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

Comment
31. Notes apparent contradictory
statements with regard to housing
resources when statements in
Section 2.1 are compared with
Section 4.3.
32. The proposed number of units will not
be sufficient to resolve the housing
shortage. The Draft EA states that the
project is not intended to satisfy the
needs of the projected 410-person
staffing level.
33. It is difficult to assess probable
impacts, such as the total vehicle miles
traveled, due to ambiguity in the
number of personnel who will use the
units compared with the estimated
number of needed housing units for the
number of projected employees.
34. The Draft EA doesn’t provide cost
comparisons to substantiate the
statement that the government would
have to invest large sums of money to
bring the existing housing stock up to
CBP standards.
35. Thirteen criteria were used to evaluate
each alternative, yet few are discussed
in the Draft EA.
36. The comment suggests that a highincome
enclave would be created at
55 Sahuaro St. and that a workplace
culture different from other residents
would occur.
37. The alternatives analysis should
consider the amenities of Sonoita,
Sonora, and Rocky Point, Mexico,
when evaluating the merits of
developing housing in Lukeville.
Response
Section 2.1 of the Draft EA states that the potential 56 units are
not intended to meet all housing demands by the CBP (page 5,
second paragraph), but rather, the immediate needs. The reference
in Section 4.3 was noting that broader, long-term needs for
housing would not be met by the 55 Sahuaro St. parcel and that
the private sector/local real estate market would continue to be an
option for CBP personnel.
Refer to response to Comment 30.
The number of housing units would range from 22 to 56 should
future funding be secured beyond the initial 22 units. The number
of personnel would be commensurate with those unit numbers.
A quantitative analysis of vehicle miles traveled resulting from
project implementation is not warranted because the project would
result in fewer miles traveled by CBP personnel. The impact on
vehicle miles traveled from the project would be beneficial.
The reference to investing money to bring existing housing up to
CBP standards will be replaced with the following statement:
Based on the Feasibility Study, the CBP determined early in the
analysis that the acquisition and use of scattered parcels for the
development of government housing would not be practical and
would result in a notable delay in the provision of government
housing.
Though the Feasibility Study provides comprehensive information
on the alternative rankings by each criterion, the Draft EA focuses
on the relevant results, providing a summary of the particular
criteria or criterion for which the alternative was eliminated from
consideration.
The Draft EA does not state, and the CBP has no reason to
believe, that residents of the proposed housing would have income
levels “much higher” than the Ajo average. The employees who
choose to live in the proposed housing would be expected to
include entry-level personnel with lower incomes. The proposed
housing would not be set apart from nearby residential units.
No walls or gates would be constructed around the development.
CBP personnel have been a part of the Ajo community for years
and are integrated through daily activities—shopping, schools,
recreation, and community events. We do not believe further
analysis of this issue is warranted.
Though U.S. Department of Homeland Security and
CBP personnel are not prohibited from traveling into Mexico as
off-duty citizens, given the nature of the work conducted by
CBP personnel, there are safety concerns with such visits. The
U.S. Department of Homeland Security and the CBP are
prohibited by law from residing outside of the United States.
Environmental Assessment 44 Ajo Housing Development Project