Dear Jeff,

Sorry that I did not get back to you earlier, I've been tied up with litigation. I wanted to let you know, however, that I have some serious concerns with this project. While forestry/silverculture can be a useful alternative to development for much of the privately held land within the New York City Watershed, particularly in the "West of Hudson" watershed, I have many concerns about a project on state-owned land in a portion of the Highlands that is moving toward old growth and which serves as a great recreational resource. I still have a lot to learn about this specific project. I have been asking City DEP to do more with respect to obtaining forestry conservation easements (see letter attached). Thanks for letting me know of your concerns.

Regards, Jim Tierney (518) 474-4843

Attachment:

(518) 474-4843

April 15, 2003

Christopher O. Ward, Commissioner
New York City Department of
Environmental Protection
Executive Offices
59-17 Junction Boulevard
Flushing, New York 11373-5108

Dear Commissioner Ward:

On January 24th of this year, twenty-one environmental and civic organizations wrote to Governor Pataki and Mayor Bloomberg to propose a series of thought-provoking measures to help protect the New York City Watershed over the long-term. As many recognize, New York City’s world-class program to protect its drinking water has an Achilles’ heel – the adverse impacts of sprawl development over time. Indeed, the peer reviewed scientific literature demonstrates that sprawl ruins drinking water quality. The proposals contained in the January 24th letter were designed to permanently limit the potential for sprawl to eventually overwhelm the many programs aimed at protecting drinking water quality and maintaining filtration avoidance.

While I want to carefully consider all of the land protection programs and goals delineated in the January 24th letter, the proposal to dramatically expand programs to obtain conservation easements to protect forested Watershed lands immediately stands out as an especially good idea. The approximately 600,000 acres of privately owned forest within the Catskill and Delaware portions of the Watershed have a huge potential for environmentally harmful recreational and residential development. The Crossroads Ventures project exemplifies this threat. Such developments harm the rural character of the Catskills, damage the existing economy of hamlets and town centers, reduce the Watershed’s desirability as an eco-tourism destination, and gobble-up prized hunting grounds that have been enjoyed by local residents for generations.

On the other hand, forested lands that are responsibly harvested for timber pursuant to approved management plans comport well with the preservation of drinking water quality and already constitute a vital, sustainable, component of the Catskill economy. There are many timber management programs with proven success. Lessons from these programs could be employed within the Watershed under the existing framework of the Watershed Agricultural Council, careful DEP oversight, and the “willing seller” principle. Of course, the full participation of Watershed partners, careful planning, specific goals and sufficient funding would be essential components of the development of a successful program. The proposed goal of obtaining conservation easements on 100,000 acres of Watershed lands over the next ten years certainly seems like an aggressive, yet attainable, goal.

As always, thank you for your time and for taking the comments of this office into consideration.

Sincerely,

James M. Tierney
Watershed Inspector General
Assistant Attorney General

Sandra Allen, DEC
Cathleen Breen, NYPIRG
John Dunn, DOH
Jeffrey Gratz, EPA
Eric Goldstein, NRDC
William Harding, WPPC
Fred Huneke, WAC
Robert Kennedy, Jr., Riverkeeper
Robin Marx, NRDC
Michael Principe, DEP
Alan Rosa, CWC
Thomas Snow, DEC
Marc Yaggie, Riverkeeper