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Otay-West Tecate Draft Project Description 15 April 2008.doc


Project Description
The U.S. Customs and Border Protection (CBP) is proposing to construct and maintain 225 miles
of personnel and vehicle fence (PF 225 project) along the United States-Mexico international
border with completion expected by December 31, 2008. The U.S. Border Patrol (BP) is a law
enforcement entity of CBP within the Department of Homeland Security (DHS). The BP’s
priority mission is to prevent the entry of terrorists and their weapons of terrorism and to enforce
the laws that protect the U.S. homeland. To assist CBP/BP agents and officers in gaining
effective control of the international border within California, three distinct segments of barrier
fence are proposed. These segments are referred to as (from west to east): (1) Otay Mountain-
West of Tecate in San Diego County, (2) Gap Filler in San Diego County, and (3) El Centro in
Imperial County, California. Only the Otay Mountain and West of Tecate segments are covered
under this document. The other two segments (Gap Filler and El Centro), will each be covered
under separate covers.

In the proposed Otay-West Tecate project, the CBP is proposing to install and maintain tactical
infrastructure consisting of two segments of primary personnel and road improvements (A-1 to
A-2) within the USBP’s Brownfield and El Cajon sectors in San Diego County, California.
Operations related to this effort (e.g. patrols, apprehensions) are not addressed in this project
description. CBP is advised that operations such as patrolling the international border and
apprehensions in the vicinity of the international border may adversely affect federally-listed

The Otay Mountain Wilderness Area is on public lands administered by Bureau of Land
Management (BLM). The wilderness boundary is approximately 100 feet north of Pak Trail, an
east-west foot trail along the border. Approximately one half of the proposed A-1 segment will
impact the Otay Mountain Wilderness Area, while the remainder will impact non-wilderness
land administered by the BLM and the City of San Diego.

There are 14 federally-listed taxa known to occur or have the potential to occur within or
adjacent to the project area (see Table 1). Additionally, three of the listed species have
designated Critical Habitat in the proposed project area.

Table 1: Federally-listed species and federally-designated critical habitats known to occur or to

potentially occur within the proposed project area and the determination of effects resulting from
the proposed project.
San Diego fairy shrimp, Branchinecta
San Diego fairy shrimp, Branchinecta
sandiegonensis, Designated (2007)
Critical Habitat
Quino checkerspot butterfly,
Euphydryas editha quino

Otay-West Tecate Draft Project Description 15 April 2008.doc

Quino checkerspot butterfly,

Euphydryas editha quino Designated (2002)
Critical Habitat
Quino checkerspot butterfly,
Euphydryas editha quino Proposed (2008)1
Critical Habitat
Arroyo toad, Bufo californicus Endangered
Coastal California gnatcatcher,
Polioptila californica californica
Coastal California gnatcatcher,
Polioptila californica californica Revised (2007)
Critical Habitat
Southwestern willow flycatcher,
Empidonax traillii extimus
Least Bell’s vireo, Vireo bellii
San Diego ambrosia, Ambrosia
San Diego button-celery, Eryngium
aristulatum var. parishii
Otay tarplant, Deinandra conjugens Threatened
Otay Mesa mint, Pogogyne
Spreading navarretia, Navarretia
Mexican flannelbush,
Fremontodendron mexicanum
California Orcutt grass, Orcuttia
Encinitas baccharis, Baccharis

Cultural, geotechnical, and biological surveys were necessary prior to barrier fence construction
and have been reviewed by the Service. Avoidance and minimization measures for cultural and
biological surveys were not necessary based on the lack of impacts associated with the proposed
surveys. In order to minimize and avoid adverse affects to listed species during geotechnical
surveys, the following measures were provided to CBP and their consultants:

Quino checkerspot butterfly

1. Geotechnical surveys within occupied quino habitat or designated critical habitat will be
accomplished with the assistance of a qualified quino checkerspot butterfly expert. The
expert will direct geotechnical surveyors and their equipment to avoid impacting areas
likely to contain quino host plant species and/or diapuasing habitat. The Service will
assist CBP in locating qualified experts.

The U.S. Fish and Wildlife Service anticipates the revised final critical habitat designation for quino checkerspot
butterfly will be published in the Federal Register in 2008.

Otay-West Tecate Draft Project Description 15 April 2008.doc

Arroyo toad
2. Activities will avoid Cottonwood Creek, Tijuana River, and Bell Valley Creek.
Specifically, all geotechnical work will occur outside of the 100-year floodplain to avoid
impacts to aestivating arroyo toads.
3. Activities will avoid wetlands.
4. Activities will avoid all federally threatened and endangered plant species.
5. Conduct geotechnical surveys outside of the bird breeding season (February 15 to August
31) and bighorn sheep lambing season (January 1 to May 31) when working within
habitat occupied by these species or within 100 meters of habitat occupied by these
6. Activities will avoid destroying native trees and shrubs. If native vegetation must be
impacted, the vegetation will be crushed versus cut.
7. Areas where native vegetation was crushed by drill rigs or other machinery during pre-
project geotechnical activities will be recorded (GPS). Routes and/or data points will be
provided to the Service upon completion of pre-project geotechnical activities.
8. Areas impacted by drill rigs or other machinery during geotechnical activities that are
outside of the PF225 construction footprint will be assessed by the project proponent.
Adverse effects identified will be mitigated (e.g. access trail restoration, barricades).
9. All pits and trenches related to geotechnical activities will be refilled with parent material
when geotechnical activities are completed.
10. Construction of or improvement to access roads was not proposed and therefore is not
part of this consultation.

General Project Construction

Construction of the proposed project (A-1 and A-2) will impact a total of 218 acres and consist
of the following project components: (1) the installation and maintenance of new barrier fence
combined with a parallel border fence patrol road, (2) road improvements to existing roads to
improve access for construction, maintenance, and patrols, (3) new road construction to access
tactical infrastructure, and (4) the development of temporary construction staging areas.

New Fence Installation

The proposed A-1 segment includes the construction of approximately 3.5 miles of new
Personnel-Vehicle Fence Type1 (PV-1). New fence construction will permanently impact
approximately 26 acres. Impacts associated with the adjacent border fence patrol role are
factored into the road improvement section below. As shown in Figures X-Z of CBP’s the draft
EIS, the fence alignment is primarily along the international border, within 3 feet. Where the
alignment crosses Copper Canyon, a large bend of the Tijuana River, and Endemic Ridge2 (large
ridge immediately west of Copper Canyon), the alignment is moved northward upwards of 1,000
feet. The proposed A-1 segment does not tie into existing fencing and will result significant gaps

Endemic Ridge is the large north-south ridge between Puebla Tree and Copper Canyon.

Otay-West Tecate Draft Project Description 15 April 2008.doc

on each end. The fence along the entire length of A-1 is unconnected to the border fence patrol
road however; a small cat-trail will be incorporated into the footprint of the PV-1 fence. The cat-
trail will allow for perpetual maintenance of the fence.

The proposed A-2 segment includes the construction of 0.8 mile of new PV-1, permanently
impacting approximately 6 acres. As shown in Figure X of CBP’s draft EIS, the fence alignment
attaches to the existing landing mat fence. The new west end of the proposed fence will
terminate at the base of Tecate Peak and not connect to other existing fence.

The PV-1 fence is an anchored, 23-foot (5 feet below ground, 18 feet above ground) grout-filled
steel bollard style fence with 4-inch gaps between each bollard. An approximate 3 feet tall mesh
panel will be attached horizontally to the top of the bollards. The PV-1 style fence is designed to
prevent passage by both people and vehicles that will be installed throughout the Gap Filler
project corridor. Panels of PV-1 fence will be welded together off-site and transported on-site by
small trucks with lowboy trailers. Using a crane, fence panels will be set in concrete-filled
trenches or holes. Blasting will be necessary in some areas along the A-1 alignment to access the
fence alignment and create a building pad for the fence and associated patrol road. The trench
will otherwise be dug by a trencher or similar equipment. An alternative in rocky terrain is to
drill individual holes into the rock for each bollard. Construction of new fence will be completed
using a trencher, driller, cement mixer, and crane. No pile driving will be required for
construction of PV-1 fence.

Maintenance of Fence

Routine maintenance will occur, as needed, to preserve the integrity of the new and existing
barrier fence. There will be no change in overall CBP Sector operations. The fences will
be made from non-reflective steel. No painting will be required. Fence maintenance will
include removing any accumulated debris on the fence after a rain event to avoid potential future
flooding. Brush removal could include mowing, removal of small trees and application of
herbicide if needed. During normal patrols, Sector personnel will observe the condition of the
fence. Any destruction or breaches of the fence will be repaired, as needed, by a contractor.


Few roads exist along the international border in segment A-1. Puebla Tree Spur Road provides
access to the border, but not along the border. Monument 250 Road originates in Marron Valley
and heads west paralleling the border to Buttewig Canyon. Puebla Tree Spur Road and
Monument 250 Road do not meet, but are connected by the Pak Trail, a narrow six-mile foot

Primary construction access to the western end of A-1 will be from the narrow and sinuous Otay
Mountain Truck Trail which originates near Kuebler Ranch at the base of Otay Mountain. To
access Otay Mountain Truck Trail, a road built to county standards will be constructed thru
Kuebler Ranch.

Otay-West Tecate Draft Project Description 15 April 2008.doc

Periodic widening of Otay Mountain Truck Trail to its intersection with Puebla Tree Spur Road
is proposed. Puebla Tree Spur Road will also be widened from its intersection with Otay
Mountain Truck Trail to Wild Bill Canyon. The other road off of Puebla Tree Spur Road, along
the high ridge to the south, will not be widened as part of this proposal.

To access A-1 from the east, Marron Valley Road (existing) will be improved in a similar
manner as Otay Mountain Truck Trail. Marron Valley Road initiates from State Route 94 and
travels generally south to the international border at Marron Valley. The road terminates at Mine
Canyon on the west end of Marron Valley. From Mine Canyon, the Monument 250 Road heads
west to border monument 250. Improvements to the Monument 250 Road were addressed under
an Environmental Assessment separate from the PF-225 project. Nonetheless, construction to
improve this road will occur concurrent with activities associated with PF-225.

Included with the proposed widening are increases in the turning radii of substandard turns. To
accomplish both the general widening of the roads and increases to turning radii, cut-and-fill
methods will be implemented. Widening will occur where needed however, project specific
details on the improvements are not available (e.g. locations, culverts, retaining walls,
miscellaneous infrastructure).

A new road (border fence patrol road) will be constructed generally along the current alignment
of the Pack Trail. The Pack Trail is a foot trail north of the border, originating where Wild Bill
Canyon enters into Mexico. The Pack Trail traverses the extremely rugged and steep topography
along the south facing slope of Otay Mountain, between Puebla Tree and the Monument 250
Road. The proposed border fence patrol road will require numerous switchbacks, large cut-and-
fill slopes, culverts, as well as other road infrastructure.

Total road related impacts in A-1 from improvements to Otay Mountain Truck Trail, Puebla Tree
Spur Road, Marron Valley Road, and construction of the new border fence patrol road will
permanently impact 144 acres.

Access to A-2 will be via Tecate Mission Road off of State Route 94. Road improvements
similar to Otay Mountain Truck Trail are proposed on Tecate Mission Road to allow access for
construction equipment. Specific project details on the proposed road improvements are not
available. Road related improvements in A-2 will permanently impact 28 acres, not including
the impacts associated with constructing the fence and its adjacent border fence patrol road. This
acreage is factored into the impacts associated with constructing the fence itself.

Access roads and the border fence patrol road will be regularly maintained during construction
by using water to compact soils and provide safe driving conditions. A tackifier will be applied
to the roads post-construction and as necessary to attempt to increase the durability and longevity
of the roads (Roadoil or Penzsuppress).

A low water crossing or similar drainage structure will be required at some stream crossings to
ensure access, except during extreme flood conditions. The designs of the structures have not
yet been determined, but will typically consist of a concrete swale or rock gabions. Rip rap will
be placed on the upstream and downstream side of the crossing for energy dissipation. The

Otay-West Tecate Draft Project Description 15 April 2008.doc

footprint of the crossing will be expected to extend approximately 25 to 40 feet on either side of
the crossing to allow placement of the rip rap. Likewise, the design for other types of drainage
structures (e.g. cross roadway nuisance flow culverts, culvert, ditches, bridges) have not yet been
finalized, but would be expected to include reinforced concrete pipe with energy dissipation
installed on either end of the pipe and earthen ditches along side of roads. Clean, native material
would be brought in from local sources for fill activities.

Conservation Measures described below address specific design parameters to be utilized to

avoid impacting species including sufficient underpass sizing, erosion control, and adversely
affecting adjacent habitat.

Staging Areas

The proposed project includes the construction of eight (8) staging areas in A-1 which will
temporarily impact 12 acres and one (1) staging area in A-2 temporarily impacting 2 acres.
Staging areas are needed to accommodate construction equipment and stockpile materials. All
vegetation within these staging areas will be cleared. Following completion of construction,
staging areas will be restored (see the Conservation Measures section below).

Segment-specific Project Construction

Segment A-1 (Otay Mountain)

Segment A-1 will be approximately 3.5 miles in length, starting on the west near the terminus of
Puebla Tree Spur Road and ending at Monument 250. The alignment traverses the extremely
steep and rugged south facing slope of Otay Mountain.

The dramatic topography of the area and CBP’s requirement to access, patrol, and maintain the
fence alignment requires significant grading of mountainside. To construct the fence along the
chosen alignment, significant cut-and-fill slopes will be created (approximately 270,000 yds3).
Cut-and-fill slopes, upwards of 300 feet wide, will allow access to some of the steeper areas
including Endemic Ridge, Copper Canyon, Buttewig Canyon, and at a large bend of the Tijuana
River, where the river enters into the United States. The largest cut-and-fill slope will be
located where the alignment bows northward and traverses the Tijuana River’s left valley wall.
The section is approximately 200 feet wide and 0.25 mile long.

The alignment compensates for the steepness of the terrain and makes use of switchbacks to get
in and out of the canyons. Cross-sections of canyons will be filled in those locations where the
topography is too steep or the canyon to large. Where the alignment crosses the canyon bottom,
the crossing is proposed to be perpendicular to the waterways general direction of flow. Specific
details of the actual crossings are not available.

Adjacent, but unconnected to the fence, will be a border fence patrol road. The border fence
patrol road will be used during construction as an access road. It will parallel the length of the
new fence and terminate at Monument 250. The length of the access road and border fence
patrol road is approximately 5.2 miles long. For the length of A-1, the fence alignment and the

Otay-West Tecate Draft Project Description 15 April 2008.doc

border fence patrol road alignment are separated by a distance of between 10 feet and up to 750
feet. In the area between the fence and border fence patrol road, an undetermined number of
access/cat trails are proposed. The trails would connect the border fence patrol road to the fence.
The acreage permanently impacted by these trails is undetermined.

Site access from the west will be from Otay Mountain Truck Trail to Puebla Tree Spur Road to
the border. From the east, access will be from State Route 94 to Marron Valley Road to
Monument 250 Road. Road widening and improvements proposed for Otay Mountain Truck
Trail, Puebla Tree Spur Road, Marron Valley Road, and Monument 250 Road are addressed in
the Road Improvement section.

The eight (8) staging areas for A-1 are spread out along the alignment. From west to east.
Staging area (A) is located at Puebla Tree where approximately 2 acres will be impacted. The
area is at the confluence of Wild Bill Canyon and an unnamed canyon and adjacent to the border.
The low lying and undulating area will be leveled to create the staging area, as well as provide
access to the border alignment. From here the fence alignment and border fence patrol road
diverge from one another as the patrol/access road follows the bottom of Wild Bill Canyon and
the fence stays on the border. The next two staging areas (B & C) are along the border where the
patrol/access road returns within 200 feet of the border. These staging areas will impact 2 acres
and 1 acre respectively. Staging area D is 6 acres in size and located above a large bend of the
Tijuana River. Staging area E is a small 1 acre staging area located approximately 500 feet west
Buttewig Canyon. Staging area F is 1 acre in size and was proposed at the bottom of Buttewig
Canyon in the middle of the waterway. The staging area was subsequently moved from the
bottom of the canyon to the immediate floodplain terrace on the west side/left terrace of the
waterway. Staging area G is 1 acre in size and is located where the proposed fence and
Monument 250 Road meet. Staging area H is the last of the staging areas for A-1 and is located
east of Mine Canyon along Marron Valley Road. This staging area is 5 acres and situated on
non-native grassland.

Additionally, seven (7) turnarounds are proposed along the length of the border fence patrol
road. Acreage calculations are included in the Roads section. Generally, the turnarounds are
widening of the road to allow for two vehicles to pass, approximately 30 feet wide and 100 feet

Segment A-2 (West of Tecate)

Segment A-2 will be approximately 0.8 miles in length, starting on the east at the end of the
existing landing mat fence, extending west to the base of the Tecate Peak (insert figure 2-2 from

To construct the PV-1 fence along the chosen alignment, approximately 30,000 yds3 of cut-and-
fill slopes will be utilized. Connected and parallel to the PV-1 fence footprint, a 60-foot wide
border fence patrol road is proposed. The border fence patrol road will parallel the length of the
new fence and terminate where the proposed fence stops.

Otay-West Tecate Draft Project Description 15 April 2008.doc

Site access from the west will be from the north utilizing State Route 94 and improving Tecate
Mission Road and South Grapeview to accommodate construction traffic (Figure x) and is
further addressed above in the Roads section.

The one (1) staging area for A-2 is located 0.5 mile east of the proposed fence segment. The
staging area will temporarily impact 2 acres and will be restored per the Conservation Measures

Table 2: Project Impacts by Segment, Action and Habitat Type

Fence  Access Road  Staging Area 
   Impacts   Impacts  Impacts          
Vegetation Habitat 
A‐1  A‐2  A‐1  A‐2  A‐1  A‐2  A‐1 Total  A‐2 Total  Total 
Diegan Coastal Sage 
62.3  3.5 
Scrub  9.4  4.2  1.2  2.0  72.9  9.6  82.6 
Mafic Southern Mixed 
Chaparral  0.2     5.1     14.7  0.0  14.7 
Mulefat Scrub  0.2     0.2     0.5     0.9  0.0  0.9 
Southern Coast Live Oak 
11.5  0.5 
Riparian Forest  0.9  0.3  1.0     13.4  0.8  14.2 
Southern Mixed 
29.7  22.0 
Chaparral  15.5     4.5     49.7  22.0  71.7 
Non‐Native Grassland     0.9              0.0  0.9  0.9 
Whitethorn Chaparral     0.2              0.0  0.2  0.2 
Burned Riparian Scrub        4.4           4.4  0.0  4.4 
Chamise Chaparral        6.8           6.8  0.0  6.8 
Disturbed        0.6  0.1        0.6  0.1  0.7 
Landscaped        4.3  0.1        4.3  0.1  4.4 
Perennial Native 
Grassland              0.2  0.0  0.2 
Southern Coast Live Oak 
6.9  0.4 
Riparian Forest              6.9  0.4  7.2 
Southern Cottonwood‐
Willow Riparian Forest              0.0  1.5  1.5 
Southern Interior Cypress 
7.5  0.4 
Forest              7.5  0.4  7.9 
Project Total  26.1  5.7  143.8  28.4  12.3  2.0  182.2  36.1  218.4 

The following conservation measures have been developed in consultation with CBP to address
the effects of the proposed project. The Service’s assessment of effects assumes that these
measures will be fully implemented.


1. For each project, CBP will either assume presence of a federally-listed species based on
suitable habitat or known presence, and implement appropriate measures or will, as part

Otay-West Tecate Draft Project Description 15 April 2008.doc

of project design and planning, perform pre-construction surveys. In California, there are
three “categories” of federally-listed species relating to the need for pre-construction

a. Species that use specific sites that are scattered over the wider landscape for
which not all sites have been identified: Surveys in and adjacent to project areas
that contain suitable habitat but do not have a recent record for the species may be
appropriate. Species presence may also be seasonal and surveys will take place
during periods the species will be present. This category includes the following
species razorback sucker, San Diego fairy shrimp, Riverside fairy shrimp, San
Diego button celery, spreading navarretia, Otay Mesa mint, and California Orcutt

b. Species with suitable habitat over an extensive area in which the species is not
evenly distributed: Surveys of the project area and adjacent areas that may be
affected will be completed before final planning to assist in avoidance and
minimization of effects. This category includes the following species: coastal
California gnatcatcher, least Bell’s vireo, southwestern willow flycatcher, Yuma
clapper rail, brown pelican, yellow-bellied cuckoo, Quino checkerspot butterfly,
arroyo toad, desert tortoise, San Diego thornmint, Willowy monardella, Encinitas
baccharis, Mexican flannelbush, Otay tarplant, San Diego ambrosia, Peirson’s

c. Species that are highly mobile and may be found at various locations within the
occupied area depending on resource availability, seasonal use patterns, or
migratory behavior: Surveys may be effective; however, due to the mobility of
the species, they will only be viable for a limited time. Knowledge of seasonal
movements and habitat use may be of more value than a site-specific survey for
these species. This category includes the following species: Peninsular Bighorn

2. Areas to be surveyed will be identified by the Service and/or project biologists. Survey
protocols exist for several species and will be followed to accurately discern presence or
absence. Surveys will be conducted prior to construction related impacts to aid in
determining project effects. Surveys will be conducted during the most opportune time.
In addition to presence or absence information, the locations of the said species, their
territories/occupied habitat (including all stages of life history), and associated corridors
and linkages (including cross-border) will be mapped and provided to the Service prior to
project related impacts (not including geotechnical activities).

3. Relocation of federally-listed species from proposed impact areas will be determined by

the Service on a species-by-species basis prior to project impacts (not including
geotechnical). Specific relocation measures will be provided by the Service for those
species. Generally, species unable to voluntarily vacate the impact area will be relocated.
Relocations will occur prior to those impacts deemed adverse to the subject species.

Otay-West Tecate Draft Project Description 15 April 2008.doc

4. With the assistance of the Service, individual federally-listed species found in the project
area will be relocated by a qualified specialist (an individual or agency personnel with
permits to handle the species) to a nearby safe location and in accordance with accepted
species handling protocols. The Service will assist CBP in finding suitable locations.

5. Construction work areas will be delineated and marked clearly in the field prior to habitat
clearing, and the marked boundaries maintained throughout the construction period.
Construction work areas include staging, laydown, temporary stockpiling, access and
haul roads, etc.

6. An employee education program will be developed. Each employee (including

temporary, contractors, and subcontractors) will receive a training/awareness program
prior to working on the proposed project. They will be advised of the potential impact to
the federally-listed species and the potential penalties for taking such species. At a
minimum, the program will include the following topics: occurrence of the listed and
sensitive species in the area, their general ecology, sensitivity of the species to human
activities, legal protection afforded these species, penalties for violations of Federal and
State laws, reporting requirements, and project features designed to reduce the impacts to
these species and promote continued successful occupation of the project area environs.

Included in this program will be color photos of the listed species, which will be shown
to the employees. Following the education program, the photos will be posted in the
contractor and resident engineer office, where they will remain through the duration of
the project. The CBP and designated biological monitor will be responsible for ensuring
that employees are aware of the listed species.

7. CBP will designate a qualified biologist who will serve as a biological monitor for
overseeing compliance with protective measures for federally-listed species during
construction activities within designated areas. The Service will assist CBP in finding
qualified biologists. The biological monitor will immediately notify the project
proponent's designated representative to halt all associated project activities which may
be out of compliance with the ESP. In such and eve, CBP will halt all construction
activities and contact the Service within 24 hours.

8. If an individual of a federally-listed species is found in the designated project area, work

will cease in the area of the species until either a qualified biological monitor can safely
remove the individual, or it moves away on its own.

9. The biological monitor will monitor construction activities within designated areas during
critical times such as breeding seasons, vegetation removal, the installation of BMPs and
ESA fencing, and all avoidance and minimization measures are properly constructed and

10. Construction speed limits will not exceed 35 mph on major unpaved roads (graded with
ditches on both sides) and 25 mph on all other unpaved roads.

Otay-West Tecate Draft Project Description 15 April 2008.doc

11. Transmission of disease vectors and invasive non-native aquatic species can occur if
vehicles cross infected or infested streams or other waters and water or mud remains on
the vehicle. If these vehicles subsequently cross or enter uninfected or infested waters,
the disease or invasive species may be introduced to the new area. To prevent this,
crossing of streams or marsh areas with flowing or standing water will be avoided, and if
not, the vehicle sprayed with a 10% bleach solution or allowed to dry completely to kill
any organisms.

12. All equipment maintenance, staging, laydown, and dispensing of fuel, oil, or any other
such activities, will occur in designated upland areas. The designated upland areas will
be located in such a manner as to prevent any runoff from entering waters of the United
States, including wetlands.

13. Typical erosion control measures, BMPs, throughout the project area will be employed in
accordance with the Project SWPPP and all conditions in the 401 Water Quality
Certification requirements of the Regional Water Quality Control Board.

14. No off-road vehicle activity will occur outside of the project footprint by the project
proponent, project workers, and project contractors.

15. Normal CBP operations are assumed to continue to use designated unpaved roads
adjacent to and within the project footprint for the duration of project construction.

16. No pets owned or under the care of CBP or any and all construction workers will be
permitted inside the project’s construction boundaries, adjacent native habitats, or other
associated work areas.

17. Light poles and other pole-like structures will be designed to discourage roosting by
birds, particularly ravens or other raptors that may use the poles for hunting perches, by
installing bird control products (e.g. those manufactured by Bird-B-Gone).

18. To prevent entrapment of wildlife species during the construction of the project, all
excavated, steep-walled holes or trenches more than 2 feet deep will be covered at the
close of each working day by plywood. Each morning before the start of construction
and before such holes or trenches are filled, they will be thoroughly inspected for trapped
animals. Any animals so discovered will be allowed to escape voluntarily, without
harassment, before construction activities resume, or removed from the trench or hole by
the biological monitor or other qualified biologist and allowed to escape unimpeded.

19. Existing roads will be utilized to the extent practical. If an existing road is available for
project purposes, even if improvement is necessary, the said road will be utilized.

20. Potential for erosion off the designated road bed into federally-listed species habitat will
be avoided or minimized.

Otay-West Tecate Draft Project Description 15 April 2008.doc

21. Potential for entrapment of surface flows within the roadbed due to incisement or edging
berms created by grading will be avoided or minimized.

22. Widening of existing or created roadbed beyond the design parameters due to improper
maintenance and use will be avoided or minimized.

23. Stream crossings will not be located near or at bends or meanders but rather at straight
stream reaches where channel stability is enhanced.

24. Excessive use of unimproved roads that results in their deterioration such that it affects
the surrounding T&E species habitat areas will be monitored and corrective maintenance

25. The minimal number of roads needed for proposed actions will be constructed and
maintained to proper standards. Roads no longer needed will be closed and restored to
natural surface and topography using appropriate techniques. The GPS coordinates of
roads that are thus closed will be recorded and integrated into the OBP GIS database
maintained in Washington D.C.

26. Roads will be designed to minimize road kill and fragmentation of federally-listed
populations. Underpasses for wildlife may be appropriate to minimize road kill and
population fragmentation. Exclusion fencing may be appropriate where road kill is likely
or to direct species to underpasses or other passageways.

27. Disturbed areas will be utilized to the extent practical for any construction related
activities, to include staging, laydown, stockpiling, etc.

28. All construction will follow CBP’s management directive 5100 for waste management.

29. A CBP-approved spill protection plan will be developed and implemented at construction
and maintenance sites to ensure that any toxic substances are properly handled and
escape into the environment prevented. Agency standard protocols will be used. Drip
pans underneath equipment, containment zones used when refueling vehicles or
equipment, and other measures will be included as appropriate.

30. Waste materials and other discarded materials will be removed from the site as quickly as

31. Waste water (water used for project purposes that is contaminated with construction
materials, was used for cleaning equipment and thus carries oils or other toxic materials
or other contaminants in accordance with state regulations) will be stored in closed
containers on site until removed for disposal. Concrete wash water will not be dumped
on the ground, but will be collected and moved offsite for disposal.

Quino checkerspot

Otay-West Tecate Draft Project Description 15 April 2008.doc

32. Prior to project impacts (excluding geotechnical), all patches of dwarf plantain (Plantago
erecta), and/or other known host plants (Plantago spp.; plantain, Castilleja exserta;
annual owl's clover, and Cordylanthus rigidus; thread-leaved birdsbeak) occurring within
and immediately adjacent to the project footprint, will be clearly delineated by a biologist
with experience identifying quino habitat and familiar with the areas of known quino
activity near the construction corridors. The host plant areas determined to be within the
project footprint will be delineated for future reference. The host plant areas determined
to be immediately outside of the project footprint will be delineated with orange snow
fencing during construction activities to avoid additional direct impacts.

33. The delineated host plant areas within and immediately adjacent to the project footprint
will be surveyed for quino larvae. All quino larvae identified on these plants will be
relocated and reared and released in-situ (ranching). Larvae to be relocated will be
removed by a qualified biologist and placed on appropriate potted host plants located at a
suitable predetermined area(s). The Service will assist CBP in locating qualified
biologists and suitable areas.

34. All host plants within the designated impact areas will be removed after quino larvae
have been removed.

Arroyo Toad
35. If facilities will be located within 0.3 mile of toad habitat, the facility will be placed as
near the outer edge of the area with as little ground disturbance as possible, vegetation
clearing will be limited, and erosion control measures put in place to reduce sediment

36. All new roads will be designed to minimize the risk of erosion or adverse effects to
aquatic habitats of the toad. Routes that cross seasonally or perennially flowing streams
will be avoided. If not avoidable, crossings will be designed to minimize effects to
streams through use of culverts or other design features that protect natural substrates and

37. The biological monitor will monitor arroyo toad activity during project construction to
minimize impacts to toads. Monitoring will be accomplished during the breeding season
as well as during precipitation events when toads will likely become active. The
biological monitor will survey all project areas utilized during construction (roads,
staging, construction, laydown, etc.) which occur in or adjacent to arroyo toad habitat.
Detected toads will be counted and moved a safe distance outside of harms way.
Occurrences of such will be reported to the Service by COB the next business day.

38. Whether or not a simulated precipitation event is done, arroyo toads found within the
Project footprint will be captured and translocated by a qualified biologist to the closest
area of suitable habitat. The biologist will coordinate with the appropriate property
owner(s) to allow for any arroyo toads to be placed there. The Service will assist CBP in
locating qualified biological monitors.

Otay-West Tecate Draft Project Description 15 April 2008.doc

39. During the removal of toads, a qualified biologist will maintain a complete record of all
arroyo toads encountered and moved. The date, time of capture, specific location of
capture (using Global Positioning System) will be recorded and provided to the Service,
within one month (30 days) of the completion of translocation. The information will be
in a report formation and supplied in both hardcopy and digital format. The Service will
assist CBP in locating qualified biologists.

40. To avoid transferring disease or pathogens between aquatic habitats during surveys and
handling of arroyo toads, the qualified biologist will follow the Declining Amphibian
Population Task Force’s Code of Practice (DAPTF, 1991) or newer version when

41. High-velocity releases from the project activities (during and after construction) that
could degrade habitat will be avoided.

42. Any use or storage of chemicals or fuels at construction sites or staging areas will be kept
0.3 mile away from toad habitat.

43. Use of herbicides will not occur within toad habitat.

Encinitas baccharis, Mexican flannelbush and Willowy monardella

44. If facilities will be located within or adjacent to occupied habitat, surveys to document
the numbers and distribution of individual will be conducted, and the project will be
designed to avoid individuals to the extent possible.

45. Individuals to be impacted by the proposed project will be translocated to a suitable site,
using appropriate techniques. The Service will assist CBP in locating suitable sites and
identifying appropriate techniques.

46. The biological monitor will advise and monitor construction activities to avoid accidental
damage to nearby individuals outside of the designated impact area.

San Diego thornmint, Otay tarplant and San Diego ambrosia

47. If facilities will be located within or adjacent to occupied habitat, surveys to decipher the
extent of occupied habitat will be conducted, and the project will be designed to avoid
individuals to the extent possible.

48. The biological monitor will supervise construction activities to avoid accidental damage
to nearby individuals outside of the designated impact area.


Road Tackifer-Binding Agent

49. Soil binding agent will be applied during the late summer/early fall months to avoid
impacts to federally-listed species. Soil binding agents will not be used in or near surface
waters (e.g. wetlands, perennial streams, intermittent streams, washes, etc.).

Otay-West Tecate Draft Project Description 15 April 2008.doc

Canyon Fills
50. Fill slopes associated with canyon fills will be restored per measures 52-54, using native
species. If slope stabilization is necessary (e.g. gabions, riprap), such material will be
only be placed at the toe-of-slope and in a manner that will not preclude fauna from
accessing the fill slopes, the culvert/underpass, and the habitat beyond the fill slopes.

Exotic/Nuisance Species Control

51. Monitoring, treatment, and management of exotic/nuisance plant species will occur on a
yearly basis along all roads and new fence alignments within A-1 directly impacted by
this project for five years. This includes those portions of Otay Truck Trail, Puebla Tree
Spur Road, Marron Valley Road, Monument 250 Road, the new border fence patrol road,
the new border fence alignment, cat-trails, turnarounds, and staging areas. CBP will
coordinate with the appropriate agencies (e.g. Fish and Wildlife Service, Bureau of Land
Management, and City of San Diego).

The following apply as off-setting conservation measures for temporary impacts (e.g. staging
areas, temporary roads, pull-outs).

52. All generally native areas, as opposed to generally developed areas, temporarily impacted
by work activities (e.g. staging areas, temporary access roads) will be re-vegetated with
native plant species using a standardized restoration plan. The restoration plan will
describe revegetating all temporarily disturbed areas associated with the proposed
project. All native seed and plant stock will be from seed and propagules collected
within a five-mile radius of the work area to the extent practicable. All seeding will
occur during the first winter or fall following completion of the work, prior to expected
winter rains.

53. No invasive exotic plant species will be seeded or planted adjacent to or near sensitive
vegetation communities or waters of the U.S. In compliance with Executive Order
13112, impacted areas will be reseeded with plant species native to local habitat types,
and will avoid the use of species listed as High or Moderate in the California Invasive
Plant Council's Invasive Plant Inventory (Revision 2005) California to the extent
practicable. Areas hydroseeded for temporary erosion control measures will use only
native plant species appropriate to surrounding habitat types.

54. Temporary impact areas will be restored in-kind, except temporary impacts to disturbed
habitat and non-native grassland in generally native areas will be revegetated with the
most appropriate native plant palette following completion of the work.

Otay-West Tecate Draft Project Description 15 April 2008.doc

Permanent Impacts
Mitigation of Land
Species Impact Notes
Ratio Habitat Management
to Offset
* Acreage includes 83.8 acres of
impacted Quino habitat and 92.4
acres of impacted Quino and
Quino Annual gnatcatcher habitat. Therefore,
checkerspot 176.2* 3 to 1 528.6 management the protection of 277.2 acres of
butterfly (perpetual) habitat occupied by both species
would offset impacts to 92.4
acres of both Quino and
gnatcatcher habitat.
California Annual
coastal 92.4 3 to 1 277.2 management
gnatcatcher (perpetual)
Arroyo toad,
Least Bell's
vireo, and
14.7 3 to 1 44.1 management

Total 283.3 849.9

Temporary Impacts (staging areas)

* Acreage includes 9.6 acres of
impacted Quino habitat and 3.2
acres of impacted Quino and
Quino Restoration Management gnatcatcher habitat. Therefore,
checkerspot 12.8* of habitat 12.8 of habitat for the restoration of 12.8 acres of
butterfly (1:1) five (5) years habitat occupied by both species
would offset impacts to 3.2 acres
of both Quino and gnatcatcher

Otay-West Tecate Draft Project Description 15 April 2008.doc

California Restoration Management

coastal 3.2 of habitat 3.2 of habitat for
gnatcatcher (1:1) five (5) years

Arroyo toad,
Least Bell's
Restoration Management
vireo, and
1.5 of habitat 1.5 of habitat for
(1:1) five (5) years