HomeMy WebLinkAboutKuhr, Dashiell
Tsuneda, Kaci
From:Dash Kuhr <dash@hipagriculture.org>
Sent:Sunday, August 30, 2026 5:09 PM
To:Council Testimony; Hustace, James
Subject:Testimony in Opposition to Bill 147 — As Currently Written
Aloha Chair and Members of the Council,
My name is Dashiell Kuhr. I am the Managing Member of Starseed Ranch LLC, a 26-acre working
farm and regenerative agriculture operation located at 52-4838 Akoni Pule Highway in Kapʻaau, North
Kohala. My family has been farming in Kohala for 18 years. We employ 15+ people across our farm
and hosted operations, we grow and/or donate approximately $100,000 in produce annually to the
local community, and we host the Hawaiʻi Institute of Pacific Agriculture — a 501(c)(3) nonprofit that
runs farm-to-school education and farmer training programs — as a long-term tenant on our land.
I am writing to respectfully but strongly oppose Bill 147 as currently drafted. I support the intent
behind the bill — requiring registration, tax compliance, and good-neighbor practices for hosted
rentals. I have no objection to any of that. My concern is with specific provisions in the current draft
that, if enacted, would eliminate the small on-farm hosted operations that make the last remaining
small farms on Hawaiʻi Island economically viable. Bill 147, as written, would be a small-farm
extinction event. I do not believe that is what the Council intends, and I want to explain why.
Small farms on Hawaiʻi Island do not survive on farming alone.
This is not an opinion. It is the economic reality of every small farm I know on this island, and it is the
reality of my own operation. Farming in Hawaiʻi is one of the highest-cost agricultural environments in
the United States. Land costs, water costs, labor costs, feed costs, imported inputs, shipping, and the
sheer isolation of our supply chain all conspire to make farming here structurally unprofitable at small
scale on its own.
On our farm, we grow and donate approximately $100,000 in produce each year. That is the output of
a serious, working agricultural operation — not a hobby farm and not a pretense. But $100,000 in
produce does not cover $100,000 in production costs, let alone land, equipment, and labor. The math
simply does not work.
What makes our operation viable — what allows us to continue farming, employ 15+ people,
and host a 501(c)(3) doing agricultural education — is approximately $160,000 in annual
agritourism revenue from our hosted operation. That revenue is what pays the mortgage. It is
what keeps the operations running. It is what allows us to donate produce to the community
rather than shutting down. The hosted operation is not a side business separate from the farm. It is
the mechanism by which the farm survives.
Bill 147 as drafted would eliminate this model.
Two specific provisions in the current draft are, for a working farm like ours, structurally fatal:
The 5-bedroom cap on TVRs. Our operation was built out over 18 years to include multiple
detached guest structures on ag land. These structures were built in compliance with the rules
at the time, with permits, and they house visitors who come to experience the farm. Under Bill
147, any operation exceeding five bedrooms is barred from the TVR framework entirely and
reclassified as a “hotel or lodge” — which is not permitted on agricultural land. There is no
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grandfather clause. Our operation, built lawfully over nearly two decades, would be effectively
outlawed overnight.
The “principal home of the host” requirement for B&Bs on ag land. As drafted, this
language would require the B&B activity to be located specifically in the farm dwelling that is
also the host’s principal home. On working farms with detached farmworker housing, guest
cottages, or multiple dwellings developed over years of operation, this language does not fit
how real farms are actually organized. It is a residential-neighborhood framework being
applied to agricultural land, and it makes no operational sense on a working farm.
Together, these two provisions would take the small hosted operations that subsidize working farms
across Hawaiʻi Island and make them illegal. Not the party houses. Not the un-hosted commercial
vacation rentals in residential neighborhoods that this bill is ostensibly targeting. The small on-farm
hosted operations run by families who live on the land, farm it, and use the hosted revenue to keep
the farm running.
This is not a hypothetical. If this bill passes as written, we will likely have to sell our farm.
I want to be direct with the Council because I do not think the consequences of this bill have been
fully weighed. If Bill 147 passes in its current form and our hosted operation is eliminated, our farm
cannot sustain itself on produce revenue alone. We would face a choice between operating at a
significant annual loss indefinitely or selling the land. In this real estate market, on Akoni Pule
Highway, the most likely buyer of a 26-acre parcel is not another farmer. It is a private residence, a
luxury estate, or a developer.
Multiply that decision across the dozens of small farms in North Kohala and Hamakua that operate on
similar economics, and the outcome is straightforward: fewer working farms, more private estates,
less agricultural production, and fewer local jobs. The bill intended to protect the community would
accelerate the loss of the agricultural land that defines it.
There is a clear compromise that addresses the Council’s concerns without harming working
farms.
I am not asking the Council to withdraw Bill 147. There is real work to be done regulating vacation
rentals on this island, and I support most of what the bill attempts. I am asking for a narrow,
defensible carve-out:
Provide a specific exemption or accommodation for hosted TVRs located on land that is
actively used for bona fide agricultural production, where the hosted operation is operated by
the farm owner or operator, and where the operation is registered under Ord 25-50 and
compliant with tax obligations and good-neighbor requirements. This carve-out could be defined
by objective criteria: minimum acreage in active cultivation, minimum annual agricultural output,
connection to an agricultural enterprise, or similar. Hawaiʻi’s existing agritourism framework under
HRS 165 provides a starting model.
This approach lets the Council achieve every substantive goal in Bill 147 — registration, tax
compliance, complaint response, prohibition of party houses and non-hosted commercial operations
in residential neighborhoods — while preserving the agritourism revenue that keeps small farms alive
on Hawaiʻi Island.
It is also consistent with existing state policy. HRS Chapter 165 explicitly recognizes agritourism as a
permitted, encouraged activity on agricultural land, precisely because the legislature understood that
agricultural viability in Hawaiʻi often requires diversified income. Bill 147 as drafted would cut against
that policy without acknowledging it.
The Council’s own study supports this concern.
The Hunden Partners Economic Impact Study commissioned by this Council in 2025 quantified the
scale of the hosted rental sector and its integration into island livelihoods. The study’s own findings
show that the sector supports thousands of jobs and represents a significant share of the island’s
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economic activity, and that conversion of these units to long-term housing is unlikely to materialize at
meaningful scale. On working farms specifically, the connection between hosted operations and
agricultural viability is direct and immediate.
The regulatory response should be calibrated to the problem the Council is actually trying to solve —
unpermitted party houses, non-hosted commercial operations in residential neighborhoods, and tax
non-compliance — not to a broad prohibition that catches working farms in the same net.
In closing.
I have farmed in Kohala for 18 years. I employ my neighbors. I donate food to the community. I host a
501(c)(3) that trains the next generation of Hawaiʻi farmers. I pay my taxes, register my operation,
and try to be a good neighbor. I am not the operator this bill is trying to regulate.
I respectfully ask the Council to amend Bill 147 to include a working-farm carve-out along the lines
described above, and I would welcome the opportunity to work with Council Members and staff on the
specific language. My hope is that the final bill can achieve what the Council is trying to achieve
without eliminating the small agricultural operations that make Hawaiʻi Island what it is.
Mahalo for your consideration and for your service.
Respectfully,
Dashiell Kuhr
Managing Member
Starseed Ranch LLC
52-4838 Akoni Pule Highway, Kapʻaau, HI 96755
808-896-6084
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