MEMORANDUM

TO:

David Mohler, Executive Director

Office of Transportation Planning

FROM:

J. Lionel Lucien, P.E, Manager, Public/Private Development Unit

Office of Transportation Planning

DATE:

August 21, 2015

SUBJECT:

Everett Wynn Casino Resort: SSFEIR

(EEA#15060)

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

As noted in our comment letter on the SFEIR, MassDOT/MBTA inappropriately

executed a deed of sale for land associated with the Wynn Everett Casino while the project was
still in the MEPA process. The decision to require an SSFEIR ensured that MassDOT/MBTA
could work with the Proponent to fashion an appropriate remedy for that action and required the
Proponent to publicly document all analysis undertaken to ensure that the transfer of land would
not adversely affect the operations of the MBTA Everett Shops.
As explained in the SSFEIR, the Proponent has worked with the MBTA to place the
subject property and the payment received for it into escrow. The escrow agreement provides
that the conveyance of the property shall be deemed to not have taken place unless and until the
Secretary of EOEA has issued a certificate finding the project adequate. If based upon the Final
MEPA Certificate, the MBTA determines that no changes are needed to the prior sale, the parties
will break escrow and the transfer will be finalized. If the MEPA certificate requires
modifications to the original transfer, the parties will ensure that all regulatory conditions are
incorporated before any land transfer is finalized.
The SSFEIR also documents the impact of the land transfer on the operations of the
Everett Shops. During the land disposition process, the Proponent consulted with MBTA staff,
including the staff of the Everett Shops to ensure that the transaction would not negatively
impact operations. With input from technical and operational staff, the Proponent was able to

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demonstrate that the modifications resulting from the land transfer would not be detrimental to
MBTA operations on the site.
B.

Orange Line Subsidy

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.

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C.

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Rutherford Avenue Improvement Planning Process

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.

Mitigation/Draft Section 61 Finding

The SSFEIR includes an updated transportation study that conforms to

MassDOT/EOEEAs Transportation Impact Assessment Guidelines (2014). The transportation
study has revisited capacity analyses for several intersections within the study area following
comments received from abutters or local communities. For the most past, the analysis was
required to address some revisions to the trip distribution or corrections of some inaccuracies in
graphics included in the previous submissions.
The SSFEIR includes updated Levels of Service (LOS) and a summary of the 50th and
95th percentile vehicle queues for these intersections as appropriate. In addition, the Proponent
has adequately addressed questions regarding the use of SYNCHRO traffic software and the
VISSIM simulation model used to verify the mitigation plan performance measures. Throughout
the process, the Proponent has worked with the MassDOT Traffic Operations unit to ensure that
information used to conduct both capacity analysis and traffic simulation were reviewed,
calibrated, and validated. MassDOT remains confident that the analysis and the traffic
simulation provided accurately portray existing and future operating conditions within the study
area and support the effectiveness of the proposed improvements to mitigate the impacts of the
Wynn Casino Resort.
As part of the SSFEIR, the Proponent has updated the analysis and the mitigation plan at
Sullivan Square to address comments expressed by the City of Boston. The comments centered
primarily on the redistribution of traffic and the lack of an AM peak hour analysis. The results
of the new analysis are not significantly different from those presented in the SFEIR and
continue to indicate that the Sullivan Square area would experience worsening LOS and
increased delay in both the No Build and Build conditions due to projected growth and casino
impacts, respectively. With the proposed interim mitigation in place, the SSFEIR analysis
demonstrates that traffic operations would generally return to close to No Build conditions (LOS
E and F) with moderate reduction of delay in the Build conditions. The Proponent should
continue to work with MassDOT and the City of Boston to refine the geometric improvements
and optimize traffic operations around the area. In particular, the Proponent should pay close
attention to how the proximity of the intersections could impact overall network operations,
including MBTA bus operations. These improvements may necessitate the acquisition of ROW
along Cambridge Street, Spice Street, and D Street. The Proponent has indicated that they have
initiated discussions with the respective property owners and expect that they will cooperate in
providing the needed right-of-way upon request. MassDOT believes that this plan provides for

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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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Bicycle: Bicycle improvements at a number of intersections, bicycle lanes along Broadway,

bicycle improvements along Sweetser Circle, bicycle racks on site, and provision for Hubway
bicycles on site.
Water Transportation: Provision of a water shuttle available to casino patrons and employees
that would connect the site to Downtown Boston.
Highway: Implementation of highway improvements at a number of locations in the study area;
interim improvements at Sullivan Square; and funding towards a study for future improvements
at Wellington Circle.
The full list of mitigation measures committed to by the Proponent is included in the
SSFEIR, but the above summary portrays the multimodal approach to mitigation to address the
project traffic impacts. MassDOT is particularly pleased that extensive discussions and analysis
have resulted in a commitment to fund additional transit capacity on the Orange Line as a way to
mitigate the projects impacts. We believe that the SSFEIR provides sufficient information on
transportation mitigation to allow the agency to finalize Section 61 findings and support required
permitting processes.
MassDOT looks forward to continuing to work with the Proponent during the permitting
of the project. The Proponent should also continue coordination with the Cities of Boston,
Everett, Somerville, Chelsea, and Medford to implement the mitigation program. MassDOT
expects further consultation between the Proponent and the City of Boston to refine the interim
mitigation plan for Sullivan Square. The changes resulting from these consultations will be
reflected in the Section 61 finding to be issued for the project. Finally, coordination with the
MassDOT Office of Transportation Planning and appropriate divisions should continue postoccupancy to implement the monitoring program for the project.
If you have any questions regarding these comments, please contact me at (857) 3688862.