June 26, 2019

Paul Enriquez, Director
Border Wall Program Management Office
U.S. Customs and Border Protection
U.S. Border Patrol Headquarters
1300 Pennsylvania Ave. 6.5E Mail Stop 1039
Washington, DC 20229-1100

Re: Pima and Cochise Counties, Arizona Border Infrastructure Project

Dear Mr. Enriquez:

The Coalition to Protect America’s National Parks is submitting comments regarding the above named proposed project’s May 6, 2019 Scoping Notice. With more than 1700 members, the Coalition consists mainly of retired NPS officials, including: former NPS directors; associate and regional directors; superintendents; rangers, and specialists with expertise in subject matter areas such as the NPS Organic Act, National Environmental Policy Act (“NEPA”) compliance; historic, natural, and cultural resource preservation; and natural resource management and science. These NPS experts, all of whom serve on a volunteer basis, formed the Coalition in 2003 to advance the preservation and protection of America’s national park areas and the central mission of NPS—the “conservation mandate” of the NPS Organic Act. See Coal. to Protect Am. Nat’l Parks, About the Coalition, https://protectnps.org/membership-2/who-we-are/.  The Coalition collectively represents nearly 40,000 years of professional stewardship experience in protecting America’s most precious and important natural and historic places. See id.

According to CBP’s Scoping Notice, approximately 63 miles of existing border barriers would be upgraded with vehicle and pedestrian barriers consisting of a bollard wall. The proposed design of the new bollard wall includes 18-30 foot, concrete-filled steel bollards that are approximately 6” x 6” in diameter. The proposed project also includes improvement or construction of roads, the installation of lighting and the installation of other detection technology. The proposed project would impact Organ Pipe Cactus National Monument (AZ); Organ Mountains-Desert Peaks National Monument (NM); Coronado National Monument (AZ) as well as several National Wildlife Refuges.

The Coalition has long supported NPS in its efforts to uphold its “conservation mandate,” and has worked with the agency to decry any attempt to recast that mandate as one where non-conservation interests are given priority over conservation goals. While we generally support efforts to increase border security, we offer the following comments on the proposed project:

  1. The Scoping Notice does not include the “purpose and need” for the proposed project. We urge CBP, in its forthcoming NEPA document, to provide documentation of the existing barriers’ effectiveness in controlling illegal vehicle and pedestrian border. Without specific data regarding existing conditions supporting the project’s purpose and need, the public cannot make meaningful comments and decision-makers cannot make informed decisions on project alternatives and resulting impacts.
  2. The existing barrier at Organ Pipe Cactus National Monument and Coronado National Monument was constructed between 2004–2006. According to the NPS 2003 Environmental Assessment (EA) (1) for that project, the barrier was to be “wildlife friendly” and include mitigation measures to protect threatened and endangered species. We call your attention to the NPS EA and hereby incorporate it into our scoping comments as background.
  3. In the upcoming CBP NEPA document, we recommend the following impact topics be analyzed (as in the 2003 NPS EA): Floodplains; Soils; Vegetation: Wildlife and Wildlife Habitat; Threatened, Endangered, and Special Concern Species; Visitor Experience; Human Health and Safety; Park Management and Operations; and Adjacent Land. The NPS EA dismissed from further consideration impacts to Wilderness due to the vehicle barrier’s relatively low height and porous structural design, which significantly reduced the visibility of the barrier from a distance. However, we request that CBP evaluate potential impacts to Wilderness character in its analysis. In contrast to the existing vehicle barrier, the sheer scale of the proposed 18-30 foot tall border wall makes it very likely to adversely impact visual resources associated with Wilderness character. Lastly, it is unclear in the proposal to what extent additional lighting would be included in the project. Any substantial increase in lighting along the 63 miles of proposed border wall could adversely impact “night skies” (natural darkness), a valued resource in the national parks in southern Arizona (2). We therefore request that Night Sky impacts be analyzed.
  4. Our efforts to obtain information on the effectiveness of the existing barrier and its impacts (both beneficial and adverse) have been unsuccessful regarding monitoring of pedestrian and vehicle impacts, effects on wildlife, vegetation, cultural resources, visitor experience and enforcement. This data should be included in CBP’s analysis of the No Action Alternative and compared with a range of reasonable alternatives in its NEPA.
  5. The Scoping Notice does not provide any details about the proposed barrier regarding location of existing and proposed roads, lighting and detection devices. In addition, the Notice does not address mitigation for wildlife crossings, flooding and other resource impacts. Without such detail, it is difficult for the public to provide more meaningful comments. We urge that CBP re-issue the Scoping Notice with additional details or, at a minimum, thoroughly disclose design and construction information in the forthcoming NEPA document.
  6. In the Scoping Notice, CBP has not indicated what level of NEPA analysis it would prepare for its border wall. Given the much larger scale and impenetrability of the proposed border wall, relative to the existing vehicle barrier, adverse impacts of the wall are likely to be significantly greater. We therefore recommend that CBP prepare an environmental impact statement (EIS) to fully assess such impacts and to propose/analyze a suite of mitigation measures to reduce those impacts. If CBP chooses to prepare an EA, it should include a suite of appropriate mitigation measures and analysis of their effectiveness to reduce adverse impacts below the “significant” level. In contrast, it would be completely inappropriate for CBP to prepare only a categorical exclusion (CE) for this project based on the premise that the border wall is simply “replacing existing structures.” As stated previously, the scale of the proposed wall is significantly greater than that of the existing vehicle barrier; and therefore potential adverse impacts are also much greater.
  7. The Scoping Notice asks the public and agencies to identify any permits and approvals needed for the project. Consideration should be given for any NPS permits and approvals, including its own environmental assessment or including NPS as a joint lead on CBP’s NEPA document. NPS permits and approvals may include special use permits and right-of-way approvals. Documentation of consultation with NPS and other effected land management agencies and Tribes should be included in the forthcoming NEPA document.

We appreciate the opportunity to comment. Please include our organization in any future notices.





Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks
201 I Street, NE #805, Washington, DC 20002

cc: Chip Jenkins, Acting Intermountain Regional Director, NPS
Scott Stonum, Superintendent, Organ Pipe National Monument, NPS
Allen Ethridge, Superintendent, Southern Arizona Parks, NPS

(1) https://www.nps.gov/orpi/learn/management/upload/EAVehBar.pdf

(2) https://www.nps.gov/orpi/learn/nature/humans-and-the-night-sky.htm