At the Boreas Ponds classification hearing held in Albany on December 7, 2016, Ross Whaley reminded the audience that public opinion alone doesn’t determine a land classification. As a former chairman of the Adirondack Park Agency, Mr. Whaley would know.

But at that same hearing — the last in a series of eight hosted by the APA — about eighty people stepped up to the podium to make their voices heard, in a marathon session that stretched a good four hours. A lot of people had something to say about Boreas Ponds that afternoon.

And by the time the written comment period ended on December 30th, the agency had received some 11,200 emails, letters, and postcards from concerned people not just across the state, but from across North America and beyond.

This level of public interest in a classification proceeding was probably unprecedented; I had certainly not seen anything like it. People participated in this process in good faith, offering their input with the assumption that state officials were paying attention.

More important than the quantity of those comments was the content. Many, many people were disappointed with the shortage of options presented by the park agency, and were not shy in saying so. Of the written comments, 84% supported a wilderness classification at Boreas Ponds stronger than anything being considered by the state; 36.5% favored a full wilderness classification, meaning no mechanized access of any kind.

By comparison, only 4% of the people who submitted written comments to the APA supported a wild forest classification, and only 11% supported Alternative 1, the map proposal that was the darling of motorized access proponents. Even fewer people favored the “split the baby” idea advocated by The Nature Conservancy and Protect the Adirondacks, in which the Boreas Ponds Tract would be shared fifty-fifty between the wild forest and wilderness designations; this proposal was supported in only 39 letters, representing a paltry 0.3% of the overall count.

I offer these numbers, first publicized back in January, as a reminder that New Yorkers were already disappointed six months ago with the state’s failure to consider Boreas Ponds as predominantly wilderness. By rejecting the four alternatives presented by the APA, the public indicated a clear preference for a definitive classification—not one that attempts to do a little bit of everything, as at the Essex Chain Lakes.

So imagine the outrage that will ensue when people learn the reason why we still don’t have a decision all these months later: the Department of Environmental Conservation has been floating a counterproposal that would take us even further away from a wilderness classification. The idea is to install a “luxury camping” facility at or near Boreas Ponds, part of what might eventually grow into a “glamping” network across the Adirondack Forest Preserve. Wilderness is the last thing on DEC’s mind.

Few details have been disclosed about this project, and whatever discussions DEC and APA have had since January have been conducted opaquely, without public scrutiny or input. Therefore what began as an awe-inspiring example of public participation now seems likely to result in a mistrial, with our state land stewards unable to reach a consensus. If DEC is listening to anyone, it most certainly isn’t the people.

What We Know

Currently, no firm proposal has been put forth for the public to review, leaving us therefore to deal with rumor and speculation. A classification for the Boreas Ponds had been expected over the winter, but there is apparently deadlock between APA and DEC. On the one hand is the public’s overwhelming support for wilderness, and on the other hand is Albany’s ambition to create a hut-to-hut system in the Adirondacks.

This desire comes straight from the top. It was spelled out in Governor Cuomo’s 2017 State of the State book in January, which outlined a program called “Adventure NY.” It was described as “a multi-year outdoor recreation campaign … to connect more New York families and visitors to the great outdoors.” Most of this would be accomplished through infrastructure improvements budgeted at $50 million. However, only one project was mentioned by name. “Specifically,” the proposal stated, “DEC will construct infrastructure at Boreas Ponds in the Adirondacks and build trails as part of the ‘Hut-to-Hut’ system that links State lands to community amenities.”

The State of the State Book was posted after the public had already voiced its preference for wilderness at Boreas Ponds, but the idea of creating an Adirondack hut-to-hut network appeared long before that. In 2014, an education consulting business called Leading E.D.G.E. LLC contracted with the state to produce a conceptual hut-to-hut plan. The project itself was called the Adirondack Community-Based Trails & Lodging System, or ACTLS for short. Funding came from the NYS Department of State.

Leading E.D.G.E. published its ideas in December 2015, a year before the Boreas Ponds comment period. The bulk of the report consists of maps of its proposed trail networks, making it long on ideas but short on specifics. One of the primary goals is to simply link Adirondack communities with surrounding state lands, allowing hikers passing through the wilderness to spend their nights at existing inns, lodges, rental cabins, and the like, rather than camping in the backcountry.

But “huts,” too, were a big part of the proposal, although the definition of this word was left open-ended — as was the question of who would build and manage the huts, the state or some yet-to-be-named concessionaire. The most specific description can be found in this passage:

We believe an ideal lodging capacity in the Adirondack Park to be 24-36 beds. It provides for a reasonable return on investment and sustainability, yet does not have too large a footprint. The ideal Adirondack lodge on private land will be “energy plus” (it produces more energy from renewable energy sources, over the course of a year, than it uses) and/or LEED certified. As much as possible, it will have a small physical footprint and an aesthetically appealing look that is visually screened. Any lodging on state land, should it be permitted, will meet similar criteria, except that it will be temporary in nature, off the grid, and removed for portions of the year.

It’s the phrase “lodging on state land” that is triggering red alerts, because throughout the history of the Forest Preserve this has been a problematic topic. Whenever the state acquires land, one of its first actions has always been to remove the buildings; putting up new ones would therefore be counterproductive.

And yes, the ACTLS plan does envision hut development on the Boreas Ponds Tract. Two of their maps show an area extending from Boreas Ponds southwest nearly to Trout Pond where the authors believe a luxury camping outpost should be located. Such an installation would preempt the wilderness classification favored by the public.

Rehashing an Old Idea

The idea of locating enclosed camping structures in the Forest Preserve is legally questionable, and hardly a new idea. The Porter-Brereton Amendment in 1932 (backed by Robert Moses, the state parks director who notoriously had no patience for wilderness preservation) would have permitted fully enclosed structures on state land, such as lodges and cabin colonies, available for rent. Parks, as far as Moses was concerned, should be developed, not “locked up” in a way that only a hardy few could enjoy them.

But the proposed amendment to the “forever wild clause” of the state constitution was roundly defeated in the public referendum by a ratio of two to one. Governor Franklin D. Roosevelt was among its critics, saying “we do not want the great forest parks of the State locked up against the people. But we do not want to turn them into popular amusement resorts.”

There is also the experience of tent platform use in the Adirondack Forest Preserve. A century ago, the old Conservation Commission (forebear of today’s DEC) implemented a program in which anyone, under state permit, could build a wooden platform anywhere on state land, upon which camping structures could be erected. This was among the state’s very first efforts to promote recreational use of the backcountry.

But in practice, these “temporary” tents evolved into permanent camps with windows and padlocks. Permits were passed to children and grandchildren, so that campsites became exclusive domains used by the same families every summer. By mid-century there were 900 tent platforms on state land across the Adirondacks — all of them privately constructed — compared to just 198 state lean-tos. The Conservation Department phased the program out in the 1950s and 1960s, and the first State Land Master Plan in 1972 listed tent platforms as non-conforming structures.

Not as Temporary as You Might Think

A key adjective in the current hut proposal is the word “temporary.” By this, we are to assume that whatever glamping structures are erected at Boreas Ponds will be removed every year on the shoulder seasons, thereby sidestepping the constitutional barrier that defeated Porter-Brereton. The 1932 proposal would have opened the door for permanent buildings, but a yurt or canvas tent can be put up or taken down as needed. “Temporary.”

The state employees who are receptive to this idea will tell you as much, citing the fall hunting camp tradition as precedent. Every year, people routinely secure DEC permits to put up seasonal camping structures on state land, ranging from canvas cabin tents to parked trailers — enclosed structures that may remain in place for weeks or even months. If these temporary structures are permitted, then what can possibly be the objection to other temporary structures for summer use?

For starters, there is a difference between a warm tent put up every November for someone’s personal use, versus a tent put up on public land for commercial purposes. Because to be clear, the “luxury camping” envisioned by state officials and ACTLS is not the first-come walk-up convenience of a lean-to, but a curated camping service for which people will pay to stay. This already seems to run afoul of DEC’s regulations, which explicitly state that “use of State lands or any structures or improvements thereon for private revenue or commercial purposes is prohibited,” with certain exceptions.

But the “temporary” nature of these proposed structures is also highly doubtful. Brendan Wiltse, my colleague at Adirondack Wilderness Advocates, was also the Johns Brook Property Coordinator at ADK for several years. During that time he became very familiar with the requirements of managing a backcountry, off-the-grid enterprise. In his experience, health regulations would likely make it impossible to provide “temporary” conveniences, because of the significant investment in infrastructure and maintenance.

Anyone seeking to provide lodging and meal services will need to meet Department of Health requirements if the intent is to sleep more than ten people. Specifically, they would need to meet the requirements of Part 7, Subpart 7-1 of NYCRR Title 10. Regulations would require potable water, as well as the disposal of gray water and human waste, both of which pose human health and environmental risks. Providing potable water requires either a well, a gravity-fed surface-water system, or a generator to pump surface water into a holding tank. Water would then need to be filtered and chlorinated. All of this requires infrastructure for plumbing, storage, and electricity. It also requires daily testing and maintenance.

A suitable gray water system would at the very least require a buried grease trap and single leach pipe, such as those used at Johns Brook Lodge.

Human waste would need to be either collected in barrels or composted. The latter option may sound easier, but composting in a backcountry environment — and for large volumes of people — typically is not effective. Therefore if onsite disposal is not possible, the waste will need to be transported offsite. As stated with the water system, there is a significant amount of staff time required to manage this waste.

If the state or its vendor chooses to serve food to its guests, then there is almost no way the structures could be temporary. There would need to be critter-proof food storage, refrigeration, stainless-steel counters, and wall and ceiling coverings that are able to be cleaned and sanitized — not to mention all the space needed for an industrial stove, three-bay sink, and the storage of kitchen wares. Just like any restaurant or grocery store, these backcountry camping and food preparation facilities would be subject to annual health inspections.

Let’s not forget the staff required to manage these facilities. The result is a very significant footprint on the landscape, more than most people would probably expect for a few yurts or canvas-walled tents. None of this is comparable to a camper parked on state land by a few hunters for their own private enjoyment.

A State-Subsidized Advantage over Private Enterprise?

In the middle of the twentieth century, when the state opened its ski centers at Gore and Whiteface, it put a dozen smaller ski centers out of business. The state had the resources to install snow-making equipment and more comfortable lifts, and it also had the liberty to put up directional signage along state highways. The privately owned ventures tended to be on smaller slopes (the state owned all of the largest mountains), and the best lift they could muster was often a T-bar; off-site advertising has always been prohibited in the Adirondack Park. Therefore competition with the state-run slopes proved fatal for many of these small businesses, and it remains a significant challenge for the few commercial and municipal ski centers that remain today.

With this experience in mind, it is disturbing to consider what impact a state-run yurt network could have on the existing businesses that have already been trying to fill the luxury camping niche, such as Camp Orenda in Johnsburg or Falls Brook Yurts in Minerva — neither of which were incorporated into the ACTLS proposal.

I asked Michele Hanley, a co-owner of Falls Brook Yurts with her husband Jim, if she thought the state’s potential entry into the yurt business would threaten her operation. “Yes it does,” she said. “Absolutely. There is more and more competition. We’d need to pay more for listings to keep up.”

Did she think there is enough demand to support more and more yurts all across the park? “No. I do not think it is good overall for us due to saturation of the market,” Hanley responded.

She cited a number of factors that could cause a decline in backcountry camping in coming years, from demographics to the rise in disease-bearing ticks. “Millennials are not as much campers,” she noted. “They want everything to be easy and comfortable. Look at how Patagonia has changed their focus to looking good, less on material performance. It’s a changing population. The Boomers, once diehard campers, are aging and using comfortable Airbnbs instead. We think our house rental in Minerva will get busier than the yurts.”

Therefore one of the unanswered questions behind this glamping movement is whether there is really any public demand for these types of facilities. On the one hand, Hanley’s observations on the changing generations would seem to point toward a rising interest in luxury-style camping. However, are the people who want queen-sized beds and gourmet meals willing to walk ten miles for the privilege? Aren’t inns, hostels, and beds-and- breakfasts already satisfying that desire to be pampered after a sweaty day on the trail?

On the other hand, a state-subsidized glamping network could come at the expense of the small businesses like Hanley’s that are already attempting to fill this niche market on their own private land. Rather than bringing additional revenue to the Adirondacks, the proposed backcountry huts/yurts/what-have-you could simply end up redirecting that revenue from one person’s bottom line to someone else’s — especially if Hanley is correct, and the market has already been saturated.

The ACTLS report, which includes 90 pages of route proposals, does not even pose these questions, let alone answer them. I see this as a fundamental flaw, because essentially what ACTLS has put forth is a business plan to monetize the Forest Preserve — but without taking the time to understand both the current market for luxury camping and its potential customer base. This type of market study should have been one of the very first steps in the process, and the results of that study should have determined the subsequent actions. Drawing maps of all the proposed routes and lodging sites is the last thing that anybody should be doing right now.

Make This a Public Process

To be fair, though, state and local government has been the instigator behind this effort; Leading E.D.G.E. and ACTLS are merely the instruments that drafted the plan, using state grant money. But part of the problem is that this has been a mostly stakeholder-driven project. That is to say, the people with a vested interest in the preferred outcome — whether they be DEC employees, town officials, or individuals who simply don’t like roughing it — have been the primary actors. Such a process, top-loaded with like-minded individuals discontented with the way the Forest Preserve has traditionally been managed, is certain to produce skewed results.

If all of the self-identified “stakeholders” are biased in favor of installing yurts on state land, for instance, then the result will be exactly what ACTLS has produced: a proposal that places the final product well ahead of the public policy discussion that rightly must come first. By proceeding directly to how to modify the Forest Preserve to include backcountry glamping — before discussing whether we should — the ACTLS process ensures that the turning of the first shovelful of dirt will lead directly to litigation.

Therefore if DEC really is poised to make such a proposal for Boreas Ponds, then this needs to be brought into the full light of day. This needs to be turned from a stakeholder process into a public process immediately. All of the ramifications need to be analyzed. Is glamping really the future of the Forest Preserve? Should state government be putting itself in direct competition with private enterprise? Any proposal to change the way the Adirondack backcountry is managed must first be subject to public input, scrutiny, and criticism — well before the first connector trail is cut or building site selected.

Simply because other mountainous areas have huts on public lands isn’t justification enough to import that culture here. Nor does it guarantee we could replicate the success of other regions. In most cases, those hut systems come with long histories and traditions. People identify them with the landscapes to which they belong. So while the huts in New Hampshire make that state unique, most people already associate the iconic lean-to with the rugged Adirondacks. In fact, outside of New York State lean-tos are often called “Adirondack shelters.”

In other words, wilderness is our brand. It’s what we do better than Maine, Vermont, and New Hampshire combined. State land stewards should never fail to recognize that distinction. Why develop away our most recognized asset? Why not seize on that distinction and promote it, rather than trying to emulate a hutting tradition that we barely understand and is not endemic to our state?

Which brings me back to Boreas Ponds. Of the 11,200 written comments submitted to the APA last year, very few called for yurts on the newly acquired property. The people who want to sleep in a bed with clean sheets — on a lake with stunning mountain views—already have the option to book a room at the nearby Elk Lake Lodge. Considering that thousands of people have asked for wilderness at Boreas Ponds, and almost no one has demanded luxury camping, the public’s frustration with the way the state is handling this classification process is justified. The people have spoken, but state officials refuse to listen.

Photos from above: Adirondack Yurt; Fall Hunting camp; Boreas Chart courtesy AdirondackWilderness.org; and a 1920 Lake George Tent Platform.