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Comments on Bill 304 <br /> Prepared by <br /> Co of HI Planning Department <br /> April 5, 2011 <br /> • Who would conduct the review? <br /> Fee Assessments (36 -8) <br /> • Different points of collection complicate management of the impact fee system. <br /> If possible, all fees should be collected at building permit stage to simplify <br /> the process. <br /> • For some, impact fees will be an incentive to build without obtaining building <br /> permits. How will enforcement be handled? <br /> • (c) In small lot subdivisions: If the intention is to assess a fee for each dwelling, <br /> the bill should specify whether additional dwellings (e.g., `ohana units, farm <br /> dwellings) will also be assessed. <br /> Exemptions (36 -9) <br /> • Given the nature of the exemptions, the Planning Department believes that <br /> DPW's Building Division is better suited than Planning to determine the <br /> validity of exemption claims. <br /> Affordable Housing (36 -10) <br /> • What will be the source of the County funding for the "affordable housing <br /> trust fund "? <br /> o How will the County determine the size of the fund needed to provide <br /> the loans? <br /> • The Finance Department (rather than OHCD) may be better suited to <br /> oversee the trust fund. <br /> • How will the County ensure that fees are paid if an owner obtains a permit <br /> to expand the size of their dwelling beyond the maximum criteria as stated <br /> in this section? <br /> • Confirm that OHCD supports Section 36 -10, particularly exemptions and the <br /> qualifying process for zero - interest loans. This is an intensive and complex <br /> process that requires cross - agency collaboration. (It is presumed that additional <br /> staffing will be required.) <br /> Fee Calculations, Adiustments, and Credits (36 -12, 14, and 17) <br /> • Is the fee adjusted annually for both inflation and per an adjustment factor, <br /> or is the adjustment factor used to calculate the inflation rate? <br /> • The Honolulu Consumer Price Index (HCPI) is typically available at the end of <br /> February or in early March, so July 1 St would be a more appropriate date for <br /> the adjusted fee schedule to go into effect. <br /> • The Departments that are familiar with costs and improvements (i.e., DPW, <br /> Parks, Fire, Police, DEM) are better suited than Planning to determine the <br /> adjustment factor (36 -12), to prepare independent fee calculations (36 -14), <br /> and to approve credits (36 -17). <br /> Page 2 of 7 <br />