ITD Letter: Response to the No Huetter Bypass Group’s Four “Asks”

See Original Letter (PDF)

ITD sent this letter as an attachment to an email on October 10, 2025 (“Brian, Please see attached letter. Thank you!”), in reply to the group’s email of September 29, 2025.

From: CarrieAnn Hewitt, PE, ITD District 1
To: No Huetter Bypass Group, Attn: Brian Rogers
Date: October 10, 2025

Dear Brian,

We have received the various letters you have sent on behalf of the No Huetter Bypass Group. This letter is to address the primary concerns you have raised from your previous correspondence. If, after reviewing this letter, you would like additional clarification, we remain available to meet in person as we have done previously. Given the volume of your concerns, an in-person discussion might be the most effective way to provide the context and answers to your questions.

Your previous letters have included four “Ask” items, which are shown in bold below, with ITD’s responses following each one. Many of these points have been addressed in prior communications.

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. This was addressed by ITD. Originally, the project team had only anticipated holding a single public meeting series centered around the Level 2 Screening Process. After the first series, we decided that a more in-depth evaluation process was needed to fairly compare the alternatives. The further evaluation used the same KMPO traffic model that follows FHWA’s recommended guidelines and best practices for model validation. KMPO’s processes were also approved by FHWA through their MTP approval. Based on this further evaluation, we held a second round of public meetings for the Level 2 Screening on September 17th and September 18th, 2025, the fourth series of public events in total, to highlight the draft Level 2 results rationale and data. The first Level 2 public meetings were the review of Level 1 final results and provided an introduction to the recommended 13 alternatives that were moving forward to Level 2. The introduction of the 13 alternatives in Level 2 also included some preliminary information from the early evaluation of these 13 alternatives. The latest public meetings were to review Level 2 alternative final data and ITD recommendations with the public and to get public comments on alternative evaluation data. ITD is planning for a fifth public engagement event in 2026 for the Draft Level 3 results.
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. The public provided input at each public meeting on the range of alternatives, and the public’s input has been considered at each level of alternative recommendations. During the recent public meetings on September 17th and 18th, we shared our data with transparency on how we evaluated the data and how our recommendations were made. The recent public meetings were specifically for this purpose. The public comments will be reviewed with the Level 2 data to finalize Level 2 and to determine which alternatives will progress to Level 3. The public information summary and Frequently Asked Questions document, both which serve to summarize public feedback, is available on the project website for all previous public engagement periods. Anyone can review those documents and look at the outputs for the alternative recommendations as part of past analyses. Our consultant is preparing the documents summarizing the recent meetings and online public comment period. Those will be available online as well once they are complete.
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. ITD has posted the Alternatives Evaluations Process Memo on the project website, and shared the updated screening matrix, which no longer includes smiley-faces representing a rating scale. The Alternatives Evaluation Process Memo explains each of the colors within the matrix and clearly defines the limits of each category. At all the public meetings, both in person and online, the public was given an opportunity to comment on the alternatives recommended and not recommended to progress to Level 3.
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. A packet of information was made available at the recent public meetings including the updated matrix. An Alternatives Evaluation Process Memo was also made available that went deeper into the scoring criteria for the colors used to represent significance of the alternative evaluation data. This information was available both in person and is actively available online.

In response to the request to use SSTI framework and rail-based transportation options, we understand your concerns. However, at this time, Idaho has not adopted the SSTI framework. The population density in Kootenai County does not support using rail or train-based alternatives as part of this study. Also, Idaho has not established a mechanism to fund, support, or maintain transit operations and infrastructure at this point in time. The purpose of this PEL is to evaluate roadway and multimodal improvements, such as bicycle and pedestrian connections and coordination with existing transit providers, and to address current and future transportation needs in the area.

ITD has coordinated with local transit agencies to understand their needs and build their recommendations into the final alternatives. We will continue to consider ways to support additional multimodal travel needs within the study area. However, rail infrastructure is not feasible or within the scope of this project at this time.

We understand that you also feel that the study is not following Federal standards and regulations. I will again reassure you that ITD is working closely with FHWA and is following all required processes, procedures, regulations, and best practices with regards to this PEL study. While the ITD PEL Procedures document was not in place when the PEL kickoff took place, FHWA has been clear that we have to follow our 2024 PEL Procedures document regardless of when the PEL project started. There are four FHWA concurrence points to the ITD PEL process. They are shown below:

• FHWA Concurrence Point 1 - Determine Reason for PEL Study and Desired Outcomes - Completed
• FHWA Concurrence Point 2 – Develop Purpose & Need - Completed
• FHWA Concurrence Point 3 – Evaluate & Screen Alternatives
  • Alternatives Evaluations Process Memo - Completed
  • Alternatives Evaluation Documentation - To be completed following Level 3 screening
• FHWA Concurrence Point 4 – Finalize PEL Document – Anticipated Summer 2026

“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. 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.”

ITD has not adopted the State Smart Transportation Initiative, and participation in that program is not a federal requirement. ITD applies Context Sensitive and Practical Design principles through its own manuals and procedures. However, those specific considerations will occur in greater detail during the National Environmental Policy Act process, which is a more advanced phase than where we currently are in the PEL study. The purpose of this PEL study is to identify potential routes and broad transportation solutions; more detailed design elements and specific standards will be evaluated at later project stages, which would include NEPA.

Public Input: ITD considered all public input for Purpose & Need, Level 1 and Level 2 and will continue to get public input throughout the entire process. Please see the Public Meeting Summaries provided on the PEL Project website.

Building a True Range of Alternatives: The Rathdrum Prairie PEL Study alternatives were developed through a combined effort including ITD, KMPO, local municipalities, the Community Working Group, and by public comment from the various public meetings. We understand that members of the No Huetter Bypass group have expressed concern about how alternatives were identified. However, it’s important to note that several of the alternatives recommended to move forward, including two of the primary alignment recommendations, originated from layouts and suggestions provided by the No Huetter Bypass group itself. Those concepts were refined through follow-up discussions and technical review to ensure consistency with engineering and environmental considerations. ITD and FHWA believe the process has been thorough, inclusive, and consistent with federal and state guidance.

There is a large lack of details about how these items have been selected: ITD has made multiple efforts to meet with communities, stakeholders, and especially representatives from the No Huetter Bypass group, including yourself, to explain our thought process in detail. During the last Community Working Group meeting, you left before we had the opportunity to present the full discussion and materials, including traffic model maps, data, and analyses that described the alternatives. The rest of the group was able to review these materials and provide input ahead of the public meeting. On 9/11/25, I emailed you and the rest of the Community Working Group the Alternatives Evaluation Process Memo, the matrix handout, and the travel time and congestion handout that included the data which was the basis for many determinations. The Community Working Group, other than the No Huetter Group representatives, has not expressed any concern with the amount of detail presented for the various alternatives during the PEL study so far.

It’s important to note that the selection matrix is not a simple tally of “green boxes.” We used more of a sieve type of analysis. We looked first at alternative performance, for example, the volume to capacity ratio maps telling the story of reducing congestion or reducing travel times. We used these as a tool to present data to the public, but it was only one piece of the performance criteria. We determined that presenting model outputs visually through maps provided a clearer overall representation of how each alternative impacts the system as a whole, which is why we decided to include that information in addition to the screening matrix. Then, we looked at the various alternative impacts to things like homes, businesses, and cultural/environmental resources.

I wanted to get this response to you as soon as possible, especially for your four main “Asks”. We were hoping that this last round of public meetings would’ve addressed most of your questions. The public meetings and online meeting forum is how we’ve been coordinating successfully with most of the public. I will coordinate with our group and work on developing a more detailed response to your remaining concerns.

Again, we offer you to sit down with us to go through our alternative data with you. Originally, I asked your availability for the week of September 29th or October 6th. I’ll be out the week of October 20th, but I’d be happy to meet with you any time before or after that. Please let me know your availability and if we can sit down with you to discuss your concerns.

I look forward to hearing from you soon.

Sincerely,

CarrieAnn M. Hewitt, PE
Idaho Transportation Department – D1 Planning Section

ITD’s follow-up: ITD Letter: Data Requests Must Go Through a Public Records Request.