Fresh Snowfall

Wilderness Study and Proposal

3

Camping Out

Harebell Flowers
82 

Back of divider 
83 

INTRODUCTION 

The purpose of wilderness designation is to 

preserve and protect wilderness 

characteristics and values in perpetuity, 

including opportunities for solitude or 

primitive and unconfined recreation. With 

passage of the 1964 Wilderness Act (16 USC 

1131 et seq.), Congress declared that it is 

national policy to secure for present and 

future generations the benefits of enduring 

wilderness resources. Wilderness can be 

officially designated only through 

congressional action. 

WILDERNESS DEFINITION 

The Wilderness Act of 1964 (PL 88-577) is the 

guiding piece of legislation for all wilderness 

areas. The act defines wilderness as follows: 

• “lands designated for preservation and 

protection in their natural condition” 

Section 2(a) 

• “an area where the earth and its 

community of life are untrammeled by 

man” Section 2(c) 

• “an area of undeveloped Federal land 

retaining its primeval character and 

influence, without permanent 

improvement or human habitation” 

Section 2(c) 

• “generally appears to have been affected 

primarily by the forces of nature, with 

the imprint of man's work substantially 

unnoticeable” Section 2(c) 

• “has outstanding opportunities for 

solitude or a primitive and unconfined 

type of recreation” Section 2(c) 

• “shall be devoted to the public purposes 

of recreation, scenic, scientific, 

educational, conservation and historic 

use” Section 4(b) 

BRIEF DESCRIPTION 

OF THE STUDY AREA 

The wilderness study area consists of the 

71,291 acres within the legislated boundary of 

Sleeping Bear Dunes National Lakeshore. 

Major land cover types of the area include 

hardwood forest, coniferous forest, sand 

dunes, dune bluffs, beaches, Lake Michigan 

waters, inland lakes, and wetlands. Most of 

the area is federally owned and managed, but 

there are also some privately owned parcels, 

reservations of use and occupancy, and rightsof-way for utilities and state and county roads 

within the study area. 
84 

WILDERNESS STUDY AND PROPOSAL 

WILDERNESS ELIGIBILITY 

The first step in a wilderness study is typically 

to identify wilderness eligible lands, or lands 

that possess wilderness character. The 1970 

legislation that established Sleeping Bear 

Dunes National Lakeshore (Public Law 91-

479) required the secretary of the interior to 

recommend the suitability or unsuitability of 

lands within the Lakeshore for preservation as 

wilderness. As a result, six areas totaling more 

than 36,000 acres were identified as wilderness eligible in the 1975 “Final Wilderness 

Recommendation”: (1) most of North 

Manitou Island, (2) most of South Manitou 

Island, (3) an area around Pyramid Point/ 

Good Harbor Bay (northern portion of the 

Lakeshore), (4) an area around the Sleeping 

Bear Plateau (central portion of the Lakeshore), (5) an area around Otter Creek 

(southern portion of the Lakeshore), and (6) 

an area west of the Platte River (southern 

portion of the Lakeshore). The 1975 recommendation proposed 35,060 acres — all as 

potential wilderness, recognizing that the 

limited land acquisition authority in the 

Lakeshore’s enabling legislation would likely 

result in nonconforming uses (such as 

residences) remaining in many areas. Not all 

of the eligible areas were proposed as 

potential wilderness at that time; the northern 

portion of the Sleeping Bear Plateau area was 

withheld because “interpretation is proposed 

in this area.” 

Subsequently, after most of the land 

acquisition had taken place and the 1979 

General Management Plan was completed, a 

new wilderness proposal was prepared. The 

1981 “Wilderness Recommendation” also 

proposed most, but not all, of the wildernesseligible areas for wilderness designation, and 

the recommendation included the general 

areas described above, with the exception of 

the area around the Sleeping Bear Plateau. 

The 1981 “Wilderness Recommendation” 

proposed 30,903 acres of wilderness; 7,128 for 

full designation and 23,775 as potential 

wilderness (areas in which there remained 

temporary nonconforming uses, such as 

reservations of use and occupancy). 

Congress then passed a law in 1982 (PL 97-

361) requiring Sleeping Bear Dunes National 

Lakeshore to manage areas proposed in the 

1981 “Wilderness Recommendation” to 

maintain their existing wilderness character 

“until Congress determines otherwise.” 

Because of this law, all lands included in the 

1981 recommendation have been, and will 

continue to be, managed as wilderness 

unless and until Congress acts upon a 

recommendation. 

In 2006 the NPS planning team evaluated the 

wilderness eligibility of lands added to the 

Lakeshore boundary since the initial eligibility 

was determined in 1975. The Bow Lakes (975 

acres), Miller Hill (640 acres), and Crystal 

River (104 acres) additions were determined 

to be ineligible for wilderness. This determination was based primarily on substantial percentages of nonfederal ownership (Bow Lakes 

and Miller Hill), existing developments, the 

relatively small size of the areas (especially 

considering that none is contiguous to other 

National Lakeshore areas that were earlier 

determined to be eligible for wilderness), and 

the corresponding lack of outstanding opportunities for solitude or a primitive and 

unconfined type of recreation. 

OPTIONS ANALYZED IN 

THIS WILDERNESS STUDY 

This Wilderness Study is a fresh look at the 

question of whether, and if so, where, wilderness should be designated within Sleeping 

Bear Dunes National Lakeshore, given the 

best available current information about 

wilderness character, public review and 
Wilderness Study and Proposal 

85 

comment, and practical considerations. This 

Wilderness Study is being carried out primarily 

because of public interest regarding issues 

associated with the 1981 “Wilderness Recommendation” that arose during a 2002 effort to 

produce a new General Management Plan for 

the Lakeshore. Following the halting of that 

planning effort, Lakeshore managers decided 

that the best way to address public concerns, 

and the indeterminate status of wilderness 

posed by the 1982 law, would be to conduct a 

new Wilderness Study. Because there are many 

misperceptions about wilderness, it is important to understand what wilderness designation for portions of Sleeping Bear Dunes 

National Lakeshore would mean. Information 

about what is and what is not allowed in 

wilderness is provided in chapter 1 (see “Uses 

and Management in Wilderness” in the 

section titled “Purpose and Need for the 

Wilderness Study”). 

Using the overall vision for each action alternative and public comment, the planning team 

developed a range of possibilities for proposed wilderness that would meet the 

Lakeshore mission of preserving resources 

and providing visitors appropriate opportunities to enjoy them. These alternative 

configurations and amounts of proposed 

wilderness are included in the action 

alternatives in this General Management Plan. 

Where practicable, proposed wilderness 

boundaries have been defined by roads, rivers, 

ridgelines, or other physical features to 

facilitate future management. 

Five wilderness options or proposals are 

evaluated in this General Management Plan / 

Wilderness Study / Environmental Impact 

Statement. Each wilderness option is included 

as part of one of the general management plan 

alternatives; see “Chapter 2: Alternatives, 

Including the Preferred Alternative.” The 

Environmental Impact Statement included in 

this document analyzes the consequences of 

these five wilderness options. 

It should be noted that the most substantial 

difference between the wilderness proposal 

in the no-action alternative (the 1981

“Wilderness Recommendation”) and the 

proposals in each of the four action 

alternatives is that no developed county 

roads are included in proposed wilderness 

in the action alternatives. These roads were 

excluded from proposed wilderness in order 

to continue to provide vehicle access to 

various areas of the Lakeshore, and in 

consultation with the Benzie and Leelanau 

County Road Commissions who own the road 

rights-of-way. Excluding the road corridors 

from proposed wilderness fragmented some 

of the eligible lands to the point that the 

planning team felt that they would no longer 

possess sufficient wilderness character, so the 

lands adjacent to M-22 between the Platte 

River and Fowler Road in the southern 

section of the park were excluded from the 

wilderness proposals in the action 

alternatives, including alternative A that 

proposes the largest acreage of wilderness. 

TABLE 5: WILDERNESS OPTIONS EVALUATED IN THIS WILDERNESS STUDY

Alternative Wilderness Proposal (acres) Notes 

No-action Alternative 30,903

(43% of the National Lakeshore) 

1981 “Wilderness Recommendation;” portions of both islands 

and the mainland 

Preferred Alternative 32,200

(46% of the National Lakeshore) 

Portions of both islands and the 

mainland 

Alternative A 33,600

(47% of the National Lakeshore) 

Portions of both islands and the 

mainland 

Alternative B 14,400

(20% of the National Lakeshore) 

Portions of North Manitou Island

only 

Alternative C 23,200

(32% of the National Lakeshore) 

Portions of both islands and the 

mainland 
CHAPTER 3: WILDERNESS STUDY AND PROPOSAL

86 

The overall vision of alternative A is that the 

National Lakeshore is valued primarily for the 

conservation of its natural resources. Correspondingly, this alternative proposes the 

largest acreage of wilderness including most 

(about 33,600 acres) of the more than 36,000 

acres of wilderness-eligible areas. In comparison to the no-action alternative, the wilderness proposal in this alternative adds the 

Sleeping Bear Plateau and removes some of 

the fragmented areas described above. No 

developed county roads are within areas 

proposed for wilderness. None of the Lake 

Michigan active beach zone is in areas 

proposed for wilderness. 

The overall vision of alternative B is that the 

National Lakeshore is valued primarily for its 

recreational opportunities in scenic outdoor 

settings. Because alternative B could potentially allow recreational facilities and 

moderate numbers of visitors in most areas of 

the Lakeshore, it proposes wilderness only on 

North Manitou Island, about 14,400 acres. 

There is no wilderness proposed in alternative 

B on South Manitou Island or the mainland. 

No county roads are within areas proposed 

for wilderness. None of the Lake Michigan 

active beach zone is in areas proposed for 

wilderness. 

The overall vision of alternative C is that the 

National Lakeshore would be managed so that 

most visitor use is concentrated in selected 

areas, with more natural, primitive conditions 

promoted in the rest of the Lakeshore. 

Consequently, alternative C was chosen to 

represent a wilderness proposal containing a 

partial amount of the eligible wilderness, 

about 23,200 acres, including almost all of 

North Manitou Island, slightly more than half 

of South Manitou Island, the Sleeping Bear 

Plateau north of the Pierce Stocking Scenic 

Drive, and the area west and south of the 

Platte River. No developed county roads are 

within areas proposed for wilderness. None of 

the Lake Michigan active beach zone is in 

areas proposed for wilderness. 

 

The wilderness proposal for the preferred 

alternative is discussed in the “Wilderness 

Proposal” section on the next page. 

PUBLIC COMMENT ON WILDERNESS 

Early in the planning process for this General 

Management Plan / Wilderness Study / 

Environmental Impact Statement it became 

apparent that many members of the public 

had misperceptions about wilderness. In 

particular, many people opposed wilderness 

designation thinking that it would close much 

of the park to the public, while at the same 

time many also expressed their support for 

continuing current management of the 

National Lakeshore, not realizing that more 

than 30,000 acres were already being managed 

as wilderness. Lakeshore managers held 

public meetings and media interviews and had 

many other communications with the public 

in an effort to provide correct information 

regarding wilderness. 

In October 2006 the National Park Service 

distributed Newsletter #3, which presented 

four alternative management concepts that 

were developed with public input and represented different ways to manage the National 

Lakeshore. Each of the management concepts 

included a distinctive (a) overall vision, (b) 

description of the relative proportions of the 

various management zones, and (c) the 

amount of wilderness that would be proposed 

for designation. 

Public support for the four management 

concepts was fairly evenly distributed, with 

the “resource enjoyment” and no-action 

concepts receiving somewhat greater support. 

Many respondents to Newsletter #3 expressed 

either support or opposition to wilderness 

designation within the National Lakeshore. 

Most who supported wilderness did so 

because they value natural conditions, 

primitive recreation, and opportunities for 

solitude, particularly as areas surrounding the 

Lakeshore become more developed. Some 
Wilderness Study and Proposal 

87 

who opposed wilderness pointed out that few 

areas within the National Lakeshore are truly 

pristine. Others opposed wilderness due to a 

perception that it would restrict access or 

because they believe it is contrary to the 

purpose of the Lakeshore. 

In March 2007, the National Park Service 

distributed Newsletter #4, which presented 

four preliminary alternatives developed from 

the concepts described in Newsletter #3. Each 

preliminary alternative included a more 

detailed wilderness proposal. Alternative A, 

with the most extensive wilderness proposal, 

received support from 42% of the respondents. The no-action alternative received 

support from 15%; alternative B, with the least 

wilderness, received support from 18%; and 

alternative C, with a moderate amount of 

wilderness, received support from 19% of the 

respondents. Most people who supported 

alternative A said the more substantial 

wilderness proposal in this alternative was a 

main reason they supported it. Fewer of the 

supporters for the other alternatives cited 

wilderness amounts as the reason for their 

preference. 

WILDERNESS PROPOSAL 

The overall vision of the preferred alternative 

is that the Lakeshore is valued primarily for 

the preservation of its natural resources and 

for the opportunities it provides for visitor 

enjoyment of natural, cultural, and 

recreational resources in a scenic outdoor 

setting. In keeping with this vision, as well as 

with public comment, the NPS preferred 

alternative proposes wilderness for most of 

the eligible lands but excludes the developed 

county roads. Six areas totaling 32,200 acres 

are proposed as wilderness: (1) nearly all of 

North Manitou Island, (2) most of South 

Manitou Island, (3) an area around Good 

Harbor Bay (northern portion of the 

Lakeshore), (4) the Sleeping Bear Plateau 

(central portion of the Lakeshore), (5) an area 

around Otter Creek (southern portion of the 

Lakeshore), and (6) an area west of the Platte 

River (southern portion of the Lakeshore). 

After studying the various options and 

considering public comment, the National 

Park Service has tentatively concluded that 

wilderness designation of these areas helps to 

fulfill its mission at Sleeping Bear Dunes 

National Lakeshore by ensuring protection of 

the values of naturalness and solitude for the 

purposes of recreation, scenic, scientific, 

educational, conservation, and historic use. In 

addition, wilderness designation of most of 

the eligible lands best fulfills the wishes 

expressed in public comment, as most respondents wanted the Lakeshore to remain largely 

the way it is now — which is to have these 

areas managed as wilderness but with existing 

roads remaining open and excluded from 

wilderness. 

Ultimately, wilderness studies typically result 

in a recommendation to Congress to designate 

all, some, or none of the lands possessing 

wilderness character as part of the national 

wilderness preservation system. Based on the 

Wilderness Study in this document, the 

National Park Service anticipates forwarding a 

wilderness proposal to the U.S. Department of 

the Interior at the conclusion of the current 

planning effort. The secretary of the interior is 

then responsible for reviewing this proposal 

and either approving or revising it before 

forwarding it on to the president as recommended wilderness. The president then 

formally transmits this recommendation to 

both houses of Congress for action. The 

process for establishing wilderness is 

described in more detail in a “Wilderness 

Review and Management Process” flowchart 

that can be found in NPS Management Policies 

2006 (Section 6.2) (see following page). 

 
CHAPTER 3: WILDERNESS STUDY AND PROPOSAL

88 

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89 

IMPLICATIONS OF MANAGING LANDS 

PROPOSED FOR WILDERNESS 

Congress passed a law in 1982 (PL 97-361) 

requiring Sleeping Bear Dunes National 

Lakeshore to manage areas proposed in the 

1981 “Wilderness Recommendation” to 

maintain their wilderness character “until 

Congress determines otherwise.” Because of 

this law, all lands included in the 1981

recommendation have been, and will 

continue to be, managed as wilderness 

unless and until Congress acts upon a 

recommendation. This is true even if this 

Wilderness Study produces a new recommendation that proposes to withdraw 

portions of those lands from wilderness. 

In addition to the lands in the 1981 recommendation, any additional lands that are 

proposed for wilderness designation in the 

“Record of Decision” for this planning process are to be managed as wilderness until 

such time as Congress specifically decides 

whether or not to include them in a formal 

wilderness designation (NPS Management 

Policies 2006). That is, management activities 

on lands proposed for wilderness cannot 

diminish the wilderness eligibility of those 

lands. 

PLANNING AND MANAGEMENT 

Once wilderness, if any, is designated, a 

wilderness management plan is typically 

developed to guide preservation, management, and use of NPS wilderness areas. Such a 

plan is developed with public involvement and 

contains specific, measurable objectives for 

preservation of wilderness values as specified 

in the Wilderness Act and NPS management 

policies. Wilderness management plans, 

which are often combined with backcountry 

management plans, articulate management 

actions such as regulations, monitoring, and 

permit systems such as those currently in 

place for backcountry camping on the 

mainland and islands. 

Management decisions affecting wilderness 

will be consistent with the “minimum requirements” concept. This concept is a documented process used to determine whether 

administrative activities affecting wilderness 

resources or visitor experiences are necessary 

in wilderness, and if so, how to minimize 

impacts from such activities. Parks are to 

complete a minimum requirements analysis 

for administrative actions and equipment uses 

that have potential to affect wilderness 

character. 

Where practical alternatives do not exist, 

maintenance or other activities may 

occasionally be accomplished through the use 

of motorized equipment. The use of motorized equipment should be based on the minimum requirement concept. Motorized equipment need not be allowed for activities that 

can reasonably be accomplished using 

nonmotorized means. 

PRIVATE RIGHTS 

Wilderness designation does not extinguish 

valid existing private rights such as land or 

right-of-way ownership or valid mineral 

interests. Valid private rights in wilderness are 

administered in keeping with the specific 

terms and conditions of each right. 

RECREATIONAL USE 

Recreational uses of NPS wilderness are to be 

of a type and nature that enable the areas to 

retain their undeveloped primeval character 

and influence, protect and preserve natural 

conditions, leave the imprint of man’s work 

substantially unnoticeable, provide 
CHAPTER 3: WILDERNESS STUDY AND PROPOSAL

90 

outstanding opportunities for solitude or 

primitive and unconfined types of recreation, 

and preserve wilderness in an unimpaired 

condition. Hunting and fishing are 

appropriate uses of wilderness at Sleeping 

Bear Dunes National Lakeshore. Public use of 

motorized equipment or any form of 

mechanical transport is prohibited, except as 

provided for in specific legislation. Operating 

a motor vehicle or possessing a bicycle in 

wilderness is prohibited. The use of a 

wheelchair, as defined by the Americans with 

Disabilities Act of 1990, is allowed in 

wilderness. Service animals accompanying 

persons with disabilities are also allowed in 

wilderness. 

EMERGENCY SERVICES 

In emergency situations involving the health 

and safety of persons, the use of aircraft, 

motorboats, and other motorized or 

mechanical equipment is allowed. Wildfires 

will be controlled as necessary to prevent loss 

of life, damage to property, the spread of 

wildfire to lands outside wilderness, or 

unacceptable loss of wilderness values. The 

use of tool caches, aircraft, motorboats, and 

motorized firefighting equipment may be 

permitted for such control. Prescribed fire 

and hazard fuel reduction programs may be 

implemented according to approved plans. 

The minimum requirement concept will be 

followed for all fire activities in wilderness. 

RESOURCE MANAGEMENT 

AND RESEARCH 

Wilderness designation does not prevent the 

National Park Service from protecting and 

maintaining historic and other cultural 

resources located within wilderness areas. 

Using the minimum requirement concept, 

these resources will be protected and 

maintained according to the pertinent laws 

and policies governing cultural resources. 

Natural resource management activities may 

be carried out in a similar fashion, and will 

generally be undertaken only to address the 

impacts of past and current use or influences 

originating outside of wilderness boundaries. 

Natural processes will be allowed, insofar as 

possible, to shape and control wilderness 

ecosystems. 

Scientific activities are appropriate in 

wilderness. Even scientific activities 

(including inventory, monitoring, and 

research) that involve a potential impact to 

wilderness resources or values (including 

access, ground disturbance, use of equipment, 

and animal welfare) are 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. 

See also “Uses and Management in 

Wilderness” in chapter 1 of this document.