Environmental organizations oppose Camp Grayling training area expansion proposal

In addition to boards representing several local governments, opposition to Camp Grayling’s requested training area expansion – currently, a proposed 162,000 acres of state land to be leased to the National Guard from the Michigan Department of Natural Resources – includes numerous environmental groups.

The Michigan United Conservation Clubs – a group with “40,000 members and 200 affiliated clubs,” according to MUCC – announced its opposition of the proposal in August of 2022.

“MUCC believes the National Guard has failed to properly justify the need for an expansion of this size. The DNR has a statutory obligation (Public Act 47 of 2009) to keep hunting lands open to hunting. An exception can be made for homeland security, but the expansion proposal has not demonstrated that need. The DNR has a duty to ensure that it does not approve proposals that could limit access and opportunity for Michiganders without good cause and a plan for mitigation of the impacts,” the Michigan United Conservation Clubs said in an email dated August 25, 2022 to the director of the DNR. “The militarization of our public land is not something to be taken lightly, and Michigan residents should not have to shoulder the burden for the country’s national security unless a valid and pertinent reason is proven to exist. To date, that reason has not been enunciated.”

“MUCC firmly believes that consideration of this proposal and the possible expansion does not fall within the department’s mission statement,” according to MUCC. “Nothing provided to the public by the DNR throughout this process has proven commitment to that mission, which commits ‘to the conservation, protection, management, use and enjoyment of the state’s natural and cultural resources for current and future generations.’”

The Sierra Club Michigan Chapter, in a letter to the director of the DNR, said the military training area expansion could be a “threat to species, hunting, fishing, and tourism.” The Sierra Club also questioned the “necessity” of the request and possible impact on water quality and the environment.

“The huge expansion of the military use of Michigan forests will cause an inevitable increase in environmental strain no matter the limitations imposed. Is this expansion an overwhelming and immediate necessity? Camp Grayling has made no effort to show such a necessity. In the absence of this showing, and given the impact of the expansion on every other important use of our forests, the preliminary approval needed to continue  processing the Camp Grayling expansion proposal should be denied,” according to the Sierra Club letter. “This expansion poses risks to our public health and waterways. Camp Grayling and military bases here and across the country have a history of contaminating our land and the water that not only many people rely on for drinking and recreation, but also many species rely on for habitat, putting stress on ecosystems.”

The Au Sable River Property Owners Association announced that it is “strongly opposed to the proposed Camp Grayling lease expansion from an area of 230 square miles to that of 480 square miles,” calling the plan “a threat to the future health and enjoyment” of area waterways and “a significant deviation from the mission statement of the (Michigan Department of Natural Resources).”

“We support a fully ready military. But the proposed expansion request by the (National Guard) is egregious, posing a significant threat to the headwaters and land surrounding the Au Sable, Manistee, Muskegon Rivers and is unjustified. Our opposition is directly in line with the mission of ARPOA to preserve, protect and enhance the Au Sable River watershed’s great natural endowments of wilderness scenery, unpolluted cold water, and stable forest habitat for the enjoyment of future generations. It is also in line with the positions taken by our companion associations such as the Anglers of the Au Sable, North Branch Area Foundation, and the Michigan United Conservation Clubs as well as the resolutions from the various townships,” according to the Au Sable River Property Owners Association.

The Michigan Environmental Council voiced its opposition of the proposal in a letter dated October 5, 2022 to the DNR director. In it, the Michigan Environmental Council questioned the necessity of the expansion and raised environmental concerns. Similar to letters from other organizations, the Michigan Environmental Council also questioned the DNR’s mission statement with regard to the potential lease.

“Not only is the Michigan National Guard’s need for an expansion unclear, but there are unknown effects to land and water from the proposed expansion. The Department of Natural Resources is tasked with protecting Michigan’s natural resources, yet the current plan to more than double the size of Camp Grayling falls short of this mission,” according to the Michigan Environmental Council.

Several letters of opposition from conservation groups mention the DNR and its “mission” and statutory duties.

According to the Natural Resources and Environmental Protection Act (Act 451 of 1994), available online through www.legislature.mi.gov, “The (Department of Natural Resources) shall protect and conserve the natural resources of this state; provide and develop facilities for outdoor recreation; prevent the destruction of timber and other forest growth by fire or otherwise; promote the reforesting of forestlands belonging to this state; prevent and guard against the pollution of lakes and streams within this state and enforce all laws provided for that purpose with all authority granted by law; and foster and encourage the protection and propagation of game and fish. Before issuing an order or promulgating a rule under this act that will designate or classify land managed by the department for any purpose, the department shall consider, in addition to any other matters required by law, all of the following: (a) Providing for access to and use of the public land for recreation and tourism. (b) The existence of or potential for natural resources-based industries, including forest management, mining, or oil and gas development on the public land. (c) The potential impact of the designation or classification on private property in the immediate vicinity,” according to Act 451.

In an online “DNR Q&A on Camp Grayling proposal” document accessed via www.michigan.gov through a “Camp Grayling lease update proposal” page link, the Department of Natural Resources cites different sections of the Natural Resources and Environmental Protection Act to answer the question “Where does the DNR get authority to lease state lands?”

“The department has the power and jurisdiction over the management, control, and disposition of all land under the public domain, except for those lands under the public domain that are managed by other state agencies to carry out their assigned duties and responsibilities. On behalf of the people of this state, the department may accept gifts and grants of land and other property and may buy, sell, exchange, or condemn land and other property, for any of the purposes of this part,” according to the Natural Resources and Environmental Protection Act. “The department may lease lands owned or controlled by the department or may grant concessions on lands owned or controlled by the department to any person for any purpose that the department determines to be necessary to implement this part.”

“This land would be leased from the Department of Natural Resources, which is typically done so in 20-year increments, though any amount of time can be agreed upon. It is unclear what kind of activities would fall under ‘electronic warfare’ and why this type of activity cannot be conducted on the current Camp Grayling grounds,” according to the Michigan Environmental Council. “Technology is a fast-paced field, and current ‘electronic warfare’ activities, whatever they may be, could be significantly different in just three to five years. The DNR has suggested a 1,500-foot buffer around Au Sable and Manistee river access in the proposed expansion area where military activity would be prohibited. However, this is insufficient to protect all of the areas of significant habitat within the proposed expansion, especially when dealing with unknown military activities and unknown effects resulting from those activities. The buffer does not appear to take into account important habitats, nor does it encompass watersheds as a whole, which not only includes lakes and rivers but protected wetlands, ponds, streams, and creeks that filter pollutants and feed into the Au Sable and Manistee rivers and ultimately into Lake Huron and Lake Michigan, respectively. These vital areas comprising Michigan’s ecosystem could be negatively impacted from unknown effects of activities associated with ‘electronic warfare.’”

Anglers of the Au Sable – an “environmental conservation organization founded in Grayling, Michigan, on January 18, 1987,” according to the group’s website – also sent a letter to the director of the DNR saying that the organization “emphatically opposes this proposed expansion.”

“This proposal seeks to incorporate into an already enormous military training complex the fragile watersheds of the Manistee and Au Sable Rivers, two of the most iconic and special rivers found east of the Mississippi River. (Anglers of the Au Sable) opposes the electromagnetic training and testing that is the National Guard’s stated use and is anticipated in this proposed expansion. Electromagnetic training involves potential serious risks, both known and unknown. Moreover, it is wrong to allow this expansion without a better understanding of electromagnetic training and testing, its risks, and whether it genuinely requires such an enormous addition to the Camp,” according to the Anglers of the Au Sable letter.

During recent meetings of local governmental boards, opponents of the Camp Grayling expansion – including some elected officials – have said that numerous other conservation groups and organizations also oppose the training area expansion.

Grayling Charter Township’s Resolution 23-02: Camp Grayling Lease and Air Space Expansion specifically mentions opposition by conservation groups as one of the reasons for its stance on the issue.

“Grayling Township residents have created/started and maintained multiple leading international conservation groups such as Trout Unlimited and Ducks Unlimited to name a few. Grayling Township cannot ignore the fact that every conservation group within our boundaries is opposed to the Camp Grayling expansion request,” according to Grayling Charter Township’s resolution.

Michigan Trout Unlimited offered its official opposition in a document dated September 1, 2022, citing “lack of specific and definitive written information regarding the scope and impact of this expansion proposal, and the lack of detailed justification of the necessity for it.”

“This proposal was communicated in haphazard and often chaotic or contradicting manners. The lands in question included enormous tracts of the Manistee River, portions of the Au Sable River, and included prolific amounts of the tributary streams feeding these watersheds. Throughout the rollout of this proposal, very little detail of the specifics of locations and restrictions on the use of the lands have been provided in writing. Most presentations of the proposal have been done via in-person public meetings or in-person small group meetings,” according to Michigan Trout Unlimited.

“Given the enormity of the lands proposed, and the myriad pathways for this proposal to impact natural resources, coldwater fish, recreational angling, and these watersheds, Michigan Trout Unlimited has a significant number of potential concerns or objections. Through the in-person meetings we have attended, the DNR and Camp Grayling staff have verbally addressed some of our concerns in ways that, if executed, would help to allay our opposition. However, none (of) these important details have been presented in writing in any form and thus we currently do not have assurances they will be addressed satisfactorily,” according to Michigan Trout Unlimited.

According to the Michigan Department of Natural Resources, via the “Camp Grayling lease update proposal” web page, “There are no anticipated environmental impacts from the proposal.” The page says the “DNR parcel review” part of the “Review process” will include use of the “Conservation Viewer tool to remove parcels where training could have negative impacts on fish, wildlife, and the natural landscape.”

The Michigan United Conservation Clubs announced in January of 2023 that “a preliminary review by the Michigan DNR shows that the lands available for lease by the National Guard for its Camp Grayling expansion proposal could be reduced significantly. The size and scope of the actual reduction would depend on the outcome of a formal DNR review of the proposed lease expansion area. That formal review has not yet been undertaken. The discussion of this preliminary review was at the quarterly meeting hosted by (Michigan United Conservation Clubs). This informal gathering of statewide and regional conservation organizations meets to discuss ongoing issues related to the DNR and works to collectively protect and enhance our outdoor heritage and conservation landscape in Michigan.”

On February 2, the Michigan Department of Natural Resources announced that it would be closing the public comment period for the “National Guard’s proposed expansion of its Camp Grayling training facility” at 5 p.m. on Wednesday, February 8.

The DNR – in its February 2 press release – acknowledged that it has received “several thousand comments” about the proposal “and staff has been evaluating public input as it is received.”

“The DNR will review the feedback received and continue discussions with the military about use of state-managed forest land for military training. Protecting water and maintaining public recreational access to land have been key concerns expressed by fishing, hunting, and conservation groups throughout the comment period,” according to the Department of Natural Resources.

Anglers of the Au Sable offered a statement following the announcement of the public comment period coming to an end on February 8.

“Enough is enough. We support our military, but this sensitive ecological area that has great economic impact and is an important natural resource for Michigan has borne enough of the burden. The affected property is the headwaters of two of the most significant trout streams in America, the Manistee and the Au Sable. The Guard has not cleaned up the PFAS mess it has created. The Guard is not living up to promises to clean up after itself, or keep out of the rivers themselves. There’s been no explanation of why the Guard needs so much more land when Camp Grayling is already the largest guard base in the nation. This expansion will not help the economy of the region, which relies far more on outdoors activities and recreation than on military spending,” according to Anglers of the Au Sable.