Make sure you have your say!

Deadline for DEIS comments is 5 p.m., Friday, July 14, 2006

The Draft Environmental Impact Statement (DEIS) is a critical part of the Department of the Interior's process of deciding whether the proposed Cowlitz casino-resort will land in rural Clark County. This public comment period, which ends July 14, is an opportunity for those who would be most affected by this facility to speak out.

A number of analysts and researchers have declared that this DEIS was poorly done -- minimizing many detrimental impacts a casino of this size would have on our area and neglecting to discuss others.

We are including eight subject areas that you might consider addressing in comments regarding the DEIS. Feel free to use them in full or in part. Or, you might want to look at the DEIS document yourself and research information related to your specific concerns.

Whether you do your own research or send in a paragraph from ours, please take at least a few minutes to offer your input.

1. I-5 Bridge traffic would become a nightmare. Regardless of early reports that the DEIS seriously underestimates traffic impacts on the region generally, consider the effects casino traffic would have on the I-5 bridge alone. The bridge is already at near capacity several times each day with stop-and- go traffic on the rise. The average weekday traffic count in July 2005 was 137,000 vehicles. According to the Cowlitz DEIS, the presence of a casino at the La Center/I-5 junction would add to the transportation network:

• An additional 13,616 weekday trips
• An additional 17,820 Saturday trips

And how does the DEIS address this major traffic snarl? It makes no recommendation. Nor does it attempt to address the financial impacts of delays, or impacts on secondary road systems, including maintenance. With or without the casino, an improved Columbia crossing is at least 10 years away.

2. Casino pay would be below the county average. The Cowlitz DEIS reports the casino-resort expects to hire approximately 3,151 employees, about as many as work for Clark County’s largest employer, the Southwest Washington Medical Center. At an average wage of $28,000, the pay is a full $5,000 less than the Clark County average.

The DEIS goes on to say that the wage midpoint of the lowest paid 630 employees would be $17,090. A three-member household qualifies for food stamps at a household income of $20,920. A two-member household qualifies for food stamps at an income of $16,660. Clearly, many families with a sole wage- earner working at the casino would need assistance.

Reading the Socioeconomics Conditions of the DEIS (Sec. 4.7) can be tricky since it turns to "household" income, which includes 1.64 wage earners per household. According to this section, "estimated median household income for all jobs under Alternative A [the project at the La Center interchange] is $39,500." The median income of the casino jobs would be $24,085 ($39,500 divided by 1.64), with half of employees earning salaries of less than that.

Low-wage jobs mean that low-rent housing would be in demand. In April, the median home sale price in Clark County was nearly $255,000, a price most casino-resort workers could not afford. The DEIS indicates that rental vacancy rates are extremely low in Clark and Cowlitz counties. Where would these workers and their families live?

3. Can employee demand be met? The casino-resort could be hard-pressed to find enough qualified, willing workers locally. Clark County employs about 12,000 people in "leisure and hospitality." Workers such as gaming dealers, housekeepers, food servers and cooks are already classified as "in demand" in Southwest Washington. Local employment is currently at a record high. Clark County employers added an estimated 5,400 jobs in 2005, and by October, the county and metro-wide jobless rates had fallen to 5.3%. This means local employers are likely to lose some of their better employees while additional workers would probably be imported from other countries if the management team of David Barnett and the Mohegan Tribe were to follow the model established by the Mohegan Sun in Connecticut. This employment scheme has resulted in a workforce that substantially impacts Connecticut’s housing markets, school systems, and transportation and social service agencies.

4. DEIS socioeconomic section is charged with arriving at a "predetermined conclusion." As a part of its analysis of the socioeconomic section of the DEIS, casino consultant ECONorthwest notes, "The authors seem to have constructed their analyses to ensure they would arrive at a predetermined conclusion, which shows lesser impacts than an objective analysis would otherwise forecast." Their report notes a number of what they call "data deficiencies," apparently due to the Cowlitz tribe’s failure to provide appropriate data for a "proper economic analysis," which compromised the integrity of the preparer’s forecasts. The ECONorthwest review addresses four areas where these "data deficiencies" have a negative impact:

1. Understating job effects
2. Understating population impacts
3. Miscalculating retail sales
4. Understating housing effects

ECONorthwest reaches the conclusion that in order to reduce community concerns, every effort has been made to heighten fiscal benefits and reduce negative social impacts in the socioeconomic section of the DEIS.

5. An inadequate number of alternatives. The Draft Environmental Impact Statement (DEIS) was tilted from the beginning to favor the site at the La Center interchange by providing only one additional site for consideration: the Ridgefield interchange. In fact, the document fails to consider a range of alternatives that is adequate to satisfy the National Environmental Policy Act (NEPA). NEPA describes the consideration of alternatives as "the heart of the environmental impact statement" and requires the EIS process to consider multiple options. Case law has demonstrated that "(t)he existence of a viable but unexamined alternative renders an environmental impact statement inadequate" (Citizens for a Better Henderson v. Hodel, 9th Circuit).

The EIS alternatives under consideration for the Cowlitz project are limited to: 1) a large-scale casino- resort located at the La Center interchange, 2) a smaller casino-resort at the La Center interchange, 3) a non-gaming commercial development at the La Center interchange, 4) a large-scale casino-resort located 2 miles to the south at the Ridgefield interchange, even closer to the Portland gaming market, and 5) no action. (The Ridgefield site is across the street from a new Catholic High School that is under construction.)

It appears that Seattle developer and Cowlitz Tribe member David Barnett's ownership interest in the La Center site has affected the consideration of alternatives in the DEIS.

6. An unexamined and viable alternative exists. In March 2006, ECONorthwest, a consultant group whose expertise is casino economics, prepared an analysis of a site near Vader, Washington, just off of I-5 at exit 60 in Lewis County, near the Cowlitz Indians' aboriginal home. The report, which ECONorthwest says would be applicable to other parcels of land in the same general area, would generate earnings well above what are necessary to compensate the Cowlitz Indian Tribe for needs unmet by federal sources. According to the ECONorthwest analysis, by the year 2013, the year after construction loans are paid off, the Cowlitz Tribe would receive between $32.8 and $34.8 million more from the Vader casino than they would need to satisfy the tribe's needs.

7. The DEIS purpose and need is violated. The Purpose and Need section of the DEIS and Alternative A, the Preferred Casino-Resort Project at the La Center junction, are at odds. The Purpose and Need section speaks of facilitating "the establishment of a land base for the Tribe" and generating revenue to support "a variety of fundamental Tribal governmental, administrative, operational, social, and educational programs to benefit Tribal members, including building of governmental offices, a cultural center and Tribal elder housing."

Yet, according to the 2000 Census, most tribal members live nowhere near the La Center junction where these services are to be established. In fact, fewer than 4% of Tribal members (50-74 persons) in Washington lived in Clark County at the time of the census. Most lived in Pierce, Thurston, Cowlitz, King and Lewis Counties, many miles to the north. This proposed reservation and casino is not being sought at La Center to restore lands and services to tribal members, but because of its proximity to potential gamblers in metropolitan Portland/Vancouver. This is an egregious example of "reservation shopping."

8. Is there really any need? Figures from the 2000 census throw into question the Purpose and Need section regarding need for the casino "to improve the long term economic vitality ... of the tribe and its members through the creation of a stable, sustainable source of employment and revenue." According to the census, most tribal members are doing quite well -- at least they were at the time the census was taken in 1999.

The census showed that the Cowlitz Indian households had a median income of $43,654. That was about 4% higher than the median income of all U.S. households, and although it was about 5% lower than Washington households, it was a whopping 35.5% higher than other American Indian households. Only 4.2% of Cowlitz families were below the federal poverty level, far better than the national level in 2000. Only 3.8% of Cowlitz Indians were unemployed when the Census was taken, well below the 5.8% rate across the country and even farther below the 6.2% unemployment rate at that time in Washington State.

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Citizens Against Reservation Shopping