6

Consultation and Coordination

Covered Bridge

Sledding at the Dune Climb

Island Visitors aboard the Manitou Isle

PUBLIC INVOLVEMENT, INCLUDING SCOPING 

Prior to the official start of this planning 

process, the National Park Service held 35 

meetings with 793 people, increasing the 

awareness of the wilderness situation at the 

National Lakeshore and hearing from the 

public their preferences for resolution. 

Primarily as a result of these meetings, the 

National Park Service decided to begin a new 

general management planning process that 

included a Wilderness Study. 

The public was notified of this Sleeping Bear 

Dunes planning effort via: (1) a Federal 

Register notice of intent, dated December 28, 

2005, to prepare an environmental impact 

statement; (2) distribution of the first 

newsletter for this effort in January 2006; and 

(3) a press release announcing a public 

comment opportunity, including public 

scoping meetings for the general management 

plan. 

Newsletter 1, issued in January 2006, 

• introduced the concepts of general 

management plans and wilderness 

studies 

• outlined preliminary issues and concerns 

for the planning effort 

• provided a general timetable for 

development of the General Management 

Plan / Wilderness Study / Environmental 

Impact Statement

• provided draft purpose and significance 

statements 

• invited the public to participate in the 

planning process by providing comment 

• provided a comment form and website 

link to facilitate public comment 

• invited the public to attend scoping 

meetings for the General Management 

Plan / Wilderness Study / Environmental 

Impact Statement

Scoping is an early and open process for 

determining the scope of a proposed action or 

project and for identifying issues related to the 

project. During scoping, NPS staff provide an 

overview of the project, including purpose and 

need and preliminary issues. The public is asked 

to submit comments, concerns, and suggestions 

relating to the project and preliminary issues. 

A public comment period was open from 

January 30 to March 17, 2006. Public scoping 

meetings (open-house style) were held on 

February 14 and 15, 2006, in Empire and 

Traverse City, Michigan, respectively. A third 

meeting scheduled for February 16 in 

Benzonia, Michigan, was postponed until 

March 2, 2006, due to adverse weather 

conditions. Meetings with NPS employees 

were also held. The main purpose of the 

comment period and meetings was to 

introduce the planning process and gather 

ideas about what the plan should address. 

Frequently asked questions and answers were 

posted on the Lakeshore’s website and were 

updated throughout the planning process. 

Nearly 150 people attended the three scoping 

meetings. More than 300 written comments 

were received in response to Newsletter 1 and 

at the public open houses. A summary of 

public comments was posted on the 

Lakeshore’s website in May 2006. 

Newsletter 2, issued in April 2006, 

• summarized public scoping comments 

• answered frequently asked questions 

• presented the draft foundation for 

planning and management — the 

purpose and significance statements 

(revised); the fundamental resources and 

values; the primary interpretive themes; 

and special mandates 

• provided a planning steps/timetable 

update 

• invited the public to participate in the 

planning process by providing comments 

283 
CHAPTER 6: CONSULTATION AND COORDINATION

• provided a comment website link to 

facilitate public comment 

• invited the public to attend public 

planning workshops 

A public comment period, including three 

public planning workshops, was announced in 

Newsletter 2 and in a press release. The 

comment period was open from May 22 to 

July 7, 2006, and the workshops were held in 

Traverse City, Michigan, on June 20and 21, 

2006. An NPS employee workshop was also 

held. The purpose of the comment period and 

workshops was to gather input about how to 

manage the National Lakeshore. In total, 

about 70 people participated in the public 

workshops, and 25 additional written 

comments were received via mail, email, and 

the NPS’ PEPC (Planning, Environment, and 

Public Comment) system. This input was used 

to develop alternative management concepts 

and draft management zones. A summary of 

public and staff comments was posted on the 

Lakeshore’s website in September 2006. 

A press release explaining and clarifying the 

wilderness situation at the National 

Lakeshore was issued in July 2006. 

Newsletter 3, issued in October 2006, 

• briefly summarized the June public 

planning workshops 

• presented draft management zones and 

alternative management concepts 

• provided a wilderness study update 

• presented draft desired conditions for 

the National Lakeshore 

• provided a planning steps/timetable 

update 

• invited the public to participate in the 

planning process by providing comments 

• provided a comment form and website 

link to facilitate public comment 

A public comment period was open from 

October 11 to November 10, 2006. The main 

purpose of the comment period was to 

introduce the alternative management 

concepts and gather ideas about the draft 

management zones, the alternative 

management concepts, and desired future 

conditions. More than 200 written comments 

were received in response to Newsletter 3. A 

summary of public comments was posted on 

the Lakeshore’s website in February 2007. 

Newsletter 4, issued in April 2007, 

• briefly summarized public comments on 

Newsletter 3

• presented refined management zones 

• presented four preliminary alternatives 

based on the alternative concepts from 

Newsletter 3

• provided brief informational sections on 

wilderness and user capacity 

• provided a planning steps/timetable 

update 

• invited the public to participate in the 

planning process by providing comments 

• provided a comment form and website 

link to facilitate public comment 

• invited the public to attend public 

meetings 

A public comment period, including three 

public meetings, was announced in Newsletter 

4 and in a press release. The comment period 

was open from March 31 to May 14, 2007. 

Three public meetings were held in Honor, 

Glen Arbor, and Traverse City, Michigan, on 

May 1, 2, and 3, 2007, respectively. Meetings 

with NPS employees were also held. The 

purpose of the comment period and the 

meetings was to gather comments on the 

preliminary alternatives and what should be 

included in the preferred alternative. About 

200 people participated, and more than 400 

written comments were received. A summary 

of public comments was posted on the 

Lakeshore’s website in August 2007. 

Using input from the public and considering 

the probable environmental consequences 

and costs of the alternatives, the planning 

team developed the preferred alternative. The 

Draft General Management Plan / Wilderness 

284 
Public Involvement, Including Scoping 

Study / Environmental Impact Statement was 

then produced and distributed for public review. The mailing list for the draft document 

included nearly 2,400 individuals and groups. 

The Draft General Management Plan / 

Wilderness Study / Environmental Impact 

Statement for Sleeping Bear Dunes National 

Lakeshore was made available for public 

review beginning April 7, 2008; the comment 

period ended on June 15, 2008. Public 

meetings were held at Honor, Traverse City, 

and Glen Arbor, Michigan, on June 3, 4, and 5, 

2008, respectively, with a total of 196 people 

attending. A total of 292 comments were 

received via letters (66 total), e-mails (60 

total), Web responses (129 total), and 

comments transcribed from the public 

meetings (37 total). Comments came from 20 

different states. Many other meetings and a 

radio broadcast regarding the draft plan were 

attended by park staff, for example, 

congressional briefings and meetings with 

road commissions, friends groups, federal 

agencies, state agencies, and townships. 

National Lakeshore staff conducted an 

extensive public involvement and outreach 

program throughout the planning process. By 

the time of printing the Final General 

Management Plan / Wilderness Study / 

Environmental Impact Statement, NPS staff 

had held more than 90 informational meetings 

with the general public and dozens of groups 

or representatives (see list below) upon their 

request. More than 2,500 people in total 

attended these meetings. 

• Benzie County Commissioners 

• Benzie County Kiwanis Club 

• Benzie County Parks and Recreatoin 

• Benzie County Road Commission 

• Benzie Fishery Coalition 

• Benzie Rotary Club 

• Benzie Sunrise Rotary Club 

• Cherry Capital Paddling Club 

• Citizens for Access to the Lakeshore 

• Citizens’ Council for Sleeping Bear 

Dunes 

• Cleveland Township 

• Conservation Resource Alliance 

• Crystal Lake Watershed Association 

• Empire Lions Club 

• Frankfort Rotary Club 

• Friends of Sleeping Bear Dunes 

• Glen Arbor Community Forum 

• Glen Arbor Township 

• Grand Traverse Band of Ottawa and 

Chippewa Indians 

• Golden K Kiwanis Club 

• Interlochen Public Radio 

• Leelanau Chamber of Commerce & 

Businesses 

• Leelanau County Commissioners 

• Leelanau County Planning Commission 

• Leelanau County Road Commission 

• Leelanau Rotary Club 

• Leelanau Scenic Route Committee 

• Manitou Islands Memorial Society 

• Michigan congressional delegation 

• Michigan state historic preservation 

officer 

• Michigan Department of Natural 

Resources 

• Michigan Department of Environmental 

Quality 

• Michigan Land Use Institute 

• Manitou Island Transit 

• National Parks Conservation Association 

• Natural Resource Conservation Service 

• Noon Tiders 

• Northwestern Community College 

• Platte Township 

• Preserve Historic Sleeping Bear 

• Republican Women of Leelanau County 

• Rotary Club of Traverse City 

• Traverse City Kiwanis 

• U.S. Fish and Wildlife Service 

• WTCM 580 Radio 

Newsletters were available online, as were 

other documents related to this planning 

effort (e.g., public comment summaries, 

frequently asked questions, letters, and 

planning updates from the superintendent). 

The Draft General Management Plan / 

Wilderness Study / Environmental Impact 

285 
CHAPTER 6: CONSULTATION AND COORDINATION

286 

Statement was also available online. An 

interactive web forum related to the planning 

effort was also available. A press release was 

sent to media outlets announcing the web 

forum and encouraging the public to share 

their thoughts and ideas in a public way. An 

NPS moderator interacted with forum users, 

answering questions and facilitating open 

discussions for all to see. 

 

The Final General Management Plan / 

Wilderness Study / Environmental Impact 

Statement is available online at the National 

Lakeshore’s website (www.nps.gov/slbe). 
CONSULTATION AND COORDINATION TO DATE WITH OTHER 

AGENCIES, OFFICES, AND TRIBES 

FEDERAL AGENCIES 

The National Park Service contacted the U.S. 

Fish and Wildlife Service (USFWS) in a letter 

dated February 16, 2006. The letter advised 

the U.S. Fish and Wildlife Service of the NPS 

planning process for this General Management 

Plan / Wilderness Study / Environmental 

Impact Statement and requested a current list 

of federally listed threatened, endangered, or 

candidate species within the National 

Lakeshore. The U.S. Fish and Wildlife Service 

responded in a letter dated March 21, 2006; 

the response letter included a list of such 

species found within Leelanau and Benzie 

counties. On March 27, 2007, National 

Lakeshore managers met with USFWS 

representatives to discuss the planning 

process. 

In subsequent communications, Lakeshore 

staff sought advice from the U. S. Fish and 

Wildlife Service regarding how to fulfill NPS 

responsibilities for complying with Section 7 

of the Endangered Species Act. On September 

26, 2007, the two agencies agreed that a 

biological assessment should not be prepared 

in association with this General Management 

Plan. A general management plan is broad and 

strategic in nature (rather than a “major 

construction activity,” which is the usual 

trigger for preparation of a biological 

assessment). Details about many individual 

proposals mentioned in the General 

Management Plan alternatives, such as trail 

development and facility improvements, have 

not been yet been determined; project 

specifics that allow more meaningful impact 

assessment would be detailed in subsequent 

implementation plans. The National Park 

Service will continue to consult with the U. S. 

Fish and Wildlife Service in the future on a 

project-by-project basis concerning the need 

for additional Section 7 consultation. The 

initial letter from the U. S. Fish and Wildlife 

Service is reproduced in appendix F. 

The environmental consequences portion of 

this document (chapter 5) provides, to the 

extent possible, a general analysis of potential 

impacts on federally listed species and critical 

habitat for all alternatives, and for the 

preferred alternative a determination of effect 

is also provided. The U. S. Fish and Wildlife 

Service has advised the National Park Service 

that the EIS analysis fulfills the requirement for 

a biological assessment and for informal 

consultation under Section 7 of the 

Endangered Species Act. 

A letter dated June 16, 2008, from the East 

Lansing Field Office of the U.S. Fish and 

Wildlife Service provided comments on the 

draft plan preferred alternative in relation to 

section 7 of the Endangered Species Act (this 

letter is reprinted on the following pages). 

This office concurred with the NPS 

determination that implementing the 

preferred alternative 

may affect but not likely adversely affect 

Pitcher’s thistle, Michigan monkey 

flower, piping plover or piping plover 

critical habitat. Effects of the proposed 

alternative are considered insignificant, 

discountable, or beneficial. This 

precludes the need for further action on 

this project as required under section 7 

of the Act. 

They noted, however, that if the project plans 

change or elements of the preferred 

alternative are modified, consultation should 

be reinitiated. 

The National Park Service contacted the U.S. 

Natural Resources Conservation Service 

regarding prime and unique farmlands in two 

counties in letters dated May 9, 2006. The 

287 
CHAPTER 6: CONSULTATION AND COORDINATION

Natural Resources Conservation Service 

replied in a letter dated May 18, 2006. 

National Lakeshore managers met with a 

representative from the Natural Resources 

Conservation Service on May 23, 2006, to 

discuss prime and unique farmlands and the 

planning process. 

A letter dated June 9, 2008, from the Chicago 

office of the Environmental Protection 

Agency provided comments on the draft plan. 

This office rated the draft plan preferred 

alternative as “LO (Lack of Objection).” (This 

letter is reprinted on the following pages.) 

STATE AGENCIES 

The National Park Service contacted the 

Michigan state historic preservation officer in 

a letter dated February 16, 2006. The letter 

advised this office about the start of this 

planning process, asked for its involvement in 

the planning process, and solicited input on 

issues and concerns to be addressed by the 

plan. No written response was received. On 

March 27 and September 4–5, 2007, National 

Lakeshore managers met with representatives 

from the Michigan state historic preservation 

office to discuss the planning process and 

historic properties within the National 

Lakeshore. 

A letter dated July 7, 2008, from Brian 

Conway, the state historic preservation officer 

(in the Michigan Department of History, Arts, 

and Libraries in Lansing, Michigan) provided 

comments on the draft plan (this letter is 

reprinted on the following pages). Mr. 

Conway stated that 

Based on the information provided for 

our review, it is the opinion of the State 

Historic Preservation Officer (SHPO) 

that the preferred alternative identified 

in the GMP does not meet the criteria of 

adverse effect [36CFR section 

800.5(a)(1)] and will have no adverse 

effect [36CFR section 800.5(b)] on 

historic properties within the area of 

potential effects . . . . 

The National Park Service contacted the Chief 

of the Coastal Zone Management Program 

(Michigan Department of Environmental 

Quality) in a letter dated May 9, 2006. This 

office responded with a letter on June 8, 2006. 

Lakeshore managers met with representatives 

from the Michigan Departments of Natural 

Resources and Environmental Quality on 

April 2, 2007, to discuss the planning process. 

The Michigan Coastal Zone Management 

Program was provided the opportunity to 

review and concur with the General 

Management Plan / Wilderness Study / 

Environmental Impact Statement. 

A letter dated June 23, 2008, from the state 

Department of Environment Quality provided 

comments on the draft plan (this letter is 

reprinted on the following pages). This office 

stated 

[W]e strongly support the Preferred 

Alternative . . . . The Preferred 

Alternative strikes a good balance 

between protecting sensitive coastal 

resources and providing ample 

opportunity for visitor access and 

recreation. Activities such as controlling 

invasive species, protecting open dune 

areas, restoring disturbed sites, and 

protecting threatened and endangered 

species are all consistent with the goals 

of the Coastal Management Program 

and the DEQ. 

This office also noted that there were activities 

identified in the preferred alternative that will 

require state permits. 

A letter dated June 9, 2008, from the state 

Department of Natural Resources provided 

comments on the draft plan (this letter is 

reprinted on the following pages). This office 

supports the work of the NPS and their 

planning partners in the development of 

288 
Consultation and Coordination to Date with Other Agencies, Offices, and Tribes 

289 

the “Preferred Alternative,” and we 

endorse that recommendation. The 

preferred plan is the result of a planning 

process that demonstrated an 

impressive effort to engage the public 

and stakeholders. 

AMERICAN INDIAN TRIBES 

The National Park Service contacted the 

following five American Indian tribal groups 

in a letter dated February 16, 2006: Bay Mills 

Indian Community, Grand Traverse Band of 

Ottawa and Chippewa Indians, Little River 

Band of Ottawa Indians, Little Traverse Bay 

Bands of Odawa Indians, and Sault Ste. Marie 

Tribe of Chippewa Indians. The NPS letter 

advised the tribes of the planning process, 

invited them to participate in planning, and 

inquired about the tribes’ potential interests 

and concerns as they relate to the planning 

effort. No written responses from the tribes 

were received. NPS staff placed follow-up 

phone calls to each tribal group on June 14 

and July 13, 2006, to make sure the tribal 

groups received the letters and to ask if they 

had questions or wished to meet to discuss the 

planning effort. 

On July 18, 2006, Lakeshore managers met 

with representatives of the Grand Traverse 

Band of Ottawa and Chippewa Indians to 

discuss the General Management Plan / 

Wilderness Study / Environmental Impact 

Statement and other matters of mutual 

interest. During that meeting, the Grand 

Traverse Band representatives explained that 

the other tribal groups had authorized them 

(Grand Traverse Band) to represent the other 

tribal groups in the National Lakeshore’s 

planning process. On August 1, 2006, the 

National Park Service sent a letter to each of 

the five tribal groups summarizing the NPS 

understanding of this arrangement. In August 

2006, the Grand Traverse Band reviewed the 

National Lakeshore’s draft interpretive 

themes and provided input to ensure that the 

statements appropriately reflect values and 

stories related to American Indian culture and 

affiliation with the National Lakeshore. 

Informal comments were received and 

incorporated. On March 16, 2007, the 

National Park Service sent a letter to the 

Grand Traverse Band and offered to present 

the preliminary alternatives and answer any 

questions. On April 10, National Lakeshore 

staff met with a representative from the Grand 

Traverse Band to present and discuss the 

preliminary alternatives. On May 14, 2007, the 

National Lakeshore received a comment letter 

from the Grand Traverse Band. The National 

Lakeshore provided clarification and 

response in a letter dated May 31, 2007, and 

requested a follow-up meeting to discuss the 

Grand Traverse Band’s comments in more 

detail. That meeting was held on June 7, 2007. 

A letter dated June 18, 2008, from the Grand 

Traverse Band of Ottawa and Chippewa 

Indians provided comments on the draft plan 

(this letter is reprinted on the following 

pages). The tribe fundamentally supported the 

preferred alternative because it “provides a 

good mix of enjoyment opportunities to the 

public as well as resource protection,” 

although slight modifications were suggested. 

The tribe expressed interest in continued 

communication with NPS staff. 
LIST OF AGENCIES OR ENTITIES RECEIVING A COPY OF THIS PLAN 

FEDERAL AGENCIES 

Advisory Council on Historic Preservation 

Federal Aviation Administration 

Isle Royale National Park 

Keweenaw National Historic Park 

Natural Resources Conservation Service 

Pictured Rocks National Lakeshore 

U.S. Army Corps of Engineers 

U.S. Bureau of Land Management 

U.S. Coast Guard 

U.S. Department of Agriculture, Forest 

Service 

U.S. Department of Labor – Occupational 

Safety and Health Administration 

U.S. Environmental Protection Agency 

U.S. Fish and Wildlife Service 

AMERICAN INDIAN 

TRIBAL GOVERNMENTS 

Bay Mills Indian Community 

Grand Traverse Band of Ottawa and 

Chippewa Indians 

Hannahville-Potawatomi Indian Community 

Keweenaw Bay Indian Community 

Lac Vieux Desert Band of Lake Superior 

Chippewa Indians 

Little River Band of Ottawa Indians 

Little Traverse Bay Bands of Odawa Indians 

Nottawaseppi Huron Band of Potawatomi 

Pokagon Band of Potawatomi Indians 

Saginaw Chippewa Indian Tribe 

Sault Ste. Marie Tribe of Chippewa Indians 

U.S. SENATORS AND 

REPRESENTATIVES 

Honorable Carl Levin, Senator 

Honorable Debbie Stabenow, Senator 

Honorable Dave Camp, House of 

Representatives 

Honorable Peter Hoeskstra, House of 

Representatives 

Honorable David E. Bonior, House of 

Representatives 

Honorable Carolyn Cheeks Kilpatrick, House 

of Representatives 

Honorable John Conyers, Jr., House of 

Representatives 

Honorable Vernon J. Ehlers, House of 

Representatives 

Honorable Dale E. Kildee, House of 

Representatives 

Honorable Joe Knollenberg, House of 

Representatives 

Honorable Sandy Levin, House of 

Representatives 

Honorable Lynn N. Rivers, House of 

Representatives 

Honorable Mike Rogers, House of 

Representatives 

Honorable Nick Smith, House of 

Representatives 

Honorable Fred Upton, House of 

Representatives 

STATE OFFICIALS, SENATORS, 

AND REPRESENTATIVES 

Honorable Jennifer M. Granholm, Governor 

State Representative David Palsrok 

State Senator Jason Allen 

State Senator Dan L. DeGrow 

State Senator Michelle McManus 

STATE AGENCIES 

AND COMMISSIONS 

State of Michigan 

Coastal Management Program 

Cultural and Economic Development 

Department of Agriculture 

Department of Environmental Quality 

Department of History, Arts, and Libraries 

Department of Natural Resources 

Department of Transportation — Traverse 

City Transportation Service Center 

290 
List of Agencies and Organizations Receiving a Copy of This Plan 

Historian 

Historical Center 

Historic Preservation Office 

Natural Features Inventory 

Natural Resources Commission 

Water Resources Commission 

REGIONAL, COUNTY, AND 

LOCAL GOVERNMENTS 

Almira Township 

Benzie Conservation District 

Benzie County Administrator 

Benzie County Clerk 

Benzie County Commissioners 

Benzie County Planning Commission 

Benzie County Sheriff’s Office 

Benzie County Road Commission 

Benzie County Treasurer 

Benzie County Parks and Recreation 

Benzonia Township 

Bingham Township 

Blaine Township Hall 

Centerville Township 

Cleveland Township 

Colfax Township 

Crystal Lake Township 

Empire Township 

City of Frankfort 

Gilmore Township 

Glen Arbor Township 

Grand Traverse County 

Homestead Township 

Inland Township 

Joyfield Township 

Kasson Township 

Lake Township 

Leelanau Conservation District 

Leelanau County Administrator 

Leelanau County Clerk 

Leelanau County Commissioners 

Leelanau County Road Commission 

Leelanau County Sheriff’s Department 

Leelanau County Planning Commission 

Leelanau County Treasurer 

Leelanau Township 

Manistee County Commission 

Metroparks of the Toledo Area 

Northwest Michigan Council of Governments 

Northwest Michigan Regional Planning 

Platte Township 

Solon Township 

Spring Township 

Suttons Bay Township 

Village of Benzonia 

Village of Beulah 

Village of Elberta 

Village of Empire 

Village of Northport 

Weldon Township 

ORGANIZATIONS, BUSINESSES, 

AND UNIVERSITIES 

AAA Michigan 

Advocates for Safe Drinking Water and Lakes 

Air Foundation 

Arts Council of Greater Grand Rapids 

Bay Area Transit Authority 

Benzie Area Historical Society 

Benzie Audubon Club 

Benzie County Chamber of Commerce 

Benzie Fishery Coalition 

Benzie Soil and Water Conservancy 

Campaign for America’s Wilderness 

Cedar Rod & Gun Club 

Center for Biological Diversity 

Cherry Capitol Paddle America Club 

Citizen’s Council of the Sleeping Bear Dunes 

Area 

Citizens for Access to the Lakeshore 

Citizens for Positive Planning 

Conservation Resource Alliance 

Crystal Lake Watershed Association 

Crystal Mountain 

Eastern National 

Empire Area Museum 

Empire Lions Club 

Frankfort-Elberta Chamber of Commerce 

Friends of Sleeping Bear Dunes 

Friends of the Crystal River 

George Wright Society 

Glen Arbor Art Association 

Glen Lake Chamber of Commerce 

Grand Traverse Audubon Club 

Grand Traverse Bay Watershed Initiative 

291 
CHAPTER 6: CONSULTATION AND COORDINATION

Grand Traverse Conservancy 

Grand Traverse Convention and Visitors 

Bureau 

Grand Traverse Hiking Club 

Grand Valley State University 

Great Lakes Natural Resource Center 

Green Party 

Izaak Walton League 

Kalamazoo Nature Center 

Land Information Access Association 

Leelanau Chamber of Commerce 

Leelanau Conservancy 

Leelanau Democratic Party 

Leelanau Historical Society 

Leelanau Scenic Heritage Route 

Leelanau-Kohahna Foundation 

Manitou Islands Memorial Society 

Michigan Association of Builders 

Michigan Association of Realtors 

Michigan Audubon Society 

Michigan Chamber of Commerce 

Michigan Council of Hostelling International 

Michigan Environmental Council 

Michigan Historical Council 

Michigan Hotel, Motel, and Resort 

Association 

Michigan Land Use Institute 

Michigan Mountain Biking Association 

Michigan State University 

Michigan Technological University 

Michigan Travel Bureau 

Michigan United Conservancy 

MSU Cooperative Extension Service 

MSU Extension 

National Parks and Conservation Association 

Natural Resources Defense Council 

Northern Michigan Environmental Action 

Council 

Northwestern University 

Preserve Historic Sleeping Bear 

Public Employees for Environmental 

Responsibility 

Save Leelanau Farmland! 

Shielding Tree Nature Center 

Sierra Club 

Student Conservation Association 

The Biodiversity Project 

The Homestead 

The Nature Conservancy 

The Wilderness Society 

Traverse City Chamber of Commerce 

Wayne State University 

West Michigan Environmental Action 

Council 

Western Land Exchange Project 

University of Arkansas 

University of Michigan 

University of Nebraska 

LIBRARIES 

Alpena County Library 

Benzie Shores District Library 

Beulah Public Library 

Glen Lake Community Library 

Leelanau Township Library 

Leland Township Library 

Library of Michigan 

Suttons Bay Area Public Library 

Traverse City District Library 

SCHOOL DISTRICTS 

Glen Lake School District 

Leelanau School 

Traverse Bay Area – Intermediate School 

District 

HOMEOWNER’S ASSOCIATIONS 

Crystal Lake Association 

Glen Lake Association 

Homestead 

Little Platte Lake Association 

Little Traverse Lake Association 

Platte Lake Improvement Association 

Platte River Homeowner’s Association 

CONCESSIONERS AND 

IN-PARK BUSINESSES 

Blough Firewood 

Camp Leelanau-Kohahna 

Commission for the Blind 

292 
List of Agencies and Organizations Receiving a Copy of This Plan 

Crystal River Outfitters 

Manitou Island Transit 

Riverside Canoe Livery 

Trading Post 

NEWSPAPERS AND MAGAZINES 

Albion Pleiad 

Ann Arbor News 

Antrim County News 

Benzie Record Patriot 

Booth Newspapers 

Cassopolis Vigilant/Edwardsburg Argus 

Central Michigan Life 

Chelsea Standard 

Chicago Sun-Times 

Compass Newspaper 

County Press 

Crains Detroit Business 

Crawford County Avalanche 

Daily Mining Report 

Daily News 

Daily Press 

Daily Reporter 

Daily Tribune 

Dearborn Press & Guide 

Detroit Free Press 

Detroit News 

Dowagiac Daily News 

Exponent 

Ferris State Torch 

Flint Journal 

Gazette 

George Weeks, Columnist 

Gladwin County Record 

Glen Arbor Sun 

Grand Haven Tribune 

Grand Rapids Press 

Grand Traverse Herald 

Grand Traverse News 

Grand Valley Lanthorn 

Herald-Palladium 

Holland Sentinel 

Houghton Lake Resorter 

Ironwood Daily Globe 

Kalamazoo Gazette 

Kalkaskian 

Lansing State Journal 

Leelanau Enterprise 

Ludington Daily News 

Mackinac Town Crier 

Macomb Daily 

Manchester Enterprise 

Marlette Leader 

Metro Times 

Michigan Chronicle 

Midland Daily News 

Mining Journal 

Monroe Evening News 

Monroe Guardian 

Montmorency County Tribune 

News-Herald 

News-Sentinel 

Niles Daily Start 

Northern Express 

Northwoods Call 

Oakland Press 

Observer Eccentric 

Oceana’s Herald-Journal 

Penasee Globe 

Pioneer Times 

P R Newswire 

Romeo Observer 

Saline Reporter 

Spinal Column Newsweekly 

State News 

Straitsland Resorter 

Student Movement – Andrews University 

Sturgis Journal 

The South End, Wayne State University 

The Technical, Kettering University 

Times Herald 

Town Meeting 

Travel & Outdoor 

Travel & Outdoor Features 

Traverse City Record Eagle 

Traverse—The Magazine 

View 

Voice News 

Ypsilanti Courier 

RADIO AND TELEVISION STATIONS 

BNZ Radio 

Voice News 

Cadillac Evening News 

293 
CHAPTER 6: CONSULTATION AND COORDINATION

294 

Community Calendar, TV 

Evening News 

Interlochen Public Radio 

The Outdoor Network 

WBKP 

WFUM-Michigan Television – U of M 

WGTU/WGTQ 29/8 

WGVU 

WILX 

WJBK FOX-2 

WKAR 

WLNS NewsCenter 6 

WLUC-TV 6 

WNEM 

WOOD TV 8 

WOTV 

WPBM-WTON TV 7 & 4 

WTCM News 

WWTV-WWUP 9 & 10 

WZPX TV-43 

WZZM TV-13 
COMMENTS ON, CHANGES TO, AND RESPONSES TO COMMENTS ON 

THE DRAFT PLAN 

COMMENTS ON THE DRAFT PLAN 

The Draft General Management Plan / 

Wilderness Study / Environmental Impact 

Statement was made available for public 

review in mid April, 2008. The public 

comment period ended on June 15, 2008. A 

postcard announcing that the document 

would be available was sent to approximately 

2,500 people. Following response to the 

postcard, the document was sent to about 700 

individuals, organizations, agencies, and 

tribes. The draft document was also posted on 

the Web and distributed at meetings. Nearly 

300 comments on the draft plan were 

received. 

KEY CHANGES TO THE 

PREFERRED ALTERNATIVE 

In response to comments on the draft plan, 

the following key changes were made. 

1. Changes in Inland Lake Boating 

The original text (pg. 54, second column of 

the draft plan, first full bullet on Inland Lake 

Use and Access) said 

• Inland Lake Use and Access — 

Motorized boats would be allowed on 

School and Loon lakes. Motorized boats 

would no longer be allowed on Bass 

(Leelanau County) and North Bar lakes. 

Access for nonmotorized boats would be 

improved at a few inland lakes (locations 

to be determined). 

The decision was made to no longer allow 

motorboats only on North Bar Lake (to 

improve visitor experiences for nonmotorized 

uses such as canoeing, kayaking, fishing, and 

swimming). Boats with electric motors would 

be allowed in the experience nature zone on 

Bass Lake (Leelanau County), Tucker Lake, 

and Otter Lake to increase the range of visitor 

opportunities that are compatible with the 

intent of this zone. 

Therefore, the revised text in this final plan 

(the bullet on Inland Lake Use and Access) 

now reads: 

• Inland Lake Use and Access — 

Motorized boats would be allowed on 

School and Loon lakes. Motorized boats 

would no longer be allowed on North 

Bar Lake. Electric motors would be 

allowed in the experience nature zone on 

Bass Lake (Leelanau County), Tucker 

Lake, and Otter Lake. Access for boats 

would be improved at a few inland lakes 

(locations to be determined). 

Changes were made in the appropriate places 

throughout the document (e.g., environmental 

consequences chapter) to reflect these 

changes. 

2. Minor Change in Wilderness Proposal 

Based on public comment, the decision was 

made to exclude the Cottonwood Trail area 

from the wilderness proposed on the Sleeping 

Bear Plateau. The Cottonwood Trail area is 

one of three trails into the namesake dunes, 

and it is used by school and other groups of up 

to 100 people, which is not consistent with 

wilderness values. 

Accordingly, the wilderness proposal for the 

preferred alternative was reduced to 32,100 

acres or 45% of the National Lakeshore. 

295 
CHAPTER 6: CONSULTATION AND COORDINATION

3. Benzie Corridor Language 

Based on public comment, the word 

“purchase” was replaced with “acquire” for 

the language about lands in the Benzie 

Corridor (as shown below) to clarify that 

donation, easements, etc. would also be 

considered. (This same change was made in 

the no-action alternative and in alternatives B 

and C). 

The National Park Service would 

continue to acquire lands within 

the Benzie Corridor on a willingseller basis (subject to available 

funding) for future development 

of a scenic road and/or a 

bike/hike trail (determined and 

evaluated via a future study). 

4. Table 3 

The Shalda Cabin in the preferred alternative 

was changed from the experience nature zone 

to the recreation zone (to be consistent with 

the 7thbullet under recreation zone in 

appendix D). The Kraitz Cabin was removed 

from table 3 completely because it has not yet 

been determined eligible for the national 

register. The “Lyle Schmidt Barn (1)” was 

changed to the “Lyle Schmidt Farm (3)” to 

reflect the actual number of structures there. 

Accordingly, corresponding figures in the 

table and in other locations throughout the 

document were updated. 

RESPONSES TO COMMENTS 

ON THE DRAFT PLAN 

Letters and Web comments from federal and 

state agencies and from tribes are reprinted in 

full, along with NPS responses to substantive 

comments. Other substantive comments 

(from organizations and individuals) are 

paraphrased, and NPS responses are 

provided. Comments are substantive if they 

do the following: 

• question, with reasonable basis, the 

accuracy of information in the 

environmental impact statement 

• question, with reasonable basis, the 

adequacy of the environmental 

analysis 

• suggest different viable alternatives 

• cause changes or revisions in the 

proposal 

Comments in favor of or against the preferred 

or other alternatives, or comments that only 

agree or disagree with NPS policy, are not 

considered substantive. 

Although the planning team is obligated only 

to respond to substantive comments, it has 

also responded to selected nonsubstantive 

comments for various reasons (e.g., politics, 

numbers of people responding, and the need 

to clarify the agency position). 

Letters, Web comments, e-mails, and meeting 

transcripts are a part of the project 

administrative record. 

On the following pages, first the comments 

from organizations and individuals and NPS 

responses are presented. These are organized 

by topic, such as access, Benzie Corridor, etc. 

Following that are reproductions of comment 

letters from agencies and organizations, with 

substantive comments bracketed and NPS 

responses provided. 

Access 

COMMENT: Make existing NPS facilities 

more accessible to visitors with mobility 

impairments. 

RESPONSE: In all development planning, the 

National Lakeshore considers ways to 

provide opportunities for visitors with 

limited mobility. Developments proposed 

in the near future at Glen Haven include 

improved parking, picnicking, and beach 

access facilities, and these facilities will be 

296 
Comments on, Changes to, and Responses to Comments on the Draft Plan 

accessible to those with disabilities. The 

National Park Service strives to maintain a 

balance between development and 

resource protection. Accessible picnic 

areas are found at the Platte River picnic 

area, along the Pierce Stocking Scenic 

Drive, and at the County Road 669 and 651 

road ends. The Platte River campground is 

fully accessible, and the more rustic D.H. 

Day campground is accessible with 

assistance. Please refer to the “Accessibility 

to the National Lakeshore” subheading 

under the “Desired Conditions and 

Strategies” heading in chapter 1. 

COMMENT: Share information regarding 

improvements to Tiesma Road and 

associated lakeshore access. 

RESPONSE: The General Management Plan

alternatives include no specific plans or 

proposals to improve Tiesma Road or 

associated access; however, the preferred 

alternative calls for Tiesma Road to remain 

open and allows for improvements to be 

made. 

Benzie Corridor 

COMMENT: The National Lakeshore’s 

establishing legislation (Public Law 91-479) 

allows for a scenic road along the Benzie 

Corridor, but not for a hike/bike trail. 

RESPONSE: Congressional action would be 

needed to allow for either removal of the 

Benzie Corridor (as in alternative A) or 

development of a hike/bike trail alone 

(alternative C). Congressional action may 

be needed to implement the preferred 

alternative if a scenic road is not included 

in the ultimate decision. 

COMMENT: The National Park Service 

should consider multiple means of 

acquisition within the Benzie Corridor 

other than purchase in fee simple, such as 

donations and easements. The National 

Park Service should also consider 

partnerships as a means of providing public 

access within or to the corridor. 

RESPONSE: In the preferred and no-action 

alternatives, and alternatives B and C, the 

term "purchase" has been changed to 

"acquire" in the final plan, to clarify that 

acquisition of less-than-fee interest (e.g., 

easements), as well as other means of 

acquisition, such as donation, would be 

considered by the National Park Service. 

Property within the Benzie Corridor would 

be acquired only from willing sellers. 

Boundary Adjustments 

COMMENT: North Fox Island and South 

Fox Island should be added to the National 

Lakeshore. 

RESPONSE: As part of the GMP process, the 

planning team assessed the Fox Islands as a 

potential addition to the National 

Lakeshore boundary (see appendix B) and 

concluded that these islands do not meet 

NPS criteria for boundary adjustments. 

Historic Resources 

COMMENT: Historic properties within 

designated wilderness will end up receiving 

less preservation treatment than those 

outside wilderness. Historic properties 

located in management zones other than 

the experience history zone will not be 

adequately preserved. 

RESPONSE: All alternatives in the Draft 

General Management Plan / Wilderness 

Study specify preservation of all historic 

properties regardless of management zone 

or proposed wilderness. 

NPS management policies for wilderness 

preservation and management are outlined 

in chapter 6 of NPS Management Policies 

2006. Section 6.3.8, “Cultural Resources,” 

states that “cultural resources that have 

297 
CHAPTER 6: CONSULTATION AND COORDINATION

been included within wilderness will be 

protected and maintained according to the 

pertinent laws and policies governing 

cultural resources using management 

methods that are consistent with the 

preservation of wilderness character and 

values. These laws include the Antiquities 

Act and the Historic Sites, Buildings and 

Antiquities Act, as well as subsequent 

historic preservation legislation, including 

the National Historic Preservation Act, the 

Archaeological Resources Protection Act, 

and the Native American Graves 

Protection and Repatriation Act.” 

Historic properties within proposed 

wilderness at the National Lakeshore are 

to be maintained in keeping with 

wilderness principles that limit the use of 

wheeled vehicles and motorized 

equipment to only those instances where 

they are the minimum tool necessary to 

accomplish the desired preservation goal. 

The National Lakeshore staff has already 

been successfully preserving historic 

structures in proposed wilderness for 

many years, and will continue to do so. The 

minimum tool requirement occasionally 

makes preservation maintenance less 

convenient, but this does not mean the 

properties receive a lesser degree of 

preservation treatment. See the “Resource 

Management and Research” subheading 

under the “Implications of Managing 

Lands Proposed for Wilderness” heading 

in chapter 3. 

As outlined in the introduction to the 

"Management Zones" heading of chapter 

2, in every management zone the National 

Lakeshore intends to preserve and protect 

natural and cultural resources to the 

greatest extent possible given available 

funds. The experience history zone does 

not confer a higher priority for 

preservation treatment of structures 

compared to other zones. It does, however, 

contain some of the highest priority 

resources — those identified as 

fundamental resources. 

 

COMMENT: Three structures in the Glen 

Haven Village Historic District need to be 

reevaluated for their eligibility for the 

national register. 

RESPONSE: There are three structures in 

Glen Haven (Wickland House, Dean 

House, and Rude Garage) that have been 

reviewed and determined ineligible for the 

National Register of Historic Places (that 

is, they are nonhistoric). The Michigan 

state historic preservation officer has 

written to the National Lakeshore 

suggesting that these structures be 

reevaluated before any actions on them are 

undertaken. The National Lakeshore staff 

plans to do so. 

COMMENT: The "Prominent Historical 

Resources Base Map" in chapter 4 has 

omissions, including the Newhall cottage 

and shed, the Lake Manitou privy and 

bathhouse, and Beuham orchard on North 

Manitou Island; the Minger Cabin near 

School Lake; the D.H. Day cultural 

landscape; certain archeological sites; and 

the Empire Air Base housing. 

RESPONSE: The map of historic resources 

was not intended to be an exhaustive 

depiction of all such resources — simply 

the most prominent ones. As such, there 

are several historic resources not shown on 

the map. As for the specific historic 

structures and landscapes listed in the 

comment, although the National 

Lakeshore continues to preserve them in 

the interim, formal determinations of 

eligibility have yet to be made. 

Archeological sites are not generally shown 

on NPS maps due to their sensitivity, 

fragile nature, and the potential for 

vandalism or looting. 

298 
Comments on, Changes to, and Responses to Comments on the Draft Plan 

COMMENT: The footnote in “Table 3: 

Range of Treatment for Historic Properties 

under the Alternatives,” indicates that the 

list in the table shows buildings, but does 

not include landscape features such as 

fence rows, cemeteries, sidewalks, etc. 

They should be included because the 

footnote also says that all landscapes are 

preserved. 

RESPONSE: All historic features, from fence 

rows to buildings, are to be preserved. The 

intent of table 3 was to respond to this 

concern by comparing the range of 

possible treatments for the buildings across 

the alternatives. The range of treatments 

for landscapes associated with the 

buildings is the same as shown for the 

buildings. All cultural landscape features 

are to be preserved. 

COMMENT: In chapter 2, table 3, the 

number in parentheses in some cases does 

not match the actual number of structures 

that exists in a district. 

RESPONSE: The table 3 numbers for Lyle 

Schmidt Farm have been corrected in the 

final plan. The table reflects structures that 

have been determined eligible for the 

national register. There are other 

potentially eligible resources for which 

formal determinations of eligibility have 

yet to be made; these are not shown. 

COMMENT: Why isn’t the “Historic 

Properties Management Plan” mentioned 

under the chapter 1 heading “Relationship 

of the General Management Plan to Other 

Planning Efforts”? 

RESPONSE: The “Draft Historic Properties 

Management Plan” was placed on hold in 

1999. Following completion of the General 

Management Plan, it may be appropriate to 

resume it. The "Relationship of the 

General Management Plan to Other 

Planning Efforts" discussion addresses 

only planning efforts that have been 

completed or are currently underway. 

COMMENT: It is not appropriate to specify, 

by management zone, a range of treatment 

for historic structures. 

RESPONSE: NPS Management Policies 2006

indicate that it is, in fact, appropriate to 

specify particular treatments or ranges of 

treatments for historic properties by 

management zone: “Delineation of 

management zones will illustrate where 

there are differences in intended resource 

conditions, visitor experiences, and 

management activities” (section 2.3.1.2). 

“Decisions regarding which treatments will 

best ensure the preservation and public 

enjoyment of particular cultural resources 

will be reached through the planning and 

compliance process . . .” (section 5.3.5). 

“The relative importance and relationship 

of all values will be weighed to identify 

potential conflicts between and among 

resource preservation goals, park 

management and operation goals, and park 

user goals. Conflicts will be considered and 

resolved through the planning process . . . ” 

(section 5.3.5). 

Management Zones 

COMMENT: There’s an error in the maps for 

the action alternatives. The orange 

recreation zone strip around the islands 

and mainland should be the darker orange 

(for water), not the lighter (for land). 

RESPONSE: In the final plan, the colors have 

been corrected to match the legend as 

suggested. For graphic simplicity, the thin 

strip of active Lake Michigan beach area, 

which is part of this recreation zone, has 

not been shown separately. 

Natural Resources 

COMMENT: Applying the recreation zone to 

all Lake Michigan beaches in the National 

Lakeshore threatens fragile beach 

landscapes, endangered species, and 

habitats adjacent to them. 

299 
CHAPTER 6: CONSULTATION AND COORDINATION

RESPONSE: The recreation zoning of Lake 

Michigan beaches reflects the NPS intent 

to continue to allow recreational 

motorboat access within the 0.25 mile of 

Lake Michigan waters within the National 

Lakeshore boundary. The recreation zone 

would be applied to active Lake Michigan 

beach areas, which are essentially bare 

sand areas that are washed by waves, but 

not the adjacent foredune. By their very 

nature, active beaches lack stabilizing 

vegetation and are not vulnerable to 

formation of lasting informal trails. With 

the exception of steep bluff slopes, these 

are the same resilient sand areas commonly 

used by visitors for sunbathing, sand play, 

and beach strolling. The National 

Lakeshore has a demonstrated history of 

protecting nesting piping plovers and their 

critical habitat in these areas in 

consultation with the U.S. Fish and 

Wildlife Service. 

COMMENT: Dredging of the Platte River 

(discussed in chapter 5 under the 

"Cumulative Impacts" heading) should be 

stopped altogether because the impacts of 

dredging are not consistent with the 

purpose of the National Lakeshore. 

RESPONSE: The question of whether 

dredging of the Platte River mouth (for 

recreational motorboat access) should be 

continued is closely related to the question 

of whether a new boat ramp should be 

developed within the high use zone near 

the mouth of the Platte River. The purpose 

of the dredging is to provide recreational 

boating and fishing access to Lake 

Michigan in September during the salmon 

run. As stated in the preferred alternative, a 

separate environmental impact statement 

would be needed to determine whether 

there may be alternatives for providing this 

access in a way that lessens impacts to 

resources and visitors’ experiences. Such a 

study would consider a number of 

alternatives, and the environmental, safety, 

visitor opportunity, and other impacts of 

implementing those alternatives. Cessation 

of dredging would likely be a component 

of one or more of these alternatives. The 

National Park Service will not make a 

decision on this topic until such a study, 

conducted with opportunities for public 

input, is completed. 

COMMENT: The preferred alternative’s 

proposal to improve the Glen Lake picnic 

area (to facilitate beach and picnic use) 

would have natural resource impacts. 

Examples include impacts to nesting geese, 

siting a well and septic system, and 

compliance with state environmental and 

other regulations. 

RESPONSE: The impacts of improving the 

Glen Lake picnic area have been 

considered broadly in chapter 5 of this 

General Management Plan / Wilderness 

Study / Environmental Impact Statement. 

Specific design details for improvements 

would be developed subsequent to this 

General Management Plan. Potential 

impacts on wildlife and other natural and 

cultural resources would be considered in 

more detail during the design phase. 

Facility improvements would comply with 

state and other applicable regulations. 

COMMENT: There would be serious impacts 

associated with a boat launch on Platte Bay, 

including impacts to Pitcher's thistle and 

piping plover. 

RESPONSE: Potential impacts from 

development of a boat launch facility on 

Platte Bay would be thoroughly analyzed in 

an environmental impact statement prior 

to any such project. This analysis would 

include consultation with other agencies as 

appropriate, including the U.S. Fish and 

Wildlife Service regarding potential 

impacts to threatened and endangered 

species and critical habitat. 

 

COMMENT: The preferred alternative's 

proposal for improvements to Esch Beach 

300 
Comments on, Changes to, and Responses to Comments on the Draft Plan 

parking would have undesirable impacts. 

Examples include potential changes to the 

area's character, natural resource impacts, 

and increased use. 

RESPONSE: Currently, parking at Esch 

Beach takes place on road shoulders within 

the county road right-of-way. This parking 

results in congestion, resource damage, 

safety concerns, and difficult access to the 

beach for visitors and emergency vehicles. 

Improvements to Esch Beach parking have 

yet to be designed, but would be developed 

in consultation with the county and would 

address these issues while minimizing 

resource impacts. Slight changes to the 

area’s character may result, but mitigation 

measures would be taken to minimize such 

changes. Improvements would be designed 

to better accommodate existing levels of 

frequently recurring use, not peak use. The 

facilities would not create more demand, 

but would help address current demand. 

However, the National Park Service does 

not control county road rights-of-way, so 

parking could occur along road shoulders 

even after improvements are made. 

Increased use may occur regardless of NPS 

actions. 

Planning Foundation 

COMMENT: Suggestions were made either 

to include cultural resources in the 

National Lakeshore’s purpose statement, 

or to list the NPS Organic Act (which 

mentions preservation of historic 

resources) in or directly under the purpose 

statement in the plan. It was also suggested 

that not including cultural resources in the 

National Lakeshore’s purpose statement 

jeopardizes the National Lakeshore’s 

ability to compete for funding to preserve 

cultural resources. 

RESPONSE: A park unit's purpose statement, 

simply stated, is the reason a specific park 

was designated by Congress. The purpose 

of Sleeping Bear Dunes National 

Lakeshore was clearly specified by 

Congress in the 1970 legislation that 

established the National Lakeshore; that 

purpose does not include cultural 

resources. 

A park unit's purpose statement does not 

replace or lessen the impact of the National 

Park Service’s mission. Rather, it focuses 

the agency's management role at a 

particular park unit. (The focus of 

management is different at Carlsbad 

Caverns National Park than at Gettysburg 

National Military Park, for example.) A 

park's purpose statement also does not 

permit the National Park Service to ignore 

the requirements of federal legislation, 

such as the NPS Organic Act, National 

Historic Preservation Act, the 

Archeological Resources Protection Act, or 

the Native American Graves Protection 

and Repatriation Act. The National 

Lakeshore’s cultural resources are 

protected by these laws, and by the General 

Management Plan’s specifically stated 

intent to preserve them. 

Adding cultural resources to the National 

Lakeshore’s purpose would offer no 

additional protection or funding for 

cultural resources beyond what is currently 

provided. The National Lakeshore has 

competed successfully for cultural 

resource preservation funding despite the 

fact that neither the enabling legislation for 

the National Lakeshore nor the existing 

General Management Plan list cultural 

resources as part of the National 

Lakeshore's purpose. There is no reason to 

expect this to change. 

The NPS Organic Act is prominently stated 

in the “Servicewide Laws and Policies” 

heading of chapter 1. In addition, the 

relationship between the National 

Lakeshore’s purpose and the NPS Organic 

Act has been clarified in the introductory 

paragraph of the “Purpose” section earlier 

in chapter 1. 

301 
CHAPTER 6: CONSULTATION AND COORDINATION

COMMENT: The planning team created the 

definition of “fundamental resources and 

values.” The term and the list of 

fundamental resources and values were not 

vetted with the public. 

RESPONSE: The planning team used the 

National Park Service's agency-wide 

definition of fundamental resources and 

values. The NPS General Management 

Planning Dynamic Sourcebook defines 

fundamental resources and values as 

“features, systems, processes, experiences, 

stories, scenes, sounds, smells, or other 

attributes determined to warrant primary 

consideration during planning and 

management because they are critical to 

achieving the park’s purpose and 

maintaining its significance.” 

Newsletter #2 (published in May 2006) 

presented the draft foundation for 

planning and management, which included 

the definition of fundamental resources 

and values and a list of fundamental 

resources and values for Sleeping Bear 

Dunes National Lakeshore. The public was 

encouraged to read and comment on this 

newsletter. Newsletters #3 and #4 also 

made reference to fundamental National 

Lakeshore resources and these newsletters 

were made available for public review. 

After reviewing all of the public comments 

received in response to the newsletters, the 

planning team found no compelling reason 

to modify the list of resources (natural, 

cultural, and recreational) identified as 

fundamental. 

COMMENT: The National Lakeshore's list of 

fundamental resources and values should 

be expanded to include more of the 

National Lakeshores resources, 

particularly its cultural resources. 

RESPONSE: The following excerpt from the 

NPS General Management Planning 

Dynamic Sourcebook (2008) explains why 

the National Lakeshore’s list of 

fundamental resources and values is not 

more comprehensive: 

Park managers are continually 

challenged to set priorities and 

allocate limited funding and staffing 

to adequately protect what is most 

important about a park while at the 

same time complying with the full 

array of legislative mandates, laws, 

and policies that cover all park 

resources and values. . . . In identifying the fundamental resources and 

values deserving primary consideration during planning and management, restraint is critical. The 

resulting list is useful only if it 

focuses on those relatively few things 

that are so important that they 

should be the preeminent considerations in all park planning and 

decision making. The list of 

resources and values should not be 

interpreted as everything that is 

important about the park, or even 

everything that is nationally significant. It should be a relatively short 

list of resources or values considered 

to be critical to achieving the park's 

purpose and maintaining its significance. Identifying fundamental 

resources and values helps ensure 

that planning is focused on what is 

truly most significant about the park. 

It creates a tool that park managers 

and staffs can use to focus planning 

and management on highly significant resources and values and ensure 

that all the resources and values 

warranting preeminent consideration are adequately protected. 

Although a few people suggested that ALL 

cultural resources should be shown as 

fundamental, this would defeat the 

purpose outlined above. If all resources are 

fundamental, it would be very difficult for a 

manager to prioritize during times of 

scarce funding. 

302 
Comments on, Changes to, and Responses to Comments on the Draft Plan 

Planning Process, Law, and Policy 

COMMENT: All four action alternatives 

place the Lake Michigan beaches in the 

recreation zone; why isn’t there more 

diversity in terms of zoning these beaches? 

RESPONSE: Many areas within the National 

Lakeshore are zoned identically across all 

action alternatives. In this case, the 

recreation zoning of Lake Michigan 

beaches reflects the NPS intent to continue 

to allow recreational motorboat access 

within the 0.25 mile of Lake Michigan 

waters within the National Lakeshore 

boundary. The recreation zone would be 

applied to active Lake Michigan beach 

areas, which are essentially bare sand areas 

that are washed by waves, but not the 

adjacent foredune. Because boat access 

from the water to the beaches is not 

causing any appreciable environmental 

impacts, and it would be extremely difficult 

to enforce a “no-beaching” rule, extending 

the recreational zoning established for the 

waters of Lake Michigan to the beaches 

themselves, allows this use to continue. 

COMMENT: An asset management plan 

(mentioned in the "Implementation of the 

General Management Plan" discussion in 

chapter 2) provides a vehicle for NPS 

management to reverse decisions made in 

the General Management Plan, especially 

with regard to preservation of historic 

structures. 

RESPONSE: Asset management plans follow 

the direction given in general management 

plans; they do not reverse it. 

The National Park Service defines assets as 

physical structures or groupings of 

structures, land features, or other tangible 

properties having a specific service or 

function. Examples include roads, trails, 

buildings, and utility systems. 

The NPS asset management program is 

designed to address several key questions: 

-What assets does the park own? 

-What is the condition of each asset? 

-What is the current replacement value 

of each asset? 

-What is required to properly sustain the 

assets over time? 

-What assets are the highest priorities 

relative to the park mission, and 

where should a park focus resources? 

Properly caring for assets throughout their 

useful life cycle saves resources in the long 

run. Asset management practices help 

parks clearly prioritize, reduce, and 

manage deferred maintenance; improve 

the overall condition of assets; better 

predict and justify future budget requests; 

anticipate maintenance needs; plan 

accordingly; and fix problems before they 

become expensive emergencies. 

COMMENT: The Port Oneida Rural Historic 

District needs its own management plan 

within the preferred GMP alternative. 

RESPONSE: Ideally, Port Oneida would have 

a comprehensive management plan, one of 

many such plans needed for the National 

Lakeshore. Such a plan would be consistent with the management direction in 

the approved General Management Plan. 

Some decisions have been made regarding 

Port Oneida already. For example, the Port 

Oneida Rural Historic District Environmental Assessment was completed, and a 

“Finding of No Significant Impact” was 

signed in June 2008. However, this 

environmental assessment only described 

and analyzed alternative locations for a 

visitor contact station and employee 

housing, alternative means of improving 

visitor access, and ways to interpret Port 

Oneida resources (see the chapter 1 

heading “Relationship of the General 

Management Plan to Other Planning 

Efforts”). A cultural landscape management plan / environmental assessment 

for Port Oneida is also underway. 

 

303 
CHAPTER 6: CONSULTATION AND COORDINATION

COMMENT: The plan should include “safe, 

off road parking at M-22 and the Platte 

River” because such had been proposed by 

the National Park Service in the past and 

the funds were appropriated by Congress 

to do so. 

RESPONSE: The 1979 General Management 

Plan stated that the long-range goal for this 

area was to provide one canoe livery 

(operated under a concession contract), 

with picnic facilities and a central parking 

area IF the private properties at that intersection became available for acquisition. 

However, the National Park Service did 

not acquire all the properties. The 1992 

Platte River Management Plan referenced 

the 1979 plan and called for “appropriate 

parking and safe access for visitors” 

desiring to use a canoe livery. The National 

Park Service subsequently addressed this in 

the 1990s by constructing a 42-car parking 

area at the Platte River picnic area and a 

pedestrian bridge for visitors to access 

Riverside Canoe Livery services. During 

the peak season (generally July and 

August), a congestion problem remains 

because the livery’s customers and 

employees park along county roads, 

including Birch Trail across the busy 

highway from the livery. 

The 1999 Senate Report 105-227 contained 

language regarding appropriations toward 

mitigating a safety hazard associated with 

parking and access to the canoe livery, 

consistent with the Platte River Management Plan. The language in the report 

regarding the safety hazard was adopted 

into the Conference Report, but was not 

included in the appropriations bill. A 

fundamental rule of federal appropriations 

is that restrictions on lump sum appropriations that appear only in the legislative 

history of an appropriations act (such as 

the Conference Report) do not bind the 

agency on its spending of lump-sum 

appropriated funds. Because the provision 

for the parking lot does not appear in any 

appropriations act for the Department of 

the Interior, the National Park Service is 

not required to use its discretionary funds 

to build a parking lot. 

Parking for National Lakeshore visitors is 

currently available. Parking congestion 

during the roughly two months of peak use 

at the junction of M-22 and the Platte River 

is a direct result of customers and 

employees of the canoe livery. The 

National Park Service is not categorically 

opposed to the construction of a parking 

lot for use by visitors who use the canoe 

livery services. To build a parking lot, there 

must be a legal mechanism, such as a 

concession contract, that would enable this 

use of National Lakeshore lands. 

COMMENT: Motorized boats must be 

allowed on Loon Lake because inland lakes 

are under the state of Michigan's legal 

jurisdiction. 

RESPONSE: Motorized boats are allowed on 

Loon Lake in every alternative. 

Visitor Opportunities 

COMMENT: Provide more bicycle 

opportunities in the National Lakeshore 

for both mountain bikes and road bikes. 

Provide a mountain bike area (such as 

Burnham Woods). Use a park trail near 

Otter Creek as a connector to county 

roads, creating a bicycle route from the 

Platte River campground to Empire. Add 

bike trails and bike concessions on the 

islands. 

RESPONSE: Placing Burnham Woods in the 

recreation zone in the preferred alternative 

allows consideration of future use of this 

area by mountain bikes, pending planning 

and environmental analysis. The hiking 

trail south of Otter Creek Road (South Aral 

Road) is in an area zoned experience 

nature and proposed for wilderness in the 

preferred alternative. Allowing bicycles on 

this hiking trail west of Otter Lake would 

304 
Comments on, Changes to, and Responses to Comments on the Draft Plan 

negatively affect wilderness values. The M22/M-109 hike/bike trail referred to in the 

preferred alternative would provide the 

desired connection between county roads. 

Currently, bicyclists can make the connection by accessing M-22 between Trails 

End and Esch Road. Most of North 

Manitou Island is proposed as wilderness, 

there are no county roads, and bicycling 

would not be allowed. Bicycles are 

permitted on county roads, including those 

on South Manitou Island, but there are no 

plans to develop a bicycle trail or concession operation on South Manitou Island. 

COMMENT: The National Park Service 

should provide additional equestrian trails 

in the National Lakeshore. 

RESPONSE: Equestrian use is currently 

allowed within the National Lakeshore on 

the Alligator Hill trail system and along 

state and county road rights-of-way. All of 

the General Management Plan / Wilderness 

Study's management zones (especially the 

recreation zone and experience nature 

zone) would allow for future consideration 

of additional horse trails, although none 

are specifically proposed in the preferred 

alternative. Wilderness proposal/ 

designation does not preclude horse trails. 

Any future trail proposals would be subject 

to analysis of environmental impacts, per 

the National Environmental Policy Act of 

1969. 

COMMENT: The National Park Service's pet 

policy at the National Lakeshore should be 

changed. 

RESPONSE: The pet policy is not a component of the General Management Plan / 

Wilderness Study; however, it is addressed 

in the “Superintendent's Compendium,” 

which is a list of designations, closures, 

permit requirements, and other restrictions 

imposed under the discretionary authority 

of the park superintendent, as provided for 

in Title 36 of the Code of Federal 

Regulations. The “Superintendent's 

Compendium” can be accessed via the 

National Lakeshore's website 

(www.nps.gov/slbe). 

COMMENT: Designate a portion of the Lake 

Michigan beach as a "clothing optional" 

area. 

RESPONSE: Michigan Penal Code 750.335a 

prohibits indecent exposure, which 

includes public nudity. It would therefore 

be inappropriate for the National 

Lakeshore to designate a "clothing 

optional" area. 

COMMENT: Recreational hunting has no 

place at the National Lakeshore. 

RESPONSE: The law that established the 

National Lakeshore in 1970 (Public Law 

91-479) specifically permits hunting within 

the National Lakeshore (see “Special 

Mandates” discussion of chapter 1). 

COMMENT: Noise impacts were not 

considered in the document. Noise levels 

(especially from trucks and motorcycles) 

are increasing, and this is affecting wildlife 

and recreational enjoyment. Are there any 

noise level regulations in the National 

Lakeshore? 

RESPONSE: Impacts related to noise are 

analyzed for each of the alternatives in 

“Chapter 5: Environmental Consequences” 

under the “Visitor Opportunities and Use” 

heading, “Visitor Opportunities” 

subheading (reference natural sounds) and 

the “Natural Resources” heading, 

“Vegetation and Wildlife” subheading 

(reference sensory-based disturbance). 

Most roads in the National Lakeshore are 

rights-of-way that are controlled by the 

Leelanau County and Benzie County road 

commissions; however, NPS regulations 

still apply. Title 36 of the Code of Federal 

Regulations (section 2.12) prohibits noise 

305 
CHAPTER 6: CONSULTATION AND COORDINATION

exceeding 60 decibels, or making a noise 

that is unreasonable considering the nature 

and purpose of the actor’s conduct, 

location, time of day or night, purpose for 

which the park was established, impact on 

park users, and other factors that would 

govern the conduct of a reasonably 

prudent person under the circumstances. 

Park rangers have the authority to enforce 

this regulation and do so as needed. 

COMMENT: Consider allowing electric 

motors on all lakes. 

RESPONSE: The preferred alternative has 

been revised to allow electric motors on 

Bass Lake (Leelanau County), Tucker 

Lake, and Otter Lake. A few lakes remain 

completely nonmotorized. 

COMMENT: Provide visitor center services 

in the North district/Port Oneida area or 

Leland. 

RESPONSE: Visitor services will be provided 

in Port Oneida (see “Port Oneida Rural 

Historic District Environmental Assessment” subheading of the “Relationship of 

the General Management Plan to Other 

Planning Efforts” heading in chapter 1 of 

this document). 

Wilderness 

COMMENT: How and when did portions of 

the National Lakeshore come to be 

managed "so as to maintain their presently 

existing wilderness character"? 

RESPONSE: Information about the legislative 

direction for wilderness studies and 

wilderness management at Sleeping Bear 

Dunes National Lakeshore is provided in 

chapter 1 under the "Purpose and Need for 

the Wilderness Study,” discussion and in 

“Chapter 3: Wilderness Study and 

Proposal.” 

COMMENT: Some areas should not be 

included in the preferred alternative's 

wilderness proposal because they are 

routinely used by large school groups and 

guided tours. 

RESPONSE: The preferred alternative’s 

wilderness proposal was revised to remove 

the Cottonwood Trail to allow continued 

use by large groups without compromising 

solitude within designated wilderness. The 

Cottonwood Trail provides an opportunity 

for large groups to experience one of the 

National Lakeshore’s fundamental 

resources, the namesake Sleeping Bear 

Dunes. Other areas either duplicate this 

opportunity or are not routinely needed by 

rangers for large group tours. 

COMMENT: Networks of small roads used 

by motorized vehicles (including off-road 

vehicles and snowmobiles) contribute to 

trail damage, litter, and a decreased nature 

experience, and they seem incompatible 

with wilderness. 

RESPONSE: For clarification, in the 

preferred alternative, all developed county 

road rights-of way are excluded from 

wilderness. Off-road vehicles, including 

snowmobiles, are allowed only on county 

road rights-of-way and the shoulders of 

state highways. The National Lakeshore 

works with the county road commissions 

to minimize resource and visitor impacts 

associated with county roads. In developing the wilderness proposals associated 

with the various alternatives, the planning 

team considered what effect keeping the 

roads open and out of wilderness would 

have on the wilderness values and 

character of adjacent lands. Because some 

of the area proposed as wilderness in 1981 

would be broken into small parcels 

surrounded by roads, the preferred 

alternative proposes about 600 fewer acres 

for wilderness (the area south of Trails End 

Road and east of Lasso/Peterson roads, 

and the area between Peterson and Tiesma 

roads) than the 1981 recommendation. 

306 
Comments on, Changes to, and Responses to Comments on the Draft Plan 

Chapter 5 considers impacts on wilderness 

character. 

COMMENT: Congress would not be able to 

designate wilderness in the Bass Lake and 

Otter Lake areas (Benzie County) because 

these areas have county roads, docks, 

picnic tables, and restroom facilities. 

RESPONSE: Neither Otter and Bass Lakes 

(Benzie County) nor the Trails End 

developed area is proposed for wilderness 

in any action alternative. In the no-action 

alternative, the lakes themselves are in 

proposed wilderness but the roads and 

facilities are not. In the preferred 

alternative, the proposed wilderness would 

be located west of these lakes. (See 

Preferred Alternative map). 

Other 

COMMENT: The impact analysis of the management zoning for the M-22/M-109 hike/ 

bike trail should include condemnation of 

adjacent private property; landform 

constraints on siting the hike/bike trail; and 

impacts to safety, property values, and 

vegetative buffers. 

RESPONSE: A “Trailway Plan and 

Environmental Assessment” is being 

prepared to analyze a range of alternatives 

within Leelanau County for providing a 

nonmotorized hike/bike trail that is 

separate from the road surface. That plan, 

scheduled for release in the near future, is 

separate from this GMP/WS planning 

process, and will examine likely impacts of 

the hike/bike trail in more detail. 

It is anticipated that the trail would be 

located entirely on either federal land 

within the National Lakeshore, on state 

highway rights-of-way, or (in a few cases) 

on county road rights-of-way. The trail 

would be sited within the state highway 

right of way in areas where private land 

abuts the highway corridor. 

Planning for the trail in Benzie County has 

not been initiated. However, the Draft

General Management Plan / Wilderness 

Study includes management zoning that 

would accommodate the hike/bike trial in 

both Benzie and Leelanau counties. 

Placement of the high use zone in the 

GMP/WS alternatives in no way implies 

acquisition of private lands for the 

hike/bike trail. This point has been 

clarified in “Appendix D: Development of 

the Preferred Alternative.” The National 

Park Service does not control state or 

county road rights-of-way within the 

National Lakeshore. The National Park 

Service also recognizes private inholdings 

and other valid existing rights, and the 

management zones shown on the 

alternative maps are not intended to imply 

otherwise. 

COMMENT: Consideration of a Lake 

Michigan boat access in the high use zone 

near Platte Point should be made more 

assertively in the preferred alternative. 

RESPONSE: A decision on whether a new 

boat ramp should be developed within the 

high use zone near the mouth of the Platte 

River is likely to be complicated and 

controversial. As stated in the preferred 

alternative, a separate environmental 

impact statement would be needed to 

determine whether any such facility would 

be appropriate in this area. Such a study 

would consider a number of alternatives 

(including a no-action alternative) and the 

environmental, safety, visitor opportunity, 

and other impacts of implementing those 

alternatives. The National Park Service will 

not make a decision on this topic until such 

a study, conducted with opportunities for 

public input, is completed. 

COMMENT: A Lake Michigan boat access in 

the high use zone near Platte Point would 

have undesirable environmental impacts. 

307 
CHAPTER 6: CONSULTATION AND COORDINATION

308 

RESPONSE: See the response immediately 

above. 

COMMENT: Over-building the parking area 

at Esch Beach could result in more use and 

watershed problems. 

RESPONSE: The preferred alternative places 

the Esch Beach parking area out of 

proposed wilderness and in the recreation 

zone, and proposes improvements at this 

site. If the scale of the developments 

eventually proposed have the potential for 

significant impacts, these would have to be 

assessed in a planning document with the 

input of the public. Please also see the 

comment and response about Esch Beach 

under the “Natural Resources” topic. 

COMMENT: National Lakeshore use of 

sustainable technologies (wind and solar 

power, alternative fuels transportation, 

etc.) should be part of the preferred 

alternative. 

RESPONSE: Sustainability of NPS operations 

and facilities is a National Lakeshore-wide 

goal. The GMP/WS alternatives do not 

differ with regard to this goal. This topic is 

addressed in the chapter 1 "Desired 

Conditions and Strategies” heading, under 

the “Facilities and Services" subheading. 

COMMENT: The National Park Service 

should collaborate with nearby counties on 

“The Grand Vision,” a regional traffic and 

land use study. 

RESPONSE: The National Park Service has 

been participating in “The Grand Vision” 

effort, attending meetings and workshops 

and providing input. 
Comments Resp

309
Comments Resp

310
Comments Resp

311

1. Table 21 was revised as suggested. The “Cu

sections related to federal threatened and endbeen revised to reflect past projects that have Michigan monkey flower. 

1.
Comments Resp

312
Comments Resp

313
Comments Resp

314
Comments Resp

315
Comments Resp

316

1. These road ends are maintained by the coun

commissions, and currently accommodate launwatercraft.

1.
Comments Resp

317

3. These concerns are addressed in chapter 1, 

Conditions and Strategies” heading, “RelationTribes” subheading, and in chapter 4 under thConsidered but Not Analyzed in Detail” headisources” subheading. A strategy related to Amadded to the chapter 1 “Natural Resources (Gsubheading of the ”Desired Conditions and St4. Although some differences between the recrrience nature zone may seem subtle, many are recreation zone permits motorized use, while tzone does not. Also, the recreation zone permfacilities such as roads, parking areas, docks anformal picnic areas, while the experience natumodest improvements such as trails or signs. Tregardless of wilderness status. Table 1 in chapside comparison of the four management zone

1.

2.

3.

4.

5. 5. In Table 1: Management Zones (chapter 2), 

to infrastructure intentionally developed by hudevelopment ranges from primitive maintained (continued on next page) 

2. The experience history and recreation zoneagricultural crops to be considered in accordanpreservation principles, and after an analysis oSuch crops may incidentally benefit wildlife anenvironment. 
Comments Resp

318

5. (continued) parking lots, to boat ramps or d

offices and museums. Protecting and preserving top priority in the experience nature zone. Natumodified only to provide for safe visitor access oimpacts, such as from exotic species or past devof “resource improvements” are allowed in all odescribed in the “Desired Future Conditions anin chapter 1 and the management zone table in c“resource enhancement” and “resource improvmeanings. NPS staff will work closely with affiliaspecific proposals.

5.

6.

7.

7. Tribal ceremonies and rituals, (e.g., sweatlodgwilderness. NPS staff will continue to work closto address these and other issues.

6. Costs for each of the alternatives are included 

scription (chapter 2) and in appendix C. Enviroevaluated in chapter 5. The areas proposed as wprovide a specific type of recreational value, and access to those areas. The preferred alternative iproposal in which county roads would remain orecreation zone, even if they were abandoned by life span of this plan. The recreation zone specifitinued use for vehicle travel. However, if a new wadvanced, and acted upon by Congress as a resudonment of the rights-of-way for the county roaRecommendation” would indeed result in their given no indication that they plan to abandon th
Comments Resp

319
Comments Resp

320

1.The National Park Service will continue to w

the state of Michigan during implementation oalternative. This includes obtaining required sdevelopment proposals are in the design phas

1.
Comments Resp

321
Comments Resp

322
Comments Resp

323
Comments Resp

324
Comments Resp

325

1.

2.

3.

1. In chapter 1, under the “Desired Conditions the strategy regarding control of invasive nonnatem Management” subheading) and the strategy (“Natural Resources [General] and Diversity” srevised.2.Chapter 5 (Environmental Consequences) seeconomics have been revised to address these im3. In chapter 1, under the “Desired Conditions the strategy regarding control of invasive nonnatem Management” subheading) and the strategy (“Natural Resources [General] and Diversity” srevised.
Comments Resp

326

4. The management zones described in chapter through this planning effort and are prescriptive tive. In other words, they do not necessarily reflment. Thus, it would be inaccurate and misleadzones to the map of the no-action alternative. 5. This element of the preferred alternative, like upon funding. The National Park Service will wMichigan Department of Natural Resources to a study. Cessation of dredging would likely be a more of the alternatives in this separate study.

4. 

5. 
Comments Resp

327

5. 

(continued)

6. 

7. 

6. Chapter 5 (Environmental Consequences) ssocioeconomics have been revised to address tgested.7. The information source has been added to thas suggested.
Comments Resp

328

1. A park unit’s purpose statement, simply st

specific park was designated by Congress. ThBear Dunes National Lakeshore was clearly sin the 1970 legislation that established the Napurpose does not include cultural resources.A park unit’s purpose statement does not repimpact of the National Park Service’s missionthe agency’s management role at a particular purpose statement also does not permit the Nto ignore the requirements of federal legislatiOrganic Act, National Historic Preservation AResources Protection Act, or the Native Ametection and Repatriation Act. The National Lresources are protected by these laws, and by Management Plan’s specifically stated intent 

1.