The Forest Service recently released the draft decision notice and declaration of a “finding of no significant impact” 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),” the Colorado Division of Natural Resources wrote 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.

Larry Desjardin
President of Keep Routt Wild