Environmental Assessment

A Woefully Inadequate Environmental Assessment

The Department of the Interior has released an inadequate and rushed Environmental Assessment

Working in secret, the Department of the Interior has released an inadequate and rushed Environmental Assessment (“EA”) that would rubber stamp the Scotts Valley project with devastating consequences to the local environment. 

The document, prepared by Scotts Valley’s paid contractors and without public notice or input from the City of Vallejo, Solano County, or interested tribal stakeholders – was released by the Department in a holiday weekend news dump.

By pursuing an Environmental Assessment, rather than a comprehensive Environmental Impact Statement, the Department of the Interior is purposely ignoring the devastating consequences this project would have on endangered species, tribal cultural resources, wetlands, and other sensitive resources.

A diverse coalition of tribal governments, including local Patwin tribes, has repeatedly requested that the Department of the Interior establish a fair, transparent, and fact-based review of Scotts Valley’s request for a “restored lands” determination. All requests have been ignored, excluding Patwin tribes from the decision-making process related to their own ancestral lands.

Flawed Process

A Fast-Tracked and Secretive Process

The Department of the Interior has been working secretly to fast-track Scotts Valley’s request for a “restored lands” decision, excluding affected tribes, local governments, and the public at large from the process.

Local Patwin tribes have repeatedly requested that the Bureau of Indian Affairs establish a fair, transparent, and fact-based review process. So have other tribal governments. Ignoring those requests, the Department of the Interior secretively directed the Bureau of Indian Affairs Pacific Regional Office to process Scotts Valley’s application.

Over a holiday weekend, the Department released a woefully inadequate Environmental Assessment, hoping to shortcut environmental review requirements without giving local tribes or the interested public a meaningful opportunity for review. The only public notice being a placed in the print version of the Sunday classifieds of a small local paper.

Cutting Corners

An Inadequate Assessment

An EA is a brief analysis prepared for projects expected to have insignificant environmental impacts. The Scotts Valley project is known to have significant environmental impacts on endangered species, tribal cultural resources, wetlands, traffic, air quality, open space, and more.

A comprehensive Environmental Impact Statement (or “EIS”) is needed to ensure thorough evaluation of environmental issues, effective mitigation of impacts, appropriate consideration of project alternatives, and meaningful opportunities for review and comment by interested parties. Patwin tribal homelands deserve no less. Why is the Department of the Interior cutting corners?

Environmental Impact

The Scotts Valley Project Would Have Devastating Environmental Consequences

Critical Habitat Destruction

The EA admits Scotts Valley’s project would “take” (a euphemism for “kill”) endangered Calippe Silverspot butterflies and destroy more than 100 acres of their last remaining habitat in Solano County. Scotts Valley would also destroy important habitat for seven other protected plant and animal species at the project site.

Cultural Devastation

The project is proposed to be built atop a known Patwin cultural siteScotts Valley would bulldoze the entire site, which would be lost to the Patwin people foreverThe EA does not even propose to allow Patwin cultural monitors to supervise the recovery and treatment of cultural resources that would be disturbed.

Air Quality Impact

The EA blatantly misrepresents the air quality impacts of the Scotts Valley project.  For example, the document assumes just 375 heavy truck trips will be needed for site gradingThe true number of heavy truck trips, according to statewide modelsNearly 17,000 – in just 45 days!  

Diesel Pollutants

Construction of the Scotts Valley project would require hundreds of heavy diesel truck trips through Vallejo each and every dayThe EA contains no analysis whatsoever of the potential impact of introducing significant levels of diesel particulate matter and other hazardous air pollutants into this environmental justice community.

Ignored Requests

Silenced Tribal Voices

A diverse coalition of tribal governments, including local Patwin tribes, has repeatedly requested that the Department of the Interior establish a fair, transparent, and fact-based review of Scotts Valley’s proposed project. Instead, the Department issued the EA over a holiday weekend, without advance notice to any interested tribes. Read the tribal requests in more detail below: