is an architectural designer and researcher based in Milwaukee, WI.
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In March of 2017, Customs and Border Protection (CBP) published an assessment claiming there would be no environmental impact for an installation of surveillance towers on the Tohono O’odham Reservation in southern Arizona. The assessment provided permission for construction of the first set of Integrated Fixed Towers along the U.S.-Mexico border.
A year later, Elbit Systems, an Israeli defense company and supplier of the Integrated Fixed Tower, secured a contract to supply Border Patrol with an additional set of towers. Eighteen of the new surveillance towers were installed within or adjacent to the critical habitats of the same endangered species that CBP previously stated would be unimpacted by the towers installed less than 15 miles to the west, on the Tohono O’odham Reservation. The environmental assessment for this installation of towers was never published.
In response to the selective publishing of only the Environmental Assessments which promote the desired narrative of Customs and Border Protection, this project is the beginning of a more critical environmental assessment. It follows my proposal for the EPA to initiate a directive to necessitate a publicly available Impact Assessment for all construction activities within CBP jurisdiction.
As surveillance towers continue to be installed up to 100 miles inland from the border of the continental United States, their use by CBP is unrestricted and unmonitored by any other government agency.
UNITED STATES GEOLOGICAL SURVEY (USGS)
U.S. FISH AND WILDLIFE SERVICE (USFWS)
U.S. CUSTOMS AND BORDER PROTECTION (CBP)
ELECTRONIC FRONTIER FOUNDATION (EFF)
U.S. GENERAL SERVICES ADMINISTRATION (GSA)
CUSTOMS AND BORDER PROTECTION (CBP)
UNIVERSITY OF NEVADA - MICHAEL RUBIO
VISUAL CONFIRMATION VIA GOOGLE MAPS
Surveillance Towers
Mapping ExtentsLocation data as of April, 2024.
Endangered + Threatened Species
CONSERVATION STATUS: THREATENED
SCIENTIFIC NAME COMMON NAME USFWS CATEGORYCOCCYZUS AMERICANUS YELLOW-BILLED CUCKOO BIRDS
GENERAL DESCRIPTION
In the extreme southern portion of their range in the States of Sonora (southern quarter) and Sinaloa, Mexico, yellow-billed cuckoos nest in upland thorn scrub and dry deciduous habitats away from the riparian zone (Russell and Monson 1988), though their densities are lower in these habitats than they are in adjacent riparian areas. During the regional period of northern migration, which begins in May in Arizona, the yellow-billed cuckoo is known to roam widely assessing the availability of food resources before selecting a nest site, and more than one nest site may be utilized during a single breeding season (15 May through 30 September). The yellow-billed cuckoo’s home range averages approximately 100 acres but has been documented at up to 500 acres.
ADVERSE EFFECTS
The yellow-billed cuckoo is secepable to collision with radio towers, cell towers, and other tall structures. Electromagnetic radiation emitted from the towers’ effects include reduced nesting success when within close proximity to the emitting source (Balmori 2009; Fernie & Reynolds 2005) and various behavioral and physiological responses to electromagnetic fields, such as disruption of normal sleep-wake cycles through interference with pineal gland and hormonal imbalance. Other non-thermal adverse effects such as disorientation of passing birds by RF waves are also of concern. Radiowave frequencies used in tranmission of data from towers also have a heating effect on biological tissue, causing undue stress and exacerbating similar effects listed above.
CONSERVATION STATUS: ENDANGERED
SCIENTIFIC NAME COMMON NAME USFWS CATEGORY PANTHERA ONCA JAGUAR MAMMALS
GENERAL DESCRIPTION
The largest and most robust of the North American cats, The jaguar’s potential range in Arizona includes mountain ranges and rugged terrain along the southeast border. A closed vegetative structure is the major habitat requirement for the jaguar. The open, dry areas in the southwestern United States are considered marginal habitat in terms of water, cover, and prey densities. Jaguars usually avoid open country like grassland and Sonoran desertscrub (USFWS 2012). recent observations of individuals suggest that southeast Arizona is the most likely area for jaguar occurrence in the United States (Hatten et al. 2002). The Tohono O’odham Nation lands were excluded from the critical habitat designation by USFWS.
ADVERSE EFFECTS
USFWS determined that the following physical or biological features are essential to the conservation of the jaguar: expansive open spaces in the southwestern United States with adequate connectivity to Mexico that contains a sufficient native prey base, have available surface water within 12.4 miles, have suitable vegetative cover and rugged topography below 6,562 feet amsl to provide sites for resting, and have minimal to no human population density. Though few jaguars have been spotted near Tohono O’odham land, (7) IFTs exist within the jaguar’s eastward critical habitat designation. An additional (18) IFTs exist within 6 miles of the critical habitat. The effects of the IFT’s electromagnetic and radiowave frequencies on local wildlife has the potential to weaken prey populations for the jaguar and disorient the sleep-wake cycle of the few remaining jaguars in this region.
CONSERVATION STATUS: THREATENED / RECOVERY
SCIENTIFIC NAME COMMON NAME USFWS CATEGORY LEPTONYCTERIS CURASOAE YERBABUENAE LESSER LONG-NOSED BAT MAMMALS
GENERAL DESCRIPTION
Requires caves and mines for roost sites and access to healthy stands of saguaro cactus and paniculate agaves for foraging. The Sonoran desertscrub vegetation community provides the early summer forage base, with bats found in southwestern Arizona. The semi-desert grassland and oak woodlands provide the late summer agave resources in the southeastern portion of the state. Lesser long-nosed bats feed on nectar of paniculate agaves and nectar and fruits of columnar cacti. Lesser longnosed bats are known to travel 30 miles to reach suitable concentrations of forage. No agaves were observed within the project area; however, two species of columnar cacti, saguaro and organ pipe cacti, were observed throughout the project area.
ADVERSE EFFECTS
Electromagnetic radiation emitted from the towers’ effects include reduced nesting success when within close proximity to the emitting source (Balmori 2009; Fernie & Reynolds 2005) and various behavioral and physiological responses to electromagnetic fields, such as disruption of normal sleep-wake cycles through interference with pineal gland and hormonal imbalance. Permanent removal of cacti and other plants in the project vicinity during the construction process could potentially reduce foraging material. Furthermore, electromagnetic radiation has proven to deter bats, further limiting their foraging proximity. IFTs exist within the foraging range of every known Lesser Long-nosed Bat roost within the project vicinity.
Tower Documentation
Effects on Soil
The Proposed Action would permanently disturb up to 223.00 acres of soil, permanent loss of vegetation. Soil disturbance and operation of heavy equipment could result in the direct loss of less mobile individuals, such as lizards, snakes, and ground-dwelling species such as mice and rats. The potential exists for minor releases of petroleum, oil, and lubricant during construction or operational activities.
Effects on Groundwater
Potential impacts on surface waters as a result of increases in erosion and sedimentation during periods of construction. Disturbed soils and hazardous substances (i.e., anti-freeze, fuels, oils, and lubricants) could directly affect water quality during a rain event. Water would be needed for a variety of construction activities, including, but not limited to, wetting construction sites for dust suppression, and concrete mixing. The water used during construction activities to control dust would equal approximately 400 acre-feet (approximately 130 million gallons).
Assuming the worst case scenario of 85 dBA from general construction equipment, the noise model predicts that noise emissions would have to travel 1,138 feet before they would be attenuated to acceptable levels equal to or below 57 dBA, which is the criterion for National Monument and Wildlife Refuges (23 C.F.R. § 722, Table 1). Construction activities would continue over the course of forty (40) days.
Generators would operate a maximum of 4 to 8 hours per day post-construction and would be equipped with sound insulation to decrease noise emissions. From the manufacturer’s data sheet, the generator's noise emissions are estimated to be 67 dBA at 23 feet from the generator. It is estimated that the generator noise would have to travel approximately 75 feet before attenuation to noise levels equal to or below 57 dBA, which is the recommended criterion for national monuments and wildlife refuges (23 C.F.R. § 722).