Background and History
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.
2007-2017: Past planning processes for Interstate 11
Planning for this project has been underway for quite some time. The process can be traced back decades but includes the following milestones:
2007 – Both 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 – We 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 corridors 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 to drop any further consideration of the proposal.
July 2016 – We submitted comments, along with other community groups, during the “scoping period” for the Tier 1 DEIS on Interstate 11, questioning the purpose and need for the project and opposing any alternatives located in Avra Valley.
June 2017 – We 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
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.
2018-2019: Tier 1 Draft Environmental Impact Statement
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 Recommended 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 lives 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!
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. Two public meetings were held in the Tucson region to gather public comments on the DEIS. Over 200 people attended the May 8 public meeting at the Tucson Convention Center, with 85 giving verbal comments. And over 350 people attended the May 11 public meeting in Marana, with over 100 people giving verbal comments. We held multiple comment-writing workshops, in mid-town Tucson, downtown Tucson, and Picture Rocks. And in early June, we sent out over 13,000 postcards to property owners along the proposed route to inform them on the proposal and their opportunity to comment on it. On July 4, 2019, we 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 and we know of many more that were submitted and not published (see our Media & LTEs page for links). 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 (see our Media & Letters to the Editor page for links).
2021: Tier 1 Final Environmental Impact Statement
On November 15, 2021, the Federal Highway Administration released its Record of Decision for the Interstate 11 (I-11) Final Tier 1 Environmental Impact Statement, including the Selected Corridor Alternative. Unfortunately, the Selected Corridor Alternative did not abandon the West Option through Avra Valley; 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.
The Record of Decision followed a public comment period that began on July 16, 2021 when the Arizona Department of Transportation and Federal Highways Administration released the Tier 1 Final Environmental Impact Statement (FEIS) for public review. The FEIS identified two possible Preferred Alternatives, the route through Avra Valley AND the route that co-locates I-11 with I-19 and I-10 through the Tucson region. There was a 30-day public comment period for the FEIS, with public comments due on August 16, 2021.
You can find a listing of media articles and Letters to the Editor about Interstate 11 from the past few years on this webpage. You can also read our public comments on the FEIS submitted on August 16, 2021.
During the most recent public comment period on the Final Environmental Impact Statement for the Tier 1 process in 2021, notable achievements related to opposing the I-11 West Option 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 West Option for I-11 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.
*A diverse array of community organizations submitted comments on the FEIS opposing the I-11 West Option through Avra Valley. See below for links to these comment letters.
Comments submitted on the Tier 1 I-11 FEIS
CSDP comments on the Tier 1 I-11 FEIS, co-signed by 24 environmental and community partners
CSDP Comments requesting an extension of the comment deadline from 30 days to 120 days
Comments from Center for Biological Diversity requesting an extension of the comment deadline from 30 days to 120 days
Comments from Friends of Ironwood Forest requesting an extension of the comment deadline from 30 days to 120 days
Dr. Thomas Wiewandt, President of Wild Horizons Publishing, comments on the I-11 FEIs, with a focus on impacts of sound/noise from freeways on wildlife
Tucson Historic Preservation Foundation, comments on the I-11 FEIS
U.S. Department of Interior, comments on the I-11 FEIS
Pima County, comments on the I-11 FEIS
Gates Pass Area Neighborhood Association, comments on the I-11 FEIS