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Zoning Administrator Interpretation 27: Extended Stay Hotels


Friday, February 5, 2021
Reference: 
ZA-027

The Zoning Administrator has determined that a Certificate of Occupancy for an existing hotel would not need to be changed to allow an extended stay hotel operation. A hotel or lodging use is permitted to have short term [i.e. less than 30 day] occupancy, but there are no limits on customers having stays longer than 30 days.

Therefore, the use would still be recognized as a hotel use, as long as a dining room is retained, consistent with the definition of hotel, under Section B-100.2:

Hotel: A building or part of a building in which not less than thirty (30) habitable rooms or suites are reserved primarily for transient guests who rent the rooms or suites on a daily basis and where meals, prepared in a kitchen on the premises by the management or a concessionaire of the management, may be eaten in a dining room accommodating simultaneously not less than thirty (30) persons. The dining room shall be internally accessible from the lobby. The term "hotel" shall not be interpreted to include an apartment house, rooming house, boarding house, or private club. All areas within a hotel shall be included in one (1) of the following categories:…[excerpt]

Therefore, it is not necessary to amend a Certificate of Occupancy in such instances.

If the property owner wanted to eliminate the dining room, they would need to seek a new Certificate of Occupancy an Inn use, as is defined in Section B-100.2:

Inn: A building or part of a building in which habitable rooms or suites are reserved primarily for transient guests who rent the rooms or suites on a daily basis. Guestrooms or suites may include kitchens, but central dining, other than breakfast for guests, is not allowed. The term "inn" may be interpreted to include an establishment known as a bed and breakfast, hostel, or tourist home, but shall not be interpreted to include a hotel, motel, private club, rooming house, boarding house, tenement house, or apartment house. For the purposes of this definition, the limitation on central dining does not prohibit an inn from allowing guests to prepare their meals at centrally located cooking facilities and to eat such meals in a central dining area.