Diving into Codes Complaints

In the original article, we broke complaints into two categories: police and codes. Let’s dive into the codes complaints a bit further today.

We shared last time that according to The Tennessean data, the 328 complaints to Codes were tied to STRPs WITH permits. However, the article by News 2 WKRN said the number for the same time period was 374 complaints including permitted AND non- permitted. Depending on which is accurate, this would mean that STRP complaints represented .98% (Tennessean source) or 1.12% (WKRN source) of total complaints to codes during the timeframe in question depending on which data source is used (328 STRP complaints according to Tennessean/ 33,452 total calls) or (374 STRP complaints according to WKRN/ 33,452 total calls).

While the total number of complaints tied to STRPs in comparison to all codes complaints is low in and of itself, when we actually break down what those complaints were for, we can see that the main cause of complaints are not related to actual disturbances.

For instance, 106 of complaints were simply for having the wrong permit. While still considered a codes violation, not one that would necessarily cause disturbances which are the crux of the issue at hand. Ironically, many of these 106 complaints have been made by NASTRA members trying to help with enforcement.  Here is the breakdown, sources and other considerations:

  • The remaining “328 calls were fielded by codes” (as stated later in The Tennesseanarticle). The article by News 2 WKRN said the number for the same time period was 374 complaints to codes. Although a seemingly small difference, the fact that there is a difference causes us to questions all of the numbers. Why do two different reporters not get the same number?

  • We also believe the report commissioned by Mayor Barry in 2015 is important to consider. On page 37 of the public report titled ‘Staffing and Organization of the Property Standards Division’, there were a total of 18,247 complaints logged to the codes department. At the time, it was reported that there were only 13 tied to short-term rentals for the entire 2015 period. Unfortunately, there is no new, public data on complaints to codes in the corresponding time period so let’s make some reasonable assumptions. If we assume the data for the year 2015 is a consistent, annual average then we can assume that there would be approximately 33,453 complaints to codes within a 22- month period (18,247 complaints/ 12 months = 1,520.6 complaints to codes per month x 22 months = 33,452.8)

  • To be fair, since we used some assumptions here, even if the total STRP reports to codes were DOUBLE what either source reported, they would still account for just at 2%of all complaints to codes.

  • According to the WKRN report on codes complaints, “most of the complaints were for owners operating AirBNBs without a permit or for advertising over the legal limit” though it does not state exactly how many of the 374 were specifically tied to these types of complaints. The Tennesseanarticle, however does give this data as follows (again, leading us to believe that despite saying their complaints were tied only to permitted properties that number did actually include complaints against non- permitted properties as well):

    • 106 complaints for permit issues, such as having the wrong type of permit

    • 102 complaints for over short-term rental occupancy limit

    • 120 for other codes complaints (trash in yard, parking on grass, etc.)

When removing the 106 complaints for permit issues, such as having the wrong type of permit and looking at codes complaints that would potentially cause disturbances that leaves only 222 complaints to codes over the 22 month. That’s about 10 per month out of the assumed total of 1,520 per month using the report commissioned by Mayor Megan Barry.


Alece Ronzino