Kamehameha Schools Comments on Draft HCDP

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Mr. Duane Kanuha Re: Comments from Kamehameha Schools to Draft HCDP (Jan. 2016) June 15, 2016 Page 5 of 7 CDP with an average lot depth of two hundred feet or less, the shoreline setback line shall be 40 feet. The development of a countywide coastal setback policy should take into account the unique geologic, geographic, topographic, and coastal conditions along the Hamakua coast. In addition, regarding setback regulations based on the proposed 1:1 horizontal to vertical concept, more information and data is required to determine the efficacy and implications of basing regulations on such concept. Moreover, Policy 19 raises additional questions and comments, for example: • Does Policy 19 apply to riparian or riverine areas? KS understands that the County is working on a separate policy addressed to riverine setbacks. Policy 19 is unclear that the policy is meant only for coastal areas, and not both coastal and riverine areas. To avoid potentially conflicting policies, the County should include language in Policy 19 clarifying that the policy does not apply to riparian or riverine areas, and should expressly limit its application to coastal areas. • Policy 19 provides two methods (i.e., methods A and B) for establishing the setback. Policy 19, however, does not define who (or what agency) determines which method is used and when one method should or would be used over the other. The lack of definition creates uncertainty. For example, does the County intend permit approval to be contingent on the use of the more restrictive method ? • Method A of Policy 19 is based on a 1:1 ratio of vertical cliff height to a horizontal setback. The Draft HCDP Rationale does not support this specific formula, and the County has not provided references to additional data regarding this concept. • KS understands the County is working on defining certain technical and material terms affecting Policy 19 and other policies, such as "toe of slope" and "top of Pali." Until these terms are defined, the implications and impact of Policy 19 cannot be fully assessed. KS reserves the right to supplement its comments to Policy 19 pending the County's finalization of such terms and definitions.