Clear Creek County Planning Commission Agenda Virtual ...

Note: This is a draft agenda for the October 6, 2021 Planning Commission meeting. This draft is subject to change before the actual meeting date. Should there not be a quorum at this particular meeting or should the meeting be cancelled, all Action items will be continued to the next regular meeting date at the same time of the day unless timely notice is given of a change. Individuals with disabilities needing auxiliary aid(s) may request assistance by contacting the Land Use Department at Clear Creek County, P.O. Box 2000, Georgetown, CO, 80444. Phone 303-679-2436. We would appreciate it if you would contact us at least 48 hours in advance of the scheduled event so arrangements can be made to locate the requested auxiliary aid(s).

Clear Creek County Planning Commission Agenda

Virtual Hearing –see link information below October 6, 2021

6:30 P.M.

Call to Order Roll Call Pledge of Allegiance Unscheduled Appearances

ACTION ITEMS

1. Election of Officers (Chairman, Vice-Chairman) 2. Approval of Agenda 3. Approval of Minutes for July 21, 2021 4. Public Hearing to consider revisions to the County’s Short Term Rental (STR) Regulations

presenter: Fred Rollenhagen Resolution #: PC-21-02

WORKING SESSION

5. Staff and Planning Commission Updates (as needed) Adjournment

Note: This is a draft agenda for the October 6, 2021 Planning Commission meeting. This draft is subject to change before the actual meeting date. Should there not be a quorum at this particular meeting or should the meeting be cancelled, all Action items will be continued to the next regular meeting date at the same time of the day unless timely notice is given of a change. Individuals with disabilities needing auxiliary aid(s) may request assistance by contacting the Land Use Department at Clear Creek County, P.O. Box 2000, Georgetown, CO, 80444. Phone 303-679-2436. We would appreciate it if you would contact us at least 48 hours in advance of the scheduled event so arrangements can be made to locate the requested auxiliary aid(s).

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Clear Creek County Planning Commission Regular Meeting July 21, 2021 1

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Minutes Clear Creek County Planning Commission

Meeting of July 21, 2021

Call to Order The meeting of the Clear Creek County Planning Commission (PC) was called to order by Chairman John Muscatell at 6:38 pm via Zoom teleconferencing platform.

Roll Call Members Present: Chairman John Muscatell, Vice Chairman Russell Clark, Dave Christensen, Julie Whisenand, and Dave Andrews. Members Absent: Staff Present: Fred Rollenhagen, Planning and Building Services Manager, and Adam Springer, Senior Planner.

Pledge of Allegiance

Unscheduled Appearances There were no unscheduled appearances. However, Chairman John Muscatell announced that he is retiring as a Planning Commission Member after this meeting due to relocating out of the County. Furthermore, Commissioner Muscatell stepped down as Chairman for this meeting and Vice Chairman Russ Clark took over chair duties for the rest of this meeting.

Approval of Agenda The agenda was approved as written.

Approval of Minutes for May 19, 2021

Commissioner Whisenand made a motion to approve the Minutes as written. Commissioner Christensen provided a second. Motion passed unanimously.


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Continuation of Work Session on short-term rental (STR) regulations (3rd Working Session on this topic) presenter: Fred Rollenhagen

Vice Chairman Clark introduced the next item on the agenda; the continuation of a working session regarding short term rental regulations. Staff Member Fred Rollenhagen presented his Report to the Commission. The Planning Commission’s last working session on Short Term Rentals (STR’s) was May 19, 2021 where the conversation continued on a number of different topics related to revising the STR regulations. Among those topics were the following:

1. Reviewed the total number of STRs in each Commissioner district and their proportion to total number of housing units (approximately 3.7% of all housing units are currently STRs).

2. The PC took public comments. They heard from many who explained how STRs support the local economy and how the STR program supports individual families’ ability to keep real estate in the family. There were also concerns about trash, noise, and party houses communicated by members of the public.

3. The Planning Commission asked to find out when homes currently used as STRs were purchased by the current permit holders, and whether permit holders typically present or otherwise convey the County’s rules to their visitors.

4. Since the last working session, some neighbors are raising serious concerns about trash being left outside by STR occupants that attract wild animals.

Planning Commission Questions and Feedback There is some concern about the duration of an STR permit; which is currently from the date of approval through the next Calendar year. Staff may want to take another look at this to ensure that the intent of the yearly permit duration is being met. It does not appear that STR owners are effectively relaying the proper conduct protocol to the renters; in order to ensure that regulations are being followed and neighborhood areas are being respected. We may want to consider developing an outline of common sense rules that should be followed by STR renters. Staff stated that STR owners are required to post certain information within the rental that speaks to basic requirements of the permit and safety information, as stated in the STR regulations. The regulations that are currently in place for STR’s seem to be very good, it just appears that the biggest issues are getting the renters and occupants to comply with the rules. Should emergency contact information for nearby neighbors to STR’s be expanded to a quarter mile?


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It may be worthwhile to track complaints in more detail, in order to understand the specific issues that we are having. Staff member Cyndie Ruschmyer discussed how enforcement works for STR complaints. Trash companies may have issues with dumping bear proof trash containers. We want to ensure that whatever method of trash container and/or trash protocol is required is practical and feasible. Should a trash management plan be required that does not involve the renters? A solution could be to require that STR property owners have trash removed from the property after every rental stay. There was concern expressed by some members of the Commission regarding future impacts in certain areas of the County if the percentage of STR’s go up significantly over time. Some Planning Commission Members expressed concern about a 4% STR cap for the County, however, said that they could potentially get on board with are larger percent cap – such as 5.5%. Parking can be an issue for those STR’s that rent out to large numbers. Should there be some type of parking management Plan? Planning Commission asked Staff if we track how many STR’s come and go over time? Staff Member Cyndie Ruschmyer stated that we have stayed pretty consistent over the time we have permitted STR’s; Maybe 6 to 8 STR’s come and go over a year period. Public Comment Terry Victor Ms Victor had the following comments concerns about STR’s: -Constant noise issues. -Out of state owners have not been very response. -Believes that there are some misunderstandings related to what is bear proof vs bear resistant trash containers, and feels like trash companies have a hard time dumping these containers. -STR owners should have the cleaning person take the trash away. -Traffic and Parking issues. -Smoke issues. -Would like to see a cap on STR’s and would like to see a setback from STR’s to existing structures (or something to that effect). -Concerned about impacts to the community related to increasing STR’s. -Enforcement is a challenge with nuisance complaints. Ann Sill Ms. Sill shared her experiences living next to an STR and the impacts it has had to her area and property.


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Public Comment Closed 8:00 Zoom Chatroom Comments The following comments were copied from the zoom chatroom that were made during the meeting. None of the comments have been edited.

From Terry Victor to All Panelists: 06:29 PM Can you see our chat? I cannot see your response From Terry Victor to Everyone: 06:30 PM I just changed to “Panelists and Attendees” if that makes any difference Also, who is the person whose name simply shows “Clear Creek"? From Cynthia Ruschmyer to Terry Victor, All Panelists: 06:30 PM can you see if I message you only? From Terry Victor to Everyone: 06:31 PM Yes, I do see the message to me only From Terry Victor to Everyone: 06:44 PM Can you tell us who you all are? I thought this would be commissioner’s…. And am unsure who is who. …. as far as position at CCC From Terry Victor to Everyone: 07:21 PM I would like to interject here Please let me interject. May I please speak? From Me to Everyone: 07:23 PM There will be a time for the public to speak in just a moment. From Terry Victor to Everyone: 07:52 PM I do From Terry Victor to Everyone: 08:05 PM I only have contact for the owner in AZ and have not had a lot of luck with him in the past. We would like the contact persons contact info How about a requirement of a copy of the short term advertisement also. And some requirements about what needs to be advertised 7pm is the first noise time per regs Just fyi…. The current link to complaint (which is a 3rd party) often does not work Does this need to be run by a 3rd party? It took me a season to find how to complain or who all to talk to. This info might be a good idea to include to all adjacent neighbors. Thanks


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At time of STR application. Could adjacent neighbors be informed then? Thanks you all for listening. And especially whom we can contact with any issues. That would be REALLY valuable. (If the county would contact us)

Conclusion The Planning Commission directed Staff to come back with a draft regulation for review before a Public Hearing. Additionally, the Commission asked if the attending public could provide any further thoughts to Staff via email in the coming weeks before the Public Hearing.

Committee Updates -Staff and Planning Commission stated their appreciation of service for outgoing Planning Commissioner John Muscatell -Planning Staff Member Fred Rollenhagen brought up the future of remote Planning Commission meetings and the potential for holding meetings in person at some point in the near future. Some cursory ideas were discussed for creating a hybrid meeting system.

Adjournment Commissioner Christensen made a motion to adjourn the meeting at 8:30 pm. Commissioner Andrews provided a second. Motion passed unanimously. Respectfully submitted, ____________________________ _______________ Adam Springer, Secretary Date Approved by the Planning Commission on October 6, 2021 __________________________ _______________ Russ Clark, Vice Chairman Date

STAFF REPORT FOR PLANNING COMMISSION Regarding an agenda item on

September 15, 2021

AGENDA ITEM: Public Hearing: Consideration of draft Resolution #PC-21-02 to approve Zoning Regulations that would revise the requirements for the operation of Short Term Rentals

STAFF: Fred Rollenhagen, Planning and Building Services Manager

Table of Contents

1. Staff Report 2. Draft Resolution of Approval with draft Regulations 3. Map of STRs in each Commissioner District 4. What are Other Nearby Communities Doing? 5. Summary of online Articles of STRs 6. Articles found online of STRs 7. Colorado Parks and Wildlife Bear-proofing Guidance 8. Clear Creek Forum poll 9. Clear Creek Forum Primary Resident Question 10. Clear Creek Forum responses and comments 11. Individual Submitted Comments

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STAFF REPORT FOR

PLANNING COMMISSION Regarding an agenda item on

September 15, 2021

AGENDA ITEM: Public Hearing: Consideration of draft Resolution #PC-21-02 to approve Zoning Regulations that would revise the requirements for the operation of Short Term Rentals

STAFF: Fred Rollenhagen, Planning and Building Services Manager Cyndie Ruschmyer, Planner I

EXECUTIVE SUMMARY

The draft revisions to the current STR Regulations are intended to address the following:

1. Place a cap of 5.5% of the total number of residential units in unincorporated Clear Creek County for short term rentals. This value accommodates all of the existing known STRs and allows for approximately 50% growth in the number of short term rentals.

2. STRs that are ‘owner occupied’ are exempt from the 5.5% restriction and which permits are good for two (2) years instead of one (1).

3. Eliminate the 8-person limit on short term rentals on lots under 2-acres, thereby allowing existing infrastructure and existing space to determine the total number of persons allowed in any STR. Adds a proposed limit of no more than 2-persons per legal bedroom, which is consistent with OWTS restrictions.

4. Clarify garbage storage requirements by following Colorado Parks and Wildlife recommendations of allowing trash to be stored in bear-proof trash containers (ie; heavy-duty steel enclosures with a locking lid). Otherwise, all trash must be stored inside a building and may be left outside only on the day of on-street pick up.

5. Miscellaneous revisions to increase the efficiency of permit review and reduce the amount of time it takes to review a permit application.

PURPOSE AND BACKGROUND: the purpose of this public hearing is for the Planning Commission to consider revisions to the Zoning Regulations that govern Short Term Rentals. the current regulations were adopted in December, 2017, to become effective May, 2018 after staff set up the program. The County contracts online monitoring to an outside contractor who monitors the internet for STR listings and notifies County staff of its findings on a monthly basis. It also maintains the online permitting process that applicants follow to obtain a permit. County Staff still must establish contact with unpermitted STRs to notify them of our process, review and approve applications, and carry out enforcement procedures with noncompliant operators. On November 10, 2020, and then subsequently on April 13, 2021, Staff held working sessions with the Board of County Commissioners to discuss the status of the County’s Short Term Rental program. The Board has remained concerned about the status of the County’s housing supply for residents and local workforce. While the Board understands that there are numerous factors that affect the supply and cost of local housing, it requested that Staff and the Planning Commission consider revisions to the STR regulations that would help work towards a goal of maintaining current resident housing stock. The primary suggestion that came from the BOCC working sessions was to consider a primary

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resident-only policy where only primary residents would be allowed to apply for STR permits. This policy is similar to current City of Idaho Springs and City and County of Denver policies. April 2021 The Planning Commission began a series of working sessions in April. During April’s working session, Staff provided information about higher-level trends in how short term rentals are being regulated by local jurisdictions across the U.S. and how they are being regulated locally. There are lots of publications that discuss this issue and some of them are a part of this Staff Report. In general, there appears to be significant new research and discussion about STRs’ effect on housing, the housing market, housing availability and housing affordability; especially in communities popular with tourists. But in general, a few straightforward recommendations came up if a community is concerned about its housing stock in light of increased STR use:

1. Regulations should limit the reallocation of housing stock from long-term to short-term without discouraging the use of home-sharing by owner-occupiers

2. Prioritize housing needs of residents over the needs of tourists when the two aims conflict

This can be achieved in a number of ways on varying levels. As examples:

1. Require that STRs be allowed only to applicants who are primary residents of the home they are renting

2. Place a limit on the number of STRs that are allowed in the community

3. Impose a limit on the number of days a STR can be rented out in a given year Staff also looked into the underlying reasons and objectives as to why some local Colorado mountain communities adopted the regulations that they did. There was no “one size fits all” and each community has regulated STRs in their own way depending on local conditions. The last few years has brought a lot of attention to how small mountain communities are addressing their local housing stock and how they are regulating short term rentals. Attached are a few recent articles. Most communities and studies currently appear to be mostly concerned about residential units being removed from the existing stock of housing, thereby putting more strain on housing supply, and new regulations appear to be attempting to address this issue. However, the Planning Commission was more inclined to consider more incentives that would prioritize primary residents’ ability to obtain a STR permit rather than restrictions that would preclude non-primary residents. Among the items that the Planning Commission had identified:

1. Place a limit on the total number of STRs being operated by non-primary resident owners while not placing a limit on number of STRs being operated by primary resident owners

2. Incentivize primary resident owner/operators such as; reduced fees or reduced process for a permit, not requiring a permit at all, etc.

3. Find ways to incentivize building additional housing that would effectively replace the housing that STRs removed from the housing stock, such as encouraging the construction of ADUs for residential use (this goes beyond the scope of this effort, but probably a worthwhile discussion).

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May 2021 This working session continued conversation of a few different topics related to revising the STR regulations. Among those topics were the following:

1. Reviewed the total number of STRs in each Commissioner district and their proportion to total number of housing units (approximately 3.7% of all housing units are currently STRs).

2. The PC took public comment. They heard from many who explained how STRs support the local economy and how the STR program supports individual families’ ability to keep real estate in the family. There were also concerns about trash, noise, and party houses communicated by members of the public.

The Planning Commission expressed concern that there may not be a “problem” to solve with a cap on the total number of STRs in the County. This comes on the heels of information that indicates there has not been a substantial growth rate of STRs since the program was implemented. During the May working session, Staff prepared some draft revisions that would help with these ideas for Planning Commission discussion. July 2021 During this working session, Staff provided data on when STR homes were purchased by their current owners to understand how many might have been purchased for the sole purpose of renting them out. As expected, a majority of STR homes were purchased within the last 3 to 5 years, but many were also purchased/owned by the same persons for decades indicating that many STR owners have had their residential unit for a long time.

Since the previous working session, some neighbors were raising serious concerns about trash being left outside by STR occupants that attract bears and other wild animals. DISCUSSION As a result of the information gleaned from these working sessions, public comment and participation, the following draft revisions are being presented to the Planning Commission for consideration:

1. Place a cap of 5.5% of the total number of residential units in unincorporated Clear Creek County for short term rentals. This value accommodates all of the existing known STRs and allows for approximately 50% growth in the number of short term rentals. This solution maintains the ability for all current short term rentals to remain and even allows for a roughly 50% growth in STRs, but it also places a modest limit to assure that STRs do not overwhelm the County and assures the majority of residential units remain available for residential use.

2. STRs that are ‘owner occupied’ are exempt from the 5.5% restriction and which permits are good for two (2) years instead of one (1). The large-picture recommendation from some of the big STR studies and papers was to openly allow ‘owner-occupied’ STRs because this very clearly allows homeowners who are residents to be able to generate income from their residence to live in it by renting out a room, or the whole residence while the owner is away. This is also consistent with the Planning Commission’s goals t incentivize primary resident owner-occupiers for the same reason.

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3. Eliminate the 8-person limit on short term rentals on lots under 2-acres, thereby allowing existing infrastructure and existing space to determine the total number of persons allowed in any STR. Adds a proposed limit of no more than 2-persons per legal bedroom, which is consistent with OWTS restrictions. While not common, a few STR owners were caught not able to allow their STR to be fully occupied because of this 8-person limitation on STRs located on lots of less than 2-acres in size even though they had the appropriate space and infrastructure (water and sewer) to do so. The Planning Commission felt that existing space for parking, and presence of adequate infrastructure should determine the maximum number of occupants than lot size. With this, however, staff is recommending that the number of bedrooms also be a factor in that determination and that regardless of other factors, there should be no larger occupation than 2-persons per bedroom. This is consistent with OWTS (onsite wastewater treatment system) regulation sizing requirements.

4. Clarify garbage storage requirements by following Colorado Parks and Wildlife recommendations of allowing trash to be stored in bear-proof trash containers (ie; heavy-duty steel enclosures with a locking lid). Otherwise, all trash must be stored inside a building and may be left outside only on the day of on-street pick up. Staff received some very strong comments about the ability of STR owners to be able to adequately manage trash that is generated. Considering that the entire County is located in high wildlife areas that include bears, racoons, and other animals that have a tendency to rummage through trash, it appears to be important for these regulations to clarify the importance to follow Colorado Parks and Wildlife recommendations for trash management. Some public comment has advised for these regulations to impose even stronger restrictions on when/how trash is left outside. Short of additional professional advisement from CPW, Staff will leave it up to the Planning Commission to consider stronger restrictions if it feels appropriate.

5. Miscellaneous revisions to increase the efficiency of permit review and reduce the amount of time it takes to review a permit application. As a practice, Staff is continuously searching for efficiencies that effectively ‘cut the fat’ out of process without reducing the effectiveness of a policy. Much is accomplished without revising regulations. In this instance, staff has found efficiencies that can be obtained by changing some process requirements in STR application review.

REFERRAL AGENCY AND PUBLIC COMMENTS Referral Agencies and County departments were notified of these proposed revisions to the Zoning Regulations and the following referrals have been received:

• Colorado Department of Transportation (CDOT) A response was received from Rick Solomon asking that we clarify what type of traffic and ample vehicle parking that is needed such as 5th wheel, RV campers or construction equipment that will not fit in the designated off-street parking areas. What assurance will CDOT have that parking on state highways will be monitored, prohibited and controlled? Parking instructions must be part of the rental.

• CORE aka IREA Response received from Brooks Kaufman, Lands and Rights of Way Manager indicating that CORE has no comment.

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CLEAR CREEK FORUM In addition to our referral process, staff posted this effort on the ‘Clear Creek Forum’ public participation site where anyone can review posted information, provide comments, respond to posted comments, and take polls. There has been very robust participation on this webpage and can be found in Exhibits __, __, and __. CLEAR CREEK COUNTY 2017 COMMUNITY MASTER PLAN The new Clear Creek County 2017 Community Master Plan does not provide specific guidance relating to short term rentals. However, it is important to consider the economic development goals and housing goals that are noted. Economic Development goals note the desire to diversify the County’s economy, in part, by supporting the growth of the tourism/recreation economy, including but not limited to; building on the County’s locational advantages for pass-through visitor services by encouraging lodging, retail and transportation services (Goal D, Strategy 7):

Chapter 4: Economic Development Guiding Principles for Economic Development 1. Diversification – Support the efforts of the County to have a more diverse economic base. 2. Employment – Support opportunities to expand the County’s job base. 3. Supporting Local governments and Sub-Areas – Support economic activity throughout the

County. Understanding the important rale local governments and sub-areas play as economic centers.

4. Tourism and Recreation – Support the role that tourism and recreation play in the regional economy.

5. Mining and resource Extraction – Support the continuation of mining and broadening the opportunities for resource extraction

6. Transportation – Support systems that create a “backbone” for regional economic activity. 7. Infrastructure – Support the development of infrastructure that facilitates economic

development, and where it demonstrates a net benefit to the County. 8. Investment – Support investments in economic development only where it demonstrates a net

benefit to the County. Economic Development Policy

Goal A: Clear Creek County will make a commitment to foster new economic development opportunities that diversify the economy and support the fiscal and economic health of the County. Goal B: Clear Creek County will make a commitment to increasing its employment base of jobs at all levels, but particularly primary jobs, in such industries as manufacturing, technology, and service. Goal C: Recognizing the importance of the municipalities and sub-areas as economic centers of the region, the County will make a commitment to promoting intergovernmental cooperation and public-private partnerships that encourage innovation and creativity in the economic expansion of our area. Goal D: Recognizing the importance of tourism and recreation to the economy and to the health of the County’s retail and service core, Clear Creek County will make a commitment to encourage sustainable cultural and recreation-based tourism development that enables the County to attract year round destination visitors as well as pass-through visitor traffic. Goal E: Recognizing the evolving role of (the) County’s natural resources as an income base and revenue source, the County will make a commitment to encourage the on-going development of resource-based industries including but not limited to minerals, water and alternative energy generation, while also embracing the County’s mining heritage and exploring opportunities for mine site redevelopment.

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Goal F: Recognizing there is a need to coordinate community investments in infrastructure and other public facilities with economic development opportunities and employment centers, Clear Creek County will make a commitment to maximize the value of these assets to achieve economic development objectives. Chapter 5: County Assets and Infrastructure; Housing Goal A: Provide adequate and diverse housing opportunities within the County for all population segments in close proximity to transportation and other required infrastructure; within incorporated areas, Multiple Use areas, and other areas identified by the Master Plan for higher density or mixed-use development. Goal B: Preserve and improve the existing housing stock Goal C: Ensure new affordable and workforce housing is targeted towards low to moderate income families.

Short Term Rentals can provide more diversified lodging that could build on tourism/recreation economic development goals in the County, as long as it does not hinder the County’s goals of preserving existing housing stock for long term residents. TAXES THAT ARE COLLECTED FROM SHORT TERM RENTALS As a reminder, there are three (3) types of tax that are collected from short term rentals; sales tax, lodging tax, and property tax. Clear Creek County collects a 1% sales tax that goes into the General Fund, and a 2% lodging tax that goes directly to fund the Clear Creek Tourism Bureau. Property tax is also collected. At this time, STR properties are still assessed at the 7.15% residential tax rate. As per the County Assessor’s Office, the state has not yet provided legal authority to allow County Assessors to assess residential property being rented out as STRs at the 29% rate that is charged to lodging, commercial, and other non-residential property. The 1% sales tax and 2% lodging tax is collected by the state and then disbursed back to the County. As per information from the Colorado Department of Revenue, the state imposes an additional sales and use tax of 2.9%. In addition to collecting state sales/use tax, the state collects sales tax on behalf of several municipalities and counties, including Clear Creek. We are referred to as “state collected” jurisdictions. All counties, except for Broomfield and Denver Counties, are “state collected”. Lodging owners or their management companies who rent rooms and accommodations for less than 30 days must collect and remit sales tax. This includes all lodging services including STRs. Additionally, the County Lodging Tax (CLD) is a tax levied only in certain counties (including Clear Creek) and is applied specifically to lodging services. Lodging owners are liable for the county lodging tax on all receipts from lodging when the stay is less than 30 consecutive days. A Colorado sales tax license is used to purchase tangible personal property items tax-free for the purpose of selling that tangible personal property, and collecting and remitting to the Department of Revenue sales tax on those sales. All businesses that sell tangible personal property must obtain a Colorado sales tax license and maintain a sales tax account with the State. As part of the Count’s STR permitting program, applicants are required to submit a copy of their state sales tax license with their application for a STR permit. This assures that the STR is “in the system” and that the state knows about them and can collect taxes. Some STR platforms like Airbnb automatically collect sales and lodging tax with each sale and remit to the state on behalf of their users.

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Sales and lodging taxes are charged for each sale. Therefore, when someone purchases one night at a lodging unit, that purchase price is subject to sales and lodging tax. Subsequently, during nights in which the vacation rental is not rented out, no sales/lodging tax is collected because no sale has occurred. STAFF RECOMMENDATION At this time, Staff recommends approval of the draft regulation as prepared.

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CLEAR CREEK COUNTY PLANNING COMMISSION RESOLUTION #PC-21-02

AMENDING THE CLEAR CREEK COUNTY ZONING REGULATIONS SECTION 12 SPECIAL USE PERMITS; AND

SECTION 23 DEFINITIONS

WHEREAS, C.R.S. §29-20-104 et seq. authorizes boards of county commissioners to plan for and regulate the use of land including a recommendation by the County Planning Commission and proper public notice; and WHEREAS, C.R.S. §30-28-111 et seq. authorizes boards of county commissioners to adopt and amend zoning regulations pursuant to specified procedures for the purpose of promoting the health, safety, morals, convenience, order, prosperity or welfare of the present and future inhabitants of the county; and WHEREAS, C.R.S. §30-28-116 authorizes boards of county commissioners to amend county zoning regulations pursuant to specified procedures including review by the county planning commission and notice to the public; and WHEREAS, on December 19, 2017, the Clear Creek Board of County Commissioners modified the Clear Creek County Zoning Regulations for the purpose of allowing and regulating the use of Short Term Rentals; and WHEREAS, the current amendment modifies the Zoning Regulations in accordance with Exhibit A attached hereto for the purpose of revising the regulations that regulate the use of Short Term Rentals; and WHEREAS, the Planning Commission, pursuant to public notice published September 1, 2021, held a public hearing on September 15, 2021 to consider this Resolution and recommendation to the Board of County Commissioners; and NOW, THEREFORE BE IT RESOLVED that the Planning Commission hereby certifies to the Board of County Commissioners, pursuant to C.R.S. §30-28-113, that the Clear Creek County Zoning Regulations be amended as stated in the attached Exhibit “A” hereto, pursuant to the following findings of fact.

FINDINGS OF FACT

1. The Planning Commission acknowledges that it is important to promote the health, safety, morals, convenience, order, prosperity, and welfare of the present and future inhabitants of the County.

2. It is desirable to update the zoning regulations so that it remains consistent with changes in land use patterns and law.

3. These regulations are intended to revise the Regulations for Short Term Rentals in order to ; a) place a cap of 5.5% of the total number of residential units for short term rentals, b) exempt short term rentals from the 5.5% cap that are ‘owner-occupied’, c) eliminate the 8-person limit on short term rentals on lots under 2-

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acres, d) clarify garbage storage requirements, and e) make miscellaneous revisions to increase permit review efficiencies.

4. These revisions are consistent with the following goals and objectives of the Clear Creek County 2017 Community Master Plan as follows:

Economic Development Policy Goal A: Clear Creek County will make a commitment to foster new economic

development opportunities that diversify the economy and support the fiscal and economic health of the County. Goal D: Recognizing the importance of tourism and recreation to the economy and to the health of the County’s retail and service core, Clear creek County will make a commitment to encourage sustainable cultural and recreation-based tourism development that enables the County to attract year-round destination visitors as well as pass-through visitor traffic. Housing Goal B: Preserve and improve the existing housing stock

5. Comments were received from: Colorado Department of Transportation CORE (aka IREA)

Comments and participation from numerous members of the public on the Clear Creek Forum online participation webpage

NOW, THEREFORE BE IT FURTHER RESOLVED that, should meaningful additional or conflicting information regarding these regulations be presented to the Board of County Commissioners during the Board’s public hearing(s), the Board should remand the draft regulations to the Planning Commission for further review prior to making a decision on these regulations. CERTIFIED this 15th day of September, 2021, at a regular meeting of the Clear Creek County Planning Commission. ________________________________ Russ Clark, Chair Clear Creek County Planning Commission

________________________________ Adam Springer, Secretary Clear Creek County Planning Commission

SECTION 23. DEFINITIONS EXHIBIT ‘A’ SHORT TERM RENTAL: The nightly or weekly rental of dwellings, dwelling units, mobile homes or rooms, excluding hotels and motels, that accommodates up to eight (8) individuals at one time 2 people per legal bedroom, for less than 30 consecutive days, including but not limited to: single family dwellings, duplexes, multi-family swellings, townhomes, condominiums, time share, or similar dwellings. (revised May 1, 2018) SHORT TERM RENTAL, LARGE: A short term rental that accommodates nine (9) or more individuals at one time. (revised May 1, 2018) PRIMARY RESIDENCE: a residence which is the usual place of return for housing as documented by the occupant’s: 1) driver’s license OR Colorado state identification card; AND 2) voter registration; motor vehicle registration; OR designated residence for tax purposes. An applicant for a Permit under the Short Term Regulations may have only one (1) primary residence for purposes of these Regulations. SECTION 12 SPECIAL USE PERMITS 1207. SHORT TERM RENTAL PERMIT 1207.1. SUBMITTAL REQUIREMENTS

A complete application and appropriate documentation must be submitted to the Planning Department by the applicant, including:

1207.1.1. Completed Short Term Rental Registration Form as provided by the Planning Department.

1207.1.2. Registration Fee 1207.1.3. Evidence of legal water supply

1207.1.4. Evidence of the availability of connection to a sanitary sewer system or an adequate County approved onsite wastewater treatment system (OWTS) for the number of occupants proposed.

1207.1.5. A scaled map or narrative clearly indicating and explaining the following: a. lot size,

b. subject parcel boundaries, c. location of residence, d. location of appropriate parking spaces, e. location of any outdoor garbage storage areas, f. location of snow storage areas, g. location of any outdoor cooking/fire facilities,

1207.1.6. Copy of Sate of Colorado Sales Tax License for the STR 1207.1.7. Landowner Authorization if the applicant is someone other than the registered

owner of the property

1207.2. STANDARDS FOR SHORT TERM RENTALS All short term rentals shall be subject to the following:

No more than 5.5% of the total number of residences, in any given year, in unincorporated Clear Creek County shall be issued permits for short term rentals. The number of residences shall be determined by calculating the total number of residential addresses as found in the Clear Creek County Mapping Department address database. Short Term Rentals located within a primary residence are exempt from this restriction.

1207.2.1. Operating Permit. All short term rentals must have an operating permit Permits are issued by the Planning Department. The permit shall be maintained and signed by the owner and if applicable, any property management company representative, agent, or designee. An operating permit for a specific short term rental shall be transferable to a different owner in accordance with procedures in this Section and as established by the Board of County Commissioners. once a Completed Short Term Rental Registration Form and Registration transfer fee is received. The new owner must comply with the notification and posting requirements as stated in these regulations. An operating permit shall be effective on and following the date of issuance, through the remaining calendar year in which it is issued, unless surrendered or suspended or revoked for cause. No more than one (1) operating permit shall be issued and effective in any given calendar year for each short term rental. Operating permits for primary resident-hosted rentals shall be effective on and following the date of issuance, through the remaining calendar year and the entire subsequent following year not to exceed a period of two (2) years.

1207.2.2. Regulations Compliance. No operating permit will be issued for a property

that is not in compliance with Clear Creek County regulations applicable to the property. Non-compliance with any of those regulations also is grounds for revocation of an Operating Permit.

1207.2.3. Fees. Fees will be established by the Board of County Commissioners and published in the Planning Department Fee Schedule. Pro-ration for an operating permit issued after January 1 in any given year shall not be authorized.

1207.2.4. Taxes. Owner is responsible for maintaining a State of Colorado Sales Tax License and remitting applicable Federal, State and Local Taxes.

1207.2.5. 24-hour Contact Person. Each short term rental owner shall have a contact person responsible for the short term rental and shall be available on a twenty-four (24) hour basis, seven days per week, and during periods in which the structure is being rented. The 24-hour contact person may be the owner, a property management company representative, or other person employed, authorized, or engaged by the owner to manage, rent or supervise the short term rental. The 24-hour contact person shall maintain a residence or permanent place of business within one (1) hour driving distance to the short term rental. The 24-hour contact person will be identified in writing before an operating permit will be issued. The person must be an individual, and be identified by company (if applicable), business telephone, cell phone, home phone, business or home (whichever is applicable), mailing address, and email address. The 24-hour contact person may be changed in writing delivered or sent to the Planning Department. Adjacent property owners whose property boundaries are within one hundred (100) feet of the subject parcel where the STR is located shall be provided written notice of the 24-hour contact person.

1207.2.6. Safety. The short term rental shall undergo and pass an initial safety inspection or provide other evidence of adequate safety as determined by the Chief Building Official prior to issuance of the operating permit.

The short term rental shall contain at least one operable fire extinguisher and operable smoke alarms as required by the Chief Building Official. The short term rental shall contain operable carbon monoxide alarms in compliance with Title 38, Article 45 or the Colorado Revised Statutes.

1207.2.7. Water/Sanitation and Occupancy. The short term rental shall submit verification of the availability of an adequate water supply plan or State-approved well permit, and verification of connection to a sanitary sewer system or the availability of an adequate County approved onsite wastewater treatment system (OWTS) for the number of occupants proposed. Such OWTS permit may be supplied by the Environmental Health Department as determined by the Environmental Health Director.

1207.2.8. Noise. While occupying or visiting a short term rental, no person shall make, cause, or permit unreasonable noise to be emitted from the short term rental that is audible upon private premises in excess of the limits set forth in title 25, Article 12, Colorado Revised Statutes or otherwise disturbs the peace.

1207.2.9. Garbage. Clearly-defined garbage storage areas shall be provided, with an adequate number of garbage containers. A plan for regular garbage pick-up or individual plan for garbage removal (including name and location) must be identified for all occupants. All outside garbage storage areas and containers shall be of a bear-proof design that is made of a heavy-duty steel enclosure with a locking lid or opening. Otherwise, all other garbage containers shall not be left unattended for on-street pick-up and shall only be left outside on the day of on-street pick-up. The property shall be properly maintained and free of garbage, trash and litter.

1207.2.10. Lighting. Outdoor lighting shall conform to the Lighting standards expressed in Section 10: Development Standards (1008.4: Lighting).

1207.2.11. Access and Parking. Off-street parking shall be provided in the amount of 1 space per bedroom. If a short term rental is accessed by a shared driveway, written permission to access the drive must be obtained from each shared driveway property owner. Occupants and visitors utilizing short term rentals must park in designated off-street parking spaces. On-street parking within a County road or right-of-way or within a private road right-of-way is prohibited. Written property owner permission is required for parking on adjacent or neighboring properties. No person shall be permitted to stay overnight in any motor vehicles, camping vehicles, or recreational vehicles (RVs) which are parked at a short term rental.

1207.2.12. Snow Storage. On site snow storage shall be provided. 1207.2.13. Fires. Fire places, fire pits, charcoal braziers, wood burning stoves, or other

outdoor cooking or fire facilities that could throw off embers shall be allowed only in designated facilities with appropriate defensible space established around the fire facility and short term rental residence. A water supply such as bucket of water or hose hooked to a faucet or other type of fire suppression (ie: sand) shall be available at the location of the fire facility for use to put out fires. Fires shall be completely extinguished before the short term rental is vacated. No fuel shall be used and no material burned which emits dense smoke or objectionable odors.

1207.2.14. Firearms and Fireworks. The discharging of firearms or fireworks on the premises of the short term rental is strictly prohibited.

1207.2.15. Signs. Signs for advertising shall not be permitted on short term rentals except as outlined in Section 10(1004) of the Zoning Regulations.

1207.2.16. Compliance with the terms and conditions set forth herein shall be the non-delegable responsibility of the owner of the short term rental; and each owner of a short term rental shall be strictly liable for complying with the conditions set forth in the Section or imposed by Clear Creek County. Owner shall comply with all applicable County, State and Federal Regulations.

1207.2.17. Addressing Address numbers shall be posted on the exterior of the building so that

it is clearly visible from the traveled road. 1207.2.18. Large Short Term Rentals Large short term rentals, as defined, are restricted to lots of 2 acres or

greater in size. 1207.2.19. Limitation of Liability. Clear Creek County assumes no responsibility for the

operation of the site and Owner covenants and agrees to hold Clear Creek County harmless for any injury or damage which may occur, or whatever types or nature, as the result of the operation of the short term rental. Owner shall maintain appropriate liability insurance for the short term rental. Owner further warrants and agrees to compensate Clear Creek County for any expense incurred in the defense of any lawsuit or other type of action which may be brought against said County as a result of said Owner’s operation of this use. Nothing contained in this Section shall allow short term rentals if otherwise prohibited by any applicable private covenants. Covenants are privately enforced according to their terms.

1207.2.20. Posting of Information. The owner shall post information inside the short term rental in a conspicuous location for its occupants including, but not limited to, the following information:

1. A copy of this Section 1208 Short Term Rental Permit 2. The name, address, and telephone number of the 24-hour contact

person, management company, agent, or owner of the short term rental that can be reached on a twenty-four (24)-hour basis.

3. The maximum number of persons allowed to occupy the short term rental.

4. The maximum number of vehicles allowed to park on the short term rental property. All vehicles must park in designated off-street parking spaces. On-street parking or on neighboring properties is prohibited.

5. A map clearly indicating the subject parcel boundaries, location of residence, and location of appropriate parking spaces.

6. The day of garbage pick-up or plan for garbage removal and notification of all rules and regulations regarding garbage removal.

7. The entire property address (including house number, street name, and city) shall be visibly posted inside the STR with instructions to call 911 in the case of an emergency.

8. Information regarding fire suppression types available onsite. If a Fire Ban is in effect, the terms of that ban must be included.

9. Information regarding fire/emergency evacuation routes out of the area. 10. The discharging of firearms or fireworks on the premises is strictly

prohibited.

1207.2.21. Enforcement If granted, the Permit will be monitored for compliance by the Planning Department. Written notice of the nature of the violation shall be given to the property owner, agent, or the applicant for any relevant permit. Notice shall be given in person, by e-mail, or by certified U.S. Mail. The notice shall specify the alleged violation, and, unless a shorter time frame is allowed by this Section or through stipulations set forth in the approved Permit, shall state that the individual has a period of fifteen (15) days from the date of the notice in which to correct the alleged violations before further enforcement action shall be taken. If non-compliance with the Operating Permit regulations is not cured timely, or if there are multiple credible or validated complaints manifesting the owner’s inability or unwillingness to control the use of the Short Term Rental, a hearing may be scheduled before the County Commissioners to determine if the permit should be revoked. The holder of the permit shall be notified of the hearing date and time by written notice given at least ten days before the hearing, from the date of the notice. Notice will be given to the permit holder or its designated contact person, by e-mail, personal delivery, posting on the property, or first class mail.

1207.2.22. The relevant decision-making entity may deny or withhold the renewal of an annual operating permit if the property is in violation of any Clear Creek County regulations applicable to it, multiple credible or validated complaints have been received during the most recent calendar year of operating as a Short Term rental, or until a violation related to the property, is corrected.

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Short Term Rentals (STR's)in Unincorporated

Clear Creek County

µ0 2 4 6 81

Miles

STR's By Commissioner DistrictDistrict 1 (32 STR's)

District 2 (30 STR's)

District 3 (66 STR's)

Commissioner DistrictsDistrict 1 (George Marlin)

District 2 (Sean Wood)

District 3 (Randy Wheelock)

This map is visual representation only, do not usefor legal purposes. Map is not survey accurate and

may not comply with National Mapping AccuracyStandards. Map is based on best available data as

of May, 2021 .H:\Arcmap_Projects\Planning\STR_050521.mxd

Community Permit Req'd? Primary Residency Req'd? # of Permits allowed Bldg. Inspection Req'd? Occupancy Limit?Clear Creek County Yes None Unlimited Yes Max 8, and based on water/sewer avalabilitySummit County Yes None Unlimited Depending on unit type and sewer availabilityGrand County Yes None Unlimited Yes, but not specified in regulationsPark County Yes None One per property At County's discretion Based on water/sewer availability and house occupancyJefferson County Yes + Spec. Exemption from BOA None Unlimited Bldg. Stds must be met Not more than 5 bedrooms in dwellingEagle County NoLake County Yes None Unlimited No Based on sewer availabilityChaffee County No? (local HOA permission req'd) None Unlimited No Based on sewer availability

Georgetown Yes No 5% of total units in each Ward Yes Max 2 adults per bedroomIdaho Springs Yes Yes 15 Yes Does not appear to beEmpire Yes No Unlimited Yes NoSilver Plume No

Summary of Articles, Reports and Studies found related To Short Term Rentals

1. Harvard Law and Policy ReviewHow Airbnb Short-Term Rentals Exacerbate Los Angeles’s Affordable Housing Crisis: Analysisand Policy RecommendationsFeb. 2, 2016- The article indicates that “inappropriate investors” permanently remove residential units from

the residential housing stock by converting many units to STRs. But on the upside, Airbnbalso allows homeowners to use STRs to make some extra money to help pay for their unit.

- On average, as much as 3% of apartments in the city’s neighborhoods where tourists frequenthave been converted to Airbnb’s.

- Neighborhoods like Venice (adjacent to the beach), up to 12.5% of apartments have beenconverted to Airbnb’s.

- In tight housing markets, a sudden reduction in housing supply “naturally” increases rents(called supply shock). Generally, a 1% decrease in supply leads to a 0.2% increase in rent.

- Additional data is needed to know how STRs affect evictions and rents.- San Francisco: has a 75-day limit on the number of days per year a unit can be listed. There

is also a cap of the # of units any individual business can list in a given year.- Recommendations: prioritize housing needs of residents over needs of tourists when the 2

aims conflict. Establish policy that;a. Addresses rent increasesb. Adds to the city’s market-rate and affordable housing stockc. Discourages conversion of whole units to STRsd. Eliminates incentives that encourage “hotelization” of apartment

complexese. Protects residents from displacement

- Given the inelasticity of the housing supply, it is inappropriate for investors to permanentlyremove units from the residential housing stock in order to cater to tourists.

2. Market WatchDo Airbnbs push up rents and house prices?Feb. 2, 2021- Germany study; 14.2% increase in rents as a result of units being used for STRs.- “while a large proportion of hosts can be considered home sharers, we find an increasing

proportion of providers who have developed a professional business model from short-termrentals. Professional short-term rentals area available to tourists throughout the year, and thuscompete directly with long-term tenants, for whom the rooms are then no longer available.”

- Residential units around tourist destinations are most affected- “Regulations on home-sharing should (at most) seek to limit the reallocation of housing stock

from long-term rentals to short-term rentals without discouraging the use of home-sharing byowner-occupiers”.

- One suggestion; levy an occupancy tax solely on property owners who rent out an entire property for an extended period of time, and require proof that property owners live in the homes they own to avoid the tax.

3. Zillow

Experts: Short-Term Home Rentals Have Little to No impact on Housing Affordability Dec. 6, 2016 - Survey was taken among housing experts to get their opinion (the article did not appear to

explain who a “housing expert” is) - Only 5.1% of housing experts with an opinion thought the ability to rent out whole homes

would have a meaningful impact on the supply and affordability of long-term rentals.

4. Vox CEPR Policy Portal Short-term rentals and the housing market: Quasi-experimental evidence from Airbnb in Los Angeles Dec. 20, 2018 - L.A. County study after policy change of restricting rentals of entire homes - Regulations Examples: in Berlin, a home owner must occupy the home a minimum of 50% of

the time. san Francisco: 90-day per year rental maximum. Amsterdam: 30-day rental maximum per year.

- Article said regulations could affect housing prices both ways; depending on the highest and best use

- Study suggests a reduction in housing prices due to home-sharing ordinances (ordinances that allow for owner-occupied STRs only)

- In areas that are attractive to tourists, the effect of STRs on property values can be large: 10 – 14% increase in value near beaches, and near downtown L.A.

5. Real Estate (United Kingdom)

The Airbnb Effect On Housing And Rent Feb. 21, 2020 - There are about 80,000 listings on Airbnb in London. 55% of those are for entire properties

(residential units) - Capital Economics: 2.7% (out of 1.5 million) of U.K.’s landlords have switched from long

term rentals to STRs - Spain: Some studies suggest rent has gone up 50% due to presence of STRs in some

neighborhoods - Berlin: a permit is required if the landlord wants to rent 50% or more of their main residence

as a STR.

6. Report prepared by the California Economic Forecast The Effect of Short Term Rentals on the Supply of Housing in Santa Barbara City and County May 12, 2016 - Found an increase in 1/10th of 1% of long term rentals available to the public as a result of the

prohibition of STRs (which is not significant)

- The study does not support the perception that STRs have a significant negative impact on the supply of long-term housing

7. 9 News (Denver) article by Jeremy Jojola

Short Term Rentals have little Impact on Denver housing Market, City Report Says Sept. 12, 2019 - City and County of Denver’s new “primary residence rule” has helped reduce the impact of

STRs on the housing market. - Therefore, STRs have very little impact on the cost of housing

(Denver imposes a rule similar to Idaho Springs in that the residence must be your primary residence in order for you to apply for a STR permit).

8. CBC, Natalie Nanowski

Stricter bylaws for Short Term Rentals come into Effect this Week Sept. 8, 2020 - City of Toronto enacted rules that allow only primary residents to rent out their home. - Purpose is to ensure homes are not removed from the City’s housing stock for STRs.

9. TransWorld SNOWboarding (Tyler Macleod)

The Long-Term Effects of Short-Term Rentals: an examination of the Mountain town Housing Crisis Jan. 25, 2019 - First-person observations and experiences of a snowboarder trying to find housing in Grand

and Summit Counties and the effects of STR industry on them over time. - In Winter Park, author checked Craigslit for housing ads. 4 properties were being advertised

for rent. - At the same time, 300 STRs were being advertised on Airbnb. - AirDNA identified only a 16% occupancy rate of existing STRs, so most housing converted

to STRs aren’t even being used a majority of the time.

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How Airbnb Short-Term Rentals Exacerbate

Los Angeles’s Affordable Housing Crisis:

Analysis and Policy Recommendations

Dayne Lee*

I. INTRODUCTION

Los Angeles, California, is in the midst of an affordable housing crisis.

Rents have increased by 7.3% in 2014 alone, and the median renting house-

hold already spends 47% of its income on housing.1 This crisis has added

fuel to the contentious debate over Airbnb, a startup technology company

that facilitates short-term rentals (STRs) of residential homes to tourists.

Whereas Airbnb and its users tout its positive effects on tourism, cultural

exchange, and the environment, its critics contend that Airbnb harms neigh-

borhoods, distorts the housing market, undermines labor unions, and exacer-

bates Los Angeles’s affordable housing crisis. In regulating Airbnb,

policymakers seek to curb Airbnb’s impacts on neighborhood character and

housing while harnessing the economic activity it brings.2

Employing legal, statistical, and secondary source analysis, this article

explores how STRs affect the price and aggregate supply of affordable hous-

ing rentals in Los Angeles, and how municipal policymakers can best regu-

late Airbnb. In Section I, I briefly outline the contours of Los Angeles’s

affordable housing crisis, and describe Airbnb and its growth in Los Ange-

les. The topics of Section II are the effects that STRs have on rents and Los

Angeles’s aggregate supply of affordable housing. Section III of this article

analyzes how and to what extent Airbnb leads to displacement, gentrifica-

tion, and segregation in Los Angeles’s residential neighborhoods. In Section

IV, I assess strategies, regulations, and policies that municipal policymakers

and stakeholders can use to regulate Airbnb. Finally, in the Conclusion, I

recommend a set of regulations, taxes, and community-benefits agreements

that will force Airbnb to be a partner that promotes, rather than impedes, the

goals of affordable housing advocates.

* J.D. Candidate, Harvard Law School (expected 2017). The author gratefully acknowl-edges professors Rick Su and Esme Caramello, as well as Eloise Lawrence for their adviceregarding this article. He thanks the dedicated Harvard Law & Policy Review editors for theirthoughtful editing and comments.

1 See Los Angeles Home Prices & Values, ZILLOW (Sept. 30, 2015), http://www.zillow.com/los-angeles-ca/home-values/ [http://perma.cc/J82K-A3F3]; Rosalie Ray et al., Impactsof the Widening Divide: Los Angeles at the Forefront of the Rent Burden Crisis, UCLA LUSKIN

SCHOOL OF PUBLIC AFFAIRS CENTER FOR THE STUDY OF INEQUALITY, Sept. 2014, at 8, http://issuu.com/csiucla/docs/ziman_2014-08w/1 [http://perma.cc/P4GH-KFHW].

2 See, e.g., Steven Leigh Morris, Airbnb is Infuriating the Neighbors. Is it Time for NewRules?, LOS ANGELES WEEKLY (Jan. 22, 2015), http://www.laweekly.com/news/airbnb-is-infu-riating-the-neighbors-is-it-time-for-new-rules-5343663 [http://perma.cc/4JG2-KAJM].


230 Harvard Law & Policy Review [Vol. 10

Airbnb likely reduces the affordable housing supply by distorting the

housing market in two interconnected mechanisms. The first such mecha-

nism is one of simple conversion: any housing unit that was previously oc-

cupied by a city resident, but is now listed on Airbnb year round, is a unit

that has been removed from the rental market and has essentially been added

to Los Angeles’s supply of hotel rooms. This leads to a real, but likely mild,

increase in citywide rents, an effect that is concentrated in affluent or gentri-

fying neighborhoods along the city’s central core. More disconcertingly,

conversion reduces Los Angeles’s already-limited supply of affordable hous-

ing. The second mechanism is “hotelization.” So long as a property owner

or leaseholder can rent out a room on Airbnb for cheaper than the price of a

hotel room, while earning a substantial premium over the residential market

or rent-controlled rent, there is an overpowering incentive to list each unit in

a building on Airbnb rather than rent to Los Angeles residents, thereby creat-

ing “cottage hotels.” This decreases the supply of housing and spurs dis-

placement, gentrification, and segregation.

These two mechanisms distort the rental housing market, which tradi-

tionally does not overlap with the hospitality sector. Tourists stay in hotels

that are specifically permitted for and developed in commercially zoned

neighborhoods. Residential housing is zoned and built through a wholly dif-

ferent process. Airbnb facilitates the inappropriate merging of the residential

and tourist markets on an unprecedented scale, and unlike with a shortage of,

say, shoes or oranges, neither the market nor the public sector can swiftly

replace the housing units that Airbnb removes from the marketplace. Thus,

city officials regulating Airbnb—and regulating STRs generally—must ad-

dress conversion and hotelization head on.

As detailed in Section IV and the conclusion of this article, policymak-

ers should pursue targeted bans and regulations that discourage conversion

and hotelization. A simple tax on STRs alone will likely be insufficient to

fund the replacement of converted units, and may serve to further incentivize

hotelization. In exchange for Airbnb’s cooperation with enforcement, city

officials could allow Airbnb to participate directly in expanding the hospital-

ity market.

A. Background: Los Angeles’s Affordable Housing Crisis

Los Angeles, California, has become America’s least affordable rentalhousing market. In 2014, the average renter in Los Angeles County3 paid

3 Los Angeles is a city located within the County of Los Angeles, California. Approxi-mately one-third of Los Angeles County residents live within Los Angeles. Unless stated oth-erwise, the statistics and neighborhoods referenced in this article refer to the city of LosAngeles, not the overall county. County-wide statistics are used as they are here when city-specific statistics are unavailable.


2016] Airbnb and L.A.’s Housing Crisis 231

$1,716 per month.4 And within the city, where most residents rent, the me-dian renting household earned less than $40,000 and spent 47% of its in-come on housing.5 One in two middle-income families and nine in tenfamilies from the bottom income quintile are rent burdened, spending atleast 30% of their income on rent.6

The city’s affordability crisis has developed because of declining realwages, population growth, and zoning policies that favor single-family andluxury housing.7 The foreclosure crisis of 2010 exacerbated the affordabilitycrisis by pushing over 100,000 former homeowners into the rental market.8

At the same time, wealthier residents repopulated the city core, rapidly gen-trifying low-income immigrant enclaves such as Chinatown and HighlandPark.9 As a result, rents increased by 7.3% in 2014 alone.10 Over the pastdecade, 143,000 market-rate apartments that were once “affordable” (mean-ing that rent constituted 30% or less of a resident’s monthly income) to fami-lies earning under $44,000 per year became unaffordable.11

Los Angeles’s public housing infrastructure is ill equipped to protectlow-income renters. Experts consider the city’s Rent Stabilization Ordinance(RSO) to be weaker than comparable regulations in San Francisco or NewYork, largely because its 3% cap on annual rent increases does not apply tounits built after 1978, and because it does not prevent landlords from ex-ceeding the cap in between tenancies.12 California’s Ellis Act exempts fromlocal rent control provisions landlords who purchase a rent-controlled unitfrom a prior owner, provided that the prior owner is selling in order to exitthe business.13 As neighborhoods gentrify, evictions of RSO-protected te-nants rose by 235% in 2014 as landlords sold their protected units to com-mercial developers, who are in turn exempted from rent control obligations

4 Richard K. Green et al., 2014 USC Casden Multifamily Forecast, USC LUSK CENTER

FOR REAL ESTATE, Feb. 2014, at 12, http://lusk.usc.edu/sites/default/files/2014-USC-Casden-Multifamily-Forecast.pdf [http://perma.cc/AM24-EN57].

5 Ray, supra note 1, at 8.6 Id. at 9 (citing US Census American Community Survey data from 2009–2011).7 Id. at 6, 13.8 How Los Angeles County’s Housing Market Is Failing to Meet the Needs of Low-Income

Families, CALIFORNIA HOUSING PARTNERSHIP COALITION REPORT, May 2014, at 2, http://www.chpc.net/dnld/Housing_Need_LA_Final_060414.pdf [http://perma.cc/7BVZ-TCXT].

9 See, e.g., York & Fig, AMERICAN PUBLIC MEDIA (2014), http://yorkandfig.com [http://perma.cc/UYK9-RA46]; see also infra Fig. 2.

10 See ZILLOW, supra note 1.11 Ray, supra note 1, at 8 (acknowledging that the authors’ affordability benchmark is 30%

of income).12 See Economic Study of the Rent Stabilization Ordinance and the Los Angeles Housing

Market, LOS ANGELES HOUSING DEPARTMENT, 2009, at 8–9; see also Ben Bergman, Has RentControl Been Successful in Los Angeles?, SOUTHERN CALIFORNIA PUBLIC RADIO, (Sept. 12,2014), http://www.scpr.org/news/2014/09/12/45988/la-rent-has-rent-control-been-successful-in-los-an/ [http://perma.cc/H5G3-P24R].

13 California Ellis Act of 1985, Cal. Gov’t Code § 7060.7 (West).



pursuant to the Ellis Act.14 Meanwhile, the Section 8 voucher waitlist hasbeen closed for nearly a decade due to limited funding.15

City officials have been similarly unable to increase the stock of afford-able housing. Since 2006, the city has been able to build only a fifth of the5,300 affordable units that Los Angeles needed to add each year.16 This islargely because funding has plummeted; the Los Angeles Affordable Hous-ing Trust Fund fell from $100 million in 2008 to just $19 million in 2015,while $1.7 billion in state funds have been cut from the California Redevel-opment Agency and the Community Development Block Grant program.17

For renters, an affordability crisis is the downside to Los Angeles’s ubiqui-tous taquerias, Korean barbeque restaurants, and perennial beautifulweather.

B. Airbnb and the Short-term Rental (STR) Phenomenon

Los Angeles’s affordability crisis has developed alongside the transfor-mation of its tourism sector by STRs—rentals of entire apartments to tour-ists for fewer than thirty days—arranged through Airbnb. A pair of artstudents founded Airbnb in 2008 to help travelers bypass expensive hotelsand gain local experiences by “couch surfing” with strangers.18 Tourists usethe Airbnb website or mobile application to browse and reserve accommoda-tions in a city or neighborhood of their choice; instead of staying at a hotelor motel, a tourist can “couch surf” with, or rent an empty apartment from, astranger in another city during their vacation.

For “hosts,” Airbnb is a platform through which apartment owners orlease-holders can rent out anything from a spare living room couch to entireapartment units, with Airbnb collecting “host service”19 and “guest service”fees from each transaction.20 On its platform, Airbnb allows both hosts andtourists to exchange pictures of the units, “review” apartments and guests ona five-star system, communicate privately, and securely exchange money.

14 Leo Duran, Ellis Act Evictions in L.A. on the Rise, SOUTHERN CALIFORNIA PUBLIC RA-

DIO (Apr. 24, 2015), http://www.scpr.org/news/2015/04/24/51256/ellis-act-evictions-in-l-a-on-the-rise/ [http://perma.cc/N8XZ-ZAEY] (describing how the Ellis Act allows rent-controlledproperties to be sold to commercial developers).

15 Ray, supra note 1, at 13.16 Id.17 Ben Bergman, Garcetti Wants Airbnb to Help Solve L.A.’s Affordability Crisis, SOUTH-

ERN CALIFORNIA PUBLIC RADIO, Apr. 16, 2015, http://www.scpr.org/news/2015/04/16/51042/garcetti-wants-airbnb-to-help-solve-la-s-affordabi/ [http://perma.cc/EW8J-L7NC]; CALIFOR-

NIA HOUSING PARTNERSHIP COALITION REPORT, supra note 8.18 Jessica Pressler, The Dumbest Person in Your Building is Passing Out Keys to Your

Front Door! The War over Airbnb Gets Personal, NEW YORK MAGAZINE (Sept. 23, 2014),http://nymag.com/news/features/airbnb-in-new-york-debate-2014-9/ [http://perma.cc/4ZYV-CMRX].

19 What are Host Service Fees?, AIRBNB, https://www.airbnb.com/help/article/63/what-are-host-service-fees [http://perma.cc/Q24Q-7AMJ].

20 Brittany McNamara, Airbnb: A Not So Safe Resting Place, 13 COLO. TECH. L.J. 149,151 (2015).



Now worth thirteen billion dollars, Airbnb is among the most lucrativeposter-children of the so-called “sharing economy,” in which technologycompanies circumvent business regulations and well-established competitorsby facilitating direct, peer-to-peer exchanges of goods and services.21 Similarcottage-scale rentals have been possible since the dawn of the Internet, butAirbnb’s unique success stems from its secure and exceptionally well-de-signed website, and from its users’ positive experiences.

Airbnb has transformed Los Angeles’s hospitality industry. In 2014,Los Angeles city residents listed 11,401 units on Airbnb, including 7,316whole-unit STRs.22 By comparison, Los Angeles has 97,000 hotel rooms,though these are dispersed throughout the county.23 Approximately 135,000of the forty-five million tourists to visit the city in 2014 stayed in an Airbnbunit.24

Airbnb reports that in 2014, it generated $314 million in economic ac-tivity in Los Angeles, and that by redistributing revenue from corporate ho-tels, it helps everyday Angelenos cope with rising rents and economicinstability.25 Airbnb touts its positive effects on cultural exchange, and 37%of surveyed guests state that they would not have been able to travel to LosAngeles for as long a period of time without the service.26 Finally, Airbnbpresents home-sharing as a sustainable, energy-efficient, and environmen-tally conscious alternative to hotels.27

But criticism of Airbnb’s business practices has mounted at a rapidpace. The Venice Neighborhood Council contends that STRs are illegal be-cause they blatantly violate zoning codes banning sub-thirty-day rentals inresidential or multifamily zones.28 Hosts’ neighbors allege that rowdy tour-ists undermine public safety.29 And unions and hotels complain that Airbnbunfairly competes with hotels by avoiding occupancy taxes and zoning laws,skirting public health regulations, and undercutting unionized hotel workersby connecting its hosts with independently contracted cleaners.30

Los Angeles’s “Airbnb economy” does not match the idyllic imageAirbnb promotes, in which artistic, young professionals couch surf from Los

21 Molly Cohen & Corey Zehngebot, What’s Old Becomes New: Regulating the SharingEconomy, BOSTON BAR JOURNAL (Apr. 1, 2014), http://bostonbarjournal.com/2014/04/01/whats-old-becomes-new-regulating-the-sharing-economy [http://perma.cc/NN7V-HPU2].

22 Roy Samaan, Airbnb, Rising Rent, and the Housing Crisis in Los Angeles, LAANE(Mar. 2015), http://www.laane.org/wp-content/uploads/2015/03/AirBnB-Final.pdf [http://perma.cc/MTJ4-DLJA].

23 Hugo Martin, Lacking Sufficient Lodging, L.A. Tourism Growth, L.A. TIMES (Apr. 13,2014), http://www.latimes.com/business/la-fi-tourism-wars-20140423-story.html [http://perma.cc/5CZ6-G25J].

24 David Owens, Positive Impact of Home Sharing in Los Angeles, AIRBNB (Dec. 4, 2014),http://publicpolicy.airbnb.com/positive-impacts-home-sharing-los-angeles/ [http://perma.cc/B4W3-LCTL].

25 Id.26 Id.27 Id.28 Morris, supra note 2.29 Id.30 Samaan, supra note 22, at 15, 22–26.



Angeles to New York to Madrid, exchanging apartments through Airbnbwith their fellow travelers. In practice, 64% of Airbnb listings in Los Ange-les are for STRs of units that are never occupied by their owners or lease-holders, and operate year-round essentially as independent, unlicensed hotelrooms.31 Chances are, an apartment booked through the service is managedby a full-time investor or company that also owns or leases dozens of otherAirbnb listings.32 Such companies contract in bulk with decorators andcleaners, manage reservations, and negotiate above-market rent leases withbuilding landlords in exchange for the privilege of renting units out onAirbnb.33

Airbnb’s emergence has significant political and policy implications forLos Angeles’s tourism sector, sustainability efforts, and labor movement. Asa bona fide cultural phenomenon, Airbnb has galvanized opposition amongneighborhood organizations, labor unions, and affordable housing advocates.Yet it has also mobilized a groundswell of support from hosts and guestsalike. The narrow focus of this article, however, is the effects that AirbnbSTRs have on Los Angeles’s affordable housing market.

II. AIRBNB INCREASES RENTS, INCENTIVIZES HOTELIZATION, AND

REDUCES THE AFFORDABLE HOUSING STOCK

An Airbnb-affiliated economist claims that Airbnb is a scapegoat for

broader economic trends in Los Angeles, and that it has increased monthly

rents by just six dollars over five years.34 Rental pricing is certainly a com-

plicated topic, but there is a simple underlying dynamic between STRs and

the rental market. Tourists and renters are non-overlapping populations with

different needs, traditionally served by non-overlapping markets. But be-

cause 64% of its listings are STRs for tourists, Airbnb brings an increasing

number of the forty-five million tourists who visit Los Angeles each year

into direct competition with renters, distorting the housing market.35

Each apartment or home listed year-round on Airbnb is a home that has

been removed from the residential housing market and added to the city’s

aggregate stock of hotel rooms; I label this phenomenon “conversion.” So

long as a property owner or leaseholder can earn a substantial premium from

Airbnb rather than renting to city residents, there is an overpowering incen-

tive to “hotelize” entire buildings, further reducing the aggregate housing

31 Id. at 8.32 Adrian Kudler, Meet LA’s Most Prolific Airbnb Host with 78 Units for Rent, CURBED

LA (Mar. 12, 2015), http://la.curbed.com/archives/2015/03/airbnb_los_angeles_most_prolific_host_ghc.php [http://perma.cc/4WMD-7MXH].

33 Id.34 Kristen Lepore, Apartment Conversions to Airbnb Hotels Driving Up LA Rents, Critics

Say, SOUTHERN CALIFORNIA PUBLIC RADIO (Mar. 16, 2015), http://www.scpr.org/news/2015/03/16/50321/are-apartment-conversions-to-airbnb-hotels-driving/ [http://perma.cc/PF4S-KBST].

35 Bergman, Garcetti Wants Airbnb to Help Solve L.A.’s Affordability Crisis, supra note17.



stock. Compounding these market distortions, neither the market nor the

public sector can swiftly replenish the housing stock, given the time, cost,

and legal barriers to developing affordable housing in Los Angeles. In light

of this basic dynamic, the following sections detail how this market-mixing

function raises rents and reduces the supply of affordable housing in Los

Angeles.

A. Airbnb Increases Rents in Neighborhoods with a High Densityof Airbnb Listings

Airbnb listings are concentrated in just seven of the city’s densest, mostexpensive neighborhoods: Venice, Downtown, Miracle Mile, Hollywood,Hollywood Hills, Echo Park, and Silver Lake.36 These tourist destinationsaccount for nearly half of Airbnb listings, and 69% of all Airbnb-generatedrevenue in Los Angeles.37 In 2014, rents in these neighborhoods were 20%higher, and increased 33% faster, than rents citywide.38

36 Kudler, supra note 32.37 Id.38 Id.



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Figure 1 shows that 3,104 whole-units are listed on Airbnb in theseneighborhoods, which have a rental stock of 104,265 units.42 To the extentthat whole-unit STRs are listed throughout the year, as much as 3% of theapartments in these districts—which have a low 3.5% vacancy rate—havebeen removed from the market and converted to tourist accommodations.This distortion is particularly acute in beachside Venice, where, according toone study, 12.5% of the neighborhood’s apartments are listed on Airbnb.43

In tight housing markets with near-zero vacancy rates, a sudden reduc-tion in supply naturally increases rents, particularly because neither the mar-ket nor the public sector can swiftly add to the housing stock. Unlike withmost commodities, a shortage in housing supply cannot be ameliorated byimporting or quickly building additional units. Assuming that a given neigh-borhood permits and can physically accommodate the construction of newhousing, building an average unit of rental housing in Los Angeles requiresan investment of $315,000, three years just for permitting, and additionaltime for construction.44 Thus, a sudden removal of between 3% and 12.5% ofa neighborhood’s housing stock constitutes a supply shock.

The price effect of a supply shock in Los Angeles is compounded byannual increases in residential demand, and by the upward pressure that theallure of STR profits puts on property values, which in turn affect propertytaxes and rents. Even under a simple economic model holding the demandfor rental housing constant against a relatively flat supply curve that has aprice-elasticity coefficient of 0.200, each 1% decrease in supply would leadto a 0.2% rent increase.45 Under this model, the rent on a $2,680 one-bed-room apartment in Venice would increase by an additional sixty-seven dol-lars per month from the reduction in local supply alone.46

In addition to a supply-related rent increase, the market could be af-fected by demand pressures from the allure of STR profits, and from acceler-

42 Estimated using household size data from Mapping L.A. Neighborhoods, supra note 39.43 Samaan, supra note 22, at 3. Like the Samaan report, Section II.A of this article as-

sumes that whole-unit listings are listed year-round on Airbnb. However, it is likely that thewhole-unit STR figures cited from the Samaan report include some housing units that are infact occupied by the owner or leaseholder for most of the year, and are not listed year-round onthe service. Such units are not removed from the residential housing market.

44 Cost per unit from California Department of Housing and Community Development,see Affordable Housing Cost Study: Analysis of the Factors that Influence the Cost of BuildingMulti-family Affordable Housing in California, CAL. DEP’T OF HOUS. & CMTY. DEV. ET AL. 32(2014), http://www.hcd.ca.gov/housing-policy-development/docs/finalaffordablehousingcost-studyreport-with-coverv2.pdf [http://perma.cc/A98W-WG6T] [hereinafter Affordable Hosu-ing Cost Study]. See also Ben Bergman, LA Rent Crisis: Why Aren’t There More AffordableApartments?, SOUTHERN CALIFORNIA PUBLIC RADIO (June 12, 2014), http://www.scpr.org/blogs/economy/2014/06/12/16821/la-rent-crisis-why-aren-t-there-more-affordable-ap/ [http://perma.cc/6N8L-Q3UE].

45 See, e.g., John M. Quigley & Steven Raphael, Regulation and the High Cost of Housingin California 26 (Berkeley Program on Housing & Urban Policy, Working Paper No. W04-008, 2004) (finding that the price elasticity coefficient to supply is .360 for non-rent controlledrental markets). A regression analysis would be needed to specifically determine the Los An-geles housing market’s price elasticity.

46 See Venice Home Prices & Values, ZILLOW, http://www.zillow.com/venice-los-angeles-ca/home-values/ [http://perma.cc/87J8-3TJE].



ated inflation at the tail-end of the distribution in a housing market withnear-zero vacancies. Put simply, a renter in an Airbnb-saturated neighbor-hood seeking to occupy one of the handful of available apartments is nolonger bidding against the local residential rent price, but is instead biddingagainst the extra profit that STRs can bring.

By incentivizing the conversion of residential units to tourist housing,Airbnb causes a small, but notable, increase in citywide rents. In the neigh-borhoods with the greatest concentration of Airbnb listings, this rent-increas-ing effect is much greater; Airbnb accounts for a significant portion of theaccelerated rent inflation seen in neighborhoods such as Venice and SilverLake.

B. Airbnb Reduces Supply by Encouraging Illegal Conversion,Hotelization, and Evictions

In addition to causing a small increase in rents, Airbnb substantiallyreduces Los Angeles’s aggregate supply of housing. Thus, as residents bidfor a smaller number of available units, an increasing number of residentsare priced out of their neighborhoods, or even the city, entirely. The phe-nomenon of “hotelization” accelerates this process. Airbnb creates a strongincentive for property owners and renters to permanently “hotelize” entirebuildings by renting each unit to tourists through Airbnb rather than findinglong-term tenants. This reduces the housing supply, and places demand-sidepressure on Los Angeles’s dwindling stocks of subsidized and unsubsidizedaffordable housing.

Although Airbnb claims that it mostly provides middle-class rentersand homeowners with supplemental income, it generates 89% of its revenuein Los Angeles from whole-unit STRs without on-site hosts.47 To the extentthat such units are listed on Airbnb year-round, these figures suggest thatAirbnb’s business model is based on encouraging hotelization and evictions,not on helping renters lease out spare rooms to make ends meet.48 Althoughit is unclear what percentage of full-time Airbnb listings whole-building“hotels” constitute, news reports paint a vivid portrait of the hotelizationphenomena in action.

Entrepreneurs approach landlords in popular neighborhoods expressingtheir intent to list rental units year-round on Airbnb.49 Investors in SilverLake and Venice have also bought homes and apartments for this purpose.50

In the Ellison Suites building in Venice, where the average monthly rent is$1,500, one woman rents fourteen units and lists them on Airbnb for $200

47 Samaan, supra note 22, at 9.48 The rental of spare bedrooms may also distort the housing market by pushing up prices.49 Tim Logan, Emily Alpert Reyes & Ben Poston, Airbnb and Other Short-term Rentals

Worsen Housing Shortage, Critics Say, L.A. TIMES (Mar. 11, 2015), http://www.latimes.com/business/realestate/la-fi-airbnb-housing-market-20150311-story.html [http://perma.cc/48BR-CRFN].

50 Morris, supra note 2.



per night, for a monthly profit of up to $63,000.51 When investors turn entireresidential buildings into unlicensed cottage hotels, their Airbnb listings aredoubly illegal. First, residential neighborhoods prohibit the rental of apart-ments for fewer than thirty days. Second, these investors do not obtain zon-ing licenses or hotel permits, do not purchase hotelier’s insurance, and do notfollow the myriad city regulations that govern hotels.

Landlords have joined the gold rush: one landlord in Venice convertedten of his building’s thirty units into Airbnb listings, though he says that hisrentals are legal because the units are leased for more than thirty days at atime.52 Furthermore, according to local activists, Ellis Act evictions haveincreased the most in the very neighborhoods where Airbnb listings are con-centrated, “in a ‘Nike’ swoosh shape across Los Angeles . . . from Venice,cut through Hollywood and Koreatown, and encompass[ing] parts of SilverLake and Echo Park.”53

C. Airbnb Likely Leads to a Citywide Reduction in Affordable Housing

Housing advocates believe that Los Angeles needs 490,340 more af-fordable homes,54 and Los Angeles mayor Eric Garcetti hopes to construct16,000 new units annually by 2020.55 But in 2014, STRs removed 7,316units from the city’s rental market, a number that seems poised to grow.56 Itis easy to imagine a future in which Airbnb’s growth—and the correspond-ing removal of rental units from the residential market—outpaces the con-struction of affordable housing in Los Angeles.

Although there is currently no data on how many of these removedunits were affordable, full-time Airbnb STRs can affect the affordable hous-ing stock in two ways. First, affordable units are particularly attractivetargets for conversion, directly reducing the stock of affordable housing.57

Through the Ellis Act, investors can relieve landlords from the administra-tive burdens of administering rent-controlled or voucher-subsidized housing,and convert newly-purchased, formerly affordable apartments into Airbnblistings, particularly in newly gentrifying neighborhoods. Thus, Airbnb in-centivizes the direct conversion of subsidized or rent-controlled units intolucrative Airbnb listings. Absent regulation, this incentive will continue toinfluence the marketplace so long as hotel rates sufficiently exceed residen-tial rents.

51 Lepore, supra note 34.52 Id.53 Duran, supra note 14.54 CALIFORNIA HOUSING PARTNERSHIP COALITION REPORT, supra note 8.55 Plan: Transforming Los Angeles, CITY OF LOS ANGELES 52 (2015), https://d3n8a8pro7v

hmx.cloudfront.net/mayorofla/pages/17002/attachments/original/1428470093/pLAn.pdf?1428470093 [https://perma.cc/RW4Q-ZT6D].

56 Samaan, supra note 22, at 3.57 Id. (describing how trade publications advise landlords on how to convert units to

STRs).



Second, Airbnb indirectly reduces the affordable housing supply by re-ducing the overall housing supply. As a result, the pressure that STRs placeon rent prices pushes units out of the margins of affordability for low- andmiddle-income residents, an effect that cascades throughout the city. In2014, Airbnb removed 1% of the units from Los Angeles’s rental market—and substantially more in some neighborhoods—while monthly rents in-creased by 7.3%.58 And by reducing the overall housing supply, Airbnb ispartially responsible for the citywide rent increases that further reduce thesupply of affordable housing.

III. AIRBNB IS CORRELATED WITH GENTRIFICATION AND MAY

EXACERBATE RESIDENTIAL SEGREGATION AND INEQUALITY

Airbnb harms the goals of affordable housing advocates in ways be-

yond its numerical impact on rents or the housing stock. Although these

harms are difficult to measure, they extend beyond the fact that tourists do

not sleep at reasonable hours and do not recycle beer cans properly. Airbnb

STRs impede integration and exacerbate socioeconomic inequality.

A. Airbnb is Correlated with Gentrification in Adjacent Neighborhoods

Gentrification occurs when rising rents displace a neighborhood’s lowerincome households, who are replaced by wealthier residents that change thedistrict’s “essential character.”59 Lower-income residents who are displacedcan face longer commutes and lose access to essential community servicesand institutions.60

Airbnb STRs are concentrated in expensive neighborhoods that havelong-since or have never been gentrified. But when middle-income rentersare displaced from these neighborhoods, they are pushed into cheaper neigh-boring communities, which they subsequently gentrify. For example, formerVenice resident Roman Barrett says he moved to Koreatown—a gentrifying,low-income Asian and Latino enclave—after being priced out of Venice byAirbnb rentals.61

Figure 2 illustrates the relationship between Airbnb-dense communitiesand their poorer, gentrifying neighbors. These neighborhoods tend to havehigh poverty rates, yet their rents have risen more rapidly than in Los Ange-les overall. This effect is particularly dramatic in Chinatown, where rentshave doubled in just two years. More data is needed to determine whether,

58 See ZILLOW, supra note 1. Total number of apartments in LA estimated by dividingcensus population data by household size data from Mapping L.A. Neighborhoods, supra note39.

59 Maureen Kennedy & Paul Leonard, Dealing with Neighborhood Change: a Primer onGentrification and Policy Choices, BROOKINGS INSTIT. CTR. ON URBAN & METRO. POLICY,Apr. 2001, at 5.

60 Id. at 22, 43.61 Logan et al., supra note 49.



say, residents displaced from Silver Lake actually move to Koreatown, butthe prevalence of STRs seems to correlate with rent hikes and gentrificationin adjacent districts.



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B. Airbnb Might Reduce Integration by DisplacingLower-income Tenants

Economic and racial neighborhood integration can lead to a range ofpositive educational, vocational, and health outcomes for low-income te-nants. But Airbnb reduces neighborhood integration by incentivizing hote-lization, encouraging Ellis Act conversions of rent-controlled units, anddriving out lower-income renters.64 Furthermore, some landlords of build-ings protected by the city’s Rent Stabilization Ordinance choose to list va-cant units on Airbnb rather than deal with the eviction and rent protectionsthat a full-time tenant would enjoy.65

Because Airbnb STRs are such a nascent phenomenon, further researchis needed to measure Airbnb’s impact on annual changes in racial and eco-nomic diversity in high-demand neighborhoods. Researchers should alsotrack the displacement of lower income residents from neighborhoods whereAirbnb listings are prevalent.

C. Unequal Access to Airbnb Exacerbates Racial andSocioeconomic Inequality

Airbnb creates winners and losers; it facilitates cultural exchange andprovides economic benefits to hosts and tourists, but distributes these bene-fits unequally. Hosts need an Internet connection and cultural savvy just toaccess the platform. And the fact that just seven of Los Angeles’s most ex-pensive neighborhoods, in which approximately 8% of the city’s residentslive, generate over two thirds of the city’s Airbnb revenue suggests that thereis little tourist demand for STRs in lower- and middle-incomeneighborhoods.66

According to Airbnb, 38% of its hosts are of low-to-moderate income,and more than half are renting out couches and spare bedrooms.67 But thesehosts only make 11% of the city’s Airbnb-supported income.68 Instead, large-scale operators reap the lion’s share of the revenue; 6% of Airbnb hosts listmultiple units, earning 35% of all Airbnb revenue.69 One such company,Global Homes and Condo, lists seventy-eight units on Airbnb through a pairof friendly, but fake, “front” women.70 These figures suggest that whereasindividual “hosts” set their rates based on the value of their apartments,commercial Airbnb operators set their prices against prevailing hotel prices,leading to profits for operators and Airbnb alike.

64 See, e.g., Duran, supra note 14.65 Samaan, supra note 22, at 12.66 The population-share of Downtown, Echo Park, Hollywood, Hollywood Hills, Miracle

Mile, Silver Lake, and Venice calculated from Mapping L.A. Neighborhoods, supra note 39.67 Id.68 Samaan, supra note 22, at 13.69 Kudler, supra note 32.70 Id.



In addition, although most Airbnb STRs blatantly violate city lawsprohibiting sub-thirty-day apartment rentals, landlords seem to enforce theselaws more diligently against renters—particularly those with rent-controlledor subsidized housing—than against apartment or condo owners.71 It wouldprobably be unfair for publicly subsidized tenants to profit from listing STRson Airbnb. But the benefits of Airbnb overwhelmingly accrue to relativelywealthy renters and property owners, not to average Angelenos.

Finally, Airbnb is based on an amorphous “trust” and “sense of com-munity” endemic to the sharing economy, a trust that extends only to somesocial groups. A recent study found that African American hosts earn 12%less than white hosts for equivalent rental listings.72 And minority guests aresystematically denied lodging by Airbnb hosts.73 If Airbnb hosts are offeringa public accommodation, minority Airbnb guests may even have a primafacie case against Airbnb hosts for discrimination in violation of the FairHousing Act of 1968, which prohibits refusal to rent to a person on the basisof a protected class, such as racial minorities.74 Airbnb facilitates systemicdiscrimination and reduces racial integration.

IV. REGULATING AIRBNB TO PROMOTE EQUITABLE HOUSING

A. Criteria for Evaluating Proposals: Solutions MustAddress All Problems

Because Airbnb STRs are a new and rapidly growing phenomenon, lo-cal and state lawmakers and regulators are just beginning to deal with thisproblem.75 The author’s view is that Los Angeles should prioritize the hous-ing needs of residents over the needs of tourists when the two aims conflict.However, there are ways to harness the benefits of Airbnb, while regulatingit so that it promotes affordable housing, integration, and equity in Los An-geles. But, any policy reforms must directly address the distortive effectsthat conversion and hotelization have on affordable housing.

Ideally, STR regulations should address as many of Airbnb’s negativeeffects on affordable and fair housing as possible. Ideally, they would alsoaddress the underlying causes of Los Angeles’s housing crisis, including the

71 See, e.g., Samaan, supra note 22, at 18.72 Benjamin Edelman & Michael Luca, Digital Discrimination: The Case of Airbnb.com 2

(Harvard Bus. Sch., Working Paper No. 14-054, 2014), http://www.hbs.edu/faculty/Publica-tion%20Files/14-054_e3c04a43-c0cf-4ed8-91bf-cb0ea4ba59c6.pdf [http://perma.cc/S6EZ-ABQX]. See also Michael Todisco, Note, Share and Share Alike? Considering Racial Dis-crimination in the Nascent Room-sharing Economy, 67 STANFORD L. REV. ONLINE 121, 122(Mar. 14, 2015) (discussing the study as proof of pervasive racial bias among Airbnb users).

73 Todisco, supra note 72, at 123.74 Id. at 126. However, only hosts, and not Airbnb itself, could be held liable.75 Ben Bergman & Alice Walton, Los Angeles Officials Crack Down on “Sharing Econ-

omy” Rides, Rental Companies, SOUTHERN CALIFORNIA PUBLIC RADIO (Dec. 9, 2014), http://www.scpr.org/news/2014/12/09/48569/los-angeles-officials-crack-down-on-sharing-econom/[http://perma.cc/HA8N-TJTH].



lack of funding for developing affordable housing. Before signing on to adeal, policymakers and community stakeholders should ask whether aproposal:

1. Addresses and combats neighborhood and city-wide rentincreases;

2. Reduces or adds to the city’s market-rate and affordable hous-ing stock;

3. Discourages the “conversion” of existing affordable units intoSTR listings;

4. Eliminates incentives that encourage “hotelization” of rentalunits;

5. Protects residents from displacement and eviction;6. Addresses cultural and economic gentrification;7. Exacerbates socioeconomic disparities or increases access to

Airbnb’s benefits;8. Promotes socioeconomic integration.

B. Evaluating Mayor Garcetti’s Plan to Tax STRs in Orderto Fund Affordable Housing

On April 16, 2015, Mayor Garcetti announced a deal he had proposedto Airbnb. Under his proposal, Los Angeles would levy a 14% occupancytax on all Airbnb facilitated rentals.76 This is expected to generate at least $5million annually, although this static projection does not take into accountexpected increases or tax-induced decreases in Airbnb activity.77 These fundswould be allocated each year to Los Angeles’s Affordable Housing TrustFund, which has been reduced from $100 million in 2008 to just $19 millionin 2015.78

Without taking matching funds into account, $5 million could fund thedevelopment of sixteen affordable units at an average cost of $315,000 perunit.79 However, Airbnb rentals remove 7,316 units—which does not includeunits that are listed only intermittently on Airbnb—year-round from Los An-geles’s rental market. Even if Airbnb stops expanding, it would take 457years for occupancy taxes to fund the full replacement of the units thatAirbnb removes from the city’s rental market. To use another rough calcula-tion, a single studio apartment in Silver Lake that is booked on Airbnb for anaverage of $132 per night at a remarkable 60% rate—219 days a year—


77 Garcetti’s Airbnb Tax Plan Does Little to Increase Affordable Housing, S. CAL. PUB.RADIO (Apr. 16, 2015), http://www.scpr.org/programs/take-two/2015/04/16/42416/garcetti-s-airbnb-tax-plan-does-little-to-increase/ [http://perma.cc/Y8CW-435Z].

78 Bergman, supra note 17.79 Average cost per Los Angeles County publicly built affordable housing unit from Cali-

fornia Department of Community Development, see Affordable Hosuing Cost Study, supranote 44, at 31.



yields $28,908 for its host, generating $4,047 in occupancy tax revenue forLos Angeles each year.80 Such a unit would take seventy-eight years to fundthe construction of its own replacement.

This may not be an apples-to-apples comparison because Airbnb shouldnot shoulder the entire burden of replacing a converted unit of affordablehousing when, presumably, an affordable housing developer would recoupits costs through tenants’ rent payments. Take, then, the hypothetical SilverLake apartment in the paragraph above and assume that it was an affordableunit of housing for a median-income city resident. Perhaps it would be rea-sonable at least to expect STR taxes to cover the costs of construction duringthe period that Airbnb leaves Silver Lake with one fewer unit of housing.

Assume that a developer spends four years building (three years of per-mitting, one year of construction) a unit of affordable housing in SilverLake, and that the unit will be habitable for fifty years. At a cost of$315,000, the unit will cost the developer $6,300 per year in constructioncosts alone over the 50-year period. If Airbnb was responsible for coveringthe costs of four years of construction, it would still have to generate$25,200 in taxes over four years, requiring a daily tax rate of 21.8%. Theback-of-the-envelope calculations in this hypothetical demonstrate the com-plications involved in trying to fund the replacement of converted orhotelized units of housing through an occupancy tax on STRs. An occupancytax of 14% might be insufficient to meet Mayor Garcetti’s stated policygoals.

Furthermore, Garcetti’s plan would not address gentrification or rentincreases in neighborhoods where Airbnb listings are prevalent. And de-pending on where new units are built, it is unclear whether the neighbor-hoods most affected by Airbnb would benefit from new housingconstruction. After all, the city may build in lower-income neighborhoodsthat offer taxpayers a better “bang for your buck” than Venice or SilverLake. This could concentrate poverty, and decrease economic integration inaffluent neighborhoods, unless the funds were used to fund mixed-use oraffordable developments in higher income neighborhoods at higher cost tothe Trust Fund.

Garcetti’s plan may spread demand and help lower income and minorityhosts. But this could backfire by contributing to gentrification in thoseneighborhoods, especially if taxes push STR demand into the already gentri-fying districts adjacent to the neighborhoods that are popular on Airbnb. Onefinal concern is that such a deal would formally excuse Airbnb from a widerange of liability, from safety-related issues to STR regulation. Legalizationmay also spur STR growth. And Garcetti should specify how his plan wouldaddress evictions, illegal conversions, and discrimination by Airbnb hostsand renters during the time period when replacement housing is beingconstructed.

80 See Airbnb, https://www.airbnb.com/s/Los-Angeles?neighborhoods%5B%5D=Silver+Lake (last visited Dec. 2, 2015). Occupancy rate figure from Martin, supra note 23.



C. Evaluating Alternative Tax and Redistribution Schemes

Mayor Garcetti’s plan directly addresses Los Angeles’s affordable hous-ing shortage, but might not replace the units that Airbnb removes from therental market. Allocating STR taxes to construct affordable housing alsodoes not address segregation and gentrification. There may be more effectiveways to tax and redistribute the revenue that STRs generate.

The city can be ambitious about tax rates and tax Airbnb at a rate higherthan the 14% occupancy fee levied on licensed hotels. As a matter of policy,it is desirable that the brunt of any taxes levied on Airbnb would be borne bytwo relatively wealthy populations: tourists and property owners. Further-more, whereas hotel guests are ostensibly paying for city services with theirtaxes, Airbnb guests could also be paying to replenish the housing stock. IfAirbnb tourists are looking to avoid paying a premium to stay in hotels, LosAngeles could tax hosts to any extent such that the price of an Airbnb is lessthan the price of an equivalent hotel room without de facto banning STRs.Although there are political limits to tax levels, officials need not set a 14%pre-negotiation upper tax limit on Airbnb listings.

Los Angeles could promote economic diversity and integration by di-recting tax revenue towards a municipal housing voucher program, whichwould increase economic integration. And if these vouchers were given tolow-income residents of Airbnb-dense buildings or neighborhoods, it wouldallow them to stay in their homes. However, like Mayor Garcetti’s plan, suchtaxation and redistribution schemes may not be able to replace all of theunits that Airbnb removes from the residential market. Other measures arenecessary to complement these tax schemes and promote integrated, afforda-ble neighborhoods throughout Los Angeles.

D. Evaluating a Ban or Targeted Restrictions on Airbnb STRs

STRs increase rents for residents and reduce the supply of affordablehousing by removing units from the housing market through conversion andhotelization. Given Los Angeles’s low vacancy rate, it is likely thatthousands of residents have been displaced due to the 7,316 year-round list-ings on Airbnb. On the other hand, Airbnb’s economists claim that in 2014,Airbnb helped add $314 million in economic activity and 2,600 jobs to LosAngeles’s economy.81 Although this does not take into account losses to rent-ers and other community stakeholders, it is plausible that Airbnb simultane-ously produces economic benefits while exacerbating the city’s affordabilitycrisis. This article approaches the issue of Airbnb from the lens of weighingits effect on Los Angeles’s affordable housing crisis, and is not an attempt toquantitatively measure the net economic gains or losses produced by Airbnb.Policymakers seeking to regulate Airbnb must make both economic and

81 Owens, supra note 24.



value-driven decisions in order to weigh the importance of promoting af-fordable housing.

A blanket ban on STRs would end Airbnb’s role in exacerbating LosAngeles’s affordability crisis. For residents displaced by Airbnb, a blanketban would likely be preferable to any solution that insufficiently addressesthe corrosive effects of STRs. Enforcing anti-STR laws could also halt theevictions, displacement, and gentrification that follow when Airbnb saturatesa neighborhood. That said, a ban would not add to Los Angeles’s affordablehousing stock itself, and would deprive the city of Airbnb’s benefits. Fur-thermore, bans that deprive property owners of Airbnb’s benefits implicateConstitutional protections for property owners under the three-pronged PennCentral takings test, which assesses: (1) the economic impact of a regulationon affected parties, (2) the extent to which a regulation frustrates investorexpectations, and (3) the extent to which a regulation is tailored to promotegeneral welfare or is arbitrary.82

Property law scholar Jamila Jefferson-Jones suggests that New York’santi-STR regulations may violate legitimate investor-backed expectations,and are not “roughly proportional,” meaning that the severity of existinglaws banning STRs are not commensurate to the value of the regulations:protecting public safety, hotels, and neighborhood property values.83 How-ever, Professor Jefferson-Jones’s analysis underestimates the public’s legiti-mate interest in protecting affordable housing.84 These argumentsdemonstrate how outright bans may become increasingly untenable givenAirbnb’s prevalence. At the moment, however, most of the STRs listed onAirbnb in Los Angeles’s residential and mixed-use (business and residential)zones are illegal.

Alternatively, city officials could legalize STRs but place targeted re-strictions on them rather than enforce the existing blanket ban. Such an ap-proach could reasonably prevent Airbnb from distorting the housing marketwhile allowing tourists and residents to benefit from it. However, such astrategy would have to address conversion and hotelization, or otherwiseameliorate Airbnb-induced reductions in affordable housing supply.

For example, enforcement agencies could choose to target unlicensedhotels and prevent hotelization. Perhaps purchasers of property could bebanned from using Airbnb for a one-year “cool-down” period. This wouldput a check on price hikes and discourage hotelization. Such a ban wouldprotect the existing affordable housing stock. However, such a requirementmay invite scrutiny under the investor expectations prong of the Penn Cen-tral test where investors, prior to enactment of the rule, bought a building forthe purpose of hotelization. But the city can assert that the restriction is

82 See Penn Cent. Transp. Co. v. City of New York, 438 U.S. 104, 152–53 (1978).83 Jefferson-Jones, Airbnb and the Housing Segment of the Modern “Sharing Economy”:

Are Short-Term Rental Restrictions an Unconstitutional Taking?, 42 HASTINGS CONST. L.Q.557, 566–68 (Spring 2015).

84 Pennell v. San Jose, 485 U.S. 1, 13 (1988) (affirming public’s right to preserve af-fordability through measures such as rent control).



necessary to prevent public nuisances and protect the affordable housingstock. And because it would not constitute rent control, a cool-down require-ment would not trigger the intervention of the Ellis Act if a purchased prop-erty was previously rent-controlled.

Similarly, policymakers could discourage “conversion” by prohibitinglandlords who have evicted a tenant without fault—meaning that the tenantis not evicted for violating his or her lease—from listing the unit in questionon Airbnb for a one-year cool-down period. This cool-down period can beimposed on all landlords, or just landlords of subsidized units. Either ap-proach would discourage wanton conversion of rental stock into touristaccommodations.

Another approach would be to assign STR permits and restrict the num-ber of permits per square mile or neighborhood. However, geographicallytargeted restrictions on STRs would be difficult to enforce, and it would bedifficult to administer a permit system that is equitable to all prospectivehosts. Furthermore, this might encourage the spread of STRs into newly gen-trifying neighborhoods. For example, such a policy could restrict the cullingof Echo Park’s affordable housing supply while exacerbating the af-fordability crisis in neighboring Chinatown.

Another solution would be to mandate that Airbnb STRs be allowedonly in buildings that meet a target affordability threshold. For example, thecity could promote inclusionary housing by only allowing STRs in neighbor-hoods or buildings where 30% of the units are affordable, which would in-centivize property owners to subsidize apartments that are currently priced atthe market rate in order to “free up” units for Airbnb listings. This woulddirectly address STRs’ effects on neighborhood socioeconomic integration.But such solutions would be cumbersome to calculate and difficult to en-force. Furthermore, such a benchmark may be considered exactions that arenot roughly proportional to the actual affordability and public safetyproblems that STRs create.85 Finally, such an approach would increase thestock of affordable housing, but simultaneously reduce Los Angeles’s overallstock of residential housing.

Lastly, city officials could prevent hotelization by legalizing STRs, butlimiting the number of days per year that a host can list a unit without goingthrough the hotel permitting process. This would disincentivize the conver-sion and removal of units from the housing market, protect the housingstock, and tamp down speculation and rent inflation. Such an approachwould be subject to an investor-backed expectations takings challenge, butthe city could argue that the limitation is necessary to protect the residentialhousing stock.

Should Los Angeles decide to adopt some sort of enforcement strategytowards Airbnb, policymakers should empower regulators to enforce zoningand hotel licensing laws. Regulations on Airbnb STRs are municipal in na-ture, concerning issues such as zoning and hotel licensing. California coun-

85 Jamila Jefferson-Jones, supra note 83, at 568.



ties have not coordinated to regulate STRs on a county or statewide basis.Although Los Angeles has not committed resources to enforcing STR laws,the City Attorney’s office has asked hosts to pay occupancy taxes.86 But it isunclear whether these warnings were symbolic or whether the City Attorneyhas the resources to enforce these laws.87

Policymakers should empower regulators to enforce zoning and hotellicensing laws. Although resources are limited, this should be a prioritygiven the havoc that STRs wreak on the residential housing market. Andrather than targeting single-unit hosts, regulators can target the cottage in-dustry of “Airbnb leasing companies” that are rapidly removing units fromthe rental housing market, thereby discouraging hotelization.88

Perhaps taxes can fund enforcement officers or a regulatory bodywithin the city planning department. In the absence of a new regulatoryagency, Airbnb should at least make it possible for the city to track STRsand crack down on the most egregious activities. Perhaps hosts who postlistings more than once a month—which indicates that a host has converteda unit—should have to register with the city. Los Angeles should also crackdown on large-scale operators who manage “virtual hotels” with multiplerooms across the city. And investors should be prevented from convertingentire buildings into cottage hotels. Airbnb’s cooperation is critical to anyeffective enforcement scheme that prevents conversion and hotelization. Per-haps city officials can negotiate with Airbnb and exchange greater coopera-tion with targeted enforcement efforts for a general legalization of non-commercial-scale STRs.

E. Promote Affordable and Fair Housing ThroughCommunity Benefits Agreements

In addition to regulating and taxing Airbnb, Los Angeles should adoptthe community benefits agreement (CBA) model that local industries havenegotiated with unions and affordable housing advocates.89 Under a typicalCBA, developers of large projects are given tax credits and the permission tobuild lucrative developments such as luxury apartments, malls, or sports sta-diums in exchange for a commitment to hire local residents, set aside afford-able housing, or donate to public projects.90 So too here, policymakers,advocates, unions, and developers would come together and bring Airbnb inas a partner, helping Los Angeles’s low-income and minority communitiesshare in Airbnb’s benefits.91,92

86 Bergman & Walton, supra note 75.87 Id.88 See, e.g., Kudler, supra note 32.89 See, e.g., Harold Meyerson, L.A. Story, AMERICAN PROSPECT (Aug. 6, 2013), http://

prospect.org/article/la-story-0 [http://perma.cc/2J9H-NLB4].90 Id.91 Id.92 If Airbnb signs a CBA with community stakeholders, rather than the city, a CBA would

likely not violate the Penn Central exactions test.



First, Airbnb should ban racially discriminatory hosts and users andmake the approval process race-blind. Airbnb could also use its platform,market penetration, and technology to connect hosts with cleaning servicesthat pay living wages. Additionally, Airbnb could apply its proprietary tech-nology to help low-income renters find low-cost or public housing.

Airbnb and developers could also be given incentives to concurrentlyexpand the supply of housing and the supply of tourist accommodations,removing tourists from the residential housing market. Developers could begiven permits to construct sanctioned “Airbnb hotel” apartments in neigh-borhoods with a high density of Airbnb listings. Qualifying newly con-structed buildings could be exempt from the bans, taxes, or restrictions onSTRs that would govern existing residential housing. These permits could becontingent upon Airbnb or the developer signing a CBA that ensures work-ers are fairly paid, and require that at least 15% of a hotel’s units be rent-controlled or subsidized for low-income residents.93 The remaining unitscould be rented at market-price, or listed on Airbnb. An even better ratio of“hotel” units to affordable residential units would be one that directs hoteldevelopers to reserve as many affordable units as possible while earningmarket-rate returns. In any combination, an “Airbnb hotel” would directlyexpand the affordable housing stock, expand the aggregate housing stock,increase Los Angeles’s supply of hotel rooms, and promote integration.

V. CONCLUSION:REFORMING STRS TO ADDRESS THE HOUSING CRISIS

As gentrification transforms Los Angeles’s urban core, policymakers

must adapt to better regulate new technologies such as Airbnb. The best

regulation comes from precise data, so additional research is needed on how

STRs affect evictions and rents. To an extent, Airbnb is a response to, not a

cause of, gentrification and Los Angeles’s affordable housing crisis. But

policymakers must understand that Airbnb profits from illegal rentals that

cause rent increases, reduces the housing supply, and exacerbates segrega-

tion. Even an outright ban on STRs would be better for low-income residents

than the unregulated status quo. Airbnb must become a responsible partner

and facilitate, not hinder, the goals of affordable housing advocates.

In preparing to negotiate with Airbnb, Los Angeles can learn from the

approaches that other cities have taken to regulate Airbnb. San Francisco,

Chicago, and Washington, D.C. negotiated with Airbnb lobbyists to legalize

STRs and apply hotel occupancy taxes to STRs.94 Aside from New York,

93 This is the same percentage that is required for other developments that seek densitybonuses from the city. LA Affordable Housing Incentives Guidelines 2014, http://cityplanning.lacity.org/Code_Studies/Housing/DRAFTUPDATEDAffordHousingGuide.pdf [http://perma.cc/ZKJ4-7JUH].




policymakers have avoided suggesting outright bans, perhaps because

Airbnb has mobilized grassroots support and formed sophisticated lobbying

and advocacy organizations.95 Airbnb spent $100,000 in 2014 alone to lobby

Los Angeles officials.96

After proposing and evaluating various reforms, my recommendation is

that Los Angeles adopt a three-pronged strategy. First, the city should pre-

vent the hotelization and conversion of existing residential buildings and

units of housing. Airbnb provides a tremendous benefit to tourists and re-

sidents alike when it allows tourists to travel off the tourist-beaten path.

Such adventures are a win-win for hosts who are merely using Airbnb for a

month per year to subsidize their own travels, or who are using Airbnb to

earn enough money to keep their home after losing a job.

But given the inelasticity of the housing supply, it is inappropriate for

investors to permanently remove units from the residential housing stock in

order to cater to tourists. Fundamentally, I would argue that the raison d’etreof Los Angeles’s housing stock is to serve its residents. Thus, Los Angeles

should ban year-round listings of apartments on Airbnb and similar websites,

perhaps by emulating San Francisco’s proposed “Ballot Measure F” and set-

ting a seventy-five-day limit on the number of days that a unit can be

listed.97 Bona fide homeowners or leaseholders who occasionally host guests

through Airbnb can be exempted from any taxes that would otherwise be

levied on STR transactions.

Furthermore, Los Angeles should institute a one-year cool-down period

before any formerly subsidized or rent-controlled home can be listed on

Airbnb. To prevent hotelization and professional Airbnb management, Los

Angeles should set a hard cap on the number of units that any individual or

business can list on Airbnb in a given year. Finally, Los Angeles should set a

hard cap on the number of units in a building that property owners and man-

agers can list on Airbnb.

In order to incentivize developers and Airbnb itself to build additional

affordable and market-rent housing, Los Angeles should apply these restric-

tions to existing residential buildings and units, but allow newly-developed

building managers and owners to set aside a greater number of units for

STRs. The city can also grant additional exemptions for developers who set

aside newly-constructed units for low-income residents, thereby directly in-

creasing the affordable housing stock and promoting economic integration.

Along this line, the city can bring developers, unions, advocates, and

Airbnb—the parent company—together to sign Community Benefits Agree-

ments. The parties can agree to build “Airbnb hotels” in tourist destinations

95 Logan et al., supra note 49.96 See, e.g., Short Term Rental Advocacy Center, http://www.stradvocacy.org/ [http://per

ma.cc/A996-EWRB].97 S.F., Cal., Admin. Code § 41.A.4, 41.A.5 (2015), http://sfgov2.org/ftp/uploadedfiles/

elections/candidates/Nov2015/ShortTermRentals_Text.pdf [http://perma.cc/LTS4-4RP6].



that set units aside for low-income residents, provide good jobs, and ban

discrimination.

Finally, Los Angeles should implement a 14% occupancy tax on any

unit that is listed on Airbnb for greater than the seventy-five-day cap men-

tioned above. This would prevent Airbnb hosts from gaining an unfair com-

petitive advantage over hotels. The city can allocate this revenue towards

code enforcement, and for funding mixed-income housing in Airbnb-dense

neighborhoods, thereby promoting integration and preventing displacement.

Airbnb is organizing constituents and mobilizing political support.98

This is why political stakeholders must regulate Airbnb STRs now, before

the industry calcifies into Los Angeles’s political and economic structure. At

the moment, local politics are favorable to increased regulations. Unions and

neighborhood associations have united with their political adversaries—ho-

tels and developers—to speak out against Airbnb.99 By framing the public

narrative around the displacement that STRs cause, regulators can also win

the support of influential faith leaders, as well as of the public. If the city

brings Airbnb together with community stakeholders, the city can eliminate

Airbnb’s corrosive effects on fair and affordable housing, and help all com-

munities benefit from safe, integrated, and affordable neighborhoods.

98 Logan et al., supra note 49.99 See, e.g., Keep Neighborhoods First, http://www.keepneighborhoodsfirst.com/ [http://

perma.cc/6YHE-A7HJ] (coalition of labor and neighborhood councils).

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Do Airbnbs push up rentsand house prices?Last Updated: Feb. 2, 2021 at 7:03 p.m. ET

First Published: Feb. 2, 2021 at 11:40 a.m. ET

‘Countless families depend on Airbnb to pay their rent and stay in their homes, which has become

even more important amidst the current crisis,’ according to Airbnb

By Jacob Passy

As Airbnb has become more popular across the country, rents and home prices have risen in tandem.

https://www.marketwatch.com/author/jacob-passy?mod=MW_author_byline

GETTY IMAGES

ABNB -2.39% !

For renters and home buyers alike, Airbnb ABNB, -2.39% is contributing to the affordability crunch

seen in many housing markets across the country.

Short-term rentals via apps such as Airbnb contribute to housing shortages and rent increases,

according to research published last week by Felix Mindl and Dr. Oliver Arentz, researchers at

University of Cologne in Germany. They attributed 14.2% of overall rent increases to short-term

rentals or 320 euros ($385) per year for new tenants.

“While a large proportion of hosts can be considered home sharers, we find an increasing proportion

of providers who have developed a professional business model from short-term rentals,” Mindl said

in a statement. “Professional short-term rentals are available to tourists throughout the year, and

thus compete directly with long-term tenants, for whom the rooms are then no longer available.”

However, a spokesman for Airbnb took issue with such findings, and said the COVID-19 pandemic

has created an untenable position for many households struggling to make ends meet, and renting

out a room is one way to deal with that. “Countless families depend on Airbnb to pay their rent and

stay in their homes, which has become even more important amidst the current crisis,” he said.

Still, the Economic Policy Institute, a progressive think tank, echoed the sentiments of the Cologne

researchers last year . “Evidence suggests that the presence of Airbnb raises local housing costs. The

largest and best-documented potential cost of Airbnb expansion is the reduced supply of housing as

properties shift from serving local residents to serving Airbnb travelers, which hurts local residents

by raising housing costs,” it said.

Sophie Calder-Wang, assistant professor of the real-estate department at The Wharton School in

the University of Pennsylvania, published a study last August that found the “increased rent burden

falls most heavily on high-income, educated, and white renters because they prefer housing and

location amenities that are most desirable to tourists.”

Other studies, have attempted to put a more specific figure on rent and house-price increases that

some analysts say are related to short-term rental sites.

A 2017 study published in the latest edition of the journal Marketing Science found that the number

of Airbnb listings in a zip code was associated with increases in property prices and rental rates. “The

BULLETIN Barron's on MarketWatch: Where are mortgage rates headed next? ! "

https://www.marketwatch.com/investing/stock/ABNB?mod=refsymb_mw

https://www.marketwatch.com/investing/stock/ABNB?mod=MW_story_quote

https://www.epi.org/publication/the-economic-costs-and-benefits-of-airbnb-no-reason-for-local-policymakers-to-let-airbnb-bypass-tax-or-regulatory-obligations/

https://scholar.harvard.edu/files/sophie-qingzhen-wang/files/calder-wang_sophie_harvard_airbnb_housing.pdf

https://www.marketwatch.com/articles/mortgage-rates-are-back-above-3-heres-where-theyre-headed-next-51614874559??mod=bnbh_mwarticle

increased ability to home-share has led to increases in both rental rates and house prices,” the

researchers wrote in the study.

Researchers used data on all U.S. properties listed on Airbnb between 2012 and 2016, and analyzed

the effects of these listings using data on rents and home values from Zillow. Based on the median

growth in Airbnb listings nationally, the short-term rentals contributed to an annual increase of $9 in

monthly rent and $1,800 in home prices for median zip code, the study’s authors found.

All told, Airbnb accounted for one-fifth of the actual rent growth and one-seventh of the actual

home-price appreciated experienced nationwide. But housing markets with fewer renters and more

homeowners saw a smaller Airbnb-related effect. The popularity of a destination was from a tourist’s

perspective also appears to have played a role.

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The researchers did acknowledge that more research is needed, “to achieve a complete welfare

analysis of home-sharing. For example, home-sharing may have positive spillover effects on local

businesses if it drives a net increase in tourism demand.”

The growing popularity of short-term rentals through platforms like Airbnb does show that the

higher rates landlords can fetch on the vacation rental market has led some to convert their

properties from long-term to short-term rentals, and that has shrunk the rental market, pushing

prices higher, they added.

A spokesman for Airbnb said the financial aid that hosts receive should not be discounted from such

studies. “The authors of this study, which is now outdated, agree that home sharing can provide

important economic benefits for families and support smart rules that allow home sharing to

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continue,” he said.

The researchers from that Journal of Marketing study said that local lawmakers might be able to

counteract the effects of Airbnb through targeted regulations.

“Regulations on home-sharing should (at most) seek to limit the reallocation of housing stock from

long-term rentals to short-term rentals without discouraging the use of home-sharing by owner-

occupiers,” they wrote.

One regulatory approach they suggested: Levy an occupancy tax solely on property owners who rent

out an entire property for an extended period of time and requiring proof that property owners live

in the homes they own to avoid the tax.

‘It feels predatory’: 6 millionpeople are not eligible for aCOVID-19 pause on student-debt payments — even ifthey work in public serviceOne student-loan borrower is slated to pay off

her debt when she’s 87, despite a career in public

service.

Jacob PassyJacob Passy is a personal-finance reporter for MarketWatch and is based in New York.

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Experts: Short-Term Home Rentals Have Little to No Impact onHousing A!ordabilityBy Cory Hopkins (https://www.zillow.com/research/about-us/cory-hopkins/) on Dec. 6, 2016

Just 5.1 percent of housing experts with an opinion said the ability to rent entire homes for short periods would have a

meaningful, large impact on the supply and a!ordability of more traditional, longer-term rentals.

On average, panelists said they expected home values to end 2016 up 4.75 percent year-over-year, a bump in

expectationsfrom 4.5 percent annual growth for this year the last time the survey was conducted.

Median U.S. home values peaked at $196,600 in April 2007. On average, panelists said they expected the median U.S.

home value to surpass this peak by November 2017.

The growing presence of short-term room and home rental services like Airbnb and HomeAway are not impacting the overall

supply or a!ordability of rental housing in a meaningful and large way, according to experts, though some smaller e!ects may

be felt in certain markets or segments.

woman putting a sight "Room for rent on a wall"

Most Popular

Home Value GrowthBreaks Records asRents Stabilize(November 2020Market Report &Weekly Data ThroughDec. 12)(https://www.zillow.com/research/zillow-weekly-market-report-27151/)

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(https://wp.zillowstatic.com/3/Fig-1-short-

term-rentals-766a50.png)Just 5.1 percent of

housing experts with an opinion said the

ability to rent entire homes for short periods

would have a meaningful, large impact on the

supply and a!ordability of more traditional,

longer-term rentals, according to the Q4

Zillow Home Price Expectations Survey

(ZHPE). [1] An even smaller share, just 3.9

percent, said the ability to rent smaller rooms

within a larger home would have a

meaningful and large impact on the overall

rental market ("gure 1).

Cities nationwide are debating the role short-

term home and room rentals play in housing

a!ordability (http://www.zillow.com/research/q3-2016-housing-a!ordability-13815/). One view suggests short-term rentals

subtract from the supply of standard, long-term rental homes and contribute to rising rents. Others argue short-term rental

units give homeowners an additional source of income, allowing them to more easily pay their monthly mortgage payment,

contribute to savings or a!ord other necessities.

But while a sizable majority of experts surveyed said they did not think short-term rentals were likely to have a large impact on

a given market, half of those with an opinion indicated the ability to rent an entire home for a short period is having smaller

impacts on the market. And 32.9 percent said the ability to rent a single room for a short period is impacting the market in a

small way.

When asked to o!er commentary and context on their opinions, several experts gave di!ering reasons for the more limited

e!ect they expected short-term rentals to have. One noted that the hotel industry was likely to be more impacted than the

larger market overall. A di!erent expert noted that the short-term and long-term rental markets were di!erent and not

e!ective substitutes. Another said the impact may be felt more acutely in very tight, supply-constrained markets like those in

California and other booming coastal states, but that those e!ects likely wouldn’t spill over into the larger market. The same

panelist also said growth in the short-term rental market was likely cyclical, closely tied to the discretionary income Americans

have available for travel.

Whether or not short-term rentals play a large role, cities across the country are grappling with housing a!ordability issues,

especially in places with rapidly rising rents and home values. In some hot West Coast markets, it’s not uncommon for renters

to spend 40 percent or more of their income on a monthly rental payment, when historically that number was much lower.

Inventory shortages play a large role in this a!ordability crisis; there simply aren’t enough rentals on the market to keep prices

low.

But clearly, experts aren’t convinced that short-term rentals are causing the problem.

Home Value Growth: The Peak is in Sight

On average, panelists said they expected home values to end 2016 up 4.75 percent year-over-year, up from 4.5 percent annual

growth for this year the last time the survey was conducted (http://www.zillow.com/research/job-growth-middle-america-

12977/) and in line with recent acceleration in home values as measured by the Zillow Home Value Index

(http://www.zillow.com/research/october-2016-market-report-13872/). Looking farther ahead, panelists on average said they

expected the annual pace of home value appreciation to slow to 3.6 percent in 2017, 2.97 percent in 2018, to 2.7 percent in

2019 and to 2.6 percent in 2020, before accelerating slightly to a 2.84 percent annual pace in 2021. Cumulatively, experts said

they expected home values to grow a total of 21.36 percent, on average, through 2021.

Panelists’ views were divided when separated into more optimistic and more pessimistic camps, especially when looking over

the longer term. The most optimistic quartile of panelists said they expected U.S. home values to rise 5.2 percent through the

end of this year. The most pessimistic 25 percent of panelists said they expected home values to rise 4.3 percent year-over-year

through 2016. Looking farther out, the most optimistic panelists said they expected home values to grow by a total of 30.8

percent from now through the end of 2021. Pessimists predicted total, cumulative home value growth of just 10.2 percent over

the same time ("gure 2).

https://wp.zillowstatic.com/3/Fig-1-short-term-rentals-766a50.png

http://www.zillow.com/research/q3-2016-housing-affordability-13815/

http://www.zillow.com/research/job-growth-middle-america-12977/

http://www.zillow.com/research/october-2016-market-report-13872/

Related

Share:

Median U.S. home values peaked at $196,600 in April 2007. On average, panelists said they expected the median U.S. home

value to surpass this peak by November 2017 – more than a decade after pre-recession peaks. The most optimistic panelists

said they expected home values to surpass pre-recession peaks by July of next year, on average, while the most pessimistic said

they didn’t expect a full recovery in home values until January of 2020.

(https://wp.zillowstatic.com/3/Fig-2-ZHPE-Chart-90a3a0.png)

[1] ZHPE, sponsored by Zillow and administered by Pulsenomics LLC, is a quarterly survey of more than 100 real estate

professionals, academics and economists nationwide that asks experts to o!er their opinion on relevant housing issues and

predict the path of home values over the next several years. This edition of the Zillow® Home Price Expectations Survey

surveyed 111 experts between October 28 and November 15, 2016.

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Housing expenditures and income inequalityChristian Dustmann, Bernd Fitzenberger, MarkusZimmermann

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On the causes and consequences of land useregulationsFrédéric Robert-Nicoud, Christian Hilber

Short-term rentals and the housing market: Quasi-experimental evidence from Airbnb in Los AngelesHans Koster, Jos van Ommeren, Nicolas Volhausen 20 December 2018

Short-term rental platforms such as Airbnb have grown spectacularly in recent years, and local governmentsaround the globe have responded differently in regulating such rentals. This column analyses the effects of apolicy change in several cities of Los Angeles County that restricted short-term rentals of entire homes andapartments. Airbnb has led to an increase in house prices that is particularly pronounced in popular tourist areas,and homeowners in these areas lose out from the regulation. Renters, on the other hand, benefit from theregulation.

Short-term rental platforms such as Airbnb havegrown spectacularly in recent years. Since its launchin 2007, Airbnb has grown into a multibillion-dollarbusiness, now offering more than 4.5 million listings inover 190 countries worldwide. Airbnb allowsindividuals to list their spare room or entire apartmentfor a self-established price to potential guests from allover the world. Particularly in heated housing markets,the new business model developed into an attractiveopportunity for generating alternative income streams.However, the surge in popularity of these platformshas also led to substantial opposition because ofdecreasing housing affordability (Samaan 2015,Sheppard and Udell 2016), illegal ‘hotelisation’ andunfair competition (CBRE 2017), and other negative effects such as noise disturbance orovercrowding within and around buildings (Newling 2016).

Local governments around the globe have responded differently towards regulating short-termrentals. Most cities have not significantly regulated these platforms, but a limited number have putsevere restrictions in place. Berlin, for instance, requires short-term-rental hosts to occupy theproperty for at least 50% of the time (O’Sullivan 2016). San Francisco imposes a cap of a maximum90 rental days per year and a 14% hotel tax (i.e. Transient Occupancy Tax) (Fishman 2015), whileAmsterdam will impose a 30-rental-days cap from 2019 onwards.

The effect of such regulations appears straightforward: basic economic theory tells us that in theabsence of negative externalities, such regulation induces a reduction in housing prices (and rents)by restricting the most efficient use of housing. This reduction will be particularly pronounced inlocations that are attractive to tourists. However, the presence of substantial negative externalitiesmay lead to the exact opposite: regulation may induce prices (and rents) to increase because thereduction in negative external costs due to regulation will increase residential demand. Hence, thenet effects of short-term rentals on the housing market are still unknown.

The case of Los Angeles

Shaping Africa’s post-Covidrecovery: A new eBook

Stronger together? Thepolicy mix strikes back

Taxing the superrich

Hans KosterProfessor of Urban Economics

and Real Estate, Vrije UniversiteitAmsterdam

Jos van OmmerenProfessor of Urban Economics,

Vrije Universiteit Amsterdam

Nicolas VolhausenResearch Analyst, McKinsey; PhD

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There are numerous reports indicating a strong positive relationship between property values andthe intensity of short-term rentals. However, calling out Airbnb as the culprit of rising housing pricesand rents is problematic, since many cities have become increasingly popular among both localsand tourists in recent years, leading to higher housing prices and a higher number of Airbnb listings.In our paper (Koster et al. 2018), we overcome this challenge by relying on a quasi-experimentalresearch design for Los Angeles County.

Similar to other cities, Airbnb rapidly grew in a decade from just a handful of listings to close to40,000 properties in Los Angeles County (Inside Airbnb 2018). While many municipalities stillstruggle with putting up regulatory measures to curb the surge of short-term rentals, 18 out of 88incorporated cities in Los Angeles County have severely restricted short-term rentals of entirehomes and apartments by adopting home sharing ordinances (HSOs). These HSOs essentiallybanned informal short-term rentals: hosts renting out entire properties became subject to the sameformal regulations as hotels and bed and breakfasts. Home-sharing through Airbnb (as well as long-term renting) is not prohibited but restricted.

Figure 1 Airbnb in Los Angeles County

There are several reasons why we focus on Los Angeles County. First, it is the most populouscounty in the US and its main locality, the City of Los Angeles, has not yet formally regulated short-term rentals or enforced a comprehensive regulation (see Figure 1). This enables us to focus onchanges in the number of Airbnb listings as well as housing prices close to the HSO-regulatedplaces. We use micro-data on Airbnb listings and housing prices between 2014 and 2018.

Our data allow us to distinguish between effects on different types of listings (home-sharing, entireproperties), as well as on the prices of different types of housing (apartments, single-family homes).We also extend the results to include effects on rents.

Our empirical approach relies on a panel regression discontinuity design, where we comparelistings that were affected by HSOs (treatment group) with nearby listings that remained unaffected

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by the legislation (comparison group). The borders of the HSO-affected cities serve as a geographiccut-off point, which assigns listings into either the treatment or comparison group. This quasi-experimental research design enables us to measure the causal effect of the HSO on Airbnb listingsand housing prices.

Measuring the causal effect of Airbnb on the housing market

First, we estimate the effect of HSOs on a property’s probability of being listed on Airbnb. In Figure2A, we plot this probability. We observe a sizable drop in listings in HSO-affected areas. Given anaverage probability of being listed of about 30%, the ordinance strongly reduces the number ofAirbnb listings by around 30%. We plot the effect over time in Figure 3A and show that the reductionin listings is about 50–60% in the long run. Hence, in line with anecdotal evidence, this suggeststhat HSOs are very effective in reducing short-term rentals.

Figure 2 Airbnb listings and housing prices: Variation near the HSO borders

Note: Negative distances indicate areas outside HSO areas, and areas inside HSO areas before treatment. The dots areconditional averages at every 200-metre interval. The dotted lines denote 95% confidence intervals.

Figure 3 The effect of the HSO on listings and housing prices over time

Note: The dotted lines denote 95% confidence intervals.

One expects a negative effect of the HSO on housing prices (except when negative externalities aresubstantial). We now compare changes in housing prices near the HSO borders. Figure 2Bsuggests that housing prices have been reduced by about 3%. The effect turns out to be highlysignificant statistically and although we examine effects at a very local level (within one kilometre ofthe border), we show with more elaborate statistical techniques that the estimated effect is veryrobust to the choice of the geographic focus. This effect becomes more pronounced over time (seeFigure 3B). We also analyse the impact of HSOs on rents and show that the effects are essentiallythe same.

0 A A

Using these estimates, we estimate the overall impact of Airbnb on property values and show thatthe effect can be large. For example, in areas within five kilometres of Los Angeles’s centralbusiness district, the price increase is 14%. Within 2.5 kilometres of beaches, the price increase dueto Airbnb is almost 10%. Hence, in areas that are attractive to tourists, prices are substantiallyhigher, while in areas without much tourist demand (e.g. Pasadena), effects are small.

Policy implications

What can we say about the distributional and welfare effects of Airbnb regulation? Using a back-of-the-envelope calculation, we show that regulating Airbnb has stark distributional implications. Aregulation implies losses for homeowners, which are substantial for individuals who live in areaspopular with tourists. The opposite holds for households who typically rent, who can only gain fromsuch a regulation. Given the average housing price in HSO cities and given our assumptions, thistherefore implies an annual welfare loss due to HSOs of about $680 per property. The intuition forsuch a substantial loss is that the investors’ willingness to pay is much higher than the willingness ofthe incumbent households being priced out of the market.

There are clear distributional implications of the HSO. We show that rents will decrease due to theHSO, so the average renter will gain. Because of the HSOs, homeowners lose, while renters tend togain. This offers a plausible explanation as to why cities around the world that have heavilyrestricted short-term rentals typically have a high share of renters.

References

Branson-Potts, H (2016), “Santa Monica convicts its first Airbnb host under tough home-sharinglaws”, Los Angeles Times, 14 July.

CBRE (2017), “Hosts with multiple units — A key driver of Airbnb growth”, technical report.

Fishman, S (2015), “Overview of Airbnb law in San Francisco”, www.nolo.com.

Inside Airbnb (2018), “Los Angeles”.

Koster, HRA, J van Ommeren and N Volkhausen (2018), “Short-term rentals and the housingmarket: Quasi-experimental evidence from Airbnb in Los Angeles”, CEPR Discussion Paper 13094.

Newling, D (2016), “Increase in Airbnb rentals leads to huge rise in noise complaints”, EveningStandard, 1 November.

O’Sullivan, F (2016), “The city with the world’s toughest anti-Airbnb laws”, CityLab, 1 December.

Samaan, R (2015), “Airbnb, rising rent, and the housing crisis in Los Angeles”, Los Angeles Alliancefor a New Economy.

Sheppard, S, and A Udell (2016), “Do AirBnB properties affect house prices?”, Williams College,Department of Economics Working Papers 2016-03.

Topics: Competition policy Microeconomic regulation

Tags: housing prices, rental prices, US, Los Angeles, online platforms, Airbnb, property values, short-term rentalregulation, home sharing ordinances, real estate

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The Airbnb Effect On HousingAnd Rent

Feb 21, 2020, 06:54am EST | 29,308 views

Gary Barker Senior Contributor

Airbnb currently hosts over 7 million listings and is active in more than 100,000 cities across 220 ...

[+] SHUTTERSTOCK

The Wall Street Journal reported earlier this month that Airbnb hadrecorded a $322 million (£248.65 million) net loss in the first ninemonths to September in 2019. That’s a considerable drop from the $200-million profit reported by the world’s largest online marketplace for

https://www.forbes.com/real-estate/old-2020

https://www.forbes.com/sites/garybarker/


https://www.wsj.com/articles/airbnb-swings-to-a-loss-as-costs-climb-ahead-of-ipo-11581443123

lodgings in 2018.

For a company with a valuation of $31 billion, according to Pitchbook in2017, it’s a sign that the horn of this start-up unicorn might just be acarrot ahead of its hotly anticipated public IPO later this year.

However, although this is disappointing news for Airbnb stakeholders andinvestors, cities and countries around the world suffering from extendedhousing crises may celebrate its diminishing market influence.

The influence of the so-called ‘Airbnb effect’ on local housing markets hasgrown into a significant cause for concern, particularly when looking at itsimpacts on housing stock, prices and communities.

But even if Airbnb really is damaging local housing markets, can anythingbe done to stop the hugely popular, multi-billion-dollar juggernaut?

The cost of the world’s largest holiday platform

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Has The U.K. Property Market Hit Its Ceiling?

Airbnb currently hosts over 7 million listings and is active in more than100,000 cities across 220 countries and regions. It’s not lacking in visioneither – Airbnb aims for 1 billion guests annually by 2028.

The platform is widely enjoyed for its access to holiday lets ranging fromsingle rooms to entire properties, varying in quality and affordability, andoffering a markedly different experience to that found in a hotel.

Then there are the clear economic benefits for local economies that standto gain from the increase in tourists supported with a wider variety ofaffordable and available holiday listings. Homeowners and landlords also

https://www.forbes.com/sites/garybarker/2021/01/21/has-the-property-market-hit-its-ceiling/

https://pitchbook.com/newsletter/ipo-bound-airbnb-struggles-to-stay-profitable

https://news.airbnb.com/fast-facts/

https://www.sfchronicle.com/business/article/Airbnb-aims-for-1-billion-annual-guests-in-a-12633657.php

benefit, as turning their rooms and properties into short-term lets canoffer an alternative and lucrative source of revenue.

But in recent years the impact of Airbnb’s service on local economics andrental markets has come under the spotlight. And analysis conducted bythe Economic Policy Institute, a non-profit, non-partisan American thinktank, found that the economic costs of Airbnb likely outweigh the benefits:

‘While the introduction and expansion of Airbnb into cities around theworld carries large potential economic benefits and costs, the costs torenters and local jurisdictions likely exceed the benefits to travellers andproperty owners.’

The ‘Airbnb effect’ is to some extent remarkably similar to gentrificationin that it slowly increases the value of an area to the detriment of theindigenous residents, many of whom are pushed out due to financialconstraints.

Cities, popular ones especially, seem to fare the worst. In major cities suchas Amsterdam, Barcelona, Edinburgh, and Los Angeles, studies on the‘Airbnb effect’ have found that over-tourism facilitated by platforms suchas Airbnb negatively impacts on house prices and communities.

The short-term rental sector is just as affected. Research conduced by theHarvard Business Review across the US found that Airbnb is having adetrimental impact on housing stock as it encourages landlords to movetheir properties out from out of the long-term rental and for-sale marketsand into the short-term rental market.

A separate U.S. study found that a 1% increase in Airbnb listings leads to a0.018% increase in rents and a 0.026% increase in house prices. It mightnot seem like much on the surface but there’s a cost creep for those

https://www.epi.org/files/pdf/157766.pdf

https://www.researchgate.net/publication/307554257_Holiday_Rentals_The_New_Gentrification_Battlefront

https://www.bbc.co.uk/news/business-45083954

https://hbr.org/2019/04/research-when-airbnb-listings-in-a-city-increase-so-do-rent-prices

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3006832

looking to rent long-term or buy.

It would be a mistake to say all markets are equal, but housing markets inthe U.S. have a socioeconomic cousin across the pond, and for the citywith the world’s highest number of Airbnb listings, it should indicate awarning.

A case study: What’s happening in the U.K?

Airbnb’s U.K. growth has been rapid and extensive. If you were wonderingwhich global city has the greatest number of Airbnb listings, it’s London,with over 80,000 listings – and 55% plus of these listings are for entireproperties.

Some see this as an opportunity for agents, that 2020 could be the ‘year ofAirbnb’. That certainly could be true for short-term landlords, and agentslooking to take a bite of that market. But of this I would be wary, as short-term gain can undermine long-term sustainability.

A recently published report from the London-based economic researchconsultancy Capital Economics, commissioned by ARLA, analysed thescale of U.K.’s short-term lets sector and the wider implications for theprivate rented sector. The research found that active listings on Airbnb inthe U.K. increased from 168,000 in 2017 to 223,000 in 2018 – that’s a33% leap, and a significant market share of the growing U.K. lettingsmarket. It’s also not the whole picture though, as data for similar short-term lettings services like Booking.com and Homeaway are unavailable.

The report further showed that 2.7% of the U.K.’s 1.5-million stronglandlord population have already made the switch from long-term rentalproperties in the private rented sector to short-term lets, equating to50,000 homes made unavailable to long-term tenants.

http://insideairbnb.com/london/

https://www.estateagenttoday.co.uk/features/2020/1/2020--the-year-of-airbnb-and-the-opportunity-for-agents

https://www.arla.co.uk/media/1048597/the-impact-of-short-term-lets.pdf

https://www.capitaleconomics.com/

https://www.arla.co.uk/

And worryingly, around 10% of U.K. landlords surveyed responded thatthey are considering moving their private rented properties to the short-term market.

The factors behind this are myriad, but over one-third of landlordssurveyed acknowledged that it was because of changes to mortgageinterest relief, which from April this year will be reduced to a 0%deductible.

Other forms of long-term regulation including higher stamp duty, theTenant Fees Act, and the abolishment of Section 21 legislation currentlyunder consideration are also cited as factors persuading landlords in thebuy-to-let sector that the grass is greener on the other side.

Here’s the kicker. If every landlord in that 10% does move their propertiesto the short-term market, up to an estimated 470,000 properties would beremoved from the private rented housing supply – around 8.7% of theentire U.K. rented sector stock. And that would significantly stretchalready strained housing supply.

I’ve said previously that supply and demand in the lettings market is aleaking ship that threatens to capsize landlords and tenants if notnavigated correctly through rough waters. If more stock is moved into theshort-term lettings market through platforms like Airbnb it could havecollateral impacts on the wider market.

Airbnb claims that between July 2017 and July 2018, the U.K. economygained £3.5 billion from hosts and guests using the platform, with anestimated 8.4-million inbound guests using the platform over this period.

Great for the economy, you might think? But a healthy housing market isthe real bedrock of a healthy economy, and the U.K. housing market is not

https://www.forbes.com/sites/garybarker/2019/11/28/supply-and-demand-the-leaking-ship-of-landlords-and-tenants/#2f5204963d36

https://www.airbnbcitizen.com/wp-content/uploads/2018/10/AirbnbUKInsightsReport_2018.pdf

in great straits at the moment.

Restrained confidence and uncertainty due to the earlier election andBrexit are only now loosening up. But whilst market confidence isreturning, low stock in both the sales and rental markets is pushing upprices.

The latest Home Asking Price Index reports that total sales stock is down10.1% year-on-year in February; and it’s worse for the rental sector, withthe supply of available rental properties in the U.K. down 18% over thesame period.

Low supply and increasing rents in the U.K. are a major concern. Thelatest official government statistics on U.K. rental housing show thatprivate rents have increased 1.5% year-on-year in the 12 months toJanuary 2020. But an extended trend outlook reveals that betweenJanuary 2015 and December 2019, private rents increase by 8.6%. That’s asignificant increase.

It’s even worse for the London, Airbnb’s bread and butter. According toRightmove, asking rents in the capital have increased almost twice asquickly compared with the rest of the U.K.

Many Londoners are now paying more than half their income on rent eachmonth. And with more than 1 in 50 London homes listed as short-termlets, it’s questionable whether Airbnb can continue its free reignthroughout the capital and the U.K. when the country is in such dire needfor affordable housing stock.

Pushing back against the short-let industry

With spiralling costs fuelling a chronic housing crisis, the voices calling forregulation of Airbnb-style short-term lets are getting louder.

https://www.home.co.uk/asking_price_index/HAPIndex_FEB20.pdf

https://www.ons.gov.uk/economy/inflationandpriceindices/bulletins/indexofprivatehousingrentalprices/january2020/pdf

https://www.rightmove.co.uk/news/content/uploads/2020/01/Rental-Trends-Tracker-Q4-2019-Final-1.pdf

https://www.theguardian.com/uk-news/2020/jan/21/homelessness-one-in-50-homes-london-short-term-let

https://www.insidehousing.co.uk/comment/the-government-must-act-on-out-of-control-growth-of-airbnb-style-lets--65114

The U.K. lags behind other countries when it comes to regulation forshort-term letting sites like Airbnb, and it might be time to reconsiderthat. Research unveiled by The Guardian on February 20 reveals that insome parts of the U.K. one in four homes is an Airbnb listing.

Simultaneously produced research from the publication highlights thatAirbnb’s presence in certain barrios (neighbourhoods) in Spain haspushed rent increases by as much as 50%, forcing locals to move to moreaffordable areas. It’s a warning sign the U.K. would do well to take note of.

Several countries and cities have started to push back against Airbnb andother short-term lettings platform because of the impacts felt on localcommunities and housing costs:

Berlin has enforced restrictions against short-term lets on platforms likeAirbnb since 2016, requiring landlords to acquire a permit if they want torent 50% or more of their main residence as a short let.

New York City is currently embroiled in a legal battle with Airbnbregarding the turn-over of host data. In fact, since launching in 2008,Airbnb has been involved in at least 11 lawsuits against an American cityor state, with the majority of cases taking place within the last two years.

Edinburgh will soon bring in a licensing scheme from 2021 empoweringcouncils to regulate ‘holiday-style’ lets if they feel it’s better for localcommunities. And in ‘control areas’, landlords will require planningpermission before they can convert a whole property for short-term lets.

Perhaps to pre-empt any future legislation in London, Airbnb introducedin January 2017 the ’90-Day Airbnb Rule’, whereby short-term rentals forentire homes are capped at 90 days per year. But this has had mixedresults, and research commissioned by City Hall has suggested that as

https://www.theguardian.com/technology/2020/feb/20/revealed-the-areas-in-the-uk-with-one-airbnb-for-every-four-homes

https://www.theguardian.com/technology/2020/feb/20/soaring-rents-and-noisy-parties-how-airbnb-is-forcing-out-barcelona-locals

https://www.bbc.co.uk/news/av/technology-36185271/berlin-cracks-down-on-airbnb-rentals

https://www.cityandstateny.com/articles/policy/technology/airbnbs-new-york-city-legal-battles.html

https://www.bloomberg.com/graphics/2020-airbnb-ipo-challenges/

https://www.mortgagestrategy.co.uk/news/lets-have-em/

many as 23% of London’s approximately 80,000 listings at the time ofstudy were in breach of the 90-day limit.

Airbnb has disputed the figures, claiming the data is wrong as it comesfrom third-party scrapers which it considers inaccurate.

There have been calls to introduce a licencing scheme for the rest of theU.K., similar to what’s being introduced in Edinburgh. But this scheme isnot being introduced by the government of city councils, it’s an Airbnbinitiative.

Who really has the lead on legislation?

Back in January, Airbnb won a significant victory in a top E.U. court to beruled as an ‘information society service’, or an online platform rather thanan estate agency, if you will. It means that they get to avoid stringentregulations in place across Europe affecting how the company operates,and for the time being (whilst the U.K. remains part of the E.U.) givesthem stronger freedoms against regulation in cities such as London.

Airbnb is certainly happy with the result, but does it match with theplatform’s recent corporate pledge to make a ‘positive contribution tosociety’? That could be the intended impression.

The platform this month kicked off a series of registration roadshows incities across the U.K. The aim of which is to ‘consult on proposals for aclear, modern and simple registration system for short-term rentals incollaboration with policymakers, communities and local hosts.’ In a recentITV interview, they stated that: “We are good partners to cities and wehave worked with more than 500 governments and organisations aroundthe world to help hosts share their homes and follow the rules. We werethe first platform to work with London to limit how often hosts can share

https://www.wired.co.uk/article/airbnb-london-short-term-rentals

https://www.politico.eu/article/airbnb-wins-legal-victory-as-top-eu-court-defines-firm-as-information-society-service/

https://news.airbnb.com/serving-all-stakeholders/

https://news.airbnb.com/en-uk/airbnb-kicks-off-host-registration-roadshow-in-uk-cities/

their homes and we have led calls for a national registration system in theUK.”

It should be taken as a positive that Airbnb is trying to lead the way onresponsible legislation. But forgive the cynic in me if I’m a little lessoptimistic. What’s more likely is that Airbnb is well aware of the impactsof their service in many cities and is trying to control the narrative andbuild a favourable impression ahead of their expected IPO later this year,whilst safeguarding against any threats towards their future revenues.

In summary

Whilst it’s easy to slay Airbnb as the cause of rising prices and lack ofrental stock in popular cities, one can’t help but wonder if they aren’tmerely the backdoor escape for landlords that have been cornered into animpossible scenario, with everything from scrapped tenant fee bans tozero mortgage relief, to a list of compliancy legislation so lengthy that it’snear impossible to self-manage a property, counting against them.Perhaps Airbnb is just the tip of the iceberg, where an unforgivingapproach to landlords and a lack of government capacity to deliver ontheir house-building promises are the bulk of the problem that’s proppingup Airbnb as the visible, easily targeted problem.

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The Effect of Short Term Rentals on

The Supply of Housing in Santa Barbara City and County

What is the effect of the short-term rental (STR) market on the supply of long-term housing?

A report prepared by the

California Economic Forecast 5385 Hollister Avenue

Box 207 Santa Barbara, CA 93111

(805) 692-2498 www.californiaforecast.com

May 12, 2016

FINAL REPORT

2

Executive Summary The purpose of this report is to present data-supported analysis and conclusions regarding the impact of Short-Term Rentals (STRs) on the supply of long-term housing in Santa Barbara City and County. Short-Term Rentals (STRs) have grown to represent an important economic engine for the local economy. A recent STR Economic Impact Report for the Santa Barbara area concluded that the operation of STRs creates approximately $471 million in overall economic activity per year, and approximately 5,000 jobs. STRs also provide significant annual Transient Occupancy Tax revenues to Santa Barbara City and Santa Barbara County. However, community members and decision makers are concerned about the impact of STRs on the supply of long-term housing. Is there a valid concern that the long-term rental housing supply in the City and County of Santa Barbara is negatively impacted by the operation of STRs? Yes. However the degree to which the supply is impacted is negligible, far less than presumed. As a principal part of the study methodology, survey requests were sent to STR property owners in Santa Barbara City and County. The survey was conducted during the month of March 2016. Key Results of the Survey

• If STRs were prohibited in the City and/or County of Santa Barbara, 71% of STR owners would continue to rent their properties as short-term rentals. 49% would be rented legally (30+ night stays), and 22% illegally (less than 30-night stays).

• Less than 15 percent of STR property owners rent their properties full time throughout the year. The remaining owners only rent their properties part time. Most owners rent their homes out as vacation rentals for less than half of the calendar year.

• 51 percent of all STR properties in Santa Barbara County are located in the City of Santa Barbara.

• In 86 percent of all cases, the entire dwelling is rented out short term. • Less than 13 percent of STR owners use the vacation rental business as their

livelihood.

3

Using the survey responses as representative of all STRs in Santa Barbara County, extrapolations to the entire population of STRs show that the prohibition of STRs would create an estimated 67 additional long-term rental units in the City of Santa Barbara, and an estimated 77 additional long-term rental units in rest of the County of Santa Barbara. 144 total additional units out of 147,368 long-term housing units in the entire County of Santa Barbara represents 0.10% of total housing stock being added to the supply of rentals. An increase of 1/10th of 1% in the long-term rental supply is created by prohibition of STRs, and does not represent a significant number of housing units that would be converted from STR use to a longer term supply of housing for purchase or rent. This study also shows that if STR prohibition is enacted, 22% of STR operators may operate in a “grey market” in which rentals of less than 30-nights will continue in spite of the prohibition. This grey market will add additional regulatory costs, and will not produce transient occupancy revenues to Santa Barbara City and County. In conclusion, the empirical evidence does not justify the perception that the operation of STRs in Santa Barbara County or City materially impacts the supply of housing for residents. Only a negligible increase in the long-term housing supply would be created by the prohibition of STRs, and approximately half of that negligible increase would not be considered “affordable” housing. Consequently, this study does not support the perception that STRs have a significant negative impact on the supply of long-term housing.

4

What is the effect of the short-term rental (STR) market on the supply of long-term housing? In Santa Barbara City and County, and in other coastal areas of California, home prices are between 2 and 6 times higher than the median home price for all homes nationwide. Average rents for apartments are twice as high as the national average. Housing is simply more expensive in the Bay Area, Santa Barbara, and along Coastal California in general than in most other areas of the country. Why? Because demand for homes in California remains strong and the growth of housing supply is dwarfed by the growth of housing demand. Housing supply growth is constrained by many factors, but the most prominent are growth controls and the regulation of new housing supply. Growth controls come in many forms, including zoning policies, urban growth boundaries, affordable housing policies, development fees, new unit limitations per year, and other land use policies.1 While there are many reasons for a constrained housing supply, a recent allegation has been aimed at short-term rentals as having a meaningful effect on restricting the supply of rental units. 1 See for example, the March 2016 edition of the California Economic Forecast’s monthly newsletter on Urban Growth Controls: http://californiaforecast.com/march-2016/

5

If the owner of a condo, home, studio, or multi-family apartment structure (who does not use the property during a portion of the year) decides to dedicate an entire unit exclusively to STR use, there is the potential to remove housing from the stock available to local residents. In the majority of cases, removing the housing unit from the housing stock would likely mean removing the unit from the rental housing stock, though it’s also possible that a unit dedicated to STR use might otherwise be available for sale, too. It is not accurate to say that all units that are dedicated to STR use are being removed from the rental stock because some of them have never been part of it, and/or the property owner is unwilling to have a non-relative tenant. Consequently, they would leave the unit vacant or exclusively available for relatives, friends or other uses if they were unable to rent it out short-term. A full listing of STRs from short-term rental websites such as AirBnB.com, HomeAway.com, VRBO.com , and Flipkey.com would include the following types of listings: Housing types that impact the supply of long-term housing: • Units that are being short-term rented full time without a resident in the home,

and there is no personal use of the property by the owner Housing types that do not impact the supply of long-term housing: • Second homes that are used a portion of the year by the owner • Extra bedrooms that someone is renting out some of the time • Full units that someone is renting out when they happen to be out

of town • Other listings by property owners who took the time to make a listing, but don’t actually follow through with renting because they don’t need the money at this moment.

6

For the purposes of determining the impact that STRs have on the supply of housing available to tenants or new purchasers, we need to know:

(1) The total number of housing units in Santa Barbara City and County

(2) The total number of STRs in Santa Barbara City and County

(3) Whether the STRs are “whole house” or “whole units”, and if they are made available throughout the year.

(4) What alternatives would current owners of STR properties choose if their current use of the property as a short-term rental was prohibited.

The current total supply of housing is presented here: Housing Supply today / Santa Barbara County Total Single Total Total

Family Apartments Supply*

------------------- units ------------------- Santa Barbara City: 21,457 16,609 38,066 Other Incorporated Cities in SB County**: 41,472 20,726 62,198 Unincorporated Areas of SB County: 38,505 8,599 47,104 Total Santa Barbara County 101,434 45,934 147,368 ---------------------------------------------------------------------------------------------------------- * Does not include mobile homes **Cities include: Santa Maria, Lompoc, Goleta, Carpinteria, Solvang, Guadalupe, Buellton Source: Department of Finance, report E-5, May 2015

The table is the most recent inventory of housing stock in Santa Barbara County, and is updated annually every May by the Department of Finance. Currently, there are 38,066 housing units in the City of Santa Barbara, 62,198 housing units in

7

Other Incorporated Cities in SB County, and 47,104 housing units in the Unincorporated Areas of SB County. This results in a total of 147,368 housing units in Santa Barbara County. Estimated STR Inventory / Santa Barbara City and County The total supply of STRs was determined in a recent report prepared by TXP, Inc.2 “Approximately 2,550 unique STR properties were listed in 2014 throughout Santa Barbara County across a variety of major online vacation rental platforms.”3 TXP determined that the total output impact of STRs in Santa Barbara County is $472 million per year and that the City of Santa Barbara’s contribution to that impact is 46.8 percent of the county total. Applying the ratio of the City to County output impact to the number of STR properties in the County, it is estimated that at most, there are 1,193 properties located within the Santa Barbara City limits.4

STR Inventory / Santa Barbara County

number of properties

Santa Barbara City: 1,193*

Rest of Santa Barbara County: 1,357 TOTAL: 2,550

* represents 46.8 of total STR supply in the County of Santa Barbara

2 TXP, Inc., “The Local Economic Impact of Short Term Rentals in Santa Barbara, CA,” Fall 2015 3 ibid., page 4 4 We say “at most” because STR properties in the City of Santa Barbara would, like housing prices, typically have a higher average rental price than the collective average of the properties outside of the City (including Carpinteria, Montecito, Goleta, Lompoc Santa Ynez and Santa Maria). A higher price would lead to a larger impact per property. A larger impact per property means that to contribute 46.8 percent of the total output in the county, the number of STR properties in the City would be less than 46.8 percent of the total STR properties in the County

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Survey of STR properties / County of Santa Barbara A recent survey of STR property owners was conducted to obtain information that is pertinent in the determination of the STR impact on housing supply. Two principal vacation rental websites (AirBnB.com and HomeAway.com) were contacted for the purpose of disseminating a survey to all STR property owners in Santa Barbara County. Surveys were also sent to owners of properties managed by professional STR management companies. 1,660 survey requests were sent to the following recipients: Surveys sent to owners by email from HomeAway corporate office*: 575 Surveys sent to owners through the HomeAway inquiry system: 476 Surveys sent to owners through the AirBnB inquiry system: 336 Surveys sent to owners by local STR management companies: 273 TOTAL: 1,660 *Approximately 425 STR property owners were not sent the survey from HomeAway.com corporate office because those property owners had “opted out” of receiving ancillary email correspondence from HomeAway.com. The survey was conducted during the month of March 2016. A total of 319 responses were received. This represents a 19 percent response rate. Responses to six principal questions were requested for the analysis. An additional 4 responses were requested from STR owners if they selected the 4th or 5th answer in question 6). The Survey Questions and the responses are presented below. 1) Where is your property located? Answer percent number Santa Barbara 51.10% 163 Montecito 14.42% 46 Goleta 1.25% 4 Carpinteria 10.66% 34 Santa Ynez Valley 14.73% 47 Lompoc Valley 0.63% 2 Santa Maria Valley 0.94% 3

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Other (please specify) 6.27% 20 Total 100% 319 The proportion of 51 percent of respondents having their properties located in Santa Barbara is statistically comparable to the 47 percent of total properties in Santa Barbara County estimated (above) to be located in Santa Barbara. Most STRs are located along the South Coast of Santa Barbara County (83%) with only a small representation of properties in the North County.5 2) What type of property is your short-term rental? Answer percent number Single Family Home 76.18% 243 Condo or Townhouse 9.09% 29 Apartment 2.51% 8 Other (please specify) 12.23% 39 Total 100% 319 The dominant response is that the typical STR is a detached single-family home. Apartments really do not comprise a meaningful portion of the short-term rental stock. The “other” category of 39 properties was mostly guest homes or cottages, separate mother-in-law or grannie units, or artist or studios, or single-family ranch homes on a ranch. 3) What do you offer for rent? Answer percent number Entire dwelling 86.52% 276 Individual room(s) in the dwelling 13.48% 43

Total 100% 319 Clearly, most STRs comprise the entire property. Consequently, it would appear that the potential to augment the housing stock would be quite high if all of these homes were precluded from STR activity. 5 The “other “ category included 5 homes in Summerland, 4 homes in “Noleta” (commonly interpreted as the unincorporated area between Goleta and Santa Barbara), 1 in Montecito, and 6 in the unspecified unincorporated South Coast region of the county. There were only 4 in the North County including the Santa Ynez Valley. Consequently, 16 of the 20 “other “ responses can be allocated into the South Coast.

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4) Please provide the best answer as to why you use your property as a short-term rental Answer percent number I need to rent the property (or rooms) to help finance the mortgage

28.84% 92 I need the additional income to make ends meet 32.92% 105 I don’t use the home full time, so I might as well rent it out when I’m not here

25.71% 82 This is my business 12.54% 40 ------------------------------------------------------------------------------------------- Total 100% 319 Less than 13 percent of STR owners claim that the vacation rental business is their livelihood. The remainder engages in STR activity to augment their incomes to finance their properties or the general cost of living. 5) How many nights during the year do YOU personally use your short-term rental property? Answer percent number None. My property is available for rent 100 percent of the year

14.42% 46 1 to 90 nights 45.77% 146 91 to 180 nights 19.75% 63 181 to 364 nights 20.06% 64 Total 100% 319 Less than 15 percent rent their properties full time throughout the year. The remaining STR owners only rent their properties part time. And most rent their homes out as vacation rentals for less than half of the calendar year. This is consistent with the previous question that property owners who rent their homes out as vacation rentals are doing so to augment their income. It is not their primary business. Furthermore, the home is used for their personal occupation (or their family’s), and would not be available to augment the long-term supply of housing if STR activity was banned.

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6) If rentals of less than 30-nights were prohibited, what would you do? Answer percent number I would personally live in the property full time 5.96% 19 I or my extended family (or friends) would use the property more

5.96% 19 I would continue to rent my property short-term, but with a 30-night minimum per rental

49.22% 157 I would convert the property to a long-term rental (1 year lease or longer)

5.64% 18 I would sell the property 10.97% 35 I would continue to rent my property for less than 30-nights, and accept the risk of enforcement action

22.26% 71

Total 100% 319 The responses above demonstrate that most STR owners would choose an option for their property other than one that would augment the housing supply in Santa Barbara County, including the City of Santa Barbara. Only 16.6 percent of respondents indicated they would either long-term rent or sell their property. Consequently, while some additional properties would be added to the housing stock, mostly as new for-sale inventory, the vast majority (72 percent) would continue to be used as short term rentals, legally or illegally. The following 3 questions pertained only to the 18 (5.6%) of respondents (above responders in blue) who indicated they would convert their rental to long-term rental property. The purpose of the 3 questions was to determine the potential rental rates of the homes (and, for shared homes, the “per-room” rental rates) that were added to the long-term housing supply. 7) As a long-term rental (1-year leases or longer), what do you think you would rent the property for: Answer percent number $1,500 per month or less 11.11% 2 $1,501 - $3,000 per month 16.67% 3 $3,001 - $5,000 per month 22.22% 4 $5,001 - $7,500 per month 33.33% 6 $7,501 - $9,000 per month 11.11% 2

12

Greater than $9,000 per month 5.56% 1 Total 100% 18 Half of respondents indicated they would rent their home for $5,000+ per month. This tends to be the higher end of rental properties in Santa Barbara, Goleta, Montecito and Carpinteria, and very high elsewhere. A review of houses for rent on Craig’s List clearly demonstrates this. Consequently, only 9 homes out of 319 STR properties surveyed (2.8 percent) would be added to the rental supply of homes in an affordable range for professionally working families. The other half (2.8 percent) would be added to the rental supply in the luxury home category. 8) As a long-term rental, how many bedrooms would be available in your property? Answer percent number 1 16.67% 3 2 22.22% 4 3 44.44% 8 4 5.56% 1 5 5.56% 1 6 or more 5.56% 1 Total 100% 18 9) What would the “per room” rate be for your long-term rental (calculated as the total monthly rent divided by the total number of bedrooms)? Answer percent number $500 or less 0.00% 0 $501 - $1000 5.56% 1 $1001 - $1,500 50.00% 9 $1,501 - $2,000 33.33% 6 Greater than $2,000 11.11% 2 Total 100% 18 The following question pertained only to the 35 (10.97%) of respondents (question 6 responders in green) who indicated that they would sell their property. The purpose of the question was to determine a potential for-sale price or “value” of the type of homes that would be added to the long-term housing supply.

13

10) What is the market value of your property? Answer percent number $500,000 or less 0.00% 0 $500,001 - $1,000,000 18.92% 7 $1,000,001 - $1,500,000 13.51% 5 $1,500,001 - $3,000,000 32.43% 12 $3,000,001 - $5,000,000 21.62% 8 Greater than $5,000,000 13.51% 5 Total 100% 35 25 of the 35 of the above responders indicated the market value of their home was $1.5 million and up. 10 of the 35 indicated the market value of their home was $3.0 million and up. The median value of the 35 STR homes is $2,581,081.

14

Conclusion The tables below quantify the effect of STRs on the supply of long-term rental and for-sale housing units in the:

1) City of Santa Barbara 2) County of Santa Barbara (excluding the City of Santa Barbara), and 3) Combined Total: City & County of Santa Barbara.

City of Santa Barbara (only) Units percent

Total Housing units: 38,066 100.00% Total Short-Term Rental units: 1,193 3.13% Long-Term Rental Housing Inventory lost due to STR activity: 67 0.18% Long-Term For-Sale Housing Inventory lost due to STR activity: 131 0.34% Total Long-Term Housing Inventory lost due to STR activity: 198 0.52% County of Santa Barbara (excluding the City of Santa Barbara) Units percent

Total Housing units: 109,302 100.00% Total Short-Term Rental units: 1,357 1.24% Long-Term Rental Housing Inventory lost due to STR activity: 77 0.07% Long-Term For-Sale Housing Inventory lost due to STR activity: 149 0.13% Total Long-Term Housing Inventory lost due to STR activity: 226 0.20% Combined Total: City & County of Santa Barbara Units percent Total Housing units: 147,368 100.00% Total Short-Term Rental units: 2,550 1.73% Long-Term Rental Inventory lost due to STR activity: 144 0.10%

15

Long-Term For-Sale Housing Inventory lost due to STR activity: 280 0.19% Total Long-Term Housing Inventory lost due to STR activity: 424 0.29% Is the allegation true that the long-term housing supply in the City of Santa Barbara is impacted by the operation of STRs? Yes. But the degree to which the supply is impacted is statistically negligible. Only 16.6 percent of current STR properties would be converted to long-term rental or for-sale housing stock in the event that STR activity was prohibited in Santa Barbara County. This represents only 0.29% of the entire housing stock in Santa Barbara County. In conclusion, prohibition of STRs will create an estimated 67 additional long-term rental units in the City of Santa Barbara, and 77 additional long-term rental units in rest of the County of Santa Barbara. 144 total additional units out of 147,368 long-term housing units in the entire County of Santa Barbara represents only 0.10% of the total housing supply. This is a negligible increase in the supply of long-term rental units, and is unlikely a large enough increase in supply to have any long-term impact on rental rates. Similarly, prohibition of STRs will create an estimated 131 additional for-sale housing units in the City of Santa Barbara, and 149 additional for-sale housing units in rest of the County of Santa Barbara. 280 total additional housing units out of 147,368 long-term housing units in the entire County of Santa Barbara represents only 0.19% of the total housing supply, and is unlikely a large enough increase in supply to reduce housing purchase prices. Finally, for half of the estimated increase in the supply of long-term housing created by the prohibition of STRs, it is likely that rental rates for these properties would exceed $5,000 per month (and, in a shared home, over $1,500 per room per month). This level of monthly rent is generally not considered an “affordable housing” rate. Therefore, a significant amount of any increase in rental properties caused by prohibition of STRs would unlikely have any impact on the “affordable housing” problem in the region. The empirical evidence does not justify the perception that the operation of STRs in Santa Barbara County or City materially impact the supply of housing for residents. Only a negligible increase in the long-term housing supply would be created by the prohibition of STRs, and approximately half of that negligible increase would not be considered “affordable” housing. Consequently, this study does not support the allegation that STRs have a significant negative impact on the supply of long-term housing.

16

References The AirBnB Impact: http://www.sfchronicle.com/airbnb-impact-san-francisco-2015/#1 LAANE report: http://www.laane.org/wp-content/uploads/2015/03/AirBnB-Final.pdf Response by AirBnB to LAANE study http://www.latimes.com/business/hiltzik/la-fi-mh-airbnb-study-of-rentals-20150930-column.html Airbnb listings in Vancouver: How many? What type? Where? https://shorttermconsequences.wordpress.com/2015/06/20/airbnb-listings-in-vancouver-how-many-what-type-where/ Effect of STRs on Home Values (see last page for conclusions, page 19) Can Short-Term Rental Arrangements Increase Home Values? A Case for AirBNB and Other Home Sharing Arrangements http://scholarship.sha.cornell.edu/cgi/viewcontent.cgi?article=1133&context=crer AirBnB impact in SF on the housing crisis https://medium.com/@magicchef/how-much-of-an-impact-are-short-term-rentals-on-the-sf-housing-crisis-21c65c8dacc1#.n68h4xuhg STRs worsen housing crisis, LA Times, March 11, 2015 http://www.latimes.com/business/realestate/la-fi-airbnb-housing-market-20150311-story.html

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INVESTIGATIONS

A report by a city analyst said short-term rentals like Airbnbs are such a

small part of housing in Denver, the industry has little impact on the

cost of homes

DENVER — An analysis that compared the number of short-term rentals in the city to the

housing supply concludes short-term rentals have very little impact on the cost of housing.

The report was generated in April and was recently obtained by 9Wants to Know as it looked

into how the city has been trying to regulate the short-term rental industry.

Short-term rentals have little impacton Denver housing market, cityreport says

Author: Jeremy Jojola

Published: 2:48 PM MDT September 12, 2019

Updated: 6:56 PM MDT September 12, 2019

https://www.9news.com/section/investigations

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A 9Wants to Know investigation found entities that appear to be businesses were issued short-

term rental permits when they should go to actual people in their primary residence. The city

said the compliance system now requires names on permits to match names on driver’s

licenses. In some situations, a business may own a property but give someone living there

permission to legally run a short-term rental, the city said.

RELATED: Owner of property management company accused of skirting short-term rental

rules

RELATED: Attorney accused of gaming Denver's short term rental rules

The report by the Economic Development department said short-term rentals make up only 1%

of the housing supply in the city, which is 306,714 home units.

“Short term rentals in Denver do not appear to have an impact on housing costs at the citywide

level. A geographic concentration of short-term rentals is moderately positively correlated with

increased home values, but not increased rents,” Analyst Katherine O’Connor wrote in the

report.

Denver’s Department of Excise and Licenses, which issues short-term rental permits, said the

“primary residence” rule has helped reduce the impact of short-term rentals on the housing

market.

“It does not allow people to buy up additional units, a bungalow next door or a condo across

town. It doesn’t allow companies to come in and buy multiple units and start short-term renting

them,” Ashley Kilroy, executive director of the Excise and Licenses department, said of the rule.

Has Denver Star NikolaJokic Been UnderratedThis Season?

FEATURED BY

https://www.9news.com/denver-short-term-rentals

https://www.9news.com/article/news/crime/owner-of-property-management-company-accused-of-skirting-short-term-rental-rules/73-3a09889a-922f-49c5-a9bd-61048642a92d

https://www.9news.com/article/news/local/attorney-accused-of-gaming-denvers-short-term-rental-rules/73-19b14e94-4f7f-4cc1-a9c6-6599d83ea548

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RELATED: Denver couple accused of illegally running short-term rental business through

Airbnb

RELATED: These are the most popular Airbnb rentals in Colorado ski towns

The city began enforcing its primary residence rule in 2017, prompting 267 people to either

withdraw their permit applications or surrender their licenses as of Sept. 5.

The city claims 75% of the short-term rental ads online are in compliance with the law, the

highest compliance rate in the country, city officials said.

The economic development report also credits the primary residence rule for helping reduce

impact.

“This prevents investors from purchasing housing that would otherwise be used for normal,

long term residential purposes, thereby decreasing the housing supply and inflating prices,”

O’Connor wrote in her report.

9Wants to Know also compared a list of properties from 2015 that were used for Section 8

housing to properties currently used for short-term rentals. No properties from the 2015 list are

being used for licensed short-term rentals.

Lisa Calderon, chief of staff for Councilwoman Candi CdeBaca, believes short term rentals still

Page 1 of 9

Sho! Term Rentals & Housing Costs in Denver

Prepared by Katherine O’Connor, Analyst – Denver Economic Developmentand Oppo!unityApril2019

AbstractThis analysis examines whether sho! terms rentals increase housing costs in Denver.Sho! term rentalscould increase housing costs in Denver in two ways. First, by decreasing the overallsupply of housingunits used for normal residential purposes, thereby increasing rents and homeprices. Second, byincreasing the value of housing units, which would raise rents and home prices. Thisrepo! evaluateswhether either of these two mechanisms of increasing housing costs areoccurring in Denver.Since sho! term rentals are 1% of Denver’s entire housing supply and are required by cityordinance tobe the host’s primary residence, it is reasonable to assume that they do not decrease thehousing supplyenough to impact housing prices. Examining housing price changes by Census Tractalongside thepropo!ion of sho! term rentals by tract indicates that a geographic concentration ofsho! term rentalsis moderately positively correlated with localized increases in owner-occupied homevalues (.329), andhas a weak positive correlation with local rent increases (.033). However, thiscorrelation is likely anindication that increased home values and rents re"ect an area’s perceived desirability,which makessho! term rentals more economically viable – rather than evidence that sho! termrentals have alocalized impact on housingcosts.

BackgroundThe de#nition of sho! term rental varies across the country and throughout theworld. Sho! termrental hosts adve!ise o$erings as entire homes, accessory dwelling units, or roomswithin a home.Hosts o$ering these rentals may be owner occupants, renter occupants, or owners whodo not occupythe residential unit. Regulations on sho! term rentals vary as well – some jurisdictionshave no policiesregarding these units, while others have strict governance and complianceenforcement.There are several ways sho! term rentals are hypothesized to impact neighborhoods,

Book early

FIND FAMILYGETAWAYS

NEARBY

https://www.9news.com/article/news/crime/denver-couple-accused-of-illegally-running-short-term-rental-business-through-airbnb/73-32adf6cc-97dd-4387-a380-ce376c757d33

https://www.9news.com/article/life/style/colorado-guide/these-are-the-most-popular-airbnb-rentals-in-colorado-ski-towns/73-4c192311-273c-4cef-a9bd-1120db86abe7

impact neighborhoods on a deeper level and can accelerate gentrification in neighborhoods.

“We have an affordable housing crisis in Denver and the fact that they’re used to be working

class families living here, I would love to see a return to that,” Calderon said of the home next to

her house.

A home at 3420 Marion St. was featured in 9Wants to Know’s report on Sunday, which revealed

it was owned by a real estate agent who ran it as a full-time short-term rental. The agent gave

up his short-term rental license after Calderon complained, prompting city investigators to see

if the agent lived at the property, as required by law.

9Wants to Know found the home is owned by "Marion House, LLC."

“We know that there are students who need housing, and this would be a great student living

place. But ultimately, we need more housing options. I’d love to see this landlord be in tune to

that and it reverts back to an affordable housing property,” Calderon said.

“This report confirms what we’ve long maintained: short-term rentals are not impacting

housing prices in Denver. Meanwhile, Airbnb helps Denver families earn extra money to offset

rising housing costs and infuses visitor spending to neighborhoods that haven't typically

benefited from tourism,” an Airbnb spokesperson said. We remain committed to working with

the City to ensure Denver receives the full economic benefits of short-term rentals."

SUGGESTED VIDEOS | Investigations from 9Wants to Know

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Toronto

Stricter bylaws for short-term rentals come into

effect this week

'They could eliminate all the ghost hotel operators,' advocate says

Natalie Nanowski · CBC News · Posted: Sep 08, 2020 6:00 AM ET | Last Updated: September 8, 2020

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Anyone wanting to rent their primary residence out on a short-term rental site will now have to registerwith the City of Toronto and pay a yearly fee. (Daniel Krason/Shutterstock)

comments

After years of court battles, the city is enacting a new set of regulations this week that will

only allow people to rent out their primary residence on short-term rental sites.

It's a move to ensure that homes, condos and apartments aren't funnelled off into the short-

term rental market as investment properties, instead of being available for Torontonians to

rent long-term.

The rules, which come into effect Thursday, bring hope to some in Toronto's challenging

rental market.

"We've been waiting for this since December 2017," said Thorben Wieditz, with FairBnb

Canada, a coalition of hotel workers and housing advocates.

"This could eliminate all the ghost hotel operators that have stockpiled investment

properties and run them as exclusive Airbnb units."

Toronto residents fed up with short-term rentals used as party houses

Toronto to enforce new Airbnb regulations after tribunal rules in favour of

stricter bylaws

Starting Thursday, anyone wanting to rent out their entire primary residence, or up to three

rooms in their primary residence, must register their short-term rental with the city.

From there, they'll be issued a unique number, which is now mandatory for advertising your

home on any short-term rental site, from Airbnb to Hotels.com. A short-term rental is

defined as a property listed for less than 28 consecutive days.

Without that number, Airbnb policy director Alex Dagg says people won't be able to place

their property on the site.

https://www.cbc.ca/news/canada/toronto/short-term-rentals-1.5222737

https://www.cbc.ca/news/canada/toronto/short-term-rental-regulations-tribunal-1.5363912

https://www.toronto.ca/news/city-of-toronto-registration-of-short-term-rentals-to-launch-september-10/

"Part of the requirement for us as a platform is to provide data to the City of Toronto," Dagg

said.

Fines range from $300 to $1,000

Exactly what format that data will take hasn't been figured out yet. People have until

December 31 to register their home with the city. There's a yearly fee of $50 and it's up to

the city, not the individual rental platforms, to enforce the new regulations.

In theory, someone could list two properties under the same registration ID, but because of

the data that the city will be getting from these rental platforms, Carleton Grant, Toronto's

executive director of municipal licensing and standards, says they will eventually be caught

and fined.

More downtown condos have popped up on the long-term rental market since the COVID-19 pandemichit. (Andrew Lupton/CBC)

"It's going to give us a number of tools to allow us to enforce and know who is participating

within the rules and who isn't — and it's going to allow us to go after them" said Grant.

"There are five different fine amounts, they range for $300 to $1,000," said Grant, adding

that offenders could also be removed from the rental sites.

'We need to hold the company accountable'

Although Wieditz believes Toronto's new short-term rental rules are some of the strictest out

there he thinks companies like Airbnb should do more to enforce them.

But even though Toronto is responsible for catching offenders based on the data city

officials are provided from hosting sites, he said it shouldn't solely be left up to the city.

"We know that in many cities across North America and Europe, Airbnb has done very little

to help municipalities enforce local bylaws and rule," said Wieditz.

"We need to hold the company accountable."

'We fear for our safety': Resident says short-term rentals operating in Toronto

condo during COVID-19

When the COVID-19 pandemic hit back in March, it exposed another layer of Toronto's

extensive and problematic short-term rental market.

With travel halted, many of the condos that were listed as short-term rentals weren't making

a profit so they became available as long-term properties.

"The Ice Condos for example, there's an unusually high number of furnished rentals now

available to long-term tenants and this is definitely something that is a result of the

pandemic," said Wieditz.

Airbnb to ban local guests under the age of 25 from booking entire homes

https://www.cbc.ca/news/canada/toronto/short-term-rentals-condo-coronavirus-1.5528450

https://www.cbc.ca/news/canada/toronto/airbnb-changes-security-measures-following-deadly-shooting-1.5452766

Wieditz says that by December, when the grace period is over and registration numbers are

mandatory on short-term rental sites, more properties will either hit the long-term market

or go up for sale.

"Looking at the data, there are over 7,000 homes that are currently advertised that are not

going to be legal under the city's bylaws and regulations," said Wieditz.

When San Francisco implemented similar rules, Wieditz says, Airbnb lost over half of its

inventory overnight.

In addition to the $50 yearly registration fee, short-term rental operators will have to start

collecting and remitting a four per cent Municipal Accommodation Tax on a quarterly basis

starting in the new year.

More information on exactly how that will work is expected this fall.

©2021 CBC/Radio-Canada. All rights reserved.

Visitez Radio-Canada.ca

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THE LONG-TERM EFFECTS OF SHORT-TERM RENTALS: AN EXAMINATION OF THE MOUNTAIN TOWNHOUSING CRISISJanuary 25, 2019 By TransWorld SNOWboarding

Has the rise of Airbnb impacted the existing housing crisis in mountain communities such as Winter Park, Colorado? | PHOTO: Carl Frey

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In August of 2011, I made the spontaneous decision to move from my hometown

outside Baltimore, Maryland, to Winter Park, Colorado. It was a small resort town I had

no prior knowledge of, making the choice to move there all the more odd to my

parents, family, and friends. I had graduated college three months prior and was

fortunate to lock down a reputable internship, transitioning into a lucrative, full-time

gig, so its easy to imagine the degree to which eyebrows were raised. Still, the

depression that came with ironing a collared shirt every morning for my ensuing ten

hours behind a desk was eating at my soul. I could see my passion for snowboarding

fading in the rear view mirror during my hour-long commute each morning, just as it

already had for many of my old on-hill companions. It was the recipe for a spur-of-the-

moment, life-altering decision at the ripe old age of 23. A quarter-life crisis some might

call it.

I didnt know a soul in Winter Park, but its down-to-earth atmosphere made for an easy

transition. After a short period of time, I locked down a two-bedroom apartment with

my girlfriend for a mere $575 a month. There was no waitlist, no bidding war, no

struggle. I put in an application, and within a few days we were moving in. I was living

the local lifestyle without a care in the world, paying my bills with an $11 an hour wage

from tuning skis, and of course, snowboarding every single day.

In 2018, that same unit is going for three times as much, and youll have to take a

number and wait in line for a chance at it. A portion of the apartments in the complex

have even been scooped up by Winter Park Resort to be used as their own employee

housing. As is the case in many other mountain towns across North America, the

amount of housing wanted ads now far exceeds the amount of for rent listings. When I

moved here, there were plenty of rental options but a scarcity of jobs. In 2018, every

business has a help wanted sign on its door.

But for those who come to vacation throughout the year, !nding a place to stay couldnt

be more painless. With the dawn of Airbnb and similar platforms, !nding a home away

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For mountain communities, lack of housing has translated to workforce scarcity.

The days of tuning boards to pay the rent are getting tougher. | PHOTO: Andrew

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from home is easier than ever. It just means a local may no longer have a place to live.

Instead, they might be living out of their car, with multiple jobs, questioning whether

the choice to leave a desk job was the right decision after all. Theyre lucky if they !nd

time to snowboard, and the quarter-life crisis has resurfaced.

Like them, Ive resorted to picking up additional work to make ends meet. Ironically, my

second job is cleaning short-term rental units. And business is booming. As often as I

walk into these units thinking a local could be living here, its hard not to consider the

owners position as well. Theres money to be made, and its easier to point the !nger

when youre not in their shoes.

IS THE BLAME ON AIRBNB WARRANTED?If youve lived in a mountain townor any destination area for that matteryoure familiar

with the kneejerk reactions of crusty locals. Its always easy to place the blame on

everything from tourists to corporate resort entities for any issue that arises in the

community, and while sometimes warranted, other times these are excuses for lack of

e"ort. Which led me to consider whether Airbnb, VRBO, and similar short-term rental

services in general, are to blame for the lack of housing options, let alone a"ordable

ones. Are these platforms actually destroying the very essence of my own mountain

community of Winter Park, alongside most other major ski towns?

Robin Van Gyn, who rents her Whistler home out via Airbnb when shes traveling,

seems to agree. But she also realizes that, like all issues, there are two sides.

It does contribute to the problem, she says. There is no housing for the workforce, and

people cant a"ord to live. Its insane.

But its also another source of income, so [as a homeowner] its hard not to, she admits.

Were all just trying to get ahead.

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Its a sentiment thats echoed by Winter Park local turned part-time Tahoe resident

Jackson Fowler, who, like Van Gyn, has a property hes rented out via Airbnb for the past

three years.

Ive seen both sides of it, being a snowboard bum and having experienced the struggle

to rent a room in Tahoe where a similar crisis is going on, Fowler explains. Everybody is

turning to the Airbnb thing. That kind of leaves the locals in the dust, and I feel for that

for sure. But, at the same time, the money I make from renting my house helps me get

by.

While its easy to blame homeowners who opt to rent a unit out short-term rather than

long-term, assuming its a decision based solely on pro!t potential, for some, the latter

is hardly an option. Van Gyn and Fowler both spend time each winter traveling to

Robin Van Gyn, who rents out her Whistler home via Airbnb, realizes there are

two sides to the short-term rental issue. | PHOTO: Robin Van Gyn

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snowboard but still need a home base to come back to. Why not make a few bucks

rather than leave it vacant?

I might as well do something with it, Fowler says. And then I still have it open when I

need it. I can always just block o" dates on Airbnb, but I cant kick out a full-time renter.

I cant just say Hey, Im coming up. Can you leave?

But that consistent inconsistency is something Van Gyn admits to struggling with.

Its hard to move your personal things all the time, she says. Sometimes you just want

your space to be there and not have to screw with it. Its work.

As enticing as the extra income can be, its not always worth it.

Short-term is a pain in the butt, she readily admits. Long-term is the way to go if you

can make it work.

THE RISE OF SHORT-TERM RENTALSWith short-term rentals rising in popularity for both homeowners and vacationers,

there had to be some quanti!able proof out there. Are STRs, as theyre acronymized,

actually taking long-term opportunities o" the market, or are they simply !lling

otherwise vacant properties?

In my search for answers, I immediately took to the !rst source that came to mind: the

ever-reputable Craigslist. At the least, I wanted to know how many long-term housing

options were available, beginning in my own community of Winter Park.

How many did I !nd? Just four. The cheapest was a dated, single-bedroom unit for

$1,400 a month with no utilities included. A two-bedroom was also available up the

road in neighboring Fraser for $1,500, which included a disclaimer stating that long-

term lease agreements would increase, at an undisclosed amount, during ski season. I

While traveling for turns like this, Robin Van Gyn has rented her unit on Airbnb to

turn its otherwise vacant days into extra income. | PHOTO: Tim Zimmerman

https://i0.heartyhosting.com/www.snowboarder.com/wp-content/uploads/2019/01/20180122_jpn_vangyn_0010.jpg

also found a two-bedroom unit in downtown Winter Park for $3,000 per month. The

fourth was presumably a scam, as it was listed multiple times for $950 and wouldnt be

available for another two months anyhow.

What about the local newspaper listings? Surely there had to be something listed there.

Nope. Absolutely nothing.

After talking to Fowler, who is actually switching his Airbnb unit back to a long-term

rental because of a recent knee injury, that shortage became even more apparent.

Its been insane since Ive put the house up as a full-time rental, he said. Ive gotten 50-

plus phone calls in the past two days, and a ton of emails. I listed it at $1,600 for a two-

bedroom, not including utilities, which, for Winter Park, is actually pretty low right now.

Perhaps the pool of Winter Park rentals is relatively small to begin withmaybe the lack

of available housing is due to a lack of housing, period. Not the case. l conducted a

search of the Winter Park area on Airbnb, which resulted in a surplus of 300 short-term

rentals.

I performed a similar search in a number of other mountain communities, from the

nearby Colorado ski mecca of Breckenridge to the housing crisis capital that is Jackson,

Wyoming. The results, unsurprisingly, werent much di"erent. While long-term listings

From renting out his home in Winter Park, Colorado, to living out of his truck,

Jackson Fowler knows a thing or two about the mountain town housing

landscape. | PHOTO Danny Kern

https://i0.heartyhosting.com/www.snowboarder.com/wp-content/uploads/2017/01/Jackson-Fowler-Dreamer-Home-Danny-Kern-06.jpg

in local papers and online were both expensive and hard to come by, Airbnb was

over#owing with potential short-term rental opportunities.

Still, when it comes to workforce housing shortages, not everyone is ready to point the

!nger at STRs.

A lot of blame is placed on short-term rentals, admits Town of Winter Park Housing

Manager, John Crone. But Im not really sure there is that much blame that can go

there. It has certainly taken some long-term rentals o" the market, but I think most of

those short-term rentals are the types that sit empty most of the time anyways.

According to AirDNA.com, which provides a market overview on rentals for a submitted

zip code, these STRs arent always proving to be as lucrative as one might expectat least

not in Winter Park. Despite an average daily rate of $209, STRs in Winter Park are only

yielding a 16% occupancy rate, which results in an average monthly revenue of only

$1,003. That revenue doesnt include taxes or service fees that the town charges either,

ultimately providing an average monthly revenue that sits well below the current

$1,400-$2,000 monthly range I saw for long-term two-bedroom units.

Revenue aside, Winter Park has witnessed incredible growth in the quantity of STRs

available. After starting with only six total cumulative rentals in 2011, that amount has

now increased to a whopping 2,410 in 2018, according to AirDNA.com. Whether these

As more homeowners favor Airbnb, locals will continue to struggle to make the

Whistler backcountry their personal backyard. Jody Wachniak takes advantage of

some prime real estate. | PHOTO: Andy Wright

http://airdna.com/

http://airdna.com/

https://i0.heartyhosting.com/www.snowboarder.com/wp-content/uploads/2019/01/28-whistler-jody-wachniak-manboys-wright-003.jpg

rentals were sitting vacant before Airbnb or not, they arent sitting vacant anymore, and

the rate at which theyre increasing is signi!cant.

And what does AirDNA say for Breckenridge and Jackson? Breckenridge has more than

twice the occupancy rate of Winter Park at 33%, while Jackson has an even higher rate

of 60%. Breckenridge yields an average monthly revenue of $2,627 and has increased

from 12 total rentals in 2011 to 6,744 in 2018. Jackson, with an average monthly

revenue of an impressive $6,254, showed an increase from only one unit in 2010 to its

current 545 total units.

Looking at the South Lake Tahoe area, the results are similar to that of Breckenridge.

AirDNA shows an average monthly revenue of $3,604 by way of a 43% occupancy rate.

Since 2010, the total cumulative rentals here have increased from just 15 to a

whopping 4,610.

In Tahoe, Fowler has seen these e"ects !rsthand.

I had a group of friends in a four or !ve bedroom house. Their lease was up, and they

were planning to renew, but the homeowners decided to switch to the Airbnb thing.

They were left in the dust, thinking they had a house for another year.

While the magnitude of these numbers undoubtedly requires context of each towns

population to appropriately put into perspectiveWinter Park has a population of just

over 1,000, while South Lake Tahoe exceeds 20,000the fact of the matter is that the

number of STRs is rising, and rising dramatically. Surely, it has some sort of e"ect on

the existing workforce housing shortages.

IS THERE AN EFFECT ON THE WORKFORCE HOUSING SHORTAGE?In Summit County, Colorado, home to the aforementioned town of Breckenridge, thats

what o$cials are bent on !nding out.

In general, we get a sense that they are having a large impact, says Jason Dietz,

executive director for the Summit Combined Housing Authority. One of the things we

want to try to do is quantify what that is [through] working with the towns that make

up the Summit Combined Housing Authority. We dont really have a quanti!able

number that we can point to with hard data right now.

Currently, Summit County, which is comprised of various communities including the

towns of Breckenridge, Frisco, Silverthorne, and Dillon, while also encompassing

popular ski destinations such as Copper, Keystone, Arapahoe Basin, and of course, the

resort Breckenridge, is in the process of putting together a study for a new housing

needs assessment that hopes to zero in on exactly how STRs are impacting local

housing across the county.

We want to understand, Are we making any headway in getting more workforce

housing, or are we staying the same, or going backwards? explains Dietz. While Summit

County has long been ahead of the curve in developing workforce housing projectsthey

have a surplus of 500 units across the county currently in the works to be

developedthere is concern as to whether the projects are keeping up with the

simultaneous growth in STRs.

We dont really know the answer to that, admits Dietz. Were looking to try forming an

RFP (request for proposal) that will quantify that to see what the real numbers are.

To make the situation more di$cult, Summit Countys !ve jurisdictions each regulate

their own communities when it comes to STRs. While Breckenridge has been regulating

STRs for some time now, which includes remitting a 3.4% tax on short-term lodging

back to the town, the area de!ned as Summit County Unincorporated currently has no

regulations.

There is zero regulation, says Dietz. Literally none in regards to it. But that is soon to

end because they have been working on putting together regulation since last year,

and they are in the process of !nalizing that. The goal is to have some in place before

winter.

For communities like Jackson, Wyoming, where STRs are just another hurdle on a long

path toward workforce housing solutions, regulations are essential. And strict.

They certainly have [a"ected the housing shortage], says April Norton, Director of the

Jackson/Teton County A"ordable Housing Department when asked whether STRs have

had an impact on the communitys current housing dilemma. Theyve taken housing

stock out of the rental market. Theyve also in#ated the values of the land here.

Planned developments in Summit County, Colorado aim to ease increasing

difficulty in finding a place down the street from the region’s world-class parks.

Brett Moody enjoying bluebird park laps at Keystone’s popular A51 park. |

PHOTO: Chip Proulx

https://i0.heartyhosting.com/www.snowboarder.com/wp-content/uploads/2019/01/20-keystone-brettmoody-chipproulx.jpg

But according to Norton, STRs are just additional fuel to an already burning !re.

In Teton County, 97% of the land is publicly owned. Were already working with such a

!nite amount of land, that yes, the short-term rentals have certainly helped to in#ate

the prices, she says. But the bottom line is our land values are in no way tied to local

wages either, so youre just fundamentally going to have issues with housing local

workers.

This explains tough regulations on STRsincluding a lodging overlay and a minimum

rental period of 31 days.

Pursuant to the Land Development Regulations Section 6.1.4.A Residential Uses, no

private or residential unit may be rented for less than 31 days unless its included on an

approved list of short-term rental units. While this should make it more di$cult for

STRs to have a substantial impression on the existing housing shortage, Norton admits

that not everyone is a law-abiding citizen.

What theyll do is write a lease for 31 days, but theyll only rent it for a weekend, she

says. So people who are trying to legally do it will do just that; they will rent to one

person per 31 days. But a lot of other people will just blatantly disregard the rules, and

if they get caught, they will be !ned. But if they dont get caught, then theyre rolling in

money because its certainly a lucrative thing to do.

In Whistler, its not uncommon for Airbnb owners to be less than honest in their

handling of business either.

You have to be zoned for nightly rentals to rent [short-term], Van Gyn points out. I

bought my place knowing that, but a lot of people do it illegally which is a bit shitty for

properties like mine.

EFFECT ON THE COMMUNITYAs mountain town work to regulate the impact of short-term rentals, or strive to !nd

out whether they have a quanti!able impact, those who live and work in these

communities deal with not only the potential that STRs are stripping them from

potential housing opportunities, a"ordable or not, but also the impact they have on the

character and atmosphere of a place they work hard to call home.

Karen Fisher, who lived in Jackson, Wyoming, from December 2009 to May 2016,

experienced this !rsthand.

When I lived in Jackson, I lived in the Village for a little while. Almost every apartment in

our complexa 16-plex I thinkwas a short-term rental spot, she re#ects. And the two

buildings next to us, the same sort of deal. Everyone knew their actual neighborsthe

people who lived therebecause there were only maybe six permanent residents in

what? 48 apartments? The rest were all rentals and Airbnbs. Our next door neighbors

were these Texans who came once a year but rented the unit all year long.

At one point, with the workforce housing market as bad as it was, Fisher had no other

choice than to live in a garage. For Fisher, it was more than acceptable compared to

other options, or lack thereof, the city had available.

The garage wasnt bad, she admits. It had running water, a washer, dryer, sink, wood

Whistler – like Jackson, Summit County, and so many other mountain towns – is

no stranger to workforce housing woes, and short-term rentals don’t appear to

be helping. | PHOTO: Scott Serfas

https://i0.heartyhosting.com/www.snowboarder.com/wp-content/uploads/2019/01/36-whistler-scott-serfas-03.jpg

burning stove, and even a bathtub. It wasnt very energy e$cient though. Cold as hell in

there.

For Fisher, STRs meant trading a once supportive community for a revolving door of

vacation-minded visitors. While it can be argued that mountain towns only exist

because of the tourists they host, in a place like Jackson, where the majority of the

workforce makes 80% less than the median income, that idea becomes a hard pill to

swallow.

A sense of community didnt exist for me in the Village, she says. Theres something to

be said about having neighbors to help each other out, which we didnt really have.

And that lost sense of community was magni!ed depending on the season.

During summer, it was much busier because the renters were on their way to

Yellowstone, she adds. So typically they were older and respectful, at least. The winters

had fewer renters, but most were man-cation lets party a bunch and make loud noises

types. That was tough while working early morning shifts. I wore earplugs.

Due to the increasingly impossible task of !nding housing and slipping sense of

community, Fisher left Jackson in the spring of 2016.

The only people I know that still live there are folks who bought houses more than ten

years ago. Things dont add up. Its almost mandatory you have a trust or other source

of income to live there, or just own a condo and have it as a rental and come out

periodically on vacation.

https://i0.heartyhosting.com/www.snowboarder.com/wp-content/uploads/2019/01/help_wanted_macleod_2.jpg

WHERE DO WE GO FROM HERE?When I travel to snowboard, the inevitable question of where to stay arises. Would I

choose to book a room at a hotel or, often for less money, avoid interaction with a

front desk agent and enjoy the comforts of home while I was away?

As easy as it is to harness a crusty local attitude and point the !ngers at short-term

rentals, one thing is certain: they arent going anywhere. And for those of us in the

snowboard community, wed be lying if we didnt acknowledge the bene!ts they can

providewhether its earning some extra income while out !lming, or having a

comfortable and a"ordable place to stay during the course of our winter travels.

But even without directly quantifying the impact short-term rentals are having on long-

term mountain town housing, its safe to say they arent helping. Housing shortages are

increasing at exponential rates, and unless communities and individuals take initiatives

to !nd solutions, the e"ects will be dramatic.

In my home of Winter Park, the town has already constructed a 38-unit workforce

housing complexone of those units fortunately belonging to myself. Theyve also

broken ground on a 27-unit, 104-bedroom complex through a long-term lease with

Winter Park Resort. This new relationship between the resort and the town will prove

vital in providing adequate housing for local employees, both at the resort and

throughout the rest of the community.

In nearby Summit County, numerous projects are either completed or underway,

according to Dietz. The town of Silverthorne has broken ground on 200 workforce

housing units, with 60 of them set to be available before this upcoming winter.

Neighboring Keystone has 66 single family homes in the works, and Breckenridge, in

addition to having recently wrapped up a project that provided 52 townhomes and 30

apartments, will also have another 18 units becoming available in the coming months.

Where once was “For Rent” signs, now are “Help Wanted” signs in their place. |

PHOTO: Tyler Macleod

Jackson is even making signi!cant strides. According to Norton, the community

approved a comprehensive plan in 2012 with the goal to house 65% of the workforce in

town. Currently, they are at 59% and trending in the right direction. In addition to 28

units recently available in August, another 90 are expected to open up within the next

year and a half. Jackson is also in the process of constructing 125 additional rental

units, and while not all of them will be restricted, they will hopefully assist in driving

rent down.

On an individual level, it could mean picking up another job for the time beingmaybe

even cleaning some short-term rentals on the sideor !nding a less-than-preferable

place to call home for a bit. It might not be as cheap and easy as it once was to live in

these places, but If youre committed to snowboarding, youll !nd a way to make it a

reality.

All the people I know will make it work somehow or another, says Fowler. If they really

want to snowboard, theyll either live in their car or stay on peoples couches. Airbnb is

de!nitely making it harder to live in these places, but no matter what, Ive realized were

all going to make it work one way or another.

And no matter how frustrating the housing climate becomes, I promise you that

ironing wax will always beat ironing a shirt.

The Town of Winter Park has taken strides in addressing the growing shortage of

workforce housing options with a number of projects currently underway. |

PHOTO: Tyler Macleod

https://i0.heartyhosting.com/www.snowboarder.com/wp-content/uploads/2019/01/workforce_housing_project_macleod.jpg

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#mountain town housing crisis #robin van gyn

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Only people can prevent conflicts with bears. Please do your part to protect your home and property, and prevent conflicts with bears.

Keep Bears Outn Many bears that enter homes do so through an unlocked or open window or door. Close and lock all bear-accessible windows and doors when you leave the house, and at night before you go to bed.

n If you must leave downstairs windows open, install sturdy grates or bars. Screens don’t keep out bears.

n Keep garage doors and windows closed and locked at night and when you’re not home. Don’t leave your garage door stand-ing open when you’re not outside. Install extra-sturdy doors if you have a freezer, refrigerator, pet food, bird seed, or other attractants in your garage.

n Keep car doors and windows closed and locked if you park outside. Make sure there’s nothing with an odor in your vehicle, including candy, gum, air fresheners, trash, lotions and lip balms.

n Bears are great climbers — remove any tree limbs that might provide access to upper level decks and windows.

n Replace exterior lever-style door handles with good quality round door knobs that bears can’t pull or push open.

n Put on talk radio (not music) when you leave home; the human voice startles most bears.

Get Rid of Attractantsn Bears follow their super-sensitive noses to anything that smells like food, and can follow scents from up to five miles away.

n Don’t leave trash out overnight unless it’s in a bear-proof enclosure or container. Obey all local regulations.

n We recommend feeding birds only when bears are hiber-nating. If you want to feed birds when bears are active, please review the Attracting Birds, Not Bears fact sheet on our website.

n Don’t store food of any kind in an unlocked garage, flimsy shed or on or under your deck.

n Don’t leave anything with an odor outside, near open windows or in your vehicle, even if you’re home. That includes scented candles, air fresheners, soaps and lotions.

Teach Bears They’re Not Welcomen If a bear comes into your yard or close to your home, do yourself and the bear a big favor, and scare it away. A confident attitude plus loud noises like a firm yell, clapping your hands, banging on pots and pans or blowing an air horn sends most bears running.

n If a bear enters your home, open doors and windows and make sure it can leave the same way it got in. Don’t approach the bear or block escape routes.

n Never approach a bear. If a bear won’t leave, call your local CPW office. If a bear presents an immediate threat to human safety, call 911. Visit www.wildlife.state.co.us/bears for more information or call your local Colorado Parks and Wildlife Office.

Please Do Your Part

to Keep Bears

Wild

C O L O R A D O P A R K S & W I L D L I F E

Bearproofing Your HomeHelp Keep Bears Wild

Colorado ParKS & Wildlife • 6060 Broadway, Denver, CO 80216 • (303) 297-1192 • www.wildlife.state.co.us/bears

© JOHN DERYCH

C O L O R A D O P A R K S & W I L D L I F EDeterrents Can Teach

Bears to Stay AwayHelp Keep Bears Wild


Bears are always on the lookout for food sources. Like most animals, bears are interested in finding the most calories they can for the least amount of work. Every calorie a bear can save is a calorie that can help it fatten up and live through the winter. Bears that have been rewarded with an easy meal for poking their nose into someone’s bird feeder, garbage can or garage will often investigate any similar food sources in their home range. Sending bears on their way empty-pawed helps protect your home and property, and teaches the bear a lesson that could save its life.

Deterrents can be useful in areas where bears have already learned that where there are people, there is usually easy-to-get-at food. The purpose of a deterrent is to make your home less attractive and persuade an exploring bear to move on.

The best deterrent of all is to make sure there’s nothing at your home or on your property to attract bears in the first place, so be sure to review our Living with Bears brochure and fact sheets for bearproofing tips.

Electronic DeterrentsMotion activated lights, noise makers and alarms

A bear may be sufficiently startled by flashing lights, noise makers, alarms and sprinkler systems to leave the area the first time, but if nothing else happens to reinforce the experience, studies show,

like most wildlife, bears will learn to ignore these type of devices, quickly figuring out they’re all bark, no bite. Still, the commotion can alert you to the presence of an intruder of some sort. If you’re reviewing options, products that randomly produce a different noise each time they’re activated or have lights that flash in different patterns may be more effective than something with a single repetitive sound or a light that simply comes on for several minutes.

Radios Leaving a radio tuned to a talk show can make it sound like someone is home and may persuade bears to leave the area. It’s the human voice that does the trick; music doesn’t seem to have any effect. If you’ll be gone for an extended period of time, you can put a radio on a timer. Some people have found this to be an effective technique in chicken coops as well.

Scent DeterrentsA bear’s nose is 100 times more sensitive than a human’s. If you find bleach or ammonia fumes unpleasant, you can imagine what they smell like to a bear. Bleach or ammonia-based cleaners are good for trash cans and other areas where strong scents could attract bears. Some people have had some success with covered buckets or other containers filled with bleach or ammonia, with holes punched in the lids to let the scent out, placed outside bear-accessible doors and windows. Bears also dislike the strong scent of pine-based cleaners, but avoid using anything with a fresh, lemony or fruity smell. And never mix bleach and ammonia; the combination produces fumes that can be deadly to both people and bears.

Warning: Ammonia Can Blind BearsSome sources recommend ammonia-filled balloons covered with honey or peanut butter as a deterrent; theoretically when the bear tries to bite the balloon, it gets a face full of ammonia instead of a treat. But an eyeful of ammonia or bleach is more than a deterrent – it can seriously injure or blind a bear.

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Bear Spray is Not A DeterrentBear pepper spray is meant for defensive use in a close encounter with a bear that has escalated into a charge. (See Hiking and Camping in Bear Country for more information on bear spray and bear encounters) Unfortunately spraying bear spray on things you’d like bears to avoid doesn’t work — when the spray dries, the pepper residue left behind mellows out and creates odors that can actually attract bears.

Barrier DeterrentsOrdinary chain-link, wood or vinyl fencing won’t keep out bears. Bears are great climbers and can easily scoot up and over fencing if there’s something on the other side they really want. Black bears are also good diggers and can tunnel underneath fencing as well.

Enclosures

If you can’t store your garbage inside a sturdy, locked building, a heavy-duty chain-link fenced enclosure with a chain-link “roof,” concrete pad bottom, and locking (not latching) gate can help keep out your average bears — but smells will still attract them, as well as other wildlife, so you will need to be extra vigilant and make sure there are no other food sources around.

In areas with high bear activity, it’s better to secure trash inside the house, in a sturdy locked garage, or specially constructed outbuilding with concrete or cinder block construction with heavy duty wood or steel doors and roof. Sides need to be flush with the ground, with no more than a 2-inch gap at the bottom of the doors. Ventilation holes should be kept to a minimum and covered with heavy-gauge steel mesh.

Electric Fencing A properly installed and maintained electric fence is an excellent bear deterrent, and proven to be effective at turning back bears. Electric fencing can be used to protect gardens, fruit trees, livestock pens and even campers, trailers and vacation homes. It’s important to check local regulations to see if electric fencing is permitted in your area, and to read and follow all of the manufacturer’s installation requirements and directions. You’ll find detailed information on how to install an electric fence on our website.

Unwelcome Mats

SOME PEOPLE USE ROT RESISTANT CEDAR FENCING TO CONSTRUCT UNWELCOME MATS.

Unwelcome mats are typically made of sheets of sturdy plywood that have been carefully studded with small nails pointing up that can be placed in front of bear-accessible doors and windows. They’ve been shown to be very effective at deterring bears, and are sometimes used to protect summer and vacation homes when owners are away. Unwelcome mats can also be used on a temporary basis if there is a bear active in your neighborhood. It’s very important that unwelcome mats be made, installed and used properly to avoid injuring bears or human or canine visitors.

For more detailed information on creating you own mats, see the fact sheet Unwelcome Mats.

Please Do Your Part to Keep Bears Wild

Visit www.wildlife.state.co.us/bears for more information or call your local Colorado Parks andWildlife Office.


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Home Audit Checklist

TRASH & RECYCLING See “Bear-proofing your Trash” Fact Sheet

Situation Ways to Bear-proof Curbside Pick-up � Only put trash out the morning of pick-up

� Bring cans back inside before dark

� Disinfect cans regularly with ammonia or bleach cleaners (pine scent is ok – no fruity or lemon odors)

Take to Dump

No change needed

Community Dumpster � Is it bear-resistant?

Storing between pick-ups or trips to dump

� Bear-proof container outside

� Bear-proof enclosure outside

� Inside your home or a sturdy, locked building

� Freeze smelly garbage

Bears are attracted to odors of all kinds. Human garbage smells great to a bear and is loaded with easy to access calories. Keeping bears away from trash cans prevents many serious problems for people and bears.

FEEDING BIRDS See “Attracting Birds, Not Bears” Fact Sheet

Situation Ways to Bear-proof � Don’t feed birds at all No change needed

� Feed birds only while bears are denning (Nov.-March)

No change needed

� Feed birds while bears are active (April – October, not advised)

� Bring all feeders in every night before dark and clean-up any fallen seeds, hulls, sugar water, etc.

� Hang feeders out of reach – 10 feet off the ground and 10 feet from anything bears can climb

Songbirds (seed or suet) � Clean up seeds/hulls daily

� Use hull-less seed or choose quality seed without millet

� Replace feeders with a small bird bath or water feature � Plant flowers/plants that attract songbirds

� Hang birdhouses or install nest boxes

Birdseed Storage � Inside your home or airtight, bear-proof containers (plastic totes and deck boxes are not bear-proof)

Situation Ways to Bear-proof Hummingbirds � Plant flowers that attract hummingbirds

� Use hanging baskets with flowers that attract hummingbirds

Birdfeeders are full of high-calorie food bears love and they provide lots of energy for very little effort. Some studies show over 80% of human-bear conflicts can be traced back to a bear’s first encounter with a birdfeeder.

ACCESS TO YOUR HOME: Can a bear easily walk into your home? Break in? Most “break-ins” are the result of a bear entering through an open door or window. See “Bear-proofing your Home” Fact Sheet

DOORS

Situation Ways to Bear-proof Lever or Push-style Doors � Doors are locked at all times when bears are active

� Replace lever knobs with round door knobs

Sliding Doors � Close and lock door, not just screen, at night and when you are away from home

Doors with Round Knobs � Though more secure, still should be locked at night and when you leave home, especially glass-paneled doors

Pet doors � One-way, radio-activated, or locked from bedtime to morning

WINDOWS

Situation Ways to Bear-proof Ground Floor Windows � Windows closed and locked at night and when away from

home

� Kitchen windows have curtains or shades drawn at night

� Decorative grates installed

Second/third Floor Windows � Tree limbs trimmed to keep bears gaining access or treat as ground floor window

� Windows with deck or overhanging roof access – treat as ground floor window

� Never leave anything that smells near windows

OTHER � Play talk radio when not at home and/or utilize other deterrents (see “Deterrents” Fact Sheet)

OUTBUILDINGS AND PROPERTY

Situation Ways to Bear-proof Garage/Storage Buildings � Close doors at all times when not in immediate area

� Lock doors and windows at night and when leaving your property

� Replace latch-style locks/lever handles with round door knobs and sturdy locks

� Replace single-pane windows with double pane or install grates

� Block potential denning sites under decks and buildings

Refrigerator/Freezer � Relocate attractants and food of any type, including canned goods, to a secure area of house; a sturdy, locked building; or bear-proof garage

� Replace panel doors with solid wood or metal doors

Barbecue Grills � Burn-off food residue and clean grease can after each use

� Store inside a sturdy, locked building (except propane)

Hot Tub Covers � Use an aluminum cover or sprinkle cover with garden lime (or any alkali) and then place a tarpaulin cover over it

Petroleum Products (like gas, oil, grease)

� Safely store in locked building or in airtight, bear-proof containers

Citronella Products � Avoid citronella products, as they can attract bears

VEHICLES

Situation Ways to Bear-proof Garage � Park inside sturdy garage that is locked at night

Outside/Car Port � Interior is kept clean; never leave food, packages or coolers inside or in the trunk; and only use unscented or pine-scented air fresheners

PETS

Situation Ways to Bear-proof Supervision � Cats are indoors at all times; dogs are supervised when

outside, especially at night

Feed pets inside

No change needed

Feed pets outside (not advised) � Bring pet dishes in every night and keep area clean and free of food (placing on a rubber mat can make this easier)

Pet Food Storage � Store pet food inside a sturdy, locked building in airtight containers (plastic totes and deck boxes are not bear-proof)

GARDENS AND LANDSCAPING

Situation Ways to Bear-proof Berry bushes, fruit-bearing trees, and gardens

� Remove fruit trees/berry bushes if near home

� Pick fruit before it ripens and pick up all fallen fruit immediately

� Pick garden vegetables as they ripen and avoid planting potatoes and root vegetables

� Avoid using blood meal and fish fertilizer in gardens

� Protect single fruit trees and vegetable gardens with properly installed electric fencing

� Install motion-sensitive outdoor lighting

Compost � Bear-proof enclosure

� Enclosure with electric fencing

� Never compost meat, fish, oil, grease or dairy products

Landscaping � Lawns mowed and weeded (dandelions, clover and grasses are natural food for bears)

� Keep little brush (shrubs, bushes, tall grasses, etc.) around house and walkways (bears could use as cover)

LIVESTOCK

Situation Ways to Bear-proof Protection � Lock livestock inside a sturdy barn or electric

fenced enclosure at night (Advised)

� Use guardian animals (e.g. dogs) to protect livestock

Breeding � Animals about to give birth held in a secure enclosure or protected by an electric fence

� Remove afterbirth and store as you would garbage (see “Trash & Recycling” section) until you can dispose of it

� Keep young animals in protected area

Deceased Livestock � Remove dead livestock once cause of death has been investigated and loss has been documented for insurance purposes; don’t bury, as bears will locate and dig up

QUICK POLL from the Clear Creek Forum (As of Sept. 7, 2021)

Do you think short term rentals are good for the community? Yes! the bring in business and spur the economy! 64% No they take up much needed housing stock 15% Yes they give homeowners ways to make money 10% No, they attract noisy renters and are difficult to manage 11% Total Votes : 91

Clear Creek Forum Question: Would you be in favor of limiting STRs to homes of primary residents only? (As of Sept. 7, 2021)

Yes: 4 No: 5 Responses: Yes. I have 2 duplexes on my block that are STRs and the people are always out of state and never here to deal with issues.

RJ 9 days ago

yes, we need the owner to be around for any issue and respond. At Silver Lake we have many STR apartments. None of the owners reside in the building. Often we have to contact them via email to report loud and noisy guests they have. I prefer the owner od SRT reside in the same building.

baboli43 10 days ago

Yes I would be in favor of limiting STRs to homes of primary residents only and with strict enforcement of appropriate permitting and taxation measures. There are at least 5 full time STR homes in my vicinity all of which are non-compliant. There should be appropriate enforcement staff hired. These STRs regularly cause issue as the guests are not monitored and often act in direct violation of County Directives. This causes concerning safety issues for primary residents. Much like the national parks are restricting and registering visitors we need to engage better management of the STRs. At high elevations in rural parts of the county, Clear Creek lacks the infrastructure for an abundance of unmanaged STRs with regard to Road and Bridge, Fire, and other Emergency Management Services. Most of the STR users in my area purchase supplies "down the hill" and do not contribute any financial benefit to Clear Creek County. If these homes were available as long term rentals I expect there would be a clear benefit to the County financially as well as offer a reasonably priced dwelling for a worker that could otherwise not afford to purchase a home to come to Clear Creek County. There is an obvious increase of "homeless" persons dwelling in cars and tents in rural Clear Creek County and these persons being availed of appropriately priced LTRs would benefit the Clear Creek County Community as a whole and provide a needed increase in local workforce.

mcmiles 10 days ago

I rent my home 50% of the year and live and work here when it's not rented. It's my primary residence. Having STR's Improves the neighborhood. I believe that buyers, investors and builders, with the intention of making it a STR should be allowed to do so. Limited to 6% of the number of residences in the district. The problem is not STRs it's not have enough lower income housing is it is in all mountain towns.. If the goal is to make STRs into long term rentals it won't work-most workers would not be able to afford the monthly cost. As someone said in the meeting last night-I agree that the town should set aside land to develop low income housing and apartments. Buying up the run down motels and converting them to three or four story apartments.. I'd like to participate with the design and construction of those.. Best, William Wunderlich Wunderlich Design

William Wunderlich about 2 months ago

No. Let alone that governments should not be overly restrictive to the use of private property, my honest question would be "why?". Reading Bob and Linda's comment upsets me that the county may be collecting fees and not actually enforcing any of the regulations. It would be disheartening not to have direct contact with your neighbor in such instances. If memory serves, one of the regulations addresses this; where direct neighbors are supposed to be informed and supplied with the contact information of the manager of the STR. Residents should be encouraged to contact the homeowner/property manager when experiencing problems with guests of the homeowner. If STRs are too noisy, enforce the regulations around noise and write regulations around punitive measures if homeowners ignore repeated attempts to control the premise. Up to and including forfeiture of a permit. If STRs are driving home costs higher or increasing demand, this is good for the county and its residents (especially other homeowners!). Anyone under the employ of the county would also surely benefit from a pay raise given that there would be more money from taxation. If STRs attract folks from out-of-town, then there are more people spending more money in our county. If STRs attract new builds, then our county is growing and this is good. Right? If STR managers are unresponsive to repeated attempts to comply with regulations, then we should regulate some punitive measures that can be taken in equal response.

If STRs spoil the plans of corporate hospitality management companies, this is competitive capitalism at its finest in my opinion. Giving consumers the choice on how to spend their money. If there are more reasons that this should be considered, then I think we should also hear those so they can be directly considered. Don't forget that STRs generate income for folks other than the STR owner.

zvgriffin about 2 months ago

No. This is a trojan horse for people that want to rid their neighborhoods of Short Term rentals. I personally do not stay in any short-term rental where the owner of the property is in the next room or upstairs. I would rather stay in a hotel if that was going to be the case. I like to stay in unique properties that I would not normally get to stay in. There are very few short term rentals where the homeowners "live" on the property as a primary residence. Counties that have enforced this were trying to find ways of eliminating STR by people who are misinformed about STR and choose to ban them rather than enforce sensible limitations to them. People who come from out of state and buy vacation homes and rent them out not only pay the same amount in property taxes as the person living there but actually pay more in lodging tax. Income is claimed on tax returns and Federal, State and local income tax applies. Occupants of these short-term rentals spend money locally as well. STR are a win, win, win for everyone except the hotel lobby and crumungeon, angry neighbors.

thandocalrissian about 2 months ago

Personally, I would absolutely not be in favor of this, and it would be devastating for families who already purchased second homes in the area. We own a second home in Clear Creek County, and we purchased it to frequently enjoy the mountains as a family with young children and be a member of the community, until a point when we have the ability to move to the area full-time. We use it as often as we can, and the main reason it is viable is because we can rent it while not in use; however, it is not a "for-profit" operation by any means. I support and follow all applicable laws and regulations, pay for my permit, and we are boosting the local economy every time we rent it out since those people are often eating local, buying local goods, and paying for activities in the local community. It would be certain that, if this were implemented, I would NOT rent it long-term. It would simply sit idle while we were not using it and bring in no money to the local economy; it would put significant financial strain on us, but we would do it because we love being in the area. I would bet this is a common case with owners of STRs in this county, since it’s not necessarily as “touristy” as Summit, Eagle, Grand, or others; we didn’t buy this home to make profit off tourism rentals. A potential option may be to limit the number of homes a single individual or entity could get STR permits for, essentially restricting a larger "for-profit" business from owning and operating more than a few rentals. At a minimum, current owners who are not full-time residents should be grandfathered in, if the intention is to discourage further people from purchasing a home strictly for STR. That being said, I think getting rid of STRs

other than residents’ homes would be a significant negative impact to the local tourism economy as tourists would simply find STRs in nearby places like Summit County or Grand County instead; many people don't want to stay in a hotel and are looking for a different experience that only a STR can provide, especially considering COVID and the future of tourism from its effects.

MTB22 about 2 months ago

No I would not be in favor. It would drastically lower property values and hurt local businesses and tourism.

rdatteri about 2 months ago

We are completely in favor of this idea as a start. The owner of the short term rental next door to us lives in Florida and uses this property exclusively for a rental. We have asked the County several times to verify if he is in compliance with the County regulations regarding having the proper inspections and paying for the proper permits or paying sales taxes. We have never heard back and we believe that our County has many more STR's that are in operation that the county doesn't know about that are not regulated. Even though our preference would be to not allow STRs at all we urge the County to at least do a better job in enforcing the regulations on the ones that do exist.

Bob or Linda Seavey about 2 months ago

YOUR IDEAS from the Clear Creek Forum What would you like the County Commissioners to know about your opinions on Short Term Rentals?

(as of Sept. 7, 2021)

Statistics and enforcement are key If the county would like to convince citizens of negative effects of STRs, then show how the roughly 140 STRs affect the 10,000 residents of CCC with true statistics. If the property values are going up, this cannot be considered a bad thing for the county or its residents. Enforce current regulations for noise complaints or homeowners operating out-of-compliance to ensure the safety and noise are kept under control. Ensuring that current regulations are even followed should be the next step in engaging the community's concerns.

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For those of us who have had quiet and privacy up here for years and years.... Try having an adjacent property (not acres, but a distance being a matter of feet) become a noisy airbnb that keeps neighbors up at night and causes bear attraction as well as traffic problems... and unsafe smoking during fire bans. Loud parties, poor behavior... Operates with no permit. Most of these issues could easily amended and are by other STR owners nearby, but the owner of this one (out of state) won't enforce and doesn't seem to understand these issues. County has limited ability to enforce. The other issue is that we are getting more crime up here. I'm not saying STRs cause it, but what used to be a very untravelled area is now known by a plethora of strangers.

Affordable housing If the concern is affordable housing, are the 140 STRs really a problem? Would they be affordable houses that people struggling with housing could buy? Generally they are higher end houses so I doubt that's the case. Other programs that would encourage development of lower income housing would better serve the county.

Short term rental makes it possible for family reunions. Otherwise not possible to pay taxes, water, gas, electricity and maintenance.

Short term rental essential to keep house in the family.

STR friendly County STR add quite a bit of value to property values. It adds revenue for tax rolls, and tourism from people visiting Colorado. Many of these people would have stayed in Denver. Being a STR county closest to Denver is very valuable to our county

One of the things that has most impressed me about STR’s is how much the local economy is impacted by people coming here. Since the mine closed, tourism is our counties biggest industry. We should do what we can to help it.

The existing codes regarding STR is great! The problem, making sure that all properties are permitted and meet safety codes.

Clarify this carefully On behalf of CDOT, we have no comment on general short term rental (i.e. AirbnB, VRBO, etc) HOWEVER - clarify what type of traffic & vehicle parking is needed such as: Are there 5th wheel, RV campers or possibly construction equipment (owned by a short term contractor) that will not fit in the designated off-street parking areas and what assurance will CDOT have that parking on state highways will be monitored, prohibited and controlled? Sometimes large homes / lodges are rented with multiple parties arriving with a need to park their vehicles - parking instructions must be part of the rental.

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A map of allowed parking on the property for STR is one of the requirements the county approves in the permit process.

no more regulation on STR I don't know one person in Clear Creek County that thinks capping or reducing the number of STRs is good for the people who live here.

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Here's one. Me. Until the county can effectively enforce QUIET and safety (such as trash attracting bears or smoking during fire bans).... as well as the impact of visitors not having proper vehicles and getting stuck in the middle of our neighborhood roads or parking in front of mail boxes.

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I do. The Airbnb across the street from me frequently has large parties. Cars blocking the road, beer bottles and other litter scattered around and loud music all night. Not sure how any Clear Creek resident thinks this is good for our community.

No more regulations on STR's It isn't going to help the county to create obstacles for homeowners to rent out their home or part of their home. Some residents are able to keep their homes here only thanks to the rental income they get from STR's. LTR's are a different animal for a homeowner and as the owner of that property and the one with the sole financial responsibility and liability over that property, it ought to be their right to decide which type of rental is going to work for them. Those who have rental properties as second homes or as investment properties will either be able to pay to make the obstacle go away or they'll decide this county isn't worth the hassle and they'll leave, taking their tourist business with them. Those are usually the high end mountain homes that an average local won't be able to afford anyway. Less tourists means less money because it's our primary source of revenue aside from the taxes you get from homeowners. Whatever revisions you're looking to make to "ensure a more stable supply of housing for long-term residents and employees who work in the County" the homeowners in this county shouldn't bear the brunt for the housing crisis, which is happening everywhere, it's not just us. Nor should our local homeowners end up in a predicament because you're trying to control the owners of second homes and investment homes in hopes a local could rent that property long term or buy it. The cost of living vs. wages problem and the problem of more people than homes is much larger than the the issue of some STR's around here, which by your own admission has remained steady even as the housing crisis skyrocketed. You're looking at the wrong thing.

Currently active STRs If any changes are implemented in the future would current STRs have a grandfather clause? I personally have put in tens of thousands of dollars for the sole reason of being able to operate a rental AND regularly visit and promote the area myself. If I had to hold the property, pay fees and taxes on it, only to use it sparingly myself I would not be able to afford it and be forced to sell. Would the county cover the losses of people that have just recently invested in CCC property for the same reason?

I'm all for regulations! Short term rentals especially up in St Mary's provide more jobs than you'll ever know.

Short term rentals are a fundamental right of property ownership. We live in Clear Creek County because we want to live here, not Evergreen

No guarantee on home buyer I have built and sold four homes in the last few years in Clear Creek. Every house was purchased by couples living full time. All of them have full time jobs. Of those eight, NONE work in Clear Creek County. The shortage of housing, especially low income, is not related to STR. I am not finding another discussion on what the county can actually do for the housing shortage. Does one exist? Perhaps property tax credits for owner occupied new homes? More funding to the building department so permits don’t take 3-4 months? Does the county own any land In unincorporated Clear Creek that they are looking to develop low income housing on?

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If you have been a landlord it’s no secret that locals are not the best tenants ( a lot of dregs) and advertising for tenants out of Denver gets better tenants and rents. STRs make the best money but it is a different animal with more work being in the de facto hospitality business. STR s are just an easy scapegoat for a complicated problem going on all over the country. The economy has been on the bubble and defying gravity for quite a while now. This market could change in the other direction almost overnight as it has done before.

I am preparing to sell Mini Modulars as one part of the solution, starting with 400 sf cabins expandable to about 1100 sf . That is just one niche. I hope the County can help me. The current affordable housing approach, subsidized apartments, still keeps people in bondage with no future equity to escape from it.

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Limiting STR as a way to develop more long term rentals does not make sense to me. I do not use my property in St. Mary's as any type of rental, but I am an experienced landlord in Denver. If I wanted to rent my 600 sf cabin in St. Mary's, I would need to set rent at approximately $1,500/mo. to break even. That, of course, does not factor in an anticipated property tax increase or any profit for me. There is no way I would even consider using this property as a long term rental given my current costs and the associated risks. If I did, it certainly would not meet the definition of affordable housing. I do see the need for more affordable housing in the county, but attempting to convert STR into long term rentals is not a viable solution. Perhaps the county could consider ways to speed up building permits for those interested in building and develop relationships with developers who might be willing to build additional affordable housing rental units within the county. Another thought would be to develop some type of HUD grants to revitalize trailer homes and neighborhoods currently in place to make them a more attractive (and affordable) option. Also, exploring the idea of tiny homes or container homes could be an affordable option in some parts of the county.

STRs are great when well operated, but they are commercial properties and should be treated as such in taxes, regulations, & zoning. STRs are businesses

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I agree with this! Then, it will give us more stabilty as property owners. They can't remove our property status.

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STRs pay lodging and sales taxes to the county just like any hotel.

Enforce the existing rules for Airbnb and VRBO The Airbnb across the street from me frequently has large parties. Cars blocking the road, beer bottles and other litter scattered around and loud music all night. Not sure how any Clear Creek resident thinks this is good for our community.

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There is a neighborhood support option through Airbnb. You can complain about these disturbances for Airbnb to handle as well.

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I am an STR owner and if what you are saying is accurate then I agree that this is not a responsible STR owner and should be ticketed etc. However, one bad apple shouldn't indict us 99% responsible owners.

Some simple math The average home price in Clear Creek County is around $436,000. Source: https://www.zillow.com/clear-creek-county-co/home-values/ 30 year mortgage/taxes/insurance assuming 20% down on a $436,000 home equates to about a $2,300 monthly payment. If I were an investor looking to rent this home as a long term rental I would need to account for vacancy, maintenance/repairs, capital expenditures, etc. So in order to simply break even on this home I would need to rent it out for around $2,700 per month. Is this affordable? Who is going to pay that rent and commute to Denver for work? Furthermore, the renter would be responsible for the $200 water monthly fee, utilities, internet, their own snow removal etc. So we are looking at over $3,000 for the end consumer/renter to be out of pocket per month. Banning short term rentals is not a solution to affordable housing and anyone who uses affordable housing as their driving force for changing STR rules should just do the simple math.

Clear Creek County needs tourism dollars Over-regulating STRs can be tricky and likely harmful to the local economy should they not account for the fact our County needs tourism dollars, and wiping out the lodging supply will drive tourists outside of the county. I am for well thought out regulations that soley keep safety in mind, however the owner-occupant regulation that is being considered would wipe out lodging supply and is not fair to owners who purchased STRs prior to all regulations. This is not one size fits all---we are different than many other countys/towns in that we are now and will more greatly in the future be dependent on tourism tax dollars.

Short Term Rentals are COMMERCIAL uses Short Term rentals are commercial uses and for profit businesses and should not be allowed in residential or any areas where commercial uses are not zoned. Want to run a business? Great - do it where businesses are zoned. They may not be the #1 culprit to the housing crisis but they certainly are a part of the problem.

Two separate issues STR are a great source of revenue for CCC! Don't force those funds to go elsewhere, as well as the jobs the STR market provides. Address the affordable housing issue and keep STR as it is. These are two separate issues!

One size doesn't fit all I echo the comments about grandfathering in those STRs that were operating before any forthcoming regulations. STRs have served CCC well if you look at the economic data thus far. Any changes made for future STRs should simply ensure the peace and safety of the community are protected, all on a case-by-case basis.

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Limit the number of STR in areas. Donkey be like IS, There are about 5 in the 2 blocks east & west of my house.

Grandfather in current permit holders I understand concern with taking away long term housing for individuals and families, but if the county approved short term rental permits for specific properties, those properties should be grandfathered in for permit renewal in the future. We rent out a suite of the house we live full time in, so no housing is removed as options from the community. Massive investments have been made since gaining the permit in 2020 to run as a short term rental property which would not have been made otherwise (linens, finishing out a kitchenette, furniture, outdoor grilll/furniture, decor etc). We now depend on this income so one of the adults in our home are able to stay home with our young child. We will host about 70 different families over the course of the year which would not have likely stayed in the area and gone out into the community to support local businesses. We created social media profiles to highlight all local community events in the area for visitors to go out, and again, support the local economy. We continue to

follow all the rental rules set by the county, while maintaining a perfect 5 star review through Airbnb. Our neighbors love us having the rental suite because they have additional arrangement options when family comes to town, and they aren't required to travel far for a hotel option. If a decision is made to restrict permits in the future, please take the following into consideration: -limit permits to one per individual/company which would reduce risk of investors coming into the county and buying multiple properties for short term rental use -grandfather in individuals that have already secured permits in the past if all requirements are met for future years -give priority of permits to individuals who rent out a suite of their home vs an entire property as no additional housing options are removed from the community

IF they are going to replace our residential need for long term housing, recognize them as businesses and they pay commercial property tax Be Fair with Residents

Hard and fast statistics on how many in any area. Not neighbors willingness to accept but 1 per 100, or 2, 3, whatever. Limit Their Density

The proposed rules make sense. Owner occupied units have no negative impact on housing availability.

More regulations will not help housing crisis. Please keep current STR regs, do not change. #1. If changes are made, please grandfather in all exisiting accounts. This is a substantial income for many residents. #2. Housing is so expensive, it kind of solves the problem anyway. Folks running STR need to make money and pay for cleaning expenses. It's pretty hard to do that when

you buy a 800k house. #3. What we have right now is really good. Limited, only 15 STR in the city center, etc (maybe regulate it for strictly?) Thank you for holding this forum!

Housing Stock The limited housing stock is due to the recent population explosion here in the Denver Metro Area. With offices being built on the west side of Denver and with more and more people having the ability to work from home, the demand for housing has increased in the foothills. It has NOTHING to do with short term rentals. A short term rental can help the current home owner keep their home or can help a buyer, who could not afford a mortgage, the steady revenue stream to purchase a home he/she would otherwise not afford.

Over 50% of STRs are managed by women and therefore support women.

The CDC says STRs are safer than hotels.

During emergencies, first responders along with people in serious need have access to furnished homes to stay in.

Short Term Rentals/Vacation Rentals are a residential use and should be taxed as residential properties. Residential properties are used to eat, sleep, and enjoy. Commercial properties include large parking lots, concierge services, 24 staff, housekeeping, etc. Big difference - Keep Residential properties taxed as residential.

From: Dawn BarnettTo: Frederick RollenhagenSubject: Re: AIRBNBS in Floyd Hill/Clear Creek CountyDate: Monday, August 02, 2021 11:18:50 AM

Thank you for the information. My main concern is that someone is only buying these 3properties as AIRBNB money makers. The realtor did not give me the impression they hadany intention of living at any of them. Please let it be known that I am 100% against any typeof vacation rental properties in our family oriented neighborhood. The constant in and out ofdifferent people week to week make me nervous for my future safety, privacy and security. Ifeel like my rights as a permanent resident are being violated.

Dawn Barnett

On Mon, Aug 2, 2021, 10:26 AM Frederick Rollenhagen<[email protected]> wrote:

Hello Dawn,

Thanks for letting us know your concern about what is happening in your neighborhood. Our short term rental regulations and permitting process can be found on the County’swebsite here:

https://www.clearcreekcounty.us/910/Short-Term-Rental-Permitting

Currently, anyone with a residential unit may apply for a short term rental permit, and aslong as they can demonstrate compliance with the regulations in their application, they willreceive that permit. Currently, there are no location restrictions and there is no limitation onthe number of permits that can be issued.

Coincidentally, the County Commissioners are currently considering revisions to the STRregulations. They have asked staff and the Planning Commission to consider morelimitations to who can receive a short term rental permit. If you are interested in being partof the conversation, or would otherwise like to know more about potential revisions that thePlanning Commission is considering, feel free to get on the Clear Creek Forum webpagethat discusses more about this topic;

https://forum.clearcreekcounty.us/

You can also find copies of past Agenda’s, staff reports, and Minutes that are related to thePlanning commission’s STR discussion here;

https://www.clearcreekcounty.us/477/Active-Cases

mailto:[email protected]



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Please let me know of any questions that you may have. If you have any comments that youwould like the Planning Commission or County Commissioners know, you can also sendthose to me.

Thanks very much,

Fred

Frederick Rollenhagen, AICP

Planning and Building Services Manager

Clear Creek County

P.O. Box 2000

1111 Rose St.

Georgetown, CO 80444

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From: Beth Luther Sent: Sunday, August 01, 2021 12:25 PMTo: Frederick Rollenhagen <[email protected]>; Amy Saxton<[email protected]>; Brian Bosshardt <[email protected]>Subject: FW: AIRBNBS in Floyd Hill/Clear Creek County

Gratefully,

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From: Dawn Barnett <[email protected]> Sent: Saturday, July 31, 2021 2:39 PMTo: Beth Luther <[email protected]>Subject: AIRBNBS in Floyd Hill/Clear Creek County

To whom it may concern,

I am a homeowner on Beaver Brook Canyon Rd, Floyd Hill area. My husband and I havelived here for 8 years with 2 properties across from us we assumed were abandoned, and 1that was used as a second home for vacations only. Recently there has been a lot of activity





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on the properties and we were able to speak to the realtor who is selling them for the owner.Unfortunately, even though they are not even on the market yet, he has investors who areinterested in purchasing all 3 properties to be used strictly as AIRBNBS. The idea of thisproposal deeply disturbs my husband and I. Having outside people in and out of ourextremely rural and private neighborhood on a weekly basis is not why I chose to live here. Ihave done some research about the permits required in order to have an AIRBNB in ClearCreek County. I guess my question is if there is anything that can be done in order to keepthese AIRBNBS from happening across the street from my house?

Thank you for any information you can provide.

Dawn Barnett

From: COmtnLadyTo: Frederick RollenhagenSubject: Comment on STR "quick poll"Date: Thursday, September 02, 2021 9:07:05 PM

I just took the poll and none of the answers were adequate.

I object to STR because it destroys community.

Instead of having neighbors, and people we've known for a lot of years, who careabout their lawns, and are there if there's a limb that blows down or the bear knocksover the trash, who cares about the history here, who cares about here, there arestrangers who are only here to be on vacation, not their problem if there's a limbdown, not their problem if the house gets trashed (they'll just not come back), not theirproblem. And there is also the dark empty house sitting there like a missing tooth in asad grin when its not being used. STR kills community.

Sincerely,D. PowellGeorgetown



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