Comments on Level 2 Alternatives for the Rathdrum Prairie Planning and Environmental Linkages (PEL) Study – Third Letter
ITD District 1
Attn: Carrie Ann Hewitt, P.E.
600 West Prairie Avenue
Coeur d’Alene, ID 83815-8764
Subject: Comments on Level 2 Alternatives for the Rathdrum Prairie Planning and Environmental Linkages (PEL) Study – Third Letter
Dear Mrs. Hewitt,
Thank you for the continued opportunity to provide feedback on the Rathdrum Prairie PEL Study. This third letter builds on our previous submissions, drawing from the Level 2 Alternatives Development, Description, and Screening Criteria Summary, the KMPO Transportation Improvement Program (TIP) 2025-2031 (Transportation Improvement Program 2025-2031), and federal regulations under Title 23 of the U.S. Code and Code of Federal Regulations (CFR). The No Huetter Bypass group continues to emphasize solutions to reduce property condemnation while prioritizing safety, efficient road design, crossings, and traffic flow compliance.
Our concerns focus on alternatives requiring excessive land acquisition, the insufficient exploration of grade separations (overpasses and underpasses) to optimize existing corridors like US-95, the underlying motivations for the Huetter Corridor/Bypass favoring commercial freight over local needs, and the underfunding of immediate US-95 improvements, which prolongs traffic hardships for residents for decades.
Democratic Deficit – The KMPO Has Other Plans Already
It is out of line with the principles of a PEL study at this level, for the entire Rathdrum Prairie, to be predetermined with outcomes. The KMPO continues to drive their agenda no matter how much democratic deficit or strategic shirking is involved. The PEL study has just been one more avenue to go against years of feedback rather than working with the community as intended. In their Transportation Improvement Program (TIP) 2025-2031 (Transportation Improvement Program 2025-2031), dated September 12, 2024, many of the designs being brought forward are already called out before the PEL has been completed, including needs for NEPA funding.
In short, the Rathdrum Prairie PEL study is a farce and does not work with the community to do what is best. Instead, it continues the poor performance and planning of the KMPO and only serves to validate non-appropriate solutions for real issues and long-term problems for the local population.
The history against this project has been enormous, but it continues. The PEL study must include data from all the feedback received against this project and its costs. Doing so will further the years of feedback where the community has provided better options and superior outcomes.
The KMPO has been disingenuous with the people of the area for years. On November 3, 2020, they added funding for the project into increases to vehicle registration (Kootenai County voters overwhelmingly reject local fee for road projects). This was voted down 66% to 33% (Kootenai County General Election, 2020).
Before that, going back to 2006, the community has been against this project. However, even back then, the KMPO has turned a deaf ear to reasonable suggestions.
KMPO November 6, 2006 Board Memorandum (KMPO Board Memorandum - November, 2006)
| Support / Opposition |
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| Against the Project Issues |
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The purposeful failure to use any community feedback over the years, to refuse to make SR-41 an access-controlled highway, and to produce misleading data to promote the agenda is concerning. Even with the amount of Right-of-Way taken for SR-41, the KMPO appears to be purposeful in designing failure into the Kootenai County’s transportation needs.
Now, in 2025, KMPO is using the Rathdrum Prairie PEL study to continue their agenda. They are systematically removing the public’s input into the design and other implementations that are possible in this area. ITD is supporting these efforts by ignoring or dismissing, without meaningful data, not only valid but better solutions for the area that will support future growth.
Excessive Land Acquisition in Level 2 Alternatives
Several Level 2 alternatives, particularly H (Access Controlled Highway along Huetter Road as an Alternative US-95 Alignment), rely heavily on new rights-of-way (ROW), displacing properties through eminent domain. Alternative H adds an access-controlled highway with parallel local roads, estimating substantial property impacts via “estimated right-of-way acquisition (number of properties, types of properties, acres)” under the screening criteria, but lacks quantified details for public review.
Federal regulations under 23 CFR § 710.105 and § 710.511 emphasize prudent use of funds and alternatives to minimize takings, such as reusing existing corridors before new construction. The PEL study’s comparative screening notes “Property Impacts: Potential impacts to properties” but does not adequately explore low-acquisition options, violating NEPA’s requirement (23 CFR Part 771) to evaluate alternatives that reduce environmental and community effects, including displacements.
What is the point of moving forward with suggestions that knowingly disregard requirements in the next step?
Lack of Details on Grade Separation Options
The Level 2 summary insufficiently details grade separations (overpasses/underpasses) as standalone or integrated solutions, particularly for US-95 crossings with arterials. FHWA guidelines in 23 CFR Part 646 (Railroad-Highway Projects) promote grade separations to eliminate at-grade conflicts, improving safety and flow without wide horizontal expansions that demand more land. For instance, Alternative I (Access Controlled Highway on US-95) mentions interchanges but omits specifics on over/underpasses at high-conflict points around arterials which could reduce ROW needs by 40-60% compared to at-grade widenings (per FHWA’s Highway-Rail Crossing Handbook).
On US-95, where congestion and safety issues are acute, grade separations could address delays and intersection bottlenecks vertically, aligning with FHWA’s emphasis on system efficiency (23 U.S.C. § 134). The study’s “big lines” approach ignores these, potentially inflating costs ($200-300M total TIP spending by 2031) and property takings.
Motivations for Huetter Corridor: Commercial Freight vs. Local Congestion
Evidence shows KMPO’s push for the Huetter Corridor/Bypass prioritizes commercial freight routes to Canada over local congestion relief. The 2025-2031 TIP lists the “US 95, ALT ROUTE HUETTER BYPASS, NEPA STUDY” (Key No. 23349) as unfunded for construction, focusing only on environmental review—indicating long-term planning for interstate-scale traffic. The current goals of the KMPO are to have the Huetter Corridor as the commercial route, compared to SR-41 or US-95 by 2035. However, this traffic only accounts for 10-20% of the volume past Lancaster Rd on I-95. The goal of the KMPO, driven by Glenn Miles, is to create a transportation corridor, but at the expense of all the people in Kootenai county to Canada (Idaho Truck Parking Research Project, 2023; KMPO 2013 minutes). This aligns with statewide rail/freight goals for goods movement (Idaho Statewide Rail Plan, 2013), but diverts from local needs in Rathdrum Prairie and people as a top priority.
As the Executive Director of KMPO, Glenn is currently leading an effort with transportation agencies, economic development organizations and business interests in Idaho and Alberta, Canada in establishing greater ties associated with freight and commerce between Edmonton, AB and Coeur d'Alene, ID areas.
FHWA regulations (23 U.S.C. § 135) require people, not just freight, be considered without imposing burdens like eminent domain on residents for economic benefits flowing northward. Further that plans should “emphasize the preservation of the existing transportation system.” 23 U.S.C. § 135 (d)(1)(H) The PEL’s screening criteria mention “Efficiency and Redundancy: The alternative improves travel efficiency… and reduces travel demand on US-95,” but overlook how Huetter serves transborder shipping, not daily commutes.
Neglect of Existing US-95 Improvements and Funding Shifts
The PEL and TIP underfund immediate US-95 upgrades, shifting resources to distant Huetter projects (e.g., unfunded beyond NEPA), leaving residents with years of congestion and problems with land acquisition in the proposed corridor area. In effect, this continues to “kick the can” down the road on a project that has shown no value since 1997.
The TIP allocates ~$250-350M by 2031, with ~70% on roadways, but US-95 projects like “US 95, PARKS RD IC” (Key No. 23429) are unfunded for construction, only preliminary engineering. The project puts money in a location with little volume compared to I-95 between I-90 and Lancaster Road. This contradicts FHWA’s asset management requirements (23 U.S.C. § 119; 23 CFR § 515) to preserve existing systems before new builds, and NEPA’s mandate (23 CFR § 771.113) to evaluate no-build and enhancement alternatives.
Per the Innovative DOT handbook (SSTI), practical design and access management (e.g., limiting ingress/egress on US-95) can improve flow without new land, reducing crashes by 19-47% via road diets (FHWA proven safety countermeasures). Redirecting funds from Huetter could address US-95’s current “Fair/Poor” conditions (2023 data), ensuring compliance with federal traffic flow standards like Level of Service.
Recommendations
To minimize condemnation and align with federal laws:
- Prioritize grade separations on US-95 (e.g., over work north of Lancaster Rd) per 23 CFR 646, costing $10-50M per structure but saving on ROW and $10M+/mile widenings.
- Adopt SSTI strategies: context-sensitive solutions and connectivity to enhance existing US-95, avoiding Huetter’s $800M+ estimates.
- Reassess Huetter’s freight focus under 23 U.S.C. § 167 (National Freight Policy), ensuring local benefits are evaluated and focus on using existing right-of-way.
- Shift TIP funding to US-95 projects, per NEPA’s alternatives requirement.
- Provide transparent ROW impact data and extend public review.
Conclusion
In conclusion, the Level 2 plans risk unnecessary eminent domain and delay relief, contravening FHWA priorities for sustainable, low-impact solutions. We urge ITD to revise the current Rathdrum Prairie PEL study for existing infrastructure focus.
Sincerely,
The No Huetter Bypass Group