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IAL ISSUES INCLUDING INFORMATION FIRST PUBLISHED AT THE CDP MEETING ON 5-25-16 & RELATED COMMENTS 2B. State vs. County IAL: The CDP differentiates County IAL (which would govern land use changes requested in the future); vs. State IAL which is a program that governs IAL parcels more broadly. Regardless of differences, there will come a time when 1) all or some of the IAL parcels included in the CDP will become part of the General Plan; and 2) when Hawaii County will have to submit a list of IAL parcels to the State Land Use Commission (LUC) as the state program progresses. Once the IAL parcels and LUPAG maps are part of the General Plan, any change to the IAL in the General Plan will require a Environmental Assessment (EA) which may cost as much as $100,000 to procure. And if the County uses the list of County IAL parcels to report to the LUC, the County IAL parcels will be in the State program. At that point any changes that are requested in the State designation will be equally expensive and time consuming to change. Also, given the nature of the IAL program, once a parcel is in IAL, it is unlikely that changes will be approved. Once in the State program, the allowed uses for any parcel designated IAL will be limited by the State (and likely by County zoning) to strict agricultural uses: an example of the uses that might be allowed for IAL when the program is operational is found in https://Ieaiscan.com/Hl/text/HB1361/id/919216. Therefore, before any parcels are designated IAL by the County, it would behoove the County to conduct a parcel -specific "on the ground study" such as has been done by Kauai (http://plankauai.com/wp-content/uploads/IAL-FINAL-AUG-2015-combined-small.pdf) to determine lands that are legitimately IAL lands. As it stands no such study has been done for Hawaii Island. Only parcels that are capable of sustained high agricultural yields and that are referred to by the CDP as "large agricultural lots" and "large productive agricultural lands" (which would be at least 20 acres because that is the smallest confirming parcel that can be created in Laupahoehoe mauka) should be considered for IAL designations. There are no large or core (20 acres or more) agricultural lots along Kihalani Homestead Road which is Rural the entire way to the top of the road. After the road terminates the large/core agricultural lands spread out for many miles up the mountain. This should alleviate concerns that the "de facto rural" parcels on Kihalani Homestead Road will clash with IAL agriculture. compare "Factor 2: Minimize encroachment onto core agricultural lands. This second factor used in evaluating LUPAG designations is based on Community Objective #2 which states: "Protect and restore viable agricultural lands and resources." 2C. IAL Criteria: According to the County, the criteria for IAL includes: 1. parcels with better potential for sustained high agricultural yields because of soil type, climate, topography, or other factors [for sustained high agricultural yields] 2. parcels that qualify as prime or unique (not usually applied to small or micro agriculture) 3. class B "good" soils (parcel 055 has a "C" rating along with most of Kihalani Homestead Road) 4. USDA "fair" for two or more crops on an irrigated basis El