Western
HemisphereTravel Initiativein the Landand Sea
Environments:
Final
Programmatic
Environmental
Assessment
Table of Contents

Executive Summary......................................................................... .1

List of Tables

Acronyms and Abbreviations........................................................... 5
Clarifications and Updates................................................................ 7

Table 1 	The top 39 land ports by volume account for 95%
of the total volume of land border crossings................ 20
Table 2	The measured processing time (No-Action) andestimated processing time for the action alternatives.. 41
Table 3	Air impacts by implementation stage and border(Northern/Southern).................................................... 47
Table 4	Noise impacts by implementation stage and border(Northern/Southern).................................................... 54

1

Introduction................................................................................ 92

Purpose and Need..................................................................... 11

3

The Alternatives....................................................................... 15

4

Establishing the Baseline......................................................... 19

5

Methods and Drivers................................................................ 33

6

Environmental Resources of Concern...................................... 47

7

Environmental Resources Not Impacted.................................. 59

List of Figures

8

Sea Ports-of-Entry and Recreational Craft .............................. 65

9Transboundary Impacts............................................................ 69

Figure 1	Map of the Northern Border LPOEs rank-ordered byaverage border crossings per day................................. 21
Figure 2	Map of the Southern Border LPOEs rank-ordered byaverage border crossings per day................................. 22
Figure 3	Noncommercial border crossings by year for the
Northern and Southern Borders................................... 25
Figure 4	Transportation method of entry at the Canadian borderin 2005......................................................................... 25
Figure 5	The composition of travelers along the Northern andSouthern Borders in 2004 (includes truck traffic)........ 26
Figure 6	Transportation method of entry at the Mexican borderin 2005......................................................................... 27
Figure 7	Average daytime wait times for high-volume LPOEs
on the Canadian border from 2003 to 2006................. 29
Figure 8	Average daytime wait times for high-volume LPOEs
on the Mexican border from 2003 to 2006.................. 29
Figure 9	The percentage of people below poverty level in 2005
(for whom poverty status is determined)..................... 31
Figure 10 Installation of RFID technology at a typical LPOE..... 35

10 Cumulative Impacts Summary................................................. 71
11 Conclusions.............................................................................. 73
12 Public Involvement.................................................................. 75
13 References................................................................................ 77
14 List of Preparers....................................................................... 83

AppendicesA. Trusted Traveler Programs....................................................... 85
B. Levels of Impact by Resource Area.......................................... 85
C.	Estimating the WHTI-Affected Travelers’ Crossings
into the United States............................................................... 86
D. Public Involvement Materials.................................................. 88
E. Federally Recognized Tribes on the Border............................. 94

WHTI Final Programmatic Environmental Assessment

Figure 11	Causal factors that affect vehicle wait time in Primaryand Secondary Inspections at LPOEs.......................... 38
Figure 12 Inbound land-border crossings from 2000 to 2006...... 39
Figure 13	Average processing times and traffic volume at selected
LPOEs for U.S. citizens and visitors........................... 40
Figure 14 The alternatives rank-ordered by processing time....... 41
Figure 15	The relationship between vehicle emissions and wait
times at LPOEs by county on the Southern Border..... 49
Figure 16	The relationship between vehicle CO emissions andwait times at LPOEs by county on theSouthern Border........................................................... 50
Figure 17	The relationship between vehicle emissions
and wait times for LPOEs by county on the
Northern Border........................................................... 51
Figure 18	The locations of major sea ports-of-entry across theUnited States................................................................ 65
Figure 19	Diagram of typical cruise-ship passenger inspection
process......................................................................... 67

vi

WHTI Final Programmatic Environmental Assessment

Executive Summary
Implementation of the land and sea phase of the Western HemisphereTravel Initiative (WHTI) plan, as directed by the Intelligence Reformand Terrorism Prevention Act of 2004 (IRTPA), is anticipated toenhance the security of the United States (U.S.) borders, while facilitating the movement of legitimate travel and trade across borders.
The WHTI plan would require that citizens of the United States,
Canada, Mexico, and Bermuda use a passport or other designatedalternative document that establishes the traveler’s identity and citizenship to enter the United States at ports-of-entry. Currently, a rangeof different forms of identification, including oral declarations, areaccepted, resulting in difficulty for border officials in detecting fraudulent documents, increased time to assess the validity of documents,
and consequential delays in traffic passing through U.S. borders.
The WHTI plan is already in place at U.S. airports. Currently,
the Department of Homeland Security (DHS) and Customs andBorder Protection (CBP) are considering how to best implement
the WHTI plan at sea ports-of-entry and at land border ports-ofentry (LPOEs). As part of that decision-making process, CBP
analyzed the potential environmental impacts of alternate ways toapply and implement the land and sea phases of the WHTI plan.
The National Environmental Policy Act (NEPA) establishes how
environmental analyses should be framed. In the case of the WHTI
plan, a national or programmatic analysis is appropriate, given thenational geographic scope of the LPOE locations and the national
application of WHTI.
CBP conducted a Programmatic Environmental Assessment (PEA)
to serve as the basis for the determination of whether the documents and use of the documents for implementation of IRTPA will
have a significant impact on the quality of the human environment
such that it would require further analysis under NEPA. The PEA
documents a review of the potential environmental impacts from
WHTI Final Programmatic Environmental Assessmentchanges to technology and operations to meet the requirements forstandardized, secure travel documents under WHTI. Specifically,
the PEA analyzes the potential environmental impacts of four alternative ways to implement the land and sea phases of the WHTI planand the three related stages of implementation activity. The analysis
focuses on implementing the land phase of the WHTI plan, since
LPOEs are the most sensitive to changes in activity in terms ofpotential environmental impacts. Changes to processing travelers
at sea ports-of-entry would happen entirely within existing buildings and other infrastructure while cruise ships are docked, and as
a result no environmental impacts to land or coastal areas aroundthe sea ports-of-entry are anticipated.
The alternatives for implementing WHTI at POEs are listed below.
Each alternative includes the existing Trusted Traveler Programs
already in place (NEXUS, Secure Electronic Network for Travelers’
Rapid Inspection (SENTRI), and Free and Secure Trade (FAST)).
The alternatives include a No-Action Alternative and three action
alternatives:
1. 	Maintain the status quo (the No-Action Alternative as
required by NEPA);
2. 	Accept a limited number of document categories for admission at a Land or Sea Port-of-Entry (POE) (Standardized
Documents Alternative);3. 	Accept standardized documents that contain a Machine
Readable Zone (MRZ Alternative); and4. 	Accept standardized documents that contain Radio
Frequency Identification (RFID) technology and an MRZ,
for the use of RFID-enabled readers at the busiest LPOEs
and MRZ at all LPOEs (RFID Alternative).
Executive Summary

Potential environmental impacts would occur in varying degrees
during the three stages of activity associated with WHTI. The stagesof activity are listed below:

income, minority, or Native American populations. No potential
impacts to energy, land use, waste, water, biological resources,
health and safety, or historic properties are anticipated for any of
the action alternatives.

1) Implementation Stage;2) Early Operational Stage; and3) Steady State Operational Stage: The stage that is considered
the driver for environmental impacts in this analysis.
To assess the potential environmental impacts of the WHTI planalternatives, CBP considered the two main drivers, or aspects ofimplementation, that would cause environmental change: construction and traffic flow. Each alternative would require differing
amounts of construction and result in different traffic flow rates atvarious LPOEs. No substantial construction would be needed for
implementation of any of the alternatives and therefore, no associated impacts would result.

Summary of Drivers for Environmental Impacts for the
Action Alternatives:•

No potential for significant upgrades or substantial new
construction•

Potential to reduce processing time and wait time slightly

Air quality and noise pollution are the primary resource areas thathave the most potential to be affected by the implementation of
WHTI, as a result of changes in traffic flow and wait times at the
LPOEs. Traffic flow and underlying factors, such as processing
time in vehicle primary inspection, are expected to be faster under
all the WHTI action alternatives. Therefore, no associated adverse
environmental impacts are expected to result from any of the WHTI
alternatives. To the extent that any of the alternatives may eventually speed processing time over current levels, some environmental
benefits would result.
Since traffic flow generally is expected to improve, air and noise
pollution also are expected to improve slightly as a result of
implementing any of the WHTI action alternatives and thus, noenvironmental justice or socioeconomic impacts resulting fromenvironmental factors are expected, including impacts to low

WHTI Final Programmatic Environmental Assessment

Executive Summary

AIR QUALITY• Potential to improve air quality slightly in someareas, mainly on the Northern Border, across allalternatives

WASTE• No potential to impact solid waste• No potential to impact electronic waste

NOISE POLLUTION• Potential to improve noise levels slightly in someareas across all alternatives

WATER• No potential to impact through runoff• No potential to impact throughatmospheric deposition

SOCIAL AND CULTURAL PRACTICES• No potential to result in disproportionately highand adverse environmental or health impacts on
low-income or minority populations

BIOLOGICAL RESOURCES• No potential to disrupt or destroy habitat• No potential to affect food and water
through air or water impacts

ENERGY• No potential to substantially increase current
levels of energy consumption• No potential to compromise the ability of LPOEs
or border communities to meet energy needs

HEALTH AND SAFETY• No potential to impact through air quality• No potential to impact through newtechnology upgrades

LAND USE• No land use impacts associated with any of thealternatives

HISTORIC PROPERTIES• No potential to impact due to limited/no
construction

Summary of Environmental Impacts by Resource for the Action Alternatives

WHTI Final Programmatic Environmental Assessment

Executive Summary

WHTI Final Programmatic Environmental Assessment

Acronyms and Abbreviations

APIS............ Advance Passenger Information System
BCC............. Border Crossing Card (Laser Visa)
BTS.............. Bureau of Transportation Statistics
CAA............. Clean Air Act
CBP.............. Customs and Border Protection
CBSA........... Canada Border Services Agency
CEQ............. President’s Council on Environmental Quality
CFR.............. Code of Federal Regulations
COM............ Commercial Vehicles
DHS............. Department of Homeland Security
DOT............. Department of Transportation
EO................ Executive Order
EPA.............. Environmental Protection Agency
FAST............ Free and Secure Trade Program
FHWA.......... Federal Highway Administration
FY................ Fiscal Year
GSA............. General Services Administration
IRTPA.......... Intelligence Reform and Terrorism Prevention Act
of 2004
LPOE........... Land Port-of-Entry
LPR.............. Lawful Permanent Resident; also:
License Plate Reader
MRZ............ Machine Readable Zone
NAAQS....... National Ambient Air Quality Standards
NEXUS........ U.S.-Canada Trusted Traveler Program
NHPA........... National Historic Preservation Act
NPS . ........... National Park Service
NPRM.......... Notice of Proposed Rulemaking
OARS.......... Outlying Areas Reporting Station
OCR............. Optical Character Recognition Zone
POE.............. Port-of-Entry

WHTI Final Programmatic Environmental Assessment

POV............. Privately Owned Vehicle
RFID............ Radio Frequency Identification
RPM............. Radiation Portal Monitor
SEA.............. Strategic Environmental Appraisal
SENTRI....... Secure Electronic Network for Travelers’
Rapid Inspection
SIP............... State Implementation Plan
UNFCCC..... United Nations Framework Convention on
Climate Change
US-VISIT..... United States Visitor and Immigrant Status
Indicator Technology
WHTI........... Western Hemisphere Travel InitiativeAcronyms and Abbreviations



WHTI Final Programmatic Environmental Assessment

Clarifications and Updates

Clarifications and Updates

The Final PEA includes additional information and clarifications
based on information and questions received during the publiccomment period and final government document review process.
Additional information on the public involvement process conducted by CBP can be found in Section 12. For a list of specificcomments and responses, see Appendix D.
Information regarding the potential impacts of WHTI on Native
Americans and other social and cultural practices has been added
to the analysis in place of the previous sections on economics inborder communities (Section 4.1.4) and environmental justice(Section 6.3). A list of Federally recognized American Indian tribes
and reservations located on the Northern and Southern Border has
been added to the Appendices. See Appendix E on page 94.
Clarification on the meaning of noncommercial traffic has been addedon page 25, in Section 4.1.2 in order to provide additional information for the reader about the data in Figure 3: Noncommercial bordercrossings by year for the Northern and Southern Borders.
Table 2 in Section 5.3.2 has been updated to show the correct numbers for the total range and median time for the MRZ and RFID
alternatives. The Draft PEA inadvertently listed incorrect values
for these processes. The error was typographical in nature and does
not change the rank order of the alternatives or conclusions regarding processing time.
In the Draft PEA, the Department of State was incorrectly listed asa coordinating agency. The Department of State is a cooperating
agency for WHTI, not a coordinating agency as stated in the Draft.
The Final PEA has been corrected to reflect the participation of the
Department of State as a cooperating agency.

WHTI Final Programmatic Environmental Assessment

Clarification and Updates



WHTI Final Programmatic Environmental Assessment

1 Introduction

1.1 What is the federal action being analyzed?
The federal action analyzed in this Programmatic
Environmental Assessment (PEA) is the land andsea travel phase of the Western Hemisphere Travel
Initiative (WHTI) plan. The plan will change thedocument requirements for many types of U.S.
travelers and foreign nationals entering the UnitedStates at land and sea ports-of-entry. This analysis
examines the environmental consequences, both
positive and negative, of a range of potential changes
in travel document requirements and the technology
associated with reading travel documents. While themajor focus of this analysis is the consideration ofchanges to technology and travel documents, relatedchanges in the operational process also will be considered. The focus of the analysis is on land border
ports-of-entry (LPOEs). With respect to potential
environmental impacts, LPOEs are most sensitive
to the proposed document and technological changes
associated with implementation of WHTI. Sea portsof-entry are less sensitive to changes in document
requirements and are, therefore, analyzed independently in this assessment.
A CBP Officer inspects a traveler at a land port-of-entry.

WHTI Final Programmatic Environmental Assessment

Introduction

Mexican citizens generally are

1.2	What is a Programmatic Environmental Assessment and why is one being
prepared for the land and sea phases of the WHTI plan?

required to present a valid passport to enter the United States.
However, Mexican citizens entering the United States from contiguous territory and possessinga Border Crossing Card (BCC),
also known as a Laser Visa, may
proceed into the United States up
to 25 miles, except in the Tucson
area, where they may proceed into
the country up to 75 miles. Since
October 1, 2001, first-time applicants for a Laser Visa are required
to present a valid Mexican passportbook as their primary evidence of
citizenship and identity. Therefore,
many Mexicans who have BCCs
already possess passports, although

The National Environmental Policy Act (NEPA) requires federal agencies to conduct environmental
assessments when major federal actions are considered that may have a significant impact on the environment. The implementing regulations for NEPA encourage agencies to implement environmental analyses
early in the planning process to ensure that environmental considerations are taken into account in agency
decision-making.
In response to the attacks of September 11, 2001, Congress passed the Intelligence Reform and Terrorism
Prevention Act of 2004 (IRTPA), which included a section mandating that citizens of the United States,
Canada, Mexico, and Bermuda present a passport or other proof of identity and citizenship to enter theUnited States. WHTI is the program implementing this statutory requirement. Under NEPA, decision-makers
must be aware of the environmental consequences of proposed policies, programs, and projects. In this case,
U.S. Customs and Border Protection (CBP) and the Department of Homeland Security (DHS) are considering the potential environmental impacts of WHTI at land and sea ports-of-entry. WHTI requires decisions
on alternatives for acceptable document categories and technology for processing these documents.
This PEA analyzes the alternatives for implementing WHTI, a program that affects the borders between
the United States and Canada and Mexico. Potential environmental impacts, therefore, are determined at a
programmatic level across both borders of the United States and are not based on site-specific constraints
or issues.

they are not required to show thepassport when crossing the border.
No major changes are anticipatedto this exemption as a result of
WHTI, as the current process meetsthe criteria necessary to satisfy the
purpose and need for this rule.

10

WHTI Final Programmatic Environmental Assessment

2.0 Purpose and Need2.1	Why is CBP changing the documentation
requirements at the border?
Since the attacks of September 11, 2001, the United States has madesecuring its borders a top priority. The Department of Homeland
Security (DHS) was formed in 2003 in response to a growing concern about the ability of the U.S. government to effectively counter
terrorist threats. U.S. Customs and Border Protection (CBP) isthe agency within DHS responsible for securing the U.S. borders.
CBP’s mission is to ensure all goods and persons entering and exiting the United States do so in compliance with all U.S. laws andregulations.
As part of this mission, CBP inspects people entering the UnitedStates to ensure that they are entering the country legally and are
not persons intending harm to the United States. CBP continually seeks new and more efficient ways to improve the process toincrease security, while ensuring the flow of legitimate trade andtravel. Enhancements to the inspection process can include changes
to operational procedures or requirements, the introduction of newtechnologies, and changes to port facilities.

2.2

What is the problem with the existing situation?
Under existing requirements, U.S., Canadian, and Bermudan citizens entering the United States by land or sea from anywhere in theWestern Hemisphere are not required to show a passport or otherstandardized document. To enter the country today from Mexico or
Canada, U.S. citizens need only satisfy the CBP Officer of their citizenship. U.S. citizens now present a variety of documents to CBP

WHTI Final Programmatic Environmental Assessment

Officers, including driver’s licenses, tribal identification cards, birthcertificates, and other documents. They may also prove their citizenship to the CBP Officer by way of an oral declaration. Similarly,
citizens of Canada and Bermuda generally are not required to present a valid passport or visa when entering the United States by landor sea from Mexico or Canada. While the traveler must satisfy the
CBP Officer of his/her identity and citizenship, this may be accomplished by using any proof of citizenship in his/her possession.
Many of the documents presented by these travelers do not denotecitizenship and are subject to potential fraud. Therefore, there

Current documentation requirements for entry to theUnited States depend on the citizenship of the individual:
U.S. Citizens must convince the CBP Officer of their citizenship. The Officer examines the documentation presented andmay ask for additional documentation until satisfied that theindividual is a U.S. citizen.
Nonimmigrant Aliens must present a valid, unexpired passport book issued by their country of citizenship and a valid,
unexpired visa issued by a U.S. embassy or consulate.
Citizens of Canada and Bermuda must satisfy the inspecting
CBP Officer of their citizenship, if required. The Officer may
request identification.
Mexican Citizens with a Border Crossing Card (BCC): Since
October 1, 2001, first-time applicants for BCCs are required
to present a valid Mexican passport book as the primary document of citizenship and identity.

11

Purpose and Need

The most important criterion tosatisfy purpose and need is theability for a CBP Officer to identify quickly and easily the citizenship and identity of all travelers
entering the United States. To
meet this criterion, the proposed
alternatives should:•	Limit the number of different types of documents that
the CBP Officer must inspect
to ensure reliable evidenceof identity and nationality•	Ensure CBP confidence
in the document-issuanceprocess•	Allow validation of the document-holder’s information
against government databases•	Require that documents
contain sufficient security
features to:
o

o

12

M
 ake evident to Officers
attempts to counterfeit oralter the document
Be electronically unique

A variety of documents that differ in appearance, information,and security features are difficult to assess for validity.

is a danger that non-U.S. citizens with U.S.
identification could present themselves as U.S.
citizens. CBP Officers must distinguish among
numerous different types and formats of identification documents on a daily basis, making
the task of recognizing fraudulent documents
more difficult. The land border is particularly
challenging for CBP Officers due to the large
volume of traffic that must be processed in ashort period of time.

Currently, CBP Officers must:•

Distinguish among thousands of different
documents•

Assess the validity of documents
presented•

Ask questions to establish citizenship andpurpose of travel•

Enter data into their computer system forcriminal-database queries

Changes resulting from the new passport anddocumentation requirements imposed by IRTPA
will result in a more reliable verification of citizenship and identity process, and will advancethe mission of CBP to secure the flow of people
and goods into the country, while facilitating
legitimate travel and trade.

2.3 	What is the purpose and need forthis federal action?
The purpose and need for the land and sea
phases of the WHTI plan is to secure the U.S.
borders through the requirement of more reliable and secure travel documents. Improved
travel documentation requirements would help
DHS and CBP ensure the identity and citizenWHTI Final Programmatic Environmental Assessment

Purpose and Needship of travelers to the United States. Proper identification of individuals entering theUnited States is necessary so that DHS and CBP can fulfill their mandate to secure thenation’s borders. Congress recently has enacted legislation requiring DHS and CBP
to make these needed improvements to travel documentation. Specifically, Section
7209 of IRTPA requires both U.S. citizens and nonimmigrant aliens to have a valid
passport or other identity and citizenship document to enter the United States.

A CBP Officer must assess documents as vehicles wait at the port-of-entry. On a typicalday, CBP processes 1.1 million passengers and pedestrians, including 724,192 aliens;
64,432 truck, rail, and sea containers; 2,639 aircraft; 365,079 vehicles; and 75,734
merchant entries coming into the United States.

WHTI Final Programmatic Environmental Assessment

To accomplish the goal of securing the nation’sborders, CBP must examine a number ofdifferent components of the entry process.
Specifically, the following types of actions(which might be required to implement theland phase of the WHTI plan) are consideredin this environmental assessment:•

Facility changes/construction
brought on by changes in travel
documents (e.g., installation of document readers, workstations, cabling,and sensors)•

Development, deployment, andimplementation of new information
technology (e.g., development of
new software/database management
system or new telecommunications
equipment, and associated training
and implementation)•

Changes in operational procedures atthe border that could change processing and wait times (e.g., increased
percentage of queried travel
documents)

These actions, along with related traffic
throughput and wait times associated witheach alternative, form the basis of the environmental assessment.

13

Purpose and Need

14

WHTI Final Programmatic Environmental Assessment

3.0	The Alternatives: How can the problem
be addressed?
To determine the best method of implementing the land phase of the WHTI plan, CBP examined threealternatives, plus the No-Action Alternative (or status quo). These alternatives were developed using thecriteria determined necessary to the meet the purpose and need for this action. This PEA examines thesealternatives with respect to their potential environmental impacts for the land environment. Sea ports-ofentry and recreational craft are analyzed independently in Section 8.0.

3.1

No-Action Alternative (Status Quo)
This alternative would not result in any changes to the current
travel document requirements or the current inspection process.
Nevertheless, it is provided as a baseline to examine what theenvironmental impacts would be if the land or sea phase of the
WHTI plan were not implemented. Under this alternative, CBP
would continue to process travelers in the traditional way, usinga wide variety of acceptable documents and oral declarations,while increasing the level of scrutiny whenever feasible. The
current process usually involves the traveler’s presentation ofa driver’s license and birth certificate or passport book, or amachine reading of Trusted Traveler Cards such as NEXUS,
Secure Electronic Network for Travelers’ Rapid Inspection(SENTRI), Free and Secure Trade (FAST), or Border Crossing
Card (BCC). Machine Readable Zone (MRZ) readers areavailable to read documents such as passports that are MRZ
compatible. Existing problems with traffic backup and longwait times at some ports-of-entry would remain.
No-Action Alternative• Thousands of accepted documents• Documents contain no standardized security features

Frequently Used Terms:
MRZ — Machine Readable
Zone — an optical-characterrecognition zone (OCR) on the
document that allows a machine
to read the document
RFID — Radio Frequency
Identification — refers to anembedded chip in a credit cardlike card or in a passport thatallows an antenna to pick up a
discrete identification number
from the card (similar to, butmuch smaller than, the E-Z Passused on toll roads and bridges)
Trusted Traveler Cards —CBP-issued cards that use either
MRZ or RFID technology andrequire background checks inexchange for faster processing
at the border, and in some cases
the use of designated express
lanes (e.g., NEXUS, SENTRI,
or FAST)• Documents accepted at all land or sea POEs
WHTI Final Programmatic Environmental Assessment

15

The Alternatives

3.2

Standardized Documents Alternative
This alternative would involve the standardization of information and layout
for a limited number of travel document categories accepted at the borders.
The approach would continue to rely on existing information-management systems and equipment. No new facility construction would be required. Under
this alternative, Trusted Traveler documents would continue to be accepted.
Standardized Documents Alternative

3.3

ßLimited number of accepted documents (e.g., five to ten categories)ß

Documents contain standardized security featuresß

Documents accepted at all land or sea POEs

Machine Readable Zone (MRZ) Alternative
This alternative is similar to Alternative 2, but would include the requirementthat all standardized documents have a Machine Readable Zone. This alternative would require MRZ equipment and cabling and common computer
software. However, the majority of vehicle primary inspection booths at
LPOEs already are equipped with operational MRZ-document readers. As in
Alternative 2, Trusted Traveler documents would continue to be accepted.
MRZ Alternative

16•

Limited number of accepted documents (e.g., five to ten categories)•

Documents contain standardized security features•

Documents include Machine Readable Zone•

Documents accepted at all land or sea POEs

WHTI Final Programmatic Environmental Assessment

The Alternatives

3.4	Radio Frequency Identification (RFID) Alternative
This alternative is the same as Alternative 3, but also would include the use of RFID
technology in the travel document. It incorporates the standardized documents categories of Alternatives 2 and 3. This alternative also would include the utilization of
MRZ technology as in Alternative 3. MRZ readers would continue to be available atall LPOEs, including those without RFID technology.

RFID Alternative

3.5

ßLimited number of accepted documents (e.g., five toten categories)ß

Documents contain standardized security features

ß

Each document contains Radio Frequency
Identification chip and Machine Readable Zone

ß

RFID accepted at the busiest POEs. MRZ accepted at
all LPOEs.

Summary of the Alternatives
The Alternatives
No-Action}

Standardized Documents Alternative
MRZ Alternative
RFID Alternative

WHTI Final Programmatic Environmental Assessment

The “Action Alternatives”

The alternatives presented above build upon one another, in thatstandardization appears in the alternatives that follow the Standardized
Documents Alternative. Likewise, the RFID Alternative would
include both standardization and machine-readable technology.
Although some vehicle lanes at LPOEs currently possess RFID technology, RFID readers would be installed on vehicle lanes at additional
LPOEs as required. MRZ readers would continue to be available at all
LPOEs, including those without RFID technology.
The three “action” alternatives cover the entire range of implementation options for the land phase of the WHTI plan. By examining
each action alternative and comparing the potential impacts to the
No-Action Alternative, the range of environmental effects can be
examined by decision-makers and the public.
17

The Alternatives

18

WHTI Final Programmatic Environmental Assessment

4.0 Establishing the Baseline

Activities along the border take place across a vast and complicated system of interactions
among people, places, communities, and political boundaries. This section describes theseprocesses and entities to help provide context for the analysis of the potential environmental
impacts of the WHTI plan. Included in this discussion are the:•Types, location, and number of LPOEs•

Description of border communities•

Border processes

4.1	What is the current operational and community environment at theland ports-of-entry?
4.1.1

Ports-of-entry
There are 325 air, sea, and land ports-of-entry in the United States, yet about three-fourthsof travelers enter the country through the 163 LPOEs (CBP, 2006b). The LPOEs are locatedalong a vast geographic area spanning 15 different eco-regions and stretching more than
7,500 miles along the boundaries between the United States and Canada and Mexico.
Land borders are unique because traffic at these crossings consists of varying combinationsof pedestrians, bicycles, cars, trucks, buses, and rail. In contrast, border-crossing travelers
at air and sea ports-of-entry enter by one mode of transport as pedestrians.
The LPOEs vary widely in size, staffing, and setting (urban vs. rural), and in the volume
and demographics of travelers crossing the borders. The 39 busiest ports process 95%of the annual cross-border travelers each year (Table 1, Figures 1 and 2, Department ofTransportation, n.d.).

WHTI Final Programmatic Environmental Assessment

A note about buses, trains, and ferries:
Bus-traffic passengers account for about
2% of all border crossings (Department ofTransportation, n.d.). A distinct but small
amount of this traffic derives from schools andyouth activities.
Train passengers account for less than one-tenthof one percent of all land border crossings. The
number of passenger-train crossings at all POEs
is small in terms of individual crossings, andthese occur only on the U.S. – Canadian border.
Ferry traffic crosses the Northern Border in
Alaska, Washington, Michigan, Ohio, New
York, and Maine. One ferry operates on the
U.S. – Mexican border at Los Ebanos, Texas: ahand-operated ferry carrying three cars at a time.
Combined ferry traffic is less than 1% of total
crossings (Department of Transportation, n.d.).
Bus, train, and ferry crossings represent only asmall number of total crossings, and for the purpose of this analysis are deemed insignificant interms of environmental consequences resulting
from the implementation of the WHTI plan.
19

Establishing the Baseline

Establishing the Baseline

Rank

LPOE Locations

Rank

LPOE Locations

1

San Ysidro, CA

20

Calais, ME

2

El Paso, TX

21Progreso, TX

3

Brownsville, TX

22

Rio Grande City, TX

4

Hidalgo, TX

23

Tecate, CA

5

Laredo, TX

24

Massena, NY

6

Buffalo/Niagara Falls, NY

25

Point Roberts, WA

7

Otay Mesa, CA

26

Presidio, TX

8Calexico, CA

27

Sault Sainte Marie, MI

9Detroit, MI

28

Andrade, CA

10Nogales, AZ

29

Alexandria Bay, NY

11

Eagle Pass, TX

30

Sumas, WA

12

San Luis, AZ

31

Fabens, TX

13

Calexico East, CA

32

Naco, AZ

14

Blaine, WA

33

Derby Line, VT

15

Douglas, AZ

34

Lukeville, AZ

16

Del Rio, TX

35

Madawaska, ME

17Port Huron, MI

36International Falls/Ranier, MN

18

Champlain-Rouses Point, NY

37

Columbus, NM

19

Roma, TX

38

Lynden, WA

39

Highgate Springs /Alburg , VT

Table 1
The top 39 land ports by volume account for 95% of the total volume of land border crossings (Department of Transportation, n.d.)

20

WHTI Final Programmatic Environmental Assessment

Establishing the Baseline

27

25
14 38

35

30

20
36

18

39

33

Average Crossings Per Day
20,000 — 40,000
10,00 — 20,000
5,000 — 10,000
2,000 — 5,000

24
27
29

6
17
9

27

27

14 38

35

30

20

25

36

14 38

30

18

39

33

24
27
29

36
6
17
9

Figure 1
Map of the Northern Border LPOEs rank-ordered by average border crossings per day

WHTI Final Programmatic Environmental Assessment

21

Establishing the Baseline

1

23 8

28

12
34
10 32

15

37

2
31

26

16
11

5

4

19 3
21

Average Crossings Per Day
40,000 — 90,000
20,000 — 40,000
10,00 — 20,000
5,000 — 10,000
2,000 — 5,000
Figure 2
Map of the Southern Border LPOEs rank-ordered by average border crossings per day

22

WHTI Final Programmatic Environmental Assessment

Establishing the Baseline

Physical LPOE Layout and Constraints
Due to differences in the communities along the vast land borderthat the United States shares with Canada and Mexico, LPOEs vary
widely in the scope and volume of operations. While certain LPOEs
operate many lanes around-the-clock, other border ports see only a
few cars during the day and close at night.
LPOEs also vary dramatically in size, ranging from 300 square feetto over 300,000 square feet. Crossing activities demonstrate similar extremes. The busiest LPOEs process almost 100,000 travelers
per day, while some isolated ports see only a few travelers a day(Department of Transportation, n.d.).

A typical port facility spans a road crossing an international boundary. On such a road, the outbound lane or lanes (leaving the UnitedStates) generally are open and bypass the facility, while the inboundlanes (entering the United States) feed into a series of inspection
booths that may include both commercial and noncommercial primary inspection stations. Some LPOEs accept only commercial
traffic, some accept only noncommercial, and most accept both.
Commercial inspections often are carried out in separate areas of theport facility. The main building in the LPOE generally houses administrative offices and the pedestrian and secondary inspection areas.

F B

G

E

D

C

A

A: Main Building
B: Inbound Noncommercial Traffic
C: Noncommercial Primary
D: Noncommercial Secondary

E: Headhouse
F: Inbound Commercial Traffic
G: Commercial Primary

LPOEs vary widely in size, fromvery large ports to very small ports.

A typical LPOE layout as seen from aerial photography

WHTI Final Programmatic Environmental Assessment

23

Establishing the Baseline

Current Facility Constraints and Complexities
Ownership and Responsibility for the 163 U.S. LPOEs:•

44 CBP-owned facilities•

95 General Services Administration-owned facilities•

23 General Services Administration-leased facilities•

1 National Park Service-owned facility

The functionality of CBP LPOE operations is determined, in part,by the physical locations within which they operate. Each port isdistinctly different from another in a variety of aspects, such aslayout of inspection space, number of lanes, number of buildings,
and square footage of workspace.
Availability of electric power can be a constraint at some facilities.
In recent years, the addition of sensors and information technology
at the ports has strained the available power capacity in some locations. Some site-specific upgrades or energy conservation measures
may be required to enable the installation of any additional technology with substantial power requirements.
Currently, one-third of the ports along both the Northern andSouthern Borders have inadequate primary and secondary inspection space, creating a facility constraint for CBP operations.
One-fifth of the LPOEs also are hampered by having insufficient
vehicle queuing areas (CBP, n.d.[b]). Many high-volume ports
currently operate at carrying capacity and cannot accommodate
adverse changes to traffic volume or processing time without anassociated impact on vehicle wait times. A decrease in traffic orprocessing time would help to reduce average wait times at thesehigh-volume ports.

24

Infrastructure needs and construction projects are included in CBP and
GSA capital programs each year.

To identify specific infrastructure needs, CBP submits a list ofprioritized LPOE facility projects to be included in the General
Services Administration’s (GSA) capital program each fiscal year.
GSA works with CBP to establish requirements for overall building
area, inspection lanes, warehouses, and other features necessary toaccommodate CBP’s programmatic needs. Projects can range frommoderate facility modifications to entirely new port construction.
At any given time, LPOEs undergo facility modifications, upgrades,
and sometimes, entirely new building projects to better support CBP
functions and operations at the ports-of-entry.
For the purposes of the PEA, facility constraints are consideredpart of the existing (baseline) environment. CBP addresses the constraining factors for each LPOE in annual prioritized submittals to
GSA. Previous site-analysis work conducted by US-VISIT (2003a,
2003b) has examined the facility constraints within the context ofthe environmental conditions at the LPOEs.

WHTI Final Programmatic Environmental Assessment

Establishing the Baseline

Northern Border

4.1.2 People and Cross-border Travel
The number of people crossing the borders has declined over thelast decade.1 Figure 3 indicates the magnitude of non-commercial border crossings. Noncommercial traffic includes privately
owned vehicles, buses, and pedestrians. No comparable data were
included for commercial crossings because WHTI will not impact
commercial traffic or documentation requirements. Some of thedifferences between the Northern and the Southern Borders areapparent. About 75% of all border crossings occur on the Southern
Border and a sizeable percentage of these involve pedestrians(Department of Transportation, n.d.; CBP, 2006b). About 25% of
all border crossings occur on the Northern Border and conversely,
very few of these crossings involve pedestrians (Department ofTransportation, n.d., CBP, 2006b). Overall, approximately 80%
of total land border crossings occur in privately owned vehicles(POVs) (Department of Transportation, n.d.)

In 2005, about one-fourth of all crossings into the United Statescame through the LPOEs on the Northern Border (Department ofTransportation, n.d.). Although LPOEs on the U.S. – Canadianborder are more numerous than on the Southern Border, far fewer
individual crossings are made on the Northern Border.
As indicated in Figure 4, privately owned vehicles (POVs) predominate as the method of entry into the United States from Canada.
While some Northern Border LPOEs are large ports such as Buffalo
and Detroit that process 30,000–35,000 travelers per day, most
Northern Border LPOEs are rural. Combined, these rural LPOEs
process fewer than 5% of all crossings per day (Department ofTransportation, n.d.).

POV
POV
85%

CanadaMexicoMillions

300
200
Pe

a
V
tri
PO des100
Bu

20

02 003 200
2

4

20

05

20

00 2001

20

02 003 200
2

4

20

05

Figure 3
Noncommercial border crossings by year for the
Northern and Southern Borders

1

ns

1

in

00 200

a
Tr

20

s

-

Bus
5%

Train
0%

Trucks9%

Pedestrians
1%

Figure 4
Transportation method of entry at the Canadian border in 2005

 he U.S. Bureau of Transportation Statistics (BTS) publishes inbound monthly border crossing/entry data for vehicles, buses, trains, passengers, and pedestrians. The data include
Tcrossings by LPOE on the U. S. –Canadian and U.S. – Mexican borders. The BTS data represent the best available quantitative information on incoming traffic into the UnitedStates for land border crossings and is the primary source of crossing data for this PEA.

WHTI Final Programmatic Environmental Assessment

25

Establishing the Baseline

Southern BorderFigure 5 shows the composition of travelers (including commercial
traffic) currently using passports or Trusted Traveler documentation
to cross the Northern Border. The pie charts also show an estimateof the percentage of travelers who are likely to need new documentation when the land phase of the WHTI plan goes into effect. On
the Northern Border, 58% of crossers are comprised of both U.S.
and Canadian citizens and are expected to be affected by the change
in document requirements under WHTI (CBP, 2006b; Departmentof State, 2005; Industry Canada, 2006). These crossers do nothave passports or Trusted Traveler documentation, and would be
required to obtain them or an acceptable alternative document after
implementation of the land phase of the WHTI plan. The percentages were calculated using the best available data from 2004 (SeeAppendix C: Estimating the WHTI-Affected Travelers’ Crossings
into the United States).

Southern Border LPOEs process about 75% of total land borderinspections nationwide, which consist of 99% of all pedestrian inspections and 75% of POV inspections (Department ofTransportation, n.d.).
Figure 5 shows the percentage of Southern Border travelers who
would be affected by the document changes required by WHTI.
Since Mexican citizens already are required to present a valid passport or Laser Visa to enter the United States and already have thenecessary documents, they would not be impacted by the change
in document requirements under WHTI. Altogether, it is expectedthat approximately 29% of travelers on the Southern Border, allof whom would be U.S. citizens, would be affected by WHTI
(CBP, 2006b; Department of State, 2005). These crossers do not
Northern Border Crossings Composition of Travelors

Total Border Crossings

24%

23%

32%
26%

Canadian Citizens
with WHTI
Canadian
Citizens
withdocumentation
WHTI documentation
US Citizens
withwith
WHTI WHTI
documentation
US
Citizens
documentation
Canadian
Citizens
WHTI documentation
US Citizens without
WHTIwithout
documentation
US
Citizens
WHTI
documentation
CandianCitizenswithout
without WHTI
documentation

19%

76%
Southern Border Crossings Composition of Travelors

Total border crossings on the Northern Border

29%

Total border crossings on the Southern Border

14%

57%

Mexican Citizens
US Citizens with WHTI documentation
US Citizens without WHTI documentation

Figure 5
The composition of travelers along the Northern and Southern borders in 2004 (includes truck traffic)

26

WHTI Final Programmatic Environmental Assessment

Establishing the Baseline

have passports or Trusted Traveler documentation, and would be
required to obtain them or an acceptable alternative document after
implementation of the land phase of the WHTI plan. The percentages were calculated using the best available data from 2004 (SeeAppendix C: Estimating the WHTI-Affected Travelers’ Crossings
into the United States).
Figure 6 indicates the types and percentages of different entry
modes on the Southern Border. The border-crossing figures for
the Southern Border are dominated by a few very large and busy
LPOEs such as San Ysidro, El Paso, and Brownsville, which eachtypically processes 40,000 – 85,000 travelers per day (Departmentof Transportation, n.d.).
One of the common characteristics of border crossings is that somepeople cross frequently. Commuters and others who cross regularly
account for a significant percentage of total border crossings. For
example, at one Northern Border LPOE, about 344,000 travelers
cross more than once a month and account for 27% of all crossingsby U.S. citizens at that LPOE (Department of State, 2005).

Train
0%

Trucks2%

Processes at Land Ports-of-Entry
In FY 2005, more than 319 million passengers and pedestrians
were processed by CBP at LPOEs (CBP, 2006a). Passengers andpedestrians are processed using varying forms and levels of identification, ranging from a verbal declaration of citizenship by a U.S.
citizen to a passport containing a visa for a foreign national. Trusted
Traveler Programs along the Northern and Southern Borders expedite the entry process for pre-screened participants and help provide
advanced passenger information to the CBP Officer.
Trusted Traveler Programs
The Trusted Traveler Programs are programs that expedite bordercrossings. These include the NEXUS, SENTRI, and FAST programs
in which typical users are daily commuters or commercial drivers.
Certain LPOEs have reserved designated lanes for the holders ofTrusted Traveler Program cards. These Trusted Traveler Programs
are important because they represent approaches similar to WHTI
alternatives that involve MRZ and RFID technology. The Trusted
Traveler Programs are discussed in more detail in Appendix A.
Port Inspection Dynamics and Wait Time

POV
78%

Bus
1%

4.1.3

Pedestrians
19%

Figure 6
Transportation method of entry at the Mexican border in 2005

WHTI Final Programmatic Environmental Assessment

In recent years, the inspection process described has become increasingly rigorous, particularly since September 11, 2001. The current
CBP strategic plan calls for screening all travelers prior to entry
through a land port-of-entry (CBP, 2006a). This increased scrutiny
typically leads to longer individual inspections than in previous
years. It also results in a substantial increase in the time spent bytravelers waiting in queues for primary inspections. Vehicles queued
for inspection can have an effect on environmental resources; consequently, a brief description of the inspection dynamics that create
long vehicle lines is incorporated here.
Wait time is defined as the time spent by a vehicle starting with its
27

Establishing the Baseline

arrival in the queue and ending with the signal to proceed to theprimary inspection booth. Wait time is a function of the number ofvehicles arriving at the port per unit of time, the time each vehicle
spends in primary inspection, port design, and the number of primary inspection booths operational. An associated measure is idle
time, or time lost, which is the sum of the wait time for every vehicle
in the queue over a specified period of time. Wait time and port
geometry (number and length of lanes operational) are the factorsthat contribute to idle time.
As shown in Figures 7 and 8, the average daily wait times on the
Canadian border are relatively short in comparison with the wait
times on the Mexican border. Trends vary by port; however, in general, wait times increased between 2003 and 2006. This continues atrend that has been discernible since 2000. Wait times peaked immediately following the September 11, 2001, terrorist attacks in the
United States, but they returned to normal for most ports-of-entry

by the end of that year, as traffic volume plummeted immediately
following the September 11 attacks.
Another attribute of wait times that differs with location involves
daily peak periods. At Northern Border ports-of-entry, wait times
typically peak at midday. On the Southern Border, wait times
remain consistently high throughout daylight hours.
4.1.4	Economics, Demographics, and Cultural Practices in
Border Communities
In general, high volumes of people and vehicles move across theNorthern and Southern Borders annually for a variety of reasons,
including historical relationships between communities along
the border, commerce and trade, business, cultural and religious
practices, access to prescription drugs and medical care, tourism,
recreation, shopping, and socialization with family and friends.

Typical LPOE Inspection Process:Step 1 As a vehicle approaches the inspection
facility, the traveler selects an open vehicle
inspection lane. Vehicles must wait at a stop
sign prior to approaching the vehicle inspection booth. At the stop sign, Radiation Portal
Monitors (RPMs) passively screen vehicles
for the presence of nuclear and radiologicalmaterials. Once the CBP Officer completes thecurrent inspection, the Officer signals for thetraveler’s vehicle to advance. As the vehicle
moves towards the inspection booth, a license
plate reader transmits the license plate number
to the primary inspection booth.

28

Step 2 One CBP Officer conducts the primary
inspection in each vehicle lane.
All persons seeking admission: Persons in thevehicle are required to identify themselves, stateor present documents showing citizenship, anddeclare their intent and purpose of travel. The
CBP Officer verifies citizenship for all occupants of a vehicle.
U.S. Citizens: Currently, persons claiming to be
U.S. citizens must satisfy the CBP Officer of
their citizenship through oral declarations or any
documentation that is sufficient in the judgmentof the examining Officer. The Officer may direct

the vehicle and all occupants to a secondary areafor further inspection or allow the vehicle toproceed into the United States.
Non-U.S. Citizens: The CBP Officer must determine that correct and legitimate travel documents are presented and determine the travelers’duration of stay in the United States. The CBP
Officer may send the travelers to a secondary
inspection area for further inspection of theoccupants and/or vehicle or for review and issuance of necessary documentation. Otherwise,
the CBP Officer will allow the travelers to proceed into the United States.
WHTI Final Programmatic Environmental Assessment

Establishing the Baseline

Average Daylight Wait Times
25.0
20.0

Minutes

15.0
10.0
5.0
0.0
2003

2004

2005

2006

Blaine-Peace ArchBlaine-Pacific Hwy
Sault Ste. Marie
Sumas
Champlain
Calais-Ferry PointPort Huron
Highgate Springs
Sweetgrass
Detroit-Amb Bridge
Detroit-Windsor

Figure 7
Average daytime wait times for high-volume LPOEs on the Canadian border from 2003 to 2006

Average Daytime Wait TImes
60.0
50.0
Minutes40.0
30.0
Minutes
20.0
10.0
0.0
2003

2004

2005

2006

San Ysidro
Calexico-West
Otay Mesa
San LuisNogales-Deconcini
Nogales-Mariposa
Laredo-Bridge II
Calexico-East
El Paso-BOTA
Laredo-Bridge I
Hidalgo/Pharr
Tecate, CA

Figure 8
Average daytime wait times for high-volume LPOEs on the Mexican border from 2003 to 2006

WHTI Final Programmatic Environmental Assessment

29

Establishing the Baseline

Figures for border crossings indicate commercial traffic (which at thelarger LPOEs uses dedicated lanes for crossing) figures more prominently at the Canadian border than the Mexican border. Commercial
traffic in 2006 along the Northern Border accounted for 18% of all
traffic crossing the U.S. – Canadian border, whereas only 3% of traffic
along the Southern U.S. – Mexican Border was commercial.
The border is characterized by many low-density rural communities, with a few large cities scattered in between. As Figure 9shows, some U.S. border states have higher poverty rates than thenation as a whole, based on the 2005 U.S. Census (U.S. Census
Bureau, 2007), with some Southern Border states indicating somewhat higher percentages than generally found in the Northern
Border states.
As with the nation as a whole, border communities reflect a varied
population and culture. Communities along the border with Mexico
may contain a predominately Latino population. By way of example, in New Mexico, 54% of the population in border counties is
Latino. Additionally, 40% of the children in New Mexico’s bordercommunities live in poverty. Similarly, in Arizona, Latinos comprise more than 93% of the population of the border community ofNogales, approximately 45% of Yuma, 86% of Douglas, and 82%
of Naco. In Arizona, populations below the poverty line number
approximately 34% in Nogales, 15% in Yuma, 36% in Douglas,and 34% in Naco.
There are currently 563 federally recognized Native American
Indian tribes in the United States. Many are located on the borders.
Some may maintain cultural interests in the border region, and may
cross the borders for activities such as tribal ceremonies, funerals,
and the provision of health care. Appendix E lists federally recognized U.S. Native American tribes and their reservations that arelocated near or on the U.S. borders with Canada and Mexico. There
are also U.S. state-recognized tribes, as well as Native American
communities in Canada and Mexico.
30

WHTI Final Programmatic Environmental Assessment

Establishing the Baseline

Data Classes
Percent
7.5 - 10.4
10.9 - 12.8
13.0 - 15.6
16.5 -21.3
44.9 - 44.0

Source: U.S. Census (www.census.gov), 2007.
Figure 9
The percentage of people below poverty level in 2005 (for whom poverty status is determined)

WHTI Final Programmatic Environmental Assessment

31Establishing the Baseline

32

WHTI Final Programmatic Environmental Assessment

5.0 Methods and Drivers

This section describes the methodology used in the analysis of thealternatives and the characteristics of the alternatives under consideration that drive the effects on the environment.

5.2	What are the analytical methods used to determine
the potential for environmental impacts?
Qualitative methods are the primary means used in this PEA for
predicting potential environmental impacts associated with thealternatives. Scoping indicated that air quality was the environmental resource of most potential concern. For air quality, theanalysis is quantitative and represents a bounding analysis in which
the upper bounds of potential impacts are tested by looking at thepotential impacts under a worst-case scenario.

5.1 	Environmental Baseline — What is the affectedenvironment?
In 2003, the US-VISIT Program Management Office of DHS initiated and completed comprehensive surveys of the LPOEs along
the Northern and Southern Borders (US-VISIT, 2003a). Thesestudies provide a description of ecosystem components such as thenatural, physical, socioeconomic, and cultural assets of the portsof-entry. They also identify the sensitive resources that require
additional evaluation and consideration when taking actions at theports-of-entry.
The baseline studies were combined within eco-regions to provide a Strategic Environmental Appraisal (US-VISIT, 2003b).
The SEA approach considered resource sensitivities and potential
environmental consequences in an ecosystem context. The ecosystem approach represents a widely accepted scientific approachto analyzing biological and physical data, and for current purposes
provides a baseline for rapid identification of resources likely to beaffected by proposed actions.
These analyses provide the context and reference points for reviewing the potential environmental impacts to natural resources that
could be caused by implementation of the land phase of the WHTI
plan. These analyses also are used to provide context in examining potential cumulative effects. CBP continues to update thesecomprehensive surveys to maintain current information.
WHTI Final Programmatic Environmental Assessment

5.2.1

What are the stages of activity?
There are three stages of activity considered in this PEA:
1. Implementation Stage — This stage represents the transition from current operations to the implementation of the new
document requirements, along with associated changes toequipment, software, and procedures at LPOEs. Issuance of
documents, deployment of equipment and software, and implementation of training occur during this stage. Impacts identified
for this stage are assumed to be temporary in duration.
2. Early Operational Stage — This stage represents the first six
months of operations at the borders using documents requiredby WHTI and associated equipment, software, and processes
that may accompany the implementation of WHTI. This stage
represents the transition from the old ways of doing businessto the new ways, and requires public and institutional adjustments to comply with WHTI. Impacts identified for this stage
are assumed to be temporary in duration.
33

Methods and Drivers

3. Steady State Operational Stage — This stage represents organizational maturation in regard to new requirements associatedwith WHTI. By this point, the CBP workforce would havebecome accustomed to the new requirements, new processes,
and new procedures associated with WHTI. In addition, thetraveling public likely would have adapted to the system. Thus,
they likely would approach the border with an understandingof their role in making the border crossing run smoothly andefficiently (e.g., by having the appropriate identification document ready to be scanned at the appropriate location). Impact
levels at this stage governed the assessment of overall impacts
to each environmental resource.

in intensity and do not rise to a level of significance. Medium
impacts do not create effects that exceed statutory, regulatory,or policy thresholds, and can be mitigated.
High: High, in the context of this environmental assessment, means that actions or policies required to implement
the alternative likely would result in significant impacts on thequality of the human environment. The level of these impacts
is dependent upon the context and degree of intensity and on the
duration of changes and effects at the national level. A findingof high for some composite locations or during one of the stagesof activity would not necessarily result in significant impacts at
the programmatic or national level. High impacts are impacts
to a majority of ports-of-entry within the context appropriate toeach environmental resource, and that result from the actions
or policies that would yield intense impacts of a long duration
or would violate statutory, regulatory, or policy thresholds forenvironmental protection. High impacts at a programmaticor national level would result in a finding of significance andtherefore would require mitigation or the preparation of an
Environmental Impact Statement.

At a programmatic level, the Steady State Stage identifies thelong-term, overall impact. Other impacts that occur during the
Implementation and the Early Operational Stages are assumed to
be temporary in duration.

5.2.2

What are the levels of impact?
Due to the qualitative nature of the analysis, impacts also are categorized at one of three levels. Impacts can be either beneficial or
have adverse effects on the environment.
Low: Low, in the context of this environmental assessment,
means that actions or policies required to implement the alternative would result in few or no impacts on the quality of thehuman environment at a national level. These impacts do not
require mitigation and are well below statutory, regulatory, or
policy thresholds for environmental protection.
Medium: Medium, in the context of this environmental assessment, means that actions or policies required to implement thealternative would result in modest impacts on the environment
at a national level. These impacts are short in duration or low

34

These definitions are refined further in Appendix B for eachresource area to explain how the analysis for each environmental
resource is conducted.

5.3

What are the drivers for environmental impacts?
A number of factors required to implement the land phase of the
WHTI plan are the primary drivers for environmental changes or
impacts. These drivers, while not environmental impacts themselves, provide important information to help understand thepotential environmental impacts of each alternative.
WHTI Final Programmatic Environmental Assessment

Methods and Drivers

5.3.1	How much construction would be needed to implement
the alternatives?
Construction activity associated with the alternatives varies
depending on the technology, and is described below. In general,
construction activity increases as the alternatives become more
technologically sophisticated. The only exception to this trend is
the No-Action Alternative. Under this alternative, it is presumed
that existing problems with traffic conditions, limited inspection spaces, and limited queuing areas would result in moderate
upgrades and new construction. Overall, none of the alternatives
are likely to result in the need for major upgrades or substantial
new construction.
No-Action Alternative — Although no changes as a result of
WHTI would result in construction under this alternative, upgrades
and construction necessary to address existing and worsening space
limitations and traffic problems would continue to occur.
Standardized Documents Alternative — This alternative involves
the least amount of construction activity associated with the land
phase of the WHTI plan. The shift in requirements to a smaller number of standardized documents would not require any construction
activity at ports-of-entry.
Machine Readable Zone Alternative — Under this alternative
new MRZ readers may be installed inside the inspection booths,
but no new construction activity would be necessary.
Radio Frequency Identification Alternative — This alternativerequires the installation of RFID sensors (readers) across all lanes
at the busiest LPOEs (See Table 1). Although sensors currently
are present in some lanes, construction to install the RFID sensors and associated cabling on the other lanes would be required.
MRZ readers would continue to be available at the smaller LPOEs
WHTI Final Programmatic Environmental Assessment

Figure 10
Installation of RFID technology at a typical LPOE

35

Methods and Drivers

LPOE Traffic Definitions
For the purposes of this analysis, the following definitions
apply:
Flow.....................The dynamics of the vehicle throughput of
the LPOE: quantity, speed, and direction ofvehicles at the various stages
Patterns.................The design and structure of the port-ofentry for processing vehicles: number andlength of lanes, inspection booths, parking
facilities, and secondary-inspection vehicle
flow
Processing time....The amount of time spent by a vehicle inprimary inspection
Queue...................The line of vehicles waiting to approachor at the stop sign in front of the primary
inspection booth
Query-rate
percentage............The percentage of identification documents that are validated through electronic
databases
Volume.................The number of vehicles arriving at the
LPOE in a specified time period
Wait time..............The amount of time a vehicle must wait in
the queue (Also see definition in Section
4.0, Establishing the Baseline)
36

without RFID technology. Computer upgrades also may be necessary to accommodate the new technology. Sensor installation andcomputer upgrades are typical construction activities at LPOEs.
As seen in Figure 10, a relatively small hole is dug for the foundation and installation of the sensor base or support. Often, a small
trench is opened to allow installation of the conduit for the wires,
if the extant conduit will not accommodate the required cables.
Construction usually takes place one lane at a time during off-hours
or low-volume hours.
Overall, none of the action alternatives would result in the need forsignificant upgrades or substantial new construction.
5.3.2	What would happen to inbound traffic at the LPOEs as aresult of the land phase of the WHTI plan?

Background
Traffic is one of the primary attributes at LPOEs that can affectthe human environment. Automobile traffic is noisy, it produces
a variety of air emissions, and it can disrupt commerce and local
neighborhood activity, especially when backed up as vehicles wait
for the border-crossing inspection. The following discussion concerns only inbound POV traffic, the traffic that has the potential tobe affected by WHTI.
Traffic varies by port-or-entry, time of day, and time of year. At thebusiest LPOEs, traffic queues typically are longer than at smaller
LPOEs because the traffic volume generally exceeds the capacity of
the LPOEs to service the traffic under current inspection protocols.
The factors that lead to long traffic queues and wait times can be
categorized as external, port design, and management or operational
factors. External factors include the volume and vehicle mix of thearriving traffic. There also are seasonal, weekly, and daily traffic patWHTI Final Programmatic Environmental Assessment

Methods and Drivers

terns, which are outside the direct control of CBP. Within these local
and seasonal variations, however, trends in traffic occur over time. In
this analysis, this is referred to as the context of current variation.
LPOE design includes approach roadways, the number and lengthof lanes leading to the inspection booths, ergonomics and design ofthe booths, the layout and types of sensors, signage, traffic patterns
leading to secondary inspections, and egress patterns and roads leaving the port-inspection facilities. LPOE design is subject to various
limitations imposed by physical location, federal, state, and local
transportation agencies, permitting, and budgets.

Figure 11 shows, in a process diagram format, many of the major
factors and interrelationships that determine or affect private vehicle
wait times at LPOEs. Those factors that could be influenced orchanged by the implementation of WHTI are indicated in red. Those
factors that can be adjusted by CBP are indicated in black. Factorsthat are external to direct control by CBP are indicated in blue. As
shown, wait time and the resultant potential impact on environmental resources is the result of numerous interacting factors, only
a few of which have the potential to be affected by the land phaseof the WHTI plan.

What is the inbound traffic volume?
Management factors include human resources, information technology, and operational policies. Human resources include thenumbers, training, turnover, and organization of the LPOE staff.
Information technology is vital to the inspection process. Its responsiveness, accuracy, reliability, integration, and information flow to
the Officer is essential to the inspection. CBP policies and guidelines provide the working rules for the LPOE. Policies establish andinfluence factors, such as query rates, acceptable wait times, training
methods, and operational flexibility. Management factors pertaining specifically to operations are those actions at the port level that
directly affect traffic throughput, such as shift assignments, numbers of open lanes, special operations, overtime, and other factorsof the LPOE’s daily operation. The significance of management
factors in determining wait times was demonstrated by the 25%
Challenge in Detroit (Doan, 2006), in which changes in operational
procedures reduced wait times for U.S.-bound commercial traffic byas much as 71% at the busiest LPOEs.2 This substantial change inwait times resulting from management factors alone demonstrates
the influence that management decisions have on wait time. This isimportant because wait time is the key variable affecting environmental resources, such as air quality and noise.
2

The number of people crossing the U.S. borders has declined substantially since 2000 (Figure 12). For the purposes of the analysis
in this document, it is assumed that the volume of border crossingsat LPOEs would remain at current levels. Although some data suggest that traffic volume may initially decrease after the land phaseof the WHTI plan goes into effect, the use of current crossing levels is intended to provide a conservative estimate for the potential
environmental impacts of WHTI.
Approximately 58% of crossers on the Northern Border and 29%
of crossers on the Southern Border would be impacted by WHTI
(See Section 4.0, Establishing the Baseline). Everyone else would
continue to use the same documentation that they currently use:
passports, Border Crossing Cards, and Trusted Traveler Cards.
Thus, the inspection process does not change for 42% of crossers
on the Northern Border and 71% of crossers on the Southern Border(See Section 4.0, Establishing the Baseline).

 n December 17, 2004, Secretary Ridge and Canadian Deputy Prime Minister Anne McLellan met in Detroit and announced the “25% Challenge.” Its goal was to makeO
quantifiable improvements in the transit times and reduce traffic congestion by leveraging the resources and leadership of the bridge, tunnel, and ferry owners in southeasternMichigan—specifically, to reduce transit times by 25% within one year.

WHTI Final Programmatic Environmental Assessment

37

Methods and Drivers

PoliCIes and Operations• Inspection protocols• Documents accepted• Port operations• Lane management• Priorities

Primary andSecondaryInspection Output
for Port

Human Resources• Staff turnover• Training and experience• Staff resources• Manning decisions• Overtime policies

Vehicle Wait Time

Information Technology• Software design• Data quality• Inter-operability• Support

PHysical Infrastructure• LPOE design• State DOT’s policy and operations• MaintenanceTravelers• Traffic volume• Types of travelers• Individual’s admissibility• Documents presented

Environmental
Aspects

WHTI may affect
External to CBP direct control
Under CBP direct control

Figure 11
Causal factors that affect vehicle wait time in primary and secondary inspections at LPOEs

38

WHTI Final Programmatic Environmental Assessment

Methods and Drivers

What is the processing time?
Inbound Land Border Crossingsn Pedestrians
Pedestrians

450

POV
n POV

400

n Bus
Train

Bus

350
300
250
200
150
100
50
0
2000 2001 2002 2003 2004 2005 2006
Year
Figure 12
Inbound land-border crossings from 2000 to 2006

Processing Time–Wait Time RelationshipThe relationship of wait time to processing time is dependent on arrival rates of the traffic and the number of inspection lanes in operation.
This relationship typically is examined in computer simulations andis unique to each LPOE. However, holding the other parameters constant, relatively small decreases in processing time always will causesignificant decreases in queue length and wait times. This dynamic
is particularly pronounced for larger LPOEs with multiple inboundlanes in operation.
WHTI Final Programmatic Environmental Assessment

Of all the factors that determine vehicle queue length and wait
times, WHTI would affect only the inspection process at the primary
inspection booth. If traffic volume is constant and management andoperational factors are held constant for the purpose of the analysis,
wait time can be examined as a function of the processing time (i.e.,
the time a vehicle spends in primary inspection).
To analyze the effect of the various alternatives on processing time,
data collection teams visited LPOEs on both the Northern andSouthern Borders to interview inspectors and supervisors and observe
the current inspection process. The teams also reviewed the traffic
analysis model (Border Wizard) used by GSA and CBP to simulate
traffic flow through LPOEs (GSA, 2007a). CBP subject-matter experts
were requested to provide estimates of the variance in processing timefor each alternative technology (CBP, 2006b). The processing time
estimates for each alternative are based on the best available data foreach technology. The time-estimate rank order was corroborated during the field interviews (LPOE Site Visits, 2006-2007).
Currently, primary processing time can be as little as 10 seconds(Arcos, 2006) for a Trusted Traveler, or as long as 90 seconds (LPOE
Site Visits, 2006-2007) for an automobile with passengers who present documents that are not immediately credible to the inspecting
Officer. If the Officer cannot verify the identity and citizenship of allpassengers within 60 to 90 seconds, either through automated queryor a brief interview, the entering vehicle and passengers are directed tosecondary inspection (LPOE Site Visits, 2006-2007). The amount oftime this primary processing takes varies by LPOE, inspecting Officer,
and traveler. For a vehicle with multiple passengers and various
identification documents that cannot be immediately verified throughmanual or automated queries, CBP Officers report they may take 45
to 60 seconds, or longer. For easily verifiable travelers (who are notin a Trusted Traveler Program), the inspection may take as few as 20
seconds (LPOE Site Visits, 2006-2007). A traveler is easily verifiable,
39

Methods and Drivers

As would be anticipated from the multiplicity of factors describedin Figure 11, average processing times vary widely according to
the conditions and policies unique to each port-of-entry. Average
processing time varies in this selection of LPOEs from a low of
30.3 seconds to a high of 62.5 seconds, with an average of slightly
greater than 46 seconds (GSA, 2007a). For the purposes of comparison, a baseline of 45 seconds for standard LPOE processing
time is used.

for example, if he/she has a passport or equivalent that can be queried automatically with RFID technology or an MRZ reader.
CBP uses a simulation program called Border Wizard to model traffic
activity at LPOEs. Border Wizard is administered by GSA for CBP
and other interested agencies. Primary processing time is an input for
Border Wizard. GSA obtains processing time input by measuring theactual primary processing time at the particular LPOEs for which asimulation is to be run. Figure 13 depicts the measured average processing time at 11 LPOEs selected from the busier ports-of-entry,
over a period from May 2002 to December 2005.

The following estimated processing times for each alternative
provide an understandable benchmark for examining those environmental resources that are sensitive to vehicle queue length andwait times. These estimates are based on CBP field experienceand modeling data (CBP, 2006b; CBP, 2006e;
GSA, 2007a; LPOE Site Visits, 2006-2007).
The estimates apply only to noncommercial
25
vehicle inspections.

The processing time is depicted for both U.S. citizens and visitors.
Processing Timeat Selected LPOE
70
60

20

15

40
30

10

20

{POVper
per dayday (K)(POV(K)

Seconds

Seconds

50

5
10

rc
h

TA

Pe
ac
eA

Bl
ain
e

Pa
so
El

Co

BO

nv
en
t

a
let
Ys

Br
inb
ow

La
re
do

idg
e

ro
n
Hu
Ra

Po
rt

as

pla
in
Ch
am

le
ns
vil

Su
m

B&

go
lda
Br
ow

Hi

M
Ot
ay

M

0
es
a

0

US Citizens
Visitors
Traffic Vol

Considering the range of potential activities
that may result from WHTI, changes to processing times and related changes to wait times
have the most potential to alter the environment of the border. Aspects that could result
from traffic and wait-time variations include
changes to air quality, noise levels, and humanhealth, along with indirect impacts to energy,
water, biological resources, cultural resources,
and land use. In addition, traffic changes havethe potential to cause impacts to the environmental resources beyond the immediate
borders of the LPOE. In some instances, thesechanges may result in impacts that cross borders—or transboundary impacts (CEQ, 1997).
For example, air pollution is transported overFigure 13
Average processing times and traffic volume at selected LPOEs for U.S. citizens and visitors

40

WHTI Final Programmatic Environmental Assessment

Methods and Drivers

Process:

No-Action

Standardized Docs

MRZ

RFID**

Obtain Document

5 – 10 seconds

5 – 10 seconds

5 – 10 seconds

0 – 10 seconds

Query IT Database0 – 10 seconds

0 seconds(no IT query)

5 seconds(MRZ swipe)

0 seconds(pre-positioned)

Officer Inspection

20 – 30 seconds

10 – 20 seconds*

5 – 10 seconds

5 – 10 seconds

Return Document

5 – 10 seconds

5 – 10 seconds

5 – 10 seconds

0 – 10 seconds

Total Range

30 – 60 seconds †20 – 40 seconds

20 – 35 seconds

5 - 30 seconds

Average Time

45 seconds

30 seconds

27.5 seconds

17.5 seconds

Rank Order4
slowest3
faster2
faster1
fastestTable 2:The measured processing time (No-Action) and estimated processing time for the action alternatives* Assumes manual query for half the documents† Total Range time is the range of average GSA-measured times at specific ports-of-entry used for input to simulation runs. Elements of the inspection process of the NoAction Alternative are estimates based on that measured time.
**RFID in this instance is the use of RFID technology only for each step of the process.
No-Action

Standardized

MRZ

RFID

   

Slowest Processing Time

Fastest Processing Time

Figure 14
The alternatives rank-ordered by processing time.
Table 2 data were used to establish the relative rank order of the alternatives with respect to processing time. The alternatives are analyzed qualitatively using the rankorder shown.

WHTI Final Programmatic Environmental Assessment

41

Methods and Drivers

long distances and may cross political borders or be generated bytraffic that is backed up in Mexico or Canada.

What would happen to traffic and wait time under eachalternative?
The alternatives are expected to result in predictable impacts on
traffic and wait-time trends, and are summarized by alternative inTable 2, Figure 14, and the discussion below. These forecasts are
based on the following sources and policies:•

DHS and CBP guidance on processing and traffic, headquarters, regional and site-specific expert judgment, and data
including baseline and projected traffic models (CBP, 2006b;
CBP, 2006e; GSA, 2007a).

•

Site visits to LPOEs conducted specific to the environmental assessments of impacts of the implementation of WHTI
(LPOE Site Visits, 2006-2007).

For the No-Action Alternative, current wait times are not expected to decrease systematically in the absence of improvements tofacilitate trade and travel. As indicated in Figures 7 and 8, there isa distinct trend toward longer wait times at the busier LPOEs overthe last year. This trend is expected to continue in the absenceof significant improvements to current border processes. In addition, the No-Action Alternative assumes that improvements toinfrastructure and LPOEs would be needed because of current,
worsening deficiencies. No meaningful changes to traffic or wait
times at low-volume rural LPOEs would be expected.
The Standardized Documents Alternative is expected to facilitate
document assessments and admissibility decisions, thus speeding
inspection and processing. The standardization of documents would
improve the reliability of the documents as evidence of identity and42

citizenship and would improve CBP confidence in the documentissuance process. These changes would allow CBP Officers at the
LPOEs to make decisions about citizenship and admissibility fasterand more effectively. Following standardization, Officers would be
able to determine authenticity, as well as perform standard queries,
such as checking databases of criminal records, with more efficiency and accuracy. The decision to allow entry or require secondary
inspection could be made much more rapidly.
CBP Officers also affect wait times by making decisions about theamount of time to spend with each vehicle in primary inspection.
Wait times are monitored on an hourly basis and measures aretaken to reduce wait times when they reach benchmark ceilings.
Decisions about whether the wait times are too long for the LPOE
are made on a site-specific basis and take into consideration traffic
flow, staffing, security, and facilitation of travel and trade. As aresult of the improved ability to process standardized documents,
Officers could use their discretion to increase the number of visualinspections of documents and passengers per vehicle over current
rates. However, the increase in the number of visual inspections
would not be expected to undermine the improvements to processing time and wait time, as Officers would retain the discretion to
perform additional visual inspections
During the Early Operational Stage, there may be an initial
increase in the number of passengers sent to secondary inspection, as travelers may not be aware of the change in document
requirements, or travelers may be aware of the document requirements but for some reason may not have been able to obtainor locate a WHTI-compliant document prior to travel. At
some LPOEs, the backup of travelers and vehicles in secondary inspection could impede the traffic flow of the LPOE
(CBP, n.d.[b]).
To mitigate potential problems during the Early Operational Stage,
DHS and CBP are working aggressively to ensure that the public is
WHTI Final Programmatic Environmental Assessment

Methods and Drivers

educated regarding WHTI documentation requirements. In the WHTI air transportation implementation phase, for example, these efforts have included phased enforcement, public outreach,and the distribution of passport applications to travelers who may not have obtained a passport
in the past. The initial air phase of the WHTI plan went into effect January 23, 2007, obligating
all air travelers, regardless of age, to present a passport, NEXUS Air Card, or Merchant Mariner
Card for entry to the United States. An aggressive public outreach campaign aimed at increasingawareness of the new documentary requirements was a critical first step, as was working closelywith private industry and air carriers from the planning stages through implementation, in enforcing the new rules in a flexible and reasonable manner (Jacksta, 2007).
For the Northern Border, traffic flows and wait time are not expected to vary from current levels
during the implementation phase. During early operation, there could be some moderate increases
to traffic wait time at medium- and high-volume LPOEs, as travelers and Officers adjust to the
new requirements. Over time, the Standardized Documents Alternative are expected to resultin moderate decreases in average wait time at medium- and high-volume LPOEs.
For the Southern Border, the overall impact to traffic flows and wait time is expected to be lessthan on the Northern Border and similar to current trends in wait times due to the low percentageof traveler crossings (29%) affected by WHTI, as compared to the total volume of crossings (CBP,
2006b). Many of the busiest LPOEs currently stand at capacity for traffic flow (CBP, n.d.[b]) andmodest decreases to processing times for fewer than a third of all crossings are unlikely to havea significant impact on current wait times.
The MRZ Alternative also is expected to improve wait times and traffic flow by allowing Officers
to query documents with more efficiency. Currently, to query a document that does not have an
MRZ, a CBP Officer must manually type the text information into the computer. Documents with
MRZs reduce the time needed for Officers to query a document because the document can beswiped and queried automatically. MRZ-readable documents would be faster to process, and as
a result are expected to speed wait times and traffic flow over the Standardized Documents and
No-Action Alternatives. The ease of document processing may lead to an increase in the total
number of document queries because officers would have more time available to query documents.
However, this potential increase would be subject to Officer discretion and therefore, would not
be expected to impact traffic flows or wait times.

Traffic Flow is Dependent on
Type of Crossing and Volume of
Crossings of LPOEs
To the extent that a specific type oftraveler affected by changes to documentation crosses in greater proportions
at high-volume LPOEs, the resulting
change to wait times and traffic will
be relatively greater at high-volume
LPOEs due to the inherent relationshipbetween traffic volume and wait times.
For example, frequent travelers may
cross in higher percentages at highvolume LPOEs. If the frequent travelers have RFID-enabled documents, thehigh-volume LPOEs may experience agreater reduction in wait time as a resultof both the increase in the number oftravelers processing at faster speeds andthe compounding decrease in lines andwait times. Many low-volume LPOEs
currently do not have appreciable average wait times, and will not be impacted
as much as high-volume LPOEs by achange in processing and resulting wait
time and traffic. This dynamic applies
across alternatives.

During the Early Operational Stage, there could be an increase in referrals to secondary processing
for individuals who are not aware of the change in documents acceptable for crossing, or travelers
WHTI Final Programmatic Environmental Assessment

43

Methods and Drivers

The Impact of WHTI on Commercial Traffic
Potential changes to document requirements related to
WHTI are not expected to directly impact the document
requirements or processing procedures for commercial
traffic at either border. Commercial drivers are subject todifferent processing requirements than noncommercial drivers at the land borders. Processing commercial vehicles
takes considerably longer than processing POVs. Drivers
must present identification during the course of the normal
commercial inspection. Changes in these documents would
not affect total inspection times. Many commercial drivers
already possess passports or participate in the frequent traveler programs. It is highly unlikely that commercial traffic
would be affected directly by WHTI.
However, in some instances, changes to processing and wait
times for personal vehicles may impact commercial vehicles
if both types of vehicles are waiting in the same area. For
example, some LPOEs do not have dedicated lanes forcommercial traffic. At other LPOEs, the backup in primaryprocessing may also back up commercial traffic destined for
dedicated lanes (e.g., if all vehicles cross a single bridge toarrive at the LPOE). This is not a new dynamic factor. At
present, changes in wait time for private vehicles can affectcommercial wait time at certain LPOEs. Although a change
in processing times for commercial traffic is not expected,
this PEA considered the environmental impacts of potentialchanges to wait times for commercial vehicles that might becaused by a clogging of traffic flow at the LPOE.
44

may be aware of the document requirements but for some reason may nothave been able to obtain or locate a WHTI-compliant document prior totravel. At some LPOEs, the backup of passengers in secondary inspection could back up the traffic flow through the LPOE (CBP, n.d.[b]).
However, this would be a temporary and site-specific occurrence. As
stated previously, DHS and CBP are working aggressively to ensure thatthe public is educated regarding WHTI documentation requirements andthat processes are in place to determine the identity and citizenship of
all travelers crossing the border in all circumstances.
For the Northern Border, traffic flows and wait time are expected to staywithin current variation levels during implementation. During the Early
Operational Stage, moderate increases to traffic wait times at mediumand high-volume LPOEs are expected, as travelers and Officers adjust to
the new requirements. Over time, in the Steady State Stage, the MRZ
Alternative is expected to result in moderate decreases in average wait
times at the busiest LPOEs due to increased document credibility andprocessing efficiency.
For the Southern Border, the overall impact to traffic is expected to beless apparent and likely would fall within the context of current variationin wait times as a result of the low percentage of the travel population(29%) that would be affected by WHTI (CBP, 2006b).
The RFID Alternative is expected to improve traffic flow and wait times
by allowing the pre-positioning of traveler information to the Officer
before the traveler reaches the inspection booth (This occurs throughan automatic query of information for an individual.). An RFID scanner reads numbers from the RFID card, which initiates a query of CBP
databases to retrieve information on the individual that is transferred to
the CBP Officer’s workstation, thus saving the Officer the time required
to manually type or scan the document. This alternative is expected toprovide improvements to traffic flow and wait times over the No-Action,
Standardized Documents, and MRZ Alternatives.
In the Implementation and Early Operational Stages, the use of RFID
WHTI Final Programmatic Environmental Assessment

Methods and Drivers

technology may cause some episodes of system failure that could
impact processing and traffic flow. However, these incidents
are anticipated to be temporary and their frequency expected todecrease over time as systems are de-bugged. RFID technology
malfunctions also can be mitigated because in the event of system
failure, the Officer can use MRZ or can manually query the document to obtain information about the individual.

Particularly during the Implementation Stage, the use of RFID
technology also may increase the number of individuals sent tosecondary inspection due an increase in the number of databasehits, or identifications, of criminals or individuals with immigration
violations (whether true or false). At some LPOEs, the backup ofpassengers in secondary inspection could back up the traffic flow
through the LPOE (CBP Snapshots, n.d.). This is not expected tooccur at all LPOEs and is a site-specific constraint. Secondary
inspection backup is expected to decrease over time as operations
and procedures improve, individuals become aware of the requirements, and potential violators avoid crossing at the LPOE.
For the Northern Border, traffic is predicted to increase or decreasesimilar to current variation during the Implementation Stage of the
RFID Alternative. In other words, while some LPOEs may experience increases, others may experience decreases, which results
in no net change programmatically. During the Early Operational
WHTI Final Programmatic Environmental Assessment▼

There may be some potential increases to wait times in the
Implementation Stage at some LPOEs as CBP Officers undergo
training and become familiar with the RFID system. There also
may be some temporary changes to traffic flow as RFID sensors
are installed at the LPOEs during the Implementation Stage. CBP
and GSA, who own and operate the LPOEs, use procedures andguidelines to minimize the impacts to traffic during installationof technology. These mitigation techniques include performing
construction during non-peak hours and managing operations tofacilitate traffic through the LPOE.

Under the RFID alternative, an individual’s data will be transmitted to a CBP
Officer before the car arrives at the inspection booth.

45

Methods and Drivers

Stage, there could be some moderate increases to traffic wait timeat the busiest LPOEs as travelers and Officers adjust to the newrequirements. Over time, in the Steady State Stage, the RFID
Alternative is expected to result in moderate decreases in average
wait time for the busiest LPOEs on the Northern Border.
For the Southern Border, the overall impact to traffic is predicted
to be low and to fall within the context of current variation in wait
times as a result of the low percentage of travelers (29%) that are
affected by WHTI (CBP, 2006b).

46

WHTI Final Programmatic Environmental Assessment

6.0 What are the environmental resources that have a potential to benefit from or be adversely
impacted by implementation of WHTI?
6.1	Would any of the alternatives result in impacts to
air quality?
No-Action
Alternative

STAGE

Standardized
Documents
Alternative

MRZ
Alternative

RFID
Alternative

N-LOW

N-LOW

N-LOW

S-LOW
N-LOW

S-LOW
N-LOW

S-LOW
N-LOW

S-LOW
N-LOW

S-LOW
N-LOW

S-LOW
N-LOW

S-LOW

S-LOW

S-LOW

1. Implementation

N-Low
2. Early Operational

S-high

3. Steady State(For resource-specific definitions of low, medium, and high, see Appendix B.)

Table 3Air impacts by Implementation Stage and Border (Northern [N]/Southern [S])6.1.1 BackgroundAs discussed in Section 5.3.2, each of the alternatives has the potential to change wait time and traffic at border crossings. Changes tothe wait times for vehicles at LPOEs have the potential to impact
the total emissions released to the airshed. An airshed is an areathat shares the same air quality as a result of topography, meteorology, and climate. Vehicles produce air emissions of various
types, including carbon monoxide (CO), carbon dioxide (CO2),
nitrogen oxides (NOx), particulate matter (PM), volatile organic
compounds (VOCs), and toxic air pollutants such as benzene andtoluene. These air emissions have a range of potential effects onhuman health and the environment. A number of factors affectthe rate of emissions produced by vehicles. These factors include
vehicle type and size, vehicle age and mileage, fuel type, weather
WHTI Final Programmatic Environmental Assessment

conditions, maintenance of the vehicle, and the way the vehicle isdriven (driving, stop-and-go, idling) (EPA, 2005).
Under the Clean Air Act (CAA, 42 USC § 7401 et seq. [1970 as
amended]), minimum standards (de minimis levels) are set for“criteria air pollutants.” Regulated criteria air pollutants include
carbon monoxide (CO), nitrogen oxides (NOx), particulate matter(PM), and volatile organic compounds (VOCs) (EPA, 2007). If
these pollutants measure above a certain level, the area is considered to be in “nonattainment” for National Ambient Air Quality
Standards (NAAQS)(40 CFR Part 50-88). Maintenance areas arethose areas that have been in nonattainment but are now meetingthe minimum standards (40 CFR Part 50-88). If a federal action
in a nonattainment or maintenance area exceeds de minimis levels, then the responsible federal agency must prepare a conformity
determination to ensure that the federal agency conforms with theapplicable State Implementation Plan, or SIP (42 USC § 7401 et
seq. [1970 as amended]). In an area without a SIP, a federal action
can be shown to “conform” if there are no new violations of thestandards and/or no increase in the frequency or severity of previous violations. For this analysis, the CAA de minimis standard
is considered the primary threshold of significance for air quality
impacts from criteria air pollutants.
6.1.2 Analysis of Air Quality
For this PEA, an analysis was conducted on the potential for air
quality impacts as a result of changes to wait times at border crossings (GSRC, 2007a). The air quality analysis first assessed existing
conditions for wait times and air emissions at LPOEs using existing CBP wait time data and EPA standard emission factors (GSRC,
47

Environmental Resources of Concern

2007a). The air quality analysis then evaluated the results of a10%, 20%, and 30% increase in wait times for LPOEs (GSRC,
2007a). As discussed in the Traffic section (5.3.2), it is assumed
that implementation of any of the action alternatives will have alimited impact on the processing and wait times for commercial
traffic. However, to be conservative with the analysis, the 10%,
20%, and 30% scenarios included an increase for both privately
owned vehicles (POVs) and commercial vehicles (COMs). The
vehicle numbers and wait times for COMs were notably lower thanfor POVs. In fact, POVs accounted for 95% of the total minutes
waited and total emissions (Department of Transportation, n.d.)
The air quality analysis showed that wait times and air emissions
are highest at high-volume crossings on the Southern Border(Figure 15). Several of the high-volume LPOEs on the Southern
Border are located in the vicinity of large cities, and the surrounding
areas currently are designated as nonattainment for NAAQS and in
violation of Mexican national standards as well (CEC, 2004). In
some instances, increases to wait time at high-volume LPOEs on
the Southern Border could result in vehicle emissions that exceed
de minimis criteria for CO. This analysis showed that existing
emissions for these high-volume LPOEs on the Southern Border
are already above de minimis standards (Figure 16). Any increase
to wait time at these sites has the potential to further exceed deminimis criteria due to the magnitude of the number of vehicles
that cross and idle at these sites.
The analysis also showed that none of the assessed changes to wait
times at border crossings on the Northern Border would result inexceeding de minimis criteria for any of the pollutants evaluated forthis analysis, even for a 30% increase in wait times and resulting
emissions (Figure 17). In fact, if the emissions for all crossingsalong the Canadian border were added together, they still would
not exceed de minimis thresholds for any of the criteria pollutants
under a 30% increase in wait times.
48

6.1.3

Potential Impacts
For the No-Action Alternative, wait times generally are expected
to increase because needed improvements to border processes andinfrastructure would not be implemented. An analysis of current
levels of air pollution at LPOEs indicates that current wait times
at the border crossings, except at certain medium- and high-volume LPOEs on the Southern Border, are not causing the levelsof emissions to exceed the established air quality standards. At
high-volume LPOEs on the Southern Border, some violations ofde minimis standards for CO for an airshed may be possible if wait
times continue to increase. These sites may experience high levelsof CO when wait times are the longest, especially if wait times continue to follow the predicted trend of increase. At a programmaticlevel, the No-Action Alternative is rated low for impacts on air
quality on the Northern Border, and high for impacts on air quality
on the Southern Border (Table 3). The Southern Border is rated
high due to the CO impact to air quality at high-volume LPOEs.
At a programmatic level for each of the action alternatives(Standardized Documents, MRZ, and RFID), there would beminor beneficial impacts to the levels of emissions as a result ofsmall to moderate improvements in traffic and wait times. Thisfinding is consistent with the results of the wait time analysis andair analysis conducted for this PEA. Small to moderate changes intraffic wait times would not critically impact the level of air emissions and the ability of sites to meet air quality standards. This
dynamic is consistent across alternatives, stages of implementation, and borders. Moderate short-term changes to traffic patterns
under any of the alternatives considered for this analysis also areunlikely to appreciably impact the current levels of air emissions
at the borders. The exception, as discussed above, is CO at somemedium- and high-volume sites on the Southern Border, which
would continue to have high levels of emissions with site-specificimpacts. Over time, the levels of wait time would improve at thesehigh-volume LPOEs, but this dynamic is unlikely to impact the
WHTI Final Programmatic Environmental Assessment

Environmental Resources of Concern

100.00

Vehicle Emissions (tons/year)

50.00

—30%
—20%
—10%
CO
—30%
—20%
—10%
NOx
—30%
—20%
—10%
VOCs
—30%
—20%
—10%
PM10
—30%
—20%
PM2.5
—10%

AZ
County,Cochisek County, TX

n County, AZ

Maveric

unty, AZ

Cameronty, TX

Yuma Co

TX

Webb C
ou

County,TXnty, AZ

Hidalgoruz Cou

County,Santa CEl Pasounty, CA

Valley CoImperial

San Diego County, CA

0.00

Pollutant Emissions by %Change to Wait Time

Figure 15
The relationship between vehicle emissions and wait times at LPOEs by county on the Southern Border

WHTI Final Programmatic Environmental Assessment

49

Environmental Resources of Concern

2000.00

CO Emissions(tons/year)

30% Increase
20% Increase
10% Increase

AZ

Wait TimeCounty,30% Decrease% Change to Current

Cochisek County, TX
Maveric

n County, AZ

20% Decrease

Camerounty, AZ
Yuma Conty, TX
Webb C
ou

County,TX

Current Levels
10% Decrease

Hidalgonty, AZ
ruz Cou
Santa C

TX
County,El Pasounty, CA
Valley CoImperial

San Diego hCounty, CA

0.00

Figure 16
The relationship between vehicle CO emissions and wait times at LPOEs by county on the Southern Border

50

WHTI Final Programmatic Environmental Assessment

Environmental Resources of Concern

100.00

Vehicle Emissions (tons/year)

50.00

—30%
—20%
CO
—10%
—30%
—20%
NOx
—10%
—30%
—20%
VOCs
—10%
—30%
Pollutant Emissions by %
—20%
PM10
Change to Wait Time
—10%
—30%
PM2.5
—20%
—10%

unty, MTVTCounty,Toole CoFranklinn County, ME

WashingtoY
n County, NY

ounty, N

Jefferso

Clinton C

a County, MIMI

nty, NY

Chippew

Erie Cou

County,unty, MI

St. Clair

Wayne Co

Whatcom

County,WA

0.00

Figure 17
The relationship between vehicle emissions and wait times at LPOEs by county on the Northern Border

WHTI Final Programmatic Environmental Assessment

51

Environmental Resources of Concern

overall volume of traffic, emissions production, and attainment status of these LPOEs. At a programmatic level, the action alternatives
are rated low for air impacts because the decrease in wait time thatis predicted as a result of WHTI would result in a small decrease,or a limited change, to current emissions.

Climate Change and WHTI
Climate change has been recognized as a global environmental effect (Department of State, 2007b). The
Intergovernmental Panel on Climate Change (IPCC)
released its most recent report in February 2007 on thephysical science basis of climate change. It summarized the human and natural drivers of climate change,
including definitive evidence of impacts via humanactivities on global climate change (IPCC, 2007).
Programs such as WHTI, which potentially benefit the
movement of vehicle traffic and reduce vehicle wait
times, have the potential, however slight, to reduce
harmful greenhouse gas emissions as recognized byinternational policies, such as the Kyoto Protocol(United Nations Framework Convention on Climate
Change, 1997). While reduction in vehicle emissions
alone as a result of WHTI would bring little overall
benefit to reducing the production of greenhouse gases
worldwide, to the extent that activities and operations
reduce the vehicle wait times at ports-of-entry, then thepotential for reducing greenhouse gas emissions fromvehicle queues at the LPOEs may increase.

6.1.4

Cumulative Impacts Related to Air Quality
The purpose of cumulative impacts analysis is to ensure that federal agencies fully consider the range of consequences of theiractions. This PEA supports this approach by looking at potential
impacts on a broad scale and incorporating a bounding analysis thatconsiders the impact on airsheds, rather than limiting the analysis to specific LPOEs. Additionally, cumulative-impacts analysis
requires an examination of past, present, and reasonably foreseeable actions that may contribute to related environmental impacts
on the resource.
Air pollution along the border historically has been a problem
only in large urban areas where the volume of traffic and travelers
crossing the border has outpaced the ability of the border inspection facilities and road infrastructure to accommodate this growth.
In some areas, these problems have contributed to a violation ofstandards, including NAAQS and the counterpart regulations in
Canada and Mexico. Other factors, such as pollution from sourcesin metropolitan areas near the LPOEs, also have contributed to these
existing problems.
Traffic volume at the borders is expected to remain constant in theforeseeable future. Therefore, traffic volume should not contributeto any cumulative impacts on air quality .
Improvements in the fuel efficiency of vehicles in the foreseeable
future, such as an increase in the use of hybrid vehicles, may help
to lessen the severity of existing air quality problems. All of theaction alternatives are expected to slightly decrease wait time at

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Environmental Resources of Concern

the LPOEs, and with the combination of more efficient vehicles
and no expected changes to traffic volume, should help to further
improve air quality. However, these improvements are site-specific in nature and are unlikely to vastly improve the overall air
quality for the airshed. Additionally, these improvements must be
counterbalanced against the potential for adverse impacts to wait
time (and therefore air quality) that may result from other bordersecurity programs and border planning initiatives. For example,
an increase in the number of documents queried as a result of the
Securing America’s Borders Initiative (CBP, 2006a) could have acountervailing effect on wait times and could mean that air quality
conditions would remain status quo. To the extent that additional
border planning initiatives are implemented in a way that facilitates inspection processing and improves vehicle wait times at the
LPOEs, there is a greater potential to improve air quality.

6.1.5 Transboundary Impacts Related to Air Quality
Air emissions may have transboundary impacts, or impacts thatcross borders. The predicted levels of impact of the proposed
alternatives apply to communities in the United States, Canada,
and Mexico. Although CBP border processing is implemented in
the United States, traffic may back up into Mexico or Canada, andair pollutants may be carried into Mexico or Canada by wind currents. The predicted levels of impact of the alternatives apply tocommunities in the United States, Canada, and Mexico. However,none of the action alternatives are predicted to result in significant
increases to wait times and air pollution at a programmatic level.
As a result, the air quality impacts of the action alternatives will beminimal or beneficial at a programmatic level as compared to the
No-Action Alternative, whether considering the impact to communities in the United States, Canada, or Mexico.

6.2	Would any of the alternatives result in noise levels
that are disruptive to border communities?
6.2.1

Background
Noise is an impact of concern for LPOEs near sensitive noise receptors as identified in the US-VISIT comprehensive environmental
surveys (US-VISIT, 2003a). Noise levels are a primary concern
for medium- and high-volume LPOEs. Of the 50 largest LPOEs,
39 were identified as having sensitive noise receptors that could
experience potential impacts as a result of an increase to idlingnoise due to future undertakings at the LPOEs. Of these LPOEs,
13 were located on the Northern Border and 26 were located on theSouthern Border (GSRC, 2007b).

As vehicles wait in line to be inspected at LPOEs,
the engines produce air emissions.

WHTI Final Programmatic Environmental Assessment

The US-VISIT Program also conducted a noise study to determine
whether the sensitive noise receptors identified in the US-VISIT
surveys were experiencing noise levels exceeding noise criteria
due to LPOE traffic (US-VISIT, 2006). Criteria relied upon in the
US-VISIT study also apply to the land phase of the WHTI plan
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Environmental Resources of Concern

No-Action
Alternative

STAGE

Standardized
Documents
Alternative

MRZ
Alternative

RFID
Alternative

N-LOW

N-LOW

N-LOW

S-LOW

S-LOW

S-LOW

N-HighN-HighN-High

S-LOW

S-LOW

S-LOW

N-LOW

N-LOW

N-LOW

S-LOW

S-LOW

S-LOW

1. Implementation

N-HIGH
2. Early Operational

S-high

3. Steady State

cesses reduce wait times, there would be fewer violations of noise
criteria and fewer noise impacts to communities at the border. Achange in the amount of commercial-traffic idling would have agreater impact on the noise level than a change in the amount ofpassenger-traffic idling (GSRC, 2007b). Nevertheless, all types ofhighway traffic have the potential to produce noise that may reacha level of concern. To the extent that changes to wait times impact
commercial traffic, the impacts to noise would be greater than theywould at sites where passenger traffic only is affected. For further
discussion of the impacts to commercial traffic as a result of WHTI,
see the Text Box in the Traffic section.

(For resource-specific definitions of low, medium, and high, see Appendix B.)

Table 4
Noise impacts by Implementation Stage and Border(Northern [N]/Southern [S])(GSRC, 2007b). The study was intended to assist with futureplanning efforts and NEPA analyses for implementation of new initiatives at the LPOEs. Standards for highway noise are establishedby state Departments of Transportation (DOTs) with approval by
the Federal Highway Administration (FHWA) (Federal Highway
Standards, 23 CFR Part 772). The US-VISIT study (2006) foundthat increases to traffic at LPOEs with sensitive noise receptors
may result in an increase in the number of violations of the FHWA
and DOT standards.
Noise is particularly an issue at LPOEs with high traffic volumes.
However, impacts at low-volume LPOEs with sensitive noise receptors (such as a neighborhood or school near a LPOE) also are possible.
Although commercial trucks produce more noise than private vehicles, the noise produced by all types of idling traffic is a concern if
there are communities located near the queue of a LPOE.
6.2.2

Potential Impacts
To the extent that changes to documentation requirements and pro-54

For the No-Action Alternative, traffic and wait times at the bordercurrently result in significant impacts to noise at certain highvolume LPOEs with sensitive noise receptors. Because of these
impacts and the predicted ongoing increase to wait times for the NoAction Alternative, it is likely that noise impacts would continue
to worsen at medium- and high-volume LPOEs on both borders.
While low-volume rural ports-of-entry also could have sensitivenoise receptors, no changes to traffic at these LPOEs are expected.
Therefore, noise levels would not change.
For each of the action alternatives (Standardized Documents,
MRZ, and RFID) traffic for the Southern Border is predicted to fallwithin the context of current variation because of the small percentage of travelers affected (29%) (CBP, 2006b). This means that no
meaningful changes to traffic or wait time at these LPOEs would
be expected. As a result, all of the action alternatives will result in
low impacts to noise on the Southern Border (Table 4).
For the Northern Border, more measurable changes to traffic are
predicted for each of the action alternatives because of the relatively
large percentage (58%) of crossers affected by WHTI (CBP, 2006b,
Industry Canada, 2006). In the short term, changes to border processing may result in some site-specific increases in traffic and wait times
in the Early Operational Stage for each of the action alternatives. As
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Environmental Resources of Concern

New Document Requirements:
The Travelers’ Response
Canadians already are adapting to thechanging security demands in the UnitedStates in anticipation of the change indocument requirements. According to
the Auditor General of Canada Report(2007), “During 2005–06, Passport
Canada processed an unprecedented
3 million passports. In comparison, it
processed about 2.7 million passports
in 2004–05 and 1.7 million in 2001–02.
Passport Canada forecasts growth to
3.8 million passports by 2008–09.”
As vehicles wait in line to be inspected at LPOEs,
the engines produce noise.

a result, the action alternatives are predicted to have high impacts to noise because the levels exceed
noise criteria at sensitive sites near medium- and high-volume LPOEs on the Northern Border for the
Early Operational Stage. However, these impacts will be short-term in duration. In the Steady State
Stage, each of the action alternatives is predicted to result in no or slight improvements to traffic and,
therefore, low impacts to noise on a programmatic level for each stage (Table 4).

6.2.3 Cumulative Impacts Related to Noise Pollution
Similar to air quality, noise pollution historically has been a problem in those communities adjacent
to busier LPOEs. Noise pollution is a localized issue that does not result in regional- or nationallevel impacts. Existing noise levels in some typical urban LPOE communities range from 40 to 70
dba (decibels) (US-VISIT, 2006). A noise level of 40 dba is equivalent to a quiet urban nighttime
setting, whereas 70 dba represents sound levels that are similar to an outdoor commercial area.
WHTI Final Programmatic Environmental Assessment

U.S. residents also have been adapting
to the WHTI Air Rule, which required
passports of travelers starting in 2007.
Passport offices currently are experiencing delays in processing applications. However, the Department ofState plans to hire an additional 400
passport adjudicators by the end of
2008. In addition, a new passport
center opened in Arkansas in April(Department of State, 2007a). These
efforts should reduce current delays in
the issuance of passports.

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Environmental Resources of Concern

Noise pollution at LPOEs results from traffic noise and periodic
construction upgrades necessary to maintain or upgrade the LPOE.
Traffic volume is anticipated to stay the same under all alternatives.
Therefore, traffic volume will not contribute to any cumulative
impacts to noise. However, as with air quality, any benefits to noise
pollution from decreases in wait time must be counterbalanced by
the potential for increases to wait time as a result of new border-security measures or planning initiatives. Additional noise from planned
construction projects at the LPOEs would not result in cumulative
noise impacts, as these are common occurrences at the LPOEs andare temporary in nature.
6.2.4

Transboundary Impacts Related to Noise Pollution
Noise levels may have transboundary impacts or impacts that crossborders. The predicted levels of impact of the proposed alternatives
apply to communities in the United States, Canada, and Mexico.
Although the land phase of the WHTI plan is being implemented
in the United States, traffic may back up into Mexico or Canada,or traffic on one side of the border may be heard in communities
on the other side of the border. However, none of the action alternatives are predicted to result in increases to wait times and noiselevels at a programmatic level. As a result, the noise impacts of
the action alternatives are expected to be minimal or positive at a
programmatic level, as compared to the No-Action Alternative,
whether considering the impact to communities in the UnitedStates, Canada, or Mexico.

6.3	What is the Potential for Effects on Social andCultural Practices in Border Communities?
6.3.1

Background
Public involvement efforts for this PEA identified a concern withthe economic effects to trade and commerce, the cost to low-income
people of acquiring new travel documents, and the disruption ofsocial patterns along the borders. CBP considered the economic

56

effects of WHTI in the Regulatory Assessment for the Notice of
Proposed Rulemaking. The potential for other effects on social andcultural practices are evaluated in this PEA.
6.3.2 Potential Impacts
No-Action Alternative – The No-Action Alternative assumes
that current processes for crossing the border would continue.
Therefore, there would be no potential for effect on social or cultural practices in border communities if this alternative is chosen.
The current acceptance of a broad range of evidence from U.S.
and Canadian border crossers generally allows some numbers ofindividuals to cross the border with minimal restrictions, using oral
declarations or choosing from literally thousands of documents
when crossing the border at the designated LPOEs.
Other Alternatives Under WHTI – It is anticipated that during
the Implementation and Early Operational Stages of the land phaseof the WHTI plan, there could be temporary disruption to social
patterns along both land borders as border crossers become knowledgeable about which documents will be accepted. Since both the
Departments of State and Homeland Security intend to engage inactive outreach for the land and sea portion of the WHTI plan,much like that for the air travel portion, these temporary effects are
expected to have a minor impact.
The implementation of WHTI would place the same requirementson all segments of the traveler population that would need to obtain
new identification documents. Minorities, American Indian tribes,
shoppers, tourists, the impoverished, and the wealthy would all
have to meet the same requirements for whatever documents are
determined suitable for implementation of WHTI. Executive Order
12898 requires federal agencies to consider environmental justice impacts when there is the potential for disproportionate highand adverse environmental or human health effects of a projector policy on low-income and minority populations. There is no
physical environmental impact on any of these populations. With
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Environmental Resources of Concern

regard to human health impacts, there are also no direct impacts tohuman health from the implementation of WHTI. It is conceivable
there are indirect impacts to human health if particular individuals
no longer cross the border because of a lack of the proper documentation under WHTI. However, any such impacts are merely
speculative, as we have no specific evidence of significant numbers of individuals who cross the border only for this purpose andno specific evidence that any who do cross the border to obtainhealth care could not obtain the documents determined appropriate
under WHTI. Consequently, environmental justice impacts are notexpected, as there would be no high and adverse environmental or
health effects causing disproportionate impacts to low-income orminority populations.
6.3.3 	Potential for Cumulative Impacts on Social and Cultural
Practices in Border Communities
Border Communities
Section 7209 of the Intelligence Reform and Terrorism Prevention
Act of 2004 (IRTPA) requires that the Secretary of Homeland
Security, in consultation with the Secretary of State, develop andimplement a plan to require travelers entering the United States topresent a passport, other document, or combination of documents,that are “deemed by the Secretary of Homeland Security to be sufficient to denote identity and citizenship.” To the extent that bordercrossers are currently presenting documents which do not denote
identity and citizenship, or to the extent they are crossing with oral
declarations, there may be some effect on patterns of crossing theborder. As stated previously, both the Departments of State andHomeland Security intend to engage in active outreach for the landand sea portion of the WHTI plan, much like that for the air portion.
As a result, this effect is expected to be temporary until travelers
obtain documents which are compliant with the IRTPA. Therefore,
there is no expected potential for cumulative effect on social and
WHTI Final Programmatic Environmental Assessment

cultural practices in border communities from implementation of
the land and sea portion of the WHTI plan.
Native American Tribal Lands
To fully assess the potential for cumulative effects on Native
American tribes, it is important to assess whether there is potential for a relationship between the implementation of WHTI andillegal alien crossings of tribal lands. These illegal crossings are asignificant concern to tribes. Tribes report that illegal aliens havedamaged traditional sacred sites and burial grounds and adversely
affected cultural practices, such as the gathering of traditional
plants and materials. Tribes indicate that the number of illegal aliencrossings has been increasing and this appears to be associated withincreased border security measures on non-tribal property. Overtime, tribes have experienced an increased need for, and cost of,tribal law enforcement activities. To the extent that WHTI provides
increased security at LPOEs and enforcement activities in between
the LPOEs increase in an effort to deter illegal immigration, more
illegal immigrants may seek to access the United States throughtribal lands. While it is difficult to quantify the scale of this potential impact and equally difficult to determine the portion that may
be associated with WHTI, to the extent that it does occur, cultural
resources could be adversely affected. This problem would not differ across the action alternatives (Standardized, MRZ, and RFID)
of WHTI, implementation of which is required by law.

57

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WHTI Final Programmatic Environmental Assessment

7.0 W hat are the environmental resources not likely to be impacted by WHTI?

Generally, impacts to the environmental resources analyzed inthis section are driven by factors that have been found not to differ substantially by alternative or geographic area. Impacts to theresources in this area have been determined to be minimal or zeroacross all alternatives.

7.1

Human Health and Safety
Human health effects occur in a variety of forms, such as exposure
to chemicals, temperature, work conditions, and physical security
and safety. Current health and safety conditions at LPOEs are managed in accordance with agency regulations. Harm to Officers andthe public is minimized by using approved procedures and designs.
The impacts of each alternative on health and safety were investigated but, due to the general improvement of vehicle wait times
and resulting improvements in air quality and the low potential
for adverse exposure to the Officers or public with RFID technology (US-VISIT, 2005b), no human health and safety impacts are
expected.

7.2

would use currently available facilities and equipment. The RFID
Alternative could require a moderately higher amount of energy
for additional technology such as RFID sensors and computer processing. This requirement could potentially impact certain LPOEs
with constraints on current energy levels. However, this impact
is site-specific and not significant on a programmatic level due tothe small number of facilities with these constraints. Furthermore,
implementation of the RFID Alternative is likely only for the busiest LPOEs. Most of the LPOEs with existing energy constraints
are smaller LPOEs in rural locations.

EnergyCurrent energy use at LPOEs includes energy for facility management and for technology such as computers and RFID. Vehicles also
consume energy in the process of crossing or idling at LPOEs. These
activities are governed by Executive Order 13423, Strengthening
Federal Environmental, Energy, and Transportation Management(2007). In terms of LPOEs, the Standardized Documents and
MRZ Alternatives generally would require the same amount ofenergy as the No-Action Alternative, because these alternatives

WHTI Final Programmatic Environmental Assessment

For all of the action alternatives, the energy consumed by changes
to equipment and vehicle wait times is minimal and expected to beless than the No-Action Alternative. In conclusion, there is little
to no potential to significantly impact the environment by the useof energy for these alternatives.

7.3

Land Use
The land phase of the WHTI plan is not expected to affect land
use in the vicinity of the LPOEs because the change in processing
associated with the alternatives will have a modest benefit in wait
times and associated traffic flow. Since the land phase of the WHTI
plan is not expected to impact the environment adversely and would
have only modest benefits to traffic flow, there would be no land-use
impacts associated with any of the action alternatives. The land
phase of the WHTI plan, by requiring better documentation to enterthe United States, could affect illegal migration. Changes in patterns of illegal migration possibly could affect land use in remoteareas such as Indian Reservations, ranches, and federal lands. At anational level, these impacts are expected to be low.
59

Environmental Resources Not Likely to be Impacted by WHTI

7.4.

action alternatives would be disposed or recycled in accordancewith current DHS policies requiring proper handling and disposalof solid waste.

Waste Impacts
The federal government’s responsibility for the reduction ofwaste is mandated by Executive Order 13423: Strengthening
Federal Environmental, Energy, and Transportation Management(2007). Technology advances have the potential to result in electronic waste, as new technology is installed and older systems are
replaced. Electronic waste (e.g., computers, printers, and monitors) is important to investigate because the potential for toxins
to be leached into the environment is high if electronics are notdisposed of properly. The volume of obsolete equipment requiring disposal and the method of disposal determines whether waste
impacts would be significant. The impacts of each alternative on
waste were investigated, but because of the relatively minor construction activities and equipment replacements associated witheach alternative, no solid waste or adverse electronic waste are
expected. Any waste that is generated from implementation of the

7.5

Water Resources
Water resources may be affected by federal activities directly
through point-source pollution (e.g., chemical releases via pipes
into water bodies) or indirectly through non-point-source pollution(e.g., runoff from impervious surfaces, atmospheric deposition).
For purposes of this analysis, the potential to increase impervious
surfaces and atmospheric deposition was considered as it relates
to potential construction activities or air quality impacts resulting
from the action alternatives in comparison to the No-Action. The
impacts of each alternative on water resources were investigated.
Due to the relatively minor construction activities and runoff asso-

Source: Treehugger.com.
Electronics have the potential to pile up in landfills unlessproperly recycled.

60

At some LPOEs, water resources are located directly
adjacent to the LPOE property.

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Environmental Resources Not Likely to be Impacted by WHTI

ciated with each alternative and the expected general improvement of vehicle wait times,
and an associated low impact on air quality and atmospheric deposition, no water resource
impacts are expected.

7.6

Indirect Impacts to Sensitive
Ecosystems via Illegal Immigration

Biological Resources

Along the Southern Border, illegal immigration

Impacts to biological resources can occur directly when habitats are disturbed or
destroyed, or indirectly, through changes to food and water. The impacts of each alternative on biological resources were investigated, but because of the relatively minor
construction activities associated with each alternative and the general improvement ofvehicle wait times expected to have a low impact on air quality, no biological resource
impacts are anticipated.

for their potential to adversely impact biologicaland Border Patrol operations have been recognized
habitats and species in the fragile ecosystems of
the Arizona deserts. The U.S.–Mexican politicalboundary, like most political boundaries, does notfollow the boundaries of natural ecological systems. Rather, it crosses habitats of wide-ranging
species, such as the recovered Mexican gray wolf,and passes through sensitive ecosystems, such as
the Sky Islands ecosystem. Along this politicalborder, enforcement activities to combat illegal
immigration, as well as illegal immigration itself(e.g., dirt roads, litter), have widely impacted
these sensitive ecosystems. It is anticipated thatto the extent that security policies such as WHTI
are implemented at the LPOEs, there may bepotential for border-security activities in between
the LPOEs to increase as stricter security policies
are implemented. However, when examined on a
programmatic scale, the biological impacts due tothis dynamic are predicted to be low and are sitespecific in nature. Short-term and long-term policy
and operational measures implemented between
the LPOEs can help mitigate any potential sitespecific impacts to sensitive biological habitats

The Mexican gray wolf (Canis lupus baileyi) is an endangered species whose range spans the vast
political border between Mexico and the United States.

WHTI Final Programmatic Environmental Assessment

and resources.
61Environmental Resources Not Likely to be Impacted by WHTI

7.7

Historic Properties
Historic properties are defined in the National Historic Preservation
Act (NHPA) of 1966 (as amended), and include “districts, sites,
buildings, structures, and objects significant in American history,architecture, archaeology, engineering, and culture.” The NHPA
requires all federal agencies to consider the potential for adverse
impacts to historic properties as a result of their actions.
A number of the LPOEs where WHTI would be implemented
are considered to be historic or eligible for listing in the National
Register of Historic Places. Some of these LPOEs were designed
and built in the 1930s and early 1940s as part of an ongoing effort
to modernize and standardize LPOE facilities. The LPOEs of thisera typically were built according to one of five standard designs.
As a result, there are many similar buildings in different areas of

the country. However, due to ongoing changes to the LPOEs, somebuildings have been demolished or changed so significantly overtime as to have lost their historic characteristics.
The major categories of historic properties that could be affectedby the implementation of WHTI are the historic buildings andstructures located at many of the LPOEs. Changes to the buildings
due to improvements, demolition, or new construction could resultin adverse impacts. WHTI-related changes to historic properties
would occur with the installation of equipment on the outside ofbuildings (e.g., RFID sensors and cables) or the inside of buildings(e.g., computers). However, none of the alternatives contemplated
under WHTI would result in construction or modifications to the
LPOE buildings. Therefore, there is no potential for impact tohistoric properties.

Some LPOEs are listed or eligible for listing in the National Register of Historic Places.

62

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Environmental Resources Not Likely to be Impacted by WHTI

AIR QUALITY• Potential to improve air quality slightly in someareas, mainly on the Northern Border, across allalternatives

WASTE• No potential to impact solid waste• No potential to impact electronic waste

NOISE POLLUTION• Potential to improve noise levels slightly in someareas across all alternatives

WATER• No potential to impact through runoff• No potential to impact throughatmospheric deposition

SOCIAL AND CULTURAL PRACTICES• No potential to result in disproportionately highand adverse environmental or health impacts on
low-income or minority populations

BIOLOGICAL RESOURCES• No potential to disrupt or destroy habitat• No potential to affect food and water
through air or water impacts

ENERGY• No potential to substantially increase current
levels of energy consumption• No potential to compromise the ability of LPOEs
or border communities to meet energy needs

HEALTH AND SAFETY• No potential to impact through air quality• No potential to impact through newtechnology upgrades

LAND USE• No land use impacts associated with any of thealternatives

HISTORIC PROPERTIES• No potential to impact due to limited/no
construction

Summary of Environmental Impacts by Resource for the Action Alternatives

WHTI Final Programmatic Environmental Assessment

63

Environmental Resources Not Likely to be Impacted by WHTI

64

WHTI Final Programmatic Environmental Assessment

8.0 How would implementation of WHTI at sea ports-of-entry and for recreational
craft impact environmental resources?

8.1

Background
Cruise ship passengers and crew must go through CBP inspection processing upon the cruise ship’s arrival in the United States.
Similarly, boat captains and passengers of pleasure craft are also
required to report their arrival into the United States. CBP operates
at sea ports throughout the country, most of which are located instates along the East and West coasts of the United States, althoughsmaller ports do operate along the Great Lakes on the border with
Canada and within the Gulf Coast states (Figure 18).

2

1

3

1. Vancouver, Canada

In 2005, 9.7 million passengers embarked on cruise voyages from
U.S. sea ports to destinations within and beyond the Western
Hemisphere (MARAD, 2006). Today, differences exist among thekinds of documentation required for entry into the United States,
based upon the destination of the cruise. The current regulatory
requirements for cruise passengers traveling outside of the Western
Hemisphere (e.g., South America, South Pacific/Far East) are thepresentation of a passport for CBP inspection upon entry into theUnited States. Therefore, it was determined that the only cruise pas-

2.	Victoria, Canada(pre-inspection)

6. New York, New York6 7. Tampa, Florida

3. Seattle, Washington
4. San Pedro, California

8. Port Canaveral, Florda

5. Long Beach, California

9. West Palm Beach, Florida

4

10. Port Everglades, Florida

5

11. Miami, Florida

78

12. San Juan, Puerto Rico

9
11

10

12

Figure 18
The locations of major sea ports-of-entry across the United States

WHTI Final Programmatic Environmental Assessment

65Sea Ports-of-Entry and Recreational Craft

sengers potentially to be affected by WHTI would be those whosecruise-embarkation sea port-of-entry and cruise destinations accept
a wide variety of document categories and have no strict requirement for presenting a passport (e.g., Eastern/Western Caribbean,
Mexico, Hawaii). Of the 9.7 million total cruise passengers, it wasestimated that 9.2 million passengers would be affected by changes
to documentation as a result of sea phase of the WHTI plan basedon cruise destinations within the Western Hemisphere. These passengers account for almost 95% of total cruise passengers entering
the United States via sea ports-of-entry (MARAD, 2006).
In 2004, border crossings into the United States via pleasure craft
accounted for approximately 22,000 of the 246 million crossingsalong the Southern Border and approximately 44,000 of the 77 million crossings along the Northern Border (CBP, 2006d). Therefore,
pleasure craft crossings into the United States account for less than
1% of the total national border crossings.

8.2

Current Processing of Cruise Ship Passengers
The current CBP inspection system uses passenger manifest systems; travel documents, such as birth certificates; driver’s licenses;
passports and visas; and inspector interviews to collect data on
people entering the United States through passenger cruise ship
terminals. For foreign nationals, pre-arrival information is stored in
the electronic Advance Passenger Information System (APIS). This
information then is verified through the use of travel documents
and inspector interviews when the traveler arrives at the passenger
cruise ship terminal.
CBP may inspect cruise ship passengers for entry into the UnitedStates in one of two ways. The method of inspection depends upon
the location, facility layout, and available inspection space of aparticular sea port-of-entry. One system utilizes CBP Officers on
board the cruise liner when it is docked at the port. Passengers,

66

their travel documents, and articles to declare are inspected on theship by CBP, and then passengers disembark to enter the UnitedStates once they are determined admissible.
The other system that may be employed by CBP utilizes existing
interior facility space (often a large open warehouse area) to process
the passengers once they disembark the ship (Figure 19). Cruise
ships offload passengers once the ship is docked at the port. Often,
technology and interior infrastructure (e.g., stanchions, desks, orcomputers) are mobile and moved in during the inspection process
and are returned to storage once inspection of all passengers is complete. In both of these inspection operating systems, cruise shippassengers are inspected as pedestrians within existing operational
and physical infrastructure at the sea port-of-entry.

8.3

Current Processing of Recreational Craft
When recreational craft arrive at a sea port in the United States, thecaptain of the vessel must report the arrival immediately to CBP
and must physically present himself/herself and the passengers
for inspection and, ultimately, admission into the United States.
Regulations require that every applicant for admission to or transit
through the United States must be inspected by CBP Officers. A
person claiming to be a United States citizen must establish thatfact to the examining Officer’s satisfaction.
The captain of a vessel must report at the nearest facility or designated place immediately upon arrival. Boaters are required toreport their arrival immediately by any means of communication
approved by CBP. The report should include the name of theboat, its nationality, the name of the master, place of docking, andarrival time. There are three methods by which boat captains, family members, and all guests entering the United States can reportfor inspection: 1) obtaining a pre-approved form I-68 or NEXUS
proximity card (Trusted Traveler Programs); 2) physically reporting
WHTI Final Programmatic Environmental Assessment

Sea Ports-of-Entry and Recreational Craft

for inspection at the nearest POE; or 3) utilizing an Outlying Area
Reporting Station (OARS), or videophone station, to report to CBP.
If an onboard inspection is required, the CBP Officer may direct thevessel to an inspection area at the nearest port.

TO CRUISESTERILECORRIDORPASSENGER CRUISE SHIP TERMINALARRIVAL

CBP
CBP
CBP
CBP

FROM CRUISE SHIP

Previous analysis of sea port inspection processes determined that
there were no environmental impacts as a result of changes to the
CBP inspection processes at passenger cruise terminals (US-VISIT,
2003c). Based on the current inspection processing of passengers
entering the United States via sea ports-of-entry or recreational craft
as described above, there is no anticipated environmental impact
resulting from any of the alternatives presented in this analysis.
While the documents and technology that are used by CBP during
inspection of these passengers may change as a result of the sea
phase of the WHTI plan, no significant programmatic environmental
consequences of these changes are anticipated because the inspection processes described above will continue to be managed andoperated within the existing physical environments. In addition,
recreational craft and cruise ships are anticipated to be docked at theports-of-entry (as is the current condition) and not waiting in coastal
zones as a result of implementing the sea phase of the WHTI plan.
Therefore, no impacts to the natural environment are anticipated asa result of WHTI implementation in these environments.

FROM LANDSIDE

Potential Environmental Impacts

TO LANDSIDE

8.4

DEPARTUREPEDESTRIANGANGWAY(ESCORTED)
STERILECORRIDORCBPPASSENGER CRUISE SHIP TERMINAL

WORKSTATIONCONCEPTUAL DEPLOYEDBIOMETRIC EXISTING TECHNOLOGY
US-VISIT ATTENDANTOTHER TRAVELERS
CBP (U.S. CUSTOMS AND BORDER PROTECTION STAFF)NON IMMIGRANT VISA HOLDERSNOTES:
1. DRAWING NOT TO SCALE
2. CONCEPTUAL (NOT FOR PLANNING/DESIGN PURPOSES)(US-VISIT, 2003c)

Figure 19
Diagram of typical cruise ship passenger inspection process

WHTI Final Programmatic Environmental Assessment

67Sea Ports-of-Entry and Recreational Craft

68

WHTI Final Programmatic Environmental Assessment

9.0 Transboundary Impacts

The implementation of the land phase of the WHTI plan, by necessity, will occur along the U.S. borders with Canada and Mexico.
The potential impacts most likely to affect Mexico and Canada arefrom vehicle sources, which create air pollutant emissions and noise
impacts. NEPA requires “analysis and disclosure of transboundary impacts of proposed federal actions taking place in the UnitedStates.” These impacts are discussed, as relevant, in the appropriate resource section

WHTI Final Programmatic Environmental Assessment

69

Transboundary Impacts

70

WHTI Final Programmatic Environmental Assessment

10.0 Cumulative Impacts Summary

Cumulative impacts are those impacts on the human environmentthat result from “the incremental impact of the action when added
to other past, present, and reasonably foreseeable future actions
regardless of what agency or person undertakes such other actions”(40 CFR 1508.7). These impacts either may directly or indirectly
impact environmental resources.
According to the President’s Council on Environmental Quality(CEQ) guidance, past actions considered in cumulative impacts
analysis should be identified and considered in the context of scoping for the analysis. For the purposes of this analysis, document
research, site visits, and internal and external data gathering wereconducted to inform the assessment of the environmental baseline at the LPOEs. Past actions, whether physical modifications,
technological upgrades, or changes in operations at the LPOE,
were considered in the context of the dynamic baseline. LPOEs
already are operationally constrained environments and vary ininfrastructure, technologies, environmental contexts, and surrounding land uses. However, LPOEs have been continually adapting to
the changing security environment within these constraints. The
land phase of the WHTI plan occurs within the context of ongoing and projected changes at LPOEs, specifically, the busier ones
which currently are at carrying capacity. Numerous factors (including traffic volume) affect the ability of ports-of-entry to managechange (as summarized in the Traffic section) and improvements
in system efficiency (such as that associated with the land phase of
the WHTI plan) can be offset by decisions to scrutinize a greater
percentage of travelers. Currently, the busiest land ports-of-entry
are maintained at carrying-capacity threshold, primarily throughmanagement practices administered locally by CBP managers (e.g.,number of Officers on duty, number of lanes open, percentage of
WHTI Final Programmatic Environmental Assessment

travelers queried or entered into the computer). It is expected thatthese management practices will continue to keep impacts at or
below the current levels.
Even with some LPOEs at carrying capacity, the national implementation of the land phase of the WHTI plan is not expected tohave cumulative impacts in the foreseeable future on resources
driven by traffic, since all alternatives considered (with the exception of the No-Action Alternative) would likely result in modest
improvements at the borders. Some temporary disruption may
occur in implementation of the land phase of the WHTI plan, but
once the system reaches the Steady State Stage, effects should bemodest but positive, when compared to maintaining the status quo.
While other border security initiatives may result in delays when
implemented, the land phase of the WHTI plan has the potential tocounterbalance other impacts on wait time.

71

Cumulative Impacts Summary

72

WHTI Final Programmatic Environmental Assessment

11.0 Conclusions

Traffic, trade, commerce, tourism, and existing social patterns are
all affected by U.S. decisions on how to manage and implement
existing laws focused on increasing border security. Decision-makers are acutely aware that increased security can have undesirable
direct and indirect effects. In recognition of these difficulties, CBP
has incorporated balancing security needs with the facilitation oflegitimate trade and travel into its strategic vision. Past studies haveshown the real challenges facing CBP in its efforts to implement
border security in the United States.
For this PEA, wait time has been the key variable for understanding potential environmental effects. Since the terrorist attacks in
the United States on September 11, 2001, it generally has taken
longer for travelers to pass through LPOEs into the United States.
Numerous factors controlled by DHS affect the wait time forpeople crossing at LPOEs. These were highlighted in Section 5of this report and include: human resources (size of the workforce,training, experience, turnover, retirement, overtime); policies(inspection protocol, percentage of travelers queried); LPOE design(traffic management, signage, lane management); information management (integration of software, computer equipment, sensors);
and implementation of laws (U.S.-VISIT program, Secure Border
Traveler’s Initiative, IRTPA/WHTI, to name a few). These factors interact with a dynamic background which includes changing
demographic trends, globalization, immigration trends, and ecosystem dynamics. Many of the busier LPOEs already are at carrying
capacity. Thus, the system is sensitive to change. It is within thecontext of this complicated system that this PEA was conducted.

of operation. The improvements to wait time would result fromthe reduction in the number of different documents CBP Officers
would have to inspect, improvements in the reliability and securityof travel documents, and the potential for automation of the inspection process.
The primary resource areas that had the most potential to be affectedby the implementation of the land phase of the WHTI plan were air
quality and noise pollution. Impacts to air and noise were examined as a result of expected changes in traffic and wait times at the
LPOEs. Since traffic conditions generally are expected to improve,
air and noise pollution also are expected to improve slightly as aresult of implementing any of the WHTI action alternatives. No
environmental justice or socioeconomic impacts resulting fromenvironmental factors are expected. No potential impacts toenergy, land use, waste, water, biological resources, health andsafety, or historic properties are anticipated for any of the action
alternatives.

Wait times would improve slightly with implementation of any of
the WHTI action alternatives once WHTI reaches a Steady State
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73

Conclusions

74

WHTI Final Programmatic Environmental Assessment

12.0 Public Involvement

At the start of the Draft WHTI PEA process, CBP sent a scoping
announcement to potentially interested parties and posted it onlineat www.cbp.gov. Additionally, the Department of State has been
involved in the WHTI PEA process as cooperating agency, andthe Environmental Protection Agency and the General Services
Administration have been involved as coordinating agencies.
Along with the release of this PEA, a Notice of Availability (NOA)
was published in the Federal Register and similar information was
published in national newspapers and in certain local newspapers.
The public comment period was held from June 25 to July 24, 2007.
During the public comment period, six comments were received
from three commenters. The technical responses to these comments
can be found in Appendix D: Responses to Comments. In addition,clarifications and updates for this Final PEA are included at the
beginning of the document on page 7: Clarifications and Updates.

WHTI Final Programmatic Environmental Assessment

75

Public Involvement

76

WHTI Final Programmatic Environmental Assessment

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77

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14.0 List of Preparers

Name

Company

Education and Experience

Project Areas

The Clark Group, LLC

MEM, Environmental Management/ Resource Ecology,
Duke University; BA, Environmental Studies, University ofNorth Carolina (Chapel Hill). Over 5 years experience inenvironmental policy and analyses.

Traffic, Air Quality, Noise,
EnergyThe Clark Group, LLC

MEM, Environmental Management/ Resource, Economics,
and Policy, Duke University; BA, Jacksonville State
University. Over 25 years experience in environmental policy
and NEPA implementation.

Reviewer

Chris Conrad

The Clark Group, LLC

MBA, Tulane University; AB, Geophysics, Universityof California (Berkeley); completed MS coursework,
Environmental Science and Engineering, Virginia Tech.
Over 17 years experience in environmental programs and
NEPA analyses.

Project Management, Analysis,
NEPA Compliance

Russ D’Hondt

Customs andBorder Protection,
Environmental Planning
Program

MA, Public Administration; BPS, Environmental and Safety
Administration. 20 years experience in NEPA.

Project Manager and Reviewer

Shirley Gromen

The Clark Group, LLC

MFA, The Ohio State University; BFA, Maryland Institute ofArt. More than 20 years experience as a graphic designer.

Graphic Design

The Clark Group, LLC

MA, Anthropology, University of Virginia; AB, Anthropology,
Syracuse University; completed coursework and field research
for PhD, Anthropology, University of Virginia. More than 20
years experience in technical writing and editing.

Sara Brodnax

Ray Clark

Catherine Howell

WHTI Final Programmatic Environmental Assessment

Technical Editing83List of Preparers

Chris Ingram

GSRC

MS, Wildlife Biology, BS, Zoology, 30 years experiencein natural resources, environmental planning, and NEPA
compliance.

Project Manager, Reviewer,
Public Involvement

Emily Johannes

The Clark Group, LLC

MS, Ecology and Evolution, University of Pittsburgh; BA,
Zoology, Miami University. Over 5 years experience inenvironmental studies and NEPA.

Water, Waste, Cumulative
Impacts, Sea Ports-of-Entry
analysis

Steve Kolian

GSRC

MS, Environmental Sciences, Tulane University;
BA, English/Chemistry, Augsburg College. 10 years
experience in NEPA and environmental studies. Watershed and
Air Quality Specialist

Air Quality, Noise

Lisa Mahoney

The Clark Group, LLC

JD and Master of Studies in Environmental Law, Vermont Law
School; BS, Ecology, Tulane University. 10 years experiencein NEPA and environmental studies.

Historic Properties, TechnicalAnalysis Management,
Cumulative Impacts

Debi Rogers

The Clark Group, LLC

MBA, University of North Carolina (Chapel Hill); BS,
Villanova University. Over 13 years in project management,
NEPA implementation, and public involvement.

Reviewer

Chris Saricks

Argonne National
Laboratory

MPhil, London School of Economics and Political
Science;BA, University of Kansas. More than 25 years
experience in technical aspects of urban and regionaltransportation planning and environmental quality analysis.

Technical Reviewer,
Air Quality and Noise Studies

Eric Webb

GSRC

PhD, Oceanography & Coastal Sciences, Louisiana State
University. 14 years experience in NEPA and environmental
studies.

Biological Resources

Gary Williams

The Clark Group, LLC

PhD, Sociology, Colorado State University; MEd andBA, University of Georgia. Over 30 years experience inenvironmental impact assessments.

Analytical Methods, Land Use,
Socioeconomics

The Final PEA includes additional information and clarifications based on information and questions received during the public comment period and final
government document review process.

84

WHTI Final Programmatic Environmental Assessment

Appendices

Appendix A: Trusted Traveler Programs
A Trusted Traveler Program is a program that expedites bordercrossings for individuals who undergo a background risk assessment
and interviews as part of a pre-approval process. These include the
NEXUS, Secure Electronic Network for Travelers’ Rapid Inspection(SENTRI), and Free and Secure Trade (FAST) programs. Certain
ports-of-entry feature designated lanes reserved for the holders of aTrusted Traveler Card. These Trusted Traveler Programs are important because they represent approaches similar to WHTI alternatives,
involving MRZ and RFID technology.
NEXUS: NEXUS is a joint program between CBP and the Canada
Border Services Agency (CBSA) designed to expedite the inspection of low-risk, pre-approved travelers. Participants in the program
must be citizens or lawful permanent residents (LPRs) of the UnitedStates or Canada. As of April 2007, 123,000 participants wereenrolled in the NEXUS program.
SENTRI: Participants in the SENTRI program are able to use dedicated fast lanes at certain U.S.–Mexican border POEs. Enrollment islimited to drivers and passengers of noncommercial vehicles. Oncethe participant’s photo, vehicle, and personal information are enteredinto the SENTRI database, CBP officials use Automatic Vehicle
Identification technology to identify electronically the vehicle andits passengers at the border, thereby reducing the travelers’ wait
time. In 2007, the program had 122,000 enrollees.
FAST: CBP’s FAST program allows certain importers, commercial carriers, and truck drivers to qualify for expedited clearance
at LPOEs. These low-risk applicants must report to an enrollment
WHTI Final Programmatic Environmental Assessment

center where they will be interviewed, have their original identification and citizenship documents reviewed, be fingerprinted, andhave a digital photo taken. The FAST program allows pre-screened
commercial truck drivers expedited security clearance at 14 LPOEs
on the U.S.–Mexican border and 17 LPOEs on the U.S.–Canadianborder. In 2007, the program had 84,000 enrollees.

Appendix B: Levels of Impact by Resource Area
Air Quality
Low: Low, in the context of this environmental assessment, means
small to no effect on the ability of the environment to absorb thechange in activity, activity level, or processes. This means a minor
positive or negative change in existing air quality at most LPOEs
and surrounding communities within an airshed.
Medium: Medium means that there is some modest effect on theability of the environment to absorb the associated change in activity, activity level, or processes. Medium impacts do not create effects
that exceed regulatory thresholds, however, and can be mitigated.
This means a moderate increase in air pollutants at most LPOEs andsurrounding communities within an airshed.
High: High levels of impact represent a high probability of regulatory noncompliance or high probability of impacting natural systems
beyond their ability to absorb the change without mitigation. Thismeans a substantial periodic or permanent increase in the level of
air pollution to an extent that exceeds federal or state air quality
standards within the airshed.

85

Appendices

Noise Pollution
Low: Low, in the context of this environmental assessment, means
small to no effect on the ability of the environment to absorb thechange in activity, activity level, or processes. This means a minor
positive or negative change in existing noise levels at most LPOEs
and surrounding communities with sensitive noise receptors. An
increase in noise is considered to be a negative change, whereas adecrease in noise is a positive change.
Medium: Medium means that there is some modest effect on theability of the environment to absorb the associated change in activity, activity level, or processes. Medium impacts do not create effects
that exceed regulatory thresholds, however, and can be mitigated.
Medium means a moderate increase or decrease in existing noiselevels at most LPOEs and surrounding communities with sensitivenoise receptors. An increase in noise is considered to be a negativechange, whereas a decrease in noise is a positive change.
High: High levels of impact represent a high probability of regulatory noncompliance or high probability of impacting natural systems
beyond their ability to absorb the change without mitigation. Highmeans a substantial periodic or permanent increase or decrease in
the level of ambient noise at the majority of LPOEs with sensitivenoise receptors or a substantial number of violations of federal andstate noise criteria. An increase in noise is considered to be a negative change, whereas a decrease in noise is a positive change.

Appendix C: E stimating the WHTI-Affected Travelers’
Crossings into the United States
This analysis used the following steps and assumptions to estimate
the percentage of border crossings that likely would be affected by
the implementation of land phase of the WHTI plan.

86

In 2004, there were 246.9 million crossings into the United Stateson the Southern Border (76% of the total) and 76.7 million crossings into the country on the Northern Border (24% of the total).
These crossings include all modes of transportation (i.e., trains,cars, pedestrians, trucks, and buses) from all of the LPOEs (CBP,
2006d). The resulting total number of crossings from both borders is323.6 million crossings into the United States in 2004 (CBP, 2006d).
Although the crossings used in this estimate include pedestrians,
buses, and trains at the LPOEs, these modes account for only a small
proportion of all land border crossings, as approximately 80% of allland border crossings are conducted via privately owned vehicles(Department of Transportation, n.d.). This analysis conservatively
includes all modes of crossings.

Crossings Considered and Dismissed
The total number of crossings referenced above also include recreational boats, which accounted for less than one percent of thetotal number of crossings into the United States in 2004 (See the
Implementation of WHTI at Sea Ports-of-Entry and for Recreational
Craft section). In addition, data from CBP for NEXUS and SENTRI
crossings conducted in January 2007 were used to estimate thepercentage of crossings that occur by Trusted Traveler Program
participants in these programs (See Appendix A). It was determinedthat less than one percent of the total number of crossings can be
attributed to Trusted Travel Program participants. These crossings
were left in this estimate as they would not differentially impact thecalculations and would contribute to a more robust and conservative estimate of the affected percentage of crossings. On a similarnote, a survey conducted in the San Diego/Tijuana metropolitan area
determined that less than 2% of all land border crossings are madeby other (non-Mexican) foreign nationals (San Diego Dialogue,1994). As such, the inclusion of all foreign nationals would not
impact the conservative assumption that all non-U.S.-citizen crossWHTI Final Programmatic Environmental Assessment

Appendicesings are conducted by Canadian citizens on the North and Mexican
citizens on the South.

Affected Northern Border Crossings(Department of State, 2005). If this statistic is applied to all U.S.citizen crossings, then a conservative estimate would be that 71.5
million crossings by U.S. citizens without WHTI plan-compliant
documents were made in 2004. This represents about 29% of all
Southern Border crossings that year.

In 2004, 34.7 million crossings of the 76.7 total Northern Bordercrossings (45% of Northern crossings) were made by U.S. citizens.
The remaining crossings (42 million) were assumed to be conductedby Canadian citizens (55%).
A report issued for Industry Canada (2006) showed that on average,
41% of Canadian travelers already have a passport. In the UnitedStates, about 43% of the population of border communities (likely
to travel via the LPOEs) currently possess a passport (Departmentof State, 2005). Thus, a conservative estimate for Canadian bordercrossings by travelers not holding passports in 2004 is about 25
million, and for U.S. citizens not holding passports about 20 million, or about 32% and 26% of the total crossings, respectively. It
is reasonable then to estimate that no more than 58% of crossingson the Northern Border would be affected by the WHTI plan. This,
however, represents a conservative assumption, as it is well known
that there are multiple crossings conducted by a relatively small
percentage of frequent travelers.

Affected Southern Border Crossings
In 2004, 105.2 million crossings were made by U.S. citizens on theSouthern Border. Therefore, it can be assumed that the remaining
141.7 million crossings, accounting for 57% of the Southern Bordercrossings, were conducted by Mexican citizens (see Crossings
Considered and Dismissed section above) who currently must crosswith a passport or a Border Crossing Card (BCC), both of which are
current WHTI plan-compliant documents.
One estimate indicates that about 68% of U.S. citizen travelers inborder states who cross into Mexico currently do not hold passports
WHTI Final Programmatic Environmental Assessment

87Appendices

Appendix D: Public Involvement Materials
Dear Sir or Madam:
The United States Bureau of Customs and Border Protection (CBP) of
the Department of Homeland Security (DHS) requests your assistancein identifying any significant environmental impacts or relevant environmental concerns that might arise from the implementation of theWestern Hemisphere Travel Initiative (WHTI) at land and sea portsof-entry (LPOEs). CBP will analyze and identify the potential forenvironmental impacts in a Programmatic Environmental Assessment(PEA), prepared in accordance with the Council on Environmental
Quality’s regulations implementing the National Environmental
Policy Act (NEPA; 42 U.S.C. §§ 4321 et seq.)
WHTI is being implemented in response to Section 7209 of theIntelligence Reform and Terrorism Prevention Act (IRTPA) of 2004,
as amended. Section 7209 requires both U.S. citizens and nonimmigrant aliens to have a valid passport or other acceptable documentsthat establish identity and citizenship for entry into the United States.
It also requires a program to expedite the entry of frequent travelers,
including those who reside in border communities. While several
alternatives are being considered, one option to speed the flow of traffic and trade at land border crossings, while meeting the requirements
for secure identity documentation, involves the use of documentswith machine readable zones (MRZ) and radio-frequency identification (RFID) technology. Implementation of this option may requirephysical modifications of land and sea ports-of-entry. Adoption of
documents with embedded technology would be an effective way to
expedite the flow of traffic at land border crossings while meeting therequirements for secure citizenship and identity documents.

88

This letter provides advance notice to interested parties about the
PEA. The PEA will (1) address whether the implementation of the
WHTI plan may result in environmental impacts to certain resources
such as air, water, and historic properties; (2) describe the underlying purpose and need to which CBP is responding; (3) describe theproposed action or actions; (4) identify reasonable, alternative ways
in which to meet the defined purpose and need; and (5) analyze thepotential environmental consequences and/or benefits while implementing those reasonable alternatives.
CBP plans to provide a draft PEA in the spring of 2007 for public
review. CBP will then address substantive environmentally-relatedcomments and incorporate appropriate changes into the final PEA.
Information about CBP is available at http://www.cbp.gov/.
Comments or suggestions on the Environmental Assessment, including specific environmental issues or concerns to be considered in theanalyses, and to receive a copy of the Draft PEA when it becomes
available, please contact CBP.WHTIENVIRONMENTAL@dhs.gov
by February 2, 2007.
Sincerely,
John P. Wagner
Director, Passenger Automation
U.S. Customs and Border Protection

WHTI Final Programmatic Environmental Assessment

Notice of Availability
DEPARTMENT OF HOMELAND SECURITY
U.S. Customs and Border Protection[USCBP–2007–0060]
Notice of Availability of a Draft Programmatic Environmental
Assessment on the Western Hemisphere Travel Initiative at
Land and Sea Ports-of-Entry
AGENCY: U.S. Customs and Border Protection, Department ofHomeland Security.
ACTION: Notice of Availability.
SUMMARY: This Notice of Availability announces that a draft
Programmatic Environmental Assessment (PEA) for the Western
Hemisphere Travel Initiative (WHTI) at land and sea ports-ofentry is available for public review and comment. The draft PEA
documents a review of the potential environmental impacts fromchanges to technology and operations to meet the requirements forstandardized, secure travel documents under WHTI.
DATES: The draft PEA will be available for public review andcomment for a period of 30 days beginning on the date this document is published in the Federal Register. Copies of the draft
PEA may be obtained by telephone request (202–344–1589) or
by accessing the following Internet addresses: http://www.cbp.
gov/travel and http:// www.regulations.gov. Comments regarding
the draft PEA may be submitted as set forth in the ADDRESSES
section of this document.

WHTI Final Programmatic Environmental Assessment

ADDRESSES: Copies of the draft PEA may be obtained from U.S.
Customs and Border Protection (CBP) through the Internet at http://
www.cbp.gov/travel and http://www.regulations.gov or by writing
to: CBP, 1300 Pennsylvania Avenue, NW., Room 5.4C, Attn: WHTI
Environmental Assessment, Washington, DC 20229.
You may submit comments on the draft PEA, by one of the following methods:•	Federal eRulemaking Portal: http:// www.regulations.gov.
Follow the instructions for submitting comments.
•	Mail: Comments by mail are to be addressed to U.S. Customs
and Border Protection, 1300 Pennsylvania Avenue, NW., Room
5.4C, Attn: WHTI Environmental Assessment, Washington, DC
20229.
Instructions: All submissions must include the agency name anddraft PEA docket number ‘‘USCBP–2007–0060.’’ All comments
will be posted without change to http://www.regulations.gov,
including any personal information sent with each comment.
FOR FURTHER INFORMATION CONTACT:Patrick Howard, U.S. Customs and Border Protection, 1300 Pennsylvania
Avenue, NW., Room 5.4C, Washington, DC 20229, 202–344–1589,
e-mail address: Patrick.Howard@associates.dhs.gov, or Pat Sobol,
U.S. Customs and Border Protection, 1300 Pennsylvania Avenue, NW.,
Room 5.4C, Washington, DC 20229, 202–344–1381, e-mail address:
Pat.Sobol@dhs.gov.

89Appendices

SUPPLEMENTARY INFORMATION:
Background
The Western Hemisphere Travel Initiative
The Intelligence Reform and Terrorism Prevention Act of 2004
(IRTPA), as amended, provides that upon full implementation,
U.S. citizens and Bermudan, Canadian and Mexican citizens andnationals would be required to present a passport or such alternative documents as the Secretary of Homeland Security designates
as satisfactorily establishing identity and citizenship upon entering
the United States. In a notice of proposed rulemaking (NPRM) tobe published in the Federal Register, the Department of Homeland
Security (DHS) and Department of State (DOS) describe thesecond phase of a joint plan, known as the Western HemisphereTravel Initiative (WHTI), to implement these new requirements.
The NPRM proposes the specific documents that U.S. citizens andnonimmigrant aliens from Canada, Bermuda, and Mexico would be
required to present when entering the United States at sea and land
ports-of-entry from Western Hemisphere countries.
DHS and CBP have analyzed the potential impacts on the humanenvironment of several alternate ways of implementing WHTI
based on technological and operational considerations as part of thedecision-making process regarding the implementation of WHTI
at sea and land ports-of-entry. The impact analysis in the draft
Programmatic Environmental Assessment (PEA), as explained in
the report, focuses primarily on the effects of implementing WHTI
at land ports-of-entry because the land environment is the mostsensitive to the proposed document and technological changes
associated with implementation of WHTI.1

1 Changes to processing travelers at sea ports-of-entry would happen entirely within existing buildings and other infastructure, so no environmental impacts are anticipated.

90

WHTI Final Programmatic Environmental Assessment

Appendices

Public Comments and Responses
Commenter:	Business for Economic Security, Trade and Tourism

Recommendation: The BTA recommends the timeframe
for the “early-operational stage” be extended from six
months to a more realistic, one- to two-year period.

Coalition of the US and Canada (BESTT)
Comment:	DHS and CBP have decided, with no scientific or
independent review, that wait times will actually decrease
with the implementation of WHTI. The BESTT Coalition,
which predicted the passport backlog and the problems with
the PASS Card, has always disagreed with this, and believes
that, at least initially, wait times will actually increase.
Response:	As explained in the analysis, the ranking of wait times
associated with each alternative was made based on thebest available information, including traffic modeling, site
visits, and field experience. The analysis also examinedthe dynamics that contribute to wait time, including total
queue length, traffic volume, inspection protocols, andport infrastructure (see Figure 11 on page 34 of the draft
Programmatic Environmental Assessment). Without
additional information provided by the BESTT Coalition as
to the reasons for the belief that wait times will increase, noadditional analysis with respect to this issue is possible.

Commenter: 	Pete Sepulveda, Maria Luisa O’Connell, Erin Ward,

Border Trade Alliance
Comment: 	Initial and Early Operation: The Draft PEA states that
implementation of WHTI and impacts from the first monthsof its introduction (early operational stage) are “assumed
to be temporary in duration” (Page 30). The document also
defines the early operational stage as occurring during thefirst six months of operation (Page 29). The BTA believes
these statements underestimate the length of time necessary
for introduction of WHTI, which will require a change
in habit and way of life for many U.S. border residents
WHTI Final Programmatic Environmental Assessment

Response:

The early operational phase will be different at land eachport of entry. CBP used six months as a reasonable amountof time for an individual land port of entry and its habitualcrossing population to become accustomed to the new
WHTI requirements. Since the analysis is keyed to thelonger-term, steady state dynamics, lengthening the timevalue of the early operational phase will have no effect on
the analysis or its conclusions.

Commenter: 	Pete Sepulveda, Maria Luisa O’Connell, Erin Ward,

Border Trade Alliance:
Comment: 	Socioeconomic Impact: The Draft PEA provides asection on border socioeconomics, but the section neglects
to address potential impacts to regional economies fromany of the three “action” alternatives. The BTA sees
this as a serious omission. The U.S. Federal ReserveDallas reports that U.S. border communities deriveconsiderable economic benefit from cross-border tradeand commerce. In some smaller communities, a majorityof the economy may be based on the movement ofgoods and people between two neighboring nations.
Implementation of WHTI has the potential to generatesignificant economic impacts within border communities.
Recommendation: The BTA highlights the omission ofan adequate economic impact section in the Draft PEA andrequests that such a chapter be included.

91

Appendices

Response:

CBP considered the economic effects of WHTI separately
in the Regulatory Assessment for the Notice of Proposed
Rulemaking. NEPA requires federal agencies to examinesocioeconomic impacts only to the extent that they relate
to the potential environmental impacts of a project (See
40 CFR §1508.14). The Programmatic Environmental
Assessment did not find any environmental impacts from
implementation of any of the alternatives that would be
related to socioeconomic impacts.

Commenter: 	Pete Sepulveda, Maria Luisa O’Connell, Erin Ward,
Border Trade Alliance
Comment: 	Extending the Geographic Range: The BTA remains onrecord as advocating for extending the geographic range
at which wait times at land POEs are measured to include
the entire queue. Using only the POE footprint, as is done
now, miscalculates the actual wait time for vehicle traffic
and fails to provide an accurate benchmark for evaluationor comparison.
	Recommendation: The BTA recommends a recalculationof wait times to include the entire queue, not just the POE
footprint, to more accurately assess a benchmark that can beused for evaluation and comparison of policy alternatives.

Response:92

The definition of “wait time” was explained on page 32 of
the draft Programmatic Environmental Assessment (PEA).
Wait time in the context of the analysis includes all vehicles
within the queue and does not end with the land port-of-entry(LPOE) boundary. The queue was also defined on page 32 of
the draft PEA as “The line of vehicles waiting to approach orat the stop sign in front of the primary inspection booth.” Theline of vehicles includes vehicles waiting outside of the LPOE
boundary. This approach is consistent with how wait times aremeasured in the field (LPOE Site Visits, 2006-2007).

Commenter: 	Pete Sepulveda, Maria Luisa O’Connell, Erin Ward,
Border Trade Alliance
Comment: 	A Fifth Alternative: Insufficient manpower often is citedas the major reason for excessive wait times at land POEs.
Recent deployment of extra manpower at southern land
POEs has demonstrated improved efficiencies at land POEs
and a reduction in illegal entries into the United States(i.e., Operation Jump Start). Even if DHS implements the
RFID “action” alternative, as proposed, the BTA believes
that increases in manpower may be required to minimize
the impact to cross-border commerce and tourism.
Recommendation: The BTA recommends the addition of a
fifth “action” alternative to include the impact of hiring andtraining new personnel as a method for implementing WHTI.
Response:

This Programmatic Environmental Assessment analyzes thepotential environmental impacts of the Western HemisphereTravel Initiative Rule for Land and Sea Ports. The decisioncontemplated in the rule is how to change the document
requirements for many types of U.S. travelers and foreign
nationals entering the United States at land and sea portsof- entry. The addition of new CBP personnel would not
be a reasonable alternative because it does not meet the
purpose and need for this action. The addition of new
personnel would not help to prevent the existing problems
with fraudulent documents or improve the ability of CBP
Officers to quickly and easily establish the identity andcitizenship of travelers entering the United States. Nor
would the addition of new personnel improve the reliabilityor security of documents currently used to enter the UnitedStates. Since this proposed alternative will not meet the
purpose and need for this action, it was not included in theanalysis as a fifth alternative.

WHTI Final Programmatic Environmental Assessment

Appendices

Commenter: 	Marthea Rountree, Environmental Protection Agency

Response: 	Sections 4.1.4 and 6.3 were revised to reflect these issues.

Comment: 	EPA has reviewed DHS’s Draft Programmatic
Environmental Assessment (PEA) on the Western
Hemisphere Travel Initiative (WHTI) in the Land and
Sea Environments. Comments are being provided on
one matter. The Preliminary Draft PEA included an
extensive discussion on the potential impacts of WHTI
activities on Tribes and Traditional Cultural Properties.
It included discussions on several issues concerningpotential impacts of the requirements for standardized
legal documentation (as proposed by WHTI) for sometribal members. They included but were not limited to:
Tribal treaty rights that provide them with aright of unrestricted access to cross the border;
Tribes’ ability to travel to sacred sites where their landspans the border and how this initiative may impact
their ability to regularly cross them to engage in cultural
practices; and financial requirements (initial and recurring)to obtain an alternate (non-tribal) travel document.
The Preliminary Draft PEA also discussed the possibilityof an exemption for tribal documents from therequirements of WHTI; their continued acceptance at theborder; therefore minimizing the impacts to the tribes.
It was EPA’s understanding that DHS was still
conducting analysis/considering the effects of thisproject on Tribes and Traditional Cultural properties.
However, the current Draft PEA does not include any
discussions pertaining to this issue. If impacts on Tribes andTraditional Cultural properties have been addressed/resolved
and it has been determined that there are no significant
impacts, EPA recommends that the Final PEA includes atleast a brief discussion on the specifics of the determination.
WHTI Final Programmatic Environmental Assessment

93Appendices

Appendix E: Federally Recognized Tribes on the Border
Reservations near or on the U.S.-Canadian border

Federally Recognized Tribes
Idaho

Coeur d’Alene Reservation
Kootenai Reservation

Coeur d’Alene Tribe
Kootenai Tribe of Idaho
Maine

Aroostook Band of Micmac
Houlton Band of Maliseet
Passamaquoddy Tribe of Maine
Penobscot Indian Nation

Aroostook Band of Micmac
Houlton Band of Maliseet
Passamaquoddy Tribe of Maine
Penobscot Indian Nation
Michigan

Grand Traverse Reservation*
Little Traverse Bay Reservation*
Bay Mills Indian Community*
L’Anse Keweenaw Bay Indian Community (includes Ontonagon)*
Sault Ste. Marie Tribe of Chippewa*
Minnesota
Leech Lake Indian Reservation
White Earth Band of Ojibwe
Bois Forte Reservation (3 sectors: Nett Lake, Vermillion, and Deer Creek
Grand Portage Indian Reservation*
Red Lake Indian Reservation
Montana
Flathead Indian Reservation
Blackfeet Reservation
Fort Belknap Reservation
Fort Peck Reservation
Rocky Boy’s Indian Reservation
New York
Oneida Indian Nation
Allegany Reservation
Cattaraugus Reservation*
St. Regis Mohawk Reservation*
Tuscarora Nation*
Tonawanda Reservation
94

Three Fires Confederacy of Ottawa, Chippewa and Pottawatomi
Little Traverse Bay Band of Odawa Indians
Bay Mills Indian Community
Lake Superior Band of Chippewa
Sault Ste. Marie Tribe of Chippewa
Leech Lake Band of Ojibwe
White Earth Band of Ojibwe
Bois Forte Band of Ojibwe
Grand Portage Band of Lake Superior Chippewa
Red Lake Band of Ojibwe
Confederated Salish and Kootenai Tribe
Blackfeet Nation
Gros Ventre Tribe of Montana and Assiniboine Tribe of Montana
Assiniboine and Sioux Nations
Chippewa-Cree Tribe
Oneida Indian Nation
Seneca Nation
Seneca Nation
St. Regis Mohawk Tribe
Tuscarora Nation
Tonawanda Band of Seneca Indians
WHTI Final Programmatic Environmental Assessment

AppendicesReservations near or on the U.S.-Canadian border

Federally Recognized Tribes
North Dakota
Three Affiliated Tribes of Mandan, Hidatsa, and Arikara
Turtle Mountain Band of Chippewa Indians of North Dakota
Spirit Lake Dakotah Nation

Fort Berthold Reservation
Turtle Mountain Reservation
Spirit Lake Nation Reservation
Washington
Chehalis Reservation
Hoh Indian Reservation
Muckleshoot Reservation
Nisqually Indian Reservation
Puyallup Indian Reservation**
Quileute Reservation
Quinault Reservation
Skokomish Reservation**
Spokane Indian Reservation
Squaxin Island Reservation**
Colville Reservation
Jamestown S’Klallam Reservation**
Kalispell Indian Reservation
Lower Elwha Reservation**
Lummi Indian Reservation
Makah Indian Reservation**
Nooksack Reservation**
Port Gamble S’Klallam Reservation**
Port Madison Indian Reservation**
Sauk-Suiattle Reservation
Samish**Stillaguamish Reservation
Swinomish Reservation**
Tulalip Reservation**
Upper Skagit Indian Reservation

Confederated Tribes of the Chehalis
Hoh Indian Tribe
Muckleshoot Indian Tribe
Nisqually Indian Tribe
Puyallup Tribe of Indians
Quileute Tribe
Quinault Tribe
Skokomish Indian Tribe
Spokane Tribe of Indians
Squaxin Island Tribe
Confederated Tribes of Colville Reservation
Jamestown S’Klallam Tribe of Washington
Kalispel Indian Tribe
Lower Elwhat S’Klallam Tribe
Lummi Nation
Makah Indian Tribe
Nooksack Indian Tribe
Port Gamble S’Klallam Tribe
Suquamish Tribe
Sauk-Suiattle Indian Tribe
Samish Indian Nation
Stillaguamish Tribe of Indians
Swinomish Indians
Tulalip Tribes
Upper Skagit Indians
Wisconsin

Bad River Indian Reservation*
Red Cliff Reservation*
Note: *Indicates Tribe is located on Great Lake or border waterway
WHTI Final Programmatic Environmental Assessment

Bad River Band of Lake Superior Chippewa
Red Cliff Band of Lake Superior Chippewa**Indicates Tribe is located on Puget Sound
95

AppendicesReservations near or on the U.S.-Mexico border

Federally Recognized Tribes
Arizona

Colorado River
Fort Apache
Fort McDowell
Salt RiverSan Carlos Apache
CocopahFort Yuma
Tohono O’odham
San Xavier
Gila River
Maricopa
Pascua Yaqui

Chemehuevi
White Mountain Apache
Yavapai
Akimel O’odham and Pee Posh
ApacheCocopahQuechanTohono O’odham
Tohono O’odham
Akimel O’odham and Pee Posh
Akimel O’odham, Pee Posh, Ak-Chin
Pascua Yaqui
California

29 Palms
Agua Caliente
Augustine
BaronaCabazonCahuilla
Campo
Capitan GrandeCuyapaipe
Inaja Cosmit
Jamul
La Jolla
La Posta
Los Coyotes
Manzanita
Mesa GrandeMorongoPala
Pauma and Yuima
Pechanga
RamonaRinconSan Manuel96

29 Palms Band
Agua Caliente Band
Augustine Band
Kumeyaay
Cahuilla Band
Cahuilla Band
Kumeyaay
Kumeyaay
Ewiiaapaap
Kumeyaay
Kumeyaay
LuisenoKumeyaay
Los Coyotes Band
Kumeyaay
Kumeyaay
Pala Band
LuisenoPauma Band
LuisenoRamona Band
LuisenoSan Manuel Band
WHTI Final Programmatic Environmental Assessment

AppendicesReservations near or on the U.S.-Mexico border

Federally Recognized Tribes
California continued

San Pasqual
Santa Rosa
Santa Ysabel
SobobaSycuanTorres-Martinez
Viejas

Kumeyaay
Kumeyaay
Kumeyaay
Soboba Band
Kumeyaay
Cahuilla Band
Kumeyaay
New Mexico

Mescalero

Mescalero Apache Tribe
Texas

KickapooYsleta Del Sur

WHTI Final Programmatic Environmental Assessment

Kickapoo
Tigua

97