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HomeMy WebLinkAboutCOM 0675.620 2022-2024 P/ PCPuID bill 12► OAMM.05 AHLA III eIII AMERICAN HOTEL&LODGING ASSOCIATION H AWA I'I HOTEL ALLIANCE Gerard C.Gibson President Hawai'i Hotel Alliance , a October 31, 2024at C f a Ashley Kierkiewicz, Chair Policy Committee.on Planning, Land Use and Development ei (--7 Hawaii County Council � .. Hawaii County Building �' 25 Aupuni Street Hilo, HI 96720 ``9 Comments on Bill 121 Draft 4 Dear Chair Kierkiewicz and Members of the Policy Committee on Planning, Land Use and Development, We appreciate the Council's efforts to reign in Illegal Transient Accommodation Rentals and to provide a set of regulations that will ensure and compel compliance with our County's laws. As written, this bill helps with the enforcement of illegal TAR's by: • Implementing Mandatory Registration of Hosting Platforms, requiring data from platforms for enforcement, and the intent to require mandatory delisting of noncompliant listings on any hosting platform, and; • Requiring posting on all advertisements of a TAR's certificate or registration, and; • Making the advertisement of a TAR without a valid registration an infraction of the code, and; • Setting standards of care that ensure TAR's are responsive to community impact, and; • Establishing fines sufficient to compel compliance with the law. Of concern are the nature and number of TAR's that this bill will allow and the inability to enforce the commonsense regulations that this bill hopes to put in place. Comm. 0 U fis Ref. To: Ref. Dote NOV — 8 2024 Ashley Kierkiewicz, Chair Page 2 Unhosted units are a pandora's box to unlimited TAR's. TAR's are the number one issue of concern as outlined in Hawaii County's Destination Management Action Plan. In addition to taking away housing supply from local families, TAR's destroy the residential nature of our communities, effectively turning our homes into illegal hotels. As we have learned over the past decade, county efforts to work in good faith with hosting platforms have had a negative effect on regulating illegal TAR's. In almost every case across Hawaii and the country where counties have attempted to enter into MOU's or collaborate with hosting platforms the real losers were the very residential communities the counties' officials were trying to protect. Hawaii County has experienced this firsthand. Our efforts to work collaboratively with platforms in 2019 with the passage of then Bill 108 resulted in more confusion in regulating TAR's, the registration of more than 6,000 TAR's (most of which were previously illegal), and as a result of the inability to enforce the laws platforms helped to put on the County's books, we now have more illegal TAR's operating throughout Hawaii County than ever before. Simply put, hosting platforms cannot be allowed to shape our County's policy on this critical issue of housing security for our residents and allowing unhosted TAR's in any form is an Achilles' heel in perpetuity to any meaningful enforcement by our County. Of equal importance is the need for a comprehensive plan to ensure enforcement is viable. As it stands, very little enforcement is possible under the existing code. As written, some of the provisions of this bill provide for the tools and fines requisite for enforcement. However, enforcement will require holding platforms accountable to the provision set forth in this bill which is only possible with funding full time positions within the County for the explicit and exclusive purpose of enforcing these rules. We urge the County to ensure that enforcement remains a priority. Thank you so much for all,your effort and hard work on this very important issue. Mahalo and Aloha, 73--e-(H � w Jerry Gibson Kekoa McClellan President Representative Hawaii Hotel Alliance American Hotel and Lodging Association