There are Two Distinctly Different Visions of the Future for Island Park at Odds Here
Jean Bjerke gets a lot of space in this paper every week, I asked Ann to extend to me the same opportunity. She graciously has agreed. My article this week is two-part. One is research I am submitting from a field trip perspective as a guest researcher for the IP News. The second part is strictly my opinion.
Part 1. Field trip.
The last two weeks have been interesting. Not intending a field trip to learn about wildlife overpasses and fencing, our Family drove across the length of Wyoming and Nebraska to take our Boys to play some baseball in Omaha. We drove on 1-80 most of the way and experienced what a major transportation route truly is. Yes, we do get trucks through Island Park, but nothing like that truck traffic…there were hundreds and hundreds of trucks traveling 70+ mph for thousands of miles, split 4 into 2 lane interstate.
If you ever travel the length of Wyoming, you will discover that there is not much but broad expanses of open and panoramic desert land there. There are also hundreds and hundreds of antelope interspersed with a few deer along the roadway. Miles and miles... and miles of fencing is erected and necessary as in much of the ranching West, to prevent domestic cattle and as an added benefit for the wildlife as well, from grazing next to the busy roadway. It is placed well back and beyond the highway easement examples we know here. Sadly, even with the fencing, we witnessed several dead animals along the road, more on that single trip than are recorded in Island Park in one year.
Through Pindale, I was particularly interested. I had never been there before. We had not reached the I-80 junction at that point, and were traveling I-191. The truck traffic was less on this roadway. There were more underpasses than overpasses, and they were engineered where the topography naturally led to a draw where they could be placed under the road, they were hardly noticeable to a traveller. Each one had a significant volume of hazing wildlife fencing to and away from them, intended to ‘encourage’ the animals to cross at that point. The interstate was higher in these places with the fencing below you, if you were not looking for either, a casual or uninterested traveller may not have noticed them at all.
The overpasses were a different story, they were highly visible-you travelled under them-and they were ’the view’ where they stood. Not just one, but 2 systems of fencing, before and after the structures were placed on both sides of the roadway. There were NO HOMES where the overpasses were located. The wildlife fencing height there is intended for smaller mammals, it was not the height required for wildlife fencing for big game species such as elk, moose, and bison.
In Pindale and Sublette County, the research shows that the people and the leadership of that jurisdiction embraced the overpass and underpass builds. They were experiencing hundreds of animal deaths on their roadway. Willing landowners entered into conservation easements to accommodate the need for private lands to supplement the builds, all stakeholders were in fact, a part of the design and development process of this system across that Wyoming county. The Wyoming state legislature also approved the re-allocation of state road and bridge dollars to fund it.
I can find no research that speaks to any effort, led in large part by a small group of part-time residents who partnered with influential NGOs, WY DOT-FHWA, and WYFG to act as ‘a quiet coalition’ in order to work on this project for years ahead of the project reveal. I cannot find any research that speaks to a scenario where The People of Sublette County or their elected leadership and business organizations were not coordinated with or were caught unaware of the effort to do this.
Such is not the case here and there is no comparison between the locations, human livability environment, WVC/wildife numbers along the roadway, environmental realities, or the recreational area aspects between Pinedale and Island Park.
The one thing that is exactly similar between us are the special interests behind this mitigation solution advocacy, and in some cases the exact same personalities are involved.
Pinedale and Wyoming wanted them, and in fact, the research speaks to the fact that they embraced the impact and believed in the need for them, they also embraced the partnerships.
'Want and need', 2 vital components that qualified and justified both the change the structures and the fencing make to the landscape and livability environment of this community, and which justifies both the significant initial, and continual maintenance investment on the part of the State of Wyoming. It was their choice.
Near Jackson massive rebuild is happening too, thats been happening for years. The Old Jackson many of us remember has long ago disappeared. Teton County Wyoming is adopting a wildlife crossing plan as an addendum to their land use planning and these will be constructed over the next several years. WVC are a reality with high numbers of animal mortality there. The People there want this. Yellowstone to Yukon, the Greater Yellowstone Coalition and local land trusts and other smaller NGO advocacies are heavily invested in that effort. So is the NPS, together they are working to engineer and re-design that gateway community to Yellowstone and the farther reaching footprint of that national park.
"Areas which are identified as core and connectivity habitat, are the focus of restrictive management practices on public lands, and are the focus of land acquisition and conservation easements on private lands."
Their words, not mine.
Part 2...The irony of it really hit home for me as I traveled away.
We are not Pinedale and we don't want to be Jackson. We are Idaho, not Wyoming. The heart of the wildlife overpass advocacy for Targhee Pass is based in Bozeman, Montana. The west entrance gateway to Yellowstone is located in West Yellowstone, Montana connecting on to Big Sky. Montana DOT endorses the concept.
We don’t desire to become an extension of those either. If wildlife overpasses and tall fencing are embraced by the citizens and the community of West Yellowstone, Montana, and residents who live in the extended Bozeman and Big Sky area, then I speak to you, you have the same connectivity potential to Yellowstone that we have. The same species of ‘greatest conservation need’ that have been identified by the USFWS and state fish and game agencies inhabit and move through your landscape. So take this project that you wish us to bear the impact and burden of and which you so strongly advocate for, and move it 6 more miles up US 20 and build it there.
Targhee Pass and the greater area of Island Park are beautiful. Those of us who are standing up to the advocacy that seeks to blast and bulldoze away Targhee Pass want you to know there is more to the story than just 134 people who have paid for a 1/2 page ad in this newspaper this week.
Behind this advocacy are organizations and agencies who have hired contract and career persons who analyze roadways for wildlife overpasses and underpasses and provide the foundational science to justify overpasses in multiple western states, and do so for a living. They are associates or part of organizations who network together to work to promote the mitigation solutions massive builds provide, and they have created powerful partnerships with state and federal agencies to get it done. They want to realize a vision they have designed, that they can slap their name on it and further make careers out of and fulfill private agendas.
Some of them are also contractors who have significant side interests that include holding patents for the wildlife crosswalk mats and who have established a contract business that provides the pre-fab crossing structure foundations. They all anxiously await ITDs upcoming decision here, and stand ready and poised to make millions not only here, but also across our state, and on into other western states.
Idaho is their pilot.
I believe that the vast majority of Island Park home, land, and business owners do not have any desire to become a large tourist attraction, we get our fill of that each summer. We have no desire to become an extension of West Yellowstone to accommodate their overflow because they are running out of development room, or to that larger point Yellowstone itself, because it desires to grow. The economy of Island Park, and the domino effect it would have to larger Fremont County should our property valuations decline and effect our tax base or our recreational economy become impacted subsequent to this project becoming reality, have very sobering implications. If we are fenced off and multiple structures are built to accommodate multiple wildlife species corridors and associated required habitats, Island Park as we know it will die. It will take some time, but a future with our children enjoying the Island Park we have now will never be.
The past two weeks I have also attended county commissioner meetings. The IPSWP advocacy was there to speak both times against myself for one, and any effort for our county to be able to vote on a wildlife overpass initiative on the upcoming November ballot. They don't want it…and they fear it. The power of a local voice, illustrated through a ballot initiative, cannot be denied or ignored by either ITD, the IDFG, or the FHWA and the USFWS.
We have stood on such before.
Many IPSWP proponents have a primary residence in another state and say that they will be disenfranchised if this vote is held. Not true, they have a choice, they can declare their residency and vote here if they want to, they just cant be one person who gets to vote in multiple states. The same can be said for opponents of wildlife overpasses that outnumber them 20 to 1. Thousands of them have signed our petition registering their voice through that forum. The IPSWPI poo-pooed that petition, claiming anyone can sign it, but they had no problem soliciting signatures from everywhere and registering comment the same way during the scoping comment periods for this project. They are making a big deal now about how ‘local’ they are and paying for newspaper space to do it.
Trying to have it both ways, I found that entertaining.
At a pivotal point in that meeting they were asked where they all lived in Island Park, and would any of them have to look at fences or an overpass out their front window or have them impact their property or access to the forest?
Not a single person raised their hand.
There are two distinctly different visions of the future for Island Park at odds here involving this issue.
The advocacy that is trying to stop irreversible change from coming to Island Park are filling the stero-typical role of ‘environmentalism’. We don't want wildlife overpass construction to threaten the wetlands in Targhee Pass and Howard Springs and Creek. We are standing against the destruction of a beautiful pass and landscape that was carved through the mountains by The Finger of God. We hold steadfast to the conviction that recognizes we are the fortunate ones, who get to live here and act as stewards of this unique place for our own short periods of mortality, tasked with protecting a future for generations to come.
The IPSWP advocacy, the ‘flagship' initiative of Y2Y into Idaho, who has joined with the GYC and federal and state agency partners have dreamed this whole thing up….and this time it is they who are the ‘threatening developers’.
They are dressing their effort up in a wildlife safety campaign, call it what they will, but unwanted development is what they are championing. What an upside down! These are the groups who usually are activists working from the position we now hold. That is a rich irony indeed.
Jean Bjerke stated in this past Monday commissioner meeting that “Ken Watts, Leanne Yancey, and Ralph Kincheloe do not speak for me”. True statement, I do not, we do not.
There should be a few beautiful places left in the world where development and the future does not devour tradition and a view back to the Rich History that made us. The West is disappearing, and you wont find it in the tourist shops marketing cowboy hats and stuffed bears. There is a need to protect people and tradition, places and a lifestyle, where a quiet and free life can still be found. Wide open views should still exist to pleasure our senses without stark manmade structures obstructing them from our eyes. There should still be a wild place where humans and beautiful natural creatures coexist, where wildlife can move freely and by choice even outside of a cabin built in the trees, and solitude can be found on a pathway that is not designated or restricted.
Island Park is that place.
I believe that I, and the people who have joined together as the IPPC speak for The Voice that has been denied and ignored, The Voice that supports our elected leadership in this effort, and that together we all want to continue to speak up and keep Island Park…Island Park. The IPPC does not meet in private places and we do not work in ‘quiet coalition” partnerships with any state or federal agency or NGO holding a checkbook connected to a federal bank account.
In addition to this letter I wish to speak strongly against a false rumor that has come to my attention. I am told it is being widely circulated in Island Park. Someone has stated falsely that Kim Trotter, US Program Director of Y2Y, has received death threats from Fremont County residents (an inference was also given toward the IPPC in that regard). Supposedly, this threat was reported to our local sheriff, and that Ms. Trotter was advised by local law enforcement to not attend public meetings for her own safety. We were very concerned when we heard this. We contacted the FC Commissioners about it. They were very concerned. So concerned, that they contacted both the Fremont County and Teton County Sheriff’s Departments and asked if this was indeed true? Both Sheriff’s departments reported back to the commissioners that they had not received any such call or report of such a threat to this person, had not spoken to her, nor have they offered her any such advice.
Why would anyone initiate such a potentially damaging and untrue rumor into our community?
Reprinted with permission from the IP News June 28, 2018 issue
Grizzly recovery was the reason the USFS closed nearly 1/2 of the Targhee National Forest to human use in the late 90’s. Massive road closures by ‘tank trapping’ method occurred WITHOUT notification or COORDINATION with the local impacted communities or the elected officials of our immediate region.
In 1999, Helen Chenoweth held a congressional field hearing about it in Rexburg. What the USFS did by massively ‘tank trapping’ (they don't like to use that term anymore) and destructing our roads violated process and protocol, this hearing is fascinating history. A CONGRESSIONAL hearing about this egregious activity was convened in Rexburg, Idaho!!
Below is one testimony, there are many.
The USFS personnel testimonies are very interesting. We encourage you to read it all, history forgotten and not learned from, is bound to be repeated. What the FHWA-ITD-IDFG-USFS-USFWS-NPS and their NGO partners wish to do here now, seeking to establish multiple species wildlife corridors with connectivity back to Yellowstone beginning by inserting wildlife overpasses into a highway upgrade, it can be conjectured invites ‘taking’ the other half. Such will render what remains, i.e. our private lands within and that neighbor forest lands, at risk of restriction-acquisition-loss of value-loss of access-loss of multiple use opportunity. COORDINATION IS THE LAW. BEFORE ANY FEDERAL ACTION IS TAKEN or PROJECT IS APPROVED, full and transparent information and participation IS TO BE SHARED WITH and SHOULD INCLUDE LOCAL JURISDICTIONS. WE ARE TO BE AT ANY and ALL DECISION MAKING TABLES and ARE TO BE INCLUDED IN EVERY STEP OF THE PLANNING and DESIGN PROCESS. A sad precedent was set on the Targhee 2 decades ago. A 30 day comment period DOES NOT QUALIFY MEANINGFUL PUBLIC PARTICIPATION. This was unacceptable then and it remains unacceptable now.
FIELD HEARING ON THE TARGHEE NATIONAL FOREST before the SUBCOMMITTEE ON FOREST AND FOREST HEALTH of the COMMITTEE ON RESOURCES HOUSE OF REPRESENTATIVES ONE HUNDRED SIXTH CONGRESS
FIRST SESSION on THE TARGHEE NATIONAL FOREST ROAD CLOSURES AND THE TARGHEE NATIONAL FOREST TRAVEL PLANS DRAFT ENVIRONMENTAL IMPACT STATEMENT STATEMENT OF ADENA COOK, PUBLIC LANDS DIRECTOR, BLUE RIBBON COALITION THINKING IN THE BOX: FOREST PLANNING AND MANAGEMENT ON THE TARGHEE NATIONAL FOREST INTRODUCTION. ''Thinking out of the box'' is a popular euphemism for creative problem solving. Tough issues can demand unconventional ways of thinking and processes that reach beyond past methods. Nowhere is this approach more needed than in national forest planning and management.
TARGHEE PLANNING BACKGROUND
When Targhee forest planning began eight years ago, there was promise that the new plan process would attempt new solutions. The supervisor at that time, Jim Caswell, engaged one of the foremost experts in the country on forest planning and public involvement, Dr. Bill Shands, to direct the public involvement part of the plan revision. I had followed Dr. Shand's work, and attended his lectures on several previous occasions. He favored complete public involvement in every step of the planning process. He wanted to take forest planning ''out of the box'' and bring it to the people (this was long before the euphemism ''thinking out of the box'' came in vogue). I admired his thesis. He theorized that if publics were involved through each step of the process, that consensus, or at least comprehension, would result.
Under Dr. Shand's direction, the first couple of years went well with the Citizen's Involvement Group (CIG). Everyone learned much about the Targhee, what decisions had to be made, and why. We knew that it would get more difficult as we got closer to actual on the ground allocations, but many felt that the continuity, relationships, and trust built up over the past two years would help the CIG achieve an unprecedented consensus on many issues.
In 1993, events beyond anyone's control broke this fragile consensus building. Jim Caswell was transferred. Bill Shands passed away. The preservationist direction of the Clinton Administration was gathering steam. The Forest Service was being ''reinvented.'' Yet much information, hard data, and public input had been gathered over the past three years. These would form the basis of Draft Standards and Guidelines, and Management Prescriptions. The general direction of the future of the Targhee would take shape. Members of the CIG wondered how the next crucial step would proceed.
THE BOX REPLACES CREATIVE PROBLEM SOLVING AND CONSENSUS
They were dismayed when out came the box that they had hoped Bill Shands had banished forever. But he was dead. The Forest Service had been reinvented, and there was a big label ''Ecosystem Management'' on the box and its management criteria were blatantly preservation oriented. Locally based solutions and citizen involvement were unimportant. Once the premises from which the box is constructed are accepted, as they are within the Forest Service from the top down, then all answers lie within. Polarization replaced developing consensus. The public was back where they started from five years ago, though much wiser!
The BlueRibbon Coalition has always been a strong advocate of cooperation with land managers. They are our partners. We work in many ways to assist them in protecting the resource while promoting balanced recreation use and public access. Our success stories in achieving this are many, and we have a long history of success stories on the Targhee.
One of the key elements of this success is constructive give and take. Another is a real dedication to on-the-ground problem solving. Very little can be achieved by talking at each other with broad brush platitudes like, ''The Targhee has several thousand miles of road open under our new plan. Doesn't that sound like a lot? Isn't that enough?'' And conversely, ''You've closed enough roads already. We don't need any more closures!''
INFLEXIBLE NEW PLAN STIMULATED POLARIZATION
Yet the inflexible standards of the new forest plan stimulated this polarization, and discouraged on-the-ground give and take. Most traditional multiple uses had such standards applied. Motorized recreation and general forest access were especially affected. These inflexible sideboards give very little latitude for on-the-ground solutions. For example, the new forest plan:
• mandated tough road and trail density standards, not only in the Bear Management Units, but throughout the whole forest.
• counted a single track trail where motorized use was allowed as having the same impact on wildlife as a Federal highway.
• imposed a ''closed unless posted open'' fiat on most summer motorized forest access.
UNWILLINGNESS TO WORK TOWARD LOCAL SOLUTION EMERGES
This inflexibility and unwillingness to work for on-the-ground answers manifested itself in other ways as the process moved forward:
• A multiple use alternative developed by local citizens, included in the draft plan and strongly supported by the surrounding communities, was dropped in the final because, we were told, it failed to sufficiently conform to established parameters.
• A travel plan environmental assessment (EA) and decision was issued shortly after the final forest plan was released. This decision designated open roads and trails on the forest, and decided which would be closed to motorized use. The regional office received 1,276 appeals on this decision. These appeals were upheld because the public was not given an opportunity through a site-specific process to comment on individual roads and trails. Targhee officials were directed by the regional office to go through another Travel Plan NEPA process that afforded the public opportunity to comment on site-specific roads and trails.
• It became apparent to citizens and organizations interested in forest access that the new plan was inflexible and therefore unworkable. Together with local elected officials and members of Idaho's congressional delegation, they urged Supervisor Reese to adjust the plan through an amendment. I attempted to persuade him that addressing access would not constitute a whole new plan revision, but he stated that it would. He refused these requests.
• Supervisor Reese issued a closure order closing the entire forest to cross-country motorized use, effectively implementing that portion of the forest plan in advance of the regional-mandated travel plan process. While this action could be considered reasonable in bear management units, it pre-empted the process for the whole forest.
It was explained that this action would enable the public to get used to the idea, and demonstrate how ''closed unless posted open'' would work on the ground. Yet little public information was distributed, and no signs were posted informing the public.
OVER 400 MILES OF ROAD OBLITERATED WITHOUT SITE-SPECIFIC DOCUMENTATION
The cavalier attitude toward public involvement culminated in the obliteration of over 400 miles of road in the bear management units of Fremont County. I realized that additional roads would be closed in this area, and that this closure could proceed in advance of the travel plan process to accommodate the grizzly bear management strategy. Many of the roads in this area were already securely gated.
However. I was appalled at the discovery that these closures would be accomplished by a massive obliteration effort. As BlueRibbon and Citizens for a User Friendly Forest (CUFF) were preparing to file suit over this lapse of NEPA, the bulldozers apparently were urged to go faster. Supervisor Reese stated that this action was necessary because current closures were not effective, and that he was mandated to reduce the road density in two years. We were unable to engage in a productive dialogue that would:
• Examine gates site specifically and determine whether they were effective or not. That all of them were being systematically violated is not true.
• Determine what additional means were needed to make them effective.
• Detemmine whether informal routes were essential (like Schoolhouse Draw, site of our October rally) and could be traded for other routes.
• Resolve and address concerns about winter travel safety.
• Determine the impact on the non-motorized recreationist.
• Determine if obliterations were necessary in the developed portions of Island Park, where the closures would not contribute to grizzly bear security.
Teton County passed an emergency ordinance that temporarily stopped the earth moving equipment from completing the obliteration in that County. About 22 roads remained to be obliterated. Because our suit was pending, and because the season was advancing, the forest service agreed to stop the work for the season. At a Teton County Commissioners' meeting that preceded this decision, Commissioner Brent Robson showed a video demonstrating that several of the roads on the obliteration list had open and unsecured gates. The question was asked, ''How could the forest claim trespass if the gates were not secured?'' In the ensuing discussion about securing roads with minimum impact, Ranger Patty Bates estimated that 25 percent of the current closures are effective. The group agreed that closures should be effected by the minimum means, not maximum. This meeting was not a part of a NEPA process, but it demonstrated that give and take could still occur. This is increasingly rare, however.
Targhee's current management attitude can be characterized by:
• Unwillingness to seek on-the-ground solutions.
• Breakdown in constructive communication.
We do not accept excuses such as, ''We're mandated by the Endangered Species Act. We'll get sued if we don't.'' These scapegoats represent avoidance of problems, not a commitment to solutions. The Targhee is but one example of how ''thinking in the box'' constrains land management problem solving. Committed to top-down mandates that come in a box, other national forest units face similar difficulties. That's why we are here. We need our Members of Congress to help us toward creative solutions, to help us ''think out of the box'' to plan the management of our public lands.
The tank trapping activity of the USFS 1997-98-99 was done for one species, massive closure to achieve road density protocols defined by a biological assessment document. This is an update to that original Biological Assessment for Idaho forest plan assessments that include the grizzly bear, signed in 2017. The Targhee Caribou management plan revision must be next, look at the map, wherever that bear walks management plans will be affected.
The Idaho Transportation Department (ITD) has the road data statistics on their website, but are somewhat different than how Ms. Bjerke states them in the IP News, June 21 edition. Site 32 stats come from 14 miles north of Ashton as the marker point. In July, 2016 the average daily traffic was 8,224 as compared to 4,533 in 1990. For the year 2015 the annual 24 hour daily average was 4,067 at Site 32. The report is also broken down into hourly counts on weekdays in 2016. These are the most current stats on the ITD website. Where Ms. Bjerke gets her data on 1.5 million yearly travelers through IP is unclear as it certainly couldn't be found on the ITD website. It is highly doubtful Ms. Bjerke's projection of 5 million future travelers per year through Island Park is correct. What traveler will choose to come to this area with that much traffic or without Idaho or the Federal Highway Administration intervening?
If people speed over the limit now, what will happen when they are fenced in with a clear animal free path by fencing? What an invitation to put the pedal to the floor, why not go faster, no harm done because the animals won't be there. Building an overpass for the purpose of a migration that occurs only two times a year during low traffic volumes does not make sense. The overpass issue, once again, is about the Yellowstone to Yukon agenda for corridor designation and connectivity to Yellowstone. It is needed for linkage between protected areas.
While the Teton Regional Land Trust (TRLT) espouses its benevolence for "charitable and educational intentions exclusively", what they do not tell you is how land trusts are often land brokers for the government with easements often sold to the government for a profit. TRLT holds 18,324 acres of Idaho land, that is a little over 25 square miles. Of those acres, 99.13% are closed to access, all of it coming from private land. Because this land is typically banned from development it is an economic loss to the county. This land, considered protected, also provides the necessary linkages to other protected land such as Yellowstone. TRLT partners with the federal government, the international organization Nature Conservancy, and conservation initiatives Heart of the Rockies and Yellowstone to Yukon, both whose objectives are connectivity. A land trust also has the potential to strategically acquire other land or development rights for regional land use planning, which TRLT is, regional. The most recent financial information on their website is from 2014 at which time their assets exceeded three million dollars.
Lastly, we have the Don Kostelee article outlining the facts on speed and accidents, and J.L. Keefer with her historical narrative and future projections on traffic patterns. While other states and countries have chosen to use overpasses as their solution, Idaho does not have to be a follower, but rather a leader in creating ways to protect human lives and wildlife that do not involve land destruction, prevent the advancement of objectives by groups that only want overpasses to justify protection status which leads to regulating private land in the vicinity, and protect private property rights.
At some point in time we have all told our children, "If all your friends jumped off a bridge then would you do it too?" Just because groups, other states, and other countries have jumped on some bandwagon does not mean Idaho or Island Park has to do the same.
On May 24, 2018, Dist 35 Rep. Karey Hanks, and the Idaho Transportation Department (ITD), hosted a legislative meeting at the ITD District 6 office in Rigby regarding the Targhee Pass Project. Below is a copy of the meeting notes.
Also, below is a copy of the letter sent by ITD to the Fremont County Commissioners and Big Horn Hills Estate regarding a speed reduction extension request that has been denied twice.
In the May 24, 2018 edition of the West Yellowstone Star, there was a large article on the Targhee Pass project. After describing all of the alternatives, the article proceeded to explain that Montana citizens "...would be welcome to submit comments..." on the project, as well as "...accepting feedback, from anyone, anywhere. including West Yellowstone and surrounding areas." Andrea Gumm also stated more "...coordination with the town (West Yellowstone) would be forthcoming". This is supposedly occurring upon the completion of the impact analysis, also know as the Environmental Assessment. The article could no longer be found on the website.
How can citizens outside of Idaho be legally involved in a project if they don't live in Idaho? How desperate is the Idaho Transportation Department? What gives them the authority to go into other states for recruitment of citizens for comments on a project that belongs only to the state of Idaho?
Lee Gagner is the Idaho Transportation Board Member for District 6. Contact him here and let him know that only Idahoans are authorized to give comments on the Targhee Pass.
The Background Of Collaboration
This article provides more precise information about the previous article, Was There Collaboration Prior To The EA, the collaboration between ITD and IDFG with some organizations, the lack of federal coordination with local elected representatives, and lack of involvement by the impact population prior to the Environmental Assessment (EA)...and exactly when did the EA begin?
ITD announced the Targhee Pass Project (TPP) at the end of November 2016, holding the first of 3 informational meetings beginning in December of 2016.
The foundational studies that support the alternative solutions being offered began in 2011. The ITD EcoLogical lead adopter and incentives FHWA grant began in 2013. The Cramer report, Safety Solutions for Wildlife Vehicle Collisions on Idaho’s US 20 and SH 87, was published in 2016, and the MOU between ITD and IDFG was signed in 2015.
BioWest became involved in 2013 with the EcoLogical grant award and developed the IPlan. BioWest was also involved in the 2016 Cramer recommendations report. BioWest is now running the TPP EA.
Langdon's involvement began in 2014, facilitating workshops between IDFG and ITD that produced their 2015 MOU to implement EcoLogical. Langdon wrote the MOU and is now facilitating the TPP.
Renee Seidler, former Wildlife Conservation Society (WCS) researcher, is now a contract employee with IDFG in the position of transportation specialist for Hwy 20. Her salary is paid by ITD, the monies first being passed from the federal government to the Wildlife Management Institute, to ITD, and then to IDFG. Part of her role is to serve as a conduit between the two state agencies and her employment was an addendum to the joint ITD/IDFG MOU.
The WCS has been involved in multiple studies in our region. Ms. Seidler has successfully worked to bring wildlife overpasses for Pronghorn to Wyoming and she has conducted wolverine research in Montana and Idaho. Her name is on the maps in the c4llc letter attached in the previous article. In her role as the transportation specialist for the TPP, Ms. Seidler is the person who prepared the National Fish & Wildlife Foundation (NFWF) grant application which was not submitted. That application was seeking funding for a wildlife overpass and associated fencing. NFWF previously gave funding to the Wyoming overpass project she was involved in.
Important Background to understand WHO submitted the following letters:
The Center for Large Landscape Conservation (C4LLC) and Yellowstone 2 Yukon, are both members of Montanans for Safe Wildlife Passage and jointly submitted the letter titled c4llc attached in the previous article to ITD in support of the safety solutions recommendations while the draft ITIP planning was being developed for the HWY 20 corridor statewide.
Quote from the c4llc letter:
“We are an informal coalition of organizations interested in improving passage for wildlife and aquatic species in Idaho. Our organizations cooperatively advocate for innovative solutions to improve and/or maintain habitat connectivity across roads and provide safe passage for people, fish, and wildlife through research, mapping, monitoring, policy work, and on-the-ground projects.”
While statewide mitigations at locations are mentioned, the c4llc letter focuses on IP and Project #14504. Multiple comments are specific in that letter and endorse the Cramer recommendations for the Island Park section. While the letter is dated July 2016, the Cramer report was not even published until the following October.
Quote from the c4llc letter:
“Project 14054. Several of our organizations were invited to a meeting with ITD’s District 6 to review a draft of Dr. Patricia C. Cramer’s forthcoming report, “Idaho Wildlife Connectivity and Safety Solutions on US 20 and SH 87,” which identifies the stretch of US-20 from mileposts 402 to 406 as one of the largest hotspots on US-20 with regards to wildlife-vehicle collisions per mile per year. This four-mile stretch of US-20 is an area of known ecological importance for grizzlies and wolverines..”.
The c4llc letter also encourages ITD to use the Great Northern Large Conservation Cooperative (GNLCC) data atlas. Gregg Servheen, IDFG, Gary Tabor, co-founder of Y2Y and the Executive director of C4LCC, and Michael Whitfield from Heart of the Rockies and the founder of Teton Regional Land Trust, all sat on the GNLCC steering committee at the time of this letter.
Tracing information on the Henrys Fork Legacy Project (HFLP) attached letter in the previous article, the source website link goes to Future West. The HFLP site shows no other activity besides the safe wildlife passage campaign in Island Park. It lists as partners, the BLM, Future West, Greater Yellowstone Coalition, the Henry’s Fork Foundation, IDFG, ID Parks and Recreation, Teton Regional Land Trust, The Nature Conservancy, the USFS, Y2Y and the WCS. The HFLP is also associated with some members of the Idaho MasterNaturalists who helped launch the ‘flagship’ safe wildlife passage initiative at Harriman State Park over the July 4th weekend, 2016. The first announcement of Y2Y’s interest in Hwy 20 in Island Park can be traced to January, 2016. The campaign chairperson for this initiative is Kim Trotter, US Director of Y2Y.
Both letters are from groups that partner with each other, Yellowstone to Yukon (Y2Y), the Henry's Fork Legacy Project (HFLP) and Center For Large Landscape Conservation(CLLC) in the pro-advocacy for wildlife overpass mitigation solutions. ITD collaborated with these groups prior to when the EA was started in October, 2016, after the ITD Environmental Evaluation determined an EA need to be completed (End of Appendix A) .
While researching how many letters were submitted during ITIP for comments on the Hwy20 Project #14504 for Targhee Pass, we were able to locate this September, 2016 ITD document. It states, "Public Involvement Coordinator Adam Rush summarized the public involvement process." "Forty-one comments from District 6 supported wildlife mitigation measures on US-20." The only groups and individuals, at that time, who were aware of the Targhee Pass project, were those identified in the two letters and those who were associated with those groups, who were given the opportunity to provide their input before any Island Park resident, and before the EA began.
A screenshot of the Acknowledgments from the Cramer report, dated October 27, 2016, illustrates the involvement of persons referenced in this records requested information explanation summary of the letters in the previous article.
Was There Collaboration Prior To The EA?
A records request to the Idaho Transportation Department (ITD) revealed that two letters from two different organizations were sent to ITD in support of wildlife overpasses at Targhee Pass. Both letters are from groups that partner with Yellowstone to Yukon (Y2Y), the Henry's Fork Legacy Project (HFLP) and Center For Large Landscape Conservation(CLLC). ITD collaborated with these groups in July, 2016 by inviting them to review a draft of Dr. Patricia C. Cramer’s forthcoming report, Idaho Wildlife Connectivity and Safety Solutions on US 20 and SH 87. There were no announcements or invitations to the public, or Fremont County officials, to participate in these meetings. Given these groups are invested in wildlife overpasses, it gives the impression that ITD was predetermining the plan for Targhee Pass. The Cramer report was not released until October, 2016. None of this was brought to Island Park residents or Fremont County officials until December, 2016
The essence of these two letters is that ITD was actively collaborating with select groups with a specific goal for wildlife overpasses. During an Environmental Assessment(EA) all information has to be considered equally, but this information appears to lend itself to ITD collecting only information and data to support a wildlife overpass. These comments were also submitted prior to the open comment period for the public. Names and dates of when comments were submitted have been requested but as of yet have not been provided. However, this September, 2016 ITD document states, ""Public Involvement Coordinator Adam Rush summarized the public involvement process." "Forty-one comments from District 6 supported wildlife mitigation measures on US-20." ITD allowed these comments to be submitted prior to any public involvement, and prior to the EA.
Y2Y, CLLC, and the Island Park Safe Wildlife Passage group created by Y2Y, were conducting public campaigns supporting wildlife overpasses prior to ITD announcing the Targhee Pass project to the public. The following article, IDFG Records Request, also seems to confirm IDFG's intent of garnering support from groups who support overpasses.
IDFG Records Request
These are records from Idaho Fish & Game (IDFG). Each email is separated by a **** line and the beginning date of the email is in bold. There is some repetition because of chain emails. The essence of these emails is that from the summer of 2017, IDFG was actively pursuing funding for one wildlife overpass at Targhee Pass, without any regard that an Environmental Assessment was being conducted, and that no decision had been made on an alternative. Other organizations were recruited for support. The Idaho Department of Transportation (ITD) was aware of this and at the very last minute asked IDFG to not submit an application for a grant to fund the overpass.
During an EA process there cannot be any "pre-decisional" activity. The attempt for funding one overpass was a pre-decisional activity by IDFG and was even acknowledged in one of the emails as such. It appears the IDFG is the driving force behind overpasses. IDFG is also discussing the possibility of adding other species for other projects while ITD is talking about a pilot project to move ahead with an overpass. Both agencies were aware they were on precarious ground with their activity for an overpass.
These are the attached documents from the emails
Idaho Fish & Game (IDFG) entered into an agreement with the Federal Highway Administration to implement their Ecological approach to transportation projects. The essence of this approach is addressing natural resource identification, avoidance, minimization and mitigation into transportation projects on a regional scale. Gregg Servheen was instrumental in this 2013 agreement along with ITD being assigned the "lead adopter". Here is the 2015-2016 report.
ITD Records Request Information
This document from USFWS came with an Idaho Transportation Department (ITD) records request on threatened and endangered species specific to Hwy 20 Targhee Pass area. There was no critical habitat identified.
Working With Y2Y
The following is an email obtained from ITD. MFWP is the Montana Fish & Wildlife Program, and MDT is the Montana Department of Transportation. There is more importance working with Yellowstone 2 Yukon, Idaho Master Naturalists, other state agencies, and garnering money to take land than with residents of Island Park, or even giving consideration that all of this discussion is pre-decisional which violates NEPA law.
Re: Today's meeting
To: Renee Seidler
Great, looking forward to discussion.
See you at 2pm.
Sent: Tuesday, August 8, 2017 9:53:17 AM
To: Karen Hiatt
Subject: Today's meeting
I look forward to our meeting at 2 pm today. I have a few items that I would like to touch on with you; some of them we can keep brief in respect of our busy schedules!
Debrief on the Commission meeting
Idaho Department of Fish and Game
IDFG Moves Ahead To Submit NFWF Grant
ITD made the final decision on the grant not being submitted.
From: Seidler, Renee 8/29/2017 12:01 PM
Subject: Specifics on budget info for proposa
To: Eric Verner, Tim Cramer, Karen Hiatt
CC: Smith, David
Hi Eric, Tim and Karen,
David Smith (Grants/Contracts Specialist, IDFG) will be submitting our grant proposal to NFWF. He has created an account on the EasyGrants submission site and can see additional details that we need to provide. The budget items descriptions will need to come from you. I assume the NFWF monies would be used to pay a contractor…? Below are the needs. Note there is more detail needed for the match info as well (below the budget list).
Matching Contributions Page: It appears I need more information than the dollar amount.
Idaho Department of Fish and Game
From: Karen Hiatt
Sent: Tuesday, August 29, 2017 8:04 PM
To: Eric Verner; Tim Cramer; Seidler,Renee
Subject: RE: Specifics on budget info for proposal
Renee, We need to discuss more before committing to this or agreeing with the project being in kind for the grant.
Maybe we can talk tomorrow.
From: Karen Hiatt 9/1/2017 2:37 PM
RE: Updates to NFWF ppl
To: Seidler, Renee
CC: Gregg Servheen; Eric Verner; Tim Cramer; Jason Minzghor
Renee, I have reviewed the NFWF grant proposal and do not feel comfortable with ITD supporting the application for this grant with the Targhee Pass project where it is currently in the NEPA process.
I apologize for this short notice and suggest that we set up a time that Jason Minzghor, Gregg Servheen, you and I can sit down and discuss concerns and strategies moving forward. Jason Minzghor is out of the office next week, so it would need to be the second week of September for a meeting.
Please let me know some dates and times that work and we will go from there.
Sent: Thursday, August 31, 2017 3:51 PM
To: Karen Hiatt
Cc: Servheen,Gregg; Eric Verner; Tim Cramer
Subject: Updates to NFWF ppl
Gregg and I have made some changes in the NFWF proposal language to make it clear that this application is from a pre-decisional point in the project. I have highlighted such language using red font in the Description, Abstract and Narrative sections to make it easier for you to see. Please give this a read and let me know if it addresses your concerns sufficiently. If need be, don’t hesitate to call. The final proposal is due to NFWF by the end of this Tuesday.
In addition, we also need these items from ITD in order to complete the application on EasyGrants:
Idaho Department of Fish and Game
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.