AWA Weighs in on Proposed State Land Master Plan Amendments

Help us to protect Wilderness!

November, 2024

Dear AWA Supporters:

The Adirondack Park Agency recently released draft language amending the Adirondack Park State Land Master Plan (SLMP). Second only to Article XIV, the “Forever Wild” constitutional amendment, The SLMP is the most important document for protecting the Forest Preserve.  So when the APA proposes changes to the SLMP, those changes bear the strictest scrutiny.

Adirondack Wilderness Advocates has been fully engaged in reviewing the APA’s draft language and advocating for the changes we think are critical to maintaining the highest protection for Wilderness. We have attended all three public comment sessions and we are preparing extensive written comments.  We are also circulating a petition opposing motorized devices in Wilderness, because two loopholes in the draft language could allow motors in wilderness at the discretion of the Department of Environmental Conservation.  Motorized access in Wilderness would be a violation of one of the most fundamental tenets of wilderness protection.

We hope that you will get involved too!  Help us protect Wilderness from potentially dangerous policy changes.  You can do so in two important ways.  First, you can sign our petition on motorized devices, available here.  Better still, you can supply your own written comments to the APA. Information on the proposed changes to the SLMP can be found here (https://apa.ny.gov/Hearings/ApaCommentPopup.cfm?ProjectNumber=APSLMP2024). Written comments can be sent via regular mail to Megan Phillips, Deputy Director of Planning, Adirondack Park Agency, PO Box 99, Ray Brook, NY 12977 or they can be emailed to [email protected]

If you email comments, please include “Project APSLMP2024; Adirondack Park Agency ; Megan Phillips” in the subject line to ensure they are routed properly.

The deadline for submitting written comments is December 2nd

Areas of Concern in Proposed Changes to the State Land Master Plan

AWA has identified four areas of concern in the proposed changes to the SLMP.  Our written comments will spell out our interests and recommendations in more detail, but here is a summary of each area:

Visitor Use Management

The APA is proposing new language in support of Visitor Use Management (VUM) as the new paradigm for managing park users. Some environmental groups have raised concerns that VUM supplants carrying capacity as a wilderness-protection methodology, instead establishing a “slippery slope” that prioritizes recreational access and use over protection of the resource. AWA is a champion for VUM because we see it as the most effective tool for addressing the dynamic challenges that most threaten wilderness.  AWA, along with the Adirondack Powder Ski Association, Adirondack Wild and Paul Smiths VIC, has been operating the Jenkins Open Woods Skiing VUM project for three years, and regularly engaging with the APA and DEC to demonstrate our use of VUM and the principles behind it.

VUM is a responsive and adaptive tool well suited to addressing everything from invasive species to climate effects to trail deterioration to spikes in visitor usage.  However, VUM is only a tool and must not be confused with Wilderness policy. AWA was a member of the High Peaks Advisory Group (HPAG), which recommended adoption of VUM. That recommendation, and all other recommendations, were made subject to guiding principles which were enumerated at the beginning of the recommendations section. Guiding Principle #1 is protection of the Wilderness.  

We support the APA’s draft language on visitor use management in spirit, but we call for a clear statement that VUM will be used in Wilderness areas only in a manner 100% consistent with Wilderness policy and with protection of the Wilderness as the highest guideline.  

Motorized Devices on Foot trails / Wilderness Areas

AWA supports public wheelchair access on any foot trail in the Forest Preserve, including battery-powered wheelchairs, as defined in the Americans with Disabilities (ADA) ACT, Title V, section 508. In that section the ADA defines a wheelchair as “a device designed solely for use by a mobility impaired person for locomotion, that is suitable for use in an indoor pedestrian area.” We added italics for emphasis: that phrase makes it clear that larger devices designed for outdoor use, devices that would destroy the Wilderness aesthetic and damage wilderness ecology, are excluded.  

Other than wheelchairs as defined by the ADA, AWA opposes public motorized access in Wilderness areas, period.  The APA’s current draft language allows for discretionary use of so-called “Other Power-Driven Mobility Devices (OPDMD’s), including carts and ATV’s.  These devices are contrary to both the letter and spirit of wilderness and are not necessary to equitable access to Wilderness.  Signing our petition will help us urge the APA to revise the language and exclude motorized devices other than wheelchairs from our Wilderness areas.  

No matter what the final adopted language looks like, this issue will continue to bear close scrutiny.  EVE technology is fantastic and incredibly beneficial for our climate, but the nature of the electric motors, batteries and intelligent software that comprise the state of the art in EVS allows for the design of vehicles with unprecedented abilities to navigate wild terrain.  Vehicles that can operate on trails the average hiker would never imagine could be traversed by a motorized device will become widely available. Electric motors operating independently on each wheel, automatic adjustments of balance points and ground clearances, and other features make current-off-road vehicles primitive in comparison.  This new generation of devices must be carefully assessed.  Adopting too broad a definition of approved motorized devices in the SLMP now could prove to be disastrous. 

Beaver Control Structures

Proposed language in the SLMP would allow the construction and maintenance of beaver control structures to protect trails, front country infrastructure, roads and more. AWA does not oppose beaver control structures, but we are opposed to their use in Wilderness: as our vice chair Kayla White stated, “In Wilderness we should be changing our behavior in response to beaver activity, not the other way around.”

Non-Conforming Structures

The APA has proposed revisions to the guidelines on removing non-conforming structures in the Forest Preserve. These revisions eliminate all deadlines for removing structures that are currently contained in the SLMP.  We agree that removing language concerning missed deadlines that go back decades in some cases years is perfectly sensible.  However, the APA’s replacement is to allow removal, including with motorized equipment, in an open-ended and “case by case” manner, with the APA as arbiter.  AWA opposes open-ended and discretionary use of motor vehicles in the Wilderness.  We call for the SLMP to require a comprehensive plan with a complete inventory of non-conforming structures, an assessment of the value of removing each, a proposed method, whether motorized equipment would be necessary and a dealine for each.  Those could be accomplished in a variety of ways, for example  as part of an updated 2010 DEC/APA MOU. 

AWA will post our complete written comments when they are available.  

Thanks as always for contributing to the protection of Adirondack Wilderness.  

We are grateful for your engagement and support!