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Page Two important standard under Irarportant Agricultural Lands (page 345), which uses lands classified as at least "fair" for two or more crops, on an irrigated basis.... is an unrealistic standard in many areas. The Bost of providing Ag water on many parts of the island, especially in ~'~est l-Iawaii, is economically prohibitive. The definition of Extensive Agricultural Land (page 34t?9: "Lrrnclc rrot classified as Imp®rtarrt Agricultural Land. Includes lands tltat are not capable of proclur•in~ust~rined, Izigh agricultural Yields with®art the intensive applicati®n of modern ~rrnira~ rraethods urrd teclurolo ies due to certaiar plrysiea! constradnts such as soil composition, slope mac/tine tillabilits• and clisrrate~. ®tJter less intensive agricultural uses such as grazing and pasture may be ine[rrclerl irr Nre Frterrsi?•e A~ricudtural land category" seems to more accurately describes much of the land placed in the Important Ag Land category. The lands proposed to be placed into the "important" Ag category in the current DRAFT totals almost 400,000 acres. fio put this in some perspective, the titate Department of Agriculture estimated in 1993 that all of the fresh fruits and vegetables consumed in the state could be grown on 18,000 acres, assuming only one crop per year. For various reasons. certain crops can't be grown in Hawaii, and because we grow multiple crops per year, our actual land needs for local consumption is considerably less. Production costs were not considered. e hope to expand and develop export markets, especially for high value tropical fruits and other orchard crops, but our overall agricultural land needs are actually small compared to the total acreage available. And in regard to Big Island production, we have to keep in mind the competition from other islands, particularly Oahu, which also has thousands of acres of former plantation lands, as well as 80% of the State population and markets. Lastly, we would like to address the proposed down-zoning of various shoreline parcels in VI~'est Hawaii. While certain landowners support or at least go along with some of the suggested changes in General Plan designation, others do not. We need to ask the following: 1. Are the proposed changes consistent with existing State and Regional plans:' 2. Have the affected landowners been directly contacted in regard to the proposed changes? 3. Has the County made a serious effort to discuss all options to mitigate their concerns short of a General Plan re-designation? 4. Ilas the current level of development interest and activity been taken into consideration in making these recommendations? 5. Have the legal consequences and County liability potentially created by the proposed changes been fully researched -specifically "due process", "equal protection", and "takings" issues? These are important process issues, which need to be thoroughly addressed. In a larger context, while we'd also like to point out that while the current level of development in West Hawaii is substantial, an important facet of this development is the predominant nature of Resort-Residential emphasis versus Resort growth. In effect, the current wave of development is substantially under building in the context of what was previously approved for mane of these sites. Rather than hotels, part time resort residential developments are occurring, which will HAWAII LEEWARD PLANNING CONFERENCE P 0. BO% 2159 KAMUEU. HAWAII 96743-2159 TEl ;808) 885-9588 FA% (808) 885-9590 EMAIL: HIPC@GTE.NET