March 20, 2008

El Paso Sector Tactical Infrastructure EA
c/o Gulf South Research Corporation
8081 GSRI Avenue
Baton Rouge, LA 70820

Re:
Draft Environmental Assessment
Construction, Operation and Maintenance of Tactical Infrastructure
U.S. Border Patrol, El Paso Sector

Dear Sir or Madam:

We appreciate this opportunity to comment on the draft environmental assessment (EA) for the construction, operation and maintenance of tactical infrastructure along the Rio Grande in the U.S. Border Patrol’s El Paso Sector. Under an agreement with the City of El Paso, the University of Texas at El Paso manages Rio Bosque Wetlands Park, which is next to the project corridor and would be affected by the proposed actions.

We offer the following comments on the draft EA. They are directed mainly at Section 3.0 in the draft EA (Affected Environment and Consequences) but apply equally to comparable portions of Section 4.0 (Cumulative Effects).

1. Impacts of Illegal Foot Traffic. In the discussion of impacts to vegetative habitat, the draft EA states (p. 3-11, lines 40-42):

Beneficial, indirect effects on the Rio Bosque Wetland Park would be expected as illegal traffic through the park is reduced or eliminated once the TI is completed.

Also, in the discussion of cumulative impacts on aesthetic resources, the draft EA states
(p.4-8, lines 19-21):

The long-term reduction of illegal traffic and the synergistic effects (e.g., trash, trails, etc.) would provide cumulative beneficial visual effects within the park.

In some areas along the U.S.-Mexico border, vegetation trampling and accumulations of trash associated with illegal foot traffic can be significant, but, in our experience, that has not been the case at Rio Bosque Wetlands Park. At the park, such impacts are minimal. We recommend either eliminating the above statements or clarifying that any beneficial effects would be minor.

2. Impacts to Wildlife. In the discussion of impacts to wildlife and aquatic resources, the draft EA states (p.3-15, lines 10-16):

The presence of a continuous canal north of the USIBWC levee, in addition to the Rio Grande, constitutes an existing impediment to the migration of terrestrial wildlife north from Mexico. Furthermore, the heavily developed and populated areas south of the Rio Grande in Mexico would also discourage wildlife migration from north to south in the project area. Therefore, the addition of a fence south of the canal would not significantly increase impediments to north-south migration of terrestrial wildlife in the area.

This paragraph does not adequately address impacts the proposed fence would have on wildlife, including at Rio Bosque Wetlands Park. The final EA needs to provide a thorough analysis of such impacts.

As indicated in Figure 2-1d, the Riverside Canal borders the eastern and southern boundaries of Rio Bosque Wetlands Park but not the western boundary adjacent to the Rio Grande levee and the proposed fence alignment. The Riverside Drain (shown as “Playa Lateral” on Figure 2-1d) is adjacent to the western boundary of the park but is dry for 8.5 months or more of the year. The reality is that today there is an open connection permitting terrestrial wildlife movement between the park and the river floodway, a connection the proposed fence would sever.

Elsewhere along the proposed fence alignment, existing obstacles to wildlife movement are far less formidable than the draft EA implies. Much of the proposed alignment would be in rural areas that are not “heavily developed and populated”. The river and the irrigation canals and drains often experience low-water periods during which they are not significant barriers to wildlife movement.

Although the draft EA discusses “north-south migration of terrestrial wildlife” across the Rio Grande, it does not address wildlife use of the river floodway as a travel corridor or wildlife movement between that corridor and adjacent areas.

With the proposed fence in place, Rio Bosque Wetlands Park and other remaining parcels of higher-quality habitat near the floodway would become even more isolated than they are today. A fence would limit the ability of native terrestrial species to move between such areas and the floodway. It would limit genetic exchange and would fragment populations that are currently connected. Over time, it would increase prospects for reduced species richness in these areas.

At Rio Bosque Wetlands Park, our management goal is to re-establish over time approximate examples of native plant and animal communities historically found in the river valley. The proposed fence would compromise our ability to achieve that goal.

3. Threatened and Endangered Species. In the discussion of impacts to threatened and endangered species, the draft EA states (p. 3-17, lines 7-8):

No Federally threatened or endangered species were observed within the project area during the biological surveys performed in 2003 and 2007. Also, no designated critical habitat for any protected species occurs within the project corridor.

The surveys were single-day, general-reconnaissance surveys performed in mid-winter (February 4, 2003 and January 17, 2007). Since both the Interior Least Tern and Southwestern Willow Flycatcher (and the Western Yellow-billed Cuckoo, a candidate for federal listing) are migratory species absent from the project area in mid-winter, failure to detect them during the surveys is not surprising. All have been observed in the project area, including at Rio Bosque Wetlands Park, during migration or in summer. We recommend replacing the sentences above with:

No designated critical habitat for any protected species occurs within the project corridor. Although no Federally listed threatened or endangered species were observed within the project area during the biological surveys performed in winter 2003 and 2007, the interior least tern, southwestern willow flycatcher and western yellow-billed cuckoo, a candidate for Federal listing, all have been observed in the project area during migration or in summer.

4. Visual Impacts. In the discussion of impacts to aesthetic and visual resources, the draft EA states (p.3-34, lines 28-30):

The USIBWC levee already interrupts the view of the Rio Grande from the U.S. side of the border. The addition of a fence along the toe levee would not detract appreciably from the current view.

For visitors walking along the west side of Rio Bosque Wetlands Park, the proposed fence would significantly alter the present view, regardless of whether the Rio Grande is visible or not. The fence would become the dominant feature on the landscape in that area. It would detract from the sense of an open, unconfined landscape visitors currently experience. The final EA should identify this alteration as a significant negative impact.

5. Access Issues. In the discussion of impacts to aesthetic and visual resources, the draft EA states (p. 3-35, lines 20-27):

A proposed pedestrian walkway along the Rio Grande through El Paso and connecting to the Rio Bosque Park could not be constructed in the floodplain if the Proposed Action Alternative is implemented, since the fence would prevent any pedestrian connection between the river and the area north of the USIBWC levee. Since the existing portions of this trail system are located north of the border fence in El Paso, this restriction should not result in a significant impact. USBP will coordinate with the city and the county to ensure that future expansion of the existing trail and the proposed fence do not conflict with each other.

Though highly modified, the Rio Grande is still a dominant feature in our regional landscape and an important part of this region’s natural heritage. There is great value in providing opportunities for the public to connect with the river and for the river to serve as a unifying feature for people living in the region. With a fence in place, those opportunities would be foregone on the U.S. side of the river between El Paso and the fence’s eastern terminus near Arroyo Diablo. The final EA should state that elimination of present and future opportunities for public access along the river in the project reach is a significant impact.

It is also worth noting that, today, some of the best opportunities to view Rio Bosque Wetlands Park are from the USIBWC levee. With a fence in place and public access along the levee effectively eliminated, those opportunities would disappear.

Thank you for the opportunity to share these comments. We hope they contribute to an improved analysis of the proposed project.

Very truly yours,

John Sproul
Program Coordinator/Manager
Rio Bosque Wetlands Park
(915) 747-8663
(915) 747-5145 fax
jsproul@utep.edu

c:
Hon. Carlos Marin, Commissioner, U.S. Section, International Boundary and Water Commission
Hon.

John Cook, Mayor, City of El Paso

Joyce Wilson, City Manager, City of El Paso

Deborah Hamlyn, Deputy City Manager, Quality of Life Services, City of El Paso

Nanette Smejkal, Director, Parks and Recreation Dept., City of El Paso