Revised Mad Rabbit Trails Proposal by Forest Service Threatens Routt County’s Wildlife

Hello Keep Routt Wild followers,

Routt County wildlife needs your help!

The US Forest Service has just released the draft Environmental Assessment for the Mad Rabbit Trails Project. After initial review of the proposal it’s abundantly clear that the Forest Service has chosen to disregard KRW recommendations by proposing a project that seriously threatens our local wildlife population, putting our elk herd and other wildlife in jeopardy.  The revised proposal unduly compromises the solitude and natural character of important wild areas in the Yampa Valley. We are disappointed that our federal land managers have overlooked the public opposition to this proposal.

Keep Routt Wild has consistently promoted a compromise proposal that would have led to increased recreational opportunities while minimizing the impact to wildlife and wild places, such as the Long Park Roadless Area, where much of the project remains targeted. Instead of adopting these reasonable alternatives, the Forest Service has proposed a project that prioritizes recreation over conservation, in contradiction to the overwhelming majority of Routt County residents recently surveyed and the recently released Routt County Master Plan.

However, you can make a difference. For the next 30 days you can officially comment on the plan and write your local representatives.

You can comment to the US Forest Service here:
https://cara.fs2c.usda.gov/Public//CommentInput?Project=50917

You can write or copy our County Commissioners, CPW officials, Steamboat Springs City Council and Staff, and others. Their emails are here:
https://www.keeprouttwild.com/your-voice

You can write a Letter to the Editor here:

https://www.steamboatpilot.com/opinion/letter-to-the-editor/

You can also attend a US Forest Service presentation from 5:30pm to 7:30pm on Thursday, Oct. 27, at Colorado Mountain College in Steamboat Springs on the second floor of the Academic Center building. Forest Service staff will provide information and answer questions. The in-person event will also have a virtual option at the project website at http://www.fs.usda.gov/project/?project=50917&exp=overview.

We have summarized major issues regarding Mad Rabbit in the section below.

Quick Summary of the Mad Rabbit Trails Project

The draft Mad Rabbit Trails Project comprises 52 miles of non-motorized and motorized trails near Rabbit Ears Pass, with many of the trails located in the Long Park Roadless Area. We believe that going forward with the project as described would be harmful to local wildlife, the Long Park Roadless Area, and would violate NEPA and Colorado Roadless Area processes. The Mad Rabbit Trails Project is situated in the habitat of the E-2 Bear’s Ear elk herd, the second largest elk herd in Colorado, making it the second largest in the world. The proposal represents a serious threat to the long-term prospects of this elk herd, other wildlife that is sensitive to human disturbance, and the undeveloped characteristics of the Long Park Roadless Area.

In particular:

• The Mad Rabbit Trails Project is described in Forest Service documents as the second phase of a comprehensive trails system, following the earlier Buffalo Pass Trails Project. Splitting up a single project into phases to be evaluated on a piece-meal basis violates NEPA processes and is designed to circumvent preparation of a full Environmental Impact Statement (EIS) containing a programmatic NEPA evaluation and proper cumulative analysis.

• The project is part of an overall trails proposal explicitly designed to attract 180,000 incremental summer visitors to the Steamboat area, each staying on average over 4 nights. Many of the planned trails are in a Colorado Roadless Area. Prorating for the portion of the project represented by the Mad Rabbit Trails Project adds over 1700 summer visitors per day, increasing the density of users on the entire trail network. The Colorado Roadless Rule is clear: “Proposed actions that would significantly alter the undeveloped character of a Colorado Roadless Area require an Environmental Impact Statement (EIS).” Yet, despite the explicitly stated purpose of attracting a huge number of tourists, no EIS is planned.

• Analysis of the predicted incremental visitor numbers, along with actual trail counter data from nearby Buffalo Pass trails, indicates that Mad Rabbit trails will exceed semi-primitive recreation volume densities articulated as a roadless characteristic in the Colorado Roadless Rule. Solitude is explicitly listed as a roadless characteristic for the Long Park Roadless Area, and this project would significantly impact that characteristic.

• The Forest Service only minimally evaluated less impactful alternatives, including placing trails on other already developed public lands or moving the trails outside of species calving areas and summer range, or to the south of US 40. All of these alternatives were brought to the US Forest Service’s attention. Not considering these alternatives violates the guidelines regarding alternatives put forth in Colorado’s “Planning Trails with Wildlife in Mind.”

• The USFS has declined to perform the much needed EIS for a proper programmatic review and cumulative effect analysis for the area, stating it is relying on the 1998 Forest Plan instead. That plan is woefully out of date, and none of the trails included at Buffalo Pass or Mad Rabbit are mentioned in the 1998 plan.

• Wildlife watching and big game hunting together bring in over $3B of economic activity to Colorado each year. Both activities will be negatively impacted by the proposed trail system. Due in part from previous recreational trails in the area, elk hunting in GMU14 has recently been limited in face of declining population numbers and calf/cow ratio.

• Due to many of the above issues, community opinion in Steamboat Springs and Routt County has shifted decidedly against this project. A recent survey of Routt County residents showed overwhelming support for a balanced approach to recreation and conservation (>70%). The least chosen option (“recreation is more Important than conservation”) gathered only 3% of the respondents. See graphic below.

• The area in question has already seen deleterious impacts from previous recreation development in the area. The resident elk population of GMU14 has declined from approximately 750 to 500 individuals from 2006 to 2019. Over the same period, the calf/cow ratio has decreased 42% from 0.64 to 0.37 calves/cow elk. This critical metric shows the precarious situation of the local elk herd.

• The proposal specifies the development of new mountain bike trails in elk calving areas and elk summer concentration areas. Scientific peer-reviewed studies have shown trail-based recreation can cause disturbance to elk up to 1500 meters away, leading to habitat loss, compression, and fragmentation.

• There are 21 miles of proposed Mad Rabbit trails in acknowledged elk calving areas that will have no seasonal closures at all. Peer reviewed research has shown a 5% probability of mortality of an elk calf each time it is disturbed, which can occur as far as 1500 meters away from mountain biking activity. Not placing seasonal restrictions on elk production areas explicitly violates Colorado’s “Planning Trails with Wildlife in Mind.”

• The previous development of the Buffalo Pass Trails Project has led to elk abandoning nearby areas, effectively leading to habitat loss for the E2 herd. This is reflected in the continuing population and recruitment decline of the GMU14 resident elk herd.

• The dense set of proposed trails near US40 in the area known as Ferndale results in over 3 linear miles of trails per square mile of elk habitat, violating the 1 linear mile of trail per square mile of habitat metric specified in Colorado’s “Planning Trails with Wildlife in Mind.”

• The Steamboat Chamber of Commerce publicizes “Steamboat is one of America’s premier mountain biking meccas with more than 500 miles of singletrack bike trails that wander through meadows flecked with wildflowers and twist around aspen groves.” With such a large existing local trails network, there is not an urgent need to develop trails in currently undeveloped areas of Routt National Forest.

• The Forest Service justifies many of the trails by being withing one mile of US40, saying much of that area is already disturbed. There is no evidence presented in the EA of this large buffer to open roads, and the studies referenced in the EA as justification never examined open roads. Actual research on disturbance due to open roads show disturbance bands ranging from ¼ mile to ½ mile.

This is an ill-conceived project that presents severe impact to local wildlife in an area already subject to intense recreation pressures. At the very minimum, the Forest Service should prepare an Environmental Impact Statement that includes the entire region between Mount Zirkel Wilderness and Sarvis Creek Wilderness areas to appraise the cumulative impacts of all recent projects in the region. This would include the previously constructed trails in the Buffalo Pass area, recent ski area expansion, and proposed road improvement projects. Barring this, the project should be halted.

Routt County residents are very concerned about our public lands, as can be seen in this survey question taken earlier this year. The Forest Service is simply not listening to Routt County residents who want to conserve our public lands and want a more balanced approach to recreation developments.

Denver Post: “Colorado’s world-class elk herd in bull’s-eye of outdoor recreation boom, report warns”

We’ve included this excellent front page Denver Post article from our recent newsletter highlighting the threat industrial strength recreation is placing on Colorado’s elk herds.

“Elk seem particularly like a canary in a coal mine for trail-based disturbance. They seem particularly sensitive to trail use,” said Holst, a wildlife biologist formerly with Colorado Parks and Wildlife.

“If we didn’t have this iconic, world-renowned resource, we’ve lost something, something that makes Colorado Colorado.”

That’s just a few of the gems in an excellent front page article by Denver Post reporter Judith Kohler. The Theodore Roosevelt Conservation Partnership (TRCP) spearheaded a trail disturbance study of the entire state of Colorado and found that nearly 40% of current elk habitat is being impacted by trail-based recreation. We independently reviewed the TRCP methodology and found it valid. In fact, the study’s trail disturbance distances match our own to the meter. We are happy to see a scientific consensus forming about how industrial strength recreation is impacting elk habitat.

You can read the Denver Post story here:

https://www.denverpost.com/2022/10/04/colorado-elk-herd-outdoor-recreation-mountain-biking/