December 5, 2006

Richard Weber
Regional Planning Division
Adirondack Park Agency
P.O. Box 99
Ray Brook, NY 12977

RE: Proposed Final UMP for Raquette Boreal Area

Dear Mr. Weber:

On behalf of the Adirondack Mountain Club (ADK), we would like to take this opportunity to comment on the Raquette Boreal Proposed Final Unit Management Plan (UMP).

Snowmobile Trails

ADK strongly supports DEC’s determination that the “No Action” alternative is the only legally viable management response to proposals discussed in the UMP to provide snowmobile access to areas east of Carry Falls Reservoir. As stated on page 100 of the UMP, “A comprehensive assessment of all of the options that could resolve that issue has not been done.”

Further, the UMP states that if any snowmobile access is proposed in the future, an amendment to the UMP will be required along with a more detailed analysis of potential impacts associated with snowmobile access.

Neither DEC or APA can in any way legally authorize (in the context of this UMP) the siting and construction of a snowmobile and ATV bridge over the Raquette River to provide motor vehicle and snowmobile access to Forest Preserve and state held easement lands east of Carry Falls Reservoir.

ADK strongly supports the closure of the Bear Brook snowmobile trail and designating it has a maintained hiking trail.

Motor Vehicle Use

ADK strongly supports DEC’s determination in the UMP that the “No Action” alternative is the only legally viable management response to proposals for motor vehicle access to the portions of the unit east of Carry Falls Reservoir. Until DEC completes a more detailed analysis of potential impacts associated with motor vehicle access in the unit and reconciles legal prohibitions on said use in the Adirondack Park State Land Master Plan and 6 NYCRR Part 196.1, no such alternative can be legally authorized and implemented. The UMP states that an amendment to the UMP would be necessary if motor vehicle access routes are proposed in the future.

ADK supports DEC’s commitment in the UMP to providing adequate signage and rock barriers on roads closed to motor vehicle use to prevent illegal motor vehicle and ATV use.

It is important to note that DEC does not have any sustainable trail development standards for public ATV use on conservation easement lands. Until such standards are in place there should be no public ATV access on conservation easement lands.

Motorboat Access

ADK supports the UMP’s proposal to promulgate a new regulation under 6 NYCRR Part 196 to prohibit the use of motorboats on the Jordan River.

General Public Access

ADK supports the management actions listed on the top of page 102 in the UMP with respect to hiking trails and canoe carries with the stipulation that attention must be given to providing sufficient parking for these facilities.

We thank you for this opportunity to comment on the Raquette Boreal Proposed Final Unit Management Plan.

Sincerely,

 

Neil F. Woodworth                                   Marisa Tedesco
Executive Director                                   Conservation and Legislative Director