Interstate 11 “Study:” Lies, Damned Lies, And Phony Statistics

Public Meetings Coming Up on “Recommended” New Highway Through the Avra Valley

The much-delayed $15 million Interstate 11 Tier 1 Draft Environmental Impact Study released April 5 by the Arizona Dept. of Transportation and Federal Highway Administration surprised no one with its choice of the controversial Avra Valley route rather than expanding and improving Interstate 10.  The Avra Valley route has been the choice for at least 12 years, championed by the Pima County Administrator in opposition to his own Board Of Supervisors’ Resolution 2007-343, opposing any new highways in 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 position was recently reaffirmed by BOS Chair Richard Elias and District 3 Supervisor Sharon Bronson, but neither their communication, nor the original resolution, appear in the Draft EIS record.

Public meetings are scheduled to begin April 29:

Monday, April 29, 5 to 8 p.m., Palo Verde Energy Education Center, 600 N. Airport Road, Buckeye;

Tuesday, April 30, 4 to 7 p.m., Wickenburg Community Center, 160 N. Valentine St., Wickenburg;

Wednesday, May 1, 5 to 8 p.m., Holiday Inn, 777 N. Pinal Ave., Casa Grande;

Tuesday, May 7, 4 to 7 p.m., Quality Hotel Americana, 639 N. Grand Ave., Nogales;

Wednesday, May 8, 3 to 8 p.m., Tucson Convention Center Ballrooms/Lobby, 260 S. Church Ave., Tucson;

Saturday, May 11, 11 a.m. to 4 p.m., Marana High School Cafeteria, 12000 W. Emigh Road, Marana.

A promise made by ADOT/FHWA Project Manager Jay Van Echo to a standing-room-only meeting in Picture Rocks last August that public meetings would, for the first time, have open discussion and questions from the floor, has been modified, with a limited number of speakers allowed to sign up and a three-minute time limit, and with those only at the Tucson and Marana meetings. ADOT spokeperson Laura Douglas says: At the public hearings, anyone can provide their comments to a listening panel. It is not a question and answer format.”  Other questions about the Draft went unanswered.

What was surprising was the extent to which the I-11 planners went to make their case, including deliberate lies and misrepresentations, the ignoring of crucial health issues, the invention of false “statistics” to bolster their position, and a plan to circumvent the National Environmental Policy Act (NEPA).  That all reflects the widespread opposition to an Avra Valley highway.  The valley is home to some 25,000 people, dozens of whom would be displaced.

Now-peaceful communities would face noise, light, air and water pollution, wildlife would be impeded and put at risk, and irreplaceable ancient archeological sites would be destroyed.  The valley would be opened to increased drug and human trafficking, along with hazardous cargo.  Existing businesses along I-10 would be harmed and Tucson Water’s CAP settling ponds put at risk.  Saguaro National Park, the Desert Museum, Ironwood Forest National Monument and other visitor destinations would suffer.  That a new and deadly Valley Fever transmission corridor would be opened up is never mentioned.

Opposition to an Avra Valley highway has grown since then-State Transportation Board Chair Si Schorr, a real estate lawyer, called for a $3 million vote on a highway study 12 years ago without hearing from a single one of the over 100 people who had come to be heard.  That ignited an outcry that hasn’t let up.  In the 2017 public comment period over 3000 people responded, a possible ADOT record, with 89 percent opposed to an Avra Valley route and just ½ of one percent in favor.

The I-11 planners minimized the response by declaring over 1400 signatures on a petition just a single comment, and reducing some 550 individually signed postcards to just two comments since they arrived in two batches.  Attempts to ask questions from the floor at that round of public meetings were frustrated, with ADOT’s PR firm, The Gordley Group, sending an enforcer over to shut a questioner up while staff gathered up opposition  flyers so that they would not be seen by attendees.

Perhaps the biggest falsehood in the current Draft EIS is the description of the unincorporated Picture Rocks and Avra Valley communities:  “Avra Valley and Picture Rocks communities do not contain low-income or minority populations.”  In fact, those areas are designated Pima County “colonias” under federal HUD guidelines:

“There are 15 USDA designated Colonias in Pima County. Colonias, typically similar in makeup to Target Areas, include communities located within 150 miles of the US-Mexico border that meet the federal definition of lacking sewer, wastewater removal, decent housing, or other basic services.”

Picture Rocks and Avra Valley are also among 19 county Community Development “target areas:”  “59,081 people (or 7% of Pima County’s total population) reside in these target areas; 39% of the people are Hispanic or Latino; 61% of households are low- or moderate-income.”

Additionally, Picture Rocks Elementary is a Title 1 school, “with a large population of low income students who receive supplemental federal funds to assist in their educational goals.”  Requests for a correections release from the planners were denied.

While expressing “environmental justice” concerns for Tucson neighborhoods that might be affected by an I-10 option, the planners conveniently forgot to mention that the Menlo Park Neighborhood Association signed on to opposing an Avra Valley I-11 and for improving I-10.  The way that happened is another example of deliberate misrepresentation.

Stunned by the depth of opposition during the 2017 public meetings and comment period, the I-11 planners went to the Udall Foundation’s U. S. Institute for Environmental Conflict Resolution  to convene a series of invitation-only “stakeholders’ meetings.”  One long-time activist was told he had been invited; the email was sent to an address he’s never had.  It became clear to participants early on that the effort was to equalize the ½ of one percent with the 89 percent, but it didn’t work out that way.  Instead, the participants united around a statement opposing any Avra Valley I-11 and favoring improvements to I-10.  That August 3, 2018, statement does not appear in the Draft, or even in the U.S. Institute’s lengthy report, but said:

“The undersigned representatives of both groups of stakeholders agreed that of the two routes proposed for a future I-11 highway, the expansion and reconfiguration of the existing I-10 and I-19 corridor is the only acceptable route. A bypass through Avra Valley is not acceptable.”

It was signed by: Carolyn Campbell & Christina McVie, Coalition for Sonoran Desert Protection; Robin Clark & Ross Maynard, Avra Valley Coalition; Demion Clinco, Tucson Historical Preservation Foundation; Gene Einfrank, Menlo Park Neighborhood Association; Kevin Dahl, National Parks Conservation Association; Helen Erickson, Erickson Terrscape; Nicole Gillett, Tucson Audubon Society; Tom Hannagan & Gene McCormick, Friends of Ironwood National Forest; Joseph Iuliano, Drachman Institute; Terry Majewski, Statistical Research; Fred Stula, Friends of Saguaro National Park.

In reviewing the “Purpose and Need” for I-11, the Draft buries and barely mentions the major reason for a new highway as originally stated in the Business Case, “nearshoring.”  That is, attracting U.S. companies from China… to Mexico, where wages are now lower.  The Draft also leaves out “integrative manufacturing,” R&D in Arizona and Nevada with manufacture and assembly in Mexico.  In line with the “new NAFTA” that requires only manufacture in North America, it is clear that planners foresee more U.S. jobs going south and more truck traffic coming north.

Travel time gets a lot of consideration, with lots of charts.  Those who travel between Tucson and Nogales will see that, without I-11, travel time could increase as much as two entire minutes by 2040.  That’s worth spending billions of taxpayer dollars to prevent!

Never mentioned in the Draft are the crony benefits to local real estate speculators.  The Sonoran Corridor, for instance, is not a straight-forward east-west line linking I-10 and I-19, but drops south, at considerable added cost, to do two things: 1) Link with an Avra Valley I-11 (as originally labeled “I-11” on the County Administrator’s maps);   and 2) provide a free access highway to a planned 3200-acre Diamond Ventures Swan Southlands/Verano development.  (A records request to Pima County asking how much the county has paid DV over the last 10 years for their land remains unanswered.)

Avra Valley Coalition research a few years ago showed that some 1500 vacant acres along the County Administrator’s Avra Valley I-11 route, dubbed the “Huckelberry Highway,” were owned by Cardon family businesses.  Wil Cardon, who committed suicide in 2017, was also a failed Republican primary candidate for several offices, with the late Don Diamond and Diamond Venture’s CEO Eliot Goldstein serving on his campaign committee.

Serious public policy issues, such as the BOS Resolution 2007-343 and the inconvenient fact that the Sonoran Corridor was rejected by Pima County voters in the 2015 bond election, are ignored.  The BOS Resolution and the recent reaffirmation of it as Pima County policy are never mentioned.  And in any discussion by the Supervisors District 4’s Steve Christy should recuse himself.  He chaired the State Transportation Board in approving the $15 million study, suspending a bunch of approved ADOT projects to generate the money.  And how is it that the Board’s employee, Charles Huckelberry, gets to willfully and repeatedly violate County policy with impunity?

And if all else fails, and somehow public protest overcomes years of subterfuge and maneuvering?  ADOT and FHWA have a plan, also not mentioned in the Draft.  It’s called the “NEPA Assignment.”  That agreement will allow ADOT to monitor itself during a Tier 2 EIS, where the 2,000-foot corridor route is narrowed down to 400 feet, with interchanges, etc. and a “reclaiming” of Sandario Road, the major north-south road in the valley.

NEPA requires environmental monitoring for air, noise, light and water pollution, for effects on wildlife and endangered species, for environmental justice concerns for poor and minority communities, and much more.  The NEPA Assignment lets ADOT monitor itself.  Clearly the planners are concerned about a political change in 2020 that could strengthen the opponents of an Avra Valley I-11.

But equally clearly the I-11 planners are worried, and have pulled out all the stops – “Lies, Damned Lies, and Phony Statistics” – to bolster their case.

In addition to the public meetings, there is a public comment period that closes May 31, 2019.  To comment, go to:

Attachments (missing from the Draft):  BOS Resolution 2007-343; Elias-Bronson Reaffirmation letter; Stakeholder’s Position;

Links: UA News Valley Fever Corridor story:;   Draft EIS:

About Albert Vetere Lannon 107 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.