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Comments on Bill 304 <br />Prepared by <br />Co of HI Planning Department <br />April 5, 2011 <br />■ How do the proposed indices compare to current methods of estimating <br />CIP costs? <br />• If the specified cost indices are not available, what "reasonable alternative <br />indices" will be used? <br />■ How would impact fees for Special Use permits or Home occupations be <br />determined? <br />• 36 -12 (f): Consider a reduced fee as an incentive for high density mixed use <br />development in core already urban developed areas. <br />• 36 -17 (b): Currently states that in -lieu credits need to be approved by Council. <br />This extra step could be eliminated and addressed as an administrative <br />function under the Director or Administrator. <br />Refunds (36 -16 & 36- 24(d ) } <br />• (a) Within how much time will this refund take place (e.g., 1 year)? What if <br />fees have been spent for infrastructure improvements and then a refund is <br />requested and granted? <br />• (b) Though specified in HRS, the six year "expiration date" is too short <br />considering 1) slow rates in fund growth (i.e., when sufficient funds will be <br />available to finance projects), 2) costs of likely improvements (which may exceed <br />fund balances), and 3) typical project lifespan from concept to completion <br />(usually greater than 6 years). <br />• If all impact fees are collected at issuance of building permit, it is less likely <br />that refunds will be requested. <br />• The Impact Fee Fund Administrator (i.e., Finance) is better suited than <br />Planning to process refund applications. <br />Fund Interest Rate (36-16(b) and 36 <br />Who determines the interest rate, and how? If so, what determines which <br />projects get refunds (at what stage)? <br />Fair Share (36 -13) <br />• Will developers be issued a refund if they have paid more Fair Share than <br />the impact fee requires? <br />Impact Fee Fund Administrator 36 -22 <br />• (a) (1) It is not stated anywhere that Planning collects fees from small <br />subdivisions and DPW collects all other fees. A single agency with financial <br />management capacity should collect fees, and it should be consistent <br />throughout the Bill. <br />• The Department of Finance is best suited to be the Impact Fee Fund <br />Administrator. <br />Page 3 of 7 <br />