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The Honorable Dominic Yagong, Chairman <br /> and Members of the County Council <br /> Page 2 <br /> May 24, 2011 <br /> Furthermore, the term " Infill" is defined on page 7 -2 of the Kona CDP as "Land <br /> development within the general boundaries of existing urban /suburban areas that were <br /> previously left undeveloped." Not only is the Project located entirely within the General <br /> Plan LUPAG Urban Expansion area and the Kona Urban Area slated for development by <br /> the Kona CDP, it is also within close proximity to existing urban/suburban developments <br /> and projects. <br /> b. Transit Oriented Development ( "TOD ") /Transit Neighborhood Development ( "TND ") <br /> Village - The Project is located entirely outside of any TOD. The closest TOD to this <br /> area is the Kahului-Puapua'a Village Neighborhood anchored by the major transit <br /> corridor makai of Queen Ka`ahumanu Highway. The Project does not meet the minimum <br /> 20 acre land area requirement to qualify as a TND. There is no legal authority that would <br /> allow me to characterize this Project as being over 20 acres, as there is no common <br /> ownership of this parcel and any neighboring parcels. <br /> c. "Greenbelt" Concept - Greenbelts are a component of a TOD /TND. Under Policy LU- <br /> 2.2, a greenbelt should surround and define the outer edge of the secondary area <br /> surrounding a higher density urban core. As this Project is located entirely outside of any <br /> TOD and does not meet the minimum 20 acre land area to qualify for a TND, there is no <br /> greenbelt requirement. Nevertheless, the Project concept does incorporate undeveloped <br /> open areas comprised of a proposed drainage mitigation area along the Project's mauka <br /> boundary abutting Hienaloli and Hualalai Roads. <br /> d. "Greenfield" Concept - The Kona CDP's glossary definition of "greenfield" is "an area <br /> that is undeveloped or used for agriculture. Refers only to undeveloped open space <br /> within the Kona Urban Area between TODs, TNDs and infill ". While the Project is <br /> located entirely within the Kona Urban area of the Kona CDP, it qualifies as an infill <br /> development and is therefore, by definition, not a greenfield area. The Project is also <br /> consistent with the General Plan LUPAG Urban Expansion designation for urban <br /> development. <br /> e. The Project is consistent with the General Plan LUPAG Urban Expansion Area <br /> designation - On February 8, 2010, the Applicant requested an interpretation of the <br /> General Plan LUPAG designation for the Project. As noted in my February 25, 2010 <br /> response letter to the Applicant (attached) and according to the Kona CDP's official map <br /> metadata, the Kona Urban Area boundary line traces the LUPAG boundaries so that <br /> Urban designations (i.e. urban expansion area, low density urban, industrial) are within <br /> the Kona Urban Area and Rural designations (i.e. important agricultural land) are outside <br /> of the Kona Urban Area. Therefore, the Project is consistent with the General Plan <br /> LUPAG designation of Urban Expansion Area. <br /> f. The Project is consistent with the Kona CDP Kona Urban Area - In the same February 8, <br /> 2010 letter from the Applicant, the Applicant also requested an interpretation of the Kona <br /> CDP - Kona Urban Area for the Project. Also noted within my February 25, 2010 <br /> response letter to the Applicant (attached) and according to the Kona CDP's official map <br /> metadata, the Project is determined to be entirely within the Kona Urban Area. <br />