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Surfrider Submits Comment Letter to EPA re: Infrastructure Projects to Improve Border Water Quality

On June 17, the U.S. EPA released a Draft Programmatic Environmental Impact Statement (PEIS) for the most comprehensive package of projects ever proposed to combat sewage issues at the US/Mexico border. This followed the EPA’s 2021 decision to move forward with environmental review of the projects, for which $300 million in federal money was allocated as part of the US Mexico Canada Agreement negotiations (aka USMCA, which replaced NAFTA) in 2020. 

Detailed environmental review of proposed federal projects is legally required per the National Environmental Policy Act of 1969 (NEPA), which requires that federal agencies fully consider the environmental effects of proposed major actions as well as any reasonable alternatives. Environmental review, in this case the Draft PEIS, also gives the public an opportunity to review and comment on the proposals to ensure their feedback is considered in the Final PEIS. 

On behalf of the beachgoing communities we represent, Surfrider, in partnership with local nonprofit Outdoor Outreach, submitted a public comment letter to the EPA in support of the most comprehensive solutions reviewed to ensure maximum prevention and mitigation of the crossborder sewage flows that ravage coastal waters and habitat on both sides of the border. 

A map rendering of Alternative 2: Core + Supplemental Projects on both sides of the border. Source: EPA

Here is a summary of our letter's main points and recommendations: 

  • We were pleased to see several components of Surfrider’s 2019 TRV Solution conceptual plan incorporated into the Draft PEIS.
  • The “do nothing alternative” is NOT AN OPTION.
  • We support the most comprehensive plan, the Alternative 2 Comprehensive Solution, which includes 6 partially reviewed supplemental projects in addition to the 4 Core Projects that received full environmental review.
  • The South Bay International Treatment Plant must be upgraded from its current 25 million gallons per day (MGD) capacity to the highest level proposed, 60MGD. The 40 & 50MGD options are insufficient to keep pace with projected population growth in Tijuana.
  • Plans to address physical waste, including plastic pollution, must be considered an important component of the mitigation of transboundary pollution. Therefore, implementation of comprehensive trash capture and extraction will be necessary in addition to wastewater management improvements.
  • The threat that climate change and accelerated sea level rise projections pose to the Tijuana River Estuary, not to mention the Imperial Beach shoreline, provides further evidence as to why the most comprehensive alternative must be implemented.
  • Additional funding from several federal and state sources will be available to fully fund and implement the entire spectrum of projects.
  • We urge the EPA and IBWC to take action as quickly and comprehensively as possible to implement Alternative 2: Core + Supplemental Projects.

Click HERE to read our full comment letter

Additional resources

In addition to the Draft PEIS, the EPA hosted two virtual public meetings during the 45-day comment period in order to cover the main components of the projects reviewed in the PEIS. Below is a recording of the first presentation (both presentations covered identical subject matter), as well as a PDF of the slide deck used in the presentations. The EPA’s webpage re: the project can be found HERE


Access the presentation slide deck HERE.

What's Next?

The EPA will now review public comments and issue a Final PEIS as soon as December of this year. If they hold true to their timeline, construction of the Core Projects could begin as early as next year. Because not all of the supplemental projects were given full environmental review in this PEIS, a secondary Environmental Impact Statement will need to be completed before those projects can begin. Additionally, completion of the supplemental projects is still contingent on whether additional funding is allocated towards this critical effort. The PEIS estimates a $600m+ price tag for implementation of the full suite of projects; currently, only $300m has been allocated.

Rest assured that Surfrider and its partners will continue to advocate for full funding at all levels of government. If you would like to stay updated on our ongoing Clean Border Water Now campaign, please subscribe to chapter email updates at the bottom of this webpage.