Interstate 11 In Southern Arizona: ADOT Versus Almost Everybody

From The Avra Valley Coalition,

While pursuing stories on the Arizona Department of Transportation’s current series of public meetings with their “reasonable range of alternative” Interstate 11 routes, members of the Media should be interested in what directly affected agencies and jurisdictions had to say less than a year ago when the Tier 1 Environmental Impact Process began.  Below are direct quotes from named sources, and are also available at  APPENDIX D Agency Scoping Comments- ADOT.

Public comments from 2016 can also be accessed, and you will see that they were overwhelmingly opposed to I-11 or I-11 through the Avra Valley.  That opposition continues as hundreds packed the Marana and Tucson ADOT meetings to express thier point-of-view.

ADOT”s I-11 planners are trying to ignore the public’s views, even refusing to answer questions from the public.

The Pima County Board of Supervisors Resolution 2007-343 is included as it remains official County policy; that, of course, raises the question of how the County Administrator can blatantly flout that policy, which Supervisor Bronson said during the election campaign remains the BOS position.

CITY OF TUCSON: The City requests that the Tier 1 EIS consider innovative approaches to alternatives that locate I-11 approximately within the existing rights-of-way for I-10 and I-19 (including frontage roads).

Developing the interstate within already disturbed areas has the potential to have fewer impacts to natural resources, lower costs, easier access to I-10 east for both freight and passenger traveling, and shorter routes to already developed freight hubs along I-10 and I-19….For roadway alternatives that skirt or bypass the majority of the Tucson metro area, there are pros and cons to consider.

Potential negative impacts to the City include loss of sales tax revenue from frontage hotels, restaurants and gas stations that cater to the trucking industry….  Additionally, there could be substantial loss of revenue from domestic and Mexican visitors who would then have an option to bypass the City of Tucson….  Also, roadway alternatives that pass through undeveloped or rural areas would have the potential to affect tourism, a large portion of which is driven by the region’s unique natural assets….  Any alternatives that are studied that traverse the Avra Valley will need to consider impacts to City-owned (Tucson Water) water facilities in the area.

Michael J. Ortega, City Manager          July 8, 2016

PIMA COUNTY (1):  Now, Therefore Be It Resolved that the Pima County Board of Supervisors opposes the construction of any new highways in or around the County that have the stated purpose of bypassing the existing Interstate 10 as it is believed that the environmental, historic, archaeological and urban form impacts could not be adequately mitigated. 

 — Board Of Supervisors Resolution 2007-343, Dec. 18, 2007

PIMA COUNTY (2): Pima County in 2013 developed a conceptual route for the I-11 Corridor through Avra Valley west of Tucson….  In developing this route we sought to demonstrate that a potential route exists through this undeveloped region rather than employing the existing I-19 and I-10 corridors which are congested and have limited expansion potential, especially near downtown Tucson.

Chuck Huckelberry

County Administrator              June 7, 2016

TOWN OF MARANA: Marana in essence only favors a western bypass alignment near our jurisdiction.

Jamsheed Mehta, Deputy Town Manager     July 5, 2016

ARIZONA GAME AND FISH:  In 2007, the Arizona Game and Fish Commission took a unanimous position of opposition to all routes for the proposed I-10 bypass, which included a route through the Avra Valley, as does theI-11 Tier 1 EIS Study Corridor. The Department now reiterates what we included in a December 18, 2008 letter to the ADOT Director: “The cumulative impact of developing new transportation infrastructure through rural lands will have the effect of a catalyst for urban, suburban, and exurban development. The Department does not find the I-10 bypass [which in part covered the same area of the proposed I-11 Study Corridor through the Avra Valley] to be consistent with smart growth and sustainable planning principles. The vastness of Arizona’s undeveloped country, and its wildlife resources, must be recognized as one of our greatest assets for current and future generations.”

As previously stated, the Department considers an Interstate/Multi-Modal corridor to be incompatible with a county, state, or federal park/recreation area. Within the Avra Valley west of Tucson, several such specially designated lands occur: Saguaro National Park, Ironwood Forest National Monument, Tucson Mountain Park/Tucson Mountain Wildlife Area, and the Tucson Mitigation Corridor. These designations demonstrate the significance of these lands to county, state, and federal officials, as well as the public at large, for recreation and wildlife habitat. The considerable public investment in these lands would be irreparably devalued by siting an Interstate/Multi-Modal corridor west of Tucson within the Tier 1 EIS Study Corridor.

Joyce Francis, PhD

Habitat, Evaluation, and Lands Branch Chief

Arizona Game and Fish Department

July 8, 2016

U.S. BUREAU OF LAND MANAGEMENT:   The BLM Tucson Field Office has significant concerns about potential overlap or adjacency of the I-11 Study Corridor with the eastern boundary of the 129,000-acre Ironwood Forest National Monument….  The BLM encourages avoidance of designated wildlife movement corridors and wildlife habitat management areas.

Rebecca Heick, Deputy State Director

Lands, Minerals & Energy       July 13, 2016

NATIONAL PARK SERVICE:  The NPS is concerned that a multi-purpose corridor of this scale bisecting the Avra Valley would irreparably degrade areas near and with (Saguaro National Park), potentially to impairment of the resource values which the park was established to protect for future generations….  Fragmenting features, such as large road systems, can essentially deny (wildlife) access to habitat and resources by severing movement corridors between and within required habitat.  The Park’s west district in recent years has lost bighorn sheep and Mexican wolves….  Additional concerns for the NPS include resources that would be impacted by a large-scale corridor development project such as this, including wilderness values, air quality values, viewsheds, night skies, noise, vegetation management and visitor use.

Melissa R. Trenchik

Environmental Quality Chief   July 11, 2016

U.S. BUREAU OF RECLAMATION: Tucson Mitigation Corridor –The 2,514-acre Tucson Mitigation Corridor was established in 1990 for approximately $4.4 million. The purchase and protection of these lands was a commitment made by Reclamation with the U.S. Fish and Wildlife Service (FWS) and the Arizona Game and Fish Department (AGFD) in the EIS for the Tucson Aqueduct. The Secretary of the Interior, Ms. Sally Jewell, signed a cooperative agreement to manage the property in accordance with the Master Management Plan, which prohibits any future development within the area other than existing wildlife habitat improvements or developments agreed to by Reclamation, AGFD, and FWS. This prohibition is intended to preserve habitat from urbanization while maintaining an open wildlife movement corridor. The property is also protected under Section 4(f of the Department of Transportation Act of 1966, because it was “acquired for mitigation purposes pursuant to the authority of the Fish and Wildlife Coordination Act, including general plan lands under Section 3þ) of that act (DOï2014)….  In order to maintain a functional wildlife movement corridor, Reclamation installed a series of seven Central Arizona Project (CAP) canal siphons for approximately $3 million, which are concrete pipe sections that travel underneath desert washes. Wildlife frequently use desert washes as a means of migrating from one area to another. In March 2016, two desert bighorn sheep (Ovis canadensis nelsoni) were observed using one of the siphon crossings within the Tucson Mitigation Corridor to migrate from the Ironwood National Monument to the Tucson Mountain District of Saguaro National Park. The construction of an I-11 travel corridor, either through the Tucson Mitigation Corridor or elsewhere within Avra Valley would have acted as a barrier that would have either severely restricted or prohibited their movement while also fragmenting habitat.

Sean Heath,  Chief, Environmental Resource

Management Division              July 8, 2016

ENVIRONMENTAL PROTECTION AGENCY:  EPA recommends that FHWA continue to study the use of these existing corridors wherever possible in order to reduce the many environmental impacts that occur through construction of new linear transportation facilities.  We believe that utilizing existing transportation corridors will provide the greatest benefit to existing communities while also minimizing environmental impacts from further growth-inducement and habitat fragmentation.

Clifton Meek

Environmental Review Section      July 6, 2016


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About Albert Vetere Lannon 106 Articles
Albert grew up in the slums of New York, and moved to San Francisco when he was 21. He became a union official and labor educator after obtaining his high school GED in 1989 and earning three degrees at San Francisco State University – BA, Labor Studies; BA, Interdisciplinary Creative Arts; MA, History. He has published two books of history, Second String Red, a scholarly biography of my communist father (Lexington, 1999), and Fight or Be Slaves, a history of the Oakland-East Bay labor movement (University Press of America, 2000). Albert has published stories, poetry, essays and reviews in a variety of “little” magazines over the years. Albert retired to Tucson in 2001. He has won awards from the Arizona State Poetry Society and Society of Southwestern Authors.