Loading...
HomeMy WebLinkAbout2024-09-26 PL-INT-2024-008822 GP 2045 Draft Comments - T. Keeney DeVera, Ashley From: Sent: Thursday, September 26, 2024 10:02 AM To: Planning General Plan Subject: Comments on General Plan Attachments: General Plan Conceptual Comments.pdf; Comments & Questions General Plan.pdf The two attachments are my comments on the General Plan. Mahalo Tawn Keeney MD INITIAL CONCEPTUAL COMMENTS REGARDING THE GENERAL PLAN 1. The basic concept underlying the notion of General Plan is desirable. However this current Draft General Plan 2045 raises questions about practical application of that notion. It is found, in survey of the proposals here that the Draft General Plan is laden with contentious ideas which are likely to represent the thinking on one administration but may well be rejected by a subsequent administration, or, more importantly by the general public. If the General Plan is to be posited as a guideline or aspirational document that spans a period of 20+ years then contentious proposals, or proposals that have a shifting or limited source of support or are poorly understood by the public or the administration, should not be a part of the document. 2. Regardless of whether the apologists of placement of contentious proposals in the Draft General Plan attempt to justify this document as a `Living Document', they may also posit it as foundational to the development of ordinances and administrative rules that may subsequently arise. 3. Where there would be significant opposition, even if the document framers should feel themselves in a majority postion, the General Plan should be avoided as residence of that directive 4. If a General Plan directive may expect even modest opposition, then that proposal should be accompanied by a full explanation of the reasoning behind its position, as inclusion in the General Plan may become rationale for proposal as ordinance or administrative rule. 5. Does the State of Hawaii or the United States have a `General Plan' that it creates periodically. No, they have constitutions. However these `constitutions' are not given to contentious proposals which arise with the shifting of societal circumstance or environment. They are fundamental guidelines which are truly foundational and not subject to whim of administration. And it is from that document that legal applications arise. There is no intermediate `General Plan', formulated as aspiration by one administration after another, not subject to public debate and discussion 6. If a General Plan is posited by an administration as description of intention of where its aspirations lie, and especially if that Plan contains contentious or poorly understood proposals then that document should be retired at the conclusion of each administration rather than posited as a guidepost for a 20+ year period. 7. And if such a document is of such fundamental importance to construction of societal rules, then its evolution should take place by amendment of the underlying document rather than reconstruction of a new document which allows only incomplete or limited understanding of how that document has transformed from what has proceeded it. 8. If the document is reformulated as transformation rather than edited as transition from currently existing structure, then a full explanation of the rationale for each proposal should be available to the public. Even in the model of transition, an explanation of changes should be available to the public. 9. The above considerations conclude that: A) The General Plan should not contain proposals where agreement will be subject to significant contention. Rather, such proposals or directives must first be considered and endorsed in their individuality. B) A General Plan should have clarity of transition from its predecessor. C) The timeframe of application of the document should be shortened, perhaps as much as to the term of the administration which has generated the document. This shortened timeframe in itself will encourage transition rather than transformation. PUBLIC UTILITIES - COMMENTS P. 91. Be a net power producer with hydrogen and waste management. Comment: It is crucial to understand that both of these strategies for energy production in the case of waste to energy and energy storage in the case of hydrogen are controversial. Directives which are so controversial as these do not belong in the General Plan and thus this directive should be removed. In regard to hydrogen, use of hydrogen for light vehicular transport has little support. Use of green hydrogen is not efficient as utilization of green energy to hydrolyze, store, pump and transport green hydrogen results in a 25% loss of initial energy input. Conversion of hydrogen back to electricity in a fuel cell results in loss of another 50% of the original energy supplied for a net energy production of 25% from the original source. Use of the original green energy for Battery storage loses only 25% of the original energy supplied. This efficiency deficit plus the necessity of a huge initial infrastructure rollout makes hydrogen for light duty transportation impractical. Currently in the US there are 2000 hydrogen cars, 900,000 Battery electric vehicles. Makes investment in infrastructure impractical. Heavy vehicles, before investment by transporters has to have assurance that widespread infrastructure will be present. Not ready for massive infrastructure for only heavy vehicles. Hawaii Island has one hydrogen fueling station. Hydrogen busses can operate from this point, especially from the Kona station. Hawaii County has ordered 3 or 4 or 5 hydrogen busses to operate from this station but this will be only a small utilizing of hydrogen. Hydrogen power for cargo ships is questionable because of the space requirement for hydrogen. This likewise is true aviation's use of hydrogen. Grid energy storage using hydrogen is much less efficient than battery storage and may be less efficient than pumped gravity storage methods. The County needs to specify how hydrogen storage would be utilized before placing this controversial proposal in the general plan. Likewise Waste to Energy proposals are at least as controversial. Certainly the burning of waste streams gives rise to CO2(e) levels in the smokestack considerably higher than burning coal and the toxic hazardous emissions other than CO2 have been implicated in multiple disease processes such as cancer and respiratory disease. There is general agreement among expert sources that the efficiency of Battery Electric Vehicles in terms of Life Cycle Energy supplied per mile of vehicle traveled is about twice that of Hydrogen Fuel Cell vehicles. If there is a limitless source of abundant renewable energy such as Geothermal might offer in the mid-term future then the efficiency is a moot point (as leaving the house lights on when you go to bed). However, until the grid is 100% clean or renewable, to power transportation via hydrogen is an improper wasteful use of that energy. The following are comments which I offered to a COH Request for Information regarding Hydrogen Economy considerations. Let's consider efficiency in the decision to choose Hydrogen fuel cell over battery electric buses. The following are comments by Volkswagen at their `Newsroom' publication. This article, though from 2020, gives an excellent overall picture of efficiency. (Insert link). Volkswagen, Europe's largest car manufacturer, begins with "The crucial question in the automotive industry is: Should we rely on the battery as an energy storage medium or hydrogen? Or even push both to the same extent and subsequently bringing them both to the road?" They continue, "Science is largely in agreement on this issue, as several recent studies have shown. The Federal Ministry for the Environment, for example, assumes that hydrogen and synthetic fuels, so-called e-fuels, will remain more expensive than an electric drive, as more energy is required for their production.The Agora Verkehrswende (traffic transformation) initiative also points out that hydrogen and e-fuels do not offer ecologically sound alternatives without the use of 100 percent renewable energies, and that, given the current and foreseeable electricity mix, the e-car has by far the best energy balance. The article continues, "So which energy storage system has the best efficiency and is the most cost-effective for powering electric cars? With battery-powered e-cars, only eight percent of the energy is lost during transport before the electricity is stored in the vehicle's batteries. When the electrical energy is converted to drive the electric motor, another 18 percent is lost. Depending on the model, the battery-powered e-car thus achieves an efficiency of between 70 to 80 percent. In the case of the hydrogen-powered e-car, the losses are much greater: 45 percent of the energy is already lost during the production of hydrogen through electrolysis. Of this remaining 55 percent of the original energy, another 55 percent is lost when converting hydrogen into electricity within the vehicle. This means that the hydrogen-powered e-car only achieves an efficiency of between 25 to 35 percent, depending on the model." Volkswagen concludes, "From every angle of the environmental balance sheet, everything speaks for the battery-powered e-car. The technology is mature and ready for the mass market. The number of models is growing steadily. And with the battery-powered e-car, driving remains affordable. Current e-models are already at the price level of comparable combustion engine models. In contrast, the hydrogen car will always remain more expensive than the battery car- due to the complex technology and high fuel costs. Drivers already pay around nine to twelve euros per 100 kilometers for a hydrogen car, while battery cars cost only two to seven euros per 100 kilometers (depending on electricity prices in individual countries). And the topic of long-distance travel? That will soon no longer play a role. With the new generation of e-cars, ranges will increase to 400-to-600 kilometers, while charging will become increasingly faster. The conclusion is clear: in the case of the passenger car, everything speaks in favor of the battery and practically nothing speaks in favor of hydrogen. "No sustainable economy can afford to use twice the amount of renewable energy to drive with fuel cell passenger cars rather than battery-powered vehicles," says study leader Dietmar Voggenreiter. This is also the view of customers: In Germany there are already more than 130,000 battery cars on the road - but only 507 hydrogen cars..." A 2022 article states the following: "Fuel cells are less efficient, and lots of electricity is wasted producing hydrogen. The battery electric Nissan Leaf gets 123 miles per gallon equivalent, and the hydrogen-powered Toyota Mirai gets 79 miles per gallon equivalent; this does not include the wasted energy when producing green hydrogen. Most of the continued support for hydrogen (including for green hydrogen) stems from the fossil fuel industry. As of 2021 only 2 manufacturers offer hydrogen cars: the Toyota Mirai and the Hyundai Nexo. Honda stopped manufacturing the Clarity Fuel Cell in August 2021. The Frauenhofer ISI, one of the leading innovation research institutions in Europe and leading one in Germany has published a study a month ago in the publication Nature: "Hydrogen technology is unlikely to play a major role in sustainable road transport " The subtitle is "Technical and economic developments in battery and fast-charging technologies could soon make fuel cell electric vehicles, which run on hydrogen, superfluous in road transport." and it explains that when compared to battery-electric hydrogen is inefficient and uneconomical in ground transport," The Hawaii Electric Vehicle Association states the following in testimony to the State Legislature on a 2022 Bill to supply a $200,000 rebate for construction of Hydrogen refueling stations. "Hawaii EV recognizes that hydrogen fuel cell vehicles (FCEVs) are electric cars and that they have zero-tailpipe emissions. However, due to the following reasons, we continue to focus our efforts on accelerating the adoption of battery electric vehicles: • Hydrogen/FCEVs are inherently inefficient. When we consider well-to-wheel efficiency, these vehicles are only around 22% efficient. We don't have energy to waste. • The hydrogen ground transportation ecosystem is costly. A fueling station can cost $2M. Level 2 and DC Fast Chargers cost around $10k to $150k, respectively. • The market is churning out ever-increasingly diverse, affordable, longer-range EVs in response to consumer demand. The same cannot be said for FCEVs. Global sales continue to be a small fraction of that of EVs. This has implications in servicing, fueling, and supplying FCEVs. • There are obvious challenges associated with the creation of non-fossil fuel- based hydrogen. Most of the global hydrogen is produced from coal or gas. For it to be meaningful in Hawaii, we first need to meet our need for affordable electricity and transportation and do so with an abundance of firm renewable power. • SB2570 SD1 has the potential to negatively impact the expansion of public charging infrastructure. As stipulated in the measure, ONE hydrogen fueling station rebate is as much as $200,000. (A) $4,500 for the installation of an alternating current Level 2 station with two or more ports; (and] (B) $35,000 for the installation of a direct current fast charging system; and (C) $200,000 for the installation of a hydrogen refueling station; provided that it does not store or dispense hydrogen fuel that is produced using fossil fuels; and A$200,000 hydrogen fueling station rebate will support the installation of over 40 Level 2 charging stations or 5 DC Fast Chargers. Testimony by 350Hawaii on that same Bill stated that currently there are 18,000 registered Battery Electric Vehicles in Hawaii but only 37 Hydrogen Fuel Cell Vehicles. Globally, 16,000 Hydrogen vehicles were sold in 2021. In that same year the total number of new cars sold was 67 million, one in 4,000 being hydrogen powered. They strongly advocate that siphoning energy and funding away from supporting a robust battery charging infrastructure to support elements of a Hydrogen transportation infrastructure would only delay our transition to a clean energy future. Again, from a 2020 article, (because not many are speaking of Hydrogen transportation in 2023) we find a similar analysis: Let's take 100 watts of electricity produced by a renewable source such as a wind turbine. To power an FCEV, that energy has to be converted into hydrogen, possibly by passing it through water (the electrolysis process). This is around 75% energy-efficient, so around one-quarter of the electricity is automatically lost. The hydrogen produced has to be compressed, chilled and transported to the hydrogen station, a process that is around 90% efficient. Once inside the vehicle, the hydrogen needs to be converted into electricity, which is 60% efficient. Finally the electricity used in the motor to move the vehicle is is around 95% efficient. Put together, only 38% of the original electricity — 38 watts out of 100 — are used. With electric vehicles, the energy runs on wires all the way from the source to the car. The same 100 watts of power from the same turbine loses about 5% of efficiency in this journey through the grid (in the case of hydrogen, I'm assuming the conversion takes place onsite at the wind farm). You lose a further 10% of energy from charging and discharging the lithium-ion battery, plus another 5% from using the electricity to make the vehicle move. So you are down to 80 watts — as shown in the figure opposite. In other words, the hydrogen fuel cell requires double the amount of energy. To quote BMW: "The overall efficiency in the power-to-vehicle-drive energy chain is therefore only half the level of [an electric vehicle]." Likewise storage of energy via Hydrogen Fuel Cells for 'grid back up' energy is not as efficient as direct energy storage via batteries. Using P. 91. Pursue financial modifications to provide creative funding for significant expansion of water systems to reach new customers in non-service areas. Comment: Please describe the financial modifications and creative funding options being suggested here. Unless these are novel ideas there are probably reasons that such ideas have not gained traction. P. 98. Collaborate with government, private and nonprofit agencies, and other stakeholders to remove regulatory barriers and seek funding to complete and improve the islands fiberoptic loop in an environmentally and economically appropriate manner. Comment: Please describe what regulatory barriers are being suggested for removal. P. 102. Explore the feasibility of incentive methods such as property tax dedications, conservation easements, or transfer of development rights to protect the defined zone of influence of existing or proposed public and private wells. Comment: Please clarify the meaning of 'zone of influence' of wells. Please give examples of where and how this might be applied. How is the defined zone of influence of existing wells currently protected. Suggest: Ensure water distribution systems supply community perimeters with water availability to support intensive grazing for the purpose of firebreak and fuel break, or support of agriculture, or evens supporting community gardens for purpose of fire break and fuel break for retarding potential wildfire. Ensure the hardening of those systems against collapse from engulfing wildfire. P.105. The County operates municipal sewerage .... Comment: Add Honokaa to the list of county operated municipal sewerage. P. 109. Amend HCC, Section 21-26-1(a) requiring "all sewer extensions shall be approved by resolution f the County Council" to read "all sewer extensions outside of Urban Growth Areas shall be approved by resolution of the County Council" Comment: Please explain the motivation for removing from the Council's authority the examination and ratification by Resolution the extension of sewer extensions within the Urban Growth Areas. Please submit this proposal to County Council for ratification before placing it in the Draft General Plan. Comment: Please show a mapping of any changes in Urban Growth Areas on the present Draft General Plan 2045 Land Use Maps from the previous 2005 Land Use Maps HOUSING P. 146. With an estimated population increase from 202,000 to approximately 273,000 in 2045, a 35% increase, there will be a demand for an additional 17,000 resident housing units over the next 25 years. Comment: Please describe the County's views of the upsides and the downsides of an increase of 70,000 residents in the next 20 years. Is the only control opportunity of this number the availability of suitable housing? P. 24. About 90% of growth is through immigration. Comment: The Office of Housing has regulations which favor current residents in opportunity for purchase of `affordable housing stock' or rental of units which have been constructed or developed using `affordable housing guidelines'. With 15,000 of the needed 17,000 housing units likely to be resided in by immigrants, and with lack of affordable housing being recorded as a pervasive cause of out-migration of current residents, please include the following proposal in the Draft General Plan in the section `Housing'. " Any application for Building Division permitting pertaining to a project which qualifies as "Affordable Housing" according to Office of Housing criteria will be prioritized to be considered and examined by the Building Division ahead of any pending permit applications which would not have designation or fulfill Office of Housing criteria as "affordable housing". P.146. 44% of the population will be over the age of 65 by 2045. Q: Does the Planning Department evaluate this for desirability? Again, would this not be an important reason for supporting the limitation of influx of immigrants through available mechanisms such as the proposal above. P. 149 Remove barriers to reduce cost for new construction and rehabilitation of the current housing through changes to tax, zoning and building standard requirements. Comment: 1) Please give examples of how changes in taxation will reduce the cost of new construction and rehabilitation. 2) Give examples of how changes to zoning will reduce the cost on new construction and rehabilitation. 3) Give examples of how relaxation of building standards will reduce cost of new construction and rehabilitation. Comment: It is stated above that 90% of growth till 2045 will be through immigration. Does it make sense to reduce taxation, which will benefit the general public, in order to accommodate immigration. Much of the cost of immigrant ownership of housing will be distributed among the current resident population (though some of the cost will be in purchase of offshore materials). Where is the advantage in reducing building costs for this immigrant population of homebuyers. Removal of barriers should only be for the `affordable housing' component. P. 149. Create subsidies like LIHTC for the missing middle of affordable housing (80% -140% AMI) Comment: Please Describe the subsidies of LIHTC. Do individuals or families currently making 120% AMI qualify for housing subsidies? Please describe the thinking that an individual or family making 140% of Area Median Income should be able to qualify for Affordable Housing Subsidies. It seems clear that affordable housing projects must become the rule rather than the exception. Housing subsidies up to 140% seems like one method toward this proposal. But then this could be paid for by increased taxation on the total of new housing which would in effect redistribute funding to support affordable housing or perhaps a progressive tax of some kind. P. 149. Encourage resort communities to include onsite workforce housing options. Q. Why has workforce housing onsite not been a stipulation of Resort Communities up until now. What are the downsides of making this a requirement rather than an encouragement? What is the encouragement which is being proposed here. If it is a requirement, or even if it is just encouragement, will it lead to importation of workforce. Can residency requirement be included? Can public/private incentivization lead to the County building affordable workforce housing on or adjacent to resort property? P. 151. Amend building regulations to allow for as-built permits and new renovation permits for less than 50% of an existing structure to conform with the building code of the year the main structure was permitted, excluding electrical and other critical life safety codes. Comment: Please explain the meaning of this and the practical impact which it will have. P. 153 Revise financial mechanisms and property tax provisions to allow for creative finance solutions to incentivize new construction and rehabilitation of affordable housing. Comment: This sounds like it was lifted from a 2007 textbook for Real Estate Lobbyists. Please describe some of the financial mechanism adjustments and property tax provisions that would allow the creative finance solutions referred to. P153. Adopt a County affordable housing program, similar to HRS 201 H that encourages development, reduces cost and simplifies permitting. Comment: HRS 201 H is an undisguised blow to the intent of Regulation. The main purpose of planning and a Planning Department is to impose regulation. The County Council should have jurisdiction to weigh the advisability of waiving regulation in the appropriate circumstance regarding Affordable Housing development. Please describe in detail the regulations which have been most commonly superseded by invocation of 201 H. In what way would a County 201 H similar proposal provide opportunities that HRS 201 H itself does not. This proposal appears to be counter to the idea of safeguards to the common good for the benefit of development, and should be abandoned. Q: Recently two 20 unit housing subdivisions in Honokaa, one affordable and one not affordable, have been passed by Commission and Council and survey begun. When the developer made presentation in Honokaa he indicated that the affordable lots without structures would be priced somewhere around $300K. By what mechanism does a vacant lot without a structure qualify as `affordable'. VISITOR INDUSTRY P. 177 By adopting regenerative practices, our island can not only mitigate the negative effects of tourism but also ensure the long-term wellbeing and resilience of its communities and ecosystems. General Comments: 1. The emphasis on Regenerative Tourism came as a result to the mounting criticism of the numbers of visitors and intrusion into the social fabric that the numbers of visitors was creating. The numbers of visitors is the basic problem - not that the visitors are disrespectful of the historic and current cultures. The catchphrase of `Regenerative Tourism' is an effort to divert attention from the real problem of numbers. It is likely that for 90+ % of visitors there has been no change of plans or behavior from before the term `regenerative tourism' was fabricated. There has been no diminishing of numbers of visitors. 2. By far, the most `negative effect of tourism' is the associated Greenhouse Gas emissions from air transport of visitors. As we see more and more the social effects of rising temperatures such as climate migration, civil unrest and food shortages and the climate disasters such as fire, flood, hurricanes, sea level rise etc. the more clear it will be that leisure travel must be eliminated. Hawaii tourism, as leisure travel, is perhaps the worst offender on the planet, Hawaii being the most distant archipelago from any inhabited continental land mass. 3. In 2021 I presented a paper to the Honolulu Climate Change Commission indicating that Greenhouse Gas Emissions from air transport of Visitors to Hawaii accounted for 1-1/2x Hawaii's total domestic GHG emissions. The Honolulu Commission requested that I present the paper to the State Climate Commission. Dr. Makena Coffman, UHERO researcher, presented a critique of the paper a year later indicating that the correct figure would be equal to all Hawaii's domestic emissions. However her analysis did not count any connecting flight emissions, but only the two Hawaii legs of an itinerary. This is resultant from her use of the Hawaii State Greenhouse Gas Inventory, of which she was an author, for visitor data. My findings were based on the Hawaii Tourism Authority's eight `Global Regions of Origin' visitor data and thus counted `connecting flights' in the itinerary (which has its own problems). 4. Also subsequent to Dr. Coffman's presentation, the IPCC designated as 'best science' on Aviation emissions a method which calculates the global warming potential of `non-0O2 emissions' as twice that of CO2 emissions themselves. Whereas myself and Dr. Coffman had calculated these `non-0O2 emissions' as equal to the warming potential of CO2 itself, using the IPCC endorsed method would bring her calculation of visitor air transport GHG emissions to 1-1/2x the state's total domestic emissions, and my calculation, including the multiple legs of any visitor itinerary, to 2x the state's total net domestic emissions. 5. My papers to the Honolulu and State Climate Commissions are included in the Communication section. CLIMATE CHANGE P. 11 "Although Hawaii Island alone will not reverse global GHG emissions, we can lead by example and set a precedent for other island states to become more sustainable. Comment: By far, the most important example that we can set would be to set a yearly adjustable tax or fee on visitation to our islands. This fee should begin modestly but progressively increase to bring the number of visitors down dramatically over a several year period. The only practical source of such a fee is a Visitor Accommodations Tax. The current State administration has suggested a$50/visitor fee (voluntary). This is insufficient to reduce visitation here. Whereas the appropriate placement of revenues from a Visitor's fee should be toward resilience to the challenges of Climate Change and sea level rise, in that visitor air transport emissions are greater than Hawaii's domestic emissions, the current proposal before legislature places the modest voluntary revenues received toward renovations of parks and trails and beaches. P 12. Airline transportation also contributes significantly to greenhouse gas emissions, as the only transportation to and from the island is by air. Comment: The State Greenhouse Gas Inventory places the greenhouse gas emissions from domestic aviation at 3.2 million tons CO2(e). 86% of passengers are visitors. This is with total domestic emissions about 13 million tons. All ground transportation accounts for 3.8MMT and stationary combustion (electricity generation) at 8MMT. However this 3.2MMT is departures only (one way) and does not include connecting flights on the itinerary but only the leg leaving Hawaii. It does not count any international flights. It accounts for minimal NOx emissions but otherwise only CO2 emissions. An averaging of results of eight aviation greenhouse gas calculators found online places the `non-0O2' emissions warming potential at equal to the CO2 emissions and thus the total global warming GHG emissions from aviation at 2x the easily calculable CO2 emissions. Using this method Makena Coffman PhD., UHERO faculty & an author of the Hawaii State GHG Inventory, concluded that emissions from visitor aviation equaled the total of Hawaii's domestic emissions in 2019. Her method also did not include any connecting legs of an itinerary other than the Hawaii legs. Using her method but adding connecting flights brings the total global warming in CO2 equivalents to approximately 1-1/2x the State's total greenhouse gas emission. Using the IPCC endorsed factors for Non-0O2 emissions in calculating warming from aviation brings the total CO2(e) from air transport of visitors to 2x Hawaii's total domestic GHG emissions. P13. "The County will need to preserve open spaces and forested lands to maintain carbon sinks. Comment: The county needs to dramatically increase its open spaces and forested lands but preservation is a foundational part of that. Funds for tree planting and restoration of forested lands should become available via a fee on visitors here due to visitors heavy GHG footprint from air travel. P15. Pursue innovative solutions that help achieve various goals such as waste to energy and micronuclear. Comment: The traditional approach to `Waste to Energy', the burning of waste, creates more greenhouse gas per KWh of electricity produced than does burning coal. The elimination of landfills diminishes Methane release to varying degrees depending on landfill technique, which may compensate for the combustion emissions. P 15. Fire risk reduction around communities potentially limits fire spreading into upland areas, reducing fire driven forest loss. Comment: The firebreak/fuel break perimeter management around communities works both ways for the good of community and environment. Water supply to these perimeter lands must be ensured to support grazing or agriculture or community gardens and, in case of fire, the assurance of firefighting potential. P. 17. Support the achievement of 70 percent renewable energy for the electricity sector by 2030, with 40 percent from renewables and 30 percent from efficiency, and 100 precent by 2045. Comment: The language here is misleading. If one is advocating for 70% of electricity generation from renewable energy, that is contrary to 40% of generation is from renewables and there has been a 30% gain in efficiency. Please explain the meaning of this directive. Is this merely a rationalization for failure to meet a 70% renewables goal by 2030. P. 20. Adopt a land acquisition program with potential leaseback options for the purchase of hazard-prone locations or those with beneficial attributes for climate adaptation or mitigation. Comment: This is not something that the public will bear. This feels like collusion between corporate or wealthy land owners and Administration. This is a directive which must be taken to the public in the form of a referendum before it is placed in the General Plan. This certainly would be reason for the County Council to defer ratification of the Draft General Plan. Proposals with this level of controversy should not be placed in the General Plan until they are taken to the people by referendum or, at least, the County Council. SUSTAINABLE GROWTH AND RESILIENT COMMUNITIES P24. Over the next 25 years, the population growth rate is expected to decline from an average of 2.3% per annum to about 0.9% per annum. In 2045 the resident population is forecast to be approximately 273,000 which is a 35% increase over 2018. Comment: Please explain the reason for this decline in population growth rate.. P. 24. About 90% of growth on average is through immigration. Comment: Many people have concern that 90% of growth is from immigration. That concern rises to the level that many people feel that growth is not a good thing but in fact is damaging to the environment and our social structure. The proposal that Affordable housing permits and inspection should always be placed at the head of the queue of projects in the Building Division might help somewhat. Growth in housing development other than affordable housing or housing for heritage residents should be discouraged, and domestic agriculture should be emphasized for the purpose of resiliency. P. 24. In 2018, 67,000 Hawaii State residents moved to the mainland; they were partially replaced by 54,000 mainlanders who moved to the State for a net out migration from Hawaii of 13,000. Comment: This problem might be improved by improving the attractiveness to the Developers of building Affordable Housing with modest discouragement toward building upscale homes. This might be accomplished by moving all Affordable projects to the head of the queue for permit review and building inspection. P. 24. The population over age 65 is expected to grow to 44% by the year 2045. In 2020, the largest cohort of the population was between the ages of 60 to 69. Comment: All of the above statistics need illumination. The domination of this population age cohort seems unworkable. The influx of retirement age immigrants is a challenge to our societal structure. P24 The number of transient accommodation rental units is beginning to trend higher than hotel units that once dominated the visitor accommodation industry. There is also a shift in the type of visitors away from the major resort areas, which may put stress on the environment of other areas. Comment: All efforts to limit the proliferation of STVRs should be supported. Visitor Accommodations Tax needs to be applied to all STVR rentals. Visitor Accommodations Tax needs to be dramatically increased. P. 26. Remove barriers to residential development in the appropriate districts to reduce development timelines, increase housing stock availability and increase affordability. Comment: Yes, this is one approach, assuming that one is trying to accelerate residential development. Perhaps one needs to start by making the case for accelerating residential development. This is not a `given'. It is a `given' that we need more housing for our heritage residents, but it seems that a preponderance of development housing actually goes to immigrants. The County, for probably excellent reasons, seems unable to solve this problem, and so, as much as we build, build, build... there are still the same number of heritage residents who seem to have to move to the mainland to find work and housing that are more practical. Consequently I don't think that the assumption should be made that we need to remove barriers to residential development. Second, how is it determined which are the appropriate `districts' for development. Changes in Urban Growth Boundaries must be clearly delineated for the public. One must respect expertise in determining where growth is appropriate, but the expression of the will of the public in and near those targeted areas is of importance to understand. It should be required that referendum or polling of residents in and near the targeted growth areas, or at least a `targeted' presentation to those residents would be made in the process of determining the desirability of growth in that area. After all, are we talking about the Planning Department's desire, or the desire of the residents of that area? Undoubtedly, the ultimate application will be a reflection of both. But a mailer to each post office box or address in the affected area, with a careful inquiry into the desires of the area residents, should be a part of the process. The General Plan Land Use Map should not be completed until such an inquiry with the public has been completed. P. 26. Review and update the Building and Zoning Codes to allow for more flexibility Comment: Please give examples of where more flexibility would be desirable. Please indicate the basic problem that is being approached by increasing flexibility, and explain how that flexibility will yield improvement in that problem. P. 26 Collaborate across State and County agencies to facilitate efficient and effective land use processes Comment: Collaboration is always desirable. Please describe what is currently the impediment to collaboration. P. 26. Advocate allowing for County initiated State Land Use Commission District Boundary Amendments to meet the preferred land use pattern. Comment: I will infer from this proposal that currently Land Use District Boundary Amendments are a function prescribed to the State. This makes sense since the natural tendency toward urban expansion meets interface with Lands subject to Department of Agriculture and DLNR oversight. I would be surprised if there is not capability of urban planners and the County to make their wishes known and advocate for those designs within the current State Authority. However it seems entirely appropriate that, consequent to communication and collaboration between the State Commission and the County that the State Commission would take responsibility for initiating District Boundary Amendments to be considered by their Commission. It seems that this procedural proposal runs counter to reasonable administrative divisions. P 26 Program the initiation of rezoning in targeted growth areas. Comment: This of course demands identification of the targeted growth areas to begin with. And, of course, that targeted growth area needs to be identified to residents living within and nearby its boundaries. Please specify with map identification where these targeted growth areas are at. Programming the rezoning in these areas might well be a proposal which should be preceded by referendum or public study of sentiment or reaction to this proposal. Media identification of these areas with open discussion should be encouraged before programming the initiation of rezoning. P 28. Develop a process for County initiated State Land Use boundary reclassification. Comment: This, I believe is a State Commission responsibility. If it is County's impression that the State Commission is failing its responsibility then please point out where those failures have occurred. P 28 Amend the Zoning Code and Subdivision Code to allow Cluster Plan Developments to be applied to all zoning districts with appropriate building site standards. Comment: Please explain in detail the meaning of this directive. Explain what is a Cluster Plan Development. Explain why such a development cannot now be applied to all zoning districts with appropriate building site standards. Please explain what is special about Cluster Plan Developments that would argue that they should be allowed in any zoning district whereas a run-of-the-mill development might not be allowed in some zoning districts. P29 Amend the Zoning Code to allow for Planned Unit Development to become administrative permits and subject to the approval of the Planning Director Comment: There might be a reaction to this Draft General Plan that the thrust is toward acceleration of the process of development. With that perspective, and less than unanimity in endorsement by the public of this perspective, it would be most desirable that there would be County Council oversight applied to the enthusiasm of the Planning Department for all significant development, whether Planned Unit Developments or any other category of Development. If it is felt that the public would be supportive of this proposal then it should be subject to referendum rather than placed in the General Plan. P 59. Support the development of small scale visitor accommodations with heritage, agriculture, wellness or similar themes in rural areas and near points of interest. Comment: All public support for short term visitor rental accommodation should be removed other than in designated resort areas. P. 59. Provide flexibility in discretionary permit applications to maintain health and safety for rural small scale visitor accommodations not serviced by public infrastructure. Comment: All public support for short term visitor rental accommodations outside of resort areas should be removed. P. 59. Amend the Zoning Code definition and requirements for Lodges and reconcile similarities and inconsistencies with the special permit provision for Retreats. Clearly articulate in the Code the zoning districts appropriate for Lodges. Comment: Please specify the referred to definitions and differences between Lodges and Retreats P. 59. Amend the zoning district's currently listed as Family Agricultural District and Residential and Agricultural District to be consistent with the Rural designation and to allow for home occupations that do not negatively impact the rural character. Comment: Please explain how the Zoning district currently listed as Family Agricultural District and Residential &Agricultural District are currently inconsistent with Rural designation. Please explain the impacts of such proposed amendment on the living, building and occupational patterns in those various agricultural districts. If no impact, please state as such. P59. Amend the Zoning Code and Subdivision Code to establish Clustered Rural Subdivision PUD Comment: Please define Clustered Rural Subdivision PUD. Please explain how it would be treated differently than any other subdivision in the Zoning and Subdivision Code. ROADWAYS P. 79. Allow for private, non-dedicated cul=de=sac and alley designs that are in accordance with national road standards. Comment: The County should enact ordinances or policies that discourage the building of gated community roadways, even if the gated roadways are privately constructed. Such gated roadways only increase the sense of division in society at a time when blending those divisions has taken on much importance. Removal from the Highways section of the 2005 General Plan the following: 13.2.5.4.2 Courses of Action (C) Encourage the State to construct a scenic highway from the Waipio Valley look-out extending Mauka to connect to Mud Lane at the entrance of Waimea. Removal from the Recreation section of the 2005 General Plan the following: 12.5.4.2 Courses of Action (D) Encourage the State to develop a scenic park on the Kohala side of Hiilawe Falls in conjunction with the development of the scenic highway. Comment: Please explain the rationale for removing the above two directives of the 2005 General Plan from inclusion in the Draft General Plan 2045.