Sunday, November 4, 2007

Call for Public Comments on Whether the Border Wall and Wildlife Refuges are Compatible

Comments are being accepted by the US Fish and Wildlife Service regarding surveying activities on Lower Rio Grande Valley National Wildlife Refuge tracts. A survey for natural resources and a survey for cultural resources will be conducted in preparation for building a border wall on at least 14 separate refuge tracts. USFWS is preparing documents that will determine whether these activities are compatible with their mission. It is important that everyone who is concerned about the construction of the border wall submit a comment to USFWS. Please send your comments via email or US mail by November 19, 2007!

Here are a few ways to guide your comments:

· According to US Fish and Wildlife regulations (603 FW 2), “The refuge manager will not initiate or permit a new use of a national wildlife refuge or expand, renew, or extend an existing use of a national wildlife refuge unless the refuge manager has determined that the use is a compatible use.” It goes on to say, “Fragmentation of the National Wildlife Refuge System's wildlife habitats is a direct threat to the integrity of the National Wildlife Refuge System, both today and in the decades ahead. Uses that we reasonably may anticipate to reduce the quality or quantity or fragment habitats on a national wildlife refuge will not be compatible.” As the intent of these surveys is to pave the way for the construction of border walls which will seriously degrade and fragment the Lower Rio Grande Valley National Wildlife Refuge, they are incompatible with the mission of the Refuge.

· We have no faith in the utility and impartiality of the survey process. The private corporation in charge of conducting the surveys, Engineering-Environmental Management, Inc. (E²M), has a vested interest in expediting the construction of the border walls to please their client, the Department of Homeland Security. In addition, E²M has already mismanaged the public comment period of the Rio Grande Valley EIS, allowing technical difficulties with both the official website and the posted fax number to interfere with the acceptance of public comments for several days of the already EIS short comment period. E²M should not be in charge of this vitally important surveying task. It should instead be carried out by local US Fish and Wildlife biologists who are familiar with the natural and cultural resources that are present in the Lower Rio Grande Valley National Wildlife Refuge.

· The USFWS has expressed concerns that there will not be enough refuge staff to properly oversee survey activities. We share these concerns; there should be USFWS oversight for all activities.

· The natural resource survey is further compromised by its limited duration. E²M employees will only spend 10 days surveying the natural resources in the wall’s path. That is utterly insufficient. Endangered species are by definition extremely rare, and sightings of migratory species are dependent on the time of year, so the odds of seeing one during any 10 day period are next to nothing. If they fail to see a particular endangered or migratory animal during their brief visit the final report may give the false impression that they are not present and will not be impacted by the wall.

· The cultural resource survey contains a troubling provision for backhoe trenching up to 33 ft deep in areas that have a high probability of cultural resources. This is listed as a “last option,” but it should not be allowed at all. Not only would such an activity be incompatible with the environmental mission of the refuge, it would likely destroy the very cultural resources that are being documented.

Please send comments to:

Refuge Manager
Lower Rio Grande Valley NWR
Rt. 2 Box 202A
Alamo, TX 78516

Or email (Subject line: Draft Compatibility Determinations: Border Fence)

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