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

epresentative of a local government with jurisdiction over the area in which the effects of
an undertaking may occur is entitled to participate as a consulting party" and in 36 CFR
800.3((f)(1), under consultation, it is stated that "the [federal] agency official shall invite
any local governments or applicants that are entitled to be consulting parties under 800.2"
Pima County has jurisdiction over the proposed undertaking APE. Pima County specifically
requested that the GSA actively and comprehensively include the Pima County Office of
Cultural Resources and Historic Preservation (OCRHP) in the planning, review, evaluation of
significance and assessment of effects regarding historic properties. This has not been
done. The October 27, 2010, consultation letter from GSA to SHPO regarding these very
topics does not include Pima County as a copied recipient. This deficiency must be
remedied through the inclusion of Pima County OCRHP as a full and active participant in
the consultation process as provided for under 36 CFR 800. I also note that the
International Sonoran Desert Alliance is not copied on this correspondence, another
deficiency in the consultation process.
Chapter 4.6 Air Quality
The preferred alternative ignores the effects on air quality caused by an 80-mile round trip
commute from Ajo to Lukeville by automobile on air quality. The effects on air quality
may be minimal or lower compared to longer distance commutes from Tucson, Casa
Grande, and Phoenix, however no analysis has been provided.
Chapter 4.8 Visual Resources
The preferred alternative does not adequately address our previous comments requesting
that the architectural building design be compatible with, and enhance the appearance of
the adjacent historical district. The designs are generic, mass-produced structures without
any attempt to provide enhancements or design features endemic to the culture and
history of the local area.
The October 27, 2010 letter from Jane Lehman, GSA Regional Historic Preservation
Officer to Robert Frankenberger, Arizona Office of Historic Preservation, Arizona State
Parks (included in the Appendix), identifies the nearby Ajo Townsite Historic District as
inspired by the City Beautiful movement. This is an important movement in the history of
the Planning profession dating from the turn of the last century. The premise of the
movement is that urban design is a strong influence on the health and well-being of the
residents of a community. The Draft EA de-emphasizes the importance of the Historic
District to the community and ignores the effects of this project on local urban design.
The architectural and site designs should be revised to be more sensitive to the local area
and to the Ajo Vision Plan referenced in my May 10, 2010 letter to Michael Dawson, with
EcoPlan Associates (included in the EA Appendix). The final product should seek to
enhance and add improvements to the community.
Chapter 4.9 Water Resources
Water quality issues have been ignored. Stating that an evaluation will need to be done to
determine if the project is 404 compliant is not sufficient. If the project is found to be 404
compliant, additional requirements will be triggered. Determination of 404 compliance
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