Tuesday, December 1, 2015

DEC’s Responses To Essex Chain Plan Comments

Polaris Bridge and the Upper Hudson (courtesy Protect the Adirodnacks)At its November meeting, the Adirondack Park Agency voted 8-2 to approve a controversial management plan for the Essex Chain Lakes Complex, finding that it conforms to the Adirondack Park State Land Master Plan.

Some observers contend that the plan violates both the State Land Master Plan and the state Wild, Scenic and Recreational Rivers Act. Three major issues are:

  • Retention of the Polaris Bridge over the Hudson River for use by snowmobiles.
  • Construction of a new bridge over the Cedar River.
  • Allowing bicycles in the Essex Chain Lakes Primitive Area.

But that’s just the tip of the iceberg. Environmental advocates, sportsmen, and members of the general public have raised many more issues, such as the appropriateness of creating a new snowmobile trail between Indian Lake and Newcomb, the appropriateness of allowing floatplanes to land on certain lakes, and whether historical buildings should be preserved or torn down.

The state Department of Environmental held three public hearings in July and received additional comments in writing. Below is a summary of the comments received and the department’s responses. Be warned that the summary is very long.


 COMMENT: DEC must also schedule hearings on this issue outside of the Adirondack Park. The Adirondack Park belongs to (and is paid for) by all New York citizens yet DEC rarely if ever holds hearings on this incredibly important resource anywhere outside the park’s boundary.

RESPONSE: An additional public hearing was held in Albany at DEC headquarters at 625 Broadway on July 22, 2015.

COMMENT: While my greatest love of the Adirondacks is based around the motor‐less wilderness and primitive area experience, I applaud, respect, and welcome the DEC choice to apply balance with the unit designations for the newly acquired lands near Newcomb. Since the Master Plan was written, I’ve witnessed a disproportional amount of land acquisitions assigned as wilderness. While I applauded this trend years ago, I now believe this practice has become grossly unbalanced at the expense of local public support. As an environmentalist, I believe there is no environmental benefit to managing the forest area in a way that alienates so much of the public against every environmental initiative, law and policy. Designating all newly purchased land as wilderness with no balance does exactly that. Allowing such a small percentage to be wild forest goes a long way for defusing those who might spend their lives fighting other worthy environmental initiatives. In other words, ideology on one end of a political view spawns the same at the other extreme. As a society, we need balance or we’ll never cooperate effectively for the benefit of the environment.


COMMENT: Please add to this draft a proposal to allow ATV access on designated access roads for the purpose of camping, fishing and hunting. The local area can gain a great deal of tourist dollars and visitors by allowing registered and insured ATV’s into this area. Please consider this as a way to boost dollars into this area. As a multi parcel land owner I feel not addressing this is a big miss on the state of New York and the DEC groups who oversee this land. There should be equal use of the land for all tax payers, not just hikers who pay no fees to use this land. Please look at states like Pennsylvania and Maine and see what they are doing with ATV use to bring in dollars to the local economy.

RESPONSE: DEC has considered this comment and declines to make this revision. ATVs are not proposed as an allowed use in this Complex Plan, nor are they a conforming use in Primitive Areas. The public may use motor vehicles to access the Wild Forest tent sites along the Cornell Road, Deer Pond Road, and seasonally along the Camp Six Road and Chain Lakes Road (South). Additionally, hunting and fishing access is allowed along those same road segments.

COMMENT: Opposes allowing all‐terrain vehicles on any multi‐use trails in the Complex. Any multi‐use trail that includes snowmobile use must remain otherwise motor‐free, and not include any possible future use of any other off‐road motor vehicles.

RESPONSE: Aside from snowmobiles, no other public motorized uses are proposed for the multipleuse trails identified in this Complex Plan.

COMMENT: In regard to wheeled transit: bicycles yes, ATV’s a strong NO.

RESPONSE: ATVs use is not proposed in this Complex Plan.

COMMENT: Support for the DEC managing several Forest Preserve units as a complex, as they have long‐advocated for this complex‐planning approach.

RESPONSE: This Complex Plan takes a more “complex” approach to planning in order to identify where proposals continue beyond unit boundaries.

COMMENT: I commend the planners for the comprehensive nature of the plan and their outstanding effort to provide public access to this beautiful area while preserving its integrity.


COMMENT: As a senior citizen hunter and fisherman I would like to see as much access as possible to this land. For too long the environmentalists have succeeded in getting the overwhelming majority of land locked up for the benefit of the fit few. In my opinion it is wrong to preclude the less fit and disabled from the ability to enjoy this land. This means making available the existing access roads on the land. The Finch lands include an extensive road and bridge network that could be utilized for recreation access. Notably the Polaris Bridge being targeted by the environmentalists should be left intact and maintained for access by the public and DEC. There needs to be a way to make this happen. Furthermore snowmobiling, bicycling and even RV traffic should be allowed on these well‐constructed haul toads which were built to withstand log truck traffic for many years. The time has come to stop the environmental lobby before the whole park is off limits to almost everyone.


COMMENT: As an organizer of Lean2Rescue projects, the commenter notes that they have learned to see such infrastructure as is proposed as a huge cost saver and carbon footprint reducer for maintenance of the interior, especially the Wilderness areas. There have been several incidents where they have been able to have materials carried by groomer to the edge of the wilderness area, where volunteers have then been able to drag the materials the final miles to the site. This avoids the need for a helicopter which processes so much more fossil fuel per hour as compared to the groomer or snowmobile.


COMMENT: The campfire ban should not be implemented. The carries to reach the Chain Lakes make for a very effective filter, generally removing those less motivated individuals that have a tendency to be irresponsible campers. Those likely to visit the Chain Lakes can certainly be trusted to observe the “dead and down” firewood regulations.

RESPONSE: DEC believes that the documented ecological impacts of fires in other areas of the Forest Preserve lend themselves to the prohibition of fires at waterfront sites in the Complex Area.

COMMENT: An advance campsite reservation system will be very cumbersome and limiting in nature. The designated campsites should be first come first served, as all other backcountry sites are. Exclusive set aside campsites for floatplane customers should not be implemented. Again, all designates sites should be first come first served, set aside campsites exclusively for floatplane customers on public land, is illegal. Are these specific campsites on State land or not? If so, they should be open to all. If not, revise the plan and collect taxes from the floatplane operators.

RESPONSE: The need for the camping permit system will be assessed after the 2018 camping season. If the five years of permit data do not justify a permit system, it will be discontinued, and the sites will become first come, first served.

COMMENT: Increase the number of campsites on the Chain Lakes Road (South), and include ADA sites.

RESPONSE: Accessible roadside camping opportunities will be provided along the Chain Lakes Road (South).

COMMENT: More should be done to protect against invasives, especially against aquatic invasives.

RESPONSE: DEC will support scientific research, work with our partners, provide educational information, and enforce existing policies that protect Forest Preserve vegetation.

Bicycle and Horse Trails

COMMENT: With regard to the use of bicycles on the roads around the Essex Chain, although I am happy to see riding opportunities for bicycles in the Essex Chain Lakes Management Complex, these routes must be legitimately designated as DEC administrative roads before allowing bicycle use of these roads.

RESPONSE: The Department’s proposal is to identify bicycling opportunities on former allseason roads in the Essex Chain Lakes and Pine Lake Primitive Areas, and manage such use in conformance with the APSLMP. On Wild Forest lands within the Complex Area, the Department proposes to designate for bicycle use a portion of the Chain Lakes Roads (North), Chain Lakes Road (South), Deer Pond Road, and Drake’s Mill Road to the Iron (Polaris) Bridge.

COMMENT: The comment was made that the justification for the designation of administrative roads should be provided. It appears that the Department decided where it wanted the bike trails and then designated these as administrative roads.

RESPONSE: See Response above.

COMMENT: Plans for mountain bike use on roads in the Essex Chain Lakes Primitive area should be based on natural resource and market studies to determine feasibility, public interest, maintenance costs, and natural resource damage. There is no evidence that mountain biking is desirable on former logging roads anywhere else in the Forest Preserve.

RESPONSE: In the Stewardship Plan, the DEC designated certain former woods roads open for bicycling. Based on feedback from users of these trails, The Complex Plan proposes to identify bicycling opportunities on former allseason roads in the Essex Chain Lakes and Pine Lake Primitive Areas, in conformance with the APSLM In addition, the Plan calls for a continued assessment of both bike and horse trail use and experiences. This assessment will be conducted in a variety of ways, and will allow DEC to better understand use, potential problems and public desires. The DEC, in consultation with APA, will assess the condition of nonmotorized recreational trails used by equestrians and bicyclists to measure the impact these activities have on natural resources. It is understood that the public desires to have “family style” bicycling experiences throughout the Essex Chain Lakes Management Complex Area. There are many factors, that when combined, result in an overall user experience. The assessment called for in this Complex Plan will attempt to measure these factors in a way that captures the overall public use as well as more subjective measurements. These subjective measurements will deal with: aspects of the trails that users find enjoyable or memorable and describe positive or negative interactions. Methods used to conduct this assessment will utilize DEC staff, including SCA Backcountry Stewards, Forest Rangers, and Foresters, as well as DEC partners, including Towns, volunteers, colleges, and contractors. The assessment will likely provide use estimates through a combination of trail registers, trail counters, and observation. The assessment will also involve interviews with users in an attempt to capture more “experience” based information, to define what is important to individual users of the area.

COMMENT: I particularly support the use of the existing road network for bicycles.


COMMENT: The Adirondack Council supports allowing mountain biking and equestrian use in certain areas of the Complex.


COMMENT: I am opposed to allowing mountain biking on trails frequented by hikers as they are dangerous to pedestrians and destructive to trails.

RESPONSE: DEC has considered this comment and has specifically included sections on “trail etiquette” to remind users that these are shared use trails.

COMMENT: I support the use of the roads in the area for horse trail riding.


COMMENT: I have skied and mountain biked the Upper Hudson Ski Loop for over 25 years. It is a great wonderful area and the path was built to support logging trucks. I have no idea why bikes were excluded from this area in the proposed plan. Perhaps there is an excellent reason, but none was offered at the meeting nor was there an opportunity to ask questions at the hearing. Newcomb could provide that same opportunity if one could ride the trail from the Upper Hudson Ski Loop down to Ord Falls and into Town on existing trails or on newly created trails being considered to extend the Upper Hudson Ski Loop into Town.

RESPONSE: The Upper Hudson Ski Loop crosses private land (working forest conservation easement land) between the parking and the register box location. DEC has proposed to open the Ski Loop (located on Blue Mountain Wild Forest land) for bicycling, and try to gain approval from the private landowner for the crossing.

Cedar River Bridge

COMMENT: I firmly support the proposed bridge over the Cedar River at the recommended site.


COMMENT: The Adirondack Council supports the building of a replacement bridge over the Cedar River for hiking, mountain biking, snowmobiling, and equestrian traffic, but not for any other motorized use. This bridge must be legally and irrevocably closed to any motorized use other than snowmobiles.


COMMENT: I support DEC’s plan to build the Cedar River Bridge and to maintain the Polaris Bridge in the Essex Chain Lakes Complex.


COMMENT: I strongly support a Cedar River Bridge as described in Alternative 4.


Economic Development and Enjoyment of the Outdoor Experience

COMMENT: I attended last night’s meeting at the Newcomb school. As a former part time resident on the Goodnow Flow for more than 30 years, and now a full time resident for the past 8 days, I want to express my appreciation for the thoughtful balance your recommended plan achieves. One of the most troubling aspects of home ownership in the park is the continuing decline of many of the hamlets in our area including Newcomb, Long Lake, Blue Mountain Lake, North Hudson, Minerva, Indian Lake, etc. The proposed plan addresses requirement to provide wilderness experience while also recognizing the importance of economic development in the affected communities. I firmly support proposed snowmobile trail that crosses the Hudson on the Polaris Bridge and continues up the east side of the Hudson to Newcomb, where it will join the Newcomb to Minerva trail. I also firmly support the proposed bridge over the Cedar River at the recommended site.


COMMENT: The Nature Conservancy / Finch Pruyn lands represent a very special collection of unique outdoors opportunities on land that was previously an important economic engine for these communities. The proposed horse trails, mountain bike trails and limited vehicular traffic are certainly appropriate for this area. All of those activities together represent a mere fraction of the disturbance caused by chain saws, skidders, chippers and logging trucks. In the 30 years on the Goodnow, we had several summers with the wakeup call of logging trucks rattling down the Goodnow Flow Road at 5:00 am to get their first load of the morning. I won’t miss that particular aspect of the logging operations, but am a strong supporter of town’s effort to be a place where the children of town residents will have a viable place to live, work and raise a family.


COMMENT: Mountain bikes, horses, snowmobiles, airplanes and other motorized vehicles should all have a place in the park. Many hunters, fisherman, and outdoor folks are older and need to use these areas that allow wheeled access. The local economy relies on all types of outdoor recreation and the park is large enough to allow everyone with any interest in the outdoors to enjoy it. If people of all interests don’t enjoy the area and learn first‐hand of its beauty and importance of open space, it will die a slow death of disinterest and neglect with future generations.


COMMENT: I write to express my support for the overall Complex plan. The plan should support the efforts and the desire of the five surrounding towns to become a “Recreational Hub.” I also believe that the Polaris Bridge should stay in place and serve multi‐trail interests in the Complex. I also strongly support Alternative 1B for a snowmobile trail that will connect Indian Lake to Minerva and a Cedar River Bridge as described in Alternative 4.


COMMENT: I am very excited about the progress that has been made as a lifelong resident of the greater Adirondack region. The economic benefit to our area from the snowmobile industry alone has been proven by the research at our neighboring institution, the State University of Potsdam, in Potsdam, NY.


COMMENT: The only business that could profit from a major connector in Minerva is Sporty’s Iron Duke Saloon until they get to Newcomb. There is no gas, restaurant, bar, rest room, mechanical or first aid help for 25 miles through the forest.


COMMENT: I’ve been snowmobiling for 25 years in the Old Forge area and travel to Indian Lake and have used the Newcomb trail. It opens new areas to see and we do not have to return the same way from Old Forge to Indian Lake. I know I speak for all of my snowmobile friends in supporting the trail and all bridges concerned. By keeping this trail open it will boost the economy in the entire area. Snowmobiling has tripled in my tenure in Old Forge and this recreational sport helps the town make it through the winter. By keeping this trail open and removing the tracks from Old Forge to Tupper Lake would make the entire area from Old Forge to Indian Lake to Newcomb and loop to Tupper Lake and back to Old Forge possible and boost the winter economy in these northern towns.


COMMENT: I recognize the economic value of having a community connector snowmobile trail network in this area, and support those efforts.


COMMENT: I understand the importance of stimulating the economy within communities of the Adirondack Park, so I support the proposed community connector snowmobile trail network. And that should also include the Vanderwhacker Wild Forest Area. Please don’t listen to the misguided people who think this plan will destroy the area.


COMMENT: To who it my concern, as outdoors enthusiasts and snowmobilers since 1973, my wife and I are all for the upgrades to the area. The upgrade should help generate more revenue for the area from hunters, fishermen, skiers, campers, snowmobilers, etc. New York State and or government have taken so much from locals already that hundreds have packed and moved out of state. Keep promoting the importance of the outdoors experience because it is relaxing for people after a hard week at work, and will also give children an opportunity to be outside instead of behind a computer.


COMMENT: Support the comprehensive Essex Chain of Lakes Plan as proposed. Specifically, they are strongly supportive of the provisions in the plan pertaining to snowmobile trails. They note that in New York State alone, snowmobilers spend over $1 billion on snowmobiling each year. This includes expenditures on equipment, clothing, accessories, vacations, gas, food, etc. Surveys show that snowmobiling families go on 27 snowmobile outings on average each winter. Snowmobiling is responsible for significant economic benefits such as: jobs for thousands of people, jobs which enable those people to further stimulate the economy through additional expenditures on goods and services, jobs which provide significant income tax revenues to state and federal treasuries and dramatically reduce unemployment and welfare payments; millions of dollars in tax revenues derived from snowmobile‐related businesses including manufacturers, suppliers, distributors, resort and hotel facilities, restaurants, service stations, insurance agencies, hardware stores, banks and credit unions; millions of dollars in winter tourism spending which support upstate economics, and; thousands of dollars in local/state sales and gas tax revenues. ARCC states that snowmobiling has rejuvenated the economies of many communities and is an important segment of the active outdoor recreation economic engine in Upstate NY. The New York State Snowmobile Association, in cooperation with SUNY Potsdam, conducted an economic impact analysis in 2003 showing the economic impact of snowmobiling in New York State to be estimated at $476.2 million. In 2008 the state of New York surveyed snowmobilers in New York and calculated the economic impact of snowmobiling in New York had increased to $875 million annually – an increase of 84% in 5 years. ARCC notes that on a local level, many businesses have reported a significant increase in business during the 2014 snowmobile season. Restaurants, taverns and hotel/motels have reported that their business increased two‐fold over the 2012‐13 season. The NYS Department of tourism actively promotes snowmobile tourism and has established a website with information on snowmobiling opportunities and conditions. ARCC states that the comprehensive proposals in the ECLMC Plan will play a significant role in the increase in economic activities in the region, and that without the ability to connect people – whether hiking, biking, snowmobiling or by motor vehicle – to the recreational opportunities and businesses in the respective counties, businesses would realize a measureable decline in sales with a corresponding increase in unemployment. Businesses need the support of all sectors, including government. Approval of the ECLMC Plan will insure the businesses will remain strong and provide employment and tax revenues for the region.


Goodnow Flow

COMMENT: From the perspective of the Goodnow Flow Association, Inc., the commenter notes that for over 60 years the Association leased much of the land in the northern section of the purchase. For the past ten or so years, they have been involved in an effort to rebuild the spillway to protect and preserve the Goodnow Flow along with the surrounding areas and wildlife habitat that depend on it. The Association is close to being able to commence this project and hopes to complete the replacement of the spillway during the summer months within the next couple of years. The Association hopes that the area proposed for the hiking parking lot can be used as a summer construction season staging area so that the spillway can be replaced.

RESPONSE: DEC will contact and work with the Goodnow Flow Association during the spillway construction.

Outer Gooley Farmhouse and Inner Gooley Buildings

COMMENT: The buildings at the former Outer Gooley Club should be removed.

RESPONSE: The Complex Plan calls for further consideration of potential uses of the Outer Gooley Club building.

COMMENT: The Outer Gooley Club buildings should remain. The Inner Gooley Club buildings should also remain, like Santanoni, for use in emergencies and for interpretive opportunities. Information for displays and related websites should be developed to appeal to younger users.

RESPONSE: DEC agrees that the Outer Gooley Club buildings warrant further consideration for use as an administrative building, an interpretative center, or possibly a historical landmark. DEC disagrees with the commenter in regard to the Inner Gooley Club structures and buildings. The Plan calls for the removal of these facilities at the end of the lease arrangements with the Gooley Club. DEC recognizes that historic preservation and the provision of wild recreational lands are both matters of state policy. In the case of the Inner Gooley Club buildings, these public values are directly in conflict with one another. In this case, it was DEC’s judgement that the value of recreational lands outweigh the value of preserving the historic buildings. The Plan calls for the removal of these facilities at the end of the lease arrangements with the Gooley Club.

COMMENT: Supports the plan to retain the farmhouse as an historic structure and other compatible uses. However, AARCH asks the Department to acknowledge that the Inner Gooley Club buildings have also been deemed to be eligible for listing under the National and State Registers of Historic Places and provides the listing reference #13PRO4428 dated 9/25/13. The Department needs to acknowledge that this complex of seven buildings is National Register eligible, that it has obligations under the State Historic Preservation Act (SHPA), and it must explore alternatives to the proposed demolition of the Inner Gooley Club buildings. The 2012 “Reservation of Leasehold Estate and Management Agreement” calling for the demolition of the buildings doesn’t negate the Department’s legal obligations under the SHPA.

RESPONSE: DEC has complied with the State Historic Preservation Act in its determination to remove the Inner Gooley Club buildings. See Appendix G which contains the record of correspondence with the Office of Parks, Recreation and Historic Preservation on SHPA compliance matters.

COMMENT: With regard to the Outer Gooley Club buildings, the Environmental Conservation Law currently would not allow these structures to remain. They can stay only if the state purchased it prior to the enactment date of the law. The structures should be removed or relocated.

RESPONSE: DEC has considered this comment and determined not to make a change the Complex Plan.

COMMENT: It is our belief that this would constitute a crime against the history of the Town of Minerva and the Adirondacks in general. The Gooley Club, incorporated in 1946, has been one of the largest and most prestigious Adirondack Sportsman’s Clubs for many decades, truly an iconic landmark within the Blue Line. The Gooley Club has hosted several generations of sportsmen including many prominent New Yorkers, as well as being an important part of the logging history with Finch, Pruyn & Co. in the Adirondacks. The buildings that make up the Chain Lakes Camp are an ingrained component of Adirondack architectural heritage. We urge you to follow the legal obligations regarding the identification and protection of historic resources required by NYS Environmental Conservation Law (ECL 9‐0109) to evaluate these facilities as to their historic importance. As is presently being arranged for the Gooley Farmhouse south of the Hudson River, the Chain Lakes Camp can provide an ideal location for interpretive use as well as a sub‐station for DEC management of the Complex and a point of refuge for users in distress.

RESPONSE: DEC has considered this comment and declines to make this revision.

Management of the Complex Area

COMMENT: The principal management objective for the Essex Chain Lakes area should be forest restoration and natural resource preservation. Retention of roads for recreational use will undermine these objectives.

RESPONSE: The Complex Plan was prepared by the State of New York to allow for appropriate public access to the lands within the complex area and to protect natural resources. The proposed management actions were chosen because they seek to allow access while protecting the area’s natural resources, and will be implemented through a series of protecting measures and administrative and management practices.

 COMMENT: ECLMC should have been classified as Wild Forest. The patchwork of classifications is problematic and doesn’t satisfy any of the stakeholders and leaves the process legally vulnerable.

RESPONSE: After careful consideration of all viable and possible alternatives, and involving major stakeholders through various forms of outreach efforts, the State has determined that the current classification best represents a management plan that provides for reasonable public access while protecting the natural resources of the Complex Area.

COMMENT: I support the Department of Environmental Conservation’s plan to manage multiple and adjoining Adirondack Forest Preserve area as one “complex” unit. Managing the area in this way will allow better integration with natural resource protection, community engagement, and recreation.

RESPONSE: DEC agrees with this comment.

COMMENT: The Forest Preserve is replete with former land uses long made illegal under the Constitution and statutory and executive law. DEC commonly asserts that when land becomes Forest Preserve, the State buys all fee simple rights and extinguishes all prior underlying rights of ownership ‐ absent a reserved and deeded right. There are no reserved, deeded rights in this case. Yet, DEC illogically argues here for “grandfathered” rights.

RESPONSE: Lands purchased by the State within its geographical and political boundaries are managed by the DEC and the APA for the benefit of the people of the State of New York. Unless encumbered by a reserved right, the State can exercise its discretion to determine how best to manage the property while seeking a balance between protecting the natural resources of the area, and allowing reasonable public access. “’Grandfathered’ rights” is a term ordinarily associated with land use law, but the language that appears in the Wild, Scenic and Recreational Rivers System Act is whether existing land uses are allowed to continue without expanding or altering the historical use. DEC has determined that current law and regulation allow the continued use of certain structures and improvements located in the Complex Area.

COMMENT: The “Schedule of Implementation” provides a column for ‘Estimated Cost’ [page 61 et seq.], but no estimated cost is provided, not to mention the source of funds. Purchase of a snow groomer tractor can reach $150,000 not including the attachments, maintenance, and operating expenses. Whence cometh the funds for this? (Please do not cite the NYS Snowmobiles Trails Grant‐in‐Aid program without specifically listing the amount allocated to the Adirondack region, the manner of allocation, and other pertinent information). We are asked to buy a pig‐in‐a‐poke. “Approve this. We will bill you for the costs later. After all you approved this. Nonsense. Provide the costs, real estimates: best case and worst case.

RESPONSE: The DEC is not always able to provide estimated costs for specific activities listed in the schedule of implementation because it is sometimes difficult for DEC to project costs without completed design plans, and costs are susceptible to changing economic conditions.

COMMENT: DEC should undertake feasibility, public interest, maintenance cost and natural resource damage studies for your proposed roads in the Essex Chain Lakes Primitive area.

RESPONSE: DEC undertakes a thorough analysis of all available resources when determining the use of existing roads and the construction of new roads or trails.

COMMENT: I would like to submit that I am a frequent tourist to the Adirondack Park from CT. I also visit VT and NH, but find the wilderness quality of the Adirondacks a better “deal” for my tourist, and eventually 2nd home dollars. I spend about $10,000 a year on family vacations to the Adirondacks because it’s “forever wild” clause. I hike, camp, canoe and ski. I do not snowmobile nor mountain bike, which I feel should be severely restricted and not expanded because they ruin the isolated, nonmechanical aspect that I feel so appealing. Please do not allow more snowmobile and mountain bike access or improved trails in the park.


COMMENT: In regards to the Essex Chain Snowmobile plan, I am writing to encourage keeping the proposed plan that the Department of Environmental Conservation released last month. These lands should be “used” by the public. I agree with Governor Cuomo’s desire to make the Adirondacks more accessible.

RESPONSE: Many of the previous determinations regarding snowmobile trails have remained the same

COMMENT: Last week there were news stories about the average age of the population in the US. Hamilton County, with an average age of 54, is one of the oldest counties in the United States! (New York State was about 33 years old). This area needs more flexibility to live. New York cannot afford to keep the Adirondacks pristine without local support. If that local support evaporates simply because there is no population, we may have wild lands, but what are we saving it for?

RESPONSE: DEC believes that this Complex Plan strikes the appropriate balance between recreational access and resource preservation.

COMMENT: While the description and inventory of fish, wildlife and habitats in this UMP is significantly improved over last year’s draft, this UMP still lacks the requisite analysis and assessment required under the SLMP. The majority of priority recommendations are generally stated, as in “monitor and inventory wildlife populations and their habitats.” For an area noted for its ecological importance, including highly rated and vulnerable wetlands, and with populations of breeding birds, amphibians, mammals and plants vulnerable to this higher intensity of human presence and uses, this UMP should recommend particularly needed or important wildlife studies , how these will be conducted and by whom, and any management implications.

RESPONSE: DEC believes they have complied with the APSLMP with regard to an assessment of existing fish, wildlife and habitat within the complex area, and further analysis will be conducted when necessary.

COMMENT: This Draft UMP does not comply with the SLMP. DEC should re‐write this UMP to forthrightly address and comply with all existing law, regulation, policy and guidance documents. We encourage DEC and APA to form a citizen advisory committee or stakeholder task force that brings the agencies together with the five towns, recreational interests and Forest Preserve advocates together to discuss the legal obstacles, alternative management recommendations, and other constructive forward steps to achieving SLMP compliance.

RESPONSE: DEC believes the proposed management objectives and action steps comply with the APSLMP, existing law, regulation, policy and guidance documents. DEC and APA participated in numerous outreach sessions to stakeholder groups, and the Forest Preserve Advisory Committee was another forum that allowed the exchange of information on the Complex Plan.

COMMENT: The area is classified Primitive regardless of the existing road infrastructure.

RESPONSE: This Complex Plan addresses management objectives in lands classified as primitive and wild forest.

COMMENT: The priority for management of the property should be to protect natural resources and the secondary consideration is the recreational use. There is no grandfathering provision to allow continued use of the roads and abridges. Activity on the land while under private ownership does not mean the uses can continue now that it is public land.

RESPONSE: Current law and regulations specifically allow existing land uses to continue within designated river areas notwithstanding any laws or regulations to the contrary. DEC and the Agency retain the discretion to determine management actions that are the most appropriate to balance public access and natural resource protection.

COMMENT: The current Draft UMP should be withdrawn and all stakeholders should be consulted to come up with a new management plan together. Most of the Park is already located within one to two miles of main roads and people should not be able to drive up to the 4th and 5th Lakes area. Historically, the Indians allowed all tribes to access the wild lands of the Adirondacks with the basic understanding that the wilderness was to be preserved and protected. The process to determine their use should be public.

RESPONSE: DEC does not intend to withdraw the UMP, and will instead present the Complex Plan to the APA to seek a conformance determination consistent with the process set forth in the Memorandum of Understanding between the Adirondack Park Agency and the Department of Environmental Conservation Concerning Implementation of the State Land Master Plan for the Adirondack Park. With regard to the commenter’s reference to historical Indian practice, traditional Indian Nation concepts such as “one bowl, one spoon” did not recognize political boundaries of land, therefore their use of land is inapposite to the discussion of how the state manages the land of the Complex Area.

COMMENT: Comment was made that the towns and communities understood at the time of the discussion of the land purchase that there would be opportunities for those who like quiet paddling areas and those who like to snowmobile and mountain bike and hunt and fish. These uses can all be accommodated without the need for extensive work by using the existing road infrastructure. The communities want to believe that there is an opportunity for economic benefit from tangible public recreational opportunities from the land purchase that will help to make the communities more economically sustainable. The road network on the site should be used to increase access to the Forest Preserve for the public so they can learn about and appreciate the Forest Preserve.

RESPONSE: The Complex Plan does not propose public access to the entire existing road network, but rather in the interest of seeking a balance between access and the protection of the Complex Area’s natural resources, an overwhelming percentage of the existing roads will not be utilized for recreation.

Motorized Use

Comment: The commenter says the existing roads on the property should be allowed to be used by sportsmen who hunt, fish and trap. These roads have been used for 150 years without damage to the environment and should continue to be used. When the land was being purchased it was said that a parking area for the public, not just CP3, would be constructed near the tube to allow for access. Also, DEC says they will monitor use and could close the parking lot that is proposed for the public and he is concerned if the area is not marketed well, use numbers will be low and the lot will be closed. The ECLMC has 50 miles of road and should not be classified as Primitive.

RESPONSE: The Complex Plan proposes a sixcar parking west of the “Tube” in conformance with the APSLMP.

COMMENT: I urge DEC to dramatically cut back on motorized uses within these lands, providing only for limited access by handicapped people and holding to the deal struck with the towns for snowmobile passage, which never included the Polaris Bridge, but did include a legal bridge across the Cedar.

RESPONSE: DEC believes that this Complex Plan strikes the appropriate balance between recreational access, including access for people with disabilities, and resource preservation.

COMMENT: I support keeping the Essex Chain of Lakes motor‐free to protect the rivers and lakes from the introduction of invasive species. This is a unique, ecological area and protecting the waters from invasive species should be a priority.

RESPONSE: Motorized boats are equipment not allowed in the Essex Chain Lakes.

COMMENT: Driving to the Essex Chain of Lakes by permit violates the State Land Master Plan and the APA Classification Resolution: The Draft UMP recommends that the general public, by permit, be allowed to drive past Deer Pond parking lot for 2 miles to a 4‐ car parking lot at “the Wild Forest‐Primitive boundary” near Fifth Lake. By doing so, the Draft undermines the APA classification resolution for a “motorless” Essex Chain Lakes Primitive Area. Even 4‐cars by permit throughout the year encourage the very things DEC does not want: introduction of invasive species into the lakes, and introduction of baitfish into the lakes. The easier DEC makes motor vehicle access for the general public, the more likely that the lakes will become polluted. The proposed action violates the Master Plan’s Primitive Area guidelines by proposing a motor vehicle road to the heart of a Primitive area. Further, it undermines the very purpose of the DEC’s CP‐3 program designed to provide exclusive motorized access to persons with disabilities or mobility limitations so that they have an opportunity to experience the same solitude and connection to nature that the general public enjoys. Finally, the APA classification decision in 2013 clearly intended to limit motor vehicle use of this road only to those qualifying for CP‐3 access: “Wild Forest access… to the south shore of Fifth Lake was established for the sole purpose of providing access to persons with disabilities.”

RESPONSE: DEC has considered this comment and has determined not to make a change in the Complex Plan. Title II of the Americans with Disabilities Act (ADA) requires, in part, that reasonable modifications must be made to the services and programs of public entities, so that when those services and programs are viewed in their entirety, they are readily accessible to and usable by people with disabilities. This must be done unless such modification would result in a fundamental alteration in the nature of the service, program or activity or an undue financial or administrative burden.

COMMENT: An area of about 27,000 acres purchased had approximately 40 miles of 2‐wheel drive accessible roads which were cut back to less than 3 miles. Try to call that real access and you will find it is little more than a non‐substantive appeasement. Much of the 40 miles of roads were of the quality that withstood the travel of logging trucks. Now they cannot be used for a pickup truck; cutting back from 40 to 3 miles does not make sense.

RESPONSE: The Complex Plan calls for 10 miles of the approximate 30 miles of former woods roads (a combination of all season and winter use only roads) to be open for public motor vehicle access within the lands classified as Wild Forest. These 10 miles of public motor vehicle roads are those which most suitable for travel by motor vehicle.

COMMENT: Some items such as proposed parking lots and non‐CP3 access were mentioned and then somehow lost between the initial proposals and the management use plan. These should be corrected in the UMP as it pertains to the Essex Chain Lakes Complex.

RESPONSE: The Complex Plan proposes a sixcar parking area west of the “Tube” in conformance with the APSLMP.

NonMotorized Use

COMMENT: I believe that there are aspects of the draft plan that fail to take into account a more longterm vision for the Park. I believe that allowing motorized access on the Essex Chain Complex would greatly harm the unique ecosystems found here. Thus, I fully support management of the Complex as motor‐free. In line with this view, I do not support expanding motorized access in the Hudson Wild and Scenic River Corridor, or the building of new snowmobile trails in the Vanderwhacker Wild Forest Area. Both of these areas contain habitats and organisms that would be put in danger by the damage motor vehicles can cause. In addition, this area will also be threatened by the likely introduction of invasive species as a result of motorized vehicle use. Consequently, I believe that the Polaris Bridge should be removed. I also support replacing the bridge over the Cedar River for hiking, mountain biking, snowmobiling and equestrian use, but believe the bridge must remain irrevocably closed to all motorized use with the exception of snowmobiles. In addition, I support providing special access for persons with disabilities, such as the creation of parking lots near Fourth and Fifth Lake, as I believe it is essential that all are able to experience the beauty that the Complex has to offer.

RESPONSE: The use of motor vehicles in the Complex Area has continued for nearly a century, and DEC believes that the continued use of motor vehicles subject to the restrictions within the Plan, will not adversely affect the natural resources present in the management area.

COMMENT: The Wild Forest corridor to 4th‐5th Lakes on the Essex Chain violates the State Land Master Plan because it does not facilitate legal motor vehicle use. This road is an illegal peninsula into the Essex Chain Lakes Primitive area and DEC should abandon plans for motor vehicle access on this corridor. The “tube” that allows motor vehicle access across 4th‐5th lakes should be removed and that channel ecologically restored.

RESPONSE: The road to the “Tube” is classified Wild Forest and motor vehicle use is a permitted use within lands classified as Wild Forest. The Complex Plan proposes to remove the “Tube” when it becomes no longer usable, and replace with a bridge, which will provide for a more natural channel.

COMMENT: Please take this letter as my public input in favor of keeping the Polaris Bridge and to designate the area as Wild Forest.


COMMENT: I do not own a snowmobile, and I try to avoid the noise and smoke whenever and wherever I can. I do see some value in the machines as a tool, but that’s not the purpose of the Polaris Bridge. Nevertheless, connecting different snowmobile regions with corridors (and such novel infrastructure as the Polaris Bridge) provides such great benefit for the snowmobile economy for so little land and infrastructure cost. We all need to get along and respect the other side if we are to effectively manage our resources. The decision to designate the area as a wild forest is a sound investment in that direction. It gives the snowmobilers a little consideration with a little land and infrastructure.

RESPONSE: The comment is noted and the Complex Plan proposes a Class II community connector snowmobile trail that utilizes the existing Iron (Polaris) Bridge in order to connect the communities of Indian Lake and Minerva.

COMMENT: Use of the bridge after the expiration of the Polaris Club’s leases would be a violation of the APSLMP and WSRRSA.

RESPONSE: The DEC agreement with the former landowner allows lessee access until September 30, 2018, and the Nature Conservancy access until September 30, 2019. The future of this bridge may be determined prior to these dates and acted upon afterwards. Note that this bridge was constructed under a WSRRSA permit issued by the APA.

COMMENT: One of the most significant issues is the fact that the Iron (Polaris) Bridge is currently designated for motorized use in this UMP so that snowmobiles can access one of two proposed trails in the Vanderwhacker Wild Forest. The Department of Environmental Conservation (DEC) must not allow motorized use of the Iron (Polaris) Bridge and should remove this temporary bridge which was installed by Finch Pruyn for logging in 1992. There is no need for a snowmobile trail across the Polaris Bridge into the Vanderwhacker Wild Forest and in fact, motorized use of the bridge would not be in the best interest of the resource because this action would site motorized use in the edge of the defined Remote Interior areas in the Vanderwhacker Wild Forest. Further, DEC has explained that the two routes that are proposed to cross the Iron (Polaris) Bridge have major construction issues. The two proposed routes in the Vanderwhacker Wild Forest that would cross the bridge are very wet or have major construction issues. I am also very concerned that either one of these proposed routes will create a redundant snowmobile corridor because of the existing snowmobile route to the west of the Essex Chain Lakes Management Complex that utilizes the Cornell Road and connects Indian Lake to Newcomb and Minerva.

RESPONSE: The Complex Plan proposes to allow the continued use of the Iron (Polaris) Bridge for snowmobile access and to support a CP3 designated route. Pursuant to current law and regulations, DEC has determined that the use of the Iron (Polaris) Bridge can continue as an existing land use.

COMMENT: As snowmobilers in NY, we support the overall Complex plan as submitted by the Department of Environmental Resources. We believe the Polaris Bridge should remain in place. Also, we support a Cedar River Bridge. We are snowmobilers from PA that visit NY to snowmobile several times each winter.

RESPONSE: Comment is noted and the Complex Plan currently proposes the continued use of the Polaris Bridge, and the construction of a bridge over the Cedar River, to support a Class II community connector snowmobile trail linking the Towns of Indian Lake with Minerva.

COMMENT: The Opalescent Hunting and Fishing Club has 75 members who also hike, bike and snowmobile. As snowmobilers we support the overall plan and support any effort for the trails to become a hub for the five surrounding towns. We believe the Polaris Bridge should stay open and serve multi‐trail function. We STRONGLY support Alternative 1B for a snowmobile trail that will connect Indian Lake to Minerva and a Cedar River bridge as you outlined in Alternative 4. This area has long been neglected and can serve to open up the recreational possibilities like those in Old Forge/Inlet area.

RESPONSE: Comment is noted; with regard to the use of the Iron (Polaris) Bridge, please see the response above. In regard to Alternative IB, DEC has concluded this alternative has the potential for greater adverse environmental impacts due to terrain constraints and the presence of wetlands areas. Alternative 1A can be constructed using fewer bridges and terrain manipulation.

COMMENT: The connection of these towns and the use of both proposed bridges will be a great way to enjoy these wonderful chunks of land that would otherwise only be enjoyed by a few. I know this land better than most and would love to see the next generation get off their phones and get into the woods.


COMMENT: I firmly support the proposed snowmobile trail that crosses the Hudson on the Polaris Bridge and continues up the east side of the Hudson to Newcomb, where it will join the Newcomb to Minerva trail.

RESPONSE: Comment is noted and the Complex Plan currently supports the use of the Iron (Polaris) Bridge. 

COMMENT: The Adirondack Council opposes expanding motorized recreational use in the Hudson Wild and Scenic River corridor and opening for new public motorized use what the Council refers to as the “temporary” Polaris Bridge installed in 1992 by Finch Pruyn for logging.

RESPONSE: DEC believes the proposed use of the Chain Lakes Road (South) and the Iron (Polaris) Bridge do not constitute an alteration or expansion from the current levels of existing land use. 

COMMENT: I DO NOT believe that the Polaris Bridge, which crosses the Hudson River, should be removed. The Polaris Bridge should be retained and repaired when necessary.

RESPONSE: Comment noted and the Complex Plan currently supports the continued use of the Iron (Polaris) Bridge. 

COMMENT: Any bridges that are currently in place should remain such as the Polaris Bridge. Removing already in place structures in this area is just plain not a good idea.

RESPONSE: Comment noted, see above response. 

COMMENT: The Polaris Bridge should be removed. It is a nonconforming use in a Wild, Scenic, and Recreational River Area. It was never intended to be permanent. The APA permit allowing its’ construction stated that the bridge was to be used temporarily until logging was completed. It was never a public road or open to use by the public. The Draft Complex’s statements to the contrary are an attempt to rewrite history and are misleading. To comply with the law, once this property came into State ownership, the State – through its appropriate agency, which in this case is DEC, is required to take the bridge away.

RESPONSE: The APA permit issued on February 27, 1992 does not contain a condition that the bridge be removed after the property is logged. As stated in the APA permit Conclusions of Law: “The project would not cause an undue adverse impact upon the natural, scenic, aesthetic, ecological, wildlife, historic, recreational or open space resources of the Park or upon the ability of the public to provide supporting facilities and services made necessary by the project, taking into account the economic and social benefits that might be derived therefrom.” DEC has determined that the Iron (Polaris) Bridge is an existing land use, and the continued use of the bridge by the public does not constitute an expansion or alteration of its use. 

COMMENT: The justification for the continued use of the Polaris Bridge and the construction of the Cedar River Bridge should be provided.

RESPONSE: The Complex Plan includes additional information relating to the justification to support the determination that allows the continued use of the Iron (Polaris) Bridge and the construction of a bridge over the Cedar River. 


COMMENT: The two options for new class II community connector snowmobile trails proposed to be cut through the Vanderwhacker Mountain Wild Forest area will violate the NYS Constitution because of the great number of trees to be cut and the vast alteration of the natural terrain which undermines constitutional protections that these lands be “forever kept as wild forest lands.”

RESPONSE: DEC believes the construction of the proposed Class II community connector trail through the Vanderwhacker Mountain Wild Forest area will not violate Article XIV of the New York State Constitution because an immaterial amount of three cutting is anticipated. The location of the new trail will be sited in a manner which minimizes impacts to the environment to the greatest extent practicable. 

COMMENT: The alternatives for snowmobile trails which could be located to the west of the Hudson River need additional analysis. Related to this, the assertion that the Chain Lakes Road (North) is a town road is incorrect. The commenter says there is no evidence that the Town of Newcomb maintains this road. The DEC should refer to Highway Law 212 and disallow ATV’s on this road.

RESPONSE: DEC has considered this comment and declines to make this revision with regard to the snowmobile trails located to the west of the Hudson River. The location of the trails to the west of the Hudson River result in the potential for adverse impacts to the river resources in the area greater than the preferred alternative. With regard to the ATV use, the Complex Plan does not propose any public ATV use on roads. 

COMMENT: I would like to see at least consideration for a trail from Indian lake to Minerva. The trail from Indian lake to Newcomb was one of the best things that ever happened to the area.

RESPONSE: The Complex Plan establishes a trail between Indian Lake and Minerva. 

COMMENT: The Adirondack Council supports establishing appropriate snowmobile use and snowmobile trail alternatives that limit impacts to the natural resources and serene recreational xperience that this wild area offers. The Council opposes the building of new snowmobile trail in the interior of the Vanderwhacker Wild Forest Area. The Council states that this would unnecessarily open this wild and remote area to disturbances given other trail alternatives to the west, and put at risk sensitive wetlands and wildlife habitats.

RESPONSE: DEC has determined that the preferred alternative for the segment of the Indian Lake to Minerva Class II community connector trail located within the Vanderwhacker Mountain Wild Forest area minimizes adverse environmental impacts to the greatest extent practicable. Locating the trail within the Vanderwhacker Mountain Wild Forest area provides the most direct and reasonable route for creating a community connector route between the communities of Indian Lake and Minerva. Existing haul roads will be utilized for a portion of the segment, and DEC will seek to avoid, consistent with the 2009 snowmobile guidance, wetlands and sensitive wild life habitat.

COMMENT: How will ATVs be prevented from using snowmobile trails?

RESPONSE: DEC will enforce against unauthorized ATV use within the Complex Area.

COMMENT: I have been snowmobiling the area for over 33 years and my family enjoys all the area has to offer. We usually stay in the area 8 weekends in the winter and 1‐2 weekends in the summer.


COMMENT: Snowmobiles trails should stay on the periphery of management areas and stay near existing roads.

RESPONSE: The Complex Plan proposes to locate snowmobile trails in accordance with the 2009 snowmobile guidance. Careful consideration will be given to site trails in locations that minimize adverse environmental impacts to the greatest extent practicable. Locating snowmobile trails next to existing roads can sometimes diminish the snowmobile experience and create potential safety issues. 

COMMENT: I strongly support Alternative 1B for a snowmobile trail that will connect Indian Lake to Minerva.

RESPONSE: Alternative 1B has the greater potential for adverse environmental impacts to the natural resources of the Vanderwhacker Mountain Wild Forest area, therefore the preferred location of the trail is Alternative 1A. 

COMMENT: As nature and snowmobile enthusiasts, we support the complex plan and believe a “recreational hub” would not only be beautiful, but also could provide needed winter revenue for these communities. We support Alternative 1B and Alternative 4 and feel that the Polaris Bridge should stay in place to serve the multi‐trail system in the Complex. We also support ALL of the efforts and energies of the DEC and applaud your work as you serve and protect our beautiful Adirondack Park!


COMMENT: The commenter supports both options 1A and 1B for the snowmobile trail, but prefers 1B as they like the direct connection between the towns. Parking areas should be in the hamlets and not in the interior of the management areas, so the people who access the management areas will have access to food and lodging.

RESPONSE: DEC believes that the most direct route would result in an unacceptable level of adverse impacts to the natural resources within the area, therefore Alternative 1A is the preferred alternative. The DEC has provided for a limited number of parking spaces in the interior of the management area with the full understanding that demand will exceed the capacity and parking areas within the hamlets and towns will be utilized. 

COMMENT: I was at the hearing in Newcomb and was disappointed that we could not ask questions. I was also disappointed that you are still showing Alternative B as a possible route, and concerned that snow trends in the park and climate change in general were not discussed. Minerva has not had reliable snow cover in the last ten years, enough for heavy use by groomers and half ton snowmobiles. The commenter asks who would maintain the marshy route through the wild forest. The commenter asks if DOT has been contacted about constructing a bridge at Route 28N over the Boreas River. The commenter asks what chemicals are used on bog bridges, such as fungicides, and asks if these chemicals would come in contact with the water. The commenter asks for a picture or specification for bog bridges and asks if these are in use on private land. The commenter asks to see an easement contract for a connector trail going over private land, preferably a form that is completed.

RESPONSE: The purpose of the hearing is for DEC to receive public comment on the proposed Complex Plan. In order to conduct the hearing in a manner that is fair to all participants, DEC is unable to respond to questions or comments in that forum because of the time it would take to answer all questions received. 

COMMENT: DEC’s plans to retain and utilize the Iron (Polaris) Bridge and build new multi‐use snowmobile trails through the interior of the Vanderwhacker Mountain Wild Forest area violates the Snowmobile Trail Guidance because it is duplicative and will be cut through a wild, interior area of the Forest Preserve. No new snowmobile trails should be cut through the Vanderwhacker Mountain Wild Forest area east of the Hudson River. These trails are redundant since the APA has approved a Minerva to Newcomb trail and there is already a trail from Indian Lake to Newcomb, so there is already an Indian Lake to Minerva connection. The existing snowmobile trail through the conservation easement needs to be assessed.

RESPONSE: The existing trails to the West in the Blue Mountain Wild Forest connect Indian Lake to Blue Mountain Lake, Indian Lake and Blue Mountain Lake to Long Lake, and Long Lake to Newcomb, but not Indian Lake to Minerva. The proposed snowmobile trail in this UMP is intended to connect Indian Lake to Minerva. 

COMMENT: I support the recreational use of snowmobiles on a dedicated trail network as long as these recreational uses do not impact recreational uses of other visitors, wildlife, and habitat in the wilderness area. However, I oppose building a snowmobile trail into the interior of the Vanderwhacker Wild Forest Area as it would unnecessarily disturb the area and put sensitive wetlands and wildlife at risk.

RESPONSE: DEC has selected the preferred alternative for the snowmobile trail in a location that minimizes adverse environmental impacts to the greatest extent practicable. The analysis by DEC took into account impacts to other uses on this multiple use trail, as well as impacts to wildlife, habitat, and other natural resources. DEC has chosen Alternative 1A because it avoids environmentally sensitive areas within the Vanderwhacker Mountain Wild Forest which includes many wetland areas. 

COMMENT: We are a family of 4 avid snowmobilers. My wife and I and our children absolutely love Adirondacks. We are members of the NYSSA and travel 6 ½ hours every weekend each way to enjoy what the Adirondacks have to offer for our sport. We support the overall Complex plan as it should support the efforts of the five surrounding towns to become a “Recreational Hub” and generate much needed income for the area. We would love to see the proposed 1B alternative for a snowmobile trail that would link Minerva to Indian Lake. We also believe the Polaris Bridge should stay in place and serve all seasonal uses for recreation. We would also support a new Cedar River Bridge as described in Alternative 4. We own a property in upstate Pennsylvania where we have snowmobiled for years and we prefer to make the much longer trip to the Adirondacks because of the involvement and planning such as this that makes the experience that much more enjoyable.

RESPONSE: Alternative 1B was rejected by DEC because of the significant environmental constraints caused by the existing terrain, number of wetland crossings and probable impacts to wetlands. DEC estimates that Alternative 1B would require twice as many bridges built than Alternative 1A, and would require more terrain modification such as the construction of water bars, benchcutting, ditching, and the construction of a turnpike through a wetland. 

COMMENT: Please allow/keep the Essex Chain of Lakes trails open to snowmobile use. I also strongly urge the DEC to make the necessary upgrades to any bridges, crossings, signage and maintenance of trails to enhance the system for all types of activities. Snowmobilers’ economic impact is considerable and reaches past NY State borders. Please keep the trails open and maintained.


COMMENT: As a snowmobiler, I support the overall Complex Plan. The plan should support the efforts and the desire of the five surrounding towns to become a “Recreational Hub.” I believe that the Polaris Bridge should stay in place and serve multi‐trail interests in the Complex. I strongly support Alternative 1B for a snowmobile trail that will connect Indian Lake to Minerva.

RESPONSE: Alternative 1B was rejected by DEC due to the greater potential for adverse environmental impacts to the Vanderwhacker Mountain Wild Forest. 

COMMENT: Remember that snowmobile trails are designed for multiple uses, including horses and bikes, not just snowmobiles.


COMMENT: It should be explained how the proposed location and design of the proposed snowmobile trails comply with the snowmobile guidance documents.

RESPONSE: This has been addressed in Section O on the Complex Plan – Snowmobile Trails. 

COMMENT: In assessing various alternative management recommendations this Draft UMP fails to take Climate Change into account. The decline in the number of weeks of snow pack and the loss of ice cover even in the central Adirondack Park over the past 50 years is very well‐documented. The failure of any Adirondack Forest Preserve UMP to take these facts into account in how winter sports like snowmobiling are planned and managed should be viewed by the DEC and APA as a serious UMP deficiency.

RESPONSE: DEC has considered the effects of climate change on the proposed Complex Plan, but declines to make any changes to the current version of the document. 

Universal Access

COMMENT: I am glad to see a section devoted to handicapped and elderly people. I am 82 years old, a year round resident of Newcomb living at Goodnow Flow on Woodys Road and have a DEC handicap permit. Please speed up your plans for handicap use at Fourth and Fifth Lakes. Traffic in front of my home has increased ten‐fold. The DEC Ranger told us that people going to and from Deer Pond would use the Cornell Road all the way to and from Route 28N. The state spent our tax dollars to buy this easement, so please grade that road to make it the access to Deer Pond and not Woodys Road. Safety is important.

RESPONSE: The accessible parking, camping, and waterway access for people with disabilities will be constructed this field season. 

COMMENT: For over 30 years I have enjoyed fishing the Stillwater area of the Hudson River. The gate was erected 0.80 miles from the river. There is no way I can haul my canoe up that long hill. We were told the gate was going to be moved closer to the river as permitted, so as to eliminate the hill. If this cannot be done, then let handicapped people go around the existing gate. Snowmobiles can. How do handicapped people get to Third Lake? Do we have to paddle all the way to get to the best fishing? Will the Management plan permit battery powered bicycles? They have no motors, and can travel the proposed bicycle trails. They are used by pedaling on level ground and then assist when going up hills. They have a far less impact on the trails than horses and snowmobiles and require less expense for trail maintenance.

RESPONSE: The parking for the Hudson River at the Iron (Polaris) Bridge has been moved down the hill, and is now 0.30 mi from the River, on a much flatter grade. Accessible parking and waterway access will be provided at Fifth Lake, and from Fifth Lake there are no carries to Third Lake, one can paddle seamlessly. 

COMMENT: The Adirondack Council supports providing special access for persons with disabilities, including a parking lot close to Fourth and Fifth Lake for those seeking an authentic wild lands experience.


COMMENT: I believe that the Hudson Wild and Scenic River corridor must remain open to people of all abilities to enjoy. And, I support keeping the Polaris Bridge across the Hudson River. The Adirondack Park is vast. There are enough totally wild areas to preserve the natural resources. Its beauty should not be completely closed off from people with limited mobility.


COMMENT: Efforts should be made to provide the maximum four‐season motorized access for the most people.

RESPONSE: DEC believes that this Complex Plan strikes the appropriate balance between recreational access, including access for people with disabilities, and resource preservation. 

Wild, Scenic and Recreational Rivers System Act (WSRRSA) 

COMMENT: Use of the Polaris Bridge and crossing of the Boreas River by snowmobiles is not permissible under the WSRRSA.

RESPONSE: DEC has determined that existing statutory and regulatory authorities allow a permit to be issued to locate a trail, designed for use by snowmobiles, within a WSRRSAdesignated river corridor, and allow the construction and use of a bridge over a river designated as Scenic. 

COMMENT: DEC must ensure that the planning, implementation, and construction of the bridge over the Cedar River complies with NYS Wild, Scenic, and Recreational Rivers Act (WSRRA) Regulations. DEC must follow the law in creating this new recreational resource in the Essex Chain Lakes Management Complex.

RESPONSE: DEC will adhere to existing statutory and regulatory authority for the planning, implementation and construction of a bridge over the Cedar River Scenic River. 

COMMENT: DEC’s plans for motor vehicle use within designated Wild and Scenic River corridors violates the Wild, Scenic and Recreational Rivers Act and violates long established management principles, practices, and precedents in long‐standing Unit Management Plans, such as the Blue Mountain Wild Forest UMP.

RESPONSE: DEC has interpreted existing statutory and regulatory authority to allow the continued use of motor vehicles, primary snowmobiles, within designated river areas as an existing land use.

COMMENT: I support wild lands restoration and to that end, oppose expansion of motorized recreational use in the Hudson Wild and Scenic River corridor. I also support the removal of the Polaris Bridge to bring the area back to the wild quality its name suggests.

RESPONSE: The State realizes that constructing program goals, such as the protection of natural resources and providing public access to recreational opportunities , are sometimes unavoidable, however, experience DEC strives to seek a balance among these priorities in order to provide as broad experience as possible to all members of the public.

COMMENT: The Essex Chain Complex UMP should comply with the Wild, Scenic and Recreational Rivers Act, which prohibit a motor vehicle bridge over the Cedar River, prohibits retention of the Polaris Bridge for use by motor vehicles, and prohibits motor vehicles, such as float planes on Pine Lake or automobiles on the Chain Lake Road South, within the .5‐mile corridor of classified Wild rivers.

RESPONSE: The Wild, Scenic and Recreational Rivers System Act and its implementing regulations were enacted and adopted, respectfully, to preserve rivers in their freeflowing condition and to protect their immediate surroundings for the benefit and enjoyment of present and future generations. The act and implementing regulations identified certain activities that were allowed and prohibited, but also acknowledged that certain land uses, in existence when the act and its regulations first took effect, could continue. Such is the case for the use of the Polaris Bridge, the Chain Lakes Road (North), the Chain Lakes Road (South), and floatplane use on Pine Lake. The construction of a bridge over the Cedar River Scenic River is permitted for roads and nonmotorized open space recreational uses. The regulations also allow DEC to permit motorized open space recreational uses, namely snowmobiles, to use the bridge if the DEC determines that the use will not adversely impact any river resource and meets all other applicable standards.

COMMENT: When the purchase of the land was being considered, the understanding at that time was that the WSRRS was going to be amended to allow the uses and their locations that are proposed in the Draft UMP. If the Cedar River Bridge is important, then the regulations should be amended.

RESPONSE: DEC has determined that existing statutory and regulatory authorities allow the proposed Action Steps in the UMP to be implemented without the need for a regulatory amendment.

COMMENT: Comment was made that when the WSRRS Act was enacted it was not understood that all existing structures had to be removed.

RESPONSE: DEC has interpreted the WSRRS Act to conclude that existing structures and improvements can continue to be used in the Complex Area in compliance with the WSRRS Act.

 Photo provided by Protect the Adirondacks: Polaris Bridge over the Hudson River.

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Phil Brown is the former Editor of Adirondack Explorer, the regional bimonthly with a focus on outdoor recreation and environmental issues, the same topics he writes about here at Adirondack Almanack. Phil is also an energetic outdoorsman whose job and personal interests often find him hiking, canoeing, rock climbing, trail running, and backcountry skiing. He is the author of Adirondack Paddling: 60 Great Flatwater Adventures, which he co-published with the Adirondack Mountain Club, and the editor of Bob Marshall in the Adirondacks, an anthology of Marshall’s writings.Visit Lost Pond Press for more information.

18 Responses

  1. Paul says:

    “Noted” – love it! It should say “duly noted – next”!

    So a new use – bridge over the cedar river – is allowed for a scenic river? Interesting At least that is their interpretation. The Polaris bridge is an existing use so I think the fact that the act referrers to “new” uses like this not being allowed that seems legal. If it is there when the act took effect it can stay.

  2. Ron T says:

    Is it time to revisit the “Master Plan”? The preservationists tout that document with the same fervor that fundamentalist Christians tout their bible. From what I’ve heard, Peter Paine was the principle architect of that plan and he wasn’t known for having a broad point of view. The adherents of the “Plan” almost succeeded in torpedoing the 1980 Olympics because the ski jumps were non-conforming structures and would be visible from the summits of certain high peaks. I feel that we need to take a broader look at that document and enlist the expertise of all segments of New York to make it more relevant to today’s needs.

  3. Scott says:

    Phil, I strongly believe in following the rules, laws, regulations etc. You wrote that the Essex Chain plan violates the ASLMP by allowing bicycles in the Essex Chain Lakes Primitive Area. My copy of the ASLMP, 1987 2nd edition, page 23, says though bikes are generally not permitted in primitive areas just like they are prohibited in wilderness areas, it goes on to say bikes may be used in primitive areas on existing roads open to the public and may be used on state truck trails specifically designated for such use and specified in the UMP. With that wording it does not seem that the Essex Chain plan is violating the SLMP with bicycles. There is an existing example of a bike trail in the Hutchins Pond Primitive Area on the gated Lows Lake Upper Dam road from Otterbrook. Bicycles seems to be permitted in primitive areas on existing roads or truck trails when designated and specified.

    • Phil Brown says:

      Scott, I just want to clarify that it was not I who wrote that the bicycle routes violate the SLMP. The comments in the article represent views expressed by the public.

      • Scott says:

        Thanks for that clarification. Bikes trails designated on the primitive area roads comes up often.

  4. Jim Waters says:

    I believe that this purchase was a terrible abuse of State powers to use tax payers’ money to further the interests of a powerful minority of its’ residents…as well as another economic blow. People of this state are voting with their feet. How long does the State of New York think they can hold up “favorable” industries with public funding? — “Noted”.

  5. Keith Gorgas says:

    Several things are readily apparent from this long list of comments. !) local people have a far better understanding of what they are talking about, no matter which side of a debate they fall on, than autocratic bureaucrats in Albany.
    2) We have gone full circle from a representative government that our forefathers gave their life’s blood for. We are so much the poorer.

    • Boreas says:


      WRT #2 – Garbage in, garbage out. If we elect poor legislators, we can’t expect good legislation. Once the influence peddlers and lobbyists get hold of politicians, representative democracy goes out the window.

      But also keep in mind, with a highly partisan and polarized citizenry, half the citizens are going to be really pissed off with any legislation – even compromise legislation.

  6. chris says:

    Surprised that there’s such a large majority in favor of more motorized access and bridges.

  7. Mike Tomaszewski says:

    I see a portion of my letter to DEC has been cited, however, most was not. I am particularly distressed by exclusive reservation of several campsites for use by float plane clients only. Is this public land or not? This smacks of political pandering and back door dealings. Float plane clients should have to adhere to the same permit process as the rest of the general public.
    Phil, this seems an opportunity for you and the Adirondack Explorer to expose the almost certain corruption that has led to this arrangement.

    Mike T.

    • Scott says:

      In any other country it is called corruption but in our country the politicians legalized it and called it lobbying.

      • Boreas says:

        Scary, ain’t it?

      • Paul says:

        What is the solution. To not have anyone talk with the folks making the rules and let them decided everything devoid of comment or suggestions from the public? Lobbying is how you get your voice heard. There are just as many regular people up on capital hill each day as there are professional lobbyists. If you don’t believe me just take a trip down to DC and check it out for yourself. People have to get over this idea that trying to influence decision makers in any way is some evil kind of corruption.

        • Scott says:

          True and good points but I don’t like how money can buy votes.

        • Boreas says:


          I think you may be surprised how many of those lobbyists are bankrolled by big business and well-funded special interest groups and how few are working pro bono for the Average Joe. That is why those ‘regular people’ are there in Albany and Washington D.C. – they are either unable to afford a lobbyist or they are powerful enough that they don’t need a lobbyist.

  8. joe says:

    I believe the float plane thing was a deal that Finch made, or maybe TNC made, and it was written into the deed before NYS bought the land. The State can’t change it if it wanted to, odd as it is. Mike Carr, who runs TNC, is a float plane pilot so maybe he did this deal. But i don’t think it was something NYS did. That’s my impression.

  9. Todd Eastman says:

    Comments are taken into consideration but the number of pro or con comments received do not directly translate into the decision…

    • Bruce says:


      You’re right, and I might add at the end of what you said, “nor should they.” After all, they’re just comments not official votes.

      I’ve been to public hearings where people were in effect “bused” to give the impression that a particular agenda was what the “public” wanted.

      What I thought humorous was a move by the Wildlife people in North Carolina to open Sunday hunting on private land. You saw hunting and gun clubs taking bus loads of their folks, and church groups taking bus loads of their folks, each trying to “pack” the hearing to make it look like they represented the public at large.

      The generally expected result was the WRC left it up to the landowners to allow Sunday hunting or not. Still no Sunday hunting on public land in NC.