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No LUPAG Rural areas are proposed for these areas due to the prevalence of the surrounding existing rural - <br />style parcels in the homestead areas (e.g., Manowai'opae Homestead Road, Hokumahoe Road, and Kihalani <br />Homestead Road). <br />*COMMENT: This policy that addresses Rural uses does not directly address the issue of <br />taking TMK _055 out of LDU. However both LDU and Rural can provide an intermediate <br />land use or buffer between more intensive uses and agriculture. Policy 4 begs the question in <br />part 3C1 of why the CDP rules out a Rural designation for the homesteads including Kihalani <br />Homestead and parcel 055; when even the CDP admits the homesteads are "defacto rural" <br />*COMMENT: On Kihalani Homestead Road the only parcels that might qualify as "Important <br />Agriculture Land" or "Extensive Agriculture" would be the parcels mauka starting at the end of <br />Kihalani Homestead Road. Otherwise Kihalani Homestead Road is basically "de facto" rural <br />(vs. agricultural "anything") as the CDP states (see the green font in Policy 4, above). This <br />begs the question "why are the Kihalani Homestead Road parcels being characterized as IAL by <br />the CDP when they are de facto Rural land?" <br />The rationale for "Taking TMK _055 out of LDU" cites Policy 5 and 4: <br />Policy 5 <br />In the official Land Use Policy Map, the urban growth boundary between developed areas (designated <br />"Low/Medium Density Urban") and lands designated as agricultural or rural (designated "Important <br />Agriculture Land" or "Extensive Agriculture" or "Rural") is intended to be parcel -specific in the Hamakua <br />CDP planning area. Areas that are clearly beyond the designated urban growth boundaries shall be <br />preserved as rural or agricultural lands to maintain open space, scenic view planes, and natural beauty <br />areas. Note: See Policy 6 for more information on Industrial areas. This policy clarifies that the urban growth <br />boundary established with the Hamakua CDP Land Use Policy Map establishes parcel -specific UGBs <br />whenever practical at the intersection between Urban and Rural/Agricultural land uses. The CDP strategy of <br />designating parcel -specific Urban designations adds clarity and specificity, increases transparency into the land <br />use designation process, and more accurately reflects the County's and the Community's land use goals and <br />intentions. Rationale: The Urban Growth Boundary (UGB) identifies areas where growth will be encouraged <br />and areas that are to be protected for agriculture. UGBs are intended to accommodate anticipated growth <br />and to separate areas appropriate for future residential development from areas intended for agricultural use. <br />This is sometimes referred to as "Town and Country" zoning, which requires that development occur only in <br />towns and villages, with the surrounding rural areas remaining undeveloped and available for farming, <br />forestry, natural area preservation, and recreation. The LUPAG map includes land use categories that <br />effectively establish an UGB between the agricultural categories (Orchard, Extensive Agriculture, and <br />Important Agriculture), the rural category, and the urban categories (Low, Medium, and High Density Urban, <br />Industrial, Urban Expansion, and Resort). This policy clarifies that the UGB established with the Hamakua CDP <br />Land Use Policy Map establishes parcel specific UGBs whenever practical. This strategy of moving toward <br />parcel -specific mapping for the Hamakua CDP Land Use Policy Map reflects a shift from the 2005 General <br />Plan's LUPAG direction of being generalized guidance. (See the rationale for Policy 1 for a further discussion of <br />the General Plan LUPAG.) As noted, the LUPAG maps were originally broad, flexible tools intended to guide the <br />direction and types of desirable growth for each area of the County. This general approach to guiding land use <br />and growth allowed for interpretive flexibility and was based, at least in part, on the challenges of creating <br />detailed maps specific enough to demonstrate land use designations at a parcel level. However, by allowing <br />12 <br />