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Fort Bliss, DHS, and HHS initially selected Parcel 1, near the intersection of Liberty Expressway and Purple Heart Memorial Highway….

By News - All rights reserved. All articles referred to are the property of their respective owners , in News , at November 21, 2019



Fort Bliss, DHS, and HHS initially selected Parcel 1, near the intersection of Liberty Expressway and Purple Heart Memorial Highway. See Email 10. But they decided not to use that site because of the substantial costs of grading the site in preparation for construction, as it had a steep slope. Email 44 explains their rationale for the change.

At some point, HHS dropped out of planning discussions because it had selected Goodfellow AFB as their preferred location for a camp for unaccompanied minors. See Email 71.

DHS then selected Parcel 2 as the site for the detention camps, and Parcel 2 was the chosen site at least up until the date of our FOIA request in August 2018. (We don’t know what happened after the date of our FOIA request.)

This site is near Site Monitor, a long disused radio receiver station. Site Monitor had some existing structures of both temporary and permanent construction, some of which Fort Bliss staff had already decided to tear down. See Email 21.

Email 6 describes the condition of existing buildings using the military’s Q and F rating system for evaluating structures. (See Explanation of Q and F Ratings, for definitions.)
Fort Bliss offered to lease Site Monitor to DHS for use for administrative headquarters and medical facilities, which DHS could occupy after the slated demolition took place. See Email 22. DHS would construct tent-type housing for families on 75 acres immediately to the west of Site Monitor. Id.
Email 26 provides further detail about the type of construction anticipated and division of labor between DHS and Fort Bliss. That email discusses a draft memorandum of agreement. The Army produced a draft memorandum in its 7th production, but it was so redacted that it did not provide any new information.
Email 34 also provides important details about the proposed plans for the camp, including cost estimates. Although Fort Bliss staff had little input from DHS when they calculated these costs, the calculations are based on the cost of housing families at the family residential center (immigration detention center) in Dilley, TX.

As part of preparing Parcel 2, Directorate of Public Works staff circulated a spreadsheet with a number of questions about the environmental attributes of the site and possible hazards there. They called these questions “LOGCAP RFIs.” This spreadsheet is where Fort Bliss staff first discussed the Rubble Dump site as an environmental hazard that might affect Parcel 2. They observed continued illegal dumping on the site, as well as potential drinking water contamination.

We also know Parcel 2 was attractive to Fort Bliss staff in part because they believed that Parcel 2 was adequately studied in a 2012 NEPA environmental analysis and that they would not have to repeat such an analysis if the site was chosen. See Email 22 and Email 71. Instead, they could sign a Record of Environmental Consideration saying that the 2012 EA covered this decision. See 32 C.F.R. § 651.19, which permits the Army to move forward with an action covered by existing or previous NEPA documents by preparing a short signed statement with project documentation.

In the course of Freedom of Information Act litigation against the Army, Army staff stated that they would rely on a 2012 Environmental Assessment for a potential land sale and transfer of these parcels, Environmental Assessment for the Sale, Development, and Exchange of Army-Owned Land, Fort Bliss, Texas. Although this EA discusses the condition of the parcels later considered for the DHS/HHS camps, it does not consider any uses related to immigration detention, let alone temporary tent construction for detaining minors.
We also believe that Fort Bliss may seek to rely on a different 2012 EA, Environmental Assessment U.S. Immigration and Customs Enforcement El Paso City Administrative Facility Fort Bliss, Texas, for the NEPA analysis for this proposed child detention center. However, this EA only discusses a proposal to house 500 adult ICE staff on a site at Fort Bliss neighboring, but south of, Parcel 2, so it is difficult to see how this analysis could adequately cover the proposal to house as many as 7,500 migrants, many of them children.
Fort Bliss general counsel said that the REC would only take seven days to complete once an executive order was issued, which would be an extremely fast track for NEPA analysis if that is the process they did indeed follow. See Email 72.

One of the key issues with Parcel 2 is contamination from illegal dumping. Fort Bliss included the Rubble Dump Site near Parcel 2 in the base cleanup plan and the site cleanup has technically been completed, nearly 20 years ago.
Illegal dumping on the site continues to this day. Although Fort Bliss built a fence around the site as part of its cleanup efforts, this fence has failed to prevent new illegal dumping. Fort Bliss staff noted both new trash (piles of tires, etc.) and trespassers during their site inspections in summer 2018. See Email 51.
As a result, there is now even greater uncertainty about the environmental hazards at the site and a greater need for thorough testing, analysis, and cleanup before any detention facilities are built nearby.

The camps would likely use generator power, which may cause harmful air pollution at the site. See Email 67.


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