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Clearly, the Court has stated that if a regulation denies a landowner "aCl economically beneficial or productive use" of the property, then a taking exists requiring just compensation.° Parcel As A /hole In determining the economic impact of government action on real property, courts look at the "parcel as a whole.i5 Therefore, if a landowner is deprived of use of part of her land, but retatns use over the remainder, it will not be considered a taking. Thts approach was affirmed recently by the Supreme Court in Tahoe-Sierra v. Tahoe Re,~tonal Planning Agency, No 00-1167 (April 23, 2002). The Court stated that an owner of a 10-acre parcel subject to a restriction on a steep slope development affecting only two acres could not bring a taking claim focusing only on two acres. Legitimate Government Interest Briefly, a land use regulation will not constitute a taking if the regulation does not deny a landowner all vtable economic use and the regulatton substanttally advances a "legitimate government interest."G The Supreme Court has made clear that the government has a legitimate interest in protecting undeveloped areas from the "ill effects of urbanization."' Clearly, the Council has a legitimate government interest in designating parts of Hawaii's coastline as conservation areas. In the Tahoe case, the Court noted that the government acrivity in question created "a comprehensive plan to protect the natural resources that made [Lake Tahoe] a desirable place to invest in the first place, increasing property values for all." This decision is important, especially in comparison with some other recent Supreme Court decisions, because of the importance the Court assigned to the goals of land use planning and regulation. The Court defers to the "consensus of the planning community," and expressed its support for the objective of reining in "inefficient and ill-conceived growth." Ripeness Takings claims can only be brought after a governmental action has occurred that results in a "taking." The Supreme Court has ruled that a landowner may not file a takings claim until all administrative remedies have been exhausted. It is well settled that a takings claim is premature where the claimant has not submitted a plan or applicarion to the governing body whose approval is requtred.s a Lucas v. South Carolina Coastal Council, 505 U.S. 1003, 1015 (1992) (emphasis added). s Penn Central Tran~ortation ('o v City of New York, 438 LJ.S. 104, 130 (1978). ~ Nollw v. California Coastal Comm'n, 483 i J.S. 825, 834 (citing Agins v. Tiburon, 447 U.S. at 260). :mains, 447 U.S. at 261; see also V11~3ge of Euclid v. Ambler Realty Co., 272 LL S. 365 (1926) (legitimate government interest in zoning certain areas for residential use only). s Awns v. Tiburon, 447 U.S. 255, 261 (1980).