November 14, 2003

Hon. Erin Crotty, Commissioner
Department of Environmental Conservation
625 Broadway
Albany, New York 12233
RE: DEC Mt. Nimham Model Forest Plan
Dear Ms. Crotty:

I am writing as Chair of the Putnam County Coalition to Preserve Open Space, a not-for-profit, citizen directed organization committed to the preservation of environmentally and ecologically sensitive land and conservation of historic sites and structures.

I would like to put my remarks concerning the proposed DEC “Model Forest” plan in the context of disturbing developments affecting forests throughout the Eastern Putnam region. As you are aware, Putnam County is the fastest growing county in the State and as such has seen devastation of incalculable acres of forest and woodland. And it is home to two watersheds: The Cat/Del and the Croton providing water to over 9 million NYC inhabitants.

The connection between preservation of forests and their watershed function has been amply elucidated by Mike Dombeck in a New York Times article of January 3, 2003. He cites the “complex array of trees, shrubs, ground covers and roots slowing runoff from rain and snow and purifying water as it percolates throughout the soil and into aquifers.” Continues Mr. Dombeck, “The focus should be on how to let our forests do their job of producing high quality water.” And concluding, “Given our water supply problems, this should be the highest priority of forest management.”

Supporting Dombeck is the September 2003 report, “Running Pure,” issued by the World Bank and World Wildlife Fund cautions: “For many cities, time is running out. Protecting forests around water catchment areas is no longer a luxury but a necessity. When they are gone, the costs of providing clean and safe drinking water to urban areas will increase dramatically,” As a Bd. Member of the Croton Watershed Clean Water Coalition, I fully endorse that position.

Over development is decimating our forests, the bulwark for maintaining our pure and high quality water. For ex. in the Town of Southeast, Brewster Highlands, a retail center on Route 312, 61 acres of forests were leveled along with slopes and ridges. Another proposal has recently been approved by the Planning Board which would result in over 60 acres being deforested in the same area. Both impact the Middle Branch Reservoir. And numerous additional residential developments prominent among them Meadows at Deans Corners located in the Town of Southeast. Further, less than stringent tree laws in several towns have opened the door for residential developers, to clear cut acres even where the footprint for the home does not warrant clearance.

However, it is not only the Croton Watershed that is being impacted. The Catskill/Delaware Watershed - the West Branch specifically, has been similarly impacted by development. This was noted noted by the Natural Resources Defense Council in their published report “The West Branch Reservoir.” According to NRDC “The 19.9 square miles of land surrounding the West Branch Reservoir make up its relatively small watershed of under 12,000. In recent years, this watershed has been the site of expanding residential development. According to one DEP estimate, there are now about 1,320 residents located throughout the West Branch.” It is the conclusion of the NRDC that “Development threatens to degrade water quality.”

In the last year, it has come to our attention that private landowners are also taking advantage of the economic gain to be derived from logging. In a most recent instance with which we have been involved, 80 acres of 1,036 of varied tree species 14”-16” in girth are proposed for harvesting. This area is home to wildlife and permitted recreation. Incursions of mechanized equipment needed for harvesting and logging trucks exiting onto narrow, sloping residential roads, endanger vehicles and children on school buses.

It is this mix of over development, lax or non-existant tree conservation laws and private landowners’ desire to harvest for economic gain together with the DEC “Model Forest” Plan for the Mt. Nimham Multiple Use Area has resulted in deep concern among residents. For here we apparently have another instance of large-scale devastation of forests, proposed 40 to 60% removal on an 87 acre parcel, occurring in a watershed area. The West Branch has been cited by the NRDC as having been in “an unhealthy eutropic state for much of the last decade.” Additionally it is in proximity to residential vehicular traffic, requiring mechanized equipment notorious for road and sapling damage. It is also home to wildlife and opportunities for active and passive recreation. As you are aware, passive recreation such as hiking has now superseded hunting in terms of the millions of dollar expended by the public. And Eastern Putnam County is on the verge of developing and fostering these opportunities.

Does the DEC’s “Model Forest” Plan accomplish the primary goals cited in the Press Release of Nov. 6, 2003 concerning DEP’s plan for timber harvesting in the Cat/Del? Does it “protect public health through providing long term supply of high quality water?” Does it “maintain ecosystem integrity by protecting essential ecosystem processes and allowing the watershed to both resist and recover from disturbances?” Does it “provide community benefits, uses, values, goods and services?” Does the “Model Forest” Plan protect the land and the water quality? It appears that a “hard look” on all of these issues and others cited, is absolutely necessary.

Please accept my appreciation for your serious consideration of my comments.

Sincerely,

AF
Southeast