CEQA EIR Required? Population and Housing

XII. POPULATION AND HOUSING –– Would the project:

a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?

b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere?

c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?


The Impact of Airbnb on NYC Rents : Office of the New York City Comptroller Scott M. Stringer

Airbnb gentrification: How the sharing economy drives up housing prices.

As the county struggles to address the issue of short-term vacation rentals, proponents organize while opponents worry about the fabric of their communities. | 0313 | montereycountyweekl

Rental housing shortage on Monterey Peninsula prompts call for referrals, finder_s fee of $500

Least Affordable Housing Market

Hawaii has record-low unemployment and it_s not a frozen hellscape. Why are people leaving? – The Washington Post

Airbnb Drives Up Rent Costs in Manhattan and Brooklyn, Report Says – The New York Times


The Long and Winding Road Leads to a Job In a Place You’ll Never Be Able to Afford

The local hospitality industry is reaching a critical point. The high cost of living is driving employees out of the Central Coast. Those help-wanted signs on restaurant windows are starting to yellow. HR departments are desperate to fill housekeeping positions. Nowhere is the problem more acute than in Big Sur, where affordable housing is nonexistent. According to hospitality leaders that Voices writer Laith Agha talked to, there are no immediate solutions, which means that the employees they do manage to hire must be willing to endure one long (if not beautiful) commute.

 long (if not beautiful) commute.

From Monterey Peninsula cities grapple with boom of short-term rentals, Monterey Herald, by JAMES HERRERA

“It’s purely financial,” one Monterey property owner said of her motivation to rent out short term. “To stay in my home, I need this income.” She asked that her name not be used for fear of repercussions from the city. Monterey prohibits rentals for fewer than 30 days.

She explained that renting out her extra rooms long term might bring in $600 to $1,000 each per month. But in the last five months she has rented them short term, bringing in $3,400 to $3,800 each per month.


From To Be or Air BnB; From Voices of Monterey Bay,

by Joe Livernois, 12/7/17




If it’s a hotel from the standpoint of the neighbors, it’s a hotel.

Are there frequent changes of strangers?

Is the income from rentals the principal source of repayment of loans on the property?  (or is it income from another job or proceeds from investments)

Do they make it hard to find a parking spot on your own street because of all the cars parked there?

Are the sounds of the place consistent with the particular residential neighborhood?

Does it have the consent of the neighbors to be there?

Does the owner contribute to the community by volunteering their time, making donations, and vote in the same District as the site?

The meaning of residential = the meaning when the ordinance was passed, the general plan approved, or even what existed at the time the LCP/LUp were approved by the CC.  Not what residential means in the age of AirBnB, VRBO etc.  it is by its very definition an intensification of that use as defined and meant and embodied in the LUP.  Just look at this room.  Just consider this process.  The term residential does not change with technology, and STR’s in the pre AirBnB world are not the same thing as STR’s that are part of a multibhillion dollar vertivcally and horizontally integrated industry.

STR’s have been banned for over 10 years in an LCP already approved by the CC.  Also, there are over 10,000 rooms that can be rented in the coastal zone once per 30 days, resulting in vast over capacity that, if utilized, would overwhelm the infrastructure and be a major intensification of use.

Renting a home to a potential audience of a few hundred, maybe a couple pf thousand people is one thing.  Renting thousands to a worldwide audioence of hundreds of millions is a factually and legally different thing.

Monterey Bay employers say lack of affordable housing a concern


Monterey >> A lack of affordable housing for workers emerged as the biggest concern of employers Thursday at a regional economic meeting.

About 70 people attended the Monterey Bay Regional Critical Conversation at Casa Munras Hotel, which focuses on a variety of issues of concern to businesses in Monterey, Santa Cruz and San Benito counties. Similar themes emerged among executives at Scotts Valley-based Fox Shox, Hyatt Regency Monterey Hotel & Spa and Spreckels-based Tanimura & Antle, who together represent about 4,300 workers.

“It is a challenge for the entry-level worker, who often has two jobs, to afford the housing in this area,” said Paula Calvetti, human resource director for Hyatt. “In all honesty, it’s more of a sticker shock.”

Affordability levels in all three counties have hit record lows, driving up the cost of rentals and hampering recruitment efforts. Tanimura & Antle’s human resources director, Larry Silva, said a need for housing is what led it to propose a $10 million, 800-person farmworker housing project in Spreckels.

Michael Cowen, human resource director for Fox Shox, said affordability levels in Santa Cruz County needed a special solution, like a light rail. When working for San Jose-based Cisco Systems, young engineers lived in townhouses in more affordable areas and would then take the train to work.

“Some sort of development like that would be really nice to see … so that people could (ride the train) and not have to have multiple jobs,” he said, adding that housing costs are affecting Fox’s ability to recruit high-level engineers.

Calvetti said employees are moving farther away than usual for housing, especially in Salinas. Housing costs are also part of the reason why Hyatt and Tanimura & Antle are having a hard time filling entry-level jobs.

“It’s an honorable profession. There’s nothing wrong with being a field worker,” Silva said.

In April, just 22 percent of homes in Santa Cruz County and 29 percent in Monterey County were considered affordable. In Monterey, a minimum qualifying income of $92,170 is needed to afford a home.

Rising home prices have also led to an increase in rents.

In March, Salinas made the top 10 in rent growth for California cities, according to the Apartment List Rentonomics blog.

California Association of Realtors chief economist Leslie Appleton-Young said at Thursday’s event that the state has gone through home affordability issues before but she can’t recall it being this bad.

“There are people all over California that probably want to see their grandchildren once in a while and don’t want their kids to move out of state because there’s no affordable housing,” she said.

She said local buyers are also competing with Chinese buyers who are paying more than asking price with cash. Chinese buyers bought 16 percent of all homes purchased by foreign citizens in 2014, according to the National Association of Realtors. About half of those homes purchased were in California.

“I don’t really think they have effective budget constraints, which is a fantasy for many of us,” she said.

The convention was also a chance for the Monterey Bay Economic Partnership to promote its website, which has data and help for businesses in all three counties, and Monterey County Business Council to show off its ACT WorkKeys program.

The WorkKeys Assessment is a national test used to rank potential employees and already used by Monterey-Salinas Transit, Hyatt, Encore Recycling and others.


“All those extra visitors must be staying somewhere, and that somewhere is private residences. Bonham estimates there were 14,000 rooms on the vacation-rental market in 2016 (that’s assuming full-time use, so the actual number is probably much higher), and every one of those is another unit that’s not available for residents looking to buy.”


STR’s Cause Sky-High Home and Long-Term Rental Prices; Washington Post

“All those extra visitors must be staying somewhere, and that somewhere is private residences. Bonham estimates there were 14,000 rooms on the vacation-rental market in 2016 (that’s assuming full-time use, so the actual number is probably much higher), and every one of those is another unit that’s not available for residents looking to buy.”

Key Points from the article:
Hawaii has record-low unemployment and it’s not a frozen hellscape. Why are people leaving?
Hawaii has the lowest unemployment rate of any state in recorded history, a good economic outlook, and — most attractive at this time of year — little chance of polar vortex or ‘bomb cyclones’.Yet in 2017 its population fell for just the third time since statehood in 1959.   . . . 
Which brings us to the core conundrum: people are leaving Hawaii even though the labor market is stronger than on the mainland, and even though it’s the high 70s in Honolulu this week. What could possibly be driving them away?
 . . . 
So why is anyone leaving?

One answer trumps all others: home prices. Hawaii has the most expensive housing in the nation, according to the home value index from housing website Zillow. Rent costs trail only D.C. and (in some months) California. Overall, Hawaii had the highest cost of living of any state in 2017 (D.C. was higher), the Center for Regional Economic Competitiveness found, and housing was the main driver.
 . . . 
It’s always been expensive to live in Hawaii, but it’s getting worse. There’s just not enough housing on the islands, and Hawaii now has one of the worst rates of homelessness in the country.
 . . . 
“[Visitors are] just not spending like they used to,” Bonham said. “They’re probably shopping at Target and Kmart and probably staying in a condo or at an Airbnb.”

That second part is the key.

All those extra visitors must be staying somewhere, and that somewhere is private residences. Bonham estimates there were 14,000 rooms on the vacation-rental market in 2016 (that’s assuming full-time use, so the actual number is probably much higher), and every one of those is another unit that’s not available for residents looking to buy.
The rise of the frugal tourist is also putting the squeeze on jobs and earnings. Residents who might have found work at higher-paying resorts in the past are now waiting on those same tourists at Target and Kmart instead. And they’re not likely to afford Honolulu housing on retail wages.

Average hourly earnings for private-sector employees in Hawaii ranked 15th in the nation over the past year, and they consistently grow more slowly than home prices.
As the changing character of Hawaii’s visitors squeeze residents on both ends, they may have no choice but to leave.

“There’s a connection there between that booming number of arrivals and that vacation-rental market and … some of the exits of people from the state because of rising costs,” Bonham said.

Amanda L Whitmire, Ph.D.


16 May 2017


Pacific Grove City Council

City Hall

300 Forest Avenue

Pacific Grove, CA


RE: Short-Term Rental (STR) Program in Pacific Grove


Dear members of the City Council of Pacific Grove,

My name is Amanda Whitmire, and I am a resident of Pacific Grove. I moved here with my husband and two young children a year-and-a-half ago to start my dream job as Head Librarian at Hopkins Marine Station. We would like to settle down in PG for the long term, but we have had a difficult time finding affordable housing. Our local issues of housing availability and cost, whether they be for ownership or long term rental, seem to be affected by several factors including military stipends, lack of opportunity for new development in the city, our desirability as a vacation destination, Prop 13, and proximity to the Bay Area housing and technology bubbles. Today I’d like to focus on one issue that you, our City Council, has control over: short-term rentals (STRs).

From what I can gather, the City has had an STR ordinance in place since 2010. According to the City’s STR Program web page[1], there are 222 active Type A STR licenses of a possible 250, plus an additional 40 Type B licenses for a total of 262 whole-home STRs in Pacific Grove. 262 homes in the STR market represents 3.1% of all houses in PG, 3.8% of all occupied homes, and 7.4% of all rental homes in the city [1]. It’s difficult to understand that number without context, so let’s examine the STR landscape at a few other California cities (Tables 1 and 2). In San Francisco, where AirBnB has been embroiled in lawsuits with the city for several years over the issue of STRs [2], short-term rentals available legally through AirBnB [3] account for only 3.7% of rental housing – that’s half the level that we see here in Pacific Grove. In Los Angeles, where landlords have been illegally evicting long term tenants to convert housing to short-term rentals, STRs available through AirBnB [3] account for only 3.5% of the rental housing market. In Anaheim, where the city government just passed an ordinance to phase out STRs over the next 18 months [4], legally operating STRs accounted for less than one percent of the rental housing market. Closer to home, Santa Cruz has 306 housing units registered with the city [5] and paying transient occupancy tax (TOT), while 372 units are listed on AirBnB [3], which account 2.5% and 3.1% of the total pool of rental housing in the city respectively. Recall that the number of licensed STRs in PG currently account for 7.4% of our rental market – double the proportion in these other cities. If you consider a more likely estimate of 400[2] STRs operating in PG, that’s over 11% of our rental inventory removed from the long-term rental pool. This does not include houses that sit empty; only houses that self-identify as rentals on the US Census. While the situations in these other cities clearly do not translate directly to our situation in Pacific Grove, it’s worth recognizing that we have a significantly larger percentage of our rental market tied up in short-term rentals than these other cities who have a well-documented history of housing troubles related to STRs.

Table 1. Table 1. Short-term rentals as a percentage of single-family and duplex housing in Pacific Grove, for all housing, occupied housing only, and occupied rental housing only. Assumes 4,867 total units

Estimated# of STRs Percent ofall housing Percent of occupied housing Percent of rental housing
Ojai [6], all illegal 315 9.9 10.8 23.2
Pacific Grove, legal only 262 5.4 6.6 12.8
Pacific Grove, realistic minimum 300 6.2 7.6 14.6
Pacific Grove, realistic high 400 8.2 10.1 19.5
Santa Cruz, units paying TOT 306 1.3 1.4 2.5
Santa Cruz, AirBnB only 372 1.6 1.7 3.1
Anaheim, legal only 356 0.3 0.4 0.7
San Francisco, AirBnB only 8,320 2.2 2.4 3.7
Los Angeles, AirBnB only 29,956 2.1 2.2 3.5

Table 2. Selected housing characteristics for California towns shown in Table 1. Data include total housing units, occupied units, owner-occupied units, and renter-occupied units. All occupancy data are shown in number and percent. Data source: US Census, American Community Survey

Total housing units Occupied housing units [N] Occupied housing units [%] Owner-occupied [N] Owner-occupied [%] Renter-occupied [N] Renter-occupied [%]
Ojai 3,179 2,926 92.0 1,569 53.6 1,357 46.4
Pacific Grove 4,867 3,953 81.2 1,901 48.1 2,052 51.9
Santa Cruz 23,499 21,526 91.6 9,459 43.9 12,057 56.0
Anaheim 104,812 99,670 95.1 46,534 46.7 53,136 53.3
San Francisco 383,676 353,287 92.1 128,698 36.4 224,589 63.6
Los Angeles 1,436,543 1,342,761 93.5 494,682 36.8 848,079 63.2


The next logical question is, do short-term rentals affect housing availability and cost? As I mentioned previously, the housing market is complicated and there’s not enough data to elucidate a causal relationship between STRs and the housing market. Some people like to argue that if there wasn’t an STR program, many homeowners would leave their home empty, so the long-term rental market isn’t affected either way. That’s a bit of a red herring. There are important ramifications beyond whether or not someone would rent out their house if there wasn’t an STR program. Having the option to have your second home as an STR incentivizes and directly supports some people in being able to afford to buy a second home here, and thus remove it from the residential market. When I make an offer on a home, I’m potentially competing with people from the Bay Area who like the idea of having a second home here but maybe can only afford the mortgage if they can rent it out as an STR. Can I prove that that’s affecting the market? No. No one can. But is it a reasonable scenario? Absolutely. The mere existence of an STR program enables further outside investment in our local market and limits my options as a long-term resident.

I am heartened to have read that the City is proposing changes to our STR program [7]. It demonstrates an important commitment to being open-minded and adaptable. There are still two major issues to consider: first, STRs in residential zones are a clear violation of the City plan; and second, will costs associated with the operation and enforcement of the program leave any revenue for the City? I’ve often heard lately that people should be able to do whatever they want with their home. This assertion is patently ridiculous. City zoning exists for the good of the community, and clearly defines what’s allowed. I can’t operate a restaurant or a goat farm at my home; you can’t operate a hotel out of yours. I’d like the City to consider restricting Type A licenses to R-3, R-4 and commercial districts only. Tourists want to be close to downtown and the beach, so let’s situate STRs right where the action is. Let’s make it as easy as possible for visitors to spend their money in our evolving downtown. Keep neighborhoods for residents!

On the issue of costs and enforcement, I have two small ideas to pitch. First, hire a programmer! A person who can write code to harvest data from home sharing service websites, or who can adapt the abundant code that already exists to do this [3,8,9], will be able to significantly streamline your monitoring and enforcement processes. You can and should automate the collection of TOT from rental companies. You should make compliance as easy as possible for operators of licensed STRs by offering online forms and payment. A programmer would also have the skills to implement my second idea, which is for the City to develop a smartphone app [10–12]. Relevant to this discussion, among the non-emergency problems you could report to the city, such as a street lamp being out or a new or growing pothole, you could also easily make an STR complaint or report a suspected violation. Help us help you.

I don’t think it’s necessary or feasible to end the STR program in PG, but it’s clear that STRs constitute a disproportionately large percentage of our rental market, and this needs to be addressed. STRs should be limited in residential districts as much as possible, if not eliminated. You need to hire someone with programming skills to automate and streamline as much of this program as possible, including the use of a smartphone app. In closing, I’d like to thank you for your time and for your continued willingness to hear from the residents of Pacific Grove.

Sincerely yours,


Amanda L. Whitmire


  1. City of Pacific Grove 2016 “City of Pacific Grove Housing Element” Available: http://www.cityofpacificgrove.org/sites/default/files/general-documents/planning-codes-regulations-and-maps/final_pg_he_2015-2023.pdf
  2. Farivar C. San Francisco, Airbnb settle lawsuit over new short-term rental law. Ars Technica. 2 May 2017. Available: https://arstechnica.com/tech-policy/2017/05/san-francisco-airbnb-settle-lawsuit-over-new-short-term-rental-law/. Accessed 16 May 2017.
  3. Murray Cox. Inside Airbnb. Adding data to the debate. In: Inside Airbnb [Internet]. [cited 16 May 2017]. Available: http://insideairbnb.com
  4. City of Anaheim. Short-Term Rental Program. In: City of Anaheim Official Web Site [Internet]. 2017 [cited 16 May 2017]. Available: http://www.anaheim.net/574/Short-Term-Rental-Program
  5. City of Santa Cruz. Short-Term Rentals (STRs). In: City of Santa Cruz [Internet]. [cited 16 May 2017]. Available: http://www.cityofsantacruz.com/departments/short-term-vacation-rental-stvr
  6. Claudia Boyd-Barrett. Ojai enforcing short-term rental ban. Ventura County Star. 5 Jan 2017. Available: http://www.vcstar.com/story/news/local/communities/ojai/2017/01/05/ojai-enforcing-short-term-rental-ban/95929698/. Accessed 16 May 2017.
  7. Mayberry C, Herald M. Pacific Grove recommends changes to city’s short-term rental program. 15 May 2017. Available: http://www.montereyherald.com/article/NF/20170515/NEWS/170519862. Accessed 17 May 2017.
  8. Tom Slee. Airbnb Data Collection: Get the Data. In: Tom Slee [Internet]. 17 Mar 2017 [cited 16 May 2017]. Available: http://tomslee.net/airbnb-data-collection-get-the-data
  9. Commerce Data Usability Project. the roof!, the roof is on fire! In: Commerce Data Service [Internet]. Mar 2016 [cited 17 May 2017]. Available: http://commercedataservice.github.io/tutorial_zillow_acs/
  10. A. Janell Williams. App happy: Cities, groups connect with smartphone apps. The West Volusia Beacon. 30 Nov 2016. Available: https://www.beacononlinenews.com/articles/2016/11/30/app-happy-cities-groups-connect-smartphone-apps. Accessed 17 May 2017.
  11. Roz Edward. City Councilmember Keisha Lance Bottoms looks to enable residents with all-in-one, downloadable app. Atlanta Daily World. 25 Apr 2017. Available: https://atlantadailyworld.com/2017/04/24/city-councilmember-keisha-lance-bottoms-looks-to-enable-residents-with-all-in-one-downloadable-app/. Accessed 17 May 2017.
  12. Sherman A. 5 Cities Benefiting From Mobile Apps. Mashable. 30 Mar 2012. Available: http://mashable.com/2012/03/30/city-mobile-apps/. Accessed 17 May 2017.


[1] http://www.cityofpacificgrove.org/living/community-economic-development/short-term-rental-program

[2] On 16 May 2017, Amanda Whitemire Phd identified 474 “whole house” listings available in Pacific Grove on VRBO, 300+ on AirBnB, and 158 on FlipKey. Even accounting for double listings, 400 is not an unreasonable estimate.

  1. “Of particular concern to officials are the Airbnb hosts who lease multiple apartments, renting them out year-round and distorting their market value in a climate of scarce affordable housing. One Airbnb user who spoke with the Times provided a glimpse into how lucrative the scheme could be. Josh, who agreed to describe his business on the condition that his last name not be used because he was fearful of legal penalties, said he rents out five apartments in Manhattan. Each one earns about $100,000 a year, he said, totaling about half a million dollars annually before fees. Only one of the leases is in his name, he said. The other four are held by people he has recruited to sign the leases in exchange for a percentage of the rental income. The arrangement is illegal. The New York State Multiple Dwelling Law prohibits apartment rentals of less than 30 days unless a permanent occupant is there. Yet Josh said that he personally knew several others engaged in the scheme in New York City. 124 hosts, all of whom had a minimum of 10 listings on the site and were earning an average of $500,000 a year.” (“Hotels in Disguise”, New York Times, December 3, 2015)

  2. “. . . the agent’s relationship with Airbnb soon shifted from desperation to opportunism. Realizing the potential to exploit the difference between long- and short-term rental prices, he signed a lease on a second Manhattan apartment this summer. He now uses it solely for Airbnb, generating up to $6,000 a month in profit. Last month, he added a third rental — this one under his wife’s account. He plans to add more, he said, possibly even under phony accounts to avoid legal scrutiny. . . Another New Yorker, a 49-year-old entrepreneur (who also insisted on anonymity), got his start on the site after shareholders pushed him out of the information technology company he had founded, leaving him without a source of income. . . But after renting out his apartment on Craigslist and through word of mouth, he signed up for Airbnb in early 2011, with a plan to make short-term rentals his full-time job. He signed leases on former factory spaces in Lower Manhattan, renovating them and listing them on Airbnb. At his peak, he said, he managed 12 listings and hired a team of cleaners, greeters and handymen to keep his scatter-site hotel operating. His relationship with Airbnb, however, turned sour when Schneiderman sought data from the company about operators like him. . . .And who would want to stop a man with 12 apartments from making ends meet?“ (“The Business Tycoons of Airbnb”, New York Times, November 25, 2014)

  3. The numbers of potential renters and cars above are reasonable and appropriate because they are less than 50% of the worst case conditions that you would be required to consider in a proper EIR.

  4. The assertion by the Coastal Commission that an ordinance modeled on “Santa Cruz and San Luis Obispo counties [are] places where ordinances permitting short term rentals have been successful” ignores the facts that are unique to the Coastal Zone in Monterey County and that the evolution of the STR industry is dramatically different than even one or two years ago. Both Santa Cruz[i] and San Luis Obispo are in fact experiencing increasing problems with STR and have not found solutions as yet. The problem is that ways to circumvent the proposed changes are also well known in the STR industry. The Coastal Commission should take administrative/judicial notice not just of the problems experienced in Santa Cruz and San Luis Obispo, but also serious problems encountered in:

  5. Amsterdam, Netherlands; Anaheim, CA; (Anaheim just banned short-term rentals entirely. Residents had complained that Disneyland visitors had overrun their neighborhoods. (New York Times; July 1, 2016); Berlin, Germany; [ii] Big Sur, CA; Carmel Highlands, CA; Carmel, CA; Danville, CA; Dana Point, CA;[iii] Goleta, CA; [iv] Hermosa Beach, CA;[v] Huntington Beach, CA;[vi] Laguna Beach, CA;[vii] Los Angeles, CA;[1] Malibu CA; Mill Valley, CA; Montecito, CA; (“Montecito Says No to Short-Term Rentals” Independent News, November 21, 2015; Growing sentiment countywide against short-term vacation rentals in residential neighborhoods received more unanimous backing with the Montecito Planning Commission’s recent support of an all-out ban, even in areas where vacation homes have been operating for years, such as Miramar Beach.);Nagano, Japan; New Orleans, LA; New South Wales, Australia; New York, NY;(In New York, where the housing shortage is dire, the law forbids virtually any short-term rental of a residential unit. The city is proposing to sharply ramp up enforcement and penalties, in part because state Atty. Gen. Eric Schneiderman has charged that 72% of private short-term rentals violate the law. (Los Angeles Times, July 19, 2015); Ojai, CA; Pacific Grove, CA (In Pacific Grove — where a short-term rental program was approved with barely an objection during the recession — voices are beginning to be raised asking for the program to be rescinded. – Carmel Pine Cone October 16, 2015); Paris, France; Portland, OR; Redondo Beach, CA San Francisco, CA; Last month, San Francisco supervisors unanimously approved an ordinance that would fine Airbnb $1,000 per day for each host listed on its website who is not registered with the city.” New York Times,July 1, 2016. . . Campos says illegitimate rentals have effectively taken 1,900 long-term housing units off the San Francisco market at a time when the city is experiencing a historic housing shortage. But the reality that concerns municipal officials is the drastic expansion and commercialization of short-term rentals. There are indications that owners or managers of single or multiple properties available for rent year-round provide a disproportionate share of the market’s volume. (Los Angeles Times, July 19, 2015). And just three weeks ago “Airbnb Sues San Francisco to Block Rental Registration Law: Startup is seeking an injunction to prevent the city from fining Airbnb for each unregistered listing (June 27, 2016 Wall Street Journal); Santa Monica, CA; Vienna, Austria; and many, many others. 


  6. For example, “What we’re trying to stop is the phenomenon of people buying buildings and evicting tenants so they can rent to tourists for three to four times as much. . .   “But there’s a commercial short-term rental industry that buys entire buildings and rents them all out. That’s changing the character of the neighborhood and taking housing stock away from people who need it.”

  7. A study issued in March by the Los Angeles civic group LAANE found that although 52% of the listing hosts on Airbnb in L.A. were on-site hosts offering private or shared rooms, they accounted for only 11% of revenue in the market. Leasing companies offering two or more whole units constituted 6% of all listing hosts but accounted for 35% of revenue.

  8. REALTOR MAGAZINE, December 2015:  STRs are having a dangerous effect on our housing stock. In L.A., a city desperate for more affordable housing, 11 units of long-term rental housing are being lost daily to STR conversions, according to a report from the Los Angeles Alliance for a New Economy. The report says people are converting rent-controlled units into commercial STR operations, and long-term rent-control tenants are being evicted. The loss of these units in the long-term rental market has driven up total housing costs for L.A. renters by more than $464 million in the last year.

  9. The trend for STRs is away from “shared spaces,” where owners are present. Individuals are now purchasing single-family or multifamily units to turn them into STRs — creating a business — to the considerable detriment of their neighbors. Some short-term renters turn these locations into party houses, creating noise, traffic, and a public nuisance. In such instances, neighbors who need a night’s sleep to work the next day or who have school-age children are disturbed. In my neighborhood, a home owner leased her property for a year to someone she believed was occupying it, only to learn he listed it on one of the STR sites as a “commercial party house.” Some 500 people being charged $125 apiece crammed narrow, winding canyon roads by illegally parking and throwing trash everywhere. When the property owner was alerted, she was shocked and started eviction proceedings.”

  10. Another example, while drafting this letter (June 28, 2016), the New York Times published an article, “Airbnb in Disputes With New York and San Francisco” that states, “Airbnb executives once promoted San Francisco as a city it could work with. After affordable housing advocates expressed fear that the service worsened the city’s housing crunch, Airbnb agreed to cap short-term rentals for entire homes and required hosts of such listings to register with the city. That law, which became known as the “Airbnb law” for its friendliness to the company, took effect in February 2015. But only 20 percent of the 7,000 or so hosts required to register have done so, and Airbnb has not removed lawbreakers . . .”

  11. The Coastal Commission letter supporting Short Term Rentals for “families and large groups” also fails to take in to account there is already a process in place for homeowners to do short-term rentals either by applying to become a Bed & Breakfast or through the Conditional Use Process. Both of these processes provide appropriate safeguards for business and adjacent homeowners. Short Term Rentals programs have clearly and unequivocally proven to eviscerate reasonable cost housing for people living and working in the area, driving up costs and commute times, while shrinking the labor pool, and making serving the influx of visitors already here more and more difficult. The saturation point that has already been reached and exceeded by visitors will disastrously impact the ability to serve these and other visitors to the area. This problem already exists in the Coastal Zone and hundreds of other cities. And now Air BnB is actually suing the City of San Francisco who is trying to stop advertising of illegal rentals on the Air BnB site. New York State legislature has passed a similar bill.

  12. The Monterey Herald reported (6/24/16) “The demand for rental housing on the Monterey Peninsula now far exceeds the supply. . . People are scrambling out there,” said Jan Leasure of MontereyRentals.com a consortium of seven local property managers. “We manage about 400 houses and right now there is a 1 percent vacancy rate.” The problem pertains to the long-term rental market as there are plenty of short-term rentals, said Leasure.”

  13. The Coastal Commission must consider Housing and Rental Costs. The Coastal Commission letter seems to suggest the extreme impact Short-Term Rentals have on long-term rental availability and costs in a time of housing shortage need not be considered. The lack of appropriate weight to the issue does a disservice to city after city after area that have seen housing costs for the people who are needed to live and work in an area skyrocket beyond any reasonable measure or ability to pay. In effect, the Coastal Commission seems to envision a future where visitors and corporate owners of formerly residential properties are served by people who live one, two, three hours away who have to commute in heavy traffic to jobs, many of which are not high paying.

  14. Mike Novo, former Director of County Planning states (memo, April 1, 2016), addressed this issue for Big Sur, and it is evident it should apply to Carmel Highlands as well:

As it stands today, we have a large need for housing in Big Sur, and a very small supply. The situation in Big Sur, where much of the acreage is in public ownership, under conservation easement, or undevelopable due to our policies, means that housing supply will be constrained in the future as well.

The need for housing includes affordable housing for employees that work in the area and housing needs for the community, so that a nucleus of residents can remain to represent the community and work or volunteer in the local businesses and governmental functions. Housing needs for the community includes long time residents, artists who provide to the galleries in the area, and an available supply so that the children of residents have a place to live as they get older and establish their own households.

Short term, or vacation, rentals are nothing new. They have been in existence for many, many years. There are heavily used tourist areas (e.g., Sea Ranch, Tahoe, and Yosemite) where whole communities of second homes and vacation homes are the rule, and housing for residents is the exception. With the relatively new tools being used on the web for short term rentals, the pressure on housing stock to convert to short term rental use is great in areas such as Big Sur and we should ensure that housing for the community does not become the exception.

From what I know so far, I believe that there likely is not enough housing stock for the needs of just the community and for employee needs. While not all employees will want to live in the community, we should plan to try to accommodate the needs of those that want to live near their jobs. That creates a safer environment for travelers on Highway 1 by reducing the need to commute long distances from outside Big Sur. It also helps to have a core nucleus of residents who stay and are invested in the community and meets our goal of reducing greenhouse gas emissions.

As such, I do not think that we have a substantial supply of housing that could or should be converted to short term rentals in Big Sur. The needs of the community and accommodating employee housing needs should come first.

[i] See KION September 30, 2015

[ii] See Slate.com April 12, 2014 and http://www.investopedia.com/articles/investing/083115/top-cities-where-airbnb-legal-or-illegal.asp

[iii] Short-Term Rentals not allowed in residential areas

[iv] Short-Term Rentals not allowed in residential areas

[v] Short-Term Rentals not allowed in residential areas

[vi] Short-Term Rentals not allowed in residential areas

[vii] See http://www.ocregister.com/articles/short-692385-beach-city.html

MCVRA Position:

  • STRs do not impact affordable employee housing. Most STRs are owner occupied or second homes. The owners want to use their home for their own enjoyment. They will not offer their home as a long-term rental. If they were ever forced to, it would not be “affordable” housing. STRs are generally some of the best houses on the street as required to meet guest expectations. These will never be “affordable.” And coastal properties are selling for millions. Future owners will never offer “affordable” housing.

If a home has the same impact – or worse – on a residential area as a hotel or B&B, than it is not a residential use.


  • If a person makes the a significant percentage of their income, or pays a significant percentage of the mortgage from rental income, it is not a residential use.


  • If it is offered to the public in general, but increases leach field, water, parking, noise, or brings strangers to the neighborhood on a regular basis, it is not a residential use.


  • If it increases security concerns over and above a typical residence, it is not a residential use.


  • If the neighbors have to work through an on-call property manager to handle neighborhood fire, safety, or other neighborhood issues, it is not a residential use.


  • If they are competing with licensed hotels and B&B’s, it is not a residential use.


  • If they are represented by a trade group that offers “Hotel-like” accommodations, it is not a residential use.


  • If the aggregate number of STR’s being allowed is a significant percentage of the licensed visitor serving accommodations, it is not a residential use.


  • If an STR takes other homeowners rights to quiet enjoyment of their homes, it is not a residential use.


  • If the STR has evicted families and working people to convert to STR’s, it is not a residential use.


  • If the STR rents itself out for special events, it is not a residential use.


From the LUP:


Page 92


  1. Commercial
  2. Commercial land use in the Carmel Coastal Segment shall be restricted to those locations of existing and proposed visitor-serving accommodations shown on the land use plan map or described in the text. Additional commercial designation of property is not compatible with the intent of this land use plan to preserve the natural and scenic character of the area.
  1. Renewal of use permits for existing commercial uses or the establishment of new uses will require careful consideration of the impact of the use on the surrounding community. Particularly where commercial activities are in proximity to residences, care must be taken to ensure that noise or visual modification do not affect the peace and tranquillity of existing neighbors.




Page 94

  1. Recreation and Visitor-Serving Commercial

Moderate to high-intensity uses providing basic support services and accommodations to meet visitor needs associated with coastal recreation and travel are appropriate. Major hotel or inn accommodations are principal uses. Such uses shall be subject to the policies of section 4.4.3-D.





Page 94-5

  1. Low-Density Residential


Low-density residential development is the primary use of this category. Agricultural land uses are limited in order to decrease cumulative erosion and water quality impacts. The establishment of impervious surface will be limited to a set percentage of the parcel size. Maximum densities ranging from 1 unit per 2.5 acres to 1 unit per acre would be allowed according to site evaluation of slope and natural resource, septic system and public facility constraints. This land use designation is applied to CarmelHighlands-Riviera. Public/quasi-publicuses(5.5.1)anddensitiesofovernightaccommodations currently in operation are permitted.



Page 96

28 total VSU (Lower Area of Point Lobos) in addition to exisiing