Matt Kendall, Environmental Program Specialist
NYS Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977

Re. APA Map Amendment 2019-01, Lake Luzerne

Dear Mr. Kendall,

We write to follow-up our verbal comments at the agency’s May public hearing concerned with the proposed map amendment in the Town of Lake Luzerne. Following the hearing, we investigated the area along Hidden Valley Road outside the hamlet of Lake Luzerne. In terms of its roadside character, the Rural Use area off that road contrasts sharply with the Moderate Intensity Use area on the same road. There are far fewer structures, driveways and commercial uses on the Rural Use side of Hidden Valley Road. Most of that area appears thickly forested from the roadway, consistent with maps provided in the Draft Supplemental EIS (DSEIS).

In brief, the 105 acres appear to fit well the “low level of development” description of Rural Use in the Act. Also, this acreage appears to be five miles between the existing hamlets of Lake Luzerne and Lake George, which qualities as being reasonably “remote from existing hamlet areas” (APA Act).

By the same token, the area does not appear to fit the character description, purposes, policies and objectives of Moderate Intensity Use, the desired reclassification. It is not “readily accessible to existing hamlets… where community services can most readily and economically be provided” (APA Act). There is no public sewer or water. While both residential and commercial development is heavy at one end of Hidden Valley Road, it is not on the Rural Use end. While a portion is “located along highways or accessible shorelines where existing development has established the character of the area” (APA Act), the majority of the area is not so located, but part of a larger, interior block of Rural Use.

While it is true that 4000 acres of Moderate Intensity adjoins the area to the east and south, 18,000 acres of Rural Use adjoins the area to the east, north and west and are far more reflective of the area’s character. The 105-acres of Rural Use are “consistent with and reflects the regional nature of the land use and development plan and the regional scale and approach used in its preparation” (Section 805(c)(5)).
The block of Rural Use is not only significant in terms of its representation of the open space character of the Park – a key stated purpose of Rural Use in the statute – but also form a part of a regionally important forest block identified by the Wildlife Conservation Society.

Given no public utilities, the presence of 15 acres of wetlands and streams and of undeveloped blocks of forest, this area continues to meet the character description of Rural Use, not Moderate Intensity Use.
The change to MIU – with potential intensity going from 75 principal buildings per square mile to 500 PBs/sq. mi would seriously erode the resources and the character of the area which was properly identified as RU, and might also detrimentally affect the water quality of streams and groundwater entering Lake Vanare.

Finally, the DSEIS contains no information whatsoever regarding the Town of Lake Luzerne’s planning for this portion of the town. The lack of such planning is also a serious problem with the proposal to greatly increase potential development intensity. It means that the town is asking APA to do little more than react, on an ad hoc basis, to proposals which may have a much larger regional planning context and impact.

We conclude that the proposed reclassification is inconsistent with the Land Use and Development Plan because it fails to conform to the character description, purposes, policies and objectives of Moderate Intensity Use and because it is not “consistent with and reflective of the regional nature of the land use and development plan and the regional scale and approach used in its preparation (Section 805 of the Act). Therefore, the proposal fails to meet your statutory standard for amendments to the APA map.

Thank you for considering our comments.


David Gibson, Managing Partner
Adirondack Wild: Friends of the Forest Preserve
P.O. Box 9247. Niskayuna. NY. 12309
Cc: Agency Members and Designees
Terry Martino
Richard Weber