Kamehameha Schools Comments on Draft HCDP

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Mr. Duane Kanuha Re: Comments from Kamehameha Schools to Draft HCDP (Jan. 2016) June 15, 2016 Page 6 of 7 • In the Draft HCDP Focus Discussions with the Hamakua community, the public expressed support for the idea of coastal setbacks as a tool to limit "new developments". However, there was no discussion or consideration of the implications or impacts of Policy 19 on coastal property, its application to all types of existing land use including agricultural, residential, cultural, historic restoration, or whether such policy would actually accomplish the public's desire to limit new development in the coastal area. 4. The Food Safety Modernization Act (FSMA) The Food Safety Modernization Act (FSMA) was signed into law in January 2011, and authorizes the U.S. Food and Drug Administration (FDA) to take a preventive approach to food safety. This new approach to food safety includes the authority to establish first-time food safety requirements for farms producing fruits and vegetables, among other requirements, for participants across the food supply chain. The FSMA Rules applying to produce and harvesting were released in November 2015. At the public outreach, regarding the Draft HCDP Agriculture Focus Discussion, held on May 18, 2016, local farmers and ranchers informed the County Planning Department that they were struggling to comply with the FSMA requirements relating to clean water and use of approved post-harvest processing facilities. The Draft HCDP has no policies designed to support farmers, landowners, or businesses struggling with complying with recently enacted FSMA requirements. State agencies and local farmers are still adapting to the new federal rules, and waiting for future guidance documents to provide an exact path toward compliance. To accommodate the ever-changing federal regulatory landscape, and to address the economic impacts of changing regulations on farmers, landowners, and businesses, the Draft HCDP should incorporate policies that promote flexibility and collaboration between the public and private sector as -needed to support the agriculture in Hamakua and address the community's needs during this transition period. KS suggested policies that: • Support farmers, landowners, and businesses as they establish Current Good Manufacturing Practices and Good Agricultural Practices in compliance with State and Federal food safety laws. • Cooperate with appropriate State and Federal agencies and the private sector to develop, improve and expand access to facilities designed for