Property Rights Foundation of America®
Founded 1994


P. O. Box 75
Stony Creek, NY 12878
(518) 696-5748

September 16, 2010


Richard Weber
Adirondack Park Agency
P. O. Box 99
Ray Brook, NY 12977
E-mailed to:

Josh Clague, DEC
625 Broadway, 5th floor
Albany, NY 12233
E-mailed to:

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 plans.

  1. 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.
  2. 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 funds.
  3. Therefore, the tract should be maintained for these recreational uses and none of the campsites, bridge(s) or other stream crossings or roads closed.
  4. Neither the Otter Brook Road nor Indian Lake Road should be closed. These roads should not be converted to hiking or horse trails.
  5. Both Otter Brook Road and Indian Lake Road should be maintained as motor vehicle roads.
  6. The plan to reduce the number of campsites from a stated number of 170 to 83, with a future possible plan for 150, should be rejected.
  7. Instead, all of the current campsites should be maintained, sanitation and staffing improved, and additional campsites added.
  8. At a minimum, the original number of over 200 campsites that were established in the Moose River Plains should be restored.
  9. The plan to separate the parking of vehicles from the actual campsites should be rejected.
  10. 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.
  11. 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.
  12. No snowmobile trails should be closed. The connector trail should be added also.
  13. Float plane access should be maximized.
  14. 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.
  15. 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.
  16. In addition, there is the campsite shell game, the snowmobile trail shell game, and so on.
  17. 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.
  18. The proposed plans amount to a betrayal of the public trust. Sly games and ruses are the heart of the proposed plans.
  19. None of the land within the Moose River Plains Wild Forest should be converted to Wilderness.
  20. The tract does not fall under any UMP or SLMP, as it is a separate entity and was written into law as such.
  21. The disposition of the gravel roads was settled in New York State Court and the State has no power to close any of them.
  22. 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.
  23. Alternates for any changes that are proposed should favor public access and use.
  24. 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.
  25. The environmental impact analysis is incomplete and cursory, failing to meet the requirements of SEQRA.
  26. 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 favored group.
  27. 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 Blue Line.
  28. The proposed revisions to the plans discriminate against senior citizens.
  29. 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 State statute.
  30. The proposed revisions to the plans comprise the misuse of taxpayer funds.

In addition, I demand a specific reply to every comment in my August 16, 2010 statement and this letter.

Thank you.

Yours truly,

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 Park


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