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

should be done at the EA stage so that any additional impacts to water quality and
wastewater treatment can be evaluated and the mitigation of those impacts should be
presented in the EA.
Chapter 5 Cumulative Impacts
The assertion that cumulative impacts from implementation of the preferred alternative are
expected to be negligible cannot be substantiated based on this chapter and, as noted
above, the inadequacies of this analysis and document. Construction impacts are direct
and indirect, and factor into the cumulative impacts. Other direct and indirect impacts are
not addressed one by one as the basis for this concluding statement regarding cumulative
impacts.
No mention has been made of the impacts to the Organ Pipe National Monument. CBP
personnel will travel 80 miles daily through the monument. Officials from the Monument
were not part of the Agency transmittal and should have had the opportunity to comment.
Note that it is the Pima County Office of Cultural Resources and Historic Preservation that
is administering the Ajo Historic Depot Restoration, in collaboration with the International
Sonoran Desert Alliance, not the Pima County Department of Transportation.
Chapter 6.1.1 Agency Responses (Pages 37 and 38)
The GSA responses are limited and incomplete, as addressed above.
Pima County was not included in the Section 106 consultation as we requested.
The responses to the Pima County Cultural Resources Department's comments are
inaccurate because a determination of no historic properties present cannot be made
without the results of an identification inventory survey and the statement that Executive
Order (EO) 13006 is not applicable to this project indicates a misunderstanding of the
intent of this EA. It is not that there is no acquisition with the historic district, it is a
question of why has the acquisition of properties within the historic district not been given
first consideration as stated in EO 13006.
Page 40. Table 5
No direct responses are provided to these citizens' comments. Why?
Page 41. Table 6
The results of the alternative evaluations are questionable given the inadequacies of the
Draft EA. These results may well be rendered inaccurate when adequate analysis is
conducted, as it should be for this Draft EA to meet a reasonable standard of adequacy.
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