Agency Review Comments Combined UPDATED 03.21.2018

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Mr. Michael Yee, Director Hawaii County Planning Department Review of the Hamakua Community Development Plan (CDP) April 17, 2017 Page 3 5. Complete Streets. Section 5.3 of the Hamakua CDP (pages 73 to 80) should reference the relevant State and County Complete Streets policies, pursuant to Act 54, Session Laws of Hawaii 2009 and HRS § 264-20.5. The CDP should elaborate on the policies related to Complete Streets, including the key State Complete Streets principles: safety, Context Sensitive Solutions (CSS), accessibility and mobility for all, use and comfort of all users, consistency of design guidelines and standards, energy efficiency, health, and green infrastructure. 6. Coastal Zone Management (CZM). Coastal Zone Management and Special Management Areas (SMA) are addressed in Chapter 205A, HRS, the CZM Act. a. Section 3.1.4, Land Use Policy, Policy 2, on page 35, of the Hamakua CDP states that new urban development shall be located away from coastal areas and the Special Management Area (SMA). The Hamakua CDP should define the term "coastal area." The coastal area can be much larger in size than the SMA, and may encompass offshore and land area. The Hamakua CDP should also provide a rationale on locating urban development away from the SMA, and list the expected advantages that may ensue from this new policy. Section 4.2.4, County Action, Policy 22, page 54-55, considers amending SMA rules to protect coastal resources. On page 55, the analysis recommends SMA boundary amendments to further protect known resources. The Hamakua CDP should provide site specific justifications for SMA boundary amendments. b. Section 4.2.3, Land Use Policy, Policy 18, on page 53, seeks to limit coastal development to achieve Coastal Zone Management and CDP objectives and policies. The use of the term "limit coastal development" is vague and too broad. We recommend a more "refined definition of this term that could include the following: "Place special controls on development within an area along the shoreline." c. Section 4.2.3, Land Use Policy, Policy 18, page 53, contains an incorrect citation. The Policy states that "An assessment of impacts on coastal scenic and open space resources and view planes, including those outlined in the General Plan, the Community Development Plan, and other adopted plans, as well as the line of sight toward the sea from the state highway nearest the coast and along the shoreline. HRS § 205A -26(3)(E) should be listed as HRS § 205A -26(3)(D).