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HomeMy WebLinkAboutCOM 0176.073 2006-2008 Hawaii Developers Council c/o 44-420 Kaneohe Bay Drive Kaneohe, Hawaii 96744 - May 15, 2007 The Honorable Pete Hoffman, Chairperson Members of the Hawaii County Council Hawaii County Council 25 Aupuni Street Hilo, Hawaii 96720 Facsimile: (808) 961-8912 Subject: Bill 51, amendments to Chapter 27 Dear Chairperson Hoffman and Members of the Hawaii County Council, This letter is to provide The Hawaii Developers Council concerns regarding recent amendments to Bill 51 relating to Chapter 27 of the Hawaii County Code 1983 (2005 edition). The National Flood Insurance Program (NIFP) is requiring local governments bring local codes and regulations into conformance with recent changes to NIFP regulations by September, 2007 in order for homeowners and businesses in these local areas to remain eligible for funds in the event of a flood disaster. In response the Department of Public Works (DPW) proposed revisions to Chapter 27 in the original drafting of Bill 51. Subsequently, Bill 51 has undergone amendments that go beyond intent of Chapter 27 and complying with NIFP regulations. We strongly support amendments to Chapter 27 to bring the chapter into compliance with NIFP regulations. NIFP regulations provide a consistent and nationally recognized set of standards by which flooding hazards are evaluated. Provided that local codes and regulations comply with the NIFP regulations, homeowners, business owners and other have access to favorable flood insurance rates that would otherwise be unavailable. However, we oppose changing the intent and scope of Chapter 27 beyond compliance with NIFP regulations as it could jeopardize Hawaii County residents and businesses access to favorable flood insurance rates and eligible funds in the event of a flood disaster. May 15, 2007 Mr. Peter Hoffman Page 2 We recommend development or subdivision standards, without proven scientific basis, such as proposed by amendment to article 4, section 27-18 (c) (8) which may restrict construction (including grading, drainage, drainage basins, roadways, buildings, infrastructure and other improvements) to 20% of the total land area of any lot or proposed new subdivision in areas that have greater than 10% slope, be deleted from the amendment until proper analysis has been accomplished by licensed engineers. Bill 51 includes building standards above those required to meet NIFP regulations such as constructing homes and other buildings one foot above base flood elevations. We feel that the NIFP regulations have been generated based on significant research effort and vetted with considerable resources when compared to the effort and resources available to the our County. Changing or upgrading the NIFP regulations, unless warranted by a local condition as certified by engineers, will increase costs to homeowners (including affordable home buyers or renters) and businesses with no apparent reduction in flood insurance or other benefit. We encourage the County Council to expedite changes to Chapter 27 needed to comply with NIFP regulations. Other changes should be carefully considered with the proper time and resources, to vet all pertinent issues affected by the proposed changes. We respectfully submit our concerns to the Hawaii County Council for consideration when enacting legislation regarding the health and safety of the residents and businesses of the County of Hawaii. Please feel free to contact me (808) 284-4221 or 808.284.4221 @earthlink.net if you would like to discuss our concerns further. Aloha, _ Frederic Berg President