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REAL ESTATE INVESTNENi CA PETAL
July 9, 2007
Council Chair Peter Hoffman
Hawaii County Council
25 Aupuni Street
Hilo, HI 96720
RE: Bill 51 Draft 5 Amendments
Dear Chairman Hoffman:
I am writing to you as a landowner of several properties in North Kona regarding our
concerns to the amendments proposed in Bill 51. The Council is to be applauded for
your efforts in keeping Hawaii's ordinances current with Federal FEMA regulations.
However, the additions to the Bill that go beyond the FEMA regulatory update aze
unwarranted and should be addressed through other ordinance updates in coordination
with the public. We offer the following comments for your consideration:
1. The amendments to Chapter 27 should only address the necessary revisions in
order to be consistent and in compliance with current FEMA requirements. We
are adamantly opposed to applying additional restrictions for development within
Flood Zone X as proposed in Section 27-5(b). Zone X areas are specifically
excluded from special flood hazard requirements under FEMA regulations, and
are areas outside of the 100-year floodplain. New or additional restrictions on
construction and development within Zone X should be removed in their entirety
from Bill 51.
2. The definition of Special Flood Hazard Zones should be consistent with current
FEMA definitions, verbatim. The definition of Zone X (shaded) and Zone X
(unshaded) should be updated to be consistent with FEMA definitions. A copy of
the FEMA definition is included below for reference:
"Zones B, C, and X -Zones B, C, and X are the flood insurance rate
zones that correspond to areas outside the I percent annual chance
floodplain, areas of 1 percent anm~al chance sheet flow,Jlooding where
average depths are less than I foot, areas of 1 percent annual chance
stream flooding where the contributing drainage area is less than 1
square mile, or areas protected
from the I percent annual chance flood by
levees. No Base Flood Elevations or depths are shown within this zone.
Insurance purchase is not required in these zones. "
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3. We object to Section 27-3(i) and 27-4(1), which propose adding freeboard to base
flood elevations. Such a requirement has no technical basis, is subjective, and is
not warranted.
4. Section 27-4(j) should be omitted as the requiremem for mitigating the one-hour
25-year stone event is excessive and will cause unnecessary detention facilities to
be constructed.
5. We object to limitations on grading, construction, or development on slopes
greater than 10 percent. Bill 51 proposes to restrict grading, construction, and
development in areas greater than 10% to 20% of the lot area or land in the
subdivision. There is no technical merit for such a requirement, and is not a
requirement of FEMA regulations. As such, we request that the Council remove
Section 27-18(c)(6) in its entirety.
We greatly appreciate the Council's efforts in resolving the issues surrounding the
proposed amendments to Chapter 27 and look forward to working with you to finalize the
amendments.
Regards,
/s/
Brian G. Rupp, P.E.
The ShopoffGroup
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