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being characterized as IAL by the CDP when they are de facto Rural land?" Both LDU and Rural can provide an intermediate land use or buffer between more intensive uses and agriculture as stated by the CDP in Policy 5 above and Policy 4 below. There are several ways the entire Kihalani Homestead can serve as an UGB (non -conforming Ag 20; Urban; Rural) without having to be designated IAL. 3C1: THE CDP SAYS: NO RURAL IS PROPOSED BECAUSE KIHALANI HOMESTEAD IS RURAL DE FACTO The Hamakua Community Development Plan: Rationale Future Addendum To Appendix Draft CDP Rationale, January 2016 states at page 37: No LUPAG Rural areas are proposed for these areas due to the prevalence of the surrounding existing rural - style parcels in the homestead areas (e.g., Manowaropae Homestead Road, Hokumahoe Road, and Kihalani Homestead Road). *COMMENT: This rationale seems to say that Kihalani Homestead cannot be considered for a rural designation because it is de facto rural already. There are many reasons why Kihalani Homestead and a rational land use policy would benefit from an official Rural designation for Kihalani Homestead and the other homesteads on Hawaii Island. To begin with, Kihalani Homestead is conceded to be rural by both the County and the CDP. The major issue with a rural designation is that it might encourage 1 acre subdivisions of Kihalani Homestead which no one on Kihalani Homestead Road would welcome. This possibility might be mitigated by layering Ag -20 zoning over a Rural LUPAG; or by creating a new Agriculture sub -category: see the idea at the conclusion to these comments. Regardless, it would make more sense to apply the Rural designation to Kihalani Homesteads rather than an IAL designation which is entirely inappropriate for the properties on Kihalani Homestead Road. The County's and CDP's concession that Kihalani Homestead is rural should be the last nail in the coffin for the idea that Kihalani Homestead should be designated IAL. The 2005 General Plan states at sec. 14.1.1 Rural Designation: Rural: this category includes EXISTING SUBDIVISIONS IN THE STATE LAND USE AGRICULTURAL DISTRICTS that have a significant residential component. TYPICAL lot sizes vary from 9,000 - square feet to two acres. These subdivisions may contain small farms, wood areas, and open fields as well as residences. Allowable uses within these areas ... may include commercial... community and public facilities." (emphasis added) *COMMENT: This description makes it clear that the County has the authority to approve Rural designations in agricultural zones; that existing subdivisions (like Kihalani Homestead) that have rural uses are eligible to be designated rural; and that rural uses can be on State Agricultural Districts as well as on Rural Districts. 15