Wednesday, March 16, 2016

APA Commissioner Indicts Cuomo Administration

APA Meeting 3-11-2016At the Adirondack Park Agency (APA) meeting on Friday March 11, 2016, the APA acted to amend the Adirondack Park State Land Master Plan (APSLMP) to make a series of changes, the most controversial being changes to the Essex Chain Lakes and Pine Lake Primitive areas to allow public bicycle use and use of motor vehicles for management and maintenance by the Department of Environmental Conservation (DEC).

The APSLMP sets management policy for the 2.6-million acre Adirondack Forest Preserve. Since enactment in 1972, the APSLMP has managed Forest Preserve lands classified as Primitive Areas as essentially Wilderness areas. Many Primitive areas have ultimately been upgraded and reclassified to Wilderness. Bicycles and motorized use, even for state agencies, except in times of emergencies, are prohibited in Wilderness areas.

The APA is led by an 11-member Board of Commissioners. Richard Booth, an environmental law professor at Cornell University, holds one of three outside-the-Park seats on the APA Board. He was appointed by Governor Spitzer in 2007 and reappointed by Governor Cuomo in 2012. Booth dissented from the APA’s decision to change Primitive areas and at the end of the APA’s deliberations he delivered a statement on the serious flaws in Forest Preserve planning and management at state agencies under Governor Andrew Cuomo.

Here is Dick Booth’s statement.

“Madam Chair I ask for permission to make some comments.

I’ve argued very long and hard with myself regarding making these comments today. Someone asked this morning if I slept well last night and the answer was no. I make them with great reluctance because I’ve decided they need to be made and I think I’m the person who’s probably in the best position to make them.

These comments are very likely to generate a good deal of criticism. They may generate a good deal of anger. They may generate strong denials. They may generate other ramifications. And I accept those possibilities.

I’m solely responsible for these comments today. I prepared them by myself and particularly no member of the Agency has had anything to do with these comments. No member of the staff has had anything to do with these comments. If there is criticism it should be directed to me.

I highly respect the office of the Governor of this state. I am a longtime observer of state government. I appreciate the awesome responsibilities that sit on the shoulders of the Governor. I respect this Governor’s many accomplishments. I’m very appreciative that Governor Cuomo reappointed me to this Agency so I could continue to serve the people of the State of New York.

I have said publicly that the State Land Master Plan amendment process regarding major amendments is badly broken and that’s what I intend to address here in these next few minutes.

All of you know that the Park is a great treasure, one of the great natural resource areas of the United States and, indeed, a natural resource treasure with worldwide significance.

The Adirondack Park established the Adirondack Park Agency in order the focus, and I quote, ‘the responsibility for developing long-range park policy in the forum or body that reflects statewide concerns.’ The Agency is that forum. The membership of the Agency represents multiple constituencies, and indeed, something as complex as the Adirondack Park would require. It represents local interests. There are five members who are required by law to be full-time residents of the Park. There are three members of the Agency who must live outside the Park and I am one of those. And there are three state officials who report directly to the Governor.

The idea of creating the Agency was that there are different priorities, there are different ideas, about the Adirondacks, and the future of the Adirondacks, and that the Agency would be the place where there would be an honest interchange, and a full interchange, of ideas and then decisions would be made. It was never contemplated that anyone would necessarily be happy with all the decisions or that any constituency would necessarily be happy with any particular decision. But there was a recognition that was important that there be a full and honest deliberation of what matters came before the Agency.

The State of New York has many interests in the Adirondack Park. Those interests at their highest levels involve, certainly, the safety of people in the state, but beyond that, in terms of the land area of the Adirondacks, the highest state interests are the state lands of the Park.

The State Land Master Plan was created to further those interests. And again it’s a mixture of interests, it’s not just statewide interests, but statewide-local interests, state government interest, and local government interests, etcetera.

The core of the State Land Master Plan is aimed at protecting Wilderness values. All of these lands, or virtually all of these lands, are protected by the forever wild clause of the State Constitution. There was no reason to create a State Land Master Plan unless at its central purpose was to provide much more protection than was afforded in a general sense under Article XIV.

The basic idea in protecting Wilderness was that in today’s life with modern conveniences that in Wilderness areas and near Wilderness areas people put aside those conveniences and move under their own power, move without motors, move without mechanized devices. The Master Plan comes down strongly in favor of allowing natural forces to undertake and pursue their own ends and for human beings to move in certain areas in traditional ways and using their own power.

Amendments to the State Land Master Plan are contemplated, and are appropriate, and the plan provides for amendments. The way the process is supposed to work is that there should be a full, honest deliberation by the multi-constituency Adirondack Park Agency, which then makes recommendations to the Governor. The Governor is authorized, and it’s entirely appropriate, to approve either the Agency’s recommendations or to disapprove those recommendations.

But this process which I just described is not what has happened over many months regarding the Essex Chain Lakes Complex, and the UMP [Unit Management Plan] that was adopted, or regarding these amendments to the State Land Master Plan. I’m not suggesting a different result might have occurred. I am saying that the process has not been a full open discussion by the Park Agency.

For many months, the Governor and the Governor’s staff have forced the Agency toward the result reached today. They have done so by rigidly controlling what analysis state agency staff was allowed to prepare and present to the Agency. They have rigidly controlled what materials Agency staff may prepare and present to the Agency. We have not had a full and open discussion on what in fact were all the issues reflecting the action that we have taken today.

That didn’t happen regarding DEC’s very flawed, in my opinion, UMP regarding the Essex Chain Complex or the EIS that it prepared. That has not happened regarding these amendments to the State Land Master Plan and the Supplemental EIS [Supplemental Environmental Impact Statement].

For example, for months it has been clear to members of this Agency, to a number of members, not all members, that the best way to accommodate public biking in the Essex Chain and Pine Lake Primitive Areas without doing violence to the Master Plan was to create a new land classification. A classification that would not allow motorized recreation but would permit public biking over miles of trails. Many many months ago I said I was willing to live with that possibility or with that conclusion. That would not do violence to the Master Plan because we would have a new classification and it wouldn’t pretend to be Wilderness and it wouldn’t pretend to be Primitive.

A number of members, including myself, requested an examination of those possibilities, but we have neither the EIS nor the materials presented to the Agency for discussion have ever formed out, fleshed out, dealt with in detail that possibility because the Governor and the Governor’s staff had not permitted the staff to undertake that work and present it to the Agency for its deliberations. This is not what the Agency Act envisioned when setting up the Park Agency. I’m not suggesting for a moment that a different result necessarily would have followed from the kind of discussion that I think the Park Agency Act demands.

As a result of what happened three very negative results have occurred and will continue to occur.

One is this action does seriously weaken the Master Plan’s protection of Wilderness because it mightily, significantly undermines the concept of Primitive Areas, which is one of the basic building blocks of protecting Wilderness in the Master Plan.

Two, this discussion has seriously weakened the statutory rule of the Park Agency as a forum in which there should be a full and open discussion of the issues facing the state regarding the management of state lands.

Thirdly, and perhaps in the long run most seriously, this is a precedent that suggests the possibility that this kind of rigidly controlled discussion may become the model for the future and that should not be the case. This is not what the people of the State of New York understand the Park Agency is supposed to be doing.

Until now, today, no Governor in this state has chosen to force the Park Agency to weaken the Master Plan. Governor Cuomo and his staff have chosen to do so and the people of the State of New York should understand that this is a significant weakening of the Master Plan. And that what has been done today can be done over and over again regarding any of the areas of the Master Plan not just Primitive areas.

The State Land Master Plan, at the bottom line, was adopted to make the state government honest about the way it’s going to manage the state lands and if it’s going to change those rules it needs to go through an open and complete public discussion of those possibilities. The State Land Master Plan amendment process therefore regarding major amendments, not the everyday normal amendments that we do each year, the major amendments, has to be repaired. Governor Cuomo has to lead that effort to repair it and he has a responsibility to do so.

I present these comments respectfully and I present them with as much force as I possibly can. Thank you.”

You can click here to watch the 12-minute presentation. Choose the Friday March 11, 2016 video and start at 1:37:25 to hear the whole statement.

Photo: APA meeting video screen grab.


Peter Bauer

Peter Bauer is the Executive Director of Protect the Adirondacks.

He has been working in various capacities on Adirondack Park environmental issues since the mid-1980s, including stints as the Executive Director of the Residents' Committee to Protect the Adirondacks and FUND for Lake George as well as on the staff of the Commission on the Adirondacks in the Twenty-First Century and Adirondack Life Magazine. He served as Chair of the Town of Lake George Zoning Board of Appeals and has served on numerous advisory boards for management of the Adirondack Park and Forest Preserve.

He lives in Blue Mountain Lake with his wife and two children and enjoys a wide variety of outdoor recreational activities throughout the Adirondacks.


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39 Responses

  1. Paul says:

    It must have taken some time to transcribe this from the video.

    How is it that he “forced” the agency to make the changes. He voted no others were able to vote no if they wanted to?

    Also, the best way to “accommodate” biking there was to give it a Wild Forest classification.

  2. Todd Eastman says:

    Thanks Peter.

  3. Bruce says:

    “There was no reason to create a State Land Master Plan unless at its central purpose was to provide much more protection than was afforded in a general sense under Article XIV.”

    And there was no need to give the APA amendment powers if the intent was to keep the SLMP exactly as originally written. Environmentalists keep falling back on the idea that the original language was intended to be engraved in stone, it clearly isn’t.

    • Paul says:

      They understand that it can and is amended. They just want it to be only amended in one direction. Instead of advocating for a more protective classification that required that it be amended they should have advocated for a WF classification. Wanna have it both ways – welcome to reality.

  4. Curt Austin says:

    Gosh, Mr. Booth sure can ramble. I think I’ve found the kernel of his complaint: “I am saying that the process has not been a full open discussion by the Park Agency.” I believe he is referring mostly to the omission of a choice to formulate a new land classification that would prohibit motor vehicles but allow bicycles.

    That would have been the most elegant approach in this and similar situations. But I sense that Mr. Booth may have favored it because such a profound proposal could not be so easily approved. He really doesn’t want bicycles in the Essex Chain, or anywhere.

    The “force” he refers to is the DEC’s choice to present only small-bore amendments to the SLMP instead, which were obviously more easily approved. He voted against them, others could have also; there was no “force” here, only a nudge.

    The people of New York State through the political process can allow bicycles or not. The decision is not so difficult to make – we’re just talking about a few bicycles on a few roads – but it must pass through a tortuous process. Naturally, some will blame the process for decisions made that they believe are clearly wrong. They might be right, but it doesn’t seem so black and white to me.

    Perhaps I’ve buried my complaint, too. The terms “indict” and “force” are so exaggerated that they sabotage rational discussion.

    • Bruce says:

      Curt,

      You’re right. If you look at the recent history of APA actions, starting with the rails and trails discussions, and look at activism in general, whenever decisions go against what a particularly vociferous special interest group or individual demands, they always say there hasn’t been enough public discussion. It’s a euphemism for, “if we keep discussing this, you might get tired of hearing our demands and give in to them.”

      Where I live, and it’s probably the only place in the country where interstate through traffic is shunted onto a busy city street, each time the DOT comes up with a plan for the connector, those in opposition to the plan (mostly the “not in my backyard” crowd) say, “there’s not been enough public discussion.” This has been going on unabated for 10 years, with little sign of any real action. Meanwhile, at 5 in the afternoon, I-26 through traffic in Asheville has to put up with rush-hour traffic and lights.

  5. Justin Farrell says:

    SLMP
    State Land Manipulation Plan

  6. Tim-Brunswick says:

    Gee whiz Peter….where’s the other views and comments that were obviously presented at this meeting?? Are we to believe that no-one else spoke,?, that there were no comments in favor of proceeding in the direction the plan is going (thankfully…)?

    There is always two sides to every story, so how come Peter Bauer only presents one side and it is always in synch. with his organization’s “Protect the Adirondacks” views………??

    Gimme a break….really!

  7. Bill says:

    I’m sorry but trying to read this many paragraphs in italics is painful. Is this really necessary?

    • Boreas says:

      Bill,

      If you have a newer browser, up toward the top in the address bar you may find a book icon or something similar. If you click on it, it will put any article into an easy-read format. In Firefox it is called ‘ReaderView”. I’m not sure about IE.

  8. Bill Ingersoll Bill Ingersoll says:

    Richard Booth is a hero of mine at the moment.

    Ms. Ulrich, not so much.

    I’ll take a guy who stands up for his ideals any day, over someone who is willing to sacrifice the SLMP (and a century’s worth of Adirondack Forest Preserve history) to save her favorable standing with the governor.

  9. Marco says:

    Thank you. Both to Pete for bringing this to our attention and to Richard Booth for making these statements.
    “The basic idea in protecting Wilderness was that in today’s life with modern conveniences that in Wilderness areas and near Wilderness areas people put aside those conveniences and move under their own power, move without motors, move without mechanized devices.”
    Yup.

  10. Paul says:

    It is not the APA or Mr. Booth’s charge to simply advocate for as much Wilderness type protections that can be afforded the public land in the park. It is their charge to find a balance that is best for the land and the people living and recreating in the park. If it were the former then their job would be easy.

    • joe says:

      You’re right Paul. People get very confused about the APA’s role, commissioner’s roles. staff roles, and so on.

      I would add that his complaint is about the amendment process. Perhaps amendments should happen more often so people get more practice at it. I don’t believe it was ever intended to be a dead document likes Scalia’s notion of a dead US Constitution. These things change, and they have to change, over time.

      But in any case the short story is the Commissioners get to vote regardless of the Governor’s wishes. They did and he lost badly, voting alone. And he gets to say his piece before, during and after the vote. Well that is the system at work. To change the SLMP you need the APAs approval and the Governor to sign it – that is all.

      In any case, this is about 9 miles of logging roads being opened to bikes. Hardly some kind of terrible failure, these seem like small entirely reasonable changes that suit the facts on the ground. This might be a fundraising opportunity for Protect and Wild but other than that it is a non-event. I certainly hope more people use the Essex Chain area – so far it is hardly used at all.

      • Boreas says:

        joe,

        The APA is supposed to study a situation thoroughly with their responsibilities to the Park being their guide, then they vote, then it goes to the governor for his approval. Booth and others feel this started with the governor who seems to have said ‘make it happen’, the commissioners foundered around to justify his wishes, then voted. The tail wagging the dog.

        I think Booth’s “indictment” is aimed at the governor above the table, but it is actually aimed at his fellow commissioners below the table for letting the governor dictate a plan of action which they accepted without much deliberation. Amendments should require a little more due process and be less politically charged.

        • Bruce says:

          “For many months, the Governor and the Governor’s staff have forced the Agency toward the result reached today. They have done so by rigidly controlling what analysis state agency staff was allowed to prepare and present to the Agency. They have rigidly controlled what materials Agency staff may prepare and present to the Agency. We have not had a full and open discussion on what in fact were all the issues reflecting the action that we have taken today.”

          It seems strange that all other members just quietly ignored this form of coercion, if indeed there really was any, and voted the way they did.

          • joe says:

            There was no coercion. The Governor stepped into the Essex Chain classification debates. He held meetings, reported on this site, with people from local government and some (not all) enviro advocacy groups. The elements of a compromise were talked out and apparently agreed to. Then it took some time to get the UMP done and get the SLMP aligned, although maybe these steps should have been done in reverse order. Seemed like they tried to max out wilderness while accommodating other uses. It wasn’t underhanded, it was they best they could figure out with all parties involved.

            This was all written about and much discussed. So this notion of an ‘indictment’ is absurd. It all unfolded with lots of participants involved. But Peter Bauer was not part of it (he was suing the State at the time) and I don’t think David Gibson was either (he was also suing the state). Adk Mtn Club and the Council were part of it, I think….

            I could be wrong, all I ‘know’ is what was reported in regional press and papers. At the time, people liked that the Governor was willing to step into this, figure out how to make it work for all sides. So all this chatter about rigid control and direction from Albany w/o regard for anyone’s opinion is bunk. I could add other words, but I’ll stop with that.

            And, yes, as someone comment, asking for more discussion, more debate, more research, is a well known route to simply exhausting the system till people give up. It’s called stalling. Do it long enough and the politician times out – see Obama and congress for the best current example of this model.

        • Paul says:

          This was thoroughly vetted and then vetted again.

          Why doesn’t someone include at least a shred of evidence to go along with the indictment?

          • Bruce says:

            Paul,

            Mr. Booth told a good tale, and that’s what lawyers do when they need to make the facts look like something other than what they are.

            Here’s a real life example: A friend was on a motorcycle and stopped at a light. Someone rolled into him from behind and the guy’s lawyer claimed my friend backed into him. Fortunately for the friend, the bent front forks proved his brakes were on when hit.

        • Paul says:

          Here is a sample of what was done.

          Here is 91 pages of work on this by the APA:

          http://apa.ny.gov/Mailing/2013/12/StateLand/SLMP-20131218-FSEIS-FINCH2013_200%20pm.pdf

          Here is another 235 pages:

          http://apa.ny.gov/Mailing/2013/12/StateLand/SLMP-20131218-FSEIS-FINCH2013_200%20pm.pdf

          etc.

          I think it was pretty thoroughly studied.

          • Bruce says:

            Paul,

            I read part of it, and didn’t know this has been going on since 2013. It doesn’t sound like any of this was ramrodded to me, as there was plenty of time to make objections known and discussed. I’m impressed by the detail.

            Looks a lot like our local interstate highway connector which was proposed 10 years ago, hashed and re-hashed several times since, and so far not one shovelful of dirt has been moved. It’s a handful of NIMBY’s (not in my back yard or neighborhood activists) who keep using the old ploy, “there’s not been enough public discussion.”

            I’m glad the APA finally voted, it’s time to move on, enough already.

  11. Charlie S says:

    Curt Austin says: “Gosh, Mr. Booth sure can ramble.”

    And so eloquently he does Curt and he makes sense and people like him are far and few and because of that the battle is ever so fierce in trying to protect what remains of the heritage that was bestowed upon us by brilliant people who saw the world beyond their graves.

    • Curt Austin says:

      That’s quite a rambling sentence, in which you’ve fit words the words “battle”, “fierce”, “heritage”, “bestowed” and even “graves”.

      The theme of my remarks here and elsewhere is that that there is no need for dramatics. What I see as I live and travel around the Adirondacks is about the same as I saw 60 years ago. I love it dearly. Looking more closely, I see that far more land is protected now. And unusually strong zoning has been implemented, attracting strong objections from all sides, as it should when operating properly.

      The major factor is that the harsh and remote environment tends to protect itself. Throughout Adirondack history, entrepreneurs have been punished severely for underestimating this harshness. Humans are the delicate objects here, not the wilderness. Black flies may have a greater role than the APA in maintaining the character of the Park.

      The dramatics disturb my inner peace. Save them for when something truly threatening is at hand. In the meantime, I might be OK with a quiet campaign against BT.

    • Bruce says:

      Charlie S,

      I’m sure he was as eloquent before the vote as after. Grousing after the vote is in is like saying a new President should not have been elected because of ya-da, ya-da, ya-da. After the vote, it’s time to support whatever happened in whatever way you can, or get out of the way.

  12. Charlie S says:

    If you click on it, it will put any article into an easy-read format. In Firefox it is called ‘ReaderView”.

    In Newspaper establishments it’s called ‘The Troy Record.’

  13. Charlie S says:

    Bill Ingersoll says: “Richard Booth is a hero of mine at the moment….
    Ms. Ulrich, not so much.
    I’ll take a guy who stands up for his ideals any day, over someone who is willing to sacrifice the SLMP (and a century’s worth of Adirondack Forest Preserve history) to save her favorable standing with the governor.

    I’m with you Bill…I’m always for the one who seems to have his or head screwed on right.

  14. Charlie S says:

    “The basic idea in protecting Wilderness was that in today’s life with modern conveniences that in Wilderness areas and near Wilderness areas people put aside those conveniences and move under their own power, move without motors, move without mechanized devices. The Master Plan comes down strongly in favor of allowing natural forces to undertake and pursue their own ends and for human beings to move in certain areas in traditional ways and using their own power.” Richard Booth

    Less and less is this in us – this urge to utilize self ambulation. More and more there are going to be struggles to protect what remains of wilderness in this country,in the world…..because each new generation is born under the influence of machinelike conditions.

  15. Charlie S says:

    Joe says: ” he gets to say his piece before, during and after the vote. Well that is the system at work. To change the SLMP you need the APAs approval and the Governor to sign it – that is all.”

    ” ..this is a precedent that suggests the possibility that this kind of rigidly controlled discussion may become the model for the future…” Richard Booth

    According to Richard you’re wrong Joe…it is not all,there’s more. It’s often that way,there’s often fluff thrown in with the mix to hopefully be overlooked by the more gullible of the race.

  16. Charlie S says:

    “I’m with you Bill…I’m always for the one who seems to have his or head screwed on right. ”

    ,,his or her head screwed on right.

  17. ADKerDon says:

    What a bunch of garbage from Booth. No wonder all his students slept through his classes. One voice out of eleven, and that voice a known discriminator. A person with total hatred of the Adirondacks, its people, and all outdoor recreation. The Adirondacks will best be served by his removal from the APA and from NYS. Although 10 members were intelligent enough to encourage some outdoor recreation, they did not go far enough. All these lands must be open to all people. End the discrimination of Booth and those like him. Abolish the forest preserve, manage it for wildlife habitat and all types of outdoor recreation – for all types of users. Directly elect all 11 members of the APA Board.

  18. Vincent Moore says:

    As a former Executive Director of the APA, I strongly support the position of Richard Booth and applaud his fearless courage in speaking out against this unnecessary weakening of the State Land Master Plan.

  19. Marco says:

    ADKerDon, again, I disagree. Discrimination is not the topic. He is not against the ADKs, nor it’s people nor outdoor recreation…again not the topic. I hardly believe that removing him from NYS is even productive to this discussion. A vote is a vote, and as far as his public comments as a person go, he has the right to speak about anything…he didn’t, he talked about what he knew about. Pete reported it as such. Professor Booth was simply saying the governor requested some reports and selected ones were passed to the appointed people. He did not agree with the vote. He did not mention ever abolishing the forest preserve, where do you get this…way off topic. And, I am sure the voters will appreciate the extra 11 candidates for researching their candidacy, and, the extra ballots available on their voting boxes (IFF you can get them to vote AND not follow a party line.) I do not appreciate spending this time with your lack of foresight and antipathological rhetoric. BTW, ALL citizens can visit the ADK’s. I fail to see how this is discriminatory. I like to bike too, but I wouldn’t attempt to try it in the Saranac 6 or the 46 Peaks.

  20. Paul says:

    God forbid that we have a Governor who is occasionally interested in something going on in upstate NY.

  21. John Frey says:

    If the SLMP is broken and can not be fixed to every ones liking. Who am I kidding “every ones liking” that will never happen. Then we need to make it perfectly clear – No more land is to be purchased by the State until permanent easements are put in place by the current land owners that will allow for reasonable use and recreation by all, not by the few. Narrow use groups have held sway for too long and now they are very upset because others have found their voice. The forest and park is thriving. The lands recently replaced into “Manufactured Wilderness” as well as those adjacent are not in wholesale danger of being overrun/overused. I agree with Mr. Booth the process is broken and there is no easy fix. I also agree with the others that have said it may have been odd that there was little screaming when the broken system was fine with more restrictive. So time out, take a step sideways, slow down the classifications and stop the purchases until the hand off of land is clear. This Governor made promises to surrounding Towns that the resulting purchases would have recreational uses allowed on …..old log roads…… bridges that were already in place.

    Enough whining already

    • Boreas says:

      I agree, the damage has been done and a new precedent has been set WRT state land classification, process changes, and amendment adoption. Why keep whining? Now we can just sit back and enjoy the show!

  22. Larry Roth says:

    The key point here is not just about whether or not the laws that protect the Adirondack Park are being respected, or whether the actions approved by the APA are actually the best use of the Park.

    The key point is that the process is being corrupted to produce the answers the Governor wants – not the answers that reflect ALL of the facts and make an honest attempt to reconcile conflicting interests in a fair way. The only difference between this and a dictator ruling by fiat is that it’s being done in the background, behind closed doors where the public cannot see.

    A careful reading of the amendment to the travel corridor UMP shows the same things Booth is complaining about in the Essex region decision. There are relevant facts that are completely omitted, assertions made with little to support them, things glossed over that are going to prove to be booby traps down the road.

    It’s clear both the process and the amendment Alt 7 resulting from it were designed to produce the ‘compromise’ instead of being an honest assessment of the best use of the corridor. Even the people who support it are going to find some nasty surprises – but they won’t be surprises to the ones who dictated it to DEC, DOT, and the APA.

    • David P. Lubic says:

      And those surprises won’t be surprises to the people who read things and analyze things correctly, and can see that a lot of signs of sloppy research, which may well be deliberate to get the results wanted.

      • Boreas says:

        David,

        True. Garbage in = garbage out.

        Are any of these amendments ever done on a ‘trial’ basis – as in we’ll test it this way for 5 years, see what happens, then revisit the idea 5 years down the road and decide if we want to finalize the amendment or alter it somewhat?

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