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

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Another issue that has not received sufficient attention is the use of sustainable development techniques used in construction and site development. Sustainable development has major impacts on all areas required to be assessed by NEPA, including biological, air and water quality, visual, floodplain, hazardous material, etc. This should be addressed. Regional concerns such as water conservation are ignored. It does not appear that alternative energy sources, such as solar power, will be part of the project. The narrative states that construction will comply with the Federal Leadership in High Performance and Sustainable Buildings Memorandum of Understanding (MOU) (Page 13). However it does not state how that will be accomplished. Chapter 4.1 Ownership, Jurisdiction, and Land Use The land use is compatible with allowed Pima County Zoning Code uses. We strongly recommend that the Customs and Border Patrol consult with Pima County Development Services to determine the applicability of a governmental exemption from the Zoning Code. Should exemptions be executed, we would request that the Customs and Border Patrol abide by the spirit and intent of exempted requirements as the project is brought to fruition Chapter 4.2 Environmental Justice/4.3 Social and Economic Resources According to the EA, Ajo has a high level of minority residents living below the poverty line at 46.5 percent. The effect of additional CBP personnel in the community may be to mask the visibility of problems related to low income levels. Statements on page 17 indicate that the percentage of the population below the poverty line is expected to slightly drop when CBP personnel move into new housing. The narrative presents this as a positive benefit. However, the impacts would probably be mixed. The number of persons below the poverty line who currently live in the area will remain the same. Their income levels will not be affected. The reduction in percentage of residents will drop only because the average income levels of the CBP personnel will be substantially above those of current residents. One aspect not addressed in the EA is the possible impact to access to assistance programs, as well as eligibility for community improvement grants, housing, and food assistance. Many assistance funding programs are based on percentages of persons below the poverty level. This impact on the community should be evaluated in the EA, focusing on the possibility of loss or reduction in program or assistance funding. Page 19 states that residents in eight existing units will be displaced by the project. Assistance will be available for relocation funds. However, the EA makes the point that adequate housing is limited in the Ajo area, which begs the question whether these displaced persons will be able to find housing in Ajo. The residents who are affected may be long-term residents with family ties in the area. The entire proposal should be reexamined, possibly to increase the number of units to provide housing for both the CBP personnel and for displaced residents. Housing should be spread and dispersed throughout Ajo and the subject area to prevent both the appearance of, and actual separation of, CBP personnel; and to more fully integrate the new residents into the fabric of the community. Additional funding should be sought to address expected impacts. 3
Chapter 4.5 Cultural Resources There is a clear misunderstanding of the concept of the Area of Potential Effects (APE) and the range of potential effects regarding historic properties. These are serious flaws in the Draft EA. To state that "GSA has determined that this undertaking will not have an effect on the Ajo Townsite Historic District, therefore is not included within the APE" indicates a lack of comprehension regarding APE and effect considerations under 36 CFR 800. Federal regulations at 36 CFR 800.16 state "Area of potential effects means the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist. The area of potential effects is influenced by the scale and nature of an undertaking and may be different for different kinds of effects caused by the undertaking." Federal regulations at 36 CFR 800.5(a)(2)(v) state that adverse effects on historic properties include the "introduction of visual, atmospheric, or audible elements that diminish the integrity of the property's significant historic features, and regulations in 36 CFR 800.5(a)(2)(iv) state that adverse effects on historic properties include "change of the character of the property's use or physical features within the property's setting that contribute to its historic significance." This APE in the Draft EA is the preferred alternative purchase area. That, however, is only a direct effect of the proposed undertaking. It is well established that the APE regarding indirect effects for many undertakings is much larger than the direct effect (or footprint) of a project when issues such as visual, audible, and atmospheric effects are considered. In the case of the preferred alternative, the visual, audible, and atmospheric effects of the proposed undertaking must be considered in the National Register listed Ajo Townsite, including the components of the listed property to the southeast of the proposed undertaking. In fact, the preferred alternative is essentially enclosed by the listed Ajo Townsite to its northeast, east and southeast. The Draft EA and the consultation with the State Historic Preservation Office (SHPO) completely fails to address the scale of the APE regarding indirect effects of the proposed undertaking and the nature of the potential effects of the undertaking on the listed Ajo Townsite, an omission that must be addressed to adequately comply with 36 CFR 800. Another inadequacy of the Draft EA and the GSA consultation with the SHPO is that there has been insufficient effort made to identify historic properties within the direct impact APE. It is clearly stated in the two documents that no historic properties are present within this APE. However, this statement is made in the absence of a historic properties inventory identification survey. In the absence of such an identification survey, how can anyone know what historic properties may be present in this APE? Given the many thousands of years of Native American occupation in the area, it is entirely possible that Native American archaeological remains are present. If they are present, this may well be an issue of concern to the consulting Native American Tribes. In addition, the proximity to the listed Ajo Townsite and many mines may result in early 20th Century or 19th Century features in this APE. The lack of an adequate historic properties identification effort must be remedied through the conduct of an inventory survey and a report documenting the results. Until this identification effort is concluded, any finding of "no historic properties affected" is an unsupported and unfounded assertion. There is also a misunderstanding of the role and involvement of local governments in the consultation process under 36 CFR 800. In 36 CFR 800.2(c)(3) it is stated that "a 4
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Final Environmental Assessment for
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Chapter 7 Conclusion...............
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SR 85 State Route 85 SWPPP Storm Wa
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^ Du "10 nt W'1IJtIl o G !lUll I ON
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The need to staff the POE for 24-ho
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The CBP Housing Program Feasibility
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Lukeville, Why, and Ajo areas. Thre
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3.1.3 Lukeville Alternative 3 Lukev
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Perro De Nieve S. Sahuaro St. Monte
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3.2.2 No Action Alternative Under t
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environmental justice concerns. Dat
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The median household income of Ajo
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Gila woodpeckers, ravens, roadrunne
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Species Habitat Potential Occurrenc
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Section 106 of the NHPA requires fe
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Federally funded projects are subje
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ecognizes that major modifications
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No Action Alternative The No Action
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Chapter 5 Cumulative Impacts Cumula
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Arizona Game and Fish Department Th
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GSA response: Discussed in Chapter
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Approximately 60 people attended th
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Comment 7. Involve local developers
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Comment 16. What is the cumulative
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Comment 31. Notes apparent contradi
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Comment 45. There is a clear misund
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Chapter 7 Conclusion 7.1 Summary of
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Chapter 8 Project Preparers and Con
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Parkhurst, Janet H. 2001. Ajo: A Mo
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Appendix A USFWS Threatened, Endang
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Appendix A. USFWS threatened, endan
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Appendix B Scoping Letter and Maili
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On General Services Administration
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Project Vicinity U.S. Customs and B
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.' GSA Pacific Rim Region October
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cc: Kirsten Brinker-Kulis Advisory
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Arizona's On-line Environmental Rev
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Arizona's On~line Environmental Rev
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GUIDELINES FOR HANDLING SONORAN DES
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Mr, Mr. Michael ODawson .....son Ae
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G_a' US Mr. Michael Oewson Dawson R
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U.S. CUSTOMS & BORDER PROTECTION NO
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Page 93 and 94: Dear Representative Grijalva: Thank
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Page 97 and 98: U.S. GENERAL SERVICES ADMINISTRATIO
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Page 105 and 106: Appendix F Public Comments
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Page 119 and 120: Page 10f2 Mike Dawson From: Sent: T
Page 121 and 122: ·. From: osmahn.kadri@gsa.gov [mai
Page 123 and 124: ---------- Forwarded message ------
Page 125 and 126: Page 1 of 1 Mike Dawson From: osmah
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Page 133 and 134: Page 7 of7 the property which can p
Page 135 and 136: oPP011unity there is to tighten not
Page 137 and 138: INTERNATIONAL SONORAN DESERT ALLIAN
Page 139 and 140: Mr. Osmahn Kadri Re: U.S. General S
Page 141: The Draft EA does not contain any c
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