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C~ vh m e n-~5 ~Un'L VJ elf G~c~ Y~l. December 3, 2003 ~ ~l ~ ~ '1'O: JoAnn FROM: Bob RL: Comments on IAL Standards and Criteria (S&C) I do think that regardless of the final list of S&C for identifying IAL, there should be enough flexibility therein for the individual counties to determine what is the most important agricultural land for their needs. The identification of IAL should be as much about memorializing what is in agricultural production as it is looking to the firtw~e to accommodate new agricultural pursuits and operations. More so in Hawaii than other areas of the country, agriculture in the future will likely be defined more by what it can or will be than what it once was. The designation of IAI, therefore, must look forward and anticipate opportunities while avoiding the risk of being too inclusive so as to make the designation process meaningless. My assumption has always been that designation of IAL will not only create a target for incentives but will also establish disincentives and regulations related to any non-agricultural activities. In reviewing the items listed in Draft 2, I have these comments: • If I understand ALISH correctly, then #s 2&3 are essentially the same. Here is where the unique needs of each county and sub-county area can come out. If ALISH can acconunodate such local features and needs, then sticking to one system will make some sense. • #5 is of course very important. But what of the potential for new water systems? Since water systems can be built on to the landscape, unless there are prohibitively expensive features in the way of new construction (i.e.: mountain range, great distance from source), then a process for acknowledging the potential for new or upgraded water systems may be in order. • #6. It is my understanding that not all the counties have done a good job of taking agriculture into account in their general and community plans. If this is the case, then making consistency with the County plans a standard for IAL could be problematic. • There is some redundancy in #s 7&9. If you identify land to meet #7, you are probably accommodating #9. • On the criterion and its alternative relating to lands for ancillary purposes (i.e.: wastewater use, open space, etc.), I think that one of the issues in Hawaii is there is so much land currently designated for agriculture that some detractors see the designation as meaningless. I can certainly understand the concerns of some that the current Ag designation provides some protection for lands with environmental values besides or beyond agriculture and opening up the designation process may leave some of these lands vulnerable. However in refining the designation of ' IAL I think it is critical to be discriminating and avoid the temptation to include lands that are not agricultural but may indeed be important for some other environmental purpose. 1