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A decade or so after the plantations shut down, Kihalani Homestead Rd. became a magnet for people who worked in Hilo or off -Island and who wanted a rural lifestyle. That rural lifestyle commonly involved and still involves micro or small agricultural projects for commercial or subsistence purposes along with increasingly upscale housing. Over the years the parcels between parcel 055 and the Belt Road in -filled with these residential/commercial (LDU) uses. Parcel 055 is a integral part of this trend and therefore part of (or the leader of) LDU land use in Laupahoehoe. The current LUPAG designation... LDU... accurately reflects the uses of parcel 055. 2. APPLICABILITY OF Important Agricultural Lands DESIGNATION FOR TMK 35004055 (2A. Introduction; 2B. State vs. County IAL; 2C. IAL Criteria; 2D. IAL Criteria applied parcel 055; 2E. Burdens of IAL; 2F. IAL Can Affect Land Values:) 2A. Introduction: An 'Important Agricultural Lands" designation for TMK 3-5-004-055 is not accurate or appropriate. In addition to the fact that parcel 055 was a early adopter of residential/commercial uses (that is, LDU uses and should stay LDU for that reason), there are other reasons why parcel 055 will never qualify as 'Important Agricultural Lands" (IAL) (the new designation that the Laupahoehoe LUPAG proposes for parcel 055). ALSO SEE THE APPENDIX AT THE END OF THIS MEMO FOR A BULLET POINT OUTLINE OF THE IAL ISSUES INCLUDING INFORMATION FIRST PUBLISHED AT THE CDP MEETING ON 5-25-16 & RELATED COMMENTS 2B. State vs. County IAL: The CDP differentiates County IAL (which would govern land use changes requested in the future); vs. State IAL which is a program that governs IAL parcels more broadly. Regardless of differences, there will come a time when 1) all or some of the IAL parcels included in the CDP will become part of the General Plan; and 2) when Hawaii County will have to submit a list of IAL parcels to the State Land Use Commission (LUC) as the state program progresses. Once the IAL parcels and LUPAG maps are part of the General Plan, any change to the IAL in the General Plan will require a Environmental Assessment (EA) which may cost as much as $100,000 to procure. And if the County uses the list of County IAL parcels to report to the LUC, the County IAL parcels will be in the State program. At that point any changes that are requested in the State designation will be equally expensive and time consuming to change. Also, given the nature of the IAL program, once a parcel is in IAL, it is unlikely that changes will be approved. Once in the State program, the allowed uses for any parcel designated IAL will be limited by the State (and likely by County zoning) to strict agricultural uses: an example of the uses that might be allowed for IAL when the program is operational is found in haps://legiscan.com/Hl/text/HB1361/id/919216. Therefore, before any parcels are designated IAL by the County, it would behoove the County to conduct a parcel -specific "on the ground study" such as has been done by Kauai (http:Hl)lankauai.conVwp-content/uploads/IAL-FINAL-AUG-2015-combined-small.pdf) to determine lands that are legitimately IAL lands. As it stands no such study has been done for Hawaii Island. Only parcels that are capable of sustained high agricultural yields and that are