CAL Comments to
GMP Newsletter #3
October 2006

Meetings:

CAL Annual Meeting:

Monday, July 16, 2007
7 pm
Lake Township Hall

Additional Comments From This Meeting

(on M-22 south of Esch Rd and just north of Riverside Canoe Livery)

View a map showing
the 1981
Proposed Wilderness Areas

CAL Comments on the National Park Service
October 2006 Newsletter # 3 on new GMP/Wilderness Study

NPS Question One: After reading over the draft management zones, do these zones cover the range of experiences and conditions you would hope to find at the National Lakeshore?  If not, why not?

CAL’s Response: 
The five zones described are useful.  However, CAL respectfully suggests two of the zone names give a somewhat misleading characterization.  While “High Use”, “Experience History” and “Administrative” Zone names speak simply and factually, Recreation” and “Natural” do not.  All five zone names are classified on that’s zone’s usage except for “Natural”, so that name is not in context with the others.  We recommend calling a spade a spade: the second sentence in the narrative for the “Natural” zone describes it succinctly:  “Visitors enjoy primitive recreation on foot or in human-powered watercraft.”  This zone would be named Primitive in any other NPS document.  Primitive speaks to its usage while “Natural” implies that only in this zone would things be left “natural”, which, of course, is untrue.  The same applies to the zone named “Recreation”.  Per the statutory purpose of the Park, “recreation” is not limited to just one area of the Park.  As Park Service personnel have pointed out numerous times, “recreation” refers to any reason a visitor might come to the Park, including Wilderness areas limited to hardy visitors and pristine vistas protected but viewed from lookouts.  It is all “recreation,” so calling one zone “recreation” defeats Park Service personnel’s point on this issue.  Hiking in a “natural” or wilderness area is “recreation” as much as swimming at a beach accessed by automobile, so naming one zone “natural” and another zone “recreation” is not useful.  In keeping with the “usage” classification, CAL suggests the name “Range of Experiences” zone better characterizes the actual NPS narrative describing the “recreation” zone.  As for the zones themselves, at least one use (or one “zone”) that the Lakeshore was supposed to provide is lacking:  boating on Lake Michigan.  In 1970, the federal government was given authority over 35 miles of prime Lake Michigan shoreline plus more around the two Manitou Islands; nowhere was it contemplated that the Park Service would go against the wishes of the State of Michigan at the time and prevent the development of a safe harbor or safe launching site along all that shoreline.
 

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NPS Question Two:  After reading over the four alternative management concepts, are there certain aspects or elements of the alternatives that you particularly like or dislike?  Briefly explain why.

CAL’s Response: 

“No Action Concept”:  Since it is posited as a possibility that the current GMP may simply remain, the same language about county roads should be included here, for clarification, that is included under the second Alternative, so that all would understand what would happen if the No Action Alternative was adopted.  The NPS language is: “…the NPS works with the counties to see if any little-used county roads could eventually be closed.  If and when the counties elected to vacate these roads rights-of-ways, the roads could be considered for other uses, such as trails or natural areas.  (The counties control county road rights-of-way within the National Lakeshore, so this decision rests with them.”)  

“Resource Enjoyment Concept”:  This “concept” is a carefully worded remake of the 2002 withdrawn GMP.  Items in the 2002 GMP under state or county jurisdiction were removed, but the 2002 inconsistency with federal law remains.  According to this proposed Alternative’s “Overall Vision”, the Park is a “resource reserve valued primarily for its publicly owned resources that are conserved for the future”.  This “vision” is to convert the Park into a “reserve”.  Such a vision is inconsistent with the statutory purpose of the Park:  “Congress established Sleeping Bear Dunes National Lakeshore to preserve outstanding natural features, including forests, beaches, dune formations, and ancient glacial phenomena in their natural setting, and protect them from developments and uses that would destroy the scenic beauty and natural character of the area, for the benefit, inspiration, education, recreation, and enjoyment of the public.”   (Sources: 1970 Public Law 91-479 and NPS May 2006 Newsletter 2)

 The law is absolutely clear that all the preservation, protection and “resource conditions” are to be managed “for the benefit, inspiration, education, recreation, and enjoyment of the public” – not some undefined “future” but for the “public” – not just the hardy public, but the general public, and not just the “future” public, but the current and future public.  In addition, the law is absolutely clear that the federal government was authorized in 1970 to begin purchasing properties in this area for the establishment of a “National Lakeshore”.  The Lakeshores in the 1970’s were created in order to carve out and protect from private development certain areas for public access and public enjoyment along certain lakeshores.  Congress did not create “reserves”; it created “Lakeshores”, and these areas were intentionally named Lakeshores rather than National Parks to emphasize the intent that public access to and enjoyment of the beaches, water and entire terrain would be given even greater emphasis than in “National Parks.  If Congress had intended to make Lakeshores into “reserves”, the legislation would have so stipulated and the Lakeshores would have been named “Reserves”.   Nowhere in this Lakeshore’s enabling legislation did Congress state that the area is to be a “reserve”.  Further, the concept of this Lakeshore as a “reserve” is inconsistent with the Park Service’s own “purpose, significance statements” and “primary interpretive themes” in May Newsletter 2.  While there are, indeed, a few national advocacy organizations who desire the entire continent to be a free-to-roam wildlife corridor with the human population herded into concentrated living areas, and all public lands made into “reserves” for a theoretical and undefined “future,” those advocates have not yet been successful in getting Congress to so revise the nation’s private and public property laws.  Such advocates also heavily lobby the agencies of the federal government responsible for managing public lands.  Advocates may advocate for anything they like, but federal agencies like the Park Service have no authority to propose in a GMP process, much less implement, anything inconsistent with statute, regardless of who advocates for such. 

CAL also suggests the following sentence would give anyone who has not visited the Park or the region a false impression:  “The National Lakeshore is in strong contrast with surrounding lands that are becoming increasingly developed.”  In truth, the economic lifeblood of the entire region is tourism of its wild and natural features, and such is actively protected and supported by both state and local government.  “Surrounding lands” in Benzie and Leelanau Counties are hardly wastelands of any kind, but in truth contain numerous scenic roads, lookouts, vistas, beaches, woods, lakes and wildlife.  Development is mainly limited to residential, orchards and wineries in ways that fit in with the surrounding countryside, and the region’s occupants take an active role in protecting and conserving the habitat through many lake associations and other volunteer groups.  For those readers of this GMP who will comment without ever having visited the region, the sentence quoted above raises false alarm that the federal Park is the only entity in the region protecting and conserving a wild and natural setting.  Regarding historical and cultural resources, the sentence “those in the natural zone may be left to nature’s forces” is reminiscent of the controversial 2002 GMP’s proposal to let such “molder”.

In addition, the following passage gives two messages:  “To increase opportunities to enjoy naturalness yet maintain plenty of vehicle access, the NPS works with the counties to see if any little-used county roads could eventually be closed.  If and when the counties elected to vacate these roads rights-of-ways, the roads could be considered for other uses, such as trails or natural areas.  (The counties control county road rights-of-way within the National Lakeshore, so this decision rests with them.)”  The two messages are that:  While the Park Service does not have authority to close county roads on its own, the Park Service would cancel its current temporary moratorium and actively resume lobbying the Counties for eventual closure of some or all roads.  CAL opposes resumption of such lobbying.
In Conclusion:  A more forthright name for this remake of the withdrawn 2002 GMP would be:  Limited Public Usage: Selected Native Species Reserve.  The Park Service would be well served to communicate immediately its withdrawal of this “Alternative Management Concept”.

“Recreation Enjoyment Concept”:   The language of this Concept’s “Overall Vision” is appropriate throughout the Park, because those seeking “solitude” in a “primitive” setting are “recreating” as much as those swimming at the beach or those doing a historical tour.  The language of the ‘Concept Description” could also satisfy a diverse array of uses, from the most primitive to the “highest” use.  The relative proportions given to the different “zones” is also consistent with and appropriate to the purpose and significance statements and primary interpretive themes listed in Newsletter 2.  However, since the term “recreation” is being used here (CAL believes inappropriately) to attempt to distinguish “recreators” as different or perhaps less noble or pristine from users who want a “primitive” experience, CAL suggests a different, less ideologically tainted name for this “Concept”, perhaps “Multi-Use”.  More development of this “Concept” is needed, especially to clarify that just because county roads would be left open, and people would be made to feel welcome throughout the Park, the “natural” setting would remain in most of the acreage, as it always has been since inception, and to clarify that there is nothing to prevent any visitor from finding an abundance of “solitude” and “quiet” in most areas of the Park.   As for water access, CAL is glad to see the sentence “Access to inland waters is improved”, but noticeably absent is any reference to the issue of access to Lake Michigan, whether from land or water.  This absence is of extreme concern to CAL. 

“Contentrated Use Concept”: 

o        This “Overall Vision” is “managed primarily to achieve two different sets of visitor experiences and resource conditions”.  CAL response:  Good attempt to meet most desires, but CAL has some concerns.

o        ”For one set, certain areas of the Lakeshore are identified and managed for developed facilities, more structured recreational opportunities, and high levels of visitor use.”  CAL response:  No one should have a problem with this, depending on the number and amount of areas “identified”. 

o        “For the second set of experiences and conditions, most other areas of the Lakeshore are managed for more natural, primitive conditions, and lower use levels.”  CAL response:  This has been the way it has been managed for decades and would meet most people’s desires to have things remain much the same. 

o        “In these (natural, primitive) areas, cultural resources are generally preserved, but those in the natural zone may be left to nature’s forces.”  CAL response:  Without more specifics, CAL is not ready to comment. 

o        “To increase opportunities to enjoy naturalness in these low-use areas, yet maintain plenty of vehicle access, the NPS works with the counties to see if any little-used county roads could eventually be closed.  If and when the counties elected to vacate these road rights-of-way, the roads would be considered for other uses, such as trails or natural areas.  (The counties control road rights-of-way within the National Lakeshore, so this decision rests with them.)”  CAL response:  The two messages are that:  While the Park Service does not have authority to close county roads on its own, the Park Service would cancel its current temporary moratorium and actively resume lobbying the Counties for eventual closure of some or all roads.  CAL opposes resumption of such lobbying. 

o        “Access to inland waters is improved”.  CAL response:  CAL is glad to see improved inland water access, but noticeably absent is any reference to the issue of access to Lake Michigan, whether from land or water.  This absence is of extreme concern.

CAL Summary on the NPS proposed “Alternative Management Concepts”: 

1.       Concept 1 needs explanation about the county roads.

2.       Concept 2 should be immediately withdrawn because it is inconsistent with the Park’s enabling legislation and this GMP’s purpose, significance statements and primary interpretive themes. 

3.       Concept 3 needs further development and its name is misleading.

4.       Concept 4 appears to be an attempt to meet most desires, but CAL has some concerns.   

NPS Question Three:  After reading over the desired conditions for Sleeping Bear Dunes National Lakeshore, do you agree with them?  If not, why not? 

CAL's Response: 
CAL generally agrees with the four-page, 21-item list of “desired conditions” with one large caveat.  The condition itemized as “Natural Resources (General) and Diversity” is full of broad, sweeping language similar to the 2002 withdrawn GMP that sought the impossibility of “restoring” the Park’s flora and fauna to a “pre-European” condition.   Further, some of its language is inconsistent with the language of the different condition called “Ecosystem Management”, which rightly states that the Park Service will see to it that “The resources and processes of the Lakeshore (will) retain a significant degree of ecological integrity.  Natural wind, sand and water processes (will) function as unimpeded as possible…” In contrast, the “Natural Resources and Diversity” condition predicates over and over that attempts will be
made to interfere with naturally occurring biological and botanical processes in order to “restore” various species.  Threatened and endangered species justly receive protection by law, but for the Park Service to attempt the restoration of whatever Staff may deem “biologically diverse native communities” gives Staff carte blanche to do almost anything.  Such sweeping language would allow the Park Service to remove what may have thrived here for untold numbers of years, even centuries, so as to replace such with species that may have changed themselves by now.  CAL is concerned about language that could lead to removal and destruction of current species in the name of pseudo-science that might thwart ecological processes and destroy rather than preserve the Park’s natural flora and fauna.  Language such as “particularly sensitive communities” and “endemic species and habitats” makes almost anything applicable for Park Service “protection” and restoration”, depending on the ideological bent of the various Superintendents the Park may have over the next twenty years.   Paragraph 2 on page 9 is highly reminiscent, although more subtle, of the previously withdrawn 2002 GMP that proposed killing the entire deer herd on North Manitou Island and terminating the State of Michigan’s fish hatchery on the Platte River, among other things.  CAL respectfully requests the Park Service to remove such broad, sweeping language so that the GMP does not in any way authorize a destruction of the Park’s resources in the name of pre-European zealotry.  CAL recommends replacing paragraph 2 on page 9 with the following:  Threatened and endangered species are protected in full accordance with applicable statute.  In addition, where practicable and not unduly disruptive of naturally occurring ecological processes, native and endemic species are encouraged with the exception of those producing harmful effects, such as ticks carrying Lyme disease, poison ivy, mosquitoes, black flies, etc.
 

NPS Question Four:  What factors do you think the National Park Service should consider when the time comes to select or develop a preferred alternative? 

CAL's Response: 

1.       Does the preferred alternative restate and fully incorporate the statutory purpose of the Park?

2.       Does the preferred alternative restate and fully incorporate the “significance statements” and “primary interpretive themes” presented in the May 2006 Newsletter 2?

3.       Will implementation of the proposed Alternative meet in spirit and content the statutory purpose of the Park, that is, preserve and protect the resources “for the benefit, inspiration, education, recreation, and enjoyment of the public”?

4.       Will implementation of the proposed Alternative meet in spirit and content the “significance statements” and “primary interpretive themes” presented in the May 2006 NPS Newsletter 2?

5.       Will implementation be well received by the local populace in Benzie and Leelanau Counties, who know and love the Park the best, are among its most frequent visitors, and, because tourism is the economic lifeblood of both counties, are highly attuned to the needs and desires of the Park’s national and international constituency?

6.       Will implementation allow reasonable usage and access to all members of the public?

7.       Will implementation provide numerous and diverse opportunities for a wide range of visitation experiences?

8.       Will implementation continue to provide the vast array of opportunities for solitude, quiet and challenging experiences already available within the Park without infringing on the rights of the general public to access and enjoy the Park as well?

9.       Does the preferred alternative express accurately and fairly the public input received during the GMP process? 

Additional Comments by CAL on Newsletter 3: 

(1)  1981 Wilderness Boundaries likely to remain:  Newsletter 3 does not sufficiently explain that   the 1981 Wilderness Recommendation’s boundaries will remain, despite all the work on this GMP, unless and until Congress passes a new law that changes the 1981 wilderness boundaries.  While Newsletter 3 states on page 8 that the Park Service will prepare a wilderness “proposal for consideration”, the Newsletter does not make clear that the proposal will likely sit on a shelf and not be implemented, since Congress is unlikely to take up any wilderness proposal that changes the 1981 boundaries, given the history and growth of an entire wilderness bureaucracy and the political power of its national advocacy organizations, all of whom would likely voice major opposition to any change except an increase to the Park’s current, half-the-Park, “de facto” wilderness acreage.                                                             

(2)  Benzie Corridor:  CAL applauds the NPS Planning Team for reminding the public in this GMP that a major undeveloped and partially acquired land mass still exists within the Park boundary set in the Park’s enabling legislation.  We applaud the Park Service for mentioning all the possible choices:  continued acquisition and then development of a scenic road or trail, or cessation of acquisition followed by no development.  While road or trail development would seem to be a favorable access issue for CAL, the foot or vehicle access would not be to currently acquired Park land nor would the scenic view be mainly of Park lands, but of private and other non-federal holdings.  The Corridor is a narrow strip of land on part of the ridge line overlooking Crystal Lake, the two Platte Lakes and other inland non-federal lakes, and looks over much woods, meadows and residences of private holdings. 
                                    
In addition, the strip is close to, but outside the greater mass of the federal Lakeshore; most of its boundary is not adjacent to the Park, but rather to private holdings.  It is unclear how a visitor to the strip, if developed, would be able to distinguish the fact that private property exists between this strip and the rest of the national Park.  While CAL believes many of its members would make use of a scenic road or trail, if developed, CAL also believes environmental and economic impact studies on each scenario are greatly needed before informed decisions for or against development can be made or before informed public input can even be produced.

It is our understanding that the intent at the time of the 1970 enabling legislation was that two scenic roads would be developed:  One around Glen Lake to mark a northern entrance to the Park, and one on a ridgeline overlooking Crystal Lake to mark a southern entrance.  However, in 1982, the Glen Lake scenic roadway project was terminated when Congress took that area out of the Park boundary.  Also, the Pierce Stocking Scenic Drive was developed, first by the owner of the property prior to Park acquisition of his land, and later the road was paved and other improvements made by the Park Service, resulting in a major scenic road in the middle of the Park rather than at the two ends.  Thirty-six years after the 1970 enabling legislation, many have forgotten that the undeveloped Benzie Corridor still sits on a ridge line within a Park boundary line that itself sits mostly outside the main Park.  Because this area has not been developed in all that time, some seem to have assumed the issue moot and are unaware the Park Service has been quietly acquiring properties from willing sellers. 

Environmental Impact Assessments Needed:  The area includes orchard lands that were farmed and fertilized for many years; some CAL members have expressed concern about possible agricultural run-off into surrounding lakes and watersheds from construction and use of a roadway or trail this size.  Members have also expressed a concern about the possible visual impact to the ridgeline by a road or trail and its scenic turn-offs.  Other citizens have opined to CAL that Park development would be preferable, environmentally, to the properties remaining in private hands with future development regulated only by the power of local zoning. 

Economic Impact Assessments Needed:   Just outside the Park, with a Trailhead Building just opened this summer in Beulah, has been the development of the non-federal Betsie River Trail along former railroad tracks in Benzie County.  The Trail has been a positive tourist development, as well as another resource for local folks to enjoy.  It is unknown if another trail or scenic road in the immediate vicinity would be economically beneficial or superfluous.  More tourist dollars might or might not result to Beulah and nearby towns.  At the same time, the long term property tax revenue consequences of continued removal (or not) of valuable private properties off the tax rolls of the affected local governments, school district and county government, and any long term tax consequences to remaining taxpayers, are also unknown and unstudied.  Without concrete development plans and accompanying environmental and economic assessments for each scenario that the Park Service proposes, CAL does not believe informed public input can result.

All these issues, in CAL’s view, need thorough examination before a decision on such becomes ensconced in this GMP.  At the conclusion of such studies, CAL would most likely support the positions taken for or against development by the duly elected officials of the most directly affected governmental bodies.  CAL hopes the Park Service will begin well-publicized environmental and economic assessment processes before advancing towards any further decisions on this major issue.  CAL also hopes that, before a Park Service decision is made, the directly affected governmental bodies would provide formal Resolutions expressing their desires for or against continued property purchasing and for or against development of a scenic road or trail.  Finally, CAL hopes that such Resolutions will be given significant weight in the Park Service’s decision regarding the future of the Benzie Corridor.

(3)  Characterization of Public Input:  CAL respectfully takes exception to a small part of Newsletter 3’s characterization of input received to date, e.g.,:  “…on one end of the spectrum, some individuals preferred that the National Lakeshore be totally wild (no facilities, all historic structures removed, etc.).  On the other end of the spectrum, we heard from people who believe wild areas are of little value.”  CAL respectfully requests to know who have actually provided statements saying they believed “wild areas are of little value”.  CAL cannot fathom anyone visiting the Lakeshore who did not expect to find, and highly value, some completely wild areas and an additional profusion of very natural settings.  As for CAL itself, CAL has many members who do not believe that Wilderness Act’s sanctions are appropriate at this Lakeshore, but who fight as hard as any Wilderness-Act advocate to retain the “wild” and natural character of the Lakeshore.  It is the management policy that has various adherents, but CAL believes the “value” of “wild areas” is treasured by all.       

(4)  Dialogue:  CAL applauds the Park Service for hosting dialogue among the varied interests, giving everyone opportunity to see the interests the Park Service is expected to meet.   We applaud Superintendent Dusty Shultz and Assistant Superintendent Tom Ulrich for holding the June 2006 Public Workshops, which was an extra and expensive step for the Park Service in the GMP process.   CAL believes the Workshops were helpful to those who attended.

Dialogue on Automobile Access:  During off-the-cuff discussions at the Workshops and other venues, it was enlightening to hear some attendees express passionately held, but distorted views of CAL’s goals, as if CAL wanted automobiles on the walking trails or more asphalt laid everywhere, which, of course, is nonsense.  CAL’s desire that the few existing county roads remain accessible by car will hardly extend, accentuate or increase the already limited automobile presence.  It was also enlightening to hear individuals passionately argue that the challenges of a wilderness setting should be available, while in the same breath argue just as passionately that such “challenges” should be conveniently accessible by car at numerous points on the mainland, revealing that a ferry ride to North Manitou Island does not add to the desired challenge and adventure but, instead, is too inconvenient. Some who voice great dislike for motorized access actually want a continued convenient auto access to the woods and trailheads themselves.  In addition, some of the most passionate theorists revealed little or no exposure to the few county roads in the Park in Benzie County (most of them dirt two-tracks that function as both walking trails and for occasional slow-speed auto traffic), and had never attempted access to the Giant Cedars on South Manitou Island.  It was also enlightening to hear individuals passionately argue that an experience in “wilderness” ought to include the joy of happening upon historical cabins or other evidence of prior human occupation that are unreachable except by foot, despite what such lack of access to these treasures would mean for the general public.  The undisputable reality is that, whether the destination is the beginning of a hiking trail or a walk through the woods or a visit to the beach or a launch of canoes, all want convenient auto access with easy driving distance to begin their experience: 

Dialogue On Quiet and Solitude:  CAL also has heard passionate pleas for the experience of quiet and solitude, but, as such is obviously abundant throughout major areas of the Park even during the July and August visitation peaks, we respectfully inquire what, exactly, is the problem?  In almost 40 years of existence, the thirteen interesting and varied trails on the mainland and more on the Islands have never, to CAL’s knowledge, been utilized remotely near their capacity.  One need only check the trailhead parking areas or actually take a hike to see how few visitors are actually on the trails at any time.  And at the few access points to the shoreline, one hears the wind and the waves much more than any fellow visitors to the beach.  Even at the “high use” area of the Dune Climb, where one should expect to see fellow visitors rather than experience solitude, would one classify the sounds of people laughing and climbing in the sand and taking photographs as offensive?  Besides these realities, ten months of the year the Park is virtually deserted.  CAL members also highly value quiet and solitude but recognize that it exists abundantly throughout most of the Park, and always will, thanks to the weather.   

Opinions by Non-Visitors:  For advocates of the “Wilderness Act” who never or rarely visit the Park, or who do not go to the many areas of acreage offering quiet and solitude, there is not much hope of real dialogue, as their opinions are not formed nor supported by facts on the ground here at this Lakeshore.  While they may comprise some of a vocal component of the “national constituency” who lobby the National Park Service for acquiescence to their ideologies, the genuine “national constituency” of Sleeping Bear Dunes National Lakeshore is comprised of those who actually visit.

In conclusion, CAL does not presume to have the expertise of the many fine NPS personnel we have met over the years and who bear the burden of responsibility for managing the Lakeshore.  We are grateful for the many requests to the public for input.  In that spirit, we respectfully offer a draft Alternative Management Concept we believe would meet the needs, desires and interests of those who actually visit or plan to visit this particular Lakeshore.  We have attempted to combine the best, in our view, of the Concepts proposed in NPS Newsletter 3, and we respectfully provide other ideas for your consideration.  Much of the following language is taken directly from NPS language already proposed.  We have faith the NPS Planning Team will evaluate these Comments for any merit they may have.  We respectfully ask other parties interested in the GMP to give consideration to our points of view in the same good faith and honest effort with which they are offered. 

CAL Proposed Alternative Management Concept

Name:  Preservation for Enjoyment

Overall Vision: To “preserve outstanding natural features, including forests, beaches, dune formations, and ancient glacial phenomena in their natural setting, and protect them from developments and uses that would destroy the scenic beauty and natural character of the area, for the benefit, inspiration, education, recreation, and enjoyment of the public.”   (See enabling legislation).

Concept Description:  Natural resources are protected and historical features are protected and preserved for the enjoyment of the public.  Wherever possible without impeding visitor safety or resource protection, natural conditions and ecological processes shall remain unfettered.  Fundamental cultural resources (i.e., Port Oneida, Glen Haven, and three life saving service stations/South Manitou Light Station) are preserved and actively interpreted; other cultural resources are generally preserved, but emphasis is given to historic resources that are well suited for visitor or other park uses.  Diverse options for visitors are improved and expanded.  New trails (bicycling, hiking, backpacking, horseback riding, skiing, snowshoeing) and backcountry camping options are provided.  Scenic driving options are retained and selected trailhead, parking and picnic areas are upgraded.  Opportunities for experiencing solitude and natural quiet will continue to abound.  Access to inland waters is improved.  Access to Lake Michigan, both to and from the water, is improved and expanded, including development of an appropriately placed safe harbor/boat launch on the mainland.  One of the Park’s most valuable natural features, the Giant Cedars on South Manitou Island, will be accessible to the general public via a stop on the once-daily tour of the Island’s tour concessionaire, and will remain exclusively available the rest of the day and night to hikers and back-country campers who stay on the Island overnight.  In general, existing roads (NPS-owned and other) remain open.  In areas deemed “High Use” zones, facilities such as trails, parking, bathrooms, and picnic areas will be reviewed and improved and/or increased in number where appropriate.  Some educational, interpretive, and visitation opportunities will be structured for maximum public enjoyment while protecting the resource, while access throughout the Park will remain for unfettered public enjoyment wherever the resource would not be compromised. The natural and wild character of the Lakeshore as a whole shall be preserved. 

Management Zones (Relative Proportions):  Moderate amounts of the High Use visitor zone and Experience History zone, large amount of a Range of Experience zone, small amount of the Primitive zone (the Range of Experience zone will continue to offer much “primitive” experience as well).

Wilderness:      Since a primitive experience in a natural setting abounds in most of the Lakeshore already, and since plentiful opportunities for solitude and quiet can be found on trails, in the woods, in the waters and on the beaches even on the busiest day of the year, wilderness sanctions are unnecessary to achieve Wilderness Act goals.  Thus, no wilderness sanctions are proposed for the mainland or South Manitou Island.  Large amount of wilderness sanctions are proposed for North Manitou Island for those seeking a particularly challenging experience.

Benzie Corridor:  Environmental and economic impact assessment processes will be undertaken and will include detailed informational outreach, including concrete plans for each scenario, followed by solicitation of public input, especially of all directly affected governmental bodies.  After these assessment processes are well underway and information has been disseminated, but prior to any further decision-making within or outside the GMP on this issue, the relevant governmental bodies will be asked to provide Resolutions stating their preference for or against further acquisition of property by the Park Service and for or against development of a scenic road or trail.  The Park Service will give significant weight to those Resolutions in determining the future of the Benzie Corridor. 
 

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Our full Comments are comprehensive and include much that which we find positive.
For your convenience, below is a short version of some, but not all, of our concerns with Newsletter 3:

County Roads.  For years, the Park Service has pressed the Counties to give up their roads.  Despite reassurances the past two years that the Park Service will give this up, Newsletter 3 is an alert that the temporary moratorium against such pressure is likely to be lifted.  The Newsletter could have expressed, but tellingly did not, full Park Service support for use of these roads to maintain access. 
Converting the Park into a Reserve:  This “Concept” of the four proposed “Management Concepts” would convert the Park from an accessible “Lakeshore” to a limited public use “reserve” for an unidentified “future” rather than for the general public (current and future).  CAL believes it is a repeat of the withdrawn 2002 GMP, minus previous attempts to act on matters under state and county jurisdiction.  CAL believes the Park Service exceeds its authority by proposing a “Concept” inconsistent with statutory purpose “for the benefit, inspiration, education, recreation and enjoyment of the public”.
Access to Lake Michigan:  CAL is extremely disappointed that there is absolutely no mention in Newsletter 3 supporting current access, nor improving access, to and from Lake Michigan.
Boating, Safe Harbors:  CAL is extremely disappointed that there is absolutely no mention of Park Service support for safe boating access to and from Lake Michigan anywhere on the 35 miles of coastline, nor on the two Manitou islands. 
Access to Platte River:  A terribly unsafe condition has existed for years around M-22 at the Platte River.  Children and adults are continually at risk of highway exposure due to a severe lack of safe parking.  If not addressed now, this serious problem will only be aggravated over the next twenty years of the new GM.
Language too Broad:  The law already protects threatened and endangered species.  Native, endemic species are also worthy of protection but not to the detriment of other benign species which might have lived here for hundreds of years.  CAL believes some of the language in this GMP is way too broad and could be used by future Superintendents to implement selective destruction of anything not deemed “pre-European”, and to unreasonably prevent benign enjoyment by the public of an area.
Benzie Corridor:  Without any specifics, CAL believes the Park Service is prematurely seeking input whether to go forward on the development of a major new scenic road or trail outside the main acreage of the Park.  We are glad the Park Service has taken this opportunity to alert the public that acquisition has already begun.  However, no maps, no specific plans, and no economic or environmental assessments were provided.  Impacts of developing or not remain unknown, so it is impossible for informed input to result.  CAL believes it premature for the Park Service to decide this matter in this GMP until the impacts (negative or positive) are studied and made public. 

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Citizens for Access to the Lakeshore (CAL)
P.O. Box 96
Beulah, MI  49617-0096
© Citizens for Access 2006

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