Property Rights Foundation of America®
PROPERTY RIGHTS FOUNDATION OF AMERICA, INC.
P. O. Box 75
Stony Creek, NY 12878
September 16, 2010
Adirondack Park Agency
P. O. Box 99
Ray Brook, NY 12977
E-mailed to: firstname.lastname@example.org
Josh Clague, DEC
625 Broadway, 5th floor
Albany, NY 12233
E-mailed to: email@example.com
Re: Moose River Plains - Comment on DEC-APA Revisions to State
Land Master Plan & UMP
Dear Mr. Weber and Mr. Clague:
This letter is to clarify and add to my official oral comments
at the Indian Lake Central School on August 16, 2010 on the DEC/APA
proposed revisions to the State Land Master Plan (SLMP) and the
Unit Management Plan (UMP) for the Moose River Plains Wild Forest.
I request that you take my comments into account and withdraw
the proposed plans, and also include this letter in the complete
formal record of the comments on these proposed revisions to the
- New York State Conservation law and the agreement with the
Gould Paper company state that the Gould property was acquired
as a gift for the purposes of fish and wildlife management and
that the area was to be known as the Moose River Recreation Area,
to be used as a recreational area for hunters, fisherman and
sportsman, and that the Moose River tract shall not become part
of the Forest Preserve.
- When the lands were conveyed according to that agreement
with the Gould company, they were purchased with restricted New
York State Recreation funds. Both the agreement and the Recreation
funding were designated to creating roads, access, and campsites,
and maintaining these for the use of sportsmen and women and
others. The closing of roads, access, and campsites contemplated
in the revisions to the SLMP and UMP would violate the terms
of the agreement and the legislative purpose of the Recreation
- Therefore, the tract should be maintained for these recreational
uses and none of the campsites, bridge(s) or other stream crossings
or roads closed.
- Neither the Otter Brook Road nor Indian Lake Road should
be closed. These roads should not be converted to hiking or horse
- Both Otter Brook Road and Indian Lake Road should be maintained
as motor vehicle roads.
- The plan to reduce the number of campsites from a stated
number of 170 to 83, with a future possible plan for 150, should
- Instead, all of the current campsites should be maintained,
sanitation and staffing improved, and additional campsites added.
- At a minimum, the original number of over 200 campsites that
were established in the Moose River Plains should be restored.
- The plan to separate the parking of vehicles from the actual
campsites should be rejected.
- In is essential that campsites be immediately adjacent to
the area where the vehicle used by the particular camping group
is parked, for accessibility and security.
- The plan to close 49 miles of snowmobile trails and create
14 new miles should be rejected, even if the new trail mileage
is a connector trail.
- No snowmobile trails should be closed. The connector trail
should be added also.
- Float plane access should be maximized.
- The plan to convert 15,062 acres of the Moose River Plains
Wild Forest to Wilderness violates the terms of the Gould purchase
and funding and other law.
- The plan to make this huge conversion of land to Wilderness
is the most mean-spirited feature of the shell game that
this entire voluminous proposal is about. Measly so-called benefits
are proposed, such as the string-like strip one-tenth of a mile
wide on each side of Cedar River Road (totaling only 2,925 acres)
to be converted to a new Intensive Use, are highlighted, while
a massive amount of use by families, senior citizens, and sportsmen
and women is sought to be wiped out.
- In addition, there is the campsite shell game, the snowmobile
trail shell game, and so on.
- It is ironic that the agencies are comfortable to propose
revision to the State Land Master Plan to effectuate these nasty
pretexts at compromise, but in other contexts of the consideration
of the Moose River Plains and other UMPs, the State Land Master
Plan, which the agencies themselves created, is sacrosanct.
- The proposed plans amount to a betrayal of the public trust.
Sly games and ruses are the heart of the proposed plans.
- None of the land within the Moose River Plains Wild Forest
should be converted to Wilderness.
- The tract does not fall under any UMP or SLMP, as it is a
separate entity and was written into law as such.
- The disposition of the gravel roads was settled in New York
State Court and the State has no power to close any of them.
- The proposed revisions to the SLMP and UMP should be reissued
to abide with the terms of the Gould agreement and the provisions
of New York State statute under which the purchase was funded.
- Alternates for any changes that are proposed should favor
public access and use.
- The plans should be revised to improve access, to restore
campsites and roads to increase public use, and a declaration
of joint APA-DEC policy made to reject any additional land acquisition
so that state funds are concentrated on staffing, desperately
needed sanitation and maintenance, and improvements to better
serve the public who would like to enjoy the State-owned forest
land in the beautiful Adirondacks.
- The environmental impact analysis is incomplete and cursory,
failing to meet the requirements of SEQRA.
- The proposed revisions to the plans are discriminatory, favoring
the use of the State-owned land in the Adirondacks for one group
to the omission of other groups who are citizens and taxpayers,
and entitled to the use of the State-owned land as much as the
- The proposed revisions to the plans are discriminatory by
favoring the cultural history related to one select group to
the diminishment of and omission of the traditions of the people
who generally are the established users of the Moose River Plains
Recreation Area and the historic residents within the Adirondack
- The proposed revisions to the plans discriminate against
- The proposed revisions to the plans are in violation of State
law because they purport to rely on compliance with an outdated
State Land Master Plan, which is, in itself, in violation of
- The proposed revisions to the plans comprise the misuse of
In addition, I demand a specific reply to every comment in
my August 16, 2010 statement and this letter.
Carol W. LaGrasse
President, Property Rights Foundation of America, Inc.
And, as an individual,
A citizen of the State of New York and the United States of America,
A senior citizen,
A New York State taxpayer,
And a resident of the Town of Stony Creek within the Adirondack
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