Letter SaveFMCP To Gaming Facility Location Board

SAVE FLUSHING MEADOWS-CORONA PARK
146-24 32nd Avenue

Flushing, New York 11354
January 30, 2023
Ms. Quenia A. Abreu

President
New York Women’s Chamber of Commerce
1524 Amsterdam Avenue
New York, NY 10031
Vicki L. Been, Esq.

New York University School of Law
40 Washington Square South
Vanderbilt Hall, #314H
New York, NY 10012-1005
Stuart Rabinowitz, Esq.

Meltzer, Lippe, Goldstein & Breitstone
190 Willis Avenue
Mineola, NY 11501-2672
Re: Record of public opposition to Citi Field area as potential casino site, and failure
of NYS Gaming Commission to produce statutory report acknowledging same
Dear Ms. Abreu, Ms. Been and Mr. Rabinowitz:
I am writing to each of you in your capacity as a member of the Gaming Facility Location
Board (“Location Board”). I write on behalf of a coalition of Queens community leaders, business
owners and civic organizations who strongly oppose the potential designation of the Citi Field
stadium area in northeast Queens as a casino site. This includes the public parkland located west
of Citi Field, and Willets Point property located east of Citi Field.
The first opportunity for public participation in the Zone 1 casino licensing process came
in 2021, when, as required by law, the NYS Gaming Commission (“Gaming Commission”) issued
a Request for Information for Unawarded Casino Licenses (“RFI”). The RFI solicited responses
not only from prospective casino developers, but also from “neighborhood associations” and other
“affected parties” who may be impacted by a casino site decision. Notably, the RFI specifically
asked whether any geographic area should be excluded from consideration as a potential casino
site.
Several members of our coalition – including the Queens Civic Congress (an umbrella
group representing more than sixty civic organizations throughout the borough of Queens) –
submitted written responses to the RFI, providing detailed explanations why the Citi Field area is
inappropriate for casino use and should be excluded from consideration. To appreciate the depth
of information we provided, note that it included explanations of the legal status of property west
of Citi Field as public parkland, as well as government-approved traffic studies pertaining to four
projects in the Citi Field area, admitting severe traffic gridlock which an added casino would
exacerbate.
The same law that required the Gaming Commission to issue the RFI – Part Z, Chapter
59 of the Laws of 2021 (“Part Z”) – also specifies that the Gaming Commission “shall prepare and
distribute a report with the results of the request for information to the governor and the legislature
no later than six months after receiving such information.” Moreover, the RFI text proclaims to
prospective respondents, under the bold heading “REPORT TO BE ISSUED”:
“The Commission is obligated to prepare and distribute a report with the results of
the RFI to the Governor and the State Legislature no later than six months after
receiving such information.”
Had the Gaming Commission ever prepared the statutory report, it would have had to
acknowledge the numerous objections raised to the Citi Field area as a potential casino site, and
the many reasons therefor. Those objections would have been conveyed to the governor and the
legislature, had the Gaming Commission distributed the report as required by Part Z. If the report
existed, we would have furnished it to you. However, the Gaming Commission did not prepare
the report.
We will not sit idly by as the Gaming Commission blunts the impact of significant public
comments by failing to digest and incorporate them into a required report. To ensure that the
Location Board is aware of the specific objections already raised to the Citi Field area as a
potential casino site, and the many reasons therefor, attached please find all of the material
that our coalition members submitted to the Gaming Commission in response to its RFI.
We are well aware that the casino site selection process will provide future opportunities
for public comment. But our present concern is to ensure that proper attention is paid to significant
public comments already duly submitted, at the earliest opportunity in December 2021, strongly
objecting to the Citi Field area as a potential casino site.
Although this cover letter is primarily to convey the attached RFI response material, I
cannot close without also refuting the Gaming Commission’s excuse for not preparing the
statutory report. Prior to the report’s return date, the legislature enacted Part RR, Chapter 56 of
the Laws of 2022 (“Part RR”), which establishes a process to consider and award casino licenses.
The Gaming Commission claims that the enactment of Part RR relieves the Gaming Commission
of its obligation to prepare the report required by Part Z. We disagree, for at least the following
reasons:
• Part RR does not explicitly repeal Part Z or its requirement for a report of the results
of the RFI. Had the legislature intended to repeal Part Z or any portion thereof, it
knew how to do so.
• Part RR does not implicitly repeal Part Z or its requirement for a report of the results
of the RFI. Nowhere does Part RR conflict with Part Z or its requirement for the
report. We understand that for implicit repeal to occur, two legislative acts must be
irreconcilable, clearly repugnant, and so inconsistent that the two cannot have
concurrent operation – which is not the case between Part Z and Part RR.
• Although Part RR establishes a process to consider and award casino licenses,

informing such a process was just one of the purposes of the RFI and report
required by Part Z. Other purposes of the RFI and report required by Part Z were
to inform determinations of “the appropriate size and scope of [casino]
development” and “the value of the gaming facility license” – each of which
Page 2 of 3
remained undetermined even upon enactment of Part RR, and subject to further
decision-making. Similarly, questions raised within the RFI -including whether any
geographic area should be excluded from consideration as apotential casino site
-remained undetermined even upon enactment of Part RR. Thus, even after
enactment of Part RR, there still were unresolved issues which the RFI was
intended to inform, and there still was arole for areport of the results of the RFI.
●The RFI solicited public comments, while expressly informing the public that the
information received would be incorporated into areport to the governor and the
legislature. Having made that representation to the public, the Gaming
Commission cannot renege.
●Requiring the Gaming Commission to produce areport of the results of the RFI,
as the legislature did in enacting Part Z, serves the purpose of compelling the
Gaming Commission to actually review, digest and assimilate each of the RFI
responses, as necessary to distill that information into aformal report. But under
the present circumstance, when there is no report, nothing demonstrates that the
Gaming Commission ever did anything with the RFI responses (which include
significant public comments) beyond relegating them to an online repository.
Finally, Inote that posting 31 separate RFI responses at an online repository cannot
substitute for areport that would consolidate and summarize the RFI results in one convenient
document. Whereas Part Zrequires distributing the report directly to the governor and the
legislature, there is no assurance that either the governor or legislators are aware that individual
RFI responses are posted online, let alone that they will seek out and review 31 individual RFI
responses at an online address.
The RFI responses that warn against the Citi Field area as apotential casino site
(attached) are avery important part of the record in this matter, and we request that you please
read them.
Sincerely,
c y
Paul Graziano
Spokesperson, coalition membership
Save Flushing Meadows-Corona Park
w w w. s a v e f m c p . o r g
6enclosures
Page 3of 3
Queens Civic Congress, Inc.
RFI Response
C O V E R L E T T E R Via email only
N.Y.S. Gaming Commission

Office of the Secretary, 5th Floor
One Broadway Center
Schenectady, New York 12305
Via email to: Kristen.Buckley@gaming.ny.gov, Stacey.Relation@gaming.ny.gov,

Alysan.Bowers@gaming.ny.gov
December 6, 2021
Dear NYS Gaming Commission:
Enclosed please find a letter including comments from the Queens Civic Congress with several
comments and concerns regarding the RFI Issued on October 20, 2021, pertaining to potential
licensing of casino facilities in downstate New York, in particular a potential proposal located at
or near Citi Field in Northeast Queens.
Below is the organization’s information as requested in the RFI.
• Submitter’s Name – Queens Civic Congress, Inc.
• Contact Name and Title – Kevin J. Forrestal, President
• Contact Telephone Number – 718-374-1359
• Contact Email Address – kjforrestal@gmail.com
• Mailing Address – 82-36 166th Street, Hillcrest Estates, NY 11432-1218
We hope you will seriously consider impacts to Queens communities. Please keep Queens Civic
Congress apprised of any future proposals or hearings on this or any related project.
Sincerely
Kevin J. Forrestal, President

One Broadway Center
Via email to: Kristen.Buckley@gaming.ny.gov, Stacey.Relation@gaming.ny.gov,

Alysan.Bowers@gaming.ny.gov
December 6, 2021
This letter is in response to your Request for Information (RFI) dated October 20, 2021, pertaining to
potential licensing of casino facilities in downstate New York.
Queens Civic Congress is an umbrella group representing over sixty civic associations covering the entire
Borough of Queens. We are commenting specifically on a potential site in Northeast Queens. Queens
Civic Congress was a signatory in opposition to a previous proposal regarding the use of public parkland
west of Citi Field Stadium for a shopping and entertainment center. The retention of public spaces,
especially parkland, in the Borough is a high priority of this organization and our member civic
associations. With the pressure to build more, bigger and higher residential and commercial buildings in
Queens, we and our members are committed to protecting parklands. In addition, due to existing traffic
congestion and other environmental issues, this organization is concerned about any project that would
greatly increase traffic and infrastructure use in our borough.
Queens Civic Congress is aware that the Commission published a “Gaming Market Study” in January
2021 which identified “northeast Queens” as a potential site of a new full casino, also described as a
“large-scale integrated resort”. The report also acknowledges that “the scale ultimately proposed for an
integrated resort casino may be much larger than we are considering” in the report.
Since past and present owners of the New York Mets have expressed interest in properties adjacent to Citi
Field for casino use, we are deeply concerned that a prospective developer/operator may propose one of
these properties for casino use. One such property, west of Citi Field, includes public parkland, as well as
the second property which is within the neighborhood of Willets Point that is located east of Citi Field.
The former New York Mets owners, the Wilpons and Saul Katz, proposed in 2011 to construct a full, Las
Vegas-style casino on the parkland property located just west of Citi Field stadium.
(See https://bit.ly/NYPost_Mar2013) It is crucial to note that on June 6, 2017, the New York State
Court of Appeals ruled that the 1961 legislation does not authorize construction of a retail
complex and movie theater on that public parkland, because it had not been explicitly authorized by the
state legislature (see https://bit.ly/citiland_Willetts_decision and Avella v. City of New York, NY Slip
04383 [Court of Appeals June 6, 2017]). Queens Civic Congress would strongly and actively oppose any
effort to subvert this ruling or any effort to amend state legislation to permit alienation of this valuable
parkland.
The current New York Mets owner, Steven Cohen, reportedly is now “in discussions with Las Vegas
Sands about bringing a casino to the Citi Field area.” (See https://bit.ly/Casino_Cohen_Sands) It is not
known at this point whether Mr. Cohen prefers as a casino site the parkland property located west of Citi
Field or vacant Willets Point property located east of Citi Field – but a full casino at either of those sites
flanking the Citi Field area would cause similar negative impacts to the surrounding communities.
In reference to RFI Question 3.2.4 regarding consideration of traffic impacts we note that vehicular entry
to and egress from the Citi Field area impinges on numerous highways and local roadways on which the
broad Queens community and businesses rely for efficient travel, including the Whitestone Expressway,
the Van Wyck Expressway, the Grand Central Parkway, Roosevelt Avenue, College Point Boulevard and
Northern Boulevard, among others.
Although New York Mets events and the U.S. Open tennis tournament already trigger significant traffic
impacts on nearby highways and roads, several large development projects and facilities are also already
approved to be built in the vicinity of Citi Field. For example:
• The 62-acre Willets Point development, consisting of up to 8.94 million gross square feet of new
construction. Traffic analyses performed for this development conclude that numerous
intersections surrounding Citi Field will operate at Level of Service “F” (i.e., “Fail”) with no
mitigation possible. Expert traffic engineer Bernard Adler testified: “I have never seen this level
of unmitigated impact, in the forty years I’ve been practicing.”
• The 29-acre Special Flushing Waterfront District, consisting of 2,993,768 gross square feet of
new development. Traffic analyses performed for this development acknowledge such poor
traffic flow on College Point Boulevard as to require 3,655 seconds (more than one hour) to exit
the development.
• The LaGuardia Airport AirTrain, if ultimately approved would include a dedicated new parking
garage to be accessed from Roosevelt Avenue, which is intended to draw in the vehicular traffic
of AirTrain passengers.
A full casino, and particularly a “large-scale integrated resort,” would be a unique attraction for the entire
City and downstate. Adding this facility to the mix at this Citi Field location will jeopardize the reliable
use of the surrounding highways and local roads, to the detriment of nearby residents, businesses and
anyone commuting through the area.
Any process to evaluate casino license proposals must require a thorough assessment of the cumulative
environmental impacts of a new casino, together with existing impacts, as well as impacts expected to
arise from other approved nearby projects – regardless of the expected completion dates of such projects.
The process must provide meaningful opportunities, with substantial advance notice, for the public and
independent experts to submit information to decision-makers and to influence the outcome.
We note that question 3.2.5 in your RFI specifically asks, when evaluating potential casino sites: “Should
local zoning requirements be considered?”
Our answer is “Yes, absolutely.”
In New York City, in the event that a proposed new land use does not comport with existing zoning, a
proposal must be made to re-zone the involved land pursuant to the Uniform Land Use Review Procedure
(ULURP; NYC Charter § 197-c). This provides for public hearings and decisions by the affected
Community Boards, Borough President, City Planning Commission and City Council.
In evaluating or approving casino license proposals, New York State officials must not circumvent
ULURP if it would be required, or override ULURP via any means.
As concerns properties that flank Citi Field stadium and that could be proposed as a potential new casino
site: The public parkland property located west of Citi Field stadium is un-zoned. We believe that it
would therefore need to become zoned through ULURP in a zoning district allowing such use in order for
a casino use to be permitted there. The Willets Point property located east of Citi Field stadium is
currently zoned C4-4, which does not permit a casino use. It would have to be rezoned through ULURP in
order for a casino use to be permitted there.
Please inform our organization of any steps the Commission takes, relating to casino licensing in
downstate New York.
Sincerely,
Kevin J. Forrestal, President

We Love Whitestone, Inc.
RFI Response
Although New York Mets events and the U.S. Open tennis tournament already trigger
significant traffic impacts on nearby highways and roads, several large development projects
and facilities are also already approved to be built in the vicinity of Citi Field. For example:
· The 62-acre Willets Point development, consisting of up to 8.94 million gross square feet
of new construction. Traffic analyses performed for this development conclude that numerous
mitigation possible. Expert traffic engineer Bernard Adler testified: “I have never seen this
level of unmitigated impact, in the forty years I’ve been practicing.”
· The 29-acre Special Flushing Waterfront District, consisting of 2,993,768 gross square
feet of new development. Traffic analyses performed for this development acknowledge such
poor traffic flow on College Point Boulevard as to require 3,655 seconds (more than one hour)
to exit the development.
· The LaGuardia Airport AirTrain, which includes a dedicated new parking garage to be
accessed from Roosevelt Avenue, which is intended to draw in the vehicular traffic of
AirTrain passengers.
Adding a full casino – a “large-scale integrated resort,” which could be a unique attraction in
the entire City – to the mix at this Citi Field location will jeopardize the reliable use of the
surrounding highways and local roads, to the detriment of nearby residents and anyone
commuting through the area.
Any process to evaluate casino license proposals must require a thorough assessment of the
cumulative environmental impacts of a new casino, together with existing impacts as well as
impacts expected to arise from other approved nearby projects, regardless of the expected
completion dates of such projects. Such process must provide meaningful opportunities, with
substantial advance notice, for the public and independent experts to submit information to
decision-makers and to influence the outcome.
We note that your RFI specifically asks, when evaluating potential casino sites: “Should local
zoning requirements be considered?”
Our answer is “Yes, absolutely.”
In New York City, in the event that a proposed new land use does not comport with existing
zoning, a proposal must be made to re-zone the involved land pursuant to the Uniform Land
Use Review Procedure (ULURP; NYC Charter § 197-c). This provides for public hearings and
decisions by the affected Community Boards, Borough President, City Planning Commission
and City Council.
In evaluating or approving casino license proposals, New York State officials must not
circumvent ULURP if it would be required, or override ULURP via any means.
As concerns properties that flank Citi Field stadium and that could be proposed as a potential
new casino site: The public parkland property located west of Citi Field stadium is un-zoned.
We believe that it would therefore need to become zoned through ULURP in order for a
casino use to be permitted there. The Willets Point property located east of Citi Field stadium
is currently zoned C4-4, which does not permit a casino use. It would have to be rezoned
through ULURP in order for a casino use to be permitted there.
Please inform our organization of any steps the Commission takes, relating to casino licensing
in downstate New York.
Sincerely,
Alfredo Centola
President
We Love WHITESTONE Civic
P.O. Box 29
Whitestone NY 11357
Alfredo Centola
President
Founding Member
Confidentiality Note: This message and any accompanying documents are covered by the
Electronic Communications Privacy Act, 18 U.S.C. §§ 2510-2521, and may contain
confidential, proprietary and/or attorney/client privileged information belonging to the sender.
This information is intended only for the use of the individual or entity named on this
message. If you are not the intended recipient, or the employee or agent responsible to the
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the taking of any action in reliance on the contents of this message is strictly prohibited.
A Better College Point Civic Association, Inc.
RFI Response
Appeals ruled that commercial development could not occur on that public parkland,
because it had not been explicitly authorized by the state legislature.
The current New York Mets owner, Steven Cohen, reportedly is now “in discussions
with Las Vegas Sands about bringing a casino to the Citi Field area.” (See
https://www.casino.org/news/mets-owner-steve-cohen-sands-talking-about-citi-field-
casino/). We do not know whether Mr. Cohen prefers this casino site on the parkland
property located west of Citi Field or the vacant Willets Point property located east of
Citi Field, but a full casino at either of these sites flanking the Citi Field area would
cause similar negative impacts to our community.
Vehicular entry to and egress from the Citi Field area impinges on numerous highways
and local roadways on which we rely for efficient travel, including the Whitestone
Expressway, the Van Wyck Expressway, the Grand Central Parkway, Roosevelt
Avenue, College Point Boulevard and Northern Boulevard, among others.
significant traffic impacts on nearby highways and roads, several large development
projects and facilities are also already approved to be built in the vicinity of Citi Field.
For example:
• The 62-acre Willets Point development, consisting of up to 8.94 million

gross square feet of new construction. Traffic analyses performed for this
development conclude that numerous intersections surrounding Citi Field will
operate at Level of Service “F” (i.e., “Fail”) with no mitigation possible. Expert
traffic engineer Bernard Adler testified: “I have never seen this level of
unmitigated impact, in the forty years I’ve been practicing.”
• The 29-acre Special Flushing Waterfront District, consisting of 2,993,768

gross square feet of new development. Traffic analyses performed for this
development acknowledge such poor traffic flow on College Point Boulevard as
to require 3,655 seconds (more than one hour) to exit the development.
• The LaGuardia Airport AirTrain, which includes a dedicated new parking

garage to be accessed from Roosevelt Avenue, which is intended to draw in the
vehicular traffic of AirTrain passengers.
Adding a full casino “large-scale integrated resort,” which would be a unique attraction
in the entire City to the mix at this Citi Field location will jeopardize the reliable use of
the surrounding highways and local roads, to the detriment of nearby residents and
anyone commuting through the area.
The process to evaluate all casino license proposals must require a thorough
assessment of the cumulative environmental impacts of a new casino, together with
existing impacts expected to arise from other approved nearby projects, regardless of
the expected completion dates of such projects. Such process must provide meaningful
opportunities, with substantial advance notice, for the public and independent experts to
submit information to decision-makers and to influence the outcome.
A Better College Point Civic Association 3

Northwest Bayside Civic Association, Inc.
RFI Response
(347) 674-6469 P.O. Box 604975 Bayside, N.Y. 11360 NBCAcivic@gmail.com
This letter is in response to your Request for Information (RFI) dated October 20, 2021,
pertaining to potential licensing of casino facilities in downstate New York.
Our organization, Northwest Bayside Civic Association, represents the interests of

homeowners situated throughout Northwest Bayside, a part of Northeast Queens.
We are aware that the Commission published a “Gaming Market Study” in January 2021 which
identified “northeast Queens” as a potential site of a new full casino, also described as a
“large-scale integrated resort”. The report also acknowledges that “the scale ultimately proposed
for an integrated resort casino may be much larger than we are considering” in the report.
We are concerned that a Northeast Queens location that could be proposed by a prospective
developer/operator as a potential new casino site, is in the vicinity of Citi Field stadium. This
includes public parkland that is located just west of Citi Field, and/or property within the
neighborhood of Willets Point that is located east of Citi Field. Past and present owners of the
New York Mets have expressed interest in those properties for casino use.
The former New York Mets owners, the Wilpons and Saul Katz, proposed in 2011 to construct a
full, Las Vegas-style casino on the parkland property located just west of Citi Field stadium.
(See
https://nypost.com/2013/02/05/mets-eye-casino-at-citi-to-help-offset-losses-suffered-in-bernie-m
adoff-scandal/) In 2017, the New York State Court of Appeals ruled that commercial
development could not occur on that public parkland, because it had not been explicitly
authorized by the state legislature.
The current New York Mets owner, Steven Cohen, reportedly is now “in discussions with Las
Vegas Sands about bringing a casino to the Citi Field area.” (See
https://www.casino.org/news/mets-owner-steve-cohen-sands-talking-about-citi-field-casino/) We
do not know whether Mr. Cohen prefers as a casino site the parkland property located west of
Citi Field, or vacant Willets Point property located east of Citi Field. However, a full casino at
either of those sites flanking the Citi Field area would cause similar negative impacts to our
community.
Vehicular entry to, and egress from, the Citi Field area impinges on numerous highways and
local roadways on which we rely for efficient travel, including the Whitestone Expressway, the
Van Wyck Expressway, the Grand Central Parkway, Roosevelt Avenue, College Point Boulevard
,and Northern Boulevard, among others.
significant traffic impacts on nearby highways and roads, several large development projects
and facilities are also already approved to be built in the vicinity of Citi Field. For example:
· The 62-acre Willets Point development, consisting of up to 8.94 million gross square feet of
new construction. Traffic analyses performed for this development conclude that numerous
mitigation possible. Expert traffic engineer Bernard Adler testified: “I have never seen this level
of unmitigated impact, in the forty years I’ve been practicing.”
· The 29-acre Special Flushing Waterfront District, consisting of 2,993,768 gross square feet of
new development. Traffic analyses performed for this development acknowledge such poor
traffic flow on College Point Boulevard as to require 3,655 seconds (more than one hour) to exit
the development.
· The LaGuardia Airport AirTrain, which includes a dedicated new parking garage to be
accessed from Roosevelt Avenue, which is intended to draw in the vehicular traffic of AirTrain
passengers.
Adding a full casino, a “large-scale integrated resort,” which could be a unique attraction to the
entire city, into the mix at this Citi Field location will jeopardize the reliable use of the
surrounding highways and local roads, to the detriment of nearby residents and anyone
commuting through the area.
Any process to evaluate casino license proposals must require a thorough assessment of the
cumulative environmental impacts of a new casino, together with existing impacts as well as
impacts expected to arise from other approved nearby projects, regardless of the expected
completion dates of such projects. This process must provide meaningful opportunities, with
substantial advance notice, for the public and independent experts to submit information to
decision-makers and to influence the outcome.
We note that your RFI specifically asks, when evaluating potential casino sites, “Should local
zoning requirements be considered? Our answer is “Yes, absolutely.”
In New York City, in the event that a proposed new land use does not comport with existing
zoning, a proposal must be made to re-zone the involved land pursuant to the Uniform Land
Use Review Procedure (ULURP; NYC Charter § 197-c). This provides for public hearings and
decisions by the affected Community Boards, Borough President, City Planning Commission
and City Council.
In evaluating or approving casino license proposals, New York State officials must not
circumvent ULURP if it would be required, or override ULURP via any means.
Regarding properties that flank Citi Field stadium and that could be proposed as a potential
new casino site: The public parkland property located west of Citi Field stadium is un-zoned. We
believe that it would therefore need to become zoned through ULURP in order for a casino use
to be permitted there. The Willets Point property located east of Citi Field stadium is currently
zoned C4-4, which does not permit a casino use. It would have to be rezoned through ULURP
in order for a casino use to be permitted there.
Please inform our organization of any steps the Commission takes relating to casino licensing
in downstate New York.
Sincerely,
Jena Lanzetta, President
Northwest Bayside Civic Association

Bono Sawdust Supply Co., Inc.
RFI Response
JSA^O 1^'
PRODUCTS OF SAWDUST ●TO SPECDTCATIONS
33-30-127 Hace Conma, N.Y. U368
Bumble Bee Brand/Div. of
Maiuifactorers of Sweeping Compounds (718)446-1374
December 9, 2021

One Broadway Center
Via email to Kristen.Buckley@gaming.ny.gov, Stacey.Relation@gaming.ny.gov,

Aly san. Bower s@gaming .ny .gov
Re: Response to New York Gaming Commission’s Request for Information

dated October 20, 2021 for Unawarded Commercial Casino Licenses
Submitters’ Names: Jack Bono and Jake Bono

Contact Name and Title: Jack Bono, President
Contact Telephone Number: 718-446-1374
Contact Electronic Mail Address: bonosawdust@aol.com
Mailing Address: 33-30 127th Place, Corona, New York 11368
Dear New York State Gaming Commission:
It has come to our attention that the Gaming Commission recently published aGaming
Market Study that identifies “northeast Queens” as apotential site of anew casino (a “large-scale
integrated resort”). We understand that the Commission is now soliciting information from parties
who could potentially be affected by the award of adownstate casino license and associated
development.
We are second and third generation property and business owners, proudly operating Bono
Sawdust Supply Co. which was established in 1933. Our building and facility were constructed by
the previous generation, on valuable land that we continue to own today in Willets Point, Queens.
We anticipate that developers will seek alicense to construct and operate anew casino in
the Willets Point /Citi Field area. We object to the use of this area for casino purposes, and will
strongly oppose any attempt to do so.
We believe that acasino project in this area will trigger all-out mischief by the state,
including eminent domain abuse and other egregious tactics to forcibly remove businesses and
property owners to obtain our land. We have no plan to leave the property and building where our
business has successfully operated for 88 years.
We also object to acasino being built in this area, even if we remain here. We rely on
surrounding highways and local roads to efficiently deliver our products, and for customers to
reach us. Acasino in this area will generate an unimaginable amount of traffic congestion,
hindering highway and local road access far more than the City’s plan to develop housing in this
area (which is already expected to be atremendous impact).
Lastly, aglitzy gambling venue in the Willets Point /Citi Field area will be astrong
negative temptation for the community of Corona that is located immediately to the west. Not all
Corona residents may succumb to the casino temptation, but Corona’s overall quality of life is
certain to decline, as the casino attracts the usual bad elements: Prostitution, assaults, robberies,
home burglaries, homelessness and degenerates.
For the above reasons, the Commission should exclude the Willets Point /Citi Field area
from consideration as apotential new casino site.
Sincerely,
r
;e Bono
Page 2of 2
Robert LoScalzo
RFI Response
169-06 22nd Avenue
Whitestone, New York 11357
December 8, 2021

One Broadway Center
Ms. Kristen Buckley

Secretary to the Commission
Via email to: Kristen.Buckley@gaming.ny.gov
Ms. Stacey Relation

Contract Management Specialist 3
Via email to: Stacey.Relation@gaming.ny.gov
Ms. Alysan Bowers

Contract Management Specialist 2
Via email to: Alysan.Bowers@gaming.ny.gov
Re: Response to New York State Gaming Commission’s Request for Information
dated October 20, 2021 for Unawarded Commercial Casino Licenses
Dear New York State Gaming Commission:
This letter and its attachments are my response to the above-referenced Request
for Information (“RFI”) issued by the New York State Gaming Commission
(“Commission”). I am a resident of Whitestone, Queens, and an “affected party” as
defined by the Commission (i.e., “an individual … who could potentially be affected by the
development of unawarded commercial casino license”; RFI at 7).
• Submitter’s Name: Robert LoScalzo

• Contact Name and Title: Robert LoScalzo
• Contact Telephone Number: 929-391-8693
• Contact Electronic Mail Address: RLosca@aol.com
• Mailing Address: 169-06 22nd Avenue, Whitestone, NY 11357
The Gaming Market Study dated January 2021, prepared for the Commission,
identifies “northeast Queens” as a potential new casino site. However, at least one area
within northeast Queens is inappropriate for new casino development, and should be
excluded from consideration: property flanking Citi Field stadium, including property
located west of Citi Field which is public parkland, and property located east of Citi Field
stadium which is known as Willets Point. (See Attachment A, aerial view.)
Citi Field is the home venue of the New York Mets baseball team. Past and present
owners of the Mets have previously proposed or reportedly expressed interest in
constructing a casino on property adjacent to Citi Field:
• The former Mets owners, the Wilpons and Saul Katz, proposed together
with other developers in 2011 to construct a casino on parkland property
located just west of Citi Field stadium. (See Attachment B, proposal
illustration; see also https://nypost.com/2013/02/05/mets-eye-casino-at-citi-
to-help-offset-losses-suffered-in-bernie-madoff-scandal/) Because at that
time a casino could only have been operated by an Indian Nation, the
proposal included a letter from the Shinnecock Indian Nation pledging its
involvement. (See Attachment C, proposal letter.) In 2017, the New York
State Court of Appeals ruled that commercial development could not occur
on that public parkland, because it had not been explicitly authorized by the
state legislature. (See Matter of Avella v City of New York, 29 NY3d 425
[2017].)
• The current Mets owner, Steven Cohen, reportedly is now “in discussions
with Las Vegas Sands about bringing a casino to the Citi Field area.” (See
https://www.casino.org/news/mets-owner-steve-cohen-sands-talking-
about-citi-field-casino/)
I anticipate that respondents to the RFI or to a future Request for Applications

(“RFA”) may propose the Citi Field area as a new casino site. However, at this early stage,
I am forewarning the Commission that the Citi Field area is not a suitable location for a
new casino, for at least the reasons discussed below. I am also aware that the Queens
Civic Congress, which represents the interests of more than 60 civic organizations
throughout Queens, is similarly writing to the Commission regarding the unsuitability of
the Citi Field area as a new casino location.
–1–
Factors that pertain to both the parkland property located west of Citi Field
and the Willets Point property located east of Citi Field
(a) Traffic congestion; obstruction of essential highways and local roads
The Citi Field area, including the Flushing Meadows Corona Park property located
to its west, and the Willets Point land located to its east, is situated at the confluence of
several major Queens highways and local roadways (see Attachment A, aerial view).
Vehicular traffic into and out of the Citi Field area impinges on the Whitestone
Expressway, the Van Wyck Expressway, and the Grand Central Parkway, in addition to
numerous local roadways including Roosevelt Avenue, College Point Boulevard,
Northern Boulevard, and Astoria Boulevard, among others. Commuters who reside in
nearby neighborhoods, or whose travel routes necessarily pass Citi Field, rely on these
highways and local roads for timely travel to and from work.
Page 2 of 16
Traffic congestion surrounding and within the Citi Field area is already severe
when games or other events occur at Citi Field, and/or during the U.S. Open tennis
tournament which occurs at the nearby National Tennis Center during three weeks each
year.
However, even without a new casino, future traffic congestion in the Citi Field area
will pose a much greater threat to the operability of surrounding highways and local roads,
due to several development projects, summarized below, that have already been
approved for the area.
It is nonsensical to establish a casino “attraction” at a place that will be incapable

of accommodating the influx of vehicles that a casino would attract. Doing so would result
in cumulative traffic impacts far exceeding any previously analyzed – a death knell for
timely travel on key Queens highways and local roads, upon which commuters rely.
Willets Point development
Among the development projects already approved and currently proceeding in

the Citi Field area is the Willets Point development, an ongoing project of the New York
City Economic Development Corporation (“NYCEDC”) and the City encompassing 61.4
acres located east of Citi Field. In 2008, the City rezoned the entire 61.4-acre Willets Point
site and designated it an urban renewal area, to facilitate City plans for its comprehensive
environmental remediation and redevelopment.
The entire Willets Point redevelopment “Proposed Plan”, approved in 20081,

provides for the thorough transformation of Willets Point into the “next great
neighborhood”, including 5,500 housing units (5,500,000 gross square feet (“gsf”)); retail
space of 1,700,000 gsf; office space of 500,000 gsf; a convention center of 400,000 gsf;
a hotel with 700 rooms (560,000 gsf); community facility space of 150,000 gsf; a school
of 130,000 gsf; approximately 6,700 parking spaces; and publicly accessible open space
of 8 acres minimum – for a total maximum development of 8,940,000 gsf.
The City is proceeding with the plan in phases, and still intends to redevelop all
61.4 acres of Willets Point.
The Willets Point Development Plan Final Generic Environmental Impact

Statement (“FGEIS”) includes a “Traffic and Parking” chapter (Attachment D) which
analyzes traffic impacts of the Willets Point development, and a “Mitigation” chapter
(Attachment E) which describes the development’s traffic impacts with mitigation
measures in place.
1
See Willets Point Development Plan Final Generic Environmental Impact Statement issued September
12, 2008, Chapter 1, Project Description; accessible online at:
https://edc.nyc/sites/default/files/filemanager/Projects/Willets_Point_Redevelopment/WP_0908_01_Proje
ct_Description.pdf; last accessed December 4, 2021.
Page 3 of 16
The FGEIS Mitigation chapter repeatedly admits to numerous instances of
“Unmitigable Impacts” that will occur throughout the Citi Field area. (See Attachment E,
Table 23-7.)
For example, it reports the following future unmitigable traffic impacts in the with-
action scenario at the intersection of 126th Street and Roosevelt Avenue2:
• Level of Service “F” during weekdays AM (non-game days)3.

• Level of Service “F” during weekdays mid-day (non-game days)4.
• Level of Service “F” during weekdays PM (non-game days)5.
• Level of Service “F” during Saturdays mid-day (non-game days)6.
Traffic Level of Service “F” (i.e., “Fail”) indicates a “constant traffic jam”7.
The FGEIS Mitigation chapter plainly states, as concerns Roosevelt Avenue at

126th Street:
“None of the significant impacts expected during all seven analysis peak
hours could be mitigated. Similar to Roosevelt Avenue at 114th Street,
mitigation options at this intersection, which would experience substantial
traffic and pedestrian volumes at the southern end of the [Willets Point]
District, are also limited by geometric constraints. Further, significant
impacts on all approaches to this intersection would make signal timing
modifications ineffective.”8
In oral testimony to the City Planning Commission on August 13, 2008 during its
evaluation of the proposed Willets Point development (Attachment F), Bernard Adler,
former Commissioner of Traffic for the City of White Plains, summarized:
“I have never seen this level of unmitigated impact in over 40 years of

practice as a traffic engineer. … [R]esidents will not be able to drive to and
from work, businesses will not be able to receive shipments or customers,
travelers will not be able to reach airports or simply drive through, and
2
This intersection is also the planned location of the LaGuardia Airport AirTrain dedicated parking
garage, approved by the Federal Aviation Administration in 2021. The garage is intended to draw in more
vehicles of AirTrain passengers, right at the location where the predicted traffic Level of Service is already
“F”.
3
Attachment E, Table 23-9.
4
Id., Table 23-10.
5
Id., Table 23-11.
6
Id., Table 23-12.
7
See, “A Roadmap to Understanding Traffic in Your Community” at 5 (derived from “A Policy on
Geometric Design of Highways and Streets” published by the American Association of State Highway
Transportation Officials); accessible online at:
https://www.nashuarpc.org/files/2213/9300/1354/transportation_guide.pdf; last accessed December 4,
2021.
8
Attachment E at 23-7.
Page 4 of 16
emergency vehicles will not be able to respond in a timely manner. … [T]his
degradation of the road and highway system would create an
unprecedented daily transportation overload.”
Mr. Adler’s associate, traffic engineer Michael O’Rourke, testified (Attachment F):
“Significant impacts will also occur on the highway network, resulting in

much slower speeds and bumper-to-bumper congestion. … On the Van
Wyck Expressway, when people are going to work in the morning,
northbound traffic speeds would be cut in half from 40 mph to 21 mph. …
When people are coming home from work, speeds would be cut from 39
mph to 18 mph. … Extremely slow speeds and heavy congestion are also
expected for the southbound Van Wyck Expressway, the southbound
Whitestone Expressway and both directions of the Grand Central Parkway.
… Traffic on the ramps will become intolerable as well. Speeds of less than
two mph are predicted for the ramp from the westbound Northern Boulevard
to the southbound Van Wyck Expressway for most of the day. By
comparison, without the project the predicted speeds are approximately 29
mph. … Single-digit ramp speeds are also predicted for the other highway
ramps in the vicinity. The congestion caused by these extremely slow
speeds will spill back onto the highway network and the local streets … The
adverse impacts that I just described will occur despite the ramp
improvements that the City has proposed.”
See also the detailed written material dated August 22, 2008 presented by Adler
Consulting to the City Planning Commission and NYCEDC (Attachment G).
Although the above-described traffic impacts of the Willets Point development are
severe, even worse impacts will occur if a casino is added near the Willets Point
development, or substituted for a portion of it.
Any traffic or environmental analysis that is performed for a potential future casino
in the Citi Field area must use as its baseline the future traffic and environmental
conditions attributable to the 61.4 acre Willets Point development, as documented in the
Willets Point FGEIS.
Moreover, any analysis that is performed for a potential future casino in the Citi
Field area must explain how vehicles will be able to reliably access the casino site, given
the poor traffic conditions documented in the Willets Point FGEIS.
Notably, in 2013 the City approved a follow-up proposal to expand the Willets Point
development to encompass not only the 61.4 acres of Willets Point property located east
of Citi Field, but also the parkland property located west of Citi Field, which would become
the site of a 1,400,000 gsf commercial shopping mall. The total size of the expanded
development would be 108.9 acres. (See Exhibit A, aerial view; see also Exhibit H,
illustrative site plan.)
Page 5 of 16
Although in 2017 the New York State Court of Appeals enjoined construction on
the parkland (see Matter of Avella v City of New York, 29 NY3d 425 [2017]), a Willets
Point Development Final Supplemental Environmental Impact Statement (“FSEIS”) was
approved for the entire 108.9 acre project that includes the shopping mall.
The Willets Point FSEIS includes a “Transportation” chapter (Attachment I) which

analyzes traffic impacts of the Willets Point development, and a “Mitigation” chapter
(Attachment J) which describes the development’s traffic impacts with mitigation
measures in place.
In written testimony dated July 10, 2013 to the City Planning Commission
(Attachment K) during its review of the proposed expanded Willets Point development
and its Supplemental Draft Environmental Impact Statement (“SDEIS”), traffic engineer
Brian Ketcham stated:
“Project impacts reported in the SDEIS are extremely severe and it is

unlikely many can be mitigated. Mitigation for expressways is not described
in the SDEIS; major changes to expressways take years and require their
own individual engineering and environmental assessments delaying
project implementation. Proposed mitigation still leaves intersections and
expressways gridlocked; this is especially true for Astoria Blvd., Northern
Blvd. and Roosevelt Avenue. The SDEIS low-balls the number of trips this
project will generate; a great deal more traffic will in fact be produced than
reported, further gridlocking the area.”
As the Willets Point FSEIS is an approved environmental review document,

irrespective of the failure to actually construct the shopping mall on parkland, any traffic
or environmental analysis that is performed for a potential future casino in the Citi Field
area should be reconcilable with portions of the data in the Willets Point FSEIS. A casino
constructed in lieu of the formerly proposed shopping mall would likely generate more
intense traffic and other impacts that those reported in the Willets Point FSEIS.
Special Flushing Waterfront District
Another approved large project that impacts the traffic flow in the vicinity of Citi
Field is the Special Flushing Waterfront District, pertaining to approximately 29 acres of
waterfront property located directly across the Flushing Creek from Willets Point. The
Special Flushing Waterfront District is bordered by College Point Boulevard and
Roosevelt Avenue, which is a major east/west thoroughfare between Flushing, the Citi
Field / Willets Point area, and Corona further to the west.
The Special Flushing Waterfront District project consists of 2,993,768 gsf of new
mixed-use development where none exists today – including 383,641 gsf of commercial
office space, 298,811 gsf of commercial retail space, 714,588 gsf of hotel space (970
Page 6 of 16
hotel units), 21,913 gsf of community facility space, and 1,574,815 of dwelling space
(1,725 units). Developers expect to construct the project by 2025.
An Environmental Assessment Statement dated December 13, 2019 (“EAS”) was

prepared for the Special Flushing Waterfront District. It contains a section that analyzes
traffic conditions with and without the Special Flushing Waterfront District constructed
(Attachment L). The traffic analysis documents numerous instances of traffic choke points
with Level of Service “F,” impinging on Roosevelt Avenue. It stands to reason that such
conditions must impact efficient west-bound travel on Roosevelt Avenue, toward the Citi
Field area. For example:
• The southbound approach of College Point Boulevard at Roosevelt Avenue,

which would:
o Continue to operate at LOS F with an average delay of 216.6 seconds

during the weekday AM peak hour, a decrease of 74.4 seconds relative
to the Future No-Action Condition.

during the weekday midday peak hour, a decrease of 58.9 seconds
relative to the Future No-Action Condition.

during the weekday PM peak hour, a decrease of 53.3 seconds relative
to the Future No-Action Condition.

during the Saturday midday peak hour, a decrease of 55.3 seconds
relative to the Future No-Action Condition.
(Attachment L at 314.)
• The southbound approach of Janet Place at Roosevelt Avenue, which

would:
o Continue to operate at LOS F with an average delay of 2,689 seconds

[i.e., more than 44 minutes] during the weekday AM peak hour, a
decrease of 4,239 seconds relative to the Future No-Action Condition.
o Continue to operate at LOS F with undefined delay during the weekday

midday peak hour, a result similar to the undefined delay in the Future
No-Action Condition.
o Continue to operate at LOS F with undefined delay during the weekday

PM peak hour, a result similar to the undefined delay in the Future No-
Action Condition.
Page 7 of 16
o Continue to operate at LOS F with undefined delay during the Saturday
midday peak hour, a result similar to the undefined delay in the Future
No-Action Condition.
(Attachment L at 314.)
As the Special Flushing Waterfront District EAS is an approved environmental

review document, any traffic or environmental analysis that is performed for a potential
future casino in the Citi Field area should be reconcilable with portions of the data in the
Special Flushing Waterfront District EAS.
the poor traffic conditions documented in the Special Flushing Waterfront District EAS.
LaGuardia Airport AirTrain
Yet another approved project that impacts the traffic flow in the vicinity of Citi Field
is the LaGuardia Airport Airtrain10. It includes a dedicated parking garage that is intended
to draw in vehicles from AirTrain passengers, despite being located at the intersection of
Roosevelt Avenue and 126th Street – a location which the Willets Point FGEIS reports
will operate at:
• Level of Service “F” during weekdays AM (non-game days)11.

• Level of Service “F” during weekdays mid-day (non-game days)12.
• Level of Service “F” during weekdays PM (non-game days)13.
• Level of Service “F” during Saturdays mid-day (non-game days)14.
9
2021.
10
The Federal Aviation Administration (“FAA”) approved the LaGuardia Airport AirTrain project on July
20, 2021 when it issued its Record of Decision. At the behest of the New York State Governor, the project
has been placed on hold, which may be temporary. The AirTrain has not been canceled, the FAA
approval remains in effect, and the AirTrain may yet be constructed.
11
Attachment E, Table 23-9.
12
Id., Table 23-10.
13
Id., Table 23-11.
14
Id., Table 23-12.
15
Page 8 of 16
An Environmental Impact Statement dated March 2021 (“EIS”) was prepared for
the LaGuardia Airport AirTrain. It contains a section that analyzes traffic conditions with
and without the AirTrain project (Attachment M). It confirms that with the AirTrain and
dedicated parking garage constructed, there will be numerous instances of poor traffic
Levels of Service on local roads adjacent to Citi Field:
• Roosevelt Avenue and 126th Street – significant impacts in the Midday,

P.M., and Saturday peak hours
• Roosevelt Avenue and Southfield Employee Lot – significant impacts in the

A.M., Midday, and P.M. peak hours
• Roosevelt Avenue and 114th Street – significant impacts in the A.M.,

Midday, P.M. and Saturday peak hours
(Attachment M at 3-271.)
At Roosevelt Avenue and 126th Street (year 2026):

• Level of Service “F” during weekdays mid-day (non-game days).
At Roosevelt Avenue and Southfield Parking Lot (year 2026):

• Level of Service “F” during weekdays AM (non-game days).
• Level of Service “F” during weekdays mid-day (non-game days).
• Level of Service “F” during weekdays PM (non-game days).
At Roosevelt Avenue and 114th Street (year 2026):

• Level of Service “E” during weekdays AM (non-game days).
• Level of Service “E” during weekdays mid-day (non-game days).
• Level of Service “F” during weekdays PM (non-game days).
(Attachment M, Table 3.14-15.)
Analysis year 2031 shows even worse conditions than those summarized above.
(See Attachment M, Table 3.14-16.)
As the LaGuardia Airport AirTrain EIS is an approved environmental review

document, any traffic or environmental analysis that is performed for a potential future
casino in the Citi Field area should be reconcilable with portions of the data in the
LaGuardia Airport AirTrain EIS.

2021.
Page 9 of 16
the poor traffic conditions documented in the LaGuardia Airport AirTrain EIS.
In summary, the expected future traffic congestion in the vicinity of Citi Field, as
documented by several approved environmental reports, make the Citi Field area an
inappropriate site for a potential casino. Moreover, adding a casino to the Citi Field area
will generate additional traffic impacts beyond those attributable to already-approved
projects – and such additional impacts will further degrade, and likely ruin, the operability
of nearby highways and local roads on which Queens residents and commuters must
rely.
For any proposed new casino site, the Commission must require a cumulative
impact analysis of the vehicular traffic to be generated by the casino, together with the
traffic to be generated by the already-approved projects intended for the same area. In
the vicinity of Citi Field, these include the Willets Point development, Special Flushing
Waterfront District and LaGuardia Airport AirTrain. Such analysis should provide at least
the same level of detail as the Willets Point FGEIS, and should comply with the State
Environmental Quality Review Act. No already-approved project should have its impacts
excluded from the cumulative analysis, merely because its expected completion date may
be a decade or more in the future.
(b) Zoning
The RFI specifically asks, when evaluating potential casino sites: “Should local
zoning requirements be considered?” My answer is “Yes.” A casino must only be
constructed on land whose zoning allows it. In the event that zoning must be implemented
or changed to allow a casino, the procedure to do so that is set forth in the New York City
Charter must be followed, and not circumvented or overridden.
Neither the public parkland property that is located west of Citi Field, nor the Willets
Point property that is located east of Citi Field, is presently zoned to allow a casino use.
In New York City, in the event that a proposed new land use does not comport with
existing zoning, a proposal must be made to re-zone the involved land pursuant to the
Uniform Land Use Review Procedure (“ULURP”; New York Charter § 197-c). This
provides for public hearings, recommendations and decisions by the affected Community
Boards, Borough President, City Planning Commission and City Council.
The public parkland property that is located west of Citi Field is un-zoned. It would
therefore need to become zoned through ULURP in order for a casino use to be permitted
there. (To be clear: I do not support alienating that parkland, implementing zoning on it,
or constructing a casino on it.)
The Willets Point property located east of Citi Field is currently zoned C4-4, which
does not permit a casino use. That property would have to be rezoned through ULURP
Page 10 of 16
in order for a casino use to be permitted there. (To be clear: I do not support rezoning
that property or constructing a casino on it.)
In evaluating or approving casino license proposals, New York State officials

must not circumvent ULURP if it would be required, or override ULURP via any means.
–2–
Factors specific to the parkland property located west of Citi Field
(a) Parkland status
The parkland property located west of Citi Field is part of Flushing Meadows
Corona Park. Parkland is held in public trust, and cannot be diverted to non-park use
without state legislative approval of a specific non-park use. (See Friends of Van Cortlandt
Park v City of New York, 2001 N.Y. Int 3 (Feb. 8, 2001).)
In 2012, when the City announced plans to expand the Willets Point development
to encompass the public parkland located west of Citi Field and construct a commercial
shopping mall there, the surrounding communities made clear that they opposed diverting
that public parkland to non-park use. A coalition of community civic organizations, good
government groups, affected residents, business owners and property owners joined with
a state senator to bring a legal challenge opposing the use of that parkland property as
the site of a commercial shopping mall. (See Matter of Avella v City of New York, 29 NY3d
425 [2017].)
Petitioners prevailed in that lawsuit. In 2017, the New York State Court of Appeals
ruled that commercial development could not occur on the public parkland located west
of Citi Field, because it had not been explicitly authorized by the state legislature.
In the event that respondents to the RFI or to a future RFA propose the parkland
property located west of Citi Field as a new casino site, I anticipate strong public
opposition by a coalition of knowledgeable parties interested in maintaining the existing
parkland.
–3–
Factors specific to the Willets Point property located east of Citi Field
(a) Casino inconsistent with a long-standing development plan in which the City has
already invested hundreds of millions of taxpayer dollars
Since at least 2007, the City has pursued its Willets Point development plan – not
for the purpose of hosting a casino, but to construct New York City’s “next great
neighborhood” comprising the 5,500 housing units and amenities described in the Willets
Page 11 of 16
Point FGEIS16. In 2008, the City instituted new zoning on Willets Point land that supports
the intended neighborhood land uses, and does not allow casino use.
In the years since, the City has spent hundreds of millions of taxpayer dollars to
acquire approximately one-third of the 61.4 acres comprising Willets Point, concentrating
on land directly across 126th Street from Citi Field stadium. As with the 2008 rezoning,
this substantial investment of public monies was made to progress the approved Willets
Point development plan, comprising the 5,500 housing units and amenities described in
the Willets Point FGEIS – not in furtherance of a casino use.
Using a large portion of Willets Point land for a casino – a “large-scale integrated
resort,” as stated in the Gaming Market Study dated January 2021 – would be inconsistent
with the City’s long-standing development plan, and would interfere with it by diverting
land from it, among other impacts.
(b) Private property acquisition, dislocation of existing businesses, and construction

delays
At present, Willets Point land is generally divided into two sections: (1)
approximately 23 acres of vacant land, owned by the City, directly across 126th Street
from Citi Field stadium; and (2) approximately 39 acres of land occupied by businesses,
privately owned, further east from Citi Field stadium.
If a prospective Willets Point casino developer cannot reach a deal with the City to
construct the casino entirely on vacant, City-owned Willets Point land, conceivably the
developer could attempt to purchase occupied Willets Point land from its private owners.
However, there is no guarantee that a prospective casino developer would

succeed in acquiring enough contiguous property to situate a casino. Willets Point
property owners who operate their own industrial businesses are extremely reluctant to
relinquish their properties, due to a lack of suitable industrial replacement sites, highway
access elsewhere that is inferior to that available at Willets Point, the risks of relocating a
business away from the area where it has been successful for decades, and other factors.
Even if a developer could acquire enough contiguous, occupied, privately-owned

Willets Point property to construct a casino, there would be a long delay until the existing
businesses are able to vacate; until all of the existing structures can be made safe for
demolition; and until demolition razes the existing structures. Even then, the land is still
not usable for casino construction, as all Willets Point land is required to undergo years-
long environmental remediation (further discussed below). Thus, there are construction
delays associated with using Willets Point land, that may not exist at other locations.
16
12, 2008, Chapter 1, Project Description; accessible online at:
Page 12 of 16
In the event that a respondent to the RFI or to a future RFA proposes any Willets
Point property as a new casino site, the Commission should ascertain whether the
respondent presently possesses the right to use the proposed site, or whether there
would be a delay while the respondent attempts to acquire the right to use the proposed
site. The Commission should also ascertain the duration of any construction delays that
will occur if a proposed casino site presently contains existing businesses that need to
relocate, structures that must be demolished, and ground that must undergo lengthy
environmental remediation. The duration of any such delays should be considered by the
Commission to be a negative factor, reducing the site’s score when compared with other
sites unaffected by delays.
(c) Mandatory, years-long environmental remediation prior to construction
The Commission should beware that all Willets Point property is allegedly
contaminated, and must undergo substantial, expensive and time-consuming
environmental remediation before any construction may occur. All Willets Point lots were
given hazardous materials E-designations in 2008, and no development may proceed
there unless remediation is first accomplished to the satisfaction of the New York City
Office of Environmental Remediation.
Moreover, the 23 acres of vacant, City-owned Willets Point land located directly
across 126th Street from Citi Field are enrolled in the New York State Brownfield Cleanup
Program (“BCP”), which is administered by the New York State Department of
Environmental Conservation (“NYSDEC”). The years-long mandatory steps to remediate
property in the BCP prior to construction include:
• Drafting by the remediating party of a site-specific Remedial Investigation

Work Plan.
• Evaluation and approval by NYSDEC of the Remedial Investigation Work
Plan.
• On-site implementation by the remediating party of the Remedial
Investigation Work Plan.
• Drafting by the remediating party of a Remedial Investigation Report.
• Drafting by the remediating party of a site-specific Remedial Action Work
Plan.
• Evaluation and approval by NYSDEC of the Remedial Action Work Plan.
• Drafting by the remediating party of a Site Management Plan.
• Evaluation and approval by NYSDEC of the Site Management Plan.
• On-site implementation by the remediating party of the Remedial Action
Work Plan.
• Drafting by the remediating party of a Final Engineering Report.
• Approval by NYSDEC of the Final Engineering Report.
• Issuance by NYSDEC of a BCP Certificate of Completion.
As an example of how long it can take to remediate Willets Point property through
the BCP, consider what has happened with seven acres of property at the southern end
Page 13 of 16
of Willets Point where the City has approved construction of 1,100 affordable housing
units and an elementary school17.
The involved property has been enrolled in the BCP since 2013. The City
announced the seven acre affordable housing and school development on February 6,
2018. According to the developer’s Remedial Action Work Plan18, the Remedial
Investigation phase began on October 22, 2018. The Remedial Action Work Plan
approved by NYSDEC was issued on May 11, 2021. According to that plan, on-site
remedial activities are expected to continue through June 2022. Thereafter, the Final
Engineering Report will be drafted and submitted to NYSDEC. The schedule anticipates
that NYSDEC will issue a Certificate of Completion during February 2023.
Thus, even omitting the drafting, evaluation and approval of the Remedial
Investigation Work Plan which must have occured prior to October 2018, the timeframe
from the beginning of the Remedial Investigation until the anticipated issuance of the
Certificate of Completion is more than four years and four months, not including
unexpected delays. Again, this is before any construction is allowed to commence on the
site.
There is nothing to suggest that other Willets Point property will not require a
similar four year timeframe for remediation, prior to any construction.
Point property as a new casino site, the duration of the delay of construction due to
mandatory, years-long remediation activities should be considered by the Commission to
be a negative factor, reducing the site’s score when compared with other sites unaffected
by a remediation delay.
(d) Eminent domain inappropriate
Acquiring privately-owned Willets Point property via eminent domain to facilitate a

non-essential entertainment and gambling-centric project is thoroughly inappropriate. If
the state attempts to use eminent domain for that purpose, it will be excoriated and
ridiculed in national media, and vociferously opposed by property owners, business
owners and surrounding communities.
(e) New Van Wyck Expressway ramps required under certain circumstances
To enable development within Willets Point, the Willets Point FGEIS specifies that
new ramps to and from the Van Wyck Expressway will be provided, “to facilitate the
17
See https://www1.nyc.gov/office-of-the-mayor/news/082-18/mayor-de-blasio-borough-president-katz-
council-member-moya-city-will-go-all
18
Accessible online at:
https://www.dec.ny.gov/data/DecDocs/C241146/Work%20Plan.BCP.C241146.2021-05-
11.Remedial%20Action%20Work%20Plan%20Final.pdf; last accessed December 6, 2021.
Page 14 of 16
movement of traffic into and out of the District and minimize traffic on nearby local
roadways.”19
NYCEDC has asserted that there is a threshold amount of Willets Point

development that cannot occur unless the new Van Wyck Expressway ramps are actually
constructed. Given the size of casino that RFI respondents likely envision – a “large-scale
integrated resort,” as stated in the Gaming Market Study dated January 2021 – situating
such a casino within Willets Point will require constructing the new Van Wyck Expressway
ramps.
The Van Wyck Expressway is a federal highway (I-678), under the jurisdiction of
the Federal Highway Administration (“FHWA”). Any modification of the Van Wyck
Expressway must be evaluated and approved by FHWA in its discretion. FHWA cannot
approve an unsafe highway modification, or one that would ruin the operability of the
highway.
NYCEDC, the New York State Department of Transportation (“NYSDOT”), FHWA

and various consultants produced an unapproved draft Access Modification Report
(“AMR”) dated August 2009. The report relies on traffic analyses of the effects of new
access ramps, in the context of the Willets Point development in the form in which it was
approved in 2008.
A contentious internal review and reworking of the draft AMR ensued for the next
two-plus years. In 2010, the New York Times reported that a NYSDOT structural engineer
“wrote to the department’s regional director and other colleagues on Dec. 28: ‘Unless the
preparers of this report start accepting the idea that it is seriously flawed, we are going
nowhere’”, and that internal emails “among State Transportation Department staff
members, federal highway officials, city officials and private consultants show the state’s
concern about the safety, design and traffic impacts of the ramps.” (See Attachment N,
“E-Mails Show State Officials’ Skepticism About Willets Point Project,” Fernanda Santos,
New York Times, August 13, 2010, p. A17.)
FHWA approved a final AMR dated March 2012, which specifies the new ramps’
design. (See Attachment O, AMR Figure 1.4). However, it is important to realize that the
approved AMR analyzed the traffic impacts of new access ramps, and specified the
ramps’ design, specifically in the context of the Willets Point development in the form in
which it was approved in 2008 – not in the context of a casino being built at the site.
Designating Willets Point as a new casino site will not only trigger the need for new
access ramps to and from the Van Wyck Expressway, but will also require the preparation
of a new AMR that analyzes effects of new access ramps in the context of a casino and
19
12, 2008, Chapter 1, Project Description at 1-11; accessible online at:
Page 15 of 16
the traffic that it will attract. The design of the ramps may also need to be revised and
tailored to best handle casino traffic. There is no assurance that FHWA will approve new
Van Wyck Expressway access ramps in the context of casino traffic.
Developing the prior federally-approved AMR took the involved agencies roughly
three years of contentious work. There is nothing to suggest that a new AMR specific to
casino traffic will not require a similar three year timeframe to produce.
Point property as a new casino site, the Commission should assess whether the site is
worth promulgating a contentious application to FHWA to approve new Van Wyck
Expressway access ramps.
The necessity to obtain approval for and construct new access ramps should be
considered by the Commission to be a negative factor, reducing the Willets Point site’s
score when compared with other sites whose use does not depend on modifying a federal
highway.
* * *
In closing, the area surrounding Citi Field stadium in the borough of Queens –
including the parkland property located to the west of Citi Field, and the Willets Point
property located to the east of Citi Field – is bedeviled by numerous complications that
collectively make it an inappropriate site for a casino.
The RFI asks: “Should certain zones or regions be excluded from consideration?”
(RFI at 8.) The Citi Field area – including the parkland property located to the west of Citi
Field, and the Willets Point property located to the east of Citi Field – should be excluded
from consideration.
Any process to evaluate future casino license proposals must provide meaningful
opportunities, with substantial advance notice, for the public and independent experts to
submit information to decision-makers and to influence the outcome.
Respectfully submitted,
Robert LoScalzo
15 enclosures (Attachments A - O)
This RFI response consists of three PDFs: Part 1, Part 2 and Part 3.
Attachments A through G are within Part 1 (the present PDF).

Attachments H through J are within Part 2.
Attachments K through O are within Part 3.
Page 16 of 16
Attachment A
Google Earth aerial view with text superimposed

identifying Citi Field stadium, Flushing Meadows Corona Park land
located to its west, Willets Point land located to its east, and
various key highways and local roads.
Attachment B
Excerpt from casino proposal dated September 9, 2011

of Sterling Equities, Related Companies and Triple M Development
(a joint venture named Willets Point Entertainment LLC) submitted
to New York City Economic Development Corporation;
page 15, artist’s rendering depicting casino, hotel and retail
development on public parkland located west of Citi Field stadium.
Attachment C
Excerpt from casino proposal dated September 9, 2011

of Sterling Equities, Related Companies and Triple M Development
(a joint venture named Willets Point Entertainment LLC) submitted
to New York City Economic Development Corporation;
page 5, letter from Shinnecock Indian Nation.
Attachment D
Willets Point Development Plan Final Generic Environmental Impact Statement

issued September 12, 2008; Chapter 17, Traffic and Parking.
To save paper for hard copy and reduce file size for PDF,
Attachment D (126 pages) is available online here:
https://www.scribd.com/document/621490077/D-
WilletsPoint-FGEIS-Chapt-17-Traffic-and-Parking
Attachment E
Willets Point Development Plan Final Generic Environmental Impact Statement

issued September 12, 2008; Chapter 23, Mitigation.
Attachment E (70 pages) is available online here:
https://www.scribd.com/document/621490065/E-
WilletsPoint-FGEIS-Chapt-23-Mitigation
Attachment F
Testimonies of traffic engineers Bernard Adler and Michael O’Rourke

at public hearing held by City Planning Commission on the topic of
Willets Point Development Plan, August 13, 2008.
Attachment G
Written material presented by Adler Consulting to

City Planning Commission and New York City Economic Development Corporation
on the topic of Willets Point Development Plan traffic, August 22, 2008.
Attachment H
Willets Point Development Plan Final Supplemental Environmental Impact Statement

issued August 2013; excerpt: Chapter 1, illustrative site plan - Phase 2.
2.28.13
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PROPOSED GARAGE PROPOSED GARAGE

PROPOSED GARAGE
PARKING FOR CITIFIELD PARKING FOR CITIFIELD
PARKING FOR CITIFIELD
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MTA BUS DEPOT
CORONA RAIL YARD
LIRR METS -
WILLETS POINT
S TAT I O N
Publicly-Accessible Open Space Private Open Spaces

within the Special Willets Point District within the Special Willets Point District
Illustrative Site Plan, Phase 2
WILLETS POINT Development Figure 1-6
Attachment I
Willets Point Development Plan Final Supplemental Environmental Impact Statement

issued August 2013; Chapter 14, Transportation.
Attachment I (269 pages) is available online here:
https://www.scribd.com/document/621490079/I-
WilletsPoint-FSEIS-Chapt-14-Transportation
Attachment J
Willets Point Development Plan Supplemental Environmental Impact Statement

issued August 2013; Chapter 21, Mitigation.
Attachment J (269 pages) is available online here:
https://www.scribd.com/document/621490067/J-
WilletsPoint-FSEIS-Chapt-21-Mitigation
Attachment K
Testimony of traffic engineer Brian Ketcham submitted to

City Planning Commission on the topic of the expanded
Willets Point Development Plan, July 10, 2013.
Chapler 2i; MilicaJitiii
the> arc found Eo be sigsuTicanih impacted under the 'With Action condition, mitigation
measures such as those typically implemented by NYOX’)T would be further explored to
address the impacts, or if no practicable mitigation measures can be identitled. the impitct,s
vsould be disclosed as bcitig unmitigatabie.
TRAFF1C-PHA.se 2(2032)
Table 2C5 pre.sents asummary of signilkam adverse traffic impacts and their ability to be
mitigated. Esnd Tabic 21-6 summarizes the unmitigated traffic study area locations by lisne
period. [3eSails of the intersection capacity results and traffic mitigation measure.s are provided in
tables as the back of this chapter.
Ta b l e 2 1 - 5
Traffic Impact Mitigation Summary—Phase 2(2032)

T Wrih aMets Game
Wfthotrt 9Mets Game
Weekelay Saturday Saturday
We e k d a y ^ We e k t e t e y Weekday Saturday iPfe-Game Post-Game
A M Midctey P U aKdday P M P M
Stgnrftcant impact 9 5 5 5 6 8 8
Fulfv ●it-gstec mpact 74 1 4 13 17 11 11 11
9 f t 7
Partiai;y Mir.gatecf- Imca; 3 7 / 5
5 t ; 6 7 5 i 5
Unmitigated impact
Ta b l e 2 1 - 6
Sumnaary of Unmitigated Intersections—Phase 2(2t)32)

Without aMets Game With aMgts Game
Waelw»y Satufda)f SaturOay

:WeeiMSay iWeeheay Weekday Saturday Pre-Game P r e - G a m a Post-Game
intersection A M iifciWay P M P M PS9
Astoria Bouieuafd a! 106tft Street X \ X
Nortnem 3cuieva-d at tOSth Street

Northern Boulevara at 1t4th Street
No.-them 3ouiev-ard at 126th Street
N o f T fi g r n B o u l e v a r d - a t P n n e e S t r e e t X \
\ \ \ X \ \
Northern Boufevard at Main Street
Northern Boulevard at Union Street X
Northern Bex.«tei-ard at Parsons Souievaird

S 4 t h A v e n u e a t 11 4 t h S ^ e e t
34th Avenue at I26th Street
Rooseveit Avenue at t08th Street
Roosevelt Avenue at 17 tth Street i r e s a \ \ \ \
R o c s e v e t t A v e n u e a t 11 4 t h S t r e e t
RoosevelT Avenue at I2€th Street !
Roosevelt Aygnue at Coliege Poifit Boulevara

Roosevelt Avenue at Pnnee Street
Rcosevetr Avenue at Mam Street \
.X X X \ \ X
Roosevelt A.venue at Union Street
Roosevelt Avenue at Parsons Boulevard \ X
Kissena Boulevard at Ma-n Street
Sanford Avenue at CcUege Point Boulevara

Sanford Avenue a? Union Street
Sanford Avenue at Parsons Boulevard
32nd Avenue at Coi^se Point Boulevard

X \ X \
Northern Boulevard at Col-ege Point Boulevard
Boat Basil Road at Stadium Road X l E W K X X
Boat Basn Road at WnrM sFair Manna

Stadium Road at Grand Cerstral Parkv.ay
Willets Point Boolevaro at Northern Boulevard
New Wiiiets Po-nt Boulevard at 126th Street
N o t e s : “ X ” m e a n s t h e i n t e r s e c t i o n w o a i d b e u i u n t t v ? a t g d i n t h e c o f r e s p o a d i fi g p e s k > » & u j
2/-/y
Attachment L
Special Flushing Waterfront District Environmental Assessment

dated December 13, 2019; excerpt: Transportation.
Attachment L (81 pages) is available online here:
https://www.scribd.com/document/621490073/L-
SpecialFlushingWaterfrontDistrict-EAS-Attach-M-Transportation
Attachment M
LaGuardia Airport AirTrain Environmental Impact Statement

issued March 2021; Chapter 3, Affected Environment and
Environmental Consequences; excerpt: pp. 268-275.
FEDERAL AVIATION ADMINISTRATION MARCH 2021
As discussed in Section 3.13.3, increased LIRR service under the Proposed Action would result in elevated noise
levels along the LIRR Port Washington Branch. Based on FTA significance criteria, approximately 571 residential and
hotel units are predicted to experience moderate noise impacts due to the increased LIRR service under the
Proposed Action when compared to the No Action Alternative, as shown on Exhibits 3.13-9, 3.13-10, and 3.13-11.
These impacts would primarily affect communities that can be classified as having a higher percentage minority
population, as identified on Exhibit 3.14-2. However, as the Proposed Action would only result in increases of
approximately 1 dBA in noise along an existing rail corridor, the Proposed Action would not result in high and
adverse effects on environmental justice populations.
As discussed in Section 3.15.3.4, the scale and the massing of the APM guideway and components would generally
contrast with the existing visual character. The Proposed Action would impact visual character in the General Study
Area, particularly for the residences overlooking the GCP. The Proposed Action would partially obstruct and contrast
with views from these residences of Flushing Bay. As shown on Exhibit 3.14-2, those communities in the vicinity of
the proposed APM can be classified as having a higher minority population and would be predominantly impacted
by the destruction or diminution of aesthetic value from the partial obstruction of their views of Flushing Bay.
Operation of the Proposed Action would not result in disproportionately high and adverse effects to environmental
justice populations due to impacts to coastal resources; historic, archaeological, architectural, and cultural resources;
and noise, vibration, and compatible land use. Environmental justice populations would experience disproportionally
high and adverse effects due to Section 4(f) and visual impacts as a result of operation of the Proposed Action.
Mitigation measures defined in Sections 3.8.5 and 3.15.5 would minimize these effects to the extent practicable, but
even with mitigation measures, effects would be disproportionately high and adverse. Therefore, the collective
impacts to environmental justice populations during operation of the Proposed Action would result in a significant
impact to environmental justice populations. Specific mitigation measures for environmental justice populations are
identified in Section 3.14.5.2.
Children’s Environmental Health and Safety Risks

The operation of the Proposed Action would not result in significant changes to health and safety risks including
air, food, drinking water, recreational waters, soil, or products children may use or to which they would be exposed.
As shown on Exhibits 3.13-9, 3.13-10, and 3.13-11, operational noise would result in moderate FTA-designated
impact levels along portions of the LIRR Port Washington Branch. No schools are located in areas where impacts
are identified; however, residential areas that are impacted may result in noise impacts to children. However, because
the Proposed Action would not increase health and safety risks attributable to products or substances that a child
is likely to come in contact with or ingest, such as air, food, water, recreational waters, soil, or products they may be
exposed to, the Proposed Action would not result in health and safety risks to children when compared to the No
Action Alternative.
Surface Transportation/Traffic
On-Airport traffic includes the curbsides, roadways, and public and employee parking facilities at LGA. Under future
operations of the Proposed Action in 2026 and 2031, it is assumed that the LaGuardia Redevelopment Program is
completed. As discussed in Section 1.3.1, the Port Authority is in the process of improving passenger level of service
at the existing passenger terminals and concourses as well as reconfiguring on-Airport roadways and improving
customer parking capacity.
The Proposed Action is a transportation improvement project that is designed to provide access options for
employees and passengers of LGA, reduce traffic congestion on off-Airport roadways near the Airport, and provide
connections to the local and regional transit system. Implementation of the Proposed Action is expected to shift a
LGA Access Improvement Project Final EIS | 3-268 | Affected Environment and Environmental Consequences
percentage of LGA passengers and employees from areas currently accessing on-Airport roadways and curbsides,
and reallocating demand to off-Airport locations.
As discussed in Section 3.2.3, two ridership studies were completed for the Proposed Action in order to assess
potential trips that would be generated by the proposed APM. The results of the ridership studies project that in
2026, between approximately 6.2 to 8.9 percent of all air passengers accessing LGA would cease accessing the
Airport via taxis, limousines, TNCs, and private vehicles, and instead would use public transit (the LIRR or 7 Line
connecting to the APM) to access the Airport. 248 In 2031, the percentage of all air passengers accessing LGA that
switch from surface vehicles to public transportation is projected to be between approximately 6.4 to 9.1 percent.
The projected shift of air passengers using private vehicles, taxis, limousines, and TNCs (which are considered low-
occupancy vehicles) to public transportation would reduce surface vehicle trips to and from the Airport. A passenger
occupancy factor was applied to low-occupancy vehicles in order to quantify the resulting number of vehicle trips
projected to be removed from the New York City roadway network. Assuming an average vehicle occupancy of
1.67 passengers per vehicle, 249 the Proposed Action is projected to remove between approximately 1.1 million and
1.5 million vehicle trips from the New York City roadway network in 2026 and between approximately 1.2 million
and 1.6 million vehicle trips in 2031. It is estimated that this would result in the reduction of between approximately
18.4 million to 26.0 million annual VMT in 2026 and between approximately 21.3 million to 27.9 million annual VMT
in 2031. 250 A reduction in up to approximately 27.9 million annual VMT is equal to the distance between Earth and
Venus. Table 3.14-13 provides daily and annual estimates of the projected reduction in vehicle trips and VMT.
TABLE 3.14-13 PROJECTED REDUCTION IN VEHICLE TRIPS AND VEHICLE MILES TRAVELED
2026 2031
AVERAGE DAILY AVERAGE ANNUAL AVERAGE DAILY AVERAGE ANNUAL
FORECAST VEHICLES VMT 1 VEHICLES VMT 1 VEHICLES VMT 1 VEHICLES VMT 1
Port Authority 2 4,163 71,187 1,520,536 26,001,161 4,470 76,437 1,632,668 27,918,614
FAA 2,945 50,360 1,075,661 18,393,807 3,411 58,328 1,245,868 21,304,339
NOTES:
FAA – Federal Aviation Administration
VMT – Vehicle Miles Traveled
1 Assumes a weighted average 17.1-mile roundtrip distance to the Airport based on the representative access points listed in Table 2-4 and the local trip origins
and destination listed in Table 1-1.
2 Port Authority forecasts for 2026 and 2031 were estimated based on the Port Authority 2025 and 2045 forecasts using a straight-line method. Forecasts of inter-
terminal rides were excluded from the forecasts presented here.
SOURCE: B-A Engineering, Passenger to Vehicle Estimate – Weekday, May 26, 2020.
To quantify localized off-Airport traffic conditions for the Proposed Action, an LOS analysis was conducted for 18
intersections and 5 freeway segments within and adjacent to the General Study Area (see Exhibit 3.14-4). These
248
It is also projected that implementation of the APM would shift approximately 10.9 percent of employee trips from private vehicles to
public transportation. However, this projected shift has not been quantified in terms of a reduction in surface vehicles trips as it is difficult
to determine the precise geographic locations of where the mode shift would occur.
249
Port Authority of New York and New Jersey, AirTrain LGA: LGA Ground Access Mode Choice Model and AirTrain Ridership Forecast 2025-
2045, October 2018.
250
Vehicle miles traveled were calculated using vehicle volumes from Section 3.14 and a weighted average 17.1-mile roundtrip distance for
passengers traveling to and from LGA (based on the representative access points listed in Table 2-4 and the local trip origins and
destination listed in Table 1-1).
intersections and freeway segments were chosen in order to determine localized traffic impacts based on the shift
of employee parking from Lot P10 to the APM OMSF and Parking Structure, the shift in passenger and employee
drop-off/pick-up to the proposed curb at the Willets Point APM Station, as well as new trips for APM employees.
Entrances to the Southfield Commuter Lot and APM OMSF and Parking Structure would be designed to prevent
backup of traffic onto Roosevelt Avenue. Intersection and freeway segment traffic volumes, as well as additional
information regarding methodology and impact determination, are provided in Appendix O.
In general, surface traffic on freeway segments near Flushing Meadows-Corona Park on the GCP, the Van Wyck
Expressway, and the Whitestone Expressway under the Proposed Action in 2026 and 2031 would generally be the
same as the No Action Alternative for segments operating at fair (LOS D) or better conditions.
Similar to the No Action Alternative, freeway segments along the GCP in the vicinity of the Airport are projected to
operate at mostly poor or failing conditions (LOS E or F) upon implementation of the Proposed Action. However, by
shifting a percentage of LGA passengers and employees from on-Airport roadways and curbsides, and reallocating
demand to off-Airport locations, traffic volumes along the GCP adjacent to the Airport would decrease, resulting in
a reduction of density (passenger cars per mile per lane) along the GCP mainline and ramp locations. An analysis of
the peak commuter hours (see Appendix O.11) indicates that the Proposed Action is projected to reduce peak hour
traffic on the GCP by between approximately 1.9 to 5.4 percent in both 2026 and 2031. Table 3.14-14 summarizes
projected GCP vehicle reductions for both forecasts, in the eastbound and westbound directions, for each peak hour
in both 2026 and 2031. In turn, it was estimated that average vehicle speeds along these segments of the GCP would
increase between 0.3 and 1.6 miles per hour in the morning, evening and Saturday peak hours. The midday peak
hour was estimated to experience speed increases between 18.3 and 23.3 miles per hour.
TABLE 3.14-14 ESTIMATED PEAK HOUR VEHICLE REDUCTION ON THE GRAND CENTRAL PARKWAY
PORT AUTHORITY FORECAST 1
FAA FORECAST
A.M. MIDDAY P.M. SATURDAY A.M. MIDDAY P.M. SATURDAY

SCENARIO PEAK 2 PEAK 3 PEAK 4 PEAK 5 PEAK 2 PEAK 3 PEAK 4 PEAK 5
2026
Westbound 159 (-2.0%) 290 (-3.8%) 245 (-3.8%) 279 (-3.7%) 143 (-1.9%) 244 (-3.2%) 208 (-3.2%) 233 (-3.1%)
Eastbound 133 (-2.3%) 305 (-5.4%) 194 (-3.3%) 264 (-5.0%) 121 (-2.1%) 282 (-4.9%) 177 (-3.0%) 231 (-3.5%)
2031
Westbound 173 (-2.2%) 312 (-3.9%) 263 (-3.8%) 302 (-3.8%) 155 (-1.9%) 262 (-3.2%) 223 (-3.2%) 251 (-3.1%)
Eastbound 142 (-2.3%) 327 (-5.4%) 208 (-3.3%) 286 (-5.1%) 130 (-2.1%) 303 (-5.0%) 190 (-3.0%) 249 (-3.5%)
NOTES:
FAA – Federal Aviation Administration
1 Port Authority forecasts for 2026 and 2031 were estimated based on the Port Authority 2025 and 2045 forecasts using a straight-line method. Forecasts of inter-
terminal rides were excluded from the forecasts presented here.
2 A.M. Peak is defined as 7:15–8:15 a.m.
3 Midday Peak is defined as 1:00–2:00 p.m.
4 P.M. Peak is defined as 4:45–5:45 p.m.
5 Saturday Peak is defined as 2:00–3:00 p.m.
SOURCE: B-A Engineering, NEPA EIS – Technical Memorandum 9 – Grand Central Parkway - 2026 and 2031 Future Traffic Conditions – Non-Game Day, December 11,
2020.
An impact summary of off-Airport intersections based on FAA’s factors to consider (unacceptable change in LOS) 251
are shown in Tables 3.14-15 and 3.14-16 for 2026 and 2031, respectively. 252 As shown in the tables, five intersections
were estimated to be significantly impacted under the Proposed Action in either 2026 or 2031 (non-gameday
scenario). A summary of impacted intersections includes:
Boat Basin Place and Marina Road – significant impact in the A.M. and P.M. peak hours
126th Street and Shea Road/34th Avenue – significant impact in the Saturday peak hour
Roosevelt Avenue and 126th Street – significant impact in the Midday peak hour
Roosevelt Avenue and Southfield Employee Lot – significant impacts in the A.M., Midday, P.M., and Saturday
peak hours
Roosevelt Avenue and 114th Street – significant impacts in the A.M., Midday, P.M., and Saturday peak hours
Additionally, seven intersections are expected to be impacted per CEQR significance thresholds. However, these are
for disclosure purposes only and will not be used to determine significance for purposes of this EIS. Five of these
intersections would also be significantly impacted based on FAA’s factors to consider, as noted above.
Boat Basin Place and Marina Road – significant impact in the P.M. peak hour
126th Street and Shea Road/34th Avenue – significant impact in the Midday, P.M., and Saturday peak hours
Roosevelt Avenue and 126th Street – significant impact in the Midday, P.M., and Saturday peak hours
Roosevelt Avenue and Southfield Employee Lot – significant impacts in the A.M., Midday, and P.M. peak hours
Roosevelt Avenue and Stadium Place North and South – significant impact in the Saturday peak hour
Roosevelt Avenue and 114th Street – significant impacts in the A.M., Midday, P.M., and Saturday peak hours
114th Street and 34th Avenue – significant impact in the Midday peak hour
Impacted intersections for 2026 and 2031 (non-gameday scenario) are shown on Exhibit 3.14-7.
As stated in Section 3.14.3.1, an analysis of the gameday scenario was conducted for disclosure purposes only. The
analysis included the same 18 intersections analyzed as part of the non-gameday scenario; however, only two peak
hours were analyzed, the Weekday P.M. Peak Hour (6:00 p.m. to 7:00 p.m.) and Saturday Peak Hour (3:30 p.m. to
4:30 p.m.). The methodology for the gameday scenario analysis was similar to the non-gameday analysis. Existing
2018 traffic volumes were projected to future 2026 and 2031 traffic levels, while accounting for other background
development projects in the area. The Proposed Action was then compared to the No Action Alternative. Per CEQR
impact criteria, a total of six intersections were estimated to be significantly impacted under the Proposed Action in
either 2026 or 2031 (gameday scenario), as discussed further in Appendix O.6, 253 but were not used to determine
significance for purposes of this EIS. Impacted intersections include:
Boat Basin Place and Marina Road – significant impact in the Weekday P.M. and Saturday peak hours
126th Street and Shea Road/34th Avenue – significant impact in the Weekday P.M. and Saturday peak hours
Roosevelt Avenue and 126th Street – significant impact in the Weekday P.M. and Saturday peak hours
Roosevelt Avenue and Stadium Place North – significant impact in the Saturday peak hour
Roosevelt Avenue and Southfield Employee Lot – significant impacts in the Weekday P.M. peak hour
Roosevelt Avenue and 114th Street – significant impacts in the Weekday P.M. and Saturday peak hours
251
Indicates a change from LOS A, B, C, or D to LOS E or F; or LOS E to LOS F.
252
Tables 3.14-12 and 3.14-13 also identify significant impacts based on CEQR criteria; however, only analysis based on FAA factors to
consider is shown. See Appendix O for full CEQR analysis.
253
B-A Engineering, 2018 Existing, 2026 and 2031 Future Traffic Conditions – Intersection Peak Hour Analysis – Game Day (GD), May 20, 2020.
TABLE 3.14-15 OFF-AIRPORT TRAFFIC IMPACT SUMMARY – 2026

NO ACTION ALTERNATIVE PROPOSED ACTION
MIDDAY SATURDAY MIDDAY SATURDAY SIGNIFICANT

A.M. PEAK 1 PEAK 2 P.M. PEAK 3
PEAK 4 A.M. PEAK 1
PEAK 2 P.M. PEAK 3
PEAK 4 IMPACT?
INTERSECTIONS DELAY LOS DELAY LOS DELAY LOS DELAY LOS DELAY LOS DELAY LOS DELAY LOS DELAY LOS FAA CEQR
1. Boat Basin Place and Marina Road 33.9 D 17.9 C 29.9 D 14.2 B 46.1 E 23.3 C 42.7 E 15.8 C A.M., P.M. P.M.
2. Boat Basin Place and Shea Road 12.9 B 13.2 B 15.0 B 14.6 B 12.9 B 13.0 B 14.8 B 14.3 B
3. 126th Street and Northern Boulevard 29.5 C 34.0 C 34.3 C 32.8 C 29.6 C 33.9 C 34.3 C 32.8 C
4. 126th Street and Shea Road/34th Avenue 37.5 D 38.5 D 45.9 D 45.0 D 38.9 D 45.1 D 50.7 D 50.6 D MD, P.M.,
SAT
5. 126th Street and 35th Avenue 5 12.1 B 14.1 B 16.0 C 17.3 C 12.6 B 15.1 C 16.8 C 18.4 C
6. 126th Street and 36th Avenue 5
11.0 B 10.9 B 13.7 B 13.5 B 11.2 B 11.2 B 14.2 B 13.9 B
7. 126th Street and 37th Avenue 5 0.0 A 12.0 B 0.0 A 9.4 A 0.0 A 12.7 B 0.0 A 9.4 A
8. 126th Street and 38th Avenue 5 9.8 A 10.2 B 10.5 B 10.2 B 9.8 A 10.4 B 10.7 B 10.3 B
9. Roosevelt Avenue and 126th Street 19.9 B 21.5 C 29.4 C 21.6 C 21.9 C 102.5 F 33.1 C 26.5 C MD MD, P.M.
10. Roosevelt Avenue and Stadium Place North 28.9 D 18.8 C 27.7 D 83.3 F 32.2 D 22.4 C 31.8 D 108.6 F SAT
and South 5 6
11. Roosevelt Avenue and Southfield Employee 10.5 B 20.4 C 20.5 C 30.6 D 59.2 F 55.3 F 134.3 F 37.9 E A.M., MD, A.M., MD,
Lot 5 P.M., SAT P.M.
12. Roosevelt Avenue and 114th Street 50.4 D 54.2 D 73.9 E 59.6 E 56.5 E 77.4 E 94.0 F 79.3 E A.M., MD, A.M., MD,
P.M. P.M., SAT
13. 114th Street and 39th Avenue 5 - - - - - - - - - - - - - - - -
14. 114th Street and 38th Avenue 5 11.7 B 11.7 B 11.8 B 12.0 B 12.2 B 12.5 B 12.2 B 12.6 B
15. 114th St and 37th Avenue 16.9 B 14.4 B 15.8 B 18.1 B 17.7 B 16.6 B 16.4 B 19.8 B
16. 114th Street and 34th Avenue 6
17.8 B 20.7 C 18.5 B 20.2 C 19.5 B 28.9 C 19.0 B 22.1 C MD
17. Shea Road and Stadium Place North 5 11.9 B 11.9 B 14.3 B 18.4 C 12.4 B 13.8 B 15.3 C 18.3 C
18. Shea Road and GCP Westbound On-Ramp 5 11.3 B 10.4 B 10.9 B 10.4 B 11.9 B 11.3 B 11.5 B 11.0 B
NOTES:
CEQR – New York City Environmental Quality Review GCP – Grand Central Parkway
FAA – Federal Aviation Administration LOS – Level of Service
1 A.M. Peak is defined as 7:15–8:15 a.m.
2 Midday (MD) Peak is defined as 1:00–2:00 p.m.
3 P.M. Peak is defined as 4:45–5:45 p.m.
4 Saturday (SAT) Peak is defined as 2:00–3:00 p.m.
5 Intersection is unsignalized.
SOURCE: B-A Engineering, NEPA EIS – Technical Memorandum 4 – 2026 and 2031 Future Traffic Conditions – Intersection and Mainline – Peak Hour Volumes and Analysis – Non-Game Day, April 17, 2020.
TABLE 3.14-16 OFF-AIRPORT TRAFFIC IMPACT SUMMARY – 2031

NO ACTION ALTERNATIVE PROPOSED ACTION
MIDDAY SATURDAY MIDDAY SATURDAY SIGNIFICANT
A.M. PEAK 1 PEAK 2 P.M. PEAK 3
PEAK 4 A.M. PEAK 1
PEAK 2 P.M. PEAK 3
PEAK 4 IMPACT?
INTERSECTIONS DELAY LOS DELAY LOS DELAY LOS DELAY LOS DELAY LOS DELAY LOS DELAY LOS DELAY LOS FAA CEQR
1. Boat Basin Place and Marina Road 48.9 E 21.4 C 38.4 E 15.9 C 70.7 F 29.8 D 159.6 F 17.9 C A.M., P.M. P.M.
2. Boat Basin Place and Shea Road 14.9 B 14.8 B 15.4 B 14.9 B 14.8 B 14.6 B 15.3 B 14.7 B
3. 126th Street and Northern Boulevard 34.1 C 33.1 C 35.4 D 33.1 C 34.2 C 32.9 C 35.6 D 33.1 C
4. 126th Street and Shea Road/34th Avenue 38.0 D 40.0 D 48.8 D 47.9 D 40.1 D 49.3 D 54.3 D 55.6 E SAT MD, P.M.,
SAT
5. 126th Street and 35th Avenue 5 14.9 B 18.0 C 17.9 C 20.2 C 15.7 C 19.8 C 19.0 C 21.8 C
6. 126th Street and 36th Avenue 5 12.5 B 12.3 B 14.9 B 15.0 B 12.8 B 12.7 B 15.5 C 15.7 C
7. 126th Street and 37th Avenue 5 0.0 A 14.4 B 0.0 A 9.6 A 0.0 A 15.3 C 0.0 A 9.6 A
9. Roosevelt Avenue and 126th Street 20.8 C 23.6 C 30.0 C 21.9 C 23.0 C 129.7 F 33.9 C 27.6 C MD, P.M.,
SAT
10. Roosevelt Avenue and Stadium Place 30.8 D 19.2 C 28.8 D 89.5 F 32.2 D 23.2 C 33.7 D 120.0 F SAT
North and South 5 6
11. Roosevelt Avenue and Southfield 10.6 B 21.3 C 20.9 C 31.4 D 82.1 F 71.6 F 170.0 F 40.6 E A.M., MD, A.M., MD,
Employee Lot 5 P.M., SAT P.M.
12. Roosevelt Avenue and 114th Street 58.3 E 60.7 E 79.4 E 63.4 E 66.7 E 92.0 F 101.5 F 86.1 F MD, P.M., A.M., MD,
SAT P.M., SAT
13. 114th Street and 39th Avenue 5 - - - - - - - - - - - - - - - -
15. 114th St and 37th Avenue 17.2 B 14.6 B 15.9 B 18.0 B 18.0 B 17.2 B 16.7 B 19.8 B
16. 114th Street and 34th Avenue 6 17.7 B 21.1 C 18.7 B 20.4 C 19.7 B 32.6 C 19.2 B 22.5 C MD
17. Shea Road and Stadium Place North 5
12.0 B 12.1 B 14.4 B 18.7 C 12.6 B 14.3 B 15.6 C 18.7 C
18. Shea Road and GCP Westbound On-Ramp 12.6 B 11.2 B 11.2 B 10.7 B 13.4 B 12.6 B 11.9 B 11.5 B
5
NOTES:
CEQR – New York City Environmental Quality Review GCP – Grand Central Parkway
FAA – Federal Aviation Administration LOS – Level of Service
1 A.M. Peak is defined as 7:15 a.m. to 8:15 a.m.
2 Midday (MD) Peak is defined as 1:00 p.m. to 2:00 p.m.
3 P.M. Peak is defined as 4:45 p.m. to 5:45 p.m.
4 Saturday (SAT) Peak is defined as 2:00 p.m. to 3:00 p.m.
5 Intersection is unsignalized.
SOURCE: B-A Engineering, NEPA EIS – Technical Memorandum 4 – 2026 and 2031 Future Traffic Conditions – Intersection and Mainline – Peak Hour Volumes and Analysis – Non-Game Day, April 17, 2020.
Mitigation measures for gameday impacts have not been identified as traffic in the vicinity of Citi Field would be
controlled by the New York Police Department during these periods. Therefore, no mitigation measures are needed.
Additional information on the gameday analysis methodology and results are provided in Appendix O.
With implementation of mitigation, traffic impacts from the operation of the Proposed Action would not be
significant when compared to the No Action Alternative.
Public Transportation
Projected ridership on the APM system is dependent in part on the existing New York City public transportation
network, including the existing and planned LIRR service and the proposed new shuttle service on the Port
Washington Branch, as well as the 7 Line. MTA has indicated that the APM ridership projections are not expected
to have a significant effect on the LIRR or subway lines (see Appendix A.5). MTA provided the following ridership
data for 2018 to demonstrate existing capacity of the 7 Line:
In the morning peak, the peak ridership direction is Manhattan bound. In that direction, the peak load on the
7 Line Local occurs at 40th Street with a volume of 13,442 and a V/C ratio of 0.79. This indicates that the peak
occupancy of the local trains is 79 percent and that the trains have 21 percent available capacity at the peak.
The peak load on the 7 Line Express occurs at Woodside-61st Street with a volume of 16,333 and a V/C of 0.90.
This indicates that the peak occupancy of the express trains is 90 percent and that the trains have 10 percent
available capacity.
In the evening peak, the peak ridership direction is Queens bound. In that direction, the peak load on the 7 Line
Local occurs at Queensboro Plaza with a volume of 10,727 and a V/C ratio of 0.74. This indicates that the peak
occupancy of the local trains is 74 percent and that the trains have 26 percent available capacity at the peak.
The peak load on the 7 Line Express occurs at Queensboro Plaza with a volume of 12,109 and a V/C of 0.84. This
indicates that the peak occupancy of the express trains is 84 percent and that the trains have 16 percent available
capacity.
To evaluate the issue of potential congestion, the FAA’s Consultant Team for the EIS forecast the APM passengers
on the 7 Line by time of day and direction. Peak forecast APM passengers on the 7 Line are expected during off-
peak subway times and in the reverse commute direction. In 2026, the FAA forecast of APM riders that would take
the 7 Line to or from the Willets Point APM Station equates to 375 riders to LGA and 171 riders from LGA during
the morning peak (6:00 a.m. to 10:00 a.m.), 969 riders to LGA and 633 riders from LGA during the midday (10:00 a.m.
to 4:00 p.m.), and 308 riders to LGA and 522 riders from LGA during the evening peak (4:00 p.m. to 8:00 p.m.). The
Port Authority forecast indicates that during the first year of operation up to 243 riders to LGA and 81 riders from
LGA per hour during the morning peak (6:00 a.m. to 10:00 a.m.), up to 257 riders to LGA and 149 riders from LGA
per hour during the midday peak (10:00 a.m. to 4:00 p.m.), and up to 120 riders to LGA and 202 riders from LGA per
hour during the evening peak (4:00 p.m. to 8:00 p.m.) would take the 7 Line to or from the Willets Point APM Station.
Based on 2018 ridership data and the available capacities provided by MTA, there is sufficient capacity on the 7 Line
to accommodate the projected ridership for passengers using the 7 Line to access the proposed APM. Even at peak
ridership demand (257 riders per hour under the Port Authority forecast) during peak 7 Line Express occupancy,
there is still available capacity. It is important to note that all peak ridership demand numbers on both forecasts
occur during the midday period, outside of the morning and evening peaks for 7 Line ridership. Furthermore, the
morning and evening peak demand estimated in the two APM forecasts are for travel in the opposite direction of
7 Line peak ridership. When compared to the No Action Alternative, the Proposed Action would result in
approximately 43 and 77 additional 7 Line trips in the peak direction during the weekday morning and evening peak
hours, respectively. This level of transit trip activity is well below the CEQR threshold (200 peak hour transit trip-
Attachment N
New York Times article published August 13, 2010

concerning agencies’ review of new Van Wyck
Expressway ramps required for Willets Point development,
“E-Mails Show State Officials’ Skepticism About Willets Point Project”.
Attachment O
Access Modification Report dated March 2012,

prepared by New York City Economic Development Corporation for
New York State Department of Transportation and Federal Highway Administration,
pertaining to Van Wyck Expressway new access ramps
required for Willets Point development; excerpt: Figure 1.4.

Letter SaveFMCP To Gaming Facility Location Board

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SAVE FLUSHING MEADOWS-CORONA PARK

146-24 32nd Avenue

January 30, 2023

Ms. Quenia A. Abreu

Vicki L. Been, Esq.

Stuart Rabinowitz, Esq.

Dear Ms. Abreu, Ms. Been and Mr. Rabinowitz:

• Although Part RR establishes a process to consider and award casino licenses,

N.Y.S. Gaming Commission

Via email to: Kristen.Buckley@gaming.ny.gov, Stacey.Relation@gaming.ny.gov,

Dear NYS Gaming Commission:

Below is the organization’s information as requested in the RFI.

• Submitter’s Name – Queens Civic Congress, Inc.

• Contact Name and Title – Kevin J. Forrestal, President

• Contact Telephone Number – 718-374-1359

• Contact Email Address – kjforrestal@gmail.com

• Mailing Address – 82-36 166th Street, Hillcrest Estates, NY 11432-1218

Kevin J. Forrestal, President

Via email to: Kristen.Buckley@gaming.ny.gov, Stacey.Relation@gaming.ny.gov,

Dear NYS Gaming Commission:

Our answer is “Yes, absolutely.”

Kevin J. Forrestal, President

Our answer is “Yes, absolutely.”

• The 62-acre Willets Point development, consisting of up to 8.94 million

• The 29-acre Special Flushing Waterfront District, consisting of 2,993,768

• The LaGuardia Airport AirTrain, which includes a dedicated new parking

A Better College Point Civic Association 3

Dear NYS Gaming Commission:

Our organization, Northwest Bayside Civic Association, represents the interests of

Jena Lanzetta, President

Northwest Bayside Civic Association

N.Y.S. Gaming Commission

Via email to Kristen.Buckley@gaming.ny.gov, Stacey.Relation@gaming.ny.gov,

Re: Response to New York Gaming Commission’s Request for Information

Submitters’ Names: Jack Bono and Jake Bono

Dear New York State Gaming Commission:

N.Y.S. Gaming Commission

Ms. Kristen Buckley

Ms. Stacey Relation

Ms. Alysan Bowers

Dear New York State Gaming Commission:

• Submitter’s Name: Robert LoScalzo

I anticipate that respondents to the RFI or to a future Request for Applications

(a) Traffic congestion; obstruction of essential highways and local roads

It is nonsensical to establish a casino “attraction” at a place that will be incapable

Willets Point development

Among the development projects already approved and currently proceeding in

The entire Willets Point redevelopment “Proposed Plan”, approved in 20081,

The Willets Point Development Plan Final Generic Environmental Impact

• Level of Service “F” during weekdays AM (non-game days)3.

The FGEIS Mitigation chapter plainly states, as concerns Roosevelt Avenue at

“I have never seen this level of unmitigated impact in over 40 years of

“Significant impacts will also occur on the highway network, resulting in

The Willets Point FSEIS includes a “Transportation” chapter (Attachment I) which

“Project impacts reported in the SDEIS are extremely severe and it is

As the Willets Point FSEIS is an approved environmental review document,

Special Flushing Waterfront District

An Environmental Assessment Statement dated December 13, 2019 (“EAS”) was

• The southbound approach of College Point Boulevard at Roosevelt Avenue,