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HomeMy WebLinkAboutCOM 0348.000 2002-2004 M<r os y JAMI-S Y. ARAKAKI ~y"~"'v'.+, Vhonc: t80R) 961-827? I'hulnnmr X l'rrw<hn,¢ Ujhorr 4 7 y~~`' FAX: (ROR) 961-R91_ ~~'~4 ~-1~~r _ r~ :.....~y~ ?,es r! ' 03 SEP 19 APl ltl 19 COUNTY COUNCIL COUi . ~ <'uuntr n/~l-lu~r<d ~i 4'OUNI - ~k= f-~AN1iul llalrlli 1 'Dun/r Hufldur,¢ _ ~ h~puni .Slrael IIiL~, ll~mni ~f l6"%'n September 19, 2003 The Honorable J Curtis Tyler [Il Acting Chair Planning Committee, and Members of the Hawaii County Council County of Hawaii 25 Aupuni Street Hilo, Hawaii 96720 Dear Chair Tyler III and Members of the County Council: SUBJECT: Wai Ola "Waters of life" Public Charter School And Ala Loop Community Association 1 am referring two communications from the Law Firm of Tsukazaki Yeh & Moore relating to the above subject to pour committee Yo be agendized on your next committee meeting. Should you have any questions or concerns, please do not hesitate to contact me at (808)961-8272. nce / - Jam¢'~ Y. AraCk~aki, Chair H~vai'i County Council JYA/adr Comm. Ref. To: Ref. Date CFP,,,~.~ 1 Tsukazaki Yeh & Moore R. BEN TSUKAZAKI ATTORNEYS AT LAW rbt@lava.net A Limited Liability Law Company THOMAS L. H. YEH 85 W. Lanikaula Street Hilo, Hawaii 96720199 tty@lava.nel Telephone (808) 961-0055 FAX (808) 969-1531 MICHAEL w. MOORS mmoore@lava.net TRANSMITTAL LETTER September 16, 2003 ow n cn O ~rnn z, r-, TO: Lincoln Ashida, Corporation Counsel CD Councilman James Arakaki = ~ Judge Sandra Song r . 3 Brian Kajikawa, Dept. of Public Works, Building Division ~ ' _c = N FROM: THOMAS L.H. YEH R. BEN TSUKAZAKI Attorneys for Ala Loop Community Association RE: Wai Ola "Waters of Life" Public Charter School Copies Date Description 1 09/16/2003 September 16, 2003 letter by Thomas L.H. Yeh to Bruce McClure, Chief Engineer, Dept. of Public Works TRANSMITTED FOR: X Your information and files Your further necessary action Your signature and return Your payment Your signature and forwarding Per your request Your review and comment Per our conversation Your review and approval See REMARKS below PLEASE CALL (808) 961-0055 SHOULD YOU HAVE ANY QUESTIONS. REMARKS: TSUKAZAKI YEH & MOORS By Nancy Doug , Assists R. BEN IhAZAKI TSUkazakl Yeh BC Moore K REN TSUKAZ.AKI ATTORNEYS AT LAW rM lu~;i_nci A Limited Liabillly Law Company l'HOMAS I. H. YEH dy@la~~nci RS N'. Lanikaula Street Hilo. Hawaii 96720-4199 MICHAEL W MUORh Telephone: (R081 961-0055 PAX (ROR) 969-1531 mmoore@~Ia~~ nei September 16, 2003 Bruce McClure, Chief Engineer County of Hawaii Department of Public Works 101 Pauahi Street, Suite 7 Hilo, Hawaii 96720 Re: Wai Ola `Waters of Life' Public Charter School Tax Map Key No. (3) 1-7-8-03 Dear Mr. McClure: This fum represents the Ala Loop Community Association which has a number of concerns about the proposed operation of the Wai Ola Waters of Life Charter School (WOL) at the above-referenced parcel. The Association is comprised of most of the owners or residents of property which abuts Ala Loop, Kurtistown, Hawaii. Part of the Association's concern relates to the operation of the school at a site which does not have the required Special Permit or Use Permit to operate from the above referenced parcel, which is zoned as "agricultural" under the Hawaii County Zoning Code and classified as an agricultural district by the Land Use Commission. We believe that without such land use permits, which are required under the Code and by state law, no building permits can legally be issued. We understand that building permit application(s) have or may soon be submitted by WOL to your department for processing and approval. We wanted to apprise you of our position on the matter and to provide written notification of the special permit and/or use permit requirement that we believe applies in this case. We are requesting that your department or the Building Division provide notice to us of the receipt of any application and the issuance of any building permit(s), if any, for the site. Bruce McClure Page 2 September 16, 2003 Finally, regardless of your department's position on the special permit or use permit issue, we request your attention to apparent Building Code violations on this property. Based on information received from and the observations of the community residents, it is the Association's belief that WOL is currently using the site for ongoing school activities and that various structures on the site have been constructed without a building permit and are thus in violation of the Hawaii County Code. We request that you check into this matter as soon as possible and inform us whether you have found any violations. Should you have any questions about the above, please do not hesitate to let us know. Otherwise, we would appreciate being kept informed by your department of the permit status for the property. Very truly yours, TSUKAZAKI YEH & MOORE By I THOMAS L.H. YEH R. BEN TSUKAZAKI Attorneys for Ala Loop Community Association TLHY:nI cc: Ala Loop Community Association Lincoln Ashida, Corporation Counsel Councilman James Arakaki Judge Sandra Song Brian Kajikawa, Dept. of Public Works, Building Division Tsukazaki Yeh & Moore R. BEN TsuKAZARt ATI'ORNBYS AT LAW rbK9av~ net A Limited LiabfGty Law Company THOMAS L.H. Y8H OyLla~~ nci RS W'. Lanikaula Street Hlu, Hawau 96720199 MICHAF.I. W. MOORP. Telephone (80R) 961-0055 FAX IROR) 969-1531 mmcrore@lav~ net O W ~O ~ ~ .Tl C' ~ --o - 4~ r a , September 16, 2003 ~ James Y. Arakaki, Chairman County Council County of Hawaii 25 Aupuni Street Hilo, Hawaii 96720 Re: Waters of Life Charter SchooUAla Loop Community Association. Dear Chairman Arakaki: This firm represents the Ala Loop Community Association in regard to the proposed charter school that the Waters of Life ("WOL") is attempting to establish on Ala Loop. The Association has very serious concerns about the legality of the manner in which WOL has proceeded in this matter. Not only has the WOL ignored Ala Loop residents until after implementing their plans for the proposed school, but it is proceeding to do so without the proper approvals and permits. An overview of the legal deficiencies in this matter is provided in the attached letters dated August 14, 2003 and September 2, 2003 that we have sent to the Corporation Counsel on this matter. To this date, Mr. Ashida has not responded to our specific legal points. Among the most serious of the legal issues that have been identified thus far is the issue of whether or not the County has improperly waived its zoning power in regard to charter schools. Quite simply, there has been no statutory pre-emption of the County's power, and the County's own charter school guidelines provide that the Zoning Code is applicable to charter schools. Yet, WOL has been allowed to proceed in non-compliance with the Zoning Code, apparently with the approval of the Mayor and the Planning Director. Chairman Arakaki Page 2 September 16, 2003 At this time, WOL is also bringing students to the site for school activities and is occupying structures without building permits. Without WOL's compliance with applicable requirements of the Code and other law, the health and safety of the Ala Loop Community Association and members of the general public will be subjected to potential adverse impacts (such as traffic hazards on a substandard road and at the entrances to the Belt Highway, sewage disposal, water, etc.). In addition, as property owners, the Association's members have a right to protect their interests against illegal land uses that intrude within their neighborhood. The Association feels that it has been abandoned by the County in this matter and that the County has failed to provide an explanation for ignoring the law in this matter. The Association respectfully requests that the County Council: 1. Place this matter on its next meeting agenda to allow an investigation and public comment on this matter; 2. Request a legal opinion from the Corporation Counsel on the legal issues that we have previously raised; and 3. Take such action that is necessary to affirm the force, effect, and applicability of the County's home rule zoning power in regard to WOL's proposed charter school. In light of WOL's plans to open its charter school as soon as possible, the Association requests that the County Council take prompt and corrective action in this matter and avoid causing the Association and its members further hardship and expense in seeking enforcement of the law in this matter. Chairman Arakaki Page 3 September 16, 2003 Please contact us with any response that you may have in this matter, any notice of future County Council meeting that relates to this request, and any request for information that we may be able to provide for your consideration. Very truly yours, TSUKAZAKI YEH & MOORE By THOMAS L.H. YEH R. BEN TSUKAZAKI Attorneys for Ala Loop Community Association TLHY:nI Enclosures (2) xc: Mayor Harry Kim Christopher J. Yuen, Planning Director Lincoln Ashida, Corporation Counsel Judge Sandra Song Representative Eric Hamakawa Senator Russell Kokubun i i TsukaZakl Yeh & Moore R. REN TSUKAZAKI ATTDRNaYS AT LAW rbt~lava.nei A Limited Liability taw Company THOMAS L.H. YEH Ily®IagAel I 85 W. Laniluula Street Hilo, Hawaii %720<I99 MICHAEL W MOORE Telephone: (fl08) %1-0055 FAX (808)969-1531 mmoofe®lavanet August 14, 2003 Lincoln S. T . AsLria Corporation Counsel County of Hawaii 101 Aupuni Street, Suite 325 Hilo, Hawaii 96720 i I Re: Operation of Waters of Life Charter School; Special Permit Requirement Ala Loop, Puna, Hawaii Ala Loop Community Association Dear Mr. Ashida: Our firm has been asked by certain residents of property bordering Ala Loop to ' review the issue of whether the proposed operation of the Waters of Life Charter School upon land zoned for agriculture and accessed through Ala Loop in the absence of a state or county land use regulatory process is proper. The residents are in the process of forming a community association to be called the Ala Loop Community Association that will soon be representing the concerns of participating residents. As we understand, the County of Hawaii has previously interpreted certain statutes, particularly HRS Section 302A-1184, as exempting charter schools from applicable State land use district law to the effect that charter schools have been deemed exempt from obtaining special permits for the operation of charter schools on lands within the State agricultural district. Based upon our review of Section 302A-1184 and other applicable law, we find that: 1. There is no exemption from land use regulatory law that has been ~ established for the purpose of protecting the public health and safety, and 2. There is no express exemption from or preemption of county land use laws and regulations. 1 Enclosure (1) i I I Tsulcazaki Yeh & Moore ATTORNEYS AT IAW A IJmibd l.iabiliry 4w Cmipury We therefore believe that the County's interpretation is contrary to the plain language and intent of Section 302A-1184 and that the failure to require the Waters of Life school to undergo the scrutiny of a special permit or other land use approval process will severely compromise the health, safety and welfare of the residents of the Ala Loop ~ community, students and others who work at or visit the proposed school, and the public ' at large. For this reason, we ask that you review the current interpretation that the County has apparently adopted in light of the following information and to provide us with your position on the issue. Background Facts Based upon infomuttion received from the residents of the Ala Loop community and other sources, we understand that the Waters of Life charter school (WOL) has acquired a 28 acre parcel of land formerly known as Sunshine Farms, designated as TMK (3)1-7-8-03 for the purpose of operating a charter school on the property. I! WOL has stated that it will have as many as 160 to 300 students enrolled at the school and that teachers, administrative staff, vendors, and parents of students will travel daily to the school. Ala Loop is a narrow, approximately fourtcen foot-wide paved road with shoulders as narrow as 2 feet in width in certain locations, providing access to and from the Belt highway at both ends of the loop. On Ala Loop, not only is the pavement width inadequate for two-way traffic, especially involving school buses, but there are sight distance and curvature problems. Ala Loop is aCounty-maintained road. I No traffic signals exist at the Belt highway intersections with Ala Loop. With the recent opening of Kamehameha School's Keaau campus, and commuter traffic, there are ah~eady severe trafFic hazards for those entering or exiting either end of Ala Loop during i morning and afternoon commuter hours. That the substandard condition of Ala Loop is inadequate to accommodate two- ~I way traffic has already been officially recognized by the County. In 1995, the County Planning Commission denied a special permit application for a proposed church on Ala Loop citing the safety hazard presented by the substandard road condition of Ala Loop as the primary ground of denial. A copy of this decision is attached for your review. The WOL site is classified as Agriculture by the Land Use Commission of the ~ State of Hawaii and as A-20a under the Zoning Code of the County of Hawaii. 2 i Tsukazaki Yeh & Moore erroiwevs erww A Limiwd liabitlry law Campu,y ~I Applicable Law HRS Section 302A-1184 provides in pertinent part as follows: "New century charter schools; exemptions. Schools designated as new century charter schools shall be exempt from all applicable state laws, except those regarding: (3) Collective bargaining under chapter 89; provided that:...; (4) Discriminatory practices under section 378-2; and (5) Health and safety requirements. New century charter schools shall be exempt from the state procurement code, chapter 103D, but shall develop internal policies and procedures for the procurement of goods, services, and construction, consistent with the goals of public accountability and public procurement practices. However, where possible, the new century charter school is encouraged to use the provisions of chapter 103D; provided that the use of one or more provisions of chapter 103D shall not constitute a waiver of the exemption of chapter 103D and shall not subject the new century charter school to any other provision of chapter 103D. New century charter schools shall account for ~ funds expended for the procurement of goods and services, and this accounting shall be available to the public. In addition, notwithstanding any law to the contrary, as public schools and entities of the State, new century public charter schools shall not bring suit against any other entity or agency of the State of Hawaii." The pertinent provisions of Section 302A-1184 were adopted in 1999 when the Legtslature adopted the concept of new century charter schools. A review of the legislative history for Section 302A-1184 reveals that when the exemption language of the statute was being reviewed, the Legislature did not intend that the exemption statute should be used to circumvent applicable zoning laws. Thus, in Act 62, 1999 SLH, the Legislature's purpose in enacting the charter school legislation was to free such schools from statutory requirements and bureaucratic red tape that inhibited a school's ability to make decisions relating to the provision of educational services and to increase flexibility and autonomy of such schools from the department of education. (See Section 1 of Act 62, Appendix A). 3 i Tsukazaki Yeh & Moore ATTORNCYS ATLAW 'i A Limited IJabtlity liw cAmpeey Similazly, in Standing Committee Report No. 1404, the House Committees on Education and Labor and Public Employment also expressed the intent that such schools should be free of bureaucratic red tape, and be able to accommodate the individual needs j of students and be exempt from state procurement laws. (See HSCR 1404, 1999 SLH, Appendix B) Section 302A-I 184 also reflects this intent and specifically addresses exemptions from the state procurement codes, but nowhere in the statute or the legislative history is there any indication that the purpose and intent of the statute was to relieve charter schools from having to comply with state and county land use and zoning restrictions. To the contrary, a specific exception to the exemption from "applicable state laws" are those state laws regarding "health and safety requirements". ~ A Special Permit is Required for the Proposed Charter School Because Special Permit Requirements Specifically Involve A Review of Health and Safety Issues Before An Otherwise Impermissible Use Can Be Established on Land Within i the State Agricultural District ~I The list of permissible uses within the agricultural districts, as set forth in HRS I Section 205-2 or 205-4.5, does not include schools. Beyond the list of permissible uses, HRS Section 205-6(a) provides that the county planning commission may approve of "certain unusual and reasonable uses" within agricultural districts other than those for which the district is classified. HRS Section 205-6(d) and (e) provides that where a special permit is sought for land .the area of which is greater than 15 acres, such a permit shall also be subject to approval by the Land Use Commission. The Land Use Commission (LUC) of the State of Hawaii has promulgated, pursuant to HRS Section 207-7, rules on the review of special permit applications. ~ Section 15-15-96 (a) of the LUC Rules require any person desiring to use land within an agricultural district for other than a pemrissible agricultural use may petition the county planning commission for a special permit to use the land in the manner desired. Although the County Planning Commission must hear and make a decision of the petition, the approval of the Land Use Commission is required in addition to that of the County Planning Commission when the area involved is greater than 15 acres. The requirement that a special permit should not be granted unless it constitutes an "unusual and reasonable use" connotes health and safety concerns that need to be addressed before the issuance of the special permit. The LUC rules require that certain guidelines be considered in determining whether a use is unusual and reasonable, I, 4 - - - I 'I§ukazaki Yeh & Moore Artolwers Aruw A limited IJabilitY 4w Cmnpany ' including whether the use would (1) adversely affect surrounding property, or (2) j unreasonably burden public agencies to provide roads and streets, sewers, water drainage and school improvements, and police and fire protection. LUC Rules 15-15-95(b). Sge N.gghborhood Boa*d v State T snd se Co mi ion, 64 Haw. 265, 270 (1982). These ~ guidelines directly relate to health and safety issues for both surrounding residents and the public health and safety: sewers, roads, water and fire and police protection. li The WOL is required to apply for and receive a special permit from both the Planning Commission of the County of Hawaii, as well as the LUC, pursuant to HRS Section 205-6 and Section 15-15-95 of the LUC Rules, as the requirements for such a permit directly relate to health and safety. There is perhaps no other statutory permit review process required or available which would take such a comprehensive and detailed look at the health and safety issues as the special permit process mandated by HRS Section 206-6 and LUC Rules. ~ The County of Hawaii's determination that a charter school need not obtain a special permit fot the operation of such a school on lands within the agricultural district, it is not only erroneous, but to the extent that the operation of such a school would exist on a parcel of land greater than 15 acres, such a conclusion would improperly result in an ad hoc divestment of the Land Use Commission's jurisdiction over such permits. To the extent that the County has informed organizers/operators of proposed charter schools that a special permit is required on agricultural district lands without consideration of the necessity of the LUC's involvement, the County should correct this position immediately and inform the proposed organizers/operators accordingly. ~ Applicable County Laws Prohibit the Operation of a Charter School Without a Special Permit It is a basic tenet of land use law that the zoning power is derived from and is a form of exercise of the police power, a power that must be exercised in the interest of public health and safety. (Lum Yip Kee. Ltd. v. Citv and Countv , 70 Haw.179 (1989)); see also 83 Am Jur 2d, Zoning and Planning, 4, 13-15. The power to zone constitutes the exorcise of the county's police power and must be reasonably related to public health, safety, morals or general welfare. As the enabling law of county zoning, HRS Section 46-4 delegates the zoning power to the counties within the framework of the general plan. The zoning power within each county is recognized by HRS Section 46-4 as the tool used to best put the general plan into effect in an orderly manner. Through the zoning power, the counties 5 I i I I 'Ikukazaki Yeh & Moore ATTORNEYS ATIwW ' A limned l.iebiliry [aw Comgny may regulate the areas where trade or business maybe conducted, particular uses maybe subject to special restrictions, the location of roads, schools, and other regulations necessary and proper to permit orderly development consistent with the deference given i to the constitutionally-rooted police power, HRS Section 46-4 provides that the zoning power granted therein "shall be liberally construed in favor of the county exercising ~ them..." i As set forth above, HRS Section 302A-1184 is clearly devoid of any charter school exemption from applicable county laws. Thus, applicable county zoning law is effective as to the location and establishment of charter schools. Under the County of Hawaii's Zoning Code, the proposed use by WOL is prohibited in the absence of a special permit. Section 25-4-3, provides that for each zoning district, the permitted uses listed in the regulations for such district may be established within that district after compliance with specific restrictions of the district. Any use not listed among the permitted uses is a prohibited use within that district. Section 25-4-4, Hawaii County Code. ~ Section 25-5-72(d) of the Code lists the uses permitted in the agricultural zoned district. Schools are not listed as a permitted use in the agricultural district, and are thus, prohibited under Section 25-4-4. WOL must establish its school in an appropriate zoning ~ district unless it obtains either of the discretionary permits described below. It should be noted that Section 25-5-72 provides that a school maybe permitted in the agricultural district if a special permit is issued for such use. It should also be noted that, in regard to applications for special permits, the ~ County of Hawaii Planning Commission has also adopted rules that contain health and safety criteria for the issuance of a special permit that are similar to the LUC's rules. They require a determination of the potential adverse affects upon surrounding property owners and the issue of whether the proposed use will unreasonably burden agencies to provide sewers, roads and streets, drainage and police and fire protection. Rule 6.3 of the Planning Commission Rules. The Zoning Code's use permit provisions also focus on potential health and safety impacts to public agencies and surrounding community and apply in cases such as this where a special permit has not been obtained for a proposed use in the agricultural district which use is otherwise impermissible. Section 25-2-61(a) provides that a school maybe permitted within the agricultural district only if a use permit is obtained from the Planning Commission. I 6 III', Tsukazaki Yeh & Moore errowrerseruw ~ ~u~~eww~gi..c~y Section 25-2-61(c) provides that a use permit shall not be required if a special permit has been obtained for such use. In the present case, a special permit has not been obtained for the establishment of WOL's charter school. Accordingly, a use permit is clearly required under Section 25-2-61 prior to the permissibility of WOL's charter school. Zoning Code provisions relating to the plan approval process also appear i applicable to the WOL's proposed use. Section 25-2-71(f) provides that plan approval may also be required by the conditions of a use or special permit or other land use approvals. In the plan approval process, the Planning Director is required to review the proposed development in relation to surrounding property, streets, traffic, and community characteristics and may deny or condition plan approval if the proposed development will create unreasonable health and safety risks. In regazd to the plan approval requirement, we note that on October 30, 2001, the County of Hawaii sent to the DOE a summary of the rules and regulations that charter schools are required to follow and en•oneously provided that charter schools did not have to obtain plan approval in the agricultural district. We believe this conclusion is incorrect because of its absolute terms and needs to be corrected immediately to state that plan approval may be required under certain circumstances. Conclusion A special permit required under both the laws of the State and the County of Hawaii is directly related to health and safety. Morever, WOL is not exempt from i compliance with the zoning laws of the County of Hawaii. A charter school is not a permissible use in the agricultural district in the absence of a special permit. The special permit, in this instance, must be approved by the Planning Commission and the LUC. ]n the absence of a special permit, a use permit is required by the County's Zoning Code prior to establishment of a school in the agricultural district. Whether via a condition of a special permit or a use permit, plan approval should also be obtained, along with such permits that are necessary in order to comply with applicable health and safety requirements that are administered by appropriate agencies. A refusal by the County of Hawaii to exercise lawful jurisdiction in this matter will expose Ala Loop residents and others to an unreasonable risk of harm, including but not limited to, safety hazazds inherent in substandard conditions of Ala Loop road, as already recognized by the County of Hawaii. ~i I 7 I i Tsukazaki Yeh & Moore ATTORNEYS ATLAW ' A Limi1CA li~bllity Law Canpny Request for Revlew We respectfully ask that your office review the above with the Mayor and the Planning Department and reconsider the position previously taken by the County. Immediate action should also be taken in informing those concerned with the administration of charter schools and WOL's charter school that the County's prior interpretation of Section 302A-1184 was erroneous or incomplete. Please let me know by August 22, 2003, if the County will be reassessing its position or if it will be necessary for the Ala Loop residents to seek relief from the appropriate agency or court in enforcing the obligations of the County and WOL to comply with the law. Very truly yours, TSUKAZAKI YEH & MOORE, A Limited Liability Law Company I THOMAS L. H R. BEN TS Attorneys for Ala Loop Community ssociation RBT:nI xc: Ala Loop Community Association Christopher J. Yuen, Planning Director James Y. Ar~akaki, Chairman, Hawaii County Council Representative Eric Hamakawa I Senator Russell Kokubun Anthony J.H. Ching, Executive Officer, Land Use Commission Diane Erickson, Esq. i, 8 I I ` I _ ------T_ Stephen K Yima"htro Mayor ~~ii77'~ ~,•w M + ~cLIIIIII~~I' II~ ~2I~Utiti ~ PLANNING COMMISSION 25 Aupunl Sneu, Roos 109 • lalq Hnnii %7r0~1252 'i, tenet %t.ezes ~ ttwe~ 9st.~ts CERTIFIED MAIL i 2 416 228 819 I July 27, 1995 Greg Lee, Trustee Mountain View Congregation of Jehovah's Witnesses 260 Kaiuhtni Street Hilo, HI 96720 Dear Mr. Lee: Special Permit Application No. 95-3 ~ Applicant: Mountain View Congregation of Jehovah's Witnesses Request: Establishment of a Church Meeting Facility Tax Mao Key: 1-7-8:25 ~ The Planning Commission at duly advertised public hearings on June 7, 1995 and July 13, 1995, considered the above-refetentxd request for a Special Permit in accordance with Chapter 205-6, Hawaii Revised Statutes, sad Rule 6 of the Planning Commission, to allow the estabhshment of a church meeting facility oa approximately 1.145 acres of land situated within the Staze Land Use Agricultural District approxtmately 1,250 feet west (Keaau) side of the Volcano Road-Ala Loop intersection, Olaa Reservation Lots, Puna, Hawaii. The Commission voted to deny Special Permit No. 905 based on the following findings: In considering a Special Permit for any proposed use, Rule 6 of the Planning i Commission relating to Special Pen~its requires that such action conform to the following guidelines: a. Such use shall not be contrary to the objectives sought to be accomplished by the Land Use Law and Regulations; b. The desired use shall not adversely affect surrounding properties; c. Such use shall not unreasonably burden public agencies to provide roads and j strcets, sewers, water, drainage, school improvements, and-police and fire protection; i d. Umtsual conditions, trends and needs have arisen since the district boundaries and regulations were established; sreg Lee, Trustee Mountain View Congregation of Jehovah's Witnesses Page 2 e. The land upon which the proposed use is sought is unsuited for the uses permitted within the district; f. The proposed use will not substantially alter or change the essential character of the land and the present use; g. The request will not be contrary to the General Plan and official Community Development Plan and other documents such as Design Plans; In addition to the guidelines detailed above, the Planning Commission must also find that the proposed use: a. Is an unusual and reasonable use of land situated within the Agricultural or ~ Rural District, whichever the case may be; and b. ; Would promote the effectiveness and gbjectives of Chapter 205, Hawaii Revised Statutes, as amended. While a proposed use must meet all of these criteria for approval by the Planning Commission, a denial may be made upon a finding of conflict with any one of these criteria. ~ The proposed use will not promote the effectiveness and objectives of Chapter 205, i H.R.S., as amended. Chapter 205, H.R.S., otherwise known as the State Land Use Law, provides the basic legal framework of land uses in the State of Hawaii and assisted in the implernetttadon of the long-range land use objectives of the State and Counties. The intent of these statutory provisions is to preserve, protect and encourage the development of lands in the State for those uses to which they are best suited is the interest of the public health and welfare of the people in Hawaii. In the case of the Agricultural District, the intern is to preserve or keep lands of high agricultural potential is agricultural use. At the County level, these broader statewide objectives are articulated through the County General Plan. In that respect, land use and its consistency wiffi the goals, objectives and policies of the General Plan will also promote the effectiveness and objectives of Chapter 205, H.R.S. The granting of this particulaz request at this particular location would be inconsistent with the objectives to be sought to be accomplished by the Land Use Law and Regulations as well as the County General Plan. A goal of the General Plan states that the County shall ~ "Designate and allocate land uses in appropriate proportions and mix and in keeping with the social, cultural, and physical environments" while maintaining a policy to ..encourage the development and maintenance of cotnmunides meeting the needs of its residents in balance wtth the physical and social environment." I The applicants propose to establish a church meeting facility within an area serviced I~ by a winding, substandard roadway. This portion of Olaa Reservation Lots is serviced by Ala Loop Road, aCounty-maintained roadway having a pavement width of only 12 feet within a 50-foot wide right-of--way. The increase in traffic along this substandard roadway generated by the proposed church use would adversely affect surrounding property owners - _ I~ i .ireg Lee, Trustee Mouwain View Congregation of Jehovah's Witnesses Page 3 by attracting traffic along a roadway in which the existing pavemem width is not sufficient to accommodate two-way traffic. The Commission would be remissed in its duties were it to approve such a use which would attract traffic along such inadequate, and possibly hazardous, roadways. The narrow and winding nature of Ala hoop Road and the frequent nightly meetings to be held at the church only add to the concerns regarding the adequacy of Ala TROP Road• The State Department of Transportation has indicated that access to the ~ subject property directly from the Volcano Highway will not be permitted. This access restriction rs further enforced by a 10-foot wide planting screen easement located along the property's entire Volcano highway frontage. Therefore, approval of the Special Permit application would not be in balance with the physical environment of this portion of Puna. The desired use will unreasonably burden public agencies to provide roadway and safety protection improvements. As in previous applications for similar types of uses, applicants were required to provide necessary roadway improvements to ensure a mitrimum pavements width which would accommodate two-way traffic. As discussed above, the existing condition of Aht Loop Road cannot support tote proposed church use. To require the applicant to widen Ala Loop Road over its 4,000-foot-plus length would be financially prohibitive and unreasonable. Approval of the proposed use, and the potential for similar uses along these types of substandard roadways, would create hazardous conditions which the County must recognize and resolve, thereby burdening governmental agencies to address such problems in a reactive, and not pro-active, manner: The Puna District has many miles of substandard roadways which are usable to accommodate the existing traffic levels upon ' them. It would not be in the best interest of the County to support an intensification of land use in areas unable to cope with such uses. This denial recommendation is also based on the potential cumulative impact of similar requests along this substandard roadway should this Special Permit be approved. The proliferation of non-residential/agricultural uses along the substandard Ala Loop Road would eliminate planning options available to the County to ensure the safety and well-being of its residents and the general public. The Commission has bcen consistent is its efforts to ensure that uses approved through the issuance of a Special Permit are provided with basic facilities and services to accommodate the approved use. Should this policy direction be abandoned with the approval of this request, smmlar requests along Ala Loop Road or other substandard roadways must be favorably considered, irtegardless of the cumulative impacts a concentration of such traffic-generating developments may have on substandard roadways. Such action cotild adversely affect lands county-wide and frustrate the County's efforts to manage such urban-types of growth to ensure adoquate public facilities and services for all. With the discussion above, approval of the request would be in direct conflict with a goal of the Land Use Element of the General Plan to "Designate and allocate land uses in appropriate proportions and mix and in keeping with the social, cultural, and physical environments of the County" while maintaining a policy to "....encourage the development and maintenance of communities meeting the needs of its residents in balance with the physical and social environmem." Based on the above considerations, it is determined that the establishment of a church meeting hall at this particular location would not promote the effectiveness and objectives of the State Land Use Law. It is, therefore, decided that this Special Permit application be denied. II .ireg Lee, Trustee lil i Mountain View Congregation of Jehovah's Witnesses Page 4 I As stated in Rule 6-9, "The Planning Commission's decision is appealable to the Third Circuit Court. " Should you have any questions on this matter, please feel free to contact Alice Kawaha of the Planning Department at 961-8288. Sincerely, Wilton K. Wong, chairman Planning Commission ~ AK:syw I I.Mount02.PC , ec: Honorable Stephen K. Yamashiro, Mayor ~ i Planning Director ~ State Land Use Commission Departtent of Public Works Department of Water Supply Corporation Counsel j ' Plan Approval Section Mr. Ricky Kamimura/Mr. Nathan Wong I II I I - Tsukazaki Yeh & Moore R. BEN TSUKAZAKI ATTORNEYS AT LAW rbt®Iava.net A Limited Liability law Company THOMAS L.H. YEH dy®lava.na I 85 W. Lanikaula Street Hilo, Hawaii 967204199 MICHAEL W. MOORE TW<phone: (808) 961-0055 FAX (808) 969-1531 mmoo¢®Iava.nu September 2, 2003 Lincoln S. T. Ashida Corporation Counsel County of Hawaii 101 Aupuni Street, Suite 325 Hilo, Hawaii 96720 Re: Operation of Waters of Life Charter School Ala Loop Community Association Deaz Mr. Ashida: In response to your letter dated August 21, 2003, in which you stated you were ii unclear as to the source of the information regarding the County's previous determination as to HRS Section 302A-1184, as it relates to exempting charter schools from State land use district laws. I As to the sources of information referred to in my August 14, 20031etter to you, I have enclosed a copy of the County's managing director's letter dated October 30, 2001 to Chuck Higgins, Public Charter School Specialist III, with a compilation of rules and regulations for charter schools. In addition, I have enclosed a ropy of the Planning Director's July 21, 2003 letter to my client, which states that charter schools located in the State Land Use Agricultural District do not have to obtain special permits. As to the former, please note that pazagraph " 3" on page one states: I' "Charter schools are not exempt from the County Zoning Code." ~i This comports with the legal azgument tendered in my August 14, 2003 letter to you. I I ll i Enclosure (2) I III Lincoln Ashida Page 2 September 2, 2003 Please let me know if I can provide you with additional information. I remain available to discuss any questions or concerns you may have regazding this matter and look forward to hearing from you. Very truly yours, TSUKAZAKI YEH & MOORE, A Limited Liability Law Company ~ r I THOMAS L. H R. BEN TSUKAZ i Attorneys for Ala Loop Community Association RBT:nI li Enclosures xc: Ala Loop Community Association James Y. Arakaki, Chairman, Hawaii County Council Representative Eric Hamakawa Senator Russell Kokubun I it I~ I i , ~tlaC91 Harry Kim ~,yer . ~ Dixie Kaetsu 1, fj idweinBDir•aar • Peter T. Young ~wb M+~•d~s Quota ~outttp of ~a~boai`i 25 Aupuni 84eet. Aaom 213 • Nib, HaxMi 9671p.1131 • (M8) %1.8211 • P~x(80i) %14353 KONA: 754786 xmidoi HiBhary, a.w 103 • a.iltu-Kao•, Hsw•i'i %740 (808)329-0228 • Frz(tOh716,S669 Iii October 3Q 2001 I Chuck Biggins li Public Charter School Speaalist III DOE/PAO P. O. Box 2360 Honolulu, Hawaii 96804 Dear Mr. I~Ilggins: II Attached is a compilation of county and state colas and regulations that charter schools are required to follow. Please duplicate sad distribute to charter schools located in We County of Hawaii. If you have any questions, please call me. Sincerely, I C'~ Dixie Kaetau I Managing Director II I I II - CHARTER SCHOOLS AND LAND USE REGULATIONS The following provides a summary of state and wunry land use regulations with respect to Charter Schools purauent to §302A-1184 HRS, §205-6 HRS and Hawaii County Code Chapter 25 (Zoning Code). 1. Baclrgronnd: Chapter 302A of Hawaii Revised Statutes sets forth a statutory scheme for the establishment and operation of charts schools. The purpose of the Act is to inaresae the IIextbiliry and autonomy at the school level by allowing existing public schools and now schools to be designated as new charter schools. 2. Appltcablllty o[ State Lawa: Charts schools are exempt firm state laws, • except those relating tb haalt6 and safety and a ' few other exceptions (Le. building, fire, and eatdtation codes). The major effect of this exemption is that Charter Schoob located in State Lead IIse Agrlcaltaral DhtMcte do not have to obtain a Special Permit. 3. Connty ZoNng Code: Charter schools are not exempt 6rnn the County Zoning Code. 4. Charter Schools ABowod In These Plan Approval is an administrative review of Zone DlsMcts with Plan Approval: techtdcal details like packing, access, and trafLc circulation, and is naatsily die 9u+~Y by ~ Phuming Departrneat without any public review, • CN (neighborhood commeroiat) • CV (village commercial) Cci (general eommercia!) • CDH (Downtown Hilo) • MCX (mixed industrial-commercial) ' • RCX (residential-commercial) 5. Charter Schools Allowed to These Uw Permits are granted by the Planning Zone Districts with a Use Permit: Commission and requiro submission of an ~ . , application and publio hearing. • RS (single-fium7y residential) • RD (double-family residential) • RM (multi-family residwtial) • RA (residential-agricultural) Planning Departrnent, County of Hawaii t)ctober 22, 2001 I _ ~i i 6. Charter Schools ue Nat Permitted In Chatter schools are not allowed in the following These Zone Districts: districts: • V (visitor) • ML (limited industrial) . • Mt3 (general industrial) • O 7. State band Use Conservatlon DIsMMs: The Plattning Department shall defer to the Depattmrnt of Land and Natural Resources (DLNR) as to whether a conservation district use permit is naxseary to operate a charter school in a Consetvati~ District. 8. Special Management Area (SMA): Charter acbools located in a delineated SMA, are (applicable to delineated shoreline subject to SMA regtdrammta in all zoning locatlona) ditAticte. A ohMer school in the SMA will need a Major SMA Permit if the improvemmta will cost more than S125,000. Major SMA Permits ate granted by the PlatmiriY Cotamissiaa. If the it»provementa are lass thaa 5125,000, the ~ charter school will aced a Minor 3MA Permit, which is gta~ed by the Plamung Director. I I I i i Planaing Deparrmeat, County of Hawaii October 22, 2001 ~ - I - _ - i PLANNING DEPARTMENT 3UMMARY OF PERMIT REQUIREMENTS FOR CHARTER SCHOOLS ' This bbb ony pats permib adminkterod by the Covey Plenning Department Charter schools have s4nltar pertnlt requiremenb t0 oUrer ectroob, except h the Agricultural District I rivab it Zonln Dbtrld Sehoola RS ' RD RM RA RCX ~ CN B CO CV ! ; CDH ML MO V LU Com BWR ~ FA M SLU C FA or rtran A PertrYtted, ra permhs s PemYlbd, plan approval C Regrdra wa pamr3 or apecbl permit X Not pemYttsd B' SubJed to dtredore Nbrprebtlon BWR Defer b dacblar by the Boats d t.arxf and Natural Raeowcea When boated in are SMA SMA roqu4amarde apps to charter ea,ow even m ab stb land Use ApAwltural Dbtrict The PbnMrq DaparUnant can adobe on the axreM zonhq of erry alts and whether tt b 4f are Sh1A. I I i _ wugrrst, 2001 COUN'T'Y OF HAWAII DEPARTMENT OF PUBLIC WORKS BUILDING DIVISION I GUIDELINES FOR RTER SCHOOLS L Buildine Permits Igquired Permits Proposed Construction Buildine Plumbin¢ Electrtcal , Use ofexisting school facility, no change Only for Only for Only for in capacity new work new work new work Conversion of an existing building into a Yes Only for Only for i chatter school new work new work Completely new facilities or additions Yes Yes Yes Concrete slab only for driveway or parking No No No it IL Submittal ReauiremenU for Permits _ Throe (3) sets of plans drawn to scale showing site plan, elevations, sections and details _ Building plans must be stamped by a Hawaii licensed architect or structural engineer _ Site plan drawn to scale showing building layout on property, parking, driveways, landscaping, retaining walls and adbacks from propeRy line _ Separate plan sheets for electrical work and mechanical work (air conditioning/heating, plumbing, septic or sewn system, range hoods, etc.). For new facilities these plans are genaally stamped by an electrical engineer and mechanical engineer, respectively. , _ Grading plan if extensive (more than 100 cubic yards) excavation or fill is involved _ When required a separate plan for fue alarm and fve sprinkler system with stamp ~ _ ADA (Americans w/Disabilities Act) compliance certification form _ When required the special inspection form -When installing septic systems a Dept.of Health approval letter to construct the individual wastewater system (1WS) I L_n Building Desien Repuirements _ Building design is required to follow the following sections of the1991 Uniform Building Code: Chapter 5 -Occupancy Requirements Chapter 8 -Requirements for Group E (Educational) Occupancies - ~ Ham&m Christopher J. Yuen ~ I, ? Ulr•nsr I Roy R. Takemao ~r oyuer a..~a. KLDlitt~~7 A~ fU21tt PLANNIIVG DEPARTMENT I01 Pwahi Street. Suite 3 • Hilo, Hawaii 96720.3043 (808) 961-8288 • Pax (SOB)961-8742 July 21, 2003 Ala Loop Homeowners P.O. Boxes Hilo, HI 96720 'i Dear Representative of Ala Loop Homeowners: SUBJECT: Ingahy Regarttiag Charter School on Ala Loop TNII{: 1-7-008:003 Olaa Reservation Lots. Pena. Aawaii We have received your letter dated July 11, 2003 regarding the Waters of Life Charter it School in escrow to purchase the old Sunshine Farm property on Ala Loop. The Planning Department has received numerous inquiries regarding the operation of charter schools within the State Land Use Agricultural District in regards to H.RS. §302A-1184, which exempts charter schools from state laws, except those relating to health and safety, and a few other exceptions. Based on this law and a legal opinion received from the County Corporation Cotmsel, we are exempting charter schools from state laud use laws not expressly related to health and safety. The major effect of this exemption is that charter schools located in the State Land Use I~ Agricultural District do not have to obtain special permits. Normally, a school in the agricultural district would Heal a special pemrit with a process that requires notice to nearby landowners and a public hearing. Charter school facilities may need other approvals and petrnita, including those related to building, fire, and sanitation. The law exempting the charter schools is open to interpretation and the courts have the final say. You, as homeowners concemal about the traffic impacts this operation may ail have on your community, have the right to take this matter to court to have a judge decide i if this charter school Heals a special permit. i i U O II Ala Loop Homeowners Page 2 July 21, 2003 If you have any questions, please feel free to contact Jeff Darrow at 961-8288. Sincerery, 2ti CHRISTOPHER J, Planning Director ]WD:pak v~»vwin6Vyetriena+u.V+taw~ClunuSthoo~.aoc cc: Mayor Harry Kim Ms. Dixie ICaetau, Managing Director Mr. Andy Levin, Executive Assistant Mr. James Arakald, County Councilman Mr. Lirre;oln Astride, Corporation Counsel Planning Commission Section i I !I i I i