Fish and Wildlife Service's Draft Letter on Border Wall's Environmental Impacts

In this draft September 2017 letter, U.S. Fish and Wildlife Service career officials wanted to warn U.S. Customs and Border Protection officials about several ways in which President Trump's proposed wall with Mexico could harm wildlife along the Texas border.

Document 9 Attachment

United States Department of the Interior
Post Office Box 1306
Albuquerque, New Mexico 87103
In Reply Refer To:
FWS/R2/NWRS/Coastal TX/066633

Mr. Paul Enriquez
Real Estate and Environmental Branch Chief
U.S. Customs and Border Protection
1300 Pennsylvania Avenue NW
Washington, DC 20229
Dear Mr. Enriquez:
Thank you for your letter dated August 25, 2017, regarding U.S. Customs and Border Protectionas (CBP)
proposed border infrastructure in South Texas which includes the installation of 35 gates in existing
border fence gaps, 32 miles of bollard wall, and 28 miles of levee wall. The U.S. Fish and Wildlife
Service (Service) reviewed your letter and is providing our initial concerns related to Federally listed
species, other Federal trust resources, and Santa Ana and Lower Rio Grande Valley National Wildlife
Refuges (NWR). Once there is a proposed action, that is spatially explicit, we can provide a formal
response and coordination under the National Environmental Policy Act, National Wildlife Refuge
System (Refuge System) Improvement Act, Migratory Bird Treaty Act, and Endangered Species Act.
Over the past several years, there has been a substantial increase in coordination between the Service,
CBP, and the U.S. Border Patrol Rio Grande Valley Sector along the Texas border. The Service
appreciates the excellent communication and information sharing that has occurred and looks forward to
maintaining this relationship into the future.
The Refuge System lands in the Lower Rio Grande Valley are considered to be one of the most biodiverse
in the continental United States. The Service supports CBP addressing direct and indirect impacts of the
proposed border activities on Federally listed species and other Federal trust resources in the project area.
In general, concerns are similar to those discussed during initial border wall/fence construction in 2008.
The Service will continue to work with CBP on the proposed activities, with a focus on ensuring impacts
to Santa Ana and Lower Rio Grande Valley NWRs and its ecotourism-based economy are analyzed and
minimized, to the extent possible.
In response to the possible components of the proposed action identified in your letter, the Serviceas
informal comments are as follows:
Levee and bollard walls
In general, the Service recommends considering technology, additional border patrol agents and other
mechanisms, when possible, instead of installation of levee or bollard walls.

Mr. Paul Enriquez


The Service understands that 10.2 miles of border wall will be constructed on Santa Ana and Lower Rio
Grande Valley NWRs in Hidalgo County, Texas. The Service does not currently have information on
specific alignments on Lower Rio Grande Valley NWR in Starr County. Currently, there are 34 miles of
existing levee wall in Hidalgo County; the proposed 28 mile addition would result in 62 miles of
impermeable barrier, precluding access to habitats by the Federally listed endangered ocelot and
jaguarundi, along with other terrestrial species. Reduction of habitat connectivity in portions of the
existing wildlife corridor will affect ocelot and jaguarundi movement, impact access to traditional water
sources, and reduce potential for gene flow. The Service recommends wildlife openings to allow ocelots,
jaguarundis and other wildlife to move through the wall to maintain habitat connectivity.
In Hidalgo County, Santa Ana NWR will be bisected, with substantial acreage south of the proposed wall
and less acreage north of the wall. Any acres north of the wall that do not have habitat corridors will
represent a direct loss of habitat particularly for ocelots and jaguarundis on refuge land in Texas. The
Service requests CBP document and assess these impacts for Starr County when the border wall
alignments are determined.
The Lower Rio Grande Valley is a flood-prone area. The Service is concerned the levee wall in Hidalgo
County could be subject to catastrophic natural flood events, leaving terrestrial wildlife trapped behind
the levee wall to drown or starve. This project will likely cause widespread mortality for terrestrial
organisms during catastrophic flood events. The Service recommends an assessment of escape routes and
consideration of constructing elevated berms south of the levee to allow terrestrial animals to retreat from
rising waters during flooding events, as well as leaving the gates open during those events.
The Santa Ana and Lower Rio Grande Valley NWRs experience numerous wildfires each year. Fighting
wildfire is dangerous, particularly if escape routes are limited due to a border wall. Natural resource
protection may be impacted due to public safety and challenges of fighting wildfires south of a border
Direct Mortality
The Service requests best management practices, such as capping hollow bollard/posts, during
construction to prevent entrapment of wildlife species during placement of vertical posts/bollards.
Socio-economic & Visitor Impacts
The Service is specifically concerned with potential tourism and visitor impacts. Ongoing efforts by the
Service, the state of Texas, private landowners, and non-profit organizations have helped create a wildlife
corridor linking numerous isolated habitat fragments in the Lower Rio Grande Valley. These efforts have
helped produce habitats that are harboring unique species of plants and animals, making the area a
destination for ecotourists.
The economics of Lower Rio Grande Valley wildlife and habitat diversity are important to the
international border region, as over 150,000 tourists contribute approximately $10.8 million annually to
the regional economy. The Santa Ana NWR is the most accessible public land for residents of Hidalgo
County and approximately 70 percent of visitors come from outside of the local area. Visitors
participating in outdoor recreational activities economically benefit the local community. The Service
recommends a socio-economic analysis of the proposed wall.
Construction of the border wall, as proposed, will likely affect visitation and the quality of visitor
experience. Construction of the border wall along the levee will separate the Santa Ana NWR visitor

Mr. Paul Enriquez


center and all administrative facilities (equipment storage, residences, parking lots, etc.) from the rest of
the refuge (99 percent of refuge lands). The proposal could result in visitors entering and exiting Santa
Ana NWR through a large gate, similar to going through a security checkpoint. This could result in a
reduction in visitation due to a perceived unsafe and unwelcoming atmosphere.
Enforcement Zones
Construction of a 150-foot enforcement zone will directly remove habitat. The enforcement zone will
also create barriers and restrict wildlife movement, especially for species such as ocelots, which require
dense brush to travel through. The Service recommends minimizing this zone, as operations allow,
especially in and near thick thornscrub and walking trails. We also recommend calculating the direct
habitat loss of the 150-foot enforcement zone based on a vegetation and endangered species survey. The
proposed cleared enforcement zone in Hidalgo County will directly remove approximately 170 acres of
habitat from Lower Rio Grande Valley and Santa Ana NWRs reducing the ability to meet refuge
purposes. In Hidalgo County, Refuge System lands will have approximately 7,800 acres south of the
proposed wall and 2,400 acres north of the wall. The 2,400 acres represent a direct loss of habitat for
ocelots and jaguarundis on Refuge System lands in Texas.
Increased lighting at night, along the wall, will likely have negative impacts on ocelot, jaguarundi and
other nocturnal species by making them more susceptible to predation. The Service recommends down
shielding lights to focus away from thornscrub habitat and shining lights only within the enforcement
zone. The Service recommends CBP continue to analyze the effects of lighting to nocturnal wildlife and
work with the Service to minimize impacts.
All Weather Roads
The Service recommends the width of all roads created or maintained by CBP be measured and recorded
using Geographic Information System (GPS) coordinates and integrated into the CBP GPS database. The
Service suggests maintenance actions not increase the width of the roadbed or the amount of disturbed
area beyond the roadbed. The all-weather road within the enforcement zone is capable of high speed use,
causing concern for public safety and increased wildlife mortality. The Service requests coordination to
address speeding issues.
We appreciate the opportunity to provide informal comments and look forward to future opportunities to
discuss the proposed project. Please feel free to contact me at 505-248-6282 if I can be of further

Regional Director

Mr. Paul Enriquez
cc: Field Supervisor, Texas Coastal Ecological Services Field Office, Houston, Texas
Refuge Manager, South Texas National Wildlife Refuge Complex, Alamo, Texas
Inter-agency Borderlands Coordinator, Department of Interior Washington, D.C.