Essex Chain Lakes Management Complex Draft Unit Management Plan
Public Comment Opportunity
Complete information can be found by clicking here to open the DEC page about this plan.
Doug's formal comments to the DEC are posted below. Be sure to send your own comments before the 7/25/2014 deadline.
July 17, 2014
Josh Clague, Natural Resources Planner
625 Broadway, 5th Floor
Albany, NY 12233-4254
RE: Essex Chain Lakes Management Complex - Draft Unit Management Plan
Dear Josh Claque:
This letter contains my comments on the Essex Chain Lakes Management Complex - Draft Unit Management Plan. I found the plan to be well written and comprehensive. Although the plan is moving quickly, it is obvious that a lot of effort has been expended to put it together. Overall the plan has many positive proposals that I support, it also has some proposals that concern me and may even be precedent setting. These comments reflect my thoughts on both what I see as positive about the plan and what I am apprehensive about. In all cases these remarks are offered as practical and constructive comments.
II. NATURAL RESOURCES AND PUBLIC USE
Please note that while exploring the area last fall I identified a stand of Phragmites near 8th Lake. It is just off the four-wheeler trail that leads to the lake.
N 43 degrees 53.019’
W 074 degrees 13.352’
The following is quoted from the Public Use section:
“However, fishing will likely be a popular activity.
The Essex Chain Lakes and surrounding water bodies are fairly accessible. As access to this area is improved, fishing pressure can be expected to increase in the short term. Experience with similar acquisitions, such as the Whitney Wilderness Area in 1998, suggests that public use will begin to level off as public curiosity is satisfied.”
This statement is significant to the public’s use of the area in general, not just in regards to fishing. It seems that many of the more restrictive proposals in the plan are based on concerns about the level of use in what could be termed the “curiosity phase”. Indeed public use of areas such as Whitney, Lows Lake and Lake Lila have leveled off. Over time, the more restrictive proposals in this plan will not be necessary or even relevant. It may be argued that in the future the plan could be amended and restrictions eased, but we all know that this is difficult to do and rarely happens once a plan is in place.
I urge the Department to use natural barriers in place of gates wherever possible. Even as of last fall there seemed to be an over proliferation of gates in this complex. These man-made structures should be carefully considered with natural barriers such as rocks, timbers and plants used whenever feasible. As “old roads” become impassible to vehicles existing gates should be removed.
B.2. Motorized Access and Parking Areas
a. Near Hudson River and Iron Bridge
Moving this parking lot closer to the Hudson River is a practical and sensible decision.
b. Deer Pond
Although I recognize that parking lot size can be utilized to control public use, parking for 10 day use vehicles and 15 overnight vehicles at this site is totally inadequate. Due to the widespread use of small solo boats now commonly paddled in the Adirondacks, even most small groups will have multiple vehicles just to transport their boats. The parking inadequacies of the Lows Lower Dam site is a prime example of what occurs when the parking capacity of an area is undersized as related to the actual carrying capacity of the area being accessed. There is plenty of room for adequate parking at the Deer Pond site, please use it to expand on what is proposed.
c. Outer Gooley
Designation of a 6 vehicle existing parking area in the vicinity of the former Outer Gooley Club is a practical and sensible decision.
b. Camping Permit System
Although I personally always carry a cook stove and use it for almost all my cooking in the backcountry, I still find that the prohibition of fires on the shoreline sites in the Essex Chain is an unnecessary rule. I believe that the campfire ban in the Eastern High Peaks was a practical and necessary management tool and has made a difference there. The situation there is much different than what is found in the Essex Chain. The High Peaks have been heavily used for decades and camping use is year round. In addition the forest types found there differ greatly and are more fragile than those found in the Essex Chain. I have camp in many of the Forest Preserve units that are primarily accessed only by canoe and kayak users. In all cases I have rarely if ever seen the degradation mentioned in the 32 year old citation from Cole, Dalle-Moll. In fact I believe that the conditions stated in the opening paragraph of this section describe more front country locations than they do back country. It is fair to point out that camping on these sites will primarily take place during the short warm season in the Adirondacks. There are many months each year when these site will lay fallow and rest.
I have camped in Algonquin Provincial Park in Ontario and the Boundary Waters Canoe Wilderness Area in Minnesota. Both those places have existed for decades and receive much more use than the Essex Chain will get. Fires are still widely used in these places and there is little sign of the degradation that is feared to occur here. In the Boundary Waters fires are kept very small by a regulation that restricts their location to within the small iron fire grate that is permanently installed at each campsite. I realize that there are those in the DEC and the APA that would feel these types of units do not meet the natural standards set forth in the APSLMP, but if they were to see these units in action they would feel differently.
In addition to all this, the regulations proposed in the plan regarding fires are confusing. Some places they are allowed and some places they are not. The public will struggle to understand and accept the differences.
VI. DETAILED MANAGEMENT PROPOSALS
1. Public Motor Vehicle Access
I am please to see that providing access to both the Chain Lakes and primitive area trails for persons with disabilities is a priority.
The CP-3 parking area to be located west of Fifth Lake is ideally sited. In fact when I explored the area last October I identified that same area as a possible location for this use. I also support and am pleased with the proposals outlined in section 4. Accessibility.
c. Mountain Biking
I am pleased that the Chain Lakes Road (North) and the road to the Iron Bridge have been temporarily designated for mountain bike use through September 30, 2018. I encourage the Department to expand mountain bike use during this period to all the trails identified on Map 10. Equestrian and Mountain Bike Use. Further, I strongly support the permanent designation of mountain bike trails on all the units in this Management Complex.
The lean-to site on the north end of Tirrell Pond in the Blue Mountain Wild Forest is an example of the degradation that can occur on campsites used by floatplane customers. With the concern about user impacts on other campsites in this complex it is important that the floatplane only sites be closely monitored and the exclusive use of them be re-examined periodically. Language calling for this review should be added to the plan.
Additional management considerations
In order to properly maintain and fund the stewardship of this complex I strongly encourage Lands and Forests to work with the Division of Operations to establish a Maintenance Management Plan to be included in section VI of this plan.
The number and variety of new user policies and restrictions proposed in the plan will be confusing to the public. I encourage the Department to streamline and standardize the rules and regulations proposed for the different units in this plan. In almost all cases the current Forest Preserve regulations, if properly enforced, are adequate to address user impacts
As former commercial forest lands with a complete network of roads, the character of this complex well fits the classifications that have been assigned to the various parcels. I am pleased that this plan allows a diversity of citizens and user groups to access the property. People with disabilities will be well served by allowing the access outlined in this plan.. The road network is a fantastic resource for mountain biking and I am happy that this activity is being study for permanent inclusion in these areas.
Thank you for consideration of these comments.
NYS Licensed Guide