Item F-3 Agenda Report — Beverly Hills City Council, July 15, 2025

AGENDA REPORT
Meeting Date: July 15, 2025
Item Number:

To: Honorable Mayor & City Council
From: Chloe Chen, Principal Planner
Masa Alkire, AICP, Assistant Director of Community Development / City Planner
Subject: AN ORDINANCE OF THE CITY OF BEVERLY HILLS AMENDING

SHORT TERM RENTAL REGULATIONS (TRANSIENT USES) FOR

SINGLE FAMILY AND MULTIFAMILY RESIDENTIAL ZONES AND

MAKING A DETERMINATION OF EXEMPTION UNDER THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
Attachments: 1. Draft Ordinance

2. Redline Ordinance (Compare to 7/1/2025 Version)

3. Redline BHMC Sections

4. City Council Agenda Report – 7/1/2025 (No Attachments)

5. Previous Public Correspondence (Through 7/1/2025)

6. New Correspondence (As of 7/1/2025)
_________________________________________________________________________________________________________

RECOMMENDATION
Staff recommends the City Council waive the full reading and introduce by title only an ordinance entitled “AN ORDINANCE OF THE CITY OF BEVERLY HILLS AMENDING

SHORT TERM RENTAL REGULATIONS (TRANSIENT USES) FOR SINGLE FAMILY

AND MULTIFAMILY RESIDENTIAL ZONES AND MAKING A DETERMINATION OF EXEMPTION UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)”. (Attachment 1).

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period less than six months. In multi-family zones, short term rentals are defined as “multifamily transient uses” as any rental of a multi-family dwelling unit for a period of less than 30 days, which are prohibited uses. While these existing regulations impose limitations on the frequency of short term rentals in single-family residential zones, it is difficult to enforce these regulations because of the documentation required to prove the occurrence of a violation.

Although short term rentals may provide flexibility for property owners who wish to lease their property and may provide a supplemental source of revenue, short term rentals have at times presented issues related to noise, disturbances due to occupancy changeover and activities (e.g. use of property for parties or large numbers of people), loss of privacy, and potential safety concerns. In addition, the current allowances for short term rentals are difficult to track and enforce, as it can be challenging to prove a violation especially if the property owner is not forthcoming with information. The agenda report for the July 1, 2025 City Council meeting (Attachment 3) provides more information regarding the background of this topic and research that staff conducted.

The City Council previously provided direction for staff to review the short term rental regulations due to concerns over adverse impacts that have been occurring within the residentially zoned areas of the City as a result of short term rental operations. The Planning Commission previously discussed this topic at a study session on August 8, 2024 and provided direction regarding the draft ordinance. Staff returned to the Planning Commission on November 14, 2024 with a draft ordinance to prohibit short term rentals in all residential zones, establish a minimum initial lease term for residential units, and create a specific penalty schedule for violations. The Planning Commission adopted a resolution recommending the City Council to adopt the draft ordinance as presented (3-2).

Commissioner Ross and Vice Chair Wolfe voted no on the draft ordinance primarily because they disagreed with the proposed minimum initial lease term of six months for multi-family residential properties. At their regular meeting on July 1, 2025, the City Council reviewed the draft ordinance, received public comment, and conducted a public hearing. After deliberating, the City Council provided direction to staff regarding amendments to the draft ordinance, and continued this item to the July 15, 2025 meeting to provide time for the draft ordinance to be revised with the proposed changes.

DISCUSSION
July 1, 2025 City Council Meeting
At the July 1, 2025 meeting, the City Council deliberated on the draft ordinance and came to a consensus on the following regulations. The draft ordinance in Attachment 1 has been updated to reflect these changes, and the red text in the below section also shows changes that have been made since the City Council’s review on July 1. Attachment 2 provides a redline of the specific changes made to the version of the draft ordinance presented at the July 1, 2025 meeting, and the updated draft ordinance under consideration for adoption. A redline of the existing BHMC code sections is also provided in Attachment 3 for additional clarification. The main changes are noted below. • Minimum initial lease term and definition of prohibited “transient uses”: a period of 1-year (12 months) shall be required for both single-family and multi- Meeting Date: July 15, 2025

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family residential zones, due to the desire for a consistent standard across the board that will help increase enforceability.
• Historic landmarked property exemption: While there was support for the idea of an exemption from short term rental regulations for single-family residences on historic landmarked properties, the topic was referred to the Planning Commission for further review and study, and will be considered in a separate ordinance. The City Council also expressed interest in creating restrictions for short term rentals of historic landmarked single-family homes, such as a minimum lease term and limiting the rental to guesthouses or accessory dwelling units on the properties.

The Planning Commission will study this topic and staff will return with a draft ordinance for City Council review and adoption after this process is completed. • Additional clarifying changes: Some minor changes to language were made to provide greater clarity, such as changing “over a year” to “at least one year” for the limitation on the initial lease term. The definitions of “multi-family transient use” and “single-family transient use” were also updated to capture scenarios where subleasing could occur, such as when a corporation leases a residence for more than a year, but allow an employee to reside in the unit for less than the required minimum one-year period. In addition, the definitions clarify that in-home caregiving services are not subject to the short term rental restrictions, as this activity is not the type of short term rental activity intended to be prohibited.

In addition, the City Council discussed and concluded the following in support of the proposed regulations:
• Short term rentals are creating negative impacts to residential areas, especially with the use of residences for parties, such as impacts to privacy, noise, and safety. • Short term rentals are potentially impacting the affordability of certain housing types, such as multi-family residential units and accessory dwelling units.

Additionally, the frequency of resident turnover and removal of units from the housing market may have impacts to the character of residential neighborhoods and may diminish long-term housing opportunities.
• While the majority of Councilmembers ultimately agreed that a 1-year minimum initial lease term was appropriate for both single-family and multi-family residential areas, other Councilmembers felt that there may be a need for more flexibility for certain types of stays, such as emergency housing needs or temporary work assignments (e.g. traveling nurses).
• The City Council was supportive of the addition of the proposed penalty fees and separate penalty for the advertising or listing of a short term rental, as these measures will act as tools for both deterring illegal activity and enforcing punitive measures for violation of the regulations. A minority of Councilmembers were interested in adding further punitive measures.

Proposed Regulations
Staff has prepared a draft ordinance that reflects the direction provided by the Planning Commission. A more general summary of the proposed changes is provided in the table below. The draft ordinance includes the following changes to existing short term rental regulations:

Meeting Date: July 15, 2025

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• Prohibit single-family and multi-family transient uses (short term rental uses) in single-family and multi-family residential zones;
• Prohibit multi-family transient uses in the Mixed Use Overlay Zone and other overlays;
• Update definitions of single-family and multi-family transient uses to:
ο Include short term rentals of residences or portions thereof, accessory dwelling units, accessory structures or other features of the property; ο Define transient uses as less than 12 consecutive months for single-family residential zones and multi-family residential zones; however the minimum initial lease term shall not preclude the ability for a lease to revert to a month-to-month lease after the initial term has concluded; • Establish a specific fine for violations of short term rental regulations that is higher than fines for violating other code provisions, to the maximum extent allowed under state law; and
• Establish that the advertising or listing of a short term rental is considered to be a separate violation of the code that is also subject to penalty fees. 1 BHMC section 10-3-401 does not include the reference that states a single-family transient use is permitted a maximum two times per year, however all other sections listed do include this reference.

TABLE 1. PROPOSED REGULATIONS

CATEGORY BHMC CODE

SECTIONS

EXISTING

REGULATION

PROPOSED

REGULATION
Single-family
residential zones
short term rental
allowance
10-3-4011, 10-
3-406, 10-3-
501, 10-3-508,
10-3-601, 10-3-
607, 10-3-701,
10-3-704, 10-3-
801, 10-3-
805,10-3-901,
10-3-904, 10-3-
1001, 10-3-
1004, 10-3-
1101, 10-3-
1104
Short term rentals
allowed for a period
of less than 6
months, up to two
times per calendar
year
Prohibited in singlefamily residences,
accessory dwelling
unit(s) or accessory
structures, including
pools, game courts,
etc; does not prohibit
temporary rental uses
permitted by a special
events permit
Multi-family
residential zones
short term rental
allowance
10-3-1209, 10-
3-1242, 10-3-
1304, 10-3-
1503, 10-3-
1543
Short term rentals
allowed if thirty
days or more, but
rentals for fewer
days are prohibited
Prohibit multi-family
transient uses in any
multi-family zone
Mixed Use Overlay
Zone and Other
Zoning Overlays
10-3-1877;
10-3-303
No restriction Prohibition of multifamily transient uses Single-family
transient use
definition
10-3-100 Defined as the
rental of a singlefamily residence or
accessory dwelling
Defined as the rental
for habitation or
exclusive use of a
single-family residence,
Meeting Date: July 15, 2025

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GENERAL PLAN GOALS AND POLICIES3
The General Plan includes numerous goals and policies intended to help guide development in the City. Some of the policies relevant to this topic are included as Attachment 9 of Attachment 3.

PUBLIC OUTREACH AND NOTIFICATION
The notice for this project was provided for the July 1, 2025 City Council meeting, pursuant to the requirements set forth in BHMC §10-3-2.5, et seq. At the July 1, 2025 meeting, the City Council continued this item to a date certain, on July 15, 2025. As such, no additional notification is required. Staff provided a courtesy notice to the interested parties list, and the Rent Stabilization Division’s landlord and property owner list.

Public Comment
One written comment has been submitted as of the writing of this report. The comment emphasizes a need for further punitive measures to be added that would apply to short term rental violations. The measures include adding a private cause of action and clarifications to the definition of a “responsible person” for purposes of a code violation.

A total of 28 written comments were provided for the July 1, 2025 City Council meeting, which have all been included in Attachment 5. One comment has requested that the ordinance include an exemption from short term rental restrictions for local historic landmark properties, in order to provide rental income to offset the cost of maintaining and unit for a period of
less than six
months
accessory dwelling
unit(s), or accessory
structure(s) for a period
of less than
consecutive 12 months
Multi-family
transient use
definition
10-3-100 Defined as the
rental or lease of a
multi-family
dwelling unit for a
period of less than
thirty days
Defined as the rental
for habitation or
exclusive use of a
multi-family residence,
accessory dwelling
unit(s), or accessory
structure(s) for a period
of less than 12
consecutive months
Penalty for
Violation
9-1-117 No specifically
defined penalty for
short term rentals
(only general code
violation applies)
Addition of specific
penalty for short term
rentals, with increasing
fee rates for successive
violations, per the
maximum amount
allowed under state
law;
Specific penalty for
advertising or listing of
short term rental shall
be considered a
separate violation
subject to penalty fees
Meeting Date: July 15, 2025

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repairing the property. Another comment requested an exception from the proposed short term rental prohibition of fourteen days to allow rentals during the upcoming 2028 Olympics, and the other comment requested that a shorter minimum initial lease term of three or six months is allowed for single-family residential homes due to the demand for housing, including the demand for temporary housing during the emergency fire event in Los Angeles. Additional comments received were supportive of the draft ordinance and proposed restrictions, while others requested that the minimum rental period for singlefamily residential zones is maintained at 30 days or a period less than 1 year such as 3 months or 6 months. Another comment provides suggested changes to the draft ordinance for the City Council to consider, including stricter penalties for violation of short term rental regulations.

At the Planning Commission meeting of November 14, 2024, several public comments were provided at the meeting. The comments included various requests for the Commissioners to consider, including: a minimum initial lease term of three months rather than six months for multi-family residential units, an exemption from the proposed short term rental prohibition for historic landmark properties, support for the proposed prohibition and regulations due to the impact of short term rentals on the affordability of housing supply, and a request for a minimum initial lease term of one-year for multi-family residential units instead of the proposed six month initial term. In addition, a written comment was submitted for the November 14, 2024 meeting, which requested that the minimum lease term for a multi-family residential unit be for one month. All written comments on this topic, including those submitted for the Planning Commission meetings have been included in Attachment 5.

ENVIRONMENTAL REVIEW
The Amendments were assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. Staff recommends that the City Council find the ordinance is exempt from CEQA because it can be seen with certainty that there is no potential for such ordinance to have a significant adverse effect on the environment pursuant to CEQA Guidelines Section 15061(b)(3). Section 15061(b)(3) of Title 14 of the California Code of Regulations states that CEQA applies only to projects which have the potential for causing a significant effect on the environment. The Amendments do not authorize construction and only involve revisions to existing standards and land use limitations for certain residential zones in the City. Therefore, it can be seen with certainty that the draft ordinance has no potential to cause a significant effect on the environment and the Amendments are categorically exempt from further review under CEQA pursuant to Section 15061(b)(3) and 15305 of Title 14 of the California Code of Regulations.

FISCAL IMPACT
The draft ordinance would amend and further restrict use regulations applicable to short term rentals, which are currently permitted on a limited basis. Therefore, no fiscal impact is anticipated as a result of this action.

Michael Forbes, AICP
Director of Community Development
Approved By
Attachment 1
Draft Ordinance
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ORDINANCE NO. 25-O-____

AN ORDINANCE OF THE CITY OF BEVERLY HILLS

AMENDING SHORT TERM RENTAL REGULATIONS
(TRANSIENT USES) FOR SINGLE FAMILY AND

MULTIFAMILY RESIDENTIAL ZONES, AND MAKING A

DETERMINATION OF EXEMPTION UNDER THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

THE CITY COUNCIL OF THE CITY OF BEVERLY HILLS DOES ORDAIN AS FOLLOWS:

Section 1. During the City’s Housing Element Update Review process for the 6th cycle planning period from 2021 to 2029, the California Department of Housing and Development (HCD) directed the City to: update the Beverly Hills Municipal Code (BHMC) definitions for “One-Family or Single-Family Residence or Dwelling” and “Single Housekeeping Unit”; clarify zoning districts that accommodate “Group Homes or Residential Care Facilities” and “Transitional Housing and Supportive Housing” to address housing constraints on persons with disabilities; address the replacement housing requirements for the sites inventory of the Housing Element; and to amend emergency shelter regulations in compliance with state law; Section 2. On November 14, 2024, the Planning Commission held a duly noticed public hearing to discuss the proposed Amendments to the BHMC pertaining to short term rental regulations, also known as single-family and multi-family transient uses, after which it adopted Resolution No. 2076 recommending that the City Council adopt the proposed changes (collectively, the “Amendments”). On July 1, 2025, the City Council held a duly noticed public hearing, received public testimony, and thereafter introduced this Ordinance.

Section 3. The Amendments were assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA -2-
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Guidelines, and the environmental regulations of the City. The Planning Commission recommends that the City Council find the ordinance is exempt from CEQA because it can be seen with certainty that there is no potential for such ordinance to have a significant adverse effect on the environment pursuant to CEQA Guidelines Section 15061(b)(3). Section 15061(b)(3) of Title 14 of the California Code of Regulations states that CEQA applies only to projects which have the potential for causing a significant effect on the environment. The Amendments do not authorize construction and only involve revisions to existing standards and land use limitations for certain residential zones in the City. Therefore, it can be seen with certainty that the draft ordinance has no potential to cause a significant effect on the environment and the Amendments are categorically exempt from further review under CEQA pursuant to Section 15061(b)(3) and 15305 of Title 14 of the California Code of Regulations.

Section 4. The Amendments are consistent with the objectives, principles, and standards of the General Plan. The Housing Element of the General Plan includes Goal H1 – Maintenance and Conservation, which encourages the maintenance of the quality and character of existing housing and residential neighborhoods, and Policy H1.5 – Conservation of Existing Rental Housing calls for preventing the loss of existing residential units. Similarly, the Housing Element sets forth Goal H2 – Housing Supply and Diversity, which calls for the provision of a variety of housing types and adequate affordable housing supply. Goal H3 – Fair Housing and Special Needs Residents promotes equal housing opportunities for all residents, especially persons with disabilities, homeless, and those at risk of homelessness. General Plan Land Use (LU) Policy 5.1 - Neighborhood Conservation calls for the maintenance of the uses, densities, character, amenities, and quality of the City’s residential neighborhoods, recognizing their contribution to the City’s identity, economic value, and quality of life. Goals LU 6 – Single-Family Residential -3-
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Neighborhoods and LU 7 – Multi-Family Residential Neighborhoods require that both singlefamily and multi-family neighborhood identities are maintained with regard to character, identity, and amenities. Amending sections of the Beverly Hills Municipal Code to limit short term rental uses in residential zones will meet several of the stated objectives, standards, goals, and policies of the General Plan. The Amendments will further protect the identity of residential neighborhoods by prohibiting potentially adverse impacts and preserving housing opportunities for a range of household types, which will further the public interest, health, safety, morals, peace, comfort, convenience, or general welfare.

Section 5. The definition of “Multi-Family Transient Use” in Section 10-3-100 (Words Defined) in Article 1 (Definitions) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows, with all other definitions in Section 10-3-100 remaining in place without amendment:
“MULTI-FAMILY TRANSIENT USE: Rental, lease, sublease, or similar agreement for habitation or exclusive or shared use of a multi-family dwelling unit or any portion thereof, or accessory dwelling unit(s), for a period of less than twelve (12) consecutive months; or the rental of an accessory structure, or any other feature or portion of multi-family residential property including but not limited to pools, game courts, and yards. The initial minimum lease term shall not preclude a lease from reverting to a month-to-month lease after the initial term has concluded. Multi-family transient uses do not include in-home caretakers occupying a multi-family residence in conjunction with providing caregiving services to the primary occupants of that residence.”
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Section 6. The definition of “Single-Family Transient Use” in Section 10-3-100 (Words Defined) in Article 1 (Definitions) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows, with all other definitions in Section 10-3-100 remaining in place without amendment:
“SINGLE-FAMILY TRANSIENT USE: Rental, lease, sublease, or similar agreement for habitation or exclusive or shared use of a single- family residence, or accessory dwelling unit(s) of a single-family residence for a period of less than twelve (12) consecutive months; or the rental of an accessory structure, or any other feature or portion of singlefamily residential property including but not limited to pools, game courts, and yards. The initial minimum lease term shall not preclude a lease from reverting to a month-to-month lease after the initial term has concluded. Single-family transient uses do not include home occupation activities authorized pursuant to Section 10-3-4302, filming and photography activities permitted pursuant to Section 4-3-101 et seq, or in-home caretakers occupying a single-family residence in conjunction with providing caregiving services to the primary occupants of the residence.”
Section 7. Section 10-3-401 (Uses and Buildings Permitted) of Article 4 (One-Family Residential Zone (R-1)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-401: USES AND BUILDINGS PERMITTED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1 shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare homes -5-
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licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing.”
Section 8. Section 10-3-406 (Businesses Prohibited) of Article 4 (One-Family Residential Zone (R-1)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-406: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare homes licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 10. Section 10-3-508 (Businesses Prohibited) of Article 5 (One-Family Residential Zone (R-1.X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-508: BUSINESSES PROHIBITED; MIMIUM INITIAL RENTAL PERIODS:

A. Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1.X. All property and buildings in zone R-1.X hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A single-family transient use of a "single-family residence" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, by a single housekeeping unit is prohibited in a single-family residence, accessory dwelling unit(s), or other accessory structure(s) of a single-family residence, including but not limited to pools, game courts, or yards. -7-
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B. A "single-family residence" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for at least one year), provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.” Section 11. Section 10-3-601 (Uses and Buildings Permitted) of Article 6 (One-Family Residential Zone (R-1.5)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-601: USES AND BUILDINGS PERMITTED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.5 shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 12. Section 10-3-607 (Businesses Prohibited) of Article 6 (One-Family Residential Zone (R-1.5)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-607: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.5X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
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Section 14. Section 10-3-704 (Businesses Prohibited) of Article 7 (One-Family Residential Zone (R-1.5X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-704: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.5X2 shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 16. Section 10-3-805 (Businesses Prohibited) of Article 8 (One-Family Residential Zone (R-1.5X2)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-805: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

A single-family transient use of a "single-family residence" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, by a single housekeeping unit is prohibited in a single-family residence, accessory dwelling unit(s), or other accessory structure(s) of a single-family residence, including but not limited to pools, game courts, or yards.

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.6X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community residential care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.” Section 18. Section 10-3-904 (Businesses Prohibited) of Article 9 (One-Family Residential Zone (R-1.6X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning of the BHMC is hereby amended to read as follows:
“10-3-904: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.7X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 20. Section 10-3-1004 (Businesses Prohibited) of Article 10 (One-Family Residential Zone (R-1.7X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read:
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“10-3-1004: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Section 21. Section 10-3-1101 (Uses and Buildings Permitted) of Article 11 (OneFamily Residential Zone (R-1.8X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1101: USES AND BUILDINGS PERMITTED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.8X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating -14-
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in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 22. Section 10-3-1104 (Businesses Prohibited) of Article 11 (One-Family Residential Zone (R-1.8X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1104: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Section 23. Section 10-3-1209 (Businesses Prohibited; Exceptions) of Article 12 (Multiple Residential Zone (R-4)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
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“10-3-1209: BUSINESSES PROHIBITED; EXCEPTIONS; MINIMUM INITIAL RENTAL PERIODS:

B. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for at least one year) provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.” Section 24. A new section, “Section 10-3-1231.5 (Uses Prohibited)” is hereby added to Article 12.3 (Multiple-Family Residential-Commercial Parking Zone (RMCP)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC to read as follows:
“10-3-1231.5: USES PROHIBITED:

A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for at least one year), provided that the initial lease term shall -16-
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be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.” Section 25. Section 10-3-1304 (Businesses Prohibited, Exceptions) of Article 13 (Residential Income and Multiple Dwelling Zone (R-4X1)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1304: BUSINESSES PROHIBITED; EXCEPTIONS; MINIMUM INITIAL RENTAL PERIODS:

A. Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-4X1 except for the business of an apartment house. All property and buildings in zone R-4X1 hereby are limited to residential uses, except as otherwise provided in this article. A multi-family transient use as defined in section 10-3-100 of this chapter is prohibited in a multi-family residence, or accessory dwelling unit(s), or other accessory structure(s) of a multi-family residence, including but not limited to pools, game courts, or yards.

B. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for at least one year), provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing”. -17-
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Section 26. Section 10-3-1503 (Businesses Prohibited; Exceptions) of Article 15 (Multiple Residential Zone (R-3)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1503: BUSINESSES PROHIBITED; EXCEPTIONS; MINIMUM INITIAL RENTAL PERIODS:

B. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for at least one year), provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.” Section 27. Section 10-3-1543 (Businesses Prohibited; Exceptions) of Article 15.3 (Residential Parking Zone (R-4-P)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
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“10-3-1543: BUSINESSES PROHIBITED; EXCEPTIONS; MINIMUM INITIAL RENTAL PERIODS:

Section 28. Section 10-3-1877 (Restricted Uses) of Article 18.7 (Mixed Use (MU) Overlay Zone) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1877: RESTRICTED USES; MIMIMUM INITIAL RENTAL PERIODS:

The following restrictions shall apply to mixed use development in the MU Overlay Zone:

A. No medical uses may be included in a mixed use development. -19-
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B. No entertainment uses including, but not limited to, cabarets, nightclubs, and adult entertainment businesses, may be included in a mixed use development.

C. Residential uses included as part of a mixed use development shall be permitted in all portions of the development regardless of the underlying zone, except that residential uses shall not be permitted within the first forty feet (40') of depth from any street-facing property line of the first floor, except as otherwise allowed through the development plan review request.

D. Commercial uses included as part of a mixed use development shall only be permitted in those portions of the development in which the underlying zone is a commercial zone unless otherwise approved through a zone text amendment request. Further, no commercial uses shall be allowed above the third story of a mixed use development.

E. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for at least one year), provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.

F. The planning commission shall have authority through conditions imposed on a development plan review permit to prohibit uses not specified herein, on a use by use basis, if it finds that the proposed uses will have a significant adverse impact on adjacent uses, or will not promote harmonious development of the area.”
Section 29. Section 10-3-302 (Permitted And Conditionally Permitted Uses For Residential Zoning Districts And Zoning District Overlays) of Article 3 (Establishment Of Zones; -20-
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Permitted And Conditionally Permitted Uses) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“The following charts establish permitted uses and conditionally permitted uses in all residential zoning districts and zoning district overlays:

A. Single-Family Residential Zones: Except as otherwise provided in this article, no lot, premises, building or portion thereof in a single-family residential zone shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except:

ALLOWED USES AND PERMIT REQUIREMENTS FOR SINGLE-FAMILY

RESIDENTIAL ZONING DISTRICTS AND ZONING DISTRICT OVERLAYS P = Permitted use UP = Use permit CUP = Conditional use permit R-1 R1.X
R1.5R1.5XR1.5X2R1.6XR1.7XR1.8X
Accessory dwelling units and junior
accessory dwelling units (subject to article
50 of this chapter)

P P P P P P P P
Single-family dwelling P P P P P P P P
Transitional and supportive housing 1:

Singlefamily
structure

P P P P P P P P
Family daycare homes, licensed pursuant
to state law

P P P P P P P P
Community residential care facility2 (state
licensed):

Small
(serving

P P P P P P P P
B0785-0001\3133014v2.doc
6 or
fewer)
Large
(serving
7 or
more)
P3 P3 P3 P3 P3 P3 P3 P3
Educational institutions CUP CUP4 CUP CUP4
Museums CUP CUP CUP
Public utility uses (except as provided in
section 10-3-2754 of this chapter)

CUP CUP CUP
Religious institutions CUP CUP
Public libraries CUP
Publicly owned playgrounds CUP
Home occupations (subject to section 10-
3-4303 of this chapter)

P P P P P P P
Notes:

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a singlefamily residence, it is regulated as such and is subject to all regulations applied to residences in the single-family residential zone where it is located.

2. For the purposes of this section, residential care facilities for the elderly, as defined in state law, shall be treated the same as community residential care facilities. Community residential care facilities shall comply with the requirements in section 10-3-2778 of this chapter.

3. A zoning clearance prior to the submittal of an application for building permit is required to verify the compliance of the community residential community care facility with the applicable requirements in section 10-3-2778 of this chapter.

4. Public educational institutions only.
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B. Multiple-Family Residential Zones: Except as otherwise provided in this article, no lot, premises, building or portion thereof in a multiple-family residential zone shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except:

ALLOWED USES AND PERMIT REQUIREMENTS FOR MULTIPLE-FAMILY

RESIDENTIAL ZONES AND ZONING DISTRICT OVERLAYS
P = Permitted use CUP = Conditional use permit
R-4 RMCP Special
Needs
Housing
Overlay
Zone 5
R4X1R4X2R3 R-4-P
Single-family dwelling P P P P P
Accessory dwelling units and junior accessory
dwelling units (subject to article 50 of this chapter)

P P P P P P
Multiple-family dwellings P P P P P P
Transitional and supportive housing:

Singlefamily
structure
P1 P1 P1 P1 P1
Multifamily
structure
P1 P1 P1 P1 P1
Family daycare homes, licensed pursuant to state law P P P P P P Emergency shelters (subject to section 10-3-1275 of
this chapter)
P
Single room occupancy housing (SRO) CUP
Community residential care facilities2 (state licensed):

Small (6
or
fewer)

P P P P P P
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Large (7
or more)
P3 P3 P3 P3 P3 P3
Public library P P P
Childcare uses licensed pursuant to state law CUP CUP CUP CUP Educational institutions CUP CUP CUP CUP
Multiple-family congregate housing for the elderly or
disabled pursuant to article 12.8 of this chapter
CUP
Multiple-family housing for the elderly or disabled
pursuant to article 12.5 of this chapter

CUP CUP CUP CUP
Museums CUP CUP CUP CUP
Public utility uses4 CUP CUP CUP CUP
Religious institutions CUP CUP CUP CUP
Restaurants located in nonconforming hotels (subject
to section 10-3-1207 of this chapter)

CUP CUP CUP CUP
Convenience retail uses (subject to section 10-3-
1233 of this chapter)
CUP
Public parking uses CUP
Ancillary retail uses6 P
Ancillary parking facilities6 P
Notes:

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a multiplefamily residence, it is regulated as such and is subject to all regulations applied to residences in the multiple-family residential zone where it is located.

4. Except as provided in section 10-3-2754 of this chapter.

5. Uses allowed in the special needs housing overlay zone are in addition to any use allowed in the underlying zoning district.

NONRESIDENTIAL ZONING DISTRICTS AND ZONING DISTRICT OVERLAYS AND SUPPORTIVE HOUSING:

A. Permitted Uses: Uses for all nonresidential zones and zoning district overlays are listed in the article addressing each specific zone or zoning district overlay. Unless otherwise specified by the zoning district overlay or specific project approval, multi-family transient uses shall be prohibited.”
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Section 31. Section 10-3-4302 (Prohibited Home Occupation Activities) of Article 43 (Home Occupations) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-4302: PROHIBITED HOME OCCUPATION ACTIVITIES:

Notwithstanding any other provision to the contrary, no person shall engage in, permit, carry on, or conduct any of the following activities as a home occupation at any time in a residential zone:

A. Repair, servicing, alteration, assembly, upholstery, or construction of any automobile or other motor vehicle as defined in the California Vehicle Code; B. Any hotel use or any other transient lodging use for compensation or benefit of any kind, including, but not limited to, the operation of bed and breakfast inns, hostels, hotels, or any similar operation;
C. Restaurant, excluding a restaurant or caterer that delivers goods or services to a residential site, has a principal place of business outside of any residential zone, and conducts no administrative or processing function within a residential zone; D. Caterer, unless a permit shall have first been obtained from the director of building and safety approving any equipment to be installed and operated in connection with the catering business;
E. Rental of any residence, or any portion thereof, for events or activities such as parties, banquets, auctions, or similar activities, except in connection with nonprofit and/or charity -26-
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functions, provided such nonprofit or charity functions are limited to one time per quarter not to exceed four (4) times in any twelve (12) month period; F. All activities regulated under title 4, chapter 2 of this code; G. Activities regulated under title 4, chapter 3 and chapter 4, article 5 of this code except as authorized by permit under title 4 of this code and consistent with the provisions of this article;
H. Any activity that would produce biohazardous or medical waste, as those terms are defined in the California Health and Safety Code, or involves the storage of materials in a manner that would result in a change in the occupancy classification of a residential structure under the city's building code, mechanical code, fire code or plumbing code, or that would otherwise violate any building or fire code or other law; I. Conduct any use, other than a residential use, prohibited in the C-3 zone; J. Conduct any use conditionally permitted in the C-3 zone; K. Manufacturing, excluding activities or occupation such as: 1) artists, authors or composers; 2) dressmakers, seamstresses, or tailors; and 3) home crafts, including, without limitation, model making, rug weaving, quilting, needle work, jewelry making, woodworking, and other similar activities which are consistent with the primary use of the dwelling as a residence, provide that such activities are limited to the use of tools and equipment commonly available for personal residential use.

L. Single-family transient uses and multi-family transient uses, as defined in 10-3-100 of this chapter, including the use of any residence, accessory dwelling unit, accessory -27-
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structure, or any other feature or portion of a residential property including but not limited to pools, game courts, and yards.”
Section 32. Subsection A of Section 1-3-311 (Administrative Fine; Citations and Compliance Orders) of Article 3 (Administrative Penalties) of Chapter 3 (Code Violations) of Title 1 (General Provisions) of the BHMC is hereby amended to read as follows:
“A. For any violation of this code for which the violation would otherwise be an infraction, the administrative fine shall be one hundred dollars ($100.00) for a first violation; two hundred dollars ($200.00) for a second violation of the same provision of this code within a twelve (12) month period; and five hundred dollars ($500.00) for each additional violation of the same provision of this code within a twelve (12) month period.

For any violation of this code for which there is no specific administrative fine established in this code, the fine imposed shall be that set forth in a resolution adopted by the city council.

Each and every day of operation of a single-family or multi-family transient use within a rolling 12-month period shall constitute a separate and additional violation.

2. In addition to operating a single-family or multi-family transient use, it shall also constitute a separate violation of this code, subject to a) the administrative fines as provided in subsection 1, and b) any other enforcement action allowed by law, or c) any combination thereo, to advertise or list a single-family or multi-family transient use by -28-
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any means and on any medium, whether or not the actual location or address of the property is included in the advertisement or listing. Each and every day an advertisement or listing is visible and accessible by the public within a rolling 12-month period shall constitute a separate and additional violation.”
Section 33. Severability. If any section, subsection, subdivision, sentence, clause, phrase, or portion of this Ordinance or the application thereof to any person or place, is for any reason held to be invalid or unconstitutional by the final decision of any court of competent jurisdiction, the remainder of this Ordinance shall be and remain in full force and effect.

Section 34. Publication. The City Clerk shall cause this Ordinance to be published at least once in a newspaper of general circulation published and circulated in the City within fifteen (15) days after its passage in accordance with Section 36933 of the Government Code, shall certify to the adoption of this Ordinance, and shall cause this Ordinance and her certification, together with proof of publication, to be entered in the Book of Ordinances of the Council of this City. -29-
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Section 35. Effective Date. This Ordinance shall go into effect and be in full force and effect at 12:01 a.m. on the thirty-first (31st) day after its passage.

Adopted:

Effective:

SHARONA R. NAZARIAN, PSYD
Mayor of the City of Beverly Hills,
California
ATTEST:
_________________________(SEAL)

HUMA AHMED
City Clerk
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
___________________________ _____________________________ LAURENCE S. WIENER NANCY HUNT-COFFEY
City Attorney City Manager
Attachment 2
Redline Ordinance (Compare to
7/1/2025 Version)

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ORDINANCE NO. 2425-O-____

AN ORDINANCE OF THE CITY OF BEVERLY HILLS

AMENDING SHORT TERM RENTAL REGULATIONS
(TRANSIENT USES) FOR SINGLE FAMILY AND

MULTIFAMILY RESIDENTIAL ZONES, AND MAKING A

DETERMINATION OF EXEMPTION UNDER THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

THE CITY COUNCIL OF THE CITY OF BEVERLY HILLS DOES ORDAIN AS FOLLOWS:

Section 3. The Amendments were assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA -2-
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Guidelines, and the environmental regulations of the City. The Planning Commission recommends that the City Council find the ordinance is exempt from CEQA because it can be seen with certainty that there is no potential for such ordinance to have a significant adverse effect on the environment pursuant to CEQA Guidelines Section 15061(b)(3). Section 15061(b)(3) of Title 14 of the California Code of Regulations states that CEQA applies only to projects which have the potential for causing a significant effect on the environment. The Amendments do not authorize construction and only involve revisions to existing standards and land use limitations for certain residential zones in the City. Therefore, it can be seen with certainty that the draft ordinance has no potential to cause a significant effect on the environment and the Amendments are categorically exempt from further review under CEQA pursuant to Section 15061(b)(3) and 15305 of Title 14 of the California Code of Regulations.

Section 4. The Amendments are consistent with the objectives, principles, and standards of the General Plan. The Housing Element of the General Plan includes Goal H1 – Maintenance and Conservation, which encourages the maintenance of the quality and character of existing housing and residential neighborhoods, and Policy H1.5 – Conservation of Existing Rental Housing calls for preventing the loss of existing residential units. Similarly, the Housing Element sets forth Goal H2 – Housing Supply and Diversity, which calls for the provision of a variety of housing types and adequate affordable housing supply. Goal H3 – Fair Housing and Special Needs Residents promotes equal housing opportunities for all residents, especially persons with disabilities, homeless, and those at risk of homelessness. General Plan Land Use (LU) Policy 5.1 - Neighborhood Conservation calls for the maintenance of the uses, densities, character, amenities, and quality of the City’s residential neighborhoods, recognizing their contribution to the City’s identity, economic value, and quality of life. Goals LU 6 – Single-Family Residential -3-
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Neighborhoods and LU 7 – Multi-Family Residential Neighborhoods require that both singlefamily and multi-family neighborhood identities are maintained with regard to character, identity, and amenities. Amending sections of the Beverly Hills Municipal Code to limit short term rental uses in residential zones will meet several of the stated objectives, standards, goals, and policies of the General Plan. The Amendments will further protect the identity of residential neighborhoods by prohibiting potentially adverse impacts and preserving housing opportunities for a range of household types, which will further the public interest, health, safety, morals, peace, comfort, convenience, or general welfare.

Section 5. The definition of “Multi-Family Transient Use” in Section 10-3-100 (Words Defined) in Article 1 (Definitions) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows, with all other definitions in Section 10-3-100 remaining in place without amendment:
“MULTI-FAMILY TRANSIENT USE: Rental or, lease, sublease, or similar agreement for habitation or exclusive or shared use of a multi-family dwelling unit or any portion thereof, or accessory dwelling unit(s), for a period of less than 6twelve (12) consecutive months within a 12-month calendar year period; or the rental of an accessory structure, or any other feature or portion of multi-family residential property including but not limited to pools, game courts, and yards. The initial minimum lease term shall not preclude a lease from reverting to a month-to-month lease after the initial term has concluded. Multi-family transient uses do not include in-home caretakers occupying a multi-family residence in conjunction with providing caregiving services to the primary occupants of that residence.” -4-
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Section 6. The definition of “Single-Family Transient Use” in Section 10-3-100 (Words Defined) in Article 1 (Definitions) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows, with all other definitions in Section 10-3-100 remaining in place without amendment:
“SINGLE-FAMILY TRANSIENT USE: Rental or, lease, sublease, or similar agreement for habitation or exclusive or shared use of a single- family residence, or accessory dwelling unit(s) of a single-family residence for a period of less than six (6) twelve (12) consecutive months; or the rental of an accessory structure, or any other feature or portion of single-family residential property including but not limited to pools, game courts, and yards. The initial minimum lease term shall not preclude a lease from reverting to a monthto-month lease after the initial term has concluded. Single-family transient uses do not include home occupation activities authorized pursuant to Section 10-3-4302 or, filming and photography activities permitted pursuant to Section 4-3-101 et seq, or in-home caretakers occupying a single-family residence in conjunction with providing caregiving services to the primary occupants of the residence.”
Section 7. Section 10-3-401 (Uses and Buildings Permitted) of Article 4 (One-Family Residential Zone (R-1)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-401: USES AND BUILDINGS PERMITTED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1 shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare homes -5-
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licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing.”
Section 8. Section 10-3-406 (Businesses Prohibited) of Article 4 (One-Family Residential Zone (R-1)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-406: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

A. Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1.X. All property and buildings in zone R-1.X hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A single-family transient use of a "single-family residence" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, by a single housekeeping unit is prohibited in a single-family residence, accessory dwelling unit(s), or other accessory structure(s) of a single-family residence, including but not limited to pools, game courts, or yards. -7-
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B. A "single-family residence" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for over aat least one year), provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.” Section 11. Section 10-3-601 (Uses and Buildings Permitted) of Article 6 (One-Family Residential Zone (R-1.5)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-601: USES AND BUILDINGS PERMITTED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.5X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
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Section 14. Section 10-3-704 (Businesses Prohibited) of Article 7 (One-Family Residential Zone (R-1.5X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-704: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

B. A "single-family residence" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for over aat least one year), provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.” Section 15. Section 10-3-801 (Uses and Buildings Permitted) of Article 8 (One-Family Residential Zone (R-1.5X2)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-801: USES AND BUILDINGS PERMITTED:
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Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.5X2 shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 16. Section 10-3-805 (Businesses Prohibited) of Article 8 (One-Family Residential Zone (R-1.5X2)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-805: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.7X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 20. Section 10-3-1004 (Businesses Prohibited) of Article 10 (One-Family Residential Zone (R-1.7X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read:
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“10-3-1004: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.8X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating -14-
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in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 22. Section 10-3-1104 (Businesses Prohibited) of Article 11 (One-Family Residential Zone (R-1.8X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1104: BUSINESSES PROHIBITED; MINIMUM INITIAL RENTAL PERIODS:

Section 23. Section 10-3-1209 (Businesses Prohibited; Exceptions) of Article 12 (Multiple Residential Zone (R-4)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
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“10-3-1209: BUSINESSES PROHIBITED; EXCEPTIONS; MINIMUM INITIAL RENTAL PERIODS:

B. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for over six monthsat least one year), provided that the initial lease term shall be at least six monthsone year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.” Section 24. A new section, “Section 10-3-1231.5 (Uses Prohibited)” is hereby added to Article 12.3 (Multiple-Family Residential-Commercial Parking Zone (RMCP)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC to read as follows:
“10-3-1231.5: USES PROHIBITED:

A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for over six monthsat least one year), provided that the initial -16-
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lease term shall be at least six monthsone year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.” Section 25. Section 10-3-1304 (Businesses Prohibited, Exceptions) of Article 13 (Residential Income and Multiple Dwelling Zone (R-4X1)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1304: BUSINESSES PROHIBITED; EXCEPTIONS; MINIMUM INITIAL RENTAL PERIODS:

A. Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-4X1 except for the business of an apartment house. All property and buildings in zone R-4X1 hereby are limited to residential uses, except as otherwise provided in this article. A multi-family transient use as defined in section 10-3-100 of this chapter is prohibited in a multi-family residence, or accessory dwelling unit(s), or other accessory structure(s) of a multi-family residence, including but not limited to pools, game courts, or yards.

B. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for over six monthsat least one year), provided that the initial lease term shall be at least six monthsone year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing”.
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Section 26. Section 10-3-1503 (Businesses Prohibited; Exceptions) of Article 15 (Multiple Residential Zone (R-3)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1503: BUSINESSES PROHIBITED; EXCEPTIONS; MINIMUM INITIAL RENTAL PERIODS:

B. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for over six monthsat least one year), provided that the initial lease term shall be at least six monthsone year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.”
Section 27. Section 10-3-1543 (Businesses Prohibited; Exceptions) of Article 15.3 (Residential Parking Zone (R-4-P)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
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“10-3-1543: BUSINESSES PROHIBITED; EXCEPTIONS; MINIMUM INITIAL RENTAL PERIODS:

The following restrictions shall apply to mixed use development in the MU Overlay Zone:

A. No medical uses may be included in a mixed use development. -19-
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B. No entertainment uses including, but not limited to, cabarets, nightclubs, and adult entertainment businesses, may be included in a mixed use development.

E. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3- 100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for over six monthsat least one year), provided that the initial lease term shall be at least six monthsone year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.

F. The planning commission shall have authority through conditions imposed on a development plan review permit to prohibit uses not specified herein, on a use by use basis, if it finds that the proposed uses will have a significant adverse impact on adjacent uses, or will not promote harmonious development of the area.”
Section 29. Section 10-3-302 (Permitted And Conditionally Permitted Uses For Residential Zoning Districts And Zoning District Overlays) of Article 3 (Establishment Of Zones; -20-
B0785-0001\3133389v1.doc
Permitted And Conditionally Permitted Uses) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“The following charts establish permitted uses and conditionally permitted uses in all residential zoning districts and zoning district overlays:

ALLOWED USES AND PERMIT REQUIREMENTS FOR SINGLE-FAMILY

RESIDENTIAL ZONING DISTRICTS AND ZONING DISTRICT OVERLAYS P = Permitted use UP = Use permit CUP = Conditional use permit R-1 R1.X
R1.5 R1.5X R1.5X2R1.6XR1.7XR1.8X
Accessory dwelling units and junior
accessory dwelling units (subject to article
50 of this chapter)

P P P P P P P P
Single-family dwelling P P P P P P P P
Transitional and supportive housing 1:

Singlefamily
structure

P P P P P P P P
Family daycare homes, licensed pursuant
to state law

P P P P P P P P
Community residential care facility2 (state
licensed):

Small
(serving

P P P P P P P P
B0785-0001\3133389v1.doc
6 or
fewer)
Large
(serving
7 or
more)
P
3 P3 P3 P3 P3 P3 P3 P3
Educational institutions CUP CUP4 CUP CUP4
Museums CUP CUP CUP
Public utility uses (except as provided in
section 10-3-2754 of this chapter)

CUP CUP CUP
Religious institutions CUP CUP
Public libraries CUP
Publicly owned playgrounds CUP
Home occupations (subject to section 10-
3-4303 of this chapter)

P P P P P P P
Notes:

4. Public educational institutions only.
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B. Multiple-Family Residential Zones: Except as otherwise provided in this article, no lot, premises, building or portion thereof in a multiple-family residential zone shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except:

ALLOWED USES AND PERMIT REQUIREMENTS FOR MULTIPLE-FAMILY

RESIDENTIAL ZONES AND ZONING DISTRICT OVERLAYS
P = Permitted use CUP = Conditional use permit
R-4 RMCP Special
Needs
Housing
Overlay
Zone 5
R4X1R4X2 R3 R-4-P
Single-family dwelling P P P P P
Accessory dwelling units and junior accessory
dwelling units (subject to article 50 of this chapter)

P P P P P P
Multiple-family dwellings P P P P P P
Transitional and supportive housing:

Singlefamily
structure
P
1 P1 P1 P1 P1
Multifamily
structure
P
1 P1 P1 P1 P1
Family daycare homes, licensed pursuant to state law P P P P P P Emergency shelters (subject to section 10-3-1275 of
this chapter)
P
Single room occupancy housing (SRO) CUP
Community residential care facilities2 (state licensed):

Small (6
or
fewer)

P P P P P P
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Large (7
or more)
P3 P3 P3 P3 P3 P3
Public library P P P
Childcare uses licensed pursuant to state law CUP CUP CUP CUP Educational institutions CUP CUP CUP CUP
Multiple-family congregate housing for the elderly or
disabled pursuant to article 12.8 of this chapter
CUP
Multiple-family housing for the elderly or disabled
pursuant to article 12.5 of this chapter

CUP CUP CUP CUP
Convenience retail uses (subject to section 10-3-
1233 of this chapter)
CUP
Public parking uses CUP
Ancillary retail uses6 P
Ancillary parking facilities6 P
Notes:

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a multiplefamily residence, it is regulated as such and is subject to all regulations applied to residences in the multiple-family residential zone where it is located.

4. Except as provided in section 10-3-2754 of this chapter.

5. Uses allowed in the special needs housing overlay zone are in addition to any use allowed in the underlying zoning district.

NONRESIDENTIAL ZONING DISTRICTS AND ZONING DISTRICT OVERLAYS AND SUPPORTIVE HOUSING:

A. Permitted Uses: Uses for all nonresidential zones and zoning district overlays are listed in the article addressing each specific zone or zoning district overlay. Unless otherwise specified by the zoning district overlay or specific project approval, multi-family transient uses shall be prohibited.”
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Section 31. Section 10-3-4302 (Prohibited Home Occupation Activities) of Article 43 (Home Occupations) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-4302: PROHIBITED HOME OCCUPATION ACTIVITIES:

Notwithstanding any other provision to the contrary, no person shall engage in, permit, carry on, or conduct any of the following activities as a home occupation at any time in a residential zone:

A. Repair, servicing, alteration, assembly, upholstery, or construction of any automobile or other motor vehicle as defined in the California Vehicle Code; B. Any hotel use or any other transient lodging use for compensation or benefit of any kind, including, but not limited to, the operation of bed and breakfast inns, hostels, hotels, or any similar operation;
C. Restaurant, excluding a restaurant or caterer that delivers goods or services to a residential site, has a principal place of business outside of any residential zone, and conducts no administrative or processing function within a residential zone; D. Caterer, unless a permit shall have first been obtained from the director of building and safety approving any equipment to be installed and operated in connection with the catering business;
E. Rental of any residence, or any portion thereof, for events or activities such as parties, banquets, auctions, or similar activities, except in connection with nonprofit and/or charity -26-
B0785-0001\3133389v1.doc
functions, provided such nonprofit or charity functions are limited to one time per quarter not to exceed four (4) times in any twelve (12) month period; F. All activities regulated under title 4, chapter 2 of this code; G. Activities regulated under title 4, chapter 3 and chapter 4, article 5 of this code except as authorized by permit under title 4 of this code and consistent with the provisions of this article;
H. Any activity that would produce biohazardous or medical waste, as those terms are defined in the California Health and Safety Code, or involves the storage of materials in a manner that would result in a change in the occupancy classification of a residential structure under the city's building code, mechanical code, fire code or plumbing code, or that would otherwise violate any building or fire code or other law; I. Conduct any use, other than a residential use, prohibited in the C-3 zone; J. Conduct any use conditionally permitted in the C-3 zone; K. Manufacturing, excluding activities or occupation such as: 1) artists, authors or composers; 2) dressmakers, seamstresses, or tailors; and 3) home crafts, including, without limitation, model making, rug weaving, quilting, needle work, jewelry making, woodworking, and other similar activities which are consistent with the primary use of the dwelling as a residence, provide that such activities are limited to the use of tools and equipment commonly available for personal residential use.

L. Single-family transient uses and multi-family transient uses, as defined in 10-3-100 of this chapter, including the use of any residence, accessory dwelling unit, accessory -27-
B0785-0001\3133389v1.doc
structure, or any other feature or portion of a residential property including but not limited to pools, game courts, and yards.”
Section 32. Subsection A of Section 1-3-311 (Administrative Fine; Citations and Compliance Orders) of Article 3 (Administrative Penalties) of Chapter 3 (Code Violations) of Title 1 (General Provisions) of the BHMC is hereby amended to read as follows:
“A. For any violation of this code for which the violation would otherwise be an infraction, the administrative fine shall be one hundred dollars ($100.00) for a first violation; two hundred dollars ($200.00) for a second violation of the same provision of this code within a twelve (12) month period; and five hundred dollars ($500.00) for each additional violation of the same provision of this code within a twelve (12) month period.

For any violation of this code for which there is no specific administrative fine established in this code, the fine imposed shall be that set forth in a resolution adopted by the city council.

Each and every day of operation of a single-family or multi-family transient use within a rolling 12-month period shall constitute a separate and additional violation.

2. In addition to operating a single-family or multi-family transient use, it shall also constitute a separate violation of this code, subject to a) the administrative fines as provided in subsection 1, and b) any other enforcement action allowed by law, or c) any combination thereo, to advertise or list a single-family or multi-family transient use by -28-
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any means and on any medium, whether or not the actual location or address of the property is included in the advertisement or listing. Each and every day an advertisement or listing is visible and accessible by the public within a rolling 12-month period shall constitute a separate and additional violation.”
Section 33. Severability. If any section, subsection, subdivision, sentence, clause, phrase, or portion of this Ordinance or the application thereof to any person or place, is for any reason held to be invalid or unconstitutional by the final decision of any court of competent jurisdiction, the remainder of this Ordinance shall be and remain in full force and effect.

Section 34. Publication. The City Clerk shall cause this Ordinance to be published at least once in a newspaper of general circulation published and circulated in the City within fifteen (15) days after its passage in accordance with Section 36933 of the Government Code, shall certify to the adoption of this Ordinance, and shall cause this Ordinance and her certification, together with proof of publication, to be entered in the Book of Ordinances of the Council of this City. -29-
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Section 35. Effective Date. This Ordinance shall go into effect and be in full force and effect at 12:01 a.m. on the thirty-first (31st) day after its passage.

Adopted:

Effective:

SHARONA R. NAZARIAN, PSYD
Mayor of the City of Beverly Hills,
California
ATTEST:
_________________________(SEAL)

HUMA AHMED
City Clerk
[Signatures continue]
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
___________________________ _____________________________ LAURENCE S. WIENER NANCY HUNT-COFFEY
City Attorney City Manager
Attachment 3
Redline BHMC Sections
SHORT TERM RENTAL REGULATIONS – REDLINE CODE SECTIONS
ARTICLE 1. DEFINITIONS
10-3-100: WORDS DEFINED:

MULTI-FAMILY TRANSIENT USE: Rental, or lease, sublease or similar agreement for habitation or exclusive or shared use of a multi-family dwelling unit or any portion thereof, or accessory dwelling unit(s), for a period of less than thirty
(30) days twelve (12) consecutive months; or the rental of an accessory structure, or any other feature or portion of multi-family residential property including but not limited to pools, game courts, and yards. The initial minimum lease term shall not preclude a lease from reverting to a month-tomonth lease after the initial term has concluded. Multi-family transient uses do not include inhome caretakers occupying a multi-family residence in conjunction with providing care giving services to the primary occupants of that residence.

SINGLE-FAMILY TRANSIENT USE: Rental, or lease, sublease or similar agreement for habitation or exclusive use of a single- family residence, or accessory dwelling unit(s) of a singlefamily residence for a period of less than six (6) twelve (12) consecutive months; or the rental of an accessory structure, or any other feature or portion of single-family residential property including but not limited to pools, game courts, and yards. The initial minimum lease term shall not preclude a lease from reverting to a month-to-month lease after the initial term has concluded.

Single-family transient uses do not include home occupation activities authorized pursuant to Section 10-3-4302 or filming and photography activities permitted pursuant to Section 4-3-101 et seq., or in-home caretakers occupying a single-family residence in conjunction with providing care giving services to the primary occupants of the residence.

ARTICLE 4. ONE-FAMILY RESIDENTIAL ZONE (R-1)
10-3-401: USES AND BUILDINGS PERMITTED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1 shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small community care facility, or transitional or supportive housing structured as a singlefamily residence. A single-family transient use of a "single-family residence", as defined in section 10-3-100 of this chapter, by a single housekeeping unit is permitted to commence two (2) times per calendar year for each single-family residence. Use of a single-family residence for a singlefamily transient use more than twice per calendar year is prohibited. 10-3-406: BUSINESSES PROHIBITED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R1.X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small community care facility, or transitional or supportive housing structured as a single-family residence. A single-family transient use of a "single-family residence", as defined in section 10-3- 100 of this chapter, by a single housekeeping unit is permitted to commence two (2) times per calendar year for each single family residence. Use of a single family residence for a single-family transient use more than twice per calendar year is prohibited. 10-3-508: BUSINESSES PROHIBITED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.5 shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small community care facility, or transitional or supportive housing structured as a single-family residence. A single-family transient use of a "single-family residence", as defined in section 10-3-100 of this chapter, by a single housekeeping unit is permitted to commence two (2) times per calendar year for each single-family residence. Use of a single-family residence or for a single-family transient use more than twice per calendar year is prohibited. 10-3-607: BUSINESSES PROHIBITED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R1.5X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small community care facility, or transitional or supportive housing structured as a single-family residence. A single family transient use of a "single family residence", as defined in section 10 3 100 of this chapter, by a single housekeeping unit is permitted to commence two (2) times per calendar year for each single-family residence. Use of a single-family residence for a single-family transient use more than twice per calendar year is prohibited. 10-3-704: BUSINESSES PROHIBITED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.5X2 shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small community care facility, or transitional or supportive housing structured as a single-family residence. A single-family transient use of a "single-family residence", as defined in section 10-3-100 of this chapter, by a single housekeeping unit is permitted to commence two (2) times per calendar year for each single family residence. Use of a single family residence a single-family transient use more than twice per calendar year is prohibited. 10-3-805: BUSINESSES PROHIBITED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.6X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small community care facility, or transitional or supportive housing structured as a single-family residence. A single-family transient use of a "single-family residence", as defined in section 10 3 100 of this chapter, by a single housekeeping unit is permitted to commence two (2) times per calendar year for each single family residence. Use of a single family residence for a single family transient use more than twice per calendar year is prohibited. 10-3-904: BUSINESSES PROHIBITED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.7X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small community care facility, or transitional or supportive housing structured as a single-family residence. A single-family transient use of a "single-family residence", as defined in section 10-3-100 of this chapter, by a single housekeeping unit is permitted to commence two (2) times per calendar year for each single-family residence. Use of a single-family residence for a single-family transient use more than twice per calendar year is prohibited. 10-3-1004: BUSINESSES PROHIBITED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.8X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small community care facility, or transitional or supportive housing structured as a single-family residence. A single family transient use of a "single family residence", as defined in section 10-3-100 of this chapter, by a single housekeeping unit is permitted to commence two (2) times per calendar year for each single-family residence. Use of a single-family residence for a single-family transient use more than twice per calendar year is prohibited. 10-3-1104: BUSINESSES PROHIBITED:

A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for at least one year), provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.”
ARTICLE 13. RESIDENTIAL INCOME AND MULTIPLE DWELLING ZONE (R-4X1) 10-3-1304: BUSINESSES PROHIBITED; EXCEPTIONS:

A. Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-4X1 except for the business of an apartment house. All property and buildings in zone R-4X1 hereby are limited to residential uses, except as otherwise provided in this article.

The following restrictions shall apply to mixed use development in the MU Overlay Zone:

A. No medical uses may be included in a mixed use development.

B. No entertainment uses including, but not limited to, cabarets, nightclubs, and adult entertainment businesses, may be included in a mixed use development.

E. A "multi-family dwelling" or "accessory dwelling unit", as defined in section 10-3-100 of this chapter, may be rented or leased (as evidenced by a written rental or lease agreement, or by evidence of occupancy for at least one year), provided that the initial lease term shall be at least one year. This provision does not apply to transitional housing, emergency shelters, congregate care facilities, or supportive housing.

The following charts establish permitted uses and conditionally permitted uses in all residential zoning districts and zoning district overlays:

ALLOWED USES AND PERMIT REQUIREMENTS FOR SINGLE-FAMILY

RESIDENTIAL ZONING DISTRICTS AND ZONING DISTRICT OVERLAYS P = Permitted use UP = Use permit CUP = Conditional use permit R-1 R1.XR-1.5 R-1.5X R-1.5X2 R-1.6X R-1.7X R-1.8X
R-1 R1.XR1.5R1.5XR1.5X2R1.6XR1.7XR1.8X
Accessory dwelling units and junior
accessory dwelling units (subject to
article 50 of this chapter)

P P P P P P P P
Single-family dwelling P P P P P P P P
Transitional and supportive
housing 1
:

Single-family structure P P P P P P P P
Family daycare homes, licensed
pursuant to state law

P P P P P P P P
Community care facility2 (state
licensed):

Small (serving 6 or fewer) P P P P P P P P
Educational institutions CUP CUP3 CUP CUP3
Museums CUP CUP CUP
Public utility uses (except as
provided in section 10-3-2754 of
this chapter)

CUP CUP CUP
Religious institutions CUP CUP
Public libraries CUP
Publicly owned playgrounds CUP
Home occupations (subject to
section 10-3-4303 of this chapter)

P P P P P P P
Single-family transient use4 P4 P4 P4 P4 P4 P4 P4 P4
Notes:

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a single-family residence, it is regulated as such and is subject to all regulations applied to residences in the single-family residential zone where it is located.

2. For the purposes of this section, residential care facilities for the elderly, as defined in state law, shall be treated the same as community care facilities.

3. Public educational institutions only.

4. A single-family transient use of a "single-family residence" by a single housekeeping unit is permitted to commence 2 times per calendar year for each single-family residence. Use of a single-family residence for a single- family transient use more than twice per calendar year is prohibited.

B. Multiple-Family Residential Zones: Except as otherwise provided in this article, no lot, premises, building or portion thereof in a multiple-family residential zone shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except:

ALLOWED USES AND PERMIT REQUIREMENTS FOR MULTIPLE-FAMILY

RESIDENTIAL ZONES AND ZONING DISTRICT OVERLAYS
P =
Permitted
use
CUP = Conditional use permit
R4
RMCP Special Needs Housing Overlay Zone 4 R4X1
R4X2R3
R4-
P
R-4 RMCP Special
Needs
Housing
Overlay
Zone 4
R4X1R4X2R-3 R-4-
P
Single-family dwelling P P P P P
Accessory dwelling units and junior
accessory dwelling units (subject to
article 50 of this chapter)

P P P P P P
Multiple-family dwellings P P P P P P
Transitional and supportive housing:

Single-family structure P1 P1 P1 P1
Multi-family structure P1 P1 P1 P1 P1
Family daycare homes, licensed
pursuant to state law

P P P P P P
Emergency shelters (subject to
section 10-3-1275 of this chapter)
P
Single room occupancy housing
(SRO)
CUP
Community care facilities2 (state
licensed):

Small (6 or fewer) P P P P
Large (7 or more) CUP CUP CUP CUP CUP
Public library P P P
Childcare uses licensed pursuant to
state law

CUP CUP CUP CUP
Educational institutions CUP CUP CUP CUP
Multiple-family congregate housing
for the elderly or disabled pursuant to
article 12.8 of this chapter
CUP
Multiple-family housing for the elderly
or disabled pursuant to article 12.5 of
this chapter

CUP CUP CUP CUP
Museums CUP CUP CUP CUP
Public utility uses3 CUP CUP CUP CUP
Religious institutions CUP CUP CUP CUP
Restaurants located in
nonconforming hotels (subject to
section 10-3-1207 of this chapter)

CUP CUP CUP CUP
Convenience retail uses (subject to
section 10-3-1233 of this chapter)
CUP
Public parking uses CUP
Ancillary retail uses5 P
Ancillary parking facilities5 P
Notes:

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a multiplefamily residence, it is regulated as such and is subject to all regulations applied to residences in the multiple-family residential zone where it is located.

2. For the purposes of this section, residential care facilities for the elderly, as defined in state law, shall be treated the same as community care facilities.

3. Except as provided in section 10-3-2754 of this chapter.

4. Uses allowed in the special needs housing overlay zone are in addition to any use allowed in the underlying zoning district.

5. If approved by the planning commission as part of a planned development pursuant to article 18.4 of this chapter.
10-3-303. PERMITTED AND CONDITIONALLY PERMITTED USES FOR NONRESIDENTIAL ZONING DISTRICTS AND ZONING DISTRICT OVERLAYS:

ARTICLE 43. HOME OCCUPATIONS
10-3-4302: PROHIBITED HOME OCCUPATION ACTIVITIES:

Notwithstanding any other provision to the contrary, no person shall engage in, permit, carry on, or conduct any of the following activities as a home occupation at any time in a residential zone:

A. Repair, servicing, alteration, assembly, upholstery, or construction of any automobile or other motor vehicle as defined in the California Vehicle Code; B. Any hotel use or any other transient lodging use for compensation or benefit of any kind, including, but not limited to, the operation of bed and breakfast inns, hostels, hotels, or any similar operation;
C. Restaurant, excluding a restaurant or caterer that delivers goods or services to a residential site, has a principal place of business outside of any residential zone, and conducts no administrative or processing function within a residential zone; D. Caterer, unless a permit shall have first been obtained from the director of building and safety approving any equipment to be installed and operated in connection with the catering business;
E. Rental of any residence, or any portion thereof, for events or activities such as parties, banquets, auctions, or similar activities, except in connection with nonprofit and/or charity functions, provided such nonprofit or charity functions are limited to one time per quarter not to exceed four (4) times in any twelve (12) month period;
F. All activities regulated under title 4, chapter 2 of this code; G. Activities regulated under title 4, chapter 3 and chapter 4, article 5 of this code except as authorized by permit under title 4 of this code and consistent with the provisions of this article; H. Any activity that would produce biohazardous or medical waste, as those terms are defined in the California Health and Safety Code, or involves the storage of materials in a manner that would result in a change in the occupancy classification of a residential structure under the city's building code, mechanical code, fire code or plumbing code, or that would otherwise violate any building or fire code or other law;
I. Conduct any use, other than a residential use, prohibited in the C-3 zone; J. Conduct any use conditionally permitted in the C-3 zone; K. Manufacturing, excluding activities or occupation such as: 1) artists, authors or composers; 2) dressmakers, seamstresses, or tailors; and 3) home crafts, including, without limitation, model making, rug weaving, quilting, needle work, jewelry making, woodworking, and other similar activities which are consistent with the primary use of the dwelling as a residence, provide that such activities are limited to the use of tools and equipment commonly available for personal residential use.

A. For any violation of this code for which the violation would otherwise be an infraction, the administrative fine shall be one hundred dollars ($100.00) for a first violation; two hundred dollars ($200.00) for a second violation of the same provision of this code within a twelve (12) month period; and five hundred dollars ($500.00) for each additional violation of the same provision of this code within a twelve (12) month period. For any violation of this code for which there is no specific administrative fine established in this code, the fine imposed shall be that set forth in a resolution adopted by the city council.

1. For any violation of the prohibition on single-family or multi-family transient uses pursuant to Chapter 3 of Title 10 of this code, the administrative fine shall be the maximum allowed under state law for the first, second, and each additional violation. Each and every day of operation of a single-family or multi-family transient use within a rolling 12-month period shall constitute a separate and additional violation.

B. Because a new and separate offense occurs under section 1-3-102 of this chapter each day during which a violation of any provision or requirement of this code is committed, continued, or permitted, the citing official may further assess a fine according to the schedule set forth in subsection A of this section for each day from the date for compliance specified in the compliance order until the date the violation is fully corrected as determined by the citing official. The administrative citation shall specify the date by which the fine must be paid.

C. Administrative fines assessed for failing to fully comply with a compliance order or administrative citation is a debt owed to the city.

D. If the responsible person provides written notice to the citing official that the violation has been corrected, and if the citing official finds compliance, the citing official shall deem the date the written notice was postmarked or personally delivered to the citing official to be the date the violation was corrected. If, however, a final inspection confirmed compliance before mailing or personal delivery of a written notice, or if no written notice is provided, the date of final inspection shall be deemed to be the date the violation was corrected.

Attachment 4
City Council Agenda Report – 7/1/2025
(No Attachments)

AGENDA REPORT
Meeting Date: July 1, 2025
Item Number:

SHORT TERM RENTAL REGULATIONS (TRANSIENT USES) FOR

SINGLE FAMILY AND MULTIFAMILY RESIDENTIAL ZONES AND

MAKING A DETERMINATION OF EXEMPTION UNDER THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
Attachments: 1. Draft Ordinance

2. Redline BHMC Sections

3. Draft Language for Historic Property Exemption

4. Planning Commission Resolution No. 2076

5. Planning Commission Staff Report – 8/8/2024 (No attachments)

6. Planning Commission Staff Report - 11/14/2024 (No
attachments)

7. Ordinance No. 14-O-2654

8. List of Historic Landmark Properties

9. General Plan Goals and Policies

10.Public Correspondence
_________________________________________________________________________________________________________

RECOMMENDATION
Staff recommends the City Council:

1. Introduce ordinance: Waive full reading and introduce by title only an ordinance entitled “AN ORDINANCE OF THE CITY OF BEVERLY HILLS AMENDING

SHORT TERM RENTAL REGULATIONS (TRANSIENT USES) FOR SINGLE

FAMILY AND MULTIFAMILY RESIDENTIAL ZONES AND MAKING A
Meeting Date: July 1, 2025

Page 2 of 9 ends

DETERMINATION OF EXEMPTION UNDER THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT (CEQA)”. (Attachment 1).

2. Consider and provide direction: Staff has prepared draft language in Attachment 3 to provide an exemption for historic landmarked properties. Staff requests the City Council consider and provide direction on whether such language should be added to the draft ordinance.

INTRODUCTION
This report provides information regarding a draft ordinance to modify short term rental regulations in residential zones. In single-family residential zones, short term rentals are defined as “single-family transient uses” and are permitted up to two times per year for a period less than six months. In multi-family zones, short term rentals are defined as “multifamily transient uses” as any rental of a multi-family dwelling unit for a period of less than 30 days, which are prohibited uses. While these existing regulations impose limitations on the frequency of short term rentals in single-family residential zones, it is difficult to enforce these regulations because of the documentation required to prove the occurrence of a violation.

On January 16, 2025, the City Council held a special meeting to discuss a potential relaxation of short term rental regulations to assist with providing temporary housing accommodations for those displaced and/or impacted by the Los Angeles County Fires in neighboring jurisdictions. The City Council adopted Interim Urgency Ordinance No. 25-O2908 to allow short term rentals for a temporary period of 45 days, and the ordinance has since expired in May 2025. The draft ordinance to amend permanent short term rental regulations was originally scheduled for Council review in January but was delayed due to the City’s urgency action responsive to effects of the nearby fires.

Meeting Date: July 1, 2025

Page 3 of 9 ends

DISCUSSION
Existing Regulations for Short Term Rentals
In 2014, the City adopted Ordinance No. 14-O-2654 (Attachment 7) to regulate the length of stay in both single-family and multi-family residential zones, referred to as transient residential uses in the BHMC, and colloquially known as short term rentals. “Short term rentals” is a general term that refers to the use of a residential property for a temporary or transient period of time, also known as vacation rentals by owner, or home share activities.

This activity generally consists of renting out a furnished house, apartment, or condominium unit, or a portion thereof, on a temporary basis to tourists who utilize this option in place of a hotel or other typical vacation accommodations. This may include temporary use of accessory features of the property, including an accessory dwelling unit or guest house, pool, or game court. This type of rental is often facilitated by online rental platforms, such as Airbnb, VRBO, Hostaway, Expedia, Trip Advisor, and Peerspace.

Single-Family Residential Zones
Currently, the BHMC defines a single-family transient use as: “Rental or lease of a singlefamily residence or accessory dwelling unit for a period of less than six (6) months”, and such use is permitted up to two times per calendar year in a single-family residence or accessory dwelling unit in each of the single-family zones. This existing regulation was intended to provide some opportunity for homeowners to host a short term rental, with a maximum allowance of up to two times per year, which intended to limit the frequency of this use and thus, limit adverse impacts that may be associated with the use. However, in practice, it has been difficult to verify compliance with these regulations.

Multi-Family Residential Zones
The BHMC defines multi-family transient use as: “Rental or lease of a multi-family dwelling unit for a period of less than thirty (30) days”, and such use is not permitted within the multi-family (R4) zone. This restriction still allows for month-to-month rental leases but prohibits the rental of a multi-family unit for any shorter period of time. Staff is aware of some leasing companies that rent out multi-family dwelling units for a month period at a time. For example, Sentral is a leasing company that specifically advertises units for traveling professionals who might be staying in a city for work or short period of time, and leases units in the city on a monthly basis. Although a minimum lease of 30 days is not generally considered a short term rental in the sense that the length of this stay is not typically used for a vacation purpose, the use of rental platforms such as Sentral may still result in fewer housing units being made available for longer-term residents of the City.

For reference, information on home occupation regulations and other types of permits that may be issued at residences can be found in the staff report from August 8, 2024 in Attachment 4. In addition, information on the current Community Preservation enforcement procedures for short term rental violations, which illuminates some of the challenges in documenting and proving a short term rental violation, can be found in Attachment 4 and the Planning Commission staff report from November 14, 2024 in Attachment 5.

Meeting Date: July 1, 2025

Page 4 of 9 ends

Planning Commission Review
July 11, 2024 Meeting
At the July 11, 2024 Planning Commission meeting, the Commission voted to continue this item to a future hearing date as a result of a request from members of the public and due to the absence of a Commissioner at the meeting.

August 8, 2024 Discussion
At the August 8, 2024 Planning Commission meeting, the Commissioners conducted a public hearing and received information on the topic of short term rentals. Several public comments were submitted at the hearing, which noted that short term rentals may have negative impacts on the affordability and availability of multi-family residential units in the City. The Commissioners provided their comments, and requested some additional information to be presented by staff, including the number of business tax licenses for short term rentals, the minimum period for leasing enforced by other jurisdictions, and information on how many rentals in the City are for six months or less. After deliberations, the Commissioners came to a consensus and directed staff to draft an ordinance that would prohibit short term rentals in all residential zones, require a minimum initial lease term of 12 consecutive months for residential units (with the ability to revert to a month-tomonth lease after the initial term is concluded), and implement a specific penalty fee for violations of short term rental limitations. The Commission also emphasized the importance of enforcing the short term rental regulations, and supported a change to the regulations that would enable the restriction to be more easily enforced by the City.

November 14, 2024 Discussion
At the November 14, 2024 Planning Commission meeting, the Commissioners reviewed a draft ordinance prepared to reflect their direction from the previous discussion. The Commissioners generally expressed support for the proposed prohibitions and the specific penalty fee, and requested that the home occupation regulations are amended in the future to address potential impacts from certain activities. The majority of Commissioners supported the proposed minimum initial lease terms, however, two Commissioners did not support the proposed minimum six-month initial lease term for multi-family residential units because they thought there may be other scenarios where shorter lease terms may be needed. In addition, some Commissioners supported a request from a member of the public to provide an exemption from the short term rental restrictions for local historic landmark properties, but did not reach a consensus. The Planning Commission adopted a Planning Commission Resolution No. 2076 (3-2) recommending the draft ordinance to the City Council (Attachment 4), as presented.

Proposed Regulations
Staff has prepared a draft ordinance that reflects the direction provided by the Planning Commission. A summary of the proposed changes is provided below, and a redline version of the code is provided in Attachment 3.

As shown in the table, the draft ordinance includes the following changes to existing short term rental regulations:
• Prohibit single-family and multi-family transient uses (short term rental uses) in single-family and multi-family residential zones
Meeting Date: July 1, 2025

Page 5 of 9 ends

• Prohibit multi-family transient uses in the Mixed Use Overlay Zone and other overlays
• Update definitions of single-family and multi-family transient uses to:
ο Include short term rentals of residences or portions thereof, accessory dwelling units, accessory structures or other features of the property; ο Define transient uses as less than 12 consecutive months for single-family residential zones and less than 6 consecutive months for multi-family residential zones; however the minimum initial lease term shall not preclude the ability for a lease to revert to a month-to-month lease after the initial term has concluded
• Establish a specific fine for violations of short term rental regulations that is higher than fines for violating other code provisions, to the maximum extent allowed under state law.

Since the Planning Commission’s review, the draft ordinance has been updated to include additional language that clarifies that short term rentals are prohibited in both single-family and multi-family residential zones. Language has also been added to further clarify and make explicit the Planning Commission’s intent to require an initial minimum lease term, but that such lease term requirements shall not apply to certain types of housing such as transitional or supportive housing, in compliance with state law. 1 BHMC section 10-3-401 does not include the reference that states a single-family transient use is permitted a maximum two times per year, however all other sections listed do include this reference.

TABLE 1. PROPOSED REGULATIONS

CATEGORY BHMC CODE

SECTIONS

EXISTING

REGULATION

PROPOSED

Page 6 of 9 ends

Policy Considerations
Housing Supply and Affordability
The use of both single-family homes and multi-family housing units for short term rental purposes removes available housing units from the market, which likely affects the city’s overall long term housing supply. The cumulative effect of short term rentals may exacerbate the existing affordable housing crisis in the greater Los Angeles area and contribute to a lack of affordable housing choices and supply in the region. This is because a short term rental operation may prohibit a more permanent residency if the unit is no longer available for leasing on a yearly or longer-term basis. Short term rentals in multifamily residential zones may have a more profound effect on this issue, since these units are more affordable than single-family residences. The removal of a multi-family unit from the rental market would likely be correlated to increasing rental rates, as this simultaneously creates more demand for existing multi-family units and a lower supply.

There is some research that supports the idea that short term rentals have had a negative effect on the housing market and some aspects of the wider economy. A study conducted by McGill University1 that reviewed the economic benefits and costs of online short term rental platforms in the areas of housing impacts, tax impacts, employment impacts, and other impacts estimated that short term rentals removed 2,500 residential units from the housing market in the greater Los Angeles area. Short term rentals have also potentially resulted in higher rental rates due to their removal of housing units from the market, which was estimated to increase rents by $810 per year for the average renter household in Los Angeles. Furthermore, the study estimated that Los Angeles may have lost up to $14 Single-family
transient use
definition
10-3-100 Defined as the
rental of a singlefamily residence or
accessory dwelling
unit for a period of
less than six
months
Defined as the rental
for habitation or
exclusive use of a
single-family residence,
accessory dwelling
unit(s), or accessory
structure(s) for a period
of less than
consecutive 12 months
Multi-family
transient use
definition
10-3-100 Defined as the
rental or lease of a
multi-family
dwelling unit for a
period of less than
thirty days
Defined as the rental
for habitation or
exclusive use of a
multi-family residence,
accessory dwelling
unit(s), or accessory
structure(s) for a period
of less than 6
consecutive months in
a 12-month period
Penalty for
Violation
9-1-117 No specifically
defined penalty for
short term rentals
(only general code
violation applies)
Addition of specific
penalty for short term
rentals, with increasing
fee rates for successive
violations, per the
maximum amount
allowed under state law
Meeting Date: July 1, 2025

Page 7 of 9 ends

million in transient occupancy taxes, and that annual wages for hotel industry workers may have been reduced as a result of lower demand for hotel stays.

In addition, a study published in 2023 in the Real Estate Economics Journal2 showed that a prohibition on short term rentals in Irvine, CA correlated to a rental price decrease of approximately 3% within two years of the prohibition becoming effective. The decline in rent was more profound for housing units that had similar property characteristics are those listed on Airbnb, and units located in areas with a higher rate of Airbnb use before the prohibition was effective. This research helps support the connection between affordability of market rate housing and the ability or inability to conduct short term rentals, with a positive impact on affordability when short term rentals are prohibited. Therefore, a prohibition on short term rentals as proposed in the draft ordinance may help to preserve affordability of the local housing market in the city.

As supported by this research, the proposed umbrella prohibition on short term rentals will allow for an easier enforcement protocol, and therefore, could potentially help reduce the overall impact of short term rentals on the housing supply.

Exemption for Local Historic Landmark Properties
During the previous Planning Commission meetings, public comment was submitted from a member of the public who currently lives in and owns a single-family residence that is also a local historic landmark. This individual requested that the Commission consider providing an exemption from the short term rental restrictions for local historic landmark properties, primarily because the rental income from a short term rental may be used to offset the costs of maintenance and repair of a historic property. While some of the Commissioners were supportive of the proposed idea, there was not majority support and no exemption was provided in the draft ordinance as recommended by the Planning Commission. As discussed by the Commission, there is currently an option for a local historic landmark property (Attachment 8 provides a list of Local Historic Landmark Properties, with single-family residences highlighted in light green) to receive a Historic Incentive Permit (HIP), which can allow deviations from existing BHMC development standards if approved (Article 32.5 of Title 10, Chapter 3 of BHMC). However, a HIP as currently written, is only intended to waive or to allow deviations from development standards, while the short term rental requirements are related to land use restrictions for a property. If the City Council decides to amend the HIP regulations to allow waivers or changes to land use regulations, then this would also allow use requests beyond just the short term rentals. Therefore, a more appropriate option if the City Council would like to provide an exception to allow short term rentals on local historic landmark properties would be to directly allow this in the code provisions for short term rentals. Staff has drafted proposed language with this exception in Attachment 3 for consideration if there is a consensus on this item.

It is also important to note that per Government code section 66315, jurisdictions may impose a required minimum rental period of 30 days or more for accessory dwelling units (ADUs), and must require a 30-day rental period for junior ADUs pursuant to Gov. code section 66233. The City’s local ADU regulations require a minimum rental period of 30 days, per BHMC §10-3-5000 A.7.b. This provision of state law is intended to ensure that ADUs provide another source of longer-term housing supply during the state-declared housing crisis. This means that if the City Council were to provide an exception for short term rentals for accessory structures on local historic landmark properties, if an ADU exists Meeting Date: July 1, 2025

Page 8 of 9 ends

on such a property, it would still be subject to the minimum 30-day rental period unless these provisions are amended as well.

PUBLIC OUTREACH AND NOTIFICATION
The notice for this project, summarized in Table 1, was provided pursuant to the requirements set forth in BHMC §10-3-2.5, et seq. In addition, staff notified an interested parties list, and the Rent Stabilization Division’s landlord and property owner list.

TABLE 2. PUBLIC NOTIFICATION TABLE
Notice Type Notice Date
Notice of Public Hearing
• Mailed Notice (500’ radius + block face; via first class mail) Not required • On-site Posted Notice Not required
• Newspaper Notice
Beverly Hills Courier
Beverly Hills Weekly
6/6/25
6/12/25
Public Comment
Nine written comments have been submitted as of the writing of this report. One comment has requested that the ordinance include an exemption from short term rental restrictions for local historic landmark properties, in order to provide rental income to offset the cost of maintaining and repairing the property. Another comment requested an exception from the proposed short term rental prohibition of fourteen days to allow rentals during the upcoming 2028 Olympics, and the other comment requested that a shorter minimum initial lease term of three or six months is allowed for single-family residential homes due to the demand for housing, including the demand for temporary housing during the emergency fire event in Los Angeles. Additional comments received were supportive of the draft ordinance and proposed restrictions, while others requested that the minimum rental period for single-family residential zones is maintained at 30 days or a period less than 1 year such as 3 months or 6 months. Another comment provides suggested changes to the draft ordinance for the City Council to consider, including stricter penalties for violation of short term rental regulations.

Meeting Date: July 1, 2025

Page 9 of 9 ends

Michael Forbes, AICP
Director of Community Development
Approved By
Attachment 5
Previous Public Correspondence
(Through 7/1/2025)
1 Karen Myron
From: Chloe Chen
Sent: Thursday, August 8, 2024 10:10 AM
Cc: Cindy Gordon; Masa Alkire; Michael Forbes; RWG DavidSnow; David Snow; Karen Myron Subject: Commissioner Question re: Short Term Rentals
Good morning Commissioners,
One Commissioner asked about whether any information is available regarding how many cities ban short term rentals in the area, county, or state.

In response, I did a little research online, and I found this statistic: 18 out of 88 (21%) cities in Los Angeles County have severely restricted short-term rentals by adopting Home Sharing Ordinances. These cities implement regulations that essentially ban informal vacation rentals (meaning any short term rental must comply with their regulations); hosts renting out entire properties are now subject to the same formal regulations as regular hotels and bed and breakfasts. Short-term home-sharing is not always prohibited, albeit restricted in those cities. The study also noted a slight decrease in home sale and rental prices as a result of these restrictions on short term rentals.

This is from a research study on Science Direct- please see more information here where it cites the statistic.

Please note the study is from 2021, and it is possible that there have been changes to short term regulations in various jurisdictions since then.

Please let me know if you would like to discuss or if you have any other questions. Thanks! bcc: Planning Commission
Chloe Chen
(She/Her)
Senior Planner
Long Range Planning
Community Development Department
p (310) 285-1194
e [email protected]
NOTE: Planning applications and project resubmittals are currently accepted via email. However, planning applications and project resubmittals are not considered received by the City until such submittal is acknowledged by a Planning Division staff member. If you have questions regarding the status of your planning application, please call 310-285-1000 and ask to speak to a planner. If you have questions about the status of your project resubmittal, please reach out to your assigned planner directly.
250 East 1st Street, Suite 1201; Los Angeles, California 90012 213.336.5900  betterneighborsla.org
August 8, 2024
City of Beverly Hills Planning Commission
455 North Rexford Drive
Beverly Hills, CA 90210
[email protected] Via Electronic Mail
Re: Better Neighbors LA Comment Letter –Agenda Item 2: A Draft Ordinance of The City Of Beverly Hills Amending Short Term Rental Regulations (Transient Uses) For Single Family And Multifamily Residential Zones, And Making A Determination Of Exemption Under The California Environmental Quality Act (Ceqa) – Comment Letter Dear Planning Commissioners,
Better Neighbors LA is a coalition of tenants, housing activists, and community members working to curb illegal short-term rental activity with the intent to protect long-term housing.1 We conduct data analysis and research on the short-term rental industry and its impact on affordable housing. Better Neighbors LA writes to you in support of the staff recommendation to amend the code to ban all short-term rentals and create a specific penalty schedule for violations.

Precautions must be taken to protect housing stock for long-term residents as Southern California continues to face a housing affordability and homelessness crisis. Prohibiting short-term rentals in all residential units within Beverly Hills will preserve existing housing stock and prevent the various problems that short-term rentals invariably introduce—from increased nuisance issues and registration enforcement challenges.

Better Neighbors LA has seen firsthand the impacts of the short-term rental industry in the City of Los Angeles. According to Professor David Wachsmuth of McGill University, shortterm rentals in the City of Los Angeles have increased rents by $810 per year on average and taken 2,500 homes off the long-term market since 2015.2 In addition, Wachsmuth found that
short-term rentals contributed to an additional 5,000 people experiencing homelessness in the City of Los Angeles each night.3
The growth of the short-term rental market has caused similar impacts in the City of Beverly Hills: your staffs’ report directly connects the removal of multifamily units from the rental market with higher demand for housing, lower housing stock, 1 https://www.betterneighborsla.org/ 2 https://upgo.lab.mcgill.ca/publication/strs-in-los-angeles-2022/Wachsmuth LA 2022.pdf 3 https://upgo.lab.mcgill.ca/publication/strs-in-los-angeles-2022/Wachsmuth_LA_2022.pdf Better Neighbors Comment Letter
Agenda Item 2: Amending Short Term Rental Regulations

Page 2 of 3 ends

and higher rents.4 Without a ban on short-term rentals coupled with strong enforcement, these units will likely continue to remain off the market to long-term tenants and potential homebuyers.

Families and long-time residents of Beverly Hills continue to face high housing costs. Los Angeles County Department of Public Health survey data from 2024 indicates that nearly 50% of households in the City of Beverly Hills are housing burdened5 and 32% are experiencing severe housing burden, spending 50% or more of their income on housing.6 The City’s limited housing stock also contributes to the high cost of housing. The City’s Housing Element Update included an assessment that found that the main challenge to fair housing and non-discrimination is the limited supply and access to affordable housing. Bevely Hills’ 2023 Housing Element Annual Report lays out fair housing goals that include protecting residents from displacement and increasing access to affordable housing in the City.7 With the combination of housing burdened residents and limited housing stock, it is not enough to just build additional units, the City must also look to a ban on short-term rentals as a way to preserve the affordability of existing and future housing stock for long-term residents.

Many cities in Southern California have passed strong short-term rental regulations to protect long-term housing stock. Most recently, in April 2024, the City of Santa Ana reconsidered their existing de facto short-term rental ban, and voted to codify a continued ban on short-term rentals.8 In Santa Ana, unlawful short-term rentals represented 35% of the City’s new housing needs as determined by the California Department of Housing and Community Development Regional Housing Needs Allocation, meaning that the City was able to potentially fulfill 35% of its obligations in one fell swoop simply by banning short-term rentals.9 Santa Ana is not alone in their efforts. The City Councils of Calabasas, Diamond Bar, Rosemead, and Temple City have all banned short-term rentals.10 The City of Calabasas adopted Ordinance No. 2018-364 in 2018 to ban short-term rentals. They found this ban consistent with the goals of the Housing Element of the Calabasas 2030 General Plan, which include promoting the general welfare of the public.11 Following this trajectory, the City of Beverly Hills should amend their regulations to ban short-term rentals in all residential units. Banning short-term rentals can help keep housing on the market and reduce its cost. For example, a recent study on the impacts of the City of Irvine’s ban on short-term rentals in residential zones found that the enforcement of their 4 Page 11. https://beverlyhills.granicus.com/MetaViewer.php?view id=57&event id=6576&meta id=610700 5 https://data.lacounty.gov/maps/24b60f480d43414bb75a067133bf41f0 6 https://data.lacounty.gov/datasets/24b60f480d43414bb75a067133bf41f0_0/explore?location=34.061572%2C119.434295%2C6.77 7 https://beverlyhills.granicus.com/player/clip/9658?view_id=49&redirect=true 8 https://www.santa-ana.org/short-term-rentals-ban/ 9 https://www.santa-ana.org/short-term-rentals-ban/ 10 Calabasas:
https://library.municode.com/ca/city_of_calabasas/codes/code_of_ordinances?nodeId=TIT17LAUSDE_ARTIIZODI ALLAUS_CH17.12STSPLAUS_17.12.175SHRMREOCPRPREXLAAPHOMOBEBRIN Diamond Bar: https://www.diamondbarca.gov/Faq.aspx?QID=314 Rosemead: https://library.municode.com/ca/rosemead/ordinances/code_of_ordinances?nodeId=900458 Temple City: https://templecity.us/DocumentCenter/View/17244/Ordinance-1059 11 https://library.municode.com/ca/city_of_calabasas/ordinances/code_of_ordinances?nodeId=888054 Better Neighbors Comment Letter
Agenda Item 2: Amending Short Term Rental Regulations

Page 3 of 3 ends

prohibition resulted in a 3% decrease on average in long-term rents, totaling a reduction of $80.7 million in annual total rental spending. 12
Preventing STRs is essential to preserving access to affordable housing. According to the staff report on this issue, there have been a total of over 400 cases opened to investigate short term rental violations since 2014. A Better Neighbors LA analysis of scraped data from Inside Airbnb in July 2024 revealed 1,157 active short-term rental listings in Bevely Hills on the Airbnb platform alone.
13 In June 2024, there were 1,068 STR listings on Airbnb. We imagine that there are additional listings on platforms like VRBO and Booking.com and speculate that some of these listings are in violation of City’s current ordinance, which limits STRs in single family zones and bans them in multifamily zones.

Short-term rentals present significant negative externalities for Beverly Hills residents. For instance, short-term rental guests can take up parking, leave trash in and around the property, cause noise disturbances, create potential safety concerns, and lead to a loss of privacy. Because of their high turnover, short-term rentals erode the fabric of communities and lead to neighbors becoming strangers. In the mountainous areas of Beverly Hills in particular, new guests coming in and out can create fire safety issues, with additional parked cars restricting access for emergency responders.

A ban on short-term rentals is only as valuable as the enforcement that backs it. As the staff report mentioned, the enforcement of a blanket ban on residential units being used as shortterm rentals is significantly easier and more cost-effective than using limited city administrative resources and staff time on developing and enforcing a permitting system. This is one of the greatest hurdles cities face in attempting to regulate STRs. An umbrella prohibition ensures that the law is clear and specific, making enforcement against illegal short-term rentals much easier.

A short-term rental ban will preserve City resources, protect residents from the negative effects of short-term rentals, and safeguard long-term residents from increasing housing costs and the threat of displacement. For these reasons, Better Neighbors requests the Planning Commission to move forward with a proposal to protect residents by banning short-term rentals in all residential units. Should you have any questions, please contact Maura O’Neill at [email protected].

Sincerely,
/s/ Randy Renick
12 https://onlinelibrary.wiley.com/doi/epdf/10.1111/1540-6229.12440 13 https://insideairbnb.com/
Deborah Blum
N Rodeo Drive
Beverly Hills, CA 90210
August 5, 2024
Beverly Hills Planning Commission
455 N Rexford Drive
Beverly Hills, CA 90210
Dear Members of the Beverly Hills Planning Commission:

I am writing to you in connection with the Planning Commission's upcoming review of the city's short term rental ordinance and Accessory Dwelling Unit ("ADU") regulations.

As long-time residents of Beverly Hills, my husband Dale Herd and I respectfully request that you consider a very limited amendment to the ordinance that would allow owners of a designated historic landmark house such as ours to defray the considerable costs of maintaining a historic property by regularly offering an ADU on the property for short-term rentals.

The story of our house is deeply intertwined with the rich history of Beverly Hills. We live in the historic Locke House, built in 1913 and located on a prominent corner of Rodeo Drive, just one block south of the Beverly Hills Hotel. This house has been a silent witness to the golden age of Hollywood, serving as a temporary residence to Joe Kennedy, who used it as his West Coast base while exploring the movie business. In 1941, my father, Edwin Blum, a screenwriter, purchased the house and continued its legacy by hosting Hollywood gatherings attended by icons like Humphrey Bogart, Lauren Bacall, and Frank Sinatra.

In 1989, Dale and I bought the house from my parents, committing to preserving this piece of Beverly Hills history. We have meticulously restored the property, ensuring that it would continue to reflect the charm and character of its heyday. In 2013, the Beverly Hills Cultural Heritage Commission recognized the Locke House's historical significance by designating it as a landmark property under our Historic Preservation Ordinance.

However, maintaining a historic home like the Locke House comes with significant financial burdens. The costs of preserving original character-defining features and addressing structural issues are substantial. As retirees living on Social Security, we struggle to make ends meet. To address this, we propose allowing owners of designated landmarks to regularly rent one ADU on the property for less than 30 days as long as they continue to reside in the main house.

We understand the Planning Commission's potential concerns about neighborhood disturbances resulting from short-term rentals. However, Airbnb's extensive screening tools allow us to carefully select responsible guests. The guesthouse's proximity to our home coupled with our presence on the property also ensures close oversight. When we’ve rented out our guesthouse over the years, we've had only positive experiences. Our guests from around the world have loved experiencing a part of Old Beverly Hills, making us feel like unofficial ambassadors for the city.

I thank you in advance for considering our request. I am planning to attend the August 8th meeting to answer any questions the Planning Commission might have.

Sincerely,
Deborah Blum

Vito Teruna
Kape Property Management, Inc.

short-term rental issues.

To make matters more frustrating, Code Enforcement has recently introduced additional layers of bureaucracy, making it even more difficult to prove violations or enforce existing codes. This only adds to the challenges we face, despite having clear evidence of ongoing violations. I strongly believe that short-term rentals should be banned in both single-family and multi-family homes within our city, and that enforcement should be consistent and equally applied to ensure all residents can enjoy a peaceful living environment.

Additionally, I would like to address concerns regarding home occupation businesses. The upstairs tenant in my building holds a home occupation business license for a piano studio, operating in a residentially zoned area. While personal enjoyment of musical instruments is allowed, I do not believe the code permits the scale of this business, which involves 2-3 hours of lessons, 5-6 days a week, in addition to rehearsals, recitals, and allowing others to use the instrument for practice. This results in 5-7 hours of activity daily. For example, just four days ago, we endured 6.5 hours of continuous playing on Saturday. On Veteran’s Day, lessons began loudly at 10:00 a.m. and continued until 8:00 p.m., with students coming in and out of the duplex throughout the day.

According to the code, a home occupation business, such as professional lessons, must be “incidental to the residential use and cannot alter the primary use of the dwelling.” In my view, the piano studio is in violation of this provision, as it is a pedagogical activity, not an artistic business like composing — whereas tutoring is not prohibited presumably because it does not involve noise that could impact others. Additionally, education, childcare, and even religious uses are prohibited in R4 zones, except with a Conditional Use Permit (CUP), because these activities can impact neighbors—impacts which music instruction similarly generates.

Yet, we are unable to rely on Code Enforcement to take meaningful action. Despite 18 months of documentation, complaints, and audio/video evidence, Ms. Medina recently closed our case, claiming that officers did not find the piano studio activity to be a nuisance or disturbance. I firmly believe that any code violation should be taken seriously and prioritized, as it significantly impacts the quality of life for residents.

Given these concerns, I respectfully request that the Commission consider adding a provision to the home occupation business license application, or amend the current guidelines, to prohibit all music lessons, rehearsals, and recitals involving instruments in residential areas, as outlined in BHMC 10-3-302. This is especially important in rentstabilized multi-unit buildings, where such activities can infringe upon residents' right to quiet enjoyment of their homes.

Thank you for your time and consideration. I look forward to seeing meaningful action that will protect the quality of life for all residents.

Happy Thanksgiving to each of you and your families!
Best regards,
Kathy Bronte

250 East 1st Street, Suite 1201; Los Angeles, California 90012 213.336.5900  betterneighborsla.org
November 14, 2024
City of Beverly Hills Planning Commission
455 North Rexford Drive
Beverly Hills, CA 90210
[email protected] Via Electronic Mail
Re: Better Neighbors LA Comment Letter –Agenda Item 5: A Draft Ordinance of the City of Beverly Hills Amending Short Term Rental Regulations (Transient Uses) for Single Family and Multifamily Residential Zones and the Mixed Use Overlay Zone, and Other Related Amendments, and Making a Determination of Exemption under the California Environmental Quality Act (Ceqa)– Comment Letter
Dear Planning Commissioners,
Better Neighbors LA is a coalition of tenants, housing activists, and community members working to curb illegal short-term rental activity with the intent to protect long-term housing.1 We conduct data analysis and research on the short-term rental industry and its impact on affordable housing. Better Neighbors LA writes to you in support of the staff recommendation to prohibit short-term rentals in single-family residential, multi-family residential, and Mixed Use Overlay zones; to establish a one-year minimum lease for single-family residential zones; and to create a specific penalty schedule for violations that set fines to the maximum extent allowed under state law. However, we encourage the Planning Commission to define transient use as 12 consecutive months in multi-family residential zones to standardize the definition of short-term rentals and best promote housing affordability in the city.

Prohibiting short-term rentals in all residential units within Beverly Hills will preserve existing housing stock and prevent the various problems that short-term rentals invariably introduce, including nuisance, loss of privacy, potential safety concerns, and enforcement challenges. As discussed in the August 8 meeting, the current enforcement process has proven to be administratively burdensome; consequently, a full ban on short-term rentals with steep penalties for violation will enable the City to more effectively enforce the ordinance. The current ordinance bans short-term rentals in multi-family residential zones and allows short-term rentals to operate twice a year in single-family residential zones, a distinction that became difficult to track for code enforcement. Establishing another dichotomy between multi-family and singlefamily residential zones in the length of a minimum lease will likely complicate enforcement for the City as well as create confusion for residents.
1 https://www.betterneighborsla.org/
Better Neighbors Comment Letter
Agenda Item 5: Amending Short Term Rental Regulations

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A one-year minimum lease in all residential zones would form a more stable community and create a clear administrative path to preventing the cannibalization of housing by exploitative short-term rental operators. The attached City of Beverly Hills Short-Term Rental Data sheet demonstrates one web of short-term rental operators in Beverly Hills. This group of 8 short-term rental hosts on Airbnb has over 200 listings in Beverly Hills between them, many of which appear to be in apartment units. If operators like these are willing to violate the ban on short-term rentals under the current ordinance, it is likely they would continue trying to skirt enforcement under a new ordinance. With the reality of negligent short-term rental operators like these, Beverly Hills needs a clear and consistent definition of transient use as less than 12 months across all residential zones to enforce the ordinance. Both Santa Monica and West Hollywood have included the one-year minimum lease in their municipal codes. In fact, West Hollywood more recently standardized their minimum one-year lease to include single family residences and condos in addition to apartments and rental units. Their council made this decision to keep housing stock available for long-term community members rather than tourists in short-term rentals.2

Without a ban on short-term rentals coupled with strong enforcement, affordable multifamily units will continue to remain off the market to long-term tenants. Beverly Hill’s Housing Element prioritizes two goals that align with this recommendation: to provide a variety of housing types and adequate housing supply and to provide more affordable housing opportunities for those already working in the City. Besides removing long-term housing from the market, short-term rentals have also been shown to increase rents. A recent study, published in September 2024 by David Wachsmuth and Cloé St-Hilaire, investigated the impact that short-term rental regulations in British Colombia have on rents in the province. Their research found that shortterm rental regulations that reduce short-term rental activity caused rents to fall in subsequent years. Municipal short-term rental regulations across British Columbia have reduced rents by

5.7%, saving renters over $600 million last year in rent payments.3 Instituting high penalties for ordinance violations will also deter bad actors in the short-term rental space. The staff recommendation to include increased fee rates for successive violations, to the maximum amount allowed under state law, is also crucial to ensure that short-term rental operators do not find it profitable to break the law. The current penalty structure, which fines $100 for an initial violation and up to $500 for successive violations, does not make much of a dent in profits that a short-term rental operator could earn in one night. As of August 2024, the average cost a short-term rental in Beverly Hills was $727.30 per night.4 A ban on short-term rentals is only as valuable as the enforcement that backs it. The staff time saved on implementing a permitting system for short-term rentals can be directed towards enforcement of the new ordinance. The City should implement a centralized enforcement system that immediately fines illegal short-term rental operators when they are found in violation. In Los Angeles, high administrative burden and a decentralized system of the Home-Sharing Ordinance 2 https://beverlypress.com/2024/03/weho-passes-one-year-housing-lease-rule/ 3 https://upgo.lab.mcgill.ca/publication/bc-str-2024/Wachsmuth_BC_STR_2024.pdf 4 Data on file with BNLA, Inside Airbnb: https://insideairbnb.com/ Better Neighbors Comment Letter
Agenda Item 5: Amending Short Term Rental Regulations

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enforcement has led to rampant abuse of the short-term rental market. For example, in July of 2024, Los Angeles has over 6,000 listings that are noncompliant with the Home-Sharing Ordinance.5
Between January and August of 2024, the City only issued 97 citations despite the high number of noncompliant listing.6 Beverly Hills must take steps to ensure that the City has strong, easily enforceable rules with a low threshold of administrative burden in order to issue citations and maintain the ordinance’s effectiveness.

Beverly Hills is not alone in their push to ban short-term rentals. Many cities in Southern California have passed strong short-term rental regulations to protect long-term housing stock. In April 2024, the City of Santa Ana reconsidered their existing de facto short-term rental ban and voted to codify the ban to meet their California Department of Housing and Community Development Regional Housing Needs Allocation requirement. 7 The City Councils of Calabasas,
Diamond Bar, Rosemead, Culver City, West Hollywood, San Gabriel, La Habra, La Mirada, Lakewood, Rolling Hills, Redondo, Lawndale, Garden Grove, and Laguna Hills have short-term rentals bans in place.
8 West Hollywood has strengthened their enforcement further by including a private right of action in their ordinance, which allows affected residents to take legal action against short-term rentals operators and platforms.

BNLA urges the Commission to recognize the scale of the short-term rental market in Beverly Hills. The attached City of Beverly Hills Short-Term Rental Data sheet shows that there has been a 259% increase in short-term rental listings on Airbnb between January 2022 and August 2024. A short-term rental ban will preserve City resources, protect residents from the negative effects of short-term rentals, and safeguard long-term residents from increasing housing costs and the threat of displacement. For these reasons, Better Neighbors requests the Planning Commission to move forward with a proposal to protect residents by banning short-term rentals 5 Data on file with BNLA from Los Angeles City Granicus data. https://granicus.com/ 6 Data on file with BNLA from Los Angeles City Planning Department. 7 https://www.santa-ana.org/short-term-rentals-ban/ 8 Calabasas:
https://library.municode.com/ca/city_of_calabasas/codes/code_of_ordinances?nodeId=TIT17LAUSDE_ARTIIZODIALLAUS_C H17.12STSPLAUS 17.12.175SHRMREOCPRPREXLAAPHOMOBEBRIN
Diamond Bar: https://www.diamondbarca.gov/Faq.aspx?QID=314 Rosemead: https://library.municode.com/ca/rosemead/ordinances/code_of_ordinances?nodeId=900458 Culver City: https://www.culvercity.org/Have-Your-Say/Short-Term-Rentals West Hollywood: https://ecode360.com/43916115?highlight=rental,rentals&searchId=1904165411732459#43916115 San Gabriel: https://www.sangabrielcity.com/1341/Frequently-Asked-Questions#:~:text=Shortterm%20rentals%20(anything%20less,term%20rental%20or% La Habrá: https://www.lhhcity.org/325/Short-Term-Rentals La Mirada:
https://www.airbnb.com/help/article/2692#:~:text=Short%2Dterm%20rentals%20in%20residential,not%20permitted%20in%20L a%20Mirada.

Lakewood: https://www.lakewoodcity.org/Business/Short-term-rentals Rolling Hills:
https://library.municode.com/ca/rolling_hills_estates/codes/code_of_ordinances?nodeId=TIT17ZO_CH17.47SHRMRERE_17.47 .020PU
Redondo Beach: https://www.redondobeachtourism.com/news/airbnb Lawndale: https://ecode360.com/LA4957
Garden Grove: https://ggcity.org/code-enforcement/short-term-vacation-rental-detailed-terms Laguana Hills: https://voiceofoc.org/2023/05/hed-laguna-hills-bans-short-term-rentals/ Better Neighbors Comment Letter
Agenda Item 5: Amending Short Term Rental Regulations

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in all residential units, establishing a one-year minimum lease for all residential zones; and creating a specific penalty schedule for violations that set fines to the maximum extent allowed under state law. Should you have any questions, please contact Maura O’Neill at [email protected].

Sincerely,
/s/ Randy Renick

Better Neighbors LA, November 14, 2024 Page 4
250 East 1st Street, Suite 1201; Los Angeles, California 90012 213.336.5900  betterneighborsla.org

From: Randy Simon
To: City Clerk
Subject: Agenda Item E 1
Date: Sunday, June 29, 2025 9:58:53 PM
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Hi!
My family and I request that the Council exclude single family historical properties and their guesthouses, such as Debbie Blum’s home at , from their short term rental regulations.

Thank you very much.

Randy Simon

From: Jamie Miller
To: City Clerk
Cc: Tracey Smith
Subject: Anomaly:Short Term Rental Ordinance
Date: Monday, June 30, 2025 1:15:14 PM
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RE: Opposition to Proposed Short Term Rental Ordinance
Dear Honorable Commissioners,
We are longtime multifamily property owners in Beverly Hills and are writing in strong opposition to the proposed ordinance amending short-term rental regulations.

Month-to-month and mid-term housing is essential to the social and economic fabric of Beverly Hills. The city’s unique position as a global destination for healthcare, business, and the arts creates a significant and ongoing need for flexible housing options. This ordinance, if adopted, would severely limit that flexibility to the detriment of the community.

Health & Wellness Needs
Cedars-Sinai and the numerous surrounding private practices attract thousands of patients from around the world who require top-tier medical care. These individuals and their families need safe, livable, and private environments for recovery—something traditional hotels cannot adequately provide. The ability to cook meals, rest in privacy, and host caretakers or loved ones is critical to the healing process. This ordinance would inadvertently harm the very people Beverly Hills has long welcomed for world-class treatment.

Support for the Arts and Business
Beverly Hills plays a vital role in the entertainment industry, hosting professionals from around the globe. The film and arts community relies heavily on month-to-month and mid-term housing due to the transient nature of productions and performances. This ordinance would eliminate the kind of housing that supports these industries and the creative professionals who contribute so much to the cultural life of the city.

Looking to the Future
We believe the proposed ordinance reflects an outdated understanding of how people live and work today.

Flexibility in housing is no longer an exception—it is a standard. By restricting mid-term rentals, the city risks losing valuable businesses, professionals, and cultural contributors. As property owners who have invested in Beverly Hills for decades, we are deeply concerned that this ordinance will ultimately push us—and others like us— to reconsider our future investment in the city.

We respectfully urge the Commission to recommend against adopting this ordinance as currently drafted.

Sincerely,
Jamie Miller
Multifamily Property Owner

expense of mom-and-pop property owners.

We already have laws in place that establish a minimum rental period of 31 days. This is a reasonable limit to avoid problematic short stays. Any restrictions beyond this amount would be an infringement on our property rights. We should have the right to rent our properties for a month or two, whether to travel or to earn a living!
Perhaps create a Permit system and consider banning future permits. For those with existing permits, establish a "three strikes, you're out" rule. Additionally, provide an exemption for properties with four units or fewer, where the owner lives on-site. Only registered properties with permits, no prior complaints or citations, should be eligible.

You all have a significant responsibility toward our livelihoods. Please take the time to consider our fair and balanced suggestion!
Thank you again.

Shelly
9400 S. Santa Monica Blvd. #102, Beverly Hills, CA 90210 | 310.248.1015 | [email protected] July 1, 2025
Honorable Mayor Nazarian and
Members of the City Council of Beverly Hills
City of Beverly Hills
455 N. Rexford Drive
Beverly Hills, CA 90210
Dear Honorable Mayor Nazarian and Members of the City Council, On behalf of the hotels operating within the City of Beverly Hills, we write to express our strong support for the adoption of the ordinance to change the language in the city’s current short term rental ordinance to prohibit single and multi-family short term rentals in Beverly Hills.

As valued contributors to the local economy, Beverly Hills hotels provide high-quality accommodations, generate significant employment, and pay millions annually in Transient Occupancy Tax (TOT), Sales Tax, Property Tax and Business License Tax, which directly supports vital city services, public safety, infrastructure, and tourism promotion. Short term rentals, by contrast, create a system that operates largely without oversight, accountability, or consistency in tax collection.

Our primary concern lies in the difficulty of tracking and enforcing TOT and other tax collection from short-term rental hosts. Unlike hotels, which operate under strict regulatory and financial reporting requirements, short-term rentals are frequently unlicensed, transient, and operate under the radar. This results in underreported or uncollected TOT, ultimately depriving the city of essential revenue that would otherwise be used to benefit the community.

Moreover, the proliferation of short-term rentals reduces demand for traditional hotel accommodations, diverting revenue from established, tax-paying businesses. This creates an uneven playing field and threatens the economic sustainability of our industry, which is already navigating the challenges of post-pandemic recovery. It also creates disruption and nuisance for those residents residing in neighborhoods where rentals are used for parties and other activities that undermine our citizens’ quality of life.
9400 S. Santa Monica Blvd. #102, Beverly Hills, CA 90210 | 310.248.1015 | [email protected] We urge the city to uphold its longstanding commitment to maintaining the residential character and quality of life in Beverly Hills by adopting language in the short term rental ordinance to eliminate any offerings in the city. Strong enforcement of existing regulations and a commitment to protecting legitimate hospitality businesses will ensure a fair, safe, and economically sound future for Beverly Hills.

We appreciate your attention to this matter and welcome the opportunity to work collaboratively with the City of Beverly Hills to support tourism in a responsible and equitable manner.

Sincerely,
The Beverly Hills Conference & Visitors
Board of Directors
Gaby Alexander – Good Graces
John Bendheim – Bendheim Enterprises
Linda Briskman – LJB Consulting
Tod Chambers – Waldorf Astoria Beverly Hills
David Ecija – The Beverly Hilton
Eliot Finkel – Eliot Finkel Investment Counsel, LLC and former City Treasurer Kathy Gohari – KG Relations and President of the Rodeo Drive Committee Sam Jagger – The Maybourne Beverly Hills
Reed Kandalaft – The Beverly Wilshire, a Four Seasons Hotel Gil Keinan – Local Equity
Peter Ostroff – Former Planning Commission Member
Offer Nissenbaum – Peninsula Beverly Hills
John Scanlon – The Beverly Hills Hotel
Bill Wiley – Two Rodeo/CBRE
Frederic Zemmour – L’Ermitage Beverly Hills
From: MmullinRELawgroup Mullin
To: City Clerk
Subject: Include during live Public Comments: 7-01-2025, Short Term Rental Ordinance City Council Meeting Date: Monday, June 30, 2025 1:03:46 AM
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Dear Members of the City Council,
We are reaching out on behalf of several small, family-owned property owners who are deeply concerned about losing their property rights and sources of income. We urge you not to adopt a minimum lease period longer than what currently exists. Property owners should have the right to rent their properties on a month-to-month basis.

They have followed all the laws, registered as required, paid taxes, fees, have never been in any violation, nor have they received any complaints regarding any of their rentals. They should not be unjustly restricted from their earnings.

The issues related to transient travelers, noise, and privacy have already been addressed by the 31-night minimum stay requirements. Any extension beyond this would unfairly target and single out a specific group of residents based on a theoretical scenario of public benefit. The City of Beverly Hills lacks adequate research, studies, or evidence to support the benefits of a longer minimum stay, as it does for the existing 31-night requirement.

Implementing a 6 or 12-month minimum lease requirement would adversely affect the economy of Beverly Hills.

You do not possess studies that demonstrate otherwise. In the absence of City or public funding to compensate property owners for their financial losses, this move could expose the City to legal action for compensation.

Moreover, adopting such requirements would likely lead to legal challenges regarding violations of constitutional rights, including due process and equal protection, and could conflict with state law. This action, if approved, may be challenged as an unreasonable restraint on trade and an unconstitutional taking of property.

We strongly urge you not to adopt or pass any ordinance that requires minimum leases or stays longer than 31 nights.

Thank you for your prompt attention to this matter.

Sincerely
M. Mullin
From: Karen Platt
To: City Clerk
Cc: Shahram Melamed
Subject: Item E-1 on 7 pm Agenda (Short Term Rentals)
Date: Monday, June 30, 2025 10:33:20 PM
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Please acknowledge receipt and circulate to all council members! Thanks so much.

Good evening Mayor, Vice Mayor and Councilmembers,
We are sorry that we can’t be there in person tonight, but would like to share the following:

We are long time residents of Trousdale Estates and members of TENA (Trousdale Estates Neighborhood Association). We are grateful to both the City Council and the Planning Commission for your careful reconsideration of short-term housing rentals. We have been the unlucky recipients of loud noise emanating from frequent parties held for all hours of the day and night in AirBNBs and short-term rentals. (A blatant offender is the house located at which has several outstanding code enforcement violations.) Unfortunately, in the past, the short-term renters have shown a complete disregard for the neighborhood, and then promptly disappear.

Hopefully, the longer rental terms will eliminate that, and we would be most appreciative.

We are also happy to see Section 10-3-4302 E which restricts parties except for non-profits and charities. Those offenders that we have had to deal with in the past are not beyond saying that one of their parties (with blasting music in the wee hours of the morning) is a “charity” affair. As a result, we would request that you add that any party is subject to the City’s Noise Abatement Ordinance.

Thank you for your consideration,
Karen Platt and Shahram Melamed

ensuring direct oversight of any guests. This approach maximizes community benefit while minimizing potential concerns.

I respectfully urge you to consider crafting the proposed ordinance with sufficient flexibility to accommodate situations like theirs. Perhaps exemptions could be granted for:

Historic landmark properties where rental income directly supports preservation efforts Senior residents who demonstrate financial need for property maintenance Properties where owners maintain primary residence and direct oversight Such accommodations would demonstrate Beverly Hills' commitment to both addressing community concerns and supporting the preservation of our architectural heritage.

Thank you for your thoughtful consideration of this request and for your continued service to our community.

Sincerely,
Iris Friedman

250 East 1st Street, Suite 1201; Los Angeles, California 90012 213.336.5900  betterneighborsla.org
June 27, 2025
City of Beverly Hills City Council
455 North Rexford Drive
Beverly Hills, CA 90210
[email protected]
Via Electronic Mail
Re: Better Neighbors LA – Agenda Item E-1: Ordinance Amending Short Term Rental Regulations– Comment Letter
Dear Mayor Nazarian and Honorable Councilmembers,
Better Neighbors LA is a coalition of tenants, housing advocates, and community members committed to protecting long-term housing by curbing illegal short-term rental (“STR”) activity. Through data analysis and research, we assess the STR industry’s impact on affordable housing and local neighborhoods. Better Neighbors LA writes to you in support of 1) the staff recommendation to prohibit STRs in all residential units; 2) the establishment of a one-year minimum lease for both single family and multi-family residential zones; and 3) the staff recommendation to create a penalty schedule for violations that set fines to the maximum extent allowed under state law.

Prohibiting STRs in all residential units is essential for preserving Beverly Hills’ housing stock, lowering rents, and mitigating the numerous problems that STRs generate including nuisance complaints, loss of privacy, safety concerns, and enforcement challenges. As discussed in the August 8 meeting, the City’s current enforcement process has proven to be administratively burdensome. A full STR ban coupled with meaningful penalties would improve enforcement efficiency.

At present, STRs are prohibited in multi-family residential zones while a “single family transient use” is permitted up to twice a year in single-family residence in each of the singlefamily zones – a distinction that has proven unmanageable for code enforcement. Establishing a similar dichotomy between multi-family and single-family residential zones for minimum lease terms will likely result in further confusion and undermine compliance. Standardizing 1-year minimum lease terms across all residential zones would simplify enforcement and provide clarity for both landlords and tenants.

Defining transient use as any rental term under 12 consecutive months across all residential zones will not only improve enforcement but also benefit renters. Beverly Hills is Better Neighbors Comment Letter
Agenda Item E-1: Amending Short Term Rental Regulations

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a majority renter city.1 Instituting a one-year minimum lease in all residential zones would ensure consistency and housing security for renters citywide. Other cities, including Santa Monica and West Hollywood, have adopted similar one-year minimum lease requirements to combat housing loss to STRs and support stable communities. For instance, the West Hollywood City Council standardized its minimum one-year lease to include single family residences and condos in addition to multi-family rental units. This Council decision aimed to preserve housing stock for long-term residents rather than for tourists.2 The Council strengthened its enforcement efforts further by including a private right of action in its STR ordinance, which allows affected residents to take legal action against STR operators and platforms. The City of Beverly Hills could consider similar measures.

A ban on STRs coupled with a one year minimum lease and strong enforcement will keep multi-family units affordable and available for long-term residents. This approach aligns with the City’s Housing Element goals of providing a variety of housing types, adequate housing supply, and more affordable housing opportunities for those already living and working in Beverly Hills. Notably, in the 7th Cycle of the Housing Element, Housing and Community Development is expected to update its methodology to account for housing units lost to STRs and vacation rentals.
3 STRs not only shrink the supply of long-term housing, but they also increase rent. A September 2024 study by David Wachsmuth and Cloé St-Hilaire investigated the impact that STR regulations in British Colombia have on rents in the province. Their research found that STR regulations that reduce STR activity caused rents to fall in subsequent years. Municipal STR regulations across British Columbia have reduced rents by 5.7%, saving renters over $600 million last year in rent payments.4
Robust financial penalties are critical to deterring repeat offenders. The attached Short-Term Rental Data sheet reveals that just eight Airbnb hosts are responsible for more than 200 listings in Beverly Hills—many of them illegal listings in apartment buildings. Such operators are clearly undeterred by the current fine structure, which caps out at $500 for repeat offenses. Given the average STR in Beverly Hills in June generates $836 per night, the current penalties are insufficient.5 We support the staff recommendation to increase fines for repeat violations to the maximum amount allowed under state law.

A STR ban is only as valuable as the enforcement that backs it. The City must implement a centralized enforcement system that issues immediate penalties when violations are identified. In Los Angeles, high administrative burden and a decentralized system of Home-Sharing Ordinance enforcement has led to rampant abuse of the STR market. As of 1 https://data.census.gov/table/ACSST5Y2023.S2502?t=Owner/Renter+(Householder)+Characteristics&g=160XX00 US0606308 2 https://beverlypress.com/2024/03/weho-passes-one-year-housing-lease-rule/ 3 https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/rhna/cahf-2040-rhna-report-2024.pdf 4 https://upgo.lab.mcgill.ca/publication/bc-str-2024/Wachsmuth_BC_STR_2024.pdf 5 BNLA analysis of Inside Airbnb data from June 2025; https://insideairbnb.com/ Better Neighbors Comment Letter
Agenda Item E-1: Amending Short Term Rental Regulations

Page 3 of 3 ends

May 1, 2025, BNLA estimates that over 30% of STR listings in LA City are non-compliant.6 To avoid similar issues, Beverly Hills should develop strong, enforceable rules with a low threshold of administrative burden in order to issue citations and maintain the ordinance’s effectiveness.

Beverly Hills is not alone in their push to ban STRs. This effort is part of a broader regional movement. Cities throughout Southern California have enacted strong STR regulations to protect long-term housing stock. In April 2024, the City of Santa Ana reconsidered their existing de facto STR ban and voted to codify it to meet their California Department of Housing and Community Development Regional Housing Needs Allocation requirement.7 The City Councils of Calabasas, Diamond Bar, Rosemead, Culver City, San Gabriel, La Habra, Lakewood, Rolling Hills, Redondo, Lawndale, Garden Grove, and Laguna Hills have STR bans in place.8
The data demonstrates STR activity in Beverly Hills has surged 259% between January 2022 and August 2024.9 A comprehensive STR ban, paired with a one-year minimum lease and a rigorous enforcement mechanism will help preserve City resources, protect residents from the negative effects of short-term rentals, and safeguard long-term residents from increasing housing costs and the threat of displacement. For these reasons, Better Neighbors urges the City Council to:
• Ban short-term rentals in all residential units;
• Adopt a one-year minimum lease requirement across all residential zones; and • Establish a penalty schedule that sets fines to the maximum extent allowed under state law.

Should you have any questions or would like additional information, please contact Maura O’Neill at [email protected].

Sincerely,
/s/ Randy Renick
6 BNLA analysis of Inside Airbnb data; https://insideairbnb.com/ 7 https://www.santa-ana.org/short-term-rentals-ban/ 8 Calabasas: https://library.municode.com/ca/city of calabasas/codes/code of ordinances?nodeId=TIT17LAUSDE ARTIIZODI ALLAUS_CH17.12STSPLAUS_17.12.175SHRMREOCPRPREXLAAPHOMOBEBRIN Diamond Bar: https://www.diamondbarca.gov/Faq.aspx?QID=314 Rosemead:
https://library.municode.com/ca/rosemead/ordinances/code_of_ordinances?nodeId=900458 Culver City:
https://www.culvercity.org/Have-Your-Say/Short-Term-Rentals San Gabriel: https://www.sangabrielcity.com/1341/FrequentlyAsked-Questions#:~:text=Short-term%20rentals%20(anything%20less,term%20rental%20or% La Habra:
https://www.lhhcity.org/325/Short-Term-Rentals Lakewood: https://www.lakewoodcity.org/Business/Short-term-rentals Rolling Hills: https://library.municode.com/ca/rolling_hills_estates/codes/code_of_ordinances?nodeId=TIT17ZO_CH17.47SHRMRERE _17.47.020PU Redondo Beach: https://www.redondobeachtourism.com/news/airbnb Lawndale: https://ecode360.com/LA4957 Garden Grove: https://ggcity.org/code-enforcement/short-term-vacation-rental-detailed-terms Laguana Hills:
https://voiceofoc.org/2023/05/hed-laguna-hills-bans-short-term-rentals/ 9 BNLA analysis of Inside Airbnb data; https://insideairbnb.com/

Victor De la Cruz
Manatt, Phelps & Phillips, LLP
Direct Dial: (310) 312-4305
[email protected]
Manatt, Phelps & Phillips, LLP 2049 Century Park East, Suite 1700, Los Angeles, California 90067 Tel: 310.312.4000 Fax: 310.312.4224 June 25, 2025 Client-Matter: 70815-031
Mayor Nazarian and Councilmembers
City of Beverly Hills
455 N. Rexford Dr.

Beverly Hills, CA 90210
Re: Comments on Proposed Short-Term Rental Regulations Ordinance Dear Mayor Nazarian and Honorable Councilmembers:

We are writing on behalf of The Belvedere Partnership dba The Peninsula Beverly Hills (the “Peninsula”), to provide comments on the City of Beverly Hills’ proposed short-term rental regulations ordinance, which we understand you are currently scheduled to consider at your meeting of July 1, 2025.

At the outset, we would like to thank both staff of the Department of Community Development and the City Planning Commission for all their hard work arriving at a proposed draft ordinance that we believe is leagues better than the current regulatory scheme. The proposed ordinance will better ensure that short-term rentals do not continue to adversely impact the City’s collection of transient occupancy tax, the character of the City’s residential neighborhoods, and the affordable housing crisis plaguing the region.

Attached to this letter are our proposed minor amendments to the draft ordinance in redline form, together with comments explaining our rationale for them. You will see that the bulk of our comments have to do with enforcement, given the high degree of evasion and noncompliance that Beverly Hills and other cities throughout Southern California have experienced, and which we believe should be of special concern in Beverly Hills, where violators would be willing to take their chances on receiving and ignoring citations given the high revenue amounts that short-term rentals in the City command.

The Peninsula is concerned that the hotel business in Beverly Hills has and will continue to be negatively impacted by illegal short-term rentals throughout the region.

We know the City understands that the City’s marquee hotels—some of the finest in the world—are here in Beverly Hills, and the City has much to gain from their continued Honorable Mayor Nazarian and Councilmembers
June 25, 2025

Page 2 ends

success and the transient occupancy tax they bring to the City’s coffers. As such, we hope you will work with our client on arriving at ordinance language that provides real enforcement mechanisms that best ensure compliance.

Thank you very much for your time and attention to this matter.

Very truly yours,
Victor De la Cruz
Manatt, Phelps & Phillips, LLP
cc: Chloe Chen, Principal Planner, Long-Range Planning, Community Development Department

City Council find the ordinance is exempt from CEQA because it can be seen with certainty that there is no potential for such ordinance to have a significant adverse effect on the environment pursuant to CEQA Guidelines Section 15061(b)(3). Section 15061(b)(3) of Title 14 of the California Code of Regulations states that CEQA applies only to projects which have the potential for causing a significant effect on the environment. The Amendments do not authorize construction and only involve revisions to existing standards and land use limitations for certain residential zones in the City. Therefore, it can be seen with certainty that the draft ordinance has no potential to cause a significant effect on the environment and the Amendments are categorically exempt from further review under CEQA pursuant to Section 15061(b)(3) and 15305 of Title 14 of the California Code of Regulations.

Section 8. Section 10-3-406 (Businesses Prohibited) of Article 4 (One-Family Residential Zone (R-1)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-406: BUSINESSES PROHIBITED:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1. All property and buildings in zone R-1 hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A singlefamily transient use of a “single-family residence” or “accessory dwelling unit”, as defined in section 10-3-100 of this chapter is prohibited.”
Section 9. Section 10-3-501 (Uses and Buildings Permitted) of Article 5 (One-Family Residential Zone (R-1.X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-501: USES AND BUILDINGS PERMITTED:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1.X. All property and buildings in zone R-1.X hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A single-family transient use of a “single-family residence” or “accessory dwelling unit”, as defined in section 10-3-100 of this chapter is prohibited.” Section 11. Section 10-3-601 (Uses and Buildings Permitted) of Article 6 (One-Family Residential Zone (R-1.5)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-601: USES AND BUILDINGS PERMITTED:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1.5. All property and buildings in zone R-1.5 hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A single-family transient use of a “single-family residence” or “accessory dwelling unit”, as defined in section 10-3-100 of this chapter is prohibited.” Section 13. Section 10-3-701 (Uses and Buildings Permitted) of Article 7 (One-Family Residential Zone (R-1.5X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-701: USES AND BUILDINGS PERMITTED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.5X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 14. Section 10-3-704 (Businesses Prohibited) of Article 7 (One-Family Residential Zone (R-1.5X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-704: BUSINESSES PROHIBITED:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1.5X. All property and buildings in zone R-1.5X hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A single-family transient use of a “single-family residence” or “accessory dwelling unit”, as defined in section 10-3-100 of this chapter is prohibited.” Section 15. Section 10-3-801 (Uses and Buildings Permitted) of Article 8 (One-Family Residential Zone (R-1.5X2)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-801: USES AND BUILDINGS PERMITTED:

A single-family transient use of a “single-family residence” or “accessory dwelling unit”, as defined in section 10-3-100 of this chapter is prohibited.” Section 17. Section 10-3-901 (Uses and Buildings Permitted) of Article 9 (One-Family Residential Zone (R-1.6X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning of the BHMC is hereby amended to read as follows:
“10-3-901: USES AND BUILDINGS PERMITTED:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1.6X. All property and buildings in zone R-1.6X hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A single-family transient use of a “single-family residence” or “accessory dwelling unit”, as defined in section 10-3-100 of this chapter is prohibited.” Section 19. Section 10-3-1001 (Uses and Buildings Permitted) of Article 10 (OneFamily Residential Zone (R-1.7X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read:
“10-3-1001: USES AND BUILDINGS PERMITTED:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1.7X. All property and buildings in zone R-1.7X hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A single-family transient use of a “single-family residence” or “accessory dwelling unit”, as defined in section 10-3-100 of this chapter is prohibited.” Section 21. Section 10-3-1101 (Uses and Buildings Permitted) of Article 11 (OneFamily Residential Zone (R-1.8X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1101: USES AND BUILDINGS PERMITTED:

Except as otherwise provided in this article, no lot, premises, building or portion thereof in zone R-1.8X shall be erected, constructed, built, altered, enlarged, built upon, used, or occupied for any purpose except as a private one-family residence, family daycare home licensed pursuant to state law, small or large residential community care facility operating in compliance with section 10-3-2778 of this chapter, or transitional or supportive housing structured as a single-family residence.”
Section 22. Section 10-3-1104 (Businesses Prohibited) of Article 11 (One-Family Residential Zone (R-1.8X)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1104: BUSINESSES PROHIBITED:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-1.8X. All property and buildings in zone R-1.8X hereby are limited to strictly private one-family residential uses except as otherwise provided in this article. A single-family transient use of a “single-family residence” or “accessory dwelling unit”, as defined in section 10-3-100 of this chapter is prohibited.” Section 23. Section 10-3-1209 (Businesses Prohibited; Exceptions) of Article 12 (Multiple Residential Zone (R-4)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1209: BUSINESSES PROHIBITED; EXCEPTIONS:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-4, except the business of an apartment house. All property and buildings in zone R-4 hereby are limited to residential uses, except as otherwise provided in this article. A multi-family transient use as defined in section 10-3-100 of this chapter is prohibited.”
Section 24. Section 10-3-1242 (Uses Prohibited) of Article 12.3 (Multiple-Family Residential-Commercial Parking Zone (RMCP)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby added to read as follows:
“10-3-1242: USES PROHIBITED:

A multi-family transient use as defined in section 10-3-100 of this chapter is prohibited.” Section 25. Section 10-3-1304 (Businesses Prohibited, Exceptions) of Article 13 (Residential Income and Multiple Dwelling Zone (R-4X1)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1304: BUSINESSES PROHIBITED; EXCEPTIONS:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-4X1 except for the business of an apartment house. All property and buildings in zone R-4X1 hereby are limited to residential uses, except as otherwise provided in this article. A multi-family transient use as defined in section 10-3-100 of this chapter is prohibited.”
Section 26. Section 10-3-1503 (Businesses Prohibited; Exceptions) of Article 15 (Multiple Residential Zone (R-3)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1503: BUSINESSES PROHIBITED; EXCEPTIONS:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-3, except the business of an apartment house. All property and buildings in zone R-3 hereby are limited to residential uses, except as otherwise provided in this article. A multi-family transient use as defined in section 10-3-100 of this chapter is prohibited.”
Section 27. Section 10-3-1543 (Businesses Prohibited; Exceptions) of Article 15.3 (Residential Parking Zone (R-4-P)) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1543: BUSINESSES PROHIBITED; EXCEPTIONS:

Except as provided in article 43 of this chapter, no business shall be conducted or maintained in any building or upon any lot or premises, or upon any portion of either thereof, in zone R-4, except the business of an apartment house. All property and buildings in zone R-4 hereby are limited to residential uses, except as otherwise provided in this article. A multi-family transient use as defined in section 10-3-100 of this chapter is prohibited.”
Section 28. Section 10-3-1877 (Restricted Uses) of Article 18.7 (Mixed Use (MU) Overlay Zone) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-1877: RESTRICTED USES:

The following restrictions shall apply to mixed use development in the MU Overlay Zone:

A. No medical uses may be included in a mixed use development.

B. No entertainment uses including, but not limited to, cabarets, nightclubs, and adult entertainment businesses, may be included in a mixed use development.

C. Residential uses included as part of a mixed use development shall be permitted in all portions of the development regardless of the underlying zone, except that residential uses shall not be permitted within the first forty feet (40’) of depth from any street-facing property line of the first floor, except as otherwise allowed through the development plan review request.

Further, no commercial uses shall be allowed above the third story of a mixed use development.

E. A multi-family transient use as defined in section 10-3-100 of this chapter is prohibited, including in the residential portions of a mixed-use development project.

F. The planning commission shall have authority through conditions imposed on a development plan review permit to prohibit uses not specified herein, on a use by use basis, if it finds that the proposed uses will have a significant adverse impact on adjacent uses, or will not promote harmonious development of the area.”
Section 29. Section 10-3-302 (Permitted And Conditionally Permitted Uses For Residential Zoning Districts And Zoning District Overlays) of Article 3 (Establishment Of Zones; Permitted And Conditionally Permitted Uses) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows with all other sections remaining unchanged:
“The following charts establish permitted uses and conditionally permitted uses in all residential zoning districts and zoning district overlays:

ALLOWED USES AND PERMIT REQUIREMENTS FOR SINGLE-FAMILY

RESIDENTIAL ZONING DISTRICTS AND ZONING DISTRICT OVERLAYS P = Permitted use UP = Use permit CUP = Conditional use permit R-1 R1.X
R1.5
R1.5X R1.5X
2 R1.6XR1.7
X
R1.8
X
Accessory dwelling units and junior
accessory dwelling units (subject to
article 50 of this chapter)

P P P P P P P P
Single-family dwelling P P P P P P P P
Transitional and supportive housing
1 :

Single-family structure P P P P P P P P
Family daycare homes, licensed
pursuant to state law

P P P P P P P P
Community residential care facility2
(state licensed):

Small (serving 6 or fewer) P P P P P P P P
Large (serving 7 or more) P3 P3 P3 P3 P3 P3 P3 P3
Educational institutions CU
P
CUP
4 CU
P
CUP4
Museums CU
P
CUP CU
P

Public utility uses (except as
provided in section 10-3-2754 of
this chapter)
CU
P
CUP CU
P

Religious institutions CU
P
CU
P

Public libraries CUP
Publicly owned playgrounds CUP
Home occupations (subject to
section 10-3- 4303 of this chapter)

P P P P P P P
Notes:

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a single- family residence, it is regulated as such and is subject to all regulations applied to residences in the single-family residential zone where it is located.

4. Public educational institutions only.

ALLOWED USES AND PERMIT REQUIREMENTS FOR MULTIPLE-FAMILY

RESIDENTIAL ZONES AND ZONING DISTRICT OVERLAYS
P = Permitted use CUP = Conditional use permit
R-4 RMC
P
Specia
l
Needs
Housi
ng
Overla
y Zone
5 R4X
1 R4X
2 R
-
3 R4-P
Single-family dwelling P P P P P
Accessory dwelling units and junior
accessory dwelling units (subject to article
50 of this chapter)

P P P P P P
Multiple-family dwellings P P P P P P
Transitional and supportive housing:

Single-family structure P1 P1 P1 P1 P1
Multi-family structure P1 P1 P1 P1 P1
Family daycare homes, licensed pursuant
to state law

P P P P P P
Emergency shelters (subject to section 10-
3-1275 of this chapter)
P
Single room occupancy housing (SRO) CUP
Community residential care facilities2
(state licensed):

Small (6 or fewer) P P P P P P
Large (7 or more) P3 P3 P3 P3 P3 P3
Public library P P P
Childcare uses licensed pursuant to state
law
CU
P
CUP CU
P
CU
P
Educational institutions CU
P
CUP CU
P
CU
P
Multiple-family congregate housing for the
elderly or disabled pursuant to article 12.8
of this chapter
CUP
Multiple-family housing for the elderly or
disabled pursuant to article 12.5 of this
chapter
CU
P
CUP CU
P
CU
P
Museums CU
P
CUP CU
P
CU
P
Public utility uses4 CU
P
CUP CU
P
CU
P
Religious institutions CU
P
CUP CU
P
CU
P
Restaurants located in nonconforming
hotels (subject to section 10-3-1207 of this
chapter)
CU
P
CUP CU
P
CU
P
Convenience retail uses (subject to section
10-3-1233 of this chapter)
CUP
Public parking uses CUP
Ancillary retail uses6 P
Ancillary parking facilities6 P
Notes:

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a multiple- family residence, it is regulated as such and is subject to all regulations applied to residences in the multiple-family residential zone where it is located.

4. Except as provided in section 10-3-2754 of this chapter.

5. Uses allowed in the special needs housing overlay zone are in addition to any use allowed in the underlying zoning district.

6. If approved by the planning commission as part of a planned development pursuant to article 18.4 of this chapter.
(Ord. 17-O-2724, eff. 2-10-2017; amd. Ord. 24-O-2892, eff. 4-18-2024; Ord. 24- O-2894, eff. 6-7-2024).”
Section 30. Subsection A of Section 10-3-303 (Permitted and Conditionally Permitted Uses for Nonresidential Zoning Districts and Zoning District Overlays) of Article 3 (Establishment of Zones; Permitted and Conditionally Permitted Uses) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows, with all other sections to remain unchanged. Subsection A is currently in the process of being added and codified for another pending ordinance, but shall be amended subsequently by this ordinance as follows:
“A. Permitted Uses: Uses for all nonresidential zones and zoning district overlays are listed in the article addressing each specific zone or zoning district overlay. Unless otherwise specified by the zoning district overlay or specific project approval, multi- family transient uses shall be prohibited.”
Section 31. Section 10-3-4302 (Prohibited Home Occupation Activities) of Article 43 (Home Occupations) of Chapter 3 (Zoning) of Title 10 (Planning and Zoning) of the BHMC is hereby amended to read as follows:
“10-3-4302: PROHIBITED HOME OCCUPATION ACTIVITIES:

Notwithstanding any other provision to the contrary, no person shall engage in, permit, carry on, or conduct any of the following activities as a home occupation at any time in a residential zone:

A. Repair, servicing, alteration, assembly, upholstery, or construction of any automobile or other motor vehicle as defined in the California Vehicle Code; B. Any hotel use or any other transient lodging use for compensation or benefit of any kind, including, but not limited to, the operation of bed and breakfast inns, hostels, hotels, or any similar operation;
C. Restaurant, excluding a restaurant or caterer that delivers goods or services to a residential site, has a principal place of business outside of any residential zone, and conducts no administrative or processing function within a residential zone; D. Caterer, unless a permit shall have first been obtained from the director of building and safety approving any equipment to be installed and operated in connection with the catering business;
E. Rental of any residence, or any portion thereof, for events or activities such as parties, banquets, auctions, or similar activities, except in connection with nonprofit and/or charity functions, provided such nonprofit or charity functions are limited to one time per quarter not to exceed four (4) times in any twelve (12) month period; F. All activities regulated under title 4, chapter 2 of this code; G. Activities regulated under title 4, chapter 3 and chapter 4, article 5 of this code except as authorized by permit under title 4 of this code and consistent with the provisions of this article;
H. Any activity that would produce biohazardous or medical waste, as those terms are defined in the California Health and Safety Code, or involves the storage of materials in a manner that would result in a change in the occupancy classification of a residential structure under the city’s building code, mechanical code, fire code or plumbing code, or that would otherwise violate any building or fire code or other law; I. Conduct any use, other than a residential use, prohibited in the C-3 zone; J. Conduct any use conditionally permitted in the C-3 zone; K. Manufacturing, excluding activities or occupation such as: 1) artists, authors or composers; 2) dressmakers, seamstresses, or tailors; and 3) home crafts, including, without limitation, model making, rug weaving, quilting, needle work, jewelry making, woodworking, and other similar activities which are consistent with the primary use of the dwelling as a residence, provide that such activities are limited to the use of tools and equipment commonly available for personal residential use.

From: Darian Bojeaux
To: City Clerk
Subject: E 1, Short Term Rental Regulations
Date: Sunday, June 29, 2025 3:47:30 PM
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Would you please read this e-mail at the council meeting? Thank you.

Darian Bojeaux
Dear Mayor, Vice Mayor, and Council Members,
My family members and I wholeheartedly approve of the proposed short term rental regulations requiring rentals to be for a minimum of 1 year. However we are requesting that historical residential properties such as Debbie Blum’s lovely craftsman home at , whose owners live on-site, be exempted from these regulations for the following reasons.

These historical residences are wonderful attractions which enhance and add character to our city, and the more people who can rent and experience these historical architectural treasures, the better.

Also very important, such historical properties are very expensive to maintain authentically and require expensive expert craftspeople, special materials which are not always readily available, and expert advice as to how to meet required standards.

Allowing this exception to just a few historical residential R-1 properties in the city will enable their owners to continue to properly maintain them which is in the best interests of our city and community.

Thank you for considering this perspective.

Darian Bojeaux
From: Marlene Dobkin
To: City Clerk
Subject: Agenda Item E 1
Date: Sunday, June 29, 2025 8:39:23 PM
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Dear Council Members,
We understand that the planning commission is advocating a ban on short term rentals. We were not aware that we were experiencing a problem with these rentals, but assuming we are, we want to express our support for coming up with a more flexible ordinance.

We believe you should write into the ordinance that the owners of historic landmark properties be allowed to engage in short term rentals to raise money for the upkeep of their homes. These homeowners have extraordinary costs associated with the preservation and maintenance of their homes. Our cities collection of well maintained historic properties is one of our great assets. These homes enhance our neighborhood’s appeal, draws tourism, and preserves the distinctive character that makes Beverly Hills special.

We respectively ask that you craft any new regulations to include specific provisions for historic property owners who demonstrate that rental income directly supports preservation efforts. The maintenance and preservation cost can be overwhelming.

Thank you
Marlene & Jerry Dobkin
Residents since 1971

As a resident of a multi-family building impacted by a short-term rental in the unit above me, I fully support and appreciate this recommendation.

In 2023, Mr. Mark Elliot and I met with Mr. Forbes and Ms. Medina, and we were informed that remedies were being put in place and were being addressed by Code Enforcement. Since that meeting, I reached out to Code Enforcement several times regarding an active Airbnb rental above my unit. Other residents from different properties have expressed concerns about short-term rentals at their locations. Code Enforcement officers, under the direction of Ms. Leslie Medina, informed us that unless the situation is “life-threatening,” they would not address these concerns.

While a short-term rental may not be considered life-threatening, it significantly impacts residents’ quality of life and peaceful enjoyment of their units or homes.

The guidelines for short-term rentals are clearly outlined in the ordinance and must be enforced as part of Code Enforcement’s responsibilities.

I respectfully request that the Council consider adopting a uniform policy requiring a one-year minimum lease for both single-family and multi-family dwellings as part of this ordinance, with penalties for violations. Moving forward, I also encourage the Council to ensure that Code Enforcement is actively investigating and enforcing this ordinance.

Thank you for your time and attention to this important matter.

Have a pleasant evening.

Sincerely,
Kathy Bronte

lease duration. Additionally, the Planning Commission Report raised research from both McGill and the Real Estate Economics journal and their impacts on the housing supply to support this measure. However, it was noted during the meeting that both of these research studies were based on short-term nightly rentals, less than 30 days, but did not include any data or findings regarding mid-term housing.

Moreover, mid-term tenants often transition into long-term residents. Imposing a 6-month minimum lease could deter future residents who might otherwise choose to make Beverly Hills their permanent home. While alternatives like AKA were mentioned during the meeting, their pricing structure – starting at $10,000 per month for a one-bedroom – places them well beyond the reach of many individuals and families seeking mid-term housing solutions.

The existing 1-month minimum strikes a fair balance between regulating short-term vacation rentals and accommodating legitimate mid-term housing needs. It protects the integrity of the community while addressing the realities of a diverse population with varying housing requirements.

I respectfully urge the council to reconsider the proposed 6-month minimum lease requirement and maintain the current 1-month minimum lease term. This approach ensures Beverly Hills remains a welcoming and inclusive community that meets the needs of its residents, both current and future.

Thank you for your attention to this matter and for your ongoing dedication to our city.

Sincerely,
Nathan
From: Huma Ahmed
To: City Clerk
Subject: FW:

Date: Tuesday, July 1, 2025 9:37:22 AM
This was in our Spam folder.
-----Original Message-----
From: victor bardack
Sent: Monday, June 30, 2025 11:32 AM
To: City Clerk <[email protected]>; Darian Bojeaux Subject:

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Dear City Council,
Please exclude Debbie Blum's home from the list of short term rentals The Blum's have economic and age challenges.

They have always been generous supporter of Beverly Hills. They have opened their home for City Events at no charge.

They are the type of Residents that make our City the caring place that it is.

Thank you for your consideration
Sincerely,
Victor Bardack
Beverly Hills North Homeowners Association, Past President

Wiseman Dawoody
(
Building Trust :

Commitments Made – Commitments Kept
It is Sincerity and Willingness to Give to Life More than you Expect to Receive
The information contained in this message is privileged, confidential, and protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer.

Used ChatGPT for the following:
----------------------------------------------------------------- Are You Scapegoating STRs for Housing Costs?
The claim that STRs drive unaffordable housing lacks evidence. A Purdue University study on Irvine’s STR ban showed only a 2.7% drop in rental prices, suggesting STRs aren’t the affordability villain (Siebert et al., Purdue University). A 2021 CGO study in Santa Monica found STR restrictions can increase housing prices by limiting property owners’ flexibility (The CGO: In Search of Peace and Quiet).
• What rigorous study proves STRs significantly drive Beverly Hills’ housing costs? • Why target STRs when zoning and supply constraints are the real culprits? • How does stripping homeowners’ income options help affordability for residents? Do Minor Complaints Justify Overreach?
The city’s concerns—noise, parties, or privacy—are minor and already addressed by noise ordinances, nuisance laws, and police response. A 2024 NBER study on Chicago’s STR ordinance, with registration and a 4% tax, reduced listings by 16.4% while lowering burglaries near regulated STRs, proving smart regulation works without bans (NBER Working Paper 32537). • Where is the comprehensive data quantifying the scope of STR-related complaints? • Why pursue a new ordinance when existing laws handle noise and disturbances? • How do you justify blanket restrictions over targeted solutions proven effective elsewhere? Why Burden Homeowners with Unenforceable Rules?
The city admits tracking STR violations is “difficult,” yet proposes a new enforcement department, passing costs to homeowners. A 2019 Strong Towns analysis shows STRs prevent displacement by providing income, strengthening neighborhoods (Strong Towns: STRs Make Neighborhoods Stronger).
• Why create unenforceable rules, as seen in New York’s failed bans, that drive STRs underground?
• How is it fair to saddle homeowners with enforcement costs for a minor issue? • Why force residents to bear the financial brunt of a bureaucracy you admit struggles to function? Why Undermine Beverly Hills’ Economy?
STRs are an economic boon. A 2017 San Diego study found STRs generated $285 million in economic impact, with $86.4 million spent on local businesses (Airbnb Economic Impact Report). In Beverly Hills, a global tourism magnet, STRs channel tourist dollars to local shops and restaurants, boosting Transient Occupancy Tax revenue.
• Why choke off this economic lifeline to favor hotels? • How does restricting STRs align with sustaining our tourism-driven economy? • Where is the data showing STRs harm local businesses more than they help? Whose Interests Are You Serving?
As our representatives, your duty is to support Beverly Hills residents, not police our property rights.

By restricting STRs, you push homeowners to operate covertly to survive financially, labeling them “violators.”
• Why treat property owners as adversaries instead of partners? • Are you representing residents or appeasing a vocal minority with unproven complaints? • How does forcing homeowners into non-compliance foster trust in your leadership? • Shouldn’t you empower residents to stay in their homes rather than dictate how they use them? A Balanced Path Forward
Instead of a new ordinance, adopt a fair framework:

1. Streamlined licensing for STR hosts to ensure accountability.

2. A modest STR tax to fund community services, as proven in Chicago.

3. Reasonable caps on rental days or guests to address concerns.

4. Platform data-sharing for efficient enforcement without new bureaucracies.

Conclusion
The evidence is clear: STRs fuel Beverly Hills’ economy, have negligible impact on housing costs, and help residents survive financially. A new restrictive ordinance lacks data on the scope of STR issues and risks harming homeowners more than helping neighborhoods. I urge you to answer these questions, reflect on your rationale, and choose representation over regulation. Support a balanced policy that empowers residents and preserves our city’s vibrancy.

Sincerely,

significantly reduce options for these visitors, potentially discouraging them from coming to our city altogether.

3. Potential Economic Harm to Local Businesses and Tourism July is a peak travel season. Limiting accommodations by restricting short-term rentals during this critical time could dissuade travelers and lead them to choose other cities that are more welcoming and flexible. This in turn affects local businesses—restaurants, shops, and service providers—who rely heavily on the economic activity generated by tourism and short-term visitors.

4. Enforcement and the Issue of "Party Houses"
While concerns about noise and misuse are valid, these issues should be addressed through targeted enforcement and regulation, not blanket bans. The vast majority of shortterm rental hosts are responsible and take great care to vet guests, uphold community standards, and follow city rules. The assumption that all short-term rentals become party houses is inaccurate and unfair to many law-abiding property owners.

5. Need for Broader Community Involvement
Finally, I believe that a decision of this magnitude should involve direct input from the community at large. A measure with such significant implications deserves to be put to a public vote or at the very least should undergo more extensive outreach to ensure that a diverse range of voices are heard before a final decision is made.

I urge the Council to consider a more balanced approach—one that includes safeguards against abuse (such as registration, occupancy limits, and fines for violations), while still allowing responsible property owners to operate short-term rentals under clearly defined guidelines.

This city has always been known for its diversity, compassion, and inclusivity. Let us ensure that our policies reflect those values by allowing for flexible, fair, and thoughtfully regulated short-term rental practices.

Thank you again for your time, dedication, and consideration of this important issue. I respectfully urge you to reconsider the proposed ordinance and to seek a solution that supports both community interests and individual rights.

Warm regards,
Noushin Ahobim
Resident and Realtor

Attachment 6
New Correspondence (As of 7/1/2025)
Victor De la Cruz
Manatt, Phelps & Phillips, LLP
Direct Dial: (310) 312-4305
[email protected]
Manatt, Phelps & Phillips, LLP 2049 Century Park East, Suite 1700, Los Angeles, California 90067 Tel: 310.312.4000 Fax: 310.312.4224 July 9, 2025
Client-Matter: 70815-031
Mayor Nazarian and Councilmembers
City of Beverly Hills
455 N. Rexford Dr.

Beverly Hills, CA 90210
Re: Comments on Proposed Short-Term Rental Regulations Ordinance – Private Cause of Action and Clarification on “Responsible Person” Dear Mayor Nazarian and Honorable Councilmembers:

We are writing on behalf of The Belvedere Partnership dba The Peninsula Beverly Hills (the “Peninsula”), to provide additional comments on the City of Beverly Hills proposed shortterm rental regulations ordinance (the “Ordinance”), which we understand you are currently scheduled to consider again at your meeting of July 15, 2025.

As you know, at your July 1, 2025, meeting, when you first considered the Ordinance, we provided a mark-up which we believe strengthens certain provisions and also bolsters the overall enforceability of the Ordinance. The City Attorney opined that some of our proposed language would be duplicative of general provisions in the City’s Municipal Code. While we would have preferred our suggestions to be specifically codified with the short-term rental regulations because we believe they are particularly prone to violation, we respect the City Attorney’s viewpoint on the matter and are therefore limiting our comments at this point to two items that we believe are of particular importance: (1) the inclusion of a private cause of action; and (2) clarity on who would be a “responsible party” for purposes of violations.1 With respect to a private cause of action, although there was one passing reference at your meeting to this concept potentially being susceptible to abuse, we would like to offer some additional perspective. First, a private cause of action would not be novel. For example, the City of Beverly Hills has already provided for a private cause of action in the entitlements for the former Wanda Project at 9900 Wilshire, now the One Beverly Hills Project, which states that “[a]ny person in the City who pays TOT to the City shall be a third-party beneficiary with a right to enforce the [short-term rental] provisions against the Association and/or the unit owners if the City or the Association fails to do so . . .”. (See Condition No. 100.) Likewise, the City of Santa Monica’s Home-Sharing Ordinance provides that “[a]ny interested person may seek an injunction or other relief to prevent or remedy violations of this Chapter. The prevailing party in such an 1 We note that some of our comments on the draft Ordinance prior to the enforcement provisions were not duplicative and in some cases strengthen the Ordinance and/or correct typographical errors. We hope these comments will be considered as well.

Honorable Mayor Nazarian and Councilmembers
July 9, 2025

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action shall be entitled to recover reasonable costs and attorney’s fees.” (See Santa Monica Municipal Code Section 6.20.100(c).) Notably, challenges to the City of Santa Monica’s HomeSharing Ordinance by both Airbnb, Inc. and Homeaway.com were denied by both a Federal District Court and the 9th Circuit Court of Appeals.

Besides being a fairly accepted practice, a private cause of action in this instance would also be good policy. As you know, the City is often short-staffed and does not have the resources to effectively pursue every violator. In that regard, the hotel sector can be an important ally to the City in pursuing enforcement.2 A private cause of action would be a very meaningful deterrent in that violators would be particularly wary about being liable for legal fees and damages if they were to lose a lawsuit filed by an interested party. With respect to concerns about abuse, courts do not allow frivolous filings and someone who files a lawsuit in bad faith would be subject to a malicious prosecution claim. Accordingly, we see no reason why the City should not allow a private cause of action – very little has been done to create new enforcement mechanisms in the Ordinance, so its omission is in effect a continuation of a status quo where violators rent out properties illegally with near impunity.

The second change is one that you directed your City Attorney to look into – our proposed language clarifying the definition of a “responsible person” under the Ordinance. We cannot emphasize the importance of our proposed language clarifying that potential violators could include, but not be limited to, “a homeowners association, real estate agent, broker, hosting platform (residential, hotel, or otherwise), or listing agent”. We understand that there is vague language in the existing Code stating that a responsible person is any person “who creates, maintains, permits, or allows a violation of this code” and this could conceivably include anyone.

However, a whole range of violators would still be able to argue in court that the Ordinance only reaches property owners. And more importantly, there is a very significant benefit to providing specificity and putting every potential violator on notice. By being very specific in the Ordinance, the City would also be providing very clear guidance to Code Enforcement staff who are likely not lawyers and will not be parsing Code language. Simply stated, it is very important that everyone has the requisite understanding of who can be considered liable for causing a violation of the Ordinance.

We hope you consider the above suggestions. The Ordinance is a critical tool to protecting residential neighborhoods, the success of the City’s world-class hotels, and importantly, the City’s transient occupancy tax receipts. We believe these two changes would go a long way in providing truly meaningful enforcement that would ensure your efforts to adopt the Ordinance are not in vain.
2 Our mark-up to the Ordinance provided a private cause of action to “any interested person” similar to Santa Monica’s ordinance; however, there is no reason the City could not make the private cause of action available only to a party who pays transient occupancy tax to the City, such as it did in the Wanda Project entitlements.

Honorable Mayor Nazarian and Councilmembers
July 9, 2025

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Thank you very much for your time and attention to this matter.

Very truly yours,
Victor De la Cruz
Manatt, Phelps & Phillips, LLP
cc: Laurence Wiener, City Attorney
Chloe Chen, Principal Planner, Long-Range Planning,
Community Development Department

Beverly Hills City CouncilJuly 15, 2025

Beverly Hills City Council
July 15, 2025