Minnesota Indian Gaming Association COMMENT: ... it is our contention that this action will have severe sociion/economic impacts on surrounding tribes." RESPONSE: Attachment I of the Addendum cites, An Analysis of the Market for the Addition of Casino Games to the Existing Greyhound Racetrack Near the City of Hudson, Wisconsin, and An Analysis of the Economic Impact of the Proposed Hudson Gaming Facility on the Three Participating Tribes and the Economy of the State of Wisconsin, both by Dr. James M. Murray, PhD. These documents were submitted during the process required by the Indian Gaming Regulatory Act (IGRA) and were utilized, in part, to assess the gaming market, market shares and other related economic impacts. It was found in these and other studies performed in the primary market areas (predominately St. Croix County in WI and Washington and Ramsey Counties in MN) that the market is of sufficient size to support an additional casino operation and will not saturate the market. Comments regarding economic or social effects are considered in the environmental assessment process, however, they are not intended by themselves to require preparation of an environmental impact statement. These comments are more appropriately addressed in the IGRA process. Kenneth Tilsen COMMENT 1: The report fails to detail the relationship between the land to be placed in trust and the parking lot property, entrance gate, etc. which is part of the facility and will not be put in trust. It fails to identify the adjacent land that will remain exclusively in the control of the Florida gaming operator. It fails to identify the long history of community opposition to the track and it fails to identify the property as across the road from land protected by the wild River Act". It inaccurately indicates the track is open all year and fails to indicated that it operates about six days a week for between 32 to 40 hours a week NOT 24 hours a day, seven days a week.' RESPONSE: The relationship between land taken into federal trust status for the Tribes is stated in several places in the Addendum and Attachments, the Notice of Availability, and the DRAFT Finding of No Significant Impact, where they indicate that the principal structure, track facilities, paddock and kennel facilities, and parking lot to the north of the principal structure are intended for trust acquisition while the main parking lot west of the grandstand building is not intended for trust acquisition. A legal description of the area of intended trust acquisition is provided in Attachment A of the Agreement for Government Services. The use of the 1988 Report is to provide background information and data regarding work that had already been done regarding the dog track facility at this location. Whether the adjacent lands to the track facility are controlled by a Florida gaming operator, or not, does not apply to this proposed action. There are no known plans for future development of these areas. The Dec. 3. 1992, Indian Gaming Referendum, included in Attachment II of the Addendum, indicates that the Hudson Community is neither for, nor against, a Tribal Casino at the dog track facility. Some opposition to actions of this nature can be expected, however, based upon this referendum, it does not appear that there is overwhelming opposition to this concept. Discussions with National Park Service personnel in St. Croix Falls, WI, indicate that the dog track facility is outside the management area of the St. Croix Wild and Scenic River System. Concerns regarding possible impacts to the St. Croix River from increased traffic and associated air pollution would be monitored and addressed through the existing air pollution control permit. According to the Wisconsin Department of Natural Resources, Bureau of Air Management, neither a new indirect source permit, nor modifications to the existing permit are required, however, the air monitoring stations constructed for the dog track facility would continue to be monitored and the terms of the permit would continue in compliance. The statement that the track is open all year is accurate. The number of hours and/or days of facility operacion per week does not render the statement inaccurate. COMMENT 2: There is no basis supplied for the conclusion that the project will have a positive impact on the economic growth and well being of the surrounding communities. Recent studies by the Ford Foundation, the Illinois Department of Safety and others suggest that the jobs lost will equal or exceed the jobs gained. No report by a biased observer was any value.... RESPONSE: The new jobs created by this proposed facility would be available to unemployed residents of the Hudson area as well as co residents of St. Croix County and other counties nearby. These new jobs would provide workers at lower-paying jobs opportunities to increase individual earnings. Many of these jobs would be available to workers without special training, skills, undergraduate and/or post graduate degrees. It is reasonable co expect that increased earnings for area residents are likely to result in increases in the purchase of goods and services in these areas. Assertions to the effect that the proposed gaming facility would result in a loss of jobs in the Hudson area are noc realistic. Minnesota Gambling 1993 by Minnesota Planning describes many of the influences of tribal gaming in Minnesota and may be more applicable to gaming influences in the subject area of Hudson, WI, chan documents from other localities. This document compares casino counties to noncasino counties in Minnesota and states. There is no evidence that tribal gaming caused an increase in reported serious crimes such as murder, rape, robbery or theft. The crime rate for casino counties between 1989 and 1991 increased only slightly more than for noncasino counties... (14.8 percent compared to 12.1 percent)." Other positive influences documented include increases in gross business sales, increases in economic activity, increases in revenues of bars and restaurants, increases in visitors from other states and a decrease in county expenditures for Aid to Families with Dependent Children for counties wich casinos compared to those without. Various negative social consequences are also discussed in this document including increases in calls for help to Gamblers Anonymous and as well as increases in visits to gambling treatment centers. It is expected, however, that the allocable amount determined by the "Agreement for Government Services will compensate the local governments for the possible need for these services. Attachment I of the Addendum cites two of the various documents, An Analysis of the Economic Impact of the Proposed Hudson Gaming Facility on the Three Participating Tribes and the Economy of the State of Wisconsin, and An Analysis of the Market for the Addition of Casino Games to the Existing Greyhound Racetrack Near the City of Hudson, Wisconsin, both by Dr. James M. Murray, PhD., that were used to assess the economic impacts of the proposed dog track/casino facility to the Hudson Community and existing tribal casino markets. Information from these documents, along with others included in the application package pursuant to the Indian Gaming Regulatory Act (IGRA), was used to generate many of the estimates regarding socioeconomic impacts. Competition between tribal casino facilities and possible impacts to each tribal community are discussed in these studies (by Dr. Murray), which show that the proposed Hudson casino/dog track facility could have a 20% share of the blackjack market and up to 24% share of the slot and video market in the primary market zone (predominately St. Croix County in WI, and Washington and Ramsey Counties in MN). This study indicates that the gaming market is of sufficient size to support an additional casino operation and will not saturate the market. Socioeconomic and business related matters are considered in the environmental assessment process, however, they are more appropriately addressed in the Indian Gaming Regulatory Act (IGRA) process. The Indian Gaming Referendum of 12/3/92 specifically asked, 'Do you support the transfer of St. Croix Meadows to an Indian tribe and the conduct of casino gaming at St. Croix Meadows if the tribe is required to meet all financial commitments of Croixland Properties Limited Partnership to the City of Hudson?" This referendum appears to ask the question that more appropriately addresses this proposed action than referendums regarding continuation of the dog track facility or State-wide surveys to limit casino gambling. This Indian Gaming Referendum of 12/3/92 indicates that there is not an overwhelming majority of citizens in the Hudson area for, or against, the operation of an Indian casino at the dog track facility. No comments from the Town of Troy, officially or unofficially, were received regarding the environmental impacts of this proposed action. COMMENT: The political social and practical effect of the Hudson dog track-to-casino proposal is as follows: " 1. It denigrates and erodes the concept of Indian Sovereignty RESPONSE: The concept of Indian Sovereignty is one that has been argued for centuries and is beyond the scope of this action. 2. It leads to the erosion of public support for Indian Gaming rights. RESPONSE: The erosion of public support for Indian gaming rights is beyond the scope of this action. 3. It breaks the solidarity of Indian Tribes in supporting each other. |