Current IssuesChad Dawson at an APA meeting

By David Gibson, Managing Partner, Adirondack Wild

Chad Dawson recently resigned from the NYS Adirondack Park Agency after four plus years of service because, despite much effort, he eventually felt he was a voice in the wilderness asking for higher standards in analysis of how best to manage our Adirondack Wilderness, Wild Forest, Primitive and Canoe areas to avoid compromising their natural resources.

Chad has just shared with Adirondack Wild his latest commentary to the APA critiquing proposed management of the Debar Mountain Wild Forest. Here is the full text of his comment to the agency.

This letter is a commentary regarding the proposal to reclassify 41 acres of the Debar Mountain Complex from Wild Forest to Intensive Use.

Dave Gibson, Managing Partner
Adirondack Wild

February 12, 2021

Steven Guglielmi
NYS Dept of Environmental Conservation
Box 296, Rt. 86
Ray Brook, NY 12977

Matthew McNamara
NYS Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977

RE: Draft Generic Environmental Impact Statement for the Debar Mountain Complex Draft Unit Management Plan and a proposal to reclassify approximately 41 acres of the Wild Forest as Intensive Use.

This letter is a commentary regarding the proposal to reclassify 41 acres of the Debar Mountain Complex from Wild Forest to Intensive Use.

The proposed plan of reclassification does not offer any information nor analysis to evaluate the impacts of such an alternative compared to keeping it as Wild Forest; furthermore, the APA and NYSDEC staff defended the proposal at the December, 2020 APA Board meeting with words to the affect: we need to develop the area to protect it. Such a justification is entirely contrary to the APSLMP mission that “protection and preservation of the natural resources of the state lands within the Park must be paramount. Human use and enjoyment of those lands should be permitted and encouraged, so long as the resources in their physical and biological context as well as their social or psychological aspects are not degraded.” (p. 1) What research has shown is that more recreational development results in more environmental impacts from construction, operations, and maintenance followed by more visitor impacts from more visitor access and use.  Minimizing and mitigating these facility and visitor impacts must be identified and addressed to reduce degradation; however, some degradation of a natural environment will occur. Keeping the area as a Wild Forest offers less developed forms of recreational access while protecting and preserving this sensitive ecosystem at Debar Pond.

The APSLMP requires, among other requirements, that each UMP include “an assessment of the impact of actual and projected public use on the resources, ecosystems and public enjoyment of the area with particular attention to portions of the area threatened by overuse” (p.10)”. The proposal for reclassification does not include any estimates of present or future use and only offered some vague anecdotes as to why this additional Intensive Use area was needed. No assessments of public use impacts on the resources nor environment were presented and this is particularly noteworthy in that the UMP pointed out the unique and fragile wetland and pond ecosystem at Debar Pond. Furthermore, the plan to make this area a “recreational hub” for access to the Debar Pond area and the greater Debar Mountain Complex fails to address the potential for overuse impacts on the resources and environment due to increased, intensive, and concentrated visitor access and use.

The APSLMP guidelines for the management of Intensive Use areas directs that: “Priority should be given to the rehabilitation and modernization of existing intensive use areas and the complete development of partially developed existing intensive use areas before construction of new facilities is considered.” (p. 42) No analysis is presented as to how the existing intensive use areas and campgrounds in the Debar Mountain Wild Forest or nearby and adjacent units could provide the interpretation and recreational opportunities proposed to be added at Debar Pond.  The information presented in this proposed reclassification plan does adequately address any compelling reason for changing this area from a more protected class to a less protected class of protection when there are other intensive use areas nearby within the AP.

The proposal to reclassify 41 acres of the Debar Mountain Complex from Wild Forest to Intensive Use is NOT compliant with the Adirondack Park State Land Master Plan (APSLMP) and the reclassification should not move forward.

Respectfully submitted,
Chad Dawson

By Chad Dawson, Former APA Commissioner