Suncadia Ph 2 Div 7 - Master File Indexed

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Page 2 of 3 -We consider the scope, methods, results, and recommendations of the 1998 cultural resources survey to be woefully inadequate as a means of determining the current proposed projects’ impacts on cultural resources. This survey did not include any subsurface testing. The authors noted that “Additional resource areas undoubtedly exist within the MountainStar Resort but, due to poor ground visibility throughout the resort area, have not been identified…” The CCT does not consider such a survey to be adequate for identifying cultural resources for a project with ground disturbing activities, much less as the basis for the Suncadia MPR Conditions of Approval, and subsequent Determinations of Non-Significance. -The SEPA checklist for this project refers to sections C-21 through C-23 of the MPR Conditions of Approval as the methods to be used to assess potential impacts to resources. Section C-23 requires subsurface testing “within identified cultural constraint areas…” only. To the best of my knowledge, these “cultural constraint areas” were identified by the 1998 effort that did not include any subsurface testing and explicitly described the likelihood of additional unidentified resources. We do not belief that sufficient information currently exists to adequately answer questions B.13.(a-d) of the SEPA checklist. -In short, the entirety of the MPR Conditions of Approval rely on a twenty-two year old cultural resource survey that explicitly details its own inadequacy, does not meet current DAHP standards, and was not conducted with the proposed project in mind. We do not consider this to be a solid basis for permitting Suncadia projects. -The CCT are not mentioned in any of these documents as an affected tribe, despite the project area being squarely in the traditional territory of the Wenatchi Tribe. To my knowledge, the CCT 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 proposed plans, timeline, and results of this survey. This survey and subsequent reporting should meet DAHP’s Standards for Cultural Resource Reporting. -The permitting process for this project seems to follow the trajectory of other Suncadia Divisions (i.e. Phase 2 Division 1 LP-20-0003, Phase 3 Division 17 LP-21-00002). In effect, this is resulting in Suncadia projects being allowed to move forward without cultural resource investigations that would otherwise be considered standard practice. The CCT’s recommendations and concerns set forth regarding this project are likely to be repeated for any subsequent Divisions if this does not change. We recommend consultation between your office, the CCT, DAHP, and other affected Tribes occur to affect revisions to the Suncadia MPR Conditions of Approval. Thank you for consulting with the Confederated Tribes of the Colville Reservation. Please note that these comments are based on information available to us at the time of the project review. Index #39