Score: +17
(34/44/17)
Orange County Grand Jury
• 2024-2025
Short-Term Rentals
Published: May 14, 2025
22 pages
⚠️ Aviso de traducción: Este contenido ha sido traducido automáticamente. El texto original en inglés es la versión oficial. La traducción puede contener errores.
⚠️ Este contenido ha sido traducido automáticamente. El texto original en inglés es la versión oficial. La traducción puede contener errores.
Findings and Recommendations 12 findings
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
No recommendations for this finding
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
No recommendations for this finding
F3
Even with robust Code Enforcement, a city’s statutory ban on STRs is not enough to keep STRs from operating.
No recommendations for this finding
F4
Anaheim’s ordinance requires OBAs to report Transient Occupancy Tax (TOT) directly to the city. This has led to the favorable consequence that unpermitted STR income is reported to the city.
Related Recommendations (2)
R1
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12)
R3
Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. (F4, F12)
F5
Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances.
No recommendations for this finding
F6
Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices.
Related Recommendations (1)
R8
Cities that allow STRs should consider random multi-year audits to confirm TOT by June 30,2026, and annually thereafter. (F6, F7, F8)
F7
Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff.
Related Recommendations (4)
R4
Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8)
R5
Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8)
R7
Cities that allow STRs should consider allocating resources to update their short-term rental TOT tracking systems by September 30, 2026. (F7, F8, F10)
R8
Cities that allow STRs should consider random multi-year audits to confirm TOT by June 30,2026, and annually thereafter. (F6, F7, F8)
F8
In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties.
Related Recommendations (4)
R4
Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8)
R5
Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8)
R7
Cities that allow STRs should consider allocating resources to update their short-term rental TOT tracking systems by September 30, 2026. (F7, F8, F10)
R8
Cities that allow STRs should consider random multi-year audits to confirm TOT by June 30,2026, and annually thereafter. (F6, F7, F8)
F9
Online Booking Agencies in foreign languages are outside the current capabilities of Code Enforcement to monitor and track unpermitted STRs.
No recommendations for this finding
F10
Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue and contribute to a greater prevalence of unpermitted STRs.
Related Recommendations (2)
R6
Cities with a permit waiting list should implement strategies to remove non-revenue- generating licenses to allow for fair access by December 31, 2025, and annually thereafter. (F7,
R7
Cities that allow STRs should consider allocating resources to update their short-term rental TOT tracking systems by September 30, 2026. (F7, F8, F10)
F11
Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation Orange County is likely to experience with the upcoming 2026 Los Angeles World Cup and 2028 Los Angeles Olympics.
Related Recommendations (1)
R2
Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. (F11)
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Related Recommendations (3)
R1
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12)
R3
Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. (F4, F12)
R9
City leaders should have regular discussions with each other to share STR management strategies on a biannual basis commencing no later than January 1, 2026. (F12) RESPONSES The following excerpts from the California Penal Code provide the requirements for public agencies to respond to the Findings and Recommendations of this Grand Jury report: Penal Code Section 933: (c) No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its reviewing authority, the governing body of the public agency shall comment to the presiding judge of the superior court on the findings and recommendations pertaining to matters under the control of the governing body, and every elected county officer or agency head for which the grand jury has responsibility pursuant to Section 914.1 shall comment to the presiding judge of the superior court, with an information copy sent to the board of supervisors, on the findings and recommendations pertaining to matters under the control of that county officer or agency head and any agency or agencies which that officer or agency head supervises or controls. In any city and county, the mayor shall also comment on the findings and recommendations. All of these comments and reports shall forthwith be submitted to the presiding judge of the superior court who impaneled the grand jury. A copy of all responses to grand jury reports shall be placed on file with the clerk of the public agency and the office of the county clerk, or the mayor when applicable, and shall remain on file in those offices. One copy shall be placed on file with the applicable grand jury final report by, and in the control of the currently impaneled grand jury, where it shall be maintained for a minimum of five years. Penal Code Section 933.05: (a) For purposes of subdivision (b) of Section 933, as to each grand jury finding, the responding person or entity shall indicate one of the following: (1) The respondent agrees with the finding. (2) The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor. (b) For purposes of subdivision (b) of Section 933, as to each grand jury recommendation, the responding person or entity shall report one of the following actions: (1) The recommendation has been implemented, with a summary regarding the implemented action. (2) The recommendation has not yet been implemented, but will be implemented in the future, with a timeframe for implementation. (3) The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a timeframe for the matter to be prepared for discussion by the officer or head of the agency or department being investigated or reviewed, including the governing body of the public agency when applicable. This timeframe shall not exceed six months from the date of publication of the grand jury report. (4) The recommendation will not be implemented because it is not warranted or is not reasonable, with an explanation therefor. (c) However, if a finding or recommendation of the grand jury addresses budgetary or personnel matters of a county agency or department headed by an elected officer, both the agency or department head and the board of supervisors shall respond if requested by the grand jury, but the response of the board of supervisors shall address only those budgetary or personnel matters over which it has some decision-making authority. The response of the elected agency or department head shall address all aspects of the findings or recommendations affecting his or her agency or department. (d) A grand jury may request a subject person or entity to come before the grand jury for the purpose of reading and discussing the findings of the grand jury report that relates to that person or entity in order to verify the accuracy of the findings prior to their release. (e) During an investigation, the grand jury shall meet with the subject of that investigation regarding the investigation, unless the court, either on its own determination or upon request of the foreperson of the grand jury, determines that such a meeting would be detrimental. (f) A grand jury shall provide to the affected agency a copy of the portion of the grand jury report relating to that person or entity two working days prior to its public release and after the approval of the presiding judge. No officer, agency, department, or governing body of a public agency shall disclose any contents of the report prior to the public release of the final report.
Agency Responses 26
Government agencies' official responses to this report's findings and recommendations. Click on a response to see the structured breakdown.
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City of Anaheim 08/12/25
August 12, 2025
•
4 pages
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City of Brea 08/14/25
August 14, 2025
•
3 pages
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City of Buena Park Supplemental Response 09/08/25
September 08, 2025
•
5 pages
• 9 responses
•
Score: 0
(+1, 7, -1)
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9 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Agree
Score: +1
The City of Buena Park agrees with this finding. Although this has not been the experience in Buena Park, there is a strong likelihood athat large events will increase the demand for both hotel and STR bookings.
Page 3 F12 City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve SerVICe. Response: The City of Buena Park disagrees with this finding. The Planning Directors Association of Orange County (PDAOC), which includes Planning and Community Development Directors from throughout the County, meet...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Disagree Partially
Score: 0
The City of Buena Park partially disagrees with this finding. Buena Park originally adopted Ordinance No. 1675 to address resident concerns associated with problematic STRs, but Buena Park has not seen a substantial growth in the number or usage of STRs in the five years since its adoption of Ordinance No. 1675, nor have STRs been a substantial source of public nuisance in the City since. F5 Proactive home inspection of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances. Response: The City of Buena P...
F5
Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances.
Response: Disagree Partially
Score: 0
The City of Buena Park agrees with this finding. Buena Park requires an inspection prior to commencing operation of an STR, an annual inspection for all operating STRs, and an inspection prior to renewal of an STR permit. F6 Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices. 6650 Beach Boulevard I p.o. Box 5009 l Buena Park, CA l 90622-5009 l[714] 562-3610 l Fax [714] 562-3770 I BuenaPark.com
Page 2 Response: The City of Buena Park agrees with this finding. While a comprehensive audit of TOT remittance from STRs has not been conducted, ...
F6
Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices.
Response: Disagree Partially
Score: 0
The City of Buena Park agrees with this finding. While a comprehensive audit of TOT remittance from STRs has not been conducted, Buena Park believes it likely that a portion of the TOT remittance is not being captured as a result of direct bookings. F7 Some cities in Orange County have outdated systems fortracking short-term rental TOT making the process less effective and more difficult for staff. Response: The City of Buena Park partially disagrees with this finding. The City utilizes RentalScape (Deckard) for STR tracking and TOT, which it has found to be both user-friendly and effective fo...
F7
Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff.
Response: Disagree Partially
Score: 0
The City of Buena Park partially disagrees with this finding. The City utilizes RentalScape (Deckard) for STR tracking and TOT, which it has found to be both user-friendly and effective for the City. Prior to use of RentalScape, the City utilized Host Compliance, which was also an effective soffware for tracking STRs. F8 In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties. Response: The City of Buena Park partially disagrees with this finding. As regulated by the Buena Park Municipal Code, any occupancy that e...
F8
In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties.
Response: Disagree Partially
Score: 0
The City of Buena Park partially disagrees with this finding. As regulated by the Buena Park Municipal Code, any occupancy that exceeds 29 days no longer qualifies as a "short-term" rental (or a transient occupancy) and is not subject to TOT. F9 Online Booking Agencies in foreign languages are outside the current capabilities of Code Enforcement to monitor and track unpermitted STRs. Response: The City of Buena Park partially disagrees with this finding. While the RentalScape software tracks over 10,000 STR booking sites, it is possible that there are booking sites, particularly in Foreign lan...
R8
Cities that allow STRs should consider random multi-year audits to confirm TOT by June 30,2026, and annually thereafter. (F6, F7, F8)
Response: Implemented
Score: 0
The City of Buena Park agrees with this finding. The City of Buena Park adopted Ordinance No. 1675 to regulate STRs in 2020. F2 The steady growth of STR usage in the last decade raises concerns of potential public nuisance. Response: The City of Buena Park partially disagrees with this finding. Buena Park originally adopted Ordinance No. 1675 to address resident concerns associated with problematic STRs, but Buena Park has not seen a substantial growth in the number or usage of STRs in the five years since its adoption of Ordinance No. 1675, nor have STRs been a substantial source of public nu...
F9
Online Booking Agencies in foreign languages are outside the current capabilities of Code Enforcement to monitor and track unpermitted STRs.
Response: Disagree Partially
Score: 0
The City of Buena Park partially disagrees with this finding. While the RentalScape software tracks over 10,000 STR booking sites, it is possible that there are booking sites, particularly in Foreign languages, which are not being monitored and could result in unpermitted STRs. FIO Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue and contribute to a greater prevalence of unpermitted STRs. Response: The City of Buena Park agrees with this finding. Buena Park does not have an STR waitlist and instead reviews new STR applications immediately upon receipt, ...
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Disagree
Score: -1
The City of Buena Park disagrees with this finding. The Planning Directors Association of Orange County (PDAOC), which includes Planning and Community Development Directors from throughout the County, meet on a regular basis to discuss issues of countywide concern and share information and strategies for addressing those issues. Additionally, the Municipal Management Association of Southern California (MMASC), which includes City Managers from around the County, meets on a regular basis as well. At a regional level, the League of California Cities meets annually to discuss a broad range of top...
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City of Cypress 07/21/
July 21, 2025
•
2 pages
• 4 responses
•
Score: +3
(+3, 1, 0)
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4 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Agree
Score: +1
The City agrees with the finding.
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Agree
Score: +1
The City agrees with the finding.
F3
Even with robust Code Enforcement, a city’s statutory ban on STRs is not enough to keep STRs from operating.
Response: Agree
Score: +1
The City agrees with the finding.
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Disagree Partially
Score: 0
The City partially agrees with the finding. While there is no formal communication structure dedicated solely to STR among Orange County cities, collaboration does occur. In addition to venues for elected officials like the League of California Cities and The Association of California Cities - Orange County, the county city managers and planning directors operate professional organizations to discuss a range of municipal issues, including STRs.
Recommendations:
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CITY OF DANA POINT
August 14, 2025
•
6 pages
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City of Fullerton 07/20/25
July 20, 2025
•
7 pages
• 11 responses
•
Score: +7
(+7, 4, 0)
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11 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Disagree Partially
Score: 0
The respondent agrees with the finding. Short-term rentals have existed in Orange County for decades, particularly in coastal and tourism-centric areas. While Fullerton is not a coastal city, we recognize the historical context of STRs and their evolving impact on communities. Our proximity to attractions in the region makes STRs desirable within the community. F2. The steady growth of STR usage in the last decade raises concerns of potential public nuisance. Response: The respondent agrees with the finding. 303 West Commonwealth Avenue, Fullerton, California 92832-1775 (714) 738-6311 * counci...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Disagree Partially
Score: 0
The respondent agrees with the finding. 303 West Commonwealth Avenue, Fullerton, California 92832-1775 (714) 738-6311 * [email protected] * www.cityoffullerton.com
The City agrees that the proliferation of STRs has amplified concerns about noise, parking, trash, and neighborhood disruption. These issues contributed to the City Council's adoption of an urgency ordinance for a short-term rental moratorium on July 15, 2028, prohibiting new STR permits and phasing out existing non-compliant ones. F3. Even with robust Code Enforcement, a city's statutory ban on STRs is not enough to keep...
F3
Even with robust Code Enforcement, a city’s statutory ban on STRs is not enough to keep STRs from operating.
Response: Disagree Partially
Score: 0
The respondent agrees with the finding. The City of Fullerton agrees that OBAs and associated entities operate through various methods to post STRs and collect revenue through unregulated or illicit avenues. Furthermore, statutory bans such as the STR moratorium provide a defined set of tools for enforcement, however existing staff case loads and resources do not match this unmet need. F4. Anaheim's ordinance requires OBAs to report Transient Occupancy Tax (TOT) directly to the city. This has led to the favorable result that unpermitted STR income is reported to the city. Response: The respond...
F4
Anaheim’s ordinance requires OBAs to report Transient Occupancy Tax (TOT) directly to the city. This has led to the favorable consequence that unpermitted STR income is reported to the city.
Response: Disagree Partially
Score: 0
The respondent partially agrees with the finding. The City of Fullerton agrees that language within Anaheim's regulations mandates OBAs report all TOT tax to the city which has enhanced reporting. City of Fullerton Ordinance No. 3290 establishes TOT collections and identifies enforcement avenues that include administrative fines, penalties, and citations for hosting platforms. Fullerton recognizes this ordinance can be enhanced to mandate reporting by OBAs. F5. Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcemen...
F5
Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances.
Response: Agree
Score: +1
The respondent agrees with the finding. The City of Fullerton agrees that proactive home inspections of new and renewing rentals can improve code compliance. A significant contributing factor to the City's adoption of the July 15, 2025, moratorium was due to the high volume of unpermitted construction work which has been directly tied to operation of unregulated short-term rentals. F6. Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices. Response: The respondent agrees with the finding. Prior to the moratorium, Fullerton relied on operator...
F6
Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices.
Response: Agree
Score: +1
The respondent agrees with the finding. Prior to the moratorium, Fullerton relied on operator self-reporting for TOT. We acknowledge that direct bookings and non-compliant operators can evade tax collection. The use of advanced web scraper tools can assist in identifying non-compliant listings through less popular OBAs. F7. Some cities in Orange County have outdated systems for tracking short-term rental
TOT making the process less effective and more difficult for staff. Response: The respondent agrees with the finding. Fullerton has relied on advanced web scraping technology to identify rent...
F7
Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff.
Response: Agree
Score: +1
The respondent agrees with the finding. Fullerton has relied on advanced web scraping technology to identify rental amounts, unpermitted postings, and the like. These tools also organize data which can be analyzed further with less extraneous staff time. F8. In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties. Response: The respondent agrees with the finding. Fullerton has encountered several scenarios where operators allege that the STR falls within the definition of a long-term lease but will then swap or fa...
F8
In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties.
Response: Agree
Score: +1
The respondent agrees with the finding. Fullerton has encountered several scenarios where operators allege that the STR falls within the definition of a long-term lease but will then swap or fall into the short-term rental territory when use is under 30 days. Unpermitted operators may swap between rental types to avoid penalties. In addition, some operators have been caught utilizing Accessory Dwelling Units (ADUs) for STR, which violations state ADU laws. In the case of Fullerton, the city has a Regional Housing Needs Assessment (RHNA) number of 13, 209 units, whereby ADUs are counted towards...
F9
Online Booking Agencies in foreign languages are outside the current capabilities of Code Enforcement to monitor and track unpermitted STRs.
Response: Agree
Score: +1
The respondent agrees with the finding. While Fullerton relies on tools to identify postings, these are typically discovered through English language scraping and key terms. The opportunity for alternate language postings to present challenges in enforcement remains. F10. Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue and contribute to a greater prevalence of unpermitted STRs. Response: The respondent agrees with the finding. The City's tools allow for proactive monitoring; however, the tools alone cannot ensure compliance. Existing code enforcement a...
F10
Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue and contribute to a greater prevalence of unpermitted STRs.
Response: Agree
Score: +1
The respondent agrees with the finding. The City's tools allow for proactive monitoring; however, the tools alone cannot ensure compliance. Existing code enforcement and planning staff routinely assess the listed operators to follow up and establish a record of violation. F11. Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation OC is likely to experience with upcoming 2026 LA World Cup and 2028 LA Olympic games. Response: The respondent agrees with the finding. The City's moratorium stops further escalation of unpermitted rental...
F11
Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation Orange County is likely to experience with the upcoming 2026 Los Angeles World Cup and 2028 Los Angeles Olympics.
Response: Agree
Score: +1
The respondent agrees with the finding. The City's moratorium stops further escalation of unpermitted rentals and maintains current level of operation. The City's proximity to the LA area as well as possible venues makes it an ideal location for temporary transient stays which can have outsized impacts.
F412. City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service. Response: The respondent disagrees with the finding. The City's management team frequently attends collaborative discussions as...
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City of Irvine 11/05/25
November 05, 2025
•
5 pages
• 7 responses
•
Score: -1
(+0, 3, -1)
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7 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Disagree Partially
Score: 0
The City of Irvine agrees with this finding. Short-term rentals (STRs) have been a longstanding issue facing jurisdictions across the region, particularly with the rise of online platforms facilitating these types of accommodations. The City of Irvine has proactively addressed this issue by adopting a citywide ban on short-term rentals. This prohibition went into effect in September 2018, following City Council action aimed at preserving the character and stability of residential neighborhoods, ensuring housing availability for longterm residents, and mitigating potential public safety and qua...
R1
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12)
Response: Unknown
Score: 0
The City of Irvine agrees with the intent of this recommendation and notes that the Community Development Department, in collaboration with the City Manager's Office, already engages in regular monitoring of changes to state law, legal precedents, and best practices related to land use and zoning, including those impacting STRs. As part of this process, the City conducts bi-annual technical updates to the Irvine Zoning Ordinance to ensure consistency with applicable laws and to support clear, enforceable local regulations. In alignment with the Grand Jury's recommendation, the City will place ...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Disagree Partially
Score: 0
The City of Irvine agrees with this finding. This observation is consistent with the experiences and concerns voiced by many Irvine
residents, particularly in our residential neighborhoods. Prior to the City's adoption of its STR ban in 2018, Irvine residents frequently expressed concerns about the negative impacts of STRs in the community. These concerns included increased noise, traffic, and parking congestion, as well as the disruption of neighborhood cohesion caused by a steady turnover of unfamiliar visitors. In some cases, the presence of STRs led to serious quality-of-life impacts, wer...
R2
Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. (F11)
Response: Unknown
Score: 0
The City of Irvine acknowledges and agrees with the importance of proactive planning in advance of large-scale events that may increase regional demand for short-term accommodations, including STRs. While the City has maintained a citywide ban on STRs since September 2018, Irvine recognizes that upcoming events- particularly the 2028 Summer Olympics in Los Angeles-may present unique circumstances that warrant a thoughtful review of the City's current policy. As part of the City's broader policy planning process, the City Council will take into consideration an approach to the treatment of STRs...
F3
Even with robust Code Enforcement, a city’s statutory ban on STRs is not enough to keep STRs from operating.
Response: Disagree Partially
Score: 0
The City of Irvine disagrees partially with this finding based on our experience since the implementation of our STR ban. In 2018, the City of Irvine enacted a comprehensive ban on STRs in response to significant community concerns related to neighborhood disruption, public safety, and housing availability. Since that time, the City has implemented a strong and proactive code enforcement strategy to ensure compliance with the ban. Irvine's Code Enforcement team has been highly effective in addressing violations. Through a combination of community reporting, technology-based monitoring, and tar...
R9
City leaders should have regular discussions with each other to share STR management strategies on a biannual basis commencing no later than January 1, 2026. (F12) RESPONSES The following excerpts from the California Penal Code provide the requirements for public agencies to respond to the Findings and Recommendations of this Grand Jury report: Penal Code Section 933: (c) No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its revie...
Response: Unknown
Score: 0
The City of Irvine agrees with this recommendation and supports increased regional collaboration to address the shared challenges and evolving legal landscape surrounding STRs. While cities may take different approaches to STR regulation based on local needs and policy objectives, regular communication among city leaders offers a valuable opportunity to exchange best practices, enforcement strategies, and legal insights. The City welcomes the opportunity to participate in biannual discussions with other Orange County jurisdictions and would support the establishment of a coordinated forum or w...
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Disagree
Score: -1
The City of Irvine respectfully disagrees with this finding as it pertains to our internal operations. Within the City of Irvine, interdepartmental coordination is a key strength of our approach to STR enforcement. The Community Development and Public Safety departments, in particular, maintain regular and ongoing communication to address
STR-related issues. This collaboration includes sharing information on complaints, coordinating investigations and enforcement actions, and evaluating policy or procedural updates to strengthen our response. This cross-departmental teamwork has been essentia...
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City of Laguna Beach 09/23/25
September 23, 2025
•
6 pages
• 12 responses
•
Score: 0
(+0, 11, 0)
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12 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. STRs have long existed and Laguna Beach has had regulations in place since 1999. F2: The steady growth of STR usage in the last decade raises concerns of potential public nuisance. Response: The City of Laguna Beach agrees with the finding. The City has strengthened its regulatory framework through recent Municipal Code updates, including the proposed addition of Chapter 5.84, which establishes a comprehensive compliance system. This framework includes nuisance response plans, proactive monitoring, technology integration, and coordinated enforc...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. The City has strengthened its regulatory framework through recent Municipal Code updates, including the proposed addition of Chapter 5.84, which establishes a comprehensive compliance system. This framework includes nuisance response plans, proactive monitoring, technology integration, and coordinated enforcement efforts among Community Development, Code Enforcement, and the Police Department to minimize potential nuisances. F5: Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improv...
F5
Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. Inspections are required under Laguna Beach's permitting process, and the new licensing ordinance will enhance this
Page 2 further. F6: Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices. Response: The City of Laguna Beach agrees with the finding. The new ordinance includes enhanced reporting and audit provisions to help address gaps in TOT collection. F7: Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more diffi...
R5
Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8)
Response: Implemented
Score: 0
The City of Laguna Beach agrees with the finding. Inspections are required under Laguna Beach's permitting process, and the new licensing ordinance will enhance this
Page 2 further. F6: Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices. Response: The City of Laguna Beach agrees with the finding. The new ordinance includes enhanced reporting and audit provisions to help address gaps in TOT collection. F7: Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more diffi...
F6
Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. The new ordinance includes enhanced reporting and audit provisions to help address gaps in TOT collection. F7: Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff. Response: The City of Laguna Beach agrees with the finding. The City recognizes the need to improve financial oversight and has adopted a new ordinance (proposed Chapter 5.84) that requires short-term lodging unit operators to obtain a Short-Term Lodging Unit Certificate. This certificate...
F7
Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. The City recognizes the need to improve financial oversight and has adopted a new ordinance (proposed Chapter 5.84) that requires short-term lodging unit operators to obtain a Short-Term Lodging Unit Certificate. This certificate enhances the City's ability to track rental activity, verify compliance with Transient Occupancy Tax (TOT) and Tourism Marketing District (TMD) assessments, and enforce reporting obligations more effectively. System improvements are planned as part of the licensing implementation. F8: In some cases, STRs are improperly...
F8
In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. To improve compliance, the City has partnered with Granicus Host Compliance, a third-party monitoring service that tracks online short-term rental listings in real time. The system captures listing metadata, screenshots, and advertisement changes over time, helping to identify rentals that are misrepresented as longterm stays but are operated as short-term rentals. This evidence enables Code Enforcement to take appropriate enforcement actions under the City's Municipal Code. F9: Online Booking Agencies in foreign languages are outside the curre...
F9
Online Booking Agencies in foreign languages are outside the current capabilities of Code Enforcement to monitor and track unpermitted STRs.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. Monitoring foreign-language listings presents challenges; however, the City's partnership with Granicus Host Compliance enhances multilingual monitoring across major STR platforms. Staff continues to explore additional tools to support enforcement. F10: Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue and contribute to a greater prevalence of unpermitted STRs. Response: The City of Laguna Beach agrees with the finding. Under the new Short-Term Lodging ordinance (Chapter 5.84), licenses for short-term lod...
R9
City leaders should have regular discussions with each other to share STR management strategies on a biannual basis commencing no later than January 1, 2026. (F12) RESPONSES The following excerpts from the California Penal Code provide the requirements for public agencies to respond to the Findings and Recommendations of this Grand Jury report: Penal Code Section 933: (c) No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its revie...
Response: Unknown
Score: 0
This recommendation will be evaluated. The City conducts annual audits of STR operators for TOT compliance and will consider expanding the audit scope as resources allow. Respectfully, Alex Rounaghi A lex Rounaghi (Sep 24, 2025 10:42:28 PDT) Alex Rounaghi Mayor City of Laguna Beach cc: Orange County Grand Jury 700 Civic Center West Santa Ana, CA 92701
9.23.25 - Grand Jury Response - Short Term Lodging Final Audit Report 2025-09-24 Created: 2025-09-24 By: Becket Wilson ([email protected]) Status: Signed Transaction ID: CBJCHBCAABAAgoaWQuboxnbxOmgzzZZ_bYfsWxoEwKLt "9.23.25 - Grand Jur...
F10
Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue and contribute to a greater prevalence of unpermitted STRs.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. Under the new Short-Term Lodging ordinance (Chapter 5.84), licenses for short-term lodging units do not renew automatically, and revoked licenses carry a minimum three-year waiting period before reapplication. These provisions help ensure that only active, compliant operators maintain
Page 3 licensing privileges, thereby helping reduce potential revenue loss associated with inactive or underused licenses. F11: Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation Orange County is ...
F11
Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation Orange County is likely to experience with the upcoming 2026 Los Angeles World Cup and 2028 Los Angeles Olympics.
Response: Disagree Partially
Score: 0
The City of Laguna Beach agrees with the finding. F12: City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service. Response: The City of Laguna Beach partially agrees with the finding. While there is no formal regional STR coordination body, City staff regularly engages with counterparts in neighboring jurisdictions to share best practices, enforcement strategies, and policy updates. The City supports increased collaboration and is open to participating in broader regional efforts to address ST...
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Disagree Partially
Score: 0
The City of Laguna Beach partially agrees with the finding. While there is no formal regional STR coordination body, City staff regularly engages with counterparts in neighboring jurisdictions to share best practices, enforcement strategies, and policy updates. The City supports increased collaboration and is open to participating in broader regional efforts to address STR issues. Recommendations: R1. Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently tha...
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City of La Habra 08/04/25
August 04, 2025
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3 pages
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City of Lake Forest Supplemental Response 09/08/25
September 08, 2025
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City of La Palma 08/05/25
August 05, 2025
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City of Los Alamitos 07/22/25
July 22, 2025
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3 pages
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City of Orange 11/25/25
November 25, 2025
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3 pages
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City of San Clemente 08/07/25
August 07, 2025
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4 pages
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City of San Juan Capistrano 08/15/25
August 15, 2025
•
4 pages
• 18 responses
•
Score: -1
(+8, 1, -9)
View Details ▾
18 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Agree
Score: +1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County. The City of San Juan Capistrano agrees with this finding.
R1
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12)
Response: Will Not Implement
Score: -1
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. This recommendation has already been implemented, as the City is continually reviewing its ordinances in response to new legislation, case law and market trends. The City of San Juan Capistrano is committed to complying with all applicable state laws and court rulings related to STRs. The City will continue to monitor legislative developments and court decisions and will...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Agree
Score: +1
The steady growth of STR usage in the last decade raises concerns of potential public nuisance. The City of San Juan Capistrano agrees with this finding.
Page 2 of 4 Proactive home inspections of new and renewing STRs, which have been implemented in
R2
Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. (F11)
Response: Will Not Implement
Score: -1
Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated TOT, by December 31, 2025, and no less frequently than every two years thereafter. This recommendation has already been implemented, as City staff is actively engaged in conversation with neighboring agencies regarding potential event and training venues associated with the Olympics as well as opportunities to accommodate visitors who come to the region and require lodging.
R3
Cities that allow STRs should evaluate the benefit of ordinances facilitating...
R3
Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. (F4, F12)
Response: Will Not Implement
Score: -1
Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. Given the very limited amount of STR activity in the city, this recommendation will not be implemented, as it is not warranted.
R4
Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8)
Response: Will Not Implement
Score: -1
Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. Given the very limited amount of STR activity in the city, this recommendation will not be implemented, as it is not warranted. Should the City see an increase in STRs, staff would evaluate options for collecting TOT.
Page 4 of 4 Cities should require STRs to include the number of days rented per month per permit to
F5
Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances.
Response: Agree
Score: +1
some Orange County cities, improve code enforcement and STR compliance with city ordinances. Based on the information provided in the report, the City of San Juan Capistrano agrees that proactive inspections of new and renewing STRs improve compliance with city ordinances. However, the City has not implemented this policy since there have been no new or renewing STRs within San Juan Capistrano. The City has not independently verified what practices other cities in Orange County have implemented. Direct remittance of taxes by OBAs does not capture all TOT for an STR because of
R5
Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8)
Response: Will Not Implement
Score: -1
facilitate short-term rental TOT desk audits by November 30, 2025. Given the very limited amount of STR activity in the city, this recommendation will not be implemented, as it is not warranted. Should the City see an increase in STRs, staff would explore auditing the TOT process. Cities with a permit waiting list should implement strategies to remove non-revenue-
R6
generating licenses to allow for fair access by December 31, 2025, and annually thereafter. Given the very limited amount of STR activity in the City, this recommendation will not be implemented, as it is not warranted. There is...
F6
Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices.
Response: Agree
Score: +1
direct booking practices. The City of San Juan Capistrano acknowledges that Transient Occupancy Tax (TOT) remitted directly by Online Booking Agencies (OBAs) may not capture all STR-related tax revenue due to direct booking practices that bypass these platforms. At this time, the City has not implemented mechanisms to track or verify TOT from direct bookings, since there has been very limited STR activity within the city. Some cities in Orange County have outdated systems for tracking short-term rental TOT
R6
Cities with a permit waiting list should implement strategies to remove non-revenue- generating licenses to allow for fair access by December 31, 2025, and annually thereafter. (F7,
Response: Will Not Implement
Score: -1
generating licenses to allow for fair access by December 31, 2025, and annually thereafter. Given the very limited amount of STR activity in the City, this recommendation will not be implemented, as it is not warranted. There is no permit waiting list. Cities that allow STRs should consider allocating resources to update their short-term
R7
rental TOT tracking systems by September 30,2026. Given the very limited amount of STR activity in the city, this recommendation will not be implemented, as it is not warranted. Should the City see an increase in STRs, staff would evaluate options for TOT...
F7
Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff.
Response: Agree
Score: +1
making the process less effective and more difficult for staff. Based on the information provided in the report, the City of San Juan Capistrano agrees that updating systems for tracking STRs and transient occupancy tax (TOT) would improve the efficiency of the process and make it easier for staff to manage. However, the City has not independently verified the systems used by other cities in Orange County and has not yet implemented any system for STR and TOT tracking since there has been very limited STR activity within the city. In some cases, STRs are improperly recharacterized as long-term...
R7
Cities that allow STRs should consider allocating resources to update their short-term rental TOT tracking systems by September 30, 2026. (F7, F8, F10)
Response: Will Not Implement
Score: -1
rental TOT tracking systems by September 30,2026. Given the very limited amount of STR activity in the city, this recommendation will not be implemented, as it is not warranted. Should the City see an increase in STRs, staff would evaluate options for TOT tracking. Cities that allow STRs should consider random multi-year audits to confirm TOT by June
R8
30, 2026, and annually thereafter. Given the very limited amount of STR activity in the city, this recommendation will not be implemented, as it is not warranted. Should the City see an increase in STRs, staff would explore TOT auditing optio...
F8
In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties.
Response: Agree
Score: +1
the collection of TOT and any applicable penalties. The City of San Juan Capistrano agrees that, in some cases, STRs may be improperly recharacterized as long-term rentals in an effort to circumvent the collection of TOT and any applicable penalties. Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue
R8
Cities that allow STRs should consider random multi-year audits to confirm TOT by June 30,2026, and annually thereafter. (F6, F7, F8)
Response: Will Not Implement
Score: -1
30, 2026, and annually thereafter. Given the very limited amount of STR activity in the city, this recommendation will not be implemented, as it is not warranted. Should the City see an increase in STRs, staff would explore TOT auditing options. City leaders should have regular discussions with each other to share STR management
R9
strategies on a biannual basis commencing no later than January 1, 2026. This recommendation has been implemented. Elected officials and City staff regularly communicate with each other on a variety of policy issues to discuss best practices and share information....
R9
City leaders should have regular discussions with each other to share STR management strategies on a biannual basis commencing no later than January 1, 2026. (F12) RESPONSES The following excerpts from the California Penal Code provide the requirements for public agencies to respond to the Findings and Recommendations of this Grand Jury report: Penal Code Section 933: (c) No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its revie...
Response: Implemented
Score: 0
strategies on a biannual basis commencing no later than January 1, 2026. This recommendation has been implemented. Elected officials and City staff regularly communicate with each other on a variety of policy issues to discuss best practices and share information. This includes discussion of issues involving STRs. Thank you for the opportunity to respond to the Grand Jury report. If you have any questions, please feel free to contact me at (949) 443-6314. Sincerely, _ _ Benjamin Siegel City Manager Orange County Grand Jury, 700 Civic Center Drive West, Santa Ana, CA 92701 cc: San Juan Capistra...
F10
Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue and contribute to a greater prevalence of unpermitted STRs.
Response: Agree
Score: +1
and contribute to a greater prevalence of unpermitted STRs The City of San Juan Capistrano acknowledges the importance of effectively managing STRs to ensure compliance and capture potential revenue. However, the City does not maintain a waiting list for STR permits because there has been very limited STR activity within the city.
Page 3 of 4
F11
Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation Orange County is likely to experience with the upcoming 2026 Los Angeles World Cup and 2028 Los Angeles Olympics.
Response: Agree
Score: +1
Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation Orange County is likely to experience with the upcoming 2026 Los Angeles World Cup and 2028 Los Angeles Olympics. The City of San Juan Capistrano agrees that large international events increase demand for STRs in the area where the events occur.
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Disagree
Score: -1
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service. The City of San Juan Capistrano disagrees with this finding. Elected officials and staff from agencies throughout the county regularly engage in communication with each other on a variety of topics, including issues related to STRs. RECOMMENDATIONS
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City of Santa Ana 12/02/25
December 02, 2025
•
35 pages
• 2 responses
•
Score: +1
(+1, 1, 0)
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2 responses to findings and recommendations
R3
Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. (F4, F12)
Response: Implemented
Due: June 30, 2026
Scheduled: within 60 days
Score: 0
: Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. (F4, F12) R4: Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8) R5: Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8) R6: Cities with a permit waiting list should implement strategies to remove non-revenuegenerating licenses to ...
F5
Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances.
Response: Agree
Score: +1
: Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances. F6: Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices. F7: Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff. F8: In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties. F9: Online Bo...
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City of Seal Beach
August 14, 2025
•
4 pages
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City of Stanton 08/13/25
August 13, 2025
•
2 pages
• 7 responses
•
Score: +2
(+4, 1, -2)
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7 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Agree
Score: +1
new phenomenon in Orange County. The respondent agrees with the finding. The steady growth of STR usage in the last decade raises concerns of potential public
R1
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12)
Response: Will Not Implement
Score: -1
nature of court findings and legislation related to STRs, by December 31, 2025, and no less Presiding Judge of the frequently than every three years thereafter. <b>Superior Court</b> 700 Civic Center Drive West The recommendation will not be implemented because it is not warranted or is not Santa Ana, CA 92701 reasonable, with an explanation therefor. The City does not permit STRs. Cities should consider developing a plan for upcoming major events that are expected to
R2
create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Agree
Score: +1
nuisance. The respondent agrees with the finding. Even with robust Code Enforcement, a city's statutory ban on STRs is not enough to keep
R2
Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. (F11)
Response: Will Not Implement
Score: -1
create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. The recommendation will not be implemented because it is not warranted or is not reasonable, with an explanation therefor The City does not permit STRs. City leaders should have regular discussions with each other to share STR management
R9
strategies on a biannual basis commencing no later than January 1, 2026. The recommendation will be implemented. City staff will continue to attend and participate in those professional associations an...
F3
Even with robust Code Enforcement, a city’s statutory ban on STRs is not enough to keep STRs from operating.
Response: Agree
Score: +1
STRs from operating. The respondent agrees with the finding. Despite the City's ban on STRs, Code Enforcement regularly receives complaints regarding STRs. The frequency of the complaints rose to such a level in prior years that the City recently procured access to a data platform that monitors STRs and supports timely, appropriate enforcement. City leaders have no regular communication with each other concerning STR issues, limiting
R9
City leaders should have regular discussions with each other to share STR management strategies on a biannual basis commencing no later than January 1, 2026. (F12) RESPONSES The following excerpts from the California Penal Code provide the requirements for public agencies to respond to the Findings and Recommendations of this Grand Jury report: Penal Code Section 933: (c) No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its revie...
Response: Will Implement
Score: +1
strategies on a biannual basis commencing no later than January 1, 2026. The recommendation will be implemented. City staff will continue to attend and participate in those professional associations and events where issues such as STRs are addressed. Should you have any questions or need any additional information, please contact Hannah Shin- Heydorn, City Manager, at (714) 890-4277 or via email at <a href="https://example.com/[email protected]">[email protected]</a>. Respectfully, Newyl Slawus David J. Shawyer Mayor Cc:
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Disagree Partially
Score: 0
opportunities to develop strategies and expertise to improve service. The respondent agrees partially with the finding. While there is no formal regular communication medium dedicated solely to STR-related issues among City leaders in Orange County, communication and collaboration does occur. In addition to mediums for elected officials such as the League of California Cities and the Association of California Cities - Orange County, city managers and planning directors participate in various professional organizations in which a range of municipal issues are discussed, including STRs. Communit...
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City of Villa Park 07/22/25
July 22, 2025
•
2 pages
• 7 responses
•
Score: +4
(+4, 1, 0)
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7 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Agree
Score: +1
The City agrees with the finding based on the information provided by the Grand Jury Report. However, the City does not have the resources or staffing to independently verify the findings. Finding F2: The Steady growth of STR usage in the last decade raises concerns of potential public nuisance. City Response: The City agrees with the finding based on the information provided by the Grand Jury Report. However, the City does not have the resources or staffing to independently verify the findings. Finding F3: Even with robust Code Enforcement, a city's statutory ban on STRs is not enough to keep...
R1
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12)
Response: Implemented
Score: 0
The recommendation has been implemented. The city reviews these ordinances regarding STRs every year. Recommendation R2: Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. City Response: The recommendation has not been implemented. The City enforces an STR ban. However, the City will support the effort of others. Recommendation R9: City leaders should have regular discussions with each other to share STR...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Agree
Score: +1
The City agrees with the finding based on the information provided by the Grand Jury Report. However, the City does not have the resources or staffing to independently verify the findings. Finding F3: Even with robust Code Enforcement, a city's statutory ban on STRs is not enough to keep STRs from opening. City Response: The City agrees with the finding based on the information provided by the Grand Jury Report. However, the City does not have the resources or staffing to independently verify the findings. Finding F12: City leaders have no regular communication with each other concerning STR i...
R2
Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. (F11)
Response: Unknown
Score: 0
The recommendation has not been implemented. The City enforces an STR ban. However, the City will support the effort of others. Recommendation R9: City leaders should have regular discussions with each other to share STR management strategies on biannual basis commencing no later than January 1, 2026. City Response: The recommendation has not yet been implemented. The City has had limited discussion surrounding STRs at ACC-OC and the League of Cities. However, this has been infrequent. The City is willing to participate as appropriate. Sincerely, THE CITY OF VILLA PARK Mayor
F3
Even with robust Code Enforcement, a city’s statutory ban on STRs is not enough to keep STRs from operating.
Response: Agree
Score: +1
The City agrees with the finding based on the information provided by the Grand Jury Report. However, the City does not have the resources or staffing to independently verify the findings. Finding F12: City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service. City Response: The City agrees with the finding based on the information provided by the Grand Jury Report. However, the City does not have the resources or staffing to independently verify the findings. NICOL JONES, Mayor * JORDAN WU, M...
R9
City leaders should have regular discussions with each other to share STR management strategies on a biannual basis commencing no later than January 1, 2026. (F12) RESPONSES The following excerpts from the California Penal Code provide the requirements for public agencies to respond to the Findings and Recommendations of this Grand Jury report: Penal Code Section 933: (c) No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its revie...
Response: Unknown
Score: 0
The recommendation has not yet been implemented. The City has had limited discussion surrounding STRs at ACC-OC and the League of Cities. However, this has been infrequent. The City is willing to participate as appropriate. Sincerely, THE CITY OF VILLA PARK Mayor
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Agree
Score: +1
The City agrees with the finding based on the information provided by the Grand Jury Report. However, the City does not have the resources or staffing to independently verify the findings. NICOL JONES, Mayor * JORDAN WU, Mayor Pro Tem ROBERT FRACKELTON, Councilmember * KELLY MCBRIDE, Councilmember * CRYSTAL MILES, Councilmember 17855 Santiago Boulevard, Villa Park, California 92861-4187 www.villapark.org
Recommendation R1: Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and...
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CITY of YORBA LINDA
August 05, 2025
•
2 pages
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City of Mission Viejo 08/18/25
August 18, 2025
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4 pages
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City of Costa Mesa 08/05/25
August 05, 2025
•
3 pages
• 3 responses
•
Score: +2
(+2, 0, 0)
View Details ▾
3 responses to findings and recommendations
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Agree
Score: +1
The City agrees. As stated in the City Council resolution adopting the interim MAYOR COUNCIL MEMBER | COUNCIL MEMBER | COUNCIL MEMBER | MAYOR PRO TEM | COUNCIL MEMBER | COUNCIL MEMBER John Stephens Mike Buley Loren Gameros Andrea Marr Manuel Chavez Arlis Reynolds Jeff Pettis District District 2 Distrit 3 District 4 District § District 6
The Honorable Maria Hernandez August 5, 2025 Page 2
F3.
Please Ri. ordinance on STRs, "the City has also begun experiencing an increase in the number of complaints related to these operations, which complains have included noise, vandalism, gun-related incid...
R2
Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. (F11)
Response: Unknown
Score: 0
The City agrees. Issues related to STRs date back to before the COVID-19 pandemic when cities reacted to complaints focused on curfew and noise violations in residential neighborhoods. In 2020, federal and state pandemic restrictions on travel and social gatherings led to a growth in STRs as an alternative to restrictions enforced at hotels or other public spaces. That same year Costa Mesa adopted its interim urgency ordinance in response to increasing complaints over noise, vandalism, gun-related incidents, parking violations and disturbing the peace violations connected to STRs. F2. The stea...
F3
Even with robust Code Enforcement, a city’s statutory ban on STRs is not enough to keep STRs from operating.
Response: Agree
Score: +1
The City agrees. Robust code enforcement cannot achieve 100% compliance or prevention on issues of public nuisance. The City relies on multiple strategies to educate the public and provide quality alternatives for accommodations or hosting events besides seeking out a shortterm rental. This includes promoting hotels and other spaces that can meet the various needs of conferences, business travelers, or family vacations. This is promoted through our travel and visitor partners at Travel Costa Mesa (https://www.travelcostamesa.com), Additionally, local economic development groups such as the Sou...
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City of Newport Beach 07/23/25
July 23, 2025
•
7 pages
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City of Buena Park 07/22/25
July 22, 2025
•
5 pages
• 15 responses
•
Score: -1
(+0, 14, -1)
View Details ▾
15 responses to findings and recommendations
R1
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12)
Response: Implemented
Score: 0
R3
Response: Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12) The City of Buena Park has already implemented this recommendation. The City of Buena Park has adopted an ordinance regulating STRs, monitors state legislation and court rulings, and updates its Municipal Code as necessary to stay up-to-date on STR legislation. Cities should consider developing a plan for upcoming major events that are expected to...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Disagree Partially
Score: 0
The City of Buena Park partially disagrees with this finding. Buena Park originally adopted Ordinance No. 1675 to address resident concerns associated with problematic STRs, but Buena Park has not seen a substantial growth in the number or usage of STRs in the five years since its adoption of Ordinance No. 1675, nor have STRs been a substantial source of public nuisance in the City since. F5 Proactive home inspection of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances. Response: The City of Buena P...
R2
Cities should consider developing a plan for upcoming major events that are expected to create a surge in demand for STRs and its associated Transient Occupancy Tax, by December 31, 2025, and no less frequently than every two years thereafter. (F11)
Response: Implemented
Score: 0
Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12) The City of Buena Park has already implemented this recommendation. The City of Buena Park has adopted an ordinance regulating STRs, monitors state legislation and court rulings, and updates its Municipal Code as necessary to stay up-to-date on STR legislation. Cities should consider developing a plan for upcoming major events that are expected to create a surg...
R3
Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. (F4, F12)
Response: Implemented
Score: 0
Response: Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12) The City of Buena Park has already implemented this recommendation. The City of Buena Park has adopted an ordinance regulating STRs, monitors state legislation and court rulings, and updates its Municipal Code as necessary to stay up-to-date on STR legislation. Cities should consider developing a plan for upcoming major events that are expected to cre...
R4
Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8)
Response: Implemented
Score: 0
R6
Response:
R7
Response:
R8
Response: RQ Response: Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8) This recommendation has been implemented. The City of Buena Park requires hotels and STRs to remit TOT on a monthly basis. Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8) The recommendation requires further analysis. The City of Buena Park recognizes the benefits of this recommendation a...
F5
Proactive home inspections of new and renewing STRs, which have been implemented in some Orange County cities, improve code enforcement and STR compliance with city ordinances.
Response: Disagree Partially
Score: 0
The City of Buena Park agrees with this finding. Buena Park requires an inspection prior to commencing operation of an STR, an annual inspection for all operating STRs, and an inspection prior to renewal of an STR permit. F6 Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices. 6650 Beach Boulevard | P.O. Box 5009 | Buena Park, CA | 90622-5009 | [714] 562-3610 | Fax [714] 562-3770 | BuenaPark.com
Page 2 Response:
F7
Response:
F8
Response: FQ Response:
F10
Response:
F141
Response: The City of Buena Park agrees with this finding. Whi...
R5
Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8)
Response: Implemented
Score: 0
R7
Response:
R8
Response: RQ Response: Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8) This recommendation has been implemented. The City of Buena Park requires hotels and STRs to remit TOT on a monthly basis. Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8) The recommendation requires further analysis. The City of Buena Park recognizes the benefits of this recommendation and will evaluat...
F6
Direct remittance of taxes by OBAs does not capture all TOT for an STR because of direct booking practices.
Response: Disagree Partially
Score: 0
F7
Response:
F8
Response: FQ Response:
F10
Response:
F141
Response: The City of Buena Park agrees with this finding. While a comprehensive audit of TOT remittance from STRs has not been conducted, Buena Park believes it likely that a portion of the TOT remittance is not being captured as a result of direct bookings. Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff. The City of Buena Park partially disagrees with this finding. The City utilizes RentalScape (Deckard) for STR tracking and TO...
R6
Cities with a permit waiting list should implement strategies to remove non-revenue- generating licenses to allow for fair access by December 31, 2025, and annually thereafter. (F7,
Response: Implemented
Score: 0
R8
Response: RQ Response: Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8) This recommendation has been implemented. The City of Buena Park requires hotels and STRs to remit TOT on a monthly basis. Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8) The recommendation requires further analysis. The City of Buena Park recognizes the benefits of this recommendation and will evaluate the potential...
F7
Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff.
Response: Disagree Partially
Score: 0
FQ Response:
F10
Response:
F141
Response: The City of Buena Park agrees with this finding. While a comprehensive audit of TOT remittance from STRs has not been conducted, Buena Park believes it likely that a portion of the TOT remittance is not being captured as a result of direct bookings. Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff. The City of Buena Park partially disagrees with this finding. The City utilizes RentalScape (Deckard) for STR tracking and TOT, which it has found to be b...
R7
Cities that allow STRs should consider allocating resources to update their short-term rental TOT tracking systems by September 30, 2026. (F7, F8, F10)
Response: Implemented
Score: 0
RQ Response: Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8) This recommendation has been implemented. The City of Buena Park requires hotels and STRs to remit TOT on a monthly basis. Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8) The recommendation requires further analysis. The City of Buena Park recognizes the benefits of this recommendation and will evaluate the potential to amend its ...
F8
In some cases, STRs are improperly recharacterized as long-term rentals to circumvent the collection of TOT and any applicable penalties.
Response: Disagree Partially
Score: 0
F10
Response:
F141
Response: The City of Buena Park agrees with this finding. While a comprehensive audit of TOT remittance from STRs has not been conducted, Buena Park believes it likely that a portion of the TOT remittance is not being captured as a result of direct bookings. Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff. The City of Buena Park partially disagrees with this finding. The City utilizes RentalScape (Deckard) for STR tracking and TOT, which it has found to be both user-frien...
R8
Cities that allow STRs should consider random multi-year audits to confirm TOT by June 30,2026, and annually thereafter. (F6, F7, F8)
Response: Implemented
Score: 0
Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8) This recommendation has been implemented. The City of Buena Park requires hotels and STRs to remit TOT on a monthly basis. Cities should require STRs to include the number of days rented per month per permit to facilitate short-term rental TOT desk audits by November 30, 2025. (F7, F8) The recommendation requires further analysis. The City of Buena Park recognizes the benefits of this recommendation and will evaluate the potential to amend its Municipal Cod...
F10
Cities that fail to routinely review their STR waiting lists potentially lose TOT revenue and contribute to a greater prevalence of unpermitted STRs.
Response: Disagree Partially
Score: 0
The City of Buena Park agrees with this finding. While a comprehensive audit of TOT remittance from STRs has not been conducted, Buena Park believes it likely that a portion of the TOT remittance is not being captured as a result of direct bookings. Some cities in Orange County have outdated systems for tracking short-term rental TOT making the process less effective and more difficult for staff. The City of Buena Park partially disagrees with this finding. The City utilizes RentalScape (Deckard) for STR tracking and TOT, which it has found to be both user-friendly and effective for the City. ...
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Disagree
Score: -1
Response: City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service. The City of Buena Park disagrees with this finding. The Planning Directors Association of Orange County (PDAOC), which includes Planning and Community Development Directors from throughout the County, meet on a regular basis to discuss issues of countywide concern and share information and strategies for addressing those issues. Additionally, the Municipal Management Association of Southern California (MMASC), which includes ...
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City of Lake Forest 07/17/25
July 17, 2025
•
6 pages
• 3 responses
•
Score: -3
(+0, 0, -3)
View Details ▾
3 responses to findings and recommendations
R3
Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. (F4, F12)
Response: Will Not Implement
Score: -1
: Cities that allow STRs should evaluate the benefit of ordinances facilitating Voluntary Collection Agreements requiring OBAs to submit TOT directly, by June 30, 2026. (F4, F12). The recommendations will not be implemented because they are not warranted or they are not reasonable, with an explanation, thereof. The City does not allow STRs, only limited home rentals and no TOT is collected. Therefore, this does not apply. R4: Cities that allow STRs should evaluate the benefit of collecting TOT on a monthly basis by individual property, by June 30, 2026. (F7, F8). The recommendations will not b...
R8
Cities that allow STRs should consider random multi-year audits to confirm TOT by June 30,2026, and annually thereafter. (F6, F7, F8)
Response: Will Not Implement
Score: -1
: Cities that allow STRs should consider random multi-year audits to confirm TOT by June 30, 2026, and annually thereafter. (F6, F7, F8). The recommendations will not be implemented because they are not warranted or they are not reasonable, with an explanation, thereof. The City does not allow STRs, only limited home rentals and no TOT is collected. Therefore, this does not apply. R9: City leaders should have regular discussions with each other to share STR management strategies on a biannual basis commencing no later than January 1, 2026. (F12). The recommendation will be implemented. City st...
F11
Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation Orange County is likely to experience with the upcoming 2026 Los Angeles World Cup and 2028 Los Angeles Olympics.
Response: Disagree
Score: -1
: Locations that have hosted major events have reported an outsized increase in demand and pricing of STRs, a situation Orange County is likely to experience with the upcoming 2026 Los Angeles World Cup and 2028 Los Angeles Olympics. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons thereof. The City lacks knowledge and information sufficient to reach this conclusion. The City does not allow STRs. Code Enforcement responds to STR complaints and, in r...
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City of Laguna Woods 07/16/25
July 16, 2025
•
3 pages
• 4 responses
•
Score: +4
(+4, 0, 0)
View Details ▾
4 responses to findings and recommendations
F1
Despite the increasing media coverage of Online Booking Agencies (OBAs), STRs are not a new phenomenon in Orange County.
Response: Agree
Score: +1
The City of Laguna Woods agrees with this finding. While the City of Laguna Woods has had limited experience with short-term rentals operating in Laguna Woods, based on our understanding of the subject and experience in other cities, we agree that short-term rentals are not a new phenomenon in Orange County. F2. The steady growth of STR usage in the last decade raises concerns of potential public nuisance. Response: The City of Laguna Woods agrees with this finding. While the City of Laguna Woods has had limited experience with short-term rentals operating in Laguna Woods, based on our underst...
F2
The steady growth of STR usage in the last decade raises concerns of potential public nuisance.
Response: Agree
Score: +1
The City of Laguna Woods agrees with this finding. While the City of Laguna Woods has had limited experience with short-term rentals operating in Laguna Woods, based on our understanding of the subject and experience in other cities, we agree that the steady growth of short-term rental usage in the last decade raises concerns of potential public nuisance. While some operators are undoubtedly conscientious and comply with local regulations, that experience does not appear to be universal. F3. Even with robust Code Enforcement, a city's statutory ban on STRs is not enough to keep STRs from opera...
F3
Even with robust Code Enforcement, a city’s statutory ban on STRs is not enough to keep STRs from operating.
Response: Agree
Score: +1
The City of Laguna Woods agrees with this finding. While the City of Laguna Woods has had limited experience with short-term rentals operating in Laguna Woods, based on our understanding of the subject and experience in other cities, we agree that cities have experienced situations in which short-term rentals continue to operate even when such operation is locally prohibited and vigorously enforced. F12. City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service. Response: The City of Laguna Wo...
F12
City leaders have no regular communication with each other concerning STR issues, limiting opportunities to develop strategies and expertise to improve service.
Response: Agree
Score: +1
The City of Laguna Woods agrees with this finding. While the City of Laguna Page | of 2
Woods is unaware of any regular (ongoing) communication that exists between all cities concerning short-term rental issues, it has been our observation that cities are generally willing to share their "lessons learned" upon request. RECOMMENDATIONS R1. Cities should review and begin to update ordinances to keep up with the rapidly changing nature of court findings and legislation related to STRs, by December 31, 2025, and no less frequently than every three years thereafter. (F4, F12) Response: This recomm...
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