Experts Conclude that the South Mountain Freeway Should Not be Built

Steve Brittle August 8, 2013 0

By Steve Brittle

A coalition of organizations headed up by Protecting Arizona Resources and Children, Inc. (PARC), pooling their resources to stop the proposed South Mountain Freeway, submitted their hundreds of pages of comments and exhibits to ADOT in response to the Draft Environmental Impact Statement (DEIS). This is the first step in bringing the flaws in the ADOT planning and review process to light. The plan is to challenge the South Mountain Freeway in federal court and stop it.


The comments included those from a variety of health, environmental, demographic and transportation experts and consultants, who focused on the severe air pollution and adverse health impacts the freeway would certainly cause, the noise, property devaluation, risks from accidents involving hazardous materials, environmental justice, and much more.

Other sections of the comments focus on how the conclusions of the DEIS are based on outdated (2005) and unscientific data, a systemic problem for the DEIS. Inaccurate data and faulty traffic simulations paint a false picture of tremendous benefit to Valley commuters for this $2.5 billion dollar, $100 million per mile road. When the data is current and scientific, when the proper models and methodology are used, the only reasonable conclusion is NO BUILD.

George D.Thurston, Sc.D., a health expert for the opposition to the South Mountain Freeway concluded:

“the increased exposure to residents living or going to school near to the proposed South Mountain Freeway will be at substantially increased risk of adverse health effects if the freeway is built as proposed, and I further note that these various health impacts are ignored or not sufficiently addressed in the draft DEIS. In particular, if the freeway is built as planned, children with asthma will be at much greater risk of experiencing asthma exacerbations (e.g., asthma attacks, wheezing, cough, etc.). Healthy children will be at significantly higher risk of getting new-onset asthma, and all children living near the proposed Freeway will likely have their lung growth and development inhibited from what it would have been without the Freeway. In adults, the primary health threat from the proposed Freeway air pollution will be increased risks of chronic cardiovascular illness (e.g., PAD), acute myocardial infarctions (MIs), and premature mortality.”

Another of the environmental experts noted, “The use of data, the methodology employed, and the conclusions presented in the DEIS are absolutely without technical merit and do not comply with the fundamental concepts and purpose of an environmental impact statement. The DEIS does not protect or properly inform the citizens of the level of risk to public health by building the freeway.” He added, “the Ahwatukee Foothills area north of the proposed freeway alignment will exceed both particulate matter (PM) and Carbon Monoxide (CO) standards within 100 meters (micro scale siting) from the edge of roadway of the South Mountain Freeway during adverse weather and meteorological conditions. Valley-wide pollutant concentrations will be high, and any build option will compound and intensify trapped pollution between the freeway and the mountain.”

Mountains near proposed Loop 202

Transportation experts characterized the DEIS as “fatally flawed,” and concluded, in part, “when correct socio-economic data is used, the No Action Alternative largely achieves the desired outcomes without exorbitant costs and/or negative impacts.” They also concluded, ” there is nothing in the stated “purpose” to demonstrate why the proposed freeway remedy must be built within the selected Study Area and nowhere else. In short, other reasonable alternatives exist that could also fulfill the stated Purpose and Need, but these have been arbitrarily excluded from detailed analysis in violation of 40 CFR 1502.14 [NEPA regulations].”

Pat Lawlis, President of PARC, said, “We are pleased to have the experts confirm what we suspected, and look forward to our day in court when we get the federal judge to order No Build. But I also have to wonder how something so poorly done could have cost $22 million, and taken over a decade.” According to Howard Shanker, the attorney for the group of commenters, “based on a review of the data, it appears that the DEIS is no more than a thinly veiled, very expensive attempt to manipulate the public into believing that construction of the preferred alternative(s) for the Loop 202 South Mountain Freeway is a good thing. A review of the need for the project, the science and the data, however, strongly suggests that the freeway would have significant negative impacts without relieving any of the traffic congestion currently experienced on the freeways and arterial streets in the Phoenix Metropolitan area.”

PARC has placed electronic versions of the comments on its website.

The Environmental Protection Agency also filed comments on the DEIS. Besides determining the DEIS to be vastly incomplete, EPA provided over a dozen pages of specific recommendations for proper modeling of air pollution hot spots for particulate matter and carbon monoxide, as well as for Mobile Source Air Toxics, and more.

EPA also offered to show ADOT how to use the correct models and analysis, provided a tutorial, and indicated it will closely review whatever ADOT does to make certain it gets it right. EPA also warns that if the modeling shows air pollution problems, that will prohibit the construction of the freeway.

“In view of the area’s current designation as nonattainment for PM10, it is essential to accurately assess and disclose potential PM10 hotspot impacts, as well as determine whether the project meets the transportation conformity requirements of the Clean Air Act. The Act and its implementing regulations provide that a project may not cause or contribute to any new localized violation of a national ambient air quality standard {NAAQS), increase the frequency or severity of any existing violations, or delay timely attainment of the NAAQS (CAA section 176(c)(l)(B) and 40 CFR 93.116(a)). The analysis found in the DEIS does not provide the information necessary to make an accurate determination of PM10-related impacts. It also does not sufficiently address other potential air quality issues of concern. The EPA is available to work with FHWA and other agencies to complete needed analyses as this effort moves forward.”

EPA’s comments are available on-line.

Proposed South Mountain Freeway

About The Public/Private Partnership

There are unanswered questions about that public/private partnership to Build South Mountain Freeway:

The AZ Corporation Commission website states that the formal incorporation for the South Mountain Development Group LLC is still pending, since May 2013, which means it is very new. It also means that it was not a legal entity when the unsolicited bid was submitted.

Speaking of not legal, by statute, ADOT can only consider sealed bids that are submitted after a request for bids is posted by the agency.

The math also doesn’t work. The Maricopa County Transportation Excise Tax revenues (from the 1994 election) that would pay to build (or repay the South Mountain Development Group) expire in 2016. The revenue projections indicate about $500 million, about 25% of the $2 billion cost of the South Mountain Freeway. Was this just a pork barrel project all along?

Perhaps the real truth is that after ADOT received PARC’s expert comments and the comments from EPA, it realized there would never be approval for federal money to build this freeway, so it pulled this publicity stunt to divert attention from the $22 million junk DEIS. It explains why ADOT suddenly touted the “unsolicited bid” the day after the close of comments on the DEIS.