HomeMy WebLinkAboutPD RECOMMENDATION (REZ 04-24)RSuffolkAmendREZ.crk.2.12.2020
COUNTY OF HAWAII PLANNING DEPARTMENT
RECOMMENDATION
SUFFOLK INVESTMENT,LLC
AMENDMENT TO CHANGE OF ZONE ORDINANCE NO. 05-113 (REZ 04-24)
Upon careful review of the requested amendments, the Planning Director is
recommending that an unfavorable recommendation for the applicant's proposed
amendments to conditions of Ordinance No. 05-113 be forwarded to the County
Council. Since this recommendation is made without the benefit of public testimony, the
Director reserves the right to modify and/or alter this position based on additional
information presented at the public hearing. This recommendation is based on the
following findings:
The applicant, Suffolk Investment, LLC has submitted an application to
amend numerous conditions of Change of Zone Ordinance No. 05-113, which
was originally approved on August 5, 2005 to change the zoning of the subject
property from Agricultural 5-acres (A-5a) to Multiple-Family Residential 2,500-
square feet(RM-2.5) for 14.872 acres of land.
The applicant is requesting modifications to the following conditions:
Condition B: (Extension of Time to Pay Water Deposit)
Condition C (Extension of Time to Complete Construction)
Condition D (Delete Rental Housing Restriction)
Condition E (Delete Requirement for Supplemental TIAR)
Condition F (Modify/Delete Already Implemented Portions of Roadway
Improvements Condition Time Extension for Construction)
Condition H (Modify Requirement for Location of Spine Road within
Project Site)
Condition I (Modify Required Location of Kuakini Highway Intersection)
Condition U (Delete Requirement of Providing a 5-acre School Site and
Improvements)
Condition V (Delete Reference to Fair Share In-Lieu Credit for School
Site and Improvements)
Condition X (Modify Affordable Housing Requirement and Change
Housing Program Approving Authority)
Condition Z (Modify Condition to Allow Administrative Time Extension)
The applicant originally proposed to develop a 250-unit market rental
housing project which included 250 units housed in twenty-four(24)two- and
three-story structures. Also proposed were over 300 parking spaces for residents
and guests, along with a 1+-acre park. The applicant's new development proposal
for the property reduces the density of rental housing to 226 units and intends to
develop open space and a passive recreation area.
The time extension and condition amendments are being sought due to the
applicant's costs of required infrastructure improvements. The applicant states
that they cannot commit to the target affordable rental level as represented in
2005, particularly due to the heavy on-and off-site infrastructure costs.
Additionally, due to the global economic meltdown that occurred over a decade
ago, the applicant believes that securing the required financing to initiate and
complete the project was too difficult to complete and thus decided to prioritize
exploring alternative uses of the property, and exploring sources for construction
financing. The applicant believes that the current economic outlook is amenable,
however time is still needed for the applicant to address the various conditions of
approval, to incorporate and finalize plans, and to secure the required financing.
Lastly, although there has been no physical construction that has occurred, the
applicant states that they have expended a considerable amount of"soft" funds.
These funds include nearly$1 million spent for more detailed land use planning
and the preparation of infrastructure construction plans for this project, as well as
the adjoining commercial/residential project proposed by Pua'a Development,
LLC.
While the proposed requests meet the Urban Expansion LUPAG
designation and are in an area served by existing infrastructure, several primary
factors necessitate this unfavorable recommendation. First, the zoning of the
subject property is not consistent with the goals,policies, and actions of the Kona
Community Development Plan(CDP) and the General Plan. Second, the retention
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of the existing zoning would not result in an appropriate land use pattern at this
time, therefore the Planning Director believes that a Project District zoning
designation is more appropriate. Additionally, the Director feels that the
requested time extension and amendment requests would support the continuation
of a speculative entitlement of the subject property for the purpose of resale.
The zoning of the subject property does not conform to the goals,
policies, and actions of the Kona Community Development Plan and the
General Plan and would not result in an appropriate land use pattern at this
time. In considering time extension and other amendments to change of zone
ordinances, the Planning Director must determine how the requests conform to
applicable goals,policies, standards and courses of action of the current General
Plan and adopted Community Development Plans. The subject change of zone
ordinance was approved by the County Council on August 5, 2005,just over three
3)years prior to the adoption of the Kona CDP on September 25, 2008. The
County Council also recently approved a slate of interim amendments to the Kona
CDP September 18, 2019.
The Land Use section of the Kona CDP serves as policy guide for County
decisions regarding physical development in Kona. It establishes a suggested
framework for future growth by identifying the County's major policies
concerning the type and location of future development in order to meet the goals
and objectives of the Kona CDP, which was created and approved with a
tremendous amount of community input and involvement.
The subject property is situated within the Kona Urban Area(UA) as
designated by the CDP. Within the UA, growth is to be directed to compact
villages located along proposed transit routes or to infill areas within, or adjacent
to, existing development into the Transit-Oriented Developments (TODs). The
CDP identified general locations of TODs within floating zones that are to
become fixed pursuant to a Project District Rezoning process.
The CDP identifies two (2)types of TODs based on type of urban core
articulated for the area: 1) Regional Center which is intended to encompass larger
population centers intended for a mix of residential, retail, commercial,
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employment and/or regional one-of-a-kind civic facilities like Kailua Village,
Makaeo, and Honokohau and 2)Neighborhood Village, which are smaller in scale
predominately residential, public/civic uses, or small-scale neighborhood-
oriented commercial uses. The subject property and adjacent lands are situated
within the Kahului-Puapua'a Village TOD, designated as a neighborhood village.
CDP Policy LU-2.1 recommends that TODs be developed as compact,
mixed-use villages, characterized by a village center within a higher-density
urban core, roughly equivalent to a 5-minute walking radius (1/4 mile),
surrounded by a secondary mixed-use, mixed-density area with an outer boundary
roughly equivalent to a 10-minute walking radius from the village center(1/2
mile).
As previously stated, the suggested location of a TOD is fixed through a
Project District(PD) Rezoning Application. According to the Zoning Code, the
project district development is intended to provide for a flexible and creative
planning approach rather than specific land use designations,for quality
developments. It will also allow for flexibility in location of specific uses and
mixes of structural alternatives. The planning approach would establish a
continuity in land uses and designs while providing for a comprehensive network
of infrastructural facilities and systems. A variety of uses as well as open space,
parks, and other project uses are intended to be in accord with each individual
project district objective. A project district is an amendment to this chapter which
changes the district boundaries in accordance with the individual project district.
Furthermore, the PD zoning allows for the flexibility to develop any uses
permitted either directly or conditionally in the RS, RD, RM, RCX, CN, CG, CV
or V districts provided, that each of the proposed uses and the overall densities for
residential and hotel uses are contained in a master plan for the PD and in the PD
enabling ordinance.
According to the CDP, the PD application process should further include
the development of a conceptual master plan to comprehensively address a mix of
permitted uses and density; street layout and standards,transit routes and
facilities, and bike and pedestrian pathways; village center public facilities;
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infrastructure requirements and timing; neighborhood park and public space
standards; a phasing plan; and calculation and treatment of density transfer area, if
any. Additionally, the Project District would allow for an increase of permitted
uses and densities versus the limitations of the existing zoning.
The CDP also suggests the use of Village Design Guidelines (VDGs) as a
guide to the development of the conceptual master plan(s). The intent of VDGs is
to ensure that the TOD is comprehensively developed as a compact, mixed-use,
pedestrian oriented development intended to increase transit use and manage
traffic congestion. The VDGs encourage residences, shopping, employment and
recreational uses located within close proximity with each other and efficiently
organized to provide for the daily needs of the residents. The VDGs consider a
range of housing types and affordability within pedestrian-oriented,human-scale
neighborhoods, incorporate natural features, open space, and cultural features,
provide efficient circulation systems for pedestrians, non-motorized vehicles, and
motorists and motorists that serve to functionally and physically integrate various
land use activities; and promote strong neighborhood identity and focus.
The applicant has argued that the existing land use plans submitted with
the amendment requests for the subject property and CN zoned property(Pua'a
Development) adjacent to the northeast(mauka)reflects the TOD concept by
incorporating a transit center on the commercially zoned property, providing
roadway connectivity, providing housing, addressing drainage and providing
goods and services to the proposed and immediately surrounding communities.
Since the adoption of the CDP, single-district zoning(e.g. RM/CN) is not
appropriate for development within a TOD. The CDP identifies the Project
District zoning district as the mechanism to achieve the mix of land uses and
required densities to support a Transit Oriented Development. Thus, retaining the
existing zoning will not allow the integrated approach required to develop the
compact, walkable,mixed-use village-style development recommended by the
CDP for neighborhood village TODs. The recommended use of the Project
District application process and development of an associated conceptual master
plan in accordance with the Village Design Guidelines is the only way to fully
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achieve with the preferred development pattern of the Kahului-Puapua`a Village
TOD articulated in the CDP.
The applicant also stated that conditions of approval of the requested
rezone amendment ordinance could further implement the TOD concept. First,
the applicant suggested a condition of approval could designate the project area as
a"Neighborhood TOD" site, which would act as a policy statement guiding the
development of adjacent parcels should they ever request an entitlement change.
A second condition of approval would require Plans for Plan Approval to comply
with the Village Design Guidelines articulated in the CDP. According to the
applicant, these proposed conditions would allow the Planning Department to
guide the gradual development of the TOD with multiple owners, without the
need of a master developer or master plan.
The Director feels that the CDP has already identified the property and
surrounding areas as a Neighborhood TOD, so this does not need to be done
through conditions of approval of individual rezone ordinances. Furthermore, this
scheme would unnecessarily create a new development process through separate
zoning ordinances, when a more appropriate, community-vetted, comprehensive
master planning process has already been established in the CDP for development
within a TOD. Additionally, the proposed process would shift the burden to the
County to act as a de facto project manager for development across multiple
parcels by having to monitor implementation conditions of multiple rezone
ordinances rather than one Project District ordinance and associated master plan
as recommended by the CDP. Furthermore, the existing RM-2.5 zoning limits
density to 2,500 square-feet per residential unit and excludes commercial uses.
Therefore, the mixed-uses and densities recommended for TOD cores cannot be
established under the current zoning.
Finally, the applicant indicated that the requirement of a Project District is
unworkable as the combined size of parcels making up the project area is
approximately 29.85 acres (14.872 acres for Suffolk Investments, LLC and
14.973 acres for Pua'a Development, LLC respectively), which is less than the
minimum 50 acres required by code for a Project District.
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Based on a review of County Real Property Tax (RPT) and State
Department of Commerce and Consumer Affairs (DCCA) records, the subject
14.872-acre property is owned by Suffolk Investments, LLC. Pua'a
Development, LLC is the only listed managing member of Suffolk Investment,
LLC. Pua'a Development, LLC also owns all of the properties immediately
surrounding the subject property, including TMK: 7-5-017:001, TMK: 7-5-
017:023, TMK: 7-5-017:026 and TMK: 7-5-017:039, which totals 46.87 acres.
Adding the land area of the subject parcel would create a total of 61.74 acres
between parcels owned by these two connected entities. As further discussed
below, the Director feels that given the shared ownership interest of the subject
and surrounding parcels, there is sufficient land area to accommodate the
minimum land area required for Project District zoning.
Another negative factor for this unfavorable recommendation is the past
segmentation of this are in securing planning entitlements. Subdivision No. 7814
was approved in 2004, to create a five (5)-lot subdivision, in which four(4) of the
lots resulted in an area just under 15 acres in size. Please note, the State Land Use
Commission rather than County Council must approve State Land Use Boundary
Amendments for properties 15 acres or more in size. In 2005,both Pua'a
Development, LLC and Suffolk Investment, LLC applied for and received
approval for a State Land Use Boundary Amendment from an Agricultural to an
Urban designation for their respective properties. At the time of processing, these
applications did not go to the Land Use Commission as they were represented by
the applicants as separate entities and were under 15 acres in size. The Land Use
Commission commented that while they had no specific objections to the
proposed project, they had strong objections to the manner in which they were
being processed under HRS §205-3.1 (Amendments to district boundaries). They
believed that both the Village Center(Pua`a) and the rental housing project
Suffolk) were part of the same Pualani Makai master planned community and the
permitting was deliberately incrementalized to evade the jurisdiction of the Land
Use Commission. Although the original 2005 boundary amendments were
approved in an incrementalized manner, in order to implement the TOD concept
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and Project District Zoning recommended by the CDP, the applicant will be
required to seek a State Land Use Boundary Amendment from an Agricultural to
an Urban district for the surrounding properties that under joint ownership from
the State Land Use Commission.
The proposed time extension and amendments do not comply with
General Plan Policy 14.5.3 (e) of the Land Use—Multiple-Family section,which
states, "To assure the use of multiple residential zoned areas and to curb
speculation and resale of undeveloped lots only, the County may impose
incremental and conditional zoning, which shall be based on performance
requirements. "
In the case of the subject, RM-zoned parcel, the applicant has gone well
beyond the time performance requirements of the existing ordinance, which
required completion of the development within five (5) years (by August 5, 2010).
The applicant did not apply for an additional five(5)years through an
administrative time extension,but if they had been granted such an extension
construction of the proposed project should have been complete by August 8,
2015. The applicant waited over four(4)years to attempt to revive their stale
ordinance and is only doing so now to either sell the property or secure a
development partner for this and the adjacent commercial development.
The applicant is now requesting to amend Condition C to require
Construction to commence within five(5)years to be complete within ten (10)
years of the effective date of the amended ordinance. In addition, the applicant is
requesting the inclusion of our standard administrative time extension condition,
which would effectively double the applicant's construction commencement
timeframe to ten(10)years and completion timeframe to twenty(20)years.
For both properties, the Planning Department requested that the applicant
provide a detailed development timeline and plan for how they intend to complete
construction within the extended timeframe requested, including any proposed
phasing or trackable benchmarks. In response, the applicant provided the name
and website of a potential development partner for the projects but did not provide
the detailed documents requested.
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Although the applicant has developed some engineering plans for drainage
and roadways over a decade ago, there has been no recent demonstrated
performance of other conditions of approval, such as developing archaeological
mitigation plans, finalizing highway access approvals, completing a sewer study
and solid waste management plan, flooding/drainage improvements,water system
improvements (or paid outstanding water commitments for 142 units), and
executing an affordable housing agreement. Based on past these performance
deficiencies and a lack of the requested development timeline, the applicant has
not demonstrated,to the Director's satisfaction, the ability to develop the property
in a timely manner.
Based on the preceding, the Director feels that the requested time
extension and other amendment requests without any trackable benchmarks
would support the continuation of a speculative entitlement of the subject
property for the purpose of resale.
Based on the Kona Community Development Plan, which was approved
with a tremendous amount of community input and involvement and to achieve
consistency with the broad goals of the General Plan and the more specific
regional goals identified in the Kona Community Development Plan, the Planning
Director does not believe retention of the current zoning is appropriate in this area
and is recommending that the applicant(s)pursue a State Land Use Boundary
amendment for the remaining two adjacent properties and submit a Change of
Zone to a Project District for the approximately 60-acre area to establish the
Kahului-Puapua`a Village Neighborhood Transit-Oriented Development.
Based on the preceding findings, the Planning Director recommends that an
unfavorable recommendation for the applicant's amendments to Conditions B, C,
D, E, F, H, I,U,V,X and Z of Ordinance No. 05-113 be forwarded to the County
Council.
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