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HomeMy WebLinkAboutCOM 0370.012 2000-2002 ~IL~ ~~s d`9N ORLiON~NCi~ ~ggB~~YHCaak°d5.~69tlN~ ~,0~~`~~Ap,1~,(~~~°~~~p~bq®~I~3~ TY-1~~sf/l~f'iW1'R'I 6d0~bJ/N 1 ~~a6B91AL~dT 7-a~~1~3 &9ifT8~N~f ~~iL~ 1 A-819ia 1 1 f6~~T6~ ~°0N® S~D~Wi`°5~~0.? ~Y CLYDE N:A(3A~T°A MANA~~~, NGi1N~f2NG D~IPAi~7"N6ENT HAWAvI' teOT~IC L(~HT C®IVIPANY ~~Rl1ARlf 21, 20®~ Chair Arakaki and Members of the Hawaii County Council: I am Clyde Nagata, manager of the engineering department at Hawaii electric Light Company ("H~LCO"), submitting testimony on behalf of HBLCO on Bill 225, Draft ~ "AN OI~I~iNANCE AMBNDING CHAPTER 22, O~ THB HAWAII COUNTIt' CO®~ 1983, RIeLATING TO STR~~TS AND SIDBWALKS." St1 R/91VI,ARI~ HBLCO supports this bill with the modification proposed by Verizon Hawaii, namely the deletion of the second sentence of subsection (h) in Section 22-4.4. C®nstruction permits; c®nditions, which requires the construction of new curb-cuts for persons with disabilities, accessible driveways or other improvements such that all repair, restoration or replacement work comply with the current requirements of the Americans with Disabilities Act r~ardless of existing conditions. I€~TB~N~L~ As proposed in Draft 5 of Bill 225, Section 22-4.4(h) would require a utility that has performed construction activities in a County street to restore the street to meet the current requirements of the Americans with Disabilities Act ("ADA") ~ even if the condition of the roadway at the commencement of construction did not meet ADA ~_M ~f. requirements. H~LCO supports the intent and purpose of ADA; however, we believe that 13111 225 as currently drafted will result in unmerited hardship on utilities that were not responsible for the design and construction of non-ADA compliant County roadways. The utilities would be required to bring those roadways up to ADA standards as proposed in Section 22-4.4(h) merely because the utilities perform construction work in a County street to maintain service to the community. for example, in order to meet County standards, a utility pole must be located one and a half to two feet from the curb. However, some of the older County sidewalks may be only five feet wide, which might not leave enough room for the utility pole whale still complying with ADA wheelchair access requirements. If a utility needed to dig up the sidewalk in order to repair a pole, Section 22-4.4(h) could require the entire line to be relocated in order to widen the sidewalk to meet ADA standards. Such a result would overwhelm any normal maintenance and repair project and would unfairly shift the burden of ADA compliance to the utilities in the design and construction of County roadways. H~LCO already pays a franchise fee to the County for the right to place its facilities in the public right of way and constructs its facilities in accordance with County requirements. The cost-shifting proposed by Sill 225, Draft 5, would unfairly place an additional burden on H~LCO's customers. C®NCLIJSI®N HIELC® respectfully requests that this bill be passed with the deletion of the second sentence of Section 22-4.4, subsection (h). Thank you for the opportunity to submit testimony on this matter. _ _ _