From Mass Audubon:
Advocacy Department
Six Beacon Street, Suite 1025
Boston, Massachusetts 02108
tel 617.962.5187 fax 617.523.4183
email jclarke@massaudubon.org
June 11, 2012
Thomas C. Hoye, Jr.,
Mayor City of Taunton
141 Oak Street Taunton, MA 02780
Dear Mayor Hoye:
As the City of Taunton begins the initial review of a proposed casino on 146 acres of land adjacent to Routes 24 and 140, Mass Audubon encourages you to consider the environmental impacts and opportunities of such development and require that all City permits, licenses and authorizations use sustainable development and energy efficiency techniques in the construction and operation of a casino at this site.
As you know, casino development will have significant impacts on our environment.
Project First Light, the destination resort casino proposed by the Mashpee Wampanoag Tribe, will include at full build-out: a 150,000 square foot casino, two 300-room hotels, several restaurants, retail stores, an event center, an indoor/outdoor water park, and parking facilities that may accommodate up to 5,900 cars.
In last year’s gaming law (Chapter 194 of the Acts of 2011), Bay State lawmakers endowed the Gaming Commission with broad powers to vet casino proposals, select up to three winning bids, and award licenses.
The Commission will oversee building and development, police long-term obedience to gambling laws, and ensure compliance with public health and safety rules.
The environment should not be an afterthought in this consideration. To win in this high-stakes game, bidders must demonstrate how they will meet a variety of mandatory and optional qualifying criteria.
Among those criteria is the option to build green.
It is Mass Audubon’s position that this should not be an option but a requirement.
To further this recommendation, we believe that local officials will have considerable influence over appropriate and applicable municipal permitting of casino development.
Following a recent meeting with the Gaming Commission regarding our proposal for green casinos, we were encouraged to also work at the local permitting level to advance this permitting standard.
The Commonwealth of Massachusetts has committed via The Massachusetts Global Warming Solutions Act (Chapter 298 of the Acts of 2008) to address climate change through mandated greenhouse gas emission reductions.
We have encouraged the Commission to keep casino development in synch with the Commonwealth’s climate change goals.
Recently, the American 2 Council for an Energy-Efficient Economy recognized Massachusetts as the number-one state in the nation for its leadership in energy-efficiency policies and programs in the residential, commercial, industrial, and transportation sectors. Massachusetts casino developments should further advance this progress.
Optional licensing criteria for the awarding of casino licenses by the Gaming Commission are as follows: Environmental impact studies – We have recommended that these be thoroughly prepared under the existing Massachusetts Environmental Policy Act (MEPA) to ensure completeness, transparency, and public review to benefit the City, its residents and the Commonwealth as a whole.
Sustainable development principles – Licenses and City approvals should advance the already well-established smart-growth policies of the Commonwealth regarding energy and environment; housing and economic development; and transportation.
Water Conservation – State licenses and City approvals should set a cap on gallons per day of water that can be withdrawn from the Assawompsett Pond Complex, the city’s source of drinking water. Leadership in Energy and Environmental Design (LEED) certification – State permits and local approvals should rely on nationally accepted benchmark for the design, construction, and operation of high-performance energy-efficient buildings.
Casinos are by their nature major energy consumers, so LEED certification is a must. Stretch energy code –The City of Taunton should require energy conservation and efficiency measures in all new construction at Project First Light.
Ten percent renewable electricity – State licenses and City approvals should demand the use of wind, solar, and/or geothermal power to supply most of the casino palaces’ energy. Monitor energy consumption – State licenses and City building approvals should mandate continued improvements to energy conservation and efficiency.
These criteria should not be optional but should be requirements of the City of Taunton and the state Gaming Commission. In addition, we recommend the following: Carbon constraints – State licenses and City of Taunton approvals should cap the amount of carbon emitted from the casino development and operation, including from cars, trucks, buses, and construction vehicles.
Wastewater – Licenses and City of Taunton approvals should limit the amount of wastewater that the casino development will send to the Taunton Municipal Wastewater Treatment Plant.
Solid Waste – Licenses and City of Taunton approvals should establish standards for waste reduction, minimization, and recycling for the casino development.
Transportation – The proposed casino should coordinate with the Greater Attleboro-Taunton Regional Transportation Authority (GATRA) to provide additional public transportation and regional ride-share opportunities.
A cars-per-day quota should also be set to reduce traffic congestion and carbon emissions. 3
Protection and Restoration of the Cotley River and adjacent wetlands – The Cotley River flows north from headwaters in Berkley across the project site and joins the National Wild and Scenic Taunton River about a half-mile further north.
Plans and permitting are underway for removal of the Barstowe’s Pond Dam, located on the project site to allow unimpeded flow of water and fish passage to upstream areas.
City of Taunton Conservation Commission approvals should ensure that the project does not result in deterioration of water quality in the river, that adequate vegetated buffers to the river are left intact; that impacts to wetlands and riverfront areas are avoided and minimized to the greatest extent practicable and that unavoidable impacts to wetland resources are fully mitigated.
There may be opportunities for Project First Light to contribute to the Cotley River restoration and dam removal efforts.
Preliminary plans suggest that this development will convert a significant amount of natural ground on the site to impervious surface, generating large volumes of stormwater runoff that may impair water quality or alter streamflow in the river. To avoid such impacts, the project should employ Low Impact Development and Green Infrastructure techniques, which will also contribute to the attractiveness of the development in terms of trees and other vegetative plantings.
City of Taunton approvals should also ensure that water withdrawals associated with the casino’s proposed indoor/outdoor water park do not adversely impact water flow and quality in the Cotley River and associated wetlands.
Community Mitigation Fund - The gaming law requires the establishment of a Community Mitigation Fund. On- and off-site development impacts will affect Taunton and extend to other communities in the surrounding region.
The fund should be equitably distributed to assist Taunton and other affected communities in offsetting costs related to casino construction and operation. The casino development plan must show what those impacts will be and how they will be addressed.
As the City of Taunton and the Gaming Commission begin work and debate on the benefits and detriments of Project First Light, the message to the Mashpee Wampanoag Tribe and its partners should be that if they want to make green, they need to go green, as casino development should not come at the expense of the nature of Taunton and Massachusetts.
Thank you for your consideration. Mass Audubon will submit more detailed comments regarding the scope for the Draft Environmental Impact Statement for this project to the Bureau of Indian Affairs, the Gaming Commission, and the City of Taunton.
Sincerely,
John J. Clarke
Director
cc: Ryan Colton, President, Taunton City Council
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