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Home My Public Portal AboutPublic Comment East West Hospitality / Tahoe Mountain Lodging Management Darrah Johnston From: Town of Truckee, CA <webmaster@townoftruckee.com> Sent: Tuesday, September 8, 2020 4:52 PM To: Truckee; Hilary Hobbs Subject: *NEW SUBMISSION* Public Comment Form for Short-Term Vacation Rental Ordinance and Permit Program Public Comment Form for Short-Term Vacation Rental Ordinance and Permit Program Submission#: 530675 IP Address: 108.215.193.24 Submission Date: 09/08/2020 4:52 Survey Time: 40 minutes, 18 seconds You have a new online form submission. Note: all answers displaying"*****" are marked as sensitive and must be viewed after your login. Name East West Hospitality/Tahoe Mountain Lodging Management Email bschuchardt@eastwest.com Phone (optional) Public Comment Please see attachment. lf your comment exceeds 2000 characters, please use the attachment function below to attach your comment in a separate document. Attachment Truckee STIR 9.8.2020.pdf Please ensure that you enter your email address in the box below and click the SUBMIT button to receive a copy of your submitted responses for Public Comment. Thank you, Town of Truckee This is an automated message generated by the Vision Content Management SystemTM.Please do not reply directly to this email. 1 t eastwest { HOSPITALITY formerly tahoe mountain lodging September 8, 2020 To Whom it May Concern: As a provider of luxury vacation rental services and HOA management in the Truckee community, in the neighborhoods of Old Greenwood, Gray's Crossing, and Northstar since 2005, East West Hospitality, formerly Tahoe Mountain Lodging submits the following commentary in response to the proposed short-term rental ordinance. In general, we support the idea of an ordinance, but in a mountain ski town that was built largely on an economy of tourism we also believe that it is prudent to welcome visitors and be mindful of the reality that tourist dollars support our local businesses, and keep our residents employed. We would like to supply our feedback on the following points: In regard to the occupancy limits, it was stated that there are to be "No more than two people per bedroom plus two additional people will be permitted, excluding children under five". In our view, occupancy limits should take into consideration that there are homes in the Truckee community that have rooms that provide sleeping accommodations that don't fit the California guidelines to be considered a bedroom because they don't have a closet. Specifically, we manage 38 mountain homes at Old Greenwood that have additional sleeping rooms that don't have closets, so are not defined as a "bedroom". They are an upstairs den with a closed door and convertible queen Murphy desk bed. Additionally, these residences have a bedroom with double bunk beds, as many homes in Truckee do. These bedrooms were designed to sleep four people. We currently accommodate 12 people in a 4-bedroom unit, (which is really 5 sleeping rooms, including the Murphy room). Many Truckee rental residences were designed similarly- with dens or pullout couches, and as such we recommend that occupancy limits should be based on bedding configurations, not by California's definition of a "bedroom", if they are to be addressed in this ordinance at all. Concerning "noise", the town of Truckee should have a separate noise ordinance that speaks to not being disruptive to neighbors, and that addresses quiet times. Regarding trash service, the ordinance needs to take into consideration that there are planned communities and HOAs within the Truckee area, which effectively address these issues without a bear box and provide their own trash removal service. As such, there should be an exemption process included in the ordinance. At Old Greenwood, for example, the HOA through its manager provides trash removal service for our fractional ownership associations (which include 38 mountain homes and 27 townhomes that rent from time-to-time). Additionally, per our HOA docs, standard bear boxes are not permitted. At Gray's Crossing, for example, bear boxes would have to be architecturally matched to the home, and therefore come at great cost to the owner. We don't find this necessary as our removal services address this issue safely and effectively. Although we share the neighborhoods in which we operate with bears, we have not historically had trash problems with residences under our management due to our operational procedures, coupled with owner and guest education. As pertains to fire safety, we would like some clarity on the carbon monoxide detector specifications. How far from each bedroom would the detector need to be located? In smaller residences this would be important information for compliance. We recommend prohibiting outdoor fire-rings, but to allow gas fire pits, which are already installed, and comply with Town of Truckee building code. Also, most of our BBQs are plumbed with natural gas hardline, and located at a safe distance from the structure, although at times not quite 10 feet away where it is not possible due to deck size. We recommend a reasonable safe distance exemption shy of 10 feet where needed. Minimum length of stay: it was stated that a two-night minimum rental length will be required. Minimum length of stay requirements should not be included in the ordinance. These are private homes, and owners should be able to incur the wear and tear to their residence if they see fit. Although one-night stays are rare, the way we operate our business is not to dictate the way guests wish to enjoy their vacation time. If this is enforced, would Truckee hotels have to take one-night stays off their books too? Special Events: "Weddings, corporate events, commercial functions, and any other similar events will be prohibited at STRs". We don't believe this ordinance should address special events. It is not fair and enforceable amongst all owners, regardless of rental status. For those owners who do not rent would this be allowed within the town? Once again, in a heavily tourist-based economy, this would negatively impact not only rental revenue, and deter people from choosing Truckee for their special occasion in favor of a more tourist- friendly environment, but also would negatively impact the local businesses that support events; such as caterers, event planners, private chefs, party rental companies, etc. Compliance: We are all for fair, reasonable, and equally enforced compliance across all Truckee communities. However, the penalties seem harsh and excessive. We are in favor of administrative penalties and citations, but the currently proposed fee structure seems too aggressive for even those owners renting in high-end communities. Permit Costs: should be prorated for the year, perhaps with an admin fee. The majority of our new residences join the rental program in advance of the ski season (ie: August, September, October). Under your proposed structure, these owners would have to pay a full year of registration to rent for just the beginning of fall, and then pay again in full for the upcoming year in October, regardless of purchase date or rental program start date. This does not seem fair or reasonable. Additionally, the fact that the permit does not follow the property at time of sale further supports a prorated approach. We would encourage the Town of Truckee to continue to see itself as a resort community that thrives on a foundation of tourism as a win-win in support of our local economy. While we back this ordinance because we believe it helps the Truckee community at large better manage itself, we also want to support and encourage tourism, rather than deter by allowing the Nimbyism of certain individuals to jeopardize the tourist friendly foundation that many of our local communities were built on. Thank you for your time and consideration of our feedback. The East West Hospitality Management Team W Kevin R.Graham Managing Partner I COO 10343 High Street, Suite 7 Truckee, CA 96161 HITLi E o: 530.550.3303 m: 530.448.3200 www.eastwest.com