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HomeMy WebLinkAboutStaff Report - PLNAPP2026-000951 Staff Report BUILDING SERVICES, CIVIL ENFORCEMENT To: Appeals Hearing Officer From: Nicholas Rush, Legal Investigator / nicholas.rush@slc.gov or 801-535-6689 Date: March 1, 2026 Hearing Date: May 21, 2026 Re: HAZ2025-01499, PLNAPP2026-00095 Appeal of Administrative Decision PROPERTY ADDRESS: 1883 S 700 E PARCEL ID: 16-17-355-006-0000 ZONING DISTRICT: R-1/7000 Single-Family Residential District APPELLANT: Avid Amiri, Property Owner ISSUE: Whether staff erred in issuing a Notice and Order evidencing short-term rental usage. STANDARD OF REVIEW: This is an appeal of an administrative decision pertaining to an enforcement of Salt Lake City’s zoning code, which is found in Title 21A of the Salt Lake City Code (“City Code”). The appeals hearing officer, established pursuant to Section 21A.06.040, is the City’s designated land use appeal authority on appeals of administrative decisions, which include enforcement actions. As per subsection 21A.20.030.H. “The responsible party shall have the right to contest the notice and order at an administrative hearing in accordance with Chapter 21A.16.” In accordance with Section 21A.16.030.A, an appeal made to the appeals hearing officer shall identify “the decision appealed, the alleged error made in connection with the decision being appealed, and the reasons the appellant claims the decision to be in error.” The appeals hearing officer’s review of the administrative decision is de novo. City Code 21A.16.030.I.1. It is an appellant’s burden to prove that the decision made by the zoning administrator was incorrect. City Code 2 21A.16.030.J. CIVIL ENFORCEMENT DECISION: Based on the provisions of the Zoning Ordinance sections 21A.33.020 and 21A.62.040, Civil Enforcement gathered evidence supporting the claim that the property owner was operating a short-term rental business in a residential zone. Subsequently, a Notice and Order was issued on January 23, 2026. APPLICABLE ORDINANCES: 21A.33.020 - Land Use Table for R-1/7,000 Single Family Residential District 21A.62.040 - Definition of ‘Dwelling’ DWELLING: A building or portion thereof, which is designated for residential purposes of a family for occupancy on a monthly basis and which is a self-contained unit with kitchen and bathroom facilities. The term "dwelling" excludes living space within hotels, bed and breakfast establishments, shared housing developments boarding houses and lodging houses. APPEAL: The subject property is a single-family residence located in the R-1/7,000 Single-Family Residential District. It is subject to the land use tables in Section 21A.33.020, permitted and conditional uses for residential districts. Per 21A.33.020, short-term rentals are not permitted in the R-1/7,000 zone nor are similar uses permitted, such as “bed and breakfast” or “hotel/motel”. The appellant claims that the Notice and Order issued January 23, 2026, erred in determining that a short-term rental use was occurring at the subject property. The appellant claims City staff was unresponsive, ignored exculpatory evidence, and did not respond to a GRAMA request for the subject property in a timeframe that would allow an informed defense of the cited violation. City staff communicated with the appellant in accordance with city code and within reasonable bounds. The appellant asserts staff was “inaccessible and unresponsive”. Civil Enforcement staff communicated the violation in accordance with the requirements set forth in Salt Lake City Code 21A.20.030. Assertions that staff were unresponsive reflect an interpretation of events not shared by the City. Staff routinely manage a high caseload, often exceeding 75 active cases at any given time. In this instance, the volume of communication from the appellant, via email, text, and phone calls to multiple staff members, was 3 unusually high. While staff endeavor to respond in a timely manner, they are not obligated to respond to each individual communication within a timeframe unilaterally determined by the appellant. As reflected in Exhibit 2, the appellant first submitted documentation alleging compliance via email on Saturday, January 24. Staff responded on Wednesday, January 28, acknowledging receipt and stated, in part, “please be assured that I will review all documents you’ve submitted. If the evidence demonstrates satisfactory compliance, fines will be backdated to the date the documentation was originally provided, as appropriate.” The Notice and Order was issued on January 23, meaning only three business days elapsed before staff provided a response that the documents were being reviewed. The documentation submitted by the appellant failed to rebut the evidence relied upon by City staff in issuing the Notice and Order. The appellant asserts that City staff ignored “exculpatory evidence provided.” The evidence at issue for the relevant period consists of a screenshot of the appellant’s future booking calendars from listing platforms such as Airbnb and VRBO. In the email transmitting those calendars, sent on January 24, 2026 (Exhibit 3), the appellant states that “the property at 1883 S 700 E has modified its listings to reflect the 30-day minimum rental term as dictated in today's Notice and Order and that the property is in compliance.” However, City staff gathered evidence from the initiation of the case in May 2025 through and beyond the Notice and Order period in January 2026 substantiating the City’s finding of noncompliance. (Exhibit 3 reflects the relevant timeframe in question when the Notice and Order was issued). The purported exculpatory evidence sent by the appellant on Jan 24 (Exhibit 3), which shows a short-term booking from January 26 through January 29 that the appellant claims were “voluntarily cancelled”, is contradicted by the City’s on-site inspection on January 28, 2026 (Exhibit 9), which documented multiple individuals with luggage entering the property; one of the vehicles present also displayed out-of-state license plates. Additionally, as reflected in the City’s case summary report (Exhibit 4), there were numerous occasions on which the City’s inspector conducted on-site inspections, spoke with neighbors, and spoke with multiple occupants, all confirming that the property was being used as a short-term rental. This included an on-site inspection on November 25 (Exhibit 6), during which the inspector obtained evidence from within an Airbnb profile showing a current short-term stay receipt at the subject address. During another inspection conducted on January 23 (Exhibits 4,5), the inspector contacted occupants on-site at the subject address. The occupants confirmed they were visiting from Idaho for a two-night stay. The inspector also documented a vehicle on the premises displaying Idaho license plates. In addition, a software tool utilized by the City indicated that the property was being actively booked for short-term rental during the enforcement period (see Exhibits 7,8,9 ). 4 All GRAMA documents were provided in the timeframe governed by state law. The appellant asserts that his initial GRAMA request for records related to the subject property, submitted on January 26, did not result in responsive records being provided before the expiration of the 10-day deadline to appeal the Notice and Order. He therefore argues that the City denied him the ability to prepare a defense for this appeal. Pursuant to Section 21A.16.030, the deadline for filing an appeal of this nature is 10 days from the date of the decision. In this instance, the relevant date is the postmark date on the Notice and Order, which was January 23, 2026. Ten calendar days from that date is February 2, 2026. Per Utah Code 63G-2-204(4)(b), a governmental entity must respond to a written request for records no later than 10 business days from date of receipt. Here, the Notice and Order was postmarked January 23, 2026; thus, ten business days from the 23rd is February 6, 2026. Accordingly, the City released the responsive records for the subject property on February 3, 2026 (Exhibit 10), well before the February 6 deadline. With the hearing on this matter scheduled for May 21, 2026, the appellant had ample time to review the responsive documents in preparation for the hearing. Nevertheless, the notion that not possessing GRAMA records for the subject property somehow inherently nullifies the City’s Notice and Order is faulty reasoning, the two are simply unrelated. In addition, the appellant states that staff ignored the exculpatory evidence provided, so any responsive records to this effect are records already possessed by the appellant. The City’s evidence is only inculpatory. CASE SUMMARY: • May 13th, 2025: A Civil Enforcement case was initiated based on data obtained from the City’s monitoring software tool that indicated short-term rental activity at the subject property. (Exhibit 4) • May 16th, 2025: During an on-site inspection, the inspector contacted a neighbor of the appellant’s subject property, who stated they were aware of the property being used as a short-term rental. The neighbor reported observing a party checking out of the property the previous day and noted frequent activity of individuals working inside the residence. (Exhibit 4) • June 13th inspection: Hosting website data indicated short-term rental use at the subject property during this weekend. During an on-site inspection, the inspector contacted a short-term occupant, who stated that he had booked the property through Airbnb while visiting his sister following her completion of a program at the University of Utah. (Exhibit 4) • September 23rd inspection: Four active listings were found on the hosting sites. The listings were set for 3-night minimums. According to the software tool, a short-term booking was found for August 24, 2025, and for a stay from September 4-7, 2025. Active listing #2 had a potential stay on October 10-12, 2025. (Exhibit 7) 5 • November 6 inspection: Data from City software indicated a short-term booking November 24-28, this was corroborated by an inspection on November 25, where a receipt for a short-term booking was obtained on-site. (Exhibit 8) • November 25 inspection: During an on-site inspection, the inspector contacted a short-term occupant who stated they had booked the property through Airbnb and were visiting from Colorado for Thanksgiving. A vehicle in the driveway displaying Colorado license plates was confirmed to belong to the occupant. The occupant provided verification of the stay by displaying an Airbnb booking receipt on their phone (Reservation Date: November 9, 2025; Confirmation Code: RC5CF3WC2J). Stay dates: November 24-25. (Exhibit 6) • January 7th inspection: Four active listings were found on the hosting sites. The listings were set for 3-night minimums. The software tool indicated potential short-term rental activity on January 24-29, 2026. This was confirmed during an on-site inspection on both January 23 and 28, 2026. (Exhibit 4) • January 23rd inspection: During an on-site inspection, the inspector contacted a short-term occupant who stated they had booked the property through Airbnb and were visiting from Idaho for a two-night stay. A vehicle in the driveway displaying Idaho license plates was documented. A Notice and Order was mailed and posted on the property that same day. (Exhibit 1,5) • January 26th: Daily fines of $200/day begin. (Exhibit 4) • January 28th inspection: During an on-site inspection, the inspector documented three individuals carrying luggage into the subject property. A vehicle with California plates was also documented. This matched the calendars provided by the appellant, showing short-term activity on this day. (Exhibit 3,9) • February 24th: Appellant provided documentation of web calendars, short term rental cancellations, and a lease agreement. At this time, no short-term listings were found on the hosting websites and on-site visits confirmed a vacant property. Fines were modified to cease on January 30 and property deemed compliant. (Exhibit 4) NEXT STEPS: If the administrative decision is upheld, the nightly rental offerings in a residential district may not continue. If the administrative decision is overturned the property owner may continue hosting nightly rentals in a residential district, inconsistent with SLCC Section 21A.33.020 Land Use Table for R-1/7,000 Single Family Residential District. Any decision on this appeal can be appealed to Third District Court within 30 days. 6 EXHIBITS: 1. Notice and Order 2. Email from Appellant 1/24/26 3. Email from Appellant re: calendars 4. Case Summary Report 5. Inspection photo 1/23/26 6. Inspection photos/evidence 11/25/25 7. Rentalscape data/calendar 9/23/25 8. Rentalscape data/calendar 11/6/25 9. Inspection photo 1/28/26 10. Grama completion 2/3/26 11. Appellant petition 7 EXHIBIT 1: Notice and Order 8 EXHIBIT 2: Email from Appellant 9 EXHIBIT 3: Email from Appellant re: calendars 10 EXHIBIT 4: Case summary report 11 12 13 14 EXHIBIT 5: Inspection photo 1/23/26 15 EXHIBIT 6: Inspection photos/evidence 11/25/25 16 EXHIBIT 7: Rentalscape data/calendar 9/23/25 17 EXHIBIT 8: Rentalscape data/calendar 11/6/25 18 EXHIBIT 9: Inspection photo 1/28/26 19 EXHIBIT 10: GRAMA completion 2/3/26 20 EXHIBIT 11: Appellant petition