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HomeMy WebLinkAboutCOM 0018.003 1998-2000 DEPARTMENT OF PUBLIC WORKS COUNTY OF HAWAII HILO, HAWAII II(ieNlO~Le~1C?CulfL Date April 15, 1999 To DOMINIC YAGONG, Chairman Committee on Public Works & Parks From JIRO A. SUMADA, Deputy hief Eng eer SUBJECT Ordinance to Amend Chapter 10 Relating to Erosion & Sedimentation Control Communication 18.01 -Letter from Thomas Langenstein We have reviewed Mr. Langenstein's letter and have the following comments: • Paee 2 -Top Paragraph: As Mr. Langenstein may be implying, most drainage related grading complaints that we have received aze caused by individual land owners or farmers. We receive very little complaints on developers creating this type of problem. Besides complying with the provisions in Chapter 10, we routinely required developers to prepaze drainage studies and mitigation plans through the land use/subdivision approval process. Though Mr. Langenstein's suggestion has technical merits, we believe that imposing such arequirement on afirst-time home owner or a farmer would be extremely difficult. There aze many azeas in Puna such as Hawaiian Acres, Orchid Land, Fern Acres and Mountain View that this provision will affect. Lot owners in these areas can ill afford a drainage study and mitigation plan that would cost $3-5,000 or more depending upon the complexity of the drainage problem. I SO C _ ~ _ ~ 4~ C~~'~Oh a • ~ I~ la Pale 2. paragraphs 2 & 3: We believe the suggestio emg made to sections 10-1 and 4 .3~ y,,m 10-3-5 violates the legislative intent of Section 10 - -(4), HRS. This section requires the County to give the Soil & Water Conservation District (SWCD) the authority to supercede the (all) standazds established by Chapter 10. Inserting language that would limit their authority would therefore be improper for the County. However, we do believe that adopting procedures that incorporate these suggestions would be entirely proper for each S WCD if they feel it is appropriate for their district. 18. O 03 Comm. Na uu ~~O F51e No.,~.C' ~ G pwP c Ref. To: F 2~ 6~99~_` Ref. Dates----- Dominic Yagong April 15, 1999 Page 2 of 2 Besides the Kona SWCD there aze Puna, Kau, Hamakua, Waiakea and Mauna Kea SWCD's. More important than having a public meeting in Kona is the solicitation of comments from the five remaining SWCD's. It is our understanding that most of these districts have not been appraised of Mr. Langenstein's suggestions. Because the suggestions have island-wide impacts, opinions should also be obtained on an island- wide basis. With respect to liabilities associated with SWCD, we believe that Section 10-2-b-(4), HRS, coupled with the fact that the SWCD is an agency of the State of Hawaii, relieves the County of liabilities related to their decision making. • Page 2. naraeraphs 3: We do not agree that prior improper excavation or grading work should be grounds for denial of a Conservation Plan, particularly if the Conservation Plan will correct the improper work. For certain types of grading violations, we require the violator to obtain a grading permit. If a Conservation Plan will yield the same result, denying a violator the opportunity to seek this avenue of action seems counterproductive. As indicated in the previous paragraph, any SWCD is still free to adopt this suggestion if it so chooses. • Page 2. paragraphs S: In a declazed emergency, State laws will be superceded. Government agencies would operate under the direction of the State or local Civil Defense Agency. • Page 3 - T_p Paragraph: Chapter 27, Flood Control, already regulates grading and other activities within the 100-yeaz flood plain. Because a 100-yeaz flood plain may contain several flood zones, Chapter 27 is more comprehensive as it addresses permitted activities for each Type of flood zone. If you have any questions or need any further assistance, please contact the Casey Yanagihaza or Galen Kuba, at x8327. Copy: NRCS -Hilo w/Langenstein letter NRCS -Waimea w/Langenstein letter Puna SWCD w/Langenstein letter Kau SWCD w/Langenstein letter Waiakea SWCD w/Langenstein letter Mauna Kea SWCD w/Langenstein letter