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Here is the letter from Dan Millis, in 2016 -- to CBP -- regarding "Towers on the Border" (link to Dan's full letter - 9 pages)

 excerpt...

Sierra Club Grand Canyon Chapter
738 N 5th Ave #214
Tucson, AZ 85705
(520) 620-6401
Dan.millis@sierraclub.org

May 16, 2016

Submitted electronically to: OTIAENVIRONMENTAL@cbp.dhs.gov

Mr. Paul C. Schmidt,
U.S. Customs and Border Protection,
Office of Technology Innovation and Acquisition,
1901 S. Bell Street, Suite 600,
Arlington, VA 20598

RE: Draft EA and Draft FONSI for Integrated Fixed Towers on the Tohono O’odham Nation

To Whom It May Concern:

Please accept the following comments on the Draft EA and Draft FONSI for Integrated Fixed Towers (IFT) on the Tohono O’odham Nation.

Founded in 1892, the Sierra Club is the oldest and largest conservation organization in the United States, with over 2.1 million members and supporters, including approximately 40,000 here in Arizona. Sierra Club’s mission is to explore, enjoy, and protect the wild places of the earth; to practice and promote the responsible use of the earth's ecosystems and resources; to educate and enlist humanity to protect and restore the quality of the natural and human environment; and to use all lawful means to carry out these objectives. We have been campaigning with a specific focus on the protection and preservation of the U.S.-Mexico borderlands in southern Arizona since 2006, and our nationally-organized Borderlands Team works to educate policymakers, members, and the public at large about border environmental issues. Our members have been involved in advocating for lands, waters, and wildlife in the border region for decades.

INTRODUCTION

Remote surveillance towers have a variety of environmental and community impacts that are not yet fully understood. Their level of impact to sensitive resources and species will depend upon the number of towers, the locations where towers are sighted, how Border Patrol operations are conducted on the ground, and, most importantly, the level of environmental planning, assessment, and mitigation undertaken by Homeland Security.

Given the size and scope of the Tohono O’odham IFT Tower Project, and its proximity to the Organ Pipe Cactus National Monument (OPCNM) and the sensitive species and  resources therein, it is necessary to conduct a full Environmental Impact Statement (EIS) in accordance with the process established under the National Environmental Policy Act (NEPA). The waiver of 37 federal laws, including NEPA, issued April 1, 2008 by former Department of Homeland Security (DHS) Secretary Chertoff, applies only to barriers and roads, not to this project. Therefore, the Tohono O’odham IFT Tower Project and its associated infrastructure must be subject to the NEPA process and a full EIS must be produced.

Seven of the proposed new construction towers would be sited in the Gu-Vo District. The Gu-Vo District has made DHS aware that it opposes all of these towers due to a variety of  concerns, including impacts to mountains and sites that are sacred, of historical significance, ceremonial, or otherwise important to residents of the Gu-Vo District. It is not clear from  available documentation that DHS understands the full range of impacts that this project would have on the people, landscapes, wildlife, and resources of the project area, and the opposition letter signed by Gu-Vo District Chairman Rodrick Manuel, Sr. and Vice Chairman Angelita Castillo indicates to us that proper on-the-ground and interagency consultation
either has not occurred, or has failed...

end of excerpt   (link to Dan's full letter - 9 pages)

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