Dear Mr. Krieber,

The 71,000-acre Sleeping Bear Dunes National Lakeshore awes people with its rolling dunes, sweeping expanses of fields and historic farmsteads, and glittering blue water. Proper stewardship of such unique natural and cultural areas requires thoughtful planning and careful management. Since the Sleeping Bear Dunes National Lakeshore’s inception in 1970, the administration and staff have done an excellent job of protecting natural resources while providing the public with access to the dunes, the water, and the forests.

The Michigan Land Use Institute is pleased to submit comments on the Sleeping Bear Dunes National Lakeshore’s General Management Plan. The Institute trusts that our comments will assist the National Park Service manage the irreplaceable natural resources in the lakeshore and preserve the unique cultural and historical resources within its boundaries. It is our hope that the Park Service’s new management plan will find a way to balance protection and preservation of the lakeshore’s valuable resources with thoughtful methods of providing access for visitors with a variety of wants and needs.

The Institute is a 2,200 member nonprofit, education, and research organization located in Benzonia that works statewide to build support for public policy that protects the environment, strengthens the economy, and enhances quality of life. The Institute works with local officials and the public to promote and establish better ways to manage our land and resources and has shared two very significant successes with the National Park Service. When the Homestead proposed to exchange property it owns along the Crystal River with Park Service land on Thoreson Road, the Institute got involved and worked relentlessly with the NPS to combat the ill-conceived land swap. The collaborative effort of the Institute, the NPS, and a variety of other concerned citizens proved successful when the land swap was denied.

The Institute also worked closely with the NPS when it helped establish Preserve Historic Sleeping Bear, a grassroots organization focused on protecting the historic and cultural resources in the Sleeping Bear Dunes. NPS officials listened to what the public had to say and amended its management plan to preserve the deteriorating historic structures within its boundaries. The Institute believes that this was a successful collaborative effort between the NPS, PHSB, and other concerned citizens that will have lasting, beneficial effects on the landscape of the lakeshore for generations to come.

GENERAL MANAGEMENT PLAN COMMENTS
The Sleeping Bear Dunes are a unique glacial phenomenon and also one of the last remaining large, undeveloped, majestic recreation areas in northern Michigan. As this region, and open space across the country, becomes more populated and developed, it is essential to protect unique wild places and manage our precious natural resources thoughtfully, responsibly, and carefully. Because this region is growing at such a rapid rate, it is increasingly necessary to keep publicly owned land in its natural state. The Institute believes that the NPS has an important responsibility to steward this magnificent landscape so as to preserve its natural integrity for future generations to use and enjoy. Placing a priority on protecting the irreplaceable natural features is vital, and the Park Service should continue to stress this as the most important basis for drafting and enacting a management plan. This means keeping the landscape in the park as undeveloped as possible. Therefore, as the Park Service further refines the General Management Plan, the Institute recommends that the NPS does not create or pave more roads, build more facilities, or alter the natural landscape any more than necessary. Instead the Park Service should foster a management strategy that balances access with protecting the lakeshore’s fragile ecosystem.

With a few modifications, Alternative 2 is our preferred approach to manage the lakeshore’s irreplaceable natural resources. The Institute prefers Alternative 2 because it:

• Gives prominence to the natural integrity of the landscape and protects the unique lakeshore environment.

• Discourages activities that would irrevocably alter the natural environment, such as creating or paving new roads.

• Continues to promote access but does so in more centralized, highly trafficked, and popular destinations — the Dune Climb, Platte River Campground and Picnic Area, D.H. Day Campground, and Glen Haven.

• Keeps most of North Manitou Island a primitive wilderness area. In this alternative, the Park Service has also designated South Manitou mostly ‘primitive’ but maintains current rustic campgrounds and continues to allow both day and night visits, which the Institute believes is important to allow people a variety of wilderness experiences.

• Maintains some of the cultural landscapes on North and South Manitou Island but keeps the remaining areas wild.

• Maintains the cultural landscape of Glen Haven.

• Includes acquiring the Benzie Corridor/Crystal Ridge but keeps this area primitive and wild.

• Seeks to obtain roads from the county as they become available to ‘be used as hiking trails as needed or restored to natural conditions.’

• Prohibits mechanized modes of transit in sensitive areas, such as School Lake.

• Keeps the Bow Lakes Unit natural and wild.

• Discourages high impact activities in sensitive and unique areas of the lakeshore.

The Institute urges the NPS to make amendments to Alternative 2 that include:

• Protecting other cultural and historic resources on South and North Manitou Island, such as South Manitou’s historic farm loop and North Manitou’s orchards, farms, and cemetery. The Institute also believes that it is important to preserve other cultural and historic landscapes within the lakeshore’s boundaries — Port Oneida Rural Historic District, the Tweedle and Treat farms, and the Bufka, Kropp, and Eitzen farms. These places are links to the past that can provide invaluable educational and interpretive learning experiences for lakeshore visitors. The Park Service should put a priority on finding a balance between maintaining these unique cultural landscapes and protecting sensitive natural resources.

• Keeping the NPS’ headquarters in Empire as the ‘central area’ visitor center. The Empire location is in the middle of the lakeshore and the current facility is easily accessible and offers visitors excellent educational opportunities. The National Park Service should discourage building any other large visitor centers, especially considering that the current facility is an exceptional, user-friendly educational resource.

• Not constructing new buildings for ‘interpretation and orientation’ purposes. Instead, the NPS should seek out opportunities to offer visitors interpretive and educational resources at different areas in the lakeshore by either upgrading buildings at these locations or by finding creative ways to provide the information on large boards, maps, brochures etc.

• Continuing to allow and promote higher levels of access in the lakeshore’s most popular destinations — the Dune Climb, the Platte River campground and picnic area, Good Harbor, Empire Beach, and perhaps the North Bar recreation area. The NPS already does an excellent job of allowing visitors to explore and enjoy these places. Access to these locations will help to consolidate visitors to specific areas that are generally the most popular, which will help the NPS control where and how many people access more sensitive areas.

• Using hybrid or electric shuttles between recreation areas or through the Pierce Stocking Scenic Drive. As greater numbers of people visit the lakeshore, alternative public transit opportunities are excellent, energy-efficient ways to bring more people into the lakeshore without degrading its unique resources.

• Maintaining the existing picnic areas and other low-impact visitor facilities. The Park Service does an excellent job of providing lakeshore visitors with many locations to picnic and get out into the lakeshore with minimal impact on the natural environment, such as the Platte River campground/picnic area and the picnic area on the corner of M-22 and Basch Road. The NPS should maintain these areas and also consider other options or locations for picnic or recreation areas that will allow people who are looking for easy access into the lakeshore more places to go.

Do you agree with the Purpose and Significance Statements? How would you improve them?

The Institute agrees with the Purpose and Significance Statements but also believes that the Park Service should place greater emphasis on how and why it is vital to preserve the unique natural environment of the lakeshore. The best place for the NPS to stress its, and the public’s, role of ‘steward’ of this irreplaceable natural wonder is in the Purpose and Significance Statements.

There should also be more emphasis in the Purpose and Significance Statements on the importance of protecting the cultural and historic resources in the park. People need a better understanding of the history of the land — how past generations lived, farmed, and played. Protecting these important links to previous generations is invaluable. These landscapes can tell a story of the land and give visitors a strong sense of place and more intimate understanding of the region. The natural resources in the park are invaluable but the cultural and historic resources are also a very important part of the Sleeping Bear Dunes National Lakeshore.

These statements allow the Park Service to make a compelling case for protecting all the resources that, together, make Sleeping Bear Dunes National Lakeshore so unique because they provide an opportunity to speak to the invaluable wilderness experiences that these wild, open spaces can provide for people. The National Park system was established to connect people with the land and the water and to provide them with an outlet that is often not available in their everyday lives. As cities and suburbs surround people with the built environment, it is evermore important to provide the public with a place to access the land and to revel in the recreational and spiritual opportunities it provides. This means preserving the natural integrity of America’s most precious and majestic landscapes.

Do you feel the Management Zones address the range of visitor experiences and resource conditions appropriate to the Lakeshore? How would you improve them?

The National Park Service must address a broad range of visitors’ wants and needs. But the management zones, and the type of activities the Park Service envisions for those zones are unclear in the current document. Without more information, it is difficult to provide the NPS with specific comments simply because there is no basis for comparison — no details of the lakeshore’s current management plan to use as a foundation for our comments. To provide a more useful and accurate analysis, it is also important to understand how the Park Services’ current management of the lakeshore differs from the management plan that is in effect today.

Our general comments:

• The types of management zones seem appropriate and should be included in every alternative, as these options offer the public access to a wide-range of visitor experiences — backcountry, cultural landscapes, historic restoration zones, natural resource recreation areas, primitive places, ecologically sensitive zones, scenic corridors, and visitor services. It is vital, however, to balance these zones so that the natural integrity of the lakeshore is not compromised. As stated previously we recommend an emphasis on the natural environment and the cultural and historic resources.

• There is little mention of what the concrete implications and impacts of the different alternatives would mean to the ecology of the lakeshore. It is vital that the NPS address the potential impacts of what the alternatives would mean to the ecology of the lakeshore — the water, the woods, and the wildlife.

• There does seem to be some inconsistency in the ‘zones,’ however. One example is the delineation of ‘ecologically sensitive’ zones. In alternatives 1 and 4, there are no ‘ecologically sensitive’ zones. Yet in alternatives 2 and 3 there are ‘ecologically sensitive’ zones, and with the exception of North and South Manitou Island in these two alternatives, there is no consistency as to the areas that the Park Service deems ‘sensitive.’ If there are ‘sensitive’ or fragile areas in the lakeshore, the Park Service should take care to protect these places — in every alternative. The Institute believes that it is important to assess the ecological importance of different regions in the lakeshore, set those areas with irreplaceable and unique natural features aside for protection, and consider different alternatives for managing fragile areas. The Institute also believes that the areas deemed ‘ecologically sensitive’ in Alternative 2 should at least remain primitive in the Park Service’s management plan.

• The Institute would like the NPS to continue to improve and promote access to the lakeshore’s magnificent natural areas but would like to ensure that this does not come at the expense or the degradation of the lakeshore’s unique ecological and historic resources. To maintain one of the largest remaining dune landscapes in the country the Park Service needs to consider how some of the alternatives — including paving parking lots, building more facilities, opening up access in natural areas — will affect air and water quality and the overall environmental quality of the lakeshore.

There is a growing emphasis on protecting air and water — marks of a high quality of life and healthy natural environment — in America’s national parks. Some of the country’s most magnificent natural areas were set aside to give people inspiring spaces to learn, play, recreate, and enjoy. If the NPS is to protect the air and water in the Sleeping Bear Dunes National Lakeshore, it is essential the Park Service give very careful consideration of the secondary impacts of the actions in every alternative. (Please see enclosed news article.)

• To allow more people into the lakeshore but continue to remain sensitive to protecting the fragile natural environment, the NPS should consider, and include in its GMP strategy, ideas for alternative forms of transportation. Electric or hybrid buses, trolleys, or shuttles are not only excellent ways to bring more visitors into the lakeshore but also are important for protecting the lakeshore from the air, water, and noise pollution that generally follows automobiles. Currently both the U.S. House and Senate are studying two different bills that promote accessible and efficient alternative transportation options in America’s National Parks. The Senate’s bill, called the Transit in Parks Act, would create a federal transit grant program to provide mass transit and alternative transportation service for national parks and other public lands. The "TRIP" initiative would authorize $65 million annually over the next six years to national parks and federal land management agencies. The Park Service should prepare to access these funds to bring alternative transportation into the lakeshore.

• The Park Service maps out several ‘ecologically sensitive’ zones in two of the alternatives. It is assumed that these ‘sensitive’ areas need more rigid management because they are fragile, but it is also important that these protective measures do not preclude possible low-impact recreational opportunities. Although it is vital to protect the irreplaceable natural resources in the park, those who would like to venture into more remote, sensitive areas should be able to find their way with Park Service-provided maps. The Park Service could designate certain areas where people can get into the lakeshore but must stay on a designated path. With creative landscaping, well-maintained trails, and signs, the Park Service can allow low-impact access to more sensitive areas while protecting the natural integrity of these fragile places.

• Each of the alternatives should have a greater emphasis the educational and interpretive opportunities in the lakeshore. The Institute believes that there is a crucial link between a healthy respect for natural resources and the ability to properly manage and protect valuable public property thoughtfully and carefully. Thus the Institute would encourage the National Park Service to add language into the GMP that addresses the importance of interpretive opportunities and allows for a variety of educational experiences without the construction of major new facilities.

• The Institute would like to stress again the importance of preserving the historic and cultural landscapes in the lakeshore to serve as historical links and emblems of past lives and experiences. The Park Service should preserve these culturally unique and irreplaceable historic buildings and landscapes. These elements help to tell the unique history of the lakeshore. The Park Service should continue to consider creative ways to maintain these historic structures by nurturing partnerships with other public interest groups, such as that with the Shielding Tree Nature Center. The ‘partnership’ with the Shielding Tree provides a unique educational experience for families and children. This is an important collaboration that helps the NPS maintain the historic farmhouse, barn, and working landscape. Fostering creative partnerships with different public interest organizations is a great way for the NPS to preserve the important cultural and historic landscapes in the lakeshore while alleviating some of the financial burden and manpower needed for their upkeep.

• The Institute believes that building another “primary orientation” facility and several other “orientation facilities” in the lakeshore is unnecessary. The NPS does an excellent job providing visitors with information on activities and resources in the lakeshore. As visitor use grows, the NPS should work to find creative mechanisms for providing visitors with information and services without building more facilities, especially considering all of these facilities will require continual care, upkeep, and staffing, which means more financial obligations on an already-tight budget. The NPS headquarters in Empire is a wonderful welcome center, centrally located, that provides visitors with a great opportunity to learn and understand the lakeshore and its amenities. If the NPS believes they need ‘ancillary’ and dispersed visitor service centers to provide people with information without them having to come to Empire, the Institute suggests looking at ways of providing visitors with information that have less impact on the natural environment. Perhaps, instead of ‘interpretive facilities,’ it might be sufficient to build graphically compelling, detailed information boards at trailheads and provide visitors with brochures and maps.

• It is difficult to make comments on the draft management plan without a better understanding of the timeline the NPS is working within — is it a management plan that is looking 20 years or 100 years ahead? The Institute understands that the Park Service updates its management plan every 20 years. But we also hope that the NPS is taking careful consideration of the impacts this management strategy will have on these globally unique natural resources for decades and centuries to come.

• The Institute supports the idea of designating significant areas in the lakeshore as wilderness because it will ensure the protection of the lakeshore’s invaluable natural resources, yet pressing for official designation is premature until important concerns on how this will impact the cultural and historic resources are addressed and resolved. There is no information in the draft GMP on where the official wilderness boundary is and how that will effect the lakeshore’s cultural and historic resources. Although the Institute believes it is important to keep the lakeshore as wild as possible, it is also important to understand and assess how official wilderness designation will impact the fate of the houses, farms, and outbuildings in the lakeshore. An understanding of the impacts to the historic and cultural resources must come before the NPS presses for Congressional designation of the 30,000 acres of land that qualify for such appointment. If possible, the Park Service should delineate ‘cultural landscapes’ within the wilderness boundary and set aside unique historic regions — Port Oneida Rural Historic District, the Tweedle and Treat farms, the Bufka, Kropp, and Eitzen farms etc. — until this issue is resolved. Officially designating a large portion of the lakeshore wilderness, while concurrently maintaining special cultural and historic areas, will help the Park Service protect both the fragile natural resources and the majestic landscapes.

• In conclusion, the planning process is the most important step in deciding how to use the land and resources in the Sleeping Bear Dunes National Lakeshore. Because the National Park Service is developing a long-term plan, and is taking the time to learn how the public would like the lakeshore to develop, it is important that citizens have ample time to comment. The Institute believes that the Park Service should extend its public comment period. The public should have at least 60 days to comment from when the information was made fully available.

What other alternatives or elements of alternatives would you like the planning team to consider? Do you have ideas for the future of the Lakeshore that don’t seem to fit any of the alternatives? What are they?

The ownership of public lands is invaluable. The Institute believes that the National Park Service should work to acquire as much property near the current park boundary lines as possible. Specifically the Institute believes that the Park Service should:

• Consider extending the park’s boundary to include North and South Fox Island. North Fox Island is now owned by the state of Michigan. But South Fox Island is at the center of a highly visible land swap proposal. As part of the rationale for trading away some of the most unique and important parcels of publicly-owned land, the state has clearly acknowledged that it is not capable of properly managing the resources on South Fox Island. There is no management plan for South Fox and the state has suggested that a private landowner would be a more suitable steward. This is an unacceptable management approach for the state’s natural resource agency to take. Given the successful track record of the NPS managing North and South Manitou Island, it seems reasonable to consider extending the lakeshore’s boundary to include North and South Fox.

• Acquire the rights-of-way to the roads on South and North Manitou Island. The Institute is concerned by the Leelanau County Road Commission’s plan to control the islands’ roads and “keep a road open that runs to the Valley of the Giant Cedars” on South Manitou. The conflicting interest of the road commission could compromise the NPS’s ability to properly manage park service land on the island. The Institute believes it is important that the NPS have complete control of the rights-of-way to maintain lakeshore resources in their natural state. More traffic and increased numbers of people in highly sensitive areas would inevitably degrade the unique character of South Manitou Island’s giant cedars. The NPS should do all it can to acquire the rights-of-way to the island’s roads.

• Expand the lakeshore’s boundaries to include the Crystal River. For 15 years concerned citizens and the NPS have advocated for an alternative to the Homestead Resort’s plan to build a golf course and fill in irreplaceable wetlands along beautiful Crystal River. The Crystal meanders slowly and quietly in and out of the lakeshore’s boundary. The potential impact of such development is uncertain but the sensitive ecosystem stands to incur great harm from such development. Now the Homestead has a new plan: To build more than 200 condominiums, and a golf course as well, on the same disputed property. The Crystal River is a unique and invaluable natural wonder that flows from Glen Lake — a liquid jewel in the heart of the lakeshore. The National Park Service should steward this magnificent public waterway, safeguarding it from potential irrevocable harm. The Institute believes the NPS should advocate for ownership of the property on which the Homestead plans to build condominiums and a golf course. It makes sense for the NPS to recommend that Congress include this unique parcel of property — caught in the middle of the Sleeping Bear Dunes National Lakeshore’s boundaries, concerned citizens, and a major development plan — in the park’s legal parameters.

• Purchase the Benzie/Crystal Ridge Corridor and include it in the lakeshore’s boundary. The Institute understands that this piece of property falls within the lakeshore’s boundaries and that it is not actually publicly owned at this time but believes that it is extremely important for the National Park Service to acquire this land. This is a unique parcel that the NPS should ensure is in public ownership. If and when this piece of property falls into public hands, it should remain in a natural state. The Institute understands that there is a plan in place to acquire this piece of property, but that this acquisition is based on the condition that this corridor becomes a road. If the legal conditions allow only a paved road, the NPS should advocate for an amendment in Congress to the current legislation changing the language so that alternatives to a paved road — paths, trails, a corridor — are feasible. To delete the Crystal Ridge Corridor from the lakeshore’s boundary is a mistake. As pressure to develop land intensifies, public land ownership is ever more important. The Institute would like to see the NPS acquire this land and keep it a green corridor where low-impact hiking on designated trails is allowed.

• Because these ‘ownership’ issues continue to arise in areas in or near the lakeshore’s boundaries, the Institute believes that there is a unique opportunity here. The Park Service should work to acquire these aforementioned natural assets and also consider other such invaluable properties to include in an expanded lakeshore boundary such as the Point Betsie Lighthouse, the North Manitou Shoal Light, and Fishtown in Leland. These places are irreplaceable natural and cultural wonders that give a true sense of northern Michigan, the lakeshore, and its people.

• Ban jet skis in the lakeshore’s boundary. The Institute understands that the Park Service has a temporary ban on jet skis in the lakeshore, but we strongly recommend that the NPS place a permanent ban on the motorized watercraft’s usage in the lakeshore. Jet skis are not only incredibly polluting but their loud noise reverberates off the water and can be heard for great distances.

• Continue to ban snowmobiles in the lakeshore. The Institute agrees with the policy of snowmobiles in the lakeshore’s boundaries but would like to stress the importance of maintaining this moratorium.

The Michigan Land Use Institute appreciates the opportunity to comment on the Sleeping Bear Dunes National Lakeshore’s draft General Management Plan. The Institute looks forward to the chance to comment further on a more clearly defined management strategy for the lakeshore — including plans for new facilities, roads, trails etc.

The National Park Service is entrusted with preserving and protecting Sleeping Bear Dunes National Lakeshore’s majestic and irreplaceable natural landscape. This is an important and challenging responsibility. But with careful planning, thoughtful management, and the support of concerned organizations and individuals, the Institute believes it is possible to work together to maintain the natural integrity of this magnificent natural resource for future generations to use and enjoy.

Please let us know if you have any questions on our comments.

Sincerely,
Johanna Miller
Policy Specialist
Michigan Land Use Institute