Environmental Assessment

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

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.

Deceptive Rendering

The renderings of the proposed casino included in the Environmental Assessment are deceptive, showing a much smaller and less intrusive building than what would be built on the site. In reality, the mega-casino would dominate the hillside, requiring a massive amount of cut and fill, intersecting with existing powerlines on the site, and creating a massive amount of traffic on I-80 and surrounding roadways. This accurate representation of the proposed casino shows just how intrusive the structure would be and highlights some of the engineering and construction challenges.

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 homesHowever, 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

Environmental Assessment Letters
and Comments

08/22/2024

Yocha Dehe Environmental Assessment Full Comment

08/22/2024

Graton Rancheria Comment Letter

08/22/2024

Tuleyome Comment Letter

08/22/2024

California Native Plant Society Comment Letter

08/21/2024

California Air Resources Board Representative Comment Letter

08/21/2024

Solano County Comment Letter

08/20/2024

United Auburn Comment Letter

08/15/2024

Solano Land Trust Opposition Letter

07/23/2024

Kletsel Dehe Comment Letter

07/23/2024

Cachil Dehe Comment Extension Request

07/23/2024

Yolo County Comment Extension Request

07/16/2024

Kletsel Dehe Wintun Nation Comment Extension Request

07/16/2024

County of Solano Comment Extension Request

07/11/2024

Yocha Dehe Comment Extension Request

07/9/2024

Yocha Dehe Letter on Exclusion from EA Process