Re. APA 2026-0108, Lyme Timber Co., Mink Pond Road, Colton, Clearcut Application

Re. APA 2026-0108, Lyme Timber Co., Mink Pond Road, Colton, Clearcut Application

Aaron Ziemann
Project Review Officer
NYS Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977

Dear Mr. Ziemann,

Adirondack Wild is very concerned about the lack of resource surveys, assessments, and analysis of the proposed 680-acre seed tree harvest and forest clearcut south of Sevey Corners in Colton. The land here forms a portion of a Department of Environmental Conservation Seveys Conservation Easement near the ecologically significant Massawepie Lake and Grasse River Flow. We are concerned that the proposed intensive harvesting may fail to comply with the protective terms of the Working Forest Conservation Easement.

No Natural Resource Survey: We are surprised that the harvest plan fails to mention or incorporate a natural resource survey of the harvest area without which forest managers, timber harvesters, state agencies and the public have no baseline understanding of sensitive wildlife habitats and ecological communities, and avoidance of significant impacts. At a minimum, the DEC Conservation Easement requires such a survey and resource assessment.

Complex Stream Network: The harvest map shows that a complex network of headwater streams and associated wetlands flow from the harvest site into the Grasse River Flow and the South Branch Grasse River. The density of the low-elevation, meandering stream/wetland network demands careful resource surveys in advance of harvest layouts. Yet, the harvest plan merely mentions the stream network, stating only that “culverts, skid bridges and corduroy will be used appropriately at stream crossings following BMPs.”

Vulnerable wildlife habitats: These include potential spruce grouse habitats, overwintering deer habitats, and vernal pools as well as riparian corridors within which may exist low-elevation boreal wetlands. All these and more may be impacted by the clearcut. The harvest plan fails to specify and map the location and extent of any no-cut buffers needed to protect these habitats and wetland features feeding the Grasse River Flow.

The harvest plan states that it will leave “the appropriate buffers on wetlands, streams and property lines. Intermittent streams and minor wet runs/ wet areas will be flagged in blue…and that special care will be taken during the layout process and harvesting along the property line, streams, APA wetlands, and riparian zones.” These assertions beg questions: What are the “appropriate buffers”? What constitutes “minor” wet runs/wet areas? What “special care” measures will be taken? Why isn’t any of this resource information clearly delineated and mapped?

Minimum one-hundred-foot buffers – preferably larger – should surround all wetlands and all riparian corridors, permanent and intermittent. To preserve their biotic integrity, identified vernal pools should receive 750 ft.no-cut buffers on all sides. All these features should be carefully mapped in the harvest layout and georeferenced for the timber harvesters.

DEC Unit Management Plan Recommends Against Forest Clearcutting: The approved 2019 DEC Grasse River Complex Unit Management Plan (UMP), which includes this easement tract, recommends that for reasons of wildlife conservation clearcuts should be discouraged and that mature softwood cover should remain intact:

“Discourage large clear cuts of mature softwood stands within conservation
easements, (except in locations where habitat restoration projects for spruce
grouse are needed or ongoing). Plan softwood timber harvests utilizing small
strip or block clear cuts with a rotation long enough to ensure interconnected
portions of mature softwood cover (12+ meters in height) remain intact (50 to
60% of the mature softwood trees). Encourage private landowners to discuss
management options for spruce grouse with DEC wildlife staff, to discuss and
conduct management consistent with the Spruce Grouse Recovery Plan”
(2019 DEC Grasse River UMP, page 70).

Significant Natural Communities: The harvest plan denotes the presence of significant state Natural Heritage Program communities described as “Sedge Meadow , Unconfined River, Shrub Swamp,” and casually notes that “harvesting will not impact the Natural Communities present.” Without mapping these important natural communities and describing how harvesting will not impact them, the note lacks substance, highly inappropriate for lands protected by the Conservation Easement and covered by FSC/SFI certification.

This tract was recommended to be included within a public-private, 185,000-acre boreal heritage reserve in order to protect the Park’s low-elevation boreal ecosystems (20:20 Vision, Fulfilling the Promise of the Adirondack Park, Biological Diversity: Saving All the Pieces, 1988, by the Adirondack Council). An extensive clearcut like the one proposed completely fails to consider the significance of this tract in the context of the Park’s rare, low-elevation boreal zone.

Reduced Forest Overstory: The clearcut harvest plan proposes to drastically reduce the forest overstory from the current 70-140 square feet of basal area per acre to 10-15 square feet per acre, eliminating practically all balsam fir which due to site conditions grow naturally here. While the goals of the clearcut application to “most effectively change the health and vigor of the stand” are commendable, without more descriptive explanation in the harvest plan we question whether sufficient regeneration will result post-harvest to justify this drastic clearcut. Agency staff should expect a more detailed, silvicultural explanation of how and to what extent this harvest should be considered a “regenerative timber harvest.”

The harvest plan improperly leaves decisions about what to leave as “reserve trees” up to the feller-buncher operating on the site: “seed trees will be marked to leave. Desirable pockets of advanced regeneration will be left at the discretion of the buncher operator.” The feller-buncher on site should not have discretion to decide what regeneration to leave or what areas are to remain uncut. That is a prescription for severe forest mismanagement. Those decisions must be the responsibility of the forester in charge based on an approved forest management plan and permit.

Forest and Soil Carbon: An extensive clearcut like this, along with proposed scarification of the forest soil, can be expected to cause a substantial loss of soil nutrients in the short-term, and over the longer-term compromise forest stand carbon sequestration and storage. This does not appear as good regenerative forestry. We also note that under the Climate Leadership and Community Protection Act, the Agency must consider and account for the carbon impact of its permit decisions.

Compliance with Agency Regulations over Clearcutting: The harvest plan seems devoid of the necessary maps to be clearcut and of buffers, wetlands, streams, crossings, and key wildlife habitats. The plan’s description of harvest methods appears minimal and insufficient. Contrary to the regulations, regeneration of timber does not appear assured. In addition, given the extent and diversity of the wetlands, the Agency may need to rate the wetlands and apply permit criteria for regulated activity in wetlands under Section 578.10.

Conclusion: For all these reasons, and especially because of the application’s apparent failure to conduct and integrate a natural resource survey and to comply with the terms of the Conservation Easement, we respectfully ask the Agency staff to recommend project denial without prejudice, and to bring this proposal before the full Agency for its review, and to schedule a public hearing.

Given its professionalism and teamwork, we are confident that Lyme Timber will, working with the APA and DEC, seek to amend this application to satisfy compliance with Agency regulations and the Conservation Easement, and to better ensure that resource considerations are carefully evaluated and integrated into an approvable forest harvest plan at this sensitive, resource-rich location.

Thank you for considering our comments.

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: John Burth, Regulatory Programs
Agency Members and Designees
Sean Ross, Lyme Timber