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Home My WebLink AboutCOM 0176.156 2006-2008 Page 1 of 1 Murashige, Laura From: Annie Yi [ayi@group70int.com] on behalf of George Atta [gotta@group70int.com] Sent: Tuesday, August 14, 2007 3:54 PM To: counciltestimony@co.hawaii.hi.us Subject: Written Testimony for August 15 County Council Meeting Attachments: Testimony to County Council re Chap 27 Amendment_081507.pdf Aloha, Please accept the attached pdf as written testimony submitted by George I. Atta, regarding the Ordinance to Amend Chapter 27, Flood Control, Hawaii County Code 1983 (2005 Edition, as amended), Relating to Floodplains and Other Flood Hazard Areas. Thank you for the opportunity to submit our testimony. ~ Sincerely, Annie Yi on behalf of George I. Atta ~ R George I. Atta, AICP Principal Group 70Internatianal, Inc. 925 Bethel Street, Fifth Floor _ Honolulu, Hawaii 96813 _ (808) 523-5866 phone (808) 523-5874 fax uninu,groun 70int. com This message, including any attachments, is intended solely for the addressee(s) and is confidential. It may also contain informaton that is legally privileged. Any person other than an intended recipient, or other party expressly authorized by the sender, is prohibited from using, copying, distributing, or otherwise disclosing the information contained herein. If you received this message in error, please immediately delete it and all copies, and promptly notify the sender. Thank you. omm. ~lo. ~~L•ls~o e .~jo: arese k,~tj e 6aot~__7 t ` 2 2007 8/16/2007 CaRC)l l~' r C) ADgust 1 s, zoo? Hawaii County Council F'm"G,s cda, Couty of Hawaii Amh o. FA'A AIC° Kailua Trade Center °""a"~y "°"g A'" 75-5706 Hanama Place, Suite 109 Sheryl B. Seaman. AIA, ASID ,I,osn Hiaa AIA Kailua-Kona, Hawaii 96740 Roy H Nihei. Ali,. CSI Jamesl Nishlmoto AIA Via email: counciltestimony@co.hawaii.hi.us `cteµnan H_YUen AIA Llnda C Mika. AIA 6eorgel Atta,AIC,P Testimon in O osition to An Ordinance Amendin Cha ter 27, Flood Control, enemy^H Dva:+.on,~,CAIA. LEED Hawaii County C de 1983 (2005 Edition, as amended), Relating to Floodplains and chnar,naMendeaRu°,nIa.AICP Other Flood Hazard Areas Jemae t ffimre, Ain. LEED Presented to Hawaii County Council RaalP Chomoy, AlA - i`Nli° Coma C91, CD'r Kimbe"y FVans August 15, 2007 Pele C Gaivez, PIA Sa,nhm Nan^, Distinguished Members of the Hawaii County Council: Roy A. Inouye. AIA C51 ca`°'Klaate' While this revision of Ordinance to amend Chapter 27 of the County Code is an Ka,hanne M. MacNeil, AIA bike F,au improvement to its predecessor (Bill 51), I would like to note the following issues ~mnka McCue which have yet to be adequately resolved. ' K3aika ~UC!(eague RossK M°nshlge. FJA Page 9: I have always wondered about the relevance of placing a definition of Kathryn A Nam H„am c. Paja flyways in the definition section. I do not see any relevance between bird flyways an DennaD Pay",nu,°„ flooding within the overall context of their section. This should be deleted. Kimoedy Poikichom, .41A, lE'cD s«,tt-angn"an Page 17: The draft says "when combined with all other existing and anticipated Y°""g' development will not increase the water surface elevation of the base flood." It is not Rohenoe Yumoi.Aw clear if this refers to only actions on the project parcels or includes adjacent and Haler. e..=°dmore. Alcl= outlying lands within the drainage area. If it is about other parcels nearby, it begs the question of how far away we look to address this comment; how far upstream and downstream we look for adjacent developments. Also, the language indicates no flexibility in the elevation of the base flood elevation; not even 1 inch. The previous draft said not "more than one feet". Clarity is needed or the sentence should be deleted. Page 19: The requirement of a CLOMR (item D) before commencement of development places another bureaucratic step into the process. FEMA is an under- funded agency these days and may take a long time to accept a CLOMR. This requirement will add uncertainty and additional burdens on project implementation. This requirement should be deleted. Group 70 International, Inc. • Architecture • Planning • Interior Design • Building Diagnostics • Assets Management • Environmental Services 925 Bethel Stree[, 5th Floor • Honolulu, Hawari 96813307 • Ph (80 81 5 2 3-5 86 6 • Fax (808) 523-5874 • www.group70inLCOm • mailt~grnup70intcom Page 22: Item F still includes for jurisdiction lands over 10% and a 40% lot coverage by impervious surfaces. It also makes a statement about development containing its own runoff without determining a standard. In the absence of a standard it is not clear if we are containing a 10 year storm, 25 year or 100 year storm unless we assume it is a 25 year storm based on other language in the draft. This vagueness increases director's discretion which adds uncertainty and additional risk to the process. Page 22-24: This section adds an additional freeboard requirement to construction between 1-3 feet. This affects the type of construction that is feasible and requires an additional elevation of structures. This affects handicapped accessibility, design and construction costs for buildings within these zones. There is no basis for the proposed amendment. Page 25: Within zone X there are requirements to add a 1-2 feet elevation of the lowest floor from the adjacent grade. First, it is not clear what adjacent grade means (within the project site next to the building or in reference to adjacent parcels of land). If it is on the project site it will then prohibit slab on grade construction and require arbitrary elevation of structures in zone X by one to two feet. This also adds to construction costs and creates problems with handicapped accessibility. To me there is no rationale behind the required increase in freeboard elevation for all the zones. As I have said in previous presentations, a case by case professional analysis is better than a blanket condition over such a vague zone as zone X. Page 30: The draft raises the new storm drainage standards to cone-hour 24 hour storm event. While this may not be excessive, it is a change in increased stringency without a good rationale for it. It still seems to me that the whole effort of Ms. Ford's amendments to this bill tries to fix a problem resulting primarily from illegal grading with a change in regulatory standards. It is like using a screwdriver to pound in a nail. It is the wrong solution to the problem it is trying to address. Page 31: The first paragraph gives the flood plain administrator the authority to require a higher standard than a 25 year storm event. While I do not have any specific problem with giving the director more discretion it is a little disconcerting to have this increase in authority without placing some criteria or guidelines for such discretion. Is it for safety, uncertainty of the facts, unique conditions or simple whim? It does not state the basis for any of the changes (i.e. why a 25-year event) say. I think criteria should be added. Respectfully submitted, GROUP 70 INTERNATIONAL, INC L~ George Atta, AICP Principal Planner for La'ipala Heights Group 70 International, Inc. • Architecture • Planning • Intedor Design • Building Diagnostics • Assets Management • Environmental Seances 925 Bethel Streel, 5th Floor • Honolulu. HawaYi 96813-0307 • Ph (808) 523-5866 • Fax (808) 523-5874 • w.xv.group70int.ram • mail~group70intcom