, 2007, September 19, 2007, October 15, 2007 and
November 15, 2007. The parties finally met briefly on November 21, 2007, six days after Mr.
Yuen had set the matter for the next Commission hearing. In other words, Mr. Yuen had no
intention of even considering a fairly negotiated resolution of these matters; his meeting with Mr.
Lim was a fagade for the Commission's benefit. Kohala's December 6, 2007 request to Mr. Yuen
for a continuance was rejected.
For the reasons stated above, Kobala does not believe the Commission can hold a hearing
on these matters on December 12, 2007. Kohala requests a continuance of the December 12,
2007 hearing to a date that is in compliance with the Stipulation, with proper notice to be
provided to all parties.
Very truly yours,
STEVEN C.L
JAB
Enclosures
cc: Ivan M. Torigoe, Esq., Attorney for Planning Commission
William Brilhante, Esq., Attorney for Planning Department
Amy Self, Esq., Attorney for Planning Department
Jennifer A. Benck, Esq., Carlsmith Ball LLP
4934d3T9-5330.1
AUG-3D-2007 11) 05:52 PH CORPORATION COUNSEL FAX NO, 8818822 P. 02
CARLSUM BALL LLP
STEVEN S.C. LIM 2505
121 Wainuenue Avenue
Hilo, lit %720
Tal No. 808.933.6644
Pax No. 808.935.7975
Attorney fox Applicant Koh" LLC
BEFORE THE PLANNING COMMISSION
OF THE COUNTY OF HAWAII
In the Matter of the Planning Director Initiated: SPECIAL MANAGEMENT AREA USE
(1) Change of Zone (REZ 07-000067) Prom RS- PERMIT NO. 379
15 to RA-5a district, (2) Repeal of Ordinance
No. 97-102 fmm A-5a to RS-15 district, and (3) STIPULATION TO CONTINUE AUGUST
Revocation of Special Management Area 31, 2007 HEARING
(SMA) Use Permit No. 379 to allow a SO-lot
single-family residential subdivision
and
Applicant Requested: (1) Amendment to
Condition C of Change of Zone Ordinance No.
97-101 and (2) Amendment to Condition 4
Special Management Ares Use Permit No. 379
Property situate at Kabus 1 st, North Kohals,
TMK: (3) 5-9.001008
STIPULATION TO CON77N[flE Amm 31- jQ,Q'j HzAmG
Applicant Kohala, LLC, by and through its counsel, Steven S.C. Lim of Carlsmith Ball
LLP, end Christopher I. Yuen, Planning Director, County of Hawaii, by and through his
attorney, William Brilhante, Deputy Corporation Counsel, hereby stipulate and agree to continue
the Planning Commission hearings In the Matter of the Planting Director Initiated (1) Change
of Zone (REZ 07-000067) from RS-15 to RA-5a district, (2) Repeal of Ordinance No. 97.102
from A-Sa to RS-15 district, and (3) Revocation of Special Management Area (SMA) Use Permit
No. 319 to allow a 504ot single-family residential subdivision, and Applicant Requested (1)
Exhibit A
,AUG-30-2007 TNU 05:52 Ph CORPORATION COUNSEL FAX NO. 9818822 P. 03
Amendment to Condition C of Change of Zone Ordinance No. 97-102 and (2) Amendment to
Condition 4 Special Management Area Use Petaiit No. 379 fiom Auguat 31, 2007 to tha
Planning Commission hearing tentatively Scheduled to be hold in West Hawaii on
October 19, 2007, Subject to continuance to a later hearing date in Want Hawaii by agfeemem of
the parties and approval by the Planning Commission.
DATED: Hilo, Hswaii, MUG 3 0 =7
STEVEN B.C.
AtoneyfoLLC
DATED: Hilo, Hawaii,
Wl1 I&W_JK FYANTE
AttonSylor Cbriatophar J. Yuen
Flaming Director, County of Hawaii
la aw Maas of the Pinang Director lahirred: (1) Chap of Zone (X5Z 07-M"7) tram R3.1 s to RA-5s
& WA (2) Repm l of OrdLuace No. 97.102 from "a to MIS district, and (3) Revocation of special
Maoepmaor Arne (SMA) Uee Pwmit No. 379 to allow a SO-lot single-ficuily mWeaWl wbdivicice., yid Appiicaa
Regiama1d: (1) Amead,neat to CwAklal C of Chanp of Zone Ordhlacs No. 97-102 and (2) Amendma t to
Cosddion 0 Special Manapmmt Arm Use Permh No. 379;
STVULA770N TO CONTOM AUGUST 31, 2007 HMARMO
03"1524Ot9.10102540001
.2-
PLANNING COMMISSION
COUNTY OF HAWAII
HEARING TRANSCRIPT
AUGUST 31, 2007
A regularly advertised hearing on the applications of Initiator PLANNING DIRECTOR and
Applicant KOHALA LLC (REZ 866/SMA 379) was called to order at 12 noon at the King
Kamehameha's Kona Beach Hotel, 75-5660 Palani Road, Kailua-Kona, Hawaii, with Chairman
William Graham presiding.
PRESENT: William Graham ABSENT & EXCUSED: Takashi Domingo
C. Kimo Alameda Shelly Ogata
Andrew Iwashita Rene' Siracusa
Alvin Rho
Rodney Watanabe
Rell Woodward
Ivan Torigoe, Deputy Corporation Counsel
Norman Hayashi, Planning Program Manager
Phyllis Fujimoto, Staff Planner
Jeff Darrow, Staff Planner
Christopher Yuen, Planning Director
And 4 people from the public in attendance.
INITIATOR: PLANNING DIRECTOR
a. Change of Zone (REZ 07-000067) for 37.88 acres of land from a Single-Family
Residential 15,000-square foot (RS-15) to a Residential and Agricultural 5-acre (RA-5a)
district.
b. Repeal of Ordinance No. 97 102 which rezoned 37.88 acres of land from an Agricultural
5-acre (A-5a) to a Single-Family Residential 15,000-square foot (RS-15) district.
C. Revocation of Special Management Area (SMA) Use Permit No. 379, which allowed the
development of a 50-lot single-family residential subdivision.
The property involved, owned by Kohala LLC, is located along the southwest (makai) side of
Akoni Pule Highway and the Kohala Ranch Subdivision, Kahua 1'r, North Kohala, Hawaii,
TMK: 5-9-1:8.
APPLICANT: KOHALA LLC (REZ 866/SMA 379)
a. Amendment to Condition C (time to secure final subdivision approval) of Change of
Zone Ordinance No. 97 102, which rezoned 37.88 acres of land from an Agricultural
5-acre (A-5a) to a Single-Family Residential 15,000-square foot (RS-15) district.
b. Amendment to Condition 4 (time to secure final subdivision approval) Special
Management Area Use Permit No. 379, which allowed the development of a
50-lot single-family residential subdivision.
The property involved is located along the southwest (makai) side of Akoni Pule Highway and
the Kohala Ranch Subdivision, Kahua V% North Kohala, Hawaii, TMK: 5-9-1:8.
1
Exhibit B
GRAHAM: Our next item of business which I believe in the last Commission hearing
when I was not here involved both Items 4 and 5, Unfinished Business. Four is initiated by the
Planning Director. Five is by Applicant Kohala LLC. It relates to a Change of Zone and a
Special Management Area Permit; and this is in the, just below the Kohala Ranch Subdivision in
Kahua 1, North Kohala And I think the Planning Department is going to put up some maps at
this time and we'll just wait a few minutes till they're ready to go.
Basically the Applicant Kohala LLC is asking for an amendment to a Change of Zone Ordinance
as well as to an SMA Permit. And the amendments would allow additional time to meet the
requirements. The Planning Director's initiation is to change the zone on that land, and also to
repeal a Special Management Area Use Permit, and repeal the ordinance which originally set the
zoning on that land.
DARROW: We're ready to go?
GRAHAM: Jeff, go ahead.
DARROW: Thank you. I'll just make this brief. I'll just do a brief presentation. The
location of this application is within the North Kohala District of Hawaii, more specifically
we're looking near Kawaihae area This would be Kawaihae in this area. Just for reference, this
is the Kohala Ranch Subdivision area. The white line running in a north-south direction on the
bottom of the map is the Akoni Pule Highway. And the area of the application is identified with
a blue dot. There are two applications that we are combining together. These have to do with
Change of Zone 97 102, which is a Rezone 866, and Special Management Area Use Permit
No. 379.
The Planning Director is recommending that Special Management Area Use Permit No. 379 be
revoked. It was originally approved to allow a 50-lot subdivision on this property. Additionally,
the Planning Director is initiating downzoning of the property from Single Family Residential
15,000 square feet to Residential-Agricultural 5 acres; and this is for approximately 38 acres of
this area. Originally the property was rezoned from Agricultural 5 acres to Single Family
Residential 15,000 square feet and, again, allowed The Special Management Area Use Permit
was approved to allow a 50-lot subdivision. The applicant, apparently the property was sold in
between this time. The applicant, nobody had requested a time extension for the Change of Zone
as well as for the SMA Permit, and so ten years after-the-fact of the original approvals there is a
request now for a time extension to Condition C of the Change of Zone as well as to Condition 4
of the SMA Use Permit.
At our last hearing the parties involved had gone into deliberations regarding this matter and
there has been a letter submitted by the applicant dated August 7'4 requesting a continuance of
this hearing until the October meeting in Kona, because of the fact that he is requesting for
certain Planning Department records to subpoena It is my understanding today that we do have
somebody signed up to testify, but their has been a request from the applicant to continue both
these matters until our October meeting.
2
GRAHAM: Thank you, Jeff. Any questions of Jeff from the Commissioners? Maybe
we can take our public testimony right now then. Ms. Byre, would you come forward. Do you
swear or affirm to tell the truth on this matter before the Planning Commission today?
BYRNE: I do.
GRAHAM: Thank you. And go ahead with your testimony and start with your name
and address, please.
BYRNE: Sure. My name is Gail Byrne, address is 68-3551 Awamoa Place,
Waikoloa, Koh"- and I'm here delivering testimony from five North Kohala non-profits and the
organizations and together our membership represents about 400 families in North Kohala.
And we're here to support the Planning Director's recommendation to repeal the Ordinance 97
102 and revoke the Special Management Area Permit No. 379. We are also urging the Planning
Commission and the Planting Director to consider the more restrictive zoning which would be
consistent with what the community has asked for over 30 years. And I have copies of a letter
signed from the five organizations here enough for each I don't know how we, what's the
appropriate way to deliver this? It's kind of summarizing some of the points I wanted to hit
today. I think there's nine in there. And then there's a second batch here. This summarizes, the
second batch summarizes the 30 years worth of, documented work that the community has done
to preserve the area makai of Akoni Pule Highway in open space and their continuing desire to
do so.
So, again, we're here to affirm and support the Planning Director's recommendations and ask for
zoning in that area of at least RA 20 if it's possible. Again, it's consistent with what the
community has asked for for 30 years in previous General Plan reviews and planning documents,
multiple resolutions.
During the last General Plan review petitions were submitted to the County requesting the
County to zone this area Open. And some of this stuff I have in the box. I was going to thump
down, about 2,000 signatures asking for this area to be in Open or Conservation. There's
another 6,000 signatures here that requested the County to put a building moratorium on this area
or the whole coast makai of Akoni Pule Highway, including this parcel. So there's a long history
of community support planning documents for more restrictive zoning.
And you guys are aware that this year the County Council passed a rezoning moratorium for
North Kohala that specifically states there will be no rezoning into districts smaller than Ag-20a.
I understand that might not be quite applicable to this particular situation; but that moratorium is
different than the moratorium that was developed for Kona or South Kohala, and specifically
with regard to the wording around Ag 20-a because it reflects the community's conversations
with their Council Member for better protections specifically along the coast.
Some of you may be aware that recent water quality surveys, and some of them hit the front page
of a paper just a few weeks ago showing that the reefs in this area or the marine environment
being heavily impacted already by upslope development. And additional development of any
kind only contribute to this problem, especially because development on this parcel borders the
ocean. My background is in civil engineering and I spent eight years working on development
3
land use issues and best management practices around development and looking at what we
could do to mitigate these kinds of effects. And I'm here to tell you in my professional
experience you can't over time. There are cumulative impacts.
And the Water Quality Study completed in 2006 by professors at the University of Hawaii Hilo
strongly criticized the degradation of water quality occurring along the Kohala Coast as a result
of increased development. There's also spotty data in there.
You know, we mentioned in our testimony that, you know, under the Clean Water Act the
County has an obligation to ensure that any pollution resulting from development is not
overwhelming the environment's ability to assimilate that pollution. And if that's not done, the
County and the State will be held accountable; and usually you have to go back and go through a
much more expensive process of retrofitting and trying to fix a problem which is almost always
very difficult or impossible to do. So we have an opportunity right here now to act proactively
and prevent a lot of costly clean-up. And we've already got a problem. It's right here. We've
seen it in the papers.
I think specifically with respect to the criteria that you guys have to look at on whether you can
grant these time extensions, my understanding is that the applicant does not meet the criteria for
a time extension. You know it's not, this project is not at all consistent with the General Plans
that have been developed; and it's certainly not consistent with the outputs of the North Kohala
Community Development Process. It's on-going right now. It's part of the General Plan. The
highest, over and over what that community has voiced is keep those areas open to the extent
possible from any development.
You know, there has been plenty of time to ask for an extension. It has been expired for five
years, is my understanding. And, you know, the original conditions and contexts have changed
under which this original permit was granted We are now seeing the cumulative effects of
development around here. We now understand better some of these impacts. And so the
conditions and context in which the original permit were granted have changed So I don't think
the applicant meets the criteria for a time extension in any regard. So that was the testimony
provided by the groups.
I just want to say a few personal roads, words. I've a Masters Degree in Civil Engineering and
so I love concrete in certain types of developments, I really do. And I actually invest in some
real estate but not in sensitive areas. And I also know there are no guarantees in any kind of
investment; and I don't expect the taxpayers to bail me out when I make a bad decision or I don't
follow-through when I need to. So that's just my, that's my own personal testimony there.
So, again, you know, the folks in North Kohala really appreciate what the Planning Director is
recommending here and thank the Planning Commission for your time.
GRAHAM: Thank you, Ms. Byre. Do we have some questions from any of the
Commissioners? In regard to what you said, I might ask Mr. Yuen if we do take this matter up at
a future hearing - apparently the State and perhaps the Federal government also has been really
studying this whole sedimentation area from Honokua Gulch going north along the coastline -
Could you at the Planning Department look to see if there's any reports on what's going on there,
4
r
and what has caused it, and, you know, what's recommended so that we could have that as part
of our folder for dealing with this application at the next hearing if we do?
WEN: We can certainly try, we'll get you what's available.
GRAHAM: Thank you.
WEN: There were some, there were a couple initial investigations and then there
has been some follow-up that's not actually, I think, in the form of a report. I did attend the
meeting and have had some discussions with people about the major runoff incident earlier this
year.
GRAHAM: Thank you. Thank you, Ms. Byrne. Would the applicant come forward at
this time. Mr. Lim, do you swear or affirm to tell the truth on this matter today before the
Hawaii County Planning Commission?
LIM: I do.
GRAHAM: Thank you. And could you give your name and address and then carry
forward with your testimony.
LIM: Steven Lim representing Kohala, LLC, PO Box 121, Hilo, 96721.
Mr. Chairman and Members of the Commission, we had half a hearing the last time. We've, I
think, requested some additional time to both get some of the documentation that we had
subpoenaed from the Planning Department and also to engage in further discussions with the
Planning Department on this matter. And as a result of that, I think we've submitted a
stipulation to continue the August 31, 2007, hearing. We last sent it to the Corporation
Counsel's office and I'm assuming it was forwarded here.
GRAHAM: Jeff?
DARROW: The continuance letter till October, correct?
LIM: Right, right. We had executed a stipulation to continue to the Planning
Commission's meeting in West Hawaii on October 19, 2007, subject to continuance to a later
date in West Hawaii by agreement of the parties and approval by the Planning Commission. So
that's what the last thing that we sent in to the County, yesterday, I believe it was.
GRAHAM: Thank you, Mr. Lim. So your request at this time is that Planning
Commission continue this matter?
LIM: That's correct.
GRAHAM: To the October hearing?
LILT: That is correct.
I
GRAHAM: All right. Commissioner Watanabe?
5
WATANABE: I'll move to continue to the October 19'x' meeting of 2007.
GRAHAM: Is there a second?
ALAMEDA: Second.
GRAHAM: All right. Seconded by Commissioner Alameda Mr. Yuen, since the
Planning Director is involved in Item No. 4, I guess, on this one, are we looking to continue both
of these items or I imagine Mr. Lim only speaks for the Kohala LLC application.
WEN: They should be dealt with at the same time. So we agree. It's not a big
rush. There's nothing happening on the property, so we agree that both Numbers 4 and 5 should
be continued to October.
GRAHAM: Thank you. And, Mr. Torigoe, are there any legal considerations we
should be aware of?
TORIGOE: No. Basically the deadlines will not start running until, as long as there's
an agreement the deadlines will be okay, I think.
GRAHAM: Thank you. Any questions, any further questions of Mr. Lim or any
comment by the Commissioners? We do have a motion right now before us.
IWASHITA: I just
GRAHAM: Yes, Commissioner Iwashita.
IWASHITA: We're treating this as a contested case kind of scenario?
GRAHAM: I don't think it's specific that we're treating it. This is whenever there's a
decision by this body I think the legal ramifications are such that it is as if it were a contested
case hearing.
IWASHITA: So, I'm just concerned that we meet all the procedural requirements, -
since we're not hearing it all at once and the Commissioners present might be different, you
know, in October than present today - whether or not we need to address any procedural
requirements.
GRAHAM: So would you like me to query Mr. Torigoe, I guess, of any further
IWASHITA: Yes.
GRAHAM: Any further procedural considerations?
TORIGOE: I believe that after the last hearing between Mr. Lim and the Director we
had an agreement that, and I assume that the question is really aimed primarily at FIRS 9141
matters about having a proposal for a decision in front of the Commissioners before the decision
6
is made. I think there was an understanding that the, let's see, the Planning Director had
submitted his recommendations and that would be sufficient but correct me if I'm wrong, I
think if you can just straighten that out and that there would not be a requirement of further
filings beyond those which we've already talked about, that is that the parties will be filing
findings of fact and conclusions of law and being able to respond. So, and I think there's a
stipulation regarding submittal of those findings and conclusions that was submitted and it was
dated, looks like, received August 16N in the Planning Department.
GRAHAM: Okay. All right. Mr. Lim, are you in conformance with all what you
hear?
LIM: That's correct. We submitted a stipulation regarding submittal of
proposed findings of fact, conclusions of law and decision and order which was signed by the
attorney for the Planning Director on August 151A and by myself on August, I think it's 16* or
16w, I can't tell which one. But basically that conforms with what Mr. Torigoe has represented
in that the Chapter 91-11. Section 91-11 proposed findings would be, we would consider the
Planning Director's background and recommendation as being the Planning Director's proposed
decision. And then we would have an extension of the deadline within which to submit any
other findings of fact which would probably be primarily the applicant's from August 17, 2007
to not later than 20 calendar days prior to the final action by the Planning Commission on this
matter. And that's all laid out in the stipulation.
GRAHAM: Okay. Thank you, Mr. Lim.
IWASHITA: Mr. Chair?
GRAHAM: Yes, Commissioner Iwashim?
IWASHITA: Just thinking about it, the way the deadline is worded I guess I'm a little
concerned is, how we're doing ahead of time when the final action by this body is going to be
and if we use that, you know, to measure the time back
LIM: Typically what we're expecting was, you know, we don't know how long
the heating is going to last in between the final action. And I think that we were trying to
estimate out that it usually takes the Planning Staff, they usually start setting up the agenda at
least 30 days ahead of time, so we would know what the date would be.
IWASHITA: Oh, so we're continuing this to October 171°. Does that now mean that
the, I believe that's the date, so it's September 27'" or something like that? Is that
LM: Well, we're expecting that we're going to have some discussions with the
Planning Director on this matter. So it may be that it gets continued further; and that's why the
stipulation has that additional, you know, continuance.
GRAHAM: Just to try to be clear on this - then if I'm hearing right then we're sort of
assuming at this point that when you refer to the final decision tentatively we're talking about the
October meeting but that we're not cementing it to that at this point because there will be further
discussions between you and the Planning Director, is that correct?
7
LIM: That is correct.
GRAHAM: Thank you.
IWASHITA: So for the moment it is the 27 h or 20 days before the 17'^. That's, okay.
GRAHAM: Okay? So if we're all clear, I think we could have Jeff take the vote on
our motion before us, which is to continue the hearing. And this is Items 4 and 5, Jeff?
DARROW: This is Items 4 and 5. What I'll be doing, we actually have five voting
sheets for this. So if it's okay if we can do one vote, and I'll do all the votes on all five of theta.
We have two for the SMA, we have one for the Planning Director's initiated rezoning and two
for the rezoning.
GRAHAM: Okay. So my understanding is both the applicant and the Planning
Director are supportive of this continuation and that Jeff plans to take five votes for one. If
there's any Commissioner who would prefer otherwise, would you please indicate so at this time.
All right. Thank you, Jeff, go ahead.
DARRO W: Sorry to, I need to get the Commissioners who
WATANABE: Yeah, I'll take it as a friendly amendment for the five.
DARROW: Okay. And also the Commissioner who seconded the
GRAHAM: Yes. Commissioner Alameda, are you, I believe you seconded
ALAMEDA: Yes to your request.
GRAHAM: Yes.
DARROW: Okay. Thank you. Okay, with that I'll take the roll. The motion before
us is to continue both Agenda Items 4 and 5 until our October 19th Kona meeting. Commissioner
Watanabe?
WATANABE: Aye.
DARROW: Commissioner Alameda?
ALAMEDA: Aye.
DARROW: Commissioner Iwashita?
IWASHITA: Yes.
DARROW: Commissioner Rho?
8
r
RHO: Aye.
DARROW: Commissioner Woodward?
WOODWARD: Aye.
DARROW: And Mr. Chairman?
GRAHAM: Aye.
DARROW- The motion passes six to zero.
GRAHAM: All right. Thank you, Mr. Lim.
LIM: Thank you very much.
The discussion ended at 12:22 p.m.
Respectfully submitted,
Sharon M. Nomura, East Hawaii Secretary
ATTEST:
Noriko Sauer, West Hawaii Secretary
l
9
SECEIVED SEP 2 4 ZW
County of Hawaiai
PLANNING.COhUdMION
AupuN Cu go a 101 POr31 SUM4 Sails 3 • labh fUmN %730
Phsm(303)951423a • Fu(SW)%14742
September 21, 2007
Steven S. C. Lim, Esq.
Carlsmith Ball, LLP
121 Waianuenue Avenue
Hilo, HI 96720
Dear Mr. Lim:
Special Management Area Use Permit No. 379
Request: Time Extension to Condition 4 of SMA 379
Change of Zone No. 866
Request: Time Extension to Condition C of Ord. 97-102
Applicant: Kohala LLC
i Tax Map Key: 5-9-1:8
Planning Director Initiated
Change of Zone (REZ 07-000067)
Request: RS-15 to RA-5a
Repeal of Change of Zone Ordinance No. 97-102 (REZ 866)
Revocation of Special Management Area Use Permit No. 379
Tax MM Key; 5-9-1:8
The Planning Commission at its duly held public hearing on August 31, 2007, voted to continue
the above-referenced requests to the October Commission meeting in West Hawaii, which is
tentatively scheduled for October 19, 2007.
We will notify you of the details of the continued hearing when they are confirmed.
Should you have questions regarding the above, please contact Norman Hayashi of the Planning
Department at 961-8288, x205.
Sincgy} ,
William r, Chairman
Planning Commission
Lhohalaa[Olpc
1 cc: Planning Department-Kona
Hawaii Comfy is an Equal Chporamiiy Provider and Employer
Exile
i
Her" Kim CbrMopbwj.llm
Me- ~ Df w
Brad Katekewa,ASLA
pf LEMAP
Inuttiv of Anf rani
PLANMG DEPARTMENT
101 FftW$uab saw? • 1010.Hwd 96720+n4
(SM96147811 • FAX(aan9614742
November IS, 20D7
Kobela LLC
c% Steven S. C. Lim, Esq.
121 Waianuawe Avenue
Hilo, HI 96720
Dear Mr. Lim:
Change of Zone No. 866
Request: Time Extension to Condition C of Ord. 97-102
Special Management Area Use Permit No. 379
Request: Time Extension to Condition 4 of SMA 379
Applicant: Kohala LLC
Tax Mini Key. 5-9-1:8
This is to inform you that the above items have been scheduled for a continued public hearing by
the Planning Commission. Said hearing, among others, will be commencing on Wednesday,
December 12, 2007, at 9:00 a.m., in the Waikoloa Beach Marriott Hotel, W273 Waikoloa Drive,
Wailooba, Hawaii, and contiatting on Ti nraday, December 13, 2007, as needed. Your presence
or the presence of as authorized representative will be appreciated in order that aU questions
relative to the request may be clarified
In accords= with the Hawaii County Zoning Code, Chapter 25-2-4, you are required to notify
the surrounding property owners and lesseas of record of the continued heariag. A copy of the
public notice is attached for your information
Should you have any questions regarding the above, please do not hesitate to contact Norman
Hayashi of this department at 961-8288.
Sincerely,
~[l
CHRTS tOPHER J UE
Planning Director
Att.
cc: Ms. Alice Kawaha
Ms. Gail Byme
I
Harm) Canty it w 84x01 Oppoffmao PwMdwand Exydayen
D
Exhibit
f
NOTICE OF PUBLIC MEETING AND HEARINGS
PLANNING COMMISSION
COUNTY OF HAWAH
NOTICE IS HEREBY GIVEN of matters to be considered by the Planning Commission of the
County of Hawaii in accordance with the provisions of Chapters 91 and 92, Hawaii Revised
Statutes, Section 6-4.3 of the Charter of the County of Hawaii, and the Planning Commission's
Rules of Practice and Procedure.
DATE: Wednesday, December 12, 2007
And continuing on Thursday, December 13, 2007, as needed.
TIME: 9:00 a.m.
PLACE: Waikoloa Beach Marriott Hotel
69275 Waikoloa Drive
Waikoloa, Hawaii
JIUS S- 9:00 ann.
1. INITIATOR: PLANNING DIRECTOR
a Continued bearing on the Planning Director's vitiation of a Change of Zone
(REZ 07-000067) for 37.88 acres of land 8om a ShWo-Family Residential
15,000-square foot (RS-15) to a Residential and Agricultural 5-acre (RA-5a)
district.
b. Continued hearing on the repeal of Ordinmux No. 97-102 which rezoned 37.88
acres of land from an Agricultural S-acre (A-5a) to a Single-Family Residential
tS,0W4quwe foot (RS-IS) district.
C. Continued bearing on the revocation of Special Management Area (SMA) Use
Pemait No. 379, which allowed the development of a 50-lot single-family
residential subdivision.
The property imroived, owned by Kohala LLC, is located along the southwest (makai)
side of Akoni Pub Highway and the Kohala Ranch Subdivision, Kahus 1 North
Kohala, Hawaii, T MX: 5-91:8.
2. APPLICANT: KOHALA LLC (REZ 866ISMA 379)
IL Continued hearing on an amendment to Condition C (time to saute final
subdivision approval) of Change of Zone Ordinance No. 97-102, which rezoned
37.88 acres of laud from an Agricultural 5-acre (A-5a) to a Single-Family
Residential 15,000-square foot (RS-15) district
b. Continued hearing on an amendment to Condition 4 (time to secure final
subdivision approval) Special Management Area Use Permit No. 379, which
allowed the development of a 50-lot single-family residential subdivision
The property involved is located along the southwest (makai) side of Akoni Pule
Highway and the Kohala Ranch Subdivision, Kabua 1", North Kohals, Hawaii,
TMX: 5-9-1:8.
1
I
NEIV DUSINESS - 9:30 am.
3. APPLICANT: HAWI JODO MISSION (USE 07-000001n
Use Permit to allow the establishment of an elementary school (K-6) on 0.95 acre of land
within the County's Single-Family Residential 13,000-square foot (RS. 15) district. Tae
property is located along the south side of the Akoni Pule Highway (Highway 270),
adjacent to and east of the existing Hawi Jodo Mission Church, Hawi, North Kohala,
Hawaii, TMK: 5-5-11:39.
4. APPLICANT: KONA VISTAS LLC (REZ 470)
Request for amendment to Condition I (time to secure Fidel Plan Approval) of Ordinance
No. 02 131, which reclassified certain lands from Unplanned (U) to a Multiple Family
Residential 5,1100- square toot (RM 5) and a Single-Family Residential 15,000-square
toot (RS-15) district. The property includes the existing Kona Vistas Subdivision
simated mania ofKuakim Highway (Highway 11), Holuaioa 11 and 2o4North Kona,
Hawaii, TMK: 7-&21:4,9-13 and 15-17.
IU BUSINESS -10:15 am.
5. INITIATOR: PLANNING DIRECTOR
Amendment to Section 25-245, Chapter 25 (Toning), Hawaii County Code 1993 (2005
Edition, as amended) with respect to Nonsignificant Zoning Changes.
ELECTION OF 2009 OFFICERS
WORKSHOP FOR PLANNING COMMISSIONERS
• Update of Planning Department activities, including status of the on-going
community development plans.
November 16, 2007
.gQ?yUMTRATIVE MATTERS
ANNOUNCE dEM
The purpose of the public bearings is to afford all interested persons a reasonabis
opportunity to be heard on the above requests.
Pursuant to Rule 4, Contested Case Procedure, of the County of Hawaii Planning
Commission Rules of Practice and Procedure, soy person seeking to intervene as a parry to
a contested ease bearlog on Item no. 3 above Is required to file a written request which
most be received In the oillee of the Planning Department no later thaw seven (7) calendar
days prior to the Planning Commission's first public meeting on the matter. Such written
request shall be In cemformkty, with Role 4, in a form as provided in Rate 4 Appendix A
"Petition for Standing in a Contested Case Hearing." The written petition/request shall be
2
r
filed with the Planning Commission at Aupuad Center, 101 Pauahi Street, Suite 3, Hilo,
Hawaff %720, and accompanied by a tiling fee of $100 payable to the Director of Finance.
Any party may retain counsel if that person so desires. Role 4 may be inspected or
purchased (52.50) at the above-Cited loeatloo, Rule 4 may also be viewed at the County of
Hawaii websfte OjmWwww.co i.hi.u s).
SuuWWWBa Testimony: According to Rule 1 (General Rules) of the Planting
Commission, a person desiring to submit oral or written testimony shall indicate ber/his name;
residence address:, and whether the testimony is on her/his behalf or as a representative of an
organization or individual. if testimony is being submitted on behalf of an organization,
documentation showing membership ratification should accompany the testimony. Written
testimony shall be submitted with an original and nine copies prior to testifying. The
Commission would appreciate timely submittal to the Planning Department at least one week
prior to the hearing date to allow for retailing and thorough Commission review. Testimony that
is irrelevant or unduly repetitious may be limited by the Chairperson pursuant to Rule 1.
Ngjkj to Lobbyists: If you are a lobbyist, you trust register with the Hawaii County
Clerk within live days of becoming a lobbyist (Article 15, Section 2-91.3(b), Hawaii County
Code). A lobbyist mans "any individual engaged for pay or other consideration who spends
more than five bonre in any month or $275 in any six-month period for the purpose of attempting
to influence legislative or administrative action by communicating or urging others to
communicate with public officials." (Article 15. Section 2-91.3(ax6). Hawaii County Code)
Registration foam and expenditure report documents are available at the Office of the County
Clerk, 333 Kilauea Avenue, 2"4 Floor, Hilo, Hawaii 96720.
Maps showing the general locations and boundaries of the areas under consideration
and/or plane of the proposed developments are on file and open to hmepection during office hours
at the Planing Department, Aupuni Center, 101 Pauahi Street, Suite 3, Hilo, Hawaii and at the
Kons office of the Planning Department, 75-5706 Kuakini Highway, Suite 109, Kailua-Kona,
Hawaii.
Any disabled person requiring special assistance or person requiring auxiliary aid ad/or
services to participate in the hearing should contact the Planning Department at %1-8288 five
(5) working days prior to the hewing so that appropriate arrangements can be made.
Hawaii County is an Equal Opportunity Provider and Employer.
PLANNING COMMISSION
William Graham, Chair
C, Kimo Alameda, I" Vice Chair
Rodney Watanabe, 2°d Vice Chair
(Hawaii Tribune Herald: November 22, 2007)
(West Hawaii Today: November 22, 2007)
~h 3
RECEIVE I) 1,u-j i y?OQ~
Harry Kim chridoplow J. Yam
MQOr fx m
Brad Kurakawa, ASLA
LZWOAP
dlmmty of PItfuuii °ijiryD/"tA1
PLANNING DEPARTMENT
tat PMMW aaat, Sdw>I • mto, thwas 96TZ4A4
r6a61961.1208 • PAX(SW961.8742
November 15, 2007
Kohala LLC
do Steven S. C. Lim, Esq.
121 Wainnuenue Avenue
Hilo, HI 96720
Dear Mr. Lim:
Change of Zone (REZ 07-000067) RS-15 to RA-5a
Repeal of Ord. 97-102
Revocation of SMA 379
Initiator. Planning Diroctor
Landowner. Kohala LLC
Zag Man Km 5-9-1:8
This is to inform you that the Planning Director's initiation on the above matters is scheduled for
a continued public hearing by the Planning Commission. Said hearing, among others, will be
commencing on Wednesday, December 12, 2007, at 9:00 am.. in the Wallmloa Beach Marriott
Hotel, 69-275 Waikoloa Drive, Waikolos, Hawaii, and continuing on Thursday, December 13,
2007, as needed Your presence or the presence of an authorized representative will be
appreciated in order that all questions relative to the request may be clarified. A copy of the
public notice is attached for your information
Should you have any questions regarding the above, please do not hesitate to contact Norman
Hayashi of this department at 961-8288.
Sincerely,
(CHRISTOPHER J. YUEN
Planning Director
Art.
cc: Ms. Alice Kawaha
Naw N Covey 4 m Egad OyyotiwNy Pmvidermd EmPbyes
Exhibit E
r
NOTICE OF PUBLIC MEETING AND HEARINGS
PLANNING COR04MION
COUNTY OF HAWAII
NOTICE IS HEREBY GIVEN of matters to be considered by the Planning Commission of the
County of Hawaii in accordance with the previsions of Chapters 91 and 92, Hawaii Revised
Statutes, Section 6-4.3 of the Charter of the County of Hawaii, and the Planning Commission's
Rules of Practice and Procedure.
DATE: Wednesday, December 12, 2007
And continuing on Thursday, December 13, 2007, as needed.
TIME: 9:00 am.
PLACE: Wail oloa Beach Marriott Hotel
69-275 Waikolos Drive
Waikolos, Hawaii
LrbMMHED BUSINESS - 9:00 am.
1. INITIATOR: PLANNING DIRECTOR
A. Continued hearing on the Planning Director's initiation of a Change ofZone
(REZ 07-000067) for 37.88 acres of lard from a Single-Family Residential
15,000-square foot (RS-15) to a Residential and Agricultural 5-acre (RA-5a)
diatricL
b. Continued hearing on the repeal of Ordinance No. 97-102 which rezoned 37.88
acres of land ft m an Agricultural 5-sore (A-5a) to a Single-Family Residential
15,000-square foot (RS-15) district
C. Continued hearing on the revocation of Special Management Area (SMA) Use
Permit No. 379, which allowed the development of a 50-W single-family
residential subdivision.
The property involved, owned by Kohala LLC, is located along the southwest (makai)
side ofAkoui Pule Highway and the Kohals Ranch SubdivisiM Kahua 1'% North
Koh" Hawaii, TMK: 5-9.1:8.
2. APPLICANT: KOHALA LLC (REZ 866/SMA 379)
L Continued hearing on an amendment to Condition C (time to secure final
subdivision approval) of Change of Zone Ordinance No. 97-102, which rezoned
37.88 acres of land Auto an Agricultural 5-acre (A-5a) to a Single-Family
Residential I5,00a"ure foot (RS-15) distria
b. Continued hearing on an amendment to Condition 4 (time to secure feral
subdivision approval) Special Management Area Use Permit No. 379, which
allowed the development of a 50-lot single-family residential subdivision.
The property involved is located along the southwest (makai) side of Akoni Pule
Highway and the Kohals Ranch Subdivision, Kahua I", North Kohala, Hawaii,
TMK 5-9-I:8.
i
1
Il
NEW BUSINESS - 9:30 JA
3. APPLICANT: HAWI JODO MISSION (USE 07-000009)
Use Permit to allow the establishment of an elementary school (K-6) on 0.95 acre of land
within the County's Single-Family Residential 15,000-squaro foot (RS. 15) district. The
property is located along the south side of the Akoui Pule Highway (Highway 270),
adjacent to and east of the existing Hawi Jodo Mission Church, Hawi, North Kohala,
Hawaii, TMK: 5-5-11:39.
4. APPLICANT: KONA VISTAS LLC (REZ 470)
Request for amendment to Condition I (time to secure Final Plan Approval) of Ordinance
No. 02 131, which reclassified certain lands from Unplanned (1J) to a Multiple-Family
Residential 5,000- square foot (RM-5) and a Single-Family Residential 15,000-square
foot (RS-15) district The property includes the existing Kona Vistas Subdivision
situated maulm of Kunkini Highway (Highway 11), Holualoa 1" and 2's-North Kona,
Hawaii, TMK: 7-&21:4,9-13 and 15-17.
W B 1 .)).NESS - 10:15 am.
5. INPPIATOR: PLANNING D=CTOR
Amendment to Section 25-2-45, Chapter 25 (Zoning), Hawaii County Code 1983 (2005
Edition, as amended) with respect to Nonsigai5cant Zoning Changes.
i . ELECTION OF 2008 OFFICERS
WORKSHOP FOR PLANNING COMMISSIONERS
e Update ofPhuming Department activities, including status of the on-going
community development plans.
Novae 16,2007
A M CTRATIVE MAE=
ANNOUNCEMENTS
~#DJOURNMENT
The purpose of the public hearings is to afford all interested persons a reasonable
opportunity to be heard on the above requests.
Pursuant to Rule 4, Contested Case Procedure, of the County of Hawaii Planning
Commission Rohts of Practice and Procedure, any persno seeking to intervene as a party to
a contested case hearing on Item no. 3 above Is required to file a written request which
most be received in the office of the Planning Department no later than seven (7) calendar
days prior to the Planning Commisdoo's first public meeting on the matter. Such written
request shall be in conformity with Rule 4, In s form as provided in Role 4 Appendix A
( "Petition for Standing In a Contested Case [leering." The written petition/request shall be
I 2
~ r
r
filed with the Planning Commission at Aupual Center, 101 Paoahi Street, Suite 3, Hilo,
Hawaii %720, and accompanied by a tiling fee of 5100 payable to the Director of Flnaate.
Any party may retain counsel If that person so desires. Rub 4 may be Inspected or
purchased (52.30) at the above-shed location. Role 4 may she be viewed at the County, of
Hawaii website fhtto://www.co.hawaii.l jgu
Sub 'tuna Testimony: According to Rule 1 (General Rules) of the Planning
Commission, a parson dashing to submit oral or written testimony shell indicate her/his name;
residence address; and whether the testimony is on her/his behalfor a a representative of an
organization or individuaL If testimony is being submitted an behalf of an organization,
documentation showing membership ratification should accompany the testimony. Written
testimony shall be submitted with an original and nine copies prior to teadfying. The
Commission would appreciate timely submittal to the Planning Department at lest one week
prior to the hearing data to allow for mailing and thorough Commission review. Testimony that
is irrelevant or unduly repetitious may be limited by the chairperson pursuant to Rule 1.
Notice to Lobbvists: If you are a lobbyist, you must register with the Hawaii County
Clerk within five days of becoming a lobbyist (Article 15, Section 2-91.3(6), Hawaii County
Code). A lobbyist means "any individual engaged for pay or other consideration who spends
more than five bouts in any mouth or $275 in any six-month period for the purpose of attempting
to influence legislative or administrative action by communicating or urging others to
communicate with public officials." (Article 15, Section 2-91.3(a)(61 Hawaii County Code}
1. Registration fames and expenditure report documents are available at the Office of the County
Clerk, 333 Kilauea Avenue, 2ed Floor, Hilo, Hawaii 96720.
Maps showing the general locations and boundaries of the areas under consideration
and/or plans of the proposed developments am on file and open to inspection during office hours
at the Planning Depaztnent, Aupuni Canter, 101 Pauaht Street, Suite 3, Hilo, Hawaii and at the
Kona office of the Planning Department, 75-5706 Kuakini Highway, Suite 109, Kailua-Kona,
Hawaii.
Any disabled person requiring special assistows or person requiring auxiliary aid and/or
services to participate in the hearing should contact the Planning Department at 961-8288 five
(5) working days prior to the hearing so that appropriate arrangements can be made.
Hawai 7 County it an Equal Opportunity Provider and Employer.
PLANNING COMMISSION
William Graham, Chair
C. Khoo Alameda, 1' Vice Chair
Rodney Watanabe, 2"4 Vice Chair
(Hawaii Tribune Herald: November 22, 2007)
(West Hawaii Today: November 22, 20M
I I
1 3
Re: Kohala LLC Page I of I
Katharine Y. Lugo
From: Norman Hayaehiinhayeshioco.AawalLhLuaI
Sent: Tuesday, September 18, 2007 3:48 PM
To: Steven S.C. Lim
Cc: Katharine Y. Lugs; Janngw A. Bank; Baba N. Yung
Subject: RE Kohut LLC
OK will waft to hear back hom m
--original Mcssage-
Froms %am S.C. Lkn (ma8to:samocarlsmith.mn)
Sent: Tuesday, September 18, 2007 3:02 PM
To: Hayaahl, Norman
Cc: Katherine Y. Lugs, JMft A. Bends; Baba N. Yung
Subject: Re: Kohals LLC
We have net hoard back on our rerqueat rar a meedag with Mr. Yum yet, so we need mme thus, Please.
Oritioal (chute
From: Hayashf, Nwmm goo mas_hpeahh®co.hewali.hLusa
To: Stever S.C. Lim
Sent- Tue Sep 10 14:29:36 2007
Subject Kchols LLC
Stew,
Are you ready to sd bock on for the October 19th PC Weds? Or, do you west to hold off till WNq
{
9/18/2007 Exbibjt F
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i CARLSMITH BALL LLP
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W W W.CAW9MiM.COM
LETTER OF TRANSMnTAL
To: William Graham DATE: Augnst 16, 2007
Chsimesa
Planning Commission Rtt Kabala. LLC . SMA Permit No. 379
101 Paudd Streak Suite 3 Ts (3)1-9-001:002
Hilo, Hawaii %720
ATTN. PHYLLIS FUJMOTO
® Mailed QX Hand Delivered 0
THE FOLLOWING IS (ARE)1RANSWrrW HEREWITH:
COMB VAn man
Original + Stipulation re Submittal of Proposed Findings of Fact,
12 Conclusions ofLaw and Decision and Order
® For Your Information ® For Review and Comment
® For Your Files ® For Necessary Action
® Per Your Request 0 For Signature end Return (Black Ink)
Q Per Our Conversation XQ See Remarin Below
REMAnro:
Enclosed for flung are the original + 12 copies of the above referenced docr umm Should you
have any questions, please feel free to caused ns. Tbank you.
By 4._
Fes' Steven S.C. Lim
Enclosure(s)
I
Eih bit
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CARLSMITH BALL LLP
STEVEN S.C. LIM 2505
121 Waismucaut Avenue
Hilo, HI 96720
Tel No. 808.933.6644
Fax No. 808.935.7975
Attorney for Applicant Kohala, LLC
BEFORE THE PLANNING COMMISSION
OF THE COUNTY OF HAWAII
In the Matter of the Planning Director Initiated: SPECIAL MANAGEMENT AREA USE
(1) Change of Zane (REZ 07-000067) fium RS- PERMIT NO. 379
IS to RA-S& diateid, (2) Repeal of Ordinamx
No. 97-102 ilom A-Sa to RS-15 district, and (3) STIPULATION RE SUBMITTAL OF
Revocation of Special Management Area PROPOSED FINDINGS OF FACT,
(SMA) Use Permit No. 379 to allow a 50-lot CONCLUSIONS OF LAW AND
single-family residential subdivision DECISION AND ORDER
and
Applicant Requested: (1) Amendment to
Condition C ofChaage ofZ one Ordinance No.
! 97-102 and (2) Amendment to Condition 4
Special Management Area Use Permit No. 379
Property situate at Kahaa 1st, North Kohala,
TMK: (3) 5-9-001:008
STIPULATION RE SUHMITTAL OF PROPOSED
EMU= OF LAS L CONCLUSIONS OF LAW AND DECISION AND OR=
Applicant Kohsla, LLC, by and through its counsel, Steven S. C. Lim of
Carismith Ball LLP, and Christopher J. Yuen, Planning Director, County of Hawaii, by and
through his anomey, William Brilbante, Deputy Corporation Counsel, bereby stipulate and agree
to the following:
(1) To extend the deadline within which all parties are to submit their
respective proposed Findings of Fact, Conclusions of Law, and Decision and Order from August
17, 2007 to no later than twenty (20) calendar days prior to the final action by the Planning
Commission on the Planning Director Initiated Revocation of Special Management Area (SMA)
Use Permit No. 379, and Applicant Kohals LLC's request for Amendment to Condition 4
Special Management Area Use Permit No. 379; and
(2) All parties may submit exceptions to the proposed Findings of Fact,
Conclusions of Lew, and Decision and Order no later than twelve (12) calendar days prior to the
final action by the Planning Commission on the Planning Director Initiated Revocation of
Special Management Ares (SMA) Use Permit No. 379, and Applicant Kohala LLC's request for
Amendment to Condition 4 Special Management Area Use Permit No. 379.
DATED- Hilo, Hawaii, Y~ 16 0-;~-
Q" SHTEPVANR &C.
Attorney for Applicant Kobela LLC
DATED: Hilo, Hawaii,
Attorney J. Yuen
Planning Director, County of Hawaii
In the Maser of tba Plmaft Deedw Initialed: (1) Chow of Zone (REZ 07-000067) tram RS-13 to RA-S&
diuriat; (2) Repeat afOMimum No. 97-102 nom A-1a to RS-15 diatriet, and (3) Revmdon of Spacial
Maosyato at Area (SMA) Use Pamb No. 379 0 albr a Wbt sinaled4mfiy residential wbdivixi end Applieaot
Regemtedr (1) Ammdmam b CaaMm C of Cbmaa of Zeno Ordinanea No. 97-102 and (2) Aamdmam to
Condition 4 Special INamysmmt Arm Un Perrmt Nw 379;
STIPULATION RE SUBMfITAL OF PROPOSED FINDINGS OF FACE. CONCLUSIONS OF LAW AND
DECISION AND ORDER
-2-
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SUMOCARIAMMM.CO6t OUR R8P Wa No.,
osausl
February 1, 2008
Casey Jarman
Hawaii County Council-Clerk y
25 Aupuni Street,
Hilo, Hawaii 96720
Re: Planning Director (REZ 07-000067/REZ 866):
(1) Planning Director Initiated Change of Zone for 37.88 Acres of
Land From Single-Family Residential 15,000-Square Foot (RS-15) to
a Residential and Agricultural 5-acre (RA-5a) District; and
(2) Repeal of Ordnance No. 97-102, Which Rezoned 37.88 Acres of
Land From an Agricultural 5-acre (A-5a) to a
Single-Fam ft (residential 15, Foot (R& 15) District
Dear Ms. Jarman:
We represent Kohala LLC ("Kobala"), the owner of approximately 37.88 acres of
land located at Tax Map Key (3) 5-9-001: 008 (the "Subject Phperty"). In connection with the
Planning Commission's ("Commisaloa") hearings on the above referenced Planning Director
initiated proposed repeal of Ord. No. 97-102 and downzoning of the Subject Property
(collectively the "Dowazoaing"), I am writing to inform you of deficiencies in the public notice
required under Hawaii County Code, § 25-2-43 (c). In addition to public notice defects, Kohala
was not properly noticed on all Commission bearings, as required by Haw. Ct. Code § 25-243
(d). Finally, Kohala is not aware of any sip posting for the proposed Downzoning, as required
by Haw. Ct. Code § 25-2-12 and Planning Commission Rule 11-4.
As a result of these defects, the Downzoning cannot now be heard by the Hawaii
County Council. Instead, the Downzoning must be returned to the Commission for further
hearings, which will have to be properly noticed. Kohala recognizes that these jurisdictional
Comm W. Tam
Ref. Data
EXHIBIT E
Casey Jarman
February 1, 2008
Page 3
defects may seem like mere technicalities. However, should the Downzoning be enacted by the
Hawaii County Council, Kohala's currently entitled 50-lot subdivision will be reduced to
approximately 7 lots. In light of the potentially devastating effect of the Downzoning, Kohala is
obligated to raise these deficiencies in an attempt to protect its valuable and Constitutionally
protected property rights.
Notice of the first Commission hearing on the Downzoning was published three
times in two newspapers, as required by Haw. Ct. Code, § 25-2-43 (c). However, no subsequent
hearing were so noticed. In the same way that a property owner who initiates a zoning change is
legally obligated to serve notice on surrounding owners and lessees of record, as provided under
Haw. Ct. Code § 25-242 (b), in this case the Planning Director, as the initiating party, had the
legal duty to publish proper notice informing the public of his proposed zoning amendments.
This duty is clearly set forth in Haw. Ct. Code § 25-243 (c), which states as follows:
Notice by mail to surrounding property owners and lessees of
record or properties within the boundaries shall not be required
In lieu of mailing written notice to surrounding property
owners and lessees of record, the director shall publish notice of
the commission's public hearing in at least two newspapers of
general circulation in the County, once a week for three
consecutive weeks, with the last notice to be at kart tea day prior
to the hearing. The notice shall specify the time, date and place of
the hearing, its purpose and a description of any property which
may be involved.
Haw. Ct. Code § 25-243 (c).
Notice of the December 12, 2007, hearing was published one time only, despite
the fact that at the prior hearing, held August 31, 2007, the Downzoning had been continued
indefinitely. Unlike other hearings where a firm date for a continued hearing is established, and
interested members of the public are therefore provided an opportunity to attend the scheduled
continued hearing, in this instance no such date was determined at the August hearing.
Therefore, it was impossible for any interested person in attendance at the August hearing to
know when the Downzoning matter would next be before the Commission. In fact, because an
October hearing date was discussed at the August hearing, it is likely that any person interested
Casey Jarman
February 1, 2008
Page 4
in the Downzoning would have checked the Commission agenda and/or newspapers in
anticipation of the October hearing and, seeing nothing listed, assumed the Downzoning matter
was settled and no longer being considered by the Commission.
The possibility of an October hearing was discussed at the August 31, 2007
hearing, where Kohala and the Planning Director stipulated to continue the matter to October 19,
2007, "subject to a continuance to a later hearing date in West Hawaii by agreement of the
parties and approval by the Planning Commission." See Stipulation to Continue August 31, 2001
Hearing, a copy of which is attached hereto as Ex it The Commission sent a confirming
letter to Kohala, dated September 21, 2007, stating that the matter had been continued to the
October Commission hearing date, "tentatively scheduled for October 19, 2007." The
Commission assured Kohala that the Commission would "notify you of the details of the
continued hearing when they are confirmed." See Commission letter, a copy of which is attached
hereto as fthibit B.
The Downzoning was not before the Commission in October, and the only notice
Kohala received of the December hearing was the Planning Director's letter dated November 15,
2007, stating that the Downzoning was scheduled to be before the Commission on December 12,
2007. Despite the Stipulation's open-ended language regarding the date of the continued hearing,
notice of the December 12, 2007 hearing was published one time only. Kohala asserts that
notice of the December hearing should have been published at least three times, as required
under Haw. Ct. Code § 25-2-43 (c). A partial procedural history on the Downzoning and
relevant hearing and notice dates are listed on the chart attached hereto as Exhibit C,
Kohala never agreed to the December 12, 2007 hearing date, nor was Kohala
informed of the Commission's approval of the December 12, 2007 hearing date, both of which
were required under the Stipulation. 1 In addition, Kohala was not timely noticed on the
December 12, 2007 hearing. The Planning Director's letter to Kohala regarding the December
hearing was dated November 15, 2007, too late to comply with Haw. Ct. Code § 25-2-43 (d),
' On December 7. 2007, Kohals sent a letter to the Commission stating numerous concerns with respect to the
Commission and Planning Director procedures on the Downzoning.
Casey Jarman
February 1, 2008
Page 5
which requires the Planning Director to provide property owners notice "no later than thirty
days prior to the commission's public hearing on the amendment." Despite these procedural
defects, the Commission held a hearing on the Downzoning on December 12, 2007, and there
continued the matter to January 11, 2008 2
A final point Kohala wishes to raise is the Planning Director's failure to post signs
at the Subject Property to notify the public of the proposed Downzoning. Under Haw. Ct. Code
§ 25-2-12 and Commission Rule 11-4 (a), such signs must be posted within ten days of
acceptance of an application for zoning amendment. The Planning Director initiated the
proposed Downzoning in June, 2007. Kohala is not aware of any public notification signs being
posted at the Subject Property.
For the reasons stated above, Kohala does not believe the Downzoning can be
heard by the Hawaii County Council at this time. Instead, the Downzoning must be returned to
the Commission for a further, properly noticed, hearing. In addition, an appropriate sign alerting
the public to the Planning Director's proposed zoning amendment should be posted on the
Subject Property.
Very truly yours,
STEV S. . LIM
JAB
Enclosures
cc: Ivan M. Torigoe, Esq., Attorney for Planning Commission
William Brilhante, Esq., Attorney for Planning Department
Amy Self, Esq., Attorney for Planning Department
Jennifer A. Benck, Esq.
7 Planning Director's notice to Kohala of the January 11, 2008 hewing was mailed December 17, 2007, and therefore
did not comply with the thirty day notice requirement under Haw. Ct. Code § 25-2-43 (d).
r_r~ sa~r,i ~r J. 'ezcu
nt ecra
hoc'
` • acrd iCarokaws, ACLA
LEEM AP
(90untg of'NafVU [ De"Diremr
PLANNING DEPARTMENT
lol Pauaw suce4 Sufte 3 - Hilo. Hawaii 96720.4224
(808)961-8288 - PAX(808)961-8742
MEMORANDUM
NO, 07-20
October 3, 2007
TO: PLANNERS, ZONING CLERKS, AND EMS
FROM: CHRISTOPHER J. YUEN
PLANNING DIRECTOR
SUBJECT: EA LAW
Because of two recent events, we have to re-evaluate our practices in reviewing
applications to see whether an environmental assessment is needed under Chap. 343,
Hawaii Revised Statutes, particularly when a land use application for private
development will need improvements within the state or county road right-of-way.
The two events the state DOT's May 2007 memo and the State Supreme Court's recent
opinion in the Superferry case.
DOT's memo said that they would not process applications from landowners for
improvements within the state r.o.w., typically for such things as driveways and turn
lanes, which are associated with private development on the adjoining land, unless the
owner could show that there had been compliance with Chap. 343 when the permits for
the land use were granted (typically by the county.)
The end result of the Superferry decision and the DOT memo, along with an earlier
Hawaii Supreme Court case (Kahan Sunset) is that when we look at a land use
application, such as a special permit, SMA permit, or a rezoning, we have to see whether
any new construction on state or county land (including adjoining road rights-of-way)
must accompany the development. Very often, it will. There will usually be a need for a
new driveway access across the unimproved shoulder of a road, for example. A larger
project may need turn lanes constructed within the right-of-way.
Now, typically, these kinds of minor road improvements will be on the "exempt list" for
DOT or DPW. This is a list of types of improvements that are normally "exempt" and do
l-la%Wli County u• as Equal Oppoilwa j Provider and tmnlaver.
PLANNERS, ZONING CLERKS, AND EMS
Page 2
October 3, 2007
not need an EA, such as paving of shoulder areas. So if DOT or DPW did this type of
work it would be considered exempt and would not need an EA. If it is done by a private
party in connection with a development, however, the entire development has to be
considered. The development can be exempted only if it is the type of development that
is in one of the "exempt classes of action" under the OEQC Rules. These are general
classes, such as construction of a single-family home not in connection with more than
one home.
Planners will have to review the application to see if there is construction on state or
county land involved. This may be shown on the site plan. Planners also have to use
common sense in looking at the application. For example, if access to the property will
require constructing a new road over a "paper" government road, this will trigger this
Chap. 343 review.
If we process an application without requiring an EA because there was no road
improvement or other EA trigger in the application, but it turns out that during the course
of the consideration of the application that there is likely going to be an EA trigger
(because there is a comment letter from DPW asking for road improvements, for
example) we will continue processing the application, because it is not clear until the
permit or rezoning is granted that this will actually be a requirement. In that case, if the
improvement is a condition of the approval, the EA will have to be done before the next
stage in the process. For example, if the property was rezoned, the EA should be done
before the preliminary subdivision plat is submitted. If the road improvement is a
condition of tentative subdivision approval, the EA should be done before final
subdivision approval, and the tentative approval should include it as a condition.
The end result of this is likely that more applications will need environmental
assessments, and, because the entire project has to be considered, some will need full
EIS's, even though the only "trigger" is a minor construction on the state or county right-
of-way.
In most cases, the Planning Department will then be responsible for submitting the
environmental assessment, because we are the agency that received the initial application.
We will usually continue our regular practice of having the private applicant actually
prepare the information that goes into the EA. We still have to find it acceptable and be
the entity that actually submits it, however. We will also make the determination whether
there must be a full EIS.
PLANNERS, ZONING CLERKS, AND EMS
Page 3
October 3, 2007
I understand that this may cause a big increase in work for some projects. We have to do
this, however, because we have to implement the state environmental impact statement
law, Chap. 343.
I expect to have further staff training on this topic soon. In the meantime, however,
attached is a checklist for reviewing new applications to see if there will be a requirement
for an environmental assessment. This is a checklist for applications that go to the
Planning Commission, such as special permits, SMA permits, rezonings, use permits, and
state land use boundary amendments, and for new subdivision applications. Planners
who are reviewing these applications should go through the checklist. When
completed, a copy of the checklist, initialed by the planner and dated, must be kept
in the file of the application. Planners must keep a copy of the DPW and DOT "exempt
lists", and the "exempt categories" handy so that they can make a determination whether
these apply. (These are included with the memo.) .
I am available for consultation on issues involving EA's and applications but long term
this has to be handled by the planners who are reviewing applications.
One further fine point on this: technically, a rezoning or a county council state land use
boundary amendment is not the type of approval that will create the need for an EA,
because state law defines the EA trigger as an "agency action", and the county council is
not an "agency" under Chap. 343. It is not part of the executive branch of government.
However, a rezoning is almost invariably followed by a subdivision or plan approval,
which is an "agency action." Because Chap. 343 says that the EA should be done at the
earliest practicable time, if a rezoning has a "trigger" for an EA, and if it is not exempt,
and if the rezoning is going to be followed by a subdivision or plan approval, then the EA
should be done prior to the rezoning. In the case of a rezoning that would not be followed
by a subdivision or plan approval (which is probably rare), no EA will be required, even
if there is a trigger.
I'm sorry for the complexity of this topic, but again, that is the result of state law.
CJY:pak
WpwinWadShfrMe m RA Uw.dm
Attachments
cc: Mayor Harry Kam
Corporation Counsel
Department of Public Works
ry
{`'n,1 f.. it 6c 1 ~ `I t lilt ch,aT) 1
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PLAIC%NG DEPARTMENT
101 Pauahi Street, Suite 3 • Hilo, Hawaii 967704224
(808) 961-8288 • FAX(909)961-8742
MEMORANDUM
NO. 07-20
October 3, 2007
TO: PLANNERS, ZONING CLERKS, AND EMS
FROM: CHRISTOPHER J. YUEN
PLANNING DIRECTOR
SUBJECT: EA LAW
Because of two recent events, we have to re-evaluate our practices in reviewing
applications to see whether an environmental assessment is needed under Chap. 343,
Hawaii Revised Statutes, particularly when a land use application for private
development will need improvements within the state or county road right-of-way.
The two events the state DOT's May 2007 memo and the State Supreme Court's recent
opinion in the Superferry case.
DOT's memo said that they would not process applications from landowners for
improvements within the state no.w., typically for such things as driveways and turn
lanes, which are associated with private development on the adjoining land, unless the
owner could show that there had been compliance with Chap. 343 when the permits for
the land use were granted (typically by the county.)
The end result of the Superfeny decision and the DOT memo, along with an earlier
Hawaii Supreme Court case (Kahana Sunset) is that when we look at a land use
application, such as a special permit, SMA permit, or a rezoning, we have to see whether
any new construction on state or county land (including adjoining road rights-of-way)
must accompany the development. Very often, it will. There will usually be a need for a
new driveway access across the unimproved shoulder of a road, for example. A larger
project may need turn lanes constructed within the right-of-way.
Now, typically, these kinds of minor road improvements will be on the "exempt list" for
DOT or DPW. This is a list of types of improvements that are normally "exempt" and do
EXHIBIT F
t ~il!%tiJ': ~~y.: ~ G:]%J.`[',:lrr- ei rdr•l. ,C. ily'n'Jyc
PLANNERS, ZONINC CLERKS, AND EMS
Page 2
October 3, 2007
not need an EA, such as paving of shoulder areas. So if DOT or DPW did this type of
work it would be considered exempt and would not need an EA. If it is done by a private
party in connection with a development, however, the entire development has to be
considered. The development can be exempted only if it is the type of development that
is in one of the "exempt classes of action" under the OEQC Rules. These are general
classes, such as construction of a single-family home not in connection with more than
one home.
Planners will have to review the application to see if there is construction on state or
county land involved. This may be shown on the site plan. Planners also have to use
common sense in looking at the application. For example, if access to the property will
require constructing a new road over a "paper" government road, this will trigger this
Chap. 343 review.
If we process an application without requiring an EA because there was no road
improvement or other EA trigger in the application, but it turns out that during the course
of the consideration of the application that there is likely going to be an EA trigger
(because there is a comment letter from DPW asking for road improvements, for
example) we will continue processing the application, because it is not clear until the
permit or rezoning is granted that this will actually be a requirement. In that case, if the
improvement is a condition of the approval, the EA will have to be done before the next
stage in the process. For example, if the property was rezoned, the EA should be done
before the preliminary subdivision plat is submitted. If the road improvement is a
condition of tentative subdivision approval, the EA should be done before final
subdivision approval, and the tentative approval should include it as a condition.
The end result of this is likely that more applications will need environmental
assessments, and, because the entire project has to be considered, some will need full
EIS's, even though the only "trigger" is a minor construction on the state or county right-
of-way.
In most cases, the Planning Department will then be responsible for submitting the
environmental assessment, because we are the agency that received the initial application.
We will usually continue our regular practice of having the private applicant actually
prepare the information that goes into the EA. We still have to find it acceptable and be
the entity that actually submits it, however. We will also make the determination whether
there must be a full EIS.
PLANNERS, ZONING CLERKS, AND EMS
Page 3
October 3, 2007
I understand that this may cause a big increase in work for some projects. We have to do
this, however, because we have to implement the state environmental impact statement
law, Chap. 343.
I expect to have further staff training on this topic soon. In the meantime, however,
attached is a checklist for reviewing new applications to see if there will be a requirement
for an environmental assessment. This is a checklist for applications that go to the
Planning Commission, such as special permits, SMA permits, rezonings, use permits, and
state land use boundary amendments, and for new subdivision applications. Planners
who are reviewing these applications should go through the checklist. When
completed, a copy of the checklist, initialed by the planner and dated, must be kept
in the Me of the application. Planners must keep a copy of the DPW and DOT "exempt
lists", and the "exempt categories" handy so that they can make a determination whether
these apply. (These are included with the memo.)
I am available for consultation on issues involving EA's and applications but long tern
this has to be handled by the planners who are reviewing applications.
One further fine point on this: technically, a rezoning or a county council state land use
boundary amendment is not the type of approval that will create the need for an EA,
because state law defines the EA trigger as an "agency action", and the county council is
not an "agency" under Chap. 343. It is not part of the executive branch of government.
However, a rezoning is almost invariably followed by a subdivision or plan approval,
which is an "agency action" Because Chap. 343 says that the EA should be done at the
earliest practicable time, if a rezoning has a "trigger" for an EA, and if it is not exempt,
and if the rezoning is going to be followed by a subdivision or plan approval, then the EA
should be done prior to the rezoning. In the case of a rezoning that would not be followed
by a subdivision or plan approval (which is probably rare), no EA will be required, even
if there is a trigger.
I'm sorry for the complexity of this topic, but again, that is the result of state law.
CJY:pak
Wpwin60/Pat/Smff Me= rc EA Iaw.doc
Attachments
cc: Mayor Harry Kim
Corporation Counsel
Department of Public Works
CHAPTER 343 REVIEW CHECKLIST FOR NEW
APPLICATIONS THAT GO TO PLANNING COMMISSION
AND NEW SUBDIVISIONS
1. Has an EA or EIS already been done for the project? If yes, stop, the
requirement has already been taken care of.
2. Is there an EA trigger?
--use of state or county lands, including construction within r.o.w.
--use of state or county funds
--use within conservation district
--use within shoreline setback
--use within historic site on national or Hawaii register (see list in GP)
--reclassification of conservation land
--building of certain helicopter facilities, see HRS sec. 343-5
--amendment to county GP or CDP not initiated by county
--construction of new W WTP serving > 49 residences
--construction of new fossil-fuel power plant > 5MW
--expansion of existing fossil-fuel power plant by > 5MW
--new landfill
--new waste-to-energy facility
--new oil refinery
If no trigger, check _ here. Stop, no EIS/EA needed.
If trigger, check off trigger category or categories, go to #3.
3. Is the trigger on an exempt list or is it an exempt class of action? Review
exempt lists and exempt classes of action.
If no, stop. Project needs EA or EIS. Write applicant, explain. Reject
application. If PPM, process but send applicant a letter explaining they
must do EA and that no TA until this is done.
If yes, list exempt list item or class of action here-, go to A.
4. Is the project as a whole similar to an exempt class of action?
if no, stop. Project needs EA or FIS. Write applicant, explain. Reject
application. If PPM, process but send applicant a letter explaining they must
do EA and that no TA until this is done.
If yes, go to #5.
5. Contact the agency whose exempt list it falls under. Let them know that
we are considering exempting the project per the category. Ask for any
objection.
If no objection, go to #6. If there is objection, see planning director.
6. Is the project in an unusually sensitive area, or are there successive
actions planned that may have a cumulative effect? If yes or if in doubt, see
planning director. If no, go to V.
7. Write brief letter to agency whose exempt list it falls under mentioning
that we consulted with the agency and have determined this project is
exempt from EA requirements under exempt list item CC applicant.
Process is now finished.
Checklist completed by - Date:
r7-.E-s4 'r CLASSES oy jtcnow
§11.200-8 Exempt Classes of Action
A. Chapter 343, HRS, states that a list of classes of actions shall be drawn up which, because they
will probably have minimal or no significant effect on the environment, may be declared exempt by
the proposing agency or approving agency from the preparation of an environmental assessment
provided that agencies declaring an action exempt under this section shall obtain the advice of
other outside agencies or individuals having jurisdiction or expertise as to the propriety of the
exemption. Actions declared exempt from the preparation of an environmental assessment under
this section are not exempt from complying with any other applicable statute or rule. The following
list represents exempt classes of action:
t. Operations, repairs, or maintenance of existing structures, facilities,, equipment, or
topographical features. Involving negligible or no expansion or change of use beyond that
previously existing;
2. Replacement or reconstruddon of existing structures and facilities where the new structure
will be located generally on the same site and will have substantially the same purpose,
capacity, density, height, and dimensions as the structure replaced;
3. construction and location of single, new, small facilities or stmctures and the alteration
and modification of the same and Installation of now, small, equipment and facilities and
the alteration and modification of same, including, but not limited to:
a. Single-family residences teas then 3,500 square feet not in conjunction with the
building of two or more such units;
b. Multi-unit structures designed for not more than feu dwelling units if not In
conjunction with the building of two or more such structures;
c. Stores, offices, and restaurants designed for total occupant load of twenty
persons or less per structure, if not in conjunction with the building of two or more
such structures; and
d. Water, sewage, electrical, gas, telephone, and other essential public utility
services extensions to serve such structures or facilities; accessory or
appurtenant structures including garages, carporks, patios, swimming pools, and
fences; and, acquisition of utility easements;
4. Minor alterations in the conditions of land, water, or vegetation;
5. Basic data collection, research, experimental management, and resource evaluation
activities which do not result in a serious or major disturbance to an environmental
resource;
6. Construction or placement of minor structures accessory to existing facilities;
7. Interior alterations involving things such as partitions, plumbing, and electrical
conveyances;
6. Demolition of structures, except those structures located on any historic site as designated
in the national register or Hawaii register as provided for in the National Historic
Preservation Act of 1966, Public Law 89-666, 16 U.S.C. §470, as amended, or chapter
6E. HRS;
9. Zoning variances except shoreline set-back variances; and
10. Continuing administrative activities Including, but not limited to purchase of supplies and
personnel-related actions.
8. All exemptions under the classes In this section are Inapplicable when the cumulative impact of
planned successive actions In the same place, over time, is stgnifirmt, or when an action that Is
normally insignificant in Its impact on the environment may be significant in a particularly sensitive
environment.
C.OMPREIiEWSIVE M-MPT(ON LIST rOP THE
DEPARTMENT OF PUBLIC WORKS
COUNTY OF HAWAII
REVIEWED AND CONCURRED IN BY THE ENVIRONMENTAL COUNCIL ON
JUNE 21, 1996
Purauant to Section 11.200.8, Hawaii Administrative Rules, the following types of actions, where they
tan within the given classes of action, shall generally be exempt from the preparation of an
environmental assessment.
EXEMPTION QA SS 1: Operations, repairs or maintenance of existing structures, facilities, equipment
or topographical features, Involving negligible or no expansion or change of use beyond that previously
existing.
1. Operate, repair and maintain traffic control devices, i.e. traffic signals, street lights, traffic
signs and pavement markings (8/21196).
2. Highway lighting systems (2/6/86).
3. Roofing 1216185).
4. Repair and maintenance of exlstimq structu se (216785).
s S. Guardrail Installation (2/6/86).
8. Acquisition of land or easements on which existing facilities are situated 12161851.
7. Operate, rep* and maintain all County automatlw and construction equipment assigned to
du department (2/61881.
8. Operate, rap* and nalintskn *111 County parking meters ( mAw.
9. Operate. repair end maintain all County owned areas kctudlng, but not limited to, Perking knts,
road rkilm of-way, dndnageways and easements. This mainanance slia8Include removal end
trimming of as vegetation, as needed. In order to minimize any encroachmerm or obstructions
wMk the road dght.of-way (8121/96).
10. Opwgty. apW snd maintain an wastewater fec{fitles kakx2ng sewer lines. pump stations anod
treatment plant components (8/21/96).
11. Operate, repair and maintain all sold waste fscftn Including transfer stations and disposal
facility components (8/21/96).
FYFMON CLASS 2: Repacament or reconstruction of existing structures and faclIttles where the
new structure will be lasted generally on the same site and will have substantially the same purpose,
capacity, density, height and dimensions ss the structure replaced.
1. Replacement or reconstruction of existing asphaltic concrete paved roads or of existing gravel
roads by resurfacing with asphaltic concrete Pavement. The completed road will be located
within the existing right-of-way and will have substantially the same purpose, capacity end
dimensions as the road prior to construction 12/5/85).
(-,omprshensiv* Exemption last
Department of Public W044.
County of Hawaii
June 21, 1995
Page 2 of 3
2. Modernization of an existing highway for safety purposes by resurfacing, widening leas than
a single lane wkhk adding shoulders, adding auxiliary lanes for loca8zed purposes (wesvkng,
climbing, speed changes, etc.) and correcting substandard curves and Intersections (2/5/8S).
3. Replacement or reconstruction of exisdng gravel parking lots not exceeding 20 amps by
resurfacing with asphaltic concrete (2/5/851.
4. Replacement or reconav adon of all wastewater facilities Including sewer lines, pump stations
and treatment plant components (8!21/95).
5. Replacement or reconstruction of all sold waste facilities Including transfer sadore and
disposal facility components IB/21/9S).
8. Rapiseament, reconstruction or extension of wow, "wags, electrical. gas, tiephons, street
light and other essendai Public utility swvke extensions within the County road dgMa.ol.way
QgMUJON CLASS 3: Consvuction and location of skngde, now, small facigdss or mmurras and the
alarstion and modification of some and knaftdon of now, small equipment and facilities and the
skeatkn and modiNcadon of same including but not limited to : (a) single family residency not in
conluncion with the bupdkno of two 13) or more such unhal N muhFunit structures deigned for not
more then four (M dwelling undo, if not in cer*wodon whh to building of two f2l or more such
svucturm (c) stores, offices and restawants designed for teal occupant load of twenty 120) Persons
or In& if not lit conlunodon wlth do burg of two 12) or more such stnwwrw (d) watw, sewage,
sloovical, on, tehphons, and other eesendi Public uWW tevke exanians to serve such strucpKSs
and Willfts. and le) accessory or appwtansnt strucam" kWudkng garages, ewpora, patios.
swimming pools and fences.
1. Play or" and play courts 12/5/85).
2. Fonckng (2/5/851.
3. Install traftk control devices, 6e. traffic agnsls, street lights. Craft signs and pavement
markings (8/21195).
4. Install wastewater facilities kwkxW g "war lines, pump stations and treatment plant
components 10/21/95).
5. Install solid waste facilities Including transfer stations and disposal facility components
(6121/95).
8. New installation of water, sewage, electrical, gas, telephone, sweet light and other essential
public utility service extensions wlthkn the County mad rightoof-way, 18121195).
EXENf.MQN °S 4: Minor alteration In the condition of land, water, or vegetation.
1. Install and/or remove all County parking meters (2/5/88).
Comprehensive `xemptlore Llai
Department of Public Works
County of Howell
June 21, 1996
Page 3 of 3
2. Maintenance and removal of all vegstation from within the County road rights-of-way that pose
a hazard to the health and welfare of the public 18/21 /961. .
3. Maintenance and removal of sell vegetation from within sAssi g sewer One and drainage
easements (8/21185).
4. Maintenance and removal of vegetation in order to conduct survey work (8/21/96).
FxEast+rtoN CUSS b: Basic data collection, research, experimental management, and reaotsce
evaluation activities which do not no* In s serious or major disturbance to an environmental resource.
1. PeAam pto&nkwy auras (e.g. reconnaissance, location work, level circuits, topographic and
hydrographic work) 12/6/88).
FAMMI CLASS N: Construction or placement of minor structures accessory to existing faclidss.
1. brtaior attentions involving such things as partitions, piwnbkg. and electrical conveyances
12!8/86!.
2. Installation of culverts under an OWN Ing County road to eliminate flooding (2/6185).
3. Installation of one or two tons on am& aids of tie rout drywall now within the County
right-ohwav to dminato or reduce beaked flooding. ponding or puddling !25/861.
4. Modification of existing wastewater facilities to Include sewer Ones, pump stations and
treatment plant componsrns 18/21195).
5. Modification of exkstkg sold wash facilities including transfer stations and disposal facility
components 18121/85).
B hang traffic control dsvkss. I.s. traffic sigrub, street OOhn, tratfio signs and pavement
markings 18121/85).
7. kn ii wastw,"W facilities including sswee Ones, pump stations and treatment plant
components (8121195).
8. Instill solid waft facilities including transfer stations and disposal facility components
(8!21/961.
9. New mawation of water, sawsge, electrical, gas, telsphmm street W and other essential
public utility service U aions within the Canny road ripl4100"aq (81211851.
As stipulated in Section t t •200.8(bl, Howell Administrative Rules, all exemptions under this list are
inapplicablo when the cumulative impact of planned successive actions of the some types, in the same
place, over time, is significant, or when an action that is normally Insignificant in its impact on the
environment may be significant in a partictdarly sensitive environment.
COMPREHENSIVE EXEMPTION LIST
FOR THE
STATE OF HAWAII
DEPARTMENT OF TRANSPORTATION
AMENDED, NOVEMBER 15,2000
NOTE: The present list, reviewed and concurred in by the Environmental
Council Docket 92-EX-01), State of Hawaii, amends and supersedes the December
16, 1992, exemption list for the Department of Transportation.
Pursuant to Section 11-200-8 (a), Hawaii Administrative Rules, the following
types of actions, where they fall within the given classes of action, shall
generally be exempt from requirements regarding the preparation of an
environmental assessment.
EXEMPTION CLASS 1: Operations, repairs or maintenance Of existing structures,
facilities, equipment or topographical features, involving negligible or no
expansion or change of use beyond that previously existing.
A. STRUCTURES
1. Buildings: repainting, reroofing, and repairs to and
maintenance of furnishings, framework, walls, roof sheathing, flooring, floor
coverage, windows, doors, electrical, plumbing, and communication systems,
elevators, escalators, conveyors, heating/ventilation/air conditioning units,
pedestrian bridges and underpasses.
2. Termite and past control treatment using Environmental
Protection Agency and State Department of Agriculture approved pesticides under
the supervision of certified applicators.
3. Repairing and maintaining protective walls damaged by aircraft
blast.
4. Grooving of existing concrete pavements, bridge decks,
taxiways and runways to improve skid resistance and safety.
5. Cleaning, chipping, painting, patching of damaged concrete and
replacement of structural members to existing roadway structures, including
tunnels and parking structures.
6. Modification required to existing buildings and equipment to
meet new codes and regulations, i.e., Occupational Safety 6 Health
Administration, building, fire, security, Federal Aviation Administration,
accessibility for the handicapped, environmental compliance, etc.
7. Repairs and modifications to sewage and water pumping stations
and treatment facilities to maintain established codes and standards provided
that modifications that expand the capacity or geographical service area of
existing facilities shall not be exempt.
B. FACILITIES
1 . Resurfacing, sealing, and/or repairing of roadways, roadway
shoulders, parking areas, taxiways, runways, walkways, bikeways and harbor
storage and container areas.
2. Repair or replacement of fender systems, utilities, manholes,
air and water navigational aids, and pipelines, excluding underwater pipelines.
3. Repairs or improvements to hatch frames and covers,
residences, loading docks and mooring facilities.
9. Repairs to rockwalls, curbings, perimeter seawalls, groins,
dikes, breakwaters, loading docks, and storm drains.
5. Temporary parking on highway remnant properties.
6. Temporary storage of construction equipment and materials on
highway remnant properties.
C. EQUIPMENT
1. Repair and maintenance of automobiles, trucks, maintenance
and construction equipment used by the department in the performance of duty.
2. Repair and maintenance of machinery such as tools, mowers,
pumps, generators, etc.
D. TOPOGRAPHICAL FEATURES
1. Planting, trimming, mowing, and irrigating State Department
of Transportation airport, harbor, and highway areas.
2. Clearing and grading, for which grading permits are not
required, to maintain safety and security standards for aircraft and vehicular
traffic.
3. Clearing of swales and drainage conduits to maintain existing
flow characteristics.
9. Clearing of shoreline areas of debris or other objectionable
material such as oil and derelict craft.
5. Requests to the Department of Land and Natural Resources or
General Services Administration for setting aside of State lands to the
Department of Transportation.
6. Requests to the Department of Land and Natural Resources for
transfer of State lands by Governor's Executive Order between the Department of
Transportation and other State agencies.
7. Subdivision of lot (s) not previously subdivided into highway
parcel (s) and highway remnant (s).
8. Subdivision of portion of highway due to encroachment or
determined surplus.
9. Consolidation of residential-zoned highway remnant parcels
into one lot (residential).
10. Leases of property for continuing aeronautical uses or
complementary airport purposes.
6. Installation and removal of sprinkler systems.
7. Utility service connection and installation along and across
State highway or roads, and in airports and harbors.
EXEMPTION CLASS 9: Minor alteration in the conditions of land, water, or
vegetation.
1. Minor ground adjustments which do not require grading permits
for the purpose of eliminating hazards to vehicular traffic and aircraft
operations or to compromise air navigational aids.
2. Landscaping: trimming and/or transplanting of trees: sodding
of bare areas for dust and erosion control.
3 . Paving of shoulder areas within existing highway rights-of-way
for driveways and subdivision street connections. These shoulder pavings will
provide vehicular access to the highway pavement lanes from the adjacent common
property line for residential and commercial driveways and subdivision street
connections. These actions will not alter the character of the highway
facility.
9. Landscaping limited to installation of underground sprinkler
or drip irrigation system and planting of groundcover, shrubs, and trees
involving minimum or no grading on property under the jurisdiction of the
Department of Transportation.
5 . Paving of previously graded parking and storage yard areas
under the control of the Department of Transportation.
EXEMPTION CLASS 5: Basic data collection, research, experimental management,
and resource evaluation activities which do not result in a serious or major
disturbance to an environmental resource.
1. Conduct topographic, sounding, wave, littoral transport and
location surveys.
2. Conduct foundation surveys.
3. Conduct traffic surveys (including transit patronage surveys).
4. Conduct graves surveys.
5. Conduct noise monitoring surveys.
6. Conduct drainage studies.
7. Conduct inventories.
S. Conduct building evaluations.
9. Conduct economical analyses (master planning updates).
10. Conduct archaeological surveys, excluding excavation.
11. Conduct air quality surveys.
12. Conduct ecological surveys for which no permit is required.
13. Conduct water quality surveys.
14. Conduct ridesharing demonstrations.
15. Conduct subsurface investigations (borings) provided cultural
remains are not disturbed.
EXEMPTION CLASS 6: Construction or placement of minor structures accessory to
existing facilities.
1. Installation of flare screens, safety barriers, guard rails,
energy attenuators and other appurtenances designed to protect the motoring
public.
2. Installation of traffic signals, pavement marks, and striping for
traffic safety and control.
3. Installation of directional, informational, and regulatory
signs.
4. Installation of light standards..
5. installation of screens around trash bin areas and for noise
control.
6. Installation of reefer outlets.
7. Procure and install works of art.
0. Alteration or addition of improvements with associated
utilities, which are incidental, to existing harbor and boat ramp operations, in
accordance with master plans that have met the requirements of Chapter 393,
Hawaii Revised Statutes. Such improvements and associated utilities include
concessions, comfort stations, pavilions, paving, rockwalls, fencings, walkways, _
loading docks, warehouses, piers, offices, container freight stations, cranes,
fuel lines, lighting, sprinkler and drainage systems.
9. Construction of bus shelters, telephone booths and sidewalks.
10 Striping of existing paved roadways or paved shoulders to
create a bikelane when no additional construction is required.
EXEMPTION CLASS 7: Interior alterations involving things such as partitions,
plumbing, and electrical conveyances.
1 Installation of office partitions and electrical outlets as
required.
2. Expand utilities as need dictates in existing structures.
3. Maintaining of existing utilities.
EXEMPTION CLASS B: Demolition of structures, except those structures located on
any historic site as designated in the National Register or Hawaii Register as
provided for in the National Historic Preservation Act of 1966, Public Law 89-
665, or Chapter 6E, Hawaii Revised Statutes.
1. Demolition of existing structures under Department of
Transportation jurisdiction except seawalls and other coastal structures and
those structures located on any historic site as designated in the National
Historic Preservation Act of 1966, Public Law 89-655, or Chapter 6E, Hawaii
Revised Statutes.
EXEMPTION CLASS 9: Zoning variances except: use, density, height, parking
requirements and shoreline setback variances.
None.
NOTE: Pursuant to Section 11-200-8 (b), Hawaii Administrative Rules, all
exemptions under this list are inapplicable when the cumulative impact of
planned successive actions of the same type, in the same place, over time, is
significant, or when an action that is normally insignificant in its impact on
the environment maybe significant in a particularly sensitive environment.