Environmental Comments on Casinos in Massachusetts

Mass Audubon does not have a position on the moral, social or cultural implications of gaming or gambling, but we do have concerns and suggestions regarding development of large-scale casino complexes.

As the Massachusetts Gaming Commission initiates its oversight of the gaming industry in the Commonwealth, Mass Audubon has encouraged them to consider the environmental impacts of such development and to require the employment of sustainable development and energy conservation and efficiency techniques. Casino developments are large projects that will have significant impacts on our environment.

In the gaming law passed during the 2011-2012 legislative session, Bay State lawmakers endowed the Gaming Commission with broad powers to vet casino proposals, select up to three winning bids, and award licenses. The Commission will oversee building and development, police long-term obedience to gambling laws, and ensure compliance with public health and safety rules. The environment should not be an afterthought in this consideration. 

To win in this high-stakes game, bidders must prove how they will meet a variety of mandatory and optional qualifying criteria. Among them is the option to build green. It is Mass Audubon’s position that this should not be an option.

Massachusetts has committed via the Global Warming Solutions Act of 2008 to address climate change through mandated greenhouse gas emission reductions. We encourage the Commission to keep casino development in synch with the Commonwealth’s climate change goals.

Optional Licensing Criteria

Optional licensing criteria, which Mass Audubon recommends be requirements for the awarding of casino licenses, are as follows:

Environmental impact studies

These should be thoroughly prepared under the existing Massachusetts Environmental Policy Act to ensure completeness, transparency, and public review.

Sustainable development principles

Licenses should advance the already well-established smart-growth policies of the state’s energy and environment; housing and economic development; and transportation agencies.

Water Conservation

Projects should minimize water use through conservation and efficiency, including capture and re-use of stormwater for landscape irrigation.

Leadership in Energy and Environmental Design (LEED) certification

Permits should depend on this nationally accepted benchmark for the design, construction, and operation of high-performance energy-efficient buildings. Casinos are by their nature major energy consumers, so LEED certification is a must.  Stretch energy code– This state building code allows adopting municipalities to require energy conservation and efficiency measures in new residential and commercial buildings, additions, and renovations.

10 percent renewable electricity

Licenses should demand the use of wind, solar, and/or geothermal power to supply most of a casino palaces’ energy.

Monitor energy consumption

All building approvals should mandate continued improvements to energy conservation and efficiency.

Again, these criteria should not be optional, they should be a requirement.

In addition there should be the following:

Carbon constraints

Licenses should cap the amount of carbon emitted from casino development and operation, including from cars, trucks, buses, and construction vehicles.


Licenses should limit the amount of wastewater casinos will send to municipal or regional systems.


Casinos should minimize impervious surfaces and provide for the cleaning and infiltration of runoff through plants and soils using Low Impact Development techniques.  Stormwater should be used as a resource for landscape irrigation.

Solid Waste

Licenses should establish standards for waste reduction, minimization, and recycling.


Casinos should provide public transportation, bus, and regional ride-share opportunities with a cars-per-day quota to reduce traffic congestion and carbon emissions.


Development plans should demonstrate how casino development will avoid, minimize, and mitigate impacts to wildlife and its habitat.  Structures should be designed to meet the new LEED Pilot Credit for Bird Collision Deterrence (PC55). Bird collisions with buildings are a significant factor in bird mortality, and the design of facades and lighting can significantly affect this risk.

The gaming law requires the establishment of a Community Mitigation Fund. This fund should be equitably distributed to assist host and surrounding communities in offsetting costs related to casino construction and operation. On- and off-site development impacts will extend throughout a casino’s region. A plan must show what those impacts will be and how they will be addressed.

The message to casino developers should be that if they want to make green, they need to go green, as casino development should not come at the expense of the nature of Massachusetts.