Environmental Assessment
Share
A Woefully 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 failed to disclose, evaluate, mitigate, or consider reasonable alternatives to the project’s significant environmental impacts.
In their haste to justify the project, the document’s preparers glossed over, dismissed, or entirely failed to address obviously significant impacts to cultural resources, protected species, wetlands, water, air quality, traffic, and environmental justice, among others. And, more fundamentally, they ignored clear evidence, in Scotts Valley’s own grading plans, that the project simply cannot be constructed as proposed.
Repeated requests from various interested parties for a clear, transparent process were ignored and then the EA was released quietly over a holiday weekend, without any advance notice to affected tribes, local governments, or other interested parties, ignoring mandatory agency procedures specifying that when BIA determines that Tribal governments could be affected by a proposed action, those Tribal governments must be consulted during the preparation of environmental documents.
By opting for a brief Environmental Assessment, rather than a comprehensive Environmental Impact Statement as clearly called for by the National Environmental Policy Act and BIA’ s own procedures, the Department of the Interior ignored more than two decades of consistent agency precedent for environmental review of Northern California tribal casino projects.
For example, 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 ignores the desecration of a Patwin cultural site.
A Rushed and Secretive Effort to Rubber Stamp the Proposal
Publication of Draft Environmental Assessment
Yocha Dehe Initial Response to Environmental Assessment
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
Environmental Assessment Zoom Meeting
Press Conference & Comment Submission
Environmental Assessment Comment letter
Yocha Dehe submits a detailed set of comments identifying the many and varied flaws with the EA.
Numerous other interested parties also submitted comments, including other tribes, local governments, and environmental groups.
An Inadequate and Misleading Assessment
The Environmental Assessment for the Scotts Valley Project is riddled with inaccuracies and misleading site plans that fail to meet the most basic requirements of federal law.
For exmple, 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.
Hiding the True Scale of Destruction
Environmental Impact
Traffic
Water Resources
Engineering and Safety Concerns
Missing Solano Ranch Project
Air Quality
Grading, Drainage, and Stormwater
Wildfires
Cultural Destruction
Missing Hotel Project
