NEW BUFFALO — The New Buffalo City Council and Planning Commission held a March 17 joint meeting to discuss a pair of draft short-term rental ordinances (covering proposed regulatory and zoning rules).

Interim City Manager Rich Killips introduced the two draft ordinances as follows:

Following the City Council’s discussion regarding short-term rentals during a special meeting in January, City staff and the City Attorney have worked to develop a new draft ordinance package that incorporates comments made by both Council members and members of the general public. Council members indicated that it would be useful for the Council and the Planning Commission together for a workshop to discuss these proposals.

The proposed ordinance package consists of two separate ordinances, the first of which is an amendment to the regulatory ordinance that the City adopted in the spring of 2019. Since that ordinance was adopted, some have argued that the City’s enforcement efforts have not been satisfactory. The “three strikes” provision has received particular criticism on the grounds that the requirement to prosecute each “strike” in the state court system makes the process overly burdensome, time-consuming, and expensive. Perhaps because of these sentiments, the City has not pursued permit revocation for any short-term rental properties during the two years since the program began.

The principal purpose of the draft regulatory ordinance is to address these concerns about enforcement cost and efficiency. The proposal seeks to achieve this purpose by, among other things:

1. Establishing an administrative hearing system that can be used to revoke licenses “in house” without court involvement. This is intended to make the process more feasible and cost-efficient.

2. Eliminating subjective standards relating to revocation so that the hearing officer’s revocation decisions will be more likely to be upheld on appeal.

3. Clarifying the responsibilities of owners and agents as compared to the responsibilities of occupants.

4. Requiring owners and agents to compile and provide information to the City about each rental reservation, so that officers called to a scene can easily identify the renters and the vehicles that belong to them, as opposed to non-renter guests at the property.

5. Strengthening provisions relating to off-street parking, which has been one of the most frequent causes for complaints under the existing ordinance.

Notably, the new draft ordinance omits several provisions that were included in the draft discussed at the special meeting in January, such as the provisions that would have decreased the maximum occupancy from 14 to 10; required a professional management company to be used as a local agent; and allowed the City to place a placard in front of properties that are found to be renting without a rental permit. Once again those are things you won’t see or hear mentioned here tonight.

The second component of the proposed ordinance package is an amendment to the zoning ordinance that (1.) caps the total number of short-term rental units in the R-1 zoning district only at existing levels (65 are currently licensed). New short-term rentals would continue to be allowed in all other zoning districts that contain dwelling units.

2. Provides that if a property owner in R-1 fails to renew a rental permit within a year of expiration (or within a year after the end of a revocation period), the short-term rental use is deemed abandoned. In short, this proposal is intended to restore the residential nature of the R-1 district, as opposed to allowing the number of short-term rentals to continue to increase. The rationale for this change is similar to the rationale for the moratorium that the City Council adopted in the spring of 2020.

During the workshop, Council members and Planning Commissioners can ask any questions they may have regarding the proposals and make suggestions for further revisions. If the proposals have significant support, staff anticipates that the zoning ordinance component of the package will then be brought to the Planning Commission for a public hearing sometime in early April. The City Council would then consider the package as a whole in late April or early May.

City Attorney Nick Curcio said the zoning would establish a cap setting the number of permits available in areas zoned R-1 residential at the current level, adding: “We think that that’s around 65 … we would double check that figure before adopted.”

“Once this was adopted, no more permits would be issued in that district unless the City Council were to … direct otherwise,” he said.

In response to a question, Curcio said the number could drop below the current level in R-1 if licenses are allowed to expire.

The draft ordinance states that “A permit is terminated when the property to which the permit applies is conveyed to another party,” but also includes the following language: “A permit that expires or is terminated upon the conveyance of the property can be renewed so long as the application is submitted within 12 months of expiration or termination.”

That aspect of the proposal drew some criticism during the discussion.

“People are selling these homes to people from out of state with the intention of selling that permit with the house, because these people buying these houses have no intention of living here, not at all,” City Council member Brian Flanagan said.

Curcio said in the remainder of the city (which includes other residential zoning areas such as R-2 and R-3) the owner of a dwelling unit would be able to engage in short-term rentals and get a permit.

“That means that new permits could continue to be issued in those areas,” he said.

Mayor John Humphrey asked if city officials believe short-term rentals “are even legal in R-1,” adding that it is his personal opinion that they are not.

“They’re commercial businesses that cater to transient visitors for limited stay. They’re function of use is of commercial lodging hotel/motel. They’re operation not compatible in single-family districts.”

Curcio said it’s at least debatable about how a court would interpret the zoning ordinance, adding that there are arguments on both sides.

Humphrey said there are 2,505 residential properties in the city, and 642 are considered “homestead” (primary residence).

“If we can return some equity to the community, I don’t know if this would do it over a full ban, but that would really help us,” he said.

During a discussion on the penalties for renting without a permit, Curcio said the $750 first-offense fine, which can be levied up to daily and increase on subsequent violations, “are somewhat beside the point in this circumstance.”

“What the city would really be looking for is injunctive relief, that’d be an order from a court saying ‘you are not legally permitted to use this property,’” he said, adding violating a court order cold lead to contempt of court charges.

Humphrey said, “I think that the purpose of this ordinance is to provide accountability, and that has always been the failing of the previous ordinance. It did not provide real accountability to the people that are … doing whatever they want basically.”

He later said “The goal is not to draconianly punish people. It’s to restore law and order … to return some semblance of peace to the community that has been upended by unregulated rentals running amok in certain residential neighborhoods.”

Curcio also talked about a reservation form required under the draft ordinance (based on a recently adopted ordinance in the Village of Michiana) which will provide information on the number of people, vehicles and other data on short-term rental properties when they are occupied.

The number of short-term rental licenses that have been issued in the city was said to be 162, while Humphrey estimated that over 300 properties are being rented out city-wide.

City council member Mark Robertson asked about the possibility of putting a cap on other districts as well, and Curcio said that could be done city-wide or district by district.

After more than an hour of discussion and another 50-plus minutes of listening to public comments, members of the City Council and Planning Commission were told by Humphrey that the next step is for planners to come back with a recommendation on how to handle zoning issues.

“There are a couple of different ways we can go,” he said.

Public comments included:

• Laura Murray, who said she lives in an R-3 residential district and has applied for a license, asked how that area would be affected by the draft ordinance (Humphrey said R-2 and R-3 would not be affected, just R-1). She also asked if the moratorium on short-term rental licenses would be lifted and Humphrey said “Not yet, but we’re trying to get there.”

• Dan Hatch said he represents the property owners who have filed a lawsuit against the city. Hatch said the current short-term rental ordinance (No. 237) can only be amended, changed or suspended by “an act of equal dignity” under the law (another ordinance). “What we’re claiming in the lawsuit is that Ordinance 237 was suspended by a resolution of the City Council, which is very, very different than an ordinance,” Hatch said. He added that the resolution for a moratorium “suspended property owners rights to apply for or be issued a short-term rental permit for an unreasonable period of 15 months.”

Hatch said the limitation of 65 units in R-1 “leaves out the significant number of property owners who are on a waiting list and who have been unable to obtain short-term rental permits because of the unlawful moratorium.”

• Dan Coffey said he served on the school board for 10 years “and at one point we we’re going to close our schools because we didn’t have any moneyed we didn’t have any taxes.” He said the schools are now great “because of the 1,800 second homeowners and the short-term rentals.” Coffey also noted that the local school system is limited to the size of the buildings and number of teachers, so adding more students wold require adding more rooms and teachers.

• David said for many short-term rental owners it is not a major money-making operation. “I’m a little bit tired of being vilified, as we are sort of the antithesis of the town … we pay twice as many taxes and many of us do not have have kids in school. The money is just being pumped into the school.”

• Talia Edwards said she thinks the registration form is a fantastic idea, adding that she is nervous about putting a cap on anything and asked officials to consider dropping the moratorium and cap and instead enforce everything to a T.

• Daniel Ruby said it seems to him that there is an agenda to abolish short-term rentals, which would reduce taxes and cause them to be raised. He also said a number of local businesses rely on short-term rental customers. “I would have to say the majority of renters are decent people.”

• John Natsis asked how many vacation rental issues were police called out on (adding that it sounds like city “was completely on fire” from discussion). “I ran vacation rentals for 20 years and had a handful of problems the entire time – 50 to 60 properties at a time. “I’m all about enforcement but gosh, the city is not on fire.”

• Joanne Moskovic (who identified herself as a plaintiff in lawsuit against the city) said, “To ask that every renter has to fill out a form identifying themselves and their vehicles and personal information and submitting it to the city seems overreaching, maybe an invasion of privacy for the renters, and certainly quite burdensome for the renters and the owners to submit that information for every single rental.”

• Jason Millovich said “I have to say I am pretty shocked at how one-sided and negative, anti-rental this seems to be.” Without tourism he said businesses can’t be supported. “This is a tourist-based economy and it’s been that way for a hundred years.” “I hope that you guys can see reason as opposed to just wanting to bash the people that are coming here, and have for decades.”

• Bill Lenga said “This is a tourist economy, there is no other business other than real estate. And I just dint understand what the vision is for this community going forward because the jobs aren’t going to be here. There’s no industrial base, there’s no infrastructure, we can barely support the breweries that are here with he sewer.”

• Diane Pyschos said since there has been very little enforcement of the original ordinance why re-write it instead of “enforcing the one we already have for the upcoming season?”

• Maria Cleveland (who owns Brewster’s) asked council to be mindful of unintended consequences. “We earn a living in 12 to 16 weeks … and we are so dependent on those visitors to survive.” She also asked city officials to be mindful of what businesses are coming out of “and maybe take a beat and realize that we need a good season.”

• Kristen Hall said she understands the moratorium, but in comments she has heard tonight and response to an email sent to the city, “It really does, frankly, feel to me that our family isn’t welcome. That second homeowners in New Buffalo are not valued by the city.”

• Debbie McNulty said her husband died so she decided to rent her home and live their part-time, adding that she takes care of her property and her neighbors know that.

Language from the two draft ordinances as included in the packet for the March 17 joint meeting includes the following:

Draft Regulatory Ordinance Amendment


The City of New Buffalo ordains:

Section 1. Amendment. Chapter 11 of the New Buffalo City Code, entitled “Short-Term Rental Units,” is amended to read in its entirety as follows:

Chapter 11 Short-Term Rental Units

Sec. 11-1. Purpose.

A. The City recognizes that one of its largest industries is tourism. The tourism market supports many different types of businesses including the hospitality market, the restaurant/dining market, the shopping and retail market as well as a host of others. The City believes that the tourism industry will continue to grow.

B. The City recognizes that a major part of the tourism industry is the short-term rental or vacation rental marketplace. This marketplace has grown exponentially with the increasing use of online booking websites, and it will most likely continue to grow as surrounding municipalities limit, restrict or eliminate the practice.

C. While short-term rentals can provide community benefits, their proliferation in single-family neighborhoods can also cause difficulties where the character of the use takes on a more transitory and commercial character. Michigan courts have recognized that transitory and commercial uses are in tension with the traditional use of single-family dwellings.

D. The City needs to take action to ensure that the operation of short-term rentals is done in a safe and controllable manner for the well-being of all in the community. The character of residential zoning districts must also be restored and preserved. To that end, the City has established zoning regulations to cap the total number of short-term rentals in the R-1 zoning district at 65 units, which is the number of lawfully existing short-term rentals in the R-1 zoning district as of the date of this ordinance.

E. The City further recognizes that the establishment of a permit hearing system is needed in order to effectively enforce the short-rental regulations provided in this chapter in a cost-efficient manner. Final determinations made in any permit hearing shall be subject to judicial review. 
Sec. 11-3. Short-Term Rental Permits; Requirement, Applications, and Review Procedure.

A. Permits required. All dwelling units used for short-term rental activity must be registered with and have a short-term rental unit permit issued by the City. Further, the operation of short-term rental units is restricted by Section 6-5 of the zoning ordinance, which caps the total number of such units allowed in the City’s R-1 zoning district.

C. Local agent required. All short-term rental units must have a designated local agent that satisfies the following:

1. The local agent shall be a natural person who resides within 20 miles of the geographic boundaries of the City of New Buffalo.

2. An owner may serve as the local agent so long as he or she has the ability to continue residing at a location within 20 miles of the City of New Buffalo during the duration of any short-term rental term.

D. Permit issuance. To the extent permits are available in the pertinent zoning district at the time of the application, a short-term rental unit permit shall be granted after a successful inspection if the requirements in this ordinance for short-term rental units and applications for a short-term rental unit permit are met.

E. Validity and renewal. Short-term rental unit permits become invalid in each of the following circumstances:

1. A permit expires on year from the date of issuance of the permit;

2 A permit is terminated when the property to which the permit applies is conveyed to another party;

3. A permit is terminated when revoked in accordance with Section 11-11 below.

F. A permit that expires or is terminated upon the conveyance of the property can be renewed so long as the application is submitted within 12 months of expiration or termination. A permit that is revoked in accordance with Section 11-11 can renewed at the end of the 1-year ineligibility period so long as the application is submitted within 12 months of the date when the permit first becomes eligible for renewal. The renewal process shall be subject to the same requirements as the initial application.

G.    Delinquent payments. No permit shall be issued or renewed unless the owner is current on the payment of all real property taxes, utility rates, fees, charges, special assessments and other amounts due to the City. Delinquencies on any such payments to the City, regardless of whether they relate to the rental unit for which a rental unit permit is sought shall result in denial of the permit.

H.    Changes in information. An owner or local agent shall notify the City in writing within 15 days of any change in the information provided on the application form. An owner of a short-term rental unit shall notify the City in writing within 15 days of any change in the designated local agent.

Sec. 11-4. Responsibilities of Short-Term Rental Operators.

The owner(s) and local agent for each short-term rental unit shall each be responsible for ensuring compliance with the following regulations, except where expressly provided otherwise:

A. Local agent availability. During each short-term rental term, the local agent shall be available 24 hours per day, seven days per week for the purpose of responding within 30 minutes to complaints regarding the condition, operation, or conduct of occupants of the short-term rental unit or their guests.

B. Timely and effective response. The local agent shall, upon notification that any occupant or guest of the short-term rental unit has created unreasonable noise or disturbances, engaged in disorderly conduct, parked vehicles in violation of this ordinance, or committed any other violations of applicable laws, rule or regulation pertaining to the use and occupancy of the short-term rental unit, respond in a timely and appropriate manner to halt and prevent a recurrence of such violations.

C. Reasonably prudent business practices. The owner and/or the owner’s authorized agent shall use reasonably prudent business practices to ensure that the occupants and/or guests of the short-term vacation rental unit do not create unreasonable noise or disturbances, engage in disorderly conduct, or violate any applicable law, rule or regulation pertaining to the use and occupancy of the subject short-term vacation rental unit.

D. Duty to provide permit and post in window. Upon request by any occupant or prospective occupant, the owner(s) or agent shall provide the occupant or prospective occupant with a copy of the short- term rental unit permit. Further, a full-sized copy of the short-term rental unit permit must be posted in a prominent first-floor window of any short-term rental during each short-term rental term.

E. Maximum occupancy; advertising regulations. Each short-term rental unit permit shall indicate the maximum occupancy for the unit, calculated pursuant to Section 11-9 below. A short-term rental unit shall not be advertised for an occupancy that is greater than the allowed maximum occupancy calculated pursuant to this section. Any advertisement posted on an online short-term rental platform must state the maximum occupancy as calculated pursuant to Section 11-9.

I. Curbside refuse pickup. The owner or local agent must make provisions to have refuse picked up (curbside) at least once per week when the short-term rental unit is being rented. Where curbside pickup is not reasonably available, this requirement may be satisfied by provision of a communal dumpster available for use by occupants of the short-term rental unit. Further, it shall be responsibility of the owner and local agent to ensure compliance with Section 15-7 of the City Code, which regulates the times at which refuse and recycling receptacles may be set out for collection and left at the curb of the street.

K. Rental of partial dwelling units prohibited. This chapter pertains only to the short-term rental of an entire dwelling unit. The short-term rental of partial dwelling units (e.g., a room or rooms within a dwelling unit) is prohibited.

Sec. 11-5. Responsibilities of Short-Term Rental Occupants and Guests.

A. Street parking prohibited. No short-term rental occupant, nor any other guest visiting a short-term rental unit during a short-term rental term, shall park vehicles on public streets adjacent to the unit. Rather, the off-street parking spaces provided on the lot must be utilized, and any excess vehicles must be parked in public parking lots or other permitted off-site locations.

B. Short-term rental reservation summary. Occupants shall produce a copy of the short-term rental reservation summary to a City police officer or other ordinance enforcement officer upon request.

C Duty to comply with applicable laws. Short-term rental occupants and guests shall comply with the City’s noise ordinance, fireworks ordinance, trash disposal ordinances, open burning regulations, applicable offenses against the public peace, and any other applicable ordinances or laws. A violation of any of the foregoing shall also be a violation of this section.

Sec. 11-6. Unauthorized Rentals Without a Permit.

A. Unauthorized rentals. It shall be unlawful to engage in short-term rental activity with respect to any dwelling unit that has not been issued a permit pursuant to this chapter. In any prosecution or action to determine a violation of this section, the following shall apply:

1. Advertising that offers a property as a short-term rental home shall constitute prima facie evidence of short-term rental activity involving the property and the burden of proof shall be on the property owner or other defendant to establish that the subject property has not been used for short-term rentals.

2. Any communication in which a person offers a dwelling unit for rent for a term of less than one month shall constitute prima facie evidence of short-term rental activity and the burden of proof shall be on the property owner or other defendant to establish that the subject property had not been used for short-term rentals.

B. Unauthorized advertising. It shall be unlawful to advertise any dwelling unit that does not have a short-term rental permit issued pursuant to this section for rent for a period of less than one month. Such advertisement shall constitute a violation of this ordinance separate and apart from a violation described in subsection A above.

Sec. 11-9. Maximum Occupancy Calculation.

The number of occupants in a dwelling unit during a short-term rental shall not exceed the lesser of:

A. Fourteen total occupants;

B. Two occupants per bedroom plus two additional occupants per finished story meeting the applicable egress requirements for occupancy in the Michigan Construction Code; or

C. Except for units within a planned unit development, four occupants for every off-street parking space that is provided on the lot and reserved exclusively for occupants of the short-term rental unit. For units within a planned unit development, the occupancy is determined only by the limits described in Subsection A and B.

Sec. 11-10. Violations.

A. Violations as municipal civil infractions. Any person who violates any of the provisions of this ordinance is responsible and may be prosecuted for a municipal civil infraction in court of competent jurisdiction, subject to payment of a civil fine of not less than $500, plus costs and other sanctions, for each infraction. Repeat offenses shall be subject to an increased civil fine as follows:

1. he fine for any offense which is a first repeat offense shall not be less than $750 plus costs and other sanctions.

2. The fine for any offense which is a second repeat offense or any subsequent repeat offense shall not be less than $1,000, plus costs and other sanctions.

3. A repeat offense means a second (or any subsequent) violation of this ordinance:

a. Committed by a person within any twelve-month period; and

b. For which the person admits responsibility or is determined to be responsible.

B. Administrative notices in lieu of citations. As an alternative or initial remedy, the City may seek to obtain compliance with this ordinance by issuing an administrative violation notice to the owner(s) and/or local agent for the unit to which the violation pertains. Each time a violation notice is issued, the owner(s) and local agent shall immediately cease the offending conduct or taking corrective action to terminate the violation described. Each violation notice shall be served in accordance with Section 11-12 and shall contain the following information:

1. The name of the responsible person(s);

2. The code section violated;

3. The address where the code violation occurred;

4. A description of the code violation;

5. The names of the issuing department and enforcement officer;

Sec. 11-11. Short-Term Rental Permit Revocation.

A. Grounds for revocation. The City may revoke the short-term rental permit for any short-term rental unit which is the site of at least three separate incidents within a 12-month period (occurring on three separate days) constituting a violation of any provision of this ordinance, whether committed by an owner, local agent, occupant or guest. In order to qualify as an incident for purposes of this paragraph: (1) the City must have issued a civil infraction citation or administrative violation notice regarding the offending conduct prior to commencing revocation proceedings pursuant to subsection B below; and (2) the violation must be either admitted by the owner or proven by a preponderance of the evidence in a civil-infraction prosecution in state court or in a revocation hearing as provided in Section 11-13 below.

B. Revocation Procedure. Upon a determination by the City that the short-term rental permit is subject to revocation pursuant to subsection A, the City shall serve a notice, pursuant to Section 11-12, to the property owner(s) and the local agent stating that the City intends to revoke the short-term rental permit. The notice shall inform the owner(s) and local agent of the date and time at which a revocation hearing will be conducted before a hearing officer, in accordance with Section 11-13. Determinations by the hearing officer regarding revocation shall constitute final orders of the City. 
C. Period of ineligibility following revocation. Upon revocation of a permit, a renewed short-term rental permit will not be issued for a period of 12 months and the unit cannot be used for short-term rentals until such permit is obtained.

Sec. 11-13. Permit Revocation and Permit-Ineligibility Hearings.

The following standards and procedures shall apply in any permit revocation or permit-ineligibility hearing conducted under this chapter:

A. Opportunity to be heard. Property owners and local agents shall be provided with the opportunity for a hearing during which they may be represented by counsel, present witnesses, and cross- examine witnesses. Hearings shall be scheduled with reasonable promptness, provided that the property owner(s) and local agent shall be given at least 14 days after service of process to prepare for the hearing.

B. Evidence. The hearing officer may admit and give probative effect to evidence of any type commonly relied upon by reasonably prudent persons in the conduct of their affairs. Irrelevant, immaterial, or unduly repetitious evidence may be excluded. Effect shall be given to the rules of privilege recognized by law. Objections to offers of evidence may be made and shall be noted in the record. Subject to these requirements, the hearing officer, for the purpose of expediting hearings and when the interests of the parties will not be substantially prejudiced thereby, may provide in an administrative hearing or by rule for submission of all or part of the evidence in written form.

C. Burden of Proof. The City shall have the burden of establishing that the grounds for permit revocation, as described in Section 11-10, by a preponderance of the evidence. A decision and an order shall not be made except upon consideration of the record as a whole or a portion of the record as may be cited by any party to the proceeding and as supported by and in accordance with the competent, material, and substantial evidence.

D. Appeals. Final determinations of the hearing officer shall be subject to judicial review in accordance with Article VI, Section 28 of the Michigan Constitution in an appeal taken pursuant to Michigan Court Rule 7.123.

Sec. 11-14. Implementation of R-1 Zoning Cap.

A. Ceasing the issuance of new permits. Upon the effective date of Section 6-5 of the Zoning Code, which caps the total number of short-term rentals in the City’s R-1 zoning district at existing levels, the City shall not issue any new short-term rental permits for parcels in the R-1 district (even if the total number of permits in existence drops below the cap established in Section 6-5). The City shall, however, continue to issue renewed short-term rental permits for properties in the R-1 district as provided in Section 11-3 above. 
B. Future amendments to allow new permits. The City reserves the right to amend this section in the future in order to provide a procedural mechanism for issuing new short-term rental permits for parcels in the R-1 district once the total number of permits in existence drops below the cap established in Section 6-5 of the Zoning Ordinance. However, the City shall have no obligation to do so. 

Draft Zoning Ordinance Amendment


WHEREAS, in April 2019, the City Council adopted an ordinance requiring the registration and inspection short-term rental units within the City; and

WHEREAS, since enacting the ordinance, City staff has studied the registration statistics and the density of short-term rentals; and

WHEREAS, after extensive study of the proliferation and effects of short-term rental uses, the City Council has determined that if current trends were allowed to continue, short-term rental uses could undermine the character and stability of neighborhoods in certain districts by, among other things:

1. Decreasing the number of long-term residents;

2. Decreasing enrollment in local schools;

3. Decreasing the availability of long-term housing stock, thereby driving up prices and making long- term residency less affordable;

4. Creating significant numbers of vacant homes in the winter months; and

5. Increasing levels of noise, traffic, and on-street parking during the summer tourist season.

WHEREAS, in a series of recent cases, Michigan courts have recognized that transitory and commercial uses are in tension with the traditional use of single-family dwellings; and

WHEREAS, the City Council has determined that it is in the best interest of the City to amend the zoning ordinance to clarify the permissibility of short-term rental uses throughout the City and to cap the total number of short-term rental units in the R-1 zoning district at the existing level of 65 units.

The City of New Buffalo ordains:

Sec. 6-5. Short-Term Rental Units Capped at Existing Levels.

A. Cap Established. The total number of such short-term rental units in the R-1 district shall not exceed 65. New permits for properties in the R-1 district shall only be issued to the extent allowed in Chapter 11.

B. Abandonment of use. Use as a short-term rental unit shall be deemed abandoned if: (a) the short- term rental permit for the property expires, terminates, or is revoked by the City, and (b) a renewed short-term rental permit is not obtained within 12 months of the date on which renewal first becomes possible pursuant to Chapter 11 of the City Code. After abandonment, the owner of the property is not entitled to a renewed short-term rental permit, and shall only be entitled to a new permit to the extent such permits are available.

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