Re. Project 2021-0256, DEC, Wetland Impacts Along Multi-Use Trail

David Gibson
Managing Partner
Adirondack Wild: Friends of the Forest Preserve
Ballston Lake, NY


Dear Mr. Haralson,

Thanks to the Agency’s longstanding study and mapping of Adirondack watersheds and wetlands, the APA has applied a fine filter to the varied characteristics, classifications, and values of Park wetlands over many decades. This work no doubt continues to be refined by Agency staff.

It is with this in mind that we wish to address your request for public comment about the DEC’s construction of the linear multi-use trail between Lake Placid and Tupper Lake, and impacts on bordering wetlands.

While the Agency and the DEC can readily discern the direct impacts to wetlands along the 34-mile linear corridor (approximately 0.5 acres), the ecological footprint and impact of the project extends outside the corridor and its shoulders, adding up to a much larger area.

Adirondack studies by the Wildlife Conservation Society have shown that an ecological impact zone extends out many hundreds of meters from a new construction footprint. While the railroad bed has existed here for more than a century, the new multi-purpose trail introduces fresh footprints, dimensions, and human uses that may increase the edge-effect of the linear corridor, or that may impose new obstacles to animal migration. This may cause declines in wetland physical and biological diversity along the corridor.

Introduction of exotic invasive species, the additional drying effect along the corridor, increased difficulties in crossing the multi- trail (in comparison with the former railroad bed), an increase in predation on songbirds nesting along the corridor or heightened predation and competition among small mammals inhabiting these wetland areas might possibly be anticipated from this project.

The half-acre of direct wetland impacts that you and DEC already anticipate may result in 30 or more acres of indirect, ecological impact from edge effects along the 34-mile corridor. We think that these likely off-site impacts are sufficient such that the APA and DEC team should factor them into your assessments and plans.

To simply say that there is one-half acre or less of anticipated direct impact on wetlands begs the question of what kind of wetlands these are. Having already studied them, your team is in a strong position to differentiate, identify and determine the type, characteristics and value ratings of each small wetland encountered along the 34-mile corridor. Each wetland type and associated habitats will experience slightly (or more significant) different impacts to the same construction techniques. These deserve to be assessed, and possible mitigation measures considered.

This suggests the scale of your project review. At the macro and meso scales, APA’s Resource Analysis and Scientific Services team should be able to identify the species occurring in each wetland type, what their movements are, the connections between them and upland habitats. At a more micro scale, construction site design techniques might vary at certain nodes along the corridor to mitigate impacts and to be more protective of the most valuable wetlands intersecting the project.

Finally, the Agency’s Private and State Land Master Plan require that the wetlands along the corridor within private lands classified Resource Management, Rural Use, and State Lands classified Wilderness and Canoe receive especially careful assessment and mitigation given overriding public and natural resource considerations and values.

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: Barbara Rice, Executive Director
Megan Phillips, Deputy Director for Planning
 Joe Zalewski, DEC Reg. Director
Adk Wild Board of Directors, Advisors