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While I realize that the Envision Downtown Hilo 2025 group has put a lot of time and effort into <br />their plan, I believe that the proposed changes adversely affect the redevelopment of Downtown <br />Hilo, and all of us. <br />The height limit from 120 feet to 60 feet or 80 feet (all other CDH zoned property) will <br />negatively impact Downtown Hilo’s potential to become a healthy, mixed-used community by <br />eliminating almost half of the potential buildable area within Downtown. <br />A vibrant Downtown is dependent on residents living, working and finding recreation in the <br />immediate area. The elimination of any potential buildable area Downtown will deter <br />investment and may prevent Downtown Hilo from developing into the comprehensive living and <br />work space most residents would like to see it become. <br />Practically, a height limit of 60 feet, combined with the current interpretation of building <br />requirements within the Tsunami Inundation Area, will most likely limit projects to a maximum <br />of three floors of potential living space. Based on market construction costs and rental income, it <br />is currently unfeasible to redevelop any property in Downtown Hilo to its highest and best use. <br />A reduction in the height limit will perpetuate this condition. <br />Maximum density must be achieved to reliably attract new businesses and services to the <br />Downtown area. The current lack of public parking and pedestrian traffic serve as deterrents to <br />many businesses, which I feel has been a major hindrance to the revitalization of Downtown <br />Hilo. The best way to address this issue is to encourage developers to increase housing options <br />and construct parking, since doing so will logically attract more traffic Downtown. A height <br />limit of 60 feet is not conducive to the construction of parking or residences, two essential <br />elements of redevelopment. <br />I also disagree with the assertion that the CDH requires an additional “sub-zone”, the proposed <br />Downtown Hilo Commercial Core, which would include all property bounded by Hilo Bay, <br />Wailuku River, and the eastern boundary of Kinoole and Ponahawai Streets. <br />This additional definition proposes to further restrict the potential uses of property that is already <br />the most restricted land within the CDH zone. Properties within this zone are not only governed <br />by applicable building and zoning requirements, but flood plain management restrictions (FEMA <br />and SMA regulations) apply to the majority of properties in this zone as it is. <br />By further classifying the CDH, we will only create additional disincentives to rebuilding and <br />revitalizing Downtown Hilo. <br />Finally, I do not believe it is wise to amend the Code to eliminate uses that are currently allowed <br />and in existence in Downtown. A better strategy would be to encourage even more diverse uses <br />and create greater opportunities for businesses and residents. <br />14 <br /> EXHIBIT C <br /> <br />