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

In this final Oct. 13, 2017 letter to U.S. Customs and Border Protection, U.S. Fish and Wildlife officials deleted several concerns the agency's career experts had raised about the environmental impacts of a proposed border wall with Mexico.

Document 10

U.S.
FISH WILDLIFE
SERVICE.

United States Department of the Interior

FISH AND WILDLIFE SERVICE

Post Of?ce Box 1306
Albuquerque, New Mexico 87103

In Reply Refer To:
WRS/Coastal

OCT 1 3 2017

Mr. Paul Enriquez

Real Estate and Environmental Branch Chief
US. Customs and Border Protection

1300 Avenue NW
Washington, DC 20229

Dear Mr. Enriquez:

Thank you for your letter dated August 25, 2017, regarding US. Customs and Border
Protection?s (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 US. 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 (N WR). Once there is a Spatially explicit
proposed action, assuming no waiver is issued by Department of Homeland Security, we can
provide a formal response and coordination under applicable Federal laws, including 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. In general, our 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 are analyzed and minimized, to the extent possible.

Mr. Paul Enriquez 3

Soda-economic Visitor Impacts

The Service is speci?cally concerned with potential tourism and visitor impacts on the affected
NWRS. Ongoing efforts by the Service, the state of Texas, private landowners, and non?pro?t
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 bene?t the local
community.

Construction of the border wall, as proposed, will likely affect visitation and the quality of visitor
experience to the affected NWRS. Construction of the border wall along the levee will separate
the Santa Ana NWR visitor 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, which in turn could impact local economies.

Enforcement Zones

Construction of a ISO-foot enforcement zone will directly remove habitat used by threatened
and/or endangered species and other wildlife in the area. 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 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 and impacting the visitor experience.
The Service recommends leaving vegetated areas near entrances and exits to public use areas to
mitigate the potential impacts to the visiting public and quality of their experience.

Lighting

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 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

Mr. Paul Enriquez 4

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, especially near
high visitor use areas.

The Service?s comments in this letter are based upon general information we have been given to
date. The Service may change these comments and opinions depending on more speci?c
information regarding the border wall that we expect will be provided by CBP in the future. We
appreciate the opportunity to provide informal comments and look forward to continued
coordination on the proposed project. Please feel free to contact me at 505-248-6282 if I can be

of further assistance.
Sincerely,

Regional Director

Mr. Paul Enriquez

cc: Field Supervisor, Texas Coastal Ecological Services Field Of?ce, Houston, Texas
Refuge Manager, South Texas National Wildlife Refuge Complex, Alamo, Texas

Inter?agency Borderlands Coordinator, Department of Interior Washington, DC.
EA-ARD