Open Letter To ADOT On Proposed Avra Valley I-11

I write in opposition to the proposed I-11 corridors through the Avra Valley in Arizona. Although I now reside in Columbus, Ohio, from 1998 to 2010 my wife and I lived adjacent to the C.A.P. Canal near the North Sandario Road/West Mile Wide Road intersection. During that time, I became familiar with the area and the problems posed by development throughout the Valley. I am particularly familiar with the area from the Tucson Mitigation Corridor south of our neighborhood to the Picture Rocks community to the north, but many of my comments apply to the Avra Valley as a whole. My comments fall into five categories:

  1. Environmental justice.
  2. Cumulative impacts.
  3. Potential for environmental pollution.
  4. Impact on wildlife
  5. Degradation of Saguaro National Park and other resources.

Environmental Justice

From its junction with Ajo Way (Arizona 86) in the south to West Marana Road in the north, Sandario Road provides access to several residential communities. Although there are pockets of relative affluence, for the most part these are low-income communities. Mobile homes are more prevalent than site-built homes, and valuations are considerably lower than average. The area is poorly served by public transportation. The Picture Rocks community, centered on the intersection of North Sandario Road and West Picture Rocks Road, is the highest density area, but even so residential lots are large and the community is spread out. This area has a strong sense of community, with its own community center, schools, and fire department.

Although the poor quality of the corridor maps available on the internet makes a judgment difficult, it seems clear that either of the alternatives through this part of the Avra Valley would have a devastating effect. In the area of Sandario Road from San Joaquin Road to West Mile Wide Road it seems inevitable that a significant number of residences will simply be obliterated by highway construction and the livability of others reduced by noise and air pollution. Areas further to the north are more difficult to judge because of the lack of named streets on the maps, but it seems highly likely that significant parts of the Picture Rocks community will be adversely affected. Homes will be separated from schools, previously quiet neighborhoods will be subject to traffic noises, and air quality will be degraded by diesel exhaust. These impacts will disproportionately and unfairly affect the lives of those whose voices are typically ignored by highway advocates, who never propose highways through affluent communities and for whom the poor are nearly invisible.

Proposed corridors through the Avra Valley do not meet standards of environmental justice.

Cumulative Impacts

The Avra Valley has been impacted by development for many years. Much of the area has been farmed extensively, with ongoing activity in the northern and southern portions. In the central portion, previously farmed land has been acquired by Tucson Water to protect the valley aquifer and to support its banking of Central Arizona Project water both north and south  of the Garcia Strip portion of the Tohono O’Odham Nation, which extends from west to east across the valley up to Sandario Road. Water is banked via several large ponds on the surface, from which CAP water infuses into the underlying aquifer. These ponds are visible from any elevated portion of Saguaro National Park and Tucson Mountain Park. The Central Arizona Project canal itself traverses the valley from north to south, with a power line and service roads along the full length of the canal. Likewise, these are visible from the parks. As previously noted, large-lot residential communities exist at several locations in the valley. Sandario Road is not only an important highway serving residential, commercial, and emergency responders, but a major thoroughfare for drug trafficking.

In short, the Avra Valley has suffered a series of environmental insults that have reduced its serenity and visual appeal, but it has somehow managed to retain something of its former beauty and sense of isolation from the nearby metropolis. The construction of a highway through this area will be the last environmental straw, not only bringing more insults by way of air and visual pollution, but by opening the valley to forms of development it has not previously seen. It is obvious from the history of the Interstate Highway System in the United States that development follows the construction of highways. Ironically, we build more highways to alleviate congestion in existing roads, only to foster more development, more sprawl, and even more congested traffic. The proposed I-11 through Avra Valley will constitute an environmental tipping point from which there will be no recovery. It will destroy the valley as we now know it.

The proposed corridors through Avra Valley should be eliminated because of their cumulative negative impact on the environment.

Potential for Environmental Pollution

In addition to the likelihood discussed above that the proposed highway will negatively affect air quality in the valley, there is a distinct danger of surface and ground water pollution as well. Trucks carry many things, including dangerous chemicals, petroleum products, and gasses. And trucks have accidents – whether due to poor maintenance, negligence, reckless or careless driving, or drug and alcohol use. Trucks that have accidents frequently spill their contents onto the highway and surrounding land. Sooner or later there will be such accidents on the proposed highway.

Although it is, again, difficult to judge their routes precisely, it is evident that the proposed highway corridor will pass near and more likely over, Tucson Water properties in Avra Valley. Thus, the potential exists for spills that find their way into the aquifer on which Tucsonans depend for their drinking water. Moreover, the Brawley Wash traverses the valley from south to north, ending at the Santa Cruz River. Hence, a spill that occurs in one location could, if rainfall causes the wash to run, be easily carried downstream from one place to another. There can be no justification for selecting a highway route that jeopardizes the water supply of a large metropolitan area, particularly when the alternative is to return to mining water underneath Tucson itself, a practice that lowered the water table drastically and contributed to significant subsidence.

On the grounds of danger to water supplies alone the proposed corridors through the Avra Valley should be eliminated from further consideration.

Impact on Wildlife

When the Central Arizona Project was constructed, the Bureau of Reclamation undertook several mitigation efforts to make sure that the CAP canal did not interfere with the movement of wildlife across the Avra Valley between the Tucson Mountains on the east and various ranges to the west. In addition to providing land bridges that enabled bighorn sheep, deer, javalina, mountain lions, and other wildlife to move back and forth across the canal, the Bureau was required to acquire a 4.25 square-mile tract of land extending from the Tucson Mountain Park in the east to Sandario Road in the west. This Tucson Mitigation Corridor is subject to an agreement between Pima County, Arizona Game and Fish, and the Bureau of Reclamation that it will be subject to no further development that does not contribute to the purpose for which the Corridor was created.

Clearly an interstate highway through this area will impact the movement of wildlife; it will do so even if mitigation efforts create underpasses to permit wildlife passage. The noise, light pollution, and smells of large trucks moving at high speed will probably degrade the entire area and make it less hospitable for wildlife.

Moreover, the corridors proposed follow Sandario Road through an area that is too narrow for the passage of an interstate highway. Sandario Road, for two miles, separates the Tucson Mitigation Corridor to the east and the Garcia Strip portion of the Tohono O’odham reservation. The highway corridor does not have sufficient width to contain a 400-foot-wideinterstate highway right of way. Unless the Tohono grant permission to build on the Garcia Strip, or the Bureau of Reclamation violates its agreement with respect to the Tucson Mitigation Corridor, the highway cannot be built. Neither of these developments seems likely.

The proposed corridors through the Avra Valley, and particularly near the Tucson Mitigation Corridor, will defeat the purposes for which the Corridor was instituted and further degrade the wildlife-supporting capacity of the area, and for this reason should be eliminated from further consideration.

Degradation of Saguaro National Park and other Resources

Tourism is a significant part of the economy of Tucson and Pima County, and Saguaro National Park, Tucson Mountain Park, and the Arizona-Sonora Desert Museum are key attractions for people visiting the area. The museum, along with numerous hiking trails in the parks; provide important recreational opportunities, as well as viewpoints from which one may view an iconic basin-range landscape extending as far as Kitt Peak to the west. Although existing development somewhat impacts views, the addition of an interstate highway in the valley will significantly degrade the view shed.

Kitt Peak is also an important consideration. The site of important astronomical observatories, Kitt Peak already labors under the threat of light pollution from residential and commercial development in the valley. An interstate highway will directly and indirectly worsen the situation. Direct impacts are likely because traffic and the lighting associated with freeway interchanges will immediately make the skies less dark. Indirectly, a highway through the valley will encourage further commercial and residential development and hence also create undesirable lighting. Pima County has an enlightened set of zoning regulations designed to foster “dark skies,” but there are limits to the extent to which lighting can be reduced by such means

Finally, Saguaro National Park is of national and not merely local importance. Environmental impact studies often look only to local interests and concerns as they examine the potential impacts of proposals such as highway or power line construction. But a thriving Saguaro National Park, with abundant wildlife, typical native vegetation such as the saguaro cactus, and iconic views, is as valuable to a resident of Columbus, Ohio as it is to those who live in Tucson, the Avra Valley, or elsewhere in Pima County. Saguaro National Park is a national treasure. Astronomical research at Kitt Peak is of interest to a national scientific community. A designated wilderness area and wildlife free to move within a viable ecosystem so close to a major metropolitan area are matters of interest and concern to all citizens of the United States.

The proposed corridors through Avra Valley will degrade the visitor experience at the West Unit of Saguaro National Park, Tucson Mountain Park, and the Desert Museum, and thus negatively affect a significant national resource.


For the reasons outlined above, I believe that all proposed corridors for Interstate 11 that pass through the Avra Valley should be removed from further consideration. In addition, because I believe that the need for an Interstate 11 project from the Mexican border to Phoenix has not been demonstrated, I favor the “no build” alternative. If subsequent experience should indicate the need for greater highway transportation capacity, the existing Interstates 19 and 10 can be expanded and improved along their current rights of way sufficiently to meet such need. The future of the transportation of goods over long distances lies in the improvement of rail services. Likewise, the movement of people between cities as close as Tucson, Phoenix, and Las Vegas should increasingly depend upon high-speed passenger rail, which is more energy efficient than automobiles and airplanes and fully competitive with airplanes in terms of time consumed in travel.

John Hewitt

John Hewitt, a former Barrio Sapo resident, was one of the first to oppose an Avra Valley I-11, 10 years ago when it was the I-10 Bypass. Hewitt has served on Pima County’s Planning and Zoning Commission.

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Under the leadership of Editor in Chief Huey Freeman, the Editorial Board of the Arizona Daily Independent offers readers an opportunity to comments on current events and the pressing issues of the day. Occasionally, the Board weighs-in on issues of concern for the residents of Arizona and the US.