Customs And Border Protection Research Articles

The securitisation of immigration through the Tactical Terrorism Response Team

ABSTRACT This article considers a significant stage in the convergence of US counterterrorism policy and immigration enforcement exemplified by the emergence of a Customs and Border Protection (CBP) unit known as the Tactical Terrorism Response Team (TTRT). In my analysis I show: (i) that TTRT agents engage in a process I call social homicide which subjects travellers to a condition of bare life; (ii) that the increasing production of border violence highlights that the convergence of securitisation and immigration enforcement is a praxis of anti-Blackness and Islamophobia; (iii) that securitisation and exclusionary immigration policy have made use of invisibility to create and expand a permanent state of exception; and (iv) that border enforcement through securitisation is used as a mechanism for the surveillance and control of social movements inside the United States. Given the limited public information on TTRT’s operations, this study explores the matter through a case study of Abdikadir Mohamed’s 2017 encounter with the unit, his subsequent immigration proceedings, and the FOIA lawsuit filed against CBP for more information on the TTRT.

Governed bodies, discarded bodies: Notes for an analysis of contemporary migrations during Covid-19

This article presents the results of an ethnographic research conducted in the northern border of Mexico from 2019 to 2021, specifically in the city of Tijuana. The objective of this article is to analyse the role of bodies in border and migration management with special emphasis on the time of the Covid-19 pandemic. To do so, I focus on three situations. First is the case of migrants whose bodies are exploited in the precarious work opportunities they find along Mexico’s northern border. Second, I look at migrants who experience detention and confinement in Customs and Border Protection (CBP) detention centres in the United States. And third, I analyse the situation of missing migrants whose bodies are sought by family members and numerous collectives in Mexico. Through the analysis of these situations, the article demonstrates that by using ‘bodies’ as a productive category for analysing migration and the containment of migratory movements, we can understand both the resulting negative effects on migrants’ subjectivity and bodies and how migrants respond to and challenge the global migration system.

625 The Impact of the Mexico-San Diego Border Wall Extension on Spinal Injuries

INTRODUCTION: San Diego, California has one of the busiest international land borders in the world, and its unauthorized crossing is a contentious issue. The recent border height extension along the San Diego-Mexico border has led to a new set of physical risks to unauthorized individuals traversing the wall. METHODS: In this retrospective cohort study, patients who presented to the UC San Diego Trauma Center between 2016 and 2021 were considered. Two different cohorts were compared: pre-height extension (Jan 2016-May 2018), and post-height extension (January 2020-December 2021). Demographics, clinical data (fracture morphology, operative intervention, concurrent injuries, length of stay), and hospital costs were collected. Spinal injuries were normalized using Customs and Border Protection (CBP) apprehensions to adjust for changing migration rates. Statistical analysis was completed with Stata MP Version 14.1 (Stata Corp LP). RESULTS: A total of 114 patients met inclusion criteria: 12 in the pre-height extension period, and 102 in the post-height extension period. The increase in spine injuries per month (0.8 to 4.25) and operative spine injuries per month (0.3 to 1.7) were statistically significant (P < 0.001). Concurrent extremity injuries were also significantly increased (8.3 vs. 43.1%, p = 0.02). The severity of injuries and economic costs were reflected in median length of stay (6 vs. 9 days; p = 0.006) and median total hospital charges ($150,914 to $293,798; p < 0.001). CONCLUSIONS: The data support that the San Diego-Mexico border wall extension is correlated with more frequent, severe, and costly spinal injuries. These findings advocate for reevaluating our current border wall infrastructure as this represents a humanitarian and public health crisis.

Port-of-Entry Simulation Model for Potential Wait Time Reduction and Air Quality Improvement: A Case Study at the Gateway International Bridge in Brownsville, Texas, USA

The mathematical study known as queueing theory has recently become a major point of interest for many government agencies and private companies for increasing efficiency. One such application is vehicle queueing at an international port-of-entry (POE). When queueing, fumes from idling vehicles negatively affect the overall health and well-being of the community, especially the U.S. Customs and Border Protection (CBP) agents that work at the POEs. As such, there is a need to analyze and optimize the border crossing queuing operations to minimize wait times and number of vehicles in the queue and, thus, reduce the vehicle emissions. For this research, the U.S.–Mexico POE located at The Gateway International Bridge in Brownsville, Texas, is used as a case study. Due to data privacy concerns, the hourly wait times for vehicles arriving at the border had to be extracted manually each day using a live wait time tracker online. The data extraction was performed for the month of March 2022. Using these wait times, a queueing simulation software, SIMIO, was used to develop an interactive simulation model and calibrate the service rates. The output from the SIMIO model was then used to develop an artificial neural network (ANN) to predict hourly particulate matter content with an R2 of 0.402. From the ANN, a predictive equation has been developed, which may be used by CBP to make operational decisions and improve the overall efficiency of this POE. Thus, lowering the average wait times and the emissions from idling vehicles in the queue.

Where Was this T-Shirt Made?

In March 2021, Biden’s administration formally declared China’s treatment of Uyghur Muslims a genocide in its annual human rights report published by the Department of State. It is difficult not to conclude that these findings may have also been influenced by the rare bipartisan criticisms aimed at China’s human rights record over the last few years. 
 This bipartisan condemnation of the Chinese government seems to have paid off as President Joseph R. Biden signed into law the Uyghur Forced Labor Prevention Act (UFLPA) on December 23, 2021. This legislation prohibits the importation of goods produced with forced labor in China as it directs US Customs and Border Protection (CBP) to apply a rebuttable presumption that “any goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China” have been made with forced labor. 
 This Note argues that given the UFLPA’s overbroad economic implications and lack of clear enforcement mechanisms, is neither effective nor a realistic way of holding American companies seeking to import products from China accountable in the long term.

Supply chain security certification and operational performance: The role of upstream complexity

Supply chain security (SCS) incidents increasingly cause financial losses to manufacturing facilities and logistics service providers. Thus, supply chain security certification can have implications for production economics, particularly for importing firms who rely on a smooth logistics flow across country borders. However, it largely remains unknown regarding how such certification could influence a firm's operational performance. To this end, we empirically examine whether and how the adoption of Customs-Trade Partnership Against Terrorism (C-TPAT) certification, initiated by the U.S. Customs and Border Protection (CBP), could improve operational performance in adopter firms. This study draws upon signaling theory to empirically investigate the value of C-TPAT certification on U.S. publicly-traded importer firms' operational performance by analyzing the longitudinal data of properly-matched sample-control groups. The data come from multiple sources: public announcements of C-TPAT certification from the News Retrieval Service database, import data from lading records, and financial data from Standard & Poor's COMPUSTAT database. Employing a coarsened exact matching (CEM) method and a difference-in-difference (DID) analysis, we find that C-TPAT certified importers have better operational performance than that of non-certified importers. We also find that the level of upstream supply chain complexity (detail, dynamic, and spatial complexity) enhances the operational performance derived from C-TPAT certification. This study sheds light on the performance value of a management standard that is attributed to the non-process mechanism (not due to process improvements) enabled by the signaling effectiveness incorporating the upstream supply chain complexities. Our findings have important theoretical and practical implications for production economics and supply chain management studies.

The use of biometric technology at airports: The case of customs and border protection (CBP)

Biometrics in an airport environment can provide a contactless way of identity verification. U.S. Department of Homeland Security (DHS) has been trialling and implementing the Biometric Entry Exit Program at U.S. Customs and Border Control (CBP). Using the Traveller Verification System (TVS), the program biometrically confirms the traveller's identity and their entry or exit, with an increased ability to detect fraudulent documents and visa overstays. This paper assesses the Biometric Exit Program to analyse the use of biometrics at airports and identify the challenges faced. An analysis is conducted on the Entry Exit Program at Dublin Airport, including facial recognition boarding gates. Pilot test results from Dublin Airport and other U.S. airports are used to identify challenges. These included a gap in stakeholder support, low biometric matching rate, infrastructure and network connectivity issues, privacy concerns amongst travellers, and heavy reliance on airlines. Recommendations and solutions for advancement are provided.

The Impact of COVID-19 on Immigration Detention

COVID-19 has spread quickly through immigration detention facilities in the United States. As of December 2, 2020, there have been over 7,500 confirmed COVID-19 cases among detained noncitizens. This Article examines why COVID-19 spread rapidly in immigration detention facilities, how it has transformed detention and deportation proceedings, and what can be done to improve the situation for detained noncitizens. Part I identifies key factors that contributed to the rapid spread of COVID-19 in immigration detention. While these factors are not an exhaustive list, they highlight important weaknesses in the immigration detention system. Part II then examines how the pandemic changed the size of the population in detention, the length of detention, and the nature of removal proceedings. In Part III, the Article offers recommendations for mitigating the impact of COVID-19 on detained noncitizens. These recommendations include using more alternatives to detention, curtailing transfers between detention facilities, establishing a better tracking system for medically vulnerable detainees, prioritizing bond hearings and habeas petitions, and including immigration detainees among the groups to be offered COVID-19 vaccine in the initial phase of the vaccination program. The lessons learned from the spread of COVID-19 in immigration detention will hopefully lead to a better response to any future pandemics. In discussing these issues, the Article draws on national data from January 2019 through November 2020 published by Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP), two agencies within DHS. The main datasets used are detention statistics published by ICE for FY 2019 (Oct. 2018-Sep. 2019), FY 2020 (Oct. 2019-Sep. 2020), and the first two months of FY 2021 (Oct. 2020-Nov. 2020). These datasets include detention statistics about individuals arrested by ICE in the interior of the country, as well as by CBP at or near the border. Additionally, the Article draws on separate data published by CBP regarding the total number of apprehensions at the border based on its immigration authority under Title 8 of the United States Code, as well as the number of expulsions at the border based on its public health authority under Title 42 of the United States Code.

Setting the Wrong Standard: A Review of Separated:

From 2017 to 2019, Soboroff covered “the greatest human-rights catastrophe” on American soil, uncovering the systematic separation of migrant families at the US-Mexico border, which had become the official policy of the Department of Homeland Security (DHS).1 The author’s experience brings a personal element to his fact-based reporting, which skillfully incorporates sources from the DHS, Office of Refugee Resettlement, Customs and Border Protection (CBP), Health and Human Services (HHS), and global immigration-focused nonprofits. Even when the Office of the United Nations High Commissioner for Human Rights (OHCHR) condemned the policy for being an “arbitrary and unlawful interference in family life” and “a serious violation of the rights of the child,” the evasion of responsibility continued.8 In a statement following the accusation, former US Ambassador to the UN Nikki Haley wrote, “While the High Commissioner’s office ignorantly attacks the United States with words, the United States leads the world with its actions.” After his harrowing descriptions of children wailing for their parents in overcrowded detention centers, it is not surprising that PHR discovered mental health conditions in many of the young children they evaluated.12 In a report from October 2020, PHR detailed the conditions brought about by the trauma of family separation, such as post-traumatic stress disorder, major depressive disorder, or generalized anxiety disorder.13 In an article for Human Rights Watch, senior quantitative analyst Brain Root explains that family separation in the United States is symptomatic of a much larger global problem: a disregard for the basic human rights of migrants.14 At the height of the Syrian refugee crisis in 2015, xenophobic policies put into place by populist leaders from Italy to Hungary were similarly justified by national security. In 2019, the DHS implemented the Migrant Protection Protocols, or the Remain in Mexico policy, which primarily targeted asylum seekers from El Salvador, Guatemala, Honduras, Nicaragua, and Mexico.17 Under this policy, asylum seekers were forced to wait for delayed asylum hearings in makeshift camps on the other side of the border, where the risk of homicide, femicide, kidnapping, and sexual assault was high.

The Citizen Question: Making Identities Visible Via Facial Recognition Software at the Border

In late 2018, Jet Blue, American Airlines, and Delta began utilizing facial recognition software (FRS) American airports: Jet Blue explained that the company had, in partnership with U.S. Customs and Border Protection (CBP), today announced the roll-out of its first fully-integrated biometric self-boarding gate. The airlines' cooperation with the CBP, the Department of Homeland Security, and the Transportation Security Agency is part of a larger program titled the Biometric Air Exit (BAE) aimed at biometrically [verifying] the departure of foreign nationals from the United States. In this way, the face included a passport or visa, and/or included mechanisms like the BAE, becomes the citizen's way of proving their worth as a and their belonging to the membership of that nation. Examining how FRS is used to identify and sort citizenship within mechanisms like the BAE is immensely important; alongside this, the process of how citizen and noncitizen is defined, as data points within larger mechanisms like the BAE, need to be made transparent. The categories of citizen and non-citizen, as sortable data categories, are not objective and are vulnerable to political purposes; building FRS with such categories at their cores leaves FRS open to manipulation by political systems. Increasing transparency throughout systems like FRS serves dual purposes: it will generate informed and effective policy and regulation of the technology; and it will clarify the political motivations behind labeling certain individuals and populations as citizens and others as non-citizens.

The economic benefits of trade facilitation: U.S. Customs and Border Protection’s Centers of Excellence and Expertise programme

AbstractWe evaluate the impacts of the Customs and Border Protection (CBP) Center of Excellence and Expertise (CEE) Program on the U.S. trade community. CBP established ten CEEs in order to facilitate trade by removing non‐tariff barriers. CEEs process importers at “virtual” centres as opposed to individual ports of entry, and they are specialised according to particular sectors. CEEs were anticipated to use government resources more efficiently, reduce paperwork, improve information flows and contribute towards a single window for documenting trade. We use difference‐in‐difference (DID) analysis of CBP administrative data to identify the impacts of importer membership in a CEE on key outcomes, including import shipment examination rates and form filings. We also use survey‐generated data on importer administrative and business costs in order to monetise the value of impacts. These data reveal that the cost to importers of having a shipment examined at a port is roughly ten to twenty times higher than the cost of importers having to file a form with a CEE. Estimated impact results suggest that two of the ten CEEs‐‐Electronics and Automotive‐‐had a statistically significant negative impact on examination rates. We review the reasons for these results, which underscore the need when doing an impact analysis for careful understanding of the underlying data and processes involved in order to develop and explain impact results. For the two CEEs that had significant impacts on import examinations, we quantify the monetary value of these impacts and estimate that they saved their members roughly $1 million in trade examination costs in FY 2014. We also estimate that expanding membership to cover more importers could yield savings of between $7 million and $18 million annually. Finally, we find that CBP could redirect approximately 9,000 import examinations and 7,000 form filings from lower‐risk CEE importers to higher‐risk importers, possibly increasing trade‐enforcement effectiveness.

Suffering Children and Handcuffed Doctors: US Immigration Policy and a Call for Advocacy.

* Abbreviations: CBP — : Customs and Border Protection COVID-19 — : coronavirus disease In December 2019, 6 protestors advocating for the implementation of an influenza vaccination program in Customs and Border Protection (CBP) detention facilities were arrested by the US Department of Homeland Security Federal Protective Services at the CBP San Diego sector headquarters. Four of the 6 were licensed practicing physicians who had arrived flu shots in hand, ready to volunteer their time and services. Whereas the arrested physicians wore white coats and stethoscopes, the officers making those arrests were clothed in army fatigues, riot gear, and automatic weapons, a stark contrast for the dozens of additional health care professionals and handful of news media crews present to witness the event. As the physicians began having their hands zip-tied behind their backs, one was seen removing the pediatric stethoscope from around his neck and placing it on the ground before being led away in handcuffs. That afternoon’s events represented the culmination of months of unsuccessful attempts by the medical community to persuade CBP to reconsider its stance on denying asylum seekers to the United States access to influenza vaccines. During the 2018 to 2019 influenza season, 3 migrant children died of flu while being detained by CBP: 2-year-old Wilmer Josue Ramirez Vasquez, 8-year-old Felipe Alonzo Gomez, and 16-year-old Carlos Hernandez Vasquez. Carlos’ death was publicized on later-released surveillance footage, which showed him stumbling around his cell, vomiting, and writhing before finally dying face down and alone on the cement floor. The Centers for Disease Control and Prevention,1 professional medical organizations,2 members of the US Senate,3 and concerned physicians … Address correspondence to Bonnie Arzuaga, MD, FAAP, Division of Newborn Medicine, Boston Children’s Hospital, 300 Longwood Ave, Hunnewell 437, Boston, MA 02115. E-mail: bonnie.arzuaga{at}childrens.harvard.edu

Transborder (in)securities: transborder commuters’ perceptions of U.S. Customs and Border Protection policing at the Mexico–U.S. border

ABSTRACT Transborder commuters are a heterogeneous population that includes U.S. citizens, lawful permanent residents, and Mexican nationals who have the legal documentation to cross the Mexico–U.S. border regularly for a variety of reasons. However, in order to engage in transborder mobility, transborder commuters must navigate land ports of entry and undergo extensive scrutiny from U.S. Customs and Border Protection (CBP) officers, who are afforded ample discretion to conduct their day-to-day policing operations. What factors explain the variation in transborder commuter's perceptions of border policing and border crossing experiences? How do negative border crossing experiences impact transborder commuters overall political engagement and feelings of exclusion from U.S. society? Drawing from an original face-to-face survey administered to pedestrian transborder commuters at the Tijuana-San Ysidro and the Ciudad Juarez-El Paso ports of entry, I find that individuals with the highest social status are more likely to report more negative perceptions of border policing practices. Second, individuals who hold the most negative views of their border-crossing experiences become incentivized to become politically engaged, but report feeling greater exclusion from U.S. society.

A Study and Analysis of the Treatment of Mexican Unaccompanied Minors by Customs and Border Protection

Executive Summary The routine human rights abuses and due process violations of unaccompanied alien children (UAC) by US Customs and Border Protection (CBP) have contributed to a mounting humanitarian and legal crisis along the US–Mexico border. In the United States, the treatment of UAC is governed by laws, policies, and standards drawn from the Flores Settlement, the Trafficking Victims Protection Reauthorization Act (TVPRA), and CBP procedures and directives, which are intended to ensure UAC’s protection, well-being, and ability to pursue relief from removal, such as asylum. As nongovernmental organizations and human rights groups have documented, however, CBP has repeatedly violated these legal standards and policies, and subjected UAC to abuses and rights violations. This article draws from surveys of 97 recently deported Mexican UAC, which examine their experiences with US immigration authorities. The study finds that Mexican UAC are detained in subpar conditions, are routinely not screened for fear of return to their home countries or for human trafficking, and are not sufficiently informed about the deportation process. The article recommends that CBP should take immediate steps to improve the treatment of UAC, that CBP and other entities responsible for the care of UAC be monitored to ensure their compliance with US law and policy, and that Mexican UAC be afforded the same procedures and protection under the TVPRA as UAC from noncontiguous states.

Influenza Vaccination and Migration at the US Southern Border

In the past year, at least three children who migrated across the US southern border in the custody of Customs and Border Protection (CBP) died with laboratory-confirmed influenza infection as a contributing factor.1 The first was Felipe, an eight-year-old boy from Guatemala who died in December 2018 upon arrival to the hospital after being diagnosed with influenza B earlier in the day. The second was Wilmer, a two-year-old boy who died in May 2019 after an eight-day admission to the pediatric intensive care unit, where he had tested positive for influenza A. The third was Carlos, a 16-year-old boy who was diagnosed with influenza A in May 2019 at a CBP Centralized Processing Center. He was given oseltamivir and transferred to another detention facility in isolation, where he was found dead in his cell less than 24 hours later. (Am J Public Health. Published online ahead of print February 05, 2020: e1-e2. doi:10.2105/AJPH.2019.305547).

Customs and Border Protection (CBP) Activities Mobilize Hispanic Voters

Do activities by immigration enforcement agencies suppress or mobilize Hispanic voters? To answer this question, we exploit the sharp discontinuity in the legal authority of United States Customs and Border Protection (CBP) at the boundary of the 100-mile interior US border zone. We find that CBP activities increased Hispanic voter registration and turnout in the 2016 US general election by 1.8pp and 1.5pp, respectively. We suggest that the main mechanism is via personal experiences—observing or hearing about CBP activities—as opposed to elite-driven campaigns that are unlikely to be spatially discontinuous. We also estimate the electoral consequences of CBP activities through a simulation exercise and find a small increase in the Democratic Party's representation in the US Congress.

Twenty-Five Years of Reasonable Care Under US Customs Law

It is now more than twenty-five years since ‘reasonable care’ became the ubiquitous benchmark of importer conduct under US customs law. This article explores the impact of the reasonable care standard on US importers since its inception in 1993 as part of the ‘Customs Modernization Act’. The statutory and regulatory basis for reasonable care is examined, as is the evolution of the relationship under reasonable care between US Customs and Border Protection (CBP) and importers. The closely related effects of the companion tenets of reasonable care introduced by CBP – ‘shared responsibility’ and ‘informed compliance’ – are also discussed. This article then examines with specificity recent section 592 caselaw from the US Court of International Trade and the Court of Appeals for the Federal Circuit that has clarified the scope and meaning of reasonable care. Also addressed are troubling developments, separate from but closely tied to reasonable care, concerning the expansion of personal liability under section 592 found in the recently promulgated judicial standard regarding the ‘introduction’ of goods into the United States. Smiszek, Trek Leather, reasonable care, Mod Act, Customs Modernization Act, Section 592, Trade Facilitation and Trade Enforcement Act, first sale valuation, 19 U.S.C. § 1592, 19 C.F.R. § 171

Law enforcement corruption along the U.S. borders

The purpose of the study is to provide an empirical characterization of law enforcement corruption along the U.S. borders. Data were analyzed on 156 criminal cases of officers and agents employed by the U.S. Customs and Border Protection (CBP). Results from the present work advance the understanding of the significantly under-studied topic of border law enforcement corruption in the U.S. context. The majority of the cases were related to organized crime activities. In terms of sex, age, and location, there were significant differences between CBP’s two main workforce components, corrupt customs officers, responsible for customs operations at the country’s official entry points, and border patrol agents, who patrol the border between ports of entry. Both types of employees working along the southern border of the U.S. with very short histories of service were more likely to be involved in drug-related corruption than their senior counterparts who were instead prone to immigration-related corruption.

“If They Notice I’m Mexican”: Narratives of Perceived Discrimination from Individuals Who Crossed the U.S.-Mexico Border at Ports of Entry

ABSTRACT Understanding individuals’ encounters with Customs and Border Protection (CBP), the largest law enforcement agency in the United States, is an important theoretical and policy-relevant issue. Travelers entering the U.S. through ports of entry may generalize their experiences with border officials to local law enforcement, and thus, negative experiences at ports of entry may reduce travelers’ willingness to cooperate with police and report victimization. Existing studies, however, have primarily examined unauthorized border crossings rather than travelers’ port of entry experiences. This study uses grounded theory and qualitative data to explore the perceptions and experiences of 191 young adults who discussed how individuals are treated when crossing the U.S.-Mexico border at land ports of entry. Findings show that participants reported perceptions and experiences of discrimination based on physical appearances, language differences, and nationality. Participants also described border officials engaging in routine law enforcement behaviors, including poor policing practices.

Negative Findings Cultural Resources Survey for the No Name Island Road Improvement Project, Laredo, Texas Laredo Sector, U.S. Customs and Border Protection

Gulf South Research Corporation (GSRC) personnel conducted an intensive archaeological survey of an existing footpath and detached river terrace, referred to as “No Name Island” proposed for vegetation removal on behalf of U.S. Customs and Border Protection (CBP). The project area consists of an approximately 0.25-mile-long dirt footpath, which is proposed to be widened to 16 feet to allow vehicle access (i.e., No Name Access Road), and an approximately 1.12-acre area of detached river terrace (i.e., No Name Island), for which clearing of dense vegetation is proposed. This investigation constitutes CBP’s good faith effort to take into account any adverse effects that may occur as a result of the proposed undertaking in compliance with Section 106 of the National Historic Protection Act (NHPA) (Public Law 89-665; 54 U.S.C. 300101 et seq). The intensive Phase I archaeological investigation included background research of the physical environment, cultural history of the area, previous investigations and previously reported cultural resources, and field survey. Field survey included pedestrian surface inspection supplemented with the excavation of shovel test pits (STPs). Background research revealed eight investigations have been previously conducted, three archaeological sites, and one National Register of Historic Places (NRHP)-listed historic district have been previously recorded within a 0.5-mile radius of the proposed project area. Two of these investigations overlapped with portions of the survey area. None of the previously identified archaeological sites or the NRHP-listed district overlap with either the No Name Access Road or No Name Island survey areas. During field survey, the pedestrian survey encountered no archaeological resources on the ground surface. The subsurface testing consisted of the excavation of four STPs along No Name Access Road within the 0.25 mile long, 60-foot wide project corridor and five STPs within the 1.12 acre No Name Island vegetation removal area. None of the nine STPs were positive for cultural material. As a result of this investigation, no cultural resources were identified within the proposed project area. The proposed project will have no adverse effect on cultural resources and no further work is recommended.