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Hawaii County Council Meeting
June 4, 2025
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COUNTY OF HAWAI'I
Hawaii County Building. RECEIVED
25 Aupuni Street Time 121QQ /WyM, sY
Hilo, Hawaii 96720 Date )I IN 0 3. 2025
Re: BILL 47 AMENDING CHAPTER 6 OF THE HAWAI`I COUNTY CODE 1983 (2016
EDITION, AS AMENDED), RELATING TO TRANSIENT ACCOMMODATIONS
Aloha Chair Inaba, Vice Chair Onishi, and Members of the Council,
Mahalo for the opportunity to provide COMMENTS on Bill 47, relating to transient
vacation rentals -(TVRs) and hosting platforms in Hawaii County. We continue to have
concerns on certain language in the Bill.
Airbnb supports a sustainable TVR program that balances the economic benefits of
home sharing with the needs of communities, however, urges caution with certain Bill 47
provisions, which could negatively impact property owners, renters, and the economy.
Bill 47 seeks to define TVRs as those who host for 180 days or less. This expansion
risks overregulating mid-term rentals. Additionally, provisions relating to platforms are
premature and should be postponed until there is a determination about the need for
new land use and eligibility legislation.
We respectfully urge the County Council to consider:
1. Defining TVRs as hosted for 30 days — The 180-day definition could potentially
restrict long standing uses of stays greater than 30 days and risks eliminating
lawful mid-term rentals and undermining long standing properly rights. For
example, Honolulu's 90-day minimum was blocked by injunction in 2023 for
similar overreach.
2. Postponing premature platform provisions — Until zoning and eligibility rules are
defined for TVRs, provisions relating to platforms (Sections 6-50 to 6-53) are
premature. We recommend delaying these until the need for any updates to
zoning and hosting rules are determined.
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Ref. Dais JUN — 4 2025
Additionally, we are concerned that Section 6-45's broad language, specifically
6-45(a)(9) creates vague and uncabined discretion for registration requirements,
creating uncertainty for hosts. We urge the Council to add clarifying language specifying
that registration approval is based solely on objective criteria listed in Section 6-45(a),
ensuring a predictable, non -discretionary process.
Lastly, we are concerned that Bill 47 may unintentionally affect local hosts who use
STRs to supplement mortgages, as it may trigger higher real property tax rates (Section
6-45(a)(8)). This could make renting unaffordable for many hosts. If these homeowners
face higher taxation, many will simply opt not to rent creating a loss of tourism taxes
without any appreciable gain in property tax.
Airbnb is committed to working with local leaders on fair rules that simultaneously
address community concerns and protect the economic benefits of home sharing for
residents and communities that rely on tourism. We respectfully request consideration
for delaying the passage of this proposal to allow for more collaboration to refine Bill 47.
Mahalo,
Janel Cozzens (nee Denny)
Sr. Policy Manager, Hawaii
Airbnb