I would tighten it considerably. The substance is strong, but the opening repeats points that appear again later. For Granicus testimony, I would make it read as one continuous argument and keep the central question unmistakable.

**Subject: Bill 108 — Infrastructure Capacity and Implementation**

Chair and Members of DRIP:

At this point in your review of Bill 108, I have one basic question:

**What happens when the Growth Framework allows additional development, but the infrastructure necessary to support that development has not been completed?**

Before advancing Bill 108, direct Planning and the responsible departments to establish the baseline infrastructure capacity for South Maui.

Determine what capacity exists, what is already being used, what is committed to approved development, what reserve capacity is necessary, and what actually remains.

Then compare that remaining capacity with the additional growth contemplated by this plan.

Where a deficiency exists, identify the infrastructure improvement required, its estimated cost, the funding source, the responsible agency, and the completion schedule.

Then ask Corporation Counsel what legal mechanism is necessary to prevent development from exceeding adopted capacity standards.

The County already has the departments. You already have planners, engineers and financial staff. You already have a Plan Implementation Division, a Capital Improvement Program, and implementation reporting.

You do not need another committee or another twenty-year study. You need to connect the systems you already have.

Section 4 provides for performance indicators, benchmarks, implementation schedules, priorities, responsible agencies, estimated costs and potential funding sources.

But identifying, monitoring and reporting a problem is not the same as solving it.

A project can be designated “high priority” and still not be built. An infrastructure improvement can appear in a twenty-year plan without being funded. A benchmark can identify inadequate capacity without requiring anything to change.

**That is the gap.**

Establish measurable capacity or performance standards for water, wastewater, roads, drainage, evacuation, fire and emergency services, and other critical infrastructure.

If additional development would exceed an adopted standard, the infrastructure necessary to support that development should be funded and scheduled to be available before or concurrently with the additional demand.

The same principle should apply to monitoring. Do not adopt the plan and decide later what success means. Establish the important benchmarks now. Tell the public what will be measured, when it will be measured, and what happens when a standard is not met.

The plan itself acknowledges that ambiguity in previous planning contributed to problems that remain unresolved. Do not repeat that mistake with another twenty-year plan.

And this should not be left to residents to figure out.

Residents should not need Dick Mayer to calculate implementation costs. They should not need attorneys representing property owners to explain what individual policies mean. They should not have to reconstruct hundreds of pages of maps, amendments and technical documents to understand what their government is proposing.

County government has the professional resources to provide that information.

**Use them.**

Before advancing Bill 108, answer these questions in plain language:

**What infrastructure is required? What capacity exists today? What is already committed? What needs to be built? What will it cost? Who pays for it? When will it be completed? And what happens to additional development if the necessary infrastructure is not completed?**

If Bill 108 cannot answer that last question, then its implementation framework is incomplete.

Measure the capacity. Establish the standards. Identify and fund the necessary infrastructure. Then allow growth within what South Maui can actually support.

Edward Codelia
Maui Resident