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*The CDP states: <br />These preexisting lots have created a challenging land use scenario because in practice, the majority of these areas are <br />"de facto" rural subdivisions within a State and County land use system that historically underutilized the State Land <br />Use Rural District and Rural LUPAG designations. <br />*COMMENT: The homestead parcels are too big to be rural; too small to be productive <br />agricultural ---but can still be ZONED agriculture (and LUPAG could be Rural) ---see <br />conclusion of these comments below for a suggestion to deal with the homestead lands <br />*The CDP states: <br />THIS POLICY IS INTENDED TO SET APPROPRIATE CRITERIA FOR WHEN THIS RURAL DESIGNATION CAN BE USED. Note the <br />General Plan's LUPAG description for Rural describes the category as including EXISTING SUBDIVISIONS in the State <br />Land Agricultural and Rural districts that have a SIGNIFICANT RESIDENTIAL COMPONENT. While rural lot sizes can vary <br />from 9,000 -square feet to five acres, new recommended Rural designations in the Hamakua CDP have corresponding <br />County zoning densities of a maximum of 1 unit per 1 acre. As noted in the General Plan, the allowable uses within these <br />areas (with appropriate zoning) may include COMMERCIAL FACILITIES THAT SERVE THE RESIDENTIAL AND <br />AGRICULTURAL USES in the area, and community and public facilities. The Rural designation does not necessarily mean <br />that these areas should be further subdivided to smaller lots as most lack the infrastructure necessary to allow further <br />subdivision. The General Plan describes rural development this way: "Rural -style residential -agricultural developments <br />may include either new small-scale rural communities or extensions of existing rural communities. Such development <br />provides opportunities for a mix of residential and small-scale agricultural activities. However, THE PRIMARY INTENT OF <br />THESE DEVELOPMENTS WOULD BE TO PROVIDE AN ADDED RANGE TO HOUSING OPPORTUNITIES. Along with this <br />housing, the large lots of these rural areas will provide opportunities for part-time agriculture, gardening activities <br />and the raising of livestock on a small scale. By providing opportunities to satisfy the demand for a rural lifestyle on <br />MARGINAL agricultural land, the pressures to develop important agricultural land for these purposes would be <br />decreased." (General Plan 14.2.1) <br />*COMMENT: The CDP text quoted immediately above exactly describes Kihalani <br />Homestead. There are housing opportunities on all the parcels: most of which already have <br />housing and the other rural uses. <br />*The CDP states: <br />This General Plan description of rural -style residential -agriculture developments presents some AMBIGUITY, particularly <br />about what constitutes "marginal agricultural lands" that are appropriate for this style of rural residential development. <br />*COMMENT: "Marginal lands" describes parcel 055 and the other homestead parcels. Most <br />or all of the homestead parcels are deficient in one way or other regarding agricultural <br />suitability (see part 2C. IAL Criteria above). This does not mean the homestead parcels <br />cannot provide benefits to our community. Only to say they are not candidates for IAL. <br />*The CDP states: <br />FOR THE PURPOSES OF THE HAMAKUA CDP, the intent of recommending LUPAG Rural designations in some areas is <br />to accommodate existing land uses, to create a transition area of small farm/residential land uses between the urban <br />LDU and the larger lot agricultural (often Ag -20) areas, <br />*COMMENT: This exactly describes Kihalani Homestead... the first "larger lot agricultural <br />(often Ag -20)" areas are located right after the end of Kihalani Homestead Road. Ag -20 should <br />be expressed as "20 acres or more" because 20 acres is the smallest conforming parcel for <br />zoning purposes. As far as Ag -20 describing Kihalani Homestead, there has never been and <br />EV <br />