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HomeMy WebLinkAboutSPP-21-000227 05.16-23 DPW-Engineering Comments DEPARTMENT OF PUBLIC WORKS COUNTY OF HAWAII HILO, HAWAII DATE: May 16, 2023 IffewaW0449 fL TO: Zendo Kern, Planning Director FROM: Department of Public Works, Engineering Division SUBJECT: SPECIAL PERMIT APPLICATION (SPP 21-000227) Applicant: Kona Aerial Gymnastic Team Inc. Request: To Legitimize the Operation of a Youth Gymnastic and Sports Fitness Facility TMK: 7-5-017.044 We have reviewed the supplemental information from Land Planning Hawaii LLC (LPH) dated May 4, 2023 for the Leeward Planning Commission as it relates to the Engineering Division and provide the following comments: Exhibit B: • does not indicate floodzone AE/AEF; • shows the location of fencing crossing floodzone AE/AEF which LPH's letter indicates "are essential to agricultural uses on the property"; however according to FEMA's NFIP Technical Bulletin 5 dated March 2020, fences are "prone to trapping debris" and "must be designed and constructed to fail under base flood conditions without causing harm to nearby buildings" or raised higher than the base flood or removed from the AE/AEF floodzone all together; the location of the fences must be supported with technical data or removed; • does not show the location of the concrete barriers which LPH's letter indicates are "outside of flood zones". At a minimum, the concrete barriers must be located outside of floodzone AE/AEF so that it does not impact the flow of water; • does indicate signage installed along the driveway route; as previously stated the Engineering Division does not have the authority to restrict access within private property which would be the liability of the property owner. County of Hawaii is an Equal Opportunity Provider and Employer Memo to Planning Department Page 2 May 16, 2023 The letter provided by Mr. Gloor certifies that the access road "is adequate for its intended purpose" and "typical of driveways in Hawaii and is consistent with Hawaii County standards" which is in reference to its construction. There is no mention regarding the safety of customers navigating the property during construction activities. No indication of where construction vehicles may be crossing the access road, no reference to signage (ie. hours of construction, location of where construction vehicles may be crossing, yield ahead/proceed with caution, etc.), or the use of flaggers when crossing the access road. We have not received any responses to comments sent to Mr. Gloor regarding the No Rise Certification for the access road. Mr. Gloor's original certification report stated that "no grading work" is "proposed within the floodway" and that "the work consists only of surface improvements to the existing driveway that crosses the flood channel". Per the Hawaii County Code, ""Grading" means any excavation or fill or any combination thereof." Therefore, even "surface improvements" are considered grading and according to FEMA's website, a No-Rise Certification for Floodways "must be supported by technical data". The certification report did not include any technical data like cross-section drawings or quantities of material excavated or filled to support the statement of "no impact on Base Flood Elevations or properties in the vicinity of the work". Grading work will not be allowed to commence until this matter is resolved. Questions may be referred to Robyn Matsumoto at 961-8924. cc: ENG-KONA County of Hawaii is an Equal Opportunity Provider and Employer