A Current Perspective on Construction Activity and Its Impact on Cultural Properties along the United States/Mexico Border

02/26/2020 2:30 PM | ACRAsphere Blog Team

This post is authored by Duane E. Peter (DP Heritage Consulting) and Richard Martynec.*

The archaeological community has expressed great concern regarding the potential impact of construction activities on cultural properties along the United States/Mexico border several times over the past three decades. This concern was sometimes warranted but frequently the concern was based on a lack of understanding of what was actually happening along the border. The following article provides a historical perspective of construction activities along the border and the associated efforts to protect the environment and cultural properties. The waiving of environmental regulations in 2017 to facilitate border wall construction has increased the potential for significant impacts to both natural and cultural resources.

Potential impacts to natural and cultural resources along the United States/Mexico border became a subject of concern with the creation of Joint Task Force-Six (JTF-6) in 1989 in response to President George H. W. Bush’s renewed counterdrug efforts (Joint Task Force North 2017). The perceived need for greater surveillance along the U.S. southern border required the development of infrastructure (primarily roads); therefore, as required under the National Environmental Policy Act (NEPA) and the National Historic Preservation Act, the potential impacts of the proposed federal action were assessed. JTF-6 sponsored a Programmatic Environmental Impact Statement (EIS) addressing the potential impacts to the environment and cultural properties in the early 1990s (U.S. Army 1994). Admittedly, the approach used a broad brush because the EIS addressed a 50-mile-wide corridor parallel to the border; nevertheless, all existing data were synthesized and natural and cultural resource inventory surveys were conducted immediately adjacent to the border and where road construction was projected to take place. These efforts were initiated in 1990 and natural and cultural resource surveys continued for well over a decade. Professional teams, consisting of both biologists and archaeologists, have actively monitored construction activities along the border since 1990.

There has been a continuing effort to avoid impacts to biological and cultural resources, but the system for avoidance has not been perfect. Much of the border is within a desert environment in which wind and water erosion may either bury or expose sites; consequently, new sites may be encountered or previously recorded sites may be less visible. Inadvertent impacts to sites have happened. Monitoring crews are frequently spread across significant distances and multiple construction crews. Mitigation of impacts has occurred in some instances.

Much of the environmental compliance conducted along the border since 1995 has been accomplished through reliance on the original Programmatic EIS or tiering new documentation off the original EIS. Some would argue that reliance on a document produced over 25 years ago is irresponsible; nonetheless, there has been a good-faith effort to avoid impacts to natural and cultural resources. In August of 2017, however, the Trump administration waived numerous major environmental laws to build a wall and fencing along the border with Mexico. The Department of Homeland Security (DHS) announced the waiver citing its authority under a 2005 law to set aside any laws and regulations, including the National Environmental Policy Act and the National Historic Preservation Act, when necessary for border infrastructure. DHS made the following statement at the time of the announcement:

“While the waiver eliminates DHS’s obligation to comply with various laws with respect to covered projects, the department remains committed to environmental stewardship with respect to these projects.” “DHS has been coordinating and consulting — and intends to continue doing so — with other federal and state resource agencies to ensure impacts to the environment, wildlife, and cultural and historic artifacts are analyzed and minimized, to the extent possible.” (Cama 2017)

It is true that multiple companies are currently providing archaeological monitoring along the border. We are aware of one company providing multiple monitoring teams consisting of an archaeologist and a member of the Tohono O’odham nation. Elsewhere a single archaeologist may be responsible for oversight of multiple construction crews over a 26-mile segment of the border. The pace of the construction is impacting the ability of DHS to ensure that archaeological sites are avoided.

The Tohono O’odham and professional archaeologists (both independent archaeologists and National Park Service staff at Organ Pipe Cactus National Monument have recently brought the potential for archaeological sites to be impacted to the attention of DHS and the public. Three sites are of major concern to the Tohono O’odham: Quitobaquito Springs at Organ Pipe Cactus National Monument, and two sites (Las Playas and an O’odham-style cist burial) at Cabeza Prieta National Wildlife Refuge. The latter two sites are within the 60-foot swath of the construction zone along the border. Quitobaquito Springs is less than 400 meters north of the border. The concern at Quitobaquito Springs is focused equally on the impact of the border construction on the water supply and the associated archaeological remains.

Aside from the well-known archaeological remains at Quitobaquito there are other important sites that are imperiled by the on-going construction of the border wall. At least portions of 17 sites farther west will be directly impacted, and another three are near the construction zone known as the Roosevelt Corridor. Two of the sites are important, one is a burial and the other is a rare intaglio (Martynec and Martynec 2011; 2014).

Intaglios or giant ground figures have been observed along the Colorado River, Sierra Pinacate and now in the western Papaguería. Those along the Colorado River have been attributed to Yuman or Patayan groups whereas the images in Sierra Pinacate are thought to have been made by Amargosan Pinacateños, or ancestral O’odham. The figures along the Colorado River are often representational and are mostly devoid of artifacts or evidence of reuse. This is not the case for those in Sierra Pinacate and the recently discovered intaglio in Cabeza Prieta National Wildlife Refuge. Many of the latter, including the Las Playas Intaglio west of Ajo, are complex with indications they were reused and, in some cases, over a considerable amount of time.

The Las Playas Intaglio measures 84 m north-south by 15 m east-west and was created by clearing the dark colored pebbles forming desert pavement and tamping down the underlying light colored sandy silt 2-3 cm below the surrounding ground surface thus creating a startling contrasting image.

All of the rocks associated with this feature are as dark as the surrounding desert pavement and at various points in time rocks have been placed in and around this giant ground figure. A total of ten head-size basalt rocks are in four different locations adjacent to the tamped down areas, and at the south end is a 1.5-m diameter cluster of basalt rocks and there is another concentration of six basalt rocks blocking a narrow, old, north-south tamped down trail that bisects this feature. Several of the rocks in the cluster at the south end exhibit shell caliche on exposed surfaces. This characteristic, which indicates fairly recent activity, was only observed at this location and on one of the large rocks inside the intaglio.

Aerial Photograph of Las Playas Intaglio

While it is obvious that a majority of the surrounding site is the product of camping episodes or short-term occupations, the overall impression the Las Playas Intaglio site and the surrounding landscape imparts is one of special purpose. It is apparent that this location held a special meaning for the prehistoric inhabitants of the area and Tohono O’odham elders have confirmed that ceremonies occurred at this locale. The near absence of artifacts in the intaglio (only two) supports the conclusion of its special importance, especially when one considers the numerous artifacts elsewhere within the surrounding site.

This giant ground figure appears to be old, dating at least to the Formative period (A.D. 800-1500), and possibly even earlier. All of the rocks in the tamped down areas are light colored in distinct contrast with the dark colored surrounding desert pavement and, except for the rock concentration at the south end, only one of the large, ancillary rocks exhibits shell caliche on exposed surfaces. Because of this it is reasoned that the rock concentration at the south end is a recent construct signifying reuse, as does the blocked interior trail.

The intaglio extends well into the Roosevelt Corridor and the burial is within 15 feet of the current wall. It is unclear if avoidance of these sites is part of the current construction plan. The Tohono O’odham requested that a buffer zone be created for these three sites; however, DHS denied that request (letter to Chairman Ned Norris of the Tohono O’odham Nation from Roy D. Villareal the Chief Patrol Agent, Tucson Sector Chief of U.S. Customs and Border Protection dated 1/10/20). Current observation of the border construction activities indicates that the pace of work is increasing and that avoidance of environmental or cultural resources is not occurring. It is very clear that impacts to the use of the traditional cultural landscape are being ignored.

In summary, we feel that JTF-6 and DHS proceeded with good intentions and have historically made a good faith effort to avoid impacts to environmental and cultural resources. In 2004 and 2005 when the original vehicle barrier was being installed near the Las Playas Intaglio site, Arizona Site Stewards placed many small rocks at the south end of the intaglio near the road. They also showed the construction team the intaglio and explained that it was on a slightly elevated flat that would be an ideal location for Border Patrol agents to park for surveillance. The construction team placed huge boulders among the comparatively small rocks the Stewards had positioned, thereby protecting the area. There was sufficient time and a sense of cooperation that is not occurring today. The perceived urgency for a Border Wall and the resulting fast-paced construction is jeopardizing the environment and the cultural properties that these agencies have identified and evaluated. A recent Washington Post article (Firozi 2020) regarding the potential impact of burials on Monument Hill within the Organ Pipe Cactus National Monument is primary evidence of the increased potential for impacts to important archaeological sites. Specific details regarding the impacts are not known; however, no human burials had been encountered as of 9 February. Such fanfare could have been avoided through early cooperative planning among DHS, the construction company, the archaeological monitors, and the Tohono O’odham nation. Significant archaeological sites could have been avoided or mitigated in a timely manner and construction could have proceeded. Respect for differing views, cooperation, and commonsense solutions can achieve the same goal as regulations. Nevertheless, the waiver or elimination of environmental regulations is hardly a sound basis for a sustainable environment for future generations. Regulations are essential to ensure that the natural and cultural environment are protected.

*This perspective of construction along the U.S./Mexico Border and its potential impacts to the environment and cultural properties reflects the participation of both authors with the survey and monitoring efforts conducted during the 1990s and the continued work of Rick and Sandy Martynec as independent researchers of the border region and as Arizona Site Stewards. This article reflects the opinions of the authors only.


Cama, Timothy

2017  DHS Waives Environmental Laws to Speed Border Wall Construction. https://thehill.com/policy/energy-environment/344772-trump-admin-waives-environmental-laws-for-border-wall-construction. accessed February 6, 2020.

Firozi, Paulina

2020 Sacred Native American burial sites are being blown up for Trump’s border wall, lawmaker says. https://www.washingtonpost.com/immigration/2020/02/09/border-wall-native-american-burial-sites/

Joint Task Force North

2017 History – Joint Task Force North. https://www.jtfn.northcom.mil/About-Us/History/. accessed February 6, 2020.

Martynec, Richard J. and Sandra K. Martynec

2011 Las Playas. Ajo Chapter of the Arizona Archaeological Society Archaeological Series, Number 6.
 2014 Las Playas. Kiva 80(1): 71-105.

U.S. Army

1994 Final Programmatic Environmental Impact Statement, JTF-6 activities along the U.S.-Mexico Border. U.S. Army Corps of Engineers, Fort Worth District, Fort Worth, Texas.

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