GOOD NEIGHBOR
ENVIRONMENTAL BOARD

Presidential advisory committee
on environmental and infrastructure issues
along the U.S. border with Mexico
Chair
Diane Austin, Ph.D.
Telephone: (520) 626-3879
Email: daustin@email.arizona.edu

Acting Designated Federal Officer
Mark Joyce
Telephone: (202) 564-2130
Email: Joyce.mark(5).epa.gov
                                        December 18,2013

President Barack Obama
The White House
1600 Pennsylvania Avenue, NW
Washington, D.C.  20006

Dear Mr. President:

As your federal advisory committee for environmental and infrastructure issues along the U.S. border
with Mexico, we write regarding priorities  for addressing serious environmental degradation and
improving the quality of life for the 15 million inhabitants of this complex, multicultural region. We are
highlighting issues for immediate action as well as long-term concerns. Although many of these issues
have been discussed in previous Good Neighbor Environmental Board (GNEB or Board) reports, the
rapid population growth of the region and current environmental conditions have outstripped even the
excellent binational, U.S. federal, state and local efforts directed at resolving them.

The economic recession and sequestration have contributed to challenges facing the Board this year;
therefore, we have worked with your Council on Environmental Quality (CEQ) to develop a plan for
making the best use of our resources and the expertise of our membership. We determined that in 2013,
we would prepare an advice letter identifying key issues that require immediate attention and would begin
gathering data for our 16th report, which will be completed in 2014. In collaboration with the CEQ, we
decided to address ecological  restoration as an umbrella concept to examine and evaluate the
effectiveness of the U.S. federal government in managing multiple aspects of natural resource and
environmental degradation, including invasive species; eroded soils; channelized streams; excessive water
withdrawals; degraded surface water quality; and disruption of landscape connectivity by border security
activities and infrastructure, which also have degraded federal protected areas.

We have discussed these topics in prior reports, beginning with our first report in October 1995.
Additionally, our  13th report specifically identified region-wide issues of environmental degradation,
including climate  impacts, environmental quality, water resource degradation, natural hazards and

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declines in biodiversity.1 For the 16th report, we focus on efforts to address these issues through
ecological restoration. Federal land managers are carrying out individual actions^ and some ecological
restoration efforts are being carried out within existing binational programs such as Border 2020 and the
Border Environment Cooperation Commission (BECC) and North American Development Bank (NADB)
climate change program, but they would benefit from a more comprehensive approach to ecological
restoration throughout the border region. Some issues require new, pragmatic initiatives that improve
coordination among U.S. agencies and across the international boundary to take advantage of synergies.
Stakeholder participation at all levels is critical in developing solutions, and existing programs that
involve coordination with a large number of stakeholders from both sides of the border can inform new
efforts.

GNEB has identified the following issues for immediate action:

    •  All U.S. federal agencies working in the U.S.-Mexico border region should increase interagency
       collaboration regarding ecological restoration and by June 2014 should draft a blueprint for
       action, including goals, metrics and protocols for achieving short-, medium- and long-term
       progress.

    •  The U.S. Department of Homeland Security (DHS) should continue to consider environmental
       protection in operations and  continue environmental protection training as a component of its
       efforts to mitigate damages to natural resources. Training should be adaptive in light of changing
       conditions along the border.

    •  EPA's Border 2020 program should expand the framework to develop performance metrics to
       include specific ecological restoration and maintenance. This will help ensure that ecological
       systems along the border remain viable.

    •  The U.S. federal natural resource agencies and the International Boundary and Water
       Commission, United States and Mexico (IBWC), in collaboration with U.S. state agencies and
       U.S. tribal nations in the border region, should develop metrics, standards and models for
       environmental flows for use  in water planning. They  should identify lessons learned for potential
       use in border watersheds, which should incorporate the recognition of the sovereignty of U.S.
       states and tribal nations regarding water rights. Needed information includes analysis of the range
       of flow characteristics such as peak flow and monthly flow variation, as well as base flows, to
       support planning for allocations, wildlife needs, recreation and treatment capacity.

    •  U.S. federal agencies, such as the U.S. Geological  Survey, Bureau of Reclamation, U.S. Fish and
       Wildlife Service and IBWC, as well as U.S. state and Mexican stakeholders and tribal partners,
       should participate in U.S. state environmental flow reviews as permitted by state law. Where no
       U.S. state environmental flow review or process is occurring, these federal agencies should
       convene basin-wide analyses of environmental flows that are developed with Mexican, state and
       tribal partners to help identify the quantity, timing  and quality of flows,  as well as beneficiaries of
       these ecosystem services, within the framework of existing governing agreements and treaties.
       These analyses should be shared with U.S. states undertaking environmental flow reviews when
1 GNEB, Thirteenth Report of the Good Neighbor Environmental Board to the President and Congress of the United
 States: A Blueprint for Action on the U.S.-Mexico Border (Washington, D.C.: GNEB, 2010), pp. 8-53,
 www.epa.gov/ofacmo/gneb/gnebl3threport/eng gneb 13th report final.pdf.

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    and if they occur. Federal agencies should apply lessons learned from the Colorado River Basin
    Water Supply and Demand Study when conducting these analyses.

•   To develop potential solutions that protect or improve the ecological condition of resources of the
    Colorado River Basin, the U.S. Department of the Interior (DOT) should continue to provide
    institutional and technical support to the Colorado River Basin Water Supply and Demand Study
    and other efforts to gain information for better management of border watersheds and water
    bodies. The solutions examined and adopted in such studies should include those that promote
    healthy river flows in the Colorado River Basin. DOI should disseminate results of the Colorado
    River Basin Water Supply and Demand Study to stakeholders in other border watersheds through
    other agencies such as the IBWC.

•   The U.S. federal government should work with Mexico to coordinate releases from Mexican
    dams in a planned fashion to meet the dual purpose of water delivery to the United States and
    transboundary ecological benefits for the Rio Grande ecosystem, particularly in the area of Big
    Bend National Park and adjacent protected areas in Mexico.

•   The BECC and NADB should use best practices to measure the environmental effects and
    benefits of the projects that the BECC and NADB support, as well as to look for ways to advance
    viable projects that could contribute to ecological restoration through grant opportunities
    supported by existing programs, including the Border Environmental Infrastructure Fund (BEIF),
    Border 2020, and Community Assistance Program (CAP), or new sources.

•   The U.S. federal government should work with local and state stakeholders to support efforts to
    use treated effluent for ecological restoration, including through the BECC and NADB.

•   Because of the transboundary reality of ecosystems in the border region, the  U.S. federal
    government should support efforts to improve urban ecological conditions through binationally
    coordinated watershed councils in places where urban sprawl is taking place, such as the canyon
    lands of Tijuana and the river valley of Ciudad Juarez. Such councils encourage citizen science
    and participation in transboundary ecological stewardship.

•   The U.S. federal government should conduct and support research that assists ecological
    restoration of water bodies, their associated habitats and resultant decisions regarding their
    management. There is an ongoing need for research regarding such key issues as  surface water-
    ground water interactions in the border region, ground water availability, invasive species control,
    and how the volume and timing of water releases from reservoirs can impact habitat. There also is
    a need to link existing models of ecological planning and restoration to border ecosystems.

•   To increase the implementation and success of environmental restoration activities in the U.S.-
    Mexico border region, the U.S. federal government should support ongoing efforts to foster
    transboundary watershed management and ecology studies. These studies can increase
    understanding of how natural and man-made watershed structures and natural processes interact.
    With this information, we can better predict how human activities impact—and ecological
    restoration activities improve—the condition of a watershed. Watershed studies are critical to
    understanding the reasons for impaired sources of surface water, as well as to looking at the
    future and understanding how alternative structural or management initiatives can make water
    available for many uses, including environmental, agricultural and industrial.

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    •  The U.S. federal government should support development and fond the acquisition of the data
       necessary to measure the effectiveness of ecological restoration programs and activities. A
       cohesive, comprehensive data collection program is paramount to the success of any ecological
       restoration activities along the U.S.-Mexico border.

The following sections provide information to support these recommendations.
                                      The Border Context


As described in the 13th GNEB report, certain defining features and characteristics of the border region
make it fundamentally different from other regions within the United States: "The U.S Mexico border
region is defined by rapid economic and population growth, rapid urbanization, spillover effects from
Mexico, asymmetries with Mexican communities across the border, international commerce and trade
flows, high rates of poverty, and a distinct ethnic identity."2 As highlighted in our prior reports and advice
letters, "[t]he North American Free Trade Agreement brought economic expansion but not prosperity to
the border region. It increased trade flows, congestion, and environmental impacts, and also stimulated
significant population growth."3 Much of the border population is concentrated in binational metropolitan
areas such as El Paso-Ciudad Juarez or San Diego-Tijuana, but significant populations live in rural areas,
with many of the latter living in poverty. These include colonias and the lands of 26 federally recognized
tribes. Colonias, located mainly in Texas and New Mexico, are informal settlements that are
economically disadvantaged areas, often lacking the most basic infrastructure, including water,
wastewater and other basic services. Addressing environmental problems in the border region is
complicated not only by the poverty of the region and rapid growth, but also by the transboundary nature
of many key environmental problems, including impaired air and water quality and hazardous materials
management. The U.S.-Mexico border region is characterized by environmental problems unlike those in
any other part of the Nation. The complex geographic, political and economic issues of the region require
the development of sustainable ecological restoration initiatives.

The U.S.-Mexico borderlands are diverse in flora and fauna and vary dramatically through the long
narrow stretch to include chaparral; coastal plains; deserts of cactus, sage bush and creosote; isolated
mountain ranges with pine and oak forests; rugged canyon lands covered in yucca; rolling hills with
grasses and mesquite; and fertile river delta estuaries. Major ecosystems of the border, such as the
Sonoran and Chihuahuan Deserts, include many unique species adapted to dry conditions.4 Portions of the
U.S.-Mexico border also serve as important migratory pathways for many avian, mammalian and
invertebrate species.
2 GNEB, Thirteenth Report,!.
3 GNEB, letter of the GNEB to the President of the United States, May 19,2009, p. 2,
 http://www.epa.gov/ocempage/gneb/pdfy2009 0519 advise letter.pdf.
4 "Southern North America: Northern Mexico into southwestern United States," World Wildlife Federation, last
 modified 2013, accessed September 6,2013, http://worldwildlife.org/ecoregions/nal303.

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                          Ecological Restoration in This Border Context


As defined by the Society for Ecological Restoration (SER), ecological restoration is "the process of
assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed. "5 Restoration is
typically applied as an "act of renewal, revival, or reinvigoration" to "enhance the ability of ecosystems to
change as their environments change."6 It is driven by the values of those implementing it, such as federal
wilderness managers striving for high levels of ecological integrity; ranchers needing sustainable soils; or
residents of sister cities such as Nogales, Arizona, in the United States and Nogales, Sonora, in Mexico
who want clean, reliable water supplies. Lack of restoration under these conditions will lead to a cascade
of negative impacts on natural resources and, in many cases, on human health.

Due to the diverse environment of the region, both politically and geographically, we acknowledge that
we cannot cover the full range of topics or innovations (tools and practices) occurring in the field of
ecological restoration on the U.S.-Mexico border. One of our goals is to evaluate and encourage further
discussion among restoration ecologists, social scientists, planners, designers and practitioners7 of several
key issues critical to border ecological restoration. In our initial review of ecological restoration
principles, activities and U.S. federal programs that could have a restoration nexus, we have identified the
following issues:

    1.   Lack of an overall mandate for ecological restoration and standards defining restoration
        success. This is needed to create a long-term commitment and increase the collaboration and
        integration of different agencies in our current ecological restoration efforts.

    2.   Lack of balance between ecological restoration's emphasis on ecological integrity and
        operational mandates (e.g., transportation, commerce, security). This balance is needed to
        create an adaptive management that is able to choose priorities for the region.

    3.   A focus in most efforts, discussions and actions related to the border "environment"  on
        "brown" issues—pollution and the lack of adequate infrastructure—rather than "green"
        issues—the need to protect, restore and manage biologically diverse flora, fauna and
        habitats.

    4.   Lack of integration with Mexico. Ecological restoration often cannot be accomplished along the
        border without a binational approach. The bulk of the programs and efforts aimed at ecological
        restoration have not been developed using a binational approach to implement them from  both
        sides of the border.
5 Society for Ecological Restoration, SER International Primer on Ecological Restoration, Version 2 (Washington,
 D.C.: Society for Ecological Restoration, 2004), http://www.ser.org/resources/resources-detail-view/ser-
 international-primer-on-ecological-restoration.
6 "What is restoration?" ReSOURCE: Eastern Santa Cruz County, Arizona, Ron Pulliam, last modified 2013,
 accessed September 13,2013,
 http://resourceeasternsantacruzcounry.ning.com/group/bQrderlandshabitatrestoration/page/whv-pollinators-rnatter-
 bv-garv-1.
7 Melissa V. Eitzel et al., "Insights From a Cross-Disciplinary Seminar: 10 Pivotal Papers for Ecological
 Restoration." Restoration Ecology 20, no. 2 (2012): pp. 147-52.

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    5.  Lack or inconsistent application of data, tools and models for assessing ecological
       restoration in the border region. There is an urgent need for a data inventory clearinghouse,
       gap analysis, a data quality review and more within the region to quantity the scope of the
       problems and reach relevant solutions.

    6.  Lack of consistency in the standards applied to achieve ecological restoration. Although
       there have been federal programs that have worked together closely to complete Ecological
       Assessments for discrete geographies, inconsistent standards covering adjacent areas under
       different international, federal, state and local jurisdictions limit the overall viability of natural
       areas that transcend these artificial boundaries.

    7.  Need for consistent and effective stakeholder engagement to create grassroots restoration
       efforts and provide opportunities for employment in this field.

    8.  Need to restore ecological connectivity and ecologically significant areas such as the Salton
       Sea and protect those that already exist.


                    The Potential for Ecological Restoration: Four Examples


In this letter we highlight four areas where the U.S. federal government has responsibility and ecological
restoration could play a significant role: collaborative efforts under the La Paz Agreement, and
particularly Border 2020; water and watershed issues; border security; and  urban areas.


1. Collaborative Efforts Under the La Paz Agreement

Since the 1983 La Paz Agreement, U.S. and Mexican officials have engaged in discussion and
collaboration on environmental protection efforts along the U.S.-Mexico border. The La Paz Agreement
includes specific accords related to air, land and water pollution; management of hazardous substances;
and water infrastructure, but it also provides a framework for discussions and actions on habitat
conservation and ecological restoration issues. The La Paz Agreement, therefore, allows the governments
to convene workgroups and committees or task forces of experts to address a wide range of border
environmental issues. The 30-year-old La Paz Agreement, as well as subsequent institutions such as the
BECC and NADB that are related to the North American Free Trade Agreement (NAFTA), have been
directed primarily at environmental improvement projects or activities. By  mandate, the BECC and
NADB have focused particularly on infrastructure such as wastewater treatment plants. These have been
of more immediate concern to the affected local governments and border residents. Identifying and
ensuring the ecological restoration impacts or benefits of these infrastructure projects has not been a
priority of the workgroups and committees established under the La  Paz Agreement or of the BECC and
NADB.

The latest collaborative effort under the La Paz Agreement, Border 2020: U.S.-Mexico Border
Environmental Program, has five overarching goals.8 Although all of the goals may affect ecological
restoration, only one, "Improving Access to Clean and Safe Water,"  specifically mentions ecological
restoration as part of "protecting and restoring watersheds and water quality." The primary emphasis,
8 EPA, Border 2020: U.S.-Mexico Environmental Program (Washington, D.C.: EPA, 2012), pp. 17-28,
 http://www2.epa.gov/sites/production/files/documents/border2020summarv.pdf.

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however, is to improve water quality using approaches directed by EPA and its counterparts in Mexico,
the Ministry of the Environment and Natural Resources (SEMARNAT) and the National Water
Commission (CONAGUA).

Broadening the focus to include ecological restoration will require more than new language. Although the
early border programs under the La Paz Agreement included agencies with ecological restoration
expertise such as the DOI, neither the current program nor its predecessor, Border 2012, have formally
included the DOI as a partner. Yet on a practical level, most efforts toward ecological restoration on the
U.S. side of the border are implemented through the DOI and its various agencies. Informally and at the
more local levels, personnel with expertise from U.S. federal agencies such as the DOI and the State
Department are involved through workgroups or task forces.

Some of the larger efforts, such as the Landscape Conservation Cooperatives and the Collaborative Forest
Landscape Restoration  Program (U.S. Forest Service), include  border regions and should naturally
intersect with border efforts such as Border 2020. The recent attempt to assess ecologies—and ecological
restoration—through the Bureau of Land Management's Rapid Ecoregional Assessment does include
three areas along the border but does not attempt to integrate an assessment on the Mexican side of the
border or directly collaborate with Mexican authorities. Still, these large, collaborative efforts point to
what is necessary for developing a more comprehensive U.S. federal policy on ecological restoration.
Incorporating these DOI efforts in Border 2020 is a needed first step.


2. Water and Watershed Issues

Water remains the primary limiting resource for most of the U.S.-Mexico border area. This key resource,
which the United States shares with Mexico in many locations  along the border, has been traditionally
considered only from the perspective of supply (i.e., getting sufficient water to end users).  The GNEB
believes that the U.S. federal government  could take a broader  look at border water supply, exploring
opportunities to make water available for ecological restoration.

The allocation of water between the two countries is addressed in two treaties, the Convention of 19069
and the 1944 Water Treaty,10 which allocate the waters of the Rio Grande and Colorado River between
the United States and Mexico. The IBWC is entrusted with applying these treaties.11

One challenge for ecological restoration has been the emphasis on water for agricultural, industrial and
municipal uses over other uses. The 1944  Water Treaty contains a specific order of preferences, giving
the highest priority to domestic and municipal uses followed by agriculture and stock raising, electric
power, other industrial uses, navigation, fishing and hunting, and any other beneficial uses that may be
determined by the IBWC.12 This emphasis on irrigation and municipal supplies affects not just the rivers
regulated by treaty but also other rivers, lakes and aquifers in the border region. It should be noted (see
9 Convention Providing for the Equitable Distribution of the Waters of the Rio Grande for Irrigation Purposes, U.S.-
 Mexico, May 21,1906, T.S. 455.
10 Utilization of Waters of the Colorado and Tijuana Rivers and of the Rio Grande, U.S.-Mexico, February 3,1944,
  and Protocol, U.S.-Mexico, November 14,1944, T.S. 944.
11 The Board has written extensively about border water and watersheds, including the 4th, 8th, 12th and 13th
  GNEB reports. See "Reports to the President of the United States," EPA, last modified December 18,2012,
  accessed September  11,2013, www.epa.gov/ofacmo/gneb/gnebjresident reports.htm.
12 Article 3 of T.S. 944. .

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below) that all the waters of the Rio Grande in the United States under both the Convention of 1906 and
the 1944 Water Treaty belong to individual water rights holders and that these water rights are granted by
state agencies. Coupled with other management practices, the priority of uses has reduced water
availability for fish and other aquatic organisms.

Another concern is that dams have disrupted the natural seasonal variations of rivers. Without high flows
in the springtime, for example, it can be difficult for native plants and animals to survive. In some areas,
rivers are essentially dry during the nonirrigation season, with resulting impacts to aquatic and riparian
species. Infestations of non-native plants along riverbanks, such as salt cedar and giant cane, or aquatic
species, such as giant salvinia, hydrilla and water hyacinth, often have replaced native species, degrading
their habitat.13 In some areas, certain non-native species consume significant amounts of water, thereby
reducing water availability.

Some specific examples of wetland or riparian habitat restoration in the border region include:

    •   The United States Section of the IBWC is working directly to restore habitat at various sites along
        the Rio Grande in the United States between Percha Dam, New Mexico, and El Paso,  Texas, and
        has started to acquire water rights from willing sellers to support the effort.14

    •   Minute 319 of the IBWC,15 signed in late 2012, is a landmark U.S.-Mexico agreement that
        includes a pilot program to provide water for the environment in the Colorado River boundary
        segment and delta, identifying water for a pulse flow to help establish native plant species as well
        as for base flow in a part of the river where upstream dams and diversions have disrupted in-
        stream flow for decades. The Minute also commits the United States and Mexico to implementing
        environmental enhancement of riparian areas, and some work has progressed at habitat
        restoration sites.

    •   The Bureau of Reclamation's Multi-Species Conservation Program (MSCP)  is a 50-year habitat
        conservation plan for 400 miles of the lower Colorado River from Lake Mead to the Mexico
        border.16 Documents to implement the MSCP were signed in 2005.

    •   As previously described in the Board's 12th report, work is underway in California to address
        ecological restoration of the Salton Sea, an inland lake that has suffered from high salinity and
        polluted runoff. Federal, state, and local stakeholders have partnered and built three wetlands for
13 GNEB. "Damage Caused by Invasive Aquatic and Riparian Species on the U.S.-Mexico Border," letter of the
  GNEB to the President of the United States, October 20,2004,
  www.epa.gov/ofacmo/gneb/comments/2004 oct 20 comments.htm.
14 IBWC, United States Section. Project Brief: Restoration Activities in the Rio Grande Canalization Project, June
  2009-August 2013 (El Paso, TX: IBWC).
15 Interim International Cooperative Measures in the Colorado River Basin Through 2017 and Extension of Minute
  318 Cooperative Measures to Address the Continued Effects of the April 2010 Earthquake in the Mexicali Valley,
  Baja California, IBWC, Nov. 20,2012, Minute No. 319, www.ibwc.gov/Files/Minutes/Minute 319.pdf.
16 "Lower Colorado River Multi-Species Conservation Program," last modified November 26,2012, accessed
  September 9,2013, www.lcrmscp.gov/generaljrograni.html.

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       the New and Alamo Rivers in Imperial Valley to assist in cleaning up these rivers and the Salton
       Sea.17

    •  One project that identified water for the Rio Grande has proven difficult to implement. IBWC
       Minute 309,18 signed in 2003, provides for water savings from irrigation district conservation
       projects in Mexico to be transferred to the Rio Grande annually. Unfortunately, because of a
       difference in interpretation of the agreement, Mexico has not made reliable deliveries of
       conserved waters, as required by Minute 309. The lack of deliveries affects water availability for
       downstream Rio Grande users in both countries and reduces transboundary environmental
       benefits.

    •  More broadly, the lack of planned water deliveries from Mexican reservoirs to the Rio Grande
       has created multiple difficulties—from generating periodic water deficits under the treaty, which
       affects Texas water users, to reducing in-stream flow in the Rio Grande—with resulting
       environmental impacts. Securing a specific commitment from Mexico to proactively manage its
       reservoirs to deliver water to the United States in a scheduled manner also would offer the
       opportunity to deliver water in a method that maximizes environmental benefits, much like the
       base flow and pulse flow deliveries planned for the Colorado River. Although scheduling water
       releases to benefit the habitat of Big Bend National Park and adjacent protected areas in Mexico
       has been discussed for a number of years, an agreement with Mexico has remained elusive.

    •  Another matter that merits further attention is the interaction between surface water use and
       ground water use. Often these interactions are not well understood. Additional research on these
       interactions and ground water migration and recharge could help inform efforts to secure water
       supplies for ecological restoration. This is not only true along the border itself, but in the case of
       the Rio Grande, also for the interactions of surface water and ground water use upstream in New
       Mexico.

    •  On a positive note, on September 16, 2013, the chairmen of the Texas Commission on
       Environmental Quality and the Texas Water Development Board and the EPA Region 6
       Administrator sent a joint letter on colonias to three Texas associations. The letter to the Texas
       Association of Counties, the Texas Municipal League and the Texas Association of Regional
       Councils asked for the members of those organizations to cooperate with state and federal
       agencies to provide services to colonia residents. Ifcolonia residents receive wastewater services,
       the prospect for successful ecological restoration increases dramatically.


3. Border Security and Impacts oq Ecological Restoration

Illegal border activity and border security activities have affected the environment of the border region;
the appropriate response strategy, besides applying best practices and mitigation funds to affected
resource managers, should include ecological restoration.
17 GNEB, Twelfth Report of the Good Neighbor Environmental Board to the President and Congress of the United
  States: Innovative and Practical Approaches to Solving Border Environmental Problems (Washington, D.C.:
  GNEB, 2009), www.epa.gov/ocempage/gneb/gnebl2threport/English-GNEB-12th-Report.pdf;
18 Volumes of Water Saved With the Modernization and Improved Technology Projects for the Irrigation Districts in
  the Rio Conchos Basin and Measures for Their Conveyance to the Rio Grande, IBWC, July 3,2003, Minute No.
  309, www.ibwc.gov/Files/Mihutes/Min309.pdf.

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In our December 2, 2009, advice letter, the Board highlighted the effects of the construction and
maintenance of the border fence on the environment. The border fence was mandated by Congress, and
the DHS was charged by Congress with its construction. To quote from the Board's 2009 advice letter,
included as an attachment in the 13th GNEB report, "While.. .the border fence has had some positive
outcomes and is  appropriate in targeted areas, the construction has caused negative impacts to some
natural and cultural resources."1' As noted in the 13th GNEB report, foremost is the disruption of
connectivity for  species moving across the border and connectivity of water flow.20 Recognizing the
positive impacts to facilitate trade and clarifying that increased border protection activities have impacts
in the region, it also could be noted that the DHS is committed to responsible environmental stewardship;
ecological restoration efforts are an integral part of that commitment as per internal policy.21 Border
Patrol activities continue, however, to have consequences. For example, tribes and DOI staff, as well as
residents in the region, report that Border Patrol activities, such as tire dragging to look for tracks of
undocumented immigrants and workers, continue to cause environmental degradation and increase
erosion.

It should be noted that the DHS has undertaken numerous mitigation efforts regarding the impact of the
border fence and is working with the DOI and various tribal organizations on many of them. To cite just
one example, the DHS' Border Patrol Facilities and Tactical Infrastructure Program Management Office
has a project to stabilize fill slopes, offset loss of vegetation and re-establish Quino checkerspot butterfly-
suitable habitat in Zone A-l, San Diego Sector.22 Other projects have emphasized species regulated under
the Endangered Species Act, but the DHS has provided only $17 million of the as much as $50 million
identified by the DOI as needed to mitigate impacts from the construction of the border fence.23 Species-
specific approaches are generally seen as  inadequate responses to widespread  degradation of natural
resources and the environment.

The DHS also has  begun to incorporate training and guidance related to environmental issues into its
practices. In addition, appropriate DHS personnel and Border Patrol officers receive  training on
environmental protection and tribal customs and relations, and they now incorporate environmental
protection and tribal liaising in their daily routine.
19 GNEB, letter of the GNEB to the President of the United States, December 2,2009, p. 1,
  http://www.epa.gov/ocempage/gneb/pdf/2009 1202_advise_letter.pdf.
20 GNEB. Thirteenth Report, pp. 71,74.
21 Janet Napolitano (DHS Secretary), "Department Sustainability Policy," memorandum to Component Heads,
  February 7,2011; Elaine C. Duke (DSH Under Secretary for Management), "Department of Homeland Security
  Environmental Policy," memorandum to all DHS employees, October 18,2008; DHS Chief Financial Officer and
  Chief Readiness Support Officer, "Financial Liabilities Policy," memorandum, April 27,2012; Sustainable
  Practices for Environmental, Energy and Transportation Management, DHS, September 29,2008, Directive
  025-01; Environmental Compliance Program, DHS, May 23,2007, Directive 023-02; Environmental Planning
  Program, DHS, April 19,2006, Directive 023-01; Instruction 023-1 for DHS Directive 023-01; and
  Instruction 017-01 for Historic Preservation in Asset Management and Operations, DHS, March 10,2008,
  Directive 017-01.
22 Dr. Teresa Pohlman (Director, Sustainability and Environmental Programs, DHS), email message to Steve
  Niemeyer (Texas Commission on Environmental Quality), July 8,2013.
23 Dr. Greg Eckert (Restoration Ecologist, National Park Service), email message to Steve Niemeyer, September 11,
  2013.
                                                10

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4. Ecological Restoration in Urban Areas

Urban ecological restoration is a critical need and focus for the U.S.-Mexico border region because border
communities face heightened environmental and public health risks associated with ecosystem
degradation (e.g., risks arising from floods, fire, dust, water contamination and newly emergent disease
vectors).24 For example, haphazard urbanization (i.e., building human settlements on steep, unstable
slopes without adequate infrastructure), as is taking place in the Tijuana canyon lands, causes severe
erosion during rain storms and ecological devastation on both sides of the U.S.-Mexico border. Because
of the complexity associated with high levels of human activity in urban ecosystems, approaches vary
from maintaining and enhancing native plant diversity—or specific rare and endangered plant or animal
species—to restoring and enhancing habitats and cultural landscapes, the latter being landscapes that
combine human and natural features to reflect and express the relationships between people and the
environments within which they live.

The nature and type of restoration that is possible or desirable in urban areas depends on the level of
degradation of the ecosystem; whether or not there is a framework or reference to reestablish systems that
were in place before the urban area was developed; and the extent of recognition of the role of human
values, perceptions and actions  in shaping the landscape.25'26 Using restoration as a tool to maximize
natural resource values in these highly managed settings provides us with opportunities to test adaptive
capacities of species and adaptation techniques under novel environmental conditions.

Ecological restoration can increase the positive impacts of restored soils, air and watersheds, as well as
provide many important socioeconomic and mental health benefits, such as enhanced social cohesion,
increased real estate values, improved health and recreational activities, and recognized cultural and
spiritual values.27 The Tijuana River Valley Recovery Team (TRVRT) is an example of a binational
collaboration that works along such lines in the San Diego-Tijuana twin city region. The TRVRT's
multiagency transborder approach "bring[s] together governmental administrative, regulatory, and
funding agencies in tandem with advice from the scientific community, the environmental community,
and affected stakeholders to...restore the Tijuana River floodplain to a balanced wetland ecosystem."28 In
another example, the U.S. federal government already is supporting some of this work in the Tijuana
River Valley on the U.S. side of the border through innovative "Community Engagement" and "Research
Translation" activities funded by the National Institute of Environmental Health Sciences (NIEHS),
Superfund Research Program.
24 "Human Health Under Threat From Ecosystem Degradation," World Health Organization, last modified
  December 9,2005, accessed September 9,2013, wvyw.who.mt/mediacentre/news/releases/2005/pr67/en/.
25 "Models for Ecological Restoration in Urban Areas: Lessons From the U.S. and Germany," U.S. Department of
  Agriculture Forest Service, last modified October 18,2010, accessed September 10,2013,
  www.nrs.fs.fed.us/urban/landscape change/ecological  restoration germanv us.
26 Lynne M. Westphal, Paul H. Gobster, and Matthias Gross, "Models for Renaturing Brownfield Areas," in ed.
  Marcus Hall, Restoration and History: The Search for a Usable Environmental Past (New York: Routledge,
  2010), pp. 208-17, www.nrs.fs.fed.us/pubs/irnl/2010/nrs 2010  westphal 001 .pdf.
27 National Research Council, Urban Forestry: Toward an Ecosystem Services Research Agenda: A Workshop
  Summary (Washington, D.C.: The National Academies Press, 2013),
  www.nap.edu/openbook.php7record id=l 8370&page=l.
28 "Tijuana River Valley Recovery Strategy," California Environmental Protection Agency, San Diego Regional
 Water Quality Control Board, last modified 2013, accessed November 10,2013,
 http://www.swrcb.ca.gov/rwqcb9/water  issues/tiiuana river valley strategy/index.shtml.
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Ecological restoration can help meet the mission of the federal agencies working in the border region,
including, for example, the DBS' mission to "Build a Resilient Nation."29 Ecological restoration that
improves coupled social-ecological systems in human settlements along the U.S.-Mexico border will help
reduce environmental and public health risks while increasing resilience and security.

These four examples are only some of the areas where ecological restoration, appropriately applied, can
address both environmental and  human problems in the border region. These examples and others will be
more fully researched in the 16th report. Special consideration will be given to potential impacts or
constraints that the recommendations will have on tribal, state and local governments, as well as
nongovernmental and nonprofit organizations.

In this letter, the Board has highlighted key issues for addressing multiple concerns of natural resource
and environmental degradation. These issues include the need to increase collaboration among U.S.
federal agencies and with stakeholders at all levels and from both sides of the border; to continue to
consider environmental protection in agency operations and continue environmental protection training;
and to gather data and develop metrics, standards and models to plan for and measure the effectiveness of
ecological restoration programs and activities. The Board will further develop the issues and themes
raised in this advice letter in our 16th Annual Report, scheduled for release in  2014.

Mr. President, we thank you for the opportunity to provide you with our insights and recommendations on
these important issues.
                                                Respectfully,
                                                Diane Austin
                                                Chair
NOTE: Good Neighbor Environmental Board representatives from U.S. federal departments and
agencies have recused their organizations from this advice letter.

cc: The Honorable Joe Biden
   The Vice President of the United States

   The Honorable Nancy Sutley
   Chair, White House Council on Environmental Quality

   The Honorable Gina McCarthy
   Administrator, U.S. Environmental Protection Agency
  "Building a Resilient Nation," DHS, accessed September 9,2013, https://www.dhs.gov/building-resilient-nation.
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