Sierra Club Idaho Chapter

The Honorable C. L. "Butch" Otter, Governor of Idaho

September 10, 2010

Dear Governor Otter,

On behalf of our 2000 members of the Idaho Chapter of the Sierra Club I write to you respectfully requesting that you change course on your public stance supporting the proposed transporting of massive over-legal loads on U.S. Highway 12. Recent events have now made this matter a national issue. Idaho District Judge John Bradbury on August 17th put a legal hold on four massive shipments of ConocoPhillips industrial processing equipment. Central to his correct ruling in a lawsuit filed by three north Idaho citizens was that the Idaho Transportation Department (ITD) violated it's own rules. Idaho citizens overwhelmingly oppose the oil industry industrializing the main Clearwater, Middle Fork Clearwater, and Lochsa River corridors. On July 13th the signatures of 1,704 Idaho citizens in vigorous opposition to this mammoth and unnecessary project were concurrently hand carried to the Lewiston ITD office and mailed to you.

The corridor's U.S. Highway 12 is nationally designated the Northwest Passage Scenic Byway and one of the nation's twenty-seven All-American Roads. This 174-mile narrow, winding, scenic gem of a roadway runs for its entire length literally yards away from three pristine rivers, including two federally designated Wild and Scenic Rivers. Between April and November, U.S. 12 is heavily used by recreationists including fisherman, hunters, kayakers, rafters, bikers, hikers, packers, swimmers, photographers, and sightseers – locals and visitors – all of whom use turnouts along the river for parking. Additionally, the highway parallels the nationally designated Lewis and Clark and Nez Perce National Historic Trails. In other words, the U.S. 12 corridor is nationally and internationally recognized as a uniquely significant treasure.

The significant and overlapping issues related to the proposed conversion of U.S. 12 into a permanent industrial truck route for the gargantuan loads of giant international corporations are public safety, impeding traffic flow, interference with the public use of their own rivers and highway, protection of the inherent wild and scenic river values, and serious damage to tourism, the single growing industry of north central Idaho.

The proposed four ConocoPhillips and 207 Exxon Mobil/Imperial Oil of Calgary (EM/IO) loads and over the longer term - up to at least a half century- more than 1,000 road-blocking loads will surely endanger the Wild and Scenic Rivers and north Idaho's proven national tourism attraction. The tourism industry in north central Idaho is strong and vibrant. It contributes approximately $150 million annually to local rural economies. It would be ruinous to degrade the high quality tourism benefits to North Idaho by partially destroying the attractive qualities that bring visitors in the first place from around the nation and world. North central Idaho is increasingly recognized as one of the "last, best places." It will not remain so if the massive "high and wide" loads are inappropriately permitted.

The whole of Idaho is infinitely blessed to have this river corridor as a remarkable natural resource, a resource that in and of itself enables a thriving segment of our state's second largest industry: tourism. A decline of tourism in north central Idaho will precipitate a decline in the tourism economy of our entire state.

The perceived economic "benefits" to the state of Idaho and Montana heralded by ConocoPhillips and Imperial Oil's public relations people are imaginary and miniscule juxtaposed with the detrimental economic impacts on tourism. Clogging our highways, compromising public safety, and threatening our most unique river valleys would be a mega-disaster. In a recent paper referencing the ConocoPhillips and Imperial Oil shipments, T.A. Power, head of the University of Montana economics department, clearly demonstrated the "voo doo economics" incorrectly espoused by the Idaho and Montana state governments. As Montana Department of Transportation director Jim Lynch pointed out in 2009 to the Montana Transportation Committee, only Canada will benefit economically.

It should be noted that in addition to the current orders from EM/IO, Sungjin Geotec Co, a Korean entity, is expecting additional orders from EM/IO for $1.5 billion for approximately 1,000 giant pieces of drilling machinery. Idaho and Montana citizens should not subsidize these foreign companies, since doing so would directly contribute to wrecking their very own natural environment, narrow river valleys, and the economy in their back yards.

What happens if one of the 500,000-pound behemoth structures tumbles into the river as it is transported around a narrow curve in the highway? Would there be a way to extract it from the river? It seems not. There is no practical way to find the physical space to set up the required 45 ft. by 45 ft. concrete pad for a huge 500-ton crane to operate. What would be the cost in money and time to completely blocked highway traffic, the river itself, and the North Idaho economy if this were to happen? A complete evaluation will show that it would be a calamity. Judge Bradford noted that accidents would be "inevitable." The narrow and winding roads and small bridges on this two lane road in this deep, pristine North Idaho river canyon simply cannot accommodate the size and overwhelming structural and load bearing stresses of hundreds of loads of such large pieces of industrial equipment for an unknown number of years. Millions of dollars of highway and bridge wear, tear, and damage is a guaranteed byproduct for the Idaho taxpayers.

As the Governor of the state of Idaho your lawful responsibility is to protect the safety, economic health, and social and environmental well being of Idaho citizens. You have a responsibility to insure that all state and federal laws are adhered to. The 1968 Wild and Scenic Rivers act is one of those laws. We implore you to stand up for your Idaho constituents in rural northern Idaho. You should not appease huge international corporations at the expense of the ruination of the quality of life for north Idaho citizens (and neighboring Montana citizens) caused by the degradation of their backyard river/highway corridors. The Nez Perce Tribe has forcefully stated that "this would establish a dangerous and unacceptable precedent in one of the most beautiful and pristine federally protected corridors in the United States."

The 2000-member Idaho Chapter of the Sierra Club is therefore on public record as strongly opposing the proposal to ship gargantuan industrial loads up U.S. Highway 12. We urge you to take immediate action to protect the tourism economy, the wild river corridor environment, and the inherent quality of life of rural north central Idaho citizens. We urge you and the ITD to summarily disapprove any and all oversize permits for the proposed massive loads based on road and bridge engineering considerations, public safety, the fragility of the wild river corridors, state and federal laws, and common sense. That is clearly the prudent course of action to clear the air, do justice to an increasingly angry affected public, and end this offensive proposal. Barring that, a professionally done and comprehensive Environmental Impact Statement is absolutely necessary with thorough public hearings throughout Idaho.

We respectfully ask you and the IDT to do the right thing and deny all of the over-legal load permits.

Sincerely, Edwina Allen, Chair Idaho Chapter, Sierra Club

Copies: ITD Boise office, attn. Mr. Alan Frew ITD Lewiston Office, attn Mr. Doral Hoff Mr. David Hensley, Deputy Chief of Staff and Legal Counsel to the Governor

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