July 5, 2006

Rick Weber
NYS Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977

Re: Blue Ridge Wilderness and Wakely Mountain Primitive Area UMP

Dear Rick:

On behalf of the Association for the Protection of the Adirondacks, I submit the following comments regarding the BRW and Wakely Mountain Primitive Area (WMPA) Final Draft Unit Management Plan (UMP) in hopes of ensuring the area's wild future.

Tree-Cutting to Maintain Scenic Vistas in Wilderness is Non-Conforming

On page 157, the UMP calls for identifying existing vistas and maintaining them by the cutting of brush and tree limbs and by minor tree cutting. Later, the UMP specifically calls for maintenance of "the existing vista at the end of the trail near the summit of Sawyer Mountain." The Association asks and expects the APA to inform the DEC that there is no authority in the State Land Master Plan for the DEC to undertake such tree cutting. Nowhere in the APSLMP Wilderness guidelines conforming structures and improvements listing can the reader find "Cutting or manipulation of vegetation to maintain existing vistas," or anything similar. As Agency members know very well, the APSLMP considers all unlisted structures and improvements - with the major exception of interior ranger stations - nonconforming.

Tree cutting to maintain vistas is not, for obvious reasons, included in the Structures definition. It is, according to the APSLMP definition, considered an Improvement. Thus, the APA is obligated to be guided by the APSLMP's definition of Improvement found on page 17:

"any change in or addition to land, which materially affects the existing use, condition or appearance of the land or any vegetation thereon, including but not limited to foot and horse trails," etc. (emphasis mine).

Keeping such a clear and unambiguous APSLMP definition of Improvement in mind, the Agency must conclude that cutting of trees or manipulation of vegetation to maintain scenic vistas, not being found on the list of confirming Improvements in Wilderness, must perforce be a nonconforming Improvement. The UMP, therefore, can not be considered conforming to the APSLMP until the General Objectives on page 157 and the specific management action on Sawyer Mountain on page 161 are clearly labeled and described as nonconforming actions which, while apparently greatly desired by the DEC, can only be undertaken through an amendment to the APSLMP.

In Wilderness Management, Hendee and Dawson state "wilderness management is essentially the management of human use and internal and external influences to preserve an area's naturalness and solitude." The act of cutting trees and clearing lands to maintain a scenic vista is an act of developing a man made facility to provide easy access to a view. The DEC's proposed vista maintenance in wilderness can not be considered by any informed observer an attempt to preserve the area's natural qualities.

Aware hikers know that scenic vistas open and close on a regular basis throughout the Forest Preserve depending on natural succession and physical events and perturbations. By determining that tree cutting for scenic vistas is nonconforming in Wilderness according to the APSLMP, neither the Agency nor the Department can not be considered to be in any way denying the hiking public of scenic views of the Adirondack Forest Preserve. Such a notion would be pure nonsense.

Last year, a very beautiful vista looking out from Sawyer Mountain onto the interior of the Blue Ridge Wilderness was improperly cut and cut severely by DEC employees. 958 square feet were involved and more than several dozen mature trees were cut. I attach photographs taken not long after the tree cutting. The vista there has long existed without tree cutting. Its eventual closure through natural succession will take years, but does not in any way imply that hikers will no longer visit the mountain or that other equally beautiful views will not open up elsewhere in the Blue Ridge Wilderness area through physical forces such as wind. In no way should DEC management recommendations or those of any agency with a mandate to apply Wilderness principles in the field be driven by a desire to route hikers up a particular trail. Such management would be internally inconsistent with other management recommendations and principles in the Blue Ridge Wilderness UMP and totally contrary to DEC and Agency mandates. However, I conclude that the sole reason DEC insists that tree cutting to maintain scenic vistas in Wilderness is justified is to assure hikers a perpetual view on one popular trail within a 47,000 acre Wilderness area. This justification, even backed by Department policy, is completely trumped by the lack of authority in the APSLMP for this or any other action to "materially change" the vegetation along a trail to maintain a scenic vista in Wilderness.

Wakely Mountain Primitive Area: Helipad and Observer Cabin Nonconforming

The Association for the Protection of the Adirondacks has many concerns about the future classification and facilities in the WMPA and provides the following comments.

• Given its close proximity to the wilderness boundary and its historical, recreational, educational and communications values, the Association supports the retention of the fire tower and the retention of Primitive classification only for the firetower.
• The WMPA current state land classification of Primitive should remain intact just for the footprint of the firetower itself until the point when the fire tower is no longer needed. At that time the firetower footprint should be reclassified as Wilderness and the fire tower removed. All other areas within the current WMPA should be reclassified Wilderness.
• The helipad and observer cabin are not integral to the communication or recreational use of the fire tower and must be removed. From Pillsbury Mountain to Kane Mountain, the observer cabin is often a focal point for vandalism and littering. The removal of these facilities is essential to minimizing these management challenges. Furthermore, the cabin and helipad lack historical significance as they are not included in the New York State and National Registers of Historic Places. The argument to retain the helipad has included the need to safely land a helicopter for installation and maintenance of communications system. The Association strongly opposes such a development and reminds the DEC that Pillsbury Mountain's tower lacks a landing pad despite having similar management challenges (i.e. the Pillsbury Tower, like Wakely, also has a proposal to install a repeater system).

By providing context to planning and by helping to draw a clear picture of the unit, the UMP appropriately includes an abundant inventory of:

• climate data that for instance highlights the steep precipitation gradient in the area,
• wetland acreage,
• vegetation cover types and percentage,
• existence of old growth,
• description of significant ecological communities,
• amphibian and reptile species and habitat descriptions,
• significance of 85 percent of bird species associated with boreal forest found in the unit,
• potential Spruce Grouse habitat map, and
• maps outlining bird conservation areas and deer wintering areas.

• the Cultural Values section that provides a fine description of human's evolving relationship with wild lands,
• the highlighting of the conservation history and uniqueness of the Forest Preserve, stating that it was the "earliest acts of large-scale public land protection in the nation" and
• DEC's incorporation of modern land management tools by utilizing the four values outlined in Hendee and Dawson as a basis to demonstrate the importance of wilderness.

Wakely Mountain Trail

Like many Adirondack mountain trails, the trail to the summit of Wakely Mountain was poorly designed and erosion has been compounded by these conditions. To address this challenge, the Association supports the closure of the current trail and prefers a re-route from Cellar Pond or a better designed trail with switchbacks near the current trail. In the event that either alternative is chosen, the current trail should be closed.

Northville Lake Placid Trail

Page 177 and 178 of the UMP describes the analysis to relocate the Northville Lake Placid Trail. We are pleased to see this analysis incorporate information such as ecologically, typography, vegetation, and wetlands. However given the resources devoted to the partnership with the Adirondack GIS Consortium, we are disappointed that the "cost analysis" tool was not utilized to establish the alternative for this trail. The consortium demonstrated the power of this tool when it was utilized to assess the snowmobile trail alternatives through the Vanderwhacker Wild Forest. The UMP provides an excellent written analysis of the alternatives, but we are concerned why this powerful land management tool has not been incorporated.

Wild Forest to Wilderness Reclassification

The Association has identified two parcels that boarder the BRW which must be reclassified to Wilderness. The first includes the Wild Forest tract south of Sagamore Lake and north east of the road to Lake Kora. The second is located on the north-west corner of the unit, just north of Sagamore Lake. This reclassification of Wild Forest to Wilderness should include the extension of the current northern boundary to the Sagamore Road.

Conclusion

We respectfully submit these comments in hopes of ensuring well planned use that preserves the BRW area's vitally important wilderness character. The work that DEC and APA have invested into this UMP is commendable. Except for two serious management proposals in this UMP which we ask and expect the Agency to find nonconforming, the Association appreciates the effort to incorporate the spirit of wilderness to guide many of the planning proposals for this area.

Sincerely,

David H. Gibson
Executive Director

CC:
Board of Trustees and Advisors, Association for the Protection of the Adirondacks
Peter Bauer, RCPA
John Davis, Adirondack Council
Neil Woodworth, ADK
Rick Fenton, DEC
Karyn Richards, DEC
Rob Davies, DEC