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definition, the title implies the bill is related to both `hosted' and `un-hosted' short-term vacation rentals. Recommendation#2 Clarify the STVR definition to specifically state how the Intemal Revenue Code defines the short-term use of an owner's primary residence. Reason: Department enforcement staff and the public will not know what the Internal Revenue Code does and does not allow unless it is clearly stated in the definition. Recommendation#3 Add to the STVR definition that dwellings where more than five bedrooms are rented are defined in the zoning code as inns, lodges, or hotels. Reason: To make it easier for the public and staff to understand how visitor accommodations are defined without having to dig through the Zoning Code. Recommendation#4 In Section 25-4-XX(a)(1)(B),remove the requirement for a Use Permit to establish a new STVR in the CV zoning district. C' Reason: Most of the commercially-zoned areas within the small rural towns around the island, such as Honokaa, Hawi,Waimea, Pahoa, Kainaliu, and Honomu, consist of Village Commercial(CV)zoning. Land uses within these CV-zoned areas consist of transient accommodations such as hotels, inns, and B&B's along with many service- oriented commercial businesses like restaurants, art galleries, and general retail establishments, which rely on customers that are both residents and tourists in order to be successful.Use Permits are permits-granted by the Planning Commission after a public hearing to ensure there is adequate existing infrastructure to support the proposed use and to ensure the proposed use will not cause a substantial negative impact on the surrounding community. These rural villages typically have adequate infrastructure to support a range of commercial uses and STVR's would pose no different adverse impact than other commercial transient accommodations such as hotels,inns and B&B's. -10-