ADK’s Comments on the High Peaks and Kaaterskill Clove Project Area Visitor Use Management Pilot Projects

The Adirondack Mountain Club (ADK) welcomes the release of the High Peaks Project Area Final Recommendations Report and Monitoring Plan. ADK supports and applauds DEC’s science-based efforts to help ensure the protection of resources, improving safety, and enhancing visitor experience. Though there is still more work to be done, and ADK supports the process continuing.

Based out of the Adirondack Park, surrounded by the High Peaks Wilderness, ADK is the leader in providing outdoor education, promoting responsible recreation, and organizing stewardship experiences. Since 1922, the organization has worked to increase access to the backcountry by building trails, conserving natural areas, and developing a stewardship community that supports the ethical and safe use of New York’s outdoor spaces. A member, donor, and volunteer-supported organization, ADK reaches across New York through its 25 chapters to inspire people to enjoy the outdoors ethically.

High Peaks Project Area

In the Adirondack High Peaks, ADK plays a critical role in responsible outdoor recreation education and frontcountry infrastructure. These services happen nowhere else in the region and must be part of a multi-faceted solution to adverse impacts from visitor use. Therefore, we will continue to collaborate with DEC in strengthening support systems and infrastructure to reduce stress on the High Peaks region that will meet the overall goals of visitor use management. A commitment to solutions that preserve access by investing in stewardship programs, physical improvements, and visitor education is a critical and yet to be fully realized opportunity.

The trailhead at the end of Adirondack Loj Road at Heart Lake is the busiest backcountry trailhead in the state of New York. In recent years ADK has seen over 100,000 visitors annually—visitation numbers that are supported by the High Peaks VUM Report as well as over 30 years of data collected and analyzed by the ADK and DEC Adirondack High Peaks Summit Stewardship Program. ADK has managed the High Peaks Information Center (HPIC) for over 50 years at this very popular site to orient recreators, keep them safe, and inspire actions that motivate visitors to protect the Forest Preserve.

ADK’s infrastructure and Leave No Trace certification as one of 12 nation-wide Level 2 providers play critical roles in relieving ecological and environmental pressure in the Forest Preserve. At Heart Lake ADK ensures visitors receive essential services including bathroom facilities, gear and maps, trip planning guidance, and Preventative Search and Rescue (PSAR) education. ADK’s Leave No Trace certification ensures Leave No Trace principles are disseminated and incorporated into every interaction with visitors.

Area-Wide Report Recommendations for the High Peaks

ADK supports many of the elements of the Area-Wide VUM Report and recommendations for the High Peaks. We are greatly encouraged with Area-Wide Recommendation 1, “Work with key partners to implement visitor information and education strategies.” ADK and DEC have been advancing this recommendation already and currently have an excellent foundation of programs. However, DEC’s ongoing commitment to ADK is critical for overall management of visitor use. Extended and enhanced commitment to ADK’s existing programs and projects is necessary and should be considered as an essential component of any visitor management initiative of New York State.

The Partnership Agreements outlined in this recommendation must ensure that all partners, including municipalities, are supported and compensated for the critical roles they fill throughout the High Peaks system in helping DEC meet its mission of managing and protecting NYS public lands.

Although we do agree with Area-Wide Recommendation 2, “Implement visitor use monitoring for adaptive visitor use management,” we do not fully agree with the strategy outlined in the report.

We fully agree with and urge DEC to move forward with Area-Wide Recommendation 3, “Conduct a formal assessment of the impacts of recreation use on ecological conditions and select ecological indicators for monitoring and adaptive visitor use management in the High Peaks Project Area.” An assessment of ecological conditions should be incorporated into a holistic plan for visitor use management of the High Peaks. As part of ADK’s work with visitors described above, over 30 years of Summit Stewardship data shows that trail maintenance and on-site educational outreach have been the primary driver of Alpine habitat restoration on the High Peak Summits, even in the context of greatly increased use in recent years. Any formal assessments of ecological impacts must include a full partnership with ADK that includes close analysis of ADK’s approach, success, and data.

In Area-Wide Recommendation 4, “Conduct visitor use monitoring and management planning for nearby areas of the Forest Preserve that might be at risk of displacement impacts from managing visitor use in the High Peaks Project Area,” this recommendation voices our concern that limiting use at popular, well-resourced trailheads will result in unintended consequences that will spread impact to sites that are not equipped with facilities and educational resources. Visitor Use Monitoring and Planning should, as the recommendation states, be part of “a unifying framework and approach across the landscape” that covers other High Peaks access points, Forest Preserve Units, and community-based destinations.

Adirondack Loj Road Sub-Region Report Recommendations

ADK has concerns about the Adirondack Loj Road Sub-Region Recommendations. We are very concerned with Adirondack Loj Road Recommendation 1, “Manage daily visitor use in the Adirondack Loj Road Subregion of the High Peaks Project Area to a maximum of 400 visitors per day.” This recommendation is problematic due to limited data and no consideration of other long-standing DEC and partner datasets. It also did not consider all the uses of the ADK parking lot which also serves on-site programming, and short local hikes, like Mt. Jo.

It is preferrable to use and allow higher use at trailheads with infrastructure and education than to push visitor use to other entry points without these resources which will result in greater impacts. There are fewer impacts to natural resources, recreation infrastructure, and visitor experience when there are facilities and educational outreach at trailheads—hikers use restrooms and dispose of waste properly, they stay on trails and do not create eroded areas, and they behave in a manner that respects the experience of other users. ADK’s facilities and outreach at the end of Adirondack Loj road decrease impacts and helps protect and restore the High Peaks Wilderness.

We are also concerned that reducing the number of vehicles allowed on weekends, when the majority of people have time off to spend with their families, will create barriers to equity in access. Furthermore, limiting parking will allow those with more resources to be the first arrivals in parking areas before those driving from a distance.

We are extremely concerned about the unintentional barriers the limits suggested in Adirondack Loj Road Recommendation 1 will create, undermining the ability of the High Peaks Wilderness and the Adirondack Forest Preserve to welcome all.

In Adirondack Loj Road Recommendation 2, “Work with partners to implement a parking management plan for access to the Adirondack Loj Road Subregion,” the recommendation to limit or eliminate parking on Adirondack Loj Road and along Meadows Lane would address safety issues. However, current lots could be expanded or new lots constructed to absorb some of the current overflow, ideally in an area with facilities and education. Also recommended, the use of on-the-road variable message boards and other real-time information technology is a sound strategy that would help visitors make informed decisions about where to park and hike before heading down Adirondack Loj Road.

However, limiting use through a hiking permit reservation system would create barriers to equal access to the Forest Preserve and is premature given that other management options have not been fully implemented, and the biological and physical analysis of the area have not been completed.

In Adirondack Loj Road Recommendation 3, “Work in partnership with the Town of North Elba and other key partners to deploy an on-the-ground parking management team during peak periods,” ADK is greatly concerned that partners are expected to help manage use on state lands without support and additional resources, even if the management action is needed adjacent to state lands on partner property or jurisdiction. It is contradictory to expect partners to ensure the Adirondacks are welcoming and inclusive of all while expecting partners to play an enforcement role in parking or peak use management.

In future VUM efforts in which DEC partners are needed to implement solutions, these partners must be part of the core team identifying solutions and tasked with determining if recommendations are reasonable before a report is completed. This can also help ensure the extent of needed additional resources are considered and incorporated into final recommendations.

Regarding Adirondack Loj Road Recommendation 4, “Deploy an on-the-ground permit check-stations at South Meadows and the Adirondak Loj trailhead,” ADK strongly opposes a permit system and would be unable to use staff to help implement a hiker permit system on or from ADK property. A permit system is the last resort after all other management opportunities have been fully funded and implemented including improved and expanded stewardship programs, infrastructure improvements, and visitor education opportunities.

The Desired Conditions outlined in the High Peaks VUM Report on page 17 states the following: “The opportunities, programming, and information the area offers for public use promote representation, inclusion, and access for all. All people feel welcome, which fosters in them a sense of place for the project area, a desire for making environmentally-sound recreation choices, and a deeper appreciation of and commitment to Wilderness stewardship for future generations.”

ADK remains committed to ensuring access to the High Peaks Wilderness. Any changes to current management of the High Peaks must ensure this popular area remains accessible and welcomes all, with close analysis of socioeconomic related access considerations, as the desired condition above states.

High Peaks Project Area Conclusion

Regarding High Peaks Area VUM Report recommendation of permits as an option for the High Peaks Wilderness: ADK urges that DEC recognize that the best strategies will require a deeper understanding and analysis of what is already working. Existing programs, education, infrastructure, and full staffing have not been fully implemented or funded to date. Permits can be seen as a catch all solution to a complex problem, however there is no quick fix for visitor use pressures.

The essential understanding is that protecting the wilderness of the High Peaks requires looking at all attributes and access points holistically and comprehensively. The social analysis which forms the basis of this report is highly limited. Moving forward with the wrong approach can result in diminishing the experience and accessibility of new visitors and future supporters to New York State’s Forest Preserves. The economic exclusivity of the High Peaks and Adirondacks is growing due to economic trends and could be further exacerbated by the wrong approach.

Regarding data collection and analysis: We are concerned that the parking data used in the current study is based on a very limited dataset. Although the consultants did discuss parking data from ADK, we were disappointed that the many years of trail counter data available for the trailhead at the ADK parking lot, the over 30 years of data collected through the Summit Stewardship Program for visitor numbers and trends on the High Peaks were not included.

These datasets should at least have been considered and discussed as background for the current study. What would have been especially important to discuss in the study is how educational outreach and trail maintenance can improve visitor experience and protect and restore habitat. ADK has restored the Alpine Zone on the very popular High Peak summits by changing the behavior of visitors through education and trail maintenance on the summits. This fact must be included in any future analyses and speaks to the lack of analysis of what is already working to address heavy use.

The study should have also included at least some element of actual experience on the summits, including questions regarding how, if hikers felt crowded during their experience, they might be willing to give up the experience or seek an alternative the next time.

It is important to note that the pictures used in the survey show individuals spread across the view scape on the summit areas. This is strongly contrary to the actual behavior of hikers. Many hikers on the summits are in groups, which is likely to change the perception of crowding.

The High Peaks VUM report focuses on only one aspect of the carrying capacity for the project area within the Eastern High Peaks Wilderness Complex. The social aspect was chosen as the focus of the pilot project given the expertise of the consultants in this area, and the ability for DEC to conduct biological and physical assessments in-house.

We are pleased to understand that DEC is planning to continue studies on the biological and physical aspects of carry capacity for the area. Without weaving the three together, social, biological, and physical, as well as considering a broader area and other entry points to the High Peaks, we do not yet have a holistic assessment of the carrying capacity of the High Peaks Wilderness. With this study, we do, however, have a very important first step.

However, we have heard from DEC that there is an assumption that whichever of the three studies—social, biological, and physical—constrains visitor numbers the most, that study would be considered the most authoritative analysis.

ADK strongly disagrees with this assumption as it does not reflect current national expertise in visitor use management. The social analysis is not an adequate proxy for the others.

We urge DEC to consider the results of this social analysis as informative but not at all definitive, and not without great potential negative outcomes if implemented without more holistic contexts and analysis.

Kaaterskill Clove Project Area

ADK does not support the overarching recommendation of the Kaaterskill Clove VUM which is to limit public access to Kaaterskill Falls. Other reasonable alternatives must be pursued and exhausted before any restriction of public access is considered.

Restricting Access to Kaaterskill Falls is likely to have unintended consequences:

• Numerous State residents and visitors would likely be denied access to an iconic Catskills landmark, simply because they did not know to secure advance reservations. They may not get another chance to see Kaaterskill Falls before having to leave the area, and for many, the Falls might have been their first and only outdoor experience in the Catskill region.
• Access to the Escarpment Trail and other areas within the Kaaterskill Wild Forest for hikers, hunters, and anglers may be inadvertently curtailed, due to confusion and limited parking.
• Dispersal of visitors who are turned away from the Laurel House Rd. parking lot would likely impact surrounding areas such as the Catskill Center’s Platte Clove Preserve, which does not have the parking or trail infrastructure to accommodate a significant uptick in visitation.
• Gated access on trails is likely to result in increased staff/visitor conflicts and the creation of new, unauthorized trails to circumvent the gated access points.
• Access to one of the few wheelchair-accessible trails in the region would be inhibited.

We support alternative strategies including:

• Increased staffing for visitor information, education, and enforcement throughout the Falls and entire Clove area.
• Infrastructure Improvements, including improvements to parking, signage, and trails both above and below the Falls and throughout Kaaterskill Clove.
• Real-time communications to the public about parking and trail conditions.
• A more comprehensive, regional approach, including a Strategic Transportation Plan for the Route 23A corridor; an expanded, multi-destination shuttle service that services an expanded and strategically designed trail network, and incorporating the current and desired conditions of the impacted natural resources, and the adequacy of existing infrastructure to accommodate visitation levels.

In summary, we are very pleased DEC has begun the process of using adaptive management and the VUM Framework. ADK is committed to continuing our work with DEC and other partners and stakeholders to ensure there is equitable access to the High Peaks Wilderness in the Adirondacks, and Kaaterskill Clove in the Catskills and that visitors have the education, skills, and facilities they need to have safe, enjoyable experiences that protect the Forest Preserve. Please do not hesitate to reach out to us if you have any questions.