Environmental Assessment
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A Woefully Inadequate Environmental Assessment
The Department of the Interior Has Released a Rushed and Inadequate Environmental Assessment
As part of its apparent plan to rubber stamp the Scotts Valley project, the Department of the Interior released a rushed, inadequate Environmental Assessment (“EA”) that fails to disclose, evaluate, mitigate, or consider reasonable alternatives to the project’s significant environmental impacts.
The document, prepared by Scotts Valley’s paid contractors without prior public notice or input from the City of Vallejo, Solano County, or any interested tribal stakeholders – was released in secret over a holiday weekend.
By preparing a brief Environmental Assessment, rather than a comprehensive Environmental Impact Statement, the Department of the Interior has purposely ignored 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, cutting Patwin tribes out of the decision-making process threatening their own ancestral lands.
Flawed Process
A Rushed and Secretive Effort to Rubber Stamp the Proposal
Publication of Draft Environmental Assessment
The Department issues the draft environmental assessment notice over a holiday weekend without any advanced notice to affected tribes, local governments, or other interested parties.
Yocha Dehe Initial Response to Environmental Assessment
Yocha Dehe expresses “deep concern and disappointment” regarding the Department’s decision to exclude Yocha Dehe from the preparation of the EA, in violation of the agency’s own protocols.
Request for Extension
Yocha Dehe requests a 30-day extension for the comment period to properly review the environmental assessment and provide substantive feedback.
Numerous other interested parties follow with extension requests of their own, including Kletsel Dehe, Solano County, the Lt. Governor, several members of Congress, Cachil Dehe Band of Wintun Indians, and Assembly Majority Leader Cecilia Aguilar-Curry.
Comment Period Extension
The Department of the Interior issues a meager 15-day extension to the comment period, insufficient for the review required.
Environmental Assessment Zoom Meeting
Rather than a formal public hearing, the Department hosts a Zoom meeting on the EA; Tribal leaders and government officials deliver remarks expressing serious concerns about the secretive and flawed EA process and the irreparable harm this project would cause to the environment, their cultural homelands, and tribal sovereignty.
Press Conference & Comment Submission
Tribal leaders and local government officials host a press conference on the day of the EA comment submission deadline urging the Department to reject the Scotts Valley project.
Environmental Assessment Comment letter
Yocha Dehe submits a detailed set of comments identifying the many and varied flaws with the Environmental Assessment.
Numerous other interested parties also submitted comments, including other tribes, local governments, and environmental groups.
Cutting Corners
An Inadequate and Misleading Assessment
The environmental assessment for the Scotts Valley Project includes incomplete, misleading, and completely inaccurate site plans that fail to meet the most basic requirements of federal law.
Specifically, it fails to include any mitigation measures for the destruction of critical habitats for multiple endangered and threatened species; neglects to adequately address air quality concerns; includes a traffic analysis based on fundamentally flawed data, completely misrepresenting the traffic impact that it will cause; fails to provide evidence for its estimation of water usage; neglects to account for the massively significant engineering and construction challenges; and will desecrate a Yocha Dehe cultural site.
Environmental Impact
The EA does not confront the fact that threatened and endangered species and their habitats will be wiped out by the project, failing to provide defined or enforceable mitigation measures to preserve protected species and their habitats.
Air Quality
Construction and operation of the project will introduce a massive new source of air emissions into a community that is already identified by regulators as being particularly vulnerable to air pollution.
Traffic
The EA includes a traffic analysis based on fundamentally flawed data—which, in some cases, is nearly 20 years old. Additionally, it fails to provide any analysis of congestion on nearby freeways and is contradicted by recent studies performed for nearby projects.
Grading, Drainage, and Stormwater
The project would require massive amounts of cut and fill on an extremely sensitive site; yet, rather than a serious, thoughtful analysis, the EA offers “cartoonish plans and vague, unsubstantiated assurances.”
Water Resources
The EA provides no substantial evidence or justification for its estimate of project water demand; proposes to rely on water supply options that are speculative and illusory; fails to address potentially significant water quality issues; and ignores cumulative projects and impacts.
Wildfires
The EA fails to adequately analyze hazardous materials and wildfire hazard issues posed by the Project.
Engineering and Safety Concerns
The proposed plan for the casino, as outlined in the EA, is physically impossible to build in its current form. The plan includes impossibilities such as water drainages flowing uphill, water flowlines crossing roads six feet above the road’s elevation, and high-voltage transmission lines conflicting with the casino site itself.
Cultural Destruction
Approval of the project would allow a Pomo tribe from a very different part of California, without any ancestral connection to this area, to destroy a Patwin cultural site in order to build its own government headquarters and casino.
Missing Solano Ranch Project
The EA fails to account for – or even to mention – the Solano Ranch project, a mixed-use development consisting of 264 multi-family residential units and 32,725 square feet of commercial space, that is proposed to be built on three of the four parcels that would be placed into trust for Scotts Valley.
Missing Hotel Project
The Scotts Valley proposal appears to include plans for a massive hotel and more than 100 homes. However, the EA does not address either possibility, resulting in a significant under-estimate of traffic, emissions, threats to protected species, and wetlands fill.
Ignored Requests
