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COM 0903.001 2008-2010
DONALD IKEDA . Phone No.: (808) 961-8261 � Fix No.: (808) 961 -8912 Council Member . .; j o I District 2 South Hilo '' E - �rt�l: dikeda@colhawaii.hi.us • •r � T � of N ►�� F ] t 1 t. r; I HAWAII COUNTY COUNCIL ;, County of Hawai`i Hawaii County Building 25 Aupuni Street Hilo, Hawai'i 96720 Date: August 9, 2010 To: J Yoshimoto, Council Chair Hawai`i County Council And Council Members From: Donald Ikeda, Chair Hawai`i County Council Planning Committee Re: Communication No. 903 (Bill No. 283) Request for Time Extension for Proposed Woodland Center by Applicant HNMP, LLC - Paul Ogasawara, Manager Attached please find a copy of a letter I received from Tom Yeh, Esq., representative for the Metcalf Family Partnership regarding the above - referenced Request for Time Extension. I request that this letter be referred and distributed to all council members prior to the August 17, 2010 Planning Committee meeting, in order to allow sufficient time for each council member to review the documents and information contained therein. Thank you for your attention in this matter. Coma Na 0 3 rl Ref. To. V/ -f / PC- Ref. Dote,AUG 17 2014 Hawaii County Is An Equal Opportunity Provider And Employer Law Offices of Yeh & Moore THOMAS L. H . YEH tly@;lava.net A Limited Liability Law Company MICHAEL W. MOORE 85 W. Lanikaula Street Hilo, Hawaii 96720 -4199 oor mmoore glava.net Telephone (808) 961 -0055 FAX (808) 969 -1531 July 23, 2010 Donald Ikeda Chairman, Planning Committee Hand-Deily' and- Delzuered County Council County of Hawaii 25 Aupuni Street? Hilo, Hawaii 96720 Re: Request for Time Extension for Ordinance No. 03 -111 Woodland Center TMK No. (3) 1 -5- 007:020 Dear Mr. Ikeda and Members of the Planning Committee: We represent the Metcalf Family Partnership, LP ( "Metcalf Family ") and, on its behalf, are providing you with the Metcalf Family's position on the above - referenced request for time extension. The Metcalf Family owns that certain parcel of real property located at the southwest corner of the intersection of the Old Pahoa Road - Kahakai Boulevard Extension. Unless proper mitigation measures related to traffic impacts are implemented prior to the opening of the Woodland Center, the public's safety will be at severe risk in a number of ways. While the Pahoa area may be in need of the services to be made available at the Woodland Center, the Center should not be allowed to open to business prior to making a certain level of concurrent traffic improvements which are determined to be the most appropriate by way of a current Traffic Impact Assessment Report ( "TIAR "). Unfortunately, such a TIAR has not been provided nor have concurrent traffic mitigation measures been recommended for approval. Instead, the Applicant proposes to funnel all Center related traffic through an un- signalized and narrow T intersection at the Kahakai Extension and the Old Pahoa Road prior to constructing alternative routes (see Attachment "1 "). While both the Department of Public Works ( "DPW ") and the Department of Transportation ( "DOT ") have acknowledged the need for traffic mitigation measures to alleviate the "anticipated heavy volume of traffic" coming into and out of the Center (see Attachments "2" and "3 "), DOT is inexplicably recommending that the Applicant be allowed to construct a right turn into Kahakai Extension from the Pahoa Bypass and right turn out from Kahakai onto the Pahoa Bypass after the planned opening of the Center. Law Offices of Yeh & Moore A Limited Liability Law Company Donald Ikeda Chairman, Planning Committee County Council County of Hawaii July 23, 2010 Page 2 The Applicant has not prepared a current TIAR in conformity with the requirements of Ordinance No. 07 -99. This ordinance added Section 25 -2 -46 to the Zoning Code, which applies to an application for change of zone and to "an extension of time to perform a condition of zoning." The stated purpose of Ordinance No. 07 -99 was to assure that if a major development adds traffic to roads which are now congested or will foreseeably be congested in the future, the re- zoning shall not take effect "unless improvements to the traffic situation occur before the occupancy of the project." Without a proper TIAR and analysis of proper mitigation alternatives which are concurrently implemented, the Center will create an unsafe combination of traffic problems and add to already existing unacceptable levels of service. For all intents and purposes, access to the Center will be limited to the un- signalized Kahakai Extension/Old Pahoa Road intersection. When this intersection becomes gridlocked, there will be no escape route for safety and emergency vehicles to get into and out of both the Center and all properties tasking access from the Kahakai Extension. Here is why: 1. The widths of the rights of way and lengths and widths of the traffic lanes are substandard for the type of traffic and traffic conditions expected to result from the Center. It will be virtually impossible for large delivery trucks to negotiate turns from any direction at the T intersection. We enclose a scaled diagram of lane widths and turning movements, as well as a recent photo of a delivery truck crossing lanes which illustrates this point (see Attachments "4" and "5 "). 2. Whether it is a matter of delivery trucks and /or sheer traffic volumes for vehicles waiting to turn into Kahakai, waiting to turn out of Kahakai, or waiting to turn into or out of the Center, traffic will back up onto Kahakai, towards the entry to the Pahoa Marketplace, and create yet more traffic load for the Old Pahoa Road /Pahoa Bypass intersection, which now has the highest accident rate in the State, and is at level of service ( "LOS ") F. LOS at the Pahoa Market Access spur is already at LOS D, based on 2006 traffic counts. Traffic has since increased at these intersections. 3. Without mitigation measures, traffic will gridlock at the T intersection and accidents will occur as transpired during the recent tsunami warning, which occurred on a weekend day when people were simply trying to buy gas (see photos of gridlock, Attachments "6" and "7 "). With a Long's, Burger King, Law Offices of Yeh & Moore A Limited Liability Law Company Donald Ikeda Chairman, Planning Committee County Council County of Hawaii July 23, 2010 Page 3 Kentucky Fried Chicken, gas station and convenience store in place (all with drive through operations), one will expect peak hour traffic to generate this type of safety and accident hazard on a frequent basis. 4. Traffic from the Metcalf Family property driveway will find it close to impossible to turn left from the driveway onto the Kahakai Boulevard Extension, or from the Kahakai Extension into the driveway. Unless a second driveway is constructed on the Metcalf Family property, this traffic conflict will create safety hazards for the public as well. Since the re- zoning was originally granted in 1991 (and already extended no less than three times), much has changed in the Puna area and in the vicinity of the Woodland Center. Traffic and population in the Puna district has increased several fold, the Pahoa Marketplace has opened, and there is already a high accident rate on the substandard roads leading to the Center. DOT has recommended that the Applicant be allowed to open the Center before the recommended traffic improvements are completed, on the basis that the certificate of occupancy will likely be issued before the connection to the Pahoa Bypass Road can be completed. But this is putting the cart before the horse, and will result in a perfect storm of traffic problems, accidents and injuries. Upon close review, the record establishes that it is the Applicant which has delayed the project, not DPW, DOT or any other agency. The Applicant has been aware of the now expired construction deadline for several years. Under the terms of Ordinance No. 03 -111, the long delayed construction of the Woodland Center project was to have been completed by July 9, 2008. Because two time extensions had already been issued by the County Council, the Planning Director was granted the authority to provide only a one year time extension under Ordinance No. 03 -111. On April 14, 2008, Mr. McElvaney requested the final one year time extension (see Attachment "8 "). In response, the Planning Director issued the one year extension, but made clear in the response to Mr. McElvaney that any extensions beyond July 9, 2009 would need to be granted by the County (see Attachment "9 "). On December 22, 2009, counsel for the Metcalf Family sent a letter to Mr. McElvaney which provided written notice that the construction deadline had already expired and this Council's approval of any extension request was required (see Attachment "10 "). Between the Law Offices of Yeh & Moore A Limited Liability Law Company Donald Ikeda Chairman, Planning Committee County Council County of Hawaii July 23, 2010 Page 4 time of the construction deadline and the letter, no buildings had been erected (see Attachments "11" - "14 "). Rather than immediately prepare a current TIAR and implement proper traffic mitigation measures, the Applicant chose to plow ahead with construction and then file the incomplete request for a time extension request, at its own risk. To now ask that necessary traffic improvements be delayed until after occupancy is asking too much. It is the Metcalf Family's position that before the Woodland Center may open for business, the following steps must be taken: A. The County Council needs to have available before it all pertinent information relative to the current traffic impacts which the Woodland Center will cause for the Pahoa area, including Kahakai Boulevard Extension, the Old Pahoa Road, and the Pahoa Bypass Road, in combination with current traffic generators which include the Pahoa Marketplace. The application should not be considered until a proper TIAR has been submitted. The TIAR is required to provide trip generation data, impacts to transportation facilities in the vicinity and the general area of the project, projections for future growth in traffic in 5, 10, 15 and 20 year increments, and provide projections on growth from other uses. Alternative plans for mitigating impacts must also be presented. Until and unless this information is provided, it is difficult to assess the mitigation measures which may be the most appropriate. At the time of the original zoning ordinance and at the time Ordinance No. 03 -111 was adopted, the Pahoa Marketplace (opened in 2005) and the Pahoa Bypass Road were not in operation. The 2003 zoning ordinance was predicated on an October, 2002 TIAR, which analyzed potential impacts from a service station and convenience store. Ordinance No. 07 -99 requires a TIAR be prepared within six (6) months of the application. While a 2008 TIAR has been prepared by the Applicant, it uses 2006 traffic counts and erroneous assumptions (see excerpts from 2008 TIAR, Attachment "15 "). B. Based upon a current TIAR, proper mitigation measures must be implemented prior to occupancy, consistent with the concurrency requirement of Ordinance No. 07 -99. C. The Applicant should be required to construct a second driveway entrance to the Metcalf Family's property per the plans prepared by the Applicant's engineer, attached as Law Offices of Yeh & Moore A Limited Liability Law Company Donald Ikeda Chairman, Planning Committee County Council County of Hawaii July 23, 2010 Page 5 Attachment "16" prior to the issuance of occupancy permits for the Center. This second driveway will mitigate and decrease the risk of accidents for traffic entering the Kahakai Boulevard Extension from the first driveway. The Applicant should be required to follow the law. Bypassing these important requirements may be temporarily expedient, but the public will ultimately suffer, injuries may increase, and the currently hazardous conditions will be multiplied several fold, unless concurrent traffic improvements and mitigation measures are imposed as conditions of the requested time extension. Should there be any questions about the above, please let us know. Very truly yours, LAW OFFICES OF YEH & MOORE By THOMAS L.H. YEH cc: Jerel Yamamoto, Esq. Office of Corporation Counsel Metcalf Family Limited Partnership Encls. TLHY\db ' _x:14 A 4� /' -- ■ ___ ��� / * It I. • Ifi 6b ` 1 \ ` \\\ 1 - h „S _ i k w ,, y�am W \ ', ' ,(:.: r _ _ _ - - - - - - i . . i / I i �y X. ,. 1- `, , 4. _ / zr 7:1 / i II 0 - .eV \ i t / ' a aim! 4., „, RL> . ® // 4 / : v, . I l ' 7/ ./ / / I' / I 4 / 0 d11 1 1 11: iiik : ill , i: 4, Ap- 4%, , „ i , 0■ l!J O / / /,/ / • Mill al liarlf q o O 1!"( / liillIl ill ■ ' — ' Mil I , � � 1 d d 1 l ti ( ? / I ICI / 1p s e I / r / / , SokF Ncon, I % % , �� onnnu ; I • , 1 = mom ��. -�A I nd / ELI gay. . � / I � . II • • II G UA 0 • I _� y e ti / 0 / ;/; / • .� " / , / j • g/ • 13 / , i ' • ' • • • V . i \ i / • i • ,/ / / • • r / / // / v DEPARTMENT OF PUBLIC WORKS I f £7 COUNTY OF HAWAII H I LO, HAWAII DATE: June 9, 2010 Neagendadaego TO: ' BJ Leithead Todd, Planning Director FROM:✓ Department of Public Works SUBJECT: CHANGE OF ZONE (REZ 698) Applicant: HNMP, LLC (Paul Ogasawara, Manager) Request: Five -Year Time Extension to Comply with Condition B (Complete Construction) of Change of Zone Ordinance 03 -111 Tax Map Key: 1 -5 -07: 020 We have reviewed the subject request forwarded by your memo dated May 12, 2010 and offer the following comments for your consideration. The State DOT and the DPW are concerned about the anticipated heavy volume of traffic in and out of the Kahakai Boulevard due to the Woodland Center project. Therefore, we recommend the applicant construct a connection (right in, right out) between Kahakai Boulevard and the Pahoa Bypass Highway meeting the approval of the State DOT and the DPW within a specified time constraint. Questions may be referred to Kelly Gomes at ext. 8327. SCANNED JUN 5 ?HO ATTACHMENT "2" County of Hawaii is an Equal Opportunity Provider and Employer • .............. i.( r n 1959 9 LINDALINGLE _ ., GOVERNOR Ir BRENNON T. MORIOKA � i * DIRECTOR s t r Deputy Directors MICHAEL D. FORMBY FRANCIS PAUL KEENO STATE OF HAWAII BRIAN H. SEKIGUCHI DEPARTMENT OF TRANSPORTATION JIRO A. SUMADA 869 PUNCHBOWL STREET IN REPLY REFER TO: HONOLULU, HAWAII 96813 -5097 HWY -PS 2.5860 June 22, 2010 Ms. BJ Leithead Todd Director County of Hawaii Planning Department 101 Pauahi Street, Suite 3 Hilo, Hawaii 96720 Dear Ms. Leithead Todd: Subject: Change of Zone (REZ 698) Applicant: HNMP, LLC (Paul Ogaawara, Manager Request: Five -Year Time Extension to Comply with Condition B (Complete Construction) of Change of Zone Ordinance No. 03 -111 Location: Hawaii, Puna District, Pahoa, TMK: (3) 9 -2 -1:001 Thank you for the opportunity to review the proposed five -year time extension for the subject project, Woodland Center, which will add a Longs Drugs, Burger King, and Kentucky Fried Chicken (KFC) to the existing service station and convenience store. We have the following comments: 1. We understand that the applicant was unable to complete all construction of the project and associated road improvements by July 9, 2009, when the one -year time extension expired. 2. The applicant's representatives have worked closely with us in attempts to provide highway improvements to mitigate the traffic impacts of the Woodland Center project. 3. We recently held meetings with staff from the County Department of Public Works and the Planning Department and with the applicant and the applicant's representatives to resolve some remaining traffic issues. SCANNED I JUN 5 zuw ATTACHMENT "3" "° S 445� Ms. BJ Leithead Todd HWY -PS June 22, 2010 2.5860 Page 2 4. Our Keaau -Pahoa Road Improvement project will improve traffic flow and safety on State Route 130 from Keaau to Pahoa, including the road segment adjacent to Woodland Center. However, the project is still in the planning stage, with completion of construction projected from 2017 to 2020. 5. To address present concerns regarding traffic circulation and safety in the vicinity of Woodland Center, the applicant has agreed to provide additional improvements that can be quickly implemented, as follows: The applicant will provide access improvements to southeast bound Route 130 from Pahoa Village Road to Kahakai Boulevard by constructing an auxiliary lane that includes right - in/right -out access onto Highway 130 to improve safety and traffic circulation. As all work will be done within the existing State and County rights -of -way, design and construction should be completed quickly. 6. Existing authority to require the applicant to provide the intersection improvements on Route 130 is found in Condition E of both Ordinances 00 128 and 03 111, which states, "improvements, if any, to the Pahoa By -Pass Road, which may include extending the left -turn storage lane leading to the connector road, shall be installed as required by the State Department of Transportation- Highways Division, prior to receipt of a certificate of occupancy for any portion of the development." 7. The applicant and DOT agreed last week on reopening access from Kahakai Boulevard to Route 130. It would be almost impossible for the applicant to install the improvements prior to the projected time of receipt of a certificate of occupancy for any portion of the development. Recognizing that the applicant will fund the entire access improvements to solve a pre- existing traffic concern, we prefer to allow the Woodland project to open as planned with a completion date for the Route 130 improvements by January 2011. We recommend that the County impose the following conditions of approval for the five -year time extension: 1. Improvements to Route 130 shall include reconnecting Kahakai Boulevard to the southeast -bound Route 130 with a right - turn-in, right -turn-out configuration and providing a dual - purpose auxiliary lane on southeast -bound Route 130 from Pahoa Village Road to Kahakai Boulevard. This dual purpose auxiliary lane will be an acceleration lane for vehicles turning right on Route 130 from Pahoa Village Road, a merge lane for vehicles traveling past Kahakai Boulevard, and a deceleration lane for vehicles turning right into the reopened Kahakai Boulevard. The right -turn-out from Kahakai Boulevard shall be a channelized acceleration lane with a paved striped island. Ms. BJ Leithead Todd HWY -PS June 22, 2010 2.5860 Page 3 2. All improvements within the State highway right -of -way must be planned, designed and constructed to AASHTO standards and current State requirements and provided at no cost to the State. 3. Amend Condition E of Ordinance 03 111 to read as follows: "improvements, if any, to the Pahoa By -Pass Road, which may include extending the left-turn storage lane leading to the connector road, shall be installed as required by the State Department of Transportation- Highways Division, [prior to receipt of a certificate of occupancy for any portion of the development] by January 2011." If you have any questions, please contact Ken Tatsuguchi, Head Planning Engineer, Highways Division, (808) 587 -1830. e „,Y.T ?„1 trul yours, BRENNON T. MORIOKA, Ph.D, P.E. 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'. , .. .., ... , . , ; 1 ATTACHMENT "7" . . , . . .- Ak1 2008 APR 1 5 P(19 /7/6 0 //I 0 00 I L �;; ail i :, )I \RTMENT COUNTY C I Y OF HAWAII DOOM@ Ihe3Y� �� REALTY CORPORATION April 14, 2008 Chris Yuen Director Hawaii County Planning Department Aupuni Center 101 Pauahi Street Suite 3 Hilo, HI 96720 (808) 961-8288 Fax: (808) 961-8742 EE: Woodland Center Project Progress. TMK- 1 :020; Keonepoko Homesteads, Pahoa, Puna, Hawaii Final Plan Approval (PLA -07- 000211) RE: Request for time extension for the above referenced project. Dear Chris, This letter is to bring you up to date concerning the significant progress to comply with all the stated conditions of Change of Zone Ordinance No. 00128. Construction began in 2006 for the Woodland Center Service Station. While the service station was under construction, Durant Media Five Architects began concept drawings for the development of the rest of the Woodland Center. The service station was completed in January 2007. Final plan approval for the development of the Woodland Center was granted March 21, 2007. March 27, 2007 SSFM International was contracted to design and plan the improvements at the intersection of Kahakai Blvd, and Pahoa Road, which include the provision on left right — turn lanes on Kahakai Blvd extension, and a left turn lane on Pahoa Road. 040276 ® MLi P.O. Box 4338 101 Aupuni Street, Suite 1001 Telephone: (808) 935 -2995 Hilo, Hawai'i 96720 -4338 HilATTA640I G2W4259 Fax: (808) 935 -8269 SSFM submitted the TIAR to the Department of Transportation on September 12, 2007. DOT did not respond with their comments until March, 2008. Hirata & Associates were contracted to do the Soil Investigation report June 5, 2007. The Durant Media Five .Architects were contracted to complete design work, plan development, and construction plans on June 29, 2007. Letters of Intent for BK/KFC were signed June 15, 2007. They have since signed their Lease documents. The Lease for Longs arrived today (June 15, 2008) for review and acceptance. The Architect to design the KFC/BK restaurants has been contracted The Phase 1 Environmental Report was contracted and completed by Hawaii National Bank. Architect and Engineering fees paid to date for the above referenced work is approximately $244, 083.00. All contractors have been doing their best and were aware of the Change of Zone conditions pointing to July, 2008. Chris, in our discussion on April 16, 2008 at 10:00 AM, Hugh Ono and I will explain some of the conditions that could not have been foreseen or are beyond the control of the applicant, successors or assigns, and that are not the result of their fault or negligence. We humbly ask for your consideration to grant this project a time extension. Sincerely, tir Jon E. McElvaney, Project Manager and Agent for Paul & Nui Ogasawara e volcanoiareci.thritmail,com cell: 938-2033 JM • Harry Kim . � '!� ';';,S% :, /, , Christopher J. Yuen Mayor • ---1 • Director O J i' Or MO Brad Kurokawa, ASLA LEED ®AP 1tIIuxttg a �.t .ftatt Deputy Director PLANNING DEPARTMENT 101 Pauahi Street, Suite 3 • Hilo, Hawaii 96720 -4224 (808) 961 -8288 • FAX (808) 961 -8742 June 9, 2008 Mr. Jon E. McElvaney Project Manager Inoue- Hawaii Realty Corporation P.O. Box 4338 Hilo, HI 96720 -4338 Dear Mr. McElvaney: Change of Zone Ordinance No. 03 -111 (REZ No. 698) Applicant: Paul Ogasawara Request: Extension of Time to Condition B (complete construction) TMK: 1 -5 -007: 020; Keonopoko Homesteads, Pahoa, Puna, Hawaii We are in receipt of your letter dated April 14, 2008, requesting an extension of time by which to complete construction of the proposed Woodland Center, as required by Condition B of Change of Zone Ordinance No. 03 -111. For the reasons as discussed below, we hereby issue an extension of time until July 9, 2009, by which to complete construction of the Woodland Center project as required by Condition B. In our April 16, 2008 meeting and in your letter, you detail the diligent efforts of the applicant to complete this project that includes the preparation of a traffic impact analysis report, soil reports, project design and engineering and working with prospective tenants of the project. Condition B requires completion of the project on or before July 9, 2008. Final Plan Approval for the gas station and convenience center was issued on January 6, 2005, which completion of the facility in early 2007. Final Plan Approval for the remainder of the Woodland Center complex was issued on March 9, 2007. Condition B states, in part, that "construction of any development on the subject property shall be completed within five (5) years from the effective date of this amendment. In the event substantial construction has occurred, but not completed within the five-year period, the Planning Director may grant an extension of not more than one year." Hawai `i County is aNgTA J MIty Provider and Employer f • Mr. Jon E. McElvaney Project Manager Inoue- Hawaii Realty Corporation Page 2 June 9, 2008 Based on the discussion above, we believe that substantial construction and effort has occurred towards the completion of the Woodland Center project and that an extension of one year to complete the project is warranted. Please be informed that I cannot grant any further administrative time extensions. Should such further extensions be required, a written request, accompanied by a $250 filing fee, shall be submitted to this office for consideration by the Planning Commission and the County Council. Please do not hesitate to contact this office should you have any further questions or need for assistance. Sincerely, CHRISTOPHER . YUEN Planning Director DSA:cs P: \wpwin60\DSA\ 2008 \LOgasawaraREZ698TECondB.doc xc w /ltr: TMK file (1 -5 -007: 020) Tsukazaki Yeh & Moore THOMAS L.H. YEH tly@lava.net •ATTORNI:.YS AT LAW MICHAEL W. MOORE A Limited Liability Law Company mmoore u?lava.net 85 W. 1 anikaula Street Hilo, Hawaii 96720 -4199 R. BEN TSUKAZAKI Telephone: (808) 961 -0055 FAX (808) 969 -1531 (1987 -2008) December 22, 2009 Jon E. McElvaney Project Manager Inouye- Hawaii Realty Corporation P.O. Box 4338 Hilo, HI 96720 -4338 Re: Conditions of Ordinance No. 03 -11, Traffic Impacts and Revised Environmental Assessment; Metcalf Family Partnership, LP Dear Mr. McElvaney: Please be informed that this office represents the Metcalf Family Partnership, LP relative to the above. We understand that Myke Metcalf has previously made efforts to bring to your attention the fact that the proposed improvements and use of the Woodland Center property will create adverse effects upon traffic circulation upon the Kahakai Extension and the Old Pahoa- Keaau Roads which will not be properly mitigated by proposed traffic improvements which have been submitted to the Department of transportation for approval. Those impacts will also adversely affect the Metcalf property (TMK No. (3) 1 -5- 007:021) and traffic to and from that site, and general traffic circulation patterns in the vicinity. In fact, even though occupancy of the proposed improvements has not yet occurred, large trucks have already begin using the Metcalf property for turn around, and this is only one component of foreseeable issues. Such other issues include, but are not limited to, the following: 1. The failure of the proposed traffic improvements, signs, markings and lanes to accommodate traffic entering and exiting the Metcalf property. Given expected traffic volumes and the current design of the proposed road improvements, it will be near impossible for traffic wishing to enter or exit the Metcalf property. We also note that a proposed traffic "island" will block ingress and egress. 2. Ingress and egress driveways should be located at the Old Pahoa Road border of the Woodland Center. 3. Current intersection improvements at the Kahakai /Keaau Bypass intersection are already inadequate and will be exacerbated by the projected traffic flows from Woodland Center, in combination with the Pahoa Market Place traffic. ATTACHMENT "10" 't'sukazaki Yeh & Moore ATTORNEYS Ar LAW A Limited Liability Law Company Jon E. McElvaney Project Manager Inouye- Hawaii Realty Corporation December 22, 2009 Page 2 4. Proposed storage lanes along the Kahakai Extension are not designed to accommodate the driveways on the Metcalf property. Despite Mr. Metcalf's requests for re- consideration of the traffic issues, we understand that you have insisted that the currently planned improvements will move forward notwithstanding these concerns, and have failed to provide the most recent traffic study to Mr. Metcalf for his review. We have had the opportunity to review the current status of approvals for the Woodland project and note that it is in violation of the provisions of Ordinance No. 03-111 and the Plan Approval issued on February 5, 2009. We also note that given the use and proposed improvements to the Kahakai Extension and Old Pahoa -Keaau Road based upon a use and occupancy that had not been previously contemplated, the provisions of Chapter 343, 1-1RS, relating to environmental impacts have been implicated as well. As you know, Ordinance 03 -111 provided amendments to Ordinance No .00 -128, and contemplated a service station and convenience store. The planned improvements comprising the Woodland project involves much more than a service station and convenience store. The amendments primarily provided an extension of time for completion of construction within 5 years of the date of the ordinance which was July 9, 2003. A one year administrative extension of the July 9, 2008 construction completion deadline was allowed until July 9, 2009 by then Planning Director, Christopher Yuen, but in his letter dated April 14, 2008, Mr. Yuen made clear that he could "not grant any further time extensions," and any such extensions would need to be considered by the Planning Commission. Moreover, the Plan Approval issued on February 5, 2009 has been conditioned upon compliance with all stated conditions of approval of Ordinance No. 03-111, prior to issuance of the certificate of occupancy, and improvements required by DOT, and Public Works. Chapter 343, HRS also requires that at a minimum, an environmental assessment be performed prior to the proposed use of State or County lands. We have seen no such assessment for the current Woodland Center project, and which should assess the combined traffic impacts of the existing Pahoa Village Marketplace together with the proposed Woodland Center project. No opportunity for public comment has been provided which the Chapter 343 and the zoning amendment process would require. Tsukazaki Yeh & Moore ATTORNEYS AT LAW A Limited Liability Law Company Jon E. McElvaney Project Manager Inouye- Hawaii Realty Corporation December 22, 2009 Page 3 While the Metcalf Family Partnership is not inclined to prevent the proposed Woodland Center project which provides for appropriate traffic improvements, you should be aware that given the failure of your client to comply with the conditions of the Zoning Ordinance and Chapter 343, the Metcalfs will be addressing these issues with the involved agencies, but would prefer to do so with an understanding that your client is willing to address traffic impacts in a way which properly mitigates impacts upon the Metcalf property, including traffic entering and exiting the Metcalf property. Given the pending request for DOT approval of the current intersection improvement plans, we also ask that you discontinue your current efforts at obtaining such approval and provide DOT with written notice that your client is undergoing a review of the plans and will be re- submitting revised plans at a later date for approval. At a minimum, we will want to review the most recent traffic study and work with your traffic engineering consultant to discuss alternative approaches to traffic circulation and traffic improvements which can best address the proposed project, in order to be able to concur on such approaches as the agencies review the request for extension of the deadlines contained in Ordinance No 03 -1 1 1 and the environmental review process occurs. Please contact me no later than December 28, 2009, as to your client's willingness to cooperate with the Metcalfs and to provide the requested letter to DOT. We look forward to your anticipated cooperation in this matter. 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' ; .. 1.-„,• ,,,, Y it . 47 ; ■ , tu ' . ,. .,,...?.. . , ATTACHMENT "14" -, •",, : r• Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center traffic data for 12 hours at the intersection of Old Kea' au -Pahoa Road at Kahakai Boulevard. Likewise, it was necessary to predict traffic volumes for not only the peak hours, but also the same 12 hours that were counted, that would be generated by the project. Additional data available from ITE in the "Trip Generation Handbook" was used for this purpose. It was assumed that the existing gasoline station would remain in place and that its traffic generation would essentially remain the same with the development in place. It was assumed that there would be a 5 percent internal capture of trips to and from the gasoline station and the newly developed commercial units on the site. III. EXISTING CONDITIONS A. Roadways The Woodland Center site is located in a triangular- shaped parcel bordered by Highway 130 at the Pahoa Bypass portion of the highway, Kahakai Boulevard, and the Old Kea'au-Pahoa Road in the Puna District of the Island of Hawaii. Highway 130 is a major arterial road serving and providing a connection between the communities of Kea'au and Pahoa and communities located further south and east. It is primarily a two - lane road with turn lanes at major intersections along its route. Recent detail hourly volumes and speeds for each direction of travel were obtained for the analysis of traffic conditions along the Highway 130 corridor. Data from these analysis are included in Appendix A, and provides current volumes and operating speeds for the section of Highway 130 approaching the intersection of the Pahoa Bypass and Old Kea'au-Pahoa Road. The current posted speed limit on Highway 130 is 45 mph. Paved shoulders averaging eight -feet wide are in place. There is no curb and gutter in place on the route, which is basically flat and on a tangent section at its intersection with Old Kea'au-Pahoa Road. The estimated annual average daily traffic (AADT) for Highway 130 was approximately 12,500 in 2004 (see AADT data from HDOT in Appendix A). There is very limited commercial development along the road in the vicinity of its intersection with Old Kea'au-Pahoa Road. Old Kea'au-Pahoa Road is a two -lane collector road that serves the Pahoa Village. It was formerly on the main route from Kea'au but assumed a much lesser role when the bypass was constructed. The road has two lanes with earthen shoulders and a posted speed limit of 30 mph. The AADT was approximately 4,700 in 2004 (see AADT data from HDOT in the Appendix A). The intersection of Highway 130 and Old Kea'au-Pahoa Road is controlled by stop signs on the Old Kea'au-Pahoa Road approach. There is a turn lane for left turns into Pahoa Village from the Pahoa Bypass direction (northbound). On the southbound approach traveling towards Pahoa along Highway 130, there is a right turn lane and a painted channelizing island for right turn traffic onto Old Kea'au-Pahoa Road. On the northern approach from Pahoa Village towards Highway 130, there are two lanes with a painted channelizing island for right turns onto Highway 130 southbound. This right turn is SSFM International, Inc. -8- December 2008 ATTACHMENT "15" Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center essentially free -flow with an acceleration lane to allow drivers to reach highway speed before merging with the southbound traffic into a single lane. B. Ordinances and Mitigation Ordinance no. 00 128 was amended as Ordinance no. 03 111. The ordinance governs the reclassification of lands from Agricultural (A -la) to Neighborhood Commercial (CN -20) at Keonepoko, Puna, Hawai`i, covered by Tax Map Key 1 -5- 07:20. With the change in classification, the applicant, its successors or assigns shall comply with the following conditions of approval relevant to traffic movement: Condition C: Curbs, gutters, sidewalk, and pavement improvements to be provided within the Kahakai Boulevard extension right -of -way fronting the property. A 25 -foot radius provided at the intersection of Kahakai Boulevard and Old Kea`au -Pahoa Road. Condition D: Access to the property will only be through Kahakai Boulevard. Intersection improvements include left and right turn lanes on Kahakai Boulevard and a left -turn lane on Old Kea'au-Pahoa Road. Condition E: Extension of the left -turn storage lane leading to the connector road on Pahoa Bypass Road. The following table presents a summary of the mitigations considered in conformance to the County of Hawai`i ordinances and the results of this study. Item To Number Road On Item ConstruBcted? Comments Old Kea`au- Southbound left Per ordinances, 1 Pahoa Road turn into Kahakai Yes verified by study B Kahakai Blvd. Two approach Yes Per ordinances, lanes verified by study Curb & gutter 3 Kahakai Blvd. and sidewalks on Yes Per ordinance one side of street Not shown as Northbound right being warranted 4 Old Kea`au- turn lane at Yes by the study but Pahoa Road Kahakai Blvd. will be built as required by HDOT Old Kea'au- Not shown as 5 Pahoa Road at Traffic signal No being warranted Kahakai Blvd. by the study SSFM International, Inc. -9- December 2008 Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center C. Traffic Volumes The traffic volumes for the turning movements at the two intersections in the study area are shown in Figure 3. These numbers represent the morning and afternoon peak hours of 7:00 to 8:00 A.M. and 4:00 to 5:00 P.M. Truck counts were not made at the Old Kea`au- Pahoa Road at Kahakai Road intersection, but were estimated using the data from the November 2006 count. Pedestrian counts were not made due to the very low existing level of pedestrian activity at the study intersections and the expectation that the proposed development would not create significant volumes of pedestrian traffic. D. Sight Distance at Intersection of Old Kea`au -Pahoa Road at Old Kea`au -Pahoa Road Spur A review was made of the sight distance available at the existing access to the Malama Market at the intersection of Old Kea`au -Pahoa Road at the spur of the Old Kea`au -Pahoa Road. A measurement was made of sight distance looking to the left and right for drivers exiting the access point. As indicated in the figure below, there is 175 feet of sight distance available looking to the left towards the intersection of Highway 130 at Old Kea`au -Pahoa Road. There is 600 feet of sight distance available looking to the right from the access point as indicated in Figure 4. SSFM International, Inc. -10- December 2008 Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center IV. TRAFFIC FORECASTS A. Background Traffic Forecast Daily traffic volumes for the years 1996 through 2004 were obtained from HDOT for their count station located at the intersection of Highway 130 at Old Kea'au-Pahoa Road. This count data is provided in Appendix A. In reviewing this data, it was determined that the traffic volume along Highway 130 and at the intersection with Old Kea'au-Pahoa Road had grown less than one percent per year on average between 1996 and 2004 using a straight -line method. At the direction of HDOT, data from the work done by Wilbur Smith Associates (WSA) for the planning for future improvements for Highway 130 was used to estimate future traffic volume growth. This report was not available in late 2007 when the original TIAR effort was started. However, the completed report is now available. As indicated in the WSA report, traffic volumes will grow over the next 30 years substantially. The predicted traffic volumes for the morning and afternoon peak hours for the year 2012 were derived by reviewing the WSA report. The predicted turning movement counts for the year 2018, developed by WSA were compared to the existing base year counts from 2002 in the WSA report. This data was compared to the counts made in 2006 to predict the growth rates of through movements and turning movements at the four study intersections for the year 2012. Traffic increases were not shown for the exits from the Fire /DMV facility, the Malama Market or for Kahakai Blvd. It was assumed these volumes would not increase in the background, in absence of the Woodland Center project. Figures from the WSA report that were used in developing the predicted increases for the major movements on Highway 130 and Old Pahoa Road are included in Appendix A. The traffic increases were assumed to be straight -line based on the increases shown in the WSA report between 2002 and 2018, applied in reverse to the year 2012. The annual traffic increase was taken to be a summation or straight -line for the years 2007 to 2012. In general, the increases are approximately 10.9% total from 2007 to 2012 for the major movements on Highway 130 and just over 5% for Old Pahoa Road. An effort was made to smooth numbers where necessary to show no gain or add of vehicles into or from the system where it was known there were no intervening access points. See also the Wintass printouts in Appendix D which contain existing and future turning movements. The growth factors discussed above were applied to the existing morning and afternoon peak hour volumes from Figure 3 to give the future traffic volumes in the build -out year of 2012 as seen in Figure 5. A proposed new facility, now under construction, will consist of a fire station and an office of the Department of Motor Vehicles. The access to this site will be located to the west of the intersection of Highway 130 at Old Kea'au-Pahoa Road. A study of this project was conducted in 2006 by M &E Pacific, Inc. The predicted traffic volumes from this report were included in this study. The volumes were not included in the existing conditions review but were included in the reviews for the year 2012 for the no build and build scenarios. 2) Traffic Impact Analysis Report, Pahoa Complex Offsite Improvements, M &E Pacific, Inc., December, 2006, Warren M. Yamamoto, P.E. SSFM International, Inc. -18- December 2008 Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center Table 4 LOS and Other Measures for Future 2012 No Build Conditions for A.M. and P.M. Peak Hours A.M. Peak Hour P.M. Peak Hour Intersection Movement Delay V/C LOS Max Delay V/C LOS Max (Sec.) Ratio Queue (Sec.) Ratio Queue (ft.) (ft.) Highway EBd 10.1 .42 B 1 8.7 .45 A 1 130 at Fire WBd 0 .56 NC 0 0 .35 NC 0 Station/DM SBd 36.5 .14 E 12 23.7 .09 C 7 V Site Total ICU 0.5 .60 B NA 0.4 .50 A NA. NBd Left 145 1.14 F 319 75.9 0.99 F 297 Highway NBd Right 145 1.14 F 319 75.9 0.99 F 297 130 at Old EBd Thru 0 0.27 NC 0 0 .27 NC 0 Kea'au- EBd Right 0 _ 0.16 NC 0 0 .19 NC 0 Pahoa WBd Left 9.9 0.16 A 15 10.8 .15 B 13 Road WBd Thru 0 0.43 NC 0 0 .19 NC 0 Total ICU* 22:5 .61 B NA 19.1 .63 B NA Old EBd Left 16.7 0.35 C 39 29.8 .67 D 117 Kea'au- EBd Right 16.7 0.35 C 39 29.8 .67 D 117 Pahoa NBd Left 2.9 0.06 A 5 3.5 .10 A 8 Road at NBd Thru 2.9 0.06 A 5 3.5 .10 A 8 Market SBd Thru 0 0.24 NC 0 0 .26 NC 0 Access /Old SBd Right 0 0.24 NC 0 0 .26 NC 0 Pahoa Spur Total ICU* 4.2 0.56 A NA 8.7 .69 B NA Old WBdLeft 10.6 0.09 B 8 12.7 .15 B 13 WBd Right 10.6 0.09 13 8 12.7 .15 B 13 Kea'au- NBd Thru 0 0.13 NC 0 0 .19 NC 0 Pahoa NBd Right 0 0.13 NC 0 0 .19 NC 0 Road at SBd Thru 1.3 0.03 A 2 0.9 .02 A 2 Kahakai SBd Left 1.3 0.03 A 2 0.9 .02 A 2 Boulevard Total/ICU* 1.9 0.42. A NA , : :1.8 .45 A NA NBd is northbound, e.g. NC - Not calculated by software. NA - Not applicable or not available from software. * ICU is Intersection Capacity Utilization calculation from Synchro for non - signalized intersections. The ICU provides a measure of overall operations for non - signalized intersections not currently available through HCM methods. See Appendix E for details. SSFM International, Inc. -20- December 2008 Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center B. Project Generated Traffic The prediction of project generated traffic was made using the ITE guidelines in "Trip Generation" 7th Edition, and the "Trip Generation Handbook." It was assumed that the service station would remain in place and that its current rate of total trip generation would not change as a result of the addition of the retail sites. It was also assumed that there would be some trips to and from the various new retail sites and the existing service station. Based on experience with similar situations elsewhere, an internal capture rate of 5 percent was used to account for this phenomenon. So, a reduction factor of 0.95 was applied to all the trip generation data. Trips created by the new retail spaces were then added to the existing traffic generation of the site to arrive at the future total trip generation. An adjustment was made for passby trips in accordance with the ITE "Trip Generation Handbook ". Since the locale of the site is in some ways remote, a decision was made to use slightly lower passby rates than given as averages in the ITE "Trip Generation Handbook." For the retail space, a passby rate of 25 percent was used and a rate of 34 percent passbys was used for the two proposed restaurants. The ITE land use code for Shopping Center, 820, was used for the retail space while the code 834 was used for the restaurants, assuming these are high- turnover, fast -food type facilities. As further detail of exact tenants might become available, a more detailed estimate could be made. At this point, with the limited knowledge of potential tenants, the use of the these two land use codes would help to provide a conservative estimate of traffic impacts by using trip generation rates and passby rates that result in estimates on the higher end of the scale. With the lack of detail information about specific site occupants this provides for a safer assessment of traffic impacts. Trip generation calculations were made for a general shopping center. Since that time, the store has become known to be Longs Drug Store which would have a lower trip generation rate. Given this, the trip generation numbers can be considered conservative and impacts from the Longs store would be less than shown. The ITE "Trip Generation 7th Edition" and the "Trip Generation Handbook" were used to develop the predicted trip generation for the site (see Table 4). An internal capture of 5 percent was used. It was assumed that the service station would continue to generate the same volumes of traffic. An assumption was made that 50 percent of the service station traffic was new and 50 percent passby. Because actual traffic count data were used, there was no effect on the development of new trips and that information is shown for completeness of the table. It was assumed that the service station had 10 percent of its traffic in the afternoon peak hour. Furthermore, this assumption has no practical effect on the analysis. The new and passby trips indicated in Table 5 for the morning and afternoon peak hours were used as part of the input to the Wintass program to develop assignments to the traffic network. The Wintass program requires trip distribution percentages of total traffic. For this project, it was assumed that the trip distribution matched the current distribution of traffic in the study network for the A.M. and P.M. peak periods. To derive SSFM International, Inc. -21- December 2008 Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center this distribution a review was made of traffic volumes approaching the site from Old Kea'au-Pahoa Road and Highway 130. Based on a review of the existing traffic volumes, the distribution of trips is predicted as indicated in Figure 6. SSFM International, Inc. -22- December 2008 Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center A summary of the application of the signal warrants is given below in Table 9. Table 9 Summary of Signal Warrants as Applied to Old Kea'au-Pahoa Road at Kahakai for Existing and Full Buildout WARRANT DESCRIPTION EXISTING BUILD (2007) (2012) 1A TOTAL VOLUME NO NO 1B INTERRUPTION OF TRAFFIC NO NO ICOMBO COMBINATION NO NO 2 4 -HR VOLUME NO NO 3 PEAK HOUR VOLUME NO NO As seen in Table 11, at full buildout of the project, none of the warrants are met for the intersection of Old Kea'au-Pahoa Road at Kahakai Blvd. As per the traffic signal warrant analysis and discussions with HDOT, a traffic signal is not warranted or proposed at the intersection of Old Pahoa Road at Kahakai Blvd. D. Recommendations As a result of the analysis of the data collected and the predicted traffic conditions, the following recommendations are made: The following mitigations are recommended at full buildout of the project: 1. Widening of the Kahakai Boulevard approach to Old Kea'au-Pahoa Road to provide for two exit lanes, one each for left and right turns. 2. Widening of the approach to Highway 130 on Old Kea'au-Pahoa Road to provide stacking for the right turn movement. This turn lane would have 75 feet of full width storage as indicated on the project site plan. 3. Widening of Old Kea'au-Pahoa Road to provide a left turn lane for traffic entering Kahakai Boulevard. This turn lane would have 125 feet of full width storage as indicated on the site plan. 4. Widening of Old Pahoa Road at Kahakai Blvd. to add a right turn lane northbound into Kahakai Blvd as required by HDOT. This lane would have 125 feet of full width storage as indicated on the site plan. Additional analysis was made of the future conditions in the year 2012 with the project built and with the recommended mitigations listed above. Traffic signals are NOT included for any intersections and all will continue to have stop sign control on the side streets. The results of this analysis are shown in Table 10. SSFM International, Inc. -37- December 2008 Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center Table 10 LOS and Other Measures for Future 2012 Build Conditions for A.M. and P.M. Peak Hours with Mitigations in Place A.M. Peak Hour P.M. Pea k Hour Intersection Movement Delay V/C LOS Max Delay V/C LOS Max (Sec.) Ratio Queue (Sec.) Ratio Queue (ft.) (ft) Highway EBd 8.9 .51 A 1 8.8 .49 A 1 130 at Fire WBd 0 .39 A 0 0 .36 A 0 Station/DM SBd 29.1 .11 D 12 26.3 .10 D 8 V Site TotaICU * .4 .56 A NA 4 54' A NA NBd Left 174.5 1.24 F 564 141.8 1.16 F 359 Highway NBd Right 13.6 .31 B 22 13.1 .30 B 31 130 at Old EBd Thru 0 0.26 NC 0 0 .24 NC 0 Kea'au- EBd Right 0 0.26 NC 0 0 .26 NC 0 Pahoa WBd Left 11.2 .0.25 B 33 10.9 .23 NC 23 Road WBd Thru 0 0.20 NC 0 0 .18 NC 0 Total ICU* 32.8 .62-' B NA 27 9 :' .60; A ; NA Old EBd Left 96.4 1.01 F 257 88.4 .98 F 241 Kea'au- EBd Right 96.4 1.01 F 257 88.4 .98 F 241 Pahoa NBd Left 9.3 0.12 A 10 9.3 .10 A 10 Road at NBd Thru 0 0.21 A 0 0 .21 A 10 Market SBd Thru 0 0.36 NC 0 0 .37 NC 0 Access /Old SBd Right 0 0.36 NC 0 0 .37 NC 0 Pahoa Spur Total ICU* 20:2 067 13 NA 1,8.4 .66 B NA WBd Left 22.2 .35 C 38 20.4 .32 C 34 Old WBd Right 11.4 .25 B 24 10.9 .23 B 22 Kea'au- NBd Thru 0 .17 A 0 0 .15 A 0 Pahoa NBd Right 0 .04 A 0 0 .04 NC 0 Road at SBd Left 8.7 .17 A 18 8.5 .16 A 14 Kahakai SBd Thru 0 .19 NC 0 0 .18 NC 0 Boulevard Total ICU* 5.4 .42 A NA 5.4 .40 A NA NBd is northbound, e.g. NC -Not calculated by software. NA - Not applicable or not available from software. * ICU is Intersection Capacity Utilization calculation from Synchro for non - signalized intersections. The ICU provides a measure of overall operations for non - signalized intersections not currently available through HCM methods. See Appendix E for details. The mitigations are as per the County of Hawai`i ordinances referenced earlier. Despite the analysis indicated previously in this report, the ordinances require widening of Kahakai Blvd. to provide a left turn lane and a right turn lane for exits from the SSFM International, Inc. -38- December 2008 Traffic Impact Analysis Report With Traffic Signal Warrant Study Woodland Center Woodland Center. The ordinances also require a left turn lane for southbound traffic on Old Kea'au-Pahoa Road and that turn lane has been included in the analysis. The analysis indicated a right turn lane northbound into Kahakai Blvd. was not necessary but it was included as per HDOT. The mitigations do include widening of the approach of Highway 130 at Old Kea'au-Pahoa Road to allow for separate left and right turn lanes. As shown in Table 10, with the mitigations in place, the intersection of Old Kea'au- Pahoa Road at Kahakai Blvd. will operate acceptably at the morning and afternoon peak hours without a traffic signal in place. The LOS for left turns is shown as C for both the morning and afternoon peak hours. The LOS for right turns from Kahakai Blvd. onto Old Pahoa Road is shown as a B for both the morning and afternoon peak hours. The longest queue of either peak hour for the Kahakai Blvd. approach is shown to be just 38 feet. This indicates that the location of the first access to the Woodland Center need only be far enough away from Old Pahoa Road so as to accommodate a queue of two vehicles or a minimum of 50 feet. As indicated in Table 10, it is expected that the left turn movement from Old Kea'au- Pahoa Road onto Highway 130 will still experience delays and congestion, as indicated by the LOS F and the V/C ratio exceeding 1.0. However, in reviewing Table 4, it is evident that these conditions will occur even without the Woodland Center project in the year 2012. As shown in Table 4, the left turn from Old Kea'au-Pahoa Road onto Highway 130 will already have an LOS worse than D and a V/C ratio above 1.0 in the year 2012 without the Woodland Center project being built. As seen in comparing Tables 4 and 10, the LOS and delays for the right turn movement from Old Pahoa Road onto Highway 130 will be acceptable with the mitigation adding the 75 -foot right turn lane. It should be noted that delay values predicted by the Synchro model using the Highway Capacity Manual are not precise and are not reliable after V/C ratios exceed 1.0. Therefore direct comparisons of delays for oversaturated conditions (V /C exceeding 1.0) are not reliable. It can most generally be said that the calculated delays may not accurately reflect real world conditions when the V/C ratio exceeds 1.0. So, it can be said that the left turn from Old Kea'au-Pahoa Road onto Highway 130 will experience congestion and queues resulting from the demand exceeding the capacity of a stop sign controlled approach in the year 2012 even without the Woodland Center project. With this in mind, it is suggested that this project need not be expected to mitigate all future traffic impacts. It is suggested that HDOT and COH may need to review the traffic control at this intersection for possible consideration of a traffic signal or a roundabout. SSFM International, Inc. -39- December 2008 r a0312-0e --0.w r„na,e C.M. r wy. \e.v \C -a. S lE 11.64 1,4! 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