Cold Spring Ranch Area Plan Amendment

Opposition to Proposed Area Plan Amendment
Cold Spring Ranch – Short-Term Rentals
Summary Position
I respectfully oppose the proposed Area Plan Amendment permitting short-term rentals (STRs) in Cold Spring Ranch (CSR). The amendment is inconsistent with the Cold Spring Ranch Area Plan,
incompatible with existing infrastructure, and procedurally premature. It would function as de facto spot planning by benefiting a limited subset of properties while imposing adverse impacts on the broader community. STRs are not currently permitted in similarly situated master-planned residential communities in Lehi, including Holbrook Farms and Traverse Mountain.

Existing Conditions and Community Design
Cold Spring Ranch was approved and constructed as a high-density residential community that does not support STR use. The community consists of approximately 1,077 residential units. Of these, approximately 647 are townhomes and approximately 242 are single-family homes located on private HOA-maintained roads that are only 24 feet in width. In total, approximately 86% of all units in Cold Spring Ranch are located on 24-foot-wide private roads where on-street parking is prohibited.
Only approximately 25 homes within the entire community have addresses on public streets. Not all of these public streets allow on-street parking, and those that do provide limited capacity. As a result, even homes located on public streets generally lack meaningful ability to accommodate additional guest parking associated with STR use.

Parking and Infrastructure Constraints
Cold Spring Ranch contains approximately 167 shared parking stalls, equating to roughly one stall for every six homes. At the time the community was approved, parking standards for high-density
residential development were materially different. In 2022, after Cold Spring Ranch was built and
occupied, the City of Lehi updated its parking requirements for high-density multifamily developments. Under current standards, comparable developments generally require approximately one parking space per 2.5 units, which would have resulted in substantially more parking being required if Cold Spring Ranch were designed today.
As a result, Cold Spring Ranch is fundamentally under-parked relative to today’s standards through no fault of the residents or HOA. Introducing STRs into a community already acknowledged as
parking-constrained would exacerbate existing limitations and conflicts.

HOA Governance and Enforcement Limitations
The HOA governing documents expressly rely on the Cold Spring Ranch Area Plan as a controlling
land-use document. The Area Plan currently prohibits STRs, and the HOA has relied on that prohibition in structuring its governance, enforcement mechanisms, and resident expectations. There is no clear or practical mechanism for the HOA to identify non-compliant STRs, as online STR listings commonly obscure the front of homes and identifying characteristics. If STRs were permitted, the HOA would be forced to rely primarily on self-reporting by STR operators.
Several STRs are already operating without approval and are currently being fined by the HOA;
however, some operators have chosen to treat those fines as a cost of doing business and continue
operating in defiance of both HOA and City regulations.

Parking, Traffic, and Neighborhood Impacts
Multiple studies have found that STR use increases traffic volume, parking demand, and neighborhood disruption relative to long-term residential occupancy, particularly in high-density residential areas.
Research by the Urban Institute and RAND Corporation has documented increased vehicle trips,
higher guest turnover, and greater enforcement challenges associated with STR concentrations. These impacts are most acute in neighborhoods with limited on-site parking and narrow streets.
In Cold Spring Ranch, where the majority of homes are located on 24-foot-wide private roads,
additional traffic, loading activity, and guest parking cannot be safely or legally accommodated. Illegal parking, towing, and neighborhood conflict are already occurring near known non-compliant STRs and would be expected to increase if STRs were formally allowed.

Consistency with the Area Plan
The proposed amendment introduces commercial lodging activity into residential zones, reduces
long-term housing availability, and shifts enforcement and infrastructure burdens to residents and the HOA. These impacts are inconsistent with the Area Plan’s stated goals and design assumptions and do not advance adaptive housing needs. A detailed analysis of these inconsistencies is provided in Exhibit A.

Notably, City Planning staff has already identified this lack of alignment. In the Development Review
Committee Redline Comments dated December 10, 2025, Kim (Planning) stated: “In the narrative,
some of the statements are not related to the stated goals in the Cold Spring Ranch Area Plan.”

Conclusion and Recommendation
This Area Plan Amendment is incompatible with the design, infrastructure, and governance of Cold
Spring Ranch. It would legitimize existing illegal activity, incentivize continued non-compliance, and
impose disproportionate impacts on a community already constrained by private roads and limited
parking. Most importantly, allowing STRs in this context would appear to constitute de facto spot
planning, benefiting a limited subset of properties while remaining infeasible for the vast majority of
homes within the Area Plan. If the Planning Commission elects to recommend any amendment to the
City Council, the only area of Cold Spring Ranch where STR use could plausibly be considered is Land Use District LD #1, and any amendment should be
explicitly limited to that land-use designation only.

Exhibit A – Findings of Inconsistency
Cold Spring Ranch Area Plan Narrative vs. Proposed STR Amendment
Finding 1 – Residential Purpose:
The Cold Spring Ranch Area Plan establishes the area as a long-term residential community focused on stability, family living, and predictable residential activity. Short-term rentals function as transient lodging rather than permanent housing and are inconsistent with this purpose.
Finding 2 – Land-Use Separation:
The Area Plan relies on separation between residential uses and commercial or visitor-oriented uses.
Allowing short-term rentals introduces a commercial lodging use into residential zones, contrary to the adopted land-use framework.
Finding 3 – Intensity and Infrastructure Assumptions:
The Area Plan anticipates long-term residential demand within a higher-density community served by private streets and limited parking. Short-term rentals increase use intensity and turnover beyond what the Plan contemplates.
Finding 4 – Residential Character:
Residential character is defined by use and occupancy stability, not building form alone. Transient
occupancy inherent to short-term rentals conflicts with neighborhood compatibility and predictability goals.
Finding 5 – Misapplication of Flexibility:
Flexibility in the Area Plan relates to housing form and design, not conversion of residential housing into transient lodging. Short-term rentals are not identified as a housing need in the Plan.
Finding 6 – Staff Acknowledgment:
In the Development Review Committee Redline Comments dated December 10, 2025, Kim (Planning) noted that some statements in the proposed amendment narrative are not related to the stated goals of the Cold Spring Ranch Area Plan.
Finding 7 – De Facto Spot Planning:
Because the amendment redefines residential use and benefits only a limited subset of properties while remaining incompatible with the majority, it would appear to constitute de facto spot planning rather than a generally applicable implementation of the Area Plan.
Conclusion:
The proposed short-term rental amendment is inconsistent with the Cold Spring Ranch Area Plan
narrative and does not materially advance the Plan’s adopted goals under Utah land-use standards.

Please don't approve this Amendment.

We are opposed to this proposed amendment.

My family has lived in Cold Spring Ranch for nearly four years. At the time of purchase, DR Horton represented that short-term rentals (STRs) would not be permitted and that the community was intended to be a stable, long-term residential neighborhood—not an investor-driven development. That understanding was a material factor in our decision to purchase our home.

We are currently experiencing a significant housing shortage, and allowing STRs would further reduce the supply of long-term housing by removing homes from residential use.

Additionally, existing enforcement efforts have already proven insufficient. Illegal STRs are currently operating within the community, and neither the HOA, its management company, nor the City has demonstrated the capacity to effectively regulate or control them. Expanding allowance for STRs under these circumstances would compound an already unresolved enforcement problem.

Proponents of this amendment argue that STRs should be permitted for “responsible homeowners.” However, the homeowners advancing this proposal purchased their properties subject to recorded CC&Rs that clearly prohibit STRs. When you look on Airbnb.com and these STRs CURRENTLY being rented even though the homeowner knows it's illegal, that's hardly responsible behavior. Those restrictions are a defining feature of why Cold Spring Ranch is a desirable place to live. Altering them after the fact undermines reasonable expectations relied upon by the majority of residents.

Furthermore, Lehi City already permitted DR Horton to walk away from park and open-space improvements that were promised as part of the original development. As a result, the community has been left with unfinished, underutilized and frankly weed ridden wasted public areas. Allowing STRs would further erode the original vision and exacerbate the impacts of those prior concessions.

The existing Area Plan is consistent with comparable master-planned communities, including Holbrook Farms, where STRs are likewise prohibited. Bans on STRs in master-planned residential communities are neither novel nor unusual.

This amendment would disproportionately benefit a small number of owners at the expense of the more than 1,000 residents who live here full-time, dare I say creating De Facto Spot Planning. For these reasons, the CSR Area Plan Amendment should be denied by the Planning Commission and the City Council.

My husband and i moved into the community three and half years ago. We were told it was going to a nice family home community. Instead it has turned into a nightmare. Homeowners that rent out and don’t manage their renters. One unit is already run like a AirBNB with a chop shop on the side. Because of that cars are parked on the road where the sign clearly states “no parking”. Garbage cans are overflowing. It looks like a dump!! We didn’t buy and move here for this!! Advantage management, the HOA, need to monitor things better I feel. And to allow AirBNB in our community will turn the neighborhoods into garbage!!! I already see it across the street from where we live. Please, if you have any decency or empathy for home owners do not allow this to happen!

My name is Raquel Corbett. As a young homeowner who is married and raising young children in Cold Spring Ranch, I strongly oppose allowing short-term rentals (Airbnbs) within all residential areas of this development.

We chose to buy a home here specifically because it is a family-oriented neighborhood designed for long-term residents, stability, and community. Allowing short-term rentals throughout residential areas would fundamentally change the character of our neighborhood. A rotating population of short-term guests does not foster the sense of trust, safety, and connection that families with young children depend on.

Short-term rentals bring increased traffic, noise, and parking issues, which directly impact day-to-day family life. As parents, it is important for us to know our neighbors, feel confident about who is coming and going, and provide a safe environment where our children can play outside and walk the neighborhood without constant uncertainty.

Additionally, there is no evidence that short-term rentals meaningfully improve housing affordability for families. In practice, they often reduce the supply of long-term housing by incentivizing investors to purchase homes for short-term profit rather than owner-occupancy. This drives up home prices and rents, making it harder—not easier—for young families to afford to live here.

Cold Spring Ranch was planned and marketed as a residential community, not a transient lodging area. Allowing STRs in all residential zones undermines that original vision and places the burden of tourism and investment activity directly onto families who have made long-term commitments to this neighborhood.

We respectfully urge decision-makers to reject this proposal and protect Cold Spring Ranch as a stable, family-centered community where homeowners can raise their children with confidence and peace of mind.

I live in Cold Spring Ranch & am requesting the planning commission deny the proposed amendment.

The current area plan already makes a clear decision about short-term rentals. It allows them in commercial areas and not in residential zones. That was a deliberate choice and it matches the plan’s focus on residents, families, and housing for people living in the community at different stages of life (rather than serving visitors and lodging uses).

The plan was recently amended by DR Horton in 2022, a time when short-term rentals were already common and well understood. Their continued exclusion from residential areas shows that this was a conscious policy decision, not something that was overlooked or outdated. Changing a recently amended plan should require a clear reason, such as a change in conditions or a new public need—and none has been shown here. Area plans exist to give residents and the city a predictable set of rules; amending the plan solely because enforcement has increased undermines that predictability and sends the wrong message about the purpose of adopted plans.

One of the main organizing principles of our area plan is a clear progression of land uses, starting with commercial areas and moving to higher-density residential, and then lower-density neighborhoods. Allowing short-term rentals in residential zones cuts across that structure and introduces lodging use into areas that were planned specifically for long term residential living.

The proposed amendment also does not explain where this change would stop. If short term rentals are allowed in our residential areas, it’s unclear why they would not also be allowed in other residential neighborhoods governed by adopted area plans. Approving this amendment would set a precedent, making it harder for other communities to rely on their residential land-use boundaries.

The physical design of the community reinforces my concerns. Many homes are on narrow private streets, with shared infrastructure and amenities that were designed around predictable, resident use. Short term rentals bring frequent guest turnover, visitor parking, and access demands that were not part of the original residential design assumptions when the plan was approved.

The plan also places strong emphasis on amenities intended specifically for community residents, including a privately maintained clubhouse, pool, and linear park. These facilities were planned, sized, and funded with the expectation that they would serve people who live in the neighborhood, not a rotating group of short-term guests.

Finally, once short-term rentals are allowed in residential areas, they tend to expand over time and are difficult to reverse. Other area plans in the city continue to draw clear distinctions between residential neighborhoods and lodging uses and there is no clear planning reason for our community to be treated differently.

I live in and own a townhome in the Cold Spring Ranch community, and I have concerns with the proposal to allow short-term rentals.
I do not understand how reducing the supply of long-term rental housing is expected to improve affordability. In other parts of Utah, including southern Utah, short-term rentals have contributed to increased housing costs by removing homes from the long-term market. Driving prices higher is not beneficial for residents or first-time homebuyers, which this neighborhood attracts. Short-term rentals tie up existing housing stock rather than expanding it.
Short-term rentals also tend to increase noise, parking demand, and wear on common areas. Communities across the state have documented issues with party houses and damage to shared property. Our neighborhood already experiences challenges with maintaining common areas, and cycling new occupants every few days would likely exacerbate these problems.
The primary benefit of short-term rentals appears to be an increase in lodging capacity. If additional lodging is needed, I believe that goal would be better addressed through appropriate zoning for hotels or similar uses in commercial areas, rather than converting residential neighborhoods into de facto hotel zones.
I respectfully ask the Planning Commission to consider these impacts and not recommend policies that fundamentally change the character of established residential neighborhoods.

-Andrew Gill

I own a townhome in the Cold Springs Ranch Subdivision of Lehi. I rent it long term to a cute family. The HOA has been transferred to Home Owner management vs the builder run HOA. There have been many concerns raised by the HOA about renters not having all the information needed to keep up common property, parking restrictions, pool clubhouse rules, etc. The homeowners have agreed to make sure info gets to their tenants so that the HOA did not enact a monthly fee to landlord homeowners (would have been grossly unfair). However, knowing that the HOA is already quite worried about rental properties, I think allowing short term rentals would compound the problems they are worried about (parking, pool usage, vandalism, etc). In addition, I personally don’t like the idea because of the same issues and I want the property to stay nice for my tenants (and my property value). The claim in the proposal that STRs would help housing affordability while preserving neighborhood character seem opposite of what would actually be the case. I could see maybe allowing a 30 day rental for people who have to be in between other houses while they sell one to afford another one? But STRs themselves don’t make housing more affordable and having people who don’t know the rules coming and going on a rotating basis would not add to the character of the neighborhood in my opinion. I am opposed to seeing short term rentals at CSRanch. Thank you!