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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. 3CI: THE CDP SAYS: NO RURAL IS PROPOSED BECAUSE KIHALANI HOMESTEAD IS RURAL DE FACTO The Hamakua Community Development Plan: Rationale Future Addendum To dix Draft CDP Rationale, January 2016 states at page 37: No LUPAG R uir ll aireas wire proposed -fair these it a,u t the pirevalleince of the a,uirr a,und in ist ing ruirall- stylle paircellsfirm the homestead it (e.g., ainouvrali°olpae Hoirnestead IlIoad, HolkuirnaIhoe IlIoad, and IKlilhSIIainl Hoirnestead IlIoad)„ *COMMENT: This rationale seems to say that Kihalani Homestead cannot be considered for a rural designation because it is de facto rural already. There are many reasons why Kihalani Homestead and a rational land use policy would benefit from an official Rural designation for Kihalani Homestead and the other homesteads on Hawaii Island. To begin with, Kihalani Homestead is conceded to be rural by both the County and the CDP. The major issue with a rural designation is that it might encourage 1 acre subdivisions of Kihalani Homestead which no one on Kihalani Homestead Road would welcome. This possibility might be mitigated by layering Ag -20 zoning over a Rural LUPAG; or by creating a new Agriculture sub -category: see the idea at the conclusion to these comments. Regardless, it would make more sense to apply the Rural designation to Kihalani Homesteads rather than an IAL designation which is entirely inappropriate for the properties on Kihalani Homestead Road. The County's and CDP's concession that Kihalani Homestead is rural should be the last nail in the coffin for the idea that Kihalani Homestead should be designated IAL. The 2005 General Plan states at sec. 14.1.1 AGRICULTURAL DISTRICTS that have ea significant residential component. TYPICAL lot sizes wary from 9,000 - square feet to two acres. These subdivisions may contain small formas, wood areas, and open fields as well as residences. Allowable uses within these areas ... may include commercialcommunity and public facilities," (emphasis added) *COMMENT: This description makes it clear that the County has the authority to approve Rural designations in agricultural zones; that existing subdivisions (like Kihalani Homestead) that have rural uses are eligible to be designated rural; and that rural uses can be on State Agricultural Districts as well as on Rural Districts. 3C2: CDP SAYS: THERE IS AN EXCESS OF RURAL DEVELOPMENT IN MAUKA AGRICULTURE *the CDP continues: