CITY OF SAN PABLO
City Council
1000 Gateway Avenue ● San Pablo, CA 94806
Main: 510-215-3000 ● Fax: 510-215-3011
www.SanPabloCA.gov
July 24, 2024
PERSONAL COURIER AND US REGULAR MAIL
The Honorable Adam Schiff
U.S. House of Representatives
2309 Rayburn House Office Building
Washington, DC 2051
RE: CONCERNS OVER THE PROPOSED SCOTTS VALLEY BAND OF POMO INDIANS
MEGA CASINO PROJECT IN VALLEJO, CA
Dear US Congressional Representative Schiff:
The City of San Pablo wishes to bring to your attention our grave concerns regarding the recent proposed Scotts Valley Band of Pomo Indians Mega Casino and Tribal Housing Project, to be located in County of Solano, in the City of Vallejo, CA. This project involves over 2,000,000 square feet of building, including casino gaming, multiple restaurants, and over 4,000 parking spaces contained in an eight-story building situated on an undeveloped hillside that is largely zoned just for open space.
Recently, the US Department of Interior / Bureau of Indian Affairs (BIA) issued an Environmental Assessment (EA) on July 8, 2024 for this proposed mega casino project, with a 30- day public comment period which initially expired on August 7, 2024, and recently extended to August 22, 2024 by BIA officials. Unfortunately, the City of San Pablo which is directly impacted by this proposed project had limited time during which to provide comments.
In addition, a number of other important stakeholders , Trib es and local agencies who are directly impacted by this proposed project were not notified directly by BIA officials.
On July 22, 2024, on behalf of the San Pablo City Council, the City provided a 5-page response to BIA o fficials outlining the inadequacy of the EA document and requesting a full, comprehensive Environmental Impact Statement (EIA) under NEPA . City of San Pablo officials strongly urged BIA officials to require the preparation of an appropriate EIS focused on addressi ng the potentially significant impacts of the proposed project, including socio- economic conditions and environmental justice, land use, geological stability and wildfire hazards, public services and utilities, transportation and circulation, air quality, biological resources, and cultural resources (See Attachment).
Of upmost importance to San Pablo is the socio -economic and environmental justice issues affecting the City which serves as the host community for the San Pablo Lytton Casino, owned and operated by the Lytton Rancheria Band of Pomo Indians since 1999. The City and Lytton Tribe have maintained a 25- year economic partnership t hrough a Municipal Services Agreement (MSA) . Lytton Casino revenues provide a much appreciated and relied upon source of funds that comprise nearly 65% of the City’ annual general fund budget each year.
Casino revenues fund critical municipal services through the MSA agreement to the San Pablo community (pop. 32,000), including but not limited to, the following: police and fire protection, The Honorable Adam Schiff
United States Congress , D-30th District
Re: Scotts Valley Band of Pomo Indians Mega Casino and Tribal Housing Project in Vallejo, CA
emergency management services, building health and safety, and youth and senior services, etc., Additional critical funds are provided through agreements with Contra Costa County which fund County-provided fire protection and EMS services, County Library and County Animal Control Services via the City’s General Fund Operating Budget.
Additionally, San Pablo is one of the lowest-income communities in the Bay Area and includes several tracts which are categorized as Disadvantaged Comm unities, according to U.S.
Census. These are areas throughout California which suffer immensely from a combination of economic, health, and environmental burdens. By way of contrast, San Pablo’s median household income is significantly less (16%) than that of the City of Vallejo, CA.
Within its Economic Analysis, the EA for the project projects a reduction of over ( -20%) in annual gaming revenues for the San Pablo Lytton Casino due to the relatively close proximity to the proposed project, which would be just 16 miles north along Interstate 80. Because the MSA with San Pablo is based on a percentage of the C asino’s revenue, this will result in a direct commensurate negative impact in benefits that accrue to the City of San Pablo, and its ability to serve its local residents. This impact must be considered a significant socio- economic and environmental justice impact of the proposed project, and is obviously of tremendous concern to the City of San Pablo officials, and its residents. The EA document fails to include any analysis of the off -site environmental justice impacts on the City of San Pablo, from which the project will syphon a considerable portion of Casino revenue which would have a corresponding economic and negative impact to the City of San Pablo, and its local program and service delivery. Based on the projected (- 20%) reduction in annual gaming revenues to Lytton Casino, there would be a potential $8-$10M estimated annual reduction in critical local funding to the City of San Pablo as a result of this mega casino project.
We urge your immediate attention on how these applications are being processed by the US Department of Interior and BIA officials, and the lack of meaningful engagement with impacted Tribes and other interested stakeholders. Thereby, denying an opportunity for meaningfully engagement and substantial environmental review needed under the NEPA process, and leaving lasting detrimental impacts to nearby local communities, and other affected Tribes in the immediate vicinity of this proposed project.
Please feel free to contact San Pablo City Manager Matt Rodriguez directly at (510) 215-3016, or via email: [email protected]
to expand on these matters as expressed by the City of
San Pablo.
Thank you for the opportunity to articulate our formal concerns over this matter.
Sincerely,
PATRICIA PONCE, MAYOR
CITY OF SAN PABLO
Attachment: Letter from San Pablo to BIA Officials dated 07/22/24
cc: Honorable Tribal Chairperson Andrew Mejia and Lytton Rancheria Band of Pomo Indians San Pablo City Council
Matt Rodriguez, City Manager
The Honorable Adam Schiff
United States Congress , D-30th District
Re: Scotts Valley Band of Pomo Indians Mega Casino and Tribal Housing Project in Vallejo, CA
Brian Hickey, City Attorney
Elizabeth Tyler, Community Development Director