Devan Korn
Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977
Re. “Indian Brook Preserve” Large-Scale Subdivision, Town of Bolton, APA 2025-0195
Dear Mr. Korn,
We have reviewed what appears on your website as Phase 1 of the “Indian Brook Preserve,” 30-lot, Large-scale Residential Subdivision in Low Intensity Use, Town of Bolton. To our disappointment, the proposed subdivision layout appears to us as a conventional subdivision, with a combination of cul-de-sacs and long, gridded-out, five-acre lots which, rather than minimize disturbance, will spread negative impacts through most of the 90-acres.
The only apparent design consideration presented to the APA thus far is to keep the immediate development footprints out of wetlands and steep slopes, which the applicant has to do anyway to comply with law. This minimalistic, legalistic approach to design is typical of subdivisions anywhere else in New York State. It should be deemed incompatible with the Adirondack Park Agency’s stated objectives for large-scale subdivisions in the Adirondack Park, or even with the purposes, policies, and objectives of Low Intensity Use areas described in the Park’s Private Land Use Plan.
The Phase 1 information submittals to the Agency fail the Large-Scale Subdivision permit request for information in a number of respects, as detailed below. Also, in no way does the proposal even minimally comply with the Agency’s large-scale subdivision permit criteria “including protection of open space, wildlife, and habitat resources, and in accordance with the objectives of conservation design.”
The proposal is not a conservation design. If it were, a full resource inventory would be submitted; evaluated as to thoroughness and completeness; sensitive resources, physical and biological, mapped; contiguous blocks of open space inclusive of those resources also mapped; and only then would lot and roadway lines be drawn in to avoid these combined resources and arranged so that the lot and roadway ecological impact zones overlap with each other to the maximum extent possible.
From what we can see on the website, none of these objectives of conservation subdivision design have been even minimally achieved so far. The fact that the ecological impact zone of each new home and driveway far exceeds the actual development footprint must be taken into account during project review.
As to the information clearly expected from the Agency during Phase 1 and, to our reading and knowledge, not yet submitted:
- There is no information, mapped or described, about permanent and intermittent streams;
- There is none of the requested wildlife habitat information, including but not limited to vernal pools, bird species, deer wintering areas, forest blocks, and more.
- There is no aquifer information.
- There is no resource information from area organizations who would be familiar with the project area, such as the Lake George Park Commission, the DEC Natural Heritage Program, The Nature Conservancy, or from land trusts like the Lake George Land Conservancy.
- There is no composite base map with all available resource information clearly shown along with lot lines and clearing limits. The maps submitted are very indistinct and difficult to read or interpret.
- Ecological impact zones surrounding each proposed home and driveway are not identified.
- There are no contiguous, protected blocks of forested open space.
As for the proposed layout, contrary to the Agency’s expectation for large-scale subdivisions the proposal does not appear to minimize creation of new disturbances within an otherwise mostly undeveloped forest matrix. The two cul-de-sacs and associated 12 or so building lots in the northern portion of the project area will greatly disturb the area and even appear to cut into wetland buffer areas and steep slopes.
Instead of leaving contiguous wetlands, wetland buffers, and steep slopes alone and not lotted into individual ownerships, practically all of the lot lines appear to bisect these significant landscape features into multiple ownerships which threatens future wetland disturbance, potential degradation of wetland functionality, loss of any forest management opportunities, and erosion in areas of steeper slopes. The backlot lines should be shortened and kept out of the wetlands and steep slopes.
As for the Agency’s Phase 1 requested project alternative designs, none are shown. The final schematic in the package may be a submitted alternative but, if so, it is not marked or described as such. The lack of marked and described alternatives that would better avoid project impacts on sensitive resources and open space and meet the Agency’s large-scale subdivision application goal of being in accordance with the principles of conservation design is a glaring omission.
We hope that during public comments, the applicant will be encouraged by the Agency to seek the advice of scientific, resource, planning, and smart design professionals who abound in the Lake George area, and seriously consider alternative conservation designs less wasteful of land and impactful of resources.
Thank you for considering our comments and concerns.
Sincerely,
David Gibson, Managing Partner
Cc: Barbara Rice, APA Executive Director
John Burth, APA
APA Members and Designees
Adirondack Wild: Friends of the Forest Preserve
P.O. Box 9247, Niskayuna, NY 12309
www.adirondackwild.org
518-469-4081