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go through a state land use district amendment for areas over 15 acres. Tr. July 22, 2003,p.m., <br /> pp. 70-74. (The County has exclusive jurisdiction over district amendments for up to 15 acres. <br /> HRS §205-3.1(c)). <br /> Given the elimination of the proposed urban residential component, Ms. Goldstein did <br /> not see a need for the project to obtain additional State Land Use Commission("LUC") approval. <br /> Transcript,July 22, 2003,p.m.,p. 60. Former LUC Executive Director Esther Ueda agreed. <br /> Transcript,July 22, 2003,p.m.,p.13. <br /> Neither did LUC Executive Director Esther Ueda have any specific concern about the <br /> County's redistricting of the sub-15 acre lodge parcel from the Agricultural to the Urban district. <br /> Transcript,July 22, 2003,p.m., p. 19. Actually, Ms Ueda explained her general concerns <br /> regarding"parceling"or piecemeal urbanization, and how Hokuli'a simply did not involve such <br /> concerns. R. Transcript, July 22, 2003,p.m.,p.13. (Portions of Goldstein and Ueda transcripts <br /> attached as Appendix "A".) <br /> The County and Oceanside also signed a Development Agreement requiring HRS <br /> Chapter 205 compliance,pursuant to HRS Chapter 146, Part VII, §§ 46-121 through 132. See <br /> attached Appendix`B". The County agreed, inter alia,that Oceanside could develop Hokuli'a <br /> in accordance with the laws,permits, zonings and other approvals granted to date. Oceanside <br /> would contribute public benefits, including a bypass highway between Keauhou and Captain <br /> Cook, and a 140-acre shoreline park. All was to be done in compliance with applicable laws, <br /> including HRS Chapter 205. See Development Agreement,paragraphs 5(p.10); 20(p. 19); 22a(p. <br /> 19-20). Oceanside believed no further discretionary permits were needed. Test. Richard Frye, <br /> Tr. July 9, 2003,p.m.,p. 60-61. <br /> The Development Agreement does not avoid HRS Chapter 205,but expressly requires <br /> compliance with it. The Circuit Court itself so held. AMENDED FINDINGS OF FACT, <br /> CONCLUSIONS OF LAW; ORDER REGARDING TRIAL ON COUNT IV OF THE FIFTH <br /> AMENDED COMPLAINT, filed October 22, 2003 ("Count IV Order", attached as Appendix <br /> "C"), COL No. 50. (Bold Italics added). <br /> 3. The Hokuli'a Agricultural Plan for HRS Chapter 205 Compliance. <br /> Given the known restrictions of HRS Chapter 205, Oceanside had consulted with <br /> multiple land use counsel to ensure legality of Hokuli'a within the State agricultural district. R, <br /> Exhibit PKO-195. Oceanside's planners thought from the beginning, that to be safe, they should <br /> 4 <br />