Guidance for Snowmobile Construction and Trail Maintenance on Forest Preserve lands in the Adirondack Park: Comments

The following are my comments on the Adirondack Park Agency's proposed Guidance for Snowmobile Construction and Trail Maintenance on Forest Preserve Lands in the Adirondack Park. Items highlighted are links to background materials.

I am very concerned about the basic framing of the task for creating the "Guidance for Snowmobile Construction and Trail Maintenance on Forest Preserve lands in the Adirondack Park"

In the memorandum to Terry Martino(Executive Director of the Adirondack Park Agency APA) it is stated that "Snowmobiling is an allowable recreational use in the Forest Preserve when occurring in compliance with APSLMP(Adirondack State Land Master Plan) guidelines". I believe that starting this statement with the phrase that "Snowmobiling is an allowable use" leads to the development of guidelines that try to accommodate modern snowmobiles. The memorandum could have begun with the statement that: "Article xiv(This is the 'Forever Wild Clause' of the NY State Constitution) and the SLMP govern the allowable use of Snowmobiles in the Adirondack Park'. This might have gotten us off on a better footing. In fact, modern snowmobiles are tremendously different in character from the snowmobiles that were allowed in the original State Land Master Plan.

• They are almost a foot wider. The standard width is now 4 ft.
• They are vastly more powerful and capable of speeds in excess of 100 mph.
• Trail grooming techniques have changed to accommodate the higher speeds and greater size of the machines.

There seems to be an assumption that no matter how much the machine morphs, the SLMP must flex to permit its use. I argue that the new guidelines regulating the use of snowmobiles are based on the technological advancements of the machine rather than on the basis of Article XIV of the NYS constitution and the APSLMP. Technological development of the snowmobile should not be the basis for guidelines. The APSLMP should be the basis for the guidelines.

There are two keys in the APSLMP that are most important:

• Snowmobile trails must maintain the character of a foot trail.
• Snowmobiles are the only allowed vehicles on snowmobile trails.

Pages 9, 10 and 11 of the proposed guidelines indicate guidelines for improvement of Class II trails that:

1. Make them 9 ft. wide.
2. Remove rocks and tree stumps protruding in such a manner to interfere with the operation of snowmobiles using landscaping equipment such as small backhoes and skidsteers.
3. Allow for the leveling of humps and dips in the trails.
4. create 'benches' with 9 foot wide areas level enough for operation. This means some beveling of the up slope and down slope areas from the bench and will inevitably result in the opening up of the forest canopy.
5. Curves in the trails will have a radius of at least 25 ft and the trail is up to 12 feet wide at these curves.
6. bridges over wet areas and streams will be 9 ft wide.

Trails with features such as these in no way resemble foot trails. They do not pass the 'common sense test' as a foot trail. They are in fact Snowmobile highways. I do understand that there are all sorts of mechanisms put in place by the guidelines to try to ensure a minimization of the impact of these improvement methods, but they do not change the essential nature of the new trails in a way that could possibly be conceived of as a foot trail.

I have also heard, verbally, of justification for these trail modifications on the basis that there are old roads in the Forest Preserve that have been converted to foot trails that were extensively graded and benched when they were roads. The argument proceeds: "Therefore creating new trails with those features merely mimics those already established foot trails". This, as you must be aware, is faulty logic. The fact that old roads have been abandoned and converted to foot trails, does not provide justification for creating what are essentially new roads to be converted to snowmobile trails - it just does not make sense. Using that logic we could build roads anywhere in the preserve and call them foot trails and it would be approved. This clearly violates the intent of the SLMP.

I think that the idea of Community Connectors is a sound idea. I think that it is also very positive to move trails from the interior of the Forest Preserve to the periphery, but I feel that two miles from the nearest highway is two far into the Preserve to consider being on the periphery. One half mile is closer to the ideal. If the intent is to provide a trail from one town to another, what is the problem with running the snowmobile trails along the shoulder of the road in places where there is no suitable trail location further into the forest? The shoulders of many Adirondack highways have recently been widened to a point where they could accommodate such use. Using these road shoulders would keep the trails off of Forest Preserve Lands.

Use of tracked snocats as groomers for the trail clearly violates the SLMP which states that snowmobiles are the only vehicle to be used on snowmobile trails. Calling daily, or even multiple daily, grooming runs with a tracked snocat a trail maintenance operation is stretching the language and intent of the SLMP. Trail maintenance has always been considered something that happens on hiking trails once a year or even once in multiple years, not a daily event. I'm sure the authors of the original SLMP and Article xiv are 'turning over in their graves'.

Alternatives:

Overall, I would suggest that snowmobile trails, as originally intended and initially described in the SLMP and earlier guidelines, be the only allowed type of trail even when used as community connectors. A public education campaign and appropriate signage could indicate that this snowmobiling experience is a Wild Forest experience different from the kind of snowmobiling experience one would expect elsewhere. Speed limits could be imposed and enforced. Yellowstone National Park has a speed limit for snowmobiles of 45 mph even on highways. I would only suggest a snowmobile speed limit on Forest Preserve Trails and it should be less than 45 mph because of the nature of the trails. Natural speed bumps should be left intact. Grooming would be done with snowmobiles pulling drag groomers.

An analogy for what I am suggesting is that we typically reduce auto traffic speeds in residential neighborhoods and install many stop signs and speed bumps in these neighborhoods to preserve the quiet for people in their homes and enhance the safety for pedestrians and children. Even though one may travel through the neighborhood with a car capable of 0 - 60 in 9 seconds and capable of traveling in excess of 100 mph, one realizes that it is not appropriate in that setting. The auto industry even has cars appropriate to the suburban setting like station wagons and minivans as opposed to the little sport sedans more attuned to the open road. Likewise to provide for the quiet and wild character of Forest Preserve lands we must operate well below the capacity of the modern snowmobile. Article xiv and the People of NYS in legislation establishing the APA and the State Land Master Plan have repeatedly indicated that the State Forest is a special place requiring restraint on our activities to preserve its forever wild character.