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Page 1 of 3 The Confederated Tribes of the Colville Reservation History/Archaeology Program (509) 634-2693 P.O. Box 150, Nespelem, WA 99155 FAX: (509) 634-2694 February 28, 2022 Kelly Bacon Staff Planner, Kittitas County Community Development Services 411 N. Ruby St. Suite 2 Ellensburg, WA 98926 RE: Suncadia Phase 2 Division 7 LP-22-00001 Dear Kelly Bacon, Thank you for consulting with the Confederated Tribes of the Colville Reservation (CCT). Please be advised that the proposed undertaking lies within the traditional territories of the Wenatchi Tribe, one of twelve constituent tribes of the Confederated Tribes of the Colville Reservation (Colville Confederated Tribes [CCT]), which is governed by the Colville Business Council (CBC). The CBC has delegated to the Tribal Historic Preservation Officer (THPO) the responsibility of representing the CCT with regard to cultural resources management issues throughout the traditional territories of all of the constituent tribes under Resolution 1996-29. This area includes parts of eastern Washington, northeastern Oregon, the Palus (Palouse) territory in Idaho, and south central British Columbia. We do not concur with Section B.13.b of the Attachment to SEPA Environmental Checklist Phase 2 Division 7, which states that archaeological sites KT01354 and KT01357 will not be affected by the proposed development. We do not believe that sufficient information exists to make this determination (see below). Given that no subsurface testing has ever occurred for these sites, their boundaries are not delineated in a way that ensures they will not be impacted by project activities. 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. Given the sensitive nature of the precontact sites in the project area, this survey should be coordinated closely with the CCT, DAHP, and other affected Tribes. The following comments are the same as those previously provided regarding Phase 3 Division 17 LP-21-0002, and will continue to be our comments regarding any Suncadia subdivision until meaningful changes are effected regarding the process for protecting cultural resources during the development of Suncadia. Again, we recommend consultation between your office, the CCT, DAHP, and other affected Tribes occur to revise the Suncadia MPR Conditions of Approval. The applicant’s answers to Section B.13(a-d) of the provided SEPA checklist provide references to the original DEIS and FEIS, as well as the Suncadia MPR Conditions of Approval sections C- 21 to C-23. These sections appear to be based on recommendations made during the original cultural resource survey effort for the MountainStar Resort in 1998 (Griffin and Churchill). Index #39