Wilderness and Backcountry Management Plan

and Environmental Impact Statement

ISLE ROYALE NATIONAL PARK

National Park Service

U.S. Department of the Interior

Isle Royale National Park ● Michigan

July 2011 

Final Wilderness and Backcountry Management Plan

and Environmental Impact Statement

Isle Royale National Park

Michigan

Isle Royale National Park 

Michigan

i

EXECUTIVE SUMMARY

This document contains the final Wilderness and Backcountry Management Plan (WBMP) for 

Isle Royale National Park and the associated Environmental Impact Statement (EIS). The 

purpose of this plan is to serve as: 

1. A public document that outlines steps for preserving Isle Royale’s wilderness 

character, natural resources, and cultural resources while also providing for the use 

and enjoyment of the park’s wilderness and backcountry by current and future 

generations; and

2. A management document that will provide accountability, consistency, and continuity 

for managing Isle Royale’s wilderness and backcountry and this park’s place in the 

National Park Service’s wilderness management program. 

The plan addresses issues and provides guidelines for managing the wilderness and backcountry 

areas of the park, which encompass all areas of Isle Royale outside of the Developed and Open 

Water Zones. This plan addresses a wide array of management issues, and identifies specific 

goals, objectives, and decision-making guidelines for administrative actions and visitor use. In 

many cases this plan formalizes current National Park Service (NPS) management practices in 

Isle Royale’s wilderness and backcountry. However, several modifications and changes are 

proposed that are intended to bring management practices on Isle Royale into compliance with 

NPS policies, improve visitor services, or generally improve wilderness and backcountry 

management in the park. This plan does not propose any changes in the wilderness boundaries 

set forth in Isle Royale’s 1976 Wilderness Legislation. 

Adopting this plan causes some changes in how the NPS manages wilderness and backcountry in 

Isle Royale, some of which will be readily apparent to the public, while others will be primarily 

operational. The NPS will institutionalize a Minimum Requirement process to guide and 

document decisions on appropriate tools for maintenance activities in the park’s wilderness, 

appropriate research projects and field methods within wilderness, and appropriate 

administrative actions within the wilderness. The NPS will aim to make better use of research 

and monitoring to guide management through the creation and implementation of a coordinated 

monitoring plan, and will strive to increase staff training and accountability for wilderness 

management. 

The most obvious changes from the public perspective are those that address crowding and 

visitor distribution, visitor information services, and resource conditions. Several issues were 

presented in the draft plan with multiple alternatives for goals and management actions, which 

were developed with extensive public input. These issues are; 1) managing overnight camping 

and boating in Isle Royale’s wilderness and backcountry, including permitting and information 

services, 2) managing day use in the park’s wilderness and backcountry, 3) managing campfires, 

4) maintaining or removing the fire towers in the park’s wilderness, and 5) maintaining or 

removing picnic tables from wilderness campgrounds. Chapter 2 outlines the details of all of the 

previously proposed changes, and identifies the NPS preferred alternative (the final, approved 

action alternative) for each of these issues. 
ii

The draft WBMP proposed several changes in how Isle Royale’s wilderness and backcountry is 

managed. The preferred alternatives were crafted with an intention of creating one cohesive 

management program, with management goals for each of several issues being complementary, 

not contradictory. The planning team’s intention was to respond to public interest and the 

concerns of subject matter experts, and incorporate the best science available for guiding 

preservation of Isle Royale’s resources and values. General goals included improving the quality 

of wilderness and backcountry experiences for visitors while still providing high public access to 

the park for appropriate types of recreation. Existing facilities could be used more efficiently, 

while unnecessary facilities would be removed from the wilderness. Table I outlines the goals 

and proposed management actions for all of the preferred (approved) alternatives. 

The preferred alternatives in combination also strive to minimize adverse resource impacts, in 

many cases improving resource conditions that are currently showing degradation. Because Isle 

Royale is already a difficult and expensive park to visit, the preferred alternatives were also 

crafted with an interest in not further restricting general public access to the park. The preferred 

alternative for managing overnight camping and boating on Isle Royale focused on more 

efficiently utilizing existing camping facilities through the creation of a backcountry office and 

advanced permitting. The intent is to expand visitor services for trip planning and reduce 

campground crowding to improve social and resource conditions in campgrounds. This could 

result in a decrease in visitor access to the backcountry for camping during the busiest weeks of 

the season. The preferred alternative for managing day use was crafted with an intention to 

allow an increase in day use and concessions lodging throughout the visitor season. Day tours 

would be managed to concentrate the majority of day visitors close to developed and 

frontcountry areas of the park and minimize adverse impacts to wilderness character and other 

critical resources. 

The preferred alternatives in combination also aimed to minimize or reduce the impacts of 

development in the park’s wilderness. Although the preferred alternative for overnight use would 

add one additional campsite at North Desor campground and a few rustic cabins in Rock Harbor, 

and the preferred alternative for day use would add 3-5 miles of new trail, no new campgrounds 

would be constructed other than those approved in the park’s General Management Plan (GMP), 

up to 2 fire towers would be removed, and campfire rings would be located only where resource 

conditions could tolerate the associated impacts. 

The EIS involves analysis of current conditions in the park and the likely impacts of 

implementing each of the alternatives, considering impacts to visitor use and experiences, 

wilderness character, natural resources, cultural resources, socioeconomics, and NPS operations 

and administration. In general, each of the alternatives would be expected to result in both 

beneficial and adverse impacts to park resources and values. None of the adverse impacts would 

be extensive or severe enough to result in degradation of resources or values. The environmental 

consequences of each alternative are summarized in Table II. 
iii

Table I: Summary of the Preferred (Approved) Alternatives

Actions Common to 

All

Managing Overnight 

Use Managing Day Use Campfires Fire Towers Picnic Tables

Goals The NPS would avoid

actions that might 

have no seeming 

physical impact but 

which would detract 

from wilderness 

character and the idea 

of wilderness as a 

place set apart.

Provide a range of 

high quality 

opportunities for 

wilderness and 

backcountry 

experiences and 

reduce adverse 

impacts to park 

resources and values.

Expand opportunities 

for high quality day 

activities, while also 

accommodating future 

increases in day use 

and minimizing 

adverse impacts to 

park resources and 

values.

Continue to provide

an opportunity for 

camping with 

campfires, while also 

concentrating and 

minimizing adverse 

resource impacts. 

Improve the park’s 

wilderness character 

by removing 

substantial structures 

that no longer serve an 

administrative need. 

Adhere to NPS policy 

for wilderness 

management while 

also utilizing effective 

tools for containing

adverse impacts in 

campsites. 

Desired 

Future 

Conditions

• Provide a range of 

quality visitor 

opportunities

• Reduce the adverse 

impacts of NPS 

operations

• Overcrowding 

would be reduced in 

campgrounds all 

season 

• Improve camper 

distribution

• Protect seasonal 

sensitivities of park 

resources

• Provide a seasonal 

range of visitor 

opportunities, with 

low use in the 

spring and fall

• Improve trip 

planning and 

information services

• Create additional 

opportunities, such 

as a new loop 

hiking trail for day 

visitors. 

• Improve social and 

resource conditions 

in day use areas by 

establishing upper 

limits to the size of 

organized day tours.

• Allow for an 

increase in day 

visitors to the park.

• Visitors would have 

the option to camp 

with campfires

• Visitors would have 

the choice of 

camping in areas 

where fires are 

permitted, or where 

fires are not 

permitted.

• Fire rings would be 

located only where 

there are no 

vulnerable natural 

or cultural 

resources. 

• Administrative 

impacts to 

wilderness character 

would be reduced 

by removing up to 2 

of the park’s 3 fire 

towers

• Ojibway Tower 

would continue to 

be used to 

administrative 

purposes that are 

compatible with 

wilderness, such as 

communications, 

research, and 

monitoring

• Isle Royale would 

be in compliance 

with NPS policies 

for wilderness 

management

• Adverse resource 

impacts would be 

effectively 

concentrated in 

campsites of 

minimal sizes.

• Picnic tables would 

continue to be 

available for visitor 

convenience in 

some wilderness 

campgrounds
iv

 

Actions Common to 

All

Managing 

Overnight Use Managing Day Use Campfires Fire Towers Picnic Tables

Appropriate 

Management 

Actions

• Low-cost rustic 

cabins would be 

added in Rock 

Harbor

• Cross-cut saws 

would be used

increasingly to 

minimize chainsaw 

use

• Sustainablyharvested, 

chemically 

preserved lumber 

would be used for 

trails and 

campgrounds

• Cross-country 

camping and 

anchoring-out 

would continue, 

with monitoring of 

impacts

• The Minimum 

Requirement 

Decision Tree 

would apply to all 

NPS activities in 

wilderness

• Establish a 

mainland-based 

backcountry office 

to coordinate 

information 

services and 

permitting

• Implement an 

advanced 

permitting system 

for all overnight 

boaters and 

campers, allowing 

more flexibility for 

boaters not using 

campsites.

• Discontinue the 

practice of issuing 

permits over the 

capacity of a 

campground

• Institute a 

permitting fee to 

offset the costs 

associated with the 

backcountry office 

• Expand North 

Desor campground 

by 1 campsite.

• Expand public 

education to reduce 

adverse impacts to 

park resources and 

values.

• Continue 

monitoring social 

and resource 

indicators

• Explore options for 

creating a new 3-5 

mile day trail near 

Windigo.

• Establish group 

size limits for day 

tours, allowing 

larger groups to 

split into multiple 

small groups. 

Limits set by 

management zone:

Frontcountry: 40

Wilderness Portal, 

Backcountry and 

Primitive: 20

Pristine: 6

Note: Hidden Lake, 

Lookout Louise, and 

McCargoe Cove are

an exception, with up 

to 40 people allowed.

• Adhere to clear 

protocols for when 

and where 

campfires would 

be appropriate, 

based on resource 

conditions.

• Remove or add fire 

rings at different 

campgrounds as 

necessary, based 

on resource 

conditions

• Replace existing 

fire rings with 

smaller metal rings 

with adjustable 

grates.

• A single 

communal ring 

could replace 

multiple individual 

campsite rings in 

some campgrounds

• Increase education 

about low-impact 

fires and sensitive 

resources. 

• Include 

information about 

the locations of 

campfire rings for 

visitors at the time 

of permitting. 

• Remove Ishpeming 

Tower. Review 

administrative 

needs 

(communication, 

research) for

Feldtmann Tower, 

using the minimum 

tool necessary to 

achieve 

administrative 

functions

• Restore the 

impacted site(s) to 

their natural 

conditions

• Maintain and 

utilize Ojibway 

Tower for 

administrative 

purposes 

associated with 

managing the 

park’s wilderness.

• Follow NPS 

policy, using 

Minimum Tool 

process to 

determine where 

picnic tables 

should remain.

• Minimum Tool 

process shows that 

tables should 

remain in 

campgrounds with 

docks and shelters.

• Remove picnic 

tables from 

campgrounds 

where docks and 

shelters are 

removed (i.e. 

Siskiwit Bay and 

Duncan Bay upon 

full 

implementation of 

the GMP)
v

Table II: Combination of Environmental Effects of all of the Preferred (Approved) Alternatives

Overnight Use, Alt. B Day Use, Alt C Campfires, Alt. B

Fire Towers,

Alt. B

Picnic Tables,

Alt. C

Proposed 

Changes

• Implement GMP-proposed new 

campgrounds

• New Backcountry Office

• Advanced Permitting

• Add 1 campsite at North Desor

• Not more than 5% sharing in 

summer

• Maintain historic low use in 

spring

• Group size limits, with 

large groups allowed to 

split up. 

• MV Sandy can carry up 

to 40 passengers total – 

maximum passenger 

numbers are consistent 

with Frontcountry and 

excepted Backcountry 

destinations.

• Explore options for 

adding a new loop trail 

in Windigo

• Campfires would be 

rotated to appropriate 

campgrounds based on 

the fuel availability and 

resource conditions. 

• Resource conditions at 

campgrounds would be 

inventoried prior to 

installing fire rings.

• Resources would be 

monitored for impacts.

• The Ishpeming Fire 

Tower would be 

removed. 

• Feldtmann Tower 

would be evaluated 

for administrative 

use.

• The Ojibway Tower 

would be retained for 

administrative uses. 

• Follow NPS policy 

and maintain 

picnic tables in 

wilderness areas 

where they meet 

Minimum Tool 

standards.

Visitor Use 

and 

Experiences

Visitation could increase from mid 

June through October. Advanced 

permitting would better distribute 

people to available campsites and 

reduce the frequency of 

overcrowding and give campers a 

greater assurance of finding an 

available campsite and opportunities 

to visit the park during low use 

times would be preserved; these are 

long-term moderate beneficial 

impacts to visitor use. Some people 

may not be able to get a permit for 

their preferred itinerary and public 

access may be limited in spring, a 

long-term, minor adverse impact.

Long-term, moderate, 

beneficial effect of high 

level of access to tours and 

group activities because of 

no size limits. Some 

visitors’ experiences may be 

negatively affected by being 

part of such a large group. 

Long-term, minor beneficial 

effect for those who enjoy 

campfires. Long-term minor 

adverse effect for those who 

do not. 

Long-term, minor 

adverse impact to 

visitor experience from 

the loss of views from 

the Feldtmann Tower if 

the tower is removed. 

Long-term minor 

beneficial impact to 

visitor experience from 

the continued 

availability of views if 

Feldtmann Tower 

remains for 

administrative uses. 

Long-term moderate 

beneficial impact to 

visitor experience 

due to the retention 

of this modern 

convenience.
vi

Overnight Use; Alt. B Day Use, Alt C Campfires, Alt. B

Fire Towers,

Alt. B

Picnic Tables,

Alt. C

Wilderness 

Character

Impacts to wilderness character 

would be long-term, moderate 

and beneficial. Overcrowding 

in campgrounds would be 

reduced. A wide range of 

opportunities for wilderness 

experiences would be 

protected.

Large groups can have a 

negative impact on the 

wilderness experience both 

for those in the group and 

for others. Minor, shortterm adverse impacts: noise, 

crowding, displacing 

wildlife. Trampling could be 

short or long-term, minor to 

moderate.

Long-term, minor beneficial 

effect for those who see 

campfires as part of wilderness. 

Long-term minor adverse effect 

for those who do not. Long-term, 

minor adverse effects to 

naturalness.

Long-term major 

beneficial impact to 

wilderness and 

naturalness in the vicinity 

of Ishpeming and possibly 

Feldtmann Tower. Longterm minor adverse 

impact to other areas 

where Feldtmann Tower 

is visible if it remains.

Long-term 

moderate adverse 

impact on 

wilderness 

character due to the 

retention of these 

modern artifacts. 

Impact is reversible 

with the removal of 

tables. 

Natural 

Resources

Impacts to natural resources 

would be long-term, moderate 

and beneficial compared to 

current conditions. Reduced 

overcrowding in campgrounds 

would reduce adverse 

biophysical and noise impacts. 

Maintaining low visitation in 

spring would minimize adverse 

impacts to wildlife. Long-term, 

minor adverse effects include 

adding one new campsite at 

North Desor and allowing an 

increase in fall visitation.

Adverse impacts to wildlife 

would be localized and 

short-term. Adverse impacts 

to vegetation and soils 

would be localized and 

could be long-term.

Long-term, minor, beneficial 

impacts to natural resources due 

to concentration of visitor 

impacts in campgrounds with 

fire rings and fewer illegal fires. 

Long-term, minor adverse 

impacts because of tree damage, 

social trails and loss of woody 

debris. Rotation should mitigate 

some of these adverse impacts.

Long-term minor, 

localized, beneficial 

effects on natural 

resources in the area of 

Ishpeming and possibly 

Feldtmann Towers. Long 

term minor localized 

adverse effects near 

Feldtmann Tower if it 

remains.

Long-term, minor 

to moderate 

beneficial impact 

to natural resources 

due to the 

concentration of 

impacts in 

campgrounds with 

picnic tables

Cultural 

Resources

Reducing campground 

overcrowding and maintaining 

low visitation in the spring 

would have long-term, minor 

beneficial impacts on cultural 

resources. Adding one new 

campsite at North Desor could 

have adverse effects on 

unknown cultural resources. 

These effects would be longterm and their severity would 

depend on the significance and 

integrity of affected resources.

Cultural objects located near 

the trails could suffer longterm minor adverse impacts.

Cultural landscapes may 

suffer short-term minor 

adverse impact.

Long-term, minor adverse 

impacts from social trails created 

by firewood seekers and from 

uncontrolled fires. 

Long-term, minor, 

adverse impacts from the 

removal Ishpeming and 

possibly Feldtmann Fire 

Towers. If Feldtmann 

Tower remains, it and 

Ojibway Tower would 

remain as examples of fire 

towers in island history. 

Long-term, minor 

beneficial impact 

to cultural 

resources due to 

the concentration 

of impacts in 

campgrounds with 

picnic tables.
vii

Overnight Use; Alt. B Day Use, Alt C Campfires, Alt. B

Fire Towers,

Alt. B

Picnic Tables, Alt. 

C

Socioeconomics

Peak season backcountry 

visitation could decrease. If this 

resulted in an increase in day 

use, then this would be 

beneficial for local 

communities as day visitors 

spend more money. Cost per 

visitor could increase if 

permitting fees were 

implemented.

Possible minor, long-term 

beneficial impacts if the 

number of day visitors to 

the park increased based on 

continued availability of day 

trips for larger groups. 

Long-term, minor, adverse 

impact to current staff workloads 

from assessment, monitoring and 

moving fire rings and restoring 

the sites.

No anticipated 

socioeconomic effects on 

local communities or 

visitors.

Park 

Operations

Long-term minor adverse 

impact to park operations. 

Additional staffing required to 

start and run a backcountry 

office. Short-term costs would 

be moderate, long-term costs 

would be minor to moderate. 

Short-term costs of constructing 

a new campsite at North Desor 

would be minor, as would longterm costs for maintenance.

Possible long-term, minor 

adverse impact if increased

staff were needed to 

minimize trampling

impacts. 

Short-term, major adverse 

impact to park operations 

due to the removal of up 

to two fire towers from 

the Park. Long-term, 

minor beneficial impact 

from lower maintenance 

cost, though could be 

significant for both 

Feldtmann and Ojibway 

Towers if major repairs 

were necessary. 

Short-term, minor 

beneficial impact 

of not having to 

remove the picnic 

tables. Long-term, 

minor adverse 

impact of 

maintenance costs 

associated with 

tables.
viii

How to Read the Final Plan/EIS: 

After public review the NPS planning team evaluated comments from other federal agencies, 

tribes, organizations, individuals, and businesses regarding the draft plan and incorporated 

appropriate changes into a Final Wilderness and Backcountry Management Plan and 

Environmental Impact Statement. Importantly, the final plan includes substantive comments on 

the draft document and NPS responses to those comments. Both appear in Chapter 5: Public 

Comment and Responses, starting on page 235. Additionally, complete copies of written

comments received can be found in Appendix K, starting on page 329. 

NPS Director’s Order #12 defines substantive comments as those that do one or more of the 

following: 

a. question, with reasonable basis, the accuracy of information in the EIS 

b. question, with reasonable basis, the adequacy of environmental analysis, 

c. present reasonable alternatives other than those presented in the EIS, 

d. cause changes or revisions in the proposal (National Park Service 2001a). 

The revised Executive Summary captures changes that have been incorporated into the final 

plan, either because of recent NPS policy changes (picnic tables) or re-evaluation by the WBMP 

team of some aspects of Preferred Alternatives based on public comments (day use group sizes). 

Per requirements established in NPS Director’s Order #12, the final plan now includes 

discussions regarding unavoidable adverse impacts, short-term uses, long-term productivity, and 

irreversible or irretrievable commitment of resources, sections 4.1.7 and 4.4 respectively. All 

changes/revisions in the Final EIS fell within the evaluated range of impacts in the Draft EIS and 

did not require further review prior to adoption. 

As readers review this Final WBMP/EIS, they should note that the term “Preferred Alternative” 

now actually means “approved action.” Where changes have occurred in the Preferred 

Alternatives, the final plan (including Chapter5: Public Comments and Responses) combined 

with the Record of Decision will detail the reason for, and the anticipated impact of the changes. 

The Record of Decision therefore should be read along with the final WBMP/EIS when the final 

plan is being reviewed by the public or for implementation. 

After the Environmental Protection Agency publishes the Notice of Availability in the Federal 

Register and a subsequent 30-day no action period, a Record of Decision approving a final plan 

is signed by the NPS Midwest Regional Director. Sixty days after the signing of the Record of 

Decision, the plan can then be implemented, depending on funding and staffing. A Record of 

Decision does not guarantee funds and staff for implementing the approved plan. 
ix

TABLE OF CONTENTS

EXECUTIVE SUMMARY i 

CHAPTER 1: INTRODUCTION 1 

1.1 Purpose and Need for this Plan ...............................................................................................1 

1.2 Scope of this Plan ...................................................................................................................2 

1.3 Goals and Objectives of Wilderness and Backcountry Management for Isle Royale 

National Park ..........................................................................................................................2 

 1.3.1 Management Goals ......................................................................................................3 

 1.3.2 Objectives ....................................................................................................................3 

1.4 Laws, Policies, and Authorities ..............................................................................................3 

1.4.1 Federal Laws and Provisions governing Isle Royale WBMP ..................................4 

1.4.2 National Park Service Provisions .............................................................................6 

1.4.3 Provisions Specific to Isle Royale National Park ....................................................7 

1.4.4 State Jurisdiction Over Lake Superior Waters .........................................................8 

1.5 Plan Review and Update .........................................................................................................8 

1.6 Relationship of the Wilderness and Backcountry Management Plan to Other Isle Royale 

Management Plans ..................................................................................................................9 

1.7 The Planning Process ..............................................................................................................9 

1.7.1 The Visitor Experience and Resource Protection (VERP) 

Planning Framework ..............................................................................................10 

1.7.2 Interdisciplinary Planning Team ...........................................................................10 

 1.7.3 Scoping ..................................................................................................................11 

1.7.4 Prevalent Issues and Concerns Raised by the Public .............................................12 

1.7.5 Research and Data Collection ................................................................................15 

1.7.6 Impact Topics Included in the Environmental Impact Statement ..........................17 

1.7.7 Impact Topics Considered but not Analyzed in Detail ..........................................20 

1.7.8 Criteria used to Evaluate Alternatives ...................................................................22 

1.8 Regional Context ..................................................................................................................22 

1.9 Park Purpose, Significance and Emphasis ............................................................................23 

1.10 History of Wilderness and Backcountry at Isle Royale ........................................................25 

CHAPTER 2: ALTERNATIVES, INCLUDING THE PREFERRED ALTERNATIVES 27 

2.1 Framework for Managing Wilderness and Backcountry at Isle Royale National Park ........28 

2.1.1 Wilderness Management Philosophy .....................................................................28 

2.1.2 Guidelines from Existing Laws and Policy ...........................................................28 

2.2 The No Action Alternative ....................................................................................................34 

2.2.1 Wilderness Boundaries and Management ..............................................................34

2.2.2 Visitor Use and Experiences, Including Facilities and Services............................35 

2.2.3 NPS Administration and Operations ......................................................................38 

2.3 Actions, or Changes, that would be Common to all Action Alternatives .............................42 

2.3.1 Wilderness Boundaries and Management ..............................................................42 

2.3.2 Visitor Use and Experiences, Including Facilities and Services............................42 
x

2.3.3 NPS Administration and Operations ......................................................................45 

2.4 The Action Alternatives, Including the Preferred Alternatives ............................................55 

2.4.1 Description of Alternatives for Overnight Use of Isle Royale’s Wilderness and 

Backcountry ...........................................................................................................55 

2.4.2 Alternatives for Managing Day Use in the Wilderness and Backcountry .............79 

2.4.3 Alternatives for Campfires .....................................................................................83 

2.4.4 Alternatives for Fire Towers ..................................................................................86 

2.4.5 Alternatives for Picnic Tables ................................................................................88 

2.4.6 Summary of the Preferred Alternatives and Proposed Actions in 

Combination ...........................................................................................................92 

2.5 The Environmentally Preferred Alternative......................................................................... 95 

 

CHAPTER 3: AFFECTED ENVIRONMENT 96 

3.1 Visitor Use and Experiences .................................................................................................96 

3.1.1 Visitor Experiences and Opportunities ..................................................................96 

3.1.2 Visitor Use Patterns and Trends ............................................................................97 

3.1.3 Social Conditions .................................................................................................101 

3.1.4 Visitor Facilities and Services .............................................................................107 

3.2 Wilderness Character ..........................................................................................................111 

3.2.1. Naturalness ...........................................................................................................111 

3.2.2 Wilderness Experiences .......................................................................................112 

3.3 Natural Resources ...............................................................................................................113 

3.3.1 Geology and Soils ................................................................................................114 

3.3.2 Aquatic Resources ...............................................................................................115 

3.3.3 Wetlands and Floodplains ....................................................................................117 

3.3.4 Vegetation ............................................................................................................117 

3.3.5 Terrestrial Wildlife...............................................................................................120 

3.3.6 Threatened and Endangered Species ...................................................................124 

3.3.7 Natural Sounds and Sights ...................................................................................126 

3.4 Cultural Resources ..............................................................................................................133 

3.4.1 Historical Overview .............................................................................................133 

3.4.2 Archeological Sites ..............................................................................................134 

3.4.3 Historic Structures ...............................................................................................135 

3.4.4 Cultural Objects ...................................................................................................136 

3.4.5 Cultural Landscapes .............................................................................................136 

3.4.6 Ethnographic Resources.......................................................................................137 

3.5 Socioeconomic Environment ..............................................................................................137 

3.5.1 Surrounding Communities ...................................................................................137 

3.5.2 Business/Economic Activities Related to Wilderness and Backcountry .............139 

3.5.3 Economic Contributions of Isle Royale to the Region ........................................139 

3.6 Park Operations ...................................................................................................................140 

3.6.1 Organization .........................................................................................................140 

3.6.2 Staffing and Budget .............................................................................................140 
xi

3.6.3 Existing Facilities.................................................................................................141 

 3.6.4 Emergency Response Services......................................................... 142 

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 143 

4.1 Methodology .......................................................................................................................144 

4.1.1 Impacts to Visitor Use and Experiences ..............................................................144 

4.1.2 Impacts to Wilderness Character .........................................................................145 

4.1.3 Impacts to Natural Resources ..............................................................................147 

4.1.4 Impacts to Cultural Resources .............................................................................149 

4.1.5 Impacts to the Socioeconomic Environment .......................................................150 

4.1.6 Impacts to Park Operations ..................................................................................151 

4.1.7 Unavoidable Adverse Impacts .............................................................................152 

4.2 Assessment of Impacts ........................................................................................................153 

4.2.1 Impacts of Actions Common to All Alternatives ................................................153 

4.2.2 Impacts of Alternatives for Overnight Use of the Wilderness 

 and Backcountry ..................................................................................................165 

4.2.3 Impacts of Alternatives for Day Use of the Wilderness and Backcountry ..........195 

4.2.4 Impacts of Alternatives for Campfires .................................................................205 

4.2.5 Impacts of Alternatives for Fire Towers ..............................................................214 

4.2.6 Impacts of Alternatives for Picnic Tables ............................................................218 

4.3 Cumulative and Combined Effects of the Alternatives ......................................................225 

4.3.1 Cumulative Impacts .............................................................................................225 

4.3.2 Combined Effects.................................................................................................225 

4.4 Other Required Impact Topics ............................................................................................234 

 4.4.1 Short-term uses and long-term productivity ........................................................234 

 4.4.2 Irreversible or irretrievable commitment of resources.........................................234 

CHAPTER 5: PUBLIC COMMENT AND RESPONSES 235 

5.1 Characterization of Comments Received ............................................................................235 

5.2 Substantive Comments and Responses ...............................................................................235 

 5.2.1 Overall Plan and Actions Common to All ...........................................................236 

 5.2.2 Overnight Alternatives .........................................................................................247 

 5.2.3 Day Use Alternatives ...........................................................................................268 

 5.2.4 Campfires .............................................................................................................272 

 5.2.5 Fire Towers ..........................................................................................................273 

 5.2.6 Picnic Tables ........................................................................................................275 

GLOSSARY 277 

REFERENCES 280 
xii

APPENDICES 285 

A. Isle Royale National Park Enabling Legislation ...........................................................285 

B. Isle Royale National Park Wilderness Legislation .......................................................286 

C. Determination of Impairment .......................................................................................288 

D. Map Index .....................................................................................................................296 

Map 1: Region......................................................................................................297 

Map 2: Wilderness Designation ...........................................................................298 

Map 2b: Wilderness Designation – East ..............................................................299 

Map 3: Wilderness and Backcountry Facilities ...................................................300 

Map 4: Potential New Campgrounds (Alternative C for Overnight Use) ...........301 

Map 5: Potential New Trail (Alternative C for Day Use) ....................................302 

Map 6: Management Zones .................................................................................303 

E. Backcountry Camping Regulations for Isle Royale National Park ..............................304 

F. Cross-Country Regulations for Isle Royale National Park ...........................................305 

G. Isle Royale National Park Minimum Requirement Process .........................................306 

H. Isle Royale National Park State-Listed Flora and Fauna ..............................................311 

I. Minimum Requirement Process – Picnic Tables ..........................................................321 

J. List of Preparers, Consultation and Coordination.........................................................328 

K. Comments Received .....................................................................................................329 
xiii

TABLES 

Table 1: Potential Wilderness Areas on Isle Royale ......................................................................25 

Table 2: Acreage of Non-Wilderness Lands on Isle Royale..........................................................26 

Table 3: Park Management Zones and Goals for Social and Resource Conditions ......................30 

Table 4: Comparison of Alternatives for Overnight Use in the Wilderness and Backcountry ......76 

Table 5: Summary of the Preferred Alternatives ...........................................................................93 

Table 6: Ferry Schedules and Capacities (2004) .........................................................................100 

Table 7: Frequency of Parties Sharing Campsites at Different Visitation Levels .......................102 

Table 8: Frequency and Extent of Campgrounds Permitted Over Capacity in 2001 and Feasible 

Campsite Additions .......................................................................................................104 

Table 9: Overcrowding at campgrounds with only water access, 2001 .....................................106 

Table 10: Rates of Trail Encounters ............................................................................................107 

Table 11: Campgrounds and Associated Facilities ......................................................................109 

Table 12: Area and Exposed Soil of Isle Royale Campsites 1996-2002 .....................................110 

Table 13: Fledging Rates (per Territorial Loon Pair) at Selected Long-Term Monitoring Sites 123 

Table 14: Common Noise Levels and their Effects on the Human Ear .......................................127 

Table 15: National, State, and County Per Capita Incomes 1997-2001 ......................................138 

Table 16: National, State, and County Average Wages per Job 1997-2001................................138 

Table 17: Unemployment and Poverty Rates ..............................................................................138 

Table 18: Number of Backcountry Parties in Campgrounds .......................................................170 

Table 19: Comparison of Environmental Consequences for Alternatives for Overnight Use ....192 

Table 20: Comparison of Environmental Consequences for Alternatives for Day Use ..............204 

Table 21: Comparison of Environmental Consequences for Alternatives for Campfires ...........213 

Table 22: Comparison of Environmental Consequences for Alternatives for Fire Towers ........218 

Table 23: Comparison of Environmental Consequences for Alternatives for Picnic Tables ......224 

Table 24: Combination of Environmental Effects of all the Preferred Alternatives ..................231 
xiv

FIGURES

Figure 1: Types of Visitors to Isle Royale National Park (1997-2001) .........................................96 

Figure 2: Annual Island Visitation and Total Annual Visitor Overnights .....................................98 

Figure 3: Seasonal Distribution of Isle Royale Visitors ................................................................98 

Figure 4: Backcountry Overnights by User Group ........................................................................99 

Figure 5: Actual and Projected Number of Permits Issued (Alternative D for Overnight Use) ..183 
CHAPTER 1: INTRODUCTION 1

CHAPTER 1: INTRODUCTION

The purpose of this Wilderness and Backcountry Management Plan (WBMP) for Isle Royale 

National Park is to outline steps for preserving the park’s wilderness character, natural resources, 

and cultural resources while also providing for the use of and enjoyment by current and future 

generations. This involves preventing or reversing degradation of conditions within the park’s 

wilderness and backcountry, including natural and cultural resources, high quality human 

experiences, and wilderness character. Additionally this plan will provide accountability, 

consistency, and continuity for Isle Royale and its place in the National Park Service’s (NPS) 

wilderness management program.

Future changes in Isle Royale’s recreation and visitation patterns are difficult or impossible to 

predict, as are trends and changes in technologies available to visitors and land managers. The 

goal is not to freeze Isle Royale in its current state, but to ensure that these future changes do not 

result in a degradation of conditions and opportunities. One intent of this management plan is to 

establish guidelines to help park managers in planning for unpredictable future conditions with 

proactive efforts to maintain desirable conditions in the park’s wilderness and backcountry, and 

an ability to be responsive to future changes.

Several factors indicate a need for this wilderness and backcountry management plan:

1. National Park Service Policy requires that each park containing wilderness maintain an 

up-to-date and approved wilderness management plan that “...will identify desired future 

conditions, as well as establish indicators, standards, conditions, and thresholds beyond 

which management actions will be taken to reduce human impacts to wilderness 

resources” (NPS 2006, § 6.3.4.2). Isle Royale completed a Draft Backcountry 

Management Plan in 1985, but this plan was never approved or fully implemented, and 

many of the issues and recommended guidelines are now out of date. Completion and 

implementation of this new Wilderness and Backcountry Management Plan would bring 

Isle Royale into compliance with NPS policy requirements.

2. The park’s 1998 General Management Plan (GMP) generally addresses management 

issues for the wilderness and backcountry, but deferred to a WBMP for identification of 

specific issues and guidelines for addressing these issues. The GMP specified that the 

park’s WBMP “would guide management of wilderness resources and ensure consistency 

in such management over time. The plan would identify a process to determine the 

appropriate tools to use in wilderness, set priorities for campground and trail maintenance 

projects, and could incorporate the Visitor Experience and Resource Protection (VERP) 

implementation plan to address visitor use limits in wilderness, identify research and 

monitoring needs, outline how VERP will be implemented, and identify staffing needs.” 

(NPS 1998a, p.29)

3. Preliminary inventory and monitoring of wilderness and backcountry resources indicates 

a difference between existing conditions and proposed desired conditions. Changes in 

1.1 Purpose and Need for this Plan
2 CHAPTER 1: INTRODUCTION

backcountry use, management actions, and associated human-caused adverse impacts 

suggest an underlying need to more proactively manage human activities that directly or 

indirectly affect wilderness and backcountry conditions. Scoping during the GMP 

process identified several concerns related to wilderness and backcountry management, 

including; visitation levels and visitor density in the wilderness and backcountry, 

resource impacts and crowding in campgrounds, and insufficient visitor information 

services.

4. The park is lacking clear Isle Royale-specific guidelines to ensure that management 

actions and tools are appropriate, do not compromise wilderness character and values, 

and adhere to applicable laws and policies. It is important that these guidelines be 

developed with input from the public, other government agencies, and NPS partners. 

This Wilderness and Backcountry Management Plan addresses issues and provides guidelines for 

managing the non-developed areas of Isle Royale National Park. This includes all of the 

management zones outlined in the Park’s GMP, excluding the Open Water Motorized Zone and 

the Developed Zone, which consist of Rock Harbor, Windigo and the Mott Island Headquarters. 

Additionally, all visitors included in the overnight permitting system would be included in the 

scope of this plan. This includes all visitors staying in designated campsites, camping off-trail, 

staying at docks, and anchoring out. 

This plan addresses backcountry as well as wilderness in the Park in order to cohesively manage 

all of Isle Royale's non-developed areas. Although there is no intention to expand wilderness 

restrictions, many goals for backcountry and wilderness management are similar. Wilderness 

issues in the park are rarely limited to the wilderness boundaries. For example, backcountry 

campgrounds found both within and outside of wilderness are similarly managed. Wilderness 

and non-wilderness campgrounds on Isle Royale cannot always be distinguished by facilities, 

types of visitors, or permitted activities. For this reason, it seems most appropriate to manage 

backcountry and wilderness in Isle Royale with one cohesive plan, and distinct from the 

management of the park's developed areas and the open motorized waters of Lake Superior.

Isle Royale’s goals and objectives are based on the park’s legislation (see Appendix A and B), 

NPS policy, and the 1998 GMP and were drafted with input from the public. In the 1931 

Congressional Record, NPS Director Albright highlighted some of the intended purposes for 

establishing Isle Royale as a National Park. 

This type of scenery, utterly distinct from anything now found in our national park 

system, its primitiveness, its unusual wildlife and interesting flora, its evidences of 

1.2 Scope of this Plan

1.3 Goals and Objectives of Wilderness and Backcountry Management for Isle Royale 

National Park
CHAPTER 1: INTRODUCTION 3

possible prehistoric occupation, all combine to make Isle Royale and its neighboring 

islands of national park caliber. 

1.3.1 Management Goals

The primary goal for managing Isle Royale’s wilderness and backcountry is to protect its 

resources while also providing for the enjoyment of current and future generations. As defined 

in the GMP, one of Isle Royale’s primary management purposes is to preserve and protect the 

park’s wilderness character for use and enjoyment by future generations as wilderness. 

Wilderness character is the combination of biophysical, experiential, and symbolic qualities in an 

untrammeled and natural state that generally appears to have been affected primarily by the 

forces of nature, with the imprint of man’s work substantially unnoticeable.

1.3.2 Objectives

• Manage Isle Royale’s wilderness and backcountry consistent with the preservation of 

wilderness character wherein nature is the primary influence and human works are 

minimal and substantially unnoticeable.

• To ensure preservation of wilderness character, use only the minimal tools, facilities and 

management techniques necessary to meet management objectives.

• Preserve cultural resources in Isle Royale’s wilderness and backcountry and foster their 

appreciation through appropriate programs of protection, research, education, monitoring, 

and treatment.

• Manage human use of Isle Royale so visitors have opportunities to experience solitude, 

remoteness, challenge, self-sufficiency, and discovery as appropriate in wilderness.

• Through interpretation and education, provide public and park staff education designed to 

promote and perpetuate awareness of, and appreciation for, wilderness character, 

resources, and ethics.

• Preserve the integrity of Isle Royale’s unique ecological community and its natural 

processes, while allowing for appropriate wilderness activities including recreation, 

scientific research, conservation, education, and preservation of cultural resources.

• Work with other agencies, institutions, governments, tribal governments, and the public, 

both within and outside the Great Lakes region, to foster a better understanding and 

awareness of wilderness preservation issues and goals at Isle Royale. This includes 

adverse impacts originating outside of the park as well as within, and on both global and 

regional scales.

Management of Isle Royale National Park’s wilderness and backcountry must be consistent with 

the laws, regulations, and policies of the Federal Government. The following summarizes the 

most relevant laws, policies, and authorities governing management of Isle Royale’s wilderness 

and backcountry.

1.4 Laws, Policies, and Authorities
4 CHAPTER 1: INTRODUCTION

1.4.1 Federal Laws and Provisions governing Isle Royale WBMP

The Wilderness Act of 1964 (16 USC §1131 et seq.) secures "for the American people of present 

and future generations the benefits of an enduring resource of wilderness." By definition, 

wilderness is “...a tract of undeveloped federal land of primeval character without permanent 

improvements or human habitation; an area where the earth and its community of life are 

untrammeled by man, where man himself is a visitor who does not remain; where the forces of 

nature predominate and the imprint of human activities is substantially unnoticeable; which 

provides outstanding opportunities for solitude or a primitive and unconfined type of recreation.” 

This act allows for the designation of wilderness areas and establishes management directives 

that specify the preservation of wilderness character.

The National Environmental Policy Act of 1969 (NEPA) (P.L. 91-190, 42 USC §4321 et seq.) 

establishes “a national policy which will encourage productive and enjoyable harmony between 

man and his environment.” NEPA requires all government agencies to develop procedures that 

ensure open and honest documentation of existing resources and potential effects to these 

resources as a result of the proposed action. NEPA fosters public involvement as a key element 

of the decision-making process. NEPA compliance procedures are described in NPS Director’s 

Order 12, Conservation Planning, Environmental Impact Analysis, and Decision Making and the 

accompanying Reference Manual (NPS 2001a). 

The Endangered Species Act of 1973 (16 USC 1531-1543) requires federal agencies to ensure 

that management activities authorized, funded, or carried out by the agency do not jeopardize the 

continued existence of listed endangered or threatened species, or result in the destruction or 

adverse modification of habitat that is critical to the conservation of the species.

The Clean Air Act of 1977 (42 USC 7401-7626) was established to improve the nation’s air 

quality and to eliminate certain pollutants linked to problems for human health or the 

environment. This act establishes National Parks greater than 6,000 acres (such as Isle Royale

National Park) as mandatory Class I areas with only minor degradation of air quality allowed. 

Managers of such lands have direct responsibility to take steps to protect the air quality and 

related values, including visibility. Executive Order 12088 (1978) requires federal agencies to 

comply with all provisions of the Act, including State Implementation Plans. This Executive 

Order establishes procedures and responsibilities to ensure that all necessary actions are taken to 

prevent, control and abate environmental pollution with respect to federal facilities and activities.

The National Historic Preservation Act of 1966 (Section 106), amended, 1976, 1980, 1992 (16 

USC 470) directs the federal government to "preserve the historical and cultural foundations of

the nation as a living part of our community life and development in order to give a sense of 

orientation to the American people”. A key element of the act is the establishment of the 

National Register of Historic Places (NRHP). Federal agencies are directed to not inadvertently 

demolish, substantially alter, or allow NRHP listed properties to significantly deteriorate. Section 

106 also includes criteria for designating National Historic Landmarks; directives for the 

Secretary of Interior to nominate properties of international significance as World Heritage Sites; 

and the establishment of State Historic Preservation Programs and Preservation Officers (SHPO) 

to direct statewide inventories of historic properties, administer the NRHP, and advise 
CHAPTER 1: INTRODUCTION 5

government agencies regarding compliance with the act. Section 106 requires Federal agencies 

to take into account the effect of their undertakings on properties listed in or eligible for the 

National Register. 

The Americans with Disabilities Act of 1990 (ADA) (P.L. 101-336) provides comprehensive 

civil rights protection to individuals with disabilities in the areas of employment, public 

accommodations, state and local government services, and telecommunications. Wilderness 

access is treated separately from access to public accommodations. Section 507(c) specifically 

addresses the issue of federal wilderness access stating, "Congress reaffirms that nothing in the 

Wilderness Act is to be construed as prohibiting the use of a wheelchair in a wilderness area by 

an individual whose disability requires use of a wheelchair, and consistent with the Wilderness 

Act no agency is required to provide any form of special treatment or accommodation, or to 

construct any facilities or modify conditions of lands within a wilderness area to facilitate such 

use.”

The Clean Water Act (Federal Water Pollution Control Act of 1972, 1977 and 1987 

Amendments, and E.O. 11752) is a national policy set forth to protect and enhance the quality of 

water resources and to prevent, control, and abate water pollution. This act requires a permit for 

a point source to discharge pollutants into navigable waters and a permit from the U.S. Army 

Corps of Engineers for any discharge of dredge or fill material into “waters of the U.S.” This act 

prohibits discharge of oil or other hazardous materials in harmful quantities.

The American Antiquities Act of 1906 prevents the excavation and destruction of historic or 

prehistoric ruins or monuments on government controlled and owned lands. Persons found on 

government land without permission would be convicted and fined no more than five hundred 

dollars or would be imprisoned no more than ninety days, or could suffer both fine and 

imprisonment.

E.O. 11593 "Protection and Enhancement of the Cultural Environment," May 31, 1971

instructs all federal agencies to provide national leadership in historic preservation and to assure 

the preservation of cultural properties in federal ownership. The order directs all federal 

agencies to locate, inventory, and nominate all sites, buildings, districts, and objects under their 

jurisdiction or control that appear to qualify for listing on the National Register of Historic 

Places.

American Indian Religious Freedom Act of 1978 (AIRFA) (P.L. 95-341; 92 Stat. 469; 42 USC 

1996) determines that the policy of the United States is to "protect and preserve for American 

Indians their inherent right of freedom to believe, express and exercise the traditional religions of 

the American Indian, Eskimo, Aleut and Native Hawaiians, including but not limited to site 

access, use and possession of sacred objects, and the freedom to worship through ceremonial and 

traditional rites." 

The Archaeological Resources Protection Act of 1979 (16 USC 470aa-470ll) defines 

archeological resources as any material remains of past human life or activities that are of 

archeological interest and are at least 100 years old. This act provides for the protection of 

archeological resources located on public and Indian lands, and establishes criteria for issuing 
6 CHAPTER 1: INTRODUCTION

permits for any excavation or removal. Per this act, information concerning the nature and 

location of archeological resources may be exempt from the Freedom of Information Act.

1.4.2 National Park Service Provisions

The National Park Service Organic Act of 1916 (16 USC 1a-1) creates the NPS, and establishes 

its purpose: "to conserve the scenery and the natural and historic objects and the wild life therein 

and to provide for the enjoyment of the same in such manner and by such means as will leave 

them unimpaired for the enjoyment of future generations." It directs the NPS to promote and 

regulate the use of the parks by such means and measures as conform to their fundamental 

purposes. Congress and the courts have interpreted this act with clarification that “when there is 

a conflict between conserving resources and values and providing for enjoyment of them, 

conservation is to be predominant” (NPS 2006, § 1.4.3). 

The National Parks and Recreation Act of 1978 (P.L. 95-625) addressed planning in the 

National Parks, directing that long-term planning for parks should address the preservation of 

park resources, the types and general intensities of development and facilities, visitor carrying 

capacities, and potential boundary modifications.

Redwoods Act of 1978 (16 USC 1a-1) amends the Organic Act to reemphasize Congressional 

direction for all NPS lands and states, "the protection, management, and administration of these 

areas shall be conducted in light of the high public value and integrity of the National Park 

System and shall not be exercised in derogation of the values and purposes for which these areas 

have been established”.

National Park Service Management Policies, 2006 establishes service-wide policies for 

preservation, management, and use of park resources and facilities, "The National Park Service 

will manage wilderness areas for the use and enjoyment of the American people in such manner 

as will leave them unimpaired for future use and enjoyment as wilderness. Management will 

include the protection of these areas, the preservation of their wilderness character, and the 

gathering and dissemination of information regarding their use and enjoyment as wilderness. 

The public purpose of wilderness in the national parks includes the preservation of wilderness 

character and wilderness resources in an unimpaired condition, as well as for the purposes of 

recreation, scenic, scientific, education, conservation, and historical use”. More specific 

guidelines for application of the Wilderness Act in NPS areas are described in Chapter 6 of 

Management Policies. Topics include wilderness qualification reviews, wilderness management, 

wilderness use, and public education. Wilderness management policies are based on provisions 

of the Wilderness Act and the Organic Act, as well as the establishing legislation of individual 

parks within the national system.

National Park Service Management Policies, 2006, “Impairment” and “Derogation”: One 

Standard (Section 1.4.2) further establishes guidance by referencing the fundamental purpose of 

the national park system, established by the Organic Act and reaffirmed by the General 

Authorities Act, as amended, which begins with a mandate to conserve park resources and 

values. NPS managers must always seek ways to avoid, or to minimize to the greatest degree 

practicable, adverse impacts on park resources and values. However, the laws do give the 
CHAPTER 1: INTRODUCTION 7

National Park Service the management discretion to allow impacts on park resources and values 

when necessary and appropriate to fulfill the purpose of the park. That discretion is limited by 

the statutory requirement that the National Park Service must leave resources and values 

unimpaired unless a particular law directly and specifically provides otherwise. Prohibited 

impairment is an impact that, in the professional judgment of the responsible NPS manager, 

would harm the integrity of park resources or values, including the opportunities that otherwise 

would be present for the enjoyment of those resources or values. Whether an impact meets this 

definition depends on the particular resources that would be affected; the severity, duration, and 

timing of the impact; the direct and indirect effects of the impact; and the cumulative effects of 

the impact in question and other impacts. An impact on any park resource or value may, but 

does not necessarily, constitute impairment. An impact would be more likely to constitute 

impairment to the extent that it affects a resource or value whose conservation is: 

• necessary to fulfill specific purposes identified in the establishing legislation or 

proclamation of the park, or

• key to the natural or cultural integrity of the park or to the opportunities for 

enjoyment of the park, or

• identified in the park’s general management plan or other relevant NPS planning 

documents as being of significance.

An impact would be less likely to constitute impairment if it is an unavoidable result of an action 

necessary to preserve or restore the integrity of park resources or values and cannot be further 

mitigated. Additionally, impairment may result from visitor activities; NPS administrative 

activities; or activities undertaken by concessioners, contractors, or other operating in the park. 

Impairment may also result from sources or activities outside the park. Impairment findings are 

not necessary for visitor experience, socioeconomics, public health and safety, environmental 

justice, land use and park operations, etc., because impairment findings relate back to park 

resources and values. The determination of impairment for the preferred alternative is found in 

Appendix C, beginning on page 283.

Director’s Order 41 and Reference Manual 41: Wilderness Preservation and Management, 

Draft 2011 & 1999 respectively provides clarification and interpretation of the National Park 

Service’s wilderness policies and establishes specific guidelines to provide accountability, 

consistency, and continuity to the Service’s wilderness management program. Topics include 

wilderness management planning, management techniques, Minimum Requirement Concept, 

interagency coordination, interpretation and education, scientific activities, facilities, signs, fire 

management, cultural resources, general public use, persons with disabilities, commercial 

services, special events, air quality, mineral development and training requirements.

1.4.3 Provisions Specific to Isle Royale National Park

Isle Royale National Park Act, March 3, 1931 (46 Stat. 1514) established Isle Royale National 

Park. The purpose for establishment stated in 16 USC, Subchapter LII, Section 408 

follows:”...said area shall be, and is hereby, established, dedicated, and set apart as a public park 

for the benefit and enjoyment of the people and known as the Isle Royale National Park.” The 

park was officially established April 3, 1940 after all the land had been acquired. 
8 CHAPTER 1: INTRODUCTION

Isle Royale Wilderness Designation, October 20, 1976 designated 98 percent of the park’s land 

area as wilderness (later additions brought the total to 99 percent). Additional areas of the park 

are currently “potential wilderness.” All designated and potential wilderness areas must be 

managed according to management directives found in the Wilderness Act of 1964.

Isle Royale National Park Biosphere Reserve, November 20, 1980 designation as a Biosphere 

Reserve by the United Nations Educational, Scientific and Cultural Organization (UNESCO). 

As a Biosphere Reserve, Isle Royale National Park is part of a network of outstanding examples 

of major ecosystems preserved for scientific research, conservation of nature and the service of 

man. Under the Man and the Biosphere Program, biosphere reserves provide a standard against 

which the effects of man on the environment can be measured.

Isle Royale National Park General Management Plan (GMP), August 1998 establishes the 

guidelines for the overall use, preservation, management, and development of Isle Royale 

National Park. The GMP articulates a management philosophy and framework for decisionmaking and problem solving. The GMP provides park purpose, significance and emphasis 

statements to guide future actions. The GMP divides the park into zones of activity to provide a 

separation of uses to enhance visitor enjoyment and to preserve the natural and cultural resources 

of the park in a way that is compatible with the Wilderness Act.

Isle Royale National Park Superintendent’s Compendium, as amended, May 2011 summarizes 

park specific rules implemented under the discretionary authority of the park Superintendent. 

Serves as public notice, identifies areas closed for public use, provides a list of areas requiring 

either a special use permit or reservation and elaborates on public use and resource protection 

regulations that pertain specifically to the administration of Isle Royale National Park. The 

Compendium does not repeat regulations found in 36 CFR and other U.S.C. and CFR titles, 

which are enforced without further elaboration at the park level.

1.4.4 State Jurisdiction Over Lake Superior Waters

In 1939, the State of Michigan ceded exclusive jurisdiction of Isle Royale including any 

submerged lands within four and one-half miles of the shoreline of Isle Royale and immediately 

surrounding islands to the United States. However, as part of this agreement the State of 

Michigan retained the authority to regulate fishing in the Lake Superior Waters of the park. 

Commissioned Officers of the National Park Service, Bureau of Indian Affairs, Tribal Fish and 

Game Officers, and the Michigan DNR all have Jurisdiction and Authority to enforce fishing 

regulations in the Lake Superior waters of the Park. The National Park Service and the United 

States Coast Guard have Jurisdiction & Authority to enforce Marine Safety Regulations such as 

boat registration, required safety equipment, water pollution regulations, etc.

Wilderness and backcountry management is an iterative process, with ongoing monitoring 

informing managers of the effectiveness of their actions and identifying when changes are 

needed to meet management goals and objectives. This calls for some flexibility in the WBMP, 

1.5 Plan Review and Update
CHAPTER 1: INTRODUCTION 9

but the specific direction and desired future conditions established in the final plan will remain as 

the management guideline. A WBMP is expected to have a lifespan of 10-15 years, with 

periodic reviews and assessments throughout that time. Environmental, social, and political 

conditions change, as does the information available to most effectively manage public lands, 

and it is not the intent of this plan to freeze conditions. Over time, changing conditions may call 

for a different management approach to meet Isle Royale’s mission. Within 10-15 years, the 

WBMP will be assessed as to the need for a thorough revision. Within five years the WBMP 

will be updated with specific decisions and additions including indicators and standards.

Isle Royale’s Wilderness and Backcountry Management Plan is to be consistent with existing, 

updated management plans. Additionally, it outlines detailed goals for resource, social, and 

managerial conditions within the park’s backcountry and wilderness, which will be relevant for 

all management plans involving issues and actions affecting the park’s wilderness and 

backcountry, either directly or indirectly. All of the park’s plans are intended to be 

complementary and consistent. Full public disclosure and justification would be required where 

any management plan alters a decision or direction outlined in a previous plan.

Current Isle Royale Management Plans that the WBMP complements:

• General Management Plan (1998)

• Natural Resources Management Plan (1999)

• Comprehensive Interpretive Plan (2000)

• Fire Management Plan (2004)

• Aviation Management Plan (2008)

• Water Resources Management Plan (2005)

Upcoming Management Plans that will be consistent with the WBMP:

• Wilderness and Backcountry Monitoring and Implementation Plan

• Fisheries Management Plan

• Commercial Services Plan

• Cultural Resources and/or Historic Properties Management Plan

The National Environmental Policy Act of 1969 (NEPA) is a national charter for protecting the 

environment. It applies to all federal projects or projects that require federal involvement. The 

purpose of NEPA is to help public officials make decisions that are based on an objective 

understanding of environmental consequences and to take actions that protect, restore, or 

enhance the environment. Another important purpose of NEPA is to inform the public of 

decisions being made that affect public lands. The public is then able to provide feedback to the 

decision-makers before the plan is implemented. To ensure compliance with NEPA, a specified 

process for proposed projects must be followed. The steps in this process are presented below. 

1.6 Relationship between this Plan and Other Isle Royale Management Plans

1.7 The Planning Process
10 CHAPTER 1: INTRODUCTION

1.7.1 The Visitor Experience and Resource Protection (VERP) Planning Framework 

VERP is a planning framework that was developed by the NPS to help park planners and 

managers work within the requirements of NEPA and specifically address visitor carrying 

capacity and make sound decisions about visitor use management. Isle Royale initially 

implemented this process for the completion of the park’s GMP, and continued with VERP as 

the guiding framework for the WBMP. The VERP framework consists of 9 primary elements,

some of which Isle Royale completed through the park’s GMP:

1. Assemble an interdisciplinary project team

2. Develop a public involvement strategy

3. Develop statements of park purpose, significance, and primary interpretive themes 

(completed in the GMP); identify planning constraints

4. Analyze park resources and the existing visitor use

5. Describe a potential range of visitor experiences and resource conditions as potential 

prescriptive management zones (completed in the GMP)

6. Allocate the potential management zones to specific locations in the park (completed in 

the GMP)

7. Select indicators and specify standards for each zone to established acceptable or desired 

conditions; develop a monitoring plan

8. Monitor resource and social indicators

9. Take management action to achieve specified standards or desired conditions

One of the key points of VERP is planning for a park’s visitor carrying capacity, as mandated by 

law in the National Parks and Recreation Act of 1978 (P.L. 95-625). Within VERP visitor 

carrying capacity is defined as “the type and level of visitor use that can be accommodated while 

sustaining acceptable resource and social conditions that complement the purpose of a park” 

(NPS 1997a, p.8). Inherent in this process is an understanding of a park’s purposes, resultant 

appropriate resource and social conditions, and that management will be an iterative process 

involving monitoring, evaluation, and taking action to achieve desired conditions. In summary, 

VERP is:

A planning and management framework that focuses on visitor use impacts on the visitor 

experience and the park resources, These impacts are primarily attributable to visitor 

behavior, use levels, types of use, timing of use, and location of use. (NPS 1997a, p.9)

1.7.2 Interdisciplinary Planning Team

An interdisciplinary planning team was formed at the start of the process of developing a WBMP 

for Isle Royale. This team consists of a core of Isle Royale employees who are managers and 

subject matter experts with expertise relevant to the WBMP. This group had primary 

responsibility for all phases of the planning process and plan development. In addition to this 

core group, assistance and consultation were periodically requested from a planner with the NPS 

Denver Service Center and researchers from the Interagency Aldo Leopold Wilderness Research 

Institute, the University of Minnesota, University of Montana, University of Vermont, Virginia 

Technological University, and Michigan Technological University. The core planning team 

from Isle Royale included:
CHAPTER 1: INTRODUCTION 11

• Superintendent

• Assistant Superintendent

• Chief of Maintenance

• Facilities Manager

• Trails Foreman

• Program Analyst

• Chief Ranger

• West District Ranger

• East District Ranger

• Chief of Natural Resources 

Management

• Lead Biological Sciences Technician

• Natural Resources Specialist, 

Wilderness Coordinator

• Cultural Resources Program 

Manager

• Chief of Interpretation

1.7.3 Scoping

Public participation and input are critical aspects of a park planning effort, for identifying issues 

of concern, reviewing proposals, and informing the planning team and decision-makers. The 

first phase of public involvement in the NEPA planning process is scoping, which is designed to 

be an early, open public process to identify the scope, issues, and feasible actions of an 

environmental document. Scoping for Isle Royale’s WBMP consisted of 4 newsletters sent to a 

mailing list of nearly 1,400 individuals and organizations with approximately 700 written 

responses received, postings on the park’s website soliciting email comments, and several public 

meetings, including 3 focus group meetings on the island in the summer of 2000, and 3 public 

meetings in 2002 and 2003 held in Duluth, MN and Hancock and East Lansing, MI. In total, 

approximately 150 individuals were involved in these meetings. Additional public input relevant 

to the WBMP was gathered through different surveys of park visitors in 1996, 1997, 2000, and 

2002 (see section 1.7.5). 

The “public” who are included in this scoping are people who value Isle Royale, and may or may 

not be visitors. This public includes past and future visitors, researchers, people connected to the 

cultural history of the island, educational groups, students and researchers, local communities, 

business owners, and past and present employees of Isle Royale or concessions businesses. It 

also includes people who may never visit the park, but care about protecting Isle Royale into the 

future. 

The public was further encouraged to review and comment on the draft Wilderness and 

Backcountry Management Plan. The release of the draft plan and open public comment period 

were announced in the Federal Register on October 21, 2005, and further announced through 

television, radio, print, and internet media, with press releases sent to media outlets throughout 

Michigan, Wisconsin, Minnesota, Illinois, Ohio, New York, Colorado, Washington DC, and 

Ontario, Canada. The full text of the draft plan was available on the Isle Royale National Park 

website, at several regional libraries, and on CD mailed to individuals and organizations, as 

requested. Public comments were also solicited through mailings, distribution of comment forms, 

and a public open house held at the park headquarters in Houghton Michigan (December 12, 

2005); approximately 10 people attended. During the 60-day comment period, a total of 40 

written comments were received via mail, email, fax, and in-person from individuals and 

organizations. The comment period ended Dec 21, 2005. After the comment period ended, the 

planning team reviewed comments on the draft document, identified substantive comments, and 

determined if revisions needed to be made to address the comments. Based on the comments that 
12 CHAPTER 1: INTRODUCTION

were received, modifications to the proposed alternatives and analysis of environmental 

consequences were made, but no major changes were made. All written comments, substantive 

comments identified, and responses to these comments, including an explanation of any 

modifications that were made to the plan or why changes were not made based on substantive 

comments, are included in Chapter 5, starting on page 235 of this document. 

A minimum of 30 days after the publication of this final study / environmental impact statement, 

a record of decision will be prepared and published in the Federal Register. This record of 

decision will document what action the National Park Service intends to take regarding 

implementation of a final wilderness and backcountry management plan for Isle Royale National 

Park.

1.7.4 Prevalent Issues and Concerns Raised by the Public

All written public comments were reviewed by the planning team. Additional comments that 

have been voiced to park staff throughout the scoping period were documented and shared with 

the planning team. All of this input was reviewed for substantive comments to be considered in 

developing the WBMP and EIS. Substantive comments are defined by NPS policy as those that 

do one of the following: a) question, with reasonable basis, the accuracy of information in an 

EIS, b) question, with reasonable basis, the adequacy of environmental analysis, c) present 

reasonable alternatives other than those presented in the EIS, or d) cause changes or revisions in 

the proposal. Comments that only agree or disagree with NPS policy are not considered 

substantive (NPS 2001a, p. 61). Several prevalent issues and concerns with direct relevance to 

the goals of the WBMP emerged from the public comments and were addressed in this draft 

plan. These issues include:

Public access to the park

There was mixed public opinion about whether the NPS should be encouraging more 

annual visitation or less. Specific discrepancies included disagreement over whether or 

not to encourage more people to visit the park during the lower use times, whether or not 

to further limit commercial groups, whether or not to include self-contained boating 

visitors in any use limits, and if the park should limit access during the peak in visitation 

or simply offer more information about busy times and areas and let people make their 

own choice of if and when to visit. In addition, a recurring concern was that Isle Royale 

is already expensive and difficult to access and the NPS should not make it more so. 

Each of the alternatives for overnight use of the park’s wilderness and backcountry 

explore different options for addressing these concerns.

Freedom and flexibility of travel within the park

Many people expressed the opinion that maintaining the flexibility to alter travel plans is 

important for visitor safety and appropriate for unconstrained wilderness experiences. 

This was considered in drafting the alternatives for overnight use of the wilderness and 

backcountry, and was also considered in evaluating the implications of each alternative.

Crowding

Generally public comments revealed mixed opinions about crowding in the park. Of 

particular concern is the issue of overcrowding in campgrounds and a need to double up 
CHAPTER 1: INTRODUCTION 13

when there are not enough campsites available for the number of camping parties. Many 

others expressed the opinion that crowding is not an issue, that meeting and interacting 

with other people is part of the Isle Royale experience that they value. Similarly, some 

suggested that the problem is in the NPS creating unrealistic expectations for visitors, and 

there should be less emphasis on promoting the island as a pristine wilderness. Many 

others expressed an opinion that current levels of crowding compromise the quality of 

their trip, resulting in impacts that are not appropriate for wilderness, that socializing and 

sharing campsites should be a choice not an expectation. More specifically, some people 

pointed out that the park should address crowding on trails as well as in campgrounds, 

that the number of visitors may be less important than their behavior, and that they would 

sacrifice some flexibility in planning a trip to the island if it meant that the park would be 

less crowded. Each of the alternatives for overnight use of the park’s wilderness and 

backcountry explore different options for addressing these concerns, and this plan 

presents a range of alternatives that would offer different social conditions.

Backcountry regulations and policies

Many people offered suggestions for better managing visitation in the park’s wilderness 

and backcountry, again with some conflicting interests. Some people suggested 

encouraging more camping off trail and anchoring out to alleviate pressure on 

campgrounds, while others were concerned that doing this would result in unacceptable 

impacts to pristine areas. Some people like the idea of implementing a fixed itinerary 

campsite reservation system for the assurance of finding a private campsite at the end of 

the day. Others expressed concern that a reservation system would be costly, overly 

restrictive, difficult to enforce, and create more visitor conflicts. There was general 

agreement however that regulations and any system for permitting should be kept as 

simple as possible. These issues were considered in evaluating current wilderness and 

backcountry policies and incorporated into alternatives for changes. Additionally these 

concerns will remain a consideration for the WBMP’s implementation plan.

Protection of the park’s resources

A common concern was protection of the park’s resources in general, with additional 

concern for human impacts on specific wildlife species. Some of the specific concerns 

included the impact of motorboats on wildlife and water quality, adverse human impacts 

on loons, and concern for changes in human use that would increase wolf-human 

encounters and could lead to wolves becoming habituated to people. A general concern 

was that increased development designed to accommodate visitation demands for a small 

portion of the season conflicts with protecting the park’s resources. Another concern was 

that additional information about impacts to resources was needed before people could 

respond to proposed actions. These concerns were all considered in developing all of the 

alternatives presented in the WBMP

Protection of wilderness character

Many people expressed support for the general protection of wilderness character in the 

park. Some comments suggested that current conditions on Isle Royale compromise 

wilderness character in terms of loss of opportunities for solitude, too much human 

contact, excessive development and size of campgrounds, off-trail impacts from camping, 
14 CHAPTER 1: INTRODUCTION

regulations that limit spontaneity and flexibility, and the impacts of NPS operations. One 

suggestion that came of these concerns was to keep the interior of the island difficult to 

access for a more remote, wilderness feel. This issue was given varying weight in each 

of the alternatives presented and maintaining wilderness character remains a fundamental 

management goal for the park.

Options for a range of user groups and diverse visitors

Some people emphasized that Isle Royale is not just wilderness and it is important for the 

NPS to maintain options for non-wilderness visitors as well. Specific concerns expressed 

included maintaining access and opportunities for motor boating visitors, and increasing 

handicapped and elderly accessibility to the park and trails. These concerns were 

considered in drafting alternatives for overnight use in the wilderness and backcountry, 

and were a significant consideration for alternatives for managing day use in the park.

There were mixed opinions about separating different user groups, with some suggesting 

that park managers should increase separation of use by creating hiker-only and paddleronly campgrounds, and others requesting that the park not totally separate users to 

maintain motor boaters’ access to the main island and trails. The issue of separation of 

users was primarily addressed in the GMP, but also became a consideration in the 

WBMP.

Maintaining appropriate facilities and services for visitors

People shared many concerns and suggestions related to the park’s visitor services and 

facilities. Many agreed that the park should improve information and education services 

available for visitors, improve the design of campsites to increase privacy, reduce noise, 

and stop the policy of overbooking campgrounds. In other areas opinions differed. For 

example, some people felt there should be more campgrounds in the park, or that the 

existing campgrounds should be expanded, while others felt that no new campgrounds 

should be added or that existing campgrounds should be smaller. Some suggested that 

additional ferry or shuttle services should be offered to make it easier to start a trip from 

trailheads in the middle of the island, while others thought the middle of the island should 

remain remote and less traveled. These concerns and suggestions were considered 

throughout the WBMP and incorporated into proposed alternatives. 

Cost and feasibility of implementing changes

Some people raised the concerns over the cost and feasibility of implementing different 

proposed changes. For example, some pointed out that effective implementation will 

require adequate staffing in the wilderness and backcountry and should remain realistic 

for staff and the park’s budget, while others emphasized that management of any new 

permitting system should remain within the park, rather than being contracted out to an 

off-site organization. The cost and feasibility of alternatives proposed will be analyzed in 

more detail in an upcoming WBMP implementation plan.
CHAPTER 1: INTRODUCTION 15

1.7.5 Research and Data Collection

Research and data collection have been an essential part of the planning framework, contributing 

to a better understanding of human impacts, current resource and social conditions, a comparison 

between current conditions and desired conditions, and implications of proposed changes. The 

following research and data collection projects have most directly contributed to the 

development of the WBMP:

Visitor surveys 1996-1997

During the summer seasons of 1996 and 1997 the University of Minnesota surveyed 

1,017 island visitors. The detailed surveys asked visitors to comment on their 

expectations for Isle Royale, perceptions of conditions in the park, and preferences for 

conditions and management actions (Pierskalla and others 1997, Pierskalla and others 

1998).

Campground Monitoring 1996-2002

In 1996 Isle Royale and Virginia Technological University completed a baseline 

inventory of biophysical impacts in the park’s campgrounds. This project was 

established for long-term monitoring of changing physical conditions in campgrounds. 

Monitoring continued with a complete survey of campgrounds in 2002. This project 

describes current and changing conditions in campgrounds related to human impacts, 

such as changes in total impacted area of campsites, amount of exposed soil, damage to 

trees, loss of vegetation, and erosion (Farrell and Marion 1998).

Visitor Surveys of Crowding in Campgrounds and on Trails

In 2000, 268 visitors completed trip diaries, reporting the number of encounters they had 

with others on trails and waterways, and the frequency of finding campgrounds full or 

needing to share campsites in overfull campgrounds. At the same time NPS staff 

collected similar data, and permit data were analyzed for accuracy and effectiveness in 

reporting visitor distribution and crowding. This project helped to better understand 

visitor distribution and areas of crowding in the park’s wilderness and backcountry, as 

well as giving guidance for ongoing monitoring. It was completed in partnership with the 

University of Montana (Mayo Kiely 2001).

Common Loon Territory Atlas 

A detailed atlas of nesting sites and breeding territories for Common Loons in the park 

was completed between 1998 and 2000. The atlas helped to identify sensitive areas in the 

wilderness and backcountry (Kaplan and others 2002).

Effects of Paddlers on Loon Nesting Success

Visitor surveys and field observations along Isle Royale’s inland lakes and Lake Superior

paddler routes studied the relationship between paddler behavior and loon nesting 

success. The study focused primarily on paddler travel patterns and proximity to active 

loon nests. This project helped to identify nesting loons’ tolerance for paddler 
16 CHAPTER 1: INTRODUCTION

encounters, as well as possible management actions to minimize nest failures (Kaplan et 

al. 2003). 

Computer Modeling of Visitor Distribution in Campgrounds

In 2001 and 2002 the University of Vermont worked with Isle Royale staff to create a 

computer simulation model designed to project campground occupancy at different rates 

of park visitation. This is a valuable tool for better understanding campground use levels 

at different times of the season, in different years, with varying visitation levels at each of 

the park’s entry points, and in specific areas of the park. It also helps to develop a 

detailed picture of visitors’ travel patterns in the wilderness and backcountry. Ongoing 

ground-truthing has validated the model’s ability to represent current conditions. 

Additionally, this model is a useful tool for analyzing the likely implications of 

management actions that would change visitors’ travel patterns, visitor distribution in the 

park, or overall park visitation at different points in the season (Lawson and Manning 

2003a). 

Visitors’ Stated Choice Surveys 

In 2002, 150 island visitors completed surveys identifying their preferred choices for 

different possible management actions to address campground crowding. Visitors were 

asked to consider implications and trade-offs between some of the management options 

available. This survey asked for people’s preferences between different options for 

reducing campsite sharing, allowing flexible or fixed itinerary permits, increasing or 

reducing visitation levels, and either adding new campsites or maintaining existing 

campground capacities. This survey helped to identify some of the more salient issues 

that determine people’s preferences for managing camping in Isle Royale’s wilderness 

and backcountry (Lawson and Manning 2003b). 

Ongoing Natural and Cultural Resources Monitoring

Other long-term research and monitoring projects offer critical information pertinent to 

managing Isle Royale’s wilderness and backcountry. These projects include; wolf and 

moose study, monitoring of eagle and osprey nests, frog and toad monitoring, songbird 

monitoring, atmospheric studies, terrestrial and aquatic contaminant studies, monitoring 

and treating invasive exotic species, monitoring rare plants and their communities, 

monitoring colonial shorebirds, monitoring forest structure and nutrient cycling, fire 

ecology, monitoring lake ecosystems and species composition, archeological surveys, 

monitoring cultural sites, listing classified historic structures, and ongoing cultural 

landscapes inventories. 

Research and monitoring will continue to be critical for assessing the effectiveness of 

management actions at achieving goals and ongoing assessments of changing conditions 

and if changes are happening in a desired direction. 

Survey of feasible campground expansions or additions

In 2002 NPS staff surveyed existing campgrounds and possible locations for new 

campgrounds. This was based on estimates of campground expansions needed to 

accommodate peak demand for campsites. Survey guidelines included not adding sites 
CHAPTER 1: INTRODUCTION 17

that would diminish the quality of existing sites (in terms of privacy, noise and view), 

working within the physical limitations of topography and soil type, not adding sites in 

areas with sensitive and vulnerable resources, maintaining campground sizes that would 

be consistent with the park’s management zones and adding sites in areas that would best 

suit visitation needs. Options were explored for adding communal sites for overflow 

camping, as well as individual campsites. 

1.7.6 Impact Topics Included in the Environmental Impact Statement

NPS managers must always seek ways to avoid, or to minimize to the greatest degree 

practicable, adverse impacts on park resources and values. However, the laws do give 

the Service the management discretion to allow impacts to park resources and values 

when necessary and appropriate to fulfill the purposes of a park, so long as the impact 

does not constitute impairment of the affected resources and values. (NPS 2006, p.12)

The assessment of impacts from a proposed action must consider three types of impacts: 1) direct 

effects, or impacts caused at the same time and at the same place as the implemented action; 2) 

indirect effects, or impacts caused by the alternative but at a later time, or in a different location 

than the actions; and 3) cumulative effects, or additive impacts to a particular resource from a 

past, present, or foreseeable future action. Additionally, there must be an assessment of findings 

on impairment. Impairment is defined by NPS policies as “an impact that, in the professional 

judgment of the responsible NPS manager, would harm the integrity of park resources or values, 

including the opportunities that otherwise would be present for the enjoyment of those resources 

or values”. Impairment considers the severity, duration, and timing of the impact as well as the 

cumulative effects of the impact of concern and others. (NPS 2006, p.12). 

The analysis of impacts evaluates the degree to which the human and natural environment will 

be affected by a proposed action. Impact topics are derived from specific issues of concern 

directly related to the proposed actions. Not every conceivable impact of a proposed action is 

substantive enough to warrant analysis. The list of impact topics considered in the EIS were 

derived from public and agency concerns raised during scoping, federal laws, regulations and 

orders, and National Park Service policies. 

Visitor use and experience 

The 1916 NPS Organic Act directs the Service to provide for public enjoyment of the scenery, 

wildlife and natural and historic resources of national parks “in such a manner and by such 

means as will leave them unimpaired for the enjoyment of future generations.” Public 

enjoyment, education and recreation are emphasized in Isle Royale’s purpose statements. All of 

the alternatives proposed in the WBMP have the potential to affect visitor use and enjoyment of 

Isle Royale’s wilderness and backcountry, and will be assessed in the EIS. 

Wilderness Character

Approximately 99% of Isle Royale National Park is designated by Congress as Wilderness. 

Moreover, the park’s wilderness character is highlighted in both its purpose and significance 

statements. NPS Management Policies (NPS 2006) clarified that:
18 CHAPTER 1: INTRODUCTION

In evaluating environmental impacts, the National Park Service will take into account 

wilderness characteristics and values, including primeval character and influence of the 

wilderness; the preservation of natural conditions (including the lack of man-made 

noise); and assurances that there will be outstanding opportunities for solitude, that the 

public will be provided with a primitive and unconfined type of recreational experience, 

and that wilderness will be preserved and used in an unimpaired condition.

Human activities, including management actions and recreation, and some of the actions 

proposed in the WBMP’s alternatives could impact these aspects of wilderness character and 

values-- naturalness and wilderness experiences. These impacts will be assessed in the EIS.

Natural Resources

Geology and Soils 

Soils and their microhabitats are known to be affected by recreation use and construction and 

maintenance of trails and campgrounds. Potential adverse impacts include general disturbance, 

loss of ground cover, compaction of soil, and erosion. Since some of the proposed actions could 

alter the use and maintenance of trails and campgrounds, impacts to geology and soils are 

included in the EIS. 

Aquatic Resources 

NPS policies require protection of water resources consistent with the federal Clean Water Act. 

Over 75% of Isle Royale’s acreage is water that includes Lake Superior and many lakes, bogs, 

ponds, marshes, and streams. Human activities in campgrounds and along trails adjacent to lakes 

and streams on Isle Royale could impact aquatic resources through soil erosion or introduction of 

contaminants or invasive exotic aquatic species. Some of the proposed actions in the WBMP 

could alter human impacts in these areas. Therefore impacts to aquatic resources adjacent to 

trails and campgrounds are included in the EIS. 

Wetlands and Floodplains 

Presidential Executive Orders mandate floodplain management and protection of wetlands. The 

park has numerous wetlands, including marshes, bogs, and vegetated lake and pond shores, 

which support considerable biodiversity. Some of the WBMP’s proposed actions could impact 

wetlands adjacent to trails and campgrounds through direct human effects of trampling, or 

indirect effects of erosion or introduction of contaminants. 

Vegetation

Isle Royale is located at the ecotone or transition zone between the boreal and northern 

hardwood forest ecosystems. Its vegetative communities and rare plant species are among its 

most important assets. Some of the WBMP’s proposed actions, including changes in campfire 

policies and management of backcountry facilities, could have adverse effects on the park’s 

vegetation. 

Terrestrial Wildlife

The isolation of Isle Royale’s relatively simple ecosystem limits the potency of human 

influences. However, human activities are known to impact wildlife species. Possible impacts 

from recreation and other human activities in the park’s wilderness and backcountry include 
CHAPTER 1: INTRODUCTION 19

habitat fragmentation, displacement of wildlife, and habituation to humans. Because some of the 

proposed actions in the WBMP may alter the patterns of human activities and their resultant 

effects on wildlife, these impacts are included in the EIS.

Threatened and Endangered Species 

The federal Endangered Species Act prohibits harm to any species of fauna or flora listed by the 

U. S. Fish and Wildlife Service (USFWS) as being either threatened or endangered. Such harm 

includes not only direct injury or mortality, but also disturbing or destroying the habitat on which 

these species depend. Two federally Threatened species – the bald eagle and the grey wolf –

inhabit Isle Royale. The Michigan Department of Natural Resources also publishes a list of 

species threatened and endangered within the state. NPS policies require that parks manage state 

and locally listed species “in a manner similar to its treatment of federally listed species, to the 

greatest extent possible” (NPS 2006 p. 45). Among state-listed animal species occurring on Isle 

Royale are the moose, common loon, and osprey. Over 75 state-listed plant species are also 

documented in the park. Changes in human activities proposed in some of the WBMP’s 

alternatives have the potential to affect these species or their habitats, thus this topic is included 

in the EIS. 

Natural Sights and Sounds 

NPS management policies call for the preservation of, “to the greatest extent possible, the natural 

soundscapes of parks” (NPS 2006, p.56). Additionally, the preservation of wilderness character 

and values includes the preservation of natural sights and sounds, minimizing the visual and 

noise intrusions of modern human activities. Development, facilities, and tools for park 

maintenance and administration can impact the sights and sounds of the park, and some of the 

proposed alternatives could alter the current state of natural sights and sounds in Isle Royale’s 

wilderness and backcountry. This will be assessed in the EIS.

Cultural Resources 

Section 106 of the National Historic Preservation Act of 1966 provides the framework for 

Federal review and protection of cultural resources, and ensures that they are considered during 

Federal project planning and execution. One of the purposes in Isle Royale’s enabling 

legislation is for it to “preserve and protect the park’s cultural...resources....” Isle Royale 

contains considerable evidence of both pre-historic and historic human occupation and use dating 

back more than 4,500 years. These cultural resources can be affected by recreation and 

management actions in the park. Thus, potential impacts to cultural resources will be addressed 

in the EIS, specifically impacts to archeological sites, historic structures, cultural objects, cultural 

landscapes, and ethnographic resources.

Socioeconomics 

Although the alternatives proposed in the WBMP are not expected to have any significant 

economic effect on local communities, some of the actions proposed could have economic 

implications for private businesses and organizations operating within the park. For example, 

changes in day use group sizes and campground access could affect tour organizations and 

changes in visitation could affect ferry services or ticket prices. Possible socioeconomic impacts 

of proposed alternatives, including the economic effects of possible changes in visitation will be 

assessed in the EIS. 
20 CHAPTER 1: INTRODUCTION

Park Operations 

Some of the potential actions proposed in the WBMP could have an effect on workloads, staffing 

requirements, budget needs, and facility requirements. These will be assessed in the EIS.

1.7.7 Impact Topics Considered but not Analyzed in Detail

NEPA and the Council on Environmental Quality (CEQ) Regulations direct agencies to “avoid 

useless bulk...and concentrate effort and attention on important issues” (40 CFR 1502.15). The 

National Park Service’s Director’s Order 12 and its accompanying Handbook give additional 

guidance for determining appropriate impact topics (NPS 2001a). Analysts must use their 

professional judgment in deciding which issues warrant consideration and to what extent. 

Certain impact topics that are sometimes addressed in NEPA documents on other kinds of 

proposed actions or projects have been judged to not be substantively affected by any of the 

WBMP alternatives considered in this EIS. These topics are listed and briefly described below, 

and the rationale provided for not considering them in any more detail. 

Air Quality 

In all of the alternatives presented the NPS would continue to protect and conserve the air quality 

of the park as a Class I air shed, which are afforded the highest degree of protection under the 

Clean Air Act. None of the alternatives being considered would substantially alter the park’s air 

quality, nor would they alter the management of the park’s air shed. 

Water Quality

In all of the alternatives presented the NPS would continue to protect and conserve the water 

quality in the park. Monitoring of water quality would continue to identify associated issues of 

concern. None of the alternatives being considered would substantially alter the park’s water 

quality, nor would they propose any changes in the park’s management of water resources. 

Waste Management 

None of the WBMP alternatives will generate noteworthy quantities of either hazardous or solid 

wastes that need to be disposed of in hazardous waste or general sanitary landfills. Therefore 

this impact topic is dropped from additional consideration. 

Transportation 

Due to Isle Royale’s isolated location in Lake Superior, with the nearest roads, railroads, and 

airports more than 20 miles away in Ontario, there will be virtually no adverse impacts from the 

various WBMP alternatives on ground or aerial transportation. The park contains no roads open 

to motorists. Isle Royale’s harbors and marinas would not be affected by proposals in the 

WBMP. While a major shipping lane does pass through park waters (between Blake’s Point and 

Passage Island), none of this plan’s proposals would have any effect on these ships. Therefore, 

this topic is dismissed from any further analysis.

Public Utilities 

Generally speaking, some kinds of projects, especially those involving construction, may 

temporarily impact above and below-ground telephone, electrical, natural gas, water, and sewer 

lines and cables, potentially disrupting service to customers. Other proposed actions may exert a 
CHAPTER 1: INTRODUCTION 21

substantial, long-term demand on telephone, electrical, natural gas, water, and sewage 

infrastructure, sources, and service, thereby compromising existing service levels or causing a 

need for new facilities to be constructed. Due to Isle Royale’s isolation and the complete 

absence of any such public utilities in the park (except those self-contained systems serving staff 

and visitors in the few developed areas), none of the WBMP alternatives will cause any of these 

impacts to any extent, and therefore utilities are eliminated from any additional analysis. 

Land Use 

Isle Royale National Park is completely surrounded by Lake Superior and does not border any 

public or private land. Nothing proposed in the WBMP would result in any change in land use 

patterns. Therefore, this topic is dismissed from any further analysis.

Prime Agricultural Lands 

There are no agricultural lands within or bordering Isle Royale, therefore this topic will not be 

addressed in the analysis of environmental impacts. 

Public Services 

In general, some kinds of projects or programs subject to NEPA analysis can interfere with the 

operation of or add to the burden on public services like police, municipal fire-fighting, 

emergency medical, and search & rescue. Since municipal, county or state-run public services 

like these are all but absent at Isle Royale, this topic is not considered any further in this EIS. 

Human Health and Safety 

Providing for human health and safety remains a priority for the NPS, and would not be altered 

by any of the proposed actions in this WBMP.

Fisheries 

The WBMP does not address regulations or management of fisheries in park waters, and none of 

the proposed actions would have foreseeable significant impacts on the park’s fisheries. This 

issue will be addressed and thoroughly analyzed in Isle Royale’s forthcoming Fisheries 

Management Plan; therefore this impact topic was not included in analysis of impacts for the 

WBMP.

Treaties, Tribal Rights, and Sacred Sites 

Treaty rights are beyond the scope of this plan. However, any actions taken to implement this 

plan will conform to laws regarding treaty rights. The NPS will routinely consult with tribes 

having treaty rights and their representatives on a government-to-government basis. None of the 

actions proposed in the WBMP would in any way alter the government-to-government relations 

between the region’s tribal nations and the NPS. Likewise, none of the proposed actions would 

alter existing treaty rights or agreements between the NPS and tribes. 

Environmental Justice/ Protection of Children 

Presidential Executive Order 12898 requires Federal agencies to identify and address 

disproportionate impacts of their programs, policies and activities on minority and low-income 

populations. Executive Order 13045 requires Federal actions and policies to identify and address 

disproportionately adverse risks to the health and safety of children. No actions proposed in this 
22 CHAPTER 1: INTRODUCTION

WBMP would be expected to have a disproportionate effect on minorities, children, or those 

living at or below poverty level.

1.7.8 Criteria Used to Evaluate Alternatives

Certain criteria were used in evaluating each of the alternatives proposed in this WBMP. This 

process will be central in identifying the preferred alternatives and a final action for the park. 

Each alternative was evaluated for projected impacts and implications of implementation as well 

as its ability to achieve the specific objectives of the WBMP. The evaluation criteria are based 

on laws and policies and legislative guidance for Isle Royale. The evaluation criteria judge an 

alternative’s ability to provide the following:

1. Protection of quality visitor experiences, including opportunities for solitude or a 

primitive and unconfined type of recreation, and a minimal chance of having to share 

campsites in overfull campgrounds.

2. Access and freedom of travel for visitors, including flexible travel within the park, 

freedom to visit the park on a date of choice, and maintaining appropriate access to 

the park for people wishing to visit.

3. Minimum impact to natural and cultural resources.

4. Public acceptability, including consideration of costs to visitors, transportation 

companies, and concessionaires.

5. Administrative and implementation feasibility, including the ability to monitor 

conditions effectively.

6. Adherence to policy, legal guidelines, and the goals of Isle Royale’s GMP.

7. Preservation of the park's wilderness character. 

8. Basing management decisions on sound scientific research and public input, 

incorporating new data and information, as necessary, into a dynamic management 

program. 

Isle Royale National Park is located in the northwestern section of Lake Superior, within 14 

miles of the Ontario (Canada) shoreline, 20 miles of Minnesota, and approximately 45 miles 

from Michigan’s Upper Peninsula. The island itself is located 620 miles from Detroit, 570 from 

Lansing, 400 from Milwaukee, 320 from Minneapolis and St. Paul, and 25 from Thunder Bay, 

Ontario. There are no roads on or leading to the island. 

The park may be accessed by ferry, seaplane, or private boat. Concessions operations run the 

seaplane service and 3 of the 4 ferries. The fourth ferry is operated by the NPS out of Houghton, 

MI for transport of personnel, cargo, and park visitors. Houghton, MI, Copper Harbor, MI, and 

Grand Portage, MN serve as the ferry landings on the mainland, with service primarily to 

Windigo and Rock Harbor on Isle Royale (Appendix D, Map 1). One of the ferries, operating 

out of Grand Portage, MN, circumnavigates the island, with up to 8 stops along the way to pick 

up or drop off passengers at docks and trailheads. The closest airports to the park’s ferry 

services are in Houghton-Hancock, MI, and Grand Marais, MN. No private, state, or other 

1.8 Regional Context
CHAPTER 1: INTRODUCTION 23

federal lands adjoin Isle Royale, though the park’s northern boundary in Lake Superior abuts the 

international US-Canadian border. 

Isle Royale is one of 13 National Park Units and 23 federal Wilderness areas within the three 

states of the Lake Superior Region: MI, WI and MN. The US Forest Service’s Boundary Waters 

Canoe Area Wilderness in northern MN is the largest Wilderness area with 809,772 acres; Isle 

Royale is the second largest (132,018 acres), and the only National Park in the area with 

designated Wilderness. There are also many State Parks, recreational waterways, and Canadian 

National and Provincial Parks within the vicinity of Isle Royale. All of these offer a wide range 

of recreational opportunities, including highly developed and primitive camping, scenic roads, 

fishing and hunting, motorized or non-motorized boating, hiking, biking, and off-highwayvehicle use. They also offer a wide range of opportunities for groups of unlimited sizes. 

Statements of purpose, significance, and emphasis outlined in Isle Royale’s 1998 GMP were 

developed based on the park’s legislation, special designations, and NPS policies, and 

incorporated public and staff input.

Park purpose statements are based on Isle Royale’s legislation, legislative history, special 

designations, and NPS policies:

• Preserve and protect the park’s wilderness character for use and enjoyment by present 

and future generations,

• Preserve and protect the park’s cultural and natural resources and ecological processes,

• Provide opportunities for recreational uses and experiences that are compatible with the 

preservation of the park’s wilderness character and park resources,

• Provide park-related educational and interpretive opportunities for the public,

• Provide opportunities for scientific study of ecosystem components and processes, 

including human influences and use, and share the findings with the public.

Park significance statements capture the essence of the park’s importance to the nation’s natural 

and cultural heritage:

• This maritime park, a U.S. Biosphere Reserve, encompasses a remote and primitive 

wilderness archipelago isolated by the size and power of Lake Superior,

• Isle Royale is world renowned for its long-term predator/prey study of wolves and 

moose. The park offers outstanding possibilities for research in a remote, relatively

simple ecosystem where overt human influences are limited,

• Park waters contain the most productive native fishery and genetically diverse lake trout 

populations in Lake Superior.

Park emphasis statements flow from the park’s purpose and significance and are used as broad 

guiding principles for park programs and priority setting:

• Self-sufficiency is a way of life on Isle Royale. Self-sufficiency is as important today for 

park backpackers, canoeists, and boaters as it was for those who first used and settled the 

1.9 Park Purpose, Significance, and Emphasis
24 CHAPTER 1: INTRODUCTION

island—Native Americans, European miners, lighthouse keepers, commercial fishermen, 

and island summer residents,

• Wilderness has many meanings to many people. For Isle Royale National Park the 

meaning is defined by the Wilderness Act of 1964, which states a wilderness is an area 

“...affected primarily by the forces of nature, with the imprint of man’s work 

substantially unnoticeable, [and] has outstanding opportunities for solitude or a primitive, 

unconfined type of recreation...”

• Isle Royale rose from the depth of Lake Superior some 11,000 years ago and remains 

ecologically connected to the lake; the forces of the lake still shape and nurture the 

landscape. The park offers visitors a chance to experience wildness, seclusion, solitude, 

and recreation. It restores the human spirit. It is a wilderness to be entered on its own 

terms. It is an adventure,

• Adventure, simple living, and solitude are important parts of an Isle Royale visit. In 

order to ensure these kinds of experiences, park users must have the skills and habits that 

foster an ethic of “Leave No Trace” on the island.

• Isle Royale is a living laboratory where plant and animal life can be studied in a relatively 

simple ecosystem. The theory of island biogeography is illustrated by both the limited 

number and variety of species to be found in the park.

• Because of Isle Royale’s generally undisturbed setting, it is an important source of 

information about the world around us—how the world evolved, how the impacts of 

civilization have altered natural systems, and what the unmodified environment holds.

• Isle Royale, as a U.S. Biosphere Reserve, is a valuable asset as a natural baseline that 

reveals the extent of impacts elsewhere, as a site where scientists and students can study 

natural processes, as a gene pool helping to maintain the diversity of a northern boreal 

forest and Lake Superior, and as a sanctuary for certain plants and animals that cannot 

survive outside of isolated wilderness.

• For thousands of years people have lived an episodic existence on Isle Royale. For 

centuries the presence of pure copper has drawn people to the island. Similarly, people 

have been drawn by the island’s spectacular scenery and wilderness opportunities to 

establish resorts and summer housing on the island. An abundant fishery attracted many. 

Although the remnants of mining activity, commercial fishing, and the resort era are 

melding into the landscape, wilderness visitors may still find traces of the park’s rich 

history.

• Isle Royale has a rich maritime heritage. The island serves as a significant navigational 

reference point, a refuge from storms, and a treacherous obstacle to mariners. For well 

over a century its lighthouses have guided ships safely through passages. The park’s 

waters are the final resting place for an array of shipwrecks that provide an underwater 

museum that includes many types and stages of maritime technology.

• The National Park Service is striving to sustain the native fishery of Isle Royale National 

Park—perhaps the most exceptional fishery in the Great Lakes region. For centuries Isle 

Royale’s waters have drawn fishermen—prehistoric people, immigrant commercial 

fishermen, and today’s sport fishermen. A relic of the past adaptive fishing lifestyle and 

technology still remains as a reminder of this significant island culture.
CHAPTER 1: INTRODUCTION 25

Since its establishment in 1931, Isle Royale National Park has been managed with a focus on 

backcountry-based recreation in concert with protection of natural and cultural resources. The 

wilderness study and recommendation process for Isle Royale began in the mid to late 1960s, 

including public hearings in 1967. The NPS worked with the public and local and state 

governments to develop a plan for wilderness designation, and then submitted the plan for 

Presidential and Congressional approval. President Nixon recommended a large portion of Isle 

Royale for wilderness designation in 1971. Following Congressional hearings, this 

recommendation was modified slightly and signed as legislation by Congress in October of 1976. 

The original designation included 131,880 acres of designated wilderness and an additional 231 

acres as potential wilderness. “All lands which represent potential wilderness additions, upon 

publication in the Federal Register of a notice by the Secretary of the Interior that all uses 

thereon prohibited by the Wilderness Act have ceased, shall thereby be designated wilderness” 

(90 Stat. 2692 P.L. 94-567 §3). In 1983, 138 acres of potential wilderness were converted to 

designated wilderness. Table 1 outlines the remaining areas of potential wilderness and 

associated non-conforming uses that temporarily prevent conversion to wilderness. Upon 

completion of a Cultural Resources Management Plan , these areas will be evaluated. Currently 

132,018 acres of the park’s lands, or 99% of its total 133,788 island acres, are designated as 

wilderness or potential wilderness. None of the park’s 438,008 acres of Lake Superior and 

submerged lands are designated or managed as wilderness (Appendix D, Maps 2a & 2b).

Table 1: Potential Wilderness Areas on Isle Royale, their Acreage, and Non-Conforming Uses

Location Acres Non-conforming use

Fisherman’s Home 5 Volunteer in Park agreement allowing residence

John’s Island 0.8 Special Use Permit 

Wright Island 1 Volunteer in Park agreement allowing residence

Davidson Island 1 NPS and researcher housing

Johnson Island 5 Special Use Permit extending life lease use rights

Amygdaloid Island 11 Ranger station with fuel storage and NPS residence

West Caribou Island 5.6 Life lease

Passage Island 3 Boat house and trail to light house for past Coast 

Guard use 

Edwards Island and 

neighboring islands 24.8 Life lease

Newman Island 0.2 Life lease (How Family)

Tobin Harbor Islands 

and portions of main 

island in vicinity

10

Life leases, Special Use Permit, Artist in Residence 

Program cabin, and NPS residence

Captain Kidd Island 20.6 Special Use Permit extending life lease use rights

Amygdaloid Island, 

Crystal Cove 5 Volunteer in Park agreement allowing residence

Total PWA 93

1.10 History of Wilderness and Backcountry at Isle Royale
26 CHAPTER 1: INTRODUCTION

Isle Royale’s wilderness legislation allowed for the continued maintenance of docks and shelters 

within the park’s designated wilderness, and further allowed for the addition of new docks where 

determined necessary for visitor safety or administration of the wilderness. 

Several small land areas were excluded from wilderness designation because of existing or 

potential future high human use with associated development that would be inappropriate for 

wilderness (Table 2). Some of these areas, such as Siskiwit Bay, have not seen the anticipated 

development and would appear to most people to be indistinguishable from wilderness. All of 

the campgrounds and docks within these non-wilderness areas fall under the scope of the park’s 

backcountry management, and with close proximity to designated wilderness are managed with 

consideration for impacts to wilderness.

Table 2: Acreage of Non-Wilderness Lands in Isle Royale National Park

Location Acres

Siskiwit Bay—area including and surrounding the existing campground 100

Barnum Island 6

Washington Island- the northeastern tip including historic buildings 31

Rock of Ages Island 1

Windigo- including and surrounding the developed area and 

campground

400

Menagerie Island 5

Malone Bay- area including the ranger station and campground facilities 100

Moskey Basin—area including and surrounding the existing 

campground

100

Rock Harbor—area from Suzy’s cave northeast to within about a mile 

of Scoville Point 322

Three Mile—area including and surrounding the existing campground 80

Mott Island 181

Daisy Farm—area including and surrounding the existing campground 160

Area including the Rock Harbor Lighthouse and Edisen Fishery 19

McCargoe Cove—area including and surrounding the existing 

campground

120

Passage Island- the southwestern tip, including the lighthouse 7

Blake Point- area including navigational aids 5

Belle Isle—area including and surrounding the campground 40

Total acreage of non wilderness lands on Isle Royale 1,677
CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 27

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION, AND THE PREFERRED 

ALTERNATIVES

This chapter presents the details of how the NPS proposes to manage the wilderness and 

backcountry of Isle Royale. The chapter begins with the philosophical and policy framework for 

managing the wilderness and backcountry, followed by a description of current conditions and 

the no action alternative, then actions common to all action alternatives, then a presentation of 

the range of action alternatives presented. The chapter concludes with a summary of all the 

preferred alternatives and what they would look like in combination. 

In many cases the decisions on how to manage the wilderness and backcountry of Isle Royale 

have already been decided by federal laws. Other decisions are dictated by NPS policy, and other 

Isle Royale-specific issues were decided in the park’s GMP. However, there are several 

important issues requiring further decision. Most of these issues were determined to have only 

one reasonable solution, which are listed in the “actions common to all action alternatives” 

section. A few issues have several feasible solutions, and in these cases multiple alternatives 

were developed to explore options in detail. These are the “action alternatives.” The action 

alternatives were developed in response to public input and research on several specific issues. 

Because each of these issues is independent of the others they are presented individually, rather 

than being combined into fewer more comprehensive alternatives. 

When the WBMP is finalized, we propose that the final preferred alternatives, along with the 

“actions common to all” would become the core of the Isle Royale’s plan for managing the 

wilderness and backcountry of the park. 

The outline below will help guide you to the issues you may be most interested in. 

2.1. The framework for Managing Wilderness and Backcountry at 

Isle Royale National Park......................................................................................................28

2.1.1. Wilderness Management Philosophy..........................................................................28

2.1.2. Guidelines from Laws and Policy...............................................................................28

2.2. The No Action Alternative ....................................................................................................34

2.2.1 Wilderness Boundaries and Management...................................................................34

2.2.2 Visitor Use and Experiences, Including Facilities and Services.................................35

2.2.3 NPS Administration and Operations, Including Resource Protection ........................38

2.3. Actions, or changes, that would be common to all action alternatives..............................42

2.3.1 Wilderness Boundaries and Management...................................................................42

2.3.2 Visitor Use and Experiences, Including Facilities and Services.................................42

2.3.3 NPS Administration and Operations, Including Resource Protection and 

Implementation of the WBMP....................................................................................45

2.4. The Action Alternatives, including Preferred Alternatives ...............................................55

2.4.1. Alternatives for Managing Overnight Use in the Wilderness and Backcountry.........55

2.4.2. Alternatives for Managing Day Use in the Wilderness and Backcountry ..................79

2.4.3. Alternatives for Campfires in the Wilderness and Backcountry.................................83

2.4.4. Alternatives for Fire Towers in Wilderness................................................................86

2.4.5. Alternatives for Picnic Tables in Wilderness Campgrounds......................................88

2.4.6. Summary of the preferred alternatives in combination...............................................92
Framework for Managing Wilderness and Backcountry

 28 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

2.1.1 Wilderness Management Philosophy

Isle Royale’s Wilderness and backcountry will be managed in a means that is consistent with 

national wilderness policies. The National Park Service would manage all designated and 

potential wilderness areas of Isle Royale National Park to protect physical wilderness resources 

as well as wilderness character, consistent with the direction of NPS Management Policies and 

The Wilderness Act. In order to protect and promote wilderness character, wilderness 

management must consider the purpose of an action and the spirit in which it was carried out. 

The Wilderness Act identifies two key components of wilderness character as 

• Generally appearing to have been affected primarily by the forces of nature, with the 

imprint of man’s work substantially unnoticeable; and 

• Having outstanding opportunities for solitude or a primitive and unconfined type of 

recreation.

Providing opportunities for solitude would include managing for visitor experiences with the 

following characteristics:

• Freedom from the reminders of society

• Privacy and isolation in natural surroundings

• Absence of distractions such as large groups, mechanization, unnatural noise, signs, and 

other modern artifacts (Federal Register, Vol. 66, No. 10, p. 3713).

However, at its essence wilderness character is unseen and immeasurable; a unique challenge of 

wilderness management. Wilderness character includes the natural and scenic condition of the 

land, natural numbers, cycles, and interactions of wildlife, and the integrity of ecological 

processes. At its core though, wilderness character, like personal character, is much more than a 

physical condition. The character of wilderness is an unseen presence capable of refocusing our 

perception of nature and our relationship to it. It is that quality that lifts our connection to a 

landscape from the utilitarian, commodity orientation that dominates the major part of our 

relationship with nature to the symbolic realm serving other human needs (Federal Register, 

Vol. 66, No. 10, p. 3729-3730).

The NPS recognizes the intangible values of wilderness, and in implementing this plan and with 

future management actions, would with every decision forego actions that might have no 

seeming physical impact but which would detract from the idea of wilderness as a place set 

apart, a place where human uses, convenience, and expediency do not dominate; a place where 

we can know ourselves as part of something beyond our modern society and its creations.

2.1.2 Guidelines from Existing Laws and Policy

Existing laws that direct the management of wilderness and backcountry in the National Park 

system are the NPS Organic Act, the Wilderness Act, and the National Historic Preservation Act. 

They provide a framework for policy and directives such as NPS Management Policies, NPS 

Director’s Orders, and Isle Royale National Park’s General Management Plan. These documents 

clearly direct certain management actions at Isle Royale. This WBMP will not propose changes 

to these directions, and they are not included in the action alternatives. 

2.1 Framework for Managing Wilderness and Backcountry at Isle Royale National Park
Framework for Managing Wilderness and Backcountry

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 29

Public use of Motorized and Mechanical Transport. 

Consistent with the Wilderness Act and NPS Management Policies for wilderness management 

(NPS 2006), public use of motorized and mechanical transport, including bicycles and portage 

wheels, would not be permitted within Isle Royale’s wilderness. This includes all of the park’s 

inland lakes and hiking trails. 

Public use of motorized equipment or any form of mechanical transport will be 

prohibited in wilderness except as provided for in specific legislation. Operating 

a motor vehicle or possessing a bicycle in designated wilderness outside Alaska is 

prohibited [36 CFR 4.30(d)(I)].

Motorboats would continue to be permitted and appropriate in the park’s Lake Superior

waters, which is not designated wilderness. 

Accessibility

According to the Americans with Disabilities Act, the Wilderness Act, and NPS Management 

Policies 2006, wheelchairs are appropriate in wilderness only if a wheelchair is a person’s 

primary mode of locomotion, manual or electric, and is suitable for use in indoor pedestrian 

areas. This does not include wheelchairs that function like an all terrain vehicle. Persons using 

wheelchairs would be reasonably accommodated in wilderness without the need to compromise 

wilderness resources or character 

Emergency Services/Human Health and Safety

Protecting human health and safety remains a priority for Isle Royale managers. Although 

wilderness is to be experienced on its own terms with inherent risks and challenges, the NPS 

would continue to provide emergency services for all Isle Royale visitors.

Implementation of the 1998 General Management Plan. 

Full implementation of Isle Royale’s GMP (1998) would continue, including the planned 

removal of the dock and break wall at Siskiwit Bay, removal of the docks at Three Mile and 

Duncan Bay, relocation of the dock at McCargoe Cove closer to the cove’s entrance, and 

addition of new overnight docking and campgrounds at John’s Island, Washington Island, 

Fisherman’s Home, Wright Island, Crystal Cove and McCargoe Cove. Additional assessment of 

environmental impacts and compliance documentation would be completed before implementing 

these changes. 

Management Zones established in the GMP would be maintained unchanged (Appendix D, Map

6). Table 3 defines these management zones. Regulations for generator use by boating parties, 

including designated areas closed to on-board generator and air compressor use, would not be 

changed.

Transportation Services

The objective of Isle Royale’s transportation services is to provide public access for appropriate 

recreation in the park and transport personnel and cargo necessary for park operations. The GMP 

established that Isle Royale’s transportation services would not be expanded. No new ferry entry 

points would be established. Rock Harbor and Windigo would remain the primary entry points, 
Framework for Managing Wilderness and Backcountry

30 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

Table 3: Park Management Zones and Goals for Resource and Social Conditions (From the 1998 Final General Management Plan for Isle Royale National Park)

Zone Visitor Experiences Resource Conditions or Character Appropriate Activities and Facilities

Land and Inland Lake Zones

Developed

Developed zones are highly developed areas 

with convenient and accessible facilities. 

Opportunities for adventure and solitude 

would be relatively unimportant, while 

encounters with other visitors and NPS staff 

would be high.

NPS toleration for resource degradation 

would be moderate. Buildings and other

structures would be obvious. This zone is 

confined to small areas without 

unprotected sensitive natural and cultural 

resources, and is in non-wilderness

Visitor and administrative facilities are provided, 

including visitor centers, educational program 

areas, residences, and maintenance areas. Primary 

ferry landings, large docks, marinas, and paved 

paths are found here.

Frontcountry

The frontcountry zone offers structured 

interpretation and education activities. These 

areas are in a fairly natural setting within a 

day’s hike or short boat ride from developed 

facilities. Opportunities offer limited 

challenge or adventure with little need for 

outdoor skills. The probability of encountering 

other visitors is high and encountering NPS 

staff is moderate.

Sights and sounds of people are evident 

with intensively managed sites and trails. 

Facilities generally harmonize with the 

natural environment. NPS tolerance for 

resource degradation would be low but 

this zone generally does not include 

sensitive natural or cultural resources. 

This zone includes both non-wilderness 

and designated wilderness.

This zone is comprised of heavily used areas 

adjacent to developed zones and surrounding prime 

park features such as high use cultural and scenic 

areas. Relatively large campgrounds with shelters 

and large group sites, hardened trails, and 

interpretive facilities and signs may be found in 

this zone. Some trails are designed for 

accessibility.

Wilderness 

Portal

These portal areas provide access and 

facilities needed to access or manage other 

zones. Larger docks, ferry landings, and large 

campgrounds mixing different types of 

visitors are found here. There are pulses of 

activity at different times, but solitude and 

quiet would be available some of the time. 

Adventure and challenge may be low, but 

there is some need for self-sufficiency.

NPS tolerance for resource degradation is 

low, with these areas appearing mostly 

natural. Included are sensitive natural and 

cultural resources only if they are well 

protected. This zone includes both nonwilderness and designated wilderness.

Only non-motorized or non-mechanized activities 

would be appropriate. Facilities in this zone could 

include moderate-sized (or the largest, in the case 

of Daisy Farm) campgrounds with shelters, large 

group sites, outhouses, trailheads, trails, and 

moderate-sized docks. Secondary ferry landings 

and some interpretive activities may be offered. 

Small signs marking trail directions, campsites, and 

resource protection needs are appropriate.

Backcountry

This zone provides a sense of being immersed 

in a natural landscape, removed from most 

modern comforts and conveniences. There are 

possibilities for risk, challenge and adventure, 

with visitors needing to have outdoor skills 

and exert themselves. Encounters with others 

are moderate, with good opportunities for 

solitude. Some noise is expected.

NPS tolerance for resource degradation is 

low. This zone includes somewhat 

primitive trails and campgrounds that are 

maintained for resource protection, visitor 

safety and harmony with the natural 

environment. This zone includes both 

non-wilderness and designated 

wilderness.

Only non-motorized or non-mechanized activities 

are appropriate. This zone includes moderate to 

high-use trail corridors. Small campgrounds with 

outhouses and possibly a few shelters and large 

group sites, small docks, and unpaved trails would 

be the only facilities. Small signs marking trail 

directions, campsites, and resource protection 

needs are appropriate.
Framework for Managing Wilderness and Backcountry

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 31

Zone Visitor Experiences Resource Conditions or Character Appropriate Activities and Facilities

Land and Inland Lake Zones continued

Primitive

This zone provides a sense of being immersed 

fully in nature and feels farther away from 

modern comforts and conveniences. 

Opportunities for independence, closeness to 

nature, tranquility, solitude and the application of 

outdoor skills are common. Possibilities for risk, 

challenge and adventure are high, requiring a 

longer time commitment, greater outdoor skills, 

and a high level of physical exertion. Encounter 

rates with others is low, with low tolerance for 

noise, visual intrusions, and social interactions.

NPS tolerance for resource degradation due to 

human activities is low. Trails and 

campgrounds are lightly used and maintained 

in a primitive condition for visitor safety and 

resource protection in a manner that conforms 

to natural surroundings. This zone is located 

entirely within designated wilderness.

Only non-motorized or non-mechanized 

activities would be appropriate. 

Facilities are limited to primitive trails 

and small campgrounds with outhouses 

and individual tent sites only. Docks are 

not located in this zone. Creek and 

wetland crossings may not always have 

maintained bridges. Small signs 

marking trail directions, campsites, and 

resource protection needs are 

appropriate.

Pristine

Visitors to the Pristine zone should expect to find 

a pure wilderness setting free of development. 

Little or no signs of modern human presence are 

obvious. A high degree of physical exertion, time 

commitment, self-sufficiency, and outdoor skill 

are required. Opportunities for challenge, 

adventure, independence, solitude, closeness to 

nature, and tranquility are common. The 

probability of encountering others is very low, 

with little or no evidence of visitor impacts.

NPS tolerance for resource modifications or 

degradation would be very low. This zone 

offers the most natural conditions and includes 

areas requiring high resource protection. 

Much of this zone is difficult to access. Onsite 

management for visitor safety and resource 

protection is limited, with greater restrictions 

implemented off-site, including access and 

length of stay restrictions. This zone 

encompasses large areas and is entirely 

designated wilderness.

Only non-motorized or non-mechanized 

activities would be appropriate. No 

facilities are appropriate in this zone, 

including trails, docks, campsites and 

signs. Cross-country dispersed camping 

and hiking are permitted, with 

regulations to protect resources, 

including special permitting and area 

closures.

Lake Superior Water Zones

Open Water 

Motorized

This zone appears predominantly natural, but 

there is evidence of human use and activity. 

There are fewer restrictions on visitor activities. 

The probably of encountering other visitors and 

seeing or hearing motorized traffic could be high, 

thus solitude and tranquility are limited. Skill, 

risk and self-sufficiency are high as lake 

conditions could be dangerous and unpredictable.

The character of this zone is unpredictable, 

changing according to Lake Superior and 

weather conditions. Management actions 

would be the minimum necessary for visitor 

safety and resource protection. Most Lake 

Superior waters within the park are included 

in this zone.

Boating of all types, fishing and scuba 

diving are appropriate and could be 

common.

Quiet/No-Wake

In Quiet-no-wake zones surroundings are 

relatively tranquil and natural. Solitude is 

possible with moderate encounter rates. 

Tolerance for noise is low.

Tolerance for noise and human-caused 

resource degradation is low. Relatively 

protected, calm waters provide increased 

safety and resource protection. A moderate 

level of management would be provided for 

safety and resource protection.

Human-powered and motor-powered 

watercraft would be found in this zone. 

Boats would travel at idling speed on 

flat water and leave no wake larger than 

prevailing sea conditions.
Framework for Managing Wilderness and Backcountry

32 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

with secondary entry points at McCargoe Cove, Belle Isle, Daisy Farm, Chippewa Harbor, and 

Malone Bay (currently provided by the Voyageur II). Water taxi service would continue to be 

available through the Rock Harbor Lodge.

Fees

Fees would continue to be collected from all visitors. Fee collection would occur according to 

NPS policy for fee collection and the regulations promulgated under the Federal Lands 

Recreation Enhancement Act of 2004.

Operating Season

Isle Royale would continue to be open from April 16 through October 31, though exact opening 

and closing dates may be determined by weather and ice conditions. The island would remain 

closed to the public in the winter and no employees or other people would reside in the park 

year-round. The park’s winter closure was implemented through the park Compendium in 1978 

primarily to protect visitor and employee safety and the island’s wildlife populations. The park’s 

visitor center in Houghton would remain open to the public year-round to provide information

services.

Personal Watercraft

Per the GMP and NPS regulations, use of personal watercraft (jet skis) are not permitted in the 

park, because of inconsistency with park purpose, significance, and emphasis statements. (NPS 

1998, p.27)

Pets

Dogs, cats and other mammals may not be brought into or possessed in the park area, except for 

service dogs [36 CFR p.99 § 7.38 (c)]. Special permitting processes apply for bringing service 

animals to the island.

Aircraft Over-flights

Policies for aircraft over-flights and landings within Isle Royale are guided by the park’s 1997 

Aviation Management Plan (NPS 2008). This document clarifies the aviation management 

objectives for the park as; 1) aid in the safe, effective, and efficient management of the NPS, 2) 

provide emergency response capability, and 3) minimize impacts on park resources, neighbors, 

and visitors. Floatplane landings are permitted exclusively in portions of Tobin Harbor, Rock 

Harbor, and Washington Harbor (36 CFR p. 99 § 7.38 (a)), except in emergency response 

situations facilitated by the NPS. Appropriate uses of over-flights for NPS operations include 

wildfire monitoring, emergencies, and limited wildlife monitoring where such flights are 

determined to be the minimum tool. Aircraft over-flights are regulated by the FAA. However, 

the following flight restrictions apply, as outlined in the Isle Royale Aviation Management Plan:

1. The Federal Aviation Administration (FAA) has issued a 2,000 foot flight level 

advisory over the island. This should be strictly adhered to by NPS flights unless the 

mission does not allow this. (example: wildlife observations)

2. Flying directly over the main island should be avoided whenever possible to reduce 

noise and visual intrusion. An example is point-to-point flights from Mott to Windigo 

or Minnesota. These flights should fly over Lake Superior waters instead of the 

island. 
Framework for Managing Wilderness and Backcountry

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 33

3. Helicopter long line missions into the backcountry should be implemented during 

periods of low visitor use primarily in early spring or late fall.

4. Backcountry landings by rotor or fixed wing aircraft will be limited to emergencies.

5. Each proposed aircraft mission will be reviewed to determine if using aircraft with its 

related intrusions is the best choice. 

6. Aircraft may only land in designated landing areas except in emergency cases.

Native American Treaty Rights

Several bands of Lake Superior Chippewa have rights guaranteed by various treaties in the 

geographic area in which Isle Royale National Park is located. The National Park Service would 

honor those legally established rights and cooperate with tribes holding those rights. The NPS 

would routinely consult with tribes and their representatives on a government-to-government 

basis in managing our wilderness resources. 

Residential Uses

Seventeen families retain life leases, special use permits, and volunteer agreements for 

residential use within the park boundaries, and in several cases within potential wilderness areas. 

The WBMP would in no way alter the agreement of these leases and permits. However, upon the 

expiration of the leases the proper steps would be taken to evaluate the conversion of any 

associated potential wilderness to designated wilderness in compliance with Isle Royale’s 

Wilderness Legislation. The potential continuation of non-conforming uses of these areas would 

be a consideration in a decision for conversion to designated wilderness.

Protection of Cultural Resources

There has been extensive prior human use in most areas now designated as wilderness, 

resulting in archeological sites, historic structures, cultural landscapes and associated 

features, objects and traditional cultural properties that are contributing elements to 

wilderness. It is important to recognize that laws, . . . intended to preserve our cultural 

heritage, are applicable in wilderness . . . actions involving all cultural resource types in 

wilderness must comply with cultural resource laws, such as compliance actions and 

inventory requirements mandated by NHPA [National Historic Preservation Act].(DO41, §C.4. p.38)

In drafting wilderness legislation Congress specifically included cultural resources as part of 

wilderness and historic values to be protected. Any impacts on cultural resources would be 

avoided if at all possible within Isle Royale’s wilderness and backcountry, as protection of these 

resources are a critical facet of wilderness management. Cultural resources include 

archeological sites, historic structures, cultural landscapes, and ethnographic resources. Any 

actions that involve ground disturbance or possible disturbance of cultural structures or 

landscapes must involve mitigation measures developed by the park in consultation with the 

Michigan State Historic Preservation Office. 

Historic properties eligible for the National Register of Historic Places that have been included in 

wilderness would be protected and maintained according to the pertinent laws and policies 

governing cultural resources, using management methods that are consistent with preservation of 

wilderness character and values. (NPS 1999a § 6.3.8)
Framework for Managing Wilderness and Backcountry

34 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

Protection of Natural Resources

Isle Royale managers are required by law to protect park resources and values, and are further 

directed to always seek ways to avoid, or minimize to the greatest degree practicable, adverse 

impacts on park resources or values. The NPS is required to protect the species listed under the 

Endangered Species Act and their critical habitats. Policy also requires that NPS managers 

inventory, monitor and manage state and locally-listed Threatened and Endangered species to the 

same extent as federally listed species, whenever possible. Under the Clean Air Act, the NPS is 

required to protect Isle Royale as a Class I Airshed, with only minor degradation of air quality 

allowed. 

Natural Light and Night Skies

The NPS recognizes the importance of protecting natural light and night skies and is committed 

to protecting natural darkness and other components of natural lightscapes in parks (NPS 2006). 

Therefore, managers would prioritize preventing or minimizing light pollution originating within 

park boundaries to the greatest extent possible while also providing for human safety within the 

developed, populated areas of the park. 

Fire Management

The WBMP would remain consistent with the park’s Fire Management Plan (2004), recognizing 

that fires are a natural part of a wilderness ecosystem, and management actions are necessary to 

ensure both a healthy fire system and human health and safety.

Hunting and Trapping

Hunting and trapping are not permitted within Isle Royale National Park. 

Current and projected conditions provide a baseline for evaluating the changes and impacts of 

the other action alternatives. The National Park Service would continue the present management 

direction, guided by the GMP. Recreational use and access patterns would continue to develop, 

and the agency would respond as necessary on a case-by-case basis. No new services or facilities 

would be developed, except those described in the GMP. 

This alternative represents “no action” on this plan. It does not imply that the National Park 

Service would take no further management action concerning the park’s backcountry. It places 

the National Park Service in a reactive role, responding to resource damage and user conflicts as 

issues arise. For all activities, the National Park Service would respond to changing use patterns 

as necessary to protect park resources, visitor safety, and visitor experience.

2.2.1 Wilderness Boundaries and Management

The NPS would maintain existing wilderness boundaries in Isle Royale National Park, with 

131,925 acres of designated wilderness and 93 acres potential wilderness (Appendix D, Maps 2A 

and 2B). Designated wilderness and potential wilderness would continue to be managed as 

wilderness, consistent with NPS Management Policies (NPS 2006). Potential wilderness on Isle 

2.2 The No Action Alternative
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CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 35

Royale consists of areas identified as suitable for wilderness designation, but with temporary 

non-conforming uses such as life leases or residences. The House Report accompanying the 

Wilderness Act (HR13160) clarifies the intent of designating an area as Potential Wilderness:

National Park Service wilderness proposals have embodied the concept of “potential 

wilderness addition” as a category of lands which are essentially of wilderness 

character, but retain sufficient non-conforming structure, activities, uses, or private 

rights so as to preclude immediate wilderness classification. It is intended that such lands 

will automatically be designated as wilderness by the Secretary by publication of notice 

to that effect in the Federal Register when the non-conforming structures, activities, uses, 

or private rights are terminated.

2.2.2 Visitor Use and Experiences, Including Facilities and Services

Appropriate and Traditional Uses

National Park Service management policies direct that wilderness areas must be managed to 

preserve their wilderness character and resources while providing for “appropriate” uses. 

Appropriate uses are those that require, yet do not degrade, the wilderness character and values, 

and include activities such as recreation, scientific inquiry, education, and historical use. The 

Wilderness Act dictates appropriate activities within Isle Royale’s wilderness, but more 

flexibility is allowed within the park’s non-wilderness backcountry, such as the use of sailboats 

and motors. 

Existing types of recreational activities and visitor uses would continue, as would backcountry 

regulations (Appendix E). People visit Isle Royale for many different activities, including 

fishing, boating, backpacking, day hiking, canoeing, kayaking, sailing, scuba diving, observing 

wildlife, seeking general restorative experiences, learning about the area’s natural and cultural 

history, and photographing wildlife, flora and natural and historical scenery. All of these 

activities and more take place in and may be dependent upon the park’s wilderness and 

backcountry. Activities within the park’s wilderness would continue to be limited to nonmechanized and non-motorized activities. 

The current conditions and opportunities for day visitors, and overnight campers and boaters are 

described in greater detail in the alternatives for managing overnight use of the wilderness and 

backcountry (§ 2.4.1) and alternatives for managing day use in the wilderness and backcountry 

(§ 2.4.2). Chapter 3 (§ 3.1) describes in detail visitor use and experiences at Isle Royale visitors. 

Cross-Country Camping and Anchoring Out

Cross-country, or off-trail, camping and anchoring out would remain an option for visitors 

seeking opportunities outside of designated campgrounds and docks. These visitors would need 

to be experienced with the skills required to safely and responsibly anchor out or camp in 

pristine, off-trail areas. Because of this, the majority of Isle Royale visitors would be encouraged 

to camp in designated campgrounds. The NPS would retain the right to adjust area closures and 

limits on where cross-country camping is permitted. Special cross-country or anchoring out 

permits would continue to be required, as would regulations to minimize the adverse impacts of 

dispersed camping (Appendix E-F). 
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36 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

Fishing

Fishing would continue to be recognized as an appropriate recreational activity in the park, but 

specific fishing regulations do not fall within the scope of the WBMP. Fishing regulations within 

the park’s Lake Superior waters are established by the Michigan Department of Natural 

Resources. Fishing regulations on the park’s inland lakes and streams are set by the NPS. 

Assessment fishing is permitted on a very limited basis within Isle Royale. The upcoming 

Fisheries Management Plan (expected 2012) will address the specifics of fisheries management 

in the park. 

Concessions and Private Business Operations

Private companies would continue to provide valued services to Isle Royale visitors. Commercial 

activity, as well as requests for special events on Isle Royale would continue to be limited to 

avoid over-commercialization, excessive demand for use, and incompatibility with park goals 

and objectives. Private companies would continue to provide visitor services, including lodging 

and food through the Rock Harbor Lodge, and ferry and floatplane services. Details of these 

services would continue to be managed through concessions contracts. 

Other commercial services that would continue under Commercial Use Authorizations (CUAs)

include charter fishing, charter diving, and guided hiking and paddling. The operating 

requirements of these permits could be adjusted annually to manage the number of people that 

each permittee could bring to the island on a single visit or cumulatively during the season.

Permitting and Information Services

Backcountry Permits for Campers and Boaters

There would be no change in the permitting system at Isle Royale. This is described in detail in 

the No Action Alternative for managing overnight use, §2.4.1.

Information and Education Services

The NPS visitor center in Houghton, MI, would continue to provide visitor information and 

services year-round via phone, email, and in person. Visitor centers in Rock Harbor and Windigo 

would provide in-person visitor information and services during the island’s operating season. 

Interpretive and educational services would be available through all NPS visitor centers, with the 

specific programs varying based on staffing levels. Visitor centers would continue to issue 

permits, collect fees, aid in trip planning, and offer resources about the park’s natural and 

cultural history. 

Isle Royale’s Comprehensive Interpretive Plan (2000) would continue to guide the interpretive 

and educational programs for the park. 

Group Size Restrictions

Group size limits for overnight stays in the wilderness and backcountry would continue to be 

maintained as no more than 10 people per group and no more than 20 associated individuals in 

these areas at one time. Night-by-night campground reservations with designated large group 

sites would continue for parties of 7-10 people. The NPS would continue to maintain 43 

designated group campsites throughout the park. 
No Action Alternative

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 37

There would continue to be no limitations on group sizes for day trips, as described in the 

alternatives for managing day use in the wilderness and backcountry, § 2.4.2. 

Wilderness and Backcountry Facilities

Campgrounds

Isle Royale would continue to maintain existing campgrounds and new GMP-proposed 

campgrounds, and would continue a strategy of concentrating camping within designated 

campgrounds. Managers would maintain the current system of concentrating camping impacts 

within designated campgrounds with outhouses, water access, and campsites with clearly defined 

tent pads or shelters. This system has proven effective at “both avoiding and minimizing areal 

measures of camping-related resource impacts” (Marion and Farrell 2002). Campgrounds would 

continue to be maintained and rehabilitated with a goal of increasing privacy and natural quiet 

through the design of campsite spacing and screening with vegetation. Outhouses would 

continue to be provided at all campgrounds to best manage human waste and visitors would be 

required to pack out all of their other waste. 

Shelters would continue to be maintained, though per the GMP no additional shelters would be 

added to campgrounds within designated wilderness, and shelters will eventually be removed 

from the Duncan Bay and Siskiwit Bay campgrounds, after the docks are removed. 

Trails

Hiking and portage trails would continue to be maintained to concentrate recreation impacts, 

minimize erosion and impacts to sensitive resources, and meet standards for primitive or semiprimitive trails. Trails would continue to be rerouted as needed to protect resources such as 

nesting eagles or loons. Boardwalks would continue to be used to minimize damage to wetlands. 

However, trail reroutes and the use of stonework and other trail building techniques would 

continue where feasible to minimize reliance on lumber for trails (see treated lumber section). 

Docks

Other than docks planned for removal in the GMP, all existing docks at entry points, 

campgrounds, and points of interest would be maintained. The GMP determined that docks 

would be removed from Siskiwit Bay, Three Mile and Duncan Bay and the McCargoe Dock 

would be relocated closer to the mouth of the cove. 

Signs

Trail and campground signs would continue to be posted at junctions, with a goal to provide 

directional information on rustic signs consistent with the surroundings. Sign materials would be 

compatible with local materials, such as rough-hewn cedar posts. Signs would also be used 

minimally to post campsite locations and resource protection information (area closures, 

revegetation sites, etc.). Overlooks, side trails, and other points of interest within designated 

wilderness would not be posted with directional or educational signs. 

Ranger Stations

The NPS would continue to maintain ranger stations with residences at Amygdaloid Island, 

Malone Bay, Rock Harbor and Windigo to provide for visitor safety, resource protection, public 

service, and support of park operations.
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38 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

2.2.3 NPS Administration and Operations

Maintenance of the Wilderness and Backcountry

Administrative Use of Motorized and Mechanized Equipment

The NPS would continue to accept administrative use of motorized or mechanized equipment 

within Isle Royale’s designated wilderness where human life is at risk, or where use of a 

mechanized tool is determined to be the least intrusive method on wilderness character and 

values. Within and outside of designated wilderness park management would continue to work 

toward more sustainable operations, including purchasing water- and energy-conserving systems 

and machinery. For example, the National Park Service would take a leadership role in using less 

polluting, quieter boats as current equipment is upgraded or replaced (NPS 1998 p. 27).

The NPS would continue to use chainsaws for trail and campground maintenance within Isle 

Royale’s wilderness on a limited basis. Chainsaws are used in May and June to clear the large 

number of fallen and hazard trees following the winter windfall. Chainsaws may be used again 

for hazard tree removal in September and October. Throughout the operating season chainsaws 

may be used for bridge construction and maintenance. To date Isle Royale managers have 

accepted that this is an appropriate use of chainsaws in wilderness to protect the safety of trail 

crew staff and maintain desired trail and campground standards with concern for visitor safety. 

The NPS would continue to use other power tools for maintenance in frontcountry zones and for 

dock, shelter, and outhouse maintenance in campgrounds along the Lake Superior shoreline. 

Generators or photovoltaic cells are used for power. A work barge with crane may also be used 

in dock maintenance at these campgrounds. Campgrounds outside of the developed zone are 

either within or in close proximity to wilderness. 

Appropriate Types of Lumber for Trails, Docks, and Campgrounds

Isle Royale currently lacks a park-wide policy for the best types of lumber to use in backcountry 

and wilderness maintenance projects, including a decision on whether or not to use new 

technologies for chemical preservatives that double the lifespan of lumber. Lumber is used 

primarily for boardwalks over fragile wetlands, and for bridges and docks. In the past, the NPS 

has used arsenic-treated lumber (CCA) for trail, dock, and campground maintenance, because of 

the significantly longer lifespan than untreated lumber. However, environmental concerns 

associated with arsenic leaching into soils and water led the NPS to stop using CCA lumber in 

National Parks. Some CCA lumber remains on Isle Royale, and untreated lumber and new 

materials, such as recycled plastic “lumber”, have been used for different projects. Some trail 

structures are currently built using local materials, such as rocks for stepping stones and 

drainages, and cedar logs for boardwalk supports, minimal boardwalks and bridges, drainage 

bars and corduroy. Trails are also continually re-routed to avoid wet areas. However, the great 

abundance of wetlands and wet areas on the island makes it unfeasible to entirely avoid wet areas 

when routing trails.

Lumber would continue to be used in trail construction and maintenance on Isle Royale as a 

means of minimizing human impacts on sensitive resources, as well as in dock construction and 

maintenance to provide access for visitors and maintenance crews. However, as aging 
No Action Alternative

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 39

boardwalks, bridges and docks require replacement, decisions on appropriate trail materials 

would continue to be made on an ad-hoc, project-by-project basis, without park-wide continuity. 

Organization

All Isle Royale divisions would continue to be involved in wilderness and backcountry 

management for the park. The Maintenance Division would continue to have primary 

responsibility for the design, development, maintenance and removal of facilities, including 

docks, trails, campgrounds, ranger stations, and communications facilities. The Maintenance 

Division would also play a central role in selecting appropriate materials and equipment for park 

operations. 

The Interpretation and Cultural Resources Division would continue to have primary 

responsibility for public education, information dissemination, visitor information services, 

permitting, fee collection, and website design and maintenance. Within this division, Cultural 

Resources Management would continue to be responsible for the full cultural resources program 

in the park, including inventorying and monitoring cultural resources, disseminating information, 

overseeing cultural resources planning, cooperating with local and regional interests, and 

preserving the park’s cultural resources. 

The Protection & Emergency Services Division would continue to play a critical role in visitor 

education, regulation enforcement, and protecting park resources. 

The Natural Resource Division would continue to be primarily responsible for coordinating 

research, inventorying and monitoring natural resources, assessing environmental consequences 

of park projects, managing park databases, collaborating with regional and national conservation 

efforts, and disseminating information about park resources. The wilderness coordinator position 

has traditionally been within this division.

All of these divisions would continue to be directly involved in wilderness and backcountry 

management through participation in Isle Royale’s planning teams and Backcountry 

Management Group (BMG), an inter-divisional advisory group. The BMG consists of 

representatives from each of the above divisions and meets several times a year with field visits 

to assess backcountry and wilderness conditions, and make recommendations on needed 

backcountry and wilderness projects. 

Resource Management and Protection

Research in Isle Royale would continue to be guided by the park’s Resources Management Plan 

(1999), but there would be no specific coordinated guidance based on wilderness and 

backcountry management needs. 

Protecting Species of Special Concern

The NPS would continue to take action to protect species of special concern in Isle Royale. 

Species of special concern on Isle Royale include Federal and State-listed Endangered and 

Threatened Species, as well as other species with dwindling regional populations. Species of 

concern that are particularly vulnerable to recreation have direct relevance to this planning effort.

This includes the gray wolf, common loon, bald eagle, and coaster brook trout, as well as many 
No Action Alternative

40 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

sensitive plant communities. Isle Royale managers have and will continue to take actions to 

minimize or eliminate human impacts to these species. Threatened and Endangered species are 

discussed in greater detail in Chapter 3, §3.3.6, however there are certain actions that Isle Royale 

managers have taken in the past and will continue as appropriate to protect sensitive species in 

the park. 

Actions that have proven successful for protecting wolves on Isle Royale include: 

• closing the park to public access in the winter, 

• closing portions of the park to overnight camping during denning and rendezvous times,

• supporting research on wolf ecology and population viability, and monitoring human 

impacts on wolves at Isle Royale,

• educating the public about the importance of maintaining a separation between wolves 

and humans and reporting any interactions they have with wolves in the park. 

Actions that have proven successful for protecting bald eagles on Isle Royale include:

• closing or rerouting trails adjacent to eagle nests

• closing campgrounds adjacent to eagle nests while the eagles are actively nesting

• supporting monitoring efforts and research about eagle productivity and associated 

human impacts on Isle Royale

• educating the public about successful conservation measures that have led to a resurgence 

of eagles in the park.

Actions that have proven successful for protecting loons on Isle Royale include:

• rerouting portages that are in close proximity to loon nest sites,

• temporarily closing particularly vulnerable loon nesting areas to paddling until chicks 

have fledged (this has proven successful at the southwestern-most end of McCargoe 

Cove, where loons appear to be having greater nesting success since the closure was 

enacted), 

• supporting monitoring efforts and research about loon productivity and associated human 

impacts on Isle Royale,

• educating the public about research findings that indicate loons have a particular 

sensitivity to human intrusions during their nesting and chick-rearing periods, and how 

people can minimize adverse impacts on loons.

Actions that are being taken to protect coaster brook trout within Isle Royale waters include:

• working together with the MI DNR to establish and maintain viable coaster populations;

• supporting research and management partnerships with the US Fish and Wildlife Service 

and the State of Michigan within Isle Royale waters and the Lake Superior Region;

• educating the public about the uniqueness and importance of the Isle Royale populations

of coaster brook trout.

Actions that have been taken to protect sensitive plant species and communities on Isle Royale 

include:

• conducting plant surveys to be aware of vulnerable areas when planning development 

projects;
No Action Alternative

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 41

• identifying vulnerable areas where recreation use should not be encouraged;

• considering rare plant communities in identifying areas closed to camping;

• surveying sites of proposed development such as trail reroutes, campsites, outhouses, and 

new buildings to avoid impacting rare plants;

• supporting research and monitoring of rare plants in the park, including mapping of 

known locations;

• educating the public about the rare plant communities of Isle Royale and actions they can 

take to minimize recreation impacts.

Isle Royale managers have utilized available information about these sensitive species and other 

vulnerable resources in making management decisions. This information has been helpful in 

locating trails and campgrounds, informing the public, and other measures to direct recreational

use away from areas that are most vulnerable to human impacts.

Scientific Activities in Wilderness

One of the legal purposes of wilderness is to provide opportunities for scientific 

activities, and these activities would continue to be encouraged and permitted within Isle 

Royale’s wilderness and backcountry, when consistent with the NPS’s responsibilities to 

preserve and manage wilderness. 

Isle Royale has a standing policy for establishing permanent plots with permanent or long-term 

physical markers. The intent is to balance the needs of long-term research projects with the 

desire to minimize associated physical impacts in the park’s wilderness. According to this policy 

“the long-term significance of a research plot, along with its associated data, is the fundamental 

reason for nominating it for permanent marking.”

Monitoring Wilderness Resources

The Natural Resource Division would continue to oversee and conduct natural resources 

monitoring projects, including species of concern, air and water quality, and recreation impacts. 

The division would continue to cooperate with the NPS Great Lakes Network for natural 

resources inventory and monitoring. Cultural Resources Management would continue to oversee 

and conduct cultural resources preservation and monitoring projects, and coordinate with local 

and regional interests. However, there would not be a coordinated, cohesive plan for monitoring 

wilderness and backcountry resources in the park and applying monitoring information to 

management efforts. 

Area Closures

With this WBMP, park managers would retain the right to implement temporary or permanent 

area closures within the park’s wilderness and backcountry. Closures are implemented on 

specific sites to protect sensitive wildlife from human disturbance, larger area closures may be 

implemented for habitat protection or protection of wildlife with broader area needs, other valid 

justifications for closures include protecting human health and safety, and protection of sensitive 

cultural resources. Closures may be for certain activities or for all public access.
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42 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

The following actions would be taken as part of the implementation of Isle Royale’s WBMP. 

This would be in conjunction with the preferred alternatives for changing the management of 

overnight use, day use, campfires, fire towers, and picnic tables in the wilderness and 

backcountry. 

2.3.1 Wilderness Boundaries and Management

All alternatives would maintain existing wilderness boundaries and acreage, including managing 

PWAs as wilderness. 

As part of this WBMP, all PWAs on Isle Royale where non-conforming uses have ceased would 

be converted to Wilderness through the proper steps. Current non-conforming uses will be 

evaluated in the park’s upcoming Historic Properties Plan where necessary.

2.3.2 Visitor Use and Experiences, Including Facilities and Services

Appropriate and Traditional Uses

This WBMP would not propose changes in current uses or regulations (Appendix E-F) in Isle 

Royale’s wilderness and backcountry. Appropriate and traditional uses within the park include 

hiking, backpacking, paddling, sailing, motorboating, sport fishing, commercial fishing with 

special use permits, scuba diving, charter diving and fishing with incidental business permits, 

and scientific research. Some of these activities are restricted within the park’s designated 

wilderness. Although the same types of uses would continue, the levels of visitation could 

change, as outlined in the alternatives for managing overnight use of the wilderness and 

backcountry (§2.4.1) and alternatives for managing day use (§2.4.2).

Cross-country Camping and Anchoring Out

Cross-country camping and anchoring out would remain an option for visitors seeking 

opportunities outside of designated campgrounds and docks, continuing current regulations 

(Appendix E-F) and permitting requirements. Under all of the action alternatives, the NPS would 

have the option of managing or limiting the number of permits issued for anchoring out or crosscountry camping, as necessary to prevent or correct unacceptable impacts to park resources and 

values. 

Fishing

Any changes in fishing regulations would be addressed in the park’s Fisheries Management Plan 

(expected 2012). 

Two goals of the fishing and educational programs for Isle Royale would be to raise awareness 

of fishing regulations and to promote ethical practices when fishing. This would include the use 

of artificial lures only, proper disposal of fish remains, taking only as few fish as are needed and 

not more than the legal limit, safe handling of live fish, and preventing the introduction and 

2.3 Actions, or Changes, that would be Common to all Action Alternatives
Actions Common to all Action Alternatives

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 43

spread of exotic aquatic species. Educational outreach with the national Leave No Trace 

guidelines for fishing would be one tool used in this effort. 

Concessions and Private Business Operations

Private organizations, private businesses operating under a CUA, and concession operations will

continue to provide valued services to Isle Royale visitors. Park-wide changes in permitting for 

camping and boating presented in the action alternatives for managing overnight use in the 

wilderness and backcountry would apply to organizations and businesses, as well as individual 

visitors. Group size limits proposed for organized day tours under the action alternatives for 

managing day use in the wilderness and backcountry would also apply to private organizations 

and businesses leading day trips in the park. 

Permitting and Information Services

Backcountry Permits for Campers and Boaters

Under all alternatives backcountry permits would continue to be required for all parties camping 

or boating overnight in Isle Royale’s wilderness and backcountry. Parties of 7-10 people would 

still be required to make advanced reservations for group campsites. However, how and where 

permits are issued could change, with options presented in the alternatives for managing 

overnight use of the wilderness and backcountry (§ 2.4.1). These alternatives also present options 

for improving visitor information services. Under all alternatives, park managers would have the 

option of adjusting visitation levels or distribution, or modifying human activities as necessary to 

slow or reverse deteriorating social or resource conditions.

Leave No Trace education and explaining backcountry regulations would remain a critical part 

of permitting for all visitors.

Information and Education Services

Public education is a critical component of any wilderness and backcountry management 

program. Education is important for park visitors, the public who do not visit the park, and NPS 

and partner employees. The WBMP would remain consistent with Isle Royale’s Comprehensive 

Interpretive Plan (2000) and would serve as guidance for interpretive and educational programs 

in the future by outlining goals and desired conditions for the future of the park. Education and 

interpretation would be used as a tool to foster public stewardship and minimize adverse human 

impacts to park resources and values. 

Alternatives for managing overnight use of the wilderness and backcountry present options for 

improving visitor information and trip planning services within the park. 

Group Size Restrictions

There would be no change in group size limits for camping parties. However, in order to 

preserve the appropriate conditions for solitude and tranquility, campgrounds within the 

Primitive Zone would be reserved for those entering the park as “individual” parties. This would 

provide an opportunity for visitors seeking a higher level of solitude and tranquility. To protect 

this opportunity, groups of 7-10 would not have the option of camping within these areas, even if 

they split into multiple parties. Primitive Zone campgrounds are; North Desor, Little Todd, 
Actions Common to all Action Alternatives

44 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

Pickerel Cove, Lane Cove, Intermediate Lake, Wood Lake, Lake Whittlesey, and Duncan Bay 

once the dock is removed. 

The alternatives for managing day use in the wilderness and backcountry present options for 

changing group size limits for day tours. 

Wilderness and Backcountry Facilities

The intention of facilities constructed and maintained within the park’s wilderness and 

backcountry would be to maintain the minimum structures necessary to protect resources and 

provide for appropriate recreation access. 

Additional facilities in Rock Harbor

All alternatives would include the addition of a small number (2-6) of rustic facilities for lowcost multiple night stays in Rock Harbor. Although these facilities would be added in the 

Developed Zone, not within the wilderness or backcountry, their addition would be intended in 

part to alleviate pressure on wilderness and backcountry campgrounds. Additional assessment of 

environmental impacts and compliance documentation would be completed prior to constructing 

these new facilities.

Campgrounds

Any changes in campground sizes or new campgrounds are addressed in the action alternatives 

for managing overnight use of the wilderness and backcountry. 

Trails

The trail system and its management would remain unchanged in all proposed alternatives, 

except for a possible new 3-5 mile section of trail designed for day use near Windigo, as 

described in Alternative C for managing day use in the wilderness and backcountry. 

Signs

There would be no change in the use of signs in the wilderness and backcountry, maintaining a 

policy of posting only those signs deemed necessary for minimal visitor service and education 

and resource protection along trails, at campgrounds, and at significant cultural or natural 

resource sites. The NPS would continue or increase efforts to use rustic, locally compatible 

materials for signs, such as rough-hewn cedar posts with burned lettering. 

Docks

There would be no changes in docks from the current conditions, except for those changes 

approved in the GMP. 

Ranger Stations

Existing ranger stations with residences would be maintained at Rock Harbor, Windigo, 

Amygdaloid Island, and Malone Bay to provide for visitor safety, resource protection, public 

service, and support of park operations. No additional ranger stations or other backcountry-based 

buildings for NPS employees and administration would be established.
Actions Common to all Action Alternatives

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 45

Repeaters and Communications Facilities

Any changes in radio repeaters, communications facilities, or other telecommunications 

equipment in Isle Royale’s wilderness and backcountry would require appropriate compliance to 

evaluate feasible alternatives and assess environmental consequences. This would include 

considering alternatives that would be based outside of the park’s designated wilderness. 

2.3.3 NPS Administration and Operations

Minimum Requirement Process

The Minimum Requirement Process with the Minimum Requirement Decision Guide (Appendix 

G) would be implemented and institutionalized. Isle Royale’s Wilderness Coordinator would 

maintain a file of all documented decisions using the minimum requirement process that would 

be available for reference. 

All management decisions and activities on Isle Royale must include a well-documented 

assessment of whether actions would affect wilderness resources or visitors’ experiences, and if 

so, if the actions are necessary and appropriate, and if there are alternatives to minimize impacts. 

Part of this minimum requirement process is identifying the minimum tool, which is defined as 

the least intrusive tool, equipment, device, force, regulation, or practice that would achieve the 

wilderness management objective safely and with the least impact on wilderness resources. 

These decisions must be well documented using the Minimum Requirement Decision Guide, and 

be accompanied by an appropriate environmental compliance document. Assessment of adverse 

impacts must consider physical resources within wilderness, as well as wilderness character and 

values, which include: primeval character and influence, the preservation of natural conditions 

(including a lack of man-made noise), cultural resource values, outstanding opportunities for 

solitude, opportunities for primitive and unconfined recreation, and the preservation of 

wilderness in an unimpaired condition (NPS 1999b). Where actions take place outside of 

wilderness, consideration should also be given to how those actions may have indirect effects on 

wilderness character and values. This process does not, however, preclude impacting tools; for 

example, helicopters could be determined to be the minimum tool under certain circumstances. 

The minimum requirement concept will be applied as a two-step process that 

determines:

• Whether the proposed management action is appropriate or necessary for 

administration of the area as wilderness and does not pose a significant 

impact to wilderness resources and character; and

• The techniques and types of equipment needed to ensure that impacts to 

wilderness resources and character is minimized.

...When determining minimum requirement, the potential disruption of 

wilderness character and resources will be considered before, and given 

significantly more weight than, economic efficiency and convenience. If a 

compromise of wilderness resources or character is unavoidable, only 

those actions that preserve wilderness character and/or have localized, 

short-term adverse impacts will be acceptable (NPS 2006, § 6.3.5). 
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46 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

The Minimum Requirement Decision Guide would also apply to all research conducted at Isle 

Royale, which is consistent with NPS policies. Methods and tools proposed for the research must 

consider impacts to, and appropriateness for, wilderness. Although research is appropriate for 

wilderness and is essential for managing and protecting wilderness, some proposed research 

projects might be better suited to non-wilderness settings or designed with alternative low-impact 

field methods. Additionally, analysis of existing datasets may be a better option than collecting 

new field data. These types of considerations will be used in assessing research proposals for Isle 

Royale’s wilderness, weighing the benefits of what can be learned against the impacts on 

wilderness resources and values (NPS 2006, § 6.3.6). 

Maintenance of the Wilderness and Backcountry

Administrative use of motorized or mechanized equipment

Administrative use of motorized or mechanized equipment by the NPS must meet the 

requirements of the Minimum Requirement Decision Guide (see Appendix G), including a 

recommendation by the Chair of the Backcountry Management Group and the Superintendent’s 

signature. Acceptable uses would include emergencies where human life is at risk, or where use 

of a mechanized tool is determined to be the least intrusive method on wilderness character and 

values. Within and outside of designated wilderness park management would continue to work 

toward more sustainable operations, including purchasing water- and energy-conserving systems 

and machinery. For example, the National Park Service would take a leadership role in using less 

polluting, quieter boats as current equipment is upgraded or replaced (NPS 1998 p. 27).

Isle Royale managers would commit to further reducing the use of chainsaws within wilderness.

However, current levels of funding for training and staffing are inadequate to pay for the 

personnel and expertise that would be necessary to achieve these standards with the exclusive 

use of hand tools in the park’s wilderness. A future goal would be to increase the use of hand 

tools in maintaining the trails and campgrounds within Isle Royale’s wilderness. Options for 

accomplishing this include 1) partnerships with other agencies that may offer a skill base in the 

use of cross-cut saws and other hand tools that could replace chainsaws, 2) trainings for 

maintenance crews, leaders, and supervisors in the use and upkeep of cross-cut saws, and 3) 

evaluation of areas of the park and sections of trails that would be best suited for cross-cut crews. 

Exceptions would continue to allow for chainsaw use in the case of emergencies involving 

human health and safety.

 

The National Park Service would also commit to reducing the impacts of other power tools used 

for maintenance on trails and in backcountry campgrounds and docks. Within 5 years of 

completion of this plan, maintenance projects in the wilderness and backcountry would be 

categorized with appropriate minimum tools for each type of project, thus the minimum tool 

process would not have to be applied to each individual project. 

Appropriate Types of Lumber for Trails, Docks, and Campgrounds

Maintenance crews would aim to maintain current trail standards while minimizing the impacts 

of using local materials for construction and also using the most efficient, least contaminating 

materials possible. Lumber treated with chemical preservatives, and those with natural 

preservatives (such as cedar) have proven to have about twice the lifespan of untreated lumber. 

Lumber treated with chemical preservatives known to be of environmental concern, such as 
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CCA, would not be used in Isle Royale’s wilderness and backcountry. Technological advances in 

lumber preservatives have lead to the development of more benign alternatives that are more 

economically feasible than lumber with natural preservatives. When lumber is necessary for trail 

construction and maintenance, the most benign chemical treatments would be acceptable for use 

in the wilderness and backcountry. An additional goal would be to utilize “green” lumber that is 

commercially managed and harvested with sustainable practices. 

Maintenance crews would continue to use local materials, as well, on a limited basis for trail and 

campground work. Local cedar and other tree species could be utilized for corduroy, water bars, 

boardwalk footings, and other applications. Local rocks would continue to be used for purposes 

such as stepping-stones, trail stabilization, drainages, and constructing tent pads.

The amount of bridging, boardwalks and drainage structures would continue to be minimized to 

the greatest extent feasible through trail reroutes. Remaining signs, boardwalks and bridges 

within the park’s wilderness and backcountry would all be constructed using a minimal amount 

of local materials and the most benign chemically treated lumber that is commercially available. 

This would maximize the lifespan of trail structures, minimizing long term costs of materials and 

labor. Protecting fragile habitats from trampling, trail widening, and erosion as well as 

minimizing hazardous trail conditions would remain a primary objective of trail construction and 

maintenance. The use of the most benign chemically treated lumber would minimize the risk of 

detrimental contamination of soils and water. Continuing the use of imported lumber would also 

minimize the local impacts of utilizing native materials for trail construction and maintenance. 

• Trail and dock maintenance staff would continually research alternatives for treated 

lumber to remain abreast of the most environmentally benign options available. This 

lumber would be used for trail and dock construction and maintenance in the park’s 

wilderness and backcountry.

• Trail crews would use minimal native materials in lieu of imported lumber where feasible 

and continue rerouting trails to avoid wet areas and fragile habitats to minimize the need 

for lumber. 

• Trail structures and docks would be designed to be compatible with their surroundings 

and wilderness character.

• Options for identifying some trail sections as free from treated lumber would be explored. 

• Proposals for trail and dock projects would include adequate funding and planning to 

include removal of any waste lumber as a part of project completion. 

• Information would be gathered about threats of adverse impacts from chemicals used in 

treated lumber as future research became available. As need dictated in the future, 

mitigation measures would be taken to minimize known threats, including removal of 

contaminating materials. 
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Resource Management and Protection

The NPS is required by law and policy to protect natural and cultural resources within National 

Parks. Specific management decisions are developed within the park for this purpose. With this 

WBMP, if resource impacts were greater than expected with any natural or cultural resources, 

managers would combine mitigation actions that modify resources with mitigation actions that 

alter human behavior, visitor distribution, or numbers and locations of people in the wilderness 

and backcountry. Resource modifications could include such things as marked routes, signs, 

constructed trail sections, groomed trails, trail reroutes or closures, designated campsites, 

campsite closures or relocations, area closures, outhouses, and tent platforms or other structures 

to protect resources in campgrounds. 

Cultural Resources Management

The specific details of how Isle Royale’s cultural resources will be managed are beyond the 

scope of this WBMP. This will be developed in a forthcoming Historic Properties Management 

Plan, and/or a Cultural Resources Management Plan, which will be consistent with the 

management goals and actions in this WBMP.

Ecological restoration

Whenever facilities are removed in the wilderness or backcountry disturbed areas would be 

restored with native vegetation with steps taken to prevent the establishment of exotic species. 

This includes the removal of structures as well as the closure of campsites, trails, and other 

development impacts. The goal would be for full ecological restoration of the native species and 

ecological functions.

Exotic plant communities could be associated with cultural landscapes. In areas where exotic 

vegetation exists as part of a cultural landscape, the vegetation would be evaluated according to 

its cultural significance and threat to native species. In some cases culturally significant exotic 

species may be retained on a limited basis, if it is feasible to prevent the species from spreading 

and competing with native species. 

Protection of natural resources

The principle of non-degradation will be applied to wilderness management, and each 

wilderness area’s condition will be measured and assessed against its own unimpaired 

standard. Natural process will be allowed, insofar as possible, to shape and control 

wilderness ecosystems. Management should seek to sustain the natural distribution, 

numbers, population composition, and interaction of indigenous species. (NPS 2006, 

§6.3.7)

An overriding goal of managing the natural resources within Isle Royale’s wilderness and 

backcountry is to ensure ecosystem integrity and prevent impairment of any resources. More 

specifically, the NPS is also required to manage for the preservation of Threatened and 

Endangered plants and animals, including restoring and maintaining listed species’ habitats, 

controlling detrimental visitor access, and re-establishing extirpated populations. State and 

locally listed species will be managed in a manner similar to the management of federally listed 
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species, “to the greatest extent possible” with a goal of maintaining natural distribution and 

abundance. (NPS 2006, §4.4.2.3)

The specific goals and actions for managing natural resources on Isle Royale are discussed in 

great detail in several resource management plans for the park, and this WBMP would remain 

consistent with these plans; Natural Resources Management Plan (1999), Fire Management Plan 

(2004), Water Resources Management Plan (2005), and Fish Management Plan (anticipated 

2012).

Protecting Species of Special Concern

Efforts to protect species of special concern in the park would continue, with an additional 

commitment to support future research on sensitive species and their vulnerability to human 

impacts and apply new information as it becomes available to management decisions for 

resource protection.

Scientific Activities in Wilderness

Current efforts to provide opportunities for scientific activities within Isle Royale would 

continue. Additionally, the NPS would expand efforts to use science to improve wilderness 

management, and as appropriate contribute to national and global conservation efforts. To aid in 

maintaining a consistency between wilderness protection and fostering scientific exploration, the 

Minimum Requirement process would apply to all scientific activities proposed for Isle Royale, 

with a goal to work with researchers to develop scientific techniques that are low-impact and less 

intrusive. To accomplish this, Isle Royale’s Minimum Requirement Decision Guide would apply 

to all proposed research activities.

Even those scientific activities (including inventory, monitoring and research) 

that involve potential impacts to wilderness resources or values (including access, 

ground disturbance, use of equipment, and animal welfare) should be allowed 

when the benefits of what can be learned outweigh the impacts on wilderness 

resources or values. However, all such activities must be evaluated using the 

minimum requirement concept and include documented compliance that assesses 

impacts against benefits to wilderness. This process should ensure that the 

activity is appropriate and utilizes the minimum tool required to accomplish 

project objectives (NPS 2006, §6.3.6.1)

These objectives and processes would apply to all scientific activities within wilderness, 

including natural, cultural, and social research, monitoring, and inventories. 

Organization

All Isle Royale Divisions would continue to be involved in wilderness and backcountry 

management for the park. 

Wilderness Management Accountability and Training

As directed by NPS Director’s Order 41, all positions having significant wilderness 

responsibilities will be supported by position descriptions that detail these responsibilities. 
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Implementation of this WBMP will include incorporating wilderness responsibilities into 

position descriptions for the following positions:

• Superintendent

• Assistant Superintendent

• Chief of Natural Resources

• Cultural Resources Program Manager

• Chief of Interpretation

• Chief of Maintenance

• Facility Manager

• Chief Ranger

• East and West District Rangers

• Trails Foreman

• Campgrounds Foreman

• Lead Biological Science Technician

• Forestry Technician

Knowledge of and experience with wilderness laws, policies, ethics, and management practices 

will also be integrated into vacancy announcements for these positions. 

Isle Royale will designate one permanent staff member to be the acting Wilderness Coordinator. 

Where funding allows this would be a specialist position, otherwise it would be a collateral duty. 

The Wilderness Coordinator will have direct responsibility for the development, coordination, 

communication, implementation, and accountability for the park’s wilderness program. The 

Wilderness Coordinator will also serve as a liaison to Regional and National wilderness 

programs. 

Other positions at Isle Royale involve significant work responsibilities that are carried out in the 

park’s wilderness, or involve significant time working with the park’s wilderness visitors. 

Wilderness training (described in detail below) will be a priority for these positions, as well. 

Wilderness Training for Key Staff

Per NPS Director’s Order 41, Isle Royale managers will ensure that each key staff person having 

responsibility for the management and protection of wilderness resources will receive the 

wilderness training necessary to ensure awareness, knowledge of, and accountability for, their

specific wilderness responsibilities. Training requirements for superintendents and assistant 

superintendents as well as for any division chiefs or other individuals identified above will be 

followed as directed in DO 41 in order to preserve the delegation of authority. Isle Royale’s 

Wilderness Coordinator will work with the National Park Service representative at the Arthur 

Carhart National Wilderness Training Center to ensure availability of needed training or training 

materials. 

Wilderness training will be incorporated into seasonal training each year for all staff working 

primarily in the backcountry and wilderness, or working directly with wilderness visitors. This 

includes but is not limited to trail crew, campground crew, visitor center staff, interpretive 

rangers, biological science technicians, and commissioned and non-commissioned rangers. It is 

also recommended that wilderness training and the application of the Minimum Requirement 

Process be included in supervisor training. Additionally, because all island-based employees live, 

work, and recreate either adjacent to or in wilderness, a summary of wilderness policies and 

ethical considerations will be incorporated into staff orientation materials or presentations. 
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Recommended trainings include national-level wilderness stewardship training for the 

Superintendent and/or other management squad positions; Regional wilderness stewardship 

training for the Chief of Natural Resources, Chief Ranger, and Chief of Maintenance; and 

subject-matter trainings for permanent staff within the Natural Resources Division, Protection 

Division, and the Interpretation and Cultural Resources Division. Currently those courses are 

available to NPS employees through the Arthur Carhart National Wilderness Training Center in 

the form of on-site trainings in various locations, over the Internet, and through distance learning 

programs such as Tel-Net. 

Additionally, it is recommended that at least one member of Trail Crew, Interpretation, 

Protection, and Natural Resources be up-to-date as a certified Master of Leave No Trace. Leave 

No Trace training is available from various sources, including independent certified instructors 

in Leave No Trace.

Staff Responsibilities and the Backcountry Management Group

The success of the WBMP would be largely dependent on staff accountability and clear 

responsibility. Isle Royale’s BMG would continue to meet on a regular basis, including field 

visits, to discuss wilderness and backcountry management issues, identify issues in need of 

management attention or change, and make recommendations. This group was established to 

provide for a unified approach to planning, maintenance, and management of backcountry areas, 

and this need would continue. The BMG would continue to consist of representatives from park 

divisions and branches with job responsibilities directly related to management of the park’s 

wilderness and backcountry. Standing members would continue to include cultural and natural 

resource management specialists, trails foreman, interpretation and education specialist, and 

district rangers. 

With implementation of this WBMP, Isle Royale’s interdisciplinary Management Team would 

meet annually to review wilderness management issues, discuss the current Wilderness Status 

Report, and assess management effectiveness and changes in management actions that may be 

necessary to achieve the goals of the WBMP. This team consists of the Superintendent, all ISRO 

division chiefs, and staff representatives from the key programs of each division. 

Interagency Coordination 

Although Isle Royale does not share a border with other federal land agencies, coordination with 

other agencies will still be important. The Michigan Department of Natural Resources retains 

jurisdiction over Lake Superior waters within the park’s boundaries. The coastguard would 

remain a vital partner for many human safety and other issues. The US Fish and Wildlife Service 

would remain involved in the management of federally listed species and their habitats, as well 

as acting as an adviser in other issues of species management. The US Geological Survey and 

Biological Resources Division would remain important partners for research consultation. Isle 

Royale managers would also coordinate with other park managers in the Lake Superior and 

Great Lakes Region to meet the broader regional goals for backcountry and wilderness 

management issues. All of these partner agencies received copies of the Draft WBMP for review 

and input.
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Wilderness and Backcountry Management Plan Implementation

Implementation of portions of this plan may be dependent on park budget and staffing. 

Acceptance of this plan identifies guidance and priorities and future management direction, but 

does not guarantee the funding that may be required for full implementation. 

Monitoring Recreation Impacts

Monitoring current conditions and trends would be critical to the long-term success of wilderness 

management, in part to determine the effectiveness of management actions for achieving goals 

and tracking any unintended effects of actions. As part of the implementation of this Wilderness 

and Backcountry Management Plan, Isle Royale would develop and implement an accompanying 

monitoring plan. This would include a detailed schedule of what would be monitored, how 

frequently, and who would take primary responsibility, as well as an outline of an annual status 

report for wilderness conditions and more thorough 5-year “State of the Wilderness Report” for 

summarizing monitoring results and management implications. The ultimate goal of this plan 

would be to assess current conditions against stated goals for resource and visitor conditions and 

evaluate the effectiveness of management actions to achieve or maintain these goals, as well as 

evaluating the impacts of management on wilderness conditions. The monitoring plan would be 

based largely on indicators and standards established in this WBMP, but would also include 

general resource monitoring that is pertinent to wilderness and backcountry management. This 

information would be used to better inform management and direct necessary changes in 

management actions. This is consistent with NPS Management Policies (NPS 2006, §6.3.6.2), 

which states “the conditions and long term trends of wilderness resources would be monitored to 

identify the need for, or effects of, management actions.”

Indicators that would be monitored include, but may not be limited to (to be established in the 

monitoring plan):

• Frequency of parties sharing campsites in overfull campgrounds

• Rates of trail encounters

• Annual visitation levels and temporal and spatial distribution of visitors

• Density of boats anchoring out in anchorage areas

• Biophysical conditions in campgrounds, including recreation impacts and screening 

between campsites

• Biophysical impacts of recreation and NPS activities in pristine zones (off-trail)

• Wolf-human encounters

• Loon nesting success, productivity, and population viability.

• Condition assessments of archeological sites and cultural landscapes along trails and 

within and adjacent to campgrounds.

Cultural resources monitoring for impacts from recreation and management activities would also 

be monitored as an important facet of wilderness and backcountry management, but these goals 

and protocols would be developed in conjunction with an Historic Properties Management Plan 

and/or Cultural Resources Management Plan for Isle Royale. 

Isle Royale’s Division of Natural Resource Management would be responsible for the 

completion and implementation of the monitoring plan for the WBMP, with assistance from the 
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park’s other divisions and branches as appropriate, such as Cultural Resources Management, 

Interpretation and Visitor Services, and Trails and Campground management.

Adaptive Management and Additional Research Needs

Wilderness and backcountry management is an iterative process that requires adaptive 

management with some flexibility as new information becomes available. The intent is to retain 

goals and objectives while allowing for flexibility in actions taken to most effectively achieve 

those goals. Research and information gathering will continue to be important to better 

understand the effectiveness and implications of management actions. Management decisions at 

Isle Royale will be based on the best information available, though desired information is not 

always available. To date the process of planning for and managing wilderness and backcountry 

on Isle Royale has identified several research needs that could aid in future management 

decisions. This list of needs will help to seek out and prioritize future research projects in the 

park:

Wolf-human interactions

One critical component of protecting wolves on Isle Royale is maintaining minimum 

wolf-human interactions and preventing the habituation of wolves to humans. Some 

questions needing to be better understood include: what relationship is there between 

human travel patterns on the island and wolf travel patterns? Is there a trend in the 

frequency and nature of wolf-human encounters on the island?

Options for minimizing human impacts on loons

Research supports the conclusion that human behavior, particularly in canoes, can and 

does have adverse effects on the nesting success of loons on Isle Royale. Given this, what 

management actions are most effective in minimizing these impacts, while also allowing

for appropriate recreation access to the park’s waterways?

Invasive exotic species

Invasive exotic species pose a significant threat to the individual native species, as well 

as the integrity of terrestrial and aquatic ecosystems on Isle Royale. Fortunately, some of 

the most serious invasive species known in the Great Lakes Region have not yet become 

established on Isle Royale. Additional research is needed to identify the most effective 

means of preventing the introduction and establishment of these invasive species, and if

established, the most effective means of eradication or containment. 

Ecosystem integrity

Much of Isle Royale’s natural sciences research has focused on individual species. One 

critical component of wilderness character is naturalness, which speaks to the health, 

sustainability, and natural state of an ecosystem. Better understanding ecosystem integrity 

and the effects that human influences have on ecological systems and functions, as well 

as exploring any differences between the island’s current state and a natural state, are 

critical for long-term management. 
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Recreation impacts on cultural resources

Additional research is needed to monitor recreation impacts on cultural resources, and 

establish guidelines for acceptable levels of impacts, if any can be established within 

policies for maintaining the integrity of these sites. A thorough inventory of cultural 

resources that may be vulnerable to recreation impacts is also needed. These issues will 

be addressed in the upcoming Historic Properties Management Plan and or Cultural 

Resources Management Plan for Isle Royale.

Cross country impacts

What are the current impacts in the pristine zone from cross-country travel and camping? 

How do current impacts compare to desired conditions? Should current levels and 

distribution of cross-country use be modified, considering impacts to sensitive resources 

and management goals for these areas?

Aquatic contaminants

What are existing threats of contaminants in campgrounds, from treated lumber, and 

associated with NPS operations? How might these contaminants be controlled to 

minimize adverse effects to resources?

Social sciences questions

Although Isle Royale has completed a fairly thorough assessment of social conditions in 

the park, some important questions remain, including how to best monitor and manage 

for appropriate levels of trail encounters, how to better understand people’s choices that 

result in impacts, and how to evaluate the effectiveness of educational efforts and 

regulations to minimize impacts.

Inventory and monitoring of cultural resources

Limited inventory of the park’s cultural resources has been completed. Additional efforts 

would focus on identification of cultural landscapes and ethnographic resources in visitor 

use areas. Research is needed to evaluate the relationship between cultural and natural 

resources and to provide options for preservation in wilderness. A system to monitor 

impacts to cultural resources is needed to protect those resources and identify changes 

over time. Because cultural sites, such as mining remains and fishing camps, can be an 

important part of the wilderness experience, sites would be monitored to ensure 

perpetuation of that experience. 
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The alternatives presented here are based on Isle Royale’s mission, purpose, significance, and 

objectives for wilderness and backcountry management and present different ways to manage 

resources and visitor use in the park’s wilderness and backcountry. The alternatives were 

formulated by the park’s interdisciplinary planning team with public input, consultation with 

partners and subject matter experts, and thorough review of laws, policy, relevant research, and 

examples from other National Parks and wilderness areas. The alternatives are divided into 5 

categories of issues; 1) overnight use of the wilderness and backcountry, 2) day use of the 

wilderness and backcountry, 3) campfires, 4) fire towers, and 5) picnic tables in wilderness. 

These issues and the range of alternatives for addressing them arose during the scoping process. 

They are addressed individually because each stands alone and deserves specific public 

comment. The no action alternative for each issue serves as a baseline for comparison. 

2.4.1 Description of Alternatives for Overnight Use of Isle Royale’s Wilderness and 

Backcountry

The majority of people who visit Isle Royale (about 70%) spend one or more nights in the park’s 

backcountry, camping, staying aboard a docked boat, or anchoring out. Changes proposed to the 

way visitation is managed are designed to improve conditions for these visitors, minimize 

adverse impacts to the park’s resources caused by backcountry activities, and address issues 

raised by the public relevant to overnight recreation. These public issues and concerns include: 

1) public access to Isle Royale, 2) freedom and flexibility of travel within the park, 3) crowding 

in campgrounds and having to double up in overcrowded campsites, 4) the simplicity of the 

park’s permitting system and regulations, 5) protection of park resources, 6) protection of 

wilderness character, and 7) providing options for a range of user groups and diverse interests. 

Where some of these interests may be in conflict, compromises are necessary. The context of Isle 

Royale is also important, where the remoteness of the park, logistics necessary for trip planning, 

and costs of simply reaching the park must be considered. 

One of the salient issues raised here is availability of a sufficient number of campsites to 

accommodate the number of parties staying in a campground for a night. When the number of 

parties in a campground exceeds the number of campsites, parties are asked and expected to 

double up, or share campsites, with multiple parties camping in a site designed to hold one party. 

Although many people report that sharing sites ended up being a positive experience in which 

they met very nice people, others point out that being forced to share when adequate sites are not 

available is inappropriate for the types of experiences people expect with a trip to Isle Royale’s 

wilderness (Isle Royale 2002). People will always have the choice of socializing and meeting 

new people while camping at Isle Royale; the issue is whether they should be forced to do so. 

Adverse impacts to people’s experiences such as noise, a loss of privacy and solitude, and the 

pressures of finding camping space are concerns, as are physical impacts associated with 

overcrowding in campgrounds. The goal of improving wilderness and backcountry experiences 

includes reducing the frequency of parties needing to share campsites. However, the goal of not 

2.4 The Action Alternatives, Including the Preferred Alternatives
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56 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

being overly restrictive or unduly limiting public access to the park suggests that some minimal 

level of campsite sharing may be necessary. 

The alternatives presented in this chapter represent a range of feasible options for achieving these 

goals for overnight visitation in the park’s wilderness and backcountry. Each of these action 

alternatives addresses the park’s visitor carrying capacity by establishing goals for social 

conditions and the number and size of designated campgrounds. All of the alternatives are 

similar in that they propose managing overnight visitation based on campsite availability and a 

limited tolerance for parties doubling up in campsites. The goals and potential management 

actions proposed in each alternative are summarized for comparison at the end of this section 

(Table 4). Chapter 4 outlines the implications of each of the alternatives for visitor use levels and 

visitor experiences. 

Alternative A for Managing Overnight Use: No Action, Continuation of Existing 

Management Direction

A.1 General Description

The National Park Service would maintain its current management direction, continuing with 

implementation of the GMP but making no other significant modifications to wilderness and 

backcountry management. Isle Royale would continue a management approach of issuing 

permits at the start of a trip, allowing for freedom of flexible travel in the park and maximum 

visitor access within the current transportation system. In effect, backcountry visitation levels 

would be determined by transportation capacities, as the NPS would not implement any 

visitation limits other than maintaining existing ferry capacity limits and schedules.

A.2 Management Goals and Actions

The current management direction of accommodating all visitors who are able reach the island 

would continue. 

A.2.1 Visitor Use Levels

Visitor use levels would not be actively managed other than through continuation of existing 

ferry schedules and capacities, the existing operational season, and the advanced reservation 

system for groups of 7-10 people. Visitor use levels in the wilderness and backcountry would be 

limited only by ferry and seaplane capacities, with no limits on people traveling to the island by 

private boat. Therefore, visitation could increase up to the point at which ferries sell out, and as 

much as people are willing to travel to the island with private boats. 

A.2.2 Backcountry Permits

Backcountry permits would continue to be required for all parties camping, docking, or 

anchoring out in the wilderness or backcountry. Permits would continue to be issued from 

several visitor centers in the park and on the mainland, and all parties would be required to 

register for a permit at the start of their trip. Backcountry permits would continue to be issued to 

all parties of 1-6 people who could reach the park, regardless of campground capacities and 

campsite availability, or dock capacities. Groups of 7-10 people would be required to register for 

group campsite reservations in advance of reaching the park, and group sites would not be 

booked beyond their availability. With a continuation of the current permitting system for small 
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parties it would not be possible to give accurate information about use levels at specific 

campgrounds on specific dates. 

A.2.3 Desired Future Conditions for Social Opportunities and Resources.

The NPS would continue to monitor social and resource indicators to identify deteriorating 

wilderness and backcountry conditions. With the knowledge of deteriorating resource conditions 

managers would have the option of taking actions to slow or reverse deteriorating conditions that 

would focus on facility design, public education and regulations.

A.2.4 Facilities and Services

The NPS would implement GMP-approved changes in docks, campgrounds and trails, but 

otherwise maintain existing wilderness and backcountry infrastructure, without any additional 

expansions in campgrounds. The NPS would maintain the flexibility to make adjustments as 

necessary for resource protection. Such adjustments may include trail reroutes, temporary 

closures of trails or campgrounds, relocations of campgrounds, or site hardening.

Existing wilderness and backcountry services would continue, including staffing ranger stations; 

conducting backcountry and wilderness patrols; maintaining trails, campgrounds and docks; 

staffing visitor centers; and offering park information via phone, Internet, publications, and 

personal contacts. 

A.2.5 Visitor Distribution Management and Solitude

Leave No Trace education would continue to be a cornerstone of visitor education at Isle Royale. 

Continued education on wilderness etiquette as well as more information on the need to share 

campsites during the peak season might mitigate some of the adverse impacts to visitor 

experience resulting from deteriorating social conditions. Under this alternative, NPS managers 

would continue to manage ferry schedules, ferry capacities, and camping party sizes, but 

otherwise would not actively manage visitor numbers. 

Visitors would have the choice to visit the park at more or less busy times of the season, and visit 

areas of the park that are expected to be more or less heavily used. Visitor Center staff would 

continue to educate visitors about visitation levels at different times of the seasons, and what 

general levels of crowding could be expected in different areas of the park throughout the season. 

This would give visitors an option to choose to come during different times of the season with 

more or fewer visitors. However, up-to-date accurate use levels at different campgrounds would 

not be available. If visitation increased significantly during any time of the season, the NPS 

would not limit or cap visitation levels beyond the capacities of existing transportation services.

A.2.6 Appropriate Management Actions 

The NPS would continue its current policy of using management actions other than limitations of 

visitation to address problems. Acceptable management actions would include:

• For deteriorating social conditions such as dock over-crowding, or trail or campground 

crowding, management actions would continue to focus on better informing the public of 

visitation levels in different areas of the park and different times of the season. However, 

with a continuation of the current permitting system it would not be possible to give site 

and date-specific information on dock or campground crowding. The goal would be to 
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58 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

modify people’s expectations about the social conditions they would find on Isle Royale. 

Additionally, backcountry staff would focus attention on overcrowded campgrounds to 

assist people in finding available and appropriate camping space for the night.

• For deteriorating biophysical conditions in campgrounds, the NPS would continue to 

modify campsite design to better concentrate and minimize impacts. Such modifications 

may include relocating campsites, revegetating areas, shrinking expanding campsites 

with physical boundaries such as transplanted trees and buried rocks, and temporarily or 

permanently closing sites in need of rehabilitation.

• Add monitoring to inform managers.

Alternative B for Managing Overnight Use: Preferred Alternative

B.1 General Description

The NPS would strive to provide a broad range of opportunities for quality wilderness and 

backcountry recreation with varying degrees of solitude, self-sufficiency and personal challenge. 

Additionally, overnight recreation would be managed to protect the park’s natural resources, 

with particular attention given to seasonal sensitivities. Establishing a mainland-based 

Backcountry Office with advanced permitting would improve information and services available 

to visitors for trip planning and improve visitor distribution to maintain quality opportunities and 

reduce adverse impacts from recreation. 

B.2 Management Goals and Actions

The overriding goal of this alternative is to provide a range of exemplary opportunities for 

wilderness experiences and minimizing limits on public access to the backcountry, while also

reducing adverse impacts to natural and cultural resources in the backcountry and wilderness, 

minimizing concerns for human safety, and improving trip planning services. 

B.2.1 Visitor Use Levels

Backcountry overnight visitation would be managed as necessary to meet goals for social 

conditions in campgrounds; 

• Spring (April 16-June 15): preserve historic visitation levels with visitation not exceeding 

the highest point between 1994-2003, which would limit the number of camping parties 

to not exceed 20% of park’s total camping capacity (Table 18).

• Summer (June 16- Sept 15): reduce campground crowding during the peak two weeks of 

the visitor season (between mid-July and mid-August) and allow for a moderate increase 

in visitation outside of those peak two weeks. With this goal, visitation would be 

managed as necessary so not more than 5% of parties per night need to double up in 

overcrowded campgrounds.

• Fall (September 16-October 31): allow for an increase in visitation within the existing 

ferry schedules and capacities, with only one ferry transporting passengers twice a week 

to and from the park after September 30. This would retain the fall as a low-use time, but 

still allow for some increase in visitation. 
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Campsite occupancy rates and/or frequency of parties doubling-up in campsites would be 

monitored and averaged on a weekly, or bi-weekly basis, with monitoring to include field 

surveys, analysis of backcountry permit data, and computer modeling.

B.2.2 Backcountry Permits

A mainland-based central permitting office would be established to improve trip planning 

services and proactively manage recreation in the park. Under this system, visitors would be 

required to get backcountry permits in advance of reaching the park. This would allow for better 

information for advanced trip planning, including how many parties were permitted for each 

campground, or how many boats were permitted for a dock on a given night. People could then 

plan their itineraries or the dates of their trips according to where there would be available space. 

However, some visitors may have to alter their travel plans to find dates or routes with available 

camping permits, and some people might not be able to get a permit for their campground of 

choice. Advanced permitting would also allow the park to manage the number of permits issued 

for compatibility with campsite availability and goals for reducing crowding in campgrounds. 

Permits would continue to be issued as flexible itineraries for parties of 1-6 people who were 

camping, anchoring out, or spending a night at a dock. However, permits would no longer be 

issued over a campground’s capacity, which would help to alleviate the problem of 

overcrowding. Campground capacities would be estimated based on advance itineraries. Permits 

would only be issued for reasonable itineraries, with a goal of minimizing a party’s need to alter 

their itinerary mid-trip. Reasonable itineraries would be determined based on a party’s 

experience level and the feasibility of a proposed itinerary. If campsites were not available at all 

of the campgrounds on a party’s planned itinerary they would need to either change the dates of 

their trip or modify their itinerary. Flexible itineraries would continue to allow for changes due to 

weather, injuries, and other unforeseen circumstances, and therefore a low level of campsite 

sharing would be expected and tolerated. 

For groups of 7-10 people permits would remain as site reservations with fixed itineraries. 

Designated group sites would continue to be reserved to full capacity, and groups would be 

limited to nightly reservation availability. Throughout much of the season these large groups 

would have no flexibility for changing their itineraries once they reach the park. 

Boaters, who are generally limited in their travel to and from the park by weather and lake 

conditions, would have 2 permit options. One would offer more certainty of being able to use 

campsites or shelters during their trip, the other would offer more flexibility to plan a trip at the 

last minute based on weather conditions: 

1. Go through the advanced permitting system to get a permit to be able to use shelters or 

campsites, (permits would be for available space, not a specific site in a campground, similar to 

the present system) following the same permitting process as all backpacking and paddling 

parties, with permits limited by campsite availability; or

2. If permits for shelters or campsites are no longer available, boaters may obtain a permit for 

dock space (if space remains) or for anchoring out, without the option of using a campsite or 

shelter. Based on boat lengths and campground dock lengths, the permitting system will allow 
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60 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

applicants to see ahead of time whether dock space is still available at full campgrounds, and can 

adjust their itinerary accordingly. If dock space is still available where all campsites have been 

booked at a campground, then a boater will be able to obtain a permit for dock space only. If 

dock space and campground space appear to be full when a boater is applying for a permit, that 

boater can still obtain an anchoring out permit, or alter his/her itinerary based on available dock 

space at a different campground. If the boater decides not to follow his/her itinerary upon arrival 

and instead goed to the full campground/dock, he/she will be obliged to anchor out or find a 

willing party from which to raft off, and may not use a shelter or campsite. A planned itinerary 

would still be required for emergency notification purposes, annual reporting, and monitoring. 

Permittees who are following an itinerary that was permitted in advance based on available 

camping/docking space (Option 1) will have precedence over parties who obtained a permit 

under Option 2.

For example, Party A obtains a permit for an itinerary showing campsite and dock space at 

Campground A one month prior to their arrival date of July 15. Party B obtains a permit for 

anchoring out on July 15 one day prior to their departure for Isle Royale on July 14, but they

arrive at Campground A at 9:00 am on July 15, and dock their boat, since space is available. 

Party A arrives at 6:00 pm on July 15, and the dock is full. Since Party A’s permit was issued in 

advance for a campsite and dock space, Party A would have priority for dock space to access the 

campground.

Permits would no longer be available on the island or through the US Forest Service Visitor 

Center in Grand Marais, MN. People would have to get their permit through the Backcountry 

Office prior to traveling to the island. Options for getting a permit would include using the 

Internet, in person at the Backcountry Office (in Houghton), by fax, or by phone to the 

Backcountry Office. The Rock Harbor and Windigo Visitor Centers would not issue permits or 

collect fees; they would be more focused on visitor information services (including important 

information about trail and campground conditions and resource issues), interpretation, and NHA 

sales and support.

Backcountry permits would be required for all parties camping, docking, or anchoring out in the 

wilderness or backcountry. This would include researchers, volunteers, educational groups, and 

park personnel, as well as general visitors. The goal would be to manage all permitting from one 

Backcountry Office with information and permits available via the internet, mail, or in person. 

This centralized system would better coordinate permitting and information dissemination as 

well as create an efficient means of distributing visitors to best utilize camping facilities while 

meeting the goals of recreation management. 

B.2.3 Desired Future Conditions for Social Opportunities and Resources.

The goal of this alternative for social conditions is to reduce campground crowding and a need to 

double up in campsites, while also preserving a range of visitation levels throughout the visitor 

season. The NPS would continue to monitor indicators to identify deteriorating wilderness and 

backcountry conditions. Where conditions did not meet standards or monitoring indicates 

deteriorating conditions, managers would take action to improve conditions. 
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Specific goals for social conditions in campgrounds under this alternative would be:

• No more than 5% of camping parties would need to share campsites at any time. This 

would be averaged park-wide on a weekly, or bi-weekly basis, and based on availability 

of campsites. 

• Current low visitation and visitor use patterns would be maintained in the spring (April 

16-June 15)

• Camping parties would more efficiently be distributed to available campsites, thereby 

minimizing the need to limit total backcountry overnight visitation. 

Trail encounters would be monitored to inform management of changes in use on specific trails, 

and the effects of altering use levels in campgrounds on trail use levels. Were increases in trail 

encounters to become a substantial concern, standards could be developed and applied in the 

future. 

If social or resource conditions were to deteriorate in the future, managers would have the option 

of adjusting visitation levels or distribution, or modifying human activities in an area as 

necessary to slow or reverse deteriorating conditions. Conversely, where goals were being 

exceeded, visitation may appropriately be allowed to increase. Other mitigative measures, such 

as relocating campsites or trails, or limiting overbooking at docks, would be additional options 

for improving conditions. 

B.2.4 Facilities and Services

To improve trip-planning services a mainland-based Backcountry Office would be established, 

with advanced permitting for visitors planning on camping, docking, or anchoring out in the 

park. This Backcountry Office would also provide trip planning information and services, 

including information on the use levels and campsite availability at specific campgrounds. 

The Backcountry Office would also be designed to improve the effectiveness and efficiency of 

NPS operations. This would be accomplished by centralizing coordination of the permitting 

system, visitor statistics management, communication between divisions involved in 

backcountry management, and better coordination of recreation management in the park.

The NPS would implement GMP-approved changes in docks, campgrounds and trails, but 

otherwise maintain existing wilderness and backcountry infrastructure. Other than this no new 

campgrounds would be added. One additional campsite would be added at North Desor, which 

currently has three campsites compared to four at Little Todd, the other campground on the west 

end of the Minong Trail. Other than this existing campground capacities would not be expanded. 

The NPS would maintain the flexibility to make adjustments as necessary for resource 

protection. Such adjustments may include trail reroutes, temporary closures of trails or 

campgrounds, relocations of campsites, or site hardening.

Existing wilderness and backcountry services would continue, including staffing ranger stations; 

conducting backcountry and wilderness patrols; maintaining trails, campgrounds and docks; 

staffing visitor centers; and offering park information via phone, Internet, publications, and 

personal contacts. 
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62 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

B.2.5 Visitor Distribution Management and Solitude

Higher visitation levels mid-season would allow for greater public access to the park’s 

wilderness and backcountry, while lower visitation in the Spring and Fall would allow for 

opportunities for greater solitude, privacy, self-sufficiency and personal challenge. Spring 

visitation would be managed to not increase over historic levels, with a goal of protecting 

wildlife and resources when they are most vulnerable to recreation impacts. Fall visitation could 

increase within the bounds of existing ferry schedules and capacities. The centralized permitting 

system and Backcountry Office would be designed to manage recreation with these goals in 

mind.

B.2.6 Appropriate Management Actions 

Certain management actions would be appropriate to meet the goals of this alternative. If impacts 

to resources or social conditions were greater than expected, managers would combine 

mitigation actions that modify and protect resources with mitigation actions that alter visitor 

behavior, visitor distribution, or numbers.

Acceptable management actions to accomplish the goals of this alternative would include:

• A mainland-based central permitting office would be established with an advanced 

permitting system to better distribute campers throughout the visitor season and between 

campgrounds before they reach the park. This would also offer better information to the 

public for trip planning. 

• The NPS would explore various options for funding the Backcountry Office. Options 

include applying for NPS special project funding and/or instituting a non-refundable 

permitting fee. 

• Permits may be issued below maximum campground capacities as necessary to achieve 

visitation goals of maintaining lower visitation in spring, and accepting not more than 5% 

of parties doubling-up in campgrounds. For example, if permitting to 100% of the park’s 

camping capacity and retaining flexible itineraries resulted in more than 5% of parties 

doubling up in campsites, then the NPS would have the option of issuing permits below 

the park’s full camping capacity. This would mean fewer permits would be issued, 

limiting access to camping in the park. 

• For deteriorating biophysical conditions in campgrounds, actions could include 

modifying site design, restoring and replanting site borders to shrink the impacted area, 

temporarily closing sites for restoration, or permanently closing and relocating sites. 

Where overcrowding contributed to deteriorating conditions, modifying use levels in a 

campground may also be appropriate for improving biophysical conditions. Campsites 

meeting the established standard may be reduced in size to meet other resource or visitor 

experience objectives. 

• For increasing impacts to natural and cultural resources the NPS would continue to 

increase visitor education about how to minimize recreation impacts on these resources. 

Where necessary and feasible, the NPS may also reroute trails or relocate campsites to 

better direct recreation away from sensitive areas. If these efforts were inadequate, 

voluntary and mandatory area closures could be implemented as protective buffers 

around sensitive resources. Closures could be temporary, for a limited portion of the 

season, or permanent, as deemed necessary to protect sensitive resources and abide by 
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legal mandates such as the Endangered Species Act and the National Historic 

Preservation Act.

• Monitoring of social and resource conditions would continue and could expand as needed 

to better understand human impacts and the effectiveness of management actions to 

curtail adverse impacts. Areas of particular importance for monitoring include 

interactions between humans and sensitive wildlife species (e.g. loons, wolves, eagles 

and osprey), changing conditions of the park’s cultural resources, and social conditions in 

campgrounds and along trails.

Alternative C for Managing Overnight Use: Accommodate Current or Increasing Use 

Levels

C.1 General Description

The National Park Service would maintain fairly high access to Isle Royale’s wilderness and 

backcountry, striving to accommodate current and increasing public interest in backcountry and 

wilderness trips. Establishing a mainland-based Backcountry Office with advanced permitting 

would improve information and services available to visitors for trip planning and improve 

visitor distribution to maintain quality opportunities and reduce adverse impacts from recreation. 

Visitation could further be accommodated and crowding reduced through the creation of a 

shuttle service in the Rock Harbor Channel, minor expansions of a few campgrounds, and the 

option to create a limited number of new campgrounds. Options to add new shelters adjacent to 

the Windigo dock would be explored. 

C.2 Management Goals and Actions

The goal of this alternative is to maintain flexibility for visitors’ travel plans, decrease the 

frequency of campsite sharing in overfull campgrounds to a more moderate level, and better 

accommodate current and increasing visitation through additional development of campgrounds. 

This alternative would allow for a slight increase in resource impacts associated with 

campground development, but significant irreversible or irretrievable impacts to resources would 

not be acceptable.

C.2.1 Visitor Use Levels

This alternative allows a higher tolerance for campsite sharing during peak season, and a lower 

tolerance off-peak, to provide a range of opportunities for both access and solitude. The number 

of permits issued per campground would be managed to not exceed campground capacities and 

meet goals for social and resource conditions as well as maximizing access to the wilderness and 

backcountry. The availability of permits may eventually limit access to the wilderness and 

backcountry for specific campgrounds or on specific dates. Visitor use levels would be 

controlled to the extent necessary to meet goals for social conditions in campgrounds; 

• Spring (April 16-June 15): no more than 5% of parties would have to double up in 

campsites in full campgrounds. Spring visitation could increase over current levels.

• Summer (June 16- Sept 15): no more than 10% of parties would have to share campsites 

during the peak two weeks in visitation (between mid-July and mid-August), and no more 

than 5% of parties would need to share sites the rest of the time. This would require a 

reduction in campground crowding during the peak two weeks of the visitor season. 
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64 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

• Fall (September 16-October 31): no more than 5% of parties would have to double up in 

campsites in full campgrounds. Fall visitation could increase over current levels.

Campsite occupancy rates and/or frequency of parties doubling-up in campsites would be 

monitored and averaged on a weekly, or bi-weekly basis, with monitoring to include field 

surveys, analysis of backcountry permit data, and computer modeling. 

C.2.2 Backcountry Permits

Camping permits would be managed to increase the efficient use of campsites throughout the 

park with moderate to high public access while also decreasing over-crowding in campgrounds. 

A central permitting station would be established, as outlined in Alternative B, section B.2.2., 

with all permits being issued in advance, before visitors reach the park. Permits would be issued 

up to, but not exceeding the capacity of a campground. This would not be a site reservation 

system for small parties of 1-6; these parties would be free to alter their itineraries mid-trip. 

However, the NPS would no longer permit campgrounds over their capacities. Some visitors 

may have to modify their travel plans to find available camping permits. 

For groups of 7-10 people permits would remain as site reservations with fixed itineraries. Group 

sites would continue to be reserved to full capacity, and groups would be limited to nightly 

reservation availability. Throughout much of the season these large groups would have no 

flexibility for changing their itineraries once they reach the park. 

Boating parties would be required to obtain advance permits for docking, anchoring out, and to 

use campsites or shelters, as in Alternative B. Last-minute permits (within 48 hours of the trip) 

for docking at full campgrounds would not be available under this alternative, but rafting off 

would not be restricted among willing boaters with valid backcountry permits.

Backcountry permits would be required for all parties camping, docking, or anchoring out in the 

wilderness or backcountry, regardless of the purpose of the trip. This would include researchers, 

volunteers, educational groups, and park personnel, as well as general visitors. The goal would 

be to manage all permitting from one Backcountry Office with information and permits available 

via the Internet, mail, or in person. Permits would no longer be issued on the island, aboard the 

Ranger III, or in Grand Marais. This centralized system would better coordinate permitting and 

information dissemination as well as create an efficient means of distributing visitors to best 

utilize camping facilities while meeting the goals of recreation management. 

C.2.3 Desired Future Conditions for Social Opportunities and Resources 

The NPS would continue to monitor indicators to identify deteriorating wilderness and 

backcountry conditions. Where conditions do not meet standards or monitoring indicates 

deteriorating conditions, managers would take action to improve conditions. 
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Specific goals for social conditions in campgrounds under this alternative would be:

• No more than 5% of camping parties would need to share campsites at any time outside 

of the two-week peak in visitation. This would be averaged park-wide on a weekly, or biweekly basis, and based on availability of campsites. 

• No more than 10% of camping parties would need to share campsites during the twoweek peak in visitation. 

• Camping parties would more efficiently be distributed to available campsites, thereby 

minimizing the need to limit total backcountry overnight visitation. 

• Trip planning and visitor information services would be improved

Trail encounters would be monitored to inform management of changes in use on specific trails, 

and the effects of altering use levels in campgrounds on trail use levels. Were increases in trail

encounters to become a substantial concern, standards could be developed and applied in the 

future. 

A minor level of impacts to wildlife, vegetation, and shoreline habitats would be tolerated as 

necessary to expand existing campgrounds and create up to three new campgrounds in the park, 

beyond those proposed in the GMP. Protecting rare species and their habitats would be a priority 

in identifying suitable sites for these expansions. Wildlife and rare plant populations would 

continue to be monitored to indicate changing conditions and inform relevant management 

decisions. 

If social or resource conditions were to deteriorate in the future, managers would have the option 

of adjusting visitation levels or distribution, or modifying human activities in an area as 

necessary to slow or reverse deteriorating conditions. Conversely, where goals are being 

exceeded, visitation may appropriately be allowed to increase. Other mitigation measures, such 

as relocating campsites or trails would be additional options for improving conditions. 

C.2.4 Facilities and Services

A mainland-based Backcountry Office would be established to provide advanced permitting for 

visitors planning on camping, docking, or anchoring out in the park. This Backcountry Office 

would also provide trip planning information and services, including information on the use 

levels and campsite availability at specific campgrounds. 

The Backcountry Office would also be designed to improve the effectiveness and efficiency of 

NPS operations. This would be accomplished by centralizing coordination of the permitting 

system, visitor statistics management, communication between divisions involved in 

backcountry management, and better coordination of recreation management in the park.

A new shuttle service would be created to further improve visitor distribution. This shuttle could 

run between Rock Harbor, Mott Island, and Daisy Farm, with a schedule coordinated with ferry 

arrivals and departures. This would aid in alleviating congestion along the Rock Harbor Channel, 

which is exacerbated by hikers and paddlers being funneled through the limited trails and 

campgrounds as they arrive and depart from Rock Harbor. This service could be operated by any 

one of the following: through concessions via a contract amendment, the NPS, or under a CUA.
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66 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

Isle Royale managers would explore options to add a few new shelters adjacent to the Windigo 

Dock to better accommodate boating parties docked there for the night. 

If better management of visitor distribution failed to adequately reduce the frequency of parties 

needing to share campsites, additional campsites could be added to the most heavily over-used 

campgrounds. New sites would be located where resources and physical conditions allow for 

quality campsites, with consideration for resource impacts as well as aesthetics of the site. New 

sites may be designated as communal “overflow” tenting areas to minimize the number of site 

additions needed. 

Where site additions are not feasible to accommodate use levels a limited number of new small 

campgrounds may be created. Suitable options for these new campgrounds would consider the 

best location within higher use areas and the limitations of sensitive resources in the park. 

Preliminary scouting for feasible sites identified three possibilities: paddler campgrounds on 

Chickenbone Lake and on the northeast end of West Caribou Island, and hiker sites on the 

southeast end of Tobin Harbor (Appendix D, Map 4). 

Existing wilderness and backcountry services would continue, including staffing ranger stations; 

conducting backcountry and wilderness patrols; maintaining trails, campgrounds and docks; 

staffing visitor centers; and offering park information via phone, Internet, publications, and 

personal contacts. 

C.2.5 Visitor Distribution Management and Solitude

The creation of a centralized permitting system would improve visitor distribution throughout the 

season and across the park to better maintain use levels within campground capacities. This 

improved distribution would minimize the crowding associated with parties needing to share 

campsites, and increase the opportunities for solitude, privacy and tranquility in campgrounds. 

The centralized permitting system and Backcountry Office would be designed to manage 

recreation with these goals in mind. Adding new campsites within existing campgrounds would 

be intended to further improve opportunities for solitude and privacy while camping. A shuttle 

service in the Rock Harbor Channel would be intended to further improve visitor distribution, 

making the interior of the park more accessible to visitors and easing the bottleneck of campers 

traveling to and from Rock Harbor as they arrive and depart on ferries. 

C.2.6 Appropriate Management Actions

Certain management actions would be appropriate to meet the goals of this alternative. If impacts 

to resources or social conditions were greater than expected, managers would combine 

mitigation actions that modify and protect resources with mitigation actions that alter visitor 

behavior, visitor distribution, or numbers.

Acceptable management actions would include:

• A mainland-based central permitting office would be established with a system of 

advanced permitting to better distribute campers throughout the season and between 
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CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 67

campgrounds before they reach the park. This would also offer better information to the 

public for trip planning. 

• The NPS would explore various options for funding the Backcountry Office. Options 

include applying for NPS special project funding and/or instituting a non-refundable 

permitting fee. 

• Permits may be issued below maximum campground capacities as necessary to achieve 

goals of no more than 10% of parties sharing during the peak, and no more than 5% the 

rest of the season. For example, if permitting to 100% of the park’s camping capacity and 

retaining flexible itineraries resulted in more than 5% of parties doubling up in campsites, 

then the NPS would have the option of issuing permits below the park’s full camping 

capacity (i.e., fewer visitor permits would be issued.)

• A shuttle service could be introduced for travel between Rock Harbor, Mott Island, and 

Daisy Farm.

• 2-3 new shelters could be added adjacent to the Windigo dock

• For deteriorating social conditions such as campground crowding, management actions 

could include adding additional communal or individual campsites or adjusting the 

number of permits issued per campground.

• For deteriorating biophysical conditions in campgrounds, actions could include 

modifying site design, restoring and replanting site borders to shrink the impacted area, 

temporarily closing sites for restoration, or permanently closing and relocating sites. 

Where overcrowding contributed to deteriorating conditions, modifying use levels in a 

campground may also be appropriate for improving biophysical conditions. Campsites 

meeting the established standard may be reduced in size to meet other resource or visitor 

experience objectives. 

• For increasing impacts to natural and cultural resources the NPS would continue to 

increase visitor education about how to minimize recreation impacts to these resources. 

Where necessary and feasible, the NPS may also reroute trails or relocate campsites to 

better direct recreation away from sensitive areas. If these efforts were inadequate, 

voluntary and mandatory area closures could be implemented as protective buffers 

around sensitive resources. Closures could be temporary, for a limited portion of the 

season, or permanent, as deemed necessary to protect sensitive resources and abide by

legal mandates such as the Endangered Species Act and the National Historic 

Preservation Act.

• Monitoring of social and resource conditions would continue and could expand as needed 

to better understand human impacts and the effectiveness of management actions to 

curtail adverse impacts. Areas of particular importance for monitoring include 

interactions between humans and sensitive wildlife species (e.g. loons, wolves, eagles 

and osprey), changing conditions of the park’s cultural resources, and social conditions in 

campgrounds and along trails.
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Alternative D for Managing Overnight Use: Entry Quotas

D.1 General Description

The NPS would establish entry point quotas consistent with the park’s carrying capacity, with a 

goal of decreasing the frequency of campsite sharing in July and August while accepting an 

increase in visitation during the rest of the season. Access to the park may be limited or reduced 

during the peak visitor season, but freedom of flexible travel within the park with low frequency 

of over-crowding in campgrounds would be a priority. Campsite or shelter reservations would be 

available at a few campgrounds for people desiring an assurance that they will be able to find 

camping space at their preferred campground. 

D.2 Management Goals and Actions

The goal of this alternative is to provide quality camping experiences in Isle Royale’s wilderness 

and backcountry by reducing campground crowding, minimizing recreation impacts to resources, 

and simplifying permitting and trip planning requirements. 

D.2.1 Visitor Use Levels 

This alternative would aim to reduce crowding in campgrounds during July and August. 

Visitation would be managed through entry quotas established for the number of camping parties 

traveling to the park on ferries. These entry quotas could limit access to the wilderness and 

backcountry on the busiest dates and entry points. Quotas would be established based on 

achieving goals for social conditions in campgrounds:

• Spring (April 16-June 15): no more than 5% of parties would have to double up in 

campsites in full campgrounds. Spring visitation could increase over current levels.

• Summer (June 16- Sept 15): no more than 5% of parties would have to share campsites in 

full campgrounds. This would require a reduction in campground crowding compared to 

current conditions. 

• Fall (September 16-October 31): no more than 5% of parties would have to double up in 

campsites in full campgrounds. Fall visitation could increase over current levels.

Campsite occupancy rates and/or frequency of parties doubling-up in campsites would be 

monitored and averaged on a weekly, or bi-weekly basis, with monitoring to include field 

surveys, analysis of backcountry permit data, and computer modeling. 

D.2.2 Backcountry Permits

Visitor distribution around the park and through the season would be improved using the park’s 

existing visitor service capabilities. Camping permits would continue to be issued to all visitors 

who reach the park at the start of their trip. However, entry point quotas would be established to 

better meet the park’s campground capacities. The quotas would set average daily limits to the 

number of camping parties entering the park, which would be managed through the ferries. Use 

levels for powerboaters and sailors would be monitored to determine a future need for entry 

quotas for these groups. With low current use levels for these visitors, boaters and sailors would 

not initially be included in the quota system. Although there may be a limit or reduction in the 
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number of camping parties traveling on the ferries during part of the season, there would be no 

quota for day visitors or lodge guests. 

The group reservation system would remain for groups of 7-10 people. These permits would be 

site reservations with fixed itineraries. Group sites would continue to be reserved to full capacity, 

and groups would be limited to nightly reservation availability. Throughout much of the season 

these large groups would have no flexibility for changing their itineraries once they reach the 

park.

Backcountry permits would continue to be required for all parties camping, docking, or 

anchoring out in the wilderness or backcountry. These would be issued from several visitor 

centers in the park and on the mainland, and all parties would be required to register for a permit 

either prior to or upon reaching the park. All visitors who reach the park would receive a 

camping permit and there would be no limit to the number of permits issued per campground. 

As in Alternatives A-C, rafting off at full docks by willing boaters with valid backcountry 

permits would not be restricted. However, efforts to improve communication between the 

permitting stations would offer better information about daily use levels at each campground, 

aiding visitors in planning their itineraries. 

Campsite reservations (and dock space associated with reserved campsite) would be available on 

a limited basis for part of the visitor season. The intention would be to offer the option of 

reservations for people seeking assurances that a campsite (and dock space, where applicable)

will be available. Smaller campgrounds would be most appropriate for this option, such as 

Tookers Island, Merritt Lane, Grace Island, Little Todd, and North Desor. Cultural sites may also 

be appropriate, such as the new GMP-approved campgrounds at Fishermans Home and Crystal 

Cove.

D.2.3 Desired Future Conditions for Social Opportunities and Resources

The NPS would continue to monitor indicators to identify deteriorating wilderness and 

backcountry conditions. Where conditions do not meet standards or monitoring indicates 

deteriorating conditions, managers would take action to improve conditions.

Specific goals for social conditions in campgrounds under this alternative would be:

• No more than 5% of camping parties would need to share campsites at any time. This 

would be averaged park-wide on a weekly, or bi-weekly basis, and based on availability 

of campsites. 

• The current system of permitting upon arrival to the park would continue, so visitors 

would not be required to adapt to a new permitting system. 

Trail encounters would be monitored to inform management of changes in use on specific trails, 

and the effects of altering use levels in campgrounds on trail use levels. Were increases in trail 

encounters to become a substantial concern, standards could be developed and applied in the 

future. 
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70 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

D.2.4 Facilities and Services

One additional tent site would be added at North Desor campground, increasing its capacity to 4 

parties for consistency with Little Todd campground.

Existing wilderness and backcountry services would continue, including staffing ranger stations; 

conducting backcountry and wilderness patrols; maintaining trails, campgrounds and docks; 

staffing visitor centers; and offering park information via phone, Internet, publications, and 

personal contacts.

D.2.5 Visitor Distribution Management and Solitude

The establishment of entry quotas would improve visitor distribution and social conditions 

throughout the season and across the park. This would minimize the crowding associated with 

parties needing to share campsites, and increase the opportunities for solitude, privacy and 

tranquility in campgrounds. Reducing overcrowding in campgrounds would also reduce trail 

encounters during the high use portion of the visitor season, similarly improving social 

conditions while traveling in the wilderness and backcountry.

D.2.6 Appropriate Management Actions

Certain management actions would be appropriate to meet the goals of this alternative. If impacts 

to resources or social conditions were greater than expected, managers would combine 

mitigation actions that modify and protect resources with mitigation actions that alter visitor 

behavior, visitor distribution, or numbers.

Acceptable management actions would include:

• A limit on the average number of permits issued to camping parties each day consistent 

with camping capacities in the vicinity of each entry point (i.e. an entry quota).

• Campsite and/or dock reservations could be instituted for a limited number of 

campgrounds for people desiring an assurance of an available campsite/dock space. 

Smaller campgrounds such as Grace Island, Tookers Island, Merritt Lane, North Desor 

and Little Todd would be appropriate choices. 

• For deteriorating social conditions such as trail or campground crowding, management 

actions could include establishing and modifying entry point quotas for camping parties 

on ferries and the seaplane, and as a future need arose establishing quotas for boaters and 

sailors who would not be included in ferry-based quotas. Entry quotas would likely result 

in fewer permits being issued to the busiest entry points during peak periods.

• For deteriorating biophysical conditions in campgrounds, actions could include 

modifying site design, restoring and replanting site borders to shrink the impacted area, 

temporarily closing sites for restoration, or permanently closing and relocating sites. 

Where overcrowding contributed to deteriorating conditions, modifying use levels in a 

campground may also be appropriate for improving biophysical conditions. Campsites 

meeting the established standard may be reduced in size to meet other resource or visitor 

experience objectives. 

• For increasing impacts to natural and cultural resources the NPS would continue to 

increase visitor education about how to minimize recreation impacts on these resources. 

Where necessary and feasible, the NPS may also reroute trails or relocate campsites to 

better direct recreation away from sensitive areas. If these efforts were inadequate, 
Alternatives for Managing Overnight Use

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 71

voluntary and mandatory area closures could be implemented as protective buffers 

around sensitive resources. Closures could be temporary, for a limited portion of the 

season, or permanent, as deemed necessary to protect sensitive resources and abide by 

legal mandates such as the Endangered Species Act and the National Historic 

Preservation Act.

• Monitoring of social and resource conditions would continue and could expand as needed 

to better understand human impacts and the effectiveness of management actions to 

curtail adverse impacts. Areas of particular importance for monitoring include 

interactions between humans and sensitive wildlife species (e.g. loons, wolves, eagles 

and osprey), changing conditions of the park’s cultural resources, and social conditions in 

campgrounds and along trails.

Alternative E for Managing Overnight Use: Maximize Resource Protection 

E.1 General Description

Resource protection would be the ultimate priority in managing use levels and distribution 

throughout the visitor season and in planning and maintaining recreation and administrative 

facilities. The NPS would improve social conditions and opportunities for solitude in July and 

August by minimizing trail encounters and the need to share campsites, while also maintaining 

the freedoms associated with flexible itinerary permits. The creation of a central permitting 

system would improve the information available to the public about use levels in specific 

campgrounds on specific dates, aiding in trip planning and better distributing visitors to 

minimize overcrowding. Issuing permits below campground capacities would aid in maximizing 

opportunities for solitude throughout the park. 

E.2 Management Goals and Actions

The goal of this alternative is to prioritize resource protection and greater opportunities for 

solitude, by reducing crowding and managing visitation levels to be consistent with the park’s 

campsite capacities, and maintaining a wide range of visitation levels throughout the visitor 

season.

E.2.1 Visitor Use Levels 

Historic patterns of low visitation times in the spring and fall would be maintained to protect 

natural resources during vulnerable times and maintain opportunities for the highest quality 

wilderness experiences on Isle Royale. The number of permits issued per campground would be 

managed to not exceed campground capacities and meet goals for social and resource conditions; 

in the spring and fall permits would be issued well below campground capacities. The 

availability of permits would likely limit access to the wilderness and backcountry for specific 

campgrounds on specific dates. Visitor use levels would be controlled to the extent necessary to 

meet goals for social conditions in campgrounds; 

• Spring (April 16-June 15): no more than 1% of parties would have to double up in 

campsites in full campgrounds. Additionally, historic use levels would be maintained by 

issuing permits up to, but not exceeding, 20% of the park’s camping capacity (see Table 

18.) Spring visitation would not increase over current levels.
Alternatives for Managing Overnight Use

72 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

• Summer (June 16- Sept 15): no more than 5% of parties would have to share campsites in 

overfull campgrounds during the two week peak in visitation (between mid-July and midAugust), and no more than 1% of parties would share campsites the rest of the season. 

This would require a reduction in campground crowding from July through August. 

• Fall (September 16-October 31): no more than 1% of parties would have to double up in 

campsites in full campgrounds. Additionally, historic use levels in the fall would be

maintained by issuing permits up to, but not exceeding, 10 % of the park’s camping 

capacity (see Table 18.) Fall visitation would not increase over current levels.

Campsite occupancy rates and/or frequency of parties doubling-up in campsites would be 

monitored and averaged on a weekly, or bi-weekly basis, with monitoring to include field 

surveys, analysis of backcountry permit data, and computer modeling. 

E.2.2 Backcountry Permits

Backcountry permits would be required to be obtained prior to arriving at the park, for camping, 

docking, and anchoring out. Camping permits would be managed to minimize over-crowding in 

campgrounds, thereby maximizing opportunities for solitude and minimizing detrimental 

recreation impacts in and around campgrounds. A central permitting station would be established 

with up-to-date information about use levels at each campground, as outlined in greater detail in 

Alternative B, Section B.2.6. All permits would be issued in advance, before visitors reached the 

park. As with Alternatives B and C, boaters would be required to log a planned itinerary for 

emergency and annual park reporting purposes, but they could alter their itinerary, and rafting off 

at full docks would not be restricted among willing boaters with valid backcountry permits. 

Permits may be issued below a campground’s capacity as necessary to meet goals for minimizing 

campsite sharing. As this would not be a site reservation system parties would be free to alter 

their camping itineraries mid-trip. Some visitors may have to alter their travel plans to find dates 

with available camping permits. 

The group reservation system would remain for groups of 7-10 people. These permits would be 

site reservations with fixed itineraries. To allow for some level of flexibility for groups once they 

reach the park, group sites would be reserved below full capacity. Some large groups may have 

to alter their travel plans to find available reservations.

The goal would be to manage all permitting from one Backcountry Office with information and 

permits available via the Internet, mail, or in person. This centralized system would better 

coordinate permitting and information dissemination as well as create an efficient means of 

distributing visitors to best utilize camping facilities while meeting the goals of recreation 

management. Backcountry permits would be required for all parties camping, docking, or 

anchoring out in the wilderness or backcountry. 

E.2.3 Desired Future Conditions for Social Opportunities and Resources 

The NPS would continue to monitor indicators to identify changing wilderness and backcountry 

conditions. Where conditions do not meet standards or monitoring indicates deteriorating 

conditions, managers would take action to improve conditions. 

Specific goals for social conditions in campgrounds under this alternative would be:
Alternatives for Managing Overnight Use

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 73

• No more than 5% of camping parties would need to share campsites during the two-week 

peak in visitation. This would be averaged park-wide on a weekly, or bi-weekly basis, 

and based on availability of campsites, and require a reduction from the current levels of 

sharing in July and August. 

• No more than 1% of camping parties would need to share campsites all season outside of 

the two-week peak in visitation. 

• Spring and fall would remain as low use times with greater opportunities for solitude, 

risk, and challenge than during the summer months.

• Camping parties would more efficiently be distributed to available campsites, thereby 

minimizing the extent that total wilderness and backcountry overnight visitation would be 

reduced. 

• Trip planning and visitor information services would be improved.

Trail encounters would be monitored to inform management of changes in use on specific trails, 

and the effects of altering use levels in campgrounds on trail use levels. If increases in trail 

encounters became a substantial concern, standards could be developed and applied in the future. 

E.2.4 Facilities and Services

A mainland-based Backcountry Office would be established to provide advanced permitting for 

visitors planning on camping, docking, or anchoring out in the park. This Backcountry Office 

would also provide trip planning information and services, including information on the use 

levels and campsite availability at specific campgrounds. 

The Backcountry Office would also be designed to improve the effectiveness and efficiency of 

NPS operations. This would be accomplished by centralizing coordination of the permitting 

system, visitor statistics management, communication between divisions involved in 

backcountry management, and better coordination of recreation management in the park.

To minimize the impacts of development in the wilderness and backcountry no new campsites 

would be constructed except if designated sites were lost to natural processes or existing 

designated campsites needed to be relocated. Such replacement campsites would only be 

approved for designation if they were necessary for protection of resources or the visitors' 

wilderness experience. There would be no net gain in the number of designated campsites, 

maintaining a total of not more than 244 sites plus those added with the GMP-approved new 

campgrounds.

One campsite would be removed from Little Todd campground, reducing its capacity to 3 for 

consistency with North Desor campground along the primitive portion of the Minong Trail. 

 

Existing wilderness and backcountry services would continue, including staffing ranger stations; 

conducting backcountry and wilderness patrols; maintaining trails, campgrounds and docks; 

staffing visitor centers; and offering park information via phone, Internet, publications, and 

personal contacts. 
Alternatives for Managing Overnight Use

74 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

E.2.5 Visitor Distribution Management and Solitude

Visitor distribution and associated wilderness conditions would be improved throughout the 

season and across the park. This would be accomplished through the creation of a centralized 

permitting system combined with issuing permits below the full capacity of campgrounds. This 

would allow for continued flexibility in camping itineraries while also minimizing the crowding 

associated with parties needing to share campsites, and increasing the opportunities for solitude, 

privacy and tranquility in campgrounds. Reducing overcrowding in campgrounds could also 

reduce trail encounters during the high use portion of the visitor season, similarly improving 

social conditions while traveling in the wilderness and backcountry. The centralized permitting 

system and Backcountry Office would be designed to manage recreation with these goals in 

mind.

E.2.6 Appropriate Management Actions 

Certain management actions would be appropriate to meet the goals of this alternative. If impacts 

to resources or social conditions were greater than expected, managers would combine 

management actions that modify and protect resources with mitigation actions that alter visitor 

behavior, visitor distribution, or numbers.

Acceptable management actions would include:

• A mainland-based central permitting office would be established with a system of 

advanced permitting to better distribute campers throughout the season and between 

campgrounds before they reach the park. This would also offer better information to the 

public for trip planning. 

• The NPS would explore various options for funding the Backcountry Office. Options 

include applying for NPS special project funding and/or instituting a non-refundable 

permitting fee. 

• Permits may be issued below maximum campground capacities as necessary to achieve 

visitation goals of maintaining lower visitation in spring and fall, and accepting not more 

than 5% of parties doubling-up in campgrounds in July and August. For example, if 

permitting to 100% of the park’s camping capacity and retaining flexible itineraries 

resulted in more than 5% of parties doubling up in campsites, then the NPS would have 

the option of issuing permits below the park’s full camping capacity. 

• For deteriorating social conditions such as trail or campground crowding, management 

actions would include modifying distribution of visitors around the park and throughout 

the season. Additionally, the number of permits issued per campground may be modified, 

as well as the number of campsites in specific campgrounds while maintaining no net 

increase in the number of campsites park-wide. 

• For deteriorating biophysical conditions in campgrounds, actions could include 

modifying site design, restoring and replanting site borders to shrink the impacted area, 

temporarily closing sites for restoration, permanently closing and relocating sites. Where 

overcrowding contributed to deteriorating conditions, modifying use levels in a 

campground may also be appropriate for improving biophysical conditions. Campsites 

meeting the established standard may be reduced in size to meet other resource or visitor

experience objectives. 

• For increasing impacts to natural and cultural resources the NPS would continue to 

increase visitor education about how to minimize recreation impacts on these resources. 
Alternatives for Managing Overnight Use

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 75

Where necessary and feasible, the NPS may also reroute trails or relocate campsites to 

better direct recreation away from sensitive areas. If these efforts were inadequate, 

voluntary and mandatory area closures could be implemented as protective buffers 

around sensitive resources. Closures could be temporary, for a limited portion of the 

season, or permanent, as deemed necessary to protect sensitive resources and abide by 

legal mandates such as the Endangered Species Act and the National Historic 

Preservation Act.

• Monitoring of social and resource conditions would continue and could expand as needed 

to better understand human impacts and the effectiveness of management actions to 

curtail adverse impacts. Areas of particular importance for monitoring include 

interactions between humans and sensitive wildlife species (e.g. loons, wolves, eagles 

and osprey), changing conditions of the park’s cultural resources, and social conditions in 

campgrounds and along trails.

Alternative Considered but Rejected: Establish a Night-by-Night Reservation System for 

All Wilderness and Backcountry Visitors

Establishing a night-by-night camping reservation system with fixed itineraries for backcountry 

permits could virtually eliminate campground overcrowding and the need for parties to double 

up in campsites while also accommodating current or increased visitation to the park. However, 

this would come at the cost of flexibility and spontaneity for visitors once they reach the park. 

Backcountry visitors in parties smaller than 7 people would no longer have the opportunity to 

modify their travel plans based on weather, preference for campgrounds, or any other reason 

once they have begun their backcountry trip. This system would also come with an increased 

cost of enforcement to ensure that overcrowding was effectively eliminated.

Night-by-night reservations for all parties could be feasible, with a switch to issuing permits and 

campground reservations in advance of visitors reaching the park. However, visitor surveys and 

other public input indicate that the costs to visitors would outweigh the benefits, and this 

alternative would not be adequately acceptable to the public. The results of visitor surveys in 

2002 suggest that prescribed, fixed itineraries are particularly unfavorable to Isle Royale visitors, 

despite the fact that such a system would be designed to eliminate campsite sharing (Lawson and 

Manning 2003). Additionally, public responses to newsletters indicated a strong opposition to 

night-by-night reservations, with greater support for alternative management actions. 

Considering the lack of public support and the requirements for enforcing a night-by-night 

camping reservation system for all backcountry visitors, the costs of this alternative were 

determined to outweigh the benefits and it was eliminated from further analysis. 
Alternatives for Managing Overnight Use

76 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

Table 4: Comparison of Alternatives for Overnight Use in the Wilderness and Backcountry

Alternative A:

No Action

Alternative B 

(Preferred) Alternative C Alternative D Alternative E

Desired 

Future 

Conditions

The NPS would maintain 

the current management 

direction, including 

continuing implementation 

of the GMP.

Provide a range of quality 

opportunities for wilderness 

and backcountry 

experiences while also 

minimizing limits on public 

access to the park, reducing 

adverse impacts to natural 

and cultural resources, 

minimizing concerns for 

human safety, and 

improving trip planning 

services.

Maintain flexibility for 

visitors’ travel plans, 

decrease the frequency of 

campsite sharing in overfull 

campgrounds, better 

accommodate current and 

increasing visitation, and 

allow for minimal 

acceptance of increased 

resource impacts associated 

with additional campsites.

Provide quality camping 

experiences by reducing 

campsite sharing during the 

peak season, minimizing 

resource impacts, and 

simplifying permitting and 

trip planning requirements. 

Manage backcountry 

visitation with an entry 

quota system.

Prioritize resource 

protection and greater 

opportunities for solitude by 

reducing campground 

crowding, managing 

visitation levels to be 

consistent with campground 

capacities, and maintaining 

a range of visitation levels 

from low to moderate 

throughout the visitor 

season. 

Management 

Actions:

Permitting 

(note: in all 

cases the 

group 

reservation 

system would 

apply to 

parties with 

7-10 people. 

Changes 

apply only to 

small parties.) 

• Existing permitting 

services would continue, 

with multiple permitting 

stations, and permits 

issued upon arrival at the 

park. 

• Permits would not be 

limited by campsite 

availability

• Create a mainlandbased central permitting 

system

• Issue flexible-itinerary 

permits to parties before 

they reach the island. 

• Issue permits at or 

below campground 

capacities as necessary to 

minimize campground 

crowding

• Create a mainlandbased central permitting 

system

• Issue flexible-itinerary 

permits to visitors before 

they reach the island. 

• Issue permits up to, but 

not exceeding 

campground capacities. 

• Maintain current islandbased permitting system

• No limit on number of 

permits issued to each 

campground

• Offer site reservations 

at a limited number of 

campgrounds during part 

of the visitor season 

• Create a mainlandbased central permitting 

system

• Issue flexible-itinerary 

permits to visitors before 

they reach the island.

• Issue permits below 

campground capacities to 

maximize opportunities 

for solitude and privacy.

Visitor Use 

Levels

The NPS would not actively 

manage visitor use levels, 

other than maintaining 

existing ferry capacities and 

schedules. Visitation could 

increase throughout the 

visitor season. 

Backcountry overnight 

visitation may be limited on 

some dates in some 

campgrounds by 

campground capacities, 

especially in July and 

August. Visitation in Fall 

could increase significantly. 

Visitors may not be able to 

get a permit for their 

preferred itinerary on their 

preferred dates.

Backcountry overnight 

visitation may be limited on 

some dates in some 

campgrounds by 

campground capacities. 

Visitation in the Spring and 

Fall could increase 

significantly.

Visitors may not be able to 

get a permit for their 

preferred itinerary on their 

preferred dates. 

Entry quotas may limit 

backcountry camping in July 

and August. Average daily 

quotas would be based on 

campground capacities. 

Visitation in Spring and Fall 

could increase significantly. 

Unless boaters increased 

significantly, quotas would 

apply only to campers 

traveling to the park by 

ferry, not by private boat. 

During parts of July and 

August limited permits may 

reduce visitation to the 

park’s backcountry. 

Visitation in Spring and Fall 

would be maintained at low 

levels.

Visitors may not be able to 

get a permit for their 

preferred itinerary on their 

preferred dates. 
Alternatives for Managing Overnight Use

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 77

Alternative A: 

No Action

Alternative B 

(Preferred) Alternative C Alternative D Alternative E

Management 

Actions:

Social 

Indicators 

and 

Standards

• The NPS would continue 

to monitor social 

conditions, focusing on 

visitor education and 

facility design to address 

deteriorating conditions.

• Visitation numbers 

would not be actively 

managed other than 

maintaining current ferry 

and seaplane capacities 

and schedules. 

• No more than 5% of 

parties sharing campsites 

6/16-9/15.

• No increase in visitation 

in the spring (5/1-6/15).

• Allow increase in 

visitation in fall (9/16-

10/31), within current 

ferry schedule.

• No more than 10% of 

parties sharing campsites 

in overfull campgrounds 

during the 2-week peak 

in visitation, 

• No more than 5% of 

parties sharing campsites 

the rest of the season. 

• Allow increase in 

spring & fall

• No more than 5% of 

parties sharing campsites 

at any point in the 

season. 

• Allow increase in 

visitation in spring and 

fall 

• No more than 5% of 

parties sharing campsites 

during the 2-week peek in 

visitation, 

• No more than 1% of 

parties sharing campsites 

the rest of the season. 

• Maintain low use in 

spring and fall. 

Facilities and 

Services

• Existing visitor centers, 

permitting stations, 

campgrounds and trails

would be maintained as 

the status quo.

• Implementation of the 

GMP would continue, 

with addition of the 

GMP-approved new 

campgrounds.

• Create a mainland-based 

Backcountry Office to 

coordinate advanced 

permitting and trip 

planning information

• Add one additional 

campsite at North Desor 

campground, expanding 

its capacity to 4.

• Create a mainland-based 

Backcountry Office to 

coordinate advanced 

permitting and trip 

planning information 

• Allow for the addition of 

new campsites or 

campgrounds as needed 

to accommodate

backcountry visitation.

• Add 2-3 new shelters in 

the vicinity of the 

Windigo Dock. 

• Institute a new shuttle 

service within the Rock 

Harbor Channel.

• Add one additional 

campsite at North Desor 

campground.

• Offer a limited number of 

campgrounds with 

campsite or shelter 

reservations.

• Create a mainland-based 

Backcountry Office to 

coordinate advanced 

permitting and trip 

planning information 

• Remove one tent site 

from Little Todd 

campground, reducing its 

capacity to 3.

Visitor 

Distribution

The NPS would not actively 

manage visitor distribution 

between campgrounds. 

Permitting stations would 

not have information about 

campsite availability or be 

able to distribute campers 

away from overcrowded 

campgrounds.

Issuing permits in advance 

of visitors reaching the park, 

and not permitting over a 

campground’s capacity 

would improve visitor 

distribution and minimize 

seasonal crowding and 

overcrowding in 

campgrounds.

Issuing permits in advance 

of visitors reaching the park, 

and not permitting over a 

campground’s capacity 

would improve visitor 

distribution and minimize 

seasonal crowding and 

overcrowding in 

campgrounds.

Camping quotas established 

for each of the park’s entry 

points would improve visitor 

distribution, thereby 

minimizing campground 

crowding.

Issuing permits in advance 

of visitors reaching the park 

, and not permitting over a 

campground’s capacity 

would improve visitor 

distribution and minimize 

seasonal crowding and 

overcrowding in 

campgrounds.
Alternatives for Managing Overnight Use

78 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

Alternative A: 

No Action

Alternative B 

(Preferred) Alternative C Alternative D Alternative E

Projected 

Visitation 

Implications

• There would be no 

limits on future increases 

in visitation other than 

the availability of ferry 

tickets.

• Ferry schedules would 

keep spring and fall as 

lower use times, but 

visitation could increase 

all season. 

• Up to 100% camping 

capacity, limited based 

on space availability and 

route feasibility at time 

of permitting.

• Expected to 

accommodate minor 

increases in visitation in 

summer and moderate 

increases in fall. 

Visitation could decrease 

during peak times.

• Maintain backcountry 

visitation in spring at 

approximately 20% 

camping capacity.

• Up to 100% campsite 

capacity.

• Current and moderate 

increased visitation could 

be accommodated in 

summer.

• Moderate to major 

increases in visitation 

could be accommodated 

in spring and fall.

• Estimated that issuing 37 

camping permits per day 

would reduce sharing to 

not more than 5%.

• The above could reduce 

camping visitation by 

about 5% in July and 

August, but allow for a 

substantial increase the 

rest of the season.

• Up to 100% camping 

capacity, limited based 

on space availability and 

route feasibility at time 

of permitting.

• Maintain backcountry 

visitation at 

approximately 20% of 

camping capacity in 

spring and 10% capacity 

in fall.

• The ability to 

accommodate increased 

visitation would be most 

limited, compared to 

other alternatives.
Alternatives for Managing Day Use

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 79

2.4.2 Alternatives for Managing Day Use in the Wilderness and Backcountry

Day visitors to Isle Royale’s Wilderness and Backcountry consist of people who visit the park 

for part of a day, or those who are staying in Rock Harbor or Windigo and take day trips along 

the trails or to destination sites. The range of activities available for these visitors offers valued 

opportunities for an important segment of Isle Royale visitors. 

Actions Common to All Alternatives for Day Use

In order to expand opportunities available in the park for people with disabilities, Isle Royale 

managers would explore options for modifying select trail sections for wheelchair accessibility. 

These trails would be appropriate in the developed and frontcountry zones within the vicinity of 

Rock Harbor and Windigo. 

All alternatives also include maintaining the concessions-operated boat tours with the stipulation 

established in the GMP that there would be no expansion of the tour destinations, schedule, or 

boat capacity. These tours are currently conducted with the M.V. Sandy, with a 42-person trip 

capacity. Destinations for these tours include; 1) the Edisen Fishery and Rock Harbor 

Lighthouse, Raspberry Island and Passage Island, which are in the Frontcountry Zone; 2) Hidden 

Lake and Lookout Louise, and McCargoe Cove and the Minong Mine in the Backcountry Zone;

and 3) sunset cruises in the Rock Harbor Channel and the open waters of Lake Superior.

Alternative A for Day Use: Maintain Existing Conditions (No Action Alternative)

A.1 Management Goals and Desired Future Conditions

The goal of this alternative is to maintain the existing conditions for day use, providing 

maximum access to the backcountry and wilderness for day visitors. Tolerance for the impacts of 

noise, crowding along trails and at destination sites, and resource impacts would be moderate to 

high. 

A.1.1 Visitor Use Levels

Access to the backcountry and wilderness for day visits would not be limited beyond boat 

capacities, maximizing visitors’ opportunities for day activities such as hiking and boat tours. 

Existing group size limits for NPS-guided tours, established with a goal of manageable sizes for 

quality interpretive tours, would be maintained. Encounters along all trails and destination sites 

accessible for day trips could be high, with up to 42 passengers on existing concessions 

organized boat tours and no limit on many hiking tours. In 2002 NPS-guided concessions tours 

to backcountry trails (the Minong Mine and Hidden Lake tours) averaged 16 people per tour, 

with a maximum group of 34 people. Opportunities for solitude or uncongested trails and sites 

would range from low to high. 

A.1.2 Guided Trip Opportunities

Park rangers and the Rock Harbor Lodge would continue to offer guided day trips to various 

destinations within the wilderness and backcountry, as would several private organizations. 

Popular locations for day trips would remain, including trails within the vicinity of Rock Harbor 
Alternatives for Managing Day Use

80 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

and Windigo and boat tours to Raspberry Island, Hidden Lake and Lookout Louise, Passage 

Island, Edisen Fishery, Daisy Farm, and McCargoe Cove and the Minong Mine.

Opportunities for guided trips would not be limited beyond capacities of tour boats or facilities. 

Space availability is and would continue to be the only limitation to guided trip opportunities. As 

of 2003 the maximum capacity for boat tours run through the Rock Harbor Lodge was 40 people. 

Group sizes on these tours would be unpredictable, ranging from small to very large groups.

A.1.3 Current Management Practices

The NPS and concessions tours would maintain group size limits based on facility capacities and 

safety, but there would be no size limits placed on any other day trips, whether they occur in 

developed areas of the park or in the wilderness and backcountry. With potential high use levels 

in areas accessible to day visitors, the NPS would minimize adverse impacts with mitigation 

measures including:

• Maintain trails to accommodate high use levels, concentrating impacts to minimize trail 

widening, erosion, and the establishment of unofficial “social trails.”

• Inform visitors to easily-accessible day use areas that they may encounter more people 

along the trails and at destinations than they would in more remote areas of the 

wilderness and backcountry. Also prepare visitors for encounters between both day and 

overnight hikers and boaters, altering expectations to avoid conflicts between different 

types of visitors.

• Work in cooperation with concessions services to schedule day tours at times that would 

least impact overnight backcountry and wilderness visitors.

• Provide additional day activities within the developed areas of the park rather than 

actively encouraging increased day use within more remote areas of the park’s wilderness 

and backcountry.

Alternative B for Day Use: Reduce Group Sizes in Selected Areas

B.1 Management Goals and Desired Future Conditions

The goal of this alternative is to provide high quality day trip opportunities while also 

minimizing adverse impacts to resources and other visitors in day use areas. The priority of this 

alternative is to improve the experiences of day trip participants and minimize adverse impacts to 

resources, other visitors in day use areas, and campers seeking remoteness and solitude. 

Crowding along trails and at destination sites, noise, and resource impacts increase with group 

size and often detract from the experiences of group participants and other people in the area. 

However, minimizing group impacts and maximizing higher quality opportunities would come at 

the expense of maximum access to organized day activities. 

B.1.1 Visitor Use Levels

The total number of guided day trips in the park would not be limited beyond facility capacities, 

but maximum group sizes would be established to maintain opportunities appropriate for each of 

the park’s different management zones, considering opportunities for participants in organized 

day trips as well as other visitors in those areas. The total number of people visiting the park or 

the wilderness and backcountry for day trips would not be limited, but group size restrictions 
Alternatives for Managing Day Use

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 81

may reduce opportunities for these visitors to participate in organized day activities in some 

areas of the park during some times of the season.

B.1.2 Guided Trip Opportunities

This alternative would aim to improve or maintain high quality experiences for guided trip 

participants by continuing existing options for day trip destinations while also ensuring 

appropriate group sizes for destinations visited. This may come at the cost of limited group sizes 

restricting some people’s opportunities to participate in organized trips.

B.2 Appropriate Management Actions

Group size limits would be established to be consistent with the goals of management zones 

(Appendix D, Map 3) as follows:

Developed Zone (Rock Harbor and Windigo)—no group size limits

Frontcountry Zone (bordering developed areas and significant attractions such as 

Edisen Fishery, Scoville Point, Raspberry Island, Passage Island trail, and Suzy’s 

Cave)—group size limit of 20. M.V. Sandy tours to these areas could carry up to 

20 passengers. 

Wilderness Portal, Backcountry and Primitive Zone (the majority of trails and 

campgrounds, including concession tours to Hidden Lake and Lookout Louise, 

and McCargoe Cove and the Minong Mine)—group size limit of 10. M.V. Sandy

tours to these areas could carry up to 10 passengers. 

Pristine Zone (off-trail)—group size limit of 6

These group size limits would be applied to all guided groups, including concession-led tours, 

NPS- guided tours, Isle Royale Institute tours, and tours with private organizations. The National

Park Service would monitor trail encounters in day use areas to ensure that regulations were 

effective at meeting goals without being unnecessarily restrictive.

Alternative C (REVISED): Set Day Use Group Sizes to Correspond with Current Use 

Levels (Preferred Alternative)

C.1 Management Goals and Desired Future Conditions

This alternative seeks to maintain options for high quality day activities in the park, and includes

smaller group opportunities within the park’s wilderness and backcountry areas. The goal would 

be to accommodate future increases in the number of day visitors up to current maximum or 

average visitation levels (depending on the management zone), while also providing quality day 

activities and minimizing adverse impacts to resources by monitoring trail and day use 

destination conditions. This section reflects changes incorporated from the public comment 

period for the draft WBMP. More details can be found in Chapter 5: Public Comment and 

Responses, and Appendix K: Comments Received. 

C.1.1 Visitor Use Levels

The total number of guided day trips in the park would not be limited beyond facility capacities, 

and group sizes within the developed zone would not be limited beyond transportation capacities. 

Maximum group sizes in other areas of the park would be established to correspond with each of 
Alternatives for Managing Day Use

82 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

the park’s different management zones, focusing on opportunities for participants in organized 

day trips consistent with current maximum numbers of day use groups. Groups exceeding 

established limits would still have the option of visiting these areas as long as they were willing 

to split into multiple smaller groups. The park would monitor scheduled day trips, through the 

Commercial Use Authorization (CUA) system, to ensure that aggregate numbers of organized 

groups (concession tours plus other organized groups) did not exceed total group size limits at a 

specific destination and time. Priority would be given to established concession tours. The total 

number of people visiting the park or the wilderness and backcountry for day trips would not be 

limited. 

The defining difference between this alternative and the No Action alternative is that upper limits 

on organized tour group sizes are established so that uncontrolled growth in group sizes does not 

occur. This type of growth is foreseeable if commercial and educational tours at the park 

increase in the future.

C.1.2 Guided Trip Opportunities

This alternative would aim to retain the current options available to day visitors within and 

adjacent to the Developed, Frontcountry, and most popular sites within backcountry zones of the 

park. Existing options for day trips would continue, and although group size limits would apply, 

these limits match current maximum or average use levels (see Section 4.2.3. for details on 

visitor use levels.)

C.2 Appropriate Management Actions

The following actions would aid in providing more opportunities for day activities within the 

vicinity of Developed and Frontcountry zones, and selected backcountry zones while also 

maintaining the overall quality of opportunities for day activities:

• Explore options for adding a new loop trail of 3-5 miles in the Windigo area that would 

remain as much as possible within the non-wilderness boundary. This may entail 

converting a segment of the corridor where the new trail would be constructed from 

“Pristine Zone” to “Backcountry Zone,” amending the management zones established in 

the GMP. 

• Establish group size limits for day trips outside of the Developed Zone (no limits in 

Developed Zone) as follows, with the option of larger groups still visiting these areas as 

long as they split up with multiple leaders: 

Frontcountry Zone (bordering developed areas and significant attractions such as 

Edisen Fishery, Scoville Point, Raspberry Island, Passage Island trail, and Suzy’s 

Cave)—group size limit of 40. 

Wilderness Portal, Backcountry, and Primitive Zone (the majority of trails and 

campgrounds)—group size limit of 20. Hidden Lake, Lookout Louise, McCargoe 

Cove and the Minong Mine would be exceptions, with group sizes of up to 40

people accepted. Any tours to these excepted destinations of more than 40 people 

would need to split into multiple smaller groups.

Pristine Zone (off-trail)—group size limit of 6
Alternatives for Campfires

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 83

2.4.3 Alternatives for Campfires

Many backcountry campers look forward to campfires as part of their experience, yet campfires 

are also associated with impacts to resources such as increased tree damage and unofficial trails, 

reduction in woody debris and screening between campsites, and damage to cultural resources. 

Isle Royale’s campfire policies would attempt to best minimize adverse impacts while also 

allowing for desired camping experiences.

Actions Common to All Alternatives

The following would be common to all alternatives:

• NPS interpretive programs could include campfires.

• NPS would prohibit the import of any firewood to the island to prevent the introduction 

and spread of invasive exotic species. (The park would possibly explore options in the 

future to use local firewood or provide kiln-dried wood from the mainland for any visitor 

or NPS firewood needs.)

Alternative A for Campfires: The No Action Alternative

The goal of this alternative is to continue offering opportunities for camping with campfires 

while also concentrating and minimizing adverse resource impacts. To accomplish this with 

minimal concentrated impacts, campfires would continue to be allowed in a limited number of 

campgrounds with NPS-provided metal fire rings. Other than for critical resource protection 

needs, campfires would continue to be permitted in the existing 11 campgrounds with fire rings. 

Additionally, standing metal grills would be replaced with metal fire rings (except in Developed 

Zone), which are more compatible with the park’s wilderness and backcountry setting. 

A.1 Management Goals and Desired Future Conditions

A.1.1 Visitor Opportunities

Visitors would have the option to plan their trips around where fires are or are not permitted. 

Some campers value campfires as a means of honing outdoor skills for self-sufficiency, as well 

as being a part of restorative and relaxing experiences. However, other campers dislike the 

adverse resource impacts associated with campfires. This alternative would offer opportunities to 

suit both. 

A.1.2 Natural and Cultural Resources

Limiting the number of campfire rings in the park, and intentionally locating those rings in areas 

lacking vulnerable cultural and natural resources could minimize adverse impacts to these 

resources. Building and maintaining a campfire inevitably has some impact on resources, though 

this impact can be minimized with Leave-No-Trace practices. On Isle Royale campfires have

been correlated with tree damage, development of unofficial trails, scarring of rocks and soil, and 

loss of woody debris in the forest. Additionally, the park’s cultural resources are vulnerable to 

fire through intentional or unintentional burning of the remains of historic structures. 
Alternatives for Campfires

84 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

A.2 Current Management Practices

• Current fire regulations would continue to be enforced including the use of only down 

and dead wood and the requirement that all fires be fully contained within NPS fire rings 

or grills.

• Maintain fire rings at the 11 campgrounds where fires are currently permitted. Over time 

replace fire rings with smaller rings with adjustable grates to aid in cooking and 

encourage appropriately small fires.

• Replace standing grills with fire rings (except at the Rock Harbor marina, where grills 

would be maintained)

• Increase education about low-impact fires and affected resources, and maintain and 

enforce regulations to minimize adverse resource impacts. 

• As future need dictates, remove fires from areas with vulnerable critical resources, or 

areas showing unacceptable fire-associated impacts to resources. This could be 

accomplished through temporary or permanent removal of fire rings.

Alternative B for Campfires: Move Campfire Rings to Different Campgrounds on a 

Rotational Basis (Preferred Alternative)

Campfires would be allowed only within NPS-provided metal rings. These rings would be 

located in campgrounds with an adequate supply of down and dead wood for fuel, and without 

vulnerable natural or cultural resources. The specific location of fire rings could change from 

year to year as they are removed from campgrounds showing significant impacts and relocated to 

campgrounds with appropriate resource conditions to accommodate campfires.

B.1 Management Goals and Desired Future Conditions

B.1.1 Visitor Opportunities

Some campers value campfires as a means of honing outdoor skills for self-sufficiency, as well 

as being a part of restorative and relaxing experiences. However, other campers dislike the 

adverse resource impacts associated with campfires. This alternative would offer opportunities 

for both. However, as the specific location of fire rings may change from year to year, campers 

may have difficulty planning in advance to camp where fires are permitted.

B.1.2 Natural and Cultural Resources

Rotating campfire rings between campgrounds, limiting the number of campfire rings in the 

park, and intentionally locating those rings in areas lacking vulnerable cultural and natural 

resources could minimize adverse impacts to resources. Building and maintaining a campfire 

inevitably has some impact on resources, though this impact can be minimized with Leave-NoTrace practices. On Isle Royale, campfires have been associated with tree damage, development 

of unofficial trails, scarring of rocks and soil, depletion of screening between campsites, and loss 

of woody debris in the forest around campgrounds. Additionally, the park’s cultural resources 

are vulnerable to fire through intentional or unintentional burning of the remains of historic 

structures. Under this alternative mitigation measures would be taken to minimize these adverse 
Alternatives for Campfires

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 85

impacts, including establishing clear protocols for when and where campfires would be 

appropriate. 

These protocols include:

• Prior to implementation an analysis of fuel loading and resource sensitivity would be 

completed in any campgrounds that would be included in the rotation. This would require 

an inventory of cultural and natural resources prior to changing fire ring locations.

• Selecting locations for campfires would be based on resource conditions.

• Only shoreline campgrounds with docks would be included in the rotation because of 

feasibility of access for maintenance, restoration and monitoring.

• There would not be a guarantee of maintaining the current number of campfires, or a 

guarantee of a minimum number of campfire sites. Management would retain flexibility 

in establishing the appropriate number and location of campfire sites each season.

• Costs of maintaining, restoring sites, and monitoring resource conditions would be 

considerations in determining the number and location of campfire sites.

• If the NPS were not able to keep up on monitoring (fuel loading, resource impacts) and 

maintenance then campfires would not be retained.

B.2 Appropriate Management Actions

• Current fire regulations would continue to be enforced including the use of only down 

and dead wood and the requirement that all fires be fully contained within NPS fire rings 

or grills. NPS would temporarily remove fire rings from heavily impacted sites and add 

rings to other campgrounds with adequate fuel availability and other appropriate resource 

conditions. Fire rings would then be moved between campgrounds on a rotational basis as 

resource impacts and fuel availability necessitated.

• Replace existing fire rings with smaller rings with adjustable grates to aid in cooking and 

encourage appropriately small fires.

• New fire rings may be communal for a campground or located within individual 

campsites, with a goal of minimizing resource impacts and fuel depletion.

• Remove all standing grills, except in Developed Zone.

• Fire rings would not be added to campgrounds with sensitive cultural resources. 

• Increase education about low-impact fires and affected resources. 

• The permitting process would include informing visitors of where they can and cannot 

have fires—permits would continue to state whether fires were allowed in each 

campground on a party’s itinerary.

Alternative C for Campfires: Remove All Fire Rings and Grills and Do Not Allow any 

Campfires in the Park.

Protection of natural and cultural resources and pristine conditions surrounding campgrounds 

would be prioritized. No campfires would be allowed in the park: campers would be prepared to 

cook on camp stoves or self-contained grills. All existing fire rings and NPS-provided grills 

would be removed from campgrounds. However, grills would remain at the Rock Harbor 

Marina, as they are compatible with the level of development in the area.
Alternatives for Campfires

86 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

C.1 Management Goals and Desired Future Conditions

C.1.1 Visitor Opportunities

Visitors would have the opportunity to camp in areas unimpacted by campfires. All camp 

cooking would be with self-contained stoves or grills.

C.1.2 Natural and Cultural Resources

Preservation of natural and cultural resources would be prioritized by removing the impacts and 

threats to these resources associated with campfires. Although current natural resource impacts 

are judged to be generally moderate to minimal, some specific sites show noticeable degradation, 

including limbed trees and loss of woody vegetation around sites. Eliminating campfires entirely 

may lead to more pristine conditions surrounding campsites. 

C.2 Appropriate Management Actions

• All fire rings and NPS-provided grills would be removed from the park, excluding the 

Developed Zone. 

• Visitors would be educated to be prepared to camp without fires, and understand the 

reasons for eliminating campfires for resource protection.

• As need dictated, enforcement of the campfire ban may increase.

Alternative Considered but Rejected: Add Fire Rings or Grills at All Campgrounds

Survey data indicate a moderate degree of increased natural resource impacts in campsites where 

fires are permitted, including tree damage and increased number of unofficial trails, and “survey 

findings present no compelling evidence for restricting the current policy of allowing campfires 

at backcountry sites” (Farrell and Marion 1998). However, unlike most natural resources, 

cultural resources are irreplaceable and irreparable once damaged. Many Isle Royale 

campgrounds are located within or adjacent to cultural sites with structures that would be 

vulnerable to damage from fires. The NPS has determined that the risk to these resources 

outweighs the benefits of allowing campfires in all campgrounds. Thus the option of allowing 

campfires in all campgrounds was rejected. 

2.4.4 Alternatives for Fire Towers

Currently there are three fire towers within Isle Royale’s designated Wilderness: 10-foot tall 

Ishpeming (built in 1961), 41-foot Feldtmann (built in 1964), and 41-foot Ojibway (built in 

1964). None of the towers are listed on the Historic Register and none are critical for fire 

monitoring at this point. Ojibway is being used for a radio repeater and research and monitoring 

projects. Trail crew and rangers occasionally use the other two for storage and to stay in 

overnight while working in the backcountry. The question is whether these facilities are 

necessary or appropriate for the park. According to NPS policy outlined in the NPS Reference 

Manual for Wilderness Preservation and Management (NPS 1999b, § 6.3.10):

...authorizations of NPS administrative facilities located in wilderness will be limited to 

the types and minimum number essential to meet the minimum requirements for the 
Alternatives for Fire Towers

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 87

administration of the wilderness area. A decision to construct, maintain, or remove an

administrative facility will be based primarily on whether or not such a facility is 

required to preserve wilderness character or values, not on considerations of 

administrative convenience, economy of effect, or convenience to the public or park staff. 

Maintenance or removal of historic structures will additionally comply with cultural 

resource protection and preservation policies and directives, and the concept of minimum 

requirement management techniques for wilderness. 

Alternative A for Fire Towers: No Action, Maintain Existing Fire Towers

This alternative would maintain all three fire towers within the park’s wilderness and 

backcountry. 

A.1 Management Goals and Desired Future Conditions

A.1.1 Visitor Experiences

Fire towers would remain in the wilderness for visitors to enjoy as part of the park’s history, as 

well as for views offered atop the towers. However, Feldtmann and Ishpeming would remain in a 

state of minimal repair, and the public would not have access to the cabins or the tops of the

towers. This alternative would accept the cost to wilderness character of maintaining obvious 

structures along wilderness trails.

A.1.2 Administrative Uses

Ojibway Tower would continue to be used administratively for research and monitoring 

equipment, a radio repeater, and future administrative needs that cannot be met outside of 

wilderness. Feldtmann and Ishpeming towers would continue to be used as temporary shelters 

and storage for park staff working in the backcountry, and could be used for other administrative 

needs in the future.

A.2 Current Management Practices 

• Necessary actions would be taken to maintain the three fire towers in a state that is not a 

safety risk to NPS staff or visitors.

• Actions may also be taken to expand the administrative use of these structures, including 

possible communication technologies where these needs could not be met adequately if 

based outside of the park’s wilderness. 

Alternative B for Fire Towers (REVISED): Remove Ishpeming Fire Tower and Possibly 

Feldtmann Fire Tower and Maintain Ojibway Tower (Preferred Alternative)

With this alternative, Ishpeming tower would be removed and the site restored to natural 

conditions. Ojibway tower would be maintained for present and future administrative needs 

associated with management of the park’s wilderness and backcountry. The decision to keep or 

remove Feldtmann tower would be based on its utility for administrative purposes, including 

telecommunications and wildlife telemetry monitoring. 
Alternatives for Fire Towers

88 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

B.1 Management Goals and Desired Future Conditions

B.1.1 Visitor Experiences

By removing the Ishpeming tower (and possibly Feldtmann tower) and restoring the sites to 

natural conditions, the wilderness character of the Feldtmann Ridge Trail and the middle portion 

of the Greenstone Trail would be improved for visitors seeking more pristine surroundings. 

Removing the towers would also eliminate the potential safety hazards of deteriorating 

structures. Retaining one of the park’s fire towers would also preserve an interesting piece of the 

history of the park. Retaining or removing Feldtmann tower will be based on its evaluation for 

administrative uses. Removing the Feldtmann tower would mean the loss of the opportunity to 

climb the tower for its vista. The treeline now extends above the Ishpeming tower, so there 

would be no loss of vista with the removal of this tower.

B.1.2 Administrative Uses

Ojibway tower, and possibly Feldtmann tower, would continue to be used for administrative 

purposes that are compatible with management of the wilderness and backcountry. Ishpeming 

tower is not meeting administrative needs that cannot be better met with a less obtrusive option. 

B.2 Appropriate Management Actions

• Ishpeming (and possibly Feldtmann) tower would be removed using the minimum 

tool necessary to safely and effectively complete the job and the necessary 

environmental compliance requirements would be completed as part of the removal 

plan. 

• Work would be done to restore the sites to their natural conditions. 

• Ojibway Tower (and possibly Feldtmann tower) would continue to be maintained and 

utilized for administrative purposes. Administrative uses and equipment could 

increase in the future, as long as they satisfied the minimum tool requirements. 

Alternative Considered But Rejected: Remove all Fire Towers

Ojibway is still being used for administrative purposes that are compatible with management of 

the wilderness and backcountry and cannot be adequately accomplished outside of the 

wilderness. Thus maintenance of the Ojibway Tower is determined to be in compliance with 

wilderness legislation and the goals of this WBMP, and was not proposed for removal. 

2.4.5 Picnic Tables

Since the draft WBMP was released, the National Park Service has revised and edited its 

management policy with respect to picnic tables: picnic tables will not be allowed in wilderness 

except in those limited circumstances when they are necessary for resource protection and when 

documented and approved by the park through a minimum requirements analysis (NPS Policies, 

2006.) The Preferred Alternative has been changed to be consistent with NPS policy.
Alternatives for Picnic Tables

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 89

Alternative A for Picnic Tables: The No Action Alternative

A.1 Management Goals and Desired Future Conditions

A.1.1 Visitor Experiences

The NPS would continue to provide picnic tables at shelter and tent sites at all dockside 

campgrounds for visitor convenience and comfort. Picnic tables would continue to provide an 

amenity for ease of cooking, and a place to sit and gather. Visitors seeking a more primitive 

atmosphere for camping would still have the option of staying in campgrounds without picnic 

tables or shelters, however, there would be fewer of these options along the Lake Superior 

shoreline; Pickerel Cove, Little Todd Harbor, and Huginnin Cove are all along the Superior 

shoreline and do not have shelters or picnic tables. 

A.1.2 Wilderness Character

Managing for wilderness character would continue to prioritize the benefits of concentrating 

human impacts and minimizing impacts to natural and cultural resources over minimizing 

modern intrusions to create a more primitive camping atmosphere. Picnic tables would continue 

to be maintained as a tool for concentrating adverse impacts in campsites. 

A.1.3 Natural and Cultural Resources Protection

Picnic tables would continue to be used as an effective tool for concentrating the adverse impacts 

of trampling, vegetation loss, and soil compaction in campsites, as well as minimizing the total 

area of campsites. Concentrating use in campsites would continue to be one goal for minimizing 

adverse impacts to natural and cultural resources. 

A.2 Current Management Practices

Picnic tables are currently provided and maintained in 20 of the park’s 36 campgrounds, 11 of 

which are within designated or potential wilderness. Picnic tables are provided at shelter sites as 

well as tent sites, and may also be found dockside. A picnic table is also provided at Hidden 

Lake, which is a trailhead within wilderness, but not a campground. These picnic tables have a 

metal base and brown-painted wood seats and tabletops. Continuing the current management 

direction would also mean failing to comply with NPS policy for wilderness management. 

Alternative B for Picnic Tables: Remove Picnic Tables From All Campgrounds Within 

Designated or Potential Wilderness

In order to adhere to NPS directives picnic tables would be removed from all campgrounds or 

docks within designated and potential wilderness. The picnic tables in non-wilderness 

campgrounds with docks would remain and be maintained. Non-wilderness campgrounds 

include Rock Harbor, Three Mile, Daisy Farm, Moskey Basin, Malone Bay, Siskiwit Bay, 

Washington Creek (Windigo), McCargoe Cove, and Belle Isle.
Alternatives for Picnic Tables

90 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

B.1 Management Goals and Desired Future Conditions

B.1.1 Visitor Experiences

Removing picnic tables would remove a modern convenience for visitors and create a more 

primitive atmosphere for camping, as suitable for recreation within a wilderness. By retaining 

picnic tables in non-wilderness campgrounds, visitors who prefer such conveniences would still 

have those opportunities within Isle Royale’s backcountry.

B.1.2 Wilderness Character

The goal of this alternative is to be in compliance with NPS management policies for protecting 

wilderness character by minimizing the intrusion of modern conveniences. Other modern 

structures within wilderness campgrounds have been justified either through specific allowances 

in Isle Royale’s wilderness legislation (as in the case of shelters), or for the purpose of 

administering the area as wilderness (as in the case of outhouses, for management of human 

waste and the associated resource and human health impacts). Picnic tables do not satisfy an 

essential need for administration of these areas as wilderness, nor are they mentioned in the 

park’s wilderness legislation.

B.1.3 Natural and Cultural Resources Protection

Picnic tables have proven to be effective in helping to concentrate human impacts in campsites, 

focusing activity within the boundaries of a campsite and minimizing increases in campsite sizes. 

However, there are other means of concentrating use and minimizing sprawl with methods that 

would be more compatible with wilderness goals and NPS directives. This alternative would 

prioritize improving the primitive atmosphere of campsites and adherence to NPS policies over 

utilizing all methods possible to minimize the sizes of campsites and measurable human impacts 

within campgrounds.

B.2 Appropriate Management Actions

With this alternative all picnic tables would be removed from campgrounds and docks within the 

park’s designated and potential wilderness. This would include: Grace Island, Beaver Island, 

Hay Bay, Todd Harbor, Birch Island, Duncan Bay, Duncan Narrows, Merritt Lane, Tookers 

Island, Caribou Island, Chippewa Harbor, and Hidden Lake. Picnic tables would be maintained 

at non-wilderness lakeshore campgrounds with docks: Rock Harbor, Three Mile, Daisy Farm, 

Moskey Basin, Malone Bay, Siskiwit Bay, Washington Creek, McCargoe Cove, and Belle Isle. 

The new campgrounds proposed in the GMP all fall within designated or potential wilderness 

and would not have picnic tables. These include Crystal Cove, Johns Island, Fishermans Home, 

Wright Island, and a new dock and campground at McCargoe Cove. Upon the GMP-approved 

removal of docks at McCargoe Cove, Siskiwit Bay, and Three Mile (all of which are nonwilderness) the picnic tables would be removed.
Alternatives for Picnic Tables

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 91

Alternative C for Picnic Tables (REVISED): Maintain Picnic Tables in Wilderness 

Campgrounds Where Consistent With NPS Policy (Preferred Alternative)

The park has re-evaluated the placement of picnic tables in wilderness using the Minimum 

Requirements/Minimum Tool guidelines, consistent with 2006 revision of NPS policy. The 

review includes evaluating the reduction of negative human impacts (compaction, loss of 

vegetation), as well as the impact on wilderness character, and possible design changes to help 

the tables be less noticeable. 

C.1 Management Goals and Desired Future Conditions

C.1.1 Visitor Experiences

This alternative would retain picnic tables in campgrounds where docks and/or shelters are 

currently maintained. Visitors seeking a more primitive atmosphere for camping would still have 

the option of staying in campgrounds without picnic tables or shelters, however, there would be 

fewer of these options along the Lake Superior shoreline; Pickerel Cove, Little Todd Harbor, and 

Huginnin Cove are all along the Superior shoreline and do not have shelters or picnic tables. 

C.1.2 Wilderness Character

Managing for wilderness character with this alternative would prioritize the benefits of 

concentrating human impacts and minimizing impacts to natural resources over minimizing 

modern intrusions to create a more primitive camping atmosphere. 

C.1.3 Natural and Cultural Resources Protection

As stated above, picnic tables have proven to be effective in helping to concentrate human 

impacts in campsites, focusing activity within the boundaries of a campsite and minimizing 

increases in campsite sizes. Although these benefits may not be significant on a park-wide scale 

of impacts and ecosystem health, they can be significant on a site-specific scale, with noticeable 

loss of vegetation and increase in areas of exposed soil caused by human impacts spreading 

beyond the intended boundaries of campsites. Retaining picnic tables in campgrounds would 

maintain one proven method for minimizing these impacts. 

C.2 Appropriate Management Actions

With this alternative Isle Royale managers would maintain picnic tables at some of the 

campgrounds within the park’s designated or potential wilderness. Where they meet Minimum 

Tool guidelines, picnic tables would be maintained at Grace Island, Beaver Island, Hay Bay, 

Todd Harbor, Birch Island, Duncan Bay, Duncan Narrows, Merritt Lane, Tookers Island, 

Caribou Island, Chippewa Harbor, Rock Harbor, Three Mile, Daisy Farm, Moskey Basin, 

Malone Bay, Siskiwit Bay, Washington Creek, McCargoe Cove, and Belle Isle. Picnic tables 

would also be added at the new campgrounds proposed in the GMP (where consistent with new 

NPS policy), all of which would have maintained docks and fall within designated or potential 

wilderness. Other than these, picnic tables would not be added at additional campgrounds.

When the docks and shelters at Duncan Bay and Siskiwit Bay campgrounds are removed (per the 

GMP), picnic tables will also be removed. 
Alternatives for Picnic Tables

92 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

2.4.6 Summary of the Preferred Alternatives and Proposed Actions in Combination

This draft WBMP proposes several changes in how Isle Royale’s wilderness and backcountry are 

managed. The preferred alternatives were crafted with an intention of creating one cohesive 

management program, with management goals for each of several issues being complementary, 

not contradictory. The planning team’s intention was to respond to public interest and the 

concerns of subject matter experts, and incorporate the best science available for guiding 

preservation of Isle Royale’s resources and values. General goals included improving the quality 

of wilderness and backcountry experiences for visitors while still providing high public access to 

the park for appropriate types of recreation. Existing facilities could be used more efficiently, 

while unnecessary facilities would be removed from the wilderness. Table 5 outlines the goals 

and proposed management actions for all of the preferred alternatives. 

The preferred alternatives in combination also strive to minimize adverse resource impacts, in 

many cases improving resource conditions that are currently showing degradation. Because Isle 

Royale is already a difficult and expensive park to visit, the preferred alternatives were also 

crafted with an interest in not further restricting general public access to the park. The preferred 

alternative for managing overnight camping and boating on Isle Royale focused on more 

efficiently utilizing existing camping facilities through the creation of a backcountry office and 

advanced permitting. The intent is to expand visitor services for trip planning and reduce 

campground crowding to improve social and resource conditions in campgrounds. Because this 

could result in a decrease in visitor access to the backcountry for camping during the busiest 

weeks of the season, the preferred alternative for managing day use was crafted with an intention 

to allow an increase in day use throughout the visitor season. Day tours would be managed to 

concentrate the majority of day visitors close to developed areas, frontcountry areas, and selected 

backcountry destinations in the park and minimize adverse impacts to wilderness character and 

other critical resources. 

The preferred alternatives in combination also aimed to minimize or reduce the impacts of 

development in the park’s wilderness. Although the preferred alternative for overnight use would 

add one additional campsite at North Desor campground and a few rustic cabins in Rock Harbor, 

and the preferred alternative for day use would add 3-5 miles of new trail, no new campgrounds 

would be constructed other than those approved in the GMP, 1-2 fire towers would be removed, 

and campfire rings would be located only where resource conditions could tolerate the associated 

impacts. Specific management actions that would be appropriate under each of the preferred 

alternatives are outlined in Table 5. 
Summary of Preferred Alternatives in Combination

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 93

Table 5: Summary of the Preferred Alternatives

Actions Common to 

All

Managing 

Overnight Use Managing Day Use Campfires Fire Towers Picnic Tables

Goals The NPS would 

forego actions that 

might have no 

seeming physical 

impact but which 

would detract from 

wilderness character 

and the idea of 

wilderness as a place 

set apart.

Provide a range of 

high quality 

opportunities for 

wilderness and 

backcountry 

experiences and 

reduce adverse 

impacts to park 

resources and values.

Expand opportunities 

for high quality day 

activities, while also 

accommodating 

future increases in 

day use and 

minimizing adverse 

impacts to park 

resources and values.

Continue to provide 

an opportunity for 

camping with 

campfires, while also 

concentrating and 

minimizing adverse 

resource impacts. 

Improve the park’s 

wilderness character 

by removing 

substantial structures 

that no longer serve 

an administrative 

need. 

Adhere to NPS 

policy for wilderness 

management by 

using effective tools 

for concentrating 

adverse impacts in 

campsites. 

Desired 

Future 

Conditions

• Provide a range of 

quality visitor 

opportunities.

• Reduce the adverse 

impacts of NPS 

operations.

• Overcrowding 

would be reduced 

in campgrounds all 

season.

• Improve camper 

distribution.

• Protect seasonal 

sensitivities of park 

resources.

• Provide a seasonal 

range of visitor 

opportunities, with 

low use in the 

spring and fall.

• Improve trip 

planning and 

information 

services.

• Create additional 

opportunities, such 

as a new loop 

hiking trail, for day 

visitors. 

• Improve social and 

resource conditions 

in some day use 

areas by limiting 

the growth of 

organized day tours

to current levels.

• Allow for an 

increase in day 

visitors to the park.

• Visitors would 

have the option to 

camp with 

campfires.

• Visitors would 

have the choice of 

camping in areas 

where fires are 

permitted, or 

where fires are not 

permitted.

• Fire rings would be 

located only where 

there no vulnerable 

natural or cultural 

resources. 

• Administrative 

impacts to 

wilderness 

character would be 

reduced by 

removing 1-2 of the 

park’s 3 fire 

towers.

• Ojibway Tower

would continue to 

be used for

administrative 

purposes that are 

compatible with 

wilderness, such as 

communications, 

research, and 

monitoring.

• Isle Royale would 

be in compliance 

with NPS policies 

for wilderness 

management.

• Adverse resource 

impacts would be 

effectively 

concentrated in 

campsites of 

minimal sizes.

• Picnic Tables 

would continue to 

be available for 

visitor convenience 

in some wilderness 

campgrounds
Summary of Preferred Alternatives in Combination

94 CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE

Actions Common to 

All

Managing 

Overnight Use Managing Day Use Campfires Fire Towers Picnic Tables

Appropriate 

Management 

Actions

• Low-cost rustic 

cabins would be 

added in Rock 

Harbor.

• Cross-cut saws 

would be used 

increasingly to 

minimize chainsaw 

use.

• Sustainablyharvested, 

chemically 

preserved lumber 

would be used for 

trails and 

campgrounds.

• Cross-country 

camping and 

anchoring-out 

would continue, 

with monitoring of 

impacts.

• The Minimum 

Requirement 

Decision Tree 

would apply to all 

NPS activities in 

wilderness.

• Establish a 

mainland-based

backcountry office 

to coordinate 

information 

services and 

permitting.

• Implement an 

advanced 

permitting system 

for all overnight 

boaters and 

campers, allowing 

more flexibility for 

boaters not using 

campsites.

• Discontinue the 

practice of issuing 

permits over the 

capacity of a 

campground.

• Institute a 

permitting fee to 

offset the costs 

associated with the 

backcountry office.

• Expand North 

Desor campground 

by 1 campsite.

• Expand public 

education to reduce 

adverse impacts to 

park resources and 

values.

• Monitor social and 

resource indicators.

• Explore options for 

creating a new 3-5 

mile day trail near 

Windigo.

• Establish group 

size limits for day 

tours, allowing 

larger groups to 

split into multiple 

small groups. 

Limits set by 

management zone:

Developed : no limit

Frontcountry: 40

Wilderness Portal, 

Backcountry and 

Primitive: 20

Pristine: 6

Note: Hidden Lake,

Lookout Louise, and 

McCargoe Cove 

would be exceptions,

with 40 people 

allowed.

• Adhere to clear 

protocols for when 

and where 

campfires would 

be appropriate, 

based on resource 

conditions.

• Remove or add fire 

rings at different 

campgrounds as 

necessary, based 

on resource 

conditions

• Replace existing 

fire rings with 

smaller metal rings 

with adjustable 

grates.

• A single communal 

ring could replace 

multiple individual 

campsite rings in 

some campgrounds

• Increase education 

about low-impact 

fires and sensitive 

resources. 

• Include 

information about 

the locations of 

campfire rings for 

visitors at the time 

of permitting.

• Remove Ishpeming 

Tower. Review 

administrative 

needs 

(communication, 

research) for 

Feldtmann Tower, 

using the minimum 

tool necessary to 

achieve 

administrative 

functions

• Restore the 

impacted sites to 

their natural 

conditions

• Maintain and 

utilize Ojibway

Tower for 

administrative 

purposes 

associated with 

managing the 

park’s wilderness.

• Retain picnic tables 

within some of the 

park’s wilderness 

campgrounds

where consistent 

with revised NPS 

policy, using the 

Minimum Tool 

evaluation process.

• Remove picnic 

tables from 

campgrounds 

where docks and 

shelters are 

removed (i.e. 

Siskiwit Bay and 

Duncan Bay upon 

full implementation 

of the GMP).
Summary of Preferred Alternatives in Combination

CHAPTER 2: ALTERNATIVES, INCLUDING NO ACTION AND THE PREFERRED ALTERNATIVE 95

2.5 The Environmentally Preferred Alternative 

The Environmentally Preferred Alternative is one that (DO-12, §2.7.D):

• Fulfills the responsibilities of each generation as trustee of the environment for 

succeeding generations;

• Ensures for all Americans safe, healthful, productive, and aesthetically and culturally 

pleasing surroundings;

• Attains the widest range of beneficial uses of the environment without degradation, risk 

of health or safety, or other undesirable and unintended consequences;

• Preserves important historic, cultural, and natural aspects of our national heritage and 

maintains, wherever possible, an environment that supports diversity and variety of 

individual choice;

• Achieves a balance between population and resource use that will permit high standards 

of living and a wide sharing of life’s amenities; and

• Enhances the quality of renewable resources and approaches the maximum attainable 

recycling of depletable resources. 

For Isle Royale’s WBMP, the Environmentally Preferred Alternative is the combination of 

alternatives that together would best achieve the above criteria. Throughout the planning process 

only those options that were determined to be environmentally sound were considered for 

inclusion in alternatives. Management actions that were not thought to be environmentally 

sound were not considered to be viable options for Isle Royale. However, in identifying 

preferred alternatives for all of the issues raised in this WBMP, the NPS strived to not only cause 

the least damage to park resources and values, but actually protect, preserve, and enhance those 

resources and values, while also enhancing public benefits from the park. The preferred 

alternatives, in combination, meet the above goals of an Environmentally Preferred Alternative 

to the greatest extent by protecting and enhancing park resources while also providing a high 

degree of public access and high quality public opportunities at Isle Royale. 
Visitor Use and Experiences

96 CHAPTER 3: AFFECTED ENVIRONMENT

CHAPTER 3: AFFECTED ENVIRONMENT

This chapter describes the existing natural and human components of the environment that could 

be affected by the implementation of any of the alternatives. Under NEPA, “affected 

environment” means resources expected to experience environmental impacts. Only those areas 

that could be affected by proposed actions are included.

The Wilderness Act dictates appropriate activities within Isle Royale’s wilderness, but more 

flexibility is allowed within the park’s non-wilderness backcountry, such as the use of sailboats 

and motors. National Park Service management policies direct that wilderness areas must be 

managed to preserve their wilderness character and resources while providing for “appropriate” 

uses. Appropriate uses are those that require, yet do not degrade, the wilderness character and 

values, and include activities such as recreation, scientific inquiry, education, and historical use. 

3.1.1 Visitor Experiences and Opportunities

With no roads on Isle Royale, visitors travel through the park by boat or by foot and visit with 

many shared and different interests. Common recreation activities include hiking, motorboating 

on Lake Superior, canoeing, kayaking, sailing, observing wildlife, fishing, and photography. 

Visitors also spend much time learning about and exploring the park’s natural and cultural 

treasures. Visitors come to Isle Royale seeking restorative experiences such as relaxing,

observing the scenic beauty, being in a natural setting, observing and hearing wildlife, personal 

challenges, and developing outdoor skills (Pierskalla and others 1997). Figure 1 illustrates the 

breakdown of island visitors by general user groups. 

Hikers

42%

Kayakers

2%

Canoers

5%

Sailors

2%

Power 

Boaters

19%

Lodge Guests

17%

Day Visitors

13%

Figure 1: Types of Visitors to Isle Royale National Park (based on average 1997-2001)

3.1 Visitor Use and Experiences
Visitor Use and Experiences

CHAPTER 3: AFFECTED ENVIRONMENT 97

The range of opportunities in Isle Royale’s wilderness and backcountry may vary at different 

times of the season and in different areas of the park. Currently, visitors to the park in July and 

August will find more fellow campers, boaters and hikers, as well as more amenities with the 

store, visitor centers, ranger stations, and maintenance activities in full operation. Those 

choosing to visit in May or October will find more challenging weather conditions, fewer NPS 

staff available for assistance, greater opportunities for solitude in the campgrounds and on trails, 

and in general, the need to be more self-sufficient. Camping within Rock Harbor and Windigo 

offers access to more developed modern conveniences such as formal interpretive programs, 

restrooms, shower and laundry facilities, a store and restaurant, boat rentals, and proximity to the 

park’s busiest dock and entry point. On the opposite end of the spectrum, obtaining a crosscountry camping permit offers the opportunity to travel and camp off-trail. This requires greater 

self-sufficiency and skill with few chances of encountering other people, the challenges of 

orienteering across rugged terrain with abundant swamps and thick forests, and the difficulty of 

finding a hospitable camping spot. There are also many options of how to visit the park, 

including guided trips, traveling with family or friends, or traveling solo. This range of

opportunities offers options suitable for first-time campers, highly experienced backcountry 

travelers, and everyone in between. 

3.1.2 Visitor Use Patterns and Trends

Isle Royale’s visitors are typical of most National Park visitors in that they tend to travel in 

family or peer groups of 2-4 people and are usually highly educated. They differ from visitors to 

many parks in that most have more experience in backcountry settings, place high value on 

wilderness attributes, and stay longer than visitors to most National Parks. With the difficulty in 

reaching the island, the vast majority of visitors stay for more than one day. 

In 1970, at the time of the park’s wilderness recommendation, approximately 10,000 people 

visited the island annually. Annual visitation has since increased to approximately 15,000. Total 

island visitation (including all visitors to the island) peaked in the 1970s and again in the mid 

1990s with annual visitation approaching 18,000 island visitors (Figure 2). The distribution of 

visitors throughout the park’s operating season has been fairly consistent, with the majority of 

visitors coming in July and August (Figure 3). Visitors come to Isle Royale from all over the 

US, as well as from other countries. The majority of island visitors who stay in the wilderness or 

backcountry come from Michigan (41%), Minnesota (20%), Wisconsin (13%), and Illinois (6%). 
Visitor Use and Experiences

98 CHAPTER 3: AFFECTED ENVIRONMENT

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

50000

55000

60000

65000

70000

19741976197819801982198419861988199019921994199619982000

Year

Number of

Visitor

Ovenights

Number of

Visitors

Figure 2: Annual Island Visitation and Total Annual Visitor Overnights to Isle Royale 

Figure 3: Seasonal Distribution of Isle Royale Visitors.

Number of Island Visitors

0

1000

2000

3000

4000

5000

6000

April May June July August September October

Month in 2001

number of visitors
Visitor Use and Experiences

CHAPTER 3: AFFECTED ENVIRONMENT 99

The average length of stay for overnight visitors parkwide is 4.5 nights (including lodge guests). 

In the backcountry, hikers and paddlers average 5.3 nights, power boaters and sailors 4.5 nights. 

Figure 4 depicts the trend in annual visitation by backcountry overnights for different user 

groups over the last 30 years (Number of people x Number of nights they spent in the park’s 

wilderness and backcountry = Backcountry overnights). 

Figure 4: Backcountry Overnights by User Group

Visitor use patterns at Isle Royale are influenced in part by ferry schedules and capacities. The 

Isle Royale Queen III has a maximum capacity of 100 passengers but voluntarily carries no more 

than 80 and infrequently sells out at that point (pers. com., The Isle Royale Line, March 23, 

2004). The Voyageur II carries up to 39 passengers and ran to maximum capacity 29 times in 

2003, and the Wenonah carries up to 100 passengers and rarely if ever sells out (pers. com., June 

Lapp, the Isle Royale Line, March 26, 2004). The Ranger III carries up to 126 passengers, 

including park personnel and their guests, and typically sells out about a half dozen times each 

year between mid-July and mid-August. Because ferries schedule fewer trips to and from the 

island in Spring and Fall than in July and August (Table 6), visitation would always be 

somewhat lower during those times. 

Annual Backcountry Overnights Total and By User Group

(2 people camping for 4 nights = 8 backcountry overnights)

0

5

10

15

20

25

30

35

40

45

50

55

60

1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001

Year

Thousands of Nights

Total

Hikers

Motorboaters

Canoers

Kayakers

Sailors
Visitor Use and Experiences

100 CHAPTER 3: AFFECTED ENVIRONMENT

Table 6: Ferry Schedules and Capacities (from 2004, with schedules comparable other years)

Capacity May June July August September October

Voyageur 

II 39 M, W, Sat 

(5/8-31)

M, W, Sat M, W, 

Sat

M, W, 

Sat

M, W, Sat (9/1-9/18)

W & Sat (9/22-9/30)

W & Sat

Wenonah 100 No trips. Daily (6/19-

6/30)

daily daily Daily (9/1-9/19) No trips.

Isle 

Royale 

Queen III

70-80

M & F 

(5/14-5/31) 

M, T, Th, F, 

Sat.

M, T, Th, 

F, Sat., 

Sun.

daily Daily (9/1-9/5)

M & F (9/6-9/27)

No trips.

Ranger 

III 126

No 

passengers

Tues. & Fri. Tues. & 

Fri.

Tues. & 

Fri.

Tues. & Fri. (9/1-

9/11)

No 

passengers

Overnight Backcountry and Wilderness Use

The majority of people who visit Isle Royale National Park spend one or more nights in the 

park’s wilderness and backcountry camping, anchoring out, or docking. Backpackers are the 

largest user group, followed by powerboaters; other visitors travel by canoe, sailboat, or kayak. 

Historically, visitation to the island has been limited only by ferry capacities. During the peak 

visitor season ferries may sell out periodically, limiting access for people who are not traveling 

to the island by private boat or do not have flexibility in when they can visit. There is no limit on 

the number of private boats traveling to the park. However, the cost of reaching the park, either 

for a ferry ticket or the cost of a personal boat and fuel, may make Isle Royale inaccessible for 

some people, which limits public access to some extent. 

The majority of backcountry overnight visitors enter the park through Rock Harbor (55%) or 

Windigo (35%), with 10% entering at one of several remote entry points. Consistent with this, 

campsites are more heavily concentrated on the east and west ends of the island, with fewer and 

smaller campgrounds in the center of the main island. The vast majority of backcountry and 

wilderness visitors stay in one of the park’s designated campgrounds. Approximately 40% of 

parties traveling by powerboat or sailboat plan on sleeping onboard their boat at a campground’s 

dock rather than camping. 

The average group size for backcountry parties in 2003, a fairly representative year, was 3; the 

most common group size was 2 people. Six percent of parties were large groups (7-10 people) 

falling under the group reservation system, the majority of which are associated with organized 

trips through camps, outfitters, schools, or scout troops. In general, visitors to the park in May, 

September, and October travel in smaller groups than those visiting in June, July and August. 

About 70% travel in parties of 1 or 2 people, compared to less than 60% from June through 

August. Similarly, very few large groups (7-10 people) visit the park in May, September, and 

October. 

It is difficult and risky to try to predict future trends in visitation at Isle Royale. At certain points 

in the past it appeared that the trend line in visitation was decreasing, while at others it appeared 

to be increasing. However, in general, visitation to National Parks and Wilderness Areas has 

been increasing over recent decades and is predicted to increase as more people have free time 

with retirement and more have adequate income for such vacations. Some factors that may 

affect future visitation increases or decreases at Isle Royale include: the price of gas for boaters, 

the general popularity of wilderness-based recreation such as backpacking and kayaking, and 
Visitor Use and Experiences

CHAPTER 3: AFFECTED ENVIRONMENT 101

political and economic factors that determine whether international or local travel is preferable 

for vacationers.

Day Use in the Wilderness and Backcountry

People who visit Isle Royale just for a day comprised 13% of annual visitation to the island from 

1997-2003. In 2003 this was 1,912 people. The majority of these people (80-90%) visited 

Windigo and the west end of the island. The ferry from Minnesota to Windigo is the shortest trip 

and allows for the longest day visit to the island. Because day visitors are in the park for at most 

4 hours, they have little opportunity to travel far into the park’s wilderness and backcountry. 

People staying overnight at the Rock Harbor Lodge or within developed areas of the park and 

taking day excursions into the wilderness and backcountry are also considered day visitors for 

the purposes of wilderness and backcountry management. Day visitors who do not spend a night 

within the park account for approximately 10% of total island visitors; guests at the Rock Harbor 

Lodge account for 15-20%. 

Day excursions and formal day tours often use the same trails used by backpackers, paddlers and 

boaters who spend multiple days and nights in the park’s backcountry. Areas of the park frequented 

by day visitors include the trails and waterways in the vicinity of Windigo and Rock Harbor, as well 

as the destinations served by Rock Harbor Lodge’s organized tours aboard the M.V. Sandy. The 

NPS has offered ranger-led day hiking trips on several trails including the Windigo Natural Trail, 

Scoville Point Trail, Rock Harbor Trail, and Tobin Harbor Trail. With the M.V. Sandy the Lodge 

offers tours that may or may not be led by NPS rangers to several destinations in different 

management zones of the park. Tours within the Frontcountry include the Edisen Fishery, Rock 

Harbor Lighthouse and Raspberry Island; Backcountry zone tours include the Minong Mine in 

McCargoe Cove, Passage Island Trail, and the Hidden Lake and Lookout Louise Trail. The M.V. 

Sandy carries a maximum of 40 passengers. The NPS keeps statistics on group sizes for the tours 

that are led by rangers. A recent 3-year average of the Hidden Lake/Lookout Louise tours showed 

17 trips per season, 19 people per trip, and a maximum of 42 people on one tour. A similar look at 

Passage Island showed 11 trips per season, 21 people per trip, and a maximum of 38 people on one 

tour (pers. com., Smitty Parratt, NPS Chief of Interpretation). 

3.1.3 Social Conditions

To date visitation to Isle Royale’s wilderness and backcountry has never been limited by the 

NPS, though visitation may be limited to some extent when ferries sell out during the peak 

season. Parties of 7-10 people are required to secure reservations for designated group campsites 

before traveling to the park. Once they reach the park, parties with fewer than 7 people have 

received backcountry permits to camp in the campground of their choice, regardless of campsite 

availability. People are limited in where they can camp outside of designated campsites to 

protect sensitive wildlife, habitats, and cultural areas. In general, visitor freedom and flexibility 

has been maximized over management of visitor distribution to efficiently use camping space. 

Under the existing permitting system, current real-time information is not available on the 

number of parties permitted for each campground. Technological limitations prevent linking the 

permitting stations for real-time updates of when and where permits have been issued. Two 

permitting stations are located on the island, one in Houghton, one in Grand Marais, MN, and 

one aboard the Ranger III ferry, with none of the permitting computers connected.
Visitor Use and Experiences

102 CHAPTER 3: AFFECTED ENVIRONMENT

Visitor surveys conducted in 1996 and 1997 revealed minor problems and areas where 

backcountry and wilderness conditions could be improved on Isle Royale, including: motorboat 

noise, too many other hikers in campgrounds, difficulty in finding dock space or a vacant 

campsite or shelter, and too many watercraft on Lake Superior (Pierskalla and others, 1997 and 

1998). This information led the NPS to further explore conditions related to crowding and noise 

in the wilderness and backcountry, in an attempt to better understand when, where, and to what 

extent there were problems, and what actions might effectively improve conditions. This has 

become one of the primary focuses of the WBMP.

Campground Crowding

Isle Royale managers have defined crowding in campgrounds as a campground being overfull, 

with parties who cannot find an available campsite needing to either share a site with another 

party or break regulations and camp outside of a designated site. Permit data, visitor surveys, 

reports from NPS backcountry staff, and more recently, computer simulation modeling have 

been used to quantify this problem over the course of several years (Pierskalla and others, 1997 

and 1998; Mayo Kiely, 2001; Lawson and Manning, 2002 and 2003). 

Detailed analysis of backcountry overnight visitor distribution in 2001 has shed some light on 

these issues. During the 2 week peak in visitation in 2001 an average of 50 camping permits 

were issued per day, resulting in 203 permitted parties staying in campgrounds each night and on 

the busiest night, 231 parties were in campgrounds. With 244 campsites in the park, this is an 

average of campsite use at 83% of capacity and a maximum use at 95% of capacity. Under these 

conditions an average of 24% of those parties would have needed to double-up campsites in 

overfull campgrounds on a nightly basis. This estimate is consistent with data collected from 

visitors and NPS backcountry personnel on the frequency of campsite sharing in 1997 and 2000 

(Pierskalla and others, 1998; and Mayo Kiely, 2001). Table 7 summarizes campground 

crowding conditions at different visitation levels, based on average number of permits issued per 

day.

Table 7: Frequency of Parties Sharing Campsites at Different Visitation Levels (based on 

computer simulation modeling with actual 2001 visitation levels)

Time of Season

Average number of 

permits issued per day 

in 2001

Average % of parties 

sharing campsites

Off-season (May, June, September and October) 12 0.4

July and August 39 8.7

2 week peak in visitation 50 24.1

July and August excluding the peak 2 weeks 36 6.4

How does this happen when the total numbers of camping parties is below the park’s total 

camping capacity? Campers are permitted for campgrounds based on their itinerary preferences, 

not based on site availability; in fact, under the current permitting system the park does not have 

accurate information about site availability at the time of permitting. Additionally, permits are 

issued for flexible itineraries so visitors may change their camping itineraries at any time 

throughout their trip, without changing their permits. As a result, more parties may end up in a 

campground than there are campsites, while other campgrounds may have empty campsites. For 
Visitor Use and Experiences

CHAPTER 3: AFFECTED ENVIRONMENT 103

example, 8 parties may arrive for the night at a campground with 6 campsites. Two parties 

cannot find empty campsites and 4 parties end up doubling-up for the night. Meanwhile, at 

another campground with 5 campsites, only 3 parties arrive for the night. Although there are 

empty campsites available on even the busiest nights, visitors are not effectively dispersed to 

campgrounds with available space, and may end up in overfull campgrounds. Continuing on to 

the next campground may not be an option given time and distances between campgrounds, and 

there are no assurances that space would be available at the next campground. 

Surveys and computer modeling have also helped to identify where in the park crowding is an 

issue. In general, campgrounds within the Rock Harbor Channel tend to be more heavily used, 

and more over-crowded than others in the park. However, during the peak 2 weeks in visitation 

most campgrounds appear to be used up to their capacities (although many may not be overfull, 

they are full with little or no space to accommodate additional use.) In 2002 NPS personnel used 

this information to scout for feasible campground expansions or options for creating new 

campgrounds. This scouting was guided by several goals, including: 1) maintain or improve the 

quality of existing campsites, considering privacy, view, and shelter from human sounds; 2) 

avoid impacts to sensitive cultural and natural resources; 3) consider appropriate campground 

sizes based on management zones; 4) locate new campsites in suitable terrain, considering soils, 

slope, and screening; and, 5) consider communal campsites as well as individual tent sites, and 

options for tent platforms. Table 8 illustrates to what extent different campgrounds were 

permitted over their capacities in 2001, the expansions in campground capacities that would have 

been required to accommodate demand that year, and feasible options for new campsites that 

would adhere to the five goals listed above. 

Park staff inform visitors of the likelihood of finding overcrowded campgrounds during the busy 

times, warning visitors of the probability of needing to double-up in campsites if they choose to 

visit during these busier times. However, this issue remains one of the consistent problems 

raised by the public. People may choose to socialize with other campers, or to share their 

campsites, but the concern is when parties are forced to double-up for lack of available 

campsites.

Aside from the sheer numbers of parties in campgrounds, other factors are also important in how 

crowded people feel, or what level of privacy and solitude they can find in Isle Royale’s 

campgrounds. People’s behavior and the design of campsites are important factors. Leave-NoTrace is a focal point of Isle Royale’s educational program, sharing with visitors the importance 

of being aware of and minimizing their impacts on other people. Some of Isle Royale’s 

campsites are well spaced, with abundant screening between sites and private water access 

points. Other sites are within sight and sound of other campers, dramatically reducing privacy 

and feelings of solitude. Improving the quality of campsites with adequate screening, spacing,

and distance from docks is an ongoing goal of campground maintenance. 
Visitor Use and Experiences

104 CHAPTER 3: AFFECTED ENVIRONMENT

Table 8: Frequency and Extent of Campgrounds Permitted Over their Capacities in 2001 and 

Feasible Campsite Additions (from 2001 permit data, based on individual parties and shelters or 

tent sites only, not groups or group sites) 

Campground

Number of 

Individual 

tent sites and 

shelters

Number nights 

permitted over 

capacity in 

2001

Number campsite 

additions needed 

to meet peak 

demand

Number of known feasible

campsite additions (including 

new GMP campgrounds)

Beaver Island 3 3 1 3 (Washington I., per GMP)

Belle Isle 7 3 3 3 (Crystal Cove, per GMP)

Birch Island 2 9 3 3 (new McCargoe Cove, per 

GMP)

Caribou Island 3 26 9 0

Chickenbone East 3 21 4 2

Chickenbone West 6 26 6 0

Daisy Farm 22 4 9 3

Desor North 3 23 8 1

Desor South 7 2 2 3

Duncan Bay 3 10 2 0

Duncan Narrows 3 4 5 0

Feldtmann Lake 5 24 13 3

Grace Island 2 14 7 3 (Johns I., per GMP)

Hatchet Lake 5 15 6 3

Hay Bay 1 39 8

3 (Wright I., per GMP) + 

3 (Fishermans Home per 

GMP)

Huginnin Cove 5 8 3

Intermediate Lake 3 0 0 0

Island Mine 4 25 5 4

Lake Richie-Canoe 3 6 5 0

Lake Richie-Hike 4 17 6 0

Lake Whittlesey 3 0 0 0

Lane Cove 5 19 6 0

Little Todd 4 4 2 0

Malone Bay 5 6 4

McCargoe Cove 9 18 11 3

Merritt Lane 2 14 4 0

Moskey Basin 8 25 7 0

Pickerel Cove 1 7 1 0

Rock Harbor 20 6 9 0

Siskiwit Bay 6 18 7 5

Three Mile 12 9 7 5

Todd Harbor 6 11 7

Tookers Island 2 18 4 0

Washington Creek 15 1 1 0

Wood Lake 3 3 1 0
Visitor Use and Experiences

CHAPTER 3: AFFECTED ENVIRONMENT 105

Crowding at Docks in the Backcountry

Currently, Isle Royale allows rafting off at docks when dock space is unavailable and docked 

boaters are willing to have another boater (with a valid backcountry permit) raft off their boat. 

While on the whole, docks throughout the park are not usually crowded, there are specific 

campgrounds with docks that are more apt to run out of dock space than others, including 

Caribou Island, Grace Island, and Hay Bay (see Table 9.) In order to determine visitor concern 

about crowding at docks, Isle Royale included questions in its 1996 and 1997 visitor surveys, 

and in one of its WBMP Newsletters.

1996 Visitor Survey

During the 1996 visitor survey at Isle Royale, backcountry visitors, powerboaters, and day 

visitors were asked to identify and rank the importance of perceived problems at the park. A 

total of 190 powerboaters, and 798 backcountry visitors were surveyed. 50.8% of the

powerboaters surveyed identified “finding an available docking spot at docks” as a moderate to 

serious problem. In addition, 18.6% believed that “having to allow unknown boats/parties to raft 

off of my docked boat at night” was a moderate to serious problem. Over 72% of powerboaters 

who responded to these two questions had boated to Isle Royale more than once. 5.8% of 

powerboaters surveyed felt that “noisy people at campgrounds with docks” was a moderate to 

serious problem, and 5% felt the same about “motorboat noise in narrow harbors and bays.” 

19.4% of the powerboaters supported “limit(ing) the number of boats so they do not exceed 

available dock and anchorage space.” 77.7% of the respondents to this management question 

had been to Isle Royale more than once (Pierskalla et al, 1997.) 

Over 96% of the 798 backcountry visitors (non-powerboaters) surveyed felt that finding 

available dock space, and having to allow rafting off were not problems. However, 20.9% felt 

that “noisy people at campgrounds with docks” was a moderate to serious problem, versus 5% 

who felt the same about “noisy people at campgrounds without docks.” In addition, 29.8% felt 

that motorboat noise in narrow bays and harbors was a moderate to serious problem (Pierskalla 

et al, 1997.) While it is not surprising that the majority of backcountry visitors would not be 

concerned with dock space and rafting off per se, it is also fair to say that the indirect impacts of 

crowding at campground docks (noise levels where boats congregate) may be a moderate to 

serious concern to 20-30% of them 

1997 Visitor Survey

The 1997 Visitor Survey asked questions and divided respondent groups in a similar manner to 

the 1996 survey. One difference in the 1997 survey was the division of user groups by zone 

(Frontcountry, Backcountry, Wilderness Portal, and Primitive). In the Backcountry group, 8% 

of powerboaters felt that the park should “limit the number of boats so they do not exceed 

available dock space.” 29.6% felt that the park should “limit the number of dock spaces 

available.” In both the Backcountry and Wilderness Portal groups, the majority of powerboaters 

felt that the number of boats at the same dock, number of boats rafting off their own boat, and 

the amount of noise generated by other boaters docked near them were all within acceptable 

limits (Pierskalla et al, 1998.)
Visitor Use and Experiences

106 CHAPTER 3: AFFECTED ENVIRONMENT

Non-powerboaters responded to survey questions quite differently. 84.8% felt that to “limit the 

number of boats so they do not exceed available dock space” ranked as acceptable to very 

acceptable as a management action. Likewise, 87.7% felt that not allowing boat numbers to 

exceed available anchorage space was acceptable to very acceptable. 77.9% thought that it 

would be acceptable to very acceptable to limit the number of dock spaces available. When 

interviewed about their current experience at the park however, the majority of nonpowerboaters across all use zones felt that the number of powerboats docked and anchored out 

during their campground stay was acceptable, and that the number of encounters with 

powerboaters docked at campgrounds where non-powerboaters spent the night was no more than 

expected (Pierskalla et al, 1998.)

Table 9: Overcrowding at campgrounds with only water access, 2001

Campground # Nights 

>Capacity, 

2001

Max # of 

Parties 

Permitted (# 

over capacity)

Capacity 

(Individual 

Sites)

Beaver Island 3 4 (+1) 3

Belle Isle 3 10 (+3) 7

Birch Island 9 5 (+3) 2

Caribou Island 26 12 (+9) 3

Duncan Bay 10 5 (+2) 3

Duncan Narrows 4 8 (+3) 3

Grace Island 14 9 (+7) 2

Hay Bay 39 9 (+8) 1

Merritt Lane 14 6 (+4) 2

Tookers Island 18 6 (+4) 2

Table 9 above shows campgrounds that are accessible only from the water. While some 

campsites would have been occupied by paddlers, it can be safely assumed that dock capacity 

was exceeded (rafting off occurred) at least a portion of the nights where a campground capacity 

was exceeded. 

Campgrounds with docks that can also be accessed by trail were not included, because 

campground crowding by hikers versus boaters could not be separated. Visual observation by 

park staff, however, has verified that docks at these campgrounds also occasionally exceed 

capacity during busy periods (pers. com., Kangas, 2005.)

In another attempt to assess visitors’ feelings about crowding at docks, WBMP Newsletter #4 

requested that respondents give their opinions on rafting off (whether they ever had, and if so, 

was it a positive or negative experience.) The number of responses was low. Of those who had 

rafted off and did respond, 15 said that rafting off was a positive experience, 11 said that they 
Visitor Use and Experiences

CHAPTER 3: AFFECTED ENVIRONMENT 107

had no opinion either way, and 5 had a negative experience (Isle Royale WBMP Newsletter, 

2002.)

Trail Crowding

Trail crowding appears to be a less salient public concern than campground crowding, which is 

consistent with general research in wilderness recreation (Manning 1999). However, crowding 

along trails, quantified through the number of trail encounters, does remain an important factor in 

social conditions in the park’s wilderness and backcountry. Table 10 summarizes known trail 

encounter rates by management zone (Mayo Kiely 2001). Managing over-crowding in 

campgrounds may also serve to manage crowding along trails, depending on the management 

action taken. The NPS will continue to monitor trail encounters to test this. 

Table 10: Rates of Trail Encounters Reported by Hikers and NPS Rangers in 2000 (see 

Appendix D, Map 6 for Management Zones)

Management Zone(s) that trail 

section passes through

Number of parties 

encountered per day

Number of people

encountered per day

Backcountry

Average 2.9 8.1

Minimum 0 0

Maximum 19.0 58

Backcountry & Primitive

Average 3.1 8.7

Minimum 0 0

Maximum 9 32

Backcountry & Frontcountry

Average 5.0 14.0

Minimum 0 0

Maximum 20.0 48.0

Primitive

Average 1.1 2.5

Minimum 0 0

Maximum 5 15.0

3.1.4 Visitor Facilities and Services

Currently the NPS maintains 36 campgrounds at Isle Royale with an additional 5 planned with 

implementation of the GMP. Each campground has designated campsites and an outhouse, some 

have a dock, shelters, and picnic tables. The campgrounds range in size from 1 to 25 campsites. 

Table 11 outlines each campground and facilities available. 

Campsites within the campgrounds consist of either a rustic shelter or tent pads and a flattened 

eating area. Shelters and individual tent sites are designed to hold one party with up to 6 people. 

Tent sites have (2-3) 12 by 12 foot tent pads clustered within a few feet of each other. 

Designated large group sites are designed with 4 or 5 closely clustered 14 by 14 foot tent pads 

for one group with 7-10 people. Although campsites can and do hold more than one party when 

campgrounds are overfull, typically there is no screening between tent pads and they sit within a 
Visitor Use and Experiences

108 CHAPTER 3: AFFECTED ENVIRONMENT

few feet of each other so there would be little to no privacy for multiple parties sharing sites. 

Similarly, shelters are one open area with 3 wood walls and one screen wall and do not offer any 

privacy for parties sharing a single shelter. 
Visitor Use and Experiences

CHAPTER 3: AFFECTED ENVIRONMENT 109

Table 11: Campgrounds and Associated Facilities (1 Potential Wilderness, 2 planned for removal per the GMP)

Campground

Management 

Zone Wilderness

?

Consecutive 

Night Stay 

Limit

# Individual 

tent sites # Shelters

# 

Group 

Sites

Dock

?

Picnic 

Tables?

Campfires 

permitted?

Boat 

generators 

permitted?

Beaver Island Backcountry Yes 3 0 3 0 Yes Yes No Yes

Belle Isle Wilderness Portal No 5 1 6 0 Yes Yes Yes Yes

Birch Island Backcountry Yes 3 1 1 0 Yes Yes No No

Caribou Island Backcountry Yes1 3 1 2 0 Yes Yes No Yes

Chickenbone East Backcountry Yes 2 3 0 1 No No No No

Chickenbone West Backcountry Yes 2 6 0 3 No No No No

Chippewa Harbor Wilderness Portal Yes 3 2 4 1 Yes Yes Yes No

Daisy Farm Wilderness Portal No 3 6 16 3 Yes Yes No No

Desor North Primitive Yes 2 3 0 0 No No No No

Desor South Backcountry Yes 2 7 0 3 No No No No

Duncan Bay Backcountry Yes 3 1 22 0 Yes2 Yes Yes No

Duncan Narrows Primitive Yes 3 1 2 0 No No Yes No

Feldtmann Lake Backcountry Yes 2 5 0 2 No No No No

Grace Island Backcountry Yes 3 0 2 0 Yes Yes No Yes

Hatchet Lake Backcountry Yes 2 5 0 3 No No No No

Hay Bay Backcountry Yes 3 1 0 0 Yes Yes No Yes

Huginnin Cove Backcountry Yes 3 5 0 0 No No No No

Intermediate Lake Primitive Yes 2 3 0 0 No No No No

Island Mine Backcountry Yes 3 4 0 2 No No Yes No

Lake Richie Canoe Backcountry Yes 2 3 0 0 No No No No

Lake Richie Hike Backcountry Yes 2 4 0 2 No No No No

Lake Whittlesey Primitive Yes 2 3 0 0 No No No No

Lane Cove Primitive Yes 3 5 0 0 No No No No

Little Todd Primitive Yes 2 4 0 0 No No Yes No

Malone Bay Wilderness Portal No 3 0 5 2 Yes Yes Yes Yes

McCargoe Cove Backcountry No 3 3 6 3 Yes Yes Yes No

Merritt Lane Backcountry Yes 3 1 1 0 Yes Yes No No

Moskey Basin Backcountry No 3 2 6 2 Yes Yes No No

Pickerel Cove Primitive Yes 2 1 0 0 No No No No

Rock Harbor Frontcountry No 1 11 9 3 Yes Yes No Yes

Siskiwit Bay Backcountry No 3 4 22 3 Yes2 Yes Yes No

Three Mile Backcountry No 1 4 8 3 Yes2 Yes No No

Todd Harbor Backcountry Yes 3 5 1 3 Yes Yes Yes No

Tookers Island Backcountry Yes 3 0 2 0 Yes Yes No No

Washington Creek Frontcountry No 3 5 10 4 No No No Yes

Wood Lake Primitive Yes 2 3 0 0 No No No No
Visitor Use and Experiences

110 CHAPTER 3: AFFECTED ENVIRONMENT

The overall size of a campsite is a combination of official tent pads, unofficial tent pads that have 

become established by repeated use, and other areas trampled by repeated use for things like 

cooking, sitting, and storing gear. The cumulative area of campsites increased by approximately 

10% from 1996 to 2002. The estimated area of exposed soil within these sites increased by 

approximately 50% in the same period. These changes, outlined in Table 12, are caused 

primarily by people using areas outside of the intended campsite boundary. However, there are 

likely several contributing factors, such as maintenance and design of campsites that do not 

clearly establish the campsite boundaries, more than one party doubling up in a site intended for 

1 party, and tent pads that may be unappealing to campers because of being wet, uneven, or some 

other reason. 

Table 12: Area and Exposed Soil of Isle Royale Campsites 1996-2002. Measurements are in 

square feet. 

Type of 

site Number

Mean Area

Mean 

Amount 

Exposed soil

Range of 

site area

Range of 

amount 

exposed soil

Cumulative 

area

1996 2002 1996 2002 1996 2002 1996 2002 1996 2002

Individual 

tent site 113 650 730 250 390 160-

1520

140-

1680

6-

1060

3-

1440 73,440 82,120

Group 

tent site 43 1570 1670 620 940 710-

2570

660-

2500

28-

1910

30-

2180 67,500 71,740

Shelter 88 420 480 130 180 130-

1270

200-

1380 8-560 8-650 37,030 42,300

In total there are 165 miles of trails and portages on Isle Royale. All but a few miles of trail are 

within designated wilderness. All trails are maintained within standards that minimize erosion 

and trail widening, concentrating foot traffic while still providing reasonable access. Trails are 

designed and maintained with an 18 inch tread, or up to 26 inches on a side slope, and brushed 

out with a 6 foot wide trail corridor. Water bars, corduroy, stepping stones, turn pike, retaining 

walls, check dams, boardwalk and bridges are all used to control erosion and minimize trail 

widening. Portions of the Ishpeming and Minong Trails are maintained to a more primitive 

standard with narrower trail corridors, more frequent wet trail crossings across beaver dams and 

wetlands, and sections of trail that may be more challenging to follow across ridge tops. 

Two remote ranger stations are maintained in the park’s backcountry, at Malone Bay and 

Amygdaloid Island. Facilities at these stations include docks, fuel storage, visitor shelters with 

park information, and ranger residences with associated utilities support (solar power, water 

treatment, and gas-powered generators for pumping boat fuel). Services offered include medical 

and emergency assistance and park information. Backcountry permitting and payment of visitor 

fees are not available at these remote ranger stations. 

Three fire towers are within the park’s wilderness; all were built in the 1960s. The NPS no 

longer relies on these towers for fire monitoring, but they continue to be maintained to varying 

degrees for research equipment, a radio repeater, and temporary storage of equipment or shelter 

for backcountry personnel. Two of the towers, Ojibway and Feldtmann, offer expansive island 

and lake views for visitors interested in climbing the towers, though the tops of the towers are 
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CHAPTER 3: AFFECTED ENVIRONMENT 111

only open in the presence of NPS personnel. Ishpeming Tower no longer reaches above the 

treetops, so the view from this tower is limited. 

The NPS maintains communications structures within Isle Royale’s wilderness and backcountry. 

Communication facilities are critical for park operations and providing for human safety in a 

park such as Isle Royale where communication often depends on radios, cell phones, and satellite 

phones. Currently the Mount Ojibway fire tower, within designated wilderness, includes a radio 

repeater and satellite transmitter powered by photovoltaic cells. Communications technology at 

a remote monitoring station on Mount Ojibway also relays monitoring data. 

The NPS maintains contracts with private businesses and organizations to provide many public 

services to Isle Royale visitors. These are managed through concessions contracts and Incidental 

Business Permits. Four ferries and one seaplane provide transportation to the island for visitors 

not traveling by private boat or plane. The Ranger III ferry is operated by the NPS. The Rock 

Harbor Lodge offers several services in addition to lodging and dining: 1) water taxi service, 

transporting visitors between Rock Harbor and various docks throughout the park’s backcountry, 

2) fishing charters; 3) boat tours to cultural and scenic sites; 4) canoe, kayak and motorboat 

rentals; and 5) small stores and showers in Windigo and Rock Harbor. Other private businesses 

offer fishing charters, dive charters, and guided recreational trips in the park. In 2003 the NPS 

issued 44 Incidental Business Permits for Isle Royale, with the majority of those going to 

backpacking organizations such as camps and outfitters. 

The character of wilderness is an unseen presence capable of refocusing our perception 

of nature and our relationship to it. It is that quality that lifts our connection to a 

landscape from the utilitarian, commodity orientation that dominates the major part of 

our relationship with nature to the symbolic realm serving other human needs...Every 

management decision against an action or technology that might degrade the wilderness 

condition serves to uphold and strengthen the character it is seen to have. Every decision 

to forgo actions, technologies, or conveniences that have no seeming physical impact but 

detract from our commitment to wilderness as a place set apart enhances wilderness and 

agency character more, because sacrifice for an ideal is the strongest gesture of respect. 

(Federal Register/ Vol. 66, No. 10/ 2001 p. 3729-3730)

Although difficult to measure, wilderness character consists of multiple components, including a 

state of naturalness and an “untrammeled” state, as well as conditions for solitude, primitive and 

unconfined experiences, personal challenge, self sufficiency, and an escape from the reminders 

of our modern society. As well as a state, wilderness character denotes an intention and a 

commitment to the spirit of an intangible. 

3.2.1 Naturalness

Naturalness in wilderness refers to the area being influenced primarily by the forces of nature, 

rather than human efforts to manipulate, control or direct in attempts to provide particular 

benefits. This would consider the systems and functions on an ecosystem scale as well as a 

3.2 Wilderness Character
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112 CHAPTER 3: AFFECTED ENVIRONMENT

micro scale by habitat. On a species level, naturalness considers the numbers, populations, 

cycles, and interactions of individual species in a self-willed manner. Relevant human 

influences on naturalness may be direct or indirect, and may result from actions taken within or 

outside of the wilderness.

There are several examples of intentional and unintentional human actions that have influenced 

the natural ecology of Isle Royale. During the park’s mining period, fires were intentionally 

started to expose bedrock and minerals. More recently, through the mid 1980’s the NPS 

followed a policy of suppressing wildfires. Both of these policies have had a significant effect 

on the forest ecology of the island, influencing forest structure, composition, and function 

throughout the park. The unintentional introduction of canine parvovirus is credited with the 

crash in the island’s wolf population in the 1980’s, with associated effects seen in the moose 

population and the island’s forest ecology. The unintentional introduction and spread of invasive 

exotic species has the potential to have significant ecosystem impacts in the future. 

On a smaller scale, the development of trails and campgrounds significantly alters the vegetation, 

wildlife and soils within the impacted areas. Additionally, research practices within the park that 

include trapping and radio collaring wolves, capturing and banding loons, handling bats and 

eaglets, and other invasive research methods detract from the “self-willed manner” and wildness 

of individual wildlife. This WBMP addresses these issues by identifying means of minimizing 

such impacts or outlining guidelines for making decisions that may impact wilderness character; 

research practices would be included in the Minimum Tool Decision Tree (Appendix G).

Naturalness also considers the effects of external human influences. Relevant concerns on Isle 

Royale include air pollution, influences on the mainland that may limit species recruitment to the 

island, and impacts to migratory species in their wintering grounds. All of these may have an 

effect on the interactions between wildlife and their habitats, the natural cycles of populations 

and succession, and long-term changes in the island’s ecosystem. However significant, these 

external influences are beyond the scope of the WBMP, though the NPS is committed to 

fostering research and partnerships that will continue to address these issues into the future. 

3.2.2 Wilderness Experiences

Wilderness experiences are largely self-directed and will be individual, based on one’s state of 

mind. However, wilderness managers have an obligation to provide a setting in which people 

may find opportunities for solitude, primitive and unconfined experiences, risk, challenge, and 

self-sufficiency. Important components which can be managed include privacy, isolation, 

freedom from constraints, and an absence of the reminders of modern society and human 

distractions such as noise, large groups, and mechanization. 

Although the majority of visitors to Isle Royale’s backcountry and wilderness hike on trails and 

camp in designated campgrounds with bridges, signs, outhouses, established tent pads, and other 

conveniences, the majority of the park’s land base is within the Pristine Zone where recognizable 

human influences and reminders are minimal; where it is possible to travel for days without 

encountering another person. Even within the designated trail system and in designated 

campgrounds, it is possible to find superlative opportunities for solitude. With unpredictable 

weather, few ferries, and limited services provided by the NPS or concessions, early Spring and 
Wilderness Character

CHAPTER 3: AFFECTED ENVIRONMENT 113

late Fall offer options of traveling for days alone with the added challenges of increased selfsufficiency, less maintained trails and potentially severe weather conditions. 

Isle Royale offers a range of wilderness opportunities throughout the visitor season and around 

the park, with options available for those seeking more social or more solitary experiences, the 

conveniences of well maintained trails and campgrounds or the challenges of off trail travel, and 

options for traveling around the park by motorboat, by foot, or by paddle. Additionally, the 

lodge, day trips on ferries, and 2 campgrounds adjacent to developed areas offer opportunities to 

experience the park’s wilderness on day trips without the need for wilderness camping skills. 

Existing NPS regulations and developments may detract from the wilderness character of 

recreation opportunities on Isle Royale, to some extent limiting unconfined experiences and selfsufficiency while adding reminders of modern society. Regulations that limit human activities 

within Isle Royale’s wilderness include fire bans, prohibitions on collecting plants and minerals, 

area closures, and required permitting. Such regulations were enacted to protect vulnerable 

natural and cultural resources in the park, as well as to protect appropriate wilderness 

experiences and wilderness character. Campgrounds with shelters and outhouses, and trails with 

bridges and signs succeed in making the wilderness more accessible and minimizing the extent 

of human impacts, but also compromise wilderness character as human developments. Human 

noises may also detract from the natural sounds of a wilderness. On Isle Royale such noises 

include the sounds of motorboats, generators, aircraft over-flights, and mechanized maintenance 

equipment, which can carry a great distance into the park’s wilderness. All of these concerns are 

within the scope of the WBMP.

Isle Royale National Park is a forested archipelago surrounded by the deep, cold waters of the 

largest of the Great Lakes. It is located in a zone of transition, or ecotone, between two major North 

American ecosystems or biomes – the boreal forest and northern hardwood forest. Boreal forest 

vegetation dominates the northeastern part of the island where forest vegetation is strongly 

influenced by lake effect climate, shallow soils, and windthrow. Northern hardwoods are more 

dominant on Isle Royale's southwestern portion, where soils are deeper and inland areas are less 

affected by Lake Superior influences than the exposed ridges and peninsulas of the northeastern 

end.

Detailed data of historical weather patterns at Isle Royale are sparse. Generally speaking, the 

climate of the park, strongly affected by Lake Superior, is characterized by short, cool summers and 

long, cold winters. Due to the moderating influence of the lake, summers are cooler and winters are 

warmer than the nearby mainland. Precipitation falls year-round, mostly as rainfall, averaging 

approximately 30 inches per year. Snow typically accumulates from mid-November through April. 

Fog is frequent near the lakeshore, especially in the spring.

Isle Royale’s biodiversity (except for birds) is generally lower than that of the mainland because the 

islands’ isolation has restricted migration of terrestrial organisms from outside populations. For 

3.3 Natural Resources
Natural Resources

114 CHAPTER 3: AFFECTED ENVIRONMENT

example, there are approximately 18 species of mammals documented on Isle Royale, far fewer 

than the number of mammals on the adjacent mainland. In addition, the limited land area of the 

archipelago likely impedes the long-term survival of viable populations of larger organisms with 

larger home ranges or territories. Isle Royale is thus a fascinating case study testing theories of 

island biogeography that attempt to explain lower species numbers (particularly mammals) and 

genetic change in some taxa (like fish in inland lakes) due to long-term isolation from other 

populations. Wolf and moose populations, together on the island only since the late 1940's, have 

become a classic study in predator/prey relationships. Other significant wildlife studies include 

studies of mercury contamination, the life history and conservation of loons, the life history of 

boreal chorus frogs, and monitoring of beaver, songbird, frog and toad, and raptor populations. For 

many people these wildlife populations and their conservation are at the essence of Isle Royale’s 

wilderness character. 

Adversely impacted natural resources are of concern for ecological health and integrity as well as 

for park visitors’ perceptions. Visitors have varying tolerances for noticeably impacted resources, 

and at some point degraded conditions will negatively affect their experiences in the park. 

3.3.1 Geology and Soils

The rocks seen on the Isle Royale archipelago today bear witness to over a billion years of 

geologic processes, including successive volcanism, sedimentation, uplift, and erosion. The 

islands’ bedrock sequence consists of thick layers of lava and sedimentary rocks that have been 

tilted toward the southeast; linear ridges oriented along a northeast-southwest axis are the eroded 

edges of individual layers of the sequence. Significant minerals in Isle Royale are copper, 

greenstones, datolite, and agates. The oldest rocks in the archipelago date back to the 

Precambrian era. 

Igneous rocks, in particular volcanic ones, dominate the geology of Isle Royale, but sedimentary 

deposits of sandstones and conglomerates are exposed on the southwestern end of the island. 

Evidence of Pleistocene glaciation is visible throughout the island and includes bedrock 

abrasions and striations, deposits of glacial till and landscape features like drumlins and 

moraines. This extensive Pleistocene glaciation has left a legacy of thin soils and numerous lakes, 

swamps, and bogs. Higher water levels in Lake Superior in the geologic past are evidenced by 

inland beach ridges. 

Fifteen soil series and 14 distinct soil associations have been mapped and described at Isle Royale 

(Shetron and Stottlemeyer, 1991). By and large, the soils on Isle Royale are derived from deposits 

and outwash left by retreating glaciers and meltwater. Glacial till deposits vary in thickness across 

the island and are much deeper toward the southwestern end. Soils in the northeastern portion of 

the island are thin and highly organic; these shallow soils are a major influence in the dominance of 

boreal forest vegetation in the northeastern part of Isle Royale. This thin mantle of organic soil, 

plus erosion and soil-burning fires, have combined to expose large expanses of bedrock, especially 

along ridges. The absence or paucity of soil is probably a limiting factor for vegetation in rocky 

areas. In contrast, toward the southwestern end of the park, soils are deeper, better developed and 

less organic. These conditions favor northern hardwoods. 
Natural Resources

CHAPTER 3: AFFECTED ENVIRONMENT 115

Human impacts to soils on a localized scale (on and adjacent to trails and campsites) include 

abrasion and loss of organic matter, exposure of soil through vegetation loss, compaction of soil, 

sterilization of soils beneath campfires, and changes in soil chemistry from human waste and 

organic waste (including food scraps, dishwater, and toothpaste). These impacts would affect 

soil porosity, biota, and/or nutrient cycling, which in turn impact vegetation, water absorption 

and runoff, and erosion. Park visitors may also perceive visible erosion or exposed soil as 

aesthetically undesirable. These impacts have been well researched and documented in 

recreation areas around the country and can be reasonably inferred to conditions in Isle Royale’s 

designated and undesignated trails and campgrounds (Leung and Marion 2000, Hendee and 

Dawson 2002). Although these adverse impacts would affect a very small portion of Isle 

Royale’s total acreage, the effects would be significant in and adjacent to the 165 miles of trails 

and 244 campsites in the park. From the perspective of healthy soils, compacted trail tread and 

campsite pads at a minimum alter drainage patterns and at maximum lead to barren or severely 

eroded conditions. 

3.3.2 Aquatic Resources

Aquatic habitats account for more than three-quarters of Isle Royale National Park’s area, and 

encompass a wide spectrum of environments, from the cold, deep waters of Lake Superior to inland 

streams, beaver ponds, lakes, marshes, swamps, wet meadows, and bogs. The park includes 

438,008 acres of Lake Superior, in addition to about 200 inland lakes and ponds totaling some 9,050 

acres. There are approximately 158 linear miles of perennial streams on Isle Royale.

In spite of the ecological importance of aquatic environments, data documenting their condition in 

the park have been rather scarce to date, although this is beginning to change. Baseline inventories 

of some inland lakes’ fish communities and limited native freshwater mussel surveys have been 

completed, and recommendations for additional data collection and studies will be included in the 

park’s upcoming Fish Management Plan, and its Water Resources Management Plan. 

Despite Isle Royale’s remoteness and the lack of industrial or municipal discharges into its inland 

waters, several air-borne pollutants, capable of being transported long distances in the atmosphere, 

have been documented in the park’s waters, sediments, flora, and fauna. These include sulfur and 

zinc, mercury, organochlorines, and herbicides. Mercury, for example, has been found in the 

park’s Common Loons, although at levels lower than those documented in loons in most other parts 

of the country. Several of these heavy metals and organic compounds are subject to 

biomagnification; that is, reaching increasingly greater concentrations in organisms higher on the 

food chain. 

Levels of toxic contaminants in the park’s inland lakes are a major concern. Fish monitored in 

1992-94 did not exceed State of Michigan advisory levels for human consumption, but in a 1995-96 

fisheries inventory, some of the fish sampled in six of the park’s inland lakes did exceed state 

advisory levels for mercury in particular (Kallemeyn, 2000.) 

The Lake Superior portions of the park, particularly its bays and channels, are used by 

motorboats. Motors are prohibited on the park’s inland lakes. Accidental oil, fuel and sewage 

discharges from boats can all damage water quality locally. Improper hygiene and human waste

(i.e. fecal matter) disposal methods on the part of backcountry users can also cause localized 
Natural Resources

116 CHAPTER 3: AFFECTED ENVIRONMENT

bacteriological contamination on inland streams, ponds, and lakes. Of additional concern are 

contaminants associated with current and past maintenance activities, such as leaching from 

chemically treated lumber used for boardwalks and bridging, and spills of bar oil and fuel from 

chainsaws. Vegetable-based products have been used to minimize adverse impacts. 

The park has experienced minor infestations from alien aquatic species, such as the sea lamprey 

(Petromyzon marinus) and zebra mussel (Dreissena polymorpha) and potentially the ruffe 

(Gymnocephalus cernuus). However, the spiny water flea (Bythotrephes cederstroemi) is observed 

almost annually in the vicinity of Rock Harbor, and is a concern for spreading and altering the 

aquatic food chain, especially if it were to reach the inland lakes. The park has identified the 

introduction and spread of exotic species as an issue of serious concern for the park and deserving 

of preventative measures.

Fisheries and Aquatic Life

Isle Royale’s Lake Superior and inland lakes fisheries may well be the most nationally significant 

natural resources of the park; 61 species are known to be present. The park’s lake trout (Salvelinus 

namaycush namaycush) population is acknowledged as the best example of a rehabilitated lake trout 

stock in all of Lake Superior. This population is now regarded as the healthiest as well as the most 

genetically diverse in the Lake. It is also the object of most fishing efforts in the Lake Superior 

portion of Isle Royale. 

The Isle Royale population of the extremely rare coaster brook trout (Salvelinus fontinalis) is one of 

only two to three known reproducing populations in U.S. waters. In fact, eggs from this population 

have been used by the U.S. Fish and Wildlife Service (USFWS) in efforts to re-establish the coaster 

brook trout elsewhere in the Great Lakes (USFWS, 1998). 

Information on the other fish species in the park’s Lake Superior waters, particularly the non-game 

species, is scanty. Species known to be present include herring, whitefish, suckers, sturgeon, 

northern pike, walleye and yellow perch. Lake herring (Coregonus artedii arcturus) appeared to be 

making a strong comeback in the early 1990’s, but by 2000 appeared to have dipped again. 

The most common sport-fishing fish species in the park’s inland waters are northern pike, yellow 

perch, walleye, rainbow trout, and brook trout. The most recent assessment of fish communities 

in the park’s inland lakes occurred in 1995-1997. Recently, surveys and inventories have also 

been undertaken for zooplankton and native mussels within Isle Royale’s inland waters, initially 

identifying unusually large populations of native mussels, in what are thought to be a relatively 

pristine state in comparison to mainland populations.

Human impacts to the park’s fish populations include the direct impact of fishing and removal of 

individual fish. Fishing is allowed in the park’s Lake Superior waters and inland lakes and 

streams. Indirect effects on fish and other aquatic life include contaminants from boating, air 

pollution and human waste (including dish water, soap, and other human waste at campgrounds). 

Of additional concern are human-transported exotic aquatic species that may become established 

in park waters with grave consequences for the aquatic food chain and native species. Most of 

these issues are beyond the scope of the WBMP and have been addressed or are being addressed 
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in the Isle Royale Water Resources Management Plan (2005) and the forthcoming (2012) Isle 

Royale Fisheries Management Plan, respectively. 

3.3.3 Wetlands and Floodplains

Executive Order 11988 on Floodplain Management requires all Federal agencies to take action to 

reduce the risk of flood loss, to restore and preserve the natural and beneficial values served by 

floodplains, and to minimize the impact of floods on human safety, health, and welfare. Because 

many wetlands are located in floodplains, Executive Order 11988 has the secondary effect of 

protecting wetlands.

Executive Order 11990, Protection of Wetlands, states an overall wetlands policy for all agencies 

managing Federal lands, sponsoring Federal projects, or providing Federal funds to State or local 

projects. It requires Federal agencies to first avoid, then minimize adverse wetland impacts, with 

public input before proposing new construction projects.

A formal determination of floodplains on Isle Royale has never been conducted. In general, the

short, low-gradient streams on the islands pose few flooding concerns, and the only facilities and 

developments near those watercourses are campgrounds and trails. Beaver dam washouts 

occasionally cause flash flooding in particular stream segments. 

According to the National Wetlands Inventory (NWI) of the U.S. Fish and Wildlife Service,

conducted in the 1970’s, a number of wetlands are present in the park, with emergent, forested, 

and scrub-shrub wetlands most common. This nationwide survey of wetlands and aquatic 

habitats is based on interpretation of high-altitude aerial photographs, not a ground survey, and 

its criteria differ somewhat from those used in jurisdictional wetlands delineations for permit 

evaluations by the Army Corps of Engineers under Section 404 of the Clean Water Act

(Cowardin, et al., 1970). In addition, natural fluctuations occur that cause changes in the type and 

boundaries of the park’s wetlands (i.e. beaver damming, or dam blowouts.)

3.3.4 Vegetation

Isle Royale and the adjacent lake country of Minnesota, with their continuous forest mantle, 

abundant wetlands and lakes, and sense of vastness and isolation, are perhaps closer to the true 

sub-arctic environment than any other region of the United States outside Alaska. Lake Superior 

moderates this arctic influence, and arctic-induced coolness provides a zone of tension between the 

boreal forest and the northern hardwood forest. 

Two major biomes occur at Isle Royale: the boreal coniferous forest and the northern hardwoods 

forest. The former generally occurs in the cooler, damper areas of the park, which tend to be found 

toward the northeast. Balsam fir (Abies balsamea) and white spruce (Picea glauca), interspersed 

with pockets of paper birch (Betula papyrifera), comprise the so-called "climax" of the boreal 

coniferous forest. Seral stages of this forest type, that is, earlier phases, are dominated by quaking 

aspen (Populus tremuloides) and paper birch; these areas, typified by the 1936 burn site, cover 

about 20% of the main island. Frequent natural disturbance in the boreal forest from windthrow, 

insect and fungus attack, preferential feeding by herbivores like moose, fire, drought, etc., make it 

a highly dynamic community. 
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The northern hardwoods forest biome is found on warmer, drier sites with adequate soil; these tend 

to be in the southwestern areas of the park. Sugar maple (Acer sacharum) and yellow birch 

(Betula alleghaniensis) are dominant here. This community is more stable and less disturbanceprone, including to fire, than the boreal forest. Xeric (drier) ridges are occupied by small, open 

stands of northern red oak (Quercus rubra), white pine (Pinus strobus), jack pine (P. banksiana), 

spruce (Picea sp.), red maple (Acer rubrum), or occasionally red pine (P. resinosa). In swamps 

and wetland forests of the park, black spruce (Picea mariana) and white cedar (Thuja 

occidentalis) are dominant with the occasional occurrence of non-dominant eastern tamarack 

(Larix laricina). 

Non-forested areas on the ridges support patchy grasses and shrubs, primarily common juniper 

(Juniperus occidentalis), serviceberry (Amelanchier spp.), honeysuckle (Lonicera spp.), hazelnut 

(Corylus americana) and blueberry (Vaccinium sp.). These areas, prone to lightning because of 

their exposure, have burned frequently, leaving little organic soil and thwarting forest 

encroachment. 

Bogs and beaver meadows are dominated by dense stands of sedges, rushes, grasses, and shrubs 

such as alder at the margins. Two kinds of bogs exist at Isle Royale. Sphagnous bogs are 

dominated by the sedge Carex limosa, and have little or no drainage. Other common species in 

sphagnous bogs are sphagnum moss (Sphagnum sp.), Labrador tea (Ledum groenlandicum), black 

spruce, and tamarack. Cyperaceous bogs are dominated by the sedge C. lasiocarpa and often have 

an active water outlet. They tend to have less Labrador tea and sphagnum moss ground cover, but 

support larch and white cedar as an overstory. 

Overall, approximately 700 species of vascular plants have been recorded at Isle Royale, of which 

slightly more than 100 species are exotics. At least 30 different vegetation alliances have been 

identified on the island, within the two broad communities or biomes described above. 

Broad characteristics of Isle Royale’s forests appear to have changed relatively little over time. 

Boundaries of contemporary forest communities generally correspond to those present in the park 

at the time of the first General Land Office survey by William Ives in 1847. Ninety percent or 

more of the park is in the same forest type as in 1847, differing only in seral stage, despite 

extensive Euro-American human use and exploitation. Yet several forest types are now 

undergoing significant changes. There is widespread paper birch mortality in older stands due to 

drought-induced stress and insect/disease attack. Balsam fir is rapidly declining on the west end due 

in part to intensive moose browsing, while substantial growth continues on the east end. Aging 

white spruce stands are also experiencing insect/disease mortality (Janke et al., 1978). 

Moose browsing is creating considerable impact on several tree species, primarily balsam fir, white 

birch, and aspen; the Canada yew (Taxus canadensis), an understory bush favored as moose browse, 

has almost vanished from the main island. The issue of moose browsing and its effects on 

vegetation composition and forage quality is complex. 
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Researchers have postulated a "spruce-moose-savanna effect," whereby intense browsing pressure 

by moose suppresses replacement trees, opening up the forest canopy and possibly the island’s fire 

patterns by reducing forest flammability. Few balsam fir, the preferred winter browse species of 

moose, are able to escape the extreme browsing and make it into the canopy over much of the park. 

In recent years, the overall quality of moose forage has declined, especially on the southwestern 

end of Isle Royale. Browse activity has changed the composition, not just the density, of the 

understory of the park's boreal forests as well; the principal understory plant described by the Ives 

survey in 1848 was the Canada yew (also known as American yew, ground hemlock, or sometimes 

“moose candy” in reference to its popularity with these large herbivores) a highly flammable 

"ladder fuel.” Today the yew is rare, limited to pockets of low moose density. Thimbleberry 

(Rubus parviflorus), the most common understory shrub in the park now, was not even mentioned 

in the 1848 Ives report. Moose do not eat it, and normally it will not carry fire because of its high 

moisture content. These factors combine to create what may be a less fire prone forest than what 

was found prior to the arrival of moose on the island. 

Passage Island, approximately 4 miles northeast of the main island in the park, offers a study of 

Isle Royale’s forests in the absence of moose. Moose have never colonized Passage Island, so 

Canada yew, which they have over-browsed on the main island, is still quite plentiful. Most of 

Passage Island’s vegetation is composed of wind-dispersed species and its vegetation is very 

different from the rest of the park. There is virtually no white spruce on Passage Island; in contrast 

it includes a large mountain ash component. This island is one of the most unique forest habitats in 

all of Michigan. Public access to Passage Island is afforded through a public dock and guided 

tours of the island. No overnight camping is allowed.

In 1936, human-caused fires burned approximately 20% of the forest on Isle Royale’s main island. 

The burned area furnished abundant forage for moose in the years following the fire, so much so 

that the moose population could not increase fast enough to avail itself of this surplus food, and a 

number of trees were thus able to “escape” over-browsing and mature. Aging birch and aspen 

forests now characterize this area.

Approximately 95% of the park is now designated as a Wildland Fire Use Zone, meaning lightningcaused fires are allowed to burn under most circumstances. In theory, this policy should allow fire 

to regain its stature as an ecological force on the island; yet very little acreage actually burned in the 

1990’s, despite some dry summers. The combination of forest types (hardwoods, birch, and aspen) 

and moose browse impacts may have tempered the typical heavy build-up of fuels associated with 

decades of earlier fire suppression. Many fire-dependent species, such as jack pine and white pine, 

will decline without its return. 

Most insect and disease impacts appear to be natural events, with the notable exception of blister 

rust on the island's white pines; with no method of control for the blister rust, an important resource 

on the island may eventually disappear from this alien disease. The park experienced widespread 

outbreaks of native tree pests in the dry years of the 1990’s, including Tortrix (Archips conflictana), 

which affected aspen and birch, and spruce budworm (Choristoneura fumiferana) which affected 

balsam fir and white spruce.
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Serious concerns exist about alien species of flora at Isle Royale. Spotted knapweed (Centaurea

biebersteinii) has been found in several places in the park, and is aggressively treated and mapped 

wherever it is found. Other invasive species of concern that have been documented within the park 

include mountain bluet (Centaurea montana), creeping bellflower (Campanula rapunculoides) and 

garlic mustard (Alliaria petiolata). The park is actively inventorying, mapping, monitoring and 

treating these invasive exotics annually. 

Known human impacts to the park’s vegetation occur on a large and small scale. The predominant 

large-scale impacts are the result of human caused fires followed by decades of fire suppression, as 

discussed above. On a smaller scale, the construction of trails and campgrounds, and human 

trampling, have significant localized effects on vegetation. These impacts are most relevant to 

recreation and the issues being addressed in this WBMP, and more specifically include changes in 

plant composition, damage to and loss of vegetation, the loss of woody debris for campfires, and 

the creation of ideal conditions for the establishment of exotics. 

Vegetation composition in and adjacent to trails and campsites shifts in response to increased light 

intensities from clearings, increased trampling, increased moisture from runoff, compacted soils, 

and the possible introduction of exotic or other disturbance-tolerant species. Most if not all 

vegetation is eliminated in the construction and use of designated trails and campsites. Generally, 

broad-leaved herbs, lichens, small shrubs, and tree seedlings have little tolerance for trampling and 

are quickly eliminated where people stray from designated trails and campsites. Plants in forested 

shady areas also appear less resilient than those in open sunny sites. A loss of original species may 

expose soils to increased erosion as well as creating favorable conditions for new, invading species 

(Hendee and Dawson 2002). The establishment and subsequent spread of invasive exotic species 

under these conditions is of particular concern. 

Vegetation is particularly vulnerable to the impacts associated with trampling in the spring. Soils 

are heavily saturated following the snow-melt, creating muddy conditions that exacerbate erosion. 

This is compounded by trail widening due to hikers avoiding wet and muddy patches on trails, and 

campsite expansions resulting from people pitching their tents outside of wet or muddy tentpads. 

The damage caused by trampling may be longer lasting when plants are damaged before going to 

seed. 

3.3.5 Terrestrial Wildlife

Isle Royale's terrestrial wildlife is a classic example of island biogeography theory, which predicts 

that biodiversity on islands is less than on mainland areas, as a result of both distance from the 

mainland (that limits colonization) and the constrained ability of an island of a given size to 

support viable and genetically healthy populations. For instance, only 18 species of mammals are 

known to breed in the park, compared to about three times that number on the north shore of Lake 

Superior. Many species of mammals cannot swim across Lake Superior and will not cross the ice 

if the lake freezes. Colonization of the island is by chance dispersal with the constant possibility of 

natural extinction. Caribou, coyote and lynx have all disappeared from Isle Royale since the 

arrival of Euro-Americans.

Mammals include the red fox, snowshoe hare, mink, short-tailed weasel, beaver, deer mouse, red 

squirrel, muskrat, river otter, American marten, and six species of bats (little brown myotis, 
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northern long ear, silver haired, red bat, hoary bat, and big brown bat). The two best-known 

mammals on Isle Royale are the moose and the timber wolf, the subject of the longest-running, 

predator-prey research and monitoring project in the history of wildlife management. Professor 

Durward Allen and his graduate students initiated this project in 1958; since the mid-1970’s, Dr. 

Rolf Peterson of Michigan Technological University has continued the studies. Moose colonized 

Isle Royale in the early 1900s, either by swimming or crossing the ice from the Canadian 

mainland. Before wolves arrived in the late 1940’s, the moose population exploded, over-browsed 

the vegetation, and collapsed twice. The second population boom was aided by the production of 

vast amounts of new browse after the 1936 fire (Peterson, 1977).

No animal symbolizes the essence of Isle Royale wilderness more than the timber wolf. Its widely 

fluctuating numbers range annually from 12 to 50 with some dramatic dips and rises in the 1990s. 

Studying these population dynamics increases our knowledge and awareness of the park ecosystem. 

In the late 1980s concern over a rapidly dwindling population led to radio collaring and extracting 

blood samples from a few wolves on Isle Royale for the first time. With this, researchers 

discovered that canine parvovirus had infected the population and was partially to blame for the 

decline. Since then a few wolves have been trapped, collared and tested for disease and general 

health every few years. Although the population has rebounded somewhat with successful 

reproduction since then, concern for the park’s wolf population continues. The isolated population 

remains vulnerable to inbreeding and disease. 

There is also growing concern with the possibility of wolves losing their fear of humans. Wolves 

have been well protected on Isle Royale in large part because they have maintained their fear of 

people, avoiding encounters and maintaining a separation. There would be serious repercussions if 

wolves were to lose this fear and become habituated to people on the island. Wolves that have lost 

their fear of people and approach people, frequent campsites, or begin associating people with food 

pose a very serious safety risk. In Algonquin Provincial Park, Ontario, “tame” wolves in 

campgrounds have bitten people on multiple occasions and there are a growing number of similar 

incidents elsewhere in North America; all of these cases have resulted in the death of a wolf 

(Peterson and Vucetich 2002, McNay 2002). To prevent this at Isle Royale a primary goal is to 

maintain a separation between wolves and people, and provide plenty of space for wolves to escape 

human presence. One means of accomplishing this is to maintain the status quo in terms of where 

campgrounds and trails are located, where and how frequently people travel off trail, and where 

wolves can consistently avoid people. 

The park's moose herd increased slowly over the five years following the population crash 

during the winter and spring of 1995-96, but began to drop to historically low numbers from 

2002 onward. Major challenges for Isle Royale moose are winter ticks and the poor winter food 

supply, especially on the southwest end of the island, where these herbivores often must survive 

on lichens. Moose on the northeast end do better because of the large balsam fir stands growing 

there.

Little is known about Isle Royale’s reptiles and amphibians, but their occurrence is doubtless 

influenced profoundly by island biogeography as well. Three species of reptiles have been 

documented – the western painted turtle, red-bellied snake, and garter snake – as have seven 
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amphibians – the blue-spotted salamander, mud puppy, American toad, spring peeper, chorus frog, 

green frog, mink frog, and wood frog. 

Due to migration and their much greater mobility and ability to disperse, birds are less affected by 

the isolation of Isle Royale than the foregoing taxa. Bird diversity tends to mirror that of nearby 

mainland areas in Michigan, Minnesota and Ontario. Two notable absences are the ruffed grouse

and the spruce grouse, which are non-migratory and unable to make the flight across the open 

waters of Lake Superior to the park. Historically, the park did have a sharp-tailed grouse 

population, which gradually disappeared (there have only been two reported sightings in over 20 

years.) Bald eagle and osprey populations continue to rebound at Isle Royale; in the 1960’s and 

1970’s pesticide poisoning eliminated nesting of these two majestic raptors in the park. Both birds 

began nesting again at Isle Royale in the 1980’s. By 2000, 14 fledglings were produced from 

twelve eagle nests and seven fledglings were produced from seven osprey nests (Romanski, 

2000). Nesting eagles and ospreys are sensitive to human intrusions and on Isle Royale area 

closures have proven effective at preventing adverse impacts from human encounters near nests. 

Another raptor recovering from pesticides across North America is the peregrine falcon (Falco

peregrinus). From 1987-91 the park released 50 young peregrine falcons from two locations on the 

island. Although peregrines are occasionally sighted, it is not believed that any successful nesting 

has yet occurred.

Isle Royale has the only known Common Loon nesting territories on the shorelines of the Great 

Lakes, and loons are synonymous with Isle Royale as they may be heard and seen throughout the 

park by virtually all visitors. The State of Michigan identified the park as one of only two 

management zones (out of six) maintaining a sizeable loon population, though loons were once 

common throughout the state and known to breed in all of the state’s counties. Loons play a 

vital ecological role in the aquatic food chain as a top predator by regulating the structure of 

aquatic communities. The NPS and research partners have monitored Isle Royale’s loon 

population and fledging rates since 1990. When fledging rates appeared to be lower than would 

be expected in an area protected as a National Park and wilderness, additional research was 

begun to explore loon territories in the park and mechanisms that may be influencing nesting 

success. There are approximately 100+ known territories within the park, including inland lakes 

as well as protected Lake Superior shorelines. Fledging rates are estimated at 0.34 park-wide. 

There are a limited number of published monitoring efforts with comparable methodologies and 

duration that would offer valid comparison for the fledging success of Isle Royale loons. Table 

13 lists known comparable studies, which includes study sites that may be expected to have 

lower levels of protection afforded loons than on Isle Royale (e.g the state of New Hampshire) 

and areas of greater protection (e.g. Seney Wildlife Refuge where no recreation is allowed on the 

lakes). 
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Table 13: Fledging Rates (per territorial loon pair) at Selected Long-term Monitoring Sites (with 

permission from Kaplan and others 2003)

Site Years Fledging Rate Source

Isle Royale National Park, MI 1990-2002 0.34 Kaplan and others 2001

New Hampshire (state-wide) 1977-1999 0.51 Taylor and Vogel 2000

Massachusetts 1975-1990 0.51 McIntyre 1994

Stillwater Reservoir, NY 1977-1990 0.58 McIntyre 1994

Vermont 1978-1990 0.59 McIntyre 1994

Seney National Wildlife 

Refuge, MI

1987-2002 0.69 Unpublished data; Evers and 

others 2000

Several mechanisms likely influence Isle Royale fledging rates. Of primary relevance to this 

WBMP is the observed impact of human interactions and intrusions into loon nesting areas. 

Loons are known to be sensitive to a human presence on the water, especially proximity to nests. 

On Isle Royale and elsewhere loons have been observed flushing off their nests when paddlers 

approach in canoes or kayaks. Preliminary research (Kaplan and others 2003) revealed that from 

1990 through 2002 as the number of permits issued to canoers on Isle Royale increased the 

number of chicks fledged per loon pair decreased. This research also revealed that under certain 

circumstances there appears to be a correlation between the number of paddlers who approach 

within 20 meters of a loon nest and the probability of a nest failing. More research is needed to 

better understand the mechanisms influencing the fledging rates of Isle Royale loons as well as 

the viability of the population in the park. However, this preliminary research reinforces the 

importance of public education and informing people of how their behavior may affect the park’s 

wildlife positively or negatively. 

Some 58 species of forest songbirds have been documented at Isle Royale from monitoring begun in 

1994. The most abundant are the white-throated sparrow, Nashville warbler, ovenbird and red-eyed 

vireo. Park staff have begun an annual monitoring program for neotropical migratory birds based 

on accepted protocols An average of 1,424 individuals representing 57 species was detected 

annually. Eighty-five species from twenty-five families were identified during a 13-year period 

from 1996 to 2008 (Egan 2009). The majority of these species are neotropical migrants, which 

comprise about half of the breeding songbirds on Isle Royale. Neotropical migrants winter in 

Central or South America. Studies of recreation impacts on birds reveal concern in several areas: 1) 

trails affect the composition of bird species by creating edge habitats that favor generalist species 

and are unfavorable for specialist species, 2) nest predation rates are higher along trails, and 3) 

intentional and unintentional wildlife feeding in campsites leads to attraction behavior and 

unhealthy food dependencies, a common occurrence with species of jays in particular (Leung and 

Marion 2000).

There are specific concerns for wildlife species during different seasons of the year. Spring and 

fall are times of high sensitivity for many species in boreal areas such as Isle Royale with a 

narrow window for breeding and rearing young. Animals that hibernate or migrate have 

particularly short periods of time to establish territories, attract mates, establish nesting or 

denning areas, and reproduce. If disturbances upset their nesting or denning periods, there is less 

of a chance in these northern climates that they could start again and successfully rear young 

before the onset of winter. Spring is also a critical period for animals such as moose and wolves 
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that have already produced young and are focused on protecting these young. Fall offers other 

unique challenges, with wildlife storing up food or body fat in preparation for winter. Fall is a 

particularly critical time for moose, as they enter the rut. Protecting wildlife from human 

disturbances during these sensitive seasonal periods is one goal of resource management on Isle 

Royale. 

3.3.6 Threatened and Endangered Species

This section, and Appendix H, summarizes information on species of plants and animals at Isle 

Royale National Park listed by the Federal government (USFWS) or the State of Michigan as 

Threatened or Endangered. In addition, species of special concern designated by the state are 

listed in Appendix H.

The Endangered Species Act (ESA) of 1973 (16 USC 1531-1544) provides the legal framework 

by which imperiled species of plants and animals are designated and protected by the Federal 

government. The Endangered Species Act of the State of Michigan (Part 365, PA 451, 1994 

Michigan Natural Resources and Environmental Protection Act) provides the parallel authority 

for the state. The current state list became effective on March 20, 1999.

A current list exists at the park for Federally-listed flora and fauna, which includes the Threatened 

grey wolf and bald eagle. No park plant species are on the Federal list. The State of Michigan list 

of endangered and threatened species and species of special concern includes many animal species 

found on Isle Royale, including six species of fish and 20 species of birds, in addition to more than 

60 plant species (Michigan State University, 1999a and 1999b). 

Federal Endangered Species

An “Endangered species” is one that is threatened with extinction throughout all or a significant 

portion of its range. No Federally-listed Endangered plants or animals are known to be resident 

at or frequent visitors to Isle Royale. The gray wolf (Canis lupus), which has been found in the 

park since the late 1940s, was reclassified from Endangered to Threatened by the US Fish and 

Wildlife Service in April of 2003. The peregrine falcon (Falco peregrinus), which is found in 

the park but not known to nest, was listed as an Endangered species in 1970, but was de-listed in 

1999 as a result of recovery of its populations from successful efforts at captive breeding and 

reintroductions. 

Federal Threatened Species 

Threatened species are assumed to be vulnerable to become Endangered, and so are offered 

protection similar to that for Endangered species. Two Federally-Threatened species occur at 

Isle Royale: 

• Gray wolf (Canis lupus) –Originally, the gray wolf resided over most of the eastern 

United States, but it was widely extirpated as human populations grew, habitats were 

modified, prey species dwindled, and aggressive predator control programs targeted 

wolves. The wolf was officially listed as Endangered by the Federal government in 1974, 

then reclassified as Threatened in 2003. Wolves have been at Isle Royale since the late 

1940’s, having arrived naturally by crossing Lake Superior when it was frozen one 
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winter. Their population size fluctuates from about a dozen to several dozen and they 

feed primarily on Isle Royale’s moose herd.

• Bald Eagle (Haliaeetus leucocephalus) was also down-listed from Endangered to 

Threatened by the USFWS in 1995 and delisted in 2007 bird as a result of its increasing 

numbers around the country. The reason for historic declines in bald eagle populations in 

the 1950’s and 1960’s included PCBs, DDT, DDE, mercury, and disturbance and 

displacement by humans. DDT was the primary cause and the banning of DDT in the 

early 1970’s has led to resurgence in numbers throughout the U.S. as well as in the park. 

Bald eagles began nesting again at Isle Royale in the 1980’s. By 2000, a maximum of s14 

fledglings were produced from twelve eagle nests (Romanski, 2000), while the long-term 

average is between 8-10 fledglings.

State-Listed Species

A number of species listed by the State of Michigan as Endangered, Threatened, or Species of 

Special Concern are found at Isle Royale. These species and sub-species are not afforded the 

same formal protection provided by the Endangered Species Act, but NPS policy grants them 

similar protection through a commitment to “inventory, monitor, and manage state and locally 

listed species in a manner similar to its treatment of federally listed species, to the greatest extent 

possible” (NPS 2006). Isle Royale species listed by the State of Michigan are presented in full in 

Appendix H. 

• State-Endangered plants: There are seven species of state-endangered plants at Isle 

Royale.

• State-Endangered animals: There are no state-endangered mammals at Isle Royale. Of 

state-endangered birds, both the peregrine falcon and the short-eared owl have been at the 

park, but there is no known nesting by either species within park boundaries.

• State-Threatened plants: There are 40 species of state-threatened plants at Isle Royale.

• State-Threatened animals: The gray wolf in the only state-threatened mammal known 

to reside and breed at Isle Royale. There are three species of state-threatened fish at Isle 

Royale, the lake sturgeon, lake herring, and shortjaw cisco, and nine state-threatened

birds; long-eared owl, red-shouldered hawk, yellow rail, merlin, common loon, bald 

eagle, osprey, Caspian tern, and common tern. Of these, the merlin, common loon, bald 

eagle, and osprey are known to breed within Isle Royale National Park.

• Plants of Special Concern: There are 18 plant species of special concern in the park.

• Animals of Special Concern: There are three fish species and/or sub-species of special 

concern at Isle Royale, the Siskiwit Lake cisco, kiyi, and spoonhead sculpin, and one 

mammal of special concern, the moose. There are nine bird species of special concern: 

Cooper’s hawk, northern goshawk, American bittern, black tern, northern harrier, blackcrowned night heron, black-backed woodpecker, dickcissel, and yellow-headed 

blackbird.

In addition to the federally listed species, several state-listed species—the common loon and 

state-listed plants—are of particular concern to the WBMP, because of the known impacts of 

human activities and recreation on these species. Management actions are known to influence 

where people travel through the location of trails and campgrounds. The locations of loon nests 
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and rare plants, as well as federally listed species and their habitats were considered in exploring 

and evaluating any changes in the location of trails and campgrounds. These were also 

considered in exploring changes in public education and park regulations. 

3.3.7 Natural Sounds and Sights

The natural sounds of Isle Royale’s wilderness may be compromised by human-generated 

mechanical noises. The natural sights may be compromised by light pollution from residential 

areas within the park and Thunder Bay to the north, and the sights of human developments 

visible from many locations throughout the park’s backcountry, including wilderness. 

Measuring Levels of Sound and Noise

NPS policy considers natural sound to be an integral part of visitors’ experiences in backcountry 

and wilderness areas of National Parks. Many visitors to National Parks place high value on 

natural sound for its novelty and marked contrast to most people’s everyday experiences as well 

for its restorative effects. Natural soundscapes can be protected in part by controlling the 

intrusion of motorized and human-generated noises into protected areas (Gamann 1999.)

A logarithmic unit known as the decibel (dB) is used to represent the intensity of sound. The 

decibel scale is similar to the Richter scale used to measure earthquakes. On the Richter scale a 

7.0 earthquake is ten times stronger than a 6.0 earthquake. On the decibel scale, an increase of 

10 dB is equivalent to a 10-fold increase in intensity or power. Therefore, a sound registering 80 

dB is ten times louder 70 dB sound. To give an example of the range of audible sounds: a 

whisper has an intensity of 20 dB and can just be heard; 140 dB (a jet aircraft taking off nearby) 

is the threshold of pain. In wilderness the typical sound level would be 30-40 dB (MPCA, 1999; 

EPA, 1974), with louder intervals of sound, such as birds singing nearby and geographic 

variations such as sound from a waterfall.

The perceived intensity of sound is not only a function of volume; certain frequencies of sound 

appear louder to the human ear than do other frequencies, even at the same volume. Decibel 

measurements of noise are therefore often "A-weighted" to take into account the fact that some 

sound wavelengths are perceived as being particularly loud. A soft whisper is 20 dB but on the 

A-weighted scale the whisper is 30 dBA. Normal speech has a sound level of about 60 dBA. 

Sound levels above 120 dBA begin to be felt inside the human ear as discomfort and eventually 

pain at still higher levels (DOD, 1978). Examples of dBA levels from some common sounds can 

be found in Table 14.
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Table 14: Common Noise Levels and Their Effects on the Human Ear

Source Decibel Level 

(dBA*) Exposure Concern

Soft Whisper 30

Up to 70 dBA

Normal safe levels

Isolated Wilderness 30-40

Quiet Office 40

Average Home 50

4-stroke outboard boat motor at idle 58

Conversational Speech 66

Busy Traffic 75 Up to 90 dBA

May affect hearing in some 

individuals depending on 

sensitivity, exposure length, 

etc.

Noisy Restaurant 80

4-stroke outboard boat motor cruising 88.5

Average Factory 80 – 90

Rock Harbor Generator 85-105

Over 90 dBA

Continued exposure to noise 

over 90 dB may eventually 

cause hearing impairment.

NPS Diesel Boats 90-100

Inboard Motorboat 110

Propeller aircraft 120

Automobile Horn 120

Chainsaw 90-125

*Indicates A-weighted decibel levels

(DOD, 1978 and ISRO 1997, MPCA 1999)

Soundscapes and Noise

“In most environments today, soundscape signatures are comprised of two natural components,

biophony and geophony, and a probable human component that includes the third,

anthrophony. Biophony is the combined sound that living organisms produce in a given habitat. 

Geophony is comprised of geophysical sounds in the environment, such as the effect of wind in 

trees or grasses, thunder, water flow, earth movement, etc. Anthrophony is usually comprised of 

human-generated mechanical sounds, such as signals from aircraft, automobiles, generators, 

snowmobiles, jet-skis, radios, television sets, boom boxes, or automobile sound systems.” 

(Krause and Gage, 2003). 

Noise is defined as unwanted sound (INCE, 1995). In a National Park setting, much of the 

human – generated sound (anthrophony) would be considered noise. In other circumstances, 

such as an orchestra concert or a conversation, human-generated noise can be pleasing. In some 

recreational settings such as an amusement park or a sports stadium a high-volume of humangenerated noise is expected. But National Parks are among those quiet settings more sensitive to 

noise intrusions. Examples of these “sensitive receptors” include places such as schools, 

churches, hospitals, retirement homes, campgrounds, and hiking trails. Some living things are 

also sensitive receptors including Threatened or Endangered species, other wildlife and some 

people.
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Even in “quiet” settings like churches and schools, a certain level of human-generated sound is 

expected, tolerated and even enjoyed. Sound becomes noise only when it is unwanted. 

Therefore a school orchestra practicing at 70 dBA would not be considered noise by the students, 

while a radio playing outside a classroom at just 60dBA would likely be considered noise. 

Determining which sounds are “noise” has to do with more than just volume. In a wilderness 

area, such as Isle Royale, complete silence is not required. The sounds of birds, frogs, insects, 

and mammals combine to form the biophony. Waves against the shore, wind in the trees, 

flowing water, and thunder are elements of the geophony. These sounds are expected in a 

wilderness and form the natural soundscape. Even at higher-than-normal decibel levels these 

sounds may not be considered noise because they are part of the wilderness experience. 

By contrast, human-generated noise, even at low decibel levels, can have a negative impact on a 

visitor’s wilderness experience. While the sounds of birds and waves are expected in a 

wilderness, the sounds of mechanical devices are not. Lower decibel noises may seem louder in 

the wilderness because the soundscape is not crowded with the human-generated mechanical 

noises that fill modern life. An average home might have a background noise level of 50 dBA; 

this level is much louder than in the wilderness where 35 dBA is more typical. In these quiet 

conditions, a hiker on the Greenstone Trail might hear a boat motor at cruising speed in the Rock 

Harbor channel, miles away. This could be more disturbing to the hiker in wilderness than a 

much louder engine noise would be in a residential area where such noises are more common 

and the general background noise of the area is much louder.

Current Noise Conditions at Isle Royale

Detailed research on noise levels and natural landscapes has not been completed at Isle Royale. 

However, there are many known sources of noise penetrating the park’s wilderness. These 

sounds originate from sources both within and outside of designated wilderness and include:

• Human voices can be heard for long distances in the park, especially across the water, 

from a height, or in the evening when the wind dies. Large group sizes, and alcoholinfluenced behavior can contribute to this.

• Motorboats traveling on Lake Superior can be heard for long distances in the park. Fourstroke engines (like those used on many NPS boats) are quieter than two-stroke engines, 

which can often be heard well into the interior of the island. Motorboats are the primary 

means of transportation for park personnel working throughout the park. In addition to 

the NPS fleet, between 1,000 and 2,000 private motorboats travel to and around Isle 

Royale each year. 

• A commercial seaplane flies regularly to the island and along the length of the park’s 

border between Windigo and Rock Harbor, landing in Tobin Harbor and Washington 

Harbor up to three times per day. Private planes also fly to and around the park, though 

rarely. These planes fly directly over wilderness when landing and taking off and can be 

heard well into the interior of the island. 

• Aircraft over-flights for resource monitoring and administrative use fly at low levels 

during the visitor season. Over-flights are for surveys of park resources (for example 

raptor counts and fire monitoring) and for administrative purposes and occur about five 

times per visitor season with about 2 hours directly over the island for each flight.
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• During winter study aircraft over-flights are used for monitoring and researching the 

island wolves and moose. These flights take place when the park is closed to visitors and 

number about 35 per year. 

• Helicopter flights are used for medical emergencies and infrequent administrative 

projects. People with medical emergencies may be transported by helicopter to mainland 

hospitals. Flights typically land outside of wilderness on the Mott Island main dock, but 

can also land in other designated zones. An average of about six emergency flights are 

needed per year. Administrative uses of helicopters in the past have included flying and 

hovering over wilderness for projects such as supplying batteries to a radio repeater, 

hauling materials for trails construction, and transporting opening crews to the island 

before ice-out in the spring. The frequency of these helicopter operations varies from 

year to year, with some years having no administrative use of helicopters. 

• TheVoyageur II ferry travels around the island, particularly into McCargoe Cove and its 

engines can be heard several miles into the interior of the island (depending on the wind 

direction). The Voyageur II makes three complete trips around the island each week and 

operates six days per week. All ferries sound horns to announce their arrival and 

departures; this can be heard in the wilderness daily within the vicinity of Rock Harbor 

and Windigo, and periodically at secondary ferry landings at McCargoe Cove, Daisy 

Farm, Chippewa Harbor, and Malone Bay.

• Generators power operations at Windigo, Rock Harbor and Mott Island. Diesel 

generators run constantly and can be heard from Tobin Harbor and Rock Harbor with the 

noise penetrating beyond the shore in both locations. Depending on weather conditions

and seasons of the year, generators can also be heard from atop ridges on the northeast 

and southwest ends of the island. 

• Tractors and other heavy equipment operating at Mott Island, Rock Harbor and Windigo 

can be heard in the interior of the island. Such equipment operates frequently throughout 

the visitor season depending upon the current projects. 

• Power tools, cranes and barges may be used for dock maintenance adjacent to designated 

wilderness areas; noise levels vary with project and location.

• Power tools are used for maintaining shelters and outhouses in shoreline campgrounds 

both within and adjacent to wilderness. 

• Chainsaws are used in designated wilderness, primarily in May and June to clear trails 

and campgrounds from winter windfall trees, and in September and October to clear 

hazard trees. Chainsaws are also used outside of designated wilderness for general 

maintenance. 

• Trail maintenance with hand tools such as pick ax and rock bars. Noise travels well, 

especially from a height and across water. For example, work on the Greenstone Trail 

can be heard at Malone Bay under the right conditions. 

• Lighthouses at Passage Island and Rock of Ages. These lighthouses constantly produce a 

“foghorn” type sound twice per minute. This sound can be heard at the far Northeast and 

Southwest ends of the park.

Noise Impacts on Wildlife

Beyond affecting human visitors and NPS employees, higher-volume noise could also negatively 

impact wildlife in the backcountry and wilderness. Most researchers agree that noise can affect 
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an animal’s psychology and behavior, and if it becomes a chronic stress, can be detrimental to an 

animal’s energy budget, reproductive success and long-term survival (Radle, 1998). 

The Noise Pollution Clearinghouse has assembled the findings of several important studies on 

the effects of noise on wildlife. The studies they cite find that “Long-term exposure to noise can 

cause excessive stimulation to the nervous system and chronic stress that is harmful to the health 

and reproductive success of wildlife species (Fletcher, 1990).” “Behavioral and physiological 

responses have the potential to cause injury, energy loss (from movement away from the noise 

source), decrease in food intake, habitat avoidance and abandonment, and reproductive losses 

(National Park Service, 1994).” And “Studies have documented hearing loss caused from 

motorcycle noise in the desert iguana (Bondello, 1976) and the kangaroo rat, an endangered 

species (Bondello and Brattstrom, 1979).” 

Mechanical noise might even cause certain species to abandon an area. In tests conducted at 

Sequoia/ King’s Canyon National Park, sponsored by the NPS and conducted by researchers 

from Wild Sanctuary and Michigan State University, detailed analysis of soundscapes revealed 

that species developed a system of audio niches so that, in general, different species did not use 

calls of similar frequencies in the same soundscape. The system of audio niches had also 

adjusted to the presence of white noise from streams and other geophonic features (Krause and 

Gage, 2003). This research has implications for human-generated noise, especially constant 

mechanical noise such as that created by generators used at Isle Royale. If species’ calls were 

cancelled out by the frequencies of human-generated noise, those species would likely either 

have to adjust the frequency of their calls, or if that were not possible, relocate to areas beyond 

the reach of the anthrophonic noise. 

The impacts of noise on wildlife needs much more research, especially the long-term effects of 

medium to low-level noise intrusion, with an emphasis on endangered species. The synergistic 

effects of noise with other stressors on animals also need investigation (Cornman, 2001). 

National Park Service Policy on Noise

The 1970 Clean Air Act authorized, and the 1972 Noise Control Act established an Office of 

Noise Abatement and Control in the Environmental Protection Agency. The office conducted 

research, coordinated the work of other agencies, and directly set noise standards for trucks, 

motorcycles, air compressors, truck-mounted garbage compactors, and railroads. More standards 

would have followed, but in 1981 Congress ended funding for the effort. In 1997, 

Representative Nita M. Lowey of New York, sponsored a bill to reauthorize the EPA's Office of 

Noise Abatement and Control. The bill never emerged from committee and was not debated on 

the floor of the House of Representatives. Representative Lowey has re-introduced the bill four 

times, most recently in 2003 and in each case the bill died in committee.

With the EPA no longer working to establish standards for noise control the task of controlling 

noise has fallen to states and localities. Most cities have noise ordinances and states like 

Colorado and Minnesota are working to establish standards of maximum acceptable noises for 

different settings throughout the state (i.e., rural, residential, industrial). For example, the State 

of Minnesota also found that sound levels in isolated wilderness are typically 30 dBA, while, at 
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night, in residential areas it is permissible for sound levels to exceed 50 dBA about thirty 

minutes of each hour (MPCA, 1999). 

Without national standards on noise pollution, noise in the National Parks has become a 

controversial issue in recent decades. Many parks retain their historical appearance, but, due to 

the widespread proliferation of human-generated mechanical noise, parks no longer sound as 

they once did. In response, NPS management policies call for the preservation of, “to the 

greatest extent possible, the natural soundscapes of parks” (NPS, 2006; Section 4.9). Human 

activities that generate noise are to be monitored, and it is NPS policy to prevent or minimize 

noise that affects the natural soundscape or exceeds levels appropriate for visitor uses. 

Additionally, 2006 Management Policies, Section 8.2.3 directs the NPS “to restore the natural 

quiet and natural sounds associated with the physical and biological resources of parks.” Where 

use of motorized equipment is necessary and appropriate, the “least impacting” equipment and 

vehicles should be used, consistent with public and employee safety. 

Some conservationists argue that auditory solitude, that is “quietude,” was recognized by the 

drafters of the 1964 Wilderness Act and is implied by the act’s language (Matzner, 2001). NPS 

policy on wilderness management explicitly recognizes the incompatibility of man-made noise 

with wilderness. Since 99% of Isle Royale National Park is Congressionally-designated 

Wilderness, and managed so as not to impair its wilderness attributes, park management must 

consider potential impacts of motorized equipment to the character, aesthetics, and traditions of 

wilderness (NPS 2006, §6.3.4.3), even where the noise originates outside of the designated 

wilderness. The NPS relies heavily on motorboats, chainsaws and generators for park 

maintenance and operations, with occasional use of airplanes for research and transporting 

personnel. Some visitors to the park use motorboats and airplanes both for access and recreation. 

Passing outboard motors can reach sound levels in excess of 80 dBA when heard from shore, 

while chainsaws and propeller aircraft can reach 120 dBA at the source. The noise from these 

sources, while intermittent (not constant) may occur on a daily basis and penetrate well into the 

backcountry and wilderness areas of the park. The extent to which the sound penetrates depends 

upon a variety of factors: weighted decibel level (dBA) of the noise at the source, distance of 

visitor from the source, number of sources operating at one time, presence of screening provided 

by hills or trees, and proximity to reflective materials like a wall, hillside, or to some extent, 

water (MPCA, 1999). Sound travels in waves and anything that absorbs or lessens the waves, 

such as distance or insulation, will decrease the decibel level, while anything that increases the 

power of the sound waves, such as additional sources of noise or reflective surfaces, will 

increase the decibel level. Wind speed and direction can also affect the intensity or even the 

detection of sound.

Therefore the noise of chainsaws operated in a dense section of forest may not travel as far as 

when that same equipment is operated on top of a ridge. Sound from motorboats and airplanes 

can travel particularly far. The noise from airplanes generally cannot be blocked much by 

screening because the waves are coming from above. Airplanes move very quickly and, as 

opposed to stationary noise sources, they travel great distances bringing their noise to large 

sections of a park. Finally, airplanes can fly over the most remote sections of a National Park to 

places where mechanical noise is a particularly unwelcome reminder of civilization. In 
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recognition of the ability of airplane noise to affect the entire park, Isle Royale has voluntary 

flight restrictions to minimize the number of low flights directly over the island. 

Like airplanes, powerboats also move, potentially carrying noise to an entire lakeshore. Boat 

motors generally have lower decibel levels than airplanes, especially 4-stroke engines such as 

those used in most park boats at Isle Royale. Water is a reflective surface and sound waves 

bounce off of water carrying more sound to listeners in kayaks, canoes or on land, as well as to 

wildlife. Even a boat traveling well offshore can sometimes be heard by hikers miles away. 

Under certain wind conditions motorboat noise at Isle Royale can be heard from ridge tops far 

into the interior of the island. Conversely, an offshore wind can greatly diminish motorboat 

noise reaching the island.

The park’s designated Wilderness faces significant noise impact problems from aircraft over-flights, 

motorboat noise, mechanized maintenance equipment, noise from large groups and adjacent visitors 

in campgrounds, and portable generators at docks. Of additional concern is the noise related to park 

management, coming from operations at Mott Island, Windigo, and Rock Harbor. Large diesel 

generators support visitor services and park operations at these locations, and these generators may 

be heard from the Greenstone Ridge and other wilderness and backcountry areas. Noise impacts 

may be one of the greatest threats to the integrity of Isle Royale Wilderness.

In addition to intruding on wilderness solitude, another potential impact of human and motorized 

noise is on wildlife. Some scientists believe that around the world, noise pollution is 

contributing to the depletion of wildlife populations, although this is very difficult to quantify 

and has not been documented at Isle Royale in particular. Research into the effects of noise on 

wildlife has been growing rapidly since the 1970s, yet often presents contradictory results 

because of the complexity of factors and the difficulty of isolating variables; nevertheless, most 

researchers agree that noise can affect an animal's physiology and behavior, and if it becomes a 

chronic stress, can be detrimental to an animal's energy budget, reproductive success and longterm survival (Radle, 1998). The long-term effects from medium to low-level noise intrusion 

need much more research, with emphasis on Threatened and Endangered species. The 

synergistic effects of noise with other stressors on animals also need investigation (Cornman, 

2001).
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3.4.1 Historical Overview

Evidence of human use and habitation can be found throughout Isle Royale and in the 

surrounding waters. As a rich source of fish, wildlife, plants and minerals, Isle Royale has 

attracted human visitors and residents for millennia. Evidence of human activity is found 

throughout the island and in the surrounding Lake Superior waters. Cultural resources ranging 

from lithic scatters of chipped stone to lighthouses trace a rich story of human use spanning from 

Archaic Times (ca. 3000 BC) to the present. Stone tools, mining pits, shipwrecks, vernacular 

boats, fishing camps, summer cabins, domestic flowers and medicinal plants are all part of the 

cultural resources of the island.

Many sites and resources still exist from prehistoric and historic use of the island, including 

periods of use by Native Americans, voyageurs and fur traders, and from extensive commercial 

fishing and mining, Lake Superior shipping, vacationing and resort development. These cultural 

resources are categorized as archeological sites, historic structures, cultural objects, cultural 

landscapes and ethnographic resources. Many of these cultural resources are located in 

designated wilderness and potential wilderness additions. 

The first evidence of human use of Isle Royale was left by Archaic- period aboriginal copper 

miners. Shallow pits remain throughout the island as testimony to the special purity of Isle 

Royale’s copper deposits. Native groups also came to harvest the island’s other natural 

resources through hunting, fishing and gathering plants and berries. Fur-bearing animals became 

important as European traders and trappers entered the area in the 1600s and 1700s. Explorers 

and missionaries of the time wrote the first historic accounts of the island.

Three phases of copper mining punctuated the nineteenth century history of the island. Coming 

thousands of years after prehistoric miners, historic entrepreneurs often mined the same sites that 

had attracted native peoples. Three phases of mining occurred in 1843-1855, 1873-1881 and 

1889-1893. Success was very limited because of the high cost of operation at Isle Royale. 

Initial profits ended when pure copper veins pinched out. Eventually all of the copper mining 

companies went out of business. 

Abundant trout and whitefish populations supported a century of commercial fishing. More than 

100 fishing families were based on the island at the peak of the industry in the early 1900s. 

However, fish populations declined severely when the arrival of the decimating lamprey 

compounded the pressures of commercial fishing. Even though fish populations rebounded in 

later decades the establishment of Isle Royale National Park meant an end to widespread 

commercial fishing operations. 

Many of Isle Royale’s early visitors were drawn by natural resources but found that the isolation 

and wilderness of the area limited their ability to access those resources. Around the turn of the 

twentieth century, tourism began to blossom at Isle Royale. The isolation and rugged nature of 

the area that draws visitors today appealed to Americans a century ago, as they sought escape 

from hot, crowded and dirty cities, as well as hay fever. Transportation companies, looking for 

3.4 Cultural Resources
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additional passengers, fostered the growth of tourism to Isle Royale, as they had successfully 

done in places like Yellowstone and Yosemite. Lodges and resorts opened at Washington Island, 

Belle Isle, Tobin Harbor and Rock Harbor; commercial fisherman operated other, smaller sites. 

The clean air and healthful attributes of the rustic setting as well as opportunities for rugged 

forms of recreation were advertised themes to Americans learning to cope with the changing 

reality of modern life. Resort tourism thrived in the first three decades of the twentieth century 

and helped give rise to the idea of a making the island a National Park.

Many who visited Isle Royale found that they wanted a more permanent relationship with the 

island. The area had been surveyed in the early years of the century and land was available for 

purchase. Families began to build summer cabins in places like Tobin Harbor, Washington 

Harbor and Rock Harbor. Other people, who could not afford to or did not choose to purchase 

land, constructed cabins or fish camps and occupied the areas anyway. Small, protected islands 

or pieces of lakeshore were popular purchases and soon dozens of cabins were built on the main 

island and on islands in the surrounding archipelago. When the National Park was established 

many cabin owners were given a unique opportunity to sell their land and stay on as “life 

lessees.” Some of their families still live in those cabins today. Those who occupied lands 

without ownership were paid to relinquish their rights but most were not given the opportunity to 

stay.

The Civilian Conservation Corps (CCC) played an important role in the construction of trails and 

facilities on the island. CCC camps were located at Siskiwit Bay, Rock Harbor (Daisy Farm) 

and Washington Harbor. Between 1935 and 1941 they were an important presence on the island 

and were instrumental in fighting the 1936 fire. 

As an island archipelago in the world’s largest body of fresh water, Isle Royale has a rich 

maritime history. The story of Isle Royale is the story of fishing boats, passenger liners and 

commercial shipping. To steer ships through treacherous reefs four lighthouses were established 

at Isle Royale. The island could be both a safe haven during storms and a deadly obstacle that 

has claimed numerous vessels over the years. Boat traffic brought occasional tragedy and Isle 

Royale is well known for its many shipwrecks. Ten major ships and many smaller vessels have 

sunk in Isle Royale waters and the island is an important destination for experienced divers.

Cultural sites are an important part of Isle Royale National Park. These sites document the 

diverse human uses of the island over thousands of years. They give perspective to the power of 

Lake Superior and the isolation of this wilderness island. The visitor can better understand the 

natural environment when confronted by past human experience at Isle Royale. 

3.4.2 Archeological Sites

The earliest evidence of human use of the island is found in the 186 designated archeological 

sites found in the park. These sites include copper mining pits, native/European contact and 

trade sites, historic settlements and lighthouse sites. Archaic period peoples (approximately 

2500 to 1000 BC) are connected to at least twelve identified archeological sites. Initial (1000 

BC to 700 AD) and Terminal or Late (600 – 1650 AD) Woodland people are associated with 

many more sites. In all more than 1000 mining pits scattered throughout the park are attributed 

to these native groups. 
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The Minong Mine site is presently listed on the National Register of Historic Places and the 

majority of the other 186 archeological sites have been recommended for nomination. These 

sites contain potential information about the island’s earliest uses and may be determined eligible 

for the National Register. 

Archeological sites also contain historic remnants along with prehistoric evidence. Mining pits 

and settlements and lighthouse-associated sites have all been identified from the historic period. 

Fur trade and Native/European contact goods have been found in various places. Many historic 

activities such as commercial fishing and fur trading occurred on or near prehistoric sites. 

Many known archeological sites have been identified as a result of NPS trail and campsite 

construction. The location of campgrounds – primarily along the coast of Lake Superior and the 

inland lakes – is also the natural location of historic and prehistoric activity. Additionally, much 

of the park’s interior has not been surveyed and may contain numerous undiscovered sites. 

3.4.3 Historic Structures

The park contains approximately 180 structures that are more than 50 years old, most of which 

are located within the park’s wilderness and backcountry. These structures are from the various 

historic eras of island use and development. Some of the structures are representative of the 

island’s maritime heritage, such as lighthouses and fishery sites. Many cabins, hotels and 

associated buildings are from the resort era and the early development of the park idea at Isle 

Royale. 

Three of the four lighthouses within the boundaries of Isle Royale National Park are listed on the 

National Register of Historic Places. The 1855 Rock Harbor Lighthouse is the oldest existing 

structure in the park and under NPS jurisdiction. Control of the three additional lighthouses (Isle 

Royale Lighthouse at Menagerie Island, Passage Island Lighthouse and Rock of Ages 

Lighthouse) is in the process of being transferred from the Coast Guard to Isle Royale National 

Park. Two of these structures, Isle Royale and Rock of Ages, are listed on the National Register, 

while the Passage Island Lighthouse has been determined eligible but has not been nominated, 

yet. 

Two other locations are also listed on the National Register - the Edisen Fishery in Rock Harbor 

and Johns Hotel in Washington Harbor. Together these locations have a total of thirteen 

structures listed on the Register. While these are the only structures currently listed on the 

Register, the Michigan State Historic Preservation Officer (SHPO) has declared another 

approximately 145 structures eligible for listing. 

The Edisen Fishery is only one of the many sites used as commercial fishing camps. For a 

century, from the 1830s until the establishment of the National Park, Isle Royale was a base for 

commercial fishing. Other sites include Wright Island, Crystal Cove, Fisherman’s Home, 

Barnum Island and Washington Island. At many of these sites buildings (fish houses, net houses 

and cabins) along with boats and docks remain intact. However, with the exception of the 

Edisen Fishery, the fishermen are gone and at several of the historic fishing camps the buildings 

are rapidly deteriorating.
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Many of the summer cabins built during the resort era remain, some of them still occupied by the 

families of the original occupants. Eight life leases are currently in effect, as are five Special use 

Permits issued to the children of lessees. Most of these leases and permits are for cabins in 

Tobin Harbor. Some historic buildings (including former lessee cabins and Civilian 

Conservation Corps facilities) have been converted to park use. Volunteer-in-Park agreements 

help the park manage the difficult task of maintaining this array of historic structures. Many of 

these structures are located in potential wilderness additions. 

3.4.4 Cultural Objects

Many of the archeological items found at Isle Royale are kept at the Midwest Archeological 

Center in Lincoln, Nebraska. Isle Royale’s own museum collection is housed in a storage 

facility in Houghton. This collection contains a general representation of the island’s cultural 

and natural resources. Shipwreck artifacts, commercial fishing gear and household goods, 

summer home items and archeological artifacts are all part of the collection. The majority of 

archives and artifacts located in the park are found at Mott Island, with a few items kept at the 

Rock Harbor and Windigo Visitor Centers, the Edisen Fishery and Rock Harbor Lighthouse. 

3.4.5 Cultural Landscapes

Cultural landscapes are geographic areas of the park that include natural and cultural resources 

and that have cultural significance when taken as a whole. This includes areas associated with 

an historical event, activity or person and areas that exhibit cultural or aesthetic values. The 

cultural landscape program at Isle Royale is new. Currently, only the Edisen Fishery, Rock 

Harbor Lighthouse, Barnum/Washington Island, Fisherman’s Home and Crystal Cove have been 

identified as cultural landscapes, but several other areas around the park need to be evaluated for 

cultural significance. With control over the remaining lighthouses (Isle Royale, Rock of Ages 

and Passage Island) being transferred to the NPS these sites should be evaluated as cultural 

landscapes.

The summer cottages area of Tobin Harbor has the potential to be recognized as a cultural 

landscape. Many of the original cottages remain, including several that are still occupied by the 

families who owned the land when Isle Royale became a National Park. Two of the summer 

cottages in Tobin Harbor are being preserved and used by the NPS, one for the artist-in-residence 

program and one as a park residence. Tobin Harbor with its protected waters and many small 

islands was a popular choice for resort-era families looking to build a cottage at Isle Royale. It is 

the best-preserved example of the summer cottage community at Isle Royale. 

Washington Harbor also had summer cabins but was better known for its thriving commercial 

fishing community. During the 1920s and 1930s over 20 fishing families lived in Washington 

Harbor. The entire harbor area should be evaluated for possible cultural landscape status. Aside 

from Edisen Fishery, the best-preserved examples of commercial fishing are Crystal Cove at the 

Northeast End of Amygdaloid Island and Fisherman’s Home in Siskiwit Bay. These sites retain 

a high degree of historical integrity and are mentioned in the General Management Plan as high 

priorities for restoration efforts. Other fishing sites on the north shore of the park should also be 

considered for cultural significance. These sites should all be evaluated as cultural landscapes. 
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Historic mining sites, including mine shafts, rock piles, partial structures, dams, stamp sand, 

wells, roads and tramway remains have the potential for cultural significance. Locations to be 

evaluated as cultural landscapes include Siskowit Mine, Minong Mine, Island Mine, Wendigo 

Mine and Todd Harbor’s Haytown Mine. 

3.4.6 Ethnographic Resources

Ethnographic resources have significance to native peoples or historic island communities and 

include prehistoric and historic sites, structures, landscapes, fauna and objects as well as natural 

resources like rivers, watersheds and plant species. At present few ethnographic resources have 

been documented at Isle Royale National Park. The only detailed ethnographic study completed 

so far has been that of the culture of Scandinavian commercial fisherman in the first half of the 

twentieth century. A study of the vernacular boat-building traditions of the fisherman has 

documented their cultural traditions and use of island resources. 

The NPS has documented hundreds of plant species used historically or currently by the 

Ojibway/Chippewa Indians. The occurrence and distribution of these plants at Isle Royale is 

unknown. Known examples of ethnobotanic species significant to native peoples and found at 

Isle Royale are sugar maple, used for sugar production and pearly everlasting, used in medicines. 

It is possible that the Ojibway people of the north shore of Lake Superior still use the island’s 

resources, however the park staff has no knowledge of such use. It is likely that additional 

ethnographic resources exist in the park.

The affected economic region includes Houghton and Keweenaw Counties in Michigan and 

Cook County in Minnesota. These areas have harsh and long winters, limited economic 

opportunities, and a significant economic reliance on tourism and recreation. There are no major 

metropolitan areas in any of these counties. The largest community is the city of Houghton, MI, 

with a population of 7,010 (2000). The socioeconomic factors most relevant to this WBMP 

would be: 1) consideration for the communities of Copper Harbor and Houghton, MI, and Grand 

Portage, MN, where ferries to Isle Royale are based; 2) communities surrounding these areas that 

may offer services to Isle Royale visitors; 3) changes in NPS staffing or contracting that may 

affect local jobs and associated economics, and; 4) changes in NPS policies that may affect Isle 

Royale-dependent businesses. 

3.5.1 Surrounding Communities

Keweenaw and Houghton Counties, MI, and Cook County, MN, share a similar history of a once 

profitable reliance on resource extraction, followed by years of economic and population decline 

in the mid to later 1900s, and a transition to the more recent significant economic reliance on 

tourism and outdoor recreation. All three counties are sparsely populated compared to the rest of 

their states. Population estimates in 2001 list 35,698 residents in Houghton County, 2,257 in 

Keweenaw County, and 5,170 in Cook County.

3.5 Socioeconomic Environment
Socioeconomic Environment

138 CHAPTER 3: AFFECTED ENVIRONMENT

Income, Employment, and Poverty

Table 15 outlines the annual per capita income for each of the surrounding communities, and 

state and national averages from 1997-2001. All 3 counties consistently fell below the national 

and state averages. This region also falls below falls below national and state averages for wages 

per job (Table 16). The major individual employer in the Keweenaw region (Houghton and 

Keweenaw Counties) is Michigan Technological University, followed by health care providers 

and local school systems. The major employers in Cook County are government and the service 

and retail industry. Table 17 outlines the region’s unemployment and poverty rates. 

Table 15: National, State and County Per Capita Personal Incomes 1997-2001.

1997 1998 1999 2000 2001

US average 25,412 26,893 27,880 29,760 30,413

Michigan 25,509 26,860 27,906 29,408 29,629

Houghton County 17,863 18,326 19,180 20,135 21,141

Keweenaw County 17,525 17,389 18,360 18,856 18,991

Minnesota 27,086 29,092 30,194 32,231 33,059

Cook County 23,070 24,423 25,745 27,036 28,257

Table 16: National, State and County Average Wage per Job 1997-2001

1997 1998 1999 2000 2001

US average 29,805 31,336 32,715 34,647 35,550

Michigan 32,105 33,766 35,024 36,251 36,661

Houghton County 21,144 21,603 22,335 22,889 25,112

Keweenaw County 15,602 16,208 17,296 18,351 16,549

Minnesota 29,599 31,312 32,650 34,582 35,736

Cook County 18,808 19,416 20,046 20,566 20,634

Source for both tables: Regional Economic Information System, Bureau of Economic Analysis, 

Economic and Statistics Administration, U.S. Department of Commerce, 2004 

(http://www.bea.gov/regional/reis)

Table 17: Unemployment and Poverty Rates (2000 census data)

Unemployment Below Poverty

Michigan 5.8 10.5

Houghton County 7.9 16.8

Keweenaw County 11.1 12.7

Minnesota 4.1 7.9

Cook County 6.2 10.1

Source: US Census Bureau http://quickfacts.census.gov

Visitor Services

The Keweenaw Peninsula, MI, and Cook County, MN, are promoted as tourist destinations with 

a focus on outdoor recreation. Hiking, boating, camping, fishing, and hunting are promoted in 
Socioeconomic Environment

CHAPTER 3: AFFECTED ENVIRONMENT 139

the Spring, Summer and Fall, and snowmobiling and skiing are promoted in the Winter. All 

three counties include multiple state parks and other recreational lands, in addition to access to 

Isle Royale National Park. Many visitor services are available in the area to support this tourism 

industry, for the most part focusing on more rustic accommodations rather than heavily 

developed destination sites. These services include camping and lodging facilities, restaurants, 

grocery stores, gift shops, outdoor equipment retail and rental shops, automotive services, 

emergency and medical services, and visitor and information services. With a larger population 

center, there are more of these services available in Houghton County than Keweenaw and Cook 

Counties. Visitors to Isle Royale National Park may use these services before and after trips to 

the island, especially those visitors requiring accommodations the night before leaving on a 

morning ferry. 

3.5.2 Business/Economic Activities Related to Wilderness and Backcountry 

Several private companies operate under concessionaire contracts with the NPS to provide visitor 

services on Isle Royale. These include the sea plane, 2 ferry companies operating 3 of the 4 

ferries, and the Rock Harbor Lodge with 2 stores, laundry and shower facilities, a restaurant, 

boat rentals, water taxi service, fishing charters, a tour boat, and lodge with motel and 

housekeeping units. All of these are associated with backcountry and wilderness visitors and 

services. 

There are several smaller business operations associated with Isle Royale that operate under 

incidental business permits (IBPs). Outfitters, camps, backcountry guide services, fishing and 

dive charters, and sailing outfits are some of these permittees. To date IBPs have been issued 

based on the compatibility of services offered with Isle Royale’s mission and management goals 

and the business’s ability to adhere to park regulations. There has not been an allocation quota 

or any limit on the number of businesses operating within the park, or the number of trips each 

business may take. The number of permits issued is, however, limited by demand for the 

services offered by these businesses. In 2003, 44 businesses or other organizations held permits, 

with a total of 95 overnight trips in the park, 774 associated visitors, and 4267 backcountry 

overnights. This represents less than 3% of all the backcountry permits issued in 2003, and less 

than 10% of total backcountry overnights. The majority of these permit holders (70%) were 

organizations leading backpacking trips, primarily as large groups of 7-10 people.

3.5.3 Economic Contributions of Isle Royale to the Region

It is estimated that visitors to Isle Royale spend approximately $1.7 million annually in the local 

communities, with the bulk of this being spent on ferries, motels, and gas. It is further estimated 

that the direct effects of this spending in the three gateway communities is $695,000 in wages 

and salaries. Most of the related local jobs are with the ferry companies and motels. The tax 

effects of direct sales and income total $51,000 in sales tax and $134,000 in income taxes 

(Strong and Solomon 2004).
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140 CHAPTER 3: AFFECTED ENVIRONMENT

3.6.1 Organization

Isle Royale’s Superintendent is responsible for overall management and operation of the park. 

Park operations are organized into five divisions: Administration, Maintenance, Ranger 

Activities, Interpretation and Cultural Resources Management, and Natural Resources 

Management. The Division of Ranger Activities carries out programs that include emergency 

services, SCUBA diving, law enforcement, concessions management, public education, and 

resource protection. Natural Resources Management is responsible for natural and social 

sciences research, data collection, inventory and monitoring, data analysis, visitor statistics 

management, and report writing. Interpretation and Cultural Resources Management is 

responsible for cultural resources research and monitoring, public education and information 

services, operation of the visitor centers, issuing backcountry and incidental business permits, 

collecting park fees, Ranger III and group camping reservations and leading guided hikes in the 

park. The Maintenance Division includes trails and dock crews, and is responsible for planning, 

design, construction, operation, and maintenance of all facilities and infrastructure within the 

park’s wilderness and backcountry. 

All divisions share the various facets of wilderness and backcountry management. For example, 

the Division of Interpretation issues backcountry permits, while the Resources Management 

Division manages the permitting database, visitor statistics, and related monitoring. Further, 

backcountry permits are issued from 5 locations; Houghton, Rock Harbor, Windigo, the Ranger 

III, and the US Forest Service Visitor Center in Grand Marais, MN. Due to technological 

challenges on the island, none of these permitting stations are electronically linked. All of these 

factors hinder communication and coordination of backcountry services and recreation 

management in the park. 

3.6.2 Staffing and Budget

The park as a whole is allotted approximately 56 FTE’s (Full Time Equivalency positions), 

which include all permanent staff as well as seasonal and field positions. Only about 1⁄4 of the 

positions work year-round. Between May and September the majority of Isle Royale employees 

are stationed on the island, based out of Rock Harbor, Mott, and Windigo. From November 

through April year-round employees are based out of the Houghton headquarters. 

In 2003 Isle Royale’s annual base budget, allocated from Congress, was $3.2 million. The 

majority of this covered personnel and park operations such as utilities operations on the island, 

and the operation, upkeep, and fueling of park boats and generators. Additional funding comes 

from visitor fees, fees from businesses operating within the park, and short-term special project 

funds. Annual spending breaks down by functional areas as follows: 1) 28% for facility 

operations; 2) 25% for maintenance; 3) 20% for management and administration; 4) 18% for 

visitor experience and enjoyment, which includes visitor center operations and visitor safety 

services; and 5) 9% for resource protection (ISRO Business Plan 2001). Isle Royale has access 

to additional project funds, which are awarded to parks on a competitive basis for anything from 

3.6 Park Operations
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CHAPTER 3: AFFECTED ENVIRONMENT 141

construction or maintenance projects to research. Some of the changes proposed in the WBMP 

may affect Isle Royale’s staffing and budget to some extent.

3.6.3 Existing Facilities

Isle Royale has a visitor center in its administrative headquarters in Houghton, MI, at the point of 

embarkation on the Ranger III park boat that carries visitors across Lake Superior to Isle Royale. 

The park’s summer headquarters are on Mott Island, about four miles southwest of Rock Harbor. 

Mott Island facilities include a boat repair/carpenter shop, warehouse/maintenance building, 

central office building, generator powerhouse, bulk fuel storage tanks, water treatment facility, 

and employee housing (duplexes, single-family houses, and dormitories). Most park operations 

are conducted or supported by employees living and working at Mott Island. NPS facilities are 

also located at Malone Bay, Amygdaloid Island, Windigo and Rock Harbor. Both Windigo and 

Rock Harbor have a generator powerhouse, bulk fuel storage tanks, water treatment facility and 

employee housing.

Rock Harbor, near the northeast end of Isle Royale, contains a number of visitor facilities, 

including docks, gas pumps, a store, restrooms, showers, laundry facilities, sewage pump-out 

services, ranger station, contact center, campground, auditorium, and lodging facilities. A 

concessionaire operates 20 housekeeping cabins, 60 motel units, restaurant, public showers, and 

other facilities at Rock Harbor. Full service operations run from mid June to early September 

every year. The concession company employs about 60 workers during peak summer season, 

most of whom are housed in a large dormitory. Tobin Harbor, adjacent to Rock Harbor, offers 

boat docks, boat rentals, and a sea plane dock.

The Windigo ranger station and visitor center are located near the southwestern end of Isle 

Royale. Facilities here include a dock, sea plane landing, campground, restrooms, sewage pumpout services, gas pump, general store and amphitheatre. A concession company operates the 

general store as well as showers, laundry, gasoline pump, and limited canoe and small boat 

rentals. There are no overnight concession accommodations available at Windigo. 

A limited number of other visitor facilities are available at Daisy Farm, Edisen Fishery, the 

Malone Bay Ranger Station, and Amygdaloid Ranger Station. 

Isle Royale’s network of about 20 hiking trails is approximately 165 miles in total length. The 

trails include approximately 14,000 maintained erosion control devices (drainage, water bars, 

etc.), six miles of bridging, and 160 trail and campground signs. There are 36 campgrounds in 

the park, over half of which are located along the Lake Superior shoreline. These campgrounds 

include a total of 90 pit toilets, 88 shelters, and 112 individual tent sites. Slightly less than half 

of the campgrounds contain group campsites, for which reservations are required. Trail and 

campground maintenance is conducted by a seasonal trail crew along and several volunteer 

groups. Insufficient maintenance and recreation management in recent years has led to increased 

erosion and development of informal, unauthorized trails and campsites. 

The park has 70 boat docks that vary considerably in size; two-thirds are available for use by 

visitors. Almost half of them are associated with campgrounds along the Lake Superior shore. 

Some of the docks are more than 30 years old and need significant repair or replacement. Isle 
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142 CHAPTER 3: AFFECTED ENVIRONMENT

Royale’s marine operations depend on its fleet of 30+ boats, which range from 16 to 165 feet in 

length, with both diesel and gasoline fueled vessels. 

3.6.4 Emergency Response Services

Without any road access to Isle Royale, emergency services rely on boats, helicopters, and 

seaplanes. Isle Royale’s Law Enforcement Division maintains an island-based staff of welltrained EMTs and an ongoing partnership with Keweenaw and Houghton County hospitals. 

Helicopter flights for emergency evacuations are available through hospitals in Thunder Bay, 

Ontario and Duluth, MN, with suitable landing pads located on Passage Island, Mott Island, and 

Windigo. The US Forest Service Beaver out of Ely, MN has also assisted the NPS in 

emergencies. Emergency response time is dependent on resource availability and weather, with 

lake and visibility conditions limiting boat, helicopter, and seaplane response times. 

Emergencies occurring inland further require travel by foot from the nearest dock or boataccessible shoreline. Isle Royale’s thick forests, rugged terrain and narrow trails preclude 

motorized emergency response to most land areas of the park. 
Methodology

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 143

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

The National Environmental Policy Act (NEPA) requires that an assessment of environmental 

impacts be completed for proposed federal actions and feasible alternatives to those actions. 

This includes full disclosure of any adverse environmental effects that cannot be avoided if a 

proposed action is implemented. Effects on historic properties are also considered in accordance 

with the National Historic Preservation Act (NHPA). Environmental effects and impacts for 

these purposes are changes in the condition of a resource or environment due to a proposed 

action. This analysis is the basis for comparing the beneficial and adverse effects of 

implementing alternative actions, allowing decision-makers to determine which approach would 

create the greatest benefits with the fewest adverse effects. This environmental impact statement 

for the WBMP is on a general, programmatic level where proposed actions are general and

conceptual in nature. Specific proposed actions such as new cabins in Rock Harbor, any new 

campsites or campgrounds, or any new trails, that would come as part of the implementation 

phase of this plan would require additional more detailed analysis of environmental impacts once 

the precise location and extent of actions is determined. These analyses may take the form of 

Categorical Exclusions, Environmental Assessments, or Environmental Impact Statements, 

depending on the scope and nature of potential impacts and will be tiered off of this document. 

Following the NPS guidelines for NEPA (Director’s Order 12), there are several categories of 

impacts to be considered:

• Direct effects are caused by an action and occur at the same time and place as the action.

• Indirect effects are caused by an action and occur later in time, or in a different location 

than the action itself, but are still reasonably foreseeable.

• Duration of the impact may be short or long-term. If an impact were short-term within 

a short period of time (less than five years) a resource would return to its predisturbance 

condition. A long-term impact would change a resource to such an extent that it would 

not return to its predisturbance condition and for all practical purposes would be 

considered a permanent change. 

• Type of impact may be beneficial or adverse.

• Intensity of impact may be negligible (barely detectable with little discernible effect), 

minor (a slight but noticeable effect with a small scale of impact), moderate (clearly 

noticeable, widespread appreciable effect), or major (highly noticeable, widespread effect 

causing substantial change).

• Cumulative impacts are incremental impacts of an action when added to other past, 

present, and reasonable foreseeable future actions, regardless of who takes the other 

action.

A final step in assessing the environmental consequences of each of the alternatives is to identify 

the environmentally preferred alternative. This is the alternative that will promote the national 

environmental policy as expressed by NEPA. 
Methodology

 144 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

A variety of methods were used to assess probable impacts of each alternative. Published and 

unpublished literature discussing the impacts of human activities on each of the resources was 

reviewed. This included a review of literature and data specific to Isle Royale as well as more 

general literature from relevant fields. Additionally, similar planning efforts and assessments of 

environmental consequences from other national parks and wilderness areas were reviewed. 

Particular attention was given to research from similar ecosystems or areas facing similar 

management issues.

In addition to literature reviews, relevant subject-matter experts were consulted for their 

professional opinions of environmental consequences of possible actions and feasible mitigative 

measures throughout the planning process. Some of this consultation led to additional research. 

The personal observations of experienced Isle Royale employees, interest groups, individual 

visitors, and park partners were also incorporated into the assessment process. 

4.1.1 Impacts to Visitor Use and Experiences

Analysis of impacts to visitor use and experience considered: 1) annual and seasonal changes in 

visitation with implications for access to the park and quality of experiences; 2) opportunities for 

a range of appropriate recreation experiences; and 3) safety of park visitors. Isle Royale’s visitor 

use statistics from 1978 through 2003, permitting databases from 2001 and 2003, and Isle 

Royale’s backcountry travel simulation model were used in analyzing past visitor use patterns 

and projecting possible future scenarios. 

Judging whether changes to people’s experiences are positive or negative is subject to personal 

preferences; what may be viewed as desirable change by some people could be considered 

undesirable by others. Therefore this analysis focused on quantifying impacts to visitor use 

levels and experiences caused by the actions proposed in each alternative, rather than 

subjectively determining whether these impacts would be adverse or beneficial. The 1996 

survey of visitors to Isle Royale offered guidance in this area by highlighting the opportunities 

that were most important to visitors (Pierskalla and others 1997):

• Backcountry hikers and paddlers prioritized restorative opportunities such as observing 

scenic beauty, being in a natural setting, observing and hearing wildlife, and relaxing. 

They also sought perceptual orientations to the park (satisfying curiosity, enjoying the 

smells and sounds of nature, and getting to know the park), personal development 

(developing skills and abilities and improving physical health), and learning about nature 

(especially wolves and moose).

• Powerboaters and sailors who visit Isle Royale’s backcountry similarly prioritized 

restorative opportunities such as relaxing, observing scenic beauty, and being in a natural 

setting. They also sought perceptual orientations to the park (satisfying curiosity, 

enjoying the smells and sounds of nature, and getting to know the park), as well as 

opportunities to powerboat and catch fish.

More general guidance is available through NPS policies and provisions. The 1991 Vail Agenda 

addressed access and enjoyment as one of six strategic objectives for improving NPS 

stewardship and management into the 21st century, clarifying NPS goals:

4.1 Methodology
Methodology

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 145

While public access and enjoyment are essential elements of the purpose of the park 

system, it should not be the goal of the National Park Service to provide visitors with 

mere entertainment and recreation. Rather, the objective should be to provide the public 

with enjoyment and enlightenment attendant to those park attributes that constitute each 

unit’s special meaning and contribution to the national character. This is use and 

enjoyment on the park’s terms. It is entertainment, education, and recreation with 

meaning. (NPS 1991 p. 20)

Impacts to visitor use and experiences were determined considering the best available 

information, including several years of visitor surveys, visitation data and annual reports, and 

visitor distribution modeling, all of which are specific to Isle Royale. Additionally, literature 

from wilderness and recreation research was reviewed for applicability and guidance. 

The anticipated changes in visitor use levels were quantified wherever possible. However, the 

expected changes in visitor experiences are conceptual in nature, and therefore these impacts 

were assessed in general qualitative categories.

Negligible — Visitors would likely be unaware of any effects associated with implementation 

of the alternative. 

Minor — Changes in visitor use and/or experience would be slight but detectable, would affect 

few visitors, and would not appreciably limit or enhance experiences identified as 

fundamental to the park’s purpose and significance.

Moderate — Some characteristics of visitor use and/or experience would change, and many 

visitors would likely be aware of the effects associated with implementation of the alternative; 

some changes to experiences identified as fundamental to the park’s purpose and significance 

would be apparent.

Major — Multiple characteristics of visitor experience would change, including experiences 

identified as fundamental to park purpose and significance; most visitors would be aware of 

the effects associated with implementation of the alternative.

4.1.2 Impacts to Wilderness Character

Working from the definitions given in the Wilderness Act and clarification under the Wilderness 

Management section of the WBMP (Chapter 3 §3.2), the following qualities or values of 

wilderness character and impacts from proposed actions can be compared in each of the 

alternatives:

Naturalness

• Surroundings that generally appear to have been affected primarily by the forces of 

nature, with the imprint of man’s work substantially unnoticeable

Wilderness Experiences

• Opportunities for solitude, privacy and isolation

• Opportunities for primitive and unconfined recreation, with personal challenge and selfsufficiency

• Freedom from the reminders of society

• Absence of distractions such as large groups, mechanization, unnatural noise, signs, and 

other modern artifacts
Methodology

 146 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Additionally, the analysis considers whether any actions in the alternative would have the 

potential to change the legal wilderness status of all or a portion of Isle Royale. 

Analysis of the environmental consequences of each of the alternatives focused on the threats 

posed by administrative and visitor activities probable in each alternative. The authoritative text 

Wilderness Management (Hendee and Dawson 2002, pp. 355-369) provides an overview of the 

most significant potential threats to wilderness character. The threats most relevant to the 

actions proposed in this WBMP were the focus of assessing the consequences of each of the 

alternatives:

• Administrative access, facilities, and intrusive management: the extent to which 

managers use motorized and mechanical equipment affects how visitors view these 

devices and their views of what wilderness should be. The use of motorized equipment 

dilutes wilderness solitude and natural quiet and can damage resources.

• Increasing public and commercial recreational use and efforts to control them: overuse of 

wilderness areas has both social and ecological impacts. Concerns with recreational use 

may include overall increases in visitation, increases in certain areas, increases at certain 

critical times, as well as changes in travel patterns. The efforts to control recreational use 

impacts are also a threat, because regulation of activities takes away from the freedom 

and spontaneity that many visitors associate with a wilderness experience. 

Additional serious threats to wilderness are being addressed in other management plans for Isle 

Royale, and are beyond the scope of the specific actions proposed in this management plan. 

These include:

• Invasion of exotic and nonnative species—addressed in the Natural Resources 

Management Plan (1999), with ongoing efforts to better understand specific species, and 

effective measures for control.

• Wildland fire suppression—addressed in Isle Royale’s Fire Management Plan (2004).

• Aircraft noise and airspace reservations—addressed in Isle Royale’s Aviation 

Management Plan (2008)

• Lack of political and financial support for wilderness protection and management—

addressed in Isle Royale’s Business Management Plan (2002) and Isle Royale Strategic

Plan. 

Trade-offs between often competing goals are additional considerations in assessing the 

implications of proposed actions in each of the alternatives. David Cole (2000) outlined 

conflicts between wilderness attributes of wild, natural, uncrowded and free. Most relevant to 

the issues being addressed in the alternatives of this WBMP is the potential conflict between 

managing for uncrowded conditions and managing for freedom of access and spontaneity and 

freedom from excessive behavioral restrictions. Cole warns that compromises that establish 

restrictions to limit use may not fully achieve uncrowded conditions, but result in displacing 

people to locations or times that had not been previously crowded. The danger is that this would 

result in conditions that are more homogeneous and neither very uncrowded nor very free. 

Projected implications of these types of compromises will be assessed for each alternative. 
Methodology

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 147

The severity of impacts was also assessed. Negligible impacts would have no discernible effect 

on naturalness, wilderness character, or other wilderness values. Minor impacts would be 

detectable and affect a limited area that meets wilderness criteria. Moderate impacts would be 

apparent and affect a limited area that meets wilderness criteria. Major impacts would 

substantially alter the naturalness, wilderness character, and/or other wilderness values, 

eliminating the characteristics that meet the criteria for wilderness. 

4.1.3 Impacts to Natural Resources

The types of impacts to natural resources that could occur as a result of visitor and administrative 

activities in Isle Royale’s wilderness and backcountry were assessed by first identifying the 

vulnerable resources within the park, then looking at the types of activities that may have 

impacts. The planning team assessed impacts to natural resources by reviewing relevant 

literature and data, consulting with subject matter experts, and applying professional judgment 

and experience. Isle Royale-specific data that were analyzed and incorporated into this 

assessment included raptor monitoring, loon monitoring, wolf and moose monitoring, the 

quantification and monitoring of biophysical impacts in campsites, rare plant surveys and 

monitoring, and recreation travel patterns related to wildlife impacts in the park. 

The following threats are those most relevant to the actions proposed and were the focus of 

assessing the consequences of each of the alternatives:

• The impacts of recreation, research, management activities and other human actions on 

Threatened and Endangered species and their habitats.

• Damage to vegetation and soils associated with camping and hiking.

• The impacts of constructing and maintaining facilities on vegetation, soils, wetlands, and 

wildlife movement.

• Changes in visitor use patterns (both temporal and spatial) caused by management 

actions, and associated impacts to wildlife and seasonal vulnerabilities in other resources.

Where the condition of or threats to natural resources in Isle Royale National Park have not been 

studied sufficiently to quantitatively assess impacts, impacts of the alternatives were assessed 

qualitatively, using the following definitions for categorical severity of impacts. Negligible 

impacts would be at the lowest levels of detection and would have no appreciable effect on 

resources, values, or processes. Minor impacts would be perceptible, but slight and localized. If 

mitigation were needed to offset any adverse effects, it would be relatively simple to implement 

and would likely be successful. Moderate impacts would be readily apparent and widespread, 

and would result in a noticeable change to resources, values, or processes. Mitigation measures 

would probably be necessary to offset adverse effects and would likely be successful. Major 

impacts would be readily apparent and widespread, and would result in a substantial impact to or 

loss of resources, values, or processes. Mitigation measures to offset adverse effects would be 

needed and extensive and their success could not be guaranteed. 

The severity of impacts to specific resources of concern in this WBMP are defined as:

1. Soils:

Negligible—the impact on soils would not be measurable. Any effects on productivity or 

erosion potential would be slight.
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 148 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Minor—An action would change a soil’s profile in a relatively small area, but it would 

not appreciably increase the potential for erosion of additional soil.

Moderate—An action would result in a change in quality or alteration of the topsoil, 

overall biological productivity, or the potential for erosion to remove small quantities of 

additional soil. Changes to localized ecological processes would be of limited extent.

Major—An action would result in a change in the potential for erosion to remove large 

quantities of additional soil or in alterations to topsoil and overall biological productivity 

in a relatively large area. Significant ecological processes would be altered, and 

landscape-level changes would be expected. 

2. Threatened and Endangered Species

No effect—The action would cause no effect on the species status or critical habitat.

Not likely to adversely affect—The action would be expected to result in discountable 

effects on a species or critical habitat, or it would be completely beneficial.

Likely to adversely affect—The action would result in a direct or indirect adverse effect 

on a species or critical habitat, and the effect would not be discountable or completely 

beneficial. 

3. Vegetation

Negligible—The impact on vegetation (individuals and/or communities) would not be 

measurable. The abundance or distribution of individuals would not be affected or would 

be slightly affected. Ecological processes and biological productivity would not be 

affected. 

Minor—An action would not necessarily decrease or increase the area’s overall 

biological productivity. An action would affect the abundance or distribution of 

individuals in a localized area but would not affect the viability of local or regional 

populations or communities.

Moderate—An action would result in a change in overall biological productivity in a 

small area. An action would affect a local population sufficiently to cause a change in 

abundance or distribution, but it would not affect the viability of the regional population 

or communities. Changes to ecological processes would be of limited extent. 

Major—An action would result in a change in overall biological productivity in a 

relatively large area. An action would affect a regional or local population of a species 

sufficiently to cause a change in abundance or in distribution to the extent that the 

communities or population would not be likely to return to its/their former level 

(adverse), or would return to a sustainable level (beneficial). Significant ecological 

processes would be altered. 

4. Visual Resources

Negligible—An action that would introduce only the perception of some additional 

movement by boats, vehicles, or people traveling by foot. The change to the viewshed 

would be so small or localized that it would have no measurable or perceptible 

consequence to the visitor experience of the viewshed.

Minor—An action that would introduce perceptible modern human additions to the 

viewshed. These actions would include structures that affect a relatively small portion of 

the viewshed, either the foreground, middleground, or background, and have barely 

perceptible visual consequences to the visitor experience of the viewshed. 
Methodology

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 149

Moderate— An action that would introduce perceptible modern human additions to the 

viewshed. These actions would include facilities, parking, and other human-made 

structures that would affect a moderate portion of the viewshed. This might include the 

foreground and middleground, or the foreground and background. These actions would 

not completely alter the viewshed, but would be a visual addition to the existing 

conditions.

Major—An action would include major facilities and parking plus other human-made 

structures that would completely alter the foreground, middleground, and background of 

the existing viewshed.

5. Water Resources

Negligible-- An action would have no measurable or detectable effect on water quality.

Minor—An action would have measurable effects on water quality. Water quality 

effects could include increased or decreased loads of sediment, debris, chemical or toxic 

substances, or pathological organisms.

Moderate—An action would have clearly detectable effects on water quality and 

potentially would affect organisms or natural ecological processes. Alternatively, an 

impact would be visible to visitors. 

Major—An action would have substantial effects on water quality and potentially would 

affect organisms or natural ecological processes. Alternatively, an impact would be 

easily visible to visitors. 

6. Wildlife

Negligible—The impact would not be measurable on individuals, and the local

populations would not be affected. 

Minor—An action would affect the abundance or distribution of individuals in a 

localized area but would not affect the viability of local or regional populations.

Moderate—An action would affect a local population sufficiently to cause a minor 

change in abundance or distribution but would not affect the viability of the regional 

population.

Major—An action would affect a regional or local population of a species sufficiently to 

cause a change in abundance or in distribution to the extent that the population would not 

be likely to return to its former level (adverse), or would return to a sustainable level 

(beneficial). 

4.1.4 Impacts to Cultural Resources

The types of impacts to cultural resources that could occur as a result of human activities in Isle 

Royale’s wilderness and backcountry were assessed by identifying vulnerable resources, areas 

where the activities occur, and types of probable threats. The planning team assessed impacts to 

cultural resources by reviewing relevant literature and data, consulting with subject matter 

experts, and applying professional judgment and experience.

There has not been a lot of research done on the possible impacts of various kinds of visitor use 

on cultural resources at Isle Royale. Many of the cultural resources themselves are still being 

identified. As more research is done, the nature of the impacts will become more certain, but for 

the purposes of this document we have included possible impacts to cultural resources as a way 
Methodology

 150 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

to aid park staff and the public in understanding the effects of the various alternatives on the 

unique cultural resources of Isle Royale.

Where the condition of or threats to cultural resources in Isle Royale National Park have not been 

studied sufficiently to quantitatively assess impacts, impacts of the alternatives were assessed 

qualitatively, using the following definitions for categorical severity of impacts. Negligible 

impacts are those at the lowest level of detection, barely measurable with no perceptible 

consequences, either adverse or beneficial and with no adverse effect that would influence 

eligibility for the National Register of Historic Places. Minor impacts would result in little, if 

any change in character-defining features or loss of significance or integrity, and would not 

affect eligibility for the National Historic Register. A beneficial effect would include 

maintenance and /or preservation of a site or object. A Moderate impact would not alter 

character-defining features or diminish the integrity of a site or object to the point of 

jeopardizing eligibility for the National Historic Register. A beneficial effect would include 

stabilization of a site. A Major impact would diminish the significance and integrity of a site or 

object, and/or would jeopardize its eligibility for the National Register of Historic Places. A 

beneficial effect would include active intervention to restore or preserve a site. In the case of 

ethnographic resources a beneficial effect would encourage traditional access and/or 

accommodate a group’s practices or beliefs.

4.1.5 Impacts to the Socioeconomic Environment

An economic impact analysis model known as MGM2 (Money Generation Model, Version 2) 

was used to estimate the economic impacts of visitors to Isle Royale National Park under a base 

case, maximum utilization of ferryboat capacity, and four other scenarios (Strong and Solomon 

2004). MGM2 is a 2003 revised version of a model that was originally developed by the 

National Park Service, and has been updated at Michigan State University, available in 

spreadsheet format. In the application to Isle Royale, several assumptions and levels of detail 

have been modified to determine the most accurate assessment of the overall economic effects of 

tourism at Isle Royale and on the three gateway communities.

The economic impacts assessed are expressed as direct or primary and secondary sales, income, 

jobs, and value added. These impact categories are based on up to 12 sub-categories (lodging in 

motel or campground, food and beverage purchase, transportation, etc.) and sector specific 

multipliers to capture direct, indirect and induced effects through an input-output model of the 

regional economy. Direct effects are the positive economic impacts on the businesses or 

government agencies that initially receive the tourist spending. Indirect effects are changes in 

sales, income and jobs that occur for those firms that supply goods and services to the businesses 

and agencies that sell directly to the Park visitors. Finally, induced effects are changes in 

regional economic activities that occur from household spending of income earned through a 

direct or indirect effect of the visitor spending. In addition to these economic effects the model 

also determines the income and sales tax revenues that can be attributed to the tourism spending.

Several steps are followed to trace through the effects of tourism spending to determine the 

overall regional economic impacts with MGM2. First, seasonal visitation levels must be 

determined, as well as their origin from the three gateway communities and by specific 

transportation mode. Next, visitation data are used to determine average group size and party 
Methodology

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 151

nights, and these trips are attributed to visitation segment (backcountry camping, motel in the 

Park or local gateway community, etc.) including a small number of day visitors. Spending 

levels are then customized based on geographic origin and trip type, and allocated to specific 

categories for the primary, secondary and total economic effects, as well as the fiscal (state and 

federal tax) effects.

Additionally, impacts to businesses operating within the park were considered. This would 

include concessions operations running the Rock Harbor Lodge and associated services, 

transportations concessionaires, and Commercial Use Authorizations (CUAs).

Where possible, impact levels were quantified. However, in cases where impacts would be more 

general, they were categorized:

Negligible — Effects on socioeconomic conditions would be below or at the level of detection. 

There would be no noticeable change in any defined socioeconomic indicators. 

Minor — Effects on socioeconomic conditions would be slight but detectable. 

Moderate — Effects on socioeconomic conditions would be readily apparent and result in 

changes to socioeconomic conditions on a local scale. 

Major — Effects on socioeconomic conditions would be readily apparent, resulting in 

demonstrable changes to socioeconomic conditions in the region. 

With respect to type of impact for economic and social effects, few standards or clear definitions

exist as to what constitute beneficial or positive changes, and those considered adverse or 

negative. For example, rising unemployment is generally perceived as adverse, while increases 

in job opportunities and average per capita personal income are regarded as beneficial. In many 

instances, however, changes viewed as favorable by some members of a community are seen as 

unfavorable by others. For example, the impact of growth on housing markets and values may 

be seen as favorable by construction contractors and many homeowners, but adverse by renters 

and by local government officials and community groups concerned with affordability. 

Consequently, some of the social and economic impacts of the alternatives may be described in 

such a manner as to allow the individual reviewer to determine whether they would be beneficial 

or adverse (impact is indeterminate with respect to “type”).

4.1.6 Impacts to Park Operations

Impacts from actions proposed in alternatives were evaluated by assessing changes to Park 

Service operations that would be required to implement the proposal. Discussions of impacts are 

for those operations that would be new, undergo major changes, or show susceptibility to 

increases or decreases in operational activity. Impacts to staffing and Isle Royale’s operational 

organization, existing facilities, implementation and maintenance costs, and the staff’s ability to 

provide services to visitors were all considered. 

 

The analysis was conducted in terms of how park operations and facilities might vary under the 

different management alternatives. The analysis is generally qualitative rather than quantitative 

because of the conceptual nature of the alternatives. Consequently professional judgment was 

used to reach reasonable conclusions as to the intensity, duration, and type of potential impact. 
Methodology

 152 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Duration of Impact. Short-term impacts would be less than one year since most construction is 

generally completed within a year’s timeframe and would last only until all construction-related 

action items are completed. Long-term impacts would extend beyond one year and have a 

permanent effect on operations. 

Intensity of Impact. 

Negligible —Park operations would not be affected or the effect would be at or below the 

lower levels of detection, and would not have an appreciable effect on park operations.

Minor — The effects would be detectable, but would be of a magnitude that would not have an 

appreciable effect on park operations. 

Moderate —The effects would be readily apparent and would result in a substantial change in 

park operations in a manner noticeable to staff and the public. 

Major — The effects would be readily apparent and would result in a substantial change in 

park operations in a manner noticeable to staff and the public and be markedly different from 

existing operations. 

Type of Impact. Beneficial impacts would improve NPS operations and/or facilities. Adverse 

impacts would negatively affect NPS operations and/or facilities and could hinder the staff’s 

ability to provide adequate services and facilities to visitors and staff. Some impacts could be 

beneficial for some operations or facilities and adverse or neutral for others.

Financial costs of implementing proposed actions were analyzed in general terms. Minor costs 

would be those in the thousands of dollars, moderate costs would be in the tens of thousands of 

dollars, and major costs would exceed $100,000. One-time implementation costs were 

considered as well as long-term, on-going costs. Adverse impacts were considered to be changes 

that would increase operational costs and workloads for the Park Service, while beneficial 

impacts would decrease operating costs and workloads. 

4.1.7 Unavoidable Adverse Impacts

Unavoidable adverse impacts are defined as impacts that cannot be fully mitigated or avoided. In 

all of the proposed alternatives efforts were made to avoid or minimize actions that would have 

adverse impacts. Where adverse impacts could not be avoided or mitigated to meet the objectives 

of the alternative, they are explained in the following sections. 
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The assessments of impacts likely to result from proposed actions are organized by alternative, 

starting with the actions common to all alternatives. Because the alternatives vary widely in 

potential area of impact, all of the impact topics are not relevant to all of the alternatives. 

Removing or retaining picnic tables, for example, would not have the same range of impacts as 

modifying how overnight use of the park’s wilderness and backcountry is managed. Only those 

impact topics relevant to any actions proposed in the alternative are discussed. 

All of the alternatives presented would achieve the objectives of wilderness and backcountry 

management for Isle Royale with varying degrees of compromise and prioritization of objectives 

(see p. 2-3). For example, the range of alternatives present different degrees of emphasis on 

providing broad public access for recreation and/or managing human use so visitors have 

opportunities to experience solitude, remoteness, challenge, and self-sufficiency. 

4.2.1 Impacts of Actions Common to All Alternatives

Many of the actions outlined in the “Actions Common to all Alternatives” chapter would have no 

measurable environmental consequences. The actions that could have an effect are:

• The continued limited use of chainsaws for trail maintenance in wilderness and a goal to 

reduce use by increasing the use of crosscut saws.

• The use of motorized equipment for maintenance and construction projects in the 

wilderness or backcountry campgrounds, including power tools such as drills, saws and 

gas-powered punjar (jackhammer)

• The proposed addition of new low-cost rustic cabins in Rock Harbor

• Continuation of cross-country camping and anchoring out policies

• Application of the Minimum Tool Decision Process for maintenance, research and 

management activities within Isle Royale’s wilderness. 

Chainsaws and Crosscut Saws in the Wilderness

The approved use of chainsaws and the goal of increasing the use of crosscut saws within Isle 

Royale’s wilderness would be expected to affect visitor experiences, wilderness character, 

natural resources, and park operations. The continued use of chainsaws or an increased use of 

crosscut saws is not expected to have an effect on the park’s cultural resources. The main 

concerns with chainsaws concern noise and fuel and oil spills. The main concerns with 

increasing use of crosscuts involve associated changes in trail standards that may affect the 

accessibility of trails and trail conditions.

Effects on Visitor Experiences

Decreasing reliance on chainsaws and increasing the use of crosscut saws would be likely to 

leave some trails in a more primitive condition. This may include fallen trees to step over or 

walk around and more cut logs remaining in sight of the trail. This may be a beneficial change 

for people seeking more challenging conditions, or an adverse change for people who felt these 

conditions would make the trails inaccessible. Additionally, these changes may lead to increased 

4.2 Assessment of Impacts (Organized by Alternative)
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154 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

trail widening and informal trails developing around fallen trees. These effects could be longterm and wide-spread on the park’s trails and in campgrounds, depending on the extent of 

increased crosscut use and decreased chainsaw use. These effects would be direct and indirect, 

short-term, and range from minor to major.

Effects on Wilderness Character

The noise of chainsaws adversely affects wilderness character; the impacts are short-term and 

localized. Chainsaws produce noise levels from 90-125 decibels. In 1974 the EPA 

recommended that noise in wilderness areas should not exceed 40 decibels. A change of 10 

decibels is 10 times louder, and is considered to be dramatic. Therefore, the noise impacts of 

chainsaws would be considered to be minor to major, depending on proximity to the worksite. 

As chainsaw use is primarily limited to the spring and fall, the impact would be felt by a small 

percentage of wilderness and backcountry visitors, though these visitors may be people who 

place greater value on wilderness character than those choosing to visit during the park’s busier 

months. The increased use of crosscut saws and other hand tools would be expected to 

beneficially affect wilderness character through a demonstration of primitive skills and 

significantly lower noise levels. 

Effects on Natural Resources

The noise and fuel contaminants associated with chainsaw use is likely to adversely affect 

natural resources on a localized scale, with impacts expected to be minor and short-term. Spills 

of bar oil and fuel would be expected to some extent with the use and transport of chainsaws, 

though using vegetable-based oils would reduce adverse impacts to soil and vegetation. 

Mechanical noise is known to displace wildlife, though this displacement would not be expected 

to be permanent. Motorized equipment would not be used in Pristine Zones (where there are no 

trails or campgrounds) or areas closed for sensitive resources, thereby minimizing adverse 

impacts on the park’s Threatened wildlife species and their habitats. The air pollution associated 

with chainsaw use would be expected to be minor and short-term. 

Crosscut sawyers may carry a small amount of kerosene for cleaning the crosscut blade, but less 

would be expected to enter the surrounding environment than fuels used continuously to run 

chainsaws. No air pollution is associated with the use of crosscut saws. On the whole, there are 

fewer negative effects on natural resources from using crosscut saws than using chainsaws.

Effects on Park Staffing

Significantly more people and more time are required to maintain comparable trail standards 

with crosscut saws compared to chainsaws. Thus a goal of replacing some chainsaw use with 

crosscuts in Isle Royale’s wilderness would require either an increase in trail crew staff and time 

spent clearing trails, or a modification in trail standards to more primitive conditions. In many 

areas of the park, with abundant hardwood trees, it would be unrealistic to expect that trails could 

be kept open without some use of chainsaws. An increase in trail crew staff could have a 

moderate, long-term adverse effect on Isle Royale’s staffing and budget allocation. Both 

chainsaws and crosscut saws have safety risks associated with them. Because the park currently 

uses chainsaws for trail clearing, there would be a period of time before novice sawyers became 

experienced with crosscut saws, and during this learning period, there would be an increased 

possibility of repetitive motion and other injuries (just as with inexperienced chainsaw operators, 
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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 155

there is a greater chance for injury.) Novices would require thorough training and supervision by 

experienced sawyers to minimize the chances of injury.

Conclusion

Overall, increasing the use of crosscut saws and decreasing the use of chainsaws for trail 

maintenance in Isle Royale’s wilderness would help to preserve wilderness values and protect 

natural resources, but there could be both adverse and beneficial impacts on visitor experiences 

and access to trails. Additionally, trail crew staffing and workloads would need to increase to 

maintain acceptable trail standards, even with an acceptance of more primitive trail conditions.

Unavoidable Adverse Impacts

Continuing to use chainsaws to maintain Isle Royale’s trails could have an adverse impact on 

vegetation, soils, and wilderness character on an isolated local scale. Short-term high levels of 

noise and the likelihood of some soil and air contaminants through accidental fuel spills and 

emissions would continue. Additionally, trampling of vegetation and some loss of vegetation on 

a very small scale would be expected with an increased frequency of hikers walking off trail to 

avoid fallen trees. 

Power Tools in the Wilderness and Backcountry

Power tools such as drills, saws, and gas-powered jackhammers are used to maintain shelters, 

docks and outhouses at shoreline campgrounds. Some of these campgrounds are within 

designated or potential wilderness; those that are non-wilderness are adjacent to designated 

wilderness. The primary concerns with using power tools in these areas is the impact of noise, 

and the implications for staffing, workloads, and maintenance standards if these tools were not 

used.

Effects on Visitor Experiences

The use of power tools by staff on park infrastructure, including maintenance and repair of 

historic structures, can occur where it is observed or heard by visitors. Short-term minor adverse 

impacts would be limited to the sight or sound of power tools being used. Visual impacts would 

be more limited, for example someone kayaking past an historic structure and seeing tools used 

that were not available historically might be disappointed. These impacts would be to the value 

of the cultural resource experience more than to the wilderness or backcountry as a whole. 

Noise concerns would still be short-term and minor, but impacts could be broader. Power tools 

make a distinctive noise and with the natural quiet of Isle Royale, that noise can carry for a 

considerable distance, especially in the right geographic and wind conditions. Someone hiking 

in the wilderness, who is unable to see the work being performed on an historic property or at a 

campground would not be impacted visually by the use of power tools but may still hear the 

tools. When the tools are no longer in use, the associated impact ends quickly. The negative 

impacts of both the sight and sound of power tool use on are short-term and minor. 

Effects on Wilderness Character

Power tools may be used to maintain campgrounds that have docks and shelters. Some of these 

are within designated or potential wilderness; Beaver Island, Grace Island, Todd Harbor, Birch 

Island, Duncan Bay, Duncan Narrows, Merritt Lane, Tookers Island, Caribou Island, Chippewa 
Impacts of Alternatives for Overnight Use

 

156 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

Harbor, and Hay Bay. The use of power tools in these areas with their associated noise and 

reminders of modern society have direct short-term adverse impacts on wilderness character. 

The non-wilderness dockside campgrounds where power tools are used are adjacent to 

wilderness, and the use of power tools here will have indirect adverse effects on wilderness 

character; mechanized noise that can be heard a distance from the worksite. Power tools other 

than chainsaws (discussed above) are not used in wilderness campgrounds that do not have docks 

or shelters. Where the worksite is within wilderness the effects would be direct; where the 

worksite is in non-wilderness the effects on wilderness character would be indirect. Limiting the 

use of power tools, substituting quieter, battery-powered tools for generator-driven tools, and 

reducing the use of power tools during the times of peak visitation could lessen these adverse 

impacts. 

Effects on Cultural Resources

Many historic structures are located in the backcountry at Isle Royale, including structures in 

wilderness, potential wilderness and non-wilderness. Historic structures in non-wilderness 

include Edisen Fishery, Barnum Island and all four of the lighthouses. Historic structures in 

potential wilderness include the life lessee cabins in Tobin Harbor, as well as Crystal Cove, 

Wright Island and Fisherman's Home. Historic structures in designated wilderness include a 

cabin at Chippewa Harbor, the Coast Guard cabin at Minong Island, the Bangsund Fishery, the 

boathouse at Savage Island, the cabin at Horner Island, the remains of the powder house at 

Senter Point, and the remains of the cabin at Long Point (Franks, 1999).

The positive impacts to cultural resources of power tool use range from short-term minor to 

long-term major. A short-term minor positive impact would be clearing the weeds around 

Edisen Fishery with a trimmer. A long-term major positive impact would be using power tools 

to stabilize an historic structure. If power tools were forbidden, some repairs to these cultural 

resources located outside of wilderness might be too costly to complete. Historic structures and 

cultural landscapes might experience beneficial impacts from the Park Service continuing to use 

power tools in maintenance. Power tools are not generally used in archeology and the use of 

such tools should not have any effect on cultural objects or ethnographic resources.

Effects on Park Operations

Using power tools is often the most efficient means of completing maintenance work in 

campgrounds. Relying exclusively on hand tools would increase the time required to complete a 

project. Therefore, continuing to use power tools in dockside campgrounds would have a longterm minor to moderate beneficial impact on park operations, aiding in meeting maintenance 

standards with existing staffing levels 

Conclusion

Although using power tools to maintain facilities in the wilderness and backcountry does have 

short-term adverse effects on wilderness character, natural and cultural resources, and visitor 

experiences, these impacts are infrequent and transitory in nature and would not significantly 

alter any park resources or values. 
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Unavoidable Adverse Impacts

There would be unavoidable adverse environmental impacts to natural soundscapes and 

wilderness resources in areas where powertools were used, with the duration of impacts shortterm and reversible. 

Treated Lumber in the Wilderness and Backcountry

The current policy on Isle Royale is to follow NPS policy to not use arsenic-treated lumber, 

commonly referred to as CCA (chromated copper arsenate) lumber. However, there is no 

approved policy for either using untreated lumber or using the latest technologies for more 

benign chemically-treated lumber, such as ACQ (alkaline copper quaternary). Lumber is used in 

Isle Royale’s wilderness and backcountry for trail and campground structures such as bridges, 

boardwalks, and docks. 

Changes that could occur under this alternative that may have measurable environmental 

consequences include:

• Using chemically treated lumber in the construction of trail structures such as boardwalks 

and bridges. 

• Maintenance crews would remove unused or replaced treated lumber from the

backcountry as part of project completion. 

Using chemically-treated lumber in wilderness trails and campgrounds could have measurable 

consequences for wilderness character, natural resources, cultural resources, and park operations.

Effects on Visitor Experience

Visitors regularly see and use structures made of chemically-treated lumber in Isle Royale’s 

backcountry, and the effects on visitors can be classified in these two terms. Some visitors may 

be disappointed to see structures such as boardwalks and bridges in the wilderness and 

backcountry that are made of mass-produced, machined lumber. They may also prefer the 

challenge of wilderness experiences such as crossing streams without the convenience of humanmade structures. Other visitors may either not notice the structures or they may not find them 

incongruous to the setting. Some visitors may appreciate the relative convenience of having 

bridges and boardwalks for travel over or through wet areas. Therefore, the effects of treated 

lumber on visitors are expected to be minor, short-term, and either positive or negative based on 

personal preferences.

Effects on Wilderness Character

The introduction of chemical preservatives, however benign, will have some effect on the 

naturalness of Isle Royale. These impacts will be localized, it is unknown if they would be longterm or short-term, and the severity of impacts on the local level are unknown, though thought to 

be minor to insignificant. Use of treated lumber is expected to have both adverse and beneficial 

effects on people’s wilderness experiences. Using lumber with a long life span reduces the longterm quantity of lumber needed to maintain bridges and boardwalks in the park, a beneficial 

effect. However, the knowledge of materials being artificially preserved and uncertainty over 

localized ecological impacts may be in conflict with some people’s wilderness values-- an 

adverse effect. 
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158 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

Effects on Natural Resources

Isle Royale maintenance crews have made significant efforts to re-route trails to avoid wet areas 

and minimize the need for bridges and boardwalks. However, the island’s abundant wetlands are 

impossible to avoid entirely with the existing trail system. Even with the re-routes, trail crews 

maintain approximately 5.3 miles of bridging and boardwalk on Isle Royale’s trails. These 

bridges and boardwalks effectively allow hikers to cross wetlands and creeks without trampling 

fragile vegetation and habitats. Importing lumber rather than relying on local materials for this 

amount of boardwalk and bridging would have a beneficial effect on the island’s natural 

resources. These benefits would be localized, long-term, moderate on a park-wide scale, and 

potentially major on a local scale (where relying on local materials would require removal of a 

substantial number of trees and a large percentage of bigger trees). Using chemically treated 

lumber is expected to double the life-span of the lumber, further aiding natural resource 

protection by reducing the amount of lumber consumed in the long run. 

However, even the most benign chemical treatments are known to leach contaminants into soil 

and wetlands. Research conduct by USDA Forest Service research laboratories found that 

copper leached from ACQ-treated wood, with elevated levels of copper detected in rainwater, 

soil, and sediment collected adjacent to treated wood. In their study ACQ treated wood released 

the highest levels of copper in the first six months, but the levels released did not appear to have 

measurable negative effect on populations of aquatic invertebrates. These researchers 

recommended using treated wood that is produced in accordance with best management practices 

as a means of minimizing copper release and associated adverse effects (Lebow and others 

2000). Beyond this one study there has been very little research on copper leaching and 

biological impacts of these more recent wood preservatives, though, so the full risk of adverse 

impacts and their severity is unknown. One area of particular concern that perhaps warrants 

further research on Isle Royale is the fact that unionids, freshwater mussels, and all mollusks are 

very sensitive to copper concentrations (Nichols and others 2001). Further research would be 

needed to determine if levels of copper that could potentially be released from ACQ lumber 

would be of concern for Isle Royale’s pristine populations of unionids.

Effects on Cultural Resources

Treated lumber can have positive impacts on historic structures if it is used for structural support 

where untreated lumber is susceptible to rotting quickly. Treated lumber would never be used 

for the exterior of historic buildings, or in any readily observable areas because this is not in 

keeping with the historic integrity of the structures. Treated lumber used in bridges and docks 

that are part of a cultural landscape would not look historic and might be detrimental to the 

landscape.

The use of treated lumber would have no predicted impacts on archeological resources, cultural 

objects/ museum collection or ethnographic resources.

Effects on Park Operations 

Relative to using untreated lumber or local materials, using treated lumber would have the lowest 

staff and time requirements over the long-term, and therefore be the least costly to the NPS. 

Chemically treated lumber and “green” certified, sustainably harvested lumber would be 
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expected to cost more initially, but would be expected to have long-term savings. Removing 

unused lumber would add time and safety risks to each project; employees risk injury during 

transport of lumber into and out of the wilderness on fairly primitive trails. 

Conclusion

Using chemically treated and sustainably-harvested lumber for maintenance projects in the 

wilderness and backcountry would be expected to have both adverse and beneficial effects on 

park resources and values. However, nothing proposed in this alternative is reasonably expected 

to result in significant impacts to any park resources or values.

Unavoidable Adverse Impacts

A decision to use chemically treated lumber could have unavoidable adverse impacts on soils 

and water resources, through leaching of chemical preservatives. Although any adverse impact 

would be expected to be localized and small-scale, the potential severity and full implications of 

these impacts are unknown.

Low-cost Rustic Cabins in Rock Harbor

In all alternatives a few low-cost rustic cabins would be planned for construction in Rock 

Harbor. The intention is to provide additional options for people wishing to spend multiple 

nights in Rock Harbor. If this action were approved, additional on-site assessments would be 

necessary to determine impacts of constructing the cabins once suitable sites were identified. 

Thus, this assessment focuses on the more general effects of adding cabins in Rock Harbor. The 

general issues relevant to adding these cabins are the effects on cultural resources and visitation 

in the Rock Harbor area, socioeconomic effects, and effects on NPS operations. A detailed 

assessment of impacts to natural and cultural resources will be a critical component of future 

compliance once suitable sites for the cabins have been selected and prior to any construction, 

and would be part of a project-specific environmental review tiered off this document. 

Because these cabins would not be located within wilderness, nor would they be expected to 

create a significant change in visitation to the park’s wilderness, they are not expected to have an 

effect on wilderness character. 

Effects on Visitor Use and Experiences

Adding low-cost rustic cabins to Rock Harbor, with the option to rent the cabins for multiple 

nights would create a new option for park visitors. Currently the Rock Harbor Lodge with 

modern motel units and housekeeping cabins offer the only option for visitors to spend multiple 

consecutive nights in Rock Harbor. The Rock Harbor campground, and nearby Three Mile 

campground are limited to one consecutive night stay. The closest option for campers to stay in 

one place for more than one night is the Daisy Farm campground. Further, the cost of the Rock 

Harbor Lodge may preclude it as an option for many people, especially when combined with the 

cost of traveling to the island. These new cabins would be a long-term beneficial change for 

people interested in basing their visit to the park from Rock Harbor. 

A small number (2-6) of new cabins would be constructed. Thus the impact to total park 

visitation would be negligible and any increase in the number of people in Rock Harbor and 
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160 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

using the trails and waterways in the area would be expected to be a long-term minor adverse 

impact. However, there would be expected to be a greater number of people within the 

immediate vicinity of Rock Harbor. There is also a likelihood that these cabins could lead to

more people in Rock Harbor during the shoulder season when the lodge is closed. This could 

have an adverse effect on solitude during these historically quieter periods. 

Effects on Natural Resources

Constructing new buildings in Rock Harbor with the associated ground disturbance, trails and 

human presence would unavoidably have some long-term adverse effects on vegetation, soils, 

and wildlife. The extent and severity of these impacts would be determined in future 

assessments once a suitable site was selected. 

Effects on Cultural Resources

The new cabins at Rock Harbor would be located adjacent to, though not in the Tobin Harbor 

Historic District, an important cultural landscape. The area does have known archeological sites, 

but not in the locations being considered for the cabins (Clark, 1995). Additional projectspecific compliance will determine the exact impact of this development on the park’s cultural 

resources. 

Socioeconomic Effects

Because the new cabins would be intended for an experience very different from the Rock 

Harbor Lodge, this change would be expected to have a negligible or minor adverse economic 

impact on the concessions operation. This service would be very rustic, catering to people who 

would not be expected to be lodge customers. 

Effects on Park Facilities and Operations

Adding new rustic cabins in Rock Harbor would have the short-term minor to moderate costs of 

construction. Over the long-term maintenance and upkeep of the cabins would have a minor 

adverse impact on the cost and workload of maintenance in Rock Harbor. These cabins would 

not require additional long-term staff. Additionally, there would be expected to be a modest 

increase in the use of utilities in Rock Harbor associated with these cabins. This could also 

increase the workload of maintenance staff in Rock Harbor. 

Conclusion

Although adding new low-cost rustic cabins in Rock Harbor could result in adverse impacts to 

natural and cultural resources in a localized area, this action would not cause significant impacts 

to park resources or values.

Unavoidable Adverse Impacts

Constructing new cabins in the developed area of Rock Harbor would result in unavoidable loss 

of vegetation and soils within the construction area, a small-scale potentially severe impact to 

natural resources. 
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Cross-Country Camping and Anchoring-Out

All alternatives propose maintaining Isle Royale’s current policies for cross-country camping 

(dispersed camping off-trail) and anchoring out. Camping outside of designated campgrounds 

and anchoring out within park waters would continue to be permissible with special permits 

required and certain areas of the island closed to camping. This policy has ongoing implications 

for wilderness character, natural resources, cultural resources, visitor use and experiences, and 

park operations. Cross-country camping is intended exclusively for people seeking the unique 

challenges and opportunities of traveling and camping off-trail; it is not intended as an overflow 

for people who cannot find space in designated campgrounds. Therefore existing policies for 

cross-country camping are not known or expected to affect visitation numbers or business 

operations in the park and there are no expected socioeconomic effects. 

Effects on Visitor Experiences

In 2003, 139 cross-country permits were issued. While cross-country camping can negatively 

affect wilderness character and natural resources, at present use levels, it is unlikely to have a 

measurable effect on visitors in the frontcountry or visitors on trails or at backcountry 

campgrounds. This presumes that cross-country campers are practicing Leave No Trace 

principles, and are not camping near established trails or campgrounds, and therefore other park 

visitors would not be aware of their presence during hikes or while camping. It is also likely that 

negative effects to natural resources would be the limiting factor if cross-country travel 

increased, and therefore the number of cross-country permits would be limited before visitors 

noticed any negative effects of cross-country travel. In frontcountry areas, the presence of crosscountry campers would not make a discernible difference to day visitors. 

Anchoring out could negatively impact those visitors who preferred unobstructed views of bays 

and nearshore areas, or if the noise from parties anchored out could be heard at shoreline 

campgrounds or at cross-country campsites. Conversely, some boaters feel that anchoring out 

adds an important element to their park experience. The 1997 Visitor Survey asked 

powerboaters and non-powerboaters how they felt about a management action that would limit 

the number of boats to not exceed available anchorage space. 87.7% of non-powerboaters felt 

that this would be an acceptable management action, while only 24.1% of powerboaters felt that 

it would be acceptable. The majority of hikers and powerboaters surveyed in the Primitive, 

Backcountry, and Wilderness Portal zones did not feel crowded by the numbers of powerboats 

anchored out during their overnight stays, and most likewise felt that numbers of boaters 

anchored out were at or below what they expected to see (Pierskalla and others, 1998.) 

Effects on Wilderness Character

Cross-country camping and anchoring out offer the most primitive of the range of opportunities 

available for recreation at Isle Royale. The greatest degree of skill and self-sufficiency are 

required, and the greatest degree of solitude, tranquility, and primitive and unconstrained 

experiences may be attained. Maintaining these opportunities would have a beneficial effect on 

wilderness opportunities. However, were use in these areas to increase significantly, the effect 

could become adverse, with increasing signs of human impacts on park resources (an adverse 

effect on naturalness) and a decrease in opportunities for solitude and tranquility (an adverse 

effect on wilderness experiences). Area closures could be seen as an adverse impact to some 
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162 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

visitors, reducing access to some of the park’s most pristine areas, while other visitors would see 

this step to protect the park’s wilderness as a beneficial impact. Managing and potentially 

limiting how many permits are issued for cross-country camping and anchoring out could 

prevent or minimize these adverse impacts. Ongoing inventories and monitoring of impacts 

from cross-country camping will alert managers to a need to make changes in area closures, the 

number of permits issued, special regulations, and/or public education efforts.

Effects on Natural Resources

Regulations are in place to direct cross-country campers to minimize their adverse impacts on 

natural resources, including a fire ban, a limit of one night camping at each site, and a 

requirement to camp a minimum of 100 feet away from water. Where these regulations are 

disregarded adverse impacts are expected. 

Cross-country camping is known to have an adverse impact on vegetation and possibly on soils 

as well, due to trampling, damage to or loss of vegetation, loss of duff, and exposure of mineral 

soils. Recreation research has demonstrated that physical impacts from recreation occur rapidly 

and recover slowly. Initial recovery of an impacted site, with restoration efforts, is expected to 

take 5-10 years, with full recovery requiring up to 30 years (Cole 1997, Cole and Marion 1985). 

The full extent and severity of impacted sites are not fully known on Isle Royale, though few 

sites impacted to the point of exposed soil have been recorded. Illegal fires at these sites have 

also been recorded, with the adverse impact of scarring and sterilization of soils beneath the fire. 

Until a more thorough inventory of cross-country camping impacts is completed, it is thought 

that adverse impacts are localized and minor to moderate. Area closures could reverse these 

impacts and allow for site restoration. 

The continuation of cross-country camping and anchoring-out would likely have no adverse 

effect on Federally Threatened species in the park, since the most sensitive areas for these 

species are closed to camping, with closures evaluated and updated annually. However, if there 

were a significant increase in the number of people camping off-trail there could be an adverse 

effect on wolf travel patterns and their aversion to people. For this reason the frequency and 

locations of cross-country camping, as well as all wolf-human encounters in the park should be 

closely monitored. Because State- Endangered and Threatened species are widespread in the 

park, area closures have not been instituted to protect all known species and their habitats. 

However, area closures have been and will continue to be implemented to protect known highly 

sensitive areas, such as all small islands in the park. Impacts to State-protected species and rare 

and sensitive features from cross-country camping and anchoring out would likely be localized 

and not on a population level, though the severity of impacts to individuals within a population is 

unknown. Disruption of wildlife travel patterns, feeding and breeding would be expected to have 

an adverse impact on systems, as well. Ongoing inventories and monitoring of impacts from 

cross-country camping will alert managers to a need to change these policies. 

Were cross-country camping or anchoring out to increase, there could be an adverse effect on 

natural quiet with increased human noise and associated displacement of songbirds and other 

wildlife that contribute to the natural sounds of an area. Adherence to Leave-No-Trace 

principles would minimize this impact, and it is expected that the adverse effect would remain 

minor, localized and short-term. 
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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 163

Effects on Cultural Resources

Isle Royale National Park has many areas that have not yet been surveyed but are expected to 

contain archeological sites and cultural objects. Cross-country camping could have varied 

impacts on these cultural resources. Off-trail campers and hikers may discover unknown 

artifacts and objects, possibly even new archeological sites. If they leave these sites undisturbed 

and report them to the NPS, cross-country campers could add to Park Service knowledge of the 

island’s cultural resources; a long-term, minor to moderate beneficial impact. Public education 

about cultural resources, how to identify them, and why they should be left onsite could increase 

the potential beneficial effect of cross-country travelers finding previously unknown cultural 

sites. 

However, cross-country campers could also have a long-term minor to moderate adverse impact 

on archeological sites and cultural objects. They could unknowingly damage sites or objects 

when hiking or camping. They could also intentionally remove interesting artifacts including 

those unknown to park staff. Staff can mitigate this potential negative impact by informing the 

public of the importance of cultural artifacts and archeological sites and explaining how to 

recognize and respect these resources. 

Anchoring out presents a limited possibility of disturbing unknown underwater archeological 

resources. There are no known submerged sites in areas that are currently used for anchoring 

out. Continuing the cross-country camping and anchoring out policies is not expected to have 

any new impacts on historic structures, cultural landscapes or ethnographic resources. 

Effects on Park Staffing

Maintaining current policies for cross-country camping and anchoring-out, with area closures 

and no limit on the number of permits issued for open areas will require a commitment to 

monitor impacts. Knowledge of changing conditions in cross-country and anchorage areas will 

be vital to inform managers of the effectiveness of policies and any future need to alter these 

policies. This commitment will require staff time for field monitoring, data analysis, and 

interpretation for management applications, though on its own this commitment would not 

require new staff positions. 

Conclusion

Continuing existing policies for anchoring out and cross-country camping on Isle Royale would 

not be reasonably expected to impact of park resources and values, since the NPS retains the 

discretion to implement area closures and modify regulations for these types of uses if conditions 

were to degrade. 

Unavoidable Adverse Impacts

Cross country hiking and camping could have unavoidable adverse impacts to vegetation and 

soils, though monitoring of commonly used areas, effective Leave-No-Trace education, and 

adaptive management as described above would minimize these impacts, and shorten their 

severity and duration. 
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164 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

Application of the Minimum Requirement Decision Guide

The Minimum Requirement Decision Guide for Isle Royale is outlined in Appendix G. 

Applying the Minimum Requirement Decision Guide to maintenance, research, and management 

activities within Isle Royale’s wilderness could have effects on the park’s wilderness character 

and natural resources. This decision would not be expected to affect cultural resources, visitor 

use or experiences (other than wilderness experiences), socioeconomics, or park operations. 

Effects on Wilderness Character

Applying the Minimum Requirement Decision Guide to maintenance, research, and 

administration activities is expected to have a major long-term beneficial effect on Isle Royale’s 

wilderness character; both wilderness experiences and naturalness. This would ensure that 

impacts to wilderness character are considered in identifying appropriate methods and tools for 

NPS activities and NPS-sponsored activities. Adverse impacts to wilderness visitors, adverse 

impacts to naturalness, and adverse impacts to the long-term integrity of the park’s wilderness 

are given due priority in determining the appropriateness of a project, its location, tools, and 

methods of completion.

Effects on Natural Resources

Applying the Minimum Requirement Decision Guide to scientific activities in wilderness would 

be expected to affect scientific research in the park to some extent, specifically the methodology 

that would be appropriate for approved research proposals. This process would not preclude the 

use of invasive methodologies that may have an adverse effect on wilderness character, but it 

may require some projects to alter their methodologies to be less invasive. This process also 

could determine that some proposals are more appropriate to be conducted outside of wilderness. 

This process is intended to ensure that impacts to wilderness character as well as long-term 

benefits to the park’s natural resources and wilderness are considered in determining the 

appropriateness of research proposals. Invasive methodologies could still be determined to be 

appropriate, where the knowledge gained would have long-term benefits to wilderness resources 

and values that outweigh the short-term adverse impacts of the methodologies. Therefore, 

applying this process to scientific activities in the park is expected to have long-term beneficial 

impacts to the park’s natural resources, though there could be some short-term adverse impacts 

to scientific activities. 

Unavoidable Adverse Impacts

Implementing the Minimum Requirement Decision Guide to maintenance, research, and 

management activities within Isle Royale’s wilderness would not be expected to have 

unavoidable adverse impacts effects on the park’s wilderness character or natural resources.
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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 165

4.2.2 Impacts of Alternatives for Managing Overnight Use of the Wilderness and 

Backcountry

Alternative A for Overnight use: Maintain Current Management Direction

The details of Alternative A for overnight use are outlined in Chapter 2, p.56-58. Changes that 

could occur by continuing the status quo and may have measurable environmental consequences 

include:

• Visitation could increase throughout the visitor season, and would be limited only by 

ferry capacities.

• Over-crowding in campgrounds could increase, with an associated increase in campsite 

sharing and physical impacts in campsites.

• Under the current permitting system, the NPS would not have the ability to direct 

campers to campgrounds with available camping space, or give visitors accurate 

information about campground use levels.

Maintaining the current management direction with no changes in how overnight recreation is 

managed in Isle Royale’s wilderness and backcountry and no active management of annual 

visitation could affect visitor use and experiences, wilderness character, natural resources, 

cultural resources, area socioeconomics, and park operations. The main concerns with likely 

impacts are primarily related to unmanaged changes in visitation and visitor distribution, and 

inadequate visitor services for trip planning. It is impossible to accurately predict a future trend 

in visitation under this alternative. However, since this alternative would allow for a substantial 

increase in visitation and crowding in campgrounds, it is assumed that this could occur. 

Effects on Visitor Use and Experiences

Continuing the current management direction would mean that ferry capacities and schedules 

would be the only limit on the total number of island visitors and their distribution throughout 

the season and between entry points. To date Isle Royale managers have taken the approach of 

accommodating all visitors who could reach the island and were interested in appropriate types 

of recreation. Rather than managing number of visitors, the NPS has managed impacts by 

concentrating recreation use on designated trails, and in designated campgrounds. This policy 

has had both beneficial and adverse effects on visitor use and experiences. 

Chapter 3, §3.1 outlines past Isle Royale visitation in detail. In general the majority of 

backcountry and wilderness visitors come to the park in July and August. Backpackers are the 

largest visitor group in the backcountry, and the one group of visitors that appear to be on an 

increasing trend when the length of stay is combined with numbers of people. Since the mid 

1990s motorboaters have been decreasing in number. It is unknown if these trends will continue. 

Ferries do sell out periodically during late July and August, so there would be the greatest 

opportunity for increased visitation outside of this peak visitor season. However, it is expected 

that factors such as weather, bugs, and school schedules would preclude dramatic increases in 

visitation in the spring and fall. Ferry tickets are sold on a first come, first served basis, so 

increases in lodge guests or day visitors could limit the number of campers riding ferries, and 

visa versa. 
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166 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

Because of all of the complicated variables such as visitors’ willingness to visit the park outside 

of July and August, changes in the percent of ferry passengers who are lodge guests or day

visitors as opposed to campers, and uncertainties in realistic projections for boating trends it is 

very difficult to predict or quantify the extent to which Isle Royale backcountry visitors could 

reasonably be expected to increase. However, under this alternative the NPS would take no 

action that would preclude a significant increase in visitation at any point in the visitor season.

Current policies have the beneficial effect of high public access to the island for people 

interested in appropriate types of recreation, and who can afford transportation to the island. An 

additional beneficial effect is freedom of travel within the park. Travel is limited to some extent 

by regulations such as area closures, encouragement to camp within designated campgrounds, 

required site reservations for groups of 7-10 people, and a prohibition on motors within 

designated wilderness. However, flexible camping permits for parties with fewer than 7 people 

allow for a high degree of freedom and flexibility regarding where the majority of backcountry 

visitors choose to travel and camp. 

These policies have resulted in periods of overcrowding in campgrounds, with parties needing to 

double up in campsites when all sites are occupied. Visitor surveys indicate the need to share 

campsites and the sheer number of people in campgrounds as concerns (Pierskalla and others 

1997 and 1998). Continuing current or increasing levels of campsite sharing would be an 

adverse effect of this alternative. Because up to 25% of backcountry visitors are affected during 

the peak visitor season and because campground crowding would be expected to continue or 

increase, this would be a moderate, long-term adverse effect to visitor experience. 

Currently, boaters in the backcountry may raft off when dock space is not available. Based on the 

results of the 1996 and 1997 visitor surveys, it appears that there is not a consensus among 

boaters or among non-boaters about whether rafting off is a concern, and whether the park 

should limit the number of boats at docks (Pierskalla et al, 1997, and 1998). See Section 3.1.3 

for detailed survey results. It is also true that, based on review of past permits, dock usage is not 

evenly distributed throughout the park (see Table 8.) If boaters’ use of backcountry docks 

increased under the current management scheme, it is possible that it could have an adverse 

impact on boaters who do not want to raft off, and on boaters and non-boaters who are seeking a 

more solitary camping experience. Because dock crowding is a function of boater numbers, it is 

difficult to predict if the need for rafting off under the current permitting system will increase or 

decrease. Therefore it may be a minor to moderate adverse effect to visitor experience, based on 

future visitation levels.
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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 167

Unmanaged changes in visitation associated with this alternative could result in increased 

visitation in the spring and fall. This would have the adverse effect of narrowing the range of 

visitor opportunities available. Currently spring and fall offer exemplary opportunities for 

wilderness experiences during low use times. Ferry schedules would maintain October visitation 

at relatively low numbers, but could allow for a significant increase in late May and June. This 

would be an adverse effect for visitors seeking greater solitude and lower encounter rates with 

other people on trails and in campgrounds. 

Effects on Wilderness Character

With no change from the current management direction, visitation could increase up to full ferry 

capacities. There would also be no limit on increases in boaters other than the limiting factors of 

fuel costs and numbers of visitors with suitable private boats. This would mean high public 

access to the park (a beneficial effect), but with the potential for adverse impacts to wilderness 

character. Continuing or increasing visitor use levels in July and August would continue or 

exacerbate the current problems with campground overcrowding. This would be an adverse 

impact to wilderness character as overcrowding reduces people’s opportunities for solitude and 

tranquility. It further compromises wilderness character by making many campers feel a need to 

rush to a campground to find an available campsite (Isle Royale 2002). Continued or increased 

overcrowding and the associated impacts to campsite size and soil and vegetation impacts are 

further expected to adversely affect the naturalness of campsites.

Were visitation to increase significantly in the spring and fall, there could be a reduction in the 

range of opportunities for wilderness experiences available in the park, with a loss of the lowest 

use times and their greatest opportunities for exemplary wilderness opportunities. 

Effects on Natural Resources

With this alternative it is expected that campground crowding would continue and may increase. 

Because of this, campsite area and amount of exposed soil is expected to continue increasing, at 

least to some extent. Maintenance and redesign of some campsites may help to slow the 

increase. 

This increased sprawl of campsites is of concern to natural resources because of associated loss 

of vegetation, change in vegetation composition, compaction of soil and associated changes in 

soil microhabitats, erosion, and potential increase in disturbance-tolerant exotic plants (Hendee 

and Dawson 2002). Degradation of these conditions has negative implications for aquatic 

resources, soil microorganisms and their role in broader ecosystem health, expansion of edge 

habitats favoring generalist over specialist species of birds, and the potential establishment of 

exotic species. These adverse impacts could be reversible with remedial action, but in the mean 

time would be expected to be moderate to major in the immediate vicinity of campsites, and 

minor to moderate on a park-wide scale. 

Of additional concern to natural resources would be increasing visitation in the spring when 

many natural resources are more vulnerable than later in the visitor season. High water levels 

and saturated soils, bird nesting periods and mammals with young all contribute to high resource 

sensitivity in the spring. Impacts such as disturbance of nesting loons and human encounters 
Impacts of Alternatives for Overnight Use

 

168 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

with wolves or wolf pups could result in moderate to major adverse impacts, whereas trail 

widening associated with muddy conditions would be minor to moderate and very localized. 

Effects on Cultural Resources

Many known archeological sites are located in and near campgrounds (Clark, 1995). 

Maintaining the status quo will continue to have an adverse impact on archeological resources. If 

an overall increase in visitation or an increase during the peak period resulted in expansion of 

campsites and related adverse impacts to soil and vegetation this could exacerbate adverse 

impacts to archeological sites. The extent of this impact could range from short-term and minor, 

to long-term and major depending upon the extent of the impacts and the significance and 

integrity of the resource affected. Archeological sites are non-renewable resources, therefore any 

damage to these sites or objects within them are irreversible. 

Several of the new campgrounds established by the GMP are located near historic structures and 

within cultural landscapes. If these campgrounds became overcrowded due to unregulated 

increases in visitation, historic structures could suffer long-term adverse impacts resulting from 

visitors camping outside of designated campsites or using historic buildings for shelter. These 

impacts could range from minor to major, depending on the significance and integrity of the 

affected resource. 

An inventory of ethnographic resources is ongoing. The park service does not presently know of 

any impacted resources, but there could be an impact to unidentified resources associated with 

overcrowded campgrounds and expanding campsites. This alternative, which would not limit 

overcrowding in campgrounds and expanding campsites could also result in long-term adverse 

impacts to ethnographic resources, though these resources are not yet well understood in the 

park.

This alternative would also allow for a significant increase in visitation in spring. Soil and 

vegetation, as well as archeological sites, are most vulnerable in spring. Therefore, adverse 

impacts to cultural resources associated with use levels in campgrounds could increase. 

Remedial measures such as educating campers about Leave-No-Trace principles and protection 

of cultural resources could minimize adverse impacts. 

Socioeconomic Effects

Isle Royale visitors are estimated to spend $1.7 million a year in the three local areas 

surrounding Copper Harbor and Houghton, MI, and Grand Portage, MN. If visitation were to 

increase under this alternative, there could be a beneficial effect on local economies. It is 

estimated that backcountry camping and boating parties spend an average of $102 per day in the 

local communities, day visitors $150-$168 per day, and guests at the Rock Harbor Lodge spend 

$330 per party per day (including money spent on the island at the Lodge). Therefore, any 

increase in visitation would be expected to have a beneficial effect on local economies (Strong 

and Solomon 2004). However, the extent of this economic benefit is unknown with this 

alternative. Although annual visitation would not be actively managed by the NPS with this 

alternative, it is unknown to what extent visitation would increase in the future. 
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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 169

Effects on Park Facilities and Operations

No necessary increases in park staffing would be expected if Isle Royale were to continue in its 

current management direction. However, an increase in the maintenance workload associated 

with minimizing sprawling campsites would be expected, a long-term minor adverse effect. The 

limitations of the current permitting system would continue with an inability to provide visitors 

with up-to-date information about space availability at campgrounds. Peak visitation periods 

result in higher numbers of visitor complaints to rangers and emergency responses by rangers. 

The rangers’ workload could be expected to rise if visitor numbers increased, especially during 

already high visitation periods. The challenges of coordinating permitting, database 

management, public education, and managing visitor statistics would continue with multiple 

divisions involved in managing backcountry permitting. The technological and logistical 

problems of managing permitting from 5 unconnected permitting stations would also continue. 

Conclusion

This alternative offers the greatest possibility of increases in visitation along with increases in 

overcrowding in campgrounds. It offers a high degree of public access and a high likelihood of 

adverse impacts to the park’s natural and cultural resources. 

Unavoidable Adverse Impacts

As documented in other sections of this chapter, maintaining the current management direction 

for managing overnight use would have unavoidable adverse impacts to many park resources 

including the quality of visitor experiences and wilderness character with continued or increased 

overcrowding in campsites during parts of the year, damage to and loss of vegetation and soils 

within and around heavily used campgrounds, and damage to archaeological resources and 

historic structures in and near over crowded campgrounds. These adverse impacts could be 

mitigated or avoided through future actions similar to those proposed in other alternatives for 

managing overnight use proposed in this plan. 

Alternative B for Overnight Use: Prioritize Providing a Broad Range of Quality 

Backcountry Opportunities and Protecting Resources (the Preferred Alternative)

The details of this alternative are outlined in Chapter 2, p. 58-63. Changes that could occur 

under this alternative that may have measurable environmental consequences include:

• A Backcountry Office with advanced permitting would be established on the mainland. 

• Some visitors may not be able to get a permit for the campground of choice on their date 

of choice.

• One new campsite would be added to North Desor. No new campgrounds would be 

added, beyond those proposed in the GMP.

• Visitation would be managed to maintain low use in the spring, allow minor to moderate 

increases in visitation in summer, and allow significant increases in visitation in the fall.

• Backcountry camping would be managed to decrease the frequency of campsite sharing 

to not more than 5% in summer (6/16-9/15).

This alternative divides the visitor season into 3 categories: 1) Spring, defined as the park’s 

opening on April 16 through June 15; 2) Summer, defined as June 16 through September 15; and 
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170 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

3) Fall, defined as September 16 through October 31. These three time periods have different 

concerns for visitor experiences, natural and cultural resources, and park operations. 

Implementing this alternative would be expected to affect visitor use and experiences, wilderness 

character, natural resources, cultural resources, area socioeconomics, and park operations. The 

main concerns with likely changes are primarily related to maximum public access and 

improving public services for backcountry trip planning. 

Effects on Visitor Use and Experiences

In general this alternative would be expected to have a beneficial effect on visitor experiences in 

the park, but may have an adverse impact on visitor access during the peak visitor season. One 

goal of this alternative is to improve the distribution of backcountry visitors to more efficiently 

use the park’s campsites. The intention is to better distribute parties to available campsites, 

thereby accommodating current levels or increased visitation levels while also reducing 

crowding and the frequency of campsite sharing. Improving visitor distribution through 

advanced permitting, as proposed in this alternative, would be expected to result in some visitors 

not being able to get a permit for their preferred campgrounds on their preferred dates. During 

the peak visitor season, this may also mean that fewer camping parties would be able to come to 

the park. 

Outside of the busiest 2-week period, the number of parties permitted to stay in campgrounds 

falls well below the park’s camping capacity, or number of campsites (Table 18). It is thus 

presumed that better distributing campers to campgrounds with adequate available campsites 

would alleviate overcrowding in campgrounds while also accommodating current or moderate 

increases in visitation. This would be accomplished by issuing backcountry permits from one 

centralized permitting station before visitors reach the island, telling visitors how many parties 

are already permitted for a campground, and no longer issuing permits over a campground’s 

capacity. 

Table 18: Number of backcountry parties in campgrounds and % campsite occupancy park-wide 

in 2001, a high year for backpackers in the park (this does not include the GMP-approved new 

campgrounds, which would reduce both the occupancy rates and the % sharing). 

Time of Visitor Season

Daily average number 

of parties permitted for 

campgrounds

Park-wide campground 

occupancy rate (percent 

of 244 campsites)

Estimated % 

of parties 

sharing sites

Spring (opening-6/15) 45 19% <1%

Summer (6/16-9/15) 139 57% 4.5%

July and August 155 64% 9.7%

Peak 2 weeks (between 

mid-July & mid-August)

203 83% 24.1%

Fall (9/16-10/31) 25 10% <1%

There are several likely implications for visitors. Permitting would be completed prior to 

reaching the island, either by phone, through the Internet, or in person at a Backcountry Office at 

the park’s Houghton headquarters. Therefore, campers would no longer have to wait to receive a 

permit upon reaching the island. Some people may not be able to get a permit for their preferred 
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 171

campgrounds on their preferred dates. For some people this would require more advanced 

planning. There would be more information for trip planning than is currently available, namely 

the number of permits already issued for specific campgrounds. Once in the park, visitors in July 

and August in particular would have a much greater chance of finding an available campsite, 

regardless of how late in the day they reached a campground. However, for some people this 

change from the current permitting system may be confusing or inconvenient and be seen as a 

short-term adverse effect. 

The two permitting types under this alternative for boaters who wish to dock overnight at a 

campground give them an option for a planned or unplanned trip. By planning and obtaining a 

backcountry permit early, boaters, like hikers, would be able to arrange an itinerary that 

optimized on less-crowded campgrounds ahead of time. Like hikers, boaters would not be able 

to exceed acceptable campsite sharing capacities. They would, however, have the benefit of 

being able to see how crowded or uncrowded the docking would be before ever arriving at the 

campground. For last minute trips, boaters would not be able to stay in the campground, but 

could obtain a docking or anchoring-out permit, and raft off with other willing boaters if no dock 

space was available. This system is expected to have minor, short-term and long-term positive 

effects for boaters who do not mind rafting off, and the same minor, short-term and long-term 

negative effects as Alternative A for boaters who prefer to dock without rafting off.

Impacts of overfull campground dock space on non-powerboaters (hikers and paddlers) would be 

marginally more beneficial than under the current system (Alternative A.) The benefits would 

occur because, with advance permitting, there would be less campsite sharing (as with other 

hikers), and last-minute boat arrivals would not be issued a campsite permit if no open campsites 

existed. This alternative would not change the current practice of allowing dock capacities to be 

exceeded, however, and so for those campers who feel indirect adverse effects of overfull docks 

(increased foot traffic through the campground, increased use of campground outhouses, 

increased noise), those effects would remain.

Visitors would still have the option of altering their itineraries at any point during their trips

(except for groups). However, if this were to result in the frequency of campsite sharing 

exceeding 5%, then the number of camping permits issued may be reduced, which would reduce 

camping access to the park.

This alternative also proposes adding one new campsite at North Desor. Increasing this 

campground to 4 campsites would be consistent with Little Todd, the other campground along 

the west end of the Minong Trail. Under the current conditions, North Desor is one of the 

campgrounds most consistently used over its capacity (Table 8, Chapter 3 §3.1.3). Advanced 

permitting would help to prevent this overcrowding, and adding one site would increase the 

number of parties who could camp in the Minong Trail’s primitive campgrounds, while also 

retaining it as a low use area. 

Under this alternative, spring visitation would be maintained at levels compatible with 

backcountry staffing levels, which would aid in minimizing threats to human safety. However, 

visitation could increase substantially in the fall, which may have an adverse effect on visitor 

safety. Backcountry staffing is at its lowest levels in late September and October, with few 
Impacts of Alternatives for Overnight Use

 

172 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

people staffing visitor centers and ranger stations and conducting backcountry patrols. 

Backcountry visitors during the fall face challenging weather conditions and must be more self 

reliant, since once they leave Windigo or Rock Harbor they are unlikely to find NPS personnel 

who could assist in an emergency. People choosing to visit at this time would need to be 

informed of these risks and the need for a great deal of self-sufficiency. 

Overall, this alternative would be expected to have long-term beneficial effects on visitor use and 

experiences when compared to current conditions, and when compared to Alternatives C, D, and 

E. 

Effects on Wilderness Character

Compared to the current management direction, this alternative is expected to better preserve a 

range of opportunities with variable visitation levels and associated opportunities for solitude. It 

would establish a threshold of not more than 5% of parties needing to double up in overcrowded 

campgrounds as well as maintaining low visitation in the spring. This would be expected to have 

a long-term moderate beneficial effect on the wilderness experiences available on Isle Royale by 

increasing solitude and privacy for campers, reducing pressures to rush to find a campsite, and 

reducing noise in campgrounds. Adding one additional campsite at North Desor would be 

expected to have the beneficial effect of increasing privacy and solitude for some parties 

camping there. However, making the campground bigger could also be seen as an adverse effect 

for people who prefer very small campgrounds. 

Effects on naturalness would also be expected to be long-term and minor to moderately 

beneficial. Reducing impacts to vegetation and soils associated with overcrowded campsites 

would improve the naturalness of areas surrounding campsites. A commitment to not construct 

any additional campgrounds in the park would also be a beneficial effect, though adding one new 

campsite to North Desor campground would have a moderate adverse effect on the naturalness of 

that area. 

 

Overall, this alternative would be expected to have long-term beneficial effects on wilderness 

character when compared to current conditions, and when compared to Alternatives C and D. 

Effects on Natural Resources

Compared to current conditions, implementing this alternative would be expected to have a 

beneficial effect on natural resources by reducing the adverse impacts to soils, vegetation, and 

increases in total impacted area associated with overcrowding in campsites. 

Adding one new site to North Desor, proposed in this alternative, would have the long-term 

adverse effect of creating a new impacted area with lost vegetation, compacted soils, a disturbed 

site vulnerable to exotic plants becoming established, and fragmented forest habitat. These 

impacts would be minor to moderate on site, but negligible to minor on a park-wide scale. 

Detailed plant and wildlife surveys as a part of site selection would minimize the severity of 

impacts. 

Maintaining low visitation in spring would have a long-term moderate beneficial effect on 

natural resources in the park, relative to current conditions. Maintaining spring as a low 
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 173

visitation time would be expected to minimize adverse effects to natural resources that are 

particularly sensitive in spring. High water levels and saturated soils make areas in and around 

campsites and trails more vulnerable to long-term damage from trampling. Wildlife mating and 

rearing young in the spring are highly sensitive to human disturbance. For example, low paddler 

numbers on the inland lakes in the spring appears to be beneficial to nesting loons (Kaplan and 

others 2004). Maintaining low human impacts such as disturbance of nesting loons and human 

encounters with wolves or wolf pups could result in moderate to major beneficial impacts, 

whereas minimizing trail widening associated with muddy conditions would be minor to 

moderate and very localized. 

This alternative could allow for a significant increase in fall visitation, which could have adverse 

effects on some wildlife species. The moose rut takes place in the fall, as does spawning in

several fish species. Wildlife in general are preparing for winter; storing up food and body fat at 

this period is critical for surviving either winter on the island or migration to wintering grounds. 

Human disturbances at this time and associated stresses could drain critical energy. Unless there 

were to be a dramatic increase in fall visitation these effects would be expected to be minor to 

moderate and easy for wildlife to escape. 

Overall, this alternative would be expected to have long-term beneficial effects on natural 

resources when compared to current conditions.

Effects on Cultural Resources

An overall reduction in sharing campsites and especially a reduction in sharing at peak times 

could lessen impacts related to campsite expansion, including adverse impacts to archeological 

sites. Increasing amounts of vegetation loss and exposed soil in campsites are of particular 

concern to archeological resources, as this increases the likelihood of exposing cultural objects 

with a subsequent threat of losing or damaging these objects. The extent that reducing 

campground crowding would reduce impacts to cultural resources depends on the proximity of 

sensitive archeological resources to campgrounds. Since many campgrounds are located on or 

near important archeological sites, any reduction in overcrowding is predicted to decrease the 

probability of related adverse impacts to archeological resources; a long-term beneficial effect. 

This alternative does propose the addition of one new campsite at North Desor. An 

archeological survey prior to site selection and avoidance of any sensitive cultural areas would 

minimize the threat of adverse impacts to cultural resources associated with expanding this 

campground. 

Several of the new GMP-approved campgrounds are located near historic structures and within 

cultural landscapes. If these campgrounds became overcrowded due to unregulated increases in 

visitation, historic structures could suffer serious long-term impacts resulting from visitors 

camping outside of campgrounds or using historic buildings for shelter. This alternative would 

help decrease the extent of overcrowding on the main island and therefore lessen the possible 

negative impact on historic structures and concurrently the cultural landscapes near the GMP 

campgrounds.
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174 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

An inventory of ethnographic resources is ongoing. The park service does not presently know of 

any impacted resources, but there could be an impact to unidentified resources associated with 

overcrowded campgrounds and expanding campsites. This alternative, which limits 

overcrowding, would limit the possibility of negative impacts to currently unknown ethnographic 

resources.

This alternative features a low threshold for overcrowding combined with lower spring visitation 

numbers. Soil and vegetation, as well as archeological sites, are most vulnerable in spring, due 

in part to increased risk of erosion and exposure of buried objects. 

Socioeconomic Effects

With this alternative, annual visitation could continue at current levels, or may decrease. It is 

expected that this alternative may not be able to fully accommodate current peak visitation levels 

in August, so the number of camping parties coming to the park could decrease to some extent if 

they were not able to come at a different time. If the number of camping parties coming to the 

park during the peak time were to decrease, there could be more room available on the ferries for 

day visitors and lodge guests. An increase in day visitors would be expected to have a minor 

beneficial effect on local communities, as day visitors are estimated to spend more money locally 

than camping parties. Strong and Solomon (2004) calculated that parties visiting Isle Royale for 

a day trip spend an average of $150-168 per day, while camping parties spend an average of 

$102 per day. The bulk of this money is spent on transportation to the island and food and 

lodging prior to traveling to the island. Any decrease in visitation as a result of this alternative 

would be expected to be minor at most, so the economic impacts to the local communities would 

also be expected to be minor. 

With advance permitting in place, concession ferry operators would require all overnight visitors 

to have valid permits in order to purchase ferry tickets (the same requirement that is currently in 

effect for groups coming out to the park now.) It is unlikely that the ferries will experience 

adverse effects from this system. Although visitors will be required to obtain their permits 

through the park’s Backcountry Office first, they will be made aware at that point of all possible 

ferry options, not just the NPS’s Ranger III. It is also true that each of the private ferry 

concessions offers unique options to potential passengers including mainland launch location, 

scheduling, and length of trip, so requiring an advance permit would not be expected to shift 

passenger numbers to the Ranger III, away from the other ferries. In addition, during peak 

visitation periods when the number of permits issued could be lower than under current 

practices, there will also be the chance to increase day-use trips aboard the ferries. Therefore, 

the adverse effect on concession ferries under this alternative is expected to be negligible to 

minor, and long term.

If the increased cost of creating a Backcountry Office were to be offset by either a permitting fee 

or an increase in the daily user fee, the costs to visitors of a trip to Isle Royale would increase, a 

minor to moderate adverse economic effect on visitors. A permitting fee would limit the costs to 

backcountry campers and boaters, while an increased daily user fee would increase costs to all 

island visitors (day visitors and lodge guests as well as campers and boaters). Currently the cost 

to visitors consists of the transportation fee ($130 round trip per adult for ferries, $290 round-trip 
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 175

per person for the seaplane, and gas money for private boaters), daily user fee ($4 per person per 

day), and any incidental expenses. 

Small businesses and CUAs would use the same system of permitting as all other backcountry 

visitors. As the availability of backcountry permits became limited, there could be adverse 

impacts to these businesses. 

Effects on Park Facilities and Operations

Implementing this alternative would be expected to have a moderate short-term cost and minor to 

moderate long term cost to the park. Establishing a Backcountry Office, with necessary office 

space, permitting computers and other equipment, creation of web-based permitting, and public 

notices of changes in permitting and planning for a trip to Isle Royale would be a moderate 

short-term adverse impact on Isle Royale’s budget, workload, and staffing. Running the 

Backcountry Office and central permitting would have minor to moderate long-term costs of 

additional staffing. Staffing a Backcountry Office could involve new positions and/or shifting 

existing visitor center positions to the new office.

The creation of the Backcountry Office would also be expected to have a beneficial effect on 

NPS operations, by improving coordination of all activities related to managing backcountry 

recreation. One central office would improve communication between divisions involved in the 

various facets of backcountry management. Management of the permitting system and its 

associated database, analysis of visitor statistics and recreation monitoring, and long-term 

development of effective backcountry education and regulations would be coordinated within 

this single office. Over the long-term this would be expected to improve the park’s ability to 

apply backcountry data to management, and improve the efficiency of visitor services and 

recreation management in the park. This long-term improved efficiency would be expected to 

outweigh the short-term costs of establishing the Backcountry Office. 

This alternative also proposes adding one new campsite to the North Desor campground, which 

would have a minor adverse effect on park workloads and budget. Creation of one new campsite 

would add to the workloads of existing staff, and not in itself require any new positions.

As with all alternatives proposing changes from the current conditions, the success of this 

alternative depends largely on an effective monitoring program with an associated assessment of 

the effectiveness of management actions for meeting goals. With this alternative it will be 

critical to determine whether advanced permitting and the permitted campground occupancy 

rates are effectively meeting the goals for reduced campground overcrowding. Such a 

monitoring program is expected to have a minor to moderate adverse effect on park operations, 

particularly the Natural Resources Management Division, which is responsible for monitoring 

natural resources and social conditions in the park. Collection of monitoring data, data analysis, 

and interpretation for management implications would require either an increase in the 

workloads of existing staff or additional staff. 

Conclusion

This alternative would be expected to have both adverse and beneficial effects on park resources 

and values. Relative to current conditions, visitor services and backcountry management would 
Impacts of Alternatives for Overnight Use

 

176 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

improve, and adverse impacts to natural and cultural resources would decrease. Increased 

visitation could be accommodated during part of the season while also reducing crowding in 

campgrounds and maintaining historic low use times during part of the visitor season. However, 

compared to current conditions, some people may have less flexibility in where they camp, and 

would likely need to plan further in advance for a trip to Isle Royale. This alternative would also 

have the long-term benefit of improving the efficiency of NPS operations for backcountry 

recreation management. 

Unavoidable Adverse Impacts

As outlined above, implementing the preferred alternative for managing overnight use of Isle 

Royale’s backcountry would be expected to have some unavoidable adverse impacts. Limiting 

camping permits to the availability of campsites could make the park’s backcountry less 

accessible to some campers during parts of the busiest times of the year; some people would not 

be able to camp in their preferred campgrounds on their preferred dates. The productivity of 

natural resources on a small scale would be impacted by the loss of vegetation and compaction of 

soils in establishing a new campsite at North Desor campground. 

Alternative C for Overnight Use: Accommodate Current or Increasing Use Levels While 

Improving Social Conditions

The details of this alternative are outlined in Chapter 2, p. 63-67. Changes that could occur 

under this alternative that may have measurable environmental consequences:

• A Backcountry Office with advanced permitting would be established on the mainland. 

• Visitation could increase all season, especially in Spring.

• A new shuttle service would be created in the Rock Harbor Channel.

• 2-3 new shelters would be constructed adjacent to the Windigo Dock.

• New campgrounds could be constructed, or existing campgrounds could be expanded on 

the east end of the island to better accommodate camping demands.

• The goal would be to reduce campsite sharing to not more than 10% sharing during the 

peak in visitation, and not more than 5% the rest of the season.

Implementing this alternative with its associated changes from the current condition would be 

expected to affect visitor use and experiences, wilderness character, natural resources, cultural 

resources, area socioeconomics, and park operations. The main issues with proposed changes 

are primarily related to visitor distribution and use levels, services offered to backcountry and 

wilderness visitors, and potential infrastructure changes (campground expansions and additions). 

Effects on Visitor Use and Experiences

Similar to Alternative B, one goal of this alternative is to improve the distribution of backcountry 

visitors to more efficiently use the park’s campsites. The details of the Backcountry Office and 

implications for visitors would be the same as those outlined above in Alternative B, with two 

exceptions. Higher campsite occupancy rates may be permissible during the peak visitor period 

since up to 10% of parties sharing would be acceptable in this alternative, as opposed to not more 

than 5% sharing in Alternative B. Higher occupancy rates would also be permissible in Spring 

under this alternative. This would allow for both higher visitation rates and higher frequencies of 

campsite sharing than would be likely with Alternative B. This alternative could also result in a 
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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 177

narrower range of visitor opportunities for solitude related to varying visitation levels throughout 

the visitor season, as there would be no certainty that current low use times in Spring and Fall 

would continue.

Although higher visitation levels for camping could be accommodated under this alternative than 

Alternative B, there is still a strong possibility that some visitors would not be able to get a 

permit for their preferred campgrounds on their preferred dates. Because campgrounds would 

not be permitted over their capacities, compared to current conditions there could be a reduction 

in visitation to parts of the park during the busiest parts of July and August. 

Increased visitation in May and October, possible under this alternative, may not satisfy those 

people who would prefer to visit in the summer, but were unable to get camping permits. 

Backcountry staffing is at low levels in May and October, and staffs are typically involved in 

training through early June. Consequently there are few people staffing visitor centers and 

ranger stations, and conducting backcountry patrols. Additionally, trail crews work through June 

to open up trails and campgrounds, clearing fallen trees from the winter and felling hazard trees. 

Backcountry visitors during the spring and fall face more challenging conditions and must be 

more self reliant, and willing to do without many services and amenities. Some people who 

could not get a permit during the summer may not want to come to the park during the more 

challenging times of Spring and Fall. 

The shuttle service proposed in this alternative would offer more flexibility and options to reach 

the interior of the park, at a lower cost than the water taxis. New shelters at the Windigo dock 

would offer a new option for boaters or others who wish to camp near the dock, and could help 

to alleviate crowding at nearby Washington Creek campground. Expanding existing 

campgrounds or adding new campgrounds would allow more parties to camp on Isle Royale 

without increasing overcrowding in campgrounds. However, this also would increase the 

cumulative footprint of campgrounds and fragment previously undeveloped areas of the 

backcountry. People who prefer smaller, quieter campgrounds, may see these expansions and an 

increase in the total number of people in a campground at one time as an adverse change. 

Boaters would also obtain advance permits through the Backcountry Office, and effects on 

boaters are expected to be the same as Alternative B, except that under this alternative, no lastminute backcountry docking-only permits would be available. As under Alternatives A-C, the 

park would not restrict rafting off by willing, permitted boaters. 

Impacts of overfull campground dock space on non-powerboaters (hikers and paddlers) would be 

marginally more beneficial than under the current system (Alternative A.) The benefits would 

occur because, with advance permitting, there would be less campsite sharing (as with other 

hikers), and last-minute boat arrivals would not be issued a campsite permit if no open campsites 

existed. This alternative would not change the current practice of allowing overbooking at 

docks, however, and so for those campers who feel indirect adverse effects of overbooked docks 

(increased foot traffic through the campground, increased use of campground outhouses, 

increased noise), those effects would remain. 
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178 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

In general, this alternative would affect visitor use levels and visitor experiences by 

accommodating more people during the busy season with more campgrounds, easier access to 

the interior of the island, and a tolerance for a higher level of campsite sharing. It would also 

allow for a greater increase in visitation in Spring than would be allowed with the Preferred 

Alternative (Alternative B). Compared to current conditions, this alternative would be expected 

to be able to accommodate existing or greater annual visitation levels, but may not be able to 

fully accommodate existing peak visitation if visitors were not willing or able to alter their 

preferred itineraries based on campsite availability. 

Effects on Wilderness Character

Overall, this alternative would be expected to have long-term beneficial effects on wilderness 

character when compared to current conditions. There would also be adverse impacts to 

wilderness character associated with this alternative. When compared to Alternative B, the 

Preferred Alternative, this alternative could result in a narrower range of wilderness experiences 

related to visitor use levels throughout the visitor season, as well as a greater degradation of 

naturalness associated with the extent of campground development in the park. Adding a shuttle 

service in the Rock Harbor Channel to transport campers would give more people access to the 

interior of the park. This may be a beneficial change for people wishing to visit the interior on 

short trips to the park, but an adverse change for people who feel greater ease of access 

compromises the wilderness character of the park’s more remote areas. 

Effects on Natural Resources

Similar to Alternative B, the Preferred Alternative, this alternative would be expected to have a 

beneficial effect on natural resources by reducing the adverse impacts associated with 

overcrowding in campsites. However, this alternative proposes the greatest likelihood of 

increasing the number of campsites in the park, with the option to expand existing campgrounds 

and create new campgrounds in previously undeveloped areas. Accordingly, the adverse impacts 

associated with campsites could increase throughout the park in this alternative. New 

campgrounds pose the potential for additional adverse impacts such as fragmenting habitats, 

expanding edge habitats, disturbing previously undeveloped sites, expanding conditions suitable 

for the introduction and establishment of exotic plant species, and introducing consistent human 

traffic in areas that previously may have seen infrequent traffic. Areas that were initially 

identified as possible sites were chosen to avoid adverse effects to Federally Threatened species, 

but it is unlikely that adverse impacts to both Federally and State-listed species could be avoided 

entirely. Therefore, this alternative would accept a minor to moderate impact to State-listed 

populations in the park.

This alternative also would allow for a significant increase in spring visitation. Although high 

rates of overcrowding and parties doubling up in campgrounds would not be a concern, there are 

other visitation-related concerns for natural resources in the spring. This alternative would have 

the same likelihood of minor to moderate adverse impacts to natural resources that are more 

sensitive to human impacts in the spring as those outlined in alternative A, the current 

conditions. 

Overall, this alternative would be expected to have long-term beneficial effects on natural 

resources when compared to current conditions. However, as this alternative would allow an 
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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 179

increase in the number of campsites and campgrounds in the park and significant increase in 

visitation in the spring, the likelihood and scope of adverse impacts are greater with this 

alternative than with the Preferred Alternative, Alternative B. 

Effects on Cultural Resources

The probable effects to cultural resources with this alternative are similar to those outlined in the 

Preferred Alternative, Alternative B, but with a greater probability of adverse impacts to cultural 

resources. 

This alternative proposes adding a few shelters in the vicinity of the Windigo Dock, adding new 

campsites to expand existing campgrounds, and possibly adding a few new small campgrounds. 

This would likely expand the cumulative footprint and impacted area of campsites in the park. 

With this expansion would come a possible adverse impact on cultural resources, increasing the 

likelihood of damage to or loss of previously unknown archeological sites and cultural objects. 

However, the likelihood of this adverse impact could be reduced or eliminated with a thorough 

archeological survey in proposed sites for these new developments. Mitigation actions such as 

site hardening (e.g. tent platforms or site capping) and removal of significant objects to the park 

museum could further reduce the severity of adverse impacts. 

This alternative would also allow for a significant increase in visitation in Spring. Soil and 

vegetation, as well as archeological sites, are most vulnerable in Spring. Therefore, adverse 

impacts to cultural resources associated with use levels in campgrounds could increase. 

Remedial measures such as educating campers about Leave-No-Trace principles and protection 

of cultural resources could minimize adverse impacts. 

Similar to the Preferred Alternative, this alternative, which limits overcrowding, would limit the 

possibility of negative impacts to currently unknown ethnographic resources. However, by 

allowing expansion of current campgrounds and possible new campgrounds this alternative 

would result in a long-term minor adverse impact to ethnographic resources. 

Overall, this alternative would be expected to have long-term beneficial effects on cultural 

resources when compared to current conditions. However, as this alternative would allow a 

significant increase in visitation in the spring, the likelihood of adverse impacts are greater with 

this alternative than with the Preferred Alternative (Alternative B). Because archeological 

resources and cultural objects are a non-renewable resource, any damage to or loss of 

archeological resources would be long-term, irreversible, and adverse. Damage to cultural 

landscapes and historic structures may be reversible, depending on the specific resource affected 

and the nature of the impact. 

Socioeconomic Effects

With this alternative some visitation may shift from the peak season to other times of the season, 

but overall visitation could increase, which could have a beneficial effect on tourism-dependent 

businesses. Isle Royale visitors are estimated to spend $1.7 million in the 3 local communities 

and surrounding areas of Copper Harbor and Houghton, MI and Grand Portage, MN (Strong and 

Solomon 2004). With this alternative this level of spending would be expected to continue, or 

could increase. 
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180 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

The effects on concession ferries are expected to be the same as under Alternative B.

If the increased cost of creating a Backcountry Office were to be offset by either a permitting fee 

or an increase in the daily user fee, the costs to visitors of a trip to Isle Royale would increase, a 

minor to moderate adverse economic effect on visitors. A permitting fee would limit the costs to 

backcountry campers and boaters, while an increased daily user fee would increase costs to all 

island visitors (day visitors and lodge guests as well as campers and boaters). Currently the cost 

to visitors consists of the transportation fee ($130 round trip per adult for ferries, $290 round-trip 

per person for the seaplane, and gas money for private boaters), daily user fee ($4 per person per 

day), and any incidental expenses. 

Small businesses and CUAs would use the same system of permitting as all other backcountry 

visitors. As the availability of backcountry permits became limited, there could be adverse 

impacts to these businesses. 

Effects on Park Facilities and Operations

Implementing this alternative would have the same short and long-term minor to moderate 

adverse effect on park staffing and budget associated with creating a Backcountry Office as 

outlined in Alternative B, above. It would also have the long-term beneficial effects of 

improving the efficiency of NPS operations for backcountry management and services. 

There would be additional costs to the park associated with adding new shelters near the 

Windigo dock (a minor short-term adverse effect), and possibly adding up to three new 

campgrounds (a moderate short-term adverse effect). Creating a shuttle service between Rock 

Harbor, Mott Island, and Daisy Farm could be a minor to moderate long-term adverse effect on 

park budget and staffing, or a negligible effect if the service were run through a concessionaire.

As with all alternatives, the success of this alternative depends largely on an effective monitoring 

program with an associated assessment of the effectiveness of management actions for meeting 

goals. With this alternative it will be critical to determine whether advanced permitting and the 

permitted campground occupancy rates are effectively meeting the goals for reduced 

campground overcrowding. Such a monitoring program is expected to have a minor to moderate 

adverse effect on park operations, particularly the Resources Management Division, which is 

responsible for monitoring natural resources, cultural resources, and social conditions in the 

park. Collection of monitoring data, data analysis, and interpretation for management 

implications would require either an increase in the workloads of existing staff or additional 

staff. 

Conclusion

This alternative could have both adverse and beneficial effects on park resources and values. 

Compared to the Preferred Alternative, a greater number of backcountry campers could be 

accommodated throughout the visitor season and campers would have more options, but there 

could also be an increase in development in the backcountry and wilderness, a higher level of 

campground crowding, and a greater likelihood of adverse impacts to cultural and natural 

resources. This alternative may not be able to accommodate future increases in visitation as well 
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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 181

as the current management practices, but it would be expected to better provide quality visitor 

experiences, and better protect park resources. 

Unavoidable Adverse Impacts

As outlined above, implementing this alternative for managing overnight use of Isle Royale’s 

backcountry would be expected to have some unavoidable adverse impacts associated with 

expanding existing campgrounds, creating new campgrounds in previously undeveloped areas, 

and adding shelters near the Windigo dock. New campsites and shelters result in decreased 

productivity on a small, site-specific scale, with a loss of vegetation, compaction and exposure of 

soil, and habitat loss and fragmentation. The combination of new human use in previously 

unused areas and potential changes in use patters through possible increased spring and fall 

visitation could have unavoidable adverse impacts on wildlife. 

Alternative D for Overnight Use: Improve Social Conditions Through the Use of Entry 

Quotas

The details of this alternative are outlined in Chapter 2, p. 68-71. Changes that could occur 

under this alternative that may have measurable environmental consequences:

• Entry quotas would be established for hikers and boaters on ferries (private boaters would 

be included in the future only as increasing boating necessitated)

• Crowding would be decreased in July and August, with a possible increase the rest of the 

season, by applying a standard of not more than 5% of parties sharing campsites at any 

point in the season. 

• One new campsite would be added at North Desor.

• Campsite or shelter reservations would be offered at a limited number of campgrounds.

Implementing this alternative with its associated changes from the current condition would be 

expected to affect visitor use and experiences, wilderness character, natural resources, cultural 

resources, area socioeconomics, and park operations. The main issues with proposed changes 

are primarily related to visitor distribution and use levels, and services offered to visitors. 

Effects on Visitor Use and Experiences

Alternative D proposes establishing a standard of not more than 5% of parties needing to share 

campsites in overfull campgrounds, accomplished through an entry quota system. This would 

reduce overcrowding during the peak season and allow for an increase in visitation and 

concurrent increase in campground crowding outside of July and August. Further, this 

alternative would not add any new campsites, with the exception of one site at North Desor and 

the GMP-approved new campgrounds, and there would be no significant change in the current 

permitting system. Over the short-term this would be beneficial in that people would not have to 

learn a new system for permitting. People would receive a backcountry permit at the start of 

their trip, and there would not be reliable information available about future campground use 

levels. Once they reached the island, people would retain full freedom to camp in or dock at the 

campgrounds of their choice, and to change their itinerary at any point. 

This alternative would also establish campsite and shelter reservations on a limited basis. This 

would be a beneficial change for people who value an assurance of campsite availability, and for 
Impacts of Alternatives for Overnight Use

 

182 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

people who would prefer to plan ahead for where they will be camping or docking for the night. 

Because this would be implemented in a limited number of campgrounds, the majority of 

campers would retain flexibility in changing their itineraries at any point in their trip and 

selecting campsites on a first-come, first-served basis. 

Establishing a standard of not more than 5% of parties needing to double up in overcrowded 

campgrounds would require changes in backcountry visitation. For the past several years it is 

estimated that up to 25% of parties needed to share campsites during the peak 2 weeks of the 

season. Additionally, in 2001, a peak year for backpacking on the island, in July and August 

outside of the peak 2 weeks, the frequency of parties needing to share sites averaged 6.4%. The 

rest of the season the frequency of sharing averaged less than 1%. To lower this number without 

either controlling visitor distribution and what campgrounds people stay in or significantly 

expanding campgrounds would require reducing visitation during part of the season. Some of 

the July and August visitors would have to come at a different time, or not come to the island at 

all. 

Use levels for powerboaters and sailors would be monitored to determine a future need for entry 

quotas for these groups. With low current use levels for these visitors, boaters and sailors would 

not initially be included in the quota system. Boaters would be required to obtain a backcountry 

permit, either prior to or at arrival time. As with Alternatives A-C, dock space would not be 

regulated, the exception being that in this alternative, there would be a few campgrounds where 

reservations would be allowed for part of the season. This alternative would have the same 

effects as Alternative A, where boaters would not be able to pre-plan an itinerary with 

information on expected campground/dock capacities by using an advance, centralized permit 

system. By having a small number of campgrounds with a reservation system, boaters would 

have the assurance that a campsite and dock space (where applicable) would be available at a 

specified date and location. This would be a minor to moderate, long term positive effect. 

Boaters who enjoy the camaraderie of rafting off would still be able to do so for most of the 

season, at most docks. Non-powerboaters who prefer a more solitary camping experience at 

campgrounds with docks would also register a minor long term positive effect for a portion of 

the season at selected campgrounds. 

Using the travel simulation model it is estimated that if the park issued an average of 37 

backcountry permits per day or 259 per week, 5% or fewer parties would need to share 

campsites. This includes all backcountry parties, boaters as well as hikers. This also assumes 

that the additional campsites would be added at the GMP-proposed campgrounds and at North 

Desor, as proposed in this alternative. It is also assumes that some boaters would be sleeping 

onboard their boats rather than occupying campsites, where sufficient dock space is available. 

Figure 5 illustrates the actual number of permits issued by week in 2001 and 2003, as well as 

projections of visitation patterns with a limit of 37 permits per day and maintaining 2003 ferry 

capacities and schedules. In 2001, 4 weeks exceeded 259 permits issued, with 283 too many 

permits being issued in this period. In 2003, 3 weeks exceeded the limit by a total of 244 

permits. These excess permits could easily be absorbed during the rest of the season, as long as 

the excess people seeking permits could be flexible in their travel dates. Overall backcountry 

visitation could increase above current levels outside of the peak time. 
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 183

Figure 5: Actual numbers of backcountry permits issued per week in 2001 and 2003 and 

projected numbers issued with a cap of 37 permits per day, or 259 per week, while maintaining 

2003 ferry capacities and schedules.

Week of the Visitor Season

May 1May 15May 29June12June 26July 10July 24Aug 7Aug 21Sept 4Sept 18Oct 2Oct 16

Number of Permits Issued per Week

400

380

360

340

320

300

280

260

240

220

200

180

160

140

120

100

80

60

40

20

0

2001

Actual

2003

Actual

Alternative D

Projected

Implementing this alternative could result in some visitors not being able to visit the park on 

their preferred dates. The number of camping parties entering the park would be limited to not 

more than an average of 37 per day (i.e. 259 per week). The result would be reduced crowding 

in campgrounds and on trails during the peak visitor season (between mid-July and mid-August). 

However, one cost of this is expected to be an increase in visitation during the rest of the season 

and an overall decrease in the range of opportunities available throughout the season on Isle 

Royale. 

Increased visitation in May and October, possible under this alternative, could have an adverse 

effect on visitor safety. Backcountry staffing is at low levels in May and October, and staffs are 

typically involved in training through early June. Consequently there are few people staffing 

visitor centers and ranger stations, and conducting backcountry patrols. Additionally, trail crews 

work through June to open up trails and campgrounds, clearing fallen trees from the winter and 

felling hazard trees. Backcountry visitors during Spring and Fall face more challenging 

conditions and must be more self reliant, increasing visitation during these times would increase 

risks to human safety in the backcountry. 

Compared to the Preferred Alternative and current conditions, this alternative would be expected 

to limit access to the park for camping to a greater extent, but with a benefit of maintaining 

maximum freedom and flexibility once reaching the park’s wilderness and backcountry. 

Because only the number of backcountry camping parties would be capped on ferries, there 
Impacts of Alternatives for Overnight Use

 

184 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

could be additional space on ferries available for day visitors and lodge guests, increasing access 

to the park for these visitors. 

One of the goals of this alternative is to keep the permitting and trip planning logistics as simple 

as possible, with the thought that establishing entry quotas by limiting the number of camping 

parties each of the ferries could carry would be the simplest system for visitors. If this 

alternative were implemented a certain portion of the permits issued per day would be allocated 

for campers traveling on ferries, with the remaining available for private boaters planning on 

utilizing campgrounds. 

Effects on Wilderness Character

This alternative proposes managing visitor use levels by establishing an entry quota, thereby 

limiting access prior to reaching the park. Compared to Alternatives B, C and E, this may allow 

people to travel more freely to the campgrounds of their choice, since permits would be issued 

upon arrival to the island, and would not be limited by campground capacities. This may be 

better for wilderness experiences than allowing more people to come to the park for wilderness 

trips but restricting the choices they have in where to travel. Compared to current conditions, 

this alternative would aim to reduce campground crowding during July and August; a long-term 

moderate beneficial effect on wilderness character and opportunities for solitude and tranquility. 

Compared to the Preferred Alternative, there is less likelihood of preserving the low use times in 

the spring, which could be a moderate adverse impact on spring visitors who are seeking more 

exemplary wilderness experiences. 

Compared to current conditions this alternative would have the beneficial effect of reducing 

sprawl in campgrounds and biophysical impacts associated with overuse of campsites, similar to 

the other alternatives. This would be a long-term beneficial effect on wilderness character.

Effects on Natural Resources

Similar to the Preferred Alternative, implementing this alternative would be expected to have a 

beneficial effect on natural resources by reducing the adverse impacts to soils, vegetation, and 

increases in total impacted area associated with overcrowding in campsites. 

Also similar to the Preferred Alternative, this alternative would have the same adverse impacts of 

adding an additional campsite at North Desor. These impacts would be minor to moderate on 

site, but negligible to minor on a park-wide scale. 

In contrast to the Preferred Alternative, this alternative could allow for increased visitation in the 

spring, with associated concern for adverse impact to sensitive resources. Impacts such as 

disturbance of wildlife could result in moderate to major adverse impacts, whereas trail widening 

associated with muddy conditions would be minor to moderate and very localized. 

Effects on Cultural Resources

This alternative features entry quotas for backcountry campers, which would reduce campground 

overcrowding, and would likely reduce the overall number of visitors on the island during the 

peak visitation period. There would likely be corresponding decreases in adverse impacts 

associated with overcrowding and high visitation. An overall reduction in sharing campsites and 
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 185

especially a reduction in sharing at peak times could lessen impacts related to campsite 

expansion, including negative impacts to archeological sites. The extent of the impact reduction 

depends on the proximity of sensitive archeological resources to campgrounds. Since many 

campgrounds are located on or near important archeological sites, any reduction in overcrowding 

is predicted to decrease the probability of related impacts to archeological resources. 

Several of the new GMP campgrounds are located near historic structures. If these campgrounds 

become overcrowded due to unregulated increases in visitation, historic structures could suffer 

serious long-term impacts resulting from visitors camping outside of campgrounds or using 

historic buildings for shelter. This alternative would help decrease the extent of overcrowding 

on the island and therefore lessen the possible negative impact on historic structures near the 

GMP campgrounds.

Similar to the Preferred Alternative, this alternative, which limits overcrowding, would limit the 

possibility of negative impacts to currently unknown ethnographic resources.

Overall, this alternative would be expected to have long-term beneficial effects on cultural 

resources when compared to current conditions. However, as this alternative would allow a 

significant increase in visitation in the spring, the likelihood of adverse impacts are greater with 

this alternative than with the Preferred Alternative, Alternative B. 

Socioeconomic Effects

Under this alternative, it is estimated that there would be a 5% reduction in camping parties in 

July and August. If those people chose to visit the park at a different time, it is expected that the 

socioeconomic effect of this alternative on the local communities would be negligible. If fewer 

camping parties riding on ferries resulted in more day visitors coming to the park during the peak 

time, there could be a beneficial effect on the local communities. Currently ferries sell out 

periodically during the peak visitor season. Entry quotas could result in fewer camping parties 

and more space available for day visitors. Day visitors are estimated to spend more money per 

day in local communities than campers. A party of day visitors is thought to spend on average 

$150-168 per day, while a party of backcountry campers is thought to spend an average of $102 

per day. The bulk of direct local spending goes to ferry companies, gas, and motels (for those 

who would stay in a motel prior to traveling to the island). If total visitation to the island were to 

decrease, there could be a minor adverse impact to local mainland communities, including ferry 

services. The Isle Royale Queen, from Copper Harbor, and the Wenonah, from Grand Portage, 

are the only ferries that carry day visitors, so any increase in day visitors would affect Copper 

Harbor and Grand Portage most directly (Strong and Solomon 2004).

Reducing the number of camping parties riding on ferries during the peak visitor season could 

also allow more room for people staying at the Rock Harbor Lodge. This could have a minor to 

moderate beneficial effect on the concessionaire operating the lodge. These visitors may be 

more likely to spend more money in the local communities than campers, as they may stay in 

motels and eat in restaurants more frequently. Thus increasing the number of lodge guests 

traveling to the island could also have a minor beneficial effect on local communities. 
Impacts of Alternatives for Overnight Use

 

186 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

This alternative proposes implementing a small-scale campsite reservation system, limited to a 

few of the park’s small campgrounds. This system would be similar to the large group camping 

system currently in effect. Advanced reservations would be available through the park’s 

Houghton Headquarters, and a permitting fee required (a non-refundable $25 fee). Thus it is 

expected that this alternative could increase the cost of a trip for those visitors opting to use the 

reservation system. 

This alternative would be expected to have negligible to minor effects on small businesses 

operating within the park. Camps, outfitters, and all small businesses would be included in the 

entry quotas, similar to all camping parties. These organizations could be adversely affected if 

they were not able to come to the park on their preferred dates. However, for organizations that 

already work through the large group permitting system, there would be no change from current 

conditions. Fishing and dive charters would not likely be affected.

Effects on Park Facilities and Operations

Implementing this alternative would have a minor short-term adverse effect due to the costs of 

constructing one new campsite at North Desor. This may also result in a long-term minor 

increase in maintenance workload associated with the upkeep of campsites. Both of these would 

likely require an increased workload for existing staff rather than hiring additional staff. 

Implementing this alternative would create a new reservation system for a small number of 

campgrounds in the park, which would increase the workload of Houghton Visitor Center staff. 

This would be a minor long-term adverse effect on park operations.

As with all alternatives, the success of this alternative depends largely on an effective monitoring 

program with an associated assessment of the effectiveness of management actions for meeting 

goals. With this alternative it will be critical to determine whether entry quotas are unduly 

restrictive or insufficient to reduce the frequency of campsite sharing to 5%. Such a monitoring 

program is expected to have a minor to moderate adverse effect on park operations, particularly 

the Natural Resources Management Division, which is responsible for monitoring natural 

resources and social conditions in the park. Collection of monitoring data, data analysis, and 

interpretation for management implications would require either an increase in the workloads of 

existing staff or the need for additional staff. 

This alternative would be expected to have a lower short-term implementation cost than 

Alternatives B, C and E. However, the long-term costs may be comparable, with this alternative 

requiring increased coordination with the ferry companies to manage the quota system, ongoing 

management of the limited site reservation system, and ongoing monitoring necessary to 

determine the appropriateness of quota levels. 

Conclusion

In general this alternative would be expected to have both beneficial and adverse effects on park 

resources and values. Relative to other alternatives, this alternative could result in the greatest 

decrease in peak season visitation, but it would allow for a large increase in visitation in the 

spring and fall. Campground crowding and the associated adverse impacts to park resources 
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 187

would decrease, but adverse impacts to resources that are most sensitive to human impacts in the 

spring or fall could increase. 

Unavoidable Adverse Impacts

As outlined above, implementing this alternative for managing overnight use of Isle Royale’s 

backcountry would be expected to have some unavoidable adverse impacts associated with 

adding a new campsite at North Desor campground, and limiting the number of camping parties 

entering the park. The park’s backcountry could become less accessible to some campers during 

parts of the busiest times of the year, with some people not being able to camp on their preferred 

dates. The productivity of natural resources on a small scale would be impacted by the loss of 

vegetation and compaction of soils in establishing a new campsite at North Desor campground.

Allowing for an increase in backcountry visitation in the Spring, this alternative could also have 

unavoidable adverse impacts to wildlife, with increased human disturbance during a particularly 

vulnerable time for wildlife (e.g. nesting birds and moose with calves). 

Alternative E for Overnight Use: Maximize Resource Protection and Opportunities for 

Solitude

The details of this alternative are outlined in Chapter 2, p. 71-75. Changes that could occur 

under this alternative that may have measurable environmental consequences:

• Establish Backcountry Office—staffing and budget implications, advanced permitting for 

campers and boaters.

• Decrease crowding to not more than 5% of parties needing to double up during the 2-

week peak in visitation, and not more than 1% sharing the rest of the season.

• Maintain historic low visitation in Spring and Fall. 

• Remove one campsite from Little Todd.

• No new campgrounds would be added, beyond those approved in the GMP.

Implementing this alternative with its associated changes from the current condition would be 

expected to affect visitor use and experiences, wilderness character, natural resources, cultural 

resources, area socioeconomics, and park operations. The main issues with proposed changes 

are primarily related to visitor distribution and use levels, and services offered to visitors. 

Effects on Visitor Use and Experiences

This alternative would be expected to result in changes to visitor use levels and opportunities that 

could be viewed as adverse or beneficial effects, depending on one’s perspective. Similar to 

Alternative B, the preferred alternative, one goal of this alternative is to improve the distribution 

of backcountry visitors to more efficiently use the park’s campsites by creating a Backcountry 

Office with advanced permitting. However, this alternative is expected to allow for the least 

increase in visitation of all the alternatives. This alternative has a lower tolerance for 

campground crowding and a need to double up in campsites, and a goal of maintaining existing 

low backcountry visitation in the spring and fall. More evenly distributing campers between 

campgrounds and throughout July and August could accommodate current visitation levels, if 

visitors were to adhere to their permitted camping itineraries. People straying from their 

camping itineraries would require permitting below campgrounds’ capacities in order to achieve 
Impacts of Alternatives for Overnight Use

 

188 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

goals for reduced campground crowding, which would reduce the likelihood of accommodating 

current visitation levels. 

There are several likely implications for visitors of instituting advanced permitting. Permitting 

would be completed prior to reaching the island, either by phone, through the internet, or in 

person at a Backcountry Office at the park’s Houghton headquarters. Some people may not be 

able to get a permit for their preferred campgrounds on their preferred dates. For some people 

this would require more advance planning. There would be more information for trip planning 

than is currently available, namely the number of permits already issued for specific 

campgrounds. Once in the park, visitors in July and August would have a much greater chance 

of finding an available campsite, regardless of how late in the day they reach a campground. 

The effects of this alternative on boaters would be identical to those under Alternative C. 

Advance permitting would enhance a boater’s ability to avoid crowded docks if he/she chose, but 

rafting off in the case of overcrowded docks would not be restricted. The effects of this 

alternative will vary based on boater preference. The adverse effects of overfilled dock space on 

boaters and non-powerboating campers is expected to be minor to moderate, and short-term to 

long-term. (See Effects on Visitor Use and Experiences section under Alternative C for more 

detail.)

This alternative also proposes removing one campsite from Little Todd, making it consistent 

with the 3 campsites at North Desor, the other campground along the primitive western section 

of the Minong Trail. Although removing one site would be expected to reduce public access to 

this section of trail somewhat, it would also provide for one section of hiking trail with very 

small campgrounds and very low encounter rates along the trail, a long-term beneficial effect for 

those people who do receive permits for these campgrounds. 

Under this alternative, spring and fall visitation would be maintained at levels compatible with 

backcountry staffing levels, which would aid in minimizing threats to human safety. 

Compared to current conditions, this alternative would be expected to improve visitor 

experiences. Relative to the other alternatives, this alternative would be expected to have the 

long-term adverse effect of limiting visitor access to the primitive western section of the Minong 

Trail, and access to the entire backcountry and wilderness for camping in Spring and Fall. 

Overall this alternative would be expected to have the adverse effect of maintaining lower visitor 

use levels than may be possible with the other alternatives, but at the same time have the 

beneficial effect of providing opportunities for higher quality wilderness and backcountry 

experiences. 

Effects on Wilderness Character

In reducing overcrowding in campgrounds and a need to share campsites, as well as preserving 

low visitation times in Spring and Fall, this alternative would have a long-term beneficial effect 

on wilderness character compared to current conditions. Compared to all the other alternatives, 

this alternative would have the greatest likelihood of maintaining a broad range of wilderness 

opportunities, including exemplary opportunities for solitude and self-sufficiency during low use 

times in Spring and Fall. Although this may make public access to the park more difficult in 
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 189

Spring and Fall, access for appropriate types of recreation would remain high in the summer 

months. 

A commitment to not increase the number of campsites in the park beyond those approved in the 

GMP would, in concert with efforts to reduce overcrowding in campgrounds, be expected to 

have a long-term beneficial effect on the naturalness of the park and areas immediately 

surrounding campsites.

Overall, this alternative would be expected to have the greatest beneficial effect on wilderness 

character, when compared to current conditions and the other alternatives. 

Effects on Natural Resources

The effects on natural resources of actions proposed in this alternative would be the same as 

those outlined in the Preferred Alternative (Alternative B) with two exceptions. This alternative 

proposes removing one campsite from Little Todd and would not expand any existing 

campgrounds. This would be a moderate beneficial effect for the area in the immediate vicinity 

of Todd Harbor and a minor beneficial effect park-wide. This is the only alternative that 

proposes any reduction in the number of campsites. Additionally, this alternative is the only 

alternative that proposes maintaining current low use in the fall. Preserving low visitation in the 

fall would have a long-term beneficial effect on wildlife species that are sensitive to human 

disturbance. This could be a minor, long-term beneficial impact on wildlife species that require 

low stress periods to build up food and fat stores to survive Winter. 

Overall, this alternative would be expected to have long-term beneficial effects on natural 

resources when compared to all other alternatives. The beneficial effects to natural resources 

would be slightly greater with this alternative compared to Alternative B, the Preferred 

Alternative, because in this alternative the cumulative footprint of campsites would be expected 

to decrease with the removal of one campsite at Little Todd, as opposed to adding one new site at 

North Desor, and low visitation would be preserved in Fall. 

Effects on Cultural Resources

The probable effects to cultural resources with this alternative are the same as those outlined in 

the Preferred Alternative, Alternative B, with minor to major long-term beneficial effects 

associated with reduced crowding in campgrounds and maintaining low visitation times in the 

spring. Overall this alternative is predicted to decrease possible adverse impacts to archeological 

resources by the greatest extent. 

Similar to the Preferred Alternative, this alternative, which limits overcrowding, would limit the 

possibility of negative impacts to currently unknown ethnographic resources.

Socioeconomic Effects

Relative to all other alternatives, this alternative has the greatest likelihood of resulting in 

decreasing the number of camping and boating parties visiting the park annually, which could 

have a minor adverse effect on local tourism-dependent economies. With this alternative, 

visitation could be reduced during the peak use times and Spring and Fall would be maintained 

with low use levels. Fewer camping parties traveling on ferries during the peak times may allow 
Impacts of Alternatives for Overnight Use

 

190 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

greater access for day visitors who otherwise would not have gotten a ticket on sold-out ferries. 

Any increased day use would offset any adverse economic effects of reduced camping visitation.

As with Alternatives B and C, with advance permitting in place, concession ferry operators 

would require all overnight visitors to have valid permits in order to purchase ferry tickets (the 

same requirement that is currently in effect for groups coming out to the park now.) It is 

unlikely that the ferries will experience adverse effects from this system. Although visitors will 

be required to obtain their permits through the park’s Backcountry Office first, they will be made 

aware at that point of all possible ferry options, not just the NPS’s Ranger III. It is also true that 

each of the private ferry concessions offers unique options to potential passengers including 

mainland launch location, scheduling, and length of trip, so requiring an advance permit would 

not be expected to shift passenger numbers to the Ranger III, away from the other ferries. In 

addition, during peak visitation periods when the number of permits issued could be lower than 

under current practices, there will also be the chance to increase day-use trips aboard the ferries. 

Therefore, the adverse effect on concession ferries under this alternative is expected to be 

negligible to minor, and long term.

Similar to Alternatives B and C, if the increased cost of creating a Backcountry Office were to be 

offset by either a permitting fee or an increase in the daily user feel, the costs to visitors of a trip 

to Isle Royale would increase, a minor to moderate adverse economic effect on visitors. A 

permitting fee would limit the costs to backcountry campers and boaters, while an increased 

daily user fee would increase costs to all island visitors (day visitors and lodge guests as well as 

campers and boaters). Currently the cost to visitors consists of the transportation fee ($100 

round trip per adult for ferries, $230 round-trip per person for the seaplane, and gas money for 

private boaters), daily user fee ($4 per person per day), and any incidental expenses. 

Small businesses and Incidental Business Permit holders would use the same system of 

permitting as all other backcountry visitors. As the availability of backcountry permits became 

limited, there could be adverse impacts to these businesses. 

Effects on Park Facilities and Operations

Implementing this alternative with establishment of a Backcountry Office on the mainland would 

be expected to have the same effects outlined under the Preferred Alternative (Alternative B); a 

moderate short-term cost and minor to moderate long-term cost to the park. It would also have 

the long-term beneficial effects of improving the efficiency of NPS operations for backcountry 

management and services. 

Removing one campsite at Little Todd would have a minor short-term adverse effect on staff 

workloads and spending, and long-term negligible beneficial effect of one less campsite to 

maintain.

As with all alternatives, the success of this alternative depends largely on an effective monitoring 

program with an associated assessment of the effectiveness of management actions for meeting 

goals. With this alternative it will be critical to determine whether advanced permitting and the 

permitted campground occupancy rates are effectively meeting the goals for reduced 

campground overcrowding. Such a monitoring program is expected to have a minor to moderate 
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 191

adverse effect on park operations, particularly the Resources Management Division, which is 

responsible for monitoring natural resources and social conditions in the park. Collection of 

monitoring data, data analysis, and interpretation for management implications would require 

either an increase in the workloads of existing staff or the need for additional staff. 

Conclusion

Relative to the other alternatives, this alternative would offer the least opportunity to 

accommodate increased public interest in backcountry and wilderness camping, but would offer 

the greatest opportunities for solitude and tranquility while camping throughout the visitor 

season. Actions proposed in this alternative could have long-term minor to moderate beneficial 

effects on natural and cultural resources. This would be the only alternative to preserve low use 

times in Spring and Fall, with associated benefits to resources that are more vulnerable during 

these times of the year. 

Unavoidable Adverse Impacts

As outlined above, implementing this alternative for managing overnight use of Isle Royale’s 

backcountry would be expected to have some unavoidable adverse impacts associated with 

limiting visitors’ access to backcountry camping. Limiting camping permits to the availability of 

campsites could make the park’s backcountry less accessible to some campers during parts of the 

busiest times of the year; some people would not be able to camp in their preferred campgrounds 

on their preferred dates.
Impacts of Alternatives for Overnight Use

192 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Table 19: Comparison of Environmental Consequences for Alternatives for Overnight use of the Wilderness and Backcountry

Alt A: Current Alt. B: Preferred Alt C Alt D Alt E

Proposed 

Changes

• Implement GMP by 

installing proposed 

new campgrounds

• Implement GMP by 

installing proposed new 

campgrounds

• Employ new Backcountry 

Office with Advanced 

Permitting

• Add 1 campsite at North 

Desor

• Institute no more than 5% 

sharing in summer

• Maintain historic low use 

in spring

• Implement GMP by 

installing proposed 

new campgrounds 

• Employ new

Backcountry Office

with Advanced 

Permitting

• Institute no more 

than 10% sharing 

during peak, 5% 

sharing or less rest 

of season

• Possible installation 

of new campsites 

and/or campgrounds

• Add shuttle service 

in Rock Harbor

• Implement GMP by 

installing proposed 

new campgrounds

• Implement entry 

quota system

• Limited site 

reservations

• Add 1 campsite to 

North Desor

• Institute no more than 

5% sharing all season

• Implement GMP by 

installing proposed 

new campgrounds 

• Employ new 

Backcountry Office

with Advanced 

Permitting

• Institute no more 

than 5% sharing 

during peak, 1% 

sharing or less rest 

of season

• Maintain historic 

low visitation in 

spring and fall

Visitor Use 

and 

Experience

A long-term moderate 

beneficial impact to 

visitor use is that public 

access would remain high, 

with significant increases 

in visitation possible 

outside of the peak few 

weeks of the season. A 

long-term, moderate, 

adverse impact to visitor 

experience would be 

diminished opportunities 

to visit the park at low use 

times. Information would 

not be available to avoid 

overcrowded 

campgrounds and 

overcrowding would 

continue and could 

increase. 

Long-term moderate 

beneficial impacts to visitor 

use include: visitation could 

increase from mid June 

through October, advanced 

permitting would better 

distribute people to available 

campsites and reduce the 

frequency of overcrowding, as 

well as, give campers a greater 

assurance of finding an 

available campsite, and 

opportunities to visit the park 

during low use times would be 

preserved. Conversely, some 

people may not be able to get 

a permit for their preferred 

itinerary and public access 

may be limited in spring, both

long-term, minor adverse 

impacts.

An expected long-term, 

minor beneficial impact 

compared to current 

conditions due to 

decreased campsite 

sharing. A long-term, 

moderate beneficial 

impact compared to the 

preferred alternative 

because of greater 

public access. 

However, long-term, 

moderate adverse 

impacts include: greater 

likelihood of sharing, 

higher levels of 

campground crowding, 

larger campgrounds, 

and a potential loss of 

the very low use times 

in spring and fall. 

Long-term, minor 

beneficial impact 

compared to current 

conditions with reduced 

campground crowding, 

but long-term, moderate 

adverse impact with 

decreased public access 

to the park. Compared to 

preferred, this alternative 

has a lower likelihood of 

accommodating July and 

August visitation and 

greater likelihood of 

increased visitation in 

Spring, with decreased 

opportunities for solitude 

and isolation. 

Long-term, minor 

beneficial and adverse 

impacts equivalent to

those outlined in the 

preferred alternative, 

with the addition of 

maintaining low use in 

the fall and spring, 

limiting the ability to 

accommodate increased 

visitation but allowing 

opportunities for 

solitude and isolation. 

This is a long-term, 

moderate adverse 

impact to visitor use 

and a long-term, 

moderate beneficial 

impact to visitor 

experience.
Impacts of Alternatives for Overnight Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 193

Table 19 (continued): Comparison of Environmental Consequences for Alternatives for Overnight use of the Wilderness and 

Backcountry

Alt A: Current Alt. B: Preferred Alt C Alt D Alt E

Wilderness The impacts to wilderness 

character would be 

expected to be long-term, 

moderate and adverse. 

Overcrowding in 

campgrounds would 

continue or increase. 

Access to the wilderness 

and backcountry would be 

high, but increased 

visitation could lead to a 

reduction in opportunities 

for solitude and 

tranquility.

Impacts to wilderness 

character would be long-term, 

moderate and beneficial. 

Overcrowding in 

campgrounds would be 

reduced. A wide range of 

opportunities for wilderness 

experiences would be 

protected. Beneficial impacts 

to wilderness character would 

be greater than with current 

conditions or alternative C. 

Long-term, minor

beneficial impacts 

realized when 

compared to the No 

Action alternative. 

Adverse impact of 

higher use levels and 

more frequent sharing 

compared to preferred 

alternative. 

Greater access to 

remote backcountry 

with new shuttle service 

would be a long-term, 

moderate adverse 

impact to wilderness 

character.

Long-term, minor 

beneficial impacts as

compared to current 

conditions. A long-term, 

minor adverse impact 

compared to the

preferred alternative due 

to a greater likelihood of 

increasing visitation in 

spring and decreased 

opportunities for solitude 

and isolation.

Same long-term, 

moderate beneficial 

impacts as the preferred 

alternative, with the 

added beneficial impact 

of maintaining 

extremely low visitation 

in the fall and spring 

providing increased

opportunities for 

solitude, isolation, and 

self-sufficiency.

Natural 

Resources

Impacts to natural 

resources would be 

expected to be long-term, 

adverse, and moderate to 

major on a localized 

scale. Continued 

campground crowding 

would mean continued 

campsite sprawl and 

associated habitat change. 

Increasing spring and fall 

visitation could adversely 

impact wildlife at 

sensitive times.

Impacts to natural resources 

would be long-term, moderate 

and beneficial compared to 

current conditions. Reduced 

overcrowding in campgrounds 

would reduce adverse 

biophysical and noise impacts. 

Maintaining low visitation in 

spring would minimize 

adverse impacts to wildlife. 

However, long-term, minor 

adverse effects include adding 

one new campsite at North 

Desor and allowing a 

substantial increase in fall 

visitation.

Long-term, moderate 

adverse impacts from 

an increase in total 

footprint area and

physical disturbance

from campgrounds 

(increased number of 

campsites and 

campgrounds), Longterm, moderate adverse 

impact on wildlife from 

changes in travel 

patterns, and increased 

use possible in spring 

and fall

A long-term moderate 

beneficial impact 

compared to the No 

Action Alternative by 

reducing impacts 

associated with 

crowding. Potential 

adverse impacts when 

compared to the 

preferred alternative with 

increased visitation in 

spring and fall affecting 

wildlife.

Similar long-term, 

moderate beneficial 

impacts as the preferred 

alternative with the 

added benefits of 

maintaining low 

visitation in the fall. 

This would have a 

long-term minor

beneficial impact on 

wildlife. Additionally, 

removing one campsite 

from Little Todd is a 

long-term minor 

beneficial impact on 

vegetation and wildlife 

habitat in the immediate 

surrounding area.
Impacts of Alternatives for Overnight Use

194 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Table 19 (continued): Comparison of Environmental Consequences for Alternatives for Overnight use of the Wilderness and 

Backcountry

Alt A: Current Alt. B: Preferred Alt C Alt D Alt E

Cultural 

Resources

Impacts would be short 

or long-term and minor 

or major, depending on 

the significance and 

integrity of affected 

resources. Adverse 

effects to cultural 

resources associated 

with campsite sprawl 

could continue or 

worsen. Damage to 

archeological resources 

would be irreversible.

The following effects would 

be long-term and their severity 

would depend on the 

significance and integrity of 

the affected resources. 

Reducing campground 

overcrowding and maintaining 

low visitation in the spring 

would have long-term, minor 

beneficial impacts on cultural 

resources. Adding one new 

campsite at North Desor could 

have adverse effects on 

unknown cultural resources. 

Potential long-term, 

minor to major adverse 

impacts to unknown 

archeological sites with 

increased development 

of campgrounds. 

However, long-term, 

minor beneficial 

impacts are expected 

when compared to 

current conditions by

decreased sharing and 

sprawl.

A long-term, minor 

beneficial impact is 

expected when compared 

to current conditions 

with reduced impacts 

from overcrowding in 

campgrounds. Less 

beneficial impact as 

compared to the 

preferred alternative 

because of the likelihood 

of increased spring 

visitation.

Impacts are the same as

those outlined in the 

preferred alternative.

Socioeconomic 

Effects

Long-term, minor 

beneficial effects on the 

economies of local 

communities are 

expected with increased 

visitation.

A potential minor, beneficial 

effect for local communities if 

peak season backcountry 

visitation decreased and this 

resulted in an increase in day 

use visitors as they typically

spend more money. Longterm negative impacts could 

include increased cost per 

visitor if permitting fees were 

implemented.

Long-term, minor 

beneficial impacts to 

local communities if 

annual visitation 

increased. Long-term 

negative impacts could 

include increased cost 

per visitor if permitting 

fees were implemented.

A potential for minor, 

beneficial and adverse 

impacts to local 

communities if peak 

season backcountry 

visitation decreased and

the rest of the season 

increased, day use 

increased, annual 

visitation decreased.

Long-term, adverse 

impacts to local 

communities from the 

likelihood of decreased 

annual visitation and 

long-term negative 

impacts could include 

increased cost per 

visitor if permitting fees 

were implemented.

Park 

Operations

Long-term, minor 

adverse impact to park 

operations is expected. 

No additional staffing 

or facilities would be 

necessary. 

There would likely be 

an increased 

maintenance workload 

associated with 

rehabilitating and 

restoring sprawling 

campsites.

Long-term minor adverse 

impact to park operations is 

expected. Additional staffing 

would be required to initiate

and run a backcountry office. 

Short-term costs would be 

moderate, and long-term costs 

would be minor to moderate. 

Short-term costs of 

constructing a new campsite at 

North Desor would be minor, 

as would long-term costs for 

maintenance.

Long-term, minor 

adverse impact to park 

operations is expected. 

Minor to moderate 

increase in maintenance 

workload with new 

campsites and/or 

campgrounds. Potential 

minor to moderate costs 

associated with 

operating a shuttle in 

the Rock Harbor

Channel.

Long-term minor, 

adverse impact to park 

operations is expected. 

Minor increase to 

workload anticipated 

with constructing and 

maintaining a new 

campsite, managing the 

new site reservations 

system for a limited 

number of campsites and 

coordinating with the 

ferries to manage the 

entry quota system.

Long-term, minor 

adverse impact to park 

operations is expected. 

Short-term increased 

workload of removing 

and rehabilitating one 

campsite at Little Todd, 

and long-term increased 

workload associated 

with running the 

backcountry office is 

anticipated.
Impacts of Alternatives for Day Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 195

4.2.3 Impacts of Alternatives for Managing Day Use in the Wilderness and Backcountry

Alternative A for Day Use: No Action, Maintain Current Management Direction

The details of this alternative are outlined in Chapter 2, p. 79-80. Maintaining the status quo for 

managing day use in the wilderness and backcountry could result in measurable environmental 

consequences. Actions that could result in impacts include:

• Visitors would have the option of participating in day tours organized and led by the NPS 

and the Rock Harbor Lodge, including hikes in and around Windigo and Rock Harbor, 

and tours with the M.V. Sandy. Access to these tours and group sizes would be limited 

only by tour boat capacities (currently 40 people).

• Private organizations leading groups on day trips (such as educational groups) would not 

be limited in group sizes or tour destinations.

Maintaining current policies for day use of Isle Royale’s wilderness and backcountry would be 

expected to have measurable consequences for visitor use and experiences, wilderness character, 

natural resources, cultural resources, and socioeconomics. Impacts would primarily be related to 

the numbers of people on organized tours and the locations of these tours. The assessment of 

impacts is based on current conditions and an assumption that day use would either continue at 

current levels or increase. 

Effects on Visitor Use and Experiences

The M.V. Sandy carries a maximum of 40 passengers. The NPS keeps statistics on group sizes 

for the tours that are led by rangers. A recent 3-year average of the Hidden Lake/Lookout Louise 

tours showed 17 trips per season, 19 people per trip, and a maximum of 42 people on one tour. 

A similar look at Passage Island showed 11 trips per season, an average of 21 people per trip, 

and a maximum of 38 people on one tour (Parratt 2003). These numbers would be expected to 

continue, or possibly increase up to the maximum boat capacity of 40 people per trip in the 

future under this alternative. Visitor access to formal day tours would be limited only by tour 

boat capacities. There are no limits to the sizes of day tours organized by other organizations 

visiting the park. Therefore continuing the current management direction would retain high 

access to day tours. 

This alternative would also be expected to have the beneficial effect of providing educational 

programs for a large number of visitors on day tours. 

Effects on Wilderness Character

Currently the concessions-operated M.V. Sandy conducts tours to three areas that include 

designated wilderness—Hidden Lake/Lookout Louise, Passage Island, and the Minong Mine and 

Pine Mountain. Group sizes may be as large as 40 people on these tours, though tours this large 

are infrequent, as average groups are closer to 20 people. The NPS and other organizations also 

lead hikes within wilderness in the vicinity of Rock Harbor. Continuing high access to the 

park’s wilderness through a variety of organized day tours would have a beneficial effect of 

maintaining current opportunities for day visitors, lodge guests and other people taking day trips 

into the wilderness. However, large groups can have an adverse effect on the wilderness 

experiences of tour participants and others in the area. Noise, physical impacts, and crowding 
Impacts of Alternatives for Day Use

196 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

associated with large groups can detract from wilderness experiences and naturalness. Noise, 

crowding, and displacement of wildlife in the area would be minor to moderate short-term 

adverse effects, while the trampling associated with large groups at destination sites could be a 

short or long-term minor to moderate impact, depending on the resilience of the impacted site.

The NPS does not collect information on day groups traveling independent of concessions or 

NPS-led tours. Therefore, it is not known how common it is for day groups to travel off trail. 

Under current conditions, day tours of any size could travel off trail with no restrictions. Were 

this to occur, or even become popular, there could be adverse effects on the naturalness of the 

park’s most pristine wilderness areas, including displacement of wildlife, trampling of sensitive 

plants and habitats, and reductions in natural sounds. 

Effects on Natural Resources

Continuing current practices for day tours would be expected to have adverse impacts on soils, 

vegetation, wildlife, and natural quiet. Large day tours gathered around an attraction site can 

lead to expanded areas of impact beyond official trails, with vegetation trampling, loss of ground 

cover, compacted soils, and increased erosion. As noise and duration of human presence 

increases with group size, larger groups would also be expected to have a greater adverse effect 

on wildlife, displacing wildlife that is sensitive to human presence. These impacts would be 

expected to be localized to the immediate vicinity of the day tours. Impacts to wildlife would be 

expected to be short-term where tours are infrequent, while impacts to vegetation and soils could 

be long-term. 

Effects on Cultural Resources

Large groups of unregulated size could expand beyond the trails and impact archeological sites 

along and near trails. Historic structures at Edisen Fishery, Rock Harbor Lighthouse, and 

Passage Island Lighthouse (Franks, 1999) would be expected to could possibly be damaged if 

large groups expand beyond acceptable areas. There is no predicted impact on cultural objects 

located in the museum collection, but cultural objects located near the trails would be impacted if 

large groups extend beyond the trails. 

Cultural landscapes at Edisen Fishery, the four lighthouses and Washington and Barnum Islands 

could be negatively impacted if large groups expand beyond the trails. The Park Service does 

not presently know of impacted ethnographic resources but unidentified resources near trails may 

be impacted if large groups expand beyond the width of the trails. 

Socioeconomic Effects

Continuing or increasing the number of visitors traveling to the park on day trips would be 

expected to have minor, long-term economic benefits on the local communities. Day visitors 

spend money in the local communities on ferry passage, and may also spend money on food, 

lodging, and souvenirs. Maintaining high access to formal day tours could also help to increase 

the annual number of guests at the Rock Harbor Lodge, an economic benefit for that private 

business as well as the local communities those visitors travel through to reach the park. Lodge 

guests are expected to spend money in the local communities on ferry passage, food, lodging, 

and other incidental expenses. Day visitors are estimated to spend an average of $150-168 per 

party per day in the local communities, while Lodge guests spend $330 per party per day 
Impacts of Alternatives for Day Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 197

(including food and lodging at the Rock Harbor Lodge). Any increase in these visitors would be 

seen as a benefit to the tourism-dependent local economies. 

Effects on Park Operations

If maintaining current conditions for day use were to result in increased trampling and erosion at 

attraction sites, it could necessitate site restoration and maintenance work to minimize the spread 

of impacted areas. This would be a minor adverse impact on park operations, as it would not be 

expected to require additional staffing. No other measurable effects on park operations would be 

expected. 

Conclusion

Maintaining the status quo for managing day use on Isle Royale would be expected to have the 

beneficial effect of providing high access to formal day tours. Adverse effects to wilderness 

character, natural resources, and cultural resources associated with crowding and trampling at 

destination sites and along trails would also be expected, as would the adverse effects associated 

with crowding and large groups of people along wilderness and backcountry trails. 

Unavoidable Adverse Impacts

As outlined above, maintaining the current management direction for day use would be expected 

to have some unavoidable adverse impacts to natural and cultural resources and wilderness 

character associated with large tour groups (up to 40 people) visiting wilderness and historic 

destinations in the backcountry and congregating off of trails. Within small localized areas near 

tour destinations, trampling off trails could result in damage to or loss of vegetation and 

archeological resources, and compaction and exposure of soil. Additionally, the wilderness 

experiences of hikers and paddlers in the vicinity of tours visiting remote backcountry 

destinations (such as McCargoe Cove and Pine Mountain) would be adversely affected by the 

noise and visual disturbance of large tour groups for the limited duration of the tour. 

Alternative B for Day Use: Maximize High Quality Experiences in Day Use Areas 

The details of this alternative are outlined in Chapter 2, p. 80-81. Changes that could occur 

under this alternative that may have measurable environmental consequences include:

• The possible destinations of day tours would continue, but group sizes would be limited 

based on location of the tour.

Developed areas (Rock Harbor and Windigo)—no group size limits

Frontcountry areas (bordering developed areas and significant attractions such as 

Edisen Fishery, Scoville Point, Raspberry Island, Passage Island trail, and Suzy’s 

Cave)—group size limit of 20. 

Wilderness Portal, Backcountry and Primitive areas (the majority of trails and 

campgrounds, including concessions tours to Hidden Lake and Lookout Louise, 

and McCargoe Cove and the Minong Mine)—group size limit of 10. 

Pristine Areas (off-trail)—group size limit of 6

Implementing the changes proposed in this alternative for day use of Isle Royale’s wilderness 

and backcountry could have measurable consequences for visitor use and experiences, 

wilderness character, natural resources, cultural resources, socioeconomics, and park operations. 
Impacts of Alternatives for Day Use

198 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Impacts would primarily be related to the numbers of people on organized tours, the locations of 

these tours, and impacts on other visitors in day use areas.

Effects on Visitor Use and Experiences

Implementing this alternative is expected to result in either a reduction in the number of 

participants in day use activities or a change in the types of activities offered relative to current 

conditions. For example, NPS-led tours with the M.V. Sandy to Passage Island average about 21 

participants with tours offered twice a week, and under this alternative not more than 20 people 

would be permitted per tour. Hidden Lake and Lookout Louise tours average about 19 

participants on tours up to twice a week, and under this alternative the maximum size would be 

10 people. There is a possibility that it would not be economically feasible to continue tours to 

some parts of the park with the small group sizes established in this alternative (e.g. McCargoe 

Cove or Hidden Lake, which would be limited to 10 people per group). If this were the case, 

there would be fewer organized activities for day trips, and day visitors would lose reasonable 

access to some areas of the park. 

The adverse effect of reduced opportunities for visitors to participate in organized day activities 

could be offset by expanding the types of activities offered, such as an increase in NPS-led 

activities out of Rock Harbor. However, visitors may not consider these tours to be comparable 

to the boat tours in other areas of the park. 

The NPS does not keep statistics on privately organized groups, so it is unknown to what extent 

implementing these day group limits would have an effect. However, this would be a change 

from current unlimited group sizes for these day tours, with an expected reduction in access to 

these activities. Thus it is expected that this alternative could have a long-term adverse effect on 

public access to day tours on Isle Royale. 

This alternative would also be expected to have the long-term beneficial effect of improving the 

experiences of participants on day tours, and other visitors in the area of the tours. The small 

group sizes proposed in this alternative are compatible with group size limits for camping parties 

in the area of day tours, and are compatible with the appropriate opportunities within each 

management zone. 

Effects on Wilderness Character

The group size limits proposed for day tours in this alternative would be expected to reduce 

crowding, noise, and trampling along the trails and destination sites used for day tours within the 

park’s wilderness. This would be expected to improve the quality of wilderness experiences for 

tour participants as well as other visitors in the area and reduce impacts to the naturalness of the 

areas; a long-term beneficial effect. However, these limits would also restrict access to these 

tours, reducing the number of visitors benefiting from such opportunities: a long-term adverse 

effect. 

Effects on Natural Resources

This alternative would be expected to have the greatest beneficial effect on natural resources. 

Implementing this alternative would be expected to have the beneficial effect of reducing the 

number of people gathered at destination areas, with associated reduction in trampling. 
Impacts of Alternatives for Day Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 199

Compared to current conditions, this would be expected to have a beneficial effect on vegetation 

and soils. Reducing the group sizes of day tours in the park’s wilderness and backcountry would 

also be expected to have the beneficial effect of reducing noise in these areas, a benefit to 

wildlife. However, if this alternative were to result in a decrease in the total number of visitors 

participating in organized day tours each year, then it could have the adverse effect of reducing 

the number of people participating in educational programs. Public education is an important 

aspect of any conservation program. Because the NPS would have other options for public 

education, including outreach programs, publications, and programs focused on visitors prior to 

reaching the park, this would be a minor adverse impact. 

Effects on Cultural Resources

This alternative limits the possible negative impacts from large groups of unregulated size 

expanding beyond the trails. Appropriate group size limits could lessen possible impacts to 

historic structures and to archeological sites located along and near trails. Possible adverse 

impacts to cultural landscapes at Edisen Fishery, the four lighthouses and Washington and 

Barnum Islands could also be minimized with group size limits. The park service does not 

presently know of impacted ethnographic resources but with the size limits proposed in this 

alternative unidentified resources near trails would be expected to experience less negative 

impact from large groups expanding beyond the width of the trails.

This alternative would be expected to be effective in lessening impacts to cultural resources 

because it establishes limits on the number of day users in a single group. It is very large groups, 

rather than a high total number of visitors, that are liable to expand beyond trails and acceptable 

areas thereby damaging cultural resources. By limiting the size of single groups this alternative 

limits the potential negative impacts to sensitive cultural resources, and would be expected to 

have the greatest beneficial effect on protecting cultural resources. However, limiting day tour 

sizes and the number of people able to visit cultural sites on guided day tours may limit public 

education about the park’s cultural resources. Incorporating off-site cultural education into the 

park’s interpretive programs and public outreach efforts could offset this adverse effect. 

Socioeconomic Effects

Limiting group sizes may adversely affect how tour groups operate and the financial viability of 

operating day tours within Isle Royale’s wilderness and backcountry. Additionally, if 

establishing these group size limits were to result in a reduction in day visitors, Lodge guests, or 

other visitors who would participate in day trips, then this alternative could have a long-term 

adverse effect on local communities. Day visitors and lodge guests are estimated to spend more 

money in the local communities than backcountry visitors. 

Effects on Park Operations

Implementing group size limits could result in the NPS increasing the types of organized day 

activities offered in the park to accommodate visitors interested in these activities. If this were 

the case, the NPS workload could increase, with a possible need to increase Rock Harbor or 

Windigo interpretive staff during the summer season. This could be a long-term minor adverse 

impact on park-wide operations, and a moderate impact on interpretive operations. 
Impacts of Alternatives for Day Use

200 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Conclusion

Relative to the other alternatives, this alternative would be expected to have beneficial effects on 

wilderness character, natural and cultural resources, and the experiences of visitors on day tours 

or in the vicinity of day tours. However, it would also be expected to have an adverse effect on 

pubic access to organized day activities. This alternative could result in the greatest decrease in 

the number of people participating in organized day activities, and possibly an elimination of 

some existing tours. 

Unavoidable Adverse Impacts

As outlined above, implementing this alternative for managing day use would be expected to 

have some unavoidable adverse impacts on visitors’ opportunities to participate in guided tours 

in the backcountry, and on the financial feasibility of businesses continuing to offer guided tours. 

Reducing maximum tour group sizes from 40 to 10 or 20 people for some of the more popular 

tour destinations it is likely that visitors would have significantly less access to day tours. Fewer 

spaces would be available for tours and it is likely that it would not be financially feasible for 

businesses to run tours with such small groups.

Alternative C for Day Use: Expand Opportunities for Quality Day Use Activities (The 

Preferred Alternative)

The details of this alternative are outlined in Chapter 2, p. 81-82. Changes that would be 

expected under this alternative that may have measurable environmental consequences include:

• The possible destinations of day tours would continue, but large groups would need to 

split into multiple groups in some areas of the park to not exceed group size limits in 

those areas:

Developed areas (Rock Harbor and Windigo)—no group size limits

Frontcountry areas (bordering developed areas and significant attractions such as 

Edisen Fishery, Scoville Point, Raspberry Island, Passage Island trail, and Suzy’s 

Cave)—group size limit of 20. 

Wilderness Portal, Backcountry and Primitive areas (the majority of trails and 

campgrounds, including concessions tours to McCargoe Cove and the Minong 

Mine)—group size limit of 10. Hidden Lake and Lookout Louise, in this zone, 

would be an exception, allowing group with up to 15 people. 

Pristine Areas (off-trail)—group size limit of 6

• A new trail would be constructed in Windigo

Implementing the changes proposed in this alternative for day use of Isle Royale’s wilderness 

and backcountry could have measurable consequences for visitor use and experiences,

wilderness character, natural resources, cultural resources, socioeconomics, and park operations. 

Impacts would primarily be related to the numbers of people on organized tours, the locations of 

these tours, and impacts on other visitors in day use areas.

Effects on Visitor Use and Experiences

With this alternative, the same opportunities currently available for day tours would continue, as 

long as the tour organizers were able to provide multiple tour leaders for larger groups. If tour 

organizers were unable to provide an adequate number of leaders, then access to guided day 
Impacts of Alternatives for Day Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 201

hikes could be limited, as with Alternative B. It is thought that the quality of experiences for 

tour participants would improve with smaller sizes, and experiences would be more appropriate 

for backcountry and wilderness settings. With smaller groups, tour participants would be 

expected to be able to hear the guide better, have a greater opportunity to interact with the guide, 

and generally stay together as one cohesive tour better. 

Smaller tour sizes could also have a beneficial effect on other visitors in the area of the tours, as 

noise, and other adverse impacts associated with large groups would decrease. However, 

splitting large tours into multiple groups on the same trail could increase the duration and 

frequency of encounters and noise, a potentially adverse effect compared to the current condition 

of one encounter with a larger group. 

Group size limits are expected to primarily affect day activities in the Rock Harbor area. The 

new trail in Windigo proposed in this alternative would provide an opportunity for a loop hike 

into the backcountry for day visitors. The majority of visitors who visit the park for part of a day 

visit Windigo with just a few hours to experience Isle Royale, and the trail would be intended for 

their benefit. Any new organized tours on this trail would be compatible with a backcountry trail 

and not exceed 10 people. 

Effects on Wilderness Character

Compared to current conditions, this alternative would be expected to have the same beneficial 

effects on the experiences of tour participants and others in the area associated with smaller 

groups along the trail and at destination sites as described in Alternative B. However, unlike 

Alternative B, this alternative would likely result in a greater number of tour groups. This would 

result in the beneficial effect of greater opportunities for visitors to participate in day tours in the 

wilderness, but could also have adverse effects for other visitors in the area. An increase in the 

number of tours groups at a given time on a trail could increase the frequency of encounters and 

the duration of noise associated with the tour group, though these impacts would be expected to 

be short-term. 

Similar to Alternative A, smaller groups would be expected to have the beneficial effect of 

reducing trampling off trail and at destination sites associated with large groups, and reducing 

the threat of adverse impacts in pristine areas associated with large groups. However, splitting 

into multiple groups could increase the extent and duration of wildlife displacement associated 

with human presence and noise. These adverse effects are expected to be short-term and 

reversible.

This alternative also proposes the creation of a new trail in Windigo, specifically designed as a 

loop trail for day visitors. This trail would create an opportunity for a loop trail with a more 

remote, backcountry feel than the Windigo Nature Trail. This would also provide an option 

other than hiking on the trails used by backpackers. This trail would have the long-term adverse 

impact of expanding development in the park. It would also have the beneficial effect of 

providing opportunities for higher quality wilderness and backcountry experiences on day visits 

to the park. It would also be intended to reduce day use along backpacker routes out of Windigo, 

a beneficial effect on the wilderness experience of backpackers.
Impacts of Alternatives for Day Use

202 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

The proposed new trail would be constructed in what is currently zoned Pristine, requiring 

conversion of the trail corridor to Backcountry Zone. Efforts would be made to keep the trail 

corridor within non-wilderness, but portions could extend into designated wilderness, 

development that would be a localized moderate to major adverse impact to naturalness. 

Overall, this alternative is expected to have both beneficial and adverse effects on wilderness 

character compared to current conditions and Alternative B. The beneficial effects would be 

expected to be long-term and the adverse effects would be expected to be short-term. The 

severity of these effects are unknown, but are expected to be minor to moderate. 

Effects on Natural Resources

Compared to current conditions, this alternative would be expected to have less adverse effects 

on vegetation and soils associated with trampling at destination areas, because fewer people 

would be gathered at destination sites at one time. This alternative would likely result in a 

greater number of groups on a trail, though these groups would be smaller. Compared to current 

conditions with all of the tour participants traveling in one concentrated group, this could have an 

adverse effect on some wildlife. Adverse effects, though less severe, could be longer lasting or 

more widespread, depending on whether the tours split up along the same trail or on different 

trails. For example, human noise, which displaces wildlife, would be expected to be longer 

lasting if large groups were to split up and hike down the same trail than if they all traveled as 

one consolidated group. 

Creating a new trail near Windigo for day use could have the adverse effects of fragmenting 

habitat, expanding development, and increasing the disturbances associated with human 

presence. On a local scale these impacts could be moderate to major, but park-wide would be 

minor. Natural resource surveys in the area would help to minimize these adverse impacts by 

selecting a route for the trail that would have the least impact possible on sensitive resources. 

Effects on Cultural Resources

This alternative limits the possible negative impacts from large groups of unregulated size 

expanding beyond the trails. Appropriate group size limits could lessen possible impacts to 

historic structures and to archeological sites located along and near trails. Possible impacts to 

cultural landscapes at Edisen Fishery, the four lighthouses and Washington and Barnum Islands 

could also be minimized with group size limits. The park service does not presently know of 

impacted ethnographic resources but unidentified resources near trails may experience less 

negative impact from large groups expanding beyond the width of the trails with the size limits 

proposed in this alternative.

An archeological survey along the proposed route of the new trail in Windigo would prevent 

adverse impacts to cultural resources associated with construction of the trail. 

This alternative could be effective in lessening impacts to cultural resources because it 

establishes limits on the number of day users in a single group. It is very large groups, rather 

than a high total number of visitors, that are liable to expand beyond trails and acceptable areas 

thereby damaging cultural resources. By limiting the size of single groups this alternative limits 

the potential negative impacts to sensitive cultural resources. Additionally, allowing boat tours 
Impacts of Alternatives for Day Use

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 203

to carry multiple smaller groups this alternative would provide better access to cultural resources 

than would Alternative B, while also improving conditions over the current conditions 

(Alternative A).

Socioeconomic Effects

Requiring large groups to split up would require multiple group leaders, which could affect how 

tour groups operate and the financial viability of operating day tours within Isle Royale’s 

Wilderness and backcountry. If this alternative were to result in some organizations no longer 

being able to operate in the park, that would be considered a long-term adverse effect. However, 

one intention of this alternative is to provide more high-quality activities for day visitors to Isle 

Royale’s wilderness and backcountry. Increasing options for trips and improving the quality of 

activities could result in increased day visitation to the park. If this were the case it would be a 

long-term beneficial effect for local communities and their economies. 

Effects on Park Operations

Requiring large tour groups to split into multiple groups for guided hikes could have an adverse 

impact on NPS operations. Some NPS-led tours would require more staff to accommodate 

current or increased interest in day tours. For example, groups on Hidden Lake/Lookout Louise 

tours average 19 people, and under this alternative two rangers would be needed to lead two 

distinct groups to comply with the 15-person size limit. This could have a long-term moderate 

adverse impact on the Rock Harbor interpretive program. 

Creating a new trail near Windigo would have a minor to moderate short-term adverse effect on 

park operations, associated with the costs of construction. This would require either hiring 

additional staff or removing staff from other trail projects. Additionally, there would be an 

increased workload for the trail crew with additional miles of trail to maintain; a minor long-term 

adverse effect.

Conclusion

Relative to current conditions (Alternative A) and Alternative B, this alternative would be 

expected to maintain high access to organized day activities while also improving the quality of 

experiences for tour participants. Some adverse effects on wilderness character and natural 

resources would continue, but beneficial effects on cultural resources and public education 

would increase over current conditions. 

Unavoidable Adverse Impacts

As documented above, implementing this preferred alternative would be expected to have 

unavoidable adverse impacts on natural resources. Establishing a new trail in the previously 

undisturbed area of a Pristine Zone near Windigo, a portion of which would be within designated 

Wilderness, would result in a loss of vegetation, compaction and exposure of soil, and 

fragmentation of habitat along the trail corridor. Splitting large tour groups into multiple groups 

at tour destinations could increase the extent and duration of wildlife displacement and 

disturbance of wilderness character associated with human presence and noise, especially where 

tours visit backcountry areas (e.g. Hidden Lake, Passage Island and Pine Mountain).
Impacts of Alternatives for Day Use

204 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Table 20: Comparison of Environmental Consequences for Day Use Alternatives

Alt A: No Action 

Alternative Alt. B Alt C: (Preferred)

Proposed 

Changes

• Maintain existing access with 

no limitations on group size

• Access to tours would only be 

limited by the capacity of the 

MV Sandy (40 passengers) 

• Institute group size limits 

ranging from 6-20 by 

management zone, for all 

except the developed zones 

of Windigo and Rock Harbor 

• No guided tours over 20 in 

the wilderness and 

backcountry, lower limits in 

some areas of the park.

• Group size limits, with large 

groups allowed to split up. 

• MV Sandy can carry up to 40 

passengers total – split into 

multiple groups at 

destination

• Explore options for adding a 

new loop trail in Windigo

Visitor Use 

and 

Experiences

Long-term, moderate beneficial 

effect of high level of access to 

tours and group activities because 

of no size limits. Some visitors’ 

experiences may be negatively 

affected by being part of such a 

large group.

Long-term, moderate adverse 

impact to visitor access to tours 

and group activities because of 

low size limits. Long-term, 

moderate, beneficial impact to 

quality of tours due to smaller 

group sizes. 

Long-term minor adverse 

impact to visitor access to tours 

and group activities due to size 

limitations. Long-term, 

moderate, beneficial impact to 

quality of tours due to smaller 

group sizes. 

Wilderness Large groups can have a negative 

impact on the wilderness 

experience both for those in the 

group and for others. Minor, 

short- term adverse impacts 

include noise, crowding, and 

displacement of wildlife. 

Trampling could be a short or 

long-term minor to moderate 

impact. 

Smaller groups are more 

compatible with wilderness 

experiences both for group 

members and others. Minor, 

short-term beneficial impacts 

include less noise, crowding 

and displacement of wildlife. 

Less trampling could be a short 

or long-term minor to moderate 

impact. 

Smaller groups are more 

compatible with wilderness 

experiences both for group 

members and others. Minor, 

short-term beneficial impacts 

include less noise, crowding 

and displacement of wildlife. 

Less trampling could be a short 

or long-term minor to moderate 

impact. 

Natural 

Resources

Adverse impacts to wildlife would 

be localized and short-term. 

Adverse impacts to vegetation and 

soils would be localized and could 

be long-term. 

Beneficial impacts to wildlife 

would be localized and shortterm. Beneficial impacts to 

vegetation and soils would be 

localized and could be longterm.

Beneficial impacts to wildlife 

would be localized and shortterm. Beneficial impacts to 

vegetation and soils would be 

localized and could be longterm.

Cultural 

Resources

Cultural objects located near the 

trails could suffer long-term 

minor to moderate adverse 

impacts. Cultural landscapes may 

suffer short-term minor adverse 

impacts.

Cultural objects located near 

the trails would gain a minor to 

moderate beneficial impact 

from the smaller groups. 

Cultural landscapes would see 

a minor, short-term beneficial 

impact.

Cultural objects located near 

the trails would gain a minor to 

moderate beneficial impact 

from the smaller groups. 

Cultural landscapes would see 

a minor, short-term beneficial 

impact.

Socioeconomic 

Effects

Possible minor, long-term 

beneficial impacts if the number 

of visitors to the park were to 

increase based on the continued 

availability of day trips.

Possible minor, long-term 

adverse impacts if the number 

of day visitors to the park 

decreased with decreased 

access to guided day trips. 

Possible long-term adverse 

impact to organizations 

providing day trips, with fewer 

participants.

Possible minor, long-term 

adverse impacts if the number 

of day visitors to the park 

decreased based on availability 

of day trips. Possible long-term 

adverse impact to organizations 

providing day trips, as 

additional leaders may be 

required.

Park 

Operations

Possible minor adverse impact if 

increased staffing were required 

to minimize the spread of impact 

from trampling

Possible long-term, minor 

adverse impact to park-wide 

operations and a moderate 

impact to interpretative 

operations based on the need 

for additional staff to lead 

more, smaller tours

Possible long-term, minor 

adverse impact to park-wide 

operations and a moderate 

impact to interpretative staff 

based on the need for additional 

staff to provide multiple leaders 

for guided tours 
Impacts of Alternatives for Campfires

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 205

4.2.4 Impacts of Alternatives for Campfires in the Wilderness and Backcountry

Alternative A for Campfires: No Action, Maintain the Current Management Direction

The details of this alternative are outlined in Chapter 2, p. 83-84. Continuing the status quo for 

campfires would be expected to have measurable environmental consequences for the following 

reasons:

• Impacts to resources associated with campfires would continue or increase in the areas 

within and surrounding campsites where fires are permitted. 

• Opportunities for visitors to camp with fires would continue at some campgrounds.

Maintaining the current policies for campfires in Isle Royale’s wilderness and backcountry 

would be expected to have measurable consequences for visitor use and experiences, wilderness 

character, natural resources, cultural resources, and park operations. Impacts would primarily be 

related to the opportunities available for campers, impacts associated with collecting and burning 

locally collected firewood, and maintenance associated with campfires. Because campfires are 

not known or expected to have any effect on park-dependent businesses or economies, there are 

no known socioeconomic concerns.

Campfires are permitted within NPS-provided metal fire rings or grills only. To minimize the 

introduction of exotic species to the island no imported firewood is permitted, campers collect 

firewood locally. Campfires are currently permitted within NPS fire rings and grills at 11 

campgrounds; Caribou Island, Chippewa Harbor, Malone Bay, Siskiwit Bay, Island Mine, Little 

Todd, Todd Harbor, McCargoe Cove, Belle Isle, Duncan Narrows, and Duncan Bay. 

Effects on Visitor use and Experiences

Retaining or removing campfire rings would not be expected to have a measurable effect on park 

visitation, though the locations of permissible campfires could influence where some parties 

travel. Because some campers value campfires as an important part of a backcountry experience 

they may seek out those campsites where campfires were allowed. However, overall the policy 

of allowing campfires at some campgrounds, and not at others is expected to have both beneficial 

and adverse effects on visitors’ experiences. Public comments reveal that while some people 

value the opportunity for campfires and think this opportunity should be more widely available at 

Isle Royale, others report that the impacts to natural resources associated with campfires detract 

from their experiences (Isle Royale 2002). Locating campfires based on suitable resource 

conditions and removing fire rings to allow for resource recovery is expected to alleviate some of 

these adverse consequences. 

Effects on Wilderness Character

Continuing to allow campfires at some Isle Royale campgrounds would be expected to continue 

to have minor adverse effects on the naturalness of the areas surrounding those campgrounds, 

and possible minor beneficial or adverse effects on wilderness experiences, depending on a 

visitor’s viewpoint. Current conditions and visitor comments are reported by the park’s 

Wilderness Rangers. The development of informal trails, loss of woody debris and damage to 

trees associated with collecting firewood (e.g. limbing, scarring, and pealed bark detracts from 

the naturalness of areas surrounding campsites where campfires are allowed.) These adverse 
Impacts of Alternatives for Campfires

206 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

effects are currently noticeable at sites allowing fires and would be expected to increase the 

longer fires were permitted at a specific site. The opportunity to build and cook with campfires, 

a valued wilderness skill, and the social value of gathering around a campfire could have a 

beneficial effect on people’s wilderness experiences. However, the increased noise commonly 

associated with groups of people gathered around a campfire at night may have an adverse 

impact on other campers seeking tranquility and natural quiet. Campers do have the option of 

choosing campgrounds where campfires are or are not allowed. 

All of these effects would be minor to moderate, depending on the extent to which Leave-NoTrace practices were followed, and limited to the vicinity of campgrounds allowing fires. Loss 

of woody debris, the development of informal trails, and the social impacts associated with 

campfires are reversible, though damage to trees is irreversible. 

Effects on Natural Resources

Allowing campfires at specific campgrounds is known to have both beneficial and adverse 

impacts on natural resources in and surrounding campsites. Campsite monitoring on Isle Royale 

suggests that the presence of campfire rings may concentrate visitor activities, with smaller areas 

of vegetation trampling and soil exposure within a campsite; a beneficial effect. However, 

campsites with fire rings also have marginally greater tree damage adjacent to campsites and 

more informal trails, which are attributed to firewood gathering (Farrell and Marion 1998). The 

loss of firewood from these areas is also an adverse impact, in that this wood is important as 

woody debris associated with nutrient cycling, ground cover, and habitat for small animals. 

Some of this damage is temporary, but tree-limbing, scarring, and other damage that often goes 

hand-in-hand with campfires is permanent damage for a tree. These effects would be expected to 

continue as localized to the campsites with fires, and would be expected to be minor to moderate 

to the extent that campfire regulations and Leave-No-Trace practices were followed. 

Temporarily prohibiting campfires would allow for recovery from non-permanent damage at a 

campsite. 

The above effects are evident at some of the campgrounds that currently have fire rings or grills. 

For example, the lower limbs of many of the coniferous trees in and around Little Todd 

campsites have been removed, reducing screening between sites and the naturalness of the area. 

At Island Mine although there is abundant coarse woody debris in the maple forest of the area, 

much of the coarse woody debris is gone within the immediate vicinity of the campsites. In 

general, where there are fire rings, some people also tend to attempt to burn their trash instead of 

packing it out, which results in greater amounts of trash left behind in campsites with fire rings.

Isle Royale does not maintain detailed records on illegal campfires, but wilderness rangers report 

cleaning up the remains of illegal campfires consistently at some of the campgrounds with fire 

bans. Illegal fires are generally more common in spring and fall. Illegal fires have an adverse 

impact on natural resources, including sterilizing soils, damaging tree roots, and scarring rocks. 

There is also a concern for the more serious adverse effect of human-caused wildfires. Since 

1994, there have been at minimum 3 known cases of illegal campfires spreading and requiring 

NPS suppression action (pers. com., Valencia, March 23, 2004).

 
Impacts of Alternatives for Campfires

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 207

Effects on Cultural Resources

Campfires are currently allowed at eleven campgrounds. Under this alternative campfires would 

continue to be allowed at the same campgrounds unless resource conditions merit the removal of 

fire rings from a particular campground. Campfires and visitors seeking firewood have the 

potential to negatively impact cultural resources near these campgrounds. People establishing 

social trails in their search for firewood could impact archeological sites near campgrounds. 

Campfires in campgrounds near historic structures at Chippewa Harbor and Belle Isle (Franks, 

1999) could impact the structures if people used them as a convenient source of fuel or if an 

uncontrolled campfire burned the structures. Cultural objects located in the park and near 

campgrounds could be impacted by firewood seekers. Campfires are not allowed in cultural 

landscapes. Park staff do not know of any ethnographic resources impacted by campfires, but 

unidentified resources could be impacted by firewood gathering or uncontrolled fires.

Ground fires could also limit the ability of archeological researchers to use remote sensing 

technology to look for archeological sites. These technologies rely on differences in either 

magnetism or density between archeological resources and the surrounding materials. Fire can 

change the magnetism and density of ground and thereby make such remote research very 

difficult in the future.

Effects on Park Operations

Maintaining the current policies for campfires would continue the NPS workloads and time 

associated with maintaining and cleaning up fire rings, picking up trash burned illegally, 

educating the public about Leave-No-Trace practices, and enforcing fire regulations. There 

would not be an expected increase in staffing. The NPS would also continue monitoring 

resource conditions related to campfires, and retain the discretion to remove fire rings where 

resource impacts became unacceptable. 

Conclusion

Continuing with the status quo for campfires in the park would be expected to have both 

beneficial and adverse effects on wilderness character and visitor experiences. Minor to 

moderate long-term adverse effects on natural and cultural resources would be expected within 

the vicinity of where campfires are permitted. 

Unavoidable Adverse Impacts

Maintaining the status-quo for campfires would have unavoidable adverse effects on vegetation 

through continued impacts to vegetation associated with firewood collection; primarily decrease 

in woody debris, damage to standing trees, and vegetation trampling.
Impacts of Alternatives for Campfires

208 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Alternative B for Campfires: Rotate Campfire Rings Between Campgrounds Based on 

Resource Conditions (the Preferred Alternative)

The details of this alternative are outlined in Chapter 2, p. 84-85. Changes that could occur 

under this alternative that may have measurable environmental consequences include:

• Campfires would be allowed in a limited number of designated campgrounds, based on 

appropriate resource conditions, which could change from year to year.

• The NPS would make a commitment to monitor resource conditions associated with 

campfires to determine if impacts to resources were acceptable. 

Implementing this alternative and rotating campfires between a limited number of campgrounds 

within Isle Royale’s wilderness and backcountry could have measurable consequences for visitor 

use and experiences, wilderness character, natural resources, cultural resources, and park 

operations. Impacts would primarily be related to the opportunities available for campers, 

impacts associated with collecting and burning locally collected firewood, and NPS workloads 

required to monitor conditions and maintain rotating campfires. Because campfires are not 

known or expected to have any effect on park-dependent businesses or economies, there would 

be no socioeconomic concerns.

Effects on Visitor Use and Experiences

Retaining or removing campfires would not be expected to have a measurable effect on park 

visitation, though the locations of permissible campfires could influence where some parties 

travel. Because some campers value campfires as an important part of a backcountry experience 

they may seek out those campsites where campfires were allowed. Overall, however, the policy 

of allowing campfires at some campgrounds, and not at others is expected to have both beneficial 

and adverse effects on visitors’ experiences, depending on personal preference. Public 

comments reveal that while some people value the opportunity for campfires and think this 

opportunity should be more widely available at Isle Royale, others report that the impacts to 

natural resources associated with campfires detract from their experience. Locating campfires 

based on suitable resource conditions and removing fire rings to allow for resource recovery is 

expected to alleviate some of the adverse consequences. 

Effects on Wilderness Character

Allowing campfires at some Isle Royale campgrounds would be expected to have adverse effects 

on the naturalness of the areas surrounding those campgrounds, and possible beneficial or 

adverse effects on wilderness experiences. The development of informal trails, loss of woody 

debris and damage to trees associated with collecting firewood would detract from the 

naturalness of areas surrounding campsites with campfires. The opportunity to build and cook 

with campfires, a valued wilderness skill, and the social value of gathering around a campfire 

would be a beneficial effect on people’s wilderness experiences. However, the increased noise 

commonly associated with groups of people gathered around a campfire at night may have an 

adverse impact on other campers seeking tranquility and natural quiet. Under this alternative 

campers would have the option of choosing campgrounds where campfires were or were not 

allowed. 
Impacts of Alternatives for Campfires

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 209

All of these effects would be minor to moderate, depending on the extent to which Leave-NoTrace practices were followed. 

Effects on Natural Resources

Allowing campfires could have both beneficial and adverse impacts on natural resources in and 

around campsites. Campsite monitoring on Isle Royale suggests that the presence of campfire 

rings may concentrate visitor activities, with smaller areas of vegetation trampling and soil 

exposure within a campsite; a beneficial effect. However, campsites with fire rings also have 

marginally greater tree damage adjacent to campsites and more informal trails, which are 

attributed to firewood gathering. The loss of firewood from these areas is also an adverse 

impact, in that this wood is important as woody debris associated with nutrient cycling, ground 

cover, and habitat for small animals (Farrell and Marion 1998). Some of this damage is 

temporary where woody debris would re-accumulate in the absence of fires. However, treelimbing, scarring, and other damage that often goes hand-in-hand with campfires is permanent 

damage for a tree. These effects would be localized to the campsites with fires, and would be 

expected to be moderate to the extent that campfire regulations and Leave-No-Trace practices 

were followed. Rotating campfires to different campsites would allow for recovery from nonpermanent damage, but would also spread the extent of permanent damage. 

A further beneficial effect of allowing campfires within NPS-provided fire rings appears to be 

success in discouraging illegal fires at those sites (Reid and Marion 2002). Allowing fires within 

NPS-selected areas in metal fire rings is expected to have less adverse impact on natural 

resources than multiple illegal fire sites that would cumulatively spread scarring, vegetation and 

duff loss, and soil sterilization. 

Effects on Cultural Resources

Under this alternative campfires would be rotated to campgrounds that met certain basic 

requirements. Campfires and visitors seeking firewood have the potential to negatively impact 

cultural resources near these campgrounds. People establishing social trails in their search for 

firewood might impact archeological resources near campgrounds where fires have not been 

allowed and firewood seekers have not impacted the surrounding area and vegetation. Campfires 

in campgrounds near historic structures (Chippewa Harbor and Belle Isle) could impact the 

structures if people used the structures as a convenient source of fuel or if an uncontrolled 

campfire burned the structures. Other campgrounds near historic structures would not be 

included in the rotation of fire rings. 

Cultural objects located in the park and near campgrounds where fires have not previously been 

allowed could be impacted by firewood seekers. Campfires are not allowed in cultural 

landscapes and campgrounds in cultural landscapes would not be included in the rotation of fire 

rings. Park staff do not know of any ethnographic resources impacted by campfires, but 

unidentified resources could be impacted by firewood gathering or uncontrolled fires. 

Ethnographic resources might experience less negative impact under this alternative because fire 

rings would be rotated away from campgrounds where available fuel has been used. However, 

unknown ethnographic resources near campgrounds where fires are not currently allowed might 

be subject to negative impacts from firewood gathering under this alternative.
Impacts of Alternatives for Campfires

210 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Ground fires could also limit the ability of archeological researchers to use remote sensing 

technology to look for archeological sites. These technologies rely on differences in either 

magnetism or density between archeological resources and the surrounding materials. Fire can 

change the magnetism and density of ground and thereby make such remote research very 

difficult in the future. Completing surveys prior to installing fire rings could mitigate this. 

Effects on Park Operations

Rotating campfire rings between campgrounds and the associated monitoring necessary to 

determine when fire rings need to be moved would require a minor to moderate increase in NPS 

workload and associated spending. The additional maintenance work would be associated with 

moving fire rings and restoring the sites where fire rings were removed. Site restoration would 

involve removing remains of fires and rehabilitating areas damaged by campfires. 

Conclusion

Relative to current conditions (Alternative A) and Alternative C, this alternative would be 

expected to balance a beneficial effect on wilderness and visitor experiences with a minor to 

moderate adverse effect on natural and cultural resources. Impact monitoring and careful site 

selection, cornerstones of this alternative, would be designed to minimize these adverse effects. 

Unavoidable Adverse Impacts

Establishing a rotational system for campfires would be expected to lead to a greater incidence of 

permanent damage to trees (scarring, limbing and bark removal). Because these impacts are 

irreversible and strongly associated with allowable campfires, it is expected that these adverse 

impacts would become more wide-spread as campfires were allowed in more campgrounds over 

time.

Alternative C for Campfires: Eliminate all Campfires from the Wilderness and 

Backcountry

The details of this alternative are outlined in Chapter 2, p. 85-86. Changes that could occur 

under this alternative that may have measurable environmental consequences include:

• All campfires would be banned in the park, and fire rings and grills would be removed 

from campgrounds.

Implementing this alternative and banning all campfires in Isle Royale’s wilderness and 

backcountry could have measurable consequences for visitor use and experiences, wilderness 

character, natural resources, cultural resources, and park operations. Impacts would primarily be 

related to the opportunities available for campers, impacts associated with collecting and burning 

locally collected firewood. Because campfires are not known or expected to have any effect on 

park-dependent businesses or economies, there would be no socioeconomic concerns.

Effects on Visitor Use and Experiences

Banning campfires on Isle Royale would not be expected to substantially affect visitation to the 

park. However, visitors would no longer have the opportunity to camp with campfires. This 

may be an adverse effect for people who value campfires as part of their camping experiences. 
Impacts of Alternatives for Campfires

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 211

Other visitors may view a campfire ban as a beneficial effect for protecting park resources and 

the naturalness of areas surrounding campsites. 

Effects on Wilderness Character

Removing all campfires from Isle Royale campgrounds would be expected to have beneficial 

effects on the naturalness of the areas surrounding those campgrounds, and possible beneficial or 

adverse effects on wilderness experiences. The development of informal trails, loss of woody 

debris and damage to trees associated with collecting firewood detract from the naturalness of 

areas surrounding campsites with campfires. Thus eliminating campfires would be expected to 

be a beneficial effect on naturalness. However, building and cooking with campfires is a valued 

wilderness skill, and gathering around a campfire a valued social experience, so banning 

campfires could have an adverse effect on people’s wilderness experiences. Conversely, without 

campfires the increased noise commonly associated with groups of people gathered around a 

campfire at night would be gone which would have a beneficial impact on other campers seeking 

tranquility and natural quiet. 

Although this alternative would eliminate the opportunity to camp with campfires on Isle Royale, 

there are many other recreation and wilderness areas in the Lake Superior Region where 

campfires are allowed and where people may find this opportunity. Therefore, the adverse 

effects of banning campfires on Isle Royale would be considered minor. 

Effects on Natural Resources

Banning campfires could have both beneficial and adverse impacts on natural resources in and 

surrounding campsites. Campsite monitoring on Isle Royale suggests that the presence of 

campfire rings may concentrate visitor activities, with smaller areas of vegetation trampling and 

soil exposure within a campsite. Removing campfires could result in wider areas of vegetation 

trampling and loss of duff and the organic soil layer, an adverse effect. Campsites with fire rings 

do have marginally greater tree damage adjacent to campsites and more informal trails, which 

are attributed to firewood gathering. Removing fire rings would likely have the long-term 

beneficial effect of reducing tree damage in the vicinity of campsites (Farrell and Marion 1998). 

A loss of coarse woody debris is also associated with campfires, so this alternative would be 

expected to have the positive effect of restoring and preserving woody material that is 

ecologically valuable for nutrient cycling, ground cover, and habitat for small animals. The 

build-up of fine and coarse woody debris in the absence of campfires may also result in increased 

intensity of natural fires or escaped illegal fires.

A possible adverse impact of this alternative is that the frequency of illegal campfires may 

increase with a greater chance of people building fires in sensitive habitats where fires would be 

inappropriate. Were campfires allowed on a limited basis it is expected that fewer people would 

disregard fire regulations, since they would have some opportunity to build fires and the NPS 

would have the opportunity to focus educational efforts on low-impact fires. A comparison of 

impacts of fires from protected areas with different campfire policies, showed that restrictive 

campfire policies such as prohibitions do not appear to prevent campfire impacts (Reid and 

Marion, 2002.)
Impacts of Alternatives for Campfires

212 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Effects on Cultural Resources

Under this alternative campfires would not be allowed at Isle Royale. Campfires and visitors 

seeking firewood have the potential to negatively impact cultural resources located near 

campgrounds. If fires were no longer allowed at Isle Royale these potential negative impacts 

might be avoided. However, if an increase in illegal campfires resulted from removing all of the 

fire rings from the island there could be other negative consequences. Illegal campfires might 

have a greater chance of becoming uncontrolled and affecting larger areas of natural and cultural 

resources. Under the other alternatives the Park Service decides which campgrounds will have 

fire rings and could take into account sensitive natural and cultural resources. Under this 

alternative, there would be no fire rings at any campground and more visitors might decide to 

make illegal fires. Possible impacts to archeological resources, historic structures and cultural 

objects associated with firewood gathering should be less with this alternative. Under all of the 

alternatives, campfires would not be allowed in cultural landscapes. Unknown ethnographic 

resources might experience less negative impact from firewood gathering under this alternative 

because the resources would not be trampled or used for fuel. 

Effects on Park Operations

Removing campfires would initially have the adverse effect of minor to moderate cost increases 

to remove fire rings and restore old fire sites. Long-term the effect would be beneficial to park 

workloads and costs, eliminating the maintenance load associated with managing campfires, a 

minor beneficial effect. However, were this alternative to result in increased illegal campfires, 

there would be a minor adverse effect of increased workloads and costs to backcountry staff 

associated with regulation enforcement and cleanup of fire remains. 

Conclusion

This alternative would be expected to result in both beneficial and adverse impacts to wilderness 

character, natural and cultural resources, and visitor experiences. 

Unavoidable Adverse Impacts

Removing all permissible campfires from campgrounds could result in adverse impacts 

associated with illegal campfires, including fire scars, damage to trees, and damage to cultural 

resources.
Impacts of Alternatives for Campfires

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 213

Table 21: Comparison of Environmental Consequences for Campfire Alternatives

Alt A: Current 

Conditions

Alt. B: Preferred Alt C

Proposed Changes

Note: in all cases standing 

grills would be replaced 

with fire rings, except at 

the Rock Harbor Marina.

• Campfires would 

continue to be allowed at 

11 campgrounds were 

they are currently 

allowed

• Campfires would be 

rotated to appropriate 

campgrounds based on 

the fuel availability and 

the sensitivity of 

resources

• Campfires would not be 

allowed at any 

campgrounds in the 

park

Visitor Use and 

Experiences

Long-term, minor 

beneficial effect for those 

who enjoy campfires. 

Long-term minor adverse 

effect for those who do not

Long-term, minor 

beneficial effect for those 

who enjoy campfires. 

Long-term minor adverse 

effect for those who do not

Long-term, minor adverse 

effect for those who enjoy 

campfires. Long-term 

minor beneficial effect for 

those who do not

Wilderness Long-term, minor 

beneficial effect for those 

who see campfires as part 

of wilderness. Long-term 

minor adverse effect for 

those who do not. Longterm, minor adverse 

effects to naturalness.

Long-term, minor 

beneficial effect for those 

who see campfires as part 

of wilderness. Long-term 

minor adverse effect for 

those who do not. Longterm, minor adverse 

effects to naturalness.

Long-term, minor adverse 

effect for those who see 

campfires as part of 

wilderness. Long-term 

minor beneficial effect for 

those who do not. Longterm, minor beneficial 

effects to naturalness.

Natural Resources Long-term, minor, 

beneficial impacts to 

natural resources due to 

concentration of visitor 

impacts in campgrounds 

with fire rings and fewer 

illegal fires. Long-term, 

minor adverse impacts 

because of tree damage, 

social trails and loss of 

woody debris. 

Long-term, minor, 

beneficial impacts to 

natural resources due to 

concentration of visitor 

impacts in campgrounds 

with fire rings and fewer 

illegal fires. Long-term, 

minor adverse impacts 

because of tree damage, 

social trails and loss of 

woody debris. Rotation 

should mitigate some of 

these adverse impacts.

Long-term, minor 

beneficial impacts to 

natural resources due to 

less tree damage, fewer 

social trails and more 

woody debris allowed to 

decompose. Long-term, 

minor, adverse impacts 

due to greater chance of 

illegal fires in sensitive 

habitats.

Cultural Resources Long-term, minor adverse 

impacts from social trails 

created by firewood 

seekers and from 

uncontrolled fires. 

Long-term, minor adverse 

impacts from social trails 

created by firewood 

seekers and from 

uncontrolled fires. 

Long-term, minor 

beneficial impacts from 

fewer social trails created 

by firewood seekers. 

Possible long-term, minor 

adverse impacts from 

increased illegal fires 

Park Operations No expected increases in 

staffing or maintenance 

costs.

Long-term, minor, adverse 

impact to current staff 

workloads from 

assessment, monitoring 

and moving fire rings and 

restoring the sites.

Short-term minor to 

moderate adverse impact 

to work loads from 

removing fire rings, longterm minor beneficial 

impact of less work when 

rings are removed, unless 

the number of illegal fires 

increased. 
Impacts of Alternatives for Fire Towers

214 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

4.2.5 Impacts of Alternatives for Fire Towers in the Wilderness 

Alternative A for Fire Towers: No Action, Maintain the Existing Fire Towers

The details of this alternative are outlined in Chapter 2, p. 87. This alternative would maintain 

the status quo, retaining the park’s three fire towers, all of which are located within designated 

wilderness. Ishpeming and Feldtmann towers would be minimally maintained for visitor and 

staff safety, but would not be generally open to the public. Retaining Isle Royale’s three fire 

towers could have measurable consequences for visitor experiences, wilderness character, natural 

resources, cultural resources, and park operations. Impacts would primarily be related to the 

physical presence of towers, and safety related to their disrepair. Retaining the fire towers would 

not be expected to have any socioeconomic impacts on park-dependent businesses or economies.

Effects on Visitor Experiences

Although all of the fire towers are kept locked at the top, visitors do have the option of climbing 

the stairs of the towers for a view. On a clear day, climbing the Feldtmann Tower or Ojibway 

Tower offers an extensive view of the park and distant mainland. Trees currently block the view 

from the Ishpeming Tower. Retaining all of the fire towers would make this opportunity 

available to visitors on both ends of the island, a beneficial effect of this alternative. 

Effects on Wilderness Character

Isle Royale’s three fire towers are located directly on wilderness trails (see Map 3, Appendix D). 

They are all metal towers ranging in size from 10 to 65 feet (not including the cabin height). As 

such they are unavoidably obvious to hikers in those areas as permanent structures and modern 

artifacts. Originally built for fire monitoring, they no longer serve that purpose, though they do 

serve to house NPS backcountry personnel intermittently for short periods of time. The Ojibway 

Tower additionally serves as an atmospheric monitoring station and communications tower. As 

such these towers may fit under the “administrative uses” exception, which makes some 

permanent facilities permissible under the Wilderness Act. However, the current use of the 

Feldtmann and Ishpeming towers are not considered essential for administration of the park’s 

wilderness and backcountry. Additionally, the visual intrusion of a modern artifact and reminder 

of modern society could be an adverse impact on both wilderness experiences and naturalness. 

The impact would be major in the local vicinity of the towers, but minor to moderate on a parkwide scale where the Ojibway and Feldtmann towers are visible from a great distance. 

 

Effects on Natural Resources

There is no known research on the effects of fire towers on natural resources, so the full 

implications of retaining Isle Royale’s three fire towers are unknown. However, NPS personnel 

have observed some bird mortality from birds hitting the towers. Therefore, retaining the towers 

could have some adverse effects on birds. Any effects on natural resources would be expected to 

be localized and minor. 

Retaining Ojibway Tower as a monitoring and research site for the collection of atmospheric and 

other data is expected to have the long-term beneficial effect of contributing to the state of 

scientific knowledge and better understanding external human influences on the Isle Royale 

ecosystem. Retaining the Feldtmann tower could provide an option to expand atmospheric 
Impacts of Alternatives for Fire Towers

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 215

monitoring to the west end of the island. There could, however, be other options for such 

monitoring that would be outside of wilderness, so the beneficial effect of retaining Feldtmann 

tower for these purposes would be negligible. 

Effects on Cultural Resources

The fire towers at Isle Royale are not considered historic structures and are not part of any 

cultural landscape. Retaining one or more of the towers would represent a part of the history of 

Isle Royale and removing all three towers may have a long-term minor adverse impact to cultural 

resources. There are no predicted impacts to cultural resources from the maintenance of the 

Ojibway, Ishpeming and Feldtmann fire towers. 

Effects on Park Operations

Retaining all three fire towers in the park would eventually require maintenance to prevent 

deterioration of the towers to the point of becoming a safety hazard. This would have a longterm minor adverse effect on NPS operations. Were significant repairs needed there could be 

moderate short-term adverse effects on NPS operations. 

Retaining all three towers could have a beneficial effect on park operations if a future need arose 

that could utilize these structures for administrative needs, such as environmental monitoring 

stations, or telecommunications equipment. 

Conclusion

Retaining all three of Isle Royale’s fire towers would be expected to have both adverse and 

beneficial effects on the park’s resources and values. 

Unavoidable Adverse Impacts

The adverse impact of the visual intrusion of prominent human-made structures in wilderness us 

the only anticipated unavoidable significant adverse impact of retaining all three of Isle Royale’s 

fire towers. 

Alternative B for Fire Towers: Remove Ishpeming and Feldtmann Towers and Maintain 

Ojibway Tower

The details of this alternative are outlined in Chapter 2, p. 87-88. Changes that could occur 

under this alternative that may have measurable environmental consequences include:

• Remove the Ishpeming and Feldtmann fire towers.

• Retain the Ojibway tower as an example of the island’s cultural history, and for 

communications and research and monitoring equipment.

Removing 2 of Isle Royale’s 3 fire towers, Ishpeming and Feldtmann, could have measurable 

consequences for visitor experiences, wilderness character, natural resources, cultural resources, 

socioecomonics, and park operations. Impacts would primarily be related to the physical 

presence or absence of the towers, and the logistics and cost of removing two towers. There 

would be no anticipated effect on visitor use levels.
Impacts of Alternatives for Fire Towers

216 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Effects on Visitor Experiences

This alternative would be expected to have both beneficial and adverse effects on visitor 

experiences, depending on the visitor’s perspective. Removing the Ishpeming and Feldtmann 

towers would eliminate the opportunity for visitors to climb those towers. Although both towers 

are kept locked at the top, visitors currently have the option of climbing most of the way to the 

top. On a clear day climbing the Feldtmann tower offers an extensive view of the park and 

distant mainland. Trees currently block the view from the Ishpeming Tower. The loss of this 

opportunity may be an adverse effect for some visitors, but people would still have this 

opportunity with the Ojibway Tower. Other visitors may see this as a positive change, reducing 

the signs of human impact on the park’s landscape. 

Effects on Wilderness Character

Removing Ishpeming and Feldtmann fire towers would have a moderate long-term beneficial 

effect on the wilderness character of the park. These two fire towers are permanent human 

improvements that no longer serve an essential administrative purpose that could not be met by 

more minimal means. The towers are both situated directly on trails, clearly visible to hikers in 

fairly remote areas of the park. The Feldtmann tower stands well above tree line and is visible 

from a great distance, adversely impacting the naturalness of the park’s view shed. The 

Ishpeming tower no longer stands above tree line, so its removal would have a negligible effect 

on naturalness of the park’s view shed.

Were helicopter support necessary to remove the towers, the noise and visual intrusion would 

have a short-term moderate adverse effect on wilderness experiences and naturalness. However, 

the adverse impacts associated with removal would be short-term, while the adverse impacts 

associated with maintaining all three towers would be long-term. 

Effects on Natural Resources

There is not any known research on the effects of fire towers on natural resources, so the full

implications of removing Feldtmann and Ishpeming towers are unknown. However, NPS 

personnel have observed some bird mortality from birds hitting the towers. Therefore, removing 

two towers could have a beneficial effect on birds. Any long-term effects on natural resources 

would be expected to be localized and minor. 

The process of removing Feldtmann and Ishpeming towers would be expected to have a shortterm adverse effect on natural resources. Helicopter support and a substantial demolition ground 

crew would be required. The trampling, noise, and human presence associated with this effort 

would be expected to have a localized, short-term minor to moderate adverse effect. 

Retaining Ojibway Tower as a monitoring and research site for the collection of atmospheric and 

other data is expected to have the long-term beneficial effect of contributing to the state of 

scientific knowledge and better understanding external human influences on the Isle Royale 

ecosystem. Retaining the Feldtmann tower could provide an option to expand atmospheric 

monitoring to the west end of the island. There could, however, be other options for such 

monitoring that would be outside of wilderness, so the adverse effect of removing Feldtmann 

tower and losing the option to use it for scientific studies in the future would be negligible. 
Impacts of Alternatives for Fire Towers

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 217

Effects on Cultural Resources

The fire towers at Isle Royale have not been in place long enough to be considered historic 

structures and are not part of any cultural landscape. However, they do represent an era of NPS 

management, and are of interest to some visitors. Retaining the Ojibway Tower would maintain 

one example from this era within the park. There are no predicted impacts to cultural resources 

from the maintenance or removal of the Ishpeming and Feldtmann fire towers. The Ojibway fire 

tower would be maintained and would preserve the history of the important role fire towers 

played in the fire suppression efforts at Isle Royale.

Socioeconomic Effects

If the work required to remove the Ishpeming and Feldtmann Towers were contracted out with 

local workers or a local business, then this alternative could have a beneficial effect on the 

socioeconomics of the local communities. The contracted jobs would be expected to pay higher 

salaries than the typical tourism jobs in the local communities, but these jobs would be shortterm. No long–term effects on the local economies would be expected. 

Effects on Park Operations

Removing two fire towers from Isle Royale’s wilderness would be expected to have a short-term 

major adverse effect on NPS operations. Removal would require contracting for helicopter 

assistance as well as significant labor time and the cost is expected to exceed to $100,000. 

Removal would also have a long-term minor beneficial effect of reducing maintenance 

workloads. This alternative is not expected to result in a change in park personnel. 

Conclusion

Removing two of Isle Royale’s three fire towers would be expected to have short-term adverse 

impacts and long-term beneficial impacts on the park’s wilderness character and natural 

resources. Similarly, there would be major short-term adverse effects and long-term beneficial 

effects on park operations. There could be both adverse and beneficial effects on visitor 

experiences. 

Unavoidable Adverse Impacts

No unavoidable significant adverse impacts to the park’s natural, cultural, or wilderness 

resources or visitor opportunities are expected with this alternative.
Impacts of Alternatives for Fire Towers

218 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Table 22: Comparison of Environmental Consequences for Alternatives for Fire Towers

Alt A: No Action Alt. B: Preferred Alternative

Proposed Changes • Fire Towers would be retained at 

all three present locations

• Only minor maintenance would 

be preformed to Feldtmann and 

Ishpeming Towers

• The Feldtmann and Ishpeming Fire 

Towers would be removed

• The Ojibway Tower would be retained 

for administrative uses

Visitor Use and 

Experiences

Long-term, minor beneficial impact to 

visitor experience from the continued 

availability of views from the 

Feldtmann Tower. 

Long-term, minor adverse impact to 

visitor experience from the loss of views 

from the Feldtmann Tower. 

Wilderness Long-term major adverse impact to 

wilderness and naturalness in the 

vicinity of the Feldtmann and 

Ishpeming Towers. Long-term minor 

adverse impact in other areas of the 

park where the Feldtmann Tower is 

visible.

Long-term major beneficial impact to 

wilderness and naturalness in the vicinity 

of the Feldtmann and Ishpeming Towers. 

Long-term minor beneficial impact to 

other areas where the Feldtmann Tower is 

visible

Natural Resources Long-term minor, localized, adverse 

effects on natural resources in the area 

of the Feldtmann and Ishpeming 

Towers.

Long-term minor, localized, beneficial 

effects on natural resources in the area of 

the Feldtmann and Ishpeming Towers.

Cultural Resources Long-term, minor, beneficial impacts 

from the retention of the Feldtmann 

and Ishpeming Fire Towers. 

Long-term, minor, adverse impacts from 

the removal of the Feldtmann and 

Ishpeming Fire Towers. Ojibway Tower 

would remain as an example of fire 

towers in island history

Park Operations Long-term, minor adverse impacts to 

park operations due to limited 

maintenance of Feldtmann and 

Ishpeming Towers. Possible shortterm major adverse impact if 

significant repairs were necessary.

Short-term, major adverse impact to park 

operations due to the removal of two fire 

towers from the Park. Long-term, minor 

beneficial impact from lower 

maintenance costs.

4.2.6 Consequences of Alternatives for Picnic Tables in Wilderness Campgrounds

Alternative A for Picnic Tables: No Action

The details of this alternative are outlined in Chapter 2, p. 89. No changes would be made from 

the current conditions. Isle Royale managers would be unable to reach their management goals 

of complying fully with NPS policies for wilderness, continuing to retain and maintain picnic 

tables within some of the park’s wilderness campgrounds:

• Picnic tables would be retained at all Lake Superior campgrounds with docks; Rock 

Harbor, Daisy Farm, Moskey Basin, Chippewa Harbor, Malone Bay, Hay Bay, Grace 

Island, Beaver Island, Washington Creek, Todd Harbor, McCargoe Cove, Birch Island, 

Belle Isle. 

Maintaining picnic tables at wilderness campgrounds could have measurable consequences for 

wilderness character, natural resources, cultural resources, and park operations. Impacts would 
Impacts of the Alternatives for Picnic Tables

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 219

primarily be related to the amenity of picnic tables and a means of concentrating impacts in 

campgrounds. There would be no anticipated effect on visitor numbers or the socioeconomics of 

park-dependent businesses or economies.

Effects on Visitor Use and Experience

The overall effect of picnic tables in the wilderness on visitors as a whole would be minor, longterm, and positive or negative, based on individual preference. Some visitors appreciate the 

convenience of having a stable, elevated surface for cooking, eating, and socializing. Some 

visitors, however, do not want to see human-made structures in the wilderness, and consider 

these structures an intrusion on their wilderness experience.

Effects on Wilderness Character

The NPS has clearly determined that picnic tables are incompatible in wilderness. This 

determination is consistent with other wilderness areas, as well. Picnic tables provide a human 

amenity and are a modern artifact that detracts from the wilderness character of an area. 

This adverse effect would be moderate and localized to campsites with tables, but it would also 

be reversible with the removal of the picnic tables. 

Effects on Natural Resources

Farrel and Marion (1998) found that campsites on Isle Royale with picnic tables were 

significantly smaller in area of disturbance than those without tables. The size, area of 

vegetation loss, and exposed soil for sites with picnic tables were consistently between 100-250 

ft2 smaller than comparable sites without picnic tables. For example, in 1996 the mean size of 

individual campsites with picnic tables was 549 ft2, compared to 717 ft2 for sites without picnic 

tables. In 2002 the mean size of individual sites with picnic tables was 581 ft2, compared to 831 

ft2 for sites without picnic tables. The presence of picnic tables in campsites appears to 

concentrate physical impacts such as vegetation loss, soil exposure, and total area of a campsite. 

This suggests that picnic tables are effective tools for concentrating physical impacts in 

campsites. As a result, retaining tables in wilderness campsites where they are currently found 

would have beneficial effects on natural resources. These effects would be long-term and minor 

to moderate. 

Effects on Cultural Resources

Picnic tables help to concentrate use. Retaining the picnic tables might help limit impacts to 

archeological resources located near campgrounds. Historic structures and cultural landscapes 

located near GMP campgrounds might have less possibility of minor negative impacts resulting 

from spreading of use and from the use of historic structures in place of picnic tables. The 

retention of picnic tables is not predicted to impact cultural objects or the museum collection. 

The park inventory of ethnographic resources is ongoing, the park staff is not currently aware of 

any impacted ethnographic resources. 

Effects on Park Operations

Continuing the current management direction for picnic tables at Isle Royale would mean failing 

to achieve the management goal of complying with NPS policy for wilderness management. 

Maintaining picnic tables would require more NPS staff time over the long-term than removing 
Impacts of Alternatives for Picnic Tables

220 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

picnic tables. However, this would be a minor effect on staffing and costs to the NPS as no 

additional staffing would be required. 

Conclusion

Retaining picnic tables in some wilderness campgrounds would be expected to have some 

adverse effects associated with modern conveniences in wilderness, and beneficial effects 

associated with effectively concentrating human impacts. However, under this alternative, Isle 

Royale managers would continue to fail to comply with NPS policies for wilderness. 

Unavoidable Adverse Impacts

Retaining picnic tables would have an unavoidable adverse impact on wilderness character. 

Picnic tables provide a human amenity and are a modern artifact that detracts from the 

wilderness character of an area, and Park Service Wilderness Policy has consistently supported 

minimizing such intrusions. 

Alternative B for Picnic Tables: Comply with NPS Policy and Remove all Picnic Tables 

from Wilderness Campgrounds

The details of this alternative are outlined in Chapter 2, p. 89-90. Changes that could occur 

under this alternative that may have measurable environmental consequences include:

• All picnic tables would be removed from a total of 33 campsites and shelters in the 

following campgrounds within designated or potential wilderness: Caribou Island, 

Chippewa Harbor, Hay Bay, Grace Island, Beaver Island, Todd Harbor, Birch Island, 

Duncan Bay, Duncan Narrows, Merritt Lane, and Tookers Island. The tables would also 

be removed from the picnic area at Hidden Lake. 

• Picnic tables would be retained at campgrounds in non-wilderness; Rock Harbor, Three 

Mile, Daisy Farm, Moskey Basin, Malone Bay, Siskiwit Bay (only until the dock is 

removed), Washington Creek, McCargoe Cove, and Belle Isle.

• Isle Royale would then be in compliance with NPS wilderness policy.

Removing picnic tables from these campgrounds could have measurable consequences for 

wilderness character, natural resources, cultural resources, visitor experiences, and park 

operations. Impacts would primarily be related to the physical presence of picnic tables as well 

as the associated concentration of resource impacts. There would be no anticipated effect on 

visitor use levels or the socioeconomics of park-dependent businesses or economies.

Effects on Visitor Use and Experience

As with Alternative A, the effects on visitors of removing picnic tables would be long-term, 

minor, and either positive or negative, depending on personal opinions. Some visitors would 

view it as a positive action that restores a more natural setting to campgrounds, with fewer 

reminders of human interference in the wilderness. Some visitors would also believe that since it 

is against NPS policy to have these structures in the wilderness, that they should not be present. 

On the other hand, some visitors may miss the convenience of having an elevated surface for 
Impacts of the Alternatives for Picnic Tables

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 221

eating and socializing. Still others may be disturbed if there is evidence that natural resource 

damage has increased at a campground where picnic tables have been removed.

Effects on Wilderness Character

Removing picnic tables from wilderness campsites would have a long-term beneficial effect on 

wilderness character in these areas. Picnic tables are modern human structures that serve as an 

amenity for camping and picnicking convenience, in contrast to a primitive atmosphere that is 

appropriate for wilderness. NPS policy clearly states that only facilities that are determined to be 

the minimum necessary for the health and safety of wilderness users, or for the preservation of 

wilderness resources and values are appropriate. This policy further states, “picnic tables will 

not be allowed in wilderness” (NPS 2006 §6.3.10.3). This alternative would bring Isle Royale 

into compliance with NPS policy.

Effects on Natural Resources

As outlined above under Alternative A for picnic tables, the presence of picnic tables in 

campsites appears to concentrate physical impacts such as vegetation loss, soil exposure, and 

total area of a campsite. Removing picnic tables from campsites could have an adverse effect on 

natural resources. Research on Isle Royale suggests that picnic tables are effective tools for 

concentrating biophysical impacts in campsites. Therefore removing the tables would be 

expected to have the adverse effect of increasing the area of vegetation loss and exposed soil as 

well as the total area of campsites where picnic tables would be removed. 

Effects on Cultural Resources

Picnic tables help to concentrate use and impacts in campsites (Farrell and Marion 1998). If 

picnic tables were removed, use might spread and could damage archeological resources near 

campgrounds. Historic structures are located near GMP-proposed new campgrounds at Crystal 

Cove, John’s Island, Fisherman’s Home and Wright Island, all within wilderness or potential 

wilderness. These campgrounds would have their picnic tables removed or they would not be 

added under this alternative. Without picnic tables, people might sit on the historic structures or 

use them as tables. Because picnic tables concentrate use, the removal of the tables might have 

some adverse impact on the cultural landscapes associated with trampling, loss of duff, and 

exposure of soil, all of which could expose or damage hidden and buried cultural objects. The 

severity of this impact would depend on the significance and integrity of the damaged resource. 

The park inventory of ethnographic resources is ongoing, the park staff is not currently aware of 

any impacted ethnographic resources. 

Effects on Park Operations

Removing picnic tables would have a short-term adverse effect, increasing workloads to remove 

all picnic tables from wilderness campsites. The effect would be minor as it would not be 

expected to require an increase in staffing, but would add to the workloads of existing staff. 

Over the long-term removing picnic tables would have the beneficial effect of reducing the work 

associated with maintaining picnic tables by reducing the number of picnic tables in the park. 

Picnic tables within non-wilderness campgrounds would still be maintained. 
Impacts of Alternatives for Picnic Tables

222 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Conclusion

Removing picnic tables from wilderness campgrounds would be expected to have both beneficial 

and adverse effects on park resources and values. 

Unavoidable Adverse Impacts

Removing picnic tables would be expected to have unavoidable adverse impacts on natural and 

cultural resources. Picnic tables have been shown to concentrate trampling, and without them it 

is likely that damage to vegetation and soils would increase in severity and extent within 

campsites. 

Alternative C for Picnic Tables: Seek a Waiver to Retain Picnic Tables in Some Wilderness 

Campgrounds (the Preferred Alternative)

The details of this alternative are outlined in Chapter 2, p. 91. Changes that could occur under 

this alternative that may have measurable environmental consequences include:

• Picnic tables would be retained at all Lake Superior campgrounds with docks; Rock 

Harbor, Daisy Farm, Moskey Basin, Chippewa Harbor, Malone Bay, Hay Bay, Grace 

Island, Beaver Island, Washington Creek, Todd Harbor, McCargoe Cove, Birch Island, 

Belle Isle, and could be added to the new GMP-approved campgrounds. 

Maintaining picnic tables at wilderness campgrounds could have measurable consequences for 

wilderness character, natural resources, cultural resources, and park operations. Impacts would 

primarily be related to the aesthetic of picnic tables and associated means of concentrating 

impacts in campgrounds. There would be no anticipated effect on visitor numbers or the 

socioeconomics of park-dependent businesses or economies.

Effects on Visitor Use and Experience

The effects of this alternative on visitors would be the same as under Alternative A, with the 

possible exception that those visitors knowledgeable about NPS policy may also appreciate that 

Isle Royale would be technically in compliance with a waiver in place. Overall, the effects 

would be long-term, minor, and positive or negative, depending on personal preference.

Effects on Wilderness Character

The NPS has clearly determined that picnic tables are incompatible in wilderness. This 

determination is consistent with other wilderness areas, as well. Picnic tables provide a human 

amenity and are a modern artifact that detracts from the wilderness character of an area. 

Although receiving a waiver from the NPS to retain picnic tables within Isle Royale’s wilderness 

would bring the park into compliance with NPS policy, it would still be considered an adverse 

effect on wilderness character. This adverse effect would be moderate and localized to 

campsites with tables, but it would also be reversible with the removal of the picnic tables. 

Effects on Natural Resources

As outlined above under Alternative A for picnic tables, the presence of picnic tables in 

campsites appears to concentrate physical impacts such as vegetation loss, soil exposure, and 
Impacts of the Alternatives for Picnic Tables

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 223

total area of a campsite. As a result, retaining tables in wilderness campsites where they are 

currently found would have beneficial effects on natural resources relative to removing tables as 

proposed in Alternative A. These effects would be long-term and minor to moderate. 

Effects on Cultural Resources

Picnic tables help to concentrate use. Retaining the picnic tables might help limit impacts to 

archeological resources located near campgrounds. Historic structures and cultural landscapes 

located near GMP campgrounds might have less possibility of minor negative impacts resulting 

from spreading of use and from the use of historic structures in place of picnic tables. The 

retention of picnic tables is not predicted to impact cultural objects or the museum collection. 

The park inventory of ethnographic resources is ongoing, the park staff is not currently aware of 

any impacted ethnographic resources. 

Effects on Park Operations

Maintaining picnic tables would require more NPS staff time over the long-term than removing 

picnic tables. However, this would be a minor effect on staffing and costs to the NPS as no 

additional staffing would be required. 

Conclusion

Retaining picnic tables in some wilderness campgrounds would be expected to have some 

adverse effects associated with modern conveniences in wilderness, and beneficial effects 

associated with effectively concentrating human impacts. 

Unavoidable Adverse Impacts

In campsites where picnic tables were retained there would be an unavoidable adverse impact on 

wilderness character. Picnic tables provide a human amenity and are a modern artifact that 

detracts from the wilderness character of an area, and National Park Service Wilderness Policy 

has consistently supported minimizing such intrusions. In campsites where picnic tables were 

removed there would be an adverse impact to natural and cultural resources through increased 

tramping of vegetation and soils. 
Impacts of Alternatives for Picnic Tables

224 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Table 23: Comparison of Environmental Consequences for Picnic Table Alternatives 

Alt A: No Action Alt B Alt C: Preferred

Proposed Changes • Picnic Tables would 

remain in wilderness in 

violation of NPS 

policy

• Picnic Tables would be 

removed from all 

campgrounds within 

designated wilderness

• Request a waiver to 

maintain picnic tables 

within wilderness 

campgrounds

Visitor Use and 

Experiences

Long-term minor

beneficial or adverse 

impact to visitor 

experience, based on 

personal preference, due to 

the retention of this 

modern convenience. 

Long-term minor 

beneficial or adverse 

impact to visitor 

experience, depending on 

personal preference, due to

the removal of this 

convenience. 

Long-term minor

beneficial or adverse 

impact to visitor 

experience, depending on 

personal preference, due to 

the retention of this 

modern convenience.

Wilderness Long-term moderate 

adverse impact on 

wilderness character due 

to the retention of these 

modern artifacts. Impact is 

reversible with the 

removal of tables. 

Long-term minor 

beneficial impact on 

wilderness character due 

to the removal of this 

modern convenience

Long-term moderate 

adverse impact on 

wilderness character due 

to the retention of these 

modern artifacts. Impact is 

reversible with the 

removal of tables. 

Natural Resources Long-term, minor to 

moderate beneficial impact 

to natural resources due to 

the concentration of 

impacts in campgrounds 

with picnic tables

Long-term, minor adverse 

impact to natural resources 

due to the removal of 

picnic tables which tend to 

concentrate impacts 

Long-term, minor to 

moderate beneficial impact 

to natural resources due to 

the concentration of 

impacts in campgrounds 

with picnic tables

Cultural Resources Long-term, minor 

beneficial impact to 

cultural resources due to 

the concentration of 

impacts in campgrounds 

with picnic tables.

Long-term, minor adverse 

impact to cultural 

resources due to the 

removal of picnic tables 

which tend to concentrate 

impacts.

Long-term, minor 

beneficial impact to 

cultural resources due to 

the concentration of 

impacts in campgrounds 

with picnic tables.

Park Operations Short-term, minor 

beneficial impact of not 

having to remove the 

picnic tables. Long-term, 

minor adverse impact of 

maintenance costs 

associated with tables.

Short-term, adverse impact 

from the increased 

workload associated with 

removing the picnic tables. 

Long-term, beneficial 

impact as picnic tables 

would not be maintained.

Short-term, minor 

beneficial impact of not 

having to remove the 

picnic tables. Long-term, 

minor adverse impact of 

maintenance costs 

associated with tables.
Impacts of the Combined Alternatives

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 225

4.3 Cumulative and Combined Effects of the Proposed Alternatives

4.3.1 Cumulative Impacts

Cumulative impacts, according to CEQ Regulations §1508.7, “result from the incremental 

impact of the action when added to other past, present, and reasonably foreseeable future actions 

regardless of what agency (federal or non-federal) or person undertakes such actions.” These are 

actions that may be minor on their own, but taken collectively would be significant over a period 

of time. Analysis determined that there would be no reasonably foreseeable cumulative impacts 

from any of the actions proposed in this WBMP, for several reasons:

• Isle Royale National Park has no bordering lands, and the Lake Superior resources that 

do overlap with the jurisdiction of other state or federal agencies are beyond the scope of 

this plan. 

• Nothing proposed in any of the alternatives in this WBMP is reasonably expected to 

result in the loss of significant regional resources or public services.

• None of the alternatives proposes significant new developments or new infrastructure, 

when compared to current baseline conditions.

• Changes in tourism in the mainland communities are not reasonably expected to affect 

visitation to the park, due to the logistics and planning required for visiting Isle Royale. 

Additionally, none of the alternatives are reasonably expected to affect tourism in the 

mainland communities or to cumulatively produce any impacts when combined with 

tourism initiatives at port cities. 

• Isle Royale’s resources are geographically isolated; therefore terrestrial management 

practices on the mainland do not impact terrestrial resources on Isle Royale.

• An overriding focus of managing Isle Royale is protecting wilderness, natural, and 

cultural resources, and 99% of the park’s land base is designated wilderness. Therefore, 

any reasonably foreseeable management actions within the park would not reasonably be 

expected to result in cumulative adverse impacts when combined with the outcome of 

this plan. 

Therefore it was determined that no past, ongoing, or reasonably foreseeable future actions by 

others would, in combination with the impacts described in this chapter, result in cumulative 

impacts on wilderness character, natural resources, cultural resources, visitor experiences, 

socioeconomics, or NPS operations when viewing Isle Royale in a larger regional context. 

However, the proposed actions taken in combination could result in impacts within the park that 

are more significant than each action taken individually. The range of possible effects of the 

proposed actions in combination is discussed in the next section.

4.3.2 Combined Effects

Combining alternatives that propose the highest degree of development or the greatest change in 

visitation, for example, could result in impacts within the park that would be greater than when 

the actions are taken individually. Therefore, the combined effects of those alternatives that 

could result in the greatest increase in development, the greatest decrease in development, and 

the greatest likely change in visitation were assessed. Similarly, all of the preferred alternatives 

were assessed for their combined impacts. 
Impacts of the Combined Alternatives

226 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Highest Development Combination of Alternatives

If combined, Alternative C for overnight use, Alternative C for day use, Alternative B for 

campfires, Alternative A for fire towers, and Alternative B for picnic tables would, together, 

result in actions with the greatest possibility of development in the park’s wilderness and 

backcountry. The combination would result in the following:

• Some existing campgrounds could be expanded by adding a few communal campsites or 

additional individual campsites (Table 8, p.104 outlines feasible campground 

expansions).

• Up to three new campgrounds could be added in the park’s wilderness, including within 

the Pristine Zone (Appendix D, Map 3).

• A shuttle service would be created in the Rock Harbor Channel with service to Rock 

Harbor, Mott Island, and Daisy Farm.

• A new Backcountry Office would be established (on the mainland, this would not add to 

development in the wilderness and backcountry).

• A new trail would be created within the Pristine Zone adjacent to Windigo, intended as a 

loop hike for day visitors (Appendix D, Map 5).

• New fire rings would be added to campgrounds on a rotational basis.

• Three fire towers would be maintained in the park’s wilderness.

• Existing picnic tables would be maintained in some wilderness campgrounds.

The combination of all of these actions and new developments would be expected to impact park 

resources and values to a greater extent than each of these actions taken individually and result in 

a greater increase in development than any other combination of alternatives in this plan. 

Increasing trails and campgrounds in the park, combined with the effects of adding a shuttle 

service, and retaining picnic tables and fire towers would be expected to have a moderate longterm adverse effect on wilderness character. The extent of modern artifacts and conveniences 

would expand, as would the cumulative footprint of development in the wilderness. Access to 

some remote areas of the park would be easier, which could adversely affect the feel of solitude 

and isolation. Additionally, these adverse effects, in combination, would be more widespread 

throughout the park than the localized impacts of individual actions.

The increased cumulative footprint of development in the park would increase the likelihood of 

adverse impacts to both natural and cultural resources associated with ground disturbance. There 

would also be greater impact to species that are sensitive to human presence. Rotating campfire 

rings may add to these adverse effects. The addition of a new trail and new campgrounds would 

add to habitat fragmentation in the park, likely result in increased establishment of social trails, 

and shrink the areas where wildlife may be undisturbed by human presence. All of these impacts 

would be adverse, minor to moderate, and long-term.

These alternatives, in combination, could allow for a substantial increase in annual visitation 

throughout the season. However, ferry capacities would continue to limit increases in camping 

parties as well as day visitors and lodge guests during the busiest times. Options for some 

visitors would increase, with a new trail for day hikes in the Windigo area, and more 

campgrounds within easy reach for campers beginning their trips in Rock Harbor. Options for 
Impacts of the Combined Alternatives

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 227

visitors seeking solitude and isolation may decrease. These impacts would be minor, long-term 

and beneficial or adverse, depending on a visitor’s priorities for access and solitude.

The combined increase in maintenance workload associated with maintaining campgrounds, 

trails, and backcountry facilities would be expected to be moderate and long-term. Taken 

individually, none of these actions would be expected to require an increase in personnel. 

However, implementing all of these changes in combination would likely require an increase in 

personnel or contracted services for both short-term implementation and long-term maintenance. 

Establishing a Backcountry Office would require an initial start-up investment of funding and 

staff time. There may also be an associated minor increase in park staffing required. However, 

over the long-term this Backcountry Office would be expected to improve park operations by 

improving staff efficiency, communication regarding recreation management in the park, visitor 

services and information dissemination, management of the permitting system, and monitoring 

backcountry conditions. 

 

Lowest Development Combination of Alternatives

Implementing the combination of Alternative E for overnight use, Alternative B for day use, 

Alternative C for campfires, Alternative B for fire towers, and Alternative A for picnic tables 

would result in the greatest decrease in development in the park. This combination of 

alternatives would also have the greatest likelihood of resulting in either no increase in visitation, 

or possibly reduced visitation to the park’s wilderness and backcountry. The actions proposed in 

these alternatives that would result in the decreased development in the Park’s wilderness and 

backcountry are:

• No new campgrounds would be added (other than the GMP-approved campgrounds).

• One campsite would be removed (from Little Todd).

• No new trails would be added.

• A new Backcountry Office would be created (on the mainland, this would not add to 

development in the wilderness and backcountry).

• All fire rings would be removed and campfires would be banned in the wilderness and 

backcountry.

• Ishpeming and Feldtmann fire towers would be removed.

• Picnic tables would be removed from campgrounds within wilderness and potential 

wilderness.

The actions proposed in these alternatives that could result in decreased visitation to the 

wilderness and backcountry are:

• The number of backcountry permits issued would not exceed campsite availability, while 

the camping capacity of the park would decrease by one campsite.

• Historic low visitation would be maintained in Spring and Fall.

• Day tour sizes would be limited to small groups in much of the wilderness and 

backcountry. 

The combination of all of these actions and changes in park services would be expected to 

impact park resources and values to a greater extent than each of these actions taken individually. 

However, this particular combination of alternatives demonstrates the greatest reduction in 
Impacts of the Combined Alternatives

228 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

development of all possible combinations of alternatives in this plan. It also demonstrates the 

greatest possible limitation on visitation.

The combination of removing one campsite from Little Todd, banning campfires, removing 2 

fire towers, removing picnic tables from wilderness campgrounds, and making a commitment to 

not add any new campsites, campgrounds (beyond those approved in the GMP), or trails would 

be expected to have a positive long-term effect on wilderness character. Preventing an increase 

in development and associated impacts within the park’s wilderness would be beneficial for both 

naturalness and wilderness experiences park-wide. 

Curtailing development in the wilderness and backcountry would similarly have a moderate 

long-term beneficial effect on natural and cultural resources. Not adding new trails or 

campgrounds would prevent the adverse impacts associated with ground disturbance and human 

activities. Reducing overcrowding in campgrounds at the same time as reducing the size of tour 

groups in day use areas would be expected to result in minor to moderate long-term beneficial 

impacts on these resources. Trampling associated with crowding in campgrounds and along 

trails that damages both natural and cultural resources would be reduced, as would noise that 

may displace wildlife. However, removing picnic tables would be expected to result in an 

increased area of trampling in campsites, as research has shown that picnic tables effectively 

concentrate human use and impacts in campsites (Farrell and Marion 1998).

Although these combined actions could have beneficial effects on wilderness character and park 

resources, they could result in moderate long-term adverse impacts to visitors. Reducing 

overcrowding in campgrounds could result in lower backcountry visitation with fewer people 

able to get camping permits during the busy use times. Maintaining historic low use times in 

spring and fall would limit the options for people who were not able to get a permit in the busy 

times to come at a different time. Additionally, limiting the size of tour groups below the current 

average tour sizes would be expected to reduce access to day activities. Limits on backcountry 

parties under the new permitting system could allow for more space on ferries for lodge guests 

and day visitors, but limiting access to organized day activities may discourage these visitors. 

All of these actions in combination could effectively reduce visitation in the park, or at least 

prevent any future increases in visitation. This could have a moderate long-term adverse effect 

on public access to the park. Long-term impacts to visitor opportunities within the park’s

wilderness and backcountry could be positive or negative, depending on a visitor’s priorities for 

access or solitude. 

Reducing the infrastructure within the park’s wilderness and backcountry would initially have a 

short-term major adverse impact on park operations, with the substantial cost of removing 2 fire 

towers combined with removing fire rings, picnic tables, and one campsite. Over the long term, 

this reduction in facilities would be expected to have a minor beneficial effect on park 

operations. The substantial cost of removing facilities would be compounded by the moderate 

cost of creating and staffing a mainland Backcountry Office.
Impacts of the Combined Alternatives

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 229

Combination of Preferred Alternatives

Implementing all of the preferred alternatives would mean implementing Alternative B for 

overnight use, Alternative C for day use, Alternative B for campfires and Alternative B for 

picnic tables.

The actions in these alternatives that would affect development in the wilderness and 

backcountry are:

• No new campgrounds would be added (other than the GMP-approved campgrounds).

• One new campsite would be added to North Desor.

• A new Backcountry Office would be established (on the mainland; this would not add to 

development in the wilderness and backcountry).

• A new trail would be constructed within the Pristine Zone adjacent to Windigo, intended 

as a loop hike for day visitors (Appendix D, Map 5).

• New fire rings would be added to some campgrounds and removed from others on a 

rotational basis.

• Ishpeming and Feldtmann fire towers would be removed.

• Picnic tables would be maintained in some wilderness campgrounds.

The actions in these alternatives that could affect visitation in the wilderness and backcountry 

are:

• The number of backcountry permits issued would not exceed campsite availability. The 

camping capacity of the park would be expanded by one campsite (at North Desor).

• Historic low visitation would be maintained in the spring, while an increase in Fall 

visitation would be possible.

• Multiple tour guides would be required for large day tours, because these groups would 

be required to split into multiple smaller groups. This may affect the availability of tours.

The combination of all of these actions and new developments would be expected to impact park 

resources and values to a greater extent than each of these actions taken individually. This 

particular combination of alternatives falls between the range of the greatest increase in 

development, and the greatest decrease in development. 

The combination of these alternatives would result in removing some facilities from the park’s 

wilderness while adding others. Two of the park’s fire towers would be removed, picnic tables 

would be retained, fire rings would be retained on a rotational basis, one new trail would be 

created, one new campsite would be added, and there would be a commitment to not add any 

new campgrounds (beyond those approved in the GMP). Overall, these changes, in combination 

with a reduction in campground crowding and the size of day groups, would be expected to have 

a moderate long-term beneficial effect on wilderness character on a park-wide scale. Preserving 

low use times in Spring would further aid in protecting opportunities for greater solitude and 

self-sufficiency than is readily available to visitors during the busier times of the season. 

Adding a new trail near Windigo and implementing a rotational system for campfires could have 

a minor to moderate long-term adverse effect on natural and cultural resources. This could be 

mitigated by resource surveys to identify locations of sensitive resources to avoid impacts and to 

find a means of restoring resources. However, limiting campground expansion to one new 
Impacts of the Combined Alternatives

230 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

campsite at North Desor, not creating additional new campgrounds, reducing overcrowding in 

campgrounds, reducing the number of people at one time at day use destinations, and 

maintaining existing picnic tables in wilderness campgrounds would be expected to have a parkwide moderate long-term beneficial effect on these resources. 

The intent of this alternative would be to accommodate current visitation levels while also 

reducing overcrowding in campgrounds, which would be accomplished by issuing advanced 

permits to better distribute campers to available campsites. However, since permits would not be 

issued over a campground’s capacity, visitation in specific areas of the park, or park-wide, would 

be limited to some extent during the busiest months. Additionally, low use would be preserved 

in Spring, so there would be limited options for visitors to come at different times of the year. 

This could result in a minor reduction in visitation, or more likely limiting the possibility for 

backcountry overnight visitation to increase in the future. This combination of alternatives 

would also allow for large day tours to split into multiple groups in the same area, and would add 

a new trail for day visitors at Windigo. The intent would be to improve visitors’ experiences in 

day use areas while also allowing opportunities for day use to increase. If the new permitting 

system were to limit backcountry overnight visitation, it would be expected that there would be 

more space on ferries for day visitors and lodge guests. With this combination of alternatives 

backcountry overnight visitation may be limited during the peak season, but visitors could better 

be accommodated with organized day trips in the backcountry and wilderness, as long as tour 

organizations were able to supply additional leaders. These impacts would be long-term, minor, 

and positive or negative, depending on visitor preferences. 

Changes in facilities within the park’s wilderness and backcountry would initially have a major 

adverse impact on park operations, with the substantial cost of removing up to two fire towers 

combined with removing and/or relocating fire rings, and creating one new campsite. The major 

cost of removing facilities would be compounded by the moderate cost of creating and staffing a 

mainland Backcountry Office. Over the long term, this change in facilities would be expected to 

have a minor to moderate adverse effect on park operations associated primarily with 

maintenance of fire rings, monitoring resource impacts associated with campfires, and staffing a 

Backcountry Office. However, over the long-term establishing a Backcountry Office would be 

expected to improve park operations by improving staff efficiency, communication regarding 

recreation management in the park, visitor services and information dissemination, management

of the permitting system, and monitoring backcountry conditions.
Impacts of the Combined Alternatives 

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 231

Table 24: Combination of Environmental Effects of all of the Preferred Alternatives

Overnight Use; Alt. B Day Use, Alt C Campfires, Alt. B

Fire Towers,

Alt. B

Picnic Tables, 

Alt. C

Proposed 

Changes

• Implement GMP-proposed new 

campgrounds

• New Backcountry Office

• Advanced Permitting

• Add 1 campsite at North Desor

• Not more than 5% sharing in 

summer

• Maintain histories low use in 

spring

•Group size limits, with 

large groups allowed to 

split up. 

•MV Sandy would carry up 

to 40 passengers total –

split into multiple groups 

at destination

•Explore options for 

adding a new loop trail in 

Windigo

• Campfires would be 

rotated to appropriate 

campgrounds based on 

the fuel availability and 

resource conditions. 

• Resource conditions at 

campgrounds would be 

inventoried prior to 

installing fire rings.

• Resources would be 

monitored for impacts.

•The Feldtmann and 

Ishpeming Fire 

Towers would be 

removed

•The Ojibway Tower 

would be retained for 

administrative uses

•Request a waiver to 

maintain picnic 

tables within 

wilderness 

campgrounds

Visitor Use 

and 

Experiences

Visitation could increase from mid 

June through October. Advanced 

permitting would better distribute 

people to available campsites and 

reduce the frequency of 

overcrowding and give campers a 

greater assurance of finding an 

available campsite and 

opportunities to visit the park 

during low use times would be 

preserved; these are long-term,

moderate beneficial impacts to 

visitor use. Some people may not 

be able to get a permit for their 

preferred itinerary and public 

access may be limited in spring, a 

long-term, minor adverse impact.

Long-term, minor adverse 

impact to visitor access to 

tours and group activities 

due to size limitations. 

Long-term, moderate, 

beneficial impact to quality 

of tours due to smaller 

group sizes. 

Long-term, minor 

beneficial effect for those 

who enjoy campfires. Longterm minor adverse effect 

for those who do not

Long-term, minor 

adverse impact to 

visitor experience from 

the loss of views from 

the Feldtmann Tower. 

Long-term moderate 

beneficial impact to 

visitor experience 

due to the retention 

of this modern 

convenience.
Impacts of the Combined Alternatives

232 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Overnight Use; Alt. B Day Use, Alt C Campfires, Alt. B

Fire Towers,

Alt. B

Picnic Tables, 

Alt. C

Wilderness 

Character

Impacts to wilderness character 

would be long-term, moderate 

and beneficial. Overcrowding 

in campgrounds would be 

reduced. A wide range of 

opportunities for wilderness 

experiences would be 

protected.

Smaller groups are more 

compatible with wilderness 

experiences both for group 

members and others. Minor, 

short-term beneficial 

impacts include less noise, 

crowding and displacement 

of wildlife. Less trampling 

could be a long-term minor 

to moderate impact. 

Long-term, minor, beneficial 

effect for those who see 

campfires as part of wilderness. 

Long-term minor adverse effect 

for those who do not. Longterm, minor adverse effects to 

naturalness.

Long-term, major 

beneficial impact to 

wilderness and 

naturalness in the vicinity 

of the Feldtmann and 

Ishpeming Towers. Longterm minor beneficial 

impact to other areas 

where the Feldtmann 

Tower is visible

Long-term,

moderate adverse 

impact on 

wilderness 

character due to 

the retention of 

these modern 

artifacts. Impact is 

reversible with the 

removal of tables. 

Natural 

Resources

Impacts to natural resources 

would be long-term, moderate 

and beneficial compared to 

current conditions. Reduced 

overcrowding in campgrounds 

would reduce adverse 

biophysical and noise impacts. 

Maintaining low visitation in 

spring would minimize adverse 

impacts to wildlife. Long-term, 

minor, adverse effects include 

adding one new campsite at 

North Desor and allowing an 

increase in fall visitation.

Beneficial impacts to 

wildlife would be localized 

and short-term. Beneficial 

impacts to vegetation and 

soils would be localized and 

could be long-term.

Long-term, minor, beneficial 

impacts to natural resources due 

to concentration of visitor 

impacts in campgrounds with 

fire rings and fewer illegal fires. 

Long-term, minor adverse 

impacts because of tree damage, 

social trails and loss of woody 

debris. Rotation should mitigate 

some of these adverse impacts.

Long-term minor, 

localized, beneficial 

effects on natural 

resources in the area of 

the Feldtmann and 

Ishpeming Towers.

Long-term, minor 

to moderate 

beneficial impact 

to natural resources 

due to the 

concentration of 

impacts in 

campgrounds with 

picnic tables

Cultural 

Resources

Reducing campground 

overcrowding and maintaining 

low visitation in the spring 

would have long-term, minor 

beneficial impacts on cultural 

resources. Adding one new 

campsite at North Desor could 

have adverse effects on 

unknown cultural resources. 

These effects would be longterm and their severity would 

depend on the significance and 

integrity of the affected 

resources.

Cultural objects located 

near the trails would gain a 

minor to moderate 

beneficial impact from the 

smaller groups. Cultural 

landscapes would see a 

minor, short-term,

beneficial impact.

Long-term, minor, adverse 

impacts from social trails 

created by firewood seekers and 

from uncontrolled fires. 

Long-term, minor, 

adverse impacts from the 

removal of the Feldtmann 

and Ishpeming Fire 

Towers. Ojibway Tower 

would remain as an 

example of fire towers in 

island history

Long-term, minor,

beneficial impact 

to cultural 

resources due to 

the concentration 

of impacts in 

campgrounds with 

picnic tables.
Impacts of the Combined Alternatives 

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 233

Overnight Use; Alt. B Day Use, Alt C Campfires, Alt. B

Fire Towers,

Alt. B

Picnic Tables, 

Alt. C

Socioeconomics

Peak season backcountry 

visitation could decrease. If 

this resulted in an increase in 

day use, then this would be 

beneficial for local 

communities as day visitors 

spend more money. Cost per 

visitor could increase if 

permitting fees were 

implemented.

Possible minor, long-term 

adverse impacts if the 

number of day visitors to 

the park decreased based on 

availability of day trips. 

Possible long-term adverse 

impact to organizations 

providing day trips, as 

additional leaders may be 

required.

No anticipated socioeconomic 

effects on local communities or 

visitors.

No anticipated 

socioeconomic effects on 

local communities or 

visitors.

No anticipated 

socioeconomic 

effects on local 

communities or 

visitors.

Park 

Operations

Long-term minor adverse 

impact to park operations. 

Additional staffing required to 

start and run a backcountry 

office. Short-term costs would 

be moderate, long-term costs 

would be minor to moderate. 

Short-term costs of 

constructing a new campsite at 

North Desor would be minor, 

as would long-term costs for 

maintenance.

Possible long-term, minor 

adverse impact to parkwide operations and a 

moderate impact to 

interpretative staff based on 

the need for additional staff 

to provide multiple leaders 

for guided tours 

Long-term, minor, adverse 

impact to current staff 

workloads from assessment, 

monitoring and moving fire 

rings and restoring the sites.

Short-term, major adverse 

impact to park operations 

due to the removal of two 

fire towers from the Park. 

Long-term, minor 

beneficial impact from 

lower maintenance costs.

Short-term, minor 

beneficial impact 

of not having to 

remove the picnic 

tables. Long-term, 

minor adverse 

impact of 

maintenance costs 

associated with 

tables.
The Environmentally Preferred Alternative

234 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

4.4 Other Required Impact Topics

4.4.1 Short-term Uses and Long-Term Productivity

Under all of the alternatives the majority of the park would be protected in a natural state and 

would continue to be used for recreation and resource protection. The National Park Service 

would continue to manage the area under all the alternatives to maintain ecological processes and 

native and biological communities, and to provide for outdoor recreation activities consistent 

with the preservation of natural and cultural resources. Any actions the National Park Service 

takes in the park would be intended to ensure that uses do not adversely affect the productivity of 

the biotic communities. 

4.4.2 Irreversible and Irretrievable Commitment of Resources

Irreversible commitments are those that cannot be reversed, except perhaps in the extreme longterm (e.g., the regrowth of an old-growth forest). Irretrievable commitments are those that are 

lost for a period of time (e.g., if a road is constructed, the vegetative productivity is lost for as 

long as the road remains). There would be no irreversible commitment of resources made under 

any of the proposed alternatives. The alternatives proposing the addition of a new trail in 

Windigo, new campsites or campgrounds, and cabins in Rock Harbor (including the Preferred 

Alternative) would result in the long-term loss of vegetation along the trail corridor and within 

the footprint of campsites and cabins. This loss of vegetation productivity would be reversible 

with restoration of impacted areas if the trail, campsites or cabins were to be removed in the 

future. No actions proposed would result in the consumption of nonrenewable natural resources 

or the use of natural resources that would preclude other uses for a period of time. 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 235

CHAPTER 5: PUBLIC COMMENT AND RESPONSES

National Park Service staff at Isle Royale National Park received responses from over 50

individuals, organizations, and agencies on the Draft Wilderness and Backcountry Management 

Plan and Environmental Impact Statement during the 60 day comment period between October 

21 and December 21, 2005 and the Open House held on December 12, 2005. From these 50 

individuals or entities, 40 provided written comments and 10 attended the Open House. National 

Park Service staff identified 130 comments addressing varying aspects of the plan and 

environmental impact statement. Substantive comments are provided in full in Appendix K, 

page 329 of this document. Comments and their respective responses were organized into 

subject matter categories (see below).

Below is the list of topics and subtopics addressed in this section. Under each of these topics 

individual substantive comments are numbered and responses, immediately following the 

numbered list, address comments jointly. 

5.2.1 Overall Plan and Actions Common to All

A. Monitoring Impacts

B. Research Impacts

C. Park Regulations

D. Wilderness

E. Park Operations

F. Transportation

G. Chainsaws

H. Treated Lumber

I. Historical References

5.2.2 Overnight Alternatives

A. General Permitting

B. Visitor Surveys

C. Overall Plan Content

D. Permitting and Transportation

E. Campgrounds, Shelters

F. Visitation

G. Wilderness Zones

5.2.3 Day Use Alternatives

A. Trails

B. Visitor Groups

5.1 Characterization of Comments Received

5.2 Substantive Comments and Responses
 236 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

5.2.4 Campfires

5.2.5 Fire Towers

5.2.6 Picnic Tables

5.2.1 Overall Plan and Actions Common to All

A. MONITORING IMPACTS

COMMENTS

1. Please explain why the natural and cultural resource indicators proposed in Newsletter 3 

(March of 2001) were not included in the WBMP, especially where there is abundant data to 

support the development of appropriate indicators and standards related to loons and paddler 

impacts on breeding success... Additionally, there is no commitment to quantifiable goals for 

resource conditions committed to in this plan, other than goals for campsite sharing. Without a 

dependable commitment to monitoring or a definition of desired resource conditions (i.e. 

standards for the many indicators to be monitored), one does not have sincere adaptive 

management. The public deserves a commitment of what resource conditions are desired and 

what improvements may be achieved by the various management actions proposed in this plan. 

Without this commitment of desired resource conditions, the WBMP lacks any real depth and 

management commitment... I would request that the final WBMP address interim steps to 

improve conditions where full implementation of each of the many elements of this plan will be 

financially unrealistic for the foreseeable future This plan heavily promotes the idea of adaptive 

management, and lays out an ambitious monitoring plan. However, current budget trends suggest 

park managers will be hard-pressed to maintain current levels of resource monitoring, let alone 

follow-through on the ambitious expansion of monitoring proposed in the plan... The public also 

deserves an explanation of the implications of how management decisions will be made if park 

staff are unable to complete and maintain the desired monitoring program. I would argue that the 

park’s current allocation of staffing resources is woefully inconsistent with a sincere 

commitment to adaptive management. 

2. Page 53 - The NPS acknowledges that canoes have an "adverse effects on the nesting loons 

on Isle Royale". Page 12 - The scope of the plan included adverse human impacts on loons. The 

combination of both credible research of canoe impacts on loons coupled with the scope of the 

plan including impacts on loons compels the NPS to include this loon impact in the management 

alternative as related to canoes. This impact is not discussed in this plan... The environmental 

consequences section does not describe succinctly how the natural resources will be impacted for 

each specific area of the park by each proposed action...

3. Policies: There is no evidence that Park managers are likely to achieve many of their stated 

goals through the policy prescriptions that are offered. Furthermore the secondary and feedback 

effects from the preferred and other Action options may result in counter-intuitive and 

undesirable long-term consequences. These might include further loss of interest in the park, 

decreased availability of transportation services, closing of lodging facilities, lowered Park 

budgets, loss of cultural assets, and more.
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 237

4. There is some mention of monitoring resources and conditions upon implementation of the 

preferred alternative, but that remains vague as to how and what will get done. The monitoring 

component of this plan is critical to knowing whether you are having any success or not, or most 

importantly, how the wilderness resource is faring at the hands of NPS management and visitor 

use. I urge you to commit to pursuing development of a good monitoring plan.

RESPONSE

Resource management decisions are currently made using the best available professional 

knowledge, and research/monitoring results, when available. While the draft WBMP does not 

set forth a quantitative monitoring plan for the Preferred Alternative, it does state that such a plan 

would be developed and implemented as part of the alternative. The Preferred Alternative cannot 

be implemented without the development of an extensive, ongoing monitoring plan and financial 

commitment to implement it. The monitoring plan would be developed if the Preferred 

Alternative is chosen, and prior to implementation of the Preferred Alternative. Funding and 

staffing constraints are severe at Isle Royale, and this is not expected to change in the near 

future, which effectively leaves the park in the No Action phase until such time as funds become 

available for both implementation and monitoring of the components as they are implemented. 

However, we anticipate an increase to park operating funds within the next three to five years 

that is specifically intended to acquire staffing and resources to develop and implement a 

monitoring plan. 

The Preferred Alternative is based on finding a balance between visitor preferences and 

protection of natural and cultural resources at the park. This draft plan was written after 

conducting extensive surveys, soliciting several seasons’ worth of public input, and consulting 

with other national parks that have completed wilderness plans (see Appendix J and References 

sections.) Based on the result of this research, we do not agree with your assertion that our goals 

are not achievable. While any of your predictions for the park’s future could occur, we do not 

believe that the proposed plan would be the cause of them. On-going monitoring will result in 

adaptive changes if projected results are not achieved.

The park is committed to being able to support adaptive management (or show that no 

adaptations/changes are necessary) as a result of sound data gathered both qualitatively and 

quantitatively. The Preferred Alternative depends on feedback from a comprehensive 

monitoring program, therefore the park is committed to developing such a program. We will 

implement components of the Preferred Alternative as funding becomes available for them and 

their respective monitoring components. Implementation of portions of the monitoring plan, will 

be based on impacts and significance of the need for change. Part of the monitoring plan will be 

to establish monitoring priorities and pursue funding accordingly. Different fund sources will 

have their individual priorities established within the overall priorities context. 

We are still committed to developing indicators and standards that adequately address potential 

resource impacts because of changes in management. During the course of developing the draft 

plan and alternatives, the National Park Service Great Lakes Network has been developing an 

inventory and monitoring program to assess the health and trends of natural systems and species 

across the Great Lakes parks. ISRO will incorporate its development of indicators and standards 
 238 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

to be consistent with this larger program, where specific network “vital signs” can inform the 

park’s indicators and standards, or vice versa. We have already developed campground survey 

methods to assess some visitor impacts, and are completing the development of cyclic 

monitoring of cross-country camping impacts. Where species-specific monitoring (such as 

loons) is a good fit as an indicator, we will pursue it. We need additional data analysis regarding 

loon breeding success and dynamic environmental factors other than visitor use (ie, nests on 

Lake Superior shores, and changing water levels or storm events) before we can determine 

whether loons will be an adequate species-specific indicator. However, early indications are that 

loons may be responsive to management of visitor use patterns in some situations (a small 

number of voluntary closures seems to be helping with nest success in certain locations.) 

Regardless of whether loons are incorporated as a wilderness management plan indicator, we are 

mandated by policy to monitor state listed species as we would federally threatened species. We 

have a long-standing loon monitoring program which will continue. Research and monitoring 

will continue to provide population and trend data, and information regarding loons and human 

impacts (including visitors, park staff, and researchers.) 

The Environmental Consequences section of the draft EIS/Plan does in fact describe the 

anticipated consequences of each proposed alternative, to the extent that the research and 

professional knowledge exist to help predict the consequences. See for example pages 193 

(effects in the immediate vicinity of Todd Harbor) and 204 (effects of a new trail near Windigo). 

The plan acknowledges that research in the park indicates that paddlers can have a negative 

impact on loon nest productivity. None of the alternatives has a specific focus on paddlers, and 

none of the alternatives would likely significantly alter paddler numbers or routes. The 

information on loons is included as part of the Affected Environment section, as is a summary of 

all relevant research and background information for wildlife that may potentially be affected by 

how we manage the wilderness. 

B. RESEARCH IMPACTS

COMMENT

The NPS and the moose/wolf researchers may be violating the Wilderness Act on Isle Royale 

since it became a national park. Park planners of the GMP did not discuss the impact of research 

on Isle Royale. The NPS and the moose/wolf researchers have been taking (as far as the public 

knows) all the moose and wolf remains from the wilderness areas of the island for many years 

and using them for their own means. These animal remains are one of the natural and short term 

historic landscapes of the island. Because of these actions, by the NPS and the researchers, 

visitors are denied the opportunity to view the remains of wildlife in the wild. In addition, the 

taking of these artifacts alters the natural resources and landscape as the remains contain 

nutrients for other wildlife and are a part of the natural process of the island. Isle Royale prides 

itself on the moose and wolf relationship and visitors should be allowed to view the remains of 

these magnificent creatures as a part of their wilderness experience on Isle Royale. Suggestions 

to mitigate this violation of the wilderness act may be to: 1) begin to prevent NPS personnel and 

researchers from taking these remains from sites on Isle Royale. Limit the researchers to taking 

only small samples of the remains for scientific research. 2) inform visitors of sites where some 

of these remains are so they can see them if they choose to do so.
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 239

RESPONSE

Research is one of the opportunities provided within national parks, and is a stated purpose for 

Wilderness areas in the Wilderness Act. The National Park Service has a required permit 

procedure for all research that occurs within parks. Research projects at Isle Royale undergo 

review to determine that they are consistent with park regulations and legislative mandates. This 

includes reviewing research projects using the Minimum Tool Process to minimize impacts to 

resources. 

The wolf/moose study does not collect all wolf and moose remains in the park. Approximately 

30% of moose skeletons are found as part of the study, and from each only a few bones, 

necessary for data collection, are removed. Most measurements are completed in situ, without 

significantly disturbing the carcass. The bulk of the moose remains that are found are left where 

they are, for all visitors to discover as part of their own wilderness experiences. Research results 

for this long-term project are available in an annual report that can be accessed at 

http://www.isleroyalewolf.org/. We periodically reassess research goals, protocols, and 

procedures as part of the permit process for long-term research projects. We acknowledge the 

concerns illustrated in the above comment about the wolf/moose study, and will review those 

concerns as part of the reassessment process. 

Isle Royale’s wolf-moose study is unique throughout the world and the results from almost 50 

years of research have informed wildlife managers, ecologists and biologists as they attempted to 

protect and restore an endangered species. In a larger context, the study has revealed significant 

and previously unknown factors in predator-prey ecology, and has been responsible for 

important advances in wildlife research.

C. PARK REGULATIONS

COMMENT

As a general comment: Don't create so many rules that it will be difficult to enforce them 

consistently and equitably, or so many rules that the visitor will have difficulty learning what 

rules apply. 

RESPONSE

The park will continue its efforts to balance the need for some regulations and voluntary 

restrictions while trying not to hinder the visitor’s experience. Existing and new regulations 

regularly receive internal scrutiny in an attempt to be consistent, user-friendly, and to be 

enforceable.

D. WILDERNESS

COMMENTS

1. The Chapter 3, "3.2 Wilderness Character," on page 112, admits to being difficult to measure 

and is a somewhat quasi-religious intangible in its own right. Without getting into "an unseen 

presence capable of refocusing our perception," etc., we can measure sights, sounds, smells, 
 240 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

people, developments and so forth, and can plan for and manage these impacts. The statement, 

"an intention and a commitment to the spirit of an intangible," falls in the same "not measurable" 

realm. We should manage measurable qualities or factors and avoid the intangible. While there is 

a religious dimension to wilderness thinking, management plans should be science-based and the 

basic objectives should address biodiversity, health and sustainability. The 1.3.1 Management 

Goals statement "Wilderness character is a combination of biophysical, experiential, and 

symbolic qualities in an untrammeled and natural state . . ." is esoteric and could be revised. 

Visitors come to parks equipped with their own "state of mind."

2. There is no justification of not expanding wilderness designation to those areas that were 

excluded, but where non-conforming uses are no longer an issue- particularly those places where 

with full implementation of the GMP docks will be removed (Siskiwit Bay and Three Mile), or 

ferry service relocated (McCargoe Cove). In these cases it would be appropriate for the WBMP 

to propose wilderness designation for consistency with the rest of the park. I would also propose 

including Moskey Basin for consistency and no existing non-conforming use. With the changes 

in the GMP and any changes proposed in this WBMP there would be no non-conforming uses 

that would preclude wilderness designation in these areas. 

3. I request a commitment in the Final WBMP that all Potential Wilderness areas where nonconforming uses (e.g. life leases) have ceased be immediately converted to wilderness, per the 

legislation. This includes areas with volunteer agreements that are within the realm of 

appropriate administrative uses for wilderness, such as Fisherman's Home, Wright Island, 

Johnson Island, John's Island, Captain Kid and Crystal Cove. Additionally, upon departure of the 

USCG from Passage Island, that PWA should be converted, as well. If these extended special 

uses are not appropriate for wilderness, then they should cease anyway as PWAs are legally to be 

managed as wilderness.

4. Acquire all inholdings, eliminate all cabins, and manage the park as a pristine wilderness. 

Designate all of Isle Royale National Park as Wilderness... so that we may fully preserve our 

nation’s heritage.

RESPONSE

“Wilderness character” is defined in the Wilderness Act of 1964 (16 USC §1131 et seq.) using 

subjective, qualitative terms in an effort to define the feelings and perceptions that wilderness 

can evoke. It is the “spirit” of the law. The Park agrees that “wilderness character” is not 

definitive in an objective sense. For management purposes, the park commits to and focuses on 

monitoring and managing ecological and aesthetic impacts to the wilderness that are 

quantifiable. Some examples of quantifiable attributes that contribute to or impact “wilderness 

character” would be trail locations, campground locations, establishment (and control) of exotic 

species, and human-caused impacts to wildlife.

In the Actions Common To All Alternatives section, the draft plan states that where nonconforming uses have ceased in Potential Wilderness Areas (PWAs), those PWAs would be 

converted. The nonconforming uses of historic structures needs to be further analysed through 

the historic properties planning process. If a decision is made to keep a non-conforming use then 

the park would take appropriate action at that time to reconcile differences between designations 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 241

and any inconsistencies in authorizing legislation to wilderness legislation and the GMP and 

Wilderness Plan. In the meantime, current inconsistencies were not deemed significant enough 

to impact overall wilderness management on the Island in the absence of historic significance 

evaluation. Future analysis should provide direction based on all relevant law and policy for 

cultural resources with these resources in context with historic features in the great lakes and the 

island. The trade-offs related to these resources and wilderness values will then be evaluated 

through a NEPA document and acted on accordingly. 

Expansion of the wilderness area is beyond the scope of the WBMP. As stated on p.1 of the 

document, the purpose of the WBMP is to describe actions being taken to manage the existing 

wilderness area. There are no more inholdings within Isle Royale.

E. PARK OPERATIONS

COMMENTS

1. The Park has to reduce its own overhead costs. Reduce the number of boats, docks (do not 

create new campsites when you cannot maintain the ones you have now), allow volunteer groups 

to maintain/repair lighthouses, campgrounds, etc.

2. Since so much of the sound violation of wilderness space is from the daily operations of boats 

and equipment at Park Service locations such as Mott Island, Windigo, and Rock Harbor, I think 

the Park needs to take a harder look at what they can do to minimize their impacts. Today, the 

NPS operates more boats and equipment than ever before, yet visitation has not markedly 

increased. Perhaps there are more effective ways to operate on a daily basis. Currently, the Park 

is operated on a “do as I say, not as I do” basis. A minimal impact Park operation should be the 

good example that the visitor follows.

3. On p. 22 and elsewhere this document discusses the fishery of Lake Superior waters. In Sec. 

1.9 on p. 22 of this plan it is stated that the NPS is "striving to sustain the native fishery". If that 

is so why doesn't this document even mention the recent and dangerous recurrence of the 

lamprey eel in Isle Royale waters? Lake trout should be added to fish of concern on p.125. There 

was ample evidence of increased lamprey predation during the recent summer of 2005. Just ask 

the fishing guides at Rock Harbor and other seasoned fishermen such as Dr. Ted Fritche from 

Marshall, MN, who fishes every summer at the eastern end of the island, and Steve, Tom and 

Chris Gale as other regular and long-time fishermen from Tobin Harbor.

RESPONSE

The park continues to look for ways to reduce its overhead costs, and utilizes volunteers 

whenever feasible. The park regularly uses the services of volunteer crews to help maintain the 

trail system, for example. The plan proposes the establishment of one new campsite, as part of 

an overall strategy in the preferred alternative and computerized trip planning to optimize on the 

current camp grounds during peak season to reduce overcrowding. The park’s 1998 General 

Management Plan/Environment Impact Statement Preferred Alternative guides the park’s 

decision-making with respect to new campgrounds, docks, and other facilities. Implementation 
 242 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

of park management plans are in turn affected by available funds. The park does utilize 

volunteers for trail maintenance, and for some repairs on park infrastructure.

We agree with your position on minimizing noise impacts from park operations. For example all 

of our 2-stroke outboard motors were replaced by 4 stroke engines. We continue to seek and 

implement techniques and practices that reduce the “footprint” of the park staff on the park. 

Unfortunately, many innovations require substantial funding to be initiated, so we continue to 

look for opportunities to gain funds for purchasing more environmentally friendly equipment, or 

for instituting more environmentally friendly practices. 

As noted in the draft plan, in-depth review of the park’s fish communities is outside the scope of 

this plan, and none of the alternatives is expected to impact the park’s Lake Superior fishery. 

However, the park’s forthcoming fish management plan will review both native and non-native 

species in Lake Superior and the park’s inland waters. The park has a lamprey monitoring 

program in cooperation with the U.S Fish and Wildlife Service. Juvenile lamprey monitoring in 

2005 showed that no breeding lamprey population is currently present in park streams. 

(Monitoring and treatment occur in juvenile lamprey populations.) Adult lamprey are present in 

Lake Superior, but they are spawning outside of the park, and therefore control efforts would 

need to focus on non-park spawning and juvenile rearing sites. For more information on lamprey 

populations in Lake Superior, go to the U.S. Fish and Wildlife Service website, 

http://www.fws.gov/midwest/Marquette/.

F. TRANSPORATION

COMMENT

Transportation by Ferry: The private firms that supply transportation service to the island must 

operate profitably in order to continue. Profits are sensitive to fuel costs and to revenues and 

especially to patronage. Policies which discourage visitation, or are perceived by potential 

customers to be unfriendly can have serious effects for transportation providers. The risks of 

operating in these waters is considerable. The season is short, and most Action policy choices 

propose to shorten the season further for dubious reasons. Action plans which propose 

substantial changes in the business environment bring new risks to bear, risks which often seem 

to be discounted, minimized, or ignored by Park management. Furthermore the private 

transportation operators must compete with a subsidized government competitor...If visitation 

drops, is the National Park Service prepared to offer comparable subsidies to its competitors, the 

private operators? Because of the profound effects upon this critical infrastructure service, 

adequate care in policy choices ought to be exercised. This degree of care is absent in the Action 

plans, which are generally dismissive of transportation effects...Critical Times: These are critical 

times, and major changes in visitor policies that affect the relative attractiveness of Isle Royale as 

a visitation venue should be undertaken with the utmost caution. No such caution toward the 

transportation services is evident in the proposals. On the contrary, statements that it is unlikely 

that ferries will experience adverse effects are without sound basis.

RESPONSE

None of the proposed alternatives suggest implementing a shorter operating season. The 

Preferred Alternative simply allows for more informed choices by visitors when planning their 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 243

overnight trips. Likewise, the Preferred Alternative for day trips does not in any way restrict 

passenger numbers on ferries. As far as competition with a “subsidized government competitor” 

is concerned, this is a national park, which in itself is “subsidized” by the government and 

taxpayers, and providing a means of entry via a federal vessel is part of the public service offered 

by the park (see pp 29, 32 and 79.)

The park expects that while overnight visitation numbers may drop slightly during the peak 

season, the majority of these potential visitors will opt for scheduling overnight trips either 

before or after the peak season. In addition, the reason for fluctuations in visitation can be 

caused by many factors, including increased fuel and travel costs to reach ferry locations. Each 

of the private ferries offers a unique service, whether it is the scheduled trip times, departure and 

arrival locations, or time spent en route. The Park has allowed concession operators to increase 

their day use capacity on a trial basis with good results for the Copper Harbor run. The 

backpacker numbers remained relatively steady and the day use had a significant increase. 

Therefore, the park does not expect significant changes in the total numbers of passenger use on 

the ferries beyond normal fluctuations experienced to date. 

We are not proposing major changes in visitor policies, or making major changes in 

transportation services in this plan. As noted on p.178 for impacts of the preferred alternative, 

concession ferry operators would require all overnight visitors to have valid permits in order to 

purchase ferry tickets. That is the same requirement that is now in effect for groups coming to 

the park. Thus we believe it is true that it is unlikely ferries will experience adverse effects from 

this system. It is true that annual camping visitation may decrease under the preferred alternative. 

But as the text notes if this does occur, there could be more room available on the ferries for day 

visitors and lodge guests. The text also notes visitors will be made aware of all possible ferry 

options, not just the NPS’ Ranger III, and that the private ferry concession operations offer 

unique options to passengers. Thus, we believe there is a good basis to indicate that any adverse 

effects of the preferred alternative on concession ferries would be negligible to minor in 

magnitude.

G. CHAINSAWS 

COMMENTS

1. I think the use of power tools (chainsaws, etc.) is fine. After a bad storm or in the beginning 

of the summer, clearing blowdowns etc., with cut saws would take forever.

2. Chainsaw Usage: The actions common to all alternatives call for reducing chainsaw usage in 

favor of crosscut saw usage, a direction we applaud. We would urge the Park Service to move 

more aggressively in this direction, recognizing that in a wilderness are trees in all their forms 

and conditions are part of the experience. One option to offset the reduction of chainsaws would 

be to encourage more service trips through organizations like Sierra Club, working to train more 

volunteers to assist with trail maintenance. Chainsaws for emergency use would continue to be 

appropriate.
 244 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

3. I request that you make a greater commitment and effort to consult with other wilderness 

areas that manage their trails without the use of chainsaws in revising your chainsaw policy and 

come closer to eliminating chainsaw use. The Boundary Waters Wilderness boreal forest and 

Shenandoah National Park with eastern hardwoods would be a comparable forest types to the 

two ends of the island- both areas with a much stronger commitment to using hand tools over 

chainsaws.

RESPONSE

The use of mechanized equipment in the wilderness is subject to review under Minimum 

Requirement Decision Guide. In some cases, this may mean that the use of a chainsaw for a 

short period of time may be less of an impact than using a larger crew with crosscut saws for a 

longer period of time (blowdown events, etc.) Overall, the park is committed to reduce the use 

of chainsaws in the wilderness where it reduces impacts, and when staff is properly trained to 

avoid injury. 

The use of crosscut saws (as with chainsaws) requires specialized staff training and experience in 

order to operate safely. Currently the expertise does not exist in the park to widely institute the 

use of crosscut saws. The park will continue to look for ways to incorporate crosscut saws into 

its trails program, both through NPS and non-NPS fund sources. Exactly how the park would 

develop and implement its crosscut program is an operational question, but it is likely that we 

would look to other parks, like those you suggested, as a guide.

The park currently uses volunteers wherever possible to maintain trails. We will continue to do 

so as appropriate and in a manner that provides safe, productive opportunities for volunteers. 

H. TREATED LUMBER

COMMENT

1. The use of treated (ACQ) wood should not be used until the long-term affects have been 

learned. The leaching of copper into the lake, especially from a government agency, should not 

be allowed. There is already too much mercury in the food chain. As for economics, if it is 

determined in the future, that there is a problem with ACQ, the cost incurred in replacing the 

wood added on to the initial cost of the installation now is doubled. I work as a carpenter. The 

use of ACQ will cause many problems in the future due to insufficient research as to the proper 

means of attachment with both fasteners and brackets. There has already been issues raised about 

the use of galvanized fasteners vs. stainless steel and this will only continue to be a problem.

2. I am also concerned that the data used to justify the use of chemically treated lumber is 

insufficient to justify its use in wilderness ecosystems. The proof should be in proving beyond a 

reasonable doubt that there will be no harm caused many years down the line, not in proving that 

harm would be caused. It was not too long ago that this standard for proof resulted in the 

widespread use of arsenic in treated lumber at a high cost to human and environmental health. I 

would request reconsidering the decision to use chemically treated lumber in wilderness. I am 

opposed to the use of chemically treated lumber in wilderness, no matter how "benign" it is 

though to be. 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 245

RESPONSE

The park will continue to search for construction materials that have the fewest adverse 

environmental impacts. Where possible, we use island materials or redesign projects to reduce 

the amount of non-native materials needed. We will use the most environmentally benign 

materials commercially available as the plan is implemented. See p.46-47 for details.

I. HISTORICAL REFERENCES

COMMENTS

1. I will confine my comments to one area I feel is incomplete and that is "prehistoric 

occupation." It is well documented that the Ojibwa, and/or other earlier Indians, occupied Isle 

Royale (or Minong) for over 4,000 years and that they extracted copper from pits using hammerstones in areas like McCargo Cove. In Chapter 3, page 113, is the statement, "During the park's 

mining period, fires were intentionally started to expose bedrock and minerals." I suggest that is 

is "more likely than not" that Native Americans also exposed a lot of bedrock through fire for the 

mining and other activities, and did so for an extended period. Fire was used for a multitude of 

reasons. There has been a lot written in the past few decades that attests to the extensive use of 

fire by Native Americans. An excellent reference is "America's Ancient Forests," 2000, Thomas 

M. Bonnicksen, John Wiley and Sons. Too frequently, the influences (on the natural ecology of 

Isle Royale was likely determined by these people (who were undoubtably the keystone species).

2. Minor but important needed corrections are, first, Table 1 on p. 23 lists Newman Island as a 

life lease property. To my knowledge, the Newman family did not take a life lease on this island 

which is located due northeast of the Gale island...Second, the text on p. 134 implies that Isle 

Royale commercial fishermen who did not hold warranty deeds were paid before they were 

removed, or in a couple of cases, given special use permits. To my knowledge these fisher folks 

were not paid anything if they did not hold warranty deeds as did the Mattsons of Tobin Harbor 

and Emil Anderson of Johnson Island in Belle Isle. 

3. I notice an error in the WBMP on Page 151 in the writer's interpretation of the condemnation 

history. The Plan states that many cabin owners were given a unique opportunity to sell their 

land and stay on as Life Lessees. This makes it sound like the Life Lessees were able to double 

dip from the Federal trough. In reality, as part of the condemnation process of lands held by 

private citizens, the Federal Government exercised their police power. When the land buyers of 

Michigan approached the landowners of Isle Royale, there was an either/or choice. You could 

EITHER get the value of your land and buildings at that time, OR you could stay on as a life 

lessee. There were no payments made to those who chose to stay on as life lessees. This is 

neither unique nor an opportunity. It is not unique since there is a long history of condemnation 

of private lands for the good of many, in our National Parks. It is not an opportunity, since the 

value of the land, is the land itself, and that was taken. While several following generations have 

had the ability to use the land, if the back taxes could be paid in exchange for clear title, I suspect 

that most would do so.
 246 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

RESPONSE

With respect to historic use of fire on the island, Cole et al (1995) examined sediment cores from 

several of Isle Royale’s inland lakes, and found charcoal layers indicating that periodic fires 

occurred in both pre- and post-settlement times. The 1995 study also showed that fire was less 

prevalent at the southwest end of the island than at the northeast end.

We thank the commenter for clarification regarding Newman Island. The information for the 

Potential Wilderness Areas chart on page 24 comes from the Isle Royale Wilderness Description 

of Boundaries, October 20, 1976. It lists as a Potential Wilderness Addition the life lease of Mac 

Ewen and How, lot 11 of Island #14 (Newman Island) in Rock Harbor. It is possible that the 

description is in error and that island #14 is not Newman Island. The property included as the 

PWA is the How life lease. The text reference on page 25 of this document has been clarified to 

read as “How Lease.”

In a few cases, families who did not own land but had some legal agreement to occupy the land 

were paid to relinquish their rights on that land. This may have only happened in a couple of 

instances. Generally, the commercial fishermen were only offered life leases if they owned the 

property they were using, the rest were issued Special Use Permits to continue operations from 

their sites. 

The comment regarding condemnation history at the park is not correct. Many families did get 

either a life lease or payment, but some families were paid for their land and also received a life 

lease; it depended on the valuation of their land and buildings compared to the value of the life 

lease. 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 247

5.2.2 Overnight Alternatives

A. GENERAL PERMITTING 

Alternative A (No Action Alternative)

COMMENTS

1. Conclusion: Option A. No Action is the necessary choice at the present time. It is responsive, 

rather than proactive, which is proper given management's inability to forecast the consequences 

of the Action policies it has offered. All the other choices ask us to accept ever more restrictions 

as an answer to a largely perceptual problem. The other Action plans involve considerable 

inconvenience, unappreciated risk, and seem to be based upon faulty or incomplete evidence and 

insufficient reasoning.

2. It is our view, however, that the best way to achieve the goal of maximum availability 

of these activities is through Alternative A rather than the parks preferred Alternative C. As 

stated in the draft WBMP on p. 79, all alternatives include maintaining the concession-operated 

boat tours with the stipulation established in the GMP that there would be no expansion of the 

tour destinations, schedule, or boat capacity. We believe that it would not be possible to 

implement the preferred Alternative C under these conditions.

RESPONSE

The No-Action Alternative is not proactive to known concerns. The Preferred Alternative is 

based on offering more real-time information to visitors so that they can knowledgeably plan an 

itinerary with realistic expectations of whether a specific campground will be crowded or not. 

Visitors still have the freedom to establish any realistic itinerary they choose, and may vary from 

the established itinerary once they are at the park. All of the alternatives, including the Preferred 

Alternative, were drafted based on extensive public input over several seasons. The park is 

attempting to be responsive to long-standing visitor concerns and comments, while at the same 

time protecting the resources which draw visitation to the park.

The Preferred Alternative works within parameters that are consistent with the Park’s GMP. The 

GMP states that modifications in both visitor transport and private tours could occur to control 

island access and visitor spatial and temporal distribution if necessary to protect park resources. 

(GMP p. 28, 39, 117.)

Alternatives B, C, and D

COMMENTS

1. Alternative B for managing overnight use needs clarification on option 1 for boaters. Can 

boaters permit for docks only? If a boater permits for a particular campground does the boater 

get permitted for the dock? ...Option 2 is clear. The name for alternative "B" 'Managing 

Overnight Use: Provide a Broad Range of Quality Backcountry Opportunities and Protect 

Resources' is not accurate, misleads the public, and consequently, should be restated as 'Modify 

Social Conditions Through The Use Of A Reservation System To Limit Visitation'. This title is 
 248 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

more in line with the other alternatives. The public should decide whether this alternative will 

provide a broad range of quality backcountry opportunities and protect resources. The NPS 

should just state that it is their preferred alternative and not try to sway the public into believing 

that the statement is true. In fact, the NPS provides just an opinion and provides no data to justify 

that this alternative can in fact do what the title says. ...Alternative C states that permitting for 

boaters would be as it is for alternative B. However, this is not the case according to the NPS 

(Jean Battle 12/12/05 and 12/14/05). Hence alternative C is not written properly to explain the 

actions intended by the NPS. This is a significant point because the people need to make an 

informed decision for this alternative and as written they are misled as to what will actually 

occur.

2. I am concerned with the inconsistency of data required to support different decisions. Section 

D.2.2 states that there would not be an entry quota set for powerboaters until a future need is 

determined. However, in several places the plan references data that identifies a conflict with 

noise and crowding in wilderness, which is partially associated with boating visitors.

RESPONSE

Under the Preferred Alternative, Option 1 for boaters is to receive a permit for both a campsite 

and dock space.

Alternative C states that, for boaters, it would function in the same manner as Option 1 for 

boaters in the Preferred Alternative, but that it would not offer Option 2 for boaters (last minute 

permits) for full campgrounds. We feel that this point is clearly made in the draft document on 

page 64.

Alternative D does not set a quota for powerboats and sailboats because use levels are currently 

low. The alternative does state that a quota could be determined later, if the need were present. 

Issues of noise and crowding were identified as part of the visitor surveys (see 3.1.3, Affected 

Environment, Social Conditions.) Each alternative addresses potential crowding at campgrounds 

and docks in different ways.

We have changed the titles of the overnight alternatives in the final plan as follows:

No Action Plan (Alternative A); Preferred Alternative (Alternative B); Alternative C; Alternative 

D; Alternative E. Likewise, descriptive titles have been removed from all alternatives in other 

sections, except to be designated alphabetically, and as either No Action or Preferred Alternative.

B. VISITOR SURVEYS

COMMENT

Surveys--Terms such as "many people commented" or "others said" which occur in the 

document are merely descriptive. Until an analysis of the methodology and results is undertaken 

they remain anecdotal and as such offer no scientific validity. The survey methodology used to 

gather overcrowding data was not presented in the ISRO WBMP. Valid survey methodology is 

critical to the conclusions presented. A) Were the questions properly framed or were they leading 

to a desired answer? B) Were the all the choices presented? C) Was the sampling statistically 

acceptable and what was the margin of error in the results? D) Was the year for the survey 

typical? For example, since 2002 when one survey was conducted, we alone have a steady drop 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 249

in backpackers from a 2002 total of 3674 to 3006 in 2005 a 19% drop in hikers. Until we have a 

copy of all methodology used, we cannot make a valid assessment of the problems presented in 

the ISRO WBMP. In addition, the results of the survey were not presented in the ISRO WBMP. 

Without these data, it is not possible for us to determine if the permitting system is 

inconveniencing the vast majority of hikers throughout the season to satisfy the few who may 

wish to travel in the peak month. Until these data are presented, we are unable to make a valid 

argument for or against the need for a NPS permitting system.

RESPONSE

In the “Affected Environment” section, we discuss in detail the results of surveys, review of park 

visitation records, and private ferry ridership records. The study citation is included in the plan, 

and study methodology and results are available at university libraries. The information 

presented in the draft plan is a summary of the results of surveys and review of historic records. 

C. OVERALL PLAN CONTENT

COMMENT

We feel the Draft WBMP plan follows the biosphere concept as advocated by the NPS and many 

environmental advocacy groups and fails to evaluate the true resources of the park and further 

hinders park use by the American Public. Could this be the reason that the Pristine Zone was not 

addressed in the plan?

RESPONSE

Comment noted. We are not familiar with the “biosphere concept” you noted and are not 

advocating the concept. We believe the draft document evaluated all pertinent resources likely 

to be affected by the alternatives. All alternatives were developed to not hinder use of the park 

but rather to provide additional flexibility and information to visitors while protecting park 

resources (e.g., see p.55). This includes providing additional opportunities for day trips (see 

Alternative C). The Pristine Zone also was covered in the plan.

D. PERMITTING AND TRANSPORTATION

Conflicts with Concession Ferries

COMMENT

Most importantly, we believe that an appearance of and actual conflict of interest exists in the 

NPS adopting a reservation system that affects all transportation services to the park while the 

NPS competes against those services with the Ranger III.

RESPONSE

The Preferred Alternative is not a reservation system. Advance permitting would apply equally 

to passengers on the Ranger III as well as concession ferries. Any new central permitting 

system will take into consideration all concerns including our partners, the concession operated 

ferries that transport overnight users to the park. The park will work with ferry concessions so 

that people seeking permits can easily check with concessions for ferry tickets.
 250 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

Ferry Prices

COMMENT

The preferred solutions offered by some Action plans suggest that a form of price rationing be 

imposed. A permit fee, plus higher daily fees would be instituted. Restrictions on transportation 

would require higher fares. Infrastructure taxes would need to be raised to defray fixed expenses 

over fewer visitors. These policies seem to be tantamount to regulating visitation by imposition 

of planning obstacles and higher costs of visitation.

RESPONSE

The possibility of increased user fees is only one of several possible options for helping to defray 

the cost of implementing this draft plan. In order to help readers understand how the park could 

feasibly finance the undertaking, we have listed all possible funding methods, but we are not 

specifying any one particular method. Concession operators have been allowed to implement 

peak season pricing which also helps achieve minor re-distribution of users. 

Loss of Visitors

COMMENT

Critical Times: These are critical times, and major changes in visitor policies that affect the 

relative attractiveness of Isle Royale as a visitation venue should be undertaken with the utmost 

caution. No such caution toward the transportation services is evident in the proposals. On the 

contrary, statements that it is unlikely that ferries will experience adverse effects are without 

sound basis.

RESPONSE

We are not proposing major changes in visitor policies, or making major changes in 

transportation services in this plan. As noted on p.178 for impacts of the preferred alternative, 

concession ferry operators would require all overnight visitors to have valid permits in order to 

purchase ferry tickets. That is the same requirement that is now in effect for groups coming to 

the park. Thus we believe it is true that it is unlikely ferries will experience adverse effects from 

this system. It is true that annual camping visitation may decrease under the preferred alternative. 

But as the text notes if this does occur, there could be more room available on the ferries for day 

visitors and lodge guests. The text also notes visitors will be made aware of all possible ferry 

options, not just the NPS’ Ranger III, and that the private ferry concession operations offer 

unique options to passengers. Thus, we believe there is a good basis to indicate that any adverse 

effects of the preferred alternative on concession ferries would be negligible to minor in 

magnitude.

Local Economies

COMMENT

Because the ISRO WBMP "Mainland Based Permitting System" will have a dramatic and 

possibly devastating economic impact on our business and the community of Copper Harbor and 

because the ISRO WBMP makes no estimate of any impact either to our business or the 

community, we request additional time to further study the proposals before the implementation 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 251

of any system. Given the data we need to make a reasoned comment, 30 days would seem to be a 

adequate time to analyze the need for the proposed permitting system. Incidentally, this is not the 

first time we have asked for the survey methodology and resultant data.

RESPONSE

The public comment period was open for 60 days, which provided adequate time for plan 

review. In addition, ferry operators and all other interested parties were supplied pre-planning 

information in various formats and encouraged to submit comments and concerns during the 

scoping process conducted via newsletters and at scoping meetings. The summary of the current 

socioeconomic environment can be found on p.138-140; an explanation of the methodology used 

to estimate socioeconomic impacts for alternatives is on p.153; the estimated socioeconomic 

impacts for each of the overnight and day use alternatives are described in pages 169-208 

(impacts for the preferred alternative are on p.178.) 

The park will involve concerned parties such as ferry concessions during the development of the 

specific process and procedures for a new permitting system. This is a routine way to help insure 

that the way an administrative action is implemented does not cause unexpected negative 

impacts to participants.

Limiting Campsite Sharing

COMMENTS

1. Is anyone seriously suggesting that backcountry visitors are deciding not to return to Isle 

Royale on account of over crowding? If so, how should such a problem be addressed? Is 

restricting access the only Actionable approach that has undergone serious consideration, other 

than minor changes in campsites and rustic cabin additions? Apparently management is only 

calculating the disappointment costs of those who place a premium on solitude, those who didn’t 

expect to have company at their planned campsite. How does management calculate the lost 

opportunity cost of those potential visitors who are denied permits at their preferred times 

because of a policy designed to assuage other visitors disappointments? Why, when more 

amiable visitors might find occasional doubling up to be quite tolerable, why are they to be 

denied access? It would be different if no other seasons of summer offered an absence of 

crowding. But visitors can choose less visited weeks in order to find fewer human encounters, 

and many do. What is wrong with this simpler and less restrictive solution?... The policy 

prescriptions offered in the plans might be appropriate for a park that had serious overcrowding 

conditions. But such is not the case on Isle Royale, and it is unlikely to become the case anytime 

soon... Most of the backcountry visitors to Isle Royale are experienced visitors who have visited 

the island in the past and are aware of the crowding situation during the peak weeks of mid-July 

to mid-August. While they might prefer less crowding, they are prepared to experience what they 

find, or else they wouldn't come at that time. The Action option plans address a misperceived 

situation with a non-solution course of actions, for the most part... Park management appears to 

have accepted as a premise the view that doubling up is inappropriate for the type of expectations 

that visitors to Isle Royale are thought to have. The salient point is that these visitors are being 

forced to do so, as stated on p. 55. Of course they are not really being forced to do anything; they 

can continue up the trail and camp cross-country, etc. [This option may be arbitrarily ruled out as 
 252 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

a solution. See p.] Some visitors' expectations of sole occupancy of a campsite aren't being met, 

and somehow this is regarded by park management as a serious matter, one that demands 

changes in visitation policies, especially when it seems it might occur more than 5% of the time 

during the peak season...Bandwagon: If the unstated objective of the reduced visitation policies 

is to adopt a downtrend, while making it appear to be a management objective, then things will 

only get worse for visitors and the for the park’s assets and resources.

2. I don’t think we need to reduce the number of times someone should go (to the island) 

because I haven’t seen any overcrowding anywhere there. Last summer every place (docking 

area) was either empty or spots plentiful available.

RESPONSE

Visitor preferences have been solicited during visitor surveys as part of the scoping process for 

this draft plan. Visitors say crowding can be a problem (p. 11, pp.103-108). Visitors report 

sharing sites over 24% of the time during the peak season, which the park believes is significant 

enough to attempt to reduce current crowding and prevent it from becoming more prevalent. 

Even so, the Preferred Alternative does not try to totally eliminate crowding but allows for 

visitor flexibility in creating and changing their itineraries. 

Overcrowding, apart from reducing the quality of visitors’ experience, also results in resource 

degradation through increased soil compaction, the establishment of social trails, and increased 

noise levels. Because Isle Royale’s land mass is almost completely federally-designated 

wilderness, the park functions under a mandate that includes ensuring that”...the imprint of 

human activities is substantially unnoticeable...”and providing “...outstanding opportunities for 

solitude or ...primitive...recreation.” 

The point of this plan is to provide quality experiences for visitors, maintain the integrity of the 

wilderness, and protect park resources. We are not trying to define the point at which visitors 

stop coming to the park because of their dissatisfaction; rather, we are proactively attempting to 

identify those aspects of a wilderness/backcountry experience that draw visitors to Isle Royale 

and assess various tradeoffs under different alternatives. 

The park is over 99% wilderness, therefore significantly expanding infrastructure in wilderness 

areas to accommodate overflow visitors is not a feasible option (and not supported by wilderness 

legislation or the park’s 1998 General Management Plan.) Similarly, cross-country camping is 

not a solution to overcrowded campgrounds, but rather is intended to provide wilderness 

experiences away from the influence of human impacts such as designated campgrounds and 

trails. A different set of skills is required for cross-country camping (as shown by the separate 

permit requirement). Unacceptable damage to natural and cultural resources would result from 

overflow campers being allowed to expand campgrounds by camping adjacent to, or near, 

existing campgrounds.

Our efforts are focused on managing visitation in a way that is acceptable to the majority of 

visitors. Four of the five alternatives allow room for increased visitation over current numbers. 

Four of the alternatives attempt to reduce crowding during peak visitor season by shifting use 

away from the peak visitation weeks by various means. By adopting a permitting procedure that 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 253

supplies the widest array of informed choices to visitors, and still allowing them to change their 

itineraries when they arrive at the park, we believe that the negative impact to visitors will be 

minor (again, our assumptions are based on survey responses from visitors themselves.) 

Occasional campsite sharing will still occur, but the number of occurrences would be fewer. In 

addition to providing a quality experience to visitors, we also will be reducing negative impacts 

of overcrowding to the natural and cultural resources in and adjacent to campsites. 

Requiring Advance Permitting

COMMENTS

1. With the Central Permitting system, there will be winners and losers. The winners will be the 

ones who already know four months in advance exactly what dates they are able and wish to 

visit, and are already familiar with the Island from previous experience, so that they know where 

they wish to go. The losers will be the first-timers and others who don't yet 'know the ropes,' and 

in particular those for whom it is impossible to determine that very narrow window of 

opportunity to visit the Island until very close to that time. An example is our attempting to find 

a week that three grandchildren, one from each of three of our children's families, are available at 

the same time.

2. Unique Isle Royale: Isle Royale is the least visited national park. Because of isolation, the 

vagaries of weather and other causes, visitation plans must often be modified. Isle Royale has 

been a venue where freedom to change plans has been a valued feature. It may not be worthwhile 

to toss this freedom away.

3. Methodology and results aside, a mainland based permitting system will only add to the 

difficulty is an already difficult and expensive trip. Our fear is that at some point, passengers 

may simply abandon the trip altogether. For the past 15 years, the overwhelming complaints we 

receive about both the National Park Service and our reservation system is the inability to get 

through to anyone in person without having to make multiple calls. To solve some of these 

complaints, we offer an 800 toll-free number for all call-backs to our office. Passengers have 

repeatedly said how much they appreciate this convenience. In addition, we have determined that 

a web-based reservation system may be a feasible choice to relieve the vast majority of 

bottlenecks. We can imagine numerous situations when a hiker goes through the NPS permitting 

system office to clear a reservation and then finds that the ferry is full (we have a self-imposed 

backpacker limit already) only to return to the NPS system and back again. This type of 

completely dual reservation system is, we believe, unprecedented in the NPS. Hikers unfamiliar 

with the degree of hiking difficulty posed by the island terrain, will find it very difficult to 

prepare an itinerary on the telephone. Campgrounds are spaced miles apart. Each reservation will 

take great time and care to give hikers feasible alternatives for their trip. We cannot imagine the 

NPS providing the permitting staff to discuss the 80-100 calls per day that they will receive

during late June, July and early August Furthermore, unless the NPS operates on weekends, we 

will lose walk-in business that arrives unannounced and unexpected to go to the island. Without 

the ability to make an island reservation, we will be required to turn them away and thereby lose 

all our walk-up passengers.
 254 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

4. The permitting/reservation system needs to be defined in detail, in this plan, in order to make 

an informed decision of the alternatives. This plan calls for a specific action; a 

permitting/reservation system. The specific details of how the reservation system will work are 

not presented in this document. Some examples are: 1) When will permitting start for a given 

season? 2) How often can a person permit? 3) Are there restrictions with respect to the number 

of reservations a person can make? 4) Would it not seem that this reservation system relies on 

the visitors to carry out the enforcement? An example may be: A hiking party comes to Daisy 

Farm campground late at night and has a reservation and has to kick out someone who is at a 

camp site. Which campsite does he/her kick out? This person seems to have the right to go to 

every campsite at Daisy Farm and ask each camper if they are permitted for that night. This 

would appear to create more social conflict than with the present permitting system. A common 

scenario with a boater, with a reservation, would be traveling to the island near dusk (possibly 

running late due to rough seas, motor problems, helping another boater) and pulling up to a dock 

and finding it full. Then the boater would have to somehow contact the people on the shore to 

move so they could get their reservation. These types of scenarios are going to be prevalent if a 

reservation system is adopted. With respect to social conditions, a reservations system would 

create more animosity among visitors and again puts the enforcement in the hands of the visitor. 

That is why for the past 50 years, the permitting system on Isle Royale has worked very well. In 

addition, it is not fair the public would have to pay for a reservation system... Page 64 paragraph 

6: Why can't permits be issued by phone with a credit card and mailed out to the visitor? There 

are many people that are not computer savvy and rely on the use of the phone instead. A 

suggestion would be to allow for phone permitting as well. How will park personnel and people 

that work at the concessions on the island get a permit? The plan as written needs to be more 

clearly stated.

RESPONSE

The advance permitting system attempts to address overcrowding at campgrounds while leaving 

visitors with the greatest level of flexibility in designing their itinerary. There will be negative 

impacts to the small number of visitors who do not plan their trip in advance, and wish to visit 

the park during its two-week peak visitation period. Historic use levels indicate there is room to 

accommodate most off peak use. This is not unlike planning to visit many popular Parks during 

peak season. We expect that the majority of visitors will be positively impacted by the ability to 

know what the camping conditions at a given campground will be, ahead of time. See pages 59-

60 for more details. 

ISRO is not the least visited national park in the National Park Service. According to 2004 NPS 

statistics, Isle Royale NP was ranked 316 out of 357 park units. Certainly ISRO is less visited 

than many National Parks; however, overcrowding at specific campgrounds during specific times 

of the year occurs just the same, and distributing visitors more evenly among available 

campgrounds remains a critical part of preventing overcrowding.

We agree that freedom to change plans is a valued feature of park. The Preferred Alternative for 

overnight use emphasizes making information available to visitors so that they can make 

informed choices about their itinerary, with the fewest restrictions possible. Even after they 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 255

arrive at the park, they are still free to alter their itinerary. By voluntarily staying consistent with 

their itineraries, visitors will help to lessen overcrowding. 

In order to successfully implement advanced permitting, the park will have to improve its current 

communications systems to aid visitors in obtaining permits. The centralized permit system will 

include an Internet option, and we will use current technology to provide as much easy access to 

the public as possible. It is in the visitor’s best interest to have a relatively seamless process to 

access the island and that will be a primary objective during implementation. The park will work 

with ferry concessions to create a workable system. 

Some of the concerns are actually implementation or operational questions that we will address 

and try to resolve during the design of the permit system. The system would be designed so that 

permits could be obtained via Internet, telephone, FAX, in person at the central permit office in 

Houghton, or by mail. The main difference with advance permitting is that no permits would be 

issued at the island. The new system would not require the use of a computer to obtain a permit; 

it would be one of several options. Permitting for park employees and concessions staff stationed 

on the island is an operational issue that would be resolved during implementation of the new 

system. 

With respect to the suggested scenarios, campers would still be expected to share campsites 

where necessary because of overcrowding, just as they are now. Currently, campers are asked to 

double up and share empty tent pad space when sites are full. The Preferred Alternative is not a 

reservation system, but a means to encourage better distribution of overnight visitors by 

providing them with the necessary information to set up an itinerary that would reduce the 

likelihood of sharing a campsite, not entirely eliminate it. Tolerance for sharing is based on 

human interactions at the time. Currently the majority of issues that come to our attention 

relative to sharing usually involve other factors: noise, wilderness ethics or personal behavior. 

Law enforcement will continue to act on code violations. The issue of sharing a campsite is 

similar to a decision to allow someone to raft off: what is your comfort level with the individuals 

and how valid is the rationale for the need? In addition, as stated in the plan, if social conditions 

(such as crowding) were to deteriorate in the future, the NPS could implement suitable 

management actions to address them (p. 61.) 

NPS will investigate all possible methods or combinations thereof, to finance the new permitting 

system. Passing a portion of the cost of the new permitting system on to the visitor is only one 

of several ways that the park could fund implementation of this plan. 

Boating Safety

COMMENTS

1. Safety is of the utmost concern for boaters traveling to the island. Most of the boating public 

that travels to Isle Royale are from around the Lake Superior Basin. Most of these boaters make 

decisions on weekend trips and extended weekend trips to Isle Royale on a days notice because 

of weather concerns. The reservation system as framed in this plan is a failure to boaters because 

of the comments mentioned above coupled with not knowing how this reservations system is 
 256 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

going to work as stated in the WBMP Draft. Again, the current permitting system is flexible 

enough for all boaters seeking visitation to Isle Royale.

2. As for advanced permitting, it would be difficult due to weather conditions (back and forth.) 

I had to cancel Isle Royale trips several times due to bad weather. An appointment system would 

not work for me. I watch for good weather before I can make any plans.

RESPONSE

As noted on pp. 59-60, there is an option for boaters to provide flexibility for planning a trip at 

the last minute based on weather conditions. Boaters and others will be able to cancel permits 

just as they do now. Safety is also of paramount concern to the National Park Service and we 

believe the options provided address your concerns. Prior to implementing any changes, we will 

provide information on how the advanced permit system will work so that boaters will be 

prepared.

Crowding At Docks

COMMENT

Mainland permitting enforcement may be difficult, and if there are violations, it will create 

confrontational situations that create other issues. How about offering priority of locations for 

those with mainland permits. No permit then no guaranteed dock space. 

RESPONSE

Some of the concerns expressed focus on procedural or operational issues that will be addressed 

as part of implementation. The establishment of a centralized permitting office would facilitate 

“enforcement” because real-time information on campground occupancy rates and individual 

permit information would be more readily available to rangers for double-checks. Permittees 

would still carry hard-copy permits in the backcountry that contained their itinerary information 

to assist with ranger checks as well. Permits would still be required for docking.

Location of Central Permitting Office 

COMMENT

The plan mentions a permitting office in Houghton. Park Management should not be restricted to 

this statement, as all options should be explored that might satisfy the needs of the park and 

visitors, such as the off sight National Park Service reservation system. The system should also 

not become an undo burden to the ferry services and passengers making reservations. Last 

minute boater needs which are often weather related would need to be provided for as well.

RESPONSE

The Houghton location is the logical year-round choice under current conditions for centralized 

permitting, however, the main point as described on pp.59-60, is an advance permitting system, 

intended to improve trip planning and proactively manage recreation in park. Implementation 

specifics include how to implement so as not to become burdensome to concessions, the location 

of the central permit office, designing a user-friendly system, will be critical to the system’s 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 257

success. As you noted, we would envision the use of a computer system and the internet to keep 

people up-to-date on campgrounds and dock use. 

Enhancing Current System

COMMENT

Page 57, last paragraph; "For deteriorating social conditions such as dock over-crowding, or trail 

or campground crowding, management actions would continue to focus on better informing the 

public of visitation levels in different areas of the park and different times of the season. 

However, with continuation of the current permitting system it would not be possible to give site 

and date-specific information on dock or campground crowding." Comment: Before a 

reservation system is implemented, the should NPS considered enhancing the present permitting 

system with a central computer system and program that could be used to continually monitor 

and inform visitors making reservations of the present permits issued for the various 

campgrounds and docks. The system could also be accessed by visitors on the internet to inform 

them of how busy the various campgrounds and docks may be at the time they make their 

reservation and before their trip... Some suggestions here would be to: 1) Improve the present 

permitting system without a reservation system with a central computer that updates the permits 

in real time and informs the visitor of the present campground capacity levels that the visitor is 

interest in staying at on the island. A web site that shows the information to the visitor may help 

the visitor in the planning process would be valuable. This may help distribute the overnight

stays and reduce the crowding... Page 64 paragraph 6: Why can't permits be issued by phone 

with a credit card and mailed out to the visitor? There are many people that are not computer 

savvy and rely on the use of the phone instead. A suggestion would be to allow for phone 

permitting as well. How will park personnel and people that work at the concessions on the 

island get a permit? The plan as written needs to be more clearly stated.

RESPONSE

The Preferred Alternative is not a reservation system: the proposed system should operate in the 

manner you described for advance trip planning. Visitors pre-plan itineraries using available 

information on predicted campground occupancies via the centralized permitting system, and by 

obtaining their permits, they in turn allow the park and subsequent visitors accessing the system 

to know how full campgrounds will be on given dates. The system will aid each visitor in trip 

planning, help prevent overcrowding and the need to share sites, allow the park to predict 

overnight visitation at a specific campground, and help visitors to make informed decisions about 

setting up an itinerary, based on those predictions. Itineraries will still be flexible for parties of 

1-6 once they reach the island.

The mainland location allows permitting in the winter months and is less likely to suffer 

communication problems associated with an isolated remote island. All computer accessible sites 

on the Island should be able to access it for updates on campground use levels. 
 258 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

User Fees 

COMMENT

Raise the daily user fee at the busiest time of the summer. This may cause some people to use the 

Park at off peak times.

RESPONSE

The NPS currently has a new national initiative for visitor fees, and our fees may change in order 

to be compliant with the initiative. Isle Royale’s fees are based on user capacity as a relatively 

stable factor; fees are not based on economic or price fluctuations because of their volatility. 

The NPS policy on setting visitor fees can be found at http://www.nps.gov/feedemo. The park 

concessionaires have already implemented peak season fares for their operations.

E. CAMPGROUNDS, SHELTERS

Rock Harbor

COMMENTS

1. Building rustic cabins at Rock Harbor seems to be a good idea as long as there is a fee 

associated to recover the cost of building and maintaining the cabins. There would also need to 

be limits on length of stay in the cabins.

2. We suggest instead the park consider adding a number of additional Adirondack style shelters 

to the Rock Harbor campground and designate them for multi-night use as a way to meet the 

desire to offer more multi-night accommodations.

3. Pertaining to the time to build 2-6 rustic cabins for rent at R.H., I can certainly understand 

why you may have heard many in favor of that; I have even had such thoughts myself, at times. 

But then, I think about all it would bring, and my conclusion is that I don't think we want to go 

there. It would, I think, be very much out of Island character. There's no question that they would 

be heavily sought after. The question would be how to contend with the pressure for More! 

More! More!? This would introduce (some, at least) a new type of visitor to Isle Royale, having 

different expectations with respect to simplicity and self-sufficiency, quite possibly with 

increased levels of consumption and waste.

4. How much more development are we willing to (accept? encourage?) in the Snug Harbor 

area? It would be tragic if our efforts to save the wilderness were compromised by our failure to 

protect the entrance to the wilderness.

RESPONSE

The park is working toward a Rock Harbor development plan that will encompass all new and 

replacement structures in the developed area at Rock Harbor. The idea of low-cost rustic cabins 

is popular with visitors, and construction of a small number of these units will be explored as 

part of the overall plan. Prior to building rustic cabins at Rock Harbor, several scenarios will be 

analyzed, including options for fees and length of stay, and market viability. This is consistent 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 259

with the GMP, which included the possibility of adding low maintenance, sustainable rustic 

structures to accommodate a maximum of 24 people (p. 38, ISRO GMP, 1998.) 

Windigo

COMMENTS

1. Alternative C offers 2-3 shelters in the vicinity of the Windigo Dock. Providing additional 

camping opportunities here would benefit boaters staying on the dock at Windigo and/or other 

visitors. Maintenance of camping facilities here would be more cost effective than expansion at 

Washington Island, which would interfere with the historic scene and associated activities that 

might take place there in the future. These might be good candidates for reservations during the 

busier periods of July and August.

2. Other Alternatives: Why are some alternatives not considered at all? Visitor crowding at the 

Rock Harbor area could be relieved by reconstruction of the lodging facilities at Windigo. It 

could also be improved by building at least a dozen or so rustic cabins there. Construction of 

campsites near the Windigo dock area would also be of help.

RESPONSE

A new campground at Washington Island is not part of the Preferred Alternative in the WBMP. 

This action was proposed in the approved 1998 General Management Plan (p.36), provided the 

campground could be added in a way that would not detract from other uses. 

Adding 2-3 shelters near the Windigo dock, and potentially increasing the size of the most 

heavily used campgrounds was included in Alternative C in the WBMP (p.66.) Construction of 

campsites within the developed zone at Windigo would need additional marketing analysis and 

are discussed in Alternative C. The review of potential impacts can be found on p.176-180. 

Only feasible alternatives in keeping with the GMP are addressed in the draft plan. Construction 

of a lodging facility at Windigo is outside the scope of this plan.

Campgrounds- General 

COMMENTS

1. Additional campsite or campsites at Merrit Lane would be desirable.

2. Two of the potential proposals- adding the trail in Windigo and constructing new 

campgrounds to spread out use- flies directly in the face of the intense public review process the 

park went thru in the GMP process. Much thought and discussion went into the rationale and 

locations of the various zones in the GMP, and the Pristine Zone was established for the 

significant purpose of keeping new development out. In neither case is there sufficient analysis 

to aid the reader in understanding if the impacts are significant or not, and this is a serious 

shortcoming in the document. 

3. When you start talking zones I am concerned that any of the existing trails or campgrounds 

would be downgraded in zone class. For example removal of a shelter or the dock at Siskiwit to 
 260 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

move it from a zone of Wilderness portal or Backcountry to Primitive would be a downgrade in 

usability. I believe there is currently far more Pristine area on the island then will ever be used. 

The reason I say this is that most hikers I know prefer the campgrounds with a shelter if they are 

going to stay in a campground. For example Feldtmann Lake or Huginnin campground could 

actually use an upgrade in zone so that they did have shelters... Wilderness and Backcountry 

Facilities section: Shelters would continue to be maintained, though per the GMP no additional 

shelters would be added to campgrounds within designated wilderness, and shelters will 

eventually be removed from the Duncan Bay and Siskiwit Bay campgrounds, after the docks are 

removed. This is my example of a down grade. The concept of removing that dock from 

Siskiwit drives me crazy. I love that dock when I am out on a backpack trip. I can only imagine 

what the boaters must have to say about its removal as well as the other dock changes in the 

GMP. They should all stay as well as the shelter. For example my wife and daughter can now say 

their first swim in Lake Superior came as a result of jumping off the dock at three mile. It part of 

the experience. Take it away and it is lost forever. 

4. Reference page 54. How can the Park construct a campground on Johns Island when there are 

no established guidelines associated with the impact on Johns Island Cultural resources? Also, 

you don't define what an "acceptable impact" is.

RESPONSE

The park’s General Management Plan/EIS (1998) contains plans to add 1-2 campsites at Merritt 

Lane to improve opportunities for paddlers to camp there. GMP approved campgrounds and 

campsite additions to campgrounds that were field verified for viability were included in the total 

numbers of the Preferred Alternative. Before a campground is established at Johns Island, the 

park will complete a review and analysis of the proposed action according to the National 

Environmental Policy Act and the National Historic Preservation Act. This review will take into 

account the impacts on the environment as well as potential impacts to the cultural resources at 

the site. 

While expansion of campgrounds to alleviate crowding not included in the GMP is explored in 

this plan, the Preferred Alternative does not extend beyond the GMP. (More discussion about 

trails and the Pristine Zone can be found under the “Day Use” comments and responses.) 

The establishment of zones occurred under the 1998 General Management Plan. We are not 

proposing (with the possible exception of the establishment of a Windigo loop trail-see Day Use 

comments and responses) any revision of zones. The GMP also discusses those areas where the 

park plans to remove or place structures including docks and shelters. Those issues are not part 

of this plan. The comment on amount of Pristine Zone area in the park exceeding visitor use 

misses the basic point about Wilderness designation. Wilderness areas are set aside as premier 

examples of areas “...where the earth and its community of life are untrammeled by man...” Part 

of preserving wilderness character and the natural and cultural resources found within it means

that it is preserved in as undisturbed a state as possible for current and future generations.
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 261

Anchoring Out

COMMENT

Clarification Needed: Page 42 paragraph 6; Can the NPS define what they mean by unacceptable 

impacts to park resources and values for boater's that are anchoring out? Please provide specifics.

RESPONSE

In the section, Actions Common to All Alternatives, the park specifies that, if in the course of 

monitoring, it determines that resource damage is occurring due to cross-country camping or 

anchoring out, it maintains the ability to regulate use to reduce or eliminate resource damage. 

This is not a new concept: the park always has the ability (and the responsibility) to protect 

resources from damage. The reason this statement is included here is to clarify that while crosscountry camping and anchoring out will continue under all alternatives, they are still subject to 

the same management considerations that they have always been. An example of a potential 

restriction on anchoring out would be a protective perimeter established off a section of shoreline 

where bald eagles or common loons were nesting.

F. VISITATION

Visitor Distribution

COMMENT

Provide more than two entry corridors for hikers and paddlers so as to reduce congestion at 

Windigo, Rock Harbor and surrounding campsites. This could be done by increasing the taxi 

service capacity or using the MV Sandy to ferry visitors to other locations. A trial study should 

be performed such as providing this service during the peak visitation times and maybe use two 

entry points such as McCargo Cove on the north shore and Chippewa or Malone Bay on the 

south shore. The impacts of the visitor redistribution throughout the island should be monitored 

to evaluate the social and environmental impacts. This is in line with suggestions made by 

researchers (Mayo 2001),3) A model should be developed using GIS and visitor information to 

evaluate the best possible ways of managing ferry service with campground crowding during the 

peak visitation times to minimize congestion and improve visitor experiences. Similar to 

Alternative C suggestion by NPS.

RESPONSE

Currently, the park maintains 2 points of entry for new visitor arrivals because the majority 

obtain their permits there and receive their island orientation there. If the concession proposed 

additional ferry runs to other parts of the park, we would consider that request when received. 

As it stands now, visitors are already able to hire a water taxi or ride the MV Sandy to reach 

other parts of the park more quickly than if they were hiking from Rock Harbor or Windigo. In 

addition, the Voyageur II already offers the option of reaching other parts of the park via an 

established ferry route.
 262 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

The park is not limiting itself from future consideration of altering ferry routes or schedules. In 

the event a ferry route was altered, the park would determine if and what type of environmental 

review was needed.

Shoulder Season Visitation

COMMENTS

1. Some suggestions here: 1) Provide no restrictions on visitation in the spring on the trails and 

in the campgrounds, 2) Over the next 5 years, design a study that addresses these issues and 

collect data to substantiate or refute the statements made on page 176...For example: page 176 

last paragraph: "Maintaining low visitation in spring would have a long-term moderate effect on 

natural resources in the park, relative to current conditions" "For example, low paddler numbers 

on inland lakes in the spring appears to be beneficial to loon nesting (Kaplan and others, 2004). 

Maintaining low human impacts such as disturbance of nesting loons and human encounters with 

wolves or wolf pups could results in moderate to major beneficial impacts, whereas minimizing 

trail widening associated with muddy conditions would be minor to moderate and very 

localized." These statements seem to be opinions that serve to restrict visitation on the island...

Page 58 visitor use levels: Setting the spring visitation level at 20 percent of the park's total 

camping capacity seems arbitrary and not justified with respect to visitor social conditions or the 

affected environment. The GMP or the proposed WBMP provides no data to show that the 

visitor social conditions or the affected environment are being harmed and seems to only be an 

opinion by the NPS and some researchers.

2. Also significantly lacking in the impacts analysis is the use of real numbers for the reader to 

understand the potential for increased use in the Fall season, or in some cases the Spring season. 

For example, on Page 58, under B.2.1, Alternative B talks about allowing increased use in the 

fall “within the existing ferry capacities and schedules”-why not provide the reader with some 

real numbers as to what this might mean? Similarly, for spring use is the comment “visitation 

not exceeding the highest point between 1994-2003”-why not provide those numbers and relate 

what it means to total visitor numbers, visitor use on the inland lakes as it relates to loon nesting, 

campsite sharing, etc?.. Having spent 11 Fall seasons on the island, I believe that season is far 

and away the best opportunity for a superior wilderness experience in the park. The combination 

of fall colors, low visitation, wildlife activity, and crisp weather provides a superb wilderness 

experience that cannot be found during the summer months, and that is why that precious period 

needs to be protected. These temporal aspects of the wilderness quality/character of Isle Royale 

need attention, for in the end that is one way to provide a range of wilderness experiences to a 

range of users. If the net result of managing the peak season is to spread the use out and degrade 

the superb experiences found in the Fall season, then overall the park has failed to manage its 

wilderness resource...Protect the natural resource-sensitive Spring season by keeping visitor use 

low, and protect the Wilderness Character-sensitive Fall season by keeping visitor use low. Do 

not compromise these two use seasons, they are each highly unique for what they provide the 

park as the foundation of the overall wilderness character of the park...Do not allow for 

increases in Fall use that potentially match the ferry capacities and schedules- for I do not know 

what % increase that might be (the document doesn't say) nor is there any logic to managing it to 

those numbers. If you have to find a number to cap it at, then be consistent and use the same 

logic you use for spring use, and cap it at the highest Fall use level you've had between 1994-
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 263

2003. We should not be so shortsighted and assume that visitation will never rise to the numbers 

in the Fall that are possible under the maximum ferry capacities and schedules that presently 

exist- it could happen. There are numerous examples where shortsighted thinking such as that 

has created real headaches (Yellowstone winter use, for example)...What is most important to 

protect the wilderness values of Isle Royale, it is those Spring and Fall seasons- I urge you to not 

compromise them. The document does not adequately evaluate the potential impacts of 

increasing the visitor use in those periods...Manage the peak season use by spreading it out 

throughout the summer season better. This may or may not mean lower overall numbers, but the 

public will adapt.

3. On retaining low use in the spring: The plan doesn't say whether it means boaters as well as 

backpackers. Backpackers will be limited by the GMP which indicated ferry service schedules 

will not be expanded, so this caps them on the max end. To keep them at current low levels, 

ferries would then need to be restricted to historic use. Lake Superior storms and its cold waters 

have effectively maintained low use for boaters in the spring and fall. They should not be 

restricted (issuing less permits then the demand) through the permitting process during spring & 

fall, but rather allow the lake to continue its natural influence on boaters. The same should 

likewise hold for the fall. (Management action is not necessary, when the lake has and will 

continue to be such a limiting and controlling factor- Also, I can't see this changing for the life of 

this current plan.)

RESPONSE

Ferry capacity and schedule data are included in Table 6, Ferry Schedules and Capacities, page 

100. Visitation data are included throughout the draft plan, including Tables 7-10, and Figures 

2-5. Loon nesting data are found on pages 123-124, including Table 13: Fledging Rates (per 

territorial loon pair) at Selected Long-Term Monitoring Sites.

Suggested spring visitation numbers are based on historic use patterns, and various levels of 

spring visitation are reviewed across the range of overnight alternatives. There is no plan to limit 

boater access to the park any time within its open season. (Park data show a decline overall, thus 

there is no current need to limit boaters.) 

As noted on p.176, there is a need to manage use to ensure that the use of trails and campgrounds 

does not adversely impact resources. The NPS is obligated to protect resources, and the spring is 

a time when resources are more vulnerable. We base our choice for maintaining historic use 

during the spring in the Preferred Alternative on research and Park data that are available, on 

known life history of park flora and fauna, on professional judgement and on observation of 

conditions over the history of the park. Studies conducted at the park are cited in the plan (for 

example, see Chapter 3.3- Affected Environment, Natural Resources, where several studies are 

cited.) The Preferred Alternative does not propose to restrict or reduce spring visitation, but only 

to hold it to historic high spring use levels to avoid potential impacts. 

Long-term implementation and continuance of the Preferred Alternative would rely heavily on 

data collected from an extensive and on-going impacts monitoring program to be developed, in 
 264 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

order to facilitate adaptive management and therefore accomplish the objectives identified by the 

park. 

Shoulder season visitation has fluctuated throughout the history of the Park and is limited by 

current ferry schedules and capacity which are unaltered by this plan. The park has no data to 

support negative cumulative effects to resources or visitor experience as a result of past peaks in 

visitor numbers during spring and fall shoulder seasons, or benefits as a result of dips. A 

thorough, extensive, and ongoing monitoring plan will be developed to test hypotheses regarding 

impacts of shoulder season use. A commitment to using sound monitoring data for adaptive 

management is a critical part of the Preferred Alternative to track future issues that may occur as 

both natural and human influenced impacts on biological processes for both flora and fauna. It 

will be especially important to monitor if/when usage starts to exceed the past peaks. We have 

added a more detailed explanation about how we will develop monitoring for individual and 

cumulative impacts in the respective sections of this document.

Peak Season Visitation

COMMENTS

1. If visitation drops, is the National Park Service prepared to offer comparable subsidies to its 

competitors, the private operators? Because of the profound effects upon this critical 

infrastructure service, adequate care in policy choices ought to be exercised. This degree of care 

is absent in the Action plans, which are generally dismissive of transportation effects.

2. Manage the peak season use by spreading it out throughout the summer season better. This 

may or may not mean lower overall numbers, but the public will adapt.

3. Further, The Isle Royale Line, Inc. has made extraordinary effort to limit hikers in the peak 

period by economic means. We charged higher prices during peak period and eliminated group 

discounts. Yet, the NPS offers a significantly lower price in general ($108 vs. our $116) but an 

even lower group rate ($90 vs. our $116). We find it disingenuous to decry overcrowding but 

remain unwilling to try to bring economics to bear on problem-and also to offer discounts to 

groups. In short The Royale Line has already adopted a number of good-faith policies to limit 

backpacker traffic in the park during the island's peak period, and we have met with some 

success. The 19% drop in backpackers since 2002 (the year of the most recent survey of 150 

hikers) attests to the success of that endeavor.

4. The NPS has not provided information to the public that shows decreasing the campground or 

dock crowding significantly impacts the resources or degrades the social conditions to a level 

that warrants a reservation system. Consequently, it is difficult to make a decision as to whether 

a reservation system is needed at this time and whether this alternative is a viable option for the 

public, especially when as the WBMP points out, that during peak visitation, the park 

campground capacity is at only 68 percent. More information is needed for the public to make a 

better informed decision. 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 265

RESPONSE

The Preferred Alternative would mostly focus on better distribution of visitors during the peak 

season. The park expects that while overnight visitation numbers may drop slightly during the 

peak season, that the majority of these potential visitors will opt for scheduling overnight trips as 

close to the peak period as possible, which will result in highest visitation still in the summer.

The reason for fluctuations in visitation can be caused by many factors, including increased fuel 

and travel costs to reach ferry locations. Each of the private ferries offers a unique service, 

whether it is the scheduled trip times, departure and arrival locations, or time spent en route. The 

Park has allowed concession operators to increase their day use capacity on a trial basis with 

good results for the Copper Harbor run. The backpacker numbers remained relatively steady and 

the day use had a significant increase. Therefore, the park does not expect significant changes in 

the total numbers of passenger use on the ferries beyond normal fluctuations experienced to date.

The park may experiment with a peak/shoulder season pricing structure.

The impacts of existing campground or dock crowding are described on pages 102-108, and the 

impacts of continuing current management into the future on visitor experience conditions are 

described on pages 165-169. Crowding also was identified as a public concern during scoping 

for the plan (see p.12) and in previous visitor surveys (see p.15). We believe an advance permit 

system would improve the visitor experience and therefore is warranted, as described on pp. 174-

176.

G. WILDERNESS ZONES

Pristine Zone

COMMENTS

1. CROSS-COUNTRY CAMPING: The potential for harm to the natural resources of IRNP 

from cross-country camping raises concerns about the decision common to all alternatives to 

continue with the existing regulations for cross-country camping. The analysis in the EIS 

explains a variety of the possible negative effects of cross-country camping, but does not address 

how the Park Service will be able to monitor the impacts of cross-country camping. While the 

numbers of parties are relatively few per year, we have a concern that parties as large as six may 

cause damage to the remote areas of the park. We would suggest limiting the size of crosscountry camping parties to three or four in the interests of limiting the impacts.

2. Where is the discussion of the incorporation of off trail camping in the pristine zone? THIS 

DOCUMENT DOES NOT INCLUDE A PERTINENT DISCUSSION OF HOW THE OFF 

TRAIL USE OF THE PRISTINE ZONE (INCLUDING CAMPING AND HIKING) MAY 

EFFECT (sic) THE ISSUE OF CROWDING IN THE CAMPGROUNDS, IN ANY OF THE 

ALTERNATIVES IN A MEANINGFUL WAY. For example, what is the carrying capacity of 

the pristine zone? How many permits are allowed in this zone and how would this offset 

crowding in the campgrounds? Not only was the Pristine Zone ignored in the Alternatives 

Section, the Affected Environment Section does not contain a description of the Zone, and as it 

would be expected the Environmental Consequences section has no mention of it. The scope of 
 266 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

this plan included the Pristine Zone and as such, alternatives must include this zone along with 

Affected Environment and Environmental Consequences sections...We support the expansion of 

certain campgrounds that experience crowding. We advocate the use of the pristine zone for 

hikers and paddlers that want solitude and we feel the NPS needs to better inform and educate 

the public of the opportunities and use of the pristine zone...As a background, one must first 

consider the size of the affected area that is in question with respect to the WBMP. The total 

wilderness area reported by the NPS is approximately 131,925 acres of land. If we assume that 

trails are 6 feet wide and there are 165 miles (5280 ft/mi) of trails then there are 5,227,200 ft2 of 

trail area utilized by visitors. The campground area affected as report by the NPS in Table 12 of 

the WBMP is 196,160 ft2. The total land area affected is 5,423,360 ft2 or 124.5 acres. So the 

percentage of wilderness land mass that is used by the vast majority of the visiting public is only 

0.0944 percent. This plan only addresses this 0.0944 percent. All the alternatives presented in 

this document do not incorporate a plan for visitor utilization of the pristine zone which is 99.906 

% of the land mass of Isle Royale... In addition, the Draft WBMP fails to provide the carrying 

capacity of the pristine zone and does not address how the utilization of the pristine zone can 

alleviate crowded campgrounds during peak seasonal visitation even though the park 

campgrounds as a whole have never been exceeded.

3. Do not create new development within the Pristine Zone, be it campgrounds or trails.

RESPONSE

The park’s zones, and what is appropriate “visitor use” within each, is defined in the GMP (p.30-

33). Visitors to the pristine zone experience a pure wilderness setting, free of development, 

without facilities or trails, with little or no sign of humans or their impacts evident. No facilities 

are appropriate, and only regulated cross country hiking and camping would be permitted (ISRO 

GMP, 1998.) Cross-country camping (also referred to as “off-trail camping”) has never been 

intended as a way to alleviate overcrowding in campgrounds. Cross-country hiking and camping 

require a special set of skills, as well as a special permit, to ensure that no resource damage 

occurs as a result of this activity. None of the alternatives in this draft plan contain any changes 

to the current cross-country use regulations (see pp. 31 & 42, and Appendices D &E.) The park’s 

Pristine Zone will continue to offer cross-country hiking and camping opportunities for those 

who have the requisite backcountry skills and prefer that type of wilderness experience

We disagree with the comment that the WBMP does not fully address visitor use of the 

wilderness area. First, with regard to the lands in the wilderness used by visitors, statistics must 

take into account that visitors also access the wilderness area by water, and not necessarily rely 

on campgrounds or trails. Some people also travel cross country on the island. Thus, the area 

used by the public is larger than the percentage you cited. The alternatives focus on the major 

wilderness area issues, which mostly are not in the pristine zone. But the plan does address 

management of the entire wilderness area, including the pristine zone — the framework for 

managing wilderness (§2.1, p.28), the description of the land zones (pp.30-31), the no action 

alternative (§2.2., pp. 34-42), actions common to all alternatives (§2.3, pp. 42-54) cover all of the 

wilderness area, including the pristine zone.

Isle Royale completed a systematic camping survey in the Pristine Zone over the 2004 and 2005 

seasons to locate cross country campsites, determine the extent of cross country camping 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 267

impacts, and to develop an effective methodology for future monitoring to compare to the 04-05 

baseline survey. The inventory and data analysis methodology used in this inventory of 

undesignated campsites were adapted from monitoring methods for designated campgrounds 

created by Dr. Jeffrey Marion for Isle Royale in 1996. The findings showed that currently the 

majority of cross country campsites had no or minor resource damage, and therefore there 

continues to be no limit on the number of permits allowed in the pristine zone . The number 

issued currently is an operational question and varies depending on how many people apply for 

permits, where they wish to go in the wilderness area, on what day, for how long. 

One of the recommendations in the final draft report was that the park should perform a portion 

of the monitoring each year so that the entire survey was complete every 5 years. These data 

would then inform future decision making on managing cross country camping. The draft of the 

final report was not available until after the printing of the draft WBMP/DEIS, and therefore was 

not cited. Detailed information on the pristine zone survey will be included in the monitoring 

plan, to be developed subsequent to this plan being finalized.

We are not proposing a significant increase in use of the Pristine Zone in the Preferred 

Alternative, therefore it does not receive extended discussion in the draft WBMP (for further 

response to comments on the proposed Windigo Trail, see Day Use comments.) The Pristine 

Zone, and all areas that fall within the federally designated Wilderness areas of the park, are 

being and will continue to be managed in ways that are consistent with the Wilderness Act of 

1964. The park is not required to consider adding campgrounds under this plan. 

Alternative C does include the option of adding campsites and possibly new campgrounds. The 

Preferred Alternative, with the exception of one new campsite proposed for North Desor and

campsites listed in the general management plan, does not consider new campgrounds.
 268 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

5.2.3 Day Use Alternatives

A. TRAILS

COMMENTS

1. Meanwhile, the Friends opposes the preferred Alternative (Alternative C) because it would 

create a three- to five-mile trail at Windigo and allows more ferry passengers to reach wilderness 

areas than is allowed. According to the EIS, the proposed trail “...would remain as much as 

possible within the non-wilderness boundary.” Lacking assurances that all of the new trail 

would remain out of the wilderness area, where a new trail is incompatible, renders Alternative C 

as an unfavorable option.

2. Day use management-Additional short day trails make sense. Limit the numbers on ferries 

during August.

3. On my many trips to I.R., I noticed the main trails out of Rock Harbor and Windigo would be 

broad from overuse. Tree roots were exposed and surface soils were compacted. As I ventured 

deeper the trail would narrow and the damage would be less. Your idea to create a 3-5 mile loop 

near Windigo would improve the quality of the main trails if you made a concerted effort to 

narrow the broad main trails near the Harbor. I support smaller groups that might use such a loop 

trail because it will lessen the overall impact on I.R.

4. While it is good that only the new trail gets lumped into one of the Preferred Alternatives, 

there is insufficient analysis to determine the impacts- what are the impacts to soils and 

vegetation, to wolf use patterns, to the very rare marten population on the West end?... Two of 

the potential proposals- adding the trail in Windigo and constructing new campgrounds to spread 

out use- flies directly in the face of the intense public review process the park went thru in the 

GMP process. Much thought and discussion went into the rationale and locations of the various 

zones in the GMP, and the Pristine Zone was established for the significant purpose of keeping 

new development out. In neither case is there sufficient analysis to aid the reader in 

understanding if the impacts are significant or not, and this is a serious shortcoming in the 

document. .. Do not create new development within the Pristine Zone, be it campgrounds or 

trails...In terms of day-use, I have no particular favorite other than strongly disagreeing with the 

idea of a 3-5 mile loop trail in Windigo. Nowhere in the document do I see a logical rationale for 

it, nor have I ever heard a call from the public for such a trail. There presently exist good options 

for day-hiking in the Windigo area that can accomplish the very same purpose. The notion of 

needing to separate the backpacking hikers from the day-hikers in Windigo is a very weak 

justification, nor can I even imagine that situation- day-hikers mingling with backpackers just 

starting out or leaving Windigo- would be a concern for either group. I never heard this issue 

raised in the GMP process nor the early days of the WBMP process, and the issue is not 

expressed in the Section 1.7.4. issues section, nor in the issues associated with the park’s GMP. I 

seriously question whether the typical day-users to Windigo would even use this trail- what is the 

general makeup of the day-users, and how likely is it that they would pursue a 3-5 mile-day hike 

during the layover of the ferry boats in question, which supply most day-users? The additional 

fact that the trail would pass through the Pristine Zone violates the core premise of that zone- the 

lack of park infrastructure/human development in the zone. A mere few years after the 
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 269

completion of the park's GMP and there are already efforts to revise the zones to accommodate 

further development is very troubling.

5. However, the issue does raise some unanswered questions about the location and design of 

the proposed 3 to 5 mile trail at Windigo. The WBMP indicates an amendment would be made to 

the General Management Plan to reassign some of the Pristine zone to Backcountry zone, but the 

EIS suggests the proposed trail might be entirely in the Backcountry zone. The EIS discusses the 

expected impacts of the proposed trail in a very general way which raises many of the key issues 

of concern, but doesn't explain how the trail would be designed and how public input would be 

garnered. While we understand that the initial decision needs to be made among alternatives 

prior to planning the trail, some guidance on the process used for public input and analysis of the 

proposed trail would be helpful.

6. We feel the preferred alternative for day use fails to meet the requirements of NEPA. 

Specifically, the proposed trail. The trail is a site specific action and needs to be addressed as 

such. This includes specific description of the trail location, specific description of the affected 

environment and specific consequences to the environment. None of these requirements of 

NEPA are present.

7. On the other hand, the preferred alternative for day use proposes establishing a new trail 

within both the Pristine Zone and designated wilderness, with associated major adverse impacts 

to wilderness on a local scale. Yet there is no data supporting a need for such a new day option in 

Windigo-no data demonstrating that either the current day hiking options are insufficient or that 

a significant conflict between day hikers and backpackers exists in the Windigo area. Nor is there 

any data presented that would support a concern that day use may increase in the Windigo area 

to the extent that additional trail options would be necessary. A stronger case with sound data 

supporting that there is a demonstrated need for the trail and the benefits of the new trail would 

outweigh the costs is needed to justify including this in the final preferred alternative. I am 

opposed to the creation of this trail.

RESPONSE

The rationale for the new trail is described on p.82. The trail is intended to provide more 

opportunities for day activities within the vicinity of developed and frontcountry zones, while 

also improving the overall quality of opportunities for day activities. It would not be built to 

separate backpackers from day hikers as the comment suggests. We also stated on p.82 that the 

trail would remain as much as possible within the non-wilderness boundary. We should also 

point out that the WBMP does not state that a trail necessarily will be built. Rather, the text notes 

that we will explore options for such a trail. The non-wilderness area surrounding Windigo 

encompasses approximately 400 acres. The proposed trail location would be primarily in the 

non-wilderness zone. We are exploring approximately a 224 yard segment of the trail extending 

into the Pristine Zone. The impacts sections (under Day Use and under Cumulative Impacts-Day 

Use) have been revised to include additional information pertaining to the proposed loop trail. 

The park will review all possible non-wilderness zone options for the trail before placing any 

portion of it in the Pristine Zone, and will not propose more than a 1% incursion into the Pristine 

Zone. Potential reasons for locating a small portion of the trail in the Pristine Zone include: to 

avoid sensitive natural or cultural resources discovered in the non-wilderness area; providing an 
 270 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

outstanding opportunity to view a unique natural resource or cultural resource feature that can’t 

otherwise be seen; the need to avoid steep grades. The park will complete all required NEPA 

compliance for any trail design, tiering the additional compliance work off of the final WBMP.

B. DAY USE VISITOR GROUPS

COMMENTS

1. This proposed arrangement would we believe pose an ongoing challenge for all entities 

involved. NPS budget constraints in recent years seem to make it unlikely that more NPS 

interpreters could be made available for the additional staffing required. Tour operators in our 

experience would be hard pressed to add additional personnel to meet this proposed extra 

staffing. Isle Royale Resorts fields a two person crew on the M. V. Sandy consisting of a 

U.S.C.G. licensed captain and deckhand, both of whom have provided some degree of 

interpretation when needed. Aside from the specific skills needed to operate the boat safely, each 

crew member is also enrolled in both company required and U.S.C.G. required drug and alcohol 

testing programs, making the casual addition of lodge provided crew for temporary interpretative 

duties a difficult prospect.

2. Elderly Visitors: Where is the consideration for elderly visitors in the management plans? 

Handicapped visitors are mentioned. Up until the closing of Windigo’s dining room by fiat of 

superintendent, there were many days when dozens of middle aged and elderly visitors enjoyed a 

meal of local fish in the Windigo dining room, while enjoying a view of the harbor, often with 

moose grazing. Why are not these types of visitors of concern, as opposed to worrying about 

campers who complain of doubling once in a while? Perhaps your surveys failed to find the 

elderly because they are mostly gone from visitor samples, victims of errant policy decisions of 

the past? Why then are these Action policy preferences worthy of reliance if based on incomplete 

information that ignores some formerly important user groups?

Clarification Needed: Page 43 paragraph 1; Both the Isle Royale Historical Society and the Isle 

Royale Boater's Association hold annual meetings at Rock Harbor Lodge. Both organizations 

hold one day meetings to support various activities related to helping the NPS promote various 

activities on Isle Royale that benefit both the NPS and the public. Will placing the limit on the 

size of the groups in the park impact the activities of these organizations?

3. Day use--I understand Edison Fishery is designated frontcountry, w/ group size 20. I'd like 

some guidance on group size for those who walk to Bangsund--some guided (IRI), some not. 

RH lodge is interested in more formal advertising of the option to hike to Bangsund for Sandy 

passengers. Usually only guided trips exceed 10, but family groups may exceed 6. It appears 

Bangsund is in a pristine zone, so we need consideration for appropriate group size. There is a 

distinct advantage in keeping organized groups together (saves time for researchers, especially). 

People do no make that hike (Edisen-Bangsund) for a wilderness experience, rather to learn 

about wolves and moose. Finally, I understand the advertising the "Bangsund option" would be 

cleared through NPS, as Greenstone would be the venue--all I know is RH lodge is interested.
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 271

RESPONSE

First, to clarify: overall day use numbers will not be limited. Limitations were proposed for day 

use tour groups, not unrelated visitors who may incidentally arrive at the same time at a given 

site from various other parts of the park (off ferries or off private boats, or on foot.) Also, no 

restrictions were proposed for use of developed areas.

Based on some of the concerns raised during the comment period, we re-designed the day use 

tour size limits under Preferred Alternative C. as follows: Frontcountry Zone: group size limit of 

40 (includes all previously listed destinations in draft plan, plus now includes Lookout Louise, 

Hidden Lake, and McCargoe Cove.) Wilderness Portal, Backcountry, and Primitive Zones 

(excluding those listed above): group size limit of 20. Pristine Zone: group size limit of 6. The 

park will manage other commercial use based on trip dates and activities to avoid exceeding 

these numbers at a particular site by organized groups, giving concession tours precedence 

because of their established schedules within the park. The potential impacts of this revision fall 

within the range of impacts in the No Action Alternative, where no limits exist in any of the 

zones.

The final plan includes a more detailed discussion on the above changes under all areas 

pertaining to the Preferred Alternative for Day Use, as well as in the Cumulative Impacts section 

for the combination of all preferred alternatives.

Based on the comment regarding Bangsund Cabin’s location in the Pristine Zone, we reexamined the GMP mapping and determined that in fact, Bangsund Cabin should have been 

mapped as a Backcountry Zone. It does not meet the definition of Pristine Zone, and it appears 

that mappers made an error during the development of GMP maps by not designating it correctly 

as Backcountry. The organized group size for Bangsund Cabin is 20 under the revised Preferred 

Alternative.

Regarding consideration of elderly visitors, we conducted surveys across all of our user groups 

to determine what visitors perceived as problems or concerns (Pierskalla and others, 1997 and 

1998.) It is our responsibility to be responsive to our user groups, and while we welcomed (and 

solicited via various accepted means) public comment from anyone who had substantive 

comments to make, it is not feasible (or even appropriate) for us to target one particular 

demographic group which may normally be underrepresented at the park. We are aware that 

certain user group are underrepresented for various reasons (including logistical difficulty and 

expense of reaching the park), and we are trying to increase opportunities where possible. For 

example, the Park has been working with Isle Royale Institute to enhance programming and 

opportunities for underrepresented groups, including the elderly.
 272 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

5.2.4 Campfires

COMMENTS

1. At no time did I think that my wilderness experience was diminished because of a lack of a 

camp fire. Please increase the area and time frame where campfires are not permitted. I don't 

believe campfires are in use very much as a cooking method. I don't believe that the aesthetics of 

a campfire are worth the local resource impacts that results.

2. Campfires- In the 1970's, the Park loaded up the landing craft and put pulp sticks at every 

lakeshore campground. The Park also provided a saw and axe at every campground. Visitors 

were invited to cut trees. In effect, the visitors were trained to expect fires. Now, policy has 

changed-we all have the right to get smarter. While rotation of sites sounds reasonable, I think 

this will be hard to manage. I would limit to very few locations, and ban during fire seasons.

3. Our members observe that the importance and attractiveness of campfires is likely to be 

significantly greater in the spring and fall when the weather is more likely to be cold, and it 

would be advisable to use the Backcountry permitting office to assure that visitors are aware of 

whether their routes take them to campsites with fire rings.

4. NPS should prohibit the importation of firewood to the island to prohibit introducing invasive 

species such as the Ash borer or japanese beetle creating more problems with the island.

RESPONSE

The Preferred Alternative balances some visitors’ desire for campfires with the need to minimize 

resource damage. The park would maintain the flexibility to remove fire rings or rotate the 

location of fire rings among campgrounds. Rotation of fire ring sites is based on the ability of the 

park to maintain adequate monitoring of resource damage at sites/campgrounds with fire rings, 

and the analysis of fuel loading and resource sensitivity in any campgrounds to be included in the 

rotation cycle. If the park was not able to devote adequate staff time to resource sensitivity 

assessment and monitoring, campfire use would be eliminated. In effect campfires are limited by 

this policy. 

Under the Preferred Alternative, the centralized permitting process would inform visitors where 

campfires are allowed. The visitors’ permits would continue the current practice of stating 

whether campfires were allowed in each campground on a party’s itinerary.

All alternatives in the WBMP include a prohibition on transport of firewood into the park from

outside sources. The purpose is to prevent the introduction and spread of invasive exotic species.
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 273

5.2.5 Fire Towers

COMMENTS

1. I enjoy climbing the firetower at Feldtmann. I would think with the Park Service upgrading 

communication and the use of wifi, the towers would be a logistical choice instead of having to 

install the required tower for cell service for instance.

2. Fire Towers-Like other cultural resources, these reflect a past period in the Park's history. I 

would leave in place, and when maintenance and safety become an issue, dismantle and leave on 

the ground in place. Just like the boiler at Daisy Farm, or the ore car in McCargoe Cove or the 

house on Newman Island, or the boathouse on Savage Island. Save the taxpayers $100,000, or

use the money for another valuable interpretive need at the Park. I think the firetowers reflect a 

different period, one that has equal value in the history of the island.

3. It is not prudent at this point to make any decisions on the fate of the Fire Towers because 

they are cultural resources and should be discussed in the cultural resources plan.

4. I would like to see Feldtmann Tower remain. 1. It's too expensive to dismantle and remove. 2. 

It may be a very fine interpretive site in the future, when Isle Royale puts more resources into 

interpretation rather than law enforcement. 3. It is at present useful for research--monitoring 

radio signals, for example.

5. This situation is not only a jarring intrusion to the wilderness experience but is also a serious 

danger to hiker safety. Because the tower is so low and the view obscured by trees, a tall crows 

nest was added on top of the roof. We know from a number of accounts from other hikers, that 

people climb up onto roof and up into the crows nest. Even when the gate is down and locked, 

people scramble up and over the catwalk fence. An accident is waiting there to happen...If the 

whole fire tower can't be removed soon, at a minimum the crows nest should be taken down right 

away. The radio antenna tower, which provides access from the catwalk to the roof, should also 

be removed. In addition, until the tower can be removed, the cabin should be secured from 

unauthorized entry or perhaps any entry at all. This would have to include covering the broken 

windows (or perhaps all the windows) and getting a real lock on the door or rendering it 

unopenable.... Contrary to what the Wilderness and Backcountry Management Plan asserts, the 

tower is NOT always kept locked. In early May of 2004 the catwalk gate was unlocked and open 

and the door to the cabin was unlocked and open as well. In early May of 2005 the catwalk door 

was down and locked but the cabin door stood wide open. And in October of 2005 we talked to 

hikers who had recently gone past and who said that both the gate and the door were open and 

furniture from the cabin was outside underneath the tower...

6. While dismissed as an option, the Friends indeed prefers the removal of the island's third 

tower, the Ojibway. It is incompatible for a wilderness area to have a 41-foot structure, 

particularly one that is no longer used for its intended purpose, fire monitoring. Leaving one 

tower for administrative purposes is counter to the intent of the Wilderness Act of 1964, which 

defines wilderness as an area of undeveloped Federal land retaining its primeval character and 

influence, without permanent improvements. The Forest Service is able to maintain campsites, 
 274 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

trails, and portages in the Boundary Waters Canoe Area Wilderness without permanent 

structures in the wilderness, and the Park Service should be able to perform comparable duties 

without such structures in Isle Royale's wilderness area. 

RESPONSE

Leaving one tower in place, the Ojibway Tower, allows visitors to see an example of how fire 

towers were placed during the island’s history, while also facilitating current park needs. The 

Ishpeming Tower currently serves no essential administrative purpose for the park, and stands as 

a non-historic permanent artificial structure in the wilderness. Under the Wilderness Act, 

structures that are not essential to the park’s operation should not remain in wilderness areas. 

Since the release of the draft WBMP/DEIS however, a telecommunications study at the park has 

shown that using the Feldtmann Tower may be an alternative to building a new structure for 

radio and telephone transmission equipment. In addition, Feldtmann Tower is used to assist with 

telemetry tracking in certain research projects. If as a result of using the Minimum Tool 

Process, we determine that retaining Feldtmann Tower for either of these uses results in less 

impact to the backcountry than other technological or structural solutions, the park may decide to 

keep Feldtmann Tower intact for administrative purposes. Unless this is the case, the previous 

direction of the park is to remove the tower. This analysis has allowed for review of that 

decision with public comment. 

Vandalism at the towers does occur, despite that fact that the park has tried several different 

potential solutions (everything from leaving them open to locking them). Patrols, repairs, 

keeping gates shut and locked, are all part of management, however the towers’ isolation makes 

enforcement difficult. Enforcement is not the critical question for removal, however: it is the 

need for the tower for administrative purposes and cultural resource values. The park would use 

the Minimum Tool Process and NEPA compliance to determine how to remove one or more 

towers. Dismantling and leaving the structural debris in place is an option that can be evaluated. 

Management concerns with this option would include the chance for visitor injury, and the effect 

of the debris on the wilderness character in the park.
CHAPTER 5: PUBLIC COMMENT AND RESPONSES 275

5.2.6 Picnic Tables

COMMENTS

1. Picnic tables- Either leave in place until they need maintenance and then remove, or remove 

all tables now.

2. We urge that where the Park Service moves forward with removing docks and structures at 

campgrounds, picnic tables should also be removed from those sites.

3. Under this scenario, human use (of picnic tables) will trump that of a remote experience and 

yield a look that more resembles a park than a wilderness area.

4. I therefore propose all picnic tables be removed and in their place I propose that you institute 

a plan to add on to the shelters (which have an wilderness exemption) and make a deck extension 

that would be part of the shelter itself in the front length of the shelter that would go out to within 

2" of the drip line of the overhanging eave. People could sit naturally on this deck as nature 

intended, cook their meals, place gear on it and even sleep out there at night if they so desire. 

This is my natural solution to picnic tables. The deck would be part of the shelter itself and 

exempt from wilderness standards. The upkeep of the shelters would also include the deck. I 

believe it would be a great change that would be acceptable to all.

5. I believe the reason the park is doing this is that the GMP calls for taking out the dock on 

Birch Point and, therefore, the picnic table must go. I find both of these removals unnecessary. 

Such removals would have the effect of taking away a very nice day or half day boat trip and 

picnic place. People of Isle Royale are able to access the beautiful headwaters of Duncan Bay, 

i.e. the "solitude and remoteness" of that location, which is convenient to Tobin and Rock 

Harbors. My family and I have enjoyed numerous excursions to this beautiful spot where we 

have often observed wildlife and birds such as eagles, osprey, loons, and moose in the 

headwaters. Having the dock is a ready shelter in the event of a sudden storm, and the picnic 

table has enabled us and many other visitors to enjoy a picnic in this picturesque place as well as 

a rest afterwards. Children are able to play and cast off the dock for a possible pike.

RESPONSE

Since this draft plan was released, the National Park Service has revised and edited its policy 

with respect to picnic tables: picnic tables will not be allowed in wilderness except in those 

limited circumstances when they are necessary for resource protection and when documented 

and approved by the park through a minimum requirements analysis (NPS Policies, 2006.) The 

park has re-evaluated the placement of picnic tables using the minimum tool guidelines. The 

review included reduction of negative human impacts (compaction, loss of vegetation), as well 

as the impact on wilderness character, and possible design changes to help the tables be less 

noticeable. The Preferred Alternative has been changed to be consistent with NPS policy.

The park does not plan to increase infrastructure in the wilderness, so the alternatives were

limited to maintaining or eliminating picnic tables. Currently visitors have an option of sleeping 
 276 CHAPTER 5: PUBLIC COMMENT AND RESPONSES

in shelters or camping at non-shelter sites. Picnic tables offer a structure on which to place food, 

and a place to sit (a deck is not a comparable amenity.)

Farrel and Marion (1998) found that campsites on Isle Royale with picnic tables were 

significantly smaller in area of disturbance than those without tables. The size, area of 

vegetation loss, and exposed soil for sites with picnic tables were consistently between 100-250 

ft2 smaller than comparable sites without picnic tables. For example, in 1996 the mean size of 

individual campsites with picnic tables was 549 ft2

, compared to 717 ft2 for sites without picnic 

tables. In 2002 the mean size of individual sites with picnic tables was 581 ft2, compared to 831 

ft2 for sites without picnic tables. The presence of picnic tables in campsites appears to 

concentrate physical impacts such as vegetation loss, soil exposure, and total area of a campsite. 

This suggests that picnic tables are effective tools for concentrating physical impacts in 

campsites.

Based on the results of the Minimum Tool flowchart as a decision tool (Appendix I, p. 320), 

retaining picnic tables at the campgrounds listed under the Preferred Alternative is consistent 

with current NPS policy. 

The removal of the dock at Duncan Bay (Birch Point) was a decision made in the 1998 General 

Management Plan, and is not being revisited in the WBMP. (See p. 37 and pp. 34-37 in the 

General Management Plan). However, your comment that the picnic table would be 

automatically removed is incorrect. We will review the continued presence of the existing picnic 

table consistent with the new NPS policy requirements.
GLOSSARY 277

GLOSSARY

Adaptive management: a process for continually improving management policies and practices 

based on monitoring and ongoing assessments of management effectiveness. 

Affected environment: resources expected to experience environmental impacts as a result of a 

proposed action or actions.

Alternatives: Options for different management actions that would be expected to achieve the 

general purpose of a project. For the purposes of this WBMP and EIS, the alternatives propose 

different means of accomplishing park goals, while at the same time protecting or minimizing 

impacts to some or all resources.

Archeological sites: sites containing physical evidence of historic or prehistoric human use of 

an area, including mining, trade, residences, travel routes, and other human activities.

Carrying capacity: as it applies to National Parks, carrying capacity is the type and level of 

visitor use that can be accommodated while sustaining the desired resource and social conditions 

that are consistent with the purpose of a park and its management objectives.

Cultural landscape: geographic areas that include natural and cultural resources and that have 

cultural significance when taken as a whole, including areas associated with a historical event, 

activity, or person and areas that exhibit cultural or aesthetic values.

Cultural objects: Objects of historic or prehistoric cultural significance, including archeological 

artifacts, shipwreck artifacts, and objects remaining from past human uses of an area.

Cultural resources: an aspect of a cultural system that is valued by or significantly 

representative of a culture or that contains significant information about a culture. A cultural 

resource may be a tangible entity or a cultural practice.

Cumulative effects: additive impacts to a particular resource, including impacts in the past, 

present and reasonably foreseeable future. 

Designated wilderness: See Wilderness

EIS: Environmental Impact Statement, which is an examination of a range of federal actions and 

their potential effects on the environment. 

Endangered species: a plant or animal that is in danger of becoming extinct throughout all or 

part of its range and has been listed under the Endangered Species Act by the federal government 

or is listed by the State as endangered, and therefore receives special protection.

Ethnographic resources: resources related to cultural systems or lifestyles that have 

significance to native peoples or historic communities; including prehistoric and historic sites, 

structures, landscapes, fauna and objects as well as natural resources like rivers, watersheds, and 

plant species. 
278 GLOSSARY

General Management Plan (GMP): the broadest level of planning used by the National Park 

Service to provide an overall direction for a park’s future management and a framework for 

managers to use when making decisions about things such as park resources, visitor use, and 

facilities. 

Historic property: a district, site, structure, or landscape that is significant in American history, 

architecture, engineering, archeology, or culture; an umbrella term for all entries in the National 

Register of Historic Places.

Impacts: effects, both beneficial and adverse, of an action on the environment. Direct effects are 

those occurring at the same time and place as the action. Indirect effects occur later in time or are 

farther removed in distance from the action, yet are reasonably foreseeable. 

Impairment: an impact that, in the professional judgment of the responsible NPS manager, 

would harm the integrity of park resources or values, including the opportunities that otherwise 

would be present for the future enjoyment of these resources or values. Whether an impact meets 

this definition depends on the particular resources and values that would be affected; the 

severity, duration, and timing of the impact; the direct and indirect effects of the impact; and the 

cumulative effects of the impact in question and other impacts. 

Minimum Tool: the management actions, administrative practices, proposed special uses, 

scientific activities, and equipment used in wilderness that would have the minimum impact on 

wilderness character and resources, with economic efficiency and convenience given 

significantly less weight. If a compromise of wilderness resources or character is unavoidable, 

only those actions that preserve wilderness character and/or have localized, short-term adverse 

impacts will be acceptable. 

Mitigation: an activity designed to avoid, minimize, rectify, eliminate, or compensate for the 

impacts of a proposed project. A mitigative measure should be a solution to an identified 

environmental problem. 

Monitoring: a systematic means of measuring resource and social conditions repeatedly over 

time to evaluate whether existing conditions or the nature of changing conditions meet 

management goals.

National Environmental Policy Act (NEPA): This act requires full disclosure of the impacts 

that would result from a proposed federal action that would have a major effect on the quality of 

the environment.

National Register of Historic Places: The comprehensive list of districts, sites, buildings, 

structures, and objects of national, regional, state and local significance in American history, 

architecture, archeology, engineering, and culture. This list is maintained by the National Park 

Service under authority of the National Historic Preservation Act of 1966.

Natural resources: Things that occur in their natural state—wildlife, water, vegetation, soils, 

etc. Features and values that include plants and animals, water, air, soils, topographic features, 

geologic features, paleontologic resources, natural quiet, and clear night skies. 
GLOSSARY 279

Potential wilderness: lands that were identified in wilderness legislation as qualifying for 

future, but not immediate designation as wilderness due to a temporary, non-conforming or 

incompatible condition. When the non-conforming use ceases these areas would become 

designated wilderness upon determination by the Secretary of Interior. 

Scoping: an publicly open planning process that solicits people’s opinions about the 

management of the park, including their opinions and concerns about the value of the park, 

desired experiences as visitors, desired resource conditions, and appropriate management 

actions. Scoping aids in identifying important issues, defining objectives, and defining a range of 

appropriate alternatives. 

Soundscape: The natural soundscape is the aggregate of al the natural sounds that occur in 

parks, together with the physical capacity for transmitting natural sounds. Natural sounds occur 

within and beyond the range of sounds that humans can perceive, and can be transmitted through 

air, water, or solid materials.

Threatened species: a plant or animal species that is at risk of becoming endangered and has 

been listed under the Endangered Species Act by the federal government or is listed by the State 

as threatened, and therefore receives special protection.

U.S.C.: United States Code contains the general and permanent laws of the United States.

Visitor experience: the perceptions, feelings, and reactions a person has while visiting a park, as 

well as certain conditions that influence the quality of the visitor experience, including the 

condition of natural and cultural resources and visitor services. 

Wilderness: also Designated Wilderness. An area that has been legislatively included within the 

national wilderness preservation system by acts of the Secretary of Interior, a Presidential 

recommendation, and congressional approval, and therefore falls under the legal guidelines of 

The Wilderness Act and policies of the NPS for wilderness management. 

Wilderness character: an often intangible entity consisting of multiple components such as a 

state of naturalness, an untrammeled state, and opportunities for certain human experiences 

including solitude, primitive and unconfined experiences, personal challenge, self sufficiency, 

and an escape from the remainders of out modern society. Wilderness character also denotes a 

human intention with a commitment to the spirit of the intangible wilderness character. 
280 REFERENCES

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285 APPENDICES

APPENDIX A: ENABLING LEGISLATION (March 3, 1931)
APPENDICES 286

APPENDIX B: WILDERNESS LEGISLATION (Oct 20, 1976)
287 APPENDICES
APPENDICES 288

APPENDIX C: DETERMINATION OF IMPAIRMENT

Isle Royale National Park Wilderness and Backcountry Management Plan / EIS

A determination of impairment is made for each of the resource impact topics carried forward 

and analyzed in the environmental impact statement for the preferred alternatives. The 

description of the park significance in Chapter 1 was used as a basis for determining if a resource 

is: 

• necessary to fulfill specific purposes identified in the establishing legislation or 

proclamation of the park, or 

• key to the natural or cultural integrity of the park or to opportunities for 

enjoyment of the park , or

• identified in the park’s general management plan or other relevant NPS planning 

documents as being of significance. 

Impairment determinations are not necessary for visitor experience, socioeconomics, public 

health and safety, environmental justice, land use and park operations, etc., because impairment 

findings relate back to park resources and values. These impact areas are not generally 

considered to be park resources or values according to the Organic Act, and cannot be impaired 

the same way that an action can impair park resources and values. 

NATURAL RESOURCE TOPICS

Geology & Soils

The geologic history of Isle Royale began roughly 1.2 billion years before the present. Over 

millions of years a series of lava flows built a lava bed 10,000 feet thick which then began to 

bend at the sides forming the Lake Superior basin. The soils of Isle Royale have been strongly 

influenced by the underlying bedrock topography and by the last glacial advance. They were 

later modified by higher lake levels and eolian deposits. In general, the upland soils are loamy in 

texture, have a high percentage of coarse fragments and are relatively shallow to bedrock. The 

lowland soils of the island are found in the valley portion of the ridge-valley landscape of the 

island. They are dominantly very poorly drained and were either formed from woody or 

herbaceous vegetation or a combination of the two. Most of the soils at Isle Royale are very 

sensitive to disturbance, with erosion being the main concern on the shallow upland soils, and 

soil displacement (rutting) or instability being common on the lowland soils.

 

Soils and their microhabitats are known to be affected by recreation use and construction and 

maintenance of trails and campgrounds. Geologic features may have scientific, historic, and/or 

aesthetic significance. Potential adverse impacts include general disturbance, loss of ground 

cover, compaction of soil, alteration of geologic features, and erosion. Actions in the preferred 

alternatives would result in negligible and short-term adverse impacts to the soils associated with 

the construction of one additional campsite at North Desor campground and a day use hiking 

trail near Windigo. Minor, localized soil impacts may also be expected where campfire rings are 

installed as social trails are likely to develop at these sites. Rotation of campfire rings to 
289 APPENDICES

different campgrounds should mitigate these adverse impacts. A long-term beneficial impact is 

expected by retaining picnic tables in campgrounds where currently present by concentrating soil 

erosion around the area immediately adjacent to the picnic table. Because these impacts are 

short-term, slight, and localized, the preferred alternatives would not result in impairment. No 

impacts to geologic resources are expected. 

Aquatic Resources

The diverse fishery of Lake Superior and inland waters of Isle Royale represent one of the most 

nationally significant natural resources in the park. The importance of the park’s native fishery 

is highlighted as a park significance statement in the General Management Plan (GMP, 1999), 

“Park waters contain the most productive native fishery and genetically diverse lake trout 

populations in Lake Superior. The lake trout is recognized as the best example of a rehabilitated 

lake trout population in Lake Superior. The coaster brook trout population, considered to be 

rare, is one of two known reproducing populations in U.S. waters. Twenty-eight species of fish, 

including sub-species of the whitefish, fathead minnow, striped-nose shiner and pearl dace have 

been recorded. The fisheries provide an outstanding opportunity for recreational fishing for 

many park visitors. 

Isle Royale is known to be rich in aquatic resources with 42 named lakes, and 233 kilometers of 

perennial streams. Isle Royale’s inland lakes harbor an abundant and healthy assemblage of 

fresh water mussels and sponges not readily seen elsewhere within the region. Additionally, 

shoreline splash pools along the Lake Superior shoreline of the northeastern portion of the park 

have garnered considerable scientific attention because of their ecological simplicity, ecological 

interactions and population dynamics of boreal chorus frogs, blue spotted salamanders and 

dragonflies. 

NPS policies require protection of water resources consistent with the federal Clean Water Act. 

Over 75% of Isle Royale’s acreage is water that includes Lake Superior and many lakes, bogs, 

ponds, marshes, and streams. Human activities in campgrounds and along the trails adjacent to 

lakes and streams on Isle Royale could impact aquatic resources through soil erosion or 

introduction of contaminants or invasive exotic aquatic species. Healthy fisheries, and aquatic 

resources and their associated communities are necessary to fulfill the purposes for which Isle 

Royale was established and essential to the natural integrity and preservation of the park’s 

ecosystem. Those actions outlined in the preferred alternatives are not expected to impact 

aquatic resources and therefore, will not result in impairment. 

Wetlands and Floodplains

Presidential Executive Orders mandate floodplain management and protection of wetlands. 

There is an estimated 7,000 hectares of wetlands in the park. These wetlands support numerous 

wetland taxa, several of which are Endangered, Threatened, or of Special Concern as listed by 

the State of Michigan. Furthermore, it is believed that the aquatic plant communities in Isle 

Royale wetlands may have been considerably altered due to intense moose herbivory. Numerous 

wetlands, including marshes, bogs, and vegetated lakes and pond shores, support considerable 

biodiversity and in addition to providing areas for unique groups of plants, wetlands provide 
APPENDICES 290

required food, habitat, and cover for fish, birds, mammals, and a host of invertebrates. Actions 

outline in the preferred alternatives mainly take place in upland habitat or sufficient distance 

from shorelines. As such, the preferred alternatives would not result in impairment to wetlands. 

Vegetation

Isle Royale is located at the ecotone or transition zone between the boreal and northern 

hardwood forest ecosystems. The southwestern end of the island completes the northern extent 

of the hardwood forest and is populated by sugar maple, yellow birch and to a lesser degree, red 

oak. The white spruce and balsam fir forest form the southern limit of the boreal forest. Its 

vegetative communities and rare plant species are among its most important assets. Isle Royale 

has over 700 vascular plant species—24 kinds of trees, 28 species of ferns, 32 varieties of 

orchids, over 100 types of forbs and grasses, and 40 species of lichens (non-vascular). There is 

also one endemic plant, the Isle Royale ragwort. The southern shoreline of the northeastern 

portion of Isle Royale is home to several species of arctic-alpine disjunct plant species. Forest 

succession is greatly influenced by moose herbivory and secondarily, the activities of beaver. 

The preferred alternatives would result in primarily long-term, moderate beneficial impacts by: 

reducing campground overcrowding, maintaining low visitation in spring when wet conditions 

increase trail widening and thus vegetation impacts, and rotating campfire rings and retaining 

picnic tables to concentrate visitor impacts. Long-term minor adverse effects would be realized 

with the construction of a new campsite at North Desor and a new hiking trail near Windigo. In 

total, these impacts would not result in impairment. 

Terrestrial Wildlife

The isolation of Isle Royale affects the relatively simple ecosystem and limits the potency of 

human influences. Many species common to the mainland, a little over 20 miles away, are not 

found on Isle Royale. With just 18 mammalian species, the principles and paradigms of island 

biogeography are at work on the island. Less affected by isolation, greater than 200 bird species 

have been documented. Notably, the park is home to an estimated one third of the statethreatened common loon population with greater than 100 breeding pairs. This simplified 

ecosystem is accentuated by the paucity of reptiles, only 3 species, and amphibians, 9 species. 

Human activities are known to impact wildlife species and possible impacts from recreation and 

other human activities in the park’s wilderness and backcountry include habitat fragmentation, 

displacement of wildlife, and habituation to humans. Construction of the trail near Windigo and 

the additional campsite at North Desor could have long-term, moderate adverse impacts but 

minor impacts are projected at the population level. Long-term beneficial impacts are expected 

by the concentration of visitor activities around campfire rings and picnic tables, and the removal 

of the Feldtmann and Ispheming Fire Towers. However, long-term, minor adverse impacts to 

wildlife may be associated with the collection of campfire wood (e.g., tree damage, social trails, 

loss of woody debris adjacent to the campfire). Because the preponderance of impacts are minor 

to moderate and not expected to impact any species at the population level, actions associated 

with the preferred alternatives would not result in impairment. 
291 APPENDICES

Threatened and Endangered Species

The federal Endangered Species Act prohibits harm to any species of fauna or flora listed by the 

U. S. Fish and Wildlife Service (USFWS) as being either threatened or endangered. Such harm 

includes not only direct injury or mortality, but also disturbing or destroying the habitat on which 

these species depend. One federally threatened species – the grey wolf – inhabits Isle Royale. 

The Michigan Department of Natural Resources also publishes a list of species threatened and 

endangered within the state. NPS policies require that parks manage state and locally listed 

species “in a manner similar to its treatment of federally listed species, to the greatest extent 

possible” (NPS 2006 p. 35). Among state-listed animal species occurring on Isle Royale are the 

moose, common loon, and osprey. Over 75 state-listed plant species are also documented in the 

park.

Viable populations of special status species are necessary for the park to fulfill its mandates 

prescribed by policy. Moreover, viable populations perform critical ecosystem services and are 

key to the natural integrity of the park. Actions in the preferred alternatives are not expected to 

impact threatened or endangered species. Prior to implementation, surveys and habitat 

assessments will be completed to determine presence, particularly plant species, and potential 

impacts and mitigations for special status species. Long-term, moderate beneficial impacts will 

be realized by concentrating visitor use with campfire rings and picnic tables, and the removal of 

two fire towers. As such, the preferred alternatives would not result in impairment. 

Natural Sights and Sounds

NPS management policies call for the preservation of, “to the greatest extent possible, the natural 

soundscapes of parks” (NPS 2006, p.44). Additionally, the preservation of wilderness character 

and values includes the preservation of natural sights and sounds, minimizing the visual and 

noise intrusions of modern human activities. Development, facilities, and tools for park 

maintenance and administration can impact the sights and sounds of the park, and some of the 

proposed alternatives could alter the current state of natural sights and sounds in Isle Royale’s 

wilderness and backcountry. Because of its isolation, the natural sights and sounds on Isle 

Royale are only minimally impacted by boat and commercial airplane traffic, and a visitor has 

opportunities to experience the call of a wolf or loon, the distinct rustling of wind through aspen 

trees, and the awesome power of a storm on Lake Superior. These and other natural sights and 

sounds expected in a Northwood’s environment are preserved at the park in large part by the 

island’s isolation and secondarily the lack of development. 

Preservation of natural sights and sounds on Isle Royale are necessary to fulfill the purposes for 

which the park was established. Although chainsaw use, an action common to all alternatives 

analyzed, will in some ways help preserve other resources from impacts, continued use in the 

park will have moderate impacts on the soundscape. These impacts will be mitigated by the 

continued practice of not permitting chainsaw use in the wilderness areas of the park from midJune through mid-September, as well as, the goal of increasing crosscut use. Because the nature 

of chainsaw use is high level, short-term and localized, the preferred alternatives will not 

constitute impairment. No other actions outlined in the preferred alternatives are expected to 

adversely impact the natural sights and sounds of Isle Royale. 
APPENDICES 292

CULTURAL RESOURCE TOPICS

Archeological Sites

The earliest evidence of human use of the island is found in the 186 designated archeological 

sites documented in the park. These sites include copper mining pits, native/European contact 

and trade sites, historic settlements and lighthouses. Archaic period peoples (approximately 2500 

to 1000 BC) are connected to at least twelve identified archeological sites. Initial (1000 BC to 

700 AD) and Terminal or Late (600 – 1650 AD) Woodland people are associated with many 

more sites. In all more than 1000 mining pits scattered throughout the park are attributed to these 

native groups.

The Minong Mine site is presently listed on the National Register of Historic Places and the 

majority of the other 186 archeological sites have been recommended for nomination. These sites 

contain potential information about the island’s earliest uses and may be determined eligible for 

the National Register.

Archeological sites also contain historic remnants along with prehistoric evidence. Mining pits 

and settlements and lighthouse-associated sites have all been identified from the historic period.

Fur trade and Native/European contact goods have been found in various places. Many historic 

activities such as commercial fishing and fur trading occurred on or near prehistoric sites.

Many known archeological sites have been identified as a result of NPS trail and campsite 

construction. The location of campgrounds – primarily along the coast of Lake Superior and the 

inland lakes – is also the natural location of historic and prehistoric activity. Noting that the Lake 

Superior basin has featured numerous shorelines over the past 10,000 years, there is reason to 

believe that some of the archaeological contexts are now submerged. Additionally, much of the 

park’s interior has not been surveyed and may contain numerous undiscovered sites. 

Shipwreck sites and other submerged cultural features are now preserved as submerged 

archaeological sites in the park, and 10 of the wrecks are listed on the National Register of 

Historic Places.

Under the preferred alternative, archaeological features (terrestrial and submerged) would 

continue to be surveyed, inventoried and evaluated under National Register of Historic Places 

criteria, and the National Park Service would implement resource management policies that 

preserve the natural resource values and culturally significant archaeological settings and 

contexts that have been listed, or determined eligible. Some slight impacts from visitation could 

occur if visitation to archaeological sites were to increase or if the Windigo day use hiking trail

and North Desor campground installations are situated in archaeological settings. However, 

because of protective efforts and continued monitoring, the preferred alternatives would not 

result in impairment to these resources. 

Historic Structures

The park contains approximately 180 structures that are more than 50 years old, most of which 

are located within the park’s wilderness and backcountry. These structures are from the various 
293 APPENDICES

historic eras of island use and development. Some of the structures are representative of the 

island’s maritime heritage, such as lighthouses and fishery sites. Many cabins, hotels and 

associated buildings are from the resort era and the early development of the park idea at Isle 

Royale.

Three of the four lighthouses within the boundaries of Isle Royale National Park are listed on the 

National Register of Historic Places. The 1855 Rock Harbor Lighthouse is the oldest existing 

structure in the park and under NPS jurisdiction. Control of the three additional lighthouses (Isle

Royale Lighthouse at Menagerie Island, Passage Island Lighthouse and Rock of Ages

Lighthouse) is in the process of being transferred from the Coast Guard to Isle Royale National 

Park. Two of these structures, Isle Royale and Rock of Ages, are listed on the National Register, 

while the Passage Island Lighthouse has been determined eligible but has not yet been 

nominated.

Two other locations are also listed on the National Register - the Edisen Fishery in Rock Harbor 

and Johns Hotel in Washington Harbor. Together these locations have a total of thirteen 

structures listed on the Register. While these are the only structures currently listed on the

Register, the Michigan State Historic Preservation Officer (SHPO) has declared another 

approximately 145 additional structures eligible for listing.

The Edisen Fishery is only one of the many sites used as commercial fishing camps. For a 

century, from the 1830s until the establishment of the National Park, Isle Royale was a base for 

commercial fishing. Other sites include Wright Island, Crystal Cove, Fisherman’s Home, 

Barnum Island and Washington Island. At many of these sites buildings (fish houses, net houses 

and cabins) along with boats and docks remain intact. However, with the exception of the

Edisen Fishery, the fishermen are gone and at several of the historic fishing camps the buildings 

are rapidly deteriorating.

Many of the summer cabins built during the resort era remain, some of them still occupied by the 

families of the original occupants. Eight life leases are currently in effect, as are five Special Use

Permits issued to the children of lessees. Most of these leases and permits are for cabins in Tobin 

Harbor. Some historic buildings (including former lessee cabins and Civilian Conservation Corps 

facilities) have been converted to park use. Volunteer-in-Park agreements help the park manage 

the difficult task of maintaining this array of historic structures. Many of these structures are 

located in potential wilderness additions.

Although the three firetowers are not historic and therefore not eligible for listing on the National 

Register, they are important reminders of previous management activities on Isle Royale. Since 

three like-examples presently exist, it would be beneficial to retain at least one for interpretive 

purposes along with any benefit to the administration fo the park (i.e., communications). 

The historic structures of Isle Royale are valuable resources that convey varied aspects of human 

presence on the island and are key to the cultural integrity of the park. The actions in the 

preferred alternatives would result in impacts on historic structures and buildings that would be 

long-term and generally minor. Because the adverse impacts would be minor, and because many 
APPENDICES 294

similar examples are present island-wide, the preferred alternatives would not result in 

impairment. 

Cultural Objects

Many of the archeological items found at Isle Royale are kept at the Midwest Archeological 

Center in Lincoln, Nebraska. Isle Royale’s own museum collection is housed in a new storage 

facility in Houghton. This collection contains a general representation of the island’s cultural and 

natural resources. Shipwreck artifacts, commercial fishing gear and household goods, summer 

home items and archeological artifacts are all part of the collection. The majority of archives and 

artifacts located in the park are found at Mott Island, with a few items kept at the Rock Harbor 

and Windigo Visitor Centers, the Edisen Fishery and Rock Harbor Lighthouse.

Under the preferred alternative, cultural objects would continue to be researched, collected and 

stored with no foreseeable increase or decrease in number. A slight chance exists that the 

installations of the Windigo loop trail and North Desor campground may result in the discovery 

of archaeological material; however, related objects would likely be scant and therefore of no 

consequence to the Park’s collection facilities. Because there would be no adverse effects on 

cultural objects, the preferred alternatives would not result in impairment. 

Cultural Landscapes

Cultural landscapes are geographic areas of the park that include natural and cultural resources 

and that have cultural significance when taken as a whole. This includes areas associated with an 

historical event, activity or person and areas that exhibit cultural or aesthetic values. The cultural 

landscape program at Isle Royale is new. Currently, only the Edisen Fishery, Rock

Harbor Lighthouse, Barnum/Washington Island, Fisherman’s Home and Crystal Cove have been 

identified as cultural landscapes, but several other areas around the park need to be evaluated for 

cultural significance. With control over the remaining lighthouses (Isle Royale, Rock of Ages 

and Passage Island) being transferred to the NPS these sites should be evaluated as cultural 

landscapes.

The summer cottages area of Tobin Harbor has the potential to be recognized as a cultural 

landscape. Many of the original cottages remain, including several that are still occupied by the 

families who owned the land when Isle Royale became a National Park. Two of the summer 

cottages in Tobin Harbor are being preserved and used by the NPS, one for the artist-in-residence 

program and one as an employee residence. Tobin Harbor with its protected waters and many 

small islands was a popular choice for resort-era families looking to build a cottage at Isle 

Royale. It is the best-preserved example of the summer cottage community at Isle Royale, and 

may require evaluation in the context of a cultural landscape.

Washington Harbor also had summer cabins but was better known for its thriving commercial 

fishing community. During the 1920s and 1930s over 20 fishing families lived in Washington 

Harbor. The entire harbor area should be evaluated for possible cultural landscape status. Aside 

from Edisen Fishery, the best-preserved examples of commercial fishing are Crystal Cove at the 

Northeast End of Amygdaloid Island and Fisherman’s Home in Siskiwit Bay. These sites retain a 
295 APPENDICES

high degree of historical integrity and are mentioned in the General Management Plan as high 

priorities for restoration efforts. Other fishing sites on the north shore of the park should also be 

considered for cultural significance. These sites should all be evaluated as cultural landscapes.

Historic mining sites, including mine shafts, rock piles, partial structures, dams, stamp sand, 

wells, roads, and tramway remains have the potential for cultural significance. Locations to be 

evaluated as cultural landscapes include Siskowit Mine, Minong Mine, Island Mine, Wendigo 

Mine and Todd Harbor’s Pittsburg and Isle Royale Mine.

Under the preferred alternative, potential landscapes would continue to be surveyed, inventoried 

and evaluated under National Register of Historic Places criteria, and the National Park Service 

would implement resource management policies (forthcoming Cultural Resource Management 

Plan) that preserve the natural resource values and culturally significant character-defining 

patterns and features of listed, or determined eligible, landscapes. Some slight impacts from 

visitation could occur if visitation to cultural landscapes were to increase. Because of protective 

efforts and continued monitoring, the preferred alternatives would not result in impairment. 

Ethnographic Resources

Ethnographic resources have significance to native peoples or historic island communities and 

include prehistoric and historic sites, structures, landscapes, fauna and objects as well as natural 

resources like rivers, watersheds and plant species. At present few ethnographic resources have 

been documented at Isle Royale National Park. The only detailed ethnographic study completed 

so far has been that of the culture of Scandinavian commercial fisherman in the first half of the 

twentieth century. A study of the vernacular boat-building traditions of the fisherman has 

documented their cultural traditions and use of island resources.

The NPS has documented hundreds of plant species used historically or currently by the 

Ojibway/Chippewa Indians. The occurrence and distribution of these plants at Isle Royale is 

unknown. A known example of an ethnobotanic species significant to native peoples and found 

at Isle Royale is the sugar maple, used for sugar production and pearly everlasting, which was 

medicinal. It is possible that the Ojibway people of the north shore of Lake Superior still use the 

island’s resources; however, the park staff has no knowledge of such use. It is likely that 

additional ethnographic resources exist in the park.

Under the preferred alternative, potential ethnographic resources would continue to be 

researched and evaluated under National Register of Historic Places criteria. Because there 

would be no known adverse effects on the existing ethnographic resources, the preferred 

alternatives would not result in impairment. 

Summary

As described above, adverse impacts anticipated as a result of implementing the preferred 

alternatives on any resource or value whose conservation is necessary to fulfill specific purposes 

identified in the establishing legislation or proclamation of the park, key to the natural or cultural 

integrity of the park or to opportunities for enjoyment of the park, or identified as significant in 

the park’s general management plan or other relevant NPS planning documents, would not rise 

to the levels that would constitute impairment. 
APPENDICES 296

APPENDIX D: MAPS

Map 1: Region

Map 2: Wilderness Designation at Isle Royale National Park

Map 2b: Wilderness Designation at Isle Royale National Park - East

Map 3: Wilderness and Backcountry Facilities 

Map 4: Potential New Campgrounds (Alternative C for Overnight Use)

Map 5: Potential New Trail (Alternative C for Day Use)

Map 6: Management Zones
Sleeping Bear Dunes 

National Lakeshore

Isle Royale

National Park

Apostle Islands

National Lakeshore

Voyageurs National Park

St.Croix

National Scenic

River

Pictured Rocks 

National Lakeshore

Thunder Bay

Port Arthur

Sault Ste. Marie

Wausau

Duluth

Alpena

Superior

Green Bay

Marquette

Eau Claire

Traverse City

Sault Ste. Marie

Houghton

Grand Portage

Copper Harbor

Map 1: Region

0 25 50 100 150

Miles

0 25 50 100 150 200

Kilometers

Key

City

Ferry access

Ferry route

International boundary

Wilderness Area

Federal Agency

Bureau of Indian Affairs

Fish & Wildlife Service

Forest Service

National Park Service

Canadian Parks

National Park

Provincial Park

Limited Access

Highway

297

__________________________________________________________________________________________________________________________________

APPENDICES
Windigo

Rock of Ages Island

Barnum Island

Washington Island

Malone Bay

Siskiwit Bay

Wright Island

Johns Island

Fisherman's Home

Key

Trail

Inland Lake

Non-Wilderness

Potential Wilderness

Wilderness

Lake Superior

Map 2a: Wilderness Designation (West)

0 2.5 5

Miles

0 2.5 5 10

Kilometers

Johns Island

Washington Island

Washington Harbor Detail

APPENDICES

__________________________________________________________________________________________________________________________________

298
Rock Harbor

Blake Point

Rock Harbor Lighthouse \ Edisen Fishery

Belle Isle

McCargoe Cove

Three Mile

Moskey Basin

Daisy Farm

Mott Island

Newman Island

Davidson Island

Captain Kidd Island

Amygdaloid / Crystal Cove

Passage Island

West Caribou Island

Johnson Island

Amygdaloid Island

Tobin Harbor

Edwards Island

Key

Trail

Inland Lake

Non-Wilderness

Potential Wilderness

Wilderness

Lake Superior

Map 2b: Wilderness Designation (East)

0 2.5 5 10 15

Miles

0 2.5 5 10 15 20

Kilometers

Edwards Island

Tobin Harbor

Rock Harbor

Blake Point

Scoville Point

Tobin Harbor Detail

299

__________________________________________________________________________________________________________________________________

APPENDICES
Map 3: Wilderness and Backcountry Facilities

0 2.5 5 10 15

Miles

0 5 2.5 10 15 20

Kilometers

Key

Ranger Station

Fire tower

Lighthouse

Dock

Campsite

No group facilities, fires not allowed

No group facilities, fires allowed

Group facilities, fires not allowed

Group facilities, fires allowed

GMP-approved new campsite

Trail

Passage Island

0 0.5 1

Kilometers

APPENDICES

__________________________________________________________________________________________________________________________________

300
Map 4: Potential New Campgrounds (Alternative C for Overnight Use)

Tobin Harbor

Threemile

Campground

Tookers Island

Campground

Tallman I

PROPOSED

CAMPGROUND

AREA

PROPOSED

CAMPGROUND

AREA

East Caribou I

West Caribou I

Mott I

Caribou Island

Campground

Chickenbone Lake

Lake Livermore

PROPOSED

CAMPGRO

PROPOS

UND AREA

ED

CAMPGROUND AREA Chickenbone

East

Campground

Chickenbone

West

Campground

Rock Harbor

PROPOSED CAMPGROUND AREA

PROPOSED CAMPGROUND AREA

Rock Harbor

Lake Superior

Lake Lesage

A

C

B

A

B C

301

__________________________________________________________________________________________________________________________________

APPENDICES
Map 5: Potential New Trail (Alternative C for Day Use)

0 0.5 1

Miles

0 0.5 1

Kilometers

Key

Proposed Trail

Ranger Station

Dock

Campsite

No group facilities, fires not allowed

Group facilities, fires not allowed

Existing Trail

Developed

Frontcountry

Wilderness Portal

Backcountry

Primitive

Pristine

Lake Superior/Park Boundary

Wilderness zones

Non-Wilderness

Wilderness

PROPOSED TRAIL

PROPOSED TRAIL

Beaver I Beaver

Island

Campground

Washington

Creek

Campground

Greenstone Ridge Trail

Nature Trail

Windigo 

Visitor's

Center

indigo 

Visitor's

Center

Feldtmann Trail

APPENDICES

__________________________________________________________________________________________________________________________________

302
Key

Campsite

GMP-approved campsite

Developed

Frontcountry

Wilderness Portal

Backcountry

Primitive

Pristine

Inland Lake

Quiet/No wake zone

Lake Superior/Park Boundary

Map 6: Management Zones

0 2.5 5 10 15

Miles

0 5 2.5 10 15 20

Kilometers

303

__________________________________________________________________________________________________________________________________

APPENDICES
APPENDICES 304

APPENDIX E: ISLE ROYALE NATIONAL PARK BACKCOUNTRY CAMPING 

REGULATIONS

1. Fires are permitted only in designated grills and metal fire rings as indicated on your 

permit. Use only dead and down wood.

2. Carry out all of your trash and litter, including cigarette butts and foil. Burning trash, or 

discarding trash or litter into pit toilets, is prohibited.

3. In campgrounds, tents must be pitched in designated sites only. Tents are prohibited in 

shelter sites.

4. Cross-country camping is permitted only if pre-registered with Park Ranger for zone and 

date on permit. Special rules apply.

5. Never feed wildlife. Keep a clean camp. Keep wildlife away from food and garbage and 

vice-versa.

6. Keep all soap- even biodegradable soap- out of lakes and streams. Do all washing and 

bathing at least 100’ away from water's edge.

7. Where there is no fish cleaning station, cut remains into small pieces and dispose in deep 

water (>50 ft depth in Lake Superior and as deep as possible in inland lakes.) If disposal 

by boat is not possible, move at least 200 feet from campground and throw remains out 

into deep water.

8. Dogs, cats, and other domestic mammals are prohibited on the land and waters of Isle 

Royale National Park.

9. Quiet hours are between 10 p.m. and 6 a.m Eastern Time. During this time, generators are 

prohibited. Special rules apply in Quiet/No Wake Zones. 

10. When fishing on inland lakes use artificial lures and barbless hooks only. On Lake 

Superior, a Michigan fishing license is required.

11. Streams and creeks are open for fishing with barbless hooks from the last Saturday in 

April through Labor Day. Special rules apply for Brook Trout-amended in 2005.

12. Possession of fish filets is prohibited, unless filets are being prepared for immediate 

consumption. 

13. Groups (7-10 people) must have advanced camping registration and follow the itinerary 

specified on the permit.

14. Removing, disturbing, or possessing living or dead wildlife or parts of them (such as 

antlers), or plants, is prohibited. Disturbance of paleontological specimens, or any 

cultural or archeological resources, is prohibited. Collecting and removing mineral 

resources such as agates, datolite, or greenstones, including those in Lake Superior, is 

prohibited. 

My signature below signifies that I understand and agree that my party/group will abide 

by these conditions and other regulations specified in park brochures and posted at park 

ranger stations. Trip leaders and/or participants can be cited for violating these conditions 

and regulations.

Signature of Trip Leader ____________________________________________________ 
305 APPENDICES

APPENDIX F: ISLE ROYALE NATIONAL PARK CROSS-COUNTRY CAMPING 

REGULATIONS

CROSS-COUNTRY CAMPING PERMIT

Isle Royale National Park

US Department of Interior, National Park Service

Cross-country campers are required to follow special regulations designed to protect the 

park’s wilderness resources and visitor experiences. All trip participants should practice 

Leave No Trace ethics and must understand and observe the following cross-country 

camping regulations:

1. Individual parties of 1-6 only are permitted to camp in cross-country areas.

2. Camping is permitted only in zones identified on your camping permit and the attached 

cross-country zone map.

3. All islands on inland lakes and islands in Lake Superior (excluding the main island of Isle 

Royale) are closed to cross-country camping.

4. Your campsite must be at least 1⁄4 mile away from any trail and at least 1⁄2 mile away from 

all developed areas, designated campgrounds and fire towers.

5. Your campsite must be at least 200 feet (or 75 paces) away from all bodies of water, and 

out of sight of the water. You must also camp out of sight and sound of other crosscountry campers.

6. Maximum stay at any one location is one night. Tents and camping gear must be moved 

at least 1⁄2 mile from the previous night’s stay.

7. No fires are permitted.

8. Carry out all of your trash.

Special fishing regulations:

• Artificial lures and barbless hooks only on all inland lakes and streams. 

• Brook Trout/Coaster Brook Trout – Catch and release only. No possession allowed.

Complete fishing regulations listed in park newspaper.

My signature below signifies that I understand and agree that my party will abide by these 

regulations. Trip leaders and/or participants can be cited for violating these regulations 

and conditions:

Signature of Trip Leader ____________________________________________________ 

Cross-country camping is intended for those seeking a higher level of solitude, adventure, 

self-sufficiency, and low impact camping in a wilderness setting. Cross country camping is not 

intended for overflow camping or to shorten travel between campsites, and is recommended for 

experienced backpackers or paddlers who are familiar with Isle Royale. The terrain is rough, 

there are many swamps and the vegetation is thick. Day hiking off trail may be a preferred 

alternative for those who haven’t cross-country camped before. 
Form Revised 2011, ISRO

$33(1',;*ISLE ROYALE NATIONAL PARK 

MINIMUM REQUIREMENT DECISION GUIDE

Phase I: Is Administrative Action Necessary?-The Minimum Requirement

What is the problem/issue that may require administrative action"(Briefly describe below.) 

 

 *Emergency: a situation that involves

 inescapable urgency and temporary need

 for speed beyond that available by

 primitive means (For example: loss of

 human life or serious injury, law enforce- 

 ment efforts involving serious crime or

 fugitive pursuit, retrieval of the deceased,

. fire suppression).

 NOTES:

 

 

 

 

 "In our culture, when everything new is automatically

 assumed to be better, it is considered a kind of

 blasphemy to argue for traditional ways of doing things.

 But sometimes the old ways are the best ways. Sometimes 

 we need to be gloriously impractical. Sometimes we need 

 to find the soul in things before we can find the soul in 

 ourselves." Jerry Dennis, Canoe Magazine-1993

1) IS THIS AN EMERGENCY?*

Act according to

established search 

and rescue 

procedures.

Briefly explain and 

proceed to Phase II.

2) Is this problem/issue subject to 

valid existing rights?

4) Is there a special provision 

in legislation that allows this 

project or activity?

3) Can the problem/issue be 

addressed outside of 

wilderness?

YES NO

YES NO

YES-Do it 

there!

NO

Proceed to 

Phase II.

APPENDICES

______________________________________________________________________________________________

306
 Form Revised 2011, ISRO

 

PHASE I: IS ADMINISTRATIVE ACTION NEEDED? (continued): The questions 

below are provided to evaluate whether resolving the issue protects wilderness character 

and values identified in the Wilderness Act. Answer the questions in terms of need to 

resolve the issue/problem. If the answer to most of the questions is yes, then the 

issue/problem probably requires administrative action, and Phase II should be 

implemented. Please cKHFN Yes or No and briefly explain to the right of the question.

 

 

 Why/How?

 

Yes No 

 

 Why/How?

 

Yes No

 

 Why/How?

 

Yes No 

 

 Why/How?

 

 

Yes No 

 

 Why/How?

 

Yes No 

 

 Why/How?

 

 

 Yes No

 

2) If the issue/problem is not resolved, or 

action is not taken, will the values of solitude 

or primitive and unconfined types of 

recreation be threatened?

1) If the issue/problem is not resolved, or 

action is not taken, will the natural processes 

of wilderness be adversely affected?

3) If the issue/problem goes unresolved or 

action is not taken, will evidence of human 

manipulation, permanent improvements, or 

human habitation be substantially noticeable?

4) Does addressing the issue/problem or taking 

action protect the wilderness as a whole as 

opposed to a single resource?

5) Does addressing the issue/problem or taking 

action contribute to protection of an enduring 

resource of wilderness for future generations?

6) Is this an issue for reasons other than 

convenience or cost of administration?

“You can measure the soil, water, and trees, but intangibles 

never.” Sigurd F. Olson, Reflections from the North Country

307

______________________________________________________________________________________________

APPENDICES
Form Revised 2011, ISRO

PHASE II: DETERMINING THE MINIMUM TOOL

Identify and describe a range of alternatives including those that utilize traditional tools, 

and non-motorized and mechanized means as well as others. Fill out the questions and 

information below for each alternativeCopy this page for subsequent alternatives.

ALTERNATIVE #____________ Briefly describe alternative below or attach description:

 

 

 

 

1) Does this alternative ensure that wilderness is not

 occupied or modified by humans?

 2) Does this alternative maintain or move wilderness toward 

minimal human influence, within legal constraints?

3) Does this alternative allow wilderness to retain solitude and 

elements of surprise and discovery?

4) Did you ensure that this alternative was not primarily based 

on economy, convenience, comfort, or commercial value?

5) Does this alternative look beyond the short term to ensure 

that future generations will be able to enjoy the benefits of an 

enduring resource of wilderness?

6) Does this alternative support the wilderness resource in its 

entirety rather than maximizing an individual resource within 

the wilderness?

7) Does this alternative recognize the unique character of Isle

of Isle Royale wilderness?

8) Does this alternative ensure that the effects of human activities

do not dominate natural conditions and processes?

 2) Describe the adverse/beneficial effects 

 of this alternative on the following:

 -Biophysical Environment

 

 -Visitor Opportunities and Experiences

 -Societal and Political Concerns

 -Health and Safety Concerns

 -Park Administration and Operations

 -Cultural Resource Considerations

 

3) Evaluate this alternative by answering 

the eight questions to the right. 

Affirmative answers protect and 

preserve the wilderness!

1) &KHFN Yes or No:

Does this alternative involve:

 Use of a temporary road/trail Y N

 Use of motor vehicles Y N

 Use of motorized equipment Y N

 Use of motorboats Y N

 Landing of airplanes Y N

 Landing of helicopters Y N

 Use of mechanical transport Y N

 Creating a structure or installation Y N

 Other impacts to wilderness character

 ________________________ Y N

Briefly describe the adverse/beneficial effects below or attach description:

APPENDICES

______________________________________________________________________________________________

308
Form Revised 2011, ISRO

What is the method or tool that will allow the issue/problem to be resolved or an action to 

be implemented with minimum impacts to the wilderness? 

The Selected Alternative is #________________________________________________. 

 

Prepared By Date Recommended By Division Chief Date

Recommended By Backcountry Management Group (BMG), Chairperson Date

SELECTION OF THE MINIMUM TOOL ALTERNATIVE

Describe the rationale for selecting this alternative:

Describe the specific operating requirements for the action. Include information on timing, locations, 

type of actions, etc. (Use this space or attach a separate sheet)

What are the maintenance requirements?

What standards and designs will apply?

Develop and describe any mitigation measures that will apply?

What will be provided for monitoring and feedback to strengthen future effects and preventative 

actions to taken to help in future efforts?

Approved By Superintendent, Isle Royale National Park Date

309

______________________________________________________________________________________________

APPENDICES
Form Revised 2011, ISRO

PHASE II: DETERMINING THE MINIMUM TOOL - Additional Alternative(s) Worksheet

Identify and describe a range of alternatives including those that utilize traditional tools, 

and non-motorized and mechanized means as well as others. Fill out the questions and 

information below for each alternative. 

ALTERNATIVE #____________ Briefly describe alternative below or attach description:

 

 

 

 1) Does this alternative ensure that wilderness is not

 occupied or modified by humans?

 2) Does this alternative maintain or move wilderness toward 

minimal human influence, within legal constraints?

3) Does this alternative allow wilderness to retain solitude and 

elements of surprise and discovery?

4) Did you ensure that this alternative was not primarily based 

on economy, convenience, comfort, or commercial value?

5) Does this alternative look beyond the short term to ensure 

that future generations will be able to enjoy the benefits of an 

enduring resource of wilderness?

6) Does this alternative support the wilderness resource in its 

entirety rather than maximizing an individual resource within 

the wilderness?

7) Does this alternative recognize the unique character of Isle

of Isle Royale wilderness?

8) Does this alternative ensure that the effects of human activities

do not dominate natural conditions and processes?

 2) Describe the adverse/beneficial effects 

 of this alternative on the following:

 -Biophysical Environment

 

 -Visitor Opportunities and Experiences

 -Societal and Political Concerns

 -Health and Safety Concerns

 -Park Administration and Operations

 -Cultural Resource Considerations

 

3) Evaluate this alternative by answering 

the eight questions to the right. 

Affirmative answers protect and 

preserve the wilderness!

1) Check Yes or No:

Does this alternative involve:

 Use of a temporary road/trail Y N

 Use of motor vehicles Y N

 Use of motorized equipment Y N

 Use of motorboats Y N

 Landing of airplanes Y N

 Landing of helicopters Y N

 Use of mechanical transport Y N

 Creating a structure or installation Y N

 Other impacts to wilderness character

 ________________________ Y N

Briefly describe the adverse/beneficial effects below or attach description:

APPENDICES

______________________________________________________________________________________________

310
311 APPENDICES

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND FAUNA

STATE LISTED PLANT SPECIES OF ISLE ROYALE NATIONAL PARK

COMMON NAME SCIENTIFIC NAME RANK1 2004 STATUS1

 GLOBAL STATE US MI ABUNDANCE

HABITAT(S)

Wild chives Allium schoenoprasum G5 S2 T uncommon

rock shore

Round-leaved orchid* Amerorchis rotundifolia G5 S1 E rare

cedar swamps

Little leaf pussytoes *** Antennaria microphylla

Rosy pussytoes* Antennaria rosea G5 SH T rare

Big leaf sandwort Arenaria macrophylla G4 S1 T rare

mixed woods

Dragon's mouth, Arethusa** Arethusa bulbosa SC rare

bogs

Heart-leaved Arnica Arnica cordifolia G5 S1 E

rocky, mixed forest

Great northern aster Aster modestus G5 S1 T rare

grassy, 

Slough grass Beckmannia syzigachne G5 S2 T rare

gravel shore, 

Low northern rock-cress Braya humilis G5 S1 T

exposed shoreline

Northern reedgrass Calamagrostis lacustris G3Q S1 T rare

rock opening

Narrow-leaved reedgrass**** Calamagrostis stricta G5 S1 T

 rocky shoreline

 1 Source: Michigan State University, Michigan Natural Features Inventory. Michigan’s Special Plants: Endangered, Threatened, Special Concern and 

Probably Extirpated. March 1999.
APPENDICES 312

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND FAUNA (CONT.)

COMMON NAME SCIENTIFIC NAME RANK1 2004 STATUS

GLOBAL STATE US MI ABUNDANCE

 HABITAT(S)

Autumnal water starwart Callitriche hermaphroditica G5 S2 SC rare

aquatic

Calypso orchid Calypso bulbosa G5 S2 T uncommon

boreal forest

Sedge Carex atratiformis G5 S2 T uncommon

rock shore, beaches

Sedge* Carex media G5 S2S3 T frequent

rock shore

Sedge*** Carex norvegica

Richardson sedge Carex richardsonii G4 S3S4 SC

grassland communities

Ross’s sedge Carex rossii G5 S2 T

bedrock outcrops

Eastern paintbrush Castilleja septentrionalis G5 S2S3 T common

aspen woods, rock openings

Purple clematis Clematis occidentalis G5 S3 SC uncommon 

 dry woods

Small blue-eyed mary Collinsia parviflora G5 S2 T rare

rock ridges

Douglas's hawthorn Crataegus douglasii G5 S3S4 SC rare

rock openings

Ram's head lady-slipper Cypripedium arietinum G3 S3 SC rare

boreal forest

American rock brake*** Cryptogramma acrostichoides G5 S2 E uncommon

rock shores & ridges
313 APPENDICES

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND FAUNA (CONT.)

COMMON NAME SCIENTIFIC NAME RANK1 2004 STATUS

GLOBAL STATE US MI ABUNDANCE

 HABITAT(S)

American rock brake*** Cryptogramma crispa

Slender rock brake Cryptogramma stelleri G5 S3S4 SC rare

rock openings 

Wild oat grass Danthonia intermedia G5 S1S2 SC

bedrock shoreline

Rock whitlow-grass Draba arabisans G4 S3 SC uncommon

rock shore &

Smooth whitlow-grass Draba glabella G4G5 S1 E rare

rock shore

Twisted whitlow-grass Draba incana G5 S1 T rare

rock shore

English sundew Drosera anglica G5 S3 SC rare

bogs, rock shore pools

Fragrant cliff woodfern  Dryopteris fragrans G5 S3 SC

Fleabane Erigeron acris G5 SR SC

rocky areas, clearings

Hyssop-leaved fleabane Erigeron hyssopifolius G5 S1 T

fens, swamps

Blue wild rye Elymusglaucus G5 S3 SC

near Lake Superior

Black crowberry Empetrum nigrum G5 S2 T rare

rock shore

Moor rush** ** Juncus stygius G5 S1S2 T

Blue lettuce Lactuca pulchella G5 SH T rare 

openings, burns
APPENDICES 314

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND FAUNA (CONT.)

COMMON NAME SCIENTIFIC NAME RANK1 2004 STATUS

GLOBAL STATE US MI ABUNDANCE

 HABITAT(S)

Auricled twayblade Listera auriculata G3 S2S3 SC rare

boreal forest

Involucred honeysuckle Lonicera involucrata G4G5 S2 T rare

trails

Small-flowered wood-rush Luzula parviflora G5 S1 T uncommon

Plains muhly Muhlenbergia cuspidala G4 SX X

dry bluffs

Mat muhly Muhlenbergia richardsonis G5 S2 T

Water-milfoil Myriophyllum alterniflorum G5 S2S3 SC uncommon

aquatic (inland lks.)

Pygmy water-lily Nymphaea tertagona G5 S1 E rare

stream deltas

Devil's club Oplopanax horridus G4 S2 T uncommon

swamps, openings 

Sweet cicely Osmorhiza depauperata G5 S2 T frequent

mixed woods

Marsh grass-of-parnassus Parnassia palustris G5 S2 T rare

swamps, lake shores

Franklin's phacelia Phacelia franklinii G5 S1 T uncommon

rock openings

Mountain timothy Phleum alpinum G5 SX X

Butterwort Pinguicula vulgaris G5 S3 SC uncommon

rock shore, mossy 

Alpine bluegrass Poa alpina G5 S1S2 T rare

rock shore

Canby's bluegrass Poa canbyi G4G5 S1 E rare

rock outcrop
315 APPENDICES

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND FAUNA (CONT.)

COMMON NAME SCIENTIFIC NAME RANK1 2004 STATUS

GLOBAL STATE US MI ABUNDANCE

 HABITAT(S)

Alpine buckwheat Polygonum viviparum G5 S1S2 T uncommon

rock shore, beaches

Prairie cinquefoil Potentilla pensylvanica G5 S1 T uncommon

rock shore

Macoun's buttercup Ranunculus macounii G5 S1 T rare

swamp forests

Prairie buttercup Ranunculus rhomboideus G4 S2 T uncommon

rock ridges

Gooseberry Ribes oxyacanthoides G5 S3 SC frequent

clearings, beaches

Pearlwort Sagina nodosa G5 S2 T uncommon

rock crevices

Satiny willow Salix pellita G5 S2 SC rare

rock shore

Tea-leaved willow Salix planifolia G5 SH T uncommon

rock shore, islands

*** Salix pyrifolia SC

Encrusted saxifrage Saxifraga paniculata G5 S1 T rare

rock shore

Prickly saxifrage Saxifraga tricuspidata G4G5 S2 T uncommon

rock shore

Rayless mountain ragwort Senecio indecorus G5 S1 T uncommon

rock openings

Awlwort Sublaria aquatica G5 S1 E rare

aquatic

False Asphodel Tofieldia pusilla G5 S2 T uncommon

rock shore pools
APPENDICES 316

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND FAUNA (CONT.)

COMMON NAME SCIENTIFIC NAME RANK1 2004 STATUS

GLOBAL STATE US MI ABUNDANCE

 HABITAT(S)

Downy oatgrass Trisetum spicatum G5 S2S3 SC frequent

rock shore

Dwarf bilberry* Vaccinium cespitosum G5 S1S2 T absent?

Alpine blueberry Vaccinium uliginosum G5 S2 T rare

rock shore

Mountain-cranberry Vaccinium vitis-idaea G5 S1 E extirpated

Squashberry Viburnum edule G5 S2S3 T common

boreal, mixed forests

* Species on rare plant list and state list but not on Slavick and Janke (1993) list.

** Listed by Slavick and Janke (1993) and rare plants list but not on state list. 

*** Species listed by Slavick and Janke (1993) but not on state list or rare plant list.

**** Species listed by Slavick and Janke (1993) and state list. Not on rare plant list.

STATE-LISTED FISH SPECIES OF ISLE ROYALE NATIONAL PARK

COMMON NAME SCIENTIFIC NAME RANK2

 GLOBAL STATE US MI ABUNDANCE

HABITAT(S)

1999 STATUS2

Lake sturgeon Acipenser fulvescens G3 S2 T

Lake Superior

Cisco or Lake herring* Coregonus artedi G5 S3 T

Lake Desor

Siskiwit Lake cisco** Coregonus bartlettii G1Q S1 SC

Siskiwit

 2 Source: Michigan State University, Michigan Natural Features Inventory. Michigan’s Special Animals: Endangered, Threatened, Special Concern 

and Probably Extirpated. July 2004.
317 APPENDICES

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND FAUNA (CONT.)

COMMON NAME SCIENTIFIC NAME RANK 1999 STATUS

 GLOBAL STATE US MI ABUNDANCE

HABITAT(S)

Kiyi Coregonus kiyi G3 S3 SC

Lake Superior

Shortjaw cisco Coregonus zenithicus G2 S2 T

Lake Superior

Spoonhead sculpin Cottus ricei G5 S3 SC

Superior, Inland lakes

*Subspecies

**Species

Fish list taken from "Wildlife of Isle Royale" revised by Dr. Peter Jordon 1981.

STATE-LISTED MAMMAL SPECIES OF ISLE ROYALE NATIONAL PARK

COMMON NAME SCIENTIFIC NAME RANK 1999 STATUS

 GLOBAL STATE US MI ABUNDANCE

HABITAT(S)

Moose Alces alces G5 S4 SC

Gray Wolf Canis lupus G4 S3 LT E

Mammal list taken from "Wildlife of Isle Royale" revised by Dr. Peter Jordon 1981.
APPENDICES 318

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND FAUNA (CONT.)

STATE-LISTED BIRD SPECIES OF ISLE ROYALE NATIONAL PARK

COMMON NAME SCIENTIFIC NAME RANK2 1999 STATUS2

 GLOBAL STATE US MI ABUNDANCE

HABITAT(S)

Cooper's hawk Accipiter cooperii G5 S3S4 SC O,T

Northern goshawk Accipiter gentilis G5 S3 SC R

Short-eared owl Asio flammeus G5 S1 E A,T

Long-eared owl Asio otus G5 S2 T A,T

American bittern Botaurus lentiginosus G4 S3S4 SC R

Red-shouldered hawk Buteo lineatus G5 S3S4 T A

Piping plover Charadrius melodus G3 S1 LE E H

Black tern Chlidonias niger G4 S3 SC A

Lark sparrow Chondestes grammacus G5 SX X A

Northern harrier Circus cyaneus G5 S3 SC O,T

Yellow rail Coturnicops noveboracensis G4 S1S2 T H

Merlin Falco columbarius G5 S1S2 T R

Peregrine falcon Falco peregrinus G4 S1 E A,T

Common loon Gavia immer G5 S3S4 T R

Bald eagle Haliaeetus leucocephalus G4 S4 LT T O

Black-crowned night-heron Nycticorax nyticorax G5 S2S3 SC A

Osprey Pandion haliaetus G5 S4 T O

Black-backed woodpecker Picoides arcticus G5 S2 SC R

Dickcessel Spiza americana G5 S3 SC A

Caspian tern Sterna caspia G5 S2 T A

Common tern Sterna hirundo G5 S2 T O

Yellow-headed blackbird Xanthocephalus G5 S2 SC A

xanthocephalus
319 APPENDICES

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND 

FAUNA (CONT.)

LEGEND FOR BIRDS LIST:

R = regular occurence

O = occasional occurence

A = accidental occurence

H = hypothetical occurence

T = breeds on adjacent mainland

Species list and abundance based on "Wildlife of Isle Royale," revised 1981 by Dr. Peter Jordon.

No listed amphibians or reptiles are known to inhabit Isle Royale. In 1977 there was one 

inconclusive photo taken of what may have been a Black rat snake (Elaphe obsoleta obsoleta) 

which is listed as Special Concern in Michigan.

No comprehensive inventories of insects, snails, or mussels have ever been done for Isle Royale.

LEGEND FOR ALL LISTS

MI Current species status under the Michigan Endangered Species Act reviewed during

2004 1996-98. Endangered and Threatened designations are legally effective as of July 2004.

U.S. Species status under the Federal Endangered Species Act as of July 2004. 

2004 LE, LT (Listed Endangered, Listed Threatened) = Species has been officially listed as 

either Endangered (E), or Threatened (T). P (Proposed) = Species has been officially 

proposed for listing.

( ) Common synonyms of species names accepted by the State Technical Committee.

GLOBAL RANKS

G1 = critically imperiled globally because of extreme rarity (5 or fewer occurrences rangewide or very few remaining individuals or acres) or because of some factor(s) making it 

especially vulnerable to extinction.

G2 = imperiled globally because of rarity (6 to 20 occurrences or few remaining individuals or 

acres) or because of some factor(s) making it very vulnerable to extinction throughout its 

range.

G3 = either very rare and local throughout its range or found locally (even abundantly at some 

of its locations) in a restricted range (e.g. a single western state, a physiographic region in 

the East) or because of other factor(s) making it vulnerable to extinction throughout its 

range; in terms of occurrences, in the range of 21 to 100.

G4 = apparently secure globally, though it may be quite rare in parts of its range, especially at 

the periphery.

G5 = demonstrably secure globally, though it may be quite rare in parts of its range, especially 

at the periphery.
APPENDICES 320

APPENDIX H: ISLE ROYALE NATIONAL PARK STATE-LISTED FLORA AND 

FAUNA (CONT.)

GH = of historical occurrence throughout its range, i.e. formerly part of the established biota, 

with the expectation that it may be rediscovered (e.g. Bachman's Warbler).

GU = possibly in peril range-wide, but status uncertain; need more information.

GX = believed to be extinct throughout its range (e.g. Passenger Pigeon) with virtually no 

likelihood that itwill be rediscovered.

STATE RANKS

S1 = critically imperiled in the state because of extreme rarity (5 or fewer occurrences or very 

few remaining individuals or acres) or because of some factor(s) making it especially 

vulnerable to extirpation in the state.

S2 = imperiled in state because of rarity (6 to 20 occurrences or few remaining individuals or 

acres) or because of some factor(s) making it very vulnerable to extirpation from the 

state.

S3 = rare or uncommon in state (on the order of 21 to 100 occurrences).

S4 = apparently secure in state, with many occurrences.

S5 = demonstrably secure in state and essentially ineradicable under present conditions.

SA = accidental in state, including species (usually birds or butterflies) recorded once or twice 

or only at very great intervals, hundreds or thousands of miles outside their usual range.

SE = an exotic established in the state; may be native elsewhere in North America (e.g. house 

finch or catalpa in eastern states).

SH = of historical occurrence in state and suspected to be still extant.

SN = regularly occurring, usually migratory and typically nonbreeding species.

SR = reported from state, but without persuasive documentation which would provide a basis 

for either accepting or rejecting the report.

SRF = reported falsely (in error) from state but this error persisting in the literature.

SU = possibly in peril in state, but status uncertain; need more information.

SX = apparently extirpated from state.
321 APPENDICES

APPENDIX I: WILDERNESS MINIMUM REQUIREMENT PROCESS

PROPOSED ACTION Allowing picnic tables in Wilderness

WHAT ISSUE IS ADDRESSED BY THE PROPOSED ACTION?:

Minimizing resource impacts while providing visitor enjoyment within Wilderness

1: Does the proposed action comply with 

law and policy?

CITE LAW AND POLICY:

2006 NPS Policies, 6.3.10.3 

Shelters and Campsites: Picnic 

tables will not be allowed in 

wilderness except in those limited 

circumstances when they are 

necessary for resource protection 

and when documented and 

approved through a minimum 

requirements analysis.

YES NO

Propose a different action

2: Is the action covered by a Categorical 

Exclusion, Environmental 

Assessment/FONSI or an Environmental 

Impact Statement/Record of Decision?

YES NO

Defer project until 

completed
APPENDICES 322

3: Is this an emergency?

*Emergency: a situation that 

involves inescapable urgency and 

temporary need for speed beyond 

that available by primitive means 

(For example: loss of human life or 

serious injury, law enforcement 

efforts involving serious crime or 

fugitive pursuit, retrieval of the 

deceased, fire suppression).

NOTES:

It is addressed in a draft WBMP

For resource protection, and visitor 

enjoyment

YES NO

Act according to 

established search 

and rescue

4: Is the action addressed in an approved 

Wilderness Plan?

YES NO

Follow Wilderness 

Plan direction.

5: Is action essential to meet Wilderness 

management objectives?

YES NO

Go to question 

#7
323 APPENDICES

6: Is the action essential to meet legal 

obligations associated with 

retained rights of island residents?

YES NO

Don’t do it

7: Can this action be accomplished 

through visitor education?

YES NO

Do visitor 

education

8: Can the action be accomplished 

outside of Wilderness?

YES NO

Do it there
APPENDICES 324

9: List alternative ways to address 

this issue

LIST ALTERNATIVES:

Alternatives are evaluated in the 

Draft WBMP.

A. No action

B. Remove picnic tables from all 

campgrounds within designated 

or potential wilderness (remove 

from 12 campgrounds, while 

retaining them at 9 campgrounds).

C. Request a waiver to maintain 

picnic tables in wilderness 

campgrounds. (NPS policies 

changed during the planning 

process and now states that picnic 

tables will not be allowed in 

wilderness except in those limited 

circumstances when they are 

necessary for resource protection 

and when documented and 

approved through a minimum 

requirements analysis.)

10: Evaluate and select alternative that 

successfully achieves objective 

with least impact on:

WILDERNESS RESOURCES

VISITORS’ WILDERNESS EXPERIENCE

Consider impact on:

-Wilderness character and influence

-Preservation of natural conditions 

(including lack of man-made noise)

-Outstanding opportunities for 

solitude

-Assurance of a primitive and 

unconfined type recreation 

opportunity

-Preservation and use in an 

unimpaired condition
325 APPENDICES

Selected 

alternative is 

proposed 

action

Selected 

alternative 

different than 

proposed 

action

Return to Q#1

11: Can this action be safely and 

effectively accomplished with 

primitive tools and skills?

(Economic efficiency and 

convenience are not primary 

considerations)

YES NO

Go to Q#13b

12: Will the use of primitive tools and 

skills have less impact on 

wilderness resources and the 

visitor experience than 

mechanized/motorized tools?

Not mechanized or motorized but 

rather an object that provides the 

presence of modern human 

activity/development

Research at ISRO has shown that 

picnic tables have caused less 

resource impacts to the surrounding 

campsite than sites without picnic 

YES NO
APPENDICES 326

tables (Farrel and Marion, 1998).

13a: Select appropriate 

primitive tools and skills

Picnic tables will be allowed when 

campsites have a dock, and 

shelters. Where campsites have 

these two features (docks & 

shelters) picnic tables will be 

allowed at both the shelters and the 

tent sites. (This has been the policy 

recommended by the BMG and 

approved by the Superintendent 

since April 1993) 

It is recommended that tables that 

blend in with the natural 

environment, should be phased into 

the landscape. (Get rid of metal leg 

tables, they reduce maintenance, 

but detract from the wilderness 

environment.) 

13b: Select minimum mechanized 

tool/technique/facility

Consider

Minimum # trips

Minimum group size

Quiet technology

Boat vs. vehicle

14: Evaluate your final destination 

using the questions on next page 

to ensure wilderness character is 

preserved.
327 APPENDICES

QUESTIONS TO CONSIDER IN WILDERNESS DECISION MAKING

1. Does your decision ensure that wilderness is not occupied or modified by humans? The 

decision minimizes the presence of picnic tables to campgrounds that have both established 

docks and shelters, and does not increase the presence of human modifications to new areas.

2. Does your decision maintain or move wilderness toward less human influence, within legal 

constraints? In these limited situations where the presence of man is evident, the picnic tables 

will not standout, especially if they are the type that blend into a natural environment. Picnic 

tables will not be permitted within the interior or lakeshore campsites without docks or 

shelters.

3. Does your decision allow wilderness to retain solitude and elements of surprise and 

discovery? This decision should not impact the solitude or elements of surprise and 

discovery.

4. Did you ensure that your decision was not primarily based on economy, convenience, 

comfort, or commercial value? Does provide some comfort and convenience, but the benefits 

of reduced resource impacts to the campsite balance the decision. 

5. Does your decision look beyond the short term to ensure that future generations will be able 

to enjoy the benefits of an enduring resource of wilderness? Yes it does.

6. Does your decision support the wilderness resource in its entirety rather than maximizing an 

individual resource within wilderness? Yes, this decision affects only 12 campsites out of 36, 

and a very small area out of the park which is designated 99% wilderness.

7. Does your decision recognize the unique character of this particular wilderness? Yes, and 

thanks for asking. Isle Royale’s wilderness is surrounded by Lake Superior waters. Wild and 

untamed, but not designated wilderness. Boaters use docks around the island for safe 

dockage, and to access associated campsites and trails. These tables are only associated with 

these campgrounds (11) that have dock access. There are also 9 docks in non-designated 

wilderness that are managed as wilderness, where tables would continue to be provided. On 

the surface the public would not be able to tell the difference why some tables would be 

allowed in campsites with docks and shelters, and not in other campsites with docks and 

shelters.

8. Does your decision ensure that the effects of human activities do not dominate natural 

conditions and processes? Yes, in a reasonable balanced way.

AFFIRMATIVE ANSWERS PROTECT AND PRESERVE THE WILDERNESS
APPENDICES 328

APPENDIX J: LIST OF PREPARERS, CONSULTATION AND COORDINATION

In preparing the Wilderness and Backcountry Management Plan and EIS for Isle Royale, the 

NPS consulted with internal NPS staff, other agencies, research partners, and the public. 

The Backcountry and Wilderness Management Plan Planning Team was the core team 

responsible for development of the Management Plan. Team members included:

• Phyllis Green, Superintendent

• Betsy Rossini, Assistant Superintendent

• Larry Kangas, Chief Ranger (formerly Isle Royale West District Ranger)

• Jean Battle, Chief, Natural Resources Management Division

• Jim Callahan, Facility Manager

• Liz Valencia, Acting Chief, Interpretation and Cultural Resources Division

• Mark Romanski, Lead Biological Technician

• Doug Boose, Program Analyst (formerly Isle Royale Trails Foreman)

• Buzz Brown, Trails Foreman

• Marshall Plumer, East District Ranger

• Greg Blust, Houghton District Interpreter/Visitor Center Supervisor

• Ann Mayo Kiely, Wilderness Coordinator and Team Leader since 2001

• David Newland, Environmental Compliance Specialist

Several people who are no longer part of the Isle Royale staff were also integral to the planning 

effort:

• Jack Oelfke, Chief of Resource Management, North Cascades National Park (formerly 

Isle Royale Branch Chief of Natural Resources) 

• Pete Armington, Chief Ranger, Denali National Park (formerly Isle Royale Chief Ranger)

• Bill Munsey, District Ranger, BLM Taos Field Office (formerly Isle Royale East District 

Ranger)

• Smitty Parratt, Chief of Interpretation Wrangle-St. Elias National Park (formerly Isle 

Royale Branch Chief of Interpretation)

• Rick Barrett, Chief of Maintenance Assateague Island National Seashore (formerly Isle 

Royale Chief of Maintenance)

Isle Royale staff and the public provided invaluable comments and input to develop plan drafts 

and alternatives. Seasonal staff and research partners were also critical for inventorying and 

monitoring wilderness conditions. 

Marilyn Hof, Senior Planner with the NPS Denver Service Center, provided direction, support, 

and consultation throughout the planning process. 

Mike Hyslop, Michigan Tech University, provided assistance with producing maps.

A preliminary draft of the WBMP was reviewed by the Midwest Regional Office and other 

wilderness managers within the NPS.
329 APPENDICES

APPENDIX K: COMMENTS RECEIVED

A full reprint of all written comments received from individuals and organizations is provided 

below. 

Individual / Organization Page

1. Unknown..............................................................................................................330

2. Alexander, Kim; Isle Royale Resorts...................................................................332

3. Glowicki, Ed; Isle Royale Boaters Association-Record of Phone Conversation 335

4. Brunson, James....................................................................................................336

5. Crites, David ........................................................................................................337

6. Edwards, R.Lawrence ..........................................................................................339

7. Forsell, Warner ....................................................................................................340

8. Barnum, David; Isle Royale Friends and Family Association.............................343

9. Funkey, Fred; Keweenaw Excursions..................................................................346

10. Gale, Christopher.................................................................................................348

11. Haataja, Mark.......................................................................................................350

12. Hand, Dave; Isle Royale Boaters Association .....................................................352

13. Hanke, Steve ........................................................................................................358

14. Heneghan, John....................................................................................................360

15. Johns, Bill ............................................................................................................363

16. Johnson, William .................................................................................................365

17. Kangas, Larry.......................................................................................................367

18. Mayo-Kiely, Ann .................................................................................................368

19. Kilpela, Donald; Isle Royale Line, Inc. ...............................................................371

20. Longcore, John.....................................................................................................374

21. McDonald, Missy.................................................................................................376

22. Merritt, Grant .......................................................................................................378

23. Nelson, Robert .....................................................................................................380

24. Oelfke, Jack..........................................................................................................384

25. Peterson, Candy ...................................................................................................388

26. Peterson, Rolf.......................................................................................................389

27. Schroeder, JR.......................................................................................................392

28. Sierra Club ...........................................................................................................395

29. Sivertson, Stuart; Grand Portage-Isle Royale Transportation Line, Inc. .............398

30. Smith, Thomas.....................................................................................................402

31. Strobel, Mark and Joan ........................................................................................403

32. Swanson, John......................................................................................................404

33. Westlake, Kenneth; Environmental Protection Agency ......................................405

34. Wherley, Sean; Friends of the Boundary Waters Wilderness..............................407

35. Woiwode, Anne ...................................................................................................409

36. Clean Wisconsin; Madison Audubon Society; Wisconsin League of Conservation 

 Voters; Sierra Club-John Muir Chapter..............................................................412
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