Here is the response I received from the MIDNR rep in charge of the situation. It sounds like the MIDNR is working with the trial groups to provide an acceptable outcome, but this whole thing still scares me. I am unaware of the events in Illinois mentioned, but don't like the condition that something can be stopped on P-R funded lands because it "interferes with other public use of the area". I know the antis love to use this argument in regards to hunting. Also, it opens the gate for them to prevent me from running my dogs in the off season for training purposes.
The question:
I am writing this to protest the banning of dog field trials on MI's Wildlife Management Area's. I find it appalling that the people who fund these areas are now being denied their usage. Furthermore, I am outraged that I had to find out through a non-MI resident after the decision had been made. I am a subscriber to the MDNR email news wire and had not noticed any reference to these closings. What is going on here? What basis was there for banning trials? Who made this decision? Why weren't the men and women of MI who are affected by this notified, or allowed a say in the process?
The response:
Good morning---I hope to answer your questions as you've outlined them in your email but please feel free to send me another note and/or phone me if you have additional questions (517-373-3263).
The U.S. Fish and Wildlife Service (USFWS) contracted with the Defense Contract Audit Agency (DCAA) to conduct a national audit of the entire Pittman-Robertson Program (also known as the Federal Aid in Wildlife Restoration Act, or PR Act), with one of the focus areas being field trial activities. Michigan has been part of the audit process since mid-1998 and is currently awaiting a draft audit report from the federal auditors (target date of late January or early February 2000).
The Michigan Field Trial Association has known about this audit for the past couple of years. The association holds two meetings per year (of which I attend all sessions) and has known since the problems in Illinois that field trial activities have come under greater scrutiny by the USFWS---I have kept the association informed every step of the way. Two of the auditors and one federal aid representative even attended the December 1998 association meeting to provide information on the ongoing audit review.
Our division chief received a phone call from the USFWS representatives a couple of days ahead of the association's scheduled meeting in December 1999 and received verbal guidance (ahead of the written report) of the following findings in relation to field trial activities:
1. Use of P-R acquired or purchased lands for field trial activities will not be allowed; and
2. Use of lands maintained or managed with P-R funds (such as state game and wildlife areas) will not be allowed if it:
a). destroys habitat or interferes with habitat restoration
b). disrupts or destroys wildlife on the area
c). interferes with other public use of the area
d). requires additional facilities or habitat changes.
The immediate impacts to the clubs involve the first bullet item---the Department will cease to allow field trial activities on Lapeer, Allegan, and Sharonville State Game Areas, and Holly Recreation Area effective in the year 2000. Portions of these four areas were purchased with PR funds. I recognize the fact that this appears to be VERY short notice but in fact, it was a heads-up since we have not received anything in writing from USFWS yet.
In addition, the Department of Natural Resources will be conducting a review of all of our permitted field trial activities that occur on lands that are maintained with PR funds. A team of field employees will conduct this review and be asked to make recommendations on how future field trials may be permitted if they do not violate the USFWS conditions outlined above in the second bullet. Staff will continue to work closely with the field trial association as they work through this review.
The reasons behind USFWS ruling that field trial activities are not to be allowed on the four areas hinges on the lands being acquired with PR dollars. The Act's rules and regulations state that real property acquired or constructed with Federal Aid funds must continue to serve the purpose for which acquired or constructed---the restoration, conservation, management, and enhancement of wild birds and mammals, and the provision for public use of and benefits from these resources. Multiple use of these areas is encouraged, provided it does not interfere with this primary purpose of wildlife management and restoration.
Intensive uses, which cause modification of wildlife habitats or divert from the approved primary use, are considered a non-compatible use due to negative impacts on wildlife and wildlife habitat restorations. When wildlife management areas are utilized for other purposes to the extent that they are diverted from the approved primary use, the USFWS requires that either (1) the area be returned to its approved use, or (2) the area be replaced at not Federal cost by another area with commensurate benefits to fish and wildlife and of equal value at current market prices. Otherwise, the state becomes ineligible to receive further funds under the Federal Aid in Wildlife Restoration Program.
So where are we at this point?? Based on requests from the field trial association members at the December meeting, we have asked the USFWS if we could have a "phase-in" situation----allowing the year 2000 activities to occur with the understanding that by 2001 we'd have other alternatives in place. Our federal aid coordinator has put in such a request and we are waiting to hear back from the USFWS on whether or not they will agree to this type of scenario.
I am also working closely with Land and Mineral Services Division on reviewing the land acquisition records to verify that parcels of land in the 4 areas were purchased with PR dollars. We are compiling that information as we speak. We are also reviewing other designated field trial areas and confirming funding sources for acquisition.
I will be attending two upcoming field trial banquets to outline the information that we currently have available and have committed to keeping the association informed as we obtain more information.
I hope this information answers your questions, but please feel free to contact me if you have additional questions or would like further information.