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Letter in support of P&Z’s Huntsman recommendations

December 26, 2014

Driggs City Council

60 Main Street

Driggs, Idaho 83422

RE: Request for City Council to uphold the Driggs Planning & Zoning Commission Recommendations

Dear City Council Members:

The Driggs Community Development staff report for the Panorama International resort asks this Board to overturn the recommendations of the Driggs Planning & Zoning Commission (P&Z). The P&Z carefully crafted their recommendations after holding two public hearings to specifically consider staff expertise and public comment on appropriate square footage and uses.

Instead of estimates, look to the already existing resorts in the region and consider established public policy that speaks to economic development.

We appreciate the city staff’s efforts to assess the amount of retail that can be borne by projected hotel occupancies, however we are not convinced that the theoretical conclusions found therein are a justifiable basis for overturning the P&Z’s recommendations. Moreover, we feel strongly that any report that speaks to retail development outside of the downtown core should at least acknowledge Teton Valley Economic Development Plan prepared in 2013 (which we address later in this letter). It should be explained how the Panorama proposal is consistent with the strategies put forth in the Economic Development Plan. It may also be prudent to explain how the proposal and its associated Comprehensive Plan amendments comport with the economic development objectives in the existing City of Driggs Comprehensive Plan.

At this juncture, we feel that the retail issue is best informed by a comparison of resorts in peer communities throughout the region. In order to project how much onsite retail a hotel at the Panorama site can support, the Community Development report relies on estimates of guests per room, and predictions of occupancy trends and daily spending based on resorts as far away as Peru. We are compelled by the fact no other resort in the region contains the ratio of retail to lodging uses proposed, a situation that arguably can be attributed to the “real-world” experience of established resort hotels and their associated retail capacity. We urge the Council to consider the data we have collected as well as the P&Z’s findings when presented with the totality of analyses put forth by the public and the Community Development Staff.

Revised Summary

As shown in the chart above (See the full report here), the amount of food and retail proposed in Huntsman plan far exceeds any other resort of similar size and type in the region.  In fact, Sun Valley Lodge was the only other non-ski resort to even have a retail shopping plaza at all – and that resort is 77 years old with over 4 times the lodging units of Huntsman Springs.  Considering that Sun Valley is also 4-season resort located a mile from town, it is probably the most similar to the Huntsman resort. To have an amount of retail in the Huntsman resort that is proportionately comparable to Sun Valley would be 2,900SF.

The Panorama commercial plaza may be in conflict with existing economic development policy, specifically the Teton Valley Economic Development Plan, the City of Driggs Comprehensive Plan, and the Teton County Comprehensive Plan.

The City of Driggs should be applauded for its contribution to and embrace of the visionary plans that establish economic development goals and strategies in the city and surrounding community. The applicable goals, objectives, and actions/strategies are summarized as follows:

Teton Valley Economic Development Plan. The emphasis of this plan is to support existing businesses and facilitate their expansion and/or transition. Most importantly, the Plan highlights the importance of nurturing the downtown area. Filling vacant retail spaces and promoting infill development is prioritized over new and possibly duplicative development at the city’s edge. The plan finds that “existing vacancies create an atmosphere of disrepair and impede the critical mass necessary to attract visitors and shoppers.” Before the 6,000-10,000 SF of retail is permitted at the proposed location, we would recommend the City accomplish the goal of a vibrant downtown envisioned in the Plan, particularly the “10-10-10” benchmark mentioned in the Community Development Director’s report. We would also note that when presented with the question of how to implement economic development goals, the Plan strongly recommends coordination with all stakeholder organizations, particularly groups like the Teton Valley Foundation, the Teton Arts Council, and the Downtown Driggs Community Association. VARD has repeatedly expressed a willingness to support the city in bringing these groups together for coordinated input, however we have found that the City’s breakneck pace provides little opportunity to facilitate coordination.

Driggs Comprehensive Plan. The goals, objectives, and policies of the Economic Development Section of Driggs’ Comprehensive Plan are strikingly similar to those in the Teton Valley Economic Development Plan. With an intense focus on encouraging retail and infill development within the existing downtown core, the plan, from an economic development perspective, seems to be silent on the appropriate policy for retail development at the city’s edge (other than public survey results finding commercial sprawl to be undesirable). Overall, the Economic Development section of the City’s Comp Plan does not contemplate retail at the Panorama site. We recommend that, at the very least, the Economic Development section is addressed with the Comprehensive Plan amendments currently under review so that the data from the 2013 Economic Development Plan and the 2012 County Comprehensive Plan is included.

Teton County Comprehensive Plan. The 2012 County Comprehensive Plan was initiated with unprecedented public outreach from all county residents (including those within Driggs city limits and AOI), and was crafted in an equally unprecedented effort to coordinate policy recommendations with the cities. First and foremost with regard to economic development, the plan recommends a coordinated economic development strategy that promotes infill within the core of the cities in order to preserve the rural character of the county. The Teton Valley Economic Development Plan is a product of this effort. In the beginning of the development code work undertaken by the County to implement its Comprehensive Plan, the County Planning & Zoning Commission received impassioned testimony from current Driggs Mayor Hyrum Smith noting the importance of city/county cooperation. We were certainly impressed by the Mayor’s comments and we hope that the City will, in the course of its planning and economic development pursuits, pay heed to the values expressed by the city’s representatives.

It is now incumbent on the city to implement these strategies and ensure that all planning & zoning decisions – particularly discretionary requests – fulfill identified strategies and exemplify the incremental, deliberate steps needed to achieve economic goals. Sometimes this requires making tough choices. Though Panorama has expressed a clear desire for 10,000 SF of retail space outside of the downtown area, the City of Driggs must decide if it is worth going off-course with respect to prescribed policy recommendations for which considerable public time and resources have been invested.

Limiting the square footage of the Huntsman commercial plaza is your only tool.

After studying how these other higher end resorts function in relation to their surrounding communities, there appears to be the real possibility that the Panorama resort will syphon existing local customers away from downtown with the allure of a brief retreat into luxury.  None of these other high-end resorts shun local customers  – in fact they try to attract locals by offering specials on events, spa treatments, brunches, and dinners.  The City of Driggs cannot police what promotions are offered by the Panorama resort to prevent them from courting local Driggs customers.

We also caution against relying upon an applicant’s stated business model to make long-term planning decisions. The Community Development Director’s Report assumes that the hotel will always be a 5-star luxury resort that will cater to a very specific market. As we know, conditions in the mountain resort lodging industry are always in flux, and the specifics of a particular business model may be fleeting. We do not wish to hold Panorama to a specific business model, and in turn, we feel that the applicant cannot expect the City to make such a monumental decision based on the specific business model presented at this particular time. We do not doubt that Panorama is putting forth its true intent with regard its 5-star business plan catering to specific guests. However, our observation of lodging enterprises in the region – particularly Jackson Hole – is that the best laid business plans are often subject to future modification, and that retail capacity based on a particular occupancy rate, guests per unit, projected retail spending per guest, and other theoretical intricacies are susceptible to such modifications.

Restricting onsite parking to guests only or building barriers across the road are not tactics employed by any of these other resorts. These resorts are still trying to attract (not shun) local customers to help round out the peaks and valleys of their business cycle. They depend on a certain amount of local traffic to keep them profitable. Moreover, segregated retail clusters in a city of 1,700 is not a concept embraced in the Driggs Comprehensive Plan and the Teton Valley Economic Development Plan, nor is it consistent with best practices in town planning. Concentrating retail in the downtown core is tried-and-true planning model for many good reasons, not least of which is the ability of concentrated commercial uses to remain fluid and adapt to changing economic conditions.

While the Community Development staff report predicts that Huntsman hotel guests will eventually leave the resort to shop in downtown Driggs, vastly more restaurants and retail are proposed at this tiny lodge than almost any other similar resort in the region. And to date, there is no secured agreement guaranteeing a regular shuttle system to bring these hotel guests into downtown Driggs.  Also, please be reminded that the City cannot require that retail and hotel become a five-star establishment.

The Planning & Zoning Commission already considered all these factors and properly concluded that the only viable tool to truly promote infill and discourage “drainage” from downtown Driggs was to limit the square footage of the commercial plaza itself.

The City’s huge volume of public comment also opposes a large commercial plaza

We are not in opposition to the resort itself, but are strongly in opposition to a large shopping plaza as detrimental to the future of downtown Driggs.  The public has clearly voiced a similar sentiment: 70% of our 120 public survey respondents expressed outright opposition or concern with this shopping plaza. It was also a common theme in the 38 public comment letters submitted to the city to-date. (See all survey responses here). We encourage you to seriously consider these comments and resist any advice to discount or dismiss the views expressed.

Chasing sales and/or property tax revenue is not sound planning.

We understand that small communities such as ours often lack resources, and that the prospect of a tax windfall is hard to resist. However, virtually every bad planning decision in postwar North America can be attributed, at least in part, to communities seeking rapid, short-term gains in additional tax revenue. Rejection of this “sprawl-for-cash” growth model represents a growing consensus in the planning community, and movements such as Smart Growth and Strong Towns have formed largely as a response to this practice. The environmental and social detriments are well-known, however, it has become increasingly apparent that these types of tax windfalls usually have diminishing financial returns, and that more often than not, cities over the long term find themselves burdened with the financial costs of maintaining the infrastructure necessary to support dispersed retail development.


We encourage the city to follow its own already-established growth and economic development plans and follow the P&Z’s recommendation to exercise restraint in approving new retail space at the Panorama site. We believe that staying the course on such plans is the best medicine for economic development and the best way to ensure that the community goals of Driggs and Teton Valley are fulfilled. VARD strives to be a partner in community and economic development, however we, as a fact-based organization, are committed to ensuring that civic action is aligned with established community plans and policies. Such plans and policies have come about through robust public participation, engagement of industry experts, and at the expenditure of significant community resources.

We thank you for your time and consideration and for your commitment to serving the interest of this community. Our comments are a sincere attempt to provide the City with the information needed to make an informed decision. To that end, please let us know if we can be of service for this or any other matter.



Shawn Hill, AICP

Executive Director

Valley Advocates for Responsible Development


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