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Communication No. 2013 -47 <br />Mr. Duane Kanuha, Director, <br />Hawaii County Planning Department <br />Aupuni Center, 101 Pauahi St, <br />Hilo, HI 96720 <br />July 17, 2013 <br />Dear Mr. Kanuha, <br />The Action Committee of the Puna Community Development <br />Plan finds that the activities described in the Application to <br />Amend Special Permit No. 1 1 22 by Hawaii Volcano Circus <br />(HVC) are largely consistent with the Puna Community <br />Development Plan. We recommend that the applicant modify <br />and amend the references they cite from the PCDP, specifically, <br />deleting all references to being a village center. j-his <br />recommendation considers that commercial zoning is not <br />presently designated in or near the applicant's property. <br />Commercial zoning is a requirement for developing a proper <br />Village Center as referenced in the PCDP. <br />In addition, we believe HVC /SPACE references to affordable <br />housing, Section 3.3.2e - "Increase the availability of <br />accessible and affordable housing through .... Innovative <br />housing tenure arrangements such as co- housing, limited <br />equity cooperatives and community land trusts ", along with <br />their desire to accommodate long term overnight camping, and <br />the possible development of substandard structures are not <br />consistent with PCDP goals. It also raises concerns over public <br />health and safety and environmental quality. <br />Several other elements of the HVC /SPACE application are <br />supported by the PCDP, and should be encouraged, namely <br />1. The SPACE farmers market is strongly supported in the <br />PCDP. The SPACE farmers' market only allows items that have <br />been made or grown on the Big Island (except for the swap <br />meet items on the second Saturday). The Certified Kitchen that <br />