City relents and releases JLL site analysis, it does NOT rank FNP site #1 as claimed in submission to HPC

The City has relented and released the Jones Lang LaSalle (JLL) site analysis of 2013. The eight page document is titled Downtown Hotel and Meeting Space Site Analysis and consists of illustrations and notes in spreadsheet form. The Jones Lang LaSalle logo is in the top right corner of each page and the file is dated June 17, 2013.

Contrary to claims made by hotel proponents, including material submitted to the HPC, nothing indicates that the chosen Frederick News-Post  (FNP) site was ranked highest by the City’s lead hotel consultant. The JLL analysis does no ranking. It describes plusses and minuses of all the sites.

The JLL analysis points up problems with the chosen FNP site, in particular integrating the Birely Tannery building into the complex.

“Adaptive reuse of the tannery building will constrain optimal building design & configuration,” one JLL point states.

On the Birely Tannery building they state: “Masonry structure likely to be solid, interior has been compromised by fire and water damage… Further studies needed to fully evaluate physical condition.”

On demolition of the Birely Tannery JLL’s advice was clear: approvals to demolish “would likely be difficult to obtain…”

Low ceiling heights may limit its usability.

JLL’s analysis poses the question: “Would this site fall under archeological regulations?” without suggesting an answer.

JLL refer to the FNP site as being of “adequate size” but having no scope for future expansion. And JLL assume that the site for the hotel comprises three lots: 200 and 214 East Patrick (the two Randall family properties of 0.9 and 1.63 acres) and also 212 East Patrick — namely the Eagles parking lot — of 0.26 acres. As of now the site constitutes only the Randall’s 2.53 acres rather than the 2.79 acres JLL assumes.

“Inclusion of the Eagles site will help” alleviate the site size issue, a JLL note says.

Awkward to access

The consultants foresaw access and visibility problems at the FNP site. The site will only be accessed from Carroll Street, they say, but arriving visitors have to travel via Patrick. They say there may be “some visibility” if no high buildings are developed between East St and the hotel but were concerned at visitors missing their turn: “…If turn onto E Patrick is missed, long drive back to (hotel) site due to one way streets.”

On environmental contamination JLL say the tannery site “may have mercury due to previous tannery use” and that like other Carroll Creek properties it probably has some arsenic. The report says remediation involves “encapsulating with impervious surface (i.e. a sidewalk) or 1 foot of clean fill.” Removed fill they say cannot typically be reused but must be carted away to a special facility.

Planning and zoning issues are alluded to: “OPX site studies assumed a 5 story building. Office of planning will likely allow no more than 3.”

On car parking JLL say that the City parking garage on All Saints Street “can accommodate additional event parking needs.”

Geotechnical studies may be needed, JLL says, to assess the cost implications of building on the FNP site. JLL does state that the FNP site construction cost may not be unusual for the downtown where outcrops of bedrock commonly require blasting.

Advantages of the FNP site mentioned by JLL include:

— its short distance to the heart of the downtown, 0.2 miles to the Market/Patrick intersection.

— an active street scene giving it character

— retail nearby

— frontage to the Carroll Creek Linear Park

Opposition to the hotel at this site by the Frederick Preservation Trust is noted under the heading Stakeholder Feedback.

Most positive sounding about the PO site

JLL’s analysis sounds most positive about the Post Office site. This site at 3.06 acres is seen as large with an additional 0.77 acres of parking lot on the southside of Patrick. High visibility is cited as an asset.

The PO site is without any known soil contamination, no historic issues, and good access and visibility for visitors. It is the same 0.2 miles to the Square Corner and a “prominent gateway site, active street.”

Rezoning will be needed but the planning department told JLL this would be just a “formality.”

Two problems were cited:

— neighbor opposition, literally not-in-my-backyard protest based on intrusion on privacy and noise and light generated by the hotel for houses backing up to the site from East Church St

— USPS failed to respond to RFI (request for information) and need to relocate the post office which could make site acquisition costly and lengthy

Galleria site of Wormald’s at 107 S East St

JLL describe the 1.7 acre Galleria site across the creek from the FNP lot as “tight but workable.” It is said to have similar hazmat issues as other creek sites and because of likely karst limestone would require deep foundations or mini-piles. Adjacency to the City’s East All Saints parking deck is cited as an advantage with Wormald already having rights to 170 spaces.

On-site parking would need to be in the basement of the hotel on the Galleria site or deck parking on the MacRo site at 111 S East St.

High visibility for visitors and good access off East Street are advantages. Walking distance is 0.3 miles to the Square Corner. The site has less active street life than the PO and FNP sites but good frontage to the ‘active’ Carroll Creek park.

Plus Wormald wanted a higher price for the Galleria than the Randalls wanted for the FNP site.

JLL wondered if the Galleria site could be acquired from Wormald in a negotiated exchange with city-owned land on E Patrick.

Senator Young advocated FNP, Galleria, brickworks sites

Senator Ron Young told JLL that the Galleria and FNP sites were the best, but he is also quoted as saying he likes the brickworks site southeast of South and East Streets’ intersection and that it “will be the fastest to build on.”

The brickworks site at 0.6 miles to Market and Patrick is 65 acres and only a tiny fraction (3 acres or so) would be needed for the hotel. JLL see lack of any approved masterplan for the site as a hindrance.

Other sites looked at include:

— Bean Factory south side of Commerce St, much too small except in conjunction with MacRo site on the north side, and even then at 1.8 acres “difficult to accommodate desired program”

— the City owned land adjacent to the MARC station (1 acre too small, difficult access)

— Potomac Edison site at 421 E Patrick, 0.5 miles out is plenty big enough at 14 acres, but hazmat PCBs need study

— 500 to 510 Highland St 0.6 miles out is large enough but much is in a flood plain

— Goodwill site 400 E Church but historic character may, JLL says, raise preservation issues even though it is not within the historic district

— three sites in the 300-block of E Patrick (east of East St) are all rejected as “too small” and “difficult to fit desired program” (200 rooms, 24k meeting space etc.)

— Carmack Jay site on N Market, too small, difficult access for visitors, odd shaped lot


In the materials submitted by the co-applicants to the Historic Preservation Commission in support of the case for demolition of the Birely Tannery building (HPC17-490) was a four page Memorandum on Bates Architects letterhead dated June 15, 2017, signed Jim and addressed to HPC staffer Lisa Murphy. ‘Jim’ is Jim Mills and the City says Bates Architects were hired by Plamondon, the hotel developer to write that summary of the case for demolition.

On page 2 of the Bates memorandum there is this:

“Each of the sites was evaluated by the consultant architect OPX as part of the initial market demand study to be appropriately sized to accommodate a 200-room full-service hotel and 15,000 to 20,000 square feet of meeting space. JLL also conducted a comprehensive criterion based analysis of the sites.


— Catalyst for Downtown growth and revitalization;

— Developer feedback (site preferences based onJLL interviews);

— Ease of acquisition;

— Site size (to accommodate hotel program);

— Overall developability.

“Using these criteria, the subject site was ranked the highest of the four sites that were identified (Downtown Post Office property, Old Frederick News-Post property, Douglas Development McHenry’s/Union Mills property.)”

OPX’s analysis of potential sites is contained in a section Site Analysis and Proposed Building Layouts pages 63 to 73 of the 2010 study ‘Market Analysis, Cash Flow Projections, and Strategic Recommendations for a Proposed Downtown Hotel and Conference Center” by Pinnacle Advisory Group and OPX downloadable from the City website at

It analyses six sites and has a Site Attribute Comparison chart on page 63. Also it shows three hotel/conference center layouts for the Frederick News-Post site (pages 67, 68 & 69) the last of the three allowing for preservation of the Birely Tannery building. It does this by building a conference center and parking in a north-south structure fronting Patrick St, parallel to and between the Terminal Building and the Eagles (where two parallel, 2-way driveways are proposed by Fillat Architects.)

The OPX analysis of 2010 does NOT rate the Frederick News-Post site the highest as suggested by the Bates Architecture memorandum. It states: “After considering the pros and cons of each site, we believe that Sites U,  V, and W (U=USPS, V=FNP, W=Galleria) are more desirable for development than Sites X, Y, and Z. (X=MARC, Y=Con Ed, Z=Brickworks).” (my labels in parentheses)

So what about the JLL site analysis, we wondered. Does that rank the chosen site #1?

We filed a Public Information  Act request for the site analysis being cited by the architects in the HPC submission.

Aug 14 Saundra Nickols the City Attorney responded (letter dated 8/9) with a refusal, invoking a ‘deliberative process’ privilege. I protested immediately and asked for reconsideration. Today Aug 23 the City Attorney wrote: “Pursuant to your request, the City has conducted a further review and determined that the document is releasable with the exception of ….” There follows reference to Acquisition Notes and Price per RFI responses on the basis respondents were guaranteed confidentiality.

Copy of JLL site analysis June 2013 as just released by the City:


below copy of letter from City Attorney on reconsideration of withholding the report:

P Sam 2017.08.23

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