2024-04-02 PL-CCI-2024-000003 Bill 121 CJ Jeppson Testimony

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From: CJ Jeppson To: W PCtesti mony Subject: Recommended Amendment to Ownership Consent in Section 25-4-17.1 of Bill 121 Date: Tuesday,April 2,2024 4:44:31 PM Dear Chairperson Lin and Esteemed Members of the Windward Planning Commission, My name is CJ, and I am a managing member and manager of many businesses. I write concerning the consent requirements stipulated in Section 25-4-17.1(a) of bill 121. The section requires, "To register, a hosting platform shall complete and provide a hosting platform registration to the director in a form prescribed by the director,pay a registration fee of$100, and agree in writing to: (1) Obtain written consent from all owners or operators of transient accommodation rentals for the disclosure: of the information required by the director." (emphasis added) While the intention of this requirement is clear and its purpose sound, its application may prove cumbersome and misaligned with the operational structures of many businesses. For instance, within our business, I have been empowered by all members to act as the singular decision-making authority on matters such as these. The necessity to gather written consent from each individual owner, despite their prior delegation of authority to me, introduces an unnecessary layer of bureaucracy that contradicts established business practices and could delay compliance and operations needlessly. I propose an amendment to this section, allowing for a managing member or an authorized agent to provide consent on behalf of all owners for businesses specifically,provided such authority is documented and recognized within the company's governing structure. For simplicity, here is an example of what the amendment could look like, starting at the (1): "(1) Obtain written consent for the disclosure of the information required by the director from either all individual owners of transient accommodation rentals or from a duly authorized representative in the case of legal entities where such authority is vested in a managing member or an equivalent position within the entity's governance structure; and" This adjustment would reflect the realities of business operations and maintain the integrity and intent of the registration process without placing undue strain on entities that contribute to our local economy. By making this amendment, the Commission would facilitate a more efficient registration process for transient accommodations while respecting the internal governance structures of the businesses that operate them. I urge the Commission to consider this practical amendment and look forward to your favorable action on this matter. Mahalo, CJ