Further research on the Targhee Pass Environmental Assessment (EA) report has revealed a very interesting piece of information.
In Section B, comments from 29-55, a total of 27, are all the same, copies of each other. It seems this was generated at the request of Kim Trotter with Yellowstone 2 Yukon (Y2Y), even requesting a copy of submissions be sent to her. There is no date when this was posted, however it was prior to January 30 as she requested comments be submitted to the Idaho Transportation Department (ITD) prior to that date. What is she tracking? Here is the link to the Y2Y website with the request. The sample comment listed on the Y2Y website are the same as those 27 comments in the EA scoping report. In case Y2Y decides to remove the web page, here is copy of it that confirms those comments came from Y2Y.
This is why ITD only considers them as 1 comment, it came from one source, in this case Y2Y. There were occasional variations of the lead sentence, however ITD did count comments that contained this duplicated form terminology as ‘unique’ and proponents are now using those added comment totals toward their positive comment tallies.
It is unfortunate Y2Y incorporated their biased work into a comment form for ITD. Idahoans should have all information regarding overpasses in order for them to make an informed decision.
Re-published with permission from the IP News
In studying the scoping report, I have found in each comment period a lengthy guidance/suggestion comment submitted jointly by The Yellowstone to Yukon Initiative and the Greater Yellowstone Coalition. At this time, I will not address the majority content, it is very comprehensive.
I would like, however, to address a single sentence found in the first comment they submitted.
“A separate letter was submitted regarding both Targhee Pass and other statewide ITIP projects by GYC, Y2Y, and other partners throughout the state and region, which also requested funding to implement wildlife passage mitigations.”
Citation #11 reads:
Weskamp, David, (The Nature Conservancy), Laatsch, Jamie, (Henry’s Fork Foundation), Rinaldi, Kathy, (Greater Yellowstone Coalition), Trotter, Kim, (Yellowstone to Yukon Conservation Initiative), VanFleet, Mary and Parmer (various affiliations), Seidler, Renee, (Wildlife Conservation Society), and Reynolds Ph.D., Timothy (wildlife biologist). Letter to Idaho Transportation Department, Attn. Adam Rush, Comments on Idaho Transportation Department 2017-2021 Idaho Transportation Investment Program. 29 July, 2016.
Please note the date on that letter: 7-29-16
This is 6 months before ITD ever came to Island Park to talk about a project on US 20, and it would not be until the end of July 2017 that ITD would tell Fremont County and IP that wildlife overpasses were included in the alternatives. The advocates promoting wildlife overpass alternatives at Targhee Pass are represented in citation #11. From that July 2016 date, you can conclude that these ‘special interests’ had an entire year to seek other agency and non-governmental organizations support for the overpasses. Since they had partnered with ITD in HWY 20 analysis, they also were aware of the ITIP planning effort and potential HWY 20 projects.
They all knew.
They were all collaborating far in advance.
The community of Island Park and Fremont County did not.
We have not been involved, informed or coordinated with in this process.
Island Park and Fremont County should request and be given a copy of that letter.
This midyear, 2017 Center for Large Landscape Conservation (CLLC) newsletter exposes the truth about the intent of conservation initiatives to use transportation projects for overpasses for their connectivity goals.
Acknowledging the fact that the International Union for Conservation of Nature (IUCN) is behind the global effort to "create a new protected area designation for wildlife corridors around the world. ", the CLLC is more than willing to comply. The new scam is now called, "conservation area designation – Areas of Connectivity Conservation (ACC) – that will
serve to link protected areas...", coming straight out of the IUCN.
CLLC Senior Conservationist, Rob Ament, will participate in this agenda by co-chairing the Transport Working Group
(TWG) "to develop global policy that addresses transportation infrastructure and development with regard to roads and rails within the ACCs." This effort will develop a coalition of individuals and NGOs by building resources to help them "...develop expertise in mitigating roads and rails for wildlife and connectivity." This means they are building their army, with the intent to force us into surrendering to their notion of conservation, using Tribes as part of their efforts.
The CLLC uses their "connectivity policy" to transform "local landscape protection in places identified by science
as critical linkage areas." Their influence over our government has also "...been driving policy creation and helping craft new legislative language at the federal, regional and state levels, as well as participate in a limited number of local, on-the-ground efforts. This includes activities such as commenting on and shaping federal land management plans- which ...included...National Forests. We are also focusing on state wildlife plans and state-based wildlife corridor legislation, county plans...", and "...influence federal administrative policies, state-based initiatives and provide wildlife corridor information for legislation across the country."
They openly admit to manipulating our government for their objectives.
Another CLLC project is advocating "for reducing the impacts that roads have on wildlife by working to secure
wildlife crossing structures...", specifically focusing on Hwy 20 at Targhee Pass. If they have been focusing on Targhee Pass, where has their name been disclosed? Does this mean all of their work has been in secret? Are they laundering their intentions behind other groups such as Yellowstone 2 Yukon, Henry's Fork Legacy Project, and perhaps even the Master Naturalists? Who are the front groups for the CLLC?
Bottom line, this newsletter openly exposes everything that has been published about these groups. The have full intention to use transportation projects for their corridor and connectivity objectives. If they are not stopped now, they will only advance those objectives until Island Park is taken over by them, placed into some form of conservation per their desire, and eventually controlling how Island Park is used. Do Not let that happen. Sign the petition and join others in stopping all efforts to put wildlife overpasses in Island Park and ending their conservation objectives.
Re-published with permission from the IP News
This is the Highway 20, Targhee Pass Project Scoping Report, first joint comment submission noting Citation #12 by Yellowstone to Yukon and The Greater Yellowstone Coalition.
For a researcher, rarely do you find a definitive document that is full of multiple validations. Usually it takes months of dogged discovery of bits and pieces of information that you find in multiple sources, and it requires the researcher to pull it all together in one place.
The Center for Large Landscape Conservation did that for us in the 2017 Newsletter and past articles Ken Watts has written for this paper have broke down that document.
Further validation of the Center for Large Landscape Conservation’s role in the Targhee Pass Project can be found in the scoping report.
Last week, I reported about citation #11, found in the first joint comment submitted by The Yellowstone to Yukon Initiative and the Greater Yellowstone Coalition. This week I will follow with citation #12 of the same comment submission.
The subject of both citations are about two letters, submitted to ITD concerning future funding and projects coming available.
These letters speak to intimate knowledge about the upcoming project at Targhee Pass in the first place, and how wildlife passages were introduced into what was originally a scheduled highway upgrade on a segment whose life-cycle requires it.
"A separate letter was submitted regarding both Targhee Pass and other statewide ITIP projects by GYC, Y2Y, and other partners throughout the state and region, which also requested funding to implement wildlife passage mitigation.”
Citation #12 credits:
Callahan, Renee (Center for Large Landscape Conservation), Domenech, Elizabeth (Yellowstone to Yukon Conservation Initiative), McClure, Meredith, (Center for Large Landscape Conservation), Paul, Kylie (Defenders of Wildlife), Robinson, Lacy (Yellowstone to Yukon Initiative), Trotter, Kim (Yellowstone to Yukon Initiative). Letter to Idaho Transportation Department, Attn: Adam Rush, Comments on Idaho Transportation Department 2017-2021 Idaho.
When ITD credited this community for the requests that they had received asking for wildlife overpasses to be introduced into this project, they were in fact misleading this community. Those requests did not come from us, they came from the largest and most influential conservation/environmentalist NGOs operating in our 5-western state region.
IP Guest Research
Re-published with permission from the IP News
Island Park and Fremont County,
I have spent the last week doing a forensic analysis of the ITD Targhee Pass Project scoping report public comments. This forensic attempts to determine true/unique submissions and gauge impact population support or opposition to wildlife overpass alternatives.
The document is 217 pages, claims 496 total comments. At least 243 were a form letter or ‘canned pre-prepared’ comments. ITD has expressed that such comments would only count as 1, therefore, in three comment periods those comments should only count as 3. I have not considered the non-governmental organizations or agency comments in this analysis.
It is very critical to know that NO COMMENTS are DATED, therefore it cannot be determined if the comments were provided during the legal comment periods. It is also critical to know that the scoping document did not reveal any names or addresses. Public agencies are required to inform people providing comments that their names and address may be released to the public, they should be, it is the only verifiable control in the process.
Island Park and Fremont County also need to know that ITD’s conservation partners on this project were given a project number to submit comments to at least 6 months before they ever came to Island Park to talk about the HWY 20 Targhee Pass Project. The Island Park Safe Wildlife Passage initiative has been running an active campaign since at least July 2016, and those same wildlife advocacy partners came with ITD to that first December blizzard ‘workshop'. At that sparsely attended event, wildlife overpasses were not offered as alternatives being considered.
During the first comment period, which the report verifies lasted 6 months, December 15, 2016 to July 27, 2017, ITD had not yet publicly revealed that wildlife overpasses were being considered in the alternatives. The public was also instructed that the comment period ended January 30, 2017. Some people had guessed about the wildlife overpasses. Many asked repeatedly for this to be confirmed or denied, and were told that we had to wait until an alternatives ‘workshop’ could be held. that would not happen until the end of July 2017.
Positives during this comment period should be suspect, the public did not know. How can the public trust that the positive 61 comments received during this time are valid, or know if the comments come from local , in-state, or out of state residents. The public was informed of a 45 day comment window, the study team accepted comment for at least 6 months after that. This comment segment is improper on many levels.
The last two comment periods, 60 days, there are 18 more positives than negatives.
・Allowing for all of the serious failures of proper process not being followed during this scoping period and resulting report, and lack of full and transparent disclosure of information to the public;
・there have been years of failure to coordinate with, and involve and inform Island Park and Fremont County in the studies leading up to overpass recommendations;
・Allowing that the wildlife overpass advocates that are involved with this project now, have had intimate collaboration with those years of study leading up to these alternatives:
・and that this scoping period has generated hundreds of form submissions that are not dated;
・Discovering that the Island Park Safe Wildlife Passage Campaign had at least 6 months to front-load comments, and an additional 6 months to do so after the public was told the comment period had ended:
・and knowing that they are working as partners with ITD in TP project development
・knowing the public was not informed about the overpass alternatives until the final 2 /30-day comment periods;
・and finally that within the comments in this report residency, names and dates of submission cannot be verified;
*an 18 comment advantage does not illustrate over-whelming local, county and true impact population and stakeholder support for wildlife overpasses.
While researching information about the current Hwy 20 project, it was discovered that this issue is not just about wildlife overpasses. It is imperative that Idahoans and Island Park understand the full picture of how many are involved in placing Idaho land into conservation status.
The Takeover of Idaho Land
There has been, and what is now a very aggressive agenda, to take and control Idaho land. Idahoans may not realize the magnitude of individuals and organizations involved so this is an overview to provide an understanding of the problem, and its depth. These organizations and individuals work in harmony with each other and some individuals traverse between groups providing direction on conservation issues. Currently, unprotected land between protected areas is highly targeted for conservation, making Island Park a prime area for conservation. This has been a highly organized effort.
Western Governor's Association (WGA)
The WGA created Resolution 07-01 in 2007, Protecting Wildlife Migration Corridors and Crucial Wildlife Habitat in the West, "to strengthen the protection of wildlife migration corridors and crucial wildlife habitat in the west.". The Crucial Habitat Assessment Tool (CHAT) was created using GIS tools, then transferred to the Western Association of Fish & Wildlife Agencies (WAFWA). Here is the result of their work, the Chat map. Island Park is identified as a linkage for connectivity to Yellowstone National Park.
Goal: Data collection, creation of corridors, and conservation.
Western Fish & Wildlife Agencies (WAFWA)
Association of Fish & Wildlife Agencies (AFWA)
WAFWA represents "Western Fish & Wildlife Agencies", including Canada. WAFWA is an "affiliate" of the Association of Fish & Wildlife Agencies (AFWA), however, IDFG is listed as a AFWA member with 13 employees on various committees. IDFG Director, Virgil Moore, was named AFWA President this year. AFWA, based in Washington D.C., "represents state agencies" on capital hill. AFWA members include other countries, federal agencies, and NGOs (NAS, TNC, SCI).
Goal: Conservation of species, enacting federal legislation to enforce conservation.
Blue Ribbon Panel (BRP)
The BRP, created in 2014 by Bass Pro shop founder John Morris and former Wyoming governor Dave Freudenthal, "represents the outdoor recreation retail and manufacturing sector, the energy and automotive industries, private landowners, educational institutions, conservation organizations, sportsmen's groups, and state fish and wildlife agencies." The BRP includes 26 business and conservation leaders, and is a conglomerate of lobbyists succeeding in in introducing legislation, H.R. 5650, Recovering America's Wildlife Act of 2016 which requests 1.3 billion dollars for conservation. One goal is creating policy options to fund "conservation of the full array of fish and wildlife species" via state SWAP plans and restructuring state fish and wildlife agencies. (BRP was renamed "Alliance for America’s Fish and Wildlife"-AAFW).
Goal: Raise funds through corporations to support conservation efforts in states and through federal legislation, possibly influence how fish & wildlife agencies are structured, rather than keeping it as a state decision.
Landscape Conservation Cooperatives (LCC)
Created by the Department of Interior and administered by USFWS, these are partnerships between NGOs, federal and state government agencies, universities, and conservation initiatives to collect data on species, habitat, and land which will then be evaluated for conservation through creation of corridors for connectivity, and other measures.
Goal: Identifying species and habitat for corridors which can be used to place large tracts of land into conservation for connectivity to other protected areas, convincing private land owners to place their land into conservation easements, buying land through NGOs and the federal government, erasing jurisdictional boundaries between counties, states, and countries, and creating a regional environmental governance.
Lincoln Institute of Land Policy (LILP)
The LILP integrates theory and practice for public policy decisions on land use. They were responsible for the idea to bring all conservationists together in one group, "a collective voice for advancing the theory and practice of large landscape conservation", called the Network for Large Landscape Conservation, then rebranded as the Network for Landscape Conservation. They also brought in LCCs, USFS, USGS, BLM and other federal agencies to enhance funding through grants. The LILP believes in regionalism, that jurisdictional boundaries, and your representation through elected officials, are irrelevant. LILP focuses on building a large landscape community of conservation practice. Property and Environment Research Center (PERC) is another organization that tries to influence the use of private property and whom "policy makers" listen to, rather than you.
Goal: Increase efforts to put all land into conservation for protection and connectivity, research land policy programs for public officials and others about the use of land, land regulation, and property rights, having a "more active role in the conversations that shape public policy decisions.", which also involves land trusts.
Network for Landscape Conservation (NLC)
The NLC includes individuals working across geographies, regardless of political boundaries, to conserve connected, ecological systems by partnering with multiple organizations and the federal government.
Goal: Conserving land for connectivity.
Center for Natural Resources and Environmental Policy (CNREP)
CNREP is "known for their work in public lands policy, water law and policy, land-use planning, and cross-boundary resource management.", including large landscape conservation strategic frameworks for policy and action.
Goal: Influence public policy on land issues.
Conservation Science Partners (CSP)
Research scientists in applied conservation science, collecting and developing new data for conservation practitioners, all to support conservation goals. Their partners include the federal government and several other sources cited here.
Goal: Producing science that supports all forms of conservation and organization objectives.
Conservation Biology Institute (CBI)
CBI conducts conservation research and develops conservation tools, such as Data Basin, for collecting data that assists conservation agendas, and regional planning assessments to support conservation projects globally. Data collection includes protected areas, conservation easements, and high conservation value areas. Partners include foundations, the federal government, corporations, and universities. The DOI funded CBI to "assist in the strategic development and expansion of scientific information, analysis and support tools to benefit the LCC network and facilitate landscape conservation design." This tool is interoperable between LCCs. Core Data Basin information is free and also serves the HORI which is a land trust partnership for placement of private land into conservation.
Goal: Provide a data center where all conservation data can be stored and accessible to conservation groups and individuals for promotion of conservation.
HD, HOR, Y2Y, GYC, COC, FW, TNC, WS, HFLP, WCS, DOW, NWF
All of these "initiatives" and NGOs have common goals, putting as much private land as possible into conservation easements, buying private land to retain or sell to the government as a conservation easement, declare areas needing protection for species or habitats, identify corridors between protected land for eventual linkage and connectivity, engage as many private land owners as possible to use conservation practices on their land, indoctrinate the young on believing their conservation is the only answer, creating conservation by design on land, expand boundaries of already existing protected land such as national parks, and engage county commissioners to integrate restrictive land use regulations into comprehensive plans. There are multiple overlaps of individuals between these groups with some players being prominent leaders such as Gary Tabor, Rob Ament, Michael Whitfield, Joel Berger, and Matthew McKinney.
Goal: Put all land into some form of conservation status with restrictive regulations on how land is used, expand protected land boundaries so wildlife has room to roam, procure as much land as possible.
USFWS, USFS, BLM, NPS, NRCS, USDA
The federal government partners with initiatives, organizations, and NGOs to accomplish conservation goals and regionalism. Each agency has a variety of programs for conservation. It is your tax dollar being used to fund these conservation groups. Eventually, all recreation and how you recreate will be "managed" for conservation and protection, as H.R. 3400, Sec. 305 describes.
Goal: Use taxpayer dollars to assist groups to achieve their goals of conservation across county, state, and country jurisdictional boundaries while failing to represent Americans as public servants through elected officials, or engage them with transparency.
Western Transportation Institute (WTI)
WTI conducts research on roads to assist with identifying core habitats, dispersal corridors, restoring connectivity, and highway mitigation methods, under the guise of road ecology.
Goal: Determine how your roads should be built and managed simultaneously with conservation groups.
Aside from these groups taking your tax dollar to support their objectives, there are also wealthy foundations that contribute to the effort. Wilburforce, Brainerd, Pew Charitable Trusts, and Turner are just a few foundations that fork over money for conservation groups.
Goal: Financially assist NGOs and initiatives in conservation objectives.
What is interesting about these groups is there are legal requirements not being followed. This Legal Framework For Cooperative Conservation document outlines some legal requirements. There are specific requirements for public involvement but these groups create their own support groups, then proclaim them as public involvement. Public engagement, those individuals who live in a particular area, are never involved and engagement with state and federal agencies are hidden as well. Specific requirements for open and transparent disclosure are also required, but this rarely happens. As stated in the document, "These resources belong to the public", not the conservation groups. But that is what they believe, they own the land, it is theirs to manipulate.
The Federal Advisory Committee Act (FACA) is intended "to ensure that agency officials make policy decisions in open, deliberative processes rather than behind closed doors with undue influence by select stakeholders". However, this is exactly what has been happening, activity and decisions are hidden from the public. In order to delegate authority to new entities, "Congress must specify the general policies under which the group operates and the restrictions limiting the group’s authority." LCCs, initiatives, and NGOs operate without any congressional policy, create their own policies while projecting an image of authority, are self directed with no oversight, while the public is not informed about the depth of involvement by so many groups, their intention to collect and share data for decisions on how we will live or use our land, or that the federal government is funding it with our tax dollar. Had we been informed would we agree to this egregious agenda? Would there be agreement to the end goal of placing all of Island Park into conservation?
Our Constitution is based on separation of powers. Therefore, federal "agencies may not “subdelegate” this authority to outside parties." But the federal and state agencies are subdelegating decisions to these conservation groups, allowing them to integrate their objectives into governmental decisions, and influencing our elected officials. Even worse, now there is a growing movement towards private sector management of our public land, which Secretary Zinke supports and is implementing with an advisory committee. Is this a sub-delegation of our public land to outside interests? Will there be corporate influence over how the land is used which overrides the public whose tax dollars pay for public land use?
There is also the audacity of the USFS being allowed to subjugate private land to public use for access to public land. The Fifth amendment clearly states, "Nor shall private property be taken for public use without just compensation."
Matthew McKinney (CNREP) has his own ideas about land, writing an article, "The Emerging Role of Network Governance in Large Landscape Conservation". He and his coauthor claim, "No single entity has the authority to address these types of cross-boundary issues, resulting in gaps in governance and a corresponding need to create formal and informal ways work more effectively across administrative boundaries, land ownerships, and political jurisdictions." Network governance is intended to "supplement", not replace other forms of governance. Supplement is a broad term but most likely here it is meant to be an insertion of his and other groups ideology for conservation and regionalism. By his own admission, "civic entrepreneurs from the public and private sectors, NGOs, and universities have catalyzed a variety of innovative governance arrangements". Have they ever heard of the Constitution, the foundation of which cannot be exchanged for other "governance arrangements?
Federal and state employees are public servants, hired to represent Idahoans through laws. Our Senators and Representatives are elected to represent our state, and us. But, the truth is, through partnerships with state and federal agencies, representation has been turned over to other states, countries, corporations, organizations, and NGOs. Unless we come together, organize direct opposition to these groups and individuals, land use for "future generations" will be living with these groups making decisions on all land use. We cannot let them take control of Idaho land. We cannot let them take control of Island Park.
Sign the petition to stop one of their agendas to put wildlife overpasses at Targhee Pass.
If there is any doubt that corridors and connectivity don't lead to more restricted land use, that it is just a myth, conspiracy, or just plain ridiculous, following is a discussion of proposed phases at the GNLCC Connectivity Initiative meeting in September, 2015. Aquatic, avian, and terrestrial fauna habitats are included in the connectivity equation, which means corridors for those habitats as well.
Starting on page 11 Conservation Outcomes include:
This means that our use of our land will not be allowed, it will be taken for conservation via the creation of different types of corridors. Is that what we want?
On their map, the Island Park area is especially hard hit for Big Horn Sheep, Elk, Moose, and Mule Deer migration corridors with targeted areas for acquisitions.
One targeted area for acquisition was accomplished recently in the Duck Creek area near Henry's Lake. In just a short 2 years, with the Nature Conservancy assisting, the US Forest Service acquired 60 acres of "key" habitat for cutthroat trout, which is also key habitat for the other species as well. For humans, they will allow "non-motorized access with camping available within 100 yards (91 meters) of Red Rock Road." Lucky us.
Be prepared, unless we step in and object to this agenda, the whole Island Park area will be incrementally taken from us, and they have given us the map on how they will do it.
The GNLCC issued a Connectivity Pilot Project Preliminary Report in 2015. Page 12 specifically lists Hwy 87 and US 20 "corridors", meaning transportation, for mitigation activity, meaning wildlife, as a short term strategy by the High Divide from the GYE to Idaho. The long term strategy aimed to "conserve private lands and connect public lands". In addition, the long term strategy included annexing the Henry's Fork and Island Park from the GBLCC to the GNLCC to "protect connectivity for multiple species". Rob Ament, Renee Seidler, Gregg Servheen, Gary Tabor, and Michael Whitfield were all participants in this project. Initially meeting in 2014, the Steering Committee "...selected connectivity as a priority shared landscape objective...to support this Ecological Connectivity Prioritization Pilot Project". Henry's Fork and Island Park were identified in the crosshairs by these individuals for their agenda.
This GNLCC power point outlines their specific goal to address wildlife vehicle collisions (WVC) with the intention of building overpasses, which will lead to the creation of wildlife corridors. That in turn will assist them in moving towards "ecological connectivity". Their intent also involves the Federal Highway Administration and state Departments of Transportation. This is what we are seeing at Targhee Pass, the involvement of individuals from Yellowstone to Yukon (Kim Trotter) when in fact, Y2Y is a partnering initiative of the GNLCC "to retain connectivity of wildlife habitat". It isn't about Elk, it is about implementing an agenda for connectivity. They are all working on the same agenda.
This is where it all began. The Obama administration issued a memorandum in 2010, part of which was to create landscape conservation cooperatives. In summary it states:
Section 1. Establishment
(C) (ii) ...creating corridors and connectivity across these outdoor spaces, and for enhancing neighborhood parks; and determine how the Federal Government can best advance those priorities through public private partnerships and locally supported conservation strategies.
(iii) Use science-based management practices to restore and protect our lands and waters for future generations.
Section 2. Functions
(b) Interagency Coordination
(vi) the Department of Transportation
However, the Department of Interior (DOI) Secretary, Ken Salazar, had already put this memorandum in action by issuing DOI Order 3289 in September, 2009. Part of this order states,
Section 3 (c) Landscape Conservation Cooperatives
"...management responses...must be coordinated on a landscape level basis." "...wildlife migration and related needs for new wildlife corridors..." "Interior bureaus and agencies must work with...other federal, state, local governments...to develop landscape level strategies..." and "...work to stimulate the development of a network of collaborative "Landscape Conservation Cooperatives".
This is how "Landscape Conservation Cooperatives (LCCs)" came to exist. No federal legislation. This is why they have no authority for any activity, and why Secretary Zinke issued "Order 3349",,,which "then revoked Order 3330..." that was issued by Secretary Jewell in 2013. This effectively ends all current LCC activity to "set in motion a review of the Agency Actions taken pursuant to Order 3330 for “possible reconsideration, modification or rescission”. As yet, it does not appear these LCCs have stopped their activity. As information becomes available on this it will be posted.