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2E. Burdens of IAL: A change to IAL for parcel 055 comes with increased land use burdens imposed retroactively; and a likely loss of property value due to the strict regulation (note that this would be in addition to the current County effort to repeal non -dedicated agricultural exemptions and to impose acreage minimums). A change to IAL would therefore cause Parcel 055 an "unreasonable economic hardship" which cannot be prevented. Thus parcel 055 should be continued in a LDU designation. An alternative would be to change the LUPAG for parcel 055 to "Rural" (see also the conclusion of these comments for another possible land use category). Designating a small farm for IAL could actually hurt the chances of anv kind of agriculture being conducted. Although incentives are supposed to support the IAL program, these incentives are may not apply to micro or small farms. The regulations of IAL might result in long fallow periods. The burdens might be offset to some extent from having pre -IAL grandfathered uses. 2F. IAL Can Affect Land Values: Using parcel 055 as an example: with a $250,000 purchase price for 3.9 acres of land, the cost per acre is apx. $64,000 per acre (not counting the farming expenses of supplies, machinery, overhead, etc.) The Institute for Local Self Government (California) reported six years ago that even the most lucrative fruit and nut crops would only support land values of $5,500 per acre. So the break-even in the best of circumstances would be 015 years or more. Many parcels nearby parcel 055 were purchased at even higher per acre amounts and have been improved with more elaborate and expensive homes which makes agriculture even less feasible. In Hamakua even seasoned large farms are finding it difficult to stay in business: one example is Richard Ha who closed his Hamakua Springs Farms because it was no longer profitable, http://www.biziournals.conV acific/news/2016/01/06/big-islands- hamakua-springs-country-farms -shuttin�.ht. The 2005 General Plan at section 14.2.1 Land Use Agriculture states: "Agricultural land values have risen beyond their value for agricultural purposes.... One of the key factors in adjusting to changing socio-economic conditions is the restructuring of our land use regulatory system to distinguish between important and other agricultural land." Land where agriculture cannot support a living wage can never be IAL. Lumping all the parcels higher than some arbitrary elevation into IAL without considering productivity does not properly characterize "Important Agricultural Land" or mean that any agriculture will be feasible. It does risk many unintended consequences and hardship for the owners of such parcels. The 2005 General Plan at section 14.3.5.3 North Hilo states: "Commercial development is limited in the North Hilo district.... Population in the district has been declining over the past thirty years." North Hilo and particularly Laupahoehoe needs the County to help them: not to restrict their options by imposing the burdens of IAL. As the 2005 General Plan section 15.1 states: "Regulations rely on government's police power to control what people can do or not do ... Regulation can be restrictive, reactive, and divisive. Incentive measures, on the other hand, can invite creative "win-win" solutions. Examples of incentive measures include property tax exemptions such as for agriculture.... Community Development Plans shall consider appropriate incentive measures to achieve various objectives...." The CDP should be opting to give micro or small farms and the rural homestead lands support and flexibility of how to operate so there is some incentive to engage in agriculture. Even without any "support", the property owners on