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Home My WebLink AboutCOM 0176.150 2006-2008 oT/28/2007 15:21 FAK •9085863923 Nasn Hone Lantls-L00 ~ ~)1i0J3 idae~ u.°u e¢cnn e.ua opro, ~ duwr: rrm an,r wnn 'u~uw, ue.¢c csaaam" ~KE'aiN°'1 oM1.7Y ro nu c•MMY4r STATE OF HAWAJ[;[ dcmw uurr."r n~,+g~it~r of sAwAw)v eto~ twrros ro. sox trn - t10NDtUtU. MnMAII fW July 24, 2007 Tl~e Honorable Pete Hoffmann, Chair AtiB Members of the Hawaii Couaty Council 3:3 ailauea Aveaue (Hen Franklin Huildinq) 2~° Eloor, Council Room Hilo, Hnwaii 96720 Vi-a Masi (~lOi)9i1-8912 AJeha Chair Hoffmann and Members of the Hawaif County Council: Subject: County of Hawaii Hill 51, Draft 5 Broposal to Amend Chapter 27, Flood Control, Hawaii County Code 1983 (2005 28ition) The Department of Hawaiiaa Hama Lands (DE1H-L) would like to express its concezns regarding the provisions of proposed Eill 51, Draft 5. One of the goals of DHtH, is to ^Provide evezy cNeliffed n:.ti•re Hawniian beaeficinry on the waiting list with na opportunity f;~r homeownership or lead stewardship on homestead lends." Nru~ D.fHL developments not only mow us closer to this goal, but also bz•ne~it the community at large by providing additional a~fordable h: Ames . Our concerns arise from the fact that certain provisions in t:.e Hi11 will require es~enditurea of additional funds for loatt, design and construction. Since our funding is limita~i, these a:.ditioaal expenditures will Nava a direct corollary in tk.a numb of affordable homes that DH[•II+ sad other developers ens provide. Foeusiag on the specific itseu that ws have particular c:ncearns with, we would like to share our views on t'ie fol_ov:ing: SQCtion 27-18 Standards fox censtruetion~ ItYm (cl (6): The requirements of prohibiting filling, grading, std other development which mny increnee flooding or eroaian hazards or, grades where the natural elevation of the ground surface prior to coastructioa exceeds ten psrcant, unless certified by a professional civil engineer licensed in the Stat® of Hawaii Comm: ~ T G . t1 S0 Ref. To:_ L'olt,nr'I Ref. Date '1111 9 5 ,ZO? 07/74/2007 15:22 FAX *9085393923 Hatn Hoae Lands-L00 ® )n'-'))3 21ie Honorable Pete goffmnn, Chair And Members o£ the Hawaii County Council J~i].y 24, 2007 Page 2 Clint the development Vill contain its own runoff and lurwcing impermeable surfaces on these areas to no more than forty percent o! the total land area o! any lot or propc~ed new subdivision will increase both the design cost and construction coat for new subdivisions. Ne defer the specific needs and resultant iaipacta of these requirements to tY.e design professionals, but wa are concerned with the addaiona= cost iapacta that will result from this. As written, this section iatplies that a subdivision proposed on terrain axCOOding tea percent will need to contain all of the runoff from the site. we ere concerned that Cris language does not differentiate between the pre-development discharge amount and post-development discharge amount as stated ir. Section 27-4, Item (j). In any event, the enlarged collectior. and con:ninment facilities Co retain a one-hour, 25-year storm event will increase Cris coot of subdivision developtasnt beyond what ie currently required. This will result in less lots per dollars expended, end drastically diminish the rate of affordable housing development. Limiting the ia~ermeebl• surfaces, in subdivisions Dropraed oh terrain exceeding teri percent, to no more than forty percent of the total lend area will impose Iower subdivision QtnSltiea. The forced lower deacitieC will result in tigher per-lot inlYastructure costs. Again, this will reduce the numbor of lore yielded per dollars expended wad decrsaae the amount of affordable homes built each year. Section 27-20, Standards far subdivisions wad other developments: Item {e): Tha requirements of having the lowest 11 oos elevated at least two last above the highest adjacent grade for Zone % Ishaded) and one foot above the highest adjacent grade for Zone % (unshaded) could negatively impact the 8welopment of a subdivision with a significant i:~creaee in the sitework construction cost- On sloping lands whr,ze aria roadway runs perpendicular to the slope and pad-graded ]ota o~_ both sides of the road, the lots on the uphill aide of the road are eypically is cut while the lots on the downhill side of the road are typically in fill- The requirements of having the lowest floor elevated either two or one feet above the highest adjacent grade (dofiaed as the highest r:atura:. 07/24/2007 15:22 FA% •8085663923 Narn Nose tantls -lD0 L Jo3 'o 03 Tl:e Honorable Pete Ho>`tlaan, Chair Aid Mambere of the Hawaii County Council J;~ly 24, 2007 Pe,~e 3 elevation oP the ground surface prior to construction :~fxt is the proposed walla of a structure) could significantly impact the homes on the cut aide of the road. The term •natura: elevation' is interpreted here as the existing ground p:~icr to grading, which may not be the intent, but is viewed as an ambiguity. 2f, in fact, 'natural elevation' is intended to be the existing ground prior to grading, then the cyst cf subdivision dewlopment will become exorbitant. Section 2T-20, Standards for subdivisions and other dewlonmente; item Ifl (11: A storm water diaposel system to collect and contain run-off from a one-hour twenty-five yQar storm event within the site boundaries will impact the amount of developable land that will be available for home sites. Together with the increased construction cost needed for the enlarged collection and coatainmant fncilitiee, this ste.ndard will ultimately result in a reduction of our ability to deliver ha:nesteads and diminish the potential fcr new affordable housing projects in the County of Hawaii. DHHL aokhowledgee the purpose behind Bill S1 of protecting the p~:l~lic from future flooding hazards and supports the Council in its intention to do so. However, as written, the Hill will drastically ierreaae the costs of subdivision development in Hawaii County and h.lnder the ability of DHHL to provide affordable housing there. Fcr this reason, DHNL urges the Council to reassess the requirements being proposed in Bill 51, Draft 5, to ensure that tlsc+y are fair and supportefl by the design professionals o'_ our State so es to be is the beat interests of all current and future rnaaidents of the County of Hawaii. Mahalo for allowing this opportunity to egress our via•xs on tlu.s matter. Aloha and m halo, Lorry m. Sumida Administrator Land Development Division II