GOOD NEIGHBOR ENVIRONMENTAL BOARD Presidential advisory committee on environmental and infrastructure issues along the U.S. border with Mexico Chair Diane Austin, Ph.D. Telephone: (520) 626-3879 Email: daustin@email.arizona.edu Acting Designated Federal Officer Mark Joyce Telephone: (202) 564-2130 Email: joyce.mark@epa.gov

December 18, 2013 President Barack Obama The White House 1600 Pennsylvania Avenue, NW Washington, D.C. 20006 Dear Mr. President: As your federal advisory committee for environmen tal and infrastructure issues along the U.S. border with Mexico, we write regarding priorities for addressing serious environmental degradation and improving the quality of life for the 15 million inhabita nts of this complex, multicultural region. We are highlighting issues for immediate action as well as long-term concerns. Although many of these issues have been discussed in previous Good Neighbor En vironmental Board (GNEB or Board) reports, the rapid population growth of the re gion and current environmental cond itions have outstripped even the excellent binational, U.S. federal, state and local efforts directed at resolving them. The economic recession and sequestration have contri buted to challenges facing the Board this year; therefore, we have worked with your Council on E nvironmental Quality (CEQ) to develop a plan for making the best use of our resources and the expertise of our membership. We determined that in 2013, we would prepare an advice letter identifying key issu es that require immediate attention and would begin gathering data for our 16th report, which will be co mpleted in 2014. In collaboration with the CEQ, we decided to address ecological restoration as an um brella concept to examine and evaluate the effectiveness of the U.S. federal government in managing multiple aspects of natural resource and environmental degradation, including invasive species; eroded soils; channelized streams; excessive water withdrawals; degraded surface water quality; and di sruption of landscape connectivity by border security activities and infrastructure, which also have degraded federal protected areas. We have discussed these topics in prior reports, be ginning with our first report in October 1995. Additionally, our 13th report specifically identifie d region-wide issues of environmental degradation, including climate impacts, environmental quality, water resource degradation, natural hazards and2 declines in biodiversity. 1 For the 16th report, we focus on efforts to address these issues through ecological restoration. Federal land managers are carrying out individual actions, and some ecological restoration efforts are being carried out within ex isting binational programs such as Border 2020 and the Border Environment Cooperation Commission (BECC) and North American Development Bank (NADB) climate change program, but they would benefit fro m a more comprehensive approach to ecological restoration throughout the border region. Some issu es require new, pragmatic initiatives that improve coordination among U.S. agencies and across the interna tional boundary to take advantage of synergies. Stakeholder participation at all levels is critical in developing solutions, and existing programs that involve coordination with a large number of stakehol ders from both sides of the border can inform new efforts. GNEB has identified the following issues for immediate action:

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

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

 EPA’s Border 2020 program should expand the fra mework to develop performance metrics to include specific ecological restoration and mainte nance. This will help ensure that ecological systems along the border remain viable.

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

 U.S. federal agencies, such as the U.S. Geological Survey, Bureau of Reclamation, U.S. Fish and Wildlife Service and IBWC, as well as U.S. state and Mexican stakeholders and tribal partners, should participate in U.S. state environmental fl ow reviews as permitted by state law. Where no U.S. state environmental flow review or pr ocess is occurring, these federal agencies should convene basin-wide analyses of environmental fl ows that are developed with Mexican, state and tribal partners to help identify the quantity, tim ing and quality of flows, as well as beneficiaries of these ecosystem services, within the framework of existing govern ing agreements and treaties. These analyses should be shared with U.S. stat es undertaking environmental flow reviews when

1 GNEB, Thirteenth Report of the Good Neighbor Environmental Board to the President and Congress of the United

States: A Blueprint for Actio n on the U.S.-Mexico Border (Washington, D.C.: GNEB, 2010), pp. 8–53, www.epa.gov/ofacmo/gneb/gneb13threport/eng_gneb_13th_report_final.pdf

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

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

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

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

 The U.S. federal government should work with local and state stakeholders to support efforts to use treated effluent for ecological restor ation, including thr ough the BECC and NADB.

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

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

 To increase the implementation and success of envi ronmental restoration activities in the U.S.- Mexico border region, the U.S. federal government should support ongoing efforts to foster transboundary watershed mana gement and ecology studies. These studies can increase understanding of how natural and man-made watershed structures and natural processes interact. With this information, we can better pred ict how human activities impact—and ecological restoration activities improve—the condition of a watershed. Watershed studies are critical to understanding the reasons for impaired sources of surface water, as well as to looking at the future and understanding how alternative struct ural or management initiatives can make water available for many uses, including envir onmental, agricultural and industrial.4  The U.S. federal government should support deve lopment and fund the acquisition of the data necessary to measure the effec tiveness of ecological restoration programs and activities. A cohesive, comprehensive data collection program is paramount to the success of any ecological restoration activities along the U.S.-Mexico border. The following sections provide inform ation to support these recommendations.

The Border Context
As described in the 13th GNEB report, certain defi ning features and characteristics of the border region make it fundamentally different from other regions w ithin the United States: “The U.S Mexico border region is defined by rapid economic and population growth, rapid ur banization, spillover effects from Mexico, asymmetries with Mexican communities acro ss the border, international commerce and trade flows, high rates of poverty, and a distinct ethnic identity.” 2 As highlighted in our prior reports and advice letters, “[t]he North American Free Trade Agreemen t brought economic expansion but not prosperity to the border region. It increased trade flows, congestion, and environmental impacts, and also stimulated significant population growth.” 3 Much of the border population is co ncentrated in binational metropolitan areas such as El Paso-Ciudad Juárez or San Diego-Tijuan a, but significant populations live in rural areas, with many of the latter living in poverty. These include colonias and the lands of 26 federally recognized tribes. Colonias , located mainly in Texas and New Mexi co, are informal settlements that are economically disadvantaged areas, often lacking th e most basic infrastructure, including water, wastewater and other basic services. Addressing environmental problems in the border region is complicated not only by the poverty of the region and rapid growth, but also by the transboundary nature of many key environmental problems, including impa ired air and water quality and hazardous materials management. The U.S.-Mexico border region is charact erized by environmental problems unlike those in any other part of the Nation. The complex geographi c, political and economic issues of the region require the development of sustainable ecological restoration initiatives. The U.S.-Mexico borderlands are diverse in flora and fauna and vary dramatically through the long narrow stretch to include chaparral; coastal plains; deserts of cactus, sage bush and creosote; isolated mountain ranges with pine and oak forests; rugged canyon lands covered in yucca; rolling hills with grasses and mesquite; and fertile river delta estuari es. Major ecosystems of the border, such as the Sonoran and Chihuahuan Deserts, include many unique species adapted to dry conditions. 4 Portions of the U.S.-Mexico border also serve as important migrat ory pathways for many avian, mammalian and invertebrate species.

2 GNEB, Thirteenth Report , 3. 3 GNEB, letter of the GNEB to the President of the United States, May 19, 2009, p. 2,

http://www.epa.gov/ocempage/gneb/pdf/2009_0519_advise_letter.pdf

. 4 “Southern North America: Northern Mexico into southwestern United States,” World Wildlife Federation, last

modified 2013, accessed September 6, 2013, http://worldwildlife.or g/ecoregions/na1303

.5 Ecological Restoration in This Border Context
As defined by the Society for Ecological Restoration (SER), ecological restoration is “ the process of assisting the recovery of an ecosystem that ha s been degraded, damaged, or destroyed.” 5 Restoration is typically applied as an “act of rene wal, revival, or reinvigoration” to “enhance the ability of ecosystems to change as their environments change.” 6 It is driven by the values of t hose implementing it, such as federal wilderness managers striving for high levels of ecological integrity; ranchers need ing sustainable soils; or residents of sister cities such as Nogales, Arizona, in the United States and Nogales, Sonora, in Mexico who want clean, reliable water supplies. Lack of r estoration under these conditions will lead to a cascade of negative impacts on natural resources and, in many cases, on human health. Due to the diverse environment of the region, bot h politically and geographically, we acknowledge that we cannot cover the full range of topics or innovatio ns (tools and practices) occurring in the field of ecological restoration on the U.S.-Mexico border. One of our goals is to evaluate and encourage further discussion among restoration ecologists, social scientists, planners, designers and practitioners 7 of several key issues critical to border ecological restoration. In our initial review of ecological restoration principles, activities and U.S. federal programs that c ould have a restoration nexus , we have identified the following issues: 1. Lack of an overall mandate for ecological rest oration and standards defining restoration success. This is needed to create a long-term commitment and increase the collaboration and integration of different agencies in our current ecological restoration efforts. 2. Lack of balance between ecological restoration’s emphasis on ecological integrity and operational mandates (e.g., transportation, commerce, security). This balance is needed to create an adaptive management that is ab le to choose priorities for the region. 3. A focus in most efforts, discussions and acti ons related to the border “environment” on “brown” issues—pollution and the lack of adequate infrastructure—rather than “green” issues—the need to protect, restore and ma nage biologically diverse flora, fauna and habitats. 4. Lack of integration with Mexico. Ecological restoration often cannot be accomplished along the border without a binational approach. The bulk of the programs and efforts aimed at ecological restoration have not been developed using a bi national approach to implement them from both sides of the border.

5 Society for Ecological Restoration, SER International Primer on Ecological Restoration , Version 2 (Washington,

D.C.: Society for Ecological Restoration, 2004), http://www.ser.org/resources /resources-detail-view/serinternational-primer-on-ecological-restoration

. 6 “What is restoration?” ReSOURCE: Eastern Santa Cruz County, Arizona, Ron Pulliam, last modified 2013,

accessed September 13, 2013, http://resourceeasternsantacruzcounty.ning.com/group/bo rderlandshabitatrestoration/page/why-pollinators-matterby-gary-1

. 7 Melissa V. Eitzel et al., “Insights From a Cross-Disciplinary Seminar: 10 Pivotal Papers for Ecological

Restoration.” Restoration Ecology 20, no. 2 (2012): pp. 147–52.6 5. Lack or inconsistent application of data , tools and models for assessing ecological restoration in the border region. There is an urgent need for a data inventory clearinghouse, gap analysis, a data quality review and more w ithin the region to quantify the scope of the problems and reach relevant solutions. 6. Lack of consistency in the standards applied to achieve ecological restoration. Although there have been federal programs that have wo rked together closely to complete Ecological Assessments for discrete geographies, incons istent standards covering adjacent areas under different international, federal, state and local jurisdictions limit the overall viability of natural areas that transcend these artificial boundaries. 7. Need for consistent and effective stakehold er engagement to create grassroots restoration efforts and provide opportunities for employment in this field. 8. Need to restore ecological connectivity and ecolo gically significant areas such as the Salton Sea and protect those that already exist.
The Potential for Ecological Restoration: Four Examples
In this letter we highlight four areas where the U. S. federal government has responsibility and ecological restoration could play a significant role: collaborative efforts under the La Paz Agreement, and particularly Border 2020; water and waters hed issues; border security; and urban areas.
1. Collaborative Efforts Under the La Paz Agreement Since the 1983 La Paz Agreement, U.S. and Me xican officials have engaged in discussion and collaboration on environmental protection efforts alon g the U.S.-Mexico border. The La Paz Agreement includes specific accords related to air, land and wa ter pollution; management of hazardous substances; and water infrastructure, but it also provides a framework for discussions and actions on habitat conservation and ecological restoration issues. The La Paz Agreement, therefore, allows the governments to convene workgroups and committe es or task forces of experts to address a wide range of border environmental issues. The 30-year-old La Paz Agreem ent, as well as subsequent institutions such as the BECC and NADB that are related to the North Amer ican Free Trade Agreement (NAFTA), have been directed primarily at environmental improvement projects or activities. By mandate, the BECC and NADB have focused particularly on infrastructure such as wastewater treatment plants. These have been of more immediate concern to the affected local governments and border residents. Identifying and ensuring the ecological restoration impacts or benef its of these infrastructure projects has not been a priority of the workgroups and committees establishe d under the La Paz Agreement or of the BECC and NADB. The latest collaborative effort under the La Paz Agreement, Border 2020: U.S.-Mexico Border Environmental Program, has five overarching goals. 8 Although all of the goals may affect ecological restoration, only one, “Improving Access to Clean and Safe Water,” specifically mentions ecological restoration as part of “protecting and restoring watersheds and water quality.” The primary emphasis,

8 EPA, Border 2020: U.S.-Mexico Environmental Program (Washington, D.C.: EPA, 2012), pp. 17–28,

http://www2.epa.gov/sites/production/f iles/documents/border2020summary.pdf

.7 however, is to improve water quality using approaches directed by EPA and its counterparts in Mexico, the Ministry of the Environment and Natura l Resources (SEMARNAT) and the National Water Commission (CONAGUA). Broadening the focus to include ecological restoratio n will require more than new language. Although the early border programs under the La Paz Agreement included agencies with ecological restoration expertise such as the DOI, neither the current program nor its predecessor, Border 2012, have formally included the DOI as a partner. Yet on a practical level, most efforts toward ecological restoration on the U.S. side of the border are implemented through the DOI and its various agencies. Informally and at the more local levels, personnel with expertise from U.S. federal agencies such as the DOI and the State Department are involved through workgroups or task forces. Some of the larger efforts, such as the Landscape Conservation Cooper atives and the Collaborative Forest Landscape Restoration Program (U.S. Forest Servi ce), include border regi ons and should naturally intersect with border efforts such as Border 2020 . The recent attempt to assess ecologies—and ecological restoration—through the Bureau of Land Manageme nt’s Rapid Ecoregional Assessment does include three areas along the border but does not attempt to in tegrate an assessment on the Mexican side of the border or directly collaborate with Mexican authoriti es. Still, these large, collaborative efforts point to what is necessary for developing a more comprehens ive U.S. federal policy on ecological restoration. Incorporating these DOI efforts in Bo rder 2020 is a needed first step.

2. Water and Watershed Issues Water remains the primary limiting resource for most of the U.S.-Mexico border area. This key resource, which the United States shares with Mexico in many locations along the border, has been traditionally considered only from the perspective of supply (i.e ., getting sufficient water to end users). The GNEB believes that the U.S. federal government could take a broader look at border water supply, exploring opportunities to make water available for ecological restoration. The allocation of water between the two countries is addressed in two treaties, the Convention of 1906 9 and the 1944 Water Treaty, 10 which allocate the waters of the Ri o Grande and Colorado River between the United States and Mexico. The IBWC is entrusted with applying these treaties. 11 One challenge for ecological restoration has been th e emphasis on water for agricultural, industrial and municipal uses over other uses. The 1944 Water Treaty contains a specific order of preferences, giving the highest priority to domestic and municipal uses followed by agriculture and stock raising, electric power, other industrial uses, navigation, fishing and hu nting, and any other beneficial uses that may be determined by the IBWC. 12 This emphasis on irrigation and municipal supplies affects not just the rivers regulated by treaty but also other rivers, lakes and a quifers in the border region. It should be noted (see

9 Convention Providing for the Equitable Distribution of the Waters of the Rio Grande for Irrigation Purposes, U.S.-

Mexico, May 21, 1906, T.S. 455. 10 Utilization of Waters of the Colorado and Tijuana Rivers and of the Rio Grande, U.S.-Mexico, February 3, 1944,

and Protocol, U.S.-Mexico, November 14, 1944, T.S. 944.
11 The Board has written extensively about border water and watersheds, including the 4th, 8th, 12th and 13th

GNEB reports. See “Reports to the Pr esident of the United States,” EPA, last modified December 18, 2012, accessed September 11, 2013, www.epa.gov/ofacmo/gneb/gneb_president_reports.htm

. 12 Article 3 of T.S. 944.8 below) that all the waters of the Rio Grande in the United States under both the Convention of 1906 and the 1944 Water Treaty belong to individual water rights holders and that these water rights are granted by state agencies. Coupled with other management pr actices, the priority of uses has reduced water availability for fish and other aquatic organisms. Another concern is that dams have disrupted the natu ral seasonal variations of rivers. Without high flows in the springtime, for example, it can be difficult for native plants and an imals to survive. In some areas, rivers are essentially dry during the nonirrigation seas on, with resulting impacts to aquatic and riparian species. Infestations of non-native plants along riverb anks, such as salt cedar and giant cane, or aquatic species, such as giant salvinia, hydrilla and water hy acinth, often have replaced native species, degrading their habitat. 13 In some areas, certain non-native species consume significant amounts of water, thereby reducing water availability. Some specific examples of wetland or riparian habitat restoration in the border region include:

 The United States Section of the IBWC is working di rectly to restore habitat at various sites along the Rio Grande in the United States between Perc ha Dam, New Mexico, and El Paso, Texas, and has started to acquire water rights fro m willing sellers to support the effort. 14

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

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

 As previously described in the Board’s 12th re port, work is underway in California to address ecological restoration of the Salton Sea, an in land lake that has suffered from high salinity and polluted runoff. Federal, state, and local stakehol ders have partnered and built three wetlands for

13 GNEB. “Damage Caused by Invasive Aquatic and Ripari an Species on the U.S.-Mexico Border,” letter of the

GNEB to the President of the United States, October 20, 2004, www.epa.gov/ofacmo/gneb/comments/2004_oct_20_comments.htm

. 14 IBWC, United States Section. Project Brief: Restoration Activities in the Rio Grande Canalization Project, June

2009–August 2013 (El Paso, TX: IBWC). 15 Interim International Cooperative Measures in the Colorado River Basin Through 2017 and Extension of Minute

318 Cooperative Measures to Address the Continued Effects of the April 2010 Earthquake in the Mexicali Valley, Baja California, IBWC, Nov. 20, 2012, Minute No. 319, www.ibwc.gov/Files/Minutes/Minute_319.pdf

. 16 “Lower Colorado River Multi-Species Conservation Program,” last modified November 26, 2012, accessed

September 9, 2013, www.lcrmscp.gov/gen eral_program.html

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

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

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

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

 On a positive note, on September 16, 2013, the chairmen of the Texas Commission on Environmental Quality and the Texas Wate r Development Board and the EPA Region 6 Administrator sent a joint letter on colonias to three Texas associati ons. The letter to the Texas Association of Counties, the Texas Municipal League and the Texas Association of Regional Councils asked for the members of those organi zations to cooperate with state and federal agencies to provide services to colonia residents. If colonia residents receive wastewater services, the prospect for successful ecological restoration increases dramatically.
3. Border Security and Impacts on Ecological Restoration Illegal border activity and border security activities have affected the environment of the border region; the appropriate response strategy, besides applying best practices and mitigation funds to affected resource managers, should include ecological restoration.

17 GNEB, Twelfth Report of the Good Neighbor Environmental Board to the President and Congress of the United

States: Innovative and Practical Approaches to Solving Border Environmental Problems (Washington, D.C.: GNEB, 2009), www.epa.gov/ocempage/gneb/gneb12threport/English-GNEB-12th-Report.pdf

. 18 Volumes of Water Saved With the Modernization and Improved Technology Projects for the Irrigation Districts in

the Rio Conchos Basin and Measures for Their Conveyan ce to the Rio Grande, IBWC, July 3, 2003, Minute No. 309, www.ibwc.gov/Files/Minutes/Min309.pdf

.10 In our December 2, 2009, advice letter, the Board highlighted the effects of the construction and maintenance of the border fence on the environment. The border fence was mandated by Congress, and the DHS was charged by Congress with its constructi on. To quote from the Board’s 2009 advice letter, included as an attachment in the 13th GNEB repor t, “While...the border fence has had some positive outcomes and is appropriate in targeted areas, the construction has caused negative impacts to some natural and cultural resources.” 19 As noted in the 13th GNEB report, foremost is the disruption of connectivity for species moving across the border and connectivity of water flow. 20 Recognizing the positive impacts to facilitate trade and clarifying th at increased border protection activities have impacts in the region, it also could be noted that the DHS is committed to responsible e nvironmental stewardship; ecological restoration efforts are an integral part of that commitment as per internal policy. 21 Border Patrol activities continue, however, to have consequences. For example, tribes and DOI staff, as well as residents in the region, report that Border Patrol activities, such as tire dragging to look for tracks of undocumented immigrants and workers, continue to cause environmental degradation and increase erosion. It should be noted that the DHS has undertaken numer ous mitigation efforts regarding the impact of the border fence and is working with the DOI and various tr ibal organizations on many of them. To cite just one example , the 

### DHS’ Border Patrol Facilities and Tactical Infrastructure Program Management Office has a project to stabilize fill slopes, offset loss of vegetation and re-establish Quino checkerspot butterflysuitable habitat in Zone A-1, San Diego Sector. 22 Other projects have emphasized species regulated under the Endangered Species Act, but the DHS has provided only $17 million of the as much as $50 million identified by the DOI as needed to mitigate imp acts from the construction of the border fence. 23 Speciesspecific approaches are generally seen as inadequate responses to widespread degradation of natural resources and the environment. The DHS also has begun to incorporate training and gu idance related to environmental issues into its practices. In addition, appropriate DHS personnel and Border Patrol officers receive training on environmental protection and tribal customs and re lations, and they now incorporate environmental protection and tribal liaising in their daily routine.

19 GNEB, letter of the GNEB to the President of the United States, December 2, 2009, p. 1, http://www.epa.gov/ocempage/gneb/pdf/2009_1202_advise_letter.pdf

. 20 GNEB. Thirteenth Report, pp. 71, 74.
21 Janet Napolitano (DHS Secretary), “Department Sust ainability Policy,” memorandum to Component Heads,

February 7, 2011; Elaine C. Duke (DSH Under Secretary for Management), “Department of Homeland Security Environmental Policy,” memorandum to all DHS employees , October 18, 2008; DHS Chief Financial Officer and Chief Readiness Support Officer, “F inancial Liabilities Policy,” memora ndum, April 27, 2012; Sustainable Practices for Environmental, Energy and Transportation Management, DHS, September 29, 2008, Directive 025-01; Environmental Compliance Program, DHS, May 23, 2007, Directive 023-02; Environmental Planning Program, DHS, April 19, 2006, Directive 023-01; Instruction 023-1 for DHS Directive 023-01; and Instruction 017-01 for Historic Preservation in Asset Management and Operations, DHS, March 10, 2008, Directive 017-01.
22 Dr. Teresa Pohlman (Director, Sustainability and E nvironmental Programs, DHS), email message to Steve

Niemeyer (Texas Commission on Environmental Quality), July 8, 2013. 23 Dr. Greg Eckert (Restoration Ecologist, National Park Service), email message to Steve Niemeyer, September 11,

2013.11 4. Ecological Restoration in Urban Areas Urban ecological restoration is a critical need and focus for the U.S.-Mexico border region because border communities face heightened environmental and pu blic health risks associ ated with ecosystem degradation (e.g., risks arising from floods, fire, dus t, water contamination and newly emergent disease vectors). 24 For example, haphazard urbanization (i.e., building human settlements on steep, unstable slopes without adequate infrastructure), as is ta king place in the Tijuana canyon lands, causes severe erosion during rain storms and ecological devastati on on both sides of the U.S.-Mexico border. Because of the complexity associated with high levels of human activity in urban ecosystems, approaches vary from maintaining and enhancing native plant diversity —or specific rare and endangered plant or animal species—to restoring and enhancing habitats and cultural landscapes, the latter being landscapes that combine human and natural features to reflect a nd express the relationships between people and the environments within which they live. The nature and type of restoration that is possibl e or desirable in urban areas depends on the level of degradation of the ecosystem; whether or not there is a framework or reference to reestablish systems that were in place before the urban area was developed; an d the extent of recognition of the role of human values, perceptions and acti ons in shaping the landscape. 25,26 Using restoration as a tool to maximize natural resource values in these highly managed settings provides us with opportunities to test adaptive capacities of species and adaptation techniques under novel environmental conditions. Ecological restoration can increase the positive impacts of restored soils, air and watersheds, as well as provide many important socioeconomic and mental hea lth benefits, such as enhanced social cohesion, increased real estate values, improved health and recreational activities, and recognized cultural and spiritual values. 27 The Tijuana River Valley Recovery Team (TRVRT) is an example of a binational collaboration that works along such lines in the Sa n Diego-Tijuana twin city region. The TRVRT’s multiagency transborder approach “bring[s] togeth er governmental administrative, regulatory, and funding agencies in tandem with advice from the sci entific community, the environmental community, and affected stakeholders to...restore the Tijuan a River floodplain to a balanced wetland ecosystem.” 28 In another example, the U.S. federal government alread y is supporting some of this work in the Tijuana River Valley on the U.S. side of the border through innovative “Community Engagement” and “Research Translation” activities funded by the National Institu te of Environmental Health Sciences (NIEHS), Superfund Research Program.

24 “Human Health Under Threat From Ecosystem Degradation,” World Health Organization, last modified

December 9, 2005, accessed September 9, 2013, www.who.int/mediacentre/news /releases/2005/pr67/en/

. 25 “Models for Ecological Restoration in Urba n Areas: Lessons From the U.S. and Germany,” U.S. Department of

Agriculture Forest Service, last modified October 18, 2 010, accessed September 10, 2013, www.nrs.fs.fed.us/urban/landscape_change/ecological_restoration_germany_us

. 26 Lynne M. Westphal, Paul H. Gobster, and Matthias Gross, “Models for Renaturing Brownfield Areas,” in ed.

Marcus Hall, Restoration and History: The Search for a Usable Environmental Past (New York: Routledge, 2010), pp. 208–17, www.nrs.fs.fed.us/pubs/jrnl/2010/nrs_2010_westphal_001.pdf

. 27 National Research Council, Urban Forestry: Toward an Ecosystem Se rvices Research Agenda: A Workshop

Summary (Washington, D.C.: The National Academies Press, 2013), www.nap.edu/openbook.php?record_id=18370&page=1

. 28 “Tijuana River Valley Recovery Strategy,” California Environmental Protection Agency, San Diego Regional

Water Quality Control Board, last modi fied 2013, accessed N ovember 10, 2013, http://www.swrcb.ca.gov/rwqcb9/ water_issues/tijuana_river_valley_strategy/index.shtml

.Ecologic a including , improves reduce e n These fo u address b o more full y constrain t nongover n In this let t and envir o federal a g consider e and to ga t ecologica raised in t Mr. Presi d these imp

NOTE: G agencies h cc: The H The V The H Chair , The H Admi n

29 “Buildi n a l restoration

, for example coupled soci a vironmental a

u r examples a r o th environ m y researched i t s that the rec n mental and n
t er, the Boar d o nmental de g g encies and w e nvironment a t her data and l restoration p t his advice le t d ent, we tha n ortant issues.

G ood Neighb o h ave recused
H onorable Joe V ice Presiden t H onorable Na n

, White Hous e H onorable Gi n

n istrator, U.S

n g a Resilient N can help me e , the DHS’ m a l-ecological a nd public h e

r e only some m ental and hu m

i n the 16th re o mmendatio n n onprofit org d has highlig h g radation. Th e w ith stakehol d a l protection i

develop met r p rograms an d t ter in our 16 t

n k you for the

o r Environm e their organiz a Biden t of the Unite d

n cy Sutley e Council on

n a McCarthy

. Environme n

N ation,” DHS, e t the mission m ission to “B u

systems in h u e alth risks wh

of the areas w m an problem s port. Special n s will have o anizations. h ted key issu e e se issues inc d ers at all lev e

n agency op e r ics, standard s d activities. T h t h Annual Re opportunity t

e ntal Board r e a tions from t h

d States

Environmen t

n tal Protectio n

accessed Sept e

12 of the feder a u ild a Resilie n u man settle m ile increasin g

w here ecolog s in the bord e consideratio n o n tribal, stat e

e s for address i l ude the nee d e ls and from b e rations and c s and models h e Board wil l port, schedul
t o provide y o

Respect f

Diane A u Chair

e presentative s h is advice let t

t al Quality

n Agency

e mber 9, 2013 , a l agencies w o n t Nation.” 29 E m ents along th

g resilience a n g ical restorati o e r region. Th e n will be giv e e and local g o
ing multiple c d to increase c b oth sides of t ontinue envi r to plan for a n l further dev e ed for releas e

o u with our i n

f ully,

u stin

s from U.S. f e t er.

, https://www. d o rking in the E cological re h e U.S.-Mexi c n d security.

o n, appropria t e se examples e n to poten t ia l o vernments, a

c oncerns of n c ollaboration t he borde r ; t o r onmental pr o n d measure t h e lop the issue s e in 2014.

n sights and re c

e deral depart m

d hs.gov/buildi n border regio n storation tha t c o border wil l

t ely applied, c and others w i l impacts or a s well as

n atural resour c

among U.S. o continue to o tection train i h e effectiven e s and themes

c ommendati o

m ents and

n g-resilient-n a n , t l help

c an i ll be

c e

i ng; e ss of

o ns on

a tion

.