US Customs and Border Protection Ajo Housing Development ... - GSA

For simplicity, specific comments are itemized according to the appropriate Chapters as
presented in the Draft Environmental Assessment (EA).
Chapter 1.3 Background and Overview
One of the issues raised in this section of the Draft EA is the need to reduce the commute
of personnel. Housing in Lukeville and Why would be more appropriate if one of the major
issues is to reduce or eliminate personnel commuting distances. However, the
inadequacies or shortage of housing in these two locations were not fully described in the
EA, nor were housing studies provided to corroborate these statements.
Page 4 states that "numerous contractors" currently in the area working on the border
fence construction are contributing to the lack. of available housing. This is a temporary
condition, as the fence construction will be completed in the near future. Once the fence
construction ends, housing will presumably become available. The transitory nature of this
situation is not adequately addressed in the Draft EA.
Chapter 2.1 Purpose of the Project
The project, as proposed, is inadequate to provide for the estimated housing needs of 410
personnel with a proposed initial 22 housing units in phase I and potential for 56 units total
in the future. According to the EA, the private housing in Lukeville, Why and Ajo has been
deemed inadequate or substandard by the EA, and therefore unable to meet the housing
need to address the problem of personnel retention and commuting distances. However,
under Chapter 4.3 Social and Economic Resources, this same private housing is listed as
an alternative for CBP personnel to address the obvious housing gap. These contradictory
statements bring into question the scope and purpose of this project, including the
assessment behind the preferred alternative.
Chapter 2.2 Need for the Project
The Draft EA explains that the expansion of the border stations and lack of available
housing units for the additional employees establishes the need for additional housing.
However, the proposed number of units will not be sufficient to resolve the housing
shortage. There is a statement on page 5 that the project is not intended " ...to satisfy the
needs of the project 41 O-personnel staffing level." The evaluation of existing and projected
housing needs is incomplete, since the narrative lists only the percentages of employees
who indicate they would use local housing, rather than the estimated number of needed
housing units for the number of projected employees (410).
Additionally, because of the ambiguity in the number of personnel who will use the units, it
is difficult to assess probable impacts, such as whether the total Vehicle Miles Traveled
(VMT) will be reduced (as implied in the narrative) from current levels, without knowing the
number of employees who will no longer make long distance commutes from places such
as metro Phoenix and Tucson. An assumption can be made that, since only 30 percent of
CBP employees will choose to use local housing, there will continue to be a significant
number of employees traveling long distances to work.
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