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GOODSILL ANDERSON QU1NN St Sr1Fe1. <br /> A Llhlil'[D LIABIllTY LAW PAR"INERSHIP LLP <br /> <br /> Honorable Bobby Jean Leithead-Todd, Chair <br /> <br /> April 17, 2003 <br /> <br /> Page 4 <br /> <br /> not rated as "Prime" or "Unique" under the ALISH classification system referred to in <br /> Criteria 2; the Properties consist of Class D and E "Poor" and "Very Poor" under the <br /> Land Study Bureau's Soil Survey Report referred to in Criteria 3; and t:he Properties do <br /> not fit within Criteria 5 or 6. In addition, the average rainfall on the Properties is less <br /> than 20 inches annually, and has an average pan evaporation rate of approximately 70 to <br /> 80 inches annually, which means that the Properties have a 50 to 60 inch annual motsture <br /> deficit, before taking into account any crop requirements. The nearest public irrigation <br /> system is the State's Waimea Imgation System which is over 6 miles away, and while <br /> Waikoloa Water Co., Inc. provides water to the Waikoloa Village, (a) its nearest <br /> pipelines end 3-4 miles from the bottom of the Properties and 5-G miles from the top of <br /> the Properties, and (b) even if such pipelines existed, Waikoloa Water Co.'s wells do not <br /> have sufficient water capacity, and its pumps do not have sufficient pumping capacity, to <br /> provide irrigation water to the Properties. According to Steve Skipper of the USDA. <br /> Natural Resource Conservation Service field office in Kamuela, the area is fire prone, is <br /> arid, is subject to strong winds and has a savatuta-type ecosystem. In terms of <br /> agricultural use, because of their topography, climate, location and soils and lack of <br /> viable water, the Properties are at best suitable only for grazing purposes. In fact the <br /> ?ands in question are subject to a grazing license in favor of Parker Ranch, but because of <br /> the extreme conditions of the Property, in recent years there has been insufficient grass <br /> for cattle grazing, and Parker Ranch's actual use of the Properties has been minimal. For <br /> all of these reasons, we believe drat under both the present and proposed land <br /> classifications, the Properties more properly belong to the Extensive Agriculture <br /> classification, than either the Intensive Agriculture or proposed Important Agricultural <br /> Land classification. <br /> Nonetheless, because the Properties currently are designated Intensive <br /> Agriculture, it appears that they have been earmarked for designation as Important <br /> Agricultural Land. We submit that because the current designation does not take into <br /> account the Properties' potential for sustained agricultural yields (or in this case the lack <br /> thereof), it would be inappropriate and unreasonable to designate the Properties as <br /> Important Agricultural Land. <br /> Finally, the proposed General Plan recognizes that "some areas that meet <br /> the criteria for important agricultural lands on an irrigated basis only [are] included in the <br /> "Extensive Agricultural Land" category due to their remoteness from potential sc;.. ces of <br /> irrigation: ' In addition to the reasons aforesaid, we believe that based on this rationale, it <br /> Ol0-d 90/SO d 910-1 0999lYS809+ NOS830NY 11150009-mo~j Yl~9f t0-ll-~dtl <br /> <br />