GSA Files Show Feds Used 'Office Relocation' Label to Skip Environmental Review for Gilroy, Calif. ICE Site

Newly obtained FOIA records show the GSA exempted a $26.5 million California facility from environmental impact studies by classifying the disputed detention site as a standard office relocation.

A request for lease proposals the General Services Administration issued in March 2023 for a building outside Gilroy, Calif., set three minimum requirements for the property: contiguous space, a ground-floor location, and a sally port large enough to accommodate a large passenger bus. In December 2024, the agency recorded the same lease on a federal environmental form as an office relocation into an existing building with no change in the general type of use, a determination that exempted the project from any environmental assessment or impact statement.

The lease covers 7240 Holsclaw Road, on unincorporated land in south Santa Clara County, about 11 miles south of an ICE field office in Morgan Hill, Calif. A review of federal contract records shows the agency awarded it in January 2025 to ECG 6 LLC, which shares a Beverly Hills address with Elmwood Capital Group, at a total contract value of $26.5 million for 18,700 rentable square feet over a term of 20 years, 15 of them firm. County property records show Elmwood acquired the Holsclaw Road parcel weeks after the award.

The occupying agency is withheld from the leasing file under a law-enforcement exemption. The agency requirements package attached to the solicitation is a 104-page Immigration and Customs Enforcement cabling standard marked “For Official Use Only,” carrying the seals of ICE and the Department of Homeland Security.

San José Spotlight, which first reported the project in May, later obtained blueprints dated Sept. 17, 2025, that show detention areas, holding rooms and detainee processing at the property.

Project Salt Box today obtained ten pages of GSA leasing, environmental and procurement records through a Freedom of Information Act request submitted in May, providing new details about how the agency evaluated and advanced the project.

Among the records is a GSA Form 4002 signed Dec. 26, 2024, in which the agency claimed an automatic categorical exclusion, the tier of review under the National Environmental Policy Act that requires neither an environmental assessment nor an impact statement. The category the agency selected covers the acquisition of space within an existing structure where there is no change in the general type of use and only minimal change from the previous occupancy level. While the “Agency” field is redacted in the GSA files, a search of federal contracting databases for the project number, “8CA3614,” shows ICE as the primary federal agency behind the project.

The form lists the existing building on Holsclaw Road as 24,000 square feet, built in 1982, within a 1-percent-annual-chance floodplain, the designation formerly called a 100-year floodplain. It records the action as not a critical action, which the form defines as any activity for which even a slight chance of flooding would be too great a risk.

To lease within that floodplain, the agency prepared a Justification for No Practicable Alternatives. A review of the document shows the General Services Administration posted the requirement on the federal contracting site in October 2022, placed it on hold for a lack of agency funds, reposted it in 2024, and received no additional offers; one property met the requirements. A floodplain memorandum approved by the acting Region 9 commissioner of the Public Buildings Service found no practicable alternative to the floodplain and no impact from the lease.

The leasing records also show the environmental determination came after years of procurement activity tied to the same requirement. Documents state GSA first posted the solicitation in 2022 under the Biden administration, suspended it because of a lack of agency funding, and later reposted it after funds became available. In a separate floodplain justification, the agency said it reviewed commercial listings, advertised the requirement twice and concluded that only one property satisfied the government's specifications.

San José Spotlight has reported that the procurement began in 2020, under the first Trump administration, as a search for detention space and continued through the Biden administration under a solicitation that shares the current contract's identification number. GSA documents show the agency posted the requirement publicly in 2022, suspended it for a lack of funding, reposted it in 2024 and awarded the lease in January 2025.

A review of the leasing file shows the tenant-improvement allowance was $61.22 per occupiable square foot, about $1.04 million, with a separate security allowance of $204,000. The solicitation disclosed that the government anticipated the buildout would exceed that allowance by roughly $182 per square foot, an overage of about $3.1 million before relocation costs. The same documents set the facility’s security level at II — a standard security level comparable with other federal law enforcement offices — on a four-level federal scale and listed a further package of agency requirements “containing sensitive information,” available only to bidders who requested it from the contracting officer.

California and Santa Clara County sued the federal government on June 10 in the U.S. District Court for the Northern District of California, seeking to block construction on the grounds that the lease and the work underway are a major federal action that required an environmental assessment or impact statement the government never produced. The complaint also cites the Immigration and Nationality Act, California’s Williamson Act and federal consultation requirements, and describes the site as likely to become an Enforcement and Removal Operations office, a category designed for administrative use and short-term holding. Santa Cruz County has joined the suit, and Monterey County and the Gilroy City Council have passed measures opposing the project.

A spokesperson for the Department of Homeland Security told San José Spotlight in May: “We have no new detention centers to announce at this time.”