Plymouth Casino Comment Letter

The Ione Band of Miwok have recently issued the environmental document on their proposed Casino project outside of Plymouth.  The Foothill Conservancy has written the following comment letter on the project.

2/26/2024

Sarah Dutchke

Tribal Chairperson

Ione Band of Miwok 

 

Chair Dutchke,

The Foothill Conservancy would like to offer the following comments on the Tribal Initial Study-Mitigated Negative Declaration for the Plymouth Casino Project currently in circulation. As part of our local environment advocacy work we often review such documents and offer suggestions to improve protections for the local environment and community.

We found that several sections of the document have either limited or dated information and suggest updating the analysis and project information so that the effectiveness of the mitigation measures can be fully evaluated. 

On the issue of traffic, Mitigation measure 3.17 E calls for Village Drive to either be aligned with Randolph Street or to only allow the southern intersection of Village Drive and Hwy 49 to have access to the project site. Measure 3.19 A calls for the widening of Village Drive to add a turn lane. These measures lack enough detail to evaluate, and would be improved with a diagram or more detailed plans of what is intended. We urge the Ione Band to solidify road improvement plans in cooperation with the City of Plymouth, the Amador County Transportation Commission, and CalTrans and update the document as needed.  

The project site plan shows the removal of the Shenandoah Inn, which contains most of the existing hotel beds in Plymouth. The loss of these hotel rooms without replacement could result in increased car traffic as visitors must travel in from other hotel locations, in Jackson, Sutter Creek and Amador City. A mitigation measure in the form of a casino-hotel shuttle service could alleviate the traffic and associated vehicle emissions.

In section 3.10 B, the analysis of the casino project’s ability to meet its water needs relies on well information from the 2009 Final Environmental Impact Statement (EIS), which, as detailed in Appendix D, relied on a 2004 well study. This estimate of onsite well capacity is based on information now twenty years old, during which time the region has undergone several long droughts. Updated well information is needed to properly evaluate the casino project’s impact on groundwater supplies. 

On the issue of public services, mitigation measures 3.15 J and 3.15 L describe mitigation payments to County Fire and Police services, respectively, but the document gives no details as to how much payments would be or how they would be calculated, thus we cannot evaluate if impacts to public safety from the casino are addressed.

The Conservancy welcomes the proposed design, as detailed in the project description, that is compatible with the natural and rural characteristics of the site, uses natural construction material and native, drought-tolerant plants in the landscaping, and is designed to minimize off-site lighting. We urge the Ione Band to consult with the existing City of Plymouth Scenic Corridor Design Guidelines (2014) which shares many of these design principles and would provide compatibility between the casino project and new construction in the Plymouth commercial core.

We also note that this casino project is dramatically smaller than the one outlined in the 2009 EIS and have concerns that the project represents a first phase of an eventually much larger project. Is the current proposed reduced casino project expected to be financially viable, or will it require further expansions? How will any future expansion of the casino be handled in the process outlined by the 2020 State Gaming Compact?

As this project moves forward we urge the Ione Band as well as the County of Amador and City of Plymouth to work together through the intergovernmental agreement process outlined in the 2020 State Gaming Compact to address the issues in this letter as well as all of those identified in the IS-MND. If any clarification is needed or you wish to discuss this further, please feel free to call me at 209-223-3508 or by email at craig@foothillconservancy.org.

Thank you for the opportunity to comment on your proposal,

 

Craig Baracco

Executive Director

Foothill Conservancy

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Leslie Smith, Sutter Creek, CA: Raised in Washington State, Leslie is a happy California transplant having moved to Sunny Sutter Creek full time in 2020. As a nascent fly fisher and lifelong skier, she is committed to the natural environment and brings extensive organizational and finance experience to the board from a nearly 40 year career in banking.