Escalation of Level 2 Alternatives for the Rathdrum Prairie Planning and Environmental Linkages (PEL) Study and Concerns

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Categories: Communications
Tags: Letter

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

Subject: Escalation of Level 2 Alternatives for the Rathdrum Prairie Planning and Environmental Linkages (PEL) Study and Concerns

Dear Mrs. Hewitt,

Thank you, again, 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.

In the last letter from the No Huetter Bypass group sent December 17th, 2024, we made the following four requests.

  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.

We then met in person on Monday, March 10th at 10:00 in the morning. During that meeting, the No Huetter Bypass group was originally met with a “training” session to help us understand what the PEL process is and what stage it was currently in at that time. However, the group was then and is now fully aware of the PEL process and what should be reviewed at this time. Further, none of the asks from our original letter had been addressed before or at the meeting ITD hosted on August 26th, 2025, titled “Rathdrum Prairie Area Transportation Study Working Group.”

During the meeting, the group voiced its continued concern with the direction of the PEL process. Given that this process is based on a Regional Planning design, there are large concerns due to quick turn to a narrow focus on needs for roads and highways. There is a large lack of details about how these items have been selected and why so many other changes to road designs and multi-modal needs have been, apparently, purposely overlooked. Moreover, the lack of the PEL following Federal standards and regulations is by far the largest issue.

At the meeting, the group made it abundantly clear that the current contractors, HDR, are not specialized and well versed in current regional design requirements and goals. We also brought up the lack of information and transparency on how conclusions have been derived in the data presented. Missing details on morning traffic patterns compared to evening traffic, the need to “stay broad” while entire areas of concern have been dismissed due to costs, land impacts, or other reason not produced for review, and the continued use of ongoing programs rather than looking at the actual needs as described in the PEL definition itself (Planning and Environmental Linkages Handbook) have lead the group to severe concern and distrust of the process and the stage it is currently at today.

Re-Ask

The No Huetter Bypass group requests that the initial requests be acted upon before doing outreach to the public. The material presented at the August 26th meeting does nothing more than state there are road options for the public to review and nothing else that would be equally valuable and could start addressing issues today. The data does not show the actual need but rather assumes need for an entire highway or road without looking at several Federal recommendations that should occur before these suggestions are presented as required.

Further Asks

Failure to Follow 23 U.S.C. 168

The Federal Highway Administration provides the requirements for a PEL study to move into NEPA based on the 23 U.S.C. 168 which we believe needs to be addressed immediately (Federal Highway Administration: PEL Flow Chart). Specifically, the following steps need to be completed.

Specific Items

  1. During the environmental review process, the relevant agency has made the planning documents available for public review and comment by members of the public and federal, state, local, and tribal governments that may have an interest in the proposed project; provided notice of the intention of the relevant agency to adopt or incorporate by reference the planning product; and considered any resulting comments.
  2. There is no significant new information or new circumstance that has a reasonable likelihood of affecting the continued validity or appropriateness of the planning product.
  3. The planning product has a rational basis and is based on reliable and reasonably current data and reasonable and scientifically acceptable methodologies. (CALTRANS PEL STUDY GUIDEBOOK)

Training for Local Resource Agencies

We can see why the PEL process may need to be further trained with local resource agencies. Upon reviewing the Idaho PEL Handbook (Idaho: PEL Procedures Handbook), it is obvious that Idaho is not as mature in the process as many other states. In short, even in Idaho’s version, utilities are to be documented. This has not been one of the criteria that is part of the evaluations and comparisons.

What is a planning product?

Since 1978, NEPA regulations have stated that “agencies shall integrate the NEPA process with other planning at the earliest possible time to insure that planning and decisions reflect environmental values, to avoid delays later in the process, and to head off potential conflicts.”

In 2012, 23 U.S.C. 168 was established by the MAP-21 legislation to facilitate the use of planning products in the environmental review process. In 2015, the FAST Act updated and refined the process, and a 2016 update of the transportation planning regulations incorporated 23 U.S.C. 168.

The term “planning product” means a decision, analysis, study, or other documented information resulting from the transportation planning process as further described in 23 U.S.C. 168. Regardless of statutory or regulatory authority, planning products coming from the metropolitan or statewide transportation planning processes can support subsequent decision-making in the NEPA process.

Planning Analyses

Planning data and analyses (at the State and local level) that are pertinent to the study area can also inform the development of a planning product and can be utilized in subsequent environmental reviews under NEPA:

  • Travel Demand Forecasting and Traffic Modeling: These predictive statewide and metropolitan transportation planning methods are used to help make informed planning decisions.
  • Regional and Local Land Use and Growth Management: These existing conditions and trends influence how transportation problems are defined and how alternatives are considered and compared against one another.
  • Population and Employment: Understanding community needs is part of the transportation planning process and is a vital component of identifying project concepts to shape project decisions and outcomes under NEPA. This is also important when considering environmental justice.
  • Natural and Built Environment: Geographic information systems (GIS) and other mapping tools can be used to identify existing environmental resources, environmentally-sensitive areas, and land use. This can identify existing conditions, potential community impacts, and effects on the natural and built environment (including climate and/or equity).
  • Mitigation: A State DOT or MPO may develop programmatic mitigation plans as part of the transportation planning process to address the potential environmental impacts of future transportation projects.

Planning Data and Decisions

The transportation planning process is a continuous, cooperative, and comprehensive decision-making process that provides for implementation of projects, strategies, and services. Planning decisions may be used in subsequent environmental reviews under NEPA as long as the data that support them are accurate, current, and meet the requirements of NEPA or whichever PEL authority that applies:

  • Travel Corridor: The travel corridor can be carried forward into project development to help narrow the range of alternatives studied in NEPA and promote more efficient decision-making.
  • Transportation Mode Choice: Highway, transit, bicycle, pedestrian, rail, ferry, or other modal options are often a fundamental element of alternatives analysis during the environmental review process. (bold added)
  • The Environmental Setting: The State or metropolitan planning process reflects consideration and analysis based on the scale and complexity of many issues, including transportation system development, land use, employment, economic development, human and natural environment, and housing and community development.
  • Purpose and need may be a statement of the objectives that the proposed action is intended to achieve. These may be identified in statewide or metropolitan transportation plans; supporting land use, economic development, or growth objectives established in applicable Federal, State, local, or tribal plans; and in Federal laws, plans, or policies serving national defense, national security, or other national objectives.
  • Preliminary screening of alternatives and elimination of unreasonable alternatives: The planning level screening of alternatives is supported by the purpose and need of a project, which is essential in establishing a basis for the development of the range of reasonable alternatives for subsequent NEPA analysis.

Little to No Alignment with the FHWA PEL Goals

The analysis draws from the uploaded documents: the Rathdrum Prairie PEL Level 2 Alternatives handout (Rathdrum Prairie PEL Study: Level 2 Alteratives PDF), the “Innovative DOT” handbook (The Innovative DOT: A handbook of policy and practice), and the response letter the No Huetter Bypass Group submitted last time. We compared these against FHWA best practices for PEL studies, federal requirements, and examples from other regional PEL efforts (e.g., Colorado’s I-25 PEL (I-25 Central Planning & Environmental Linkages (PEL) Study), Washington’s SR 167 PEL (SR 167 Master Plan), and Minnesota’s US 52 PEL (Hwy 52 — Hader to Zumbrota study)). The Rathdrum study shows strengths in stakeholder engagement and screening criteria but has inaccuracies and failures in scope, leading to overly narrow alternatives that prioritize roadway expansion over multi-modal options, potentially increasing condemnation needs without fully addressing safety or federal mandates.

Procedural and Analytical Failures

The Rathdrum Prairie PEL study, as presented in the “Level 2 Alternatives Development, Description and Screening Criteria Summary” pamphlet, exhibits profound procedural and analytical flaws that undermine its credibility and its compliance with federal PEL guidelines, specifically around then need for Context Sensitive Solutions (Introduction to Context Sensitive Solutions) (Context Sensitive Solutions Overview).

A primary failure is the severe lack of transparency. The study document presents a list of screening criteria—Safety, Congestion, Mobility, Property Impacts, Community Planning, Environmental Resources, and Implementation—but provides no underlying data, methodology, or weighting to explain how these criteria were applied or how conclusions were reached. The “faces” symbology used in the online screening matrix is functionally meaningless without this backup documentation, constituting a “purposeful removal of people’s right to information”. This opacity is a direct violation of the core PEL principle of a clear, collaborative, and defensible decision-making process.

Furthermore, the process appears to have systematically dismissed substantive public and expert input. The public critique alleges that numerous lower-impact, higher-value solutions—including improved traffic light management, standalone overpasses and underpasses to resolve specific bottlenecks, and comprehensive access management—were proposed in public meetings but are completely absent from the 13 formal Level 2 alternatives as standalone design alternatives. This indicates that the process was not one of genuine, collaborative alternative development but of retroactively justifying a pre-selected set of “big lines on a map.” This approach directly contradicts the PEL requirement for early and continuous public involvement in shaping the range of alternatives considered (Planning and Environmental Linkages Questionnaire).

Finally, the study demonstrates a failure to adhere to modern, federally-endorsed transportation standards. The study ignores the principles of the State Smart Transportation Initiative (SSTI) and the updated 2023 Manual on Uniform Traffic Control Devices (MUTCD). The presented alternatives show no evidence of applying the principles of Practical Design, Context-Sensitive Solutions, TDM, or integrated land use, all of which are central to modern, fiscally responsible, and federally-endorsed planning.

Fundamental Design Flaws and Missed Opportunities

The specific designs proposed within the ITD study are as flawed as the overall process, reflecting an outdated engineering philosophy that prioritizes vehicle speed and capacity above safety, cost-effectiveness, and community context. These design choices are not merely technical details; they are instrumental in justifying the study’s pre-determined, high-impact conclusion. By establishing a massive footprint as the “default” solution, the study makes any discussion of less impactful alternatives seem inadequate by comparison. The engineering choices serve to systematically exclude the very solutions that would minimize the need for property condemnation.

Over-Engineered for a Single Purpose

The default proposal of four-lane roads with a center turn lane (a five-lane cross-section) for arterials like “Alternative D” and the massive six-lane-plus-median design for US-95 are prime examples of over-engineering that ignore decades of safety research. Federal research and widespread state practice have demonstrated that “Road Diets”—converting a four-lane undivided road to a three-lane cross-section (one travel lane each way with a center two-way left-turn lane)—often result in significant safety improvements, with crash reductions ranging from 19% to 47%, with minimal impact on capacity for roads carrying up to approximately 20,000 vehicles per day. The ITD study provides no traffic volume analysis or safety performance data to justify why these safer, less impactful, and more cost-effective designs were not considered as a primary alternative. Similarly, the proposed wide medians and swells (e.g., 40 foot media and 18 foot swells on US-95) are presented without justification, consuming significant amounts of land that could be avoided entirely or repurposed for high-capacity transit like bus rapid transit or light rail or an entire local access road with several grade separation crossings.

The Critical Omission of Grade Separation

The most glaring design failure across all alternatives is the near-total absence of underpasses and overpasses as primary, standalone solutions. The study only proposes them as incidental components of massive new highway alignments, such as the railroad overpass included in Alternative A’s new bypass route. This overlooks one of the most effective tools in the transportation engineer’s toolkit. Resolving key intersection conflicts (e.g., US-95 at Prairie Avenue or Hayden Avenue) or the BNSF rail line conflict in Rathdrum with targeted grade separation could alleviate major bottlenecks and safety hazards with a fraction of the property condemnation required for constructing a multi-mile bypass. This failure to consider targeted, surgical solutions in favor of massive new construction is a hallmark of an outdated and inefficient planning process that fails to seek the most cost-effective solution to the identified problem.

Insufficient and Impractical Multi-Modalism

The token inclusion of “pathways” in some cross-sections is a superficial nod to multi-modalism, not a genuine transportation solution that provides a viable alternative to driving.

  • Lack of Network Integration: The plans show isolated pathway segments running parallel to high-speed highways with no indication of how they connect to a larger community network of trails, sidewalks, or key destinations like schools, parks, and commercial centers. This violates the fundamental principle of street connectivity and creates “paths to nowhere” that do not serve a real transportation purpose.
  • Failure to Address 4-Season Requirements: The climate in Kootenai County includes significant snowfall (an average of 37 to 42 inches annually) and extended periods of freezing temperatures. The proposed simple pathway designs show no consideration for winter maintenance, which is essential for year-round utility. Best practices for snowy climates require specific design considerations, such as adequate clear width for plowing equipment (a minimum of 6.5 to 7.5 feet), designated snow storage areas to prevent piles from blocking the path, and proper grading and drainage to prevent hazardous freeze-thaw icing cycles. Without these features, the proposed facilities would be unusable for a significant portion of the year, failing to provide reliable, 4-season transportation choices.
  • Absence of Transit and Rail: The complete lack of dedicated bus lanes, bus rapid transit (BRT) infrastructure, or any consideration for passenger rail, as emphatically noted in the public critique, is a profound failure for a long-range planning study. In a growing region, ignoring these high-capacity, low-impact modes are indefensible and contrary to the federal goal of providing a range of transportation choices.

Overview of Best Practices for Regional PEL Studies

PEL studies, per FHWA guidance (e.g., “PEL in Practice: Examples from Discussions with States” (PEL in Practice: Examples from Discussions with States) and “Planning and Environment Linkages Handbook” (Planning and Environmental Linkages Handbook)), are pre-NEPA processes to identify transportation solutions collaboratively, incorporating environmental, community, and economic goals early. Key best practices include:

  • Broad Scope and Flexibility: Start with a wide range of concepts (e.g., 50+ in Level 1, as in Rathdrum) but ensure progressive screening retains diverse options, including non-roadway solutions. FHWA emphasizes flexibility (e.g., Colorado DOT’s PEL Handbook (Planning and Environmental Linkages (PEL) Handbook) recommends phased implementation and multi-agency coordination).
  • Multi-Modal Integration: IIJA and 23 U.S.C. § 134 require considering transit, biking, walking, and rail to reduce vehicle demand and congestion. Examples: Washington’s SR 167 PEL included bus rapid transit (BRT) lanes and bike paths to minimize new land needs; Colorado’s SH 119 Multi-Modal PEL (SH 119 MULTI-MODAL PLANNING AND ENVIRONMENTAL LINKAGES STUDY) added rail corridors and pedestrian overpasses.
  • Safety and Traffic Flow: MUTCD and FHWA’s “Effective Practices” mandate addressing conflicts via grade-separated crossings (underpasses/overpasses), access management (e.g., reducing driveways), and complete streets designs. Minnesota’s US 52 PEL used underpasses to separate rail/pedestrian traffic, improving flow without wide expansions.
  • Minimizing Property Impacts: FHWA’s PEL Questionnaire stresses using existing corridors, “road diets” (reducing lanes) (Road Diets (Roadway Reconfiguration)), and compact designs to avoid eminent domain. California’s PEL Guidebook (CALTRANS PEL STUDY GUIDEBOOK) highlights revalidating data every 5 years to refine alternatives and reduce land takings.
  • Environmental and 4-Season Considerations: NEPA integration requires assessing impacts on natural resources; IIJA promotes resilient designs for all-weather use (e.g., cleared bike paths in snowy regions like Idaho).
  • Transparency and Re-Evaluation: FHWA case studies (e.g., Missouri’s I-70 PEL (I-70 Planning and Environmental Linkages (PEL) study)) emphasize public input on screening matrices, cost models, and data sources to avoid bias.

The “Innovative DOT” handbook (The Innovative DOT: A handbook of policy and practice) aligns with these, advocating smart growth principles like multi-modal shifts to reduce congestion without widening roads, thereby limiting eminent domain. It cites examples where states like North Carolina used transit investments to bolster economic security while minimizing environmental footprints.

The Modern DOT: A Mandate for Innovation, Efficiency, and Choice

National best practices, as compiled in the “The Innovative DOT” handbook (The Innovative DOT: A handbook of policy and practice) and promoted by organizations like the State Smart Transportation Initiative (SSTI), show a clear and decisive shift away from a singular focus on highway expansion to solve transportation problems. Modern Departments of Transportation (DOTs) are now tasked with a broader mission: delivering mobility, ensuring equitable access, and building communities, all while facing the challenges of declining revenues and aging infrastructure.

Adopting Performance-Based Practical Design (PBPD)

The revised PEL study must be grounded in the principles of Performance-Based Practical Design (PBPD), a federally-endorsed approach that combines the cost-saving ethos of Practical Design with a rigorous focus on performance management. This means that every design choice must be explicitly justified by its quantitative contribution to achieving a defined performance goal (e.g., a specific percentage reduction in fatal and serious injury crashes, an improvement in travel time reliability, or an increase in access to jobs) at the lowest possible life-cycle cost. Under PBPD, features that are “nice to have” but do not contribute to a core, defined need are eliminated.

Key Principles

This modern approach is built on several key pillars that directly contradict a simple “build-more-lanes” philosophy:

  • Asset Management (“Fix-it-First”): Prioritizing the maintenance and optimization of the existing transportation system before building new capacity is demonstrably more cost-effective. The American Association of State Highway and Transportation Officials (AASHTO) estimates that every $1 spent on keeping a road in good condition avoids $6 to $14 in future reconstruction costs. This principle demands a focus on preserving the billions of dollars already invested in public infrastructure.
  • Practical Design & Context-Sensitive Solutions (CSS): These federally-endorsed approaches demand that projects be “right-sized” to meet a specific, well-defined purpose and need. They require using design flexibility to fit the project to its unique community and environmental context, rather than defaulting to the highest—and often most expensive and impactful—design standards found in manuals. This includes explicitly questioning and reforming traditional Level of Service (LOS) metrics that can drive over-design and lead to projects that are out of scale with their surroundings.
  • Multi-Modalism and System Efficiency: The most cost-effective way to increase the person-carrying capacity of a corridor is often not to add lanes for cars, but to manage demand and improve the efficiency of the existing network for all users. This includes a robust toolkit of strategies such as Transportation Demand Management (TDM) to reduce peak-hour single-occupancy vehicle trips, improving local street connectivity to disperse short trips off of major arterials, and modernizing access management to preserve traffic flow and improve safety.
  • Integrated Land Use and Transportation Planning: A core tenet of smart transportation is the proactive coordination between state DOTs and local governments to foster development patterns that reduce vehicle miles traveled (VMT) and leverage existing transportation investments. This breaks the costly cycle of transportation agencies perpetually chasing sprawling development with new, expensive infrastructure.

Revised Screening Criteria

The vague criteria used by ITD must be replaced with specific, measurable, and publicly vetted metrics aligned with modern transportation goals:

  • Safety: Measured by predicted crash reduction for all users (pedestrians, cyclists, and vehicles), using methodologies from the Highway Safety Manual, not just vehicle-vehicle conflicts.
  • Accessibility: Measured by the change in the number of jobs, schools, and essential services reachable within a 30-minute trip by automobile, transit, bicycle, and walking—not by abstract vehicle speed or Level of Service.
  • Property Impact: Measured quantitatively by the number of parcels impacted, the total acreage of right-of-way required, and the number of residential and business displacements. This must be treated as a primary constraint on design, not a secondary consideration.
  • Life-Cycle Cost: Including initial construction costs, long-term maintenance obligations, and operational costs over a 30-year planning horizon.
  • Multi-Modal Performance: Measured by the miles of connected, 4-season bikeways created; the percentage of population and jobs served by new or improved transit service; and the improvement in pedestrian level of comfort and safety.

Building a True Range of Alternatives

The revised study must analyze, at a minimum, the following four distinct “families” of alternatives, comparing each against a “No-Build” baseline. This approach ensures that a genuine spectrum of solutions is considered, from low-cost management strategies to transformative infrastructure investments. Each alternative within a family must have multiple design options (e.g., different intersection treatments, varying lane widths) to allow for genuine comparison and optimization.

Alternative Family 1: System Optimization and Management (The “Fix-It-First” and “Smarter” Alternative)

  • Concept: Maximize the capacity and safety of the existing road network without significant widening or new construction. In accordance with federal asset management principles, this should be the first alternative fully explored.
  • Components:
    • Access Management: Implement a comprehensive access management plan for key corridors like SH-41 and US-95. This involves consolidating driveways, installing raised medians where appropriate to control turning movements and reduce conflict points, and developing a supporting local street and cross-access system for local circulation. This preserves through-capacity and dramatically improves safety.
    • Advanced Signal Coordination: Implement an adaptive, coordinated traffic signal system across the prairie to optimize traffic flow based on real-time demand, reducing unnecessary stops and delays.
    • Transportation Demand Management (TDM): Partner with major employers, school districts, and local jurisdictions to implement a suite of TDM programs, such as carpool/vanpool incentives, telework support, and subsidized transit passes, to reduce peak-hour single-occupancy vehicle trips.
    • Targeted Safety Improvements: Apply low-cost, high-impact safety countermeasures at identified high-crash locations, such as improved signage, enhanced lighting, and high-visibility intersection markings per the MUTCD.

Alternative Family 2: Strategic Grade Separation and Connectivity (The “Surgical Solution” Alternative)

  • Concept: Address the most critical bottlenecks and safety hazards with targeted, high-value grade separation projects, avoiding the immense cost and property impact of full corridor reconstruction or new bypasses.
  • Components:
    • Key Intersection Grade Separation: Analyze the feasibility and impact of constructing overpasses or underpasses at the most congested intersections on US-95 (e.g., at Prairie Avenue, Hayden Avenue, and Kathleen). A modern design like a single-point urban interchange (SPUI) or Tight Diamond can dramatically increase traffic throughput with a significantly smaller footprint than a traditional cloverleaf interchange.
    • Local Street Connectivity: In partnership with local jurisdictions, fund the construction of key missing links in the local street grid to provide viable alternative routes for local trips, thereby taking pressure off the state highway system.

Alternative Family 3: The Multi-Modal Corridor Transformation (The “Complete Streets” Alternative)

  • Concept: Reconstruct key arterial corridors within their existing or minimally expanded footprints to function as true multi-modal thoroughfares that are designed to move more people, not just more cars.
  • Components:
    • Road Diet Application: Analyze the conversion of existing four-lane sections of SH-41 and other suitable arterials to a three-lane cross-section (one travel lane each way with a center turn lane). This proven safety countermeasure improves safety for all users and creates space for other modes within the existing pavement width.
    • Dedicated Transit Infrastructure: Incorporate dedicated bus-only lanes or Business Access and Transit (BAT) lanes, especially during peak hours, along US-95 and SH-41. This makes transit a faster, more reliable, and more competitive option than driving alone.
    • 4-Season Bicycle and Pedestrian Facilities: Design protected bike lanes and sidewalks that meet winter maintenance design guidelines. This includes ensuring sufficient width for small plows, designating snow storage zones, and designing for proper drainage to prevent icing. All facilities must be designed to be fully compliant with the Americans with Disabilities Act (ADA).

Alternative Family 4: Integrated Rail and Land Use (The “Long-Range Vision” Alternative)

  • Concept: Address long-term growth and fundamentally reshape travel demand by integrating high-capacity rail transportation with supportive local land use policies.
  • Components:
    • Passenger Rail Feasibility: Conduct a formal, comprehensive study on the feasibility, costs, and benefits of restoring or enhancing passenger rail service through the corridor, connecting to Spokane and other regional centers.
    • Land Use Coordination and Scenario Planning: Work proactively with Kootenai County and the cities to use scenario planning tools to model the transportation impacts of different future growth patterns. The state should then tie future transportation infrastructure funding to the adoption of local comprehensive plans and zoning codes that encourage more compact, mixed-use development around existing town centers and potential future transit nodes, thereby reducing future VMT and the need for costly road expansions.

Conclusion

The Rathdrum Prairie PEL study’s failures are not isolated technical errors; they represent a systemic and cascading non-compliance with this entire federal framework. The study fails the spirit of PEL by presenting a narrow, pre-ordained set of alternatives, which suggests a lack of genuine early and continuous stakeholder engagement. This failure to consider a true range of lower-impact alternatives—such as TDM, access management, or grade separation—directly causes the proposed solutions to have unnecessarily large property impacts.

The manufactured need for extensive property acquisition then puts the agency on a collision course with the principles of the Uniform Act, which treats condemnation as a last resort. This entire flawed process stands in direct opposition to the modern, innovative, and fiscally responsible approach advocated by the FHWA. The Rathdrum Prairie PEL study is not just a poor plan; it is fundamentally misaligned with the entire modern federal transportation paradigm and represents a legacy approach that is no longer considered acceptable or defensible at the federal level.

Sincerely,

The No Huetter Bypass Group

Works Cited

  1. Federal Highway Administration. Planning and Environmental Linkages Handbook.
  2. Federal Highway Administration: PEL Flow Chart.
  3. CALTRANS PEL STUDY GUIDEBOOK.
  4. Idaho: PEL Procedures Handbook.
  5. Rathdrum Prairie PEL Study: Level 2 Alteratives PDF.
  6. The Innovative DOT: A handbook of policy and practice.
  7. I-25 Central Planning & Environmental Linkages (PEL) Study.
  8. SR 167 Master Plan.
  9. Hwy 52 — Hader to Zumbrota study.
  10. Introduction to Context Sensitive Solutions.
  11. Context Sensitive Solutions Overview.
  12. Federal Highway Administration. Planning and Environmental Linkages Questionnaire.
  13. PEL in Practice: Examples from Discussions with States.
  14. CODOT. Planning and Environmental Linkages (PEL) Handbook.
  15. SH 119 MULTI-MODAL PLANNING AND ENVIRONMENTAL LINKAGES STUDY.
  16. Federal Highway Administration. Road Diets (Roadway Reconfiguration).
  17. I-70 Planning and Environmental Linkages (PEL) study.