Loading...
HomeMy WebLinkAboutCommunication No. 2018-03- Hawaii Island Community Development Corporation CDP Amendment TestimonyHAWAII ISLAND COMMUNITY DEVELOPMENT CORPORATION 100 PAUAHI STREET, SUITE 2014 - HILO, HAWAII 96720 February 12, 2018 Mr. Michael Yee Planning Director 101 Pauahi Street Suite 3 Hilo, Hawaii 96720 Subject: Comments on Kona CDP After reviewing the proposed changes to the Koan CDP policies we offer the following comments in the interest of producing more affordable housing for the Kona community: Policy HSG-4.1: Public Lands Therefore, public housing projects and projects using public lands or financing shall devote a significant percentage of the residential units to meeting the needs of middle-income renters (50 to 100% of median income) and lower-income households (less than 50% of median) Comment: This policy is vague in how much is to be required but presumably it is a large percentafe that would not fit all programs. Workforce housing could be built on the large State of Hawaii holdings north of Palani Road but would be hampered by an across the board requiremnet that each project include low and very low income housing. The policy could say that a range of resident oriented housing should be included in planning the use of public lands. Policy HSG-4.3: Affordable Housing Floating Zone If 100% afforable, the project in concurrence with the Design Center may preempt the planning standards pursuant to HRS Section 46-15. Comment: If a projects meets the criteria for a Housing Floating Zone and is 100% affordable does this policy mean that it must meet the with concurrence from the Design Center to allow design requrements to be pre-empted under 46-15 HRS? I'm not sure if it is the intent to give veto power to the Design Center, that would be inappropriate. Policy HSG-5.1 Perpetually Affordable Units Public Agencies and non-profits that develop or own affordable housing units shall utlilize methods, such as leasing or controlled appreciaiton, to ensure that sales prices of these units remain perpetually affordable. Comment: Long term affordability is desirable but to say that it should be forever is not helpful. HICDC has developed low income housing on land leased from private parties. Such sites would not be available if the requireent is that the land can only be used for affordable housing - forever. The practical result would be to reduce affordable housing production. Policy HSG-5.2 Privately Constructed Affordable Units: All affordable units shall remain affordable for 40 years. Comment: This policymay well reduce the number of housing units produced including afforable units. It is well beyond what the housing m arket has faced up to now. The economics of housing requirements and credits is very complex, to have aspirational statements codified without solid analysis is quite dangerous and could result in the opposite effect. For example, years ago the state required that all new housing projects going thoruhgh the LUC have 60% afforable housing. I believe the total production under those requiremnts was zero, the requirements were then reduced and housing production commenced. The initial policy resulted in years of non-production until the requiremnte were reduced to a feasible level. Policy HSG-5.3 Redevelopemnt Shall Not DisplaceAffordable Units. Where there are concentrations of exisitng affordabunits, redevelopment plans or projects shall ensure that units comparable in number and affordability to the existing units are provided in the new project, with priorit given to displaced residents to purchase or rent. Comment: Where there are existng affordable units the cost basis is almost assuredly low, much lower than the cost of new construction. To have the newly constructed units be as affordable as the old units will requre large subsidies such as Project Based Section 8 voucers which are very limited. urther, for those households with income above 50% AMI such vouchers are unavailable. The intent of maintain the afforable housing supply is good but to make it absolute will be counter productive. HOUSING POLICY PROPOSAL It would be most useful if the Housing Section state that providing the necessary backbone infrastructure for futuure residential growth areas is a critival function that only governemnet can provide and should provide. The lack of infrastructure is the largest impediment to developing land for housing. The county needs to take the lead in seeing that the designated residential areas are developed thruogh infrastructure expansion and appropriate zoning. Within that context the economics of affordable housing are more favorable. Policy LU-2.8.2.b.ii "Greenfields" Rezoning for an affordable housing project should not require a Kona CDP Amendment. ffordable housing projects smaller than 20 acres can be successfully developed utilizng the 201H exemption process which is meant to expeditie the processing and approval of affordable housing projects. Requiring a CDP amendment would be contrary to the purpose. Policy-LU-4.2: Mandatory Review. For affordable projects the Design Center review can be part of the normal process of reviewing 201H exemption proposals. To require that hte Design Center review and make recommendations prior to submission will lengthen the process and be contrart to 201H's ntent of expediting the review process. Policy PUB-4.1: Water for TODs should similarly include water for affordable housing. This is an essential element in initiating an affordable housing project. Policy PUB 4.6 Wastewater Treatment and Effluent Reuse. The near term need for sewage treatment capacity for lands north of Hina Lani should be recognized and explicitly provided for at the Kealakehe STP if DEM deems it appropriate. Policy PUB-7.3 Recruitment Incentives. Giving high priority to government workers amy not be allowed depending on the financing sources. The last sentence should be modified by adding "to the extent allowable" somewhere. Thank you for the opportunity to comment on the Kona CDP Sincerely, [signed] Keith Kato Executive Director