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Comments on Bill 304 <br />Prepared by <br />Co of HI Planning Department <br />April 5, 2011 <br />precedes its publication. Given that the County's CIP has changed since then, and other <br />changes have occurred (including the preparation of several CDPs), that Study needs to <br />be updated and the fees need to reflect that update. Further, again due to the time lapse, it <br />may be difficult to determine fee credits or reconcile credits against infrastructure <br />privately installed. <br />5. The impact fee program has implementation issues that will require staff time, software, <br />agency coordination, etc. The Kona CDP Financing Plan proposed a separate impact fee <br />to cover the cost of infrastructure financing administration, which would include in large <br />measure the cost of the Kona CDP impact fee program. A separate fee for impact fee <br />program administration should probably be added to the bill. <br />6. It is not clear to me whether money in impact fee funds and accounts can be co- mingled <br />to maximize flexibility in the use of the fee revenue. This could accelerate construction <br />of needed infrastructure and reduce costs of interest and borrowing. Stipulations about <br />inter - fund /account borrowing would have to be made, including that borrowed funds <br />must be repaid with interest. <br />Keep me posted how things go, and don't hesitate to ask any follow -up questions about this. <br />— Dave <br />Page 7 of 7 <br />