Waiting until the July 8 deadline for public comment on the Arizona Dept. of Transportation (ADOT)/Federal Highway Administration’s (FHWA) Draft Tier One Environmental Impact Study (DEIS), County Administrator Chuck Huckelberry gave a “Yes, but…” to the proposed Avra Valley Recommended Alternative. In doing so he completely ignored, once again, the Pima County Board of Supervisor’s unanimously adopted policy in Resolution 2007-343 opposing “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.”
Also not mentioned is the April, 2019 letter from Board President Richard Elias and District 3 Supervisor Sharon Bronson reaffirming that policy as the official position of Pima County. Instead, Huckelberry, the Board’s employee, says: “The County will object to any Avra Valley alternative I-11 corridor that does not adequately mitigate environmental, historic, archaeological and urban form impacts to the standards set for in out detailed list of comments in Attachment 1 and our environmental mitigation analysis found in Attachment 2.”
Also missing in Huckelberry’s memo is the unanimous position of the Tucson City Council and Mayor opposing the Avra Valley route and arguing for improving I-10 as a less costly and more economically beneficial alternative that would also protect Tucson’s CAP water settling ponds in the Avra Valley.
Attachment 1 are detailed comments by Pima County Transportation Director Ana Olivares criticizing some of the DEIS analysis and explaining why more mitigation is needed to make the Avra Valley highway more acceptable. What would make the Avra Valley route acceptable, she states, are to:
- Minimize or eliminate interstate entrance and exit points (interchanges) in Avra Valley;
- Acquire mitigation lands adjacent to the I-11 route to forestall future commercial and urban expansion in the Avra Valley;
- Establish additional wildlife movement corridors in Avra Valley via acquisition or other means; and
- Establish protected wildlife movement corridors north of Avra Valley between the Piccacho Mountains/Durham/Coronado Plain area and the Ironwood Forest National Monument via acquisition or other means.
Olivares adds that Pima County’s inclusion in discussions with the federal Bureau of Reclamation is necessary to make any changes to the Tucson Mitigation Corridor, established “in perpetuity” when the CAP canal system was built to facilitate wildlife connectivity.
Attachment 2 is Huckelberry’s 2014 study of how to do the Avra Valley highway correctly, with 11,000 acres of mitigation lands to be provided at at ADOT/FHWA expense, plus elevated highways in some areas – an idea originally ridiculed by the County Administrator when ADOT’s State Engineer Jennifer Toth first raised it a dozen years ago. Toth said then that double-decking six miles of I-10, from Ruthrauf to I-19 would do everything they wanted, but was too expensive.
Analysis, confirmed by ADOT, found that the cost-per-mile was much greater, but the total cost would be nearly $2 billion less than constructing a new 56-mile Avra Valley highway. Huckelberry quipped then that a double-decked freeway would fall down, “like in San Francisco.” Now he finds it the only way to get necessary right-of-way in some parts of his proposal, such as at Sandario and Mile Wide.
While the required Tier 2 EIS is mentioned, the recent FHWA – ADOT Memorandum of Understanding allowing ADOT to monitor itself on the environmental issues in a Tier 2 study, is not.Interstate 11 Corridor Draft Tier 1 Environmental Impact Statement Review and Comments by Pima County
How the County Administrator, hired by and accountable to the Board of Supervisors to carry out County policy, can simply flaunt that policy and make his own – as with the Avra Valley I-11 route – is a mystery. Even when the Board President and most affected Supervisor reaffirm that policy, he chooses to ignore it – and is not called to account.
Huckelberry is an intelligent man. What he appears to be doing in this memo and the attachments is negotiating for the feds and ADOT to add more land, at their expense, to that owned or controlled by the county. I-11 is a bargaining chip. Huckelberry has wanted an Avra Valley I-11 all along, but now sees an opportunity to obtain more land for Pima County along with the highway.
His mitigation strategies, better than those in the DEIS, would still run an interstate highway through it, bringing noise, air and water pollution, increased smuggling and hazardous cargo; ousting families from their homes, reducing tourism, impacting wildlife, and destroying a rural way of life.
A detailed comment submitted July 4 by 28 organizations – a broad coalition of environmental and citizen groups organizing by the Coalition for Sonoran Desert Protection – offered a different scenario: Given the far-reaching and devastating impacts that the Recommended Alternative route would have on the incredible portfolio of public conservation lands in and adjacent to Avra Valley, we express our strong opposition to the Recommended Alternative route (Avra Valley) and feel that should additional capacity be warranted, that reconfiguration of existing highways is the only acceptable Alternative. This DEIS is replete with inadequate analyses and is, in and of itself, a fatal flaw.