SECTION 4.0 ENVIRONMENTAL CONSEQUENCES

Transcription

1 SECTION 4.0 ENVIRONMENTAL CONSEQUENCES

2 SECTION 4.0 ENVIRONMENTAL CONSEQUENCES 4.1 INTRODUCTION This section describes the environmental consequences that would result from the development of the alternatives. The analysis presented in this section has been prepared in accordance with the Council on Environmental Quality s (CEQ) National Environmental Policy Act (NEPA) Regulations Section The direct environmental effects of each alternative are provided under the resource headings described in Section 3 and listed below. This section also provides analysis of growth-inducing and indirect effects in Section 4.14, as well as cumulative effects in Section Section Resource Area/Issue 4.2 Geology and Soils 4.3 Water Resources 4.4 Air Quality 4.5 Biological Resources 4.6 Cultural and Paleontological Resources 4.7 Socioeconomics Conditions 4.8 Transportation/Circulation 4.9 Land Use 4.10 Public Services 4.11 Noise 4.12 Hazardous Materials 4.13 Aesthetics 4.14 Indirect and Growth-Inducing Effects 4.15 Cumulative Effects Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

3 4.2 GEOLOGY AND SOILS This section identifies the direct effects associated with geology and soils that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section 3.2. Cumulative and indirect effects are identified in Section 4.15 and Section 4.14, respectively. Measures to mitigate for adverse effects identified in this section are presented in Section ALTERNATIVE 1 PROPOSED CASINO RESORT AND MIXED-USE PROJECT Topography The topography of the project site is irregular with rocky outcroppings, shallow depressions, and enclosed basins. The project site exhibits hummocky topography on the northwest quadrant, and gentle slopes in the other three quadrants, with a wide flat saddle traversing the property from the southwest to the northeast corner. The main entrance to the project site would be located at a low point along Highway 2, with the bulk of the development located in the center of the site. Alternative 1 would involve approximately 117 acres of clearing and grubbing of the first eight inches of topsoil. Topographic features of the site would be altered by earthwork. The preliminary grading plan for Alternative 1 is included in Appendix F (Drawing 1). Grading would consist primarily of excavating soil for project components and filling where cut slopes necessitate additional leveling. As discussed in the Grading and Drainage Analysis Report (Hahn, 2011b; Appendix F), Alternative 1 would balance onsite cut and fill, with the exception of approximately 78,370 cubic yards of structural fill that will be imported to meet engineering requirements for roadways, parking areas and building footings. While some cut-and-fill slopes would be noticeable on the project site, the project design would preserve the most significant topographic features by avoiding approximately13.25 acres in the northwest corner of the project site. In addition, the finished grade would not be completely level, preserving some of the existing slopes. Development of Alternative 1 would result in a less than significant effect on topography. No mitigation is required. Soils/Geology Alternative 1 could impact soils due to erosion during construction, operation, and maintenance activities. Such activities include clearing, grading, trenching, and backfilling. The majority of the soils on the project site have a slight to moderate erosion susceptibility based on soil type and slope gradients. Table in Section 3.2, Geology and Soils describes the soil types, erosion potential, and general gradients for each of the soil units on the site. According to the preliminary grading and drainage plan (Appendix F), the soils on the project site are particularly susceptible to wind erosion. Disturbance of the soils could result in loss of topsoil and a degradation of air quality through wind erosion. Sediment discharge into navigable (surface) waters of the U.S. is prohibited by the Federal Clean Water Act (CWA) (1972, with modifications in 1977, 1981, and 1987), which establishes water quality goals for Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

4 sediment control and erosion prevention. One of the mechanisms for achieving the goals of the CWA is the National Pollutant Discharge Elimination System (NPDES) permitting program, administered by the United States Environmental Protection Agency (EPA). As part of the NPDES General Construction permit, a Stormwater Pollution Prevention Plan (SWPPP) must be prepared and implemented. The SWPPP must make provisions for (1) erosion prevention and sediment control; and (2) control of other potential pollutants. Construction of Alternative 1 would disturb more than 1 acre; therefore the Tribe is required by the CWA to obtain coverage under, and comply with the terms of the NPDES General Construction Permit. Mitigation measures are presented in Section to reduce any potential impacts to less than significant. With regulatory requirements and best management practices described therein, effects from implementation of Alternative 1 on soils and geology would be minimal and, therefore, less than significant. Seismicity Construction of the casino and associated facilities would not be significantly affected by seismic hazards, as the area has low liquefaction and ground acceleration characteristics (WADNR, 2011). Since no known fault traces are mapped in the vicinity, the potential for surface rupturing along an on-site fault trace is low and should not be considered a constraint for Alternative 1. Additionally, the Tribe has committed in its gaming compact with the State of Washington to develop the property consistent with the Uniform Building Code (UBC, now the International Building Code), which includes provisions for design and construction of structures in each seismic zone. Impacts from seismicity under Alternative 1 would be less than significant. No mitigation is required. Mineral Resources Alternative 1 would not adversely affect known or recorded mineral resources. Alteration in the land use would not result in a loss of economically viable aggregate rock or diminish the extraction of important ores or minerals. Because there are no known or mapped mineral resources within the site, development and use of the land would not affect such resources. There are no abandoned mines, shafts, or tailings that would affect development. Project-related impacts to mineral resources under Alternative 1 are less than significant. No mitigation is required ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Topography As with Alternative 1, Alternative 2 would involve substantial clearing and grading. Topographic features of the site would be altered by earthwork. Grading would consist primarily of excavating for project components and filling where cut slopes necessitate additional leveling. As discussed in the Grading and Drainage Analysis Report (Appendix F), Alternative 2 would balance on-site cut and fill with the exception of approximately 78,730 cubic yards of structural fill that will be imported to meet engineering requirements for roadways, parking areas and building footings. The Preliminary Grading Plan for Alternative 2 is included in Appendix F. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

5 While some cut-and-fill slopes would be noticeable on the project site, the most significant topographic feature, (13.25 acre wetland area in the northwest corner of the site) would be preserved. Development of Alternative 2 would result in a less than significant impact on topography. No mitigation is required. Soils/Geology Alternative 2 could adversely affect soils due to erosion during construction, operation, and maintenance activities. Such activities include clearing, grading, trenching, and backfilling. The majority of the soils at the project site have a slight to moderate erosion potential based on soil type and slope gradients. Table in Section 3.2, Geology and Soils describes the soil types, erosion potential, and general gradients for each of the soil units on the site. As with Alternative 1, Alternative 2 would also require a NPDES permit from the EPA for sediment control and erosion prevention into navigable (surface) waters of the U.S. As part of the General Construction NPDES permit, a SWPPP must be developed and include provisions for (1) erosion prevention and sediment control and (2) control of other potential pollutants. Mitigation measures are presented in Section to reduce any potential impacts to less than significant. With incorporation of the regulatory requirements and best management practices described therein, effects from implementation of Alternative 2 on soils and geology would be minimal and, therefore, less than significant. Seismicity Construction of the casino and associated facilities would not be significantly affected by seismic hazards, as the area has low liquefaction and ground acceleration characteristics (WADNR, 2011). Since no known fault traces are mapped in the vicinity, the potential for surface rupturing along an on-site fault trace is low and should not be considered a constraint for Alternative 2. Additionally, the Tribe has committed in its gaming compact with the State of Washington to develop the property consistent with the UBC (now the International Building Code), which includes provisions for design and construction of structures in each seismic zone. Impacts from seismicity under Alternative 2 are would be less than significant. No mitigation is required. Mineral Resources Alternative 2 would not adversely affect known or recorded mineral resources. Alteration in the land use would not result in a loss of economically viable aggregate rock or diminish the extraction of important ores or minerals. Because there are no known or mapped mineral resources within the site, development and use of the land would not affect such resources. There are no abandoned mines, shafts, or tailings that would affect development. Project-related impacts to mineral resources under Alternative 2 are less than significant. No mitigation is required. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

6 4.2.3 ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Topography Alternative 3 would involve clearing and grading as part of the construction of project components. Topographic features of the site would be altered by earthwork. Grading would consist primarily of excavating for project components and filling where cut slopes necessitate additional leveling. As discussed in the Grading and Drainage Analysis Report (Appendix F), Alternative 3 would result in equal on-site cut and fill with the exception of approximately 78,730 cubic yards of structural fill that will be imported to meet engineering requirements for roadways, parking areas and building footings. The preliminary grading plan for Alternative 3 is included in Appendix F. While some cut-and-fill slopes would be noticeable on the project site, the major topographic features (i.e., hills and slopes) would be preserved. Development of Alternative 3 would result in a less than significant effect on topography. Soils/Geology Alternative 3 could adversely affect soils due to erosion during construction, operation, and maintenance activities. Such activities include clearing, grading, trenching, and backfilling. The majority of the soils at the project site have a slight to moderate erosion potential based on soil type and slope gradients. Table in Section 3.2, Geology and Soils describes the soil types, erosion potential, and general gradients for each of the soil units on the site. As with Alternatives 1 and 2, Alternative 3 would also require an NPDES permit from the EPA for sediment control and erosion prevention into navigable (surface) waters of the U.S. As part of the General Construction NPDES permit, a SWPPP must be developed and include provisions for (1) erosion prevention and sediment control; and (2) control of other potential pollutants. Mitigation measures are presented in Section to reduce any potential impacts to less than significant. With incorporation of regulatory requirements and best management practices described therein, effects from implementation of Alternative 3 on soils and geology would be minimal and, therefore, less than significant. Seismicity Construction of the casino and associated facilities would not be significantly affected by seismic hazards, as the area has low liquefaction and ground acceleration characteristics (WADNR, 2011). Since no known fault traces are mapped in the vicinity, the potential for surface rupturing along an on-site fault trace is low and should not be considered a constraint for Alternative 3. Additionally, the Tribe has committed in its gaming compact with the State of Washington to develop the property consistent with the UBC (now the International Building Code), which includes provisions for design and construction of structures in each seismic zone. Impacts from seismicity under Alternative 3 would be less than significant. No mitigation is required. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

7 Mineral Resources Alternative 3 would not adversely affect known or recorded mineral resources. Alteration in the land use would not result in a loss of economically viable aggregate rock or diminish the extraction of important ores or minerals. Because there are no known or mapped mineral resources within the site, development and use of the land would not affect such resources. There are no abandoned mines, shafts, or tailings that would affect development. Project-related impacts to mineral resources under Alternative 3 are less than significant. No mitigation is required ALTERNATIVE 4 NO ACTION/NO DEVELOPMENT Under the No Action/No Development Alternative, no development would occur on the project site. The site would remain in its current state. Topographic features and soils would remain undisturbed. No landform, soil, or seismic effects would occur as a result of the No Action/No Development Alternative Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

8 4.3 WATER RESOURCES This section identifies the direct effects to water resources anticipated to result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section 3.3. Indirect effects associated with off-site construction and growth-inducement are identified in Section Cumulative effects are identified in Section Measures to mitigate for potentially adverse effects identified in this section are presented in Section ALTERNATIVE 1 PROPOSED CASINO RESORT AND MIXED-USE DEVELOPMENT Surface Water Flooding The project site is located outside the 100-year and 500-year floodplains. Therefore, Alternative 1 would not impede or redirect flood flows, alter floodplain elevations, or affect floodplain management. No impacts from flooding are expected to occur as a result of Alternative 1. Construction Impacts Construction activities under Alternative 1 would include ground disturbing activities such as clearing and grubbing, mass grading, and excavation, which could lead to erosion of topsoil. Erosion from construction sites can increase sediment discharge to surface waters during storm events thereby degrading downstream water quality. Construction activities would also include the routine use of potentially hazardous construction materials such as concrete washings, oil, and grease, which may spill onto the ground and be dissolved in stormwater. Discharges of pollutants, which include grease, oil, fuel and sediments, to surface waters from construction activities and accidents are a potentially significant impact. Implementation of mitigation measures presented in Section would reduce or prevent adverse effects to the local and regional watershed from construction activities. Stormwater Runoff Stormwater discharges from residential, commercial, and industrial areas are of concern in managing surface water quality. Pollutants that accumulate in dry periods such as oil and grease, asbestos, pesticides, and herbicides, may create water quality problems due to their presence in high concentrations during the first major storm event of the season. Development of the casino and hotel facilities, and other ancillary components, would generate increased runoff during rain events due to an increase impervious surfaces on the site by approximately 103 acres, which would increase stormwater run-off. A grading and drainage analysis for the project alternatives has been completed and is included in Appendix F. As described in Appendix F, stormwater runoff under Alternative 1 would be directed into on-site stormwater control facilities sized to accommodate excess water draining from impervious surfaces. These vegetated swales are part of the Low Impact Development (LID) techniques recommended by the U.S. Environmental Protection Agency (EPA) for reducing impacts to surface water quality (EPA, 2012). All stormwater would be retained onsite and percolate into groundwater; no runoff would be discharged offsite (Appendix F). In accordance with the Intergovernmental Agreement (IGA, Appendix C) between the Tribe, the County, and the City, stormwater facilities have been designed consistent with the Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

9 City of Airway Heights Public Works Standards. The Guidelines for Stormwater management were replaced by the Spokane Regional Stormwater Manual (SRSM) in June The SRSM meets or exceeds applicable criteria from the WSDOE s Stormwater Management Manual for Eastern Washington (Spokane County etc., 2008). The proposed stormwater control facilities, which include several vegetated detention swales (Figure 2-4), would contain all stormwater on-site. No discharge to waters of the U.S. would occur, either through non-point source stormwater runoff or through point source discharge of stormwater from a culvert or outfall. Accordingly, there would be no impact to offsite drainages and no pollutants would be discharged to the Lower Spokane River; therefore, the project would not contribute to the exceedance of established total maximum daily loads (TMDLs). No additional mitigation beyond the use of LID techniques described in Section 2.0 of the EIS is required. Groundwater Development of Alternative 1 would not require the use of on-site groundwater supplies as water would be provided pursuant to a services agreement with the City discussed in Section 4.10, Public Services. Therefore, because new wells would not be developed, there would be no impact to existing wells in the immediate vicinity of the site. The City obtains its primary water supply from groundwater. At full buildout, Alternative 1 would require approximately 205,570 gallons per day of potable water. The City has agreed to provide potable water service to the project and has indicated it has sufficient capacity under existing conditions. Wastewater generated by Alternative 1 would also be treated off-site by the City as discussed in Section The City s Water Reclamation Plant uses percolation ponds as a means of disposal for treated wastewater. Although, some water would be lost through evaporation and evapotranspiration prior to percolating into the groundwater through wastewater disposal/ reuse methods at the WTRRF, the importation of surface water into the basin through the existing agreement with the City of Spokane, and the subsequent treatment and disposal of this water though percolation and irrigation into the groundwater further adds to the groundwater recharge and offsets water demands from the Proposed Project. Therefore, the increased drawdown of groundwater associated with water demand from Alternative 1 would be off-set by groundwater re-charge from the use of percolation ponds. The conversion of undeveloped land to commercial uses introduces large areas of impermeable surfaces such as paved parking lots and new roads. The introduction of these surfaces can reduce groundwater recharge in areas where surface percolation accounts for a large percentage of natural recharge, such as the Airway Heights paleochannel, resulting in the lowering of the groundwater levels in nearby wells. Although the development of Alternative 1 would introduce large areas of impermeable surfaces, the use of detention ponds for storing stormwater would allow collected stormwater to percolate into the groundwater table. No accumulated stormwater would be discharged offsite. Therefore, the introduction of impermeable surfaces on the project site would not have an adverse impact on groundwater levels. Groundwater Quality Runoff from project facilities could flush trash, debris, oil, sediment, and grease that accumulate on impervious surfaces into stormwater runoff. Fertilizers used in landscaped areas could also accumulate in stormwater if over applied. Although stormwater would not flow offsite and impact surface water quality, the detention swales would percolate some of the accumulated stormwater into the shallow Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

10 unconfined alluvial aquifer, potentially transporting dissolved chemical contaminants into the groundwater. As noted in the Grading and Drainage Report prepared by Hahn Engineering (Appendix F), several features designed to filter surface runoff have been incorporated into the project design in accordance with the Airway Heights Public Works Standards as required by the IGA. These features include the use of stormwater detention basins to remove suspended solids such as trash, sediment, and other potential materials that could degrade water quality. Use of vegetative swales would provide additional filtering by capturing sediment and pollutants within the soil matrix. Thus, the impact to ground water quality from stormwater runoff would be less than significant. Mitigation measures are presented in Section that would further reduce the potential for stormwater runoff to impact water quality. Wastewater generated by Alternative 1 would be treated and disposed through connection to the City s sewer system. The City s new Wastewater Treatment, Reclamation, and Recharge Facility (WTRRF) would discharge treated wastewater to percolation ponds, which could indirectly affect groundwater quality. These effects are discussed in Section 4.14, Indirect and Growth Inducing Effects ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Surface Water Impacts to surface water, including flooding and construction impacts, stormwater runoff, and wastewater, as a result of the development of Alternative 2 would be similar to those of Alternative 1 as both alternatives are similar in design. However, Alternative 2 has a smaller development footprint than Alternative 1. Approximately 20 less acres of impervious surfaces would be created under Alternative 2, for a total of approximately 83 acres. Similarly, stormwater detention basins and runoff control structures differ in size and placement between the two alternatives. However, just as under Alternative 1, a degradation in stormwater quality as a result of the increase in impervious surfaces could impact groundwater quality. The design of the stormwater facilities incorporates the water quality control measures used for Alternative 1. These vegetated swales are part of the LID techniques recommended by the EPA for reducing impacts to surface water quality (EPA, 2012). These measures would ensure that impacts to stormwater quality are minimized. Mitigation measures are presented in Section that would further reduce stormwater runoff impacts to water quality, ensuring they remain less than significant. Groundwater Impacts to groundwater supply and quality as a result of the development of Alternative 2 would be similar to those of Alternative 1 as both alternatives are similar in design and would be provided water and wastewater services by the City. As with Alternative 1, Alternative 2 would increase impervious surfaces, thereby decreasing direct recharge to groundwater on the project site. However, stormwater would be collected on-site and percolated into groundwater through detention basins, therefore returning groundwater recharge on site to pre-development levels. The operation of Alternative 2 would have a less than significant effect on groundwater levels. However, as with Alternative 1, the increase in impervious surfaces may cause contaminants to collect in stormwater, which may eventually reach groundwater. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

11 Mitigation measures are presented in Section to ensure impacts to groundwater quality from stormwater recharge remain less than significant ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Surface Water Alternative 3 is a non-gaming alternative; however, the entire site would be developed with retail land uses in a similar manner as under Alternative 1. Alternative 3 would result in the development of 103 acres of impervious surfaces similar to Alternative 1. Impacts to surface water, including flooding and construction impacts, stormwater runoff and wastewater, as a result of the development of Alternative 3 would be similar to Alternative 1. Groundwater As with Alternatives 1 and 2, on-site groundwater supplies would not be developed as water and wastewater services will be provided by the City. Stormwater that infiltrates into the ground through the proposed detention basins would be sufficiently filtered by the soil prior to reaching the nearest groundwater aquifer used by nearby wells. Therefore, the operation of Alternative 3 would have a less than significant effect on groundwater quality. Mitigation measures are presented in Section to ensure impacts to groundwater quality from stormwater recharge remain less than significant ALTERNATIVE 4 NO ACTION/NO DEVELOPMENT Under the No Action/No Development Alternative, no development of any kind would occur on the project site. No change in land use is proposed, and the site would remain in its current state. Surface water would continue to runoff in sheet flow towards existing depressions onsite, and no impervious surfaces would be added. Groundwater would not be affected by percolation of channelized stormwater, and no groundwater would be extracted to serve the project. No mitigation is required. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

12 4.4 AIR QUALITY This section identifies the direct effects to air quality that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section 3.4. Indirect and cumulative effects are identified in Section 4.14 and Section 4.15, respectively. Measures to mitigate for adverse effects identified in this section are presented in Section METHODOLOGY Development and operation of the Alternatives would emit criteria pollutants, hazardous air pollutants (HAPs), and greenhouse gases (GHGs). During construction, criteria pollutants, HAP and GHG emissions from earth-moving activities, diesel-fueled trucks, and construction equipment would occur. During operation criteria pollutants, HAP and GHG emissions from patron, worker, delivery vehicles, and onsite stationary sources (boilers) would occur. This section presents the methodology used to assess the affected environment and to evaluate the potential air quality effects of the proposed Alternatives. Construction Analysis Construction would entail mass earthwork, fine grading, construction, and road construction. A mixture of trucks, scrapers, excavators, and graders would be used to complete each phase. Effects on air quality during construction were evaluated by estimating the amount of pollutants that would be emitted over the duration of the construction period (for each phase where applicable). Particulate matter is the primary pollutant of concern resulting from earth-moving activities. Volatile organic compounds (VOC), nitrogen oxides (NO x ), sulfur dioxide (SO 2 ), and carbon monoxide (CO) emissions from the construction of Alternatives 1, 2, and 3 would primarily be produced by dieselfueled equipment use. The majority of these emissions would be from on and off-road truck use at the project site. Emissions from diesel-fueled trucks and construction equipment were calculated using EPA approved emission factors from 2007 Off-Road air quality model (Offroad, 2007). A detailed list of the proposed equipment and emissions resulting from the equipment is located in Appendix T. The majority of the respirable particulate matter 10 microns in size (PM 10 ) emissions would result from the fugitive dust generated during earth-moving activities, such as site grading. Air quality model Emission Factor (EMFAC) 2007 emission factors were used to estimate PM 10 project related emissions (EMFAC, 2007) from equipment exhaust and fugitive dust. EMFAC s PM 10 emissions factor is 38.2 pounds per acre-day and the PM 2.5 emissions factor is based on 28 percent of the PM 10 s emission factor. Actual particulate matter emissions from dust generation can vary day to day, depending on level of activity, specific operations, mitigation measures, and weather conditions. Emissions were estimated assuming that construction would begin in 2012 and continue at an average rate of 22 days per month for all Alternatives. For this analysis grading for Alternative 1, Phase I, is estimated to last 5 months; Phase II, 3 months; and Phase III, 5 months. Alternatives 1, 2, and 3 total construction durations were estimated to be 18 months, 14 and 21 months, respectively. Emissions results are summarized below and included in Appendix T. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

13 Operational Analysis Emission factors in grams per vehicle miles traveled (g/vmt) were estimated for patron vehicles during January and July (winter and summer) and evaluated using EPA s model MOBILE6.2 (EPA, 2003). MOBILE6.2 calculates emission factors for gasoline-fueled and diesel-fueled light-duty vehicles, trucks, heavy-duty vehicles, and motorcycles. The model accounts for progressively more stringent tailpipe emission standards over the vehicle model years evaluated. MOBILE6.2 model input data is site specific and the output data is provided in Appendix T. Mobile Source Emissions Emissions of PM 10, NO x, SO 2, CO, VOC, and CO 2 from vehicles traveling to, from, and within the alternative project sites were calculated for each alternative. Calculations were based on emission factors derived from the EPA s MOBILE 6.2 air quality model (EPA, 2003), trip estimations developed using the ITE Trip Generation Manual, and estimated number of patrons for the project alternatives. Emissions factors for SO 2 were derived from the EPA s AP 42 and used to estimate project related SO 2 emissions (EPA, 1995). Stationary Source Emissions For each of the project alternatives, natural gas would be used as fuel for hot water boilers, space heating, domestic water heaters, steam boilers for food service, cooking equipment, laundry equipment, and swimming pool heaters. Based on casino/hotel and recreational facilities of similar or greater size, annual gas usage for Alternative 1, Phase I is estimated at 130 million standard cubic feet (MMscf), Phase II is estimated at 160 MMscf, and Phase III is estimated to be 240 MMscf of natural gas use. Since Alternative 2 is the same as Phase I of Alternative 1, the natural gas use is estimated to be 130 MMscf per year. Alternative 3 is similar in size to Alternative 1, Phase III; therefore, natural gas use is estimated at 240 MMscf. Emissions from natural gas combustion are calculated using emission factors from AP-42 (EPA, 1995). Federal General Conformity Conformity regulations apply to Federal actions that would cause emissions of criteria air pollutants above certain levels to occur in locations designated as non-attainment or maintenance areas for the emitted pollutants. As discussed in Section 3.4 the project site is located in an area that is classified as attainment or unclassifiable for all National Ambient Air Quality Standards (NAAQS), therefore a federal general conformity determination analysis is not required for the proposed alternatives. Carbon Dioxide Hot Spot Analysis Implementation of the project alternatives would result in emissions of CO. Because CO disperses rapidly with increased distance from the source, emissions of CO are considered localized pollutants of concern rather than regional pollutants, and can be evaluated by Hot Spot Analysis. In accordance with the Transportation Project-Level Carbon Monoxide Protocol, Hot Spot Analysis is conducted on intersections that after mitigation would have a level of service (LOS) of E or F (UC Davis, 1997). After Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

14 the implementation of recommended mitigation for the project alternatives, no intersection would have an LOS or an increase in delay that would warrant a Hot Spot Analysis. No further analysis is needed. Climate Change The Council on Environmental Quality (CEQ) recently provided guidance on integrating analysis of GHGs in NEPA documents (see Section 3.4). As directed by the CEQ Guidance, this EIS considers whether project emissions have individual or cumulative effects on climate change. Given the global nature of climate change impacts, individual project impacts are most appropriately addressed in terms of the incremental contribution to a global cumulative impact (provided in Section 4.15). This approach is consistent with the view articulated by the Intergovernmental Panel on Climate (IPCC) Change Fourth Assessment Report (IPCC, 2007). Therefore, refer to Section 4.15 for a discussion and analysis of cumulative impacts related to climate change. Federal Class I Area If any alternative emits greater than the Prevention of Significant Deterioration (PSD) threshold of 250 tons per year (tpy) of any one criteria pollutant from stationary sources during construction or operation then a best available control technology (BACT) analysis will be conducted. For this analysis, emissions from construction will be considered a stationary source, because they will generally occur from one area, the project site. Tribal New Source Review The Tribe would be required to apply for a permit under the newly implemented minor new source review requirements of the CAA if stationary source operational emissions of regulated pollutants would exceed the thresholds presented in 40 CFR , Table 1. Table 1 of 40 CFR provides the following applicable emission thresholds for stationary sources in an attainment area: CO 10 tpy; NOx 10 tpy; SOx 10 tpy; VOC 5 tpy; PM 10 5 tpy; and PM tpy ALTERNATIVE 1 PROPOSED CASINO RESORT AND MIXED-USE DEVELOPMENT Construction Emissions Construction of Alternative 1 would emit PM 10, NO x, SO 2, CO, VOC, GHGs, and Hazardous air pollutants (HAPs) primarily in the form of diesel particulate matter (DPM) from the use of construction equipment and grading activities. Emissions from construction equipment have the potential to increase the concentration of DPM in the close vicinity (within approximately 500 feet) of the construction site, if control measures are not implemented. Phase I construction is anticipated to begin in 2012 and last approximately 18 months. Phase II construction is anticipated to begin in 2015 and last approximately 14 months. Phase III construction is anticipated to begin in 2019 and last approximately 21 months. Construction for all Phases is assumed to occur 8-hours a day, 5 days a week. The construction emission totals for the Alternative 1 are shown in Table Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

15 The project site is in a region of attainment for all criteria pollutants; therefore, in accordance with 40 CFR 93, construction of the proposed project would not cause an exceedance of National Ambient Air Quality Standards (NAAQS). As shown in Table 4.4-1, no criteria pollutant is emitted in a quantity greater than the PSD threshold of 250 tpy; therefore, no BACT analysis is warranted and construction of Proposed Project would not impact air quality within the Spokane Tribe s Reservation which is designated as a Federal Class I area. Best management practices (BMPs) provided in Section would minimize construction related emissions of criteria pollutants. BMPs provided in Section would also reduce DPM emissions from construction equipment by approximately 85 percent, avoiding potentially adverse effects to nearby sensitive receptors. Currently the Federal Air Rules for reservations (FAR) do not apply on off-reservation trust lands; however the EPA is planning to revise the rule to include off-reservation emission sources. If the EPA promulgates a final rule before the project begins construction then the Tribe would be required to file a dust plan with the EPA within 30 days of beginning construction. The dust plan would include the dust control BMPs provided in Section Therefore, with mitigation, construction of Alternative 1 would not result in significant adverse effects associated with the regional air quality environment. TABLE CONSTRUCTION EMISSIONS ALTERNATIVE 1 Criteria Pollutants Construction Year VOC NOx CO SOx PM 10 PM 2.5 tons per year Phase I Total Emissions Phase II Total Emissions Phase III Total Emissions Maximum Phase Emissions Source: EPA, Mobile 6.2, Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

16 Operational Vehicle and Area Emissions Buildout of Alternative 1 would result in the generation of mobile emissions from patron, employee, and delivery vehicles, as well as stationary emissions from combustion of natural gas in boilers, stoves, heating units, and other equipment on the project site. Estimated mobile and stationary emissions from operation of Alternative 1 are provided in Table Detailed calculations of vehicle and area emissions are included as Appendix T. TABLE OPERATION EMISSIONS - ALTERNATIVE 1 Criteria Pollutants Sources NOx VOC CO SOx PM 10 PM 2.5 tons per year Phase I Stationary Mobile Total Emissions Phase I and II Stationary Mobile Total Emissions Phases I, II, and III Stationary Mobile Total Emissions Notes: N/A = Not Applicable; de minimus levels are not applicable due to attainment status (Refer to Section 3.4). Source: EPA, Mobile6.2, The project site is in a region of attainment for all criteria pollutants. Under the federal Clean Air Act 40 CFR Part 93, if a region is in attainment for all criteria pollutants, then the region meets the NAAQS and there are no de minimis levels or thresholds for a project s emissions. The project site is located two miles east of a maintenance area for PM10 and CO. Indirect emissions from vehicles traveling through the maintenance area to the project site could contribute to poor air quality conditions in this area. As shown in Table 4.4-2, no criteria pollutant is emitted in a quantity greater than the PSD threshold of 250 tpy; therefore, no BACT analysis is warranted and the Proposed Project would not impact air quality within the Spokane Tribe s Reservation which is designated as a Federal Class I area. As shown in Table emissions of individual criteria pollutants from stationary sources would not exceed the FAR Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

17 threshold of two tons per year. As shown in Table 4.4-2, operational emissions would not exceed the minor new source review thresholds and therefore, an associated minor new source permit would not likely be required. However, if the EPA promulgates class specific guidelines or regulations which require that the Tribe obtain a minor NSR permit, then the Tribe would apply for and obtain a minor NSR permit in accordance with the EPA guidelines and NSR regulations. Mitigation provided in Section would minimize criteria air pollutant emissions from operation of Alternative 1. With mitigation measures to minimize emissions of criteria pollutants, Alternative 1 would not result in significant adverse effects associated with the regional air quality environment. General Conformity Determination Conformity regulations apply to Federal actions that would cause emissions of criteria air pollutants above certain levels to occur in locations designated as non-attainment or maintenance areas for the emitted pollutants. If project-related emissions from a Federal action occurs in a location designated as attainment or unclassified, then the general conformity regulation does not apply to the Proposed Project; however, if project-related emissions occur in a nonattainment or maintenance area then general conformity regulation would apply. Since project-related indirect emissions from vehicle travel would occur in the adjacent maintenance area, a general conformity analysis will be conducted prior to federal action ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Construction Emissions Construction emissions for Alternative 2 would be from the same sources as Phase I of Alternative 1. Alternative 2 construction is anticipated to begin in 2012 and last approximately 18 months. Construction emission totals for the Alternative 2 are shown in Table The project site is in a region of attainment for all criteria pollutants; therefore, in accordance with 40 CFR 93, construction of Alternative 2 would not cause an exceedance of NAAQS. As shown in Table 4.4-3, no criteria pollutant is emitted in a quantity greater than the PSD threshold of 250 tpy; therefore, no BACT analysis is warranted. BMPs, provided in Section would further reduce construction related emissions of criteria pollutants. BMPs provided in Section would also reduce approximately 85 percent of DPM emissions from construction equipment. Currently the FAR does not apply on offreservation trust lands; however the EPA is planning to revise the rule to include off-reservation emission sources. If the EPA promulgates a final rule before the project begins construction then the Tribe would be required to file a dust plan with the EPA within 30 days of beginning of Alternative 2 construction. The dust plan would include the dust control BMPs provided in Section Therefore, with mitigation, Alternative 2 would not result in significant adverse effects associated with the regional air quality environment. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

18 TABLE CONSTRUCTION EMISSIONS ALTERNATIVE 2 Criteria Pollutants Construction Year VOC NOx CO SOx PM 10 PM 2.5 tons per year Maximum Years Emissions Source: EPA, Mobile 6.2, Operational Vehicle and Area Emissions Buildout of Alternative 2 would result in the generation of mobile emissions from patron, employee, and delivery vehicles, as well as stationary emissions from combustion of natural gas in boilers and other equipment on the project site. Estimated mobile and stationary emissions from operation of Alternative 2 are provided in Table Detailed calculations of vehicle and area emissions are included as Appendix T. TABLE OPERATION EMISSIONS - ALTERNATIVE 2 Criteria Pollutants Sources VOC NOx CO SOx PM 10 PM 2.5 tons per year Stationary Mobile Total Emissions Notes: N/A = Not Applicable; de minimus levels are not applicable due to attainment status (Refer to Section 3.4). Source: EPA, Mobile6.2, The project site is in a region of attainment for all criteria pollutants. Under the federal Clean Air Act 40 CFR Part 93, if a region is in attainment for all criteria pollutants, then the region meets the NAAQS and there are no de minimis levels or thresholds for a project s emissions. As shown in Table 4.4-4, no criteria pollutant is emitted in a quantity greater than the PSD threshold of 250 tpy; therefore, no BACT analysis is warranted. As shown in Table individual criteria pollutants from stationary sources do not exceed the FAR threshold of two tons per year. As shown in Table 4.4-4, operational emissions would not exceed the minor new source review thresholds and therefore, an associated minor new source Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

19 permit would not likely be required. However, if the EPA promulgates class specific guidelines or regulations which require that the Tribe obtain a minor NSR permit, then the Tribe would apply for and obtain a minor NSR permit in accordance with the EPA guidelines and NSR regulations. Mitigation provided in Section would minimize criteria air pollutant emissions from operation of Alternative 2. With mitigation measures to minimize emissions of criteria pollutants, Alternative 2 would not result in significant adverse effects associated with the regional air quality environment. General Conformity Determination As discussed in Section 3.4 the project site is located in an area that is in attainment for all NAAQS; therefore, Alternative 2 is not subject to a conformity determination; however, since operational projectrelated vehicle emissions would occur in the adjacent maintenance area, a general conformity determination will be conducted prior to federal action ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Construction Emissions Construction of Alternative 3 would similar to construction of Alternative 1. Refer to Section Alternative 3 construction is anticipated to begin in 2012 and last approximately 21 months. Construction for Alternative 3 is assumed to occur 8-hours a day, 5 days a week. Construction emission totals for the Alternative 3 are shown in Table TABLE UNMITIGATED CONSTRUCTION EMISSIONS ALTERNATIVE 3 Criteria Pollutants Construction Year VOC NOx CO SOx PM 10 PM 2.5 tons per year Maximum Years Emissions Source: EPA, Mobile 6.2, The project site is in a region of attainment for all criteria pollutant; therefore, in accordance with 40 CFR 93, construction of Alternative 3 would not cause an exceedance of the NAAQS. As shown in Table 4.4-5, no criteria pollutant is emitted in a quantity greater than the PSD threshold of 250 tpy; therefore, no BACT analysis is warranted. BMPs, provided in Section would further reduce project related criteria pollutants. BMPs provided in Section would also reduce approximately 85 percent of DPM emissions from construction equipment. Currently the FAR does not apply on off-reservation trust lands; however the EPA is planning to revise the rule to include off-reservation emission sources. If the EPA promulgates a final rule before the project begins construction then the Tribe would be required to file a dust plan with the EPA within 30 days of beginning of Alternative 3 construction. The dust plan would Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

20 include the dust control BMPs provided in Section Therefore, with mitigation, construction of Alternative 3 would not result in significant adverse effects associated with the regional air quality environment. Operational Vehicle and Area Emissions Buildout of Alternative 3 would result in the generation of mobile emissions from patron, employee, and delivery vehicles, as well as stationary emissions from combustion of natural gas in boilers and other equipment on the project site. Estimated mobile and stationary emissions from operation of Alternative 3 are provided in Table Detailed calculations of vehicle and area emissions are included as Appendix T. The project site is in a region of attainment for all criteria pollutants. Under the federal Clean Air Act 40 CFR Part 93, if a region is in attainment for all criteria pollutants, then the region meets the NAAQS and there are no de minimis levels or thresholds for a project s emissions. As shown in Table 4.4-6, no criteria pollutant is emitted in a quantity greater than the PSD threshold of 250 tpy; therefore, no BACT analysis is warranted. As shown in Table individual criteria pollutants from stationary sources do not exceed the FAR threshold of two tons per year. As shown in Table 4.4-6, operational emissions would not exceed the minor new source review thresholds and therefore, an associated minor new source permit would not likely be required. However, if the EPA promulgates class specific guidelines or regulations which require that the Tribe obtain a minor NSR permit, then the Tribe would apply for and obtain a minor NSR permit in accordance with the EPA guidelines and NSR regulations. Mitigation provided in Section would minimize criteria air pollutant emissions from operation of Alternative 3. With mitigation measures to minimize emissions of criteria pollutants, Alternative 3 would not result in significant adverse effects associated with the regional air quality environment. TABLE UNMITIGATED OPERATION EMISSIONS - ALTERNATIVE 3 Criteria Pollutants Sources VOC NOx CO SOx PM 10 PM 2.5 tons per year Stationary Mobile Total Emissions Notes: N/A = Not Applicable; de minimus levels are not applicable due to attainment status (Refer to Section 3.4). Source: EPA, Mobile6.2, General Conformity Determination As discussed in Section 3.4 the project site is located in an area that is in attainment for all NAAQS; therefore, Alternative 2 is not subject to a conformity determination; however, since operational project- Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

21 related vehicle emissions would occur in the adjacent maintenance area a general conformity determination will be conducted prior to federal action ALTERNATIVE 4 NO ACTION/NO DEVELOPMENT Under the No Action/No Development Alternative, no development would occur on the project site. No construction or operational mobile or stationary criteria pollutants or DPM emissions would be generated under this Alternative. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

22 4.5 BIOLOGICAL RESOURCES This section identifies the effects to biological resources that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section 3.5. Cumulative and indirect effects are identified in Section 4.15 and Section 4.14, respectively. Measures to mitigate for adverse effects identified in this section are presented in Section ALTERNATIVE 1 PROPOSED CASINO AND MIXED USE DEVELOPMENT Potential Effects to Habitats Table provides a summary of the acreage of each habitat type that would be affected under Alternative 1. As shown in this table, Alternative 1 would affect approximately acres of habitat within the project site. None of the habitats that would be affected by the implementation of Alternative 1 are considered sensitive communities. TABLE ANTICIPATED EFFECTS TO HABITAT TYPES ALTERNATIVE 1 Habitat Type Acres Disturbed Areas Dry, Open Grassland Seasonally Wet Grassland/Meadow 1.88 Shrub -- Aspen Forest -- Vernal Wetlands -- Total Source: AES, 2011; AECOM, 2010 Potential Effects to Federally Listed Species No federal listed wildlife species occur within the project site. Therefore, Alternative 1 would result in no effect to federally listed wildlife species. One federal listed plant has a low potential to occur within the northwestern portion of the project site: Spalding s silene. As described in Section 3.5.2, based on the negative findings of Spalding s silene during the focused botanical surveys conducted within the property during two years where known populations of Spalding s silene were in bloom at the Fairchild AFB, this species does not occur within the 145-acre property. Therefore, no additional surveys or mitigation are required. Alternative 1 would result in no effect to Spalding s silene. Potential Effects to Migratory Birds Migratory birds and other birds of prey protected under the Migratory Bird Treaty Act (50 CFR 10) have the potential to nest within the proposed project footprint. If active nests are present in these areas, tree removal and other construction activities associated with construction of Alternative 1 could result in impacts to these species. Implementation of mitigation identified in Section 5.2.4, including conducting a Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

23 preconstruction survey prior to construction commencement, would reduce the potential for the proposed project to adversely affect active nests of migratory birds and other birds of prey within the project site. Potential Effects to Wetlands and/or Waters of the U.S. A wetland delineation report was prepared for the project site and is included in Appendix H (AECOM, 2009). The delineation identifies 0.70 acres of vernal wetlands within the project site, which are considered isolated features. The USACE issued a Jurisdictional Determination on May 17, 2011, confirming that the wetlands located within the project site are not jurisdictional waters of the U.S. and thus are not subject to regulation by the federal government under the Clean Water Act (CWA) (Appendix H). The proposed project footprint associated with Alternative 1 was designed to avoid the vernal wetlands, and therefore will have no effect on these habitat features ALTERNATIVE 2 REDUCED CASINO AND MIXED USE DEVELOPMENT Potential Effects to Habitats Table provides a summary of the acreage of each habitat type that would be affected under Alternative 2. As shown in this table, Alternative 2 would affect approximately acres of habitat project site. None of the habitats that would be affected by the implementation of Alternative 2 are considered sensitive communities. TABLE ANTICIPATED EFFECTS TO HABITAT TYPES ALTERNATIVE 2 Habitat Type Acres Disturbed Areas Dry, Open Grassland Seasonally Wet Grassland/Meadow 1.03 Shrub -- Aspen Forest -- Vernal Wetlands -- Total Source: AES, 2011; AECOM, 2010 Potential Effects to Federally Listed Species No federal listed wildlife species occur within the project site. Therefore, Alternative 2 would result in no effect to federally listed wildlife species. Spalding s silene was determined not to occur on the project site; therefore, Alternative 2 would result in no effect to Spalding s silene. Potential Effects to Migratory Birds Construction activities associated with Alternative 2 could result in impacts to nesting birds. Implementation of mitigation identified in Section 5.2.4, including conducting a preconstruction survey prior to construction commencement, would reduce the potential for the proposed project to adversely affect active nests of migratory birds and other birds of prey within the project site. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

24 Potential Effects to Wetlands and/or Waters of the U.S. There are no jurisdictional Waters of the U.S. located within the project site. Alternative 2 would have no effect on the non-jurisdictional vernal wetlands located within the project site ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Potential Effects to Habitats Table provides a summary of the acreage of each habitat type that would be affected under Alternative 3. As shown in this table, Alternative 3 would affect the same acreage as Alternative 1; acres. None of the habitats that would be affected by the implementation of Alternative 3 are considered sensitive communities. TABLE ANTICIPATED EFFECTS TO HABITAT TYPES ALTERNATIVE 3 Habitat Type Acres Disturbed Areas Dry, Open Grassland Seasonally Wet Grassland/Meadow 1.88 Shrub -- Aspen Forest -- Vernal Wetlands -- Total Source: AES, 2011; AECOM, 2010 Potential Effects to Federally Listed Species No federal listed wildlife species occur within the project site. Alternative 3 would have no effect on federal listed wildlife species. T Spalding s silene was determined not to occur on the project site; therefore, Alternative 3 would result in no effect to Spalding s silene. Potential Effects to Federally Listed Migratory Birds Construction activities associated with Alternative 3 could result in impacts to nesting birds. Implementation of mitigation identified in Section 5.2.4, including conducting a preconstruction survey prior to construction commencement, would reduce the potential for the proposed project to adversely affect active nests of migratory birds and other birds of prey within the project site. Potential Effects to Wetlands and/or Waters of the U.S. There are no jurisdictional Waters of the U.S. located within the project site. Alternative 3 would have no effect on the non-jurisdictional vernal wetlands located within the project site. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

25 4.5.4 ALTERNATIVE 4 NO ACTION/ NO DEVELOPMENT Under Alternative 4, no project-related activities would occur on within project site. The project site would remain in trust and land would remain in its existing condition. Therefore, the No Action/ No Development Alternative would have no effect on the habitats, federal listed plants or wildlife, migratory birds, or jurisdictional waters of the U.S. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

26 4.6 CULTURAL AND PALEONTOLOGICAL RESOURCES This section identifies the direct effects to cultural resources that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section 3.6. Cumulative and indirect effects are identified in Section 4.15 and Section 4.14, respectively. Measures to mitigate for adverse effects identified in this section are presented in Section ALTERNATIVE 1 PROPOSED CASINO AND MIXED-USE DEVELOPMENT Cultural Resources An archaeological investigation of the project area (Appendix I) revealed one previously unrecorded cultural resource consisting of historic debris within the project site. The site plan for Alternative 1 completely avoids this resource. Therefore, Alternative 1 will result in No Historic Properties Affected. The Spokane Tribal Historic Preservation Officer has concurred with this determination in a letter dated July 18, 2011 (Appendix I). Indirect effects associated with off-site infrastructure improvements are discussed in Section 4.14, Indirect Effects. There is a slight possibility that previously unknown cultural resources will be encountered during ground disturbing activities. This would be a potentially significant impact. Mitigation measures are presented in Section for the treatment of unanticipated archaeological discoveries. Therefore, the project will not result in significant adverse effects to unknown archaeological resources. Paleontological Resources No paleontological resources have been reported or observed on or in the vicinity of the project site. Therefore, Alternative 1 would not result in significant adverse effects to known paleontological resources. There is a low possibility that previously unknown paleontological resources would be discovered during earthmoving activities. Mitigation measures are presented in Section for the treatment of unanticipated paleontological discoveries. Therefore the Alternative 2 would not result in significant adverse effects to previously unknown paleontological resources ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Cultural Resources The cultural resources investigation of the project area resulted in the recordation of one previously undocumented cultural resource (Appendix I). The project design for Alternative 2 clearly avoids this resource. Therefore, Alternative 2 will not result in significant adverse effects to known historic properties. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

27 There is always the possibility that previously unknown archaeological resources will be encountered during construction activities. This would be a potentially significant impact. Mitigation measures are presented in Section for the treatment of unanticipated cultural resources discovered during project related construction. With the implementation of these mitigations measures, the project would not result in significant adverse effects to previously unknown paleontological resources. Paleontological Resources As with Alternative 1, no paleontological resources have been reported or observed on or in the vicinity of the Project Site. Therefore, the project will not result in significant adverse effects to known paleontological resources under Alternative 2. There is a potential for previously undocumented paleontological resources to be discovered during construction activity. This would be a potentially significant impact. Mitigation measures are presented in Section for the treatment of unanticipated paleontological discoveries. Thus, the project will not result in significant adverse effects to previously undocumented paleontological resources under Alternative ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Cultural Resources One previously undocumented cultural resource consisting of historic debris was discovered during the course of the cultural resources investigation of the project site (Appendix I). As with Alternative 1 and 2, the current project design of Alternative 3 avoids this resource. Therefore, Alternative 3 will not result in significant adverse effects to known archaeological resources. There is always the possibility that previously unrecorded cultural resources will be encountered during construction activities. This would be a potentially significant impact. Mitigation measures are presented in Section for the treatment of unanticipated archaeological discoveries. As a result the project would not result in significant adverse effects to known archaeological resources under Alternative 3. Paleontological Resources As with Alternative 1, no paleontological resources have been reported or observed on or in the vicinity of the project site. Therefore, Alternative 3 would not result in significant adverse effects to previously known paleontological resources. There is a potential for unrecorded, subsurface paleontological resources to be discovered during heavy ground-disturbing activity. This would be a potentially significant impact. Mitigation measures are presented in Section for the treatment of unanticipated paleontological discoveries. Therefore the project would not result in significant adverse effects to previously unrecorded paleontological resources. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

28 4.6.4 ALTERNATIVE 4 NO ACTION/ NO DEVELOPMENT The No Action/No Development Alternative and will not result in significant adverse effects to cultural or paleontological resources. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

29 4.7 SOCIOECONOMIC CONDITIONS This section identifies socioeconomic effects anticipated to result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section 3.7. Cumulative and specific indirect effects are identified in Section 4.14 and Section 4.15, respectively. Measures to avoid, minimize, and mitigate for adverse effects identified in this section are presented in Section Assessment Criteria Socioeconomic Impacts To determine the potential effects of the alternatives associated with socioeconomic conditions, the economic effects of temporary construction and ongoing operational activities of each alternative were measured. Because socioeconomic effects would be most pronounced in the vicinity of the project site, the scope of analysis focuses on impacts to the site and surrounding Spokane County. Impacts from construction would be a one-time occurrence, while those from operation would be generated continuously after opening. An adverse economic, fiscal, or social impact would occur if the effect of the project were to negatively alter the ability of governments to perform at existing levels, or alter the ability of people to obtain public health and safety services. Much of the analysis presented herein relies on data presented in the Spokane Tribe of Indians West Plains Mixed-Use Development Economic Impact and Growth Inducing Study (Economic Impact Study) included as Appendix J (AES, 2011b), as well as the Economic Background Study and Competitive Effects Analysis included as Appendix G (Innovation Group, 2011). Economic effects in this analysis are quantified for Spokane County using the Impact Analysis for Planning (IMPLAN) model. Environmental Justice Impacts To determine the impacts of the alternatives on environmental justice, the location and status of minority and low-income communities of concern, as identified in Section 3.7, are compared to the effect and nature of an alternative s impacts. An adverse environmental justice impact would result if any impact within the scope of this document disproportionately affected an identified minority or low-income community or Native American tribe. Final Guidance for Incorporating Environmental Justice Concerns in EPA s NEPA Compliance Analyses provides the following direction on how to analyze the impacts of actions on low-income and minority populations: Under NEPA, the identification of a disproportionately high and adverse human health or environmental effect on a low-income population, minority population, or Indian tribe does not preclude a proposed agency action from going forward, nor does it necessarily compel a conclusion that a proposed action is environmentally unsatisfactory. Rather, the identification of such an effect should heighten agency attention to alternatives (including alternative sites), mitigation strategies, monitoring needs, and preferences expressed by the affected community or population (EPA, 1998). Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

30 4.7.1 ALTERNATIVE 1 PROPOSED CASINO AND MIXED-USE DEVELOPMENT Economic Effects Expenditures on goods and services for construction and operational activities would generate substantial direct economic output, as well as indirect and induced economic output. Output is defined as the total value of all goods and services produced at the establishment or construction site. Direct output would result from money spent on activities for construction and operational activities of the project. Indirect output would result from expenditures on goods and services by businesses that receive funds directly from the construction and operation of Alternative 1. Induced output would result from expenditures on goods and services by employees directly generated from construction and operation of Alternative 1. Construction Expenditures on goods and services from the construction of Alternative 1 were calculated from estimated costs for construction, investment in furniture, fixture and equipment (FF&E), various business and consulting fees, and pre-opening expenses. Construction of the first phase of Alternative 1 is anticipated to begin in 2012, and the first full year of operation of Class III gaming is anticipated to occur in The second and third phases are anticipated to begin operation in 2016 and 2020, respectively. Under Alternative 1, construction activities are estimated to cost approximately $404.3 million, which is expected to generate a one-time total output of approximately $301.9 million within the County (Table 4.7-1). Direct output is estimated to total approximately $190.1 million, of which approximately $185.9 million (98 percent) is attributed to the construction industry. Indirect and induced outputs were estimated to total $46.2 million and $65.6 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. TABLE ONE-TIME CONSTRUCTION ECONOMIC IMPACT (MILLIONS) Construction Alternative Development Budget $404.3 $160.0 $256.1 Direct Output (Industry) Construction $185.9 $73.9 $134.0 Manufacturing $1.2 Wholesale Trade $2.9 $2.0 $10.1 Direct Total $190.1 $76.7 $144.1 Other Output Indirect $46.2 $18.6 $35.2 Induced $65.6 $26.3 $49.4 Total Output $301.9 $121.6 $228.7 Note: Though numbers appear to be estimated to the nearest dollar, accuracy is not indicated to that level due to rounding. Due to rounding, numbers may not add up to equal the number given in the Total. Source: AES, 2011b; Projections are presented in 2011 dollars Construction of Alternative 1 would generate substantial output to a variety of businesses in Spokane County. Output received by Spokane County businesses would in turn increase their spending, and labor demand, thereby further stimulating the local economy. This would be considered a beneficial impact. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

31 Operation Expenditures on goods and services from the operation of Alternative 1 were calculated from revenue projections for the first complete year of operation under buildout conditions, currently estimated to be Under full buildout conditions, the projected revenue for the gaming and hotel component of Alternative 1 is estimated to be approximately $141.2 million and the total estimated annual number of patrons is approximately 2,823,056 (Warner Gaming, 2011). Approximately $94.5 million in additional revenue would be generated at the retail establishments located at the project site (Civic Economics, 2009, included as Appendix U of the Final EIS; AES, 2011b). New spending from the proposed project is expected to generate a net annual total output of approximately $249.3 million within the County (Table 4.7-2). Direct output is estimated to total approximately $161.6 million, of which approximately $100.6 million (62 percent) would be attributed to the gaming and entertainment industry. Indirect and induced outputs were estimated to total $37.5 million and $50.1 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. TABLE ANNUAL OPERATIONAL ECONOMIC IMPACT (MILLIONS) Operation Alternative Direct Output (Industry) Entertainment & Recreation $100.6 $70.7 $4.6 Retail Trade $37.2 $16.4 $26.7 Accommodation & Food Services $23.9 $8.5 $39.6 Direct Total $161.6 $95.7 $70.8 Other Output Indirect $37.5 $22.6 $16.4 Induced $50.1 $28.7 $24.4 Total Output $249.3 $147.0 $111.6 Note: Though numbers appear to be estimated to the nearest dollar, accuracy is not indicated to that level due to rounding. Due to rounding, numbers may not add up to equal the number given in the Total. Source: AES, 2011b; Projections are presented in 2011 dollars Operation of Alternative 1 would generate increased revenues for a variety of businesses in Spokane County as a result of increased economic activities. Output received by Spokane County businesses would in turn increase their spending, and labor demand, thereby further stimulating the local economy. This would be considered a beneficial impact. No mitigation is required. Substitution Effects Potential substitution effects (the loss of customers at existing commercial businesses to the new business) of Tribal casinos on existing restaurant, recreation, and retail establishments must be considered when attempting to determine the true magnitude of the casino s impact on the economy. The magnitude of the substitution effect can generally be expected to vary greatly by specific location and according to a Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

32 number of variables. That is, how much of the casino s revenue comes at the expense of other business establishments in the area depends on how many and what type of other establishments are within the same market area as the casino, disposable income levels of local residents and their spending habits, as well as other economic and psychological factors affecting the consumption decisions of local residents. Existing Tribal Casino Gaming Market Substitution Effects An analysis of the potential substitution effects of Alternative 1 on other local gaming facilities based on the gaming market and the distance, size, and quality of nearby facilities was conducted and is included as Appendix G of the EIS (Innovation Group, 2011). The analysis included collecting background information and developing a gaming market gravity model. The gravity model is based on an assessment of overall gaming revenues supported by population, incomes, typical win per visit and casino gaming participation both nationally and in the Pacific Northwest. As indicated by the study, existing regional gaming facilities with the greatest potential to be affected by the project include: Northern Quest Casino located approximately two miles from the project site, Couer D Alene Casino Resort located approximately 33 miles from the project site, Two Rivers Casino located approximately 38 miles from the project site, and Chewelah Casino located approximately 40 miles from the project site (Innovation Group, 2011; Appendix G). The Two Rivers and Chewelah Casinos are owned and operated by the Spokane Tribe; therefore any potential impacts of the proposed project to these casinos would be offset by the anticipated revenue generated for the Spokane Tribe at the project site. The study concluded that the anticipated gaming revenue substitution effect in 2015 from the operation of Alternative 1 (Phases I, II, and III) would be approximately 36.8 percent of total projected gaming revenue for the Spokane gaming market (Innovation Group, 2011; Appendix G). Anticipated substitution effects would not result in the closure of any of the competing gaming facilities. In fact, it is likely that existing regional casinos would continue to generate significantly positive cash flows. As stated in Appendix G, Spokane is sufficiently large to support three casinos of the magnitude of Northern Quest and Coeur D Alene (Innovation Group, 2011; Appendix G). Moreover, any anticipated substitution effects are likely to diminish after the first year of the project s operation and once local residents experience the casino and return to more typical spending patterns. It is important to note that the addition of a casino in Spokane County would be likely to expand the gaming market for the region as a whole. Therefore, substitution effects resulting from Alternative 1 to competing gaming facility revenues would not impact the ability of the Kalispell or Coeur D Alene tribal government to provide essential services and facilities to its membership. Please refer below to a detailed discussion of potential impacts to the Kalispel tribal government from the substitution effects which would occur as a result of Alternative 1. Non-Gaming Substitution Effects A retail market study was conducted in order to analyze retail development opportunities for the project site (Civic Economics, 2009; Appendix U of the Final EIS). The retail market study concluded that the site could support the retail proposed under Alternative 1. According to a 2000 Harvard University study, worst-case non-gaming substitution effects occurring in rural environments as a result of Native American casinos have shown on average a nine percent decrease in earnings at local restaurants and bars and an increase in earnings in other commercial sectors (Taylor et. al, 2000). Because the project site is Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

33 not located in a rural area as defined by the U.S. Census Bureau, it may be inferred that if substitution occurs it would be at some percentage lower than nine percent. Additionally, potential non-gaming substitution effects would be counteracted by the local economic activity generated by casino patrons other than local residents. Specifically, as the casino would draw non-residents to the area, the associated increase in new visitor demand for off-site entertainment venues, restaurants, and bars would make up for some area residents choosing to visit Alternative 1 rather than other local establishments. Appendix V provides a detailed discussion of numerous studies in addition to the Harvard study that have determined the introduction of gaming establishments into a community does not permanently substitute for other expenditures. Thus, in light of the substantial body of research summarized in Appendix V, it is not anticipated that significant quantifiable non-gaming substitution effects would occur as a result of Alternative 1. Tax Revenues Alternative 1 would result in a variety of fiscal impacts. Since tribes are sovereign nations, they do not pay corporate income taxes on revenue or property taxes on tribal land. Alternative 1 would increase demand for public services, resulting in increased costs for local governments to provide these services. Tax revenues would be generated for federal, state and local governments from activities including secondary economic activity generated by tribal gaming (i.e., the indirect and induced effects of the economic impact analysis). The taxes on secondary economic activity include: corporate profits tax, income tax, sales tax, excise tax, property tax, and personal non-taxes, such as motor vehicle licensing fees, fishing/hunting license fees, other fees, and fines. Additionally, Section lists annual payments that would be made by the Tribe to the State and local governments in accordance with the Tribal-State Compact and local agreements. These annual payments would provide support for public services, community benefits, and utilities throughout the region. Alternative 1 would be constructed on land that is already held in trust by the federal government for the Tribe. Therefore, no property taxes would be lost. As shown in Table 4.7-3, substantial tax revenues would be generated for federal, state and local governments from economic activity associated with construction and operation of Alternative 1. Local governments include Spokane County, the City of Airway Heights, and other cities within Spokane County that would experience economic activity as a result of Alternative 1. Construction of Alternative 1 would generate one-time $8.6 million in federal tax revenues, and $6.6 million in state/county/local tax revenues. Operation of Alternative 1 would generate annually $6.3 million in federal tax revenues, and $4.7 million in state/county/local tax revenues from indirect and induced taxes. Actual annual tax revenues generated by the project may be greater than those indicated above as direct personal income tax is not accounted for in the tax revenue estimate. While tax revenues generated by existing gaming facilities would temporarily be reduced proportional to the estimated substitution effect described above, the net impact to tax revenues as a result of the Proposed Project would be positive. Summary of Economic Effects Construction and operation of Alternative 1 would generate substantial economic output for a variety of businesses in Spokane County. Additionally, Alternative 1 would generate substantial tax revenues for Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

34 state, County, and local governments. Potential effects due to the loss of state and federal tax revenues resulting from the operation as a sovereign nation on trust land would be offset by increased local, state and federal tax revenues resulting from construction and operation of Alternative 1, and from revenue sharing programs per the tribal-state compact and local agreements as outlined in Section Overall, Alternative 1 would result in a beneficial impact to the local economy in Spokane County. Jurisdiction TABLE TAX REVENUES (MILLIONS) Alternative Construction (One-Time) Federal $8.6 $3.4 $6.3 State/County/Local $6.6 $2.6 $4.9 Operation (Annually) Federal $6.3 $3.7 $2.9 State/County/Local $4.7 $2.7 $2.3 Note: Though numbers appear to be estimated to the nearest dollar, accuracy is not indicated to that level due to rounding. Due to rounding, numbers may not add up to equal the number given in the Total. The operational tax revenues indicated in the table include indirect and induced taxes only. Due to the project s unique circumstances, including the proposed location on trust land, direct tax revenues were not quantifiable. As such, actual tax revenues generated by the project may be greater than those indicated above as direct personal income tax has not been included in the totals. Source: AES, 2011b; Projections are presented in 2011 dollars. Employment Investment in construction and operational activities would generate substantial direct employment opportunities and wages, as well as indirect and induced employment opportunities and wages. The source of direct, indirect, and induced employment opportunities and wages would be similar to those industries for economic output, as discussed above in Tables and The IMPLAN model was used to estimate employment opportunities generated by Alternative 1. Construction For full buildout under Alternative 1, investment in construction activities would generate a one-time total of approximately 2,216 employment positions within the County (Table 4.7-4). The number of employment positions is equivalent to the number of person-years available from wages. A person-year is defined as the amount of labor one full-time employee can complete in a calendar year. For example, two half-time employees working for a year would constitute one person-year. Employment opportunities generated from construction and operation of Alternative 1 would result in wage generation. Wage totals include hourly and salary payments as well as benefits including health and life insurance and retirement payments. Under Alternative 1, investment in construction activities would generate one-time total wages of approximately $105.4 million within the County (Table 4.7-4). Direct wages were estimated to total approximately $68.6 million, of which approximately $65.1 million (95 percent) would be attributed to the construction industry. The generation of employment and wages during the construction phase is considered a beneficial effect of Alternative 1. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

35 TABLE ONE-TIME CONSTRUCTION EMPLOYMENT AND WAGE IMPACTS Construction Impact Alternative Employment (Person-Years) Direct (Industry) Construction 1, ,016 Manufacturing 6 4 Wholesale Trade Direct Total 1, ,076 Other Indirect Induced Total Jobs 2, ,778 Wages (Millions) Direct (Industry) Construction $65.1 $25.8 $46.9 Manufacturing $0.4 $0.2 Wholesale Trade $1.1 $0.7 $3.5 Direct Total $66.6 $26.8 $50.4 Other Indirect $15.8 $6.4 $12.0 Induced $20.0 $8.0 $15.1 Total Wages $102.4 $41.2 $77.5 Note: Though numbers appear to be estimated to the nearest dollar and/or whole number, accuracy is not indicated to that level due to rounding. Due to rounding, numbers may not add up to equal the number given in the Total. 1 Penta Building Group, 2011 Source: AES, 2011b; Projections are presented in 2011 dollars Operation Employment opportunities generated from the operation of Alternative 1 would include entry-level, midlevel, and management positions. Examples of employment opportunities typically offered by tribal casino and resort facilities are listed in Table Average salaries offered are expected to be consistent with, or greater than, those of other tribal gaming facilities, and competitive in the local labor market. TABLE TYPICAL TRIBAL CASINO EMPLOYMENT OPPORTUNITIES Casino slot operations Hotel management Food & beverage operations Financial services Table games Hotel facilities Restaurant services Support services Entertainment operations Hotel marketing Culinary services Security services Casino credit Housekeeping services Human resources Surveillance Casino administration Hotel administration Casino services Hotel services Source: AES, 2011b. As calculated through IMPLAN, operation activities associated with Alternative 1 would generate an annual total of approximately 2,805 employment opportunities to be captured within Spokane County Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

36 (Table 4.7-6). Direct employment impacts were estimated to total approximately 2,087 job opportunities (Appendix J). Indirect and induced employment opportunities were estimated to total 289 and 429, respectively, and would be dispersed and distributed among a variety of different industries and businesses throughout Spokane County. TABLE ANNUAL OPERATIONAL EMPLOYMENT AND WAGE IMPACTS Operational Impact Alternative Employment (Person-Years) Direct (Industry) Entertainment and Recreation Retail Trade 1, Accommodation and Food Services Direct Total 2,087 1,073 1,412 Other Indirect Induced Total Jobs 2,805 1,493 1,741 Wages (Millions) Direct (Industry) Entertainment and Recreation $19.8 $13.2 $1.3 Retail Trade $14.9 $6.6 $10.7 Accommodation and Food Services $5.3 $1.9 $12.6 Direct Total $39.9 $21.7 $24.6 Other Indirect $11.6 $7.1 $4.7 Induced $15.3 $8.8 $7.5 Total Wages $66.8 $37.5 $36.8 Note: Though numbers appear to be estimated to the nearest dollar and/or whole number, accuracy is not indicated to that level due to rounding. Due to rounding, numbers may not add up to equal the number given in the Total. Source: AES, 2011b; Projections are presented in 2011 dollars. 1 Warner Gaming, 2011 Operation activities associated with Alternative 1 would generate annual total wages of approximately $66.8 million within Spokane County (Table 4.7-6). Direct wages were estimated to total approximately $39.9 million, of which approximately $19.8 million (50 percent) would be attributed to the gaming and entertainment industry. Indirect and induced wages were estimated to total $11.6 and $15.3 million, respectively, and would be dispersed and distributed among a variety of different industries and businesses throughout Spokane County. The generation of employment and wages during the operation phase is considered a beneficial effect of Alternative 1. For the purposes of this analysis, it is assumed that the unemployment rate for Spokane County will follow a similar trend to what has been projected for the U.S. as described in Section 3.7, and that the County will experience a labor force of 247,434 people and an unemployment rate of 8.2 percent (20,290 people) in 2013, which is anticipated to be the first year of operation under the project (Appendix J; Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

37 Table 4.7-7). Since there are projected to be approximately 20,290 unemployed persons in the County in 2013, there are anticipated to be more than enough people available to fill the 2,805 employment positions generated by Alternative 1. Between 2013 and the project s full buildout in 2020, it is anticipated that the labor force would continue to grow as Phases II and III are developed. Therefore, 2013 labor force projections are considered to be a conservative estimate of anticipated people available for work at the project site. For reasons described above under Economic Effects, Alternative 1 is not expected to result in significant permanent job loss elsewhere due to substitution effects. TABLE PROJECTED SPOKANE COUNTY LABOR MARKET 2013 Labor Force 247,434 Unemployment 20,290 (8.2%) (Rate) Note: 2013 Labor market considers direct, indirect, and induced employment. Source: AES, 2011b. Summary of Employment Effects Construction and operation of Alternative 1 would generate substantial temporary and ongoing employment opportunities and wages that would be primarily filled by the available labor force in Spokane County. Given the projected unemployment rate, and the dynamics of the local labor market, Spokane County is anticipated to be able to easily accommodate the increased demand for labor during the operation of Alternative 1. This would result in employment and wages for persons previously unemployed and would contribute to the alleviation of poverty among lower income households. While employment opportunities at existing gaming facilities may temporarily be reduced proportional to the estimated substitution effect described above, the net impact to employment opportunities as a result of the Proposed Project would be positive. This is considered a beneficial effect. Housing Based on the information presented in Section 3.7.1, in the project s first full year of operation in 2013, the Spokane County housing market is projected to have 211,307 total units and 14,185 vacant units (Table 4.7-8). TABLE PROJECTED 2013 HOUSING MARKET Housing Units Total Units 211,307 Occupied Units 197,122 Vacant Units 14,185 % Vacant 6.7% Source: U.S. Census Bureau, ; AES, 2011b. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

38 As indicated in Table 4.7-8, more than enough vacant housing is anticipated to be available to accommodate any direct employees that might relocate to the area to accept a position at the project site. As noted in the Employment discussion above, there are anticipated to be more than enough Spokane County residents available for work to accommodate all 2,087 direct employment opportunities at the project site. Therefore, it is not anticipated that any employees of the project would require relocation in order to accept a position. However, if any employees were to relocate to Spokane County to accept a position, the number of projected vacant housing units (14,185) would be more than enough to accommodate all employees. Between the first year of operation in 2013 and the project s full buildout in 2020, it is anticipated that the housing stock, as well as vacant units, would continue to grow as Phases II and III are developed. Therefore, 2013 housing market projections are considered to be a conservative estimate of anticipated available housing units following full buildout of the project. The 718 indirect and induced employment opportunities would be dispersed among a variety of different businesses in Spokane County. Since these opportunities would be located at a variety of locations throughout Spokane County, it is expected that employees would be located in the vicinity of these locations, and would not require relocation. As discussed above, based on regional housing stock projections and current trends in Spokane County housing market data, there are anticipated to easily be more than enough vacant homes to support potential impacts to the regional labor market under Alternative 1. Therefore, Alternative 1 is not expected to stimulate regional housing development. A significant adverse impact to the housing market would not occur. Potential indirect effects resulting from growth inducement are discussed further in Section Social Effects Problem and Pathological Gambling Gambling, in one form or another, is now legal in every state except Hawaii and Utah. According to a National Gambling Impact Study Commission (NGISC) study, approximately 86 percent of Americans report having gambled at least once during their lifetimes and 63 percent of Americans report having gambled at least once during the previous year (NGISC, 1999). This estimate is based on participation in all forms of gambling including lotteries, poker, internet gambling, sports betting, and casino gambling. The American Psychiatric Association (APA) describes pathological gambling as an impulse control disorder characterized by persistent and recurrent maladaptive gambling behavior that disrupts personal, family, or vocational pursuits. The gambling pattern may be regular or episodic, and the course of the disorder is typically chronic (NGISC, 1999). The APA has established ten criteria for diagnosis of a pathological and problem gambler, which include preoccupation, tolerance, withdrawal, escape, chasing, lying, loss of control, illegal acts, risked significant relationship, and financial bailout. At-risk gaming behaviors typically meet one or two of these criteria; problem gamblers typically meet three to four of these criteria; and pathological gamblers typically meet at least five of these criteria. Collectively, both pathological and problem gambling are referred to as problem gambling. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

39 An NGISC (1999) study reported on three studies, two completed in 1997 and one completed in 1998, noted that pathological gambling often occurs in conjunction with other behavioral problems, including substance abuse, mood disorders, and personality disorders. Even if it were possible to isolate the effects of problem gambling on people who suffer from co-morbidity, it is difficult to then isolate the effects of casino gambling from other forms of gambling. As discussed, casino gambling is only one form of gaming. In fact, the most prevalent forms of gambling are those found in most neighborhoods: scratch lottery cards, lotto, and video lottery terminals. Thus, problem gamblers are likely to already exist in most communities. However, there are several recent studies that suggest that the presence of a casino results in a higher rate of resident problem and pathological gamblers than in counties without a casino. At the national level, approximately 4 percent of the adult population is considered problem or pathological gamblers. According to Grinols et al. (2000), the Las Vegas community has a problem and pathological gambler population that is nearly six percent higher than in a non-casino community. Ricardo Gazel finds in his Economic Impacts of Casino Gambling at the State and Local Level (1998) article, that the incidence of problem and pathological gamblers can be between 1 to 4 percent higher in a casino community than for the general population, depending on the type of gambling that is prevalent. He finds that communities with a higher percentage of slot machines have a higher problem and pathological gambler differential than in areas with other types of gambling. Several studies suggest that these population differentials take effect for residents within a 50 mile radius of a casino, and increase to the above mentioned rates as the casino moves closer to the population. According to Welte et al. (2004), the probability of being a problem or pathological gambler roughly doubles for those living within ten miles of a casino compared with those who do not (7.2 percent and 3.1 percent, respectively). Because four existing casinos are located within 50 miles of the project site, including the existing Northern Quest Casino located approximately two miles from the project site, there would be no anticipated significant increase to problem gambling rates in the local area. Additionally, as outlined in Section 5.2.6, the Tribe would make annual payments to the State, County, and local governments per the tribal state compact and local agreements as described in Section These annual payments would provide support for public services and community benefits, including problem gambling services, throughout the region. Thus, potential impacts to problem gambling as a result of the proposed project would be less than significant. Optional mitigation measures are recommended in Section to further reduce less than significant impacts. Crime There is a general belief that the introduction of legalized gambling into a community increases crime. However, this argument is based more on anecdotal evidence rather than empirical evidence. Casinos, by their nature, increase the volume of people entering a given area. Whenever large volumes of people are introduced into an area, the volume of crime would also be expected to increase. This is true of any largescale development. Taken as a whole, literature on the relationship between casino gambling and crime rates suggests that communities with casinos are as safe as communities without casinos. The National Opinion Research Center (NORC, 1999) found that insufficient data exists to quantify or determine the relationship between casino gambling within a community and crime rates. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

40 Alternative 1 would introduce a large number of patrons and employees into the community on a daily basis. As a result, under Alternative 1, criminal incidents would be expected to increase in the project area, particularly at the project site, as with any other development of this size. However, increased tax revenues resulting from Alternative 1 and local agreements between the Tribe, County, and City of Airway Heights would fund expansion of law enforcement services required to accommodate planned growth. Thus, Alternative 1 would not result in significant adverse effects associated with crime. Potential impacts to law enforcement services are addressed in Section 4.10, Public Services. Community Impacts Schools Employees that relocate to the project area to accept a position at the project site may increase the number of kindergarten through 12 th grade students enrolled in the Cheney School District (CSD). However, due to the limited number of employees that are expected to relocate to the project area as a result of Alternative 1, as noted in the Housing section above, it is expected that these effects would be negligible. Additionally, given that any anticipated new students would be distributed across all grade levels between kindergarten through high school, any new students that may enroll in CSD as a result of the project would be considered a nominal impact on the district. Further, if Alternative 1 were to result in the relocation of any families to the area, CSD would likely collect additional tax revenue from the families of new students and would use these taxes to hire additional teachers to meet additional demand, if necessary. Therefore, any potential increased enrollment would have a nominal effect on the ability of CSD to provide education services at existing levels. Alternative 1 would not result in adverse impacts to Spokane County schools. No mitigation is required. Libraries and Parks Effects to area libraries and parks could occur if the employees or patrons of Alternative 1 significantly increase the demand on these resources. Due to the limited number of employees that are expected to relocate to the project area, as noted in the Housing section above, it is expected that these effects would be negligible. Additionally, due to the casino/resort character of Alternative 1, it is not anticipated that patrons would frequent local libraries or parks. Therefore, there would be a less than significant effect to libraries and parks. No mitigation is required. Effects to the Spokane Indian Tribe Alternative 1 would benefit the Tribe in at least two ways. First, it would generate new income to fund the operation of the Tribal Government. This income is anticipated to have a beneficial effect on Tribal attitudes, expectations, quality of life, and culture by funding Tribal programs that serve Tribal members, including education, health care, housing, social services, and Tribally-sponsored cultural events, and by supporting Tribal self-sufficiency and self-determination. As indicated in the Spokane Tribe of Indians Unmet Needs Report, essential governmental, social, and other tribal member services that would be funded by the revenue generated under Alternative 1 include: Fire and Emergency Medical Services, a Tribal Bank Revolving Loan Program, a Food Distribution Program, Youth Centers, a Social Security and Retirement Fund, and a Scholarship Endowment / Higher Education Program, among others (AES, 2011; Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

41 Appendix A). Second, Tribal members would have access to new jobs created on the project site. Employment generated by this Alternative would not only allow Tribal members to enjoy a better standard of living, but would also provide an opportunity for Tribal members to end their dependence on government funding. As discussed in Section 3.7, Socioeconomics, approximately 47 percent of the tribal labor force is unemployed and 45.3 percent are employed but living below the poverty line. Therefore, the creation of employment opportunities is expected to benefit Tribal members as well as local taxpayers in general. The casino is projected to generate millions of dollars annually for the Tribe. According to the Indian Gaming Regulatory Act (IGRA) 25 U.S.C. Section 2710 (b)(2)(b), net revenues from any tribal gaming are not to be used for purposes other than (i) to fund tribal government operations or programs; (ii) to provide for the general welfare of the Indian tribe and its members; (iii) to promote tribal economic development; (iv) to donate to charitable organizations; or (v) to help fund operations of local government agencies. IGRA also requires that the Tribe develop a plan to use gaming revenues for these purposes, which must be approved by the Secretary of the Interior, before making any distributions to individual Tribal members. Effects to the Kalispel Indian Tribe According to information provided by the Kalispel Tribe, profit earnings from the Northern Quest Casino and related development are the primary source of income for the Kalispel Tribe. The second largest income source is federal, state, and other grants. The remainder of the income is made up from other income, such as fishing and hunting licensing fees, settlement payments, and rental and lease income. Currently, the Kalispel Tribe allocates a portion of their net income from Northern Quest directly to tribal members rather than governmental operations and programs. As described in Appendix V to the Final EIS, it was estimated that with the buildout of Alternative 1 in 2020, revenues at the Northern Quest Casino would be reduced by 33 percent when compared to future revenue projections based on the 3 percent growth rate predicted by the Kalispel Tribe in the absence of competition from the Spokane Tribe s casino (Comment Letter 23 in FEIS Volume I). Based on the analysis of comparable situations, the anticipated substitution effects (drop in annual revenue due to competition) are likely to diminish over time after the first year of each phase operation. After this period, normative revenue growth for Northern Quest is expected to resume. The 2020 revenue projections for Northern Quest with competition from Alternative 1 would represent a 13.8 percent reduction from 2011 revenues. Based on a review of financial information provided by the Kalispel Tribe, a certain portion of revenue from the Northern Quest Casino is currently allocated directly to tribal members. While these direct payments may be eliminated, the overall tribal government budget in 2020 Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

42 is not expected to be considerably reduced when compared to existing conditions (approximately 6.7 percent reduction after elimination of direct payments to tribal members). While the Kalispel tribal government s budget would be impacted by the Proposed Action, these effects are expected to dissipate over time due to market growth and would not prohibit the Kalispel tribal government from providing essential services and facilities to its membership. Environmental Justice: Minority and Low-Income Communities Subsection describes local populations near the project site that could be affected by development of Alternative 1 to determine if any minority or low-income populations exist. No low-income or minority communities, were identified through review of the demographics of Census tracts in the vicinity of the project site. However, because the project would inherently impact members of the Spokane Tribe and could potentially result in indirect effects on the Kalispel Tribe as a result of competitive effects to the Kalispel Tribe s Northern Quest Casino, the Spokane Tribe and the Kalispel Tribe have been considered minority communities that could be impacted by the Proposed Action. Effects to the Spokane Tribe and Kalispel Tribe are discussed above. Alternative 1 would not result in significant adverse effects to minority or low-income communities ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Economic Effects The direct economic effects for both construction and operation of Alternative 2 are comparable to those described for Alternative 1, but to a lesser scale since Alternative 2 is reduced in size and scope. Construction Under Alternative 2, construction activities are estimated to cost approximately $160.0 million, which is expected to generate a one-time total output of approximately $121.6 million within the County (Table 4.7-1). Direct output was estimated to total approximately $76.7 million, of which approximately $73.9 million (96 percent) would be attributed to the construction industry. Indirect and induced outputs were estimated to total $18.6 million and $26.3 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. Construction of Alternative 2 would generate substantial output to a variety of businesses in Spokane County in the industries discussed above. Output received by Spokane County businesses would in turn increase their spending, and labor demand, thereby further stimulating the local economy. This would be considered a beneficial impact. Operation Under buildout conditions in 2013, the projected revenue for the gaming component of Alternative 2 is estimated to be approximately $94.2 million and the total estimated annual number of patrons is approximately 1,883,546 (Warner Gaming, 2011). Additional revenue estimated at approximately $40.8 would also be generated at the retail establishments located at the project site (Civic Economics, 2009; Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

43 AES, 2011b). Alternative 2 is expected to generate an annual total output of approximately $147.0 million within the County (Table 4.7-2). Direct output was estimated to total approximately $95.7 million, of which approximately $70.7 million (74 percent) would be attributed to the gaming and entertainment industry. Indirect and induced outputs were estimated to total $22.6 million and $28.7, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. Operation of Alternative 2 would generate increased revenues for a variety of businesses in Spokane County as a result of increased economic activities. Output received by Spokane County businesses would in turn increase their spending, and labor demand, thereby further stimulating the local economy. This would be considered a beneficial impact. Substitution Effects Under Alternative 2 a portion of revenue may be transferred from other local businesses through substitution. As noted under Alternative 1, whenever a new casino opens in a market area, a certain amount of market cannibalization is to be expected. The anticipated gaming revenue substitution effect in 2013 from the operation of Alternative 2 would be approximately 24.1 percent of total projected gaming revenue Spokane gaming market (Innovation Group, 2011; Appendix G). Any anticipated substitution effects are likely to diminish after the first year of the project s operation and once local residents experience the casino and return to more typical spending patterns. Therefore, substitution effects resulting from Alternative 2 to competing gaming facility revenues would not impact the ability of the Kalispell or Coeur D Alene tribal government to provide essential services and facilities to its membership. Please refer below to a detailed discussion of potential impacts to the Kalispel tribal government from the substitution effects which would occur as a result of Alternative 2. Similar to Alternative 1, potential non-gaming substitution effects, should it occur, represents a negligible portion of total economic activity that would be generated by Alternative 2. Appendix V provides a detailed discussion of numerous studies in addition to the Harvard that have determined the introduction of gaming establishments into a community does not permanently substitute for other expenditures. Thus, as with Alternative 1, it is not anticipated that significant quantifiable non-gaming substitution effects would occur as a result of Alternative 2. Tax Revenues Alternative 2 would result in a variety of fiscal impacts. Similar to Alternative 1, under Alternative 2 the Tribe would not pay corporate income taxes on revenue or property taxes on tribal land. In addition, Alternative 2 would increase demand for public services, resulting in increased costs for local governments to provide these services. Tax revenues would be generated for federal, state and local governments from the same activities discussed in Alternative 1. Alternative 2 would be constructed on land that is already held in trust by the federal government for the Tribe. Therefore, no property taxes would be lost. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

44 For Alternative 2, construction activities would generate one-time tax revenues, while operational activities would generate annual revenues to the federal, state, Spokane County, and local governments. Construction would result in an estimated $3.4 million in federal tax revenues, and $2.6 million in state/county/local government tax revenues. Operation of Alternative 2 would result in an estimated $3.7 million in federal tax revenues, and $2.7 million in state/county/local government tax revenues (Table 4.7-3) from indirect and induced taxes. Actual annual tax revenues generated by the project may be greater than those indicated above as direct personal income tax is not accounted for in the operational tax revenue estimate. While tax revenues generated by existing gaming facilities would temporarily be reduced proportional to the estimated substitution effect described above, the net impact to tax revenues as a result of Alternative 2 would be positive. Similar to Alternative 1, the Tribe agrees to make annual payments to the State, County, and local governments per the tribal state compact and local agreements as described in Section The net generation of revenues to governments would be comparable but to a lesser extent than Alternative 1, and is considered a beneficial effect. Summary of Economic Effects Construction and operation of the Alternative 2 would generate substantial economic output for a variety of businesses in Spokane County. Additionally, Alternative 2 would generate substantial tax revenues for state, County, and local governments. Overall, Alternative 2 would result in a beneficial impact to the Spokane County economy. Employment Investment in construction and operational activities would generate substantial direct employment opportunities and wages, as well as indirect and induced employment opportunities and wages. The IMPLAN model was used to estimate employment opportunities generated by Alternative 2. Construction Under Alternative 2, investment in construction activities would generate a one-time total of approximately 832 employment positions within the County during the construction phase (Table 4.7-4). Indirect and induced employment opportunities were estimated to result in 148 and 225 employment opportunities, respectively. Under Alternative 2, investment in construction activities would generate one-time total wages of approximately $41.2 million within the County (Table 4.7-4). Direct wages were estimated to total approximately $26.8 million, of which approximately $25.8 million (90 percent) would be attributed to the construction industry. Indirect and induced wages were estimated to total $6.4 million and $8.0 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. The generation of employment and wages during the construction phase is considered a beneficial effect of Alternative 2. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

45 Operation As calculated through IMPLAN, operation activities associated with Alternative 2 would generate an annual total of approximately 1,493 employment opportunities captured within Spokane County (Table 4.7-6). Direct employment impacts were estimated to total approximately 1,073 job opportunities. Indirect and induced employment opportunities were estimated to total 175 and 245, respectively. Indirect and induced employment opportunities would be dispersed and distributed among a variety of different industries and businesses throughout the County. Investment in operational activities associated with Alternative 2 would generate annual total wages of approximately $37.5 million within the County (Table 4.7-6). Direct wages were estimated to total approximately $21.7 million, of which approximately $13.2 million (61 percent) would be attributed to the gaming and entertainment industry. Indirect and induced wages were estimated to total $7.1 million and $8.8 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. The generation of employment and wages during the operation phase is considered a beneficial effect of Alternative 2. Summary of Employment Effects Construction and operation of Alternative 2 would generate substantial temporary and ongoing employment opportunities and wages that would be primarily filled by the available labor force in Spokane County. This would result in employment and wages for persons previously unemployed, increasing the ability of the population to provide themselves with health and safety services and contributing to the alleviation of poverty among lower income households. While employment opportunities at existing gaming facilities may temporarily be reduced proportional to the estimated substitution effect described above, the net impact to employment opportunities as a result of the Proposed Project would be positive. This is considered a beneficial effect. Housing The 2013 County housing market as discussed under Alternative 1 would fulfill the demands for housing under Alternative 2. Indirect impacts resulting from growth inducement are discussed further in Section 4.14 and Appendix J. This impact would be comparable, but to a lesser extent than Alternative 1. Alternative 2 would not result in significant adverse effects to the housing market. Social Effects Social impacts including pathological and problem gambling, and crime from Alternative 2 would be comparable but to a lesser extent than Alternative 1, since Alternative 2 is reduced in size and scope. With implementation of the conditions of the tribal state compact and local agreements listed in Section 5.2.6, adverse social impacts would not occur. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

46 Community Impacts Schools Effects to schools would be similar to, but less than those described under Alternative 1 because Alternative 2 is reduced in size and scope. This would be considered a less than significant impact. No mitigation is required. Libraries and Parks Effects to parks and libraries would be similar to those described under Alternative 1 and, therefore, less than significant. No mitigation is required. Effects to the Spokane Indian Tribe The effects to the Spokane Indian Tribe under Alternative 2 are comparable to those described for Alternative 1, but to a lesser scale since Alternative 2 is reduced in size and scope. Alternative 2 would not generate a sufficient amount of revenue to fund all essential governmental, social, and other services indicated in the Spokane Tribe of Indians Unmet Needs Report (AES, 2011; Appendix A). Effects to the Kalispel Indian Tribe As described in detail in Appendix G of the Draft EIS, operation of Alternative 2 in 2013 is anticipated to cause a 29.5 percent reduction in gaming revenues (i.e. gaming substitution effect) at the Northern Quest Casino. As described in detail in Appendix V of the Final EIS and discussed above, based on the analysis of comparable situations, the anticipated substitution effects (drop in annual revenue due to competition) are likely to diminish after the first year of operation, once local residents experience the casino and return to more typical spending patterns. After this period, normative revenue growth for Northern Quest is expected to resume. As discussed under Alternative 1, the reduction in gaming revenue at Northern Quest from economic competition as a result of Alternative 2 would not significantly impact the Kalispel tribal government s budget to the point where it would no longer be able to provide essential services and facilities to its membership. Environmental Justice: Minority and Low-Income Communities No minority or low-income communities were identified through review of the demographics of Census tracts in the vicinity of the Project Site. However, because the project would inherently impact members of the Spokane Tribe and could potentially result in indirect effects on the Kalispel Tribe as a result of competitive effects to the Kalispel Tribe s Northern Quest Casino, the Spokane Tribe and the Kalispel Tribe have been considered minority communities that could be impacted by the Proposed Action. Effects to the Spokane Tribe and Kalispel Tribe are discussed above. Alternative 2 would not result in significant adverse effects to minority or low-income communities. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

47 4.7.3 ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Economic Effects Construction Under Alternative 3, construction activities are estimated to cost approximately $256.1 million, which is expected to generate a one-time total output of approximately $228.7 million within the County (Table 4.7-1). Direct output was estimated to total approximately $144.1 million, of which approximately $134.0 million (92 percent) would be attributed to the construction industry. Indirect and induced outputs were estimated to total $35.2 million and $49.4 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. Construction of Alternative 3 would generate substantial output to a variety of businesses in Spokane County in the industries discussed above. Output received by Spokane County businesses would in turn increase their spending, and labor demand, thereby further stimulating the local economy. This would be considered a beneficial impact. Operation Alternative 3 is expected to generate an annual total output of approximately $111.6 million within the County (Table 4.7-2). Direct output was estimated to total approximately $70.8 million, of which approximately $39.6 million (56 percent) would be attributed to the accommodation and food services industry. Indirect and induced outputs were estimated to total $16.4 million and $24.4 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. Operation of Alternative 3 would generate substantial output to a variety of businesses in Spokane County. Output received by Spokane County businesses would in turn increase their spending, and labor demand, thereby further stimulating the local economy. This would be considered a beneficial impact. Substitution Effects A retail market study was conducted by Civic Economics in 2009 in order to analyze retail development opportunities for the project site (Civic Economics, 2009; Appendix U of the Final EIS). The retail market study concluded that the site could support the retail proposed under Alternative 3. Additionally, the Innovation Group also conducted a study to evaluate potential substitution effects of Alternative 3 on other local establishments (Innovation Group, 2011; Appendix G). As concluded by the Innovation Group, Alternative 3 would not result in a measurable impact on existing retail businesses in the project area since the proposed retail square-footage would be less than the estimated retail growth opportunity in the region (Innovation Group, 2011; Appendix G). Any anticipated substitution effects are likely to diminish after the first year of the project s operation and once local residents return to more typical spending patterns. The substitution effect, should it occur, would represent a negligible portion of total economic activity that would be generated by Alternative 3. This impact would be considered less than significant. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

48 Tax Revenues Alternative 3 would result in a variety of fiscal impacts. Similar to Alternative 1, under Alternative 3 the Tribe would not pay corporate income taxes on revenue or property taxes on tribal land. In addition, Alternative 3 would increase demand for public services, resulting in increased costs for local governments to provide these services. Tax revenues would be generated for federal, state, and local governments from the same indirect and induced activities discussed in Alternative 1. Alternative 3 would be constructed on land that is already held in trust by the federal government for the Tribe. Therefore, no property taxes would be lost. For Alternative 3, construction activities would generate one-time tax revenues, while operational activities would generate annual revenues to the federal, state, Spokane County, and local governments. Construction would result in an estimated $6.3 million in federal tax revenues, and $4.9 million in state/county/local government tax revenues. Operation of Alternative 3 would result in an estimated $2.9 million in federal tax revenues, and $2.3 million in state/county/local government tax revenues (Table 4.7-3) from indirect and induced taxes. Actual annual tax revenues generated by the project may be greater than those indicated above as direct personal income tax is not accounted for in the operational tax revenue estimate. Summary of Economic Effects Construction and operation of the Alternative 3 would generate substantial economic output to a variety of businesses in Spokane County. Additionally, Alternative 3 would generate tax revenues for state, County, and local governments; however, revenue sharing benefits would not occur. Overall, Alternative 3 would result in a beneficial impact to the Spokane County economy, but to a lesser degree than Alternative 1. Employment Investment in construction and operational activities would generate substantial direct employment opportunities and wages, as well as indirect and induced employment opportunities and wages. The IMPLAN model was used to estimate employment opportunities generated by Alternative 3. Construction Under Alternative 3, investment in construction activities would generate a one-time total of approximately 1,778 employment opportunities within the County during the construction phase (Table 4.7-4). Direct output was estimated to total approximately 1,076 employment opportunities, of which approximately 1,016 (94 percent) would be attributed to the construction industry. Indirect and induced employment opportunities were estimated to result in 280 and 422 employment opportunities, respectively. Under Alternative 2, investment in construction activities would generate one-time total wages of approximately $77.5 million within the County (Table 4.7-4). Direct wages were estimated to total approximately $50.4 million, of which approximately $46.9 million (93 percent) would be attributed to Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

49 the construction industry. Indirect and induced wages were estimated to total $12 million and $15.1 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. The generation of employment and wages during the construction phase is considered a beneficial effect of Alternative 3. Operation As calculated through IMPLAN, operation activities associated with Alternative 3 would generate an annual total of approximately 1,741 employment opportunities captured within Spokane County (Table 4.6-6). Direct employment impacts were estimated to total approximately 1,412 job opportunities. Indirect and induced employment opportunities were estimated to total 120 and 209, respectively. Indirect and induced employment opportunities would be dispersed and distributed among a variety of different industries and businesses throughout the County. Under Alternative 3, investment in operational activities would generate annual total wages of approximately $36.8 million within the County (Table 4.6-6). Direct wages were estimated to total approximately $24.6 million, of which approximately $12.6 million (51 percent) would be attributed to the accommodation and food services industry. Indirect and induced wages were estimated to total $4.7 million and $7.5 million, respectively. Indirect and induced output would be dispersed and distributed among a variety of different industries and businesses throughout the County. The generation of employment and wages during the operation phase is considered a beneficial effect of Alternative 3. Summary of Employment Effects Construction and operation of Alternative 3 would generate substantial temporary and ongoing employment opportunities and wages that would be primarily filled by the available labor force in Spokane County. Given the projected unemployment rate, and the dynamics of the local labor market, Spokane County is anticipated to be able to easily accommodate the increased demand for labor during the operation of Alternative 3. This would result in employment and wages for persons previously unemployed, increasing the ability of the population to provide themselves with health and safety services and contributing to the alleviation of poverty among lower income households. This is considered a beneficial effect. Housing The 2013 County housing market would fulfill the demands for housing under Alternative 3. Indirect impacts resulting from growth inducement are discussed further in Section 4.14 and Appendix J. This impact would be comparable, but to a lesser extent than Alternative 1. Alternative 3 would not result in significant adverse effects to the housing market. Potential indirect effects resulting from growth inducement are discussed further in Section Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

50 Social Effects Social impacts including crime from Alternative 3 would be comparable Alternative 1. With implementation of the conditions of the IGA listed in Section 5.2.6, adverse social impacts would not occur. Community Impacts Schools Effects to schools would be similar to, but less than those described under Alternative 1 because Alternative 3 is reduced in size and scope. This would be considered a less than significant impact. No mitigation is required. Libraries and Parks Effects to parks and libraries would be similar to those described under Alternative 1 and, therefore, less than significant. No mitigation is required. Effects to the Spokane Indian Tribe The revenues generated by the proposed retail establishment would not be collected by the Tribe; however, the Tribe would collect revenues from leases signed by retailers. The effects to the Spokane Indian Tribe under Alternative 3 would be beneficial, but to a lesser scale than Alternative 1. Alternative 3 would not generate a sufficient amount of revenue to fund all essential governmental, social, and other services indicated in the Spokane Tribe of Indians Unmet Needs Report (AES, 2011; Appendix A). Effects to the Kalispel Indian Tribe As Alternative 3 does not include the operation of a casino, no impacts to the Northern Quest Casino would occur. The non-gaming competitive effects to the Kalispel s non-gaming businesses would be the same as discussed above. As described previously, Alternative 3 would not result in a measurable impact on existing retail businesses in the project area since the proposed retail square-footage would be less than the estimated retail growth opportunity in the region (Innovation Group, 2011; Appendix G). Therefore, Alternative 3 would not significantly impact the Kalispel tribal government s budget to the point where it would no longer be able to provide essential services and facilities to its membership. Environmental Justice: Minority and Low-Income Communities No minority or low-income communities were identified in through review of the demographics of Census tracts the vicinity of the project site. However, because the project would inherently impact members of the Spokane Tribe and could potentially result in indirect effects on the Kalispel Tribe as a result of competitive effects to the Kalispel Tribe s Northern Quest Casino, the Spokane Tribe and the Kalispel Tribe have been considered minority communities that could be impacted by the Proposed Action. Effects to the Spokane Tribe and Kalispel Tribe are discussed above. Alternative 3 would not result in significant adverse effects to minority or low-income communities. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

51 4.7.4 ALTERNATIVE 4 NO ACTION/NO DEVELOPMENT Under the No Action/No Development Alternative, none of the three development alternatives (Alternatives 1, 2, and 3) considered within the EIS would be implemented. The No Action/No Development Alternative assumes that existing uses on the 145-acre project site would not change in the near term. Under this alternative, the BIA would not take any actions in furtherance of their obligation to promote tribal self-determination and economic development. None of the potentially beneficial or adverse effects identified for Alternatives 1 through 3 are anticipated to occur. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

52 4.8 TRANSPORTATION/CIRCULATION This section identifies the direct effects to transportation and circulation that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section 3.8. Cumulative effects are identified in Section Indirect effects associated with off-site construction and growth-inducement are identified in Section Measures to avoid and, if necessary, mitigate for adverse effects are presented in Section ANALYSIS METHODOLOGY The project would result in the addition of vehicle traffic to local intersections. A traffic impact analysis (TIA) was prepared for Alternatives 1, 2, and 3. The TIA was subsequently revised through two addendums prepared based on the results of consultation between the BIA and cooperating agencies as well as comments received during the public review period for the Draft EIS. The TIA and Addendum 1 are provided in Appendix D of the Draft EIS while Addendum 2 is provided in Appendix R of this Final EIS. This section incorporates the results of these studies and describes the number of trips that would be generated by each Alternative and any potential adverse effects that would occur to area intersections within the study area. Traffic effects resulting from Alternatives 1, 2, and 3 were analyzed using trip generation rates provided by the International Traffic Engineer s Trip Generation Manual 8 th Edition, 2009 and the 2002 ITE Journal article, Recalibration of the Trip Generation Model for Las Vegas/Hotel Casinos. Consultation In order to determine the appropriate study area and analysis methodologies for the project, multiple scoping discussions were held with the Washington Department of Transportation (WSDOT), the City of Airway Heights (City), and the County of Spokane. Study Area To assess changes in traffic conditions, 22 intersections were evaluated for each project alternative. Detailed descriptions of study intersections for the project alternatives are included in Section 3.8 and Appendices D and R. Methodologies In accordance with the Intergovernmental Agreement (IGA) between the Tribe, City, and Spokane County, the TIA, including Addendums, for the proposed alternatives was prepared in conformance with the requirements for traffic studies set forth in Spokane County Standards for Road and Sewer Construction, Technical Reference A, and City of Airway Heights requirements. The TIA complies with standard practices for traffic studies within the region and meets County, City, and WSDOT requirements for traffic studies. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

53 Peak Hour Traffic conditions were assessed for PM peak hour conditions only based on the traffic study scope of work defined by WSDOT, County, and City. PM peak was selected since it is generally the worst case condition both in terms of existing traffic volumes on the network and the highest trip generation from the proposed project alternatives. Intersection PM peak hour turning movements were counted at each existing study intersection in July Counts were also collected at U.S. Highway 2 (US-2) and Fairchild AFB entrance, and Craig Road and State Route 902 (SR-902) in September Additional turning movement counts were taken at the driveway on the project site for Spoko Fuel in May Traffic count data sheets are provided as Appendix A in the TIA (Appendix D). Traffic counts were collected from 3:00 PM to 6:00 PM. The highest traffic volume hour was utilized to determine the peak hour, which varied from intersection to intersection. Trip Generation Rates The PM peak hour trip generation was calculated for each of the project alternatives and phases of development. Trip generation rates for all land uses except the casino/hotel and the police/fire facility were based on information published in the Institute of Transportation Engineers (ITE) 8 th Edition of Trip Generation (ITE Manual). The ITE Manual provides empirical data, based on field observations for trip generation characteristics of similar land uses. The ITE Manual does not provide a trip generation rate for the land use category of Indian Casinos; therefore, an alternative methodology was used as explained below. Casino/Hotel (Alternatives 1 and 2) Trip generation for the casino/hotel is based on information provided in Recalibration of Trip Generation Model for Las Vegas Hotel/Casinos, May 2002 ITE Journal pp Rowe, Kaseko, Ackeret (ITE Journal Article). This research indicates that the best predictor of traffic volumes is the size of the gaming component of casino/hotels as measured by the gaming positions; which provides rates that are inclusive of the facility, accounting for employees, hotel patrons, and restaurant guests. Police/Fire Facility (Alternatives 1, 2, and 3) The trip generation for the proposed police/fire facility was based on data from Police Station PM Peak Hour Trip Generation in the Portland Metro Ara, December 2, 2009, Portland State University, Armans, Edmonds, et al. Retail/ Commercial (Alternatives 1, 2, and 3) Trip generation rates from the ITE Manual for land use category 820, shopping center, were applied to the proposed retail/commercial areas located along US-2 and in the western portion of the project site. For the retail components contiguous with the casino/hotel, trip generation rates from the ITE Manual for land use category 814, specialty retail, were applied. For the proposed commercial building that would be located in the north central portion of the project site, ITE Manual trip generation rates for land use category 720, Medical-Dental Office, were applied. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

54 Bowling Alley/Multi-Purpose Recreational Facility (Alternative 3) The ITE Manual land use category 437 (bowling alley) trip generation rate was used for the bowling alley component proposed under Alternative 3. The retail, restaurant, general office, and police station proposed under Alternative 3 used the same trip generation rates discussed above. The ITE Manual land use category 435 (multipurpose recreational facility) trip generation rate was used to determine project related traffic for the multipurpose recreation facility proposed under Alternative 3. The ITE Manual land use category 310 (hotel) was used to determine the trip generation rate resulting from the hotel component under Alternative 3. Trip Reductions Not all of the trips to various proposed uses under each of the project alternatives would be newly generated trips on the road network. Some of the trips would already be on the road going to a different destination and stop at the proposed facilities; these types of trips are referred to as pass-by trips. Additionally, patrons may visit more than one type of use within the project site on a single trip (for example, a casino patron may also visit the retail shops); these trips are referred to as internal trips. Both of these trip types reduce the number of newly generated traffic on the roadway network. Trip reduction/internalization (shared trips) were determined using calculations based on ITE procedures, documented in the Trip Generation Handbook, which is common practice for a TIA and widely accepted among traffic engineers. Internal and pass-by trip reductions assumed for each alternative are provided in Sections 4.8.2, 4.8.3, and Trip Distribution The trip distribution assumed for each of the Alternatives is based on location of the project, type of the project, density of development surrounding the project site, existing transportation facilities, existing traffic volumes and patterns on adjacent and nearby arterial roadways, and professional traffic engineering judgment. Traffic to and from the project site is expected to be distributed in the following manner: 10 percent to/from areas north and east of the site using Craig Road north of US-2 and Deno Road. 10 percent to/from areas east of the project site using 6 th Avenue. 45 percent to/from areas east of the project site using US percent to/from areas west of the project site using US percent to/from areas south of the project site using Craig Road south of US-2. Assessment Criteria The potential for adverse effects as a result of project related traffic was determined based on acceptable LOS standards determined by the appropriate jurisdictional agency. If an applicable LOS standard has not been established, an adverse effect standard has been provided using guidance from other jurisdictions and the professional judgment of DEA. Applicable LOS standards are described below. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

55 For the following arterial intersection under the jurisdiction of the City of Airway Heights (City), the standard is LOS D or better: Craig Road and 6 th Avenue For the following arterial intersections under the jurisdiction of the County of Spokane (County), LOS E or better is the standard for unsignalized intersections and LOS D or better is the standard for signalized intersections: Craig Road and Deno Road (unsignalized) Craig Road and McFarlane Street (unsignalized) Craig Road and Thorpe Road (unsignalized) Deno Road and Hayford Road (unsignalized) For the following arterial intersections under the jurisdiction of the WSDOT, LOS E or better is the standard for unsignalized intersections and LOS D or better is the standard for signalized intersections: US-2 and Craig Road (unsignalized) US-2 and Lundstrom Street (unsignalized) US-2 and Lawson Street (signalized) US-2 and Garfield Street (signalized) US-2 and Hayford Road (signalized) Craig Road and SR-902 (unsignalized) US-2 and Fairchild AFB (signalized) Deer Heights Road and US-2 (unsignalized) Flint Road and US-2 (unsignalized) Spotted Road and US-2 (unsignalized) WSDOT, the County, and the City do not provide assessment criteria for intersections operating below acceptable LOS standards under existing conditions (without the addition of project related traffic); therefore, the following assessment criteria was used which is consistent with the terms of the IGA between the Tribe, City and County: If an intersection operates at an LOS below the applicable standard in the baseline without project condition, an adverse effect would occur if there is a quantifiable increase in the vehicular delay as a result of project related traffic. Future Baseline Conditions To assess project related impacts, future baseline traffic conditions were estimated for the years 2012, 2015 and 2019, which correspond to the timing of buildout of various phases of the project alternatives. Baseline traffic conditions for each year were estimated by adding projected traffic growth from approved and/or reasonably foreseeable projects to existing traffic volumes. Projected traffic growth was estimated based on information provided by the City, WSDOT, County and the Spokane Regional Transportation Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

56 Council (SRTC). A detailed discussion of pipeline projects and traffic growth assumptions for future baseline conditions is provided in the TIA (Page 36 of Appendix D). These pipeline projects, including residential, commercial, industrial, and entertainment developments are combined with regional planning level traffic growth assumptions to provide estimated non-project related traffic levels during the future baseline years. Additionally, the 6 th Avenue extension to Craig Road was assumed to be in place as a component of the study roadway network under future baseline conditions and impacts from the from the Project Alternatives were assessed at the proposed intersection. The extension was a planned improvement within the City s Six Year Transportation Improvement Plan (City of Airway Heights, 2005). The extension was intended to be included on the City s Six Year Transportation Improvement Plan (City of Airway Heights, 2012) and will be added upon its next revision (Tripp, 2012) Funding for the 6 th Avenue extension to Craig Road would be provided by the City or through an established traffic impact fee assessment area for nearby proposed development. Table summarizes baseline traffic conditions during the PM peak hour at each of the study intersections without the addition of project-related traffic. TABLE FUTURE BASELINE WITHOUT PROJECT LOS INTERSECTION 2012 w/pipeline 2015 w/pipeline 2019 w/pipeline Delay LOS Delay LOS Delay LOS US-2 /Craig Rd F F 1 F US-2 /Lundstrom St C 28.7 D 42.8 E US-2 /Lawson St B 20.1 B 23.1 C US-2 /Garfield St B 21.9 C 29.6 C US-2 /Hayford Rd D 44.5 D 66.6 E Craig Rd. /Deno Rd. 9.4 A 9.4 A 9.4 A Craig Rd. /McFarlane St B 10.9 B 10.9 B Craig Rd. /Thorpe Rd. East 9.0 A 9.0 A 9.1 A Craig Rd. /Thorpe Rd. West 9.0 A 9.0 A 9.0 A Craig Rd. /SR D 36.4 E 37.8 E US-2 /Fairchild AFB B 17.4 B 21.4 C Craig Rd. /6 th Ave B 11.6 B 24.3 C Deer Heights Road/US F ** F ** F Flint Road/US F 88.8 F F Spotted Road/US D 36.4 E 51.5 F Deno Road/Hayford Road 13.5 B 14.1 B 15.9 C Note: 1 Delay is Excessive. Bold = unacceptable LOS; ** = exceeds model delay capacity. Source: DEA, 2011; (Appendix D) and DEA, 2012 (Appendix R of the Final EIS) As shown in Table 4.8-1, the following four study intersections would operate below the applicable jurisdictions LOS standards under future baseline conditions without the addition of project traffic: US-2/Craig Road (2012, 2015, and 2019) US-2/Hayford Road (2019) Craig Road/SR-902 (2019) Deer Heights Road/US-2 (2012, 2015, and 2019) Flint Road/US-2 (2012, 2015, and 2019) Spotted Road/US-2 (2019) Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

57 4.8.2 ALTERNATIVE 1 PROPOSED CASINO AND MIXED-USE DEVELOPMENT Site Access Access to the site will be provided by six driveways, three along US-2 and three along Craig Road between US-2 and 6 th Avenue (Figure 2-4). Improvements to these access intersections to manage safe ingress and egress of traffic at the project site have been recommended as a result of the TIA and Addendums (Appendix D of the Draft EIS and Appendix R of the Final EIS) and consultation with WSDOT, and are included as mitigation in Section These mitigation measures include the installation of two full-movement accesses on the US-2 site frontage using roundabout intersection control, along with a roundabout at the US-2/Craig Road intersection. The three roundabouts would be equally spaced just less than 0.25 miles apart. The westerly access would be positioned near the property boundary providing access to the overall site as well the existing Spoko Fuel facility. The middle roundabout would be located just east of the proposed main access shown on Figure 2-4. The results of the TIA Addendum indicate that this access configuration would operate better, provide greater capacity and disperse traffic more evenly when compared to the originally proposed access driveways, reducing the project s impact to US-2 corridor traffic flow and operations. Indirect effects as a result of the reconfigured access driveway mitigation are discussed in Section Construction Traffic Construction of Alternative 1 would require truck trips for delivery of equipment and material, structural fill, and daily construction workers trips. Traffic impacts resulting from the construction of Alternative 1 construction activities would be temporary and intermittent in nature and would generally occur during off-peak traffic hours (5 AM to 6 AM and 10 AM to 4 PM). Construction activity impacts would be concentrated on US-2 in the immediate vicinity of the project site, and would include temporary traffic delays due to slower moving construction trucks and the increase in worker vehicles on area roadways. Daily construction trips are estimated to be approximately 902 trips during Phase I, 616 during Phase II, and 1,134 during Phase III, most of which would occur prior to the peak traffic hour. Daily construction trips include construction worker trips, material delivery, truck trips for import of structural fill, and equipment delivery. Traffic generated by construction of Alternative 1, Phase I would be 33 percent of operational traffic, Phase II would be 23 percent of operational traffic, and Phase III would be 42 percent of operational traffic. Phase I generates the greatest amount of construction traffic compared to operational traffic. Traffic due to construction would be temporary, intermittent, and would generally occur outside the peak hour. Because construction traffic would be temporary, significantly less than operational traffic, and would occur outside of the peak hour, significant adverse effects would not occur. Project Traffic Trip Generation The projected vehicle trip generation resulting from Alternative 1, Phases I, II, and III is shown in Table Methodology used to determine trip generation and trip distribution is described above. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

58 Proposed Land Use Unit/ Variable TABLE ALTERNATIVE 1 PEAK HOUR TRIP GENERATION PM Peak Hour ITE Code Trip Rate trips/peak hour Trips Trip Reductions Shared Trips Pass by Trips Total Trips PHASE I Casino/Hotel 1,878/G P , ,168 Shopping Center 155.1/ksf Quality Restaurant 9.2/ksf Commercial 41.6/ksf General Office 10.5/ksf Police Station 14.0/ksf Total Trips 2, ,855 PHASES I AND II Casino/Hotel 2,468/G P , ,437 Shopping Center 155.1/ksf Quality Restaurant 18.0/ksf Commercial General Office Police Station Specialty Retail 69.6/ksf Total Trips 3, ,324 PHASES I, II, and III Casino/Hotel 3,040/G P , ,692 Shopping Center 155.1/ksf Quality Restaurant 18.0/ksf Commercial General Office Police Station Specialty Retail 205.0/ksf Total Trips 3, ,717 Note: Ksf = thousand square feet; G P = gaming positions. Source: DEA, 2011; (Appendix D). Trip Reduction The following shared trip reductions were assumed for Alternative 1: Casino/Hotel 15 percent Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

59 Shopping Center 24 percent Quality Restaurant 42 percent Commercial 37 percent The following pass-by trip reductions were assumed for Alternative 1: Casino/Hotel 4 percent Shopping Center 20 percent Quality Restaurant 26 percent Traffic Conditions with Alternative 1 To assess the impacts of the project on transportation facilities in the study area, the projected number of trips generated by Alternative 1 was added to baseline with pipeline project traffic volumes (refer to Section 4.8.1). Table shows the PM peak hour intersection delay and LOS at each of the study intersections under baseline with Alternative 1, Phases I, II, and II traffic conditions. PM peak hour turning volumes at each of the study intersections under baseline plus Alternative 1 traffic conditions are provided within the TIA (Appendix D). With the addition of project-related traffic, the following study intersections are projected to operate at an unacceptable LOS: Phase I (2012) US-2/Craig Road US-2/Hayford Road Craig Road/SR-902 US-2/Middle Driveway Deer Heights Road/US-2 Flint Road/US-2 Spotted Road/US-2 Phase II (2015) US-2/Craig Road US-2/Lundstrom Street US-2/Hayford Road Craig Road/SR-902 US-2/Middle Driveway Deer Heights Road/US-2 Flint Road/US-2 Spotted Road/US-2 Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

60 Phase III (2019) US-2/Craig Road US-2/Lundstrom Street US-2/Hayford Road Craig Road/SR-902 US-2/Middle Driveway US-2/Garfield Deer Heights Road/US-2 Flint Road/US-2 Spotted Road/US-2 Deno Road/Hayford Road TABLE BASELINE PLUS ALTERNATIVE 1 INTERSECTION LOS INTERSECTION 2012 Phase I 2015 Phase II 2019 Phase III Delay LOS Delay LOS Delay LOS US-2 /Craig Rd. 1 F 1 F 1 F US-2 /Lundstrom St E 76.6 F F US-2 /Lawson St B 22.8 C 39.4 D US-2 /Garfield St B 27.9 C 69.2 E US-2 /Hayford Rd E 80.0 E F Craig Rd. /Deno Rd B 11.2 B 11.7 B Craig Rd. /McFarlane St C 18.0 C 20.5 C Craig Rd. /Thorpe Rd. East 11.3 B 12.5 B 13.9 B Craig Rd. /Thorpe Rd. West 10.1 B 10.5 B 10.9 B Craig Rd. /SR F F 1 F US-2 /Fairchild AFB B 22.1 C 31.9 C Craig Rd. /6 th Ave B 15.0 B 44.0 E US-2 /Dwy. West 16.1 C 18.9 C 25.8 D US-2 /Dwy. Middle 1 F 1 F 1 F US-2 /Dwy. East 16.4 C 19.6 C 25.8 D Craig Rd. /Dwy. North 12.8 B 16.3 C 47.4 E Craig Rd. /Dwy. Middle 11.9 B 14.0 B 22.3 C Craig Rd. /Dwy. South 14.9 B 20.2 C 48.6 E Deer Heights Road/US F ** F ** F Flint Road/US F F ** F Spotted Road/US F 76.4 F F Deno Road/Hayford Road 26.2 D 38.3 E 89.6 F Note: 1 Delay is Excessive. Bold = unacceptable LOS. BG = Background; PH = Phase. ** = exceeds model delay capacity. Source: DEA, 2011; (Appendix D) and DEA, 2012 (Appendix R of the Final EIS) The increase in traffic generated by Alternative 1 would contribute to unacceptable traffic operations at the study intersections outline above. Without mitigation, these intersections would operate below acceptable LOS standards described in Section Consistent with the requirements of Section 3.0 of the IGA (Appendix C), mitigation measures have been recommended within the TIA and included within Section These mitigation measures were developed in consultation with WSDOT, Spokane County and the City of Airway Heights, and include requirements to fully fund and/or construct key Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

61 improvements to address impacts caused by Alternative 1. These improvements will provide an immediate benefit to the transportation network and added capacity to serve the Proposed Project. Mitigation measures include fully funding construction of improvements to the access intersections, the segment of Craig Road adjacent to the project site, US-2/Craig Road intersection, and the Craig Road/SR- 902 intersection. In addition, mitigation has been provided to ensure funding is made available to implement the extension of 6 th Avenue to Craig Road if the City has not fully funded the project at the time of implementation of Alternative 1. By constructing specific improvements instead of providing partial funding for future projects at these locations, traffic conditions would immediately be improved. Furthermore, the recommended near term mitigations for Phase I, including improvements to the Craig Road transportation corridor, will provide a viable and immediately available alternative route to the project site via Craig Road to SR 902 and I-90, which may serve to relieve traffic along US-2. Additionally, mitigation requires that the Tribe contribute a proportional share to future improvements that when fully implemented would restore the intersections identified above to acceptable operating conditions in accordance with applicable agency requirements, or would restore operating conditions to pre-development levels. While there is currently no governmental funding program in place for the proposed improvements to the US-2 transportation corridor, including the following intersections: US-2/Garfield, US-2/Lundstrom, US-2/Hayford, there are a number of proposed regional transportation projects currently in the planning phase, including the 21 st Avenue/18 th Street Corridor, that would reduce traffic on US-2 and potentially significant adverse effects of the project. Mitigation requires that the Tribe contribute a proportionate share to such improvements at which time a plan is developed and implemented by the responsible agencies. Prior to implementation of Phase II and III of the project, the traffic impacts of the project and mitigations would be re-evaluated and any changes to the mitigation plan would be subject to review and approval by the applicable jurisdictional agencies. Because the timing of some mitigation is uncertain and may not occur until after project implementation, short-term significant adverse effects associated with traffic and circulation may occur until such time mitigation is designed, approved and implemented by the appropriate jurisdictional agencies. Upon implementation of recommended mitigation, Alternative 1 would have a less-thansignificant effect associated with traffic and circulation. Indirect effects of traffic mitigation measures are addressed in Section Transit, Bicycle, and Pedestrian Facilities Bicycle and pedestrian facilities in the vicinity of the project site are limited. Sidewalk facilities in the vicinity of the project site are limited to facilities east of Craig Road along US-2. There are no bicycle lanes in the vicinity of the project site. Because sufficient parking is available onsite and sidewalk and bicycle facilities do not currently provide direct access to the project site, no significant adverse effects would occur to pedestrian facilities as a result of Alternative 1. To further reduce potential impacts to bicycle and pedestrian facilities and to improve connectivity and circulation, mitigation is provided in Section consistent with the current ( ) Smart Routes project list, the recommendation in the West Plains-Spokane International Airport Transportation Study (2011), the Spokane Regional Bike Plan (2008), and the Spokane Regional Pedestrian Plan (2009). Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

62 Currently, the Spokane Transit Authority (STA) operates the only bus line to and from the project site (Route 61). According to Karl Otterstrom, Planning Director, STA, Route 61 had an average weekday ridership of 1, 375 riders in 2011 (STA, 2012a). These riders are distributed throughout the day with the greatest average number of riders being approximately 72 boarding the outbound bus between 3:00 and 4:00 pm during the weekdays (STA, 2012a). Twenty eight buses operate on Route 61 during the weekday, with three buses operating during the peak hour (3:00 pm and 4:00 pm); therefore, there is an average of 24 riders per bus during the weekday peak hour (STA, 2012a; STA, 2012b). STA buses on Route 61 are approximately 40 foot long and have a minimum capacity of approximately 39 seated riders(sta, 2012a). Assuming that two percent of the estimated patrons for Alternative 1 use the bus system which is consistent with the STA model split when planning new routes (SRTC, 2012), during the peak hour with the greatest number of potential riders approximately 44 riders would be added to the three Route 61 buses, or approximately 15 riders per bus. This addition of 15 project-related riders to existing ridership on each of the three peak hour Route 61 buses would result in an average of 39 riders per bus. Thirty-nine riders would not exceed the STA seated bus capacity of 39; therefore, a less than significant effect to public transit facilities would occur. It should be noted that peak hour traffic for casinos is between 7:00 and 9:00 pm; therefore, peak hour transit ridership related to Alternative 1 would not likely coincide with typical peak hours observed by STA. Although additional ridership would not exceed the capacity of STA s existing facilities, mitigation measures have been provided in Section to further reduce potential effects to public transit facilities ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Site Access Access to the project site under Alternative 2 would be the same as Alternative 1. Refer to Section Construction Traffic The temporary traffic generated during construction of Alternative 2 would be less than Alternative 1; therefore, Alternative 2 would result in a less than significant effect to traffic and circulation during construction. Project Traffic Trip Generation The projected vehicle trip generation resulting from Alternative 2 is shown in Table Methodology used to determine trip generation and trip distribution is described above under Section Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

63 TABLE ALTERNATIVE 2 PEAK HOUR TRIP GENERATION PM Peak Hour Proposed Land Use Unit/ Variable ITE Code Trip Rate trips/peak hour Trips Trip Reductions Shared Pass by Trips Trips Total Trips Casino/Hotel 1,878/G P , ,168 Shopping Center 155.1/ksf Quality Restaurant 9.2/ksf Commercial 41.6/ksf General Office 10.5/ksf Police Station 14.0/ksf Total Trips 2, ,855 Notes: Ksf = thousand square feet; G P = gaming positions. Source: DEA, 2011; (Appendix D). Trip Reduction The following shared trip reductions were used for Alternatives 2: Casino/Hotel 15 percent Shopping Center 24 percent Quality Restaurant 42 percent Commercial 37 percent The following pass-by trip reductions were uses for Alternatives 2: Casino/Hotel 4 percent Shopping Center 20 percent Quality Restaurant 26 percent Trip Distribution The trip distribution for Alternative 2 is the same as Alternative 1. Refer to Section Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

64 Traffic Conditions with Alternative 2 To assess the impacts of the project on transportation facilities in the study area, the projected number of trips generated by Alternative 2 was added to baseline with pipeline project traffic volumes (refer to Section 4.8.1). Table shows the PM peak hour intersection delay and LOS at each of the study intersections under background plus Alternative 2 traffic conditions. PM peak hour turning volumes at each of the study intersections under background plus Alternative 2 traffic conditions are provided within the TIA (Appendix D and Appendix R of the Final EIS). TABLE BASELINE PLUS ALTERNATIVE 2 INTERSECTION LOS INTERSECTION 2012 Alternative 2 DELAY LOS US-2 /Craig Rd. 1 F US-2 /Lundstrom St E US-2 /Lawson St B US-2 /Garfield St B US-2 /Hayford Rd E Craig Rd. /Deno Rd B Craig Rd. /McFarlane St C Craig Rd. /Thorpe Rd. East 11.3 B Craig Rd. /Thorpe Rd. West 10.1 B Craig Rd. /SR F US-2 /Fairchild AFB B Craig Rd. /6 th Ave B US-2 /Dwy. West 16.1 C US-2 /Dwy. Middle 1 F US-2 /Dwy. East 16.4 C Craig Rd. /Dwy. North 12.8 B Craig Rd. /Dwy. Middle 11.9 B Craig Rd. /Dwy. South 14.9 B Deer Heights Road/US F Flint Road/US F Spotted Road/US F Deno Road/Hayford Road 26.2 D Notes: 1 Delay is Excessive. Bold = unacceptable LOS. ** = exceeds model delay capacity. Source: DEA, 2011; (Appendix D) and DEA, 2012 (Appendix R of the Final EIS) With the addition of project-related traffic, the following study intersections are projected to operate at an unacceptable LOS: US-2/Craig Road US-2/Lundstrom Street US-2/Hayford Road Craig Road/SR-902 US-2/Middle Driveway Deer Heights Road/US-2 Flint Road/US-2 Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

65 Spotted Road/US-2 The increase in traffic generated by Alternative 2 would contribute to unacceptable traffic operations at the study intersections outline above. Without mitigation, these intersections would operate below acceptable LOS standards described in Section In addition, mitigation has been provided to ensure funding is made available to implement the extension of 6 th Avenue to Craig Road if the City has not fully funded the project at the time of implementation of Alternative 2. Consistent with the requirements of the IGA, mitigation measures have been recommended within the TIA and included within Section that would restore the intersections identified above to acceptable operating conditions in accordance with applicable agency requirements, or would restore operating conditions to pre-development levels. Because the timing of some mitigation is uncertain and may not occur until after project implementation, short-term significant adverse effects associated with traffic and circulation may occur until such time mitigation is designed, approved and implemented by the appropriate jurisdictional agencies. Upon implementation of recommended mitigation, Alternative 2 would have a less-than-significant effect associated with traffic and circulation. Transit, Bicycle, and Pedestrian Facilities Impacts to the STA transit system, and bicycle facilities, and pedestrian facilities under Alternative 2 would be less than those analyzed under Alternative 1 (refer to Section 4.8.2). As discussed under Alternative 1, the increase in ridership is not expected to exceed capacity of STA public transportation facilities; therefore, significant adverse effects to public transportation facilities would not occur. Mitigation has been provided in Section to improve bicycle and pedestrian circulation and further reduce potential effects associated with public transportation ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Site Access Access to the project site under Alternative 3 would be the same as Alternative 1. Refer to Section Construction Traffic Construction of Alternative 3 would require truck trips for delivery of equipment and material, structural fill, and daily construction workers trips. Traffic impacts resulting from the construction of Alternative 3 construction activities would be temporary and intermittent in nature and would generally occur during off-peak traffic hours (5 AM to 6 AM and 10 AM to 4 PM). Construction activity impacts would be concentrated on US-2 in the immediate vicinity of the project site, and would include temporary traffic delays due to slower moving construction trucks and the increase in worker vehicles on area roadways. Daily construction trips are estimated to be approximately 1,763 trips, most of which would occur prior to the peak traffic hour. Daily construction trips include construction worker trips, material delivery, 89 truck trips for import of structural fill, and equipment delivery. Traffic generated by construction of Alternative 3, would be less than the total operational vehicle trips. Traffic due to construction would be temporary, intermittent, and would generally occur outside the peak hour. Because construction traffic Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

66 would be less than operational traffic and would occur outside of the peak hour, significant adverse effects would not occur. Mitigation is provided in Section 5.2.7, which would further reduce impacts to traffic condition during construction of the proposed project. Project Traffic Trip Generation and Trip Distribution The projected vehicle trip generation resulting from Alternative 3 is shown in Table The ITE Manual was used to determine each project component s trip generation rate with the exception of the police station. The trip generation rate for the police station is provided in Section The trip distribution under Alternative 3 would be the same as the trip distribution used in Alternative 1, refer to Section TABLE ALTERNATIVE 3 PEAK HOUR TRIP GENERATION PM Peak Hour Proposed Land Use Unit/ Variable ITE Code Trip Rate Trips/Variable Trips Trip Reductions Shared Pass by Trips Trips Total Trips Hotel 300/rooms Shopping Center 155.1/ksf Quality Restaurant 9.2/ksf Commercial 41.6/ksf General Office 10.5/ksf Bowling Alley 45.02/ksf Multipurpose Recreational Facility 55.85/ksf Police Station 14.0/ksf Specialty Retail 96.6/ksf Total Trips 1, ,486 Notes: Ksf = thousand square feet. Source: DEA, 2011; (Appendix D). Trip Reduction The following shared trip reductions were use for Alternative 3: Hotel 39 percent Shopping Center 9 percent Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

67 Quality Restaurant 42 percent Commercial 37 percent The following pass-by trip reductions were use for Alternative 3: Shopping Center 26 percent Quality Restaurant 26 percent Traffic Conditions with Alternative 3 To assess the impacts of the project on transportation facilities in the study area, the projected number of trips generated by Alternative 3 was added to baseline with pipeline project traffic volumes (refer to Section 4.8.1). Table shows the PM peak hour intersection delay and LOS at each of the study intersections under baseline plus Alternative 3 traffic conditions. PM peak hour turning volumes at each of the study intersections under baseline plus Alternative 3 traffic conditions are provided within the TIA (Appendix D and Appendix R of the Final EIS). TABLE BASELINE PLUS ALTERNATIVE 3 INTERSECTION LOS INTERSECTION 2012 Alternative 3 DELAY LOS US-2 /Craig Rd. 1 F US-2 /Lundstrom St E US-2 /Lawson St B US-2 /Garfield St B US-2 /Hayford Rd D Craig Rd. /Deno Rd B Craig Rd. /McFarlane St B Craig Rd. /Thorpe Rd. East 10.4 B Craig Rd. /Thorpe Rd. West 9.6 A Craig Rd. /SR F US-2 /Fairchild AFB B Craig Rd. /6 th Ave B US-2 /Dwy. West 16.6 C US-2 /Dwy. Middle 1 F US-2 /Dwy. East 15.0 C Craig Rd. /Dwy. North 11.9 B Craig Rd. /Dwy. Middle 10.9 B Craig Rd. /Dwy. South 12.0 B Deer Heights Road/US F Flint Road/US F Spotted Road/US E Deno Road/Hayford Road 23.2 C Notes: 1 Delay is Excessive. Bold = unacceptable LOS. ** = exceeds model delay capacity. Source: DEA, 2011; (Appendix D) and DEA, 2012 (Appendix R of the Final EIS) With the addition of project-related traffic, the following study intersections are projected to operate at an unacceptable LOS: Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

68 US-2/Craig Road US-2/Lundstrom Street US-2/Middle Driveway Deer Heights Road/US-2 Flint Road/US-2 The increase in traffic generated by Alternative 3 would contribute to unacceptable traffic operations at the study intersections outline above. Without mitigation, these intersections would operate below acceptable LOS standards described in Section Consistent with the requirements of the IGA, mitigation measures have been recommended within the TIA and included within Section that would restore the intersections identified above to acceptable operating conditions in accordance with applicable agency requirements, or would restore operating conditions to pre-development levels. Because the timing of some mitigation is uncertain and may not occur until after project implementation, short-term significant adverse effects associated with traffic and circulation may occur until such time mitigation is designed, approved, and implemented by the appropriate jurisdictional agencies. Upon implementation of recommended mitigation, Alternative 3 would have a less-than-significant effect associated with traffic and circulation. Transit, Bicycle, and Pedestrian Facilities Impacts to the STA transit system, and bicycle facilities, and pedestrian facilities under Alternative 3 would be less than those analyzed under Alternative 1 (refer to Section 4.8.2). As discussed under Alternative 1, the increase in ridership is not expected to exceed capacity of STA public transportation facilities; therefore, significant adverse effects to public transportation facilities would not occur. Mitigation has been provided in Section to improve bicycle and pedestrian circulation and further reduce potential effects associated with public transportation ALTERNATIVE 4 NO ACTION/ NO DEVELOPMENT The traffic conditions under the No Action/No Development Alternative would continue as described in Section for the baseline without Project conditions. No project related traffic would be added to the local intersections; therefore, no effects would occur under this alternative. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

69 4.9 LAND USE This section identifies the direct effects to land use that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section 3.9. Cumulative effects are identified in Section Indirect effects associated with off-site construction and growth-inducement are identified in Section ALTERNATIVE 1 PROPOSED CASINO AND MIXED-USE DEVELOPMENT Effects to Existing and Planned Land Uses Alternative 1 would result in the development of a casino-resort facility, site retail, commercial building, tribal cultural center, and police/fire station. As discussed in Section 3.9, the project site is located on existing tribal trust property and is not subject to state or local land use regulations. The Tribal Council of the Spokane Tribe of Indians (Tribe) has jurisdictional authority over land use matters on the federal trust lands held on their behalf; however, the Tribal Council desires to work cooperatively with local and state authorities on land use matters. In furtherance of that goal, the Tribe entered into an Intergovernmental Agreement (IGA) with the City of Airway Heights (City) and Spokane County and a Memorandum of Agreement (MOA) with the City in which the parties acknowledged that it is to their mutual benefit to utilize the status and unique opportunities of each as separate governments to cooperate, and where possible, to partner in the development of the Tribe s property in such a manner as best serves the interests of the parties and the interests of the public health and safety of the City and County and their residents, as well as the Tribe. (Appendix C). In Section 6.0 of the IGA, the Tribe, City, and Spokane County set forth certain terms and conditions with regard to their respective obligations in conjunction with the annexation of the project site into the City. The annexation of the project site into the City became effective on April 30, Given the commercial and light industrial nature of surrounding development along U.S. Highway 2 (US- 2), especially to the east, Alternative 1 would be consistent with nearby development. Prior to its annexation, the project site was located within the Spokane County and City Urban Growth Area (UGA) and Joint Planning Area (JPA) boundaries, and hence the proposed development would not introduce sprawling or leap frog development to the area. However, development of Alternative 1 has the potential to result in significant impacts to adjacent sensitive receptors, including residential land uses to the east, as discussed in detail in the other topical sections of this Environmental Impact Statement (EIS). Impacts may include, but are not limited to, air quality and noise effects from construction and operational activities (Sections 4.4 and 4.11 respectively); congestion on local roads from increased traffic (Section 4.8); and alterations of the visual resources and aesthetics of the surrounding area (Section 4.13). Implementation of mitigation measures identified in Section 5.0 would reduce potential adverse effects to less than significant levels. As discussed in detail below, the proposed development is generally consistent with policies related to land use in the vicinity of the Fairchild Air Force Base (AFB) and Spokane International Airport (SIA). Therefore, Alternative 1 would result in less than significant effects associated with land use conflicts. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

70 Compatibility with Air Force Base and Airport Operations The project site is located approximately 1.5 miles west of the entrance to Fairchild AFB on US-2, and is adjacent to and directly below established flight patterns for Fairchild AFB. As noted in Section 3.9, the project site does not fall within the Department of Defense s designated Accident Potential Zones, which have a measurably higher potential for accident rates. On February 29, 2012, the Tribal Council enacted Resolution , which acknowledges that existing and future operations at Fairchild AFB may pose inconveniences to property owners, including but not limited to air, traffic, noise, fumes, dust, and smoke, and confirms the Tribe s commitment to accept such inconveniences or discomfort as normal and necessary aspect of operating a Class III gaming facility and resort near an Air Force Base that serves as a critical economic engine for the Region. This resolution has been included within the Final EIS as Appendix W. Further, Fairchild AFB has confirmed that it does not intend to change current or future flight operations for current or future aircraft should they be requested to do so by the Tribe (USAF, 2012). Implementation of the proposed project would not encroach upon Fairchild AFB s available air space or impede its ability to implement the operational and training mission of the installation for the following reasons: 1) The Tribe has agreed to accept any inconveniences associated with AFB operations during operation of the proposed project, and the Fairchild AFB has confirmed that it does not intend to alter its flight patterns in the unlikely event that the Tribe issues complaints related to nuisances on the project site; and, 2) With the implementation of mitigation recommended in Section 5.0, including measures to avoid creation of hazardous wildlife attractants and minimize light and glare, the Proposed Project would not create an air navigation hazard or otherwise impede Fairchild AFB operations as described below under the discussion of consistency with Fairchild Joint Land Use Study strategies and recommendations. While Fairchild AFB operations may result in noise levels or odors on the site that would be perceived as a nuisance, such nuisances would not cause physical harm or health related threats to tribal employees or patrons visiting the proposed facilities. Further, the location of the proposed casino and hotel is more than 4,400 feet (0.85 miles) north of the Department of Defense defined Accident Potential Zones (APZs), which designate areas that have a measurably higher potential for aircraft accidents; therefore, the proposed project would not locate people within an area that is considered to have a level of risk associated with accident potential that warrants land use and density restrictions. A detailed discussion of consistency with the Fairchild Joint Land Use Study strategies and recommendations is provided below. As stated therein, with mitigation, the Alternative 1 would be consistent with all recommended strategies to ensure development is compatible to Fairchild AFB operations. These strategies were developed to prevent harm to both the Air Force and SIA operations as well as land uses within the project site. Therefore, with implementation of mitigation measures recommended in Section 5.2.8, the Proposed Project would be considered compatible with Fairchild AFB operations. This impact is considered less than significant with mitigation. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

71 Consistency with Fairchild Joint Land Use Study (JLUS) Strategies and Recommendations As discussed in Section 3.9.2, the Fairchild Joint Land Use Study (JLUS) identified four factors that should be considered when determining whether or not proposed land uses within the project site are compatible with airport operations: (1) development of tribal lands, (2) height of current/future development, (3) aircraft noise, and (4) light and glare. As described in detail below, the project is compatible with each of the identified factors. In addition, as shown in Table 4.9-1, after mitigation Alternative 1 is consistent with the applicable strategies listed in Section 5.0 of the Fairchild JLUS. In accordance with Strategy 29, the Spokane Tribe is represented on the JLUS Coordinating Committee, which was established to maintain efficient and effective coordination between local jurisdictions, Fairchild AFB, and other interested parties. Based on the factors and strategies outlined in the Fairchild JLUS, with mitigation outlined in Section (land use mitigation), Section (sounds attenuation mitigation), and (light and glare mitigation), the construction and operation of Alternative 1 would be considered compatible with air traffic operations and would not result in significant adverse land use effects associated with Fairchild AFB and SIA operations and planning. Development on Tribal Lands The Fairchild JLUS does not describe specific concerns regarding the development of the project site; it only states that without cooperative land use planning, local planning boards and communities are often left with little control over what is built on tribal lands (Spokane County, 2009). Although land use and zoning designations adopted by local governments are not binding on tribal lands, the proposed commercial use on the project site is consistent with other uses along U.S. Highway 2 (US-2). The Tribe has engaged in significant coordination with both Spokane County and the City regarding proposed land uses on the project site, as evidenced from the IGA, MOA, and Interlocal Agreement (ILA) discussed in Section 1.5. Furthermore, the Proposed Project is consistent with Strategies 36 and 50 of the Fairchild JLUS. Height of Current/Future Developments As discussed in Section 3.9.2, consistent with Strategy 53 of the Fairchild JLUS, the FAA conducted an aeronautical study in November 2010 under the provisions of Title 49 USC, Section 44718, and Title 14 CFR Part 77, which concluded that the proposed 145-foot hotel tower would not be a hazard to air navigation (Appendix K of the Draft EIS). In April 2012, the FAA reviewed the aeronautical study in light of current operations and found that no significant aeronautical changes have occurred which would alter the determination issued for the proposed project. The FAA s Determination of No Hazard to Air Navigation, dated November 3, 2010, is provided in Appendix K of the Draft EIS while the extension notice, dated April 17, 2012, is provided in Appendix S of the Final EIS. The FAA determination and extension will expire on October 17, 2013, 36 months after the original notice was issued. In the event that construction of the hotel tower is not completed prior to the expiration of the determination, a new aeronautical study will be completed by FAA prior to construction. Aircraft Noise The U.S. Air Force has an ongoing and sustained operational mission at Fairchild AFB and, consequently, due to the current airspace and flight track limitations, will need to continue to fly existing patterns, which will generate elevated noise levels within the project site as pilots fly the Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

72 closed patterns and conduct approach and departure flight operations over the project site. As discussed in Section 3.9.2, the Air Installation Compatible Use Zone (AICUZ) Study recommends that, whenever possible, commercial/retail, trade, and personal and business services be located in areas up to 70 decibel (db) Day-night Average Level (Ldn) without restriction. Between 70 and 80 db Ldn, noise level reduction measures should be included in the design and construction of buildings (Fairchild AFB, 2007). As shown on Figure 3.9-5, the project site is outside the existing 65 Ldn noise contour of the Fairchild AFB and SIA as determined by the 2007 AICUZ, and, therefore, is within the recommended average noise limits for commercial uses. However, as depicted in Figure 3-21 of the 2009 JLUS and Figure 4 of Appendix L of the 2009 JLUS, the project site is located within the predicted Ldn noise contours for potential future mission scenarios based on a mix of next generation air refueling aircraft (32 KC-767A) and B-52 aircraft (defined as Scenario 3 within the JLUS). Additionally, as described in Section 4.11, routine aircraft flying above the project site can produce a sound exposure level (SEL) of 94 db at 145 feet above ground level (agl), and less frequent transient aircraft flying over the site can produce a SEL noise ranging approximately from 104 db to 112dB at 145 feet agl. Exposure of hotel patrons to noise from aircraft is considered a potentially significant land use compatibility impact as a result of Alternative 1 due to the potential for annoyance and nuisance complaints. Mitigation consistent with Strategies 23 and 27 of the Fairchild JLUS is provided in Section to ensure appropriate sound attenuation methods are utilized during construction of the hotel to minimize the potential for nuisance to Alternative 1 hotel patrons. Additional mitigation is provided in Section consistent with Strategies 10 and 44 of the Fairchild JLUS which would protect Fairchild AFB against liability for any nuisance caused by aircraft using Fairchild AFB and/or the airspace above the project site (i.e. noise and vibration). Light and Glare As discussed in Section , the use of glass panels and reflective ornamental detailing in the project design could increase the glare in the vicinity of the project site. Consistent with Strategy 54 of the Fairchild JLUS, mitigation measures are recommended in Section to reduce this potential impact to Fairchild AFB and SIA to a less-than-significant level. The FAA determination provided in Appendix K and extension provided in Appendix S concerning the effect of the proposed hotel tower on the safe and efficient use of navigable airspace by aircraft states that marking and lighting are not necessary for aviation safety. Bird and Wildlife Attractions Alternative 1 does not include any new features that would attract birds and wildlife to the project site, with the exception of bio-filtration swales that would retain stormwater within the project site for limited periods of time. Under existing conditions, due to the uneven nature of the site topography, stormwater ponds within depressions within the site until it percolates into the groundwater. The grading and drainage plan for Alternative 1would balance the topography of the site and direct stormwater towards approximately 14 bio-filtration swales. Under Alternative 1, stormwater is unlikely to pond within the bio-filtration swales for periods longer than would be experienced under existing conditions. Further, development of the project site would be a deterrent to wildlife and would likely decrease the level of bird activity when compared to existing conditions. To further reduce potential effects, mitigation measures are recommended in Section consistent with Strategies 16 and 18 of the Fairchild JLUS. With the Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

73 incorporation of mitigation, the Proposed Project would not increase the bird/wildlife aircraft strike hazard in the vicinity of the subject property. Strategy Number TABLE CONSISTENCY WITH APPLICABLE FAIRCHILD JLUS STRATEGIES Consistent Discussion Strategy 10 Implement recommendations in the current Fairchild AFB AICUZ: For purposes of this strategy, the noise contours used will be as established for the potential mission scenario based on a mix of next generation air refueling aircraft (32 KC-767A) and B-52 aircraft. Within this area, local jurisdictions will use the Air Force Land Use Compatibility Guidelines to evaluate existing and future land use proposals in this area. Yes The project site is located between the 65 db to 70 db Ldn contours as established for the potential mission scenario based on a mix of next generation air refueling aircraft (32 KC- 767A) and B-52 aircraft (see Figure 3-21 of the JLUS, and Figure 4 of Appendix L of the JLUS) (Spokane County, 2009). The U.S. Air Force Recommended Land Use Compatibility Guidelines provided in Table 3-1 of the AICUZ indicate that the proposed types of retail and commercial uses within the project site are an acceptable use within the db Ldn noise contour with no restrictions (Fairchild AFB, 2007). The Guidelines indicate that the proposed hotel, which would be classified as transient lodging (Standard Land Use Coding Manual No. 15), is an acceptable use within the db noise contour with the inclusion of measures to achieve outdoor to indoor noise level reduction. Mitigation in Section would result in the use of sound attenuation materials for construction of the proposed hotel that would achieve a maximum interior noise level of 45 db Ldn. Therefore, Alternatives 1 and 3 would be consistent with this strategy after mitigation, and Alternative 2 (which does not include a hotel) would be consistent with this strategy without mitigation. 16 Bird/Wildlife Aircraft Strike Hazard (BASH) Consideration in Jurisdiction or Agency Projects: All projects sponsored by a local jurisdiction or agency should consider bird attraction and will consult with Fairchild AFB on the review and mitigation of significant attraction issues. Yes Mitigation measures have been included within Section to control bird and wildlife attractions on the project site as recommended by the Fairchild AFB during cooperating agency consultation. Therefore, with mitigation, Alternatives 1, 2, and 3 are consistent with this strategy. 18 Control Bird and Wildlife Attractions Near Base: Work directly with local jurisdictions and other agencies on control of bird and wildlife attractions in the immediate vicinity of the base. Yes Mitigation measures have been included within Section to control bird and wildlife attractions on the project site as recommended by the Fairchild AFB during cooperating agency consultation. Therefore, with mitigation, Alternatives 1, 2, and 3 are consistent with this strategy. 23 Sound Attenuation for New Construction: For commercial uses, sound attenuation will be required for new construction inside of the 75 Ldn contour for the potential mission scenario based on a mix of next generation air refueling aircraft and B-52 aircraft. In this Yes Refer to discussion under Strategy 10. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

74 27 36 area, the minimum Sound Transmission Class (STC) rating of structure components shall be provided in compliance with the table shown below. As an alternative to compliance with this table, structures should be permitted to be designed and constructed so as to limit the interior noise level to no greater than 45 Ldn. Exterior structures, terrain and permanent plantings shall be permitted to be included as part of the alternative design. The alternative design should be certified by an acoustical engineer. Ldn STC of Exterior walls and roof ceiling assemblies or greater STC of Doors and windows Ensure Construction Standards for Sound Attenuation Are Met: Ensure contractors are following appropriate sound attenuation standards as part of new construction or substantial remodels or reconstructions. Other Sensitive Uses in MIA 4: MIA 4 is not considered suitable for the following uses: Public or private schools; hospitals; convalescent facilities; public assembly facilities (such as theaters, stadiums, community centers, churches, and similar facilities); and libraries. Yes Refer to discussion under Strategy 10. Yes The project site is located partially within MIA 4. Within the designated MIA 4 area, Alternatives 1, 2 and 3 would not result in the construction of public or private schools; hospitals; convalescent facilities; public assembly facilities (including theaters, stadiums, community centers, churches, and similar facilities); or libraries. Therefore, Alternatives 1, 2, and 3 are consistent with this strategy. 44 Develop Specific Memorandum of Understandings (MOUs) to Implement JLUS Recommendations: Sign specific MOUs between individual jurisdictions and Fairchild AFB as tools are adopted. MOUs should cover: interagency coordination and other tools involving the interaction of two or more jurisdictions, agencies or Fairchild AFB. Yes Mitigation in Section of this Draft EIS requires the Tribe to make a good faith effort to enter into a memorandum of understanding, or similar agreement, with the Fairchild AFB that addresses compatibility issues associated with potential nuisances that may be caused by AFB operations on proposed land uses within the project site. The Tribe and Fairchild AFB are engaged in on-going discussions regarding the feasibility of entering into an MOU or interagency agreement. In the event that an agreement cannot be negotiated, mitigation in Section requires the Tribe to adopt a tribal ordinance as an alternative mechanism for implementation of equivalent mitigation commitments. Therefore, with mitigation, Alternatives 1, 2, and 3 are consistent with this strategy. 50 Intensity Standards for Non-Residential Yes The area proposed for development within the Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

75 Uses: Non-residential uses in MIA 4 can have a maximum occupancy of 150 persons per gross acre. Gross acreage is measured based on the site for a given use. In other words, the building or structure and land area associated with that development (parking, storage, etc). project site consists of approximately 121 acres (not including the pre-existing Spoko Fuel and wetland preservation area). Assuming a maximum occupancy of 150 persons per gross acre, approximately 18,150 persons would be allowed within the project site under the recommendations of this strategy. Under full build-out conditions, Alternative 1 would employ 2,087 persons, and is expected to experience an average of 7,734 patrons per day. Using an overly conservative assumption that all patrons and employees would be present within the site at the same time, the total number of people within the site would be 9,821 under Alternative 1, which is well below the maximum occupancy level recommended by this strategy. The number of employees and patrons under Alternatives 2 and 3 would be less than Alternative 1. Therefore, Alternatives 1, 2, and 3 are consistent with this strategy. 53 Ensure FAA Part 77 Compliance: For all structures, ensure compliance with FAA Part 77 requirements when establishing height regulations or restrictions. Yes The FAA conducted an aeronautical study under the provisions of Title 49 USC, Section 44718, and Title 14 CFR Part 77 which concluded that the highest structure proposed within the site, the 145-foot hotel tower, would not be a hazard to air navigation (Appendix K). Therefore, Alternatives 1, 2, and 3 are consistent with this strategy. 54 Develop or Update Light and Glare Controls: Develop or update light and glare controls to protect the operational environment near Fairchild AFB. These controls should be designed to reduce the amount of light that spills into surrounding areas and impacts regional ambient illumination. Yes At this time, the City of Airway Heights, Spokane County, and Fairchild AFB have not established controls related to light and glare to protect the operational environment near the AFB. As discussed in Section 4.13, the following would be incorporated into the design of Alternative 1: downcast lighting and low-pressure sodium bulbs would be used in the landscaped and parking areas to minimize off-site scatter; lighting fixtures would be an integral part of the overall design and strategically positioned to minimize any direct site lines or glare to the public. Through the use of downcast and directed lighting, low-pressure sodium bulbs, and strategically positioned lighting fixtures, the impacts of lighting off-site would be minimized and would not be adverse. Mitigation measures have been included within Section to minimize glare caused by the use of glass panels and reflective ornamental detailing in the project design. Therefore, with mitigation, Alternatives 1, 2 and 3 are consistent with the goals of this strategy. Source: Spokane County, 2009 Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

76 Consistency with Applicable Airport Overlay Zone Requirements Effective at Time of Master Plan Preparation The project site is located within the designated Airport Overlay Zone for both the City and Spokane County. While the project site was annexed into the City, and therefore County land use regulations would not apply even is the site were not located in federal trust, Section 4.0 of the IGA, as amended, requires the Tribe to prepare a Master Plan for the project site that complies with Spokane County s Airport Overlay Zone (Chapter of the Spokane County Zoning Code) and any similar City regulation (i.e. Chapters and of the City s Municipal Code). In the event of an inconsistency between the County s and City s regulations, the more restrictive shall apply. A summary of applicable Airport Overlay Zone policies in place at the time the Master Plan for Alternative 1 was prepared and a discussion of consistency with these policies is provided in Table Mitigation measures are included within Section 5.0 to ensure that Alternative 1 is in compliance with the applicable requirements of the Spokane County and the City s Airport Overlay Zone codes in effect at the time the Master Plan for Alternative 1 was prepared in accordance with the IGA. After mitigation, Alternative 1 would not result in adverse effects associated with land use conflicts with Fairchild AFB and SIA operations. TABLE CONSISTENCY WITH APPLICABLE COUNTY AND CITY AIRPORT OVERLAY ZONE POLICIES Policy Consistent Discussion Spokane County Airport Overlay Zone General Use Restrictions No use shall be made of any land in the conical area that would cause any one of the following circumstances. a. The use creates or causes interference with the operations of radio or electronic facilities at the airport or with radio or electronic communications between airport and aircraft. b. The use makes it difficult for pilots to distinguish between airport lights and other lights. c. The use results in glare in the eyes of pilots using the airports, d. The use impairs visibility in the vicinity of the airport. e. The use endangers the landing, taking off, or maneuvering of aircraft. f. The use creates a bird attractant that, in the opinion of the airport, could interfere with aircraft operations. Yes The project site is located within the conical area as defined by the Spokane County code. Alternatives 1, 2, and 3 would not cause any of the circumstances restricted by this policy for the following reasons: a. None of the alternatives propose the development of any land uses that would interfere with the operations of radio or electronic facilities at the airport or with radio or electronic communications between airport and aircraft b-e. Through the use of downcast and directed lighting, low-pressure sodium bulbs, and strategically positioned lighting fixtures, the impacts of lighting would be minimized and would not be adverse. Mitigation measures have been included within Section to minimize glare caused by the use of glass panels and reflective ornamental detailing in the project design. Further, the FAA conducted an aeronautical study under the provisions of Title 49 USC, Section 44718, and Title 14 CFR Part 77 which concluded that the highest structure proposed within the site, the 145-foot hotel tower, would not be a hazard to air navigation (Appendix K). Therefore, with mitigation, Alternatives 1, 2, and 3 are consistent with this policy. f. Mitigation measures have been included within Section to control bird and wildlife attractions on the project site as recommended by the Fairchild AFB during cooperating agency consultation. Therefore, with mitigation, Alternatives 1, 2, and 3 are consistent with this policy, Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

77 City of Airway Heights Airport Overlay Zone and Air Installation Compatible Use Zone General Use Restrictions and General Use Restrictions In addition to the General Use Restrictions listed within Chapter of the Spokane County Code, before development within the conical area, the awarding of an avigation easement to the appropriate airport(s) shall be required and recorded with the Spokane County Auditor s Office Yes Mitigation in Section of this Draft EIS requires the Tribe to make a good faith effort to enter into a memorandum of understanding, or similar agreement, with the Fairchild AFB that addresses compatibility issues associated with potential nuisances that may be caused by AFB operations on proposed land uses within the project site. Required acknowledgements and commitments within this agreement would be the equivalent of language included within a typical avigation easement (an example of an avigation easement can be found in Appendix E of the JLUS). Therefore, with mitigation, Alternatives 1, 2, and 3 are consistent with these policies Height Restrictions, Administrative Height Variances, and Height Restrictions No structure or object of natural growth shall be constructed, altered, maintained, or allowed to grow in any airspace area as described hereinabove so as to project above the conical surface, with several exceptions. In all cases, no structure shall be erected so high as to increase the Federal Aviation Administration landing and approach and departure minimums for aircraft using the runways of the affected airports. Height variances may be granted for several reasons as listed in the code, including if it should it be determined that the structure will not exceed specifications identified in the Federal Aviation Regulations, Part 77, Objects Affecting Navigable Airspace, Sections 77.23, 77.25, and Yes The FAA conducted an aeronautical study under the provisions of Title 49 USC, Section 44718, and Title 14 CFR Part 77 which concluded that the highest structure proposed within the site, the 145-foot hotel tower, would not be a hazard to air navigation (Appendix K). Therefore, Alternatives 1, 2, and 3 are consistent with these policies Substantial Noise Impact Areas (Ldn-65) Substantial noise impact areas are defined as those areas where it has been determined that existing or potential noise levels exceed 65 Ldn (day-night average sound level) Substantial Noise Impact Areas Prohibited Uses In areas where substantial noise impacts exist, the following uses are prohibited: A. Churches; B. Hospitals; C. Libraries; D. Manufactured (mobile) home parks; E. Nursing homes; F. All residential uses; Yes As shown on Figure 3.9-5, the project site is outside the existing 65 Ldn noise contour of the Fairchild AFB and SIA as determined by the 2007 AICUZ, and, therefore, is within the recommended average noise limits for commercial uses. Alternatives 1, 2 and 3 do not propose the development of churches, hospitals, libraries, manufactured home parks, nursing homes, residential uses or schools within the project site. Therefore, Alternatives 1, 2 and 3 are consistent with these policies. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

78 G. Schools Substantial Noise Impact Areas (Ldn 65) Proposed uses in FAFB noise zones shall be in accordance with the land use requirements contained in Table 1. Spokane County, 2010b; City of Airway Heights, Agriculture While the project site contains prime agricultural soils, there are no farming operations on the site or infrastructure that would support land cultivation. As previously discussed in Section 3.9.2, prior to being annexed into the city limits of the City, the project site was located within the County s designated UGA and the City s JPA (Spokane County, 2010; City of Airway Heights, 2006; Spokane County, 2011b). Consultation with the National Resource Conservation Service (NRCS) has confirmed, in accordance with 7 CFR 658.2, that because the project site is set aside for urban development under the County s UGA it is not farmland and, therefore, is not subject to protection under the Farmland Protection Policy Act (FPPA) (Neils, 2011). Alternative 1 would not result in significant adverse effects to agricultural resources ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Effects to Existing Land Uses Alternative 2 would result in the development of a casino-resort facility, site retail, commercial building, tribal cultural center, and police/fire station on existing tribal trust property which is not subject to state or local land use regulations. As discussed above, the Tribal Council has jurisdictional authority over land use matters on the federal trust lands held on their behalf; however, the Tribal Council desires to work cooperatively with local and state authorities on land use matters. The IGA and MOA entered into by the Tribe, City, and Spokane County also apply to Alternative 2 (Appendix C). The annexation of the project site into the City became effective on April 30, Similar to Alternative 1, Alternative 2 has the potential to result in significant impacts to adjacent sensitive receptors as discussed in detail in the other topical sections of this EIS. Impacts may include, but are not limited to, air quality and noise effects from construction and operational activities (Sections 4.4 and 4.11 respectively); congestion on local roads from increased traffic (Section 4.8); and alterations of the visual resources and aesthetics of the surrounding area (Section 4.13). Implementation of mitigation measures identified in Section 5.0 would reduce significant impacts to less than significant levels. Additionally, Alternative 2 has the potential to result in land use conflicts with airport operations due to light and glare resulting from building materials, and wildlife attractants resulting from the development of storm water bio-filtration swales. Potential conflicts resulting from the development of a hotel would be avoided under Alternative 2. With the implementation of mitigation measures recommended in Section and , Alternative 2 would be consistent with applicable strategies of Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

79 the Fairchild JLUS as well as the policies of Spokane County and the City of Airway Heights Airport Overlay Zone codes related to land use in the vicinity of the Fairchild AFB and SIA (refer to discussion in Table and Table 4.9-2). Therefore, after mitigation, Alternative 2 would result in less than significant effects associated with land use conflicts. Agriculture As discussed under Alternative 1, consultation with the NRCS has determined that the project site is not subject to protection under the FPPA due to the fact that it has been set aside for urban development (Neils, 2011). Therefore, Alternative 2 would not result in significant adverse effects to agricultural resources ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Effects to Existing Land Uses Similar to Alternative 1, Alternative 3 would result in the development of site retail, commercial building, tribal cultural center, and police/fire station on existing tribal trust property which is not subject to state or local land use regulations. Although Alternative 3 does not include a casino-resort facility, it does include a mixed-use complex with entertainment venues and hotel, similar in size to Alternative 1. As discussed above, the Tribal Council has jurisdictional authority over land use matters on the federal trust lands held on their behalf; however, the Tribal Council desires to work cooperatively with local and state authorities on land use matters. The IGA entered into by the Tribe, City, and Spokane County also applies to Alternative 3 (Appendix C). It is assumed that an agreement similar to the MOA, provided in Appendix C, would be executed prior to construction of Alternative 3. The annexation of the project site into the City became effective on April 30, Similar to Alternative 1, development of Alternative 3 has the potential to result in significant impacts to adjacent sensitive receptors as discussed in detail in the other topical sections of this EIS. Impacts may include, but are not limited to, air quality and noise effects from construction and operational activities (Sections 4.4 and 4.11 respectively); congestion on local roads from increased traffic (Section 4.8); and alterations to views of the project site and surrounding area (Section 4.13). Implementation of mitigation measures identified in Section 5.0 would reduce significant impacts to less than significant levels. Additionally, Alternative 3 has the potential to result in land use conflicts with airport operations due to light and glare resulting from building materials, and wildlife attractants resulting from the development of storm water bio-filtration swales. Additionally, Alternative 3 would result in exposure of hotel patrons to future noise levels from air traffic in excess of 65 db Ldn and maximum SEL noise of db at 145 feet agl. With the implementation of mitigation measures recommend in Section 5.2.8, , and , Alternative 3 would be consistent with applicable strategies of the Fairchild JLUS as well as the policies of Spokane County and the City of Airway Heights Airport Overlay Zone codes related to land use in the vicinity of the Fairchild AFB and SIA (refer to discussion in Table and Table 4.9-2). Therefore, after mitigation, Alternative 3 would result in less than significant effects associated with land use conflicts. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

80 Agriculture As discussed under Alternative 1, consultation with the NRCS has determined that the project site is not subject to protection under the FPPA due to the fact that it has been set aside for urban development (Neils, 2011). Therefore, Alternative 3 would not result in significant adverse effects to agricultural resources ALTERNATIVE 4 NO ACTION/ NO DEVELOPMENT Under the No Action/No Development Alternative, current land uses would continue to exist on the project site. No impacts associated with land use and agricultural resources would occur. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

81 4.10 PUBLIC SERVICES ALTERNATIVE 1 PROPOSED CASINO AND MIXED-USE DEVELOPMENT Water Supply In accordance with Section 2.0 of the Intergovernmental Agreement (IGA) (Appendix C), the City of Airway Heights (City) public water system will serve the project site through connections to be provided to the project site at the Spokane Tribe of Indians (Tribe) sole cost and expense. Domestic water would be provided by extensions of the City water system at two locations; one at the west end of 6 th Street and one near the intersection of 12 th Street and Craig Road. Recycled water, consisting of treated effluent from the City s Wastewater Treatment, Reclamation, and Recharge Facility (WTRRF), which became fully operational in May 2012, would be used for irrigation and other non-potable uses. As stated in Section 2.3.1, the estimated average daily domestic water demand for consumption, food preparation, sanitation, and other general water requirements for Alternative 1 is approximately 205,570 gallons per day (gpd) and the peak hour demand is estimated at 500 gpm. It is estimated that landscaping would require an additional 14,000 to 17,000 gpd and the water cooling system for the central plant would require an additional 10,000 to 15,000 gpd. However, irrigation water and water for the cooling system would be obtained from the WTRRF and would not be an additional demand on the City s municipal water system. There is an additional requirement of 2,250 gallons per minute (gpm) for 4 hours of emergency fire hydrant flow and an additional 750 gpm for fire sprinkler flow (Hahn Engineering, 2011). The simultaneous combination of Alternative 1 s peak domestic flow, fire sprinkler flow, and fire hydrant flow, totaling approximately 3,500 gpm would result in the highest demand to the City s municipal system. Table shows the water demand for build out of Alternative 1. TABLE ALTERNATIVE 1 TOTAL DEMAND SUMMARY FOR BUILDOUT (GPM) Fire Hydrant Flow Fire Sprinkler Flow Peak Domestic Flow Total Peak Flow 2, ,500 Source: Hahn Engineering, 2011 As described in Section , the City currently produces approximately 2.5 million gpd from four wells, which is routed to two storage facilities with a combined capacity of 1.14 million gallons. The City is currently planning to expand its water supply by constructing an additional water reservoir with at least 1.0 million gallons of capacity, developing the WTRRF which will reduce the demand for potable water for irrigation and industrial uses, initiating an aquifer storage and recovery program, and replacing one of the existing wells with a 1,200 gpm well. Century West, on behalf of the City, completed a water capacity analysis for the proposed project. The analysis concluded that with the addition of the 1,200 gpm well and the use of reclaimed water from the WTRRF, the City would have sufficient capacity to serve the projected demands of Alternative 1 (Century West, 2011). However, to ensure that fire flow demands will be consistently met over time Alternative 1 requires 500,000 gallons of additional storage (Hahn Engineering, 2011). Pending an agreement with the City, this additional storage would either be Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

82 provided by an onsite storage tank (see Figure 2-4) or through the City s construction of a 500,000 gallon water reservoir on Deno Way adjacent to the 1.0 million gallon reservoir described in Section , for which the Tribe would pay its fair share. No significant direct effects to the City s water supply sources would occur as a result of Alternative 1. Cumulative impacts to the City s water supply sources are discussed in detail in Section Indirect effects associated with the expansion of the City s water supply infrastructure are discussed in Section As described in Section , project site would be connected to the City s existing system at two locations; one at the west end of 6 th Street and one near the intersection of 12 th Street and Craig Road. The City s existing distribution facilities have available capacity to service the increased demands from Alternative 1 (Hahn Engineering, 2011). Cumulative impacts to the City s distribution facilities are discussed in detail in Section In accordance with Section 2.0 of the IGA, upon connection to the City s water system the Tribe would pay the current water capital connection charges and monthly service fees, as well as fund the extension of the City s municipal system to the project site (Appendix C). This fair share compensation would allow the City to expand its water supply infrastructure as necessary to serve the proposed development. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City s public water system and level of service would occur. As discussed in Section , the City of Airway Heights has an intertie agreement with the City of Spokane in which the City of Spokane agrees to sell water, at established city rates, to the City when conditions exist whereby the [City s] water system cannot furnish adequate water. Although the use of reclaimed water from the WTRRF is anticipated to reduce the City of Airway Heights demand of potable water from the City of Spokane, there is a potential for the project to utilize water this agreement. Pursuant to the agreement, the City of Airway Heights shall pay for supplied water at the established city rates. These payments will be funded by the monthly service fees paid by water users served by the City, including the Tribe. The payments to the City of Spokane would allow the City of Spokane to maintain its water supply infrastructure as necessary to serve the proposed development. Furthermore, should the demands of the City of Airway Heights exceed the City of Spokane s capacity to meet its needs, the City of Spokane has the right to temporarily discontinue water service; thereby preventing significant impacts to the City of Spokane s water supply system. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City of Spokane s public water system and level of service would occur. Wastewater Service In accordance with Section 2.0 of the IGA (Appendix C), the City s public sewer and wastewater treatment system shall serve the project site through connections to be provided to the project site at the Tribe s sole cost and expense. As stated in Section 2.3.1, the projected average daily wastewater flow for Alternative 1 would be approximately 199,410 gpd. As discussed in Section , Phase I of the City s WTRRF began operating in May Phase I of the WTRRF has an average daily treatment capacity of 1 million gallons per day (mgd). In accordance with the Washington Department of Ecology (DOE) requirements, Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

83 construction of subsequent phases, which would increase the total capacity to 3.0 mgd (City of Airway Heights, 2011b), is triggered when the previous phase operates at or above 80 percent of its design capacity. As discussed in Section 3.10, the WTRRF was operating at approximately 50 percent of its design capacity in June 2012 (Cochran, 2012). Additional wastewater flows resulting from Phase 1 of Alternative 1 in conjunction with other growth expected in the city would likely cause the existing treatment facility to operate at or above 80 percent of its design capacity, thus triggering the construction of the Phase II expansion of the WTRRF. Phase II of the WTRRF would have ample capacity to treat wastewater generated under Phase 2 and 3 of Alternative 1 (Hahn Engineering, 2011). Because the WTRRF was designed to have the flexibility to provide increased treatment capacity to meet future demands through construction of additional modular units, no significant adverse effects to the City s wastewater treatment capacity would occur as a result of Alternative 1. Cumulative impacts to the City s wastewater treatment capacity are discussed in detail in Section Indirect effects associated with the Phase II expansion of the City s WTRRF are discussed in Section As described in Section , the project site would be connected to the City s existing wastewater collection system, at the Tribe s sole cost and expense, through a lift station on the eastern portion of the site, which will then pump the wastewater via a 4-inch diameter force main south under U.S. Highway 2 (US-2) then convert to gravity flow continuing south down Craig Road, and east on 21 st Avenue to the WTRRF located at the corner of 21 st Avenue and Russell Street (see Figure ). Cumulative impacts to the City s wastewater collection system are discussed in detail in Section Indirect effects associated with the extension of the collection system are discussed in Section In accordance Section 2.0 of the IGA, upon connection to the City s sewer system the Tribe would pay the current capital connection charges and monthly service fees, as well as fund the extension of the City s municipal system to the project site (Appendix C). This fair share compensation would allow the City to expand its sewer collection infrastructure as necessary to serve the proposed development. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City s public sewer and wastewater treatment system and level of service would occur. Solid Waste Service Construction Construction of Alternative 1 would result in a temporary increase in waste generation. Potential solid waste streams from construction are expected to include paper, wood, glass, aluminum and plastics from packing materials; waste lumber; insulation; empty non-hazardous chemical containers; concrete; metal, including steel from welding/cutting operations; and electrical wiring. Waste that cannot be recycled or disposed of at the Waste to Energy (WTE) Recycling Center/Disposal Site would be disposed of at either the Northside Landfill (NSLF) or the Roosevelt Regional Landfill (RRLF), which accepts construction/ demolition materials. As discussed in Section , the available capacity for the NSLF and RRLF is 1.4 million tons and 170 million tons, respectively. Construction of Alternative 1 would not result in significant effects on solid waste services. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

84 Operation As described in Section , the project site is located within the service area of Sunshine Disposal and Recycling, Inc (Sunshine Disposal). It is anticipated that the Tribe will contract with Sunshine Disposal for solid waste collection service. Waste generated under Alternative 1 would be handled appropriately through disposal at the facilities described in Section Based on the generation rates of similar gaming facilities, it is estimated that Alternative 1 would generate approximately 2.4 tons per day of trash (Table ). Landscaping and maintenance staff would pick up any trash that is left on the property. Decorative receptacles for trash and recycling would be placed strategically throughout the casino, hotel, and associated facilities to discourage littering. As discussed above, waste that cannot be recycled or disposed of at the WTE Recycling Center/Disposal Site would be disposed of at either NSLF or the RRLF. The solid waste from Alternative 1 would represent approximately 886 tons per year, which is equal to 0.53 percent of the WTE s yearly capacity, 0.55 percent of Phase 2 of the NSLF, or percent of the RRLF s remaining capacity. Operation of Alternative 1 would not result in a significant amount of solid waste being transported to the WTE or landfills. Operation of Alternative 1 would not result in significant effects on solid waste services. TABLE ESTIMATED SOLID WASTE DISPOSAL ALTERNATIVE 1 Waste Waste Generation Source Generation Rate 1 Units Value Total Waste (lb/day) Hotel 2 lb/room/day Casino (other services) 3.12 lb/100 sf/day 98, Restaurant lb/sf/day 56, Commercial Retail 2.5 lb/ksf/day 359, Total lb/day Total ton/year Total cy/year 5, Source: AES, 2011 Law Enforcement An analysis of the impact of casino gambling on local crime rates is included in Section 4.7. As discussed in Section 2.3.1, law enforcement services and prosecution, court, and jail services would be provided by the City of Airway Heights Police Department (AHPD) pursuant to Section 2.2 of the Memorandum of Agreement (MOA) between the Tribe and City (Appendix C), as described in Section The AHPD would not need any additional facilities or equipment to meet the increased need for services under Alternative 1 (Swan, 2011). The payments by the Tribe outlined in Section 6.0 of the MOA would compensate the City for costs of impacts associated with increased police services. The onsite tribal police station would facilitate the security responsibilities of the Tribe, as outlined within the Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

85 MOA, including the Tribe s agreement to assist the City in any law enforcement matter where individuals pursued by the City flee to and/or take shelter within the trust property up to and including detention of the individual. Should any additional services be needed from other law enforcement agencies, the Tribe shall provide fair-share assistance t through the existing mechanism established within Section XIV, Public Health and Safety, of the Tribal-State Compact for Class III Gaming (Appendix C). With implementation of the conditions of the MOA and the Tribal-State Compact for Class III Gaming, as discussed in Section 5.2.9, development of Alternative 1 would not result in significant effects on public law enforcement services. Fire Protection and Emergency Medical Services As discussed in Section 2.3.1, fire protection and emergency medical services would be provided by the City of Airway Heights Fire Department (AHFD) pursuant to Section 2.3 of the MOA. Additional fire protection services would be provided by the on-site tribal fire station. As described in Section 1.5.3, the Tribe and the City agree to coordinate emergency service programs and exchange emergency response policies. The AHFD would not need any additional facilities or equipment to meet the increased need for services under Alternative 1 (Ledgerwood, 2011). The payments by the Tribe outlined in Section 6.0 of the MOA would compensate the City for costs of impacts associated with increased fire protection and emergency medical services. The increase in traffic through Fire District 10 West Plains District as a result of Alternative 1 could significantly increase District s call volume. The Tribe shall provide fairshare assistance to District 10 through the existing mechanism established within Section XIV, Public Health and Safety, of the Tribal-State Compact for Class III Gaming (Appendix C). With implementation of the conditions of the MOA and the Tribal-State Compact for Class III Gaming, as discussed in Section 5.2.9, development of Alternative 1 would not result in significant effects on fire protection and emergency services. Electricity and Natural Gas Electricity would be obtained from Inland Power and Light (Inland Power), which currently provides electricity to Spoko Fuel through an underground power line. Inland Power has the capacity to serve Alternative 1 through either existing aboveground and/or underground power lines adjacent to the site or a new semi-dedicated line from its substation located on Craig Road approximately 500 feet north of the northeast corner of the project site (Appendix L). Once an alternative is chosen, Inland Power would work with the Tribe to identify the power facilities needed for each component of the development (Damiano, 2011). The Tribe would be responsible for payment of any fees charged by Inland Power for services/electricity provided to the site. As Inland Power will directly charge the Tribe for services rendered, there will be no effect on existing rate payers. Implementation of Alternative 1 would result in the irreversible and irretrievable commitments of energy resources during operation of Alternative 1. Mitigation has been incorporated into Section for greenhouse gas (GHG) emissions that would result in a reduction of energy use over baseline conditions, reducing the commitment of energy resources to the project. These measures include installation of energy efficient lighting, advanced lighting design including day lighting, solar water heating, and the planting of trees to strategically reduce building cooling requirements. Accordingly, Alternative 1 would not result in significant effects on energy services. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

86 Natural gas service would be provided by Avista Utilities through a connection to either an existing 8- inch diameter high pressure line parallel to US-2 or an existing 6-inch diameter intermediate pressure line along Craig Road north of US-2 both of which are adjacent to the project site (Appendix M). Avista Utilities currently has sufficient capacity to serve Alternative 1 (Wright, 2011); therefore, Alternative 1 would not result in significant effects on natural gas services ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Water Supply As described under Alternative 1, the City s public water system shall serve the project site through connections to be provided to the project site in accordance with the IGA (Appendix C). As stated in Section 2.3.2, the estimated average daily domestic water demand for Alternative 2 is approximately 85,200 gpd and the peak hour demand is estimated at 175 gpm. The quantity and source of water for landscape irrigation and the water cooling system is the same as described under Alternative 1. There is an additional requirement of 1,875 gpm for 3 hours of emergency fire hydrant flow and an additional 397 gpm for fire sprinkler flow (Hahn Engineering, 2011). The simultaneous combination of Alternative 2 s peak domestic flow, fire sprinkler flow, and fire hydrant flow, totaling approximately 2,447 gpm would result in the highest demand to the City s municipal system. Table shows the water demand for build out of Alternative 2. TABLE ALTERNATIVE 2 TOTAL DEMAND SUMMARY FOR BUILDOUT (GPM) Fire Hydrant Flow Fire Sprinkler Flow Peak Domestic Flow Total Peak Flow 1, ,447 Source: Hahn Engineering, 2011 With the addition of the 1200 gpm well and the use of reclaimed water from the WTRRF, the City would have sufficient capacity to serve the projected demands of Alternative 2 (Century West, 2011). However, Alternative 2 would require the same amount of additional water storage as Alternative 1. No significant direct effects to the City s water supply sources would occur as a result of Alternative 2. Cumulative impacts to the City s water supply sources are discussed in detail in Section Indirect effects associated with the expansion of the City s water supply infrastructure are discussed in Section Alternative 2 would connect to the City s existing water supply system in the same manner as described under Alternative 1. The City s existing distribution facilities have available capacity to service the increased demands from Alternative 2 (Hahn Engineering, 2011). Cumulative impacts to the City s distribution facilities are discussed in detail in Section As described under Alternative 1, upon connection to the City s water system the Tribe would pay the current water capital connection charges and monthly service fees, as well as fund the extension of the Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

87 City s municipal system to the project site in accordance Section 2.0 of the IGA, (Appendix C). This fair share compensation would allow the City to expand its water supply infrastructure as necessary to serve Alternative 2. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City s public water system and level of service would occur under Alternative 2. As with Alternative 1, there is a potential for the project to utilize water obtained under the intertie agreement between the City and the City of Spokane. As described above, pursuant to the agreement, the City of Airway Heights shall pay for supplied water at the established city rates. These payments will be funded by the monthly service fees paid by water users served by the City, including the Tribe. The payments to the City of Spokane would allow the City of Spokane to maintain its water supply infrastructure as necessary to serve the proposed development. Furthermore, should the demands of the City of Airway Heights exceed the City of Spokane s capacity to meet its needs, the City of Spokane has the right to temporarily discontinue providing water service; thereby preventing significant impacts to the City of Spokane s water supply system. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City of Spokane s public water system and level of service would occur. Wastewater Service As described under Alternative 1, the City s public sewer and water treatment system shall serve the project site through connections to be provided to the project site in accordance with the IGA (Appendix C). As with Alternative 1, Alternative 2 in conjunction with other growth expected in the City would likely cause the existing treatment facility to operate at or above 80 percent of its design capacity, thus triggering the construction of Phase II of the WTRRF (Hahn Engineering, 2011). Because the WTRRF was designed to have the flexibility to provide increased treatment capacity through construction of additional modular units to meet future capacity needs, no significant adverse effects to the City s wastewater treatment capacity would occur as a result of Alternative 2. Cumulative impacts to the City s wastewater treatment capacity are discussed in detail in Section 4.15, and indirect effects associated with the Phase II expansion of the City s WTRRF are discussed in Section Alternative 2 would be connected to the City s existing wastewater collection system through the same route as described under Alternative 1. Cumulative impacts to the City s wastewater collection system are discussed in detail in Section Indirect effects associated with the extension of the collection system are discussed in Section As described under Alternative 1, upon connection to the City s sewer system the Tribe would pay the current capital connection charges and monthly service fees, as well as fund the extension of the City s municipal system to the project site in accordance Section 2.0 of the IGA (Appendix C). This fair share compensation would allow the City to expand its sewer collection infrastructure as necessary to serve Alternative 2. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City s public sewer and wastewater treatment system and level of service would occur under Alternative 2. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

88 Solid Waste Service Construction Construction of Alternative 2 would result in waste generation similar to that described under Alternative 1. Construction of Alternative 2 would not result in significant effects on solid waste services. Operation As with Alternative 1, it is anticipated that the Tribe will contract with Sunshine Disposal for solid waste collection service. Based on generation rates at similar facilities, Alternative 2 would generate approximately 1 ton per day of trash (Table ). Methods of trash and littering reduction are similar to those described under Alternative 1. Waste generated under Alternative 1 would be handled appropriately through disposal at the facilities described in Section The solid waste from Alternative 2 would represent approximately 372 tons per year, which is equal to 0.15 percent of the WTE s yearly capacity, 0.23 percent of Phase 2 of the NSLF, or percent of the RRLF s remaining capacity. Alternative 2 would not result in a significant amount of solid waste being transported to the landfill. Operation of Alternative 2 would not result in significant effects on solid waste services. TABLE ESTIMATED SOLID WASTE DISPOSAL ALTERNATIVE 2 Waste Waste Generation Source Generation Rate 1 Units Value Total Waste (lb/day) Hotel 2 lb/room/day 0 0 Casino (other services) 3.12 lb/100 sf/day 61, Restaurant lb/sf/day 26, Total lb/day Total ton/year Total cy/year Source: AES, 2011 Law Enforcement An analysis of the impact of casino gambling on local crime rates is included in Section 4.7. The AHPD would not need any additional facilities or equipment to meet the increased need for services under Alternative 2 in accordance with Section 2.2 of the MOA (Swan, 2011). Similar to Alternative 1, development of Alternative 2 would not result in significant effects on law enforcement services with implementation of the conditions of the MOA and the Tribal-State Compact for Class III Gaming, as discussed in Section Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

89 Fire Protection and Emergency Medical Services The AHFD would not need any additional facilities or equipment to meet the increased need for services under Alternative 2 in accordance with Section 2.3 of the MOA (Ledgerwood, 2011) and District 10 would be assisted through the impact mitigation fund established in accordance with the Tribal-State Compact for Class III Gaming. Similar to Alternative 1, development of Alternative 2 would not result in significant effects on fire protection and emergency medical services with implementation of the conditions of the MOA and the Tribal-State Compact for Class III Gaming, as discussed in Section Electricity and Natural Gas As with Alternative 1, electricity for Alternative 2 would be obtained from Inland Power, which currently has the capacity to serve Alternative 2 from its substation located on Craig Road. Once an Alternative is chosen, Inland Power would work with the Tribe to identify power facilities needed for each component of the development (Damiano, 2011; Appendix L). The Tribe would be responsible for payment of any fees charged by Inland Power for services/electricity provided to the site. As Inland Power will directly charge the Tribe for services rendered, there will be no effect on existing rate payers. Implementation of Alternative 2 would result in the irreversible and irretrievable commitments of energy resources during operation, although to a lesser extant that during operation of Alternative 1. Mitigation has been incorporated into Section for greenhouse gas (GHG) emissions that would result in a reduction of energy use over baseline conditions, reducing the commitment of energy resources to the project. These measures include installation of energy efficient lighting, advanced lighting design including day lighting, solar water heating, and the planting of trees to strategically reduce building cooling requirements. Accordingly, Alternative 2 would not result in significant effects on energy services. As with Alternative 1, natural gas for Alternative 2 would be provided by Avista Utilities through a connection to either an existing 8-inch diameter high pressure line parallel to US-2 or an existing 6-inch diameter intermediate pressure line along Craig Road north of US-2. Avista Utilities currently has sufficient capacity to serve Alternative 2 (Wright, 2011; Appendix M); therefore, Alternative 2 would not result in significant effects on natural gas services ALTERNATIVE 3 NON GAMING MIXED-USE DEVELOPMENT Water Supply As described under Alternative 1, the City s public water system shall serve the project site through connections to be provided to the project site in accordance with the IGA (Appendix C). As stated in Section 2.3.3, the estimated average daily domestic water demand for Alternative 3 is approximately 156,370 gpd and the peak hour demand is estimated at 515 gpm. The quantity and source of water for landscape irrigation and the water cooling system is the same as described under Alternative 1. There is an additional requirement of 2,250 gpm for 4 hours of emergency fire hydrant flow and an additional 750 gpm for fire sprinkler flow (Hahn Engineering, 2011). The simultaneous combination of Alternative 3 s peak domestic flow, fire sprinkler flow, and fire hydrant flow, totaling approximately Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

90 3,515 gpm would result in the highest demand to the City s municipal system. Table shows the water demand for build out of Alternative 3. TABLE ALTERNATIVE 3 TOTAL DEMAND SUMMARY FOR BUILDOUT (GPM) Fire Hydrant Flow Fire Sprinkler Flow Peak Domestic Flow Total Peak Flow 2, ,515 Source: Hahn Engineering, 2011 With the addition of the 1200 gpm well and the use of reclaimed water from the WTRRF, the City would have sufficient capacity to serve the projected demands of Alternative 3 (Century West, 2011). However, Alternative 3 would require the same amount of additional water storage as Alternative 1. No significant direct effects to the City s water supply sources would occur as a result of Alternative 3. Cumulative impacts to the City s water supply sources are discussed in detail in Section Indirect effects associated with the expansion of the City s water supply infrastructure are discussed in Section Alternative 3 would connect to the City s existing water supply system in the same manner as described under Alternative 1. The City s existing distribution facilities have available capacity to service the increased demands from Alternative 3 (Hahn Engineering, 2011). Cumulative impacts to the City s distribution facilities are discussed in detail in Section As described under Alternative 1, upon connection to the City s water system the Tribe would pay the current water capital connection charges and monthly service fees, as well as fund the extension of the City s municipal system to the project site in accordance Section 2.0 of the IGA, (Appendix C). This fair share compensation would allow the City to expand its water supply infrastructure as necessary to serve Alternative 3. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City s public water system and level of service would occur under Alternative 3. As with Alternative 1, there is a potential for the project to utilize water this agreement. Pursuant to the agreement, the City of Airway Heights shall pay for supplied water at the established city rates. These payments will be funded by the monthly service fees paid by water users served by the City, including the Tribe. The payments to the City of Spokane would allow the City of Spokane to maintain its water supply infrastructure as necessary to serve the proposed development. Furthermore, should the demands of the City of Airway Heights exceed the City of Spokane s capacity to meet its needs, the City of Spokane has the right to temporarily discontinue providing water service; thereby preventing significant impacts to the City of Spokane s water supply system. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City of Spokane s public water system and level of service would occur. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

91 Wastewater Service As described under Alternative 1, the City s public sewer and water treatment system shall serve the project site through connections to be provided to the project site in accordance with the IGA (Appendix C). As with Alternative 1, Alternative 3 in conjunction with other growth expected in the City would likely cause the existing treatment facility to operate at or above 80 percent of its design capacity, thus triggering the construction of Phase II of the WTRRF (Hahn Engineering, 2011). Because the WTRRF was designed to have the flexibility to provide increased treatment capacity through construction of additional modular units to meet future capacity needs, no significant adverse effects to the City s wastewater treatment capacity would occur as a result of Alternative 3. Cumulative impacts to the City s wastewater treatment capacity are discussed in detail in Section 4.15, and indirect effects associated with the Phase II expansion of the City s WTRRF are discussed in Section Alternative 3 would be connected to the City s existing wastewater collection system through the same route as described under Alternative 1. Cumulative impacts to the City s wastewater collection system are discussed in detail in Section Indirect effects associated with the extension of the collection system are discussed in Section As described under Alternative 1, upon connection to the City s sewer system the Tribe would pay the current capital connection charges and monthly service fees, as well as fund the extension of the City s municipal system to the project site in accordance Section 2.0 of the IGA (Appendix C). This fair share compensation would allow the City to expand its sewer collection infrastructure as necessary to serve Alternative 3. With implementation of the conditions of the IGA, as discussed in Section 5.2.9, no significant effects to the City s public sewer and wastewater treatment system and level of service would occur under Alternative 3. Solid Waste Service Construction Construction of Alternative 3 would result in waste generation similar to that described under Alternative 1. Construction of Alternative 3 would not result in significant effects on solid waste services. Operation As with Alternative 1, it is anticipated that the Tribe will contract with Sunshine Disposal and Recycling, Inc. for solid waste collection service. Based on the generation rates for similar facilities, there is an average generation rate of 0.81 tons per day of trash (Table ). Methods of trash and littering reduction are similar to those described under Alternative 1. Waste generated under Alternative 1 would be handled appropriately through disposal at the facilities described in Section The solid waste from Alternative 3 would represent approximately 297 tons (1,858 cubic yards) per year, which is equal to 0.12 percent of the WTE s yearly capacity, 0.18 percent of Phase 2 of the NSLF, or percent of Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

92 the RRLF s remaining capacity. Therefore, operation of Alternative 3 would not result in significant adverse effects on solid waste services. TABLE ESTIMATED SOLID WASTE DISPOSAL ALTERNATIVE 3 Waste Waste Generation Source Generation Rate 1 Units Value Total Waste (lb/day) Hotel 2 lb/room/day Commercial Retail 2.5 lb/ksf/day 251, restaurant lb/sf/day 79, Total lb/day Total ton/day 0.81 Total ton/year Total cy/year Source: AES, 2011 Law Enforcement As discussed in Section 2.3.3, no agreement with the City has been made at this time to provide law enforcement services to the site under Alternative 3; however, it is assumed that an agreement similar to the MOA provided in Appendix C would be executed prior to construction of Alternative 3. Alternative 3 would result in an increase in need for law enforcement services similar to that of Alternative 1 due to the similarities in land use and size. Since the AHPD has determined that it could provide law enforcement services to Alternative 1 with its existing facilities and equipment (Swan, 2011), the AHPD would also be able to serve Alternative 3. With implementation of an agreement containing conditions similar to that of the MOA, as discussed in Section 5.2.9, development of Alternative 3 would not result in significant effects on law enforcement services. Fire Protection and Emergency Medical Services As discussed in Section 2.3.3, no agreement with the City has been made at this time to fire protection services to the site under Alternative 3; however, it is assumed that an agreement similar to the MOA provided in Appendix C would be executed prior to construction of Alternative 3. Alternative 3 would result in an increase in need for fire protection and emergency medical services similar to that of Alternative 1 due to the similarities in land use and size. Since the AHFD has determined that it could provide fire protection and emergency medical services to Alternative 1 with its existing facilities and equipment (Ledgerwood, 2011), the AHFD would also be able to serve Alternative 3. With implementation of an agreement containing conditions similar to that of the MOA, as discussed in Section 5.2.9, development of Alternative 3 would not result in significant effects on fire protection and emergency medical services. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

93 Electricity and Natural Gas As with Alternative 1, electricity for Alternative 3 would be obtained from Inland Power, which currently has the capacity to serve Alternative 3 from its substation located on Craig Road. Once an Alternative is chosen, Inland Power would work with the Tribe to identify the power facilities needed for each component of the development (Damiano, 2011; Appendix L). The Tribe would be responsible for payment of any fees charged by Inland Power for services/electricity provided to the site. As Inland Power will directly charge the Tribe for services rendered, there will be no effect on existing rate payers. Implementation of Alternative 3 would result in the irreversible and irretrievable commitments of energy resources during operation, although to a lesser extant that during operation of Alternative 1. Mitigation has been incorporated into Section for greenhouse gas (GHG) emissions that would result in a reduction of energy use over baseline conditions, reducing the commitment of energy resources to the project. These measures include installation of energy efficient lighting, advanced lighting design including day lighting, solar water heating, and the planting of trees to strategically reduce building cooling requirements. Accordingly, Alternative 3 would not result in significant adverse effects on energy services. As with Alternative 1, natural gas for Alternative 3 would be provided by Avista Utilities through a connection to either an existing 8-inch diameter high pressure line parallel to US-2 or an existing 6-inch diameter intermediate pressure line along Craig Road north of US-2. Avista Utilities currently has sufficient capacity to serve Alternative 3 (Wright, 2011; Appendix M); therefore, Alternative 3 would not result in significant adverse effects on natural gas services ALTERNATIVE 4 NO ACTION/NO DEVELOPMENT Existing uses on the project site would continue under the No Action/ No Development Alternative. No additional public services would be necessary and, therefore, no impacts to public service providers would occur. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

94 4.11 NOISE This section identifies the direct effects to noise that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section Cumulative and indirect effects are identified in Section 4.15 and Section 4.14, respectively. Measures to mitigate for adverse effects identified in this section are presented in Section METHODOLOGY The assessment of project effects is based on Federal Noise Abatement Criteria (NAC) standards used by the Federal Highway Administration (FHWA) and Washington State Department of Transportation (WSDOT) (Table ). Adverse noise-related effects would occur during construction and operation, if project implementation would result in an increase in the ambient noise environment of greater than 67 decibels (dba), equivalent noise level (Leq), or would result in an audible increase in ambient noise level at sensitive receptor locations including residential housing adjacent to the project site. See Section 3.11 for a definition of sensitive receptors. The assessment of vibration noise is based on the Federal Transportation Administration standards of 0.5 Peak Particle Velocity (PPV) for structures and 0.1 PPV for annoyance of people (FTA, 2006). Sound exposure level (SEL) is a measurement of noise from a single noise source at a particular measuring point. SEL is used to determine what physiological effects are caused by noise from a single event; therefore, SEL noise will be used in determining the annoyance of sensitive receptors when exposed to noise from aircraft flyovers. According to the Federal Aviation Administration (FAA) speech is interrupted at 60 db, which can cause annoyance in sensitive receptors ALTERNATIVE 1 PROPOSED CASINO AND MIXED-USE DEVELOPMENT Construction Noise Construction Traffic Grading and construction associated with Alternative 1 would be intermittent and temporary in nature. The closest receptors that would be exposed to noise during project construction are private residences located along South Craig Road approximately 100 feet east of the project site. Construction noise levels at and near the project site would fluctuate depending on the particular type, number, and duration of uses of various pieces of construction equipment. Construction-related material haul trips and worker trips have the potential to raise ambient noise levels along local routes, depending on the number of worker/haul trips made and types of vehicles used. All construction traffic and deliveries would access the project site via U.S. Highway 2 (US-2). Since Phase III construction results in the greatest number of construction workers and material trips, Phase III would result in greatest increase in noise level; therefore, Phase III is analyzed below. During construction of Phase III a maximum of 537 one-way worker trips would occur per day. Although construction trips would generally occur outside of the peak hour, it is assumed for this noise analysis that all construction trips occur during the peak traffic hour to provide a worst case scenario analysis. It is conservatively estimated that an average of 60 soil and material hauling trips per day or 7 trips per peak Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

95 hour would occur during Phase III construction. Because trucks are louder than passenger cars, a passenger car equivalence (PCE) multiplier of 8 cars per truck was used (TRB, 2000). Therefore, the total equivalent passenger car trips per peak hour would be 593. The traffic volume on US-2 would be 2,254 trips per peak hour during construction of Phase III (TIA, 2011, Appendix D). The existing ambient noise level in the vicinity of US-2 was measured at 72.7 dba, Leq (refer to Section 3.11, Table ). Since the existing ambient noise level in the vicinity of US-2 is greater than the NAC of 67 dba, Leq, significance for the project will be evaluated based on whether the project audibly increases the ambient noise level. As discussed in Section 3.11, a 3 dba increase in noise is barely perceivable. Construction trips would not double the existing traffic volume and would result in a 1 dba Leq increase in the existing ambient noise level (WSDOT, 2009), which is less than 3 dba. Therefore, noise resulting from increased construction traffic would be barely perceivable and would not result in a significant adverse effect to the ambient noise level during any phase of construction. Construction Equipment Construction of Alternative 1 would consist of ground clearing, excavation, erection of foundations and buildings, and finishing work. Table shows typical stationary point source noise levels at 25 feet during different construction stages. TABLE TYPICAL CONSTRUCTION NOISE LEVELS Construction Phase Noise Level at 25 feet (dba Leq) Ground Clearing 84 Excavation 89 Foundations 78 Erection 85 Finishing 89 Source FTA, 2006 Stationary point sources of noise attenuate (lessen) at a rate of 6-9 dba per doubling of distance from the source, depending on environmental conditions (i.e., atmospheric conditions, topography and type of ground surfaces, noise barriers, etc.) (WSDOT, 2004). An attenuation factor of 6.0 dba per doubling of distance is appropriate for this analysis given the flat topography and lack of ground cover on and in the vicinity of the project site. The maximum construction noise at the project site would be 89 dba at 25 feet. Using an attenuation factor of 6.0 dba Leq per doubling of distance, the maximum noise level at the nearest sensitive noise receptor, a private residence, would be 77.0 dba Leq. The maximum noise level at the nearest sensitive noise receptor would be greater than the NAC of 67 dba Leq (Table ). Therefore, there would be a potentially significant effect due to stationary construction noise. Mitigation measures are provided in Section , which are consistent with the State of Washington Administrative Code and when implemented would reduce stationary construction noise. Therefore, Alternative 1 construction noise would not result in significant adverse effects associated with the ambient noise environment. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

96 Construction Vibration Construction activities for Alternative 1, Phases I, II, and III would consist of using earthmoving equipment shown in Table , which can produce detectable or damaging levels of vibration at nearby sensitive land uses, primarily depending on the distance between the source and the nearby sensitive land use. Generally, physical damage is only an issue when construction requires the use of equipment with high vibration levels (i.e., compactors, large dozers, etc) and occurs within 25 feet of an existing structure. Table provides estimated vibration levels at 25 feet and 100 feet from construction activities. The predicted Peak Particle Velocity (PPV) levels are below the significance threshold of 0.5 PPV for structures at 25 feet and 0.1 PPV for annoyance of people at 100 feet (FTA, 2006). Therefore, vibration from construction of Alternative 1 would not result in significant adverse effects to nearby structures and sensitive receptors. TABLE REFERENCE AND PREDICTED PPV FROM CONSTRUCTION OF PHASES I, II AND III Reference PPV at 25 feet Predicted PPV at 100 feet Equipment Inches per Second Large bulldozer Excavator Compactor Scaper Loaded trucks Small bulldozer Note: PPV was predicted using the equation PPV predicted = PPV ref *(D ref/d source)^1.4. Source: FTA, Operation Noise The following identifies potential impacts from project-related noise sources, such as traffic, heating ventilation and air conditioning (HVAC) systems, parking structure and parking lots, and deliveries. Traffic The level of traffic noise depends on: l) the volume of the traffic, 2) the speed of the traffic, and 3) the number of trucks in the flow of the traffic. It is not anticipated that speed in the vicinity of the project site or the mix of trucks in the traffic would change during the operational phase; however, with the implementation of Alternative 1 traffic volumes would increase. US-2 The primary source of noise in the project area is generated by traffic on US-2 approximately 300 feet from nearby sensitive noise receptors. As discussed in the Traffic Impact Analysis (TIA) (Appendix D), there are approximately 2,254 vehicles per peak hour on US-2 adjacent to the project site. Alternative 1 would add an estimated 2,717 vehicles per peak hour to area roadways, of which 60 percent or Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

97 approximately 1,630 vehicles per peak hour would occur on US-2 (Appendix D). The existing ambient noise level in the vicinity of US-2 was measured at 72.7 dba, Leq (refer to Section 3.11, Table ). Since the existing ambient noise level in the vicinity of US-2 is greater than the NAC of 67 dba, Leq, significance for the project will be evaluated based on if the project audible increases the ambient noise level. As discussed in Section 3.11 a 3 dba increase in noise is barely perceivable; therefore, an increase in the ambient noise level of 3 dba would be considered significant. Alternative 1 traffic at buildout would less than double the existing volume of traffic resulting in an increase of the ambient noise level of approximately 2.3 dba Leq; therefore, Alternative 1 would not result in significant adverse effects associated with traffic noise levels for sensitive receptors located in the vicinity of US-2. Craig Road Craig Road is located adjacent to the project site, approximately 25 feet from existing and future sensitive noise receptors. Three proposed access driveways to the project site are located on Craig Road. The existing traffic volume on this roadway is 100 vehicles during the peak hour (TIA, Appendix D). Alternative 1 would add 543 vehicle trips during the peak hour to Craig Road. The existing ambient noise level in the vicinity of Craig Road was measured at 50 dba, Leq (refer to Section 3.11, Table ). Alternative 1 would more than double the traffic volume on Craig Road resulting in a 7.4 dba Leq increase in the ambient noise level. With implementation of Alternative 1, the ambient noise level on Craig Road would be 57.4 dba, Leq, which is less than the NAC of 67 dba, Leq for residential sensitive receptors (Section 3.11, Table ). Therefore, Alternative 1 would not result in significant adverse effects associated with traffic noise levels for sensitive receptors located along Craig Road. Other Noise Sources Commercial uses would bring the possibility of noise due to operations of roof-mounted air handling units associated with building HVAC equipment and noise from loading docks, and the parking lot. The noise levels produced by HVAC systems vary with the capacities of the units, as well as with individual unit design. In this case, HVAC systems on commercial buildings would be located at higher elevations than the residences, so that roof-mounted HVAC equipment has the potential to be heard at nearby sensitive noise receptors. However, given the distance to the nearest sensitive noise receptor, noise from roof mounted HVAC equipment would not be audible. Therefore, Alternative 1 HVAC noise would not result in significant adverse effects associated with the ambient noise environment. Idling trucks at Alternative 1 loading docks have the potential to emit noise of 80 dba at 50 feet from the source (WSDOT, 2004). The proposed loading docks will be located approximately 1,000 feet from the nearest residences located east and west of the property boundaries. Using the attenuation value of 6.0 (refer to construction analysis above) the ambient noise level at the nearest sensitive noise receptor would be 56 dba, Leq, which is less than the NCA of 67 dba, Leq (Section 3.11, Table ). Therefore, Alternative 1 loading dock noise would not result in significant adverse effects associated with the ambient noise environment. Parking structure and lot noise would be mainly due to slow moving and idling vehicles, opening and closing doors, and conversation. The noise level in parking lots and structures is dominated by slow moving vehicles; therefore, the ambient noise level in a parking structure or lot is approximately 60 dba, Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

98 which is less than the NAC of 67 dba. Therefore, Alternative 1 parking structure and lot noise would not result in significant adverse effects associated with the ambient noise environment. Operation Vibration Commercial and hotel uses do not include sources of perceptible vibration. Therefore, operation of Alternative 1 would not result in significant adverse effects associated with vibration. Compatibility with Aircraft Noise and Vibration The western half of the project site is located within Military Influence Area (MIA) 4 as defined by the Fairchild Air Force Base (AFB) Joint Land Use Study (JLUS), the boundaries of which were determined based on the primary areas of aircraft over flight and potential for exposure to noise and vibrations from aircraft under existing conditions and possible future mission scenarios at the AFB (JLUS, Spokane County, 2009). Aircraft routinely fly approximately 500 feet above ground level (agl) directly over the project site for closed patterned training operations from the Fairchild Air Force Base (AFB). The approximately 145-foot hotel tower component of the Proposed Project would place sensitive receptors within 355 feet of air-borne aircraft noise and vibration. Average Noise Levels As shown on Figure 3.9-5, the project site is outside the existing 65 Ldn noise contour of the Fairchild AFB and SIA as determined by the 2007 AICUZ, and, therefore, is within the recommended average noise limits for proposed land uses under Alternative 1. However, as depicted in Figure 3-21 of the 2009 JLUS, the project site is located within the predicted Ldn noise contour for potential future mission scenarios based on a mix of next generation air refueling aircraft (32 KC-767A) and B-52 aircraft (defined as Scenario 3 within the JLUS). Exposure of hotel patrons to noise from aircraft is considered a potentially significant impact as a result of Alternative 1 due to the potential for annoyance and nuisance complaints. Mitigation consistent with Strategies 23 and 27 of the Fairchild JLUS is provided in Section to ensure appropriate sound attenuation methods are utilized during construction of the hotel to minimize the potential for nuisance to Alternative 1 hotel patrons. Single Event Noise As shown in Section 3.11, Table , routine aircraft flying above the project site can produce a maximum SEL of 94.4 db at 145 feet agl (Fairchild AFB, 2011b). Rare single event aircraft that may fly over the site (estimated to occur once every month) would result in SEL noise ranging approximately from 104 db to 112 db at 145 feet agl. SEL noise from aircraft occur approximately ten times per day (refer to Section 3.11, Table ) primarily during the daytime hours (between 6 am to10 pm). The Proposed Project does not propose any outdoor activity areas; thus, the greatest potential for noise effects would be interior levels at the hotel (casino and retail uses on the project site are commercial uses that are not considered sensitive receptors per the JLUS recommendations). Typical building materials provide a sound attenuation of approximately 25 db, resulting in a maximum interior SEL noise from routine passing aircraft of 70 db, and from less frequent transient aircraft of 80 db. SEL noise from passing aircraft would exceed the FAA threshold for speech interference of 60 db and may annoy sensitive Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

99 receptors (refer to Section ). However, the Proposed Project would not result in long-term exposure of sensitive receptors to single event noise from aircraft over flight as patrons at the hotel would not permanently reside on the project site and noise from aircraft would occur infrequently (approximately 10 times per day) and for a limited duration (approximately 10 seconds of peak level noise). Further, maximum exterior and interior SEL from aircraft would cause periodic annoyance and would not result in acute or chronic human health effects (U.S. Navy, 2005). Due to the potential for annoyance and nuisance complaints, SEL noise from aircraft is considered a potentially significant adverse impact to patrons using the hotel component of the Proposed Project. There are no federal, state, or local thresholds for single event noise measured in terms of SEL. Mitigation measures are provided in Section which would reduce interior SEL noise from aircraft. The mitigation measures provided in Section are consistent with Strategies 23 and 27 of the Fairchild Joint Land Use Study. With the incorporation of mitigation, SEL noise from aircraft would not result in a significant adverse effect. Single Event Vibration Levels Noise from aircraft operation, including Fairchild AFB s jet tanker fleet, transient aircraft, and Army helicopters, is the primary source of vibration within the project site (JLUS, Spokane County, 2009). Noise from these aircrafts does not produce sound at the db and frequency levels typically connected with significant vibrations (JLUS, Spokane County, 2009). However, patrons of the hotel may occasionally experience perceptible vibration and the hotel windows may periodically rattle. According to the findings of the Federal Aviation Administration's Noise Abatement Policy, vibration from aircraft passing over the site would not be harmful to humans or damaging to the hotel structure (FAA, 2000). With the implementation of mitigation measures provided in Section , human perception of aircraft vibration would be reduced due the interior noise reduction accomplished by this mitigation measure. Vibrations due to aircraft noise would not result in a significant adverse effect ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Construction Noise Noise impacts resulting from grading and construction associated with Alternative 2 would be similar to Alternative 1. During construction of Alternative 2, a maximum of 443 one-way worker trips would occur per day. It is conservatively estimated that an average of 66 soil and material hauling trips per day or 8 per peak hour would occur during the grading and building phases of construction. The total equivalent passenger car trips assumed per peak hour would be 507. Construction trips would not double the existing traffic volume and would result in a less than 1 dba Leq increase in the existing ambient noise level, which is not audible (WSDOT, 2009). Therefore, Alternative 2 construction traffic noise would not result in significant adverse effects. Noise resulting from construction activities within the project site from Alternative 2 would be similar to Alternative 1. Mitigation measures are provided in Section , which are consistent with the State of Washington Administrative Code and when implemented would reduce stationary construction noise to below the NAC. Therefore, Alternative 2 construction noise would not result in significant adverse effects associated with the ambient noise environment. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

100 Construction Vibration Construction of Alternative 2 would result in similar vibration effects as Alternative 1. Refer to Section Alternative 2 construction vibration would not result in significant adverse effects associated with the ambient noise environment. Operation Noise Traffic US-2 Alternative 2 would add an additional 1,113 vehicles per peak hour to US-2 at buildout (Appendix D). Project traffic at buildout would less than double the existing volume of traffic resulting in an increase of the ambient noise level by approximately 1.7 dba Leq, which is not an audible increase; therefore, Alternative 2 would not result in significant adverse effects associated with the ambient noise level for sensitive receptors in the vicinity of US-2. Craig Road Alternative 2 would add 371 vehicle trips during the peak hour to Craig Road (Appendix D). Alternative 2 would more than double the traffic volume on Craig Road resulting in a 5.1 dba Leq increase in the ambient noise level. With implementation of Alternative 2, the ambient noise level on Craig Road would be 55.1 dba, Leq, which is less than the NAC of 67 dba, Leq for residential sensitive receptors (Section 3.11, Table ). Therefore, Alternative 2 would not result in significant adverse effects associated with traffic noise levels for sensitive receptors located along Craig Road. Other Noise Sources Noise from stationary sources and parking lots resulting from Alternative 2 would be similar to Alternative 1. Refer to Section Therefore, Alternative 3 parking structure and lot noise would not result in significant adverse effects associated with the ambient noise environment. Operation Vibration Commercial uses do not include sources of perceptible vibration. Therefore, operation of Alternative 2 would not result in significant adverse effects associated with vibration. Compatibility with Aircraft Noise and Vibration Under Alternative 2, aircraft noise at the project site would be the same as Alternative 1. However, Alternative 2 does not have a hotel component. Alternative 2 would not place noise sensitive receptors in an environment which exceeds recommended noise thresholds for commercial uses. Alternative 2 would not result in significant land use compatibility effects due to aircraft noise and vibration within the project site. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

101 ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Construction Noise Noise impacts resulting from grading and construction associated with Alternative 3 would be similar to Alternative 1. During construction of Alternative 3, a maximum of 837 one-way worker trips per peak hour would occur per day. It is conservatively estimated that an average of 66 soil and material hauling trips per day or 8 per peak hour would occur during the grading and building phases of construction. The total equivalent passenger car trips assumed per peak hour would be 925. Construction trips would not double the existing traffic volume and would result in a 1.5 dba Leq increase in the existing ambient noise level, which is not audible (WSDOT, 2009). Therefore, Alternative 3 construction traffic noise would not result in significant adverse effects. Noise resulting from construction activities within the project site from Alternative 3 would be similar to Alternative 1. Mitigation measures are provided in Section , which are consistent with the State of Washington Administrative Code and when implemented would reduce stationary construction noise to below the NAC. Therefore, Alternative 3 construction noise would not result in significant adverse effects associated with the ambient noise environment. Construction Vibration Construction of Alternative 3 would result in similar vibration effects as Alternative 1. Refer to Section Alternative 3 construction vibration would not result in significant adverse effects associated with the ambient noise environment. Operation Noise Traffic US-2 Alternative 3 would add an additional 908 vehicles per peak hour on US-2 at buildout (Appendix D). Project traffic at buildout would less than double the existing volume of traffic resulting in an increase of the ambient noise level of 1.5 dba Leq, which is not an audible increase; therefore, Alternative 3 would not result in significant adverse effects associated with the ambient noise level for sensitive receptors in the vicinity of US-2. Craig Road Alternative 3 would add 303 vehicle trips during the peak hour to Craig Road (Appendix D). Alternative 3 would more than double the traffic volume on Craig Road resulting in a 4.5 dba Leq increase in the ambient noise level. With implementation of Alternative 3, the ambient noise level on Craig Road would be 54.4 dba, Leq, which is less than the NCA of 67 dba, Leq for residential sensitive receptors (Section 3.11, Table ). Therefore, Alternative 3 would not result in significant adverse effects associated with traffic noise levels for sensitive receptors located along Craig Road. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

102 Other Noise Sources Noise from stationary sources and parking lots resulting from Alternative 3 would be similar to Alternative 1. Refer to Section Therefore, Alternative 3 parking structure and lot noise would not result in significant adverse effects associated with the ambient noise environment. Operation Vibration Commercial and hotel uses do not include sources of perceptible vibration. Therefore, operation of Alternative 3 would not result in significant adverse effects associated with vibration. Compatibility with Aircraft Noise and Vibration Under Alternative 3, aircraft noise at the project site would be the same as Alternative 1. Exposure of hotel patrons to noise from aircraft is considered a potentially significant impact as a result of Alternative 3 due to the potential for annoyance and nuisance complaints. Mitigation consistent with Strategies 23 and 27 of the Fairchild JLUS is provided in Section to ensure appropriate sound attenuation methods are utilized during construction of the hotel to minimize the potential for nuisance to Alternative 3 hotel patrons ALTERNATIVE 4 NO ACTION/NO DEVELOPMENT Under the No Action/No Development Alternative, a change in the current land use of the project site is not reasonably foreseeable. None of the potentially effects identified for Alternatives 1 through 3 are anticipated to occur. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

103 4.12 HAZARDOUS MATERIALS This section identifies the effects to hazardous materials that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section Cumulative and indirect effects are identified in Section 4.15 and Section 4.14, respectively. Measures to mitigate for adverse effects identified in this section are presented in Section ALTERNATIVE 1 PROPOSED CASINO AND MIXED-USE DEVELOPMENT Construction There are no reported hazardous materials spills, violations, or instances of recorded contamination within the proposed development areas on the project site. The Spoko Fuels service station, located on the southwestern corner of the project site, contains three underground storage tanks (USTs) containing petroleum products. Due to the contained nature of the USTs, lack of reported violations, and the distance between the Spoko Fuels service station and Alternative 1 components, the hazardous materials (diesel and gasoline) located on the project site would not create a significant impact. The possibility does exist that undiscovered contaminated soil and/or groundwater is present on the site due to hazardous materials usage on adjacent sites that could affect surface and/or subsurface conditions on the project site. Although not anticipated, construction personnel could encounter contamination during constructionrelated earth moving activities. This could pose a risk to human health and/or the environment. The unanticipated discovery of contaminated soil and/or groundwater could have a potentially significant effect. The recommended measures presented in Section would further minimize or eliminate adverse effects. Hazardous materials used during construction would include substances such as gasoline, diesel fuel, motor oil, hydraulic fluid, solvents, cleaners, sealants, welding flux, various lubricants, paint, and paint thinner. These materials would be used for the operation and maintenance of equipment, and directly in the construction of the facilities. Regular fueling and oiling of construction equipment would be performed daily. The most likely possible incidents would involve the dripping of fuels, oil, and grease from construction equipment. The small quantities of fuel, oil, and grease that may drip would have low relative toxicity and concentrations. Typical Best Management Practices (BMPs) for construction limit and often eliminate the effect of such accidental releases. Specific BMPs presented in Section would minimize the risk of inadvertent release and, in the event of a contingency, minimize adverse effects. With these measures, Alternative 1 would not result in significant adverse effects associated with hazardous materials during construction. Operation As discussed in Section , the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) regulations include provisions that require facilities to document the potential risk associated with the storage, use, and handling of toxic and flammable substances. OSHA regulations are codified in 29 CFR Part 1910 and are applicable to the project. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

104 Diesel fuel storage tanks would be needed for the operation of emergency generators. The fuel tanks would be housed within the individual generator units. The storage tanks would have double walls with integrated leak detection systems. If a leak were to occur within the inner tank, the outer tank would contain the leak, while a pressure sensor would signal the leak on the indicator panel of the generator unit. Security personnel would monitor the generator units. Security personnel would be on site at all times and would be trained in emergency response procedures. The generators would be located in areas that are easily accessible to maintenance and emergency personnel. During operation of the facilities under Alternative 1, the majority of waste produced would be nonhazardous. The small quantities of hazardous materials that would be utilized include motor oil, hydraulic fluid, solvents, cleaners, lubricants, paint, and paint thinner. These materials would be utilized for the operation and maintenance of the casino and other project facilities. The amount and types of hazardous materials that would be generated are common to commercial sites and do not pose unusual storage, handling or disposal issues. Materials would be stored, handled, and disposed of according to state, federal, and manufacturer s guidelines. Therefore, operation of Alternative 1 would not result in significant adverse effects associated with hazardous materials ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Construction Alternative 2 is similar to Alternative 1, with the exception that casino development would be downsized, including the removal of the parking structure, and adjacent retail centers. As discussed under Alternative 1, the confined hazardous materials within the USTs (Spoko Fuel service station) on the project site would not affect surface and/or subsurface conditions on the site. As with Alternative 1, however, the possibility exists that undiscovered contaminated soil and/or groundwater exists on the site. Although not anticipated, construction personnel could encounter contamination during construction-related earth moving activities. The unanticipated discovery of contaminated soil and/or groundwater could have an adverse effect. The recommended measures presented in Section would further minimize or eliminate adverse effects. The amount and type of hazardous materials that would be stored, used, and generated during the construction of Alternative 2 are the same as those described under Alternative 1. As discussed in Subsection above, BMPs for the storage and handling of hazardous materials are provided in Section Adherence to these BMPs would minimize the risk of inadvertent release and, in the event of a contingency, minimize adverse effects. With these measures, Alternative 2 would not result in significant adverse effects associated with hazardous materials during construction. Operation The type and amounts of hazardous materials that would be used, generated, and stored during the operation of Alternative 2 would be similar to those of Alternative 1. Refer to Section for a description of potentially significant effects resulting from hazardous materials usage and storage during Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

105 project operation. Alternative 2 would result in less than significant effects associated with hazardous materials ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Construction Similar to Alternative 1, Alternative 3 would consist of non-gaming development similar in size to Alternative 1. As discussed under Alternative 1, the confined hazardous materials within the USTs (Spoko Fuel service station) on the project site would not affect surface and/or subsurface conditions on the site. As discussed under Alternative 1, the possibility exists, however, that undiscovered contaminated soil and/or groundwater exists on the site. Although not anticipated, construction personnel could encounter contamination during construction-related earth moving activities. The unanticipated discovery of contaminated soil and/or groundwater could have an adverse effect. The recommended measures presented in Section would further minimize or eliminate adverse effects. The amount and type of hazardous materials that would be stored, used, and generated during the construction of Alternative 3 are the same as those described under Alternative 1. As discussed in Subsection above, BMPs for the storage and handling of hazardous materials are provided in Section Adherence to these BMPs would minimize the risk of inadvertent release and, in the event of a contingency, minimize adverse effects. With these measures, Alternative 3 would not result in significant adverse effects associated with hazardous materials during construction. Operation The type and amounts of hazardous materials that would be used, generated, and stored during the operation of Alternative 3 would be similar to those of Alternative 1. Refer to Section for a description of potentially significant effects resulting from hazardous materials usage and storage during project operation. Alternative 3 would result in less than significant effects associated with hazardous materials ALTERNATIVE 4 NO ACTION /NO DEVELOPMENT Existing uses on the project site would continue under the No Action/ No Development Alternative. No effects from the use, storage, or handling of hazardous materials would result from the No Action/ No Development Alternative. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

106 4.13 AESTHETICS This section identifies the direct effects associated with aesthetics that would result from the development of each alternative described in Chapter 2.0. Effects are measured against the environmental baseline presented in Section Cumulative and indirect effects are identified in Section 4.15 and Section 4.14, respectively. Measures to mitigate for adverse effects identified in this section are presented in Section ALTERNATIVE 1 PROPOSED CASINO AND MIXED-USE DEVELOPMENT Construction Impacts Alternative 1 would be constructed in three phases over a period of seven years between 2012 and Equipment staging for the construction activities would take place on the project site. During this time, heavy construction equipment, materials, and work crews would be readily visible from stationary locations in neighboring residential and commercial use areas, as well as from vehicles traveling along the primary travel routes near the project site. However, views of construction may be partially or wholly blocked by previously existing vegetation and/or structures. Aesthetic related impacts from construction would be temporary in nature and would not result in obstructed views of scenic resources. Therefore, construction of Alternative 1 would not result in significant adverse effects associated with visual resources. Operational Impacts Development of Alternative 1 would encompass the majority of the project site. The multi-use site would consist of the phased construction of a casino resort facility, parking facilities, retail space, tribal cultural center, commercial space, and a fire and police station to be constructed on the approximately 145-acre site located within the city limits of the City of Airway Heights (City). The casino resort facility would include a casino, a spa, and a three-hundred room hotel. The height of the multi-story hotel tower would not exceed 145 feet. To the west of the casino resort facility there would be a four story concrete parking structure. Project design would incorporate appropriately scaled landscaping, using plant material native to the region, to enhance the design of the buildings. An architectural rendering of the development proposed by Alternative 1 is presented as Figure 2-5. No designated resources are present in the vicinity of the project site with the exception of US-2 which is designated under the Spokane County Comprehensive Plan as an aesthetic corridor (Spokane County, 2001). Since US-2 parallels the project site, motorists will generally have unobstructed views of the proposed development. Alternative 1 would be in reasonable conformance with Spokane County policies pertaining to development within a designated aesthetic corridor as it would be considered an allowable use and would include appropriate landscaping adjacent to the highway frontage. Development of Alternative 1 on the project site would not be visually incompatible with land uses currently existing in the immediate vicinity, including development within the City, Spokane Fairchild Air Force Base (Fairchild AFB), and Northern Quest Casino property. While Alternative 1 would result Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

107 in a visually cohesive development that may be considered more aesthetically pleasing than other regional commercial strip development, it would considerably increase the level of human-made elements on the existing landscape of the project site. The proposed development would alter the colors, lines, and texture of the landscape vegetation currently located within the project site. While the site-specific visual effects may be considered significant, the context of the project development in relation to the larger landscape would be less than significant (additional development within a highly developed region). Specific effects to viewsheds in the vicinity of the project site as well as possible effects associated with shadow, light, and glare are discussed below. Effects on Viewsheds Surrounding the Project Section 3.13 describes the viewsheds surrounding the project site. Analysis of potential impacts to the viewsheds resulting from the build-out of Alternative 1 is identified below. Viewpoint A Viewpoint A is located within the Fairchild AFB, providing views of the project site to the west along US-2. There are approximately thirty houses to the west along US 2 that would experience clear views of the proposed development under Alternative 1. The viewshed from Viewpoint A would change from one of rural open space in the foreground and small town development in the background, to one with commercial development consisting of the casino-resort facility at a distance of approximately 1.0 mile. Construction of Alternative 1 would result in alteration of existing views of rural land uses within the project site. However, due to the distance between the project site and Viewpoint A, this change would not represent a major alteration to the existing regional viewshed. Therefore, a less than significant impact would occur. Mitigation is provided in Section to reduce visual effects. Viewpoint B Viewpoint B is experienced by a single residence on 6 th Avenue to the immediate north of the project site. This residence would experience altered views of the project site under Alternative 1 due to its close proximity. The landscaping of the residence includes large trees and bushes, which would serve as partial screening of the Proposed Project. Furthermore, Viewpoint B looks directly out onto a portion of the project site that is not being developed in order to protect existing wetlands. However, the proposed development, particularly the casino resort facility, would be visible through the trees. The view from this residence would change significantly from one of open rural spaces and residential areas, to one of commercial development consisting of the casino-resort, a concrete parking structure, and retail buildings. This would be considered a potentially adverse effect. Mitigation provided in Section would minimize the potential for adverse effects to sensitive receptors from Viewpoint B. Viewpoint C Viewpoint C is experienced by residential communities to the east of the project site in the City boundaries. The view from these residences would change from one of open space and rural Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

108 development, to one of commercial development consisting of the casino-resort complex, a concrete parking structure, and retail buildings. This would be considered a potentially significant adverse effect. Mitigation provided in Section would minimize the potential for adverse effects to sensitive receptors from Viewpoint C. Viewpoint D Viewpoint D is experienced by commuters traveling west along US-2 in downtown City. Views of Alternative 1 from within the community would be screened by development, trees, and infrastructure. The casino resort facility and the concrete parking structure would be the only components of the development that would be visible. This change would not represent a major alteration of the existing viewshed, and would not screen visual resources from view. Therefore, a significant adverse visual effect would not occur from this viewpoint. Mitigation provided in Section would further reduce the potential for adverse effects. Viewpoint E Commuters driving north along South Craig Road and rural residential and industrial uses are represented by Viewpoint E. This viewshed would change from one of open space and rural development, to one of open rural areas in the foreground and commercial development consisting of the casino-resort, concrete parking structures, and retail buildings in the background. However, due to the distance between the project site and Viewpoint E, this change would not represent a major alteration. A significant adverse visual effect would not occur from this viewpoint. Mitigation provided in Section would further reduce the potential for adverse effects. Viewpoints F and G The view for travelers on US-2 directly adjacent to the project site would change from open space to commercial development. Proposed landscaping improvements adjacent to the roadway would soften the visual impacts of the urban development in the background. Views of the project site experienced from these areas are temporary due to the speed at which commuters pass the project site. As described above, the proposed commercial development would be visually cohesive with urban development in the project site vicinity and may be considered more aesthetically pleasing than other regional commercial strip development. Further, Alternative 1 would conform with Spokane County standards for development adjacent to US-2, a designated aesthetic corridor. Because there are no residences or other sensitive receptors that would experience prolonged views of the project site, a significant adverse visual effect would not occur from these viewpoints. Shadow, Light and Glare A significant effect from shadow would result if the proposed development were to cast a shadow on private residences or public areas for substantial portions of the day. The nearest buildings off site are residences to the north and east as described above as Viewpoint B and Viewpoint C. The direction of the Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

109 sunrise will vary from east to southeast throughout the year; the direction of the morning shadow from the hotel will vary from west to northwest, accordingly. In the late afternoon, the casino resort facility may briefly cast a shadow over the east and northeast during certain times of the year. However, the shadow from the development would not result in significant adverse effects to nearby residences since the casino and resort structures are located further north than the easterly residences, causing any possible shadows to be cast over the residences for only a brief amount of time before sunset. Alternative 1 would introduce new sources of light into the existing setting. Light spillover into surrounding areas and increases in regional ambient illumination could result in potentially significant adverse effects if it were to impact operations at the Fairchild AFB, result in traffic safety issues, or create a nuisance to sensitive receptors. The following would be incorporated into the design of Alternative 1, including the proposed hotel tower: downcast lighting would be used in the landscaped and parking areas to minimize off-site scatter; lighting fixtures would be an integral part of the overall design and strategically positioned to minimize any direct site lines or glare to the public. Exterior signage would be considered as part of the exterior architectural design and would enhance the buildings architecture and the natural characteristics of the site by incorporating native materials in combination with architectural trim. Illuminated signs would be designed to blend with the light levels of the building and landscape lighting in both illumination levels and color characteristics. Through the use of downcast and directed lighting, and strategically positioned lighting fixtures, the impacts of lighting off-site would be minimized and would not be adverse. These measures are consistent with the policies for aesthetics and visual resources contained within the Recommendations Section of the Fairchild Joint Land Use Study 2009 (refer to Section 3.13). The use of glass panels and reflective ornamental detailing in the project design, including the proposed hotel tower, could increase the glare to aircraft operations, travelers on US-2 and adjacent residences. Therefore the potential for Alternative 1 to produce glare in the project vicinity is a potentially significant adverse effect. Mitigation measures in Section are consistent with the International Dark-Sky Association s Model Lighting Ordinance (IDA, 2011) and would reduce this potential impact to a less than significant level ALTERNATIVE 2 REDUCED CASINO AND MIXED-USE DEVELOPMENT Construction Impacts The mixed used development proposed under Alternative 2 would result in similar, yet less intensive construction on the project site as Alternative 1. Equipment and material staging would occur on-site and be visible from stationary locations in neighboring residential and commercial use areas, as well as from vehicles traveling along the primary travel routes near the project site. However, views of this construction may be partially or wholly blocked by previously existing vegetation and/or structures. Aesthetic related impacts from construction would be temporary in nature and would not result in obstructed views of scenic resources. Therefore, construction of Alternative 1 would not result in significant adverse effects associated with visual resources. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

110 Operational Impacts Impacts to viewsheds resulting from Alternative 2 would be similar although lessened, when compared with Alternative 1 due to the reduced intensity design and the absence of a hotel and parking structure. The removal of the 145 foot high hotel tower, in particular, would lessen the visual impact of Alternative 2 from surrounding viewpoints. While the site-specific visual effects may be considered significant, the context of the project development in relation to the larger landscape would be less than significant (additional development within a highly developed region). Effects on Viewsheds Surrounding the Project Effects on viewsheds surrounding the project would be similar to those discussed under Alternative 1; however the main visual element, the hotel tower and multi-story parking structure would not be developed. As described under Alternative 1, the views of the project site would change from one of open rural and residential areas, to one of commercial development consisting of a casino set amidst a planned landscape and retail buildings. Construction of Alternative 2 would result in significant alteration of existing rural viewsheds; however, Alternative 2 would be partially screened by existing development and landscaping and would blend into the existing development within the City. Mitigation is provided in Section to include screening for existing residences directly adjacent to the project to reduce the potential for adverse visual effects. Shadow, Light and Glare Under Alternative 2, the majority of structures within the casino-retail development would be one story, with the exception of the commercial building in the northern portion of the proposed site, limiting the amount of shadow casted on nearby residences. Alternative 2 would not result in significant adverse effects associated with shadow. The development of Alternative 2 would introduce new sources of light and glare as described under Alternative 1. Through the use of downcast and directed lighting and strategically positioned lighting fixtures, the impacts of lighting off site would be minimized and would not be adverse. With mitigation provided in Section , which are consistent with the International Dark-Sky Association s Model Lighting Ordinance (IDA, 2011), Alternative 2 would not result in significant adverse effects associated with light emissions and glare ALTERNATIVE 3 NON-GAMING MIXED-USE DEVELOPMENT Construction Impacts Development under Alternative 3 would result in similar construction activity to Alternative 1 due to the similar scale of proposed development. The presence and high visibility of construction equipment and activities would remain visible to neighboring residential and commercial areas. However, views of this construction may be partially or wholly blocked by previously existing vegetation and/or structures. Aesthetic related impacts from construction would be temporary in nature and would not result in obstructed views of scenic resources. Therefore, construction of Alternative 2 would not result in significant adverse effects associated with visual resources Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

111 Operational Impacts The features of Alternative 3 would be similar to those described under Alternative 1. Under Alternative 3, the design of the project is visually identical to Alternative 1, as all proposed buildings would have the same location, height, and general appearance. The only difference is that the central portion of the project site would be used for recreational facilities and additional commercial space instead of gaming. This alternative would also protect the existing wetlands in the northwest corner. A site plan for this alternative appears as Figure 2-7. Effects on Viewsheds Surrounding the Project Effects on viewsheds surrounding the project would be similar to those discussed under Alternative 1. As described under Alternative 1, the views of the project site would change from one of open rural and residential areas, to one of commercial development consisting of a large complex set amidst a planned landscape and retail buildings. Construction of Alternative 3 would result in significant alteration of existing rural viewsheds; however, Alternative 3 would be partially screened by existing development and landscaping and would blend into the existing development within the City. Mitigation is provided in Section to include screening for existing residences directly adjacent to the project to reduce the potential for adverse visual effects. Shadow, Light and Glare Like Alternative 1, the resort facility proposed by Alternative 3 could briefly cast a shadow over some of the residences to the east of the project site in the late afternoon, during certain times of the year. However, the impact would be less than significant. The development of Alternative 3 would introduce new sources of light and glare as described under Alternative 1, which would result in a potentially significant impact. Through the use of downcast and directed lighting and strategically positioned lighting fixtures, the impacts of lighting off site would be minimized and less than significant. With mitigation provided in Section , which are consistent with the International Dark-Sky Association s Model Lighting Ordinance (IDA, 2011), Alternative 3 would not result in significant adverse effects associated with light emissions and glare ALTERNATIVE 4 NO ACTION/NO DEVELOPMENT No impacts would occur to visual resources under the No Action/No Development Alternative. Existing tribal commercial uses would continue to occur on the project site. The visual environment on the project site would remain the same. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

112 4.14 INDIRECT AND GROWTH-INDUCING EFFECTS The Council on Environmental Quality (CEQ) Regulations for Implementing the National Environmental Policy Act (NEPA) requires that an Environmental Impact Statement (EIS) analyze both the indirect and the growth-inducing effects of a proposed project (40 CFR Section [b], 40 CFR Section [b]). indirect effects are caused by the action and are later in time or farther removed in the distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on natural systems. Direct impacts, caused by the action and occurring at the same time and place as the action, have been discussed in Sections 4.2 to 4.13 and cumulative impacts measured in conjunction with other reasonably foreseeable projects, whether past, present, or future, are addressed in Section The potential indirect effects of off-site traffic mitigation and utility/infrastructure improvements integral to the development of Alternatives 1, 2, and 3 are discussed independently in Sections and , respectively, as they are distinctively separated in time and/or space from the proposed alternatives. Figure shows the location of the various road and infrastructure improvements. Growth inducing effects are also discussed independently in Section since they are a distinct subset of indirect effects. Potential indirect effects associated with proposed alternatives would be minimized to a less than significant level through project design and recommended measures presented in Chapter 5.0. In addition, off-site improvements would require obtaining approvals and permits from jurisdictional agencies, including the Washington Department of Transportation (WSDOT) and the City of Airway Heights (City), and therefore may be subject to the Washington State Environmental Policy Act (SEPA). Implementation of permitting and SEPA requirements would further reduce the potential for significant adverse effects from off-site construction projects INDIRECT EFFECTS FROM OFF-SITE TRAFFIC MITIGATION IMPROVEMENTS Pursuant to Section 3.0 of the Intergovernmental Agreement (IGA; Appendix C), the Tribe agrees to make street and intersection improvements as identified in the traffic impact analysis (TIA; Appendix D and Appendix R) to provide for the safe and efficient vehicle and pedestrian movements and maintain traffic levels of service (LOS) in reasonable conformity with applicable City or County standards or at their pre-development levels. A detailed description of off-site traffic mitigation recommended for Alternatives 1, 2, and 3 is provided in Section As described therein, the traffic improvements recommended for Alternative 1 cumulative year 2032 would result in the highest area of impact at each intersection. Figure shows the location of the off-site traffic mitigation improvements recommended for Alternative 1in the cumulative year and Table presents the estimated area of impact for each traffic mitigation measure. The mitigation measures that would require construction to widen/improve intersection approaches, add lanes, and install traffic signals and/or roundabouts would require grading and the introduction of fill material. Construction of these improvements could generate indirect impacts in several areas, which are discussed below under each issue area. Improvements that do Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

113 _ ^ _ ^ _ ^ _ ^ _ ^ ^ _ ^ ^ ^ ^ _ ^ _ ^ _ ^ _ ^ Project Site LEGEND _ ^ _ ^ Traffic Mitigation Locations Ð N O R TH! SOURCE: ESRI World Street Map, 2011 Feet 0 2,000 4,000 West Plains Mixed Use Development Final EIS / Figure Proposed Road Improvements

114 not require construction, such as restriping and optimizing signal timing, are unlikely to generate indirect impacts and are, therefore, not discussed below. TABLE ALTERNATIVE 1 INTERSECTION IMPROVEMENTS Intersection Improvement Approximate Area of Impact (square feet) US-2 / Craig Road: Option 1: Install a traffic signal, widen/improve intersection 54,000 approaches to include dual EB, NB, and SB left turn lanes, and add second NB through lane Option 2: Install a roundabout 50,000 US-2 / Lundstrom Road: Nominal less than 1,000 Restripe and widen approaches to accommodate exclusive NB and SB right turn lanes US-2 / Lawson: Nominal less than 1,000 Modify the signal timing and modify and widen NB and SB approaches as needed to provide dedicated left turn lanes US-2 / Garfield Road: Option 1: Optimize signal timing None Option 2: Modify signal timing and add third EB and WB auxiliary 100,000 through lanes US-2 / Middle Driveway Option 1: Install a traffic signal and a WB right turn lane 15,000 Option 2: Install a roundabout 20,000 US-2 / Fairchild AFB: 40,000 Modify signal timing, add NB left turn lane, and add WB thru lane Craig Road / SR-902: Option 1: Install a traffic signal 5,000 Option 2: Install a roundabout 20,000 Craig Road / 6 th Avenue Option 1: Widen the intersection approach to provide an exclusive 5,000 NB right turn lane Option 2: Install a roundabout 10,000 Craig Road / North Driveway Option 1: Add second NB thru lane from Highway 2 to 6 th Avenue 5,000 Option 2: Install a roundabout 5,000 US-2 / Flint Road Install a traffic signal 5,000 US-2 / Deer Heights Road Install a traffic signal 5,000 US-2 / Spotted Road Restrict NB left turn (through signage or restriping) None Deno Road / Hayford Road Install storage for SB and WB turning lanes 2,000 Notes: US-2: U.S. Highway 2; SR-902: State Route 902; AFB: Air Force Base; NB: northbound; SB: southbound; WB: westbound; EB: eastbound Source: David Evans and Associates (DEA), 2011 (Appendix D); DEA, 2011b; DEA, 2012c Additionally, mitigation requires that the Tribe contribute a fair share payment towards construction of the 21 st Avenue/18 th Street corridor, which would consist of an approximately 5.8 mile long, three-lane Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

115 facility that that would extend south of US-2 directly across from the western boundary of the site parallel to US 2 and terminate in the vicinity of the Airport Road Interchange, and the I-90/Medical Lake Interchange improvements, which may include a full reconstruction and reconfiguration of the interchange. As discussed in Addendum 2 to the TIA (Appendix R to this Final EIS), WSDOT is in the initial planning stages to determine the proposed improvements and a preliminary cost estimate for the interchange improvements. Environmental Consequences Geology and Soils The construction of roadway improvements would require grading and the introduction of fill material. Changes to topography would be moderate due to the variable relief and slope of the area. The increase in impervious surfaces and additional cut-and-fill embankments could result in erosion of soils. Stable fill material, engineered embankments, and erosion control features would be used to reduce the potential for slope instability, subsidence and erosion in accordance with the jurisdictional agency (WSDOT, County, and/or City) requirements for roadway construction. Watering during grading activities would mitigate the effect of wind erosion to the underlying soils. Effects to geology and soils would be less than significant. With standard construction practices and specifications required by the jurisdictional agency and the General Construction National Pollutant Discharge Elimination System (NPDES) permit program, there would be no adverse effects to geology and soils as a result of off-site traffic mitigation under Alternative 1, 2, or 3. Water Resources The development of roadway improvements for traffic mitigation could affect water resources due to grading and construction activities and an increase in impervious surfaces. Potential effects include an increase in surface runoff and increased erosion, which could adversely affect surface water quality due to increases in sediment and roadway pollutants such as grease and oil. Additionally, WSDOT is required by State and Federal regulations to have a stormwater permit in areas covered by Phase I and Phase II of the municipal stormwater permit program. WSDOT has agreed to a statewide permit to avoid having a piecemeal stormwater program and to promote better management of stormwater runoff from all State highways. The permit covers stormwater runoff from State highways, rest areas, weigh stations, scenic view points, park-and-ride lots, ferry terminals, and maintenance facilities (Ecology, 2005). Construction of roadway improvements that exceed 1 acre of land would be required to comply with the NPDES General Construction Permit Program. To comply with the program, a Stormwater Pollution Prevention Plan (SWPPP) would be developed that would include soil erosion and sediment control practices to reduce the amount of exposed soil, prevent runoff from flowing across disturbed areas, slow runoff from the site, and remove sediment from the runoff. Construction on WSDOT roadways would be required to comply with the WSDOT NPDES permit. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

116 Curb and gutters, inlets, and other drainage facilities would be constructed to meet the standards of the jurisdictional agency and provide adequate facilities to direct stormwater runoff. With incorporation of these drainage features and compliance with the soil erosion and sediment control practices identified in the SWPPP, effects to water resources would be less than significant. Therefore, there would be no indirect effects to water resources as a result of off-site traffic mitigation under Alternative 1, 2, or 3. Air Quality With the improved circulation resulting from traffic mitigation, including the installation of access driveway roundabouts, level of service (LOS) is improved, thereby reducing idling time and associated emissions. Construction generated dust and emissions will be controlled by BMPs mandated by the State of Washington. Construction emissions would be minimal given the temporary nature of construction activities. As traffic improvements would take place within an area in attainment for all criteria air pollutants, corresponding air effects would not be significant. Biological Resources A biological survey of proposed intersection improvement areas identified within the TIA and Addendum 1 was conducted on April 20 th and 21 st, The survey concluded that all intersection improvements would take place within previously disturbed areas and sensitive biological communities, habitat for special status species, and wetlands would not be impacted. A Biological Assessment would be conducted to determine whether any threatened or endangered species or specific habitat concerns are present within the selected 21 st Avenue/ 18 th Street corridor (WSDOT, 2010b). Compliance with the Endangered Species Act (ESA) would minimize indirect effects. Delineation and classification of wetlands potentially impacted by the construction of the 21 st Avenue/18 th Street corridor would be performed as the project is designed (WSDOT, 2010b). The selected I-90 Medical Lake Interchange improvements would be subject to the protection of biological resources afforded by NEPA and SEPA. In addition, the improvements would be subject to compliance with the ESA and Section 404 of the Federal Water Pollution Control Act and Amendments. A survey has not been conducted for the new intersections identified in TIA Addendum 2. The new intersections associated with proposed signage, striping, and installation of traffic signals would take place within previously developed areas and sensitive biological communities, habitat for special status species, and wetlands would not be impacted. Based on review of aerial photographs, the Deno Road/Hayford Street intersection has the potential to impact potential wetlands and/or waters of the U.S. A delineation and classification of any wetlands potentially impacted by construction of the Deno Road/Hayford Street intersection would be performed prior to construction in accordance with Section 404 of the Clean Water Act. All impacts to wetlands would be avoided to the extent possible and mitigation provided where avoidance is not possible. Indirect effects to biological resources as a result of off-site traffic mitigation under Alternatives 1, 2, or 3 would be minimized through compliance with environmental laws, including the ESA, Clean Water Act, NEPA and SEPA. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

117 Cultural Resources No prehistoric or historic period cultural resources are known to occur within the or adjacent project area based upon a record search, conducted by Historical Research Associated in 2009 at the Washington State Department of Archaeology and Historic Preservation (DAHP), and a pedestrian survey of the proposed intersection improvement areas identified within the TIA and Addendum 1. The locations of all proposed intersection improvements are currently developed environments and, therefore, are unlikely to contain unknown cultural resources. The selected 21 st Avenue/ 18 th Street corridor and I-90 Medical Lake Interchange would be subject to the protection of cultural resources afforded by the SEPA Guidelines. In addition, improvements involving federal funding and approval would be subject to Section 106 of the National Historic Preservation Act. No significant impacts to cultural resources would result from offsite traffic improvements under Alternatives 1, 2, and 3. Socioeconomic Conditions No projects funded with Housing and Urban Development funds were identified in the area (WSDOT, 2010b). Off-site traffic improvements would result in short-term disturbances to traffic flows. Surrounding businesses and residences would remain accessible throughout construction. The area of roadway impacts would be of a limited size and would not create socioeconomic effects. The fair share costs of these roadway improvements would be borne by the Tribe consistent with the IGA and MOA (Appendix C). Therefore, there would be no indirect effects to socioeconomic conditions as a result of off-site traffic mitigation under Alternative 1, 2, or 3. Transportation/Circulation Off-site traffic mitigation would result in beneficial effects to traffic circulation. Off-site traffic improvements would be limited in scale and duration, resulting only in short-term disturbances to traffic flows. If construction activities require temporary lane closures to accommodate construction equipment, a traffic management plan would be prepared in accordance with the jurisdictional agency requirements, thus avoiding potentially adverse temporary effects. Land Use Construction of off-site traffic mitigation would not result in adverse land use effects. The intersection improvements would be in accordance with the City Comprehensive Plan Transportation Element roadway network designations. The final US 2 connections and the 21 st Avenue/18 th Street corridors would be determined by local jurisdictions including the City, County, and WSDOT in accordance with their respective comprehensive plans (WSDOT, 2010b). Therefore, there would be no indirect effects to land use as a result of off-site traffic mitigation under Alternative 1, 2, or 3. Public Services Traffic improvements may require relocation of utilities near existing roadways. These utilities include overhead electricity lines and telecommunication lines. Relocation of these lines could result in a temporary break in service to some homes and businesses in the area. However, because these effects are common when upgrading and maintaining utility services, and because potential service breaks would be temporary, these effects are considered to be less than significant. Furthermore, each improvement would Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

118 be completed to the standards of the agencies with jurisdiction over the intersections (WSDOT, County, or City of Airway Heights). As described in Section of the Draft EIS, all construction work within federal and state right-of-ways must be done in accordance with the current WSDOT Standard Specifications for Road, Bridge, and Municipal construction manual. Section of the 2012 construction manual establishes requirements to protect all private and public utilities. Additionally, item 1 of the General Notes for street construction within the City of Airway Heights Public Works Standards requires that all workmanship and materials be in accordance with the most current copy of the WSDOT Standard Specifications for Road, Bridge, and Municipal construction manual. No effects to police, fire, or emergency medical services are expected as access to homes and businesses would be maintained during the construction period. Therefore, there would be no indirect effects to public services as a result of off-site traffic mitigation under Alternatives 1, 2, or 3. Noise Construction of intersection improvements would result in minimal noise impacts. Any impacts that may occur would be reduced through County and municipal regulations including the imposition of construction hours and the use of noise abatement equipment. Most proposed intersection improvement locations are not located on residential streets, and therefore noise would not affect sensitive receptors. The selected 21 st Avenue/ 18 th Street corridor would be evaluated for traffic noise impacts in accordance with applicable standards and any identified noise impacts would be mitigated in accordance with WSDOT policy (WSDOT, 2010b). Accordingly, no significant indirect noise impacts are expected to occur as a result of off-site traffic mitigation under Alternatives 1, 2, and 3. Hazardous Materials Construction of the off-site roadway improvements could potentially result in negative hazardous materials effects. The accidental release of hazardous materials used during grading and construction activities could pose a hazard to construction employees, surrounding residents, and the environment. However, these hazards, which are common to construction activities, would be minimized with adherence to State and Federal statutes and standard operating procedures, such as refueling in designated areas, storing hazardous materials in approved containers, clearing of dried vegetation, and proper initiation of response and clean-up measures. Potential indirect hazardous materials impacts from the construction of off-site roadway improvements are therefore considered to be less than significant under Alternatives 1, 2, and 3. Aesthetics With the modification and expansion of existing roadways, visual effects would occur. Road improvements would be made in areas that are already developed with roadway networks. Modified intersections, interchanges, and roadways would conform to modern design standards. Improvements would not result in significant removal or alteration of vegetation, topographic features, or key visual characteristics. Additionally, traffic improvements would not change surrounding land uses and would occur in areas with existing roadway networks. Therefore, no significant indirect effects to aesthetics or community character are expected to occur as a result of off-site traffic mitigation under Alternatives 1, 2 or 3. Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

119 INDIRECT EFFECTS FROM WATER/WASTEWATER INFRASTRUCTURE IMPROVEMENTS Improvements In accordance with Section 2.0 of the IGA (Appendix C), the City s public water and sewer services will serve the project site through the City s municipal utilities with connections to be provided to the project site at the Tribe s sole cost and expense. The water and wastewater infrastructure improvements are the same for Alternatives 1, 2, and 3 and are described below: Water Distribution and Storage Facilities As detailed within the Water and Wastewater Demand Analysis Report (Appendix E), the project site would connect to the existing City s water supply system at two locations: one near the current asphalt end at the west end of 6 th Street and one near the intersection of 12 th Street and Craig Road (Figure ). The 6 th Avenue connection will require construction of approximately 800 linear feet of 12-inch diameter PVC pipe extending the City s system onto the project site and the installation of a master meter for the site. The 12 th Avenue connection will require construction of approximately 100 linear feet of 12- inch PVC pipe from an 8-inch diameter main located just east of the intersection of Craig Road and 12 th Avenue to the project site. As described in Section 2.3.1, the Tribe may contribute funding towards the development of an off-site storage tank in order to off-set impacts to storage capacity within the City s existing water system. Although a water storage tank is being constructed at the same location, this section analyzes the potential impacts from the construction of an additional tank. Wastewater Collection and Recycled Water Lines As shown on Figure , wastewater generated by the project alternatives would be transported to the City of Airway Heights Wastewater Treatment, Reclamation, and Recharge Facility (WTRRF) via proposed sewer mains that would extend underground from a lift station on the eastern portion of the site which will then pump the wastewater via a 4-inch force main south under U.S. Highway 2 (US-2) then convert to gravity flow continuing south down Craig Road, and east on 21 st Avenue to the WTRRF located at the corner of 21 st Avenue and Russell Street. Additionally, proposed recycled water pipelines would extend from the WTRRF to the project site to supply recycled water for landscape irrigation and the water cooling system, as described in Section The alignment for the recycled water line would be identical to the sewer main alignment, but with a minimum of 10 feet separation. Wastewater Treatment and Disposal Facilities The wastewater treatment demand for each alternative will contribute to the need for implementation of the planned Phase II expansion of the City of Airway Height s WTRRF. The Phase II expansion would increase the total treatment capacity of the WTRRF to 2 million gallons per day (mgd) through the addition of new treatment facilities within the existing boundaries of the plant. Treated wastewater produced by the Phase II expansion would be disposed of through recycled water irrigation or percolation ponds or sub-surface system that would be constructed at an off-site location. The proposed location for Phase II percolation ponds or sub-surface system is shown in Figure Treated effluent would be transported to the percolation ponds or sub-surface system via a force main that would extend from the Analytical Environmental Services Spokane Tribe of Indians West Plains Development Project

120 LEGEND Proposed Sewer and Recycled Water Alignment Reclaimed Water Line Water Supply Infrastructure!? Proposed Water Storage Tank City of Airway Heights WTRRF Phase II Percolation Site City of Airway Heights WTRRF City Limits Project Site! ÐN O R TH Feet 0 1,200 2,400!? Deno Way W. Balmer Ave Craig Rd Spraque Ave 6Th Ave Tower Dr 6Th St S. Hayford Rd Fairview Hghts Rd 12Th Ave Albert St 21St St Lundstrom St 13Th Ave Lundstrom St Lawson St Market St 19Th Ave 10Th St Campbell St Garfield Rd 2 Lawson St Russell St Mcfarlane Rd SOURCE: AEX Aerial Photograph, 5/15/2009 West Plains Mixed Use Development Final EIS / Figure Proposed Water and Wastewater Infrastructure Improvements