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.