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Stop the Casino 101 Coalition


The Voice of the People

  February 23, 2012
Analytical Environmental Services subject of controversy that
could threaten Graton Rancheria casino's environmental study

Stop the Casino 101 Coalition (STC101) has learned of allegations of serious illegal and improper conduct on the part of Analytical Environmental Services (AES), the company that performed the National Environmental Protection Act (NEPA) study for the proposed Rohnert Park casino.   

According to attorney Guy Martin of Perkins Coie, AES appears to have acted in collusion with a Native American tribe, the Bureau of Indian Affairs (BIA) , and tribal attorneys, financial backers and lobbyists, in the preparation of a casino-related NEPA study in Oregon, corrupting the NEPA process to the point where it was impossible for the agency to make fair and impartial decisions.

Guy Martin is widely recognized as one of the senior natural resources, energy and environmental lawyers in Washington, D.C., and is an acknowledged expert in Indian law.   

Through a Freedom of Information Act (FOIA) inquiry to the Department of the Interior, Bureau of Indian Affairs, Mr. Martin discovered that AES permitted a cooperating agency, the Cowlitz tribe, to "actively and inappropriately (involve itself) in the preparation of the EIS by AES far beyond the role legally permissible for a cooperating agency" for its casino site located in La Center, OR.   

Martin found that the Cowlitz tribe, its attorneys, partners and lobbyists had "at least 71 formal telephonic or in-person meetings" with AES while the lead agency, the Bureau of Indian Affairs (BIA), had virtually no active role in the preparation of the environmental study.  This is illegal under NEPA.

Mr. Martin discovered that AES appears to have "informed the Tribe of the status of what appears to be every document, study, and comment, while the Tribe appears to have informed AES of every legal and political action that it intended to take", all or which is illegal or improper under NEPA law.

In his letter to BIA Secretary Larry Echo Hawk, Mr. Martin says, "For all practical purposes, AES and the Tribe functioned as a single unit with the joint purpose of obtaining approval for the project. Even more problematic is that BIA at no point supervised, oversaw, or participated in these meetings.  There is simply no reasonable argument that AES was working independently from the Tribe, or under the direction and oversight of BIA."

In instance after instance, Mr. Martin found evidence of what appears to be improper and illegal behavior on the part of AES, including an indication of illegal behavior on the part of an EPA official.  In one case, the Tribe was apparently concerned about an unfavorable rating that it felt it would get from the EPA.  

According to the BIA documents, Suzi Schaeffer, an attorney for the Cowlitz tribe, "...contacted someone at EPA HQ, "who was sympathetic to our problem, and . . . would call the program office there to initiate an inquiry into whether headquarters review of this issue has occurred/is appropriate (according to him HQ review is required only for issues of 'national significance' - given the political attention to gaming issues I told him this qualified)."

There are many other instances in the record that reveal what appears to be collusion between AES and the Cowlitz tribe as well as improper coordination between the Cowlitz, AES and also the mayor of La Center, OR, where the Cowlitz casino site is located.  

AES performs a large number of tribal casino environmental studies in the country.  Locally, AES performed the EIR for the Point Molate casino project in Richmond and the EIS done by the National Indian Gaming Commission for the Graton Rancheria Project here in Sonoma County.  

"There is the potential here for a scandal of epic proportions, "said Pastor Chip Worthington, founder of STC101.  "We're talking about possible collusion to defraud the American public by the BIA and even an official at the Environmental Protection Agency, not to mention the alleged behavior of AES."

"It's reasonable to consider that AES may have behaved in a similar, illegal fashion when it did the Graton casino NEPA study, that they may have a corporate culture that encourages such behavior.  We're going to find out."

STC101 has sent copies of the Martin letter to Assemblymember Jared Huffman, Senator Dianne Feinstein, Congresswoman Lynn Woolsey and the Sonoma County Board of Supervisors.

(A copy of Mr. Martin's letter can be viewed at www.stopthecasino101.com )




The Graton Rancheria Casino/Hotel project Final Environmental Impact Statement (FEIS) is fatally flawed in all major issue areas.  Although scaled back somewhat, the casino won't be scaled back for long, and the FIGR won't have to obtain any permits for any additional work they do.  Remember:  they aren't subject to CEQA. 

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Stop the Casino 101 Coalition

979 Golf Course Drive #170

Rohnert Park, California 94928


Pastor Chip Worthington, Founder