Simplify parking and ventilation rules on adaptive-reuse projects

The following testimony was submitted by the Grassroot Institute of Hawaii for consideration by the Honolulu City Council Committee on Housing, Health and Sustainability on Nov. 20, 2024.
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Nov. 20, 2024, 2:30 p.m.
Honolulu Hale

To: Honolulu City Council Committee on Housing, Health and Sustainability
       Matt Weyer, Chair
       Esther Kiaʻāina, Vice Chair

From: Grassroot Institute of Hawaii

             Malia Hill, Policy Director

RE: Bill 51 (2024) — RELATING TO ADAPTIVE REUSE

Aloha Chair Weyer, Vice-Chair Kiaʻāina and other members of the Committee,

The Grassroot Institute of Hawaii supports — and offers amendments to — Bill 51 (2024), CD1, which would amend county ordinances to allow for the adaptive reuse of existing commercial buildings.

Converting non-residential structures to residential use is an innovative way to boost Hawaii’s housing stock and foster the creation of vibrant, walkable communities, as discussed in the Grassroot Institute’s policy report “How to facilitate more homebuilding in Hawaii.”[1]

Unfortunately, many adaptive-reuse projects are frustrated by regulations that make it difficult or prohibitively expensive to refit commercial buildings for residential use, such as window or ventilation requirements.

Carving out an alternate approach to current ordinances on light and ventilation would help facilitate adaptive reuse on Oahu. It also would help meet the state’s Act 37 requirement that the counties adopt or amend existing ordinances to allow for adaptive reuse by the end of this year.

As for the proposed amendments, Grassroot suggests clarifying how the parking mandates would apply to projects retrofitted under the bill.

Current city ordinance does not impose a parking mandate for projects in Primary Urban Center Development Plan or Ewa Development Plan areas unless the projects are built in the residential, agricultural and preservation zoning districts.[2]

In paragraph 1 of Councilmember Matt Weyer’s CD2 amendment, the bill does provide that, “The retrofitting or repurposing shall be exempt from park dedication and additional off-street parking requirements; provided that (A) The number of the building’s existing off-street parking spaces satisfies at least fifty per cent of the city’s off-street parking requirement; and (B) The building’s floor area, height, and setbacks do not change as a result of adaptive reuse, except when providing outdoor amenities for the residential use or activating the street frontage of ground floor commercial area.”

The inclusion of these stipulations might be interpreted as an exemption to the general rule of no parking mandates in the areas mentioned above, and thus would frustrate the Council’s past efforts to reduce parking requirements.

It also could be costly for adaptive-reuse projects. The Ulupono Initiative has estimated that each parking space imposes between $53,000 and $57,000 in costs on commercial developments in Honolulu,[3] driving up housing costs as a result.

Grassroot recommends removing paragraph (A) to provide clarity that such projects do not need to provide additional parking spaces — no matter where on the island they are located.

Likewise, there is ambiguity in the word “effects” in section 7, which states: “Any purchase or rental agreement for a dwelling unit reliant on mechanical ventilation shall include notice to the purchaser or renter of the potential effects to the unit and its occupants should the mechanical ventilation fail.”

We recommend replacing this section with the following language: “(7) Any purchase or rental agreement for a dwelling unit reliant on mechanical ventilation shall include notice that the unit is mechanically ventilated with non-openable windows.”

Thank you for the opportunity to testify.

Malia Hill
Policy Director
Grassroot Institute of Hawaii
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[1] Jonathan Helton, “How to facilitate more homebuilding in Hawaii,” Grassroot Institute of Hawaii, December 2023.
[2] § 21-6.20 Off-street parking requirements., Revised Ordinances of Honolulu, accessed  Nov. 19, 2024.
[3] “The Costs of Parking in Hawai‘i,” prepared by PBR & Associates for the Ulupono Initiative, August 2020, p. 3.

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