GNLCC Not "Germane" To Targhee Pass Project

One of the issues brought up in the scoping report comments was the relationship of the Great Northern Landscape Conservation Cooperative (GNLCC) to the Targhee Pass transportation project.  In the updated, 2018 Targhee Pass EA Scoping Report, on page 14, there is a basic summary of Department of Interior (DOI) secretarial orders (SO) that are pertinent to the existence of landscape conservation cooperatives, which includes the GNLCC.  The report states, "...land use planning and landscape scale conservation/mitigation are beyond the scope of ITD’s mission...", and those SOs are "...are not germane to Federal Highway Administration procedures."

That is interesting.  In a 2013 GNLCC newsletter it specifically states, "...MAP-21 is the first national transportation law to weave throughout its programs authority for state, federal and tribal managers, and researchers to reduce the number of motorist collisions with wildlife and improve connectivity among habitats disrupted by roads."  The Center For Large Landscape Conservation (CLLC) even provided further clarification on this federal highway law.

Another factor that needs consideration is the relationship Idaho Fish & Game (IDFG) has with the GNLCC.  The EA report also states, "The Idaho Department of Fish and Game’s (IDFG) interest in collaborating with ITD as described in the MOU stems from IDFG’s mission to preserve, protect, perpetuate, and manage the fish and wildlife populations of the state."  There are actually two MOUs between ITD and IDFG, one in 2015, and the second in 2017.  What the report left out was the MOUs state in the 2015 report that IDFG would be responsible for "...increasing wildlife linkage/connectivity/corridors...", and reiterated in the 2017 report, "...provide for wildlife connectivity...", "...facilitate...migration corridors for wildlife...", and "...develop...site specific information...on wildlife crossings...wildlife connectivity and wildlife crossing designs."

This is relevant because IDFG is involved with the GNLCC and its objectives for overpasses.  Not only does IDFG partner with GNLCC partner Yellowstone 2 Yukon (Y2Y), IDFG has also received funding from the GNLCC for a Decision Support System project, and other projects.  One project was even led by GNLCC member and IDFG employee, Gregg Servheen, the Transboundary Decision Support System to Guide and Implement Conservation, Land Use, Energy, Transportation, and Climate Change Management and Monitoring, which included connectivity.

In summary, IDFG is involved with the GNLCC, there are federal laws that require transportation projects to include wildlife mitigation, the ITD MOUs state the IDFG role is for corridors and connectivity, the GNLCC objectives include wildlife corridors and connectivity, all which makes the GNLCC very "germane" to the Targhee Pass Project.