Comments of the Carmel Highlands – Mal Paso Defense Alliance for the July 24th STR Meeting

There were two sets of comments and a letter from our attorney.  The one-page summaries of each are below.

Comments on the July 24th Staff Report

One-Page Summary Comments on July 24th Staff Report

CHMPDA Executive Sunnary and Comments, July 24 2019

Not submitted but available if needed: CEQA July 24 updated   (111 pages)

Executive Summary of Comments on the Draft Ordinances to be considered at the July 24th meeting

STR/Homestays have no realistic scenario where they supply the affordable accommodations near the coast desired by the CCC in the Greater Point Lobos area.

STR/Homestays will destroy still-occupied affordable worker housing in the Greater Point Lobos area.

The California Coastal Commission and the California League of Cities and Counties (July 12, 2019) were clear in their comments that Homestay/STR’s are not residential-equivalent uses, and that they are Visitor Serving Units.

The California Coastal Commission and the California League of Cities and Counties (July 12, 2019) were unanimous in their comments that Homestay/STR’s are forcing longer and longer commutes for workers, and driving up rents and home prices.

We endorse responsible access for everyone, and affordable housing near the jobs.  But the Draft Ordinances with have the opposite effect – drive worker housing away from the coast, and make visiting for them and their families prohibitively expensive.

STR’s not required by CCC if other low-cost options are available – such as those available in abundance in Big Sur, Carmel Valley, and the Greater Point Lobos area like campgrounds, RV parks, and low-cost hotels.  We are open to exploring further such options in ways compatible with the infrastructure, water and other capacities of this area.

Huge Increases in Day Visitors has made access to the coast difficult for everyone including residents.  STR’s will not increase access to the coast because there are not enough parking spaces, bathrooms, road capacity and other infrastructure to handle the existing and projected loads.  STR’s just add to the problem.

The Draft Ordinances are inconsistent with the Carmel Area Land Use Plan and other laws and plans governing the Greater Point Lobos Area, and the PC Staff analysis on this point is wholly deficient because it ignores clear and unequivocal language in the CALUP.

The Consensus Position which was endorsed by MPCPA and Preserve Carmel Highlands is also endorsed by CHMPDA.  In summary:

First – if you want to rent your house or apartment for car week, or the AT&T, or the U.S. Open – you can still do that.  Nothing prevents anyone from renting their house once a month.

Second – if you are a person and live here full-time and want to rent out a room in your home, while you live there, you can do that.  But, only if there is room in the Master Plan for more hotel rooms and somebody else didn’t get their first.

Third – really serious enforcement, or no rentals allowed.


One-Page Summary of Comments on the July 24, 2019 Staff Report by CHMPDA

One-Page Summary of Comments of the Carmel Highlands – Mal Paso Defense Alliance, a new association of Preserve Carmel Highlands, the Mal Paso Creek Property Association, and individuals throughout the Coastal Zone.

The Staff Report dated July 24, 2019 is a significant step forward.The Staff Report does not raise two issues that deserve to be brought to the attention of the Supervisors for their consideration and direction:  Americans with Disabilities; and, Enforcement.

The “Consensus Position”addresses the Enforcement issue, and the Carmel-by-the Sea and City of Monterey enforcement practices should be studies and adopted.  The Staff Report documents extensive cheating in the coastal zone. Enforcement  has been a source of frustration and tension for over 8 years now, and the current system isn’t working for residents or the County.

On the issue of Defining Principal Resident we support:

Option B. Other definition of principal resident.

The Consensus Position states:

Owner occupied and managed. No absentee owners, property management companies, corporations, or LLC’s would be permitted. The owner would be required to be a permanent year-round resident, and the home would be his or her primary residence. The owner would be required to live in, and be present on site, during the STR/Home Stay rental period.

Since this Consensus was achieved, one Planning Commissioner expressed their view that if an owner is long-term leasing to a person who lives and works in our community like a nurse, or a teacher, firefighter or similar occupation that they should also be allowed to have a Homestay-type STR.  If the resulting rule helps provide desperately needed affordable housing for the people who work in or near the coastal zone,  WE AGREE.

  1. Approval Threshold – Ministerial versus Discretionary: Option E is consistent with the Consensus Position, and that the Pacific Grove limit for Homestays is preferable (“Occupancy: A maximum of one bedroom may be rented to two adults; a second bedroom may be rented to children as part of the same contract.”)
  1. Visitor Serving Unit Counts: Option A is consistent with the Consensus Position. ” Option A : Where visitor serving limits apply, count each bedroom in a vacation rental as a visitor serving unit.” 

Carmel Area

Option A. Regarding Homestays in Carmel Area:  We believe the Pacific Grove limit for Homestays is best: (“Occupancy: A maximum of one bedroom may be rented to two adults; a second bedroom may be rented to children as part of the same contract.”)  Also consistent with the “Consensus Position”is “3. Allow homestays only in the Special Treatment Area – Point Lobos Ranch per CLUP Section 4.4.3.F.4; and, to “4. Restrict homestays to owner-occupied residences.”

%d bloggers like this: