Fiona Watt, Director
Division of Lands and Forests
625 Broadway
Albany, NY 12233

Joseph Zalewski, Regional Director
Rt. 86
Ray Brook, NY 12977

Megan Phillips, Director of Planning
NYS Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977

Improper use of all-terrain vehicles on Wild Forest Trail in classified Wilderness

Dear Ms. Watt, Mr. Zalewski, and Ms. Phillips,

The undersigned have concerns that the DEC Region 5 Northville office improperly authorizes routine departmental use of all-terrain vehicles on the Wilson Ridge and Otter Brook trails located between the Little Moose and West Canada Lake Wilderness areas.

Moreover, DEC staff have also been observed leaving that Wild Forest trail and using their ATVs at Little Moose Lake within the West Canada Lake Wilderness.

As you know, a Wild Forest trail was authorized in the Moose River Plains Complex Unit Management Plan in 2011 to connect the Otter Brook trail to the Limekiln Lake-Cedar River Road via Wilson Ridge trail. The UMP states that:

This proposal will leave a strip of lands classified as wild forest along the Otter Brook Truck Trail, from the intersection with Indian Lake Road, to Little Moose Lake.  The corridor will then follow the Wilson Ridge Road to the LLCRR. This corridor is being created for the sole purpose of maintaining an important mountain bike loop that would have been eliminated had the area been to wilderness. A single‐track bike trail will be developed within the 20-foot-wide corridor (10 feet either side of center line of the road).Other non‐motorized uses on this route may include hiking, skiing and horseback riding. 

The UMP authorized this as a trail, not an administrative road. No public motorized uses are to be permitted. Elsewhere, the UMP states that “this proposal would retain a 20‐foot wide Wild Forest Corridor that would connect the southern end of the Otter Brook Road to the Limekiln Lake‐Cedar River Road.  This corridor would be closed to public motorized use, but passive recreation such as mountain biking, hiking, horseback riding and x‐country skiing would be permitted.”  

To be clear, the land on either side of this trail is classified Wilderness. Nevertheless, campers on Little Moose Lake have recently encountered Forest Rangers and other DEC authorized staff operating ATVs not only along the Wild Forest trail but up to the lake itself within the West Canada Lake Wilderness.

The Department staff’s verbal explanation of their ATV use was that it was authorized by the DEC Northville office to conduct routine, ordinary maintenance of the trail, which included the construction of bridges strong enough to support ATV use.  However, this is not an administrative road. Under the approved UMP and in recognition of its sensitive location dividing two Wilderness areas, this was designated as a Wild Forest trail for hiking, biking and horseback riding. While administrative personnel may use motor vehicles to reach, maintain or construct permitted structures and improvements, ATV-rated bridges are not APSLMP permitted uses or structures on Wild Forest trails.

Routine administrative use of motor vehicles along this non-motorized trail by the DEC suggests that DEC Northville may be treating and maintaining this trail as an administrative road in Wild Forest. Such a designation would require an amendment to the Moose River Plains UMP.  New roads may not be built in Wild Forest “unless such construction is absolutely essential to the protection or administration of an area, no feasible alternative exists, and no deterioration of wild forest character or natural resource quality will result” (APSLMP).

If the Department is routinely riding ATVs within the West Canada Lake or Little Moose Wilderness areas, we have additional reason to have grave concerns about DEC’s APSLMP compliance here. Administrative personnel may not use motor vehicles or motorized equipment within Wilderness areas for day-to- day administration, maintenance or research. Yet, DEC personnel were recently encountered on their ATVs along the shores of Little Moose Lake within the Wilderness, hundreds of feet away from the Wild Forest trail.

DEC personnel verbally communicated that they would be returning on their ATVs to breach a beaver dam on the Wild Forest trail across the lake’s outlet. The reason given is that the beavers were raising the level of Little Moose Lake. The presence of beavers and their dams are entirely natural conditions in Wilderness. Beaver activity this far into Forest Preserve Wilderness do not constitute APSLMP authorized “sudden, actual or ongoing emergencies involving the protection or preservation of human life or intrinsic resource values” (APSLMP). DEC’s use of ATVs to reach and remove a beaver dam because it is raising the level of a Wilderness lake five miles from the nearest road appears to be a serious abuse of the APSLMP and of the UMP.

Pursuant to page 16 of the DEC-APA Memorandum of Understanding (MOU), please treat this letter as a third-party complaint to the Adirondack Park Agency that the DEC’s apparently routine use of motor vehicles on and off this trail appears inconsistent with the APSLMP and the Moose River Plains Complex UMP.  Please forward our complaint to the primary DEC contact person for a response. Pursuant to the MOU, we also ask the Agency to give this complaint an investigation number for the purpose of tracking.

We look forward to hearing from you.

Thank you.

David Gibson, Managing Partner
Adirondack Wild: Friends of the Forest Preserve

Bill Ingersoll, Vice Chair
Adirondack Wilderness Advocates

Pete Nelson, Chair
Adirondack Wilderness Advocates

Cc:  Basil Seggos, Commissioner, DEC
       Peter Frank, Assistant Director, DEC Lands and Forests
       John Solan, Director, Division of Forest Rangers
       Barbara Rice, Executive Director, APA
       John Ernst, Chair, APA

Adirondack Wilderness Advocates
P.O. Box 191
Keene, NY 12942

Adirondack Wild: Friends of the Forest Preserve
P.O. Box 9247
Niskayuna, NY 12309