ENVIRONMENTAL ASSESSMENT:
Proposed San Xavier Regional Detention
Center Project, San Xavier District, Arizona

Prepared for

BIA Papago Agency
Circle Drive, Bldg 49
Sells, Arizona 85634
and
The Tohono O’Odham Nation
2018 W. San Xavier Road
Tucson, Arizona 85746

Prepared by

CEI also known as BBAR Inc.
(Certified Environmental Inspectors)

May, 2009

ENVIRONMENTAL ASSESSMENT
PROPOSED SAN XAVIER REGIONAL DETENTION CENTER PROJECT,
SAN XAVIER DISTRICT, ARIZONA

For answers to questions, the public may contact:
Bureau of Indian Affairs
Papago Agency
Attn: Donna Peterson
Circle Drive, Bldg 49
Sells, Arizona 85634
Phone: (520) 383-3286
Email: donna.peterson@bia.gov
or
TOHONO O’ODHAM NATION
San Xavier District
Attn: Austin Nunez
Chairman, San Xavier District
2018 W. San Xavier Road
Tucson, AZ 85746
Phone: (520) 573-4006
Email: anunez@waknet.org

Prepared by
Ben B. Boothe
CERTIFIED ENVIRONMENTAL INSPECTORS
(CEI aka BBAR INC.)
9800 Verna Trail North
Fort Worth, TX 76108
(817) 738-9595
bba_a@hotmail.com

DISCLAIMER
Certified Environmental Inspectors (CEI) declares no financial or other interest in the
outcome of the proposed project, but is serving as independent consultant.

Certified Environmental Inspectors (CEI)

By: _Ben B. Boothe _________________
Title: _President, CEC, CEI___________
Date: April 20, 2009

TABLE OF CONTENTS
List of Acronyms ……………………….…………………………………………………………... i
List of Tables..……………...………………………………….…………………………………… ii
List of Figures..………………………………………………….…………………………………...ii
Abstract …………………………………………………………………………………….……iii-iv
CHAPTER 1 INTRODUCTION ………………………………………………………………….. 1
1.1 Purpose of the Environmental Assessment ……………………………………………… 1
1.2 Purpose and Need for the Proposed Action …………………………………………….. 1
1.2.1 Background and Mission of the U.S. Marshals Service ………………………….. 1
1.2.2 Fugitive Investigations ……………………………………………………………. 2
1.2.3 Protecting the United States Courts ………………………………………………. 2
1.2.4 Prisoner Custody and Transportation …………………………………………..... 2
1.2.5 Witness Security ………………………………………………………………….. 2
1.2.6 Asset Seizure ……………………………………………………………………… 2
1.2.7 Special Operations and Programs ………………………………………………… 3
1.2.8 Purpose of the Detention Services ……………………………………………….. 3
1.2.9 The National Picture ……………………………………………………………… 3
1.2.10 The Situation in Southern Arizona ………………………………………………. 4
1.3 Public Involvement ……………………………………………………………………. 4
1.4 Laws, Regulations, Permits and Approvals …………………………………………….. 5
CHAPTER 2 ALTERNATIVES ………………………………………………………………….. 7
2.1 Proposed Action ……………………………………………………………………….... 7
2.1.1 Description of the San Xavier District ……………………………………………. 7
2.1.2 Proposed Action Description …………………………………………………….. 7
2.1.3 Proposed Action Location ……………………………………………………….. 8
2.1.4 Proposed Action Development Consultants and Relationship of Parties …………. 10
2.1.5 Proposed Action Project Size …………………………………………………….. 10
2.1.6 Proposed Action Building Description …………………………………………… 10
2.1.6.1 Proposed Action Security………………………………………………… 11
2.1.7 Proposed Action Infrastructure Development …………………………………… 15
2.1.7.1 Onsite Waste Water Treatment System…………………………………… 15
2.1.7.2 Onsite Water System ……………………………………………………… 16
2.1.7.3 Water Treatment and Water Storage Tanks……………………………….. 16
2.1.7.4 Paved Access Roadways ………………………………………………….. 16
2.1.7.5 Paved Parking Lot ………………………………………………………… 16
2.1.7.6 Overhead Electrical Lines ………………………………………………… 16
2.1.7.5 Underground Gas ………………………………………………………… 17
2.1.7.5 Telephone Service ………………………………………………………… 17
2.1.8 Proposed Action Land Lease..…………..………………………………………… 17
2.1.9 Proposed Action Construction Activities…………………………………………...17
2.1.9.1 Construction Equipment…………………………………………………….17
2.1.9.2 Construction Activities…………………………………………………….. 18
2.1.10 Proposed Action Soil Erosion Control Measures ………………………………... 20

2.1.11 Proposed Action Storm Water Runoff Control…………………………………… 20
2.1.12 Proposed Action Site Surrounding Properties, Businesses, Land Uses …………. 20
2.2 Alternative Considered but Eliminated from Further Evaluation ……………….............. 24
2.2.1 Alternative Action Site #1 ……………………………………… ……………….. 24
2.2.2 Alternative Action Site #2 ……………………………………… ……………….. 24
2.2.3 Alternative Action Site #3 ……………………………………… ……………….. 25
2.3 No Action Alternative ………………………………………………………………….. 25
CHAPTER 3 AFFECTED ENVIRONMENT …………………………………………………….. 26
3.1 Land Resources …………………………………………………………………………. 26
3.1.1 Erosion, Slope, and Soil Suitability ………………………………………………. 26
3.1.2 Geology……………………………………………………………………………. 26
3.1.3 Minerals……………………………………………………………………………. 26
3.1.4 Topography………………………………………………………………………… 26
3.2 Water Resources ………………………………………………………………………… 27
3.2.1 Water Quality ……………………………………………………………………… 27
3.2.1.1 Groundwater…………….. ………………………………………………...…. 27
3.2.1.2 Surface Water………………………………………………………………. 27
3.2.2 Water Quantity ……………………………………………………………………. 27
3.2.3 Water Use …………………………………………………………………………. 27
3.2.4 Water Rights……………………………………………………………………….. 27
3.2.5 Floodplain………………………………………………………………………….. 28
3.3 Air Resources …………………………………………………………………………….31
3.4 Biological Resources ……………………………………………………………………. 31
3.4.1 Special Status Species …………………………………………………………….. 31
3.4.2 Wildlife Resources ………………………………………………………………… 32
3.4.3 Migratory Bird Treaty Act…………………………………………………………. 32
3.4.4 Vegetation …………………………………………………………………………. 32
3.4.5 Wetlands…………………………………………………………………………… 36
3.5 Cultural Resources ………………………………………………………………………. 36
3.5.1 Historical, Cultural, and Religious Properties …………………………………….. 36
3.5.2 Archaeological Resources ………………………………………………………….36
3.6 Socioeconomic Conditions ……………………………………………………………… 36
3.6.1 Employment and Income ………………………………………………………….. 36
3.6.2 Demographic Trends ………………………………………………………………. 37
3.6.3 Community Infrastructure …………………………………………………………. 37
3.6.4 Environmental Justice ……………………………………………………………... 38
3.6.5 Indian Trust Assets ………………………………………………………………... 39
3.7 Resource Use Patterns ……………………………………………………………………39
3.7.1 Hunting, Fishing, Timber Harvesting, and Gathering ….………………………... 39
3.7.2 Mining ……………………………………………………………………………... 39
3.7.3 Agriculture ………………………………………………………………………… 40
3.7.4 Recreation …………………………………………………………………………. 40
3.7.5 Transportation Networks ………………………………………………………….. 40
3.7.6 Land Use …………………………………………………………………………... 41
3.8 Other Values …………………………………………………………………………….. 43
3.8.1 Wilderness ………………………………………………………………………… 43
3.8.2 Sound and Light …………………………………………………………………... 43

3.8.3 Public Health and Safety …………………………………………………………...43
3.8.4 Solid and Hazardous Waste ………….……………………………………………. 43
3.8.5 Visual ……………………………………………………………………………… 43
CHAPTER 4 ENVIRONMENTAL CONSEQUENCES …………………………………………. 44
4.1 Land Resources ………………………………………………………………………….. 44
4.1.1 Proposed Action……………………………….……………………………………44
4.1.2 No Action Alternative ……………………………………………………………... 44
4.2 Water Resources ………………………………………………………………………… 44
4.2.1 Water Quality ……………………………………………………………………… 44
4.2.1.1 Proposed Action …………………………………………………………….. 44
4.2.1.2 No Action Alternative ………………………………………………………. 45
4.2.2 Water Quantity …………………………………………………………................ 45
4.2.2.1 Proposed Action…………………………………………………………….. 45
4.2.2.2 No Action Alternative ……………………………………………………….. 45
4.2.3 Water Use ………………………………………………………………................ 45
4.2.3.1 Proposed Action…………………………………………………………….. 45
4.2.3.2 No Action Alternative ……………………………………………………….. 46
4.2.4 Water Rights ………………………………………………………………………. 46
4.2.4.1 Proposed Action…………………………………………………………….. 46
4.2.4.2 No Action Alternative ……………………………………………………… 46
4.2.5 Floodplain ………………………………………………………………………... 46
4.2.5.1 Proposed Action…………………………………………………………….. 46
4.2.5.2 No Action Alternative ……………………………………………………… 46
4.3 Air Resources ……………………………………………………………………………. 46
4.3.1 Proposed Action ……………………………………………………………………46
4.3.1.1 Mitigation Measures ………………………………………………………… 47
4.3.2 No Action Alternative ……………………………………………………………...47
4.4 Biological Resources ……………………………………………………………………. 47
4.4.1 Proposed Action ……………………………………………………………………47
4.4.1.1 Mitigation….……………………………………………………................. 47
4.4.2 No Action Alterative……………………………………………………................. 48
4.5 Cultural Resources ………………………………………………………………………. 48
4.5.1 Proposed Action ………………………………………………………………….. 48
4.5.1.1 Mitigation Measures ………………………………………………………… 48
4.5.2 No Action Alternative ……………………………………………………………... 48
4.6 Socioeconomic Conditions ……………………………………………………………… 48
4.6.1 Proposed Action ……………………………………………………………………48
4.6.2 No Action Alternative ……………………………………………………………... 49
4.7 Resource Use Patterns…………………………………………………………………… 49
4.7.1 Hunting, Fishing, Timber harvesting, Gathering, Mining, Agriculture, and Recreation…. 49
4.7.1.1 Proposed Action…………………………………………………………….. 49
4.7.1.2 No Action Alternative ……………………………………………………….. 49
4.7.2 Transportation Networks ………………………………………………………….. 49
4.7.2.1 Proposed Action ……………………………………………………………. 49
4.7.2.1.1 Mitigation Measures …………………………………………………... 49
4.7.2.2 No Action Alternative ……………………………………………………….. 50
4.7.3 Land Use …………………………………………………………………………... 50
4.7.3.1 Proposed Action……………………………………………………………. 50

4.7.3.2 No Action Alternative …………………………………………………….. 50
4.8 Other Values …………………………………………………………………………….. 50
4.8.1 Wilderness ………………………………………………………………………… 50
4.8.1.1 Proposed Action……………………………………………………………... 50
4.8.1.2 No Action Alternative ……………………………………………………….. 50
4.8.2 Sound and Light ………………………………………………………………….. 50
4.8.2.1 Proposed Action …………………………………………………………….. 50
4.8.2.1.1 Mitigation ………….. ………………………………………………….50
4.8.2.2 No Action Alternative ………………………………………………………. 51
4.8.3 Public Health and Safety …………………………………………………………...51
4.8.3.1 Proposed Action…………………………………………………………….. 51
4.8.3.2 No Action Alternative ………………………………………………………. 51
4.8.4 Solid and Hazardous Waste Treatment …………………………………………… 51
4.8.4.1 Proposed Action…………………………………………………………….. 51
4.8.4.2 No Action Alternative ……………………………………………………….. 51
4.8.5 Visual ……………………………………………………………………………… 51
4.8.5.1 Proposed Action …………………………………………………………….. 51
4.8.5.2 No Action Alternative ……………………………………………………….. 51
4.9 Comparison of Alternatives ……………………………………………………………... 52
4.9.1 Summary of Cumulative Impacts …………………………………………………. 52
4.9.2 Summary of Unavoidable Adverse Impacts ………………………………………. 52
CHAPTER 5 CONSULTATION AND COORDINATION …………………………………….... 53
CHAPTER 6 LIST OF PREPARERS …………………………………………………………….. 54
CHAPTER 7 REFERENCES ……………………………………………………………………... 55
APPENDIX ... …………………………………………………………………………………….. 56
Exhibit A-1

San Xavier District Letter Verification of Public Meetings

Exhibit A-2

Legal Description of Proposed 48.8 Acre and 60’ Access and Utility

Easement
Exhibit A-3

San Xavier District’s Attorney Letter Describing District’s Water Rights

Exhibit A-4

Biological Resource Clearance Letter

Exhibit A-5 - A-10

Pima County Endangered Species List

Exhibit A-11

Wetland Map Sahuarita, Pima County

Exhibit A-12-A13

Natural Resources Conservation Services Depth to Water Table Map

Exhibit A-14-A17

Natural Resources Conservation Services Flooding Frequency Map

Exhibit A-18-A-19

BIA correspondence to SHIPO regarding No Historic Properties Affected

Exhibit A-20

BIA correspondence, Determination of No Historic Properties Affected

CHAPTER 1
INTRODUCTION
1.1 PURPOSE OF THE ENVIRONMENTAL ASSESSMENT
This document, together with its appendices and incorporations by reference, constitutes an
Environmental Assessment (EA) prepared under the guidelines pursuant to the National
Environmental Policy Act (NEPA) of 1969, as amended. Its purpose is to present an
assessment of the environmental consequences of a Proposed Action by the San Xavier
District to enter into a contract agreement with a private contractor to operate a Regional
Detention Center to house not less than 750 or more than 1500 adult detainees. For the
purpose of this EA the Proposed Action of the ultimate size of 1500 adult beds is being
evaluated.
The EA, the assessment it presents, and the procedures by which the environmental
investigations are conducted and incorporated in decision-making are parts of a process
established by NEPA to ensure that the environmental consequences of federal actions are
adequately taken into account. The BIA’s approval of the Lease agreement between the Land
Owners (allottees) and the District, constitutes a Federal action requiring an EA. The process
is designed to ensure that public officials make decisions based on a full understanding of the
environmental impacts of Proposed Actions and takes all appropriate steps to "protect,
restore and enhance the environment" (40 CFR 1501.7). The purpose of this document is to
allow for meaningful public review and comment on potential environmental impacts that
may result from procuring detention services at a site.
1.2 PURPOSE AND NEED FOR THE PROPOSED ACTION
The primary need for this Proposed Action was decided by the citizens of the San Xavier
District of the Tohono O’odham Nation (the District) through their elected tribal leaders, to
seek a private operator to bring a facility to the Reservation to assist in the community’s
economic development.
The purpose of this facility is to house up to 1500 adults which may include, Federal, State,
County and Tribal detainees. Agencies that may use the facility, but have no commitment or
contractual obligation at this time, include cities, county Sheriff offices within the region, the
Arizona Department of Corrections (ADOC), Immigration and Customs Enforcement (ICE),
Federal Bureau of Prisons (FBOP) and the United States Marshals Service (USMS). A
discussion of the USMS mission, activities and current and anticipated long term need for
detention bed spaces is provided in sections 1.2.1 through 1.2.10. This discussion is provided
as an example of just one of the many agencies who could contract for bed space in the
District should this facility be constructed at the proposed location in the San Xavier District.
1.2.1 Background and Mission of the U.S. Marshals Service
It is likely that the USMS will utilize the proposed San Xavier Regional Detention Center,
therefore a discussion regarding the background and mission of the USMS is provided for the
readers benefit. The USMS is the nation’s oldest and most versatile federal law enforcement
agency. Created by the Judiciary Act of 1789, the same legislation that established the federal
__________________________________________________________________________________________
Page 1

judicial system, the USMS has served the nation through a variety of vital law enforcement
activities. The Director, Deputy Director and 95 U.S. Marshals (appointed by the President or the
Attorney General) direct the activities of District offices and personnel stationed at more than 350
locations throughout the 50 states and U.S. territories. The USMS occupies a uniquely central
position in the federal justice system and is involved in virtually every federal law enforcement
initiative. Approximately 4,000 Deputy Marshals and career employees perform a variety of
nationwide, day-to-day missions as described below.
1.2.2 Fugitive Investigations
The USMS has primary jurisdiction nationwide in conducting and investigating fugitive
matters involving escaped federal prisoners, probation, parole, and bond default violators, and
warrants generated by the Drug Enforcement Administration (DEA) investigations and
certain other related felony cases. The USMS is responsible for the "15 Most Wanted"
fugitives listing and provides support in the areas of domestic and international investigations,
electronic surveillance and analytical support
1.2.3 Protecting the United States Courts
Providing personal protection to federal judges, court officials, witnesses, and jurors is a
principal mission of the USMS. In the Marshal Districts, this means ensuring security and
maintaining decorum within the courtroom itself, as well as personal protection for judicial
officers, witnesses, and jurors away from the court facilities when warranted. The scope of the
Marshals Service Court Security program includes protection for more than 2,000 federal
judicial officers as well as countless other court officials, jurors, and witnesses. There are
currently more than 700 locations where court proceedings are held throughout the nation.
The USMS administers contracts for approximately 3,000 Court Security Officers who secure
building entrances at more than 450 court facilities in the United States and its territories.
1.2.4 Prisoner Custody and Transportation
The USMS assumes custody of individuals arrested by all federal agencies and is responsible
for the housing, medical care and transportation of prisoners from the time they are brought
into federal custody until they are either acquitted or incarcerated.
1.2.5 Witness Security
The Witness Security Program was authorized in 1970 by the Organized Crime Control Act
of 1970 (Public Law 91-452) and was amended by the Comprehensive Crime Control Act of
1984. Through this program, the USMS provides for the security, health, and safety of
government witnesses, and their immediate dependents, whose lives are in danger as a result
of their testimony against organized crime, drug traffickers, terrorists and other major
criminals. Since 1970, witnesses have entered the Witness Security Program and have been
protected, relocated, and provided with new identities by the USMS. The successful operation
of this program by the USMS is widely recognized as providing a unique and valuable tool in
the government's war against major criminal conspiracies and organized crime. In both
criminal and civil matters involving protected witnesses, the USMS cooperates fully with
local law enforcement and court authorities in bringing witnesses to justice or in having them
fulfill their legal responsibilities.
1.2.6 Asset Seizure
In 1984, Congress enacted the Comprehensive Crime Control Act, giving federal prosecutors
new forfeiture provisions to combat crimes and creating the Department of Justice Assets
Forfeiture Fund. The proceeds from the sale of forfeited cars, real estate, jewelry and other
forms of property, as well as tainted cash, are deposited into this fund and reinvested into law
enforcement activities. The Marshals secure custody, inventory, appraise, store and maintain
Page 2

property until the final court order is entered. Professional companies under contract to the
agency do much of the work in this program. The volume and complexity of some types of
assets require considerable knowledge and skill to be successfully managed. The USMS
provides property services to the DEA, Federal Bureau of Investigation, immigration
Naturalization Service, U.S. Postal Inspection Service and the Food and Drug Administration.
These federal agencies work with state, local and international enforcement agencies to
investigate seized asset cases. At the conclusion of forfeiture cases, participating state and
local agencies can apply for an equitable share of the proceeds.
1.2.7 Special Operations and Programs
Deputy U.S. Marshals carry out hundreds of special missions yearly that are related to the
USMS's broad federal law enforcement and judicial security responsibilities. These include
the Special Operations Group (SOG) a specially trained and highly disciplined tactical unit
that respond to emergencies anywhere in the United States or its territories. The SOG's
missions include: fugitive apprehension; dignitary protection; court security; transporting
high profile and dangerous prisoners; witness security; and asset seizures. Additional special
missions include the Missile Escort Program and the Judgment Enforcement Teams.
1.2.8 Purpose of the Detention Services
The purpose of the proposed detention services is to house detainees having business before
the federal courts in the USMS Southern District of Arizona, i.e., individuals arrested for
violation of federal statutes and not released on bond while awaiting trial. The USMS
assumes custody of individuals arrested by all federal agencies and is responsible for the
housing, medical care, and transportation of prisoners from the time they are brought into
federal custody until they are either acquitted or incarcerated. These individuals are
principally detained by USMS either in federally-owned and operated facilities, or through
Intergovernmental Agreements (IGA) or the Cooperative Agreement Program (CAP) with
state and local facilities, where bed space is obtained on a per diem basis. Current housing
and transport arrangements in southern Arizona are both inadequate and inefficient, due to the
growth in the number of detainees and reduction of available detention bed space.
1.2.9 The National Situation
During the past decade, the federal detainee population has experienced unprecedented
growth as a result of expanded federal law enforcement initiatives and resources. The
detainee population has increased by more than 825 percent, from almost 4,000 in 1981 to
more than 36,000 today. Current projections indicate the USMS prisoner population will
reach a level of approximately 42,000 by FY 2002, and approximately 47,000 by FY 2003.
These prisoners will be housed in a combination of Federal, state, local and private facilities
around the country. The growth in the detainee population is occurring at the same time that
available Federal, state, local, and private jail space is decreasing. Local jail space is
increasingly needed to house local offenders, leaving less space available for housing federal
detainees. These trends are projected to continue unabated for the foreseeable future and
present a major challenge for federal agencies responsible for detaining prisoners.
Faced with severe shortages in state and local bed space, especially in major metropolitan
areas (federal court cities), as well as court ordered caps on prisoner populations, the USMS
is finding it increasingly difficult to locate bed space in state and local jails that have
traditionally been used to house federal prisoners. Consequently, the USMS periodically
contracts with the private sector for detention services or houses detainees farther and farther
from their respective federal court cities. The resultant long-distance movement of federal
detainees involves substantial amounts of USMS time and resources, and strains the Justice
Prisoner and Alien Transportation System to its limits.

Page 3

1.2.10 The Situation in Southern Arizona
The USMS has an immediate and long-term need for approximately 1500 prisoner beds
located within proximity to the federal courthouse in Tucson. The high level of criminal
activity in the southwestern United States requires more beds than are readily available in
local or state facilities. The shortage of beds has been ongoing for more than two years. The
USMS has a specific need for detention facilities to be located near federal courthouses
because of its responsibility to detain those individuals accused of violating federal laws.
The USMS has detainees scattered among numerous county jails throughout south and west
Arizona, some farther than 300 miles away. Obtaining available detainee bed space from local
facilities has become increasingly difficult. The USMS often moves a prisoner from jail to jail
numerous times before they are sentenced. The USMS estimates that it spends at least half a
million dollars a year to transport prisoners. For security and logistical purposes, the USMS
prefers that detainees be housed at consolidated locations proximate to federal court cities.
1.3 PUBLIC INVOLVEMENT
The subject San Xavier Regional Detention Center Project has been an ongoing project for
several years. The San Xavier District has conducted public meetings, and these have been
advertised by public notice in appropriate local media, with Tribal leaders, members, and
members of the community at large invited. At these meetings, the project has met with
favorable support within the community. Public meetings took place at the District Meeting
Room located at 2018 W. San Xavier Road, Tucson, AZ 85746 on the following dates:
07/25/06 and 08/01/06. A letter from the Chairman of the District, Mr. Austin Nunez,
confirming the dates of the public meetings can be found in the Appendix, Exhibit A-1.
This environmental report will be available for public review for a 15-day public comment
period beginning in May 2009. The commencement date for the public comment period will
be advertised by District officials in the appropriate public sources. This EA will be available
at the following locations:
San Xavier District - Office of Economic Development
2018 W. San Xavier Road
Tucson Arizona 85746
and
BIA Papago Agency
Circle Drive, Bldg 49
Sells, Arizona 85634
At the conclusion of the 15-day public comment period, the BIA will review public
comments, respond where appropriate, and issue a Final EA.

1.4 LAWS, REGULATIONS, PERMITS AND APPROVALS
Page 4

In accordance with 25 U.S. Code [USC] 415, 25 Code of Federal Regulations [CFR] 162 and the
terms of the Bureau of Indian Affair’s (BIA), the proposed signing of the Detention Center’s
lease by the District and the Allottees, requires the approval of the Superintendent of the Papago
Agency of the BIA. The above-mentioned lease is for a tract of land owned by approximately 44
Alottees. The proposed lease area is a 48.8-acre tract and use of a 60-foot wide Access and
Utility Easement (easement contains approximately 5.6 acres) hereinafter referred to as the
subject site. The subject site is contained within a 160-acre parcel, out of Township 16 south,
Range 13 east, Section 25, Allotment 127, Pima County, Arizona.
An Environmental Assessment (EA) is required because approvals by the BIA constitute a major
federal action under the National Environmental Policy Act (NEPA) of 1969 (42 USC 4371 et
seq., as amended). The BIA is the reviewing agency under NEPA. The BIA is the lead federal
agency. This EA was prepared in accordance with NEPA and the Council on Environmental
Quality Guidelines for Implementing NEPA (40 CFR, Parts 1500-1508). As part of this EA,
attention was given to the following laws and regulations:
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American Indian Religious Freedom Act (42 USC 1996)
Archaeological Resources Protection Act (16 USC 470aa-mm)
Clean Air Act (42 USC 7401 et seq.)
Clean Water Act (33 USC 1251 et seq.)
Comprehensive Environmental Response, Compensation and Liability Act (42 USC 9601 ct
seq.), and Superfund Amendments and Reauthorization Act (42 USC 11001 et seq.)
Endangered Species Act (16 USC 1531-1542)
Executive Order 11593, Protection and Enhancement of the Cultural Environment
Executive Order 11988 on Floodplain Management
Executive Order 12898 on Environmental Justice
Farmland Protection Policy Act (Public Law 97-98)
National Historic Preservation Act (16 USC 470 et seq.)
Native American Graves Protection and Repatriation Act (25 USC 3001)
Resource Conservation and Recovery Act (42 USC 6901 et seq.)
Safe Drinking Water Act (42 USC 300f et seq.)
Southern Arizona Water Rights Settlement Act of 1982, Public Law 97-293, and Southern
Arizona Water Rights Technical Amendments Act of 1992, Public Law 102-497 (collectively
SAWRSA)

Other Permits/Approvals that may be required for the project are included in Table 1 on the
following page.

Page 5

TABLE 1 – Agency / Permits & Approvals
Agencies
San Xavier District Office

Permits/Approvals
Building permits (Building Construction to conform to 2006
International Building Code (IBC)
American Correctional Association ACA Building and Operational Accreditation
(ACA)
Arizona Department of Corrections ADOC Certification of Facility prior to occupancy by State
(ADOC) Standards
Pima County and Arizona Department Highway access permits
of Transportation
Environmental Protection Agency Wastewater permits and water treatment permits, 401 (Water
(EPA) Region IV, and the Office of Quality Certification under the Clean Water Act)
Environmental
Health
Services
(OEHS)
(EPA) Region IV
Notice of intent (NOI), Erosion control and storm water
pollution and prevention plan
Arizona State Historic Preservation Section 106 Consultation under the National Historic
Office
Preservation Act
US Fish & Wildlife Service
Section 7 consultation under the Endangered Species Act
US Corp of Engineers
404 Nationwide Permit #14 Linear Transportation Crossings
The appropriate building code for the Proposed Action will be the 2006 International Building
Code (IBC 2006) with current amendments. The project will also be designed in accordance
with ACA and ADOC standards. Health Codes are not applicable to this project during
construction; however, during operation the Indian Health Services Office of Environmental
Health, Health Codes will apply and inspections by this entity will be on an annual basis. In
addition any of the agencies utilizing detention bed space will have their own health
inspections prior to placing inmates in the facility. Construction Safety Standards will be
OSHA. There are no other known federal, state, or tribal permits required for this project.

Page 6

CHAPTER 2
ALTERNATIVES
The following chapter describes the alternatives evaluated in this document: the Proposed Action,
Alternative Action and No Action. Included in the Proposed Action is a description of the
intended uses of the parcel following approval of the lease and amendments. Also included in this
chapter is a discussion of the alternatives considered but eliminated from further consideration.
Alternative action is deferred as an action to be available (if any) if the “Proposed Action” or “No
Action” are not utilized.

2.1 PROPOSED ACTION
2.1.1 Description of the San Xavier District
The Tohono O’odham (formerly known as Papago) Nation sits in the heart of the Sonoran Desert,
sixty miles west of Tucson, Arizona. The Tohono O’odham live on four separate land bases
totaling more than 2.7 million acres, which is comprised of the main reservation, the San Xavier
District, the San Lucy District and the Florence Village. The main reservation is located in south
central Arizona and includes the Sells community, which serves as the Nation’s Capital.
Approximately 18,000 of the tribe’s 24,000 members live on this main section of the Tohono
O’odham Reservation. The San Xavier District is located just south of Tucson. The San Lucy
District is located near the city of Gila Bend. Florence Village is near the city of Florence,
southeast of Phoenix.
2.1.2 Proposed Action Description
The Proposed Action (project) involves the development of a 1500-bed Regional Detention Center to
be developed for and placed within the San Xavier District reservation. The development of the
Detention Center will include construction of the building, an onsite waste water treatment system,
water wells, reverse osmosis water treatment plant and a water storage tank with pumping facilities.
This Proposed Action was developed for the tribe with the concept of an economic development
project that would be derived from:
1.
2.
3.
4.

The creation of construction jobs.
Permanent jobs as detention and ongoing operational personnel.
Monies invested into the District for procurement of goods and services.
Fees derived from the leasing of beds by the District to various agencies requiring
detention bed space.

The Proposed Action is feasible and will satisfy needs for additional detention/prison bed space in
the Tucson area. The proposed Regional Detention Center is to provide prison beds to
accommodate the national need for prison space in the USA and in this area. It is built due to
needs of national security and will also constitute an economic development enterprise for the
area, creating new jobs for the District and surrounding area. The facility will be of modern
construction with kitchen, recreational areas, cells, sally port, outdoor secured recreational areas
as well as clinic, library and rooms for meetings and administrative purposes.
Page 7

2.1.3 Proposed Action Location
The proposed facility is to be developed by the District. The proposed site for the facility is
located within the San Xavier District of the Tohono O’odham Indian Reservation. The
property is an undeveloped 48.8-acre tract and a 60’ wide access and utility easement (5.6
acres), within a 160-acre parcel, located in the northern third of allotment 127, Township 16
south, Range 13 east, Section 25 Pima County, Arizona. The general location of the site is 0.4
miles west of Nogales Highway, and approximately 3500 feet north of Pima Mine Road. A
copy of the survey (Figure 1) is presented on the following page. A copy of the legal
description for the site can be found in the Appendix, Exhibit A-2.

Page 8

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Figure 1- Subject Site Survey
Page 9

2.1.4 Proposed Action Development Consultants and Relationship of Parties
During the summer and fall of 2006, preliminary discussions and meetings with the District about the
concept of this project were held. The District, by resolution, selected a project team to explore and
develop this project. The Project Team includes:
•
•
•
•
•
•

Project Consultant and Developer - Innovative Government Strategies (IGS)
Detention Operator - Community Education Centers (CEC)
Project Financing - Municipal Capital Markets
Construction Manager at Risk - Hale-Mills Construction
Architecture - D L. Williams Architecture in association with Runyon Architects
Engineering - FCC Corp in association with DRW Engineering

The relationship between the various entities is as follows:
The Project Team is a consultant to the District. The District will own the facility and will
contract with the various project team members for various services including operation and
maintenance of the facility. The District will acquire the proposed 48.8-acre allotment and 5.6
acre access and utility easement from the Allottees for a 30-year lease period. The District, as a
part of this Proposed Action, will allocate 126 acre feet / year of water for the project. The BIA
will oversee and approve the leasing of the property from the Allottees to the District. The BIA
also is responsible for overseeing the development, publishing and presentation of the NEPA
documentation for this project to the public.
2.1.5 Proposed Action Project Size
The Proposed Action includes a building size of 1500 beds, a one-story structure comprising
approximately 230,180 square feet of building area.
2.1.6 Proposed Action Building Description
The 1500-bed San Xavier Regional Detention Center is a secure, adult detention facility that
is designed to be expandable. This main building is approximately 230,180 square feet,
situated on 48.8 acres. The exterior walls are concrete panels. The building structure is steel
frame with a standing seam metal roof. The facility is designed and will be constructed to
comply with applicable local, state and national codes.
The Administrative Area contains all functional space necessary to support the detention
facility. This area includes Lobby, Public Restrooms, Receptionist, Warden’s Office, 10+
additional Administrative Offices, Copy Room, Records, Inmate Phone Monitoring, Supplies,
Staff Lounge, Conference Room, Briefing/Training Room, and Staff Locker Rooms/Toilets.
The ceiling in the Administrative Area is acoustical ceiling tile. The floors in this area are
carpet or vinyl composition tile. The walls are metal studs with gypsum wall board and/or
concrete masonry unit.
Detainee Intake contains a secure Vehicular Sallyport, Intake Processing, Holding, Issue
Property Storage, Dress In/Dress Out, Intake Administrative Offices and Count/Movement
Room. The detainee Infirmary contains Nurse’s Station, Infirmary Holding Room, Exam
Rooms, Dental, Isolation Cells, Sick Ward, Telemedia Exam Room, Emergency Treatment,
Medication Room, Medical Records, Medical Staff Offices, Pharmacy, Medical Conference
Room, Medical Storage, Medical Library, Workroom, Staff and Detainee Toilets. The
Page 10

ceilings in these areas are concrete (as dictated by security requirements), gypsum board or
acoustical ceiling tile. The floors are either sealed concrete or vinyl composition tile. The
walls are concrete masonry unit and/or metal studs with gypsum wall board.
The detainee Housing contains (76) separation cells, (58) 8-person dorms, and (40) 24-person
dorms. There are Multi-purpose Rooms, Supplies, and a Control Picket in each detainee
“pod”. Detainee recreation areas are adjacent to each detainee “pod”. Both Contact and NonContact Visitation are provided for detainees and their visitors. The Central Control room is
located in the secure area, along with Barber, Commissary, Mail Room, Library and Supplies.
The ceilings in the detainee area are either concrete, security board or exposed to structure.
The floors are sealed concrete and the walls are grouted, reinforced concrete masonry units.
All detainee plumbing fixtures are detention grade stainless steel fixtures. The doors in the
detainee housing are security hollow metal and shall be equipped with detention grade
hardware. Remote operated locks shall be provided where required. Kitchen is fully equipped
with the appropriate kitchen equipment and food storage areas and is designed to
accommodate food preparation for 1500 detainees. The Staff Dining is adjacent to the
Kitchen. The commercial grade Laundry is equipped to accommodate 1500 detainees.
2.1.6.1 Proposed Action Security
The entire facility is monitored through closed circuit television at the Central Control
Room. All electric locks are operable from Central Control. An emergency generator
provides power to the facility in case of loss of power. The entire facility is surrounded
by a double security fence (twelve feet tall), with three rolls of razor ribbon applied to
both fences. A concrete anti-dig barrier 18” deep by 1.0’ is provided under the interior
security fence. A perimeter patrol road surrounds the building and will be monitored
by patrol car 24-hours a day. Security lighting to national security standards will be
provided along the security fence and exterior walls of the facility.
The following pages contain the following figures:
• Figure 2 - Aerial view of 48.8 acres and 60’ access and utility easement
• Figure 3 - Plan of Facility
• Figure 4 – San Xavier Regional Detention Center Floor Plan
On the aerial view it can be seen that approximately 25 acres of the 48.8 acres is planned to be
developed within the secure fence. The detention facility design incorporates large buffer areas
within the project acreage boundaries for increased security and visibility.

Page 11

Figure 2 - Aerial view of 48.8 acres and 60’ access and utility easement
Page 12

Figure 3 - Plan of Facility
Page 13

Figure 4 - Detention Center Floor Plan
Page 14

2.1.7 Proposed Action Infrastructure Development
The current 48.8-acre site and property for the 5.6 acre access and utility easement is
undeveloped. Infrastructure to be constructed to support the proposed Regional Detention Center
includes:
• Onsite waste water treatment system
• Onsite Water System
• Water Treatment and Water Storage Tanks
• Storm water Detention/Retention Ponds
• Paved Access Roadway
• Paved Parking Lot
• Overhead Electrical lines
• Underground Gas
• Telephone Lines
2.1.7.1 Onsite Waste Water Treatment System
Waste water treatment for the proposed Regional Detention Center will include onsite
construction of a package waste water treatment plant (WWTP) rated to treat 250,000
gallons per day (GPD) and construction of three, 5-acre lined evaporative ponds to
receive the treated effluent. The 250,000 gallons includes treatment of the estimated
100,000 gallons of waste water generated each day and a 2.5 design peak factor. A
permit to discharge the treated effluent will be prepared and submitted to the EPA to
provide the option of discharging the treated effluent into the dry wash located at the
south east end of the property which will allow flow offsite to the east and off
reservation property to the Santa Cruz River. The evaporative ponds have been designed
to store all treated effluent with an appropriate reserve capacity for rainfall and a low
evaporative occurring months.
The WWTP will consist of conventional waste water treatment trains that include:
•
•
•
•
•

Aeration Tanks (3)
Clarifier
Aerobic Digester
Chlorine contact tanks
Holding pond with 30 day reserve capacity

The liner of the evaporative ponds will be constructed of High Density Poly-Ethylene
(HDPE) or Hypalon fabric. Treated effluent may be utilized by the operator for
landscape irrigation onsite. The lined ponds will be connected by piping and valves to
allow flow from one pond to the other and for segregation for WWTP maintenance and
repair.
An Arizona registered Professional Engineer will design all WWTP plans and prepare
and submit the effluent discharge permit to the EPA for review and approval prior to
operation. The BIA and District will be sent copies of WWTP plans and Discharge
Permit Application and Final Permit for their records.
Page 15

2.1.7.2 Onsite Water System
Potable and Fire protection water for the proposed project will be provided by drilling
wells on site, construction of a reverse osmosis water treatment plant and construction of
ground storage water tanks for reserve capacities. Test wells will be drilled to determine
the permanent placement of water wells for the facility. Two wells will be drilled to
accommodate the required 75 gallons per inmate /day water usage (75 gallons x 1500 =
112,500 gallons per day. The 112,500 gallons of water per day equates to
approximately 126 acre feet per year (to be obtained from the San Xavier District). All
wells will be drilled within the 48.8 acre site.
2.1.7.3 Water Treatment and Water Storage Tanks
Existing water quality at the site meets drinking water standards based on sampling of
nearby wells and discussions with the District’s Hydrologist. However, the domestic
water will be treated by reverse osmosis to improve water taste and quality by treating
sulfates and Total Dissolved Solids (TDS) present in the groundwater. A single 500,000
gallon (or two 250,000 gallon) storage tanks will be constructed onsite and appropriately
sized domestic and fire protection booster pumps will be constructed to provide a
reserve capacity of water and fire protection capabilities for the facility.
2.1.7.4 Storm Water Detention
Storm Water Detention/ Retention Basins will be constructed onsite to contain the post
development runoff generated by the increase in impervious surface area created by the
development of the project. Detention /Retention Design for this project is based on the
Storm water Detention/Retention Manual published by the Pima County Department of
Transportation and Flood Control District of the City of Tucson. Design involves
calculating the existing condition peak runoff and the post development peak runoff for
various duration storms. Inflow and outflow hydrographs are calculated and a stage
storage model developed to determine the appropriate volume of storage for a given
area. Based on this criteria, the required storm water detention volume for this site is
calculated to be approximately 4.0 acre feet. The 4.0 acre feet will be detained in a
detention basin approximately 1.5 acres in size, 4.0’ deep located at the east end of the
parking lot.
2.1.7.5 Paved Access Roadways
Roadways to the site from Pima Mine Road and interior to the site will be constructed of
Asphalt paving or Chip Seal to meet traffic loading requirements. Storm water culverts
will be installed at the existing dry wash area at the south property line of the site.
2.1.7.6 Paved Parking Lot
The Parking lot for visitors and staff and all other parking areas will be asphalt
pavement.
2.1.7.7 Overhead Electrical Lines
Three phase electrical lines for the project will be installed from Pima Mine Road,
where main lines exist for connection to the north, within the 60’ Access and Utility
Easement to the project site.

Page 16

2.1.7.8 Underground Gas
Natural Gas lines for the project will be installed from Pima Mine Road where main
lines exist for connection to the north, within the 60’ Access and Utility Easement to the
project site.
2.1.7.9 Telephone Service
Underground telephone lines for the project will be installed from Pima Mine Road
where main lines exist for connection to the north, within the 60’ Access and Utility
Easement to the project site.

2.1.8 Proposed Action Land Lease
A lease is a legal instrument that provides for the contractual use or control of a property for a
given period of time. This Proposed Action cannot occur without a lease, because the lease
defines the financial value of the use or control of a property. The lease cannot, in this case, be
signed until the BIA approves the environmental and appraisal reports. Approval of the signing
of the lease by the BIA is central to defining the economic benefit of the control and use of the
project for financial gain.
The land lease is for a 48.8-acre tract of land known as a portion of Township 16 south, Range
13 east, Section 25, Allotment 127, Pima County, Arizona. The lease agreement also includes a
60’ wide access and utility easement comprising 5.6 acres that provides access to the site from
Pima Mine Road. The subject tract will be leased for the Proposed Action under a 30-year
lease for the purposes of constructing a 1500-bed Regional Detention Center. This EA is
concerned with the use of the land for the 30-year lease period; however, it is logical to
conclude that the facility would remain an ongoing enterprise if the goals and success of the
project are as anticipated. The responsibility of the Lessee is to pay the lease in accordance to
the terms of the lease and the responsibility of the Lessor is to appropriately abide by the
terms of the lease. Under the proposed lease agreement, the Allottees will be the Lessor with
the San Xavier District as the Lessee.
The term of the lease is 30 years. The Lessee shall pay compensation to the Lessor for the use of
the land. Other questions relating to the lease can be directed to Mr. Austin Nunez, Chairman of
the San Xavier District of the Tohono O’odham Nation.
2.1.9 Proposed Action Construction Activities
The current 48.8 acre site and the 5.6 acre easement area are undeveloped. The proposed
building and infrastructure design described in previous sections will result in utilization of
construction equipment and general construction activities described below:
2.1.9.1 Construction Equipment
During construction, the equipment to be used will be standard construction equipment,
including, but not limited to the following:
•

Equipment for Building Pad Construction – 3 Scrapers, 1 Paddle Wheel Scraper, 1
Blade, 1 D-9 Cat, 1 Water Wagon, 1 Water Truck, 1 Water Tower, 1 Raygo Steel
Face Roller, 1 Service Truck, 1 Reach Forklift, 1 Backhoe, 1 Skip Loader, 1
Storage Container, 1 Debris Box
Page 17

•

Equipment for Concrete, Underground Plumbing & Electrical – 3 Backhoes, 1
Skip Loader, 1 Reach Forklift, 1 Intermittent Boom Pump, 3 Storage Containers, I
Debris Box, 1 Wash Down Box

•

Equipment for Steel Erection – 2 Cranes, I Reach Forklift, 2 Portable Welders, 1
Portable Generator, 1 Storage Container, 1 Debris Box

•

Equipment for Fireproofing – 2 Semi-Trailers, I Hopper/ Spray Truck, 1 Debris
Box

•

Equipment for Metal Studs Framing/ Drywall/ EIFS – 2 Reach Forklifts, 1
Intermittent Crane, 1 Debris Box

2.1.9.2 Construction Activities
A description of the general types of construction activities is presented in a question and
answer format in Table 2 on the following Page.

Page 18

Table 2 – General Construction Project Questions and Responses
General Construction/Project Questions
What will the construction workforce
consist of, (general numbers and potential
types of jobs)?

Response To General Questions
General construction workers ranging from 10 to
100 depending upon the phase of the project.

Where will the staging areas for materials,
vehicles, machinery be located?

Staging area will be on the subject property
adjacent to building site.

What is the Duration of construction?

12 - 18 months.

What is the Duration of the lease?

30 years.

At the end of the lease term, what will
happen to the property?

Tribal authorities will decide whether to execute a
new lease, or close the facility.

Who will the facility serve?

The facility will serve the Tohono O’odham
Nation for jobs and the USA for prison beds.

How will general emergency procedures be
developed?

General emergency procedures will be defined by
the prison warden in accordance with the standard
prison procedures and guidelines.

How will waste disposal during
construction be handled

Waste disposal will be collected by a contract
vendor and delivered to and disposed of in an
approved land fill off of the Reservation.

How will dust control be maintained during Dust control will be accomplished by using water
materials hauling and construction?
trucks on non paved roads and construction areas
and by limiting construction activities during high
wind events.
How will construction in the floodplain, be A registered Floodplain engineer (hydrologist)
addressed?
will be one of the project consultants. Any
construction in a floodplain area will be in
accordance with federal (EPA, COE and FEMA)
agency guidelines.
Will the road(s) to and within the site be
A paved roadway approximately 3,000 feet long,
paved?
consisting of asphalt or chip seal will be
constructed in the access easement from Pima
Mine Road to the 48.8 acre site. The proposed
perimeter patrol road will be unpaved.
How will new utilities be brought to the
site?

Utilities (Natural Gas, Electrical, and Telephone)
will be extended from Pima Mine Road and
placed within the access and utility easement.

Will the parking lot be paved?

The parking lot will be paved with asphalt.
Page 19

2.1.10 Proposed Action Soil Erosion Control Measures
Building sites as a matter of normal construction are graded, and soils replaced with foundation
materials. An erosion control plan as well as a Storm Water Pollution Prevention Plan (SWPPP)
will be prepared by a registered civil engineer and plans posted on site and adhered to in
conformance with federal laws. A Notice Of Intent (NOI) will be filed with the Environmental
Protection Agency (EPA) prior to commencement of construction. A perimeter silt fence will be
installed to mitigate potential soil erosion. Standard landscaping and soil coverage will be applied
to avoid erosion at completion of construction activities.
2.1.11 Proposed Action Storm water Runoff Control
Development of the 48.8 acre Regional Detention Center site and the 5.6 acre access and utility
easement area will result in an increase in the percentage of impervious areas to rainwater. This
increase in the impervious area can create additional storm water runoff to occur. The proposed
Regional Detention Center design will include construction of a 1.5 Acre (4.0 feet deep) storm
water detention/retention pond designed to release storm water runoff at the pre-developed rate as
described in section 2.1.7.4.
The project will not involve development in an erosion-sensitive area. The area to be developed is
devoid of any vegetation except minor and scattered native weeds and grasses.
2.1.12 Proposed Action Site Surrounding Properties, Businesses, Land Uses
Approximately 5/8 of a mile southeast of the subject property is a tract owned by Pima
County that includes the hydrology unit of Pima County (injection wells). The land to the
southeast of the proposed Regional Detention Center, north of Pima Mine Road and east of
the San Xavier District boundary is old retired farm land that was owned by ASARCO at one
time, but was taken over by the City of Tucson and Central Arizona Water Conservation
District (CAWCD) for the purpose of constructing the Pima Mine Road recharge facility.
Except for the recharge basins and water distribution infrastructure, the land is mostly
undeveloped. The land 3/4 miles south of the subject is a corporate office and land to the
southeast, south of East Pima Mine Road, is a pecan orchard. Adjoining land west (and
southwest) of the subject is allotted tribal land, not utilized for agriculture.
The following pages contain:
• Figure 5 - Aerial map with contours
• Figure 6 – Location map (showing roadways and general site location)
• Figure 7 - San Xavier District Allotte map (with subject site location).

Page 20

Figure 5 - Aerial Map with Contours

Page 21

Sahuarita, Arizona

ohooo O'odlHlm Indian Reservation

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Figure 6 – Location Map (showing roadways and general site location)
Page 22

<0

Figure 7 - San Xavier District Allotte map (with subject site location).

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Page 23

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2.2 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER EVALUATION
Beginning in 2006, the District has considered and evaluated, in order, three previous Alternative
actions (sites) to the Proposed Action (site). These include:
1. Alternative Action #1 - A location 1 mile west of Interstate 19.
2. Alternative Action #2 - A location 18 miles northwest, of the Proposed Action Site
3. Alternative Action #3 - A location south of the proposed location within the 160-acre
allotment 127 along and fronting Pima Mine Road.
Each of the above mentioned locations were deemed inferior due to:
• Accessibility
• Location with respect to highways, roadways and other means of transportation
• Availability of water resources and utilities,
• Terrain
• Proximity to businesses and residences
Each of the 3 alternative locations posed greater potential negative impact to environmental and
socio-economic issues than the Proposed Action site.
2.2.1 Alternative Action Site #1
The first site that was considered was located approximately 1 mile west of Interstate 19
fronting Pima Mine Road to the North and was situated just east of the ASARCO Mine
Tailings impoundment. This site was deemed less desirable than the Proposed Action site for
the following reasons.
a. Concern of the stability of the mine tailings embankment which was approximately
100 feet above the existing ground level of the proposed site.
b. Groundwater quality and quantity were a concern in this area due to potential leaching
of mine tailings into groundwater source and the high amount of total dissolved solids
(TDS) in the groundwater samples provided by the District’s Hydrologist.
c. Presence of a large quantity of Saguaro Cactus on the site.
d. Poor quality of Pima Mine Road to this site.
2.2.2 Alternative Action Site #2
The second site was a site located in the Northwest portion of the San Xavier District that was
located approximately 0.8 mile south of Highway 86 (AJO Highway). The legal description
of this site is the northwest corner of Section 27, Township 57 South, Range 11 East. This site
was deemed less desirable for the following reasons.
a. The site has no paved access to a major roadway. The best access available required
the purchase of an access easement from the University of Arizona through Section
22. Approval of this easement would require University of Arizona Board approval
and the requirement to build a substantial (0.8 mile) of Roadway at the Districts cost.
b. Erosion of the property was an anticipated problem due to seasonal flooding and the
Page 24

steeper grades of this site.
c. Large cost and more disturbed areas of vegetation to grade the site for development
due to slopes and grades of existing terrain.
d. Electricity and gas was not readily available to the site.
2.2.3 Alternative Action Site #3
The third site was a 50-acre site located within the 160-acre allotment 127 and approximately
3000 feet south of the Proposed Action site location and having frontage on Pima Mine Road.
This site was deemed less desirable for the following reasons.
a.
b.

c.
d.

The site would have a close proximity to Pima Mine Road and would be more visible
to traffic and neighboring communities such as Sahuarita.
The development of this site along Prime highway frontage would take away
potential development for projects that could better utilize highway frontage uses
such as retail and commercial development.
Location was closer than Proposed Action Site to ongoing business concern just
south of Pima Mine Road.
This site was considerably more expensive to lease based on Pima Mine Road
frontage.

2.3 NO ACTION ALTERNATIVE
The No Action Alternative is defined as a decision by the District not to proceed with a
detention services contract with a contractor owned/contractor-operated facility within the
reservation, or a decision by the BIA not to approve the lease. The No-Action Alternative
would avoid the potential impacts and inconveniences associated with detention operations,
such as minor noise and minor disruption of traffic patterns associated with construction and
operation.
The District anticipates that the potential project would not create adverse impacts as defined
by NEPA. Impacts that might occur must be contrasted with loss of positive benefits such as
lessening of overcrowded conditions in existing city, county, tribal, state and federal
detention facilities, societal benefits derived from efficient operation of the criminal justice
system and beneficial impacts on the local economy due to construction activities and/or
operational budget expenditures. In light of these considerations, the No-Action Alternative is
deemed to be neither prudent nor in the best interest of the public.

Page 25

CHAPTER 3
AFFECTED ENVIRONMENT
This chapter describes the existing environments that may be potentially affected by the Proposed
Action and No Action Alternatives. Environmental resources considered include: land resources,
water resources, air resources, biological resources, cultural resources, socioeconomic conditions,
resource use patterns, and other values (wilderness, sound and noise, visual, solid and hazardous
waste treatment, and public health and safety).
3.1 LAND RESOURCES
3.1.1 Erosion, Slope, and Soil Suitability
The project area has no significant slopes or topographic relief. Elevation is approximately 2,640
feet above mean sea level. Slope of the project site is approximately is between 0 (flat) to 0.4
percent, sloping from southwest to northeast. No evidence of erosion or sedimentation was
evident during site visits in 2007 and 2008.
Soils in the project area appear suitable for the proposed project. Review of soil data indicates
that the project area is underlain by the Continental-Tubac series (Hendricks 1985). Continental
soils are deep and. well drained with a gravelly sandy loam surface layer about 6 inches thick.
The subsoil is gravelly sandy clay loam and clay about 25 inches thick. Tubac soils are also deep
and well drained. Typically, they have gravelly sandy loam and loam surface layers about 14
inches thick underlain abruptly by clay subsoils about 17 inches thick.
3.1.2 Geology
Subject area is considered an area of high silica sands, and arid desert lands. There are some
loams, mixed with clays providing adequate drainage. There is no evidence or record of any
seismic activity in the area. This area has a layer of fine sandy loam soils, with an area
underneath the top soils ranging from 2 feet to 15 feet under the surface. Under the 15 feet
level below which is additional sand, fine gravel, and some limestone gravel formations.
3.1.3 Minerals
Soils and sub soils are considered stable. Soil maps indicate that the subject consists of sand
and calleche type soils desert sand high silica, Sandy loam 60%, slope to NE, Limu fan 40%.
Soils of the subject are Grabe loam, Comoro sandy loam, Grabe silty clay loam, Sonoita loam,
Comoro loam, Riverwash and Sonoita-Tubac complex. There has been no extensive research or
investigation for minerals on the subject site as a part of this EA.
3.1.4 Topography
The general area of the subject property is flat to slightly sloping desert lands with some salt
cedar and desert vegetation, on soils of high silica content. The general area around the subject
site is pasture land, farmlands or desert. The terrain is gently flat with some gullies in the desert
and is uninhabited, undeveloped land.

Page 26

3.2 WATER RESOURCES
3.2.1 Water Quality
3.2.1.1 Groundwater
The regional aquifer underlying the Santa Cruz River is the primary source of groundwater in
the San Xavier District. Depth to the water table in the regional aquifer near the proposed
project ranges from 83 to 93 feet beneath the surface. Natural recharge to the regional aquifer
occurs primarily as percolation through major stream channels and through mountain front
recharge. Near the proposed project area, recharge is expected to be dominated by infiltration
through the ephemeral El Vado Wash and the Santa Cruz River. Average annual recharge
through the Santa Cruz River channel in this area is estimated at between 200 and 400 acrefeet per year (Osterkamp 1973). Water sampling near the project site indicates groundwater
will meet primary drinking water standards although Sulfate concentration may be slightly
high.
3.2.1.2 Surface Water
Surface water that is generated by rainfall currently percolates into the soil and eventually
recharges the aquifer. Some runoff flows to the Santa Cruz River, however, given the flat
topography the majority of water will enter the aquifer through filtration.
3.2.2 Water Quantity
In the project and surrounding area there are other layers of underground water. The main
water table is at 20 feet to 400 feet according to Scott Rodgers District Hydrologist.
3.2.3 Water Use
There are currently seven wells near the project area at the current time. The Tohono
O’odham Utility Authority owns four of these wells that provide potable water for most of the
San Xavier District including residences and the nearby Indian Health Services (HIS) clinic.
The District’s Desert Diamond Casino located approximately 3 miles west of the project site
has an independent onsite well and reverse osmosis treatment plant for potable water. Water
use for the Proposed Action will be accomplished by drilling an onsite well, and providing
treatment to groundwater.
3.2.4 Water Rights
The San Xavier District is entirely within the Tucson Active Area (TAMA) established by the
Arizona Department of Resources (ADWR). The TAMA includes the AVRA Valley and
Upper Santa Cruz sub-basins. The boundary between these two sub-basins runs through the
San Xavier District. The Southern Arizona Water Rights Settlement Act (SAWRSA) of 1952
established pumping rates for the San Xavier District. The District is allowed to pump 10,000
acre feet of groundwater annually. This includes water pumped by ASARCO (a mining
company), the San Xavier Cooperative Farm, domestic users, and all other water use on the
District. SAWRSA amendments now being negotiated should grant the District an annual
allocation of 50,000 acre-feet of Central Arizona Project water. A letter from the District’s legal
counsel regarding water rights for the District is provided in the Appendix, Exhibit A-3.

Page 27

3.2.5 Floodplain
The Proposed site is bordered by the Santa Cruz River to the West and a seasonally dry wash
to the south. Federal Floodplain is mapped by the Federal Emergency Management Agency
(FEMA) through hydraulic and hydrology studies and publication of Flood Insurance Rate
Maps (FIRMS). The FIRM that includes the Project area is (Community Panel No.
04019C2840 K, dated February 8, 1999). The subject site and access easement are currently
in an area designated as Zone X. The Zone X is defined as areas to be outside of the 500-year
floodplain. A copy of the FIRM Panel for the subject site is included on Figure 8 and the
FIRM Map Legend is included on Figure 9 on the following pages.

Page 28

-- ..........

•

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,

-_.
=-==--

25

lW NUIlIEI
ll4fI9CtI4t I I

E1FEtJM UTE:
F£DlIiI'f .. ttt!I

PIMA COUNTY
UNlKCORPORATED AREAS
G40073

ZONE X

I

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--

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Figure 8 – Flood Insurance Rate Map (Number 04019C2840 K) February 8, 1999

Page 29

Figure 9 – Legend - Flood Insurance Rate Map (Number 04019C2840 K)

I~ ~:J
'

k

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~

.. "

110"56'15"
I 32"03'45"

LEGEND
SPECIAL FLOOD HAZARD AREAS INUNDATED
BY lOO-YEAR FLOOD
ZONE A
No b,a", llood eIeo.':IliwS ~,mined
ZONE AE

s..",

ZONE AH

flood depth, af 1 te 3 ieet (usually
af
,.".-.J0>gI;
b,a",
flood
cle..mions

Ilood ele>"ti<>o< dete<mjned

APPROXIMATE SCALE IN FEET
1000
0
1000
E3
E3
E3

a"""

dele'mined
~lood depdl> af 1 10 ) fe.. (""",,11y """'"
flow On slof>ing le""in):
depti'r<
<lo«>,m;r>«!, F".. .",as of .lIuvial ran flooding,

ZONE AO

""'''go

NATIONAL ROOD INSURANCE PROGRAM

veIodtie< abo <!e'ermifi<;<!
ZONE A99

To be
fede<,,1

p~

flood

con~on : ""

hom l()Q.-y€a' flood by
p<Ole<:tioo >y5lem unrler
flood e~~tions

w..::

d<'Iermined.

ZONE X

ZONE II

C~I

flood with ve\O<ity hau,,j

Iw~",

FIRM
ROOO INSURANCE RAl[ MAP

action): "" base flood ele>"tion> det... m,ned
ZONE liE

I~~?iij

CwstJl flood ",i'h ~ hOUlrd !waVe
actionl: ha.e flood elev"tOons de!ermined.

AREAS

ROaDWAY AREAS IN ZONE AE

CJ

OTHER FLOOD AREAS

CJ

OTHER AREAS

ZONE x

.......... of S(J()..year flood: areaS of lClO-yea'

fkJod with

I&EE "'~P

"0"" 'Of'

P~NE'-" NOT P"INTEDI

""'''S''

depths 01 "'" than
1 foo' Qf with drai"'l!" .reas "'" than
1 "luare mile: ~nd >tea< p<otected by
Jc".",'$ f,om 1()()-y<.\" flood
.!:!!&!!2.f:!:!ill..~

ZONE X

Neg

~rr",ned 10 be outs>de SOO-Y"'"

tb>dpl4in.
ZONE D

....."" in whid>
un<kte,mir>«!

flood

hal,,,,,

UNDEVELOPED COASTAL BARRIERS

CJ

c::::::J

CJ

MAP NUMBER
04mSC1B40 K

klentif,.,.J
ldefltif><'<i
()I~('"".",
1983
1991'l
p,ote<ted
Coastal barrier anlaS are "",mally locate(! wilh:n Or adlaceM 10 Special
Flood Halald A,eas

"''''a'

8

EffiCTIYE DATE:
FEBRUARl B.1BBS

Floodplain Bounda,.,.

FlOOd""",! Bounda,.,.
Zon.. D Boundar;
Boundar;

H3<a<d
Dividing
Coastal
Within

Dividing Special Flood
Zone'
and
Boundary
Are".
of
Diffe,em
Base
Flood
Elevations
Special
Flood
Hozard

F~d...-.l Emerg~ncy

Manlgement Agency

Thi. iI an <>mel'" eopy Of. portion Of!f>e at».e relerer><:e<l n<><><:l map n
wM extracted "'ing F.MITO.... Ur>e. Thi. mlp dOH not reJeet ef>lnget
or Imer"Klment. """en may n_ Deen m_ • ..eae<lU"nt 10 tne date on t""
bU" block. For the '.teet proWcl imorm.t,on.bout NItlonal Flood '...u..nce
Prog..m 1<><><:1 ml~ checl<
FEMA F'<><><:I Mop 51"..,. '" WNW,m.~.Iem.Qf1'I

t""

Page 30

3.3 AIR RESOURCES
The EPA regulates activities affecting air quality on federal and Indian lands. Federal lands are
not subject to Arizona’s State Implementation Plan (SIP), and the Tohono O’odham Nation has
no agreement with the State regarding the implementation of SIP on the reservation. In Arizona,
the Arizona Department of Environmental Quality (ADEQ) administers the SIP. Under the Indian
Air Rule, the Nation has the option of writing a Tribal Implementation Plan (TIP) for air quality.
San Xavier District is within a Group I attainment area that currently meets federal health
standards for ozone (created by volatile organic carbons and nitrogen oxides) and PM10 pollutants
(airborne particles 10 microns or less in diameter). The area has been designated non-attainment
for carbon monoxide. The primary sources of carbon monoxide include exhaust from aircraft at
Tucson International Airport, and vehicle emissions from Nogales Highway and Los Reales
roads. Periodic dust storms may result in temporary, localized deterioration of air quality.
There are no air quality monitoring sites on the San Xavier District. The nearest monitoring
station is at Santa Clara elementary school. There was no exceedance of the National Ambient
Air Quality Standards (NAAQS) at any of the monitoring stations reported by Pima County DEQ
in 2004, specifically Santa Clara, the site nearest the San Xavier Regional Detention Center.

3.4 BIOLOGICAL RESOURCES
Karen Howe, biologist for the Tohono O’odham Nation has performed a biological survey on
the subject site on November 2008. A copy of the Biological Resource Clearance letter is
included in the Appendix as Exhibit A-4.
3.4.1 Special Status Species
Pursuant to the Endangered Species Act (50 CFR 402.12 ©) the USFWS was contacted to
determine the potential occurrence of threatened or endangered species in and adjacent to the
study area. The current Pima County list of 19 endangered, threatened, proposed, and candidate
species available from the U.S. Fish and Wildlife Service (USFWS 2009) was obtained to
determine which species have the potential to occur in the project area. It was determined that one
federally listed species, the Pima pineapple cactus has the potential to occur within or near the
proposed project area. Findings regarding this species are summarized in Table 3 below.
Table 3 - Federally Listed Species with the Potential to Occur in the Proposed Project Area
Species
Pima Pineapple Cactus
(Coryphantha scheeri robustispina)

Status
E

Likelihood of Occurrence
Unlikely to occur.

An onsite inspection for Pima Pineapple Cactus was completed and none were observed. A
complete listing of the endangered, threatened and candidate species for Pima County (obtained
from the Arizona Ecological Services Office of the USFWS) is found in the Appendix Exhibits
A-5 through A-10. Research and in the field surveys disclosed no known occurrences of state
endangered or threatened species or natural communities in the general vicinity of the
Page 31

proposed project. The project area is not within proposed or designated Critical Habitat for any
federally listed species. In October 2008 the Tohono O’odham Nation Natural Resources
Department surveyed the proposed project area and determined the area was clear of any special
status species.
3.4.2 Wildlife Resources
There is a variety of wildlife in Arizona, including small mammals, rabbits, falcons, reptiles,
raptors, skunks, filed mice, lizards, deer, snakes, coyotes, rattlesnakes, woodpeckers, scissortailed flycatchers, cardinals, robins, mockingbirds, wrens, blue jays, roadrunners, dove,
sparrows, shrikes, hawks, owls, and vultures. However, the arid nature of the area, limits the
population. During the site survey, we saw no species of any kind. The subject property is
considered arid desert land, with cactus, salt cedar trees/underbrush, and very little grass. It
has very little vegetation except for native grasses and some trees, therefore there are few
species noted to live near the subject only a few miles from Tucson, Arizona, in Pima County.
In the past 100 years, the subject property has primarily been considered desert prairie, and
it’s proximity to the community of Tucson and Highway 86, have been such that there is no
evidence of any species on or near the subject site. The subject site is not a woodland, or
wetland, and has only grasses with some desert plant varieties on the property, and is not a
producer of significant food for animals. No permanent surface water exists on the subject
site, therefore no aquatic species are expected to occur. Onsite investigations did not identify
any significant natural plant or animal communities, or native prairie remnants which would
be impacted by the proposed project.
3.4.3 Migratory Bird Treaty Act
The Migratory Bird Treaty Act was implemented to end the commercial trade in birds and
their feathers that had decimated populations of many native bird species. The Migratory Bird
Treaty Act decrees that all migratory birds and their parts (eggs, nests, and feathers) are fully
protected. Project site surveys indicate that the subject property is not suitable for breeding or
nesting of any significance for migratory birds, nor a route to or from any such lands
3.4.4 Vegetation
The project area is located within the Arizona Upland Sonoran Desert scrub biotic community (as
described in Brown 1994) with an elevation of approximately 2,460 feet above mean sea level.
Vegetation within the project area is limited. Vegetation that is present includes Velvet mesquite
(Prosopis velutina), creosote bush (Larrea tridentata), burroweed (Isocoma tenuisecta), and
grasses. Xeroriparian vegetation associated with the El Vado Wash includes cat claw acacia
(Acacia greggii), palo verde (Cercidium spp.), desert broom (Baccharis sarothroides), and fourwinged saltbush (Atriplex canescens). Weeds, grass, and small trees were present, but no unusual
presence of noxious weeds or invasive species were observed.
The project area is bordered by undeveloped land to the east and west. South of the subject across
the road are some commercial improvements; Nogales Highway, Union Pacific Railroad tracks,
and Tucson International Airport to the east; and other commercial sites to the south. No naturally
occurring permanent surface water exists in the project area, and no stands of deciduous broadleaved riparian trees are present. There are no natural caves or crevices, or mines suitable for bat
roosts in the project area. No saguaro cacti (Carnegiea gigantea) were observed within the
project area.

Page 32

Table 4 – Summary List of Threatened Endangered or Candidate Species (Pima County)
Plm. County

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Figures 10 and 11 on the following pages contain Photographs taken during site surveys.

Page 33

View of subject property

View from South Property line Looking South

View from South Property line Looking West

View from South Property Line Looking North

View from South Property Line Looking East

Figure 10 - Site Photographs

Page 34

View from North Property line looking South

View from North Property Line looking North

View from North Property line looking West

View from North Property Line looking East

Figure 11 - Site Photographs
Page 35

3.4.5 Wetlands
The subject property is in an area of gently rolling, arid desert lands. There are no lakes,
valleys, or flowing waterways on the subject tract. This is a dry area, and the potential for
flooding or drainage is considered minimal. Terrain maps do not indicate any deep or low
areas on the subject, except where the gullies are, and that drainage is considered normal, this
being a gently rolling area with general gently rolling topographical characteristics. There are
some underbrush trees, but no wetland habitats on the site. There is not hydrophilic vegetation
present. There is no significant wetland hydrology present. Hydric soils are not present. This
site is determined to be a non-wetland area. A wetland inventory map is included in the
Appendix as Exhibit A-11. This exhibit shows that there are no recorded wetlands on or near
the proposed site
3.5 CULTURAL RESOURCES
3.5.1 Historical, Cultural, and Religious Properties
The project site is within a region that has witnessed a fairly uninterrupted period of Native
American occupation from the Middle and Late Archaic-Early Agricultural period to the period
of contact with the Spanish in the early 1700s. Isolated projectile points found elsewhere in the
region, but not at this site, indicate earlier Paleo-Indian and Early Archaic occupations, bringing
the length of human occupation to over 10,000 years. The best-documented occupation in the
region is the ceramic period Hohokam occupation dating from ca. A.D. 200 to 1450. Hohokam
habitation sites elsewhere in the region, but not at the subject site (lease area), include villages
with ballcourts and later villages with platform mounds and ceros de trincheras (hillside terraced
sites) (e.g., Dart 1987:17-26).
For the Protohistoric Period, between A.D. 1450 and the arrival of the Spanish in the early 1700s,
early accounts indicate that Pima-speaking people lived along major drainages. One such
community was the village of Bac on the Santa Cruz River, east of Black Mountain.
3.5.2 Archaeological Resources
Staff from the Tohono O’odham Cultural Affairs Office conducted a Class III cultural resources
inventory of the entire project area in October 2008. Results indicated that no previously recorded
cultural resource sites or traditional cultural places are located in the project area, nor were any
cultural resource sites observed in the project area during the survey.

3.6 SOCIOECONOMIC CONDITIONS
3.6.1 Employment and Income
In 2000, the unemployment rate on the Tohono O’odham Reservation was 9.9 percent; the rate
for the San Xavier District is unavailable. Of the population age 16 or over, approximately 59
percent were not in the labor force (U.S. Census Bureau 2000). Median annual household income
for the Reservation was $19,970. The San Xavier District planner, council, legislative council
representatives, community groups, and individuals outline their desire for increased employment
and standards of living in the “Vision for San Xavier” (1990).
Residents of the San Xavier District are employed on the Reservation and in surrounding
communities. The major employers on the District include the Indian Health Service Clinic,
Page 36

businesses that lease land at the San Xavier Business Park (which include the Desert Diamond,
Casino and Caterpillar, a maker of heavy equipment), Foreign Trade Zone, ASARCO Inc.,
Mission School, and District government offices. Traditional livelihoods, such as farming and
ranching, are currently being revived, with farming expected to take on increased importance
with the rehabilitation of the San Xavier Cooperative Farm. Many District residents are selfemployed as artisans or in various trades. Outside the District, community members work for the
tribal government in Sells or for businesses in Tucson.
In general we believe the socio-economic benefits to the community will be positive. We
reviewed and researched any potential impacts of noise, traffic, displacement, and employment.
We noted no negative potential impacts. The presence of a Regional Detention Center in an area
of grassland and pasture lands is not expected to have any negative noise or vibration impacts.
3.6.2 Demographic Trends
Between 1990 and 2000, the population of Pima County grew by 26.5 percent while the
population of Arizona grew by 40 percent (Table 5). During the same period, the Tohono
O’odham Reservation population increased by 23.6 percent (Census Bureau 1990, 2000).

Table 5. Population Growth in Pima County and the State of Arizona from 1970-2000
Population
Arizona
Pima County
Tohono O’odham
Reservation

1970

1980

1990

2000

1,775,399

2,716,546

3,665,228

5,130,632

351,667

531,443

666,880

843,746

n/a

n/a

8,730

10,787

Source: U.S. Bureau of Census

By 2004, the San Xavier District within the Tohono O’odham Reservation had a population of
2,238 (Arizona Department of Health Services 2005). Demographic data for the District indicate
a relatively young population, with 37% of the population under the age of 20 in 2005. High
school graduates in 2005 accounted for 37.9% of the population.
3.6.3 Community Infrastructure
The primary paved roads that serve the project area are: Interstate 19, Pima Mine Road and the
Nogales Highway (see also Section 3.7.5 Transportation Networks). Nogales Highway is under
the jurisdiction of and maintained by Pima County. The Pima County Department of
Transportation has raised no objections to the project, and current roads are deemed adequate to
serve all traffic needs.
The public and private utilities that currently serve the San Xavier District are as follows:
ƒ

Natural Gas – The area is serviced by Southwest Gas Corporation by a main gas line that
parallels the Nogales Highway. This line enters San Xavier Business Park at Pan Tak Road,
and then enters the existing casino just 2 or 3 miles from the subject. The gas service for the
proposed development would consist of a two inch (2”) gas line that would connect into the
existing gas line in Pan Tak Road and could easily be extended to the subject if required.
Service to the proposed development would originate at this connection, from which a one
Page 37

and one-half inch (1.5”) gas line would continue along Pima Mine Road to provide service to
the development. The Tohono O’odham Utility Authority would construct the new gas lines.
ƒ

Electric – Tohono O’odham Utility Authority

ƒ

Telephone – Qwest

ƒ

Water - Water service in the surrounding community is provided by the Tohono O’odham
Utility Authority, although domestic water service to the San Xavier Business Park and the
adjacent Free Trade Zone are provided by Tucson Water, a division of the City of Tucson.
The domestic water and fire protection supply for the proposed development will come from
a private well system and a private sealed water treatment system, designed in compliance
with all federal and state regulations and specifications.

ƒ

Sewer – Sewer service in the surrounding community is provided by the Tohono O’odham
Utility Authority, although sewer service to the subject development will be by the above
described private sewer treatment system build in accordance with standards utilized in
prisons throughout the United States and in compliance with all regulations.

ƒ

Solid Waste – The subject development and the District will contract with a private contractor
for the disposal of solid waste.

Community resources include the fire department and police department operated by the Tohono
O’odham Nation, and a road system constructed and maintained by the BIA Branch of Roads and
Pima County. There are two schools on the San Xavier District: San Xavier Mission School
(private parochial) and Head Start (early childhood). Other students attend Tucson public schools,
charter schools, and boarding schools. Through contracts with Indian Health Services, the Nation
has a transportation service, Community Health Representative Program, Director of Health
Services, and a clinic.

3.6.4 Environmental Justice
Executive Order 12898, dated February 11, 1994, established the requirement to address
environmental justice concerns, within the context of agency operations. As part of the NEPA
process, agencies are required to identify and address disproportionately high and adverse human
health or environmental effects on minorities and low-income communities (Council on
Environmental Quality 1997).
In compliance with Executive Order 12989, consideration was given to local minority and lowincome groups that may be affected by the Proposed Action. The subject development is in
agreement with the concept of compliance with economic development for the area, and agrees
with the Tohono O’odham Nation and local community as described in the 1990 document
“Vision for San Xavier.” Tohono O’odham members would be given preference for permanent
employment positions, so long as this does not violate any employment law or regulations,
although it is possible that Native Americans of other tribes or non-Native Americans would fill
some short-term positions, including construction phase employment. The proposed project
would not result in disproportionately high and adverse human health or environmental effects on
minorities and low-income communities.
Page 38

3.6.5 Indian Trust Assets
The BIA, as a federal agency, is charged with protection of Indian Trust Assets. Secretarial Order
3175 (Department Responsibilities for Indian Trust Assets), incorporated into the Departmental
Manual at 512 DM 2, indicates that if the actions of a Department of the Interior (DOI) agency
might impact Indian trust resources, the agency must explicitly address those potential impacts in
planning and decision documents as well as consult with the tribal government whose trust
resources are potentially affected by the federal action.
In addition, pursuant to the Executive Order 13175 of November 6, 2000, and in consultation
with tribes, a government-to-government consultation policy has been issued. Consultation means
a process of government-to-government dialogue between the BIA and Indian tribes regarding
proposed federal actions in a manner intended to secure meaningful and timely tribal input. It is
through this government-to-government relationship that the BIA has a duty to consult with tribal
governments. The purpose of this consultation policy is to set forth appropriate guidelines that are
understood and adhered to by all parties. It is vital to the health of the government-to-government
relationship that all contacts and consultation with Indian tribal leaders and the BIA be conducted
in a professional and respectful manner and in accordance with the set guidelines.
3.7 RESOURCE USE PATTERNS
3.7.1 Hunting, Fishing, Timber harvesting, and Gathering
No hunting, fishing, or gathering occurs on the parcel. No large-scale timber harvesting activities
occur on or in the immediate vicinity of the project area. Some community members gather wood
for household use 4 miles west of the project area and in scattered areas where there is vegetation.
This consists of harvesting dead mesquite trees and dead and fallen branches from mesquite trees
along the Santa Cruz River.
3.7.2 Mining
No mining activities occur on or in the immediate vicinity of the project area. There are many
mines in the county though. The ASARCO Mission Complex, an open pit copper mine in
operation since the late 1950s, is located in the southern portion of the District, approximately
seven miles from the project site. The mine has affected groundwater and soils in the immediate
area (Pima Association of Governments 1983). The refining process ASARCO uses creates
tailings that are deposited in ponds on the District. These tailings contain some copper, high
levels of calcium and sulfate, and are probably saturated with gypsum (Pima Association of
Governments 1983). Known groundwater contamination from these ponds includes elevated
sulfate levels, TDS, and hardness in the aquifer adjacent to and below the ponds. Tailings and/or
water from these ponds can enter District washes under extreme conditions. Such an event
occurred in 1990, when a tailings pond dam broke and released large volumes of tailings and
water into a wash. Tailings were deposited more than 3 miles downstream of the tailings facility
and 2 miles downstream of the Central Arizona Project pipeline. Extensive soil sampling for
metals contamination following this event indicated that the discharge did not result in hazardous
metal levels in the soils on the District (Shaffer 1993). The spilled tailings were not believed to be
a health risk.
3.7.3 Agriculture

Page 39

The San Xavier Cooperative Association operates the San Xavier Cooperative Farm, which
grows alfalfa, hay, squash, tepary beans, and other traditional crops without the use of herbicides
or pesticides. The Cooperative sells this produce to community members and is developing a
more widespread consumer base. The San Xavier Cooperative Farm is located in the general area.
The Cooperative Farm is planning to rehabilitate fields and expand operations over the next few
years. The effort consists of rehabilitating approximately 800 acres of currently fallow fields in
the existing farm area west of I-19. An extension farm east of I-19 will consist mostly of land that
has not been farmed in the past, although some fallow fields exist in the area.
The land to the southeast of the proposed Regional Detention Center, north of Pima Mine
Road and east of the San Xavier District boundary is old retired farm land that was owned by
ASARCO at one time, but was taken over by the City of Tucson and CAWCD for the purpose
of constructing their Pima Mine Road recharge facility. Except for the recharge basins and
water distribution infrastructure, the land is mostly vacant. The land 3/4 miles south of the
subject is a corporate office and land to the southeast, south of East Pima Mine Road, is a
pecan orchard. Adjoining land west (and southwest) of the subject is allotted tribal land, not
utilized for agriculture.
3.7.4 Recreation
The subject site’s proximity to the District Center, Education Center and Mission Manor Park
pose no impact to recreational issues. No organized recreational activities occur in the project
area. Recreational opportunities on the San Xavier District are based at the District Center and the
Education Center, which are located a few miles from the project site, across Interstate 19 and the
Santa Cruz River. They consist of youth basketball programs, youth after-school programs, and
other sports leagues. The District Education and Recreation Departments are considering
expanding these programs to include softball, volleyball, and toka (a traditional Tohono O’odham
sport). Arts arid crafts classes are offered at the District Center. There are two softball fields and
numerous unmarked trails and opportunities for outdoor recreation, such as hiking and horseback
riding, on District lands. The Recreation Center contains basketball courts, an indoor gym, and
space for aerobic exercise equipment and free weights. Non-athletic recreational pursuits include
private dances and parties, as well as District-sponsored events such as community Halloween
and Christmas parties. Although a small neighborhood park (Mission Manor) is located
approximately two and one-half miles northwest of the project site, no parks exist within District
boundaries.
3.7.5 Transportation Networks
The existing roadway network within a few miles of the subject includes Los Reales Road,
Komelic Drive, Pan Tak Road, Topawa Drive, Nogales Highway, Valencia Road, 12th Avenue,
Aero Park Boulevard, Hermans Road, Pima Mine Road and San Xavier Road. According to the
Pima County Department of Transportation, Valencia Road is classified as an urban principal
arterial. Nogales Highway is classified as an urban minor arterial, and Los Reales Road, 12th
Avenue, Hermans Road, and San Xavier Road are classified as urban collectors. No other study
area roadways are classified (Kimley-Horn and Associates 2006).
Nogales Highway, in the vicinity of the subject, currently provides two lanes in each direction
with a continuous left-turn lane. Projected traffic volumes from the Pima Association of
Governments (PAG) 2030 regional transportation model indicate that daily volumes along
Page 40

Nogales Highway south of Valencia Road may approach 70,000 to 85,000 vehicles per day.
Based on the volumes, it is anticipated that Nogales Highway will need to provide six lanes of
travel to accommodate future regional traffic volumes. The PAG’s 2030 Regional Transportation
Plan (RTP) identifies Nogales Highway as a 6-lane parkway from Old Vail Road to Valencia
Road, with an estimated widening time frame later in the RTP scope (2020-2030) (Kimley-Horn
and Associates 2006).
Los Reales Road west of Nogales Highway currently provides one lane in each direction. While
no improvements are currently planned for this roadway, projected traffic volumes from the PAG
2030 regional transportation model indicate that daily volumes may exceed 22,000 vehicles per
day. Based on these volumes, it is anticipated that Los Reales will need to provide four lanes of
travel to accommodate future regional traffic demands (Kimley-Horn and Associates 2006).
Pima Mine road and other general roads in the area appear to be adequate to handle traffic needs
for the subject, considering that the subject will increase traffic an estimated 400 to 600 cars
passing per day.
3.7.6 Land Use
In 1992 the San Xavier District adopted a District General Plan for Land Use and Transportation
(San Xavier District 1992). This Plan sets guidelines for development on the District and includes
a summary of different land uses that may be pursued and where community facilities are to be
located. District land is divided into the following categories: single family residential, multifamily residential, public and social, commercial, industrial, agricultural, grazing, mining, and
open space. The project area is located in an open vacant area.
Land use near I-19 of the planned development is a mix of commercial, residential, office space,
and light and general industrial. Land uses to the north and to the west of the planned
development are primarily residential, while Raytheon, Tucson International Airport, and office
space are located to the east. Commercial land uses in the area are limited to the retail store
located on the corner of Los Reales Road and Nogales Highway (Kimley-Horn and Associates
2006). Adjacent lands of the subject site to the west and north are undeveloped tracts utilized for
grazing. The land to the east is an abandoned farm currently owned by the City of Tucson.
Approximately 1 mile south of the project site, a commercial business supporting the mining
industry is present.
A site Vicinity Map is included in Figure 12 on the following page and indicates the
proximity of the various land uses to the subject site.

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A. 3.81 miles South is the Anza Trail School
B. 4.25 miles South is Sahuarita Primary School
C. 3.97 miles Southeast is the Sahuarita Edge High School
D. 4.34 miles Southeast is Sahuarita Baptist Church
E. 1.51 miles West is a casino and restaurant
F. 4.39 miles Northeast is Summit View Elementary School
G. 7.70 miles Northeast is the local airport
H. 7.35 miles Northwest is San Xavier Mission Church and San Xavier Mission School

Figure 12 – Site Vicinity Map (Proximity To Other Land Uses)
Page 42

3.8 OTHER VALUES
3.8.1 Wilderness
No designated wilderness areas occur within or immediately adjacent to the parcel.
3.8.2 Sound and Light
Existing noise levels on the parcel are typical of noise levels for parcels located in a sparsely
undeveloped area. Primary sources of noise are overhead aircraft and vehicular traffic on West
Pima Mine Road. Sound factors on Pima Mine Road are considered minimum. Light should not
affect or disturb any residential development since there is no human population and sparse
human and animal population in the area. Noise levels of subject after development will be
considered non intrusive (as noted with specific ratings in Edition #1).
3.8.3 Public Health and Safety
The Tohono O’odham Nation’s police department provides law enforcement services to the
immediate area including to the proposed project area. The Tohono O’odham Nation’s police
department maintains a police station within the San Xavier District. The Tohono O’odham
Nation’s fire department maintains a fire station within 6 miles of the proposed project site.
The project site is located east of I-19 and 3/4 miles north of East Pima Mine Road, near aquifer
pumping stations, approximately 0.4 mile west of Nogales Highway. The subject site is five miles
south of the Tucson International Airport. The heights of the proposed Regional Detention Center
comply with the requirements of Part 77 of the Federal Aviation Regulations. The FAA has not
been contacted since the project site does not lie within the flight path of the airport, or any
FAA restricted building area/zone in regards to the Tucson Airport. Project construction is a
one-story structure with a maximum roof height of 35 feet above ground level, which is well
below the height of the surrounding transmission lines and utility poles.
3.8.4 Solid and Hazardous Waste
Solid and hazardous waste generated from the Regional Detention Center will be disposed of
offsite at an approved landfill. The proposed project will include an onsite water treatment and
sewer system.
3.8.5 Visual
Existing visual resources include views to Martinez Hill to the North and Black Mountain to the
northwest of the site. Due to the flat nature of the site and the proposed one story building
structure visual impacts are anticipated to be negligible.

Page 43

CHAPTER 4
ENVIRONMENTAL CONSEQUENCES
The environmental effects that likely would result from the construction of the Regional
Detention Center are described in this chapter. The various types of impacts, if any, are defined
and impact locations are identified. Impacts can be direct or indirect, adverse or beneficial, and
short or long term. Short-term impacts are generally considered to be from one to two years long.
Long-term impacts are considered to be from 10 to 30 years.

4.1 LAND RESOURCES
4.1.1 Proposed Action
The effects this project would have on Erosion, Slope, and Soil Suitability, Geology, Minerals
and Topography would be negligible. The project would not involve development in an erosion
sensitive area. There would be a minor short term effect on erosion due to construction which
will be addressed by the SWPPP and Erosion control measures monitored by the EPA. Minor
long-term beneficial effects to land resources would occur due to the addition of vegetation
associated with project landscaping and maintenance of landscaping.
4.1.2 No Action Alternative
Under the no-action alternative, there may be continued gradual degradation of the site resulting
from the current lack of vegetation, as a result of general dry conditions, which seem to have
become worse in recent years.

4.2 WATER RESOURCES
4.2.1 Water Quality
4.2.1.1 Proposed Action

Groundwater - The project would have negligible impact on groundwater quality. The
groundwater table is between 20 to 400 feet deep according to the District’s Hydrologist
and well logs available in the vicinity of the project site. A depth to water table chart for the
subject site can be found in the Appendix, Exhibit A-12 and A-13. This project will include
the construction of onsite water wells and a wastewater treatment system described in
Chapter 1. The Wastewater treatment plant will prevent any untreated water from leaving
the site or entering the aquifer by use of package treatment and storage of treated water in
lined evaporative ponds.
Surface Water - The project would have a negligible impact on surface water quality. No
surface water is to be utilized and the construction is such that water flows will not be
changed or impacted to any great degree. Site grading will be performed to maintain the
general flow patterns of surface water from southwest to northeast. An SWPPP will be
completed for the project as required by the EPA for its National Pollution Discharge
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Elimination System Construction General Permit (GCP) under section 402 of the Clean
Water Act. Site design and construction of the project will include Storm water detention/
retention ponds constructed to collect and release storm water at pre-developed rates and
conditions. These ponds will be designed in accordance with EPA guidelines and best
Management Practices (BMP’s).
4.2.1.2 No Action
Under this alternative, there would be no change in current water quality for either
groundwater or surface water.
4.2.2 Water Quantity
4.2.2.1 Proposed Action
Water usage for this project will have negligible impact on water quantity for the
District. During construction of the project will be from offsite and off tribal land, and
will be obtained from Pima County. Water consumption (from Offsite Sources is
calculated to be as follows:
1. Drinking water 2. Construction water for concrete 3. Water for excavation activities
4 Miscellaneous water for the project
Total

200 gallons per day
563 gallons per day
1,000 gallons per day
100 gallons per day
1,863 gallons per day

Water Usage following completion of the project and long term operation of the facility
is based on 75 gallons per inmate per day which yields 112,500 gallons per day. This
converts to 126 acre feet per year. This amount does not create an undue burden on the
Districts allotment of water. The project will be required to apply for this water use
pursuant to the Nation’s Interim Allottee Water Code.
4.2.2.2 No Acton Alternative
Under this alternative there would be no change in water quantity.
4.2.3

Water Use
4.2.3.1 Proposed Action
No negative impacts to the water usage the District now has are anticipated. Water use for
the proposed project would be for construction water as defined above, domestic
consumption and use by the inmates and personnel during operation of the facility and for
Fire protection if need in the event of a fire emergency. The 75 gallons per inmate per day
includes all personnel. Daily water consumption will vary based on the number of
inmates at any given time. The 75 gallons per day is derived from the following average
daily usages:
Kitchen (meal prep and dish washing)
Toilet Use
Shower
Laundry Facilities
General Cleaning and drinking
Total

10 gallons/day
20 gallons/day
20 gallons/day
10 gallons/day
15 gallons/day
75 gallons/day
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Fire protection water supply would be provided from the fire suppression system and
storage tank system to be built on the premises in accordance with accepted standards.
4.2.3.2 No Action Alternative
Under the No action Alternative, there would be no change in current water usage.
4.2.4

Water Rights
4.2.4.1 Proposed Action
Under the Proposed Action there would be no change in water rights of the District. There
would be a slight decrease in the amount of water available to the Districts if the project
proceeds.
4.2.4.2 No Action Alternative
Under the no action alternative there would be no change in water rights of the District.

4.2.5

Floodplain
4.2.5.1 Proposed Action
The project will not have any impact on floodplain since the project is not contained within
a floodplain designated by FEMA. Additional analysis will be given to this project and an
independent hydrology study will be prepared prior to construction to ensure building
elevations are above potential sheet flow flooding. The tracts of land to the East of the
subject site indicate that sheet flow flooding could occur on those tracts. Flood frequency
charts obtained from the Natural Resources Conservation Service for the subject site are
included in the Appendix, Exhibits A-14 through A-17.
4.2.5.2 No Action Alternative
Under the no action alternative there would be no impact to floodplain areas.

4.3 AIR RESOURCES
4.3.1 Proposed Action
Under the Proposed Action, construction activities associated with development of the project
would result in unquantifiable short-term increases in level of dust (PM10 emissions). During the
mass excavation of the project site, the earthwork subcontractor would have a storage water tank
on site and would be periodically watering the site to provide dust control. Throughout the
duration of the project the general contractor and its subcontractors would be responsible for
providing dust control. The water used for providing dust control would be from wells already
discussed.
The expected increase in vehicular traffic to and from the proposed Regional Detention Center
would likely result in a small but unquantifiable long-term increase in vehicle emissions and dust.

Page 46

4.3.1.1 Mitigation Measures

This impact would be temporary and partially mitigated by implementing the “General
Construction Guidelines” of the Nation. Key elements of these guidelines include:
ƒ construction sites should be cleaned daily to eliminate wind scattered debris;
ƒ grading shall be limited to the scope of each project or to less than six months of

construction, whichever is less; and
ƒ excessive areas of bare soil would be watered using water trucks to minimize dust during

the construction phases.
4.3.2 No Action Alternative
This alternative would result in no short-term or long-term changes in air quality.

4.4 BIOLOGICAL RESOURCES
4.4.1 Proposed Action
Special Status Species - No impacts to any federally threatened, endangered, proposed, or
candidate species are anticipated as a result of the project. The federally endangered species list
identified the Pima pineapple cactus as the only known endangered species to occur in the
vicinity of the project area. However, none were recorded within the boundaries of the proposed
project during the site survey.
Wildlife Resources – The proposed project does not occur in the vicinity of any proposed or
designated Critical Habitat. Because impacts to habitat would be limited, it is unlikely that any
wildlife would be displaced, even temporarily, from the project area. Impacts to wildlife habitats
would, therefore, be negligible.
Migratory Birds – No Impact to migratory birds is anticipated as a result of this project, since no
evidence of migratory birds were found at the site during the site survey.
Vegetation - The proposed project would not result in the permanent loss of native desert
vegetation except in the specific construction site. No impacts of noxious weeds and invasive
species are anticipated as a result of the construction or long term operation of the facility.
Wetlands - No impact to wetlands would occur as a result of this project since there are no
wetlands present on the site.
4.4.1.1 Mitigation
Mitigation for biological resources include covering trenches at the end of the workdays,
preconstruction surveys for any species or migratory birds, washing construction vehicles
to prevent spread of noxious weeds, and plant salvage, including Barrel Cactus,
requirements will all be utilized by contractors as deemed relevant and appropriate.

4.4.2 No Action Alternative
Under this alternative, there would be no impact to the biological resources.
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4.5 CULTURAL RESOURCES
4.5.1 Proposed Action
There are no known cultural resource sites, including traditional cultural properties, in the project
area. The BIA Regional Director has determined that requirements for the NHPA have been
satisfied under 36 CFR 800 for this project based on consultation with the Tohono O’odham
Nation and State Historic Preservation Office (SHPO) and that no further steps are necessary.
The Arizona SHPO has concurred with the determination of “No Historic Properties Affected”
on the subject site by signature dated December 11, 2008. A copy of correspondence from
the Deputy Regional Director to the SHPO is included in the Appendix, Exhibit A-18, A-19,
and A-20.
4.5.1.1 Mitigation Measures
The San Xavier District requires that an archaeological monitor be present for all
construction in the project area. In the event that buried historic or prehistoric artifacts or
features are encountered during construction, work should be halted in the immediate
vicinity of the find and the San Xavier District and the Cultural Affairs Program be
contacted immediately so that the discovery can be evaluated.
4.5.2 No Action Alternative
Under this alternative, there would be no changes to the property, so there would be no impact to
cultural resource sites, including traditional cultural properties.
4.6 SOCIOECONOMIC CONDITIONS
4.6.1 Proposed Action
The residents of the Tohono O’odham Nation (population 10,787) and eastern Pima County
would likely fill new employment opportunities associated with the proposed project. The
existing labor force would likely fill the Regional Detention Center jobs without attracting new
residents to the area because of the high level of unemployment in the Nation and the preference
for hiring tribal members.
There would be no adverse impact on employment and income patterns resulting from this
project. There is a potential beneficial impact as the proposed Regional Detention Center would
offer increased job opportunities for tribal members. During the construction phase, the project
would create new temporary labor positions. Following construction, the project will bring from
250 to 300 jobs to manage and service the Detention facility depending upon occupancy. Annual
pay roll would be in the range of `6.0 to 7.0 million dollars. It is estimated that salaries turnover
in the local economy by a factor of five through procurement of goods and services by employees
and vendors. The Proposed Action would not disproportionately adversely affect minorities or
low-income communities. Job hiring has not yet begun and salary or income levels are not yet
determined.
The Proposed Action would address the socioeconomic needs of Tohono O’odham members,
thereby serving the short-term and long-term interests of the Tohono O’odham Nation and nontribal residents living in general vicinity. The project would be a benefit to Indian Trust Assets
Page 48

because it provides alternative sources of income on underutilized, previously unproductive land.
In addition, revenue from the Regional Detention Center operations would provide a significant
amount of funding for various services desired by members of the Tohono O’odham Nation.
4.6.2 No Action Alternative
The no action alternative could provide a negative impact to the Socio-economic conditions of
the District. This would occur by losing potential jobs, procurement service opportunities and
loss of an opportunity by the District to diversify its economic base.

4.7 RESOURCE USE PATTERNS
4.7.1 Hunting, Fishing, Timber harvesting, Gathering, Mining, Agriculture, and Recreation
4.7.1.1 Proposed Action
No major hunting, fishing, timber harvesting, gathering, mining, agriculture, or organized
recreation occurs on the parcel being considered in this EA. The proposed Regional
Detention Center project is expected to have no impact on the ASARCO Mission Complex
due to its distance from the project site. The proposed Regional Detention Center project is
expected to have no impact on the Cooperative Farm. The proposed detention center project
is expected to have no impact on the District Center, the Education Center, other recreational
activities within the San Xavier District, or Mission Manor Park due to their distances from
the project site. Therefore, under the Proposed Action, there would be no impact to these
resource uses.
4.7.1.2 No Action Alternative
Under this alternative there would be no impact to hunting, fishing, timber harvesting,
gathering, mining, agriculture, or organized recreation.
4.7.2 Transportation Networks
4.7.2.1 Proposed Action
The construction of new facility is expected to increase visits to the property, which would
increase traffic impacts to the project area roadways. After the proposed development, all
studied area intersections would operate at acceptable levels. Traffic on Pima Mine Road
would be anticipated to increase in a range up to 600 cars per day passing this area. Current
roads are adequate for this increase. Proposed Action therefore creates a negligible impact.
4.7.2.1.1 Mitigation Measures
Mitigation measures to traffic issues will include signage and lighting as required on
Pima Mine Road during construction and at the completion of the project as determined
by PIMA County to address the new intersection of the access road and Pima Mine
Road.
4.7.2.2 No Action Alternative
Under this alternative, there would be no impact to the local transportation network as traffic
levels would not increase due to the Regional Detention Center.

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4.7.3 Land Use
4.7.3.1 Proposed Action
Under the Proposed Action, land use in the area will change from undeveloped land to a
portion of the land being used as a Regional Detention Center. This will have no negative
environmental impact. There are no impacts to proposed land use, including adjacent and
nearby land users. There will be no impact to the community. Nearby schools, churches
and/or businesses will not be impacted by the proposed land use.
4.7.3.2 No Action Alternative
Under the No Action Alternative, there would be no change in current land use and therefore,
no Impact to land use.

4.8 OTHER VALUES
4.8.1 Wilderness
4.8.1.1 Proposed Action
There are no wilderness areas within or adjacent to the San Xavier District; therefore, no
wilderness areas would be affected by the Proposed Action.
4.8.1.2 No Action Alternative
Under the no action alternative there would be no impact to wilderness areas.
4.8.2 Sound and Light
4.8.2.1 Proposed Action
One industrial business enterprise was identified approximately 1 mile south of the proposed
project site. Under the Proposed Action, there would be a short-term increase in ambient
noise levels during the construction phase of the project which would be short term and
minimal. Following construction, vehicular traffic would increase, but associated noise levels
would remain consistent with the current land use for the area. However, these impacts would
be temporary and would only occur during normal business hours. Following construction,
vehicular traffic would increase, but associated noise levels would remain consistent with the
current land use for the area.
4.8.2.1.1 Sound and Light Mitigation
Construction hours on the exterior of the building will generally be limited to daytime
hours. Exterior lighting for the Regional Detention Center project will utilize
directional lenses on perimeter lighting as well as wall mounted light packs. This will
provide the level of lighting required for security and minimize light pollution for
surrounding areas.

4.8.2.2 No Action Alternative
Under the No Action Alternative, sound and noise would remain at the levels associated with
the existing businesses and traffic.
Page 50

4.8.3 Public Health and Safety
4.8.3.1 Proposed Action
There would be little or no impact to public health and safety under the Proposed Action.
Vehicle-related injuries may increase as a result of increased traffic volume; however, the
potential for vehicular accidents would be mitigated by the measures listed in Section 4.7.2.2.
There will be a potential benefit to Public Health and Safety as a result of the project.
National Studies have shown that crime decreases in areas adjacent to correctional facilities
due primarily to the increase in law enforcement traffic and visibility.
4.8.3.2 No Action Alternative
Under a No Action alternative no impact will occur.

4.8.4 Solid and Hazardous Waste
4.8.4.1 Proposed Action
Under the Proposed Action, the Regional Detention Center will contract with a Solid waste
disposal company and all Solid Waste will be disposed of in an off reservation approved
landfill. Hazardous waste should be limited to medical and chemical waste associated with
cleaning. The Facility Operator will have a hazardous waste management plan and will
contain and contract for removal, transportation and disposal of all hazardous waste off
reservation at an approved landfill.
4.8.4.2 No Action Alternative
Under the No Action Alternative, there would be no change in solid and hazardous waste
status of the site.

4.8.5 Visual
4.8.5.1 Proposed Action
Coordination between the Tohono O’odham Nation cultural resources committee and the
architect to design the buildings to reflect the cultural values of the Nation was completed.
The new buildings would be consistent with the visual aesthetics of the current use and
zoning of the property. No visual impacts to the area are anticipated.
4.8.5.2 No Action Alternative
If there is no action then there is no impact on visual resources.

4.9 COMPARISON OF ALTERNATIVES

Page 51

Neither alternative would have significant adverse impacts to the resources considered in this
environmental assessment. The Proposed Action would result in a net beneficial impact to the
socioeconomic conditions by providing employment opportunities to members of the Tohono
O’odham Nation and revenue to the San Xavier District. Under the Proposed Action, the District
would begin to achieve the economic goals set forth in the 1990 “Vision for San Xavier.” Under
the No Action alternative, the project area would remain in its current state; there would be no
development of the Regional Detention Center.
In comparing alternative, it appears that the development of this project when considered with
alternatives, has a positive impact on the tribe and no action maintains the status quo.
4.9.1 Summary of Cumulative Impacts
No adverse cumulative effects would result from the project. On the contrary, a net cumulative
improvement to employment opportunities and revenues for the Nation would result from the
increased employment and income generated by the Regional Detention Center.
4.9.2 Summary of Unavoidable Adverse Impacts
No unavoidable adverse impacts are anticipated from either the Proposed Action or No Action
Alternative.

Page 52

CHAPTER 5
CONSULTATION AND COORDINATION
The following agencies were consulted during the preparation of this EA:
Federal:
Bureau of Indian Affairs, Papago Agency
Bureau of Indian Affairs, Western Region Environmental Quality Services
Health and Human Service, Indian Health Service Tucson Area Office
US Environmental Protection Agency, Indian Programs Office
US Environmental Protection Agency, Wetlands Regulatory Office
US Fish and Wildlife Service, Tucson Office
State:
Arizona Department of Transportation (ADOT) – Tucson District Office
Arizona Game and Fish Department
Arizona State Historic Preservation Office
Local:
City of Tucson Department of Transportation
City of Tucson Engineering Division
City of Tucson Storm Water Section
City of Tucson Water Department
Pima County Department of Transportation
Pima County Department of Wastewater Management
Pima County Regional Flood Control District
Rural Metro Fire Department
Town of Sahuarita
Tucson Airport Authority
Tribal:
San Xavier Allottees Association
Tohono O’odham Nation, Cultural Affairs Program
Tohono O’odham Nation, Department of Public Safety
Tohono O’odham Nation, DPS Fire Department
Tohono O’odham Nation, Environmental Protection Agency
Tohono O’odham Nation, Natural Resources Committee of the Legislative Council
Tohono O’odham Nation, Natural Resources Department, Wildlife and Vegetation Management
Tohono O’odham Nation, Planning Department
Tohono O’odham Nation, San Xavier District Council
Tohono O’odham Nation, San Xavier District Hydrologist
Tohono O’odham Nation, Solid Waste Program
Tohono O’odham Nation, Utility Authority

Page 53

CHAPTER 6
LIST OF PREPARERS
CERTIFIED ENVIRONMENTAL INSPECTORS (CEI)
Ben B. Boothe, Sr.
Certified Environmental Consultant #4989
Senior Environmental Manager
9800 Verna Trail North
Fort Worth, TX 76108
(817) 738-9595
bba_a@hotmail.com
www.environment-solutions.com
Chris Cuny
FC Cuny Corporation
#2 Horizon Court Ste 500
(469) 402-7700
crc@fccuny.com
Heath, Texas 75032
BIA - BUREAU OF INDIAN AFFAIRS
BIA Western Regional Office
Two AZ Center 12th Floor
400 North 5th Street
Phoenix, AZ 85004
The BIA Papago Agency
Circle Drive Bldg 49
Sells, Arizona 85634

Bureau of Indian Affairs representatives provided advice and assistance in preparation of this EA.

Page 54

CHAPTER 7
REFERENCES
Arizona Department of Health Services, 2005. San Xavier primary care area statistical profile – 2005. Office of
Health Systems Development.
Brown, D.E. (editor). 1994. Biotic communities: southwestern United States and northwestern Mexico. University
of Utah Press, Salt Lake City. 342 pp.
Council on Environmental Quality (CEQ). 1997. Environmental justice, guidance under the Tribal Environmental
Policy Act. Council on Environmental Quality, Executive Office of the President, Washington, D.C.
Dart, A. 1987. Archaeological studies of the Avra Valley, Arizona, for the Papago Water Supply Project. Volume
1: Class III Archaeological surveys on the Tohono O’odham Indian Reservation. Anthropological Papers
No. 9, Institute for American Research, Tucson.
Hendricks, D.H. 1985. Arizona soils. College of Agriculture, University of Arizona, Tucson. 244 pp.
Kimley-Horn and Associates. 2006.
Osterkamp, W.R. 1973. Ground-Water recharge in the Tucson area, Arizona. USGS Miscellaneous Investigation
Series, Map I-844-E, Washington, D.C., 20244.
Pima Association of Governments (PAG). 1983. Assessment of nitrate in groundwater of the Upper Santa Cruz
Basin: report and detailed recommendations.
Pima County Department of Environmental Quality. 2005. http://www.airinfonow.org. Accessed March 2006.
San Xavier District. 1990. Vision for San Xavier. San Xavier District, Tohono O’odham Nation.
San Xavier District. 1992. District general plan for land use and transportation. San Xavier District,
Tohono O’odham Nation.
Shaffer, M. 1993. Evaluation of soil contamination, San Xavier Indian Reservation. Unpublished report.
Spicer, E.H. 1962. Cycles of conquest: the impact of Spain, Mexico, and the United States on the Indians of the
Southwest, 1533-1960. University of Arizona Press, Tucson.
SWCA Environmental Consultants (SWCA), 2005.
U.S. Bureau of the Census. 1990. American Factfinder. http://www.census.gov.
U.S. Bureau of the Census. 2000. American Factfinder. http://www.census.gov.
U.S. Bureau of the Census. 2006. American Factfinder. http://www.census.gov.
USDA Natural Resources Conservation Service Web Soil Survey 2.1 National Cooperative Soil Survey

Page 55

______________________________________________________________________________

APPENDIX
______________________________________________________________________________

Page 56

CHAPTER 5
CONSULTATION AND COORDINATION
The following agencies were consulted during the preparation of this EA:
Federal:
Bureau of Indian Affairs, Papago Agency
Bureau of Indian Affairs, Western Region Environmental Quality Services
Health and Human Service, Indian Health Service Tucson Area Office
US Environmental Protection Agency, Indian Programs Office
US Environmental Protection Agency, Wetlands Regulatory Office
US Fish and Wildlife Service, Tucson Office
State:
Arizona Department of Transportation (ADOT) – Tucson District Office
Arizona Game and Fish Department
Arizona State Historic Preservation Office
Local:
City of Tucson Department of Transportation
City of Tucson Engineering Division
City of Tucson Storm Water Section
City of Tucson Water Department
Pima County Department of Transportation
Pima County Department of Wastewater Management
Pima County Regional Flood Control District
Rural Metro Fire Department
Town of Sahuarita
Tucson Airport Authority
Tribal:
San Xavier Allottees Association
Tohono O’odham Nation, Cultural Affairs Program
Tohono O’odham Nation, Department of Public Safety
Tohono O’odham Nation, DPS Fire Department
Tohono O’odham Nation, Environmental Protection Agency
Tohono O’odham Nation, Natural Resources Committee of the Legislative Council
Tohono O’odham Nation, Natural Resources Department, Wildlife and Vegetation Management
Tohono O’odham Nation, Planning Department
Tohono O’odham Nation, San Xavier District Council
Tohono O’odham Nation, San Xavier District Hydrologist
Tohono O’odham Nation, Solid Waste Program
Tohono O’odham Nation, Utility Authority

LIST OF ACRONYMS

ACA
ADEQ
ADOC
ASARCO
ASTM
BIA
CAP
CAWCD
CEC
CEI
CERCLIS
COE
CORRACTS
DRW
EA
EMF’s
ERNS
FBOP
GNRTR
IBC
ICE
IGA
LUST
NEPA
NHPA
NPDES
NPL
OSHA
PE
Phase I
RCRA Viol
SAWRSA
SHPO
SOG
SPL
SWLF
SWPPP
TRIS
TSD
USFWS
USMS
UST/AST

American Correctional Association
Arizona Department of Environmental Quality
Arizona Department of Corrections
American Smelting and Refining Company
American Society for Testing and Materials
Bureau of Indian Affairs
Cooperative Agreement Program
Central Arizona Water Conservation District
Community Education Centers
Certified Environmental Inspectors
Sites under review by USEPA
Corp of Engineers
RCRA Corrective Actions
DRW Engineering
Environmental Assessment,
Electronic Magnetic Fields
Emergency Response Notification System of Spills
Federal Bureau of Prisons
RCRA Registered Small or Large Generators of Hazardous Waste
International Building Code
Immigration and Customs Enforcement
Intergovernmental Agreements
Leaking Underground Storage Tanks
National Environmental Protection (Policy) Act
National Historic Preservation Act
National Pollutant Discharge Elimination System
National Priority List
Occupational Safety and Health Administration
Professional Engineer
Environmental Inspection of Property with no sampling (ASTM)
RCRA Violations/Renforcement Actions
Southern Arizona Water Rights Settlement Act
State Historic Preservation Office
Special Operations Group
State Equivalent Priority List
Permitted as Solid Waste Landfills, Incinerators, or Transfer Stations
Storm Water Pollution Prevention Plan
Toxic Release Inventory Database
RCRA Permitted Treatment Storage, Disposal Facilities
United States Fish and Wildlife Service
United States Marshal Service
Registered Underground or Above Ground Storage Tanks

i

LIST OF TABLES
Table 1 – Agency / Permits & Approvals……………………………….……………………...6
Table 2 – General Construction Project Questions and Responses……………………………19
Table 3 - Federally Listed Species with the Potential to Occur in the Proposed Project Area... 31
Table 4 – Summary List of Threatened Endangered or Candidate Species (Pima County)……33
Table 5 - Population Growth in Pima County and the State of Arizona from 1970-2000……..37

LIST OF FIGURES
Figure 1 - Subject Site Survey………………………………………………………………. 9
Figure 2 - Aerial view of 48.8 acres and 60’ access and utility easement………………… 12
Figure 3 - Plan of Facility…………………………………………………………………. 13
Figure 4 - Detention Center Floor Plan……………………………………………………. 14
Figure 5 - Aerial Map with contours……………………………………………………...…..21
Figure 6 – Location Map (showing roadways and general site location) …………………….22
Figure 7 - San Xavier District Allotte Map (with subject site location)………………………23
Figure 8 – Flood Insurance Rate Map (Number 04019C2840 K) February 8, 1999………. 29
Figure 9 – Legend - Flood Insurance Rate Map (Number 04019C2840 K)………………. 30
Figure 10 – Site Photographs………………………………………………………………. 34
Figure 11 – Site Photographs………………………………………………………………. 35
Figure 12 – Site Vicinity Map (Proximity to Other Land Uses)…………………………….42

ii

ABSTRACT
The purpose of this Environmental Assessment (EA) is to evaluate the San Xavier District’s
(District) Proposed Action of entering into an agreement with a private contractor to provide
detention services for 1500 detainees on a site located on the San Xavier Reservation. This
EA addresses potential human and environmental impacts of the Proposed Action and its
alternatives and is evaluated in accordance with the National Environmental Policy Act
(NEPA) of 1969, as amended, and United States Department of Justice environmental
guidelines.
BACKGROUND
In September 2006 the District began to investigate and pursue economic development
opportunities related to locating a detention center within the boundaries of the Reservation.
The District has determined that the opportunity exists to construct a regional criminal justice
facility within the Reservation to provide an immediate and long-term need for approximately
1500 detention bed spaces for use by various agencies. The District is deemed to be an
advantageous location based on the strong community support for this type of project, the
proposed location’s proximity to US Courthouses located in Tucson and Phoenix, and the
border patrol activities along the Mexican border. Potential users of this facility include:
nearby cities; counties within the region; state agencies such as the Arizona Department of
Corrections (ADOC); the United States Marshals Service (USMS); the Immigration and
Customs Enforcement (ICE); Federal Bureau of Prisons (FBOP), the Bureau of Indian Affairs
(BIA) and other criminal justice agencies/departments.
The District is desirous of entering into an agreement with a private operator to build and
operate a facility in the San Xavier Reservation for the economic development opportunities
such a facility could bring to its members. The high level of city, county, ICE, FBOP and
USMS activity in the southwestern United States requires more beds than are readily
available in local or state facilities. The shortage of beds has been ongoing for several years.
There is a specific need for detention facilities to be located near federal courthouses because
of its responsibility to detain those individuals accused of violating federal laws. Proximity to
the courthouses can facilitate meetings with lawyers and family, and is logistically preferable
when transporting detainees to court appearances. The proposed detention facility will be
within 20 miles from the federal courthouse in Tucson and within 115 miles of the federal
courthouse in Phoenix. Various city, county, state, and federal agencies are authorized to
enter into contracts with private entities for the housing, care, and security of persons in its
custody by the Anti Drug Abuse Act of 1988.
PROPOSED ACTION
This EA evaluates the impacts of the District entering into an agreement with a private
contractor to provide detention services for up to 1500 detainees. The contractor on behalf of
the District will design, finance, construct, and operate the proposed detention facility under
a separate contract agreements. Due to a national jail space crisis, the ability of county, state
and federal governments to provide adequate detention space for inmates, detainees and
prisoners has become limited, especially in major metropolitan areas with federal
courthouses.
iii

FINDINGS
The procurement of detention services at a proposed location in the San Xavier Reservation
meets a key requirement in that it is located in close proximity to a federal courthouse in
Tucson. The implementation of obtaining detention services is not expected to have any
adverse effects on environmental resources or socioeconomic conditions in the San Xavier
Reservation or surrounding community. Implementation of detention services is not expected
to have any adverse impact on geology, soils, topography and drainage, climate, cultural
resources, surface water, groundwater, aquatic resources, wetlands, vegetation, wildlife
resources, endangered species, prime and unique farmlands, or wild and scenic rivers. The
cumulative effect of this Proposed Action is also not expected to have adverse impacts to the
San Xavier Reservation or the surrounding communities; therefore, no major mitigation efforts
are required for the development of this project at this location.
Beneficial impacts of the Proposed Action include economic development for the
community, as well as the surrounding area. The Proposed Action and project site have
received public support. The site selected by the proposed contractor is in an area removed
from the residential population in a remote area (at the eastern edge) of the San Xavier
Reservation, with existing utilities and excellent highway access. Safety and aesthetic
concerns that may exist regarding the detention facility have been addressed in the concept
design and security measures for construction are planned.

iv

San Xavier District
2018 W. an Xavier Road
'l'ucson,AZ 85746.

520-573-4000
Austin Nunez -Chairman

Thi is to veri ry that the subject San Xavier Detention Project has been an. ongoing project for
several years. We have had public meetings, and these have been advertised by public notice in
appropriate local media; with Triba] leaders, members, and members of the community at large
invited. At the cmeetings, the project has met with good support within the community.
Public meetings took plaee at the District Meeting Room located at 2018 W. San Xavier Road;
Tucson, AZ 85746 on the following dates: 07125106 and 08101/06 The environmental research,
Phase T, and NEPA reports have been available for many months and are available for review by
the pUblic, at the tribal offices located at the Office of Economie Development, San Xavier
District· 2018 W. San Xavier Road; Tucson, AZ 85746.

cc: Austin Nunez
Jerry Carlyle
File copy

Exhibit A- 1

SAN XAVIER DISTRICT
OF THE
TOHONO O'ODHAM NAnON
2018 W. SAN XAVIER RD.• TUCSON. AZ 85746

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LEGAL DESC1Ul'TION

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SEcnON 25. TWP 16S0, RI3E
SAN XA VlER DISTRICT
TOHONO O'ODRAM NATION
A portion of the Northeast 1/4 ofSoction 25, Twp16So. R13E, San Xavior DuU'ict ortho Toho

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Nation deserihed 4S follows:

:

COMMe"NClNG at the soUlheast comor of said Section 25;
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l1-laNCE NOOJa'04UW alons the: ~3.'St section line or said SectioD 25, 4087:22 ft. lO the POINT bF

BEG~O

THENCE 856"10'01 "W, 1542.5Hc
THENCE NO"33'26"W, 2086.95 n. to a pain, on 'he north line of said Section 25;
THENCE 889"15'17"E .long said north line 1288.31 ft. (0 <he NE corn.r of sold SeOlion 25;
THENCE 80"38'04"E .lons tho ...,Iine of said Section 25, 1211.31 ft. tb. POINT OF

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BEGINNING.
Said parcel contftining 48,8 acres o.nd subject to

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60 fL inga~. cgre~1I Wld utility easement alorig th~

c.:ll:Ot 60 ft. of the south 4087.22 fl. of s.uid Section 25.

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Exhibit A- 2

Law Offices of

BARASSI, CURL & ABRAHAM, P.L.C.
LOUIS W. BARASSI
DAVID L. CURL*
JAMES E. ABRAHAM*

485 S MAIN AVE., Bldg. 1
TUCSON, ARIZONA 85701-2227

(520) 884-7777 ˜ Fax (520) 620-0921
www.barassiandcurl.com

DOUGLAS W. GLASSON
KATRINA M. CONWAY

*Certified Specialist in Personal Injury and Wrongful Death by the Arizona Board of Legal Specialization

November 21, 2008
Via Email
Ben B. Boothe, Sr.
BEN B. BOOTHE Sr. COMPANIES
benboothe@gmail.com
Re: San Xavier District / Federal Support Center
Dear Mr. Boothe:
In answer to your questions, and to assist you in responding to the Bureau of
Indian Affairs, we provide the following information.
2.
As General Counsel to the District, I actively participated in negotiations
which resulted in the Southern Arizona Water Rights Settlement Act Amendments
of 2004, which confirmed the rights to use of water on the San Xavier
Reservation, and the Interim Allottee Water Code of the Tohono O’Odham Nation,
which codified procedures for registering water uses. The Act assures that up to
10,000 acre-feet per year of groundwater may be withdrawn from lands of the
District for use thereon. See PL 108-451, Sec. 308 (f)(1)(A). To my knowledge, all
of this allocation remains available at this time. Your hydrologist estimated the
needs of the project at 8250 gallons per day; this works out to 9.24 acre-feet per
year, well within the available water. The project will be required to apply for
recognition of this water use pursuant to the Nation’s Interim Allottee Water
Code. I am confident that nothing in the Code will allow for the Project’s
proposed use to be denied.
Please let my office know if there is any further assistance we can provide to
move this matter forward.
Sincerely,
/s/
Louis W. Barassi
/g
Encl.
cc:
Austin Nunez
Jerry Carlyle

Exhibit A- 3

Exhibit A- 4

Pima County
COMMON NAME,

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COONTY

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on ltoe rear It1e 1~~t1,
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hlan.pled and oona::led
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meclEtI)', and a cEll gl'...n cui YEl'.'apEt
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spelled hog lrom a~a
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~mbemellle)wlI~ stenda
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Pima County

~IHAT

ELEVATION

3,300-8,000 n S IBarrt9, ~ie B,
baclM'aLEu, ponds, and
st:oclilanks I~El, B"e mostt]'
roo hom hlrodlD3d IlIh,
Cf~J'rl!~, and OOlfrolJ!,

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S ha bN sllrhgs, slT\3l1
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Sma II slroo IT'll, spnngs,
and c1anegas 'i\3gala~d
ahalb/.-s.

COMMENT$

P.€q ulre parlT\3M nL or neartl' parlT\3M nL
....aler scurces, Po~allons non~ofltoe
GIla Ftier mEl'1' be a c1CE.e~ raEtEd, OOL
dlsl hel, undescnbed spaclls, A spac III
rue allG'i'a la tie holJ! c1Je Lo opel3l1on
and maln~nance 01 Itiesbck. Ianlls on
Sla~ a nd ~t,a~ lands.

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Pup~ (CIll.eremus).Crllt:Et ~~lal
Includes aUllotaqu 10 S~lngs, P rna
Ccultf, pMbns SEll Felpe Creel<,
CB'nZO \\I~,and R~Creel<W~,
Impala I Ccultf, CaJlfcrna.

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Fcund on mUlple pn'.'al.e lands,lnduclng
lhe Na lU'e COnseFia rq' and lhe AUdLbon
SOcl~]'. AlsooccusonFeoolll1 andstEt.e
lands a nd In SOnora, I.\3xt:o. Cnlt:a I
rn Wa I, occus In CocIhl!e, G la, G 13 rnm,
G'eenee, Pima, PinEl, sanla Cruz, and
Ya'tapal m un laa.
Species t'lslcrt:altJ' also occurred In
Is curren Ir
s1=flngs.

back.wa~1ll ollB'ga n'.131ll 001
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Cnllcal ~l:tlsL In Ccmse and SEIlIB Cruz
munilis (64 FP.37441 , JutJ' 12, 19Q9J.

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110-57-20 W

110-57-0 W

t:l Counl\e$ 1001<

II

Stal$l00K

0

.............

0

............

110-56-40'"

Map center: 320 0'12" N, 1100 57' 34" W

$

Scale: 1:27,272

This map is a user generated static output from an Internet mappinfl?te and is for general reference only. Data layers that appear on this map mayor may not be
accurate, current, or otherwise reliable. THIS MAP IS NOT TO BE SED FOR NAViGAnON.

Exhibit A- 11

,

••

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•

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Exhibit A- 12

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Depth to Water Table-Pima County, Arizona, Eastern Part; and Tucson-Avra Valley Area, Arizona

MAP LEGEND

MAP INFORMATION
Map Scale: 1:24,200 if pooted on A size (B.S" x 11") sheet

Area of Interest (AOI)

D

Area of Inleres! (AOI)

The soil surveys that comprise your AOI were mapped at scales
ranging from 1:20,000 to 1:24,000

Soil Map Unils

Please rely on the bar scale on each map sheet for acCtlrate map
measuremoots

Soils

D

Soil Ratings

D
D
D
D
D
D

0-25

Source of Map
Natural Resources Conservation Service
Web Soil Survey URL- hllp:llwebsoilsurvey_nrcs.usda.QOv
Coordinate System
UTM Zone 12N NADB3

" '"
'" ''''
'''' ''''

This product is generated from the USDA-NRCS certified data as of
the version date(s) listed below_

'''' ""

> ,'"

Political Features

o

Gibes

Soil Survey Area
Survey Area Data

Pima County, Arizona, Eastern Part
Ver.>ion 8, Sep B, 2008

Soil Survey Area
Survey Area Data

Tucson-Avra Valley Area, Arizona
Ver.>ion 6, Sep 5, 2008

Your area ofinterest (AOI) includes more than one soil survey area
These survey areas may have been mapped at different scales, with
a different land use in mind, at different times, or at different levels
of detail. This may result in map unit symbols, soil properties, and
interpretations that do not completely agree across soil survey area
boundaries

WOlter Features
•
OCeans
Slrearns and canals

Transportation
Rails

Date(s) aerial images were photographed

612512007

Interslafe Highways
The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident

US Routes

MajorRlliIds

Natural Resources
Conservation Service

Web Soil Survey 2.1
National Cooperative Soil Survey

Exhibit A- 13

3/1Of2009

Page 2 of4

••
l

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A

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Exhibit A- 14

•,••

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Flooding Frequency Class-Pima County, Arizona, Eastern Part; and Tucson-Avra Valley Area, Arizona

MAP LEGEND

MAP INFORMATION
Map Scale: 1:24,200 if pooted on A size (8.5" x 11") sheet

Area of Interest (AOI)

D

Area of Interesl (AOI)

The soil surveys that comprise your AOI were mapped at scales
ranging from 1:20,000 10 1:24,000

SoiIMapUnils

Please rely on the bar scale on each map sheet for accurate map
measuremoots

Soils

D

Soil Ratings

D
D
D
D
D

Rare

D

Very Frequenl

N~

Nalural Resources Conservation Service
Source of Map
Web Soil Survey URL- hllp:llwebsoilsurvey_nrcs.usda.gDV
Coordinale System
UTM Zone 12N NAD83

Very Rare

This product is generaled from the USDA-NRCS certified data as of
the version date(s) listed below_

OCcasional
Frequent

Political Features

o

Gibes

Pima County, Arizona, Eastern Part
Ver.>ion 8, Sep 8, 2008

Soil Survey Area
Survey Area Data

Tucson-Avra Valley Area, Arizona
Ver.>ion 6, Sep 5, 2008

Your area ofinterest (AOI) includes more than one soil survey area
These survey areas may have been mapped at different scales, with
a different land use in mind, al different times, or at differenllevels
of detail. This may result in map unit symbols, soil properties, and
interpretations that do not completely agree across soil survey area
boundaries

WOlter Features
•

Soil Survey Area
Survey Area Data

OCeans

Slrearns and canals
Transportation

Rails

Date(s) aerial images were photographed

612512007

Interslafe Highways

The orthophoto or other base map on which Ihe soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor shifting
of map unit boundaries may be evident

US Routes

Major Roads

Natural Resources
Conservation Service

Web Soil Survey 2.1
National Cooperative Soil Survey

Exhibit A- 15

3/1Of2009
Page 2 of4

Flooding Frequency Class-Pima County, Arizona, Eastem Part; and TucsonAvra Valley Area, Arizona

Flooding Frequency Class

Flooding Frequency Class- Summary by Map Unit- Pima County, Arizona, Eastern Part
Map unit symbol

Map unit name

Rating

Acres in AOI

Percent of AOI

3

Anthony fine sandy loam, 0 10 None
3 percent slopes

40

02%

36

Hayhook.-Sahuarita complex, None
1 to 5 percent slopes

43.2

19%

82

Tubac sandy loam, 0 to 2
percent slopes

20

01%

None

Subtotals for Soil Survey Area
Totals for Area of Interest
Flooding Frequency Class- Summary by Map Unit Map unit symbol

Map unit name
Anthony gravelly sandy loam, Rare
1 10 3 percenl slopes

ApB

Anthony soils, 0 to 3 percent Occasional
slopes

A,B

Anthony and Sonoita soils, 0 Rare
to 5 percent slopes

2.1%
100.0%

Tucson-Avra Valley Area, Arizona

Rating

AoB

49.2
2,312.7

Acres in AOI

Percent of AOI

300.8

130%

645

28%

241.1

104%

Be

Brazilo loamy sand

Rare

85

04%

CIC

Cave-Rillilo complex, 0 to 8
percent slopes

None

04

00%

Cm

Comoro sandy loam

Rare

223.7

97%

Co

Comoro loam

Rare

40.0

17%

GbB

Gila loam, 1 to 3 percent
slopes

Rare

24

01%

Gh

Grabe loam

Rare

487.3

211%

Gm

Grabe sHty clay loam

Rare

429.8

186%

Go

Gullied land

None

28.1

12%

LmB

Laveen complex, 0 to 5
percent slopes

None

15.6

07%

Pm

Pima silty clay loam

Rare

246.7

107%

Ro

Riverwash

Frequent

28.7

12%

So

Sonoita loam

None

29.3

13%

SIB

Sonoita-Tubac complex, 110 None
3 percent slopes

97.7

42%

y,A

Vinton loamy sand, 0 to 1
percent slopes

19.0

08%

Rare

Subtotals for Soil Survey Area

2,263.5

97.9%

Totals for Area of Interest

2,312.7

100.0%

Natural Resources
Conservation Service

Web Soil Survey 2.1
National Cooperative Soil Survey

Exhibit A- 16

3/10/2009

Page30f4

Flooding Frequency Class-Pima County, Arizona, Eastem Part; and TucsonAvra Valley Area, Arizona

Description
Flooding is the temporary inundation of an area caused by overflowing streams, by
runoff from adjacent slopes, or by tides. Water standing for short periods after
rainfall or snowmelt is not considered flooding, and water standing in swamps and
marshes is considered ponding rather than flooding.
Frequency is expressed as none, very rare, rare, occasional, frequent, and very
frequent.
"None" means that flooding is not probable. The chance of flooding is nearly 0
percent in any year. Flooding occurs less than once in 500 years.
"Very rare" means that flooding is very unlikely but possible under extremely
unusual weather conditions. The chance of flooding is less than 1 percent in any
year.
"Rare" means that flooding is unlikely but possible under unusual weather
conditions. The chance of flooding is 1 to 5 percent in any year.
"Occasional" means that flooding occurs infrequently under normal weather
conditions. The chance of flooding is 5 to 50 percent in any year.
"Frequent" means that flooding is likely to occur often under normal weather
conditions. The chance of flooding is more than 50 percent in any year but is less
than 50 percent in all months in any year.
"Very frequent" means that flooding is likely to occur very often under normal
weather conditions. The chance of flooding is more than 50 percent in all months
of any year.

Rating Options
Aggregation Method: Dominant Condition
Component Percent Cutoff: None Specified
Tie-break Rule: More Frequent
Beginning Month: January
Ending Month: December

Natural Resources
Conservation Service

Web Soil Survey 2.1
National Cooperative Soil Survey

Exhibit A- 17

3/10/2009
Page 4 of 4

.5 H1'0- ;2.00'0 -

·

United States Department of the Interior
BUREAU OF INDIAN AFFAIRS

WESTERN REGION

l~! Gte / h p

CGIO/1400 North 5- SU"ed

2:

!f.... o Arizona Cenler

1'I;l, 8' (.Jg'!'!(),\,
~.1 ~
~

,.

TAJ<E PRIDE
'NAMEfUCA

l,tI&oenill., Arizona 85004

NIl';JOLyl...... '0
1::n~"'<)nmcnW QuKhly

Services

NOV l ti 2008
I
Mr. James Gam.son
State Hl5toric Pres6vation Officer

Arizona State Parks
BOO West Washington

Ph.:;cnix, AriuJlUl 85001
Dear Mr. Garrison;
A!;,

Agency Official for purposes of Section 106 of the National HistoriC PreservatIOn Act of

1966, as amended (NHPA), I WISh to consult with you pursuant to 36 CFR 8003(&) about the
proposed undertaking, approval of a lease for a Feden! Holding Facilily (Project No. 2008294). on the San Xavier Disuict of the Papago Indian Reservation.

In consultation with the Tahono O'odham Nation (fON) as identified at 36 CPR 8OO.3(d), I
hllvC made a reasonable and good faith effort to carry our llppropriare identifiC<llion efforts as
prescribed at 36 CFR 800.1, lind find dmt no historic properties art present within the area of
potential effect (APE). Documentation of this fmding is provided in the enclosed m~morandum
from Mr. P~t~r St~r~ dared October 20, 2008.
I coodude that a detennirul.tion of"No Historic Properti.e$ Affected" pursuant to J6 CFR BOO '1
(d) (I) is appropriat~ for the undertaking, as no lustoric properties were found within th~ APE.
This deremtination will be indud~ as part of the National Environmental Policy Act (NEPAl
dOCllllll"nrllrinn ll,,-'<n"';<>t("(! with the proposed undertllkinr, whi<"h i~ "n'ic:j[Jfll~c1 t~, hI' ~ ...
Environmental Assessment. As part of the NEPA review process, we will employ corresponding
Bureau and tribal notification procedures for addressing our responsibilines as dcfmed 'H 36 CFR

BOO.2Cd).
As required at 36 CFR BOO.5 (c), I am submitting documentation of this finding and await your
tesponse: within thirty da~ d receipt_ I trUSt you will agree: with this finding and seek. your
concurrence that th~ ~ction 106 consultation process has been successfuUy completed fot the
subject undert<lking.

Exhibit A- 18

Page 2
[f ther are any questi ns, please contact Mr. Gany J. Cantley, Regional Arche I gist, at (602)
379·6750.

~~
Regional Direct r

Enclosure
c: Sup nncendent, Papago Agency
Arm: Environmental oordinator
Chairman, Tohono O'odham Tribal Council
Program Mae agee, Cultural Affairs Dept., ON
Real Estate Services, WRO

Exhibit A- 19

II DCLO~

United States Department of the Interior
BUREAU OF INDIAN AFFAIRS

WESTERN REGION
400 North 5'" Street
Two Arizoua Center
Phoenix, Arizona 85004

...

I"~""'~""T
EnvironmenllJ Qualily Servi=

FEB 102009
Memorandum
To:

Superintendent, Papago Agency
Attention: Environmental Coordinator

FronPCTINGoeputy Regional DirL'uor - Trust Services
Set:tion 106 ofNHPA, Federal Holding F ility; Papago Indian Re5ervation

You are hereby advised that the consuLtation process with the Arizona State Histotic
Preservation Office (SHPO) has been completed for the proposed undertaking on the Papago
Lndian Reservation: approval of a (ease for a Federal Holding Facility (project No: 2008_
294). ThL' SHPO has concurred with our determinations of "No Historic Properties Affet:ted"
by receipt of the attached letter dated November 26, 2008.
We have determined that the memorandum from Mr. Peter Steere is accurate for purposes of
compliance with Section 106 of the NationaL Historic Preservation Act of 1966, as amended
(NHPA).
We Hnd tbBt no historic properties fire within the area of potential effect (APE) for the project.
Our responsibilitieli under the NHPA are hereby complete, with the proviso that shouLd
unrecorded cultural material be encountered in the course of construction, work shall cease at
thin location and the Program Manager, Cultural Affairs Department, and the BIA Regional
Archeologist be notified immediately.
This detcnnillation should be included as part of the National Environmental Policy Act
(NEPA) documentation associated with the proposed actions to demonstrate compliance with
Federal responsibilities under Section 106 of NHPA.
If you have lmy questions, please contact Mr. Garry ]. Cantley, Regional ArcheolOgist, at (602)

379·6750.

Att3chment

Page 2

ce: Real Estate Services, WRO
Chairman, Tohono G'odham Tribal Council
Program Manager, Cultural Affairs Dept., TON (w/attach)

Exhibit A- 20