Adirondack Council
Adirondack Mountain Club
Association for the Protection of the Adirondacks
Environmental Advocates of New York
Residents' Committee to Protect the Adirondacks
Sierra Club
February 28, 2005
Hon. Ross Whaley
NYS Adirondack Park Agency
P.O. Box 99
Route 86
Ray Brook, NY 12977
Siamese Ponds Wilderness Area UMP and Indian Lake Islands Campground
Dear Chairman Whaley:
By statewide and global standards, the Adirondack Forest Preserve is significant. Its size, biological diversity, recreational opportunities, and proximity to millions of people contribute to the Preserve's uniqueness. But the Forest Preserve is also susceptible to misuse, abuse and neglect. We must manage this magnificent legacy of wildness with great care and sensitivity if we are to pass it on, undiminished, to future generations.
The Siamese Ponds Wilderness is one such place in need of thoughtful and careful management. Historically, it inspired many visionaries, including Howard Zahniser, author of the Federal Wilderness Act, and Paul Schaefer, known for his dedication to and effective advocacy on behalf of the Adirondacks. It continues to inspire today's visionaries: author Bill McKibben said in a recent New York Times article that it is "one of the loneliest and most beautiful parts of New York's "forever wild' Adirondack Forest Preserve."
The organizations listed above, have many concerns about the actions proposed by the Department of Environmental Conservation (DEC) in the Siamese Ponds Wilderness Final Draft Unit Management Plan (SPWDFUMP). And we share serious concerns about the review and public hearing process administered by the Adirondack Park Agency (APA) in relation to this UMP.
APA Action on Siamese Ponds Wilderness Plan UMP Violates APA Policy
Action by the APA on the SPWDFUMP should not be undertaken at its March meeting because the APA has failed in its public comment process and official review to comply with its own policy, entitled "Agency Review of Unit Management Plans Pursuant to the Adirondack Park State Land Master Plan" (approved 2001, revised 2003, and referred to as State Land-1). We are troubled that in at least two respects APA actions seem at variance with the stated process enumerated in this policy:
1. Necessary Staff Documents Have Not Been Developed and Made Public
The State Land-1 policy enumerates a process for APA review of a final draft UMP for compliance with the Adirondack Park State Land Master Plan (APSLMP). Item 9 (p. 5) states that the State Land Team's report will be "available for review at least 30 days prior to a meeting at which the Agency will first consider the unit plan's compliance with the master plan." It is our understanding that this has not been done. Further, if, as Item 9 states, comments on such a document were solicited from APA Commissioners, we would submit that this constitutes a public document, as all materials provided to the Commissioners are public documents.
More important, Item 10 (p. 5) states that a final report from the State Land Team will be prepared "at least 15 days prior to the meeting at which the Agency will first consider the unit management plan's compliance with the Master Plan. A two-meeting cycle for final review of a Unit Management Plan is preferred." To our knowledge, the 15-day requirement has not been met. Further, the policy states that there should be a 2-meeting cycle for plan review after the final staff report has been completed and distributed to the Commissioners and the public. This does not seem to be the process being followed by the APA staff in its review of the SPWDFUMP.
2. Public Hearing Fails to Provide Draft UMP Necessary for Informed Public Comment The APA has announced a public hearing period on the SPWDFUMP, which ends on March 1, 2005. While this hearing is meant to gather comments from the public, the public has not been given an opportunity to read this plan. The only copies made available to the public were those distributed to the Forest Preserve Advisory Committee by the Department of Environmental Conservation or were part of the 50 copies supplied to the APA by the DEC. For unknown reasons, the SPWDFUMP is not available on either the DEC or APA website. Requests to DEC and APA offices for copies by the public were met with responses that additional copies were not available. The APA's State Land-1 policy creates the expectation that as a matter of process, final draft UMPs will be made available on the DEC and APA websites (p. 4), but this has not happened. Failure to adequately supply the public with the final draft UMP undermines the effectiveness of a public hearing to gather public comments.
Due to problems with the public hearing process, and the apparent failure to generate a final report by the State Land Team, we call upon the APA to postpone action on the Siamese Ponds UMP until the APA's April meeting at the earliest. (Parenthetically, we note that for similar reasons, Agency action on the Vanderwhacker UMP should also be postponed until at least April).
Designation/Classification of the South Basin of Indian Lake in 1979
The eastern shore of Indian Lake, originally classified as Intensive Use, was re-classified as Wilderness in 1979. This did not happen haphazardly. The DEC, local government officials, legislators, private individuals, national and regional environmental groups, snowmobile clubs, and other stakeholders were involved, and many supported the reclassification. Further, the APA records cite the approval by Governor Hugh Carey as specifically noting "the reclassification of approximately 37,000 acres of existing state land including the Indian Lake Intensive Use Area." This history cannot be ignored and must be taken into account as part of this area's future planning.
While some at the DEC have openly referred to this reclassification as a "mistake", we believe careful examination of the record will show that it was the right decision then, and continues to be the right decision today. The issue before the APA now is to ensure that this area be managed as a Wilderness Area and not as an Intensive Use Area.
DEC's Proposal for an "Indian Lake Islands Special Administrative Area" Violates the State Land Master Plan
Administrative subdivisions of Wilderness areas are not allowed
The State land Master Plan (SLMP) does not make a provision for dividing Wilderness beyond the current classifications and into "a smaller subdivision called a special area compartment-Indian Lake Islands Special Administrative Camping Area" (page 103 of the SPWDFUMP). This type of area within Wilderness would represent a new classification, which is strictly illegal without undertaking the reclassification procedures set forth in the SLMP.
The "wilderness experience" is one of the Adirondacks' most valuable commodities and it should not be compromised as is being proposed in the SPWDFUMP. Dividing the proposed 16 campsites along the eastern shoreline of Indian Lake as a "special area compartment" would degrade the very "wildness" of this area that makes it so special.
The proposal for a "Special Administrative Camping Area" that includes parts of the Siamese Ponds Wilderness Area should therefore be rejected, as it fails to comply with the SLMP.
Fees should not be charged for camp sites in Wilderness areas, and the campsites in the Wilderness area should not be managed as part of the state's reservation/campground system
The idea of generating income from the proposed Indian Lake Island Administrative Area for the Indian Lake Island Campground compromises the irreplaceable benefits of an untrammeled wilderness. The justification stated in the SPWDFUMP for making these sites a part of the Indian Lake Islands Campground is to enable enforcement of camping regulations (i.e. quiet hours, age limit for alcohol possession, fireworks, etc.), yet there is no documentation that these are significant management challenges. If preventing resource degradation is paramount to this UMP, then these sites should not be managed as a campground, but must be managed as a wilderness.
Wilderness area must not be managed as an Intensive Use Area
The SPWDFUMP states that over 4,700 camper days (a camper day is defined as one person camping for one night) were enjoyed in 2004 from Memorial Day through Labor Day on 20 campsites. To which, we ask, at what expense? With an average of nearly 48 people per day at those sites, permitting this to occur is a violation of the SLMP. The definition of an Intensive Use area states "these areas provide overnight accommodations" for a significant number of visitors" (38). This Wilderness is clearly being managed as an Intensive Use Area and such management must cease.
Despite years of management by DEC's Campground staff, there has been tremendous damage to the natural resources from over-use and from vegetation trampling, from ditching, and from subsequent erosion. The overriding theme of the SLMP is that Forest Preserve lands must be managed for the protection of natural resources - not for public recreation. It is quite reasonable that the opportunity to reserve campsites through the state reservation system and access to these sites via a motorboat has greatly increased their use. Moreover, campsites are patrolled by DEC staff in motorboats, a practice used only for emergencies on lakes in other Wilderness areas, such as on Little Tupper Lake and Lake Lila.
The Siamese Ponds Wilderness Area should no longer be managed as an Intensive Use Area.
The Siamese Ponds Wilderness Draft Final Unit Management Plan fails to provide management alternatives for the Indian Lake shoreline and islands
DEC's failure to provide alternatives to the 16 campground sites managed in the Siamese Ponds Wilderness is unacceptable. We urge the DEC to look at management examples from other areas with similar resource challenges, such as the Boundary Waters Canoe Area and the Voyageur Canoe Area in Minnesota or the Allagash Wilderness Water Way in Maine for alternative proposals. The High Peaks UMP also proposes viable alternative management solutions that should be considered. Page 152 of that UMP recognizes that current camping guidelines present challenges in protecting "wilderness resources as required by the APSLMP." Subsequently, the HP UMP restricts camping to areas of relatively high use and only at designated sites. A similar alternative should be considered for the 20 campground sites managed in the Siamese Ponds Wilderness.
Additionally, alternative proposals were made during the DEC's public hearing on the draft plan, but were ignored. The DEC's responses to public comments do not even address comments made from many individuals and organizations that suggested a "motorless Jessup River Bay." The DEC has provided no explanation for this omission. This management alternative merits discussion and inquiry. SPWDFUMP includes alternatives for other management decisions, such as campsites on 13th Lake, but for the Indian Lake shoreline and islands only one management action is proposed. (This should be contrasted with the Vanderwhacker Wild Forest Final Draft UMP, which includes 8 alternatives for a Newcomb to Minerva snowmobile trail.) A motorless Jessup River Bay designation would minimize negative impacts on nine Wilderness campsites and provide a new and diverse recreational experience for this area. Indian Lake is a heavily used and heavily motored lake. A motorless Jessup River Bay would be manageable and would provide a greater level of protection for this area than currently exists.
Alternative management proposals should be developed for APA discussion and approval, which include an option for the management of the Jessup River Bay as a motorless area. The APA should request such alternatives from the DEC prior to any finding that the SPWDFUMP complies with the SLMP.
Transfer of sites to Jessup River Wild Forest is unacceptable
There are currently 20 campsites along the Wilderness area shoreline on Indian Lake. The DEC proposes to transfer four sites to the Jessup River Wild Forest area, two of these to an island and two to the Indian Lake shoreline. This is being recommended because the current campsites fail to meet the necessary separation distances. We agree that the number of sites should be reduced, but given that most of the sites on the Indian Lake islands in the Jessup River Wild Forest area fail to meet separation distance requirements it makes little sense to develop new sites in this area. Further, no such action should be done without planning and examination through a UMP for the Jessup River Wild Forest.
All campsites in the Siamese Ponds Wilderness Area along the Indian Lakes shoreline should meet minimum separation distances as stated in the SLMP. We support removal of four sites, but these sites should not be transferred to other areas.
We thank you for the opportunity to present our views on the Siamese Ponds Wilderness Draft Final Unit Management Plan.
Sincerely,
Brian L. Houseal
Executive Director
Adirondack Council
Neil F. Woodworth
Executive Director
Adirondack Mountain Club
David Gibson
Executive Director
Association for the Protection of the Adirondacks
David Higby
Adirondack Project Director
Environmental Advocates of NY
Peter Bauer
Executive Director
Residents' Committee to Protect the Adirondacks
John Stouffer
Legislative Director
Sierra Club - Atlantic Chapter