>>1174663those WERE designed for panniers. also a better example of front racks designed to mount on the bottom eyelet would be the older blackburn low-rider rack, or any front rack made by jandd or surly.
>>1174631 >>1174632using a longer m5 bolt, install your fenders close to the eyelets and then just enough washers/spacers (or even a hex nut) so that the legs of rack clear the fork. you won't want to put excessive weight on this setup because of the increased cantilever load on the eyelets, but it'll do.
if you do have a front rack that is meant to attach on the bottom eyelets without interfering with the fork, i suggest you get a long m5 bolt and, screwing it in from the inside of the fork, attach your fenders on the inside of the fork so you can install your rack as close to the mounts as possible and then secure the rack to this assembly with a hex nut.