ITD District 1
Attn: Carrie Ann Hewitt, P.E.
600 West Prairie Avenue
Coeur d’Alene, ID 83815-8764

Dear Carrie Ann Hewitt,

Thank you for the opportunity to provide feedback regarding the Planning and Environmental Linkages (PEL) Study. My insights are based on the materials presented during multiple meetings and my observations from ITD, KMPO, City, and County meetings over the last four years.

Ask

1. An extension to the level 2 planning process must be initiated. Additional funding must be allocated to reviewing the sources, data, and concepts presented to the HDR Inc. consultants.
2. A review, open to the people with complete transparency, must be conducted to validate that people’s inputs were used in deriving the “Alternative” solutions.
3. Pricing models, environmental impacts, implementation, property, mobility, and safety values must be presented to the public for review. The review process should include public feedback on how the “faces” are determined.
4. The Level 2 magazine must be redone to include only information on the website, including the “faces” Screen Matrix and how those faces were determined.

Summary

The overall Planning and Environmental Linkages (PEL) study performed by the HDR Inc. consulting group sponsored by the Idaho Transportation Department (ITD) is of poor quality and obtuse. The people deserve better planning for the Rathdrum Prairie. The situation continues to compound with a consistent lack of alignment with current solutions for future planning by the Kootenai Metropolitan Planning Organization (KMPO). Even on the KMPO’s website, their main pictures and focus are on roads and only roads.

The solutions produced in the magazine continue to show that the only agenda being driven is one that is old-fashioned and failed. Roads are not the only nor best solution for mobility and continue to be shown as a less effective way to support communities.

Further, the website information does not provide sources and data used to determine the level 2 Screen Matrix definitions and how they were derived. There appears to be a sub-agenda in place to drive conclusions for “Alternative” solutions, which government agencies like the KMPO previously proposed. These conclusions are contrary to current-day financial analysis and federal guidelines.

Failed Report Summary by HDR Inc.

The No Huetter Bypass group had asked several times before the consultants were selected if the consultants would have specialties around the State Smart Transportation Initiative (SSTI). The Idaho Transportation Department representatives reassured us that these consultants would be highly educated and well-versed in all transportation projects. After reviewing the Level 2 Alternatives Development, Description, and Screening Criteria Summary, HDR consultants and other document creators appear to have ignored significant cross reference in modern changes to transportation requirements made by the Federal Government, not to mention more progressive solutions like the SSTI.

The PEL study is, unfortunately, not well-informed of solutions for scale and local planning needs, which should be reviewed for a positive path forward. The consultants did not appear to use modern solutions well documented in the 11th Edition of the Manual on Uniform Traffic Control Devices (MUTCD) for Streets and Highways, December 2023, and do not consider solutions documented by the State Smart Transportation Initiative.

During the meetings with HDR, they stated that the current summary should only include the “big lines” on the map as the NEPA process will add more details. Unfortunately for the people, this means that several key items brought to their attention in meetings, like improved light management across the Rathdrum Prairie, sizing of arterials, overpass and underpass use instead of road changes, removal of ingress and egress for roads like SH-41 and others were not taken into consideration as stand-alone solutions. In the meetings, it was also proposed to the consultants that part of the requirements for this should be deeper engagement with Idaho state lawmakers to address inaccuracies in the law that impact positive outcomes in the planning process. The summary doesn’t include any of these statements and only provides a hyper-focus on “big lines” across a map. Long Range Planning

The Level 2 summary does not provide critical details on the proposed solutions but stays high-level; interpreting the suggestions is nearly impossible to analyze for validity or value. For example, Alternative I from the summary only provides the interchanges and cross-section of the proposed road. However, it does not specify why there needs to be a 40’ median on US-95, why the local access road does not have a turn lane, and how pedestrian and multimodal solutions will be addressed in the design. The online documentation showing the level 2 Screening Matrix does not provide critical information to understand what the “faces” mean. The lack of transparency here shows a purposeful removal of people’s right to information.

It is concerning to think that "Alterative D" could be a better solution than “Alternative H” because a 4-lane with a turn lane arterial was selected as "Alternative D" instead of a 2-lane with a turn lane. "Alternative H" is also considered to be only "Medium Cost" with no financial scale associated with it when reading it. However, using Federal standard pricing and other states, the estimate for development is above $800,000,000. However, it seems that KMPO has provided an initial forecast for this solution, estimated at a $300,000,000 project.

Without transparent details and sources on the data used to evaluate the solution and an overall improvement in traffic light management, multimodal solutions, underpass and overpass additions, and removal of ingress and egress, long-range planning does not improve.

Arterial Road Planning Biased to 4-lanes with a Turn Lane

It should not be a foregone conclusion that four lanes with a turn lane are required, even for large arterials. The key challenges or significant issues related to 4-lane arterial roads often include the following aspects, generally addressed in road design manuals, including the MUTCD. The design of 4-lane arterials with a center turn lane (often referred to as five-lane roads) is intended to manage traffic volume and facilitate left-turn movements. However, this design can have several negative impacts and actually fails when it becomes saturated.

Figure 1Source: Understanding and Improving Arterial Roads to Support Public Health and Transportation Goals

Increased Conflict Points

The presence of a center turn lane can increase the number of conflict points between vehicles, particularly at intersections and driveways. This can lead to a higher likelihood of collisions, especially rear-end and sideswipe accidents as vehicles maneuver into and out of the turn lane (Transportation, n.d.).

Figure 2 Source Road Diet Summary. Retrieved from Minnesota Department of Transportation

Traffic Flow and Congestion

When traffic volumes exceed the capacity of the center turn lane to provide gaps, it can lead to congestion and reduced flow efficiency. Vehicles waiting to make left turns can back up traffic, especially during peak hours, reducing the overall throughput of the road. “Uncontrolled access to arterial streets can cause the traffic flow to break down, congestion to become almost intolerable and local businesses to suffer,” Layton said. “It is important that travelers and business owners understand access management is good for everyone.” (Layton, 2009).

Safety Concerns for Pedestrians and Cyclists

These roads often do not provide adequate protection or infrastructure for non-motorized users, increasing the risk of accidents involving pedestrians and cyclists. The wide cross-section can make crossing distances longer, leading to higher exposure times for pedestrians. Further, putting bike and walking paths does not reduce the overall problems as, the usage patterns for such solutions here in northern Idaho and seasonally limited (McAndrews, 2017).

Table 1 Understanding and Improving Arterial Roads to Support Public Health and Transportation Goals

The suggested designs do not provide any information on how they comply with or impact the known standards for the community. The design suggestions by HDR continue to follow the “big lines” concepts; however, they pre-bias the concept of impact to the community in their depictions without providing reasoning and long-term impacts.

In several of the typical section descriptions, pathways were described for bike and pedestrian traffic. However, the connections to these sections are typically impossible and don’t align with larger paths like the North Idaho Centennial Trail. These alignments were not done during the PEL study which adds additional concern to the overall goal of the PEL results.

Noise and Pollution

Higher traffic volumes and speed can increase noise levels and air pollution, impacting the quality of life for those living adjacent to these roads. Sound levels can also be considerable due to moderately high traffic volumes characteristic of arterials and also due to considerable braking and acceleration that often occur on arterials that are heavily signalized (Wikipedia, n.d.).

Number of Additional Accidents

The number of additional accidents due to this design and significantly higher. Specific data on how many additional accidents occur yearly because of these designs is not uniformly documented across the U.S. However, studies on similar road configurations suggest that four-lane undivided roads have a higher crash rate compared to other configurations. For example, in Minnesota, the average crash rate for four-lane facilities is reported to be 5.7 crashes per million entering vehicles (MEV) per year, while three-lane configurations (which include a center turn lane) have a rate of 2.0 crashes per MEV per year, indicating a 46% reduction in crash rates with a three-lane design. This implies that four-lane arterials might see more accidents due to their design (Transportation, n.d.).

Traffic Operations

At lower traffic volumes, this design can operate more efficiently than a four-lane setup with a turn lane, as it can handle left turns without significantly disrupting through traffic. However, at higher volumes, this might not always be the case, especially if there are insufficient gaps for turning traffic (Layton, 2009).

No Planning for Train-based Transportation

When considering multimodal transportation for growth expansion, excluding train transportation can lead to several significant issues. There has been no design for this type of transportation in all designs presented. Even the larger median reservations are outside locations that would support the addition of this type of transportation in the future. The missing inclusion and design for this is another example of a request that disappeared during meetings with HDR consultants.

Reduced Efficiency for Long-Distance Travel

Trains are highly efficient for long-distance travel, offering speed and capacity that can significantly reduce travel times compared to road-only options. Without trains, people must rely more heavily on slower, less efficient road or air travel for long distances, which can increase travel time and cost (LTD, 2023).

Environmental Impact

Rail transport is generally more environmentally friendly than road transport, with lower emissions per passenger mile. Excluding trains means missing out on opportunities to reduce carbon footprints, increase air quality, and promote sustainable transport options, especially for bulk passenger movement (Wireless, 2018) (Goulet, 2024).

Congestion and Infrastructure Strain

Without rail options, there’s a greater dependency on road infrastructure, leading to increased congestion, particularly in urban areas. This can exacerbate traffic issues, lead to longer commute times, and increase the wear and tear on roads, necessitating more frequent and costly maintenance.

In the United States, transportation planning goals and existing road design are often out of sync. In many U.S. cities, roads were built first for vehicles, with little thought given to other types of transportation. This imbalanced approach has far-reaching effects, impacting public health and well-being in many ways. In 2022, there were over 7,600 pedestrian deaths in the U.S., more than 17% of all traffic-related fatalities. [1] Meanwhile, the transportation sector is responsible for more than 25% of all pollution-related deaths each year. [2] Not only that, but the existing road infrastructure in many cities fails to account for the 9% of U.S. households that don’t have a car [3] or the 45% of Americans who lack access to public transportation. [4].

Economic and Urban Development Limitations

Rail services can drive economic growth by connecting urban centers with suburbs or rural areas, fostering development along rail corridors. Omitting train transportation can hinder this development, limiting access to jobs, education, and services, and potentially slowing down regional economic growth.

The Infrastructure Investment and Jobs Act, also known as the Bipartisan Infrastructure Law, offers U.S. states and cities the chance to invest in transportation systems that modernize infrastructure, expand access and mobility for all people in a community, improve public health and safety, and boost local economies. Transportation emits more climate-warming greenhouse gases than any other sector in the United States, so cutting carbon from transport is also essential to achieving the ambitious goal of reducing emissions 50%-52% by 2030. Recent modeling from America Is All In, a coalition of state and local climate leaders, shows that emissions reductions in the transportation sector can contribute more than one-third of what’s needed to reach the 2030 U.S. climate goal. The key is to go multi-modal: not just cars, buses, rail, bicycles or walking, but a coordinated system of various modes of transportation. States, tribes, cities, universities and businesses have vital roles to play in developing clean multi-modal transportation systems that work for the entire community while fostering health, safety and economic prosperity. (Liz Bridgwater, 2022).

Cost Implications

While the initial investment in rail infrastructure might be high, the long-term operational costs per passenger can be lower compared to maintaining extensive road networks or relying solely on air travel. Excluding trains might lead to higher transportation costs over time due to the inefficiencies of other modes for certain types of travel.

Not including trains in a transportation planning study can lead to several negative cost implications.

Increased Long-Term Transportation Costs

Trains are highly efficient for moving large numbers of people and goods over long distances. Without considering rail in planning, there might be an over-reliance on road infrastructure, which is generally more costly to maintain and expand due to higher wear and tear, congestion, and the need for extensive road networks (RUNGWANICHSUKANON, 2015).

Higher Environmental Costs

Rail transport tends to have lower emissions per passenger or ton of freight compared to other modes. Excluding trains from planning studies means potentially missing out on reducing external costs like air pollution, noise pollution, and carbon emissions, which can have significant economic implications in terms of health costs, environmental cleanup, and compliance with environmental regulations (Wisnicki, n.d.).

Increased Traffic Congestion and Its Associated Costs

Trains can significantly reduce road traffic, particularly in urban areas or busy corridors. Without rail, increased road congestion leads to higher economic costs due to lost productivity, increased fuel consumption, and more frequent vehicle repairs. The cost of congestion in terms of time and fuel can be substantial (Logistics, 2023).

Operational Inefficiencies

Without rail, multimodal logistics plans might not be as efficient, leading to higher operational costs for transport providers and shippers. This includes costs associated with more frequent handling of goods, longer transit times, and less optimal routing (Dandan Chen, 2019).

Public Perception and Future Flexibility

If rail is not considered, future adjustments to include rail might be more costly or politically challenging due to established infrastructure and public expectations. This can limit future flexibility and increase costs when rail becomes necessary or desirable.

Conclusion

In conclusion, the Rathdrum Prairie PEL level 2 summary is open to immense debate on how the conclusions were drawn. It further ignores concepts brought up in meetings with the people and blatantly overlooks the need for more than roads to solve the needs of the community over the next decade or more.

Narrowing down the “Alternatives” provided could only be done through personal bias from the data presented to the community. Even that data appears to be carefully tailored from previous local government projects.

Primary Selection for Alternatives would be the following:

ALTERNATIVE	VOTE	COMMENT
A	Yes	Further design details and reasoning should be provided on how it impacts ingress and egress. Having multiple ingress/egress locations for a 4-lane with turn lane road is problematic as stated above. Other solutions could be found here.
B	No	The design has been shown to be ineffective throughout the United States.
C	Yes	The section design provides for an excessive amount of land and space. There is no reason presented showing a need for medians as large as shown along with drainage areas.
D	Maybe	The section design is not valid for the environment. Nothing currently shows that a 4-lane with a turn lane is better than a 2-lane with a turn lane.
E	No	Parts of the suggestion might be viable, but much must be redesigned to be usable.
F	No	Parts of the suggestion might be viable, but much must be redesigned to be usable.
H	No	Much information has already been presented on the ineffectiveness of this solution due to many other North/South routes and the issues that would occur on I-90 between SH-41 and US-95. Further, the design continues to show local corruption in the layout that the work would only happen in the Post Falls jurisdiction and not in the Coeur d’Alene jurisdiction.
I	Yes	It is the burden of the State to make this an access-controlled highway. This must be completed before “need” can be found in taking land for several other projects.
J	Yes (change design)	The design does not take into account the train tracks and tunnels. It should be expanded in research more thoroughly before moving forward for this level of voting.
K	Yes	Look to remove ingress and egress as much as possible to reduce the need for arterial construction and focus on making this the primary route to go from I-90 to US-95 above Lancaster Rd.
L	Yes	Look to remove ingress and egress as much as possible
M	No	Leave Wyoming intact and focus on faster options for East to West traffic
N	Yes	Remove large medians and look to remove ingress and egress to the roads as much as possible.

The community continues to be let down, even after this $3,000,000 investment. The consultant team appears to have focused more on local government feedback than on the appropriate design for the community. The consultant team did not take into account the average temperature and winter conditions when looking to support mobility in these solutions. The initial “asks” at the being of the letter are still required.

Sincerely,

The No Huetter Bypass Group