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Fifty-one years ago (1971) the newly created Adirondack Park Agency was granted the authority to draft, revise, and interpret the Adirondack Park State Land Master Plan, or APSLMP. That plan was signed by the Governor in 1972 and revised by many Governors since. The NYS courts have found that the APSLMP has the force and effect of law.
No Material Increase: This past week, the APA sent the public notice that we have 60 days to comment in order to “inform the APA Board’s interpretation of the Adirondack Park State Land Master Plan’s Wild Forest Basic Guideline No. 4 – no material increase of road mileage on lands classified as Wild Forest.” The rest of APA’s press release consists of seemingly arcane questions and alternatives that presumes public awareness and understanding of the past and how it relates today.
I have a few basic problems with what APA has sent out to the public. First, what precipitated this sudden rush to submit a complex set of questions and alternatives to public comment? APA provides no clues and no context. A public workshop is planned, presumably to help answer basic questions like this, but this educational step should have been completed before scheduling a public comment period.
Second, and as I will explain, the Agency’s apparently sole focus on Wild Forest Guideline No. 4 is misplaced. This guideline should be interpreted in context with other guidelines in the State Land Master Plan.
Third, the entire exercise ignores the Adirondack Park as a whole in which there are 800,000 acres under some form of conservation easement, many of which contain miles of trails and dirt roads open to public motor vehicles, either year-round or seasonally. To signal, as the Agency appears to be doing, that all measurements of “materiality” in the increase of such motorized access must be realized within Wild Forest areas of the Adirondack Forest Preserve makes little sense from a Park planning perspective.
Basic Guideline 4: The APSLMP’s Wild Forest Basic Guideline No. 4 states that “Public use of motor vehicles will not be encouraged and there will not be any material increase in the mileage of roads and snowmobile trails open to motorized use by the public in wild forest areas that conformed to the master plan at the time of its original adoption in 1972.”
Measuring “material increase” has bedeviled the staff of both agencies for 50 years. Staff need accurate information as to what existed in 1972, what exists today and what constitutes materiality. I do not gainsay this need for the staff to know the information and to be able to trust it and present it with confidence to the boards and to the public.
This has not always been the case. Case in point: the snowmobile trail mileage on Wild Forest areas of the Forest Preserve was estimated from hand-drawn maps and field checked with surveyor wheels in the 1970s and again early in the 21st century. Those snowmobile estimates spanned both sides of the digital divide. Moreover, the quality of the estimation varied considerably across the Adirondacks. As a result, the estimates were just that – and were continually changing. That lack of clarity frustrated members of the Snowmobile Focus Group brought together by DEC for several years some 20 years ago. I was one of those Focus Group members. The snowmobile mileage numbers on the Adirondack Forest Preserve, over 750 miles, are still estimates, as are the snowmobile trail numbers on private and municipal lands, some 1100 miles Parkwide.
State Land Master Plan guidelines once appeared internally coherent and integrated to its authors and early interpreters, but as the decades pass, they appear less and less coherent and integrated to the staff and boards now in charge. It is tempting for today’s planning administrators to read these guidelines in isolation from each other. That appears to be happening now. That means that staff and board must be continually trained to read and interpret the State Land Master Plan as one coherent, cohesive, integrated document.
If one does that, Guideline 4 cannot be read in isolation from other Master Plan Wild Forest guidelines, such as this guideline found under the very relevant heading Recreational Use and Overuse:
All types of recreational uses considered appropriate for wilderness areas are compatible with wild forest and, in addition, snowmobiling, motorboating and travel by jeep or other motor vehicles on a limited and regulated basis that will not materially increase motorized uses that conformed to the Master Plan at the time of its adoption in 1972 and will not adversely affect the essentially wild character of the land are permitted (underlining is mine).
This guideline expands on Guideline 4 on which so much APA attention appears solely focused. This other guideline focuses on recreational use, not just mileage. It focuses on the essential wild character of the land. How much motorized uses (as opposed to mileage) have grown since 1972 and how they may be affecting the essential wild character are vital judgment calls, not measurements. This guideline appears to suggest that while knowing the mileage of routes in 1972 and today and judging their “materiality” is important, it is not at all sufficient.
Meeting with a key DEC Director of Lands and Forests: I organized a small group to meet with Norman J. Van Valkenburgh in 2006 to seek answers from a man who ought to know. Norm was the DEC’s Director of Lands and Forests at a crucial point in time from 1976-1980 when DEC felt obliged to carry out the Master Plan’s guidelines, including the Wild Forest guidelines cited here. We asked Norm about the confusing caveats and qualifications of the Master Plan, especially in its Wild Forest guidelines. We asked how we should read the Master Plan coherently. Norm told us he felt on firmer ground than we did. Even as everyone appears focused on the mileage of roads and trails open to motorized uses, Norm told us that emphasis is misplaced. The real emphasis should be on use, he said.
During our 2006 meeting Norm explained that Wild Forest guideline 1 under Recreational Use and Overuse “doesn’t say mileage; it says use, which means the level of use today should be no greater than such use was in 1972. If there were, say, one hundred snowmobiles using the snowmobile trails on the Forest Preserve in 1972, then no more than one hundred should be allowed on those trails today – whatever mileage of trails there was or is today…Everyone has focused on the mileage of snowmobile trails and ignored the crux of the plan. The purpose of the Master Plan was to restrict and control use, not set a limit of the number of miles of trails. That’s why no such number was put in the Master Plan. Trail width, height, tread, parking and all other uses facilitating motorized vehicles such as snowmobiles similarly should not be materially increased beyond what existed in 1972,” he said.
Norm went on to say that unit management plans (UMP), the documents which carry out the general guidelines of the Master Plan in the field, should be used to appropriately limit additional motorized uses, locations, mileages. “UMPs can actually be the tool to ratchet back such uses,” he said. “The Master Plan sets an upper limit on such uses, but DEC has ample authority to set those limits lower in each UMP.”
DEC’s “ample authority” to set lower limits on motorized uses is found in this State Land Master Plan guideline under the heading of Motor Vehicles and Motorized Equipment:
The Department of Environmental Conservation may restrict, under existing law and pursuant to authority provided in this master plan, the use of motor vehicles, motorized equipment and aircraft by the public or administrative personnel where in its judgment the character of the natural resources in a particular area or other factors make such restrictions desirable.
Do Motorized Uses Expand with growth of the Forest Preserve? At their May 2022 meeting, some members of the APA still seemed uncertain about whether “no material increase” applied only to pre-existing Forest Preserve as of 1972. Maybe what was intended was expansion of motor vehicle opportunities on Wild Forest classification whenever the Forest Preserve’s Wild Forest grew.
Once again, Wild Forest guidelines in the State Land Master Plan must be read in their entirety. Under the heading Roads, Jeep Trails and State Truck Trails, guideline 3 clarifies the question of newly-acquired Forest Preserve classified as Wild Forest:
“Established roads or snowmobile trails in newly-acquired state lands classified as wild forest may be kept open to the public, subject to basic guideline 4 set forth above.”
“Subject to basic guideline 4” demonstrates that the Agency and the Department were anticipating the additional acquisition of Forest Preserve post 1972 and that agencies understood that the mileage open to public use of motor vehicles was constrained and should not materially expand as the result of new state land acquisitions.
Putting together all of the State Land Master Plan Wild Forest guidance should give the APA little doubt of what was intended by the authors of the State Land Master Plan – to tightly constrain not just the mileage open to public use of motor vehicles in the Adirondack Forest Preserve, but the motorized uses as well, and not to expand that mileage and uses as new state lands were acquired. The APA understood in 1972 that such constraints were fundamental to a 20th century application of the meaning of the “Forever Wild” provisions of Article 14, Section 1 of the New York State Constitution. The same understanding should persist today.
Conservation easements and Park context: One of the biggest changes to the Adirondack Park since 1972 is the very significant acreage of private lands now under conservation easement – more than 800,000 acres. There was no conservation easement law until 1983. Once, pulp and paper companies held onto their lands for extractive use at mills. Those ownerships ended years ago. Now, miles of private industrial roads as well as trails on conservation easements are open to some form of negotiated public motorized recreation. In fact, DEC’s easement program and its snowmobile plan are partially intended to shift some motorized access off the Forest Preserve and onto routes negotiated with private landowners.
APA and DEC are planning agencies and should interpret the Master Plan’s guideline about materiality of Forest Preserve routes open to motorized uses through the planning lens of the entire Adirondack Park. The agencies should know the mileage and location of routes on private and municipal land as well as on the Forest Preserve. APA should analyze Wild Forest materiality knowing also the extent, location and connectivity of motorized opportunities on privately-held conservation easement land and municipal land. After all, isn’t this one Adirondack Park?
Related: see this recent discussion post
Photo: Gulf Brook Road on the Forest Preserve in North Hudson
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Yes, it’s one Park and this makes total common sense.
It is beyond me as to how the APA will complete this study with any degree of accuracy. I live on Lens Lake Road in Stony Creek.
350′ beyond my property, this “road” crosses private property Lot 270.-1-2 (old Lot # 14) and from there travels .75 miles to the Livingston Lake Club “in-holding” which is under the same ownership as the Lot 270.-1-2.
DEC refers to this road as a “travel way”, which is apparently, their definition of an illegally constructed road, through the Forest Preserve, that connects two private properties.
The 2006 Draft UMP for The Wilcox Lake Wild Forest did not recognize this road and questioned it’s legality. The Town of Day which contains half the “travel-way’s” mileage does not recognize it as a legal road.
The APA map of roads for The Wilcox Lake Wild Forest shows the portion of this road in Stony Creek but not the portion in Day.
How can any conclusion the APA/DEC reaches have any credibility when they look the other way at an illegal road that was realigned across private property 120 years ago and routed to a private in-holding and is maintained and traveled for the benefit of a private landowner.
The APA will not even address the numerous “wet-land” violations associated with this road/travel-way.
This is actually very in line with my own intuitions about Wild Forest Basic Guideline No. 4. The management goal should not be to conserve road mileage, but to conserve pre-extant (conforming) land uses, and even then, as a reference point for maximum level of acceptable use. The problem, as we have seen by now, is that qualitative standards are highly susceptible to erosion (e.g., by political pressure).
I’d be the first to be wary of an overreliance upon quantitative guidelines for Park management. These, too, can be eroded and circumvented. (Notwithstanding, GIS overlays, especially in the Adirondacks, are not perfect either.) However, having watched the last meeting, it seems unlikely that there will be a paradigm shift at APA prior to this decision.
Fortunately, I do think that there is a better qualitative strategy than any of those in the matrix presented by APA staff (one that conservatively limits motorized use). Measure and limit road mileage by individual Wild Forest unit; and, without excluding any CP-3 roads from oversight, treat each type of land use (public motorized access, CP-3, snowmobile) differently (e.g., by using weighted metrics).
Anything else proposed — Parkwide metrics like total mileage or miles/acre — will only become tools for implementing bad management, giving the State ample buffer room to circumvent APSLMP guidance for any specific area that they set their sights upon for expansion of motorized use. For example, under the proposed interpretations, some private rights-of-way may likely be integrated into existing public road networks as inholdings or surrounding private lands are added to specific Wild Forests units in the future. Hopefully by codifying existing road mileage on a highly granular basis into an institutional mandate, at least this type of future “material increase” of motorized use can be averted in a way that most existing users will find acceptable.
All of that being said, we do indeed need to be managing the Adirondack Park as one Park if we are to eventually solve the problems that we are seeing now with overuse, housing, etc. But simple is not easy. Many of the proposed “management complexes” and “independent working groups” are apt to fail in a big way without big paradigm shifts. How do we start? ..From the ground up or from the top down?
* I do think that there is a better QUANTITATIVE strategy
A commonsense interpretation of “no material increase” means just that–no increase for the sake of increase. “Material” in this case refers to things like new roads, or new routes, or changing uses. No material increase allows some leeway for when some road needs to be rerouted slightly, but does not allow for new road construction or allowing motorized use on trails that formerly did not allow motorized use. No means no!
Thanks again to David for laying out the details that the APA never seems inclined to communicate.
I tend to agree with Zephyr about a reasonable definition of material change, but then there is nothing so uncommon as commonsense and the APA is clearly not content with “no means no,” if it actually considered that possibility. As JB says, this focus on details leads to larger questions, to a context that is even bigger in my mind than what David describes. I think I feel another op-ed coming on, but have a deadline to meet first.
Thanks to all for drilling down on the meaning(s) of “material.” I agree with the view that emphasizes “use” — by which is meant the repeated and repeated downward pressure on a defined space of ground. Foot-steps in the same place may be the start of a path just as tire tread on top of tire tread compacts a roadway. How do we gauge overuse? What’s more, there are legions of potential abusers of roadways itching to barrel up, down and over motorized spaces.
All needs to be understood, in my opinion, given the current zeitgeist for selling 4-wheel drive trucks, AWD SUVs, vans, ATVs, motorcycles and related off-road motorized vehicles. Ford, Toyota, Chevrolet, Range Rover you name it they are there. Visualize the 10 and 30 second truck commercials showing carefree folks climbing up a rock strewn trace, wheels spinning, tossing rocks and dust into the clear mountain air. See that shiny truck or SUV sliding to a stop near the edge of a precipice — a few rocks tumbling over the cliff for effect — high up near the top of a mountain. Whether shot in the Rockies or Monument Valley, these are the adrenaline pumping moments the public is conditioned to think is “really livin’ the life.” The Adirondacks and Catskills are a short road-trip from anywhere.
The potential for motorized vehicle overuse was the late Edward Abbey’s nightmare. To say nothing of the call for sustained wilderness preservation of Colvin, Apperson, Marshall, Schaefer, Zahniser and others. Talk about context! The Adirondack Park is our public trust. Whether road, trace or trail we need to prevent material overuse.
James,
You have succinctly and accurately hit the
proverbial nail on the head!
I detest the irresponsible “message” of those TV commercials. They, like cigarette commercials, and not
“certain” words should be banned from the airways!
It’s not out of the question. In France, car commercials are now required to encourage people to drive less!
Here here! And their healthcare system is way better than ours.
Thank you!
This is a well thought out discussion and analysis of the ongoing dilemma faced by the APA and others in trying to further the goals of each different organization. Mr. Gibson’s article should be read and understood by all people interested in the future of the Adirondack region, not just the limited wild forest areas. It it long past the time when these guidelines can be viewed in isolation. The entire park and the impact of any change (in this case wild Forest Roads) must be looked at in the entire context of the future of the Park region.
We can certainly quibble about the mileage of roads and snowmobile trails that were there as of 1972. Norm VanValkenberg categorically stated that there were 848.88 miles (and he said he was a surveyor), but more recent research indicates there were fewer miles on Forest Preserve. Does this mean, however, that mileage could increase to that level without a “material increase.” The notion that use levels for motorized recreation cannot increase beyond those in 1972 is totally unjustifiable to motorized interests given that the non-motorized use of wilderness areas has increased many fold since 1972. Politically (and like it or not, these decisions are political), that constituency is just as deserving of equal treatment as the non-motorized constituency.
I am certainly no suggesting that any new roads be constructed on newly-acquired lands, but the status of Gulf Brook Road (as pictured at the top of this article) was debated extensively regarding the access that should be allowed. I was a strong advocate – both in online comments and at a public hearing – for public access to end at the Inner Gate, now designated as the “Fly Pond Parking.” In the end, public road access was extended to Four Corners (and yes, I took advantage of that access), but the decision to allow access that close to the ponds was not arrived at without significant debate.
To me, the decision-making process regarding Boreas access is how we responsibly move forward in the 21st Century as land ownership and use levels change. We can’t be locked in to what was believed to be “best” in 1972.
“We can’t be locked in to what was believed to be “best” in 1972.” So where does it stop? Throw out Forever Wild? Certain concepts and laws are so basic and essential they endure. No material increase in motorized use is integral to the concept of Forever Wild.
I’m confused on what Mr. Goodwin writes. First, Mr. Gibson writes about use and roads on Wild Forest lands, however, Mr. Goodwin doesn’t identify which land type Norm Van Valkenberg asssociates with those 848.88 mi miles of roads and snowmobile trails. Then, Mr. Goodwin throws in “new research (reference needed please) indicates that there were fewer miles on Forest Preserve”. Shouldn’t we be comparing apples with apples and not apples with pears?
Then, Mr. Goodwin writes, based on use levels, that it’s not fair to motorists because use on non-motorized trails has increased on wilderness areas and he infers motorized use on public trails and roads has not. This is bunk for several reasons, first, as Mr Gibson stated, there has been a large increase in leased land obtained by the state which has greatly increased the amount of roads open to the public for motorized use; second, motorized use on existing roads in the Wild Forest has increased dramatically (just look at the explosion in sales of snowmobiles and ATVs in the last several decades), as well as non-motorized use. Although, using conditions in 1972 may not be perfect, the courts need a standard to go by to make their rulings, and Mr. Goodwin offers no solution as to what that standard should be. Without criteria, we’ll end up with a huge number of individual battles at each location– a waste to time, money, and emotional capital. I assume that the 1972 criteria was implemented to prevent the slippery slope of development sprawl spoiling the Adirondack wilderness. The main point in creating the Adirondack Park was create a place where wilderness can thrive without threat of being victim of industrial, suburban, and urban sprawl.
I had assumed that anyone reading this critique would know that snowmobile trails could only be on lands classified as Wild Forest. The “new research” was stated by Rich Weber, APA Director of Planning, as being “only” 760 miles on Wild Forest lands – therefore potentially allowing more snowmobile trails on Wild Forest while still remaining under the 848.88 cap.
As for the future, as of now there is no cap on hikers in Wilderness areas, so how can the State justify any cap on snowmobile users.
And to respond to your last point, the Adirondacks have managed to mostly avoid unlimited growth and remain far, far wilder than any other part of the Northeast.
They are not capping the numbers of snowmobile users, just the mileage of the trails. In some respects they have capped the number of miles of hiking trails as well.
A good writer knows not to assume what the reader knows. A good writer explains everything clearly and references original data to the reader (not second-hand references such as verbal statements). There may be readers unfamiliar with the history of non-motorized and motorized use in the Adirondacks and want to learn more about it.
Mr. Goodwin fails to cite the date of the “new research” that he mentions and also the original reference or source of that information so that the reader could check it out for themselves. In any case, both factors of the timeline (of what and when was measured) and the source of the original data are critical in this case. Mr. Goodwin mentions that “Norm VanValkenberg categorically stated that there were 848.88 miles of snowmobile trails” which was the best available data at that time and which was used as the original criteria in the Adirondack Park State Land Master Plan. Then, in 2008 (not so new research), the Adirondack Park Agency remeasured snowmobile trails that were displayed in a 1972 DEC snowmobile trail map (https://apa.ny.gov/state_land/analysis_mileage_small_11x17_600dpi.pdf), and came up with 740 mi. Again, this was not new info, it was remeasuring conditions in 1972 again using a different source of old data. It is important to note that the APA figure of 740 mi does NOT represent the present extent of snowmobile trails, but represents that back in 1972. Mr Goodwin wrongly jumps to the conclusion that that there are now about 109 mi of potential snowmobile trails below the the cap of 849 mi. The real questions are:
1) What is the source of the discrepancy between the snowmobile trail measurements for 1972 noted by Norm Van Valkenberg (surveyed?) and that by the APA in 2008 (also of 1972 data)?
2) What is the original source of the Norm Van Valkenberg’s figure of 849 mi and where can one examine that data?
3) Whose data is more accurate? I have reservations about the accuracy of the DEC map that was digitized by APA just from a brief glance in the area where I live in which I noticed that the snowmobile trail along the abandoned D&H RR bed thru the Wild Forest in the Bloomingdale Bog does not show up in their map.
4) In any case, if the APA map of the remeasured extent of snowmobile trails in 1972 does prove to be the more accurate measurement, then that data becomes the best available data for 1972, and it follows that the snowmobile trail cap figure of 849 mi should be replaced by 740 mi.
Another unknown is that the State during the last 50 years (1972-2022) has purchased land that has become Wild Forest and some of these new lands included snowmobile trails. My question would be how many more miles of snowmobile trails were added since 1972? We also know that there are over 1,000 mi of snowmobile trails on leased land open to the public.
And to respond to your last point, it is inappropriate to compare development and wilderness between the Adirondacks and the Northeast. The management approach of the Adirondack Park is unique– there is no other place like it.
Has development been increasing in the Adirondacks? Yes, it has, especially in the tourism and second home sectors. As an example, I have seen one measurement of that growth reflected by the number of new wells drilled in the Adirondacks–an indication of new homes being built. For a groundwater study I’m conducting in the Adirondacks, I’ve collected 9,500 well records in the Adirondacks for a 20 yr period from 2000-2020. That number is expected to be significantly higher if I had included the period of COVID, when there has been a housing shortage and a resulting spike of second-home building.
The Adirondacks Park is an unique environment where people and an wilderness ecosystem coexist. It’s a delicate balance between the people who choose to make a living here and also the right of an ecosystem not to be threatened.
As per Mr. Gibson, I don’t see how anyone can see ambiguity in the phrase: ” …snowmobiling, motorboating and travel by jeep or other motor vehicles on a limited and regulated basis that will not materially increase motorized uses … are permitted.” The APA Act (alongside Article XIV) is also unambiguous that all uses — including hiking or skiing — must be limited to some degree on all Forest Preserve.
“Unlimited growth” is impossible anywhere. Similarly, there is no human activity that can truly “Leave No Trace”. Everything must be done in moderation (and some things not at all). Clearly, those who drafted the APA Act and APSLMP realized this, and, now faced by the spectre of growing overuse, we should too. Why don’t we?
I believe the ambiguity is whether the APA Act intends to enforce limiting uses is based on mileage of trails and roads, or on the amount/intensity of use.
APSLMP doesn’t say either/or — it says both!
Basic Guideline No. 4, which the agency has chosen to focus on, explicitly prohibits the opening of additional road or snowmobile trail mileage (newly constructed or pre-existing) for public motorized use. Other guidelines (e.g., “Roads and administrative units” guideline no. 4) explicitly prohibit construction of new roads on wild forest lands (except limited administrative roads), effectively creating something akin to the US Forest Service’s 2001 Inventoried Roadless Areas Rule. Still, other guidelines explicitly limit levels of use.
The only ambiguity I see is the question of whether the opening for public access of pre-existing roads on newly-designated wild forest lands constitutes a material increase in road mileage (i.e., if road mileage in other wild forest areas is not closed). I see a strong argument for this in the case of lands annexed to existing wild forest units, since this would almost certainly increase levels of motorized use (especially with respect to acquisition of inholdings or adjacent lands with private rights-of-way). But what about altogether newly-designated wild forest units? If yes, as David suggests, then this creates a huge management conundrum because effectively it means either that APA needs to define “no material increase” as some arbitrary but liberal percentage of new mileage above 1972 total Park mileage (a perilous situation), or that DEC will need to close public roads in existing wild forest units if any newly-established wild forests are to have public roads.
If we’re being practical and using common sense, I think it’s reasonable that APSLMP “Roads and administrative roads” guideline no. 3 is in fact not requiring this — that road mileage on “wild forest areas that conformed to the master plan at the time of its original adoption in 1972” can be measured separately from road mileage on newly-acquired tracts big enough and isolated enough to be designated as completely new wild forest units, as long as wild forest character is protected.
Whatever choices are made, one of the worst and most misguided options would be to establish an acre per mile proportion for all wild forest units within the Park. Think about it: is the relationship between wild forest character and road mileage really linear? …In other words: if you have a circle and you expand its area by 100%, does the distance across it also expand by 100%? Of course not! For every percent increase in area, the distances between points within that circle increase by a much smaller proportion. There needs to be a balance between this kind of arbitrary and unrealistic granularity on the one hand and arbitrary and obtuse abstraction on the other.
Wild forest designation was clearly not primarily designed so that wild forest areas could act as thoroughfares for motorized use. Contrary to some interpretations, neither were designated wild forests, which constitute a significant proportion of the Forest Preserve, created as a way to allow for intensity of use that degrades the wild or biophysical character of the resource. What wild forest designation does allow for is a visionary way of preserving wild land, where strategic motorized access, building off of historic use patterns, enables a different kind of recreation experience than wilderness — namely, easily accessible spur trails and clustered campsites — while, from an ecological standpoint, still preserving large areas de facto wilderness.
Can Adirondack Almanac consult with a web designer to make a responsive website that would allow us to read articles on our phones please? Fonts should display at least at 14 pixels on a mobile phone. Thx
With my Firefox Android browser Settings/Accessibility I can disable “Automatic font sizing” and choose any size I want. OR I can enable “pinch and zoom.
I doubt AA can make changes that would work across all smartphone browsers.
I can read articles fine on my Android phone using the standard Chrome browser.
My Firefox works fine for me as well on default settings. But if I wanted to change the font size, that’s how I would do it.
If this really means that there can be no material increase in USE and it has nothing to do with milage.. Does this mean that we cannot have more people with disabilities now in 2022 (or in the future) than had access in 1972, who might need MV access allowed on these roads? That seems like its gotta violate the ADA? Dave, what do you think?
Well said, JB. The focus needs to be on the goal/s, not the metrics.
You need both goals and metrics. You can’t have an outcome to achieve goals without criteria, methods, and thresholds.
I have spent a fair part of my life writing “criteria,” including even award-winning ones. But they are only relevant where there is sufficient clarity of and commitment to the goals. Where the APA, and this specific issue, are at these days is all about goals. A focus on metrics or criteria (or whatever you call them, we could throw ‘standards’ in there as another way of saying it), in the absence of that clarity and commitment is more likely to further muddy the waters (and despite JB’s excellent explanation, these waters are muddy) than to achieve anything. This thread is full of evidence supporting that point.
Having metrics and yet focusing on goals are not mutually exclusive! There is even a way to achieve goals without any metrics at all, but that is a very, very long story, and one that nobody is willing to hear yet…
No, but there is an order to it. Goals first. When the numbers start driving you end up with neoliberal capitalism and no intrinsic values, whether they be wildness or wildlife or what.
I have seen important goals achieved without anything I think Mr. Miller would recognize as metrics, though there might arguably have been implicit criteria (as in, don’t piss off Gladys, she rules public opinion around here). I was speaking to a group yesterday and found myself making the point that what they needed to promote was not, at least not in the first place, good policy or technical solutions (though they will need these later). What they needed to promote was imagination.
I guess we’ll have to agree to disagree. Solving a problem or resolving an issue is a PACKAGE. Establishing goals are not first, as Mr. Nellis stated. The first thing is to identify and characterize the problem, including the pertinent background info such as what and when was done in the past. Next, is to establish some initial goals, and having some imagination comes into play here, as Mr. Nellis points out, but in other cases tried and true goals and methods may suffice. Then, reality (ex., physical or political conditions) may require that the goals to be modified when considering physical conditions in the environment and whether the entity attempting to solve a problem have the power or sphere of influence to achieve the initial goals. For example, does the local government have jurisdiction over an issue or does some other level of government. Then, methods are needed to to established that can successfully execute to goals. Methods of study include the information needed to be collected, compiled, and analyzed in order to solve the problem. Last, but not least, as a scientist, I have found in many instances that, such as with the Best Management Practices BMPs) in agriculture, that plans to measure whether policies and practices were successful after they were implemented were lacking or non-existent. For example, there have been little done to determine whether these BMPs have been successful or not. Have the BMP practices and equipment and operation continue to be effective and maintained over time? Have nutrient levels that are causing Harmful Algal Blooms, (HABs) been reducing in runoff to streams and lakes? More practices and policies need to incorporate post-implementation metrics or we’ll never know whether these practices and policies are successful or not and whether we’re wasting time and money. You can write great goals, even award winning ones, but if you can’t prove that your goals were successfully achieved thru post implemented metrics, then you may be fooling yourself.
After seating in on last evenings online presentation on by APA and DEC on the interpretation of the Adirondack Park State Land Master Plan’s Wild Forest Basic Guideline No. 4, I feel that this thread has gotten off on a tangent. Last evenings presentation focused on motorized vehicle roads and NOT on snowmobile trails that much of this thread ended up to be on (I was guilty of this, also). Also, there was considerably emphasis on consideration of how recent handicap access (referred to as (CP-3) has affected present road mileage and may affect planned changes in the future. Anyway, what I wanted to point out is that in order to be informed with accurate info, one should really read and examine the documents posted on the APA website (https://apa.ny.gov/Mailing/2022/05/stateLand.htm) as well as articles such as Dave Gibson’s. The APA website contains background valuable as well as info to know about what the APA and DEC are seeking are far as public input. In a nutshell, for going forward into the future dealing with the amount of motorized roads in the Adirondacks, these agencies are seeking public input on three proposed scenarios that deal with defining what a road is, and defining what is meant by and what could be meant by “material increase”. Recent handicap access policies are a significant factor in these considerations. The three proposals are summarized in a table in slide 33 (https://apa.ny.gov/Mailing/2022/05/StateLand/NoMaterialIncreaseAlternativesPresentation.pdf). Note that APA may be uploading in the near future a more recent powerpoint based on last nights presentation.
This conversation has gone into a circle, so I will cease and desist after this. But why on earth would anyone go to the trouble of defining and properly characterizing a problem if they didn’t want to solve it? Intention is fundamental. Do goals expand and evolve as we learn? Hopefully. And does having some agreed upon measures of success help? Yes. But how often can those measures be as simple as the change in a single very simple (though not necessarily very easy to count) number?
I began this understanding quite clearly how the APA is trying to channel public comment on a complex issue into three neat, quantitative scenarios that are effectively rooted in how the world was 50 years ago. How can doing that be fair to a public that holds a wide variety of perceptions and opinions, to decision-makers operating in a politically complex field or, most of all, to a resource that we will all agree is massively complex.
Is our understanding of the impacts of roads better than it was in 1972? Without doubt? Is our understanding of forest ecology better. Yes, it is. Is our understanding of what “wild” means more sophisticated? Despite disagreement about it, the answer is either “Yes” or we have to admit to not having learned a thing in 50 years. That could be true, I suppose, but hopefully not.. Any proposed set of metrics which treats all miles of road, all areas of wild forest, and all recreational experiences (with one partial exception) as essentially the same just is not credible.
A recording of last night’s meeting is available online for any interested (http://nysapa.granicus.com/ViewPublisher.php?view_id=2). For those who attended last month’s APA meeting, little of the information presented will be new, save for a bit more background on snowmobile and CP-3 mileage and the two public comments advocating for increased accessibility for users with disabilities.
I think that Lee’s (and also David’s) point here is that, while maybe organizationally useful as suggested starting points for further discussion, arbitrary metrics, like the proposed 15% (or greater than or less than) increase in mileage, should be (or need to be) augmented with context, a task which itself requires something like imagination. While I agree that monitoring and adaptive management is useful (especially in specific contexts), I do not believe that it can effectively constitute the be-all-end-all solution for land management that it is often promulgated as — e.g., as in the APA/DEC Visitor Use Management Framework (as full of metrics as anything that I have ever seen).
No matter how comprehensive a set of criteria is, a management strategy can always be arrived at that checks all of the obligatory checkboxes, but whose outcome (e.g., a UMP) ultimately leaves all stakeholders worse off than if there were scarcely any criteria at all (i.e., in which case entirely new criteria are inevitably adopted). A hammer can be used to drive a screw, but what you end up with doesn’t look or function like a screw or a nail.
APA Act and APSLMP provide a design — including a set of administrative criteria — for achieving a specific and *predetermined* outcome (for those who don’t like the term “predetermined”, we can say “planned”). If we start trying to reappropriate a design, however well thought out, for something that the original designers did not have in mind, then we would be better served by considering a different design.
Back to the topic at hand, if we’re really so keen on expanding access to Wild Forest areas, the original vision of APA and the interests of all stakeholders involved will arguably be better served by considering another designation or design, where the allowed densities of development and infrastructure can be better balanced against the constellation of social, psychological, physical and ecological considerations that comprise “wild character”.
Whatever we do, first, we must at least realize and acknowledge the inherent trade-offs that are made with every management decision (something we don’t do enough). Second, we should be reconciling those decisions with the effects that they will have on larger levels. And third, we need to be careful now more than ever not to fall into the trap of hubris. Whatever management gains are made by technological or theoretical advancement are always offset by new challenges posed by those same advancements. In the end, nothing can offer an escape for us from hard and arbitrary choices, but planning and design can channel those choices into something that eventually becomes less arbitrary. If there is a silver lining to the APA’s sudden urge to decide on the issue at hand, it is that the most arbitrary choice of all is pretending not to have any plan at all.
JB, what is needed, if you’re not satisfied with the APA/DEC proposals, are alternative concrete counter proposals. Just harping and expressing opinions on the shortfalls of the existing proposal and not offering alternative concrete solutions is counterproductive and doesn’t move us forward. An alternative proposal should be concise, and include statement of problem, goals, methods, timeline, rough cost comparison/cost benefits (manpower, equipment and operation, etc.) and the disadvantages vs advantages to the APA/DEC proposal. If you already had provided to APA and DEC a counter proposal, could you kindly share it with us?
I surmise that one of the main reasons that the APA and DEC have chose to concentrate on MILEAGE, rather than on USE, is that MILEAGE is easy to relatively cheap to measure and is mostly already available, whereas there are incomplete or insufficient data USE data, and collecting, compiling, and analyzing that needed new USE data would require a lot of time and manpower such as installing maintaining a data-collection network. One may have a difficult time selling an expensive alternative approach if the benefits are not perceived to be that much better.
Todd, I certainly do have a number of concrete counterproposals! I’ve tried to include some of them in my comments here. All of them involve possible ways to measure and regulate mileage in a way that better reflects use and other guidelines from APSLMP, and none of them involve collection of new data or an unreasonable amount of analysis by APA GIS staff. I suppose I could make it an open letter, but hijacking the comments section under any of David Gibson’s masterful articles doesn’t seem like the most tasteful way to do that. Hopefully I’ve at least made clear why I don’t think that a percent cap above a blanket mileage for the entire Park is most faithful to APSLMP. Do you? I’m always happy to hear critiques.
Glad to hear that you do have concrete proposals. I wasn’t exactly clear where I can view them. Are they scattered throughout this thread? Any chance that they are posted in one document on the APA website. And these proposals include most of the elements I mentioned such Statement of Problem, Goals, Methods or Approach, Costs and Cost Benefits?
To answer your question. I think relying more on use rather than a cap on mileage is more appropriate. However, the details on what use data is available and how much more needs to collected (and the costs to collect, compile, and analyze the use data) need to also be factored in the cost benefits. That is I I’m interested in seeing the details in your proposals. If it’s going to cost 10-25 times more than the cap on mileage approach, then maybe that much less costly approach is good enough. The devil is in the details.
Eventually all public comments are usually uploaded to the APA website. Yes, mine will be a list expanding upon everything I’ve said above. I was hoping that the virtual public information meeting would have been better advertised and more conversational (Q&A). Maybe the in-person meeting can be like that.
I’m not sure that I understand your idea that considering use is more expensive than only considering mileage. Sure, I could imagine that building a time machine to go back to 1972 and measure historic use levels would be very expensive. In reality, I don’t think there are any here who have seriously expressed a need for establishing an empirical metric for historic use levels. Most arguments made here have been in favor of moving away from (though not completely abandoning) hard empirical metrics, not establishing new ones.
Rather, what is being stated is that “mileage of roads and snowmobile trails open to motorized use by the public in wild forest areas” is an obvious proxy for use. Under APA’s organizational duties, that term (“mileage”) merely needs to be defined as such — a process in and of itself that will cost next to nothing — and, thanks to decades of work by a very small APA staff, all of the historical data needed to do this has already been digitized.
The day-to-day work of planning and management agencies does not involve the type of strict scientific process that you seem to be describing. Maybe you could make some argument that it should, but only up to a point of diminishing returns. Science is focused on metrics because, if we’re being honest, that’s all there is — metrics are the outcome. In planning and management, metrics are secondary and subjugated by the outcomes, which are policy and implementation.
As to your concern about “cost”, one could go so far as to declare that what “costs” the most, by far, is policy implementation, not policy creation — whether that takes the form of more access restriction (gates and enforcement) or taking the uncommon step of destroying closed roads (as Lee suggests). Of course it is true that the cost of implementation depends on the policy being implemented. But, in this case, any misplaced fixation upon the “cost” of policy has little to do with your concern about the definition of “mileage” (and/or “use”) and everything to do with the definition of “no material increase” — i.e., the levels of acceptable change regardless of how change is defined.
Now, all of this nonsense aside: Should planning agencies reject their mandates when the “costs” are too high? Any discussion about “cost benefit analysis” in regards to Park planning and management is a big fat red herring. The Adirondack Park is not a business. Or at least it wasn’t designed to be. If it costs too much for APA and DEC to faithfully carry out their duties, either they need more funding or they aren’t doing it right. Period.
JB, I took some time away from this thread to enjoy the outdoors on this beautiful weekend. I hope you did, also. I’ve also concluded that that is a chasm between our thinking and we’re just spinning wheels in place and going nowhere. From the lack further reader’s comments for some time, I think others have also tired of our back and forth. Therefore, I’m ending my communication.
Unfortunately, whatever roads are allowed frequently get used for other things than were intended. Snowmobiles and ATVs can easily get around most gates and often do, and I have encountered them on old roads that are now supposed to be trails. Witness what happens at Crane Pond for example. https://andyarthur.org/crane-pond-road-in-my-pickup.html
A “closed” road is one on which the surface has been scarified and on which native vegetation has been installed and is being maintained. There should be signs and barriers to protect the planting, but they should be temporary. Leaving a road passable, then “closing” it with gates and signs is, at the least, subject to change by future administrators and, honestly delusional. The gate just makes it a road for some to use, but not others.
It is true that restricting use on a road may be appropriate to address certain types of impacts (seasonal closures for wildlife, for example), but again, that is temporary. The roads is there, subject to expanded use if policy changes, and with many of the same impacts (hydrologic impacts, for example, are a function of how the road is built far more than its level of use).
The question goes back to context and goals. Why is the road there? How does that implement (or not) our goals? If the goals are sufficiently clear and detailed, the question usually isn’t hard to answer and public discussion can be aimed at what are difficult, but tangible, questions. The overall mileage of roads is just an abstraction. Changes in that abstraction – minor or otherwise – are also abstract. A genuinely productive public discussion of this issue would focus on specifics.