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Pagc 2 of 3 <br /> <br /> Take Holualoa Kona Coffee Co. as a case in point. All of that firm's 12 acres of <br /> coffee production is sold retail to people who visit the farm (both in the store and <br /> later over the Internet). If you were to extract all agtourism influence, the <br /> residual would be gross income unrelated to agtourism. If the production from <br /> those 12 acres were dumped on the wholesale market, the amount received <br /> would probably be less than 5% of the current gross. (Custom roasting would add <br /> a bit more revenue, but agtourism related revenue is still way in excess of 50%.) <br /> Dumping on the wholesale market is the approach of "old agriculture." We want <br /> to encourage the "new agriculture" where growers take responsibility for their <br /> marketing, where through the many avenues of direct marketing they <br /> become "price makers" rather than "price takers" of the old agriculture. Proposal <br /> d.6. is not only impossible to calculate accurately, its attempted implementation <br /> would be regressive. It can only have seriously negative consequences and should <br /> be deleted. If you can come up with a clearer idea of what you are trying to <br /> achieve, you will be able to write an effective regulation in its place. <br /> I cannot here itemize all of my other objections in detail, but I do want to <br /> mention one more: Section 25-2-75, Sub-section (3): agtourism facilities "shall <br /> not exceed 1,000 square feet in total area." <br /> It is unrealistic, arbitrary and irrelevant to demand that agtourism facilities not <br /> exceed 1,000 square feet. That regulation would eliminate many of our finest <br /> Hawaii agtourism attractions, including the above mentioned Holualoa Kona <br /> Coffee Co., Monty Richard's Ranch and Greenwell Farm. Again, how will you even <br /> calculate which facilities are agtourism facilities. The store is clearly an agtourism <br /> facility, but what about a coffee parchment drying area nicer than would be <br /> required for non-agtourism related production? Perhaps you would add only that <br /> area to the 1,000 square foot limit that is necessary to accommodate visitors. <br /> But, really, how much is that? As you can see this arbitrary 1,000 square foot <br /> limitation is as much a quagmire as the above regulation limiting agtourism <br /> income to 50% of total gross income. Delete it or rewrite it to reflect a genuine <br /> need. <br /> I believe the intentions of the planning Commission and the County Council are <br /> good. While I can clearly see many of the proposal's problems, I do not know <br /> from where exactly these problems arise. I suspect the source of the problems <br /> may lie in the fact that the definitions of "agricultural tourism" and "agricultural <br /> activities" are fundamentally inaccurate and extremely limiting and rigid. I think if <br /> you were to articulate more realistic definitions, more appropriate zoning would <br /> emerge. This is an important topic for another day. But clearly, the Planning <br /> Commission has more homework to do. <br /> The economic and social benefits of good agtourism are easily demonstrated. <br /> Effective planning is critical to realizing the enormous potential of good agtourism. <br /> The County's citizens, especially those in the agricultural community, are looking <br /> to you for appropriate zoning regulations. Indeed the whole state is looking to you <br /> for guidance because the County of Hawaii's zoning regulation, being the first in <br /> the state, will inevitably become a model for the other counties. <br /> Sincerely, <br /> Dr. Kent Fleming <br /> Professor & Extension Economist <br /> 1 1 /10/?005 <br /> <br />