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Page 2 of 2 <br /> <br />-In short, the entirety of the MPR Conditions of Approval rely on a twenty-two year old cultural <br />resource survey that explicitly details its own inadequacy, does not meet current DAHP <br />standards, and was not conducted with the proposed project in mind. We do not consider this to <br />be a solid basis for permitting Suncadia projects. <br /> <br />-The CCT are not mentioned in any of these documents as an affected tribe, despite the project <br />area being squarely in the traditional territory of the Wenatchi Tribe. To my knowledge, the CCT <br />were not a party to and were not consulted with regarding the Suncadia MPR Conditions of <br />Approval, despite the project area being squarely in the traditional territory of the Wenatchi <br />Tribe. Our recommendations and concerns are not bound by an agreement we were not included <br />in drafting. <br /> <br />-We recommend a full cultural resource survey, inclusive of subsurface testing, be <br />conducted of the entire project area, prior to any permitting or Determination of <br />Significance. The CCT should be consulted with on the results of this survey. This survey and <br />subsequent reporting should meet DAHP’s Standards for Cultural Resource Reporting. <br /> <br />-The permitting process for this project seems to follow the trajectory of other Suncadia <br />Divisions (i.e. Phase 2 Division 1 (LP-20-0003). In effect, this is resulting in Suncadia projects <br />being allowed to move forward without cultural resource investigations that would otherwise be <br />considered standard practice. The CCT’s recommendations and concerns set forth regarding this <br />project are likely to be repeated for any subsequent Divisions if this does not change. We <br />recommend consultation between your office, the CCT, DAHP, and other affected Tribes occur <br />to affect revisions to the Suncadia MPR Conditions of Approval. <br /> <br />Thank you for consulting with the Confederated Tribes of the Colville Reservation. Please note <br />that these comments are based on information available to us at the time of the project review. <br />We reserve the right to revise our comments as information becomes available. If you have any <br />questions or concerns, please contact me at (509)-978-9064. If you would like to speak with the <br />THPO, please contact Guy Moura at (509)-634-2695 or guy.moura@colvilletribes.com. <br /> <br /> <br />Sincerely, <br /> <br />Aren Orsen <br />CCT History/Archaeology <br />Archaeologist II <br />Aren.Orsen.HSY@colvilletribes.com <br />509-978-9064 <br /> <br /> <br />Index #20