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<br /> Honorable Chair and Members of the Hawaii County Council <br /> My name is George Atta and I represent the owners of a 49-acre project site in Kona. I <br /> am here to state our position that we aze opposed to Bill 51 draft #C~and Ordinance <br /> Amending Chapter 27, Flood Control, Hawaii County Code 1983, as amended, relating to <br /> storm water management. We think the bill is fundamentally flawed and should not be <br /> approved. <br /> Section 27-3 Purpose: In this section the new purpose (O) to require re-channelization to <br /> meet or exceed the base 100-yeaz flood is not an achievable goal. Channels vary in size <br /> naturally and most will overflow during a hundred yeaz storm. To re-channel all <br /> channels is impossible as there is a hierazchy of channels in a drainage system. <br /> Under Section 27-12. Definitions (22) the entire island of Hawaii is listed as a floodplain <br /> or flood-prone azea. This is patently not true and excessive. To put this excessive reach <br /> in the meaning of the term "flood-prone" azea makes the definition meaningless. <br /> Section 27-16 (d) requiring map revisions within 6 months of the flood study information <br /> is not a practical thing. It places an unrealistic deadline for a County staff that is already <br /> stretched thin. These map revisions take time and usually the Federal agencies take more <br /> time. <br /> Under Section 27-18: Standards for construction ©Filling (6) which places a 10% slope <br /> threshold for restricting site development to within 20% of the site including pazking, <br /> roadways and other surface features is too restrictive. This section also requires the <br /> owner to retain on site storm-water from a 100-yeaz storm. We think both the slope/site <br /> restriction and the lot coverage restriction are excessive. <br /> 10 percent slope is the vast majority of the lands on the Big Island since the island is <br /> made up of the major shield volcanoes Mauna Loa, Mauna Kea, Kilauea, Hualalai and <br /> the Kohala Mountains. These areas generally have slopes over 10%. This threshold is <br /> excessive and there is no scientific basis provided for the threshold. <br /> The condition requiring onsite storage of flows from a 100-year storm is excessive. Even <br /> nature does not have a standazd that retains site requirements to keep a 100-yeaz storm on <br /> site. In a hundred yeaz storm, nature herself does not follow the rule for retention of <br /> runoff from a 100-year storm. When such a storm occurs nearly all channels will overtop <br /> their banks and almost no site will retain the water onsite. It is not physically possible. <br /> To impose a requirement on landowners that even nature does not meet is impractical. <br /> Section 12, Chapter 24, article 4; section 27-20(a)(4) says all building construction will <br /> be at least a foot above the base flood elevation. This is not possible since the <br /> foundations have to be on the ground and the BFE is usually several feet above ground. <br /> The only way this could be achieved would be if all construction occurs on fill that is <br /> raised above the BFE. This is both expensive and excessive. y <br /> Comm. No. <br /> Ref. Tdr <br /> Ref. Date, 1 2007 <br /> <br />