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.