Something else to consider:
Currently the conductors from the padmount are probably the property of the PoCo and being such they are most likely undersized for the building service.
As such you can't simply place a padmount ATS next to the transformer, reroute the service conductors to the ATS and provide new conductors from the ATS to the transformer since the service conductors would now be the property of the hotel. You will have to provide new 400's in each of those existing 3.5" conduits (350's wouldn't be code compliant).
