impact.

(k) Oneida Tribe of Indians of Wisconsin: The Oneida Tribe stated that since they are located 250 miles away from Hudson, Wisconsin, they are not in a position to offer detailed comments or analysis on the impacts of the proposal (Volume III, Tab 9). They did state that they do not perceive that there would be any serious detrimental impacts on their reservation or gaming operations.

None of the Tribes who have written to our office to protest this proposal has provided us with any figures to back up their claim that the Hudson Venture would be "devastating economically to the other casinos in the area. As a result, we must rely heavily on the study prepared by Arthur Andersen and Dr. Murphy to estimate the impact on the other Tribes economically.

Arthur Anderson's study estimates current market revenue for the six existing casinos in the Minneapolis/St. Paul area to be $510 million with a total estimated market revenue between $550 and $630 million' (Volume I, Tab 3, page 21).

Since the Hudson Venture's share of the market is estimated to be 580 Million, AA has found that even though the existing casinos would suffer some economic loss, the "proposed Hudson casino should not significantly impact aggregate revenues of the existing casinos Id. We have particular concern over the economic impact of those casinos located within 55 road miles from Hudson. They include the Mystic Lake Casino, Turtle Lake Casino and Treasure Island Casino. Each of the Tribes operating these casinos have voiced strong opposition to the Hudson Proposal based on economic reasons. However, none of these Tribes have provided our office with any hard figures to back up their claims.

On August 12, 1994, we requested the Lac Courte Oreilles, Red Cliff, and Sokaogon Tribes provide an analysis which focuses on the particular economic impact of the proposed casino on the

• The market was estimated by Arthur Andersen & Co. using the following figures: . Population within 100 miles.... 3,800,000 MULTIPLIED BY: Estimated per capita gaming revenue.... $145 - $165 We also note that the Hole in the Wall Casino in Danbury, Wisconsin, was not included in figuring the total estimated market

revenue.

EOP 064531

Mystic Lake, Turtle Lake and Treasure Island Casinos. The Tribes did not respond in writing. Their representative, Bill Cadotte, did state that there is no legal basis to reject the proposal based on what the potential political ramifications might be. We concur. Specifically, we find that additional market studies cannot be completed by the three Tribes without financial data supplied by the three casinos in question.

2. Political:

A number of Tribes and commentators have indicated that expansion of off-reservation gaming erodes their political power and will eventually undermine their ability to limit States from expanding gaming. However, it can be argued that each new gaming operation, whether or not on land placed into trust prior to October 17, 1988, erodes Tribal political power to protect the gaming industry. We find that the Tribal Sovereignty of the Lac Courte Oreilles, Red Cliff, and Sokaogon Tribes is far more important than limiting the expansion of Tribal Gaming. In fact, each Tribe currently operating gaming facilities went into the industry knowing that expansion into major metropolitan areas was a possibility and maybe even likely. We find that it is up to each individual Tribe to operate within the limits of the Indian Gaming Regulatory Act, their Class III Gaming Compacts and their. existing governing documents. The Minneapolis Area Office will not restrict Lac Courte Oreilles's, Red Cliff's, Sokaogon's or any other Tribe from operating within these limits and find that any negative political ramifications from this proposal would be

minimal.

C.

EVIDENCE OF ENVIRONMENTAL IMPACTS AND PLANS FOR REDUCING ANY
ADVERSE IMPACTS:

The

The Lac Courte Oreilles and Red Cliff Bands Lake Superior Chippewa Indians and the Sokaogon Chippewa Community propose to purchase, and place into federal trust 55.82 acres of land. proposed trust site consists of the St. Croix Meadows Greyhound Racing Facility including the principal structure, track facilities, paddock and kennel facilities and parking lot to the north of the principal building, for the purpose of operating a Class III gaming facility in addition to the existing pari-mutuel dog track operation. The main parking lot west of the grandstand building is not intended for trust acquisition.

The existing grandstand would be remodeled to accommodate gaming activities, however, most support facilities (kitchen, washrooms, office space, etc.) would be maintained.

1. Environmental Considerations:

An "Environmental Assessment for St. Croix Meadows Greyhound Racing Park, Hudson, Wisconsin, January 1988" was prepared by

24

Mid-State Associates, Inc., in accordance with the requirements of the Wisconsin Racing Board Application for License (Volume IV, Tab 4). An addendum to the Environmental Assessment was prepared by Bischof & Vasseur for the proposed trust acquisition (Volume IV, Tab 3). Based on the findings of the EA and the Addendum, the Superintendent, Great Lakes Agency, found that the proposed action will not have a significant impact on the quality of the human and/or natural environment, and the preparation of an Environmental Impact Statement will not be necessary. The Finding of No Significant Impact was issued on September 14, 1994 (Volume IV, Tab 1).

A Level I Hazardous Waste Survey has not yet been completed. However, we do note that a Phase I Environmental Property Assessment has been prepared by Braun Intertec for the Tribes. It indicates that there are no documented or observable environmental concerns associated with asbestos containing building materials or underground storage tanks. It also states that there is no documented evidence indicating any past or current land-use activities that have had an adverse

environmental impact on the site. We also note that prior to the United States taking the land into trust, a Level I Hazardous Waste Survey must be completed and approved at the Area Office. We will satisfy this requirement under the 25 C.F.R. Part 151 process.

2. Natural and Cultural Resources:

The addendum to the Environmental Assessment states that the proposed facility will have no new significant short-term, longterm, or cumulative impacts on the regional geology, including bedrock and soils, ground water/water quality, or climate (Volume IV, Tab 3).

The Addendum also states that the facility is not expected to impact any natural areas such as native trees or wildlife habitat. Additionally, there are no anticipated impacts from the planned action on wetlands or other surface waters in the area. According to the National Wetlands Inventory Map for the site, there are no designated wetland areas located on the site. rare plant or animal species or other significant natural feature will be adversely impacted.

No

(a) Land_Resources: The topography of St. Croix County ranges from gently rolling to hilly and rough (Volume IV, Tab 4, pages 3 & 4). All of the county has been covered by continental glaciation. The St. Croix River has also had a major impact on the topography of the area. The St. Croix River is bounded by 100 - 200 bluffs along its eastern shore. The Hudson Casino Venture would be located on the plateau above these river bluffs. The site where the proposed facility would be located and the

EOP 064533

immediate area surrounding the site is mostly gently rolling with an average elevation of 840 feet' Id.

The site surrounding the facility is a combination of many soils. Pillot silt loam is the most common Id. The slope of this soil is 0 to 3 percent so runoff is slow and there is slight hazard of erosion. Most of the remaining soil at the site is BurkhardtSattre complex of differing slopes. Since most areas of the Burkhardt-Sattre complex are cultivated, there is no identified erosion or soil blowing problem.

Since the planned action will utilize the existing racetrack facilities, there will be no significant impact on prime or unique farmlands in the Farmland Protection Policy Act (Volume IV, Tab 3, page 3).

(b) Water Resources: The Hudson area has an abundance of groundwater. All potable water used in St. Croix County is groundwater. The supply of water is presently determined by the ability to pump it out of the ground. The source of the groundwater is precipitation (Volume IV, Tab 4, page 3).

The Hudson area surface waters occupy two major drainage systems. The St. Croix River drains the western two-thirds of St. Croix County. The balance of the county is mostly drained by the Chippewa River which flows into the Mississippi River id.

The St. Croix River is located approximately 4800 feet to the west of the proposed facility. There are no other existing surface water bodies in the EA study area Id.

(c) Air Quality: Both the City of Hudson and St. Croix County have stated that the projected traffic increase will not cause the air quality to exceed applicable standards (Volume III, Tab 1, page 1 and Volume III, Tab 2, page 2). Air monitoring stations are currently in place at the track exit and the southeast corner of the Carmichael Interchange to detect any change in the air quality which could be harmful to the area Id (d) Threatened and Endangered Species: St. Croix County is listed as a habitat for the following three endangered or threatened species (Volume IV, Tab 4, page 4):

(1) Peregrine Falcon Potential breeding habitat; Endangered. (2) Bald Eagle Breeding and wintering habitat; Threatened. (3) Higgins Eye Pearly Mussel - River habitat; Endangered. According to the EA, site visits in 1988 to the area around the proposed facility did not detect any of these species Id. The development site may serve as a habitat for the Peregrine Falcon and Bald Eagle. However, none have yet been located. Additionally, there is no habitat for the Higgins' Eye Pearly

26

Mussel at the site. At any rate, the natural area consisting of vegetation or wildlife habitat will not be impacted by the internal construction or additional traffic flow Id.

(e) Cultural Resources: No specific cultural resources or structures are known to exist on the site.

The State Historical Society of Wisconsin has stated that there are no buildings in the study area that are listed in the National Register of Historic places (Volume IV, Tab 2, page 2).

The Mississippi Valley Archaeology Center, Inc., stated that there are no known archeological sites in the proposed project area (Volume IV, Tab 2, page 3).

D. IMPACTS ON THE SOCIAL STRUCTURE IN THE COMMUNITY: Concern over an increase in crime has been expressed by most of those people who wrote to oppose the Hudson Venture. However, none of the letters contained any scientific or statistical evidence to back up this claim. The City of Hudson has stated that similar predictions were made in regard to the St. Croix Meadows dog track before it went into operation in 1990. The City stated, to date, none of the earlier negative predictions: concerning increased crime, etc., have come true... (Volume III, Tab 1, page 2). To prevent any crime escalation in the City of Hudson, and to help offset any fear among the community, the City has stated that they will hire an additional Investigator Crime Prevention Office in the year the Casino is opened (Volume III, Tab 1, page 4). The City also expects the Police Department to expand the police force by five officers and one clerical employee within the next five years Id. Additionally, the Tribes have stated that they are committed to paying for the reasonable costs of these services (Volume I, Tab 1, page 12).

The City stated that the residents of the community have come to accept the dog track's existence and that there is no

overwhelming majority of citizens either in favor of or opposed to the casino (Volume III, Tab 1, page 2). Nevertheless, the city is prepared to handle any negative reaction by the community over the casino.

The current facility is supplied by existing public water, sanitary sewer, electric, and telephone utilities. No additional infrastructure is scheduled to be constructed as part of the proposed action.

EOP 064535