[Note: see http://www.sanpedrorivervalley.org for the factual details that underpin these arguments.]

(1)Compared with the valleys through which all the other Bypass Alternatives would run, those designated for the San Pedro would traverse a valley which is significantly more constricted and steep-sided. This means much greater expense of construction and maintenance and much greater damage to environmental and local human interests.

(2) In the 1970s, the ADOT set into motion an effort to construct a large roadway similar to Alternative "K" (though much smaller in scale) through the entire Middle San Pedro to highway I-10, as a way to facilitate local economic interests. It was abandoned only after major taxpayer expenses had been incurred and the scale and environmental problems involved in the enterprise were belatedly recognized.

(3) Upland landforms and lifeforms near and north of the Tres Alamos Wash,  part of the Chihuahuan Desert and Apache Highlands Ecoregions, are sustained by both the river and the corridors that crosscut it. In the floodplain, rare Fremont Cottonwood/Goodding Willow Gallery Forest supports large populations of birds and other wildlife. Either the "D" or "K" Alternative routes would damage the integrity of this life-support system.

(4) The Redington Sub-Area of the Middle San Pedro River watershed narrows like a funnel into a long, side-constricted valley where Interstate-type road construction must either cut through the floodplain and its immediate margins, or cut through the adjacent uplands on either side. Any of these alternatives are unacceptable, both for gross economic reasons and for the devastation of life-corridors they would create. Here, as the valley constricts, the number, frequency, and complexity of cross-cutting corridors begins to multiply, as would the range of radiating side-effects from massive road construction.

(5) Near the Kelsey Canyon crossing of the Cascabel Road, and northward through the Teran Wash crossing, the cross-cutting ecological corridors become larger and the adjacent uplands even closer, and the obvious economic/ ecological/human costs would further multiply.

(6) In terms of "Central-place" theory, the Cascabel Central corridor intersection complex  -- where Chihuahuan Desert, Apache Highlands, and Arizona Uplands division of the Sonoran Desert meet the distinctive riparian zones of the river – fulfills every criterion of indispensibility from a desert ecosystem point of view. Destroying this nexus would be a mindless act of devastation.

(7) Hot Springs Canyon is an unpredictable, dynamic -- and on occasion quite dangerous -- water-and-debris carrier, which sometimes displays highly destructive power. For safety, it would require very expensive and elaborate bridges to cross it, both in the floodplain (and to greatly magnified degree) in crossing the adjacent very rugged uplands. On the other side of the constriction, Paige Canyon can (and just a few years back, did) dump a temporary dike across the entire river floodplain, causing the San Pedro River to back up for days until rising floodwaters cut through the dike.

(8) Interstate Highway construction in the vicinity of Soza Mesa would be both builders' and maintainers' nightmares, repeatedly facing the closest geohydrological metaphor of the volcanic Lahar -- that is, floods churning massive loads of rock and trees in with (and thickening) the water. And to speak ecologically only of Soza Mesa, it forms a unique and highly rich -- while very inconspicuous -- nesting place for impressive varieties of plants and animals. Any suggestion to build a roadway across any part of this at once dangerous and valuable tableland seems preposterous.

(9) the argument presented in (6) above applies equally well to the western side of the valley at this point: in the uplands, multiple bridgings would be required; in the floodplains, a freeway on high, massive stilts...

(10) At Milepost 31, the San Pedro River rises again as perennial stream, rich in fish, migratory fowl, the suites of creatures who rely on such zones. The Redington Narrows forms a tight bottleneck that can back up debris-laden waters during heavy floods, which would seem to preclude roadways in the floodplain here. The adjacent uplands remain rugged and would be expensive to cross with a big highway.

(11) The Redington Corridor complex links important natural corridors, one traversing a Nature Preserve and the other extending into imposing federally-designated Wilderness. At this point the valley widens sufficiently that building a Bypass would probably not be quite so expensive as (and perhaps slightly less ecologically damaging than) would obtain in the corridors a short distance upstream, but the very fact that Redington has more flat (much of it private) land means that an off-ramp nexus would likely be designated here, followed by urbanization. The now-primitive linking uplands of Redington Pass would soon be paved, and the vital ecosystem once symbolized by the Bellotta Ranch would be ruined.

(12) Summary Judgements and Recommendations:

As you can see from the preceding presentation, the San Pedro Valley is not only special to us, but to the people of the state and the nation. As such, many government agencies, at the city, county, state, and federal level, have invested heavily in maintaining the ecological integrity of the valley. The proposed bypass would heavily damage the fruits of these efforts and subsequent associated developments would destroy them. In addition, -- and this is a major point we have not previously made here -- some of the investments in conservation have been made as part of formal mitigation arrangements to compensate for the loss of riparian habitat associated with water developments in other parts of the state. The proposed bypass would contribute to hydrologic dysfunction in the watershed, and associated developments would lead to the depletion of the aquifer that feeds the San Pedro. The proposed I-10 bypass, if built, would nullify the benefits of the mitigation purchases by destroying the context in which they were made. The result would be a cascade of complications statewide.

Regionally, southeastern Arizona from I-10 to the Gila River represents a landscape not yet fragmented by development. Not only is the San Pedro Valley a key national scale migration corridor south to north, but also it is a key way station in migrations east/west between sky islands. We have reviewed the geology of the region and described the patterns of tributaries to the San Pedro that are so crucial to the wildlife movement to and from the river in the cross river corridor. The section of the valley where it narrows, between Teran Wash and Redfield Canyon, is particularly vulnerable to such fragmentation with no way to build an interstate without serious damage. The destruction of the east-west cross river movement of wildlife cannot be mitigated by a few large bridges because of the multitude of smaller washes and tributaries that are biologically important. The health of the river depends on the health of the watershed that supports it and conversely the health of the watershed depends on the health of the river because of the self-regulating interaction of the wildlife populations. The proposed by-pass would disrupt these connections with regional consequences.

Globally, the Arizona Department of Transportation cannot ignore that well within the lifetime of the proposed bypass, fossil fuel shortages will be chronic and the price of fuel will be high. The EPA has declared that C02 can be regulated as a pollutant and that consequences of globally warming are already being felt and will accelerate. This is the context in which the proposal is being made. To say no to the I-10 bypass is to say no to the fossil-fuel dependent, global warming policies of the Twentieth Century, and to say yes to planning for an alternative, more sustainable Twenty-first Century. The ADOT I10 Bypass study is far too narrowly conceived. We need to look at how we in Arizona want to live in a future of limited oil and global warming and to discover what infra-structure best fits this future.