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Bonnie Goodell 4 eoe-~~-ins ~13I7I01 y1 33 PM '?3I10 Bocrtve Goodell Borwe Btssen/Sisstainabiliry Committee re GP DRAFT & Zoning March S, 2001 agnculture, and mined use This misrepresentation of land uses violates both the directions for use of the TraztPlan computer model and federal planning requirements The Federal Highway Administration investigated our complaznt and found that all our allegations were supported They were very specific A complete copy of the Federal Investtgattve Findings may be found on my websrte, www bonmegoodell.com I strongly suggest that you download a copy of the Investtgattve Findings and read them very carefully The local consultant providtng the land use and population data for the HL.RLTP, from 1993 until 1998, was Mr VPilliam Moore, who all dunng that time was also employed by W H. Shipman to plan for its development around Keaau. and to obtazn W H Shipman's Boundary Amendment from the Land Use Commission. I personally made testimony to the Land Use Commission, the Department of Education, and through numerous memos to the County Planning Department (as lead consultant for the Puna Community Development Plan) from 1992 on, that the misrepresentation of land uses for the small-owner subdtr tstons, and the associated failure to provide services and correct land use analyses, was a violaUoa of them tights I also alleged, and still mazntazn, that the residents and landowners of those subdivisions have been and are being substantially harmed by that misrepresentation and by the associated fazlure to provide fair treatment in all county and state services, including at least planning, water souroe development, transpoRaUon, schools, police, fire protection, parks, and access to federal azd, such as from FEhlA, HUD, and USDA Correcting this land use misrepresentation and disparity in services has tmphcations for the all land use decisions on the Btg Island. For instance, m the County General Plan, Urban Expansion Areas, such as the one around Keaau, have been justified by land rue analyses which purport to show that there is iasuffictent area of urban land to support what would be needed for anticipated future growth. Obviously it would be impossible to reach the conclusion that Puna needed additional urban lands if the land uses rn the existiag subdivisions were not misrepresented You can find maps illustrating what I mean on my website, on the page explaining the civil tights complaznt about the HL.RLTP The Sustatnability Committee and I, personally, have already communicated with Mr Hayashi, at the beginning of the review process, to clanfy how the General Plan is the basis of the dtscnminatton Therefore, I have attached copies of those communications. My website also contains a Level of Services Study which I suggest be compared with all the facilities maps and facilities elements is the existing and DRAFT General Plan