Rights Foundation of America®
P.O. Box 718
Keene Valley, N.Y. 12943
August 28, 2009
Adirondack Park Agency
P.O. Box 99
Ray Brook, N.Y. 12977
Attn: Richard Weber
I make the following statements in opposition to the Lows Lake
- Dams, roads and private inholdings contradict the description
of the area as "Wilderness." It can never be a Wilderness
as long as these exist.
- Manmade lakes, such as Lows Lake, cannot honestly be considered
as part of a "Wilderness."
- The State Land Master Plan has not been updated for nearly
25 years. This needs to be done prior to any actions on classifications,
Unit Management Plans or any DEC/APA "policies," as
all of these are inherently intertwined.
- Unit Management Plans can always be revised by the APA; just
because some action was taken in a prior UMP does not mean it
cannot be rescinded or amended.
- Unless the State of New York owns the entire beds of the
lakes and rivers, and the entire shorelines surrounding them,
Lows Lake and the other waterbodies cannot be classified. APA
staff James Connolly stated at the June 2009 APA meeting that
classifying the waters of Lows Lake was a "progression"
in the way the APA treats waterbodies. No government agency can
rule by establishing incremental "progressions" absent
the proper legal processes. This is a dangerous precedent that
harks back to the DEC's and/or APA's unilateral determinations
on all-terrain vehicle prohibitions and definition of "roadside
- The recreational use study commissioned by DEC and/or APA
showed little or no user conflicts on Lows Lake between motorized
and non-motorized uses, giving less rationale for creating a
classification that would banish certain user groups but not
others. The results of that study should be taken into account.
- The "Timeline" of Lows Lake contained several statements
that the lake is dangerous for canoes, giving less rationale
for establishing it as part of a "Wilderness Canoe Route."
- The "Timeline" contained a later entry stating
that the number of campsites designed for canoeists' use was
being increased, exhibiting a bias toward accommodating one user
group while denying others.
- The APA Act states that economic issues have to be considered.
As co-owner of Adirondack Maps, Inc., which publishes maps of
that area, I have direct knowledge that hiking and canoeing activity
is confined to the warm months of early summer through early
fall, while hunters and anglers extend the seasons on both ends,
and addition of snowmobiling would make it a true year-round
recreational area. The economic effect of all types of recreation
on the communities cannot be ignored.
- The State Environmental Quality Review law requires that
every issue that is identified by the public must be addressed,
not dismissed without comment.
This process is not supposed to be a popularity contest, where
whichever point of view gets the most comments wins.