February 10, 2024
Lisa Applebee P.E. Idaho Division, Federal Highway Administration 3050 Lake Harbor Ln Suite 126 Boise, Idaho 83703 Subject: US Highway 20 – Ashton to SH87 The Island Park Preservation Coalition does not believe that the Idaho Department of Transportation complied with either the spirit or intent of the Planning and Environmental linkages process on the US 20 Ashton to SH 87 highway project. This letter is intended to document the shortcomings and request that you do not approve the PEL product developed by ITD. “Planning and Environmental Linkages, or PEL, is a collaborative and integrated approach to transportation decision-making that considers environmental, community, and economic goals early in the transportation planning process.” The Idaho Department of Transportation’s PEL process for the US 20 Ashton to SH 87 highway project has many shortcomings. The PEL process must consider the following topics according to the Federal Highway Administration: “Visual Agricultural and Forest Resources Air Quality Biological Resources Cultural Resources Geology and Soils Hazards and Hazardous Materials Hydrology and Water Quality Land use and Transportation Planning Noise Social and Economics” Many of these topics have not been seriously considered by the Idaho Department of Transportation. ITD has not included the independent technical experts needed in the alternative screening process in order to honestly consider these topics. The alternatives screening group was made up predominantly of engineers from ITD and Horrocks Engineers. There were only a handful of elected representatives involved in the screening process and only in the second phase. No private citizens or non-government organizations have ever been involved or invited into the screening process. The local NGOs and private citizens would have added a great deal of technical value to the process. ITD would say they held public meetings to get local input from citizens and NGOs. The format for the few public meetings that ITD has offered, have been walk-through information stations. Paper comment forms were provided to the public. Presentations and question and answer sessions were not provided. This is far different from being involved in a constructive meeting and constructive screening process. Non-involvement results in failure to gather critical local knowledge and opinions on alternatives that were considered and what viable alternatives may or may not make it through the screening considerations. Neither ITD nor Horrocks Engineers represented the public’s interest in the screening process and they do not represent the impact population or effected stakeholders. This is very evident when you consider the alternatives that ITD and Horrocks decided to advance. With 20+ engineers in the screening group, the few elected representatives were always out voted and the most expansive and expensive engineering choices advanced. This was totally a biased process. It should also be pointed out that Horrocks Engineers has a profound conflict of interest because they profit from selecting the more complex highway designs. In this case, a four lane, high speed, limited access FREEWAY, in an extremely sensitive environmental area has been advanced in the screening process while viable and preferred alternatives the public has tried to offer, were being rejected. Very significant requirements have been neglected in the process. ITD did not include any substantial analysis or documentation for the critical, required issues (Visual, Agricultural, Forest Resources, Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Hazards, Hazardous Materials, Hydrology, Water Quality, Land use, Noise, Social, and Economics issues) in any of their public meetings or online. ITD said they did a “high level analysis” of these issues but have provided little public documentation to support this claim. US Highway 20 has historical national significance as the “longest main street in America”. The history of US 20, originally wagon tracks that connected the hamlets of Pine Haven, Pond’s Lodge, Macks Inn, Island Park Village, and the original homesteads and Army Post of the Henry’s Lake area, known as ‘settlers islands’ all became what is now known as Island Park and the city’s main street. As the current US 20 travels through Targhee Pass it has become an asphalt highway that was first the trail Chief Joseph and The Nez Perce escaped into Yellowstone on as they fled the advance of Howard’s Army. These are serious issues for local business people and the residents of the larger Island Park community whose financial future and valued historic past are being risked. FHWA states: “To be viable in NEPA, a PEL study must involve interested State, Local, Tribal, and Federal agencies as well as the public, document relevant decisions in a form that is identifiable and available for review during the NEPA scoping process and can be appended to or referenced in the NEPA document, and be accepted by the NEPA lead agencies. ITD has clearly violated the spirit and intent of the PEL process. These violations have clearly compromised the process. Undoubtedly, the flawed process has resulted in not moving the best and publicly supported alternatives forward. This contention is most evident in the almost total dismissal of the passing lanes alternative that was advanced by the Island Park Community. Not only was this alternative not seriously considered, it was supported by prior state analysis that existed, but was hidden from the public and not offered as an initial alternative. The community solution, as it was suggested and then proven as scientifically supported is based almost entirely on the JUB Engineers solution that was funded by ITD in 2019, at a cost of $3.25M. It should be noted that the entire screening process was compromised when ITD Chief Operating Officer, Dan McElhenney stated to the ITD board, that “ideally this should be a four lane highway”. This statement was made in January 2020, months before the US 20 PEL began. This is an obvious pre-decisional statement and in subsequent ITD board meeting notes one can see District 6’s further pre-decisions positioning the PEL and preferred multiple lane outcome, which definitively compromises the entire PEL and NEPA process. The Island Park Community solution provides an acceptable solution to any perceived issues with “travel time and delays, congestion, safety – specifically, with the goal of reducing the number and severity of crashes, and outdated design standards”, for over 20 years. This statement is based on the $ 3.25M JUB Engineers study conducted for ITD in 2019. The community solution (additional passing lanes, rumble strips, tree cut back, stop lights, lower speeds, widening shoulders, wider stripes, improved signage, improved paint highway painted turning lanes, solar lights in wildlife areas, and more message boards warning of hazards) can be implemented at a fraction of the cost ($700,000,000) of a four lane freeway. The community solution is much better from an environmental perspective as well. Forests and rangeland do not have to be destroyed. There is much less risk of contaminating ground water and polluting the Snake River Aquifer. The Fremont County Wetland map identifies much of the 33 miles along US 20 in Island Park as a wetland. There will also be less risk to wildlife when considering the community solution has reduced highway widths, slower speeds, stop lights and fewer ancillary roads. A massive open pit aggregate mine will not be needed in the Island Park Caldera in order to advance a US 20 4 lane freeway design. And yet this elegant solution was not even seriously considered! ITD predicts that traffic volume on US 20 Ashton to SH 87 will increase linearly by about 4% per year in the future. There is no doubt that Yellowstone National Park will implement a reservation system in the near future making the 4% prediction totally erroneous. The NPS is currently trying to determine a future where Yellowstone National Park and it’s own limited infrastructure can best accommodate tourism impacts. The future planned improvements to Yale-Kilgore Road will have a positive impact on overall and local traffic volume on US 20. If speed limits are selected to improve traffic flow and safety, and traffic lights are installed to improve intersection safety, truck traffic will likely be reduced as the trucks desiring the quickest route will likely use I-15. It should be remembered that when I-15 was suggested, a prominent purpose and need cited at the time, was to provide a truck route for eastern Idaho. I-15 should be considered the primary truck route, not US 20 as US 20 is the primary resident connector for the local communities north from Idaho Falls to the Montana state line. It should be noted that there is heavier traffic on US 20 north of Ashton to Montana about 5% of the total hours of an entire year. The other 95% of the time, this segment of US 20 has much lower traffic. The best investment of valuable and finite highway infrastructure dollars should be paramount to both oversight and management agencies and their contractors. A four lane freeway would be a costly (~$700,000,000) and a substantial over-build 95% of the year. The Island Park Preservation Coalition requests that you REJECT the results of the US 20 Ashton to SH -87 PEL process. The process has been flawed from the beginning as pointed out in this letter. To move forward with this flawed PEL process would jeopardize the follow on NEPA process and certainly result in long delays and considerable additional costs and possibly litigation. Ken Watts, Chairman Island Park Preservation Coalition P.O. Box 361 Island Park, ID 83429
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