HomeMy WebLinkAboutCOM 0236.071 2024-2026expedia group -
May 20, 2025
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COMM,236,
Council Chair Holeka Goro Inaba
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County of Hawaii
Hawai'i County Building'
25 Aupuni Street
Hilo, Hawai'i 96720
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Re: Bill 47
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Dear Chair Inaba, Vice Chair Onishi, and Hawai'i County Councilmembers,
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 47. 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.
Division 3, Platform Requirements
Bill 47 would allow county officials to review the transient vacation rental (TVR) registration
number, tax map key (TMK) number, and transient accommodations tax (TAT) ID number, so
county staff can compare listing information to the county's data for registered TVRs. Expedia
Group shares similar reporting with Kauai County, and this reporting and collaboration has
helped Kaua'i to drive a high rate of compliance with its short-term rental laws. We appreciate
that the legislation would set a consistent standard across the industry by passing a law
applying to all hosting platforms.
Communication 236.003 Amendment
We favor establishing clear guidelines to foster collaboration between Expedia Group and
Hawaii County. The amendment introduced via Communication 236.003 is an improvement
because it outlines a process for platforms to support county enforcement of county laws and
regulations. However, we respectfully request changes to Section 6-53 to further clarify and
improve the language. Please see the proposed changes below with new text bolded and
deleted text stFieken thFeugh.
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Section 6-53 Violation; penalty
a. Upon determination that a hosting platform is in violation of this division, the
planning director shall easeel the fegi tmfieii and -issue a notice of violation and order
the hosting platform:
1. To cure the violation within ten business days;
2. If the platform fails to cure the violation pursuant to Section 6-53(a)(1),
the director shall order the hosting platform
A. To cease and desist from providing booking services to any TVR in
the County no later than ninety days from the date of the notice, or a
later date as the planning director may determine; and
B. To Pay:
i) A civil fine for each day in which the violation persists in
the amount specified in the order, provided the amount is not
less than $1,000 and not more than $10,000; or
In the case of a violation of Section 6-52(c), a civil fine of
$250.
b. Upon determination that a hosting platform is providing booking services for a TVR
for which the registration is expired, cancelled, or otherwise invalid, the planning
director shall issue to the hosting platform a notice or removal and order:
1. Identifying the TVR to be removed by unique website address or link and the
basis for removal;
2. Ordering the hosting platform to
seFAees remove the listing for the TVR from the hosting platform no later
than ten days from the date of the notice; and
3. Advising the hosting platform that failure to comply with the order constitutes a
violation under subsection (a).
4. A hosting platform that complies with this provision shall not be issued a
penalty or order pursuant to Section 6-53(a).
As currently drafted Section 6-53(a) would require the director to cancel a hosting platform's
registration if a single transaction for a TVR without a license took place. If, for example, a
transaction took place the same day a TVR's license expired, there is no grace period or
opportunity to rectify the situation under 6-53(a). This is inconsistent with the compliance
outlined under Section 6-53(b). We recommend clarifying the language to indicate that
platform license cancellation is the remedy if platforms do not delist properties that the county
has highlighted as improper rather than for a single, inadvertent violation.
We also respectfully suggest you amend the language in Section 6-53 (b)(1) to clarify how the
department identifies a listing, so platforms can reliably identify the correct listing.
Finally, we recommend you clarify the language in Section 6-53(b)(2) to clarify the requirement
is to remove a listing. The definition of "booking services" is so broad that it could prevent
issuing payments or refunds for previous or ongoing stays.
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1111 Expedia Group Way West I Seattle, WA, 98119 1 USA I T + 1 206 481 7200I F+l 206 481 7240
expedlagroup.com
We applaud the proposed changes to Section 6-52 (a)(4). Including URLs will provide the
county with essential information to verify property registrations while offering platforms
clarity and consistency in their reporting obligations.
Division 3 Effective Date
We respectfully request that the Division 3 effective date be pushed out until after the effective
date for the rest of the legislation. For TVR owners to obtain a TVR registration number, the
county must first set up a registration system and allow time for owners to apply for and
receive the registration numbers. In our experience, once an application is available, it typically
takes three to six months for operators to apply to register and move through the registration
process.
Uniformly Formatted Registration Numbers
We understand the county is planning to issue uniformly formatted registration numbers, i.e.,
provide a number with the same number of digits/characters, to all transient vacation rentals,
regardless of whether the TVR is registered and operating under the provisions of this bill or the
provisions of previous legislation, like Bill 108. We applaud this idea. Without a uniformly
formatted number, platforms will not have a clear indication if a rental is exempt from
registering under Bill 47 or if a would-be rental needs to register and has not done so. It will
also be impossible for platforms to comply with the reporting under section 6-52 since not all
rentals would have a "registration number issued under division 1 associated with the TVR".
Thank you for the opportunity to provide comments. We look forward to working with Hawaii
County Council as it contemplates Bill 47. Please do not hesitate to contact me if there is any
additional information we can provide.
Mahalo,
Mackenzie Chase
Regional Manager, Hawaii
Expedia Group
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1111 Expedia Group Way West 1 Seattle, WA, 98119 1 USA 1 T + 1 206 481 72001 F + 1 206 481 7240
expediagroup.com