A letter to Teton County Commissioners from Responsible Growth Coalition, Jackson Hole Conservation Alliance, Protect our Waters JH and Indian Springs Ranch HOA.

August 16, 2022

Dear Madam Chair Macker and Commissioners,

We are writing to object to the stated meeting purpose for tomorrow’s TTC Stakeholder Meeting, and ask that you broaden it. The agenda states:

Stakeholder Meeting #12 Purpose:

To review the results of the public meeting and identify a Stakeholder-preferred build alternative for recommendation to the project team. Per County Commission direction, County staff has said that it is tasked with providing a recommendation for a preferred build alternative for a proposed Tribal Trail connector. Once identified and presented to the Commission, the Staff says the Board is to vote on whether to proceed with the project.

The last Stakeholder Committee was told the same thing, and despite that, 7 out of 10 members of the committee voted for an alternative plan that provided solutions for emergency redundancy and other project objectives without putting thousands of vehicles through this sensitive meadow every day and increasing traffic on an already congested Highway 22. Several members of the committee were subsequently replaced in a fashion seen as biased by this group and many residents.

Why would the BCC direct the planners to choose a preferred build alternative rather than determine whether the road is feasible, what benefits it might provide, what it could cost, what the risks would be to the environment, and what alternatives exist? To insist that a choice is made is tantamount to asking if someone would prefer to drive or run off of a cliff. The committee has been tasked with making a choice when perhaps none are the right choice.

We were unable to find notes from BCC meetings directing the planners to choose a preferred build alternative. In fact, to our knowledge, The Board of County Commissioners actually did not give direction to the planners in over two years on this project. In that time:

1. The extent and value of the wetlands was identified by BIOTA, whose analysis included a 2,000 year old fen that supports the surrounding wetlands, absorbs carbon emissions, and purifies waters that flow all the way down into the Snake, our single source aquifer.
2. The Army Corps ruled that these wetlands are under federal jurisdiction, so their stringent process for securing a section 404 permit, including approval procedures, public comment (and dissent), wetlands mitigation, alternative consideration analyses, etc. will have to be followed if the commissioners vote for continuance.
3. WYDOT has moved up their planning process for the WY22 corridor, so this potential project could and should be considered in the context of any plans that may include a road extension that would connect WYO 22 with South Park Loop Road.
4. The Jackson Hole Land Trust has publicly stated that they do not want their easements picked at ‘piecemeal,’ but rather prefer to see a holistic plan for the corridor.
5. Indian Springs Ranch HOA and the Land Trust have publicly said they are not in favor of modifying the easement, which leaves one route (the existing right of way) as the only option that doesn’t call for lawsuits and condemnation of wetlands under federal jurisdiction and conservation easement.
6. That route on the right of way would require a new intersection, which undoubtedly would make HWY 22 worse even beyond the more than 6% volume increase that would be created by induced demand, per the County models.
7. Traffic figures have not been updated since the BCC last weighed in on this project over 2 years ago, despite continued requests from the public to see updated models. Questions about traffic model assumptions such as how much pass through traffic would be anticipated go unanswered.
8. The budget, to our knowledge, has not been updated in over 2 years. What was estimated to be a $7 million project could cost $15 million or more now.
9. The recent survey of Teton County residents no resulted in 2/3 of the voters being against the road and 1/3 in favor. The No Build Option had approximately five times the support of any other option.
   We ask that ‘No-Build’ and/or ‘delay/incorporate into the WYDOT NEPA process for the corridor’ be considered as options, particularly given that the No-Build Option is the opinion of 2 /3 of residents who have submitted official public comment.
   
   Thank you,
   Responsible Growth Coalition
   Jackson Hole Conservation Alliance
   Protect our Waters JH
   Indian Springs Ranch HOA