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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.