Mad Rabbit “Final” Environmental Assessment Published

As we predicted in July’s KRW newsletter, the Forest Service released the draft Decision Notice and Declaration of FONSI (Finding of No Significant Impact) for the Mad Rabbit Trails Project, a proposal to add approximately 49 miles of trails in Routt National Forest.

After reviewing the EA (Environmental Assessment), we have come to the unfortunate conclusion that the evaluation is deeply flawed, violates multiple aspects of NEPA (National Environmental Policy Act) and the Colorado Roadless Rule, and presents a grave threat to wildlife and wild places in Routt County. The flaws are too numerous to detail in this newsletter, but we will give a few examples in the articles below. The bottom line is that we believe the impacts necessitate preparation of an EIS (Environmental Impact Statement) that includes a more extensive evaluation of the project including consideration of the cumulative impacts from all activities in the project area.

The draft Final Decision triggers a 45-day objection period, where those who commented on the Mad Rabbit draft EA in late 2023 are eligible to object to the Forest Service’s decision. You can read the specific requirements to submit an objection here. We calculated that the deadline is September 25. You can submit your objection at the bottom of that page, and you can read those already submitted too. Objections can address process errors and errors of fact. Sadly, there are plenty of both. Merely saying you like or dislike the project will be insufficient to change a decision. The objections must be related to an issue you brought up earlier or based on new information. An example of new information may be the terrible death toll elk took this last winter and the relation of winter survival rates to summer range.

A recent article in the Steamboat Pilot itemized numerous changes to the Mad Rabbit project, reflecting those in the press release from the Forest Service. Many people thought these were changes since the draft EA was released last year. They are not.

Most of the changes mentioned were changes from hypothetical maps from 2018. The actual changes since last year’s draft EA were modest:
·       Trail #24, a 3.5 mile trail in the Ferndale area, was removed. Many other trails remain in Ferndale

·      A potential bypass trail around Long Lake was added.

·      A conditional elk calving closure for trail #14 was added.

·      All elk calving closures became contingent on average snow levels being less than 12”. (We have found no evidence in any literature that a 12” snow level deters elk from their calving areas. In fact, radio-collared data on Elk R190 shows a cow elk migrating 250 miles, and then crossing the continental divide in feet of snow to give birth.)

Astonishingly, there remains over 14 miles of trails traversing elk calving areas with no seasonal closures at all, though this was a major concern in the comments from supporters and opponents of Mad Rabbit alike.

We will be working with our legal team over the next few weeks to submit our own objections. Read the next two articles to see some of the issues we will be raising.

YOU CAN HELP

If you submitted Mad Rabbit comments last year, you are eligible to submit an objection letter.  In addition, please consider a donation to Keep Routt Wild at this pivotal moment. There are several ways to donate to Keep Routt Wild, documented here. We have a very capable legal team and are organizing a wide coalition of partners to object to Mad Rabbit in its present form. On this issue, we are literally the sentry that stands between this misguided project and Routt County wildlife. This does not come without cost. Your donation of any amount will help to preserve wildlife and wild places in Routt County. Thank you.

Mad Rabbit Evaluation is Technically Flawed

As we noted earlier, the Mad Rabbit evaluation is deeply flawed. Since the Final EA is largely unchanged from the draft EA, our comments from last year show many of the legal, procedural, and environmental analysis flaws of the final EA. You can read those comments here.

We’ll use this opportunity to show two examples of the flawed technical analysis. Both are from the Analysis Methodology chapter of the Terrestrial Wildlife section. A key paragraph states:

“Recommendations from Wisdom et al. (2018) were also followed to keep trail development within one mile of open roads to maintain habitat effectiveness within large, undisturbed blocks including habitats within the Long Park Colorado Roadless Area…. Wisdom and Johnson (2019) found this type of trail planning reduces habitat compression by maximizing large undisturbed areas with high habitat value.”

There's a big problem with the above. Neither publication says this. In fact, neither discusses the topic at all. There is no guidance in either publication about placing trails near roads or at what distance. We’ve linked the two studies referenced so you can read them for yourselves. Sadly, this paragraph lays the basis for much of the rest of the environmental evaluation, layering flaws on top of flaws.

Another major flaw in the environmental assessment occurs lower on the very same page and is related to Elk Habitat Effectiveness (EHE), a controversial issue with Mad Rabbit. This is a scientific term defined as the percentage of usable habitat during the nonhunting season. The Forest Service calculated the EHE and claimed there was no change due to Mad Rabbit. How could that be? The Forest Service used an obsolete model from 1983 that doesn’t take into account habitat loss from trails, only roads. Since there are no roads in Mad Rabbit, only trails, they claim there is no change to habitat effectiveness. They state, “There is no change in habitat effectiveness from the no action related to the Mad Rabbit proposal. Trails are not part of the calculation for habitat effectiveness.” 

You read that right. The Forest Service chose to use a model that doesn’t take into account the impact from trails to evaluate a project that consists entirely of trails. They justify this because they used it in 1998 when the Forest Plan was created. Ironically, Forest Service researchers have subsequently shown that this old model is inaccurate, even for roads, and have developed new models that can be used for roads and trails.

We could go on, and we will when we submit our objections. There are also significant flaws with respect to the finding of compliance with the Colorado Roadless Rule, and with respect to the Forest Service claiming credit for now fulfilling its management responsibilities to address illegal trails to mitigate for the new impacts of Mad Rabbit’s major recreational trail development. There are also a litany of process violations of NEPA. These are terrible precedents that could impact public lands across Colorado. We documented many of these in our comments last year, and we are disappointed that the Forest Service has decided not to address these in either the Final EA or in their response to comments.

LTE: Mad Rabbit Evaluation is Flawed, Requires an EIS

The following letter to the editor was submitted to the Steamboat Pilot.

The Forest Service recently released the draft Decision Notice and Declaration of a “Finding of No Significant Impact” (FONSI) for the Mad Rabbit Trails Project, a proposal to add approximately 49 miles of largely non-motorized trails in Routt National Forest. After reviewing the Environmental Assessment, Keep Routt Wild has come to the unfortunate conclusion that the evaluation is deeply flawed, violates multiple aspects of the National Environmental Policy Act and the Colorado Roadless Rule, and presents a grave threat to wildlife and wild places in Routt County.

“The project has the potential to set a precedent for future trail development in our state, in that a significant portion of the proposed new trail segments overlap with sensitive elk production areas mapped by CPW as high priority habitat (HPH), and nearly all are located within the boundary of a designated Colorado Roadless Area (CRA),” wrote Colorado Division of Natural Resources in a comment letter last year.

DNR added, “A more expansive environmental impact statement (EIS) would be better equipped to illuminate unforeseen possibilities for steering development away from areas of high biological and resources value, and avoiding conflict with other uses.”

We agree. Our own comments supported the legal requirement to perform an EIS. An EIS is a more expansive evaluation that would include the cumulative impacts in the entire project area, and would require consideration of other alternatives. By issuing a FONSI, the Forest Service seeks to avoid this evaluation.

The Forest Service seeks to justify its decision largely by including the rehabilitation of illegal trails as an offset for the impacts of Mad Rabbit. However, the Forest Service already has the authority and responsibility to do this. To do its job and retire seldom used illegal trails, as mitigation for building new high-use recreational ones, is simply wrong and sets bad precedent.

By ignoring the clear text of the Colorado Roadless Rule that “proposed actions that would significantly alter the undeveloped character of a Colorado Roadless Area require an EIS,” the proposal also sets a dangerous precedent, weakening the protection of 4.2 million acres of roadless areas in Colorado.

All this comes on top of a historic winterkill of local ungulates, who will lose more habitat. When is enough enough?

Routt County residents and wildlife deserve a comprehensive evaluation of Mad Rabbit. An EIS is the only way that will happen.

KRW joins Yampa Valley Sustainability Council for Wet Meadow Restoration in California Park

Photo credit: Yampa Valley Bugle.

KRW volunteers joined volunteers from Yampa Valley Sustainability Council, Colorado Crane Conservation Coalition, and others August 5 and 6 to aid in restoration work of wet meadows in California Park, a location north of Hayden in Routt National Forest. What a wonderful experience! We built one-rock dams and other structures, techniques developed by indigenous cultures and documented by Forest Service researcher Bill Zeedyk. It’s an innovative design technique that lets nature repair itself.  Read more about this unique restoration project at the Yampa Valley Bugle here.

Yampa Valley Crane Festival August 31 – September 3

Our friends from the Colorado Crane Conservation Coalition are presenting the 12th annual Yampa Valley Crane Festival in various locations across the Yampa Valley, including Steamboat Springs, Hayden, and Craig. If you like greater sandhill cranes (and we do!), the festival features guided crane-viewings, bird and nature walks, expert speakers, films, crane and bird art, children and family activities, and more! As usual, the festival occurs during fall staging- when cranes gather in large numbers in the fall to feed and gain energy for their migration south. We’re happy to spread the word about this great event. For more information and a schedule of events, click on the image below, or here.

Humorous KRW Facebook Post Gets 6 Million Views

We publish timely news articles on our Facebook page where we play dual roles as a celebrant of local wildlife and a conservation watchdog. We like to sprinkle our posts with a little humor now and then, as life is too short to be serious all the time. We spotted the photo below of some bears in a mountain stream and decided to caption it with some Routt County humor. The post went viral overnight. To date, the post has accumulated 162,000 reactions, been shared 55,000 times, received 2900 comments, and viewed over 6 million times.

What we’ve been reading and watching

(Click on any title to read the article.)

Routt County Commissioners table letter for $4 million grant over Brown Ranch regional park issue

“Down the street at the annexation committee meeting, several people, including Macys, spoke in public comment expressing concern over the proposed location of the regional park, citing impacts to wildlife specifically. Maps created during the

Ranch planning process show the area of the regional park is in a mule deer migration corridor, sand hill crane habitat, a Columbian sharp-tailed grouse production area and is partially in an elk production area.

 “Migration paths are key for the mule deer to move to the most productive habitats, whether winter or summer,” said Larry Desjardin with Keep Routt Wild during public comment. “When we encroach on these areas, we develop pinch points that constrain and impede migrations, further impacting the survival rates of mule deer. Pinching closed these migration corridors is a key component to today’s declining success of mule deer. This proposal will further exasperate this problem.””

BREAKING: Steamboat Council drops demand for regional park at Brown Ranch

“[The] parkland proposed drew the ire of local environmentalists noting it could have severe impacts on elk, mule deer, sage grouse, and other wildlife, and from the Routt County Commissioners, who would need to approve the park’s development plan, as the proposed location is beyond the urban growth boundary and is not being annexed.”

Scared bears and crowded camps: Weighing outdoor recreation’s impacts

“As Wyoming outdoor recreation grows in popularity, so do its impacts — ranging from rogue trails to littered landscapes and critter conflicts. 

Such anecdotes are nothing new. But now a growing body of research is supporting their validity. It underscores the challenges of managing landscapes for the benefits to users and communities while preserving the resource — and comes as the state is trying to define its approach to the burgeoning outdoor recreation economy and determine its criteria for granting outdoor recreation funds.”

CPW stresses being bear aware this fall as bears begin to pack on pounds for winter

“Twenty chicken sandwiches, 10 large orders of french fries, 10 soft drinks and 10 milkshakes is the approximate fast food order needed to total 20,000 calories. That is how many calories hyperphagia, an increase in feeding activity driven by biological need, drives a hungry black bear to consume every single day as they pack on the pounds to build up their fat reserves to survive the winter.

Quote of the Day