LP-21-00002 Suncadia Ph 3 Div 17 BOCC Staff Report

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6 were not a party to and were not consulted with regarding the Suncadia MPR Conditions of Approval, despite the project area being squarely in the traditional territory of the Wenatchi Tribe. Our recommendations and concerns are not bound by an agreement we were not included in drafting. -We recommend a full cultural resource survey, inclusive of subsurface testing, be conducted of the entire project area, prior to any permitting or Determination of Significance. The CCT should be consulted with on the results of this survey. This survey and subsequent reporting should meet DAHP’s Standards for Cultural Resource Reporting.” Colville Tribe recommends consultation between CDS, the CCT, DAHP, and other affected Tribes on revisions to the Suncadia MPR Conditions of Approval. Staff Response: The applicant provided a response to the comments submitted by the Colville Confederated Tribes, included as Index #30. The applicant stated that they will comply with the conditions set forth in the Development Agreement in Exhibit F conditions C 21-23. Cultural resource issues are addressed in the conditions C 21-23 of Exhibit F to the Development Agreement. Suncadia has retained Central Washington Anthropological Survey (CWAS) to perform archaeological subsurface testing within the 150-foot buffer of the identified site and there are no plans to develop within the defined border of the site. Mitigation measures listed within these conditions shall be applied. The applicant will need to adhere to all applicable regulations as outlined in the Development Agreement. Department of Archaeology & Historic Preservation (DHAP) DHAP provided the following comments: • DAHP agrees with all comments provided in the 26 August 2021 letter from Aren Orsen, Archaeologist II with the CCT History/Archaeology Program. • The boundary testing of site 45KT1363 by CWU, while appreciated, is not adequate for the scale of the project. An archaeological survey with subsurface testing across the entire project area is highly advised. A report meeting DAHP’s Standards for Cultural Resource Reporting should be produced to accompany the survey. • If any work within the boundary of 45KT1363 is proposed, a site alteration permit from DAHP will be required. Please contact Lance Wollwage, Assistant State Archaeologist, with any questions about the permitting process. • We recommend that any historic buildings or structures (45 years in age or older) located within the project area are evaluated for eligibility for listing in the National Register of Historic Places on Historic Property Inventory (HPI) forms. We highly encourage the SEPA lead agency to ensure that these evaluations are written by a cultural resource professional meeting the SOI Professional Qualification Standards in Architectural History. Staff Response: The applicant provided a response to the comments submitted by DAHP, included as Index #30. The applicant stated that they will comply with the conditions set forth in the Development Agreement in Exhibit F conditions C 21-23. Cultural resource issues are addressed in the conditions C 21-23 of Exhibit F to the Development Agreement. Suncadia has retained Central Washington Anthropological Survey (CWAS) to perform archaeological subsurface testing within the 150-foot buffer of the identified site and there are no plans to develop within the defined border of the site. Mitigation measures listed within these conditions shall be applied. The applicant will need to adhere to all applicable regulations as outlined in the Development Agreement. Washington State Department of Ecology (DOE) DOE provided the following comments: