A draft environmental review the Department of Homeland Security released Monday found that converting a warehouse in Surprise, Ariz., into a 1,500-bed immigration detention center would cause no significant environmental harm. The company hired to run the facility managed the review.
The draft environmental assessment says consultants under contract to GardaWorld Federal Services prepared the review and its supporting documents. GardaWorld’s project manager is listed as the review’s project manager and as a technical reviewer. Immigration and Customs Enforcement hired GardaWorld under a $313 million contract to convert the warehouse at 13290 W. Sweetwater Ave., and the company is set to operate the facility.
DHS also released a draft mitigated finding of no significant impact, the document that would let ICE move ahead without a more detailed environmental impact statement. Its only binding conditions concern water. The public has 30 days to comment on both documents, which Project Salt Box has posted on DocumentCloud.
A second private firm also had a hand in the review. A project manager from Rudiarius LLC is listed as a technical reviewer. Rudiarius paid for an environmental review of ICE’s warehouse in Roxbury, N.J., and is a partner in a joint venture with SK2 LLC, the firm that brokered ICE’s warehouse purchases, Project Salt Box has reported. Three government employees, two from DHS and one from ICE, are listed as reviewers.
DHS’s own NEPA manual allows contractors to draft environmental documents but calls NEPA decision-making “an inherently governmental function.” Only a DHS employee may sign the final documents. The manual does not address whether a contractor with a financial stake in a project may prepare its review.
The review is the product of a court agreement. Arizona sued DHS and ICE in April, arguing the agencies were converting the warehouse without the review required under the National Environmental Policy Act. In late June, the state and the agencies asked a federal judge to pause the case while ICE completed an environmental assessment. Under the order the judge entered in July, ICE may not hold anyone at the site or physically convert it until the assessment is final.
Justice Department lawyers told the court on Nov. 5, that ICE’s contractor had prepared a draft assessment and that ICE was reviewing it. “No final EA or associated agency decision document has been issued,” they wrote.
A spokesman for Arizona Attorney General Kris Mayes told 12News on Monday that the office was still reviewing the assessment and had no comment.
Do you know more? If you work for DHS or a contractor and have information about the Surprise facility, ICE’s environmental reviews, or its warehouse program, Project Salt Box wants to hear from you. Email projectsaltbox@proton.me or reach Michael Wriston on Signal at mwriston.410.
Water is the largest effect
The facility would use about 190,000 gallons of water on an average day and about 215,000 at its peak, the draft says. The city of Surprise plans for a maximum of 380,000 gallons a day, three times what the building was designed to use. To meet that demand, the city would build a new well about five years ahead of schedule and expand a planned treatment system that removes arsenic from groundwater.
Under a city ordinance for large water users, the facility would also have to supply 15 years’ worth of water rights, about 1,512 acre-feet, before it could receive service. Chris Judd, a Surprise City Council member, told ABC15 in October that the facility would use “two to three times more than our highest current water user.”
The facility would owe the city about $8.9 million before it could open, according to a Sept. 22 city memo to GardaWorld. That includes $6.1 million for a new well, about $921,000 for more water treatment, about $840,000 for wastewater treatment, and about $1.1 million for water rights. The company could hand over the water rights instead of paying for them. Development impact fees would come on top of the total.
All five binding conditions in the draft finding come from the city memo. ICE would keep its own records showing it met them and would share them with DHS reviewers “upon request.” DHS’s environmental manual says agencies must monitor whether such measures work.
Neighbors, schools, and air
The warehouse sits across West Sweetwater Avenue from Rinchem, a chemical company that files a risk management plan with the Environmental Protection Agency, according to the draft assessment. Federal law requires those plans from facilities that use the substances posing the greatest risk in an accidental release, the draft says. It reports no violations or releases at Rinchem and says the facility would likely shelter detainees in place during a chemical emergency because of its closed-loop air system.
The draft says the facility would run around the clock with 676 staff members across three shifts and about 25 detainee transport vehicles coming and going each day. It says the 3 p.m. shift change would overlap with dismissal at nearby Dysart High School and Dysart Middle School. The draft also says a peak-hour traffic analysis “cannot be calculated from currently available information” because city traffic counts do not cover the route.
Maricopa County does not meet federal air quality standards for ozone and airborne dust, the draft notes. Its air analysis looks at the facility’s 12 backup generators, which the draft calls the only stationary source of emissions, and finds the effect would be insignificant. The draft does not mention a Clean Air Act conformity review. DHS’s NEPA manual lists conformity with a state’s air quality plan among the environmental requirements its reviewers must weigh.
The draft does not include a separate analysis of cumulative effects. Instead, citing the Supreme Court’s 2025 ruling in Seven County Infrastructure Coalition v. Eagle County, it says it weighs reasonably foreseeable effects within each resource section. However, the draft finding of no significant impact says the Department of Homeland Security considered “cumulative impacts” in reaching its conclusion.
What happens next?
The draft says renovation would take about 30 days once approved. Comments on the draft assessment and draft finding are due Dec. 9, and can be submitted via email through the DHS public comment page.
After ICE delivers a final assessment, the court order gives Arizona 10 days to decide whether to renew its request to block the project. If it does, ICE must wait at least 21 more days before starting conversion work, unless a judge rules otherwise.