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Mr. Duane Kanuha <br />Re: Comments from Kamehameha Schools to Draft HCDP (Jan. 2016) <br />June 15, 2016 <br />Page 2 of 7 <br />community collaborations. Approximately 98 percent of the support for KS' educational <br />programs comes from its endowment fund. Program tuition and fees are nominal, and the <br />majority of students are eligible for financial aid or merit -based scholarships. <br />To ensure that the endowment continues to provide educational opportunities in perpetuity, <br />KS practices prudent management of its trust. Driven by its new strategic plan, KS also <br />seeks to partner with entities that have mutual goals for the advancement and well-being of <br />Hawai`i's people, its systems and its lands. <br />KS respectfully submits the following <br />Development Plan for consideration by <br />"Steering Committee'. <br />1. General Comments <br />comments to the Draft Hamakua Community <br />the Hamakua CDP Steering Committee (the <br />1.1. Amend References to "Bishop Estate/Kamehameha Schools" <br />Pages 69, 72, and 88 of the Draft HCDP and the two references on page 103 of the <br />Hamakua Community Development Plan: Rationale (Jan. 2016) (the "Draft CDP <br />Rationale', refer to and use the term "Bishop Estate/Kamehameha Schools". KS requests <br />that all references in the Draft HCDP and the Draft CDP Rationale to "Bishop <br />Estate/Kamehameha Schools" be amended to read simply: "Kamehameha Schools". <br />1.2. Clarify Legal Enforceability of HCDP Absent Legislation <br />Over the years, the County has applied components of other adopted community <br />development plans with the same force and effect as law or administrative rules and <br />regulations. According to Section 15.1 of the General Plan, however, "... Community <br />Development Plans shall recommend amendments as appropriate to the codes, maps, or <br />administration and enforcement." (Emphasis added.). Furthermore, the focus of a <br />community development plan is to identify "courses of action" by district in greater detail <br />than the General Plan. Community development plans, like the Draft HCDP, are not <br />intended to be used, nor should they be used, in place of validly enacted or amended <br />statutes, county codes, or agency rules and regulations. The Draft HCDP, like all <br />community development plans, should identify specific codes, rules, or regulations for <br />appropriate and valid amendment to carry out the policies and objectives of the plans. <br />The Draft HCDP, like other community development plans, is robust with <br />statement of policy and proposed actions. KS is concerned that such a robust plan as the <br />