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Casino Should Get Full Environmental Review

The U.S. Dept. of the Interior should require completion of a full Environmental Impact Statement before considering the approval of the St. Regis Mohawk Tribe’s proposed casino complex at Monticello Raceway in New York State’s Catskill region. That’s the message environmental groups are sending to Acting Dept. Secretary P. Lynn Scarlett. This proposed project is huge (see details below) and threatens to have major impacts on traffic and development throughout the region, including along the Shawangunk Ridge.

Write to Secretary Scarlett with your views:
P. Lynn Scarlett
Acting Secretary of the Interior
U.S. Department of the Interior
1849 C Street, NW
Washington, D.C. 20240

Background
A recent Bureau of Indian Affair's memorandum from Acting Assistant Deputy Secretary George Skibine to the agency’s Eastern Regional Director, dated April 11, 2006, suggests that the preparation of a mere Environmental Assessment (EA)—a much less rigorous environmental evaluation as compared to a full Environmental Impact Statement (EIS)—is all that is needed before the Department may sign-off on the casino project. The memo also intimated that the Department has already decided to issue a “Finding of No Significant Impact” as soon as the Tribe collects some new environmental data.

Under NEPA, all federal agencies must, among other things, complete an EIS for all “major federal actions significantly affecting the quality of the human environment.” 42 U.S.C. § 4332(2)(C). There is little question that the size and scope of the proposed casino meets this threshold. The proposed Raceway complex would have 766,000 square feet of floor space, 4,200 gambling positions, a 1,500-seat bingo hall and parking for 4,800 cars and buses. The casino would draw 5.9 million visitors annually, according to documents produced by Empire Resorts, the casino developers, and the St. Regis Mohawk Tribe. If this project advances as currently proposed, it would be as big as the MGM Grand, Las Vegas’s largest casino, and would create traffic back-ups that will affect roadways as far away as the Tappan Zee Bridge.

Federal law requires the preparation of an EIS for this project because even a single large casino, like the one proposed by the St. Regis Mohawk Tribe, has the potential to unalterably affect the air, water, and unique rural character of the Catskills region as well as the integrity of the nearby New York City watershed, which provides drinking water to half the state’s population every day. A recent analysis by Sam Schwartz LLC, a well-respected, independent transportation consulting firm, raised serious questions about the effects of traffic from just one casino, concluding that just one casino would create “unacceptable conditions” on the region’s already congested roadways.

In addition to evaluating the direct environmental threats posed by the proposed casino complex at the Monticello Raceway, a full EIS is also necessary under NEPA and implementing regulations to assess the cumulative impacts of constructing other proposed casinos in the same or nearby towns in the Catskills. Over the last 18 months, as many as five large casinos have been proposed for this the region of the Catskills. While it appears that some of these proposals may not be advancing at the same pace as the Monticello Raceway project, press and other reports indicate there is still strong support for developing multiple casinos in vicinity of the Raceway.

There is strong precedent for the Department to require a full EIS for the Monticello Raceway site. Specifically, in 2003, the Department made formal decisions to require the preparation of EISs for the St. Regis Mohawk Tribe’s plan to build a casino at the Kutsher’s Sport Academy and the Stockbridge-Munsee Tribe’s proposal to build a casino in nearby Bridgeville, also in Sullivan County, New York. Both of these projects were comparable in size and scope to the current St. Regis Mohawk Tribe proposal now being considered by the Department.