Cities Index.
Supplemental Agenda Materials

Vallejo City Council
April 14, 2026

Document
Supplemental Agenda Materials
Meeting
April 14, 2026
Body
Vallejo City Council
Pages
20
Original file
9.1 MB
Text extracted from the city's file for reading and search. Open the original on vallejoca.api.civicclerk.com. That file is the official record.

• How much will this cost them?
• Will this require more police presence?
• How about fire services?
• Will this create serious traffic?
• Will this require plugging into our scarce water
sources?
These are not minor details. They are the difference between responsible governance and reckless decision-making. Vallejo deserves answers before public resources are committed.

Scotts Valley has promised jobs and economic opportunity for Vallejo. Instead, its actions reflect a pattern of advancing its own interests while sidelining community voices and public process. Moving forward with a casino, even a "temporary" one, while federal gaming eligibility remains under review demonstrates a troubling disregard for transparency and accountability.

These actions also impact the ancestral homelands of the Patwin people, local Tribes with deep and continuing cultural ties to this land. Proceeding without consultation or respect for those connections perpetuates harm and undermines trust.

Scotts Valley is betting that the community won't push back.

By signing this petition, you are calling for:

NO to a Temporary Casino that will have a permanent impact on the city of Vallejo NO to rushed and secretive actions taken without public review or community consent NO to committing city resources
Vallejo deserves transparency, accountability, and respect. Not decisions made in haste with lasting consequences. Protect Our Community!
Now, government documents show this so-called "preview casino" has moved forward without meaningful public review, leaving the community no opportunity to ask basic and necessary questions, such as:

PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Protect Tribal Homelands · Vallejo, CA

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VALLEJO SIGNATORIES
Vallejo Residents: 305 Signatures_253UniqueSigners
144 7RtaOComments
Signers with Comments
Greg Thompson · Vallejo, CA 94590
[email protected]
"We don’t need any temporary casinos in Vallejo!!!!"
Diana Lanham · Vallejo, CA 94591 — 2 petition submissions [email protected]
"No Casino"
Mishel Adolph · Vallejo, CA 945903SetitiRnsuEPissiRns [email protected]
Susan Oldershaw · Vallejo, CA 94591
[email protected]
"A casino will only have a negative effect for Vallejo residents." Carol Butcher · Vallejo, CA 94589•3SetitiRnsuEPissiRns [email protected]
"No. Temporary trailor is NOT what was said it would be and NOT WANTED" Jenny Smith · Vallejo, CA 94591
[email protected]
"Please say NO to the casino"
Madisen Ellis · Vallejo, CA 94589
[email protected]
"No casinos in Vallejo, period!"
Raquel Arambula · Vallejo, CA 94590
[email protected]
"No casino!!"
"The safety of the community is already stretched. The Scotts Valley Tribe needs to help fund those services that are falling short because of man power and funds to pay for more man power. The community should not have to go without to support a casino. The casino needs to pony up the cash"
"HELL NO to a trailer casino..."
"No trashy trailor casino. If its not goinv to be equivalent to others in bay area then should not EVER be allowed to be here...and a trailer type casino is a far cry from what this was represented to be!!! NO! NO TRAILER CASINO HERE!!!" "No trailer casino! Ugly snd not what we were tokd!"
Pamela Phillips · Vallejo, CA 94589
[email protected]
"We cannot get police to respond when we call 911 now! Don’t stretch the limited resources thinner!! Make getting more police and emergency services a priority. Vallejo will not go and thrive until you do!!!" Judy Heyman · Vallejo, CA 94590
[email protected]
"Our community needs this project to go through proper channels if it happens at all." PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document

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Carlos Solorzano · Vallejo, CA 94589
[email protected]
"We do not need a casino, we need more support for small businesses." Juan Hoyos · Vallejo, CA 94590
[email protected]
"No trailer casino!!..."
bob Woolery · Vallejo, CA 94589
[email protected]
"Water supply and treatment plant (new on site) discharges must be independent of current COV systems. These could be by pipelines to/from Clearlake, or by desalination from White Slough. Public Safety (Police and Fire) must be independently provided from Tribal resources and personnel."
Holly Peters · Vallejo, CA 94590
[email protected]
"Vallejo has more to offer than making it a hotspot and destination for gambling." Allison Medina · Vallejo, CA 94591
[email protected]
"Please I would love to keep the land as is. No casino . Crime and poverty don’t mix well with casinos . Coyote valley by Mendocino national forest is a crime ridden area with drunks and gamblers. We don’t need this in Vallejo" Protect Tribal Homelands · Vallejo, CA
Thomas Talley · Vallejo, CA 94591
[email protected]
"As a Vallejo Resident, a casino is not what we need. The location is horrible and will cause undue traffic in the area. They won't even help the homeless camp outside the gate! Council needs to reject this casino and put some actual effort into city infrastructure, local programs to uplift the deposed and distressed, and rebuild trust with the community." Aubreu Gomez · Vallejo, CA 94591
[email protected]
"To: Vallejo City Council From: >Aubrey@ Dear Vallejo City Council, The Scotts Valley Band of Pomo Indians has announced the opening of a -hour “preview casino” in Vallejo while its larger mega casino project remains under active federal review. The U.S.

Department of the Interior acknowledged that Scotts Valley’s original gaming approval may have been based on legal error, yet the Tribe is pressing ahead as if that review does not matter. Without input from the City of Vallejo or the public, Scotts Valley abandoned the government center it previously told residents it was planning and replaced it with a “preview casino.” Despite being described as temporary, the facility would require permanent water, electrical infrastructure, public safety (police and fire), and other public services — resources that belong to the residents of Vallejo, not a Tribe from Clearlake. In September 05, Scotts Valley asked the Vallejo City Council and the public to approve a Memorandum of Understanding for city services to support a government center on the site. When local Tribes, elected leaders, and residents raised reasonable questions about the project, they were met not with clarity or meaningful engagement, but with dismissal and hostility— further eroding trust and transparency. Now, government documents show this so-called “preview casino” has moved forward without meaningful public review, leaving the community no opportunity to ask basic and necessary questions, such as: How much will this cost them? Will this require more police presence? How about fire services? Will this create serious traffic? Will this require plugging into our scarce water sources? These are not minor details. They are the difference between responsible governance and reckless decision-making. Vallejo deserves answers before public resources are committed. Scotts Valley has promised jobs and economic opportunity for Vallejo.

Instead, its actions reflect a pattern of advancing its own interests while sidelining community voices and public process. Moving forward with a casino — even a “temporary” one — while federal gaming eligibility remains under review demonstrates a troubling disregard for transparency and accountability. These actions also impact the ancestral homelands of the Patwin people, local Tribes with deep and continuing cultural ties to this land. Proceeding without consultation or respect for those connections perpetuates harm and undermines trust. Scotts Valley is betting that the community won’t push back. By signing this petition, you are calling for:

NO to a Temporary Casino that will have a permanent impact on the city of Vallejo NO to rushed and secretive actions taken without public review or community consent NO to committing city resources Vallejo deserves transparency, accountability, and respect — not decisions made in haste with lasting consequences. Protect Our Community!" PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document

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xavier zarate · Vallejo, CA 94589
[email protected]
"I don’t think Vallejo’s priorities should be building a casino given the state Vallejo is in" Joshua Escobar · Vallejo, CA 94589
[email protected]
"I sure hope some one can get Peter the city council member from district 5 to grow a backbone and stand against something this community is opposed to."
Elizabeth Woods · Vallejo, CA 94591
[email protected]
"Bring back the horses."
Raquel Barrera · Vallejo, CA 94591
[email protected]
"I live near this supposed to be casino and I am afraid it will cause traffic in highway I0 east from Vallejo town." Protect Tribal Homelands · Vallejo, CA
Judith Race Hoepker · Vallejo, CA 94590 — 4 petition submissions [email protected]
Kristin Sosso · Vallejo, CA 94589
[email protected]
"No casino!"
Martin Gewing · Vallejo, CA 94589 — 2 petition submissions [email protected]
"Just saying NO!"
Martin Gewing · Vallejo, CA 94589
[email protected]
"Just saying NO!"
Karen Orr · Vallejo, CA 94591
[email protected]
"More traffic congestion and crime are a concern. NO casino." Mary Jo Reynolds · Vallejo, CA 94590
[email protected]
"No to Scotts Valley trailer casino or any casino."
brianna flores · Vallejo, CA 94589
[email protected]
"bringing a casino into vallejo close to were i live is a horrible idea. i would probably have to move away from the area. my husband has a past of bad casino/gambling addiction. i know he will lapse and be tempted to go on the daily/weekly bases. it would cause marital problems them will stem to affect my children... i will be moving away from the area before it ipens its doors." "Stop this from happening"
"Stop the casino we the residents of Vallejo do not want a casino in our city." Armando Gonzales · Vallejo, CA 945902SetitiRnsuEPissiRns [email protected]
"Vallejo doesn't need a casino."
"We don't need a casino in Vallejo"
Lenette Weishaar · Vallejo, CA 94591
[email protected]
"Vallejo doesn’t need a casino and it will stretch already limited emergency services beyond breaking." PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document

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Abbey J. · Vallejo, CA 94590
[email protected]
"This land clearly is not connected to this tribe, it is connected to other tribes. Therefore this land does not belong to them and by this along with their actions, it's becoming pretty clear this is just a landgrab. They are showing zero concern for the legal process and the community."
Protect Tribal Homelands · Vallejo, CA
Tony Speck · Vallejo, CA 94590
[email protected]
"Public review first!"
Betty Simmons · Vallejo, CA 94590
[email protected]
"I'm opposed to casinos of any description in Vallejo or any nearby locations. In this case, the rather sly progress right under our noses gives a clue to how transparent and honest they will be. Our precious natural hillsides and landscapes give us a special place to live and recreate. I don't want to lose that. In addition, I have concerns about the values promoted by a casino, the concept of easy money is a lure that discourages honest skill development in the business sector and creates and promotes a "make big money quick"way of thinking. It, also, discourages honest business concepts and skill development more suitable for a city of our size.

Then, there's the traffic issue, crime issue, and senseless overcrowding of our freeways. We are a unique city, placed in a valuable location with the ferry service to San Francisco, the beautiful waterways, the hills covered with flowers in the springtime. We have remarkable houses in The Heritage District and we have a racially mixed community that provides opportunities in the field of cuisine, entertainment, and business acumen. Our history cries for more publications, reenactments, research and writing sessions with prizes, rewards, and opportunities for recognition and advancement for our young people. We still have places on Mare Island that can add to its attractiveness for cyclists, sports and music events, housing and innovative business and education opportunities.

Imagine a bicycle race on Mare Island that can inspire families, children, teens and more as families have picnics and get acquainted. What about a swimming pool? I'd rather see us develop and support our young people, higher education, and sports events than succumb to the intangible promises of a harsh, money grabbing casino. Let's open up communication that is fair, rewards the workers, gives motivation to exceptional students who can train the younger people in high tech, in photography, in finance, sports, music and the global economy. Let's find a way to fund trips for them to the countries where they can share and learn educational, art, economics, languages with each other. Selling out (in any way) this prime piece of our city breaks my heart.

We've so many better options. Lets find ways to keep our kids alive and vibrant, not put them as bait to those who carry guns.. We could name it the McCoy - Monterossa - Oakley CENTER, for example, and have a goal of never again paying out of our city funds for the unconscionable actions of various departments of the City of Vallejo. We could rise above the recognition as a city with the worst streets, to a city that rises to a recognition as a: City That Cares, City That Solves Problems, City With a Vision, City That Inspires, City That Looked to it's Youth for Answers. City Uses Creative Solutions" Kim Garvin · Vallejo, CA 94590
[email protected]
"This casino plan has not been vetted. The people of Vallejo must be heard." Suzanne Huddleston · Vallejo, CA 94591
[email protected]
"I do not want a casino in Vallejo, California. Suzanne Huddleston" James Bergquist · Vallejo, CA 94589
[email protected]
"Vallejo does not need another underhanded business venture that bleeds the City while promising prosperity." Carla Juell · Vallejo, CA 94591
[email protected]
"Do not authorize or commit to any financial backing until the final review for approval is done." Catherine Henderson · Vallejo, CA 94589
[email protected]
"Who has been approving all these construction projects. How are people going to cross that busy run way without getting hit. Not a good spot for a casino. I'm not comfortable with that location" PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document

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Isabel Robles · Vallejo, CA 94592
[email protected]
"No. Stop treating Vallejo like a dumping ground for your illegal activities." Protect Tribal Homelands · Vallejo, CA
Diane Al-Amin · Vallejo, CA 94589
[email protected]
"NO!! Needs thorough vetting and and I would like to understand how the proceeds from this casino would benefit our local tribes and community. Not to say anything of gambling itself being a vice best left to others. And honestly, it's just going to be a traffic nightmare with the increased traffic from Admiral Callahan!" David Wolins · , CA 94591
[email protected]
"Unless the council can assure the public that the casino will pay their FULL costs to cover ALL expenses and operating costs for the added costs, DON'T sign an agreement to support this project." Doreen Serb · Vallejo, CA 94591
[email protected]
"No. Saw how this plays out in other towns. A mess."
Estella Olsen · Vallejo, CA 94592
[email protected]
"NO TEMP CASINO IN VALLEJO"
Susan James · Vallejo, CA 94591
[email protected]
"Stop the Opening of Scotts Valley’s Temporary “Preview Casino” in Vallejo" Frank Gomez · Vallejo, CA 94591
[email protected]
"Please stop the temporary preview casino."
JANET YOUNGDALE · Vallejo, CA 94590
[email protected]
"NO TO ANY CASINO!"
Ralph Cuberos · Vallejo, CA 94589 — 2 petition submissions [email protected]
"We don't need anything like this near here"
Betty Ching · Vallejo, CA 94591
[email protected]
"Vote NO."
Pat Johnson · Vallejo, CA 94590
[email protected]
"Stop the casino!!!"
Rowena Crisostomo · Vallejo, CA 94591
[email protected]
"Pls stop the temporary opening of the casino . I am totally against it as it will bring more crime with not enough police force ." Nick Jenkins · Vallejo, CA 94590 — 2 petition submissions [email protected]
"The Scott's Valley Pomo can take their grift back up to Lake County where it belongs. You failed at Konocti, so now you're going to come down here and sh
t on Vallejo?! I don't think so. Get your butts back to clear lake." "We were sold a real casino with all ours problems, but now y'all are putting in double wides?! Seriously?! How ghetto can you get?! It's not your land, so put this on YOUR tribe's land! This ain't Scott's Valley!" PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document

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Protect Tribal Homelands · Vallejo, CA
Joel Mcbride · Vallejo, CA 94589 — 2 petition submissions [email protected]
Ross Levine · Vallejo, CA 94589
[email protected]
"not approved by the city or it's people."
Kathleen Stavis · Vallejo, CA 94590
[email protected]
"Our community deserves better."
Bonnie Manzonko Garcia Sellars · Vallejo, CA 94590
[email protected]
"Unlucky location for a casino"
Brenda Wallace Smith · Vallejo, CA 94589
[email protected]
"Say Hell No to this potential money grab."
Chris Talbot · Vallejo, CA 94589
[email protected]
"No on the casino!"
James Cisney · Vallejo, CA 94590
[email protected]
"Do not open the door. It will be harder to close once they get a foot in." Dawn Hubberstey · Vallejo, CA 94589 — 2 petition submissions [email protected]
"...Vallejo residents needs our emergency units for us not the casino. STOP the casino" "We don’t need a casino here. We have enough traffic n crime in our city with very little cops. It needs to be shut down" "Seems like the other tribe has a point. The seizure of the land has no historical proof." "Tribe has no legal ties to that land, as the other tribe has argued." Colin Fahrion · Vallejo, CA 94590
[email protected]
"No casinos in Vallejo!"
Christine Wait · Vallejo, CA 94589
[email protected]
"Please no"
Ethan Standafer · Vallejo, CA 94589
[email protected]
"Hell no"
Amanda Sullivan-Smith · Vallejo, CA 94590 — 2 petition submissions [email protected]
"No trailer casino!"
Cheyenne Taylor · Vallejo, CA 94589 — 3 petition submissions [email protected]
"We already have a full casino within 15 minutes of Vallejo and we have a card room in American Canyon on the other end. We don’t need or want this!"
Sandi Gundersen · Vallejo, CA 94589
[email protected]
"Keep Vallejo Safe"
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document

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Protect Tribal Homelands · Vallejo, CA
toni Mahdik · Vallejo, CA 94589
[email protected]
"No casino"
Roberta Iloff · Vallejo, CA 94590
[email protected]
"What in the world are you thinking, City Council!!"
Laura Morales · Vallejo, CA 94590
[email protected]
"No to casino"
Fauzia Osman · Vallejo, CA 94590
[email protected]
"We do not want this casino in our neighborhood!"
Holly Peters · Vallejo, CA 94590
[email protected]
"We don’t need (more) casinoes"
Rebecca Turner · Vallejo, CA 94591 — 2 petition submissions [email protected]
"I hope we're not that gullible to any type of casino whether or not temporary before all federal reviews are done. First they need to have all necessary documents completed and what about any other tribes who actually live here and not putting profits totally for themselves"
"Please don't commit to any legally bind agreement before we see all the cards on the table" Sheryl O'Connor · Vallejo, CA 94590 — 3 petition submissions [email protected]
"WE VOTED NO. NO MORE CORPORATE BULLSHIT."
"VALLEJO DOES NOT NEED MORE SAFETY ISSUES. VALLEJO NEEDS MORE OFFICERS." "Too much trouble for Vallejo now. Police couldn't handle the crime that comes with a Casino. BIG NO" Cherrlynn Hubbard · Vallejo, CA 94591
[email protected]
"We do not want a casino. We want businesses that we actually need like quality grocery stores and real solutions to the homeless epidemic. How about cleaning our streets up of all the trash and garbage from the homeless population trying to survive." Christine Corral · Vallejo, CA 94591
[email protected]
"No to casino!!"
Richard Custer · Vallejo, CA 94589
[email protected]
"Why doesn’t the city council work on getting Vallejo’s roads fixed, especially Sonoma BLVD, instead of getting a casino built." Brendan Ortman · Vallejo, CA 94591 — 2 petition submissions [email protected]
"HIRE MORE POLICE OFFICERS, LOWER YOUR STANDARDS"
Daphne Ames · Vallejo, CA 94589
[email protected]
"We need more police officers."
Shari Miller · Vallejo, CA 94590
[email protected]
"NO temporary casino or permanent casino!"
Fe Mangoba · Vallejo, CA 94591
[email protected]
"No casino set up at all."
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document

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Protect Tribal Homelands · Vallejo, CA
Luis Gomez · Vallejo, CA 94590
[email protected]
"No casino!!!!"
Rasheeda Foster · Vallejo, CA 94590
[email protected]
"No to the casino!"
Gio Penate · Vallejo, CA 94590
[email protected]
"There are more hazards than benefits if any to the community. As if Vallejo doesn't have enough problems." Jimmy Genn Genn · Vallejo, CA 945902SetitiRnsuEPissiRns [email protected]
LisaMarie Miramontes · Vallejo, CA 94591
[email protected]
"Shamefully took the home of q bunch of beautiful horses" "...Native Tribes moved around, but, to the best of my knowledge, the Lake Tribe, were not past residents of Vallejo." "My Home Town allowed a casino. Nothing but trouble."
Lockwood Tracy · Vallejo, CA 94590
[email protected]
"My sentiments exactly. With our law enforcement resources spread so thin. The last thing we need is a casino." Kare Black · Vallejo, CA 94590
[email protected]
"No temporary casino"
Mary Sori · , CA 94590 — 2 petition submissions
[email protected]
"It affects us as residents of Vallejo, so no “preview casino” thanks!" Nora Koontz · Vallejo, CA 94589
[email protected]
"A casino is the LAST thing needed in Vallejo, Ca."
Peach Prell · Vallejo, CA 94591 — 2 petition submissions [email protected]
"NO!!!"
Nardos Tesfaye · Vallejo, CA 94592
[email protected]
"We don’t need casinos in Vallejo. It is like opening a door for more problems in our city instead of dealing with an existing situation." LEE RAPPEPORT · Vallejo, CA 94590 — 2 petition submissions [email protected]
"NO!!!"
"No Casino in Vallejo!"
Arnold Ercole · Vallejo, CA 94589
[email protected]
"Local Traffic will be hell…."
M. Dairo · Vallejo, CA 94591
[email protected]
"Stop the opening of casinos in vallejo"
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Vick Scott · Vallejo, CA 94590
[email protected]
"Stop the casino. Not good for our city."
Deborah Cole · Vallejo, CA 94589
[email protected]
"People will get robbed and they'll get sued!!"
Ibrahim Edais · Vallejo, CA 94590
[email protected]
"Are we serious? To boost our economy, instead of reviving the downtown by driving incentitive for small businesses to open and programs to launch, we're building a $700m casino resort on TRIBAL LAND?!"

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Protect Tribal Homelands · Vallejo, CA
Edith G. · Vallejo, CA 94590
[email protected]
"As a resident of Vallejo, I never received any communication regarding the new casino construction, like logistics, or future management plans that would benefit to the community."
Gloria Venegas · Vallejo, CA 94591
[email protected]
"This so called “preview casino” is the last thing Vallejo needs. It will only cause more problems than we already have." Randall Harper · Vallejo, CA 94590
[email protected]
"No Casino in bay Vallejo"
Fernando Barboza · Vallejo, CA 94591
[email protected]
"Is not necessary in this city"
Larry Milliken · Vallejo, CA 94590
[email protected]
"I have lived jn Vallejo for over ten years now. I own my home. We don’t have police we don’t have first responders. We are closing schools. The last thing we need is this. It will attract the very worst of our society." Dave David · Vallejo, CA 94589
[email protected]
"We need a big tax payer in Vallejo for improvements."
Wanderley Revert · Vallejo, CA 94590
[email protected]
"No to trailer cassinos in Vallejo"
Linda Obrien · Vallejo, CA 94591
[email protected]
"Absolutely NO"
Brendan Ortman · Vallejo, CA 94591
[email protected]
"HIRE MORE POLICE OFFICERS, LOWER YOUR STANDARDS"
Jennifer Panameno · Vallejo, CA 94590
[email protected]
"We don’t need any more distractions here"
Precious Villegas · Vallejo, CA 94591
[email protected]
"Vallejo already has enough problems in terms of crime and violence. Address these issues before creating more. Also what eye sore it would be in ruining the natural landscape of that beautiful area." PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Maria Macagba · Vallejo, CA 94589
[email protected]
"Inconvenient location"

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Protect Tribal Homelands · Vallejo, CA
Albert Regis · Vallejo, CA 94591
[email protected]
"Told NO once ...NOW!"
ROBERT BELL · Vallejo, CA 94591
[email protected]
"No casino!!!!"
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Signers Without Comment
George Mariscal
[email protected]
Vallejo, 94591
Matthew Heinrichs
[email protected]
Vallejo, 94590
Erika Anholm
[email protected]
Vallejo, 94591
Steve Davis
[email protected]
Vallejo, 94590
Christina Washington
[email protected]
Vallejo, 94590
Victoria Ruiz-Jaime
[email protected]
Vallejo, 94591
Kathleen Ackelbein
[email protected]
Vallejo, 94591
Andrew Price
[email protected]
Vallejo, 94590
Kia Kalama
[email protected]
Vallejo, 94591
Frank Garcia
[email protected]
Vallejo, 94590
William Tennant
[email protected]
Vallejo, 94591
Eladio Tunac
[email protected]
Vallejo, 94589
Maria Panameno-Arvilla
[email protected]
Vallejo, 94589
Beth Tessler
[email protected]
Vallejo, 94590
Kim Palacios
[email protected]
Vallejo, 94590
Kevin Linam
[email protected]
Vallejo, 94589
Truse Pretto
[email protected]
Vallejo, 94591
Kathleen O’Halloran
[email protected]
Vallejo, 94591
Amanda Sullivan-Smith
[email protected]
Vallejo, 94590
Amber Acosta
[email protected]
Vallejo, 94591
Diane Probasco
[email protected]
Vallejo, 94590
Ralph Ron Bowen
[email protected]
Vallejo, 94591
Karen Richer Richer
[email protected]
Vallejo, 94591
Britt Sandkulla-Sinclair
[email protected]
Vallejo, 94591
Breanna Walker
[email protected]
Vallejo, 94591
DIANNA M Pugh-Ramsey
[email protected]
Vallejo, 94591
Carlos Solorzano
[email protected]
Vallejo, 94589
Kia Kalama
[email protected]
Vallejo, 94591
Steve Davis
[email protected]
Vallejo, 94590

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Protect Tribal Homelands · Vallejo, CA
=enaiGa'eOeRn
[email protected]
m Vallejo, CA 94591
Andy Fletcher
[email protected]
Vallejo, 94591
Kathleen Ackelbein
[email protected]
Vallejo, 94591
Cass Mckinney
[email protected]
Vallejo, 94590
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[email protected]
Vallejo, CA 94590
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[email protected]
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[email protected]
Vallejo, CA 94590
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[email protected]
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[email protected]
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[email protected]
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[email protected]
Vallejo, 94591
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Loretta Bancroft
[email protected]
Vallejo, 94591
Sheila Cullen
[email protected]
Vallejo, 94591
jessica Juarez Juarez
[email protected]
Vallejo, 94589
Richard Oleksy
[email protected]
Vallejo, 94590
Nanette Koelsch
[email protected]
Vallejo, 94590
Sajan Singh
[email protected]
Vallejo, 94591
Lorisa Osborn
[email protected]
Vallejo, 94591
Roxanna Breeden
[email protected]
Vallejo, 94591
Robert Stewart
[email protected]
Vallejo, 94590
Angela Whitford
[email protected]
Vallejo, 94591
Dorothy Floyd
[email protected]
Vallejo, 94589
angele Woodfin
[email protected]
Vallejo, 94591
Alberto Blanco
[email protected]
Vallejo, 94590
Russell Urzi
[email protected]
Vallejo, 94591
Greg McGriff
[email protected]
Vallejo, 94591
Colin Schock
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Vallejo, 94590
Ronald Steege
[email protected]
Vallejo, 94591
George Mariscal
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Vallejo, 94591
Dee Miller
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Vallejo, 94592
Dennis Reed
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Vallejo, 94590
Steve Davis
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Vallejo, 94590
Francine Gray
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Vallejo, 94589
Francine Gray
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Vallejo, 94589
Maria Guadamuz
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Vallejo, 94590
Ann Adams
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Vallejo, 94590
Francisco Silva
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Vallejo, 94591
Ronald Steege
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Vallejo, 94591
Alicia Jackson
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Vallejo, 94591
Julio Escobar
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Vallejo, 94591
Virginia Ward
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Vallejo, 94591
Tim Johnson
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Vallejo, 94592
Tim Johnson
[email protected]
Vallejo, 94592
Christina Gutierrez
[email protected]
Vallejo, 94591
Megan Hatcher
[email protected]
Vallejo, 94591
Terence McGuinness
[email protected]
Vallejo, 94591
Nanette Koelsch
[email protected]
Vallejo, 94590
Judith Preciado
[email protected]
Vallejo, 94591
William Tennant
[email protected]
Vallejo, 94591
Rosemary Lojo
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Vallejo, 94589
George Mariscal
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Vallejo, 94591
Angela Whitford
[email protected]
Vallejo, 94591

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Protect Tribal Homelands · Vallejo, CA
+iOar\%riFK
[email protected]
Vallejo, 94591
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Caroline Abram
[email protected]
Vallejo, 94589
Lindsey Sampson
[email protected]
Vallejo, 94591
Sara Oldershaw
[email protected]
Vallejo, 94591
Krista Kern
[email protected]
Vallejo, 94591
Nanette Koelsch
[email protected]
Vallejo, 94590
Rolando Miranda
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Vallejo, 94589
Shareileen Raymundo
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Vallejo, 94589
Terence McGuinness
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Vallejo, 94591
Martha Garcia
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Vallejo, 94589
A Shuster
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Vallejo, 94590
Penny Barnes
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Vallejo, 94591
Lyra Francisco
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Vallejo, 94591
Nicole O’Hara-Shearer
[email protected]
Vallejo, 94589
JorJa Alferez
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Vallejo, 94591
Tiff Sanchez
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Vallejo, 94589
Gail Burch
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Vallejo, 94591
Bret Souza
[email protected]
Vallejo, 94590
Gary Marshall
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Vallejo, 94591
Phyllis Woodard
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Vallejo, 94589
Drsexy Meraz
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Vallejo, 94590
Liz Caine
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Vallejo, 94591

WILLIAM PLONSKY
[email protected]
Vallejo, 94590
Martha Garcia
[email protected]
Vallejo, 94589
Martha Garcia
[email protected]
Vallejo, 94589
Martha Garcia
[email protected]
Vallejo, 94589
Laura Julian
[email protected]
Vallejo, 94589
Tracy Williams
[email protected]
Vallejo, 94591
Jodie Rouse
[email protected]
Vallejo, 94590
Yi Teh
[email protected]
Vallejo, 94591
Maryanne Gibb
[email protected]
Vallejo, 94591
Judy Shaw
[email protected]
Vallejo, 94589
Paul De Vita
[email protected]
Vallejo, 94589
Tammy Quijano
[email protected]
Vallejo, 94591
Ruby Trinidad
[email protected]
Vallejo, 94590
Angela Stewart
[email protected]
Vallejo, 94590

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Protect Tribal Homelands · Vallejo, CA
/aura'Rrais3SetitiRnsuEPissiRns
[email protected]
Vallejo, 94590
5iFarGR1etrR3SetitiRnsuEPissiRns
[email protected]
Vallejo, 94591
$OiSFRtt
[email protected]
Vallejo, 94591
*eRrge5aPire]
[email protected]
Vallejo, 94590
7KeOPaS\
[email protected]
Vallejo, 94591
Laura Julian
[email protected]
Vallejo, 94589
Tiarra Hearne
[email protected]
Vallejo, 94589
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Arthur Collins
[email protected]
Vallejo, 94591
LeiKim Sawyer
[email protected]
Vallejo, 94589
Jacqueline Baniqued
[email protected]
Vallejo, 94589
Eliza Nedine Dizon
[email protected]
Vallejo, 94591
Theresa Hindsman
[email protected]
Vallejo, 94590
Ruby Trinidad
[email protected]
Vallejo, 94590
Regina Mitchell
[email protected]
Vallejo, 94590
Suzanne Klehr
[email protected]
Vallejo, 94590
Randy Montgomery
[email protected]
Vallejo, 94591
Angela Stewart
[email protected]
Vallejo, 94590
Samantha Koehler
[email protected]
Vallejo, 94591
Linda Tronnes
[email protected]
Vallejo, 94590
Kristen Bautista
[email protected]
Vallejo, 94591
Katherine Hanna
[email protected]
Vallejo, 94589
Robbie Jackson
[email protected]
Vallejo, 94591
Camille Salazar
[email protected]
Vallejo, 94591
Jamie Mao
[email protected]
Vallejo, 94591
Claudia Soriano
[email protected]
Vallejo, 94591
Jackson Stevens
[email protected]
Vallejo, 94589
Esmeralda Garcia
[email protected]
Vallejo, 94591
Ricardo Vasquez
[email protected]
Vallejo, 94591
Kim Carter
[email protected]
Vallejo, 94590
Angelo Sanchez
[email protected]
Vallejo, 94590
Tracy Finuf
[email protected]
Vallejo, 94591
Vanessa Araujo
[email protected]
Vallejo, 94591
Peter Berroya
[email protected]
Vallejo, 94589
Natalie Marberry
[email protected]
Vallejo, 94589
Susan Madderra
[email protected]
Vallejo, 94591
Me'khi Stewart
[email protected]
Vallejo, 94589
Michael Garcia
[email protected]
Vallejo, 94590
Alia Rose
[email protected]
Vallejo, 94590
Anthony Eugene Magbitang
[email protected]
Vallejo, 94591
Kevin Linam
[email protected]
Vallejo, 94589

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Protect Tribal Homelands · Vallejo, CA

PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document SOLANO COUNTY (Non-Vallejo) SIGNATORIES
Solano County Residents: 82 Signatures _ 65 Unique Signers 33 Total Comments
%eniFiaarea: 1 signer
Jeff Traina · , CA 94510
[email protected]
American Canyon: 21 signers
Francisco Jimenez · American Canyon, CA 94503
[email protected]
Linda Green · American Canyon, CA 94503 — 2 petition submissions [email protected]
Lori Davis · American Canyon, CA 94503
[email protected]
Bess Kemp · American Canyon, CA 94503
[email protected]
Julia Salvador · American Canyon, CA 94503
[email protected]
Mike Greene · American Canyon, CA 94503
[email protected]
Laura McSkeane · American Canyon, CA 94503
[email protected]
Shana Ellis · American Canyon, CA 94503
[email protected]
Matthew Fredborg · American Canyon, CA 94503
[email protected]
Brandon Saker · American Canyon, CA 94503 — 2 petition submissions [email protected]
Tony Lauser · American Canyon, CA 94503
[email protected]

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Protect Tribal Homelands · Vallejo, CA
JIM KAISER · American Canyon, CA 94503
[email protected]
Brandon Saker · American Canyon, CA 94503
[email protected]
Jennifer Mates · American Canyon, CA 94503
[email protected]
Charles Preset · American Canyon, CA 94503
[email protected]
Jenny Greene · American Canyon, CA 94503 — 2 petition submissions [email protected]
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Michael Greene · American Canyon, CA 94503
[email protected]
Rosario Garcia · American Canyon, CA 94503
[email protected]
Nancy Morales · American Canyon, CA 94503
[email protected]
Edgar Herrera · American Canyon, CA 94503
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Benicia: 23 signers
Mary Brakefield · Benicia, CA 94510
[email protected]
Esther Jackson · Benicia, CA 94510
[email protected]
Mary Brakefield · Benicia, CA 94510
[email protected]
Pat Toth-Smith · Benicia, CA 94510
[email protected]
Ken Bryant · Benicia, CA 94510
[email protected]

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Protect Tribal Homelands · Vallejo, CA
Deborah Morrison · Benicia, CA 94510
[email protected]
Scott Freitas · Benicia, CA 94510
[email protected]
Judith Amlin · Benicia, CA 94510
[email protected]
Debbie Dovala · Benicia, CA 94510
[email protected]
Carmelita Thurman · Benicia, CA 94510 — 2 petition submissions [email protected]
Mariza Angel Moffatt · Benicia, CA 94510
[email protected]
karen ebert · Benicia, CA 94510 — 2 petition submissions [email protected]
Mariza Angel Moffatt · Benicia, CA 94510
[email protected]
Nicole Barnum · Benicia, CA 94510
[email protected]
Fran Wilder · Benicia, CA 94510
[email protected]
Denise Thompson · Benicia, CA 94510
[email protected]
karen ebert · Benicia, CA 94510
[email protected]
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document

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Protect Tribal Homelands · Vallejo, CA
Tamra J Amato · Benicia, CA 94510
[email protected]
Lisa Burton · Benicia, CA 94510
[email protected]
Juliet Vercelli · Benicia, CA 94510
[email protected]
Neena Plune · Benicia, CA 94510
[email protected]
Lisa Reynolds · Benicia, CA 94510
[email protected]
Fairfield: 14 signers
· Fairfield, CA 94534
[email protected]
Roch Brousseau · Fairfield, CA 94533
[email protected]
Rhonda Reeder Perez · Fairfield, CA 94533
[email protected]
Marcia Adair · Fairfield, CA 94534
[email protected]
Scott Maddi · Fairfield, CA 94533
[email protected]
Faye Ny · Fairfield, CA 94534
[email protected]
Denise Kirchubel · Fairfield, CA 94534
[email protected]
Faye Ny · Fairfield, CA 94534
[email protected]
Nathan Barron · Fairfield, CA 94534
[email protected]
ANita Sosa-Huerta · Fairfield, CA 94534
[email protected]
Terri Boyles · Fairfield, CA 94534
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Tina Brown · Fairfield, CA 94533
[email protected]
Elizabeth Woods · Fairfield, CA 94533
[email protected]
Zachary Clayton · Fairfield, CA 94533
[email protected]
Rio Vista: 3 signers
Patricia Anderson · Rio Vista, CA 94571
[email protected]
Laura Britto · Rio Vista, CA 94571 — 2 petition submissions [email protected]
PROTECT TRIBAL HOMELANDS Stop the Scotts Valley Preview Casino: Petition Document Vacaville: 14 signers
Carol Thomson · Vacaville, CA 95688
[email protected]
Linda Crastes · Vacaville, CA 95687
[email protected]
Regina Benson · Vacaville, CA 95687
[email protected]
Cynthia Simpson · Vacaville, CA 95688
[email protected]
Kimberly Ramey · Vacaville, CA 95687
[email protected]
Kimberly Ramey · Vacaville, CA 95687
[email protected]
Randy Powers · Vacaville, CA 95687
[email protected]
Randy Powers · Vacaville, CA 95687
[email protected]
Julie Velez · Vacaville, CA 95687
[email protected]
Regina Benson · Vacaville, CA 95687
[email protected]

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Protect Tribal Homelands · Vallejo, CA
Mary Little · Vacaville, CA 95688 — 2 petition submissions [email protected]
Kimberly Ramey · Vacaville, CA 95687
[email protected]
Sandra Silutton · Vacaville, CA 95688
[email protected]

1 I. The City Has Adopted an Erroneous Definition of the Project.

CEQA defines projects broadly to include “the whole of the action” and requires lead agencies to consider all reasonably foreseeable environmental issues, including all reasonably foreseeable phases of development. Here, the City has proposed to violate these fundamental requirements by pretending the proposed action before the City Council (“Project”) is limited to a small part of a much larger casino development project (“Full Buildout”) – a textbook case of improper segmentation.

Substantial evidence makes clear that the Project is an initial phase of Scotts Valley’s full buildout. Scotts Valley’s own April 10, 2026, letter (included in the supplemental agenda materials) shows the connection, referring to the Project as the “[c]urrent [p]hase” of the larger buildout and explaining the importance of the proposed Class II gaming operation to “establishing an economic foundation” that will allow Scotts Valley to follow the “pathways required for the full project.” (Shawn Davis Letter to Mayor and Vallejo City Council re MOU Between the City of Vallejo and the Scotts Valley Band of Pomo Indians (Apr. 10, 2026).) Chairman Shawn Davis was likewise quoted in a December 2025 article by the Daily Republic as describing an “interim facility” as a way for Scotts Valley to “provide meaningful economic opportunity . . . while we work on our permanent facility.” In addition, Chairman Davis submitted sworn statements in federal court stating that Class II gaming would serve as a pathway for its initial gaming operations, even as the Tribe pursued the additional option of Class III gaming through a compact.” (Declaration of Shawn Davis in Support of Motion for Preliminary Injunction (May 19, 2025).)

The City’s agenda packet contains further evidence. For example, the Staff Report says that one of the benefits of the Project is to “advance” the City’s Cooperative Agreement with Scotts Valley – an agreement which addresses the Full Buildout. The Staff Report explains that some of the studies prepared for the Project were undertaken pursuant to the Cooperative Agreement (and reimbursement arrangements) for the Full Buildout.

The Staff Report further notes that Scotts Valley is actively working toward the Full Buildout, including by seeking a Class III gaming compact with the State of California.

And the Staff Report recommends that mitigation for MOU should include a traffic study addressing the Full Buildout.

Additional evidence can be found in the proposed MOU itself. For example, MOU Exhibit C says the Project is meant to support the Full Buildout and is part of “the deployment of phased development.”

2 These examples – and more could readily be found – show that the Project represents a threshold moment that would commit resources and infrastructure necessary for the Full Buildout. As a result, CEQA demands that all reasonably foreseeable environmental impacts of the Full Buildout be evaluated.

Perhaps recognizing this issue, the agenda packet includes several references to a prior Environmental Assessment (“EA”) under the National Environmental Policy Act (“NEPA”). The EA was riddled with holes and failed to identify or mitigate relevant environmental impacts, as the City itself has recognized. Moreover, the EA, by its own terms, did not address any Class II gaming facility and did not purport to provide a CEQA-compliant environmental analysis. If anything, the EA simply confirms that the Full Buildout is a reasonably foreseeable phase of development and must be evaluated. (See Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal. 3d 376, 396-398 [requiring CEQA analysis of environmental effects of future expansion of a project if it is a reasonably foreseeable]; San Franciscans for Reasonable Growth v. City & County of San Francisco (1984) 151 Cal.App.3d 61, 75 [similar].)

Nor can the City avoid review by disclaiming discretion. Although there may be alternative ways for Scotts Valley to develop the lands currently held in trust for its benefit, the Band has designed and proposed this Project (and the Full Buildout) in such a way that City permitting and approval is required. Full CEQA compliance is therefore required.

The City’s failure to properly define the scope of the Project infects the entire environmental analysis (such as it is) and requires reconsideration and further review under CEQA.

II. The City Improperly Relies on a Class 3 Exemption from CEQA Review

The City proposes to invoke CEQA Guidelines section 15303 as the first of two exemptions from CEQA review. In urbanized areas, the Class 3 exemption for “New Construction or Conversion of Small Structures” authorizes up to four “commercial buildings not exceeding 10,000 square feet in floor area on sites zoned for such use if not involving the use of significant amounts of hazardous substances where all necessary public services and facilities are available and the surrounding area is not environmentally sensitive.” (CEQA Guidelines § 15303, subd. (c).) It also authorizes water mains, other utility extensions, and street improvements “of reasonable length to serve such construction.” (CEQA Guidelines § 15303, subd. (d).)

3 The City has failed to properly establish that the Class 3 exemption is applicable. First, the property is not zoned for use as a casino – “temporary” or otherwise. As the City itself stated in its EA comment letter, “[t]he Vallejo zoning code does not have any use classification for a casino so the proposed casino would be inconsistent with existing zoning.” (City of Vallejo Comments on Environmental Assessment for Scotts Valley Band of Pomo Indians Casino and Tribal Fee-to-Trust Project (August 22, 2024), at 9.) The same principal applies here.

The Project also fails to meet the requirement that “all necessary public services and facilities are available.” If they were already available, there would be no need for the MOU.

In addition, the surrounding area is “environmentally sensitive.” As shown in MOU Exhibit B (among many other documents), the Project site includes protected wetlands.

It is also within and adjacent to habitat for numerous species identified as threatened or endangered under federal and/or state law. Without CEQA analysis, the City risks blindly facilitating further ground disturbing activity and hundreds of daily car trips that could pose risks of runoff into these nearby wetlands and otherwise threaten wildlife that depends on this sensitive habitat. In this regard, it is worth noting that the EA (and other federal processes) excluded any consideration of special-status species entitled to protection under the California Endangered Species Act (“CESA”), including the Crotch’s bumble bee, western bumble bee, burrowing owl, and Swainson’s hawk. Swainson’s hawk is listed as threatened under CESA and the other three species are candidates for listing under CESA, entitling them to protections afforded to listed species. The Project would occur within – and indisputably impact – their habitat, but neither the City nor any federal agency has complied with relevant requirements.

III. The City Improperly Relies on a Class 4 Exemption from CEQA Review

The City also points to CEQA Guidelines section 15304, claiming a Class 4 CEQA exemption for “Minor Alterations to Land.” Reliance on this exemption is likewise misplaced. By its own terms, CEQA Guidelines section 15304 only applies to “minor . . . alterations to land, water, and/or vegetation.” This does not cover the provision of services to a casino or exempt from CEQA review any of the foreseeable environmental effects spurred by that approval.

The Staff Report asserts that grading will be on land with slope of less than 10 percent.

Presumably, this is intended to address earthwork associated with utility connections authorized by the MOU. It does not extend to the modifications to the water lines and other service infrastructure, cover major roadway improvements, or exempt from CEQA 4 the foreseeable impacts of gaming operations at an environmentally sensitive project site.

In addition, CEQA Guidelines section 15304 expressly says that grading “shall not be exempt in a waterway” or “in any wetland. (CEQA Guidelines § 15304, subd. (a) [emphasis added].) The U.S. Fish and Wildlife Service’s National Wetlands Inventory shows an intermittent wetland crossing through the project area, which alone precludes reliance on the Class 4 exemption for grading work as contemplated by the City.1

The Staff Report suggests the MOU also involves a “[m]inor temporary use of land having negligible or no permanent effects on the environment.” The assertion – unsupported by substantial evidence – is simply not believable given the extensive environmental impacts flowing from the Project (not to mention the Full Buildout) and its sensitive location. A controversial casino project is not a “minor alteration to land.”

IV. Regulatory Exceptions Preclude Reliance on Categorical Exemptions

Even if the categorical exemptions cited by the City were applicable to the Project (and they are not) the exceptions set forth in CEQA Guidelines section 15300.2 would preclude their use.

A. Sensitive Environment

First, “a project that is ordinarily insignificant in its impact on the environment may in a particularly sensitive environment be significant.” (CEQA Guidelines § 15300.2, subd. (a).) The wetlands in and immediately adjacent to the project site were acknowledged in the NEPA review for the Full Buildout and have been mapped on the U.S. Fish & Wildlife Service National Wetlands Inventory.2 Thus, the potential for significant impacts flowing from approval of the MOU is enhanced and reliance on CEQA exemptions is invalid.

B. Cumulative Impacts

In addition, subsection (b) of section 15300.2 indicates that exemptions are inapplicable “when the cumulative impact of successive projects of the same type in the same place, over time is significant.” Even if (as the City suggests) the Full Buildout were a separate project, it would indisputably be a “successive” gaming development “in the same place” – and additional reason why the City’s claimed CEQA exemptions are inapplicable here. 1 U.S. Fish & Wildlife Service National Wetlands Inventory, https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/. 2 U.S. Fish & Wildlife Service National Wetlands Inventory, https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/. 5 C. Unusual Circumstances

Third, reliance on CEQA exemptions is not permitted where there is “a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances.” (CEQA Guidelines § 15300.2, subd. (c).) The “unusual circumstances” exception is plainly applicable here. Authorizing public services, infrastructure, and an encroachment permit for a casino clearly goes beyond the typical modest circumstances where these CEQA exemptions would be invoked. Therefore, this situation presents unusual circumstances threatening significant environmental impacts such that this exception applies. (See Voices for Rural Living v. El Dorado Irrigation District (2012) 209 Cal.App.4th 1096, 1109.)

Also unusual is the process by which the property was originally taken into trust and declared eligible for gaming in the first place – so unusual, in fact, that it spurred multiple rounds of litigation and a rare admission by the U.S. Department of the Interior that the original gaming eligibility decision was likely legal error. The Department has taken the highly unusual step of reconsidering its original gaming eligibility decision and informed interested parties that the original decision should not be relied on in the meantime. The federal judge overseeing the cases has gone even further, upholding Interior’s inherent authority to reconsider and noting that Scotts Valley would be “ill-served” by relying on the original decision. (See Scotts Valley Band of Pomo Indians v. Burgum (D.D.C. 2025) 808 F. Supp.3d 1, 28.) Interior anticipates completing the reconsideration process by July 31, but the Project would nonetheless unleash unevaluated (and unmitigated) environmental impacts on a sensitive area.

i. Water Supply and Water System Capacity Impacts

The City Water Department has submitted a cursory and incomplete memorandum purporting to conclude that any water concerns can be dismissed. But the memo admits that “specific water demand projections for the interim use were not provided.” Its conclusion appears to be based solely on the fact that the Project’s water use (whatever it may be) would likely be less than the Full Buildout – a leap of logic that cannot substitute for serious analysis.

There is reason to take a closer look. As the City itself explained in its comments on the EA, the Project site contains important water mains requiring careful treatment.

Moreover, security risks to the nearby Columbus Parkway Tank would be a serious concern. These concerns are all the more salient given the Staff Report’s acknowledgement of Scotts Valley’s alarming efforts to tap into the water system without proper authorization, leading to $15,000 of water loss and damage to water lines. 6 Additionally, the City does not appear to have conducted any meaningful analysis of potential constraints on water supply, including the history of curtailment orders from the State Water Resources Control Board under License 7848, increasing drought from climate change, and the City of Vallejo’s various water disputes with the City of American Canyon.3 The fact that neither the Project nor the Full Buildout is properly accounted for in an up-to-date Urban Water Management Plan heightens the concern. CEQA case law requires careful evaluation of expansions in water service when drought conditions can put strain on the ability to provide adequate water supply. (Voices for Rural Living v. El Dorado Irrigation District (2012) 209 Cal.App.4th 1096, 1110-1112.) Furthermore, the California Supreme Court has mandated that future water supplies be clearly identified and analyzed under the assumption that all phases of the project will be built and contribute to water demand. (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 430-432.) These analytical oversights along with the evidence of potentially significant water supply impacts from the project preclude reliance on CEQA exemptions.

ii. Emergency Access and Traffic Impacts

The City does not appear to have addressed serious problems with emergency access and traffic circulation that would be exacerbated by the opening of the gaming facility. The Staff Report discusses Scotts Valley obtaining encroachment permits for utility and road work but does not discuss the nature of this work in any detail or evaluate the impacts it may cause. To ensure adequate emergency access, the driveway into the property is required to be expanded and paved. (See California Fire Code § 503.2 [requiring a minimum of 20-feet wide fire access roads that can support the loads of fire apparatus and are surfaced to provide all-weather driving capabilities].) As the City itself has noted, site plans fail to show the width of access and egress to enable proper emergency access and a minimum of 12-feet wide paved lanes is required to provide adequate emergency vehicle access. (City EA Comments at 8, 19.) The MOU vaguely commits to ensure timely 3 See, e.g., Cross-Complaint of City of Vallejo, City of American Canyon v. City of Vallejo (Sacramento County Superior Court Case No. 34-2022-00327471-CU-CO-GDS) [“The possibility of curtailments impacting Vallejo’s ability to supply its License Water to American Canyon pursuant to the Agreement and Addenda has been in the contemplation of the parties since the Agreement was entered into.”]; City of Vallejo Petition for Writ of Mandate, City of Vallejo v. City of American Canyon (Sacramento County Superior Court Case No. 24WM000078) [“By failing to consider the impacts of the 2021 and the 2022 Curtailment Orders on the City’s water supply, the DEIR failed to consider the actual quantities delivered to the City during such years and the potential for impacts from future curtailments. Due to its failure to evaluate these recent water supply impacts, the DEIR and the FEIR impermissibly seek to rely on paper water that does not have a realistic probability of being available during significant portions of entire years.”]. 7 ingress and egress consistent with California Fire Code, but there is no discussion of when this will happen, what the planned improvements are, and what impacts it is likely to cause. Those potentially significant impacts are not covered by any exemption and must be studied under CEQA.

Furthermore, adding traffic to existing congestion problems near the Project site will require substantial mitigation. The AP Triton Analysis included in the agenda packet assumes 801 daily trips and suggests that any traffic impacts can be addressed with a Traffic Management Plan—but no detail is provided regarding the contents of such plan, making it a highly unreliable source of mitigation. Approval of this MOU would authorize the temporary gaming facility to open and exacerbate traffic with no commitment to truly mitigate these impacts.

The concern is not abstract. Even in the absence of a Project traffic study, there is substantial evidence of significant impacts related to at least two specific intersections.

 Intersection of Columbus Parkway (Auto Mall Parkway) & Admiral Callaghan Lane
o City comments on the EA explained that queue lengths as this intersection exceed existing storage and will further impact traffic circulation. o In response, the EA adopted mitigation to widen Columbus Parkway (Auto Mall Parkway).
o However, the temporary facility has not agreed to implement this mitigation prior to opening, meaning that significant impacts will remain unmitigated.4

 Intersection of I-80 Southbound Offramp & SR-37 Eastbound Offramp o Appendix R to the Final EA acknowledged a Level of Service (“LOS”) of F as the existing intersection condition. (Final EA, Appendix R, Table 4.) o The SIR found that this already unacceptably congested intersection would suffer an additional 7-second total delay.
o Perhaps more troubling is that the volume-to-capacity ratio was calculated to increase by 0.027 in violation of the City’s threshold for significant impacts at intersections already operating over capacity. The City Public Works Department’s Traffic Impact Analysis/Study Guidelines explain that 4 It is also worth noting that a federal Supplemental Information Report (“SIR”) found that a temporary gaming facility would add 24 feet of storage in the eastbound lane but did not evaluate the addition of storage to the northbound lane. The Final EA noted that the northbound lane had already used up 409 feet of its 425 feet of storage. Thus, a similar addition of 24 feet of storage to the northbound lane would result in a safety risk from exceedance of available storage.
8 for an intersection with an LOS of F, any increase in volume-to-capacity greater than 0.01 is a significant traffic impact.5
o The EA provided for roadwork improvements as mitigation to be completed before the casino opened, but the Staff Report fails to consider traffic impacts or commit to the measure in the EA or any alternative measure to ensure significant traffic impacts are avoided.

These potentially significant traffic impacts preclude the City’s reliance on CEQA exemptions.

iii. Biological Resource Impacts

As explained above, the Project site and adjacent lands are habitat for (and contain) numerous special-status species. Particularly notable are several special-status species entitled to protections under CESA, including Crotch’s bumble bee, western bumble bee, burrowing owl, and Swainson’s hawk. The Project facilitates loss of foraging habitat for these species, among others, and poses risks of significant impacts from ground disturbing activities and influx of vehicle traffic that could cause collisions. These impacts are not evaluated – and have never been evaluated – and no mitigation is proposed.

Therefore, there remain potentially significant environmental effects from the unusual circumstances presented by the Project and reliance on categorical exemptions is improper.

iv. Public Safety Impacts

The MOU also calls for the City to dedicate police services to Scotts Valley despite significant staffing shortages. In December 2025, Vallejo’s Chief of Police Jason Ta recommended the City extend the state of emergency over police staffing shortages declared in July 2023.6 Though the City Council failed to extend the state of emergency – by a tied vote of 2-2 with only four of the six Council members present – the issues over permanent City law enforcement remain.7 The City has had to turn to reliance on outside law enforcement services, including additional traffic services from CHP authorized by 5 City of Vallejo Public Works Department, Traffic Impact Analysis/Study Guidelines, https://www.cityofvallejo.net/common/pages/DisplayFile.aspx?itemId=17941488. 6 Janis Mara, Times-Herald, Vallejo City Council Fails to Extend Police Department Staffing Emergency (Dec. 18, 2025), https://www.timesheraldonline.com/2025/12/18/vallejo-city-council-fails-to-extend-police- department-staffing-emergency/
7 Id.
9 Governor Newsom in February 2025 as well as an agreement with the Solano County Sheriff’s office to provide one year of support.8

Against this backdrop, committing police resources to serve Scotts Valley's gaming facilities risks potentially significant consequences. While the MOU provides for monetary contribution, it does not ensure staffing. And even the monetary contribution would evaporate unless Scotts Valley’s casino is operating – hardly a sure thing given the above-referenced reconsideration process.

v. Cultural Resource Impacts

CEQA defines “Tribal cultural resources” to include any resource determined to be “significant” to a California Native American tribe based on the criteria in Public Resources Code section 5024.1(c). (Pub. Res. Code § 21074, subd. (a)(2).) Those criteria, indicating potential eligibility for the California Register of Historical Resources, include:

 Association with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;  Association with the lives of persons important in our past;  Embodiment of distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; and
 Potential to yield information important in prehistory or history. (Pub. Res. Code § 5024.1, subd. (c).)

Satisfaction of any one criterion suffices to meet the definition. (Id.) A cultural landscape meeting any of the criteria likewise “is a tribal cultural resource to the extent that the landscape is geographically defined in terms of the size and scope of the landscape.” (Pub. Resources Code § 21074, subd. (b).) The project qualifies as a tribal cultural resource under several of the criteria.

As explained in Yocha Dehe’s comments on the EA, the project site is “within the ancestral lands of our Patwin people, between the historic villages of Aguasto and Suskol.” (Yocha Dehe Comments on EA at 5.) Patwin Indigenous Knowledge explains the spiritual and cultural significance of Patwin peoples’ connection to their ancestral lands—and the grave harm inflicted upon a tribe like Yocha Dehe should another non-Patwin tribe be allowed to establish its tribal headquarters on those lands. (Id. at 7.) The Full Buildout 8 Id.; City Council Resolution No. 25-105 N.C. Approving an Agreement with the County of Solano for Law Enforcement Services and Authorizing the City Manager to Execute Same (June 17, 2025). 10 would bulldoze the site known as CA-SOL-275, a known and recorded Patwin cultural site important to stonework, creation of ceremonial beads, and traditional commerce in the region. (Id.; Exhibit A to Yocha Dehe Comments on EA – ECORP Consulting, Inc. Peer Review at 15-18.) CA-SOL-275 is part of a broader network of Patwin sites located in the hills north of Vallejo, warranting protection as a tribal cultural resource landscape.

We reiterated our concerns about Scotts Valley’s project adversely impacting cultural resources and our connection to our Patwin ancestral land in our March 2, 2026 letter. But the City neglected to even include this letter in the agenda packet materials, let alone respond to it in any meaningful way.

This evidence shows that project site satisfies several of the listed criteria in Public Resources Code section 5024.1(c). The landscape is associated with Patwin cultural heritage that contributed to pre-contact economic patterns and exchange systems constituting California’s earliest history. It also embodies distinctive characteristics of the time period and has potential to yield information important to prehistory and history. If the City had considered the significance of these resources to Yocha Dehe and other Patwin tribes, as dictated by Public Resources Code section 21074(a)(2), it would have become clear that it qualifies as a tribal cultural resource.

The City has made no effort to consult with Yocha Dehe regarding the impacts of this project at all. The City turns a blind eye to the cultural injury threatened by this project despite the fact that Yocha Dehe is the most likely descendent of Native American human remains found in Vallejo and Solano County – failure that is all the more notable since the City previously recognized, in connection with a commercial project on these same parcels known as “Solano Ranch,” the importance of proper consultation and consideration of Patwin cultural resource concerns.

D. Historical Resource Impacts

The impacts to tribal cultural resources discussed at length above further provides a separate basis that reliance on CEQA exemptions is improper. CEQA Guidelines section 15300.2(f) says that a categorical exemption “shall not be used for a project which may cause a substantial adverse change in the significance of a historical resource.” For the reasons described above, this project threatens significant adverse effects to tribal cultural resources, which are themselves significant historical resources. Therefore, subsection (f) of exemption exceptions provides an independent basis that reliance on CEQA exemptions is prohibited.

11 V. The City Impermissibly Relies on Mitigation to Support a Categorical Exemption

The Staff Report admits that approval of the Project would cause impacts that require mitigation. (Staff Report at 5; see also id. at 1 [“Staff have analyzed the potential impacts of the requested services and find that the City has capacity to serve the limited temporary use, provided that certain mitigations are implemented.”].) But there is no such thing as a “mitigated categorical exemption.” Just the opposite, in fact – if mitigation is needed, a categorical exemption cannot be used. “If a project may have a significant effect on the environment, CEQA review must occur and only then are mitigation measures relevant. . . . Mitigation measures may support a negative declaration but not a categorical exemption.” (Salmon Protection & Watershed Network v. County of Marin (2004) 125 Cal.App.4th 1098, 1102 [internal citations omitted and emphasis added].) While we can certainly understand the City’s desire to be compensated for providing utilities, services, and infrastructure, a negative declaration or environmental impact report would be needed to address the potential impacts of those actions.

VI. The City Has Failed to Respond to Yocha Dehe’s Comments

Yocha Dehe has repeatedly expressed concern regarding the possibility of an MOU between the City and Scotts Valley, including in letters dated December 9, 2025, and again on March 2, 2026. Both letters contain inquiries and evidence directly relevant to the Project. But when the City released the agenda package for the Project, neither letter was anywhere to be found. They appear to have been ignored – and certainly the City has provided no response. Failure to consider contrary evidence amounts to an abuse of agency discretion under CEQA. (Pub. Res. Code § 21168.5; see Berkeley Hillside Preservation v. City of Berkeley (2015) 60 Cal.4th 1086, 1105 [“An agency presented with such evidence [of significant impacts] must determine, based on the entire record before it—including contrary evidence regarding significant environmental effects—whether there is an unusual circumstance that justifies removing the project from the exempt class.”].) For this reason, too, the Project should not be approved.

VII. The City Has Not Complied With Other Legal Requirements

The City has also failed to comply with other requirements. In attempting to escape CEQA compliance, City Staff claim the Project will be outside of municipal jurisdiction.

But neither the City nor Scotts Valley has complied – or even attempted to comply – with Water Code and Government Code provisions requiring Local Agency Formation Commission (“LAFCO”) review and approval of expanding municipal services beyond jurisdictional boundaries. Indeed, it is doubtful whether Scotts Valley could comply with 12 applicable law given (among other things) the serious questions about whether its casino uses comply with federal law and the fact that the only water infrastructure arguably within relevant parcels consists of storage and transmission lines.

In fact, extension of City services would require a General Plan amendment – both because the Project is an integral part of a development that would impermissibly convert open space, contrary to Planning and Zoning Law and LAFCO standards, and because even the initial phase of that development would conflict with applicable planning and zoning designations. And General Plan amendment, in turn, would require extensive proceedings and analysis, including S.B. 18 compliance – none of which has even been initiated.

Action Item 9.B Memorandum of Understanding with Scotts Valley Bank of Pomo Indians proposed edits

1. MOU Section 2.1.3 (h)
SVBPI shall comply with the terms of all easements on the Tribal Property, including but not limited to restrictions on grading, location of structures and other improvements in relation to such easements, and shall reimburse the City for any and all damages to any improvements located on the Tribal Property or on City Property upon which water improvements serving the Tribal Property currently or hereafter exist. SVBPI shall install the following improvements to the satisfaction of the City: Roadway improvements upon the City’s access easement including but not limited to: compacted gravel improvements for the full width of the City’s easement from Columbus Parkway to the boundary of the Subject Property; Two lockable gates, first gate to be located at the proposed parking lot entry and the second gate to be located at the top perimeter of the Subject Property and signage on gate prohibiting parking on the easement or in any way blocking gate access.

The City shall be provided unfettered access on the full length and width of its easement including keys or other unassisted access to all gates.

2. Exhibit E 5 (b)
For the Temporary Development, the City will apply its existing commercial water rate, consistent with commercial development within the City. The rate structure applied herein shall not establish or imply any precedent for future phases of development or long-term water service, which will be subject to separate agreement.

3. 2.1.1. (c)
(c) SVBPI shall employ security personnel or contract for private security on the Tribal Property 24 hrs. a day, 7 days a week. In addition, SVBPI shall install at least one Automatic Lense Plate Reader (FALCON) and (CONDOR) camera through FLOCK and Security camera towers and shall share access to all data with the City of Vallejo Police Department.

4. EXHIBIT D

Community Benefit Contribution
(3) SVBPI shall provide $100,000 per annum for local charitable organizations whose work is conducted within Vallejo, California. The parties shall meet and confer on where the funds are allocated.

SVBPI Shall provide a one-time payment to the City of the cost to fill all pot-holes on Columbus Parkway between the frontage of Tribal Property of APN 1820-20-010 completely through the intersection of Ascot Parkway. Such amounts shall be paid to the City within 30 days of the City providing costs from the contractor.

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