October 7, 2003

Wilderness Study Coordinator
Apostle Islands National Lakeshore
Route 1, Box 4
Bayfield, Wisconsin 54814

Dear Wilderness Study Coordinator:

On behalf of the Board of Directors and staff of the Friends of the Boundary Waters Wilderness (“Friends”), please accept the following comments regarding the Draft Wilderness Study/Environmental Impact Statement for the Apostle Islands National Lakeshore. We appreciate the opportunity to share our concerns, comments and recommendations with you. Please make our comments part of the official record.

The Friends is a non-profit wilderness conservation organization with about 3,000 members from across the country. The mission of the Friends of the Boundary Waters Wilderness is to protect, preserve and restore the wilderness character of the Boundary Waters Canoe Area Wilderness (BWCAW) and the Quetico-Superior Ecosystem.

Staff members visited the Apostle Islands National Lakeshore for two days in July 2003 and attended open houses hosted by the National Park Service (NPS). We appreciate the time and effort taken by NPS staff members to present information and answer our questions.

Many Friends members and residents from Minnesota and throughout the upper Midwest visit the Apostle Islands National Lakeshore. Protecting the Apostle Islands is important to achieving a region of wild interconnected areas across northern Minnesota, Wisconsin and Michigan. Such efforts are important to the long-term health and protection of the Boundary Waters Canoe Area Wilderness.

I. EXECUTIVE SUMMARY
The Friends endorses a modified Alternative C, which designates most islands in the park as wilderness. Our proposed change is to designate Basswood Island as wilderness, with the exception of the dock on the west side of the island and a quarry on the southern tip of the island. These exclusions are consistent with a myriad of other areas throughout the park that historically have not been managed as wilderness, including, but not limited to, waterways, all public docks on the islands, and major cultural sites such as the six light stations and numerous historic residences and structures.

The Friends of the Boundary Waters Wilderness also offers the following comments and recommendations:

A. The Friends strongly opposes the addition of “limited facilities” and “additional visitor developments” relating to the cultural resources on Basswood, Sand, Rocky, and Stockton Islands, as noted in Alternative C.

B. The Friends urges the National Park Service to make its final decision regarding wilderness designation based on the Apostle Islands National Lakeshore’s suitability for wilderness – not based on the NPS’s plans for future development.

C. Discussion regarding future development should be part of the Park’s management plan – not part of the draft wilderness study. We would like to see a detailed explanation, in the Park’s management plan, why the National Park Service believes that additional facilities might be needed given the extensive current system of visitor facilities.

D. The National Park Service must ensure that the biologically-important sand bridge, or tombolo, that now connects Presque Isle to Stockton Island is protected given that “sandscape vegetation is … very sensitive to human trampling.”

E. The National Park Service must address ways in which it will protect the bear population from the encroachment of humans on both Stockton and Sand Islands.

F. The National Park Service must ensure the continuing protection of piping plovers’ habitat. We request that the final Wilderness Study include a discussion of how the Park Service will comply with its legal responsibility to not adversely modify or destroy critical habitat when Long Island changes from de facto wilderness to non-wilderness.

II. OVERVIEW
The Apostle Islands National Lakeshore lies at the northern tip of Wisconsin as it juts into Lake Superior. The 21 islands (Madeline Island is the only island not included in the National Lakeshore) range in size from three acres (Gull Island) to 10,054 acres (Stockton Island), and each of them is unique. There are old-growth forests; high hills and steep valleys; red sandstone bluffs and intricate sea caves; and one of the greatest concentrations of black bears in North America.

While the surrounding waterways (not slated to be designated as wilderness) provide recreational opportunities for a variety of boats (kayaks, motorboats, and sailboats), the interiors of most of the islands remain remote and primitive and their characteristics are consistent with the tenets of the Wilderness Act: “… an area where the earth and its community are untrammeled by man, where man himself is a visitor who does not remain…” [16 U.S.C.§ 1131 (c)].

III. COMMENTS ON PREFERED ALTERNATIVE C
A. Inclusion of Basswood Island as Wilderness
The Friends endorses a modified Alternative C, which designates most islands in the park as wilderness. The Friends urges the National Park Service to designate the 1,917 acre Basswood Island as wilderness, with the exception of the public dock and the quarry at the southern tip of the island. These exclusions are consistent with a myriad of other areas throughout the park that historically have not been managed as wilderness, including, but not limited to, waterways, all public docks on the islands, and major cultural sites such as the six light stations and numerous historic residences and structures.

Friends staff spent fours hours walking along Basswood’s shoreline and interior, and strongly believes that this heavily-forested island deserves wilderness protection. The island’s shoreline and interior were remote, quiet, wild, and exhibited “… outstanding opportunities for solitude or a primitive and unconfined type of recreation.” [National Park Service’s Wilderness Preservation and Management Policies, 6.2.1.1.].

Aside from a few small clearings, as a result of early farming, the dense forest of red oak, sugar maple, quaking aspen, white and yellow birch, eastern hemlock, balsam fir, white cedar, red and white pine, and a few basswood trees provides a true wilderness experience. Red squirrels are common; there are whitetailed deer; and the island’s diverse habitat attracts many of the 100 plus bird species that nest in the Apostles, including bald eagles. [www.nps.gov/apis/htm]

While there is evidence, to the trained eye, of the McCloud-Brigham Farm and the Rudd Farm, an old logging camp, and two quarries on the island, these sites are not incompatible with wilderness. According to the National Park Service’s Wilderness Preservation and Management Policies: “Lands that have been logged, farmed, grazed, mined, or otherwise utilized in ways not involving extensive development or alteration of the landscape may also be considered suitable for wilderness designation if, at the time of assessment, the effects of these activities are substantially unnoticeable or their wilderness character could be maintained or restored through appropriate management actions.” [National Park Service’s Wilderness Preservation and Management Policies, 6.2.1.2.].

For example, the McCloud-Brigham Farm, founded in 1865 and farmed until 1923, was the first homestead in the Apostle Islands. Today, there are remains of old buildings and stone walls that have all but been obliterated by the forces of nature. The remnants of this farm, along with the logging camp and quarries, enhance the visitor experience as they speak eloquently to a rich human history and the resilient power of nature. And, it is just that power Congress sought to preserve when it passed the Wilderness Act of 1964.

It should be noted that Congress occasionally has included historic evidence within wilderness designations. While not common, old mining shacks and herders’ shelters can be found in several wilderness areas in the western United States.

B. Opposition to Future Development
The Friends strongly opposes the addition of “limited facilities” and “additional visitor developments” relating to the cultural resources on Basswood, Sand, Rocky, Stockton Islands as noted in Alternative C. The draft study states that “they [Basswood and Sand] are ideally suited for the expansion of interpretive opportunities, such as some limited facilities to help visitors understand the historical and natural processes on the Apostle Islands.” [Draft, page 33]. Furthermore, the study states that the former fishing community on Rocky Island “… keeps open the possibility of providing additional visitor developments to accommodate increased use in one of the park’s most popular areas.” [Draft, page 34]. And finally, the study states that on Stockton Island, the new boundary would “… keep open the possibility of providing additional visitor developments to accommodate increased use in the immediate vicinity of these popular areas.” [Draft, page 34].

Interpretive opportunities and increased visitor use are not compelling reasons for additional facilities or developments. As outlined below (see V), the Friends believes there are others ways in which to interpret the rich cultural history of the islands other than building structures and erecting signage.

Furthermore, the Friends strongly discounts the argument that a possible increase of visitors to the Apostle Islands warrants additional visitor developments. The Apostle Islands National Lakeshore currently provides the following to its 195,000 annual visitors: a visitor center in the old courthouse building in Bayfield; a visitor center at Little Sand Bay; a visitor center on Stockton Island; six light stations, all of which are major visitor attractions; and the Manitou Island Fish Camp.

C. Concerns on Decision-Making Process
The Friends urges the National Park Service to make its final decision regarding wilderness designation based on the Apostle Islands National Lakeshore’s suitability for wilderness – not based on the NPS’s plans for future development. Specifically, we are concerned that in Alternative C, “some areas were excluded because of the potential for expanding visitor facilities.” [Draft, page 33]. Determining an area’s suitability for wilderness designation should not be based on the need for more development

IV. COMMENTS ON FUTURE DEVELOPMENT IN GENERAL
We are alarmed by the numerous references throughout the Draft Study that refer to future developments at a time when “lack of adequate funding for preventative maintenance and investment projects has accelerated the deterioration of aging park assets and historic structures, and multiplied the cost of maintaining these facilities” [Apostle Islands National Lakeshore Business Plan, page 10]. In fact, according to the Apostle Islands National Lakeshore Business Plan, the park operated in 2001 with an “…almost $3.5 million operational shortfall.” [Apostle Islands National Lakeshore Business Plan, page 3].

Discussion regarding future development should be part of the Park’s management plan – not part of the draft wilderness study. We would like to see a detailed explanation, in the Park’s management plan, why the National Park Service believes that additional facilities might be needed given the extensive current system of visitor facilities. We specifically question this need because “as of September 30, 2001, 85% of park visitors surveyed indicated satisfaction with appropriate park facilities, services and recreational opportunities.” [Apostle Islands National Lakeshore Business Plan, page 12].

V. COMMENTS ON CULTURAL RESOURCES AND INTERPRETATION
The Friends acknowledges that there is visitor interest in the history and cultural importance of the major cultural sites, such as Manitou Fish Camp and the six light stations. The Friends urges the National Park Service to consider a myriad of other ways in which to disseminate information on these cultural resources other than future development. For example:

1) Create “discovery site” pamphlets that would provide background information on these areas and allow visitors to “discover” the sites on their own rather than via interpretive signs, markers, or new structures.

2) Encourage Eastern National, a nonprofit that supports the park’s visitor services and research programs, to publish additional books, maps and other publications focused specifically on the cultural resources

3) Maximize the use of employees and volunteers stationed at the light stations and Manitou Fish Camp and educate them about other cultural resources within the park so that as they talk about their specific site, they can also share information about the numerous other cultural sites around the islands

4) Use the existing three visitor centers and light stations and develop additional displays and videos that focus on the cultural resources.

Again, the Friends believes that the historical significance of past human activity on these islands should not be overlooked as it provides a rare opportunity to examine the interaction between humans and nature. Humans have been on the Apostle Islands for hundreds of years, and today, the islands show many signs of human activity. Since the mid 1600s, fur trading, quarrying, farming, logging, and fishing have occurred. Today, there are reminders of these activities such as at the Manitou Fish Camp and quarry pits on Stockton, Hermit, and Basswood Islands.

The Apostles are a unique blend of cultural history and natural forces, and these values are worth protecting. The last “improvement” they need is additional man-made facilities.

V. COMMENTS ON NATURAL RESOURCES
The Apostle Islands are a product of more than one million years of the forces of nature. Wind, waves and ice have carved distinctive arches, extensive sea caves, and honeycomb cliffs into the shorelines of these islands. There are miles of sandscapes, including beaches, sand spits, cuspate forelands, tombolos and a barrier spit (Long Island, southwest of Madeline, is an example of a barrier spit). These unique sandscapes are constantly changing due to a variety of natural forces, and each of them supports a variety of ecologically-important plants and animals.

In addition, several of the islands boast old-growth forests, towering reminders of what was once found across all of northern Wisconsin. For example, on Sand and Outer Islands, large white pine and hemlock dominate the reserve areas.

Finally, the forces of nature have created remarkable conditions that allow plants and wildlife to survive and thrive. For example, Stockton Island boasts one of the greatest concentrations of black bears in North America, and they regularly inhabit Sand and Oak Islands as well.

In addition, there are more than 100 species of birds (including the bald eagle), 800 species of plants (one federally listed and 37 listed as rare in Wisconsin, and over 200 species of mushrooms on Raspberry Island alone), and 35 different mammals. By establishing the Islands as a wilderness area, we are able to protect and restore the ecological health of these islands for the benefit of both its natural and human communities.

We do have some comments and concerns regarding natural resources in the non- wilderness areas in Alternative C.

a. Concern and Question regarding the tombolo on Stockton Island
While we concur with the reduction of non-wilderness lands on Stockton identified in Alternative C and excluding Presque Isle from wilderness designation given the large number of administrative and housing units in the area, we are concerned about the ongoing protection of the biologically-important sand bridge, or tombolo, that now connects Presque Isle to Stockton Island. Throughout the Draft Wilderness Study, there are repeated statements regarding potential development on the non-wilderness portions of the islands and specific to Stockton, comments such as “… keep[ing] open the possibility of providing additional visitor developments to accommodate increased recreational use in the immediate vicinity of these popular areas.” [Draft, page 34].

Sandscapes are vulnerable to invasions of exotic species, especially where native vegetation has been affected by human disturbance [Draft, page 53]. This would be exacerbated if the National Park Service builds additional facilities on Presque Isle. In addition, sandscapes are sensitive to disturbances such as fire and storms as well as repeated human traffic that can cause the sandscape to revert to barren sand [http://www.nps/gov/apis/sandscap.htm]. The National Park Service must ensure that this unique, biologically-important sandscape is not destroyed given that “sandscape vegetation is … very sensitive to human trampling.” [Draft, page 53].

b. Concern for and comment on black bears on Stockton and Sand islands
Stockton Island boasts one of the greatest concentrations of black bears in North America, and “Stockton and Sand are the only islands with a known reproducing black bear population” [Draft, page 54]. While we concur with the reduction of non-wilderness lands on Stockton and the exclusion of Sand Island from wilderness, we are concerned about the potential increased human activity on both of these islands caused by possible new developments. The National Park Service must address ways in which it will protect the bear population from the encroachment of humans.

c. Concern for and comment on birds
The Apostle Islands boast more than 100 species of birds, and the islands serve as an important migratory flyway stopover in the Great Lakes region [Draft, page 54]. "Because the Midwestern landscape has been drastically altered since European settlement, maintaining the quality of remaining stopover sites is critical if birds are to reach their breeding or wintering grounds in good physiological condition… Larger, more ecologically diverse tracts of land with natural mosaics of forests, wetlands, grasslands and openings, are likely to be consistently attractive to many migrant species…” [Ewert and Hamas 1995].

The Friends is concerned that Long Island, which is excluded from wilderness designation in Alternative C, is a key island for these birds. According to the Draft Wilderness Study, “… Long Island[s] provide[s] key habitat for migratory birds” [Draft, page 55]. “…Long Island is important for waterfowl, passerines and shorebirds.” [Draft, page 55]. The National Park Service must ensure the continuing protection of these birds’ habitat if Long Island is no longer protected as wilderness which it has been, de facto, since 1989.

Furthermore, the Draft Wilderness Study states, “Long Island is the only location where piping plovers have successfully nested in the state of Wisconsin in recent years” [Draft, page 55]. The piping plover is an endangered species in the Great Lakes area. The coastal beaches traditionally used for nesting have been lost to commercial, residential, and recreational development.

On May 7, 2001 the U.S. Fish and Wildlife Service’s final determination of critical habitat for the Great Lakes breeding population of the piping plover was published in the Federal Register [Federal Register 2001]. This final rule designated two critical habitat units within the Apostle Islands. The Western Michigan Island Beach and Dunes unit lies entirely within the Apostle Island National Lakeshore and is designated as “suitable” for plover use. The Long Island/Chequamegon Point unit lies partially within the Apostle Islands National Lakeshore and is designated as “current” for plover use.

Clearly, Long Island is an important refuge for birds, including the endangered piping plover. As non-wilderness, we fear the potential loss of this key bird habitat. Section 7 of the Endangered Species Act (ESA) states, “Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency…is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species…” [16 U.S.C. § 1536 (a)(2)]. We, however, see no evidence of Section 7 consultation with the U.S. Fish and Wildlife Service. We request that the final Wilderness Study include a discussion of how the Park Service will comply with its legal responsibility to not adversely modify or destroy critical habitat when Long Island changes from de facto wilderness to non-wilderness.

Again, the Friends appreciates the opportunity to comment on the Draft Wilderness Study/Environmental Impact Statement for the Apostle Islands National Lakeshore. We look forward to receiving more information as the process progresses.

Sincerely,
Melissa Parker Lindsay, Executive Director

Sarah Strommen, Policy Director