April 11, 2005
Peter Frank, Director
Bureau of Forest Preserve Protection and Management
NYS DEC
625 Broadway
Albany, NY 12233
Re: Draft Forest Preserve Roads Policy
Dear Mr. Frank:
On behalf of the Association for the Protection of the Adirondacks, I submit the following comments regarding the Department of Environmental Conservation's (DEC) Draft Forest Preserve Roads Policy. We applaud the work that has gone into developing this much-needed policy, however as recent events regarding the Old Mountain Road in the Sentinel Mountain Wilderness demonstrate, there is obviously more work to be done.
Purpose and Background
The Association appreciates the contextual background included in Section III of the draft policy, but is concerned that an essential clause has been left out. Both the Adirondack Park State Land Master Plan (APSLMP) and the Catskill Park State Land Master Plan (CPSLMP) state, "Public use of motor vehicles by the general public will not be encouraged." This roads policy must reflect the comprehensive plans that guide management of all Forest Preserve lands in the Adirondack and Catskill Parks.
Is it a Road?
Across the Forest Preserve from the Black River Wild Forest, to the Wilcox Lake Wild Forest, and now the Sentinel Mountain Wilderness, needless arguments and unending frustrations develop within the unit management planning process because the question "is it a road?" continues to be asked without a satisfactory answer. The Association's expectation was that the long-awaited "Road Policy" would address this essential issue unequivocally and with clarity. Unfortunately, it has not. A critical component of the new road policy must be a procedure for establishing the status of each "way" through the Forest Preserve. In addition, if a way's status has been determined as abandoned, steps need to be outlined in the policy to formally close or abandon roads so that its legal status is not in question.
Determination of Road Width, Driving Surface and Desired Condition
The policy states that "The width, existing condition and desired condition of all roads will be addressed in Unit Management Plans (UMPs)." This statement simply avoids addressing the issue and simply displaces it by making it a part of the UMP. The state must provide clear guidelines to the land manager responsible for implementing the plan. Those guidelines must include standards for width, driving surface and desired conditions of roads in the Forest Preserve. The current trail classification system DEC uses in UMP's is a good example.
Information Needs
Time and again the Association has criticized the Department for failing to include information that would assist the public in decision making. This proposed policy is no exception. It must include a current assessment of the status quo, including the mileage of existing roads and the multitude of impacts resulting from roads in the Preserve. The Adirondack Park Agency recently produced a map showing the extent of influences, from what the Agency believes to be current roads on Forest Preserve lands, on the "Primitive" resources of the park. It is exactly the type of map that should accompany the draft Roads Policy.
Ordinary Maintenance
This policy allows for "ordinary maintenance" in the Adirondack Park without APA consultation or UMP authorization. Attached are photos of the Mill Creek Rd. in the Black River Wild Forest and the Wolf Lake Landing Rd., which is just North of the Mill Creek Road. The latter has received lots of work, including tons of gravel, over the past summer and greatly altered the road's character. What is unacceptable to the Association is that the changes in character of the Wolf Lake Landing Road are a result of actions outlined in this draft policy as "Ordinary Maintenance" including
- pothole filling,
- grading of driving surface,
- cleaning of existing ditches,
- mowing and brushing, and
- resurfacing of driving surface, with similar material currently used on the road.
"Ordinary Maintenance" has obviously changed the character of the Wolf Lake Landing Road. We request that you reconsider your list of acceptable practices to reflect this reality.
Conclusion
The Association recognizes the challenges faced in completing the new roads policy. But we are also aware that the time has long passed wherein an appropriate roads policy should have been developed and subjected to the appropriate public review process. We look forward to working with you in developing a sound Road Policy that meets the myriad environmental, social, legal, and recreational challenges of today and fully protects the irreplaceable wild character and ecological integrity of the Forest Preserve.
Sincerely,
Kevin Prickett Wilderness Stewardship Advocate
CC: Rob Davies
Karyn Richards