Scoping for Proposed Casino by the Stockbridge-Munsee Band of the Mohican Nation

re: Scoping for Proposed Casino by the Stockbridge-Munsee Band of the Mohican Nation

December 5, 2003

Franklin Keel
Regional Director
Bureau of Indian Affairs
Eastern Regional Office
711 Stewarts Ferry Pike
Nashville, Tn 37214
re: Scoping for Proposed Casino by the Stockbridge-Munsee Band of the Mohican Nation
I am writing as President of Orange Environment, Inc., a not-for-profit, tax-exempt organization concerned over its 21 years with protecting the integrity of the environment and communities of Orange County and its region and promoting sustainability.

Please consider OEI to be an interested party with regard to this application.

With regard to the scoping for the proposed casino, please assure that the following matters are fully considered in the DEIS.

The development of a casino in Sullivan County, New York will, by its very nature, attract thousands of new cars daily to the existing traffic pattern on the Rt. 17 corridor. Rt. 17 currently serves as the main street for much of Orange County and nearly all of Sullivan County. Because Orange County is heavily a commuting community, moreover, the Rt. 17 corridor serves as a primary path to work for many residents. Additionally, the Rt. 17 corridor serves as a vacation pathway for people visiting the northwestern counties of the Catskills. And finally, Rt 17 serves through traffic moving between the metropolitan area and upstate highway connections and is currently designated to become an Interstate Highway (Rt 86), increasing such traffic. Each of these four existing use categories comes with its own traffic dynamics, all of which will interact with changes induced by the proposed project and cumulatively with other future projects and changes. Moreover, the Rt. 17 corridor is directly connected in use pattern to the Rt. 6/Pallisades system toward Manhattan and with the Rt 87 NYS Thruway System and its connections to Rt. 287, as well as other roadways. These existing patterns and connections show current times and points of extreme congestion and trends reflect a current dramatic negative change in capacity (i.e., loss of service). Numerous secondary roads support this corridor, all of which are affected by congestion in the system as secondary impacts. In turn, direct and indirect impacts for municipalities, residents’ quality of life, emergency and enforcement responders, and others are felt. For both the corridor and the connected system, therefore, we request that the DEIS address all changes to this corridor and system caused by the proposed project over time, in isolation and in combination with other anticipated changes.

Specifically some of the particular issues of concern related to the above changes are:

  1. Congestion and Travel Time. How will this project affect the Main Street character of transit for both Orange and Sullivan Counties?
    1. What are the likely and worst case impacts in terms of congestion and mobility impairment for residents of both counties over time?
    2. What are the potential impacts for corridors of induced secondary mobility as residents attempt to use secondary roads to avoid Rt 17?
    3. What are the likely impacts for rush hour congestion points (barriers and nodes), including the Harriman toll booth, the Rt. 6 traffic circle, and the Rt. 17/I-287/I-87 node, both during commuting times and during the Sunday return-to-the city congestion dynamic?
    4. What changes to the character of Orange and Sullivan County will occur due to changes in traffic pattern?
    5. How will access to proposed and existing hospitals and emergency facilities be affected?
  2. Cumulative Effects. What are the cumulative impacts stemming from this proposal in combination with other proposals for casinos, for cultural centers and other known projects that will induce additional traffic onto the Rt. 17 corridor and in light of the Interstate Highway designation as Rt. 86, likely induced growth of Sullivan and Orange Counties, and the Catskills weekend and vacation traffic flow?
  3. Air Pollution. Orange County is currently not in compliance with the Clean Air Act with regard to the NAAQS for ozone. What impact will induced traffic due to this project have on air quality with regard to all NAAQS (and for pollutants of concern not included inthe NAAQS) for the Rt 17 transit corridor and corridors of induced secondary mobility in terms of efforts to meet the standards, consequences should stricter compliance requirements be required, consequences for respiratory health in the corridor, considering both isolated and cumulative effects?
  4. Water Quality. The extended Rt. 17 corridor affects water quality in at least the Ramapo, Wallkill, Hudson, and Delaware/Neversink watersheds. What are the potential impacts to surface and ground water resources due to direct impacts from road construction, repair and reconfiguration, from traffic directly, and from traffic-support facilities (gas stations) associated directly or indirectly with the proposed project and cumulatively?
  5. Traffic Safety and Crime. How much of an increase will the assessed project (and the project in cumulative combination with other changes) cause in the accident and injury rate on the Rt. 17 corridor and on secondary impacted roadways?
    1. Will the project increase the rate of drivers impaired by alcohol or drugs using the regional/local road systems?
    2. What resources will be required to police and enforce traffic laws and to address crime, violations and emergency response demands caused by accidents?
    3. Will the project in isolation or cumulatively change the crime dynamics of the region or the required efforts to address crime?
  6. Induced Growth. How will the proposed project induce growth in Sullivan and Orange Counties in isolation and cumulatively and what are the direct, secondary and indirect and cumulative impacts of such growth?
    1. What will the impacts be for growth in residences?
    2. What will the impacts be for growth and change in businesses?
    3. What will the impacts be for growth and demand on services provided by government and non-governmental agencies?
  7. Quality of Life. Due to the project and cumulative impacts, what changes will occur for the residential and business community of Orange and Sullivan Counties that will affect their quality of life, including the stress of daily life and their ability to meet life needs in an efficient and comfortable manner?
  8. Quality of Environment. How will the proposed project, in isolation and cumulatively, affect the overall environmental quality of the region, including the quality of the region as habitat for diverse species of plants and animals?
  9. Mass Transit, Trip Avoidance, and Global Climate Change. The Rt. 17 corridor is currently underserved by mass transit. Rail connections were moved from the main line in Orange County in the 1970s. Bus service has become increasingly limited except as a tool for primary commuting to Manhattan. The proposed action promises to dump excessive additional traffic onto roads that might instead be diverted to public transportation were that available in a form likely to attract both casino riders and to serve the commuting needs for the existing transit corridor.
    1. What mitigations for project impacts exist that will spur the development of mass transit infrastructure and service along the Rt. 17 corridor?
    2. Overall, how will this project contribute to global climate change and what mitigation might reduce this impact?

Thank you for this opportunity to contribute to scoping. We reserve the right to submit additional comments through the designated period. And we look forward to participating actively in the review process.

Sincerely,

Michael R. Edelstein, Ph.D.
President