Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
3A - Public Comment
1 Brent Rasi Subject:RE: Feedback on Proposed Changes to STVR Regulations From: William White <William.White.211553247@p2a.co> Sent: Monday, October 3, 2022 10:30 AM To: Dennis Woods <Dennis.Woods@palmspringsca.gov> Subject: Feedback on Proposed Changes to STVR Regulations NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Dennis Woods, Hearing reports about limiting or putting a cap that would limit vacation rentals is a bit alarming. We would be concerned for a number of reasons. Would current People that have vacation rentals lose their licenses? How do you determine this? Would this just be for putting a cap on new rentals? Also, putting the blame on vacation rentals for the lack of affordable housing and/or long term housing is not fair. Yes, housing prices are rising everywhere, especially in a place like Palm Springs. After the pandemic, so many people are fleeing big cities and looking for better options. People that moved from big cities like LA, San Francisco, New York, etc..... They can afford a lot more. So much of the data has shown this. My partner and I moved to Asheville, NC right as the pandemic started and there are very similar parallels. Both are big tourists destinations, that are not big cities. Lots of art, culture and good food. Both cities have seen a huge hike in home prices over the past two years, and it had NOTHING to do with vacation rentals. People from New York, Florida, and California are coming here all the time, and I know it is a similar situation there. Also, the lack of new or affordable housing that has been built in the area of Palm Springs is an issue. Looking at the data, there has been hardly any new building/complexes in the area. Not sure who there is to blame on that, but changing the STR situation is not going to change that. I hope there are ways to increase affordable housing, and get places built for that. Also, since I still love to come visit and stay at our condo, I hope to be able to afford to do that. I lived in Los Angeles for almost 20 years, and love the city of Palm Springs. It is truly a wonderful place. Sure hoping you find another way to the solution you are looking for, because this will not solve it. Sincerely, W. Griffin White Regards, William White 2001 E Camino Parocela Palm Springs, CA 92264 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: I'm concerned about changes to the VR program From: Haven White <Haven.White.577602364@p2a.co> Sent: Monday, October 3, 2022 10:40 AM To: Dennis Woods <Dennis.Woods@palmspringsca.gov> Subject: I'm concerned about changes to the VR program NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Dennis Woods, Let me admit up front that my primary concern is selfish. My brother and I live in cold climates on opposite coasts. We purchased our condominium in Palms Springs a number of years ago so we could enjoy sunny Christmas holiday vacations together. However, we are not among the rich and famous who can afford a second home on a whim. We rely on our snow bunnies' months‐long rentals January through April combined with short term renters in the fall to be able to afford our bills and our mortgage. Given that our home is in a large condominium community, I would guess that our neighborhood is above the proposed 10% cap, and I’m not sure how many permits out of proposed 2,500 cap are already active in the VR program. If the proposed changes are made to the Vacation Rentals program’s rules, do we risk losing our current permit? For us, that would mean having to give up our condo as well. Winter rentals are not enough to cover the rest of the year. The only way we could avoid selling would be to become landlords for full time renters. However, that would end our years of Decembers in Palm Springs, as well as our home's availability to snowbirds January‐April. We don't want to be landlords. We want to be part‐timers in a city that has always welcomed us. We hope the city council won't make decisions that would end our ability to participate in the city's winters. In a less selfish vein, I wish the work group had made a strong recommendation for the construction of additional affordable housing in Palm Springs. The numbers they present clearly suggest that less wealthy locals' actual real estate problems are a lack of affordable units being built, not the increase in vacation rentals. If the goal of any proposed changes is to improve the life of those being squeezed out of the housing market, promoting new construction needs to be at the center of that plan. Thank you for your time. Regards, Haven White 90 E 37th Ave Eugene, OR 97405 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Feedback on Proposed Changes to STVR Regulations From: Cindy Stillman <Cindy.Stillman.211523862@p2a.co> Sent: Monday, October 3, 2022 10:35 AM To: Dennis Woods <Dennis.Woods@palmspringsca.gov> Subject: Feedback on Proposed Changes to STVR Regulations NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Dennis Woods, Good evening, I purchased my property in Palm Springs in 2004. At the time of purchase, the property was a well known and popular complex for vacation rentals and it remains this way. I initially lived in the unit, but found a need in later years to travel more for work and now partially rely on income produced from the seasonal rental. I still use the property personally and as often as work and rentals permit. I am not considered a short‐term rental as I currently only rent for 30 or more days. However, I would like to retain the option to obtain a permit for shorter rental periods should my circumstances require. As I bought the property with this in mind 18 years ago, I would hope any significant changes to city permits provide some grandfather rights for long term properties purchased for this purpose. As you are aware, the economy is uncertain. Some of us rely on alternative sources of income until and beyond retirement. My plan since purchase, has been to retire to this property. I have held steady in this commitment despite the devastating decrease to property values that lasted for over a decade. I have a 5 star review and premier host rating with the company I use, no complaints from neighbors, etc. I take pride in the property and in being a representative of the city I love. Please consider this carefully as any changes for some, could be devastating for others. Respectfully submitted Regards, Cindy Stillman 505 S Farrell Dr Palm Springs, CA 92264 9/29/2022 Public Comment Item 3A From:City of Palm Springs To:City Clerk; City Clerk Subject:*NEW SUBMISSION* Submit Public Comment to the City of Palm Springs Date:Thursday, September 29, 2022 5:07:14 PM Submit Public Comment to the City of Palm Springs Submission #:1995234 IP Address:72.132.191.194 Submission Date:09/29/2022 5:07 Survey Time:10 minutes, 19 seconds You have a new online form submission. Note: all answers displaying "*****" are marked as sensitive and must be viewed after your login. Full Name/Nombre Ashley Ryan City of Residence/Ciudad de residencia Palm Springs, Phone (optional) /Teléfono (opcional) 2149573203 Email (optional/opcional) AshleyRyanTV@gmail.com Your Comments/Sus comentarios My name is Ashley and I have been a resident of Palm Springs for 2 years. I moved out here and began a new venture of flipping houses and turning standard family homes into desirable reflections of Palm Springs classic midcentury modern architecture and design. The results have been stunning, and the business has been successful. However, some of the purchasers of these properties have been investors with plans to use the properties for vacation rentals. I fear that a vacation rental moratorium, would not only decrease sale price, but would also decrease activity and the amount of time on the market which would cut into our bottom line, making it not possible to do the work we do. We employ a great number of local companies to do these projects from local tile houses, cabinet makers, roofers, solar, and the many beloved furniture and design stores in the area. If we aren't able to do business, all of these business would also lose business. Please say no to vacation moratorium. Thank you, City of Palm Springs This is an automated message generated by Granicus. Please do not reply directly to this email. 9/29/2022 Public Comment Item 3A 1 Brent Rasi From:Thomas Ledwith <thomas_m_ledwith@yahoo.com> Sent:Friday, September 30, 2022 4:59 AM To:Lisa Middleton; Geoff Kors; Dennis Woods; Grace Garner; Christy Holstege Cc:City Clerk Subject:STR and permit Fees Categories:Public Comment - Pending Processing NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. To All , Very interesting article in "TDS" . The group or commission was not diverse enough representing all sections of Palm Springs. Housing stock was thrown around , permit fees .people buy homes in Palm Springs for investment and live in those homes , people buy homes for retirement and that still is an investment. If homeowner decide to rent their homes out and what is the problem with that ? I urge the council to please take a hard look from as a homeowner point of view . Sincerely, Thomas M Ledwith 2701 E Mesquite Palm Springs Sent from my iPhone 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Please don't damage our beautiful city's budget with Vacation Rental Permit Caps! From: Bruce Lahey ‐ psLUX.com <bruce@pslux.com> Sent: Thursday, September 29, 2022 4:14 PM To: Christy Holstege <Christy.Holstege@palmspringsca.gov> Subject: Please don't damage our beautiful city's budget with Vacation Rental Permit Caps! NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Hello Christy – I would like to voice my opposition to restricting vacation rental permits. Our economy is close to a recession ‐‐ restricting vacation rentals and thereby reducing our beautiful city’s tax revenue does not seem prudent. If you feel that you must cap vacation rental permits, I encourage you to do so at the citywide level ‐‐ capping permits at the neighborhood level will have a greater negative financial impact. PLEASE: No neighborhood vacation rental permit caps! Thank you for your consideration. BRUCE LAHEY BRUCE@PSLUX.COM 415.902.7747 9/29/2022 Public Comment Item 3A From:Rodney Dickson To:City Clerk Subject:STR Limit Support Date:Thursday, September 29, 2022 4:59:21 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. Palms Springs City Council, This email is to inform you of my support for the limits on short term rental properties as outlined by the STR working group. Although I understand the value of short term rentals to the financial viability and sustainability of the city, as a local homeowner I also very well understand the impact of uncontrolled short term rental properties on individual neighborhoods. Such negative impact within the neighborhood can out weigh the financial benefit to the city. There does need to be a balance and limiting short term rentals is a common sense approach avoiding an “all or nothing” model. Many thanks for your consideration to limit rentals. Rodney Dickson Sent from my iPhone 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Comments to council meeting on September 29th, item: REVIEW AND DISCUSSION OF VACATION RENTAL WORKGROUP RECOMMENDATIONS From: Jamie Adner <adnergroup@gmail.com> Date: Thursday, September 29, 2022 at 2:10 PM To: Lisa Middleton <Lisa.Middleton@palmspringsca.gov>, City Clerk <CityClerk@palmspringsca.gov> Subject: Comments to council meeting on September 29th, item: REVIEW AND DISCUSSION OF VACATION RENTAL WORKGROUP RECOMMENDATIONS NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. To honorable City Council members: My name is James Adner and I am a full‐time resident of Palm Springs. I am a full‐time Realtor and have been selling homes in Palm Springs for over ten years. I want to speak to the proposed changes in the short‐term rental ordinance and how they may negatively impact the Palm Springs home market. First, the data presented dates from 2017 ‐ 2022, an extraordinarily hot home market. During this time, there seemed to be an endless appetite for buyers to purchase Palm Springs real estate and home prices seemingly did nothing but rise. The median price of a Palm Springs home increased from $593,000 in 2017 to $950,000 in 2021. But in September 2022, we are no longer in that hot market. We are in one of the worst real estate markets in decades. Take a look at the headline from a Costar article from September 28, 2022. (Costar is the #1 commercial real estate database) "The Housing Market Faces a Painful Correction The low‐rate environment that helped juice the housing market for the past several years is decidedly over as the Federal Reserve moves to push interest rates ever higher in its battle to tame decades‐high inflation. Even as robust pandemic‐era demand for housing drove prices higher, rock‐bottom mortgage rates allowed buyers some relief in their monthly payments. 9/29/22 Public Comment Item 3A 2 But affordability has now cratered to 2005‐2006 levels after mortgage rates swooped higher over the course of the year." The Palm Springs home market is at the beginning of a painful correction. Interest rates are stratospheric and homes are languishing on the market. In September 2021, 78 Palm Springs homes sold. In September 2022, 41 Palm Springs homes sold. Furthermore, interest rates are expected to rise through 2023, further curbing demand. In this dire housing market, there is now the threat of total chaos created by limiting the number of licenses. Think of the impact when two classes of homes are created ‐ homes with licenses, which have immediate greater resale potential, and homes without licenses, that immediately have lower resale potential. How will this license cap play out? In anticipation of the changes, current homeowners are certain to “hoard” licenses knowing the economic value of the license. This hoarding will result in an even greater number of licenses than the current number, before the cap was implemented. And how will new licenses be allotted? By waitlist? If a waitlist is created, homeowners who may one day want a license will add their name to the waitlist. This will essentially mean that no new homeowners will be eligible for licenses. I believe the current ordinance, one of the most highly regulated in the nation, is adequate. It is also equitable in that any homeowner may obtain a license. I believe that further data needs to be collected during the down market before any changes are implemented. I would go so far as to say that the conclusions of the 2022 report are invalidated because they don’t cover a representative “snapshot” of the home market through its ups and down. It is very possible the number of licenses will decline with the declining market and as short‐term renters are sidelined by the recession. Sincerely, James Adner 1128 E San Lorenzo Rd, Palm Springs, CA 92264 9/29/22 Public Comment Item 3A 1 Brent Rasi Subject:RE: Please vote to limit STRs in our neighborhoods and the rest of the recommendations of the STR working group From: Britton Stuber <brittonstuber@gmail.com> Sent: Thursday, September 29, 2022 1:50 PM To: Llubi Rios <Llubi.Rios@palmspringsca.gov> Subject: Please vote to limit STRs in our neighborhoods and the rest of the recommendations of the STR working group NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. We support limiting STRs recommended by the STR work group. Three voting PS citizens of over 22 years, all support limiting STRs as recommended by the STR working group. We are tired of our neighborhood being hollowed out by mini hotels and losing our full time neighbors to a street full of cars and strangers. My street of 10 houses has 5 rental properties on it and two more homes for sale will most likely become the same thing. Please do something. Britton Stuber John HInes Betty Cahill 2596 N Aurora Drive PS CA 92262 BrittonStuber@gmail.com 9/29/22 Public Comment Item 3A 1 Brent Rasi Subject:RE: Short-Term Vacation Rentals From: Ross Bodle <rbodle@hotmail.com> Date: September 28, 2022 at 4:38:34 PM PDT To: Dennis Woods <Dennis.Woods@palmspringsca.gov> Subject: Short‐Term Vacation Rentals NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Good Afternoon Dennis, I wanted to weigh in with you again on Short‐Term Vacation Rentals prior to the City Council meeting discussion tomorrow evening on the Citizens Panel Recommendations. Sorry for the lateness of my communication. We just returned from another trip. I'm very pleased that their recommendation on capping Neighborhoods to 10 percent aligns with my previous suggestion to you. Attached please find some additional suggestions I have packaged as a "Neighbors of Short‐Term Vacation Rentals Bill of Rights." The suggestions are based on Jim and my experience with STVRs in Gene Autry. As you know, we have been pushing for months for the City to take legal action against a certain illegally operating STVR in our Neighborhood. In addition, we now find ourselves without neighbors. When we bought our home seven years ago, we had good neighbors that we knew on both sides, behind and across the street. We now have no neighbors. I have read the recommendations of the Citizens Panel and note, not surprisingly, that District 2 has a significantly higher percentage of STVRs as part of our housing stock than any other in the City. I appreciate the opportunity to share my thoughts with you and look forward to your feedback. If you are in agreement with any, please 9/29/2022 Public Comment Item 3A 2 adopt them as your own and inject them into the discussion tomorrow night with the hopes that other Council members will agree. Best wishes, Ross Ross A. Bodle 9/29/2022 Public Comment Item 3A Neighbors of Short-Term Vacation Rentals (STVRs) Bill of Rights In addition to a 10 percent per Neighborhood Cap, Neighbors are entitled to: 1) Be informed by mail that a Registered Short-Term Vacation Rental (STVR) is located directly adjacent to their property. That requirement would cover homes behind, next-door, and across the street; and condos/town homes sharing walls. The mailing would also include STVR ordinance information and how to report violations. 2) Be informed by mail when a previously registered STVR is no longer permitted for whatever reason. The mailing would also include information on how to report any suspected Short-Term Rental activity that may occur after the date of permit termination. 3) Be informed via email the specific outcome(s) of a Code complaint(s) related to a STVR they have reported. 4) Be informed via email the specific outcome(s) of any court action taken by the City Attorney against the owner(s) of an illegally operating unregistered STVR, resulting from their Code complaints. 5) Be assured that the City will change its’ current STVR Ordinance to fine and take legal action, to the maximum extent allowed by State Law, against the owner(s) of an illegally operating unregistered STVR. 6) Be assured that the City will change its’ current STVR Ordinance to carry out maximum “Due Diligence” to prevent an individual or their immediate family directly or via an LLC from owning as a whole or shares more than one STVR; and will apply the same strict ownership restrictions to any investment group, company, or business. If determined after STVR registration is granted, the City would reserve right to revoke permit. 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Feedback on Proposed Changes to STVR Regulations On Sep 28, 2022, at 9:19 AM, Dean Marriott <Dean.Marriott.576935889@p2a.co> wrote: NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Dennis Woods, Hello, Thank you for your work on the changes to the Vacation Rental rules. We own a home in Racquet Club Estates that we rent part of the time and enjoy several months a year. We, like everyone, want to maintain the sense of community and neighborhood that makes Palm Springs attractive to so many. We fully support the existing rules applied to vacation rentals, including the noise regulations, parking, and per bedroom occupancy limits. These have been most helpful in our own neighborhood and with our renters. We take and apply the rules very seriously. We have a few questions and thoughts about the proposed changes: 1.What happens to existing homes that are used as vacation rentals part of the year that were purchased with rules in place that permitted use as rentals? 2.How will the City apply the 10% rule especially in neighborhoods exceed that percentage now? 3.We suggest the 10% cap per neighborhood seems very low and we are not sure the justification behind that number. We would suggest something closer to 20% be considered. 3.Please consider that home owners who rent do pay property tax and also pay 12.5% transit occupancy tax, without the ability to vote. (We are sure you have calculated the loss of revenue from the TOT the city would realize if rentals are limited.) 4.Please consider that the renters do contribute significantly to the local economy. Many of those rentals will not switch to hotel rooms‐ they want the privacy and convenience of larger space and private homes. 5.Housing prices throughout the country have been high and only recently shown a drop. The status of a home as a vacation rentals is likely not a primary cause of the housing affordability issue since so many cities across the country are dealing with this without the vacation rental numbers that Palm Springs has. Whatever the causes of high home values, home owners also who do not rent their home benefit from higher home values. And when values drop, they drop for everyone. 6.It seems that the biggest issue is noise and parking in that order. We encourage you to continue, and expand if necessary, the enforcement of the current regulations. They are important ‐ we tell our guests that and we would expect other owners who rent to do the same. We very much appreciate your consideration of this and our comments. Please reply any time to the email or number above. Kind regards, Debrah & Dean Marriott Regards, Dean Marriott 500 E Lindsey Dr 9/29/2022 Public Comment Item 3A 2 Palm Springs, CA 92262 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Feedback on Proposed Changes to STVR Regulations On Sep 28, 2022, at 9:24 AM, Stephane Wong <Stephane.Wong.211541051@p2a.co> wrote: NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Dennis Woods, I hope you will consider the proposal of 2,500 vacation rentals and 10% density cap with the below two considerations: 1)Whether higher densities have been proven to be associated with issues in the various Palm Springs neighborhoods versus being an assumed. I have been renting out my home for short‐term renters since 2016 with most of my renters being repeat annual guests that take care of the home as if it were their own. I do not think that the ~20‐30% short‐term rental density in the neighborhood of Taquitz River Estates has been an issue. 2)This is my only home in Palm Springs and my family and I have spend anywhere from 1‐8 months a year at the home. We love Palm Springs. The short‐term rental helps cover part of the mortgage, which I hope will enable me to retire in Palm Springs. I solely post this rental on VRBO as I was informed this website only allows full house rentals versus Airbnb and generally this leads to respectful guests staying at the home. I hope that home owners with a single property would be assessed differently to those with multiple proprieties who are making this a significant business. Regards, Stephane Wong 165 E Mesquite Ave Palm Springs, CA 92264 9/29/2022 Public Comment Item 3A From:Franklinps To:City Clerk Cc:Geoff Kors Subject:Public Comment on Agenda Date:Thursday, September 29, 2022 12:09:09 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. This is in response to the Public Hearing on the Short Term Rental Ordinance changes. One of the issues that is rarely discussed when governments change the rules is the unintended consequences associated with the new law or changes. These proposals are full of unintended consequences, with limits on the number of permits to be issued owners will rush to get a permit that they may never use just to cover themselves for the future. What about if my neighbor’s application is 2500 and mine is 2501, so they get a permit and I don’t? If there is a limit “per neighborhood” what stops a neighborhood from disbanding? What about the 7,000 homes not in a neighborhood? As far as the ADA compliance issue. This issue has come up in other cities and the plaintiff attempting to require this for all rental properties has lost. If this applies to STRs then why not all rental property? This could cost homeowners ten’s of thousands of dollars so they might abandon the STR permit and rent it anyhow. Instead of spending the money to be compliant the owner would just pay the possible fines, figuring the fines would be less. I would suggest that this go back to the drawing board and thought through before fixing something that is working. Citations are down, complaints are down and while the number of permits might be creeping up a bit, it is not going to double overnight. One final note, why wasn’t there a Realtor on this workgroup? We are on the front lines on this issue, but those that applied were not requested to be on the panel. Sincerely, Jim Franklin 2022 President 9/29/2022 Public Comment Item 3A Greater Palm Springs Realtors 4045 Ramon Palm Springs, CA 92264 760-485-0858 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Short Term Vacation Rentals Moratorium Vote September 29, 2022 From: Brian <bdyaklich@gmail.com> Date: September 29, 2022 at 9:20:02 AM PDT To: Llubi Rios <Llubi.Rios@palmspringsca.gov> Subject: Short Term Vacation Rentals Moratorium Vote September 29, 2022 NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Mayor and City Council Members, I support a full moratorium of all short term vacation rentals in Palm Springs. Our neighborhoods have become a dumping ground for hundreds of unwelcome invaders for weekend parties and back yard play. I am concerned about the impact on the environment and the continued reduction of accessible housing in our community. Thousands of cars enter our neighbhoods reducing the safety or our streets and the quality of our air. (Palm Springs has some of the worst air quality issues in the state.) Over 6 percent of our housing market is not accessible to families seeking housing in Palm Springs. This needs to change Thank you for your consideration in this important issue. Sincerely, Brian Yaklich Sent from Mail for Windows 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Short Term Rentals From: Jim Bruce <jrbrucejr@hotmail.com> Date: September 29, 2022 at 9:17:35 AM PDT To: Dennis Woods <Dennis.Woods@palmspringsca.gov>, Christy Holstege <Christy.Holstege@palmspringsca.gov>, Geoff Kors <Geoff.Kors@palmspringsca.gov>, Lisa Middleton <Lisa.Middleton@palmspringsca.gov>, Grace Garner <Grace.Garner@palmspringsca.gov> Cc: Llubi Rios <Llubi.Rios@palmspringsca.gov> Subject: Short Term Rentals NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Palm Springs City Councilmembers, I am writing to Beg & Plead with you to Immediately issue a Moratorium on new Short Term Rental / STR Applications, while you consider a cap. Per the information prepared by the Committee created by the PS City Council to study this issue, the current number of registered STR’s plus the current number of applications already exceeds the recommended 10% cap. Plus almost half of the Neighborhoods already have over the recommended 10% registered STR’s. Many are significantly over, some near twice to four times that number. Just as the Council placed a Moratorium on new Pot Facilities in Desert Gateway Neighborhood, while considering new policy, the Council should act in the interest of your constituent resident homeowners, NOT in the interests of out‐of‐town investors. Thank you for supporting your constituents. Jim Bruce, AIA Emeritus 2753 East San Angelo Road 9/29/2022 Public Comment Item 3A 2 Palm Springs, CA 92262 760-507-5884 Sent from Mail for Windows 9/29/2022 Public Comment Item 3A From:Joan Gand To:City Clerk Subject:Public Comment on Agenda - Short Term Rentals Date:Wednesday, September 28, 2022 8:20:00 AM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. We would be in favor of a cap on short-term rentals. We especially support the 10% of properties per neighborhood. We live in Vista Las Palmas, and we feel like we are surrounded by short term rentals. What good is trying to enjoy a beautiful night out in our backyard while next door or across the street there is a wild party going on with shouting so loud we can hear every word? There have been times when we couldn't even sleep because the noise went until 2 a.m. We know there is a noise ordinance but it is difficult to enforce. We would also be in favor of some kind of limit on "party houses." We don't mind vacation rentals with a quiet couple or family enjoying our beautiful neighborhood for a few days, but the "party house" has become the norm in our neighborhood. Sincerely, Joan and Gary Gand -- Joan Gand PS Modcom Education Committee Chair The Gand Band, www.thegandband.com Chicago Bauhaus and Beyond co-founder Neo Instruments North American Distributor My Name is Lopez documentary now streaming! Gand Concert Sound and Installations www.gand.com 9/29/2022 Public Comment Item 3A From:LetsAll@GoBananas.net To:City Clerk; Veronica Goedhart Subject:2022-09-29 City Council Agenda Item 3A - STRs Date:Wednesday, September 28, 2022 9:29:51 AM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear City Council and Staff, Agenda Item 3A STR Ord Update. So glad we have an Ordinance that can be updated, and it appears to be in good hands for that process. The City deserves a sincere pat on the back for this achievement, it’s made an impactful difference. One concern in the update going on currently is the apparently arbitrary cap of 2,500 permits. There needs to be a substantive matrix to the cap, but at this time it appears it is being chosen by the old “The PFA Method”, and that’s problematic. PFA = “Pluck From Air Method”. Please have them come up with something with solid calculated substantive matrix behind the number for the cap, not just some guessing PFA. The PFA optics are not good. Thank you for reading, Bob Heinbaugh & Paul Hinrichsen – Upper West Side NOrg leadership members 9/29/2022 Public Comment Item 3A From:Bonnie Ruttan To:City Clerk Subject:Council topic/STRs Date:Wednesday, September 28, 2022 9:42:54 AM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. We would like to express our support of limits on STRs as recommended by the STR Work Group Thank you for your consideration Bill and Bonnie Ruttan 1111 Abrigo Rd Sent from my iPad 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: No STR caps by neighborhood From: keithruoff@gmail.com <keithruoff@gmail.com> Sent: Wednesday, September 28, 2022 9:26 AM To: Christy Holstege <Christy.Holstege@palmspringsca.gov> Subject: No STR caps by neighborhood NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Hello, I would like to voice my opposition to restrictions on the number of vacation rental permits allowed in Palm Springs. STR's provide enormous financial benefit to the city and all not detrimental to our city and neighborhoods. Capping the number of permits, especially at the neighborhood level, will have a negative impact on the city. I urge you to take the most conservative vote at this time and only cap permits at the citywide level. Please do not cap permits at the neighborhood level. Doing so will have negative financial impact on homeowners and the city. No neighborhood permits caps! Thank‐you Keith Ruoff 301 W Via Escuela Palm Springs, CA 92262 (415) 596‐6132 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Feedback on Proposed Changes to STVR Regulations From: Stephane Wong <Stephane.Wong.211541051@p2a.co> Sent: Wednesday, September 28, 2022 9:23 AM To: Christy Holstege <Christy.Holstege@palmspringsca.gov> Subject: Feedback on Proposed Changes to STVR Regulations NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Christy Holstege, I hope you will consider the proposal of 2,500 vacation rentals and 10% density cap with the below two considerations: 1) Whether higher densities have been proven to be associated with issues in the various Palm Springs neighborhoods versus being an assumed. I have been renting out my home for short‐term renters since 2016 with most of my renters being repeat annual guests that take care of the home as if it were their own. I do not think that the ~20‐30% short‐term rental density in the neighborhood of Taquitz River Estates has been an issue. 2) This is my only home in Palm Springs and my family and I have spend anywhere from 1‐8 months a year at the home. We love Palm Springs. The short‐term rental helps cover part of the mortgage, which I hope will enable me to retire in Palm Springs. I solely post this rental on VRBO as I was informed this website only allows full house rentals versus Airbnb and generally this leads to respectful guests staying at the home. I hope that home owners with a single property would be assessed differently to those with multiple proprieties who are making this a significant business. Regards, Stephane Wong 165 E Mesquite Ave Palm Springs, CA 92264 9/29/2022 Public Comment Item 3A From:Ken Priore To:City Clerk Subject:Fwd: Proposed limit on short-term vacation rental puts Palm spring families at risk Date:Wednesday, September 28, 2022 10:40:41 AM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. ---------- Forwarded message --------- To: <paul.albani-burgio@desertsun.com>, <Lisa.Middleton@palmspringsca.gov>, <Grace.Garner@palmspringsca.gov>, <Geoff.Kors@palmspringsca.gov>, <Christy.Holstege@palmspringsca.gov>, <Dennis.Woods@palmspringsca.gov>, <Llubi.Rios@palmspringsca.gov> In 2018 the voters overwhelmingly rejected a ban on short term vacation rentals. What the working group has proposed is an arbitrary limit, primarily fueled by a vocal minority that consistently have sought to undermine this vote. The proposal also skews in favor of the privileged who have the ability to live in Palm Springs without the ability to offset costs with vacation rentals. As economic uncertainty is rising, We ask the city council to consider a more nuanced approach, that would allow owners who’s Palm Springs property is their primary residence, to be excluded from the arbitrary limit. The 2500 limit is arbitrary and not based on data The working groups proposal of a ban of 2500 permits and a 10% per neighborhood limit is flawed and not driven on any discernible data. How did the working group establish a 10% threshold per neighborhood as acceptable? What were the criteria? Also, it is important to remember that the neighborhoods were drawn for a set of factors by developers over the past 50 years, and vary greatly in size. We ask the city council to think about the disparate impact that an arbitrary limit may have on the individual households in neighborhoods that vary so widely in size and boundaries. According to the working group’s data, there are 34,794 households in Palm Springs, of which the 2500 freeze represents 7%. On what basis did the working group establish this number? This arbitrary limit is inconsistent with the 10% limit the group proposes. Using the group’s logic, shouldn’t the limit be closer to 3400? We ask the city council to consider a limit that is evenly applied to all neighborhoods that is based on data. A broad brush approach does not balance interests but caters to a narrow agenda. An approach that support residents One consideration that is completely missing in the council’s approach is the impact on residents that have their primary residences but may also occasionally rent out their home as a vacation rental. Critics have cast the short term vacation rental debate as residents versus non- residents, and continue the argument from the 2018 vote on the ban. There is little to no data to support this argument. There is a less vocal set of constituents that are active members of the community 9/29/2022 Public Comment Item 3A and also rent out their homes occasionally as vacation rentals. To remove this option by an arbitrary cap on new short term rentals would introduce more instability for some residents of Palm Springs. Entering into a period of economic uncertainty, the city council should continue to support households in Palm Springs but exempting households that are full time residents from the arbitrary limit. The city could use established mechanisms (attestation, voter registration, driver’s license, tax domicile) to enable this process. This would protect families but maintain this critical financial support during a time of economic uncertainty. This arbitrary limit is nothing more than an opportunistic grab by a privileged minority to undermine the 2018 vote. We applaud those residents who have been long term residents of Palm Springs and have the ability to live without the support of vacation rental income. But there are others who are not as fortunate, or who are barely holding onto their dream of living in Palm Springs. For these residents we ask that you consider a data driven approach that supports the residents of Palm Springs. The proposed limit is not a balancing of interests and is not based on data, but opinions. This arbitrary limit is the wrong decision at the wrong time. -Ken Priore Resident-Palm Springs 9/29/2022 Public Comment Item 3A 1 Brent Rasi To:Christy Holstege Subject:RE: The proposed short-term rental permit cap From: Geoffrey Moore <geoff@geoffreymoore.com> Sent: Friday, September 23, 2022 8:05 AM To: Christy Holstege <Christy.Holstege@palmspringsca.gov> Subject: The proposed short‐term rental permit cap NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. I think the proposed short‐term rental permit cap I just read about is a bad way to address the issue. I think reducing the number of times ALL home owners can short‐term rent their homes per year is a better solution. This approach would weed out investors out who are currently making big returns, but it would also allow new home buyers who want to offset some of their second home expenses to obtain a permit. I think reducing the contracts from 36 to 26 or 24 is a better, less discriminatory solution. I also think the city will open itself up to lawsuits if it allows one homeowner to have a permit, but a neighbor not to have a permit. I don’t see how that can be defended. G Geoffrey Moore CRS, GRI, SRS, GREEN, ABR® CalBRE# 01942291 760-641-5689 (cell) www.geoffreymoore.com Town Real Estate PO Box 5297 Palm Springs, CA 92263 My greatest success is your happiness 9/29/2022 Public Comment Item 3A From:City of Palm Springs To:City Clerk; City Clerk Subject:*NEW SUBMISSION* Submit Public Comment to the City of Palm Springs Date:Wednesday, September 28, 2022 11:08:01 AM Submit Public Comment to the City of Palm Springs Submission #:1991785 IP Address:72.132.189.197 Submission Date:09/28/2022 11:07 Survey Time:8 minutes, 36 seconds You have a new online form submission. Note: all answers displaying "*****" are marked as sensitive and must be viewed after your login. Full Name/Nombre Michael Alcenius City of Residence/Ciudad de residencia Palm Springs, Phone (optional) /Teléfono (opcional) 2028413810 Email (optional/opcional) malcenius@gmail.com Your Comments/Sus comentarios Thanks to the City Council for convening a group to address the STR issues. I appreciate the extensive work that was done by the group and agree with the suggestions. I live in an area of Indian Canyons with a high concentration of STRs. On a high-season weekend, it appears to be a Motel 6 rather than a high value residential area. Also, given Ms. Holstege Husband's major line of income, should she not recuse herself from any vote regarding STRs? Interesting precedent if she does not. Thank you, City of Palm Springs This is an automated message generated by Granicus. Please do not reply directly to this email. 9/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Note from a constituent regarding the STR issue From: Jeffrey Schneider <mylioe@gmail.com> Sent: Wednesday, September 28, 2022 10:05 AM To: Christy Holstege <Christy.Holstege@palmspringsca.gov> Subject: Note from a constituent regarding the STR issue NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Christy, I am a supportive constituent and longtime resident and business owner here in Palm Springs. I live in the Araby neighborhood in South Palm Springs. I was surprised to see that discussion of limiting vacation rentals is suddenly on the docket again. I thought we had resolved this issue a few years ago with Measure C, when we voted overwhelmingly in favor of the vacation rentals. What has suddenly prompted this issue to the forefront of the city council’s attention? Renting full homes in Palm Springs is what draws the majority of tourists here to our city for their vacations. Intimate gatherings with friends and families in a private setting is the reason they drawn here, and they spend money here at our wonderful restaurants and shops. I believe the ordinance as it currently is, has been doing just fine in maintaining a balance between residents and renters. If there are issues, perhaps you should focus more on efficient regulation of the ordinance and not on arbitrary limits to the number of rentals. Especially, pitting specific neighborhoods against one another seems entirely draconian, and will throw our real estate even more out of balance. Suddenly investors will go into what are currently more residential neighborhoods where licenses are more available. Also, this seems a very odd time to start to put these limits on vacationers coming to Palm Springs. Real estate values are tumbling, the buyers are gone. After a very slow summer, we are clearly moving into some sort of slowdown/recession. My businesses have slowed down dramatically and I am anticipating some hard times ahead. Why aggravate this situation even further by limiting tourist options here in Palm Springs, ultimately turning them away. This whole effort seems totally suspect to me. WHo is pushing this? I feel like the issue has been negotiated and negotiated and we have finally achieved a good balance here in Palm Springs that has been working. Overall the number of rental units has hardly changed in five years. Why attempt to fix an issue that isn’t broken. The city Council should be creating a favorable climate for its business community, which is a tourist‐ based economy. We need to be welcoming visitors and not throwing up roadblocks. I think the city Council should be focusing on the more important issues that affect our lives here in Palm Springs, The increase in crime, homelessness, and not enough health care professionals. Please, let's leave well‐enough alone on this issue. Best, 9/29/2022 Public Comment Item 3A 2 Jeffrey Schneider 2990 Araby Circle Palm Springs, CA 92264 (323) 428‐8992 9/29/2022 Public Comment Item 3A 1 Brent Rasi To:Christy Holstege Subject:RE: NO STR cap by neighborhood From: psmontevista@gmail.com <psmontevista@gmail.com> Sent: Wednesday, September 28, 2022 11:09 AM Subject: NO STR cap by neighborhood NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Hello, I would like to voice my opposition to restrictions on the number of vacation rental permits allowed in Palm Springs. STR's provide an enormous financial benefit to the city and are not detrimental to our city or to our beautiful neighborhoods. Capping the number of permits, especially at the neighborhood level, will have a negative impact on the city and its most important revenue stream. I urge you to take the most conservative vote at this time and only cap permits at the citywide level. Please do not cap permits at the neighborhood level. Doing so will have a decisively negative financial impact on both homeowners and the city itself. No neighborhood permits caps! We urge you! No neighborhood permits caps! Thank you, Heather & Christopher Lyon 1387 North Via Monte Vista Palm Springs, CA 92262 415‐518‐6069 9/29/2022 Public Comment Item 3A From:keithruoff@gmail.com To:City Clerk Subject:Public Comment on Agenda 3A Date:Wednesday, September 28, 2022 12:54:44 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Mayor, Mayor Pro Tem and council members: I would like to voice my opposition to restrictions on the number of vacation rental permits allowed in Palm Springs. STR's provide enormous financial benefit to the city and are not detrimental to our city and neighborhoods. Capping the number of permits, especially at the neighborhood level, will have negative long-term impact on the city. I urge you to take the most conservative vote at this time and only cap permits at the citywide level. Please do not cap permits at the neighborhood level. Doing so will have negative financial impact on homeowners and the city. Let the citywide cap take effect and see what impact it has before taking any additional action. Take a conservative approach to this issue and only set caps at the city-wide level. Thank-you Keith Ruoff 301 W Via Escuela Palm Springs, CA 92262 (415) 596-6132 9/29/2022 Public Comment Item 3A 1 Brent Rasi To:Thomas Ledwith Subject:RE: Vacation rentals From: Thomas Ledwith <THOMAS_M_LEDWITH@yahoo.com> Date: September 23, 2022 at 10:24:30 AM EDT To: Lisa Middleton <lisa.MIddleton@palmspringsca.gov>, Grace Garner <Grace.Garner@palmspringsca.gov>, Dennis Woods <Dennis.Woods@palmspringsca.gov>, Geoff.Kors@palmspringsca.gov, Christy Holstege <christy.holstege@palmspringsca.gov> Subject: Vacation rentals To All , When is government going to stop ? If a person wants to rent their home , that is their business . The City council has more fish to fry. Such as Homeless, drug abuse crime .Someone In PS mentioned this to me . The council members who voted "Yes" for the navigation center, to go in Ms .Garners district .The reason why they did not want it in their Districts. Ms.Garner District should get more High end projects. Just my 2 cents .Thank you for reading my email. Sincerely, Thomas M Ledwith 2701 E Mesquite Palm Springs "No to the Preserve" Sent from my iPhone 9/29/2022 Public Comment Item 3A From:planetcyd@aol.com To:City Clerk Subject:Re: Short term rentals. HELP Date:Wednesday, September 28, 2022 1:25:19 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. HELP!!!!!!! Short term rentals or AIRBNBS. Yes please, do something! 50% short term on my block, San Lorenzo rd Yesterday, I was told the people that just bought the home next door.. and was never going to use as a AIRBNB rental, will be now doing it. 1500 per night! Pissed off! I have on all sides of me now. 40 new people every damm weekend. Sent from the all new AOL app for Android 9/29/2022 Public Comment Item 3A From:Bob Gentry To:City Clerk Subject:In support. Date:Wednesday, September 28, 2022 1:33:52 PM Attachments:DB5D3FD2FE2F44A78CB73E994CA4102A.png 50CD2996093943419F845E7CB072753B.png NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Offices of Mayor & City Council, I’ll keep my email brief because I know no one really likes to read long-winded emails about the struggles of living with STR’s; you’ve all heard it all before. But, I’m writing to say as a Palm Springs resident for the last 10 years, I support this proposal from the workgroup Hank Plante is part of [from the segment on KESQ News]. *I’m unable to come to the meeting on Thursday, sadly. When I moved here 10 years ago, I intentionally purchased my home away from the downtown area and hotels, but now it seems I’m surrounded by what I was hoping to avoid. In hindsight, I might have been better off living near those hotels and resorts since they seem to police themselves. My retirement home is now filled with anxiety, many sleepless nights, and a sense of dread as my neighbors move away, only to be replaced with another short term rental. The atmosphere around such holidays like Labor Day, 4th of July, Spring Break, Coachella, and other events our desert offers leaves me constantly On Edge. Thanks for taking the time to read this. I hope this proposal is something people on both sides of the issue can find common ground on…because it is a problem that needs to be fixed somehow. Thanks again, Bob Gentry 310-497-2721 2349 N Los Alamos Rd Palm Springs, CA 92262 All Bob Gentry Links BobGentry.com Facebook | Instagram | Twitter | YouTube 9/29/2022 Public Comment Item 3A Blue Élan Records 10880 Wilshire Blvd., Suite 2000 Los Angeles, CA 90024 BlueElan.com 9/29/2022 Public Comment Item 3A From:planetcyd@aol.com To:City Clerk Subject:No more Airbnb Date:Wednesday, September 28, 2022 2:54:11 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. Neighborhoods are for neighbors. I don't feel safe with 40 new strangers on my block every weekend, Please be responsible and stop or limit this madness. Cyd Detiege San Lorenzo rd Palm Springs Sent from the all new AOL app for Android 9/29/2022 Public Comment Item 3A From:Paula Auburn To:City Clerk Cc:Paula Auburn Subject:STVR Study Report - comments Date:Wednesday, September 28, 2022 5:12:56 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. TO: Mayor Lisa Middleton, and Council Members Grace Garner, Christi Holstege, Geoff Kors, and Dennis Woods FROM: Paula Auburn RE: STVR Study Recommendations DATE: September 27, 2022 As a 19-year resident and a long-term member of ONE-PS, I have observed the demise of solid residential neighborhoods through the process of conversions to short-term rentals. We have lost several community leaders and volunteers to other valley cities with stricter prohibitions. Conversations with elderly widows show their fear of increasing crime in vacant neighboring homes and losing neighbors they once knew and conversed with. This only increased my aversion to this type of rental in residential zoning. It seems to clear that these are “hotel-like” businesses within residential zoning. As more corporations buy these homes as an investment it, it further erodes neighborhood quality of life. At the rate of conversions, I wonder where future voters will come from? Who will volunteer to serve on Boards and Commissions? Certainly not the short- term renters and certainly not the owners who do not live in Palm Springs and certainly not the corporations! Perhaps I should thank you for increasing the attractiveness of HOAs such as mine. The short-term gains are not worth the long-range costs. Good budgeting can be done without reliance on TOT to fund basic services. Thank you. Paula Auburn 1369 Campeon Circle, PS 760-464-4494 9/29/2022 Public Comment Item 3A 9/29/2022 Public Comment Item 3A From:Doug Prochaska To:City Clerk Subject:Public Comment - Item 3A Vacation Rental Workgroup Recommendations Date:Wednesday, September 28, 2022 5:24:37 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. Mayor Middleton and Members of the Council: I live at 2260 Paseo Roseta, between Tahquitz and Baristo, in the Sunrise Park neighborhood. Last November, The Palm Springs Post published a map showing locations of vacation rentals throughout the city. After studying the map, I realized that during my 20-minute morning walk around my neighborhood with my dog, we pass 13 homes that are vacation rentals. On Paseo Gracia, there are several in a row, and they are busy. As you might imagine, the subject of vacation rentals is a topic of neighborhood discussion, and neighbors with whom I spoke identified other rentals in our neighborhood that do not appear on that map. That's a lot of rentals for a small neighborhood. I have studied the City Council Staff Report which includes the recommendations of the Vacation Rental Workgroup. I believe that implementing these recommendations is best for our city. Vacation rentals are a knotty issue with a variety of stakeholders. The recommendations of the Workgroup provide a good compromise that, I believe, addresses the needs of all stakeholders. I urge the Council to implement the recommendations of the Workgroup, including a city-wide cap of 2,500 rentals and a neighborhood cap of 10%. Respectfully, Doug Prochaska Sender notified by Mailtrack 9/29/2022 Public Comment Item 3A 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 City of Palm Springs 2022 Vacation Rental Work Group Recommendations Supplemental Comments and Data Version 1.0 September 26, 2022 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) i 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Copyright © 2022 Vacation Rental Owners and Neighbors of Palm Springs. All rights reserved. This document contains information protected by copyright. No part of this copyrighted work may be reproduced, duplicated, modified, or distributed in any form or by any means or stored in any database or retrieval system without the prior express written permission Copyright violations may carry civil and criminal penalties. 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) ii 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Contents 1 Introduction ....................................................................................................... 1 1.1 VRON-PS Purpose ....................................................................................... 1 1.2 Supplemental Comments and Data Report ...................................................... 1 2 Vacation Rental Density ...................................................................................... 1 2.1 City-wide Permit Caps Must be Applied When Dealing with Density .................... 1 2.2 A City-Wide Cap Must Allow for Application Exceptions ..................................... 2 2.3 Implementing 10% or 20% Density by Neighborhood ...................................... 2 2.3.1 Caveats to the information contained in Section 2: .............................. 3 2.3.2 10% Neighborhood Density .............................................................. 3 2.3.3 20% Neighborhood Density .............................................................. 5 2.4 VR Density Caps by Neighborhood are an Experiment ...................................... 7 2.5 Why Not Limit the Density of 2nd/Vacant Homes by Neighborhood? .................... 8 3 Ancillary and Secondary Use ............................................................................. 10 3.1 Owners Do Stay in their Vacation Rentals ..................................................... 10 4 Impacts Toward Housing Supply ...................................................................... 13 4.1 Summary of Studies Provided to the Work Group .......................................... 13 4.1.1 Forbes: ........................................................................................ 13 4.1.2 Economic Policy Institute (a non-partisan think tank): ........................ 14 4.1.3 Harvard Business Review ............................................................... 14 4.1.4 Milken Institute ............................................................................. 15 4.2 2010 vs. 2020 US Census Use of Housing Changed ........................................ 15 Appendix A: City Map of Areas Not in a Named Neighborhood .................................... 1 Tables Table 1: Percent Total Permits per Neighborhood City-Wide Impact ........................................ 2 Table 2:10% Density per Neighborhood City-Wide Impact ..................................................... 4 Table 3: % of Vacant Homes by Neighborhood ............................................................... 9 Table 4: 2021 VR Owner Occupied Stays by Week ................................................................ 11 Table 5: 2010 vs 2020 Census Change in Type of Residential Usage ....................................... 16 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 1 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 1 Introduction Vacation Rental Owners and Neighbors of Palm Springs (VRON-PS) is a 501(c)(4) non-profit incorporated in California in 2017. Our 11-member Board of Directors volunteer their time. 1.1 VRON-PS Purpose VRON-PS is dedicated to preserving Palm Springs’ rich history of vacation rentals and home- sharing through education, awareness, and the promotion of responsible vacation rental ownership and management. 1.2 Supplemental Comments and Data Report This report has been prepared to supply the City Council, City Staff, and the public with additional concerns and/or information and data that was not included in the City’s September 22, 2022, VR Work Group Recommendations Final Report. This report is not intended to recap any of the narrative already contained in the City’s report. Instead, it is intended to provide data information that was electronically sent prior to each meeting and presented to the Work Group but not allowed to be included in the final report. Today’s tourists are looking for different types of accommodations including small intimate hotels, larger international brands, resort hotels, and vacation rentals. This report contains three major sections following the Council’s interest in seeing recommendations about: § Vacation Rental density § Vacation Rentals as an ancillary or secondary use of one’s property § Impacts towards housing supply 2 Vacation Rental Density 2.1 City-wide Permit Caps Must be Applied When Dealing with Density By far the most difficult and complex of the 3 Work Group topics, the discussions on density originally were focused on only including a city-wide density by every named neighborhood organization at 7%, but this approach was deemed problematic for a few reasons. There are over 7,700 residences not in a designated named neighborhood, which presents a challenge with this approach. Further, this 7% density would allow approximately 2,500 permits which is close to the current permits issued by the City, however, a density percentage would not account for the future growth in new housing and actually allows for more permits over the coming years as newer neighborhoods are built. VRON-PS requested a discussion about a city-wide cap on the total number of permits regardless of the density. VRON-PS voted for and fully supports the 2,500 city-wide permit cap. 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 2 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 As the discussions about neighborhood density continued to explore different percentages, none of these higher density limits can achieve their desired goal without also including a city- wide cap of 2,500. For example, the table below demonstrates a 10% neighborhood density will produce the undesired effect of allowing 3,180 permits. The density percent applied to all neighborhoods must also have a city-wide cap or else the desired limit on total permits cannot be achieved. Table 1: Percent Total Permits per Neighborhood City-Wide Impact 2.2 A City-Wide Cap Must Allow for Application Exceptions It is obvious the number of new permits currently being processed will quickly exceed the 2,500-permit limit if Council wishes to implement this. Typically, an ordinance takes effect 30 days after the 2nd and final vote. However, in fairness to certain situations, the Work Group agreed to the following: • Homes who can provide documentation of the close of escrow within the previous 30 days after enactment will be allowed to apply for a permit and follow the same approval provisions in the current ordinance. • Homeowners with a valid permit who wish to change their property management from self-managed to agency-managed, agency-managed to self-managed, or from one agency to a different agency, will be allowed to do so at any time. A transfer of management does not require forfeiting a valid permit. Open Item: The Work Group discussed what will happen to owners who purchased a home 2- 18 months ago and the properties are undergoing complete renovations. These properties should have a single or multiple building permits from the City. However, these properties cannot apply for a permit prior to the city-wide cap going in effect because they are unable to pass the physical home inspection required to obtain a permit. VRON-PS is open to any discussions and ideas on how we can allow for these homes to complete their renovations and obtain a permit without the process being unfairly used as a workaround where the original intent of the owner was not to make the home a vacation rental at the time of purchase. 2.3 Implementing 10% or 20% Density by Neighborhood While the City’s Recommendations Report provided a list of neighborhoods above or below 10% or 20% density, there was no information provided summarizing how many neighborhoods nor the total number of permitted properties would be impacted by this 7/22 Permits% Permits of HH'sPermits at 7% per NORGPermits at 10% per NORGPermits at 15% per NORGPermits at 20% per NORG2,446 7.03%2,221 3,180 4,760 6,347 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 3 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 concept. It is virtually impossible to see the macro impact without this analysis. VRON-PS has produced the same data provided by the report but provided the table below ranked by neighborhood density to understand the overall impact. 2.3.1 Caveats to the information contained in Section 2: • 5 neighborhoods (bottom of the chart) are NOrg’s that contain an entire HOA that prohibits vacation rental permits and are not included in redistributing permits • There are approximately 7,700 residences that are not part of a name incorporated NOrg. They are widely dispersed across the City. An easy-to-understand map of the unincorporated areas can be found in Appendix A 2.3.2 10% Neighborhood Density Table 2 details the neighborhoods impacted by both permit reductions and additions. • 21 neighborhoods currently exceed the 10% threshold. The number of neighborhoods above 10% could increase if the Council implements this later in the year. • 20 neighborhoods are under the 10% density. A total of 788 properties must be redistributed to other neighborhoods over time. Racquet Club Estates would be particularly impacted since 154 permits would need to be eliminated. At some future point in time, when the 155th permit is forfeited, a new permit could be issued. VRON-PS assumes there will be a waiting list maintained for each neighborhood that is above the cap, and permits, when they become available, would be granted according to that list. 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 4 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Table 2: 10% Density per Neighborhood City-Wide Impact 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 B C G I K T U AA Distr ict #Neighborhood 7/28/2022 VR Count Households % Permits of HH's Permits at 10% per NORG Reduction / Increase per NORG NOTES 2 Racquet Club Estates 208 540 39%54 -154 3 Movie Colony East 166 773 21%77 -89 5 Tahquitz River Estates 126 613 21%61 -65 5 Twin Palms 90 329 27%33 -57 2 Desert Park Estates 102 465 22%47 -56 3 Sunrise Park 125 705 18%71 -55 1 Gene Autry 108 608 18%61 -47 2 Vista Norte 143 1069 13%107 -36 1 Demuth Park 101 683 15%68 -33 2 Ranch Club Estates 64 360 18%36 -28 3 Vista Las Palmas 69 419 16%42 -27 1 Sunmor 40 142 28%14 -26 3 El Mirador 37 158 23%16 -21 5 Deepwell Estates 66 451 15%45 -21 2 El Rancho Vista Estates 31 114 27%11 -20 3 The Movie Colony 34 199 17%20 -14 2 Racquet Club West 97 858 11%86 -11 5 The Mesa 37 277 13%28 -9 5 Indian Canyons 53 452 12%45 -8 4 Little Beverly Hills 25 178 14%18 -7 1 Lawrence Crossley 11 79 14%8 -3 5 Warm Sands 50 479 10%48 -2 -788 Permits Above Must Migrate to the NOrgs below over time 2 Oasis del Sol 56 562 10%56 0 2 Little Tuscany 68 690 10%69 1 3 Old Las Palmas 38 408 9%41 3 4 Araby Cove 7 109 6%11 4 4 Rimrock 0 61 0%6 6 4 Los Compadres 44 516 9%52 8 2 Whitewater Club 5 211 2%21 16 2 Rogers Ranch 9 431 2%43 34 5 Historic Tennis Club 16 518 3%52 36 1 Desert Highland/Gateway 11 480 2%48 37 5 Canyon Palms 7 445 2%45 38 4 Tahquitz Creek Golf 71 1150 6%115 44 3 Midtown 51 1036 5%104 53 4 Araby Commons 19 732 3%73 54 5 Andreas Hills 19 753 3%75 56 4 Gateway 1 584 0%58 57 1 Upper Westside 55 1247 4%125 70 4 Melody Ranch 10 826 1%83 73 4 Sonora Sunrise 85 1678 5%168 83 3 Baristo 25 1147 2%115 90 5 Canyon Corridor 10 1063 1%106 96 +788 Homes after all NOrgs above have been migrated No NRB 55 7782 1%778 723 Not assigned as this is an amalgam of unorganized NOrgs 1 Escena 0 587 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 1 Four Seasons 0 538 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 1 Mountain Gate 0 509 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 1 Palm Springs Villas II 0 461 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 4 West Gate PS 0 319 0%0 0 NOrg is an HOA probibiting 28 nights or less stays City Wide Total 2,445 34,794 7.03%3,238 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 5 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 2.3.3 20% Neighborhood Density Table 3 details the neighborhoods impacted by both permit reductions and additions. • 7 neighborhoods currently exceed the 20% threshold. The number of neighborhoods above 20% could increase if the Council implements this later in the year. • 34 neighborhoods are under the 20% density. A total of 173 properties must be redistributed to other neighborhoods over time. Racquet Club Estates would be particularly impacted since 100 permits would need to be eliminated. At some future point in time, when the 100th permit is forfeited, a new permit could be issued. 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 6 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Table 3: 20% Density per Neighborhood City-Wide Impact 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 A B H I V W X Y District #Neighborhood Households % Permits of HH's Permits at 20% per NORG Reduction / Increase per NORG Possible Distribution of Over- caps NOTES 2 Racquet Club Estates 540 39%108 -100 5 Twin Palms 329 27%66 -24 1 Sunmor 142 28%28 -12 3 Movie Colony East 773 21%155 -11 2 Desert Park Estates 465 22%93 -9 2 El Rancho Vista Estates 114 27%23 -8 3 El Mirador 158 23%32 -5 5 Tahquitz River Estates 613 21%123 -3 173 Permits Above Must Migrate to the NOrgs below over time 4 Rimrock 61 0%0 0 0 4 Gateway 584 0%0 0 0 1 Lawrence Crossley 79 14%16 5 5 3 The Movie Colony 199 17%40 6 6 2 Ranch Club Estates 360 18%72 8 8 4 Little Beverly Hills 178 14%36 11 5 After all NOrgs above maxed out, the 2 Gene Autry 608 18%122 14 5 remainder get to share whats left 4 Araby Cove 109 6%22 15 5 3 Vista Las Palmas 419 16%84 15 5 3 Sunrise Park 705 18%141 16 5 5 The Mesa 277 13%55 18 5 5 Deepwell Estates 451 15%90 24 5 4 Demuth Park 683 15%137 36 5 1 Whitewater Club 211 2%42 37 5 5 Indian Canyons 452 12%90 37 5 3 Old Las Palmas 408 9%82 44 5 5 Warm Sands 479 10%96 46 5 2 Oasis del Sol 562 10%112 56 5 4 Los Compadres 516 9%103 59 5 2 Little Tuscany 690 10%138 70 5 2 Vista Norte 1069 13%214 71 5 2 Racquet Club West 858 11%172 75 5 3 Rogers Ranch 431 2%86 77 5 5 Canyon Palms 445 2%89 82 5 1 Desert Highland/Gateway 480 2%96 85 5 5 Historic Tennis Club 518 3%104 88 5 4 Araby Commons 732 3%146 127 5 5 Andreas Hills 753 3%151 132 5 4 Melody Ranch 826 1%165 155 5 3 Midtown 1036 5%207 156 5 4 Tahquitz Creek Golf 1150 6%230 159 5 1 Upper Westside 1247 4%249 194 5 5 Canyon Corridor 1063 1%213 203 5 3 Baristo 1147 2%229 204 5 4 Sonora Sunrise 1678 5%336 251 5 N/A*7782 1%1556 1501 Not assigned as this is an amalgam of unorganized NOrgs 1 Escena 587 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 1 Four Seasons 538 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 1 Mountain Gate 509 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 1 Palm Springs Villa II 461 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 4 West Gate PS 319 0%0 0 NOrg is an HOA probibiting 28 nights or less stays 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 7 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 2.4 VR Density Caps by Neighborhood are an Experiment Potential issues to consider: • Multiple cities in both Coachella Valley and other cities have limited vacation rentals to specifically zoned areas such as a tourist or commercial zone. The well-known aftermath of COVID has completely altered the housing landscape in the past 2 years making it difficult, if not impossible, to assess the impacts of these reductions to specific zoning areas. • Named, incorporated NOrg’s are a unique community feature in Palm Springs although the concept exists in other cities around the country. Incorporated NOrg’s have not been implemented in the rest of Coachella Valley. Applying a uniform density limit to NOrg’s (micro neighborhoods) has never been attempted anywhere in California or the US that VRON is aware of. • Realtors and buyers face confusion and potential risks regarding neighborhood density caps when purchasing a property with the intent to obtain a vacation rent permit. One example would be that a permit could be available when a buyer chooses a house but not available by the time that buyer closes escrow. Or simply the uncertainty of not knowing when a permit will become available in a particular neighborhood. We strongly recommend the City provide a publicly available specific street address lookup software took to provide both the availability of a permit in a NOrg as well as the number of permit applicants on a waiting list. • While studies are not conclusive, it has been posited that vacation rentals inflate real estate prices. If this were assumed to be true, it would follow that drastically limiting available permits on a neighborhood-by-neighborhood basis would create uncertainty in home valuations, both between different neighborhoods and within neighborhoods. Would the value of homes in a certain neighborhood change significantly as permit availability in that neighborhood changes? • As this approach will lead to permit density shifting from more dense neighborhoods to less dense neighborhoods, will it have an impact on the affordability of less dense neighborhoods? Currently, some of the more affordable neighborhoods in Palm Springs have a lower density of vacation rentals. 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 8 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 2.5 Why Not Limit the Density of 2nd/Vacant Homes by Neighborhood? VRON-PS hired National Demographics Corporation to provide a table showing the “vacant” residence rate by neighborhood for all the named neighborhoods. Concerns about not having full-time (owner or rental) neighbors was barely discussed in the workgroup, however, vacation rentals are publicly hounded by some residents as the #1 cause of a lack of full-time neighbors. The 2020 US Census completely disproves this. The table below was electronically provided to the City for distribution ahead of the meeting. This information was also printed and reviewed during the meeting. However, it was not included in the final report which shortchanges the Council, Staff, and public from seeing a key piece of the puzzle in why some people say, “I can’t go next door to borrow a cup of sugar.” 31.3% of all Palm Springs residences are not full-time “owner occupied” or rented full-time as defined by the 2020 US Census. These are classified by the Census Bureau as “vacant”. As expected, there is a wide variance by neighborhoods, basically tracking with the home values. For example, Vista Las Palmas is 56.2% 2nd homes. • 12 neighborhoods range are 40%+ 2nd homes • 13 neighborhoods range from 30% to 38.2% 2nd homes • 15 neighborhoods range from 20.3% to 29.2% 2nd homes • 12 neighborhoods range are below 20% 2nd homes 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 9 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Table 3: % of Vacant Homes by Neighborhood NDC 8/29/22 Source: National Demographics Corp - 2020 Census Neighborhood City's HH Count % Owner Occupied % Long Term Renter Occupied % Vacant Non-STR Vacancy % of HH STR % of HH Whitewater Club 211 n/a n/a n/a n/a 2.8% Vista Las Palmas 419 35.7%17.5%56.2%39.7%16.5% Canyon Corridor 1,063 36.8%14.2%51.5%50.5%0.9% Tahquitz Creek Golf 1,150 31.7%2.5%50.7%45.0%5.7% Melody Ranch 826 40.3%8.1%49.8%48.5%1.2% Old Las Palmas 408 29.2%19.5%46.7%37.6%9.1% Sonora Sunrise 1,678 41.6%14.9%44.8%40.0%4.8% West Gate PS 319 37.4%4.7%43.8%43.8%0.0% Sunmor 142 28.1%51.7%43.7%14.8%28.9% Twin Palms 329 52.6%19.5%43.6%16.9%26.7% Midtown 1,036 40.2%9.3%42.5%37.6%4.9% Palm Springs Villas II 461 30.9%18.3%41.6%41.6%0.0% Canyon Palms 445 48.0%5.3%41.0%40.1%0.9% Andreas Hills 753 48.6%10.6%40.2%37.7%2.5% Racquet Club West 858 63.7%13.6%38.2%26.8%11.4% Historic Tennis Club 518 29.5%26.9%38.1%35.0%3.1% Rogers Ranch 431 51.5%8.8%37.9%36.2%1.6% Oasis del Sol 562 51.5%8.8%35.4%26.2%9.3% The Mesa 277 37.7%17.2%35.4%22.0%13.4% Indian Canyons 452 40.5%10.7%34.7%23.6%11.1% Araby Commons 732 39.2%38.4%33.4%30.8%2.6% Vista Norte 1,069 47.6%21.0%32.4%19.4%13.0% Tahquitz River Estates 613 50.2%19.0%31.9%12.0%19.9% Little Tuscany 690 35.7%21.4%31.6%22.2%9.4% Deepwell Estates 451 55.3%18.0%31.4%17.5%14.0% El Rancho Vista Estates 114 56.6%14.8%31.0%7.3%23.7% Movie Colony East 773 40.4%25.1%30.2%9.1%21.1% No NORG 7,782 46.5%22.4%29.2%28.6%0.6% El Mirador 158 25.9%51.8%29.0%6.9%22.2% Racquet Club Estates 540 43.6%23.9%29.0%0.0%35.9% Upper Westside 1,247 48.7%27.6%28.6%24.4%4.2% Escena 587 56.6%14.8%27.9%27.9%0.0% Little Beverly Hills 178 38.1%16.0%27.8%12.6%15.2% Sunrise Park 705 27.7%44.0%25.1%7.8%17.3% Araby Cove 109 58.3%10.7%24.1%17.6%6.4% Baristo 1,147 22.8%50.0%22.6%20.4%2.2% The Movie Colony 199 43.8%12.9%22.4%4.3%18.1% El Dorado Palms n/a 48.9%25.4%21.8%n/a 0.0% Desert Park Estates 465 68.6%16.2%20.6%0.0%22.2% Gateway 584 25.7%57.1%20.4%20.2%0.2% Mountain Gate 509 47.6%12.2%20.3%20.3%0.0% Ranch Club Estates 360 57.5%15.2%19.5%1.4%18.1% Warm Sands 479 34.4%38.5%19.1%9.7%9.4% Gene Autry 608 57.3%16.4%18.6%1.8%16.8% Rimrock 61 50.8%19.3%17.5%17.5%0.0% Lawrence Crossley 79 53.0%12.1%16.4%3.8%12.7% Parkview South Belardo n/a 37.7%17.2%16.4%n/a 0.0% Demuth Park 683 50.9%33.7%15.4%1.9%13.5% Los Compadres 516 31.4%49.6%14.6%7.1%7.6% Four Seasons 538 55.2%26.9%13.2%13.2%0.0% Desert Highland/Gateway 480 39.1%21.3%12.3%10.0%2.3% Citywide Totals 34,794 41.9%23.7%31.3%24.5%6.8% 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 10 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 3 Ancillary and Secondary Use 3.1 Owners Do Stay in their Vacation Rentals VRON-PS presented information to the Work Group showing the average percentage of time an owner(s) occupies their rental. The data shows that statements that “owners never occupy their rentals” are simply not true. VRON-PS does not make use of popularly known AirDNA data for various reasons having to do with how the data is collected and its resulting unreliability. However, Visit Greater Palm Springs subscribes to KeyData, a national company providing hospitality data about vacation rentals. This data is highly accurate because it comes directly from (interfaces with) property management companies’ reservation and booking software systems. Homeowners who 100% manage their own properties do not use these systems. KeyData reported on slightly less than 600 agency managed homes. All of these are local Palm Springs based companies with hundreds of employees collectively. The table on the next page shows a weekly percentage distribution of use. Someone is occupying the home, or it is not available due to maintenance 62% of the year. The annual averages for specific uses are: • 35.4% as a paid rental • 7.6% the home is occupied by friends/family or is unavailable for maintenance work. • 19.2% the owner is occupying the house This means the average home is occupied or unavailable due to a maintenance hold 62% of the year and the owner is at the home 1/3 of the that time. 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 11 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Table 4: 2021 VR Owner Occupied Stays by Week Palm Springs Vacation Rentals (1/1/2021 to 12/31/2021 as of 4/10/2022) Weekly Percent of Use Date PAID RENTAL OWNER OCCUPIED MAINTEN ANCE / FRIENDS TOTAL OWNER as % of TOTAL OCCUPANCY 1/1/21 31.5% 23.4% 10.0% 64.9%36.0% 1/8/21 31.8% 23.0% 10.3% 65.2%35.3% 1/15/21 35.6% 23.7% 10.5% 69.8%34.0% 1/22/21 33.7% 22.1% 9.8% 65.6%33.6% 1/29/21 36.3% 18.2% 7.2% 61.7%29.6% 2/5/21 41.7% 18.9% 6.2% 66.8%28.3% 2/12/21 54.5% 19.5% 5.4% 79.5%24.5% 2/19/21 47.7% 20.6% 4.7% 73.0%28.3% 2/26/21 47.6% 18.7% 4.1% 70.4%26.6% 3/5/21 52.1% 17.4% 4.6% 74.0%23.5% 3/12/21 53.9% 17.1% 4.6% 75.6%22.7% 3/19/21 58.5% 17.3% 3.9% 79.8%21.7% 3/26/21 58.1% 15.8% 4.1% 78.0%20.3% 4/2/21 57.5% 16.5% 4.1% 78.0%21.2% 4/9/21 50.8% 18.6% 5.4% 74.7%24.8% 4/16/21 44.7% 20.7% 5.0% 70.5%29.4% 4/23/21 42.8% 20.1% 5.3% 68.3%29.5% 4/30/21 37.7% 21.5% 4.8% 64.0%33.6% 5/7/21 36.0% 22.0% 5.4% 63.4%34.6% 5/14/21 36.2% 22.1% 5.0% 63.3%34.9% 5/21/21 33.5% 21.2% 5.5% 60.3%35.2% 5/28/21 40.0% 19.7% 5.5% 65.2%30.3% 6/4/21 31.7% 20.5% 5.9% 58.0%35.3% 6/11/21 36.0% 19.4% 5.2% 60.5%32.1% 6/18/21 35.0% 18.1% 5.7% 58.7%30.8% 6/25/21 31.8% 18.4% 6.0% 56.2%32.7% 7/2/21 35.7% 19.3% 6.8% 61.8%31.3% 7/9/21 26.0% 20.3% 7.8% 54.1%37.6% 7/16/21 28.2% 19.5% 7.8% 55.5%35.1% 7/23/21 27.8% 18.8% 7.7% 54.3%34.7% 7/30/21 27.3% 18.1% 8.0% 53.3%33.9% 8/6/21 25.3% 20.1% 8.3% 53.8%37.4% 8/13/21 25.0% 19.2% 9.1% 53.3%36.0% 8/20/21 21.3% 18.0% 9.6% 48.9%36.8% 8/27/21 17.9% 17.3% 9.6% 44.8%38.7% 9/3/21 27.1% 19.2% 9.4% 55.6%34.5% 9/10/21 17.6% 18.7% 11.4% 47.7%39.2% 9/17/21 20.6% 19.1% 11.0% 50.8%37.7% 9/24/21 22.5% 18.4% 11.0% 51.9%35.5% 10/1/21 24.6% 18.2% 9.1% 51.9%35.1% 10/8/21 28.7% 19.6% 9.1% 57.4%34.2% 10/15/21 29.1% 18.5% 8.7% 56.3%32.9% 10/22/21 27.6% 18.4% 9.4% 55.4%33.2% 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 12 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Palm Springs Vacation Rentals (1/1/2021 to 12/31/2021 as of 4/10/2022) Weekly Percent of Use Date PAID RENTAL OWNER OCCUPIED MAINTEN ANCE / FRIENDS TOTAL OWNER as % of TOTAL OCCUPANCY 10/29/21 27.6% 18.2% 10.1% 55.9%32.5% 11/5/21 34.8% 19.4% 10.0% 64.2%30.3% 11/12/21 33.3% 15.8% 10.3% 59.4%26.6% 11/19/21 47.8% 18.0% 8.6% 74.4%24.2% 11/26/21 29.2% 17.4% 10.2% 56.8%30.6% 12/3/21 26.7% 18.1% 10.4% 55.2%32.8% 12/10/21 24.2% 18.8% 9.7% 52.7%35.6% 12/17/21 36.3% 20.1% 9.7% 66.1%30.4% 12/24/21 51.5% 18.3% 8.1% 77.9%23.5% Annual Avg 35.4% 19.2% 7.6% 62.2%31.5% PAID - Occupancy percentage from paid guests OWNER - Occupancy percentage from homeowner stays only MAINTENANCE/FRIENDS - Maintenance Holds or block for non-paid friends/family OWNER as % of TOTAL - Owner occupancy as a percenatge of the TOTAL occupancy Source: KeyData Inc Report of 594 Palm Springs Agency Managed Properties 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 13 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 4 Impacts Toward Housing Supply 4.1 Summary of Studies Provided to the Work Group Important overviews note: The first three of these articles/reports, from Forbes, EPI and HBR, have one major factor in common: they are not analyzing the effects of the short-term rental industry as a whole. • They're analyzing the online marketing platform Airbnb. Airbnb's name is in the title of each article and the data and results cited are Airbnb-related only. The implication by those citing these sources in their arguments seems to be: As Airbnb goes, in any market, so goes the rest of the short-term rental industry, even in Palm Springs. • This is an inherently flawed argument as Airbnb is only one of the many available online marketing platforms available, and not all available properties are listed on Airbnb. • Additionally, Airbnb says their listings skew largely to homeowner-managed properties (as opposed to professionally managed properties), including both homesharing and whole-property units. • In Palm Springs we know roughly half of the listings are professionally managed, and not all managers use Airbnb. • Airbnb is not an accurate reflection of the entire short term rental ecosystem, especially in Palm Springs. • In Palm Springs, 34.6% (2020 US Census) of homes are second/vacation homes • STR's are heavily and effectively regulated, and apartments cannot be STR's. These first three reports do not account for this set of market-specific factors. 4.1.1 Forbes: "The Airbnb Effect on Housing & Rent" Key Finding: "An unforgiving approach to (annual lease) landlords and a lack of government capacity to deliver on their house-building promises are the bulk of the problem that’s propping up Airbnb as the visible, easily targeted problem." This is an article about housing issues in the UK. In his conclusion, the author admits that there are larger housing and regulatory issues in the UK (where STR's have been largely unregulated) and annual leasing landlords may be using "Airbnb" (STR) as an escape from the challenges of operating an annual lease property: "Whilst it’s easy to slay Airbnb as the cause of rising prices and lack of rental stock in popular cities, one can’t help but wonder if they aren’t merely the backdoor escape for landlords that have been cornered into an impossible scenario, with everything from scrapped tenant fee bans to zero mortgage relief, to a list of compliancy legislation so lengthy that it’s near impossible to self-manage a property, counting against them. Perhaps Airbnb is just the tip of the iceberg, where an unforgiving approach to landlords and a lack of government capacity to deliver on their house-building promises are the bulk of the problem that’s propping up Airbnb as the visible, easily targeted problem." 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 14 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 4.1.2 Economic Policy Institute (a non-partisan think tank): The economic costs and benefits of Airbnb - No reason for local policymakers to let Airbnb bypass tax or regulatory obligations. Key Finding: "The single biggest potential cost imposed by Airbnb comes in the form of higher housing costs for city residents if enough properties are converted from long-term housing to short-term accommodations." Specifically, the author cites three 2018 studies all done in New York City, in one of which "they find that a 10 percent increase in Airbnb listings in a ZIP code leads to a 0.42 percent increase in ZIP code rental prices and a 0.76 percent increase in house prices." One would have to read the individual studies in depth to decide if they agree with the assumption that Airbnb listings "lead to" rent and sale price increases. This study is analyzing the "benefits and costs" of a short-term rental platform (in this case Airbnb), and assumes that "Airbnb" rentals are not regulated, and not charging and remitting TOT to the City, like hotels do. This is not the case in Palm Springs. Many of the "costs" cited are assuming that dwellings would be occupied full time if not used as STR's, which is not historically the case in Palm Springs. As stated in the study: "If property owners take dwellings that were available for long-term leases and convert them to short-term Airbnb listings, this increases the supply of short-term rentals (hence driving down their price) but decreases the supply of long-term housing, increasing housing costs for city residents." Additionally, this study positions STR's against hotels, assuming guests will still travel to the destination, and simply stay in a hotel if STR's are not available. We know this is not the case, or even possible, in Palm Springs, due to capacity limits during peak demand (weekends, holidays, high season). STR's have historically had roughly half the bedrooms available for nightly accommodations in Palm Springs, and the hotels have been very supportive of STR's in Palm Springs. 4.1.3 Harvard Business Review Research: When Airbnb Listings in a City Increase, So Do Rent Prices Key Finding: "At the median owner-occupancy rate zip code, we find that a 1% increase in Airbnb listings leads to a 0.018% increase in rents and a 0.026% increase in house prices." This research focuses on analysis using Airbnb listing data only, not general market STR data (which would include other online marketing platforms and local management agency data). The author states early in the article: "Critics...have argued that home-sharing platforms like Airbnb raise the cost of living for local renters. There is not much evidence to support this claim one way or the other." Their finding is: "At the median owner-occupancy rate zip code, we find that a 1% increase in Airbnb listings leads to a 0.018% increase in rents and a 0.026% increase in house prices." Palm Springs is not at or near the median owner-occupancy rate but skews much lower. They also propose: "because of Airbnb, absentee landlords are moving their properties out of the long-term rental and for-sale markets and into the short-term rental market." This is a flawed argument in a market like Palm Springs, especially given that apartments are not allowed to do short term rental. Their analysis leans heavily on the assumption that "non- owner-occupiers are more likely to reallocate their homes from the long- to the short-term rental market." We know that Palm Springs is more of a vacation/second home market than an "investment" market. Most absentee landlords have no desire to use the property themselves, and don't want to go to the trouble and expense ($75-100K+) of fully furnishing/equipping a 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 15 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 home, then paying all the utilities and managing the reservations (or paying a manager a higher rate to do it for them). 4.1.4 Milken Institute Staying Power: The Effects of Short-Term Rentals on California's Tourism Economy and Housing Affordability Key Finding: "STR's account for about only 1 percent of California's housing stock (5.3% in the Palm Springs Desert) and most are expensive single-family homes that would not otherwise add to the needed affordable housing supply." This report has two important and helpful standout qualities. It's an analysis of STR's (not just the company Airbnb) and is focused on California, and even includes extensive region-specific data in its analysis, including the "Palm Springs Desert". It states: "Adopting strict regulation against STR's does not solve the housing shortage and could have the unintended consequence of depriving state and local governments of a major source of tax revenue as a result of reduced travel-related spending." And "STRs are not a significant driver of increasing housing unaffordability and availability, which is instead driven by decades of underdevelopment, especially of affordable multifamily units." 4.2 2010 vs. 2020 US Census Use of Housing Changed The table below was provided in the City’s Recommendations Report without an explanation of the lengthy discussion that occurred at the 3rd meeting. There have been years of comments that vacation rentals are the root cause of the City’s rental housing shortage, though the link between short-term rentals and housing prices is questionable (see above articles). There are other factors, however, that require discussion. This table shows the changes in the US Census housing category units between 2010 and 2020. While the total population increased by less than 100 in population, the use of units changed by 2020: • There were 393 or 1.1% new units built since 2010. • Full-time Owner Occupied increased by 1,804 or 13.4% • Vacant (2nd homes neither Owner Occupied or a Full-time Rental) decreased by 1,042 or 8.7%. Vacation Rentals fall under the Vacant Units category. The City has more Owner-Occupied units, but that has decreased the supply of long- term rentals. Since the number of “vacant” units (which includes vacation rentals) also decreased, it follows that the increase in owner occupied units has more to do with the decrease in full-time rental units than vacation rentals do. Apartment building rentals are legally prohibited from being vacation rentals which is strictly enforced. 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) 16 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Table 5: 2010 vs 2020 Census Change in Type of Residential Usage 2010 to 2020 Housing by Type of Use Source: National Demographics Corp - 2010 2020 Census/ACS Neighborhood 2010 Housing Units 2020 Housing Units 2010 Owner Occupied 2020 Owner Occupied 2010 Housing Full Time Rental 2020 Housing Full Time Rental 2010 Vacant Units 2020 Vacant Units Citywide Totals 34,791 35,184 13,458 15,263 9,287 8,649 12,046 11,004 Change in # of Units 393 1,805 -638 -1,042 % Change 2010 to 2020 1.1%13.4%-6.9%-8.7% % of Total Housing 38.7%43.9%26.7%24.9%34.6%31.6% 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) A-1 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Appendix A: City Map of Areas Not in a Named Neighborhood Areas in purple are not in a named neighborhood. S Gene Autry TrlE Vista Chino S Ave CaballerosS Sunrise WayE Alejo Rd S Indian Canyon DrE Tahquitz Canyon Way S El Cielo RdE Ramon Rd E Bogert Trl E La Verne Way E Palm Canyon Dr E Mesquite Ave Farrell DrN Cerritos DrW San Rafael Dr W Racquet Club Rd E Tachevah Dr W Tramview Rd National Demographics Corporation, September 2, 2022 Color Key: Light purple: City area not assigned to a neighborhood. Light Grey: Official neighborhood areas Pink dots: STR permits outside of recognized neighborhoods. �2021 CALIPER 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) A-2 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 Appendix B: National Demographics Corp Letter Phone: (818) 254-1221 P.O. Box 5271 info@NDCresearch.com FAX (818) 254-1221 Glendale, CA 91221 www.NDCresearch.com July 18, 2022 To: Vacation Rental Owners and Neighbors of Palm Springs (VRON-PS) From: Douglas Johnson, President Daniel Phillips, Consultant Re: Neighborhood by Neighborhood Housing Data Analysis National Demographics Corporation (NDC) has been contracted (or engaged) by Vacation Rental Owners and Neighbors of Palm Springs (VRON-PS) to supply 2010 and 2020 census data on a citywide a neighborhood organization basis. Since 1979, NDC has provided expert analysis of Census data for local governments and organizations across California and Arizona, including 2018 districting work for the City of Palm Springs and hundreds of cities, counties, school districts and special districts across the state. NDC has both decades of expertise in working with and analyzing Census data, and local expertise in Palm Spring’s neighborhoods from our districting experience with the city (which was heavily focused on the City’s recognized neighborhoods as building blocks for the Council districts). Differentiating between occupied, vacant and short-term rental housing neighborhood by neighborhood is a challenging task due to the need to compare and attempt to match up different data collected at different levels of geography: 1. The City provides its relatively precise counts of housing units by Neighborhood. But the City does not identify which (or how many) housing units in each neighborhood are occupied or vacant. 2. NDC complied the attached table of housing units, Short-Term Rental units, occupied housing units and vacant housing units. A few brief notes about the data used for this table follow. NDC and VRON-PS are happy to host a Zoom meeting with any or all members of the PS Vacation Rental Work Group to discuss this data in more detail. 3. VRON-PS provided NDC with the database of Short-Term Rentals with their addresses. NDC was able to use a combination of geocoded addresses and the City- identified neighborhood for each STR (where available) to precisely identify how many STR housing units are in each neighborhood (2,350 of the 2,351 STR permits in the city were successfully located). 4. The 2020 decennial Census identifies the total number of housing units and the number of occupied and vacant housing units in each Census Block. (A short-term rental property would be considered “vacant” in the decennial Census count.) Census Blocks roughly correlate to actual city blocks. Many Palm Springs 9/29/2022 Public Comment Item 3A Vacation Rental Owners & Neighbors of Palm Springs (VRON-PS) A-3 611 S Palm Canyon Drive # 7-120, Palm Springs, CA 92264 National Demographics Corporation Page 2 Neighborhood boundaries do not precisely match Census Block boundaries. And where Neighborhood boundaries do follow actual city blocks, the decennial Census household count often still varies somewhat from the City’s household count for that neighborhood. But while the databases may disagree on whether there are 450 or 465 housing units in a given neighborhood, the percentage of the housing units in the relevant Census Blocks is likely a reliable estimate of the vacancy rate of a given Neighborhood. For example, the image below shows (in colors) the boundaries of Movie Colony East and Rogers Ranch. The red lines, which follow the roads, indicate the Census Block boundaries that follow the actual city blocks. So while the housing units count for the Census Blocks circled in red around Movie Colony East will include some Rogers Ranch housing units and thus differ from the official City counts, it is likely that the vacancy rate for the red-outlined area around Movie Colony East is a pretty accurate percentage for vacancies in Movie Colony East: 5. Where data are shown as “n/a,” the Neighborhood is entirely contained within Census Blocks that are parts of other neighborhoods and thus NDC does not have estimates for the “n/a” Neighborhood. 9/29/2022 Public Comment Item 3A From:JF S To:City Clerk Cc:JF S Subject:Comments to council meeting on September 29th, item: REVIEW AND DISCUSSION OF VACATION RENTAL WORKGROUP RECOMMENDATIONS Date:Wednesday, September 28, 2022 6:13:25 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. To all the honorable council members, My name is Jesus Salcedo, I am a Palm Springs resident and registered voter in Palm Springs. I reside at 1577 S. Riverside Dr. I am writing to submit my concerns with the recommendations made by the VR workgroup. While I believe that some effort needs to be made to improve the existing ordinance, I do not think the recommendations made by the group will achieve this goal. Limiting the total number of VR licenses in the city will create chaos in the real estate market. It will also limit the amount of investment that comes to the City as the potential for economic growth is stunted by these limits. From the Staff report you can see that the natural number of STR licenses hovers around the same year after year. This recommendation does not fix any problems because no problem exists. The second recommendation made by the group: To limit the number of STR licenses to a random 10% by neighborhood reeks of favoritism, at best, towards the neighborhoods with larger lots and fewer homes. This will undoubtedly result in the more densely built neighborhoods being gentrified and push lower income residents further out of town; as these neighborhoods would naturally support more VR licenses under this extreme solution. I believe the improvements on the VR Ordinance should be focused on building on an already good framework for the coexistence of wonderful residents and fantastic visitors. Do not let a few bad apples on either side spoil what you have created. Lastly, the staff report does not fully show the effects that the VR homes have on housing affordability in this City in particular. About 50% of the homes belong to people with at least one other home elsewhere. This needs further study and specific, local solutions that do not displace residents should be considered. I support changes to the ordinance and appreciate the work done by the "VR 9/29/2022 Public Comment Item 3A workgroup" and yourselves; but I do not support hasty changes that do not take into account all sides of the coin. The impact of your decisions will have long term effects on the City and us, its residents. Please consider giving this matter the time and effort that it deserves and do not proceed with unnecessary speed that may appear to be driven by reasons other than the well being of all of us, residents of Palm Springs. sincerely and respectfully yours, Jesus Salcedo 1577 S. Riverside Dr. Palm Springs, CA 92264 9/29/2022 Public Comment Item 3A From:Greg Roberts To:Lisa Middleton; Grace Garner; Dennis Woods; Geoff Kors; Christy Holstege; City Clerk; gwroberts1592 Subject:Comments for Council meeting on 9/29/22 re Vacation Rental and Homeshare Workgroup Date:Tuesday, September 27, 2022 3:26:49 PM NOTICE: This message originated outside of The City of Palm Springs -- DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Mayor, Mayor Pro Tem and Council members: It was an honor and pleasure to serve on the Vacation Rental and Homeshare Workgroup. As a citizen of this great city I was proud to see the thoughtful, data driven, utilitarian recommendations of this workgroup. As a citizen, I would encourage you to adopt the recommendations of this group. As you know, this is a contentious issue with widely divergent views; however, I find these recommendations to be a measured response that does no immediate harm but, through time and attrition, level sets most of the major issues from all perspectives. You can be very proud of the work of the City staff that guided these discussions and carefully and accurately documented the recommendations before you. There is no panacea but this is a logical, rational start to doing the greatest good for the most people who live, visit, work and love this great city. Thank you for your consideration. Please approve these recommendations. Regards, Gregory Roberts 09/29/2022 Public Comment Item 3A 1 Brent Rasi To:Dennis Woods Subject:RE: New Changes Will Hurt My Family's Welfare On Sep 27, 2022, at 2:54 PM, David Magidoff <David.Magidoff.319664498@p2a.co> wrote: NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Dennis Woods, I appreciate that change and progress always needs to happen in government. But the 2500 cap and 10% proposal for PS VRs will directly affect the welfare of my family. My wife and I are expecting our first child in December and this could not be more despondent news. We strongly ask that there are more reasonable considerations proposed first before such extreme measures are considered. VRs are a lifeline into the economic life blood of Palm Springs. We are incredibly proud of the rules and regulations that we have done for our VR, creating an environment of safety and quiet for all neighbors around us. It is something we put as priority number one. And we have many friends who do the same. Let's find less dramatic ways to find health and compromise to all visitors and neighbors. Thank you for reading. Regards, David Magidoff 1111 E Palm Canyon Dr Palm Springs, CA 92264 09/29/2022 Public Comment Item 3A 1 Brent Rasi To:Dennis Woods Subject:RE: Feedback on Proposed Changes to STVR Regulations NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Dennis Woods, I moved out to Palm Springs three years ago to launch a luxury vacation rental business. We use the latest technology including Noise Aware and Party Sqausher in each house. Along with signage around the house reminding guests of the STR noise ordinance. And an in person check in. We have NEVER had an issues. We are a professional management company that communicates to our guests 24/7. My family, my manager and crew depend on this business to earn a living. I would hope that managers that operate at a high level of compliance not be dragged into the bad apples. Maybe require all homes to be managed by professional managers with the technology and contracts we use. It will eliminate issues. This way Palm Springs restaurants and businesses will continue to succeed. I would have never discovered Palm Springs had it not bee for Airbnb and renting mid century modern houses that you cannot find anywhere else in the country. Please allow the market to continue with professional managers. Regards, Kevin Kaiser 777 E Tahquitz Canyon Way Palm Springs, CA 92262 09/29/2022 Public Comment Item 3A 1 Brent Rasi Subject:RE: Feedback on Proposed Changes to STVR Regulations On Sep 27, 2022, at 2:34 PM, Ray Goettl <Ray.Goettl.319672480@p2a.co> wrote: NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. Dear Councilmember Dennis Woods, Please consider that vacation rentals have been managed very well with few complaints since the last codes were put into place. Please also consider the vacation rental business provides income for many people who reside in Palm Springs, including me as a manager of just a few homes. In turn, I hire many local contractors and other business people for repairs, cleaning, etc. Lets not limit what people come to Palm Springs for, especially when it is working well and bringing money into our city! Sincerely, Ray Goettl Regards, Ray Goettl 1163 Pasatiempo Rd Palm Springs, CA 92262 09/29/2022 Public Comment Item 3A 1 Brent Rasi To:Monique Lomeli Subject:RE: 10% Cap on STR's Proposal From: Rob Cooper <psremodel@hotmail.com> Sent: Tuesday, September 27, 2022 4:21 PM To: Geoff Kors <Geoff.Kors@palmspringsca.gov>; Justin Clifton <Justin.Clifton@palmspringsca.gov>; Teresa Gallavan <Teresa.Gallavan@palmspringsca.gov>; Christy Holstege <Christy.Holstege@palmspringsca.gov>; Lisa Middleton <Lisa.Middleton@palmspringsca.gov> Subject: 10% Cap on STR's Proposal NOTICE: This message originated outside of The City of Palm Springs ‐‐ DO NOT CLICK on links or open attachments unless you are sure the content is safe. As a 22 year resident of the Twin Palms Neighborhood, I want to implore all of you to please please adopt this proposal to cap rental permits in our neighborhood. As you know Twin Palms is currently well above the proposed 10% at 27.36%. Please do not maintain the currant status quo. The un‐restricted flow of permits allowed on any given block has gone on much too long. Because of this, we are now surrounded on all sides with 12 STR's including 2 that are unpermitted. I am begging all of you to approve this "workable solution". Please allow us to maintain this "neighborhood" with the few remining full‐time homeowners that are left. Thank you very much. Robert Cooper 1835 Apache Cir 09/29/2022 Public Comment Item 3A