January 17, 2007

Mr. Stewart Brown, Senior Forester
NYSDEC
PO Box 220
232 Golf Course Road
Warrensburg, NY 12885-0220

Dear Mr. Brown:

On behalf of the Adirondack Mountain Club (ADK), we would like to take this opportunity to comment on the Lake George Wild Forest (LGWF) Draft Unit Management Plan (UMP). Partly due to its close proximity to the Capital Region and partly due to its easy accessibility via the Northway, this region is one of the more popular and more heavily used areas in the Adirondack Park.

Snowmobile Trails

While ADK supports the UMP’s recommendation to close nine miles of snowmobile trails in the unit, ADK questions whether DEC has done all it should to eliminate duplicative trails in LGWF. The recently adopted Snowmobile Plan for the Adirondack Park lists the area of the LGWF lying east of Lake George as an area with a proliferation of duplicative trails. The Snowmobile Plan states that these areas should be the focus of efforts to re-designate snowmobile trails for non-motorized use. Accordingly, we ask DEC and the Adirondack Park Agency to carefully re-evaluate the multiple loops of snowmobile trails in the area of the LGWF east of Lake George to determine whether additional mileage beyond the aforementioned nine miles should be closed or redesignated for non-motorized recreational use.

ADK supports the rerouting of Lapland and Millman Ponds trail sections to follow along the edge of the ponds inside the forest cover.

Illegal ATV Use

ADK strongly supports all proposed DEC management actions to eliminate illegal ATV use on state-owned lands. This requires the construction of rock barriers and barricades to prevent removal and/or vandalism. Proper signage is also necessary, especially to provide sufficient evidence for legal proceedings following ticketing. Additionally, there should be sufficient enforcement patrols and sweeps to curtail illegal ATV use in all parts of the LGWF.

It has come to our attention that trails in the Lily Pond/Round Pond area have been seriously damaged by excessive motor vehicle use. The UMP fails to adequately address this issue and provide a strategy for protecting the new trail from excessive damage due to illegal ATV trespass. The UMP should also address ATV trespass at Greenland Pond. We believe that any roads or trails illegally opened by the Town of Horicon for ATV use should be closed and barriered immediately.

Hiking and Cross Country Ski Trails

Prospect Mountain Trail: ADK strongly supports DEC’s inclusion of a new official trail up the south side of Prospect Mountain from the Lake George Village Recreation Area. For several years this route has been used informally by our members, as it is far superior to the steep and badly eroded trail going up the east side of the mountain from the Village of Lake George.

The Draft UMP suggests that a major re-route is needed around one especially badly eroded section of this south-side route. Careful measures should be taken all along this path to control water drainage and avoid potentially swampy sections, thus preventing similar erosion problems elsewhere. The trail’s proximity to Glens Falls and Lake George Village guarantees that it will be heavily used, producing more rutting and erosion, unless the trail is well designed to withstand such use. ADK’s trail experts are willing and eager to help the state by supplying trail design expertise, professionally led volunteers to do the actual work, and possibly even a fully-professional crew as well. Building a well-designed trail in the beginning carries the benefit of avoiding costly repairs years later.

Northwest Bay Tract: ADK supports the UMP’s recommendation to designate the present trail system on the recently acquired Northwest Bay Tract. However, ADK is concerned about the UMP’s proposal to construct an additional 1.5 miles of foot trail from the northern portion of this present trail to the Clay Meadows parking lot. The UMP states that a bridge spanning Northwest Bay would be required to designate a trail in this location. Doctor William Brown in a letter to DEC dated January 5, 2007 outlined four potential problems with the proposed route: cost, threat to a pristine watershed into Lake George, safety, and threatened species habitat. ADK urges DEC and the Adirondack Park Agency to fully evaluate the impacts of the proposed new trail on this area.

Dacy Clearing to Bumps Pond: ADK supports the repair and rehabilitation of the trail from Dacy Clearing to Bumps Pond in accordance with Class III trail specifications.

Buck Mountain Trail: This trail is one of the most popular in the LGWF area. The trail is in need of serious repair, including sections which should be hardened, boardwalked, and/or re-routed.

Palmer Pond Trail: ADK supports the designation of the trail around Palmer Pond as a Class III Ski trail, along with the creation of an additional trail to complete a loop of the shoreline of Palmer Pond.

Mountain Bike Trails

ADK supports the closure of steep, single track mountain bike trails in the Tongue Mountain Range. As stated in the UMP, a large portion of these trails are very steep and not compatible with mountain bike use. ADK also supports a study to determine whether a mountain bike trail system in the vicinity of Prospect Mountain is both desired and feasible.

Camping and Campsites

ADK strongly believes that DEC should develop an accurate inventory and map of all campsites in the area, along with descriptions of their conditions and recommendations for continuing use, needed improvement, or closure. An area as heavily used as the LGWF requires closer and more continuous monitoring than do many of the other wild forest areas in the Adirondack Park.

Lean-tos

Although ADK supports the management proposals regarding existing lean-tos, we question the wisdom of building a new lean-to in the vicinity of Pole Hill Pond. If the Pandanarum Road is being illegally used by ATVs, having a lean-to, or lean-tos in the vicinity of the pond may be inviting misuse.

Further, in regards to the proposed new lean-to on the Northwest Bay Tract, we would like to point out that a 2004 survey of LGWF users conducted by Chad Dawson and Cornell University indicates that a majority of people of who use the area oppose the creation of additional lean-tos. We ask that DEC take this study into consideration.

Sanitation

Due to the popularity of the LGWF and its proximity to major cities, sanitation is another serious problem in some areas of the LGWF. ADK strongly supports educational efforts to obtain compliance with the Leave No Trace and Carry-it-in, Carry-it-out programs. As with other efforts to improve visitor experiences in the LGWF area, this will require a large investment in more ranger personnel for both education and enforcement.

ADK also supports the addition of accessible porta-johns in heavily used parking lots, especially at Clay Meadows, Deer Leap, Hogtown and Pilot Knob Rd. and Buck Mountain trailheads. However, DEC should require that these porta-johns not adversely affect the aesthetics of the area. Careful selection of colors is critical to preserving the wild forest character of LGWF.

Reclassification of Tongue Mountain Range

ADK suggests that this area be reclassified and designated as a separate Wilderness or Primitive Area. This area does not contain snowmobile trails or other non-conforming uses. The UMP recognizes the unique character of this mountain range. A reclassification of this area to Wilderness will provide greater legal protection for the unique and wild Tongue Mountain Range.

Hudson River Special Management Area (HRSMA)

This area is badly in need of extensive regulation. ADK supports the proposed management strategies of: restricting camping in the “front-country” portions of the HRSMSA to designated sites only, and the maintenance of clear signage; establishing a day-use area, codified in regulation, with clear signage; issuing only one camping permit per year to a person/group for any of the designated sites within the HRSMA; monitoring public use and specifically overnight uses through regular patrols as well as by camping permits; and conducting an annual inventory of campsite conditions at the end of the camping season.

ADK opposes an Adirondack Park State Land Master Plan (APSLMP) reclassification of this area to an Intensive Use Area. The significant drawbacks to this idea, stated on page 209, are reasons not to pursue this plan. As stated on page 209, such a reclassification proposal violates the non-degradation concept of wilderness management. ADK concurs with this statement.

Timber Rattlesnake

The matter of the rattlesnake population on Tongue Mountain should be addressed. The timber rattlesnake is a state- designated threatened species and its habitat is critical. There should be more educational information at all trailheads, especially in the Tongue Mountain area, about the snakes and how to avoid an encounter with them. Hikers need to know that they are rarely in danger from the snakes. The serious consequences of illegal killing or poaching of the snakes should be clearly spelled out.

Thank you for this opportunity to present our comments on the LGWF Draft UMP.

Sincerely,

 

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