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3A. Taking TMK _055 out of LUP COMMENT: The CDP removes LUP designations for parcel 055 and other parcels on Kihalani Road. The rationales regarding the CDP proposals to remove LUP on some Laupahoehoe parcels and to put other parcels into LUP is stated in "Future Addendum to Appendix, Draft CDP Rationale, January 2016" page 36: see text of the rationales in blue below. The CDP had 2 choices. 1) To use the 2005 LUPAG map; and the listing of parcels in LDU in the County computers (which I confirmed for parcel 055 several times over the counter at Planning between 2004 to 2016) that clearly designated and included parcel 055 designated as LDU; or 2) To disregard the County designation that was clearly the product of a rational plan; and adopt the Land Use Commission (LUC) map. Thus even if the 2005 LUPAG map might have been "blob" mapping, the County had a list of LDU properties in their computers so there was no confusion about what was LDU. The current designation of parcel 055 as LDU confirms that the County has the discretion to designate and zone property outside of the LUC Districts as "Urban" since Urban is a designation that is typically left to the discretion of the County. The CDP decided that the LDU designation should be reduced and chose to align with the LUC map. This resulted in an irrational LDU pattern where two parcels that were comparable (parcel 055 and parcel 086) are being treated differently in the CDP draft. Also, the decision to align with the LUC ignores the fact that the County, as the agency that is responsible for the administration of Urban lands, should default to align with the LDU designations the County adopted in the 2005 General Plan as a matter of policy rather than resorting to the State Districts that are outdated and less informed. For instance, the large Land Commission Urban District in Papaaloa is based on the plans of Hamakua Sugar to build a very large residential development in Papaaloa including large public parks and other amenities. Although a small amount of the Hamakua Sugar residential development was actually constructed, the majority of the development was never completed due to the closing of the plantations: but the Urban district based on the Hamakua Sugar plan remains on the maps. The rationale the CDP used for the decision to shrink the LUC designation for Laupahoehoe is found at page 36 of the FUTURE ADDENDUM TO APPENDIX Draft CDP Rationale, January 2016 "Figure 16: Laupahoehoe/Papaaloa 2015 Proposed LUPAG Map". The proposed LUPAG changes to Laupahoehoe are to lengthen the MDU area along the Old Mamalahoa Highway to allow for increased flexibility in revitalizing the commercial core of the town and in response to recent development trends in that area, and to align the makai and mauka LDU boundaries to be more consistent with the State Land Use Urban district (while accounting for topography issues such as gulches). n