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March 12, 2018 <br />Page 2 <br />A separate issue is that having SB 2567, SD 2 become effective at an early date <br />would not provide either DOH or an existing homeowner time to adequately prepare for <br />this new requirement. The process of establishing administrative rules for exemptions <br />or to establish financial aid legislation or rules, within a few months, or even a few <br />years, would be inadequate and would result in a negative impact on low and middle <br />income families. Such an imposition on current homeowners ought not to occur for at <br />least 10 years, so if this proposed legislation is enacted, it is strongly urged that it take <br />effect no earlier than December 31, 2028. A delay would allow DOH to investigate <br />alternative IWS and appropriate treatment standards for home IWS replacements for <br />cesspools. <br />Finally, 1 recognize and appreciate that SB 2567, SD 2 provides for a waiver of <br />the conversion requirement under certain circumstances. However, if it is determined <br />that this bill must move forward, 1 would ask that it be amended to require conversion <br />only in those geographic areas where there has been a determination that drinking <br />water, public recreation, or coral reefs are at imminent risk of harm. A slightly different <br />approach would be to add to the "legitimate reasons" for a waiver: <br />(5) No finding by DOH that drinking water, public recreation, or <br />coral reefs are at imminent risk of harm. <br />Thank you for your consideration. <br />pectfu ly sub ited, <br />Mayor, County of Hawaii <br />County of Hawaii is an Equal Opportunity Provider and Employer. <br />