COMMENTARY: Debar Pond Lodge: 2025 DEC analysis falls short, again
Adirondack Wild: Friends of the Forest Preserve challenges DEC plan to raze historic Adirondack lodge
By Dave Gibson
In 2020, DEC issued a draft unit management plan (UMP) for Debar Wild Forest which included the removal of Debar Pond Lodge and in its place the creation of a 41-acre day use picnic and display area to be classified as Intensive Use. Among the details, DEC proposed widening the current access road for two-way traffic and constructing a lot of new parking for cars and buses.
DEC’s proposal was severely criticized by Adirondack Wild and by many others for facilitating greater intensity of use without evaluating the resulting impacts, and for eroding the peaceful serenity and wild character and quality of the shoreline, Pond, and adjacent trails. Fortunately, DEC heard the criticism, thought better about it, and withdrew the Intensive Use proposal.
Five years on, this past August DEC issued a Scope of Environmental Issues surrounding Debar Pond Lodge which included DEC’s preferred alternative to remove the Lodge and maintain the Wild Forest classification. Gone were the Intensive Uses, fortunately. Or were they?
So long as DEC explains its actions, the department’s preference for removing the Lodge while retaining the wild forest character of the shoreline may prove very defensible from legal and management standpoints.
However, DEC fails to explain – and that is unacceptable. Before removing the Lodge state law requires and the public deserves explanation and analysis of reasonable alternatives to its removal. Here, DEC falls short, as it did in 2020.
For example, DEC still fails to explain the constitutional and legal differences between the presence and maintenance of Debar Pond Lodge on the Forest Preserve – deemed unconstitutional and illegal – and the presence and maintenance of Camp Santanoni on the Forest Preserve – deemed both constitutional and legal.
Before taking down an Historic structure designed by a distinguished Adirondack architect, William Distin, NYS DEC needs to honestly evaluate and explain its action and the alternative courses of action. DEC judgement enters into any final decision, but that judgement must be informed by analysis.
Also, having dropped Intensive Use, the 2025 DEC Scoping document continues to use the term “day-use area.” Is the former Lodge footprint going to be restored to Wild Forest conditions, or not? DEC can’t seem to make up its mind and therefore continues to confuse the public. DEC can and must do better. Here is Adirondack Wild: Friends of the Forest Preserve’s comment letter to DEC:
“Adirondack Wild: Friends of the Forest Preserve appreciates the chance to think through the scope of environmental impacts resulting from DEC’s preferred alternative: removal of Debar Pond Lodge (herein, “the Lodge”) and restoration of the immediate area to natural conditions governed by the Wild Forest State Land classification. We will do so primarily by raising questions and seeking stronger analysis of impacts, alternatives, and defense of the preferred action.
We can appreciate why in this Scoping document the Lodge and other nearby structures are deemed not to serve DEC’s Adirondack Forest Preserve responsibilities. The Scope rationally judges the Lodge to have no State administrative, educational, or other functional uses related to the DEC’s statutory mission of care, custody, and control of the Forest Preserve. The Scope also rationally argues that the Lodge requires continual maintenance; and that the State lacks resources to maintain it.
Constitutional and legal issues: The Draft Scope states that “after considering many alternatives, absent a Constitutional Amendment the DEC must comply with existing law and there is no mechanism whereby Debar Lodge can remain.” DEC correctly argues that the Lodge’s presence on the Forest Preserve violates Article XIV, Section 1, NYS Constitution, which it plainly has done since the land was acquired for the Forest Preserve in 1979.
Interestingly, Camp Santanoni in Newcomb, acquired as part of the Forest Preserve in 1972, similarly violates Article XIV, Section 1. Article XIV has never been amended to allow Camp Santanoni to remain on the Forest Preserve; yet, DEC has been an active partner in preserving, maintaining, and educating at Camp Santanoni since the adoption of the Camp Santanoni Unit Management Plan in the 1990s. What is the legal distinction between the two sets of structures? We think the Draft Scoping document needs to address this question. Both Santanoni and Debar Pond structures are listed on the State and National Registers. Santanoni is also a designated National Landmark, but so is the entire Forest Preserve. The Environmental Conservation Law, ECL 9-0109(4), was enacted in 1983 to legislatively preserve Camp Santanoni, the result of almost a decade of strong interest in its preservation. No constitutional challenge of that law has been attempted. In 1983, little or no thought appears to have been given to Debar Pond Lodge, which had been acquired four years earlier. Does ECL 9-0109, however unconstitutional, also apply to Debar Pond Lodge? This DEC Scoping document should explain.
ECL 9-0109 lists legislative criteria for maintaining pre-existing historic structures and improvements on the Forest Preserve, limiting them to those acquired prior to the law’s June 21, 1983, enactment. Debar Pond Lodge was acquired in 1979, so it meets that threshold. Second, such structures must be listed or eligible for the State and National Register. The Lodge is so listed. Third, the DEC Commissioner must make findings that such structures can be maintained for public enjoyment and understanding of the Forest Preserve, or for departmental activities necessary to protect the Preserve, all the while without disturbing “wild forest character” of land on which the structures are located.
Here, Debar Pond Lodge may possibly meet the public enjoyment and understanding test even if it fails to support necessary departmental activities. Disturbance of wild forest character may be a factor at Debar Pond, but one could argue that such character has been similarly disturbed at Camp Santanoni on Newcomb Lake. The final criteria are that maintenance of the structure be in accordance with reasonable regulation of the Forest Preserve. Here again, there seems to be no clear distinction between Debar Pond Lodge and Camp Santanoni.
The DEC Commissioner may prove unable or unwilling to make the necessary Findings required under ECL 9-0109, and removal of Debar Pond Lodge may be ultimately judged the best course of action. Still, there seem to be statutory mechanisms similar to those which have preserved Santanoni allowing Debar Pond Lodge to remain. To comply with SEQRA, all legal issues surrounding the presence of Debar Pond Lodge on the Preserve and comparisons with Camp Santanoni should be explored and evaluated.
Preferred recommendation: Following removal of the Lodge, the preferred inclusion of an undefined number and size of parking lots, more picnic tables, an undefined number and location of interpretive displays, and undefined amount of tree cutting at Debar Pond Lodge in order to expand trails sounds very much like an Intensive Use Day-Use area proposed by DEC in 2020, and now rejected. In fact, the Scoping document includes the words “Day Use area” on page 4:
“Potential mitigation measures which may be developed in consultation with OPRHP may include documentation of contributing historic features (buildings) prior to their removal, and the development of public educational materials throughout the day-use area interpreting the history of the Debar Lodge site and the surrounding land.”
On pages 5-6, the Scope goes on to state:
“Trees and other vegetation will need to be removed for the construction of facilities, such as trails and parking areas, however such removal will be localized to the immediate project site…Proposed trails, parking areas, primitive tent sites, lean-tos, and educational signage will need to be constructed. Additionally, the Debar Lodge is proposed to be removed.”
These proposed actions appear inconsistent with restoring “natural conditions” in a Wild Forest area. There should be minimal, if any, construction of new facilities for access and recreation to Debar Pond and surrounding Wild Forest. The existing parking area may need some small future improvements and some minimal expansion of capacity, but there seems to be little justification for wholesale new parking areas. Regardless, perimeter parking capacity and any increase in primitive overnight camping, including lean-tos, should be predicated on a Wild Forest Visitor Use Management (VUM) assessment and carrying capacity analysis. SEQRA Scoping assumptions about future development of recreational facilities are premature and inappropriate because they are clearly not backed up by carrying capacity analysis as part of Unit Management Planning and required under the State Land Master Plan, APSLMP.
In brief, the Scope’s preferred goal to “restore the immediate area to natural conditions” should be steered by APSLMP Wild Forest guidelines and guided by future VUM studies. The Scope should not make presumptions about construction of future recreational development and facilities, especially more perimeter parking.
Local support:
On page 4, the Scope states that “despite potential impacts to community character, on December 20, 2023, the Town Board of the Town of Duane passed a resolution to support continuation of State ownership of the DPLS as Forest Preserve. Therefore, the local community supports the possibility that the structures at the site could be removed by the State in order to comply with the Wild Forest classification in the APSLMP.”
Without seeing the entire resolution, DEC’s statement that the town “possibly” supported (in 2023) the removal of the Lodge lacks evidence. Furthermore, the statement is dated. DEC should be actively consulting the Town of Duane and its views this summer of 2025 before characterizing those views as being supportive of “the possibility” that the structures should be removed.
Stated insignificant impacts:
On page 7, the Scope states that:
“The proposal to reconfigure the site has been undertaken with careful consideration to uphold and respect the unique historic character of the lodge and the human history of the site. Design details will include the repurposing of certain components of the lodge, and the footprint of existing buildings will be carefully repurposed to assure that site disturbance and vegetation removal is minimized wherever possible.”
Without knowing the details, reconfiguring the site and repurposing certain components of the lodge are not insignificant impacts. DEC word choice here is questionable, raises more questions, and adds nothing to public understanding of actual and potential impacts.
Similarly, on page 8 the Scope states that: “Evaluation of the potential impacts suggests that the proposed actions would benefit the local economy and would likely improve visitation to the area as the result of improved management for the area.” This statement lacks evidence and is conclusory. To our knowledge there has been no evaluation of economic impacts, with or without the Lodge. It is just as possible that Lodge removal could negatively impact future visitation.
Stated alternatives
On page 11, the Scope states that:
“Amending the New York State Constitution is a complicated undertaking, and this effort ultimately fell apart and is no longer under consideration.”
As DEC is aware, there actually was a very impressive organizing, planning, and fundraising effort made over several years to amend Article XIV for a land exchange permitting the Lodge and adjacent six acres to remain in exchange for much larger additions to the Forest Preserve nearby. In fact, the scope of that effort more than suggests there is considerable historic preservation interest in supporting and maintaining the Lodge if there were local support and a legal mechanism for its retention. What may have “fallen apart” were apparent failures of the Lodge Friends group to relate well to local sentiment, to the Town of Duane boards, as well as the vocal opposition to an Article XIV amendment by some environmental organizations, all resulting in political opposition to introducing an amendment in the State Legislature.
On page 10, Alternatives, Restoration, the Scoping document reads:
“The other option would require the reclassification of the land to historic area under the Adirondack Park State Land Master Plan (APSLMP). There are currently five areas classified as historic under the APSLMP. These are Crown Point, John Brown’s Farm, Camp Santanoni, the Hurricane Mountain Fire Tower, and the St. Regis Mountain Fire Tower. Like the Debar Pond Lodge Site, all these properties are listed in the State and National Registers of Historic Places. The first three properties are also designated by the Secretary of the Interior as National Historic Landmarks (NHL). The Hurricane and St. Regis Mountain Fire Towers, while not NHLs, are situated in and historically connected to the Adirondack Forest Preserve, which is an NHL. National Historic Landmark designation is made pursuant to the National Historic Sites Act of 1935 and requires a site to be of national significance. The National Register of Historic Places documentation for the Debar Pond Lodge Site indicates that it is of local significance and not state or national significance. The APSLMP definition for historic areas states that the location must be of significance to the Adirondack Park, the State, or the Nation. Since Debar Pond Lodge is not significant to the Adirondack Park, the State, or the Nation, the reclassification of the property to historic area is not justified.”
In fact, St. Regis and Hurricane Mountain firetowers were reclassified by the APA from Primitive to Historic in 2010 not because these firetowers have state and national significance when compared with other firetowers on the Forest Preserve; other firetowers in the Adirondack Park are both older and taller. Rather, the two firetowers were reclassified because there was such strong, vocal, local, and DEC support for their retention. The only way to retain those towers in these Wilderness or Primitive settings was to reclassify them and their immediate footprint of less than an acre. Due to the strong support for reclassification, it was accomplished.
Denying Historic reclassification for Debar Pond Lodge while justifying the Historic reclassification of the firetowers because they sit on the Forest Preserve, a National Landmark, is distinction without difference. Debar Pond Lodge is also on the Forest Preserve.
DEC relies on local volunteer friends groups to help maintain the two firetowers, as they do in maintaining Camp Santanoni. Given the Friends group support for a constitutional amendment during 2021-24, something similar – a Friends group of volunteers supportive of fundraising and Lodge maintenance under a Historic reclassification – could happen at Debar Pond Lodge. That possibility should be addressed in the Scope’s Alternatives.
Poorly analyzed: Historic reclassification
Does the Lodge qualify under the State Land Master Plan for Historic classification? Historic areas are locations of buildings, structures or sites owned by the state (other than the Adirondack Forest Preserve itself) that are significant in the history, architecture, archeology or culture of the Adirondack Park, the state or the nation; that fall into one of the following categories: state historic sites, properties listed on the National Register of Historic Places, or properties eligible for such nomination. It seems that the Lodge meets the latter criteria. Furthermore, the Lodge has Park-wide architectural significance. It is one of the largest full-log buildings in the Adirondacks, and was designed by William Distin, one of the two or three most important architects in Adirondack history. Distin had a 60-year career designing some of the region’s most outstanding rustic camps. In recognition of its outstanding architectural character which “embodies the distinctive characteristics of a type, period [and] method of construction”, “represents the work of a master”, and “possesses high artistic values”, the Debar Pond Lodge complex was listed on the National Register of Historic Places.
The DEC Scoping document should acknowledge the reasons why the Lodge was listed on the National Register in 2014. It should also elucidate why the Lodge does or does not meet Historic area definitions and guidelines.
In summary, the Scope makes a rational case for why the Lodge’s presence violates Article XIV and fails to serve DEC’s care, custody, and control responsibilities for the Forest Preserve. However, it does a poor job of thoroughly analyzing legal alternatives, such as an Historic reclassification and retaining the Lodge under the Environmental Conservation Law. The ECL, followed by a Historic reclassification, is why Camp Santanoni, which also lacks an amendment, was not removed and remains a popular historic resource and destination within the Forest Preserve.
Also, under the preferred alternative of Lodge removal the Scope makes presumptions about constructing additional recreational facilities at the site which may conflict with a stated goal of restoring Wild Forest natural conditions and which lack analysis of the carrying capacity of the site and Debar Pond to withstand a variety of human uses.
For these reasons, it appears to Adirondack Wild that the draft Scope of actual and potential impacts resulting from removal of Debar Pond Lodge within the Debar Mountain Wild Forest fails to satisfy the State Environmental Quality Review Act.
Thank you for considering our comments.
Sincerely,
David Gibson, Managing Partner
Adirondack Wild: Friends of the Forest Preserve
Photo: Debar Pond Lodge on Debar Pond (or just a view of the pond) in Duane NY, early 2000’s. photo by Nancie Battaglia