11-30-2025: RE: Comments on the Transient Lodging Study (October 2025)
November 30, 2025
New Orleans City Planning Commission
1300 Perdido Street
New Orleans, LA 70112
RE: Comments on the Transient Lodging Study (October 2025)
Dear Commissioners:
Louisiana Landmarks Society appreciates the work that has gone into the Transient Lodging Study. The analysis, community engagement and recommendations represent a significant step toward addressing the challenges posed by short-term rentals in our city.
We commend the Study's goal of limiting Commercial Short-Term Rentals to one per block in most districts. As the Study documents, 72.8% of survey respondents prioritized stopping illegal CSTRs, 62.6% wanted to preserve year-round housing, and 59.2% wanted to keep neighborhoods residential. The one-per-block limitation area" and "when too many acknowledges what the Study clearly states: "transient lodging uses change the demographics of an land uses on a given block are taken up by transient lodging uses, they contribute to a loss in community character because they change both the urban form and demographics of an area."
We also appreciate the Study's recognition that protecting community character must come first, as stated in the Executive Summary: "it is the very exceptional community character in New Orleans that drives the tourism industry and increases demand for STRs. For this reason, protecting community character must come first."
Areas of Concern
1. CBD-5 District Exemption from Density Limits
We strongly urge the inclusion of CBD-5 in the one-per-block limitation. The Study itself defines CBD-5 as the "Urban Core Neighborhood Lower Intensity Mixed-Use District," explicitly designed as a transitional zone to encourage long-term residents. Particularly desirable is the ability for residents to live near work and transi opportunities. The current recommendation exempts CBD-5 from density restrictions.
However, the Study's own findings support restricting STRs in CBD-5:
- The Study warns that "by limiting CSTRs' continued proliferation—it is likely that prospective buyers will be less likely to inflate housing and building costs, and more units in mixed-use and commercial areas will be made available for long-term housing"
- Survey respondents reported that displacement and unaffordability concerns were concentrated in areas with high STR density
- The Study notes that "limiting the over-concentration of STRs will better protect community character by preserving existing long-term housing units"
By limiting STRs elsewhere while leaving CBD-5 unrestricted, the regulations will simply shift the problem, causing a proliferation in this transitional neighborhood and accelerating the conversion of long-term residential units to short-term rentals. This directly contradicts the district's purpose of encouraging permanent residents.
2. Hostel Definitions and Standards
We encourage more robust work to define and regulate hostels. The Study acknowledges that "existing Hostels are not permitted as separate uses in the permit data despite being a separate use in the Comprehensive Zoning Ordinance," and notes that of four businesses advertising as hostels, two had Hotel licenses and two had Bed and Breakfast Inn licenses.
The proposed minimum standards for hostels include only basic requirements: on-site operator 24/7, sleeping accommodations limited to 2 occupants unless the room contains 70 square feet per occupant (maximum 6 per room), and common bathroom facilities. Without more detailed operational standards similar to those imposed on CSTRs—such as impact management plans, noise abatement requirements, and security protocols—the hostel classification may become an attractive loophole for operators seeking to avoid more stringent CSTR regulations.
Given that hostels would be permitted by right in numerous commercial and CBD districts with no density limitations, inadequate standards could create an unintended consequence of the otherwise thoughtfulregulatory framework.
3. French Quarter Hotel Restrictions
We ask that the French Quarter be restricted from additional hotels beyond existing operations. The Study documents that the French Quarter currently has 43 hotels operating as legally nonconforming uses, noting that "hotels are currently prohibited in the French Quarter."
While the Study states that "the current ban on new transient lodging uses in the French Quarter has been effective," the proposed allowances would undermine this success. The French Quarter is one of the nation's most significant historic districts and deserves the strongest protections against further commercialization. Opening even limited corridors to new hotel development sets a concerning precedent and contradicts the Study's own finding that existing restrictions have worked well.
4. On-Site Management/Safety Requirements for All STRs
We ask that all STRs, regardless of size, be required to follow the same safety and operational rules as hotels, including having someone on-site at all times and meeting full hotel fire and safety standards. The Study acknowledges that CSTRs often operate indistinguishably from smaller hotels and bed and breakfasts "in both appearance and function."
The proposed regulations create a two-tiered system: Hotels must have "customary lodging services" with onsite operators, while CSTR-S and CSTR-M operators need only be "on call and available" 24/7, with violations requiring three occurrences within two weeks before license revocation becomes possible. This creates an uneven playing field and compromises safety.
Since short-term rentals function as de facto hotels—which both the Study and common experience confirm— they should all meet the same rigorous standards. Public safety, fire protection, and neighborhood security should not be compromised based on the size or classification of a transient lodging operation. The Study documents significant noise and STR complaints concentrated in areas with high CSTR density, suggesting that the "on-call" model is insufficient for protecting neighborhood quality of life.
5. Enforcement Challenges with Size Classifications
While we appreciate the logic behind establishing Small, Medium, and Large CSTR categories to match regulations to land use impact, we remain concerned about the practical enforcement challenges this tiered system will create. The Study itself acknowledges enforcement difficulties throughout, noting that as of March 2025, there were 7,552 noncompliant listings—more than three times all licensed STRs combined.
The proposed system requires monitoring:
- Which specific units in multi-family buildings are operating as CSTR-Ms (2-4 units, not exceeding 25% of building)
- Whether buildings in CBD districts exceed the 10% or 4-unit threshold
- Whether operators are managing multiple units under a single license
- Compliance with the one-per-block rule across three different size categories
- Whether whole-home dwellings meet CSTR-L standards versus operating illegally as smaller categories
The Study notes that "concentrations of CSTR licenses that are held in single ownership and are located within and across multiple buildings create a significant land use impact," identifying eight buildings with 10 or more listings. The tiered classification system, while theoretically sound, may make it even more difficult to track and prevent such concentrations.
We recommend that the City Planning Commission work closely with the Department of Safety and Permits to develop clear enforcement protocols, technology solutions, and adequate staffing before these regulations take effect. The Study's documentation that enforcement actions spike after each new regulatory iteration suggests that without proper implementation planning, well-designed rules will fail to achieve their protective intent.
Fundamental Principle
We continue to believe that STRs—of any classification—erode the availability, affordability, safety, and general quality of life of the residential community. The Study's own data supports this concern, documenting that 67.33% of renters reported being "very concerned" about negative impacts, and 27.28% of all respondents reported that they or someone they knew had been evicted from a unit now operating as a CSTR.
The Study acknowledges that "what is difficult to reconcile is there continues to be increased redevelopment activity occurring across the City, evidenced by continued infill development and housing sales, and when comparing citywide datasets, this increased development activity does not appear to benefit the local population." This troubling finding reinforces our position that prioritizing short-term lodging over long-term residential use fundamentally weakens our city.
We also note with alarm the significant and continuing increase in hotels throughout the CBD and historic neighborhoods such as the Marigny. While we understand the necessity of the tourism economy, any device that can encourage long-term residential use versus short-term use strengthens the livability of the city and helps retain our sense of community, our culture, and our authenticity—the very qualities that make New Orleans worthy of preservation and attractive to visitors.
As the Study itself states: "Community character is not only reflected in buildings and streetscape, but also made of the people who permanently live, work, and call New Orleans home." Without permanent residents, there is no authentic New Orleans to experience or preserve.
Louisiana Landmarks Society stands ready to work with the Commission, City Council, and community stakeholders to refine these recommendations in service of preserving New Orleans' residential neighborhoods, historic character, and authentic community fabric.
Thank you for your consideration.
Sincerely,
Sandra Stokes
Chair of Advocacy
Louisiana Landmarks Society