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CARLSMITH BALL LLP <br />A LIMITED LIABILITY LAW PARTNERSHIP <br />121 WAIANUENUE AVENUE <br />P.O. Box 686 <br />Han, HAWAII 96721-0686 <br />TELEPHONE 808 935 6644 FAx 808 935 7975 <br />WWW.CARLSMITH.COM <br />SL.P 4@CARLSMIr%I.COM <br />November 12, 2019 <br />VIA HAND -DELIVERY <br />Mr. Michael Yee, Planning Director <br />Attn: Ms. Bethany Morrison <br />Planning Department, County of Hawaii <br />101 Pauahi Street, Suite 3 <br />Hilo, Hawaii 96720 <br />?19 toll 1? <br />09 <br />Re: Request for Planning Director -Initiated General Plan Amendment from Low <br />Density Urban and Conservation to Medium Density Urban for Tax Map Key <br />Nos.: (3) 7-3-009: 017, 025, 026, 028, and 063 <br />Dear Mr. Yee and Ms. Morrison: <br />On behalf of our client Kaloko Residential Park LLC ("Kaloko"), the owner of the <br />above -referenced parcels, we are requesting Planning Director -initiated revisions to the Draft <br />2040 County of Hawai`i ("County") General Plan' (the "Draft General Plan") and the <br />proposed Future Land Use Designation Map (the "FLUM") for North Kona, dated August 2019. <br />Kaloko's requested revisions relate to its properties located in Kailua-Kona, District of <br />North Kona, County, and State of Hawaii, identified by Tax Map Key Nos.: (3) 7-3-009: 017 <br />("Parcel 17"), 025 ("Parcel 25"), 026 ("Parcel 26"), 028 ("Parcel 28"), and 063 ("Parcel 63") <br />(collectively the "Property"). The Property consists of approximately 1,139 acres. <br />Kaloko intends to develop a mixed-use community village on the Property that integrates <br />diverse housing offerings, mixed-use commercial and retail growth and employment <br />opportunities, and a range of community services and facilities (inclusive of medical, lodging, <br />I In addition to the specific revisions requested herein, Kaloko joins in on the "Comments on 2019 Draft General <br />Plan" prepared by the Law Offices of Yeh & Moore, submitted with the Planning Department on or about October <br />31, 2019, which objects to the Draft General Plan in its present form, and requests that it be revised to conform to its <br />purpose, as set forth in HRS § 46-4 and the County's Charter. The Draft General Plan inappropriately contains <br />regulatory standards rather than policy statements, which will lead to, among other things, issues of interpretation <br />and challenge, issues of enforcement, and divesting agencies of their delegated authority to issue permits and <br />approvals under standards which allow for the exercise of discretion. <br />HONOLULU HILO <br />KONA <br />MAUI - Los ANGELES <br />