Pima County, Arizona
Board of Supervisors
Ann Day, District 1
Dan Eckstrom, District 2
Sharon Bronson, District 3
Raymond J. Carroll, District 4
Richard Elias, District 5
County Administrator
Chuck Huckelberry

Table of Contents
Chapter One
Introduction to Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Chapter Two
The Diversity of Cultures in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Chapter Three
Air Quality and Transportation in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Chapter Four
Water Quality and Supply in Pima County

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Chapter Five
Locations of Industry, Landfills, Roads, and Other Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
Chapter Six
Land Use and Housing Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
Chapter Seven
Fiscal Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65
Chapter Eight
Cultural and Environmental Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
Chapter Nine
Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
Appendix A
Principles of Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87
Appendix B
Federal Executive Order on Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88
Appendix C
Declaration of Intent to Cooperatively Participate
In the Sonoran Desert Conservation Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93
Appendix D
1974 Projected Costs of Alternate Plans for Growth . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94
Appendix E
Sources of Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

Figures
Fig. 1-1
Fig. 1-2
Fig. 2-1
Fig. 2-2
Fig. 2-3
Fig. 2-4
Fig. 2-5
Fig. 2-6
Fig. 2-7
Fig. 2-8
Fig. 3-1
Fig. 3-2
Fig. 3-3
Fig. 3-4
Fig. 3-5
Fig. 3-6
Fig. 3-7
Fig. 3-8
Fig. 4-1
Fig. 4-2
Fig. 4-3
Fig. 4-4
Fig. 4-5
Fig. 4-6
Fig. 4-7
Fig. 4-8
Fig. 4-9
Fig. 4-10
Fig. 4-11
Fig. 4-12
Fig. 4-13
Fig. 4-14
Fig. 4-15
Fig. 5-1
Fig. 5-2
Fig. 5-3
Fig. 5-4
Fig. 5-5
Fig. 6-1
Fig. 6-2
Fig. 6-3
Fig. 6-4
Fig. 7-1
Fig. 7-2
Fig. 7-3
Fig. 7-4
Fig. 9-1

Average Age of Mortality among Groups in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Community Stress Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Racial-Ethnic Composition of Pima County Population in 2000. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Racial distribution in Pima County 1990. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Racial distribution in Pima County 2000. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
The Traditional O’odham Homeland . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Downtown Tucson in 1883. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Part of downtown Tucson in 1918. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
A typical FHA-approved neighborhood layout in 2000. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Tucson’s barrios. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Air pollution sources in Pima County 2001 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Means of Transportation to Work, Pima County 1990-2000. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Air pollution and former pollen monitoring sites in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Public transportation service in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Carbon Monoxide (CO) 8-hour concentrations in ppm. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Ozone one-hour average mean levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Particulates (PM10) Annual Average . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Nitrogen Dioxide (NO2) Annual Mean. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Major water providers in Pima County. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
Major water wells in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Stylized diagram of a cone of depression . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
Tucson’s TCE plumes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Where TARP water is delivered. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Where CAP water was delivered in 1992 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Where Tucson Water intends to distibute the Clearwater blend of CAP
and Avra Valley water by 2003 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Polluted groundwater areas listed as Superfund Sites or WQARF sites . . . . . . . . . . . . . . . . . . . . . . . . 33
Tucson Water Quality Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Average hardness of Tucson Water at various zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Average nitrate levels of Tucson Water in various zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Average fecal coliform levels of Tucson Water in various zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Average trihalomethanes in Tucson Water at various zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Potential land subsidence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
Tucson Water supply as a percentage of demand for 2003 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Industrial zoning in Tucson and Pima County. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
General location of facilities with hazardous waste permits
from Pima County Department of Environmental Quality.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
Major wastewater facilities in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
Present and Historic landfills in Pima County. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Neighborhoods directly affected by construction of I-10 and I-19 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
Generalized zoning map of Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
Buying power in 1962 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Income distribution in Pima County in 1990. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59
City and County Parks in Eastern Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
Population growth in Pima County in incorporated and unincorporated areas. . . . . . . . . . . . . . . . . . . 69
Housing costs by percent change in Pima County and Tucson. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70
Residential housing sales in Pima County 1989-2001 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
Poverty rate by school district in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73
Draft Sonoran Desert Conservation Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82

Tables
Tab. 3-1
Tab. 5-1
Tab. 6-1

Pima County pollen control ordinance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Present and historic landfills in Pima County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
Pima County and City of Tucson Selected Zoning Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

ACKNOWLEDGMENTS
Many thanks to the following people who provided helpful
information and/or commented on the draft document
Diane Austin, University of Arizona, Bureau of Applied
Research in Anthropology
Raúl Grijalva, Pima County Supervisor
Richard Grimaldi and Frances Dominguez, Pima County
Department of Environmental Quality
Chris Leverenz, City of Tucson, Division of Solid Waste
Management
Linda Mayro and Roger Anyon, Pima County Cultural Resources
Paul Matty, Pima County Wastewater Management Department
Librarian
John Regan and Bill Tanksley, Pima County Technical Services
Tom Victory, Tucson Water
Claire Zucker, Pima Association of Governments
The cover photos depict outdoor art in the Tucson area from a
variety of locations and by various artists. Locations include South
Tucson, El Rio Neighborhood Center, downtown Tucson, Pueblo
Gardens, Tucson Urban League, North Stone Avenue, South Sixth
Avenue, and the Santa Cruz River Linear Park.

Chapter One
Introduction to Environmental Justice

T

“Environmental justice should comprehend the claims of poor communities because they
suffer from economic disadvantage, communities of color because they have chronically
been victims of discrimination, and tribal communities because they typically have been
denied full protection of their rights to culture and self government under the law.”
Getches and Pellow 2002

he goal of the national environmental justice
movement is to assure that minority and lowincome people do not suffer disproportionately from actions such as siting of landfills, air
pollution, contaminated water, toxic waste, and other
environmental pollution problems. In recent years
the concept has begun to spread to other governmental actions, such as land use more generally.
Although the environmental justice movement had its
origins in African-American churches and has been
centered around racial inequities, some people in the
field believe that income levels are a more significant
factor in determining environmental justice.
The purpose of this report is to look briefly
at past and present situations where disadvantaged
groups in Pima County have been disproportionately
impacted by water and air pollution and the impacts
of sprawl and to ask how the Sonoran Desert
Conservation Plan (SDCP) might impact those people in Pima County. The first eight chapters examine
specific issues and impacts in the past and present.
Chapter Nine summarizes conclusions and the possible positive and negative environmental justice
impacts that the SDCP may have in each of these
areas.
An analysis of the impacts of the SDCP on environmental justice is required as part of the SDCP
Environmental Impact Statement, but this analysis
will go beyond what the federal government requires.
This report includes cultural, social, and fiscal issues.
In looking at unjust situations, it is often not easy
to determine cause and effect. If more low-income
people live near industrial areas than do high-income
people, is this because the industry was intentionally
sited in a low-income area, or because the cost of
housing is lower near industrial areas?
This report does not address all possible civil
rights issues, but only those that could be affected by
decisions made as part of the SDCP. The SDCP is
not designed as a vehicle for correcting past envi-

ronmental wrongs, but part of its mission is to
assure that the plan does not create new inequities.
The SDCP cannot address wrongs against Native
Americans of the 19th century, for example, but may
offer some benefits to Native Americans today.
Two basic questions have a central role in environmental justice analysis:
1. Was the action taken because decision makers
considered the impacts of the disadvantaged groups
less important than they would have been if the
group were high income? For example, is industry
more often located in minority areas? If so, is this
because the land was cheaper, the people didn’t protest, or because it was close to potential employees?
How much do zoning codes affect location of facilities? In Pima County there are only a few areas
where new industry can be located without a zoning
change.
2. Is the official response to an action or incident different because the affected group is low
income or minority? For example, would elected
officials have taken the TCE pollution in Tucson
more seriously at an earlier date if it had occurred
in the high income, predominately white foothills
area rather than in the low income, predominately
minority areas near the airport?

Definitions of Race and Ethnicity

The dictionary defines “race” as “a local geographic or global population distinguished as a more
or less distinct group by genetically transmitted
physical characteristics.” It defines ethnicity as
“a social group within a social or cultural system
that claims or is accorded special status on the base
of complex, often variable traits such as religious,
ancestral, linguistic, or physical characteristics.”
Race is in many ways an arbitrary way of classifying human beings and the definitions are a subject
of debate among anthropologists. The U.S. census
has gone from only two classifications – “White”

1

and “Negro” to a multiplicity of classifications in
the 2000 census. “White” usually refers to people
of European heritage, but often excludes people of
Spanish European heritage who fall into their own
category. “White” includes people from a wide
range of European backgrounds from Central Russia
to the Mediterranean and Scandinavia. Ethnic
groups within this category include Greeks, Italians,
etc. Locally, the term “Anglo” refers to people of
European heritage other than Hispanic. Hispanic
(under various names such as Spanish, Latino,
Mexican, or Chicano) generally includes anyone with
a Spanish (or often also Portuguese) surname or with
a portion of such ancestry, whether from Europe,
South America, the Philippines, or Tucson. This
only became a separate census category in the mid20th century and is treated in the 2000 census as an
ethnic group rather than a race. Native Americans
are usually grouped into one category instead of recognizing the multiplicity of heritages they represent.
Similarly the term “Black” or “African-American”
refers to people at least partly of African heritage
from areas south of the Sahara Desert, although they,
too, represent a multiplicity of heritages. Finally,
large numbers of Americans are a mixture of more
than one of these categories, although traditionally
a person with a partially minority heritage has been
classified with the minority group rather than as
“White” except in some Caribbean countries where
part White is classed as “White.” For the first
time in 2000 the census included a classification
of “mixed.” Classification by color is especially
misleading. “Blacks” come in shades of brown to
beige and “Whites” come in shades of beige. We no
longer refer to “Red Indians” or “Yellow Chinese”
but these were common terms in the past. For the
purposes of this report, we use the U.S. census classifications of “minorities” or “White.” It should be
noted, however, that internationally “White” is not
the majority group.
Definitions of Environmental Justice
Environmental justice has been defined generally
as the pursuit of equal justice and equal protection
under the law for all environmental statutes and regulations without discrimination based on race, ethnicity, and/or socioeconomic status. This concept applies
to governmental actions at all levels — local, state
and federal — as well as private industry activities.
Some more specific definitions are below.

2

Environmental Justice is the right to a safe,
healthy, productive, and sustainable environment for
all, where “environment” is considered in its totality
to include the ecological (biological), physical (natural and built), social, political, aesthetic, and economic environments.
Environmental justice refers to the conditions in
which such a right can be freely exercised, whereby
individual and group identities, needs, and dignities
are preserved, fulfilled, and respected in a way that
provides for self-actualization and personal and community empowerment. This term acknowledges environmental “injustice” as the past and present state
of affairs and expresses the socio-political objectives
needed to address them.
Environmental Equity is an ideal of equal treatment and protection for various racial, ethnic, and
income groups under environmental statutes, regulations, and practices applied in a manner that
yields no substantial differential impacts relative
to the dominant group—and the conditions so-created. Although environmental equity implies elements of “fairness” and “rights”, it does not necessarily address past inequities or view the environment broadly, nor does it incorporate an understanding of the underlying causes and processes.
Environmental Racism is “Racial discrimination
in environmental policy-making, enforcement of regulations and laws, and targeting of communities
of color for toxic waste disposal and siting of polluting industries,” according to Reverend Benjamin
E. Chavis, Jr., Ex-Chairman of the NAACP. Racial
discrimination can be intentional or unintentional and
is often a manifestation of “institutional racism.”
This term acknowledges the political reality that created and continues to perpetuate environmental inequity and injustice.
Environmental Classism is the results of and the
process by which implementation of environmental
policy creates intended or unintended consequences
which have disproportionate impacts (adverse or beneficial) on lower income persons, populations, or
communities. These disparate effects occur through
various decision-making processes, program administration (e.g. Superfund clean-up schedules), and the
issuance of regulatory actions such as compliance
inspections and other enforcement measures such as
fines and penalties, and administrative and judicial
orders. Flawed policies formation processes coupled
with agency norms, priorities, traditions, and profes-

sional biases often make implementation subject to
these disproportionate consequences. (Bryant 1995)
Principles of Environmental Justice
In 1991 people from many nations met to discuss environmental justice issues in the People of
Color Environmental Leadership Summit. The group
adopted seventeen principles which are listed in full
in Appendix A. The principles most relevant to this
report are numbered at the end of each in the order
they appear in the statement:
Environmental justice affirms the sacredness
of Mother Earth, ecological unity and the interdependence of all species, and the right to be free from
ecological destruction. (1.)
Environmental justice demands that public
policy be based on mutual respect and justice for
all peoples, free from any form of discrimination or
bias. (2.)
Environmental justice mandates the right to
ethical, balanced and responsible uses of land and
renewable resources in the interest of a sustainable
planet for humans and other living things. (3.)
Environmental justice must recognize a special legal and natural relationship of Native Peoples
to the U.S. government through treaties, agreements,
compacts, and covenants affirming sovereignty and
self-determination. (11.)
Environmental justice affirms the need for
urban and rural ecological policies to clean up and
rebuild our cities and rural areas in balance with
nature, honoring the cultural integrity of all our communities, and providing fair access for all to the full
range of resources. (12.)
Environmental justice calls for the education
of present and future generations which emphasizes
social and environmental issues, based on our experience and an appreciation of our diverse cultural
perspectives. (16.)
Chapter 9 of the report looks at how the Sonoran
Desert Conservation Plan fits in with these principles.
Beginnings of
Environmental Justice
Environmental justice had its beginnings in the
speeches of leaders such as Martin Luther King who
claimed that people of color were more often targeted for undesirable facilities and suffered from the
impacts of pollution more often than whites.
The catalyst for the Environmental Justice was a

small, low-income, predominately African-American
community in the south, Warren County, North
Carolina. In the 1970s a landfill was planned on
those lands to be used for the disposal of PCB contaminated soil, removed from 14 sites throughout the
state. Many demonstrations occurred to protest this
landfill.
At the request of congressman Walter Fauntroy,
the US General Accounting Office conducted a study
of eight southern states to determine the correlation
between the location of hazardous waste landfills and
the racial and economic status of the surrounding
communities. The results showed obvious bias in the
placement of the landfills: three out of every four
landfills were located near predominantly minority
communities.
Another study found that three out of every
five African-Americans and Hispanics live in a community where there are unregulated toxic waste sites.
The commission also noted that African-Americans
were heavily over represented in areas with the greatest number of toxic waste sites. While race plays a
great part in determining the location of hazardous
waste landfills, the study found that economic status
is also important.
Closely following this was a study by the
National Law Journal. It found that the
Environmental Protection Agency (the EPA) took
20% longer to cite abandoned polluted sites in
minority communities as a priority, as compared to
the time it took the EPA to prioritize sites in white
communities. It also noted that polluters of minority
communities paid fines 54% lower than polluters of
white communities. This led to major changes in
federal policy. (Bryant 1995)
Federal Policies on Environmental Justice
In February 1994 President Clinton issued an
Executive Order directing federal agencies to take
environmental justice into account when taking
actions that might affect minority and low-income
populations. This begins with the following goal:
“To the greatest extent practicable and permitted by law, and consistent with the principles set forth In the report on the National
Performance Review, each Federal agency
shall make achieving environmental justice
part of its mission by identifying and
addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies,

3

and activities on minority populations and
low-income populations in the United States
and its territories and possessions, the
District of Columbia, the Commonwealth of
Puerto Rico, and the Commonwealth of the
Mariana islands.”
The full Order is in Appendix B.
As a result of this order, federal agencies developed policies on environmental justice. The U.S.
Environmental Protection Agency plays a major role
in this effort and has adopted a policy with includes
the goal to assure that:
“No segment of the population, regardless of
race, color, national origin, or income, as a
result of EPA’s policies, programs, and activities, suffers disproportionately from adverse
human health or environmental effects, and all
people live in clean, healthy, and sustainable
communities.”
Environmental justice is now one of the many factors
that must be considered in Environmental Impact
Statements.
In 1997 the federal Council on Environmental
Quality issued guidance on environmental justice for
federal agencies. When stating the general principles
CEQ cautioned that each community or part of a
community has its own history and situation and
studies must be sensitive to the needs of each par-

ticular situation.
Environmental Justice Organizations
in Pima County
The most active environmental justice organization in Pima County has been Tucsonans for a Clean
Environment (TCE). This group formed around the
issue of TCE contaminated water on the south side.
(see Chapter 3) TCE joined forces with Toxic Waste
Investigative Group (TWIG), a Maricopa County
based group involved with similar issues in that
area. Local environmental groups have been slow to
become involved in these issues. The Sierra Club
has been involved in toxics issues throughout the
state, but has not specifically focused on issues related to environmental justice. In the 1970s the Group
Against Smelter Pollution (GASP) was instrumental
in improving air quality by achieving tighter regulations on smelters and in some cases having smelters closed. The Arizona Lung Association has also
been instrumental in improving air quality generally.
Jeanne Clarke in a 1998 article asserted that the
environmental groups have been remiss in not joining forces to deal with issues such as landfill siting
on Tucson’s south side. (See Chapter 3) She also
shows the importance of two Hispanic elected officials in Pima County in bringing these issues to
public attention and achieving change. Other groups

Fig. 1-1. Average Age of Mortality among Groups in Pima County
Source: Pima County Health Department

4

5

Fig. 1-2. Neighborhood Stress Index. Source: City of Tucson Planning Department.

that have been involved in specific issues are the
Environmental Justice Action Group which was
involved in the Brush Wellman situation (See chapter
five) and the Southwest Network for Environmental
and Economic Justice.
Health, Social Issues,
and Environmental Justice
The health of various ethnic groups varies greatly. Fig.1-1 shows the average age at death for the
major ethnic groups in Pima County. This ranges
from 81.2 for white females to a low of 51.1 for
Native American males. Does it, however, follow
that environmental factors are the cause of this disparity? No, many other factors influence longevity.
American Indian and black children between the
ages of 14 and 24 have a much higher mortality rate
than Asian or non-Hispanic white children. Blacks
get AIDS at a rate about three times the average
for all Arizonans. Non-Hispanic whites are more
likely to die of coronary heart disease than all other
ethnic groups, but less likely to die of diabetes which
disproportionately affects the O’odham. Whites are
less likely than blacks to die of homicide but more
likely to die of suicide.
The role of environmental pollutants is very difficult to separate out from the many other causes
of disease and injury. Genetics, life style, access
to medical care, inadequate diets and many other
factors come into play. Epidemiological studies may
reveal a cause and effect relationship between a pollutant and an effect, but this is often difficult to
determine. Extraneous factors such as age, occupation, and life style have to be sorted out from the

6

potential environmental cause. Mobility of contemporary people complicates matters because people
are exposed to a variety of possible causative agents
in different locations. Sample size is critical. The
number of people to be studied after those who do
not qualify for various reasons may be too small
to draw conclusions. Anecdotal information is inadequate to draw proper conclusions, especially in cases
where there may be more than one explanation of an
effect. (Talbot 1995)
The City of Tucson Planning Department produced a report on community stress and a map of
indicators of stress in the community to assist with
the Community Block Grant program. (Fig. 1-2)
The criteria for determining stress levels included
factors such as percentages of minors and seniors in
the area, problems speaking English, disability, poverty, unemployment, crowding, sanitation, and age of
housing. The areas with the greatest indicators of
stress are predominantly low income and minority
areas. Compare with Figs. 2-3 and 6-3.
Zero Population Growth did a similar study for
metropolitan areas in the United States in 1988
(Urban Stress Test) that used different criteria to
determine stress including violent crime, air quality,
education, poverty level, water quality, rate of population growth, and crowding. At that time Tucson
was average with a rating of 3.5 out of 5. The 2001
version of that study is called “Kid Friendly Cities”
and the same general criteria are used along with
new ones such as parks. This time the Tucson area
earned a B+ while the Phoenix area earned a C-.
That study looked at metropolitan areas as a whole
and did not look at regions within urban areas.

Chapter Two
The Diversity of Cultures in Pima County

“One thing I really miss about the Old Drachman is that courtyard. There were some
beautiful rose bushes that just bloomed their hearts out, and they never had any care. … in
that courtyard a lot of things took place. I remember the Cinco de Mayo celebrations. The
children would dance, and there would be lots of paper flowers …” Kelly 2000.

T

here are numerous examples of past environmental inequities in Pima County some of
which affect the health and welfare of lowincome and minority residents to this day. The
major ones are described below. Because of the
way Tucson grew, low-income and minority residents
have a greater possibility of living in areas where
the groundwater and soil are contaminated by old
landfills, industrial pollution, and hazardous waste
sites. This is because what was once the edge of
town may now be a neighborhood with lower land
values where the cost of living is lower. Within city
limits 19.2% of the population is below the federally
established poverty level while in Pima County as a
whole, 15.2% is below that level. Nearly two-thirds
of those below the poverty level are under the age of
18. (U.S. Census)
Higher income people have in most cases chosen
to live in areas which are now the outskirts of town
without a history of pollution. Industrial sites

tend to be along the transportation routes which traverse some of the low-income neighborhoods. Some
established low-income minority neighborhoods were
affected severely by construction of the freeway, construction of the city-county government buildings,
and by urban renewal and construction of the Tucson
Convention Center, as discussed below.
Changes in Racial and Ethnic
Distribution in Pima County Over Time
The various groups have arrived in Pima County
at different times and for very different reasons. This
affected housing patterns and racial interactions. Fig.
2-1 shows the current percentages of racial/ethnic
groups in Pima County. Figs. 2-2 and 2-3 show
racial distribution in Pima County in 1990 and 2000.
For the purposes of this report, the only differences
mapped are “white” and “minority.” It is clear that as
the community has expanded, most of the new fringe
areas continue to have very low minority population

Other (1,930)

Fig. 2-1. Racial-Ethnic Composition of Pima County Population in 2000.
Source: U.S. Census

7

Fig. 2-2. Racial distribution in Pima County 1990. Source: U.S. Census

8

9

Fig. 2-3. Racial distribution in Pima County 2000. Source U.S. Census.

Fig. 2-4 The Traditional O’odham Homeland.
Source: Adapted from Tohono O’odham: History of the Desert People.
levels. Also see figures 6-3 and 6-4 for maps of
income levels in Pima County.
O’Odham
For thousands of years the only inhabitants of
the area were various Native American groups. The
O’odham have been in the area for many, many centuries or as they say “since the dawn of time.” The
O’Odham themselves and many historians consider
them to be descendants of the Hohokam people,
although there are other theories. The ancestral homeland at the time of Spanish arrival included much of the
land south of the Gila River from the San Pedro River
to the Colorado River. It also extended into Mexico
south to the Rio Sonora. (Fig. 2-4) The Spaniards
occupied specific places within that homeland (usually
prime locations where there were reliable water supplies), but the O’Odham continued to occupy most of
the entire area. When Arizona became part of the
United States, the O’odham homeland was split between
Mexico and the United States. Subsequently, the Anglos
occupied much of the O’odham homeland within the
United States. In 1864 the U.S. set aside the first
O’odham lands – about 5 square miles at San Xavier. In
1874, President Grant set aside some 71,090 acres for
the O’odham establishing the San Xavier Reservation.
10

In 1890 41,000 acres were allotted to 291 individuals
there. Subsequently the U.S. Government established
the Gila Bend Reservation but later took more than
12,000 acres away from it. In 1912 the Ak-Chin
Reservation was established and in 1916 President
Wilson set aside 3.1 million acres for the Papago
Reservation, with its headquarters at Sells, but in 1917
took back 475,000 acres. This land was returned during
the Depression. Additional lands were added at various
times, but in 1937 the government took 520 acres for
Organ Pipe National Monument. Subsequently, the size
of the reservation was reduced even more for the Cabeza
Prieta Game Range and Luke-Williams Air Force Base
(including the Goldwater Bombing Range). In 1951 the
O’odham petitioned the U.S. government for payment
for land taken and in 1968, the U.S. government paid
the O’odham $26 million for lost lands. The O’odham
Tribe’s (then Papago) 1985 book on O’odham history
has a lot of good information.
Apaches
The Apaches are an Athabaskan-speaking people
closely related to tribes in northwest Canada and
Alaska. These tribes were nomadic, moving towards
food supplies such as caribou. For unknown reasons,
probably related to the search for food, groups of

Athabaskan people moved south and eventually
reached the southwest United States in the 16th
century. Some of these people settled in the Four
Corners Area and became known as “Navajo.”
Others moved farther south – what we know
today as the Chiricahua Apaches, the San Carlos
Apaches, the White Mountain Apaches, and others.
For the most part the Apaches continued their
nomadic lifestyle augmented by horses that the
Spaniards had brought to the area. Their nomadic
lifestyle came into conflict with the lifestyles of
the O’Odham who lived in villages. Apaches often
lived in the mountainous areas, coming to the valleys to seek food and raid the local tribal groups,
Spanish settlements, and later Anglo settlements.
The U.S. government settled the Apaches onto reservations in east central and northern Arizona –
the San Carlos Apache Reservation and the White
Mountain Apache Reservation and some were sent
to Florida or Oklahoma at the end of the nineteenth
century. A detailed book on the Apaches is James
L. Haley’s Apaches : a History and Culture portrait.
Hispanics
The first Spanish forays into the area were
in the mid-16th century, but it was not until the
late 17th century the first Spaniards began to settle
in the area, but their numbers were very small
compared to the O’Odham. Some of the original
Spanish founding families became a wealthy elite
who formed the basis for a group of influential
Hispanic families over the years. When Pima
County became part of the United States in 1854,
Mexican settlers began to migrate north hoping for
a better life, a trend that continues to the present.
By the time the first Anglos settled in the area after
1854, Hispanics and Native Americans dominated
Pima County, but intermarriage between Anglo
men and women of the upper class Spanish families was relatively common. Sheridan’s book Los
Tucsonenses provides a wonderful description of
the Hispanic community from 1854-1941.
Anglos - Whites
A few intrepid explorers from the United States
entered Arizona as early as the 1820s, but it was
the 1848 California Gold Rush that brought them
traveling through in droves. After the Gadsen
Purchase in 1854 more Americans came to stay,
but it was not until after the Civil War and arrival

of the railroad that Anglo numbers increased rapidly until they became the majority population in
the early twentieth century which they continue to
be to this day, although the percentages have begun
to decrease. Sonnnichsen’s 1982 book describes
the history of Tucson and its cultures, with emphasis on the spread of Anglo culture in the area.
African-Americans
A few Africans arrived with the Spanish
Conquistadors. The start of Afro-American immigration, however, really began with people who
came to the area as Buffalo Soldiers in the 1860s.
Some of them stayed or returned as the years progressed and slavery was abolished in the United
States. Many intermarried with other minority
groups. With the increased development of agriculture in the early 20th century other AfricanAmericans came to work in the fields. Some
worked as domestics and often lived at their
employers’ home. Another wave of AfricanAmericans arrived after World War II when people
of many races settled in Tucson where they had
been stationed during the war or where they had
worked in the aircraft industry. Lawson’s two volume history of African Americans in Tucson is a
wealth of information. (1996 and 2000)
Chinese
A few people of Chinese heritage came to the
area to work mines and even more arrived along
with the railroad which they had helped to build
in the 1880s. These people tended to be vegetable
farmers and merchants. The first Chinese settlement was on the west side of the Santa Cruz River
near Solomon Warner’s mill and the agricultural
fields. By 1880 most Chinese lived along Main
Street near Pennington but by 1900 the original
settlement began to be deserted and Chinese lived
along Main Street as far south as Cushing Street.
Tucson never developed a true “Chinatown” as
so many other western cities had. Chinese markets were an important part of Tucson life into
the twentieth century. Lister’s 1989 book on the
Chinese community provides much information.
Yaquis
For centuries, the Yaqui have lived along the
Yaqui River in the state of Sonora where they farmed
in small communities. They came into contact with
the Spaniards in the mid 16th century. By 1700 the

11

different ethnic groups participated in the first
festival.

Fig. 2-5. Downtown Tucson in 1883,
based on the Spanish town layout.
communities had organized into eight towns with
a unified governmental structure. In 1887 Yaquis
started coming to Arizona to escape political turmoil
in Mexico. The major Yaqui communities were in
the Tucson area and in Guadalupe, near Phoenix. In
1964 the federal government established the Yaqui
Reservation on Tucson’s southwest side and in 1978
they were officially recognized as a tribe. Pascua
Village, however, continues as a major Yaqui community just north of downtown Tucson.
Other Ethnic Groups
People of many other heritages live in the
Tucson area: Vietnamese, Japanese, South Pacific,
Armenian, and others. The Tucson Meet Yourself
Festival, first organized in the 1970s, was a celebration of the diversity of cultures in the area and 40

12

Changes in Housing
Patterns over Time
In the early days Tucson was small and people lived within walking distance of each other
and the stores and workplaces. The town was
laid out as a typical community, combining elements from Spain and Mexico. Adobe was
the most common construction material. House
fronts were at the street, with no front yards,
but many homes had gardens in the rear or in
interior courtyards. In many cases the houses
were connected row houses. The town layout
also followed the Spanish pattern, in which a
central plaza was the community meeting place.
In Tucson as in many other western towns, there
were also smaller plazas that served as meeting
places. Fig. 2-5 shows the layout of Tucson in
the Spanish period.
Spanish architecture prevailed until the early
20th century when architectural styles common
in places like New England began to dominate
the town.
Houses were mostly built of brick
or wood and set back from the street with front
yards and back yards, but no interior courtyards.
They often had outside porches and gabled roofs.
The Anglos preferred detached houses on large
lots rather than row houses. Fig. 2-6 shows the
layout of Tucson in the early Anglo period.
The major streets ran east and west, with some
important north-south streets such as Main Street
(Camino Real) which was originally the main route
from Tucson to Sonora. Other north-south streets
developed over time as the community expanded
north of Speedway. (Maclaury 1989). Oracle Road,
for example, had a bridge for crossing the Rillito
where the paving stopped although the road went on
unpaved all the way to Phoenix in the early 1900s.
As growth extended to the east, Broadway and
Speedway became major east-west thoroughfares
that allowed people to live farther and farther from
downtown. The town basically remained on a grid
street pattern until the development of suburbs and
planned developments after World War II. A new
street pattern emerged in many of these new areas–
one that featured curved streets and cul-de-sacs. Fig.
2-7 shows a typical neighborhood in the 1990s. This
type of layout is discussed more in Chapter 6.
Nationally the civil rights movement began to

open doors for racial equality
after World War II. The
Supreme Court made rulings
about equality in transportation,
employment, schooling, housing, and other areas. These rulings, of course, affected racial
equality in Pima County and
schools were integrated, as
were other aspects of life.
Housing patterns, however,
changed much more slowly and
were affected both by prejudice
and by income levels. With
improvements in employment
opportunities, more and more
minorities could afford homes
in the more affluent areas,
which in turn impacted racial
distribution.

Fig. 2-6. Part of downtown Tucson in 1918. Source: Maclaury 1989.

Segregation and Integration
When Tucson was still a
very small town, there was
little room for segregation since
most people lived within a few
square miles of each other,
except for the O’Odham who
utilized lands from the San
Pedro River to the Gulf of
California and the Apaches
whose territory went even farther east and north.
Native Americans lived at
places like San Xavier, Sells,
and to some extent on Tucson’s
south side. Hispanics tended
to live in the barrios in the
downtown vicinity. Orientals
and blacks tended to live on the
south side and whites expanded
to the north and east as the
town grew. Schools were
segregated until the 1950s and
1960s. Gertrude Mason, a
progressive planning advocate
in the 1930s made a radical
suggestion that “Negro” and
“Mexican” children should be
allocated a place to play in
the city parks, instead of parks

13

being only for white children. For
several decades children were punished
for speaking languages other than
English in school. Intermarriage was
forbidden by Arizona law (although the
law was frequently ignored) for about
fifty years until the U.S. Supreme
Court nullified the law in the 1950s.
During the Depression, most
African-Americans lived south of
Speedway along Main Street. A second zone was between 4th and 5th

Avenues near Stone. Å third enclave
was along the railroad between 22nd
and 25th Streets. Some 95% of
African-Americans lived in segregated
neighborhoods. Some of these
areas were overcrowded and slums
developed. As time passed three
distinct African-American neighborhoods developed: South Park (Railroad
Tracks to Kino Boulevard from 22nd
Street to 36th street), “A” Mountain
(south of “A” Mountain), and Sugar
Hill (north of the University between
Stone and Park Avenue). South Park’s
development, starting around 1940
followed a pattern in which people first Fig. 2-7. A typical FHA-approved neighborhood layout in 2000.
lived in tents, then moved into houses Note cul-de-sacs, curving streets, and limited access streets in and
that they often built themselves. The out of the neighborhood. Residents must leave the neighborhood
area near “A” Mountain was settled by
for shopping and work.
people who moved into what was then
desert starting in the 1930s. A major
Barrios have been an important part of Tucson’s
problem in development of the “A” Mountain neigh- heritage for more than one hundred years. These are
borhood was difficulty in borrowing money to buy
predominantly Hispanic areas with a strong sense of
homes in that neighborhood, until a lender agreed to
neighborhood and common culture. Fig. 2-8 shows
loan money there. Sugar Hill developed in the
Tucson’s barrios today. Some of the barrios were split
late 1950s when African-Americans started to move
or encroached upon to make way for modern Tucson as
into an area occupied by whites. This area was
described in several chapters that follow.
integrated and tended to be occupied by professionThe Pascua Yaqui neighborhood south of Miracle
als. (Lawson 1996 and 2000)
Mile and west of Oracle was for many years the primary
After passage of the Civil Rights Act in 1964
concentration of Yaquis. When the federal government
more and more African-Americans were able to buy
established the Yaqui reservation on Tucson’s southwest
homes in other parts of town, although with difside in 1964, many tribal members moved there although
ficulty. One resident describes an incident where the many remained in the old area which remains a cohesive
realtor agreed to sell him a lot, but only after all
neighborhood.
the other lots had been sold so that whites would
Another group of people who sought equality in
not boycott the area. Desegregation of schools also
the late 20th century were the disabled. The federal
made it easier for African-Americans to live wherev- government passed the Americans with Disabilities Act
er they chose since their children could go to neighin 1991. People with disabilities earned the right of
borhood schools.
equal access to public buildings, public education, trans-

14

portation and employment. One
response to this Act was development of a transportation system in
Tucson, South Tucson and unincorporated Pima County that provided
a wheelchair accessible van service
to people unable to use the public
bus system for health reasons. More
recently Pima County passed an
ordinance to require accessibility
features in new housing.
Finally, people have been segregated by their ability to afford to
buy or rent housing. While this is
common in many parts of the world,
the land use patterns in much of
the West accentuate these distinctions. New homes and apartments
must conform to zoning codes that
divide areas into classifications such
as single family on large lots or
on small lots, commercial, industrial, and residential. See Chapter Six
for more information and a zoning
map. This pattern is different from
that of many European cities or cities such as San Francisco where
there is much more mixture of commercial and residential, with people
living above stores, for example.
The housing patterns in Pima
County often mean that a car is
needed to get from home to work
to shopping. See Fig. 3-2 in
Chapter 3 for an indication of the
percentage of people who drive to
work. Distances are great and it is
not economically feasible to provide
public transportation in many parts
of the community. This in
turn segregates people to a certain
extent by their ability to drive.
Transportation issues are discussed
in Chapter 3.
Fig. 2-8. Tucson’s barrios. Source: Arizona Historical Society

15

16

Chapter Three
Air Quality and Transportation in Pima County

A

“Sprawl keeps a person in the driver’s seat. The suburban family, on average, makes ten
car trips a day (keeping in mind that most families have two vehicles). A commuter living
an hour’s drive from work annually spends the equivalent of 12 workweeks, or 500 hours, in
a car. Traffic delays rack up more than 72 billion dollars in wasted fuel and productivity.”
John Mitchell in National Geographic 2001.

ir quality continually varies depending on the
weather, temperature, and time of day. In
1997, the Rating Guide to Environmentally
Healthy Metro Areas listed Tucson as a city with
one of the worst air pollution problems in the nation
ranking it 256 out of 317 metro areas. Phoenix
ranked 309. (Weinhold 1997) In recent years, however, Pima County has seldom violated national air
quality standards, largely because of requirements
established under the 1970 Clean Air Act that led to
improvement in emissions controls for automobiles.
Air pollution comes from stationary point sources
such as smoke stacks and from nonpoint sources that
are mobile, such as vehicles. Pima County’s major
air pollution comes from vehicles. See Fig. 3-1.
Responsibility for monitoring air quality is in the
Pima County Department of Environmental Quality
(PCDEQ) which produced a report for SDCP that

covers air quality in some detail. (Anon. 2001) The
purpose of this chapter is to give a very short history
of air quality in Pima County, summarize some of the
information from the PCDEQ report, and then look at
the question – “Are low income and minority neighborhoods in Pima County disproportionately affected
by poor air quality?”

Historic Problems

In past years, there were significant point sources
of air pollution from industry in Pima County. The
Rillito Cement Plant was at one time a major local
pollution source, but now has installed control devices and is well controlled. When the plant was polluting, people living near the plant who were mostly
low-income suffered disproportionately from pollution-related respiratory problems.
In 1971 the Tucson Advisory Committee on Air

Fig. 3-1. Air pollution sources in Pima County 2001.
Source: Pima County Department of Environmental Quality.

17

Pollution predicted that air quality would worsen as
the population increase if corrective measures were
not adopted. (Caldwell 1971) Significant changes
were made and air quality has actually improved.
The number of motor vehicles was expected to
increase at an annual rate of 5.8 percent, which is
lower than the actual increase, but pollution has not
increased proportionately because of efficient emission controls. Automobiles have long been the major
source of pollution, with the worst problems being in
areas where many vehicles travel at peak times, especially in stop-and-start traffic situations. Although
the number of vehicles has risen dramatically, the
amount of vehicle-caused pollution has not increased
because of pollution control devices required on new
vehicles and the vehicle inspection program. Copper
smelting was expected to increase at an annual
growth rate of 8 percent. In fact, the smelters in the
area have been closed mostly for economic reasons.
The San Manuel smelter in Pinal County was at
one time a major source of air pollution for northeastern Pima County. Heavy clouds of pollution
traveled north and south along the San Pedro River
and entered the Tucson metropolitan area north of
Saguaro National Park. This problem was resolved
by installing scrubbers on the smokestacks. That
smelter is now closed. There was at one time also
a smelter in Ajo which was a major local pollution
source. This smelter is also closed.
Another historic and continuing cause of pollution has been unpaved roads and construction sites
from which dust blows. Along with the direct respiratory effects of dust, known to air quality professionals as “particulates,” may come diseases such
as Valley Fever. This disease is endemic to the
southwest. Most people who get Valley Fever have
only minor symptoms, but for others the disease can
be serious or even fatal. The disease also attacks
dogs and other animals.
Many residents of San Xavier and Tucson’s south
side had major air pollution problems when the
Minerec Company had an air pollution release in
June 1998. Some residents had previously complained of air quality problems from Minerec. The
facility is located on San Xavier property southeast
of the airport, but the state has jurisdiction over
Indian lands in the area of air quality. The Pima
County Air Quality Hearing Board conducted a public hearing on September 8. The quotes below are
from the hearing minutes. The Board heard witnesses from the Minerec Company who denied a

18

continuing problem and residents from the area. One
resident said “I would like to speak about the continuing saga of Minerec. In 1992, Minerec released
5,834 pounds of toxic waste in the air. … People
were becoming ill in 1992. Minerec was given a
permit in 1992 for a generator to burn their toxic
waste . Minerec installed the first in 1993. We now
have to put up with the releases of the toxic wastes
of Minerec. … Minerec was caught dumping toxic
waste into the sewers around the Roger and Oracle
area …” Another resident who lived at San Xavier
testified that “Minerec has released noxious fumes
into the atmosphere not once but numerous times.
… The real issue is the constant violation of southside residents’ right to life, happiness and general
well being guaranteed b the Constitution and the
Bill of Rights…. “ Another resident of a nearby
mobile home park reported having complained about
Minerec more than 30 times to the Department and
the police. Another park resident stated that “people
of color are being poisoned and this is the worst
case of environmental racism I have ever seen.”
Following the hearing the Board of Supervisors
upheld the department’s order that Minerec be shut
down.
In the mid-1990s city road workers worked on
an unusual bubble in the pavement east of DavisMonthan Air Force Base. The bubble turned out to
be full of a dangerous gas and when the Pima County
Department of Environmental Quality investigated
the situation, they discovered an extensive problem
that came from years of recycling old airplanes. In
the process workers melted down the plane parts in
order to recover aluminum. They tended to abandon
the waste product, called “dross,” from this process.
Dross built up in the soil and migrated down washes.
When the developer of the nearby subdivision bladed
a wash through the subdivision they found a layer
of this waste material. The Department worked with
the residents to inform them and help them deal
with the problem. It also set strict new rules for
the recycling process. Companies may leave no
new dross on site and must remove surface deposits.
Staff decided that it would not be harmful to health
or otherwise beneficial to remove subsurface deposits
unless individual homeowners needed to dig in the
ground. The Department did, however, recommend
that people not grow vegetables in dross-contaminated soil. This is not a minority neighborhood,
but tends to be occupied by low-to-middle income
people working at the Base.

For industrial siting issues, see Chapter 5.
Finally pollen and molds can cause serious health problems for many people. The
amount of pollen has risen along with the
use in landscaping of certain nonnative as
well as some native plants. Bermuda grass
and mulberry trees, for example, are major
sources of allergenic pollen. Local ordinances now prohibit planting of certain
plants with high allergenic potential (Table
3-1) and new subdivisions have many fewer
allergenic species than older parts of town
where problematic pollen counts tend to be
much higher than they are in the outlying
areas. Pima County no longer monitors for Fig. 3-2. Means of Transportation to Work, Pima County
pollen and mold and no longer has records 1990-2000. Source: City of Tucson Planning Dept.
of pollen concentrations.
Mold is primarily a problem in buildings where
The Current Situation
moisture accumulates. It can quickly become a very
Today the major sources of air pollution are vehiserious health problem if not controlled. Leaky
cles either because they pollute directly or because
pipes, leaky roofs, areas where water enters or exits
they drive on unpaved roads. As a result of federal
the building are the major places where mold gets
legislation and a series of lawsuits, Pima County constarted. Leaking pipes under house foundations, for
tinuously monitors air quality for major pollutants.
example, can accumulate moisture long before the
Air quality is continuously monitored at 11 sites as
leak is detected and repaired. Mold that gets started
shown on Fig. 3-3. Each site monitors different
under the house can move upwards. Mold problems
pollutants, depending on regulations and the need to
are not more prevalent in low income areas than in
know the status of certain problem pollutants.
other parts of the community.
Table 3-1 Pima County Pollen Control Ordinance (Chapter 7.41)
The following plants produce large amounts of allergenic wind-borne pollens which are noxious and contribute to human
disease:
A. Common bermuda grass
A. Any person maintaining lawn or open space planted in common bermuda grass shall mow that grass
frequently enough to prevent pollination.
B. Any person owning land on which common bermuda grass has become established shall cause that grass to
be cut or removed.
C. In no case shall bermuda grass be allowed to grow unchecked. Bermuda grass which is freely pollinating
shall constitute a nuisance. (Ord. 1991-137 § 19 (part), 1991)
B. Mulberry tree and Olive tree. The provisions of this chapter shall not apply to Swan Hill olive trees and
Wilson olive trees.
A. No mulberry tree or olive tree shall be sold in the county.
B. The sale of a mulberry tree or olive tree in the county shall constitute a nuisance.
C. No mulberry or olive tree shall be planted in the county.
D. The planting of a mulberry tree or olive tree in the county shall constitute a nuisance.
Abatement of nuisance.
A. If a nuisance exists on private property, the director may order the owner or occupant to remove the nuisance within
twenty-four hours at his/her own expense. The order may be given to the owner or occupant in person or left at his usual
place of abode. If the order is not complied with, the director may cause such nuisance to be removed, and the expenses of
removal shall be paid by the owner or occupant who caused the nuisance.
B. When a nuisance exists on public property, the director shall notify the responsible public official, who shall cause the
nuisance to be removed.

19

Fig. 3-3. Air pollution monitoring sites and former pollen monitoring sites in Pima
County. Source: Pima County Department of Environmental Quality.

20

21

Fig. 3-4. Public transportation service in Pima County. Source: Pima Association of Governments.

Fig. 3-5. Carbon Monoxide (CO) 8-hour concentrations in ppm. Source: Pima County Department
of Environmental Quality.
Is air quality worse in minority and low income
areas than in other parts of the community? There
is no evidence that this is the case. While South
Tucson ranks high in pollutants from automobiles,
so do the Orange Grove Road area and 22nd and
Craycroft. In general, areas with the greatest traffic
congestion are most susceptible to having poorer air
quality. The rapidly expanding northwest part of
the community has had some of the worst traffic
congestion problems, contributing to the problem at
Orange Grove Road. This rapidly growing area
also is likely to have the most dust from construction
sites, although efforts are made to water down the
dust. Certain roads in the urban area are regularly
very congested as vehicles from all parts of the community converge at peak hours when people travel to
work or school.

drive on crowded streets to areas where parking is
scarce. In Tucson, it is usually faster and more
convenient to go by car.
The current transportation system in Pima
County favors people who can afford to drive at least
one vehicle and whose health and age permit driving.
Fig. 3-4 shows the public transit system in Pima
County. The inner city has many routes, but there
are few routes in the outlying areas probably because
people in those areas prefer to use their cars even if
bus service were available so bus service is not made
available there. Also, distances are so great that it
would be very difficult to design efficient bus routes.
The way the community has grown has made it difficult to provide a transportation system that is not
dependent on the automobile. The vast majority of
people drive to work as shown in Fig. 3-2.
If low income housing were to be built on
the urban fringes or were to be scattered around in
higher income subdivisions, would lower income and
minority people move there? Probably not in large
numbers for various reasons, but largely because of
the problems of transportation.
The Major Pollutants in Pima County
The following information is summarized from
the Pima County Department of Environmental
Quality Annual Reports of various years. The sites
in the graphs were chosen as representative of predominately minority-low income neighborhoods versus higher income non-minority areas. Because different monitoring stations measure different pollutants, a consistent comparison of the same neighborhoods is not possible.

Transportation
Transportation and land use are closely related
as mentioned above. Construction of new major
roads opens up opportunities for development. On
the other hand, the influx of people in a new area
calls for construction new roads and expansion of
existing ones. The way the community has grown
has made it difficult and costly to provide public
transportation. A rail transit system, for example,
has been proposed many times, but never found to
be cost-effective in this area. This is also true of
most other sprawling cities. The BART system
in the San Francisco area offers an attractive transportation alternative in that community because
the community is developed in a compact fashion.
Fig. 3-6. Ozone one-hour average mean levels.
For the destinations on the system it is usually
Source: Pima County Department of Environmental Quality.
faster and more convenient to go on BART than
22

Fig. 3-7. Particulates (PM10) Annual Average.
Source: Pima County Department of Environmental
Quality.
Carbon Monoxide (CO)
CO is a odorless, colorless gas produced by the
incomplete burning of carbon-based fuels such as
gas and wood. When inhaled, CO can enter the
bloodstream where it inhibits the delivery of oxygen
through the body. Low concentrations cause dizziness and fatigue. High concentrations can be fatal.
More than 70% of the CO in Tucson’s air is
from vehicles. Concentrations are highest in the
winter when temperatures and wind speeds are low
and there is a temperature inversion. In the 1970s
and early 1980s Pima County often did not meet
federal standards for CO, but since 1984 there have
been no violations. Fig. 3-5 shows CO levels at
minority and non-minority monitoring sites in Pima
County.
Ground-Level Ozone
Ozone is a variety of oxygen with three oxygen
atoms. It comes from chemical reactions involving
volatile organic compounds, nitrogen oxides and sunlight. Ozone is necessary at high altitudes to protect
the earth from ultraviolet rays from the sun. At
ground level, however, it impairs lung function and
is especially dangerous for people with lung diseases
such as asthma. Ozone levels are generally higher
in the summer months because of intense heat and
sunlight.
Fig. 3-6 shows ground level ozone levels at minority
and non-minority monitoring sites in Pima County.
Particulates
Particulate matter is any solid in the form of
smoke, dust, and vapors that can remain suspended
in the air. They are produced from burning of diesel

fuel, fertilizers, burning, and in Pima County
one of the major sources is dust from construction and unpaved roads. Particulates
create haze and reduce visibility and cause
respiratory problems. Particulates come in
many sizes. The current EPA standard of
PM10 refers to particulates with a diameter
of 10 microns or less. In 1999 Pima County
exceeded the federal 24-hour standards four
times, but the annual averages met and continue to meet the EPA standards. Fig. 3-7
shows particulate levels at minority and nonminority monitoring sites in Pima County.
Lead
Lead is a highly toxic metal that causes nervous
system damage, digestive problems and cancer. Now
that lead is no longer used in gasoline, airborne lead
is not a serious problem in Pima County. Nationally,
after lead was phased out of gasoline, lead levels
in the air decreased 96 percent between 1979 and
1998. Lead problems may still occur, however, in the
form of old lead-based paint, some water pipes, and
other sources.
Nitrogen Oxide (Nox)
Nitrogen oxides are produced by burning fossil
fuels. The most dangerous form, NO2 is poisonous
and highly reactive. It is one of the agents that helps
form ozone and contributes to acid rain. NO2 has
declined since 1980 and there have not been violations of the standard. Fig. 3-8 shows NO levels at
minority and non-minority monitoring sites in Pima
County.

Fig. 3-8. Nitrogen Dioxide (NO2) Annual Mean.
Source: Pima County Department of Environmental
Quality.
23

Sulfur Dioxide (SO2)
In Arizona, the main source of SO2 is copper
smelters. When there were active smelters in Pima
County, SO2 was a problem, but with the closing of
the smelters at San Manuel, Ajo and Douglas, there
is very little airborne SO2 in Pima County.
Airborne Toxics
This includes a variety of toxic air pollutants,
including volatile organic chemicals, pesticides, herbicides, metals, and radio nucleides. These can
cause a variety of health problems such as cancer,
birth defects, and nervous system problems. They
can be fatal. Sources include dry cleaners, auto
paint shops, chemical manufacturers, and incinerators. Beryllium comes in this category. It has been a
subject of controversy in Tucson. See Chapter 5 for
a discussion of the beryllium problem.
Other Pollutants
Other pollutants include carbon dioxide, chlorofluorocarbons, and some volatile organic compounds.
These, too, do not appear to disproportionately affect
low income or minority residents.
Odor
Although odors are not generally health problems, they can be problems for people having to
live near areas with odor problems. Temporary
odor problems come from roofing, painting, and
vehicle exhaust. More long-lasting odor problems
can come from landfills, dairies, and wastewater
treatment plants. Odor complaints are handled
through the air quality permit process.
Radon
Radon is a colorless, odorless, radioactive gas
produced by the decay of uranium. It is present
in minute quantities in many soils and can travel
through soil and rock. The amount of uranium in
the soil is a major factor influencing indoor radon
concentration. Uranium is in many cases associated
with limestone as it is in southwestern Tucson where
the potential for radon contamination is the greatest
in Pima County. This area is centered near the
intersection of Cardinal Avenue and Valencia Road
west of the airport. The levels are a maximum of

24

14 times the background level at this central point.
Several dozen homes were tested here and found
to have higher than normal levels of radon. This
is a relatively low income area with high minority
residency. This, however, cannot be considered an
instance of environmental justice since the radon
occurs naturally and is not manmade and the neighborhood was developed before radon levels were
known.
Radon reaches homes by traveling as a gas
through soil near and beneath the home. It decays
quickly, so only the radon in the top ten feet or so if
liable to reach the surface. It is quickly disseminated
when it reaches the air. Cracks in concrete floors,
open spaces around pipes, joints where floor meets
wall and drainage outlets are good conduits for
radon. The main factor in how much radon seeps
into homes is the difference in air pressure between
indoors and outdoors. An evaporative cooler increases the indoor air pressure, so the radon is forced
out, while a heater or furnace decreases indoor air
pressure and radon is sucked in.
Radon can also be trapped in groundwater. It
dissipates quickly, however, once it reaches the surface and as it travels through pipes.
To learn more about radon, see Radon: A
Geological Hazard by the Arizona Geological
Survey. (Spencer 1992)
Urban Heat Islands
In some large cities, the accumulation of pavement, walls, and buildings along with heat sources
has led to higher temperatures in the city core than in
the surrounding countryside and a steady increase in
average temperatures is documented over the years.
In Los Angeles, for example, the high temperature in
the downtown area has increased from less than 100o
to more than 105o while temperatures in nearby
countryside have not shown similar rises. Similar
rises have been documented for Phoenix, Washington
DC, Tokyo, Shanghai, and Baltimore. In cities with
proven heat island effects, the heat is generally the
greatest in the inner city. No study has been
done of the Tucson area, but there does not yet
appear to be a significant heat island effect at the
University of Arizona station, where long-term temperature records are kept.

Chapter Four
Water Quality and Supply in Pima County
“A Tohono O’odham student may feel no responsibility for the toxic contamination of the
aquifer beneath a Mexican American barrio in South Tucson until he discovers that the same
political, economic, and social forces that removed the Tohono O’odham from their floodplain
gardens along the Santa Cruz River later forced the removal of Mexican Americans from their
barrios along that same river and subsequently placed them at a contaminated locale in an
industrial section of Tucson. An earnest Anglo student may justifiably and resolutely refuse
to accept responsibility for her great-great-grandfather’s relation to the removal of American
Indians to reservations only a fraction of the size of their former territories or to the forced
removal of Indian children to government boarding schools. However, she will be hardpressed to abjure all responsibility for the cultural politics that give the dominant culture the
power to deplete aquifers to keep her campus mall green …”
Joni Adamson 2001.

P

ima County residents depend almost entirely
on groundwater since there are no major
flowing rivers with perennial surface water.
Tucsonans have never had to deal with highly polluted rivers like the Ohio River which was once so
polluted with fuels that it burst into flames. People
living at the end of the Mississippi River must use
water that has been used many times before upstream
for cities, industry, and agriculture. Water in Pima
County has, however, been contaminated by pollutants that seeped slowly through the soil down to the
aquifer. Soils manage to filter out some pollutants,
but others, such as salts and TCE can reach the
aquifer. Since it may take many years for this to
happen, the connection between cause and effect is
not always obvious.
Water distribution in Pima County is quite complex. Most residents in the metropolitan area receive
their water from the City of Tucson. Other important water providers in the metropolitan area are
Metropolitan Domestic Water Improvement District,
Flowing Wells Irrigation District, and others as
shown on Figure 4-1. In addition, many people have
their own wells, especially in rural areas. There are
more than 20,000 private wells in Pima County.
Tucson Water serves about 80 percent of the
metropolitan population and provides water both
inside and outside of city limits. Most of the low
income and minority residents in the metropolitan
area get their water from Tucson Water. Tucson
Water, however, does not serve the Tohono O’odham
Nation. The University of Arizona has its own
wells, but buys some water from Tucson Water.
Most of the Tucson Water system is intercon-

nected, but there are a few isolated service areas.
Water for the main part of the service area comes
from local wells, wells in the south and central parts
of town, wells in Avra Valley, and most recently
the Colorado River, via the Central Arizona Project
(CAP). Because of this complexity, it is often not
simple to say where the water comes from for any
neighborhood as the source supply may be different
at different times of year and supplies are blended.
Often the blending occurs in reservoirs where water
is stored until it is needed. A neighborhood may
receive blended CAP and Avra Valley Water, treated
water from the TARP plant (see below)and water
from wells in the metropolitan area. In the summer
during peak water demand times more water is
pumped from wells in the metropolitan area than in
the winter when there is less demand. It is certain,
however, that few customers get their water entirely
from wells beneath their homes. In the isolated
service areas, however, supplies come from one or
several wells in the immediate area.
People getting their water from other water providers are more dependent on one or a few water
sources since the system is not connected to the
Avra Valley system or the CAP. People with their
own wells are entirely dependent on the water supply
near their home. The Safe Drinking Water discussed
below, requires that water delivered to customers at
least meet minimum water quality standards.
Once pollution has reached groundwater it is
liable to continue to move underground, flowing to
a lower point. Since water is continually being
pumped in the region, water may move toward areas
being pumped because the level of the water table

25

Fig. 4-1 Major water providers in Pima County. Soure: Gelt et al.

26

27

Fig.4-2- Major well concentrations in Eastern Pima County. Source: Gelt et al.

slants toward the pumping area. This is called a
“cone of depression.” (Fig. 4-3) This fact makes
cleanup efforts complex since pumping water to
clean it up make actually promote movement of pollution toward the well. This also complicates decisions about where to recharge water, since new water
entering the aquifer near the contaminated area may
force the contamination to move towards wells.

health experts have reason to expect that there is
something in the environment that is causing them in
that location. It is difficult to prove cause and effect
in situations where there is a long lag time between
the cause and the effect. Cancer, for example, may
take years to show up after exposure to the cancercausing material. Since our society is so mobile, the
person may live far from the area where he or she
was exposed to the cause. This makes epidemiological studies very difficult. Researchers need to figure
Water Quality and Health
out how the person may have been exposed if it is
Water pollution can seriously affect human health.
determined that exposure to some toxic material was
In the past the major health concerns were related
the cause. Often the numbers of people in a cluster
to communicable diseases such as cholera. Modern
of diseases is so small that even though there are, for
disinfection eliminates most of those problems, but
example, four times as many cases of a particular of
toxic materials are of concern. Even very small
cancer in the region, that number of affected people
amounts of some substances can contribute to canis likely to be too small to draw meaningful statisticer, birth defects, lupus, and other diseases. These
may be measured in parts per billion. Unfortunately, cal conclusions.
People are exposed to a great variety of possible
however, it is very difficult to determine cause and
pollutants including the air they breathe, the water
effect in any neighborhood or individual because
there are so many other possible reasons for diseases the drink, the food they eat, smoking, alcohol, drugs
and other sources. Some people appear to be predisto occur and very little is known about the causes
posed to certain diseases because of their ethnicity
of some diseases. A child who was born with
or personal family background. Sickle cell anemia,
birth defects, for example, may have them because
for example, is found primarily in people of African
of genetics, habits of the pregnant mother, or some
heritage. Some kinds of disease appear to “run in
environmental cause, In many cases no one knows
families” so that more members of that family get the
why a child has a birth defect. If there are an
disease than the general population. Sometimes this
unusual number of birth defects in a specific area,
predisposition requires an environmental trigger.
Finally, there are hundreds
of chemicals that have never
been fully studied to determine
their impacts on human health.
The Environmental Protection
Agency (EPA) has not been able
to keep up with health impact
studies of the many new chemicals as they are introduced.
Studies of impacts are expensive
and need to be conducted first
on animals, but it is not always
accurate to assume that a chemical that affects a mouse or other
laboratory animal will similarly
affect humans. It is not ethically possible to experiment on
humans by exposing them to new
Fig. 4-3. Stylized diagram of a cone of depression. When there are
chemicals. All of these factors
many wells, the drop in the water table and subsidence potential can
complicate studies of cause and
be region-wide. Source: Pima County Graphic Design.
effect.

28

conducted activities that had a
major impact on water quality on
the south side of the metropolitan
area, in the vicinity of the Tucson
International Airport. The most
notorious impact came from solvents used to clean airplanes.
One of those solvents,
Trichloroethylene (TCE) did reach
the aquifer in problematic quantities twenty to thirty years after it
was discharged. By 1981 residents convinced officials that a
serious health problem existed, but
the source of the problem was not
clear. A Tucson Citizen headline
in November, for example, read
“City’s polluted wells: The mystery remains.” By then testing had
shown problem levels of TCE in
six city wells. By 1983 experts
had mapped a plume of polluted
water extending from Hughes
Aircraft Company to a spot just
south of Irvington Street, crossing
the northeast corner of the San
Xavier District. Many of the
people affected were low income
and Hispanic or Tohono O’odham.
Some of them had moved to the
area after being displaced from the
downtown area by construction
of the Tucson Convention Center
and the City-County Government
buildings in the 1960s.
Soon the plume was found to
extend even farther, at least as far
Fig. 4-4. Tucson’s TCE plumes. The TCE slowly moves generally north as Michigan Street. Tucson
north-northwest. Source: ADEQ.
Water shut down the affected
It is not feasible to test water for all possible
wells, but some people had been
pollutants as each test must be conducted separately
drinking contaminated water for years and there
which makes testing very costly. The EPA requires
appeared to be more than normal numbers of people
water providers to test for probable toxic pollutants
with diseases such as cancer and lupus. Residents
in addition to standard pollutants such as nitrates.
believed that this was related to the contaminated
water and later studies confirmed that this was probably the case. One problem in making the connecMajor Water Quality Problems in Pima
tion between the contaminated water and illness was
County
determining when people started drinking the water
TCE
and when the contamination reached specific parts of
Tucson has little heavy industry that is usually
the area. By 1980 some 20,000 people lived in the
the greatest source of water pollution nationally.
affected area, up 5,000 or so from 1960.
In the 1940s and 50s, however, the aircraft industry

29

The Arizona Department of Environmental
Quality and the Environmental Protection Agency
joined the search for the source and ultimately decided that the problem stemmed from hazardous releases from Hughes Aircraft, Grand Central Company,
and other businesses in the area that released their
wastes into washes or disposal ponds. Residents
formed Tucsonans for a Clean Environment (TCE) to
ensure that the government agencies did everything
that was needed to clean up the problem and deal
with local health problems. In 1987, 1600 residents
(of whom 70% were Hispanic) sued the City of
Tucson saying the tainted water caused illness and
death. The lawyers had found incriminating documents that showed that the city had known about
the potential for problems as early as the 1950s.
Fig. 4-4 shows the TCE plume.
The outcome of all these efforts was an
agreement reached among the plaintiffs, the City
of Tucson, Hughes Aircraft (now Raytheon), the
Airport, the Department of Defense and others in
1991. Some of the companies that had contributed
to the problem were no longer in business. Raytheon
now removes TCE in its area in a treatment plant
on its grounds. The City of Tucson operates the
Tucson Airport Remediation Project (TARP) along
the Santa Cruz River, with funding from parties to

the agreement, under EPA oversight. TARP uses an
aeration process to remove the TCE and other volatile organics. The resulting water more than meets
EPA standards for TCE and other contaminants and
the quality is monitored in much more detail than is
required for any other water in the system. There
had been considerable controversy about what to do
with the water from the facility. If it was injected
back into the groundwater it would become contaminated again. Residents objected to releasing it into
the Santa Cruz River fearing, among other things,
that a health problem from mosquitoes would result.
The water is now put into the Tucson Water system
and delivered north of the polluted area as shown on
Fig. 4-5.
There was still a problem for people with
their own wells. The Pima County Department
of Environmental Quality (formed by the Board of
Supervisors partly in reaction to the TCE problem)
identified private wells in the area with high levels
of TCE and worked to help people connect to the
Tucson Water system.
Another outcome was an epidemiological study
and establishment of the El Pueblo clinic on the
southside to serve people who might have TCErelated health problems. In a legal settlement
residents with diseases that probably were caused
by TCE received monetary settlements.
Clark documented that the official reaction to this whole problem was very slow
until a second Hispanic was elected to
the Pima County Board of Supervisors in
1985. Supervisor Grijalva’s support was
essential to raising the level of concern
in the community, getting governmental
action, and accomplishing the actions
discussed above. (Clarke 1998)

Fig. 4-5 Where TARP water is delivered. Water runs north
from TARP to a reservoir from where it flows to customers.
Source: Tucson Water.

30

Central Arizona Project (CAP)
In 1992 CAP water began flowing
to about 84,000 Tucson Water customers.
Fig. 4-6 shows where CAP water was
introduced in 1992. It soon became
clear that there would be problems. The
water that left the treatment plant met
federal water quality standards, but in
some homes it was discolored. At first
Tucson Water did not believe that there
was a problem, but so many people complained that something had to be done.

Fig. 4-6. Where CAP water was delivered in 1992. The minority and low-income parts of town
generally continued to receive groundwater. Source: Gelt et al.

Fig. 4-7. Where Tucson Water intends to distibute the Clearwater blend of
CAP and Avra Valley water by 2003. Most customers will receive the blend for
at least part of their water supply. Source: Tucson Water.

31

Studies showed that the changed chemical characteristics of the water were causing scale within pipes
to dissolve and if those pipes were made of iron,
rust came off, turning the water brown. Pipes broke,
coolers and hot water heaters were damaged and
people had problems with their swimming pools.
After citizen outcry the CAP water was turned off
and a citizen initiative assured that it would not be
used again in the city system for many years. A
second election reaffirmed that decision, but a third
election in 1999 reversed things and Tucson Water
prepared to reintroduce CAP water, this time blended
with Avra Valley groundwater. After careful preparation and changes to the treatment process, the reintroduction in 2002 was relatively uneventful. In the
meantime Tucson Water had replaced most of the old
water mains in the central part of town.
Most of the low income and minority neighborhoods continued to received groundwater and
were not directly affected by the fiasco. Fig. 4-7
shows where the CAP-Avra blend, referred to as
the Clearwater Blend, will be delivered by 2003.
The water comes into a reservoir at Star Pass and
flows into the city system. The first deliveries were
roughly north of 22nd Street, but gradually most of
the city will receive this water. Introduction of the
Clearwater blend went very smoothly and few if any
water quality problems have developed.
This is a case where the south side managed to
avoid the problems suffered by the rest of the community in 1992, but where by 2003 the south side
will be drinking much the same water that the rest
of the community drinks. Thus, there is no environmental justice problem in this case.

Polluted Groundwater in Pima County
Figure 4-8 shows where the most polluted
groundwater in the region is located. This map
shows Superfund sites, areas that the federal government has declared to be in need of cleanup and Water
Quality Assurance Revolving Fund (WQARF) sites,
areas that Arizona considers in need of cleanup. The
TCE plume shown is in the process of cleanup, but
most of the other sites are not being treated, although
other actions are being taken as indicated below.
Does this mean that people living near those sites
are drinking polluted water? Not unless they have
their own wells. The downtown area, for example,
is polluted with diesel fuel and other pollutants
from a long history of fuel leaks and spills. Tucson
32

Water does not pump water from this part of the
aquifer but brings water into the area from elsewhere.
Agricultural activities can also be sources of pollutants. In Pima County, however, the major agricultural water users are in the Avra Valley-Marana area,
downstream from metropolitan Tucson and do not
significantly affect low-income and minority residents in the city. There are high levels of nitrates in
some groundwater in the Marana area, but the source
is unclear. Wastewater and agriculture may both be
implicated.
The following are all the officially designated
polluted sites in the Tucson area as listed by
the Arizona Department of Environmental Quality.
(Anon. 2000a)
West University – a site at 6th and 7th Street
between 7th and 5th Avenues is contaminated with
TCE, PCE, and DCE above drinking water standards.
The nearest well is at the University of Arizona, to
the east.
Silverbell Jail Annex – This site is in the vicinity
of Silverbell Road south of Sweetwater Drive west
of I-10. Contaminants are primarily TCE, PCE and
other solvents and arsenic. All concentrations are
below the federal standards. The only drinking water
well in the area is at a mobile home park used mainly
by a transitory population. A remediation plan has
not yet been adopted.
Shannon Road-Rillito Creek – This site is in
northwest Tucson on both sides of the Rillito. The
only contaminant above the regulatory level is PCE,
but other chemicals have been detected below that
level. Water is provided here by Metro Water and
Acacia Gardens. It is treated to meet federal standards.
Park-Euclid – This site is in central Tucson, just
south of Broadway on both sides of Arroyo Chico
in an area where there have been laundry and drycleaning activities since the 1930s. Residents are
currently involved in discussions about remediation.
The area is served by Tucson Water which does not
pump from wells in the area.
Miracle Mile – This site is in the Roger Road
–Romero Road area. When problems were first
detected with volatile organic compounds in 1993 the
Flowing Wells Irrigation District took responsibility
for providing water to the Mobile Home Park using
water from outside the area.
El Camino del Cerro – This area is located
between the Santa Cruz River and I-10 north of

Fig. 4-8. Polluted groundwater areas listed as Superfund Sites or
WQARF sites. Source: ADEQ.

33

El Camino del Cerro on both sides of the railroad
tracks. The closed Camino del Cerro landfill is
on the southwest corner of the site. Numerous
organic compounds have contaminated the groundwater, but amounts have been decreasing. Private
drinking water wells were affected with the result
that Pima County at first shipped in bottled water
to the businesses in the area and then arranged for
connection to Tucson Water so no one there is using
contaminated water at the present time.
Broadway-Pantano – This site is on Tucson’s east
side north of Broadway and east of Pantano Wash
at the site of an old landfill. The problem contaminants are TCE, PCE, and vinyl chloride. There
are several drinking water wells in the area, four
of which are owned by Tucson Water. Whenever
contaminant levels get higher than one half the regulatory level, Tucson Water ceases pumping at that
well. St. Joseph’s hospital also has a well in the
area, but has installed a wellhead treatment system
which reduced the levels to non-detectable levels.
There are also a few private wells in the area the
owners of which must work directly with ADEQ to
determine if there is a risk.

Davis-Monthan Air Force Base – This site is
located entirely on the base. The main problems are
with petroleum waste, aluminum dross from airplane
melting and a jet fuel leak. The dross has been
transported off base. The contamination is near the
surface in the soil and no water contamination is
known.
Raytheon, Tucson International Airport, and
National Guard Sites – These are all located in the
same area west of the airport extending from Hughes
Access Road to Valencia. This is the major contamination site in the Tucson area, associated with the
TCE problem discussed above.

Contamination from Landfills
Old landfills have also polluted or might pollute
groundwater. In May 1982 the Arizona Daily
Star reported that the old Ina Road Landfill and
the El Camino del Cerro Landfill along the Santa
Cruz River north of Ruthrauff Road were leaking low
levels of pollutants including TCE into downstream
wells. Seasonal flooding in the river was
eroding away parts of the dump. The Tucson
Mountains Association, representing mostly white,
middle to high income
residents, became involved
when private wells of their
members were contaminated.
See Chapter 5 for
more discussion of landfill
issues.

Fig. 4-9. Tucson Water Quality Zones. Source: Tucson Water.

34

Drinking Water Today
Does this mean that people who live in the affected
areas are drinking unsafe
water? No. First, the federal Safe Drinking Water
Act, passed in 1974,
requires water providers to
produce water that meets
certain minimum drinking
water standards. Water
must be tested regularly
and any violations immediately reported to the consumer. Water providers do
their own testing but there
are stiff penalties for failure to test and report and

between the low income areas and
the higher income areas. Tucson
Water maintains current water quality
information by area on its web site.
Some residents get their water from
other water providers such as the
Flowing Wells Irrigation District or
the Metropolitan Water Improvement
District. These providers have a
much smaller number of sources that
they use for their customers, but they
too must conform to Safe Drinking
Water Act requirements. Fig. 4-1
shows the service areas of the larger
water providers in eastern Pima
County.
People who have their own wells
are slightly more likely to have a
Fig. 4-10. Average hardness of Tucson Water at various zones in problem, especially if they are in
locations where pollution potential
2001. Source: Tucson Water.
exists, such as in abandoned farm
correction violations. Second and most important
land. They are responsible for their
is that most people do not drink water from the
own water quality and testing and do not come under
aquifer beneath their homes unless they have their
the Safe Drinking Water Act. In some cases, such
own wells. Most of the minority and low income
users may live in “wildcat” subdivisions and may be
neighborhoods are served by Tucson Water which
low income, but they may also be high income users.
gets its water from a variety of sources and transports
There appears to be no relationship today
that water throughout the entire service area. Only
between income, race, and drinking water quality in
in a few isolated locations do residents drink water
from wells near their homes.
Much of the water used in
the Tucson area is from Avra
Valley wells and increasingly
from the Colorado River. By
2003 Tucson Water anticipates
that most of the metropolitan
area will receive a blend of Avra
Valley and CAP water as discussed above. Tucson Water
also pumps from wells throughout the community, using that
source more in the peak months
of summer than in the low use
months of winter. Wells that are
in areas with contaminated water
are not used. For the most
part, water from more than one
source is blended with water
from another source and stored
in reservoirs. Water quality
Fig. 4-11. Average nitrate levels of Tucson Water in various zones in
does not generally differ greatly
2001. Source: Tucson Water.

35

be uniform or differential, depending on
the underlying geology. (Slaff 1993)
When the ground subsides unevenly
(differential subsidence) the effect is liable to be that fissures will appear in
the ground. Deep fissures can be seen
in Pinal County and eastern Maricopa
County. A major fissure can be seen
north of Picacho Peak west of the freeway. Avra Valley has also had subsidence and some fissures occur there.
Fissures can damage or destroy structures such as streets, houses, and pipelines.
When the ground subsides relatively
uniformly, the area is lowered by inches
or even feet, but the average person
may not notice a change until the subsidence affects streets, gas, water and
Fig. 4-12 Average fecal coliform levels of Tucson Water in
various zones in 2001. Measured, but none detected in zones sewage pipes, house foundations, and
other structures. The flow of water on
without columns. Source: Tucson Water.
the surface may change radically. In one
Pima County. This is, however, a perception in
place in Pinal County flood water actusome areas that the water is not safe to drink. This
ally flows in the opposite direction from which it
can be measured by the percentage of people who
flowed historically. A major impact in an urban
buy bottled water or who have home water treatment area may be that sewage no longer flows downhill
systems. A University of Arizona study revealed that towards the treatment plant, but flows back towards
in 2001 that people who lived in minority and low
homes.
income sections of town, mostly south of downtown,
As early as 1969 scientists were warning of subwere more likely to buy bottled water than people
sidence threats. The Phoenix Gazette reported on
in higher income parts of town. There
may be several reasons for this. People
may still be suspicious after the TCE
crisis, reacting to the CAP crisis of the
early 1990s, they may be generally suspicious that health problems are caused
by bad drinking water, people from
Mexico are accustomed to using bottled
water, or sellers of bottled water may
be more active and successful in those
parts of town. (Williams et al. 2001)

Water Supply and Subsidence

Subsidence
When groundwater is pumped the
ground gradually compacts when the
water between the bits of rock and sand
is gone, leaving empty spaces. When
the compaction is great and soil conFig. 4-13. Average trihalomethanes in Tucson Water at various
ditions right, the entire surface of the
zones in 2001. THM not measured in zones 11-17.
ground will sink. The sinking may
Source: Tucson Water
36

October 4 “The mammoth cracking apart of Arizona
caused by overpumping of groundwater has reached
a stage our expert described as “very critical. …
Arizonans have been fortunate that the mammoth
cracks haven’t developed in heavily populated areas
…”
Fig. 4-14 shows areas of greatest potential subsidence in Pima County, based on underlying geology. One major area is located in the vicinity of
Tucson Water south side well fields. Another is in
central Tucson. Tucson Water has begun to cut back
pumping in the central area now that CAP water is
coming into the system, partially to limit subsidence
problems. As of January 2002, 26 wells in that area
were no longer in use. Tucson Water has not yet cut
back pumping significantly from the south side well
field, and does not plan to reduce pumping there in
the near future, according to Tucson Water. Fig. 4-15
shows the origins of water that Tucson Water intends
to distribute in 2003. The percentage of Tucson
Water’s total water supply coming from the south
side of Tucson would be unchanged from 2000. This
does not mean that subsidence will occur, but is
reason for caution.

Water wells
Water wells are located throughout the community, with the greatest concentrations just north
of the San Xavier District of the O’odham Nation
and in the Avra Valley. The primary negative

impact of water wells results when a great deal of
water is pumped over a long period of time which
can cause subsidence if more water is pumped
than is recharged. This deficit of pumping over
recharge occurs throughout much of the metropolitan area and subsidence is already occurring is
parts of the area. One study shows that the area
of greatest potential subsidence is in the vicinity of
County Club Road and Speedway Boulevard. (See
Fig. 4-14) Another area of potential subsidence
is around Tucson Water’s south side well field.
While the availability of CAP water has led
Tucson Water to lessen its reliance on pumping in
the central part of town, it is still actively pumping
the south side well field.
The most significant impacts of subsidence are
damage to streets, water and sewer pipes, railroad
tracks, and buildings. Buildings can crack and
in severe cases the building may have to be abandoned. Some of the areas with actual and potential subsidence problems are in low-income and
minority areas on Tucson’s south side. Other
potential subsidence areas are in the more affluent
parts of town, such as the El Encanto neighborhood.
Water supplies at San Xavier
Prior to the arrival of the Anglos the Santa Cruz
River flowed intermittently from its headwaters to a

Fig. 4-15. TucsonWater supply as a percentage of
demand planned for 2003. Source: Tucson Water
37

Fig. 4-14 Potential land subsidence. Source: Anderson et al. 1988.
38

spot near present day Marana. There were perennial
reaches in many places. San Xavier was one of
those places where several springs brought water to
the surface along a shallow riverbed. During the
Spanish period much of the water was diverted for
agriculture but since there was no pumping the water
table remained high. By 1940, however, diversions
of water for Tucson and for agriculture and pumping
had lowered the water table at San Xavier more than
150 feet in some places. (Halpenny 1962) In the
1970s, Tucson was pumping 40,000 acre feet annually from that area. In 1975 the federal government,
on behalf of the O’odham, sued the City of Tucson,
mining companies, and agricultural interests claiming that the defendants had damaged the tribe’s water
rights by excessive pumping. Finally, in 1982,
parties reached agreement and Congress passed
the Southern Arizona Water Rights Settlement Act
(SAWRSA). The settlement gave the O’odham

37,800 acre feet of CAP water annually and 28,200
acre feet of effluent. It was not until 2001, however,
that CAP water actually reached San Xavier amidst
great ceremony and rejoicing. The water will be
used for agriculture and for riparian restoration projects. Other CAP water reached the Shuk Toak
District in Avra Valley in 2000 and is being used
for agriculture. This replacement water helps rectify
some of the wrongs of the past, but cannot bring
the water table back to its former level. (Gelt et al.
1999)
More than 1,000 sinkholes and fissures have
appeared in the San Xavier District. Many of these
are on former farmland and on land where there
was once a majestic mesquite bosque. Geologists
believe that lowering of the water table by groundwater pumping is a major cause of these problems.
(Anderson et al. 1997)

39

40

Chapter Five
Locations of Industry, Landfills, Roads, and Other Facilities
“It is a perfect example of environmental racism. … from a scientific viewpoint, the Rita
Ranch site was the best one, but it as well as a Green Valley site, was located in the district
of a Caucasian supervisor and his primarily Caucasian constituents fought successfully to
keep it away from their neighborhood.” Clarke 1999 quoting two Hispanic Pima County
Supervisors on landfill siting.

M

uch of the infrastructure of modern Pima
County has been built on lands once used
by others either in recent times or long
ago. Construction activities have destroyed archaeological sites, displaced people, changed the landscape, and disrupted wildlife habitat and corridors.
Facilities that have potential to contribute the most
to environmental pollution include landfills and hazardous waste disposal sites, mines and smelters,
industrial facilities, wastewater treatment facilities,
power plants, water wells, highways, and other facilities.
Industrial Facilities
Tucson has few large industries compared to
many towns its size. None of the local industries
are traditional “smokestack” industries, such as steel
mills. While industry offers jobs and tax revenue,
it may offer some negative aspects for neighbors,
including noise, air pollution, water pollution, hazardous materials movement, or traffic congestion.
Fig. 5-2 shows the concentrations of facilities with
hazardous waste permits.
Industrial zoning. Fig. 5-1 shows the areas
within Pima County that are zoned for industrial
uses. Industrial zoning includes several categories
with everything from heavy industry to small producing companies and even animal feed lots. Fig.
5-2 shows location of facilities that currently have
permits to use hazardous substances. Most of the
industry is located near the major transportation corridors of I-10, I-19, the airport, and the railroad,
adjacent to low income and minority neighborhoods.
Tucson’s largest industrial employer, Raytheon (formerly Hughes Aircraft Co.) which manufactures airplane parts with emphasis on the defense industry,
is located south of the Tucson International Airport.
This company is not, however, a significant polluter.
A major issue affecting people on the south
side in recent times is related to an industrial facility

that involves beryllium. The City of Tucson worked
hard to recruit the Brush Wellman Company believing that the company would create jobs. In the
late 1970s city and county officials supported a $3
million bond issue to help buy land and build the
plant. The plant was built and jobs peaked at 256
in 1988, according to the Arizona Daily Star (May
10, 1999). The company assured the city and county
that they would comply with safety and air quality
standards. In 1982 the company moved to Tucson
and later researchers documented that workers at the
plant had the highest rate of illness of all Brush
operations. Nine percent of the workers developed
beryllium disease.
According to the EPA, acute (short-term) inhalation exposure to high levels of beryllium has been
observed to cause inflammation of the lungs or acute
pneumonitis (reddening and swelling of the lungs) in
humans; after short-term exposure ends, these symptoms may be reversible. Acute pneumonitis may
cause death. Chronic (long-term) inhalation exposure of humans to beryllium has been reported
to cause chronic beryllium disease (berylliosis), in
which granulomatous lesions (noncancerous) develop in the lung. The onset of these effects may be
delayed by 3 months to 15 years. Employees in
Tucson have been affected by beryllium in the workplace.
Although workers experience the most serious
beryllium problems, nearby residents are concerned
over air quality in their area, either because of
routine releases or accidental high releases. The
company currently meets EPA air quality standards,
but residents testified at a public hearing that they
thought the standards were too lax.
Fires in industrial areas can release toxic gases.
In June 2001 some Maricopa County families who
claim their health was harmed by smoke from an
industrial fire sued Phoenix for alleged environmental racism. (Arizona Republic) The class-action
lawsuit claims two decades of zoning decisions and
41

Fig. 5-1. Industrial zoning in Tucson and Pima County. Sourc: Pima County Technical Services

42

Fig. 5-2. General location of facilities with hazardous waste permits from Pima County
Department of Environmental Quality (by zip code). A permit does not imply discharge of
hazardous materials, but regulation of hazardous materials used by the facility. The list includes
small facilities such as dry cleaners as well as large industrial production facilities. Compare
with Figs. 2-9 and 6-3 showing distribution of people by race and income. Source: Pima County
Department of Environmental Quality

43

tax credits were used to lure chemical companies
and led to the situation. The lawsuit says more
than 1,000 Phoenix residents suffered illnesses from
asthma to rashes to eye problems as a result a fire
at the Central Garden and Supply Warehouse. The
city denied any responsibility or any proven health
problems from the fire. The suit has not been
resolved. There has not been a similar situation in
Tucson, but there is potential. Several years ago,
Tucsonans on the south side had problems when a
large tire storage area caught fire and burned for
days.
Mines and Smelters
Pima County has three major copper mining
areas and is adjacent to a fourth. It has no active
smelters. The largest active mining area in Pima
County is between the San Xavier District of the
O’odham Nation (partly on District property) and
Green Valley. The mine was located there before
Green Valley became the large community it is today
and the thousands of people who moved to that area
were or should have been aware that the mine would
be their neighbor since the tailings ponds are a predominant feature of the horizon, although people
may not have been fully aware of the possible
impacts. The O’odham Nation to the north, however, predates the mine. The Bureau of Indian
Affairs assisted in drawing up a long term lease that
became quite controversial among tribal members,
mainly for financial reasons.
The major impacts of the mine result from
blowing dust, possible contamination of groundwater,
changes in land use, and aesthetic qualities. The
large elevated tailings ponds are a predominant landscape feature west and northwest of Green Valley.
The company has made attempts to vegetate the
slopes with mixed success. Note in Chapter 3 that
the particulate levels are relatively low in the Green
Valley area. The Pima Association of Governments
has studied the groundwater impacts intensely. The
potential contamination areas are continuously monitored and measures taken to assure that contaminants
do not reach groundwater. There is anecdotal evidence of pollution of washes on Indian land, however.
Another mining area, the Silverbell Mine, is
on the northwest side of the metropolitan area, west
of Marana in a sparsely populated area mainly occupied by ranchers. Proposed new mining could
be within the newly created Ironwood National
Monument (one of the first accomplishments of

44

SDCP), although new mining is not allowed under
current management. There are efforts in Congress
to allow mining in the National Monument or
remove the areas of mining potential from the designated boundaries. In either case, impacts would
not be felt disproportionately in minority and lowincome neighborhoods.
Ajo was at one time a major mining and smelting area, but the mines are closed. At the time of
active mining, per capita income in Ajo was higher
than many other parts of Pima County. This is not
true today. There are rumors, however, that the mine
will reopen. The company has secured an air quality permit for the mine in case economic conditions
are favorable for reopening the mine, but they did
not request a permit for the smelter, according to
PCDEQ.
Just outside of Pima County is the San Manuel
Copper Mine. As discussed in the air quality section,
the San Manuel smelter at one time affected the
San Pedro River area within Pima County, but it is
closed now for economic reasons, although copper
processing still occurs there . The SDCP will have
no impact on this mine.
Sand and gravel mining is an active industry in
the metropolitan area. Sand and gravel operations
can be found along the Santa Cruz River and Pantano
Wash. These facilities are located in areas where
there is a lot of sand and rock material that is replenished at times when water flows in the watercourses.
These facilities are not located disproportionately in
minority and low income areas,
Power Plants and Transmission Lines
Pima County has one major power plant at
Irvington Road and I-10 in an area that is primarily
commercial and industrial. Pima County also gets
power from a variety of other sources, including
coal-fired power plants in Springerville and Page,
and Hoover Dam which produces hydropower at
the dam. Tucson Electric Power is connected to a
regional power grid that exchanges power throughout
a wide area. Major transmission lines radiate out
from the power plant and along the Santa Cruz River.
The power that Tucsonans use, therefore, has many
of its environmental and social impacts in areas far
from Tucson, such as the Navajo Nation. New power
plants are proposed in various locations throughout
central Arizona. Because of limits on new pumping
of water in the Tucson Active Management Area, new
power plants in the Tucson and Avra Valleys are high-

Fig. 5-3. Major wastewater treatment facilities in Pima County.

45

Table 5-1. Present and Historic Landfills in Pima County
1. “A” Mountain
2. Ajo
3. Broadway North
4. Broadway South
5. Cactus
6. Camino del Cerro
7. Catalina 1
8. Catalina 2
9. Columbus
10. Cortaro
11. Cottonwood
12. County Parks
13. Dragoon
14. Harrison
15. Ina Road
16. Irvington
17. La Cholla
18. Los Reales
19. Marana1
20. Marana 2
21. Mission
22. Old Nogales
23. Prudence
24. Rio Nuevo N.
25. Rio Nuevo S (Congress)
26. Rio Nuevo S (Nearmont)
27. Rita Road
28. Ryan Field
29. Ryland
30. Sahuarita 1
31. Sahuarita 2
32. Saint Mary’s
33. Silverbell/Jail Annex
34. State Pit
35. Tangerine
36. Tumamoc
37. 29th Street
38. Vincent Mullins
39. Walnut

1953-1962
1974-present
1961-1972
1950s-1962
1959-1961
1973-1977
1965-1970
early 1970s-1991
1960-1962
1965-1967
1973-1985
1970-1973
1964-1966
1969-1996
1971-1984
1978-1988
1968-1971
1967-present
1969-1971
1972-1983
1963-1970
1965-1970
1974-1978
1960-1971
1953-1960
1960-1967
1972-1977
1973-1977
1960-1965
1968-1973
1973-present
1963-1973
1966-1975
1968-1970
1983-present
1962-1966
1963-1967
1976-1987
1961-1965

Source: Pima Association of Governments
Only includes landfills started after 1950.

46

Fig. 5-4. Active and Abandoned Landfills in Pima County.
Source: Pima Association of Governments.
47

ly unlikely. Transmission lines, however, are proposed, especially one that would traverse the Avra
and Altar Valleys, relatively close to some sensitive
areas such as the Ironwood National Monument.
While these lines would have environmental impacts,
they are not expected to have disproportionate
impacts on low-income or minority areas.
Wastewater Treatment Plants
Wastewater treatment plants are, for the most
part, located along the river at the downstream end
of the community so that sewage can flow by gravity
from homes and businesses to the treatment plant.
For this reason there are no major wastewater treatment facilities located in the downtown area, or the
south side. Pima County is responsible for most
of the wastewater treatment in Pima County. The
two largest plants are along the Santa Cruz River
at Roger Road and Ina Road, away from residential
areas. (Fig. 5-3) These two plants treat most of
the wastewater produced in Pima County. The most
significant negative impacts of the wastewater treatment plant are possible water quality problems and
the smell. People traveling along I-10 can sometimes detect a distinct odor from the Roger Road
Plant and less so from the Ina Road Plant. People
most affected by this live along Silverbell Road and
vicinity in the Camino del Cerro road area down to
an area south of Ina Road. None of this area is
minority or low-income dominated.
In addition there are smaller wastewater
treatment facilities in outlying areas such as Avra
Valley and Green Valley. These small facilities have
little impact on minority or low-income areas.
In some areas it is not feasible to connect
to the community wastewater system and people
use septic tanks for their household wastewater.
The County Health Department has jurisdiction over
approval of new septic tanks, under state regulation.
The major low-income and minority neighborhoods
in the area are connected to the county system,
although some individual homes may remain on septic tanks. The majority of septic tanks tend to be
in the outlying areas. In some of these areas people
are liable to have their own wells. If problems
occur because of poor maintenance or placement,
the well water may be contaminated. This has not
been a major problem in Pima County and does not
disproportionately affect disadvantaged areas.

48

Landfills
Landfills have generally been sited near the edge
of settled areas. This is especially true for periods
when transportation was not as easy as it is today.
The prehistoric inhabitants dumped their trash very
close to their villages, forming what archaeologists
refer to as “middens.” They disposed of few, if any,
toxic materials. The early Spanish and Anglo settlers
also dumped their trash very close to home. There
are numerous informal “wildcat” dump sites in
the areas near downtown Tucson and south to 22nd
Street. As the community grew, what was considered
the “edge of town” moved outward as did the dumps
(now called “landfills”). Now the new city and county landfills are located far from what used to be
the edge of town. Fig. 5-4 and Table 5-1 provide
information about the known active and landfills used
since 1950. People still dump their trash illegally
in many places. One such wildcat site is along the
Santa Cruz River north of Camino del Cerro Road.
Here it is easy to find refrigerators, coolers, kitchen
trash, mattresses, and many other things. Some of the
historic wildcat sites have been mapped, but little is
known about them. Known wildcat sites are scattered
around the county with concentrations along Ajo Way
west of the Tucson Mountains, south and east of the
Tucson International Airport, and west of Marana.
(Anon. 1995)
The amount of waste to be disposed of also grew
even more rapidly than the population as affluence
increased and people tended to throw things away
rather than salvage or repair them. It has become
increasingly more expensive to dispose of waste
materials. A growing trend toward recycling has
helped the problem somewhat, but the lack of a market for recycled materials has limited the effectiveness of this method. At one time people were
allowed to salvage materials directly from the landfills, but this has been stopped for safety reasons.
Until 1980 there were few if any state or federal
restrictions on construction of landfills. They could
be built in watercourses, taking advantage of old sand
and gravel pits, for example. They did not have to be
covered or lined. State law now requires that landfills
be out of the floodplain. Federal laws regulate types
of lining and cover. Modern landfills are far different
from what they were even 25 years ago.
An ideal landfill site is either is a ready-made
hole such as a gravel pit away from a watercourse or
in an area where soil can easily be dug. Minimizing
travel time to the landfill is also important to reduce

costs for trash collectors and to minimize wildcat
dumping. Any agency or company proposing to
build a new landfill must go through an extensive
process requiring both federal and state approvals.
Some problems remain, however, from landfills
constructed in past times. The decaying garbage
releases methane but regular monitoring of these
sites has not revealed problematic amounts. The
Hilton Hotel at Broadway and the Pantano Wash
is located on the site of an old landfill. The
hotel owners installed methane scrubbers and must
report problem levels of methane to the Tucson Fire
Department. The hotel has been in place for more
than 15 years with no reported methane problems.
The City of Tucson conducted a study of methane migration from closed landfills in September
1999. The Solid Waste Management Department
studied methane production at five closed landfills
sites in 1998 and 1999. This was a follow up to
a study of 15 closed landfills in 1995-1997. Both
studies indicate that degradation of landfill materials
is very slow in the dry climate of Pima County and
the researchers detected very low levels of methane.
The City has proposed reclamation of one abandoned
landfill site on the south side near Valencia Road
with plans to use it as a park after mitigation measures, but although funds are available for the mitigation, they are not yet available for the park.
(Leverenz and Dillard 2000)
In the early 1990s Pima County began to
look for a site for a new landfill because capacity
in the old one was rapidly declining. A major controversy erupted when one proposed site for the new
landfill was southeast of the Tucson International
Airport. Many people in the area were still reacting
to the TCE contamination from sites near the airport
(See Chapter 4) and felt that their neighborhood
was being chosen once again as a pollution source,
although the site was more than a mile from the
nearest residential area. After great community controversy the site was rejected. The County continues
to expand the existing landfill
on the northwest side of town.
Probably the greatest impact of active landfills stems from the need to transport waste material
to the landfill. This results in considerable truck traffic and some materials blowing off trucks, although
tie-down is required.
Are landfills disproportionately in minority
and low-income neighborhoods? For historical reasons there are abandoned wildcat and designated

landfills in the downtown area near low income and
minority neighborhoods. The active landfills today
operated by Tucson and Pima County , however, are
located away from the urban center. Fig. 5-4 illustrates that contemporary active landfills are not disproportionately in minority and low income neighborhoods. Many of the closed landfills, such as
the Broadway Proper Landfill are also away from
disadvantaged areas.
The Tucson area has no active hazardous waste
disposal site, except for a small site operated by the
University of Arizona near Oracle for disposal of
low level medical waste from the University Medical
Center. State law currently forbids construction of
hazardous waste disposal sites in Arizona, so hazardous wastes are shipped out of state and it is highly
unlikely that any new disposal sites will be proposed
in Pima County.
Roads
Freeways have been a source of controversy
since I-10 was proposed and built from 1958 – 1962
when federal funds became available. (See Chapter
7). Tucson became the first Arizona city to take
advantage of the newly available federal highway
funds when Phoenix declined to build a freeway.
Construction of I-10 opened up many opportunities
for Tucson at a time when it was beginning to have a
rapid growth spurt. The freeway cut through Marana
and along the Santa Cruz River through downtown
Tucson and turned east on Tucson’s south side. It
had the effect of joining Tucson with an easy route
east to New Mexico, west to California, and north
to Phoenix. It also had the effect of damaging and
cutting off some low income areas. Fig. 5-5 shows
the Tucson area in 1955, with the path of the freeway
marked. It closely followed the route of the old
Casa Grande Highway and then ran north of the old
Benson Highway. Construction of that highway had
also affected neighborhoods in its path.
The main difference between the freeway and
the old highways was that the freeway had many
fewer crossings than the highway, effectively cutting
off neighborhoods on both sides of the freeway and
blocking some residents from easy access to the
Santa Cruz River. The freeway right-of-way is also
considerably wider than the highway right-of-way.
I-10 came through just west of Barrio Anita, separated the Kroeger Lane neighborhood from its neighbors, and destroyed an area occupied by minorities
at the Nogales Highway interchange (later the I-19

49

interchange). Thirty families living in the interchange area petitioned the federal government on the
grounds that they did not receive adequate compensation for their destroyed homes. The City of South
Tucson objected to the location of the interchanges
which bypassed businesses there and objected to the
path of the interchange which cut off part of the
town. There were also impacts in the Marana area
where the freeway construction involved taking some
farmland out of production. The newspapers had
numerous stories about the impact of the freeway
on motels and other businesses who were concerned
about loss of business, but scarcely mentioned the
impacts on low income neighborhoods.
Since that time the Phoenix area has built numerous freeways and Tucson has allowed no more,
except for I-19 from Tucson to Nogales. I-10 greatly decreased the travel time from Tucson to Phoenix
and other destinations to the east and west. I-19
decreased travel time to Sonora. New freeways have
been proposed and rejected twice in Pima County
amidst demands for solutions to travel problems and
rancor and public outcry. In January 1970 the Daily
Citizen reported “Giant traffic jams predicted if freeway system isn’t built. Tucson will be smothered

50

by traffic by the mid 1980s if an efficient freeway
system is not built, the director of the Tucson Area
Transportation Planning Agency warned….”
In the 1980s citizens rejected a major freeway
north of the Rillito River. Residents displayed
bumper stickers with admonitions such as “Keep it
Kinky,” referring to the winding road that followed
the bends of the river. They preferred their rural,
quiet life style and wanted to protect the environment. They also argued that freeways are not costeffective.
Most of the new and widened roads are built
in the rapidly developing areas to serve new subdivisions. The City of Tucson asked voters to approve
a 1/2 cent transportation sales tax in a May 2002
election in which nearly 50% was for roads and
interchanges to accommodate growth while less than
18% was to be used for public transit.

Fig. 5-5. Neighborhoods directly affected by construction of I-10 and I-19 (in yellow).
The base map is a 1955 map of Tucson, with the freeway added in blue and access spots in red.

51

52

Chapter Six
Land Use and Housing Issues

“Most recent and rapid population growth in Tucson and the U.S. has taken place on the
urban fringe. Development tends to leapfrog to the outer fringes as developers look for large
parcels of inexpensive land on which to build. People move to the suburbs to enjoy the feeling
of open space and get away from congested traffic and crowded living conditions. … But an
examination of suburbs…reveals some negative aspects of suburban development.”

P

lanning and zoning decisions are made at the
local level and the local communities take
pride in handling land use matters locally, but
many of those decisions have actually been strongly
influenced by federal policies and subsidies. Tucson
would not be the rapidly growing type of community
it is if left entirely to its own devices. These federal
policies have influenced the rate and direction of
growth and contributed to separation of neighborhoods by income and race or ethnicity.

The Impacts of
Federal Policies on Land Use
Land and Housing Availability
“Manifest Destiny” was the slogan as the
American West was acquired and settled. It was
the fate of Americans to occupy lands from coast
to coast and “put them to productive use.” The
federal government encouraged people to settle in
the West by offering nearly free land under the 1862
Homestead Act and the 1875 Desert Land Act. It
made travel west easier when it subsidized construction of cross-country railroads and later land crosscounty highways. These and other subsidies and
policies for wastewater facilities, water supplies, and
others are discussed in Chapter 7. This section
looks specifically at the impacts of federal housing
policies and subsidies on land use patterns for disadvantaged groups and others.
During the Great Depression of the 1930s, many
people lost their homes, jobs, and savings. Banks
failed as did many businesses. Remedies were
needed and President Roosevelt’s New Deal policies
included the Social Security System, the Civilian
Conservation Corps, banking insurance and others.
The most important innovation for housing and land
use was the Federal Loan Bank which later developed into the Federal Housing Administration. It
seemed to New Deal planners that guaranteeing
home loans would give people security in home ownership, help the banks, promote housing construction,

and improve the economy by offering millions of
jobs in construction all in one low cost program. The
government would not loan people money for homes,
but would guarantee private loans.
Before 1940 almost all home construction was
by individual builders who built a small number of
homes each year. Only the wealthy and upper middle class could afford to own a home and more than
half the population rented homes. Home loans generally required a fifty percent down payment, with
the rest to be paid off in seven years. Homes on
farmland were a major exception because most farmers built their own homes, but many farm workers
lived in rental or share-cropping situations.
New Deal planners envisioned a mass production approach to home building akin to the methods
Henry Ford had devised for the auto industry. This
would greatly speed up the number of new homes
available and increase the number of jobs in construction. Congress passed the Federal Housing Act
in 1934. The government would provide mortgage
insurance that would guarantee 20-year loans for up
to 80 percent of the value of the home. This was
liberalized even farther in later years. This meant
that many more people could afford to buy a home
and at times it was actually cheaper to buy than rent.
While this program was designed to accomplish
these goals, it was also designed to be run in a fiscally sound manner so that the government would
not have to make good on very many loan defaults.
To assure fiscal soundness, the government adopted
policies which the designers believed would add stability and predictability to the process. These policies strongly influenced the type of towns we see
today in the West and other rapidly growing parts of
the country.
After World War II, mass production of homes
became the norm. The federal government offered
inducements to builders who would develop entire
subdivisions, building infrastructure as well as
homes. The government would provide a “conditional commitment” to guarantee the mortgages which in

53

turn allowed the developer to gain financing for the
property with very little capital of his own. During
World War II the federal government had helped
stimulate the mass production approach by paying
for construction of housing for defense workers.
“Connie Chambers” in Tucson was one such project.
In 1944 Congress passed a similar program as part of
the G.I. bill offering veterans housing loans at even
more favorable rates. The industry was ready to start
building millions of homes by 1950.
The two agencies adopted standards that have
become the standard nationally for homebuilding and
strongly influenced how communities went about
zoning. They explicitly favored loans for new construction in the suburbs, declaring that “interior locations in the metropolis have a tendency to exhibit a
decline in quality.” They seldom guaranteed loans
to refurbish older homes or to build on vacant property in the city. Older industrial communities got
far fewer loans than did rapidly growing towns in
the West. The policy manuals emphasized privacy
and homogeneity rather than diversity. They favored
single-family dwellings and did not approve of
the traditional small-scale rental properties, such as
apartments for the grandparents over the garage.
They counseled developers not to arrange streets as
grids, but preferred curving avenues and cul-de-sacs
to preserve privacy. Neighborhoods were to contain
all one kind and price of housing on similarly sized
lots. This meant that everyone who lived in a
particular subdivision was of a similar income level.
Homes were to be occupied by traditional families,
so female heads of households had difficulty qualifying for FHA mortgages.
The policies also favored developments that had
curving roads and cul-de-sacs to promote privacy.
Fig. 2-7 is an example of such a development in
Tucson. There are only a few access roads to the
main road out of the subdivision. While the curving
streets may have more charm than the rectangular
street grid, they do make it difficult to walk places,
although cul-de-sacs are safer places for children to
play. A person may live just a short distance from
some desired destination, but with the street pattern
may mean that it is actually much farther, possibly
out of walking range.
Emerging Trends of Real Estate commented
“Areas with sensible zoning (integrated commercial,
retail and residential), parks, and street grids with
sidewalks will age better than places oriented to
disconnected cul-de-sac subdivisions and shopping

54

strips, navigable only by car.” (Anon. 2001j)
Most insidiously, the agencies strongly disapproved of neighborhoods that were not racially
homogeneous. Builders were explicitly advised to
write restrictive covenants into all deeds, legally barring purchase by specific groups. This type of deed
restriction had begun much earlier, but was federal
policy until the Civil Rights Movement of the 1960s.
A deed written in 1929 in Country Club Manor in
Tucson, for example, stated “No part of said property
shall be sold, conveyed, rented, or leased in whole or
in part to any person not of the White or Caucasian
Race, except such as my be employed thereon as
domestic servants by the owner or tenant of any
lot of said property. … the restrictions referring to
persons not of the White or Caucasian Race shall be
perpetual.” This particular deed restriction was still
attached to the deed when the house was last sold
in the 1980s, although this type of deed restriction
had been outlawed two decades earlier and cannot be
enforced. While FHA and VA are no longer allowed
to discriminate by race or creed, they still prefer to
make loans in neighborhoods that are homogeneous
by income level.
The old neighborhood concept that included corner grocery stores and other convenient shops was
scrapped in favor of special areas zoned for commercial uses. This meant that for the most part it
was not longer possible to walk to the store or work
and people living in these areas were necessarily
dependent on automobiles. In many cases children
had to be driven to school or recreation. More than
one car often became a necessity. See Chapter 3
for a discussion of the role that the federal highway
program played in transportation.

Public Housing
Another effort that had its beginnings in the New
Deal of the 1930s was the attempt to provide
low income public housing. The Housing Act of
1937 called for slum clearance and every new public
housing unit had to replace a substandard one. This
did not increase the low income housing supply but
replaced old housing with new. In 1941 Tucson
applied for federal funds for public housing and in
1942 plans for construction of “La Reforma” began.
The project included 159 residential units and a
health clinic. The first residents were families of
defense workers. By 1947 there were only 12 low
income families in the unit. The rest were defense
workers above the income limits, but this began to

change when people above the maximum income
level were evicted. It was not until 1963 that La
Reforma was integrated.
In 1949 Congress passed the Housing Act that
called for construction of 810,000 new public
housing units. After considerable community
debate and acrimony, Tucson finally applied for
funds in 1963 and in 1967 residents began to move
in to the first new units in a project that came to
be known as Connie Chambers. To make way for
this project 263 buildings were demolished in Barrio
Viejo.
By 1974 the Star claimed that the city had built
“an instant ghetto” and supported Councilman
Romero’s proposal to move La Reforma families
into scattered-site units, but this had to wait until
money was made available to acquire those units.
In 1995 the city finally received a grant to do a
comprehensive redevelopment plan for the area and in
1999 demolition of the projects began along with a
plan to build 60 affordable homes throughout Barrio
Santa Rosa, a day-care complex and other amenities.
In No Me Veas Diferente, former project residents
recall the many good times and neighborhood spirit
of the projects as well as the bad times that mostly
came later when crime and gangs became problems.
(Kelly 2000)
In 1993 the People’s Law Center issued a report
detailing racial discrimination and neglect in Tucson’s
public and federally subsidized housing. (Bohlke
1993) The report concluded, among other things, that
“The promise of a home in decent, safe and sanitary
condition regardless of income has yet to be fulfilled.”
Urban Renewal
In 1949 Congress passed the Housing Act, part
of which came to be known as “Urban Renewal.”
This Act enabled city governments to use their eminent domain powers to seize property in areas identified as slums, purchase it with the help of federal
funds, and then sell the assembled area to a private
developer for redevelopment. An important goal was
to provide good housing in well-planned neighborhoods. The funds available, however, could only
eliminate some 200,000 dwellings out of 5 million
slated for removal. A 1954 amendment authorized
the FHA to guarantee loans on older preexisting
properties, but it was many years before Congress
would change the racial segregationist policies of
FHA. The program fell far short of its goals and in
many cases the low-cost housing that was eliminated

was replaced by high-cost luxury housing or offices
and the area was otherwise made unaffordable for
the previous residents who were forced to move out
without getting substitute housing.
By 1957 Tucson officials were concerned about
the movement of people from the center of town
to the suburbs, with the consequent decline of the
downtown area. Shopping malls gradually replaced
the downtown area for customers. Urban renewal
appeared to offer a good solution. In 1962 the
decline of downtown was becoming serious and officials proposed using urban renewal funds to eliminate the “slums” and replace them with a complex of
buildings that would revitalize downtown. There was
enormous opposition from people who lived in the
neighborhood, from people concerned about historic
preservation, and many others. In 1965 the urban
renewal proposal was put to vote along with a proposal for a new community center and was defeated.
The city council put a new proposal before the voters
who approved it in 1966.
Many Hispanic residents of the area were outraged. The barrios were home and the old church
plaza was a traditional civic center for the Mexican
residents. People not only wanted homes, they wanted to maintain their historic neighborhood and the
social relationships with which they were familiar.
In protest, some as yet unnamed residents put sugar
in the gas tanks of the construction equipment parked
at El Tradito.
The pro-renewal forces won out and in 1972
the city received a $2.25 million dollar loan. The
bulldozers moved in and as Sonnischen said “the old
landmarks vanished, including Sabino (Gay) Alley,
several old hotels and stores, the building which had
once been the Alianza headquarters, and dozens of
saloons, rooming houses and business blocks whose
900 inhabitants scatters – uprooted and in many
cases, resentful.” As the Arizona Daily Star reported in December 1978, “the old adobe homes that
sheltered generations, the small, productive gardens,
and the security of their neighborhood where everyone knew each other, shared the same culture and
spoke Spanish … Those who lost their homes …
were paid off but the money couldn’t compensate for
the psychological blow…” In place of this barrio
today the City has the Tucson Convention Center and
the city-county government complex to the north.
Both have helped to maintain downtown as an attractive place to work and recreate. Most of the old
stores, such as Steinfelds, however, closed.

55

Table 6-1 Pima County and City of Tucson Selected Zoning Categories
COUNTY ZONES
Zone Descriptive Title

Area

CITY ZONES
Zone Descriptive Title

RURAL
IR
Institutional Reserve
RH
Rural Homestead
GR-1 Rural Residential
SR
Suburban Ranch
SR-2
Suburban Ranch Estate
SH
Suburban Homestead

1,568,160
180,000
36,000
144,000
72,000
36,000

IR
RH
--SR
--SH

36,000
36,000
16,000
8,000
7,000
7,000
5,000
6,000

-RX-1
RX-2
R-1
R-2
R-2
-R-3

6,000

R-3

8,000
8,000

MH-1 Mobile Home
MH-1 Mobile Home
(Multifamily or Park)

RESIDENTIAL
ML
Mount Lemmon
CR-1 Single Residence
CR-2 Single Residence
CR-3 Single Residence
CR-4 Mixed-Dwelling
CR-4 Mixed-Dwelling
(Single-Family)
CR-5 Multiple Residence
5,000
CR-5 Multiple Residence
None
CMH-1 Mobile Home - 1
CMH-1 Mobile Home - 1

BUSINESS/MIXED USE
MR
Major Resort
871,200
--TR
Transitional
None
TR
Transitional (Residential) 10,000
TR
Transitional (Residential) 10,000
RVC
Rural Village Center
None
-CB-1 Local Business (Res.)
10,000
CB-1 Local Business(Nonresi.) None
CB-2 General Business(Res.) 7,000
CB-2 General Business(Nonres.) None
--TH
Trailer Homesite
18,000
---MU
Multiple Use (Re.)
7,000
MU
Multiple Use (Re.
7,000
MU
Multiple Use (Nonres.) None

56

Area

Institutional Reserve*
Rural Homestead*

1.568,160
180,000

Suburban Ranch*

144,000

Suburban Homestead

36,000

Residence
Residence
Residence
Residence (Multifamily)
Residence

36,000
16,00
7,000
None

Residence (Single-Family)
Residence (Multifamily)

-O-1 Office
O-2 Office
O-3 Office
O-3 Office (Single-Family)
O-3 Office (Multifamily)
RVC Rural Village Center*
NC Neighborhood Comm.
C-1 Business (Residential)
C-1 Business (Nonresidential)
C-2 Business (Re.)
C-2 Business (Nonres.)
C-3 Business (Residential)
C-3 Business (Nonresidential)
RV
Recreational Vehicle Park
OCR-1 Mixed Use
OCR-2 Mixed Use
PAD Planned Area Dev.
MU Multiple Use (Sing.Fam.)
MU Multiple Use (Multifam.)
MU
Multiple Use(Nonres.)

7,000
7,000

10,000
None
None
5,000
None
10,000
None
None
None
None
None
None
7,000
None
None
40 acres
7,000
5,000
None

57

Fig. 6-1. Generalized zoning map of Eastern Pima County.
Source: Pima County Technical Services.

Fig. 6-2. Buying power in 1962. Adapted from Cole’s Directory.

58

Fig. 6-3. Income distribution in Pima County in 1990. Source: U.S. Census.

59

Some people still are suspicious and resentful
today as the City of Tucson considers the Rio Nuevo
Project. Planners have been sensitive to these concerns and the possible problems of gentrification
with accompanying increase in land values, rents,
and taxes.

Beginnings of Planning and Zoning
Before the 1930s zoning was virtually unknown
in the United States. In Tucson, planning and zoning
procedures in the city began to be developed in the
1930s, but it was not until the 1950s that the county
got that authority and also implemented planning and
zoning. While in some other areas zoning was
a response to problems of overcrowded slums and
unsanitary conditions, in Tucson zoning got its start
as a way to direct land use in an area that was
beginning to expand outside traditional living areas.
As Gertrude Mason, the person most responsible for
starting planning and zoning in Tucson, said in the
1930s:
“As we see it, a city plan guides the city’s
growth; it benefits both the present and the
future generations. … We remember the
Tucson of the past, when the Spanish atmosphere was much more apparent, when modern progress had not given us so many conveniences and taken away so much of the
city’s charm. We hope it is not too late
to save some of the things that have made
Tucson different.” (Mason manuscript
AHS)
She went on to call for underground utility wires,
development that would be contiguous (rather than
what we now call “leapfrog” development), and that
it be kept compact to facilitate installation of sewers,
etc. She believed that compact development was
much more cost-effective than what we now call
“sprawl.” Finally, she advocated for a subdivision
approval processes that would include requirements
that developers provide parks and schools. Some of
Mason’s ideas were not implemented but fortuitously
are reflected in the SDCP proposals.
At the end of the nineteenth and start of the
twentiety in Tucson land uses tended to be mixed
so that a neighborhood might contain residences of
various income levels, corner stores, and other amenities. For the most part people lived within walking
distance of work and shopping because the town
was small and automobiles were rare, although the
streetcar did run all the way to the university.
60

Roy Drachman recalled that
“A common sight on Tucson streets in
almost every part of town were corner
Chinese groceries. They were small stores
in the back of which the family lived and
were an important part of Tucson life. …
The Chinese stores did not generally sell
meat, leaving that to a few meat markets
located along Meyer Street, Congress Street,
and in one or two larger grocery stores in the
downtown area.” (Drachman 1999)
America’s first comprehensive zoning code
adopted in New York City in 1916 had a pyramidal
approach to permitted uses. In the residence zone,
nothing but residences were permitted. In the commercial zone both commercial and residential use
was permitted. In the industrial zone all three kinds
of uses were allowed. That is, residences were
allowed anywhere.
In 1909 Los Angeles took a very different
approach and created a multitude of different types
of zones providing the framework for the exclusive
“single-family only” residence zones. This became
the model for most zoning codes today. The total
exclusion of uses from zones and their isolation by
vast distances really took hold after World War II.
At a time when the U.S. Supreme Court was
outlawing racial segregation, economic segregation
was becoming institutionalized in zoning codes.
(Gerckens 1994)
Since local zoning policies developed at about
the same time that the federal policies above developed, it is no surprise that they developed along the
same lines. Zoning today divides the community
into areas in which the lot sizes are fairly similar to
each other as are the costs of the house. Commercial
and industrial uses are placed in their own zones with
transition areas between them. At the present time
Pima County has residential zoning classifications
listed in Table 6-1. Most of the Catalina Foothills
area is zoned for large lot single family residential
uses, some town house uses, and commercial uses
such as shopping centers and professional offices at
some major intersections. Golf courses are also
located in the area, but no industry or low income
housing areas. Industry is primarily located along
the major transportation routes – the railroad, the
interstates and the airport. Fig. 6-1 shows general
zoning, with all single family residential zones
grouped together for simplicity and all commercial
zones grouped together. Some rezoned areas are an

exception to this general pattern.
Parks
Parks and recreation areas have been important
to Tucsonans for more than one hundred years.
Plazas were integral to the Spanish-era town. (See
Fig. 2-5). The Elyssian Grove was a major gathering
place for Tucsonans until the early 20th century.
Neighborhood parks such as Himmel Park and
Estevan Park are significant as well as the large natural parks such as Tucson Mountain Park and Saguaro
National Park and the National Forests. Access
to the public lands for hunting, fishing, picnicking,
and camping is a major attraction of Pima County.
Fig. 6-4 shows the location of city and county parks
in the metropolitan area. Parks are located throughout the city, especially in the older areas. Newer
areas of the city and county have far fewer neighborhood parks or recreation areas, although golf courses
are located in some of those areas.

Impacts of Land Use Policies

Since most minority and low-income neighborhoods are within city limits of Tucson and South
Tucson much of the discussion below relates to those
incorporated areas. Much of the sprawl, however,
occurs in the unincorporated areas. This makes coordinated planning difficult.
While planning and zoning have played important roles in bringing order to a previously somewhat
chaotic land use pattern and in preserving open
space, it has also played the role of excluding people
of lower income levels from large parts of the region.
Fig. 6-2 is a generalized map of income levels in the
area derived from Cole’s Directory. This directory
was produced to give merchants an idea of which
parts of the community had the most wealth and
were thus better potential customers. Fig. 6-3 is
a map of income levels based on the 1990 census.
(Similar information is not yet available for the 2000
census). Although the community has grown considerably, the areas of higher and lower income are still
clear. Whereas in the past people by necessity lived
close to their place of work, they now are frequently
unable to do so.
The combination of FHA and VA policies, and
the development of exclusionary zoning codes have
led to an assumption that in a place like Tucson
this is normal as well as preferred. Cities such San
Francisco or Paris follow quite a different pattern in
which people may live above stores, in which hous-

ing prices are more mixed, and in which shopping
and work are either close by or convenient by public
transit. The older part of Tucson tends to have more
mixed uses than newer areas.
An SDCP study of housing to be issued within
the next few months will go more deeply into these
issues, including mortgage and insurance policies
and how federal policies have actually functioned on
the Pima County level.
Pima County still has areas of strong minority
residence despite four decades of civil rights legislation and a county-wide increase in percentage of
minority population. This is partly by choice of
residents and partly because of the exclusionary policies discussed above.
In the late 19th and early 20th century, communities considered mixed land uses the norm. In
most cities people were able to walk to work and
stores. While some neighborhoods had homes for
wealthy people, they were usually not far from the
places where their employees lived and people could
walk to the market.
In 1926 the U.S. Supreme Court ruled that it was
legal for communities to zone land for specific uses.
This came when the automobile was becoming more
prominent, and growing cities began to take on a new
form. Present day cities in the sunbelt are designed
with the automobile in mind. In cities like Tucson
and Phoenix, it is difficult for people to live in most
parts of town unless they own at least one vehicle.
People depend on cars to get to work, go to the
store, take children to activities, and many other
tasks. People who are unable to drive for age, health,
or economic reasons may become isolated or have
depend on others to go to the store, library, school
or doctor.
Urban Sprawl
The Environmental Justice Research Center at
Clark Atlanta University (www.ejrc.cau.edu) has
done studies on a wide range of environmental justice issues. A recent publication, Sprawl Atlanta,
looks at the social equity dimensions of uneven
growth and development.
“Ask ten people to define sprawl, and you
will probably get ten different definitions.” In
this report, we define sprawl as: random unplanned
growth characterized by inadequate accessibility to
essential land uses such as housing, jobs, and public
services like schools, hospitals, and mass transit.
Sprawl-driven development has negatively impacted

61

the population, jobs, investment capital and tax base
of the urban core. Typically, strip centers, low-density residential housing, and other isolated, scattered
developments leapfrog over the landscape without
any rhyme or reason.

dependency and limited economic opportunity, loss
of population in the core area, increased energy consumption and air pollution from the many miles that
people travel to get to places from the suburbs, and
disparity in school districts.

“ Sprawl creates a car-dependent citizenry.
Urban sprawl is consuming land faster than
population is growing in many cities across
the country. Historically, the decentralization
of employment centers has had a major
role in shaping metropolitan growth patterns.
Government policies buttressed and tax dollars subsidized this decentralization through
new roads and highways at the expense of
public transit. Tax subsidies made it possible
for new suburban employment centers to
become dominant outside of cities, and to
pull middle-income workers and home owners from the urban core. …”

Other Forms of Community Planning
“This increased exclusion of uses from zones,
coupled with a penchant for low development density
(low density is best density) resulted in vast spread
cities of huge zones of developmental uniformity and
life-style conformity. Most commonly, this meant
the exclusion of all but the more affluent from participation in the new modern suburban-American society.” (Gerckens 1994) What are the alternatives to
sprawl and to exclusionary zoning? The following
are a few examples of ways other communities coordinate land use.
In Calgary, Alberta, Canada the entire metropolitan area is made up of “communities.” Sprawl
never got started in Calgary. When a developer
applies for permission to build, he does not plan
a subdivision but a community. The community
must be contiguous to the already developed area
and must include provisions for a whole range of
facilities necessary for that community. It must have
provisions for different types of housing at different
prices, a shopping area, school, parks, church, and
access to public services. It must also have
provisions for connecting to the public transit system. The edge of town is clear. The need
for the new neighborhood must be demonstrated.
(www.gov.calgary.ab.ca)
Another approach is termed “traditional neighborhood development.” This land use pattern
attempts to imitate in modern form the old concept
of “village” in which people lived near or above
stores and workplaces and walking was the normal
way to get places. It incorporates too many factors
to list here. The major components are connection
to the regional structure of transportation and other
infrastructure, incorporation of natural components
and parks, a balanced combination of houses, shopping, workplaces, and recreation areas, public buildings, sidewalks, easily accessible commercial buildings, and ecologically sensible design. Civano, on
Tucson’s far east side was designed with some of
these properties in mind.
Suburban Town Centers are favored by some
suburban residents. In the early 1990s, nationwide

The book discusses the many ways in which
sprawl affects low income and minority residents
of Atlanta. They point out that all Americans pay for
sprawl with increased health and safety risks, worsening air and water pollution, urban decline, disappearing farmland and wildlife habitat, racial polarization, city/suburban disparities in public education,
lack of affordable housing, and the erosion of community. The authors believe that sprawl-fueled
growth is pushing people further and further apart
geographically, politically, economically, and socially. Some of the economic impacts they discuss are
mentioned in Chapter 7 of this report.
The authors conclude after extensive research
that the major impacts of sprawl on Atlanta’s
minority and low income populations include
automobile dependency, urban infrastructure
decline, core city abandonment and disinvestment,
increased energy consumption, air pollution, threat
to farm land and wildlife habitat, and diminished
quality of life. The social effects include
urban core poverty, unemployment, limited mobility, economic disinvestment, social isolation, city/
suburban school disparities, public health threats,
and safety risks.
While this study is specific to Atlanta, many of
the conclusions would undoubtedly be applicable to
Pima County if a thorough study were done. Some
clear similarities to Pima County include automobile

62

surveys were conducted to determine what features
and amenities home buyers would most like in a new
community. One surprise was that people said they
preferred “town centers” with a village green surrounded by shops and civic buildings to strip malls.
…” (McMahon 1999) In many ways this is a
return to the Spanish-derived downtown of Tucson a
hundred years ago.
Another approach to containing sprawl is to
set an urban growth boundary around a community
beyond which development is only allowed under
certain conditions which vary in different proposals.
A proposal on the Arizona ballot in 2000 would
have required cities and counties to set such a boundary beyond which new development would only be
allowed as an exception and beyond which extension
of certain services would be denied. Decisions were
left to local communities rather than mandated at the
state level, although the state did set basic requirements. Existing uses were allowed to remain. The
initiative failed. It was patterned on a similar law
in Oregon that has been in effect for some thirty

years. This approach does not deal with issues of
exclusionary zoning but is primarily aimed at controlling sprawl.
Inclusionary zoning is an effort to incorporate a
certain percentage of low cost housing in new higher
cost developments. Sometimes this takes the form of
requiring that rentals be no higher than a maximum
rate for a given number of years and at other times it
requires a mixture of owner-occupied housing types.
This approach is most successful when coordinated
with the availability of public transportation. As
one Hispanic south side resident said in a personal
conversation, however, “We wouldn’t move out to
the suburbs because few of us own even one car
and because our extended families live here. In a
suburban neighborhood there would be no way for
the grandparents to live next door or in an attached
apartment.” On the other hand, in neighborhoods,
such as Menlo Park, people of the younger generation with relatively high incomes do move to areas
such as the Tucson Mountains foothills.

63

Fig. 6-4. City and County Parks in Eastern Pima County.
Source: Pima County Technical Services

64

Chapter Seven
Fiscal Issues

“The result of low density sprawl is that the total miles of water and wastewater infrastructure needed to serve the same number of people is doubled, tripled, quadrupled, and more.
And who pays: You and I do, through our taxes. …”
Jim Woods in Kemp-Rye 2001.

T

his chapter looks at four questions:
1. To what extent does growth pay for
itself in Pima County?
2. Are the current growth patterns in Pima
County the most cost-effective?
3. Who pays and who should pay for the costs
incurred in making growth possible?
4. Are disadvantaged groups disproportionately
affected by growth and land use policies?
This study is, however, in no way a comprehensive growth study for Pima County. This
need for such a study is high. For many years
officials have assumed that population growth is
both economically beneficial and necessary. They
have also seldom questioned whether the current
growth patterns are the most cost-effective ones.
On the other hand, there has been discussion of
who should pay and the concept of impact fees has
been at issue.

Who Pays for Growth?
For more than 125 years, the federal government has paid a significant role in providing land
and money to encourage people to settle the west.
In the nineteenth century the government was
eager to assure to protect the recent acquisitions
of Arizona, California, and other states and territories from reconquest by previous owners.
Congress passed acts to give settlers land, and
to give funds to state and local governments for
various projects that would encourage migration
to the West. The amount of federal subsidies has
decreased since the 1970s and 1980s and more
and more of the costs are borne now by state
and local government. These local governments
must now decide how to fill the financial gap.
Discussion of impact fees center around how the
costs of growth should be distributed between
existing residents and newcomers. There is, however, also increased discussion of reduction of
the total costs of growth through more systematic

planning for infrastructure and land use planning
that reduces the need for infrastructure.
The purpose of this section is not to conduct a
study of the costs of growth or the costs of sprawl.
This study has yet to be done for Pima County
and will require economic expertise. This chapter
raises questions that still need answers and asks
what impacts rapid population growth and urban
sprawl may have on low income and minority residents in Pima County.
The Federal Role
The measures discussed below are the major
ways in which taxpayers throughout the nation
have helped pay for facilities in rapidly growing
parts of the nation, most of which are in the
“Sunbelt.” Many of these measures also benefited the less rapidly growing parts of the nation,
but benefiting the Sunbelt disproportionately. In
the 1970s, for every six tax dollar paid by an
Arizona, ten dollars came back to Arizona. Since
then, that ratio has continually decreased The
contributors were taxpayers in the “Rustbelt” of
the Midwest and East. While those taxpayers
helped to subsidize growth elsewhere, their cities
were often losing population and experiencing
decaying infrastructure. Arizonans who have a
reputation for mistrusting the federal government
have benefited from handsomely from federal
subsidies.
The section below very briefly describes the
most significant ways in which federal taxpayers
have contributed to population growth and land
use patterns in Arizona and other parts of the
West. Gerald Nash describes many of these
programs in much more depth in The Federal
Landscape. In some cases the laws were specifically designed to encourage population growth
in the West while in other cases the laws had
that unintended consequence. (Nash 1999) In
contrast to the prevailing thought, however, the

65

U.S. General Accounting Office in 1999 found
that it was unclear to what extent federal policies
were responsible for sprawl. They did find evidence that federal policies may have contributed
to sprawl but that a whole range of local policies,
economic factors, and social conditions were also
responsible. (Anon. 1999)
Arizona Statehood Act (1912)
At the time that a territory entered the Union,
the federal government was deemed to own the
land. It could distribute the land to individuals
and businesses. When a state achieved statehood
status, the federal government distributed certain
lands to the state government. Under the statehood act for Arizona and the Arizona constitution, the revenue from those lands is supposed
to help pay for education. The land initially
allocated to Arizona largely came in a checkerboard fashion with certain lands in each township
allocated for building schools. The state could
choose other lands and the federal government
could later trade state lands for lands it wished
to designate for federal purposes. Because of
this checkerboard approach, state lands are scattered around the state. This has led to conflicts
between state and local governments about how
state land should be used, since the state earns
revenue both from leasing the land and selling it
and is supposed to maximize that revenue for the
benefit of education. Since statehood came after
many parts of the state had already been settled,
some of the best farmland and mining property
was already occupied under the acts described
below and did not become part of the state’s
pool.
The Homestead Act (1862) and
Desert Land Act and (1875)
Federal policies to encourage growth began with
such laws as the Homestead Act and the Desert Land
Act that provided land at a very low cost to people
who agreed to develop it. Under the Desert Land
Act anyone could obtain 640 acres of land for very
little money if they would develop it for use. A family could apply for land for each adult member and
assemble enough land for a working farm or ranch.
Because of the arid conditions in the southwest, much
larger tracts of land were needed for success than
66

in the wetter parts of the county where a farmer
could succeed on just a few acres.
Federal Preserves
At the time of statehood, the federal government set aside certain lands for federal use. In
addition, the federal government acquired other
lands in later years for various purposes such
as National Forests, National Parks, and military
bases. At the present time, the federal government controls about 24,000,000 acres of Arizona
land, including about 750,000 in Pima County.
Indian lands include 2,491,000 acres in Pima
County and 20,239,000 statewide. Most of
the federal lands are available for multiple
uses including grazing, lumbering, and mining.
People have grazing leases, for example, on
most of the National Forest and Bureau of Land
Management lands in Arizona. Mining on federal lands is discussed below. The existence of
some of those federal lands, such as Saguaro
National Park, Organ Pipe National Monument,
and Sabino Canyon contribute greatly to attracting tourists to Pima County.
The Mining Laws of 1872
The federal government believed it was important that the valuable resources in the West should
be utilized and prospectors should be encouraged
to locate and develop mineral resources. Anyone
could make a mining claim on most federal lands
and in return for a certain amount of annual work
on that claim receive full use of the land for virtually nothing. These laws played a major role in
subsidizing Arizona’s mining industry that formed
a major part of the backbone of Arizona’s economy and played a significant role in the growth of
the state. These laws remain in effect to this day
and are sometimes used to claim federal land then
use it for purposes other than mining.
Water Development
The federal government began to build and
subsidize western water projects early in the twentieth century. Roosevelt Dam on the Salt River
was the first big dam building project of the newly
formed Reclamation Service (later the Bureau
of Reclamation). Hoover Dam and later Glen
Canyon Dam were among the many Bureau proj-

ects with multiple purposes including power production. This cheap federally subsidized power
was significant to Arizona’s development. These
federal projects combined with agricultural water
projects in the Yuma and Phoenix areas played a
major role in how Arizona grew.
The most recent federal water project is
the Central Arizona Project (CAP). Originally
proposed to save agriculture by providing cheap
water, the project is now primarily operated to
satisfy Indian water claims and provide water for
population growth in Maricopa and Pima counties.
The federal government built the project under
the condition that Arizonans pay back part of the
costs at very favorable interest rates. After some
controversy, the City of Tucson decided to buy the
largest amount of CAP water in Pima County so
the customers of Tucson Water bear most of the
Pima County part of the repayment and operating
costs. It is highly doubtful if Arizonans could
have afforded to build the CAP without federal
assistance. Most people believe that the CAP was
the last great water project the federal government
would subsidize. Without the promise of CAP in
the 1960s, it is very doubtful that Tucson would
have been able to grow as it did subsequently on
its limited groundwater supplies.
The New Deal of the 1930s
The Great Depression affected virtually every
level of society. Banks closed, mortgages were
foreclosed, jobs were scarce, and many businesses
had a hard time surviving or failed. President
Roosevelt initiated a great variety of projects to
help cure the severe problems.
Civilian Conservation Corps (CCC)
The CCC provided jobs for millions of people
nationwide. In Pima County CCC workers built
bridges, picnic areas, restrooms, buildings, small
dams, park facilities, sidewalks and other structures. Many of the facilities in Sabino Canyon,
for example, were CCC projects. Sidewalks in
the Sam Hughes neighborhood bear the CCC seal
today.
Social Security Act
So many older people lost their savings
and old age pensions that Roosevelt believed that

the federal government should guarantee a minimum amount of income for retirees who had been
employed. Social security is extremely important
in protecting the needs of retirees to this day,
although there are doubts about its long-term viability as the number of retirees increases while the
number of wage earners decreases nationally.
One impact of social security is that is has provided a fixed income for retirees allowing them
to leave their homes in other parts of the nation
and move to a warm climate for retirement. One
reason that Pima County his been able to grow
and prosper without a strong industrial base is
the amount of retiree money (Social Security and
private income) that is spent for homes in places
like Rancho Romero and Green Valley as well as
less costly mobile homes parks. The golf course
industry has prospered partly because of incomes
of retirees that moved to Pima County from other
parts of the nation.
Federal Home Loan Bank
The major role that the Federal Home Loan
Bank and later the Federal Housing Administration
have played in making housing available and influencing how communities grow is discussed in
Chapter 6.
Federal Tax Policies
Federal income tax policies encourage people
to buy homes when possible rather than rent and
when changing homes to buy a home of at least
the same price as the previous home. Mortgage
costs and property taxes may be deducted but
rental costs and the costs of refurbishing an old
home may not. As Hanchett (2001) said: “Poor
Americans reaped no benefit from these home
ownership subsidies. Middle-income taxpayers
say small individual gains. The deductions were
largest for the nation’s wealthiest citizens, who
had the greatest income to shelter.” When the
house is sold, the seller has to pay capital gains
taxes on the increased value of the home beyond
a certain level unless the money is used to buy
another home of equal or greater value. This
strengthened the market for more costly homes.
Tax law also subsidizes new commercial construction through accelerated depreciation. The writeoff is greater for new construction than for reno67

vation and since the law forbade write-offs for
depreciation of land, it became more attractive for
developers to buy cheap land rather than higher
cost urban land.
Federal tax law also gives a tax break
for preservation of historic places and this stimulated some urban revitalization. Another tax law
designed to help urban areas is the Community
Reinvestment Act that encouraged lenders to invest
in all neighborhoods, not just suburban ones.
The Federal Highway Act of 1956
After World War II and the Korean War,
President Eisenhower believed that it was important to develop an interstate highway system for
national defense purposes as well as to improve
the opportunities for people to get from one city
to another. The Congress debated whether to
fund the construction through bonds or on a payas-you-go basis. The result was the highway trust
fund in which revenues are collected as taxes on
gasoline sales as well as an initial appropriation of
$25 billion. Tucson was the first Arizona city to
apply for and get highways for its section of what
became I-10. The construction program was very
ambitious and resulted in thousands of miles of
highway being constructed in just a few years.
(Lewis 1997)
Probably few people could anticipate the
many impacts of that bill. It made it possible for
people to travel long distances quickly in their cars
and truck drivers to deliver supplies to areas not
served by trains. It spurred the tourism industry
and contributed to Arizona’s growth. Over the
long run it contributed to the sprawl form of
growth in many communities. Whereas people in
the pre-freeway days had to live relatively near
work or a railroad line, the new fast roadways
made it possible to live an hour’s drive or more
from work. As discussed in Chapter 4, Tucson did
not allow any more freeways after I-10 and I-19,
but the Phoenix area did and this contributed to the
sprawling growth form of Phoenix.
The Water Pollution Control Act of 1972
Congress passed this law at a time when
concern for the environment was very high. The
primary intent was to stop severe water pollution
and clean up contaminated rivers. The new sys68

tem that required polluters to get permits for discharging possibly contaminated water to a watercourse (NPDES permits) played a major role in
improving the quality of the nation’s waters. One
unintended side effect of the law and later amendments, however, was to provide funds for rapid
population growth. The government would pay
for much of the costs of building municipal wastewater treatment plants and the pipe system to get
the water to those facilities.
In Pima County, the Roger Road and the Ina
Road Wastewater Treatment Plants were built and/
or expanded with a large infusion of federal funds
as were major sewer lines to Oro Valley and elsewhere.
In 1974 the Council on Environmental Quality
commissioned a study on Interceptor Sewers and
Suburban Sprawl. The authors concluded that
“current financing procedures – on both the local
and federal level – may encourage the construction of sewerage systems tailored to the needs of
future developers rather than the control of pollution problems. Where communities intend to
finance the local share of projects costs by connection fees on new development, this creates pressure to encourage rapid growth and thus ensure the
financial viability of the project.. … Communities
often view the EPA program as a one-time-only
opportunity to obtain federal funds, and thus there
is a definite incentive to design a future-oriented
system….”
Congress no longer provides this kind of subsidy for new facilities to accommodate growth
so local taxpayers and ratepayers must pay the
full cost. Increasingly stringent NPDES permit
requirements have somewhat increased local costs
to upgrade the treatment plants to meet new standards. Pima County Wastewater has taken the lead
in Pima County in assessing connection fees to
help pay for wastewater facility construction.
The Costs of Growth
A full-blown costs of growth or cost of sprawl
study is far beyond the scope of this report, but
is sorely needed as stated above. It has long
been assumed that population growth is good for
the economy because it creates jobs, brings new
money into the community and contributes to
overall financial well-being. Studies in other parts

of the country, however, have shown that quite
the opposite is the case. Other studies show that
the costs of growth are directly related to how a
community grows in addition to its rate of growth.
These are briefly discussed below.
There are four types of costs: construction
costs, maintenance costs, cost of providing service,
and the marginal costs of replacing a resource as
it is depleted.
Construction costs
These are the costs of acquiring land and constructing facilities including roads, water lines,
buildings, flood control structures, schools, and
water treatment facilities. These costs are sensitive
to distance. That is, a long road or sewer line
frequently costs more to build than a shorter one,
although there are other factors such as type of
terrain and cost of acquiring land. How land uses
are distributed affects the cost of construction. See
the discussion below on the cost of sprawl.
Operating and Maintenance Costs
These are the costs of doing such activities as

repairing roads, paying for water treatment chemicals, providing energy to run facilities, providing
gas for vehicles, and keeping buildings in good
repair. These costs are less sensitive to distance .
Service Costs
These are the costs of paying people to provide
services such as police protection, teaching, court
trials, public transportation, and library services.
Marginal Costs
These are the costs of finding replacements for
materials that are used up. Finding new water
sources is the primary example in Pima County.
The first water to be pumped is generally the
cheapest. When wells could be hand-dug or
water gathered from springs, water was comparative cheap. Bringing water in from more distant
sources, such as the Colorado River, for example,
is more expensive . The federal government
helped subsidize the Central Arizona Project as
discussed above. The marginal costs of providing
energy are becoming an issue in American politics
as American oil reserves are depleted.

Fig. 7-1. Population growth in incorporated and unincorporated areas in Pima County.
Source: Arizona Department of Economic Secutiry.

69

Does Growth Pay for Itself?
Many elected officials, business people,
and the news media have assumed that growth has
positive economic impacts for a community. For
example, in a recent KUAT newscast, the reporter
said; “Good news. Housing permits reached
record levels in Pima County …” Is growth really
economically necessary or desirable? Eben Fodor
(1998) addressed these questions by examining ten
common myths concerning growth. Four of those
myths are discussed below:
1. Growth reduces unemployment
If this was true, rapidly growing areas
would have lower unemployment rates than slow
or no growth areas. He found no correlation
between growth and unemployment. The Sierra
Club in 1988 found a similar result in Pima
County (Tellman 1988). The unemployment rate

in that study fluctuated with the national unemployment rate and not with growth spurts.
2. Growth builds up the tax base, providing needed
revenues
Fodor compared the per capita tax rate of rapidly
growing communities with slower growing ones and
found that larger cities have higher per capita taxes.
While there may be temporary tax windfalls, this is
not always the case. Springfield Oregon, for example, had a decade of rapid growth that left its municipal funding decimated. He also cited the City of
Eugene, Oregon which levies a $2,000 impact fee for
new single family homes, but conservative estimates
of the actual cost of public infrastructure is more
than $20,000. In fact, he conducted a survey of large
cities and found that larger cities have higher tax
rates than smaller ones. A study in the Chicago area
found that fast growing areas that do not increase
their tax rates must resort to cuts in services.

Fig. 7-2. Percent change in housing costs in Pima County and Tucson 1990-2000.
Source: Tucson Planning Departtment.

70

3. We must subsidize and support business growth
to have good jobs
A “good business climate” says Fodor, translates to one with less government regulation, lower
taxes and a higher level of business subsidies. He
cites a University of Wisconsin study that came to
the conclusion that states with good business climates (defined as little government regulation and
much financial support of business) had worse
economic outcomes and that states with the
worst business climate rating experienced $585 to
$1,000 more growth in per capita income than the
ones with the best ratings.
4. If we try to limit growth housing prices will
shoot up
Fodor cites a California study that compared cities with growth controls and those without and found no correlation between growth
controls and housing prices. A look at “Silicon
Valley” where sprawl is rampant and housing prices were among the highest in the nation makes it
clear that other factors such as supply and demand
are far more significant. As the computer firms in
the area went out of business in 2000 and people
left the area in droves, the cost of housing declined
precipitously, leaving many people with houses of

less value than the remaining mortgage payments.
Fig. 7-2 and 7-3 show how much housing
prices have risen in the past decade in Pima
County. Costs have risen much more rapidly
outside city limits than inside, primarily because
less low-income housing is located away from
the urban area.
What are the economic effects of rapid population growth?
There have been numerous studies of the cost
of growth throughout the nation and all reach similar conclusions. The American Farmland Trust has
conducted studies in a many communities where
urbanization is creeping into farmlands and developed a systematic approach for doing these studies.
For example, in Lake County Ohio they looked the
entire range of revenues and expenditures and found
that for every dollar of revenue that was received for
residential development, it cost an addition $.54 to
satisfy the demand for community services annually.
44%of the costs were for education, 18% for public
works, 17% for public safety, Only 4% of the costs
were for health and human services. Open space
and farmland did not generate much revenue, but it
needed few expenditures. Industry was also less
costly to service. For this area for every dollar in

Fig. 7-3. Changing prices of homes sold in Pima County.
Source: City of Tucson Planning Department.

71

revenue, the costs were $1.54 for residential, $1.23
for commercial and industrial and only $.34 for
farm, forest and open land. They concluded
that the most cost-effective land use pattern for
that community was to de-emphasize population
growth.
Since that time the American Farmland Trust
has assisted local communities in conducting similar studies in eighteen states, but none in Arizona.
In every case residential growth costs the community more to provide services than it earns in
revenue from those areas. Construction costs
are not part of the calculations. The residential
ratios of revenue to cost ranged from a low of
1:1.01 in Groton, Montana to a high of $1:$2.11 in
Stewardson Township, Pennsylvania. The median
ratio was $1:1.15. The median ratio of revenue to
cost for commercial development was $1:.27 and
$1:.36 for farmland and open space. (Anon 2001)
Studies in many other communities have come
to similar conclusions. Fodor cites a study in
Redmond, Washington in which costs exceeded revenues for all kinds of residential development. In
Loudon County, Virginia the annual cost to the
community per dwelling in 1986 ranged from $705
for 4.4 houses per acre to $2,232 for 0.2 houses
per acre. In Pima County, an SDCP study showed
that unregulated (wildcat) growth does not pay for
itself even for public safety costs. (Anon. 2000.)
Similar studies need to be done for other types of
land uses in Pima County. We just do not know
whether growth pays for itself in Pima County.
Two indications that it may not are the financial
crises that are happening in 2001at both the local
and state levels at a time when the growth rate is
one of the highest in the nation. Similarly, when
California was experiencing rapid growth, the state
experienced a tax crisis and citizens voted in a
measure that made it very difficult to raise taxes.
The Costs of Sprawl
No detailed study has been made in recent
times of the costs of various growth patterns in
Pima County. It is obvious, however, that dispersed growth patterns increase the road miles that
must be built, the length of sewer lines, the distances that the sheriffs must travel to provide public service and many other structures and services.
Some costs are fixed no matter where the growth
72

occurs. The wastewater treatment plant must be
the same size no matter where the people live, but
the pipes that move the sewage are sensitive to
distance. Water wells and treatment systems are
not sensitive to growth patterns, but the transmission lines are and energy costs increase to pump
the water farther and uphill. Providing infrastructure in a more compact fashion reduces costs.
In 1972 Pima County, Tucson and the City of
South Tucson commissioned what appears to have
been the very first cost of sprawl study in the
United States. (Booz, Allen 1974) The consultant
looked at four different growth patterns: Peripheral
Expansion (sprawl), Contained Growth, Activity
Centers, and Satellite Cities. The study also
looked at the impacts of these growth patterns at
both high (1,000,000 ) and low (800,000) population levels. The full chart with the cost conclusions is in Appendix D.
In brief, the consultant found that at the low
population level capital needs would be from $1.4
to $1.8 billion in 1974 dollars. 2000 dollars would
be slightly more than 3 times this amount.
At both the low and high population levels,
the contained growth alternatives would cost significantly less than any other alternative.
At the high population level, contained growth
will save approximately 30% over the peripheral
expansion alternative. The main costs are in construction, but peripheral expansion will be more
costly to public agencies in serving scattered areas
and significantly increase travel time and cost of
residents to reach public facilities and services.
Property taxes under contained growth at the high
population rate were projected to be $9.01 per
$100 per assessed valuation as opposed to $11.83
for peripheral expansion in 1974 dollars. The
accompanying maps projecting peripheral expansion at full population levels are very similar to
today’s actual map. The map projecting contained
growth has many similarities to the SDCP proposed today, except that some of the areas that
SDCP proposes for no development are already in
use.
The federal Council on Environmental Quality
published the first major national study of the
costs of sprawl in 1974. (Anon. 1974) Their
study was comprehensive and looked at costs of a
wide range of factors including schools, transpor-

73

Fig. 7-4. Poverty rate by
school district in Pima County.
Source: Adapted from Pima
County Superintendent of Schools
information.

tation, police, infrastructure, air pollution, library
services, health costs and many others. The major
conclusions were Planned development of all densities is less costly to create and operate than
sprawl. Economic and environmental costs (as
well as resource consumption) are likely to be
significantly less at higher densities to house and
service a given population.
The greatest cost advantages occur when
higher density planned developments are contrasted with low density sprawl.
When alternative residential developments
are considered for a given site size, development
costs increase with density, but not as rapidly as
the increase in the number of dwelling units which
can be accommodated.
The Sierra Club cited twelve cost of
sprawl studies in its 1998 study. These are a few
examples. In California’s Central Valley a study
showed that compact growth would save $29 billion over 50 years in the cost of taxpayer-financed
services than sprawl. Another result of that
study was that the cost of providing services to
urban sprawl will exceed the tax revenues by
nearly $1 billion a year. The New Mexico
Local Government Division estimated that the
state already faced a backlog of more that $15 billion in infrastructure needs and that in some parts
of the state foreclosures and bank failures followed
periods of rapid unmanaged growth. A Utah
study found that sprawl development would lead
to a cost of $10,121 per household.
The report
also reports that a consulting firm found that the
actual cost of providing infrastructure to a single
family home was $6,390, but the city was only
collecting $2,511. The Town of Gilbert came to
the conclusion that growth was costing taxpayers
16% more than it brings in in revenues and fees.
Who Pays for Growth and Sprawl?
Costs are paid for by federal taxpayers,
state taxpayers, local payers of sales tax or property tax, consumers, fee payers, and private funds.
The elected officials making a rezoning decision
may not feel responsible for increasing costs for
some other jurisdiction such as a school district.
The system is often so complex that it is very
difficult to determine just who is paying what. For
example, school districts do not follow political
74

lines of city limits. School property taxes are
collected from taxpayers within the school district.
The cost of schools is also partially subsidized
by state funds under a tax equalization program
to help make up the difference between districts
with high land values and those without high land
values. Through property taxes, Tucson Electric
Power customers help pay the costs of schools
in Springerville where a portion of Tucson’s electric power originates. Because of the property
value of the power plant, this district is relatively
wealthy. The Sunnyside School District, on the
other hand, has low property tax revenues. The
state helps to partially equalize these differences.
The recently voter-approved 1/2cent increase in
the state sales tax is another source of funds for
local schools. In some cases developers help pay
for schools by donating land for a new school.
Federal programs also provide funds for local
schools. (Fig. 7-4 shows income levels in various
Pima County school districts).
Construction costs may be paid on a payas-you-go basis from annual funds or from borrowed funds, most commonly bonds that are paid
back through revenues from the project (e.g., water
rates) or through the general fund. There are
arguments for and against each method. The
advantage of pay-as-you-go is that the total costs
are lower because there is no interest to pay, but
the disadvantage is that current residents pay all
the costs of construction up front. The advantages
of paying through bonding is that future taxpayers
help pay for the facilities that benefit them, but the
disadvantage is that costs are increased because
of interest and the pay-back calculations assume a
certain rate of population growth which can be an
incentive to help attract that growth.
Utilities such as gas and telephone generally
pay for expansion by charging customers connection fees and by including those costs in the rates.
One argument given at rate increase hearings is
that the utility cannot keep up with the costs of
growth without raising the rates.
Maintenance and service costs are almost
always paid for through taxes and commodity
rates spread evenly among the customers, usually
according to their rate of use. Continued sprawl
increases costs for many kinds of services as discussed below. It has even been argued that the

cost of postage stamps has gone up faster than
inflation because of the need to deliver mail to
more and more distant and spread-out locations in
the suburbs.
How Does Population Growth and Sprawl
Affect Disadvantaged Neighborhoods?
The purpose of this section is not to analyze the costs of growth in Pima County. This
must be the subject of a detailed economic study.
As federal and state subsidies to local governments
continue to decrease, more of the costs of growth
will be borne by local residents. In the following
section we raise questions that need answers.
Who Should Pay for Growth?
The two basic approaches are to borrow
(i.e., sell bonds) and pay-as-you-go. Borrowing
has the advantage is that it spreads the costs out
over a longer period of time and with population
growth, there are more people to help pay back the
costs. Newcomers help existing residents pay the
costs. Borrowing, however, means higher costs
because of the need to pay interest. Borrowing
also is a problem if the projected population
growth does not materialize so it creates an incentive for continued population growth, which in
turn leads to more borrowing. The pay-as-you-go
approach can be through taxes and/or through
impact and connection fees. Impact fees increase
the one-time cost of a new home, but lessen the
tax burden while taxes have the opposite effect.
SDCP proposes much more use of the
impact fee approach to cover many of the costs
of providing infrastructure for new construction.
Partly in response to withdrawal of federal funding
for wastewater facilities, Pima County Wastewater
has been charging connection fees for many years
to help pay for the costs of new sewer lines.
Developers argue that an impact fee would add too
much to the cost of new homes and would penalize newcomers and that it is unfair because existing residents never had to pay those fees. They
prefer to spread the costs out over the community.
Tucson is actually unusual in its paucity of significant impact fees. Scottsdale has impact fees that
cover a wide range of costs and such fees are
common in California and elsewhere. Seldom,
however, do impact fees actually cover the full

infrastructure costs and even more rarely do they
deal with annual operating and service costs.
Do People in the Core Area Help Subsidize
Growth on the Fringes?
This too is an unanswered question because
of the complexity of the tax and fee systems, the
multiplicity of taxing entities (city, county, school
district, state, federal, and private) and the lack
of a study for Pima County. It seems clear,
however, that if the total costs of growth must be
paid on a community-wide level, everyone who
pays property taxes (either as a homeowner or
renter) is helping to subsidize growth at the present time. Since gas taxes help subsidize road
expansion, everyone who uses a vehicle is helping
to subsidize those roads. If voters approve the
city’s half cent sales tax proposal, everyone who
buys many kinds of goods will help subsidize new
roads. At the state level, income taxes and sales
taxes are also used to help subsidize growth. All
gas and electricity customers share in the costs of
extending the infrastructure for growth.
In the 1970s the Tucson City Council proposed that people who live at higher elevations
pay more for their water since it costs more to
pump water uphill to them. The lowest areas in
the Tucson Water service area are along the Santa
Cruz River where most of the disadvantaged areas
area. The higher elevations are in the Catalina
Foothills and Tucson’s far east side. It seemed
like a sensible notion at the time, but when it was
introduced along with a rate structure that encouraged conservation by charging more for higher
water use in the summer, high water users in the
higher elevations revolted. The four responsible
members of the council were recalled or resigned
and the City Council has never again seriously
considered “lift charges,” although the other
aspects of their rate structure remain. So all water
rate payers help pay to provide water to Tucson
Water customers in the higher income parts of the
service area.
Are Minority and Low Income People
Disproportionately Affected by Paying for
Growth?
The preceding discussions all lead up to the
main question of this chapter whether minorities
75

and low income groups are disproportionately
affected. This is another question to which we do
not have the answer because no studies have been
done locally.
Lower income people may get subsidies in the
form of certain social services, but they do not
require the large expenditures to build infrastructure or provide services that higher income people
in the suburbs do. Duany et al. (2000) said “This
situation is exacerbated by the costs of sprawl.
Everyone’s taxes – from rich and poor alike – fund
the construction of new far-flung infrastructure.
… The American tendency toward building ever
anew is most damaging to the poor because it
is inextricably linked to the abandonment of the
old. As we neglect older neighborhoods, we also
neglect their residents.”
Hanchett (2001) argues that because of the
FHA and federal tax policies discussed in Chapter
Six, all taxpayers are subsidizing new suburban
development. He argues that by the 1960s the

76

tax break alone was costing the U.S. Treasury
more than $700 million per year, while the federal
government spent that same amount over ten years
on Urban Renewal projects. By 1984 the subsidy
totaled $53 billion annually, about five times greater than all direct federal expenditures for housing.
People in low income neighborhoods do not
pay more than other residents to help pay for
growth in the new higher income areas, but what
they pay is a larger percentage of their total
income. $100 per year may not mean much to
someone earning $100,000, but it may mean the
difference between buying food or medicine to a
low income person. People whose families have
lived in Pima County the longest have contributed
to paying the costs of growth and sprawl much
longer than have newcomers. The Hispanic neighborhoods on the south side have many families
that have lived in Pima County for generations, as
opposed to the newer mostly white suburbs.

Chapter Eight
Cultural and Environmental Issues

“I think ecology has something to tell us about the nature of a healthy city. … We know
that when we clearcut an uneven-age, deciduous and evergreen climax forest and replace it
with a monocultural , even-aged species like Douglas Fir, we not only change its arboreal
characteristics, but also drastically change the surrounding plant and animal communities
… We know from ecology that those plant and animal communities that are the most diverse
are also the most stable and enduring. …” Helm and Tukel 1993.

N

ative American cultures traditionally tend to
view humans in the context of the entire surroundings and emphasize the interrelationships between animate and inanimate parts of the
world. For desert cultures such as the O’odham living in harmony with their surroundings was not only
culturally significant, it was essential for survival.
Significant cultural places range from specific
places such as I’Itoi’s cave on Baboquivari to trails
and places where people traditionally gathered foods,
hunted, or conducted religious ceremonies. Some
cultural places are sacred and their locations are not
to be revealed to outsiders. Others do not have
specific locations but may include the entire top of
a mountain that had and has religious significance.
Burial sites have strong significance for all the cultures in Pima County and archaeologists must follow
strict protocol including consultation with the appropriate tribe before excavation and repatriation of
human remains.
Many culturally significant sites have already
been destroyed, damaged, or made inaccessible to
the group that valued it. The Star reported in
November 2000 that a group of 50 spiritual leaders,
medicine people and dancers from various tribes visited the site of a planned three-level I-10-I19 interchange to call attention to the desecration of sacred
burial grounds as a result of the construction. They
noted that the archaeologists were taking artifacts to
the museum and that the bones would be repatriated,
but that this was still serious desecration they could
not accept.
Pima County’s Traditional Cultures
Traditional cultures of minority populations are
important aspects of the human environment in Pima
County. Traditional cultures encompass values about
the natural and physical environments that are rooted
in a community’s history and beliefs. In many cases,
the basis of each of these traditional cultures is, to
a considerable degree, grounded in the natural envi-

ronment. Environmental justice issues include the
human environment as defined by the traditional cultures of minority populations.
A number of minority populations, Indian
and non-Indian, have traditional cultures that are
part of the affected human environment in Pima
County. Indian cultures include those of the Tohono
O’odham, Pascua Yaqui, Apache, Hopi, and Zuni
tribes. Tohono O’odham and Pascua Yaqui populations are resident on reservations in Pima County
today, whereas the Apache, Hopi, and Zuni are not.
The Tohono O’odham traditional culture has a
long history in Pima County, and the affected human
environment of the Tohono O’odham people includes
their cultural values regarding many traditional cultural places, and cultural and natural resources
throughout Pima County. Many of the places important to the O’odham are on Indian lands, but since
they once occupied lands from the San Pedro River
to the Gulf of California, other important places are
on non-Indian lands.
The traditional culture of the Pascua Yaqui community in Pima County does not have the time
depth of the Tohono O’odham, because of their more
recent arrival in the area. Even so the Pascua Yaqui
traditional culture is part of the affected human environment in Pima County.
The Apache Tribes have many historical and
cultural connections with places in Pima County,
and these places have important values in traditional
Apache history and culture. Today the Hopi and Zuni
cultures are centered in the Four Corners area , but
they, too, have cultural affinities with places in Pima
County where their ancestors once lived and traveled.
In traditional Hopi and Zuni cultures, the many buried ancestors and established shrines in Pima County
have roles that are integral to Hopi and Zuni presentday beliefs. Consequently, traditional Hopi and Zuni
cultures are part of the affected human environment
in Pima County
Non-Indian traditional cultures in Pima County
77

include the Hispanic culture. The four centuries of
Spanish experience in Pima County have left many
cultural sites of importance, such as San Xavier
Mission, the Convento and the Camino de Diablo to
the west.
Numerous historical sites are of importance to
the Anglo culture, including historic ranches, houses,
and mines. Other cultures also consider certain places and events significant parts of the human environment in Pima County.
Environmental justice issues apply to all minority traditional cultures that are connected to the area
within Pima County. Sometimes there are conflicts
between values of the different minority populations.
Some Native Americans, for example, may view the
Spaniards as conquerors and not wish to preserve
sites offensive to them while others have enthusiastically embraced the Catholic religion brought by the
Spanish missionaries, as shown by the O’odham’s
strong commitment to the San Xavier Mission. The
conflict is sometimes clear when Anglo military
monuments emphasize Anglo victories over native
peoples rather than their struggles against Anglo
occupation.
Cultural Values and the Environment
Different cultures share values but also have
many distinct value systems. The importance of the
natural world is often a significant part of American
Indian cultures. An example of this comes from
the 1994 hearing on the Minerec Company cited in
Chapter 4. Mr. Daniel Preston, Vice-Chairman of
the Tohono O’odham Nation, stated that “at some
point the Nation will be coming out with regulations
which will be more stringent than what your regulations are because we do have a culture and tradition
to protect the environment.” Another speaker at
the hearing quoted the Peacemaker of the Iroquois
Confederacy “Think not forever of yourselves, O
Chiefs, nor of your own generation. Think of continuing generations of families, think of our grandchildren and of those yet unborn, whose faces are
coming from beneath the ground.”
Cultural Values and SDCP
Several SDCP studies have concentrated on
archaeological and historic sites as well as cultural
landscapes. Proactive identification and preservation
of significant locations is an important part of SDCP.
Continuation of the present trend to fragment
landscapes into small blocks of privately owned land

78

is detrimental to many cultural values. Many traditional cultures place a high value on large unfragmented swaths of natural open space, a value that
will be greatly diminished if landscape fragmentation continues. Almost all tribes in the Southwest
historically described the extent of their lands at the
time the United States assumed control by identifying mountains, river, or places such as shrines. In
the case of the Tohono O’odham, Picacho Peak is
a point on the northern boundary while the crest of
the Rincon Mountains is part of the eastern boundary. Spanish methods of dividing the land, on the
contrary, were based on the use of natural points, and
the use of somewhat arbitrary rectilinear areas. The
U.S. introduced an entirely revolutionary means of
dividing up the land, based on city grid plans
with intersecting lines along the cardinal directions.
These arbitrary lines cut across mountains, prairie
and watersheds from the Atlantic to the Pacific.
(Anon. 2001a) The international through Arizona
boundary consists of straight lines that cut through
deserts, mountains, and river valleys and through the
O’odham homeland.
The most sacred peak to the O’odham is only
partly within the Nation. Water has always
been extremely important to the Native Americans.
Mountains are regarded by the Tohono O’odham
as the locations of rainhouses, positioned in the cardinal directions, which have all the trappings of rain
- winds, clouds, and rainbows. Another important
mountain, Frog Mountain, also known as Mount
Lemmon, is named for an animal closely associated
with water. Most of the important water and mountain sites have been appropriated by non-Tohono
O’odham people and in many cases fragmented into
various jurisdictions and private landholdings. In
SDCP the County attempts to delineate large areas
in need of protection, based not on arbitrary rectilinear mapping, but based on natural features such as
watercourses and on the habitat needs of a variety of
sensitive species.
Continuation of the current trends also perpetuates the unabated assault on species of plants and
animals that are important and integral aspects of
traditional cultures in Pima County. Each traditional
culture attributes certain species with significance in
religious rites, in their cultural history, and for their
traditional subsistence practices. The continued loss
and diminution of culturally important species and
the increased fragmentation of the landscape if no
changes are made will dramatically restrict the abil-

ity of practitioners to perpetuate the time-honored
customs of traditional cultures.
If the full conservation alternative is adopted
with all the SDCP proposals for preservation, this
will provide the greatest protection for traditional
cultures and the values they embrace. This alternative will protect the greatest diversity of species and
retain the largest swaths of traditional cultural landscapes as natural open space. Traditional cultural
practitioners will have the maximum ability to continue their customs and rites with the minimum
impact to the human environment, as long as access
to those areas is assured.
Preservation of more recent historic sites is
also a significant element of SDCP. A proactive
approach to identification of significant sites will
attempt to assure either preservation of sites or an
opportunity to fully study sites that cannot be protected indefinitely into the future. Additional educational opportunities for school children and adults are
proposed to inform them about our cultural heritage
and involve them in appreciation for the need to
preserve significant sites.
Environmental Issues and SDCP
Most Native American cultures had and have
a strong relationship to the natural world – its
resources, wildlife, and vegetation. Appendix C.
contains the cooperative agreement between the
Tohono O’odham Nation and Pima County. This
agreement points out the strong feelings and knowledge that the O’odham have about the natural
world. It recognized that “for the Sonoran Desert
Conservation Plan to be truly comprehensive and
meaningfully conserve the resources important to the
original and new residents of the Sonoran Desert,
a cooperative and collaborative effort is needed
between Pima County and the Tohono O’odham.”
Perceptions of the natural environmental vary
according to the cultural background and experiences
of the individual. If you are totally dependent on

the local natural environment for your food, clothing,
and shelter, your values will be quite different from
the values of people who import most of their necessities and luxuries from distant places. No culture in
Pima County today lives entirely on local resources,
but the cultural values of those whose background
includes this experience differ from those whose culture was developed elsewhere. On the other hand,
people arriving from elsewhere may view the environment with a fresh view because it is so different
from what they have experienced. (Anon. 2001a)
Culture-related impacts to minority groups
include impacts on the people and their culture, and
to the landscapes and places that sustain the culture.
Both are important.
The Sonoran Desert Conservation Plan cannot
restore the land to its previous condition, but it
does propose to work to save large areas of significant wildlife habitat and wildlife corridors. The
plan includes preservation and restoration of riparian
areas and wetlands that can still be restored, although
it cannot return most of those areas to pristine conditions. The plan offers respect for all forms of
life, including Threatened and Endangered Species
as well as those not officially listed but facing threats
from human encroachment, such as cottonwood-willow riparian forests.
Closing Thoughts
The SDCP report, People and Places, closes with
this thought. “Biodiversity, a complex mosaic of
interrelated natural components, is high in riparian
contexts and in the mountain “sky islands” of Pima
County. Biodiversity is prized as an essential element of both cultural landscapes and scientific landscapes. Conserving places with high biodiversity is
good for plants, animals, people, and cultures. A
rich and diverse environment if the basis for the richness and diversity of cultures. ... Preservation is not
just about places; it is about people’s lives.”

79

80

Chapter Nine
Conclusions

“We are the children of the Earth. She is our Mother, and it’s our right and duty to
protect her. There are forces in the universe beyond anything Europeans can imagine.
From our traditional ways, we know that we do not have the right to degrade our Mother
and that we must live in harmony with all creation. The Europeans’ lopsided emphasis
on human beings at the expense of the rest of the created order and their presumptuous
assumption that they are somehow outside the chain of interrelatedness of all things have
led inevitably to imbalance and disharmony and will result in a readjustment that will
cut arrogant human beings down to size, give them a taste of that ultimate reality that is
beyond their ability to manipulate or control, and restore balance and harmony. …”
(Russell Means in Weaver 1997)

T

he purpose of this chapter is to assess
whether the Sonoran Desert Conservation
Plan (SDCP) would have a disproportionate
impact on low income and minority populations
as opposed to continuing the current trends.
Environmental injustices have been numerous in
Pima County for more than 300 years.
This report cites many examples including
loss of much of the O’odham homeland, groundwater
pumping that affected San Xavier, siting of industries
that cause illnesses among low income and minority
people, exclusionary land use policies and others.
SDCP makes no pretense to righting the wrongs of
the past. SDCP does propose no new policies that
will lead to environmental injustices and offers policies that are fully in harmony with environmental
justice principles.
The National Environmental Policy Act
requires that projects conducted under federal
aegis include an Environmental Impact Statement.
Agencies are required to the fullest extent possible
and using all practical means to “avoid or minimize
any possible adverse effects of their actions upon the
quality of the human environment” which includes
“the natural and physical environmental and the relationship of people with that environment.” Further it
calls for preservation “of important historic, cultural,
and natural aspects of our natural heritage, and maintain, where possible, an environment that supports
diversity and individual choice.” (NEPA Section 101
and 40 CFR 1500, sections 101b et al.).
The Draft Sonoran Desert
Conservation Plan in Brief
SDCP is a comprehensive county-wide plan
that establishes where new development should and
should not occur within the unincorporated areas

of Pima County (not including the O’odham Nation).
Extensive studies were made of areas where sensitive
species of plants and animals occur today and which
habitats should be protected for the benefit of those
species. Studies were also conducted into archaeologically and culturally important sites and areas and recommendations made for protection of those areas. In
many cases the cultural and historic sites were in the
same locations proposed for species protection. It also
proposes that natural parks with recreation potential be
expanded. SDCP then designates areas where development should occur to accommodate continuing population growth. SDCP proposes an approach to providing
infrastructure such as wastewater facilities and roads
in a cost-effective orderly fashion to prepare for new
development, rather than the predominant current trend
of providing infrastructure in response to development.
Fig. 9-1 shows the draft land use plan. See Appendix
E. for a list of some of the many relevant SDCP
publications which contain much more information.
Does SDCP Conform to the Principles of
Environmental Justice?
In Chapter 1 the principles adopted by the 1991
People of Color Environmental Leadership Summit
were mentioned. The group adopted
seventeen principles that are listed in full in
Appendix B. SDCP is in harmony with all of the
applicable concepts. The most significant ways in
which SDCP meets those principles are discussed
below. The principles are numbered at the end as
they are in the declaration.
Environmental justice affirms the sacredness
of Mother Earth, ecological unity and the interdependence of all species, and the right to be free from
ecological destruction. (1.)

81

Fig. 9-1. Draft Sonoran Desert Conservation Plan.
Source: Pima County Technical Services.

82

One of the cardinal underlying concepts of
SDCP is the importance of ecological interdependence and the need not only to preserve individual
species, but to protect entire ecosystems. The plan
for large connected preserves is designed to preserve
many species, their food supplies, their breeding
areas, and their ability to move between preserves
to the extent possible in a county that has been occupied by humans for thousands of years. SDCP goes
beyond the requirements of federal law by including
not just federally listed species, but all species that
the scientists agree are in need of protection.
Environmental justice demands that public policy be based on mutual respect and justice for
all peoples, free from any form of discrimination or
bias. (2.)
SDCP involves numerous studies of cultural
issues and includes proposals to preserve diverse cultural values in implementing the plan. In numerous
cultural and historical reports, a respect for a variety
of cultures, past and present, is stressed. The SDCP
proposal reflect a commitment to work proactively to
preserve Pima County’s cultural heritage.
Environmental justice mandates the right
to ethical, balanced and responsible uses of land and
renewable resources in the interest of a sustainable
planet for humans and other living things. (3.)
The underlying concept of SDCP is to change
land use trends in order to optimize responsible uses
of land and resources in Pima County. Preservation
of riparian areas, for example, is crucial to preserving
the integrity of those areas for resident and migratory
wildlife while in many cases also offering flood control benefits and reduced flood damage costs for
humans. Some of these riparian areas, such as the
Cienega Creek Preserve also offer important recreational opportunities for all humans where the only
cost to humans is the cost of getting there.
Environmental justice must recognize
a special legal and natural relationship of Native
Peoples to the U.S. government through treaties,
agreements, compacts, and covenants affirming sovereignty and self-determination. (11.)
SDCP has worked cooperatively with the
O’odham but has not attempted to force its will upon
the Nation, recognizing that it does not have jurisdiction over those sovereign lands. Cooperation should
provide greater opportunities to preserve traditional

cultural places off the reservation. In particular,
Pima County has a agreement with the Tohono
O’odham Nation to work cooperatively in developing
and implementing the plan.
Environmental justice affirms the need for
urban and rural ecological policies to clean up and
rebuild our cities and rural areas in balance with
nature, honoring the cultural integrity of all our
communities, and providing fair access for all to the
full range of resources. (12.)
Pima County has been fortunate in that it does
not have major problems with toxic wastes, air-polluting industry, or polluted surface water, although
some problems do occur with groundwater. Major
clean up efforts are not needed or planned as part of
SDCP. Pima County has, however, suffered from
land use patterns and policies that encourage sprawl
and inefficient use of the land and other resources.
These patterns have led to dependence on the automobile with its consequent heavy use of petroleum
resources and lowered air quality. The proposals in
SDCP cannot return the community to a pre-sprawl
condition but they do promise to help contain future
sprawl in a reasonable way. These policies will
lead to more sensible land use, preservation of scarce
natural resources, and lower costs of providing services and infrastructure which will benefit all residents, including low income and minority people.
Environmental justice calls for the education
of present and future generations which emphasizes
social and environmental issues, based on our experience and an appreciation of our diverse cultural
perspectives. (16.)
Education is an important element of SDCP. To
this end, staff developed an environmental education
program to acquaint children with a variety of facts
and ideas important to the plan. The SDCP web site
includes a variety of ways in which young people
can learn about plant and animal species, ecosystems,
cultures, and their interrelationships. The County
works cooperatively with groups such as the Tucson
Audubon Society to support workshops and other
programs that work directly with children. In addition, staff have spoken to a wide variety of adult
groups about SDCP in an effort to educate them
on the basic concepts and how the plan will work
in practice. The more ethan 200 reports contain a
wealth of information available to interested people.

83

Air Quality and Toxic Materials
The Past and Present Situation
Air quality varies throughout the community
but for CO, N02 and ozone there is no evidence that
disadvantaged populations are currently disproportionately affected. These pollutants come primarily
from vehicular traffic and impacts tend to be greater
in areas with heavier start-and-stop traffic. Another
major source is particulate matter that comes primarily from unpaved roads, construction, and mine tailings. These activities are not conducted disproportionately in disadvantaged areas, rather the most rapidly growing areas tend to have more construction
activity and in some cases worse traffic congestion
problems than established neighborhoods. Some
established neighborhoods, however, are impacted by
traffic congestion. Grant Road, for example, was not
designed for the amount of traffic that currently uses
it and there are congestion problems at peak travel
hours.
Businesses and industry that have air quality
permits are currently disproportionately located near
low income and minority neighborhoods. These
neighborhoods may potentially be affected by accidental releases of materials that would impact health.
Potential Impacts of SDCP
There are no proposals that would increase
the number or location of facilities with air quality
or hazardous waste permits and there should be no
positive or negative impacts on disadvantaged areas.
There are no new landfills proposed under SDCP,
although new landfills be eventually be needed as the
community grows. There is virtually no possibility
that a new landfill would be located within the most
populated part of the urban area.
There should be few if any new air quality
impacts from increased traffic through disadvantaged
neighborhoods that are predominantly on Tucson’s
southwest side and South Tucson. Areas proposed
for new development are largely on the southeast
side of the community and there are few popular regular travel destinations that would require increased
travel through the area. If development is in places
more concentrated then air quality generally would
be less affected than projected by making public
transportation systems more feasible and use of the
private auto for regular trips less attractive.

84

Drinking Water Quality and Supply
The Past and Present
Although there have been drinking water quality
problems in the past, most notably problems
with TCE in the area northwest of the Tucson
International Airport, people throughout the Tucson
Water service area receive very similar quality drinking water. There are contaminated groundwater
areas in the community, mostly in the older parts of
town. These are, however, not the source of drinking
water for customers. All water providers must meet
Safe Drinking Water standards and regularly report
and fix any problems. The only people who might
have drinking water problems are those with their
own wells or who get their water from very small
water providers who are not covered by the Safe
Drinking Water Act. These are not disproportionately in disadvantaged areas, although some of these
areas may be where wildcat subdivisions occur, some
of which may be low income.
Groundwater supplies throughout the area have
been severely impacted by continually increasing
water use over the past century. The minority group
most severely impacted by groundwater pumping is
the San Xavier District of the O’odham Nation. The
water table here dropped to the point that the giant
mesquite bosque died. The water deficit was partially rectified when CAP water reached San Xavier
in 2001.
Drop in groundwater levels has the potential to
affect parts of the county quite severely. This
has already been detected at San Xavier where thousands of sinkholes and fissures have appeared, apparently because of excessive groundwater pumping.
Subsidence is occurring the central part of the metropolitan area, centered approximately at Country Club
Road and Speedway. With the arrival of CAP water,
Tucson Water has lessened its groundwater pumping
in the central area but continues to pump the south
side well field without closing wells. This area has
potential for subsidence that would affect disadvantaged areas if pumping is not reduced appropriately.
Potential Impacts of SDCP
SDCP will have no positive or negative impact
on drinking water quality which is the responsibility
of municipal and private water providers that are not
under county jurisdiction. The county also does not
have the authority to deal with groundwater pumping
and subsidence issues. SDCP should have no disproportionate impact on water quality or water supply

for disadvantaged areas or any other areas.
Siting of Industry and Other Facilities
The Past and Present
In the past, some minority neighborhoods
have been severely impacted by siting of new government facilities, most notably the City-County
Government buildings and the Tucson Convention
Center. They were also affected by construction of
I-10 and I-19 in the 1950s and 1960s.
Areas zoned for heavy industry are along
the major transportation routes and that disproportionately affects many of the low income areas where
the industry is located. Unused old landfills are disproportionately in the downtown and near southside
areas, but more recent ones are not. Wastewater
treatment plants are located downstream from the
urban area and do not significantly affect disadvantaged areas. Tucson’s only power plant is not near a
disadvantaged area.
Potential Impacts of SDCP
SDCP does not propose new industry, freeways, government buildings, landfills, power plants,
wastewater treatment plants, hazardous waste disposal sites or similar facilities. It does put sensitive
areas out of bounds for building such facilities in the
future, however, and this may mean that they might
be built nearer to the urban area. This is not likely to
disproportionately impact disadvantaged areas. The
City of Tucson’s Rio Nuevo Project may affect
neighborhoods in the downtown area, but this is not
a part of SDCP.
Land Use, Affordable Housing, Transportation,
and Access to Services
The Past and Present
Under the patterns of growth that have
occurred for the past half century, new subdivisions
have been predominately built on the outskirts of
town and have not met standard criteria of affordability for lower income people. Because of their
design and location most people must own at least
one vehicle to get to work, shopping, or recreation.
The subdivisions are not designed to encourage public transportation Lending policies make it somewhat difficult to renovate older areas or build homes
within vacant parts of the urban area. Federal
lending policies and local zoning codes encourage
segregation by income levels, although past federal
policies that discouraged mixed-race neighborhoods

were stopped in the 1960s. Both federal and
local policies discourage mixed-use neighborhoods.
The income gap between owners and renters has
increased, especially for lower income residents.
Potential Impacts of SDCP
SDCP cannot change federal lending policies,
but it can affect county zoning and building codes
and encourage types and location of development
conducive to the use of public transportation.
SDCP proposes more flexibility that will allow for
and encourage more mixed-use development.
Will new construction in some areas increase the
cost of housing for low income people? Most new
housing in the unincorporated area is not affordable
for low income people today. The median price of
a new house in Tucson is about $130,000, up from
about $80,000 in1990, even without new land use
controls or impact fees. At a time in the future
when land becomes more scarce, the median price
will undoubtedly continue to rise in response to the
cost of land and many other factors, but cost will be
most directly related to supply and demand. SDCP
may, however, encourage better use of vacant land
within the urban area, the best place to put new
affordable housing to minimize dependence on the
auto and increase access to jobs and public services.
SDCP also contains an element to make housing
more accessible to the disabled. The Board of
Supervisors passed an ordinance in 2002 requiring
accessibility in new housing.
Taxes, rates, and fees
The Past and Present
At the present time the costs of growth are paid
for through a complex mixture of property taxes,
sales taxes, federal highway user fees, state and federal income taxes, user fees, commodity charges, and
private funds. Local taxing entities include Pima
County, municipalities, and school districts and in
some cases special districts. It is very difficult to
determine the actual cost of growth in the community
because of this complexity and the amount of state
and federal subsidies which have begun to decline. It
is clear, however, that the new homeowner pays only
a small portion of the cost of providing the roads and
other facilities needed for that home. The remainder
is shared by taxpayers at the local, state and federal
levels. It is highly likely that low income and minority groups in the core city are helping pay the costs
of providing new homes in outlying areas.

85

Potential Impacts of SDCP
SDCP will not change the complexity of this
structure. It may lessen the burden on inner city
residents in two ways. The proposed impact fee will
help fund some of the infrastructure costs, relieving
current residents. More significantly, by containing
growth within certain predetermined areas and by
taking a proactive stance toward phasing in of infrastructure, overall costs to the community should be
lowered, thus lessening the burden on new and existing residents alike. Pima County has no jurisdiction
over land use or fiscal policies of the incorporated
areas, but can affect the direction of growth outside
those areas.
Cultural Sites and Values
The Past and Present
Many traditional cultural and archaeological
sites were destroyed as the population grew, but
some have been preserved or at least studied before
they were destroyed. Some important sites are on
Tohono O’odham lands or federal preserves such
as Organ Pipe National Monument or Coronado
National Forest, but many are on state or private
land. At the present rate and pattern of development
sites continue to be destroyed. An increasing number
of traditional cultural sites have become inaccessible
to all but private landowners and their guests.
Potential Impacts of SDCP
SDCP has mapped known areas of archaeological or historic value and has prioritized areas
most in need of preservation and protection. It also
proposes a pro-active program of studying the most
valuable sites in advance of development if they cannot be preserved. It is much more difficult to map
traditional cultural sites as they tend to be secret or
cover large areas where traditional activities such as
saguaro harvest once occurred. Many of the areas
proposed for habitat protection also include traditional cultural areas. Where this occurs the benefits to
the affected population, primarily American Indian,
will be positive for those groups as long as access
is assured.
Open Space, Wildlife, and Habitats
The Past and Present Situation
Thousands upon thousands of acres of wildlife habitat and riparian areas have been damaged
because of population growth in Pima County.
Because of dispersed growth patterns, people have

86

encroached on the land at a far greater rate than
population increase. People are also using more
land per person than in the past and the average
house size has nearly doubled in the past fifty years.
Increased water use has led to the loss of flowing
streams and springs that were once important to both
people and wildlife.
The government, however, has also set aside
thousands of acres of land as National Parks,
National Forests, Wildlife Refuges, State Parks, and
city and county natural parks. Many of these lands
contain important wildlife habitat and flowing water.
Private land stewards and non-profit groups have also
protected thousands of acres of land. Federal laws
protect certain threatened and endangered species.
Subdivision development on the fringes of some
of those preserves, on the other hand, has limited
public access and cut off long-used trails within
them. Areas that were once “the boondocks” where
people hunted are now covered with subdivisions
or fenced off from public use. The ability of low
income people to enjoy the desert is still there, but
much limited from what it was even in 1950 when
one could roam the Catalina foothills to hunt deer,
watch birds, or walk the dog without conflicts with
private landowners.
Potential Impacts of SDCP
A significant element of SDCP is its coordinated
approach of viewing the county as an interrelated
place. SDCP looks to set aside certain areas where
protection of wildlife habitat and vegetation will be
the primary goal. The plan is to connect these areas
as much as possible to allow wildlife movement
between those areas. SDCP also includes cooperative efforts to restore species that have declined or
even disappeared from the area.
Finally, the plan also includes natural areas available
for public recreational use at no cost other than the
cost of getting there.
A fully implemented SDCP will benefit vegetation and wildlife and the people who value nature, no
matter what the income level.
Summary of the Anticipated Impacts
There are no foreseeable negative environmental
justice impacts from SDCP and some positive
impacts. SDCP will not right injustices of the past
but will help mitigate some of the damage that would
occur in the future without benefit of SDCP.

Appendix A
Principles of Environmental Justice
The following list was adopted by 61 nations as the Principles of Environmental Justice at the People of
Color Environmental Leadership Summit on October 27, 1991, in Washington, D.C.
1. Environmental justice affirms the sacredness of Mother Earth, ecological unity and the interdependence of all species, and the right to be free from ecological destruction.
2. Environmental justice demands that public policy be based on mutual respect and justice for all
peoples, free from any form of discrimination or bias.
3. Environmental justice mandates the right to ethical, balanced and responsible uses of land and
renewable resources in the interest of a sustainable planet for humans and other living things.
4. Environmental justice calls for universal protection from nuclear testing, extraction, production and
disposal of toxic/hazardous wastes and poisons and nuclear testing that threaten the fundamental right to
clean air, land, water, and food.
5. Environmental justice affirms the fundamental right to political, economic, cultural and environmental
self-determination of all peoples.
6. Environmental justice demands the cessation of the production of all toxins, hazardous wastes, and
radioactive materials, and that all past and current producers be held strictly accountable to the people for
detoxification and the containment at the point of production.
7. Environmental justice demands the right to participate as equal partners at every level of decisionmaking including needs assessment, planning, implementation, enforcement and evaluation.
8. Environmental justice affirms the right of all workers to a safe and healthy work environment, without
being forced to choose between an unsafe livelihood and unemployment. It also affirms the right of those
who work at home to be free from environmental hazards.
9. Environmental justice protects the right of victims of environmental injustice to receive full compensation and reparations for damages as well as quality health care.
10. Environmental justice considers governmental acts of environmental injustice a violation of international law, the Universal Declaration On Human Rights, and the United Nations Convention on Genocide.
11. Environmental justice must recognize a special legal and natural relationship of Native Peoples
to the U.S. government through treaties, agreements, compacts, and covenants affirming sovereignty and
self-determination.
12. Environmental justice affirms the need for urban and rural ecological policies to clean up and rebuild
our cities and rural areas in balance with nature, honoring the cultural integrity of all our communities, and
providing fair access for all to the full range of resources.
13. Environmental justice calls for the strict enforcement of principles of informed consent, and a halt to
the testing of experimental reproductive and medical procedures and vaccinations on people of color.
14. Environmental justice opposes the destructive operations of multi-national corporations.
15. Environmental justice opposes military occupation, repression and exploitation of lands, peoples and
cultures, and other life forms.
16. Environmental justice calls for the education of present and future generations which emphasizes
social and environmental issues, based on our experience and an appreciation of our diverse cultural
perspectives.
17. Environmental justice requires that we, as individuals, make personal and consumer choices to
consume as little of Mother Earth’s resources and to produce as little waste as possible; and make the
conscious decision to challenge and reprioritize our lifestyles to insure the health of the natural world for
present and future generations.

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Appendix B
Federal Executive Order on Environmental Justice
FEDERAL ACTIONS TO ADDRESS ENVIRONMENTAL JUSTICE
IN MINORITY POPULATIONS AND LOW-INCOME POPULATIONS
By the authority vested in me as President by the Constitution and the laws of the United States of America,
it is hereby ordered as follows:
Section 1-1. IMPLEMENTATION.
1-101. Agency Responsibilities.
To the greatest extent practicable and permitted by law, and consistent with the principles set forth In the
report on the National Performance Review, each Federal agency shall make achieving environmental justice
part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human
health or environmental effects of its programs, policies, and activities on minority populations and lowincome populations in the United States and its territories and possessions, the District of Columbia, the
Commonwealth of Puerto Rico, and the Commonwealth of the Marian islands.
1-102. Creation of an Interagency Working Group on Environmental Justice
(a) Within 3 months of the date of this order, the Administrator of the Environmental Protection Agency
(“Administrator”) or the Administrator’s designee shall convene an Interagency Federal Working Group on
Environmental Justice (“Working- Group”). The Working Group shall comprise the heads of the following
executive agencies and offices, or their designees: (a)Department of Defense; (b) Department of Health
and Human Services; (c)Department of Housing and Urban Development; (d) Department of Labor; (e)
Department of Agriculture; (f) Department of Transportation; (g) Department of Justice; (h) Department of
the Interior; (i) Department of Commerce; (j) Department of Energy; (k) Environmental Protection Agency;
(1) Office of Management and Budget; (m) Office of Science and Technology Policy; (n) Office of the
Deputy Assistant to the President for Environmental Policy; (o) Office of the Assistant to the President for
Domestic Policy; (p) National Economic Council; (q) Council of Economic Advisers; and (r) such other
Government officials as the President may designate. The Working Group shall report to the President
through the Deputy Assistant to the President for Environmental Policy and the Assistant to the President
for Domestic Policy.
(b)The Working Group shall: (1) provide guidance to Federal agencies on criteria for identifying disproportionately high and adverse human health or environmental effects on minority populations and low-income
populations;
(2)coordinate with, provide guidance to, and serve as a clearinghouse for, each Federal agency as it
develops an environmental justice strategy as required by section 1-103 of this order, in order to ensure
that the administration, interpretation and enforcement of programs, activities and policies are undertaken
in a consistent manner; (3) assist in coordinating research by, and stimulating cooperation among, the
Environmental Protection Agency, the Department of Health and Human Services, the Department of
Housing and Urban Development, and other agencies conducting research or other activities in accordance
with section 3-3 of this order;
(4) assist in coordinating data collection, required by this order;
(5) examine existing data and studies on environmental justice;

88

(6) hold public meetings at required in section 5-502(d) of this order; and
(7) develop interagency model projects on environmental justice that evidence cooperation among Federal
agencies.
1-103. Development of Agency Strategies.
(a) Except as provided in section 6-605 of this order, each Federal agency shall develop an agency-wide
environmental justice strategy, as set forth in subsections (b) - (e) of this section that identifies and addresses
disproportionately high and adverse human health or environmental effects of its programs, policies, and
activities on minority populations and low-income populations. The environmental justice strategy shall list
programs, policies, planning and public participation processes, enforcement, and/or rulemakings related to
human health or the environment that should be revised to, at a minimum: (1) promote enforcement of
all health and environmental statutes in areas with minority populations and low-income populations: (2)
ensure greater public participation; (3) improve research and data collection relating to the health of and
environment of minority populations and low-income populations; and (4) identify differential patterns of
consumption of natural resources among minority populations and low-income populations. In addition,
the environmental justice strategy shall include, where appropriate, a timetable for undertaking identified
revisions and consideration of economic and social implications of the revisions.
(b) Within 4 months of the date of this order, each Federal agency shall identify an internal administrative
process for developing its environmental justice strategy, and shall inform the Working Group of the process.
(c) Within 6 months of the date of this order, each Federal agency shall provide the Working Group with an
outline of its proposed environmental justice strategy.
(d) Within 10 months of the date of this order, each Federal agency shall provide the Working Group with
its proposed environmental justice strategy.
(e) Within 12 months of the date of this order, each Federal agency shall finalize its environmental justice
strategy and provide a copy and written description of its strategy to the Working Group. During the 12
month period from the date of this order, each Federal agency, as part of its environmental justice strategy,
shell identify several specific projects that can be promptly undertaken to address particular concerns identified during the development of the proposed environmental justice strategy, and a schedule for implementing
those projects.
(f) Within 24 months of the date of this order, each Federal agency shall report to the Working Group on its
progress in implementing its agency-wide environmental justice strategy.
(g) Federal agencies shall provide additional periodic reports to the Working Group as requested by the
Working Group.
1-104. Reports to The President.
Within 14 months of the date of this order, the Working Group shall submit to the President, through the
Office of the Deputy Assistant to the President for Environmental Policy and the Office of the Assistant to the
President for Domestic Policy, a report that describes the implementation of this order, and includes the final
environmental justice strategies described in section 1-103(e) of this order.
Sec. 2-2. Federal Agency Responsibilities For Federal Programs.
Each Federal agency shall conduct its programs, policies, and activities that substantially affect human health
or the environment, in a manner that ensures that such programs, policies, and activities do not have the effect
of excluding persons (including populations) from participation in, denying persons (including populations)

89

the benefits of, or subjecting persons (including populations) to discrimination under, such, programs,
policies, and activities, because of their race, Color, or national origin.
Sec. 3-3. Research, Data Collection, and Analysis
3-301. Human Health and Environmental Research and Analysis. (a) Environmental human health research,
whenever practicable and appropriate, shall include diverse segments of the population in epidemiological
and clinical studies, including segments at high risk from environmental hazards, such as
minority populations, low-income populations and workers who may be exposed to, substantial environmental hazards.
(b) Environmental human health analyses, whenever practicable and appropriate, shall identify multiple and
cumulative exposures.
(c) Federal agencies shall provide minority populations and low-income populations the opportunity to
comment on the development and design of research strategies undertaken pursuant to this order.
3-302. Human Health and Environmental Data Collection and Analysis To the extent permitted by existing
law, including the Privacy Act, as amended (5 U.S.C. section 552a): (a) each federal agency, whenever
practicable and appropriate, shall collect, maintain, and analyze information assessing and comparing environmental and human health risks borne by populations identified by race, national origin, or income. To
the extent practical and appropriate, Federal agencies shall use this information to determine whether their
programs, policies, and activities have disproportionately high and adverse human health or environmental
effects on minority populations and low-income populations;
(b) In connection with the development and implementation of agency strategies in section 1-103 of
this order, each Federal agency, whenever practicable and appropriate, shall collect, maintain and analyze
information on the race, national origin, income level, and other readily accessible and appropriate information for areas surrounding facilities or sites expected to have substantial environmental, human health, or
economic effect on the surrounding populations, when such facilities or sites become the subject of a
substantial Federal environmental administrative or judicial action. Such information shall be made available
to the public unless prohibited by law; and
(c) Each Federal agency, whenever practicable and appropriate, shall collect, maintain, and analyze information on the race, national origin, income level, and other readily accessible and appropriate information for
areas surrounding Federal facilities that are: (1) subject to the reporting requirements under
the Emergency Planning and Community Right-to-Know Act, 42 U.S.C. section 11001-11050 as mandated
in Executive Order No. 12856; and (2) expected to have a substantial environmental, human health, or
economic effect on surrounding populations. Such information shall be made available to the public unless
prohibited by law.
(d) In carrying out the responsibilities in this section, each Federal agency, whenever practicable and
appropriate, shall share information and eliminate unnecessary duplication of efforts through the use of
existing data systems and cooperative agreements among Federal agencies and with State, local, and tribal
governments.
Sec. 4-4. Subsistence Consumption Of Fish And Wildlife.
4-401. Consumption Patterns. Inorder to assist in identifying the need for ensuring protection of populations
with differential patterns of subsistence consumption of fish and wildlife, Federal agencies, whenever
practicable and appropriate, shall collect, maintain, and analyze information on the
consumption patterns of populations who principally rely on fish and/or wildlife for subsistence. Federal

90

agencies shall communicate to the public the risks of those consumption patterns.
4-402. Guidance. Federal agencies, whenever practicable and appropriate, shall work in a coordinated manner
to publish guidance reflecting the latest scientific information available concerning methods for evaluating the
human health risks associated with the consumption of pollutant-bearing fish or
wildlife. Agencies shall consider such guidance in developing their policies and rules.
Sec. 5-5. Public Participation and Access to Information
(a) The public may submit recommendations to Federal agencies relating to the incorporation of environmental
justice principles into Federal agency programs or policies. Each Federal agency shall convey such recommendations to the Working Group.
(b) Each Federal agency may, whenever practicable and appropriate, translate crucial public documents,
notices, and hearings relating to human health or the environment for limited English speaking populations.
(c) Each Federal agency shall work to ensure that public documents, notices, and hearings relating to human
health or the environment are concise, understandable, and readily accessible to the public.
(d) The Working Group shall hold public meetings, as appropriate, for the purpose of fact-finding, receiving
public comments, and conducting inquiries concerning environmental justice. The Working Group shall
prepare for public review a summary of the comments and recommendations discussed at the public meetings.
Sec. 6-6. General Provisions.
6-601. Responsibility for Agency Implementation. The head of each Federal agency shall be responsible for
ensuring compliance with this order. Each Federal agency shall conduct internal reviews and take such other
steps as may be necessary to monitor compliance with this order.
6-602. Executive Order No. 12250. This Executive order is intended to supplement but not supersede
Executive Order No. 12250, which requires consistent and effective implementation of various laws prohibiting discriminatory practices in programs receiving Federal financial assistance. Nothing
herein shall limit the effect or mandate of Executive Order No. 12250.
6-6O3. Executive Order No. 12875. This Executive order is not intended to limit the effect or mandate of
Executive Order No. 12875.
6-604. Scope. For purposes of this order, Federal agency means any agency on the Working Group, and such
other agencies as may be designated by the President, that conducts any Federal program or activity that
substantially affects human health or the environment. Independent agencies are requested to comply with
the provisions of this order.
6-605. Petitions far Exemptions. The head of a Federal agency may petition the President for an exemption
from the requirements of this order on the grounds that all or some of the petitioning agency’s programs or
activities should not be subject to the requirements of this order.
6-606. Native American Programs. Each Federal agency responsibility set forth under this order shall apply
equally to Native American programs. In addition the Department of the Interior, in coordination with the
Working Group, and, after consultation with tribal leaders, shall coordinate steps to be taken pursuant to this
order that address Federally- recognized Indian Tribes.
6-607. Costs. Unless otherwise provided by law, Federal agencies shall assume the financial costs of
complying with this order.

91

6-608. General. Federal agencies shall implement this order consistent with, and to the extent permitted
by, existing law.
6-609. Judicial Review. This order is intended only to improve the internal management of the executive
branch and is not intended to, nor does it create any right, benefit, or trust responsibility, substantive or
procedural, enforceable at law or equity by a party against the United States, its agencies, its officers, or any
person. This order shall not be construed to create any right to judicial review involving the compliance or
noncompliance of the United States, its agencies, its officers, or any other person with this order.
William J. Clinton
THE WHITE HOUSE,
February 11, 1994.

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Appendix C
Declaration of Intent to Cooperatively Participate
In the Sonoran Desert Conservation Plan
The Tohono O’odham Nation
and Pima County Government
WHEREAS, the Sonoran Desert is homeland to the Tohono O’odham Nation; and
WHEREAS, Members of the Tohono O’odham Nation have made a most significant contribution to the
cultural resource base of the Sonoran Desert; and
WHEREAS, Members of the Tohono O’odham Nation have great knowledge about the natural resource
base of the Sonoran Desert; and
WHEREAS, Members of the Tohono O’odham Nation have demonstrated wisdom in utilizing scarce
water resources in the Sonoran Desert; and
WHEREAS, on March 2, 1999, the Pima County Board of Supervisors committed to preserving and
protecting the Sonoran Desert through the adoption of the Sonoran Desert Conservation Plan in concept;
and
WHEREAS, the Sonoran Desert Conservation Plan seeks to protect and preserve cultural and historic
resources; and
WHEREAS, under the Sonoran Desert Conservation Plan, 12 habitat types, 20 plant communities, 108
vulnerable species are being considered for protection; and
WHEREAS, for the Sonoran Desert Conservation Plan to be truly comprehensive and meaningfully
conserve the resources important to the original and new residents of the Sonoran Desert, a cooperative
and collaborative effort is needed between Pima County and the Tohono O’odham;
NOW THEREFORE BE IT DECLARED THAT THE BOARD OF SUPERVISORS OF PIMA
COUNTY, ARIZONA,
Will seek to collaborate with Tohono O’odham Nation in developing and establishing the Sonoran
Desert Conservation Plan.
SIGNED THIS 11th day of December,1999.
Edward D. Manuel
Tohono O’odham Nation

Sharon Bronson
Pima County

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Appendix D
1974 Projected Costs of Alternate Plans for Growth
Summary of Cost Impacts (In Millions of Dollars)
Low Population
Peripheral Contained
Expansion
Growth
CAPITAL
Total Capital Cost

1,769

1,409

High Population
Peripheral Activity Contained Satellite
Expansion Centers
Growth
Cities
2,563

2,308

1,732

1,985

Savings over
Peripheral Expansion

360

255

831

578

Percent of
Peripheral Expansion

79,6%

90.1%

67.6%

77.4%

339

328

330

OPERATING
Total Annual Cost

242

233

343

Savings over
Peripheral Expansion

9

4

15

13

Percent of
Peripheral Expansion

96.3%

98.8%

95.5%

96.2%

Source: Cost/Revenue Analysis Four Alternative Plans for Growth. Prepared for the Pima County
Comprehensive Planning Process. Booz, Allen and Hamilton. San Francisco. 1974. p. 8.
Figures are in 1974 dollars. The equivalent in 2000 dollars would be approximately 3.2 times the
1974 dollar amounts.

94

Appendix E
Sources of Information

1.

Introduction to Environmental Justice

2.

The Diversity of Cultures in Pima County

Adamson, Joni. 2001. American Indian Literature, Environmental Justice, and Ecocriticism. University of
Arizona Press. Tucson.
Anon. 1988a. Urban Stress Test. Zero Population Growth. Washington D.C.
Anon. 2001c. Kid Friendly Cities. Zero Population Growth. Washington D.C.
Anon. 2001d. Composite Stress Index. City of Tucson Planning Department. www.ci.az.us.gov
Bryant, Bunyan. 1995. Environmental Justice: Issues, Policies, and Solutions. Island Press. Washington DC.
Getches, David H. and D.N. Pellow. Beyond Traditional Environmental Justice. IN Mutz, K.M., G.C. Bryner, and
D.S. Kenney. 2002. Justice and Natural Resources. Island Press. Washington D.C.
Lee, Charles. Developing Working Definitions of Urban Environmental Justice. Race, Poverty and the
Environment. 3(4):3-5 and 23.
Mutz, K.M., G.C. Bryner, and D.S. Kenney. 2002. Justice and Natural Resources. Island Press. Washington
D.C.
Talbot, E.O. and G.F. Craun. 1995. Introduction to Environmental Epidemiology. Lewis Publishers. Boca
Raton.
Weinhold, Robert. 1997. Rating Guide to Environmentally Healthy Metro Areas. Animas Press. Durango.
Housing

Anon. 1972. Barrio Historico. College of Architecture. University of Arizona. Tucson.
Anon. 1984. Tales told in our Barrio: A Carrillo School Project. Tucson Unified School
District #1. Tucson.
Anon. 1985. Tohono O’odham: History of the Desert People. Papago Tribe. University of Utah Printing
Services.
Anon. 1997 Visions of Barrio Anita. Tucson Pima Arts Council. Tucson.
Anon. 1998b. Pima County Health Status 1997. Pima County Health Department. Tucson.
Anon. 2000. Un Camino al Rio. A Path to the River. Memories of the Santa Cruz River and Barrio Anita.
Path to the River Press. Tucson.
Bret Harte, John. 1980. Tucson: Portrait of a Desert Pueblo. Windsor Publications. Woodland Hills, CA.
Drachman, Roy P. 1999. From Cowtown to Desert Metropolis. Ninety Years of Arizona Memories. Whitewing
Press. San Francisco.
Fontana, Bernard. 1989. Of Earth and Little Rain. University of Arizona Press. Tucson.
Haley, James L. 1997. Apaches : a History and Culture portrait. University of Oklahoma Press Norman
Henry, Bonnie. 1992. Another Tucson. Arizona Daily Star. Tucson.
Kelly, Regina. Don’t Look at Me Different. No Me Veas Diferente. Voices from the Projects. Voces de los
Proyectos. Tucson Voices Press. Tucson
Lawson, Harry. 1996 and 2000. The History of African Americans in Tucson: an Afrocentric Perspective.
Lawson’s Psychological Services. 2 vols.
Lister, Florence and R. Lister. 1989. The Chinese of Early Tucson. Historic Archaeology from the Tucson Urban
Renewal Project. University of Arizona Press. Tucson
Maclaury, Maria I. 1989. La Placita: Vantages of Urban Change in Historic Tucson. MA Thesis. University
of Arizona.
Martin, Patricia. 1998. Days of Plenty, Days of Want. Bilingual Press. Tempe.
Mason, Gertrude. Manuscripts at the Arizona Historical Society. Tucson
Perez, Alicia, Ed. 1998. Visions of Barrio Anita. Looking Through the Eyes of Different Generations. Tucson
Pima Arts Council. Tucson.
Sheridan, Thomas. 1986. Sonorenses, Tucsonenses IN Tucson: A Short History. Southwest Mission Research
Center. Tucson.

95

Sheridan, Thomas. 1986. Los Tucsonenses: The Mexican Community in Tucson, 1854-1941. University of
Arizona Press. Tucson.
Sonnichsen, C.L. 1982. Tucson: The Life and Times of an American City. University of Oklahoma Press.
Norman.
Valenzuela, Blanca, Ed. 1998. History Paints a Beautiful Picture. Report on the A Mountain Neighborhood
History for the Casa Alegre Mural Project. Casa Alegre Mural Project Coalition. Tucson.
www.heard.org/education/rain/cultura5/raincul9.html. Heard Museum. 2001

3.

Air Quality Issues

Anon. 2001a. Air Quality Strategies for the Comprehensive Plan. Sonoran Desert Conservation Plan Report.
Pima County.
Anon. 2001b. Transportation Primer. Sonoran Desert Conservation Plan Report. Pima County.
Anon. 2001c. Trends in Circulation. Sonoran Desert Conservation Plan Report. Pima County.
Anon. Various years. Annual Air Quality Report. Pima County Department of Environmental Quality. Tucson.
Caldwell, Roger. 1971. Air Pollution in Tucson. A Report to the Mayor and Council. Tucson Advisory
Committee on Air Pollution. Tucson.
Collins, Lynne. 1985. History of Air Pollution control in Pima County, Arizona (1962-1984). Pima County
Health Department. Tucson.
Lewis ,Tom. 1999. Divided Highways: Building the Interstate Highways, Transforming American Life. Viking
Penguin.
Mitchell, John. 2001. The American Dream: Urban Sprawl. National Geographic. July. 49-72.
Spencer, J.E. . 1992. Radon Gas - A Geologic Hazard in Arizona, by 1992, Down-to-Earth Series 2. Arizona
Geological Survey. Tucson.
Weinhold, Robert. 1997. Rating Guide to Environmentally Healthy Metro Areas. Animas Press. Durango.
Housing
Wood, Howard. 1998. How Government Highway Policy Encourages Sprawl.

4. Water Quality and Supply Issues

Adamson, Joni. 2001. American Indian Literature, Environmental Justice, and Ecocriticism. University of
Arizona Press. Tucson.
Anderson, S.R. 1997. Potential for Aquifer Compaction, Land Subsidence, and Earth Fissures in the Tucson
Basin, Pima County, Arizona. U.S.G.S. Hydrological Investigations Atlas 713. Tucson.
Anon. 1998. Anomalous Drinking Water Quality Data – Causes and Impacts. Pima Association of Governments.
Tucson.
Anon. 2000a. Superfund Programs Section Site Information. Arizona Department of Environmental Quality.
Phoenix.
Anon. 2001. Clearwater 2001. Tucson’s New Blended Water Resource. Tucson Water.
Tucson.
Anon. 2001. Water Quality in Pima County. Sonoran Desert Conservation Plan Report. Pima County.
Anon. Various years. Annual Water Quality Report. Tucson Water. Tucson.
Clarke, Jean and A. Gerlak. 1998. Environmental Racism in the Sunbelt? A Cross-Cultural
Analysis. Environmental Management. 22(6): 857-867.
Gelt, Joe, et al. 1999. Water in the Tucson Area: Seeking Sustainability. Water Resources Research Center.
University of Arizona. Tucson.
Halpenny, Leonard. 1962. Groundwater Resources Within the San Xavier Indian Reservation and Proposals
Relating to Leases for Development of Groundwater. Water Development Co. Tucson.
Slaff, Steve. 1993. Land Subsidence and Earth Fissures in Arizona. Arizona Geological Survey. Tucson.
Tellman, B. 2001. Water Resources in Pima County. Sonoran Desert Conservation Plan Report. Pima County.
Tellman B. 2001. Water Conservation in Pima County. Sonoran Desert Conservation Plan Report. Pima County.
Williams, Bryan, Florez and Pettygrove, 2001. Inter- and Intra-ethnic variation in water intake, contact, and source
estimates among Tucson residents: Implications for Exposure Analysis. Journal of Exposure Analysis and
Environmental Epidemiology 11 (6)
www.ci.tucson.az.us Tucson Water web site.

96

5.

Siting of Industry, Landfills, and Other Facilities

6.

Land Use and Housing

Anderson, S.R. 1997. Potential for Aquifer Compaction, Land Subsidence, and Earth Fissures in the Tucson
Basin, Pima County, Arizona. U.S.G.S. Hydrological Investigations Atlas 713. Tucson.
Anon. 1995. Landfills along the Santa Cruz River in Tucson and Avra Valley, Arizona. Pima Association of
Governments. Tucson.
Anon. 1998a. Existing and Proposed Wastewater Treatment Facilities and 208 Planning Boundaries in Pima
County. Pima Association of Governments. Tucson.
Anon. 1998b. Analysis of Impediments to Fair Housing Choice. Draft. City of Tucson and Pima County
Community Services Departments. Tucson. 1998.
Anon. 1999a. Evaluation of Methane Migration Potential at Closed Landfills. Solid Waste Management
Department. City of Tucson.
Anon. 1999b. Public Landfills and Permanent Transfer Stations in Eastern Pima County and Ajo. Pima
Association of Governments. Tucson.
Clarke, Jean and A. Gerlak. 1998. Environmental Racism in the Sunbelt? A Cross-Cultural
Analysis. Environmental Management. 22(6): 857-867.
Hoffman, John, et al. Investigation of the causes of sinks in the San Xavier District, Tohono O’odham Nation,
Pima County Arizona. U.S. Geological Survey Open-File Report 97-19. Tucson.
Leverenz, Chris and M.J. Dillard. 2000. Assessment of Gas Migration Potential in Old Landfills. IN Proceedings
of the Solid Waste Association of North America Third Annual Arid Climate Symposium, Albuquerque.
Lewis ,Tom. 1999. Divided Highways: Building the Interstate Highways, Transforming American Life. Viking
Penguin.
Slaff, Steve. 1993. Land Subsidence and Earth Fissures in Arizona. Arizona Geological Survey. Tucson.

Anon. 1973 Planning for Population Growth in the Tucson Area. League of Women Voters of Tucson. Tucson.
Anon. 1974. Interceptor Sewers and Suburban Sprawl: the Impact of Construction Grants on Residential Land
Use. Urban Systems Research and Engineering. Prepared for the Council on Environmental Quality.
Washington D.C.
Anon. 1976, The Growth Shapers. The Land Use Impacts of Infrastructure Investments. Urban Systems
Research and Engineering for the Council on Environmental Quality. Washington D.C.
Anon. 1985. Growth Management and Land Use Planning in Arizona. Arizona Town Hall. Phoenix.
Anon. 1999. Community Development: Extent of Federal Influence on Urban Sprawl is Unclear. General
Accounting Office. Washington D.C.
Anon. 2000. Sprawl Costs Us All. Sierra Club. San Francisco
Anon. 2001a. Committed Lands in Eastern Pima County. Sonoran Desert Conservation Plan Report. Pima
County.
Anon. 2001b. Pima County Comprehensive Plan Update. 2001. Sonoran Desert Conservation Plan Report.
Pima County.
Anon. 2001c. Pima County Planning and Zoning Primer. 2001. Sonoran Desert Conservation Plan Report.
Pima County.
Anon. 2001d. Regional Plan Policies and the Development Policy in the Conservation Lands System. Sonoran
Desert Conservation Plan Report. Pima County.
Anon. 2001e. Housing in Pima County. Sonoran Desert Conservation Plan Report. Pima County.
Anon. 2001f. Inclusionary Housing Study. Sonoran Desert Conservation Plan Report. Pima County.
Anon. 2001g. Trends in Housing Affordability. Sonoran Desert Conservation Plan Report. Pima County.
Anon. 2001h. Trends in Housing Costs and the Affordable Housing Development Policy. Sonoran Desert
Conservation Plan Report. Pima County.
Anon. 2001i. Universal Design for Adaptations in Housing. Sonoran Desert Conservation Plan Report. Pima
County.
Anon. 2001j. Emerging Trends in Real Estate. PricewaterhouseCoopers and Lend Lease Real
Estate Investments. New York.
Bohlke, Linda. 1993. Unfulfilled promises: Racial discrimination and neglect in Tucson’s public
and federally subsidized housing. Southern Arizona People’s Law Center. Tucson.

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Brown, Lester. 1987. The future of Urbanization: Facing the Ecological and Economic
Constraints. Worldwatch Paper #77. Washington DC.
Bullard, Robert. Residential Apartheid in Urban America.: Race, Poverty and the Environment.
3(4):7-8.
Bullard, Robert D. G. S. Johnson ,and A. O. Torres. 2000. Sprawl City: Race, Politics and Planning in Atlanta.
Island Press.
DeKok, David, et al. Eds. 1996. Arizona’s Growth and the Environment – A World of Difficult
Choices. Arizona Town Hall. Phoenix.
Diamond, Henry and P. Noonan. 1996. Land Use in America. Island Press. Washington DC.
Drachman, Roy P. 1999. From Cowtown to Desert Metropolis. Ninety Years of Arizona Memories. Whitewing
Press. San Francisco.
Duany, Andres, E Plater-Zyberk and J. Speck. 2000. Suburban Nation: The Rise of Sprawl and the Decline of the
American Dream. Northpoint Press. New York.
Fodor, Eben. 1996. The Three Myths of Growth. Planning Commissioners Journal. 21:18-19.
Fodor, Eben. 1998. Bigger not Better. New Society Publishers.
Gerckens, Laurence C. 1994. American Zoning and the Physical Isolation of Uses. Planning Commissioners
Journal. 15:10-11.
Geddes, Robert. Ed. 1997. Cities in Our Future. Island Press. Washington DC.
Helm, Mike and G. Tukel. Restoring Cities form the Bottom Up. Race, Poverty and the Environment. 3(4):1
and 20-22.
Hampson, Fen and J. Reppy. Eds. 1996. Earthly Goods: Environmental Change and Social Justice. Cornell
University Press. Ithaca.
Kelly, Regina. Don’t Look at Me Different. No Me Veas Diferente. Voices from the Projects. Voces de los
Proyectos. Tucson Voices Press. Tucson
Kemp-Rye, Mark. 2001. Smart Growth and Small Communities: Sprawl Comes to Rural America. On Tap. 1(3)
National Drinking Water Clearinghouse.
Kunstler, James H. 1996. Home From Nowhere. The Atlantic Monthly. 278(3):43-66.
Mason, Gertrude. Manuscripts. Arizona Historical Society. Tucson.
McMahon, Edward. 2001. Building Codes Get Smarter. Planning Commissioners Journal 66(3): 265-279.
Mitchell, John. 2001. The American Dream: Urban Sprawl. National Geographic. July. 49-72.
Moe, Richard and C. Wilkie. 1997. Changing Places: Rebuilding Community in the Age of Sprawl. Henry
Holt & Co. New York.
Orfield, Myron. 1997. Metropolitics: A Regional Agenda for Community and Stability. Brookings Institution.
Washington D.C.
Rome, Adam. 2001. The Bulldozer in the Countryside. Suburban Sprawl and the Rise of American
Environmentalism. Cambridge University Press. Cambridge.
Shaw, Jane S. and R Utt. 2000. A Guide to Smart Growth: Shattering Myths, Providing
Solutions. Heritage Foundation and Political Economy Research Center. Washington DC
and Bozeman.
Sternberg, Ernest. 2000. An Integrative Theory of Urban Design. Journal of the American Planning Association.
McMahon, Edward T. 1997. Stopping Sprawl by Growing Smarter. Planning Commissioners Journal. 26:4-5.
Tellman, Barbara. Ed. 1988. Saguaro We Going? Impacts of Population Growth in Eastern Pima County.
Sierra Club. Tucson.
Whittier, Jim. 2001. How Smart Growth Can Address Environmental Justice Issues. NGA Center for Best
Practices.
www.ejrc.cau.edu web site of the Environmental Justice Research Center. Clark Atlants University.
www.gov.calgary.ab.ca web site of the City of Calgary.

7.

Fiscal Issues

Anon. 1974. Interceptor Sewers and Suburban Sprawl: the Impact of Construction Grants on Residential Land
Use. Urban Systems Research and Engineering. Prepared for the
Anon. 1999. Community Development. Extent of Federal Influence on “Urban Sprawl” is Unclear.
GAO/RCED-99-87. General Accounting Office. Washington D.C.

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Anon. 2000. Impact of Unregulated Development at the Community and Watershed Level. Sonoran Desert
Conservation Plan Report. Pima County.
Anon. 2001a. Concurrency and Urban Development. Sonoran Desert Conservation Plan Report. Pima County.
Anon. 2001b. Impact Fee and Affordable Housing Study. Sonoran Desert Conservation Plan Report. Pima
County.
Anon. 2001c. Level of Service Study. Sonoran Desert Conservation Plan Report. Pima County.
Anon. 1974. The Costs of Sprawl. Real Estate Research Corporation for the Council on Environmental Quality.
Washington D.C.
Anon. 1974a. Interceptor Sewers
Anon. 1998. Sprawl Costs us All. Grand Canyon Chapter of the Sierra Club. Phoenix.
Anon. 2001a. Fact Sheet: Cost of Community Services Studies. American Farmland Trust. Washington D.C.
www.farmlandinfo.org
Booz, Allen, and Hamilton. 1974. Cost/Revenue Analysis: Four Alternate Plans for Growth. A Report for Pima
County, San Francisco.
Conroy, M. 1977. The Potential Economic Impact of the Physical Development Guide for Eastern Pima County.
Tucson.
Fodor, Eben. 1998. Bigger not Better. New Society Publishers.
Guilory, Renee. 1998. Sprawl Costs us All. Sierra Club, Grand Canyon Chapter. Phoenix.
Hanchett, Thomas. 2001. The Other “Subsidized Housing.” Journal of Housing and Community Development.
Jan-Feb.:19-22, 42-49.
Kemp-Rye, Mark. 2001. Smart Growth and Small Communities: Sprawl Comes to Rural America. On Tap. 1(3)
National Drinking Water Clearinghouse.
Ladd, Helen. 2000. Effects of Population Growth on Local Spending and Taxes. Research in Urban Economics.
9:181-223
Lewis ,Tom. 1999. Divided Highways: Building the Interstate Highways, Transforming American Life. Viking
Penguin.
Nash, Gerald. 1999. The Federal Landscape: An Economic History of the Twentieth Century West. University
of Arizona Press. Tucson.
Robinson, Susan G., Ed. 1990. Financing Growth: Who Benefits? Who Pay? And How Much? Government
Finance Officers Association. Chicago.
Van Horn, Renee. 1993. The Cost of Community Services in Madison Village and Township, Lake County, Ohio.
American Farmland Trust. Northampton MS.

8.

Cultural and Environmental Issues

Adamson, Joni. 2001. American Indian Literature, Environmental Justice, and Ecocriticism. University of
Arizona Press. Tucson.
Anon. 1944. Official Statement by the Co-Chairman. Tucson Committee for Inter-Racial Understanding. March
22, MS Arizona Historical Society.
Anon. 1996. Environmental Justice, Urban Revitalization, and Brownfields: The Search for Authentic Signs of
Hope. National Environmental Justice Advisory Council. EPA. Washington DC.
Anon. 1997. Environmental Justice: Guidance under the National Environmental Policy Act. Council on
Environmental Quality. Washington DC.
Anon. 1987. Alarming Trends – 1986. Caveat Emptor. Phoenix South Community Mental Health Center.
Phoenix.
Anon. 1998b. Pima County Health Status 1997. Pima County Health Department. Tucson.
Anon. 1999. Preserving Cultural and Historic Resources. A Conservation Objective of the Sonoran Desert
Conservation Plan. Sonoran Desert Conservation Plan Report. Pima County.
Anon. 2000a.Relationships Between Land and People. The Cultural Landscapes Approach in Archaeology and
History. Sonoran Desert Conservation Plan Report. Pima County.
Anon. 2000b. Overview of Traditional Cultural Places in Pima County. Sonoran Desert Conservation Plan
Report. Pima County.
Anon. 2001a. People and Places: Cultural Landscapes and Pima County. Sonoran Desert Conservation Plan
Report. Pima County.

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Anon. 2001b. The Environmental Protection Agency’s Environmental Justice Strategy.
www.epa.gov
Anon. 2002a Trails, Rails, and Roadways in Pima County. Sonoran Desert Conservation Plan Report. Pima
County.
Anon. 2002b. Priority Cultural Resources in Pima County. Sonoran Desert Conservation Plan Report. Pima
County.
Getches, David H. and D.N. Pellow. Beyond Traditional Environmental Justice. IN Mutz, K.M., G.C. Bryner, and
D.S. Kenney. 2002. Justice and Natural Resources. Island Press. Washington D.C.
Helm, Mike and G. Tukel. Restoring Cities form the Bottom Up. Race, Poverty and the Environment. 3(4):1
and 20-22.
Jackson, Richard and C. Kochtitzky. 2001. Creating a Healthy Environment: The Impact of the Built Environment
on Public Health. Sprawl Watch Clearinghouse Monograph Series.
Roodman, David and N. Lenssen. 1995. A Building Revolution: How Ecology and Health Concerns are
Transforming Construction. Worldwatch Paper #124. Washington DC.
Weaver, J. Ed. 1997. Defending Mother Earth: Native American Perspectives on Environmental Justice. Orbis
Books. Maryknoll NY.
Chapter 9. Conclusions
Weaver, J. Ed. 1997. Defending Mother Earth: Native American Perspectives on Environmental Justice. Orbis
Books. Maryknoll NY.

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