HomeMy WebLinkAboutCOM 0739.218 2016-2018y.
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David J. Reber, Esq., President
Nathan Nelson, Esq., Vice President
Patrick Byrne, Treasurer
Naomi C. Fujimoto, Esq., Secretary
Michael R. Cruise, Esq.
David Derauf, M.D.
Joyce Lee-Ibarra
Neal Milner
Blake Oshiro, Esq.
Garret Sugai
Co -Executive Directors
Victor Geminiani, Esq.
Gavin Thornton, Esq.
1 Hawai `i Housing Planni
Corporation, Dec. 201(
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(808) 587-7605
hiappleseed.org
Testimony of Hawaii Appleseed Center for Law & Economic Justice
Commenting on Bill 108 (2018) in Hawaii County
County Council Planning Committee
Monday, June 18'h,2018 at 2 P.M.
Hawai `i County Council should add restrictions to its permitting process
and set forth an enforcement strategy before passing BiR 108.
The Hawaii Appleseed Center for Lazy & Economic Justice is working to build a
Hawai `i where everyone has genuine opportunities to achieve economic security and fulfill
their potential. We change gstems that perpetuate inequality through research, poli y
development, education, coalition building, and advocacy.
Thank you for the opportunity to testify regarding Bill 108.
Hawai `i Appleseed recognizes Bill 108 as an important first step in
establishing a regulatory framework for short-term vacation rentals (STRs)
on Hawaii Island. With the second highest per capita homelessness
population of all 50 states and the District of Columbia, and with the
highest housing and rental costs in the nation, it is imperative that Hawaii,
including its counties, begins to control what has been an unfettered
expansion of the STR industry in order to protect its long-term housing
supply.
Currently the housing supply in Hawaii is not keeping up with demand.
Hawaii gained 8,458 housing units from 2011-2014, but this pace is
insufficient to create the 24,551 units it needs between 2016 and 2020.1
Hawaii Island in particular will feel the demand squeeze in the next decade
as its population continues to rise.' In 2016, 17% of the units in Hawaii
County were "unavailable," three times the number of unavailable units in
Honolulu. What's more is that we can expect low-income populations to be
hit the hardest as approximately 74% of the total housing units required by
g Stas v, SMS Research & Marketing Services for Hawaii Housing Finance and Development
(p. 5, 34). Available at
r/hhfdc /files /2016 / 12/State_HHPS2016_Report_111416-FINAL-122216.pdf
d population rises: Census estimates show Hawaii County making biggest gains, Hawaii
?3, 2017.
Comm. o. -'l�
No. 94
Ref. To:
9,,4. Date __ JUL 4 0 296 w
i-lawai`i Appleseed Center for Law and Economic Justice
June 17, 2018
Page 2 of 5
2025 in Hawaii will be needed for households making less than $75,000 per year.'
The prevalence of STRs is exacerbating this problem by taking units out of the long-term rental
market for those that need it the most, and perhaps permanently. In Hawaii County in 2014 there
were 4,986 individually advertised short-term vacation rentals, demonstrating that 1 out of 16
housing units may have been stripped from the residential market for transient vacation rental
(TVR) use. Moreover, a large number of TVRs are owned by non-residents that have less of a stake
in the progress of local communities. It is estimated that 42.9% of homebuyers in Hawaii County
are non-residents. Local researchers suggest that it is the expansion of such investor ownership that
is especially reducing the housing stock and driving up rent,` in particular where the rentals are for
entire homes. On Hawaii Island approximately 49% of TVRs are for entire homes or condos, and
93% of TVR listings are for entire homes throughout the state.' The unregulated proliferation of
STRs is thus making it even more difficult to curtail the existing housing crisis in Hawaii County
and the state.
Although Hawaii derives some benefits from STRs through increased tourism spending and tax
collection, the benefits are far outweighed by the costs. San Francisco, which like Hawaii County
has struggled with high housing costs and a proliferation of STRs, found that every housing unit
withdrawn from the market to be used as an STR produces a net negative economic impact, even if
the unit generates host income, visitor spending, and hotel taxes. San Francisco estimates that their
local economy loses up to $300,000 per STR per year. The impact of STRs in Hawaii County is
likely to be similar.
In particular, STRs could cause significant job loss and a decrease in wages for the local population.
As platforms like Airbnb detract visitors from hotels, hotel workers could lose their jobs entirely. If
these workers are able to find jobs with a platform, their wages could still decrease substantially. A
Los Angeles report estimated that the Airbnb workforce (consisting of domestic cleaning services)
makes $4.08 an hour, resulting in $1.1 million less in wages than hotel workers per week, or $54
million less per year., It is also important to consider that decreasing the workforce at hotels could
threaten them with collapse. Appleseed urges council members to carefully consider these economic
and social costs when deciding whether to pass the current draft of Bill 108.
3 Hawai `i Housing Planning Sturdy, SMS Research & Marketing Services for Hawaii Housing Finance and Development
Corporation, Dec. 2016 (p. 35). Available at
https: //dbedt.hawaii.gov/hhfdc/files/2017/03 / Mate_HHPS2016_Report_031317_final.pdf
4 SKIS, Hawaii Hou ing Planning Studji 2016 63 (2016), available at
https://dbedt.hawaii.gov/hhfdc/files/2016/12/State_HHPS2016_Report_111416-FINAL-122216.pdf .
S 2017 Visitor Plant lnventog, Hawaii Tourism Authority, 2,017 (p. 60). Available at
http://www.hawaiitourismauthority.org/default/assets/File/reports/accommodations /2017%20VISITOR%20PLANT
%20INVENTORY%20REPORT%20-%2001-17-2018.pdf
6 AirBnB, Rising Rent, and the Housing Crisis in Los Angeles, Los Angeles Alliance for a New Economy, March 2015
(pg. 15). Available at https://www.laane.org/wp-content/uploads/2015/03/AirBnB-Final.pdf
LA
Hawaii Appleseed Center for Law and Economic Justice
June 17, 2018
Page 3 of 5
Appleseed appreciates that Bill 108 sets forth a permitting system that will enable the county to
identify STR units, thereby providing a tool for enforcement. Indeed, maintaining access to the
addresses of these units is the only way to ensure adherence to zoning laws at the foundation of this
bill. We also recognize the importance of the provision that stipulates that a unit's STR
advertisement is prima facie evidence it is being operated as such. Shifting the burden of proof to
the host will significantly decrease the load that would be imposed on an already under -resourced
and under -staffed enforcement agency.
While Appleseed recognizes Bill 108 as an important first step in regulating STRs in Hawaii County,
there are sections that should be strengthened if it is going to have a genuine impact.
The Permitting Process
First, the permitting process itself could include regulations that would function to better safeguard
the character of Hawaii Island and its housing market, and place STR benefit in the hands of locals
as opposed to investors and non-residents. As it stands, Bill 108 does not distinguish between
commercial STRs held by owners with multiple units and other STRs. This distinction is important.
Tightening regulation on commercial users, at the permitting stage at the very least, gives the county
control over its long-term housing stock to ensure that its units are distributed fairly among locals,
investors, and non-residents.
Two other provisions raise concern. The grandfathering clause in the bill is problematic as it could
permanently take long-term housing units off of the market. Additionally, the provision that allows
registration to automatically rollover to a new owner, regardless of whether that owner already owns
several STRs, will also decrease the county's ability to regulate its own housing stock and protect is
own neighborhoods. Accordingly, in addition to reconsidering inclusion of the latter three
provisions, Appleseed encourages Hawaii County Council to adopt the following:
❖ Limiting the Numbers:
13 Limitations on the number of STR units a single owner may have and limitations on
how many STRs are allowed in areas with the highest demand for affordable housing
13 Limitations on the number of non-conformance units an individual may have, as well
as limitations on expanding the non-conformance unit beyond its original size
❖ Creating Classifications for Different Types of STRs: Including classifications that
distinguish between STRs for single units and commercial STRs (owners that have
purchased multiple units or homes in a certain area)
•:° Scaling the Registration Fees: Establishing registration fees for new STRs as well as
scaling registration fees for new and existing STRS based on the aforementioned categories
and how many units the owner maintains. Charge $250 for the first unit, $500 for the
second, and $1,000 for the third.
❖ Preventing Immediate Conversion: Requiring an owner to live in Hawaii County for 5
years before being able to convert their unit to an STR
Hawaii Appleseed Center for Law and Economic Justice
June 17, 2018
Page 4 of 5
❖ Protecting New Housing Developments: Restrictions on STR conversion in newly
developed housing units planned for Hawaii County that are meant to provide affordable
housing for local residents
•:' Host Transparency: Requiring that all unit and host information is disclosed in the
registration packet for both regular registrations and non -conforming use certificates
(NCUCs)
•:' Restricting STRs to natural persons
Enforcement Strategy
Second, Appleseed urges Hawaii CountyT Council to consider regulating beyond the registration
process by including an enforcement strategy in Bill 108. Successful regulators across the country,
such as enforcement agencies in San Francisco and Portland, have found that a permitting process
alone, largely ignored by hosts and platforms, is insufficient'. Evidence of this phenomenon is
apparent in counties around Hawaii as well. For example, in Honolulu, while only 775 TVUs and
B&Bs were permitted in two zoning areas, up to 4,400 "individually advertised units" were found on
booking sites across two -dozen conununities.' Similarly, although Maui has only issued 223 TVR
permits, the number of active TVRs on the island is estimated at 9,000. A lack of enforcement on
Oahu and Maui has made the ability to cheat the permitting system all too easy, and has rendered
these bills ineffective. The inability to enforce has also hurt law-abiding residents. In Maui a DPP
memo noted that STR owners who had gone through the registration process saw a decrease in
occupancy, as they were unable to compete against illegal rentals with lower rates.' A lack of
enforcement not only fails to catch those already cheating, but also could potentially deter otherwise
law-abiding citizens from obtaining a permit and following other provisions of this bill.
Consequently, Bill 108 should at least lay the groundwork for an enforcement strategy. As a start,
Appleseed recommends the following enforcement provisions:
❖ Increase Community Involvement: Either require that operators post NCUCs or
registration numbers on a conspicuous place visible from a public street on which the STR is
located, or establish a website where legal operations can be identified. In addition, requiring
that the county distribute a letter to each household not operating an STR nearby that
educates neighbors on how to identify and report illegal STRs
❖ Establishing an Enforcement Process: Setting up a clear process for taking and
registering complaints that utilizes the intake and investigative resources of the focal police;
7 Simone McCarthy, San Francisco to Airbnb: Enforce the rules or pay the price, The Christian Science Monitor Qune
15, 2018, 9:00 AM), https•//www.csmonitor.com/Business/2016/0608/San-Francisco-to-Airbnb-Enforce-the-rules-or-
pay-the-price; Steve Law, City tries nezv softer apProach to regulate short-term rental companies Portland Tribune (Tune 15.
2018, 9.00 AM, https•//portlandtribune com/pt/9-news/387932-278421-city-tries-new-softer-approach-to-regulate-
short-term-rental-comp anies-
8 ROH § 21-4.110-1. For a list of permitted rentals, see
http: //honoluludpp.org/Portals/0/pdfs /HotIssues/NUCreport.pdf.
9 Memo Report, County of Maui Department of Planning, August 18, 2016. Available at
https://www.mauicounty.gov/DocumentCenter/View/ 105774/091316 -Agenda -Item -D 1-Resolution-16-93-
Enforcement-Procedures-for-STRHBB
Hawaii Appleseed Center for Law and Economic Justice
June 17, 2018
Page 5 of 5
Creating a complaint hotline and setting clear deadlines for responding to complaints, setting
hearing dates, and making decisions.10
❖ Fines and an Enforcement Fund: Fining hosts and platforms daily for posting
advertisements without permit numbers and for other violations of this bill. The proposed
ordinance in Honolulu and the active ordinances in Boston, San Francisco, and New
Orleans require such fines. Fines should increase with each violation, commencing at the
issuance of the first notice of violation, and including disgorgement of profits derived from
the unit or banning the property from being used as an STR after several. Collected fines
should be funneled to the county's enforcement fund.
❖ Increase Transparency in Advertisements: In addition to a permit number, all advertising
material should include the property owner's address and zoning classification.
❖ Involve the Platforms: Demand data transparency from Internet platforms to identify
illegal operators and impose requirements that remove noncompliant listings from
platforms. In San Francisco, home -sharing platforms must remove unregistered listings or
face a fine. They also must collect data from their hosts and pass it on to the city.
I' •
Appleseed appreciates that Bill 108 establishes the groundwork for a regulatory framework attempting
to balance permitting STR growth with protecting the long-term housing stock and local residents.
Appleseed believes that the bill as it stands, however, doesn't do enough to fulfill its latter purpose.
With further consideration of the aforementioned recommendations as a means of regaining control
of the housing market, Appleseed believes Hawaii County will be one step closer to a more balanced
approach and a more prosperous community.
Attached hereto as an addendum for your reference is Hawai iAppleseed's report that discusses these
issues more in depth.
Mahalo for the opportunity to comment on Bill 108.
io Deadlines for responding to complaints are in several cities' ordinances including Boston and San Francisco, among
others.
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Hawai `i Appleseed
Center for Law and
Economic Justice
119 Merchant Street
Suite 605A
Honolulu, Hawaii 96813
(808) 587-7605
www.hiappleseed.org
Authored by:
Victor Geminiani
Madison DeLuca
-Contents
ExecutiveSummary........................................................................................................................................................1
TheState of Housing in Hawai `i....................................................................................................................................3
Severe Impact of Housing Shortage on Those Most in Need.................................................................................4
Economic Challenges Facing Hawai `i Residents.....................................................................................................5
Hawai`i's Vacation Rental Industry ..............................................................................................................................6
CaseStudy: Maui............................................................................................................................................................9
Vacation Rental Regulation in Other Major Cities..................................................................................................10
CurrentState of VRU Enforcement............................................................................................................................10
Recommendations.......................................................................................................................................................1 1
Conclusion......................................................................................................................................................................12
Endnotes.........................................................................................................................................................................13
Executive Summary
Finding affordable housing has long been a significant challenge for Hawai'i's residents. Over the past
decade, it has risen to crisis proportions. Economic barriers to achieving economic stability are daunting
for most Hawai'i residents, and are nearly insurmountable for low-income households. The growth of the
vacation rental industry in recent years is exacerbating these problems. While vacation rentals offer the
possibility of extra income for some residents and additional tax revenue for the state, many of the benefits
go to nonresident investors. The adverse consequences of housing stock lost to vacation rentals far
outweighs the benefits they might provide to local families and,our community.
Hawai'i's housing costs are among the highest in the nation. Hawaii workers earn the lowest wages in the
nation after accounting for cost of living. These financial pressures are compounded by Hawai'i's
regressive fax system, which places the second highest tax rate in the nation on people in poverty. Given
these factors, an unusually high percentage of our residents are renters -43 percent, the fourth highest
percentage in the nation. Rent is more expensive in Hawai'i than any other state. In recent years, rents
have been increasing at more than twice the rate of wages. It's no surprise that Hawai'i has the highest
rate of homelessness in the nation, and families who have called Hawaii home for generations are being
priced off the islands.
At a time when Hawai'i is only building half of the units necessary to keep up with demand, housing stock
available to Hawai'i residents is being eaten up by nonresident purchasers. Twenty-seven percent of
Hawaii home sales are made to nonresidents. On Maui, 60 percent of condominium sales are made to
nonresident buyers. The proliferation of short term vacation rental units (VRUs)—the majority of which are
operated by nonresidents—has added another pressure point by further limiting the availability of housing
for local families.
Over just the last two years, the number of VRUs has increased by 35 percent. There are currently 23,000
VRUs being advertised around the state. Up to 93 percent of them are for entire homes, rather than the
rent -out -a -room image purveyed by the VRU industry. One out of every 24 housing units in the state is a
VRU, with some communities being completely overwhelmed by the industry's growth. On Kauai one in
eight homes is used as a VRU. In Lahaina, the ratio drops to one in three. The reason why investors are
choosing VRUs over long-term rentals is obvious: the average VRU brings in about 3.5 times more revenue
than a long-term rental unit.
The loss of long-term rentals to VRUs means higher housing costs for Hawai'i residents. Although Hawaii
derives some benefits from VRUs through increased tourism spending and tax collection, the benefits are
far outweighed by the costs. San Francisco, which like Honolulu has struggled with high housing costs and
a proliferation of VRUs, found that every housing unit withdrawn from the market to be used as a VRU
produces a net negative economic impact, even if the unit generates host income, visitor spending, and
hotel taxes. San Francisco estimates that their local economy loses up to $300,000 per VRU per year. The
impact of VRUs in Hawaii is likely to be similar.
Hawaii should consider adopting measures that will help reverse the damage caused by the proliferation
of illegal VRUs in the state, including:
• Making it illegal to advertise a VRU that is not permitted and requiring all VRU advertisements to
include a permit number (currently, enforcement agencies report that a VRU advertisement is. not
sufficient to prove that the unit is actually being used as a VRU);
• Requiring that internet hosting platforms identify and remove noncompliant hosts;
• Empowering local neighbors to enforce the laws against VRUs by granting them standing to file a
complaint with the courts;
• Increasing the staff of the county enforcement office;
• Requiring owners or hosts to be present whenever they_ are hosting; and
• If, after cracking down on illegal VRUs, communities decide to modestly increase the number of
VRU permits, dispersing permitted rentals unit in communities throughout the island to avoid
oversaturation.
Unless Hawai'i takes action against illegal VRUs, their numbers will continue to rise as investors convert
more homes built for residents into vacation rentals for visitors. Home prices and rents will rise, and Hawai'i's
families, communities, and economy will suffer.
The State of Housing in Hawaii
The housing crisis is one of Hawai'i's most critical problems today. Our housing costs are among the highest
in the nation.' We have the lowest wages when adjusted for cost of living,2 the highest rate of chronic
homelessness,3 and the highest rate of overcrowding in housing.4 These problems continue to worsen with
housing costs increasing at more than twice the rate of increases in wages.5 Housing has always been
expensive in Hawaii, but housing costs have rocketed further out of reach for Hawai'i residents over the
last decade.
A primary contributor to Hawai'i's housing
problem is that our supply of affordable
housing fails to keep up with demand.
Although Hawai'i gained 8,458 housing from
2011 to 2014, this pace is insufficient to create
the 24,551 units Hawai'i needs between 2016
and 2020 to keep up with new demand.6 For
every two units needed, only one is being
built.
As demand continues to outpace supply,
housing prices and rents for families who live
and work in Hawai'i will continue to rise. This
problem is exacerbated by nonresident
home purchasers. Statewide, 27 percent of
Hawai'i's homes sold between 2008 and 2015
went to nonresidents.? On Maui, investors and
second -home owners hold over 60 percent of
condominiums and apartments$ and 52
percent of homes are sold to nonresidents .9
This dramatically shrinks the pool of available
housing for our families.
Vacation rental units (VRUs) provide another
significant pressure, leading to the reduction of
available housing for Hawai'i residents and
driving up rents. VRUs are rental properties being
used as rentals for less than 30 days to transient
parties, and many are illegal.10 In Hawaii, where
43 percent of households rent—the fourth
highest percentage out of all the states—this
issue is particularly problematic.'' A sharp
increase in VRU inventory, driven by the strong
economic returns VRUs generate, undoubtedly
affects our local housing market. Maui, the
island with the largest number of VRUs in the
state, is particularly impacted.
Rent vs. Wage Increases
Increases in rent prices have dramatically
outpaced increases in wages since 2000
350rn
300 0 ....
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Rent - Cumlative % Change
Wages - Cumlative % Change
Percent of Maui
condos and
3
apartments sold
to investors and
z
0
second
homeowners
Severe Impact -of Housing Shortage on Those Most in Nee*
Hawai'i's housing shortage most acutely affects residents and families who are the least economically
secure. Housing demand is typically measured relative to "Area Median Income" (AMI)—the income level
at which half of Hawai'i's residents make more and half make less. In 2016, the median household income
for Hawaii was $74,511.12 Approximately 74 percent of the total housing units required by 2025 are
needed for households making less than $75,000.13 In other words, roughly three-quarters of the total
amount of new housing required in coming years needs to be affordable to the lowest -income half of the
population. The greatest housing needs are at the lowest levels of the income scale.
Hawai'i Housing Demand by Income Level (2015-2025"
More than $150K
$1 OOK to $150K
aN. _� n
$75Kto$100K
$60K to $75K .
$45K to $60K
$30K to $45K
Less than 30K
1000 units neede*
a9, IF
Not only is there a need for new, affordable homes in the future, the unfortunate reality is that the amount
of planned affordable housing is far below the amount needed to close the availability gap. Units built
by the private market, without the use of government subsidies, are typically priced at levels affordable
only to households at 140 percent of AMI and above—prices well out of reach for the vast majority of
Hawaii residents. The Hawaii Housing Finance and Development Corporation (HHFDC)—the main state
agency charged with developing and financing housing affordable below 140 percent of AMI —planned
to develop only 5,801 units of housing between 2016 and 2020.14 This is less than a third of the 19,908 units
needed at or below the 140 percent of AMI income level in this time period.15
The lack of sufficient housing stock and increased housing costs relative to wages has resulted in high
rates of crowding (where a household has more than two people per bedroom) and doubling up (where
multiple households live in a single home). In recent years, Hawai'i has been ranked first in crowding for
owner -occupied units and second for renter -occupied units. In 2016, 20 percent of Hawai'i's'households
were crowded or doubled up. 16
Native Hawaiians are particularly disadvantaged by the explosion of VRUs. Their homes are more likely to
be overcrowded and doubled up, leaving no space to rent out.17 They are also more economically
insecure; while Native Hawaiians participate in the labor force at higher rates than the state average,
they earn significantly less per capita. 18
Economic Challenges Facing
Hawaii Residents
Living in Hawaii comes with
Percentage of Households Facing
serious economic challenges
Housing Cost Burdens by Income Group (2017)
that compound the struggle to
find affordable housing. Hawaii
�%
85%
851
86%
is the second worst state for
80%75%
taxing people in poverty,19 and
61 % 60%
Hawaii residents earn the lowest
'
wages in the country when
40%
I f j'
adjusted for cost of living.20 Forty-=°':
21 �° 25%
67o
eight percent of households in
20%
;
! `` 9%
3
Hawaii struggle to afford basic
_.:.._.
.. '.... . ,.a.h.
_.._ b:..Ol
household necessities.21
Extremely
Low very Low LOW Middle
Above Median
(0-30% AMI) (31%-50% AMI) (517,;-80% � A tial) (81-10-100 70 AMI)
(100%+ of AMI)
Housing is considered affordable a Cost Burdened L� Severely Cost Burdened
when a household spends no
more than 30 percent of its income on shelter. Families with expenses exceeding this amount are
considered cost -burdened, while those spending more than 50 percent are severely cost-burdened.22
Seventy-five percent of extremely low-income households in Hawaii spend more than half of their income
on housing. 23 This leaves little money to cover other expenses such as clothing, food, and medicine.
Forty-three percent of Hawai'i households rent rather than own—the fourth highest percentage in the
nation. Hawai'i's "housing wage" (defined as the wage needed to afford a two-bedroom unit at fair
market rents) is $35.20—the highest of all the states. In comparison, the average renter's real wage is
$15.64. A minimum wage worker would need to work 152 hours a week -3.8 full-time jobs—to afford a
two-bedroom unit, and 116 hours a week -2.9 full time jobs—to afford a one -bedroom unit.24
As the housing market becomes increasingly hostile,
eviction and displacement become more likely. Eviction
can lead to lower credit scores and increased difficulty
finding replacement housing, loss of security deposits and
personal belongings, and additional moving expenses that
already cash-strapped families can ill afford.
Even if a displaced family can find new housing, it may be
in a different area. This breaks up communities, severs ties
with family and friends, and disrupts children's schooling.
Classroom turnover hurts our keiki; it leads to lower
achievement, academic progress, and high school
graduation rates. Additionally, unstable housing situations
can increase substance abuse and incidences of
psychiatric disorders.25
13% of homelessshelter
clients core from homes
they were unable to retain
The most severe consequence of displacement is homelessness. In 2016, almost thirteen percent of
homeless services clients came from homes they were unable to retain.26 As)Hawai`i has the nation's
highest chronic homelessness rate, keeping people housed should be a high priority.27
Housing costs even drive some residents out of our state. In 2016, approximately 22 percent of survey
respondents said they would move out of Hawaii on their next move. Thirty-one percent of those who
wanted to leave reported that housing was one of the problems causing them to move.28
PIMMMM
Hawai `i's Vacation Rental Industry
The Internet has provided opportunities for anyone to advertise units for short-term rental, regardless of
county or state laws. A sizable percentage of VRU operators (also known as "owners" or "hosts") are willing
to operate in violation the law because the economic returns for a VRU are significantly higher than that
of a long-term rental.
Compounding matters is the recent rise of internet hosting platforms like HomeAway and Airbnb. These
platforms have substantial marketing budgets, nedr-universal brand awareness among travelers, and e-
commerce infrastructure that makes it easier for people to operate a VRU today than ever before.
Internet hosting platforms also provide significant anonymity. They shield host information from regulators
and permit illegal operations to list on their sites. This makes enforcement nearly impossible and reduces
illegal hosts' fear of getting caught.
Sharp Rise in Hawaii Vacation Rentals
VRUs in Hawaii are pervasive and their numbers are growing. In 2017, the Hawaii Tourism Authority (HTA)
estimated that 23,000 VRUs existed in Hawai'i,29 a 35 percent increase in only the last two years.30
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2015 2017
Since Hawai'i has roughly 540,000 total housing units, these estimates mean that approximately 1 out of
every 24 units is a VRU.31 The share of VRUs is even higher in towns frequented by tourists. In Koloa on
Kauai, 1 out of -every 2.5 housing units is a VRU.32
Vacation Rental Ownership
Some platforms perpetuate the myth that VRU hosts
are residents renting out extra rooms to make ends
meet.33
However, the majority of hosts are nonresidents. The
available data is not sufficiently detailed to
determine the full extent of nonresident ownership,
but it does reveal that at least 52 percent of VRUs
are owned by nonresidents. The true figure is likely
much higher.34
Entire Home vs. Shared Home
At minimum, 52%
of VRUs are
owned by
nonresidents
Additionally, the majority of VRUs are entire -home rentals. Various sources estimate that between 74
percent and 93 percent of VRUs are for entire -home rentals. A report commissioned by Airbnb derived
the low-end estimate of 74 percent,35 while the high-end estimates were derived from visitor surveys and
data extracted from VRU booking sites. Ninety-two percent of visitors surveyed self-reported that they had
the entire unit to themselves,36 while data extracted from three separate VRU booking sites indicated that
93 percent of VRUs were for an entire home or entire condo.37
Up to 93 percent
of VRU listings are
ror entire ho ..
These entire -home rental hosts are likely not renting their primary residence, as the hosts would need to
vacate the premises for the duration of their guests' visits. Rather, entire -home listings are likely posted by
multi -unit hosts who use VRU platforms to facilitate commercial -style rental operations. From 2009 to 2014,
the number of Airbnb booked entire -home listings increased by an annual average of over 100 percent.38
A recent study suggested that hosts with 20 or more units earned more than 27 percent of the total revenue
generated by multi -unit hosts.39 It should be noted that the study was conducted by a group with ties to
the hotel industry, but if even close to accurate, it paints a compelling picture of who is benefiting from
VRUs.
Detriments of Vacation Rentals Outweigh Benefits
While VRUs bring additional tourism, spending, and the potential for taxation, studies have shown that the
negative impacts on cities' economies and housing costs far outweigh the benefits. San Francisco found
that VRUs result in the withdrawal of housing units from the residential market, which leads to higher
housing costs. Every housing unit withdrawn from the market to be used as a VRU produces a net negative
economic impact on the city, even if the unit generates host income, visitor spending, and hotel taxes
every day of the year. The city estimates that the local economy loses up to $300,000 per VRU per year.40
Other cities have also tracked the outsized and negative effects of VRUs. In 2014, Airbnb absorbed one
percent of Los Angeles' rental,housing market, and rents rose 7.3 percent.41 Furthermore, if 8,000 illegal
Airbnb listings were removed in New York City, the number of available rental units would rise 10 percent.42
Why Long -Term Rentals Are Being Lost to Vacation Rentals ,
(A
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generatecompared to
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Renting out a unit as a VRU is more profitable
than renting it long-term, making VRUs
particularly appealing for nonresident
investors. A 2015 study by Honolulu's Office of
Community Services indicated that at 80
percent occupancy, the average Airbnb unit
would bring in about 3.5 times more revenue
than a long-term rental.43 Approximately
seventy-eight percent of rental units on Oahu
earn less money than the average Oahu
entire -home Airbnb.
Thus, on average in Honolulu, a potential host
would only have to rent on Airbnb 73 days out
of the year to earn more on Airbnb than
renting long term. In some areas the threshold
is lower; a Waimanalo host would only have to
rent ori Airbnb 26 days to make more than
they would renting long term.44 A report
prepared for the 'Hawai'i Tourism Authority
estimates that revenue from VRUs will reach
$1.9 billion by 2021, an increase of 58 percent
from 2016 revenue.45
Given the enormous economic incentives, it is
inevitable that opportunists will use VRUs to
commercialize Hawai'i's neighborhoods.
Hosts are overwhelmingly speculators and
investors who benefit from the escalating
price of housing in Hawai'i,46 and our property
tax rate, which is the lowest in the nation.47
Hawaii is a safe place to invest money for
long-term security and a high return on
investments, at the expense of our residents.
Case Study: Maui
With almost 9,000 estimated VRUs48 taking up 13.6 percent of its housing stock,49 Maui is an example of
unfettered VRU proliferation. One in seven housing units on Maui is a VRU. In Lahaina, it is one in three.so
Maui is an example of what the state of Hawaii could
become if we do not enact stricter regulations.
Approximately
are active on Maui. Only
r
Who Nonresident Mauitom,.
Owners Say They • To
"Don't
Know"
Residents
Only
Nonresidents dominate Maui's housing market. Sixty
percent of condos51 and 52 percent of homes on Maui
are sold to nonresident buyers.52
Sixty-six percent of nonresidents who own Maui
property report renting out their units. Only 16.7 percent
of these owners choose to rent to residents only.53 Thus,
it is no surprise that Maui has the highest percentage of
residential units being used as VRUs in the state.54
Since 2006, the number of housing units produced each
year on Maui has lagged behind the number of new
Visitors households. A 2014 report commissioned by the County
of Maui shows that by 2020, Maui's unmet housing need
will reach nearly 4,000 units. Seventy percent of these
units will be needed for households at or below 80
percent of AM1.55 Almost a quarter of Maui residents are
severely cost -burdened; this is the highest proportion of
severely cost -burdened residents in the state.56
Even when new units are constructed they are often not affordable;
Maui has the lowest share of affordable housing in the state. Median
sales prices for homes on Maui saw the largest increase (24 percent)
in the state from 2010 to 2014. Furthermore, less than a quarter of
prospective Maui home buyers are able to make an adequate down
payment.57
Maui has taken concrete steps to address the problems posed by
VRUs:
• Potential hosts must obtain a permit, arrange a safety
inspection and provide public signage with their contact
information.
• Opposition from neighbors can trigger a Maui Planning
Commission review of the VRU and neighborhoods have caps
on the number of short term rentals that can operate.
• Any dwelling approved for short-term use must have been constructed more than five years
before a permit application is submitted.58
However, lack of enforcement power has limited the efficacy of these regulations. Although the number
of active VRUs is estimated at 9,000, Maui has only issued 223 permits.S9
Vacation Rental Regulation in Other major Cities
Cities across the globe are searching for solutions to reduce the proliferation of illegal VRUs and increase
the supply of critical housing for residents. Three examples of such locations are:
San Francisco
• In 2014, San Francisco limited homesharing
to 90 days per year during which hosts are
not present for their guest's stay, mandated
that hosts register their properties, required
hosts or platforms to collect taxes,71 and
only allowed each host to rent out one
unit.72
• In 2016, the city required VRU platforms to
verify that listings are registered before
posting them online. Non-compliant
platforms could face fines of up to $1,000
per day.73
• The system was implemented in January of
2018, resulting in Airbnb listings decreasing
by almost 50 percent.74
Barcelona, Spain
New York City
• New York State law was amended in 2010
to prohibit rentals of fewer than 30 days
during which the owner is not present.75
• In examining Airbnb data from 2014, the
New York Attorney General's Office found
that nearly 72 percent of New York City
listings are illegal. Additionally, while only 6
percent of hosts ran commercial -scale
operations, these hosts collected 37
percent of the city's Airbnb revenue.76
• Subsequently, in 2016 Governor Cuomo
made it illegal to advertise an apartment
for rent for less than 30 days on a VRU
platform.77 Offenders could be fined up to
$7,500.78 1
• A 2016 study revealed that 40 percent of Barcelona VRUs are illegal. The report also blamed
Barcelona's 33 percent rise in rent since 2013 on the increase in tourist accommodations.79
• Professionally -owned tourist apartments must be licensed, and owners of illegally advertised
properties face fines of up to €60,000.80
• Barcelona doubled its VRU enforcement team from 20 to 40 inspectors. By 2018 the city will have
over 100 inspectors.81
Current State of VRU Enforcement Oahu VRU Enforcement Actions
Increased enforcement is essential to ensuring that the VRU
1200
1 035
industry in Hawai'i remains in check. Additionally, the burden
1000
for proving a violation should be reduced—enforcement
800
agencies claim that advertising the unit as a VRU is not, on
600
°?" 9
its own, sufficient proof it is being used as a VRU. On Oahu for
400
example, from January through August of 2017, Honolulu's
200
Department of Planningand PermittingDPP conducted
49 2
1,035 VRU investigations. They issued 49 notices of violation,
inifial violation Code
only two of which were referred to the Code Compliance
Investigafions Notices Compliance
Referrals
Branch for civil fines.71
Recommendations
Reduce the Burden of Proof
L
As mentioned in the preceding section, enforcement agencies claim that an internet ad is purportedly
not enough evidence to issue a violation, and it is difficult to gather evidence to prove that someone is
renting a unit for less than 30 days.72 Allowing investigators to use online advertisements as evidence will
shift the burden of proof to the host. There are several options available:
Implement fines. Other locations, including Austin, Texas,73 and New York State,74 have banned
the hosts of unlicensed or noncompliant short-term rentals from advertising, imposing fines on
those that do. San Francisco has taken the practice of fining even further, placing the burden of
enforcement on rental platforms. Platforms are fined $1,000 per day per unregistered host.75
Demand data transparency from internet platforms to identify illegal operators and impose
requirements that remove noncompliant listings from platforms. In San Francisco, homesharing
platforms must remove unregistered listings or face a fine. They also must collect data from their
hosts and pass it on the city 76
• Model Honolulu's Bill 20 regarding Accessory Dwelling Units (ADUs). Honolulu has included strong
enforcement provisions in its regulations on ADUs. In 2015, Bill 20 allowed homeowners to build
ADUs on their property to create more affordable rental units. The bill stipulated that rentals cannot
be for less than six months and the property owner or property owner's relative must occupy the
primary dwelling unit on the property.
In addition, Bill 20 strengthened DPP's enforcement powers by placing the burden of proof on the
homeowner. Inspectors can use advertisements on the internet as proof that an accessory
dwelling unit is being used as a VRU. Advertising without a permit creates a presumption that the
unit is being illegally rented and requires the owner to prove that it is not.77 Advertising the ADU as
a VRU can result in revocation of the ADU permit and fines of $1,000 per day.78 Regulations on
VRUs themselves must have equally strong enforcement tools.
Plan Carefully for Expansion of Permitting
Hawai'i cannot bear the heavy load of VRUs that has been building over recent years. However, if
enforcement efforts successfully reduce the number of illegal VRUs, it may be appropriate to consider a
modest, controlled expansion of permits, in which case, the following factors should be considered:
• Neighbors should be informed of any permit applications submitted in their neighborhoods and
be given an opportunity to contest the applications.
• Permits should be dispersed fairly around the island, not concentrated in one particular
community that will be overburdened.
• All advertising material, including websites, should include the property owner's permit number,
address, and resort zoning classification.
• Each unit's property owner or resident should be required to be present during guests' stays.
• Fines for unpermitted units should commence at the issuance of the first notice of violation. Fines
should start low but increase substantially with subsequent violations to the level where they
eliminate the possibility of still making a profit after paying the daily fines. Correcting a violation
should not dismiss the assessed fines.
Broaden the Authority of Enforcement Agencies
Enforcement agencies like the DPP would benefit from more staff and a greater focus on deterrence, not
just compliance. Fines from noncompliant VRUs should be used to fund DPP enforcement expansion.
Support Increased Community Involvement
Community members can work in partnership with enforcement agencies to protect their neighborhoods.
Counties should establish a hotline or reporting app to monitor VRUs and require hosts to notify their
neighbors that they have applied for a VRU permit. Furthermore, neighbors should be explicitly allowed
to use state courts to appeal for enforcement against specific units in their neighborhoods, or to bring
claims against neighborhood hosts directly.
conclusion
While the VRU industry is arguing that vacation rentals are boosting Hawai'i's economy and residents'
incomes, in reality, VRU are doing more harm than good. The proliferation of VRUs—the majority of which
are owned by nonresidents—is reducing the housing stock available to families who live and work in
Hawai'i and increasing our already high housing costs. Residents who have been struggling for years
under the pressures of expensive housing and relatively low wages are reaching their breaking point.
Families who have lived in Hawai'i for generations are being displaced from their homes and their islands
by a steady flow of short-term visitors. While Hawai'i welcomes its visitors and recognizes their importance
to our economy, tourism needs to be carried out in a way that is balanced and sustainable over the long-
term. The current state of VRUs in Hawai'i is not. Hawai'i needs to take action before further damage is
done.
Endnotes
1 2016 American Community Survey 1 -Year Estimates Ranking Tables, R251 1 and R2514, 2016. Available at
http://files.howaii.gov/dbedt/census/acs/ACS2016/ACS2016_1_Year/state_rank/I 6_state_ranking_file.pdf
2 Kolko, Jed. Cities Where Salaries Go Furthest in the U.S., Indeed Hiring Lab (Aug. 24, 2017). Available at
http://www.hiringla b.org/2017/08/24/salaries-g o-furthest-in-us-
cities/?utm_source=Grassroot+Institute+Newsletter&utm_campaign=d062b83822-
Prez-Column-10-6 _17&utm_medium=email&utm_term=0_9daOfl cl e4-d062b83822-
164734697&ct=t(Prez Column_10_6_17)&mc_cid=d062b83822&mc_eid=43e4O3dd28
3 The 2017 Annual Homeless Assessment Report (AHAR) to Congress, The U.S. Department of Housing and Urban Development,
Dec. 2017 (p. 65). Available at https://www.hudexchange.info/resources/documents/2017-AHAR-Part-1 .pdf
4 Selected Housing Characteristics, 2016 American Community Survey 1 -Year Estimates, U.S. Census Bureau. Available at
https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_16_1 YR_DP04&prodType=table
5 FMR History for Honolulu County, Hl, HUD User. Available
at: https://www.huduser.gov/portal/datasets/fmr/fmr_il_history/history_fmr.odn?inputname=METR04652OM46520*Honolulu%2OCou
my%2B1500399999&county_select=yes&statename=Hawaii&�statefp=l5&stusab=Hl&fmr year=2016&i1_year=2016&area_choice=c
ounty; Median Household Income by State. Historical Income Tables: Households, U.S. Census Bureau. Available
at https://www.census.gov/data/tables/time-series/demo/income-poverty/historical-income-households.htmi
6 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawai'i Housing Finance and Development Corporation,
Dec. 2016 (p. 5, 34). Available at https://dbedt.hawaii.gov/hhfdc/files/2016/12/State_HHPS2016_Report_I 1 1416-FINAL-122216.pdf
7 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawaii Housing Finance and Development Corporation,
Dec. 2016 (p. 16). Available at https://dbedt.hawaii.gov/hhfdc/files/2017/03/State_HHPS2016_Report_031317_final.pdf
8 Cassiday, Rick. Oahu Rental Housing Study, Department of Community Services City & County of Honolulu, 2014 (p. 55).
Available at https://dbedt.howail.gov/hhfdc/files/2015/02/RENTAL-HOUSING-STUDY-2014-UPDATE-CITY-COUNTY-OF-HONOLUILU.pdf
9 Residential Homes Sales in Hawaii, Department of Business, Economic Development and Tourism Research and Economic
Analysis Division, May 2016 (p. 18). Available at
http://files.hawaii.gov/dbedt/economic/data_reports/homesale/Residential_Home_Sales_in_Hawaii_May20l 6.pdf
10 The Impact of Vacation Rental Units in Hawaii, 2016, SMS Research & Marketing Services for Hawaii Tourism Authority Research
Division, Nov. 2016 (p. 2-3). Available at
http://www.hawaiitourismauthority.org/default/assets/File/Housing%20and%2OTourism%201 13016.pdf
11 Out of Reach 2017: The High Cost of Housing, National Low Income Housing Coalition, 2017 (pp. 16, 66). Available at:
hffp://nlihc.org/sites/default/files/oor/OOR_2017.pdf
12 Census Data Highlights, Hawai'i State Data Center, Sept. 2017. Available at
http://files.howaii.gov/dbedt/census/acs/ACS2016/ACS2016_1 _Year/Other_Files/ACS_2016_Analysis_DBEDT_final.pdf
13 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawai'i Housing Finance and Development Corporation,
Dec. 2016 (p. 35). Available at https://dbedt.hawaii.gov/hhfdc/files/2017/03/State_HHPS2016_Rep6rt_031317_finai.pdf
14 Annual Report, Hawaii Housing Finance and Development Corporation, 2015 (p. 3). Available at
http://files.hawaii.gov/dbedt/annuals/2015/2015-hhfdc.pdf
15 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawai'i Housing Finance and Development Corporation,
Dec. 2016 (p. 5, 34). Available at https://dbedt.hawaii.gov/hhfdc/files/2016/12/State_HHPS2016_Report_I 1 1416-FINAL-122216.pdf
16 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawaii Housing Finance and Development Corporation,
Dec. 2016 (p. 8). Available at https://dbedt.howaii.gov/hhfdc/files/2017/03/State_HHPS2016_Report_031317_final.pdf
17 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawai'i Housing Finance and Development Corporation,
Dec. 2016 (p. 73). Available at hffps://dbedf.hawail.gov/hhfdc/files/2016/12/Sfate_HHPS2016_Report_I 1 1416-FINAL-122216.pdf
18 Testimony of Kamana'opono Crabbe Relating to Land Use Ordinance, Office of Hawaiian Affairs, Dec. 9, 2015 (p.2).
19 Who Pays? S1h Edition, Institute on Taxation and Economic Policy, Jan. 2015 (p. 15). Available at https://itep.org/wp-
content/uploads/whopaysreport.pdf
20 Kolko, Jed. Cities Where Salaries Go Furthest in the U.S., Indeed Hiring Lab (Aug. 24, 2017). Available at
http://www.hiringlab.org/2017/08/24/salaries-go-furthest-in-us-
cities/?utm_source=Grassroot+Institute+Newsletter&utm_campaign=d062b83822-
Prez-Column-1 0 6 17&utm medium=email&utm_term=0_9da0f1 cl e4-d062b83822-
164734697&ct=t(Prez_Column_10_6_17) &mc_cid=d062b83822&mc_eid=43e4O3dd28
21 Alice: A Study of Financial Hardship in Hawaii, Aloha United Way, 2017 (p. 1). Available at
https://www.auw.org/sites/default/files/United%20Way%20ALICE%20Report%20-%20Hawaii%2C%202017.pdf
22 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawai'i Housing Finance and Development Corporation,
Dec. 2016 (p. 7). Available at https://dbedt.hawaii.gov/hhfdc/files/2016/12/State_HH PS2016-Report- 1 1 1416-FINAL-122216.pdf
23 2017 State Housing Profile, National Low Income Housing Coalition, June 14, 2017. Available at
http://nlihc.org/sites/default/files/SHP_Hi.pdf
24 Out of Reach 2017: The High Cost of Housing, National Low Income Housing Coalition, 2017 (pp. 16, 66). Available at:
http://nlihc.org/sites/default/files/oor/OOR_2017.pdf
25 Geminiani, Victor & Chin, Jennifer. Evicted in Hawaii - Lives Hanging in the Balance, Hawaii Bar Journal, 2016 (p. 30-32).
26 Yuan, S., & Gauci, K. T. Homeless Service Utilization Report: Hawaii 2016, University of Hawai'i Center on the Family, 2017 (p. 7).
Available at: http://uhfamily.hawaii.edu/publications/brochures/b761 f HomelessServiceUtilization20l 6.pdf
27 The 2017 Annual Homeless Assessment Report (AHAR) to Congress, The U.S. Department of Housing and Urban Development,
Dec. 2017 (p. 65). Available at https://www.hudexchange.info/resources/documents/2017-AHAR-Part-1 .pdf
28 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawaii Housing Finance and Development Corporation,
Dec. 2016 (p. 18-19). Available at https://dbedt.hawaii.gov/hhfdc/files/2016/12/State_HHPS2016_Report_I 11416-FINAL-122216.pdf
29 2017 Visitor Plant Inventory, Hawaii Tourism Authority, 2017 (p. 70). Available at
http://www.howaiitourismouthority.org/default/assets/File/reports/accommodations/2017%20VISITOR%20PLANT%20]NVENTORY%20
R EP O RT%20-%2001-17-2018.pd f
30 2015 Visitor Plant Inventory, Hawaii Tourism Authority, 2015 (p. 72). Available at
.http://www.hawailtourismauthority.org/default/assets/File/reports/accommodations/2015%20VISITOR%20PLANT%201NVENTORY%2
OREPORT.pdf
31 QuickFacts Hawaii, Housing, U.S. Census Bureau. Available at: https://www.census.'gov/quickfacts/HI
32 Individually Advertised Units in Hawaii, SMS Research & Marketing Services for Hawai'i Tourism Authority, Dec 2014 (p. 3, 7, 8).
Available at
http://www.hawaiitourismauthority.org%default/assets/File/research/accommodations%20studies/Individually%20Advertised%20Un
its%20in%20Hawaii%20(Vacation%20Rentals).pdf
33 Geron, Tornio. Airbnb Had $56 Million Impact On San Francisco: Study, Nov. 9, 2012. Available at
https://www.forbes.com/sites/tomiogeron/2012/11 /09/study-airbnb-had-56-million-impact-on-san-francisco/#352e35413962
34 Available data show that out of a total of 45,075 short-term rentals, including those characterized as "residential" (VRUs) and
those characterized as "commercial," 31,402 (70 percent) were owned by nonresidents and 13,673 (30 percent) were owned by
residents. According to the some data set, 28,398 of the 45,075 short-term rentals are "residential" (VRUs). Making the most
conservative assumption possible—that residents owned only VRUs and no "commercial" rentals—nonresidents would own 14,725
(52 percent) of the VRUs in Hawaii. The Impact of Vacation Rental Units in Hawaii, 2016, SMS Research & Marketing Services for
Hawaii Tourism Authority Research Division, Nov. 2016 (p. 6). Available at
http://www.hawaiitourismauthority.org/default/assets/File/Housing%20and%20Tourism%201 13016.pdf
35 Cassiday, Rick. Airbnb & Hawaii Housing, Jan. 9, 2017 (p.14). Available at https://www.airbnbcitizen.com/wp-
content/uploads/sites/27/2017/01 /HawaiiAirbnbReportDesigned.pdf
36 Hawaii's Home and Vacation Rental Market: Impact and Outlook, JLL for Hawaii Tourism Authority, Dec 29, 2016 (p. 33).
Available at
http://www.hawaiitourismauthority.org/default/assets/File/JLL%20Report_Impact%20of%20Home%20Rento1%20Market%20on%20H
awa ii_12-29-2016.pdf
37 2017 Visitor Plant Inventory, Hawaii Tourism Authority, 2017 (p. 60). Available at
http://www.hawaiitourismauthority.org/default/assets/File/reports/accommodations/2017%20VISITOR%20PLANT%201NVENTORY%20
REP ORT%20-%2001-17-2018.pdf
311 Cassiday, Rick. Airbnb & Hawaii Housing, Jan. 9, 2017 (p. 2). Available at https://www.airbnbcitizen.com/wp-
content/uploads/sites/27/2017/01 /HawaiiAirbnbReportDesigned.pdf
39 Hosts with Multiple Units -A Key Driver of Airbnb Growth, CBRE Hotels' Americas Research, March 2017 (p. 19). Available at
https://www.ahla.com/sites/default/files/CBRE-AirbnbStudy_2017.pdf
40 Amending the Regulation of Short-Term Residential Rentals: Economic Impact Report, City and County of San Francisco, May
18, 2015 (p. 8). Available at http://sfcontroller.org/sites/default/files/Fi[eCenter/Documents/6458-
150295_economic-impact_final.pdf?documentid=6457
41 How Airbnb Short-Term Rentals Exacerbate Los Angeles's Affordable Housing Crisis: Analysis and Policy Recommendations,
Harvard Law and Policy Review, Feb 2, 2016 (p. 231, 240). Available at:
http://blogs.ubc.ca/canadianliteratureparkinson/files/2016/06/How-Airbnb-Short-term-rentals-disrupted.pdf FROMMM
42 Woolf, Nicky. Airbnb and house -sharing firms reduced New York housing stock by 10% - study, The Guardian, June 27, 2016.
Available at https://www.theguardion,com/us-news/2016/jun/27/airbnb-new-york-city-housing-stock-reduction-study
43 Hawaii Housing Planning Study, SMS Research & Marketing Services for Hawai'i Housing Finance and Development Corporation,
Dec. 2016 (p. 58). Available at https://dbedt.hawaii.gov/hhfdc/files/2016/12/State-HHPS2016_Report_I 1 1416-FINAL-122216.pdf
44 Financial Characteristics 2016 American Community Survey 1 -Year Estimates, U.S. Census Bureau, 2016. Available at
https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtmi?pid=ACS_16_1 YR_S2503&prodType=table; Zip
Code Boundaries: US Census Bureau. Available at https://www2.census.gov/geo/tiger/TIGER2010/ZCTAS/2010; Median Contract
Monthly Rent: 2015 American Community Survey 5 -year Estimates Table B25058, U.S. Census Bureau, 2015. Available at
https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=bkmk; Zip Codes, Honolulu Open Data, City &
County of Honolulu (2017). Available at http://honolulu-
cchnl.opendata.arcgis.com/datasets/62431 dd72960448087a287fo06b87bf5_7; Honolulu, Airdna, Sept. 2017. Available at
https://www.airdna.co/market-data/app/us/hawaii/honolulu/overview
45 Hawaii's Home and Vacation Rental Market: Impact and Outlook, JLL for Hawaii Tourism Authority, Dec 29, 2016 (p. 26).
Available at
http://www.hawaiitourismauthority.org/default/assets/File/JLL%20Report_Impact%20of%20Home%20Rental%20Market%20on%20H
aw a i i_ 12-29-2016. p d f
46 Table 21.01—Number and Value of Building Permits, by county: 1958 to 2016, The State of Hawaii Data Book, The Department of
Business, Economic Development & Tourism, 2016 (p. 1006). Available at
http://files.hawaii.gov/dbedt/economic/databook/db20l 6/db20l 6.pdf
47 Logan, David. Property Taxes by State - 2016, National Association of Home Builders, Oct 2, 2017. Available at
http://eyeonhousing.org/2017/10/property-taxes-by-state-2016/
48 Minutes, Council of the County of Maui Planning Committee, 6/16/16 (p. 13). Available at
https://www.maulcounty.gov/ArchiveCenter/ViewFile/Item/21920
49 Individually Advertised Units in Hawaii, SMS Research & Marketing Services for Hawai'i Tourism Authority, Dec 2014 (p. 4).
Available at
http://www.hawaiitourismouthority.org/default/assets/File/research/accommodations%20studies/Individually%20Advertised%20Un
its%20in%20Hawaii%20(Vacation%20Rentals).pdf
so Individually Advertised Units in Hawaii, SMS Research & Marketing Services for Hawai'i Tourism Authority, Dec 2014 (p. 8).
Available at
http://www.hawaiitourismauthority.org/default/assets/File/research/accommodations%20studies/Individually%20Advertised%20Un
its%20in%20Hawaii%20(Vacation%20Rentals).pdf
51 Cassiday, Rick. Maui Rental Market, Department of Housing and Human Concerns County of Maui, 2014 (p. 3). Available at
https://dbedt.hawaii.gov/hhfdc/files/2015/02/RENTAL-HOUSING-STUDY-2014-UPDATE-COUNTY-OF-MAUI.pdf
52 Residential Homes Sales in Hawaii, Department of Business, Economic Development and Tourism Research and Economic
Analysis Division, May 2016 (p. 18). Available at
http://files.hawaii.gov/dbedt/economic/data_reports/homesale/Residential_Home_Sales_in_Hawaii_May20l 6.pdf
53 The Impact of Vacation Rental Units in Hawaii, 2016, SMS Research & Marketing Services for Hawai'i Tourism Authority Research
Division, Nov. 2016 (p. 20). Available at
http://www.hawaiitourismauthority.org/default/assets/File/Housing%20and%20Tourism%201 13016.pdf
54 Individually Advertised Units in Howaii, SMS Research & Marketing Services for Hawai'i Tourism Authority, Dec 2014 (p. 4).
Available at
http://www.hawaiitourismauthority.org/default/assets/File/research/accommodations%20studies/Individually%20Advertised%20Un
its%20in%20Hawaii%20(Vocation%20Rentals).pdf
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https://www.mauicounty.gov/DocumentCenter/View/91217
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https://www.mauicounty.gov/DocumentCenter/View/1 4762
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http://www.sfbos.org/ftp/uploadedfiles/bdsupvrs/ordinancesl 4/00218-14.pdf
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64 Chapter 225, New York City, 2010 (p. 1). Available at https://wwwl .nyc.gov/assets/buildings/pdf/NYS_chapter_225.pdf
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