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There is no clear necessary reason to change the duration of a short-term rental except as <br /> an additional source of revenue. Parking, noise, and code enforcement rules exist regardless of <br /> rental duration or tenant type. <br /> Recommendation#2: Eliminate the definition of and distinction between "owner- <br /> hosted" and"operator-hosted"; regulate all rentals that are "hosted"in the same <br /> manner. <br /> If one of the purposes of this Bill is to attempt to keep long-term rentals in the rental <br /> market, then why does it matter that the individual that uses the property as his "Principal home" <br /> is an owner or an operator? If it is someone's "Principal home,"that person is a long-term <br /> resident- either a resident owner, or a resident tenant. Housing is key, not ownership. <br /> To discriminate against long-term renters by not allowing them to be employed as a rental <br /> operator, only encourages off-island owners to sell, rather than facilitate at least one long-term <br /> rental. Likewise, as homes can be large and in that case the cost and mortgage beyond an average <br /> income in Hawaii, the opportunity to be a long-term tenant host operator provides opportunity to <br /> create housing in properties that are too expensive for acquisition to most folks. <br /> Recommendation #3: Eliminate the requirement of a notarized affidavit of full <br /> compliance of all health, safety, and code requirements.A declaration that all <br /> information submitted is true and correct to the best of the applicant's knowledge <br /> should suffice. <br /> To require short and mid-term rental owners to swear—under penalty of perjury (which is <br /> A crime)that they are fully compliant with all health, safety and code regulations unnecessarily <br /> discriminate against a particular segment of the community. There is no logical reason for this. <br /> Long-term rental owners do not need to apply for a permit and their premises are not <br /> Validated for full health, safety, and code compliance. Property owners can buy and sell <br /> properties without being in full health, safety, and code compliance. Why does this bill hold <br /> tourists' standards higher than our own residents? <br /> The building and permitting process has been broken for a long time. This fact has been <br /> identified in several national studies by credible institutions, including UHERO. Because of this <br /> fact, it is also common knowledge that many residents have built or modified their properties, <br /> albeit within code and by licensed professionals, however, did not have the time or money to <br /> work within the broken permitting process. <br /> To know, and be responsible for, the environment that created the infamously difficult <br /> permitting process, and then to write regulations that would require all applicants to have all <br /> permits, is disingenuous at best.At worst, it puts residents in an untenable position of having to <br /> cease operations of what for some is the only way they can make ends meet or face a crime for <br /> attesting to a fact they know is untrue. Just as there is no liability for issuing a driver's license, <br /> there is no liability for the county in issuing a registration for an STVR. There is no rational <br /> reason for this requirement except to deter application. <br /> 2 <br />