Act Now: Tell CBP to Prioritize Wildlife over the Border Wall
2/8 Update: The feedback window for CBP is now closed. Click here to see what we asked of CBP in our comment letter.
Border wall construction has destroyed critical landscapes and wildlife migration corridors for decades. 84 environmental and other federal laws and statutes were waived in recent years to accelerate border construction, giving way to severed terrestrial corridors for wildlife, newly graded roads, light and noise pollution, water pumping from underground aquifers and springs, and more. Incredible damage has been done — but now we have a chance to start border restoration.
Will you tell U.S. Customs and Border Protection to create and improve wildlife crossings, revegetate disturbed landscapes, decommission border roads, and leave border lights unilluminated?
QUICK RESOURCES TO HELP YOU ACT NOW:
Resources from CBP:
Resources from Sky Island Alliance & Partner Organizations:
Have a bit more time? Scroll down for key talking points, guidelines for submitting comments to CBP, and resources that will help you spread the word.
The Current Situation:
On December 20, 2021, the U.S. Department of Homeland Security (DHS) authorized U.S. Customs and Border Protection to “complete additional projects necessary to address life, safety, environmental, and other remediation requirements in locations previously undertaken by DoD…” in sectors that included Arizona’s Tucson sector.
On January 4, 2022, U.S. Customs and Border Protection for the Tucson sector issued a Border Barrier Remediation Plan includes Pima, Cochise, and Santa Cruz Counties. The plan, which is accepting public feedback until February 3, proposes to take actions along the border that include:
- Closing small gaps in the border wall
- Installing new culverts to aid drainage
- Reseeding construction sites
- Completing and repairing gates
- Creating wildlife crossing holes in the wall that measure roughly 8.5 x 11 inches
A sampling of the wildlife (mountain lion, mule deer, black bear) that are unable to migrate across borders under current conditions:
Understanding the Remediation Plan: What are Its Deficiencies?
1. As it currently stands, CBP’s Border Barrier Remediation Plan does not follow the National Environmental Protection Act (NEPA), which is an environmental review process triggered when any significant federal action is proposed. NEPA is not being followed because it is one of the 84 environmental laws currently waived at the border. Because of this and other waivers, the remediation plan does not include elements expected in an Environmental Assessment:
- The purpose and need for the proposed action,
- Alternatives (as required by section 102(2)(E) of NEPA),
- The environmental impacts of the proposed action and alternatives,
- A listing of agencies and persons consulted.
2. There is no specific language or location data in the plan for where these “gaps” in the border wall are, and CBP does not provide any identifying information that describes which gaps will be filled.
3. CBP’s remediation plan does not identify the places that endured the most severe damage caused by blasting, including Coronado National Memorial, Guadalupe Canyon, Organ Pipe Cactus National Monument, the Patagonia Mountains, Cabeza Prieta National Wildlife Refuge, and others.
4. Major watercourses and tributaries, like the Santa Cruz and San Pedro Rivers, Silver Creek, Black Draw, and Hay Hollow, are under threat because the CBP plan does not allude to maintaining open corridors for water and wildlife in any of these locations.
5. Since the gaps in the border wall were not identified, there is no effective way for the public to comment on the process and file their objections or support.
6. Stadium lighting, which has been installed in numerous segments such as the San Bernardino Valley, are not an item that has been addressed in the plan.
Key Messages for Comment Letters:
[PDF FOR DOWNLOAD: Comment Talking Points & Key Messaging]
Based on all of this, we currently have a chance to ask for significant improvements to the landscape conditions currently seen in the borderlands. (Download the PDF above for detailed key messages to use in your letters and latitude/longitude coordinates you can add for each location.)
Tell U.S. Customs and Border Protection that its remediation plan must include these high-priority actions for wildlife:
1. Do not close gaps in the wall. The priority must be protecting remaining wildlife corridors from further fragmentation and beginning to remove physical barriers to restore natural wildlife migration, habitat, and flow of water. The top priority wall gaps to leave open are over the Santa Cruz River and in jaguar Designated Critical Habitat (Baboquivari and Atascosa).
2. Keep gates across rivers open year-round on the San Pedro River, Silver Creek, Black Draw, and Hay Hollow to reopen vital wildlife corridors during dry seasons when wildlife must be able to move in search of water on the landscape.
3. Create large wildlife openings in the wall to protect the short-term survival and long-term persistence of wildlife populations on both sides of the border. These openings should be significantly larger than the proposed 8.5 x 11” small wildlife opening proposed to allow the seasonal migration and daily movement of multiple species across the border. We strongly encourage CBP to follow the recommended underpass dimensions in the Wildlife Crossing Structure Handbook from the U.S. Department of Transportation and Federal Highways Administration and create wall openings with a minimum dimension of 23 feet wide and 13 feet high and preferred dimension of >32 feet wide and >13 feet high. These large openings should occur every mile along the wall and be monitored for effectiveness.
4. Decommission patrol road extensions. New border roads into previously inaccessible high-elevation areas pose security and severe erosion risks to Sky Island habitats. The patrol road extensions in Coronado National Forest, Coronado National Monument, and Guadalupe Canyon should be decommissioned and the habitat restored under the direction of public land managers.
5. Disturbed habitat needs erosion control, revegetation, and invasive species monitoring. In consultation with local public land managers, all disturbed land including rockfall, erosion, staging, and disturbed areas should be first evaluated for potential erosion risk and stabilized, then revegetated with native plants and seed. These areas are highly prone to invasion by noxious weeks and an invasive species monitoring and response program should be carried out as the remediation.
6. Turn off all lighting infrastructure, including arrays integrated into the wall and free-standing lighting installations near the wall because it interferes with the natural behavior of wildlife including bird migration and pollutes dark skies with artificial light.
To make your comments count: 1) Use your own words to differentiate your personal comments from those submitted by others. 2) Include KEY WORDS that will help the comments get tallied accurately for the correct places and actions. Examples of key words to use are highlighted in the statements above.
Map Viewer of High Priority Actions:
Use this Google Map to explore where the wall gaps are and what CBP should focus on as top priority remedial actions for wildlife.
Click on any icon to view details and photos, and keep checking back; we’ll be adding more to this map over the next few days.
Commenting on CBP’s Border Barrier Remediation Plan:
U.S. Customs and Border Protection has requested feedback on their Tucson Sector Border Barrier Remediation Plan. They are looking for comments on the following:
- “Are there any other immediate actions that are needed to address life and safety issues, including the protection of the public, USBP agents, and nearby communities from potential harms, and avert further environmental damage or degradation as a result of border barrier construction since 2019?”
- “What are the highest priority actions?”
- “Are there best practices the remediation contractor should follow when implementing these activities?”
Comments are due February 3, 2022.
How to Submit Comments:
- Call 1-800-514-0638
- Email TucsonComments@cbp.dhs.gov with the subject “Tucson Remediation Plan Comments”
- Submit comments on specific proposed actions using CBP’s online interactive map
- Mail a copy to: U.S. Customs and Border Protection, U.S. Border Patron Headquarters, 1300 Pennsylvania Ave. 6.5E Mail Stop 1039, Washington D.C. 20229-1100
Please be sure to customize the comments you submit to CBP. Unique comments submitted by individuals across the region will give this feedback a higher chance of success.
Spread the Word:
We need as many people as possible to comment on CBP’s remediation plan. Use these sample messages and photos to share this action alert with your networks.
U.S. CBP is requesting feedback on their Border Barrier Remediation Plan, which includes filling small gaps in the border wall. Submit comments by 2/3 and tell CBP to prioritize wildlife by improving land and water crossings, controlling erosion, etc. Learn more ► www.skyislandalliance.org/act-now/
Customs and Border Protection recently shared their remediation plan for the border wall in Pima, Cochise & Santa Cruz Counties. Comment by 2/3 and ask them to take significant remedial actions for the region’s wildlife and water. Learn more ► www.skyislandalliance.org/act-now/