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2026-05-12 Appellant's Memorandum in Opposition to Motions to Dismiss (PL-BOA-2025-000119 & 121)
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2026-05-12 Appellant's Memorandum in Opposition to Motions to Dismiss (PL-BOA-2025-000119 & 121)
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(2003) . "Within agricultural districts . . . accessory agricultural <br /> uses and services described in sections 205-2 and 205-4.5 may be <br /> further defined by each county by zoning ordinance. " HRS § 205- <br /> 5 (b) (2017) . <br /> HRS § 205-2 (d) (Supp. 2012) lists seventeen uses or <br /> activities [that] agricultural districts "shall include, " and <br /> transient vacation rentals is not expressly listed. (emphasis <br /> added) <br /> HRS § 205-4 .5 (a) (Supp. 2006 & 2016) delineates the <br /> permissible uses in agricultural districts rated class A or B. <br /> One permissible use in an agricultural district is a farm <br /> dwelling, which was defined as "a single-family dwelling located <br /> on and used in connection with a farm[.] " HRS § 205- 205 (a) (4) <br /> (Supp. 2006 & 2016) . Of the fourteen permissible uses within the <br /> agricultural district enumerated in subsection (a) , none <br /> expressly included transient vacation rentals. HRS § 205- <br /> 4 .5 (a) (Supp. 2006) . (emphasis added) <br /> Any use not expressly allowed in subsection (a) is <br /> prohibited, unless an HRS § 205-6 (2001 & Supp. 2016) special <br /> permit or an HRS § 205-8 (2001) nonconforming use certificate is <br /> obtained. See HRS § 205-4 .5 (b) (Supp. 2016) . Thus, any use <br /> permitted by a county not expressly allowed in HRS § 205-4 . 5 (a) , <br /> or by virtue of HRS §§ 205-6 or 205-8, conflicts with the <br /> statutory regime. Save Sunset Beach Coal., 102 Hawaii at 482, <br /> 78 P.3d at 18 . (emphasis added) <br /> 153 Haw. at 393-394, 539 P.3d at 177-178. <br /> 8. On its face, Campos holds that transient accommodation <br /> activity in the State Land Use Agriculture District and a county-based Agricul- <br /> tural Project District lying therein is not a direct permitted use if the soil <br /> productivity rating of the subject land is Class B or Class C (the soil produc- <br /> tivity rating for the land in this agency appeal is Class Q. No party sought <br /> further review of the Intermediate Court of Appeals' decision and Campos is <br /> now settled law and is on "all fours" with the question presented in this agency , <br /> appeal. Further, Campos is consistent with the State Land Use Commission's <br /> declaratory order in the "Rosehill Cases." 27 <br /> Z' As is stated in Part A.16 to A.20, Pages 8 to 9, supra, the State <br /> Land Use Commission's declaratory order arose in a contested case <br /> under Chapter 205, Hawaii Revised Statutes. Based on legislative <br /> 24 <br />
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