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LAND USE RESEARCH
FOUNDATION OF HAWAII �1
noo Alakea Street,4th Floor 11111111111116
Honolulu,Hawaii 96813 ..�.
(8o8)521-4717 —r
www.lurf.org
Via Hand Delivery
October 2, 2012
Dominic Yagong, Council Chair
Pete Hoffman, Council Vice-Chair
Donald Ikeda, Council Member
J Yoshimoto, Council Member
Dennis"Fresh" Onishi, Council Member
Fred Blas, Council Member
Brittany Smart, Council Member
Brenda Ford, Council Member
Angel Pilago, Council Member
Hawaii County Council
County of Hawaii
25 Aupuni Street
Hilo, Hawaii 96720
Opposition to Hawaii County Council Resolution No. 303-12, Urging the
Hawaii State Legislature to Repeal Chapter 171C of the Hawaii Revised
Statutes (HRS) to Effectively Abolish the Public Land Development
Corporation(PLDC).
Dear Chair Yagong,Vice-Chair Hoffman,and Members of the Hawaii County Council,
The Land Use Research Foundation of Hawaii(LURF)is a state-wide private, non-profit
research and trade association whose members include major Hawaii landowners,
developers and a utility company. One of LURF's missions is to advocate for reasonable,
rational and equitable land use planning,legislation,and regulations that encourage
well-planned economic growth and development,while safeguarding Hawai'i's
significant natural and cultural resources and public health and safety.
LURF opposes Resolution No. 303-12,which urges the State Legislature to repeal HRS
Chapter 171C based on the reported realization of the people the County of Hawaii that
said law would have detrimental effect"on our land,ocean, environment, and the
avoidance of many of our zoning and subdivision laws,which HRS 171C may ignore."
Comm. No. 51-(13.
Rif. To:
Ref. Date OCT •3 2012
F ,
Hawaii County Council
County of Hawaii
October 2,2012
Page 2
LURF's support for the PLDC. Contrary to the questionable and unsubstantiated
position taken by proponents of this Resolution, LURF commends the mission,
objectives and priorities of the PLDC,which are to create partnerships between state
and county agencies,departments,businesses, non-profits and community groups,to
improve our communities, create jobs and support development that is sensitive to the
cultural,historical and natural resources of the State of Hawaii. As such, LURF
supports the PLDC's efforts to partner with members of the public and to assist state
and county agencies to increase public benefit by reinvesting and enhancing state assets
such as parks and schools,as well as the PLDC's Strategic Plan and draft Administrative
Rules which will establish operating procedures for the Corporation; set forth a process
by which the PLDC may initiate or enter into cooperative agreements for the
development or financing of projects; and institute a procedure for undertaking and
financing any project facility as part of a project.
Allow further public input and the opportunity for PLDC to proceed.
Because the PLDC is now completing a public comment process by which it is
addressing questions and misconceptions expressed at community meetings held
statewide, LURF believes it would be premature for this Council to intervene in this
process by the consideration and passage of this Resolution,which may result in the
impulsive and untimely abolishment of the PLDC,thereby destroying the chance for
stakeholders and interested parties to provide invaluable input regarding this significant
opportunity through which private entities will be able to enter into agreements and
partnerships for the development and financing of projects that will make optimal use of
public land,generate revenues for the State, and in turn,economically and
environmentally benefit the people of Hawaii,including the Big Island.
Council support will result in positive economic benefits. As State land and
assets are abundant on the island of Hawaii, LURF strongly believes, contrary to the
sentiment held by supporters of this Resolution that the Council's support of the PLDC
and public initiated projects would result in positive economic impact for Hawaii
County and for the State.
Clarification of PLDC Requirements. LURF,too,understands the concerns of this
Council relating to the environment and what may appear to be an opportunity for
potential circumvention of existing zoning and subdivision laws. LURF has therefore
conducted a detailed review of the draft Administrative Rules, and has offered,for the
PLDC's consideration,suggestions and clarifications which LURF believes address its
concerns and are consistent with the intent and purpose of the legislation underlying the
creation of the PLDC. These recommendations include, amongst other things,
clarification that the PLDC is subject to Chapter 343 (Environmental Impact
Statements), Chapter 6E (Hawaii Historic Preservation), Chapter 92 (Public Agency
Meetings and Records — "Sunshine Law"), Chapter 104 (Wages and Hours of Employees
on Public Works) and Chapter 171(Management and Disposition of Public Lands —
prohibition of the sale of ceded lands); confirmation that the public land planning
activities of the PLDC"shall be coordinated with the county planning departments and
the county land use plans,policies, and ordinances"; and assurance that the proposed
procedural rules which seek to provide for public input,transparency and an efficient
d •
Hawaii County Council
County of Hawaii
October 2,2012
Page 3
process for PLDC proceedings and determinations are consistent with applicable rules
of other similar agencies.
Independent review of the PLDC, and recommendations for clarifications
and revisions to the draft Rules and Strategic Plan. LURF suggests that in lieu
of the action contemplated being taken by Resolution 303-12,the County of Hawaii
should likewise conduct its own independent review of Act 55 (2011), as well as the
PLDC draft Rules and Strategic Plan,to ensure thorough understanding of the actual
intent and purpose of the legislation,and,to propose,if necessary,its own clarifications
and revisions to the pending Rules and Plan.
Attendance at the next PLDC Board Meeting to present concerns and
recommendations for revisions to the PLDC draft Rules and Strategic Plan.
The PLDC agenda for its October 11, 2012 meeting will include the request to approve
the PLDC Strategic Plan and draft Administrative Rules that set forth its mission,goals
and parameters with regard to environmental, historic preservation and land use.
Approval of the draft Rules will allow the Rules to go out for a public hearing, a
minimum of thirty(3o) days after receiving Board approval.
As these PLDC agenda items will be heard later in October, LURF respectfully requests
that Resolution 303-12 be held,or at the very least postponed,in order that the
Council and the public may rightly be provided with further information which may
considerably affect its opinion of the PLDC and the proposed measures to be taken by
this Resolution.
Thank you for the opportunity to express our opposition to,and concerns regarding this
matter.