REPORT OF IMPACTS ON NEARBY COMMUNITIES

MOHEGAN SUN MASSACHUSETTS

Off of Thorndike and Breckenridge Streets Palmer, Massachusetts

Prepared for: Mohegan Tribal Gaming Authority 1 Mohegan Sun Boulevard Uncasville, CT 06382

Presented by:

BEALS+THOMAS
BEALS AND THOMAS, INC. Reservoir Corporate Center 144 Turnpike Road Southborough, MA 01772-2104

October 21, 2013

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BEALS+THOMAS
BEALS AND THOMAS, INC. Reservoir Corporate Center 144 Turnpike Road Southborough, MA 01772-2104 T 508.366.0560 F 508.366.4391 mail@btiweb.com I www.btiweb.com Regional Office: Plymouth, MA

October 21, 2013 Mr. Paul I. Brody, Consultant Mr. Gary Luderitz, Vice President Operations and Development Mohegan Tribal Gaming Authority 1 Mohegan Sun Boulevard Uncasville, CT 06382 Via: Reference: email Report of Impacts on Nearby Communities Mohegan Sun Massachusetts Palmer, Massachusetts B+T Project No. 2123.14

Dear Mr. Brody and Mr. Luderitz: We are pleased to submit this Report of Impacts on Nearby Communities, to assist Mohegan Sun Tribal Gaming Authority with negotiations with the surrounding communities to Mohegan Sun Massachusetts Project. This report considers the impacts of the proposed Mohegan Sun Casino resort on the communities near the proposed casino. The report tracks the same technical areas of study that are contained in the Scope of Work prepared by the Pioneer Valley Planning Commission on behalf of the Massachusetts Gaming Commission to study the impacts of the proposed casino. The studies and documents referenced in this report are included as appendices. We thank you for the opportunity to submit this report, and look forward to providing further assistance to Mohegan Tribal Gaming Authority for this project. Very truly yours, BEALS AND THOMAS, INC.

John E. Thomas, PWS Vice President

Mr. Paul I. Brody, Consultant Mr. Gary Luderitz Mohegan Tribal Gaming Authority October 21, 2013 Page 2

Enclosures cc: Toby Arnheim, Mohegan Tribal Gaming Authority Paul Tresnan, Mohegan Tribal Gaming Authority Charles Blanchard, Town of Palmer Town Officials

JET/KDH/mks/212314RP001

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Table of Contents
TABLE OF CONTENTS ............................................................................................................................................ I 1.0 2.0 INTRODUCTION ..............................................................................................................................................1 NEARBY COMMUNITIES..................................................................................................................................1 SUMMARY .......................................................................................................................................................3 CONCLUSIONS ............................................................................................................................................... 10 SUMMARY ..................................................................................................................................................... 11 CONCLUSIONS ............................................................................................................................................... 13 SUMMARY ..................................................................................................................................................... 14 CONCLUSIONS ............................................................................................................................................... 15 SUMMARY ..................................................................................................................................................... 16 CONCLUSIONS ............................................................................................................................................... 17 SUMMARY ..................................................................................................................................................... 18 CONCLUSIONS ............................................................................................................................................... 19 SUMMARY ..................................................................................................................................................... 20 CONCLUSIONS ............................................................................................................................................... 21 SUMMARY ..................................................................................................................................................... 22 CONCLUSIONS ............................................................................................................................................... 23 SUMMARY ..................................................................................................................................................... 24 CONCLUSIONS ............................................................................................................................................... 25 TRANSPORTATION ........................................................................................................................................3 1.1 2.1 2.2 3.0 3.1 3.2 4.0 4.1 4.2 5.0 5.1 5.2 6.0 6.1 6.2 7.0 7.1 7.2 8.0 8.1 8.2 9.0 9.1 9.2

HOUSING ......................................................................................................................................................... 11

ECONOMIC DEVELOPMENT AND FISCAL IMPACT ANALYSIS ..................................................... 14

WATER RESOURCES ................................................................................................................................... 16

ZONING ANALYSIS ...................................................................................................................................... 18

OPEN SPACE PROTECTION ....................................................................................................................... 20

LAND USE DEVELOPMENT IMPACT ASSESSMENT ........................................................................... 22

PUBLIC SAFETY ............................................................................................................................................ 24

FIGURES FIGURE 1: REGIONAL AERIAL MAP FIGURE 2: EXISTING TRAFFIC EXHIBIT FIGURE 3: PROPOSED TRAFFIC INCREASE EXHIBIT FIGURE 4: WATER SYSTEM IMPROVEMENTS AND MITIGATION PLAN FIGURE 5: WASTEWATER SYSTEM IMPROVEMENTS AND MITIGATION PLAN FIGURE 6: EXISTING HYDROLOGY AREAS MAP FIGURE 7: REGIONAL OPEN SPACE PATTERNS FIGURE 8: WETLANDS AND ENDANGERED SPECIES

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APPENDICES EXPANDED ENVIRONMENTAL NOTIFICATION FORM APPENDIX A: ANALYSIS OF THE SOCIO-ECONOMIC AND FISCAL IMPACTS OF THE PROPOSED MOHEGAN SUN APPENDIX B: MASSACHUSETTS CASINO ON THE TOWN OF PALMER ZONING ANALYSIS RELATED DOCUMENTATION APPENDIX C: OPEN SPACE PROTECTION RELATED DOCUMENTATION APPENDIX D:

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1.0

INTRODUCTION Mohegan Tribal Gaming Authority (MTGA, the Proponent) has proposed the construction of an approximately one million square foot mixed-use casino resort (the Project) on a 152-acre lot in the Town of Palmer, Massachusetts. The resort will include a casino gaming area, restaurants, retail space, hotels, and an aqua adventure park facility. In addition, two structured parking garages and several small accessory buildings will be provided to support the operation of the resort. To assist the Proponent in negotiating with communities surrounding the casino development in Palmer, we have prepared this summary of research regarding scope items contained in the Outline for Scope of Work by Regional Planning Agencies (RPAs) on behalf of the Massachusetts Gaming Commission (MGC) for Mohegan Sun/Palmer Proposal Review. These scope items include: Transportation Housing Economic Development & Fiscal Impact Analysis Water Resources Zoning Analysis Open Space Protection Land Use Development Impact Assessment Public Safety

1.1

Nearby Communities Section 2 of Massachusetts General Laws Chapter 23K: The Massachusetts Gaming Commission defines surrounding communities as follows: municipalities in proximity to a host community which the commission determines experience or are likely to experience impacts from the development or operation of a gaming establishment, including municipalities from which the transportation infrastructure provides ready access to an existing or proposed gaming establishment This report considers the impact of the proposed Mohegan Sun resort casino on the Towns that abut Palmer: Belchertown, Brimfield, Ludlow, Monson, Ware, Warren, and Wilbraham. In addition, the report also considers the impact on the Towns of Brookfield, Hampden, Holland, Sturbridge, Wales, and West Brookfield. The Towns of Brookfield, Sturbridge, West Brookfield, and Warren are the only nearby communities that fall within the jurisdiction of the Central Massachusetts Regional Planning Commission; therefore, the majority of the research provided applies to the Pioneer Valley region.

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Table 1-1: Nearby Communities Area (mi2) 32.0 55.4 35.2 16.6 19.7 13.1 28.2 44.8 39.0 16.0 40.0 27.6 21.1 22.4 Approximate Distance from Site to Town Center (mi)1 0.8 8.4 7.0 11.7 8.6 10.9 7.9 5.0 13.2 8.5 7.6 7.4 10.3 6.6 2010 Census Population 12,140 14,649 3,609 3,390 5,139 2,481 21,103 8,560 9,268 1,838 9,872 5,135 3,701 14,219 2011-12 Total Students2 1,854 2,819 597 518 854 392 3,071 1,462 1,688 282 1,461 848 532 2,632 August 2013 Unemployment Rate3 8.1% 6.6% 8.0% 8.8% 6.1% 7.1% 7.4% 6.5% 6.0% 6.8% 7.9% 8.4% 8.6% 6.4% Housing Vacancy Rate4 7.9% 4.2% 10.6% unknown unknown unknown 3.6% 4.6% 9.5% unknown 10.2% 8.6% unknown 3.4%

Town PALMER Belchertown Brimfield Brookfield Hampden Holland Ludlow Monson Sturbridge Wales Ware Warren West Brookfield Wilbraham
1 2

Source: Google Earth aerial imagery dated March 29, 2012 Source: Massachusetts Department of Elementary and Secondary Education 2011-12 School Attending Children Report. For FY2013 data in select towns, refer to Analysis of Socio-economic and Fiscal Impacts. 3 Source: Massachusetts Executive Office of Labor and Workforce Development, Department of Unemployment Assistance. Labor Force, Employment and Unemployment Massachusetts and Cities and Towns. Updated from July 2, 2013 Analysis of Socio-economic and Fiscal Impacts. 4 Source: The Analysis of Socio-economic and Fiscal Impacts of the Proposed Mohegan Sun Massachusetts Casino in the Town of Palmer, prepared by Community Opportunities Group, Inc., dated July 2, 2013.

Please refer to Table 1-1 for nearby community statistics, and Figure 1: Regional Aerial Map for a map of the nearby communities considered in this report.

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2.0 2.1

TRANSPORTATION Summary Vanasse & Associates, Inc. (VAI) has conducted a Traffic Impact Assessment (TIA) (see Appendix A) to determine traffic impacts associated with the development of the proposed Mohegan Sun Massachusetts casino project in Palmer, Massachusetts. The TIA was prepared in consultation with the Town of Palmer and its peer review consultant, Howard/Stein-Hudson Associates, Inc., discussions with several entities within the Massachusetts Department of Transportation (MassDOT), and was performed in accordance with state standards for the preparation of a TIA. Areas of discussion included in this summary include Existing Conditions; Future Traffic Volumes; ProjectGenerated Traffic; Traffic Operations; and the Proposed Mitigation Strategies intended to mitigate the Projects impact at critical locations. Existing Conditions Traffic counts were conducted during the time periods expected to receive the majority of activity from the proposed casino. These time periods were identified by both Mohegan Sun and through VAIs review of Mohegan Sun traffic count data to be Friday afternoonevening and Saturday afternoon-evening time periods, based on peak traffic volumes observed at Mohegan Suns other properties. The Friday afternoon-evening time period also overlaps the exiting employee peak with the arriving casino patron peak. The Friday peak time period was selected to be 3:00 to 6:00 PM and the Saturday peak time period was selected to be 4:00 to 7:00 PM. Traffic counts were collected when public schools were in session and vacations were at a minimal level, thereby providing a conservative worst case analysis. In general, traffic volumes on Friday were observed to peak between 4:30 PM and 5:30 PM while the volumes on Saturday were observed to peak between 4:00 PM and 5:00 PM. The Saturday midday peak time period generally occurred between 11:30 AM and 12:30 PM. Summary of Intersection Conditions Most of the locally originating traffic (expected to originate from locations within 15 miles of the Project) is expected to travel on main routes such as Routes 20, 32, and 181. Intersections along these routes are the main intersections providing access to the Project. Public Transit The Pioneer Valley Transit Authority (PVTA) provides the only transit service in the area. The PVTA currently operates the Palmer Village (PV)/Ware Shuttle (WS) bus that circulates from the Eastfield Mall through the Town of Palmer and passes adjacent to the Site on Route 32 on a 90-minute or greater frequency between the hours of 7:40AM and 8:45PM.

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The Vermonter Amtrak passenger train presently passes through Palmer, on its route between Washington D.C. and St. Albans, Vermont; however, there is no stop at the historic location of the station in Palmer. The train passes through Palmer to continue on tracks owned by CSX, and due to the type of connection made, there is no opportunity for passenger transfer. The route for the Vermonter is undergoing change and will not pass through Palmer in the future. There are no other passenger rail or commuter rail services in the town. Proposed Conditions 2023 No-build Traffic Volumes Traffic volumes in the study area were projected to the year 2023, which reflects a tenyear planning horizon. Independent of the Project, traffic volumes on the roadway network in the year 2023 under no-build conditions include all existing traffic and new traffic resulting from background traffic growth. Anticipated Project-generated traffic volumes superimposed upon this 2023 no-build traffic network reflect the 2023 build conditions for the Project. Future Traffic Growth Traffic-volume data compiled by MassDOT from permanent count stations and historic traffic counts in the area were reviewed in order to determine general background traffic growth trends. Data collected from locations in and surrounding the Town of Palmer indicate that traffic volumes in the area have decreased or stayed consistent since 2000, based on counts conducted by MassDOT. Averaging these data resulted in an annual growth rate of 0.9 percent per year over the next ten years, and 0.5 percent per year over the next twenty years recommended by MassDOT. This rate was used in projections to account for general background growth in traffic attributed to projects not accounted for specifically. MassDOT has filed an ENF related to the proposed All Electronic Tolling System (AETS), which would result in major changes at all existing toll plazas. The tolls are planned to be removed in 2016 as the Department moves away from an exit-based tolling system and towards a mainline-based tolling system. MassDOT has indicated that it is proposing to expedite the AETS project to a 2016 completion date, which would coincide with the proposed completion date of the Project. The proponent will continue to coordinate with MassDOT to assess how automated tolling will affect regional traffic patterns and conditions. There are no other proposed changes or regional roadway improvements expected in the vicinity of the Site that will change traffic flow conditions over the horizon-year time frame. Trip Generation Trips for the casino project were developed using a trip-generation model based on counts of the existing Mohegan Sun Connecticut facility for the peak time periods of the casino, observed to occur on Friday and Saturday between 4:00 PM and 7:00 PM, and on
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Sunday between 3:00 PM and 4:00 PM. The trips for the other uses were developed using the ITE Trip Generation Manual with the various land uses. Adjustments for passby traffic and internal capture between the uses were also included. The proposed Project was estimated to generate the following trip totals for the respective time periods: Table 2-1: Trip Generation Summary Time Period/ Directional Distribution Friday Evening Peak Hour Enter Exit Total Saturday Midday Peak Hour Enter Exit Total Saturday Evening Peak Hour Enter Exit Total Sunday Evening Peak Hour Enter Exit Total Weekday Total Daily Trips (Enter and Exit) Saturday Total Daily Trips (Enter and Exit) Sunday Total Daily Trips (Enter and Exit) Total New Trips from the Casino Project 1,005 836 1,841 995 711 1,706 765 1,078 1,843 771 818 1,589 19,884 23,174 16,160

Trip Distribution The directional distribution of generated trips to and from the casino component of the proposed Project was determined using a population-based gravity model combined with patron data from the Mohegan Sun at Connecticut site. Trips from the other components were distributed using a strict population-based gravity model. Separate trip distributions
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were developed for local (within 15 miles of the Site) and regional trips. In general, this results in the majority of Project traffic assigned to the regional Mass Pike highway (approximately 86 percent), with smaller volumes expected to use the local roadways. The Trip Distribution Summary is shown in Table 2-2. Table 2-2: Trip Distribution Summary Roadway/Direction from/to Percentage Mass Pike/east 43 Mass Pike/west 43 Route 20/west 6 Route 20/east 2 Route 32/south 2 Route 32/north 2 Route 181/north 2 Table 2-3: Access Approach Vehicle arrivals are projected for each roadway as follows: To/From Route 181 W I-90 W I-90 E Route 32 N Route 20 W Route 32 S Route 20 E Local Local Trips <15 mi. 8% 38% 2% 4% 25% 13% 8% 2% 100% Regional Trips >15 Mi. 48% 52%

100%

A summary of existing and proposed Project-generated trips on the local roadways at the boundary of the Town of Palmer under the worst case peak traffic condition of Friday evening has been provided below. Refer to Figures 2 and 3, which show the trips under existing and proposed conditions at these various local roadways leading to the project site from the abutting towns.

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Table 2-4: Existing and Project Trips at the Town of Palmer Borders Roadway/Direction from/to I-90 (at Palmer Exit 8) I-90 (West Wilbraham/Ludlow) I-90 (East Wareham/Brimfield) Route 181 (North Belchertown) Route 32 (North Ware) Route 32 (South Monson) Route 20 (Southwest Wilbraham/Ludlow) Route 20 (Southeast Brimfield) Existing Trips Peak Friday Evening (VPH) 1,782 5,365 4,569 929 1,354 1,023 1,373 1,036 Proposed Increase of Trips Peak Friday Evening (VPH) / % 1,595 / 90% 797 / 15% 798 / 17% 34 / 4% 18 / 1% 42 / 4% 112 / 8 36 / 3%

The traffic analysis estimate that the peak hour Friday afternoon trips through the adjacent towns on local routes will be as follows: Ludlow and Wilbraham Monson Brimfield and Sturbridge Belchertown Ware 112 vehicles 34 vehicles 36 vehicles 34 vehicles 32 vehicles

Estimates for Wales, Holland, West Brookfield, Warren, and Brookfield were not generated, but the roadway network indicates that these towns would likely experience less than 10 trips during the Friday peak hour. Build Condition Traffic Volumes and Structured Improvements The 2023 build condition traffic-volume networks were developed by adding Projectgenerated traffic to the 2023 no-build peak-hour traffic volumes. The proposed Project was shown to result in peak-hour traffic-volume increases on the study area roadway network as noted above in Table 2-4. Extensive mitigation has been identified to address these increases. At some local intersections within the Town of Palmer that impact neighboring communities, improvements were identified to address either deficiencies related to delays, safety/crash history, or changes to LOS caused by the Project. Exhibit plans of these locations are provided in Appendix A. A list of the improvements is tabulated in Table 2-5.

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Table 2-5: Proposed Local Intersection Mitigation Summary

Location Route 181/ at Thorndike Road Measure Realign Thorndike Road approach 2" Mill and Overlay, Pvmt Mkgs Comment "T" type intersection Intersection plus 100 feet New span poles, LED signal heads, APS ped heads/poles, geometric modifications, Opticom, controller, pull boxes, conduit, and signage as needed, etc. Monument relocation, potential park replication Intersection plus 200 feet Addressing grade changes Intersection plus 200 feet New mast arms, signal heads, ped heads/poles geometric modifications, Opticom, controller, pull boxes and conduit as needed, etc. Intersection plus 100 feet Full depth reconstruction on Breckenridge Street Intersection plus 100 feet Full depth reconstruction possible, bridge impacts, etc. Evaluate mini-roundabout and other alternatives Intersection plus 100 feet Full depth reconstruction possible, bridge impacts, etc. Evaluate mini-roundabout and other alternatives Intersection plus 100 feet and Stone Street

Route 181/North Main Street at Route 20/Wilbraham Street

Replace signal equipment

Streetscape Improvements 2" Mill and Overlay Driveway modifications Pavement Markings and Signage

Route 20/Main Street at Route 32/Thorndike Street

Replace existing traffic signal

2" Mill and Overlay, Pvmt Mkgs Route 20/Route 32/Park Street at Breckenridge Street Right-Turn Lane installation 2" Mill and Overlay, Pvmt Mkgs Route 20 Route 32/Park Street at Stone Street Right-Turn Lane installation Road Safety Audit 2" Mill and Overlay, Pvmt Mkgs Route 32/Main Street/Stone Street at South Main Street Right-Turn Lane installation Road Safety Audit 2" Mill and Overlay, Pvmt Mkgs

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Location

Measure

Comment New mast arms, signal heads, ped heads/poles geometric modifications, Opticom, controller, pull boxes and conduit as needed, etc. Intersection plus 100 feet and Thorndike St. between int. 5 and int. 9

Route 20/Route 32/Park Street at Thorndike Street

Replace existing traffic signal 2" Mill and Overlay, Pvmt Mkgs

Travel Demand Management (TDM) Measures Reducing the volume of traffic generated by the proposed development is an important component of the transportation mitigation plan. The goal of the proposed traffic reduction strategy is to reduce the use of single-occupant vehicle (SOV) travel by encouraging car/vanpooling, bicycle commuting, the use of public transportation and pedestrian travel. Public Transit The Project Proponent will coordinate with the PVTA to discuss the location of a bus stop for the Palmer Village/Ware Shuttle (PV/WS) route that would be close to or on the Project Site. In order to encourage the use of public transportation, the Proponent will make available public transportation schedules, which will be posted in centralized locations for employees and patrons. In addition, the Proponent will investigate providing a shuttle bus for employees and/or patrons from a centralized location, potentially in the downtown area or if demand exists from a remote location such as Springfield or Ludlow. Dedicated Bus Service Many patrons travel to the Mohegan Sun Connecticut casino via private bus service. The Proponent expects to implement a similar bus program at the Massachusetts Site, and has designed the Site to accommodate bus circulation. These buses are expected to come from other locations in Massachusetts, Vermont, Connecticut, New Hampshire, and Maine, and New York. With a seating capacity of 40 patrons per bus, use of this High Occupancy Vehicle (HOV) mode will reduce congestion on the roads leading to the Site. Approximately 18 to 22 buses are expected on a daily basis at the Palmer Site, exclusive of any shuttle bus service or PVTA public transit bus service that may be provided at the Site. Ridesharing In order to encourage car/vanpooling, the property management team will coordinate with MassRIDES and the Town of Palmer to identify car/vanpool resources that may be available to employees of the proposed Project. This information will be posted in a centralized location for the residents. MassRIDES can provide customized commuter events, transit assistance, carpool matching and vanpool formation, among other services.

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Retail tenants will be encouraged to provide information on MassRIDES services including ride matching databases to their employees in an effort to decrease SOV travel. Commuter Choice Program In addition to the above services, MassRIDES can assist employers with developing commute tax programs for their employees. Such programs allow employees to set aside a portion of their pre-tax income for commute-related expenses, which could include transit or car-pooling. Regional Events Unlike other Mohegan Sun casino resorts, the proposed Palmer complex includes fairly small entertainment venues (e.g. cinema), averaging 36,000 sf with minimal events. Therefore, the egress of a large volume of traffic at one time is not anticipated. As for community-type events such as the Brimfield Fair, traffic counts were conducted at the time of the fair and only a daily 2% increase in traffic was noticed on Route 32. Another, much larger local event is the Big E in Springfield. Most attendees of the Big E will travel on the Mass Pike, exiting at the Springfield and/or Ludlow exits, therefore not impacting Palmer, its nearby communities, or local roadways. 2.2 Conclusions Based on the TIA, the proposed Project can be accommodated on the roadways with a measurable but not a significant impact on overall traffic operations in Palmer. As presented above, 86% of the projected traffic will access the Project via the Mass Pike, with of the balance of the trips generated from Palmer and the Towns of Belchertown, Brimfield, Monson, Ware, Warren, and Wilbraham. Also, 74% to 80% of visitors are expected to visit from greater than 15 miles from the towns abutting Palmer. The roadways in the regional network have ample capacity to accommodate the additional traffic generated by the casino project. Although overall daily traffic volumes will increase, the trips will be distributed throughout the day with minimal impact beyond the Town of Palmer, as opposed to a facility that hosts frequent large events, which is not being contemplated by the proposed project. Refer to Figures 2 and 3, which show the actual trips under existing and proposed conditions at these various local roadways leading to the project site from abutting towns.

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3.0 3.1

HOUSING Summary Valley Vision 2: The New Regional Land Use Plan for the Pioneer Valley, prepared by the Pioneer Valley Planning Commission, notes an increase in housing costs in both Hampden County and Hampshire County from 1992-2005. Many housing units were built in the region from 1990-2000, but the region underwent a small population increase relative to the level of development during the same time period. As a result, several towns and cities in the region, such as Palmer, Springfield, and Chicopee, have a large number of housing vacancies, contributing to an effect the plan calls sprawl without population growth. Refer to the figures from Valley Vision 2 reproduced below for a map of these regional trends, and to Table 1-1 for town-specific vacancy rates. Housing Growth (1990 2000)

Source: Valley Vision 2: The New Regional Land Use Plan for the Pioneer Valley, prepared by the Pioneer Valley Planning Commission, dated September 2007

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Urban Flight Creates Vacancies

Source: Valley Vision 2: The New Regional Land Use Plan for the Pioneer Valley, prepared by the Pioneer Valley Planning Commission, dated September 2007

The Analysis of Socio-economic and Fiscal Impacts of the Proposed Mohegan Sun Massachusetts Casino in the Town of Palmer, prepared by Community Opportunities Group, Inc., indicates that regional real estate values will not be impacted by the Project. Several case studies on other casino resort towns were performed, and none of the assessors or building department officials noted a significant change in real estate values, aside from the increased value of the casino properties. It is anticipated that the Proponent will directly employ approximately 3,150 employees in the casino, hotel, aqua adventure park, retail, and food service facilities. The average wage of the 1,980 employees at the casino resort is anticipated to be $41,100. Due to the high unemployment rate in the region, it is possible that jobs will be filled by residents of Palmer and the nearby communities, producing no need for additional housing. While there will likely be an increase in the number of employees who move to the region, the region may have a sufficient supply of vacant housing to accommodate the increase. The Projects proximity to the Massachusetts Turnpike and other state routes will also allow employees to come from a larger geographic range, including Springfield, Worcester, Holyoke, and several northern Connecticut towns. See the following figure for regional housing sale price trends from 2002-2011

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Regional Housing Sale Prices, 2002-2011

Source: The Analysis of Socio-economic and Fiscal Impacts of the Proposed Mohegan Sun Massachusetts Casino in the Town of Palmer, prepared by Community Opportunities Group, Inc., dated July 2, 2013

3.2

Conclusions While initial research indicates that there is available housing to accommodate employees who move to the region, further research and inventory of the housing situation in the nearby communities as proposed by the PVPC and the CMPC appears to be warranted, and will allow for a fuller review of the impacts. Refer to Appendix B for the referenced socioeconomic study.

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4.0 4.1

ECONOMIC DEVELOPMENT AND FISCAL IMPACT ANALYSIS Summary Analysis of Economic Development Projections Communities with the largest existing economies include Ludlow, Palmer, Sturbridge, and Ware. These economies are based primarily on industrial manufacturing, cargo service, health services, and retail trade. Sturbridges economy is based largely on tourism. For towns with smaller economies, most existing jobs are in the fields of municipal employment, education, manufacturing, transportation, and warehousing. Average businesses in the study area are small, most with 12 employees or fewer, suggesting a more locally-focused economy. The unemployment rate for the region is 8.3%. Individual town unemployment rates are included in Table 1-1 above. The Project is expected to create approximately 6,900 person-years of construction jobs, nearly 4,000 directly due to the construction, and more than 2,900 indirect/induced from construction. The operation of the project will support approximately 3,150 direct and permanent jobs. Over 900 indirect and induced jobs in the retail, finance, insurance and real estate sectors in the region are also anticipated once the Project is fully operational. Construction will require an estimated $230 million in materials, some of which could be provided by local businesses. Additional opportunities for purchases from local businesses include furniture, fixtures, and electronics. It is also anticipated that workers who commute to the region will patronize local businesses, creating a positive economic benefit to the region during the construction period. Existing local businesses may also be able to annually provide the Project with goods and services such as food supplies, advertising, and transportation, in the long-term. Existing small businesses in the region may see an increase in spending from both casino visitors and employees. In addition, new businesses that cater to casino visitors, such as hotels, restaurants, and retail outlets, may be developed. While it is possible that local entertainment venues may see a decrease in patronage, the overall impact on small businesses is anticipated to be positive due to the increased local spending from the casino, its patrons, and its employees. Refer to Table 1-1 for the distance from the Site to the nearby community town centers, and Section 6.0 for a more detailed discussion of town commercial centers. Revenue Implications of Casino Development Plan As discussed above, small business growth in the region resulting from the Project is a potential revenue source for nearby communities. Nearby communities that have instituted a local meal or room occupancy tax may see revenue from casino visitors. In addition to these potential sources of local revenue, state revenues such as the one-time licensing fee and annual gaming tax will help to establish the Local Capital Projects Fund and the Gaming Local Aid Fund, which aim to offset any potential negative impacts to host communities and nearby communities.
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Expenditures As discussed in Section 9.0 below, it is anticipated that improvements to Town of Palmer Fire, Police, and Public Works departments that committed to under the Host Community Agreement will meet the increased demand for these services without the need for support from the nearby communities. The Towns of Palmer, Ludlow, Belchertown, Ware, and Monson, operate local K-12 school districts, while Wilbraham, Warren, Brimfield, and Sturbridge belong to regional school districts. According to the Massachusetts Department of Elementary and Secondary Education statistics, school enrollment in the Town of Palmer has decreased 29.3% from 2001 to 2012. In Ware, the nearby community in closest character to Palmer, the school district has a 3.5% drop in enrollment in the same time period. Evidence suggests that enrollment in regional schools has risen, so trends in school enrollment for nearby communities are difficult to determine. Refer to Table 1-1 for school enrollment figures for each town in the study area. It is not anticipated that nearby communities should see a notable increase in expenditures resulting from the Project. This will need to be confirmed by the housing study, as any new demand on the educational system from an increase in students will be a consequence of new housing resulting from the casino project. 4.2 Conclusions The construction period will an opportunistic time for businesses in the region to capitalize on the expenditures made by the work force. Upon operation of the casino project, the regional draw of visitors to the destination resort will provide additional opportunities for businesses to attract passersby from the modest increase in traffic on the regional roadway network. Operation of the casino will require services from a wide variety of businesses in the region. Although no direct revenue from the casino project will be realized by nearby towns, and the fact that direct business benefits cannot be identified, increased business activity in the region will clearly benefit the regional economy. Refer to Appendix B for the referenced socioeconomic study, and Appendix A for the Host Community Agreement.

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5.0 5.1

WATER RESOURCES Summary Water Supply The daily water demand for the Project is estimated to be in the range of approximately 280,000 to 320,000 gallons per day (gpd). Water to the Project Site will be provided by the Palmer Water District #1, a quasi-public water company that serves a portion of the Town of Palmer. Several improvements to the water supply infrastructure have been identified in order to meet the calculated demand, including interconnection with the Town of Monson Water Department. The water demand calculations and proposed infrastructure improvements have been presented to the Monson Board of Water Commissioners, who reviewed and concurred with the conclusions. It is anticipated that water demand will be accomodated by the existing and improved infrastructure in Palmer and Monson, and will not impact any other nearby communities. Refer to Appendix A for the referenced calculation and design documents, and Figure 4: Water System Improvements and Mitigation Plan. Wastewater The Town of Palmer operates and maintains a municipal wastewater treatment facility (WWTF), approximately two miles northwest of the Project Site. This facility also services the Towns of Monson and Belchertown. The facility has adequate capacity for additional sewage flow generated by the Project. The Proponent has committed to funding a portion of the design improvements to the municipal sewer system in order to accommodate the estimated Project flow of 280,000 to 300,000 gpd. However, a wastewater treatment plant with a capacity of approximately 120,000 gpd utilizing a membrane bioreactor (MBR) will be constructed at the Site to reclaim treated effluent for toilet flushing, cooling water, and irrigation water. This will reduce the average daily discharge from the Project to the Palmer WWTP to approximately 175,000 gpd to 225,000 gpd. Other proposed sewer improvements, including new sewers and pump stations, will allow capacity for additional development unrelated to the Project. Due to the large amount of proposed water reclamation, and sufficient sewer capacity within the Town of Palmer, wastewater generated by the Project will not impact the nearby communities. In regard to the Host Community Agreement, the Proponent has committed $500,000 for removal of infiltration/inflow (I/I) to the WWTF, benefitting both Monson and Belchertown. Refer to Appendix A for the referenced calculation and design documents, and Figure 5: Wastewater System Improvements and Mitigation Plan. Stormwater Management The stormwater runoff from the Site drains to four primary locations within the Town of Palmer. Refer to Figure 6: Existing Hydrology Areas Map. All stormwater from the site flows to streams within the Quaboag River watershed. The entire length of the Quaboag River is a Class B water, which is suited for uses such as a wildlife habitat, primary and secondary contact recreation, and irrigation. The Quaboag River merges with the
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Chicopee River in Palmer which flows to the Connecticut River in Chicopee. The stormwater management system for the Project will be designed to provide treatment and detention for stormwater runoff associated with the proposed impervious surfaces on Site. All stormwater BMPs will be designed to treat a minimum of the first 1-inch of runoff generated by the on-site impervious areas, will comply with MassDEP stormwater standards, and will incorporate low impact development (LID) techniques where appropriate. The stormwater BMPs will provide sufficient detention to prevent an increase in the volume of stormwater discharging from the site. Due to the localized treatment of runoff, stormwater flows generated by the site will not impact the nearby communities. Other efforts to secure water quality include the Storm Water Pollution Prevention Plan (SWPPP) and the Site Owners Manual. Refer to Appendix A for these documents. 5.2 Conclusions Water and sewer demands of the Project have been calculated, and infrastructure improvements in Palmer including the connection to Monson will adequately serve the Project without adversely affecting any nearby community. Stormwater flows from the Project will not degrade the Quaboag River, its Class B designation, and the existing activities of the river.

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6.0 6.1

ZONING ANALYSIS Summary The entire Project site is located within the Highway Business zoning district in the Town of Palmer. The purpose of the Highway Business district as articulated in the Town of Palmer Zoning Ordinance is to allow auto-accommodating commercial development in areas along highways that have already been predominately built in this manner and in some new areas. The proposed Project is consistent with this use. Many of the nearby communities have Rural Residential zoning districts which take up the majority of the towns. More developed communities such as Ware have Suburban and Downtown Residential Districts in addition to the Rural districts. The Towns of Belchertown, Hampden, Monson, and Wilbraham have Residential Multiple Dwelling districts, while the Town of Brimfield has designated their Multiple Dwelling District for the elderly. The Analysis of Socio-economic and Fiscal Impacts identifies the trade, finance, insurance, and real estate sectors as probable sources of induced economic development in the region resulting from the Project. Although the majority of the visitors to the site would arrive via the Massachusetts Turnpike, it is likely that the area along Route 32 would be targeted for any commercial development. In the Town of Monson to the south of the Project site, development on Route 32 consists of residential and rural residential properties, but several centers have been targeted for commercial and industrial development. Most of the Town of Monsons industrial and commercial development zones directly abut or are easily accessible from Route 32. Similar conditions exist along Route 32 in the Town of Ware to the north of the Project site. Town centers for other nearby communities are generally zoned for commercial or industrial use. Some more rural communities like Warren have zoned their town centers as Village, which allows both economic and residential development. It is anticipated that existing commercial zoning can accommodate economic development yielded by the Project. Refer to Table 1-1 for the distance from the Site to the nearby community town centers. The Project includes construction of two structured parking garages as well as surface parking which will accommodate all visitors to the project, so parking is not anticipated to impact the nearby communities. For a discussion of potential housing development, see Section 3.0.

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6.2

Conclusions The Project has been designed in harmony with the purpose of the underlying zoning district in the Town of Palmer. Any new development resulting from the Project in the nearby communities is anticipated to be very modest. Existing zoning in the region appears adequate to accommodate economic or residential growth from the casino project. Refer to Appendix C: Zoning Analysis Related Documentation for copies of available town zoning maps.

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7.0 7.1

OPEN SPACE PROTECTION Summary The Project site is located adjacent to open space designated for the Palmer Reservoir. Due to its protected status as a Public Water Supply contributor, this open space area will not be impacted by the proposed development, or any other development on the Project site. Other open space and recreational facilities near the Project are located approximately 1,200 feet to the south of the Project site at the location of the Converse Middle School. The Quabbin Reservoir, located in the north of Belchertown and Ware represents the largest area of protected open space in the region, and is located approximately 7.0 miles from the Project Site. State parks located near the Project include Red Bridge State Park in Ludlow (4.5 mi), Ludlow State Park (5.3 mi), Brimfield State Park (5.7 mi), and Wells State Park in Sturbridge (12.4 mi). Based on MassGIS information, designated open space parcels are located sporadically throughout the region; therefore, the Project will not disrupt any regional open space connectivity patterns. Refer to Figure 7: Regional Open Space Patterns. On-Site wetland resource areas as defined by the Massachusetts Wetlands Protection Act and the Town of Palmer Wetland Bylaw and Regulations consist of Bank, Bordering Vegetated Wetland (BVW), Isolated Vegetated Wetland (IVW), and Land Under Water Bodies and Waterways (LUWW). Two certifiable vernal pools are also located on-Site. Based on a hydrologic analysis, the wetlands in the north of the Site drain to a perennial stream flowing southwest along Thorndike Street/Route 32. Wetlands in the southern half of the Site generally drain to the east towards a culvert beneath Thorndike Street/Route 32 to an off-Site wetland system.. No regional wetland impacts have been identified. Impacts to the on-Site wetland systems resulting from the Project will be avoided and minimized where possible, and mitigated where alteration occurs. Refer to Figure 8: Wetlands and Endangered Species for wetlands in the region surrounding the Project, and Appendix D: Open Space Protection Related Documentation for detailed onSite wetlands. Based on the Natural Heritage Atlas effective October 1, 2008, and confirmation with MassGIS on September 25, 2013, the Project Site contains no mapped priority or estimated habitat for rare species. The nearest rare species habitats are located in the area surrounding the Quaboag and Chicopee Rivers, 4,000 feet or more away from the Project Site. These water resources will not be impacted by the Project, and therefore no impact on rare species in the region can be expected. Refer to Figure 8: Wetlands and Endangered Species for the location of rare wildlife habitat relative to the Project.

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7.2

Conclusions Although the Project site will be developed for commercial purposes, no regional impacts to open space or recreation facilities are anticipated. Wetland impacts will be avoided to the extent practicable. Unavoidable impacts to wetlands will be minimized, and mitigated, and will not affect the regional wetland systems. No rare species habitat is located near the Project Site, and the remote habitat will not be impacted.

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8.0 8.1

LAND USE DEVELOPMENT IMPACT ASSESSMENT Summary The Project has undertaken several Smart Growth strategies outlined in Valley Vision, the applicable regional plan. The Project will pursue Gold Leadership in Environmental and Energy Design (LEED) certification, and will offset energy use with photovoltaic arrays, in compliance with Strategy #13: Encourage Sustainable Design. These sustainable design elements will reduce the environmental impact of Project development on the region. The Project has also undertaken Smart Growth Strategy #12: Improve Infrastructure in Urban Areas and Limit Infrastructure Expansions. The Project will make use of existing water and sewer infrastructure to service the Site, and additional improvements to water and sewer infrastructure will benefit two nearby towns. As discussed in Section 5.0, it is anticipated that water infrastructure needs of the Project will be met by the Towns of Palmer and Monson, and will not impact other communities. Sewer pump station improvements will benefit Monson and Belchertown. The Project also addresses elements of the Pioneer Valley Planning Commission Regional Transportation Plan, which lists Massachusetts Turnpike Off Ramp Congestion Project as a high priority project for 2011-2014. The Plan identifies Exit 8 of the Mass Pike, which will serve the Project Site, as suffering particularly long delays. The proposed transportation improvements discussed in Section 2.0 above at the intersection of Route 32 and Mass Pike Exit 8 will benefit the entire region. The noise associated with the permanent operation of the Project is anticipated to include the heating, ventilation and air conditioning (HVAC) systems for Project buildings, the outdoor recreational facilities, and increased vehicle traffic. Methods to avoid, minimize, and mitigate noise impacts will be developed as the building design progresses. Directed exterior lighting, including the use of energy efficient LED technology, is also being considered. The wooded area surrounding the Project will provide a natural buffer against light and noise to the immediate area. The Project is located approximately one mile away from the boundary of Monson, the closest abutting town. Due to the distance between the Project Site and nearby communities, noise and light impacts are not expected. Refer to Table 8-1 for the closest distance from the Site to the nearby community boundaries.

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Table 8-1: Distances to Town Boundaries Town Belchertown Brimfield Brookfield Hampden Holland Ludlow Monson Sturbridge Wales Ware Warren West Brookfield Wilbraham

Distance from Site to Town Boundary (mi) 2.4 2.8 8.8 5.4 8.5 3.9 0.9 9.5 5.8 3.6 3.2 7.8 3.6

Source: OLIVER: MassGISs Online Mapping Tool

8.2

Conclusions The Project has incorporated several Smart Growth design elements consistent with regional planning documents, which will positively impact nearby communities. It is not anticipated that noise and light generated by the Project will impact nearby communities.

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9.0 9.1

PUBLIC SAFETY Summary Based on analysis of previous casino resort operational data, The Analysis of Socioeconomic and Fiscal Impacts anticipates that the Project will have limited long-term impacts on local fire department services, whereas short-term impacts will consist mostly of inspectional services during the construction period. While it is certain that the regional community will see an increase in demand for Emergency Medical Services (EMS) and police response, particularly drunk/disorderly complaints, case studies indicate that these incidents were met by local departments with minimal increase in capacity. The Town of Palmer is serviced by a full-time Police Department with 20 personnel. Palmer is also serviced by three fire districts. The Project is located within the Palmer Fire District No. 1. EMS for Palmer is provided by the non-profit Palmer Ambulance Service, Inc. The same dispatch covers fire, police, and EMS services. As part of the Host Community Agreement between the Town of Palmer and Mohegan Sun Massachusetts, LLC, passed by the Palmer Town Council on September 3, 2013, the Proponent has agreed to pay fees to offset the demand on Town services created by the Project. This Departmental Mitigation Program consists in part of: An annual payment applied to the Police Department for the hiring and training officers and dispatchers, and the purchase of new cruisers and other equipment, as well as a one-time fee for expansion of the department and training existing officers. An annual payment applied to the Fire District for the hiring and training officers and dispatchers, as well as a one-time payment for the purchase of specialized equipment and temporary fire inspection services. An annual payment applied to Palmer Ambulance Service provider to increase the staff and maintain equipment, as well as a one-time fee for the purchase of a new ambulance and expansion of the ambulance garage. It is anticipated that these improvements will address the increased demand for emergency and public safety services in Palmer where the need for these services will arise. Reliance on services from the nearby communities to address public safety needs is not anticipated. The Massachusetts State Police and MGC will have a presence at the facility for law enforcement and public safety purposes. Additional mitigation measures, particularly in regard to problem gambling, will also be provided as part of the license application process with the MGC. Refer to Appendix B for the socioeconomic study, and Appendix A for the Host Community Agreement.

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9.2

Conclusions Improvements to the public safety services within the Town of Palmer will accommodate the great majority of emergency response items. The modest increases in traffic on the regional roadway network will have a direct relationship on the traffic accidents and violations over time, but will not require any increase in staffing as a consequence to address daily conditions. It is not anticipated that public health concerns could spread to nearby communities.

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Appendices* *Appendices found on FTP site. See instructions on the following page.

FTP ACCESS INSTRUCTIONS

A folder has been created for you on the B+T FTP server. IP Address: 71.11.7.37 Username = user2123-1 Password = uhvRGN013 Folder = 2123-1 * username and password are case-sensitive Instructions for Accessing Your FTP Folder Using Windows Explorer (not Internet Explorer) 1. Launch Windows Explorer (or My Computer) 2. Enter ftp:// 71.11.7.37 in the address bar 3. Enter the provided username and password 4. Click 2123-1 5. Copy files from folder as needed (or paste files to) Using Internet Explorer (for downloading files only): 6. Launch Internet Explorer 7. Enter ftp://71.11.7.37 in the address bar 8. Enter the username and password indicated above 9. Click BTI_FTP 10. Click 2123-1 11. Right click and select Save target as . . . Use your favorite FTP client software. Filezilla is a free download (http://filezillaproject.org/) we use it here at B+T. Other FTP client software include CuteFTP, WSFTP, etc. Using the FileZilla FTP client software: 1. Launch FileZilla. 2. Enter the Host (71.11.7.37). 3. Enter the Username and Password. 4. Click Quickconnect. 5. Browse to the Remote Site folder. (The folder created for the client. The pane on the right-side of the application window.) 6. Browse to the Local Site folder. (The pane on the left-side; this is where you will upload your files from or download your files to.)

Appendix A Expanded Environmental Notification Form

For documents referenced in this report, refer to the following sections within the EENF:

Appendix E: Stormwater Technical Information Appendix F: Water System Technical Information Appendix G: Wastewater System Technical Information Appendix H: Transportation Technical Information Appendix I: Host Community Agreement

Appendix B - The Analysis of Socio-economic and Fiscal Impacts of the Proposed Mohegan Sun Massachusetts Casino in the Town of Palmer

Appendix C Zoning Analysis Related Documentation Zoning Map for the Town of Brimfield, Massachusetts Town of Brookfield Zoning Map Monson, Massachusetts Municipal Zoning Districts Palmer, Massachusetts Zoning Map Town of Sturbridge Zoning Districts Zoning Maps of the Town of Ware Zoning Map of Warren, Massachusetts Zoning Map Town of Wilbraham

Appendix D Open Space Protection Related Documentation Request for Determination of Applicability