|
Routt County residents were not shy in objecting to Mad Rabbit. Pages of objections were filed with the Forest Service. We wish to thank the community for letting your voices be heard. We’ve posted all objections submitted by organizations on our website here. Scroll down to read the objections, both in opposition and in support. This page is the definitive summary of what’s going on with Mad Rabbit. We counted 25 organizations objecting to Mad Rabbit, and one in favor. Local Objections in Opposition to Mad Rabbit Keep Routt Wild objected to Mad Rabbit in a letter submitted by our legal team. The body of the objection was 22 pages, with over 100 pages of exhibits. We articulated seven critical deficiencies with the draft decision, including multiple violations of NEPA (National Environmental Policy Act) and the Colorado Roadless Rule. We further stated: “Because of these deficiencies, KRW objects to the FEA and draft FONSI. To comply with NEPA, Forest Service statutory and regulatory requirements, and the Colorado Roadless Rule, the Forest Service must withdraw the FEA and draft FONSI and defer decision on the Project while it prepares an environmental impact statement (EIS) or until a new Forest Plan has been adopted. An EIS is necessary to comprehensively analyze the cumulative impacts of the trail system and other developments in Steamboat Springs and surrounding lands and due to the significant effects of the proposed Mad Rabbit Project on the environment. The EIS must: afford detailed consideration to a reasonable range of alternatives, including an alternative akin to the compromise proposal that KRW has previously presented to the Forest Service, see Exhibit D; assume that current unauthorized trails will be closed, not as part of the Project or as mitigation for the Project; analyze the Project’s impacts using updated habitat models and disturbance buffers that are consistent with sound science and current knowledge; and otherwise comply with NEPA’s and other requirements for an EIS.”
KRW wasn’t the only local group to object. Other local objectors include: Routt County Cattlemen’s Association NWCO chapter of Great Old Broads for Wilderness Trappers Lake Sierra Club Friends of the Routt Backcountry These objections included some of the issues brought up by KRW, but also included others. For example, the Cattlemen brought up the issue that excessive recreational pressure on public lands will push wildlife onto nearby agricultural lands, with associated negative impacts. Objections from Governments and Agencies We reported earlier that the Routt County Commissioners unanimously objected to Mad Rabbit. They requested that the Forest Service perform an EIS (Environmental Impact Statement) and forward them any comments from CDOT regarding safety issues in the Ferndale region next to US40. Since that time, the State of Colorado, the Department of Natural Resources (DNR) and Division of Parks and Wildlife (CPW) objected to Mad Rabbit. You can read their letter here. We will highlight a few key passages:
“As DNR and CPW stated in Cooperating Agency meetings and previous comments, the analytical framework for analyzing direct, indirect, and cumulative adverse impacts on wildlife species and their habitats is outdated and not adequately supported by the cited literature.” (Page 3)
“The outdated methodology of wildlife habitat analysis is neither accurate nor comprehensive.” (Page 3) “CPW does not believe the Final EA adequately assesses the cumulative impacts of the proposed action. The Final EA does not meaningfully discuss the incremental effects of the proposed action when added to the effects of specific past, present, and reasonably foreseeable actions.” (Page 6) “…CPW has also stated in Cooperating Agency meetings that existing non-system trails are inconsistent with the current Forest Plan.” (Page 8) “DNR and CPW stress that non-system trails should be addressed by the Forest Service regardless of the outcome of the Mad Rabbit Trails Project Final EA decision.” (Page 8) It is important to note that the DNR letter does not formally request an EIS. Instead, it requests that “… the Forest Service revisit the body of the Final Mad Rabbit Trails Project Environmental Assessment to produce a defensible Finding of No Significant Impact (FONSI).” Other Conservation Groups Objections were filed by several state and regional conservation groups. These include:
Rocky Mountain Wild National Wildlife Federation Colorado Wildlife Federation Colorado Wildlife Conservation Project Rocky Mountain Elk Foundation Mule Deer Foundation Backcountry Hunters and Anglers Theodore Roosevelt Conservation Partnership …and many others! The reason Mad Rabbit is getting such widespread attention is that, if approved, it sets several precedents that will negatively impact wildlife and wildlife habitat across the state of Colorado. For example, 4.2 million acres of Colorado Roadless Areas could have their protections impaired if the Mad Rabbit EA becomes policy. A common theme to almost all objections was the observation that the Forest Service simply ignored public comments submitted last year regarding the draft EA. We recommend reading Mark and Marilyn McCaulley’s excellent Letter to the Editor from September 24. They point out how their clear citation of the Colorado Roadless Rule was not addressed in the draft final EA at all. “The Forest Service has not addressed this issue, they have ignored it, as they have ignored other clear NEPA requirements. This is clear if you read the submitted comments.” Objections in favor of Mad Rabbit As we noted above, one organization objected, but was in favor of Mad Rabbit. You can read the objection from Routt County Riders here or on our website. We don’t agree but we post this objection because we believe Routt County deserves to hear the full debate.
|
