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FIELD NOTES: SAFEGUARDING THE WILD

Adirondack Wild Comment:

RE: Proposal to Reclassify Lands in Primitive and Canoe Areas “Historic” in order to permit Restoration of the St. Regis and Hurricane Mountain Fire Towers

October 12, 2010

Curt Stiles, Chairman and Agency Board Members
NYS Adirondack Park Agency
P.O. Box 99
Ray Brook, New York 12977

Dear Chairman Stiles, and Agency Members:

On behalf of Adirondack Wild: Friends of the Forest Preserve, we write to express great concern over the proposal to reclassify half an acre of land at the base of the St. Regis and Hurricane Mountain fire towers to “Historic Area” status. We encourage the Agency to postpone or amend this proposed action.

The Agency has failed to consider the win-win alternative already being considered by the Town of Keene, with the support of many town residents, that the Hurricane Fire Tower could be successfully removed from the peak and relocated in the valley at a site where it could be an important tourist draw and historic site. The Town recently adopted a resolution highlighting its readiness to take possession and care for the tower. Town board members have undertaken previous studies of sites in the valley where it would be a conforming structure and would permit high visitor interest, use and interpret the story of the fire warden history to tens of thousands of people annually.

Given this information, APA should not take action unless it has fully aired this possibility with Town officials and the public. Moreover, any action by APA should encourage and permit the towns involved to accept removed towers and use them as cultural and historic venues on lands where the towers would not impact surrounding Canoe, Primitive or Wilderness. The same opportunity that clearly exists in Keene may also exist for the St. Regis tower

In regard to the proposed reclassification of the lands under the towers as Historic, Adirondack Wild believes this action would be a serious dereliction of the APA’s affirmative duty to implement the Adirondack Park State Land Master Plan (APSLMP), as follows:

The action would set a very significant and negative precedent of “spot zoning” that is clearly inconsistent with the Agency’s duty to make resource considerations for designated Primitive and Canoe areas their paramount concern (Page 1, APSLMP).

The proposal, if adopted, would seriously weaken the Agency’s integrity, and historic responsibilities for State Land policies and the APSLMP. The document you are responsible for implementing reads: “The St. Regis Mountain fire tower may be retained so long as retention is considered essential by the DEC pending ultimate removal…”(Page 31, APSLMP) and with respect to Hurricane, “should it be replaced by other means of fire patrol and communications, the entire area should be reclassified as wilderness” (Page 78, APSLMP). The language is clear and unmistakable to any reader once they understand that the DEC has unequivocally declared any conditions for retaining the firetowers no longer pertain. For thirty-seven years, the Agency has had an affirmative duty to follow through. What makes this Agency in 2010 exempt from that duty?

Historic classification would make a mockery of the APSLMP and its own Historic guidelines. Classifying the .5 acre tower base as Historic implies that the State “has committed resources to manage such areas primarily for historic objectives” (Page 42, APSLMP). This is clearly not the case. Basic guidelines for Historic Areas also call specifically for such areas to "be designed, managed and interpreted so as “to blend with the Adirondack environment and have the minimum adverse impact possible on surrounding state lands...in a setting and on a scale in harmony with the relatively wild and undeveloped character of the Adirondack Park (Page 42). Restoring the towers as interpretive sites on .5 acre “donut holes” surrounded by wilderness is completely antithetical to the basic guidelines which the Agency seems now prepared to adopt for these firetowers.

  • Under Historic classification, the towers must “be designed, managed and interpreted in conformity with a special unit management plan for the area” (Page 42). In other words, Historic reclassification implies an affirmative duty to restore, forever maintain and make accessible to the public structures deep within areas that are to be managed for remote, wild land values, solitude, wilderness experience goals, etc.. Many of the required actions to restore and maintain the .5 acres would directly violate the management guidelines for the Primitive and Canoe areas that lie just outside that tiny footprint. It is nonsensical and gross mismanagement to classify these footprints as Historic.
  • Consider: Why did the Open Space Institute retain its private ownership of the footprint around Mt. Adams firetower when the State took ownership of the surrounding lands for inclusion in the High Peaks Wilderness? They did so because they correctly assumed this was the only way to retain the tower, and that the APA had a duty under the APSLMP to classify the mountain as Wilderness consistent with its surroundings.
  • Consider: The firetowers, starkly visible, noise-laden, wind-battered metal structures requiring intensive restoration and maintenance will impact the wilderness experience within which the structures of man are to be non-existent, removed or where the "imprint of man's work is substantially unnoticeable, where "man's influence is not apparent.”
  • Seeking Wilderness classification after preserving the fire tower on Hurricane through this action “dumbs down” the entire classification system. Why would you make a parochial political decision and a mockery of not only the ideals, but of your legal obligations for Wilderness, Primitive and Canoe? Non-conforming structures must matter to the Agency. This isn’t optional on your part.
  • The action will weaken the integrity of the Adirondack Park Land Use and Development Plan for regulation of tall towers in general. If these dilapidated, five-story man-made towers are deemed of "no undue adverse impact" to the surrounding Canoe and wilderness lands, then how can the APA possibly expect to carry forward their private land Tall Towers Policy, much less tell land owners and corporations with private lands in Industrial Use or Resource Management that their applications for wind farms or cell towers violate Agency policy?
  • Again, the proposed action will deny the win-win opportunity to relocate these two towers in hamlet or near hamlet settings where their historic area classification could truly be justified, and their cultural and historic draw could benefit local communities.

Thank you for considering our viewpoints.

Sincerely,
Dan Plumley, Partner
Dave Gibson, Partner

cc: John Banta, Jim Connolly, Walter Linck, Kevin Prickett, Terry Martino, Rick Weber, Rob Davies, Karyn Richards, Elizabeth Lowe

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4] Posted 10/06/10
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2010

12/06/10 Law Judge rules on Adirondack Wild  read more >

10/21/10 Adirondack Wild, Fire Towers and Wilderness  read more >

10/12/10 Comment: Proposal to Reclassify…Fire Towers  read more >

10/07/10 Wild Action Now: Moose River Plains  
read more >


10/07/10 Comment: Moose River Plains   read more >


10/07/10 Comment: Public Hearing, Fire Towers on St. Regis and Hurricane Mountains  read more >
10/07/10 Comment: Alternative Actions for Fire Towers on St. Regis and Hurricane Mountains   read more >
10/07/10 Comment: State-Owned Conservation Easements  read more >
10/07/10 Safeguarding the Wild   read more >

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Peter Brinkley, Honorary Chair
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