CBP road project needs deeper review of impacts, environmentalists say

Environmentalists say a proposed federal road project west of Nogales warrants deeper scrutiny of its potential impact to fragile jaguar and ocelot territory in the project area.

The Holden Canyon Connector Road project, planned within rugged terrain west of Nogales, would add or improve 12 miles of roads between Holden Canyon and Warsaw Canyon.

U.S. Customs and Border Protection says the project is needed to help agents traveling east to west through the mountainous area, about 10 miles southeast of Arivaca.

“The limited east/west road access … has constrained agents’ abilities to safely and efficiently respond to this area,” CBP said in its 2023 scoping letter, outlining the goals of the project.

“The purpose of this project is to improve mobility and accessibility for CBP agents responding to and seeking to prevent illegal cross-border traffic, address emergencies involving human health and safety, and prevent or minimize environmental damage arising from occurrence of and response to CBV (cross-border violator) illegal entry on public lands,” the agency said.

But the Tucson-based Center for Biological Diversity says a draft environmental assessment published in November — as part of the environmental review process under the National Environmental Policy Act, or NEPA — is inadequate.

In comments responding to the assessment, the nonprofit also objects to the assessment’s preliminary finding that the project will have “no significant impact” on the critical habitats or listed species in the area. In addition to jaguar and ocelot sightings in this remote wilderness area, other potentially affected species include the yellow-billed cuckoo, Mexican spotted owl and Chiricahua leopard frog.

If CBP’s draft “finding of no significant impact” becomes final, that would mean the agencies don’t have to conduct a deeper analysis under NEPA. But the Center for Biological Diversity says the potential impacts are significant enough that land managers should prepare a full environmental impact statement.

“That’s exactly why we spend so much time commenting on these proposals,” said Laiken Jordahl, southwest conservation advocate for the Center for Biological Diversity. “They have an opportunity to change course, or at least include mitigations that would lessen the harms of the project.”

Among the center’s concerns, submitted to the U.S. Forest Service during the project’s second public comment period, which ended in early December, the environmental assessment incorrectly stated that there have been no ocelot sightings in the area.

This summer, an ocelot was recorded for the first time on June 12 in the Atascosa Highlands west of Interstate 19, which is within the project area, on a camera run by Phoenix Zoo researchers. Experts believe the same ocelot was spotted again east of I-19 in July.

“It was a jaw-dropping omission that the land management agency charged with protecting these species didn’t even acknowledge there was an incredibly rare ocelot sighting in this very mountain range, just a few months before this document was published,” Jordahl said. “We know the cat is actively using these areas. It’s moving through these mountainous corridors, and it would certainly be negatively impacted by this project.”

Back to homepage

Subscriber Login

Keep reading with a digital access subscription.

Subscribe now

A CBP official said the agency became aware of the ocelot sighting late in its environmental review process. CBP is now consulting with the U.S. Fish and Wildlife Service, and Coronado National Forest, on the project’s potential to affect the ocelot, the official said.

The project calls for 3 miles of roads in the area to be decommissioned, in order to offset the impacts of new road construction. But those existing roads are already so far out of use and overgrown that they aren’t recognizable as roads anymore, Jordahl said.

Creating new roads in remote areas can end up increasing smuggling there, as human smugglers begin making use of those roads, Jordahl said. Recreational users also want access to the area, as indicated by comments submitted in the most recent public comment period, he said.

“We have in the public record now comments from dirt-bike advocacy groups, indicating their eagerness to use this road, and also hunting groups saying they support the project because they want to use the road,” he said. “That directly contradicts the environmental assessment, which says there won’t be a significant uptick” in traffic in the area.

A CBP official said the new roads will allow a Border Patrol presence in an area that has been largely unpatrolled, due to the lack of east-west roadways, and agents’ presence there will discourage smuggling activity.

Jordahl said CBP failed to look at alternative ways to improve response time in the area, such as improving north-south roads or technology-based solutions.

“We list out a number of those alternatives they should have looked at. Not to say we’d support them, but legally they need to consider these alternatives, as many would be less damaging,” he said.

The Center for Biological Diversity emphasized that the agencies are obligated to consider the cumulative effects of previous border-wall infrastructure construction, as well as the Holden Canyon road project’s potential impacts.

The Atascosa Highlands, which include the Pajarito Mountains, are “one of the best remaining corridors for jaguar and ocelot,” Jordahl said. “It connects to a wide expanse of wilderness land south of the border in Sonora, and ultimately connects up to the breeding population of both ocelots and jaguar in Sonora. Again, these rugged areas are the exact areas that are most favored by wildlife and especially spotted cats. They’re natural corridors for the species.”

The public will have another chance to weigh in on the project after a draft decision is announced in April 2025, a spokeswoman for the U.S. Forest Service said in an email.

The responses to specific comments will be published on the Forest Service website when the decision notice is posted in April, said Starr Farrell, public affairs officer for Coronado National Forest. The public can track the project’s progress and view submitted public comments on the agency’s site.

The project’s lead agencies, CBP and USFS, will have to address “all the substantive comments and concerns we’ve raised in our comments in order for it to be legitimate,” Jordahl said. “If these concerns go unaddressed, that’s when the window for litigation opens.”