This week in the IP News 2 informative posts were published. Both contained one operative word, “currently” and on that basis were carefully worded.
First there was this one:
“Currently" there are no wildlife overpasses or anything associated with them to consider. But, if and when there are, then Idaho Fish & Game has a different answer for us.
Then there was also this article:
Ms. Davey we have one question:
Once wildlife overpasses are constructed how do you get back across The Targhee National Forest to achieve ‘connectivity’ to Yellowstone for multiple "species of greatest conservation need", defining what are the perimeters of their necessary protected habitats, or widths and lengths of their dispersal and migratory corridors, or define the restrictions and management requirements of all necessary ‘right-of-ways’….without having to re-visit the management plan of The Targhee National Forest?
FREMONT COUNTY COMMISSIONERS MEETING MINUTES February 26, 2018
District Ranger Elizabeth Davy RE: Ashton/Island Park Ranger District Updates
"She (Ms. Davy) is working with ITD on the Targhee Pass Project providing the environmental analysis for potential widening of the road and a potential wildlife crossing. "She is writing letters supporting various grants for ITD and other things."
Now we have the USFS working with ITD on the TPP…how many sate and federal agencies are involved and once again this is all news to Fremont County because we sure haven’t been invited to participate.
A letter written by the Board of the Henry's Fork Chapter Idaho Master Naturalist Program, titled, "Who Are The Idaho Master Naturalists (IMNs), was posted in the IP News on 3/22/18. The article basically describes the functions of the organization. This was first addressed by the Citizen Advocacy For Island Park Idaho Issues face book page.
A list of their "only" partners included Idaho Fish & Game, US Forest Service, Henry's Fork Foundation, Nature Conservancy, and Idaho Department of Parks & Recreation. The article pointed out they are restricted from volunteering "...for political issues or advocacy of a political nature.", pointing out that "allegations" of involvement with non-governmental organizations were "false", and that they were not "participating in any campaign pertaining to the options...being considered by ITD for the Hwy 20 Targhee Pass project." However, the Nature Conservancy is an NGO.
In researching the statement regarding not participating in campaigns for alternatives this Facebook post was found from July 12, 2016, in partnership with the Island Park Safe Wildlife Passage (IPSWP) group which advocates for wildlife overpasses. IPSWP is coordinated by Yellowstone 2 Yukon (Y2Y). Although it appears the Henry's Fork Legacy Project (HFLP) created the IPSWP, the contact is Kim Trotter, the US Program Director for Y2Y.
IMN stated they do not partner with non governmental organizations (NGO), however they listed the NGO Nature Conservancy as a partner in the article. In further researching this, it was found that Y2Y lists the IMNs as a collaborating partner, along with the HFLP which was created by Y2Y, on page 12 of this 2015 annual Y2Y report. Y2Y is one of the lead initiatives for wildlife overpasses in the Island Park area.
Another NGO the IMN partners with is the Wildlife Conservation Society (WCS). As stated in this 2015 ScienceDaily article, "...WCS and IDFG recruited the help of the Idaho Master Naturalists (IMN)..." to "...conduct surveys for animal tracks alongside U.S. Highway 20...". This partnership was also recognized in a Rexburg Standard Journal article as seen in the graphic below.
The Island Park and Idaho Falls Idaho Master Naturalists volunteered for the US20 Road Ecology Report in which the WCS also participated.
In the June 8, 2016 IMN meeting minutes report, in which the link has now been removed by IDFG, but a pdf of that meeting can be found under the IP Focus tab, there seems to be an indication that IMN has regular contact with the HFLP and ITD, both of which are promoting wildlife overpasses.
There seems to be adequate evidence that the IMN did indeed partner, collaborate, and secondarily to that, promote objectives of the Y2Y created HFLP and IPSWP, NGOs and state agencies.
Big Horn Hills Estate (BHHE) home owners, Ralph & Connie Kincheloe, participated in an interview with Zeb Bell on March 13 to discuss the wildlife overpasses at Targhee Pass, the impact it would have on that residential area, the questionable activities by the Idaho Transportation Department and Idaho Fish & Game, and the involvement by conservation initiatives.
To hear the full interview start at the 50:02 mark.
Is the Henry's Fork Legacy Project (HFLP) really a friend to Island Park? In describing their mission they state it is their dedication, "...to helping people in the Henry’s Fork area conserve their rural landscapes, rural lifestyles, and unique natural resources." Just who in the Henry's Fork area asked this group to take charge of how we live? HFLP also states they want to, "Help people conserve wildlife and reduce human/wildlife conflicts.", and "Provide information and tools to help the community guide new growth and development." It is the Fremont County planning and development board that has this responsibility. Wildlife and humans have shared Island Park for decades. Occasionally, there is a problem with bears given the high numbers of grizzly. But the HFLP has done NOTHING on this issue. Wildlife mortality on Hwy 20 does not even rank in the top 15 problem areas in Idaho.
Land conservation was identified as the beginning "focus". Can there be growth and development if you want to conserve everything? The Fremont County comprehensive plan addresses this delicate balance with private property owners. Development through the Targhee Pass area and on Henry’s Lake Flat is cloistered and animal movement is not obstructed by it.
According to HFLP history, "2006-2007 Forest Supervisor initiated HFLP to encourage conservation through a collaborative network of NGOs and agencies." This "network" is a conglomeration of groups that do not live in the area, who have specific ideological agendas. and which does not include Island Park residents as a whole. Even federal and state agencies are part of this group, agencies which are obligated to represent Idaho citizens. Following are "network" members.
Teton Regional Land Trust Henry’s Fork Foundation Idaho Fish and Game
Nature Conservancy Bureau of Land Management Future West
Caribou-Targee National Forest Wildlife Conservation Society Greater Yellowstone Coalition
Idaho Dept of Parks and Recreation Idaho Department of Lands Yellowstone 2 Yukon (Y2Y)
Interestingly, there is no identified board of directors or members on their website. While the Island Park Safe Wildlife Passage Initiative (IPSWPI) can be found on the HFLP website, and is listed as a "A working group of the Henry’s Fork Legacy Project" in their brochure, why is it that Y2Y is the contact for more information and Kim Trotter, Y2Y US Program Director, is also the Committee Chair of the initiative?
Another group Y2Y partners with is the local Henry's Fork Chapter of the Idaho Master Naturalists. They are listed as a "collaborating partner" on page 12 in the PDF that can be downloaded here, and along with Y2Y were acknowledged in the P. Cramer Safety Solutions report.
In 2009 HFLP also expanded their scope "...to include living with wildlife activities and land and natural resource planning." Generations of families making their home, and visitors, have been living with wildlife and protecting the natural resources in the Henry's Fork area for decades. It seems HFLP has decided no one is able to live with wildlife. Why?
A new objective was introduced in 2013, "...three committees were created representing the three legs of the “HFLP Stool”–Land Conservation, Living with Wildlife and Land Use and Public Land Management." Over the next two years it states they held "periodic'" meetings, conducted "communications outreach", and built a website. Does anyone remember these activities? Island Park residents are familiar with this name but meeting notes are not available on the HFLP website. Beyond the ISPWP initiative there seems to be no other activity.
In 2016 "they" and their "network members"..."Identified ITD Highway 20 redesign project as a new focus for the group." Y2Y is the force behind this group and brings their establishment and money to the effort. HFLP also claims, "The project meets the mission of the HFLP and has a strategic and longer, landscape-scale perspective." It is Y2Y that has a landscape scale perspective, but only for conservation.
Aside from all the evidence that the Idaho Transportation Department (ITD) has been partnering with groups on wildlife overpasses, it appears they had already made the decision to put wildlife overpasses in Island Park as early as June, 2016, without every bringing it to Island Park citizens or going through the required NEPA process!!
At the June 8, 2016 Idaho Master Naturalist (IMN) Henry's Fork Chapter meeting, it was announced, "James commented that the Idaho Department of Transportation is focusing on building four safe passages (either over or under passages). Two may be located in or around Island Park."
Hmmm, ITD already made the decision to build overpasses in Island Park.
A copy of those meeting notes can be read below, page 4, or online here. (Update, as of 3/22/18 this link was removed by IDFG, however an archived copy is here)
This comment was made prior to a letter from Henry's Fork Legacy Project (HFLP) to ITD, dated July 29, 2016, regarding a private meeting that was held at the invitation of ITD and their support of wildlife overpasses specifically at Targhee Pass. The letter was also signed by the following initiatives and individuals.
David Weskamp - Conservation Manager for East Idaho - The Nature Conservancy
Dennis Glick - Executive Director - Future West
Jamie Laatsch - Conservation and Outreach Coordinator - Henry's Fork Foundation
Kathy Rinaldi - Idaho Conservation Coordinator - Greater Yellowstone Coalition
Kim Trotter - US Program Director - Yellowstone to Yukon Conservation Initiative
Mary and Parmer VanFleet - Residents, Island Park - Member Idaho Master Naturalists, HFLP, HLF, Henry’s Fork Foundation, The Nature - Conservancy, Teton Regional Land Trust
Renee Seidler - Associate Conservation Scientist - Wildlife Conservation Society, North America Program
Timothy D. Reynolds, Ph.D. - Certified Wildlife Biologist
The letter can be read below.
Without ever considering all of the public participation and local government coordination requirements, ITD has already colluded with special interest groups and made the decision for overpasses. These groups were also allowed the privilege to submit comments, or in other words front load their comments, before ITD opened up the comment period to Island Park residents, or even before the project was brought to them in December, 2016! How did their ability to front load comments affect the outcome of the EA Scoping Report? Did this not cause a bias in the comment numbers??? Is there not something illegal about this?
Federal laws are very clear, a proper process must be followed requiring coordination from the initial planning and development stages of any impact project which has not occurred in Fremont County and Island Park. Should this highway project be started over following the process law defines? Perhaps Island Park residents should demand this from ITD.
Reprinted with permission from the Island Park News.
Researching the proposed Targhee Pass Project, I found a very informative piece of information. In the scoping report, I found a reference to a 2014 MOU between ITD and IDFG concerning HWY 20 in an EPA letter citation.
IDFG and ITD had earlier MOUs. A 2004 MOU agreement covered a broad array of topics.
“Then in 2014, through a Strategic Highway Research Program (SHRP) grant, the two agencies were provided the opportunity to take a fresh look at roles, responsibilities and how to best work together. By coordinating statewide workshops, designed in a way that would extract the right issues, encourage productive discussions, what resulted were actionable items that could be implemented in a new MOU.”
The two agencies hired The Langdon Group (TLG) to help facilitate the process.
Area workshops for ITD District and IDFG Region staff were held in Moscow, Idaho Falls and Boise. Workshop participants also included representatives from the US Fish and Wildlife Service (USFWS), Federal Highway Administration (FHWA) and the Local Highway Technical Assistance Council (LHTAC).
What IS IMPORTANT FOR ISLAND PARK TO NOTE IS: “an afternoon session and small-group discussion was on (Data Sharing, Planning and Project Coordination, Road Kill, and Wildlife Crossings). Discussion topics were determined through key stakeholder interviews conducted by The Langdon Group, with ITD and IDFG staff, and vetted through the joint Technical Advisory Committee.”
Who are the members of this committee? Was there any local or regional elected representation present?
“Results and Benefits. ...In total, the workshops produced 175 pages of flip chart notes and 7,800 words. Input ranged from general observations to specific MOU recommendations. The Langdon Group worked closely with the two agencies to write a new MOU that is reflective of the needs and interests of those individuals intended to benefit from it.”
I have asked for a copy of this information and I am waiting for a response to my records request. I am sure it will cost me, it seems the price for truth is not cheap.
The conflict of interests involved in the Targhee Pass Project are PROFOUND!!
·Y2Y and the IP Master Naturalists, ITD, Heart of the Rockies and BioWest (and others) participated in the P. Cramer 2014-2015 HWY 20 study, which resulted in recommendations for wildlife overpasses at the locations which are currently being considered at Targhee Pass. Future recommendations for the rest of the Island Park HWY 20 travel corridor were also identified and now appear in the I-Plan.
·Y2Y and members of The IP Master Naturalists are running the campaign known as The Island Park Safe Wildlife Passage Initiative.
·BioWest is now running the Targhee Pass Project Environmental Assessment.
·ITD, Idaho Fish and Game, and The Wildlife Conservation Society did a 4 year study on Hwy 20 looking at where wildlife cross. It ended near the time the P. Cramer study began. Renee Seidler was working for The Wildlife Conservation Society then, now she is a contractor working for IDFG and being pd. for by ITD.
·The Wildlife Conservation Society was also a contractor for Heart of the Rockies director Michael Whitfield at the same time, conducting a ‘connectivity pilot’ here, which also involved evaluating HWY 20 for connectivity/wildlife mitigation critical to the same goals Y2Y has for ‘connecting’ Yellowstone to Central Idaho, and from there up to the Yukon. This pilot was being conducted through the federal DOI cooperative the Great Northern Land Conservation Cooperative (GNLCC), where Gary Tabor co-founder of Y2Y, Michael Whitfield-HOTR, and IDFG Gregg Servheen were members of the GNLCC steering committee determining grant allocations and project selection.
·Y2Y and networked non-governmental partners all were signatories and the senders of the 2 scoping report letters we have previously reported about in this newspaper, that went to the ITD board to recommend wildlife mitigations recommended by the P. Cramer study. The Henrys Fork Legacy Project, whose flagship initiative is the Island Park Safe Wildlife Passage effort sent their very own letter. Their larger non-governmental networked partners sent the second, it’s same style recommendations included HWY 20 and also other ITD projects across our entire state.
·Now we discover that The Langdon Group, who is facilitating the Targhee Pass Project, wrote the 2014 MOU between ITD and IDFG that set the entire thing up. A subsequent cooperative agreement has been added to the 2014 MOU-Project #A014(054), A019(913), A019(606 &A019(711) Targhee Pass (JCT 87 to Montana state line, phase 1&2) US 20 Chester-MT Safety Corridor Plan & Ashton Hill Bridge to Dumpground Rd. The agreement administrators are Gregg Servheen of the IDFG and Karen Hiatt of ITD, it authorizes the hire of Renee Seidler.
·All of this federal grant award money coming into our region between 2011 and 2015, and all of it involving multiple same organizations and people, all are predicated on our wildlife resources and focus on HWY 20, what do you conclude about all of it?
·Even the HUD-EPA-DOT grant, that we all remember had a hidden and failed national monument initiative in it, can also be linked to the wildlife and HWY 20 analysis. In the final report submitted to HUD, Appendix E.3 titled ‘Wonders and Wildlife”, Project WW.2 calls for implementation of SWAP through the IDFG, Initiative WW3. calls for safe wildlife corridors and overpasses implemented through state transportation projects, and cites as it’s source the ITD study, and Initiative WW.4 calls for conserving land through land trusts with non-governmental partners taking the lead.
….what in the heck do you think is going on?
All of this federal money has focused on the same thing, and has happened during a dedicated window of time in coordinated regard. It has funded state agencies, and their non-governmental partners with profound and multiple conflicts of interest, to bring unwanted, unwelcome and unsolicited change to Island Park and Fremont County. Force upon us, radical change which proposes to drastically impact our uses, restrict our access, and forever re-design our livability environment...using our wildlife resources as the excuse.
Guest Research IP News
The research information for this article can be found at these links:
MOU/Island Park US 20
Cooperate agreement/subsequent to the MOU Island Park US 20
HUD final report information comes from archived research information
On March 3, 2018 the Targhee Pass Environmental Assessment Team emailed an update on the Targhee Pass project. The full update can be found below.
One section in that newsletter states:
Updated Scoping Report
ITD has updated its Scoping Report for the Targhee Pass EA. The scoping report summarizes how comments are being addressed in the EA process. Updates to the scoping report included an additional paragraph at the top of page 5 regarding issues identification and some stakeholder comments that failed to publish in the original version. The Scoping Report is available to the public on the project website or by clicking here.
This is the added paragraph at the top of page 5.
"The purpose of identifying issues is to determine the relevant issues to be evaluated in the EA. The number of comments identifying an issue does not influence the importance of the issue. Additionally it is not the purpose of scoping under NEPA to conduct a vote or referendum regarding the importance of issues. Comments expressing ideas regarding issues are accepted from anyone and multiple comments from single individuals expressing additional issues are accepted. Comment letters therefore do not constitute a representative sample of any population."
Why was that added? Is it to justify outside groups are eligible to be involved in an issue where they don't live? Or, is it saying that all comments supporting overpasses have no influence? Based on the information on this website, clearly outside groups have been allowed more influence than Island Park citizens.
Interestingly, they also report "some stakeholder comments" failed to be included in the original report. In reviewing this huge document again some interesting questions were brought up in those previously omitted comments.
In Appendix B, page 40, comment #107 is new. For convenience a copy of the comments are below in the pdf or you can go to page 40 here.
Those comments are well worth reading, it is lengthy but addresses in detail some of the areas the NEPA process requires such as socio-economic, cultural aspects, and the omission of private property owners and citizen involvement. The Cramer Safety Solutions Study was also heavily scrutinized, even criticizing the inadequacy of data collection. Many questions were raised about the lack of studies on other factors as well.
Regarding the Safety Solutions study, Comment #24 asks, "Restricted wildlife movement, restricted recreational use, reduction of scenic value, cost, efforts to “convince” an elk to move through a structure, private land, hunter access, restricting access by “skittish” animals, restricted off road vehicle access, tree, vegetation, and shrub removal, poor carcass data collection, and limited bridge access are found to be common “cons” to building these structures, and in the report itself it states, “Overall, solutions for WVC that maintain wildlife connectivity are not always cost effective initially based on WVC crash and carcass data.”
Comment #27 states, "Much of the migration data is 10 plus years old. This data should not be used. Same with “probable collared Elk crossings” and “probable collared moose crossings”. What percentage of the herd was collared and how can this data be used to substantiate migration patterns for either species?
From the same Safety Report Comment #28 states, "Elk are among the most difficult ungulates to accommodate with wildlife crossing structures.”, and are used primarily by only a single or a less than 4 herd."
Comment #34, "The Safety Solutions study recommended further analysis given the inadequate data methodology."
In fact, the Cramer study invalidates any reason to put wildlife overpasses at Targhee Pass. Is that why they were left out, fear that people would read those comments and see the rather direct questioning of their very own study? ITD is justifying overpasses based on this study, a study that negates using overpasses!
Even more fascinating is a new section titled, "NEPA/CEQA PROJECT SCOPING QUESTIONS", found in Appendix C, page 29, Comment 184. A copy of those comments can be found in the pdf below or in the report.
Although the report lists CEQA, it should actually be CEQ for the Council On Environmental Quality. This agency is responsible for overseeing NEPA implementation. The comments in this section are related to CEQ requirements. Questions about wetlands, historic preservation, noise, hazards, sanitation, site suitability, soil condition, economic impacts, alternative site analysis, and public participation are part of CEQ. Again, the comments are long but it brings to light the tremendous amount of information that ITD has failed to address in their quest for overpasses. It isn't a simple matter of sticking these structures in Targhee Pass for the Elk, it also includes all of the impacts they will have on Island Park. These comments address those questions that ITD has not answered or brought forth to the public.
Given this information, ITD should be compelled to answer those questions, such as:
1.6 What anticipated effects would three wildlife overpasses in this area have on existing private property wells and septic systems?
5.1 Has the site been studied for a potential increase in invasive species which have been known to occur in wildlife overpasses?
11.2 What impact will fencing have in the area on private land and for other wildlife? If studies have not been conducted on this, why, and when will studies be conducted?
11.8 11.8 Are the three proposed overpass sites compatible with surrounding areas in terms of:
11.8.1 Land use
11.8.2 Residential type (low/high-rise)
11.8.3 Residential density
11.12 What agency will be responsible for the ongoing maintenance, repair, and replacement of fencing?
14.2 Will any of the three overpasses be affected by wind/snowstorm concerns?
15.7 Will three overpasses affect or be affected by ingress and egress streets?
23.1 Please provide documentation of all meeting minutes and communications with Fremont County Commissioners regarding this proposed action.
23.2 Please provide documentation of all meeting minutes and communications with the Island Park City Council.
23.3 How many meetings were conducted with the Fremont County Commissioners and Island Park City Council regarding three overpasses at Targhee Pass?
23.4 What was the agenda and topic of conversation with the Fremont County Commissioners and Island Park City Council members regarding overpasses and Targhee Pass?
25.1 What efforts were made to conduct outreach to all IP residents for input from the beginning, at the time when ITD was contemplating road construction at Targhee Pass?
25.2 Please provide documentation of the percentage of Island Park residents that were contacted when the project at Targhee Pass was only being considered, and at the initiation of the EA.
The reader is encouraged to read through these comments, they are thought provoking, may provide more insight on subjects that have not been addressed by ITD, exposes their glaring omissions in the NEPA process up to this point, and might give the reader some new issues they have not thought about before.
To date, none of the questions raised in these comments have been answered by ITD. How convenient for them. As usual, don't give adequate time or opportunity for citizens to study the issue and have their questions answered, wait until most have read the report and won't be interested in going through it again to find new comments. How devious is this process? But, now is the time, read the questions raised in these comments and bring them forward to ITD. As citizens you have the right to have these questions answered. Be prepared to bring these questions to ITD at the next meeting, and insist on answers to them.
Making Sense of It All
This blog will help you make sense out of all the information on the website, how it affects IP, previous articles in the IP News, our history, and how efforts continue to put IP into various forms of conservation status.