July 10, 2025
Aaron Ziemann
Adirondack Park Agency
Box 99
Ray Brook, NY 12977
Re. Land Vest Timber Harvest, Indian Lake, APA 2025-0104
Dear Mr. Ziemann,
Adirondack Wild has the following concerns about this timber harvest proposal to clear-cut or overstory-cut over 500 acres adjacent to and very near the Cedar River and its tributaries.
Our primary concern: Our main concern is that the proposed forest harvest appears to lie within resource sensitive riparian corridors adjacent to the Scenic Cedar River and a half a dozen of its tributaries, to connected wetlands, and to two Wilderness areas. The area is also classified Resource Management. To our knowledge, the sensitivity of this area is atypical for forest clearcutting permit applications. Careful review and conditions are called for in this instance to uphold the Agency’s responsibilities for resource protection.
Review by the full Agency is warranted: Because of the area’s land use classification, River Area, apparently sensitive nature, and resource- rich character, the permit should be reviewed by the entire Agency and not be delegated to staff.
Lack of Information for Public Comment: One short paragraph posted about the proposed harvest is inadequate for informed public comments. There is no descriptive information presented about the area’s natural resources. The public should not have to resort to FOIL procedures to view a succinct summary of these. The applicant’s harvesting sketch is difficult for the public to interpret. There is also no mention of the forest harvest history at this location and previous Agency permits.
Regulations: However, from the limited information provided questions arise whether the applicant intends to conform to the Agency’s regulatory prohibition of timber harvesting or construction of wood roads within 100 feet of the Cedar River and its tributaries. Moreover, beyond 100 feet of the Cedar River out to the quarter-mile boundary of the River Area there appears to be no adherence to the Agency’s Part 577.6 River Area regulations which prohibit clearcutting of more than 15 contiguous acres in the same ownership, and requiring that no more than 50 percent of the basal area in any tract larger than 30 acres be cut.
Instead, the applicant seems to be proposing to simply clearcut more than 300-acres and cut the overstory on another 200-acres. Such significant deviation from Agency regulatory limits strongly suggests that a variance may be needed. Again, this permit must come before the full Agency for a thorough review.
Ecological Assessments: Given the riparian areas and wetlands, the APA should require ecological assessments as part of permit review, otherwise critically rare or sensitive species could be impacted or lost. Searching and mapping flora, fauna and important ecological assemblages is standard practice today for ecologically based forestry. The applicant and Agency should wish to comply with these standards.
Among other things, the biological inventory and assessment should account for amphibian populations and movements from breeding pools to upland habitats. Amphibians require as much as 800 to 1,000 feet of upland habitat beyond their breeding pools in order to survive. One hundred-foot buffers around their breeding pools are insufficient to protect amphibian populations. Depending upon the outcome of the biological inventory, use of variable retention forest islands and corridors that can break up large, open clearcuts would sustain critical movement and breeding of amphibians which, in turn, contribute to forest ecosystem health.
Post Harvest Conditions: Post harvest, the Agency should be insisting on conditions which conform with the industry-accepted standard of retaining at least 450 quality stems/acre of desirable growing stock. This standard was discussed with the industry and agency during silvicultural meetings held at APA in 2015. We urge that APA staff foresters and biologists be on-site pre-harvest, during, and post-harvest to assess permit compliance.
Conclusion: This clear-cut application affects several miles of a Scenic River, numerous tributaries, and potentially valuable wildlife habitats near two Wilderness areas. It appears to be one of the most sensitive forest harvesting applications to come before APA in recent years. It should be thoroughly reviewed, undergo ecological assessments, and come before the full Agency to consider its impacts to Park resources, including the cumulative impacts of timber harvesting at this location.
Thank you for considering our concerns.
Sincerely,
Managing Partner
Adirondack Wild: Friends of the Forest Preserve
P.O. Box 9247, Niskayuna, NY 12309
Adirondackwild.org
518-469-4081
Cc: Barbara Rice, Executive Director
Agency Members and Designees
Claudia Braymer, Protect the Adirondacks
Jackie Bowen, Adirondack Council
Cathy Pedler, Adirondack Mountain Club