III.4. Short-Term Rental Update; Howard
CITY OF HOPKINS
Memorandum
To: Honorable Mayor and Council Members
Mike Mornson, City Manager
From: Kurt Howard, Planner
Date: March 14, 2023
Subject: Short-Term Rental Update
_____________________________________________________________________
PURPOSE
Staff will present an overview of short-term rentals (STRs) in Hopkins. The presentation
will briefly ground the Council in definitions and the history of STR regulations in
Hopkins, review current regulations that apply, revisit questions raised during the first
STR application review processed by the City, explore potential policy objectives and
recommend adjustments to the City’s regulatory approach to STRs in Hopkins.
Staff will be looking for input and direction from the Council on various policy objectives
and regulatory elements that could be incorporated into a potential update to the City’s
regulations for STRs in Hopkins.
INFORMATION
The growth in the popularity of STRs enabled by online platforms including Airbnb,
Vrbo, and many others has, expanded the reach of the STR market such that its
impacts are felt in a wide variety of communities. Some of these impacts are arguably
positive, such the availability of flexible hospitality options that did not exist before and
economic development benefits. However, STRs can also bring with them negative
impacts, including threats to neighborhood character and nuisances that create tension
between landlords and neighbors. The mix of impacts that STRs will have in Hopkins is
as unique as the community itself, so an effective approach to regulating STRs should
be informed by the community’s goals and vision regarding the role of this land use in
Hopkins.
Short-Term Rentals Defined
Short-term rentals are considered by the zoning code to be a form of lodging. Lodging
is described as “establishments that provide temporary lodging for less than 30 days to
transient guests who maintain a permanent place of residence elsewhere”. Short-Term
Rentals are defined as “all or a portion of a residential dwelling unit offered for rent to
overnight guests for fewer than 30 consecutive days”.
History of Short-Term Rental Regulations in Hopkins
Prior to the Zoning Code Update completed in the summer of 2 022, STRs were not
specifically acknowledged or regulated in the City Code. In 2018, staff adopted an
internal zoning policy of treating short-term rentals the same as bed and breakfasts,
Planning and Economic
Development Department
since code language was readily available and bed and breakfasts have similar impacts
to STRs. During the Zoning Code Update process, the topic of STRs was studied and
considered more closely. It was ultimately decided to specifically acknowledge and
regulate STRs as follows.
Current Regulations
Short-term rentals in Hopkins are currently regulated through three primary means:
zoning, licensing, and general nuisance standards.
In terms of zoning, STR as a land use is permitted in non-industrial mixed-use zones,
conditional in neighborhood zones, and prohibited in all othe r zones. All permitted STRs
in the City are subject to the Supplemental Use Regulations established by the code,
which are:
1. Short-term rentals must comply with all applicable licensing and permit
requirements of the city and Hennepin County.
2. No more than 6 adults and their dependent children may occupy rooms within a
short-term rental.
3. Short-term rentals are not permitted on lots occupied by accessory dwelling
units.
4. External structural alterations or site improvements that change the residential
character of the lot upon which a short-term rental is located are prohibited.
Examples of such prohibited alterations include the construction of a parking lot,
the addition of commercial-like exterior lighting, and signage.
5. A register of short-term rental guests must be maintained and made available to
the city upon request.
6. Short-term rentals may not be used for special events to be attended by
individuals who are not registered guests of the short-term rental unit.
The City Code’s rental licensing requirements apply to STRs in the same manner as
any other rental dwelling unit. Many of these provisions area a natural fit for STRs, but
some rental licensing requirements translate poorly to STRs. Most notably, all rental
licensees are required to conduct criminal background checks on all prospective
tenants.
The City’s general nuisance ordinances related to things like noise, trash, and parking
all apply to properties used for STR the same way they do for all other properties in the
City. These ordinances reinforce the expectation to be a good neighbor and grant the
City authority to step in if nuisances persist.
Questions Raised
The first application for a Conditional Use Permit (CUP) to use a property as a STR was
considered by the Planning and Zoning Commission at its meeting on October 25, 2022
and by the City Council on November 1, 2022. Processing this permit application
offered an opportunity to evaluate the City’s new regulations in practice . Questions,
comments, and concerns raised during the application review process touched on the
following topics:
The impacts of STRs on neighborhood character and how to manage them
The impact of STRs on affordability and availability of housing
The ability for the City to effectively monitor and address nuisances should they
arise after an STR has been permitted
Rates of compliance with STR regulations and how to address existing
unpermitted STRs
Ensuring a fair and consistent process for reviewing and deciding on STR permit
applications
In light of the insights gained by the first CUP application review , staff received direction
from the City Council to study the City’s regulatory approach to STRs.
Policy Objectives
In order to identify opportunities to improve the City’s approach to regulating STRs, it is
helpful to reflect on what outcomes the City hopes to achieve with its regulatory
approach. Developing a clear set of policy objectives helps ensure that the regulatory
approach taken is informed by Hopkins’ unique situation in the STR market, the
community’s priorities, and the City’s capacity to effectively enforce its policies in a
practical and cost-effective manner.
Examples of potential policy objectives that have been articulated by the City Council,
Planning and Zoning Commission, community, and staff thus far include:
Protecting life safety
Minimizing nuisances
Accurately tracking the number and location of STRs operating in the City
Preserving neighborhood character
Protecting affordability and availability of housing
Improving rates of compliance
Enabling reasonable use of private property
Offering options for hospitality
Regulatory Elements
A variety of tools and mechanisms are available to help the City achieve its policy
objectives regarding STRs.
Registration: A requirement for STR operators to register with the City could provide the
City with an effective means of tracking the number and location of STR operators in
the City. This approach could have the effect of creating an approachable means for
STR operators to formalize their operation in the City while providing the City with a
more reliable account of the number and location of STRs. The collection and
availability of this information would help the City track and evaluate the impact of STRs
on an ongoing basis as dynamic trends in the STR market continue to develop .
Licensing: A requirement for STRs to obtain and maintain a special Short-Term Rental
License could allow the City to specify the terms that all STRs must adhere to in order
to operate legitimately in Hopkins, identify a timeframe for license renewal, and
establish grounds for license revocation.
An effective STR licensing program would likely retain some elements of the current
licensing requirements, while omitting elements that are poorly suited or impractical for
STRs. One notable element of the current rental licensing requirements that is poorly
suited for STRs is the requirement for hosts to run criminal background checks on
prospective guests. The terms of the license could also cross -reference the City’s
general nuisance standards related to noise, trash, and parking, and include inspection
requirements if desired.
Inspections: Inspections could offer the City an opportunity to verify that basic life safety
protections are in place for STRs that are permitted to operate in Hopkins. These
protections could include the installation of smoke detectors, carbon monoxide
detectors, and proper egress for sleeping areas. Inspections could be required either as
a one-time requirement prior to finalizing approval of an STR or on a recurring
schedule.
Zoning: The City’s current zoning of STRs identifies the use as permitted, conditional,
or prohibited depending on the zone. For zones in which the use is identified as
permitted, properties are allowed to use their property for STR subject to the
supplemental use regulations and rental licensing requirements. For zones in which
STRs are a conditional use, STR operators are required to appl y for a CUP which
requires an $800 non-refundable application fee and a public hearing at the Planning
and Zoning Commission before a final decision is made by the City Council.
Analysis
A fine-tuned and coordinated mix of these regulatory elements may be better suited to
meet the community’s policy objectives than the CUP application process. The CUP
application review process and public hearing do create an opportunity for the
community to review the proposed use and develop conditions as needed to maintain
public welfare.
However, the scope of the CUP application review process is limited to the particular
merits of an individual application rather than the impact of STRs in the City overall.
Additionally, CUP approval runs with the land and grants CUP holders permission to
use the property for STR so long as the approved conditions are being met, limiting the
ability to revise operating conditions over time according to feedback and changing
trends. Finally, the cost, timeline, and uncertainty associated with the CUP application
process could increase the temptation for STR operators to circumvent the proper
approval process altogether. Given the high proportion of properties in the City where
STR is a conditional use, this would significantly harm rates of compliance and deprive
the City of valuable information needed to effectively monitor STRs and their impacts.
Recommendation
In light of these considerations, staff recommends that the following potential
amendments to the City’s regulation of STRs be considered:
Require STR operators to obtain a license with a two-year renewal period
Require initial inspection to verify adequate life safety protections are in place
Revise zoning to make STRs a permitted use in zones where it isn’t currently
prohibited
Establish appeal process for administrative decisions and license revocation
FUTURE ACTION
Based on input and direction from the City Council, staff will determin e precisely which
ordinance revisions would be needed to implement an y desired changes to the City’s
STR regulations and return to the Council with draft revisions.