LP-24-00003 Suncadia PH 2 Div 7 - BOCC Packet

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6 Inadvertent Discovery Plan (IDP) in place prior to work. They further stated that there are known cultural resources of precontact and historic significance nearby and that this project is considered to be at a very high risk for inadvertent discovery according to the DAHP predictive model. They also stated that no portion of this area has been previously surveyed. The CTCR further requested a cultural resource survey for the full project in preparation for future residential or other construction, including subsurface testing. They also stated that an IDP is necessary to ensure compliance with all Section 106 and relevant cultural resource laws both at the federal and state level. Staff Response: Applicant provided a response to CTCR comments, stating: “The entire Suncadia resort property has been extensively surveyed for cultural and historic sites during the environmental impact process culminating in the identification of sites as well as adoption of appropriate mitigation measures as set forth in Conditions of Approval C-21 – C-23 of Exhibit F to the Development Agreement with Kittitas County. Suncadia is very cognizant and sensitive to cultural resources and historic properties and always preserves, protects, and follows all applicable rules and regulations as set forth in the Development Agreement.” Staff therefore states that Suncadia has adequately addressed the comments submitted by the CTCR. Department of Archaeology and Historic Preservation DAHP provided the following comments: Our statewide predictive model indicates that there is a high probability of encountering cultural resources within the proposed project area. Further, the scale of the proposed ground disturbing actions would destroy any archaeological resources present. Identification during construction is not a recommended detection method because inadvertent discoveries often result in costly construction delays and damage to the resource. Therefore, we recommend a professional archaeological survey of the project area be conducted and a report be produced prior to ground disturbing activities. This report should meet DAHP’s Standards for Cultural Resource Reporting. We also 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 DAHP comments, stating: “The entire Suncadia resort property has been extensively surveyed for cultural and historic sites during the environmental impact process culminating in the identification of sites as well as adoption of appropriate mitigation measures as set forth in Conditions of Approval C-21 – C-23 of Exhibit F to the Development Agreement with Kittitas County. Suncadia is very cognizant and sensitive to cultural resources and historic properties and always preserves, protects, and follows all applicable rules and regulations as set forth in the Development Agreement.” Staff therefore states that Suncadia has adequately addressed the comments submitted by DAHP. Kittitas County Public Health KCPH provided the following comments: KCPH stated they have no comment for this plat application, so long as everything that was submitted in the application is true. Staff Response: Since KCPH did not provide substantive comments, staff has no further response. Kittitas County Public Works