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Home My WebLink AboutCDN 2018-03-13 Item 2D - Discussion - Short-Term Rental RegulationsAllan Ekberg, INFORMATIONAL MEMORANDUM TO: Community Deyelopnient and Neighborhoods Committee FROM: Jack Pace, DCD Director BY: Charlotte Archer, Asst. City Attorney; Nora Gierloff, Deputy DCD Director; Minnie Dhaliwal, Planning Supervisor CC. Mayor Ekberg DATE: March 6, 2018 SUBJECT: Short-term Rental Regulations ISSUE Should Tukwila update its short-term residential rental regulations to address ADUs and single family houses? BACKGROUND In conjunction with the City's discussions pertaining to detached accessory dwelling\Jnit (ADU) n8gu|aUOnS, which began in March 2017, the City Council requested a review of the City's regulation of short-term (defined as a period of less than thirty days) rentals within the City. This review was intended to focus on the use of single-family and multi -family residences, as well as both attached and detached A[)Us, for the purpose of obtaining rental income, commonly via an online marketplace such as HomeAway, Vacation Rental By Owner ("VRBC}") or AirBnB. Anecdotally, property owners in the City are using their residential structures for both short- and long-term rentals on a regular basis (see Attachment A). The intention for this project was to review and revise, where necessary, the standards for rentals.1 . A. Existing Regulations for Short and Lona -term Rentals. Whether a particular residential building located within the City may be used as a short-term or long-term rental is determined by the regulations set out in Title 18 TMC Zoning Code. Currently, multi -family dwellings shall not be used for a rental tenancy of Iess than one month. See TMC 18.06.347. There is no prohibition on the use of a multi -family dwelling as a long-term rental. 1 Beyond the scope of this analysis are the fnUmwing, which are subject to distinct regulations: Assisted Living Facilities (TMC 18.06.058); Continuing Care Retirement Communities (TMC 18.06.178); Convalescent/Nursing Homes (TMC 18.08.173); Correctional |nstitutions, including transitional housing (TMC 18.06.178); Extended -Stay Hotel or Motels (TMC 18.06.287); Hotels (TMC 18.06.440); Motels (TMC 18.06.585); Secure Community Transitional Facilities (TMC 18.0}706); Senior Citizen Housing (TMC 18.06.708); Shelters (TMC 18.06.743); commercial properties used for the purposes of short-term and extended -stay housing, such as mote|S, hnte|o, and extended stay motels. 63 INFORMATIONAL MEMO Page 2 64 There s norestriction on1he use or long-term rental. Similarly, there is no restriction on the use of mobile home dwellings in rnobile home parks for short- or long-term rentals. Moreover, Tukwila's current standards for attached ADUs permit the DU t d n of draft Aordinance .at --_.ows _---___--`=-�ADUs has aplaceholder ^'~ rentalsless days. That could be modified based on the Council's overall decision about short-term rentals. There are other categories of uses that rmrentals, including:�'r`'' • Dormitories as "a residential building r use which provides housing for students, attending an affiliated school or housing for members of a religious order." • Boarding House defined as "a residential building which provides housingshort-term commercia basis for tenants" is a conditiona use in the MDR and HDR zones. r Bed and breakfast facilitiesdefined "an occupied 'dwelling guest rooms where lodging is provided for compensation," are permitted in the LDR, MDR and HDR zones as conditional uses (for up to twelve guests), and guests shall be limited to a 14 -day maximum length of stay. Tukwila has never received an application for a bed and breakfast conditional use permit. Two other residential uses currently not identified in the TMC may also be affected by an amendment to the City's existing regulations for short- and long-term rentals. First, adult family homes (AFH)2 could arguably be considered residential properties used for rental purposes; however, state law prohibits the City from enacting regulations that put up a road -block to the placement ofAFHs in all areas zoned for residential purposes. Second, the same analysis would likely apply to a residence used to house people with disabilities, including the recovery from a drug addiction.' B. �Existing Licensure Requirements for D TukVv|o'SResident��|Rental Business LicenseProgram,codifiedChapter5.uo su of the Tukwila Municipal Code (TMC), establishes an annual rental licensure requirement for all "units" intended for rent. Each dwelling unit must be inspected for life safety issues every four years and a Certificate of Compliance is issued by the City for those units that meet all requirements. The code is silent about whether it applies to short-term rentals. C. Regulation of Rentals byNeighboring Jurisdictions. Staff analyzed the methods other cities in Washington utilize to regulate short-term rentals to develop a proposed model for Tukwila, see Attachment B. This issue is currently being debated in many jurisdictions in Washington in light of the dramatic recent growth of major companies in the short-term rental industry, as well as the housing crisis in the greater Seattle area. 2 Adult family homes are defined by state law as "a residential home in which a person or persons provide personal care, special care, room, and board to more than one but not more than six adults who are not related by blood or marriage to the person or persons providing the services." RCW 70.128.010. See RCW 36.70.990. INFORMATIONAL MEMO Page 3 (On 1' 2017, Seattle adopted new regulations to prevent property operating short-term rentals as if they were hotels, as part of a larger effort to ensure an adequate suppl of -term rental stock for the City's permanent see Attachment C. The new -~—' regulations limit hosts to twdwelling unitseach requires aspeciallicense to operate said rentals. The City also requires rental VRBO, to obtain a special "platform license" to facilitate bookings in Seattle. In advance of adopting these regulations, the City approved a new tax on short-term rentals, again designed to prevent property owners from operating short-term rentals as if they were hotels, Similarly, in October 2017, the City of Kirkland adopted Ordinance 0-4607, which regulates rentals lasting for less than thirty days. Properties must be owner -occupied at least 245 days per year and a "Short -Term Rental Business License" from the City is required. The use of an ADU as a short-term rental is allowed for up to 120 days per year, as long as the property owner (or authorized agent) occupy the primary residence for at least 245 days per year. A property manager must live within 15 miles of the residence when residence is used for short-term rental purposes. The City further dictates terms that must be included in the rental agreement, including a provision that "encourages renters to exercise best efforts to avoid conflicts with neighbors related to issues such as noise, littering, parking and trespass." The City also requires a business license for long-term rentals, including owner -occupants with a roommate. ANALYSIS Council is being asked to set a policy direction on short-term rentals. A. Advantages of Short -Term Rentals. Given the results of Staff's search (see Attachment A), there appears to be an existing marketplace for the short-term (defined as 29 days or less) rental of single- and multi -family dwellings in the City. This is occurring despite the codified prohibition on the use of multi -family dwellings for this purpose. From a policy perspective, short-term rentals bring numerous benefits to those who operate them, their visitors, and the surrounding neighborhood. Many individuals use short-term rentals to hep afford their own home, either renting out a basement, a spare room, or the entire home when they are out of town themselves. They provide a flexible means for homeowners to earn more money than by renting out their property on a long-term basis. For visitors, short-term rentals often offer G more affordable option, and short-term rentals bring tourists and their collective spending power to Tukwila. B. Disadvantages�fP8Dn�UnQShort-Term Rentals. The rise in the use of rental properties as short-term rentals has also had negative iin communities throughout Washington. Short-term rentals can artificially inflate rental costs, and the more commercial use of short-term rental platforms has taken entire houses, condos and apartments off the long-term housing market. Some short-term rentals attract disruptive visitors, who are essentially vacationing within residential areas, and can have negative impacts on property values. Some studies have indicated some commercialized short-term rentals impact the hotel industry and the larger business community, by circumventing traditional lodging taxes. 65 66 Short-term rentals may also contribute to creating a transient community and increase parking demand in residential areas. Some of these negative effects may be mitigated by only allowing rentals of rooms within owner occupied dwellings as opposed to entire units. However, regulating the short or long-term rental of individual rooms within an owner -occupied dwelling would be a significant expansion of the Residential Rental Business License program. Additionally, without cooperation from the online rental platforms it is difficult to identify properties and enforce the current short-term rental regulations. We receive lodging tax as a lump sum and AirBnB only reports aggregate rental data, rather than by address. Currently, the City has no permitted Bed and Breakfast facilities. This somewhat antiquated form of residential use, with the rise of AirBnB and other online alternatives. The City is aware of a few Boarding Houses within the City and there are ongoing code enforcement complaints relating to un -permitted Boarding Houses in the LDR zoning district (where this use is prohibited). The existing definition of a Boarding House makes this regulation difficult to enforce, given its use of undefined terms like "short-term" and "commercial basis." Similarly, there is no cap on the number of tenants that may reside in one residential building, no requirement that the building is owner -occupied, and no other relevant regulations such as higher parking standards. C. Options. With this context in mind, the City could apt to prohibit short-term rental of all dweling units within the City, including entire single-family nesid8ncee, rooms within owner -occupied residences, multi -family residences, ADUs (attached and detached), mobile and manufactured homes, Bed and Breakfast facilities, and Boarding Houses. Alternatively, the City could permit the use of some or all types of dwelling units as short-term nanta|o, subject to restrictions such as: (1) Iimitations on the number of ease agreements per dwelling unit; (2) caps on the number of occupants per bedroom; (3) the length of time the dwelling unit may be occupied by a tenant within a calendar year; (4) require certain amount of parking stalls for the property, if used for rental purposes; and/or (5) owner -occupancy requirements. As discussed briefly above, there are additional restrictions from state law on regulations for adult family homes and inpatient substance abuse facilities. The City Attorney would craft anguage for these uses based on the overall direction from Council. FINANCIAL|MPACT Allowing short-term rentals and requiring them to be licensed would modestly increase the revenue to the Rental Housing Program. Enhanced enforcement of short-term rental restrictions INFORMATIONAL MEMO Page 5 RECOMMENDATION The Council is being asked to review Tukwila's short-term residential rental regulations, chose to allow or prohibit the different types of short-term rentals, and send the issue to the Planning Commission for a public hearing and recommendation. ATTACHMENTS: A. Results of Staff Review of Rental Listings. B. Table of Neighboring Jurisdictions' Regulation of Short-term Rental Properties C. Regulating Short Term Rentals Seattle Policy Brief 67 INFORMATIONAL MEMO Page 6 68 ATTACHMENT A Staff reviewed the inventory of short-term rental properties (as advertised on Craigslist, VRE30 and AirBnB), in order to determine the scope of the existing use of these services. A review 2017, rentalsd 35 m offered in Tukwila, including the following: Three bedroom home, for $149/night Private room in single family home, for $38/night - Two bedroom condo,for - One bedroom condo, [g85/night Studio cabin , 0' for $55/night Guesthouse (ADU), for $65/night Room in single family home with private bath, for $40/night Private room in single family house, for $56/night Private room in three-bedroom apartment, for $60/night ' Single family home, for $112/night - Detached ADU (Cottage), for $80/night Private room in single family home, for $45/night Two bedroom apartment, $120/night INFORMATIONAL MEMO Page 7 ATTACHMENT B Neighboring Jurisdictions' Jurisdiction Residences ADUs (Detached Multi -Family ,~^�^Licensure or Attached)i Requirements Alf any) Poulsbo San Juan County Permitted,Permitted no more than 34 guests per bedroom; parking required Clyde Hill Permitted, with limits on occupancy, parking, and use (for lodging only, can't be used for events) |kwaco Conditional use in single-family, zones with limits on occupancy and parking. Leavenworth Westport Permitted (attached only), max 3 guests r bedroom; parking required; owner must occupy ADU or primary residence Prohibited Relevant Code ~—~Citations " g None�� (� � ^ 18 70.070 Permitted in "Vacation SJCC Commercial Rental Permit" 18.40.270 zone only required Permitted, with limitations on occupancy, parking, and use (for lodging only, 't be used for events) Permitted use in certain specified zones Permitted, with limits on occupancy, parking, and use (for lodging only, can't be used for events) Business Ch. 5.20 License CHMC Required Permitted use in certain zones Prohibits use of entire dwellings as vacation rentals; permits short-term rental of a portion of a home when the property owner lives on-site throughout the visitor's stay with appropriate permits, including a business license Pennitted. Prohibited subject to owner- 000upanoy requirement and permitting Permitted, subject to occupancy cap, parking and other standards Permitted, but only 1 vacation rental unit per "property" Prohibited Business Ch. 15.41 License IMC Required | � ' Business License Required Business License Required LMC 18.52.120 Ch. 17.22 4 San Juan County Council is currently considering legislation to reduce this to two guests per bedroom. 69 70 71 ao Estimated Air8n8rental reviews in Scattic in July 20130oNand July 2015(bounm). Data from /nsideoirhobzom 2 72 Introduction tdti For many years, short term home rentals have been a popular lodging choice for travelers in Europe and certain high volume tourist destinations in the United States. With the advent of technology-based onlfne platforms that facilTtate the marke0ng and booking of short term rentals, this market has rapidy expanded across the giobe. One need only look at the rise of two of the mjor companies in the short term rental industry to view the incredibly fast pace of growth. Airhnb received its hrst $20,000 seed grant in 2009.' In December 2015, less than seven years later, the company conhrmed a round of $1.5 bHlion in venture capital funding, bringing its total valuation up to $25.5 biUion.z Its website now touts more than 2 million listings available in 34.O0Ocities across 191 countries.' HnmcAwaKanother vacation rental company that includes the website VRBO.com (Vacation Rentals by Owner), aunched in 2006 and also grew rapidy; the company's website states its annual revenue increased 28.9% in 2014 over the priorycac+ Previously a publicly traded company on the NASDAQ exchange. Homeaway was acquired by Expedia in late 2015 for $3.9 biUion, a price nearly 20% higher than its market value at that point.' It currently offers more than 1 million listings in 190 countries.° No evidence suggests that the growth of this industry in Seathe 5 any different. WhHe Seattle-speciflc data Has not been made publicly available by mjor players in the short term rental marketp|acc, external websites scrub Airbnb hsdngs data and aggregate the information for market analysis. These websites show recent rapid growth in the number of listngs.7 Airbnb states on its website, The number of guests using Airbnh has grown steadiy since 2009, with visitation more than doubhnD every year." '1g /oOcilo0d is O nice guy, he hos kept tile rent re/Qtive/y reasonable for me owl pity pQrfper, but he's recently informed Us yVe need to leave o few rriDnth5 hCCoUSe Scottie Benefits enefits an0Challenges of Short Term Rentals tN Short term rentals bring numerous bencfits to those who operate thcm, thcir visitors, and the surroundng neighborhood. Many individuals use short term rentals as a way to help afford their own home, either renting out a basement, a spare room, or the endre home when they are out of town themselves. In a housing market that presents affordability challenges, there is no doubt short term rentals alleviate the housing burden for the many families that operate them. For visitors, short term rentals often offer a more affordable option. Short term rentals bring iourists, wedding pondes, visiting family members and LhcircoUecbvespcndingpowcrtoneighborhoodsacross3caff|e.Airbnb recently estimated the economic impact of its visitors in Seattle was $178 million from August 2O24LoJuly 2O15.supporting 17OOiobs.n At the same time, the more commercial use of short term rental platforms has taken entire houses, condos and apartments off of the long term housing market. One external website estimates that roughly one-third of Airbnb's listings in Seattle are from hosts with multiple listings. These could be multiple rooms in a house or completely separate units; hosts with multiple listings are more likely to be commercial operators not renUng pordons of their own primary residence.9 Arecent report published by CBRE Hotels' American Research found that 79 percent ofAirbnb's revenue in Seattle comes from enOre home isdngs and the revenue generated by hosts with multiple enUre home Iisdngs increased by 183 percent between 2015and 2O16.1f) Commercial enterprises utilizing online rental platforms to market multiple units in multiple locations further exacerbate the housing crisis facing Seattle. Without regulabon, this pracUce could conUnue to rapidly expand, As a 3 73 /\ /o+ewy the City/ to con putpursue more units into the, long term'/^�� ' ,f/` market /� worth / . ., exaOl/�a� /[)r). recent Harvard Law and Policy Review article explains, "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 incendve to Iist each unit in a building on Airbnb,.. In tight housing markets with near -zero vacancy rates, a sudden reduction in supply naturally increases rcnts, particularly because neither the market nor the public sector can swiftly add to the housing stock." 11 The extent of Seathe's housing crisis is well known. Lower income renters are being pushed further from the center city as prices rise; home buyers face an extreme lack of ophons and strong competition for every purchase offer. In 2015, Mayor Murray's Housing Af±ordabHity and Livability Agenda (HALA) taskforce put forward recommendations to achieve his goal of 50,000 new units of housing over the next 10 years, with 20,000 of these units designated as affordable. Short term rentals are not the leading cause of the severe shortage of housing (at all levels of affordability), but they have exacerbated an existing crisis. Any strategy the City can pursue to put more units into the long term market is worth examination. One of the recommendations from the HALA taskforce focused onshort|crmrcniab. Specifically. the Loskforcerecommended that the City pursue collecdng taxes on this activity and dedicating those tax dollars to affordable housing. Currently, the City Iacks the taxing authority to implement this recommendation. The sales tax is collected by the State and the hotel -motel tax in Washington is revenue carved out from the State's portion of the sales tax and remitted to local jurisdictions; state law dictates how this revenue can be spent. Facing this lack of opdons for new taxing authority, we have focused on regulatory actions that would align with the HALA goal of putting more units into the long term market. "The only / hove rented th07�,:c311Dshort ter8?Re.ntO/S2�ice,./\irbnb,has' been mypriO1oryFgSid8nce..Osingle forDilyhome/OCQiedinOn50 .5000 zone, the service for iirUCSWhen / Will beO00JO3thiO/loDci ron 003/5 51000 00005 exceeded -thirty cloys per G,./ff[l/Orci aOd/4irBOB host While secondary to the housing concern, short term rentals aso pose challenges to a fair economic playing field in the vacation market as it is unclear how many operators apply for the necessary business license and pay all applicable taxes. Further, many neighbors of units that have been converted to short term rentals raise Iegihmate questions about neighborhood hvabi|ity. Regulatory egN0atory Systems in n Oth Cities A review of the regulatory approach taken by other jurisdictions reveals a wide range of regulatory responses. On one end of the spectrum, some jurisdicdons have focused exclusively on collecting the appropriate taxes that apply to short term rental transactions. On the other end, cities ranging from New York City to Santa Monica have enforced much stricter regulations; in New York City, apartments cannot be rented out for Iess than 30 days. Per a new law in Santa Monica. short term rental operators will have to live on the property during any short term rental stay. Other cities have attempted to find a middle ground, Philadelphia allows for short term rentals up to 90 cumulative days a year without a permiL, requires a permit and owner occupancy of the unit for rentals from 90-18O cumulative days a year, and prohibits short term rentals for more than 180 cumulative days a year. San Jose alows short term rentals of up to 180 days a year without a host present and year-round with a host present. Both cities were cited byAirbnb's Public Policy Team as posidve examples for Seattle to explore. Taxation and Regulatory egNNatory Context � Seattle �-��U��U� in ��U�V�Ne Short term rental transacdons currnntly operate outside of a soid regulatory framework in Seattle. Any person providing lodging services is required to collect and remit retail sales tax, meaning that anyone who offers their home or a pordon of their home for short term rental should be paying this tax. Airbnb recently announced an agreement with the Washington State Department of Revenue to pay saes tax on behaf of its hosts, but it is unclear how many other owners pay the retail sales tax (9.6% in Seattle) on their units if they are not offering the units through Airbnb's website. "Last y2cotQ/DeighbJring LOVvnhousef .6510. 0/61.5 sOlL_.One neighbor found Lilo" the owner- /snow renting out: O///lirBe be:Ai-DOp73/Othe hOUseOOd OpDOr8Ot/yruns //aS0D/\irE3n 1/"Vh£D/O1e0bbD8ci this; to 000Up/.:? of friends living /i OtherpOrts Of the city two Of the/?l sold they Were: OVVQre Df ttimilor sit-uobbas in their areas: The Convendon and Trade Center tax (15.6% when combined with sales tax) only applies to lodging businesses with 60 or more units, The sales tax is the only applicable tax to a short term rental (ransochon, because the basic hotel/motel tax in Washington State is collected as part of the state's pordon of the sales tax and then remitted to local jurisdictions. The vast majority of short term rental operators do not have business Jicenses, which are currently nequired . While most if not 0 short term rental operators would fall under the Business and Occupa0on Tax minimum threshold of $100,000 in gross revenue, they are stSI required to get a icense and report their revenue. With the exception of Bed and Breakfasts, commercial lodging (hotels and motels) are not allowed in residential zones. In single family zones, bed and breakfasts are allowed with conditions 6 76 outlined inSeattle Municipal Code 23.44I}51.They must have a business license, adhere todispersion requirements, establish quiet hours, must be operated by the principa owner and the owner must ITve on site, must no0fy neighbors, have Iimited signage, and meet parking requirements. In multffamily zones, bed and breakfasts have similar but Oightly less restricdve requirements (SMC 23.45.545G). Regulatory egNNato0y RoNe for ° Government ��0��@�N� ��nn��mmmmmm��mmU� While some elements of the current short term rental market are noveH ncftiding the technology and the Sexibility it offers, many aspects of this market are sfmpy business operations. The City has always played a regulatory role when it comes to business and determining what evel of operadons is appropriate in residental areas. Any City government reguIatons should support one of these ihrecgoab: Baance the economic opportunity created by short term rentals with the need to maintain supply of long-term rental housing stock available at a range of prices. Ensure a level playing field for individuals and companies in the short term rental market. Protect the rights and safety of owners, guests and neighbors of these unfts. AsexV|aincdintheBeneDtsandChoUengessrdion.ihc first goal is the most pressing for Seattle City government. The primary elements of the regulatory scheme proposed below were built to address this issue. At the same bme, the proposed regulations also either directly or ndirecty support the second and third goals. Primary [) '/' ` ��Nu/ng economic opportunity while ^�^^ /��/�,�/�/ng' rental k ` stock Proposed Regulations f~. �� N r Seattle ttN SUL t Term Rental tN Operators ��r�� Wfth any reguaton, one must start by deflnng the actvfty being regulated. In this case, we are defining short term rentals as any stays of 29 nights or fewer n duration, Stays Ionger than 29 nights n duraton woud not be subject to this proposal or be part of any cumulahve short term rental stay calculations. We believe any stays of 30 nights or more 0l a need in our housing rnarket for households in transion. One benefit of the technology that faciHtates the marketing and hooking of short term rentals is that it expandecl this niche in the housing market. - Re��00&� �^��n�- � � Primary Residence Short terin rental opemtor resides Business License Existing Requirement Not Primary Residence Sdor terrn rental operator resides off-site Business License Existing Requirement 78 The basic proposed framework for short term rentals in Seattle would look hke this: You wiU be: 1. limited torenting your primary residence (including an in-Iaw unit or backyard cottage associated wfth your primary residence) and a maximum of one additional dweIing unit and 2. required to register with the City and get a new Short Term Rental Operator hcensc as well as a business license, anexisting requirement. You will also be subject to a few more standards, including providing: • proof tdat the unit is your primary residence, • the hcense number on any short term rental listing, • a local contact number for guests, and • a signed declaration that the unit is up to code This proposed limit on the number of units is designed to meet tbe goal of maintaining our long term housing supply. This requirement will impact those who use these platforms commerciaU\( not homeowners trying to make a little extra income on the side. The proposal would allow an exception to the proposed hmi|s for operators of existing short-term rentals located in the Downtown, South Lake Union, and Uptown Urban Centers (areas where many of the City's lodging uses are located) while not allowing this comrnercial acdvfty to expand. We also propose leveling the regulatory playing field for tradihonal bed and breakfasts, which still operate under reguladons from the pre-on[ine short term rental era. By Iessening some the regulatory hurden they currentiy face, the City can bring traditional bed and breakfasts in line with the new reguadons for short term rentals. 7-& /�o � � � ///� /J//�[��(/ [)/l��{]rs w'// be those [ these / � Uuse��/[]��U -lot ^ // co[�[�e[c/a//y' not / /n trying) / /�l��e(]�/neys � L.� /^�� / + �[} [D[/xc� (7 //' [/(� e)(�r/] income n ~,� �� [)� '/ �//� side. 9 79 A Summary of New Regulations Facing Opera ors Regulations / requirements Operator's primary Operator resides residence off-site Applicable policy goal Title 5 Business License (existing requirement) x x x Pay all applicable taxes (existing requirement) x Prohibit evidence of STR use from exterior for except for signs as permitted by the sign code x x Limit # of units to the primary residence and one additional dwelling unit x Provide proof that the dwelling unit offered for short term rental is their primary residence x NA Provide a local contact to all, guests x x Require operators declare that the unit meets the requirements of the Housing and Building; Maintenance Code x x •t Require posting of basic safety information for guests within rental units x x 10 80 Proposed Regulations ��. �� N r Seattle ttN SUL t Term Rental tN Platforms After surveying pracdces in otherjurisdicdons, it became clear that receiving data from the online platform companies is vital to an effective enforcement structure. In order to facilitate the enforcement, the City will need to collect basic informadon from the Short Term Rental Platforms like VRBO or Airbnb. To do so, these companies will need to register for a new regulatory license with the City. "/ con Qresidential [!eoDOTor0 hove cleaned for 5evero/AirbDb re0ferSUDci hove thought ' r0 very /0n,c,Ttire tio/ this was severely adding to the h0Q3iqq prob./ern city, / 'IOci /t unfair- how people could sit 00 empty opo/1/}lents OMd rent them out for - 'income while my friends, who ore wilfins Ori/7C0y7/8m/hi/e81yfri8ndS'VVh0orOm/i//i/ls poyOn/0Oth/yrent, C(sra fir)dQ/loffDrdQaB OportmeOt/n.the city: -S,residential clean 8r The only requirements for the license will be a) to provide informatlon about Seattles reguatons to operators using the platform b) to share basic data with the City on a quarterly basis, including the total number of short term rentals listed on the plafform and the totalnumbcrofnightseach|istingwasrentcd through the short term rental platform and c) provide booking services only with operators who have been Concluding Remarks and Comments on Equity Inevitably, no citywide policy can best meet the individual needs of every short term rental operator. The proposed regulations detailed above attempt to strike a balance that recognizes both the benefits and challenges offered by short term rentals. They also attempt to focus on this issue through an equity -based lens: while there are a variety of stakeholders and interests in this area, those looking for an affordable home in this city are more in need of supportive local government intervention than those offering their second (or third or fourth) homes to out-of-town visitors. After these regulations are translated into legislation, they will be vetted through the full public process of the City Council, where input is eagerly accepted and further revisions robustly debated. Endnotes ' http://techcrunch.com/2009/03/04/y-comhinators-airbed-and- breakfast-casts-a-wider-net-for-housing-rentals-as-airbnb/ 2http://www.wired.com/2015/12/airbnb-confirms-1-5-billion-funding- round-now-valued-at-25-5-billion/ rhttps://www.airbnb.com/about/about-us 4https://www.homcaway.com/info/media-center/presskit 'http://www.nyt-imes.com/2015/11/05/business/dealbook/expedia-to- acquire-homeaway-for-3-9-billion.html?_r=0 6https://www.homeaway.com/info/about-us 'See https://www.airdna.co/sample/us/washington/seattle or http:// nsideairbnb.com/get-the-data.html 8http://blog.airbnb.com/economicimpactsinseattle/ 'http://insideairbnb.com/seattle/ ° https://www.ahla.com/sites/default/files/CBRE_AirbnbStudy_2017. pdf '-' http://harvardlpr.com/wp-content/uploads/2016/02/10.1_ 10_Lee.pdf