HomeMy WebLinkAboutCOM 0739.013 2016-2018Testimony by Tom Burton in favor of Bill 108
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Introduction
My name is Tom Burton. Representing only myself, I write in favor of control of
short-term rentals. Mahalo to all committee members for allowing me to testify, and,
to Council Members Eoff and Kanuha for getting this ball rolling.
Short-term vacation rentals are vexing governments throughout Hawaii and the
world. Their social damage is a fast-moving crisis that so far evades a complete
solution anywhere, to my knowledge; so it should come as no surprise that our first
attempt, Bill 108, falls well short of ideal. By suggesting changes, I mean no
disrespect to the blood, sweat, and tears that have gotten us this far.
The rest of this testimony is divided into three parts: essential improvements,
suggestions, and creative options. I'll address the first part also in oral testimony.
Essential improvements
These three improvements must be included into, or at least hinted at, in the bill you
pass; otherwise, you run the risk of going through these motions for nothing.
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Section 1 of Bill 108 presents its purpose in tactical terms: where, what, and how. I
propose to first state the goals of the act: why we need it. To preserve affordable
housing; to bring in more revenue; to try to shape the growth of short -terms rentals
so that rental income and taxes outweigh the social costs of displaced residents; to
keep Hawaii County a nice place to live—these ',are some of the goals you might
consider. Stated goals could build a moral consensus and guide you toward better
legislation, and they would make the legal argument for a social need to regulate
short-term rentals. The County may need this argument in court.
Liget grandfathering
This photo shows a typical
weekday in Los Angeles in
1960. Growing up nearby,
I watched the battle to
clean this up. First, the big
guys: industrial polluters
had deep pockets, but they
were few and easy to spot.
But the rest of us, the small
fries whose only crime was
being too numerous, were
most of the problem. If Los
Angeles had grandfathered
A-, e little guys forever, LA
today would be worse than Beijing on a bad day.
Planning Committee Meeting, April 24 2018
Testimony by Tom Burton in favor of Bill 108 Page 2 of 3
Grandfathering works only when the rules are ahead of the curve; and when is a
clumsy democratic process ever ahead of the curve? The social costs of rampant
STRs are already severe—unacceptable in places—and sure to worsen. Those STRs
in place now, and the new ones who slide in before we get our act together, cannot
be allowed to continue indefinitely. Grandfatherings in Bill 108 need amortization
periods, perhaps dependent upon zone, after which they expire. So, current owners
would suffer some economic loss, to be balanced against the social need argued in
the purpose of the bill.
Amortization periods stated in the bill won't be credible, unless the bill you pass
spells out their details, and how they will be administered and enforced.
To reduce the administrative and enforcement cost of this. effort, owners must be
strongly encouraged, through the permit and enforcement system, to provide
complete and accurate data to the County. Voluntary disclosures by owners can be
verified by administrative work, and by complaints from neighbors. If informed
neighbors choose not to complain, and if the result is more unpermitted short-term
rentals, maybe that's OK; maybe that's a form of neighborhood input that deserves
respect.
The County should burden the owner with the job to inform neighbors about his or
her STR. Perhaps we can follow the example of the notification process required by
Planning when one applies for a water variance during subdivision.
There's so much more be said on this crucial topic, and I hope others will fill this
gap.
Are residential STRs a good fit for commercial or tourist zones?
Perhaps more, or denser, short-term rentals should be allowed in certain zones, but
I can argue that a proliferation of short-term rentals in a commercial or tourist area,
with their low-paying nonunion jobs, will compete unfairly with hotels; and when
the economy turns down, and tourists opt for the lower cost short-term rentals,
those union jobs may disappear. I'm not sure about that, but it seems to me that
these residential rental units may have no more right to exist in a commercial or
tourist zone than they do in a residential zone.
e
Perhaps you could consider allowing short-term rentals in new housing stock, after
a waiting period, perhaps depending on zone. Give a new building a chance to make
it as a home before throwing it under the bus. The waiting periods won't be credible
unless the bill you pass spells out their details, and how they will be administered
and enforced.
Planning Committee Meeting, April 24 2018
Testimony by Tom Burton in favor of Bill 108 Page 3 of 3
Is collecting TAT an essential element of the solution?
Transient Accommodations Taxes (TAT) are a huge incentive to hide for small STR
operations. Bill 108 burdens the County to assist the State in collection of TAT for
short-term rentals, with little return for the County. This effect would be worse if
home owners, who live.in their homes, are saddled with TAT for renting out rooms,
because the TAT robs them of income that they would have spent in the community.
Bill 108, in Section 3, currently avoids this issue by excluding such operations from
the definition of "short-term vacation rental." Unfortunately, these operations are
part of the numerous small fries who will do us in, if we exempt them all, forever.
Could we possibly come up with a new label for these operations, one that will allow
us to raise their property taxes a bit, and regulate their numbers, without triggering
the collection of TAT?
Planning. Committee Meeting, April 24 2018