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Lawsuit Timeline

Pre-lawsuit – 2007-2021

2007 – The Arizona Game and Fish Commission and Pima County made formal statements opposing any new freeway that “bypasses” Interstate 10.

2011 – The Maricopa Association of Governments made a presentation to the Pima Association of Governments Management Committee about a potential “Interstate 11 Corridor.”

July 2013 – The Coalition for Sonoran Desert Protection (CSDP) submitted comments on the I-11 and Intermountain West Corridor Study – Corridor Justification Report (completed by the Arizona and Nevada Departments of Transportation) opposing any highway options in Avra Valley.

January 2014 – The Friends of Saguaro National Park passed a formal resolution opposing the proposed Interstate 11 in Avra Valley and called on the Arizona Department of Transportation (ADOT) to drop any further consideration of the proposal. 

July 2016 – CSDP submitted comments, along with other community groups, during the “scoping period” for the Tier 1 Draft Environmental Statement on Interstate 11, questioning the purpose and need for the project and opposing any alternatives located in Avra Valley.

June 2017 – CSDP submitted comments, along with other community groups, on the “I-11 Corridor Alternatives Selections Report” opposing any routes located in Avra Valley and supporting co-location with Interstates 19 and 10.

2018: I-11 Joint Stakeholder Community Planning Group

ADOT and the Federal Highways Administration (FHWA) convened a diverse coalition of community groups to offer input on two proposed routes for Interstate 11: 

• 1) Located in Avra Valley, west of the Tucson Mountains (to be referred to as the West Option), or

• 2) Co-located with the existing Interstate 10.

At the end of this advisory process, many of the involved groups formed the I-11 Joint Stakeholder Community Planning Group.

In August 2018, the I-11 Joint Stakeholder Community Planning Group released a press release formally opposing a highway in Avra Valley.

2018-2019: Tier 1 Draft Environmental Impact Statement (DEIS)

Throughout the fall of 2018, community partners knew that federal agencies were working on a Tier 1 DEIS for I-11.

To strengthen the argument against the West Option, CSDP expanded our Wildlife Camera Monitoring Program in 2018 to include new wildlife cameras in Avra Valley along the proposed West Option route to document the diverse wildlife in this area that would be harmed by a new freeway. We documented beautiful photos of wildlife and scat evidence of mountain lions in late 2018!

The Tier 1 DEIS was released on April 5, 2019, listing the West Option as the Recommended Alternative. Throughout April, May, June, and early July 2019, we worked with our member groups, partners on the I-11 Joint Stakeholder Community Planning Group, and concerned community members to execute a coordinated, community-based response to this DEIS.

Outreach

Two public meetings were held in the Tucson region to gather public comments on the DEIS. Over 200 people attended the May 8, 2019 public meeting at the Tucson Convention Center, with 85 giving verbal comments.

Over 350 people attended the May 11, 2019 public meeting in Marana, with over 100 people giving verbal comments. 

CSDP held multiple comment-writing workshops, in mid-town Tucson, downtown Tucson, and Picture Rocks. In early June, we sent out over 13,000 postcards to property owners along the proposed West Option route to inform them about the proposal and their opportunity to comment on it. 

On July 4, 2019, CSDP submitted our official comments on the Tier 1 DEIS, representing our 30 members and including 27 signatories from our member groups and partner organizations. Sixteen Letters to the Editor were published in the AZ Daily Star opposing the I-11 route (we know of many more that were submitted and not published), and 22 news stories were published both in print, on-line, and on TV about the public comment period and the widespread community opposition to this proposal.

View all LTEs, letters, and media here

Additional resources can be found on our post dedicated to the 2019 Tier 1 DEIS.

2021: Tier 1 Final Environmental Impact Statement (FEIS)

Starting July 16, 2021, ADOT and FHWA hosted a 30-day public comment for the public to review the FEIS. The FEIS identified two possible Preferred Alternatives, the West Option AND the route that co-locates I-11 with I-19 and I-10. CSDP released a list of talking points for public use to increase pressure against the West Option.

CSDP continued to work with our community to collectively oppose the West Option. Notable achievements included:

• The City of Tucson re-affirmed their 2019 resolution opposing any new freeway in Avra Valley at their meeting on August 10, 2021.
• The Town of Sahuarita Mayor and Council formally opposed the I-11 West Option at their meeting on August 10, 2021 and subsequently submitted a letter expressing this opposition on August 13, 2021.
• Pima County approved a resolution opposing any new freeway in Avra Valley and the proposed I-11 West Option at their meeting on August 16, 2021. Pima County received over 225 letters from community members supporting this resolution.

On August 16, 2021, CSDP submitted public comments telling ADOT/FHWA to ABANDON the West Option in Avra Valley.

On November 15, 2021, FHWA released its Record of Decision for the I-11 Tier 1 FEIS. Unfortunately, the listed Selected Corridor Alternative did not abandon the West Option; instead, it maintains both the West and East Options in the Tucson Region as the process moves forward to the Tier 2 stage. The full Record of Decision with Appendices is also available for review.

Lawsuit Begins

FHWA approved the highway in November 2021 despite postponing an environmental review or deciding between two route options in Pima County, both of which would harm wildlife, public lands, and air quality and exacerbate the climate emergency. 

On April 21, 2022, CSDP and member groups (Center for Biological Diversity, Tucson Bird Alliance (then Tucson Audubon Society), and Friends of Ironwood Forest) filed a lawsuit in U.S. District Court in Tucson to challenge FHWA’s approval of I-11 in November 2021. The lawsuit says FHWA’s “approve now, study later” approach violated federal law.

In April 2022, the Center for Biological Diversity published a press release about the lawsuit.

On January 25, 2023, U.S. District Judge John C. Hinderaker heard arguments on the federal government’s motion to dismiss a portion of our lawsuit. Read the press release about the court hearing.

On May 24, 2023, U.S. District Judge John C. Hinderaker issued his decision and denied the federal government’s motion to dismiss a portion of our lawsuit. This meant our lawsuit could move forward in full. Learn more at this press release and this AZ Daily Star article. You can also read Judge Hinderaker’s full decision.

On July 19, 2023, the U.S. Fish and Wildlife Service announced that the cactus ferruginous pygmy owl (Glaucidium brasilianum cactorum) (CFPO) will be listed as threatened under the Endangered Species Act.

On December 14, 2023, CSDP and co-plaintiffs in the lawsuit filed new charges against the FHWA for failing to consider harms to threatened and endangered species from the proposed I-11 routes. We argued that the CFPO’s new protections require federal officials to go back to the drawing board before moving to the next phase of choosing the highway’s exact route through Pima County. Read the press release here.

In June 2024, Pima County reaffirmed their opposition for I-11 by passing a new resolution asking Governor Katie Hobbs to stop consideration of the West Option. Read the full letter here.

In late 2024, the lawsuit moved to settlement negotiations.

In January 2025, as a result of our ongoing lawsuit – FHWA and ADOT agreed to re-evaluate their Tier 1 FEIS on the proposed Interstate 11. ADOT also agreed to hold a new 60-day public comment period in the future. Read the press release here.

Present Day

We expect ADOT’s public comment period for the re-evaluated Tier 1 FEIS to begin in late 2026.

Document Library

Last updated: March 12, 2026