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ELM Testimony from the Public Meeting and Hearing in Adams
March 2, 2004
March 15, 2004
Mr. James Baecker
Department of Conservation and Recreation
251 Causeway Street
Boston, MA 02114
Re: Draft Amended Master Plan for Greylock Glen, Adams, Massachusetts
Dear Mr. Baecker:
The Environmental League of Massachusetts is pleased to submit these written comments in addition to those I delivered in person at the Public Meeting and Hearing in Adams on the evening of March 2.
By way of background, the Environmental League has been deeply interested in the Northern Berkshires since our beginnings as an organization in more than one hundred years ago. Our first legislative effort, in 1898, the year of our founding, was to fight the commercialization of Mount Greylock and to establish the Mount Greylock State Reservation.
In particular, over the last two decades, since the enactment of Chapter 676 of the Acts of 1985, the Environmental League has advocated for the protection of the 1,063 acres of land adjacent to the reservation known as Greylock Glen. We have consistently opposed several earlier attempts to construct large commercial and residential developments on this parcel.
The Environmental League continues to believe that adding the entire Glen property to the Mount Greylock Reservation would be most appropriate. We believe that it is places like the Glen that make the Berkshires such a special part of our state. And we agree with the sentiment expressed at the recent public hearing that future generations will be grateful to us if we save Greylock Glen, rather than develop it.
Nevertheless, it is our judgment that the Draft Amended Master Plan dated January, 2004 represents a real advance over earlier plans advanced by state government. The Environmental League believes that with certain important modifications the current draft may form the basis of a limited development at Greylock Glen that will provide appropriate recreational and educational opportunities, concomitant economic benefits to Adams and the surrounding region, and permanent protection to the great majority of the Glen's acreage and to the reservation itself.
In fact, we believe that the history of failed major development projects at this site is a strong indication that market forces will not support any Greylock Glen development that fails to place conservation and sustainability at the forefront. The natural beauty and biodiversity of the Northern Berkshires is the region's greatest asset: it would be a tragic error to undermine this asset in the vain pursuit of economic activity. The region would suffer a permanent scar, and the failed project would harm, not help, the cause of stimulating the local economy.
While the new Draft Master Plan is an improvement over earlier efforts, it must be revised to make clear that there will be permanent protection of all lands that are not part of any proposed development. Not only must the next version of the Master Plan make this clear: the entire 1,063 acres of Greylock Glen must be accounted for in eventual land disposition documents that ensure protection in perpetuity. This may be achieved by means of adding some or all of the Glen property to the Mount Greylock State Reservation, by the state granting conservation easements to an independent, non-profit entity that is not affiliated with the eventual developer of the Glen, or by some combination thereof.
It will not be sufficient to include protective provisions in any lease of all or part of the Glen property, since a lease may be modified at any time by the consent of the parties to the lease, in this case, the state and its designated developer or developers. Protective lease covenants, while possibly desirable, are no substitute for permanent protection.
The Environmental League will vigorously oppose any proposed development at Greylock Glen that does not guarantee the protection, in perpetuity, of the undeveloped lands and that does not limit any development to appropriate uses that entail only minimal alteration of Greylock Glen.
The next version of the Master Plan should also state clearly that it is the state's final plan for what development will be permitted at Greylock Glen. While phasing of development may be appropriate, the plan for any such phasing should be in place before the start of any construction or development activity. In particular, the total allowable amount of lodging units, the character of such units, the location of roads, parking lots, buildings, camping and rest room facilities, and maintenance facilities needs to be specified in the Final Master Plan. The Department of Conservation and Recreation should also clarify how it will ensure that a Final Master Plan is, in fact, the last word on permissible development at Greylock Glen.
Golf courses and other golfing facilities, e.g., driving ranges, miniature golf courses, should be added to the list of prohibited uses.
Care should be taken throughout the Glen to site any buildings, parking lots, and other facilities with the greatest sensitivity to the natural and scenic features of the Glen property. Clustering of built elements of the Master Plan should be undertaken wherever possible to minimize the total footprint of any planned development.
On page 9 of the current draft, respondents are only "encouraged" to embrace the concept of sustainability - they should be required to do so, both in the Master Plan and in any leases or other land disposition documents relating to this site.
On page 19, it is stated that "the underlying development mandates for the Greylock Outdoor Recreation and Environmental Center facility establish that the project will "be maximally productive for stakeholders." A list of stakeholders then follows: citizens of the commonwealth, neighboring communities and their residents, target markets (end users), master developer. But the interests of these stakeholders sometimes are in tension with each other, as anyone who has followed the history of this site knows well. As a simple matter of mathematics, one cannot simultaneously maximize the satisfaction of all of these audiences. And the paramount interest for the Department must be that of citizens of the commonwealth in preserving Greylock Glen and the adjoining reservation in perpetuity as a natural resource. The other interests, however legitimate, must not compromise this one.
On page 21, the Draft Amended Master Plan states that, "The developer will be expected to take into consideration the visual impacts of the Greylock project on the town of Adams and on the summit of Mount Greylock and to mitigate impacts as appropriate." This should be strengthened to affirmatively assert that the Department of Conservation and Recreation will allow no development to go forward that does not present a pleasing and appropriate view to the town and that does not minimize the change in the current, undeveloped views of the Glen from the summit of Mount Greylock.
On page 21, does the fifty acre maximum within the development parcel refer to the built footprint or to the entire area within the developable perimeter, including areas proximate to buildings and facilities but not actually built upon? It should be the latter - for example, courtyards or walkways between buildings should count as part of the overall fifty acre development limitation.
On page 26, large scale retail or commercial development is categorized as a prohibited use. This is appropriate. But the meaning of "large scale" needs to be clearly defined. We suggest the plan enumerate precisely the kinds of retail and commercial development that will be permitted, and then state that all other retail or commercial uses are prohibited.
On page 28, the plan states that, "insofar as practical, [any development should] establish a 100' buffer of no disturbance around each wetland or waterway." It should be possible in the next draft of the Master Plan to identify with precision any such areas where non-disturbance is not practical. We would expect there to be few or no such areas.
On page 29, it is stated that "Mountain bike and snowmobile trails will not be allowed to intrude on ecological restoration sites or important natural resource ecosystems." This is as it should be. Furthermore, there should be substantial buffer zones around such areas to make enforcement of vehicle prohibitions easier.
On page 30, there is a building construction guideline that states the development proposal should "anticipate building expansion." This needs to be strengthened: as noted above, all building to be allowed at the site must be spelled out before the first clod of earth is disturbed. This project must not be allowed to nibble away at the undisturbed Glen lands.
The Environmental League appreciates the opportunity to comment on the Draft Amended Master Plan and stands ready to help the Department carry out its responsibility to protect Greylock Glen and the Mount Greylock State Reservation as special public places for this and for future generations.
Sincerely,
James R. Gomes
President
cc: The Honorable Thomas Reilly, Attorney General
The Honorable A. Joseph DeNucci, State Auditor
The Honorable Pamela Resor, Senate Chair, Natural Resources Committee
The Honorable William Greene, House Chair, Natural Resources Committee
Gregory Sullivan, Inspector General
Douglas Foy, Chief of Commonwealth Development
Ellen Roy Herzfelder, Secretary of Environmental Affairs
Katherine Abbott, Commissioner, Department of Conservation and Recreation
