NYSDEC Draft Policy for Construction in the Forest Preserve

[Dave Bourque]

Draft Forest Preserve Work Plan Policy (ny.gov)

[tgoodwin]

I guess someone should make a comment on this plan. Pasted in below is the comment I have sent to the DEC Forest Preserve Advisory Committee.

COMMENTS ON CP-XX/FOREST PRESERVE WORK PLAN POLICY
by
Tony Goodwin
Member of the Forest Preserve Advisory Committee and
Retired Director of the Adirondack Trail Improvement Society

First of all, I recognize the need for such a policy at this point in time, and I believe that this draft policy meets that need.

I believe, however, that there should be more specificity on when an "Ordinary Maintenance Work Plan" is required. The policy states that 'Work Plans' will not be required for projects conducted by organizations that are included in stewardship agreements such as a VSA, but still seems to require a 'Work Plan' if any "earth moving" is required. My question is whether the amount of earth moving required to build a basic rock staircase on a wilderness trail rises to the threshold of requiring a plan. The proposed plan does have a stated threshold for when a tree count is required ("i.e. no more than one tree or edge tree per 300 feet"), but digging pits in the trail and quarrying native rocks does require some 'earth moving". Any way to describe how much is acceptable without a plan?

Maybe the final plan could provide some clarity to the conduct of this important technique used to create more sustainable trails.

[I unfortunately can't resist a final 'grump' (that doesn't need to be in this comment as finally included). It seems we now need 13 pages of policy to describe what my father could accomplish with one letter/phone call to Billy Petty, then DEC Region 5 Director, when my father wanted to build the current Brothers Big Slide Trail, the Hedgehog Trail, and the Giant Ridge Trail. Can anyone imagine these trails not being there or believe these trails have in any way caused any environmental problem?]

[TCD]

I let this sit for several days, waiting to see responses.

Thanks, Tony, for your thoughtful response. Of course you are right.

I think I am more cynical than you. I think the creation and implementation of a "policy" like this is for only two purposes:

1. Give bureaucrats something to do so they can waste more of our money;

2. Provide "political cover" for bureaucrats when they get nothing useful done for years on the ground, in the real world.

This is just more of the same. I didn't bother to comment; the "comment" process has been a joke for the past couple years. Nothing will change until all leadership changes (from the governor on down), and then about ten years of housecleaning gets done. I will be done hiking before that happens.

[billconner]

Thank you all for your time. Following this.

[adkjack]

As we have the VSA for the Mt. Adams Trail and Fire Tower, I have read this several times over also. I’m in agreement with Tony about the need for a uniform oversight in some fashion but as usual when developing such a plan the devil is in the details. There are at least two areas currently on the Adams trail that will require some earthwork ie stone step or minor reroute (less than 10’ ) due to erosion over the last decade as volume has increased significantly. I have just recently provided an overview notification of typical maintenance plans for the year. I suspect that a more detailed plan may be required for those sections which I have no problem in providing as the work and effect to the current trail is minimal. My concern is turn time for approval or denial. As an all volunteer effort scheduling these projects in advance is daunting enough to get helping hands, usually on weekends so it could be difficult if the process is a lengthy one. Currently my plan is to get to Mt. Adams as early as possible to asses trail and tower work needed for the summer when there is minimal snow cover. Then provide a synopsis with descriptions, location and photos of areas of concern and present the to the Forester