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Second, he stated "the current wording suggests that the consultant's determination <br /> occurs after Plan Approval" but this claim is unfounded as the language refers to "the <br /> proposed use" which indicates this option is part of an application process and does not <br /> occur after Plan Approval. Even if the language needs to be tweaked a bit, that hardly <br /> constitutes a "significant concern" that merits an unfavorable recommendation. <br /> Third, the Director stated that "it would be more logical to hire a consultant before Final <br /> Plan Approval rather than afterward" but, again, the language in this Section refers to <br /> "the proposed use" which indicates this option is part of an application process and <br /> does not occur after Plan Approval. <br /> Fourth, the Director stated that "relying on private consultants could introduce delays in <br /> the approval process" that may violate the 60-day timeframe mandated by HRS 4689. <br /> Again, this claim is unfounded and alarmist because nothing in Bill 194 includes "relying <br /> on private consultants". The choice to engage a private consultant is mentioned only <br /> once, is optional, and is at the discretion of the Director. <br /> 5) Regarding Proposed Section 25-4-12(h) <br /> This Section describes tower siting prioritization. It says: <br /> (h) Telecommunication antennas and towers shall be sited in accordance with the <br /> following order of priority: <br /> (1) On building sites with existing telecommunication antennas or towers; <br /> (2) On industrial zoned lands; <br /> (3) All other lands, exclusive of industrial zoned lands and residential zoned lands; <br /> and <br /> (4) Residential zoned lands. <br /> The Director stated five concerns. <br /> First:The Director's stated concern is that it's "unclear how staff should prioritize <br /> applications across zoning districts", which is confounding since the proposed Section <br /> describes exactly how applications should be prioritized. <br /> Second: He stated it "lacks guidance on whether applicants must analyze unviable <br /> lower-priority sites."This statement is baffling. Why would an applicant need guidance <br /> about analyzing unviable lower-priority sites? Why is this even a concern for the <br /> Director? And even if it was a valid concern, telecommunications corporations have <br /> endless resources at their disposal. They are free to do any and all analyzing of unviable, <br /> low-priority sites if they so choose without that being stipulated in the ordinance. <br />