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HomeMy WebLinkAboutCOM 0351.003 2016-2018 CARLSMITH BALL LLP A LIMITED LIABILITY LAW PARTNERSHIP 121 WAIANUENUE AVENUE P.O.Box 686 HILO,HAWAII 96721-0686 5.i TELEPHONE 808.935.6644 FAX 808.935.7975 -••-#-z WWW.CARLSMITH.COM f KGARSON@CARLSMITH.COM August 11, 2017 r,) .= — VIA HAND DELIVERY Chair Karen Eoff and Members of the Committee on Planning Hawai'i County Council 25 Aupuni Street, Suite 1402 Hilo, Hawai'i 96720 Re: Public Testimony Regarding Bill 52: "Adopts the County of Hawari Ka'u Community Development Plan (CDP)", August 15, 2017, 2:00 p.m. Dear Chair Eoff and Members of the Committee on Planning of the Hawai'i County Council: Carlsmith Ball LLP represents a number of clients that own properties within the Ka'u Community Development Plan("Ka'u CDP") area. We write to caution the County Council that a recent unpublished Intermediate Court of Appeals case held that the Kona Community Development Plan("Kona CDP")had the force of law when applied to a Planned Unit Development application in Kona, and as such, altered the provisions of other portions of the Zoning and Subdivision Codes as applied to the specific parcel in question, even without a separate ordinance specifically amending those Codes by the County Council. As similar language is contained in the Ka'u CDP, we urge the County Council to carefully examine each provision of the Ka'u CDP to avoid potentially adopting a special set of Zoning and Subdivision Code provisions for parcels in Ka'u. On June 26, 2017, the Intermediate Court of Appeals issued an unpublished opinion in Missler v. Board of Appeals of the County ofHawai'i (CAAP-13-002347, CAAP-13-0002752 ?Dv ggib and CAAP-13-0003040) ("Missler Decision"), which held that provisions within the Kona CDP :" 3 that were specifically indicated to be legally binding on County departments and agencies hold 1 the force of law under the facts and circumstances of that case. Thus, the ICA held that a F provisions within the Kona CDP augment the Zoning Code and Subdivision Code for certain g kinds of applications within the Kona CDP area. The Missler Decision was contrary to the County's official position taken in the Missler case. The County's position was that by adopting the Kona CDP, the County was not adopting HONOLULU • HILO • KONA • MAUI • Los ANGELES Chair Karen Eoff and Members of the Committee on Planning Hawai'i County Council August 11, 2017 Page 2 law,but only recommendations. In addition, the County's position was that CDPs could not change the Zoning Code and Subdivision Code without specific amendments being processed to those Codes. See attached letter dated February 24, 2016 from former Planning Director, Duane Kanuha to the Kona Community Development Plan Action Committee. The Ka'u CDP contains similar mandatorylanguage as contained in the Kona CDP. Section 2: Applicability of the Ka'u CDP states that Land Use Policies labeled "Policy Controls": "... limit the range of decisions that can be made in the future, like land use policies that specifically designate future settlement or transportation patterns. These binding, sometimes restrictive policy controls often include use of the term 'shall', which, from a legal standpoint, means the policy is imperative or mandatory." [emphasis added]. If the Missler Decision is not overturned, and absent corrective legislation, based on the Missler Decision, it appears these "Policy Controls" in the Ka'u CDP could be interpreted by the courts as automatically amending other inconsistent sections of the Zoning Code and Subdivision Code, similar to the Kona CDP. For this reason, we urge the County Council not to pass the Ka'u CDP with the "imperative or mandatory" language. Given the Missler Decision, our County has the potential to be administering numerous different codes and rules with respect to each geographical area covered by a different CDP. This is not only unwieldy, but certainly not the original intent of the CDP process. Additionally, the Council needs to carefully examine,be aware of, and make known to the public, exactly what is being changed prior to the passage of the Ka'u CDP. It is simply not fair to the public (some would call it denial of due process) to change existing laws and rules which affect property interests without providing specific notice of what is being changed, how it is being changed, and the effect of those changes on the property rights of the owners, as well as all members of the public. We urge the County Council to demand an open, fair and transparent process when it is considering the Ka'u CDP so that all property owners in Ka'u can be notified of specific laws and rules which may change and affect Ka'u property owners' interests. Thank you for your consideration. Sincerely, Katherine A. Garson Enclosure xc with enclosure: Mayor Planning Director Corporation Counsel 4824-0078-4460.3 William P.Kenos ...... Duane Kanuha Mayor - r ':\, Director Bobby Command DepuC Director West llawai'i Office EastHawai`i Office 74-5044 Ane Keohol:atole Hwyo t+ 101 Pauahi Street,Suite 3 Kailue-Kona,ldawai'i 9674 '0 C I f aw.. 1 Hilo,Hawaii 96720 Phone(808)323-4770 Phone(808)961-8288 - Fax(808)327-3563 PLANNING DEPARTMENT Pax(808)961-8742 February 24,2016 Mr.Hiram Rivera,Chairperson Kona Community Development Plan Action Committee Planning Department,West Hawai'i Office 74-5044 Ane Keohokalole Hwy Kailua-Kona,HI 96740 S SUBJECT: RE UEST FOR LEGAL OPINION r Dear Mr. 'vera.: This is in response to a letter dated February 8,2016 from past KCDP AC Chairperson Greg Ogin requesting clarification on whether the ordinance adopting the KCDP also amended all of the other code provisions that the KCDP stated it amended. Further,the letter also asks if all sections of the existing County Codes,that are not consistent with the KCDP,were also amended. Both Assistant.Corporation Counsel William V.Brilhante Jr.and i reviewed the subject letter and our joint response follows herein. The short answer is no. The only way the Hawai'i County Code("the Code")can be amended is through submittal and approval of a detailed amendment specific to a particular code section clearly articulating the language to be deleted and/or added. Until such time as specific amendments to the Code Sections Chapter 23 (Subdivisions) and 25 (Zoning) are approved by Council action,the Code requirements remain unchanged and controlling. Discussion: The authority vested in the creation of the various Community Development Plans("CDPs")were codified in the Hawaii County General Plan("GP"). The GP specifically states"the Community Development Plans shall recommend amendments as appropriate to the codes, maps or administration and enforcement (emphasis added). See GP 15.1, pg. 15-2 (February 2005 as amended). www.coliplxnninwlegtxum ffawai'i County is an Equal Opportunity Provider and Employertannin.? iccr,it Igo Mr.Hiram Rivera,Chairperson Kona Community Development Plan Action OQnunittee February 24,2016 Page 2 The very intent of the CDP was to be another tool to assist the Planning Department through submittals of"recommendations"that should be used to guide decision making in the future. There was no intent in the GP for the CDP's to override any statutory requirements currently held. The controlling documents which adopted the various CDPs are Ordinance No. 08 116, an ordinance adopting the County of Hawai'i Puna CDP; Ordinance No. 08-131; an ordinance adopting the County of Hawai'i Kona CDP; Ordinance No. 08 151, an ordinance adopting the County of Hawaii North Kohala CDP.; and Ordinance No. 08 159, an ordinance adopting the County of Hawaii South Kohala CDP. Each ordinance had a stated purpose which was to adopt the CDP attached to the respective ordinance as Appendix A, pursuant to the County of Hawaii General Plan,Section 15.1 (February 2005 as amended). The COPS were subsequently and collectively adopted under Chapter 16,PLANNING,Article 2. Community Development Plans,Section 16-2,Adoption of Community Development Plans of the Hawai'i County Code. Section 16-2 states in part"The community development plans listed below are adopted and incorporated by reference." KONA. The document identified as"Mapping the Future:Kona Community Development Plan Volume 1" is adopted by reference subject to later amendments by ordinance, and may be cited as the"Kona CDP." The planning area for the Kona CDP encompasses the judicial districts of North and South Kona.(emphasis added) NORTH KOHALA. The document identified as"North Kohala Community Development adopted byreference to later amendments byordinance,and maybe cited as the Plan" isp subject area for. the North Kohala CDP encom judicial asses the "North Kohala CDP. The planning P district ofNorth Kohala.(emphasis added) PUNA. The document identified as the"Puna Community Development Plan"is adopted by reference subject to later amendments by ordinance, and may be cited as the "Puna i district f CDP. em basis added) The planningarea for the Puna CDP encompasses the judicialo ( P P Puna and the Volcano Census Designated Place that includes the Volcano Golf Course subdivision in the district of Ka'u. SOUTH KOHALA. The document identified as the "South Kohala Community Development Plan"is adopted by reference subject to later amendments by ordinance,and may be cited as the"South Kohala CDP."(emphasis_added) The planning area for the South Kohala CDP encompasses the judicial district of South Kohala. As you can see,the purposes for each of these ordinances and incorporation in the Hawaii County Code were specific to the adoption of the particular CDP. None of them made any reference to amending any other portion of the Code. Of all the CDP's individually adopted by ordinance,only the Puna CDP was further amended by ordinances for clarification, designation or providing for Mr.Hiram Rivera,Chairperson Kona Community Development Plan Action:Gorimittee February 24,2016 Page 3 e non-substantive formatting and clerical revisions between November,2010 and December,2011 . These amendments were proposed and adopted following the adoption of the initial Puna CDP document in 2008, based on suggestions by the PCDP AC to the Planning Department, and initiated by the Planning Director. Section 3-10 (b)Hawaii County Charter("the Charter")specifically states,"Every ordinance of the council shall embrace but one subject, which shall be expressed in its title. If an ordinance embraces a subject not expressed hi its title,only that subject shall be void.(emphasis added)See Hawai'i County Charter Section 3-10(b). Accordingly,pursuant to the language of the Charter,other than adoption of the above-referenced CDPs, any stated, expressed or implied amendments to any other sections of the Code, shall be void. Finally, as referenced in ordinances above, each CDP was adopted pursuant to a controlling document, which by Charter is the GP. The GP sets forth specific language clearly delineating which documents shall be controlling,wherein it states "If there is a direct conflict between the Community Development Plan and the General Plan, the General Plan shall be controlling. (emphasis added) See Hawai'i County General Plan Section 15.1 (February 2005 as amended) Accordingly,not only will specific requirements of the CDP that are in conflict with the Code have to be amended thru Council action,but any conflicts between the CDPs and the GP would have to be specifically amended as well.Until such time as that takes place,each conflict that arises within the CDPs are deemed void and unenforceable pursuant to the Charter and GP. What the above determination means for the CDP AC's,is there is now a more interpretive role for the AC's with respect to providing guidance to the department in the implementation of the various components of the Kona CDP which were heretofore considered to be enacted and therefore legally binding through its adoption. Two important elements of the Kona CDP, Transportation and Land Use, although still guided by the documents Vision Statement and Guiding Principles,can now be implemented in a more flexible manner which is more reflective of how community dynamics ebb and flow over time. Nevertheless,I fully expect that the AC's will give due consideration to the intent of the participants and drafters of the KCDP in the exercise of this expanded interpretive role. Relatedly, then,various action items which are pending concurrence by this department relating to the above, are hereby acknowledged and will be implemented. More specifically, the recommendation by the AC as of your meeting of August 27,2014 relating to the use of adjacent or nearby lands and/or improvements to make up a difference in a proposed master plan with a total land area of less than 50 acres, and a recommendation on the application of CDP transportation policy 6.1 to require application of the official concurrency map in a manner that Mr.Hiram Rivera,Chairperson _ Kona Community-Development Plan Action:Committee February 24,201.6. . Page 4 area mitigation transportation improvements sufficient to offset traffic demand or impact of a proposed project based on approved level of service(LOS)analysis will be applicable. Staff will have to re-orient themselves a bit in response to this adjustment in how the Kona CDP is to be viewed but I expect that this re-adjustment will provide a great opportunity for a closer and more productive working relationship with the AC over time.It is thus critically important for the AC members to clearly understand that amendments to existing ordinances are a time consuming process and wholesale revisions will generally not be favorably considered. The AC's with the assistance of staff will need toprioritize their.thinking and try to focus on what critical elements of the CDP really and seriously need amending or revision. I will be happy to respond to any further questions you or the other members of the KCDP AC may have on this matter. Sincerely, (rif DUANE KANUHA Planning Director DK:rl c: Assistant Corporation Counsel William V.Brilhante,Jr.Esq. Deputy Planning Director Bobby Command All Division Managers Kona CDP Action Committee Members Managing Director