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.