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Comments on Bill 304 <br /> Prepared by <br /> Co of HI Planning Department <br /> April 5, 2011 <br /> precedes its publication. Given that the County's CIP has changed since then, and other <br /> changes have occurred (including the preparation of several CDPs), that Study needs to <br /> be updated and the fees need to reflect that update. Further, again due to the time lapse, it <br /> may be difficult to determine fee credits or reconcile credits against infrastructure <br /> privately installed. <br /> 5. The impact fee program has implementation issues that will require staff time, software, <br /> agency coordination, etc. The Kona CDP Financing Plan proposed a separate impact fee <br /> to cover the cost of infrastructure financing administration, which would include in large <br /> measure the cost of the Kona CDP impact fee program. A separate fee for impact fee <br /> program administration should probably be added to the bill. <br /> 6. It is not clear to me whether money in impact fee funds and accounts can be co- mingled <br /> to maximize flexibility in the use of the fee revenue. This could accelerate construction <br /> of needed infrastructure and reduce costs of interest and borrowing. Stipulations about <br /> inter -fund /account borrowing would have to be made, including that borrowed funds <br /> must be repaid with interest. <br /> Keep me posted how things go, and don't hesitate to ask any follow -up questions about this. <br /> — Dave <br /> Page 7 of 7 <br />