ACC Response to the DEC’s High Peaks Visitor Use Management Recommendations Report

The following outlines the Adirondack Climbers Coalition (ACC)’s comments in response to the DEC’s High Peaks Visitor Use Management Recommendations Report. 

Comments are organized as follows: 

1) Responses To Recommendations 

2) Concerns About Process

3) Alternate Solutions. 

1. RESPONSES TO RECOMMENDATIONS

    ACC is opposed to the implementation of a High Peaks permit system

    A Permit System limits climbers access to public land

    • We are a small user group and should have equal opportunity to access the High Peaks. The impact to climbers of the proposed permit system is wide-ranging, including restricting access to the following significant climbing resources:
      • Heart Lake Portal: Avalanche Pass, Wallface
      • Garden Portal: Panther Gorge, Big Slide, Gothics, Courthouse
      • Upper Works Portal: Avalanche Pass, Wallface  
      • AMR Portal: Noonmark, Gothics, Pyramid 
    • Many people who live in the Adirondacks are here specifically for the flexibility to access public land. The average income in Essex county is ~$70,000, which is below the state average of ~$81,000.  In general, people do not choose to stay in this are because of the economy.  People who choose to stay in the area are here partly because of the flexibility to access public land.
    • Climbers without flexible work schedules will be impacted greatly. Climbers in gateway towns work full time jobs to support living here, and do not have the flexibility to accommodate only “permitted dates” for their activities.  Additionally, visiting climbers will be discouraged or disappointed when they learn they need a permit to enter public land.
    • Permits would reduce the flexibility that climbers need when planning a major ascent in the High Peaks.  Two popular routes, the Trap Dike on Mt Colden and the Diagonal on Wallface are major undertakings.  Actual weather on the planned day is an important factor in the feasibility of these ascents.  A permit system would “lock climbers in” to particular dates, possibly impacting safety.

    A Permit System that impacts climbers does not address the issues of aesthetic degradation and parking safety

    • Human waste and eroded trail issues are best solved by improved infrastructure (trail design and maintenance, latrines, parking) and increased interaction with Rangers and Stewards.
    • Climbers don’t have a major impact on trails, since they are few in numbers, and their primary objective is more vertical terrain.
    • Additionally, increased interactions with Rangers/Stewards can result in dispersal of users to other areas, reducing overall impact
    • There is evidence that permits may be inappropriate or counterproductive in wilderness areas as they fail to address the primary drivers of ecological impact. A large body of recreation ecology research shows that visitor behavior, spatial concentration, and site design matter more than total visitor numbers in many wilderness contexts. Impacts such as soil loss, vegetation damage, and campsite proliferation are highly localized and strongly influenced by where people go and how they behave, not simply by how many people enter the area.
    • Permits function as administrative filters not conservation tools. There isn’t a clear evidence-based link between wilderness permit systems and impact mitigation.

    A Permit System may not be the more cost-effective solution

    • Permit systems are costly and often weakly enforced. A backcountry permit system was attempted in the 1990s.  Even then, it could not be managed, and was abandoned
    • DEC Rangers are already overworked. A permit system would pull them away from the  more important work of education, monitoring, and safety.
    • Access rationing should only be used when other tools (education, site management, dispersal) have failed. It’s not clear that these other options have been tried or explored.

    A Permit System will introduce complexities and challenges not addressed in the VUM Report

    • A Permit System would burden many local systems and communities with responsibilities around enforcement and accountability, particularly the small Town of Keene. 
    • Local climbing related businesses would suffer economic impact.
    • Using as an example the policy of the Adirondack Mountain Reserve to restrict public access to private easement land by parking permits, we can estimate how hiking permits will work. During the busy summer months it is essentially not possible to get an AMR permit for a Saturday.  This will badly hurt the local economy.
    • Online reservation systems have the ability to be taken advantage of by bots and automated AI- task agents.
    • A strong and growing literature links permits, fees, and advance reservations to inequitable access. Time specific reservations, online lotteries, and advance planning requirements favor users with flexible work schedules, stable internet access, and prior outdoor knowledge—traits correlated with higher income and educational privilege. Permit requirements are a structural constraint, compounding cost, travel, and safety barriers, and undermining the Wilderness Act’s mandate for wilderness to be available for the use and enjoyment of all people.

    Permit Systems have been reviewed and eliminated in several areas by the US National Park Service.  Their reasoning should be considered.

    • These decisions were based on review of post‑COVID visitation and traffic data.
    • The affected parks include:
    • Yosemite National Park (California) – Vehicle reservations eliminated for the 2026 season after data showed operational capacity could be managed using real‑time traffic controls and parking management rather than entry caps.
    • Arches National Park (Utah) – Ended its timed‑entry system first introduced in 2022, shifting to visitor education, flexible travel timing, and congestion messaging.
    • Glacier National Park (Montana) – Dropped vehicle reservations for Going‑to‑the‑Sun Road in 2026 while retaining managed shuttles and targeted controls
    • Mount Rainier National Park (Washington) – Discontinued its timed‑entry program beginning summer 2026, citing access and gateway‑community concerns.

    2. CONCERNS ABOUT PROCESS

    ACC disagrees with using “expectations for solitude” as a justification for VUM proposals.  It should be noted that the Adirondack State Land Master Plan refers to “opportunites for solitude”, NOT to “a guarantee of solitude.” 

    Visitors to our most popular portals and viewpoints should not expect solitude during peak season 

    • It should be recognized that there are conflicts between the expectations that wilderness areas be natural, wild, uncrowded and free (Cole, 2020) and proper management should seek to manage these conflicts.
    • The Adirondack Park is vast, and there are virtually unlimited opportunities for solitude, outside of a few highly popular locations. 
    • Education is needed to inform visitors of options for visitors looking for locations with fewer interactions. 

    ACC Believes the process that was used to develop the VUM report is invalid for the following reasons:

    • The VUM study uses data from surveys using hypothetical visitor experience based on simulations, not on actual experiences, potential creating corrupt data.
    • Respondents were asked how they feel about crowding. They were not asked “How do you feel about a crowd on the summit vs. you not being able to go there at all?”
    • The focus was upon hiker numbers at only a handful of popular locations. 
    • Carrying capacity and physical metrics were not considered
    • Parking and road congestion was mentioned but not measured

    Based on the above concerns, the data and studies used to support the VUM Report should actually NOT be used for any decision support. 

    ACC notes that the possibility for “no action” was not considered

    • DEC decision packages are usually structured to show several alternative management options for comparison including ‘No action’. This was not the case here. 

    3. ALTERNATE SOLUTIONS

    ACC sees many alternate solutions that were not considered in the VUM report

    Although the report notes that some alternate solutions are not being considered, these viable alternatives should be revisited

    • Bathrooms, signage, stewards and education all represent viable, evidence-based alternative solutions. 
    • Road congestion could be managed through proper infrastructure development. 
    • Resources for a permit system could instead be invested into increased adequate, safe, paved, off-road parking combined with signage and trailhead stewards to redirect visitors when parking is full.  

    In conclusion, the ACC believes that significant limitations in both the methodology and process of the VUM report undermine the legitimacy of its recommendations.

    Specifically: the evidence base is insufficient to justify a permit system; key alternatives were not adequately evaluated; user access, feasibility, and enforcement challenges were not adequately reviewed.

    Given these concerns, ACC urges DEC to better serve the natural resource and the public by:

    • Reevaluating the recommendations with a broader and more transparent alternatives analysis
    • Prioritizing infrastructure, education, and stewardship strategies
    • Expanding stakeholder engagement, particularly with user groups directly affected