Two views of the Wynn casino

FREDERICK SALVUCCI

Salvucci is a senior lecturer at MIT and a former state transportation secretary. He was asked by the city of Somerville to critique the casino’s transportation impact and he also advised Attorney General Maura Healey, whose views echo many of his concerns. He submitted an 11-page analysis and a three-page summary to Energy and Environmental Affairs Secretary Matthew Beaton, who must decide whether to award an environmental permit to Wynn this Friday. What follows is the summary.

I urge that EOEEA a) find the report filed by Wynn to be inadequate, and b) require the preparation of a fully comprehensive analysis using the independent and objective transportation analysis capacity of the Central Planning Transportation Staff (CTPS). Such analysis is appropriate for consideration of a state action establishing a state-sanctioned regional monopoly to operate a casino, with potentially dramatic adverse transportation impacts on local traffic at Sullivan Square, and regional traffic on 1-93.

The major flaws in the Wynn report:

The Wynn document is disingenuous in presenting a traffic analysis which relies on reversing the long-planned modification of Sullivan Square and Rutherford Avenue (now approved by the state in the recently approved TIP) and replacing it with the much more expensive retention of the underpass at Sullivan Square. Wynn does not disclose this assumption, nor present any analysis of the cost of the vastly more expensive reconstruction of the underground roadway.

The Wynn document fails to present any analysis of the adverse environmental impacts associated with the MBTA sale of land to Wynn, the potential adverse impact on the MBTA heavy maintenance facilities at Everett shops, and the failure to preserve a right of way for the long-planned Urban Ring Bus Rapid Transit (BRT) service to Chelsea and Logan Airport in this area.

The Wynn document fails to include appropriate Section 61 possible mitigations, such as: not altering the current access provisions from Alford Street, so that the Everett  Shops can remain intact; and providing at least the land, and preferably the construction, of a BRT right of way to accommodate BRT Urban Ring connectivity from Logan Airport, East Boston, and Chelsea to Sullivan Square, Lechmere, and Kendall.

Particularly significant is the lack of any consideration of a no-build alternative. From an environmental  perspective,  the  no-build  scenario  does  not threaten  regionally  damaging gridlock to regional facilities as does the Wynn proposal. Nor does it threaten to undermine ongoing smart growth initiatives such as Assembly Square, nor long standing municipal and state plans such as the conversion of Rutherford Avenue to an urban boulevard and the Urban Ring vital to the climate change policy of tripling transit mode share.  Places  such  as  Brockton  arc better situated to attracting the existing  Massachusetts  gamblers who now travel  to  Rhode  Island or Connecticut, without directly tempting so many new gamblers from the low and moderate income center of the Boston metropolitan area. The Gaming Commission and others should be disclosing that a choice needs to be made, and that there are differential environmental and economic  impacts  associated with each proposal and the choice exists to not award a gaming license.

The Wynn document does not provide any Alternatives Analysis to  recognize that an urban casino as proposed is likely to generate much more traffic  from  frequent short-term  visitors than the theoretical  “resort casino,” with  fewer visitors who stay  for longer periods  of  time.

The Wynn document does not provide any analysis of the adverse impact caused by the proposed casino on traffic flow on 1-93, one of only two interstate highways serving eastern Massachusetts, nor any proposals to mitigate such adverse regional impacts.

The Wynn document proposes monitoring traffic in Sullivan Square and charging a fine if traffic exceeds what Wynn’s published analysis predicts. But this shifts the large risk of an unmitigatable gridlock at Sullivan Square and on 1-93 to the general public, with Wynn exposed to only a small fine. This is a sort of “pay-to-pollute” approach. The Massachusetts Environmental Policy Act (MEPA) is supposed to identify risks in advance and require the proponent to mitigate them, not to burden the general public with “mistakes” made in the analysis of the proponent.

The Wynn document is deficient in not relating the impacts associated with the proposed casino, and any proposed mitigation, to the policies of the Commonwealth such as Environmental Justice, the promotion of transit oriented development, and the tripling of transit mode share required to conform to the Commonwealth climate change plan. By introducing an auto oriented-activity like the casino into an already congested area, and undermining transit expansion opportunities and smart growth opportunities in East Somerville, Charlestown, and Everett, the Wynn proposal undercuts and undermines the environmental policies of the state.

The Wynn document ignores the opportunity to increase credibility by providing an independent evaluation of the traffic impacts by the CTPS, the public agency with the capacity to incorporate all current and planned conditions on the transportation network (such as the “grounding” of McGrath Highway, the “boulevarding” of Rutherford Avenue, the extension of the Green Line, and the “calming” of O’Brien Highway at Lechmere), the Assembly  Square revitalization  with TOD densification, now underway, and similar transit-oriented planning now underway in conjunction with the Green Line extension at Union Square and Inner Belt, as well as similar initiatives in Charlestown. This analysis would inform the public and the public agencies with major responsibility such as the Gaming Commission and MassDOT, of both the impact of the casino and the effectiveness of any potential mitigation.

I urge that EOEEA require that a new document be prepared, with an objective and competent traffic impact analysis prepared by the CTPS (as recommended by the Attorney General) to property and credibly identify likely adverse impacts and potential mitigation strategies, and to support an informed public discussion of the major local and regional issues involved before making final decisions. I also urge the EOEEA to require that the decisions improperly made by the Gaming Commission and by MassDOT prior to completion of the MEPA process be set aside and reversed to the status quo until such time as a proper MEPA process is completed.

GEORGE BACHRACH, EKONGKAR SINGH KHALSA, DAN RUBEN 

Bachrach is the president of the Environmental League of Massachusetts, Khalsa is the executive director of the Mystic River Watershed Association, and Ruben is executive director of Boston Green Tourism.

We are writing pertaining to your agency’s review of environmental/energy permits for the Wynn Resort, Everett project. We do not take a position on casino gambling, per se, nor do we endorse this or any particular project, other than as they affect the environment. In that regard, there are a series of elements pertaining to environmental stewardship via the Wynn project which we find commendable.

Remediation and Site Contamination: First, and most obviously, the former Monsanto site in Everett has long been a large, contaminated, industrial site requiring substantial financial resources for remediation. The Wynn project has the resources to exceed the capping and monitoring of prior proposals and will dredge and remove contaminated soil and sediment.

Living Shoreline: Wynn has revised original plans for a sea-wall and will now restore the degraded coastal bank into a “living shoreline” along the Mystic River, including a vibrant salt marsh and native vegetation. This will be the only such shoreline in the city of Everett.

Open Space: The project’s site design sets construction away from the Mystic River allowing for six acres of vegetated open space along the river, accessible for public events and recreational use. Included will be the construction of a 20 foot wide public harborwalk for pedestrian and bike access, including easements extending the harborwalk onto two adjacent sites connecting to a OCR park.

LEED Design: The project is currently designed to meet the Gold standard under the LEED ranking system, and aspires to reach Platinum. Platinum should be the goal.

Water Conservation: The project will harvest roof runoff for use in site irrigation, using only non-potable water for irrigation of the six acres of open space. In addition, water consumption will be regulated via low flow water fixtures throughout the project.

Combined Heat and Power: The project proposes onsite cogeneration providing for 20% of the electric power needed and to supply hot water for hotel and kitchen use, substantially reducing energy needs and greenhouse gas emissions. Wynn will also include onsite solar and purchase renewable energy, and this commitment must be pushed to the highest level possible.

Transportation: This remains a challenging issue and requires additional study. Proposals by Wynn for alternative transportation are helpful. The proposed MBTA Orange line subsidy would provide partial relief, as would shuttle buses. Staggered works shifts for employees to avoid periods of congestion is helpful. Water transportation and increased bike and pedestrian access via the harborwalk, as well as the proposed pedestrian bridge across the Mystic River from Assembly Square, Somerville are positive steps. Again, more detailed traffic analysis is appropriate.

We commend Wynn Resort, Everett for their environmental stewardship and energy conservation as envisioned in the design elements referenced above. We look forward to your full environmental review.