Michigan Department of Natural Resources
PO Box 30028
Lansing, MI 48909
June 19, 2017
Re: Comments regarding revised ORV rules on state forest lands
Huron Pines mission is to protect the Great Lakes by conserving the forests, lakes and streams of Northeast Michigan. We work with a variety of public and private landowners, diverse user groups, local community leaders, conservation organizations and many others to accomplish our mission. Huron Pines also understands that a variety of recreation experiences are an important part of our economy and have recently participated in a stakeholder meeting hosted by DNR to provide input on the plan to open state forest roads for ORV use.
Huron Pines is providing site specific comments on the DNR Roads Web Map and found that tool to be very user friendly. We would ask that the non-motorized trails be labeled to help users navigate easier. Below are procedural or overall comments our organization is providing.
Our organization understands the timeline legislature has placed on the Department of Natural Resources to develop a roads inventory and make recommendations for proposed open, proposed closed or seasonally restricted. That being said Huron Pines has real concerns about the long-term impact these decisions will have upon our landscape with what appears to be no plan for managing additional use, increased resource damage and potential user conflicts. We have yet to see anything similar to an overall environmental impact study that opening 6,000+ miles of roads will have on our resources in the northern lower peninsula, nor have we seen information regarding the estimated economic impact communities in our region will see. There also doesn’t seem to be a plan in place for maintaining these roads with the increased use (at the stakeholder meeting we were told $0 were allocated for state forest roads), a monitoring plan or what additional funds will be available for resource damage and increased law enforcement.
Having worked on numerous land restoration projects resulting from ORV damage over the past 3 decades with the DNR, US Forest Service and private landowners, we have seen first-hand the resource damage that can be caused and the expense to restore the land. We also know that once a trail is laid down, or an area is open, it is extremely hard to deter future use. This is of particular concern to us in riparian areas, wetlands, stream crossings and areas with known endangered species.
At the stakeholder meeting it was unclear whether or not the DNR would be compiling public input and sharing that information. Huron Pines would strongly encourage the DNR to share those comments and how the DNR used that feedback to make final decisions. With only two days set aside for review of comments (July 17 & 20, 2017) and two weeks for final recommendation (August 9, 2017) it does not seem like there will be much opportunity for the Department to digest all of the public comments thoroughly.
Since the intent of opening state forest roads is to increase off-road vehicle use, obviously the state must be prepared to deal with increased user conflict, increased resource damage and increased trespassing—all issues currently documented. Here are a few items we ask the DNR to consider before final recommendations:
- Establish centralized ORV “hubs” in order to create a better destination experience for riders versus what appears to be a “ride anywhere” mentality. The “ride anywhere” concept creates opportunity for more damage to sensitive areas, it also takes away from the Pure Michigan vision of high-quality, well-managed recreation experiences for all.
- It was stated at the stakeholder meeting on June 14, 2017 that the intent of PA 288 was not to create dead-end trails with no loop. It was also stated that it was not the DNR’s intent to add additional roads to connect segments. Therefore, we propose the DNR reevaluate segments that dead-end, especially in sensitive habitat areas (Ecological Reference Areas, Natural River corridors, etc.) and consider them to be closed in order to prevent the creation of illegal trails.
- Many water quality and habitat decisions are guided by Section 319 approved watershed management plans. In northern Michigan, excess sediment loading from human impacts has been identified as the #1 non-point source pollutant in many of these watersheds. In fact, the majority of this sediment comes from road/stream crossings or road ends. Based on the current map provided by the state there are thousands of segments that either dead end at a stream or run parallel to a river or lake or appear to ford the river, a practice that always results in downstream sedimentation problems and is not appropriate for our coldwater, stable stream systems. We would ask that the state look very closely at these areas and when there is no loop or other “destination” available consider closing these segments to prevent resource damage, additional sedimentation and user conflict.
- There are many areas with roads are proposed open where ORVs will now intersect non-motorized trails (e.g. Black Mountain-Presque Isle County, North Higgins Lake-Crawford County). Less than 15% of state forest roads have been considered closed and from a recreation and user experience standpoint we would encourage the state take a closer look at some of these non-motorized areas and consider maintaining more “quiet recreation areas”.
- Develop a means of tracking increased use so that necessary adjustments can be made in subsequent years and we support increased allocation to the Department in order to meet long-term planning, restoration needs and have the capability to be able to respond quickly to problems.
- Collaborate with partners to develop a long-term plan to encompasses monitoring, enforcement, restoration and a funding mechanism.
The following are areas that Huron Pines supports closure of roads or recommends further thought be given to possible closures. In all of these cases by looking at the map there will be no shortage of opportunities on adjacent forestland for ORV use.
Pigeon River Country State Forest
Huron Pines fully supports the DNR’s decision to recommend the entirety of Pigeon River Country State Forest remain closed to ORV use on forest roads. The PRC is not only rich in unique and rare wildlife, high-quality streams, scenic sinkhole lakes, it is also an area that visitors and residents identify as a wild area and seek undisturbed experiences. Designating this as closed to ORV use also aligns with the Department’s own Concept of Management.
Mason Tract, Jordan River, Sand Lakes Quiet Area
Huron Pines also fully supports the DNR decision to keeping the Mason Tract on the South Branch of the Au Sable River, the Jordan River Area and Sand Lakes Quiet Area closed to ORV use. These are existing areas of quiet recreation for hiking, fishing, hunting, etc. and are certainly an important draw for visitors because of those meaningful experiences.
Kirtland’s Warbler Management Areas
From an endangered species, wildlife management and user conflict standpoint, we have several concerns about opening roads in Kirtland’s warbler management areas (or roads adjacent to USFS areas managed for Kirtland’s warbler). State and Federal agencies, universities and conservation partners have spent the better part of 40 years and significant financial resources on the recovery of the bird. It is a co-managed landscape that also provides habitat for the upland sandpiper, Eastern bluebird, white tailed deer, black bear and snowshoe hare, and for several protected prairie plants, including the Allegheny plum, Hill’s thistle, and rough fescue. Every year Michigan Audubon and the US Forest Service offer tours for bird watchers, drawing visitors from around the world. It is our understanding from the stakeholder meeting that neither the USFS or USFWS were consulted prior to designating opening most of these roads. Huron Pines strongly recommends the DNR review the suitable nesting area map and at a minimum requests the state close the roads to ORV use during nesting season (e.g. Staley Lake Road area.)
“The DeWard tract is a 4,720 acre special management area located in Antrim, Crawford, Kalkaska, and Otsego Counties. Plagued by damage from motorized vehicles, this special area was designated in 1980 to protect the Upper Manistee River Corridor.” — DNR’s Grayling Forest Management Unit’s website. In the proposed plan, all of the roads in this area are proposed open to ORV use which seems to be in direct conflict with management of this area. There is already existing resource damage on the hills (east side of Deward Tract) from illegal ORV use and we are very concerned about increased degradation in this area. Therefore, we ask the DNR to consider closure on some of these roads particularly when they lead to the river.
We live, work and recreate in northern Michigan and value the rich natural resources and access to public lands. Huron Pines offers our assistance to help implement comments suggested above.
Cc: Representative Triston Cole
Bill O’Neill-State Forester