Pima County Challenged Over ‘Adverse Effects’ Of I-11 On Avra Valley Residents

fCiting the Pima County Regulatory Bill of Rights, Avra Valley resident and retired activist Albert Lannon filed a formal complaint with the Board of Supervisors at their January 2 meeting alleging that County Administrator Charles Huckelberry and his staff “for at least five years have ignored, violated, mis- and re-interpreted BOS Resolution 2007-343, making new county policy not adopted by this board, without notice or public discussion, in favor of an Avra Valley route for a proposed Interstate 11.”

BOS Resolution 2007-343 expressly “opposes the construction of any new highways in or around the county that have the stated purpose by bypassing the existing Interstate 10 as it is believed that the environmental, historic, archaeological, and urban form impacts could not be adequately mitigated.”  The resolution specifically discusses the Avra Valley as worthy of protection.

 Albert Lannon Presentation of Complaint During the Call to the Audience

The county administrator’s actions, Lannon claims, “adversely affects” him and thousands of neighbors by mis-using their tax dollars in support of an I-11 route that will bring “air, noise and light pollution, wildlife disruption, and loss of tourist revenues to be made up from our tax dollars.  Losing the present peaceful enjoyment of Saguaro National Park, Tucson Mountain Park, the Desert Museum, Kitt Peak and Ironwood Forest National Monument will adversely affect me.”

As a result of the county administrator’s violation of official county policy, he charged, an Avra Valley I-11 route is one of only two alternatives now being considered by the Arizona Department of Transportation’s I-11 Tier One Environmental Impact Study Team.  A “recommended alternative” – either the Avra Valley route or the existing I-10 corridor – is expected to be named by ADOT this summer.

Further, Lannon charged that the Sonoran Corridor, originally labeled as part of I-11 on county maps published by Huckelberry’s office, “adversely affects me by telling me that my vote in the bond election means nothing so why bother to vote?”  The Sonoran Corridor, along with other bond proposals, was rejected by voters in 2015.

Lannon noted that the county administrator’s proposed route connecting I-10 and I-19 is “convoluted to give a planned Diamond Ventures development a free access highway in violation of Pima County Personnel Rules of Conduct.  That also adversely affects me by mis-spending my tax dollars as well as demonstrating that the rule of law does not apply to the county administrator’s office.”

He pointed out that about 90 percent of over 3000 public comments this past summer to ADOT’s Environmental Impact Study opposed any Avra Valley I-11, with only about one-half of one percent favoring it.

Lannon’s 10-page formal complaint, including citations and evidence, was handed to the Clerk of the Board to distribute to all on the dais.  Under the Regulatory Bill of Rights, they have 15 business days to respond.

The formal complaint also asks that Supervisor Steve Christy recuse himself from any deliberations as he chaired the State Transportation Board when the $15 million, three-year I-11 EIS was approved and is on record expressing animosity towards Avra Valley residents, referring to them as “anti-highway builders” in an email to the county administrator’s staff.  The email was obtained by the Arizona Daily Independent as part of a public records request.

Neither the supervisors nor the county administrator had any immediate comment.

The Complaint reads:


Please consider this a formal Complaint, pursuant to the Pima County Regulatory Bill of Rights, “To establish complaint receipt procedures for use by individuals adversely affected by ordinances, rules, substantive policy statements, or county or flood control district practices alleged to violate ARS 11-251.18 (pursuant to) the Arizona Revised Statutes (Regulatory Bill of Rights).”  As ARS 48-3609.02 notes,”rule” means a district statement of general applicability that implements, interprets or prescribes law or policy, or describes the procedure or practice requirements of a district.”

As provided in Pima County Board of Supervisors Policy C 2.8, adopted November 17, 2015, A. Complaints: “Individuals alleging that they have been adversely affected by a county or flood control district ordinance, rule, substantive policy statement or practice in violation of the applicable Regulatory Bill of Rights may submit a written complaint to the relevant department Director or their designee. The written complaint must contain the name and address of the adversely affected person making the complaint, reference to the specific ordinance, rule, regulation, substantive policy statement or practice alleged to violate the Regulatory Bill of Rights together with the factual and legal basis for the complaint. The department Director or designee will have fifteen business days following receipt of the complaint to review the complaint and respond to the complainant.”

Since the Complaint is against the County Administrator’s office and Charles Huckelberry, hired by the Board of Supervisors of which you are the Chair, you are the equivalent of the appropriate “department Director” to whom this is addressed.   It is BOS policy that the County Administrator is violating, creating a new policy contrary to the one adopted by yourselves, creating adversity for myself and thousands of taxpayer residents of the Avra Valley, who are also your constituents.

As provided in County Code 2.04.010,

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“The board of supervisors is the governing body of the county. The powers, duties and responsibilities of the board of supervisors are established in the Constitution of the state of Arizona and the Arizona Revised Statutes, Title 11, Chapter 2. Certain administrative and executive powers and duties of the board may be delegated to other persons or bodies; however, the board has ultimate responsibility for the affairs of the county.”  (All emphases added.)

As provided in 2.12.070,

  • The county administrator shall report to the board of supervisors of Pima County, and under the direction of the board of supervisors the county administrator shall be responsible for the general direction, supervision, administration, and coordination of all affairs of the county (including county administrator’s office), except those duties exercised by the other elected of ficials of the county.
  • Subject only to policies adopted or directions given by official actions of the board, the county administrator shall be responsible for the general supervision, direction, administration and coordination of all the affairs of the county except those conducted by the other elected officials of the county.

Further, Pima County Personnel Policy Rules of Conduct, adopted April 19, 2016, forbids employees of Pima County to “Directly or indirectly use or allow the use of County property of any kind, including property leased by the County, for other than official or assigned duties.

As an adversely affected resident and taxpayer of Pima County, I make the following Complaint:

Since at least 2013 the County Administrator has been actively pursuing, advertising, and promoting an Avra Valley route for a proposed Interstate 11 in blatant violation of BOS Policy, as expressed in Resolution 2007-343 (copy attached).  He has used copious County resources and personnel in his continuing deliberate reinterpretation of BOS Policy, including the publication of maps (attached).  He has spoken for the County in the current Arizona Department of Transportation Interstate 11 Tier 1 Environmental Impact Study (attached) creating the impression that Pima County favors an Avra Valley route for I-11, despite the clear language of BOS 2007-343, and Supervisor Bronson’s statement to a Picture Rocks community meeting prior to the last election that the BOS opposes an Avra Valley I-11 route consistent with BOS 2007-343.

As a result the current ADOT study continues to show an Avra Valley I-11 route as one of only two possible “recommended alternatives” despite overwhelming community opposition.  Adverse effects of the County Administrator/ADOT’s proposed I-11 Avra Valley route include the displacement of 47 families, noise and air pollution, light pollution, infringement on protected land such as the Tucson Wildlife Mitigation Corridor established when the CAP canal was constructed to facilitate wildlife movement, and diminishing of current recreational facilities.

Loss of tourism dollars may well lead to increased property taxes to make up the difference, which adversely affects me, a fixed-income senior.  The misuse of my tax dollars on this issue over the past five years affects me adversely.

The impact of an Avra Valley interstate highway nearby would adversely affect me and many others by denying us the enjoyment we now have of Saguaro National Park West, Tucson Mountain Park, the Arizona-Sonora Desert Museum, Ironwood National Monument and Kitt Peak Observatory.  I, and my neighbors, would be subject to the dangers of hazardous cargo, human and drug smuggling in our communities.  Those, like myself, who have medical conditions like Chronic Obstructive Pulmonary Disease would be put at increased physical risk from increased air pollution, an adverse situation.  I, and others, would adversely face decreased property values with a freeway nearby.

I would note that various affected communities have spoken out in opposition to an Avra Valley I-11, including Citizens for Picture Rocks  and the San Xavier and Schuk Toak Districts of the Tohono O’odham Nation.

The Pima Natural Resources Conservation District points out yet another adverse effect impacting me:

“Pima County voters approved an open space bond, and the Sonoran Desert Conservation Plan. The citizens did this knowing that their taxes would be significantly higher because of it, and the proposed CANAMEX (I-11) section through Avra Valley violates the values of the Pima County residents. It is incompatible both ecologically and from a quality of life perspective, with a rural setting. In addition, rural lands that had been eligible for zoning changes may no longer qualify.”

Further, the County Administrator continues to champion a bypass renamed “auxiliary interstate,” the Sonoran Corridor, that affects me adversely.  The Sonoran Corridor was rejected by voters in the 2015 bond election.  Continuing to promote the Sonoran Corridor forces me, and others, to wonder why we should bother voting if the results are going to be ignored.  Discouraging voters from voting affects us all adversely as does spending our tax dollars on a plan rejected by the voters.

Setting aside public policy issues like taxpayers donating to corporations posting billion-dollar profits, there s a case to be made for connecting I-10 and I-19 with a relatively straight east-west line.  The County Administrator’s Sonoran Corridor bypass, however, drops south to give Diamond Ventures, a private for-profit business, a free access highway for their planned Swan Southlands development at the expense of County taxpayers, including myself, another adverse effect.

That appears to be a significant breach of County Policy which states:  “All employees of Pima County shall maintain the highest ethical standards in the conduct of County business and avoid circumstances that may create an appearance of impropriety or cause members of the public to have a negative opinion of the County.”  And a breach of  the Pima County Personnel Policies Rules of Conduct which do not allow employees to  “Give preferential treatment to any private organization or individual.” 

 Research shows that some 1500 acres of Mr. Huckelberry’s Avra Valley I-11 route are owned by companies belonging to the family of the late Wilford Cardon, who was alive when the route was promulgated.  Mr. Cardon’s last failed political campaign had prominent support from Don Diamond.

For all of the above reasons I, and so many others, have been adversely affected by the County Administrator’s office and their reinterpretation of BOS 2007-343 without required notice, public discussion or a vote of the Board of Supervisors.  One remedy could be the BOS publically rebuking the County Administrator and his minions and restating publically, and to the ADOT Study Team, Pima County’s opposition to any new interstate in the County as contrary to BOS 2007-343.

I understand that willful violation of County policy – gross insubordination — and misuse of County resources by the person hired to carry out that policy may call for more drastic personnel action and that is generally done in executive session.

I would also ask that, in any discussion of this matter by the BOS, that Supervisor Steve Christy recuse himself.  As Chair of the State Transportation Board Mr. Christy approved the $15 million I-11 Study now in progress, and has mis-characterized myself and other Avra Valley residents as “anti-highway builders” who get “stirred up” (see attachment).  His bias is self-evident.


Albert V. Lannon


  • Members, Board of Supervisors
  • Clerk of the Board
  • County Attorney
  • Charles  Huckelberry


While the County Administrator is very careful with his words, his misrepresentations of County policy clearly establish the violation of BOS 2007-343 which affects my neighbors and I adversely.  Note that he speaks for the County despite his violation of BOS 2007-343.  Here are some of his statements from the ADOT record:

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”

Source: Pima County

Note that the “Sonoran Corridor” was originally named part of I-11 on County maps.

In 2013- 14, after unveiling his proposed Avra Valley I-11 route, the County Administrator was quoted in the media saying “The concept of Interstate 11 should be from Canada to Guaymas…we cannot be left out of this.”  He wrote in Desert Times newspaper and Picture Rocks Digest, “That (I-11) corridor needs to extend to Mexico and it is critical we remain engaged in that discussion…The proposed (Avra Valley) route is a starting point…As a transportation engineer I am the last person who will try to convince you that a new highway would have no impacts on the surrounding area….”  I note also that in the above letter he justifies elevating a portion of I-11 “to facilitate wildlife corridors…”  The fact is there is an insufficient right-of-way in at least one section of his proposed I-11 route.  Earlier the County Administrator had publically denigrated elevated highways because they “might fall down in an earthquake, like in San Francisco.”

From The Arizona Daily Independent, July 25, 2016:

Re:  emails from Steve Christy to the office of the County Administrator:

On March 26, 2014, then-STB (State Transportation Board) Chair, and now candidate for Pima County Supervisor, Steve Christy wrote to county staff and others:

“The greatest risk of conducting (a study being considered) is that it will prematurely and unnecessarily stir up all the anti-highway builders, especially in Avra Valley who will get stirred up enough anyway once the EIS is underway giving them more time and reason to activate and hone their skills….”

Christy’s email list included County Strategic Planning Officer John Moffatt, Deputy County Administrator John Bernal, County Dept. of Transportation Director Priscilla Cornelio, and staff of the Southern Arizona Leadership Council and Pima Association of Governments.  The email also indicated that the I-11 promoters had some differences with the Arizona Dept. of Transportation (ADOT).

The message went to Pima County Administrator Chuck Huckelberry two minutes after Moffatt received it.

(Note:  Steve Christy’s last meeting as STB Chair approved the $15 million Tier 1 EIS for Interstate 11, suspending financing for several just-approved road projects to generate the money.)


More from the ADI story:  While trying to position the Sonoran Corridor prior to the bond election, real estate banker, auto dealer  and former STB chair Steve Christy complained on March 17, 2015, to Huckelberry, Moffatt, Cornelio, and SALC vice-president Ted Maxwell that ADOT might label the highway as a “planning route” instead of a designated State Route.  Christy was upset: “Oh crap!  This stinks…This just isn’t right.”

Huckelberry, obviously piqued, sent the email on to (Pima County) lobbyist Michael Racy the next day, saying, “ADOT on shit list.”


Access the complete ADI story at:

For an analysis of the 2017 Public Comment on a potential Avra Valley Route, visit:

Of over 3000 comments received, almost 90 percent preferred the “no build” or use the existing I-10 corridor options rather than an Avra Valley alignment.  About one-half of one percent favored I-11 in the Avra Valley; the balance of comments were unrelated or referred only to other areas.

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