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referred to by the CDP as "large agricultural lots" and "large productive agricultural lands" (which would be at least 20 acres because that is the smallest confirming parcel that can be created in Laupahoehoe mauka) should be considered for IAL designations. There are no large or core (20 acres or more) agricultural lots along Kihalani Homestead Road which is Rural the entire way to the top of the road. After the road terminates the large/core agricultural lands spread out for many miles up the mountain. This should alleviate concerns that the "de facto rural" parcels on Kihalani Homestead Road will clash with IAL agriculture. compare "Factor 2: Minimize encroachment onto core agricultural lands. This second factor used in evaluating LUPAG designations is based on Community Objective #2 which states: "Protect and restore viable agricultural lands and resources," 2C. IAL Criteria: According to the County, the criteria for IAL includes: 1. parcels with better potential for sustained high agricultural yields because of soil type, climate, topography, or other factors [for sustained high agricultural yields] 2. parcels that qualify as prime or unique (not usually applied to small or micro agriculture) 3. class B "good" soils (parcel 055 has a "C" rating along with most of Kihalani Homestead Road) 4. USDA "fair" for two or more crops on an irrigated basis The County recommends "the location of these lands should be verified by more detailed mapping when considering specific land use decisions." Additional State statutory and administrative criteria include: 1. lands that are producing sustained high agricultural yields (including soil quality, growing conditions, productivity rating systems, adequate water, Hawaiian agriculture, lot size (critical land mass), and proximity to markets, water, power 2. land that contributes to the State's economic base and produces agricultural commodities for export or local consumption 3. such land that is fallow None of these criteria match parcel 055 (see 2D IAL Criteria applied) 2D. IAL Criteria applied to parcel 055: Applying the IAL criteria for County and State that pertains to parcel 055, a change of LUPAG designation and a change from LUP to IAL is not warranted. 1. TOPOGRAPHY: 3.955 acre parcel; about half of it (2.328 acres) is a steep part that falls to the gulch; CTAHR evaluates the steep part as possibly suitable for timber or grazing which may not be feasible on 2.328 acres). Also the County is proposing a 10 acre parcel size to qualify for an agricultural exemption for timber or grazing. Setting up timber or grazing would require fences, grading and other supplies and labor which would require an investment of $20K or more. 2. LOT SIZE (CRITICAL LAND MASS): The CDP Rationale refers to large agricultural lots ("preserve large productive agricultural lands") which would be at least 20 acres because that is the smallest confirming parcel that can be created in Laupahoehoe mauka; 1.627 acres for crops plus the marginal 2.328 acres in the back of the parcel is not "large".