Case Document 200-1 Filed 08/27/19 Page 1 of 25 EXHIBIT 1 Case Document 200-1 Filed 08/27/19 Page 2 of 25 FOURTH DECLARATION OF KENNETH P. RAPUANO I, KENNETH P. RAPUANO, pursuant to 28 U.S.C. 1746, hereby declare as follows: 1. I am the Assistant Secretary of Defense for Homeland Defense and Global Security Among other duties, which are generally re?ected in Department of Defense Directive 5111.13, I am responsible for developing, coordinating, and overseeing implementation of policy for plans and activities related to defense support of civil authorities. On April 5, 2018, the Secretary of Defense designated the to manage the then-newly established Border Security Support Cell. The Border Security Support Cell is the focal point and integrator for all requests for assistance, taskings, and information related to support pursuant to the President?s April 4, 2018, memorandum, ?Securing the Southern Border of the United States.? 2. This declaration is based on my own personal knowledge and on information made available to me in the course of my of?cial duties. 3. To date, as described in my previous declarations, has authorized the transfer of $2.5 billion to fund border-barrier?construction support to the Department of Homeland Security (DHS) under 10 U.S.C. 284(b)(7) for seven projects: Yuma Sector Project 1, Yuma Sector Project 2, El Paso Sector Project 1, El Centro Sector Project 1, and Tucson Sector Projects third declaration, dated May 15, 2019, I stated that then-Acting Secretary of Defense Patrick Shanahan did not intend, and was not planning, to provide additional border-barrier- construction support to DHS under Section 284 for the ensuing six months (through November 15, 2019). In the course of executing the contracts for the seven approved Section 284 projects, the US. Army Corps of Engineers (U SACE) determined that lower-than-expected contract costs may yield suf?cient savings to build up to an additional 20 miles of border ban'ier. Speci?cally, USACE anticipates that the ?nal total contract price for the seven projects will be less than original rough-order-of?magnitude budget estimates. USACE will not know the precise amount available until later in the ?scal year when USACE ?nalizes all contract pricing. 5. On August 16, 2019, DHS sent to an amendment to its February 25, 2019, request for assistance under Section 284. The amendment added mileage as well as new projects to the list of DHS-requested border-barrier-construction projects. See Exhibit A. 6. On August 26, 2019, Secretary of Defense Mark Esper authorized USACE to use any excess funds resulting from contract savings on the previously approved $2.5 billion in Section 284 projects to undertake three additional border barrier construction projects. To that end, Secretary Esper approved three additional Section 284 projects: Yuma Sector Projects 4 and 5 and Tucson Sector Project 4. See Exhibit A Case Document 200-1 Filed 08/27/19 Page 3 of 25 I hereby declare under penalty of perjury that the foregoing is true and correct. Executed on: August 26, 2019 KE ETH P. RAPUANO Case Document 200-1 Filed 08/27/19 Page 4 of 25 EXHIBIT A Case 4:19-cv-00892-HSG Document 200-1 Filed UNCLASSIFIED//FOR OFFICIAL USE08/27/19 ONLY Page 5 of 25 ACTION MEMO USD(P) :SJ2_ Prepared by: Tom Hanniff, ODASD HDI&DSCA Phone Number: 571-256-8315 FOR: SECRETARY OF DEFENSE 1/ /1 .. I FROM: Kenneth P. Rapuano,_Assistant Secretary of Defense, H o m e l a n ~clioba Security AUG 2 2 2019 SUBJECT: Department of Homeland Security Request for Assistance Pursuant to 10 U.S.C. § 284 PURPOSE: To obtain your approval of a Department of Homeland Security (DHS) request to block drug-smuggling corridors along the southern border under 10 U.S.C. § 284 by constructing fences and roads, and installing lighting along approximately 20 miles in the Yuma and Tucson Sectors using excess fiscal year (FY) 2019 funds already provided to the U.S. Army Corps of Engineers (USACE). COORDINATION: This memo was coordinated with OGC and the Department of the Army. BLUF: With your approval, USA CE may build up to 20 additional miles of fencing in the Yuma and Tucson Sectors using excess FY19 funds already provided to USACE for construction under Section 284. DISCUSSION: • On August 16, 2019, OHS submitted a request for assistance (RFA) {TAB C) for 11.6 additional miles of border barrier construction under Yuma Sector Projects #3 (8 miles), #4 (1.1 miles), and #5 (2.5 miles). This modifies the Secretary of Homeland Security's February 25, 2019, RF A that requested DoD assistance in blocking up to 11 specific drugsmuggling corridors along the southern border of the United States. o The additional 8 miles of construction under Yuma Sector Project 3 are not recommended for your approval given their geographic location (i.e., the additional mileage is interspersed within the 31 miles of border barrier being considered for construction under 10 U.S.C. § 2808). • 10 U.S.C. § 284 gives you the authority to construct roads and fences, and to install lighting to block drug-smuggling corridors across international boundaries of the United States in support of counter-narcotic activities of Federal law enforcement agencies. • Then-Acting Secretary of Defense Shanahan approved construction under Section 284 on March 25, 2019, and May 9, 2019. ISOCA ,OSMA ,O MA k::oS ISO Action Grp f:S l,SR IHLe/., .,. "{,. - OSOSA OSOSMA OSOMA OSOCA ESB Rvw ESO I :zr)fl'J\ " I OSD00892 5-19/C l'v1 D0 11043-19 UNCLASSIFIED//FOR OFFICIAL USE ONLY I Case 4:19-cv-00892-HSG Document 200-1 Filed 08/27/19 Page 6 of 25 UNCLASSIFIED//FOR OFFICIAL USE ONLY • The requirements of Section 284 are met: OHS/Customs and Border Protection (CBP) is a Federal law enforcement agency; DHS has identified each project area as a drug-smuggling corridor; and the work requested by DHS falls within the scope of subsection 284(b )(7) in that it involves construction of fences (including a linear ground detection system), construction of roads, and installation of lighting (support by grid power and including imbedded cameras). o Any support provided under Section 284, including under subsection (b )(7), is subject to 10 U.S.C. § 276, which provides that support may not be provided if the provision of such support would adversely affect the military preparedness of the United States. • USACE has realized contract savings for existing Section 284 projects such that sufficient funds may be available for construction of up to 20 additional miles of border barrier. • In addition to the 3.6 additional miles from the Yuma #4 and #5 projects in the DHS request, USA CE has identified 16.4 miles of projects in the Tucson Sector (Tucson #4, 14.4 miles; and Tucson #5, 2 miles) that were previously requested by OHS on February 25, 2019, and could be completed using the generated savings (TAB D). o The mileage in Tucson Sector Projects #4 and #5 was not previously approved because of other, higher priority projects and availability of funds based upon initial cost estimates. • USA CE has indicated that it will be able to fully obligate these funds before the end of FY 2019, after which point the funds will expire. • Undertaking these projects would add 20 miles of border barrier that USACE has indicated it will be able to complete before the end of calendar year 2020. RECOMMENDATION #1: Determine that approving additional border barrier support in Yuma Sector Projects #4 and #5 and Tucson Sector Projects #4 and #5 do not adversely affect the military preparedness of the United States because the funds have already been provided to USACE ~barrier construction under Section 284. Approve· 8~\ C\ Disapprove: _ _ Other: RECOMMENDATION #2: Approve the construction ofup to 20 miles of border barrier in Yuma Sector Projects #4 and #5 and Tucson Sector Projects #4 and #5 as funds allow. Approve:~ f/zs, /\ct Disapprove: _ _ Other: RECOMMENDATION #3: Sign the memorandum (TAB A) to the Secretary of the Army authorizing the Commander, U.S. Army Corps of Engineers, to undertake up to 20 miles of border barrier construction in Yuma Sector Projects #4 and #5 and Tucson Sector Projects #4 and #5. UNCLASSIFIED//FOR OFFICIAL USE ONLY 2 Case 4:19-cv-00892-HSG Document 200-1 Filed 08/27/19 Page 7 of 25 UNCLASSIFIED//FOR OFFICIAL USE ONLY RECOMMENDATION #4: Direct the Executive Secretary to sign the memorandum (TABB) to the OHS Executive Secretary informing them of your decision. COORDINATION: TAB E Attachments: As stated UNCLASSIFIED//FOR OFFICIAL USE ONLY 3 Case Document 200-1 Filed 08/27/19 Page 8 of 25 TAB A Case 4:19-cv-00892-HSG Document 200-1 Filed 08/27/19 Page 9 of 25 SECRETARY OF DEFENSE 1000 DEFENSE PENTAGON WASHINGTON , DC 20301-1000 MEMORANDUM FOR SECRETARY OF THE ARMY COMMANDER, U.S. ARMY CORPS OF ENGINEERS SUBJECT: Construction of Roads and Fences and Installation of Lighting along the U.S. Southern Border in Support of the Department of Homeland Security On February 25 , 2019, the Secretary of Homeland Security requested that DoD provide support to the efforts of the Department of Homeland Security (DHS) to secure the southern border by blocking up to 11 drug-smuggling corridors along the border through the construction of fences and roads and the installation of lighting. On August 16, 2019, the Secretary of Homeland Security amended this February 25, 2019 letter by requesting additional DoD assistance by undertaking Yuma Sector Projects #3, 4, 5. I have determined that the requirements ohitle 10, U.S. Code, section 284, have been satisfied, and I have decided to authorize the U.S. Army Corps of Engineers to use excess funds already provided for the construction of border barrier projects under section 284 for constructing up to 20 miles of 30-foot pedestrian fencing, constructing and improving roads, and installing lighting within Yuma Sector Projects #4 and 5 and Tucson Sector Project #4. The U.S. Army Corps of Engineers will be the construction agent for this support and will take all necessary action to undertake construction this fiscal year. In light of the continuing nature of the crisis at the southern border, as described by the President, the Acting Secretary of Homeland Security, and other DHS officials, you should undertake construction as quickly as possible, consistent with applicable law. As the proponent of the requested action, Customs and Border Protection will serve as the lead agency for environmental compliance and will be responsible for providing all necessary access to land. DHS will accept custody of the completed infrastructure, account for that infrastructure in its real property records, and operate and maintain the completed infrastructure. My point of contact is Kenneth Rapuano, Assistant Secretary of Defense for Homeland Defense and Global Security. cc: Chairman of the Joint Chiefs of Staff Under Secretary of Defense for Policy Under Secretary of Defense (Comptroller)/Chief Financial Officer General Counsel of the Department of Defense Assistant Secretary of Defense for Legislative Affairs Assistance Secretary of Defense for Homeland Defense and Global Security Assistance to the Secretary of Defense for Public Affairs. Case Document 200-1 Filed 08/27/19 Page 10 of 25 TAB Case 4:19-cv-00892-HSG Document 200-1 Filed 08/27/19 Page 11 of 25 OFFICE OF THE SECRETARY OF DEFENSE 1 000 DEFENSE PENTAGON WASHINGTON , D.C. 20301-1000 MEMORANDUM FOR EXECUTIVE SECRETARY, DEPARTMENT OF HOMELAND SECURITY SUBJECT: Additional Support to the Department of Homeland Security Thank you for your August 16, 2019 memorandum modifying your February 25, 2019 request that the Department of Defense (DoD) provide the Department of Homeland Security (DHS) assistance pursuant to section 284 of title 10, United States Code. The Department of Defense (DoD) appreciates that DHS confronts a continuing and worsening crisis at the southern border. As indicated in previous memoranda regarding DoD support to DHS under 10 U.S .C. § 284, DoD has continued to assess the availability of resources and other factors in order to determine how additional similar support can be provided to DHS. 10 U.S.C. § 284(b)(7) gives DoD the authority to construct roads and fences, and to install lighting to block drug-smuggling corridors across international boundaries of the United States in support of counter-narcotic activities of Federal law enforcement agencies. For the following reasons, the Secretary of Defense has concluded that the modified support requested on August 16, 2019 satisfies the statutory requirements: • • • The DHS/Customs and Border Protection (CBP) is a Federal law enforcement · agency: DHS has identified each project area as a drug-smuggling corridor; and, The work requested by DHS to block these identified drug smuggling corridors involves construction of fences (including a linear ground detection system), construction of roads, and installation of lighting (supported by grid power and including imbedded cameras). At this time, DoD will undertake up to an additional 20 miles of 30-foot pedestrian fencing, will construct and improve roads, and will install lighting, as described in the August 16, 2019 and February 25, 2019, requests. Specifically, DoD agrees to undertake Yuma Sector projects 4 and 5 and Tucson Sector project 4, subject to the availability of funds. As the proponent of the requested action, CBP will serve as the lead agency for environmental compliance, and will be responsible for providing all necessary access to land. DoD requests that DHS place the highest priority on completing these actions for the projects identified above. DHS will accept custody of the completed infrastructure, account for that infrastructure in its real property records, and operate and maintain the completed infrastructure. The Commander, U. S. Army Corps of Engineers, is authorized to coordinate directly with DHS/CBP and immediately begin planning and executing using funds already provided to the U. S. Army Corps of Engineers to undertake the approved Section 284 projects. Di& CAPT, USN Executive Secretary Case Document 200-1 Filed 08/27/19 Page 12 of 25 TAB Case Document 200-1 Filed 08/27/19 Page 13 of 25 if i tn Advisor U.S. Department ofHomeland Security Washington, DC 20528 ?a t. Homeland Secur1ty Us August 16, 2019 MEMORANDUM FOR: Robert G. Salesses Deputy Assistant Secretary, HDI DSCA Department of Defense FROM: RDML Brendan C. McPherson Military Advisor Department of Homeland Security SUBJECT: Modi?cation Request for Assistance Pursuant to 10 U.S.C. 284 REFERENCE: Request for Assistance Pursuant to 10 U.S.C. 284, dated February 25, 2019 Department of Defense Response to Department of Homeland Security (DHS) Request for Assistance Pursuant to 10 U.S.C. 284, dated March 25, 2019 Modi?cation Request: Section 284 Funding for Border Barrier Construction, dated April 4, 2019 Modi?cation of Support to Block Drug- Smuggling Corridors, dated April 10, 2019 Modi?cation of Support to Block Drug? Smuggling Corridors, dated April 12, 2019 zverview DHS thanks for both the response and approval of the use of Section 284 funding, as indicated in reference for the construction of border fencing and roads and installation of lighting as requested in reference The original RFA noted the signi?cant number of apprehensions and drug seizures between border crossings in the Yuma Sector during FY18. That continues to be the case to date in FY19. Year to date in FY19, the U.S. Border Patrol has apprehended 65,000 illegal entrants and seized over 3,000 pounds of marijuana, over 30 pounds of heroin, over 900 pounds of methamphetamine and almost 40 pounds of fentanyl between border crossings in the Yuma Sector. Modification Based on contracting ef?ciencies, DHS requests the following update to Yuma Project 3 and the addition of Yuma Project 4 and Yuma Project 5 to reference All other aspects of references through (6) remain unchanged. Case Document 200-1 Filed 08/27/19 Page 14 of 25 Subject: Modi?cation Request for Assistance Pursuant to 10 U.S.C. 284 Page 2 Add 8 miles to Yuma Proiect 3 Construct approximately 8 additional miles of new pedestrian fencing. When added to the vehicle barrier replacement requirement identi?ed in reference this project now comprises approximately 39 continuous miles of barrier beginning at the east end of the BMGR and moving east to the border of the Yuma and Tucson sectors. Start coordinate: 3223482799, -113.96138144 End coordinate: 32.0390333, -113.3341097 Add Yuma Project 4 This project includes approximately 1.1 miles of new primary pedestrian fencing, starting east of the Andrade point of entry, moving north to south along the Colorado River. Start coordinate: 32.71869511, -114.71949202 End coordinate: 32.70419718, -114.72601301 Add Yuma Project 5 This project includes approximately 5 miles of fencing in the Yuma Sector. The ?rst segment is 0.5 miles of replacement primary pedestrian fencing beginning west of the Andrade port of entry, terminating at the port of entry. The replacement of ineffective pedestrian fencing in this area is necessary because the older bollard and landing mat design is easily breached and has been damaged to the extent that it is ineffective. Start coordinate: 32.71760179, -114.73656871 End coordinate: 32.71813154, -114.72859107 The second segment is 0.4 miles of replacement primary pedestrian fencing beginning at the Andrade port of entry, moving east. The replacement of ineffective pedestrian fencing in this area is necessary because the older landing mat design is easily breached and has been damaged to the extent that it is ineffective. Start coordinate: 32.71828514, -114.72627594 End coordinate: 32.71871991, -114.72028232 The third segment includes approximately 1.6 miles of replacement primary pedestrian fencing. The project is located west of the San Luis port of entry and runs north to south along the Colorado River. The replacement of ineffective pedestrian fencing in this area is necessary because the older mesh design is easily breached and has been damaged to the extent that it is ineffective. Start coordinate: 3251419938, -1 1480111753 End coordinate: 32.49350559, -114.81166187 Copy: DHS ESEC CBP ESEC Case Document 200-1 Filed 08/27/19 Page 15 of 25 TAB Case Document 200-1 Filed 08/27/19 Page 16 of 25 [?rcculit'e Secr?rfurji' LLS. Department of Homeland Securit} Washington. DC 20528 Homeland Security February 25, 2019 MEMORANDUM FOR: CAPT Hallock N. Mohler Jr. Executive Secretary Department of Defense FROM: Christina Bobb . 5 v, f. 5 Executive Secretary 'l Department of Homeland Security (DHS) SUBJECT: Request for Assistance Pursuant to 10 U.S.C. 284 I. Overview As the government department tasked with border security, the Department of Homeland Security (DI-IS), through US. Customs and Border Protection (CBP), is requesting that the Department of Defense assist DHS in its efforts to secure the southern border. The Secretary has directed me to transmit this request for assistance to your attention. This memorandum supersedes the February 22, 2019 version. In Section 102 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, as amended (IIRIRA), 8 U.S.C. 1103 note, Congress has directed DHS to construct border infrastructure in areas of high illegal entry to deter illegal crossing of both drugs and people into the United States. Pursuant to Section 102, DHS has identi?ed the areas set forth in Section 11 below as areas of high illegal entry where CBP must take action (the Project Areas). Within the Project Areas, DHS is experiencing large numbers of individuals and narcotics being smuggled into the country illegally. The Project Areas are also used by individuals, groups, and transnational criminal organizations as drug smuggling corridors. Mexican Cartels continue to remain dominant in these areas, influencing and controlling narcotics and human smuggling operations, within their respective strongholds. DHS must use its authority under Section 102 of IIRIRA to install additional physical barriers and roads in the vicinity of the United States border in order to deter and prevent illegal crossings within the Project Areas. The construction of border infrastructure within the Project Areas will support ability to impede and deny illegal entry and drug smuggling activities within the Project Areas. -- Case Document 200-1 Filed 08/27/19 Page 17 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 2 The Project Areas identi?ed are adjacent to some of the most densely populated metropolitan areas of Mexico and are also home to some of the strongest and most violent drug cartels in the world. Deterring and preventing illegal cross-border activity will help stem the ?ow of illegal narcotics and entries in these areas. Similarly, the improved ability to impede, deny, and be mobile within the Project Areas creates a safer operational environment for law enforcement. To support action under Section 102 of IIRIRA, DHS is requesting that DOD, pursuant to its authority under 10 U.S.C. 284(b)(7), assist with the construction of fences roads, and lighting within the Project Areas to block drug-smuggling corridors across the international boundary between the United States and Mexico. 11. Capabilities Requested Within the Project Areas there is existing vehicle fence and dilapidated pedestrian fencing. Vehicle fencing is intended to stop vehicles from illegally entering the United States, but can be climbed over or under by individuals. Pedestrian fencing is intended to prevent and deter individuals and vehicles from illegally crossing into the United States. DHS requests that assist in the execution of projects, within the Project Areas set forth below, to: (1) replace existing vehicle barriers or dilapidated pedestrian fencing with new pedestrian fencing; (2) construct roads; and (3) install lighting. The new pedestrian fencing includes a Linear Ground Detection System, which is intended to, among other functions, alert Border Patrol agents when individuals attempt to damage, destroy or otherwise harm the barrier. The road construction includes the construction of new roads and the improvement of existing roads. The lighting that is requested has an irnbedded camera that works in conjunction with the pedestrian fence. The lighting must be supported by grid power. The segments of fence within the Project Areas identi?ed below are situated on federal property. DHS will be responsible for securing, to the extent required, any other real estate interest or instrument that is required for project execution. In the event a real estate interest or instrument that is needed for project execution cannot be obtained for a segment of fence within a Project Area in a time frame that is within the requirements of this request for assistance, the segment may be withdrawn ?'om this request. In addition, DHS will be responsible for any applicable environmental planning and compliance to include stakeholder outreach and consultation associated with the projects. Case Document 200-1 Filed 08/27/19 Page 18 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 3 Project Areas: ILA. El Centro Sector Within the United States Border Patrol El Centro Sector (El Centro Sector) DHS is requesting that assist by undertaking road construction, by replacing approximately 15 miles of existing vehicle barrier with new pedestrian fencing, and by installing lighting in the speci?c locations identi?ed below. The speci?c Project Area identi?ed below is located in Imperial County, California and has been identi?ed by the Office of National Drug Control Policy (ONDCP) as a High Intensity Drug Traf?cking Area (I-HDTA). Multiple local transnational criminal organizations known for smuggling drugs into Calexico from Mexico using a variety of tactics, techniques, procedures, and varying concealment methods operate in this area, including Cartel De Jalisco Nueva Generacz?on (CJNG) as well as remnants of the Beltran Leyva Organization and La Familia Michoacana organizations. CING, based in Jalisco, was previously a faction of the Sinaloa Cartel. CJNG broke away from the Sinaloa Cartel and has become an established Mexican Cartel. The Mexican government has declared CJNG as one of the most dangerous cartels in the country. Due to the close proximity of urban areas on both sides of the border, the El Centro Sector suffers from some of the quickest vanishing times that is, the time it takes to illegally cross into the United States and assimilate into local, legitimate traffic. These quick vanishing times enable the illegal activities of transnational criminal organizations, whether they are smuggling people or narcotics. Border Patrol?s own experience with apprehensions between border crossings bears this out. In ?scal year 2018, there were over 29,000 apprehensions of illegal entrants attempting to enter the United States between border crossings in the El Centro Sector. Also in ?scal year 2018, Border Patrol had approximately 200 separate drug-related events between border crossings in the El Centro Sector, through which it seized over 620 pounds of marijuana, over 165 pounds of cocaine, over 56 pounds of heroin, and over 1,600 pounds of methamphetamine. The speci?c Project Area is as follows: 0 El Centro Project 1: The project begins approximately 10 miles west of the Calexico Port of Entry continuing west 15.25 miles in Imperial County. 0 Start coordinate: 32.63273, ?115.922787; End coordinate: 32.652563, -1 15.662399 Case Document 200-1 Filed 08/27/19 Page 19 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 4 ILB. Yuma Sector Within the United States Border Patrol Yuma Sector (Yuma Sector) DHS is requesting that assist by undertaking road construction, by replacing approximately 36 miles of existing vehicle barrier and approximately 6 miles of dilapidated pedestrian fencing with new pedestrian fencing, and by installing lighting in the speci?c locations identi?ed below. The speci?c areas identi?ed below are located in Yuma County, Arizona. Yuma County has been identi?ed by the ONDCP as a HIDTA. Of particular note is the operation of the Sinaloa Cartel in this area. The Sinaloa Cartel continues to be the most powerful cartel in the country and controls illicit networks and operations in the United States. Despite the arrest of Joaquin "El Chapo" Guzman-Loera, its narcotics business has continued uninterrupted. As a result, there have been no signi?cant changes within the Sinalaa Cartel?s hierarchy, or any changes in the illicit Operations conducted by the Sinaloa Cartel. Border Patrol?s own experience with apprehensions between border crossings bears this out. In ?scal year 2018, there were over 26,000 apprehensions of illegal entrants attempting to enter the United States-between border crossings in the Yuma Sector. Also during ?scal year 2018, Border Patrol had over 1,400 separate drug-related events between border crossings in the Yuma Sector, through which it seized over 8,000 pounds of marijuana, over 78 pounds of cocaine, over 102 pounds of heroin, over 1,700 pounds of methamphetamine, and over 6 pounds of fentanyl. The replacement of ineffective pedestrian fencing in this area is necessary because the older, wire mesh design is easily breached and has been damaged to the extent that it is ineffective. Additionally, this area is notorious for border violence and narcotics smuggling. Furthermore, while the deployment of vehicle barrier in the Yuma Sector initially curtailed the volume of illegal cross-border vehicular traf?c, transnational criminal organizations quickly adapted their tactics switching to foot traf?c, cutting the barrier, or simply driving over it to smuggle their illicit cargo into the United States. Thus, in order to respond to these changes in tactics, DHS now requires pedestrian fencing. The speci?c Project Areas are as follows: 0 Yuma Project I The project begins approximately 1 mile southeast of the Andrade Port of Entry continuing along the Colorado River for approximately 5 miles in Yuma County. 0 Start coordinate: 32.704197, -114.726013; End coordinate: 32.642102, -114.764632) Case Document 200-1 Filed 08/27/19 Page 20 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 5 Yuma Project 2: The project involves the replacement of two segments of primary pedestrian fencing in Yuma Sector for a total of approximately 6 miles. This includes approximately 2 miles of fencing along the Colorado River. 0 Start coordinate: 32.37755528, -114.4268201; End coordinate: 32.3579244, -114.3623999; The project also includes replacement of primary pedestrian fencing approximately 17 miles east of the San Luis Port of Entry, on the Barry Goldwater Range, continuing cast for approximately 4 miles. 0 Start coordinate: 32.51419938, -114.8011175; End coordinate: 32.49350559, -114.8116619 Yuma Project 3: The project begins approximately 0.4 miles east of the Barry M. Goldwater Range continuing approximately 31 miles east through the Cabeza Prieta National Wildlife Refuge in Yuma County. 0 Start coordinate: 32.232935, -113.955211; End coordinate: 32.039033, -113.33411 Tucson Sector Within the United States Border Patrol Tucson Sector (Tucson Sector) DHS is requesting that assist by undertaking road construction, by replacing approximately 86 miles of existing vehicle barrier with new pedestrian fencing, and by installing lighting in the speci?c locations identi?ed below. The speci?c areas identified below are located in Pima, Cochise, and Santa Cruz Counties, Arizona. Pima, Cochise and Santa Cruz Counties have been identi?ed by the ONDCP as a HIDTA. The Sinaloa Cartel relies on their local associates to coordinate, direct, and support the smuggling of illegal drugs and aliens from Mexico to the United States. Since Arizona is contiguous with the U.S.-Mexico International Boundary, the Tucson and Phoenix metropolitan areas are major trans-shipment and distribution points for contraband smuggling. Plaza bosses operate as a Sinaloa Cartel leader within their speci?c area of operation along the Sonora-Arizona corridor of the U.S.-Mexico International Boundary. Border Patrol?s own experience with apprehensions between border crossings bears this out. In ?scal year 2018, there were over 52,000 apprehensions of illegal entrants attempting enter the United States between the border crossings in the Tucson Sector. Also in ?scal year 2018 Border Patrol had over 1,900 separate drug-related events between border crossings in the Tucson Sector, through which it seized over 1,600 pounds of marijuana, over 52 pounds of cocaine, over 48 pounds of heroin, over 902 pounds of methamphetamine, and over 11 pounds of fentanyl. Document 200-1 Filed 08/27/19 Page 21 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 6 In addition, the absence of adequate pedestrian fencing, either due to the presence of vehicle barrier only or ineffective pedestrian designs, in the Tucson sector continues to be particularly problematic as it pertains to the traf?cking of illegal narcotics. Rival transnational criminal organizations frequently employ ?rip crews? who leverage the remote desert environment and lack of infrastructure to steal one another?s illicit cargo resulting in increased border violence. The terrain also provides high ground to scouts seeking to protect and warn smuggling loads being passed through the area. Transnational criminal organizations have successfully utilized this advantage in furtherance of their illicit activity and for this reason the area is in need of an improved capability to impede and deny illegal crossings or people and narcotics. In addition, the area hosts a number of tourist attractions that allow illegal activity to blend into legitimate activity; avoiding detection and evading interdiction. The speci?c Project Areas are as follows: 0 Tucson Project I . The project includes replacement of two segments of vehicle barriers. The ?rst segment begins approximately 2 miles west of the Lukeville Port of Entry continuing west approximately 30 miles. 0 Start coordinate: 32.038278, -113.331716; End coordinate: 31.890032, -1 12.850162 0 The second segment project begins approximately 3 miles east of the Lukeville Port of Entry and continues east approximately 8 miles in Pima County, Arizona. 0 Start coordinate: 31.8648, -112.76757; End coordinate: 31.823911, -112.634298 0 Tucson Project 2: The project includes approximately 5 miles of primary pedestrian fence replacement around the Lukeville Port of Entry extending from approximately 2 miles west of the port to approximately 3 miles east of the port. 0 Start coordinate: 31.88999921, -112.850162; End coordinate: 31.8648, -112.76757 Case Document 200-1 Filed 08/27/19 Page 22 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 7 Tucson Project 3: The project includes three segments of vehicle barrier replacement beginning approximately 18 miles west of the Naco Port of Entry and continuing to approximately 25 miles east of the Douglas Port of Entry (or approximately 5 miles west of the Arizona/New Mexico state line) for approximately 20 miles of non-contiguous vehicle barrier replacement in Cochise County, Arizona. Start coordinate: 31.333754, -1 10.253 863; End coordinate: 31.333767, -110.250286; Start coordinate: 31.334154, -110.152548; End coordinate: 31.334137, -110.147464; Start coordinate: 31.333995, -109.453305; End coordinate: 31.332759, -1 09. 1 29344 0 Tucson Project 4: The project begins approximately 9 miles east of the Nogales Port of Entry and continues eastward for approximately 30 miles with approximately 26 miles of non-contiguous vehicle barrier replacement in Santa Cruz and Cochise Counties, Arizona. Start coordinate: 31.333578, -110.79579; End coordinate: 31.333511, -110.775333; start coordinate: 31.33328, -110.70545; End coordinate: 31.333602, -110.288665) Note: 'An additional approximately 0.3 miles of new pedestrian fence could be built between the existing segmented vehicle barrier locations to ?ll existing gaps if appropriate real estate interest can be veri?ed Tucson Project 5: The project includes approximately 2 miles of vehicle barrier replacement beginning approximately 4.5 miles east of the Sasabe Port of Entry continuing east in six non-continuous segments for approximately 15 miles in Pima and Santa Cruz Counties, Arizona. Start Coordinate: 31.460175, -11 1.473171; End Coordinate: 31.459673, -111.471584; Start Coordinate: 31.453091, -111.450959; End Coordinate: 31.449633, -111.440132; Start Coordinate: 31.440683, -111.412054; End Coordinate: 31.437351, -11 1.40168; Start Coordinate: 31.423471, -1 1 1.358336; End Coordinate: 31.422541, -1 1 1.355444; Start Coordinate: 31.42221, -1 11.354379; End Coordinate: 31.421321, -111.351608; Case Document 200-1 Filed 08/27/19 Page 23 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 8 0 Start Coordinate: 31.386813, -1 11.243966; End Coordinate: 31.385462, -1 1 1.239759) II.D. El Paso Sector Within the United States Border Patrol El Paso (El Paso Sector) DHS is requesting that assist by undertaking road construction, by replacing approximately 70 miles of existing vehicle barrier with new pedestrian fencing, and by installing lighting in the speci?c locations identi?ed below. The speci?c areas identi?ed below are located in Luna, Hidalgo and Do?a Ana Counties, New Mexico. Luna, Hidalgo and Do?a Ana Counties have been identi?ed by the ONDCP as a HIDTA. There are three speci?c transnational criminal organizations of interest operating in the El Paso Sector - the Sinaloa Cartel as well as remnants of the Juarez Cartel and the Beltran Leyva Organization. In the El Paso Sector the Sinaloa Cartel employs a variety of tactics, techniques and procedures depending upon the terrain and environment to move drugs across the border. While the Sinaloa Cartel has a strong presence and control of territories at the ?anks of the Sector, it does not have full control of the territory throughout the El Paso Sector. The Juarez Cartel, traditionally a major traf?cker of marijuana and cocaine, has become an active member in opium cultivation and heroin production. Border Patrol?s own experience with apprehensions between border crossings bears this out. In ?scal year 2018, there were over 31,000 apprehensions of illegal entrants attempting to enter the United States between border crossings in the El Paso Sector. Also in ?scal year 2018, Border Patrol had over 700 separate drug-related events between border crossings in the El Paso Sector, through which it seized over 15,000 pounds of marijuana, over 342 pounds of cocaine, over 40 pounds of heroin, and over 200 pounds of methamphetamine. Although the deployment of vehicle barrier in the El Paso Sector initially curtailed the volume of illegal cross-border Vehicular traf?c, transnational criminal organizations quickly adapted their tactics switching to foot traffic, cutting the barrier, or simply driving over it to smuggle their illicit cargo into the United States. Thus, in order to respond to these changes in tactics, CBP now requires pedestrian fencing. Successfully impeding and denying illegal activities or transnational criminal organizations in this area is further complicated by the close proximity of New Mexico Highway 9 to the border. In some cases the highway is less than a half a mile, allowing illegal cross-border traf?c to evade detection and apprehension and quickly vanish from the border area. Case Document 200-1 Filed 08/27/19 Page 24 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 9 The speci?c Project Areas are as follows: 0 El Paso Project 1: The project includes 46 miles of vehicle barrier replacement beginning approximately 17.5 miles west of the Columbus Port of Entry continuing east in non-contiguous segments to approximately 35 miles east of the Columbus Port of Entry within the Luna and Do?a Ana Counties, New Mexico. 0 Start Coordinate: 31.7837, -107.923151; End Coordinate: 31.783689, -107.679049; 0 Start Coordinate: 31.783672, -107.573919; End Coordinate: 31.783741, -107.03 81 54 0 El Paso Project 2: The project includes 23.51 miles of Vehicle Barrier replacement in non- contiguous segments within Hidalgo and Luna Counties, New Mexico. The ?rst segment begin approximately 5.1 miles east of the New Mexico/Arizona Border continuing east 4.55 miles. 0 Start Coordinate: 31.332323, -108.962631; End Coordinate: 31.332292, -108.885946; 0 The second segment begins approximately 3 miles west of the Antelope Wells Port of Entry to 3 miles east of the port of entry for 6.12 miles of Vehicle Barrier replacement. 0 Start Coordinate: 31.333368, 408.582412; End Coordinate: 31.333407, -1 08.47926; 0 The third segment begins approximately 20 miles west of the Columbus Port of Entry extending west 12.84 miles. 0 Start Coordinate: 31.783722, -108.182442; End Coordinate: 31.783708, -107.963193; Technical Speci?cations As set forth above, DHS requires road construction, installation of lighting, and the replacement of existing vehicle barrier or dilapidated pedestrian fencing with new pedestrian fencing within the Project Areas. DHS will provide with more precise technical speci?cations as contact and project planning moves forward. Given experience and technical expertise, DHS plans to coordinate closely with throughout project planning and execution, to include review and approval of design speci?cations, barrier alignment and location, and other aspects of project planning and execution. Case Document 200-1 Filed 08/27/19 Page 25 of 25 Subject: Request for Assistance Pursuant to 10 U.S.C. 284 Page 10 IV. Sequencing The DHS request for assistance includes approximately 218 miles in which DHS requires road construction, the installation of lighting, and the replacement of existing vehicle fencing or dilapidated pedestrian fencing with new pedestrian fencing within the Project . Areas. DHS requests that DoD?s support under 10 U.S.C. 284 address the requirements in order of priority as resources allow. The DHS order of priority is as follows: Yuma Sector Project 1 Yuma Sector Project 2 El Paso Sector Project 1 El Centro Sector Project 1 Tucson Sector Project 1 Tucson Sector Project 2 Tucson Sector Project 3 Tucson Sector Project 4 . Yuma Sector Project 3 10. El Paso Sector Project 2 11. Tucson Sector Project 5 V. Funding DHS requests that provide the above-referenced border fences, roads, and lighting on a non-reimbursable basis as support to block drug smuggling corridors. DHS will accept custody of the completed in?'astructure and account for that infrastructure in its real property records. DHS will operate and maintain the completed in?'astructure. VI. Conclusion DHS requests assistance under 10 U.S.C. 284 to construct fences, roads, and to install lighting in order to block drug smuggling corridors in the Project Areas set forth above. The Projects Areas set forth above are also areas of high illegal entry under IIRIRA 102(3), and the requested fences, roads, and lighting will assist in deterring illegal crossings in the Project Areas.