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HomeMy WebLinkAboutCOM 0176.014 2006-2008 M[v os N4- ~i Harry Kim Bruce C. McClure Mayor Director •era~ ?~~'Oi'M'~' Jiro A. Sumada ~~~~f,~ II~~~tilltltGl DeputyDirecfor jj W .f DEPARTMENT OF PUBLIC WORKS _ Aupuni Center ) ~ 101 Pauahi Street, Sui[e 7 ~ Hilo, Hawaii 96720-4224 ~ ~ ~ - (808) 96L8321 ~ Fax (808) 961-8630 - Tv - www.co.hawaii.hi.us r.,~ March 22, 2007 ~at Honorable Brenda Ford Chair Committee on Public Works and Intergovernmental Relations and Members of the Hawaii County Council Hawaii County Council Ben Franklin Building 333 Kilauea Avenue 2"d Floor Hilo HI 96720 SUBJECT: Bill 51, Draft 2 Departmental Comments Please find below our comments on draft 2 of Bill 51. The purpose of Chapter 27 is to address flood hazard areas. These are comments to Bill 51, Draft 2. 1. Section 27-12. Page 5 the definition of "Flood Prone" is a FEMA definition... a. The definition in Bill 51 for Floodplain or flood-prone is defined by FEMA. Their definition of a "Floodplain or flood-prone area' means any land area susceptible to being inundated by water from any source (see definition of "flooding). DLNR is concerned about the definition's alteration. 2. Underscoring of "Within" is unnecessary because it exists in the current code. "Within" appears on: Item (b) (4), page 16; Item (c) (1), page 16; and Item (c) (3), page 16; 3. Section 27-12. Page 7 (11) directly by the Secretary of the Interior in states with add out to read without approved programs. 4. Item (6), page 17 we have the following comments: a. What are "natural protective buffers?" A definition is needed so staff can apply this to the plans they review. Comm. No. ~ 7 f0 . Ref. To: Ref. Uate~ R Q 2 007 CounTy of Hawaii is an Equal Opportunity Provider and Employer. Honorable Brenda Ford Chair Committee on Public Works and Intergovernmental Relations and Members of the Hawaii County Council March 22, 2007 Page 2 b. Civil engineers may have difficulty certifying that a development, particularly farms and residences, will not increase the likelihood of flooding or erosion in other areas. "Likelihood" needs to be clarified and explained. c. This section has no relationship to Chapter 27 or its purpose to regulate or restrict land use and subdivisions based on topography. This conflicts with Chapter 4 of the County Charter and Chapter 2, Article 7 of the Hawaii County Code that delegates this authority to the Planning Director. These provisions should be addressed in Chapter 23 and/or Chapter 25. 5. The intent of Item (d), on page 20, is to address only Flood Zone A in this section, which has no Base Flood Elevations (BFE) on the FIRMS (Flood Insurance Rate Maps). The first sentence should probably read and other developments in any location or flood zone any shall The requirement is necessary only for areas in Flood Zone A and has no applicability or value in any other location. 6. Item (d) (1), page 20, the purpose of this section is strictly informational. Public Works does not accept or process subdivision and development applications. This is done by our Planning Department. Many Federal and State permits, including 404 permits are not obtained until a developer is reasonably certain their construction plans meet County and State approval. For example, because NPDES permits are based on construction plans, a developer cannot get an NPDES permit at the time of application. They don't know the improvements the County will require of them and as a result, they will not have usable construction plans to submit their NPDES application. 7. Item (e) page 20, please justify with specific examples accompanied with an economic analysis, to answer, why it is necessary to use a 100-year design storm standard? The 10- yearstandard that we proposed meets EPA water quality requirements. Further, we have been using a 10-year storm as the minimum design for almost 24 years with more than reasonable results. It is also the minimum standard for the County of Maui, City & County of Honolulu and the State DOT Highway Department. Wehwill be present in Hilo for the April 3 meeting to answer any questions. Bruce C. McClure, P. E. Director BCM:vmht County of Hawa~ i is an Equal Opportunity Provider and Employer.