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Interstate 11

I-11: A Disaster for the Sonoran Desert?


The Draft Environmental Impact Statement (DEIS) for Interstate 11 was released on April 5, 2019 and, as of right now, the deadline for public comments is July 8, 2019 (this was extended from the original May 31, 2019 deadline). As expected, the Preferred Alternative in the DEIS is in Avra Valley at the doorstep of Saguaro National Park, the Arizona-Sonora Desert Museum, and Ironwood Forest National Monument We need you to TAKE ACTION TODAY to oppose this absurd, destructive, and insane proposal. 

This map shows previous routes considered for I-11 west of the Tucson Mountains. The yellow route is representative of the Preferred Alternative released in April 2019. This route has to “thread the needle” between Saguaro National Park and Ironwood Forest National Monument and would completely isolate Saguaro National Park and the Tucson Mountains, severing all wildlife linkages that currently connect this mountain range to other protected open spaces to the east and west. Click on this image for a larger view of the map. (See below for the actual Preferred Alternative Route or “Recommended Corridor Alternative.”)


Preferred Alternative route for the proposed Interstate 11, as released in the Tier 1 DEIS in April 2019. Click on this image for a larger view.



1. Leave a comment on THIS POST on the Arizona Department of Transportation Facebook page letting them know that you OPPOSE the Recommended Alternative route for I-11 that traverses Avra Valley and is at the doorstep of Saguaro National Park, Ironwood Forest National Monument, and other treasured public and tribal lands. Feel free to also use any of the ideas available in our SUGGESTED TALKING POINTS to help write your comment. 

2. Send in a quick comment requesting an extension of the public comment period. Simply go to THIS WEBSITE and submit the following comment (or put into your own words, which is even better):

Due to the large footprint of the preferred alternative and the destructive and negative consequences to hundreds of thousands of acres of federally protected lands, local open spaces, and private property, the public comment period for this project should be extended by 120 days to September 28, 2019. The current comment period is only 56 days, or less than 2 months, which is unacceptable and does not give members of the public enough time to thoroughly review the Draft Environmental Impact Statement and write thoughtful, well-informed comments for your review and consideration. Thank you for considering my comment on this issue. 

3. View an interactive map of the Preferred Alternative Route for Interstate 11 to gain a deeper understanding of all the public lands this proposed interstate would destroy forever. The interactive map can be found HERE


1. Download and print out outreach posters and distribute to your friends, neighbors, and nearby businesses to increase awareness about this grave threat to the Sonoran Desert. The images below are .jpg files which you can save to your computer by right-clicking the image and clicking the “Save Image As…” option. You can also download a pdf version of the half-page flyer HERE and the full-page flyer HERE

Half-page flyer (two flyers on one 8.5×11 sheet of paper)


Full-page flyer that can be printed on one 8.5×11 sheet of paper.


2. Write a Letter to the Editor opposing the I-11 Preferred Alternative Route. Letters can be submitted to the Arizona Daily Star at THIS WEBSITE

Talking points to help inform your letter to the editor can be found HERE

Here are some Letters to the Editor about I-11 recently published in the AZ Daily Star for your reference:

I-11 bad for all in Pima County” – Gene Valdes (May 21, 2019)

Let’s stay united on opposing I-11 Corridor” – Dorian Dodson (May 19, 2019)

New route for I-11” – Jeffrey McConnell (May 18, 2019)

Re: the April 22 article ‘Federal, state, and local voice concerns over environmental impact of proposed I-11 highway” – Christine Felix (May 15, 2019)

Save the people, not just wildlife, from I-11” – Albert Lannon (May 14, 2019)

3. Attend a free comment-writing workshop:

Thursday, May 16, 5:30-7:30pm ♦ Martha Cooper Library 1377 N. Catalina Ave. Tucson

Tuesday, May 21, 6:30-7:30pm ♦ Picture Rocks Community Center 5615 N. Sanders Rd. Tucson


1. Attend one of the public meetings planned for southern Arizona. Your presence really matters at these meetings, whether you want to speak or not! Just being there and showing that you oppose the Preferred Alternative for I-11 will make a big difference. 

Wednesday, 5/8/19 ♦ 3–8 p.m. ♦ Tucson Convention Center Ballrooms/Lobby ♦ 260 S. Church Avenue, Tucson

Saturday 5/11/19 ♦ 11 a.m.–4 p.m. ♦ Marana High School Cafeteria ♦ 12000 W. Emigh Road, Marana

Thank you to everyone that came out to these meetings! Over 200 people attended the May 8 public meeting, with 85 giving verbal comments. And over 350 people attended the May 11 public meeting in Marana, with over 100 people giving verbal comments. Thank you for speaking up and voicing your opposition to the proposed I-11 route! 

2. Read the DEIS and send in your comments on this insane proposal. Suggested talking points to help inform your comments can be found HERE. You can find the DEIS at THIS WEBSITE.

General guidelines for written comments on federal proposals can be found HERE.  You can submit public comments in multiple ways, including:    

At a public hearing (see above)

Phone: 1.844.544.8049 (bilingüe)



I-11 Tier 1 EIS Study Team c/o ADOT Communications               
1655 W. Jackson Street
Mail Drop 126F              
Phoenix, AZ 85007


For many years, local community organizations and government agencies in Pima County, AZ have been aware of plans and ideas surrounding the issue of how to accommodate increased traffic flow on Interstate 10, which currently runs directly through downtown Tucson. One idea that has been floated in various forms is to build a brand new freeway west of the Tucson Mountains to “bypass” Interstate 10.

This proposed freeway, now called Interstate 11, is abhorrent on many levels, the most significant being that a freeway west of the Tucson Mountains would have to be built directly adjacent to Saguaro National Park and Ironwood Forest National Monument.

In addition to these iconic federal parks, there are other protected open spaces that would be negatively impacted such as Pima County-owned Tucson Mountain Park, the Tucson Mitigation Corridor owned by the Bureau of Reclamation and managed by Pima County, open space properties purchased and protected under the Sonoran Desert Conservation Plan, and tribal lands owned by the Pascua-Yaqui Nation and the Tohono O’odham Nation. To put it simply, Interstate 11 would be a disaster for the Sonoran Desert. 

I-11 Joint Stakeholder Community Planning Group

In 2018, the Arizona Department of Transportation and the Federal Highways Administration convened a diverse coalition of community groups to offer input on two proposed routes for Interstate 11: 1) west of the Tucson Mountains, as described above, 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 the following press release (a more lengthy position statement written by the group, along with a list of the groups involved, can be found HERE):

Citizens Convened by Federal and State Highway Departments Strongly Oppose Highway in Avra Valley

Stakeholders find Common Ground in Downtown Route to Create a Sustainable City

Arizona Department of Transportation (ADOT) and the Federal Highway Administration (FHwA) recently convened representatives of several stakeholder organizations in a process to explore two alternative routes for the proposed Interstate 11 through Pima County. Stakeholders have developed a consensus position that re-designing I-10 and I-19 to accommodate co-location with I-11 could have a positive effect on downtown revitalization while stating strong opposition to an “I-10 bypass” in Avra Valley.

“A freeway that borders Tucson Mountain Park, Tohono O’odham tribal lands, Saguaro National Park, and Ironwood Forest National Monument makes absolutely zero sense,” stated Carolyn Campbell, Executive Director of the Coalition for Sonoran Desert Protection. “The direct and cumulative effects of a freeway to these natural and cultural iconic places of the Sonoran Desert simply cannot be mitigated. This route should not be under consideration.”

Stakeholders believe that there are shortcomings associated with the federal review process that focuses on new highway construction.  However, “we believe that there could be a significant opportunity to address some of the historic negative consequences that resulted from the construction of I-10,” said Gene Einfrank, Menlo Park Neighborhood Association President. “The building of I-10 physically divided our community and diminished the quality of life of our downtown and other neighborhoods along the highway. Instead of simply adding new lanes to our existing highway, we should consider redesigning portions of it—either going underground or suspended—so that we can reconnect our city.” 

Moreover, stakeholders encourage a broader look at future transportation options, focusing on changes to the management of the existing highway to reduce congestion, including pricing, scheduling, and other programs; technologies that improve traffic flows; and enhancements to the rail system, including light rail and intermodal transportation.

The group recommends ADOT and FHwA refer to the I-11 Super Corridor study final document, which was submitted to ADOT in 2016, to draw inspiration on a comprehensive design. The Sustainable Cities Lab, hosted at the UA College of Architecture, Planning and Landscape Architecture, completed this transdisciplinary study on the I-11 corridor along with Arizona State University and the University of Nevada, Las Vegas. UA’s study area focused on opportunities from Marana to the south of downtown Tucson. Their outcomes incorporate the addition of light and heavy rail, walking, cycling, new technology for controlling traffic as well as incorporating alternative forms of energy production and transportation.

Current Process and Next Steps

Throughout the fall of 2018, community partners knew that federal agencies were working on a Draft Environmental Impact Statement (DEIS) for the “Tier 1” level of review of Interstate 11. Maps of various route alternatives had been circulated in prior years, with the two possible routes described above – west of the Tucson Mountains or co-located with Interstate 10 – being the final two in the running.

The Tier 1 DEIS was finally released on April 5, 2019 and the Preferred Alternative was as we suspected, at the doorstep of some of our most treasured and valuable public lands in southern Arizona.   In preparation for this, the Coalition expanded our Wildlife Camera Monitoring Program in 2018 to include new wildlife cameras in Avra Valley along the proposed I-11 route to document the diversity of wildlife that live in this area and would be harmed by a new freeway. Our monitoring of this area has resulted in beautiful photos of wildlife, along with scat evidence of mountain lions in late 2018!

We continue to work with our partners on the I-11 Joint Stakeholder Community Planning Group to execute a coordinated, community-based response to this DEIS. 

Join us today in this important fight by taking action with any or all of the suggested actions above, donating or volunteering – thank you for your support of the Sonoran Desert! 

Map of proposed route west of the Tucson Mountains (differs slightly from Preferred Alternative released on April 5, 2019 but the negative impacts are the same)


Photos of Saguaro National Park


Saguaro National Park is a national treasure populated by large stands of the Sonoran Desert’s most iconic plant, the saguaro cactus. Since Interstate 10 already runs along the park’s eastern flank, an additional freeway directly to the west would isolate and endanger this national park forever. Photos courtesy Saguaro National Park/NPS.


This saguaro cactus stands tall and greets the sun in Saguaro National Park-Tucson Mountain District. Photo courtesy Saguaro National Park/NPS.


Photos of Ironwood Forest National Monument


Scenic vista of Ironwood Forest National Monument, home to one of the largest “forests” of saguaros and ironwood trees in the world. Nearly 600 plant species and 121 vertebrate animal species call the monument home. Photo by Bob Wick/BLM-CC.


Ragged Top Mountain is one of the most recognizable vistas in Ironwood Forest National Monument. It is also home to a healthy population of desert bighorn sheep that occasionally roam and migrate to the Tucson Mountains to the east, and historically even further to the Tortolita and Santa Catalina Mountains. Photo by Bob Wick/BLM-CC.


Photos of wildlife that would be harmed by an I-11 route west of the Tucson Mountains


This Nelson’s Bighorn Sheep ram (Ovis canadensis nelsoni) was photographed in the northern end of the Tucson Mountains in 2016 after likely migrating from Ironwood Forest National Monument to the west (and directly through the area proposed for an I-11 route). This ram was one of two desert bighorn sheep spotted throughout the Tucson Mountains until they finally traveled further afield. Photo by Brian Jones.


This mule deer was photographed in the Tucson Mountains among dense Sonoran Desert foliage. Photo by Thomas Wiewandt.


CSDP Conservation Science Director Jessica Moreno was excited to find mountain lion scat in Avra Valley near one of our camera sites. The large home range this mountain lion needs would be fractured forever by a potential new freeway being proposed nearby.

All four animals below were photographed by the same remote wildlife camera managed by the Coalition and our amazing volunteers in the northern Tucson Mountains. Coyotes, javelinas, foxes, and bobcats are four of many small mammals that populate the Tucson Mountains and would be harmed by a new freeway west of the Tucson Mountains.


Road Runner: Opponent suggests improvements to I-1o could alter plans for proposed I-11” – AZ Daily Star (May 19, 2019)

KXCI-30 Minutes Interview on CSDP and I-11” – Interview with CSDP Executive Director Carolyn Campbell, hosted by Amanda Shauger (May 12, 2019)

Letter from Representative Raul Grijalva opposing the Recommended Alternative route for I-11, read into the record at the May 8 public meeting at the TCC

Time to draw a line for nature, in Avra Valley” – AZ Daily Star (May 12, 2019)

Interstate 11 Public Hearing” – Recap of the May 8 public meeting at the Tucson Convention Center starts at minute 13:52 and an interview with ADOT Project Manager Jay Van Echo at minute 16:48, Channel 6, AZ Public Media, Arizona 360 (May 10, 2019)

Public asked to share input on proposal for Interstate 11” – AZ Public Media (May 10, 2019)

ADOT seeking public comment on proposed route for Interstate 11” – KGUN 9 (May 10, 2019)

Interstate 11 meeting draws few local residents” – Nogales International (May 10, 2019)

ADOT holds public meeting on controversial I-11 corridor” – KOLD 13 (May 8, 2019)

State Seeks Public Comment on New Interstate” – Article and radio interview on Arizona Public Media (May 7, 2019)

Federal, state and local agencies voice concerns over environmental impact of proposed I-11 highway” – AZ Daily Star (April 22, 2019)

William Thornton: Running Interstate 11 through Avra Valley would be a bad idea” – Op-Ed in the AZ Daily Star (April 17, 2019)