Stop CANAMEX, Stop the Intermountain West Corridor and I-11! Stop the Sun Corridor! Stop the 202!

Wednesday, July 28, 2021

UPDATE: Public Comment Deadline

 From Coalition for Sonoran Desert Protection

Interstate 11

On July 16, 2021, the Arizona Department of Transportation and Federal Highway Administration released the Tier 1 Final Environmental Impact Statement (FEIS). The FEIS now identifies TWO possible Preferred Alternatives, a West Option through Avra Valley AND an East Option that co-locates I-11 with I-19 and I-10 through the Tucson region.



The first action we are asking you to take is to submit a short comment letter requesting an extension of the public comment deadline from the current 30 days to a longer 120 days (see section below for various ways to submit your comment). You can read the comment letter we submitted with this request HERE. Feel free to copy the language in this letter and/or personalize with your own words. 

A summary of talking points from our letter requesting an extension of the public comment deadline include:

  • The 30-day comment period is insufficient for review of the documents and ensuring the public is aware of the opportunity to review and comment on the project.
  • Because the impacts of this project are intergenerational, we urge you to consider an extension to provide the public with a full and fair opportunity to participate in this process.
  • Many of the communities impacted by the Preferred Alternative Options within the Corridor Study area are minority and low-income populations who in many cases do not have access to the traditional means by which federal EIS processes are advertised and published. Both proposed alternatives will have disproportionate adverse effects on these populations and they will need adequate time to be notified via ground mail or other means.
  • The West Option through Pima County is proposed through traditional Tohono O’odham lands where tribal members may have limited internet access.
  • The Draft EIS documents totaled close to 5000 pages of text, maps, and other figures – the length and breadth of this document warrants a longer public comment period to allow adequate review by the public.
  • A new Interstate freeway has not been built in this metropolitan area since 1961 – over two generations ago. Many of the issues will have long-lasting, significant impacts on our community and we need sufficient time to review the record, research issues and concerns, and provide a substantive response.

 See more...

Tuesday, May 2, 2017

Interstate 11 Updates, April/May 2017

Public Meetings

During the first year of this three-year study that began in March 2016, ADOT evaluated a wide range of alternatives ‒ or possible routes ‒ in order to narrow the choices to the recommended range of reasonable alternatives to be evaluated further in the Tier 1 Environmental Impact Statement. These alternative corridor options will be available for review and comment at the public meetings and during a 30-day public comment period.
The final set of corridor options, which will be determined after the public comment period, will be subject to further analysis as part of the Draft Tier 1 Environmental Impact Statement. A no-build option will also be evaluated...
The public comment period will begin on April 28. That’s when the latest study and meeting materials will be posted to the Interstate 11 website at and an online mapping and comment tool will be activated. The comment period runs through June 2. The schedule for the six public meetings is here:
Tuesday, May 2
Arizona Riverpark Inn
777 W. Cushing St.
Wednesday, May 3
Marana Middle School – cafeteria
11285 W. Grier Road
Thursday, May 4
Nogales High School – cafeteria
1905 N. Apache Blvd.
Wednesday, May 10
Dorothy Powell Senior Adult Center – dining room
405 E. Sixth St.
Casa Grande
Thursday, May 11
Wickenburg Community Center
160 N. Valentine St.
Tuesday, May 16
Buckeye Community Center – multipurpose room
201 E. Centre Ave.


The following was sent in an email from Albert Vetere Lannon:

Here are the materials posted on the website late this afternoon (Friday); they are what will be presented at the public meetings.  If you open the “Meetings” link and scroll down, select the top right posterboard image, labeled “Reasonable Range of Build Corridor Alternatives Tier 1 Analysis.”
This shows three alternatives: the existing I-10 corridor (B) and two Avra Valley routes (C and D) which are close to each other and even overlap.  Note that C and D are “undergoing additional analysis,” which means they aren’t ready to talk much about them.  C and D both butt up against Saguaro Park, Ironwood, Tucson Mountain Park and the federal Bureau of Reclamation’s Wildlife Mitigation Corridor established when the CAP canal was built. 
This doesn’t show it (yet) but the County Administrator’s plan is to elevate the highway to deal with insufficient right-of-way.  (Note:  While Tier 1 looks at 2000 foot ROW corridors, they will actually need 400 feet to move forward – Sandario and Mile Wide does not give them that, hence the elevated idea.)
Alternative D gives the Tohono O’odham Nation a little more breathing space.
The fact that an I-10 alternative is still on the table is only because We, the People, have spoken out loud and clear opposing any Avra Valley route, although their materials do not reflect that; ADOT just tells us why we need I-11.

I-11 and Jobs

Albert Vetere Lannon also wrote this article recently:
Silence From Washington About Interstate 11 Jobs – In Mexico!   | Arizona Daily Independent
Another reason may be that I-11 is in sharp conflict with the stated goals of the national administration to bring American jobs home from other countries.  The “Final Purpose and Need Memorandum” justifying I-11, put online by ADOT February 28, 2017, continues its calls for “nearshoring” and “integrative manufacturing.”
 “Nearshoring” is attracting US companies from China to lower-wage Mexico.  “Integrative manufacturing” means R&D in the US with production and assembly in Mexico.  The Port of Guaymas is being expanded to steal shipping jobs from the West Coast.  Read it for yourself at, click on Arizona and then on Reports.
It is important to point out that Trump's opposition to outsourcing jobs to Mexico is guided by (racist) nationalism and politics, not concern about workers. Even if he acknowledges NAFTA's negative impact on Mexican workers, his policy is not informed by this reality, and in fact is out of touch with the reality of American workers as well.

On the other hand, neoliberalism is not the proper response to nationalism. For further discussion on this, you might check out, if you haven't already, Arizona-Mexico Trade: Inroads to private gain, Part 2: Blowing Smoke and Part 3: Shifting Border Enforcement.

Tuesday, February 7, 2017

I-11 Comments

Comments on the I-11 and a summary are available for view.

Sunday, December 18, 2016

December 2016 Updates

Some good news and some bad news.
Gila River Indian Community Files Injunction Seeking To Stop South Mountain Freeway Construction Pending Federal Appeal
December 16, 2016

SACATON, AZ. – The Gila River Indian Community on Friday filed a court motion seeking an injunction that would halt the construction of the South Mountain Freeway – and stop the desecration of lands long held sacred by Community members – pending the outcome of the Community’s and other parties’ lawsuits against the Federal Highway Administration and the Arizona Department of Transportation.


The appeals process continues on PARC's part, despite some disappointment.
And while the "center segment" which includes the mountain will not be started until summer 2018 if at all, some construction is beginning.

Preliminary digging begins on western end of South Mountain Freeway
Posted: Thursday, December 15, 2016

With a new round of legal attacks on the South Mountain Freeway slated to begin Thursday, crews have begun making major excavation on the thoroughfare’s western end.
“A 300-foot-long cut along the embankments of Interstate 10 near 55th Avenue is the first sign of construction in the West Valley for the Loop 202 South Mountain Freeway,” the Arizona Department of Transportation announced in a release last week.

Wednesday, November 23, 2016

Nov 2016 Updates

Court refuses to block construction of South Mountain Freeway

"A federal appeals court has refused to issue an emergency order to stop construction of a new Phoenix freeway.
The 9th Circuit U.S. Circuit Court of Appeal’s action Monday means construction of the South Mountain Freeway can proceed while the appeals court considers an appeal."


Benefit show for Standing Rock and No 202 Resistance

Foreign Trade Zone Sweetheart Deal for Monsanto Delayed

The Pima County board of supervisors voted to delay the decision to afford Monsanto tax breaks on the land they purchased in Avra Valley for a giant greenhouse in which to seed for GMO corn. The land lies between a proposed Interstate 11 alignment and the I-10.

Monsanto was hoping to quietly benefit from their land becoming designated as a Foreign Trade Zone (FTZ). FTZs function like inland ports in which businesses get tax breaks and duty exemptions and deferrals, as tax incentives. The presence and authority of the Customs and Border Protection (CBP) in these foreign trade zones have unknown implications for migrants within them.

See: Dozens Tell Pima County Supervisors: “Say No to Monsanto”, Pima County supervisors postpone vote on tax breaks for Monsanto, Details of Monsanto deal with Pima County are released | Government and politics, and The Big Fix and How It Works: Pima County’s “Project Corn”

Thursday, November 3, 2016

Public Opposes New Interstate 11 in Southern Arizona

This media release was sent via email from the Avra Valley Coalition.
News from the Avra Valley Coalition:             Contact: Albert Lannon, 520-622-3561,

Public Opposes New Interstate 11 in Southern Arizona

A review of the public comments gathered at five “public scoping meetings” in June, 2015, by the Arizona Department of Transportation shows a large majority favoring “enhancing or expanding existing highways and freeways” rather than building a new highway.  Written comments from the more than 500 people attending those meetings run seven to one opposing a new interstate.  Most attendees came from the Tucson-Marana area and most of  those objected specifically to a new highway through the Avra Valley as proposed by Pima County Administrator Chuck Huckelberry.

According to ADOT Community Relations Manager Laura Douglas about 150 people attended the Tucson meeting, with another 150  in Marana; Casa Grande had 51 attendees, Buckeye  53, Nogales 41, and Wickenburg 95.  An additional 300 comments were received outside of the public scoping meetings, but those are not yet available for review.  While some of the attendees thanked ADOT “for allowing all the input,” it is not clear that the voice of the public will be heard in determining the future of I-11.

Project Director Jay Van Echo acknowledged in a May 18 meeting with Avra Valley activists that there were only two possible routes, along the existing I-10 or through the Avra Valley.  According to emails obtained by the Arizona Daily Independent, the Avra Valley route as first choice was made before the $15 million Tier One Environmental Impact Study was underway.  Here is a June 10, 2016, email from Pima County Economic Development Director John Moffat to County Administrator Huckelberry and his assistant, Nanette Slusser:


While the Pima County Board of Supervisors is on record in Resolution 2007-343 opposing any I-10 bypass in Pima County, Huckelberry and his staff have been allowed to use county resources to promote the Avra Valley route, and the BOS supported the McCain-Kirkpatrick-Grijalva amendments to the FAST Act designating I-11 and its Sonoran Corridor leg, formerly named “I-11” on county maps, as interstates eligible for federal funds.

Opponents of I-11 note that planners envision a future with research and development in Arizona and Nevada and manufacture and assembly in Mexico where they believe wages will be lower than in China.  They call that “integrative manufacturing.”  They also hope to attract American companies from China to Mexico, called “nearshoring,” and to steal jobs from the West Coast to the expanding Port of Guaymas.  An Avra Valley route would hurt tourism at places like the Desert Museum and Saguaro National Park, take away Kitt Peak’s needed darkness, and lose jobs along the existing I-10 corridor.  It would also negatively impact communities and wildlife, along with ancient archeological sites.

Candidates for the Board of Supervisors Ally Miller and Kim DeMarco have publically opposed an Avra Valley I-11 route, while the other incumbents have been silent as the County Administrator beats the drums.  The Green Party candidates also oppose it, while Steve Christy – who served as chair of the State Transportation Board when the I-11 EIS was approved – favors the Avra Valley route.

The Sonoran Corridor, listed as an “auxiliary highway” to avoid the bypass conflict, was shown on county maps as I-11 and its curious configuration links with the “Huckelberry Highway” at I-19.  The Sonoran Corridor was also rejected by voters in last November’s bond election, but that hasn’t slowed down Huckelberry or BOS Chair Sharon Bronson from looking for ways to advance it.

Bronson’s opponent in the election, Kim DeMarco, along with L.D. 11 state legislators Steve Smith and Vince Leach, have publically stated their support for double-decking part of I-10 rather than ruining the Avra Valley.  That option, according to ADOT, would cost one-third that of a new highway and save taxpayers nearly $2 billion.  LD 11 State Senate candidate Ralph Atchue isn’t sure how much input state legislators will have, and prefers the highway not go through the Avra Valley.

Saturday, September 10, 2016

Meetings on the South Mountain Freeway

Excerpts of something ADOT sent out.

ADOT offers multiple ways to provide feedback, get the latest project information

Beginning later this month, ADOT will hold three public meetings to provide details and seek input on preliminary design plans:
  • Tuesday, Sept. 27, Desert Vista High School, Multipurpose Room, 16440 S. 32nd St., Phoenix
  • Wednesday, Sept. 28, Betty Fairfax High School, Multipurpose Room, 8225 S. 59th Ave., Laveen
  • Thursday, Oct. 6, Fowler Elementary School, Multipurpose Room, 6707 W. Van Buren St., Phoenix
All meetings are scheduled for 6-8 p.m., with presentations beginning at 6:30 p.m.
The meetings will provide information on the freeway’s location, profile, interchange configurations and noise barrier locations, as well as initial concepts for landscaping and visual appearance. The preliminary design has been updated since it was circulated for public comment along with the Draft Environmental Impact Statement in 2013.
More public meetings will be held later this year to share final design and construction plans and to provide more information on what to expect during construction.
As part of its commitment to public involvement, ADOT is seeking input from anyone with an interest in the freeway. There are several ways to do so:
The latest project information is available via the project website at, email and text updates (click “Subscribe for Updates” on the project website), the project hotline numbers (1.855.763.5202, or para Español, 623.239.4558) and newspaper advertising...
For more information, visit

Sunday, August 28, 2016

Judge rules in favor of freeway, opposition builds

News spread on August 19th of the late decision by federal judge Diane Humetewa in favor of the Loop 202 South Mountain Freeway and against the lawsuit. A few days later, freeway opponents had an opportunity to confront ADOT at a Ahwatukee Foothills Village Planning meeting.

Boos, chants and protests greet ADOT at Ahwatukee meeting on freeway

PARC announced it would file an appeal with the Ninth Circuit court.

Then, on Saturday, the Akimel O'odham Youth Collective posted the following:
Yesterday in a special tribal council meeting about stopping the proposed 202 freeway through Moadak Do'ag (Avikwaxòs in the Piipaash language), our elected leaders voted to file an appeal of the August 19 U.S. District Court ruling, as well as a stop-work injunction.
Later on in the meeting, several council members asked Osborn Maledon about how to strengthen our lawsuit as it heads to the appeals court. GRIC tribal members Andrew Pedro, Napoleon Marrietta and Linda Paloma Allen had prepared several suggestions to that effect. The content of our speech is posted on the Facebook pages for Akimel O'odham Youth Collective and Gila River Against Loop 202.
As a direct outcome of our speech, GRIC council made history today. The council passed a motion to request amicus curiae briefs from the sister O'otham tribes and from the Bureau of Land Management. For the first time since 1986, the GRIC government is consulting the other three members of the Four Southern Tribes about how to stop the freeway from blowing up three ridges of Moadak Do'ag/Avikwaxós.
As this case heads to appeals court, no new evidence can be introduced. The panel of three judges at the appeals court will review the same documents that Judge Humetewa reviewed. The case can now be won or lost on the basis of the added amicus curiae briefs, which can introduce new arguments. Our speech today directed GRIC council to request these amicus briefs.
As the tribe works politically to defend our lands, we know that the people will also come together culturally. We are encouraged by the support that has been coming together in the past week. As we have been directed to do by elders, we ask that you visit the do'ag if you are able to, to pray there and be with Creator there, so He knows we have not forgotten our relationship to Moadak Do'ag/Avikwaxós. If you can, bring a relative with you and leave an offering. Come back again to the do'ag and bring more people to pray with you.
In this way, we will unite culturally as our elected leadership unites politically.