Lyme Timber Co., Big Brook/Perkins Clearing Tract Clearcut

Lyme Timber Co., Big Brook/Perkins Clearing Tract Clearcut

October 30, 2026
Aaron Ziemann
Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977
Re. APA 2026-0202, Lyme Timber Co., Big Brook/Perkins Clearing Tract Clearcut

Dear Mr. Ziemann,
Adirondack Wild is concerned about the lack of detailed, mapped information about vulnerable aquatic resources within the proposed 500-acre shelterwood forest harvest in the town of Arietta. Moreover, we are concerned that the DEC conservation easement requirements that the landowner adequately map all aquatic resource information and minimize or mitigate negative impacts from forest management operations are not being sufficiently followed in this application.

As the application reveals, forest operations proposed overlap the headwaters of the Jessup River, with numerous perennial and intermittent streams and associated wetland features involved. The proposed logging operations parallel the rivers, streams, and wetland features for miles. Neither the application nor the Lyme Adirondack Forest Company (LAFCO) forest management plan provides the Agency or the public with confidence that these aquatic resources will remain unaffected by the forest operations, or that any resource damage will be minimized to the greatest extent possible.

Poorly Protected Riparian Management Zones (RMZ): The permit application states that “APA classified wetlands, a classified brook, and several permanent unclassified streams can be found throughout the stand. These RMZs will be buffered per the requirements of the LAFCO management plan to prevent water quality impacts.”

Unfortunately, when it comes to buffering of watercourses and associated “requirements” the LAFCO management plan itself is entirely vague and cannot serve to reassure the Agency that aquatic impacts will be minimized, much less prevented as stated.

For instance, the LAFCO management plan states on page 64 and throughout that the goal within Riparian Management Zones is to “minimize operation of machinery within the riparian zones and try to limit the number of repetitive trips on the same trail and try to minimize ground disturbance” (emphasis ours).

What specifically is the limit to the number of repetitive trips that will minimize ground disturbance within these sensitive Riparian Management Zones? The Agency and the public are left to guess what they are. Simply trying hard to minimize impacts to riparian zones should be an unacceptable standard at the Adirondack Park Agency.

As for the protection of the banks and waters of intermittent streams and brooks, the LAFCO management plan states merely that the forest operator “will use professional judgment to protect water quality on intermittent streams.” Protection of all watercourses during this forest harvest, perennial or intermittent, should never be left to the forest operator to determine.

Inadequate Mapping: As for the application’s inadequate mapping, the LAFCO management plan states that its GIS system identifies all hydraulic features and “locates all streams, ponds, vernal pools, wetlands, and seeps” (page 64).

If that is the case, then this application fails to show these features in any detail. The APA and the public are presented merely with a large-scale, colored, schematic picture of the proposed forest harvest areas. While streams and wetland boundaries are crudely shown, the map and application do not provide the locations of vernal pools, ponds, and seeps despite the LAFCO GIS system assurance (page 64 of the management plan) that all these wetland features are identified and mapped throughout Lyme’s ownership.

Easement Requirements: Moreover, Lyme’s DEC Sustainable Forestry Conservation Easement (2007) states on page 32 that “Grantors Forest Management Plan shall include maps showing… special treatment areas,” identified in the easement as lakes, ponds, bogs, watercourses and wetlands, wild, scenic, or recreational rivers, and special habitats. To our knowledge, in this application the Agency lacks the easement’s required, detailed, mapped information of aquatic resources and other special treatment areas to arrive at a permit determination.

Zero “no cut” zones: While LAFCO’s management plan states that 100-foot RMZs must be flagged along 1st and 2nd order streams, wetlands, ponds, and vernal pools, the prescribed management plan within RMZs need only “consider” no-cut zones “in shallow or poorly drained soils” (page 66). Otherwise, operation of forest machineryneeds only be minimized within the 100-foot RMZ.

By contrast, the DEC conservation easement contemplates that no forest management activity shall take place within the 100 ft. buffer subject to certain conditions (page 33). That should be an APA permit requirement as well. Minimum one-hundred-foot no-cut buffers ought to surround all wetlands and all riparian corridors, permanent and intermittent. To preserve their biotic integrity, identified vernal pools should receive 750 ft.no-cut buffers on all sides. All these features should be carefully mapped in the harvest layout and georeferenced for the timber harvesters.

Forest and Soil Carbon: An extensive clearcut like this, along with proposed scarification of the forest soil, can be expected to cause a substantial loss of soil nutrients in the short-term, and over the longer-term compromise forest stand carbon sequestration and storage. Under the Climate Leadership and Community Protection Act, the Agency must consider and account for the carbon impact of its permit decisions.

Timber Harvest Plan: Adirondack Wild is not objecting to the shelterwood clearcuts or clearcuts with reserves proposed in the application. As the landowner, and subject to adherence to its multiple conservation easements and certifications, Lyme has the right and the expertise to develop harvest plans.

Conclusions: However, the application’s failure to map, buffer, and protect the harvest area’s abundant watercourses and wetlands (RMZs in the application) violates the terms of the DEC conservation easement. Therefore, we respectfully ask Agency staff to recommend project denial without prejudice, and to bring this proposal before the full Agency for its review, and to schedule a public hearing.

The Big Brook/Perkins Clearing conservation easement land contains a wealth of sensitive aquatic resources. Given its professionalism and forest certifications, Lyme Timber is more than capable of ensuring that all aquatic resources are mapped, evaluated, and impacts buffered through the use of no-cut riparian zones.

Thank you for considering our comments.

Sincerely,
David Gibson
Managing Partner
Adirondack Wild: Friends of the Forest Preserve
P.O. Box 9247
Niskayuna, NY 12309
518-469-4081

Cc: John Burth, Regulatory Programs
Agency Members and Designees
Sean Ross, Lyme Timber