HomeMy WebLinkAboutCOM 0896.154 2022-2024P / Goun I
HAWAII ISLAND GROUP
August 20, 2024
County of Hawai'i �
County Council'
25 Aupuni St
Hilo HI 96720
Re: Opposition to Bill 169, Draft 2
Aloha Madam Chair and members of the county council,
There is no justification for granting an extension of time for this rezoning for the following
reasons:
Housing
Bill 169, draft 2 will not provide additional affordable housing. Even there is a commitment to
20% affordable housing units, this would only provide the number of affordable housing units
required for this residential development alone.
Please see the attached a study completed by Keyser -Marston Associates for the City and County
of Honolulu. As you can see from the table below, 20% inclusionary affordable housing units
will only supply the number of affordable units needed to accommodate the 80% market rate
homes (1 of every 5 homes built).
Cumulative Inclusionary Percentage to Mitigate Increased Affordable Housing Need
Single Family
Low -Rise
Mid -Rise
High -Rise
Rental
Townhomes
Condo
Condo (PUQ
Apartment
Extr. Low
3.8%
3.5%
3.1%
4.1%
3.1%
(up to 30%
AMI)
Very Low
10.5%
9.5%
8.8%
11.1 %
8.7%
(up to 50%
AMI)
Low (up to
16.5%
15.1 %
14.0%
17.4%
13.8%
80% AMI)
Moderate
19.8%
18.2%
16.9%
20.9%
16.7%
(up to 120%
AMI)
140% Tier
20.5%
18.9%
17.6%
21.7%
17.3%
(up to 140%
AMI)
The average 2023 home price in Hawai'i was $510,000. Assuming a 6.5%, 30-year mortgage
with 20% down with mortgage and associated costs being 30% of the purchaser's annual
P 0 Box 11,37 Hilo, 1-11 967E 1-1'137
income, the household income would have to be approximately $135,000 per year. This would
bring approximately $375,000 (70% x $135,000 x 4 housing units) in discretionary income
directly into the local economy. That money will create a demand for additional services, such
transportation, food, healthcare, home and yard maintenance, etc. The demand for additional
services creates the need for additional jobs. The people getting those new lower paying service
jobs would need affordable housing. That is why one affordable unit must be built in each
residential development for every 4 market rate units built.
To summarize, a residential development being sold at market rate would need to supply 20%
affordable homes to handle the additional demand for services to those new market rate
households. Therefore, Kona/Royal Visas does not provide net additional housing units for our
county's affordable housing unit inventory.
Additional information supporting denial of Bill 169, draft 2:
General Plan Section 5, Flooding and Other Natural Hazards
"5.4 STANDARDS
(a) "Storm Drainage Standards," County of Hawaii, October, 1970, and as revised.
(b) Applicable standards and regulations of Chapter 27, "Flood Control," of the
Hawaii County Code.
(c) Applicable standards and regulations of the Federal Emergency Management
Agency (FEMA).
(d) Applicable standards and regulations of Chapter 10, "Erosion and Sedimentation
Control," of the Hawaii County Code.
(e) Applicable standards and regulations of the Natural Resources Conservation Service
and the Soil and Water Conservation Districts."
"5.5.7 North Kona
5.5.7.1 Profile
The North Kona district can be divided into two watershed areas. The area north of
Keahole Point and the summit of Hualalai have very low rainfall and runoff. Rainfall
for this area reaches a maximum average of 40 inches per year, but most of the area receives
less than 20 inches per year. The soils in the area are extremely permeable and
there is no record of hazardous flooding in this area.
The southern area, extending southward from Keahole Point, contains most of the urban
development and is subject to increasing hazards from floodwater damages as
land is more intensively utilized. The area is characterized by dry vegetative growth
along the coastal areas and thick tropical vegetation in the upper forest reserves. The
ground slope is steep, averaging approximately 15 per cent.
The steep slopes, shallow soils, frequent high intensity rains, and the lack of well-defined
drainageways make many areas in the North Kona district susceptible to flooding
and overland flows.
Flash floods, primarily from overflows of the Keopu/Hienaloli, Waiaha, Kaumalumalu
and the Holualoa/Horseshoe Bend drainageways, have been identified by the
Natural Resources Conservation Service's "North Kona Flood Plain Management
Study."
Flood water and sediment damage occurs along the entire coffee belt with the Kainaliu,
Holualoa and Kailua village areas experiencing the heaviest damage.
The entire coastline of the North Kona district is subject to inundation by tsunamis.
Kailua and Keauhou have recorded run up and damage from tsunami activity in the
past. In addition, the coastline has also been subject to damage from storm waves."
"5.5.7.2 Courses of Action
(a) Drainage systems for the Keopu/Hienaloli, Waiaha, Kaumalumalu and the Holualoa/
Horseshoe Bend drainageways shall be studied and remapped to determine the
actions necessary to mitigate negative impacts.
(b) Establish and maintain appropriate vegetative cover in high rainfall, sediment and
debris producing areas.
(c) Encourage the mapping of the floodways in North Kona to develop more effective
flood control programs.
(d) Encourage the use of natural drainageways as greenways in the development of
the region.
(e) Maintain and re-establish forest cover in mauka areas to improve the capacity of
the ground to absorb heavy rainfall."
Kona Community Development Plan, Flooding
The county council should consider and apply the policies and actions in the Kona CDP Chapter
4.3.2.b. "Turning Stormwater Management into an Asset. If the mauka lands are able to mitigate
some of the surface stormwater runoff, there is still a challenge in managing stormwater runoff
because of Kona's steep topography and undefined drainageways. The objective is to identify the
drainageways where the major stormflows would be directed, provide a buffer to these
drainageways to account for our imperfect knowledge, and to design these drainageways to
function as recreational or open space amenities (e.g., linear parks).
The following KCDP Policies and Actions must be considered and applied when considering
Bill 169, Draft 2:
Policy ENV-1.7: Flood Corridors. The County's
Central Environmental Resources Inventory (see Policy ENV- 1.1) should include the
FederalEmergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) 100-year
floodplains, as well as planned natural flow ways identified by the Stormwater Management
Program (see Policy PUB —4.7), where predevelopment offsite runoff
from existing and future development will be directed. Collectively, the FIRM floodplains and
the planned flow ways may serve as open space amenities, such as linear parks and/or greenbelts
between urbanized areas.
Action ENV-1.7a: Develop priorities and financing strategies to improve accuracy
and comprehensiveness of flood mapping (DPW, 2-3).
Action ENV-1.7b: Budget and hire contractor to study feasibility of regional
stormwater management systems, such as flow ways (DPW, PD, 2-3).
Action ENV-1.7c: Identify corridors to be recommended for public open space
pursuant to Policy ENV-2.2 Open Space Network Program (PD, DPW, 3-5)
Policy ENV-1.9: Improvements Proposed Adjacent to Drainage Facilities. New construction,
improvements to repetitive loss structures, and substantial improvements proposed adjacent to
drainage facilities outside of the special flood hazard areas identified on the Flood Insurance
Rate Maps shall be subject to review and approval of the director of public works in compliance
with HCC 27-25.
Cultural Resources
Policy CR-1.1, "Cultural Resources Commission (CRC): "Cultural Resources Commission
(CRC). The Action Committee should work closely with the County of Hawaii Cultural
Resources Commission to implement the Kona CDP's goals, policies, and actions for Kona,
along with the General Plan..."
General Plan 2045 (July 2024 draft)
"Collaborative Biocultural Stewardship
Action Ln: Develop and establish Open Space Network Overlay for natural landscape features,
such as beaches and dunes, forests, streams, floodplains, wetlands, estuaries, or recharge areas
that have the inherent capacity to avoid, minimize, or mitigate the impacts of climate change.
Addressing Climate Change for Island -Wide Health
Policy 8.7: Prioritize the preservation and restoration of natural landscape features, such as
reefs, beaches and dunes, forests, rangelands, streams, floodplains, wetlands, and aquifer
recharge areas that have the inherent capacity to prevent, minimize, or mitigate the impacts of
climate change.
Public Utilities
Policy 28.d: Develop drainage master plans from a watershed perspective that considers non-
structural alternatives, minimizes channelization, protects wetlands that serve drainage functions,
coordinates the regulation of construction and agricultural operation, and encourages the
establishment of floodplains as public greenways.
Collaborative Biocultural Stewardship
Action Ld: Revise floodplain management requirements to require consideration of nature -
based solutions as alternatives for all projects that have the potential to affect floodplains or
wetlands. (DPW Project)
1.n Develop and establish Open Space Network Overlay for natural landscape features, such as
beaches and dunes, forests, streams, floodplains, wetlands, estuaries, or recharge areas that have
the inherent capacity to avoid, minimize, or mitigate the impacts of climate change. (Planning
Dept. Project)
Implementation, Public Utilities
Action 28.d: Develop drainage master plans from a watershed perspective that considers
nonstructural alternatives, minimizes channelization, protects wetlands that serve drainage
functions, coordinates the regulation of construction and agricultural operation, and encourages
the establishment of floodplains as public greenways. (DPW Project)
HIG hopes the county council will respect the recommendation of the Cultural Resources
Commission and the KCDP Action Committee. Please respect the constitutionally -protected
rights and resources of kanaka maoli.
For these reasons, as well as many more involving infrastructure, please vote against Bill 169,
Draft 2.
Mahalo for this opportunity to testify.