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specific strategy would be when the parcel is large and may need to reflect two (or more) different types of LUPAG designations. For example, when the parcel borders a town where part of it would be within the urban growth boundary, and yet the large parcel stretches farther into agricultural areas where an Agricultural designation is appropriate. The CDP strategy of making parcel -specific LUPAG designations adds clarity, specificity, and increases transparency into the land use designation process and more accurately reflects the County's and the Community's land use goals and intentions. *COMMENT: *there are no splits at or around parcel 055 *the 2005 General Plan was not "generalized" for LDU: the County had a written list of parcels that were LDU; and all indicators are Laupahoehoe LDU urban designations were made after a rational process *the "community" referenced is first and foremost the citizens of Laupahoehoe and the respective land owners *the 2005 LUPAG map might be considered to be "blob mapping" but the County has also maintained written data for each parcel at all times of the LUPAG designations of each parcel which has shown parcel 055 as LUPAG; even with blob mapping the boundaries and characteristics of a parcel can be determined in County records *parcel specific mapping and good technology is helpful; but for something like IAL a site visit and comprehensive study should be done The rationale cites General Plan Policy 14.1.30): (j) Encourage urban development within existing zoned areas already served by basic infrastructure, or close to such areas, instead of scattered development. *COMMENT: The 2005 Laupahoehoe LUPAG which included parcel 055 in the LDU designation was not "scattered" and reflected a rational land use designation for Kihalani Homestead Road. Like parcels were treated equally and there was a clear boundary for the LDU (even though the IAL designation is not appropriate in Kihalani Homestead but applies only to the large agricultural parcels above the top of Kihalani Homestead Road). 4. CONCLUSION The main problem of dealing with the homestead lands is that there is really no category, either State or County, that fits their use well. Homesteads are de facto Rural. But there is a problem in using Rural in that the rural category provides for parcels as small as one acre and even the homestead owners would not want new one acre parcels created in their neighborhoods. The Urban uses can cover some of the homestead lands at lower elevations but do not apply as well past where electric service terminates. Agricultural zoning takes care of land use above the urban uses. The fact that neither the State nor County have taken the time to deal with the "challenge" of the homestead lands (referenced in the CDP) is NOT a reason for slamming the homesteads into an equally inappropriate category like "Important Agricultural Lands" which involves many unintended consequences and hardships for the land owners living in the homesteads. The homesteads were created under State law to address a particular need: to attract small scale farmers and homesteaders to settle in the remote parts of the island and to occupy those areas for the good of the island. Having taken this bargain nearly 100 years ago which still is perpetuated today, it behooves the State and County to recognize the homesteaders 21