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The Public/Private Development Unit has reviewed the Second Supplemental Final
Environmental Impact Report (SSFEIR) for the Wynn Casino project in Everett. The proposed
project entails the development of a 2.6 million square-foot (sf) resort casino to be located on the
west side of Route 99 (Broadway), opposite Mystic Street. The project site comprises
approximately 33.9 acres of land in the City of Everett, adjacent to the Mystic River. The project
is bounded to the west by the tracks of the Massachusetts Bay Transportation Authority
(MBTA); to the north by the MBTAs Everett Shops Facility; to the east by Route 99, an existing
carwash, and the Massachusetts Water Resource Authority (MWRA) and the Boston Water &
Sewer Commission Treatment Plant facility; and to the south by the Mystic River.
Primary access to the site will be provided via a new signalized intersection on Route 99
on land acquired from the MBTA. A secondary access for deliveries and employees will be
provided via a service road that would follow the periphery of the MBTA Everett Shops property
and connect with Route 99 across from Beacham Street in Everett.
On April 3, 2015, the Secretary of Energy and Environmental Affairs issued a Certificate
in response to the SFEIR filed on February 25, 2015, finding the project not in compliance with
MEPA regulations. An SSFEIR was required to address the following transportation issues:
A) An explanation of and remedy for the premature conveyance of land from the MBTA to
the Proponent prior to the completion of MEPA review;
B) A commitment to a specific dollar amount for an annual operating subsidy to the MBTA
to support service and capacity improvements on the Orange Line;
C) The establishment of a process for long-term improvements along the Rutherford Avenue
Corridor and at Sullivan Square; and
D) An update of the transportation analysis/mitigation commitment/Section 61 Findings.
MassDOT has thoroughly reviewed the updated transportation study included in the
SSFEIR, and during the process and has met for discussions with the Proponent, the Cities of
Boston, Somerville, and Everett and other stakeholders involved with the approval of the project.
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It is our opinion that the SSFEIR has adequately addressed the issues raised in the MEPA
Certificate and presented a comprehensive mitigation program to address the projects traffic
impacts. MassDOT shares some of the City of Bostons concerns regarding the effectiveness of
the interim mitigation plan to address the existing deficiencies at Sullivan Square due to its
proximity to the I-93 southbound ramp. However, we believe with the City of Bostons
cooperation, the willingness of the Proponent to acquire right-of-way as appropriate, and
discussions and inputs from technical staff involved in the permitting process, this plan can be
refined and finalized to address the remaining concerns. MassDOT will continue to work with
the Proponent, the City of Boston and other interested stakeholders to ensure that the interim
mitigation plan is further refined and the right-of-way issues are addressed prior to the issuance
of MassDOTs Section 61 Findings. Further, as explained below, MassDOT stands ready to
continue working with these same stakeholders to address longer-term mitigation issues that may
arise out of the proposed reconfiguration of Rutherford Avenue and Sullivan Square.
Accordingly, MassDOT believes that the SSFEIR has adequately addressed the key
transportation issues raised in the SSFEIR Certificate and supports issuance of a certificate
finding the SSFEIR to be adequate. We believe that no further environmental review need be
required based on transportation issues and that remaining issues can and will be addressed
through the permitting process and finalization of Section 61 findings.
The following comments addresses in more details MassDOTs review of the SSFEIR.
A.
Land Conveyance
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demonstrate that the modifications resulting from the land transfer would not be detrimental to
MBTA operations on the site.
B.
During the MEPA review of this project, MassDOT consistently requested that the
Proponent provide an operating subsidy for additional Orange Line service. Throughout the
process, MassDOT and the Proponent engaged in discussions on this issue, but no commitment
was made up through and including in the SFEIR. In our comment letter requesting an SSFEIR,
MassDOT again requested that the Proponent be scoped to continue working out this issue.
The Proponent is expecting significant usage of the MBTA transit system by both patrons
and employees traveling to the site. The SSFEIR includes an updated analysis of projected
Orange Line peak loads for weekday and weekend service days between the Wellington and
Back Bay Stations. Based on these projections, the increase in demand would add a significant
number of employees and casino patrons in the transit system during some peak periods.
As discussed in the SSFEIR, MassDOT requested the Proponent to mitigate transit
impacts in a manner analogous to the way that project proponent mitigate traffic impacts on
roadway network - by funding the provision of additional operational capacity to offset any
deterioration in service caused by the project. In the case of the Orange Line, the proposed
mitigation approach is to fund additional service in any case where the level of service in the
Build Condition is projected to be below the level of service in the No Build Condition, unless
the Orange Line has existing capacity to handle the increased trips.
As reflected in the SSFEIR, there are four times of the week, where the Orange Line is
projected to violate MBTA service quality standards in the Build Condition and the annual cost
to run additional service to mitigate this condition is $382,200. The revenue that is assumed for
this service based upon the additional passengers added to the Orange Line by Wynn customers
and/or employees is $110,500 annually, requiring an annual subsidy of $271,700. In addition, in
order to encourage transit mode share during late night service hours, the Proponent has agreed
to subsidize additional service beyond the required mitigation. That service will provide reduced
headways during weekday evenings (9:00 to 11:00) at a cost of $109,200, for a total annual
Orange Line subsidy of $380,900 (2015 dollars). The Proponent has agreed to annually inflate
this subsidy by 2.5% and to commit to a term of 15 years. The total subsidy over the 15-year
period will be $7.4 million. MassDOT and the MBTA have engaged with the Proponent in
reaching agreement on this subsidy structure and amount. We are now confident that the subsidy
would not only mitigate the transit impacts of the project but would help improve quality of
service on the Orange Line. MassDOT and the MBTA therefore support the transit mitigation
subsidy as laid out in the SSFEIR.
C.
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Over the course to the MEPA review, the City of Boston, along with other commenters,
expressed concerns regarding the incompatibility of the Wynn Casino with the Citys long-term
goals for both Sullivan Square and the Rutherford Avenue corridor. According to preliminary
conceptual plans resulting from a visioning process by the City of Boston, the Rutherford
Avenue corridor is expected to be reduced to two lanes in each direction with pedestrian and
bicycle facilities provided on both sides. Sullivan Square, the northern terminus of Rutherford
Avenue in the City of Boston, is expected to be redeveloped into a network of neighborhood and
pedestrian-friendly streets to accommodate denser land use that would connect to the existing
Charlestown neighborhood.
In our comment letter on the SFEIR, MassDOT requested that the SSFEIR scope include
the development of a planning process for the integration of the Citys long-term plans for
Sullivan Square and Rutherford Avenue and the impacts of casino traffic. In the Certificate on
the SFEIR, the Secretary of EEA called for the development of a planning process with
participation by MassDOT, the Massachusetts Gaming Commission (MGC), the Proponent and
the City. On June 1st, MassDOT convened a group of stakeholders to begin the process. Parties
in attendance included the Executive Office of Energy and Environmental Affairs, the MGC,
Wynn, the City of Somerville and the City of Everett. The City of Boston, though invited, opted
not to attend.
A second meeting called by the Secretary of Transportation on August 13th was attended
by the MGC, Wynn and representatives of the cities of Boston, Everett and Somerville. At the
meeting, the City of Boston presented an overview of the existing problems at Sullivan Square
and discussed their extensive efforts to develop plans in conjunction with the Charlestown
neighborhood to reconfigure Sullivan Square and the Rutherford Avenue corridor. They
expressed strong reservations regarding the ability of the mitigation plan proposed by the Wynn
Casino Resort Proponent to address the projects traffic impacts at Sullivan Square. In addition,
they argue that the Wynn Casino Resort mitigation plan is incompatible with the City of Boston
vision for Sullivan Square and Rutherford Avenue. Similarly, the City of Somerville expressed
concerns that the additional traffic associated with the casino at Sullivan Square and along
Rutherford Avenue would inhibit future growth planned in Somerville, more specifically at
Union Square and at Assembly Row. On the other hand, the City of Everett expressed their
support for the Wynn Casino project mitigation plan and viewed the project as a catalyst for
economic development and future growth. The August 13 meeting, while it did not resolve the
outstanding issues, was productive and allowed MassDOT to ensure that we understand all of the
parties concerns with respect to both interim and long-term mitigation. Having held these two
meetings, MassDOT believes we have fulfilled the requirement in the SFEIR Certificate to
initiate a planning process to address the transportation concerns at Sullivan Square and
Rutherford Avenue.
What is clear from the meeting and from subsequent review of material provided by the
City of Boston is that there are two distinct time periods that must be considered with respect to
mitigating the projects impacts on Rutherford Avenue and Sullivan Square. The first is an
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interim period during which those roadways will remain roughly in their current configuration;
the second is a future condition in which Rutherford Avenue and Sullivan Square have been
reconfigured. While many people believe that the Sullivan Square redesign is a done deal, the
Citys process to date has not produced a design for this important project that is sufficiently
detailed that it can be thoroughly evaluated by MassDOT and the public. MassDOT supports the
Citys efforts to advance its ideas for the future of Rutherford Avenue and Sullivan Square and in
July 2014 executed an agreement with the City of Boston to fund the 25% design plans using a
federal earmark. While that effort is progressing, until the design is advanced MassDOT cannot
provide detailed feedback on the proposed redesign or hold required public hearings.
MassDOTs understanding is that the City of Boston plans to begin actual construction in 2020,
assuming of course that the proposed design works and funding can be obtained. Therefore, the
interim time period is likely to encompass the opening of the Wynn casino.
Thus, while the City of Boston has a compelling vision for the future of Rutherford
Avenue and Sullivan Square, it does not yet have a project that has been designed. For reasons
of both fairness and efficiency, the MEPA process and MassDOTs traffic analysis guidelines
require each project proponent to account for all other private and public projects that precede it;
projects for which a MEPA filing has occurred are required to be taken into account in the traffic
analysis for all subsequent filers that affect the same area of the transportation network. But the
City of Boston has not initiated state or federal environmental review for its Rutherford Avenue
and Sullivan Square redesign and cannot do so until the design process has advanced. Nor has
MassDOT been provided with sufficiently detailed design to be able to evaluate the project or
model its impacts on the regional transportation network.
MassDOT believes the SSFEIR has adequately addressed the key transportation issues
during the interim period while Rutherford Avenue and Sullivan Square remain in roughly their
current configuration. As stated above, we believe that remaining traffic issues for this
timeframe can be addressed through the permitting process and finalization of Section 61
findings. MassDOT will of course consider the comments filed by all stakeholders including the
Cities of Boston and Somerville in the development of the Section 61 Finding for the project.
The question remains of how best to continue the process for planning long-term
improvements along the Rutherford Avenue Corridor and at Sullivan Square and for evaluating
the impacts of the Wynn casino and other planned development projects on traffic in this
important location. MassDOT is ready either to convene or participate in such an effort. Indeed,
we believe that such a regional working group could address all of the transportation issues
associated with the impact of the casino and other planned development on future conditions in
the area of Rutherford Avenue and Sullivan Square. Any such effort could be informed by
ongoing efforts at MassDOT and the MBTA to conduct technical analyses of the future
conditions for that area as they are impacted by the plans for Rutherford Avenue and Sullivan
Square as well as the Green Line Extension project, the reimagining of McGrath Boulevard and
planned private development in nearby communities. MassDOT would be happy to work with
others to refine the models developed for those efforts in order to inform the work of the regional
working group.
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Perhaps the MEPA certificate on the SSFEIR could acknowledge the need for such a
process and even tie it to the development of a long-term mitigation plan that would in turn
unlock the $25 million in funding that Wynn has set aside for making longer-term improvements
to Sullivan Square. Such a process for developing a long-term mitigation plan for Rutherford
Avenue and Sullivan Square could, of course, involve noticing the availability of a draft version
of the plan in the MEPA Monitor so that appropriate public review and comment could be
ensured even after the MEPA process for the Wynn casino comes to an end.
D.
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sufficient flexibility for further refinements to address its concerns at the I-93/Cambridge Street
intersection and at the MBTA Sullivan Square Station.
Finally, we note that many commenters have suggested that the Boston Metropolitan
Planning Organizations (MPOs) regional travel demand model be used to conduct modeling
and analysis in light of the projects potential impact on the transportation system and the
regional distribution of its trip patterns. The regional travel demand model is not used for
developer-proposed projects, however, but for projects where MassDOT is proposing a project
which actually would change the regional travel network. The distinction between those projects
that are analyzed using the travel demand model and those that are not is not, as some
commenters have suggested, the number of trips generated. Indeed, if MassDOT were to
advocate for use of the regional travel model based on the magnitude of trips generated, it is
unlikely that the Wynn casino project would require such additional analysis. The projected
traffic impacts of the Wynn Casino are no larger than many other projects that have been
reviewed through the MEPA process without requiring the use of the regional travel demand
model. MassDOT has, for example, provided feedback on traffic generated by the Westwood
Station Project (Westwood), the Northborough Crossing Project (Northborough), the Northwest
Development Project (Burlington), the Old Colony Place Project (Plymouth), and the Patriot
Place Project (Foxborough) without requesting or requiring use of the regional travel model
and all of those projects had traffic impacts that exceeded 20,000 vehicles per day. MassDOT
therefore believes that the use of the regional travel demand model is inappropriate in this
context and that the Proponents transportation study is consistent with the MassDOT/EOEEAs
Transportation Impact Assessment Guidelines (2014) and meets the standards of practice
nationally. The numerous MEPA filings on this project have provided sufficient opportunities
for agency review and public comment on transportation issues and the methodology of the
transportation study.
Draft Section 61 Findings
The Draft Section 61 included in SSFEIR outlines a comprehensive package of
multimodal improvements to address the projects impacts. These improvements are detailed in
the SSFEIR, but can be briefly summarized as follows:
Transit: An Orange Line operating subsidy for 15 years totaling approximately $7.4 million;
creation of a comprehensive bus shuttle system for casino patrons and employees; and MBTA
station improvements and bus amenities and accommodations.
Walking: Pedestrian accommodations at all intersections where improvements are proposed;
sidewalk reconstruction along Broadway (Route 99); pedestrian improvements at Sullivan,
Wellington, and Malden Stations; and funding towards the design of a potential bridge
connecting the Assembly Row Station with the shared use path abutting the site.
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