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Comments on Bill 304 <br /> Prepared by <br /> Co of HI Planning Department <br /> April 5, 2011 <br /> • How do the proposed indices compare to current methods of estimating <br /> CIP costs? <br /> • If the specified cost indices are not available, what "reasonable alternative <br /> indices" will be used? <br /> • How would impact fees for Special Use permits or Home Occupations be <br /> determined? <br /> • 36 -12 (f): Consider a reduced fee as an incentive for high density mixed use <br /> development in core already urban developed areas. <br /> • 36 -17 (b): Currently states that in -lieu credits need to be approved by Council. <br /> This extra step could be eliminated and addressed as an administrative <br /> function under the Director or Administrator. <br /> Refunds (36 -16 & 36- 24(d)) <br /> • (a) Within how much time will this refund take place (e.g., 1 year)? What if <br /> fees have been spent for infrastructure improvements and then a refund is <br /> requested and granted? <br /> • (b) Though specified in HRS, the six year "expiration date" is too short <br /> considering 1) slow rates in fund growth (i.e., when sufficient funds will be <br /> available to finance projects), 2) costs of likely improvements (which may exceed <br /> fund balances), and 3) typical project lifespan from concept to completion <br /> (usually greater than 6 years). <br /> • If all impact fees are collected at issuance of building permit, it is less likely <br /> that refunds will be requested. <br /> • The Impact Fee Fund Administrator (i.e., Finance) is better suited than <br /> Planning to process refund applications. <br /> Fund Interest Rate (36 -16(b) and 36 -19) <br /> • Who determines the interest rate, and how? If so, what determines which <br /> projects get refunds (at what stage)? <br /> Fair Share (36 -18) <br /> • Will developers be issued a refund if they have paid more Fair Share than <br /> the impact fee requires? <br /> Impact Fee Fund Administrator (36 -22) <br /> • (a) (1) It is not stated anywhere that Planning collects fees from small <br /> subdivisions and DPW collects all other fees. A single agency with financial <br /> management capacity should collect fees, and it should be consistent <br /> throughout the Bill. <br /> • The Department of Finance is best suited to be the Impact Fee Fund <br /> Administrator. <br /> Page 3 of 7 <br />