HomeMy WebLinkAbout030225 email - TESTIMONY regarding proposed Short-Term rental ordinance (0002)ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them.
Commissioners,
Please accept the following as testimony regarding the proposed Short-Term rental ordinance to be considered on March 4, 2025.
Throughout, “zip code” should be changed to “ZIP code” (ZIP is an acronym, standing for Zoning Improvement Plan – see AP Style Manual et al)
In 18.20.210 (3)
“(e) Short- term rentals shall not exceed 4% of the unincorporated Jefferson County housing unit total not including:
i. Master planned resorts,
ii. Hospitality permits approved under prior regulations, or
iii Short-term rentals for less than 30-days predating hospitality regulations”
COMMENT: This appears to state that “grandfathered” STRs are not included in the 4% count. It is estimated that there are approximately 500 existing STRs, which is at least 3% of existing
houses that might be used for STRs. The additional 4% allowed by the proposed “grandfathered” exemption would allow more than 7% of houses to be used for STRs, a number which is far
in excess of the percentages used in the other locales studied, where 2% or 3% are the established limits.
RECOMMENDATION: There should be no “grandfathered” exemption. Existing STRs will have to compete for available permits on a level playing field with all other applicants. A lottery or
other system will likely be required to ensure fairness; DCD will have to work out the details (see Additional Concern, below).
“(f) Subject to the established maximum numbers of short-term rentals, rentals for less than 30 days are permissible where the land owner is a resident of Jefferson County and the landowner
or a qualified representative is in Jefferson County during the entire rental period.”
COMMENT 1: “qualified representative” is not defined
RECOMMENDATION: Add a legal definition, which should include a reference to a contractual agreement between the landowner and the “representative”.
This will need to be crafted carefully to cover arrangements with VRBO et al (the “platforms”) as well as with actual people.
COMMENT 2: “is in Jefferson County during the entire rental period” should be changed to be consistent with other sections;
RECOMMENDATION: Replace "is in” with “reside in”.
Also, “land owner” should be the “landowner”
In (8) Enforcement
COMMENT: There is no mention of the requirement for listings on “platforms” to include the Jefferson County-assigned permit number in the listing.
RECOMMENDATION: The “platforms” must be informed by the county that they are not allowed to accept listings that don’t have a permit number and that to do so would invite legal action.
ADDITIONAL CONCERN:
DCD’s role is not defined aside from a brief mention in the WHEREAS’.
DCD should be required to develop procedures for implementing this JCC, including application forms (which must be on-line, not paper), a permit fee schedule, etc. and must complete
that work within 90 days of the effective date of the ordinance.
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Thank you for considering my testimony,
Tom Thiersch
Jefferson County