"For a moment, the hand of man is stayed…
and he neither destroys nor constructs.
He has left time behind him."
—Paul Schaefer


Adirondack Wild Comment:

Re. Moose River Plains Wild Forest Draft Unit Management Plan

September 17, 2010

Josh Clague
625 Broadway
Albany, NY 12233

Rick Weber
P.O. Box 99
Ray Brook, NY 12977

July 2010

Dear Josh and Rick:

Adirondack Wild: Friends of the Forest Preserve thanks the Department and the Agency for diligent efforts devoted to this management plan over the past decade. We have benefited from our own investigations and recreation in the Moose River Plains on a variety of occasions since 1987. Very recently, we have spent valuable field time with former veteran Forest Ranger Gary Lee. In years past, we have also enjoyed field time with DEC Division of Lands and Forests staff, including UMP lead author Keith Rivers and APA staff member Rick Weber. We thank them all for helping us reach a more comprehensive understanding of the area than we had before, and the issues to be considered in its planning and management.

Principal Concerns with this UMP:

1. Adirondack Wild believes the proposed Intensive Use Camping Area located deep within a Wild Forest violates the State Land Master Plan, SEQRA analysis of alternatives, and widely accepted principles of wild land management which have been adopted by DEC. We strongly oppose this proposal, and believe that the road corridors are Wild Forest in character and must remain so.

2. We are recommending that the lands south of the South Branch of the Moose River and north of the Otter Brook Truck Trail possess primitive characteristics and merit a Moose River Plains Primitive classification, but feel that Wilderness classification and removal of these lands from the cultural context of the Moose River Wild Forest region would be the wrong policy at this time. We note that a Moose River Plains Primitive classification is not among the SEQRA alternatives presented in the UMP, a significant shortcoming.

3. We share concerns with local government and other stakeholders about the ongoing maintenance of the 42 or so miles of good roads which currently provide access to the wild beauty of the Plains. This Unit Management Plan could provide more discussion and options for how state-local-private partnerships could ensure that the road system is adequately maintained over the next five years.

4. There is a need for more shared dialogue among a variety of stakeholders about planning and user management of the Moose River Plains Wild Forest.

Wild Lands and Ecosystems

With respect to the Moose River Plains, it may be helpful to note several overarching principles of ecosystem-based, wild land management, which Adirondack Wild: Friends of the Forest Preserve is making a very high priority. For example, these three principles were the starting point for collaborative dialogue in the Pacific Northwest:

1. Healthy, fully functioning ecosystems provide the basis for sustaining communities, economies, cultures and the quality of human life. There are very heart-felt connections that human communities of the central Adirondacks and visitors to that region have with the Moose River Plains Wild Forest.

2 Empowered and healthy communities play a leadership role in sustaining healthy ecosystems, cultures and economies. The more that DEC and APA can meaningfully and constructively engage these communities in the management of the Moose River Plains, the better.

3. Focus planning on the needs of the ecosystems and the values that you want to maintain. Wild land values and objectives for management overlap with human objectives for benefiting from wild lands.

As you know, the Adirondack Park State Land Master Plan (SLMP) contains numerous references to the “paramount responsibilities” of both agencies to protect and preserve the natural resources on our Forest Preserve, or State Lands in the Adirondack Park. How to undertake those responsibilities through unit management planning is described on pages 7-9 of the SLMP, including:

  • inventories of biological, biophysical, recreational resources and analysis of an area’s ecosystems
  • assessments of how actual and projected public use impacts on those resources and systems and of carrying capacities of the area – physical, biological and social – with special attention on those sites threatened with overuse;
  • management objectives which seek to both protect and rehabilitate resources and ecosystems, and plan for public use consistent with assessed carrying capacities.

In addition to the SLMP, DEC has adopted Wild Forest Management Principles which are drawn from the textbook Wilderness Management (Dawson and Hendee). DEC states “many of the principles that apply to wilderness management can be adapted to all wild land management” in the Forest Preserve.

We wholeheartedly agree. Adirondack Wild has initiated a Dialogue for the Wild effort which seeks to expand dialogue about ecosystem-based, wild land management, design and decision-making. We will be evaluating State management (Unit Management Plan) recommendations based upon criteria such as:

  • A systems approach to managing all parts of the Forest Preserve
  • Quality of scientific information about ecosystem health including wildlife, vegetation, habitat, climate, water and air quality
  • Quality of recreational user and other data that could imply changes in pressure on sensitive ecosystems
  • Demonstrated understanding of interrelationships between wild lands and the larger Park landscape.

In truth, the criteria we will employ to evaluate unit management plans paraphrases those already contained in the SLMP, and therefore are no more than what is truly required in law already. Unfortunately, we have noticed for many years that many ecosystem-based, wild land management criteria and principles required by the SLMP are frequently given little substantive attention in the unit plans or management recommendations. Through our dialogue for the wild and other means we will do our best to work with the agencies to improve their performance in this respect, and thus place New York in a leadership position with respect to ecosystem-based wild land management.

Intensive Use Camping Area:

We appreciate the efforts DEC and APA have made since 2002 to inventory and assess conditions at the 170 primitive tent sites along the road corridors in the unit. This preparatory work to ensure that future Wild Forest primitive tent sites are sufficiently spaced from water sources and other sites, and screened from roads is important and professionally done. Consultation with the towns of Inlet and Indian Lake and other stakeholders is now very important. Any tent site rehabilitation and closure should form part of this consultation and dialogue, be prioritized and phased in over a period of years.

However, there is no justification for an Intensive Use Camping Area. An Intensive Use reclassification would be bad public policy for the following reasons:

  1. The road corridors are, without question, Wild Forest in character, not Intensive Use. They are unpaved, run through remote, wild territory, often have a full tree canopy above them, and lack any of the facilities expected in a State Campground, Boat Launch Site, Ski Area, or Visitor Information Center – the four types of Intensive Use areas listed in the SLMP.
  2. Creating an Intensive use area in the middle of this wild, remote area would set a very poor precedent for other Wild Forest areas in the Park. Without question, once this precedent is established in the Moose River Plains, there will be pressures on the APA to reclassify lands along the Powley-Piseco Road, the Crane Pond Road, and other Forest Preserve corridors.
  3. The proposal violates basic wildland planning principles. Two fundamental principles are to manage wild lands as a comprehensive whole, not as separate pieces, and not allowing Wild Forest resources to degrade, but to restore conditions that have degraded beyond acceptable levels. This proposal to downgrade the road system from Wild Forest to Intensive Use does the opposite in both instances.
  4. Repeatedly, the EIS claims that an Intensive Use area “balances” the recommendation to reclassify Wild Forest to add to the West Canada Lake Wilderness Area. Rather than planning comprehensively and instead of basing recommendations on the ecological integrity and character of the entire area, this draft views roadside camping as offsetting Wilderness expansion, offering each user group a slice of the recreational pie. This is classic piecemeal, formulaic, and outdated management.
  5. The UMP fails to demonstrate how DEC will have the capacity to manage campers and resources within a 3,000-acre, 40-mile long Intensive Use camping corridor spread between Inlet and Indian Lake.
  6. The threats from invasive insects, such as Emerald ash borer entering this vast area within infested firewood, are enhanced should the road corridors be reclassified to Intensive Use. This is particularly so in the absence of Ranger stations and inspections at the head of the LLCRR.

In 2006, the Draft UMP recommended the closure of 99 of the 170 primitive tent sites adjacent to or near the roads because the sites were degraded, too close to water or wetlands, or packed together so tightly that campers could not have a wild forest experience (1/4 mile site and sound separation distance required by the SLMP). This proposal, while seeking to comply with the APSLMP, naturally raised serious objections from Inlet’s government, businesses and from campers who are loyal to their traditional camping sites and who were not adequately informed about the reasons for this proposal.

Instead of working with a focus group or citizen advisory committee to come up with strategies for public education and alternatives, in the face of recreational pressures the Department and the Agency have simply given up on the Wild Forest in spite of your paramount responsibility under the APSLMP to protect and preserve the natural resources of the NYS Forest Preserve. “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.”

In fact, creating a 3000 acre Intensive Use area with as many as 150 tent sites accessible by motor vehicle deep within a Wild Forest area here signals that NYS is not managing this area comprehensively, but in component parts in violation of DEC’s own Wild Forest Management principle number 2, “Manage Wild Forest as a composite resource.”

We quote from this Principle: “All the components of the Wild Forest resource – physical, biological and social – are interrelated and one management plan must deal comprehensively with those components and their interrelationships. Actions taken for the management of one component must be considered in light of how they will affect other components. Each component must be viewed as a part of the larger whole which is the Wild Forest resource.”

Maintain Wild Forest classification: DEC and APA should maintain the Wild Forest classification throughout the LLCRR corridor. After greater consultation and dialogue with the community, a plan should be proposed leading to the phasing-out over time of those primitive tent sites which are the worst violators of basic management guidelines and which have the most damaged soils and worst water quality impacts. This can be done over a period of years, but should employ education and information in order to prepare the recreating public in advance for these actions.

Expanding the West Canada Lakes Wilderness by 15,000 acres

Adirondack Wild supports additional Wilderness classifications where they make ecological and wild land management sense. In this instance, we feel the UMP and EIS overtly trades additional Wilderness for an Intensive Use Camping Area. Such overt recreational trade-offs are not the purpose of management planning for wild lands, which more appropriately are to examine an area comprehensively, in ecological context and with stakeholder dialogue.

Here are the actual words in the EIS which concern us, and which, while seeking “balance” are in reality a damaging trade-off of perceived conflicting recreational uses:

"Reducing the extent of Wild Forest through the reclassification of lands to the Intensive Use category while, through another related reclassification action, significantly expanding an adjoining Wilderness area. The two reclassification actions are appropriate applications of the Master Plan’s classification criteria tailored to actual area characteristics. Combined, each individual reclassification action positively reinforces the other and would provide a balanced approach to the management of the area.”

The reclassification proposal of 15000 acres of the Moose River Plains to become part of the adjoining West Canada Lakes Wilderness also ignores regional pride and identification with the Moose River Plains. The Intensive Use area and the Wilderness expansion should not be considered as a quid pro quo. Instead, all actions should be viewed with an eye towards enhanced, integrated, ecosystem-based management for an essentially wild, remote area.

As shown by the EIS, the proposal to reclassify the area between the now closed Otter Brook Truck Trail and the South Branch of the Moose River to Wilderness is justified primarily as a way to “balance” the Intensive Use Camping Area along the road system. While Adirondack Wild appreciates that the area is essentially wilderness in character, we feel that a Primitive classification within the Moose River Plains would better suit the conditions and characteristics of the area as well as the old system of roads. The UMP fails to discuss this alternative, which by itself is a serious deficiency.

A Primitive reclassification would permit all terrain or mountain bicycling to continue or be expanded here on designated routes. Finally, by naming this area the Moose River Plains Primitive Area, the Department and Agency would recognize the strong cultural identification people in this region have with the Moose River Plains, as opposed to the West Canada Lakes Wilderness.

This area would meet both types of Primitive Area definition in the SLMP. The area is essentially Wilderness in character, yet does still contain improvements (Old Truck Trail) inconsistent with Wilderness. On the boundary of the West Canada Lakes Wilderness, this region is also fragile and requires wilderness management. The old truck trail is rapidly growing over and mountain biking may soon become impossible without some improvements to the old road bed. This boundary area could be managed for mountain biking and hiking with a relatively small amount of investment and effort

In the future, the 15,000 acres could be upgraded to Wilderness after efforts are made to discuss the basis and benefits of a Wilderness reclassification proposal with a variety of stakeholders or citizen advisory committee members which include residents of Inlet and Indian Lake.

Inventory of Resources and Analysis of Ecosytems: Adirondack Wild has initiated a Dialogue for the Wild effort which seeks to expand dialogue about ecosystem-based, wild land management, design and decision-making. We will be evaluating State management recommendations based upon criteria such as:

  • A systems approach to managing all parts of the Forest Preserve
  • Quality of scientific information about ecosystem health including wildlife, vegetation, habitat, climate, water and air quality
  • Quality of recreational user and other data that could imply changes in pressure on sensitive ecosystems
  • Demonstrated understanding of interrelationships between wild lands and the larger Park landscape.

We feel that the UMP is weak in all four of these criteria, particularly in its required analysis of ecosystems in the unit, extent and nature of public use, and actual and anticipated impacts of projected public use on natural resources and ecosystems; and management actions designed to minimize impacts on those ecosystems and resources. In truth, there is little to differentiate the 2006 and 2010 drafts in terms of natural resource inventories and analysis of ecosystems.

This is unfortunate because there are many amateur and professional ecologists who visit the area frequently and who could help create area-specific lists and suggestions for special area management. Such people include former Forest Ranger Gary Lee. The UMP makes relatively little use of the information many citizen experts have provided over the years with respect to birds, orchids, ferns and other natural features

It is particularly disappointing to see the lack of data and analysis of projected public use, or ecosystem change over time. After such long time preparing this 2010 draft, the continued lack of hard information about numbers of snowmobilers, or firm plans to gather this information is perplexing. Furthermore, nowhere in the poorly substantiated projected growth in use of snowmobiling is there a discussion of how climate change may significantly impact the number of days with sufficient snow cover for snowmobiling – and how management of the area might respond if, say, the number of days with snow cover decreased by another 15-30% in the immediate decades ahead. That is roughly the percent decrease in snow cover between 1965 and 2005 (Jenkins, Climate Change in the Adirondacks, 2010). As Jenkins notes, there is no question that throughout New York State more water is running off into streams in winter and less is accumulating in the snow pack

Need for Collaborative Dialogue

Adirondack Wild feels that the Moose River Plains is a model land unit for collaborative dialogue, study and action. This could take the form of a citizen advisory committee, or forum for dialogue. The urgency and passion with which people spoke about their feelings and knowledge of the area at the public hearings in August are the best indication of the need and benefits of expanded opportunities for dialogue. The efforts undertaken by the Town of Inlet and others to help the State maintain the Limekiln Lake- Cedar River Road this past spring is another indication that people care deeply about the accessible, wild beauty of their Moose River Plains. Hunters, fishers, snowmobilers, hikers, bikers, photographers, and generations of family campers are just some of the many stakeholders who might appreciate ongoing opportunities to share information and opinion about the area’s management, and about how to educate this and future generations of users to better care for the Moose River Plains consistent with the Constitution and APSLMP. Adirondack Wild is presently reaching out to the Town of Inlet and others to initiate this dialogue.

The proposed snowmobile trail connector is proposed as close to Rt. 28 as possible in conformance with overall Park-wide goals. We appreciate the efforts this UMP makes to assess all of the alternative routes this trail might take. However, the preferred alternative route would be mechanically groomed in violation, we believe, of the Master Plan, and knowledgeable people affirm that terrain constraints may make its construction impractical and too costly. The issues related to the need, location, routing and trail management of additional snowmobile trail community connectors through the Moose River Plains should be the subject of discussion with stakeholders within a citizen advisory committee.

We support the closure to motorized use of 49 miles of existing, minimally-used and dead-end snowmobile trails, but acknowledge that this is a very sensitive issue to certain snowmobilers, local government and other stakeholders. This management step should be the subject of additional dialogue.

The proposed Historic Great Camps Special Management Area is very important, and should be supported, but with more detailed operating guidelines for the State and Private Owners. In this draft, there is nothing particularly special about this Special Management Area. Yet, we know how truly special the Great Camps Sagamore and Uncas are, how much they contribute to the cultural heritage and tourism in the area, and how these camps complement the State Lands surrounding them. The APSLMP, page 37, provides the State with all the authority it needs to do such things as:

  • prohibit by regulation the use of recreational motorized uses in the Special Management Area,
  • to cost share on critical road and bridge maintenance,
  • and to support educational programs through interpretive signage wherever appropriate.

We ask that the UMP provide greater specificity about how the SMA can ensure that these Great Camps are protected and interpreted so that they continue to benefit the community and economies of the central Adirondacks as key elements in the region’s cultural and heritage tourism program.

Stewardship: The Moose River Plains has lost its Assistant Forest Ranger program due to budget cuts. Two rangers share coverage of this vast region in addition to other areas of responsibility. A new educational and outreach program hiring and training youth from Inlet, Old Forge, Indian Lake to serve as a youth conservation corps for the Moose River Plains would boost local employment and pride, train conservation stewards, and upgrade conditions in the plains. Such a program should be immediately investigated. Funds could be sought from Americorps/Student Conservation Association.

We strongly support the reconstruction of a Ranger station at the head of the LLCRR to assure better public contact, information exchange, education, emergency incident response and enforcement of rules such as the new firewood regulation. In the absence of a Ranger station, how will DEC plan to monitor its regulations prohibiting the transportation of firewood more than 50 miles from its source? The threat of non-native insects such as Emerald ashborer or Asian long-horned beetle is yet one more reason why the State should reject the proposed Intensive Use Camping corridor in the absence of demonstrated staff capacity to inspect firewood entering the area.


This is a recovered Wild Forest that has been given several second chances. This history could be usefully included within the UMP. Thanks to citizen action and the Moose River Committee from 1945-1955, the Moose River Plains were spared from two huge dams that would have put the Plains 50 feet underwater and resulted in a “cemetery of stumps and mudflats” according to Paul Schaefer, leader of the Moose River Committee. The proposed Higley dam would have flooded Icehouse, Helldiver, Beaver, Mitchell and other lakes and ponds in the area.

A decade later, the Plains were purchased for the NYS Forest Preserve after intensive logging by the Gould Paper Company. Over the ensuing 33 years, the Moose River Plains and the recreating public benefited from the devoted service of DEC Forest Ranger Gary Lee who served as first responder for the campers, recreationists, facilities, wildlife and natural resources in the area. In 2010, the Town of Inlet immediately responded to State budget cuts by maintaining the roads in cooperation with DEC. All of these citizen efforts and the meaning of Article 14 of our NYS Constitution itself, the Forever Wild provision, should inspire our collective efforts to manage and care for the Moose River Plains Wild Forest according to sound principles of ecosystem and wildlands management. Planning must also be done with sensitivity to several generations of families whose lives and family traditions have immeasurably benefited from shared outdoor experiences in this wild, remote region.

Accessible, Wild Beauty

There is accessible, wild beauty in the Moose River Plains Wild Forest which is critically important to a wide diversity of users and stakeholders. In turn, State agencies must work with all stakeholders to keep it wild, reduce our human impacts wherever possible, advance wildlife and water quality objectives, and provide all stakeholders with a better chance to collaboratively design the future management of this wonderful, remote area.

Master Plan notes the ecological significance of the Moose River Plains and its historic deer wintering areas. The Moose River Plains are special. Care must be taken to manage the area as a comprehensive whole set of ecosystems, not as component parts or for specific forms of recreation.

Quoting from the 1967 Conservation Department brochure for the unit:

“It is a remote region with much to offer the individual or group who enjoy wilderness camping, fishing or hunting. Facilities are primitive in keeping with the general atmosphere of the region. Help care for our wilderness environment and enhance the enjoyment of it for yourself and those who follow."

It is up to this UMP to faithfully execute these admonitions in the field.

Thank you for considering our comments, and we look forward to ongoing dialogue among stakeholders committed to the Moose River Plains Wild Forest.

David H. Gibson, Partner
Daniel R. Plumley, Partner

Adirondack Wild: Friends of the Forest Preserve
Regional address: P.O. Box 9247, Niskayuna, NY 12309
Adirondack office: 72 Schaefer Road, Keene, NY 12942
518-576-9277; 518-469-4081

cc: Pete Grannis, DEC Commissioner Curt Stiles, APA Chairman John Frey, Inlet Supervisor Barry Hutchens, Indian Lake Supervisor Bill Farber, Hamilton County Chris Amato, DEC Deputy Commissioner Rob Davies, Dir. Lands and Forests

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ADK ALMANACK - Writings by David Gibson

Wilderness 50th

The mission of Adirondack Wild: Friends of the Forest Preserve is to advance New York’s ‘Forever Wild’ legacy and Forest Preserve policies in the Adirondack and Catskill Parks, and promote public and private land stewardship that is consistent with wild land values through education, advocacy and research.

Top left, Whiteface Mountain © Ken Rimany; Pond Reflections © Janet Marie Yeates

Peter Brinkley, Honorary Chair
Terry Jandreau, Chair
Kenneth J. Rimany, Partner
David H. Gibson, Managing Partner
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