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HomeMy WebLinkAboutCOM 0675.420 2022-2024August 19, 2024 Councilmember Ashley L. Kierkiewicz µ County of Hawaii Hawai'i County Building 25 Aupuni Street Hilo, Hawai'i 96720 Re: Bill 121, Draft 2 Dear Chair Ashley L. Kierkiewicz, Vice Chair Dr. Holeka Goro Inaba, and members of the Policy Committee on Planning, Land Use, and Development, On behalf of Expedia Group, a family of brands that includes Expedia.com, Hotels.com, and short-term rental leader Vrbo, I am writing to share comments on Bill 121, Draft 2 and our support of Section 6 of the bill, pertaining to hosting platforms, as currently drafted. Expedia Group welcomes balanced regulation and management of short-term rentals and has worked with municipalities around the world to craft, enact, and enforce laws to regulate vacation rentals. Bill 121, Draft 2 will allow county officials to review the tax map key (TMK) number and transient accommodation tax (TAT) ID number associated with transient accommodation rentals (TARS) so county staff can compare listing information to the county's data for registered TARS. Expedia Group shares similar reporting with other counties in Hawai'i, which has helped counties like Kauai to drive a high rate of compliance with its short-term rental laws. Bill 121, Draft 2 establishes clear guidelines to foster collaboration between Expedia Group and Hawaii County. The legislation outlines a process for Expedia Group to share information which will support county enforcement of county laws and regulations. The legislation would also set a consistent standard across the industry by passing a law applying to all hosting platforms. We support maintaining the current definition of "transient" as referring to occupancy of thirty consecutive days or less. The Hawai'i County Planning Department as well as hosting platforms already have systems and operations in place to utilize the 30 days or less definition and changing the definition of "transient" to be a longer period of time creates a significant administrative burden. For example, properties legally renting month -to -month to residents would be newly required to register as transient accommodation rentals to continue this practice. Moreover, any properties that are unable to register as TARS to continue legally renting for periods of 30 days or more may issue legal challenges to the legislation that could forestall implementation. We also recommend changing the exemptions in the definition of "transient" in Chapter 25-1-5 to match the exemptions for transient accommodations tax in the Hawai'i Revised Statutes in Chapter 237D-3, which rely on the characteristics of a structure rather than a person, e.g., exempting a student dormitory 0 11 1 1 Expedia Group Way West I Sea IIle, WA, 98119 ( USA IT +1 206 481 72001 F +1 206 481 7240 expediagroup.com cornrn. Ref, TO' AUG 1i')ale__ Ref. k rather than lodging occupied by a student. Under the current draft, any full-time students, military personnel, or temporary health-care employees would not be subject to transient accommodations regulations, even if the stay was personal and recreational. These exemptions offer limited benefit as there is no way for most booking services and hosting platforms to confirm the identity of a traveler to show that they qualify for exemptions, weakening the efficacy of the ordinance overall. Thank you for the opportunity to provide comments. We appreciate all of Hawai'i County's thoughtful work to craft balanced legislation. Changes to date, including the amendments adopted last month, show the sponsors' commitment to crafting sensible, practical legislation. We look forward to working with Hawai'i County Council as it contemplates Bill 121, Draft 2. Please do not hesitate to contact me if there is any additional information we can provide. Mahalo, Mackenzie Chase Regional Manager, Hawai'i Expedia Group 0 1111 Expedia Group Way West I Sea Itie, WA, 90119 I USA I T+1 206 481 72001 F A-1 206 481 7240 expediagroup.com