The Hilton Expansion Must Follow Marco Island’s Comprehensive Plan
Rick Woodworth urges City Council to uphold Marco Island’s Comprehensive Plan as it considers the Hilton’s proposed expansion from 310 to 626 rooms, raising concerns about density limits, traffic, pedestrian safety and parking.
Rick Woodworth
10/16/20265 min read
My letter to Marco Island City Council explaining why the rezoning request from the Hilton should be denied:
Councilors,
The Hilton wants to increase from 310 hotel rooms to 626. The revised proposal tries to make that possible by declaring that hotel rooms do not count toward the City’s density limits. In my view, the City cannot set aside its Comprehensive Plan simply by changing how rooms are counted for one property. The proposal also leaves important questions about traffic, pedestrian safety, and parking unanswered. Please follow staff’s recommendation: deny the application, or postpone a decision until the applicant pursues the Comprehensive Plan Amendment that staff says is required.
I opposed this application in my September 17 letter. I am writing again because the revised Planned Unit Development (PUD) document submitted for the October 19 hearing offers a different explanation for why the additional rooms should be allowed. That explanation needs a clear answer from Council on the record.
1. Changing how rooms are counted does not change the City’s limits.
The City’s Land Development Code says that, when calculating residential density, “each guestroom shall be considered a dwelling unit.”
Section 4.3 of the revised PUD says the opposite: “for the purposes of this PUD, each hotel guestroom shall not be considered a dwelling unit.” Section 3.2.A then says the PUD overrides the Land Development Code wherever they conflict.
In plain language, the applicant wants Council to approve a special rule under which this hotel’s rooms would no longer count toward the limit of 16 dwelling units per acre in Comprehensive Plan Policy 3.1.5.
That would change the density rules for this one property through a rezoning ordinance. Section 163.3194, Florida Statutes, requires development orders to be consistent with the adopted Comprehensive Plan. A zoning ordinance cannot avoid the Plan’s limits by changing the definition used to calculate density.
2. The Plan does not allow unlimited hotel rooms.
Paragraph E of the proposal’s Statement of Consistency argues that there is “no upward limit” on hotel rooms in the Resort/Residential land use category. Its reasoning is that Policy 3.1.5 does not give hotels a separate room limit, as the commercial categories do.
That reading overlooks three parts of the Plan:
The category has a density limit. Policy 3.1.5 specifically lists “resorts, hotels, and timeshare uses,” then sets a maximum of 16 dwelling units per acre.
Hotel rooms count toward the Island’s total. Policy 3.1.1 limits the entire Island to 22,775 dwellings. Table 1 of the Future Land Use Element includes Resort/Residential hotel, motel, and timeshare units in that total. Allowing unlimited hotel rooms would undermine that Island-wide limit.
The limits are binding. Policy 1.1.1 says the Plan’s density and intensity limits are legally binding. The lack of a separate hotel-room limit in one policy does not cancel the limits elsewhere in the Plan.
Here is what those numbers mean for this property:
At 16 units per acre, the 10.4-acre site would allow approximately 167 units.
Policy 4.2.2 allows the 310 existing rooms, built in 1985, to be redeveloped.
The applicant is requesting 626 rooms, more than either figure allows.
3. The proposal offers twice as many rooms in exchange for design features. The Plan prohibits that.
Sections 4.1.A.1.a and 4.3 start with 30 rooms per acre, then allow 60 rooms per acre if the owner provides on-site parking, builds towers with a view corridor, and includes a dune system.
This is a density bonus: The owner gets more rooms in exchange for certain features. Policy 3.1.1 expressly says that “bonus densities or incentives are not allowed in any future land use category.”
The starting figure of 30 rooms per acre is already nearly twice the Plan’s limit of 16. That existing density is protected by Policy 4.2.2 because it predates the City’s incorporation. That protection allows redevelopment of the existing rooms; it does not provide a basis for doubling them.
4. Promised public improvements do not make additional density allowable.
Section 5.6 offers:
$175,000 toward traffic signal retiming.
A $500,000 maintenance escrow for the beach access next to the hotel.
Up to $60,000 for a crosswalk, if the City chooses to build one.
Median landscaping and dune work.
Parking access during declared emergencies.
Some of these improvements may benefit the public. They do not change what the Comprehensive Plan allows.
Accepting them in exchange for otherwise prohibited density would give one owner a special exception. Staff identified this concern in its findings under Section 30-62(3)(b), referring to a “special privilege to an individual real property owner.” Other beachfront owners could then ask for similar treatment.
5. The proposal still needs to answer basic traffic and parking questions.
Staff found that trips to and from the property would roughly double.
As I explained in my September 23 memorandum, the applicant’s Traffic Impact Statement leaves out two important locations:
Jolley Bridge: The study does not analyze the bridge, even though the City’s 2026 traffic counts place it near capacity.
Winterberry Drive and South Collier Boulevard: The study includes no intersection or pedestrian analysis here, even though staff identified this location as its primary safety concern.
The limit on trips in Section 5.2 does not explain how these locations would handle the traffic or how pedestrians would be protected.
Parking is another concern. Section 4.4 requires one space per guestroom, but restaurants, lounges, ballrooms, and meeting rooms would provide only 20 percent of the parking normally required by the Land Development Code.
Where would the additional vehicles park? Council should ask what this would mean for overflow parking on South Collier Boulevard and in neighboring commercial lots.
6. Council should make clear which version it is reviewing.
The proposal quoted in the staff report’s comparison table is different from the revised document submitted for this hearing.
The version in the table counted each hotel room as “less than 1 dwelling unit,” with two conditions: a 75-foot front setback and no kitchens or eating facilities in guestrooms.
The revised document removes both conditions. It also extends the 50-foot east setback from the first five floors to the first seven floors.
Please confirm on the record which version Council is considering.
What I am asking Council to do:
The central question is straightforward: Does the City’s Comprehensive Plan allow 626 rooms on this property? Declaring that hotel rooms no longer count toward density does not answer that question. Neither do promised improvements or design features.
Staff continues to find that the application conflicts with Goal 1, Objective 1.1, and Policy 1.1.1 of the Future Land Use Element. Staff says a Comprehensive Plan Amendment is the proper way to seek additional density on this site.
Please deny REZN-24-000098, or postpone a decision until the applicant pursues that amendment. The City should follow its adopted limits, and the unresolved traffic, pedestrian safety, and parking questions deserve clear answers.
Thank you for your consideration.
Respectfully,
Rick Woodworth
Marco Island Resident
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Political advertisement paid for and approved by Rick Woodworth, 2026 candidate for Marco Island City Council