August 4, 2025
Matthew Kendall, Environmental Program Specialist
NYS Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977
Re. APA Map Amendment 2025-01, Lake Luzerne
Dear Mr. Kendall,
On behalf of Adirondack Wild, for the following reasons we oppose the proposed reclassification of approximately 73 acres from Rural Use to Moderate Intensity Use along Hidden Valley Road in Lake Luzerne, and we oppose the proposed reclassification of the adjacent 123 acres from Rural Use to Low Intensity Use along Rt. 9N and Hall Hill Road, also in Lake Luzerne.
- The land is properly classified: The Agency’s Draft Supplemental Environmental Impact Statement and our own investigations show that both areas, nearly 200 contiguous acres, meet the existing Rural Use classification and its character description, purposes, policies, and objectives.
Consistent with Rural Use, there is a low level of development in both these areas. Area A has only 3 private residences, while Area B has just 7 residences. Also consistent with Rural use, both areas are five miles between the existing hamlets of Lake Luzerne and Lake George, thereby being “reasonably remote from existing Hamlet areas.”
As for open space character, a key stated purpose of Rural Use in the APA Private Land Use and Development Plan, both Area A and Area B appear and are mapped as substantially forested open space consistent with their current classification. Both areas are part of a contiguous 18,000-acre block of Rural Use. This block of Rural Use inclusive of Areas A and B also forms a part of a regionally important forest block identified by the Wildlife Conservation Society. This regionally important forest block should not be fragmented.
In terms of its roadside character, the Rural Use portions of Hidden Valley Road, Rt. 9N, and Hall Hill Road contrast sharply with the Moderate Intensity Use portions of Hidden Valley Road. There are far fewer structures, driveways and commercial uses on the Rural Use side of Hidden Valley Road, for example. Most of that area appears thickly forested from the roadway, consistent with maps provided in the Draft Supplemental EIS (DSEIS). - The proposed reclassifications are inappropriate and not justified: By the same token, the two areas do not appear to fit the character description, purposes, policies and objectives of Moderate Intensity Use and Low Intensity Use, the desired reclassifications. The proposal could seriously jeopardize the scenic character and natural resources of this section of Lake Luzerne. Neither area proposed for reclassification has public sewer or water. The proposed 73-acre reclassification area (to Moderate Intensity Use) is not “readily accessible to existing hamlets… where community services can most readily and economically be provided” (APA Act). Nor does the proposed 123-acre reclassification area (to Low Intensity) offer “a relatively high level of residential development and local services,” or “provide an orderly growth of housing development opportunities in the Park” (APA Act).
While both residential and commercial development is heavy at one end of Hidden Valley Road, it is not on the Rural Use end. While just a portion is “located along highways or accessible shorelines where existing development has established the character of the area” (APA Act), many of both areas are not so located, but form part of a larger, interior block of Rural Use.
Moreover, the proposed elimination of approximately one mile of Rural Use along Rt. 9N and its current Critical Environmental Areas (CEA) designation could drastically alter the scenic and aesthetic quality of this stretch of road. This proposal threatens to add significantly greater commercial clutter in the ten miles of Rt. 9N spanning Lake George and Lake Luzerne.
In brief, the 200-acres of Rural Use inclusive of Areas A and B are “consistent with and reflect the regional nature of the land use and development plan and the regional scale and approach used in its preparation (Section 805(5) of APA Act). The reclassification proposal is seriously inconsistent with the plan and its regional scale. - Significant resource constraints: The current Rural Use classification could maximally authorize up to 23 principal buildings (PB) on both areas. The proposed reclassifications could maximally authorize 72 more, up to 95 PBs. Given no public utilities, the presence of 15 acres of wetlands and streams, as many as 25-acres in steep slopes, and 80% of the area appearing as undeveloped blocks of forest, the entire area continues to meet the character description of Rural Use, not Moderate Intensity Use and Low Intensity Use. The change to MIU/LIU – with potential intensity going from 75 principal buildings per square mile to 500 PBs/sq. mi and from 75 PBs to 200 PBs per square mile, respectively, could seriously erode the resources and the character of the entire area and could easily and detrimentally affect the water quality of streams and groundwater entering Lake Vanare, causing the lake to become culturally eutrophic.
- Lack of planning and regional context: These reclassification proposals contain no information whatsoever regarding the Town of Lake Luzerne’s planning (infrastructure, transportation, services, water quality and quantity, etc.) to prepare for such greatly increased development intensity on this 200-acre portion of the town. The lack of such planning represents a serious problem given the greatly increased potential development intensity and the fact that many forms and intensities of development would no longer be jurisdictional to the Agency’s review and permitting decisions. If these reclassification were approved, APA could do little more than react on a very limited, occasional jurisdictional basis to future development proposals on 200-acres which could have seriously fragmenting, broadly regional impacts and significant local undue and adverse impacts.
We support the Agency’s thorough Draft Supplemental Environmental Impact Statement. After reading it and visiting the area in question, we conclude that the proposed reclassifications are highly inconsistent with the Land Use and Development Plan because they fail to conform to the character description, purposes, policies and objectives of Moderate Intensity Use and Low Intensity Use, and because they are 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.
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