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5. Mitigation 

5.1 Introduction 

The CEQ NEPA regulations require that mitigation measures be developed for all effects 

of a proposed action where it is feasible to do so (CEQ 46 Fed. Reg. 18026, 19a; 40 CFR 

Sections 1502.14(f) and 1502.16 (h)). Correspondingly, the identification of mitigation 

measures is discussed in the BIA NEPA Handbook (Part 6) and in the DOI NEPA Manual 

(Part 516 DM 4). The NEPA regulations define mitigation as: 

“avoiding the impact altogether by not taking a certain action or parts of an 

action, minimizing impacts by limiting the degree or magnitude of the action and 

its implementation, rectifying the impact by repairing, rehabilitating, or restoring 

the affected environment, reducing or eliminating the impact over time by 

preservation and maintenance operations during the life of the action, 

compensating for the impact by replacing or providing substitute resources or 

environments” (40 CFR 1508.20). 

Accordingly, in this section mitigation measures have been identified where feasible to 

address specific potential effects. 

As described elsewhere in this document, the conveyance of lands into trust is an action 

where title to the Nation’s existing lands would be transferred to the Federal government 

with no change in their uses. The majority of the resource categories (e.g., the physical, 

cultural and natural environment) evaluated in the Draft EIS would not be directly 

affected by the Proposed Action because neither it nor any of the alternatives involve 

ground disturbance of the environment or a change in land use. In instances where there 

may be indirect or cumulative effects on these resources, mitigation measures are discussed 

below, as appropriate. 

Lands taken into trust are not subject to state or local taxation or regulatory jurisdiction. 

In a recent report by the General Accountability Office to Congress regarding the Trust 

Land program, it was noted that the most common negative comments on Trust Land 

Applications come from state or local jurisdictions concerned about the loss of tax 

revenues and regulatory controls (General Accountability Office 2006). Accordingly, this 

Draft EIS has identified potential socioeconomic effects, in particular those related to fiscal 

and regulatory matters. To the extent that adverse effects exist or are perceived as existing 

in these areas, this section discusses their mitigation as well. 
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5.2 Mitigation Measures 

Regarding potential socioeconomic effects of the Proposed Action, the Nation’s 

relationships with the surrounding communities over the past four years demonstrate a 

preexisting pattern and practice of mitigation of the types of effects that have been 

identified. On the fiscal side, as discussed in detail in Sections 3.7 and 4.7, the Nation has 

made various payments to local governments. In addition, the positive economic effects 

from the Nation’s activities — the employment of nearly 5,000 workers, the Nation’s 

purchases and other spending in the region, and the overall beneficial effect of the 

Nation’s enterprises, particularly Turning Stone Resort & Casino — also serve to mitigate 

the purported adverse fiscal effects that have been identified by various concerned parties 

and the public. Overall, the revenues generated by the Nation’s enterprises exceed the 

amounts that would be received in taxes without those revenues (Further details are 

presented in Sections 3.7 and 4.7 Socioeconomics). 

With respect to potential regulatory effects, the past ten years similarly serve as a guide for 

how they can be avoided or mitigated to be less than significant. The Nation has 

implemented and administered its own regulatory scheme, which covers a broad spectrum 

of environmental and related issues. Moreover, the Nation’s lands have been (and would 

remain) subject to federal environmental laws and regulations. The Nation has consulted 

with State and local jurisdictions informally or on a government-to-government basis on 

matters of mutual concern. The Nation has managed, and continues to manage, activities 

affecting its neighbors through the resolution of environmental, social, cultural and 

economic issues. 

As described in other sections of the Draft EIS, the Nation’s actions in this regard, among 

other things, have also included: 

• The establishment of ordinances, codes and regulations to preserve and protect 

environmental, historic and cultural resources in a manner that is in alignment 

with State and local laws; 

• The adoption and application of a Land Use Ordinance and related ordinances to 

enhance the compatibility of Nation and non-Nation properties and to protect 

public safety and human welfare; 

• Entering service agreements with local communities or paying user-based charges 

and fees with respect to water, sewer, public safety and fire protection; and a 

demonstrated willingness to cooperate and collaborate with State and local 

governments to successfully resolve issues of concern and promote an atmosphere 

of mutual assistance and support. 

The Nation is committed to the continuance of these policies, programs and cooperative 

dialogue and agreements in the broad sense of mitigating potential adverse effects resulting 

from the proposed action. 
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Taxes 

The estimated property tax effects for lands proposed for trust are discussed in Sections 

3.7 and 4.7 Socioeconomics. Lands placed in trust would be exempt from property tax as 

follows under the various alternatives identified in Section 2.0: 

Alternative Land Area (Acres) Property Taxes 

 

 Alternative A 17,370 $2.7 million 

 Alternative B 35,000 $5.4 million 

 Alternative C 9,903 $2.4 million 

 Alternative D 3,248 $1.0 million 

 Alternative E 225 $200 thousand 

 Alternative F 11,986 $2.5 million 

In the future these foregone taxes would be considered an adverse effect on the local 

government revenues. These figures do not include taxes assessed against the casino 

gaming floor tax lot, as that assessment is being disputed. The amount of the property tax 

claimed based on that disputed assessment is almost $11 million. 

This effect has been and would continue to be offset by service agreements and the 

property, sales, and income taxes directly and indirectly generated by the Nation and its 

employees. These include the following: 

• The Nation has made direct payments to local governments of $38.5 million since 

1995 in several categories of spending (i.e., Silver Covenant Payments, Municipal 

Service Agreements, Other Utility/Water Sewer Payments, and Infrastructure). This 

amount includes tax payments in the fall of 2005 and the spring of 2006 to the 

City of Sherrill and the City of Oneida, respectively, as well as $7.7 million in 

Silver Covenant payments to local governments that may be discontinued in the 

future. It is expected that the Nation will continue to pay local governments for 

services provided. 

• Nation employees paid an estimated $5.6 million in local property taxes in 2005. 

• The Nation withheld and remitted $3.3 million in State income taxes from its 

employees in 2005. 

• Nation vendor and employee spending stimulated $7.3 million in New York State 

tax payments for personal income, business, and sales taxes in 2005 and $1.2 

million in local sales tax revenues for Madison and Oneida Counties and the study 

area municipalities. 

• The Nation paid $2.2 million and $2.8 million, respectively, to the New York 

State Police and the New York Racing and Wagering Board for their services to the 

Turning Stone Resort & Casino which would be expected to continue in the 

future. 

This information is discussed and analyzed in detail in Sections 3.7 and 4.7 

Socioeconomics which concludes that the Proposed Action provides more revenues for the 
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state and local governments than would be available without the Nation’s enterprises. 

This is reflected in Table 5.2-1 which shows a summary of the annual 2005 costs 

attributable to the Nation in comparison to the direct payments it made for services and 

the taxes generated by Nation employees and through multiplier effects on other 

businesses. Overall, the total revenues produced by the Nation agreements and associated 

employee and multiplier taxes in 2005 was about $24.2 million while its costs were 

around $6 million, which resulted in a beneficial net effect to the State and local 

governments of over $18 million. A similar comparison for the Proposed Action in 2011 

is outlined in Table 2.5-2 where the estimated beneficial effect to the State and local 

governments increases to nearly $19 million. 
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Table 5.2-1 

Nation Payments and Associated Tax Payments 

Compared to Costs of the Proposed Action in 2005 

($ in Millions) 

New 

York 

State 

Madison 

County and 

Study Area 

Municipalities 

Oneida 

County and 

Study Area 

Municipalities 

School 

Districts Total 

Nation Payments: (1) (2) 

New York State Racing and Wagering 

Board $2.80 $2.80 

New York State Police $2.20 $2.20 

Municipal Service Agreements (7) $0.57 $0.57 

Other Utility/Water/Sewer Payments $0.03 $0.60 $0.63 

Infrastructure Payments $0.25 $0.21 $0.46 

Subtotal $5.00 $0.28 $1.39 $0.00 $6.66 

 

Other Tax Revenue Payments: 

Taxes Paid by Nation Employee 

Income Taxes $3.38 $3.38 

Sales Taxes $1.66 $0.32 $0.60 $2.59 

Property Taxes (3) $1.29 $1.45 $2.89 $5.63 

Subtotal $5.05 $1.61 $2.06 $2.89 $11.60 

 

Taxes Paid from Multiplier Effect (4) 

Sales Tax $0.58 $0.04 $0.19 $0.82 

Personal Income and Business Tax $5.08 $5.08 

Subtotal $5.66 $0.04 $0.19 $0.00 $5.90 

 

Total Revenues $15.71 $1.93 $3.63 $2.89 $24.17 

Less: Total Costs (5) (6) $5.17 $0.21 $0.41 $0.21 $6.00 

Net Effect $10.54 $1.72 $3.22 $2.68 $18.17 

(1) All direct payments made by the Nation in 2005, with exception of infrastructure payments which are estimated as 

1/20th of the total infrastructure payments made between 1995 and 2005 in recognition of useful life of investment in 

assets. 

(2) Excludes one-time payments made by Nation in settlements of existing outstanding property tax bills levied by 

communities. 

(3) Estimate of Nation employee-paid property tax estimated by multiplying per capita assessed value with current tax 

rate, controlling for number of Nation employee household members (employee and other household members) without 

exemptions. 

(4) Does not include estimate of off-site visitor spending tax collections for gas, food, and lodging. 

(5) Total Costs for New York State include Nation reimbursement payments and estimated O&M costs attributable to 

Nation for transportation. Other potential State costs attributed to the Nation for its activities on or related to its lands 

(e.g., State Police, inspections) are not included. 

(6) Total Costs for Local Governments and School Districts do not include the induced costs of Nation employees in their 

residences. 

(7) Service Agreements for Verona including Water, Sewer and Fire District. 
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Table 5.2-2 

Nation Payments and Associated Tax Payments 

Compared to Costs of the Proposed Action in 2011 

($ in Millions)

New 

York 

State 

Madison 

County and 

Study Area 

Municipalities 

Oneida 

County and 

Study Area 

Municipalities 

School 

Districts Total 

Nation Payments: (1) (2) 

New York State Racing and Wagering Board $2.80 $2.80 

New York State Police $2.20 $2.20 

Municipal Service Agreements (7) $0.57 $0.57 

Other Utility/Water/Sewer Payments $0.03 $0.60 $0.63 

Infrastructure Payments $0.25 $0.21 $0.46 

Subtotal $5.00 $0.28 $1.39 $0.00 $6.66 

 

Other Payments: 

Taxes Paid by Nation Employee 

Income Taxes $3.57 $0.00 $3.57 

Sales Taxes $1.76 $0.34 $0.64 $2.73 

Property Taxes (3) $0.00 $1.37 $1.54 $3.06 $5.96 

Subtotal $5.33 $1.70 $2.18 $3.06 $12.27 

 

Taxes Paid from Multiplier Effect (4) 

Sales Tax $0.61 $0.05 $0.20 $0.86 

Personal Income and Business Tax $5.37 $0.00 $5.37 

Subtotal $5.99 $0.05 $0.20 $0.00 $6.23 

 

Total Revenues $16.32 $2.03 $3.76 $3.06 $25.17 

Less: Total Costs (5) (6) $5.17 $0.27 $0.43 $0.34 $6.21 

Net effect $11.14 $1.76 $3.33 $2.72 $18.95 

 

(1) All direct payments made by the Nation in 2005, with exception of infrastructure payments which are estimated as 1/20th 

of the total infrastructure payments made between 1995 and 2005 in recognition of useful life of investment in assets. 

(2) Excludes one-time payments made by Nation in settlements of existing outstanding property tax bills levied by 

communities. 

(3) Estimate of Nation employee-paid property tax estimated by multiplying per capita assessed value with current tax rate, 

controlling for number of Nation employee household members (employee and other household members) without 

exemptions. 

(4) Does not include estimate of off-site visitor spending tax collections for gas, food, and lodging. 

(5) Total Costs for New York State include Nation reimbursement payments and estimated O&M costs attributable to Nation 

for transportation. Other potential State costs attributed to the Nation for its activities on or related to its lands (e.g., State 

Police, inspections) are not included. 

(6) Total Costs for Local Governments and School Districts do not include the induced costs of Nation employees in their 

residences. 

(7) Service Agreements for Verona including Water, Sewer and Fire District. 
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Regulatory Jurisdiction 

New York State and local governments have taken the position that lands transferred into 

trust would have an adverse effect by precluding their authority to regulate uses and 

activities on the Nation’s trust lands. The State has asserted that the separation of lands 

from New York State and local regulatory jurisdiction affects the regulatory scheme as a 

whole because of the difficulty in applying environmental laws uniformly and equitably 

over an entire geographic area. 

If the proposed action were to be adopted, the trust lands would continue to be regulated 

by Federal laws including environmental laws. In addition, the land would continue to be 

regulated by Nation laws and ordinances, many of which have been in place for nearly 10 

years, covering building construction, land use, public safety, hunting and fishing, historic 

preservation, and environmental protection (For details on the Nation’s laws and 

ordinances refer to Section 3.9.5 Regulatory Programs). Through those policies, the 

Nation remains committed to standards of environmental protection and conservation. 

The Nation has further demonstrated this commitment in past collaborative actions with 

New York State and local municipalities involving, for example, the protection of species, 

the CWD program, permitting of the reclaimed water pipeline, a cooperative agreement 

with the SHPO, the creation of the 75-acre wetlands bank, following the intent of New 

York State and local air and noise standards, and the preservation of the Rome Sands 

Plain. The government-to-government service agreements that the Nation has entered 

with respect to water, sewer, public safety and fire protection have served as a 

jurisdictional bridge. The combination of Federal and Nation regulatory oversight and the 

ongoing practice of consultation and coordination between the Nation, Federal, New 

York State and local agencies could serve as a mechanism to mitigate effects on the 

environmental, cultural and socioeconomic environment stemming from lands held in trust 

status. 

Land Use Planning and Zoning 

Similarly, the State and local governments have contended that transferring lands into 

trust would have adverse effects where the local government is unable to effectively 

implement community planning and its zoning, land use, and other regulations. In all 

alternatives, except Alternative G - No Action, portions of Nation trust lands would be 

interspersed with non-Nation lands. Local governments would have no jurisdiction over 

the trust lands and have asserted that this would have an adverse effect on their ability to 

cohesively plan and to uniformly enforce their zoning and land use regulations. 

The extent of this effect would be different in each alternative. In many cases, Nation’s 

lands comprise a very small percentage of the entire area of the community, which 

minimizes the geographic extent of the effect. In most areas, the Nation’s current land 

uses are consistent with local zoning and land use plans in the surrounding communities. 

The Nation is not planning any development that would be inconsistent with local 
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municipality zoning, with the possible exception of additional two family dwellings in the 

Village of White Pines. In addition, the Nation has adopted and followed an Oneida 

Indian Nation Land Use Ordinance and other ordinances to protect and preserve public 

safety and human welfare. The Oneida Indian Nation Land Use Ordinance mandates that 

no existing land uses can be substantially changed or altered unless a Land Use Permit is 

obtained after the Nation considers compatibility, location and environmental effect. 

This and the Nation's history of cooperation with and support of local community 

infrastructure and programs could provide the basis for effective collaborative land use 

planning for establishing consistency across non-Nation and Nation lands (Refer to 

Sections 3.2 and 4.2 on Land Resources for further details). A continuation of these 

practices could serve to mitigate the potential effects expressed by the State and local 

governments. 

Surface Water 

Under Alternative E PTNP- F and the CC-AEC and PTNP-F scenarios under Alternative G 

- No Action, golf courses would cease operations. Surface water quality may deteriorate 

when storm water control measures fall into disrepair. The golf course irrigation water 

would no longer be reclaimed from the City of Oneida Sewage Treatment Plant and would 

instead be discharged to Oneida Creek, increasing its nutrient load. However, the most 

likely mitigation, which would be the responsibility of the new owner, would be to close 

the reuse system and process the wastewater through the City of Oneida Sewage 

Treatment Plant which has the treatment capacity to accommodate the additional load. 

Under alternatives and scenarios whereby the Turning Stone Resort & Casino and its 

attendant facilities grow due to increased visitors, there would be a less than significant 

effect of increased water supply and wastewater (Refer to Section 4.3 Water Resources for 

further discussion). 

Under the Proposed Action surface water would continue to be regulated by federal law 

and wastewater treatment plant effluent limits would continue to be set by permits issued 

by NYSDEC and USEPA. In the past the Nation has demonstrated its support and 

commitment to surface water protection by: (1) funding the expansion of the wastewater 

treatment plant; (2) requiring that contractors for the Nation’s construction projects 

adhere to the conditions of the NYSDEC State Pollutant Discharge Elimination System 

General Permit for Storm Water Discharges from Construction Activities; (3) funding 

studies in cooperation with local governments to locate new sources of water; and 

(4) funding 100% of a new water and sewer line and a water tower in the Town of 

Verona (More details are provided in Sections 3.3 Water Resources and 4.3 Water 

Resources). In addition the Nation has implemented water conservation measures that 

have significantly reduced water consumption at Turning Stone Resort & Casino, thereby 

mitigating the effect of the resort’s growth on local water resources. This includes the 

installation of state-of-the-art on-line water treatment systems on the cooling towers of the 
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cogeneration facility, allowing the Nation to use reclaimed water from the City of Oneida 

Sewage Treatment Plant—a practice that saves approximately 40,000 gallons of water per 

day. The Nation has also installed a water treatment system at its Villages at Turning 

Stone RV Park that has reduced water use by approximately 15,000 gallons per day 

during camping season. Additional conservation measures include: (1) shutting off 

outside hose bibs to prevent unauthorized use of domestic water; (2) installing water 

meters on all water feed lines into the resort and monitoring these meters daily; 

(3) running sprinkler flow tests for shorter durations; and (4) running boilers at higher 

cycles of concentration. All of these examples are ongoing measures the Nation is 

employing now to avoid or mitigate the effects to surface water quality and quantity. 

Employment 

Losses of jobs would be unavoidable under certain alternatives and their scenarios 

(Specific details are presented in Sections 3.7 and 4.7 Socioeconomics). In Alternatives D 

and E, overall Nation employment would decrease and there would be a loss of jobs at 

local non-Nation businesses. Under the Alternative G - No Action CC-AEC or PTNP-F 

scenarios, there would be a significant loss of 5,773 jobs (compared to Alternative A) 

affecting the 86 percent of workers (or 4,992 residents) of Madison or Oneida Counties 

who are directly employed or indirectly supported by the Nation’s economic activity. 

Mitigation of these effects in the form of unemployment compensation and support would 

become the responsibility of State and local governments. 

Traffic 

In Alternatives A through F, as a result of additional visitors to the Turning Stone Resort 

& Casino, traffic is projected to increase to 2,174 trips during the evening peak in 2011. 

Due to Nation-funded mitigation to area roadways in 1997 (in the vicinity of the casino 

resort) this increase in vehicle trips could be accommodated. However, a drop in the level 

of service and associated delays may occur during peak periods at the intersection of NYS 

Route 365 and I-90 Exit 33. Possible improvements have been identified which include: 

reduction of speed limits on Route 365; an additional lane exiting I-90 at Route 365; and 

increasing the capacity at the I-90 toll booths. Please refer to Sections 3.8.5 and 4.8.5 

Transportation for further details. 

Historic, Cultural and Archaeological Resources 

Under different alternatives various amounts of land would enter trust containing the 

Nation’s important cultural and archaeological sites. The National Historic Preservation 

Act would still continue to apply to lands in trust and those lands would receive added 

protection under ARPA and NAGPRA. The Nation has enacted its own Oneida Indian 

Nation Cultural, Historical or Archeological Resources Ordinance and has a Nation 

Historian and a Historic Preservation Committee to oversee all activities related to the 

preservation of the Nation’s historic and archaeological resources. Since taking possession 

of some of their cultural assets, the Nation has implemented a program to preserve and 

protect those sites as well as to archive important artifacts and data recorded from those 
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sites. Prior to their acquisition by the Nation, these sites had been damaged and looted by 

amateur artifact seekers. 

The Nation has worked with the New York State Office of Parks, Recreation and Historic 

Preservation, and the Nation and SHPO signed a cooperative agreement on March 18, 

2004 to share archeological site file information. For detailed information on historic, 

cultural and archaeological resources refer to Sections 3.6 and 4.6 Cultural Resources. 

A combination of the State, Federal and Nation protective regulations, the Nation’s 

proactive program to preserve its archaeological sites, and a continuation of the 

cooperation between the Nation and State agencies, could serve to mitigate potential 

regulatory effects and sustain resource protective programs.

Government Services 

In the PTNP-F or CC-AEC scenarios of Alternatives D, E or G all the Nation’s 

government programs would be severely curtailed or cease altogether because they are 

located in facilities on lands that would be alienated or foreclosed. Other than trust land 

conveyance, substantial Federal funding and support would become necessary and might 

not be sufficient to mitigate significant adverse effects on the Nation and its members. 

The Nation’s demand for healthcare, emergency medical services, fire protection and other 

community supplied services would increase with incremental growth in the community 

and potentially with more visitors going to the Turning Stone Resort & Casino. This 

would have a less than significant effect on the resources of the local governments to meet 

the increased service needs. Over the next five years, there would be only a 0.1 percent 

increase in the two-county population due to additional employment and only a five 

percent increase in school-aged children. The increase in visitors at the Turning Stone 

resort & Casino would only incrementally affect the community supporting infrastructure 

already in place (see Section 4.7.8 for more details). The anticipated growth would not 

increase the demand enough to result in the construction of new facilities or infrastructure 

or in physical alterations to existing facilities. The increased demand would not be large 

enough to affect current response times for emergency services. There may be need for 

some change in equipment needs and deployment for select government services. Local 

and State police have complete jurisdiction enforcement power on all Nation lands 

regardless of whether they are in trust or not, although Nation police attend to service 

calls on Nation lands that reduces the level of resource commitments of other local 

policing jurisdictions. 

In the past, the Nation has supported the expansion of these services by providing funding 

to the local municipalities in a variety of ways. The Nation continues to send most of their 

children to local public schools for their education, utilize existing healthcare facilities, 

cooperate with local police departments regarding law enforcement, and rely on 

municipalities for emergency response and fire protection. Current and ongoing service 
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agreements and cooperative service efforts, such as the Mutual Aid Plan, would be 

expected to continue. More detailed discussions of government services are presented in 

Sections 3.7.4, 3.7.8, 4.7.4, and 4.7.8. 

With regard to mitigating the effect of adding Native American students to local schools, 

there are three types of dedicated financial assistance that are available to public school 

systems to offset the effects of the tax-exempt status of Indian lands that may have 

relevance in New York: 

• Federal Effect Aid Program -- Effect Aid, now Title VIII of the Elementary and 

Secondary Education Act of 1965, consists of four parts dealing with: loss of 

federal property, basic support payments for federally connected children, disabled 

federally-connected children, and construction grants for school systems that serve 

large numbers of federally connected children. In excess of 90 percent of the 

annual allotments are distributions for the basic support payments to federally 

connected children, meaning students from families that live or work on military 

or federally recognized Indian lands that do not make tax payments that reach 

local school systems. Records have indicated that no school district in New York 

State accepted Effect Aid funds due to Indian student enrollment in 2005, the most 

recent year for which data were available. 

• Indian Education Act - The Indian Education Act of 1972 (IEA) is administered by 

the U.S. Department of Education. The IEA provides grants based on the average 

amount spent on each child in the state containing the applying school system and 

the number of Native American students in the school district. It is designed to 

focus on programs not capital construction or repairs/maintenance of facilities. 

The Madison and Oneida schools meeting or exceeding the 10 student or 25% 

Native American enrollment criteria are eligible to receive IEA funding. 

• New York State Indian Aid for Public Schools -- New York State, through its 

Office of Native American Education, offers financial assistance directly to public 

schools that have students from Indian families living on tribal lands. Only services 

provided to students living on Indian Nation lands can be counted towards a 

reimbursement. At this point in time and for the recent past, of all the school 

systems in Madison and Oneida Counties, only the Stockbridge Valley Central 

School System in Oneida County has received reimbursements through this 

program. 

In addition, the maintenance of service agreements and their modification if necessary to 

accommodate growth along with a continuation of cooperation between the Nation and 

the municipal service providers would further mitigate an increase in demand for 

community services. 

Lifestyles and Cultural Values 

The projects and programs implemented by the Nation that focus on culture, language, 

ceremonies, and community are critical and necessary for the Nation to retain the unique 

Oneida lifestyle attributes, cultural values, and philosophy. Alternatives D and E both 

would exclude all the key lands with respective cultural facilities owned by the Oneida 
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such as the Shako: wi Cultural Center, Ray Elm Children & Elders Center, Village of 

White Pines, Festival Sites, traditional croplands plus cultural service departments. Both 

alternatives, under the PTNP-F scenario where these lands would be alienated or 

foreclosed, would have the same direct significant adverse effect on the Nation. 

Alternative G would convey no lands into trust and would also have a significant adverse 

effect on the Nation especially under either the CC-AEC or the PTNP-F scenarios where 

the lands supporting all of the Oneida cultural foundation would be alienated or 

foreclosed. More details are provided in Sections 3.7.11 and 4.7.11 which address 

Lifestyle and Cultural Values. 

While increased federal or New York State funding, if it were available, could mitigate 

some of these effects, it could not mitigate the effect on Oneida cultural values, sense of 

community and self-identity that would result from the No Action alternative, or 

Alternatives D and E. Such effects would be avoided by providing the Nation with a landbased homeland for its people, where the Nation can exercise sovereignty and maintain 

and support its lifestyles and cultural values.