As an active opponent of the Pima County Administrator and Arizona Dept. of Transportation’s plans to run a new highway, Interstate 11, through the Avra Valley. I sent the following letter via the U.S. Postal Service to President Donald Trump, Secretary of Transportation Elaine Chao, and Acting Federal Highway Administration Administrator Brandye Hendrickson on February 24, 2018:
Dear Mr. President, Secretary Chao, and Acting Administrator Hendrickson:
I am writing on behalf of a great many people in rural Pima County, Arizona, who are concerned about plans to build a new interstate highway, I-11, in Southern Arizona. A three-year, $15 million Tier One Environmental Impact Study was begun in March, 2016, by the Arizona Dept. of Transportation (ADOT) and the Federal Highway Administration. That study has now determined that there are only two possible routes, either the existing Interstate 10 corridor, or a new highway through the Avra Valley west of Tucson. A preliminary preferred alternative is due this Spring.
A portion of I-11 is being constructed to link Las Vegas and Phoenix. We have no opinion on that; it is their business. We are concerned, however, that the Southern Arizona planning is directly contrary to the goals of your Administration to keep jobs in the United States.
In the Business Case of the Purpose and Need document, the emphasis is on 1) “nearshoring,” that is, attracting American companies from China to… Mexico, where wages are now lower than China; 2) “integrative manufacturing,” which is research and development in the U.S. with manufacture and assembly in…Mexico; 3) attracting shipping from U.S. West Coast ports to the expanding Port of Guaymas in…Mexico.
In short, I-11 is about creating jobs in Mexico and stealing existing American jobs from West Coast ports.
A route through the Avra Valley and its rural communities would evict families, create air, noise and light pollution, increase human and drug smuggling, impede wildlife movement, damage archaeology sites thousands of years old, and inevitably raise taxes due to loss of tourism at places like Saguaro National Park, the Arizona-Sonora Desert Museum, Kitt Peak Observatory, Tucson Mountain Park and Ironwood Forest National Monument.
Even ADOT admits that they could do without an Avra Valley highway. Several years ago Jennifer Toth, then ADOT’s State Engineer, said publically that double-decking just six miles of the existing I-10 north of the I-19 interchange would do everything they wanted, but cost too much. While the cost-per-mile would be higher, double-decking a piece of I-10 would cost nearly $2 billion less than a new highway (ADOT’s numbers).
In last summer’s EIS scoping round more than 3,000 people commented, believed to be an ADOT comments record. We went through those comments one-by-one and found that 89 percent opposed I-11 in Southern Arizona or any Avra Valley I-11 route, while just ½ of one percent favored such a route. That material can be found at http://i11study.com/Arizona/Documents.asp.
It is not a partisan issue. There are Republicans, Democrats and Independents on both sides of the issue.
With your Infrastructure Plan now on the table, and with a choice of I-11 routes on the immediate horizon, we ask that you and your Administration state your position for the guidance of both the ADOT-FHWA EIS study and voters. We hope you will join us in opposing any Interstate 11 route through the peaceful Avra Valley, and that you will confirm that I-11 is not about facilitating jobs for Americans and act accordingly.
I might add that, while we are often called NIMBYs, I am 80 years old with incurable cancer and other afflictions. I will be gone long before the first bulldozer enters the Avra Valley. But we owe it to our children and grandchildren and great-grandchildren not to ruin this piece of the Sonoran Desert, not to leave our pockets of rural poverty without hope while jobs are exported across the border.
Please also know that your responses will be made public to our neighbors and supporters.
After a month with no response from any of the three, I re-sent the letter as an email on March 23, 2018. While the White House has a website for that purpose, it was quite hard to track down ways to email DOT or FHWA. The White House responded in three and one-half hours:
Given that the quick response does not mention the subject of my letter, my guess is that it is an automated system and no one actually reads the emails. Of course I now realize that the President was quite busy at the time dealing with issues far more important than saving American jobs, like starting an unwinnable trade war with China, deflecting adultery charges, and purging the military of the one-half of one percent who might be transgendered. (That is the highest estimate from a Dept. of Defense/Rand Corp. Study.)
Okay, so I wait and see if DOT or FHWA responds. In the meanwhile I note that Pima County Administrator Charles Huckelberry sent the Board of Supervisors a memo in response to questions from Vice Chair Ramón Valadez about my quoting his pro-Avra Valley I-11 statements in the press:
My letter to Huckelberry: As to your rationale regarding “interaction and information” about Interstate 11, I suggest that you are rewriting recent history. BOS Resolution 2007-343 is also clear and unambiguous and “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.” That is Pima County policy which you have ignored, re-interpreted, and violated in disregard of the Arizona Revised Statutes.
You state, “Pima County has no decision-making authority in the location of a future Interstate 11. Our only role is to provide review and comment on proposals….” That, I suggest, is disingenuous and contrary to the documented history. The ADOT-FHWA Tier One Environmental Impact Study began in March, 2016. In July, 2013 – nearly three years earlier — you and your office released maps and arguments for routing I-11 through the Avra Valley.
At that time ADOT was looking only at a Las Vegas – Phoenix connection, with no plans south of Casa Grande. You launched an expensive campaign to extend I-11 south to Mexico in violation of 2007-343.
You are quoted in the July 4, 2013, Arizona Daily Star saying, “It makes no sense for this route to stop at the Gila River if we’re serious about building a corridor to stimulate this area’s economic potential.” Accompanying that article was your map of your proposed Avra Valley I-11 route, which I note included what is now called the “Sonoran Corridor.”
You are also quoted in the Star of June 30, 2013, “The concept of Interstate 11 should be from Canada to Guaymas and not stop north of the Gila. We cannot be left out of this.”
Your column in the Marana News around that time added, “A potential southern segment of Interstate 11 would bypass Interstate 10 by looping behind the Tucson Mountains and ultimately connect to Interstate 19, building the potential for one of the first north-south high-capacity routes through the intermountain west….”
And in the October, 2013, Marana News you wrote: “The proposed route we released in July should be considered a starting point for the discussion as we move forward.”
Also in October, 2013, you wrote in the Picture Rocks Digest, as “another upside…Steering that through traffic on I-10 away from the heart of the city will help ease congestion….”
When it was pointed out that then-ADOT State Engineer Jennifer Toth had said that double-decking just six miles of Interstate 10 north of the I-19 interchange would do everything ADOT wanted for nearly $2 billion less than a new Avra Valley highway, you told Star reporter Phil Villareal, “’If you look at the history of double-decker freeways, most of them have been torn down. One of them fell down, in San Francisco’…He expressed concerns over the logistics and safety of the option.” (August 22, 2013) That, of course, ignores the fact that the I-10 – I-19 interchange is elevated, and that later you championed an elevated highway at Mile Wide and Sandario Roads because of insufficient right-of-way.
In the current ADOT-FHWA study, Pima County’s position on I-11 is represented only by your comments, with no mention of Resolution 2007-343. Here are some from the public 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.”
“If the existing interstate route were selected, impacts and traffic volumes would require interstate widening and perhaps double decking with related costs and urban socioeconomic impacts related to noise, access and public safety. The conceptual route through Avra Valley developed by Pima County considered both cultural and environmental features…Additionally it incorporated the use of an elevated roadway section to facilitate wildlife corridors, which is a proven concept. By utilizing a route n primarily undeveloped State, County and City lands, all but a few residences were avoided along the 56 mile route.” (June 7, 2016) Previously you stated that 47 families would have to be evicted.
Here is the relevant paragraph from his BOS memo; I leave it to you, dear readers, to figure out what he said:
The only “mitigation detail” in his ADOT comments is the elevated freeway that might fall down. Analysis? Possible initial observable mitigation requirements? I’m still looking.
POSTSCRIPT: A week after my emails to Washington, the automated White House response is the only respnse I’ve received. And that, sadly, is no April Fool!