19 KEY CONCERNS ABOUT THE PROPOSED MAD RABBIT TRAIL NETWORK
1. The high-volume trails built to attract tourists will have a significant impact on wildlife and habitat, specifically elk habitat.
2. Though branded as “multi-use” trails, these are largely trails designed for high volume mountain biking.
3. The proposed area for Mad Rabbit 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.
4. The previous development of the Buffalo Pass Trails Project has led to elk abandoning nearby areas, effectively leading to habitat loss for the E2 Bear’s Ear elk herd. This is reflected in the continuing population and recruitment decline of the GMU14 resident elk herd.
5. 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.
6. 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 CPW’s “Planning Trails with Wildlife in Mind.”
7. There are no maintenance or trail enforcement plans associated with the funding of the trails. This is essential for protecting wildlife.
8. The majority of the trails will be placed in Colorado Roadless Areas, a designation close to that of a wilderness area. There are numerous violations of the Colorado Roadless Rule presented by this project
9. 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, impacting local housing and 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.
10. The Forest Service only minimally evaluated less impactful alternatives, including placing trails on other already developed public lands or moving the trails outside of 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 CPW’s “Planning Trails with Wildlife in Mind.”
11. The dense set of proposed trails near US40 in the area known as Ferndale results in nearly 4 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 CPW’s “Planning Trails with Wildlife in Mind.”
12. The USFS has declined to perform the much needed EIS (Environmental Impact Statement) for a proper cumulative effect analysis for the area, stating it is relying on the 1998 Forest Plan instead. This plan is woefully out of date, and none of the trails included at Buffalo Pass or Mad Rabbit are mentioned in the 1998 plan.
13. 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.
14. The Forest Service proposes to close and rehabilitate 36 miles of illegally created trails to attempt to compensate for impacts associated with the new trail building. This is inappropriate for several reasons. First, the Forest Service has allowed unsanctioned trails to persist on forest lands in derogation of its administrative duties. Stepping up to do its job now should not be credited as “mitigation” for yet additional impacts of new trails construction. Second, it is arbitrary to make an equivalence between closing of undocumented trails with rare usage on one hand, and minimization of impacts from trails proposed for high-volume tourism on the other. This is not backed up by any research included in the EA; human disturbance to wildlife is dependent on the frequency and type of activity, not purely the length of a trail. The Forest Service has not performed any traffic analysis on either the trails proposed to be decommissioned, or on the newly proposed trails. Third, using the removal of illegally created trails as a mitigation allowing for new trails to be built creates perverse incentives for the unauthorized trail builders.
15. 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%), with the least chosen option (recreation is more Important than conservation) gathering only 3% of the respondents.
16. More human pressure on public lands will lead to deer and elk being pushed onto private agricultural lands, causing damage
17. 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.
When is enough enough?
18. We face unbalanced risks with the Mad Rabbit decision. We can always use a different trail, but habitat loss is forever.
19. There is value in wild places. Let’s keep Routt wild.
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