Santa Barbara Association of REALTORS® | 1415 Chapala Street | Santa Barbara, CA 93101 (805) 963-3787 | (805) 966-9664 FAX | www.sbaor.com REALTOR® is a registered trademark that identifies a professional in real estate who subscribes to a strict code of ethics as a member of the National Association of REALTORS®
May 20, 2025
Mayor Paula Perotte
Mayor Pro Tempore Stuart Kasdin
Councilmember Luz Reyes-Martín
Councilmember James Kyriaco
Councilmember Jennifer Smith
130 Cremona Drive
Goleta, CA 93117
RE: C.2. Short-Term Vacation Rental and Underused Housing Stock (Implementation of Housing Element Subprograms HE 1.7 and 1.8)
Dear Mayor Perotte and Councilmembers,
The Santa Barbara Association of REALTORS® (SBAOR) represents about 1,300 REALTORS® throughout the South Coast and our mission includes engaging in real estate related community issues affecting our members and/or their clients who are homeowners, housing providers, tenants, and commercial owners. As one of the leading organizations on the South Coast primarily focused on housing, we support the staff recommendations for housing priorities for Goleta residents and employees.
We appreciate being able to comment on an issue that we have been an active participant in since its inception. We strongly believe in having a commonsense Short-Term Rental (STR) ordinance which is why in 2017 we partnered with the City of Goleta to mail postcards to every resident informing them about the short-term rental regulations.
We have also conveyed the positive aspects of your ordinance with not only the other municipalities in the Santa Barbara South Coast, but also across the state and nation.
Below are our stances and comments on the staff recommendations:
SUPPORT
1. Update the definition of an STVR and other related uses in the Goleta Municipal Code to better reflect the functional differences between different forms of transient visitor accommodations (such as hosted vs. non- hosted).
2. Collect additional attribute data when issuing licenses in order to collect more information on the types of properties providing tourist accommodations to aid in long-term evaluation of the impact on local housing availability.
3. Update the data collection to provide data that can be used for ongoing monitoring, analysis, and enforcement, such as: o Transient Occupancy Tax (TOT) Remittance. Continue to collect information on TOT remittances in a format that allows authorized staff to identify whether a property and/or unit was actively engaged in visitor accommodations activity (i.e., submitting TOT and for what amount) during a given month. o Availability. Collect information on the number of nights per month that the property was made available for occupancy by short-term visitors. o Occupancy. Continue to collect information on the number of nights per month that the property was booked for occupancy by visitors.
4. Maintain and update annual relicensing procedures to ensure applicable code requirements, such as the fire and safety codes, are met.
Santa Barbara Association of REALTORS® | 1415 Chapala Street | Santa Barbara, CA 93101 (805) 963-3787 | (805) 966-9664 FAX | www.sbaor.com REALTOR® is a registered trademark that identifies a professional in real estate who subscribes to a strict code of ethics as a member of the National Association of REALTORS®
5. Create an STVR property search tool, in order to provide greater public transparency, facilitate identification of non-compliant properties, and encourage the prompt resolution of nuisance issues and associated complaints.
8. Implement enhanced enforcement penalties, such as a “three strikes” policy or points system, that would allow the City to revoke STVR licenses from operators that repeatedly violate STVR regulations noted in the GMC, adopted nuisance standards, and/or who fail to demonstrate a good faith attempt to address problems in a timely manner. We support coordination with the Sheriff’s office.
9. Limit the total number of STVRs that may be permitted within the City at any given time.
13. Update definitions, see Recommendation 1 above.
17. Consider fewer restrictions on hosted STVRs or consider using differential regulations for hosted and non- hosted STVRs to allow for short-term renting to facilitate homeownership, while limiting the prevalence of absentee landlords and corporate ownership within the STVR market. – I think we are ok with this?
18. Market and enforce the “Good Neighbor Guidelines” as noted in the City’s STVR Performance Standards. As noted in GMC subsection 5.08.085(H))(10), these guidelines may include location-specific information, such as neighborhood quiet hours, local speed limits and the prohibition of fires and fireworks in beach areas.
19. Take steps to encourage development of new tourist accommodations other than STVRs that do not impact how the housing stock is utilized, including hotels and motels.
20. Take steps to encourage and facilitate construction of a diversity of housing types that meet the needs of a wide array of workforce households. Note that this recommendation already aligns with programs in the City’s Housing Element 2023- 2031.
OPPOSE
6. Prohibit short-term renting of properties recently subject to a no-fault eviction in order to reduce the incentive for property owners to evict existing tenants in order to convert the property to an STVR.
This has not been an issue that has been prevalent in Goleta and there are already existing regulations in relation to no-fault evictions and therefore this is not needed.
7. Establish a STVR permit waiting period for new home purchases of at least one year following the purchase of a residential property before that property is eligible to apply for an STVR permit.
If homes are permissibly allowed to be a STR, then creating this “waiting” period could be considered a regulatory taking per The Gym 24/7 Fitness, LLC v. The State of Michigan.
10. Create a mechanism to reduce allowed permits and/or discontinue an allowance for STVRs when directed by City Council.
This recommendation seems too vague and does not define what the mechanism would be or when it would be used. Given the ambiguous nature of this recommendation, we request you do not move forward with this recommendation.
11. Apply different standards/allowances within specific geographic subareas that can help to ensure the availability of visitor accommodations in appropriate areas, such as in the Coastal Zone. This approach could also limit STVRs in certain residential zone districts.
If the City moves forward with specific geographic subareas, also known as “overlay zones”, we would want to make sure that a current holder of an allowed STR would be allowed to transfer the Vacation Rental License. This is key to many of the real estate transactions because when buying a property, buyers want to know exactly what they can and cannot do with their property.
Santa Barbara Association of REALTORS® | 1415 Chapala Street | Santa Barbara, CA 93101 (805) 963-3787 | (805) 966-9664 FAX | www.sbaor.com REALTOR® is a registered trademark that identifies a professional in real estate who subscribes to a strict code of ethics as a member of the National Association of REALTORS®
12. Establish STVR density standards that establish a minimum distance between permitted STVR units, or a maximum share of units within a certain defined area that may be short-term rented. This approach could serve as an alternative, or in addition, to geographic standards in Recommendation 11 above.
We have seen this in other cities and there is a devaluation of the properties that do not have the option to become a STR while those that do have the option increase their property valuation. Any changes to this ordinance need to ensure an even playing field for all property owners within the same zone.
14. Establish code provisions regarding fractional ownership and timeshares, limiting the areas where fractional ownership and timeshare uses may be allowed, including both new construction and the acquisition and conversion of existing residential uses.
We understand establishing code provisions for timeshares, but not fractional ownership. Fractional ownership is much different than timeshares in that it has multiple co-owners that use a vehicle like an LLC to divide the partnership. Most fractional ownership properties have HOA-like rules that prohibit the fractional ownership from being rented to anyone outside the partnership. Given the limitations already in place and given the very nature of fractional ownerships, we recommend you do not adopt this recommendation.
15. Create a registry for leases of 31 to 90 days and consider requiring property owners and managers to declare long-term rentals of 31 to 90 days and to notify the City in the event that the rental is cancelled, or the lease broken, within 30 days of the start date.
We are very concerned with this recommendation because it sounds like a rental registry. A rent registry would open the door to major privacy concerns and major cost. A Rental Registry would require private Tenant and Housing Provider Information to be shared with the City. This raises serious privacy concerns. In an era when even the most sophisticated databases get hacked routinely, this is not a wise policy.
The cost of administering the program would be in the millions of dollars and most certainly be passed onto the housing provider. The City of Goleta partakes in an existing staff level program called the Rental Housing Mediation Program that addresses disputes between tenant and housing provider. This program has been extraordinarily successful in resolving disputes. There really is no need for another level of bureaucracy.
16. Establish a maximum number of nights per year that a non-hosted STVR may be rented in certain areas, where full-time resident occupancy is the preferred use. This limitation can reduce the financial incentive to buy second homes to use as STVRs.
We oppose this recommendation at this time because we don’t know what the number is and the possibility it would create a slippery slope of increasing the number at a later date.
We look forward to continuing this important conversation while still allowing property owners to exercise their private property rights.
Sincerely,
Summer Knight
SBAOR 2025 President
Written Comment to City Council Meeting of May 20, 2025 Agenda Item: Discussion/Action Item C.2
Short Term Vacation Rental and Underused Housing Stock
(Implementation of Housing Element Subprograms HE 1.7 and 1.8)
This letter is to support City Council action to strengthen regulations regarding Short Term Vacation Rentals (STVR). I comment as a resident of Goleta for 35 years. I was an educator in local public schools for 26 years. In retirement, I continue to work part-time at Santa Barbara Cottage Hospital.
Current STVR regulations in Goleta are overly broad, too permissive, and lack adequate enforcement supervision. As a result, it is likely that permit applications will increase over time, reducing housing for permanent residences and long-term rental. The decrease in housing availability will increase costs for home ownership and long-term rentals. Equally important, an increased number of STVR properties would be corrosive of our cohesive neighborhoods and a sense of community.
Following are the city staff recommendations that I strongly support. Where the option exists to limit availability of non-hosted STVRs, I further support minimizing such availability to the greatest extent possible.
• Define STVR housing to differentiate clearly between hosted and non- hosted rentals.
• Reduce restrictions regarding hosted STVRs.
• Establish a maximum limit for the number of nights per year that a non- hosted STVR may be rented.
• Limit the total number of STVRs in the city of Goleta at any point in time. • Create mechanisms whereby the Council can reduce the allowable number of STVR permits at any time.
• Create a registry for leases of 31 to 90 days, requiring property owners and managers to declare these rentals, and notify the City in the event the rental is cancelled.
Special Note: Additional Attributes Requiring Council Review Based on personal experience, the following factors also need to be included in City policy regarding STVRs.
1. Private Road Only Access: As resident of a private road, I argue that the city needs to be particularly sensitive to STVR creation in neighborhoods that can only be accessed via narrow private roads. STVRs generate traffic and added use of private roads that the City neither maintains nor funds, placing an added burden on the residents who pay for and maintain the road.
2. On such private roads, access for emergency vehicles must be considered. A private road may not be wide enough for two-way traffic at every point, limiting access for police, fire, and ambulance services. STVRs increase traffic and exacerbate this problem.
3. Fire Danger: Some areas of Goleta have limited access. Adding the traffic from temporary STVR residents increases congestion and limits access in a fire emergency. For me, the recent Holiday Hill Fire is a relevant example.
Roads are inadequate for exit when everyone in an area needs to evacuate quickly at once.
4. Septic Systems: Some Goleta homes rely on septic systems. Current STVR regulations allow for large numbers of people to live in homes with sanitation systems designed for smaller nuclear families. For homes reliant upon such waste disposal, regulations need to be created for maintenance and inspection to reduce the possibility of system failure and ground water contamination.
5. Revise downward the standards for maximum number of occupants.
Current policy allows two people per bedroom plus two more people. In my case, this results in an STVR next door that by Municipal Code can house up to twelve adults in a residence that has never been home to more than two adults and two school aged children.
6. When a Homeowners Association or other regulatory entity exists, require consultation with these agencies prior to permit approval.
Finally, adequate City staffing needs to be supported to supervise STVR enforcement. In our case, despite written requests, we never received notice of our neighbor’s STVR permit approval—essential to the ten-day window to appeal to the City Manager–nor did we ever receive a written Nuisance Response Plan from the owner. These provisions are requirements of our Municipal Code. City government should be cautious about taking on programs if staffing is insufficient to address code compliance and enforcement.
Thank you for allowing this opportunity to provide input. I am grateful and appreciative of the service that you provide to our city.
Dan Cooperman
5947 La Goleta Road