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*The rationale for not considering a Rural designation for Kihalani Homesteads (and <br />Laupahoehoe generally) is stated in "Future Addendum to Appendix, Draft CDP Rationale, <br />January 2016" page 36: In the rationales at part "Figure 16" the Laupahoehoe/Papaaloa <br />Proposed LUPAG map is discussed. With regard to Laupahoehoe and Kihalani Homestead <br />Road specifically, the CDP "Future Addendum to Appendix, Draft CDP Rationale, January <br />2U16 ttie riaure 16" ttie UIJF states: <br />Figure 16: Laupahoehoe/Papa'aloa 2015 Proposed LUPAG Map Rationale: The coastal communities of <br />Laupahoehoe, Papa'aloa, and Kapehu camp are inexorably linked with each other; each community is a former <br />plantation village surrounded by open pastures and working agriculture in close proximity to each other. <br />Laupahoehoe is the largest town in the North Hilo District and contains a strip of commercial lands along the Old <br />Mamalahoa Highway just mauka of Highway 19. Papa'aloa has a parcel with commercial zoning located makai of <br />the Highway 19 and three parcels with Industrial zoning in close proximity to the shoreline. Kapehu is a small <br />coastal subdivision with no commercial components but does have its own independent wastewater system. The <br />proposed LUPAG changes to Kapehu are to shrink the LUPAG LDU to be more parcel specific (this area is designated <br />State Land Use Urban District). This subdivision is a built -out neighborhood surrounded by agricultural lands in <br />close proximity to the shoreline; therefore, further expansion of the residential uses into the surrounding <br />agricultural lands or toward the shoreline are not preferred growth scenarios. The proposed LUPAG changes to <br />Papa'aloa are to make the LUPAG Low Density Urban designations mauka of the Highway 19 more parcel -specific <br />and consistent with the State Land Use Urban District. It is proposed to remove the LUPAG Medium Density Urban <br />designation since the necessary services and commercial uses could be accommodated under the LUAPG [sic] LDU <br />designation and the increased density that the LUPAG MDU allows for is not appropriate in this small coastal <br />community (see Policy 2 and Policy 3). The makai parcels of Papa'aloa with County Industrial zoning are <br />recommended to be designated as LUPAG LDU, or for the County -owned site, LUPAG Open since this would be <br />consistent with the neighboring park parcel and since Industrial uses are no longer desirable in such close proximity <br />to the shoreline. See the Note below for more information on LUPAG and County Zoning. The proposed LUPAG <br />changes to Laupahoehoe are to lengthen the MDU area along the Old Mamalahoa Highway to allow for increased <br />flexibility in revitalizing the commercial core of the town and in response to recent development trends in that <br />area, and to align the makai and mauka LDU boundaries to be more consistent with the State Land Use Urban <br />district (while accounting for topography issues such as gulches). In a few areas, the LDU is expanded beyond the <br />State Land Use Urban district to allow for infill growth along the lower portion of Kihalani Homestead Road. In <br />summary, the proposed changes to the LDU areas add consistency between the State and the County designations, <br />they lead to an overall reduced LDU area that is less arbitrary and more parcel -specific, they remove the MDU area <br />from Papa'aloa to ensure that commercial development is consistent with the rural character of the area, and they <br />remove obsolete Industrial designations on coastal parcels. No LUPAG Rural areas are proposed for these areas <br />due to the prevalence of the surrounding existing rural -style parcels in the homestead areas (e.g., Manowai`opae <br />Homestead Road, Hokumahoe Road, and Kihalani Homestead Road). These homestead areas contain previous <br />lots of record that were created prior to statehood, and they accommodate an EXCESS of rural development in the <br />agricultural mauka areas along the homestead roads. See the rationale for policies: Policy 2, Policy 4 and Policy 5 <br />and the existing General Plan Policy 14.1.3 0). <br />*COMMENT: Policy 4 begs the question in part 3C1 of why the CDP rules out a Rural <br />designation for the homesteads including Kihalani Homestead and parcel 055; when even the <br />CDP admits the homesteads are "defacto rural" On Kihalani Homestead Road the only parcels <br />that might qualify as "Important Agriculture Land" or "Extensive Agriculture" would be the <br />parcels mauka starting at the end of Kihalani Homestead Road. Otherwise Kihalani Homestead <br />Road is basically "de facto" rural (vs. agricultural "anything") as the CDP states (see the green <br />font in Policy 4, above). This begs the question "why are the Kihalani Homestead Road parcels <br />14 <br />