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manner as a zone change, "unless the council authorizes the changes or alterations to <br />be made by the director". What circumstances might exist where the County Council <br />would pre -authorize the Planning Director to allow a time extension? If the intent of this <br />section is to authorize the Planning Director to approve a time extension on a case -by - <br />case basis, it would be helpful to know what this criteria is. Perhaps I'm <br />misunderstanding this section, but that's how this language reads to me. <br />3. If Bill 194 is approved by the County Council, establish that the time extension is a one- <br />time extension, and valid for a specific time period - say two years. Once the time <br />extension has run its course, and no further action has been taken by the developer to <br />secure a grading or building permit to vest the project, the project should be deemed <br />abandoned, and invalid. No subsequent time extensions should be allowed. <br />Additionally, I'd like to offer that language within Section 25-2-44(d) be modified to <br />reflect that the "County Council direct (emphasis added) the Planning Director to initiate <br />the process for enactment of an an Ordinance reverting the affected property back to <br />its original zoning designation or a more appropriate zoning designation in accordance <br />with Section 25.2.43". This way, there is no confusion about which entity within the <br />County is pursuing a zoning ordinance revision, and clearly directs the Planning Director <br />to take this action. <br />4. For any time extension request where an updated environmental review has been <br />prepared, have this document peer reviewed by a third party that the developer pays <br />for. When the private developers prepare these documents, it feels as if the fox is <br />watching the hen house. You can't have the entity who's requesting a rezoning also <br />prepare the environmental document for the project. There's no appearance of <br />neutrality, and of any kind of checks and balance approach. It also doesn't appear <br />that there is any independent analysis by the Planning staff of the environmental <br />document. <br />It would be helpful for the public to understand how many applications have been approved <br />and not built, and approved where an extension has been requested and approved - whether <br />by one of the Planning Commissions or County Council. Such a list would provide a more <br />comprehensive understanding of the scale of development that could occur on the island and <br />the impacts to the road system, water, wastewater, electric generation, natural habitats, and <br />potential loss of pre -contact Native Hawaiian artifacts. This list would be a significant tool for <br />the County Council to have as it contemplates Bill No. 194. <br />Thank you for the opportunity to comment on this much needed legislation. <br />Mahalo. <br />Elizabeth Dunn <br />2 <br />