My name is William F. Keller, and I represent the constituents of the 184^th Legislative District in the Commonwealth of Pennsylvania, Philadelphia County.  I am respectfully submitting this written testimony to the Pennsylvania Gaming Control Board in opposition to a proposal by Philadelphia Entertainment and Development Partners, L.P. (PEDP) (Foxwoods Casino Philadelphia) to build a 16-acre casino and entertainment facility on South Columbus Boulevard, between Tasker and Reed Streets.

According to the proposal by PEDP, the site is “commonly known as Piers 60, 62 and 63 . . . on the South Delaware waterfront bordered by the river, Columbus Avenue, and Tasker Avenue and Reed Street.”  As I understand it, the project is massive in scope.  PEDP “envisions three significant phases” involving construction of a 3,000-slots casino facility, a parking garage for 4,500 vehicles, retail and restaurant space, and something described as an “entertainment venue.”  And this is only Phase I. 

Phase II proposes a $183 million expansion and addition to the existing structure, additional space in the casino to accommodate 2,000 more slot machines, expanded parking for 1,500 more vehicles, more retail and food space, and what is described as the Pier 60 Entertainment District.

Phase III calls for yet another $180 million addition, a 500-room hotel tower, assembly and conference space, and a health spa.  Also under consideration is a possible residential condo tower development by a separate company.

I point out the details of this proposal not as an advertisement for Foxwoods; rather, even to the casual observer it is clearly evident that this project is far too ambitious for its proposed location.  And since that is the case, the results will be horrendous and run counter to the very purpose of the gaming legislation signed by Gov. Rendell in 2004.

It took a strong bipartisan effort to craft the historic pieces of legislation known as House Bill 2330 and Senate Bill 100. At the heart of House Bill 2330 is property and wage tax relief, something homeowners throughout the Commonwealth are desperately seeking.  However, this can only be accomplished if, as Gov. Rendell himself said during the signing ceremony for these bills, “urban slots venues . . . generate significant resources for the Commonwealth.”

In other words, the two slots parlors ultimately chosen for Philadelphia must represent the very best investment on behalf of the citizens of Pennsylvania.  If not, we have done them a great disservice.  If these proposed casinos do not maximize the revenue potential as dictated by law, then we have skirted the spirit of the legislation.  Moreover, the onus is on you, too, as members of the Pennsylvania Gaming Control Board to fulfill your duties and obligations to the citizens of the Commonwealth.

Why does Foxwoods present a higher risk among the five proposals before you?  Because, in short, as a resident of the neighboring Pennsport community testified, the proposed casino development guarantees a “gridlock tourist-trap experience for visitors.”

Since there are more homes within one mile of the proposed Foxwoods site than any of the other four possible locations, and since the community there is currently besieged by most of the burdens of urban life: a high concentration of big-box retailers, adult entertainment facilities, and traffic congestion that at certain times of the day levies a choke-hold on the area, it would be unconscionable to seriously consider this site for such a monstrous development.

The chief development officer for Foxwoods Development Co. publicly admitted the obvious when he was quoted in The Philadelphia Inquirer on April 12, 2006:  “Unless we can find a way to get customers to our site easily, they’re not going to come back, and we are going to be out of business.”  This does not evoke the spirit of optimism and enthusiasm associated with the goal of the gaming legislation: to generate the revenues needed to unburden the taxpayers.

According to research published in The Inquirer, Foxwoods would generate less tax revenue than three out of four other applicants before you.  Strangely enough, the site would be one of the most expensive among the five to develop, as much as $170 million more that one of the proposals.

Moreover, the traffic plan designed by consultants for PEDP calls for construction of new ramps, and relocation of existing ones, for I-95 in South Philadelphia.  Anyone even remotely familiar with such an arduous task knows all too well how long such a project will take to complete.  The approval process alone, involving all three levels of government—city, state and federal—could take years. 

In the meantime, how will the residents there cope with the social costs of the project?

Their quality of life, which is already adversely impacted due to traffic and overdevelopment, will be further taxed.  One of the most densely populated areas in Philadelphia is being asked to shoulder additional burdens.  Not only it is fundamentally unfair, it is simply the wrong thing to do.

And what about the consumer?  Should this development proceed, how often would patrons return to visit after navigating a nightmarish scenario of traffic gridlock?  Suddenly, how attractive will Foxwoods be then?  The adverse impact on business would be severe, and a serious threat to the revenue-generated tax relief we sought to gain.

As one who has spent a lifetime living and working in the neighborhoods that will bear the brunt of this proposed casino development, I urge this board to reject Foxwoods’ proposal.  The location they have chosen simply cannot adequately sustain such a venture, and in the end, the taxpayers will fail to see the fruits of the legislation we worked long and hard to craft in their favor.