Breaking Down Total Complaints by Permit Type

Nashville Metro City Council is considering a moratorium and/ or phase out of type 2 and 3 short term rentals. This is being driven by complaints that these types of short terms because they are not owner- occupied. Let’s take a look at how short term rental types are defined according to Nashville Codes Administration site:

Type 1: Owner-Occupied

(single-family, duplex, or multifamily)

  • Owner-occupied residence or a secondary residence associated with an owner-occupied principal residence on the same lot.

  • Includes the rental of an entire dwelling unit to a single party of individuals, or

  • If only part of the unit, includes at a minimum one sleeping room and a bathroom, and is limited to a single party of individuals.

Type 2: Not Owner-Occupied

(single-family or duplex)

  • Are not owner-occupied or associated with an owner-occupied principal residence

  • Are single-family or duplex properties

  • Rentals are limited to a single party of individuals

  • The Metro ordinance limits the number of Type 2 permits allowed to in each census tract to 3%.

Type 3: Not Owner-Occupied Multifamily

(Multifamily apartments and condominiums)

  • Are not owner-occupied or associated with an owner-occupied principal residence

  • Are in multifamily structures

  • Rentals are limited to a single party of individuals

According to The Tennessean article, “The Metro Council is considering a moratorium or a ban on short-term rentals in multifamily buildings and those where the owner doesn’t live on the property. Those types of properties accounted for 18 percent and 49 percent of the police complaints, respectively — roughly the same proportions as the permits issued under each category.”

Based on the order of the wording, this would mean that multifamily dwellings (type 3 permits) accounted for 18% of the complaints and those where the owner doesn’t live on the property (type 2) accounted for 49% of the complaints. That would imply that the remaining 33% of complaints must have been tied to the type of permitted not discussed in the article, owner- occupied STRPs (type 1). According report commissioned by Mayor Megan Barry, here is the breakdown of STRP permits by type:

  • Type 1 (owner occupied) – 894 of 2,505 permits (35% of total)

  • Type 2 (non- owner occupied) – 1,092 of 2,505 permits (44% of total

  • Type 3 (multi-family) – 519 of 2,505 permits (21% of total)

Let’s apply that math to the total complaint data (includes police and codes complaints):

  • 975 total complaints (again, still unknown if this is tied to permitted and non-permitted or just permitted and is a duplicated number)

    • 975 x 49% = 478 complaints tied to type 2

    • 975 x 33% = 322 complaints tied to type 1

    • 975 x18% = 175 complaints tied to type 3

This indicates that permits and complaints are proportionate to the number of STRP types – which the The Tennessean article does point out- this would indicate that type 2 and type 3 are no better or worse than type 1. Considering the debate is regarding a moratorium on type 2 and 3 STRPs, this should be a consideration.


Alece Ronzino