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in the Planning Commission's letter of October 19, 2001. Hopefully the Planning <br /> Committee will give attention to those changes suggested by the Planning Commission <br /> that were not adopted by the Planning Director in this letter In response dated November <br /> 30, 2002. <br /> • We have concerns with the proposed County Conservation Designation in regard to <br /> Regulatory Taking Issues, particularly H-1, South Kona-1, proposed to be changed from <br /> Extensive Ag to County Conservation. <br /> • In regard to the designation of Important Ag Lands (IAL) we have two comments. In <br /> general we believe these designations should reflect either current agricultural activity or <br /> realistic future agricultural activity. To the degree that we designate IAL for other <br /> purposes such as open space, conservation, etc., it only dilutes the category. It also <br /> dilutes the category when we overly designated IAL to virtually render the classification <br /> meaningless, as is the current state today. To put these Ag designations in some <br /> perspective, the following State Department of Agriculture data is lnteresung <br /> At the height of both sugar and pineapple production in the State, their combined <br /> acreage totaled about 325,000 acres. <br /> More recently..- <br /> • For Oahu, total acreage in crop went from 23,300 in 1997 to 19,300 in 2001 <br /> - a decrease of 4,000 acres. Within this, pineapple went up 200, but other <br /> (diversified) crops went down 4,200 acres. Oahu has about 130,000 acres <br /> classified/zoned for agnculture. <br /> • For Maui County, total acreage in crop went from 55,600 in 1997 to 48,100 <br /> in 2001 - a decrease of 7,500 acres. Within this, sugar went down 7,700 <br /> acres, pineapple stayed constant, and other (diversified) crops went up 200 <br /> acres. Maui has about 400,000 acres classified/zoned for agriculture. <br /> • For Kauai, total acreage in crop went from 28,100 in 1997 to 12,800 in 2001 <br /> - a decrease of 15,300 acres. Within this, sugar went down 15,000 acres <br /> and other (diversified) crops went dawn 300 acres. Kauai has about 140,000 <br /> acres classified/zoned for agriculture. <br /> • For the Big Island, total acreage in crop stayed constant at 11,900 acres in <br /> 1997 and 2001, all attributable to other (diversified) crops. This does not <br /> include plantation forestry. Hawaii has about 1,200,000 acres <br /> classified/zoned for agriculture. <br /> • Statewide, total acreage in crop went from 143,600 in 19997 to 114,700 in <br /> 2001 - a decrease of 28,900 acres. Within this total, sugar went down <br /> 22,700 acres, pineapple went up to 200 [same as Oahu], but other <br /> (diversified) crops went down 6,400 acres. Statewide, there are about <br /> 1,930,000 acres classified/zoned for agriculture. The current General Plan <br /> proposes placing 386,283 acres in the IAL category. <br /> <br /> • Specifically we disagree with the following proposed IAL designations. <br /> Hamakua-1: The IAL district should fall below the Hamakua Ditch System. <br /> North Kohala-1: The IAL district should fall below the Kohala Ditch System <br /> S. Kohala-1: The IAL district should fall above the Kohala Mountain road above the <br /> Hawaii Preparatory Academy and should follow the rainfall belt closer to Waimea <br /> town in the Pu'ukapu region. <br /> S. Kohala-4: The IAL designation should not include the Mauka Waikoloa, Keamoku <br /> and Waiki'i lands as they do not have sufficient rainfall nor could they be <br /> economically irrigated. <br /> N. Kona Z; N. Kona-3; N. Kona-4; 5. Kona-1: Mauka lands above the coffee belt <br /> and not otherwise suited for agriculture such as the Kaloko Lands (valuable <br /> watershed) should be deleted from proposed IAL <br /> N. Kona-4; S. Kona-1: The makai lands below the coffee belt (rainfall Ime) should <br /> be eliminated from the proposed IAL <br /> Page 2 of <br /> <br />