​​Barton Initial Environmental Checklist

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11/2023 TRPA Accepts Initial Environmental Checklist Prepared By Barton

TRPA had no intention of ramping things up to an EA and/or EIS and instead was hoping for a fast track project approval in Aug 2024.  Push back and questions from the public forced TRPA in October 2024 to go to the next step and require Barton to do an EA.

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TRPA accepted the IEC prepared by Barton without asking for any additional information​. The submittal had no signature/date from the Barton representative preparing it and no signature/date from the TRPA representative receiving it.

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TRPA Code 2.2.1 uses a standardized Initial Environmental Checklist (IEC) to identify potential impacts and determine what level of environmental review is required for project approval (TRPA Rules of Procedure 6.4). If the IEC results in a Finding of No Significant Effect or Mitigated Finding of No Significant Effect, the project may proceed without further documentation (Rules of Procedure 6.6-6.7). If the IEC is unclear or indicates a potentially significant impact, then a more substantive Environmental Assessment (EA) or Environmental Impact Statement (EIS) may be required (Rules of Procedure 6.5).

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TRPA failed to require a signature on the document for the person preparing the document (see picture below and Barton IEC PDF link below Pg 18)​

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TRPA staff failed to sign the document after accepting and/or reviewing the submitted information (see picture below and Barton IEC PDF link below Pg 19)

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TRPA planned to only require this environmental checklist for this Barton Hospital project leading up to the fast track area amendment

plan approvals in August 2024.  

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​And at no point in 11 months since the IEC was filed did TRPA look at the IEC to determine if the answers presented by Barton needed more explaining and/or that this project would need an Environmental Assessment and/or Environmental Impact Study.

 

The Barton IEC had 91 specific questions asking about the project's impacts on the environment.  Here is a summary of Barton's responses- 

91 total questions  

    54 No

    31 Data Insufficient

    5   Yes

    1   No, with mitigation

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Project: 230,000 sq ft, 89' above Laura Dr, site is known to be environmentally sensitive with major water issues, it is next to Rabe meadows/stream and wildlife, adding helicopter noise, building on top of a neighborhood, next to casino corridor traffic congestion

 

TRPA accepted Barton's IEC document with the 54 "No" responses and 31 "Data Insufficient" responses.  

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TRPA then relayed info provided by the IEC submitted by Barton and shared this info with the public 

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TRPA used info from Barton's IEC for all decisions for the next 11 months

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TRPA had no intention of ramping things up to an EA and/or EIS and instead was hoping for a fast track project approval in Aug 2024.  Push back and questions from the public forced TRPA in October 2024 to go to the next step and require Barton to do an EA.

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​Barton, TRPA and Douglas County clearly never planned on doing an Environmental Assessment or EIS and planned for the fast track project approval in August 2024.  They used this same strategic move with the Latitude 39 project- this project only required an IEC.

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​​​TRPA should have reviewed the site history and the scope of the proposed project and immediately moved this to an Environmental Assessment.  And once some of the additional info came in fuzzy and unclear from Barton they should have required Barton to do an Environmental Impact Study​​​​​​​​​​​

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​     Online Link to Barton IEC

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EIS Scoping Comment Submitted 6/6/25 

Barton Health Initial Environmental Checklist

Please review the Initial Environmental Checklist (IEC) submitted by Barton Health in November 2023 for the proposed project:
https://www.bartonstayinca.com/barton-initial-environmental-checklist

There are several issues within this IEC that warrant closer examination and public clarification:

1. Incomplete Signatures and Missing Identification

• The IEC document submitted by Barton contains blank fields for the preparer’s signature, date and county info.

• The IEC document submitted by Barton contains blank fields for the evaluator’s signature, title and date.

• These fields are a critical part of verifying the authenticity, accountability, and chain of responsibility for environmental review documentation.

Request:
Please explain:

• Why were these fields left blank?

• Who was responsible for preparing the IEC?

• Who was responsible for accepting and evaluating the IEC?

• Was the IEC considered formally submitted and valid despite the lack of signatures?

2. Summary of Responses and Lack of Supporting Evidence

The IEC contains responses to 91 specific questions about the proposed project’s potential environmental impacts. Barton’s responses were as follows:

• 54 marked "No" (indicating no impact)

• 31 marked "Data Insufficient"

• 5 marked "Yes"

• 1 marked "No, with Mitigation"

TRPA’s own IEC guidelines state:

“All ‘Yes’ and ‘No, with Mitigation’ responses will require further written comments and evidence.”

Request:

• Please confirm whether TRPA received the additional written explanations required for the 5 "Yes" and 1 "No, with Mitigation" responses.

• If no supplemental information was submitted, please explain why TRPA allowed the project review process to proceed.

3. Use of “Data Insufficient” Without Follow-up

The "Data Insufficient" response was used 31 times. These responses signal that the applicant could not provide enough evidence to determine whether environmental impacts would occur.

Request:

• Please explain why TRPA allowed the IEC to move forward with such a high volume of “Data Insufficient” responses.

• Under what circumstances does TRPA allow “Data Insufficient” to substitute for an impact analysis or mitigation plan?

4. Timing of TRPA Project Review Process

Request:

• On what exact dates did TRPA make the following decisions:

  • To escalate the review from an Initial Environmental Checklist to an Environmental Assessment (EA)?

  • To escalate the review from an EA to a full Environmental Impact Statement (EIS)?

• If the IEC had been completed fully and properly in November 2023 (with signatures and full explanations), would that have affected the timeline, scope, or need for an EIS?

5. Inconsistency With Known Site Conditions

The proposed project site in Stateline, NV, is widely recognized by environmental professionals in the region as a highly constrained and environmentally sensitive location.

Request:

• Please analyze how Barton was able to submit "No" impact responses to 54 of 91 questions, despite the known complexity and sensitivity of the site.

• Evaluate whether this high number of “No” responses is consistent with other similar projects on similar land types.

• Examine whether the outcome and public process could have been more accurate or efficient had the IEC been fully and completely prepared in November 2023.

Conclusion:

There appear to be material deficiencies in the original IEC submitted by Barton Health. These omissions and unclear responses have likely contributed to a delayed and less transparent environmental review process. This EIS should fully investigate the adequacy of the IEC, the decision-making timeline of TRPA, and whether TRPA properly applied its standards for completeness and disclosure under Code of Ordinances Chapter 3.