This is the second in a series of discussions on seven areas of issues with the proposed Loop 202 South Mountain Freeway (SMF). To begin the series, I discussed the fact that Protecting Arizona’s Resources and Children’s (PARC’s) chances of winning in court are extremely good because of the combination of these seven areas of grounds for suing the Arizona Department of Transportation (ADOT) and the Federal Highway Administration (FHWA):

• Distortion of purpose and need for the SMF.

• Air pollution.

• Negative health effects — especially for children.

• Destruction of wells.

• Danger from hazardous materials.

• Desecration of South Mountain.

• Destruction of quality of life (noise, crime facilitation, home values).

This time I will concentrate on ADOT’s weak attempts to provide a purpose and need for the SMF. Purpose and need are the first requirements of the National Environmental Policy Act (NEPA), the governing law for the development of a new freeway. Without purpose and need, a new freeway cannot be justified.

About 30 years ago, ADOT decided on the need for the SMF and that it would be located from Interstate 10 and the Loop 202 San Tan Freeway down Pecos Road, through three ridges of South Mountain, meeting I-10 again at 59th Avenue. By 1988, ADOT began purchasing land for a right of way along 59th Avenue and along Pecos Road. Perhaps this activity could be regarded as “just in case” purchases except that ADOT has never purchased right of way land for any other possible SMF alternatives.

The problem is that NEPA prohibits ADOT from deciding the location of a freeway until they have completed an Environmental Impact Statement (EIS). The EIS is to consider all possible alternatives, including every possible location for the freeway as well as alternative forms of transportation. ADOT published the Final EIS for the SMF in September 2014. Since from the very beginning they had decided on the specifics of the SMF, it was no surprise that the EIS found “reasons” for eliminating all other possible forms of transportation and all other possible locations for a freeway. ADOT’s “reasons” are very flimsy, however, for many of the alternatives, and they will not hold up in court. For example, the current truck bypass — from I-10 at Casa Grande, west on I-8 to Gila Bend, then north on SR 85 to where it intersects with I-10 at Buckeye – was eliminated as a possibility because it is outside of Maricopa County.

Speaking of truck bypasses, it takes no genius to determine that the SMF is intended as one. With a major commercial area around 51st Avenue on the west side of South Mountain, companies like the “tank farm” are chomping at the bit to have a shortcut for their gasoline tanker trucks carrying hazardous materials (hazmats) to the East Valley. The EIS excludes tunneling through South Mountain as an alternative for the SMF because hazmats cannot use freeways with tunnels. The EIS also dismisses out of hand all alternative forms of transportation, such as light rail, that would move people around. Clearly, the SMF is for hauling freight, using hazmats as well as the big rigs of the trucking companies near 51st Avenue. Of course, ADOT has never admitted that the SMF is intended as a truck bypass because Phoenix already has one of them, and it is far outside the metropolitan area as it should be. So ADOT continues with the ruse that the SMF is intended as just another freeway.

ADOT evidently figured that they would have no opposition to their EIS, so they developed a really shoddy document. The Draft EIS that came out in 2013 used census data from 2005, rather than the readily available 2010 data, to try to support traffic projections for 2035. Considering that the traffic projection models they use are only valid for projections of about two years into the future, even once they updated the data in the Final EIS, their projections were useless. The ineffectiveness of ADOT’s long-range traffic projections was illustrated by the fact that, using the 2005 data, their projections for 2010 were off by more than 10 percent. Extrapolating 25 years into the future compounds the error five times over, so the traffic projections for 2035 could be off by more than 50 percent!

Even though ADOT has been able to manipulate one of their modeling techniques (however inappropriately) to try to “justify” a need for a freeway in 2035, they have been unable to get their models to show that the SMF would bring any of the traffic congestion relief that they promised. In their Final EIS, in Table 3-8 Regional Travel Times 2035, on page 3-34, ADOT projects that in 2035, with the SMF in place, a trip from Ahwatukee Foothills Village to Downtown Phoenix (or vice versa) would save a driver one minute! Further, the reader is supposed to be impressed by the total number of minutes that would be saved by 135,000 or so drivers!

These are but a few examples of the type of logic ADOT uses in the EIS for the SMF. With all ADOT’s missteps in the EIS regarding purpose and need well documented and well refuted by experts in traffic engineering, demographics, and modeling, PARC is well prepared to contest the SMF in court in the area of purpose and need.

Yet purpose and need is just the first area in which PARC has a winning case. My next installment will discuss the area of air pollution.

In addition to previous funding mechanisms, PARC has started a campaign on Just search for “PARC” to find and feel this new energy.

• Dr. Pat Lawlis is president of Protecting Arizona’s Resources and Children (PARC), a non-profit organization by and for the residents of Ahwatukee. Lawlis is a graduate of Arizona State University and has been a resident of Ahwatukee for more than 20 years.

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