The Capay Valley Coalition, a community organization committed to agricultural viability and safety in western Yolo County, highlights here numerous unexamined issues not addressed by the Tribal Environmental Impact Report on the proposed expansion of Cache Creek Casino, and proposes solutions:

The traffic analysis in the TEIR is flawed in claiming no increase in traffic volume. The project is proposing to add 2300 event center visitors, 20 percent additional gaming space, 37 percent additional dining space and additional parking for 900 more cars. If there is need for additional parking it stands to reason the developers expect there will be additional traffic volume.

The TEIR Traffic Impact Study analysis relies on the Caltrans SR-16 Safety Improvement Project for several key road improvements. But the SIP is the subject of a lawsuit objecting to its design and scale, and seeking analysis of a scaled down project. With significant delays in the implementation of the SIP, the TEIR offers no solutions for the impact of the traffic increases that the expansion will cause.

The TEIR traffic analysis must evaluate the impacts of peak event traffic on the highway 16 corridor from I-505 to the Casino. The TEIR analysis lacks and requires the inclusion of comprehensive planning for the impacts of increased traffic upon the communities of Esparto and Capay, and upon the farm businesses along the highway. The TEIR must evaluate "fairshare" of impacts of increased traffic and mitigate accordingly. Finally the TEIR must look at context sensitive Highway 16 safety improvements that could be implemented immediately while the SIP is being litigated.

It was agreed during the last expansion that a Park & Ride was to be built near Hwy. 16 and Hwy. 505 to provide bus service to the Casino and that each Casino employee was to be required to use it. This should be implemented before any new expansion is contemplated.

Water transfers out of Yolo County without a permit are illegal. The Casino depends on transferring water from lands within Yolo County to operations outside of Yolo County (on tribal land) for its water needs. Under consideration is the option to discharge treated waste water into Yolo County's Cache Creek.

The conclusion that there will be no significant impact on the aquifer and neighboring wells is not realistic. The option to discharge treated wastewater to Cache Creek does not honestly and adequately assess impacts on the affected parties: Downstream users, from Brooks to Woodland and Davis, including natural communities as well as human.

A permitting process should be in place for any water transfer to tribal lands that is monitored by the county and discussed in an open process at community meetings sponsored by the Capay Valley General Plan committee.

A third-party neutral analysis of water use and impact and identification of real mitigation measures for affected neighbors is needed. A thorough analysis is needed of the effects of waste water discharge on downstream users.

Each "expansion" allows the opportunity to analyze impacts only on a piece meal basis. A cumulative analysis has never been done to provide a true picture of the overall significant impacts the Casino has had and will continue to have on the community, the county and the state. For example, the State of California is committed to decreasing carbon emissions, while the increased traffic volume of the casino expansion will only increase emissions.

We question the validity of a for-profit entity certifying its own EIR. The community has no recourse should there be off-reservation impacts not covered by the EIR's planned mitigation.

The Tribe can strive to be a good neighbor. As a good neighbor, the casino should accept responsibility for serious impacts on the valley. The Tribe should not claim sovereign immunity from liability for off-reservation impacts. The tribe should convene community meetings that openly work through the cumulative impacts and benefits of any growth of the casino on the communities of the Capay Valley. These discussions should recognize the interdependent relationship of the tribe and community members, and should consider the shared future of those who live, work, and visit the Valley.

The TEIR should evaluate the feasibility of another access. Growth in the casino is the driving force behind the Highway SIP. Any scale increase in the casino should acknowledge the Cumulative impacts of expansion on the Valley communities. All analysis of the traffic impacts and potential solutions should include an analysis of alternate access.