Dear Gaming Facility Location Board Members,
I am writing on behalf of the Appalachian Trail Conservancy (ATC) regarding the proposed Sterling Forest Resort in the Town of Tuxedo in Orange County, New York and the project’s potential impacts to the Appalachian National Scenic Trail (ANST). The ATC strongly opposes this proposal.
The ATC is a private, nonprofit, educational organization founded in 1925 to coordinate the efforts by both public agencies and private individuals and organizations to design, construct, maintain, and conserve the ANST, a unit of the National Park System authorized by the National Trails System Act (16 U.S.C. §1242).
The ATC has a membership base of approximately 42,000 individuals and also is a federation of 31 hiking and outing organizations (with a combined membership of more than 180,000), each of which maintains and manages an assigned segment of the Appalachian Trail (A.T.). In total, about 6,000 volunteers annually commit approximately 245,000 hours of labor along the trail.
Our mission is to conserve the natural lands, pristine waters, and forested and pastoral landscapes that surround and border the Appalachian National Scenic Trail, our nation’s first and foremost national scenic trail. The trail is a continuous, 2,185-mile footpath extending across 14 states from Maine to Georgia. Following passage of the National Trails System Act, federal and state agencies launched one of the most ambitious land conservation efforts in our nation’s history—including the acquisition of more than 3,000 parcels of land and 180,000 acres. The results of those efforts, spanning more than 35 years, is a publicly owned “greenway” connecting eight national forests, six other national parks, and more than 60 state parks, forests, and game-management units.
Those lands are remarkable not only for their scenic qualities but also their extraordinary diversity of natural and cultural resources. Indeed, based on extensive natural resource inventories, we now know that more than 2,000 occurrences of state or federally listed rare, threatened, or endangered species at more than 500 discrete sites are found on lands associated with the A.T., ranking the A.T. among the most biologically diverse units of the National Park System. Similarly, recent inventories of cultural resources in selected states suggest that those same lands possess an equally rich assortment of significant historical and cultural resources. With an estimated 2 million-plus hikers each year, the Trail also ranks among the most heavily visited units of the National Park System.
Working in close cooperation with locally based volunteer trail clubs and numerous agency partners, thousands of privately owned parcels have been acquired by state and federal agencies to protect the Trail experience and the surrounding landscape. Significantly, the very first section of the A.T. to be constructed was in New York’s Hudson Highlands.
The protection of New York’s Sterling Forest is a prime example of the long-standing effort to preserve the Trail corridor and the hiking experience for future generations. Sterling Forest State Park surrounds the proposed resort development and includes approximately 22,000 acres of protected lands in a critical watershed for New York City that is also a highly valuable recreation area. These lands were preserved through the strong and effective collaboration of the National Park Service, the states of New York and New Jersey, the Palisades Intestate Park Commission and private conservation groups and many citizens. The magnitude of the proposed casino resort development would inevitably have a devastating impact on the immense value of the public investment to date to protect Sterling Forest.
The importance of the keeping the ecological integrity of Sterling Forest intact should not be underestimated. Distinct ecologic communities, unparalleled outdoor recreation opportunities, and a magnificent scenic landscape are afforded to visitors of Sterling Forest. These values are the essence of the Appalachian National Scenic Trail and projects of this magnitude are incongruous with the scenic and culturally significant experience that the A.T. provides to its visitors. Sterling Forest features critical habitat for nesting and migratory birds and is a nationally recognized Important Bird Area (IBA). The area surrounding the proposed casino is replete with important wetlands that provide valuable ecological services to the community.
We are pleased that the SEQRA draft scoping document identifies the Appalachian Trail as a resource to be assessed. The ATC formally requests both potential visual and aural impacts on the Trail (including lighting) as well as cultural resource impacts be carefully evaluated. Preliminary viewshed impact assessments on the Trail from this development indicate the hiking experience through Sterling Forest would be adversely impacted. The ATC, and our long standing partner the New York - New Jersey Trail Conference, should be consulted as these impacts are assessed, as well as the National Park Service’s Appalachian National Scenic Trail office. To be clear, this development would clearly threaten the integrity of our nation’s most popular national park units.
We appreciate the opportunity to provide these comments and look forward to a detailed assessment of this proposal. However, based on the information that has been made available to the public, we believe a major casino development clearly should not be built in the proposed location, and we respectfully urge the board to consider a more appropriate site for any casino in this part of the state.
Ronald J. Tipton
Executive Director & CEO