P.O. Box 118
Titusville, New Jersey 08560
www.highlandscoalition.org

January 16, 2004

Mr. Jeff Wiegert
NYS Department of Environmental Conservation
21 South Putt Corners Road
New Paltz, New York 12561

RE: Proposed Amendment to the Hudson Highlands Unit Management plan to accommodate an Experimental Forest at the Nimham Mountain Multiple Use Area in the town of Kent, Putnam County

Dear Mr. Wiegert:

Thank you for extending the time frame for accepting comments on the foregoing referenced action. The Highlands Coalition would like to take this opportunity to describe the significance of the project within its regional context and to register our comments on the specific action at Mount Nimham. While we understand the critical importance of encouraging landowners to keep lands in forest cover for the sake of water quality protection, we do not believe that Mount Nimham is the appropriate site for a model forest demonstration project. We are concerned that the property's location in the Highlands merits further consideration, in general; and that the model forest proposal at Mount Nimham is incompatible with the preservation of site specific environmental characteristics and existing public uses. Specifically, Mount Nimham is:

· Located in a small but very sensitive and strategically necessary watershed,
· Contains mature, century old trees providing distinct habitat;
· On a site that is a popular recreation destination,
· Situated in a quiet, residential area, and
· Part of the Highlands region which has regional implications.

The Highlands Coalition is an interstate coalition of over 110 environmental organizations that collaborate to protect the nationally significant natural resources of the Highlands region. The Model Forest proposal at Mount Nimham would jeopardize the two most significant natural resources of the Highlands region – drinking water and interior forests. Also, logging operations would destroy habitat provided by tall trees, disturb the quality of life for residential neighbors, and impair recreational opportunities for residents and visitors alike. Therefore, the Highlands Coalition opposes the siting of a Model Forest project at Mount Nimham.

The Highlands Region
The Highlands region is loosely defined as the eastern most range of the Appalachian Mountains, a two million acre greenbelt that runs parallel and just west of the densely populated urban corridor of Philadelphia, Newark, New York City, and Hartford, in the states of Pennsylvania, New Jersey, New York, and Connecticut. In New York the Highlands sweep across Rockland, southern Orange, northern Westchester, Putnam, and southern Dutchess Counties. The New York Highlands are a forested complex of narrow ridges and valleys, rock outcroppings and cliffs, streams and aquifers offering a semi-rural quality of life for residents and accessible outdoor rural recreational opportunities for millions of people living in nearby urban centers.

Most importantly, the Highlands provide or protect the drinking water resources for approximately 20 million people in nearby urban centers. The region contains large tracts of intact interior forests that provide highly valued habitat for significant levels of biodiversity, including endangered and threatened species. And the scenic splendors found on ridge tops and valleys attract millions of recreational visits per year, providing an important economic stimulus. Ultimately, the region offers a diminishing opportunity to enjoy a semi-rural quality of life on the east coast of the Mid-Atlantic States.

In the past the Highlands’ steep topography and rocky terrain have generally been inhospitable to development due to additional costs for construction. Now, more ridge top development than ever before is being granted by local planning boards, thus impacting water quality, scenic vistas, and overall quality of life. These pressures are felt the strongest in Putnam County. Once a semi-rural forested region dotted with farms, Putnam County is now the fastest growing county in the state, as measured by land cover changes and population growth. Much of Putnam County lies within the Highlands and also within the New York City Watershed. Therefore, it is subject to the NYC Watershed Agreement; and on that basis, was chosen as the site for one of DEC’s four “model forest” projects in the NYC watershed. However, its location within the Highlands, a region that is nationally recognized as significant, should also be a major consideration.

Mount Nimham
Mount Nimham is important to protect because of its environmental attributes and public uses. It is a mature forest providing significant habitat for biodiversity. It forested slopes serve to protect drinking water reservoirs, and provides a rural setting for the community. It is a prominent natural and scenic feature in the area, and is a very popular destination for recreationalists, residents and visitors alike. It is characterized by steep slopes and 100 year old mature trees. Tall trees are very important to certain bird species such as the cerulean warbler; and research has demonstrated that “even-aged management” allowing for shorter stand rotation will eliminate the large tall trees that cerulean warblers require, thus limiting potential habitat. It is located within the watershed of the West Branch reservoir, part of the Delaware reservoir system. Its small watershed is only 19.9 square miles, just under 12,000 acres, populated by about 1,320 residents. Any land cover changes in this relatively small watershed have significant impacts on water quality. According to the Natural Resources Defense Council, this relatively rural watershed is experiencing recent development and growth that “threatens to degrade water quality.”

Both the Watershed Agricultural Council (WAC) and the College of Environmental Science and Forestry have invested over $300,000 in developing this forest research site. The location is important because of its proximity to New York City and outdoor education centers will allow WAC to reach a larger audience with its message about connecting water quality with healthy forests. It was also selected because it would be the second site in an undeveloped watershed in the Catskill/Delaware watershed and would allow for replication of the science at the Frost Valley Model Forest in Ulster County. However according to WAC’s own website describing the research already done at Forest Valley, environmental impairments are likely to result. At Frost Valley, after 33% of the basal area was removed on the test area, researchers observed that harvesting and road building had effects on nutrient cycling and macro invertebrates. Nitrate levels in the steam increased dramatically, and the diversity of species decreased while the numbers of these organisms remained stable.

Conclusion and Recommendations
The Highlands Coalition opposes Mt. Nimham as the site for a model forest project due to Mt. Nimham’s location in a small sensitive watershed that is vital for water supply reliability and protection of water quality in the West Branch reservoir. Its steep slopes and intact mature forest dictate that conservation measures be prioritized. Logging will destroy valuable habitat, disturb the surrounding community character and impair the provision of highly valued outdoor recreation. However, if a decision is made to continue to pursue a Model Forest at this site, then we urge the New York State Department of Environmental Conservation to conduct a full environmental assessment pursuant to SEQRA. Because of the potential serious environmental consequences of this proposed amendment to the Hudson Highlands Unit Management Plan, we believe it is a Type I agency action subject to SEQRA. Moreover, a full consideration of alternative sites should be done to account for the national significance of the natural resources at Mount Nimham in the Highlands.

Sincerely yours,

Carole S. Nemore
New York Outreach Coordinator