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May 13, 2023

Via email to ramos@nysenate.gov; hard copy via USPS mail

Hon. Jessica Ramos

New York State Senator, District 13
74-09 37th Avenue
Jackson Heights, New York 11372

Re: Opposition to Parkland Alienation Legislation – Citi Field Vicinity

Dear Senator Ramos:

I understand that you will hold a town hall meeting on May 19 to hear feedback
regarding potential alienation of parkland in the Citi Field vicinity. However, during a virtual
committee meeting of Queens Community Board 7 which you attended on May 10, you
stated that on May 11 you would be meeting with unspecified “groups” that are concerned
about such parkland alienation.

Among the key groups that were not invited to meet with you on May 11 are the
Queens Civic Congress, which represents the interests of 60+ civic groups throughout
Queens, and Save Flushing Meadows Corona Park, a coalition of civic organizations,
civic leaders and residents committed to protecting public parkland in Queens’ flagship
park.

I am writing to ensure you are aware that the Queens Civic Congress has adopted
the following resolution:

“Queens Civic Congress strongly opposes the alienation of parkland,

including but not limited to Citi Field, and we stand opposed to the bill
introduced in the New York State Assembly as A5688.”1

See Attachment A.

Meanwhile, the position of Save Flushing Meadows Corona Park has been
reported by the press for many months. See Attachments B and C.

Indeed, both the Queens Civic Congress and individual civic organizations that are
members of Save Flushing Meadows Corona Park expressed their strong opposition to
any alienation and commercialization of parkland in the Citi Field vicinity, in writing to the
NYS Gaming Commission as long ago as December 2021, in response to the

1
i.e., the bill introduced by Assemblyman Aubry to alienate certain Flushing Meadows Corona Park land for the
development of a gaming facility (casino).
Commission’s Request for Information (“RFI”) concerning unawarded commercial casino
licenses.

The RFI specifically asked whether any areas should “be excluded from
consideration” as potential new casino sites. Significantly, the only area, anywhere, that
any RFI respondent identified as inappropriate for a casino, is the parkland surrounding
Citi Field stadium.

On April 2, 2022, I sent a letter to you with several of the RFI responses attached.
USPS postal records document that the mailpiece was delivered to your office on April 4,
2022. However, you never acknowledged or responded to my letter which included the
RFI responses objecting to the Citi Field parkland as a potential casino site.

The NYS Gaming Commission was required by statute2 to prepare a report with
the results of its RFI, and to distribute the report to the legislature. Had the Commission
done so, the report necessarily would have documented all of the objections to the
parkland in the Citi Field vicinity as a potential casino site, and the reasons therefor.
However, the Commission never prepared the report, or distributed it to the legislature.

On August 8, 2022, I sent a second letter to you, concerning the NYS Gaming
Commission’s apparent failures to produce the statutory report with the results of the RFI,
and to deliver the report to the legislature. USPS postal records document that the
mailpiece was delivered to your office on August 9, 2022. However, you never
acknowledged or responded to my letter – even though the letter concerned a report that
you, as a legislator, were entitled to receive from the NYS Gaming Commission, but which
the Commission never produced.

There are many reasons why there is strong opposition to the alienation of public
parkland in the Citi Field vicinity, and/or its potential use as a casino site. They include:

Parkland is a non-renewable resource that must be protected.

• The public trust doctrine imposes a duty to hold public land for the use and
enjoyment of everyone in the public.

• No proposal would be taken seriously, to alienate and make available for

commercial purposes scores of acres of Central Park, Prospect Park or Van
Cortlandt Park. Queens’ flagship park deserves the same respect, not to be
considered developable land.

• No use of the land would be more diametrically opposed to the purposes

for which parkland exists and is set aside in the first place, than to construct
a money-centric commercial casino.

2 Laws of 2021, Chapter 59, Part Z.

Page 2 of 5
 The parkland surrounding Citi Field actually hosts numerous public events,
year-round.

• NY Mets owner Steve Cohen and his consultants have attempted to

characterize the Citi Field parkland as dormant. But in doing so, they
conveniently overlook that the very same parkland is routinely the site of
numerous large, popular public events. See Attachment D.

• That fact that this parkland is paved asphalt is one factor that makes it an
appropriate location for the numerous large, popular public events that are
held year-round. See Attachment D.

• If the parkland surrounding Citi Field is no longer available to host such

events, some of them may relocate into the nearby grassy areas of Flushing
Meadows Corona Park – requiring the closure of those public areas to
everyone except ticket holders for the durations of the events. An example
of this is the upcoming Governor’s Ball, which was previously held on the
Citi Field parkland but is being held this year within the grassy area of
Flushing Meadows Corona Park – thus displacing all of the park’s routine
users from that area of the park for the duration of the event. Governor’s
Ball will occur from June 9 through June 11, but the set-up and tear-down
of the three distinct stage areas will require many more days than that.

An attraction constructed on the Citi Field parkland will exacerbate already

horrendous vehicular traffic, and even worse future traffic to be caused by
Willets Point development.

• Your NYS Senate web site states that you do not have a driver’s license.
Thus, you have not experienced the driver’s perspective of gridlock traffic
that routinely occurs in the Citi Field area on the Whitestone Expressway,
Van Wyck Expressway, Northern Boulevard, Roosevelt Avenue, and other
roadways, exit ramps and intersections. See Attachment E.

• The horrendous present-day traffic conditions are without the construction

of the 62-acre Willets Point development. The Final Generic Environmental
Impact Statement for the Willets Point development predicts severe,
unmitigable traffic impacts that will result from the Willets Point
development, including a traffic Level of Service of “F” at 126th Street and
Roosevelt Avenue during weekday mornings, weekdays mid-day, weekday
evenings and Saturdays mid-day, even on non-game days.3 Traffic Level of
Service “F” (i.e., “Fail”) indicates a “constant traffic jam”.4

3See Willets Point Development Final Generic Environmental Impact Statement, Chapter 23.
4See “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 April 23, 2020.

Page 3 of 5
 • During the 2008 Willets Point development ULURP, Bernard Adler, a
licensed professional engineer and the former Commissioner of Traffic for
the City of White Plains, testified that as concerns the traffic impacts of the
Willets Point development documented in the environmental review, “I have
never seen this level of unmitigated impact in over 40 years of practice as
a traffic engineer. This is an unprecedented overload of the local roadway
system.”5 An additional casino or entertainment attraction near Citi Field will
exacerbate those already-overloaded conditions.

• From the southbound Whitestone Expressway, only one exit ramp leads
down into the Citi Field area – Exit 13D. Traffic on that exit ramp already
routinely spills back onto the Whitestone Expressway mainline and
obstructs the flow of traffic, especially when events occur at Citi Field. An
additional casino or entertainment attraction near Citi Field will exacerbate
this condition, ruining the reliability of the Whitestone Expressway. The
Expressway cannot be widened to improve it.

Casinos bring social ills that are unwanted by the community and will harm
it.

• Per the parkland alienation bill sponsored in the NYS Assembly by

Assemblyman Aubry, the purpose of the potential alienation is to enable a
gaming facility (casino).

• Casinos “lead to a plethora of social ills, including increased substance

abuse, mental illness and suicide, violent crime, auto theft and larceny, and
bankruptcy. The latter three all increased by 10 percent in communities that
allowed gambling. … 8 percent of crime in counties with casinos was
attributable to their presence.”6

• Casinos depend upon problem gamblers for their revenue base.7

• Living close to a casino increases the chance of becoming a problem

gambler.8

• Problem gambling affects families and communities as well as individuals.9

• Young people are viewed as the future of casino gambling.10

5 Testimony of Bernard Adler, P.E. to City Planning Commission, August 13, 2008.
6 “Studies: Casinos bring jobs, but also crime, bankruptcy, and even suicide,” The Washington Post, Dylan Matthews,
October 30, 2012.
7 “Why Casinos Matter: Thirty-One Evidence-Based Propositions from the Health and Social Sciences,” Council on

Casinos, 2013 at 18.

8 Id.
9 Id. at 20.
10 Id. at 21.

Page 4 of 5
 • Casinos extract wealth from communities.11

• Casinos typically weaken nearby businesses.12

• Casinos typically hurt property values in host communities.13

• A casino in the Citi Field vicinity – within easy walking distance of Flushing
– will prey upon Flushing’s Asian community. “Research shows Asians in
the U.S. have a disproportionate number of pathological gamblers (i.e.
addicted) as compared to the general American population.”14

* * *

For at least the reasons summarized above, there is strong opposition to the
alienation, commercialization and potential casino use of public parkland in the Citi Field
vicinity. I encourage you to refrain from introducing any Senate bill concerning such
alienation.

If you would like to meet with representatives of the Queens Civic Congress and
Save Flushing Meadows Corona Park, it would be my pleasure to help facilitate it.

Sincerely,

Robert LoScalzo

5 enclosures (Attachments A-E)

11 Id. at 24.
12 Id.
13
Id. at 25.
14“Asian Gambling Addiction: The high proportion of Asians who gamble is no coincidence,” Psychology Today, Sam
Louie MA, LMHC, July 10, 2014.

Page 5 of 5
 Attachment A

Queens Civic Congress resolution

adopted April 18, 2023.
Queens Civic Congress Opposes Parkland Alienation Legislation 5/5/23, 12:2528 AM

From: queenscivic@gmail.com,
To: rlosca@aol.com,
Subject: Queens Civic Congress Opposes Parkland Alienation Legislation
Date: Wed, Apr 19, 2023 2:13 pm

Queens Civic Congress Opposes Parkland Alienation Legislation

QCC Parkland Alienation Resolution

Assemblyman Aubry has introduced legislation to alienate
portions of Flushing Meadows Corona Park for the development
of a Citi Field Entertainment Center/Casino.

Queens Civic Congress views parkland as sacred and

irreplaceable.

In response, on April 18, 2023, Queens Civic Congress approved

the following resolution:

Passed unanimously at the QCC general meeting, April 18,

2023:

“Queens Civic Congress strongly opposes the alienation of

parkland, including but not limited to Citi Field, and we
stand opposed to the bill introduced in the New York State
Assembly as A5688.”

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| Queens Civic Congress Website

Queens Civic Congress | P.O. Box 604759, Bayside, NY 11360

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 Attachment B

“Civics opposed to Citi Field casino; ahead of visioning sessions,

Queens groups aim to protect parkland,” Queens Chronicle,
Sophie Krichevsky, January 5, 2023.
 Attachment C

Save Flushing Meadows Corona Park news release

issued January 3, 2023.
*** CIVICS CHAMPION DEVELOPMENT-FREE PARK *** 1/3/23, 10:5558 PM

From: savefmcp@gmail.com,
To: rlosca@aol.com,
Subject: *** CIVICS CHAMPION DEVELOPMENT-FREE PARK ***
Date: Tue, Jan 3, 2023 10:43 pm

*** CIVICS CHAMPION DEVELOPMENT-FREE PARK ***

LEADERS DECRY STEVE COHEN’S INITIATIVE TO CONSTRUCT CASINO OR
OTHER COMMERCIAL STRUCTURES IN FLUSHING MEADOWS CORONA PARK

Queens, New York – Prominent civic leaders have organized to oppose the
construction of a casino or other commercial structures on the public parkland
surrounding Citi Field stadium. Their announcement of opposition comes
days before Mets owner Steve Cohen will hold a “visioning session” to
advance his desired development scenarios for that parkland. It also comes
one year after numerous Queens civic groups first notified the NYS Gaming
Commission of strong objections to siting a casino in the vicinity of Citi Field
stadium, including on the public parkland.

Although Cohen’s visioning session will be held just as the Gaming Facilities
Location Board is accepting applications for three downstate casino licenses,
and although Cohen reportedly intends to submit an application to construct a
casino on parkland surrounding Citi Field, Cohen’s press release for his
upcoming visioning session conspicuously lacks any specific mention of
building a casino on the parkland – instead vaguely referring to an
“entertainment” venue on “50 acres of vacant asphalt.”

“We believe that Steve Cohen is trying to create a perception of public

support for a vague concept of an ‘entertainment venue’ – but that he
may later misrepresent that as support for a casino to be built on the
parkland,” said Jena Lanzetta, a Bayside community activist. “He’s
soliciting public opinion, without disclosing that his plans impact public
parkland, or that his true ambition is a casino. We will expose such
deceptions every step of the way.”

The civic leaders are especially outraged by Cohen characterizing the land at
issue not as public parkland, but merely as “50 acres of vacant asphalt.” The
50 acres in question – the former site of Shea Stadium – are not only leased
for parking operations at Citi Field, but also host numerous events, including
carnivals and fairs, para-athletic sports matches and a variety of other public
uses. (see photo above)

“The land surrounding Citi Field is public parkland, part of Flushing

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*** CIVICS CHAMPION DEVELOPMENT-FREE PARK *** 1/3/23, 10:5558 PM

Meadows-Corona Park,” said Richard Hellenbrecht, a founder and officer

of Flushing Meadows-Corona Park Conservancy. “Yes, it’s paved over
and sometimes used as parking spaces for events at Citi Field. But the
fact that it’s paved makes it perfectly suitable for the numerous concerts,
circuses, festivals, marathons, and other popular public events that are
held year-round on that very parkland. For Cohen to imply that ‘vacant
asphalt’ is all it is, or that it is un-used as parkland, is deceptive and
misleading – and plain wrong.”

A previous attempt by Queens Development Group to construct a 1.4 million

square foot commercial shopping mall on the same parkland where Steve
Cohen wants to build a casino was disallowed by a 2017 Court of Appeals
decision. That court upheld a unanimous decision of the Appellate Division,
that the parkland at issue could not be constructed upon for non-park use,
because the legislature never explicitly authorized it. Included among the civic
groups and individuals who presently oppose commercialization of the
parkland are many who were plaintiffs or organizers of the prior lawsuit,
including the Queens Civic Congress, urban planner Paul Graziano,
Whitestone civic leader Alfredo Centola, and community activists Christina
Wilkinson of Maspeth and Robert LoScalzo of Whitestone.

Queens Civic Congress President Warren Schreiber, said: “Our message

to state legislators is: Our parkland is irreplaceable. It is not for sale.
Contrary to what would-be casino owners may say, public parkland is not
‘developable property,’ and it must never be viewed as such. Why is
Flushing Meadows-Corona Park – which this planned ‘entertainment
center’ and casino has been proposed in – over decades consistently
targeted by commercial schemes, when other parks throughout the city
are not? Can you imagine a Manhattan developer holding a ‘visioning
session’ to consider repurposing the portion of Central Park between
59th and 61st Streets? If it’s outrageous to do that in Manhattan, then it’s
just as outrageous to do it in Queens.”

The civic leaders are not only concerned that Cohen’s plans will take away
precious parkland. They also believe that a major year-round attraction built on
land surrounding Citi Field will exacerbate traffic on major roadways that
commuters already find intolerable; and that if a casino is built, its negative
impacts include demonstrated social ills that will spill into surrounding
communities and populations.

Willets Point, located east of Citi Field, is already approved to be developed –

all 62 acres of it. The traffic impacts of that project alone will worsen conditions
on most of the popular roadways in the vicinity of Citi Field – so much so, that
one professional engineer testified to the City Planning Commission that ‘I
have never seen this level of unmitigated impact, in the 40 years I’ve been

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*** CIVICS CHAMPION DEVELOPMENT-FREE PARK *** 1/3/23, 10:5558 PM

practicing. This is an unprecedented overload of the local roadway system.’

Any additional year-round attraction constructed on land west of Citi Field will
generate even more traffic – further congesting roadways such as the Van
Wyck Expressway and the Whitestone Expressway.

Tony Nunziato, President of Juniper Park Civic Association,

said: “Touting the economic benefit of a casino is like putting the
proverbial ‘lipstick on a pig.’ In fact, casinos extract wealth from
communities, and typically weaken nearby businesses. Casinos depend
on problem gamblers for their revenue base and living close to a casino
increases the chances of becoming a problem gambler.”

That affects families and communities, as well as individuals. Casinos lead to

social ills including increased substance abuse, violent crime, auto theft and
larceny, and bankruptcy. The latter three all increased by 10 percent in
communities that allowed gambling, and 8 percent of crime in counties with
casinos was attributable to their presence. The New York Times published an
investigative report on December 26, 2022, plainly headlined, ‘Casinos Target
a Vulnerable Clientele: Older Asian Gamblers.’ A Citi Field-area casino, then,
will ‘target’ the ‘vulnerable’ Flushing population of ‘older Asian gamblers.’”

Paul Graziano, an urban planner who was also a plaintiff in the 2014
lawsuit that enjoined construction on the parkland, said: “From a
planning perspective, the development of a casino on public parkland is
just plain wrong. Back in the 1980s, former Borough President Donald
Manes supported the construction of a Formula One Grand Prix raceway
around Meadow Lake, with the intention of turning Flushing Meadows-
Corona Park into the ‘Meadowlands’ of New York City. As a parks
advocate stated at the time: ‘This is not just a racetrack in the park. Once
you’ve said yes to this, how do you stop the next guy? How do you stop
a race in Central Park?’ Four decades later, we now face yet another
attempt to take away our parkland for a private entity’s monetary gain.
The continued attempts to monetize, privatize and destroy this particular
park must stop.”

The civic organizations and leaders that have organized to oppose

commercialization of the parkland or construction of a casino anywhere in the
Citi Field vicinity include:

Queens Civic Congress, which represents the interests of 60+ civic

groups throughout Queens

Individual civic organizations including:

A Better College Point Civic Association

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*** CIVICS CHAMPION DEVELOPMENT-FREE PARK *** 1/3/23, 10:5558 PM

Auburndale Improvement Association

Bayside Hills Civic Association
Bay Terrace Community Alliance
Bellerose Commonwealth Civic Association
Douglaston Civic Association
Flushing Meadows-Corona Park Conservancy
Holly Civic Association
Juniper Park Civic Association
Kissena Corridor Park Civic
We Love Whitestone

And area residents and experts.

The civic organizations and leaders oppose construction of a casino anywhere

in the Citi Field vicinity, whether on the parkland located west of Citi Field, or
on Willets Point land located east of Citi Field (as the negative impacts upon
key roadways and community populations would be the same, irrespective of
which property is used).

For additional information about negative impacts of casinos, see:

“Studies: Casinos bring jobs, but also crime, bankruptcy, and even suicide:”
https://www.washingtonpost.com/news/wonk/wp/2012/10/30/studies-casinos-
bring-jobs-but-also-crime-bankruptcy-and-even-suicide/

“Why Casinos Matter: Thirty-One Evidence-Based Propositions from the

Health and Social Sciences”:
http://instituteforamericanvalues.org/catalog/pdfs/why-casinos-matter.pdf

“Casinos Target a Vulnerable Clientele: Older Asian Gamblers:”

https://www.nytimes.com/2022/12/26/nyregion/nyc-casino-asian-immigrant-
gamblers.html

“Simple but Local, Queens Slots Are Hurting Gambling Meccas” (“… Resorts
World Casino New York City generated nearly $630 million in revenue over the
last 12 months from electronic slot machines …”)
https://www.nytimes.com/2012/10/24/nyregion/aqueduct-casinos-success-
may-spur-industry-expansion-in-new-york.html

​ ​ ​

Save FMCP | savefmcp@gmail.com, Flushing, NY 11354

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 Attachment D

Examples of popular events that have been held

on the public parkland surrounding Citi Field stadium.
 Attachment E

Examples of typical vehicular traffic on the Whitestone Expressway

in the vicinity of Citi Field stadium.