Customs and Border Protection has prepared a draft Programmatic Environmental Impact Statement for unspecified enforcement activities along the entire US - Canada border, from Maine to Washington. These could include new or expanded forward operating bases, fencing, roads, towers, and just about anything that they think of over the next decade or so. The PEIS is extremely vague on exactly what might be done and where. It can be viewed here:
http://www.northernborderpeis.com/about-the-peis.html
The public and interested organizations should offer comments, either online or at one of the scheduled public meetings along the northern border. Public meetings will be held from 7-9PM at the following locations:
October 4, 2011
Massena, NY VFW
101 W. Hatfield St.
Massena, NY 13662
October 6, 2011
St. Albans, VT
St. Albans Historical Museum
9 Church Street
St. Albans, VT 05478
October 5, 2011
Augusta, ME
The Senator Inn & Spa
284 Western Ave.
Augusta, ME 04330
October 4, 2011
Caribou, ME
Caribou Inn and Convention Center
19 Main Street
Caribou, ME 04736
October 11, 2011
Rochester, NY
Holiday Inn - Rochester
Airport 911 Brooks Avenue
Rochester, NY 15624
October 12, 2011
Erie, PA
Ambassador Banquet Center
7794 Peach Street
Erie, PA 16509
October 6, 2011
Detroit, MI
Holiday Inn Express
1020 Washington Boulevard
Detroit, MI 48226
October 17, 2011
Washington, DC
Crystal City Marriott at Reagan National Airport
1999 Jefferson Davis Highway
Arlington, VA 22201
October 3, 2011
Duluth, MN Holiday Inn
200 West First Street
Duluth, MN 55802
October 13, 2011
Naples, ID
The Great Northwestern Territories Event Center
336 County Road 8
Naples, ID 83847
October 5, 2011
Bottineau, ND
Twin Oaks Resort and Convention Center
10723 Lake Loop Road
Bottineau, ND 58318
October 11, 2011
Bellingham, WA
Hampton Inn
3958 Bennett Drive
Bellingham, WA
October 6, 2011
Havre, MT
The Town House Inn
627 1st Street West
Havre, MT 59501
Showing posts with label environmental impact statement. Show all posts
Showing posts with label environmental impact statement. Show all posts
Wednesday, September 21, 2011
Wednesday, September 3, 2008
National Campaign Against the Border Wall: Activist Kits Available
No Border Wall Coalition has developed two national campaigns designed to amplify the anti-wall message during the presidential campaign season. (See below for details.) We hope that these projects can help diverse groups and individuals unite and build a strong national movement against the border wall ahead of the new Congress and new administration.
We would appreciate your help publicizing and distributing materials and facilitating these initiatives. If you are interested, we can send you a kit that includes a slideshow presentation CD, project worksheets, and a border wall factsheet. The slideshow is a 12 minute overview of the border wall issue and covers the entire southern border. Please request materials from noborderwall@yahoo.com.
Here are descriptions of the campaigns:
National Letter Writing Campaign: This campaign is targeted to those groups working outside of the border region or to border groups for which the wall has not been a central focus. It consists of a Letter-Writing Campaign Kit, which we will send upon request. The kit contains a 12-minute slide presentation which is an overview of the damages that border walls cause or will cause and features compelling photos from all along the border (thanks to many of you), a factsheet, and a letter-writing worksheet. The ideal use for the kit is for groups to set aside 45 min to 1 hour in their meeting program to view the slideshow, discuss the issue and write letters to their US senators.
Border Wall Documentation Project: This campaign is designed to bring together all of the activist groups and individuals along the border for a single mission: to document the negative impacts of the border wall and border wall construction, as well as the abuse, neglect and incompetence of DHS, CBP and Border Patrol in its implementation of the border wall project. It calls upon border residents to bear witness to the destruction caused by the border wall and the abuse perpetrated by DHS and to report the destruction and abuse to Congress. Many border residents were able to document the potential damage of the border wall in their areas during the Environmental Impact Statement process. However, now that Chertoff has waived the laws, there is no longer any official process through which damages will be documented. What we would like to do with the border wall documentation project is reinstate such a process border-wide and compile documents for use in anti-wall lobbying efforts, Congressional hearings and lawsuits. If we get a good response, we might also be able to assemble an online database which could be useful well into the future, even in future efforts to bring down existing walls. Joining together for such an important project will also help us all get to know one another and other sympathetic border groups, create solidarity, and give us an opportunity to speak with one voice.
We would appreciate your help publicizing and distributing materials and facilitating these initiatives. If you are interested, we can send you a kit that includes a slideshow presentation CD, project worksheets, and a border wall factsheet. The slideshow is a 12 minute overview of the border wall issue and covers the entire southern border. Please request materials from noborderwall@yahoo.com.
Here are descriptions of the campaigns:
National Letter Writing Campaign: This campaign is targeted to those groups working outside of the border region or to border groups for which the wall has not been a central focus. It consists of a Letter-Writing Campaign Kit, which we will send upon request. The kit contains a 12-minute slide presentation which is an overview of the damages that border walls cause or will cause and features compelling photos from all along the border (thanks to many of you), a factsheet, and a letter-writing worksheet. The ideal use for the kit is for groups to set aside 45 min to 1 hour in their meeting program to view the slideshow, discuss the issue and write letters to their US senators.
Border Wall Documentation Project: This campaign is designed to bring together all of the activist groups and individuals along the border for a single mission: to document the negative impacts of the border wall and border wall construction, as well as the abuse, neglect and incompetence of DHS, CBP and Border Patrol in its implementation of the border wall project. It calls upon border residents to bear witness to the destruction caused by the border wall and the abuse perpetrated by DHS and to report the destruction and abuse to Congress. Many border residents were able to document the potential damage of the border wall in their areas during the Environmental Impact Statement process. However, now that Chertoff has waived the laws, there is no longer any official process through which damages will be documented. What we would like to do with the border wall documentation project is reinstate such a process border-wide and compile documents for use in anti-wall lobbying efforts, Congressional hearings and lawsuits. If we get a good response, we might also be able to assemble an online database which could be useful well into the future, even in future efforts to bring down existing walls. Joining together for such an important project will also help us all get to know one another and other sympathetic border groups, create solidarity, and give us an opportunity to speak with one voice.
Wednesday, January 23, 2008
Submit Comments on New Border Walls in San Diego, El Paso, Tucson, Yuma, and Marfa
Ignoring the growing opposition to the construction of walls along the border, DHS Secretary Chertoff is pushing for hundreds of miles to be built in 2008. This despite the fact that Chertoff himself said back in July,
"Fencing is not the cure-all for the problem at the border. I think the fence has come to assume a certain kind of symbolic significance which should not obscure the fact that it is a much more complicated problem than putting up a fence which someone can climb over with a ladder or tunnel under with a shovel.”
Instead of searching for substantive solutions to border issues, Chertoff is plowing ahead with the hollow symbol of the wall. To quickly lay the groundwork the Department of Homeland Security has once again hired a private contractor, e2M, to sell the wall. In the past month they have issued a steady stream of reports that are intended to give the impression that the environmental and societal impacts of the wall have been thoroughly evaluated, and that the National Environmental Policy Act is being complied with. One of the requirements of NEPA is public input and openness, so brief public comment periods have been established for each sector's report. It is vital that they hear from us, as our comments will become part of the official public record. DHS has recently taken to lying to Congress and the press about the inclusion of public input into the border wall process. A flood of comments opposing the wall will make it more difficult for them to lie about public support for the border wall.
Below is the information needed to access and comment upon each of the newly released reports.
San Diego, California
4 miles will be added to the existing wall.
The Draft Environmental Impact Statement is available at http://www.borderfencenepa.com/san-diego-sector-eis/
To submit a public comment:
Electronically through this website: SAN DIEGO SECTOR EIS COMMENT FORM
By email to: SDcomments@BorderFenceNEPA.com
By mail to: San Diego Sector Tactical Infrastructure EIS, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
By Fax to: (757) 257-7643
The public comment period ends February 11, 2008
Also near San Diego, California
30 more miles of wall will be built.
The Draft Environmental Assessment is available at
http://www.borderfencenepa.com/san-diego-sector-ea/
To submit a public comment:
By email to: SDEAcomments@BorderFenceNEPA.com
By mail to: San Diego Sector Tactical Infrastructure EA, c/o Gulf South Research Corporation, Baton Rouge, Louisiana, 70820
By Fax to: (225) 761-8077
The public comment period ends February 5, 2008
In El Paso, Texas
24.5 miles of wall will be built.
The Draft Supplemental Environmental Assessment is available at
http://www.borderfencenepa.com/el-paso-sector-sea/
To submit a public comment:
By email to: DSEAcomments@BorderFenceNEPA.com
By mail to: El Paso Sector, Deming Station, Tactical Infrastructure SEA, c/o Gulf South Research Corporation, 8081 GSRI Avenue, Baton Rouge, Louisiana 70820
By Fax to: (225) 761-8077
The public comment period ends February 16, 2008
In Tucson, Arizona
7.6 miles of new wall will be built.
The Draft Environmental Assessment is available at
http://www.borderfencenepa.com/tucson-sector-ea/
To submit a public comment:
Attend and submit comments at the public open house to be held 4:30 p.m. to 8:00 p.m. on January 31, 2008 at the Tucson Convention Center, 260 South Church Avenue, Tucson, Arizona 85701
Electronically through the Web site at: http://www.borderfencenepa.com/
By email to: TSEAcomments@BorderFenceNEPA.com
By mail to: Tucson Sector Tactical Infrastructure EA, c/o Gulf South Research Corporation, 8081 GSRI Avenue, Baton Rouge, Louisiana 70820
By Fax to: (225) 761-8077
The public comment period ends February 16, 2008.
Near Yuma, Arizona
14 miles of wall will be built.
The Draft Supplemental Environmental Assessment is available at
http://www.borderfencenepa.com/yuma-sector-sea/
To submit a public comment:
Attend and submit comments at the public open house to be held 4:30 p.m. to 8:00 p.m. on January 30, 2008 at the Shilo Inn Hotel, 1550 South Castle Dome Avenue, Yuma, Arizona 85365, (928) 782-9511
Electronically through the Web site at: http://www.borderfencenepa.com/
By email to: YSEAcomments@BorderFenceNEPA.com
By mail to: Yuma Sector Tactical Infrastructure SEA, c/o Gulf South Research Corporation, 8081 GSRI Avenue, Baton Rouge, Louisiana 70820
By Fax to: (225) 761-8077
The public comment period ends February 20, 2008
Near Marfa, Texas
11 miles of wall will be built.
The Draft Environmental assessment is available at
http://www.borderfencenepa.com/marfa-sector-ea/
To submit a public comment (if you missed the January 23rd protest):
Electronically through the Web site at: MARFA SECTOR EA COMMENT FORM
By email to: MScomments@BorderFenceNEPA.com
By mail to: Marfa Sector Tactical Infrastructure EA, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
By fax to: (757) 299-8444
The public comment period ends February 6, 2008.
"Fencing is not the cure-all for the problem at the border. I think the fence has come to assume a certain kind of symbolic significance which should not obscure the fact that it is a much more complicated problem than putting up a fence which someone can climb over with a ladder or tunnel under with a shovel.”
Instead of searching for substantive solutions to border issues, Chertoff is plowing ahead with the hollow symbol of the wall. To quickly lay the groundwork the Department of Homeland Security has once again hired a private contractor, e2M, to sell the wall. In the past month they have issued a steady stream of reports that are intended to give the impression that the environmental and societal impacts of the wall have been thoroughly evaluated, and that the National Environmental Policy Act is being complied with. One of the requirements of NEPA is public input and openness, so brief public comment periods have been established for each sector's report. It is vital that they hear from us, as our comments will become part of the official public record. DHS has recently taken to lying to Congress and the press about the inclusion of public input into the border wall process. A flood of comments opposing the wall will make it more difficult for them to lie about public support for the border wall.
Below is the information needed to access and comment upon each of the newly released reports.
San Diego, California
4 miles will be added to the existing wall.
The Draft Environmental Impact Statement is available at http://www.borderfencenepa.com/san-diego-sector-eis/
To submit a public comment:
Electronically through this website: SAN DIEGO SECTOR EIS COMMENT FORM
By email to: SDcomments@BorderFenceNEPA.com
By mail to: San Diego Sector Tactical Infrastructure EIS, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
By Fax to: (757) 257-7643
The public comment period ends February 11, 2008
Also near San Diego, California
30 more miles of wall will be built.
The Draft Environmental Assessment is available at
http://www.borderfencenepa.com/san-diego-sector-ea/
To submit a public comment:
By email to: SDEAcomments@BorderFenceNEPA.com
By mail to: San Diego Sector Tactical Infrastructure EA, c/o Gulf South Research Corporation, Baton Rouge, Louisiana, 70820
By Fax to: (225) 761-8077
The public comment period ends February 5, 2008
In El Paso, Texas
24.5 miles of wall will be built.
The Draft Supplemental Environmental Assessment is available at
http://www.borderfencenepa.com/el-paso-sector-sea/
To submit a public comment:
By email to: DSEAcomments@BorderFenceNEPA.com
By mail to: El Paso Sector, Deming Station, Tactical Infrastructure SEA, c/o Gulf South Research Corporation, 8081 GSRI Avenue, Baton Rouge, Louisiana 70820
By Fax to: (225) 761-8077
The public comment period ends February 16, 2008
In Tucson, Arizona
7.6 miles of new wall will be built.
The Draft Environmental Assessment is available at
http://www.borderfencenepa.com/tucson-sector-ea/
To submit a public comment:
Attend and submit comments at the public open house to be held 4:30 p.m. to 8:00 p.m. on January 31, 2008 at the Tucson Convention Center, 260 South Church Avenue, Tucson, Arizona 85701
Electronically through the Web site at: http://www.borderfencenepa.com/
By email to: TSEAcomments@BorderFenceNEPA.com
By mail to: Tucson Sector Tactical Infrastructure EA, c/o Gulf South Research Corporation, 8081 GSRI Avenue, Baton Rouge, Louisiana 70820
By Fax to: (225) 761-8077
The public comment period ends February 16, 2008.
Near Yuma, Arizona
14 miles of wall will be built.
The Draft Supplemental Environmental Assessment is available at
http://www.borderfencenepa.com/yuma-sector-sea/
To submit a public comment:
Attend and submit comments at the public open house to be held 4:30 p.m. to 8:00 p.m. on January 30, 2008 at the Shilo Inn Hotel, 1550 South Castle Dome Avenue, Yuma, Arizona 85365, (928) 782-9511
Electronically through the Web site at: http://www.borderfencenepa.com/
By email to: YSEAcomments@BorderFenceNEPA.com
By mail to: Yuma Sector Tactical Infrastructure SEA, c/o Gulf South Research Corporation, 8081 GSRI Avenue, Baton Rouge, Louisiana 70820
By Fax to: (225) 761-8077
The public comment period ends February 20, 2008
Near Marfa, Texas
11 miles of wall will be built.
The Draft Environmental assessment is available at
http://www.borderfencenepa.com/marfa-sector-ea/
To submit a public comment (if you missed the January 23rd protest):
Electronically through the Web site at: MARFA SECTOR EA COMMENT FORM
By email to: MScomments@BorderFenceNEPA.com
By mail to: Marfa Sector Tactical Infrastructure EA, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
By fax to: (757) 299-8444
The public comment period ends February 6, 2008.
Wednesday, January 9, 2008
Del Rio, Texas Border Wall Public Comment Period Open Until February 5
The Department of Homeland Security has announced that 4 miles of new border wall (or border fence, or tactical infrastructure) will be built near Del Rio, Texas beginning in the Spring of 2008. A Draft Environmental Assessment has been released, and public comments will be accepted through February 5th, 2008.
The Draft Environmental Assessment for the Del Rio Sector is available for download at. http://www.borderfencenepa.com/del-rio-sector-ea/ . A paper copy may be requested as well.
You can submit a public comment on the Del Rio, Texas border wall in one of the following ways:
a) Attend and submit comments at the public open house to be held 4:30 p.m. to 8:00 p.m. local time on January 24, 2008 at the at the Ramada Inn-Del Rio, 2101 Veterans Boulevard, Del Rio, Texas 78840.
b) Electronically through the Web site at: http://www.borderfencenepa.com/
c) By email to: DRcomments@BorderFenceNEPA.comd) By mail to: Del Rio Sector Tactical Infrastructure EA, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
e) By Fax to: (757) 299-4101
When submitting comments, please include name and address, and identify comments as intended for the Del Rio Sector Draft EA.
All submitted comments are supposed to become a part of the public record. To comply with the National Environmental Policy Act the Final Environmental Assessment should include responses to the public comments that are received.
In fiscal 2007 the Del Rio Sector, where there has never been a wall, saw a 45% drop in apprehensions of border crossers. In contrast, the San Diego sector, where there has been a wall for over a decade, saw a 7% increase. DHS has yet to explain the rationale for importing this failed and expensive project from San Diego to Del Rio, where they seem to be having great success without it.
It is especially important that the public comment on the Del Rio Draft EA because it is a fundamentally flawed document that in no way meets the requirements of the National Environmental Policy Act. The most glaring deficiency is its description of the purpose for carrying out the proposed action. Rather than establishing national security or the reduction of illegal activity as the purpose, the Draft EA states,
“The purpose of the Proposed Action is to increase border security within USBP Del Rio Sector through the construction, operation, and maintenance of tactical infrastructure in the form of fences, roads, and supporting technological and tactical assets.” (1.2 - 4)
The “proposed action” is described as follows:
“CBP proposes to construct, operate, and maintain tactical infrastructure consisting of primary pedestrian fence; concrete retaining wall; and associated patrol and access roads, and lights along two discrete areas of the U.S./Mexico international border in the USBP Del Rio Sector, Texas” (1.3 – 5)
If the purpose and the proposed action are one and the same - the construction, operation, and maintenance of “tactical infrastructure” - then by definition no other alternatives will be able to achieve the stated purpose. “Additional USBP Agents in Lieu of Tactical Infrastructure” may in fact be highly effective at preventing unauthorized entries into the United States, but because it is “in Lieu of Tactical Infrastructure” it will never bring about the stated goal of “the construction, operation, and maintenance of tactical infrastructure.” The same holds true for all of the other “Alternatives Considered but Eliminated from Further Detailed Analysis.” In each case, the phrase “in Lieu of Tactical Infrastructure” is attached, so by definition none will align with the stated purpose. This is a clear violation of the Council on Environmental Quality’s regulations.
The private contractor hired by the Department of Homeland Security is apparently more interested in pleasing their employer than complying with NEPA. Instead of producing misleading document with a predetermined outcome, they should go back to the drawing board and produce an unbiased assessment of the environmental and cultural impacts that the border wall will have. A project of this magnitude requires a full Environmental Impact Statement rather than a far less rigorous Environmental Assessment. In either case, the final document should provide objective information rather than a sales pitch.
It is crucial that everyone with these and other concerns about the border wall submit them in writing. The Department of Homeland Security will interpret silence as a lack of interest.
The Draft Environmental Assessment for the Del Rio Sector is available for download at. http://www.borderfencenepa.com/del-rio-sector-ea/ . A paper copy may be requested as well.
You can submit a public comment on the Del Rio, Texas border wall in one of the following ways:
a) Attend and submit comments at the public open house to be held 4:30 p.m. to 8:00 p.m. local time on January 24, 2008 at the at the Ramada Inn-Del Rio, 2101 Veterans Boulevard, Del Rio, Texas 78840.
b) Electronically through the Web site at: http://www.borderfencenepa.com/
c) By email to: DRcomments@BorderFenceNEPA.comd) By mail to: Del Rio Sector Tactical Infrastructure EA, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
e) By Fax to: (757) 299-4101
When submitting comments, please include name and address, and identify comments as intended for the Del Rio Sector Draft EA.
All submitted comments are supposed to become a part of the public record. To comply with the National Environmental Policy Act the Final Environmental Assessment should include responses to the public comments that are received.
In fiscal 2007 the Del Rio Sector, where there has never been a wall, saw a 45% drop in apprehensions of border crossers. In contrast, the San Diego sector, where there has been a wall for over a decade, saw a 7% increase. DHS has yet to explain the rationale for importing this failed and expensive project from San Diego to Del Rio, where they seem to be having great success without it.
It is especially important that the public comment on the Del Rio Draft EA because it is a fundamentally flawed document that in no way meets the requirements of the National Environmental Policy Act. The most glaring deficiency is its description of the purpose for carrying out the proposed action. Rather than establishing national security or the reduction of illegal activity as the purpose, the Draft EA states,
“The purpose of the Proposed Action is to increase border security within USBP Del Rio Sector through the construction, operation, and maintenance of tactical infrastructure in the form of fences, roads, and supporting technological and tactical assets.” (1.2 - 4)
The “proposed action” is described as follows:
“CBP proposes to construct, operate, and maintain tactical infrastructure consisting of primary pedestrian fence; concrete retaining wall; and associated patrol and access roads, and lights along two discrete areas of the U.S./Mexico international border in the USBP Del Rio Sector, Texas” (1.3 – 5)
If the purpose and the proposed action are one and the same - the construction, operation, and maintenance of “tactical infrastructure” - then by definition no other alternatives will be able to achieve the stated purpose. “Additional USBP Agents in Lieu of Tactical Infrastructure” may in fact be highly effective at preventing unauthorized entries into the United States, but because it is “in Lieu of Tactical Infrastructure” it will never bring about the stated goal of “the construction, operation, and maintenance of tactical infrastructure.” The same holds true for all of the other “Alternatives Considered but Eliminated from Further Detailed Analysis.” In each case, the phrase “in Lieu of Tactical Infrastructure” is attached, so by definition none will align with the stated purpose. This is a clear violation of the Council on Environmental Quality’s regulations.
The private contractor hired by the Department of Homeland Security is apparently more interested in pleasing their employer than complying with NEPA. Instead of producing misleading document with a predetermined outcome, they should go back to the drawing board and produce an unbiased assessment of the environmental and cultural impacts that the border wall will have. A project of this magnitude requires a full Environmental Impact Statement rather than a far less rigorous Environmental Assessment. In either case, the final document should provide objective information rather than a sales pitch.
It is crucial that everyone with these and other concerns about the border wall submit them in writing. The Department of Homeland Security will interpret silence as a lack of interest.
Friday, January 4, 2008
California Border Wall Public Comment Period Open Until January 24
The Department of Homeland Security has announced that 44.6 miles of new border wall (or border fence, or tactical infrastructure) will be built near Calexico, California beginning in the Spring of 2008. A Draft Environmental Assessment has been released, and public comments will be accepted through January 24th, 2008.
The Draft Environmental Assessment for the El Centro Sector is available for download at http://www.borderfencenepa.com/el-centro-sector-ea/ . A paper copy may be requested as well.
You can submit a public comment on the California border wall in one of the following ways:
(a) Attendance and submission of comments at the Pubic Open House to be held on January 9 2008 at the Imperial Valley Expo, 200 East Second Street, in Imperial, California.
(b) Electronically through the web site at: http://www.borderfencenepa.com/
(c) By email to: ECcomments@BorderFenceNEPA.com
(d) By mail to: El Centro Sector Tactical Infrastructure EA, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
(e) By fax to: (757) 299-5585
When submitting comments, please include name and address, and identify comments as intended for the El Centro Sector Draft EA.
All submitted comments are supposed to become a part of the public record. To comply with the National Environmental Policy Act the Final Environmental Assessment should include responses to the public comments that are received.
It is especially important that the public comment on the El Centro Draft EA because it is a fundamentally flawed document that in no way meets the requirements of the National Environmental Policy Act. The most glaring deficiency is its description of the purpose for carrying out the proposed action. Rather than establishing national security or the reduction of illegal activity as the purpose, the Draft EA states,
“The purpose of the Proposed Action is to increase border security within USBP El Centro Sector through the construction, operation, and maintenance of tactical infrastructure in the form of fences, roads, and supporting technological and tactical assets.” (ES-1)
The “proposed action” is described as follows:
“CBP proposes to construct, operate, and maintain tactical infrastructure consisting of four discrete sections of primary pedestrian fence, lighting, and roads; one section of lighting; and access roads along the U.S. / Mexico International Border in the USBP El Centro Sector, California.” (1.3 – 3)
If the purpose and the proposed action are one and the same - the construction, operation, and maintenance of “tactical infrastructure” - then by definition no other alternatives will be able to achieve the stated purpose. “Additional USBP Agents in Lieu of Tactical Infrastructure” (2.3.1 – 6) may in fact be highly effective at preventing unauthorized entries into the United States, but because it is “in Lieu of Tactical Infrastructure” it will never bring about the stated goal of “the construction, operation, and maintenance of tactical infrastructure.” The same holds true for all of the other “Alternatives Considered but Eliminated from Further Detailed Analysis.” In each case, the phrase “in Lieu of Tactical Infrastructure” is attached, so by definition none will align with the stated purpose. This is a clear violation of the Council on Environmental Quality’s regulations.
The private contractor hired by the Department of Homeland Security is apparently more interested in pleasing their employer than complying with NEPA. Instead of producing misleading document with a predetermined outcome, they should go back to the drawing board and produce an unbiased assessment of the environmental and cultural impacts that the border wall will have. A project of this magnitude requires a full Environmental Impact Statement rather than a far less rigorous Environmental Assessment. In either case, the final document should provide objective information rather than a sales pitch.
It is crucial that everyone with these and other concerns about the border wall submit them in writing. The Department of Homeland Security will interpret silence as a lack of interest.
The Draft Environmental Assessment for the El Centro Sector is available for download at http://www.borderfencenepa.com/el-centro-sector-ea/ . A paper copy may be requested as well.
You can submit a public comment on the California border wall in one of the following ways:
(a) Attendance and submission of comments at the Pubic Open House to be held on January 9 2008 at the Imperial Valley Expo, 200 East Second Street, in Imperial, California.
(b) Electronically through the web site at: http://www.borderfencenepa.com/
(c) By email to: ECcomments@BorderFenceNEPA.com
(d) By mail to: El Centro Sector Tactical Infrastructure EA, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
(e) By fax to: (757) 299-5585
When submitting comments, please include name and address, and identify comments as intended for the El Centro Sector Draft EA.
All submitted comments are supposed to become a part of the public record. To comply with the National Environmental Policy Act the Final Environmental Assessment should include responses to the public comments that are received.
It is especially important that the public comment on the El Centro Draft EA because it is a fundamentally flawed document that in no way meets the requirements of the National Environmental Policy Act. The most glaring deficiency is its description of the purpose for carrying out the proposed action. Rather than establishing national security or the reduction of illegal activity as the purpose, the Draft EA states,
“The purpose of the Proposed Action is to increase border security within USBP El Centro Sector through the construction, operation, and maintenance of tactical infrastructure in the form of fences, roads, and supporting technological and tactical assets.” (ES-1)
The “proposed action” is described as follows:
“CBP proposes to construct, operate, and maintain tactical infrastructure consisting of four discrete sections of primary pedestrian fence, lighting, and roads; one section of lighting; and access roads along the U.S. / Mexico International Border in the USBP El Centro Sector, California.” (1.3 – 3)
If the purpose and the proposed action are one and the same - the construction, operation, and maintenance of “tactical infrastructure” - then by definition no other alternatives will be able to achieve the stated purpose. “Additional USBP Agents in Lieu of Tactical Infrastructure” (2.3.1 – 6) may in fact be highly effective at preventing unauthorized entries into the United States, but because it is “in Lieu of Tactical Infrastructure” it will never bring about the stated goal of “the construction, operation, and maintenance of tactical infrastructure.” The same holds true for all of the other “Alternatives Considered but Eliminated from Further Detailed Analysis.” In each case, the phrase “in Lieu of Tactical Infrastructure” is attached, so by definition none will align with the stated purpose. This is a clear violation of the Council on Environmental Quality’s regulations.
The private contractor hired by the Department of Homeland Security is apparently more interested in pleasing their employer than complying with NEPA. Instead of producing misleading document with a predetermined outcome, they should go back to the drawing board and produce an unbiased assessment of the environmental and cultural impacts that the border wall will have. A project of this magnitude requires a full Environmental Impact Statement rather than a far less rigorous Environmental Assessment. In either case, the final document should provide objective information rather than a sales pitch.
It is crucial that everyone with these and other concerns about the border wall submit them in writing. The Department of Homeland Security will interpret silence as a lack of interest.
Tuesday, December 4, 2007
Call for Public Comments About the Border Wall in Texas
The Department of Homeland Security (DHS) is accepting public comments about the Rio Grande Valley “Tactical Infrastructure” Draft Environmental Impact Statement (EIS). (Guide to the EIS is below.)
Submit your comments by December 31, 2007 in one of the following ways:
a) Electronically through the website at http://www.borderfencenepa.com/
b) By email to: RGVcomments@BorderFenceNEPA.com
c) By mail to: Rio Grande Valley Tactical Infrastructure EIS, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
d) By fax to: (757) 282-7697
**Be sure to include your name and address**
What is an Environmental Impact Statement?
Environmental Impact Statements (EIS) are required by the National Environmental Policy Act “for all major federal actions significantly affecting the quality of the human environment.” An EIS must fully describe the environment of a project area, consider a reasonable range of alternatives to the proposed action, and conduct a thorough impacts analysis for each alternative. The Draft EIS, by law, must determine and consider the effect of 70 miles of border walls on the human environment as well as the natural environment.
Although the border wall is an enormous project that is certain to damage the communities and natural areas of the Rio Grande Valley, the Draft EIS is a hastily-written document with glaring omissions and unfounded assertions. It is based on only 7 days of on-the-ground survey work. In addition, no biological, cultural, or engineering surveys have yet been conducted on the 14 national wildlife refuge tracts slated to get walls. In short, the Draft EIS is putting the cart before the horse in promoting the border wall as the preferred alternative before even bothering to fully study the impacts of the border wall or alternatives to the wall.
Use the following information from the “Tactical Infrastructure” Draft EIS to guide your comments:
Alternatives to the wall were not seriously considered in the Draft EIS:
· By law the Draft EIS must consider alternatives to the proposed project. However, the document rejects a number of alternatives to building the border wall, including increasing the number of Border Patrol agents or using “virtual fencing,” without any indication that they were seriously considered or evaluated.
· The Draft EIS implies that the required “No Action Alternative” means doing nothing and dismisses it out of hand. However, taking “no action” in this case means the continuation of current Border Patrol operations which have been highly successful. In fiscal year 2007 these led to a decrease in apprehensions of 34% in the Rio Grande Valley, dropping apprehensions to their lowest level in 15 years.
· The Draft EIS wrongly assumes that border walls are effective. They are not. The Congressional Research Service found that the wall in San Diego “did not have a discernible impact on the influx of unauthorized aliens coming across the border.” Indeed, fiscal year 2007 apprehensions increased by 7% in San Diego, where they have triple-layer fencing.
The wall’s effect on flood risk does not appear to have been seriously studied in the Draft EIS:
· The steel mesh used for the wall is treated in the Draft EIS as permeable to water. In a flooding event, even a standard chain link fence becomes clogged with debris and blocks the flow of water. The photographs included show a mesh that is far tighter than standard chain link, which will certainly become clogged with debris during any flooding event.
· The words “hurricane” and “tropical storm” do not appear even once in the Draft EIS, despite the fact that the Rio Grande Valley is located in a hurricane zone.
· The Draft EIS found that the border wall’s impact on water flow in the Rio Grande Basin is expected to be “negligible,” but they do not cite any hydrological studies to back up this claim. Nor do they take into account the existing problems of the flood-control levee system along the river. With no studies to model whether a border wall would channel flood waters, the Department of Homeland Security is recklessly endangering lives and property in the event of a hurricane or torrential rain.
When considering the wall’s effect on wildlife habitat and endangered species, the Draft EIS does not address crucial issues:
· The Draft EIS concludes that “the conversion of 508 acres to support tactical infrastructure is a minimal cumulative impact compared to other development” (Section 5.11). This narrow focus is misleading, as placing a barrier across a tract of wildlife habitat will have a negative impact far beyond the acreage on which the wall sits.
· The border wall will bisect many national wildlife refuge tracts; many others will have their northern border walled off. The walls will prevent wildlife dispersal to and from the river and block north-south travel corridors. This fragmentation undermines the integrity of the wildlife corridor, a series of land tracts meant to allow wildlife travel along the river. Further, refuge personnel will be unable to properly manage wildlife habitat, as fighting wildfires or controlling prescribed burns will be too dangerous behind walls.
· The border wall will deny wildlife access to the river, in many places the only water source, and the Draft EIS does not address this at all. Many tracts of the Lower Rio Grande Valley National Wildlife Refuge will be severed from the river. Such tracts were purchased and incorporated into the National Wildlife Refuge System because their river access made them valuable habitat.
· The Draft EIS claims that 150-175 acres of habitat suitable for the federally endangered ocelot and jaguarundi will be destroyed. It does not address the fact that the wall will separate populations of these endangered cats, preventing them from finding mates. Reducing their genetic diversity will increase the likelihood of their extinction. In addition, there are approximately 20 other federally threatened and endangered species in the RGV that could be adversely impacted.
· Extensive nighttime flood lighting will be associated with the wall segments, but there is no thorough analysis of the possible impacts of this on wildlife.
· There is no analysis of the possible impacts to wildlife of the roads associated with the walls.
· The proposed “wildlife migratory portals,” tiny vertical slots only a couple of inches wide, represent a purely token effort at wildlife mitigation. Animals larger than a cockroach or a starving field mouse will be unable to pass through the wall to reach water or mates.
The Draft EIS seems intent on ignoring the Migratory Bird Treaty Act:
· The Draft EIS states that construction of the border wall is planned for the Spring of 2008 and due to continue until the end of the year. However, it also contains a recommendation that “any groundbreaking construction activities should be performed before migratory birds have returned (approx. March 1) or after all young have fledged (approx. July 31) to avoid incidental take” (Section 4.9.3.2). This recommendation should be followed and no construction should occur during this time to avoid killing nesting birds.
· The Draft EIS does not address the issue of long-term habitat loss for migratory bird species. During the spring and fall migrations, millions of birds funnel through the Rio Grande Valley. Many that arrive have flown hundreds of miles across the Gulf of Mexico. They require intact habitat to rest and refuel, and without it they may be too weak to complete their journey.
The Draft EIS makes baseless claims about the wall’s affect on the RGV economy:
· Ecotourism brings more that $125 million to the Rio Grande Valley annually from 200, 000 tourists and creates 2,500 jobs in the local economy. As national wildlife refuge lands, state parks, and private reserves are lost, degraded, or rendered inaccessible and endemic and migratory species decline or are displaced because of the border wall, there will be less incentive for nature enthusiasts to visit the area. The Draft EIS makes the absurd assertion that a wall would actually bring in more visitors because they would feel safer.
· 23 million Mexican nationals visit the Valley each year, contributing $3 billion to the local economy and supporting 41,000 jobs, $560 million in wages, and $203 million in business taxes. The Draft EIS states that the wall will have “no long-term impacts” on the local economy because visitors will be able to cross at ports of entry. It completely ignores the message that a wall sends. If a store displayed a window sign that said “Mexicans Keep Out” they would not get much business from Mexican shoppers even if their doors were wide open. The border wall will present just such a message, and will certainly impact retail sales.
· There is a recognition that taking hundreds of acres of farmland out of production will have negative impacts on landowners’, and that it will be harder to access to parts of their land. There is no discussion of the impact that this will have on the ability of farms to remain viable, or on the Valley’s economy.
· The Draft EIS states that, “Minor to moderate adverse indirect impacts would be expected from the imminent dislocation of some families due to property acquisition.” For a low-income, Texas family evicted from their home by the federal government, the impact is by no means indirect or minor.
The Draft EIS ignores Environmental Justice rules:
· Although the Rio Grande Valley’s population is over 85% minority, and its border communities are some of the poorest in the nation, the Draft EIS finds that the border wall will not have a disproportionate impact on minority or low income populations. Rather than address this they manipulate statistics: “Of the proposed 70 miles of tactical infrastructure, substantially less than half is within census bureau tracts that have a higher proportion of minority or low-income residents” (Section 5. 5.11). Instead of counting the people who will be impacted, the Draft EIS counts the miles, using the many uninhabited areas to dilute, at least on paper, the wall’s impact on minority and low-income populations.
It is crucial that everyone with these and other concerns about the border wall submit them in writing. The Department of Homeland Security will interpret silence as a lack of interest. The deadline for comments is December 31, 2007.
Submit your comments by December 31, 2007 in one of the following ways:
a) Electronically through the website at http://www.borderfencenepa.com/
b) By email to: RGVcomments@BorderFenceNEPA.com
c) By mail to: Rio Grande Valley Tactical Infrastructure EIS, c/o e²M, 2751 Prosperity Avenue, Suite 200, Fairfax, Virginia 22031
d) By fax to: (757) 282-7697
**Be sure to include your name and address**
What is an Environmental Impact Statement?
Environmental Impact Statements (EIS) are required by the National Environmental Policy Act “for all major federal actions significantly affecting the quality of the human environment.” An EIS must fully describe the environment of a project area, consider a reasonable range of alternatives to the proposed action, and conduct a thorough impacts analysis for each alternative. The Draft EIS, by law, must determine and consider the effect of 70 miles of border walls on the human environment as well as the natural environment.
Although the border wall is an enormous project that is certain to damage the communities and natural areas of the Rio Grande Valley, the Draft EIS is a hastily-written document with glaring omissions and unfounded assertions. It is based on only 7 days of on-the-ground survey work. In addition, no biological, cultural, or engineering surveys have yet been conducted on the 14 national wildlife refuge tracts slated to get walls. In short, the Draft EIS is putting the cart before the horse in promoting the border wall as the preferred alternative before even bothering to fully study the impacts of the border wall or alternatives to the wall.
Use the following information from the “Tactical Infrastructure” Draft EIS to guide your comments:
Alternatives to the wall were not seriously considered in the Draft EIS:
· By law the Draft EIS must consider alternatives to the proposed project. However, the document rejects a number of alternatives to building the border wall, including increasing the number of Border Patrol agents or using “virtual fencing,” without any indication that they were seriously considered or evaluated.
· The Draft EIS implies that the required “No Action Alternative” means doing nothing and dismisses it out of hand. However, taking “no action” in this case means the continuation of current Border Patrol operations which have been highly successful. In fiscal year 2007 these led to a decrease in apprehensions of 34% in the Rio Grande Valley, dropping apprehensions to their lowest level in 15 years.
· The Draft EIS wrongly assumes that border walls are effective. They are not. The Congressional Research Service found that the wall in San Diego “did not have a discernible impact on the influx of unauthorized aliens coming across the border.” Indeed, fiscal year 2007 apprehensions increased by 7% in San Diego, where they have triple-layer fencing.
The wall’s effect on flood risk does not appear to have been seriously studied in the Draft EIS:
· The steel mesh used for the wall is treated in the Draft EIS as permeable to water. In a flooding event, even a standard chain link fence becomes clogged with debris and blocks the flow of water. The photographs included show a mesh that is far tighter than standard chain link, which will certainly become clogged with debris during any flooding event.
· The words “hurricane” and “tropical storm” do not appear even once in the Draft EIS, despite the fact that the Rio Grande Valley is located in a hurricane zone.
· The Draft EIS found that the border wall’s impact on water flow in the Rio Grande Basin is expected to be “negligible,” but they do not cite any hydrological studies to back up this claim. Nor do they take into account the existing problems of the flood-control levee system along the river. With no studies to model whether a border wall would channel flood waters, the Department of Homeland Security is recklessly endangering lives and property in the event of a hurricane or torrential rain.
When considering the wall’s effect on wildlife habitat and endangered species, the Draft EIS does not address crucial issues:
· The Draft EIS concludes that “the conversion of 508 acres to support tactical infrastructure is a minimal cumulative impact compared to other development” (Section 5.11). This narrow focus is misleading, as placing a barrier across a tract of wildlife habitat will have a negative impact far beyond the acreage on which the wall sits.
· The border wall will bisect many national wildlife refuge tracts; many others will have their northern border walled off. The walls will prevent wildlife dispersal to and from the river and block north-south travel corridors. This fragmentation undermines the integrity of the wildlife corridor, a series of land tracts meant to allow wildlife travel along the river. Further, refuge personnel will be unable to properly manage wildlife habitat, as fighting wildfires or controlling prescribed burns will be too dangerous behind walls.
· The border wall will deny wildlife access to the river, in many places the only water source, and the Draft EIS does not address this at all. Many tracts of the Lower Rio Grande Valley National Wildlife Refuge will be severed from the river. Such tracts were purchased and incorporated into the National Wildlife Refuge System because their river access made them valuable habitat.
· The Draft EIS claims that 150-175 acres of habitat suitable for the federally endangered ocelot and jaguarundi will be destroyed. It does not address the fact that the wall will separate populations of these endangered cats, preventing them from finding mates. Reducing their genetic diversity will increase the likelihood of their extinction. In addition, there are approximately 20 other federally threatened and endangered species in the RGV that could be adversely impacted.
· Extensive nighttime flood lighting will be associated with the wall segments, but there is no thorough analysis of the possible impacts of this on wildlife.
· There is no analysis of the possible impacts to wildlife of the roads associated with the walls.
· The proposed “wildlife migratory portals,” tiny vertical slots only a couple of inches wide, represent a purely token effort at wildlife mitigation. Animals larger than a cockroach or a starving field mouse will be unable to pass through the wall to reach water or mates.
The Draft EIS seems intent on ignoring the Migratory Bird Treaty Act:
· The Draft EIS states that construction of the border wall is planned for the Spring of 2008 and due to continue until the end of the year. However, it also contains a recommendation that “any groundbreaking construction activities should be performed before migratory birds have returned (approx. March 1) or after all young have fledged (approx. July 31) to avoid incidental take” (Section 4.9.3.2). This recommendation should be followed and no construction should occur during this time to avoid killing nesting birds.
· The Draft EIS does not address the issue of long-term habitat loss for migratory bird species. During the spring and fall migrations, millions of birds funnel through the Rio Grande Valley. Many that arrive have flown hundreds of miles across the Gulf of Mexico. They require intact habitat to rest and refuel, and without it they may be too weak to complete their journey.
The Draft EIS makes baseless claims about the wall’s affect on the RGV economy:
· Ecotourism brings more that $125 million to the Rio Grande Valley annually from 200, 000 tourists and creates 2,500 jobs in the local economy. As national wildlife refuge lands, state parks, and private reserves are lost, degraded, or rendered inaccessible and endemic and migratory species decline or are displaced because of the border wall, there will be less incentive for nature enthusiasts to visit the area. The Draft EIS makes the absurd assertion that a wall would actually bring in more visitors because they would feel safer.
· 23 million Mexican nationals visit the Valley each year, contributing $3 billion to the local economy and supporting 41,000 jobs, $560 million in wages, and $203 million in business taxes. The Draft EIS states that the wall will have “no long-term impacts” on the local economy because visitors will be able to cross at ports of entry. It completely ignores the message that a wall sends. If a store displayed a window sign that said “Mexicans Keep Out” they would not get much business from Mexican shoppers even if their doors were wide open. The border wall will present just such a message, and will certainly impact retail sales.
· There is a recognition that taking hundreds of acres of farmland out of production will have negative impacts on landowners’, and that it will be harder to access to parts of their land. There is no discussion of the impact that this will have on the ability of farms to remain viable, or on the Valley’s economy.
· The Draft EIS states that, “Minor to moderate adverse indirect impacts would be expected from the imminent dislocation of some families due to property acquisition.” For a low-income, Texas family evicted from their home by the federal government, the impact is by no means indirect or minor.
The Draft EIS ignores Environmental Justice rules:
· Although the Rio Grande Valley’s population is over 85% minority, and its border communities are some of the poorest in the nation, the Draft EIS finds that the border wall will not have a disproportionate impact on minority or low income populations. Rather than address this they manipulate statistics: “Of the proposed 70 miles of tactical infrastructure, substantially less than half is within census bureau tracts that have a higher proportion of minority or low-income residents” (Section 5. 5.11). Instead of counting the people who will be impacted, the Draft EIS counts the miles, using the many uninhabited areas to dilute, at least on paper, the wall’s impact on minority and low-income populations.
It is crucial that everyone with these and other concerns about the border wall submit them in writing. The Department of Homeland Security will interpret silence as a lack of interest. The deadline for comments is December 31, 2007.
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 Bryan_Winton@fws.gov (Subject line: Draft Compatibility Determinations: Border Fence)
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 Bryan_Winton@fws.gov (Subject line: Draft Compatibility Determinations: Border Fence)
Thursday, October 4, 2007
Take Action! Comment on the Environmental Impact Statement for the Rio Grande Border Wall.
Comments about the construction of border walls in Texas are being accepted as part of the Environmental Impact Statement (EIS). “Environmental Impact” includes the impact on the human environment, as well as on wildlife and the quality of water and air. It is important that we raise all of our concerns during this time.
Please write, fax or e-mail your comments in by October 15, 2007.
Here are a few ways to focus your comments:
Destruction of wildlife habitat. The lower Rio Grande Valley has already been cleared of 95% of the brush. In an area considered one of the most biologically diverse in North America, any additional destruction of brush, including clearing 508 acres for construction of the wall, will have severe consequences for wildlife. How will wildlife survive with their habitat limited by a wall? How will they get to and from the river, find food, shelter, and potential mates in habitat dissected by a wall? In some cases like Starr County, the Rio Grande is the only source of water for wildlife. Any animal that encounters miles of wall will have to travel long distances for a very basic necessity, water.
Endangered & rare species. The ocelot, jaguarundi and red-billed pigeon currently face the real possibility of extinction or extirpation. These are just a few of the endangered and rare species whose U.S. populations would certainly collapse with construction of the wall. The ability of rare species like the ocelot and jaguarundi to cross into Mexico helps keep wildlife populations healthy by maintaining a level of genetic integrity. Reduction of gene flow among or within populations will reduce the likelihood of long-term survival of these species. . A formal Section 7 Consultation under the Endangered Species Act needs to be done.
Violation of International Migratory Bird Treaty. If construction of the wall takes place during the spring, as stated in the Federal Register, many migratory and nesting birds will be affected. The clearing of brush will destroy thousands of nests, many with young birds in them. This is in direct violation of the International Migratory Bird Treaty.
Impact of construction. What will be the impacts of construction? Of roads for vehicles and heavy equipment? Of lighting and transmission lines?
Economic impact. Access will be cut off for wildlife enthusiasts interested in wildlife watching, canoeing, kayaking, and hiking along the river. Eco-tourism brings more than $125 million to the RGV annually from 200,000 eco-tourists, creating 2,500 jobs in the local economy. What are the economic impacts of limiting access to refuges, state parks, and other public and private parks and natural areas?
Community impact. A wall could mean uprooting families from their homes and demolishing or cutting off access to historical buildings and community centers. How many people will lose their homes? What buildings will be destroyed? How will property owners gain access to their land? What will the presence of a wall do to property values? How will there be public access to cemeteries and historical and archaeological sites along the river? Will there be access in case of fire or other emergencies on the other side of the fence?
Impact on agriculture. Farming is still the backbone of the economy in the Rio Grande Valley. How much agricultural land will be taken out of production by the wall? How will farmers gain access to their land? To their pumps and irrigation equipment? How will they bring farm equipment onto farmland behind a wall?
Impact on flood control. All the walled areas are in a floodplain. Has the Army Corps or DHS coordinated with FEMA? How will the wall affect the flood control levees? Will the IBWC have access to the levees and input in the construction? Will future widening of the levees result in even more habitat loss on the south side (since the wall is on the north side)?
Relations with Mexico and the rest of the world. Mexico will perceive the border wall as an insult. How will this affect the bi-national relations and cooperation? How will the border wall affect US relations with other countries and its standing in the world? What kind of example is the US setting of a free and open democratic society?
Alternatives to a physical wall. According to the National Environmental Policy Act, alternatives to projects must be explored. What are the comparative costs and impacts of alternatives to a border wall such as "virtual fencing," more boots on the ground, and comprehensive immigration reform?
Problems with the EIS. The EIS is geographically too limited. The EIS should look at total and cumulative impacts into the future. What about the impacts in other areas where a wall is proposed? How will the impacts of this initial proposed fencing change if the total amount of fencing called for by the Secure Fence Act is installed? What will be the environmental impacts of future needs of the wall such as maintenance and lighting?
Inadequate public comment period. The public comment period is less than thirty days. For a project of this magnitude, the public comment period should be extended. In addition, the website that was created to facilitate public comment has been been offline more than it has been up. This makes it difficult to access maps and other information, as well as preventing the public from using the coment feature on the site.
Submit your comments to Customs & Border Patrol by one of the following methods:
~ E-mail: RGVcomments@BorderFenceNEPA.com
~ Mail:
Rio Grande Valley Tactical Infrastructure EIS
C/O e2M
2751 Prosperity Avenue, Ste. 200
Fairfax, Virginia 22031
~ Fax: (757)282-7697
~ Electronically: www.BorderFenceNEPA.com (This website was removed on
Friday, September 28 and may or may not be up again.)
** Be sure to include you name, address and identify your comments as for the RGV Sector EIS.**
The deadline for public comments is October 15, 2007!
Please write, fax or e-mail your comments in by October 15, 2007.
Here are a few ways to focus your comments:
Destruction of wildlife habitat. The lower Rio Grande Valley has already been cleared of 95% of the brush. In an area considered one of the most biologically diverse in North America, any additional destruction of brush, including clearing 508 acres for construction of the wall, will have severe consequences for wildlife. How will wildlife survive with their habitat limited by a wall? How will they get to and from the river, find food, shelter, and potential mates in habitat dissected by a wall? In some cases like Starr County, the Rio Grande is the only source of water for wildlife. Any animal that encounters miles of wall will have to travel long distances for a very basic necessity, water.
Endangered & rare species. The ocelot, jaguarundi and red-billed pigeon currently face the real possibility of extinction or extirpation. These are just a few of the endangered and rare species whose U.S. populations would certainly collapse with construction of the wall. The ability of rare species like the ocelot and jaguarundi to cross into Mexico helps keep wildlife populations healthy by maintaining a level of genetic integrity. Reduction of gene flow among or within populations will reduce the likelihood of long-term survival of these species. . A formal Section 7 Consultation under the Endangered Species Act needs to be done.
Violation of International Migratory Bird Treaty. If construction of the wall takes place during the spring, as stated in the Federal Register, many migratory and nesting birds will be affected. The clearing of brush will destroy thousands of nests, many with young birds in them. This is in direct violation of the International Migratory Bird Treaty.
Impact of construction. What will be the impacts of construction? Of roads for vehicles and heavy equipment? Of lighting and transmission lines?
Economic impact. Access will be cut off for wildlife enthusiasts interested in wildlife watching, canoeing, kayaking, and hiking along the river. Eco-tourism brings more than $125 million to the RGV annually from 200,000 eco-tourists, creating 2,500 jobs in the local economy. What are the economic impacts of limiting access to refuges, state parks, and other public and private parks and natural areas?
Community impact. A wall could mean uprooting families from their homes and demolishing or cutting off access to historical buildings and community centers. How many people will lose their homes? What buildings will be destroyed? How will property owners gain access to their land? What will the presence of a wall do to property values? How will there be public access to cemeteries and historical and archaeological sites along the river? Will there be access in case of fire or other emergencies on the other side of the fence?
Impact on agriculture. Farming is still the backbone of the economy in the Rio Grande Valley. How much agricultural land will be taken out of production by the wall? How will farmers gain access to their land? To their pumps and irrigation equipment? How will they bring farm equipment onto farmland behind a wall?
Impact on flood control. All the walled areas are in a floodplain. Has the Army Corps or DHS coordinated with FEMA? How will the wall affect the flood control levees? Will the IBWC have access to the levees and input in the construction? Will future widening of the levees result in even more habitat loss on the south side (since the wall is on the north side)?
Relations with Mexico and the rest of the world. Mexico will perceive the border wall as an insult. How will this affect the bi-national relations and cooperation? How will the border wall affect US relations with other countries and its standing in the world? What kind of example is the US setting of a free and open democratic society?
Alternatives to a physical wall. According to the National Environmental Policy Act, alternatives to projects must be explored. What are the comparative costs and impacts of alternatives to a border wall such as "virtual fencing," more boots on the ground, and comprehensive immigration reform?
Problems with the EIS. The EIS is geographically too limited. The EIS should look at total and cumulative impacts into the future. What about the impacts in other areas where a wall is proposed? How will the impacts of this initial proposed fencing change if the total amount of fencing called for by the Secure Fence Act is installed? What will be the environmental impacts of future needs of the wall such as maintenance and lighting?
Inadequate public comment period. The public comment period is less than thirty days. For a project of this magnitude, the public comment period should be extended. In addition, the website that was created to facilitate public comment has been been offline more than it has been up. This makes it difficult to access maps and other information, as well as preventing the public from using the coment feature on the site.
Submit your comments to Customs & Border Patrol by one of the following methods:
~ E-mail: RGVcomments@BorderFenceNEPA.com
~ Mail:
Rio Grande Valley Tactical Infrastructure EIS
C/O e2M
2751 Prosperity Avenue, Ste. 200
Fairfax, Virginia 22031
~ Fax: (757)282-7697
~ Electronically: www.BorderFenceNEPA.com (This website was removed on
Friday, September 28 and may or may not be up again.)
** Be sure to include you name, address and identify your comments as for the RGV Sector EIS.**
The deadline for public comments is October 15, 2007!
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