HomeMy WebLinkAbout04-24-17 Public Comment -A. Kalloch -ShortTermRentalsGood evening, Mayor Taylor, Deputy Mayor Andrus, Commissioners, and staff. In anticipation of your public hearing
tonight, I wanted to pass along the attached comment/testimony of Airbnb, which includes updated statistics (current as of
April 1, 2017) and feedback on the draft ordinance.
As you will read, we believe the ordinance has many valuable provisions and we offer a number of suggestions that will
encourage compliance and effective enforcement, rendering the regulations even stronger.
Please do not hesitate to reach out with any questions/comments. We appreciate your continued attention to this issue.
All best,
Andrew Kalloch
Testimony of Andrew L. Kalloch, Public Policy, Airbnb
Short Term Rentals in Bozeman, Mont.
Monday, April 24, 2017
Good evening. My name is Andrew Kalloch and I am a lawyer working in Public Policy
for Airbnb. Thank you for your continued work on short-term rental regulation.
Before turning to our comments on the latest draft ordinance, we wanted to provide
updated updated statistics about our community of hosts and guests for the year ending
April 1, 2017.
As we noted in January, short term rentals have long been an important component of
the Big Sky economy and Airbnb is proud to be part of this tradition.
In the year ending April 1, 2017, 2,000 Montanans welcomed 85,000 guests. In
addition, 64,000 Montana residents used Airbnb to travel domestically and abroad.
The vast majority of these hosts are individuals and families who share their homes
occasionally to pay for their mortgage, medicine, and student loans, or save money for
retirement or a rainy day.
Furthermore, unlike other types of lodging, such as multinational hotel chains, 97
percent of revenue generated through Airbnb goes directly to our hosts, who plow it
back into the local economy.
As the State’s fourth largest city by population, it is no surprise that Bozeman is home to
a robust community of Airbnb hosts and users. In the last year:
●There were 300 Active Hosts who welcomed 14,000 guests to 370 listings, with
the typical host earning over $6,000.
●70 percent of Bozeman hosts are women, with the average host age being 45.
●40 percent of hosts are over 50. Supplemental income from STR is particularly
important to this population, which often struggles to “age in place” on fixed
incomes.
●The typical listing was rented for 49 nights, highlighting the fact that most hosts
are not full-time commercial operators, but instead rent out their home or a
portion of their home during vacations or other times when they are out of town.
In fact, nearly 75 percent of listings are rented for fewer than 90 days a year, with
only 6 percent of listings renting for more than 180 days a year.
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●Guests stayed an average of 3.0 nights per stay, with an average group size of only
2.4 people, showing that short-term rentals on Airbnb are primarily couples and
families.
●The average age of guests was 40.
●In addition to those who visited Bozeman using Airbnb, 14,000 Bozeman
residents used Airbnb to travel elsewhere in the U.S. and abroad.
Reasonable regulation can help foster the economic opportunity home sharing creates
for Bozeman families, businesses, and the broader economy.
The proposal put forth today includes many valuable elements, including simple
registration, clearly marked emergency information within short-term rental units, and
the designation of a local contact in the event that a host is out of town.
In addition, the proposal builds off the creative work of mid-sized cities like Portland,
Maine, which have distinguished between owner-occupied STR and other forms of STR.
While Airbnb supports many of these provisions, we offer the following suggestions to
make the ordinance even stronger and to ensure effective compliance and enforcement.
●STR Application Fee: The draft ordinance includes annual fees that will
dissuade many STR hosts from registering, potentially affecting the enforceability
of the ordinance. This is particularly true for “Type 2” STR hosts who may be
subject to annual fees of up to $475, even if they occasionally rent their home
while out of town.
As a result, we urge the Commission to revise the fee structure to improve
compliance and strengthen enforcement.
In Portland, Maine, owner-occupied STR permits cost $100, while
non-owner-occupied STR permits cost $200 in multi-family homes, with the
price rising sharply for additional permits. Furthermore, in other municipalities,
the renewal fee is significantly lower than the initial permit fee and/or the permit
lasts for longer than one year.
●STR Public Database: Airbnb values the privacy of hosts and guests. Indeed,
that is one reason how we preserve the trust necessary for people to open their
homes to one another and engage in home sharing in a safe, secure manner. To
that end, we are concerned about the provision requiring hosts to “agree to
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inclusion of the STR and the owner/responsible person’s contact information in
an online listing” on the City’s website. Hosts may have good reasons for not
wanting their names/addresses available for public view, including privacy and
security of their property.
Given that the ordinance requires neighbor notification for Type 3 rentals and the
posting of a permit number on all advertisements, we believe that the
maintenance of a City-held database is unwarranted and unnecessary.
●House Rules: We support requirements for hosts to share “house rules” with
prospective guests (including applicable local codes). However, these rules
should not be required to be sent via regular mail for a physical signature. Most
STR on our platform--and our competitors’ platforms-- involve electronic sharing
of information and many bookings take place within a week of the trip, rendering
“snail mail” transactions impractical. To that end, we believe that the house rules
provisions should allow for electronic sharing and affirmation by hosts/guests.
●Criminal Liability: Airbnb supports the provisions of the ordinance that
empower the City Manager to suspend/revoke registration for public safety
purposes. However, we do not believe that criminal liability should attach to
these violations, many of which are ministerial in nature. To that end, we urge
the Commission to modify the draft to remove the reference to “misdemeanor”
charges and maintain violations as civil offenses.
●Self-Certification: We support the staff recommendation that would allow
applicants to engage in a “self-inspection and certification process” regarding
minimum safety requirements and to operate with provisional approval until a
Fire Department inspection could be conducted. Experience has taught us that
simplifying the application process increases compliance and, in turn, eases
enforceability.
All told, we appreciate the thoughtfulness and diligence of Mayor Taylor, Deputy Mayor
Andrus, the Commissioners, and their staff, and look forward to continuing to work with
each of you to ensure that Bozeman’s STR regulations can be a model for other cities
across the country.
Thank you.
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