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CHAIR HOLEKA GORO INABA, VICE CHAIR DENNIS ONISHI
HAWAII COUNTY COUNCIL
MEETING DATE: Wednesday, June 4, 2025
TIME: 9:00 am
PLACE: Hilo
RE: OPPOSITION TO BILL 47, Draft 2
1
HI IVIAST
HAWA19 MID AND SHORT-TERM
RENTAL ALLIANCE
Dear Chair Inaba, Vice Chair Onishi, and Members of the Hawaii County Council:
On behalf of the Hawaii Mid- and Short -Term Rental Alliance (HIMAST), I respectfully submit
our strong opposition to Bill 47, Draft 2, and urge the Council to defer any further action on
this legislation until the County's economic impact study on the short- and mid-term rental Z!3
(STR/MTR) sector is publicly released and considered.
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Intent Is Not a Safeguard t
While we recognize the Council's stated intent —to promote transparency and improve cis
compliance —intent that is not codified cannot be enforced. We've repeatedly heard that
enforcement will be "complaint -driven" and that this bill is not designed to punish. Yet the
Council has declined to amend the bill to reflect those assurances in law. Residents are
rightfully concerned that registering today could result in targeted enforcement tomorrow.
A Pattern Worth Remembering
Hawaii has seen firsthand how vague legislation and unchecked implementation lead to public
distrust and policy failure. From documented cases of political corruption, to the now -
unconstitutional practice of "gut and replace" lawmaking, our communities have learned to
look not only at what's said —but at what's possible under the law as written.
Bill 47 creates mechanisms that can be repurposed or reinterpreted by future administrations:
• Mandatory registration without protection for voluntary disclosure
• Platform compliance mandates
• Fines and penalties with unclear limits
• Enforcement authority not clearly defined or restricted
It sets the stage for a system that could easily evolve into a punitive regime —even if that is not
the Council's current intent.
Data Should Guide Policy
This Council commissioned an economic impact study for a reason: to make informed,
responsible decisions. Advancing Bill 47 before that study is released sends a clear message that
the data —and the communities affected —are an afterthought.
What genuine public interest is being served by rushing this bill forward now, rather than waiting
a few more weeks to evaluate the evidence? At best, it's premature. At worst, it undermines trust
in the entire policymaking process.
Comm. Niza
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Our Recommendations
BINIAST respectfully urges the Council to take the following steps:
1. Defer Bill 47 until the County's impact study is released and reviewed by the public.
2. Amend any future registration program to include enforceable protections for
voluntary registrants.
3. Incorporate a limited -time amnesty period to acknowledge the realities of legacy
structures, informal housing, and the role STRs play in the economic sustainability of
many local families.
This is not an argument against regulation —it is a call for measured, lawful, and community -
informed regulation. We believe sound policy must be built on evidence, trust, and clear
boundaries —not assumptions or unenforceable promises.
Thank you for your time, your service, and your consideration of our testimony.
Respectfully,
Caitlin Miller
Secretary, HIMAST Alliance