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County ofHawai`i Phone: (808)961-8564
Council District 9- h'a,808)887-2069
North and South Kohala I + . Email:tim.richardsahawaiicountv.gov
Chair: Committee on Agriculture, to .,.;.•0%• Vice Chair:Committee on Finance
Water, Energy, &Environmental o_M'
Management
HERBERT M. "TIM" RICHARDS, III -'
HAWAII COUNTY COUNCIL
District 9
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25 Aupuni Street, Ste. 1402, Hilo, Hawai`i 96720 7
October 31, 2019
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Mr. Michael Yee, Director s
Department of Planning i "
101 Pauahi Street, Suite 3
Hilo, Hawaii 96720
SUBJECT: COMMENTS ON THE GENERAL PLAN 2040 AUGUST 2019 DRAFT
Aloha, Mr. Yee:
I appreciate the opportunity to provide comments on the County ofHawai`i General Plan
2040 August 2019 Draft(Draft General Plan 2040).
As you know I represent the Hawaii County Council District 9 which encompasses
North and South Kohala. I am Chair of Committee on Agriculture, Water, Energy and
Environmental Management, and Vice Chair of Committee on Finance. I was born and
raised in North Kohala and grew up working on my family's Kahua Ranch. I am also a
veterinarian and have been involved with ranching and farming in my district for my
entire professional career. I know the lands of my district well, and I know the areas that
are productive agricultural lands and the areas that are not productive agricultural lands.
Based on my knowledge and experience, I believe that many of the lands in my district
designated on the Draft General Plan 2040 Future Land Use Map as "Productive
Agricultural Lands" are not, in fact,productive agricultural lands. The same is true of
many ofthe lands designated on the General Plan 2005 LUPAG Map as "Important
Agricultural Lands." You may recall on previous conversations that Mr. Jeff Darrow and
I specifically discussed this point.
Hawaii County is an Equal Opportunity Provider andEmployer
Mr.Michael Yee,Director
Department ofPlanning
Comments on General Plan 2040,August 2019 Draft
Page 2 of 5
From comparison ofthe Draft General Plan 2040 Future Land Use Map with the
General Plan 2005 LUPAG Map it appears that much of the "Important Agricultural
Lands" area from the 2005 LUPAG Map was just carried over to the Draft Future Land
Use Map and the designation name changed to "Productive Agricultural Lands."I note
that the General Plan 1989 LUPGA map used the designation of"Intensive Agricultural"
for much of these same lands.
While in the past many of these lands may have been part of historic ranches or supported
grazing, today, with changing ranching production and practices, many of these lands are
no longer supporting significant ranching or agricultural use and would I not consider all
of these lands "Productive Agricultural Lands" for crops or other agricultural uses.
Moreover, I do not believe the criteria used in the Draft General Plan 2040 for the
Productive Agricultural Lands" designation support such a designation for all lands
designated "Productive Agricultural Lands". Interestingly, the General Plan 2005 used
the same criteria to designate land as "Important Agricultural Lands." Because ofthis, I
question if analysis was done as part of the land use mapping and designation process to
support designating the land per the criteria. On the webpage for the Draft General Plan
2040 I did not see reports, analysis, or GIS data supporting the "Productive Agricultural
Lands" criteria and thus the designation for"Productive Agricultural Lands."
It appears that the criteria were simply copied from the General Plan 2005 and pasted in ,
the Draft General Plan 2040 with little or no analysis regarding the actual land
characteristics meeting the criteria. Specifically, in the Draft General Plan 2040 I am
referring to the following criteria for"Productive Agricultural Lands":
Productive Agricultural Lands: Productive agricultural lands are those with better
potentialfor sustained high agricultural yields because ofsoil type, climate, topography,
or otherfactors (5-acre minimum lot size).
Productive agricultural lands were determined by including thefollowing lands
emphasis added]:
Lands identified as "Important Agricultural Lands" on the 2005 General Plan
Land Use Pattern Allocation Guide maps.
Lands identified in the Agricultural Lands ofImportance to the State ofHawaii
ALISH) classification system as "Prime" or "Unique".
Lands classified by the Land Study Bureau's Soil Survey Report as Class B
Good" soils. (There are no Class A lands on the Island ofHawai`i)
Lands classified as at least "fair"for two or more crops, on an irrigated basis, by
the USDA Natural Resource Conservation Service's study ofsuitabilityfor various
crops.
Mr.Michael Yee,Director
Department of Planning
Comments on General Plan 2040,August 2019 Draft
Page 3 of 5
In North and South Kona, the "coffee belt", a continuous band defined by
elevation, according to inputfrom areafarmers.
State agricultural parks.
In my district I am aware of areas designated "Productive Agricultural" that do not meet
these criteria except that they had have been identified as "Important Agricultural Lands"
on the General Plan 2005 LUPAG maps. In particular, I am aware that the lands for the
proposed Nakahili Workforce Family Agricultural Community (near the intersection of
Mamalahoa Highway with Waikoloa Road) do not meet the above criteria:
The lands are identified in the ALISH classification system as "Other" (not"Prime" or
Unique")
The Land Study Bureau's Soil Survey Report classifies the soils of the lands soils as
Class D "Poor" soils (not Class B "Good" soils)
The USDA Natural Resource Conservation Service classifies approximately 96 percent
of the soils as within Waikaloa-Pu`u Pa complex and the USDA's Farmland
Classification ofthe lands is "Not prime farmland"
The lands are not in North and South Kona and is not in the "coffee belt"
The lands are not a State agricultural park.
While I have not done a comprehensive analysis of other lands in my district designated
Productive Agricultural Lands" on the Draft General Plan 2040 Future Land Use Map,
I would like to see better analysis for this designation before the General Plan 2040 is
finalized.
I raise these concerns about the land use designations on General Plan 2040 Future Land
Use Map because I am also a strong advocate for the working families in my district and
beyond, who are striving to afford Hawai`i's high cost ofliving, including high housing
costs. Our working families are struggling with housing availability and cost—and this
holds for both rental and for-sale homes.
My concerns about housing availability and cost arise from the results of several
projections and studies regarding population growth and housing needs:
Population continues to grow: The number of people residing in South Kohala has
increased faster than for the County as a whole. Average annual growth in South Kohala
is estimated at 3.0%between 2000 and 2010, and 1.8% between 2010 and 2018,
compared to 2.2% and 1.3% for the County in the respective periods. South Kohala's
more rapid growth is attributed to its jobs base and accessibility to additional
opportunities in the North Kona District immediately to the south.
Housing demand continues to surpass housing supply: Population growth and
household formation mean more housing supply is needed, but the backlog for primary
Mr.Michael Yee,Director
Department of Planning
Comments on General Plan 2040,August 2019 Draft
Page 4 of 5
resident-oriented housing in Hawaii County remains formidable. A 2015 DBEDT study
forecasted the need for 19,600 to 20,100 additional homes by 2025. We should be adding
some 1,600 to 2,000 new primary residential homes per year to meet need. In contrast,
private residential permitting for Hawai`i County averaged only 784 units per year
between 2015 and 2017.
Short supply leads to crowding and less attainable prices: Even when homes are
available, they are often not affordable to working people and average households, and
17% of households in North Hawai`i (including North and South Kohala and Hamakua)
are crowded and/or doubled-up. Median home values are notably higher in South Kohala
about$480,000) and North Hawai`i (about$434,000)than for the County as a whole
about $335,000).
The Draft General Plan 2040 supports these points in the Summary ofKey Findings
section with subsections such as:
Roughly 50% growth by 2040.
Housing is a burden for more than 50% ofhouseholds.
Housing remains unaffordable
Households remain overcrowded
There are many positive policies in the General Plan 2040 supporting the provision of
providing equitable and safe housing for all, but I believe that these polices are not fully
supported by the Future Land Use Map. The housing and land use policies should
support flexibility from the Future Land Use Map designations for worthy affordable and
workforce housing projects regardless of Future Land Use Map designations. Some of
these projects may only be viable on lands outside the Urban Growth Boundaries due to
landownership, land acquisition costs (e.g. non-urban designated lands are often available
to developers at lower costs). Especially in the cases where developers are stepping up to
provide all infrastructure (water, wastewater, etc.), these projects deserve consideration
on their merits and should not be outright refused solely on the Future Land Use Map
designations, which cannot foreseeably anticipate all land use needs for housing over the
next 20 years.
In a recent"listening" session on the General Plan Update at the Waimea Community
Association monthly meeting, Ms. April Surprenant made the statement (paraphrasing)
that"Hawai`i County has enough appropriate zoning to allowing building homes to
address our needs for the next 100 years". When I pressed this issue, she did
acknowledge that affordability ofthe land thus affordable housing construction would be
problematic. A categorical statement of Hawai`i County having a plethora of land
availability conducive to affordable housing construction is misleading. We have to do
better.
Mr.Michael Yee,Director
Department ofPlanning
Comments on General Plan 2040,August 2019 Draft
Page 5 of 5
I would like to see explicit polices in the General Plan 2040 that provide the Council
with the authority to approve worthwhile workforce housing projects outside of the
established Urban designation and Urban Growth Boundary areas, particularly on non-
productive agricultural land. As an example, the General Plan 1989 had a "floating zone"
concept related to locating industrial and resort retreat areas outside of the standard
LUPAG map designations. Such a "floating zone" concept for resident workforce
housing could be implemented in the General Plan 2040 to enable workforce housing in
areas outside ofUrban designation and Urban Growth Boundary areas to take advantage
of changes in population, housing preferences and types, new concepts and trends,
economic influences, and other situations.
We are in a housing crisis and we need the flexibility to designate more areas for
housing. Many undeveloped areas within Urban designation and Urban Growth
Boundary areas are not being developed for housing. There may be many reasons for
thisthe high land cost, individual developer or landowner financing or economic
viability, infrastructure needs, the County of Hawaii's procurement process, etc. If
private developers have the wherewithal, and the ability to develop viable housing in
areas outside of Urban designation and Urban Growth Boundary areas, the General Plan
2040 should have policies that are supportive ofthese initiatives provided there is
Council review and oversight.
I would be happy to meet with you and your staffto discuss any of the matters raised in
this letter in further detail and to work with you or your staff in drafting polices for
inclusion in the Draft General Plan 2040. Please feel free to call (
or email (tim.richards a@hawaiicounty.gov).
Aloha,
71g,c,4
HERBERT M. "TIM" RICHARDS, III