BEFORE
THE LAND USE COMMISSION
OF
THE STATE OF
Docket NO.A00-734
In the Matter of the
Petition of Castle and Cooke Homes Hawaii, INC.
And
Pacific Health community,
INC.
TESTIMONY
OF THE OFFICE OF PLANNING
IN PARTIAL SUPPORT OF THE PETITION
IMPACTS UPON THE RESOURCES OF THE
AREA
Groundwater and Potable
Water Impacts
The City and County of Honolulu Board of Water Supply
(BWS), by letter dated
1. A water master plan
for the proposed development should be submitted for our review and
approval. The water master plan should
include the proposed development layout along with the proposed water
facilities and necessary hydraulic calculations.
2. Board of Water Supply
(BWS) Rules and Regulations require the use of nonpotable water for the
irrigation of large landscaped areas if a suitable supply is available. The applicant should research and address the
availability and use of nonpotable water for irrigation and developing a dual
water system. The BWS is evaluating the
feasibility of recycled water application over the potable aquifer in
3. We recommend the use
of drought tolerant/low water use plants and xeriscaping principles for all landscaping. We also recommend the installation of an
efficient irrigation system, possibly using drip irrigation. The irrigation system should incorporate
moisture sensors to avoid the operation of the system in the rain and if the
ground has adequate moisture.
4. The project may cause
a loss of recharge because of increased runoff from this urban
development. Because the current
sustainable yield for the Waipahu-Waiawa aquifer was derived with the
assumption that these parcels remained in agriculture, the change in land use
may impact the adopted sustainable yield.
In reference to Potential Changes to Groundwater Availability (section
4.6.2, page 4-11), there should be discussion on the impact of the development
decreasing the sustainable yield of the Waipahu-Waiawa aquifer due to increased
runoff from the development decreasing the sustainable yield of the
Waipahu-Waiawa aquifer due to increased runoff from the development’s streets,
gutters, roofed and paved areas diverting water that currently provided aquifer
recharge. The recharge losses are most
significant at Koa Ridge Mauka, which receives an average annual rainfall of 50
inches to 80 inches. Therefore, within
the annual rainfall area of 50 inches or higher, we recommend design features
maximizing landscaped areas and utilizing percolation and settling basins which
would minimize loss of recharge to the basal aquifer and address storm water
runoff control.
5. Water availability for
the development
The developer will be
required to install a water source and obtain a water use permit. However, at this time, it cannot be
determined if there is adequate groundwater supply in the Waipahu-Waiawa water
management area to accommodate the vacant Urban designated lands of Central
Oahu, Ewa and Honolulu in addition to the Koa Ridge development. There are several factors that add to the
uncertainty of groundwater supply and these factors should be addressed prior
to the Land Use Commission taking action of the proposed boundary amendment
application.
a. On
b. On
August 22, 2000, the Hawaii Supreme Court’s decision on the Waiahole Ditch
contested case indicated that the CWRM must complete the State Water Resources
Protection Plan prior to the adoption of the County Water Use and Development
plans for affirming groundwater sustainable yields and in stream flow standards
that guide water planning and regulation.
The availability of the Waiahole Ditch water for
c. The
State Agricultural Water Use and Development Plan has not been completed and agricultural
water demands for Leeward Oahu have not been identified. This plan needs to be completed to determine
water allocations for agriculture and urban demands that are in competition for
the use of groundwater from the
6. Impacts to
Downgradient BWS Wells
We are concerned about
the proposed source wells adversely impacting our downgradient wells in
The State Commission on
Water Resource Management (CWRM) should conduct groundwater-modeling analyses
to evaluate the potential impact of well pumpage upon our existing wells.
7. The Koa Ridge
development is within the proposed wellhead protection area and source water
protection criteria as established by the State Department of Health, must be
addressed.
8. The EA should discuss
mitigation measures for loss of recharge and prevention of contamination the
underlying aquifer.
Drainage Patterns
The property does not contain any perennial streams. Runoff is ultimately discarded into the
adjacent gulches and streams adjacent to the Petition area, which are
tributaries to Waikele and Waiawa Streams.
Waikele Stream goes thro ugh developed areas in
The Waiawa Property is within the Panakauahi Gulch
system, which discharges into Waiawa stream in a southwestern direction.
The Koa Ridge Mauka area slopes both in the northwest
direction toward Kipapa Stream and the southwest direction toward small unnamed
gulches that branch out from the main Panakauahi Gulch, eventually going into
Waiawa stream.
The Flood Insurance Rate map designates the area as Zone
D, which indicates areas in which flood hazards are undetermined. The
Petitioner indicates that since the Petition area is located on plateaus
bordered by gulches, flooding on the Petition Area would be unlikely. However,
the Petition also indicates that waters flowing into the adjacent gulches would
be upstream of existing development in
According to consultant studies done in 1996 and 1999,
there are no candidate proposed, or listed threatened or endangered species in
the Petition areas. However, within the adjacent gulches and gullies, outside
of the Petition areas, there is a mixture of native and introduced plants,
particularly in the higher elevations of the Petition area.
Waiawa had a brush fore in 1998, and guinea grass and
trees are the predominant plants on this site.
The northeast portion of Koa Ridge Mauka has fallow
pineapple fields, with surrounding guinea grass, and other types of
grasses. The central portion of Koa
ridge Mauka is cultivated in pineapple, with the remainder in open grassland.
The eastern area of Koa ridge Makai contains seed corn
with pineapple to the north and southwest of Waihole ditch. The remainder of
the area contains trees and grasslands.
Fauna
According to the consultant’s studies, there were no
candidate, proposed, listed, threatened or endangered species found on the
Petition Areas.
Koa Ridge Makai had no signs of pigs, or small mammals,
such as mongoose, rats and mice; however, the small mammals were believed to be
present. Birds seen on the property were common except for the golden plover.
Waiawa may contain pigs, since pig hunters were seen.
Koa Ridge Mauka contained signs of mice, rats, mongoose
and pigs in the Petition area. Many birds were found on the site, mostly
non-native.
According to the Petitioner’s study, the only State
historic site is on Koa Ridge Makai, which is the Waiahole Ditch built in 1913.
The ditch runs along the upper portion of Koa Ridge Makai and the lower portion
of Koa Ridge for about 3,600 linear feet. The ditch is open, except where the
ditch runs under roads, and there are two metal pipe siphons, which carry the
water across two steep gullies in the southern portion of Koa Ridge Mauka. The
consultant did find one basalt adz within the northern portion of Koa Ridge
Makai, but no artifacts were found within the other Petition areas. Kipapa
Ditch, which is on the west side and adjacent to Koa Ridge Makai, is also a
State historic site, constructed in 1930.
Cultural Resources
According to the Petitioner, there are no cultural
practices or activities on this site; however, access to the Kipapa Ridge Trail
for hunting and native gathering in the adjacent areas may be significant for
traditional and customary native Hawaiian practices.
The Office of Hawaiian Affairs, by letter dated
Scenic Resources
According to the petition, the development of the
Petition Areas for residential, commercial and community health uses will alter
the existing views from the H-2 freeway. Koa Ridge Mauka offers an exceptional
view.
Air Quality
According to the Petitioner’s consultant, the air quality
in the area is good since agricultural cultivation has declined. Air quality
data from Department of Health monitoring stations suggest that air quality
standards are being met.
By letter dated
“ Due to the characteristics of the soil in the area, there is a significant potential for fugitive dust to be generated during clearing and removal of debris, grubbing, grading, and excavation of the various project sites, Implementation of adequate dust control measures during all phases of construction is warranted. Construction activities must comply with provisions of Chapter 11-60.1, Hawaii Administrative Rules, section 11-60.1-33 on Fugitive Dust. The contractor should provide adequate means to control dust from road areas and during the various phases of construction activities.”
Aural Quality
The
State Department of Health by letter dated
“Potential noise problems may occur in areas designated for mixed use. Mixed use communities should be designed to minimize impacts on existing residential areas from commercial/industrial areas…Contractor shall obtain a Community Noise Permit if the noise levels from construction activities are expected to exceed the maximum permissible sound levels of the regulations as stated in Section 11-46-6(a), Hawaii Administrative Rules…The contractor shall comply with the requirements pertaining to construction activities as specified in the rules and the conditions issued with the permit as stated in section 11-46-7 (d)(4)…Sound levels emanating from stationary equipment, such as the HVAC system, shall comply with the provisions of the Department of Health’s Administrative Rules, Chapter 11-46, “Community Noise control.”
Socio-Economic and Market Impacts
The
State Housing and Community Development Corporation of
comments regarding the proposal, as follows:
“Policies
A(3) and B(3) of the State Housing Functional Plan seek to ensure that (1)
housing projects and (2) projects which impact housing provide a fair
share/adequate amount of affordable homeownership and rental housing
opportunities. Petitioner has indicated
that for-sale housing units would be provided in a variety of styles and prices
and that they would meet State and County affordable housing guidelines and
requirements for pricing and affordable percentages. Petitioner has also indicated that
consideration would be given to providing affordable rental housing and special
needs housing as needs are identified.
The
socio-economic impact assessment shows that the
According
to the Final Review Draft of the Central Oahu Sustainable Communities Plan
(COSCP) dated March 2001, the vision for Central Oahu in the year 2025 shows
population growth from 149,000 in 2000 to over 173,000 in 2025. The vision estimates an addition of 11,000
new housing units to the existing 45,000 homes in
Agricultural Impacts
By
letter dated
“…
Is concerned about the removal of hundreds of acres of prime agricultural lands
in the Koa Ridge Makai, Koa Ridge Mauka, and Waiawa areas. Our concerns are mitigated by the following
information. We note that the 226 acres of
pineapple production to be displaced by the project will be replaced with lands
in the Helemano area north of
The
DOA also states that the Waiahole Ditch:
“…
traverses the petition area at the H-2.
Appropriate measures to maintain ditch easements and prevent trespass
need to be planned and implemented in coordination with the Agribusiness
Development Corporation.”
The United States Department of Agriculture also provided
comments by letter dated
“Part of our agency’s mission is to identify and encourage the protection of prime, important, and unique farmlands for future generations. Of the approximately 1,200 acres within the project area, most of the area is designated prime with about half of the Koa Ridge Mauka site designated as unique (figure 11). The Petitioner has st5ated that ‘the project will not impact agriculture production in the region, county or state.’ Additionally, stated is ‘The project will not negatively impact the supply of land needed for diversified agriculture on the island or within the State.’ Several other statements are made that diminish the importance of these lands for future agriculture.
This project would consume a significant acreage of prime farmlands. Each petition reviewed by this office for over a decade that involved conversion of prime farmlands has stated that there would be no significant impact on the availability of these lands. Cumulatively, the impact is significant. Have we fully considered what level of agricultural self-sufficiency we desire? Even the Koa Ridge Mauka lands, which are stated to be lower quality (unique) for agricultural production, are prime for timber species such as Koa and other species. At such a time when the cost of imported fossil fuel becomes a major issue, we will want to once again consider biomass crops that in the recent past were only slightly not cost effective. Will we have the land available for that?
We have no illusions that the project will be denied because of these concerns. It is merely our hope that this letter will heighten the level of concern for the loss of our finite high quality agricultural land resource.
Lastly, an increased flooding hazard through decreased rainfall infiltration could have major impacts on urban areas of the coastal plain as well as portions of the Waiahole Ditch. A close scrutiny of the hydrology is essential.”
ADEQUACY OF PUBLIC
SERVICES AND FACILITIES
Water Service
The Board of Water Supply provided comments on the availability of potable water for the development, by letter dated June 29, 2001 which states that it cannot be determined if there is adequate groundwater supply in the Waipahu-Waiawa water management area to accommodate the vacant Urban designated lands of Central Oahu, Ewa and Honolulu in addition to the Koa Ridge development. (See section on Groundwater and Potable Water Impacts).
The State Department of Health has provided
comments by letter dated
1. “The project proposes to develop one or more new sources of drinking water as well as storage and distribution facilities with the intent to tie into the Honolulu Board of Water Supply’s Waipio Heights Water System. Please be advised that, prior to use as a new source of potable water serving an existing public water system, the Director of Health must approve this source. This approval is based upon the submission, review, and acceptance of an engineering report, which demonstrates that the water from this source or sources either meets all federal and state drinking water standards or can be treated to meet these standards.
2. If the project does not connect to the Honolulu Board of Water Supply system, it will be subject to a number of other requirements prior to its ability to provide water to support the development in addition to the source approval mentioned above.
3. The project does not appear to propose any activity within the Hydrologic Zone of Contribution of the U.S. Navy Waiawa Shaft which was identified and submitted by the Department of Health to the Land Use Commission in 1990. However, we would request the applicant to verify this preliminary finding.”
The Commission on Water
Resource Management by letter dated
1. “We recommend coordination with the county government to incorporate this project into the county’s Water Use and Development plan.
2. A Well Construction Permit and/or a Pump Installation Permit from the Commission would be required before ground water is developed as a source of supply for the project.
3. The proposed water supply source for the project is located in a designated water management area, and a Water Use Permit from the Commission would be required prior to the use of this source.
4. If the proposed project alters the bed and banks of a stream channel, the project may require a stream channel alteration permit.
5. As noted above and in the subject document, well construction, pump installation and water use permits would be required for the development of new wells to serve the project. The State water code identifies seven conditions to obtain a water use permit, which includes analyses of water availability and impact on existing wells.
In March 2000, the Commission adopted a revised sustainability yield for the Waipahu-Waiawa Aquifer of 104 millions of gallons per day (mgd) utilizing a milestone approach. The Commission has also revoked unused water allocations in the aquifer. At present, allocations from the Waipahu-Waiawa Aquifer total 82.501 mgd.”
Roadways
The State Department of Transportation provided the
following comments, dated,
“This project will have a significant impact on the State transportation system. As such, the developers should be responsible for providing their pro rata share of required regional transportation improvements.
1. The applicant should coordinate with adjacent developers (Gentry Investment Properties and Pacific Health Community) to investigate the possibility of cost share arrangements for offsite transportation roadway improvements.
2. The Traffic Impact Analysis Report (TIAR) states that with the project, the interstate H-1, East and West of the Waiawa Interchange (IC) will operate at a level of service (LOS) E & F, Eastbound and Westbound during the AM and PM peak hours in the year 2020. Our Highways Division is studying improvements to H-1, including a widening alternative. The applicant should assist in our transportation planning studies by identifying vehicle trip reduction programs such as its existing express bus service and assessing the program’s impacts, and continue its participation in LOTMA and other joint transportation efforts.
3. The TIAR states that with the project, the following key intersections will be operating at an unsatisfactory LOS in the year 2020:
a.
b.
c.
d. Ka-Uka Boulevard/Moaniani Street/H-2 Southbound off-ramp
The TIAR
should incorporate, as an addendum, 1) a project construction schedule
including the corresponding required roadway mitigations to be provided by the
developer(s) for these intersections to operate at a satisfactory LOS D or
better, and 2) an analysis of the intersection of
4. On Appendix B Infrastructure Report, pate 4-7:
a. Proposed Drainage System Infrastructure, the developer should satisfy flood control and water quality issues. There should be no increase in “q” from the development to any state highway or facility.
b. The applicant will satisfy Federal Highway Administration requirements for obtaining approvals for the new Koa Ridge Interchange.”
Wastewater
The State Department of Health provided comments by
letter dated
“The subject project is located in the No Pass Zone and in the critical wastewater disposal area as determined by the Oahu Wastewater Advisory Committee…As the area is located within the City sewer service system, we will require that the project be connected to the City’s sewer service system. No other means of wastewater treatment and disposal is allowed.”
Solid Waste
The State
Department of Health submitted comments by letter dated
1. The Office of Solid Waste Management (OSWM) recommends the development of a solid waste management plan for the project that encompasses all phases from construction to occupation. Examples of elements that the plan should consider include the recycling of greenwaste generated during land clearing activities, the use of locally produced compost in the landscaping of the project, and the provision of recycling facilities in the design of the project.
2. Consider the use, to the extent possible, of recycled content building products in the construction of the project.
3. The developer shall ensure that all solid waste generated during the construction of the project is directed to a permitted solid waste facility.
Civil Defense
By letter dated
“…that the
developer plan for emergency warning notification in the
Schools
The Department of Education provided comments by letter
dated
1. The Petitioner states that the proposed project would contain between 6,000 and 7,500 units at buildout. Based on the higher unit count of 7,500, the DOE estimates that the project would generate the following number of students:
SCHOOL TYPE STUDENTS
Elementary 1,875
Middle 750
High 750
2. The DOE will be seeking a fair-share contribution primarily in the form of a land dedication. For 7,500 units, the land dedication requirement amounts to 70 acres. Any remaining fair-share balance owed after the land dedication would be satisfied through a cash contribution based on the DOE’s fair share formula.
3. Given the number of units proposed, there will be a need for three elementary schools of 12 acres each and one middle school of 20 acres. The equivalent of one-half of a high school will also be needed (see item 4 below).
The petitioner indicates one elementary school each in Koa Ridge Makai and Koa Ridge Mauka. The DOE concurs with those general locations. We will need to coordinate with the Petitioner to determine the most suitable locations for the third elementary school and the middle school.
4.
A 50-acre high school site is needed somewhere within
the Koa Ridge or Waiawa by Gentry developments.
Our discussions with the Petitioner will include the need for a high school site in the region.
5. We request that the State Land Use Commission include the DOE’s standard condition should the proposed project be reclassified. The language of the condition is as follows:
Petitioner shall contribute to the development, funding, and/or construction of school facilities, on a fair share basis, as determined by and to the satisfaction of the Department of Education. Terms of the contribution shall be agreed upon, in writing, by the Petitioner and the DOE, prior to Petitioner applying for county rezoning.”
CONFORMANCE TO THE COASSTAL ZONE MANAGEMENT PROGRAM
The Petition indicates that the project area lies outside the Special Management Area, but is within the State Coastal Zone Management area. No Special Management Area permit will be required.
CONFORMANCE WITH COUNTY PLANNING AND ZONING
The petition area is designated by the City and
DISCUSSION
The City and County of Honolulu has developed a Final Review Draft, dated March 2001, of the Central Oahu Sustainable Communities Plan (COSCP). The COSCP addresses the future development of the Central Oahu area, including the subject Petition Area. According to the Department of Planning and Permitting, the COSCP proposes an Urban Community Boundary to “give long-range protection from urbanization for 10,500 acres of prime and unique agricultural lands and for preservation of open space while providing adequate land for residential, commercial, and industrial uses needed in Central Oahu for the foreseeable future.” The Petition Areas at Koa Ridge Makai and Waiawa are within the Urban Community Boundary. Koa Ridge Mauka is not included in the Urban Community Boundary area.
According to the COSP (Final Review Draft, March 2001) Central Oahu’s likely share of Oahu population in the year 2010 (16.4%) will be within the current General Plan 2010 population distribution range (14.9 – 16.5%). By 2025, Central Oahu’s share of Oahu population (at 16.8%) is projected to be slightly above the current General Plan guidelines.
The Petition should clarify and explain how the proposed phasing of the residential units will relate to the population projections in light of the units that are proposed and already approved but yet unbuilt for Central Oahu. According to the COSP, p. 2-22, approximately 13,130 residential units were previously approved for Central Oahu while the total residential units proposed for Central Oahu amounted to 11,050. The combined unbuilt total of previously approved and proposed units is 24,180 as of June 200.
In their letter to OP dated June 29, 2001, the Board of Water Supply states that there should be a discussion on the impact of the proposed development decreasing the sustainable yield of the Waipahu-Waiawa aquifer due to increased runoff from the development’s streets, gutters, roofed and paved areas, thereby reducing aquifer recharge. They state that the recharge losses are most significant at Koa Ridge Mauka, which receives an average annual rainfall of 50 inches to 80 inches. It also cannot be determined if there is adequate groundwater supply in Waipahu-Waiawa water management area to accommodate the vacant Urban designated lands of Central Oahu, Ewa, and Honolulu in addition to the Koa Ridge development. Water source development for the proposed project may impact supply from existing downgradient wells.
The proposed project will further add to traffic congestion in the region, especially during peak hours. Existing school facilities are operating near or above capacity. Affordable housing for the future employees at the proposed Pacific Health Center should be addressed. A previous reclassification in the Waiawa area generated substantial concern regarding possible groundwater contamination of the U.S. Navy Waiawa Shaft.
The proposed reclassification 571.5 acres at Koa Ridge Makai to the west of H-2 Freeway is a logical extension of future urban growth as is the proposed reclassification of the 190.8-acre Waiawa site which is planned in coordination with the existing Waiawa Gentry Urban District. However, the 485.5-acre Koa Ridge Mauka area is further removed from existing urban areas and will be very costly in terms of the required public services and facilities. Its importance for groundwater recharge, open space and visual amenities should also be recognized.
The Office of Planning recommends reclassification of Koa Ridge Makai and Waiawa provided that certain conditions are met. Koa Ridge Mauka should remain in the Agricultural District.
RECOMMENDATION
Based on agency comments received to date and the foregoing information and analysis, the Office of Planning recommends that the Petition by Castle and Cooke Homes Hawaii, Inc. and Pacific Health Community, Inc., to reclassify approximately 1,247.983 acres of land, Tax Map Key TMK: 9-4-06: por. 1, por. 2, por. 3, por. 29; 9-5-03: por. 1, por. 2, por. 4; and 9-6-04: 21 at Waipio and Waiawa, Oahu, State of Hawaii, from the State Land Use Agricultural to the Urban District, be approved in part. We recommend that the Koa Ridge Makai and Waiawa Petition Areas be approved subject to the following conditions. Koa Ridge Mauka should be denied.
1. Petitioner shall provide affordable housing opportunities for residents of the State of Hawaii in accordance with applicable affordable housing requirements of the City and County of Honolulu. The location and distribution of the affordable housing or other provisions for affordable housing shall be under such terms as may be mutually agreeable between the Petitioner and the City and County of Honolulu.
2. Petitioner shall participate in the pro-rata funding and construction of local and regional transportation improvements and programs necessitated by the proposed development in designs and schedules accepted and determined by the State Department of Transportation (DOT). Agreement between the Petitioner and the DOT as to the level of funding and participation shall be obtained prior to the Petitioner acquiring County zoning or prior to the Petitioner securing county building permits if county zoning is not required.
3. Petitioner shall provide public access to the Kipapa ridge trails and other traditional gathering and hunting trails to the satisfaction of the State Department of Land and Natural Resources.
4. Petitioner shall contribute to the development, funding, and/or construction of school facilities, on a fair share basis, as determined by and to the satisfaction of the Department of Education (DOE). Terms of the contribution shall be agreed upon, in writing, by the Petitioner applying for county rezoning.
5. Petitioner shall provide adequate water source facilities and improvements to accommodate the proposed project. Water source facilities and improvements shall be coordinated and approved by the Commission on Water Resource Management of the State Department of Land and Natural Resources.
6. Petitioner shall provide adequate wastewater treatment, transmission, and disposal facilities as determined by the State Department of Health.
7. Petitioner shall fund and construct adequate civil defense measures as determined by the State of Hawaii Department of Defense, Office of Civil Defense.
8. Should any previously unidentified human burials, archaeological or historic sites such as artifacts, marine shell concentrations, charcoal deposits, stone platforms, pavings or walls be found, Petitioner shall stop work in the immediate vicinity and the State Historic Preservation Division of the Department of Land and Natural Resources (SHPD) shall be notified immediately. The significance of these finds shall then be determined and approved by the SHPD. Subsequent work shall proceed upon an archaeological clearance from the SHPD when it finds that mitigative measures have been implemented to their satisfaction.
9. Petitioner shall implement efficient soil erosion and dust control measures during and after the development process to the satisfaction of the State Department of Health.
10. Petitioner shall design and construct drainage improvements required as a result of the development of the Property to the satisfaction of the Department of Health and the Commission on Water Resource Management of the State Department of Land and Natural Resources.
11. Petitioner shall coordinate with the Agribusiness Development Corporation, and the Department of Land and Natural Resources State Historic Preservation Division, to develop appropriate measures to maintain Waiahole Ditch infrastructure and easements.
12. Petitioner, where feasible, shall implement water conservation measures such as indigenous and drought tolerant plants and turf and incorporate the same into common area landscape planting.
13. Petitioner shall notify all prospective buyers of property of the potential odor, noise and dust pollution resulting from surrounding agricultural uses.
14. Petitioner shall develop the Petition Area in substantial compliance with the representations made by the Petitioner to the Commission. Failure to do so for any reason including economic feasibility, may result in the imposition of fines as provided by law, removal of improvements by Petitioner at Petitioner’s own expense, reversion of the petition Area to its former condition by Petitioner at Petitioner’s own expense, reversion of the Petition Area to its former classification or a change to a more appropriate classification, or any other legal remedies.
15. Petitioner acknowledges and agrees that it has no vested interest or right to develop the Petition Area, as reclassified, until Petitioner has substantially complied with the representations it made to the Commission. Petitioner waives any claims for liability against the State arising from any reversion of the Petition Area.
Dated:
OFFICE OF PLANNING
STATE OF
_____________________
DAVID W. BLANE
Director of Planning