In a battle of the written word this week between top state officials, the power of the pen has seemed to swing the way of Wynn.
Dueling letters of support and opposition from several officials ended on Monday with the top transportation official in the state writing that Wynn’s traffic plan had satisfied her and the state’s Department of Transportation (DOT).
“MassDOT believes that no further environmental review need be required based on transportation issues,” read the letter from Transportation Secretary Stephanie Pollack. “Specifically, MassDOT believes that the SSFEIR has adequately addressed the key transportation issues during the interim period while Rutherford Avenue and Sullivan Square remain in their current configuration.
“As for the longer-term important issues affecting Rutherford Avenue and Sullivan Square, MassDOT acknowledges that additional collaborative work by the Cities of Boston, Somerville and Everett, as well as other stakeholders, would be helpful. As you know, this area has been subject to extensive planning over the past decade, and the long-term issues there go well beyond those posed by the proponent’s development.”
The war of words comes in anticipation of the Aug. 28 expected decision on a critical, final piece of the puzzle in Wynn’s path to secure a full environmental certificate (known as a MEPA certificate) from Energy and Environmental Affairs Secretary Matthew Beaton. The certificate has been mostly completed, but has been hung up since February on traffic concerns in Sullivan Square and the surrounding environs.
With the letter on Monday from Pollack, many of the efforts put forth by Wynn – and opposed in large part by some residents of Charlestown and the City of Boston – were validated.
“We believe that these longer-term issues are best addressed through a regional working group, and MassDOT is ready either to convene or participate in such an effort,” read the letter.
“And perhaps, as we suggest in the attached MEPA comments, such a process could produce a Sullivan Square mitigation plan that could in turn unlock the $25 million in funding that the proponent has set aside to make longer-term improvements to Sullivan Square.”
Charlestown State Rep. Dan Ryan wrote in his comment letter he felt that the casino project should move forward as a way to spark solutions to long-standing problems.
“I have always viewed [the casino] as a supplemental source of revenue that will allow this region to find practical solutions to some of its unfulfilled infrastructure dreams,” he wrote. “In some cases, I believe Wynn Resorts is being asked to address and mitigate traffic and environmental concerns that are not of their doing and are not casino related. As a regional economic development effort, I do find this broader use of gaming revenue and mitigation fitting and proper. This license, if issued, is intended to boost the economic viability of an entire region. I advocate an even more comprehensive use of gaming resources. With these suggestions considered, I respectfully ask that you allow Wynn Everett to move forward in as timely a manner as possible.”
Everett Mayor Carlo DeMaria indicated that Boston planned Sullivan Square without the help of other regional users – such as Everett. He said everyone needs to come to the table this time.
“These positions must be reconciled,” DeMaria wrote. “Simply put, if Sullivan Square is impacted by regional factors, then it is the entire region that must come to the table.”
However, those comments in support of Wynn’s traffic solutions were bookended by Attorney General Maura Healy – a Charlestown resident – who submitted critical comments on Friday along with her own commissioned traffic study.
Healy called for Secretary Beaton to hold up the certificate on Wynn until the long-term solution is identified.
“We urge you not to issue a MEPA certificate for the casino until Wynn’s certificate includes a long-term traffic solution for Rutherford Avenue and Sullivan Square that takes into account years of planning by community stakeholders and is compatible with the City of Boston’s redevelopment plans for that area,” she wrote. “If you approve the casino without a long-term traffic mitigation plan, we may never get one… Allowing the multi-stakeholder planning process to continue unimpeded will best ensure that the public’s interests, particularly related to traffic, regional economic development, and neighborhood planning, are represented at this critical stage. If the Casino is built without a long-term plan in place for Rutherford Avenue and Sullivan Square, we simply may never solve the traffic problem.”
Her key points of contention for holding up the certificate were that the casino was not compatible with Boston’s plan to downsize Sullivan Square, that the traffic numbers generated by Wynn were not accurate, that the on-site parking is not sufficient and that the casino’s impacts on I-93 were not addressed.
Of most interest in the 68-page comment letter from Healy, was a brand new traffic study commissioned by the AG and poking holes in the numbers of Wynn’s analysis throughout the MEPA process.
Healy commissioned the report from SmartMobility, which was delivered by its president, Norman Marshall, on Aug. 20.
The report basically identified the same issues that were of concern to Healy.
“All of these issues should be resolved prior to construction of the proposed project, because it is unclear whether satisfactory mitigation of these issues is even possible,” read the study. “Even if mitigation is feasible, the plan should be in place before the Wynn Casino is built. Otherwise, the required mitigation may not be implemented.”
The study indicated that the numbers used by Wynn to study trip generation – using casinos in New York City, Philadelphia and Montreal – should be reconfigured, using the averages of traffic counts at those three casinos. When using those new numbers along with the numbers of gaming positions, Marshall indicated that the trip numbers are much higher than predicted by Wynn.
For example, Wynn indicates that gaming trips coming in would be 556 during the Saturday peak hour, but Marshall calculates that to be 898 trips – some 342 more trips that suggested.
Even Rep. Ryan, who urged the issuing of the certificate, wrote in his letter that Wynn traffic numbers probably are not accurate because there is no real way to predict Sullivan Square and Rutherford Avenue due to political and governmental factors.
“I’m sure the numbers Wynn used were not accurate; because, accurate traffic numbers do not currently exist,” he wrote. “Sullivan Square has been in a constant state of flux my entire adult life…I have sat through numerous meetings over the years and listened to expert traffic analysis that did not concur with the experiences of anyone who uses this corridor on a regular basis. I do not believe you can accurately model 21st Century projections onto third world conditions without bringing to the table the people who use these roads daily. Anecdotal conversation added to the analytical morass must happen in an inclusive and open manner. This is not an engineering problem. It is a political and governmental problem.”
He also indicated that estimates for Rt. 1 traffic traveling to the casino via Rutherford Avenue and Sullivan Square was underestimated. He said that local people who know better will not take Rt. 16 to Rt. 99 to access the casino. He said he believes far more people will take the Tobin Bridge and drive through Charlestown.
In the end, though, it will be Secretary Beaton that makes the call – presumably this Friday, Aug. 28. With his approval, a long and arduous process will come to an end and the casino company can begin moving forward quickly on plans ready to be executed.
If he decides more needs to be done, it will be back to the drawing board for Wynn to address any additional identified concerns about the traffic situation.