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From: Thomas Buehlmann
Sent: Monday, May 5, 2025 2:46 AM
To: Council Testimony
Subject: Proposed Bill 47 -Written Testimony cf)
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To Whom It May Concern,
I am writing as a concerned and directly affected owner of a Transient Vacation Rental(TVR) in Hawai`i
County regarding Bill 47—An Ordinance Amending Chapter 6 of the Hawaii County Code 1983(2016
Edition,as Amended) Relating to Transient Accommodation.
To Whom It May Concern,
I am writing as a concerned and directly affected owner of a Transient Vacation Rental(TVR) in Hawai`i
County regarding Bill 47—An Ordinance Amending Chapter 6 of the Hawaii County Code 1983(2016
Edition, as Amended) Relating to Transient Accommodation.
While I understand and support the County's intention to regulate responsibly and ensure fair practices,
believe that many aspects of this proposed bill are overly burdensome,vague, and counterproductive—
both for small-scale property owners and for the County's administrative capacity.
General Comments:
At a time when both government and citizens aim to reduce bureaucracy and operational costs,this bill
significantly increases regulatory complexity and expenses for TVR owners.Though some provisions may
have good intent, many lack clarity, are difficult to implement, or unnecessarily duplicate existing
processes.
Section 6-45—Expiration of Registration 90 Days After Ownership Transfer:
This proposed change deviates from current practices and creates a serious risk for owners and guests.
If a new owner cannot secure re-registration in time, existing reservations may need to be canceled,
exposing the host to financial liabilities and reputational harm.
Furthermore, information requested in items(4), (6), and (7) of.this section appears to already exist in
County records or could be obtained internally.. Requiring owners to resubmit data the government
already holds is redundant and inefficient.
Item (9) is overly vague and risks placing undue,discretionary burden on applicants depending on
interpretations by the Director of Finance.
Recommendation:A more efficient and fair approach would be to allow for a simplified update of owner
information upon transfer of ownership,without requiring a full re-registration.Since the pr• •- ty,tself
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Ref. Date - 6 2025
has not changed, only the ownership details need updating.This process should also involve a reduced
fee structure.
Section 6-46-Registration Requirements:
Item (3),which asks for confirmation of the"highest daily rate," is impractical. Rates fluctuate based on
demand and seasonality, and it is unclear how the County would verify or assess this information—
especially for properties with multiple units.
Section 6-47-Renewal of Registration:
If renewal involves resubmitting the full set of documentation,this creates an unnecessary
administrative burden on both the owner and the County. If instead it is meant simply to confirm ongoing
operation,then it seems to serve primarily as a recurring fee with little added value.
Section 6-48-Cancellation of Registration:
Point(1),which allows for cancellation based on any legal violation, is excessively broad. It potentially
penalizes owners for circumstances beyond their control, including actions taken by guests or
neighbors.This could be unfair and legally risky.
Section 6-50-Exceptions:
The logic for the narrow set of exceptions listed is unclear.They seem arbitrarily limited and exclude
many responsible operators who provide valuable accommodations in the community.
Section 6-52-Director's Authority:
Point(4)grants the Director of Finance broad discretion to impose undefined additional conditions.This
• opens the door to inconsistent enforcement and unclear expectations.
Subsection (c) also lacks justification—especially considering that Section 6-50 already limits
exemptions to one TVR per qualifying professional.The added restriction seems excessive and not
clearly linked to the bill's objectives.
Conclusion:
As a small TVR owner striving to comply with the law and provide quality accommodations, I urge the
Council to consider the unintended consequences of Bill 47 in its current form. Increased costs,vague
language, and duplicative processes will deter responsible ownership and strain government resources.
I respectfully request that the Council revise the bill to ensure fair, practical, and efficient
implementation.
Sincerely,
Dr.Thomas Buehlmann
Dr.Thomas Buehlmann
Email:Thomas.Buehlmann@gmail.com
Mobile(bus): +61 457 785 974(preferred)
US Contact:+1 602 652 2540
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