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expenses of supplies, machinery, overhead, etc.) The Institute for Local Self Government <br />(California) reported six years ago that even the most lucrative fruit and nut crops would only <br />support land values of $5,500 per acre. So the break-even in the best of circumstances would be <br />015 years or more. Many parcels nearby parcel 055 were purchased at even higher per acre <br />amounts and have been improved with more elaborate and expensive homes which makes <br />agriculture even less feasible. In Hamakua even seasoned large farms are finding it difficult to <br />stay in business: one example is Richard Ha who closed his Hamakua Springs Farms because it <br />was no longer profitable, http://www.bizjoumals.com/pacific/news/2016/01/06/big-islands- <br />hamakua-springs-country-farms-shutting html. The 2005 General Plan at section 14.2.1 Land <br />Use Agriculture states: "Agricultural land values have risen beyond their value for agricultural <br />purposes.... One of the key factors in adjusting to changing socio-economic conditions is the <br />restructuring of our land use regulatory system to distinguish between important and <br />other agricultural land." Land where agriculture cannot support a living wage can never be <br />IAL. Lumping all the parcels higher than some arbitrary elevation into IAL without considering <br />productivity does not properly characterize "Important Agricultural Land" or mean that any <br />agriculture will be feasible. It does risk many unintended consequences and hardship for the <br />owners of such parcels. The 2005 General Plan at section 14.3.5.3 North Hilo states: <br />"Commercial development is limited in the North Hilo district.... Population in the district <br />has been declining over the past thirty years." North Hilo and particularly Laupahoehoe <br />needs the County to help them: not to restrict their options by imposing the burdens of IAL. As <br />the 2005 General Plan section 15.1 states: "Regulations rely on government's police power <br />to control what people can do or not do ... Regulation can be restrictive, reactive, and <br />divisive. Incentive measures, on the other hand, can invite creative "win-win" solutions. <br />Examples of incentive measures include property tax exemptions such as for <br />agriculture.... Community Development Plans shall consider appropriate incentive <br />measures to achieve various objectives...." The CDP should be opting to give micro or small <br />farms and the rural homestead lands support and flexibility of how to operate so there is some <br />incentive to engage in agriculture. Even without any "support", the property owners on <br />Kihalani Homestead Road still try to contribute by helping to "keep the country, country" and <br />by making a small but helpful contribution to agriculture. <br />3. The CDP rationales for: 3A. taking TMK -55 out of LUP; 3B. putting TMK <br />_055 into IAL; 3C. not considering a Rural designation for TMK _055 <br />are not convincing and should be revised. <br />In this section 3., excerpts of "rationales" from the CDP are shown in blue in 12 point Calibri <br />with a 1 point borde ; and COMMENTS are shown in black print. Relevant text in the CDP <br />and in the comments is highlighted in yellow with particularly relevant wording in bold. <br />References to the "CDP" are to the Hamakua CDP. <br />7 <br />