No, doubt that the coin is lustrous. and should be a 65. I figured there was much more flash to the coin than what is pictured in the slab photo. This is where @GDJMSP chimes in with the deterioration on the die face determines the amount of the luster. Later die states do not show the same as an early strike, This is why a lot of us, factor in die state as a determination of grade.
Based on this an a couple of other recent PCGS GTG's on commems, it seems to me they have tightened up their grading on the series. I was at 66 all day on this coin, as it is (IMO) much nicer then my 34-D MS65 (PCGS) with a green bean.
The coin has luster, but I'm reasonably certain the quality of luster was a good bit higher at an earlier point in its life. Look at the remains of black toning at the top of the obv - - just below the corner of the cape - - as well as the top portion of the rev and the rim just at the corner of the wagon's top. The black color of the toning coupled with the pattern of specks scattered here and there indicate to me that coin was heavily and very darkly toned over much of its surface at one point. This look is typical of dipped coins. The toning itself, given how dark it is, probably reduced the quality of luster somewhat. And then dipping it, perhaps for half a second too long in an effort to remove as much of the dark toning as possible, the luster would almost certainly have been reduced a bit more. These coins are well known for having very high quality of luster in some cases. I suspect this was one of them once. But either the heavy black toning, and or the dipping combined with it, have reduced it to what we see now. If pictures of this coin and what it looked like before it was dipped existed, I think most most would find it quite ugly and some think it beyond hope. But as it is, it serves as a good example of what dipping can do for a coin - restore it to a coin its owner is proud to have.