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The Concept of Management Plan revisions for the
Pigeon River Country State
Forest (PRCSF) recently presented for approval by the Department of
Natural Resources significantly reduced access by equestrians in the
PRCSF. Why did this happen?
One major problem is
that there were no equestrians, as far as the MHC knows, on the Steering
Committee appointed by the MDNR to review and suggest modifications to
the Concept of Management Plan for the Pigeon River Country State
Forest. In fact, the MHC did not know anything about the changes
proposed to the Concept of Managment Plan until November 2007, too late
to have meaningful input into the Plan. When word finally got out,
there was a barrage of objections filed, the majority by equestrians.
The MDNR then established a Work Group to provide additional comments
related to cycle and equestrian uses. This Work Group consisted
of representatives from the equestrian and mountain bike users groups (3
each), the PRC Advisory Council, the PRC Association, hunting, fishing
and trapping user groups, Resource Stewards, and the DNR. It met twice
at the Pigeon.
The problem related to
horses appears to be that for about three weeks in the fall, during the
elk rutting season in mid-September/early October, there is a major
influx of equestrians who ride out and about to view this
spectacle. During the rest of the year, horses are relatively scarce in
the Pigeon.
As a result of the
Work Group meetings, the plan now includes three new loops for
equestrians out of the Elk Hill Campground. While better than nothing,
it's about the only concession that was made to equestrians. Rejected
was the suggestion to keep most service roads open to equestrians, even
though no real justification was given for closing them to horses.
Rejected were several less restrictive measures proposed to address the
issue. Rejected was the request to study the problem for a year before
taking any action so as to arrive at a less radical solution for
handling the glut of riders during that brief time in the fall, as well
as to address any other management or environmental concerns that might
be identified during that time. The MDNR also indicated skepticism
regarding resently-published peer-reviewed scientific studies that
conclude the presence of horses on the trails were not responsible for
the spread of invasive non-native species, and did not consider that
evidence in coming to its decision.
The DNR's new order
takes horses off all but a very select few of the Pigeon's service
roads (equestrians are allowed only on those service roads needed to
complete the three new loops referenced below). All off-trail riding is
strictly prohibited. Horses are confined to the shore to shore
trail, forest roads that are marked for equestrian use and public
roads. In addition, a few select service road sections and 2-track
forest roads are combined to create three new loops for horses out of
the Elk Hill campground. The Johnsonʼs Crossing Trail
Campground remains open for equestrian use. The 10 Elk Hill campsites
that are in the Equestrian Campground proper have been retained, but the
6 outlying campsites at Elk Hill have been closed.
Why? The
following excerpt from the minutes of the April 10, 2008, NRC
Meeting presents the DNR's position in the best light:
Mindy
Koch, Resource Management Deputy,
provided information including maps
depicting areas open for mountain biking, shore-to-shore equestrian
trail and other areas open for equestrian use.
Ms.
Koch provided a history of the
PRCSF. In 1919, P. S. Lovejoy, the architect of the DNR, had a vision
for the PRCSF and named it "The Big Wild." Today, keeping that in
context, the DNR is attempting to maintain this area as "The Big Wild."
As of today, 118,000 acres have been dedicated as the PRCSF which was
approved in the amended PRCSF Concept of Management.
The
original Concept of Management was approved in December of 1973 and was
the beginning of the DNRʼs formal adoption of a policy to protect and
maintain the natural beauty of its forests and waters and to sustain a
healthy elk herd and wildlife population. In 2005, a review and update
of the Concept of Management was requested by the NRC since there had
not been a thorough review and modifications to the Concept since 1973.
Issues occurring in the PRCSF pressed the need for review, such as
increasing and changing recreational uses; private development around
the forest; and increase in size of the PRCSF by 15,000 acres since 1973
but this increase was not taken into consideration; and increase in
knowledge and technology. In 2005, the NRC appointed a 10 person
Steering Committee to create a process to update the Concept of
Management. Seven subcommittees were created under the Steering
Committee each representing a chapter of the Concept of Management and
were represented by diverse interest groups and were charged with
providing recommendations to the Steering Committee to modify the
Concept of Management, of which they did do. The Steering Committee then
created a draft Concept of Management and held two public hearings in
northern Michigan.
Several
versions of the Concept of Management revision have been done, all of
which have been posted on the DNR web site for public review and
comment. The final draft of the Concept of Management was provided to
the NRC in October of 2007 and approved by Director Humphries in
November of 2007. Since the Concept of Management was approved, Land Use
Orders of the Director to address the issues, especially recreational
issues, have been posted on the NRC agenda for Directorʼs action. The
first Order was approved in December of 2007 limiting snowmobile use in
the PRCSF to forest roads and county road right-of-ways.
Before
the Director currently is an Order opening up seven research lakes that
had been closed to use to conduct research. A Work Group had been
established to provide additional comments to the DNR related to cycle
and equestrian uses. This Work Group consisted of representatives from
the equestrian and mountain bike users groups, the PRC Advisory Council,
the PRC Association, hunting, fishing and trapping user groups, Resource
Stewards, and the DNR. The revisions to the PRCSF Concept of Management
were not unanimous.
Ms.
Koch said there appears to be a
lack of understanding amongst the users of the PRCSF. It is fairly
unique in that it is a very large block of public ownership in the Lower
Peninsula. Other items that make the PRCSF unique is oil and gas
development has been very restrictive; unlike other state forests, a
significant amount of Game and Fish Fund monies were used for
acquisitions meaning the goal of the area was to encourage fishing and
hunting and to preserve that activity in perpetuity; and a core of the
elk herd in Michigan is located in the PRCSF and the DNR believes the
herd is moving out of the PRCSF.
Currently, Land Use Orders of the Director exist that have requirements
for the PRCSF, as well as other State forests, wildlife areas, and State
parks. One of the orders prohibits equestrian use on 17 sections within
the PRCSF. This is not a new development. These prohibited areas
surround the Elk Hill Equestrian Campground and the Johnsonʼs Crossing
Trail Campground. The Land Use Order being reviewed and discussed today
limits equestrian camping to Elk Hill Campground and the Johnsonʼs
Crossing Campground. It also limits equestrian use to State forest
roads, country right-of-ways, the shore-to-short equestrian trail and a
limited amount of closed two-track roads (management roads that do no
allow motorized use). That totals 280 miles in the PRCSF available to
equestrian use. Bicyclers have about 300 miles of available use in the
PRCSF. No campgrounds will be closed by the proposed orders. Closures
are due to budget cuts and the DNR hopes to reopen them once funding
becomes available.
The next
step if for the DNR to review 2500 acres of property recently acquired
north of the PRCSF (Le Grande Ranch) where the possibility of additional
equestrian use may be developed.
Commissioner Madigan asked if
equestrians users pay as do ORV riders. The answer was no.
Ms.
Koch said one of the major
biological concerns with equestrian use in the PRCSF is the disturbance
of wildlife habitat or disturbance of threatened and endangered species
in sensitive areas. User conflict concerns also exist.
(NRC
Minutes, Pages 4 - 6 )
To say the revisions
to the PRCSF Concept of Management were not unanimous is an
understatement. Moreover, the MDNR's position that there is an
apparent lack of understanding amongst the users of the PRCSF is
debatable at best. Rather, equestrian users' challenges to the Plan are
based on disagreement regarding the validity of the basis for
removing equestrains from the trails they have historically ridden.
These MDNR decisions adverse to equestrians may be the result of
reliance on "bad science" or of yielding to the wishes of competing user
groups who, unlike equestrians, were "at the table" when the changes
were being written and proposed. Or they may be the result of an
improper procedure, or no procedure at all, for making these kinds of
specific determinations for modification of the Plan.
Michigan
citizens, as well as equestrians, would benefit from passage of a state
law that requires the MDNR to have a procedure similar to that in
the National Environmental Procedures Act (NEPA), which includes an
environmental impact analysis, before it can close recreational trails
on state lands to equestrians (or any other user group, for that
matter). It is the
Michigan Horse Council's
position that any state administrative rules that make it the general
rule to exclude equestrians on state-owned lands on which there are
recreational trails should be regarded as unduly restrictive, unless
such an exclusion is supported by a NEPA-like review that includes an
environmental impact analysis. For example, scientific evidence does
not support the position of the DNR that horses spread invasive
non-native plant species. Nor is the use of horses on Michigan trails --
even remote, back-country trails -- necessarily incompatible with the
protection of fish and wildlife. The MHC believes the general
rule should be that horses, like hikers, shall be permitted on all
Michigan trails unless there is some cognizable reason for
their exclusion. The Michigan Horse Council also believes the state
legislature should mandate the MDNR institute a required procedure
similar to NEPA's in making that determination.
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