HomeMy WebLinkAbout2026-07-16 Zi Zi Opposition Testimony - Late
From: Zi Zi
To: Planning LPC Testimony
Subject: Opposition to Bill 147 — Concerns from a Responsible Hosted Accommodation Operator on Agricultural Land
Date: Thursday, July 16, 2026 9:17:33 AM
Dear Members of the Hawaiʻi County Council:
I am writing to respectfully express my opposition to Bill 147 as it is currently drafted, and to share the perspective of a responsible, law-
abiding hosted accommodation operator in Kona whose property sits on agriculturally designated land.
My property is a single-family home with one dwelling unit. While it carries an agricultural land designation, it has never been used for
agricultural purposes and has no realistic capacity to serve in that function. It is a residential home in every practical sense, managed
under a homeowners association (HOA) with established community standards. I operate a hosted Airbnb on the property and am present
and engaged in ensuring that every guest understands and adheres to the good neighbor principles set forth by both Airbnb and our
community.
I take my obligations as an operator seriously. I pay an 18.5% transient accommodations tax on a monthly basis, in addition to regular
property taxes. I am fully compliant with all applicable tax requirements and have maintained this compliance since I began operating.
My operation also contributes meaningfully to the local economy. I hire a professional local cleaning crew for every guest turnover and
retain a local gardener to maintain my yard on a monthly basis. These are real jobs for real members of our Big Island community — not
outsourced labor, but neighbors who depend on consistent, local work. My guests, in turn, come to Hawaiʻi Island with curiosity and
respect for the land. They leave with a deeper appreciation for the beauty and culture of this place, which is exactly the kind of visitor
experience our island deserves to offer.
I am particularly concerned about the proposed Special Use Permit (SUP) process for hosted accommodations on agricultural land. While
I understand the County's interest in creating regulatory clarity, the current bill raises far more questions than it answers. Critical
implementation details remain unresolved, including:
• What the Special Use Permit process will actually look like in practice;
• Whether existing, lawfully operating hosts will be permitted to continue operations while their permit applications are under review;
• How long the permitting process is expected to take;
• What costs property owners will be expected to bear;
• What standards applicants will be required to meet; and
• Whether there will be sufficient certainty for families and small operators to continue relying on this income during the transition.
For a property like mine — one that bears an agricultural designation in name only — it is deeply unfair to impose the same permitting
burden as would apply to an active farm operation. My home is a residential dwelling that happens to sit on agriculturally zoned land
through no choice of my own. Requiring an SUP process without clear timelines, defined costs, or workable standards places an
unreasonable burden on small operators who are simply trying to operate legally and contribute positively to the community.
I respectfully urge the Council to consider the following before advancing Bill 147:
• Grandfathering protections for currently lawful, tax-compliant hosted accommodation operators, ensuring they are not made
inadvertently nonconforming;
• Clear, practical, and proportional enforcement standards that distinguish between responsible small operators and bad actors;
• Defined timelines, transparent costs, and achievable standards for any SUP process before it takes effect;
• Recognition that agricultural land designations do not always reflect actual land use, and that applying farm-operation rules to single-
family residences is neither equitable nor practical; and
• An opportunity for existing hosted accommodation operators on agriculturally designated land to continue operating while any new
permitting framework is finalized and implemented.
I am not opposed to sensible regulation. I welcome rules that protect neighborhoods, ensure tax compliance, and hold operators
accountable. But Bill 147, as written, risks eliminating responsible operators like me while leaving critical implementation questions
unanswered. The County deserves a framework that is fair, workable, and informed by the real-world realities of operators who have
been doing this right.
I appreciate the Council's time and consideration, and I remain committed to engaging constructively throughout this process. Please do
not hesitate to contact me if you have questions or wish to discuss my concerns further.
Mahalo nui loa,
Zi Zi
Owner, Melomelo Holiday LLC
Kona, Hawaiʻi