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GooDSUt ANDERSON QuuvN ~ STIFEL <br /> A UM:rp Un6n,~n Lnw PA R71`1ERSHm LLP <br /> Honorable Bobby Jean Leithead-Todd, Chair <br /> <br /> April 17, 2003 <br /> <br /> Page 2 <br /> General Discussion regarding the Criteria for Izr~,ortant A~icultural Land <br /> We understand that the proposed revisions to the General Plan would <br /> eliminate the "Intensive Agriculture" classification and in its place create a designation of <br /> "Important Agricultural Land". Under the proposed revisions, "lmportant Agricultural <br /> Lands" are defined as those lands with "better potential for sustained high agricultural <br /> yields because of soil type, climate, topography, or other factors." The proposed <br /> revisions state that Important Agricultural Lands will be determined by including the <br /> following lands: <br /> 1. Lands identified as "Lntensive Agriculture" on the 1989 General Plan <br /> Land Use Pattern Allocation Guide maps. <br /> 2. Lands identified in the Agricultural Lands of Importance to the State of <br /> Hawaii (ALISH) classification system as "Prime" or "Unique". <br /> 3. Lands classified by the Land Study Bureau's Soil Survey Report as <br /> Class B "Good" soils. (There are no Class A lands on the island of <br /> Hawaii). <br /> 4. Lands classified as at least "fair" for two or more crops, on an irrigated <br /> basis, by the USDA Natural Resource Conservation Service's study of <br /> suitability for various crops. <br /> 5. In North and South Kona, the "coffee belt", a continuous band defined <br /> by elevation, according to input from area farmers. ' <br /> 6. State agricultural parks (These Six items are hereafter referred to as <br /> "Criteria"). <br /> For the following reasons, (1) WLCI and its affiliates oppose the automatic <br /> inclusion of lands as Important Agricultural Land merely because it meets Criteria 1, and. <br /> (2) WLCI and its affiliates oppose the use of Criteria 2, 3, and 4 as the sole basis for <br /> classifying Lands as Important Agricultural Land without also considering additional <br /> factors, such as water availability, topography and climate. <br /> 1. With respect to Criteria 1, rather than assuming that all lands <br /> currently identified as "Intensive Agriculture" on the 1989 Genera] Plan should be <br /> included under "Important Agricultural Land", those lands should be evaluated to <br /> 810-d 90/80 d 910-1 0895!95908+ N05830Ntl 11150007-WO~d E1~91 EO-ll-~dtl <br /> <br />