Memo_Yagong_Planning Dept Comments 304 Dr April_11

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Comments on Bill 304 Prepared by Co of HI Planning Department April 5, 2011 Who would conduct the review? Fee Assessments 35 -8 • Different points of collection complicate management of the impact fee system. If possible, all fees should be collected at building permit stage to simplify the process. • For some, impact fees will be an incentive to build without obtaining building permits. How will enforcement be handled? • (c) In small lot subdivisions: If the intention is to assess a fee for each dwelling, the bill should specify whether additional dwellings (e.g., `ohana units, farm dwellings) will also be assessed. Exemptions (36 -9) • Given the nature of the exemptions, the Planning Department believes that DPW's Building Division is better suited than Planning to determine the validity of exemption claims. Affordable Housing_ (35 -10) ■ What will be the source of the County funding for the "affordable housing trust fund "? o How will the County determine the size of the fund needed to provide the loans? • The Finance Department (rather than OHCD) may be better suited to oversee the trust fund. How will the County ensure that fees are paid if an owner obtains a permit to expand the size of their dwelling beyond the maximum criteria as stated in this section? ■ Confirm that DHCD supports Section 36 -10, particularly exemptions and the qualifying process for zero - interest loans. This is an intensive and complex process that requires cross - agency collaboration. (it is presumed that additional staffing will be required.) Fee Calculations, Adjustments, and Credits (36-12,14, and 17) • Is the fee adjusted annually for both inflation and per an adjustment factor, or is the adjustment factor used to calculate the inflation rate? • The Honolulu Consumer Price Index (HOPI) is typically available at the end of February or in early March, so July 75t would be a more appropriate date for the adjusted fee schedule to go into effect. • The Departments that are familiar with costs and improvements i.e., DPW, Parks, Fire, Police, DEM) are better suited than Planning to determine the adjustment factor (36 -12), to prepare independent fee calculations (36 -14), and to approve credits (36-17)., Page 2 of 7