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HomeMy WebLinkAboutCOM 0370.009 2000-2002 DEC-19-2001 WED 08 07 AM CORPORATION COUNSEL FAX N0. 9618622 P, O1 r, ~`o: Chaigrnan .Tames Arakaki F°a~ 8912 Subject: 13111225, I,~ra~ 4 1aa~: December 19, 2001 Pages: 3, including this cover sheet. T°~ANSMTTTING: Letter to Galen Kuba dated 12/1$/01 regarding concerns raised by the County Cotzraeil on 13111225 amending Chapter 22, Streets and Sidewalks, ;~awaii Cotanty Code. COIViMENTS: laor Counci's information. C®NF„e~`J,a1T.,I1`~'• This docuttacnt is intended only for the personal and confidential use of the person aaazayed above and tnay be a privileged and confidential attorney-client cosa~ttsunication. If you are not the person agastacd above, NOTICB IS ~lfY GIVEN that you are strictly prohibited from readitag, reviewing, disseminating and/or copying this doeutr~at. Please cal] the office listed below iremediately if you have received dais docurYaeaat in error and please rettu~n it to the addaess listed below by U.S. Postal Service at our expense. Thank you, from the desk ot... ~e~a T~RtCA;9E ASSISTANT CORP043ATION COUNSEL COUNTY O4° FIAWAII 101 AUPUNI STREET' SUITE 325 HILO. HAWAII 96720 (808)96151 Fax: (808) 961-8622 x~ Ifi1e ~ Ai R,ef, 'To: Ref. Uate.,~,....__a_._.~ DEC-19-2001 WED 08:07 AM CORPORATION COUNSEL FAX NO, 9618622 P, 02 ~~.Ta'!`~' ~Ipil !n ~ l<.It1Cds~4 .5.~. ~&~l~a'A ?MaW~r g~ tQ` Curpe~ratir~n Cugnce! •~•a•.tinn~~ J:1 ay, ~ m;.p~ (uer~p4[l; lcsucc ~itF ~~~t~`~~ ~.sristunl C:nrporeeeirrn Cnunart ~Y Olh`l~'IC~ OF T~ C®~AT°~~}I®t C®'t7NS~;& lOl Aupuafi Street, Suite 325 • Heto, Hawaii 96720.362 ¦ (808) 961-8251 • FAX (808) 961-8622 I)ecernber 18, 2001 ~1en Kuba, Director Delsartment of Environanental 1Vlanagement County of ~€awai`i 25 ~upuni Strut 13i1o, ~ia'wai`i 96720 Dear C;alen: Re: CQrtcerais wised C cil on ' 1225 Azr;iendinsr Clraa9ter ~2. Streets and Sidewalks Pll try ~d answer the questions as discussed with you regarding the concerns raised by the Council on Bi11225 arraending Chapter 22, Streets grad Sidewalks, I~awai`i County Code. (1) Wla i; Co 'l r ve from the variance rocess in Secti 22-71? ha reviewing the other vaa7an~ provisions within the County Code, only the sign code requires th~¢ variances be granted by the County Co>tncil. F'or the most past, variaaaces are t~hraical in nataare .grad therefore it was felt ur~ecessary to raise this processing to the level of the County Couxacil. Building, stabdivision, - g, plumbing, and zoning vaxiaraces arc all done at deparCara.tal or board level and do snot require Council approval. (2} c 'on 2 - , c su a is t e D' for c e not to enforce the code. 8,.,~ ~ 2>: - recauestcd. We do not see the interpretation that is put forth by Council. The wording in;Section 22-8.2(a) states that "the director shall serv® the person with a notice of violation and osier pursuant to this section." Subsection (c) states that the "order gnay require the person to do any or all of the following," and lists Svc separate actions that may take place. That appears to only discretionary lara~aage and we feel it is appropriate for the director to be .given soYrae latitude in detea~naining vrlaat type of penalties will lee required in an order of notice of violation. (3) Bxolain w11y Septemiser 1 ~sras used aid n®t Junc 30 in Suction 22 Vi(i)? September 1 was the date drat was referenced in the zoning. code and there is no rationale as to DEC-19-2001 WED 08 07 AM CORPORATION COUNSEL FAX N0, 9618622 P, 03 Galen Kuba, Director Page -2- Dccernber 18, 2041 why Septelrnber 1 rather than Juno 30 was chosen. V6~e would actually reconarnend that ito data bo ixacluddd in order to allow the director to f lc with the Bureau at anytirnc, and not raise an issue as to whether a filing if not Heads on Septetnber 1 of the year is still a valid ~1ing. Therefore we recoa~nend deletion of the Septeanber t requirement entirely from this section, (4) 1 c do o e o e o~ d so a" i .The use of authorized personnel to issue a sumgraon or citation in a crianinal prosecution is made necessary by Section 803-691<iawai`i Revised Statutes which states that officers are authorized to issue citations in lieu of arrest. `hat authorization may be extended by the police chief to specially deputized personnel. (s) ~ . ~tiou ~2-8.5, which reXate~,s to egencv Hewers is ~o~' ertt - coa><s~. tional rights. This section authoa~es the director where a violation causes itaraent peril to public health and safety to, without a public hearing, order the responsible person to ixrediately cease the activities, pcrgoran all accessary work and other actions necessary to correct the violation. ~4, person's constitutional ~ghts are not absolute and she County--has a legatiareate interest in protecting flee health, safety and welfare of the r~zernbers oJ' the public, especially in emergency situations. Z`laese have -been recognized as corr~pellia~g state interests seed as such >inay infiatsge upon the constitutional rights ofothers. See L)®e v. Cary grad County, 8 ~aw.App. 571 (1991);1!?ar~darad v. ~'arag, 5 I~avv.l~pp. 453 (1985). T>1e general toile govea~aia~g delegation of authority to executives, o~r'acers and bodies with respect to the admia-zistratioa~ of statutes for the protection of public health, safety and welfare are generally recognized as constitutional. 16 C.J.S. Constitutional I.aw ~ 161. Tt is our opinion that Section 22-8.5 is constitutional for the protection of the health, safety, grad welfare of the public, and there eacists a coanpelling state interest and a rational basis for the emergency powers to be exercised by the director. Sincerely, It.AI.D TAKA.S~ Assistant Corporation Counsel C.rT: de r:/depdcrvilD4T g~lon council concereas bill 225/12-U1/G7de.wpd