Christopher Cooper, Counsel
Ray Brook, NY 12977
Re. Agency 2, Public Comment Policy, Unit Management Plans
Dear Mr. Cooper,
In addition to our earlier, more comprehensive comments of April 12 and March , Adirondack Wild has one additional, final comment to make. It pertains to the APA’s proposal to strike or eliminate from the Agency’s Public Comment Policy the section concerning public comment about Unit Management Plans and their compliance with the State Land Master Plan.
We disagree with striking all reference to Public Comment About Unit Management Plans from the Agency’s comment policy for several reasons. First, your Memo to the Agency board in March provides no written explanation for striking out such a large section of the Public Comment Policy. That in and of itself is confusing and concerning.
Second, public comment to the Agency about the compliance of UMPs with the Master Plan rises to a level of great, statewide significance. The Forest Preserve is owned by all New Yorkers, who have the right and responsibility to comment about its management and stewardship, protected by the State Constitution and guided by Unit Management Plans judged to be compliant with the State Land Master Plan.
To strike all reference to public comment about UMPs from the Agency’s policy conveys a wrong and disrespectful message to the public, but also one that is also unhelpful to the Agency’s ultimate evaluation of UMPs and determination of APSLMP compliance. APA State Land Planning Staff need and deserve the guidance about public comment opportunities for UMPs in the Public Comment Policy. It is a helpful reference to them and the work they have to do with DEC and with Park stakeholders. Striking all reference to such guidance is unhelpful to your own Agency staff.
Finally, while the APA-DEC Memorandum of Understanding (MOU) addresses review and approval procedures and public comment opportunities about UMPs and their APSLMP compliance, you have made no reference to the existence or relevance of the MOU in the comment policy. Your Public Comment Policy should continue to summarize UMP public comment opportunities while also citing reference to the MOU for more information.
Thank you. This final comment augments our earlier comments letters in March and April.
David Gibson, Managing Partner
Adirondack Wild: Friends of the Forest Preserve
P.O. Box 9247
Niskayuna, NY 12309
Cc: Agency Members and Designees
Barbara Rice, Executive Director
Ashley Dougherty, Executive Chamber