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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: Lau ahoehoe/Pa aaloa 2015 Proposed LUPAG Map". The proposedLUPAG changes -to Lakipalhoelhoe are to lengthen the IMDU airea along the Old I airn«SIIalhoa ffii hway to allow for l ncireased flexffililllity lien revlitafizlng the coirnirneird SII wire of the town and in response 'to recent v Ilo n't tr n s in t1hat area, and ;!o IIS n 'tlh lk i andqlk LQUIbogn iri s 'to The more consis'ten't with the S'ta'te Lamed Use Urban dis'tinc't (whille accokinting(hill'foir topography isski s skich as , aAldh s). *COMMENT: As stated above, the logical alignment would be with the County as expressed by the decisions made by the County for the 2005 General Plan that included the parcels in LDU that the CDP wants to delete including parcel 055. *What are the "recent development trends" in Laupahoehoe? The only "trends" that have affected Kihalani Homestead Road in the past 10 years have been more residential construction. Otherwise the reasons for LDU designations that existed when the LDU parcels were designated for the 2005 General Plan still exist. The CDP states to support "Taking parcel 055 out of LUP": In a 'few areas, the LDU is expanded lbeyond the S'ta'te Lamed Use Urban district -to allow 'foir infiIIII growth allong the Ilower portion of KiIh II ni Homestead Road. *COMMENT: The fact that the CDP chose to expand LDU beyond the State Urban district for some Laupahoehoe parcels confirms that the County may decide about urban land use regardless of the State districts. This validates the current LDU designations for Kihalani Homestead Road which includes parcel 055 in LDU. *What is the "infill growth" that would justify departing from alignment with the State Urban District? How would the "infill" rationale apply to the LDU "expansion" while LDU is being deleted from other parcels? If infill is a criterion for being LDU all the parcels between Mamalahoa and parcel 056 should be LDU based on any rationale regarding "infill". The CDP states to support "Taking parcel 055 out of LUP": In skimmm ary, the proposed changes 'to the LDU areas add consistency Ibetween the S'ta'te and the Cokinty designations, they II 'to an overall redkiced LDU area that is (less arbitrary and more arc ll -s cific, *COMMENT: Why is the 2005 LUPAG LDU area arbitrary? Exercising discretion, as the 2005 General Plan did when the current LDU designations were made, is not "arbitrary". The proposed CDP changes to LDU appear to be based on CDP wanting more land in IAL which is not warranted based on current and long standing land use in Kihalani Homestead. *COMMENT: Also, there are two "factors" that are used by the CDP to justify the proposed Laupahoehoe LDU decisions. Interestingly, these factors may be diametrically opposed in terms of but each factor seeks to attain the same objectives. How were the objectives implemented to align with the State rather aligning with the County? The true goal is whether the certain "patterns" are "sustainable". Parcel 055 is a mere half mile or less from the urban