The "Sharing" Economy: Issues Facing Platforms, Participants, and Regulators A Federal Trade Commission Workshop #01982

Submission Number:
Richard Koplow
Initiative Name:
The "Sharing" Economy: Issues Facing Platforms, Participants, and Regulators A Federal Trade Commission Workshop
I write from an unusual position as both a strong proponent of services such as Airbnb, and also an operator of a bed-and-breakfast and member of professional industry organizations (including PAII) which have taken a somewhat different position. As a seasoned traveler, I base my lodging decisions primarily on the type of experience I seek, on familiarity with the destination, and secondarily on location of the lodging. In Morocco I stayed with Airbnb to avail myself of the extraordinary assistance from a family and to stay within the old medina. As a senior, the support of hosts often makes my travel possible. When staying in the home of a host I do not expect guarantee of absolute safety and sterility as when at a hotel; I obtain adequate expectations from the online reviews (more reliable than for hotels), and neither ask nor expect the government to limit my choices. Here in the US, resources such as Airbnb can make larger family reunions practical. One magazine after another, both popular and scholarly, has recently cited Airbnb in particular as a major contributor to global understanding -- certainly deeper than the Internet. No one corresponds for years with hotel front-desk staff. On the practical matters, it is disingenuous to merely ask 'equal treatment' among types of short-term lodging. This does not protect guests from rat infestations in bedrooms or other virtually non-existent threats as sometimes claimed, but to regulation meaningless and unwelcomed for such resources. As an innkeeper, though my establishment is exempt from ADA requirements, I must provide regulation-marked handicapped parking; is this to be expected of homeowners? Hosts often welcome me with local wine; I do the same and must hold a license for casual service of beverages; must a homeowner do the same? On and on the rules go, covering the bedrooms and kitchen access and staff and so on. Should homeowners have a certified food service manager to provide breakfast? The real question about 'equal treatment' of lodging resources is equivalent to whether the speed of airplanes should be limited to that of trains for 'fairness.' I am content to let guests decide on preferred lodging based on their perceived needs. My B&B business can well stand on its reputation for quality and service. When my daughter leaves home, I would like to list her bedroom with Airbnb primarily for meeting guests and interacting with them. For many folks, seniors especially, such arrangements provide the opportunity to remain in their family homes. I recently attended an AtlanticLIVE forum on the economy at which 'the permissionless, innovative economy such as Airbnb' was cited by multiple speakers as a method to provide major necessary invigoration to the economy, and especially to the forgotten middle class. I have never, in years of using shared hosting facilities, seen or heard of community hazards these facilities are feared to promote, such as increased traffic and parking, and wild partying. Indeed, the presence or proximity of the owner generally ensures a natural check on incompatible activities. I see far more 'wild parties' at commercially rented beach houses than at any listed with Airbnb -- the latter usually having owners present or nearby, methods for mutual verification of both renters and lessors, and insurance provided by the exchange service, all honed through years of 'permissionless' innovative development. Nonetheless, if municipalities feel they are in such straits that the loss of revenue from lodging taxes is significant, I could accept -- at such time as the sharing economy develops sufficient maturity -- some mechanism to collect lodging taxes. However, I would absolutely eschew any and all other regulation or licensure, especially for residences which are essentially or frequently owner-occupied, and possibly to ensure some reasonable number of simultaneous guests per bedroom. This compromise has been adopted by various localities.