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could be revoked for a single disturbance of quiet hours. Revocation of a registration should be a last <br /> resort for the County after several attempts to bring a platform into compliance have failed. We <br /> recommend changing this to read: "may cancel a hosting platform registration after the platform has <br /> received three or more final judgments against it for one or more violations of Division 1.2 of this <br /> chapter." <br /> Amend the Definition of"Transient" <br /> We support the Planning Director's recommendation to maintain the definition of"transient" or <br /> "transients" to mean "any visitor or person who rents or uses lodging or dwelling unit, portion thereof, <br /> for thirty consecutive days or less and whose permanent address for legal purposes is not the transient <br /> accommodation rental." The Hawai'i County Planning Department as well as hosting platforms already <br /> have systems and operations in place to utilize the 30 days or less definition and changing the definition <br /> of"transient" to be a longer period of time creates a significant administrative burden. It could also <br /> create legal challenges from rental properties since a property could have been legally rented for periods <br /> of 30 days or more but would be newly required to register as a transient accomodation rental (TAR) to <br /> continue the practice and is ineligible to do so. This is similar to the issue in the recent Hawai'i Legal <br /> Short-Term Rental Alliance v. City and County of Honolulu lawsuit in which the Hawai'i Legal Short-Term <br /> Rental Alliance (HILSTRA) prevailed. <br /> We also recommend changing the exemptions in the definition of"transient" in Chapter 25-1-5 to match <br /> the exemptions for transient accommodations tax in the Hawai'i Revised Statutes in Chapter 237D-3, <br /> which rely on the characteristics of a structure rather than a person, e.g., exempting a student dormitory <br /> rather than lodging occupied by a student. Under the current draft, any full-time students, military <br /> personnel, or temporary health-care employees would not be subject to transient accommodations <br /> regulations, even if the stay was personal and recreational.These exemptions offer limited benefit as <br /> there is no way for most booking services and hosting platforms to confirm the identity of a traveler to <br /> show that they qualify for exemptions and could create incentives for scofflaws to cater to individuals <br /> inaccurately claiming to qualify for exemptions. <br /> Thank you for the opportunity to provide comments.We look forward to working with Hawai'i County as <br /> it contemplates Bill 121. Please do not hesitate to contact me if there is any additional information we <br /> can provide. <br /> Mahalo, <br /> Mackenzie Chase <br /> Regional Manager, Hawai'i <br /> Expedia Group <br /> MaChase@ExpediaGroup.com <br /> O <br /> 1 1 1 1 Expedia Group Way West I Seattle,WA, 98119 I USA I T+1 206 481 72001 F+1 206 481 7240 <br /> expediagroup.com <br />