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LDU is also appropriate for parcel 054 due to its location and to the fact that parcel 054 (to be <br />taken OUT of LDU by the CDP) is owned by the owner of adjacent parcel 043 (that is being <br />retained in LDU). These two parcels are the same for all purposes but the CDP proposes to <br />treat them differently. As for parcel 055, there are many other characteristics, besides those <br />mentioned above, that tie parcel 055 to the makai urban areas rather than the large parcels <br />mauka. More detail is offered in the comments below about parcel 055's proper designations. <br />The draft CDP describes LDU as follows: "LUPAG LDU, or Low Density Urban: this category <br />is defined as: <br />"Residential, with ancillary community and public uses, and neighborhood and convenience -type commercial <br />uses; overall residential density may be up to six units per acre." The urban zones in the County Code that <br />correspond to the LDU designation allow for parks, community uses, residences, boarding and group living <br />facilities, home occupations, small scale commercial or personal services, convenience stores, medical clinics, <br />and restaurants." <br />Parcel 055 has been residential/commercial in nature for many years. In fact parcel 055 was <br />the only residential use on Kihalani Homestead Rd. for many years after the homestead was <br />subdivided. Parcel 055 was occupied by the plantation's chemist who worked on Parcel 055 ; <br />and a large two story home was built on Parcel 055 by him, as well as a small cottage built in <br />1950. The family that lived on Parcel 055 left Hawaii Island to get work on Oahu after the <br />plantation shut down because they could not make a living farming after sugar cane phased out. <br />A decade or so after the plantations shut down, Kihalani Homestead Rd. became a magnet for <br />people who worked in Hilo or off -Island and who wanted a rural lifestyle. That rural lifestyle <br />commonly involved and still involves micro or small agricultural projects for commercial or <br />subsistence purposes along with increasingly upscale housing. Over the years the parcels <br />between parcel 055 and the Belt Road in -filled with these residential/commercial (LDU) uses. <br />Parcel 055 is a integral part of this trend and therefore part of (or the leader of) LDU land use <br />in Laupahoehoe. The current LUPAG designation... LDU... accurately reflects the uses of <br />parcel 055. <br />2. APPLICABILITY OF Important Agricultural Lands DESIGNATION FOR TMK <br />35004055 (2A. Introduction; 2B. State vs. County IAL; 2C. IAL Criteria; 2D. IAL Criteria <br />applied parcel 055; 2E. Burdens of IAL; 2F. IAL Can Affect Land Values:) <br />2A. Introduction: An "Important Agricultural Lands" designation for TMK X055 is not <br />accurate or appropriate. In addition to the fact that parcel 055 was a early adopter of <br />residential/commercial uses (that is, LDU uses and should stay LDU for that reason), there are <br />other reasons why parcel 055 will never qualify as "Important Agricultural Lands" (IAL) (the <br />new designation that the Laupahoehoe LUPAG proposes for parcel 055). ALSO SEE THE <br />APPENDIX AT THE END OF THIS MEMO FOR A BULLET POINT OUTLINE OF THE <br />3 <br />