ITD's alternatives analysis in their permit application to the Army Corps is so weak that it cannot possibly be defended. The key shortcomings include:

1. The project purpose and need description is ambiguous and unduly restrictive.

2. There is no inventory of the impact to wetlands for each alternative. (C'mon, ITD, how hard is it to fill out a spreadsheet with columns "alternative" and "acres wetlands fill?")

3. The measurement of conformance of the alternatives against the purpose and need completely lacks objectivity. (For instance, determining that the stretch of U.S. 95 through Ponderay containing eight intersections, two planned stoplights and 45 driveway entrances can be classified as a "non-stop.")

All three of these are required; any one of them missing puts the entire project at risk.

Further, ITD's report is substantially a work of fiction. One alternative requires acquisition of the courthouse property — the ITD spinsters suggest a new courthouse might end up in the creek! In another, a water line operated only during the summer is described being as 'crucial that it not be disturbed' - as if it would cut the water supply to metropolitan Seattle or something. This behavior will only bite them in the end (in more way then one).

It is time for ITD to stop its repeated attempts to end-run federal regulations. When they choose to embrace, rather then evade, regulations will they get the permit that will allow them to take the improvements to U.S. 95 forward to completion.

STEVE POTTER

Sandpoint