Brianna Fernandez
Idaho Transportation Department
P.O. Box 7129
Boise, ID 83707

Re: Draft Idaho Transportation Investment Program (ITIP)

Dear Members of the Idaho Transportation Department:

I write as a long-time observer of Idaho transportation outcomes to urge an immediate course correction. The draft seven-year Idaho Transportation Investment Program (ITIP) places more than $1.3 billion of highway work into an “unfunded” category. It defers roughly $1.5 billion more in congestion-mitigation projects (Idaho Statesman, 5 July 2026). That fiscal reality is not primarily the product of insufficient revenue; it is the predictable result of four decades of planning that has treated capacity expansion as the default solution while systematically under-investing in the operational and access-management tools that other states have proven far more cost-effective.

As a matter of sound Federal Highway Administration (FHWA) practice and consistent with the performance-based planning requirements under 23 U.S.C. § 150 and related regulations accessible at highways.dot.gov/laws-regulations, scarce public resources must first be directed to measures that improve safety, mobility, and reliability within the existing right-of-way. Such measures minimize or eliminate the need to acquire additional real property interests by negotiation or, when necessary, by eminent domain. Idaho’s continued prioritization of new lane-miles and major interchange reconstructions before optimizing the existing system unnecessarily escalates both capital cost and the frequency of formal condemnation proceedings.

The Core Problem Is Not Growth Alone—It Is Outdated Planning

Idaho’s population growth is real and substantial. Kootenai County and the Rathdrum Prairie corridor have experienced rapid increases that place measurable demand on the state and local networks. Yet the same pattern of congestion, safety deficiencies, and escalating project costs has been visible for decades. Continuing the same planning paradigm by prioritizing new lane-miles and new roads before fixing the operational deficiencies of the existing system will only reproduce the same overspending and the same unsatisfactory results—and will continue to drive unnecessary property acquisitions.

ITD and its regional partners have, in practice, treated modern performance-based and multimodal practices as optional rather than essential. The State Smart Transportation Initiative (SSTI), a joint project of Smart Growth America and the University of Wisconsin–Madison High Road Strategy Center, has for more than a decade convened state DOTs, published the Innovative DOT Handbook containing 34 concrete recommendations, and assisted agencies in Virginia (Smart Scale), Hawaii (SmartTRAC), and elsewhere in shifting from legacy capacity-driven decision rules to outcome-based prioritization. Those agencies have demonstrated that data-driven project selection, multimodal accessibility metrics, and demand-management strategies deliver better mobility and safety results at lower long-term cost while substantially reducing the need for new right-of-way. Idaho’s continued reliance on traditional expansion projects, even while maintenance and preservation needs grow, shows that the state has not internalized these lessons.

Immediate Actions Required: Defund I-90 Expansion, Stop Key Number 23349, and Remove Key Number 24395

The I-90 widening between SH-41 and US-95 (adding lanes to create four lanes in each direction) is already under construction. It is projected to cost approximately $200–210 million for that segment alone, with corridor-level estimates reaching far higher. The project will not deliver meaningful traffic relief relative to the scale of investment when compared with targeted, lower-cost interventions: grade-separated or improved overpasses at key crossings, continuous right-turn lanes where they currently do not exist, and coordinated signal timing and adaptive signal control across the Rathdrum Prairie arterial network. Adding through capacity on the freeway while the parallel arterials remain fragmented by excessive access points and deficient turn-lane geometry shifts and amplifies the problem. These operational measures can be delivered largely within existing right-of-way and thereby avoid or sharply reduce the need for property acquisition under the Uniform Relocation Assistance and Real Property Acquisition Policies Act (42 U.S.C. § 4601 et seq.) and 23 CFR Part 710.

Key Number 23349, US 95, Rathdrum Prairie Area Transportation Study, must be stopped immediately. The study area runs from I-90 north to SH-53 and from the Washington state line east to US-95. Its stated purpose is to evaluate the system and recommend solutions via a Planning and Environmental Linkages (PEL) process under FHWA guidance (23 U.S.C. § 168 and related PEL procedures). In practice, the trajectory of such studies in North Idaho has been to generate additional roadway capacity projects rather than first optimizing the existing network. Continuing the study under current assumptions will lock in more of the same expensive, low-return infrastructure that requires extensive new right-of-way and potential condemnation. Funding and staff effort should be redirected at once to operational improvements and access management on the existing arterials.

Key Number 24395, the I-90 / US-95 Interchange (Exit 12) reconstruction from Emma Avenue to Cherry Lane, must likewise be removed from the program in its present form. This project proposes to replace the I-90/US-95 interchange and ramps and to widen US-95 between Emma Avenue and Cherry Lane with associated intersection improvements, at a construction cost on the order of $128.4 million (unfunded in the current ITIP). The addition of a reconstructed or “new” interchange exit serving US-95 will not improve overall traffic flow or safety until the fundamental deficiencies on US-95 itself are corrected: the provision of above-grade and below-grade overpasses or grade separations at critical crossings, systematic removal or consolidation of mid-block ingress and egress approaches, redesign of the existing right-of-way for improved access control and traffic management (raised medians, restricted turning movements, continuous right-turn lanes), and modern signal management or adaptive control. Until those underlying operational and access-management problems are resolved, the rebuilt interchange will accelerate the delivery of congested traffic onto an already failing arterial. It will recreate the same weave, rear-end, and conflict-point problems that FHWA Corridor Access Management guidance and Interstate access policy (including the requirement under applicable regulations that changes in Interstate access not produce significant adverse impacts on mainline operations or safety) are designed to prevent. Reconstructing the interchange first is therefore a classic example of capacity addition that fails the test of independent utility and that unnecessarily expands the footprint of property acquisition.

KMPO and District 1 Have Not Delivered Modern Solutions

The Kootenai Metropolitan Planning Organization (KMPO) and ITD District 1 have supported performance-target adoption in form, yet the project pipeline continues to emphasize capacity expansion. The agencies have not prioritized the suite of proven, lower-cost countermeasures that the Federal Highway Administration has documented for decades—corridor access management, dedicated turn lanes, signal coordination, and geometric improvements that remain within existing right-of-way. As a result, Northern Idaho continues to receive planning products that perpetuate the very deficiencies the public is asked to fund and that increase the likelihood of formal condemnation proceedings when negotiated purchases cannot be completed.

Referenceable Facts from FHWA and Peer States: Prioritize These Before Any Further Expansion

• Road Diets / Lane Reconfigurations (four-to-three lane conversions): FHWA’s Road Diet Informational Guide and related safety analyses of 45 sites in Iowa, California, and Washington produced an estimated 29 percent reduction in total crashes (Iowa subset 47 percent; California/Washington subset 19 percent). Operational benefits include separation of left-turning traffic, reduced speed differential, and improved side-street access. When implemented with resurfacing, the incremental cost is minimal, and the work is almost always accomplished within the existing right-of-way, thereby eliminating any need for additional property acquisition or condemnation. These treatments should be evaluated and applied on appropriate arterials throughout the Rathdrum Prairie before any additional through-lane capacity is funded.
• Access management / reduction of ingress and egress points: FHWA Corridor Access Management guidance documents show that crash rates rise linearly with driveway or commercial approach density. Research synthesized by FHWA shows average speed reductions of approximately 2.5 mph for every additional 10 access points per mile. Closing, consolidating, or converting these approaches to right-in/right-out only, combined with raised medians where appropriate, simultaneously improves safety, reduces delay, and can defer or eliminate the need for costly capacity projects. This is the single highest-leverage action available on the existing arterial network and must be funded and executed immediately. In many cases, removal or consolidation of these approaches can be accomplished with minimal or no new right-of-way. To date, Idaho State representatives have taken the incorrect stance on this work and have forced plans, such as the initial SH-41 design, to retain excessive approaches, which have gravely impacted traffic flow and safety. Federal policy and 23 CFR provisions governing control of access on Federal-aid highways support precisely the opposite approach.
• Turn-lane geometry, grade separations, and signal management: Dedicated right-turn lanes where they currently do not exist, properly designed left-turn lanes, above- and below-grade overpasses or grade-separated crossings at key conflict locations, and modern signal coordination or adaptive control deliver measurable reductions in delay and rear-end crashes at a fraction of the cost of adding through lanes or reconstructing interchanges. These tools should be the first call on available funding. They address the root causes of congestion and crashes on US-95 and the parallel arterials and are prerequisites to any meaningful benefit from a rebuilt I-90/US-95 interchange.

Other states that have adopted SSTI-supported practices and FHWA-supported countermeasures have demonstrated that a “fix-it-first, manage-access, operate-smarter” sequence produces superior mobility and safety outcomes while controlling capital outlays and minimizing the need to exercise the power of eminent domain. Idaho’s continued deviation from that sequence is the principal reason project lists grow faster than available revenue and why property owners face repeated threats of acquisition.

Requested Actions

1. Immediately defund any further expenditures on I-90 lane additions in the Coeur d’Alene / Post Falls corridor beyond what is contractually unavoidable; redirect remaining resources to overpasses, right-turn lanes, access-management treatments, and signal systems that address the actual choke points and that can be delivered within existing right-of-way.
2. Terminate Key Number 23349 (Rathdrum Prairie Area Transportation Study) in its current form. Any successor effort must be scoped exclusively around operational improvements, access management, grade separations, and safety countermeasures on the existing network before any new-capacity alternatives are considered.
3. Remove Key Number 24395 (I-90/US-95 Interchange reconstruction, Emma Avenue to Cherry Lane) from the ITIP and from active programming until the prerequisite operational and access-management deficiencies on US-95—above- and below-grade overpasses, systematic removal of excess ingress and egress approaches, redesign of the existing right-of-way for controlled access and improved traffic management, and modern signal systems—are funded, designed, and substantially complete. A reconstructed interchange that feeds additional volume onto an uncorrected arterial fails both the independent-utility test and the operational-safety criteria applicable to Interstate access changes.
4. Direct KMPO and District 1 to adopt, within six months, an explicit prioritization framework that places road diets/lane reconfigurations, access-management projects, grade separations, and signal/turn-lane upgrades above new lane-miles and major interchange reconstructions, consistent with FHWA guidance, 23 U.S.C. performance management principles, and SSTI best practices, and that explicitly prioritizes solutions that minimize or eliminate the need for new property acquisition.
5. Report publicly, before the September ITIP adoption, the dollar value of capacity-expansion and interchange projects (including KN 23349 and KN 24395) that can be deferred or canceled by implementing the operational measures listed above, together with an estimate of the reduction in required right-of-way takes and potential condemnation actions.
6. Remove funding to the Kootenai Metropolitan Planning Organization (KMPO) until the organization approaches the residents with plans that align to the needs of the community.

Continuing to plan and build as Idaho has for the last four decades will only continue to overspend, produce the same deficient results, and force more property owners into negotiation or condemnation proceedings that could have been avoided. The fiscal pressure revealed by the current unfunded list is the moment to change course. I urge you to act.

Respectfully submitted,

The No Huetter Bypass Group