HomeMy WebLinkAboutCOM 0931.000 1996-1998
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DONALD IKEDA ALAN S. KONISHI
County Ckvk •'a,.," Deputy County Clerk
~re'oi'x~'tl
OFFICE OF THE COUNTY CLERK
Election Division
County of Hawaii
25 Aupuni Street
Hilo, Hawaii 96720
Memorandum
To: Honorable James Y. Arakaki
Chair, Hawaii County Council
From: Donald Ikeda
Clerk
Date: July 23, 1998
RE: Initiative Petition of the Parents Against Irradiation
The purpose of this memorandum is to present two certificates issued to the Parents Against
Irradiation, with regard to the initiative petition the committee submitted on June 19, 1998 and
which the committee amended by a supplemental filing on July 20, 1998. This presentation is
made in compliance with Article XI, Hawaii County Charter.
Section 11-5(a) states:
Within twenty days after the filing of an initiative or referendum petition, the clerk of the
council shall complete a certificate as to the sufficiency of the petition. As soon as a
certificate is completed, the clerk shall notify the petitioners' committee of the contents of
the certificate. If a petition is certified sufficient the clerk shall pre nt his certificate to
the county &Qnncil at its next meeting. If the clerk certifies a petition is insufficient, the
certificate shall show the particulars wherein the petition is defective. A majority of the
petitioners' committee may elect to amend a petition certified insufficient and must so
notify the clerk, but if a majority does not elect to amend a petition, the clerk shall
present the certificate to the county council at its next meeting. A petition is approved for
consideration through council action upon the clerk's certificate of sufficiency.
(underling added)
Ale No. CC E14
t~.~:-. t~+- JUL 2 2 19gR
Honorable James Y. Arakaki
July 23, 1998
page two
Section 11-6(a) states in relevant part:
The county council shall proceed immediately to consider an initiative or referendum
petition which has been determined sufficient in accordance with the provisions of this
article. If an initiative petition is concerned, the ordinance it proposes shall at once be
introduced subject to the procedures required for ordinances under Section 3-9 and 3-11
of this chapter ...(underlining added)
Note that the Corporation Counsel has confirmed that the reference to the sections is incorrect.
The proposed ordinance should be processed pursuant to sections 3-8 and 3-10.
In accordance with the above quoted Charter provisions, presented with this memorandum are
the following:
1) Certificate of Insufficiency, issued on July 7, 1998;
2) Certificate of Sufficiency, issued July 23, 1998; and
3) Letter from Richard D. Wurdeman, dated 16 July 1998
Presented separately is the ordinance proposed by the petition in bill form for our consideration.
s
C.
THE OFFICE OF THE COUNTY CLERK
COUNTY OF HAWAII
In the Matter of the )
Initiative Petition of ) CERTIFICATE OF INSUFFICIENCY
PARENTS AGAINST ) EXHIBITS "A-C"
IRRADIATION. )
CERTIFICATE OF INSUFFICIENCY
Pursuant to Sectionl 1-5(a), Article XI, Hawaii County Charter, the initiative petition
submitted by the PARENTS AGAINST IRRADIATION, entitled: "Initiative Petition -
Amending Chapter 14, Article 8 (Nuclear Energy) of the Hawaii County Code", is hereby
certified and deemed to be insufficient pursuant to Section 11-4(b), Article XI, Hawaii County
Charter, on the grounds that the petition "is signed by less than the required number of qualified
voters of the County." As explained in the following findings, the petition must contain 7,346
valid signatures to be deemed valid. The petition is deemed to contained 6,876 signatures of
qualified voters of the County.
Pursuant to Section 11-5(a) & (b), Article XI, Hawaii County Charter, the following
findings, which will be presented to the committee as outlined herein, show the particulars
wherein the petition is not sufficient. The Parents Against Irradiation committee is hereby
notified that pursuant to the Section 11-5, Article XI, Hawaii County Charter:
1. If a majority of the committee elects to amend the petition, you must notify the
Clerk. If not, you are hereby notified that the Clerk shall present this certificate to
the County Council at its next meeting on Wednesday, August 5, 1998, at which
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time you may request that the County Council approve or reject the certificate or
substitute its own determination of sufficiency of the petition by resolution. You
are hereby notified that the review actions of the County Council shall be final.
2. The committee may elect to file a supplementary petition upon additional papers
within ten days following receipt of this certificate. Pursuant to Section 1-29,
Hawaii Revised Statutes, the date of receipt is to be excluded when computing the
ten day period and if the tenth day falls on a Saturday, Sunday or holiday, it shall
also be excluded.
The above is based on the applicable law, the documents received, the evaluation of the
documents conducted by my staff and the following findings.
Findings
1. The sufficiency of the petition was determined based on the provisions of Article
XI, Hawaii County Charter, the basic procedures and policies used in 1988 to evaluate the
Hapuna Beach Initiative the last previous initiative measure which was placed on the ballot, a
1988 opinion from the Corporation Counsel, a review of federal law relating to social security
numbers, verbal instructions from the Office of Information Practices of the State of Hawaii, a
June 30, 1998 letter from the Corporation Counsel, and the documents submitted. Further, every
signature line was evaluated, first, by computer, and then manually by members of this office.
2. On June 19, 1998, at or about 1:30 pm, The Parents Against Irradiation submitted
an initiative petition, consisting of more than 1,088 pages addressed to the Council assembled as
one instrument, containing the full text of the ordinance proposed by the committee. A copy of
the proposed ordinance is attached as Exhibit "A" and incorporated into this certificate by
reference. The date of submission was at least forty-eight hours prior to the regularly scheduled
County Council meeting on July 1, 1998.
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3. Parents Against Irradiation is comprised of five members who are qualified voters
of the County and signers of the petition:
Name Date/Page Signed Petition
Naomi Cohen September 21, 1997/page 1021
Mark Cohen, M.D. September 21, 1997/page 1021
Julie Jacobsen September 21, 1997/page 1021
Donnalyn Johns September 21, 1997/page 1021
Susan Gilbert September 21, 1997/page 1021
Lorraine Sonoda-Fogel September 21, 1997/page 1021
Susan Gilbert, an original member of the committee, passed away on April 24,
1998, and was replaced by Lorraine Sonoda-Fogel.
4. Each signature page of the petition indicated the names and addresses of the
members of the petitioners' committee and the address to which all notices could be sent, Post
Office Box 467, Papaikou, Hawaii 96781. Each signature page contained a space for each
signer to provide their name, signature, residence address, social security number and date of
signing. A page of the petition, attached as Exhibit "B" and incorporated into this certificate, is
submitted as a sample page (with the information relating to the signers of that page omitted).
5. The pages were on papers of uniform size and style and assembled as one
instrument. The instrument was submitted and reviewed in the presence of the members of the
committee in a proceeding open to the public and press. Pursuant to Section 11-4(a)(3), Article
XI, Hawaii County Charter, which states:
petitions which reasonably comply with this subsection (a) shall be
accepted by the clerk without delay (emphasis added)
the pages deemed acceptable were received for processing.
6. Of the pages submitted, 1,088 pages were accepted after it was determined that
each set of pages was accompanied by an Affidavit executed by the circulator of the pages
attesting to the effect that the person circulated a set of papers, each page bears a stated number
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0
of signatures, each signature was affixed in the circulator's presence and each signature is the
genuine signature of the person whose name it purports to be. A copy of one of the Affidavits is
attached as Exhibit "C" and incorporated into this certificate by reference.
7. The 1,088 pages were processed only after it was determined, in the presence of
members of the committee, in the proceeding which was open to the public, that a copy of the
proposed ordinance (Exhibit "A") was stapled to each page at the time of signing.
8. A number of pages were returned to the committee at that time and not processed
because the pages were from another petition proposing a referendum.
9. After reviewing Section 11-2(c), Article XI, Hawaii County Charter, and after
reviewing the procedure and policy used by this office in 1988, it is determined that the
committee needs 7,346 valid signatures to be deemed sufficient based on the following
computation:
Votes Cast for Mayor in 1996
Candidate Number
Adler 391
Anderson---------------------------------------------- 393
Bonk ------------------------------------------------16,659
Rath -------------------------------------------------11,724
Yamashiro -----------------------------------------19,807
Total ------------------------------------------------48,974 x 15% = 7,346
In 1996, there were 1,460 "blank" ballots which contained no vote for any
mayoral candidate and 30 "over vote" ballots which contained votes for more than one candidate
for mayor. In 1988, the "blank" and "over" votes were not counted in computing the total
necessary to place the Hapuna Beach initiative on the ballot.
10. The 1,088 signature pages accepted contained 10,050 signatures. Of those
signatures, an initial computerized check indicated that 6,154 signatures were accompanied by
-4-
s
the correct social security number of a duly registered Hawaii County voter. Those signatures
were preliminarily deemed valid.
11. A subsequent manual review, in accordance the basic procedures and policies
used in 1988 to determine the sufficiency of the initiative petition relating to Hapuna Beach, was
conducted. The manual review included but was not limited to the following actions:
a. The information in the column entitled "Date" was checked to confirm
that the signer indicated a date of signing. Persons who did not provide
the information had their signatures invalidated (for example, some of the
signers on one page listed their date of birth). Also persons who were not
registered voters on the date of signing or for whom we did not receive,
prior to validation, a voter registration affidavit executed prior to or
contemporaneously with the petition signing, were invalidated as having a
"prior signature date." The date check was made of every signature
deemed valid.
b. If the computerized check indicated that the name and social security
number did not match, voter registration files were searched to determine
if the name on the petition corresponded to a duly registered Hawaii
County voter. If so, then the social security numbers on the petition and in
the voter registration file were examined to discover the reason for the
discrepancy. In those cases in which it was determined that numbers had
been transposed or a minor discrepancy was probably the result of a
difficult to read number, the signature was validated. Also, a check was
conducted to determine if the voter's name had changed or if the voter pro-
vided an incomplete name (initials only) or a nickname.
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C. Signatures not accompanied by a social security number were
labeled "duplicate" in the computerized check. We compared every
name (as best as we could read it), not accompanied by a social security
number, to our computerized voter information files. If it was determined
that the name matched the name of a duly registered Hawaii County voter,
and if the address provided matched the address in our files, the signature
was deemed valid (assuming it was properly dated.) It should be noted
that the Corporation Counsel issued an opinion in 1988 with regard to the
Hapuna Beach initiative which prohibits the invalidation of a signature
merely because it is unaccompanied by a social security number. The
opinion is based on federal law which supersedes the County Charter.
d. A further procedure was employed if a signature was not accompanied by
a social security number, however it matched the name of a person
registered to vote in Hawaii County but the address provided in the
petition differed from that in voter registration files. I am informed and
believe that generally such addresses are different because the voters have
moved since registration and have not yet informed our office of the
change. (A voter may report the change as late as on election day. It has
been our office's experience that roughly 10,000 voters change addresses
during an election year and on election day alone approximately 400
voters report new addresses.) There is a high likelihood that
automatically+jecting such signatures would result in denying the
participation in the petition process by some duly registered Hawaii
County voters. Once our staff determined that the name provided on the
petition corresponded to the name of a duly registered Hawaii County
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F
voter, the signature on the petition was compared to that contained in our
voter registration files. If the signature appeared to be genuine based on
the comparison, it was deemed valid. This was done for every signature
which was: 1) matched to the name of a Hawaii County voter; 2) not
accompanied by a social security number; 3) stated a different
address in the petition from that in our voter registration files; and 4)
which we validated. No evidence of fraud or forgery was found by
the elections staff. A total of 106 signatures were preliminarily validated
by this process. (The validated signatures were subject to a further check
to prevent duplicate validations.)
e. Further, 820 randomly selected signatures of the 10,050 submitted were
compared to those on file. No evidence to indicate fraud or forgery was
found. A comparison of every signature is not required by the County
Charter. It is not believed to be conducted by any other county in
processing initiative petitions. It is not possible given the limitations of
time, staff and technology and it is not conducted by County or State
elections officials to validate nomination petitions.
12. Pursuant to Section 11-4(d), signers had until 4:30 pm, Monday, July 6, 1998, to
file a written request with my office requesting that their signature be withdrawn. Six requests
were received by that deadline.
13. Based on the review of the signatures submitted, the voter registration information
on file and the applicable law, I find the following relating to the validity of the signatures
submitted:
-7-
s
Signatures submitted 10,050
Less:
"Not on File" (NOF)
Name and social security number do not match Hawaii
County voter. Manual check confirmed "no match". -1,481
"Duplicate" (DUP)
(1) Computer determined person signed more than once
or (2) signer did not provide social security number and
manual check confirmed that name on petition
did not match Hawaii County voter. Computer read
all names without social security number as a "duplicate". -1,094
"No signature date" (NSD) -75
"Prior signature date" (PSD) -70
Signature missing -22
Signature incomplete -2
Signature illegible -1
Inactive voter -34
"Wrong County" - Not Hawaii County voter -279
Withdrawals -6
"Wrong name"
Social security number matched Hawaii County voter
but name did not match. -2
Final duplicate check invalidations
Manual review all 3 ,583 "not on file" or "duplicates" indicated
1,008 possibily valid. A final manual check compared social
security numbers of such NOF & DUP with that of previously
validated signatures. Manual check eliminated duplications. -143
Plus:
"Wrong Social Security Number" - validated
Signer's name on petition matched Hawaii County voter
but social security number originally misread or contained minor
transposition or other error. Manual check
discovered error and confirmed no duplication. +35
Valid signatures 6,876
(68.41% of 10,050 submitted)
-8-
14. A representative of the committee will be invited by telephone, upon the
signing and filing of this certificate, to pick-up a copy of this certificate. This certificate will be
mailed to Post Office Box 467, Papaikou, Hawaii 96781 by regular mail and by certified or
registered mail, return receipt requested. Copies of this certificate will be made available to the
public and press on the day it is signed and filed, after an initial attempt is made to contact the
committee by telephone.
DATED at Hilo, Hawaii is -Y-A, day of July, 1998.
4,1111~
Donald Ikeda, Clerk
County of Hawaii
-9-
S
Exhibit "A"
Certificate of Sufficiency
Proposed ordinance
EXHIBIT "A"
INITIATIVE - PROPOSED ORDINANCE AMENDING CHAPTER 14, ARTICLE 8,
SECTIONS 14-45(a) (5) AND 14-45(a) (6) (A) OF THE HAWAII COUNTY CODE
COUNTY OF HAWAII - STATE OF HAWAII
BILL NO.
PROPOSED ORDINANCE
AN ORDINANCE AMENDING CHAPTER 14, ARTICLE 8, SECTION 14-45(a)(5) OF
THE HAWAII COUNTY CODE BY ADDING THE WORDS "but shall not. be limited
to" TO THE END OF SECTION (5) AND BY ADDING SUBSECTION (D) TO STATE
"Any quantity of radioactive material used in commercial irradiation
facilities," AND AMENDING SECTION 14-45 (a) (6) (A) OF THE HAWAII COUNTY
CODE, BY DELETING THE WORDS "or commercial devices, processes Or
facilities" THEREFROM.
BE IT ORDERED BY THE COUNCIL OF THE COUNTY OF HAWAII:
SECTION I. The Hawaii County Code, Chapter 14, Article 8,
Section 14-45(a)(5) is hereby amended as follows:
The present text which states:
"(5) The term `radioactive material or substance' shall
include:"
shall be amended to state:
"(5) The term 'radioactive material or substance' shall
include but shall not be limited to:"
Subsection (D) shall be added to state as follows:
"(D) Any quantity of radioactive material used in
commercial irradiation facilities."
SECTION 2. The Hawaii county code, Chapter 14, Article 8,
Section 14-45 (a) (6) (A) is hereby amended to delete the words "or
commercial devices, processes, or facilities,."
SECTION 3. This ordinance shall take effect upon its
approval.
?rtitiyf•Y?~1~~yr~4~~~~~rMr 1~1l1rr~~~rlyr lryr4
Exhibit "B"
Certificate of Sufficiency
Sample Affidavit Signature Page
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Exhibit "C"
Certificate of Sufficiency
Sample Affidavit Which
Accompanied Sets of Signature Pages
RECEVE
EXHIBIT "C" 98 19
OFF. 0t AFFIDAVIT
STATE OF HAWAII j
ss:
COUNTY OF I-LAWAIJ)
AJ Rv\Z PC~G_~ being first duly sworn, upon
oath deposes and says:
1. That your Affant is a person over the age of 21 years and is a
resident of tha County and State of Hawaii;
2. That this Affidavit is based upon the personal Icnowledge of the
Afftant and Affiant is competent to testify as to the truth hereof,
3. That your Affiant personally circulated the attached papers,
consisting of the full text of the proposed form of the ordinance whose enactment is
sought, a copy of the current Hawaii County Code, Chapter 14. Article 8 and the
Initiative Petition including -0-, pages of signatures numbered 13-7 -
4. That on each signature page attached hereto 'thete are
signatures and that a total of --JL signature pages are attached hereto, for a total of
oZ signatures;
5. That each signature affixed on all of the pages attached hereto
was affixed in your Afftant's presence; and
6. That each signature on every signature page attached hereto is
the genuine signature of the person whose name it purports to be.
FURTHER AFFIANT SAY ETH NAUGHT.
SUBSCRIBED AND WORN to before me
this dad of 1998.
Notary Public, State of Hawaii
Third Judicial District
tiny commission expires
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'98 JUL 23 =
UFF, u= : _
THE OFFICE OF THE COUNTY CLE
COUNTY OF HAWAII
In the Matter of the )
Initiative Petition of ) CERTIFICATE OF SUFFICIENCY;
PARENTS AGAINST ) EXHIBIT "A"
IRRADIATION. )
CERTIFICATE OF SUFFICIENCY
Pursuant to Article XI, Hawaii County Charter, the initiative petition submitted by the
PARENTS AGAINST IRRADIATION, entitled: "Initiative Petition - Amending Chapter 14,
Article 8 (Nuclear Energy) of the Hawaii County Code", and amended by a supplemental filing
on July 20, 1998, is hereby certified and deemed to be sufficient. The original petition was
deemed to have been insufficient on July 7, 1998 on the grounds that the petition "is signed by
less than the required number of qualified voters of the County." As explained in the Certificate
of Insufficiency, the petition must contain 7,346 valid signatures to be deemed sufficient. The
petition as filed on June 19, 1998 was found to have contained 6,876 valid signatures, 470 less
than required. The petition as amended is deemed to contain not less than 7,852 signatures of
qualified voters of the County. This determination is made after a computerized and manual
review of 1,025 of the approximately 2,100 additional signatures submitted. The reviews found
that the supplemental filing contains not less than 976 additional valid signatures. The number
of validated signatures will be increased when all remaining additional signatures are reviewed.
The Parents Against Irradiation committee is hereby notified that pursuant to the
Section 11-5, Article XI, Hawaii County Charter the Clerk shall present this certificate to the
County Council at its next meeting on Wednesday, August 5, 1998.
'The above determination of sufficiency is based on the documents received, the
evaluation of the documents conducted by my staff and the following findings.
Findings
I . On June 19, 1998, The Parents Against Irradiation submitted an initiative petition
consisting of more than 1,088 pages addressed to the Council, assembled as one instrument,
containing the full text of the ordinance proposed by the committee. Pursuant to Section 11-5(a),
Hawaii County Charter, a Certificate of Insufficiency was issued on July 7, 1998. It was
determined that the petition contained the valid signatures of 6,876 Hawaii County qualified
voters.
2. On July 10, 1998, the Certificate of Insufficiency was received by the Committee
via certified or registered mail, return receipt requested.
3. On July 13, 1998, a majority of the committee informed the County Clerk by
letter, that pursuant to Section 11-5(a), Hawaii County Code, the committee elected to submit an
amended petition. A copy of the letter is attached as Exhibit "A" and incorporated into this
certificate.
4. On July 20, 1998, the tenth day following its receipt of the Certificate of
Insufficiency, the committee submitted 250 pages (identical in format to the 1,088 pages
accepted on June 19), assembled as one document, containing additional signatures.
5. Each signature page of the petition indicated the names and addresses of the
members of the petitioners' committee and the address to which all notices could be sent, Post
Office Box 467, Papaikou, Hawaii 96781. Each signature page contained a space for each
signer to provide their name, signature, residence address, social security number and date of
signing.
-2-
6. The pages were on papers of uniform size and style and assembled as one
instrument. The instrument was submitted and reviewed in the presence of the members of the
committee in a proceeding open to the public and press. Pursuant to Section 114(a)(3), Article
XI, Hawaii County Charter, which states:
petitions which reasonably comply with this subsection (a) shall be
accepted by the clerk without delay (emphasis added)
the pages deemed acceptable were received for processing.
7. The 250 pages were accepted after it was determined that each set of pages was
accompanied by an Affidavit executed by the circulator of the pages attesting to the effect that
the person circulated a set of papers, each page bears a stated number of signatures, each
signature was affixed in the circulator's presence and each signature is the genuine signature of
the person whose name it purports to be.
8. The 250 pages were processed after it was determined that a copy of the proposed
ordinance was stapled to each page at the time of signie.
9. The 250 signature pages contained approximately 2,100 signatures. Of those
signatures, an initial computerized check determined that 1,025 signatures were accompanied by
the correct social security number of a duly registered Hawaii County voter. Those signatures
were preliminarily deemed valid.
10. A further manual review of the apparently valid signatures was conducted. Each
signature line which corresponded to an apparently valid signature was reviewed to determine if
the name and social security number indicated by the computerized check matched the
information provided by the signer. The information in the column entitled "Date" was checked
to confirm that the signer indicated a proper date of signing. Those signatures found to have
matching information and which had an acceptable signing date were validated.
11. Based on the computerized check and the manual review it is determined that the
supplemental filing contains not less than 976 additional valid signatures. (The presently
-3-
unvalidated 49 signatures from the batch of 1,025 will be further reviewed.)
12. All of the 976 additional validated signatures were accompanied by a social
security number. A further review of the remaining additional signatures is presently being
conducted employing the procedures used to determine the insufficiency of the original petition.
That review will increase the number of valid additional signatures.
13. The 976 additional validated signatures represent 207% of the 470 signatures
which the petition as filed was deemed to lack in order to be certified as sufficient.
14. A supplemental exhibit to this Certificate of Sufficiency will be filed upon the
final count of signatures. The exhibit will contain a breakdown of the valid and invalid
signatures; said breakdown will be displayed in the same format used in the Certificate of
Insufficiency (page 8).
15. A representative of the committee will be invited by telephone, upon the signing
and filing of this certificate, to pick-up a copy of this certificate. This certificate will be mailed
to Post Office Box 467, Papaikou, Hawaii 96781 by regular mail and by certified or registered
mail, return receipt requested. Copies of this certificate will be made available to the public and
press on the day it is signed and filed, after an initial attempt is made to contact the committee by
telephone.
DATED at Hilo, Hawaii is 3 r`/ day of July, 1998.
Donald Ikeda, Clerk
County of Hawaii
-4-
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P. 0. Sox 467
;D,4pxO1--< t;WA79"' PM 4 17
808- 934-799f,
July 13, 1998 COI. i\~i
Dear Mr. Ikeda:
Pursuant to Section 11-5 (b) of the Hawaii County Charter, a majority of the petitioners'
committee for the initiative petition to amend Chapter 14, Article 8 (Nuclear Energy) of
the Hawaii County Code, have elected to submit an amended petition. We intend to
submit the amended petition to your office on Monday, July 20 at 3:00 PM. Thank you.
Sincerely,
Naomi Cohen ( Mark Cohen Julie Jacobson
Exhibit "A"
Certificate of Sufficiency
0Vos
y
Stephen K. Yamashiro Richard Wurdeman
Mayor A - Corporation Counsel
OrNr'~f
Y aixnfV of Cttftiaii
OFFICE OF THE CORPORATION COUNSEL
101 Aupuni Street, Suite 325 • Hilo, Hawaii 96720-4262 • (808) 961.8251 • Fax (808) 961-8622
16 July 1998
Mr. Donald Ikeda
County Clerk
25 Aupuni Street
Hilo, Hawaii 9672
RE: INITIATIVE AND REFERENDUM
Dear Mr. Ikeda:
On July 8, 1998, you pointed out an incongruity in the Hawaii
County Charter (HCC), which had apparently not been noted before.
Presently, the section relating to County Council Action on
initiative petitions, HCC §11-6, required that they be processed
pursuant to Section 3-9 and 3-11 of HCC, relating to resolution
and emergency ordinances respectively.
In earlier editions of the HCC, what is now Section 3-8 (Actions
of the Council) was codified as Section 3-9. What is now 3-10
(Ordinance) was 3-11. (HCC 1968, 1980 editions).
It appears that in rearranging the order of the sections in
Article 3 for the publication of the current 1991 edition, the
editor neglected to note that these sections were referred to in
other Articles.
Thus, my conclusion is that notwithstanding the incongrous
results of the editing error, §11-6 should be construed to refer
to §3-8 and §3-10, as codified in the present Charter.
Sincerely,
R~~~ WURDEMAN
Corporation Counsel
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