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and growth allowed for lirnteirpiredve flexliblilllity and was based, at least lin paint, on the challenges of careading detailed irrrn«cps specffiic enough to deirrrnornstir«ate land use desligrna Borns at a paircell level. However, lby allowing gemuer ll, lbllolb' s'tylle LUPAG maps, p ircells were o'f'ten split in -to various LUPAG designations in ways -tlh 't were more arbitrary -tlh n -they were in'ten'tion ll. TINS, at dirrrnes, led to property ow nears desliirlirng clleareir &rectliorn about tllheliir land use deslgrna Borns and future devellopirrrnernt optliorns and led some property ow nears to seelk fuirtheir ILIIa nnl ng Depairtirrrnernt lirnteirpireta Borns of tllheliir property lin hella lion to the gerneir«SII CUIN G deslgrna Borns„ INow that the CUP's Ihave the oppoirtunity and the technology to easlilly and a ffiickmtlly care«ate paircell-specffiic CUIN G maps, lit lis a irrrnoire piroacdve plla nnl ng strategy to clearly airtlicull«ate LUPAG deslgrla lions lin the l-l5rrrn51ku a CUP at a paircell Ileo( ll and decirease than prevalence of sphtfling LUPAG deslg na to ns airNtirairlilly„ compellfiirng reason for an exceptlion to thus approach wound be unrllhern pairt of a paircell lis lin an Open JUIN G deslgrna Born (such as unrllhern p«girt of a paircell lis unrlithlirn the State Land Use Cornseirvadorn &stikt — e.g.,along the coastfiirne or lin irrrn«sulka forests). Any p«girt of a paircell that lis deslgrn« ted as LUPAG Open wound ireirrrn«Minn Open for that specffiic «sirea of the paircell„ Otheir exceptliorns to thus paircell-specffiic strategy wound be unrllhern'the paircell lis lairge and irrrnay meed to ireflect two (or irrrnoire) d0eirernt'types of LUPAG deslgrna Borns„ For exarrrnplle, unrllhern'the paircell borders a town unrllheire pairs of lit wound be unrlithlirn the urban growth boundary, and yet the lairge paircell stretches fairtheir lirnto agikulltuir«SII «sireas unrllheire an AgirlculltuiralI deslgrna Born lis appiropirl ate„ The CUP stirategy of irrrn« lding paircell-specffiic LUPAG deslgrna Borns adds cllarlty, specffiiclty, and lirncire«uses transparency lirnto'the land use deslgrna Born process and irrrnoire accurately ireflects the County's and the Coirrrnirrrnurnity"s land use goalIs and 16,01111cy 4 "In carder to preserve larger lot agricultural lands for productive agricultural use, allow rural development can lands near urban areas where an intermediate land use between residential and productive agricultural areas is consistent with the surrounding uses and rural character *COMMENTS: Both LDU and Rural can provide an intermediate land use or buffer between more intensive uses and agriculture as stated by the CDP in Policy 5 above and Policy 4 below. There are several ways the entire Kihalani Homestead can serve as an UGB (non -conforming Ag 20; Urban; Rural) without having to be designated IAL. The rationale cites General Plan Policy 14.1.30) to support "Taking parcel 055 out of LUP": (D) Encourage urlb n develloprnen't within existing zoned areas allready served lby lb sic infrastructure, or chose 'to such areas, instead of scattered develloprnen't. *COMMENT: The 2005 Laupahoehoe LUPAG which included parcel 055 in the LDU designation was not "scattered" and reflected a rational land use designation for Kihalani Homestead Road. Like parcels were treated equally; and there was a clear boundary for the LDU (even though the IAL designation is not appropriate IN Kihalani Homestead but applies to only the large agricultural parcels ABOVE THE TOP of Kihalani Homestead Road). 3B. putting TMK 35004055 into IAL: see part 2., above: "Applicability Of Important Agricultural Lands Designation For TMK 35004055". Parcel 055 does not qualify as IAL and should not be designated as such. 3C. The CDP declines to consider a Rural designation for the homestead lands: 3CI: CDP Says: No Rural Is Proposed Because Kihalani Homestead Is Rural De Facto; 3C2: CDP Says: There Is An Excess Of Rural Development In Mauka Agriculture; 3C3: The CDP Cites Various Policies To Justify Not Considering A Rural Designation For Homestead Parcels Including Kihalani Homestead