September 10, 2014
Driggs City Council
60 North Main Street
Driggs, Idaho 83422
RE: Comments on Huntsman Springs Hotel Resort Use Exemptions
Dear City Council Members:
The decisions before you today will impact when, if ever, there will be economic investment in the Huntsman Springs portion of downtown Driggs. As you know, the original Huntsman PUD entitlement included the Huntsman Springs hotel that is platted next to the Teton County Courthouse. There was no second hotel proposed, considered or authorized by the city when the PUD plat was approved or at any later time.
Huntsman Springs now seeks conditional approval for a new hotel location far removed from the Teton County Courthouse. While the applicant seeks to style this new hotel location as a different hotel, and denies any intention to abandon the area next to the Courthouse with the now-approved hotel, if conditions are not imposed by the City upon this re-location, nothing will be done for a long, long time, if ever, to remediate blight and integrate this development with the City. The applicant’s remarks to the P&Z commissioners make clear that Huntsman Springs has no intention of building the now-approved hotel or any other improvement at the Courthouse site.
This Council’s upcoming September 16, 2014 hearing will be the first time the City will have received any substantive public comment on Huntsman Springs’ proposal for a second hotel and all of the accompanying use exemptions that Huntsman Springs requests. As new, proposed conditional uses under the Driggs code, the applicant must prove that it has met each of the requirements for a new permitted use and this Council must consider and weigh as well any adverse impacts on the City that would arise from authorizing these new uses, including the impacts from abandonment of the already-approved hotel location.
We encourage this Council to approach this incredibly complex and high-impact land use proposal with an abundance of caution and attention to detail, realizing that all decisions on this application do not need to be made (and probably should not be made) in just one evening of hearings. We also believe that appropriate conditions should have been discussed and recommended by the City of Driggs’ Planning & Zoning Commission (P&Z) at their August 13, 2014 hearing. While the P&Z acknowledged that important information was missing from the record and that the staff and Commission had not identified potential conditions that should be required if these uses were to be approved, they passed the application on. The P&Z simply needed more time and information to do its work. We encourage the City Council to consider remanding the application to P&Z for continued review.
For the City Council’s consideration, we submit the following comments regarding the Huntsman Springs hotel resort use exemption proposals:
Issue 1: Inadequately detailed and inconsistent use exemption plans.
If this Board is to consider the requested commercial use exemptions, now is the time to understand the specifics of what uses are proposed, their scale, and their impact. However, it is not possible to do so with the vague and conflicting information currently provided by the applicant. Huntsman’s July 15, 2014 narrative to accompany their conditional use exemption application provides absolutely no definition or detail as to what types of commercial uses exemptions are being requested. None of this information was defined before or at the August 13, 2014 P&Z. The Commission recommended approving all of the proposed commercial use exemptions without any definition of “commercial” or any size or use limitations despite the fact that Driggs’ staff had recommended these uses be curtailed to not avoid conflicts with the Driggs Comprehensive Plan.
In addition, the most current application materials include two conflicting sets of plans drafted by CMMI Inc., both dated August 8, 2014 which depict a wide range of sizes and impacts proposed for the commercial shopping plaza – spanning from 14,000SF to 18,500SF depending on which document you refer to. In addition, the Master Plan, dated September 3, 2014 depicts 19,000SF of commercial uses. It is impossible to properly ascertain whether any of these use exemptions meet the criteria outlined in the Driggs PUD ordinance because there is absolutely no information about what is specifically being proposed.
Issue 2: No additional commercial shopping plaza of any kind should be permitted.
The currently proposed building and architectural plans for the hotel structure contemplate all of the following accessory uses within the body of the hotel building:
- A bar/lounge
- Two restaurants
- Pool with café
- Spa with retail
- A fitness center
- Conference and event facilities.
These types of uses are reasonably incidental to a hotel if restricted in scope. However, the proposed commercial plaza (which ranges in size from 14,000-19,000SF of retail space, depending of which document you review) is clearly not incidental to a hotel and will compete with downtown businesses. This violates the the Driggs Comprehensive Plan’s goal of attracting visitors to downtown Driggs and the goal of the originally-approved Huntsman Springs plat which calls for integrating the development with Driggs core existing businesses.
If this Board approves any form of commercial shopping – whether it is a brick and mortar store or vendor stalls – the door will then be permanently opened to commercial sales that will compete with downtown businesses. This Board cannot legally require that Huntsman give local businesses an opportunity to sell onsite, and given that Huntsman is proposing a year-round multi-sport resort, this Board will find it nearly impossible to effectively limit the types of goods to be sold onsite. If the Board allows any form of commercial sales outside of a hotel gift shop, the City simply will not be able to effectively curtail the types of goods sold onsite or their future expansion.
Issue 3: Excursion Center should be an in-hotel concierge desk.
The most recent applicant submittals propose a commercial “excursion center” ranging in size from 5,166SF to 3,895SF depending on which of applicant’s latest submittals you review. Absolutely no detail is provided in the July 15, 2014 narrative to accompany their use exemption application as to what this use would be. However, at the August 13, 2014 P&Z hearing, the applicant described this center as a place where guests can book ski trip and tours and buy sporting goods. The large size of this center (it is depicted as having a footprint as large as the Key Bank Building in downtown Driggs) creates concern that Huntsman would be establishing their own outfitters in place of using local outfitters. This Board should approve only an in-house concierge desk/excursion center within the hotel to ensure that Huntsman is not trying to establish it’s own touring and sporting goods businesses. This in-house arrangement would also be much more conducive to Huntsman working with local outfitters and businesses.
Issue 4: Beautification of Huntsman property around the courthouse and a plan to integrate the development with the area of the City surrounding and adjacent to the Courthouse.
Right now, Huntsman is mothballing indefinitely their original intention of building and investing in downtown Driggs with a hotel and supporting facilities west of the County Courthouse. At the August 13, 2014 P&Z hearing, Huntsman representatives emphasized that there are no plans and no intention to do anything with the downtown hotel site in the foreseeable future. Instead, they seek to invest their resources in a different hotel site far removed from the City center. With the developer/landowner expressing no interest in developing their lots that are already zoned for hotel and commercial sites, this will effectively kill any other interest in investing in this area. This barren land which abuts Driggs’ commercial core is likely to persist as undeveloped years if not decades and must be remediated to control blight in interim. No re-located uses shold be permitted without an approved plan to provide equivalent benefits of development and integration as proposed in the now-approved plat.
Issue 5: Height exemptions establish dangerous precedents.
If this Board is seriously considering the 64ft height request for the hotel lobby, the applicant should provide visual renderings from Highway 33 and this Board should make a finding of a need-based justification for this height before issuing any kind of decision. The only justification for the 64-foot lobby that was presented at August 13, 2014 hearing, was that it was necessary for the mountain-town architectural motif. Commissioner Rick Baldwin characterized this justification as “self serving and weak,” and he was right. And yet, the P&Z recommended the height exemption for approval with no limitations or supporting documentation. If this recommendation is adopted without correcting these errors and omissions, it will set a dangerous precedent for setting aside the City’s hard-fought height regulations in the future based on little to no established need.
Issue 6: Safe public access to pathways.
We join in all of the comments outlined in Teton Valley Trails and Pathways comment letter (dated September 9, 2014). The applicant made no disclosure of these new, proposed restrictions in any of the public filings that the City identified in its Notice as comprising all of the application and its supporting materials. The north-south public trail should be contiguously platted and timely built so the public has a safe access to each of the conditional uses are completed:
- The hotel resort if it is approved in the proposed north end location
- To the Buffalo Valley condos and future Huntsman employee housing
- To 100W
- To the 2500N connection into the rail trail as originally envisioned
In addition, the Harper Avenue “city walk” should be improved to provide a safe, walk-able, well-lit and landscaped ‘promenade’ into Driggs. There must be a near-term and specific timeline for completing all of this work.
Thank you for the opportunity to submit these comments.
/S/ David Axelrod
Valley Advocates for Responsible Development
 A comparison of the artist’s rendering of the approved hotel with that of the proposed hotel shows that they are very similar. The footprint at the proposed hotel location would fit within the now-approved hotel location. No second hotel will likely be built within our lifetimes.
 At the August 13th, 2014 Driggs Planning & Zoning Commission hearing, Commissioner Rick Baldwin asked, “What is the future for the additional hotel site?” Huntsman Springs’s consultant representative from Panorama International responded: “I would say, who knows? Maybe in 10-15 years there may be a need for small boutique hotel. We’ve got 300 [rooms] on the books. I don’t know. We can’t predict that. I know the use isn’t going to be there for a long time.” August 13, 2014 Driggs Planning & Zoning Commission hearing audio tape number 2.
 At their August 13, 2014 hearing, the Driggs Planning & Zoning Commissioners noted that the following was missing from the applicant’s submissions: information on the proposed commercial use exemptions, accurate renderings showing the height of the proposed lobby, a completed pathways plan, and visual renderings of the hotel from Highway 33. They also expressed concern that absolutely no public input had been received prior to the hearing.
 As stated in the Driggs Planning Staff’s August 7, 2014 staff report regarding these uses exemptions: “the onsite commercial uses currently proposed may hamper the Comprehensive Plan’s goals of attracting visitors into downtown. The Plan encourages infill and redevelopment in the CBD of desired uses such as visitor retail (restaurants, art & craft shops, and retail stores). If these services are provided on site, it may prove to be detrimental to Main Street business and the Comprehensive Plan’s goals of maintaining a healthy retail shopping and tourist district in the downtown core. Staff recommends that any commercial services provided on site be minor in nature. The hotels services should only be available to guests and cater to their travel needs.” The Commission did not impose any conditions to protect these interests.
 Huntsman Building Plans August 8, 2014, and Huntsman Architectural Schematic Aug 8, 2014. Both were drafted by CMMI Inc.
 As stated in the Driggs Planning Staff’s August 7, 2014 staff report regarding these uses exemptions: “the onsite commercial uses currently proposed undoubtedly will hamper the Comprehensive Plan’s goals of attracting visitors into downtown.”
 The Excursion Center is 5,166 SF in the Huntsman Building Plans dated August 8, 2014. , 3,895SF in the Huntsman Architectural Schematic, also dated Aug 8, 2014. Both were drafted by CMMI Inc.
 All of the original Huntsman plats and plans depict the hotel that is presently zoned next to the Teton County Courthouse.
At the August 13th, 2014 Driggs Planning & Zoning Commission hearing, Commissioner Rick Baldwin asked, “What is the future for the additional hotel site?” Huntsman Springs’s consultant representative from Panorama International responded: “I would say, who knows? Maybe in 10-15 years there may be a need for small boutique hotel. We’ve got 300 [rooms] on the books. I don’t know. We can’t predict that. I know the use isn’t going to be there for a long time.” August 13, 2014 Driggs Planning & Zoning Commission hearing audio tape number 2.
 August 13, 2014 Driggs Planning & Zoning Commission hearing audio tape number 2.
 Ironically, such a height request would make more sense if required for the site already approved, next to the Courthouse.