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

Re. Additional Comments, Proposed Adirondack Park State Land Master Plan (APSLMP) amendments

Dear Ms. Phillips,

As we have re-read the Agency’s proposed amendments pertaining to Unit Management Plan Development, we now wish to augment our earlier letter with additional concerns about Unit Management Plan Development and carrying capacity assessments.

Rather than strengthening the Master Plan’s guidance for development of UMPs, the proposed additional two paragraphs on page 11 prescribing carrying capacity assessments add little in the way of better guidance protective of natural resources. In fact, the final sentence of paragraph 2 badly weakens the Master Plan’s UMP carrying capacity requirements.

The two proposed new paragraphs on page 11 succeed in diverting attention away from existing Master Plan requirements for inventories, assessments, and management objectives in line with the Master Plan’s unifying theme of protection of natural resources of the State Lands of the Park. For example,

  • The APSLMP already requires inventories of resources and analysis of ecosystems; of existing facilities for use by the public and managers; of the extent and nature of public use; and of the extent and nature of projected public use.
  • APSLMP already requires assessments of the impact of actual public use on such ecosystems, and on anticipated impacts on public enjoyment, as well as physical, biological, and social carrying capacity of projected future public use, with special attention on portions threatened by overuse.
  • APSLMP already sets out management objectives to protect and rehabilitate above-described resources and ecosystems, and to plan for public use consistent with the assessed carrying capacities.

Adding prescriptive language of Visitor Use Management (VUM) in the SLMP amendments is not wise because the VUM framework, like the related frameworks of LAC and VERP before it, is not set in stone. It may need adjustment in the future. What should not change are the existing APSLMP requirements for what UMPs must contain to ensure management consistent with the APSLMP’s unifying theme. Therefore, of great concern is the concluding sentence of paragraph 2  that “levels of time and resources to fulfill this commitment (of carrying capacity assessments) should be proportionate to the significance of impacts.”

With this one sentence, the Agency invites future land managers and administrators the opportunity to sidestep carrying capacity assessment work  – including necessary work to establish waterbody carrying capacity assessments –  whenever anybody in authority judges that the work is out of proportion to alleged insignificant impacts, and therefore not required.  

This single sentence undermines fifty years of professional judgements about the significance of impacts backed up by existing APSLMP requirements of what UMPs must contain. Rather than strengthen UMP development, this sentence weakens the entire structure. The sentence should be removed.

Additionally, the amended list of Visitor Use Management strategies concludes on page 11 with “building facilities that can accommodate heavy use.”  A strategy as unconditional as this is highly inappropriate for inclusion in the APSLMP. The APSLMP’s unifying theme is protection of natural resources, not accommodating “heavy use.” The Final Programmatic EIS (FPEIS) for Amending the APSLMP clearly prioritizes protection over accommodation of use. For example,  on page 30 the FPEIS states “where an overuse problem exists, the creation of a special use zone allowing additional facilities in heavily used portions of Wilderness, Primitive, Canoe or

Wild Forest areas should not be proposed. Dispersal or regulation of use would be a more appropriate response to such a problem.”

Furthermore, the NYS Court of Appeals ruling in 2021 stopped DEC from making substantial changes to the Forest Preserve and interfering with its natural development more than may be necessary to accommodate hikers.

New APSLMP amendments ought to strive to strengthen – and not, as is the case here, weaken the APSLMP’s most important directive regarding UMPs: that they should be based on assessments of the carrying capacities of each land and water resources, and they should prescribe management aimed at ensuring those carrying capacities are not exceeded; and rehabilitating any areas and waters whose resources – both natural and experiential – are suffering degradation due to overuse.

Thank you for including our additional comment letter in the comment record.

Sincerely,
David Gibson, Managing Partner
Adirondack Wild: Friends of the Forest Preserve
P.O. Box 9247
Niskayuna, NY 12309
www.adirondackwild.org
518-469-4081

Cc: Agency Members and Designees
        Barbara Rice, Executive Director, APA
        Sean Mahar, Acting Commissioner, DEC
        Governor Kathy Hochul
        Executive Chamber