posted by
Property Rights Foundation of America®


P.O. BOX 718

February 6, 2006

Mr. Francis Sheehan
NYS Dept. of Environmental Conservation
625 Broadway
Albany, New York 12233-4250


Dear Mr. Sheehan:

I trust you have received my comment letter regarding the "NYS Open Space Plan," which I express-mailed to your office on January 13th and which was guaranteed to arrive by the due date of January 18th.

In my telephone call to you, I had requested that you extend the time for public comment. The time given spanned the season from Thanksgiving through New Year, when many people are busy with the holidays and/or must take care of end-of-year business details. In addition, as you well know, the document is more than 400 pages long, plus appendices.

It was not an acceptable answer which you gave me, that DEC would "informally" extend the comment period. Impenetrable as the SEQR law is to the public, even to someone such as myself who has a very high threshold of boredom, I do know enough to abide by its legal deadlines.

I do not appreciate your telling me that I sounded like one of your teenagers who couldn't finish her homework on time. I sincerely doubt you would have made that kind of patronizing and insulting remark to a male caller.

For your information, I am one of the few people who has followed this whole sorry "Open Space" process since it began in 1990. Even one of the Adirondack Park Agency Commissioners, a Manhattan attorney and a member of one of those environmental lobbying groups that hold lifetime membership seats on the Committees, knew nothing about it. And from their discussion at the APA meeting in January. I gathered that few other Commissioners were the least bit cognizant of it either.

My comment letter will show that I had painstakingly compared the draft Plan to the previous version from 2001-02. This comparison provoked a number of detailed questions on the many disturbing changes I found. I had to submit a Freedom of Information law request to discover the origins of the "Conservation Partnership Program," and did not receive the information in time to add it in to my comment letter. I am still awaiting FOIL requests to the Department of State on the "Coastal and Estuarine Program" and to the NYS Office of Parks, Recreation & Historic Preservation for further analysis of their SCORP documents. In fact, just last week I sent follow-up letters to those two agencies stating that I have not yet received responses.

My comment letter contains numerous questions on those designation programs, references to which are scattered throughout the un-indexed Plan, as well as questions regarding the vaguelt-titled broad-brush sweeps of land in the Plan such as "Heritage Areas," "Ecological Corridors," "Greenbelts" and "Complexes."

If you require more time to fully respond to my list of 60 questions and comments, please be assured I will treat your request with more seriousness than you did mine. Also, please advise me of my recourse in the event DEC does not satisfactorily respond to my comment letter.

I am sending a copy of this letter, along with my original comment letter, to my State Senator.


Susan Allen

cc: Sen. Elizabeth O'C Little


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