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c. Current value of parcel: the CDP raises concern that rising land values threaten viable agricultural endeavors,4 however in many areas, especially those with water and electric service, the "affordability train" has already left the station: the current and inherent value of parcels such as Parcel 055 has already reduced the economic viability of agricultural production. The valuation of Parcel 055 supports the parcel's current LDU designation (in addition to the presence of a paved, county maintained road as well as infrastructure such as water & power, close proximity [.4 miles] to local services such as a school, restaurants, library, swimming pool, Belt Road, etc.) while at the same time, making our agricultural work possible. d. Parcel -specific designations which promote consistency between the State and County designations and reduce arbitrariness: the CDP emphasizes LUP AG land use designations will not alter State zoning or applicable restrictions. With that being said, the "on -paper" change to IAL does not eliminate the "on -the -ground" reality: Parcel 055 is too small to sustain high yields for export or local consumption nor could it be considered vital for future self-sufficiency needs of the island.s Considering the current approved uses, size, and unsuitability of Parcel 055 for prime agriculture, the logical action would be to retain the current LDU designation which would do more to promote consistency and reduce arbitrariness. If application of the IAL designation to our small property is meant to serve instead as a transition area of small farm residential land uses between the urban LD U and the larger lot agricultural areas" or simply, "to shrink the urban designations, " it is being done by a mis-application of the IAL label. A more appropriate, less arbitrary action would be to allow it to remain LDU or create a Rural zone. The CDP states that homestead areas such as Kihalani Homestead Road "accommodate an excess of rural development in the agricultural mauka areas "as a rational for not using a Rural designation. It would seem more consistent to use the Rural designation if in the opinion of the planners, these properties are already fulfilling that function. Why characterize these lots as IAL if in fact, their actual function is Rural? Or why not keep them as LDU, a designation which more aptly describes their "homestead" character? a Act 183: "Limit physical improvements on important agricultural lands to maintain affordability [my emphasis] of these lands for agricultural purposes." 'Policy 29, Rationale, Criteria for the designation of State Important Agricultural Lands, Draft Hamakua CDP. 3 e. Creation of the urban growth boundary: the UGB would more appropriately be applied to the upper boundary of Parcel 055 for all the reasons stated in this letter. The State Ag20 uses already prevent growth and Parcel 055 does not meet IAL