High Peaks VUM Pilot Project

High Peaks VUM Pilot Project

Josh Clague, Director, Bureau of Forest Preserve
NYS Department of Environmental Conservation (DEC)
625 Broadway
Albany, NY 12233
Re. 2025 Visitor Use Management Pilot Project, High Peaks Wilderness Project Area

Dear Josh,
In 2019, DEC sponsored a well-attended High Peaks Stakeholder Meeting in Keene Valley. All concluded that better data was needed to inform management decisions. Questions posed to stakeholders that day included: “how many people are using the trails? When are they using trails? Which trails and trailheads? What is the parking capacity? How much use can the trails sustain? How many of us can the summits accommodate?”

You and your DEC colleagues have now delivered answers to some of these key questions via consultants trained in the Visitor Use Management (VUM) framework. This Pilot Project report provides the first measured correlation between High Peaks Wilderness perimeter access and interior crowding – data that has long been identified as needed by DEC and the approved 1999 High Peaks Complex Unit Management Plan.

The consultants competently facilitated stakeholder input and examined goal setting, impact analysis, desired conditions, related indicators, thresholds, and management recommendations for improving recreational safety and visitor satisfaction in parts of the eastern High Peaks Wilderness. They did this taking into account foundational guidelines for management of Wilderness areas.

However, this Project’s final VUM assessment is also seriously incomplete in several important ways which we will describe.

Study Incomplete: For more than 50 years, NYS DEC Unit Management Plan (UMP) draft and final reports have referred to the Adirondack Park State Land Master Plan’s (hereafter, the “Master Plan”) required “assessment of the physical, biological and social carrying capacity of the area with particular attention to portions of the area threatened by overuse.” In the last 15 years, UMP’s have referred to the Limits of Acceptable Change (LAC) protocol as the preferred planning approach in which to conduct those assessments. Yet, LAC assessments were never completed due to reluctance to assume accountability for related management decisions. Over the last five years, DEC has changed the preferred method for these assessments from LAC to Visitor Use Management or VUM. Yet, LAC and VUM are essentially the same planning process. DEC chose this VUM Pilot Project to be “intentionally focused on visitor experiences and public safety,” and to “augment NYS DEC’s internal capacity to address resourcerelated monitoring and management.”

To date, DEC has not demonstrated commitment to conducting the full VUM process to include physical and biological condition assessments integrated with the social assessments, resulting in one comprehensive VUM assessment. Until all VUM assessments are made and integrated, this VUM Pilot Project study must be deemed incomplete. We urge DEC to move expeditiously to include biological and physical condition assessments of the same subregions examined in this Pilot Project, completing the comprehensive VUM assessment required by the Master Plan. In addition, our comments note the failure of this Pilot Project to undertake the necessary VUM studies for the very important and complex Johns Brook Valley subregion in Keene. This failure also marks the Pilot Project as incomplete. The consultants should be rehired to finish this important work.

Historical Context: The Project seems out of context with history. While it refers to prior planning, it does not highlight its direct connection with prior plans, and citizen input between 1975-2019. This Pilot falls within a historical continuum, not dropped out of a clear blue sky. While it advances our understanding of recreational safety and Wilderness visitor satisfaction indicators and thresholds, its management recommendations will not surprise former DEC High Peaks planners, managers, and stakeholders.

Adirondack Loj subregion: The Pilot Project report presents evidence that Vehicles Parked at One Time (VAOT) is a reliable and measurable parking indicator and threshold to be employed at Adirondack Loj, South Meadows Road (Meadows Lane) and Adirondack Loj Road trailheads. The Project presents strong evidence that VAOT as an indicator is statistically related to other key chosen indicators such as levels of perceived crowding on the summits ( or Persons Per View, PPV) atop Mt. Marcy, Algonquin and Cascade.

The importance of correlating interior conditions – in this case, Wilderness hiker satisfaction on trails and on summits – with perimeter parking is historical in nature. As stated in the 1999 High Peaks Wilderness Complex Unit Management Plan, “attempts were made in the 1970s to balance trailhead parking with the carrying capacity of the Wilderness. However, the absence of enforceable parking controls on trailhead access roads makes this difficult…contributing to undesirable user concentrations at entry points…It is necessary to make adjustments and/or restrict entry through some trailheads to reduce crowding and improve safe traffic flow.”

A recommended management action in the 1999 UMP was to: “develop individual special parking plans for Elk Lake, South Meadows, the Garden, Adirondack Loj, and the Ausable Club…Access roads to these facilities need to be carefully managed if analysis shows overuse and restricted traffic flow.”

The “careful management” referred to in the 1999 UMP included an inventory of interior primitive camping sites and to close many of those sites that were violating State Land Master Plan Wilderness management guidelines. These difficult but necessary interior management actions were taken in the early 2000s. Next, the UMP proposed to construct a 100-vehicle parking lot at South Meadows Road and Adirondack Loj Road intersection and create a DEC visitor service facility there to communicate with and serve hikers. Concurrently, DEC was to ask the Adirondack Mountain Club (ADK) to limit their parking lot to 200 vehicles and to ask the Town of North Elba to post and enforce No Parking on South Meadows and Adirondack Loj roads. These combined, interrelated actions, while attempted, were never successfully undertaken. Parking limits and enforcement along the Loj Road and Meadows Lane have been challenging to implement ever since.

Given the problematic past attempts to balance the High Peaks Wilderness resources in the interior with perimeter parking, and given a doubling of hiker pressure since 1999, a combined 300-vehicle capacity at ADK Loj and Meadows Lane would now make existing conditions worse and further compromise Wilderness interior resources. We support the Pilot Project’s key recreational indicator of Vehicles at One Time (VAOT), and the threshold of 180 vehicles parked at one time using the Adirondack Loj parking lot. The 180 maximum capacity there has been shown by the Pilot Project tocorrelate closely with the upper threshold of 400 persons accessing the trails to Mt. Marcy per day and the upper threshold of achieving fewer than 10 persons per view (PPV) on the summits of Mts. Marcy, Algonquin, and Cascade most of the time. The PPV desired condition would also enable Summit Stewards on Marcy, Algonquin, and other peaks to have more meaningful, one on one educational conversations about endangered alpine vegetation and Leave No Trace stewardship. According to the 2024 Summit Steward report, stewards attempt to communicate with several dozen or more hikers on the summits at any given time during peak weekends.

On Site Parking Management: Next comes the question of which management strategy to employ to maintain parking capacity at the Loj to 180 vehicles, and to prevent overflow parking on the Adirondack Loj Road and Meadows Lane. We are skeptical that the recommended On Site Parking Management team is a sufficient management action. First, years of unsuccessful attempts at collaboration to enforce “No Parking” along these roads hardly inspires confidence today. Second, the recommended 2-4 dedicated staff to regulate parking along Loj Road and Meadows

Lane are too few in number and would expose those few to high-risk encounters with the hiking public. The Loj Road is too long. There are no practical check points along its length. The management team members would be isolated from one another. The burden and risks to young employees attempting to enforce against illegal parking are too great to make this an effective and sufficient management strategy. Parking Reservation System: To ensure that a 180-vehicle parking capacity is not exceeded, we recommend that DEC institute a parking reservation system using the well-tested Reserve America online reservation service. A well-designed reservation system removes the anxiety of arriving only to find no available, legal parking space. We think that a parking reservation system, employed in conjunction with parking enforcement) at Loj Road and Meadow Lane, would work better and be more acceptable to hikers than the hiker permit option recommended in the Pilot Project. Due to hiking pressures and Master Plan guidelines, DEC has long considered various forms of reservations or permits. The 1978 draft of a High Peaks UMP weighed eight permit alternatives along a spectrum ranging from mandatory registration and reservation permit systems…to no control at all. Alternative C, reservation or permit systems, stated that “through past experience the U.S. Forest Service has found that a permit system is one of the best ways of gathering user information concerning an individual management area.”

The 1994 Draft High Peaks UMP stated that “Wilderness permits are a key management tool for protecting wilderness resources and ensuring high quality visitor experiences.” It further stated that these systems were extensively deployed in the National Park Service, the U.S. Forest Service and other public land agencies in the U.S. and Canada. The 1999 adopted UMP stated that within three years of the UMP a working group would be formed to study and develop (within five years) the structure and implementation process for a camping permit system, requiring an amendment to the UMP. That work was never undertaken.

Since 2021, a parking reservation system has been employed successfully for Forest Preserve trailheads starting at Adirondack Mountain Reserve (AMR) in Keene Valley and at the Catskill Forest Preserve’s popular Peekamoose “Blue Hole” swimming area. According to visitor use surveys and studies conducted by investigators at SUNY College of Environmental Science and Forestry, the AMR parking system has resulted in fewer road safety issues, less resource damage on selected High Peaks Wilderness trailheads, and reasonable levels of hiker satisfaction knowing that they are guaranteed a parking space. According to resource stewards, resource conditions have improved at the Catskill Forest Preserve’s “Blue Hole” since the Reserve America system was deployed.

With the consent and cooperation of North Elba, a similar system could be employed at a well-signed parking reservation station created at Adirondack Loj Road and Meadow Lane where personnel employed by ADK, DEC, and Town of North Elba, or a partnership of all three, could check parking reservations and flag those with advance reservations onwards to the 180-vehicle ADK parking facility. Those without reservations could be more easily turned around here, avoiding road congestion and confusion at Adirondack Loj. Parking enforcement along Loj Road and Meadow Lane will also be needed.

A year of preparation, testing, education, and notification before parking reservation deployment, including an amendment to the High Peaks UMP, would seem necessary. A certain number of parking allotments could be held back by the system to allow for spontaneous same-day hiking opportunities at Adirondack Loj trailhead. This and other lessons learned and adjustments made in the AMR parking reservation system in Keene Valley, based on public criticism and comment, will give DEC many practical insights into preparation, design and testing of an Adirondack Loj reservation system. Why do this? The Adirondack Park State Land Master Plan Wilderness guidelines make it clear: “Each individual unit management plan will seek to determine the physical, biological and social carrying capacity of the wilderness resource. Where the degree and intensity of permitted recreational uses threaten the wilderness resource, appropriate administrative and regulatory measures will be taken to limit such use. Such measures may include, but need not be limited to: the limitation by permit or other appropriate means of the total number of persons permitted to have access to or remain a wilderness area or portion thereof during a specified period; the temporary closure of all or portions of wilderness areas to permit rehabilitative measures.” Revitalized partnerships in education, outreach, and parking management will all be necessary to reach desired conditions. However, for decades these traditional management steps have been found insufficient. The SLMP and High Peaks UMP make clear: where indirect, educational means are shown to be insufficient, limitations by permit or other appropriate means shall be undertaken to ensure that Wilderness interior desired conditions are met.

For this very reason, parking reservations for day-use and overnight camping have been required for decades at preserves such as Maine’s Baxter State Park, to pick one example. While the reservation process at Baxter requires advance preparation, it is not onerous. To the question “why do we do this,” Baxter State Park staff respond: “we limit access to Katahdin to preserve the fragile alpine ecosystem and your experience as a visitor. Remember, as trustees of Governor Baxter’s deeds, we are charged with doing this in perpetuity, which is a very long time.” Similar language could be employed by DEC in the High Peaks, for example: “we institute reservation systems to preserve the resources of the High Peaks Wilderness, including its fragile alpine ecosystem, because we are Wilderness stewards responsible for the State Land Master Plan’s Wilderness management guidelines, the Wilderness recreational experience, and the ‘forever wild’ clause of the NYS Constitution.”

Cascade/Porter Mountain Subregion: The Pilot Study recommends that as soon as the new trail to Cascade peak is complete, parking management be employed at ORDA’s Mt. Van Hoevenberg Olympic Sports Complex. It recommends on-site parking management teams of two people limit hiker parking to no more than 100 vehicles, the equivalent of no more than 240 people accessing the Cascade Mt. trail daily, in order to achieve the Study’s desired condition of fewer than 10 per view (PPV) on Cascade during peak weekends.

To achieve desired conditions, parking management will need to be much more robust than what is recommended. As the report states, “the parking supply at Mt. Van Hoevenberg can accommodate substantially more than 240 visitors per day to access the Cascade Subregion.” This is serious understatement. The six huge parking lots at the Olympic Sports Complex have space for thousands of cars. Once the new Cascade trail is open and the current access off Rt. 73 closed, pressure to fully utilize available parking at the Olympic Complex will increase. A more robust management response and investment than what this Pilot recommends – by ORDA and DEC- will be necessary to achieve the Pilot Study’s desired conditions on the trail and on Cascade. At least six or seven on-site parking attendants, in addition to volunteer stewards and a DEC Forest Ranger, may be needed to limit parking to 100 cars, and to greet and communicate Leave No Trace and other advice. ORDA should make a significant financial contribution from its annual budget to needed signage, training, personnel, and on-site parking management.

Johns Brook Valley Subregion: The most surprising aspect of the Pilot Project study is this statement: “due to finite project resources, data were not collected as part of this project to assess crowding impacts and estimate crowding-related capacities for the Johns Brook Valley Subregion.” Given significant and complex Wilderness access issues and impacts stretching from Keene Valley, The Garden parking, past John Brook Loj, Slant Rock, and on to the summits, this gap in the Project’s data collection and assessments is disappointing and reflects poorly on the Project’s initial design and contract.

Placing much of the responsibility now, as this Pilot Project appears to do, on the Town of Keene to undertake current conditions, perimeter parking, and other studies are unfair and impractical. The recommended work is too urgent to leave solely to a small town’s supervisor’s office and partner volunteers. The situation demands DEC’s full attention, financial support, and, if necessary, new VUM contract. Thanks to strong legislative support in Albany, DEC has sufficient Forest Preserve stewardship resources to design and contract for this needed, additional work in Keene.

On behalf of Adirondack Wild, thank you for considering our comments, which we may supplement in future correspondence. We look forward to assisting the Department in carrying out its visitor use management responsibilities in the High Peaks Wilderness and beyond.

Sincerely,

David Gibson, Managing Partner Adirondack Wild: Friends of the Forest Preserve
P.O. Box 9247, Niskayuna, NY 12309
Adirondackwild.org
518-469-4081; [email protected]

Cc: Amanda Lefton, DEC Commissioner
Katie Petronis, Deputy Commissioner, Natural Resources
Fiona Watt, DEC Director, Lands and Forests
Joe Zalewski, DEC Regional Director, Reg. 5
Megan Phillips, APA
APA Members and Designees
High Peaks Advisory Group