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3 S Jackson Street

Montgomery, AL 36104
Phone: (334) 244-1320

June 6, 2019

The Honorable William Parker


1710 North 20th Street
Birmingham, AL 35203

Dear Councilor Parker:

On behalf of the lodging industry, I am writing to express our strong opposition to an increase in the lodging tax in
Birmingham. From a political perspective, lodging taxes may be easier to impose than other taxes because visitors
that use lodging accommodations are generally not constituents. Typically, hotel operators collect the tax from
guests. And, while the legal incidence of the tax may fall on the consumer, the economic burden of the lodging tax
is shared by both hoteliers and their guests. The lodging market is competitive, and in a competitive market, the
tax burden is shared between buyer and seller.

A lodging tax raises the price of lodging accommodations. It is simple economics. Depending on the elasticity of
the supply and demand for lodging, the hotel manager may not be able to increase rates by the amount of the tax.
Since the elasticity of supply and demand changes depending on market conditions, the true burden of a lodging
tax varies as market conditions change. As a result, hoteliers often have to lower their room prices to maintain the
value to their customers. The lower room rates mean less money available to reinvest in the property and less
money available to pay hotel staff members.

Birmingham, Alabama already ranks as one of the highest cities in the country with regard to lodging tax. (See
attached U.S. Lodging Tax Study) Raising the tax by an additional $3 per will bring Birmingham to the very top in
the entire United States for lodging tax. Birmingham has made great strides in becoming a destination location for
convention business. This additional tax will adversely affect the trend and will put Birmingham at a competitive
disadvantage with other similarly situated venues. The average lodging tax for the top 150 largest cities in the
United States is 13.69%; this additional tax would place Birmingham at approximately 22.7%, well outside of the
market.

When the combined sales and lodging tax rates in New York City reached 21.25% —the highest rate in the country
and more than twice the average rate for major U.S. cities at that time—convention organizers boycotted the city.
Meeting planners have limited monetary resources to spend on their events. Additional expense in the form of
lodging taxes adds no value to the meeting. The U.S. Travel Association's Travel Tax Institute conducted a study
that showed that 49 percent of travelers say they have altered their plans due to high travel taxes. I am afraid that
with Birmingham being among the very highest in lodging tax percentages – we may reach a point of diminishing
returns.

While our hoteliers are not opposed to all lodging taxes, their use and allocation is very important to the industry.
Our hoteliers would love to have a seat at the table to discuss the issues that are important to the industry and how
we can help move the city forward as a preferred destination.

Sincerely,

Mindy B. Hanan, J.D.


President & CEO
Total Tax Rates by City
The following table summarizes the total lodging tax rate for 214 cities across the United States.
Included in this table is an interpolation of additional flat rate fees that some cities have. This is an
estimated percentage based on the 2015 average daily rate (ADR) for that city. With these additional
fees included, Columbus, GA has the highest total tax rate of 22.90%. The average total tax is 13.28%,
with the lowest total tax rate in Denali, AK of 7.00%.
City State Additional
Fees Total Tax Rate
Columbus Georgia 6.90% 22.90%
Macon Georgia 7.70% 22.70%
Augusta Georgia 6.20% 20.20%
Atlanta Georgia 3.90% 19.90%
Kansas City Missouri 1.70% 18.55%
Anaheim California 1.30% 18.30%
Overland Park Kansas 17.85%
Birmingham Alabama 17.50%
Omaha Nebraska 17.50%
Cincinnati Ohio 17.50%
Columbus Ohio 17.50%
Toledo Ohio 17.25%
Chattanooga Tennessee 17.25%
Knoxville Tennessee 17.25%
Montgomery Alabama 3.10% 17.10%
Indianapolis Indiana 17.00%
Niagara Falls New York 17.00%
Houston Texas 17.00%
Nashville Tennessee 1.70% 16.95%
Seattle Washington 1.20% 16.80%
San Antonio Texas 16.75%
Cleveland Ohio 16.50%
Chicago Illinois 16.39%
Lincoln Nebraska 16.25%
Charlotte North Carolina 16.25%
North Charleston South Carolina 1.10% 16.10%
Louisville Kentucky 16.07%
Ardmore Oklahoma 16.00%
Memphis Tennessee 15.95%
St. Louis Missouri 15.93%
Topeka Kansas 15.80%
Charleston South Carolina 0.60% 15.60%
Los Angeles California 15.50%
San Francisco California 15.50%
Baltimore Maryland 15.50%
Philadelphia Pennsylvania 15.50%
New York New York 1.20% 15.33%
Santa Fe New Mexico 15.31%
Akron Ohio 15.25%
San Jose California 1.20% 15.20%

STR – Lodging Tax Study 8


City State Additional
Fees Total Tax Rate
Milwaukee Wisconsin 15.10%
Tuscaloosa Alabama 15.00%
Little Rock Arkansas 15.00%
Long Beach California 15.00%
Statewide Connecticut 15.00%
Evansville Indiana 15.00%
Gaithersburg Maryland 15.00%
Rockville Maryland 15.00%
Detroit Michigan 15.00%
Cherry Hill New Jersey 15.00%
Tacoma Washington 1.50% 15.00%
Myrtle Beach South Carolina 15.00%
Austin Texas 15.00%
Dallas Texas 15.00%
Fort Worth Texas 15.00%
Appleton Wisconsin 15.00%
Green Bay Wisconsin 15.00%
Denver Colorado 14.75%
Washington, D.C. District of Columbia 14.50%
Portland Oregon 14.50%
Virginia Beach Virginia 14.50%
Madison Wisconsin 14.50%
Boston Massachusetts 14.45%
Worcester Massachusetts 14.45%
Cambridge Massachusetts 14.42%
Bellevue Washington 14.40%
Tucson Arizona 2.20% 14.25%
Fort Smith Arkansas 14.25%
New Orleans Louisiana 1.20% 14.20%
Rockford Illinois 14.17%
Schaumburg Illinois 14.17%
Mesa Arizona 14.02%
Mobile Alabama 14.00%
Fort Wayne Indiana 14.00%
Romulus Michigan 14.00%
Rochester Minnesota 14.00%
Grand Island Nebraska 14.00%
Kearney Nebraska 14.00%
North Platte Nebraska 14.00%
Atlantic City New Jersey 14.00%
Newark New Jersey 14.00%
Albany New York 14.00%
Rochester New York 14.00%
Lawton Oklahoma 14.00%
Pittsburgh Pennsylvania 14.00%
Columbia South Carolina 14.00%
Greenville South Carolina 14.00%

STR – Lodging Tax Study 9


City State Additional
Fees Total Tax Rate
Spokane Washington 2.00% 14.00%
Honolulu Hawaii 13.96%
Scottsdale Arizona 13.92%
Oklahoma City Oklahoma 13.88%
Buffalo New York 13.75%
Sandusky Ohio 13.75%
Norman Oklahoma 13.75%
Alexandria Virginia 0.70% 13.70%
Tulsa Oklahoma 13.52%
Bentonville Arkansas 13.50%
North Little Rock Arkansas 13.50%
Rogers Arkansas 13.50%
Reno Nevada 13.50%
Sparks Nevada 13.50%
Durham North Carolina 13.50%
Eau Claire Wisconsin 13.50%
Kailua Kona Hawaii 13.42%
Kihei Hawaii 13.42%
Lahaina Hawaii 13.42%
Waikoloa Hawaii 13.42%
Lexington Kentucky 13.40%
Minneapolis Minnesota 13.40%
Wichita Kansas 13.30%
Richmond Virginia 13.30%
Dayton Ohio 13.25%
Huntsville Alabama 1.20% 13.20%
Taos New Mexico 13.19%
Collinsville Illinois 13.17%
Rosemont Illinois 13.17%
Brookfield Wisconsin 13.10%
Kissimmee Florida 13.00%
Miami Florida 13.00%
Boise Idaho 13.00%
Idaho Falls Idaho 13.00%
Pocatello Idaho 13.00%
Cedar Rapids Iowa 13.00%
Council Bluffs Iowa 13.00%
Des Moines Iowa 13.00%
Baton Rouge Louisiana 13.00%
Grand Rapids Michigan 13.00%
Henderson Nevada 13.00%
Albuquerque New Mexico 13.00%
Saratoga Springs New York 13.00%
Syracuse New York 13.00%
Erie Pennsylvania 13.00%
Statewide Rhode Island 13.00%
Charleston West Virginia 13.00%

STR – Lodging Tax Study 10


City State Additional
Fees Total Tax Rate
Florence Kentucky 12.90%
Arlington Virginia 12.90%
Stillwater Oklahoma 12.81%
Santa Barbara California 0.80% 12.80%
Raleigh North Carolina 12.75%
Salt Lake City Utah 12.60%
Phoenix Arizona 12.57%
San Diego California 12.50%
Orlando Florida 12.50%
Canton Ohio 12.50%
Vancouver Washington 2.00% 12.40%
Pigeon Forge Tennessee 12.25%
Wisconsin Dells Wisconsin 12.25%
Bloomington Illinois 12.17%
Springfield Illinois 12.17%
Springfield Massachusetts 12.17%
Bloomington Minnesota 12.17%
Jackson Mississippi 1.10% 12.10%
Anchorage Alaska 12.00%
Juneau Alaska 12.00%
Ketchikan Alaska 12.00%
Tampa Florida 12.00%
Biloxi Mississippi 12.00%
Las Vegas Nevada 12.00%
Williamsburg Virginia 12.00%
Beckley West Virginia 12.00%
Morgantown West Virginia 12.00%
Sioux Falls South Dakota 2.30% 11.80%
Hyannis Massachusetts 11.70%
Lexington Massachusetts 11.70%
Waltham Massachusetts 11.70%
Woburn Massachusetts 11.70%
St. George Utah 11.60%
Bend Oregon 11.40%
Aspen Colorado 11.30%
Matanuska-Susitna Borough Alaska 11.00%
Sitka Alaska 11.00%
Ann Arbor Michigan 11.00%
Traverse City Michigan 11.00%
Harrisburg Pennsylvania 11.00%
Lancaster Pennsylvania 11.00%
Park City Utah 11.00%
Mitchell South Dakota 2.40% 10.90%
Rapid City South Dakota 2.00% 10.50%
Ocean City Maryland 10.50%
Custer South Dakota 10.50%
Flagstaff Arizona 10.46%

STR – Lodging Tax Study 11


City State Additional
Fees Total Tax Rate
Deadwood South Dakota 1.80% 10.30%
Colorado Springs Colorado 10.25%
Sand Point Alaska 10.00%
Wilmington Delaware 10.00%
Robinsonville Mississippi 10.00%
Laughlin Nevada 10.00%
Battleboro Vermont 10.00%
Rutland Vermont 10.00%
Cheyenne Wyoming 10.00%
Medford Oregon 10.00%
Burlington Vermont 10.00%
Killington Vermont 10.00%
Stowe Vermont 10.00%
Vail Colorado 9.80%
Great Falls Montana 2.40% 9.40%
Billings Montana 2.10% 9.10%
Hattiesburg Mississippi 9.00%
Manchester New Hampshire 9.00%
Statewide New Hampshire 9.00%
Casper Wyoming 9.00%
Bozeman Montana 1.90% 8.90%
Fairbanks Alaska 8.00%
Fairbanks North Star Borough Alaska 8.00%
Dover Delaware 8.00%
Newark Delaware 8.00%
Coeur d'Alene Idaho 8.00%
Twin Falls Idaho 8.00%
Statewide Maine 8.00%
Bismarck North Dakota 8.00%
Fargo North Dakota 8.00%
Minot North Dakota 8.00%
Jackson Wyoming 8.00%
Denali Alaska 7.00%

STR – Lodging Tax Study 12