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Apr 26, 2022
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20220426 public comment on item J2. Short term rental compliance update -- REVISED AND RESUBMITTED

Revised and Resubmitted

Dear Council

I have written to you many times regarding STR. In light of my limited time, I will be brief and happy to provide all my background research.

It is noteworthy that the issue of Short Term Rentals ("STR") has been, one way or another, discussed since at least 2016. I had to trace back all publicly available documents in providing these comments because we do not make it easy for residents to find information.

The current Staff Report 22-082-CC references the January 28, 2020 housing staff informational report, which summarized the results of the Housing Commission STR regulation community outreach process and community input as "no regulation was recommended." However, the outreach studies' factual details, including specific questions, background data presented to the respondents, and the number of each respondent within a category, are missing from all the public records. You know, all those pesky objective and based-on-science study design parameters!

Sadly all the decisions that are followed by the City are made referencing so-called data that, without more, is unreliable and suspect.

It is, however, clear from various City reports, including the AIRDNA 2019 report (which begs the question why did we need to pay for another report instead of using the 2019 report for collecting the taxes when we were supposed to) that over 70% of the rentals are unhosted and that about 1/3 of newer high-density multifamily residential properties are under corporate leases.

Previous Staff Reports, including the 2019 report, identified that corporate leased units remove rental units from the market and that the City should investigate and analyze further to determine if some type of separate regulation should be considered. To date, no regulation has been provided by the City.

The current staff report (which of course, does not release the actual HdL report), which was delayed for several years, set out to gather data to collect STR occupancy taxes. To gether this information, basic data had to be gathered. However, the current report, except for a few numbers, does not provide any of the critical underlying data (such as the number of rented nights and neighborhoods). I have personally contacted the City several times to no avail.

The City of New Orleans, for example, has an online map of all STRs and their registration status. Why are Menlo Park data, such as where these STRs are concentrated, withheld?

Feigning some sort of vague consensus during the 2019 outreach, for which we have no details other than a conclusory Staff presentation, the current Staff Reports states that "The common theme in almost every discussion or conversation held during the outreach on SRT regulation was that there was no desire for additional regulation that would place any controls or limits on SRT's." As a side note, many cities in Bay Area have some sort of STTR regulations.

It should be further noted that even if such a common theme were valid, the "outreach" was done 3 years ago in 2019 without the benefit of the present HdL report.

Unfortunately, these prolonged delays, lack of creditable data supporting Staff conclusions, and the lack of transparency leave the impression that the City is more interested in protecting the wealthy and corporations and not those burdened by the housing shortage.


Respectfully,

Soody Tronson
Menlo Park resident