Invasive Species Prevention Plan

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Lake George Aquatic Invasive Species Prevention Plan

and Draft Generic Environmental Impact Statement

April 2013

Lake George Park Commission P.O. Box 749, 75 Fort George Road, Lake George, NY 12845 518-668-9347 www.lgpc.state.ny.us Bruce Young, Chairman
David Wick, Executive Director

Lake George Aquatic Invasive Species Prevention Plan/ Draft Generic Environmental Impact Statement
Prepared For: Lake George Park Commission P.O. Box 749 75 Fort George Road Lake George, NY 12845

Lead Agency: Lake George Park Commission P.O. Box 749 75 Fort George Road Lake George, NY 12845 Contact Person: David Wick, Executive Director

Prepared By: The LA Group Landscape Architecture and Engineering, P.C. 40 Long Alley Saratoga Springs, NY 12866 Contact Person: S. Jeffrey Anthony, RLA

Date of Complete Draft Document: April 8, 2013 Date of Public Hearing: May 28, 2013 Date of Close of Comment: T.B.D.

TABLE OF CONTENTS DRAFT for Public Review 5/7/2013 11:05 AM

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY SECTION 1 1.1 1.2 1.3 1.4 1.5 1.6 SECTION 2 2.1 2.2 2.3 2.4 2.5

............................................................................................ i

PROJECT DESCRIPTION ..................................................................... 1-1 Introduction ........................................................................................ 1-1 Project Description ................................................................................. 1-1 Location and Regional Context .............................................................. 1-2 History and Background ......................................................................... 1-4 Purpose and Need for AIS Control ......................................................... 1-6 Movement and Spread of AIS .............................................................. 1-11 EXISTING CONDITIONS ....................................................................... 2-1 Water Quality ........................................................................................ 2-1 Ecology ........................................................................................ 2-1 Fisheries ........................................................................................ 2-1 Lake George as a Drinking Water Supply .............................................. 2-2 AIS Introduction into Lake George ......................................................... 2-3 2.5.1 Boat Launches ............................................................................ 2-3 2.5.2 In-Lake Transport ....................................................................... 2-4 Aquatic Invasive Species Summary ....................................................... 2-4 2.6.1 Lake George Aquatic Plant Community...................................... 2-5 2.6.2 Curly Leaf Pondweed ............................................................... 2-10 2.6.3 Eurasian Watermilfoil ................................................................ 2-10 2.6.4 Zebra Mussel ............................................................................ 2-12 2.6.5 Asian Clam ............................................................................... 2-13 2.6.6 Spiny Water Flea ...................................................................... 2-15 AIS Threats to Lake George ................................................................. 2-16 Aquatic Invasive Species Spread Prevention Programs ...................... 2-18 2.8.1 AIS Prevention Initiatives in Western States ........................... 2-18 2.8.2 AIS Prevention Initiatives in Northeast States .......................... 2-25 2.8.3 AIS Prevention Initiatives in New York State ............................ 2-26 2.8.4 Lessons Learned from State AIS Prevention Initiatives............ 2-27 2.8.5 AIS Prevention Initiatives in Warren County, NY ...................... 2-27 2.8.6 AIS Prevention Initiatives for Lake George ............................... 2-28 ALTERNATIVES ANALYSIS ................................................................. 3-1 Introduction ........................................................................................ 3-1 Lake George Alternative 1: No Action .................................................... 3-1 3.2.1 Description .................................................................................. 3-1 3.2.2 Potential Benefits (Pros) ............................................................. 3-2 3.2.3 Potential Drawbacks (Cons) ....................................................... 3-2 Lake George Alternative 2: Enhanced Voluntary Compliance ............... 3-3 3.3.1 Description .................................................................................. 3-3 3.3.2 Potential Benefits (Pros) ............................................................. 3-5 3.3.3 Potential Drawbacks (Cons) ....................................................... 3-6 Lake George Alternative 3: Regulatory Self-Certification ....................... 3-7 3.4.1 Description .................................................................................. 3-7 3.4.2 Potential Benefits (Pros) ............................................................. 3-8 3.4.3 Potential Drawbacks (Cons) ....................................................... 3-8

2.6

2.7 2.8

SECTION 3 3.1 3.2

3.3

3.4

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3.5

3.6

3.7.

3.8 SECTION 4 4.1 4.2 4.3

Lake George Alternative 4: Regulatory Mandatory Boat Inspections ... 3-10 3.5.1 Description ................................................................................ 3-10 3.5.2 Potential Benefits (Pros) ........................................................... 3-11 3.5.3 Potential Drawbacks (Cons) ..................................................... 3-12 Lake George Alternative 5: Regulatory Mandatory Boat Inspections with After-Hours Self-Certification ........................................................ 3-13 3.6.1 Description ................................................................................ 3-13 3.6.2 Potential Benefits (Pros) ........................................................... 3-14 3.6.3 Potential Drawbacks (Cons) ..................................................... 3-14 Lake George Alternative 6: Inclusion of Non-Motorized Watercraft .... 3-14 3.7.1 Description ................................................................................ 3-14 3.7.2 Potential Benefits (Pros) ........................................................... 3-15 3.7.3 Potential Drawbacks (Cons) ..................................................... 3-15 Cost Summary of Alternatives .............................................................. 3-15 ECONOMIC ANALYSIS AND IMPACTS............................................... 4-1 Introduction ............................................................................................. 4-1 Description of Assessment Area ............................................................ 4-1 Economic Assessment of Alternative Actions ........................................ 4-2 4.3.1 Lake George Alternative 1: No Action ....................................... 4-3 4.3.2 Lake George Alternative 2: Enhanced Voluntary Compliance... 4-9 4.3.3 Lake George Alternative 3: Regulatory Self Certification .......... 4-9 4.3.4 Lake George Alternative 4: Regulatory Mandatory Boat Inspections................................................................................ 4-10 4.3.5 Lake George Alternative 5: Regulatory Mandatory Boat Inspections with After-Hours Self-Certification ......................... 4-11 4.3.6 Lake George Alternative 6: Regulatory Non-Motorized Boat Registration............................................................................... 4-12 THE PROPOSED PROJECT (PREFERRED ALTERNATIVE) ............. 5-1 Mandatory Boat Inspections and Decontamination ................................ 5-1 5.1.1 Selection of the Preferred Alternative ......................................... 5-1 5.1.2 Description of Program ............................................................... 5-1 5.1.3 Inspection Station Locations ....................................................... 5-8 5.1.4 Control of Launch Access Points .............................................. 5-10 5.1.5 Inspection Procedures .............................................................. 5-12 5.1.6 Implementation ......................................................................... 5-13 5.1.7 Management ............................................................................. 5-16 5.1.8 LGPC Authorization Process .................................................... 5-17 5.1.9 Cost Estimates.......................................................................... 5-17 5.1.10 Funding Approaches................................................................. 5-18 Required Administrative Actions........................................................... 5-26 POTENTIAL IMPACTS OF THE PREFERRED ALTERNATIVE .......... 6-1 Native Aquatic Plant Species ................................................................. 6-1 Water Quality ........................................................................................ 6-1 Ecology ........................................................................................ 6-1 Fisheries ........................................................................................ 6-2 Wetlands ........................................................................................ 6-2 Public Health and Potable Water Supplies ............................................. 6-2 Recreation ........................................................................................ 6-2

SECTION 5 5.1

5.2 SECTION 6 6.1 6.2 6.3 6.4 6.5 6.6 6.7

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6.8 6.9 6.10 SECTION 7 7.1

Land Use Economics Aesthetics

........................................................................................ 6-4 ........................................................................................ 6-4 ........................................................................................ 6-5

7.2 7.3 SECTION 8 8.1 8.2 8.3 8.4 SECTION 9

PARTICIPATING AGENCIES, ADMINISTRATIVE RECORD, AND REGULATORY IMPACT STATEMENT................................................. 7-1 Participating Agencies ............................................................................ 7-1 7.1.1 Federal Executive Order ............................................................. 7-1 7.1.2 APA Role and Statutory Responsibilities Related to AIS Control ............................................................................ 7-3 7.1.3 NYS Agriculture and Markets Role and Statutory Responsibilities Related to AIS Control....................... 7-4 Administrative Record ............................................................................ 7-5 Regulatory Impact Statement ................................................................. 7-5 GROWTH INDUCING, SECONDARY, AND CUMULATIVE IMPACTS 8-1 Introduction ........................................................................................ 8-1 Growth Inducing Impacts ........................................................................ 8-1 Secondary Impacts ................................................................................. 8-2 Cumulative Impacts ................................................................................ 8-2 ADVERSE IMPACTS WHICH CANNOT BE AVOIDED IF THE PROPOSED PROJECT IS COMPLETED................................................................... 9-1

SECTION 10 IRREVERSIBLE AND IRRETRIEVABLE COMMITTMENT OF ENVIRONMENTAL RESOURCES ...................................................... 10-1 SECTION 11 EFFECT OF THE PROJECT ON THE USE AND CONSERVATION OF ENERGY RESOURCES ...................................................................... 11-1 LIST OF TABLES Table 1-1 Table 1-2 Table 1-3 Table 1-4 Physical Characteristics of Lake George .................................... 1-4 Spending Estimates for AIS Management 1986-2012................ 1-7 Economic Returns on AIS Management..................................... 1-7 Summary of Responses of Aquarium and Pond Owners by Municipality ................................................................................. 1-8 Summary of Launch Points......................................................... 2-3 Number of Launches Recorded by Lake Stewards in 2012 ....... 2-3 History of EWM Sites and Management Outcomes ................. 2-11 History of Zebra Mussel Sites and Management Outcomes .... 2-14 Asian Clam Population Distributions......................................... 2-15 Future AIS Risks for Lake George ............................................ 2-18 Aquatic Invasive Species Prevention Programs by State ......... 2-19 Lake Tahoe Boat Inspection Fee Structure .............................. 2-21 Summary of AIS Prevention Methods in Western States ......... 2-24 Summary of Estimated Costs of Alternatives ........................... 3-16 Comparison of Alternative Actions............................................ 3-17

Table 2-1 Table 2-2 Table 2-3 Table 2-4 Table 2-5 Table 2-6 Table 2-7 Table 2-8 Table 2-9 Table 3-1 Table 3-2

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Table 4-1 Table 4-2

Lake George Waterfront Parcels: Summary of Impact of No Action Alternative to Waterfront Property Values .................................. 4-8 Lake George Waterfront Parcels: Summary of Impact of No Action Alternative to Municipal Real Property Tax Revenues ............... 4-8 Potential Inspection Station Sites ............................................... 5-9 Summary of Launch Sites on Lake George .............................. 5-11 Clean-Drain-Dry Standards ...................................................... 5-12 Protocol for Watercraft Inspections........................................... 5-14 Inspection Station Operations................................................... 5-15 Proposed Administration Chart ................................................. 5-17 Inspection Station Site Development Costs.............................. 5-18 Cost of Employees.................................................................... 5-18 History of LGPC Annual Boat Registrations ............................. 5-19 Summary of Annual Revenues Projected from Preferred Funding Option ......................................................... 5-21 Comparison of NYS and LGPC Boat Registrations .................... 6-3

Table 5-1 Table 5-2 Table 5-3 Table 5-4 Table 5-5 Table 5-6 Table 5-7 Table 5-8 Table 5-9 Table 5-10

Table 6-1 LIST OF FIGURES Figure 1-1 Figure 1-2 Figure 1-3 Figure 1-4 Figure 2-1 Figure 2-2 Figure 2-3 Figure 5-1 Figure 5-2 Figure 5-3 Figure 5-4 Figure 5-5 Figure 5-6 Figure 5-7 APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Appendix I

Regional Location Map ............................................................... 1-2 Lake George Park Commission Boundary Map ......................... 1-3 Boater Origins Map ..................................................................... 1-8 Regional Invasives Map.............................................................. 1-9 Historic Lake George AIS Distributions 1985-2012 .................... 2-6 Lake George AIS Distributions 2012 .......................................... 2-7 Lake George Boat Launch Sites ................................................. 2-8 Recommended Inspection Station Sites ..................................... 5-3 Concept Site Plan for Boat Inspection Station Design A ............ 5-4 Concept Site Plan for Boat Inspection Station Design B ............ 5-5 Concept Plan for Rogers Rock Campground ............................. 5-6 Concept Plan for Mossy Point Boat Launch ............................... 5-7 Watercraft Inspection Interview Process .................................. 5-13 Proposed Administration Chart ................................................. 5-17

List of References List of Acronyms LGA Lake Steward Inspections Summary Data 2008-2012 Draft LGPC Regulation to Require Watercraft Inspections for AIS Economic Analysis: Methodology and Analysis Proposed Implementation Schedule Terrestrial and Aquatic Invasive Species in the Lake George Region Hazard Analysis Control Countermeasure Plan (HACCP) Protocol Clean-Drained-Dry Protocols and Standards

EXECUTIVE SUMMARY DRAFT for Public Review 5/7/2013 11:05 AM

EXECUTIVE SUMMARY

Introduction This executive summary provides a synopsis of the findings of the Lake George Aquatic Invasive Species Prevention Plan (Plan) and Generic Environmental Impact Statement (GEIS). This document will be used by the Lake George Park Commission (Commission) to evaluate alternative methods to limit the future introduction of aquatic invasive species (AIS) into Lake George. A range of alternative measures to prevent the introduction of AIS into Lake George have been identified and evaluated, including pros and cons, costs and logistics, and these are presented in detail in this Plan. The Preferred Alternative recommended in the Plan presents the highest level of prevention of potential new AIS introductions into Lake George, while working to minimize the inconvenience to boaters. The Preferred Alternative is the mandatory inspection, prior to launch, of all motorized boats that are brought by trailer to Lake George. Those boats that do not meet the inspection standard of Clean-Drained-Dry (C-D-D) will be required to have their boat decontaminated through a high pressure hot water (HPHW) process prior to launch into Lake George. The Commission is the lead agency under the New York State Environmental Quality Review Act (SEQRA). This document has been prepared in accordance with 6 NYCRR 617. The Commission was established in 1960 and reauthorized in 1985 to oversee and manage the unique resources of the Lake George Park, especially the lakes superior water quality. To do so, the Commission is conveyed special authority and responsibility by New York State. The Commissions programs fill critical gaps to ensure the lakes protection and encourage cooperation among the many public and private entities whose common goal is the lakes preservation. Lake George is approximately 55 miles north of the City of Albany, 150 miles north of New York City, and 143 miles from Montreal, Canada. It is renowned for its historic significance in the French and Indian War, Revolutionary War, and in the early development of the Adirondack Park. Lake George itself is prized as being one of the clearest of all large lakes in the eastern United States. Lake George is also highly appreciated and enjoyed by tourists for its outstanding recreational resources. Project Purpose and Need The main purpose of the Plan is to provide clear direction that will guide and coordinate all subsequent planning and management related to preventing the future introduction of aquatic invasive species (AIS) into Lake George. The Commission believes that proactive intervention and targeted local actions to protect Lake George will increase public awareness of this problem, avoid costly control measures in the future, and prevent environmental degradation. Lake George has five known AIS. AIS are a rapidly escalating problem and have the potential to cause significant, long-term damage to the Lake George environment and cost millions of dollars to control in the future. These negative impacts could extend to the local tax base and the robust tourism industry. This Plan assesses how to prevent the introduction of aquatic invasive species into Lake George. It identifies and assesses the positive and negative aspects of the various means to achieve this goal (alternatives studied); how the preferred alternative was selected (mandatory boat inspections), and how a mandatory inspection program could be implemented and funded for Lake George.

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Threats Early discovery of AIS is critical to implementing a successful controlled action. Early discovery is established when there is both an organized surveillance mechanism on the water body as well as evaluation of regional threats that may occur on a regular basis. The most critical regional threat is represented by those AIS found in nearby waterways which are fully capable of thriving in Lake George. Examination of data provided through the Lake George Associations (LGA) Lake George Lake Steward Program indicates the greatest threats for new AIS are from local and regional waterbodies including the Hudson River, Mohawk River, Lake Champlain, Saratoga Lake, and Schroon Lake. Dozens of invasive species are present in waterbodies surrounding Lake George. Intercepting these AIS before they reach Lake George is the most efficient and economical method of AIS control.

Summary of Launch Points There are approximately 100 launch points where trailered boats can enter Lake George (see map at left). However, the vast majority of launches on Lake George take place at relatively few launch points, most notably at Norowal Marina in Bolton, Mossy Point Public Launch in Ticonderoga, and Rogers Rock State Campground in Hague. Type of Launch State and Municipal Commercial Marina with Public Launch Motel/Resort Private Residential/Association Totals Totals 7 17 30 46 100

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EXECUTIVE SUMMARY DRAFT for Public Review 5/7/2013 11:05 AM

Current AIS Prevention Efforts Lake George has benefitted from extensive outreach and education on invasive species, thanks to a consortium of organizations and agencies working together on this issue. The Lake George Park Commission sends out AIS information to all boaters on Lake George through the boater registration program, and partners with the Lake George Association on their Lake Steward Program. The LGA Lake Steward program is a proactive outreach and prevention program which maintains stewards at the six largest launch sites on Lake George. These stewards interact with a large percentage of individuals launching boats and conduct a voluntary external examination of the boat to see if any plants or other species are visible. In 2012, Lake Stewards inspected almost 6,972 boats prior to launching into Lake George and discovered 112 boats (1.6%) which had visible invasive species on the hull or trailer. These species were removed, thereby preventing additional AIS introductions into Lake George. The Lake Steward Program is tremendously beneficial in its outreach and education value, however, it is limited in its ability to determine whether a boat is contaminated with invasive species. A large number of invasive species may be transported and introduced during their microscopic, juvenile stage which may not be detected by a visual inspection. Further, the current Steward Program is a voluntary program that is presently too limited in its geographic extent and regulatory authority to ensure adequate long term protection against the introduction of aquatic invasive species at all the boat launches on Lake George. Public Outreach The Commission believes a well-informed public base is essential in selecting the most effective and cost efficient invasive species prevention alternative. Throughout the years 2011, 2012 and 2013 the Commission has held more than 30 public Invasive Species Committee meetings at locations throughout the Lake George basin. These meetings have been well attended by the public and also municipal representatives. Excellent feedback was received at these meetings, which has shaped this planning effort. In addition to the AIS Committee meetings, three separate public open house style meetings were held throughout August and September 2012 to inform the public and invite comment on the various alternatives under consideration. The first public meeting was designed to educate the Lake George boating community about the AIS issue and invite feedback on identifying alternatives to prevent AIS from entering Lake George. Information stations provided background information about the locations and status of aquatic invasives in Lake George, the invasive species that are present in regional waterbodies, and how invasive species may be transported. The second public meeting outlined the feasible alternatives to control the

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EXECUTIVE SUMMARY DRAFT for Public Review 5/7/2013 11:05 AM

introduction of AIS. This meeting concentrated on a number of preventative methods that would be employed to inhibit the introduction of new invasives in Lake George. This discussion included the environmental, social, and economic impacts of each of the alternative strategies. The public was invited to ask questions and select the alternative strategies they believe would be most effective for Lake George. A third public information meeting was held to introduce the public to the selected preferred strategy, which includes mandatory boat inspections of all trailered vessels prior to launch, with a standard of Clean, Drained, and Dry (C-D-D). In addition to these public meetings on the Plan, the Commission Executive Director has conducted dozens of presentations to a wide variety of organizations throughout the Lake George Park over the time of this planning effort, including more than a dozen municipal meetings. Alternatives Analysis The alternatives considered include: Lake George Alternative 1: No Action, which means the primary LGPC existing AIS prevention programs and actions would cease with the exception of its traditional outreach effort through annual mailings and announcements; Lake George Alternative 2: Enhanced Voluntary Compliance, a pro-active, non-regulatory approach that builds upon the existing framework of public outreach and the Lake Steward Program; Lake George Alternative 3: Regulatory Self-Certification, a program requiring boaters to self-certify that they will not launch into Lake George without having first met a set of standards; and Lake George Alternative 4: Regulatory Mandatory Boat Inspections, a mandatory inspection and decontamination (if necessary) of all boats prior to launching at Lake George. Alternative 5: Regulatory Mandatory Boat Inspections with After-Hours Self-Certification, a program that would operate as described in the Regulatory Mandatory Boat Inspection program described in Alternative 4 above, except that during unstaffed hours at public launches boaters would be allowed to forego inspection stations and launch their boat provided they have a self-certification form as proof of meeting the C-D-D protocol.). Alternative 6: Regulatory Registration of Nonmotorized boats, a program that requires all non-motorized vessels on Lake George to register and pay for an aquatic invasive species decal. Economic Impacts of Alternatives Lake George is the center of the regional tourism economy. The assessment of the economic impact of alternative methods to prevent the introduction of AIS into Lake George considered impacts to recreation and its associated impact to tourism expenditures and potential impacts to real property values. The specific alternative prevention measures assessed included a No Action alternative, implementation of a public education campaign, voluntary inspection of boats prior to entering the lake, self-certification by boat owners enabling them to perform their own inspection, and mandatory boat inspection. As a result of the overall assessment performed, the preferred alternative to prevent the introduction of AIS into Lake George is mandatory boat inspection. The most adverse economic impacts are anticipated to occur under the No Action alternative since this alternative would allow for the very limited control of AIS into Lake George. As such, economic analyses show the anticipated impacts of significant infestation of AIS estimated as follows: The loss in total annual tourism expenditures is estimated to range between $9.74 million to $48.7 million;

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The annual loss in visitor events is estimated to be approximately 146,600 to 733,000 events; Tourism-related employment is estimated to experience a net loss of approximately 162 to 800 jobs with a corresponding reduction in wages paid ranging from approximately $4.55 million to $22.74 million; A potential reduction of boating activity of ten to thirty percent (10%-30%); A potential reduction of swimming activity by twenty to eighty percent (20%-80%); A potential reduction in angler (fishing) days ranging between ten percent and thirty-five percent (10%-35%); An estimated average loss of real property values of approximately 4% among shoreline properties; and, An annual estimated loss in real property tax revenue ranging from approximately $91,000 to $627,000.

The Preferred Alternative The Preferred Alternative recommended in this Plan presents the highest level of prevention for new AIS introductions into Lake George, while working to minimize the inconvenience to boaters. The Preferred Alternative is the mandatory inspection, prior to launch, of all motorized boats that are brought by trailer to Lake George. The objective will be to prevent the introduction of aquatic invasive species into Lake George. Boats that exclusively recreate on Lake George and all non-motorized watercraft will be exempt from inspection. All qualifying boats will be required to visit one of the inspection stations that will be available at convenient locations around Lake George. Once the inspection process is complete, boats that have passed the C-D-D standard are fitted with an inspection tag that links the boat to the trailer. These boats may then be permitted to proceed to launch into Lake George. Those boats that do not meet the C-D-D standard have the option of being decontaminated. Presently, the most efficient means of decontamination is a High Pressure Hot Water (HPHW) process. Once decontaminated, the boat will be fitted with the inspection tag, and can then continue to launch. At each launch point, launch attendants will verify each boat has the proper inspection tag prior to launching. Those boats arriving at launches without the proper tags will be referred to the closest inspection station and will not be permitted to launch. Launch attendants will also be responsible for securing boats exiting the lake with a tag linking the boat to the trailer. This could certify that boats arriving at the launch with unbroken tags would launch without an additional inspection. Spread prevention is always a component of the message of C-D-D and boaters leaving the lake will be advised on appropriate spread prevention practices. The mandatory inspection process could be implemented by establishing regional inspection sites that boaters can conveniently access from major travel routes in the Lake George region that are in close proximity to high-volume boat launches. The system would focus on off-lake locations that are overseen by the Commission so as to provide the most consistent level of inspection for all boats and provide the most efficient way to track detailed data about the origins of boats, and the presence and type of AIS identified. A total of five inspection stations are recommended to be located in the towns of Ticonderoga, Hague, Bolton, Lake George and Queensbury. Potential Inspection Station Locations Town Potential Sites Lake George Exit 21 Site: Town of Lake George Landfill Bolton Norowal Marina or

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Hague Ticonderoga Queensbury

Site on County Route 11 Rogers Rock State Campground Mossy Point State Boat Launch Area of Ridge Road/SR 149

To make clear, these sites are shown to be good locations based on launch volume, access, and logistics. However, rights to operate at these locations have not been secured. The Commission would be responsible for project management and plan implementation, annual reporting, and working with all partners including federal, state, county, local governments, and not-for-profit organizations. Program implementation would require finding and developing inspection sites, working with marinas, training personnel, preparing MOUs with marinas and motels, preparing and operating a variable number of sites, scheduling personnel, closing sites down at the end of boating season, and preparing year end reports. The mandatory boat inspection program would require an initial source of funds for equipment and site development costs for the five inspection sites which are estimated at $300,000. In addition, an annual funding program will be needed to support wages and supplies for the inspection program. Total annual operational costs to run the five inspection stations are estimated at $700,000. There is no permanent source of funding to address the critical issue of AIS prevention for Lake George. Costs for AIS management have, so far, been borne by all the partners. Millions of dollars have been spent battling AIS over the past 26 years and it is estimated that other costs, including permitting and planning expenditures for these management efforts, represent an additional one million dollars. Possible funding sources for the mandatory inspection program include: Increased boat fees; Establishment of inspection and decontamination fees; Use of Warren County Occupancy Tax funds; Creation of a special Lake George Park tax district; Use of a portion of Warren County sales tax; use of a portion of the mortgage tax; Funds from the NYS General Fund; dedicated funds from the Environmental Protection Fund; Federal and state grants; and contributions from municipalities, private donations, and non-profit donations. Some of these sources are more feasible than others, and some are simply unlikely, however for the purposes of assessing all the potential options, all are considered. The Preferred funding option for the program is from revenues generated from increased boat registration fees and new boat inspection/decontamination fees. The Commission has not increased boat fees in over 10 years. There are limitations to what can be charged for inspection fees before the cost begins to impact the boaters desire to come to Lake George. Conversely, a reduction in the number of available inspection stations may create an inconvenience to boaters. The preferred funding option for the mandatory boat inspection program is summarized in the table below. A complete discussion of funding approaches is found in Section 5.1.9. Summary of Projected Annual Revenues from Preferred Funding Option Proposed Boat Registration Fees Estimated New Fees Generated

Lake George Boat Registrations 100% fee increase (equates to average of $35/year increase for boats under 25 feet in length, greater for larger boats)

$550,000

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Inspections Annual Inspection/Boat Wash Fee 2,600*** pay $40 Total

$100,000

$650,000

*Decrease of 700 annual registered boats from current level of 10,387 to LG due to impact of fee increase. ** Slight increase in temporary registrations due to decrease in annual registrations. *** Inspection fee is annual & includes boat washing services; Trailered boats also typically pay Temporary Boat Registrations.

To implement the preferred alternative of mandatory inspections of trailered boats for Lake George, the LGPC would have to undertake a regulatory effort to modify its current regulations. This effort would also likely require a statutory change to its boat registration fee schedule to provide funding for this effort. Authority over the LGPC fee schedules are set in law, and require approval by the NYS Legislature and the Governors office. The process to implement any new regulatory action will follow steps set forth in both the NYS State Environmental Quality Review Act (SEQRA) and the State Administrative Procedures Act (SAPA), among others. These processes ensure that the public is well informed of these initiatives, and that any new regulation meet appropriate standards for administrative and regulatory action.

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SECTION 1 PROJECT DESCRIPTION


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SECTION 1

PROJECT DESCRIPTION

1.1

Introduction

Lake George is experiencing a rapid escalation of introductions of aquatic invasive species (AIS). AIS have the potential to cause significant, long-term damage to the environment, result in a decline in the local tax base, and cost the public millions of dollars to control in the future. Every few years, a new species of aquatic invasive plants or animals are introduced into Lake George. The need for prevention, monitoring and management efforts continue to expand and have exceeded the ability of the Lake George Park Commission (Commission or LGPC) and its partners to fund under current budgets. The long-term management of AIS is thereby facing an unsustainable future. As of 2012, Lake George is challenged with an infestation of five aquatic invasive species: Eurasian watermilfoil (EWM), curly-leaf pondweed, spiny water flea, zebra mussels, and Asian clams. The LGPC currently manages only three of these AIS EWM, zebra mussels and Asian clams. Absent prevention strategies, dozens of aquatic invasive species may be introduced to Lake George. The primary vector by which these species may arrive is trailered boats coming in from nearby waterways such as Lake Champlain, the Hudson River, and from the Great Lakes and Finger Lakes region. The Lake George Aquatic Invasive Species Prevention Plan (Plan) presents a feasible plan that would limit future new AIS introductions to the greatest extent practical. The Action Plan is intended to identify and evaluate the alternative control technologies available and arrive at a preferred program.

1.2

Project Description

The objective of this undertaking is to analyze the current and potential impact of aquatic invasive species on Lake George, and to evaluate the current and potential management efforts employed to protect this resource. This plan will focus on AIS as defined by the Invasive Species Advisory Committee (ISAC) and in the NYS Invasive Species Management Plan 2010 (ISAC 2006 and NYS ISMP2010). Invasive species is defined as a non-native species to the ecosystem under consideration and whose introduction causes or is likely to cause economic or environmental harm or harm to human health (ISAC, 2006). The Plan is presented as a Draft Generic Environmental Impact Statement (DGEIS) prepared by the lead agency, the Lake George Park Commission (LGPC), in accordance with 6NYCRR 617, the State Environmental Quality Review Act (SEQRA) and 6NYCRR 643. The DGEIS may support an eventual rule making process that would be necessary to alter the Commissions current regulations.

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1.3

Location and Regional Context

The project is located at Lake George, widely known for its clarity and high water quality among all large lakes in the eastern United States. Lake George is also appreciated and enjoyed by tourists for its outstanding recreational resources. Lake George also maintains a high profile for its historic significance in the French and Indian War, Revolutionary War, and in the early development of the Adirondack Park. Lake George is approximately 55 miles north of the City of Albany, 150 miles north of New York City, and 143 miles from Montreal, Canada. Figure 1-1, Regional Location Map, illustrates the position of Lake George in New York State. The lake has a southnorth orientation with the south end forming the southern gateway into the Adirondack Park. The Adirondack Park is a 6.1 million-acre environmental and recreational paradise, the largest state-protected area in the contiguous United States, and the largest wilderness area east of the Mississippi River. A significant factor in the development of the tourism industry in the Lake George region is the fact that it flanks the southeastern boundary of the Adirondack Park and is adjacent to the Adirondack Northway (I-87). The Northway provides transportation access to the southern end of Lake George via its Exits 21-24, and the northern end of Lake George accessed by Exits 25-26. These routes provide millions of visitors from the north and south convenient access to marinas, overnight accommodations, restaurants, shopping and other services.

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Lake George has a robust tourism base that is highly seasonal. Resources spent on tourism development focus on retaining the existing tourism base and growing visitor trips to Lake George in the spring, fall and winter seasons. The Warren County Planning and Tourism Departments released their annual Visitor Occupancy Survey (2011) which provides a snapshot of visitor statistics. According to the findings of the on-line survey, over 7.9 million people visited Lake George in 2011. Approximately 40% utilized hotels, motels and other non-resident lodging; 11% stayed at local campgrounds, and 49% visited the area for a day trip. These visitors generated $487 million in sales tax in Warren County, the majority of which was spent in Lake George. Study indicators show a strong relationship between the quantity and quality of waterbased recreational activities and the exceptional water quality and clarity of Lake George with the overall success of tourism. The tourism base has been enhanced in recent years by adventure and heritage tourism themes. Newer attractions such as the Wild West Ranch and Adirondack Adventure, along with upgrades to existing facilities such as Six Flags Great Escape, continue to attract new and repeat visitors to the area. The Lake George Region has made a significant effort to fill most summer and fall weekends with events that have great appeal to a broad range of visitors with varying interests and socioeconomic characteristics. These events include Americade, the Adirondack Nationals Car Show, Lake George Arts Project Jazz Festival, the Adirondack Hot Air Balloon Festival, and weekly fireworks on Lake George. A complete analysis of tourism benefits is presented in Section 3, Economic Impacts and Analysis. 1.4 History and Background

Lake George is approximately 32 miles long and has an average width of 1.33 miles. The 45square mile lake has an average depth of 70 feet and a maximum depth of 196 feet. The maximum depth of the lake occurs in the south basin just north of Pilot Knob at Calves Pen and 190 feet west of Glenburnie, south of Anthonys Nose, in the north basin. The long linear shape of Lake George exposes approximately 176 miles of irregular and varied shoreline, which makes it challenging to both monitor and manage AIS. The lake lies at an elevation of 320 feet above sea level and its 233 square mile watershed is part of the Lake Champlain basin. Lake George drains to the north to an outlet dam known as the A Mill and a penstock (a pipe ten feet in diameter) located at the hydroelectric plant at the entrance of the LaChute River. The dam, built in 1903, is located about three-quarters of a mile beyond the natural rock dam at Ticonderoga. The penstock offers a means of discharging excess lake water into the river when the lake level is high. The LaChute River winds through the Ticonderoga business district and drains into Lake Champlain just west of Fort Ticonderoga. Lake George aligns on a slight northeast to southwest axis, which is typical of the fault pattern in the Adirondacks. In pre-glacial times, the lake flowed to the south and the outlet was by Dunhams Bay and the Queensbury Country Club along NY Route 149. The water entered Glacial Lake Albany that covered the Capital District. At the north end of Lake George, just beyond Snug Harbor Marina, is the natural sill or dam composed of bedrock that prevented the lake from flowing north during the pre-glacial period. During the last glacial period, as the glaciers retreated, a large landslide or outwash delta was formed in the former valley at the south end of the lake and created a dam. This landslide is evidenced by the golf course and the gravel pits along NY Route 9L (Hutchinson DR et al, 1981). Once flow to the south was blocked off due to this landslide, the outlet reverted to its present location approximately 7,000-10,000 years ago.

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The 1903 dam raised the lake level by approximately 3 feet which submerged additional areas along the lake shore. This area is ideally suited to support submerged aquatic plants. All of these events shaped the bathymetry of the lake, which has distinct zones of very deep water, as well as shallow water areas in the south and at major streams coming into the lake (Northwest Bay). Table 1-1. Physical Characteristics of Lake George Total Length 32 miles Maximum Width 2.05 miles (1.33 average) Maximum Depth 196 feet (69.7 ft. average) Surface Area 42.45 square miles Miles of Shoreline 131 miles Littoral Zone Area 8,058 acres Area within 500 of the shoreline 4,639 acres Watershed Area 149,120 acres Source: LaFleur, R., E.L. Shuster, and C.W. Boylen. 1994. Lake Georges surface area is 28,160 acres and its watershed is 149,120 acres. In most locations around the lake, the ridgelines that form the watershed boundaries are visually evident. See Figure 1-2, Lake George Park Commission Boundary Map, which represents a close approximation of the Lake George watershed. The total lake volume is estimated at 1,700,000 acre feet or 553,910,000,000 gallons. Using the average annual rainfall and the average annual runoff statistics, the water residence time in the lake is 8.7 years. Water entering the lake at the Sheriffs Dock culvert in Lake George Village will take roughly 8.7 years to discharge at Ticonderoga. The volume of water and long detention rate causes changes in water quality to occur over a protracted period of time. Following the discovery of Eurasian watermilfoil in 1985, Lake George became a laboratory for the study of AIS behavior in oligotrophic lakes. Numerous studies were initiated that assessed the impacts caused by EWM in a lake that had not been previously impacted by invasive species (Madsen, R.D., 1994). Lake George is now contending with five known aquatic invasive species infestations: curly-leaf pondweed, EWM, zebra mussels, Asian clams and spiny water flea. A state-of-the-art approach comprised of advocacy, education, outreach, research, surveillance, monitoring, and remediation is necessary for the comprehensive prevention and management of AIS in Lake George. A high level of cooperation and collaboration has occurred among a diverse partnership of civic organizations, municipalities and governmental agencies. This unique collaboration has enabled the efficient implementation of coordinated actions to address AIS. These partners include the Lake George Park Commission, Darrin Fresh Water Institute, Lake George Association, Fund for Lake George/Waterkeeper, Lake George Watershed Coalition, NYSDEC, Adirondack Park Agency, Warren County and nine municipalities around Lake George. Three task forces were established to address AIS issues as they occurred and as resources were needed. The Zebra Mussel Task Force was formed in 2000, and evolved into a more general Lake George Invasive Species Task Force in 2010. The Lake George Asian Clam Rapid Response Task Force was created in 2011 to specifically address the introduction of Asian clams.

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LGPC is therefore the primary entity responsible for AIS management and has helped lead community efforts to manage an annual Eurasian Watermilfoil Management Program since it was first discovered in Lake George in 1985. 1.5 Purpose and Need for AIS Control

The Commission was established by the NYS Legislature in 1961 with the following intent: 43-0101. Legislative Intent The preservation and enhancement of natural beauty in the state; the preservation and conservation of pure water supplies and other natural resources; the preservation and development of natural resources and recreational facilities for the benefit of the public; the promotion of the study of history, natural science, and lore; the conservation and protection of state lands in the forest preserve and areas adjacent thereto; and the promotion and preservation of the health and welfare of the public residing. Sojourning, or visiting therein being the concern of the state; the legislature hereby declares it to be in the public interest to preserve, protect, conserve and enhance the unique natural scenic beauty and to promote the study of the history, natural science, and lore of Lake George and the area near or adjacent thereto and to provide means whereby owners of real property near or adjacent to the lake. Other interested individuals, corporations, associations, organizations, and municipalities bordering on the lake ay preserve, protect and enhance the natural scenic beauty of the lake and its surrounding countryside and regulate the use of the lake and the area near or adjacent thereto for appropriate residential, conservation, health, recreational, and educational purposes. The intent of legislation is clear and the Commission has an obligation preserve and conserve the natural resources in the Lake George Park along with developing recreational facilities. There are readily identifiable AIS threats known to exist in the vicinity of Lake George and numerous means of transport of AIS to Lake George. Further, the federal government has provided a framework to form the basis of the need for AIS control. Based on Executive Order 13112 that required the development of Invasive Species Management Plans by federal, state and regional authorities, and the need to protect Lake George, the following goals will guide the formation of this Plan: Protect the unique aquatic resource at Lake George by limiting the introduction of aquatic invasive species; Protect the economic vitality of the Lake George region; and Allow fair, reasonable, recreational access to the lake without unduly jeopardizing protection of the lake. In addition, the Lake George Park Commission has a specific regulation relating to this issue prohibiting the launch of a vessel into Lake George without first inspecting it for invasive species. Section 646-1.6(h) of the Lake George Park Commission Rules and Regulations states: No person shall launch a vessel into or remove a vessel from the waters of the park without inspecting the vessel and its trailer, if any, to ensure the detection of marine growth, including macrophytes (weeds), or any other hull contamination, and removing said growth and disposing of it so as to ensure that it is not discharged into the waters of the park.

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The DGEIS sets out a method to fully implement Section 646-1.6(h) of the Commission Rules and Regulations. The DGEIS provides protocol for inspection methods to meet detection requirements, removal methods and disposal requirements. In the 1980s, there were only two AIS in NYS that were commonly viewed as a threat to lakesEurasian watermilfoil (EWM) and water chestnuts. Since 1985, the number of AIS in New York has increased to over 100 plants, mollusks, invertebrates and fish. Extensive EWM control programs were initiated in the Finger Lakes and across the Central NY region as a result of spreading EWM infestations. These programs primarily employed mechanical and hand harvesting methods to improve boating access and recreation. Between 1980 and 2003, there were over 30 reports of AIS being discovered in the Great Lakes (NYSISTF, 2005). In the early 1970s, statewide AIS control involved both harvesting and the use of contact herbicides to control water chestnuts in the Erie Canal system and some larger lakes and water bodies associated with the canals. This program had an emphasis on keeping navigation channels open and improving recreation for boaters. This program was eventually terminated due to a lack of federal funding. Within a short period of time, any level of control of water chestnuts was lost.

Photo Credit: Mike McMurray

The Lake George Associations Lake Steward Program reported that, based on survey information collected from boaters at 6 of the primary launch sites in 2012, boats launching on Lake George originated from 155 unique water bodies in 13 states and 2 Provinces in Canada. Many of the water bodies identified report the presence of AIS. As of 2007, the Great lakes reported a total of 184 non-native species, the St Lawrence River reported 87 AIS, Lake Champlain reported 48, and the Hudson River reported 91 (Lake Champlain Sea Grant). Lake Champlain presents perhaps the highest risk for AIS introduction in that it is separated from Lake George by just one mile away, and only four miles exist between the state boat launch at Ticonderoga on Lake Champlain and the state boat launch at Ticonderoga on Lake George (Mossy Point). Saratoga Lake, located just 35 miles south of Lake George, manages three AIS plant species plus zebra mussels. The Adirondack region is also experiencing AIS introduction into local lakes. Management efforts of EWM continue in such nearby lakes including Glen Lake, Lake Luzerne, Brant Lake, Lake Sunnyside, Schroon Lake and Hadlock Pond. See also Figure 1-3, Boater Origins Map, and Figure 1-4, Regional Invasives Map. The sheer cost of battling AIS in Lake George is driving the effort to prevent new AIS from being introduced to Lake George. There is no permanent source of funding to address the critical issue of AIS management at Lake George. Costs for AIS management have, so far, been borne by all the partners on one level or another. The majority of funding has come directly from the Lake George Park Commission and the NYS Environmental Protection Fund. It is estimated that a total of over $6.5 million has been spent battling AIS over the past 26 years. It is estimated that other costs, including permitting and planning expenditures, total $1.4 million. See Table 1-

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2,
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Spending Estimates for AIS Management 1986-2012. As the need for additional funds escalates year after year, new sources of funding must be found or generated through fees, or both. Spending for management activities is irregular year to year which makes it challenging to budget accurately. Reasonable funding levels that take into account prevention, monitoring, maintenance and eradication need to be established for future years. Table 1-2. Spending Estimates for AIS Management 1986-2012 AIS Type Management Timeframe Costs Eurasian Watermilfoil $4,500,000 26 Years Zebra Mussels $ 50,000 13 Years Asian Clams $1,500,000 2 Years Outreach and Education $ 500,000 26 Years Total Spending to Date $6,550,000
Source: LGPC. Note: Amounts represent estimates.

The cost of managing existing AIS is reported to be a minimum of 16:1 times higher than the cost of prevention (US Congress of Office of Technology Assessment, 1993). Over the last 26 years (1986-2012), it has cost the Lake George community an estimated $6.5 million dollars to combat EWM, zebra mussels and Asian clams. Though these expenditures have been necessary to maintain these invasive populations at manageable levels, Table 1-3, Economic Returns on AIS Management, indicates a better investment would have been prevention measures that inhibited the initial introduction of these species to Lake George. The future threat of new AIS introductions to Lake George is high and the outcome of large or extensive uncontrolled growth of AIS may result in significant impacts to the regional economy (see Section 4.0). AIS growth in as little as 200-800 acres of a widely utilized portion of the lake has the capacity to result in a loss in tourism of $10 million or more. Table 1-3. Economic Returns on AIS Management`

Source: Biosecurity Strategy for Victoria, 2009.

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1.6

Movement and Spread of Aquatic Invasive Species

The movement and spread of AIS is caused by both human activities and natural processes. Tracking the movement of aquatic invasive species is therefore a process that requires extensive investigation. A method that evaluates the overall potential for environmental damage from AIS has been adopted by New York State and the federal government. The Hazard Analysis Control Counter Measure Plan (HACCP) evaluates and prioritizes risks and threats associated with biological materials. It recommends a process that focuses control measures on the important vectors or transport mechanisms of AIS. The HACCP recommended process is presented in Appendix H. The logical approach to management of AIS transport is to focus on transport mechanisms that can be controlled and moderated. This is the same approach utilized by the federal government in recommendations to managers of refuges and parks. AIS management plans typically focus on documenting and controlling AIS introduction that is related to human activity including recreation, construction, and movement of equipment, including firefighting gear (USFWS, 2009 Managing Invasive Plants (MIP)). Potential vectors for the spread of AIS are numerous. A significant mechanism by which invasive species are transported worldwide is through commerce, such as in the aquarium and ornamental pond trade (Padilla and Williams 2004, Maki and Galatowitsch 2004). A survey of aquarium and fish pond owners was completed in 2004 following initiation of the Habitattitude program. An outreach effort of USFWS, Habitattitude is a program on the impacts of unwanted fish or plants from aquariums and fish ponds. This program is supported by See Grant and has been utilized by pet shop and other retailers (Green and Armson, 2005). A survey was carried out in two cities in both Minnesota and Pennsylvania. The response rate varied from 30-45% and the total number of responses was 1,077.The survey contained 24 questions and two are summarized below in Table 1-4, Summary of Responses of Aquarium and Pond Owners by Municipality. Table 1-4. Summary of Responses of Aquarium and Pond Owners, by Municipality Question Duluth Rochester Allentown Erie 42 (21%) 70 (33%) 63 (30%) 96 (33%) During the last 3 years did you have a live plant or animal that you wished to dispose of? During the last 3 years did you dispose of a 3 (1%) 10 (18%) 10 (18%) 22 (25%) plant or animal by releasing to a surface water or storm drain? Those individuals that had an unwanted aquarium or pond plant or animal and did not release it to the environment most often cited that it was not good for the animal or plant, or environment. This response correlates well to another question in the survey that asked if release of a plant or animal was an environmental problem. Between 74-88% of the respondents either agreed or strongly agreed with that statement (Green and Armson, 2005). This study shows that improper disposal of aquarium or pond plants or animals does occur, yet in 2005 there was an understanding that it was not good husbandry practice. Given the passage of time increasing awareness of the damage associated with invasive species, this potential source would continue to be a small contributor. The 2005 boater study (Holmes and Associates, 2006) identified that 70% of lake residents understood that invasive species were

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an issue which shows the knowledge was in place at that time. This level of knowledge should translate to positive action of using appropriate methods to dispose of unwanted plant or animal materials. Subsequent to transport through commerce, invasive species may be spread through such diverse activities as medicine, research, the wastewater industry, culinary arts, and religious ceremonies (Champion and Clayton 2000, Severinghaus and Chi, 1999). Aquatic invasive species may also be spread by wildlife. Specifically, waterfowl have the potential to spread aquatic invasive species on their bodies (Figuerola and Green 2002), but are more likely to transport AIS in their digestive tracts (Brochet et al. 2010, van Leeuwen et al, 2012). van Leeuwen et al. 2012 note, However, our taxonomic knowledge of which species are capable of surviving passage through the digestive system of waterbirds is still limited. For instance, Ayers et al. 2010 researched the viability of terrestrial plants excreted by Canada goose, and determined the Canada goose is not a frequent vector of seed dispersion. A more common vector of AIS is boats. Historically, the transoceanic movement of ballast water is thought to be the greatest single vector of AIS to the Great Lakes (Ricciardi, 2001). More recently, transient recreational boating patterns have been identified as a significant predictor in the overland dispersal of AIS (Leung et al., 2006, Murray et al., 2002, Bossenbroek et al., 2001, Piola et al., 2009, Rothlisberger et al., 2010). Boats are capable of transporting macrophytes overland on boat exteriors and trailers, and invasive animals have been demonstrated to be transported within the standing water that exists in boats (ie. Bilges, engines, live wells, ballast tanks), in mud and macrophytes that may be inadvertently hauled between water bodies, and attached directly to hulls (Johnson et al., 2001, Piola et al., 2009, Rothlisberger et al., 2010). Non-motorized boats such as canoes have also been established as vectors for AIS, however it is believed that canoes and similar vessels represent an insignificant contribution (<1%) to overall dispersal (Stasko et al., 2011). Invasive species propagule pressure is the transport frequency and number of individuals released during an introduction. This is a key factor in the establishment of aquatic invasive species populations (Kolar and Lodge, 2001). Increased propagule pressure increases the likelihood that a species may survive. Locally, in the Lake George region, there is little evidence to support a significant propagule pressure from anthropogenic introductions directly associated with international commerce and its associated vectors such as ornamental ponds, research, and culinary arts, which are not critical components of the local or regional economy. In other words, while other means of aquatic invasive species introduction should be taken into account and addressed, it is clear that the focus should be on addressing threats from transient boats from other lakes. As Lake George doesnt flood, there is no danger of overflow from ornamental ponds affecting the lake with exotic invasive species. Also, based on local experience, there are very few of these ponds in the Lake George watershed. Regarding religious ceremonies and ethnic groups exporting exotic species into the lake, demographics exhibit a relative lack of global ethnic diversity in the Lake George basin in general. As such, invasives introduced through ceremonies or for food sources are thought to be scant. General educational initiatives on keeping non-native species out of Lake George and its tributaries would be seen as the best means to address these vectors. The local and regional economy is tourism-based, and centers around outdoor recreational opportunities associated with Lake George (see section 4). Water-based activities, including thousands of visitors that annually travel to Lake George for recreational boating, are the cornerstone of this economy, and as such are believed to represent the most significant source of propagule pressure. Thus, in consideration of the risk posed by all potential vectors of AIS to

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Lake George, it is recommended the Commission pursue management of spread prevention with a focus on transport by trailered boats, because this is the most controllable and most common mechanism of AIS introduction (Rothlisberger, 2010).

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2.1

Water Quality

Lake George is widely considered to be one of the cleanest large lakes in the United States, with water clarities exceeding 40 feet in the central and northern portions of the lake. Lake George water quality has been well studied and the subject of continuous chemical monitoring since 1981. This work has been completed by DWFI and funded by the LGA and The Fund. Prior to 1981, extensive evaluation of the lake occurred between 1970-1976 as part of International Biome studies and the first evaluation of the lake took place in 1920 (C. Boylen, 1981). The waters of Lake George are considered nutrient poor resulting in low density growth of phytoplankton, which in turn, allows the water to be very clear. Lake George is oligotrophic and Secchi depth transparency is between 5 and 13m (CSLAP, 2010). The total phosphorus level varies, but is nearly always below 10 ug/l or 10 parts per billion (CSLAP, 2010). Water clarity is slightly less in the south basin, and total phosphorous concentration is higher in the south than in the north. Low water clarity and high nutrient levels in the south is a result of the larger watershed surrounding the south basin, development in south basin, and residence time of water in the south basin (Long et al., 1981 and Dillion, 1983). Many aquatic invasive species, when populations grow out of control, can have an impact on water quality and clarity. As all invasive species are living organisms, their die-off can alter the localized water chemistry, and ultimately result in increased algae and reduced clarity. 2.2 Ecology

The Lake George basin occupies two ecozones. The far north portion of the basin is found within the Lake Champlain Valley and the rest of the lake is in the eastern Adirondack foothills. The most common forest type is the northern hardwood forest at elevations below 2,500 feet and the Appalachian Oak Hickory Forest (Lake George Wild Forest Unit Management Plan, 2006). As with water quality, aquatic invasive species can have a tremendous negative impact on the existing ecology of Lake George. Many invasive macrophytes (water plants), including Eurasian Watermilfoil, Hydrilla, Brazilian Elodea and many others can form dense stands, crowding out native species and forming a monoculture. Along the same lines, many invasive species of fish and zooplankton can significantly alter the lakes food web, resulting in dramatic changes in the game fishery. 2.3 Fisheries

Lake George is considered a two-tiered fishery because it supports both cold water and warm water fish. The cold water salmonids are found in the deep water zone of the lake. These include Lake trout, Atlantic salmon, Brown trout, and Brook trout, which spawn in the fall in shallow water with rocky, cobble substrate. Lake trout spawning occurs from OctoberDecember when the temperature of the lake is approximately 51-57F (George, 1981). The salmonids rely upon smelt as an important portion of their diet. Juvenile lake trout will also prey upon native large body zooplankton including opossum shrimp or Mysidacea. Fish species that spawn in the spring include smelt and rainbow trout that both enter streams to lay eggs.

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Both smallmouth bass and largemouth bass are components of warm water fisheries and are found in shallow water areas around the lake. They spawn on clean, rocky shorelines in late May to early June. The yellow perch is another important game fish and is sought year round by fishermen. Young yellow perch feed on zooplankton and benthic invertebrates (George, 1981). Comprehensive fishery surveys have not been completed in Lake George during recent years. There is a limited annual effort to net lake trout in order to assess the condition and size of these fish, however this netting effort is insufficient to estimate the lake trout population of Lake George. An electrofishing effort to inventory the bass population has not been completed in over five years. It is feasible to assess the forage base of the fisheries by use of specially designed echolocation equipment (fish finder). Forage based high resolution echolocation inventories are routinely carried out on the Great Lakes (by both NYS and the Federal Government and Canada) and on Lake Champlain by the State of Vermont. High resolution echolocation equipment is not available to the local regional NYSDEC office. Understanding the forage base is critical to predicting the stability of the game fishery. Also, there are a number of invasive fish, including the European Rudd, that have replaced many of the native forage base fish, however, acoustic surveys cannot differentiate species changes (personal communication with R. Ferritino, 2012). As noted above, aquatic invasive species can greatly alter the existing fisheries in Lake George through alteration of the food chain, over predation of forage fish and zooplankton, and in many other ways. 2.4 Lake George as a Drinking Water Source

Lake George is the source of raw water for the Village of Lake George and Ticonderoga municipal water supplies. The raw water is filtered and is disinfected prior to delivery to the residents in these water supply districts. Lake George is classified by the NYSDEC as a Class AA special water body and is a suitable source for drinking water. The above community water supplies did not obtain a filtration avoidance determination, which would have required extensive watershed regulations to prevent water quality degradation associated with development and natural changes. An unknown number of homeowners continue to use Lake George as a source of potable water. The level of water treatment prior to consumption by homeowners varies from nothing to particulate filtration, followed by disinfection using ultraviolet light or chlorine treatment. The above treatment actions may not fully protect homeowners from water borne pathogens. The fact that Lake George is a drinking water source for tens of thousands of residents and visitors is one of the key factors in seeking aggressive protections against invasive species. As noted in Section 2.2 Water Quality, invasive species can alter in a negative way the water quality of a waterbody in a much more rapid fashion than would occur naturally. As such, this would put increased strain on the Village of Lake George water treatment plant, and also be cause for concern among the many residents who take their water directly from the lake.

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2.5

AIS Introduction into Lake George 2.5.1 Boat Launches

The number and distribution of the launches on Lake George make it challenging to control and enforce their use. As reported in Table 2-1,Summary of Launch Points, there are approximately 100 launch access points on Lake George. Seven of these sites are public launches operated by the state or municipalities; an additional 17 launches exist at commercial marinas around Lake George; and an additional 30 launch points are operated at motels and resorts. The remaining 46 launch points are associated with residences and association ramps. See Figure 2-3 for the distributions of boat launch locations. Table 2-1. Summary of Launch Points Total Launch Points 7 17 30 46 100

Launch Type State/Municipal Launch Commercial Marina with Public Launch Motel/Resort Private Residential/Association Totals
Source: LA Group

Table 2-2, Number of Launches Recorded by Lake Stewards in 2012, indicates the public launches receiving the highest volume of boats on Lake George - Mossy Point State Boat Launch, Rogers Rock State Campground, Hague Town Launch, and Norowal Marina were monitored by LGA Lake Stewards for a period of 90-97 days in 2012. Dunham's Bay Marina, in the southeast corner of Lake George, was monitored for a period of 16 days in late June/early July. Not only has the Lake Steward Program successfully intercepted boats bringing in and taking out invasive species at each of these launch points, it has collected important data on boater behavior, which guides the Commission in how to further outreach and educate boaters and where to focus enforcement efforts. Also, significant data was collected that has been useful in determining the pattern of use of trailered boats as well as their place of origin and the location of other lakes where they have been boating. This data provides critical information that projects the kind and level of risk for invasives that can be expected at each of the launch points. The Lake Steward Program reported that during 2012, boats originated from 155 different waterbodies in 13 states and 2 Provinces in Canada within 2 weeks prior to launching in Lake George. Thirteen (13) percent (921 boats) are considered "high risk" due to their point of origin of Lake Champlain, the Hudson River, Saratoga Lake, Lake Hopatcong (NJ), Atlantic Ocean, Long Island Sound, Schroon Lake, Candlewood Lake (CT), and the Connecticut River (See Figure 1-3). Table 2-2. Number of Launches Recorded by Lake Stewards in 2012 Total Launches 2,337 1,836 1,698

Launch Name Norowal Marina Mossy Point State Boat Launch Rogers Rock State Campground

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SECTION 2 Hague Town Boat Launch Dunhams Bay Marina Totals


Source: LGA

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2.5.2

In - Lake Transport

In-lake transport of AIS is a high concern for the Lake George. The primary cause of in-lake colonization by AIS is thought to be the transport of plant fragments and mud on boats and anchors. Lake George boaters enjoy anchoring in multiple locations throughout the lake and often move from bay to bay over the period of a weekend. They also engage in many varied activities that could expose anchors and equipment to contact with AIS. This includes fishing, water skiing in near shore areas, and anchoring. In addition, many, if not most of the marinas with public launching are located where there are existing beds of EWM and, in some cases, near Asian clam populations. Anchoring in these locations or just passing through these areas poses the potential for introduction of AIS to another location. Overcoming this problem would likely require limitations to anchoring in some locations, improved boater education, cleaning props, outdrives and anchors and special signage at the marinas and on the lake. Effective control in-lake movement of invasive species given these extreme difficulties and practicalities is highly unlikely. This issue makes prevention of new invasive species even more paramount, as once introduced, these species are likely to be spread within Lake George through boaters. 2.6 Existing Aquatic Invasive Species in Lake George

There are five known aquatic invasive species in Lake George. A profile of each species is found below. There are a number of confusing references describing aquatic invasive species in the public arena including exotic species, nuisance aquatic species, nuisance aquatic invasive species, and aquatic invasive species. These terms are generally used to identify species that are causing environmental or health damage. In recent years, regulations have been put in place to restrict the sale, transport, and use of specific species of plants or animals. In the process of developing these regulations, the definition of AIS has become more standardized. In addition, official lists of invasive species are constantly evolving. There are 183 exotic species commonly cited in the Great Lakes (Great Lakes Commission, 2007). These species include Chinook and Coho salmon, which were introduced by various states and the federal government to improve recreational opportunities on the Great Lakes. In New York State, the Nuisance Invasive Species Task Force (NYSISTF), consisting of a group of state agencies, is in the process of updating the NYS AIS list. See Appendix G for a preliminary list of terrestrial and aquatic invasive species established by the NYSISTF. The following sections are brief descriptions of key invasive plants and animals found in NYS, and the types of impacts associated with each species. In order to assess potential impacts each species, it is important to understand both the AIS and the water bodies they infest. Figure 2-1, Historic Lake George AIS Distributions 1985-2012, illustrates the changing concentrations of AIS throughout Lake George over a 27 year period. Figure 2-2, Lake George AIS Distributions 2012, provides an overview of conditions regarding three of the AIS currently known to be in the lake.

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2.6.1

Lake George Aquatic Plant Community

The Lake George aquatic plant community is comprised of approximately 59 species (Eichler and Boylen, 2000). Inventories of the aquatic plant community have been completed frequently over the years by the Darrin Fresh Water Institute and, therefore, very good information exists about the macrophyte community. The macrophyte community occupies the shallow water zone that extends from the shoreline to the water depth at which plants are no longer found. This area describes the littoral zone for the purposes of this report. In Lake George the maximum depth for rooted aquatic plants is 12m

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(Sheldon and Boylen, 1975). In general, however, the maximum depth for most plants in Lake George is 8m with most found between 0-6m (Eichler et.al, 2002). The area of the lakes entire littoral zone is 27.1 km or 6,695 acres, representing approximately 25% of the total lake area (27,217 acres) (Boylen and Kuliopulos). The width of littoral ranges from 1-3m (3-10ft) as along the east shore north of Pilot Knob where there are sheer cliffs, to locations where the entire embayment is within the littoral zone (Warner Bay, Dunhams Bay, and Sawmill Bay). The first 2-3 feet of water depth covers flooded lands that became submerged during the construction of the first dam in the Lake George outlet (http://www.lgpc.state.ny.us/lakelevel). In many locations and as early as one-hundred years ago, a fringe of submerged marshland existed along bay areas of the Lake George shoreline. The lake has since receded to become the current shoreline level. The submerged shallow areas are in many ways well suited for the growth of rooted plants, however, this same zone is subject to wave action that continually shifts sediments and is within an active area of ice scour during winter months. All the littoral zone is not suitable for plant growth and, for most species the precise characteristics needed for plants is highly variable or unknown. Most aquatic plans are normally found in soft sediments that are a mix of organic materials, silt, sand and clay. Unmixed sediments such as sand or clay flats are less suited to plant growth and normally lower plant densities are found in those areas. Areas of dense sand will not support macrophytes, however, sand with limited amounts of organic material will allow aquatic plants to grow (Cooke, Welch, Petersen and Nichols 2005). Since these areas have been found to support EWM grown, extensive AIS surveillance and monitoring of delta areas around Lake George have been completed on a regular basis (Eichler and Boylen, 2007). A compiled map of all areas of the littoral zone that support plant life has not been prepared for Lake George. However, extensive mapping of EWM as well as native plants (Eichler and Boylen 2009) shows that much of the littoral zone with low slope, mixed sediments of fine and course materials between 0-6m, will support the growth of macrophytes. If native macrophytes can survive at a certain location, it is safe to assume that invasive aquatic plants will also survive in that location. The growth pattern of EWM is somewhat instructive of a management of invasives. The numbers and locations of EWM continues to expand annually even with physical control instituted over the years (Lycott, 2010). At the same time explosive logarithmic growth is seen at the largest beds since these areas are most likely to reach sufficient plant density to rapidly grow by stolon growth, auto rejuvenation and accidental fragmentation (King 2012, and Madsen,1994). Lake George aquatic environment will support rapid aquatic macrophytes and mollusk growth (Lycott, 2012 and LGPC Interim Reports). The lakes littoral zone is especially important to this report since it is supports local tourism and represents the highest residential and commercial real estate value. It is the area that is occupied by beaches, boat docks, waterfronts, hotels, and restaurants and allows lake users to enter the lake. It is often an area of conflicts between user groups, landowners, anglers, boat operators, and the natural environment. The primary issue with invasive aquatic plants or animals is not the absolute area of coverage but the economic importance of the area of infestation. Therefore, AIS found in the Caldwell basin and along the west shore of Lake George between the Village of Lake George and Town of Bolton will have the highest potential for recreational and economic impacts than any other location on Lake George. It is recognized the undeveloped shoreline is an important component of the lake aesthetic, however, its role in providing access is limited.

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2.6.2

Curly-Leaf Pondweed

Curly-leaf pondweed (Potamogeton crispus L.) has been found in Lake George since the extensive plant survey in the 1970s (Ogden et al, 1976). Curly-leaf pondweed grows well in the early spring season and to some extent under the ice. The early season growth causes the plants to be readily visible in the early spring when other plants havent started to actively grow. Normally curly leaf pond weed would complete a full growth cycle and die back by late June. In recent years curlyleaf pondweed has exhibited a second cycle of growth in many lakes in New York, to an extent that Photo Credit: USFW the plant has remained in the water column during the entire growing season (personal communication M. Heilman and M. Belland, 2012). Curly-leaf pondweed is an aquatic invasive and, although it is widespread, it grows marginally and has had minimal impact in Lake George. It is a threat, however, to other lakes and the Plan should consider how to prevent the spread outside Lake George. 2.6.3 Eurasian Watermilfoil

In Lake George there has been a constant effort to control EWM since 1986. The plant was found in 1985 at Huddle Bay, Lake George Village and Huletts Landing, and has since spread to 191 locations on the lake. At this time, there are approximately 13 dense beds left to manage in the lake, plus a few dozen scattered sites. However, great progress has been made on controlling milfoil, and more than 90% of the sites are currently controlled or have been eliminated in Lake George. EWM is highly adaptable and is found across the entire continental Unites States except in Wyoming (EDD maps, 2012). The geographic extent and densities of this plant demonstrate its nuisance status (C.S. Smith, J.W. Barko 1990, M.S. Adam, N.L. Clesceri, 1986) and adaptability among ecosystems (Lycott 2011 and Boylen 1986). Research indicates that EWM forms dense mats that crowd out native plants, affects the structure of the natural food web, hinders recreation, and can decrease property values (see Section 4). EWM studies on Lake George include an evaluation of the impact of EWM on the native macrophyte community (Madsen, J.D. 1994). This study determined that due to its natural rapid growth cycle and ability to efficiently shade-out native species, EWM would outcompete and result in the displacement of native species. Following this research, additional studies were conducted and most of the results were repeated. EWM and other plants that grow at high Photo Credit: Invasive.org densities also have long-term environmental impacts on game fish and prey species. Frequently when EWM becomes dense, it prevents fish from being able to effectively feed on small prey. This causes the quantity of prey species to increase, which in turn causes the size of the individual animals to reduce. EWM beds cause game fish to expend more effort and energy to capture

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the small prey and this process reinforces the cycle of decreasing game fish size (Prisciandaro, No date). Over half of the sites with EWM in Lake George are located in the southern basin with the highest concentrations adjacent to intensively used areas with marinas in the Village of Lake George and hamlet of Bolton Landing. Shallow bays in the southern basin including Dunhams, Harris, and Warner also contained dense beds. In the northern basin, the lakeside hamlets of Hague, Huletts Landing, Putnam and the outlet to Lake George had the highest concentrations of plants. Control measures have been mechanical or physical, including suction harvesting, diver hand harvesting and benthic matting. Two attempts were made to obtain permits for application for herbicide use in 1986 and 1997. Ultimately, permits were not obtained. Data show that 173 of the 191 sites have been substantially cleared through management efforts through 2011 (Lycott, 2011). A total of 13 sites out of 191 continue to need additional management efforts including maintenance and eradication. Seven of these sites remain dense beds and eleven sites have moderately dense beds. Table 2-3, History of EWM Sites and Management Outcomes, indicates the number of reported EWM sites and their status at the conclusion of each survey year. The cumulative cost of management to date is $4.5 million representing an average spending of $166,000 per year. Table 2-3. History of EWM Sites and Management Outcomes Year Total # Density of Milfoil Growth EWM Sites Bed Moderate Scattered 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 3 22 43 55 66 76 91 97 106 N/A 111 118 123 127 134 136 141 144 146 148 149 157 160 171 3 9 8 8 12 13 11 16 21 N/A 26 25 28 31 34 28 24 23 22 20 18 17 14 16 0 0 0 0 6 8 7 4 13 N/A 13 11 11 7 7 8 11 7 6 8 10 9 8 6 0 13 29 35 23 19 27 40 10 N/A 5 9 13 6 4 3 4 4 3 2 2 0 6 9

Status New 3 19 21 12 11 10 15 6 9 N/A 1 7 5 4 7 2 5 3 2 2 1 8 3 11 Clear 0 0 6 12 25 36 46 37 62 N/A 67 73 72 83 91 94 103 110 114 112 115 127 132 140

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SECTION 2 Year 2009 2010 2011 2012 2.6.4 Total # EWM Sites 179 183 191 200 Zebra Mussel Density of Milfoil Growth Bed Moderate Scattered 9 9 7 6 6 2 11 11 0 1 0 9

EXISTING CONDITIONS Status New 8 4 8 9 Clear 164 171 173 174

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Source: Lycott Environmental Inc., 2012.

Adult stage zebra mussels were first discovered along the shoreline in the Village of Lake George in 1999 by divers with Bateaux Below (underwater archaeology organization). The Darrin Freshwater Institute (DFWI) confirmed the presence of several thousand mussels in Lake George Village directly adjacent to the commercial docks. This was the first confirmed evidence of adult zebra mussels although veligers (larvae) were previously found. The Lake George community established the Zebra Mussel Task Force in 2000 to quickly respond to the problem. This task force has evolved into the Lake George Invasive Species Task Force and addresses all invasive species. Zebra mussels have caused extensive damage to the Great Lakes ecosystem, interrupting food web interactions and damaging infrastructure while fostering nationwide and regional efforts to control movement of zebra mussels (ONeill and MacNeill, 1991). Zebra mussels are found in three states west of the 100th Meridian (Utah, Colorado, and California) and in all states east of the Mississippi River except Alabama, Georgia and Florida.

Photo Credit: Minnesota Department of Natural Resources

Zebra mussels are clearly capable of being invasive species yet conditions have to be suitable in a water body for the mussels to achieve explosive or extensive growth. In part, control and elimination of zebra mussels from Lake George were aided by the water of the lake being too low in calcium. The prevalence of zebra mussel infestation on Lake George in the area of boat launches indicates that import by boat is a likely source (see Figure 2-3). DFWI continues to lead and conduct the research, monitoring and removal associated with the control of zebra mussels in Lake George. Over a period of two months, researchers enlisted the assistance of volunteer SCUBA diving teams to hand harvest more than 21,000 zebra mussels from the sites (3,900 square meters) and successfully removed what is estimated to be more

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than 90 percent of a mussel infestation. DFWIs surveillance of the lake has since resulted in the discovery of eight new colonies of zebra mussels. Each is being systematically removed through SCUBA dives in the same way that the initial site was cleared.Between1999-2009, over 25,000 zebra mussels were removed from Lake George in 11 areas. Continued investigation and monitoring of the site for larvae suggests that the mussels have not successfully reproduced since the removal began 12 years ago. There is good evidence to suggest that zebra mussels will not thrive in Lake George, because calcium levels in the lake are generally lower than the organism prefers (Wimbush, J. et al., 2009). Table 2-4, History of Zebra Mussel Sites and Management Outcomes, presents the status of control efforts. Partners at Lake George are addressing threats from zebra mussels by advancing proactive means to prevent their introduction by continuing to monitor, physically remove, and implement a lakewide zebra mussel control program of public education and outreach, and through regular reporting and assessments of results and knowledgebased support of existing as well as possible future control programs. The total cost of surveillance, monitoring, and removal is estimated at $50,000 since 2000. Table 2-4. History of Zebra Mussel Sites and Management Outcomes Location Date Mussels Discovered Removed to Date Lake George Village 1999 21,278 Lake George Village Cleverdale 2004 1,380 Queensbury Mossy Point 2004 1,816 Ticonderoga Sandy Bay 2006 451 Queensbury Rogers Rock 2007 231 Hague Yankee Boating Center 2007 36 Lake George Castaway Marina 2007 47 Queensbury Treasure CoveDiam. Pt. 2008 188 Diamond Point BeckleysDiam. Pt. 2008 22 Diamond Point Middle Bay 2009 26 Bolton Total 25,475
Source: Lake George Association (http://www.lakegeorgeassociation.org/what-we-do/InvasiveSpecies/Zebra-Mussels.asp.)

2.6.5

Asian Clam

The Asian clam (Corbicula fluminea) is believed to be the most serious AIS infestation in Lake George. Asian clams can reproduce prolifically and reach densities of thousands of clams per square meter, as evidenced in Lake Tahoe and some New York State lakes. As they die off, the result can be biofouling of the water with increases in algae blooms, and large swaths of area covered with sharp clam shells. Given their preferred habitat is sand, this is of grave concern for the beach areas in Lake George. In fact, the largest area of infestation is in the Village of Lake George, the shoreline of which is mostly sandy and occupied my multi-million dollar resorts. Since discovery in 2010, this species is known to have infested eight locations throughout Lake George. The Asian clam was first discovered in August 2010 by DFWI. A group of civic and governmental groups quickly formed the Lake George Asian Clam Rapid Response Task Force (LGACRRTF), which developed and implemented a containment and eradication plan. Three of the four known sites were treated in 2011 under permits and approvals received from the Adirondack Park Agency, Department of Environmental Conservation, US Army Corps of Engineers, Office of General Services and State Historic Preservation Office.

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A total of four sites were treated in 2011 using 1,148 benthic mats and one site was treated with suction harvesting. According to the Lake George Asian Clam Rapid Response Task Force the Lake George benthic barrier effort is one of the largest mounted against Asian clams in the U.S (http://www.lcbp.org/PDFs/LGACRRTF_201 1_Report%20_2012_Plan.pdf). See Table 2-5, Asian Clam Population Distributions, for more detailed information. The results indicate that an estimated 99 percent of all Asian clams were killed in Lake George Village following two matting treatments. Good but limited results were also obtained with benthic barriers at Norowal Marina. Suction harvesting was the initial treatment implemented at Photo Credit: Skaneatelestalk.com the Middleworth Bay site located near Treasure Cove Resort. The results did not meet treatment expectations and this site has seen minimal management since that time. Surveillance of Asian clams is a critical part of the management program. In 2010, DFWI examined 40 areas in the south end of the lake. Three infestations of the Asian clam were found in 2011 as part of both EWM control work and through a lakewide survey of 173 sites of high-risk and suitable-habitat areas coordinated by the Lake George Association and Lake George Watershed Coalition on behalf of the Lake George Asian Clam Rapid Response Task Force. A total of 213 sites have been surveyed across Lake George for the presence of the Asian clams, and no additional infestation sites were found. However, in the fall of 2012, a lakewide surveillance effort was carried out to test for Asian clams. A group of 30 volunteers took up to 30,000 samples from the bottom of the lake at locations conducive for Asian clams. This effort revealed an additional four new areas of Asian clam populations. The total cost for treatment efforts in 2011 was over $630,000 in direct material and services costs. This does not include the in-kind services provided by the local governments in the Towns of Bolton and Lake George.
Source: Lake George Association

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and the Village of Lake George, or the assistance from the staff of the Lake George Park Commission, or staff time and support from the many private not-for-profit and governmental organizations involved in this work. For more information and the current status of the fight against this existing threat, go to www.stoptheasianclam.info. Table 2-5. Asian Clam Population Distributions Shoreline Location Lake George Village Middleworth Bay Location by Town Lake George Village Bolton Date 2010 2011 2011 2011 2012 2012 2012 2012 Type of Treatment Benthic Mats Suction Harvesting and Benthic Mats Benthic Mats Benthic Mats Benthic Mats Benthic Mats Benthic Mats Benthic Mats

Boon Bay Bolton Norowal Marina Bolton Lake Forest Acres Hague Hwang Site Queensbury Diamond Cove Resort Diamond Point, Lake George Shelving Rock Bay Fort Ann 2.6.6 Spiny Water Flea Task Force Source: Asian Clam Rapid Response 2.6 Spiny Water Flea

The possible presence of the spiny water flea was first reported on July 27, 2012 by a Lake Steward with the Lake George Association at DEC's Mossy Point State Boat Launch near the north end of the lake. A fisherman reported having a clump of small organisms on his fishing line after spending time trolling the waters off Mallory Island along the east shore of the lake. The samples were taken to the Darrin Fresh Water Institute where four spiny water fleas were identified. The Lake George Association sampled the waters off Mallory Island and further confirmed its presence. While it is not clear when or how the spiny water flea was introduced into the lake, it is believed that the initial introduction was through adult, larvae or eggs being transported to the waters by bait bucket, bilge water, live well, boat, or other equipment. Currently, there are no successful means to control or eradicate this and many other aquatic invasive species, so preventing their spread is the only means for reducing their impacts on native aquatic communities. Signage has been posted warning boaters, anglers and other recreational enthusiasts to take precautions to avoid transporting this and other invasive species, particularly after leaving waters known to have an aquatic invasive species. The spiny water flea spends a portion of the day in the deep water in the darkness to avoid predation by open water feeding fish. The open water feeding fish in Lake George include smelt and small lake trout. At dusk, the spiny water flea mitigates vertically as does the Mysis relicta, a native large body zooplankton. Both the spiny water flea and Mysis relicta feed on zooplankton. In other waterbodies, spiny water flea populations have grown rapidly and outcompeted the natives for food (Ontario Invading Species). The spiny water flea has been found to be less digestible to juvenile forage fish, such as smelt (Sea Grant Michigan, 2004), which can result in smaller populations of these fish, and consequently the population of game fish that feed on them (Bunnel, D.et al, 2011). Significant changes in the salmon fisheries on Lake Michigan and Lake Huron are

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linked to the combined changes associated with spiny water flea, zebra mussels and changes in forage fish (Bunnel, D. et al., 2011 and Diane, J.S. and E. LaPorte, 2012). 2.7 Aquatic Invasive Species Threats to Lake George

Current NYSISTF Data as well as an Invasive Species Biology Summary provided within within Appendix G provide a comprehensive survey of invasive species that represent a risk to Lake George. Table 2-6 below, Future AIS Risks for Lake George, summarizes the invasive species that presently represent the highest risk to Lake George. These species include both macrophytes and small bodied organisms that may be transported by trailered boats. Furthermore, each of these invasive species may be found in other New York State waterbodies or within waterbodies that Lake George boaters most frequently report visiting within 2 weeks pior to launch on Lake George (Summary of 2008-2012 Lake George Steward Program Data, Lake George Association). Among these species are the macrophytes Brazilian waterweed, Hydrilla, and waterchestnut which are known to form dense beds of vegetation that impact recreation and alter Lake ecology). As noted in section 1.6, the primary transport mechanism for these species is entanglement on boats and boat trailers. As noted in section 1, the primary transport mechanism for small bodied organisms is via standing water that exists in boats (ie. bilges, engines, live wells, ballast tanks), in mud and macrophytes that may be inadvertently hauled between water bodies, and direct attachment to hulls (Johnson et al., 2001, Piola et al., 2009, Rothlisberger et al., 2010). Some of the invasive species that may be transported in a relatively invisible state amidst bilge water and livewells include those that pose a great risk of introduction to Lake George, such as the Quagga mussel, Fishhook wateflea, Bloody Red Shrimp, and New Zealand mudsnail. Other invasive species located within New York State waters that spread in this manner include the Asian clam and the Zebra mussel, which already exist in Lake George. Based on the physiology of each of the aforementioned small bodied organisms, it is believed that each may survive and thrive within the Lake George environment. Lake Georges calcium concentrations (12.4 ppm Ca) are currently above the threshold for survivorship of the Quagga mussel. Though presently at the lower threshold for survivorship, calcium concentrations have increased 65% over the last 25+ years and continue to rise (unpublished Darrin Freshwater Institute). It is also noted that micro-niches exist in the Lake where development causes localized calcium concentrations on the order of 40-80ppm (Cohen & Weinstein 2001, unpublished Darrin Freshwater Institute), which is sufficient to allow for successful populations of Quagga as well as Zebra mussels (Whittier et al. 2008). Further, the Asian clam population in Lake George has been demonstrated to cause localized increases in calcium concentrations creating an environment conducive to the Quagga mussel as well as Zebra mussel (unpublished Darrin Freshwater Institute). With lakewide calcium concentrations and the distribution of high calcium micro environments on the rise, the introduction of the quagga mussel represents a real threat to Lake George. In contrast with the quagga mussel, the New Zealand mudsnail has a lower calcium threshold of 7ppm with a pH of >6.9, and may immediately thrive throughout the Lake George environment. (http://www.dfo-mpo.gc.ca/CSAS/Csas/publications/sar-as/2010/2010_065-eng.pdf). Other small bodied invasives in close proximity such as the bloody red shrimp and fish hook waterflea are known to have high tolerance for environmental variability, and may also thrive in the Lake George Environment (Wittmann 2007 [shrimp]). Details pertaining to the origin and ecosystem impacts of each of these invasive species may be found in Appendix G.

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Lastly, reintroduction of existing small bodied invasives such as Asian clam and zebra mussel may undercut existing management efforts. As such, these remain a threat at Lake George boat launches. Table 2-6. Future AIS Risks for Lake George Species Current Location Bloody Red Shrimp Brazillian waterweed Carolina fanwort Found in the Great Lakes. Found in Orange & Westchester Counties. Has been moved by aquarium trade but will reproduce vegetatively. Found in Hunt Lake, Jenny Lake, Efner Lake & Mill Lake in Saratoga County (has not grown explosively over the last 20+ years). Found regionally. Status in Lake George unknown. Lake Champlain and Champlain Canal; lake Ontario drainage area. Escaped from an experimental station in Ottawa 1932, found in Lake Champlain in 1999. Plant produces stolons-overwintering buds that form dense mat formations. Found in the Great Lakes, Finger Lakes, and the St. Lawrence River. Found in Orange Co., Broome County, Ithaca, NY and near Buffalo in barge canal. Capable of growing rapidly in these well-buffered waters. Some evidence shows that it will grow in soft water, but that information is limited. This is a very adaptable plant (Madsen, J.D. and C.S. Owens, 2000). Found in the Great Lakes and St. Lawrence River Found regionally, but some natural control is occurring. Found in Mohawk River and Great Lakes. Well adapted to cold water. All found in Great Lakes. In Lake Champlain, Mohawk River. The nut seed is nearly impossible to kill; most likely introduced in mud or debris. Easy to control if caught early but may grow rapidly.

Likely Transport Mechanism Ballast, livewells, bait buckets, etc. Entanglement on trailered boats, or dumped. Entanglement on trailered boats, or dumped.

Common reedgrass European Frog-bit

Seed dispersal, construction disturbance. Entanglement on trailered boats, or dumped.

Fishhook Waterflea Hydrilla

Ballast, livewells, bait buckets,fishing equipment. Entanglement on trailered boats.

New Zealand Mud Snail Purple loosestrife Quagga mussel Round goby, rudd, and rusty crayfish Water chestnut

Attached to entangled macrophytes, livewells, bait buckets, etc. Seed dispersal. Hull fouling, ballast, livewells, bait buckets, etc. Bait transport. Entanglement on trailered boats, anchor debris.

Source: Eichler, 2009, and Invasive Plant Atlas, 2013

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2.8

Aquatic Invasive Species Spread Prevention Programs

Many states, particularly in the western U.S., have established programs to address existing and anticipated AIS invasions. This section describes and compares the existing programs in western states, states across the Northeast, and New York State to gain an understanding of what approaches have been the most successful. A summary of findings of the spread prevention programs is provided in Table 2-7 and 2-9. 2.8.1 AIS Prevention Initiatives in Western States

The approach to AIS management has been more focused and aggressive in the western U.S. due to the 100th Meridian Initiative (see below). The Initiative addresses AIS control in the vast landholdings by federal government of large reservoir systems, and the regional irrigation network water diversion and projects. Where it is a less complicated process to conceptualize the potential for zebra mussel damage. Many western states also receive significantly less rainfall, therefore, water is very important and is moved great distances to serve regional needs. In order to protect the agricultural production, most states in the west have weed control districts and restrictions on the movement of fruits and vegetables. This large-scale approach to biological threats has become the foundation to AIS control in the west. Information was compiled from each state by reviewing various websites operated by both the federal Underwater Matting of Asian Clams. Photo Credit: government and states. Lake George Association
8

The survey examined trends that emerged in the strategies selected and the overall success of the programs. There are two approaches a statewide approach and a lake by lake approach. Table 2-7, Aquatic Invasive Species Prevention Programs by State, illustrates the three basic strategies for AIS prevention: voluntary inspection programs; self-certification programs; and mandatory boat inspections/ decontamination programs. Many states have no compliance program whatsoever. As can be seen by Table 2-7, most states have elected to implement a voluntary approach, however, some states are not finding voluntary inspections to be effective and are switching the entire program over to mandatory programs or including individual lakes into mandatory programs. Other states have evolved their prevention approach into hybrid self-certification/inspection programs. A description of these programs is provided below for the 100th Meridian Initiative, and the states of California, Colorado, Idaho, and Minnesota. Table 2-7. Aquatic Invasive Species Prevention Programs by State Voluntary Inspection Self-Certification Varying Levels of Mandatory C-D-D and Outreach Programs Inspection and Decontamination Connecticut Idaho Arizona (Oregon Sea Grant) Iowa Oregon (plus roadside California: Lake Tahoe inspection) Maine Massachusetts Colorado: Lake Pueblo

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SECTION 2 Voluntary Inspection and Outreach Nebraska Nevada New Hampshire New York: Lake George Self-Certification Programs (multiple lakes)

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Varying Levels of Mandatory C-D-D Inspection and Decontamination Idaho: Mandatory inspection when station in operation Minnesota: multiple lakes Montana New Mexico (Mandatory decontamination after boating in AIS waters) Oregon: multiple lakes

North Dakota: (multiple lakes; inspection only) Oklahoma Washington: multiple lakes Rhode Island Wyoming: multiple lakes South Dakota Texas Vermont Note: Lakes and reservoirs operated, managed or controlled by federal agencies may have mandatory inspection programs on individual lakes in their jurisdictions (Lake Mead, Big Flathead Lake, Lake Powell (which shifted from self-certification program to mandatory inspections in 2009) and others). (See Table 2-9 for sources) (Lam J. 2013). 100th Meridian Initiative The 100th Meridian Initiative is a strategic regional strategy to prevent the spread of zebra mussels and other AIS into 100th meridian jurisdictions and western states. It is comprised of federal (National Park Service, US Fish and Wildlife, Bureau of Land Management, and USACOE), state, tribal, and provincial entities and includes the following states: Texas, Oklahoma, Kansas, Nebraska, North Dakota, South Dakota, and Manitoba. This program focuses on AIS through information and education, voluntary boat inspections and boater surveys, commercially hauled boats, monitoring, rapid response, identification and risk assessment of additional pathways, and evaluation. Most states have passed laws against transport of AIS with emphasis on zebra mussels. Laws also require boats to be inspected when inspection stations are open. Table 2-9, Summary of Prevention Methods in Western States. In most locations, at least 10% of boats inspected require decontamination (St. George News, 2011). There is a wide variation in requirements for inspections among all the states. Some states do not inspect at all, some operate inspect out of state boats only, some inspect only when random road stations are open, some quarantine all boats until they are decontaminated, and some inspect all boats or have a combination of the above procedures. The clear trend is for more required inspections following departure from an AIS contaminated waterbody. Lake Tahoe The state of California has mandatory boat inspections on several reservoirs and selected lakes. The Tahoe Regional Planning Agency (TRPA) has been administering a mandatory boat inspection program on Lake Tahoe since 2008. TRPAs prevention program started out with a Voluntary Inspection Stewardship Program in 2007. Mandatory Inspections that were based at marina launches were initiated in 2009.This program has been modified to accommodate needed adjustments for consistency and convenience. One of those modifications relocated the physical inspection stations and responsibility for the inspection process from on-lake marinas to five regional roadside off-lake inspection stations. Marina operators with launches are required to verify the proper inspection tags are on the boat. The law makes it both illegal for a

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boater to launch a boat that has not been inspected and for a launch operator to permit the launching of a boat that has not been inspected. Annual fees are charged for all boats. Annual fees range from $30- $121. Decontamination fees are $25 per wash. No fees are charged for inspection and decontamination of non-motorized canoes, kayaks and paddleboards. Table 2-8, Lake Tahoe Boat Inspection Fee Structure, indicates the complete range of fees for all boat types. Specific elements of the program are: Transport law prohibits the transport or introduction of AIS; Clean-Drained-Dry is the standard; Wire inspection seals are utilized; Mandatory decontamination for any boats that do not pass inspection; Program augmented outreach and education; Launches are closed when not manned by inspectors; MOUs govern private launches and resort business launches; Program is enforced by marine patrol; and Funding is through fees and federal grants. The TRPA program believes that mandatory inspections are proven to be a highly effective AIS prevention tool. In 2012, only a single boater was found without a proper inspection tag and, since the mandatory inspection program was initiated there have been no new introductions of AIS reported. Table 2-8. Lake Tahoe Boat Inspection Fee Structure
Source: http://tahoeboatinspections.com/welcome-to-tahoe-boat-inspections/

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Colorado Prevention began with voluntary Stop the Hitchhiker outreach and education and continued active surveillance and monitoring program in Colorado. The first detection of AIS (zebra and quagga mussel larvae) in Colorado waters occurred in 2007 at Pueblo Reservoir in Pueblo State Park. The discovery of AIS larvae caused immediate closure of the boat launches on Pueblo Reservoir. The following year there was mandatory inspections at Pueblo Reservoir. The last discovery of zebra mussels was in 2009 when two adults were last found during sampling efforts, however, juvenile mussels were still being found in the waters of the lake. Boats are therefore also required to be inspected and possibly decontaminated when exiting Pueblo Lake. The mandatory inspection program is considered to be highly effective and will be expanded as funding is available. The boat inspection program in Colorado evolved from mandatory inspection of out of state boats to a program of containment requiring inspection on certain waterbodies. The mandatory program was put in place in 2012. The state of Colorado adopted a law requiring all persons transporting a vessel to submit to inspection for boats that have been in another states waters in the 30 days prior, for boats not registered in Colorado, and for boats that have been on a Colorado lake with AIS. There are 59 lakes with mandatory inspection some due to need to control EWM or the discovery of larvae of zebra or quagga or operator of reservoir or lake is requiring inspection. The launches are closed when inspection is not available. Inspection hours vary greatly and most waterbodies are prohibiting overnight beaching or mooring of boats. Most sites inspect boats upon entry and at retrieval. Three Colorado Parks and Wildlife officers inspect during normal business hours at eight privately operated inspection locations. Inspected boats have a green seal zip-tie to identify that the boat has been inspected. Boats with a green seal must stop at operating inspection sites. Fees for the program vary. Specific elements of the program are: Transport law prohibits the transport or introduction of AIS; Clean-Drained-Dry is the standard; Green inspection seals are utilized; Mandatory decontamination for any boats that do not pass inspection; Program augmented outreach and education; Launches are closed on most lakes when not manned by inspectors; Program is enforced by Colorado Parks and Wildlife; Roving patrols randomly conduct inspections; and Funding is through fees and state and federal grants. Idaho The Idaho Department of Agriculture began operating mandatory watercraft inspection stations in the spring of 2009. The program requires that any boat that is registered in Idaho or another state and any non-motorized vessel must purchase and display Idaho Invasive Species Fund decals for an annual fee. All watercraft is subject to inspection when inspection stations are open. In 2011, 15 inspection stations were in operation and no zebra or quagga mussels have been found in Idaho waters. This program is run in conjunction with an Early Detection/Rapid Response (EDRR), a monitoring program for invasives which is a critical second defense against invasive species. EDRR increases the likelihood that localized populations will be found, contained, and eradicated before they become widely established. This EDRR plan mirrors a similar Columbia Basin rapid response plan that is being developed for the control of zebra\quagga mussels, which have been recently detected in the nearby Colorado River system (2011 Idaho Invasive Species Program Summary).

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Specific elements of the program are: Roadside inspection stations open 7 days a week 7am-7pm; Clean-Drained-Dry is the standard; Funding derived from Invasive Species Stickers that are sold for $22 for non-resident boats and $7 for non-motorized craft; no fee for resident boats; Anyone transporting a watercraft (powerboats and car top watercraft) must stop at boat inspection station; and Program augmented outreach and education. Minnesota Minnesota created the Watercraft Inspection Program in 1992 in response to legislation proposed by the Department of Natural Resources, Minnesota Lakes Association, and angling groups. The goal of the program is to prevent the spread of invasive species through boater education, watercraft inspections and watercraft decontaminations at public water accesses. In 2010, the Minnesota legislature added to the existing transport rule, a requirement that boaters had to drain the boat bilge when leaving a waterbody. Some lakes have inspection stations to contain AIS at those locations. Minnesota continues to focus on containment by limiting export of AIS from contaminated lakes to lakes without AIS. Most lakes without AIS dont have inspectors, however, in 2010, 42 lakes had citizen inspection teams and 2011, 44 lakes or local municipalities aided in AIS-related inspections. Boat owners have to become trained in CDD by completing a computer based instruction class. The majority of citations were warnings. Enforcement activities are increasing. In 2010, conservation officers spent 12,800 hours on AIS which is up from 4,800 hours in 2009. In 2011, 13,629 hours of conservation officer AIS enforcement activity occurred. Written citations have increased from 159 in 2010 to 487 in 2011 reflecting the move from warnings to actual citations due to the length the program has been in place (Minnesota Invasive Species Program 2010 and 2011). 2011 legislation aimed at strengthening Minnesotas ability to prevent the spread of AIS gave watercraft inspectors new authority to inspect, remove, drain, decontaminate or treat waterrelated equipment. Authorized inspectors can prohibit the launching or operation of waterrelated equipment if a person refuses to allow an inspection, or doesnt remove water or aquatic invasive species. Authorized inspectors can also require a watercraft to be decontaminated prior to launching into state waters. Minnesota DNR legislation in the 2011 report recognizes that regulation on transport of AIS should focus on moving biological debris that may not be recognized as an AIS and that water related shore equipment need to be inspected. In 2010, 14 additional waterbodies were found to have EWM followed by ten more in 2011.Zebra mussels were found in three new lakes in 2010 and eight additional lakes in 2011. Also in 2012 the City of Minneapolis started mandatory inspections at entry points at three (3) lakes within their park system. The mandatory inspection at containment lakes enforcement and selfcertification has not stopped the spread of EWM or zebra mussel in Minnesota (Minnesota Invasive Species Program 2010 and 2011). , a study of costs associated with varying levels of inspections was completed in 2012 (Thompson 2012). This study examined options from operating 55-3,600 inspection stations in a state with 11,842 lakes and 2,000 access points. Specific elements of the program are: Roadside inspection stations open 7 days a week 7am-7pm; Clean-Drained-Dry is the standard; Budget is over $4M; Funding derived from a surcharge on watercraft licenses, a surcharge on non-resident fishing licenses, and the states general fund; Surcharge for a three year license period is $5, or $1.67 per year;

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Anyone transporting a watercraft must stop at boat inspection station; and Additional appropriations, primarily for specific research efforts, have come from the Environment and Natural Resources Trust Fund and Minnesota Future Resources Fund. Federal grants are also sought to help fund program efforts.

Source: Montana Department of Agriculture AIS Prevention

Table 2-9.
State ARIZONA

Summary of AIS Prevention Methods in Western States


AIS Trans Transport prohibited C-D-D Cleaning Procedures HWHP selfcertification EWM Lake Mead 1/2007 8 counties 25 counties Zebra Mussel None Law Required inspection when entering state and at NPS facilities Lake specific mandatory inspection and 15 entry sites inspection stations Mandatory/Self with Stations 47,000 inspection 2011, 25 mussel foul

CALIFORNIA

Transport prohibited of specific species

HWHP

1 zebra mussel 26 quagga

COLORADO IDAHO

Transport prohibited Transport prohibited

HWHP HWHP

1 water body 12 counties

2-1 contained No state-wide Monitoring

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State

AIS Trans

C-D-D

EWM

KANSAS

MONTANA

Transport prohibit of specific ANS Prohibit transport of species specific

clean and dry for 5 days

24 WB

10 WB

Law boats Sticker required No boat inspection

Inspect clean dry Random inspection HWHP

4 counties

None

NEBRASKA

NEVADA NEW MEXICO NORTH DAKOTA OKLAHOMA

OREGON

Specific ANS trans. prohibited transport prohibited Transport prohibited No veg. transport in boat Remove aquatic plants Transport prohibited of specific species

HPHW

7 counties 1 county 7 counties 2 counties 17 counties 23 counties

4 waterbodies None None 1 county

Varies HWHP selfcertification Recommends HPHW HWHP

23+ counties No

Location Specific & Temporary EWM Quarantine/ Mandatory Inspections AIS inspection by conservation peace officer Inspection required at NPS Boat inspection started in 2010 No mandatory inspection. $100 fine. No boat inspection Four inspection stations Carter Lake Close in 2012 to SCUBA divers Mandatory inspection Clean-dry 5 days no inspection No boat inspection Mandatory inspection; Selfcertification with inspection at various locations State-wide surveillance program Random inspection at roadside and marinas Require decal purchase $10 in

HWHP

SOUTH DAKOTA TEXAS

UTAH

Specific ANS trans. prohibited Transport is prohibited Transport prohibited

5 days out of the water HWHP

4 counties 26 counties 3 counties

2 counties

Varies

None 84 monitoring locations for AIS No zebra mussel 2011

WASHINGTON

Transport prohibited of specific species

HWHP Disinfection of wet wells

36 counties

WYOMING

Prohibit

HWHP

3 counties

None Monitor 84

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State

AIS Trans

C-D-D

EWM

Law state, $30 out of state

http://sf.nd.gov/fishing/aquaticinvasive http://gfp.sd.gov/wildlifes/nuisance/aquatic/default.aspx http://www.oar.state.ok/vs/oar www.//.wildlife.state.nm.us/ais/document EWM Distribution EDD Map S 2012 Early Detection Distribution Mapping System The University of Georgia Center for Invasive Species Ecosystem Health www.eddmaps.org USDA www.invasivespeciesinfo.gov/aquatics/ wgfd.wyo.gov www.agri.state.id.us www.invasivespecies.wai.gov Note: Changes in programs occur rapidly which will cause this table to be out of date.

2.8.2

AIS Prevention Initiatives in Northeast States

In the Northeast, the states of New York, Connecticut, Massachusetts, Maine, New Hampshire, Rhode Island, and Vermont all have programs to identify AIS and are focused on rapid response programs to address the presence of new invasive species. Efforts implemented in most of these states focus on extensive outreach to reduce the transfer of AIS between water bodies. Currently, primary efforts focus on the management of EWM while spread prevention efforts focus on zebra mussels and quagga mussels. Spread prevention is highly dependent on the availability of funding and is generally centered on education and lake steward programs. The Connecticut program is managed by the Department of Environmental Protection and trains boating education assistants to impart boating education, safety and the interception of invasives. The state prohibits the transportation of nuisance species and violators are subject to a fine. The Massachusetts program, operated by the Office of Coastal Management, and focuses on reducing the lake to lake transport of zebra mussels by introducing boat launch stewards at a limited number of locations. Boat inspections are required at potable water supply reservoirs. Participants in bass fishing tournaments must fill out self-inspection and certification forms and display them in the tow vehicle in order to enter a tournament. The Maine program is operated by the University of Maine and provides a volunteer lake steward training program that administers voluntary courtesy boat inspections through 49 different organizations. The same program operates their citizen lake monitoring program. Self-certification is required and a fee is charged to purchase a sticker. The New Hampshire program prohibits the transport of invasive species. Public outreach focuses on the "Stop Hitchhikers" program and guidance on C-D-D standards. The Vermont program also has a prohibition on transporting invasive species. To fund invasive controls, the state requires a $10 fee to purchase a sticker that shows the boat owner is contributing to AIS transport control. There is also an active program to train volunteers to recognize AIS and complete surveys on their respective lakes. The Lake Champlain Basin

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Program manages an independent program for Lake Champlain. It operates the Lake Champlain Cooperative Boat Wash Program, a voluntary program that encourages boaters to properly clean their boats. This program utilizes 10 commercial car wash facilities. Four car wash facilities are located in New York and one is in Ticonderoga. It has also operated a Boat Launch Steward Program season since 2007. Three stewards in VT and four stewards in NY worked from Memorial to Labor Day weekend at various launches around Lake Champlain including Point Au Roche, Wilcox, Plattsburgh, Peru, Westport, Port Kent, Ticonderoga, and South Bay in NY and South Hero, Malletts Bay, and Shelburne in VT. Lake Champlain stewards also covered a number of fishing tournaments and educational events to share information about aquatic invasive species spread prevention and they assisted the Lake Champlain Committee by collecting blue green algae samples at their launches to enhance monitoring efforts for harmful algae blooms. The Rhode Island program consists of education and outreach using C-D-D approaches. The Save the Lakes organization has been working with the Rhode Island Department of Environmental Management to develop a program where volunteers help to distribute information about aquatic invasive plants (AIS) to boaters at the most used boat ramps and help inspect boats and trailers at popular boat ramps. The Rhode Island Aquatic Invasive Species Working Group developed the Rhode Island AIS Management Plan, which outlines recommended actions for managing invasives and provides a framework for coordinating State and Federal management efforts. Many states have developed individual AIS Management Plans. However, despite the guidance in these plans, the success of prevention and control is highly dependent on available funds to implement the recommendations. Numerous states have transport laws that prohibit the transport of aquatic invasive species or biological debris. Often these laws are not backed by enforcement action and, therefore, their effectiveness is limited. 2.8.3 AIS Prevention Initiatives in New York State

In response to the growing invasive species and federal assistance program, legislation was developed that created the NYS Invasive Species Task Force (ISTF). ISTF made 12 recommendations that centered on coordination, prevention, education, comprehensive planning, and control of invasive species. One of the main recommendations was to fund a partnership of organizations to prevent or minimize the harm caused by invasive species. NYSDEC developed a new partnership with resource managers, non-governmental organizations, industry, resource users, citizens and other state agencies and stakeholders to combat invasive species. Eight Partnerships for Regional Invasive Species Management (PRISMs) were eventually developed across NYS. Lake George falls under the PRISM known as the Adirondack Invasive Plant Program (APIPP). APIPP has been the successful PRISM due to stable leadership and a high level of commitment by all involved parties. Formed in 1998 by the Adirondack Nature Conservancy, APIPP coordinates both the Aquatic Invasive Species Project and the Terrestrial Invasive Species Project. APIPP plays a critical role in instituting a framework for aquatic invasive plant monitoring and educational outreach in the Adirondack Park. An inventory of aquatic invasive plants in a number of the lakes in the Adirondack Park has been mapped by APIPP and indicates a potential pattern for how AIS are being transported and introduced into area lakes. A new law signed by Governor Andrew Cuomo in July 2012 gives the departments of Environmental Conservation and Agriculture and Markets the authority to develop a statewide regulatory system that would make the knowing sale, purchase, possession, introduction, importation and transport of invasive species an enforceable violation. The new law requires

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NYSDEC and NYS DAM to produce this rule by September 2013 (Senate Bill, S6826A-2011) and establishes penalties for those who violate the rules. Penalties would range from a warning for a first violation to fines of no less than $250 for subsequent violations. Financial penalties would be greater for nursery growers, operators of public vessels and commercial fishing vessels. Working with the Invasive Species Council, the state agencies would develop regulations for dealing with the disposal and control of invasives, including a list of prohibited species that would be illegal to knowingly possess with the intent to sell, import, purchase or transport. 2.8.4 Summary of Lessons Learned from State AIS Prevention Initiatives This section evaluates the findings from the various states that have operated some level of AIS prevention as outlined above. In many western states, boats that originate from out-of- state are subject to mandatory inspections and the expansion of enforcement and random inspections is becoming nearly comprehensive. Research on AIS prevention programs in other states (see above explanation on Minnesota) found that voluntary inspections or selfcertification are not effective in ending the spread of AIS. All self-certification programs have been augmented by random roadside inspection stations where all boats are required to be examined. States with extensive random inspection and enforcement, such as Montana, Wyoming and Colorado, are being successful in stopping the movement of targeted invasives. In most western states, all out of state boats must be inspected. At many roadside inspection stations, high pressure hot water (HPHW) decontamination is available. In Utah and Colorado, private sector facilities are utilized for HPHW decontamination. Mandatory inspections are a superior method of preventing new AIS from being introduced into a waterbody (Pueblo Lake, Colorado). Inspections sites that are located in off-lake locations are more efficient to run, and more consistent in how inspections occur. Successful implementation of the inspection process requires continuing cooperation between partners. Any selfcertification program must be supported by strong clear transportation prohibitions, a mandatory inspection process, and enforcement program. See Table 2-9, Summary of AI S Prevention Methods in Western States, for a comparison of states that actively practice some level of AIS prevention. 2.8.5 AIS Prevention Initiatives in Warren County, NY Municipalities have played a strong role in local AIS management, particularly at the county level. The geographic boundaries of Lake George exist in three counties: Warren, Essex and Washington. Since the majority of the commercial land base is in Warren County, the communities along the west side of Lake George have made direct cash contributions to the effort to manage AIS. Warren County has also made considerable financial donations toward AIS management, and has recently passed an Invasive Species Transport Law. The Lake George Association and Lake Champlain Basin Program have partnered with Warren County to purchase and post signs referencing the new transport law at various launch sites and other significant points around Lake George. Warren County passed their transport law in 2011 (Local Law #9) making it illegal to introduce and transport aquatic invasive species into all Warren County waterbodies. Although similar laws have been passed at the local level in New York State, including the Town of Lake Pleasant and the Village of Lake Placid, this action represents the first county law of its kind in to pass in New York State. The law states:

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It is unlawful to launch or attempt to launch in Warren County a watercraft into a water body with any aquatic invasive species or other plant or animal, or parts thereof, visible to the human eye in, on, or attached to any part of the watercraft, including in live wells and bilges; the motor, rudder, anchor or other appurtenants; any equipment or gear; or the trailer or any other device used to transport or launch a watercraft that may come into contact with the water; It is unlawful to enter a public highway in Warren County after leaving a launch site without first removing by hand any aquatic invasive species or other plant or animal, or parts thereof, visible to the human eye in, on, or attached to any part of the watercraft, including in live wells and bilges; the motor, rudder, anchor or other appurtenants; any equipment or gear; or the trailer or any other device used to transport or launch a watercraft that may come into contact with the water; Removed items must be discarded away from the shoreline, in such a manner as to prevent the removed items from re-entering the water body; It is unlawful to introduce, throw, dump, deposit, place or cause to be propagated, transplanted, introduced, thrown, dumped, deposited or placed in any water body, in whatever capacity and for whatever purpose while in Warren County, an aquatic invasive species. 2.8.6 AIS Prevention Initiatives for Lake George

The Lake George Park Commission has a regulation requiring boat owners to inspect boats for AIS prior to launch and upon retrieval (see Section 1.5). However, the wording of this regulation makes enforcement difficult. Unfortunately, the same is true for the above-referenced Warren County transport law. As such, current AIS prevention efforts for Lake George rely solely on education and outreach. Education and outreach is used in a number of forms and formats to raise the awareness of the invasive species problem, and to reduce the chance of unintentional introduction of invasive species. This educational program relies on all lake users to limit the spread of aquatic invaders. Currently, the Commission and partners provide one of the most extensive and comprehensive public outreach and environmental education programs in the country related to aquatic invasive species prevention for a specific waterbody. A considerable portion of the outreach and education on AIS is provided by the Lake George Association (LGA) and The Fund for Lake George and Waterkeeper program. These two organizations work in concert to give their members a comprehensive understanding of how the watershed functions. Two websites have been developed for public outreach. The LGA and the Fund developed the StoptheAsianClam.info, which reports the work of the Lake George Asian Clam Rapid Response Task Force (LGACRRTF). Also developed by the LGA in concert with the Fund and Commission is the website, ProtectLakeGeorge.com, which reports on the general status of aquatic invasive species projects and programs. In response to the growing issues with AIS, the LGA developed the Lake Steward Program in 2008. Stewards are employed at marinas and boat launches during the summer to collect data through boater surveys, inspect the exterior of boats for AIS, and educate boaters on AIS spread prevention. The LGA also provides awareness and education about lake issues to its membership and the community. The Fund for Lake George (FUND) and associated Waterkeeper program seeks to use lake and watershed monitoring to continuously benchmark the quality of Lake George, and advocate for

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best management practices in land development and resource use. As part of this mission, the FUND supports AIS education and management initiatives with other organizations and local governments. In 2012 the FUND published a report Clean Boats Only: The Case for Proactive and Mandatory Boat Inspections and Decontamination program for Lake George to Prevent New Aquatic Invasive Species Infestations.

Photo Credit: Lake George Association

Public education on AIS reaches communities in the Lake George watershed and the Capital District on a regular basis through a variety of means including press releases, websites, radio, online videos, local and regional public meetings and more. Over the last several years, visitors and boaters have been frequently and consistently exposed to educational messages about AIS awareness. However, getting messages about AIS prevention out beyond the local region is more challenging. A Recreational Study completed for Lake George (Holmes & Associates, 2005) tracked boating behavior and found that only 30% of visitors believed that invasive species were a threat while 70% of lake residents considered it a threat. This finding indicates that the message has to move beyond the Lake George area. In light of this, the Commission and local partners are providing increasingly more resources toward public education. In 2012 an estimated $10,000 was spent on contracted items such as educational rack cards, mailings and electronic messaging. In addition to this, four to six times as much was spent on staffing efforts related to AIS prevention through the many local nonprofit and agency partners in the Lake George Basin.

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These targeted efforts are believed to be successful at reaching a percentage of the boating population on Lake George, but exactly how much is difficult to quantify. Boat launch stewards report that the majority of people launching at their sites are aware of invasive species issues, including prevention strategies, and they act appropriately in response. However, the accuracy of these quick surveys is difficult to verify. Regardless, all partners engaged in these initiatives agree that public understanding is the cornerstone of success of any prevention program, and that more efforts in this arena would certainly be beneficial. In late 2012 the Lake George Park Commission organized a committee of local and regional individuals representing agency, nonprofit, business, municipal and tourism sectors who have background and expertise in both the issue and in messaging in general. This committee has met to discuss the various methods and means of a larger and more comprehensive AIS outreach and education plan to reach users of Lake George. For the 2013 season, Governor Cuomos Administration announced $50,000 of new funding to enhance the existing invasive species prevention efforts for Lake George; $10,000 of which is directed to outreach efforts. The other funding for 2013 is broken out between increased boat launch stewards ($20,000) and increased LGPC Marine Patrol efforts ($20,000). This additional $10,000 for outreach is being augmented by a generous private donation of $9,500 from the Lake George Power Boaters Association and potential additional funding from the nonprofit organizations the Lake George Association and the Fund for Lake George. With these additional resources, the outreach committee agreed that this effort would greatly benefit from a professional marketing firms experience and ideas. In response, the LGPC and LGA researched firms who specialize in this work and have selected a firm (Adworkshop from Lake Placid) to provide improved messaging and outreach. Adworkshop has detailed a program with varying costs and strategies to reach the boating population on Lake George to a much greater degree than has been available to date. This 2013 strategy will set the stage for future outreach initiatives, and will provide a model to build upon in the future. Endeavors will be made to assess the effectiveness of various strategies employed, and future efforts will gain from the experiences learned in the 2013 program. The messaging will be consistent and clear, and will relay a positive message. In any boating option chosen to prevent new invasive species introductions to Lake George, all parties agree that the core of the program should be public awareness of the issue. When people understand the importance of this topic and their ability to affect positive change, then all other options become more successful.

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SECTION 3

ALTERNATIVES ANALYSIS

3.1

Introduction

The alternatives analysis is the cornerstone of environmental impact evaluation. This section describes a range of feasible actions and costs for the public to consider for preventing the further introduction of AIS into Lake George. A review of the alternatives will describe each option and evaluate the individual benefits, short and long-term impacts, costs and unknowns. For this report, each alternative will be described as it relates to the operation or implementation of the alternative, the groups or agency responsible for the type of facility or equipment needed to implement the alternative, the annual cost associated with implementing the action, and a five-year equipment replacement cost projection. The alternatives considered include: Lake George Alternative 1: No Action, Lake George Alternative 2: Enhanced Voluntary Compliance, Lake George Alternative 3: Regulatory Self-Certification, and Lake George Alternative 4: Regulatory Mandatory Boat Inspections. Seen as implicit to the success of any alternative, all of the alternatives discussed would include a significant level of effort on public education and outreach. Sections 2.8.6 discusses Education and Outreach including existing efforts and recommended strategies for maximizing public awareness of this issue. It is anticipated that any alternative prevention strategy will include a similar significant outreach and education component and, is therefore not included as an alternative to be reviewed separately.

Photo Credit: LGPC

3.2

Lake George Alternative 1: No Action 3.2.1 Description

The "No Action" Alternative is a required element of SEQRA and has to be considered by any project applicant as an available alternative. An evaluation of the short-term and long-term consequences of the No Action Alternative will be described. In this case, no action means the primary Lake George Park Commission existing AIS prevention programs and actions would

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cease, with the exception of its traditional outreach efforts to boaters in their annual mailings and through traditional outreach. Commission funding of the LGA Boat Launch Steward Program would not continue, as those funds are generated through the NYS Environmental Protection fund and are decided on an annual basis by NYS leadership. The No Action alternative is a lesser program than what is currently in place on Lake George through the Lake George Park Commission. The reason this No Action alternative is outlined in this way is that considerable LGPC funds and staff time are utilized on an annual basis for AIS prevention efforts, but this funding and staff time could be utilized on other important initiatives such as EWM control, LGPC Marine Patrol activities, or other traditional programs. The Commission needs to make clear that, as with all alternatives, there are benefits and drawbacks to No Action. The No Action Alternative would halt more aggressive efforts by the LGPC to intercept or slow the introduction of AIS into Lake George. The LGPC would not be in the position to stop the LGA or the Fund from operating the existing voluntary boat inspection program, but any Commission funding of those programs would end. The LGPC would also not develop or distribute public outreach materials requiring funding beyond the traditional efforts noted above. The portable boat washing equipment used in 2012 would continue to be owned by Warren County Soil and Water Conservation District, and operated at their discretion. 3.2.2 Potential Benefits (Pros)

The No Action Alternative would save money that is currently expended to fund the Lake George Association voluntary Boat Launch Steward Program; a commitment of $35,000 per year in 2012 and 2013. This comprises more than 50% of the annual cost of the program, not including LGA professional staff cost to administer it. Also, staff time that has been devoted to the contracting and coordination of this effort would be re-allocated to other tasks. In addition, the staff time and expenses related to proactive outreach development and implementation would be spared and allocated as well. These financial and staff resources could be targeted to current invasive species management efforts, which would improve the level of effort on this front. This would increase the current funding level for EWM control approximately 20%, or the efforts on Asian clam control 5-10%. LGPC staff time allocated to these or other initiatives as described would increase in the 3-5% range, as these traditional contracting and outreach efforts are fairly streamlined and dont require considerable levels of effort. 3.2.3 Potential Drawbacks (Cons) The No Action alternative would reduce the level of effort currently expended on AIS prevention for Lake George, thereby causing a high risk of introduction of new aquatic invasive species to the lake. Between 2010 and 2012, the Asian clam and spiny water flea were discovered. During this time period, there was a well-organized lake steward program that focused on the exterior of boats and interacting with boaters to educate them on the need to prevent AIS introduction. Given the large number of boaters from other lakes in the proximity of Lake Champlain there is likely to be an escalation in the rate of AIS introduction. Aquatic invasive plants will inhabit the same area that lake users enter and enjoy the lake. Elimination of funding to the LGA for the Boat Steward program would result in a 50% reduction to the program or would require the LGA to derive internal or outside sources of funding to

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continue at current levels. A 50% reduction in program funding would likely result in a similar reduction in coverage through the steward program. The ultimate result of this alternative would be a small to moderate increase in effort to manage existing invasive species, but a significant reduction in prevention efforts for new introductions. 3.3 3.3.1 Lake George Alternative 2: Enhanced Voluntary Compliance Description

The enhanced voluntary prevention alternative is a proactive, non-regulatory approach that builds upon an existing framework of two key initiatives: public outreach and a non-regulatory boat launch steward program in which staff people trained in AIS prevention interact with boaters at the primary launches on Lake George. The 2012 AIS program for Lake George put forth a good level of effort on both topics, with a $50,000+ Boat Launch Steward Program through the Lake George Association, plus considerable work to outreach a Clean, Drained, Dry message to boaters coming to Lake George through both print and electronic initiatives. This Lake George effort is considered to be one of the top AIS prevention programs in the State, but as with any program, financial, logistical and programmatic realities limit how much has been done. The alternative described herein details an effort to reduce these limitations and maximize the benefits of these initiatives, thereby realizing as much of the potential from this alternative as possible. Boat Launch Steward Program (Existing) Lake George has one of the largest and most advanced voluntary boat inspection programs in the eastern U.S. The LGA Lake Steward Program has been in operation since 2008 and is carried out by the LGA and is funded by grants and donations. The grants that have supported the program are from the Lake George Park Commission and the Lake Champlain Basin Program. The donations are a component of LGA allocations from individual foundations that support various LGA activities. Boat inspections are conducted by trained boat launch stewards from the Lake George Associations Lake Steward Program. Lake stewards are trained by Paul Smiths College as part of the Adirondack Watershed Institute, and these stewards work at five or six boat launches on Lake George as decided by the steward program manager at the LGA. Once stewards are granted permission by the boat owner, they commence inspecting the exterior of the boat for visible materials which could be invasive in nature. On Lake George in 2012, lake stewards operated the primary launch points to Lake George, including Mossy Point State Boat Launch, Rogers Rock State Campground, Hague Town Boat Launch, Dunhams Bay Marina, and Norowal Marina. While it is difficult to calculate exactly (as comprehensive lake-wide boat launch numbers dont exist), it is believed that approximately 40-60% of boat launches on Lake George had interactions with Stewards in 2012. The Stewards were present at the major launch points on the lake for much of the summer season, which accounts for this fairly high number. However, there are almost 100 public and private launch points on Lake George, including Public launches, Motels, Marinas, Associations, and private homeowner launches. The summary results of the 2012 Boat Steward Program are summarized as follows (Lake George Steward Program 2012 End of Season Report, LGA, 2012)

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DRAFT for Public Review 5/7/2013 11:05 AM Over the 2012 season, the Lake George lake stewards inspected 6,972 boats. Boaters were asked what the last body of water their boat had been in during the past two weeks. The total number of waterbodies visited within two weeks of overland transport to Lake George was 155 unique waterbodies located in 13 different states throughout the United States and 2 Provinces in Canada. Lake George itself was the most common recorded previous waterbody visited with 3,282 boats; the next most frequent waterbody was Lake Champlain at 96 boats. Boaters were most frequently coming from lakes in New York State (3,704). There were 921 (or 13%) boats that can be considered at risk boats for transporting aquatic invasive species, meaning they had been in another body of water other than Lake George within two weeks prior to launching in Lake George. From all five launches, lake stewards collected 272 aquatic organism samples from 189 boats and trailers launching and retrieving, and identified 131 samples to be an invasive species. Two percent of the boats inspected were transporting an invasive species. Six different invasive species were identified: Eurasian watermilfoil, curly-leaf pondweed, water chestnut, zebra mussels, quagga mussels, and spiny water flea. Approximately 83 percent of boaters reported having previously interacted with a lake steward. Spread prevention measures were reported being taken by 63 percent of boaters.

In short, this program is very good at educating a good portion of visiting boaters about the threats of aquatic invasive species to Lake George, and also for identifying and removing visible aquatic species on boats and trailers. Enhanced Boat Launch Steward Program (for Alternative 2) This program could be expanded in the following ways to enhance the coverage and increase the number of boaters who interact with the Stewards: 1. Expanded seasonal coverage (pre and post season) 2. Expanded number of launch locations around the lake 3. Expanded hours per day 4. Train marinas and other possible launch point managers in AIS identification and prevention, to have them do this work internally Photo Credit: Lake George Association 5. Increase LGPC Marine Patrol presence at launch sites to assist in compliance with existing LGPC AIS prevention regulation (prohibiting any person from launching a vessel into the lake without inspecting the boat and trailer for marine growth or any other hull contamination to ensure that such items are not discharged into Lake George (6 NYCRR '646-1.7h)). A combination of the above five factors combined would make for the most comprehensive steward program possible. For equity in evaluating all best available for AIS prevention alternatives on Lake George, number 6 above (combination of all) will be reviewed and discussed herein. The current inspection season typically runs from mid-May to the third week in August when the majority of lake stewards depart for the fall college semester. A longer season could be put into place, perhaps expanding to the beginning of traditional boating season in early May, running through the traditional close of boating season around late October. To achieve this, the

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existing program of hiring college students almost exclusively would have to be modified to include personnel which would be able to work the pre and post-season times. Voluntary inspections through a program such as this could only work at launch sites rather than regional or off-lake locations which would be easily avoided by boaters. To expand the number of boat launch locations that are manned by boat stewards, the LGA and LGPC staff would work to determine what additional launch sites would have the traffic to merit full-time staffing of a steward, and at what days and hours. If it is determined that the launch counts at various marinas around the lake would not merit this staffing, then discussions could be had with smaller local marinas and managers of launches about these efforts happening internally (i.e. without LGA trained staff). If, for example, a marina only launches 3-5 boats per day, then a program could be set up whereby marina staff would provide the voluntary inspection of the boat for invasives and the boater education prior to launch. This initiative would require considerable logistical effort on training marina, motel and perhaps homeowner association staff on these important topics, as staffing shifts at these facilities would necessitate that multiple individuals in each entity receive training. As this would be a voluntary activity, there might be a need to compensate these entities for undertaking this work, perhaps on a perboat inspected basis. Once financial compensation for services rendered enters the equation, controls for quality and, even fraud, would need to be in place. If all six items listed above were instituted, it is conceivable that a significantly higher number of boaters who launch on Lake George would have interaction with a steward of some type, and the benefits of such program would be maximized. To help support AIS prevention efforts on Lake George, a pilot effort will be undertaken in 2013 whereby the Lake George Marine Patrol will have a part time presence at various launch sites around the lake. The intent of this is to assist in the education of boaters on Lake George about the importance of AIS prevention, to assist the stewards in inspections, and to provide greater compliance with the LGPC existing regulations. The combination of increased outreach, enhanced boat stewards and extra Marine Patrol presence will be the Lake George AIS prevention program for 2013. It is a considerable increase in level of effort over any previous year on Lake George. 3.3.2 Potential Benefits (Pros) With the enhancement of the Boat Steward Program, it is anticipated that the number of boaters who come into contact with a steward could increase from the existing estimated 40-60% up to an estimated 80%+ (another 1,000-2,000 launches addressed by the program). The remaining 20%+- of launches on the lake which could not be effectively addressed through this program would constitute small volume launches (smaller marinas, motels, associations) which cannot justify a full time staff position through the traditional LGA program, and would choose not to become involved in an internal boat steward program as described above. The great benefit of the steward program is its relative cost-effectiveness for the number of launches that are addressed through this program. Over the years, the Lake George Association has evaluated the locational launch numbers and has developed a very good program which targets high volume launches in high volume times of year. This leads to an excellent bang for the buck and a means to provide low-level voluntary boat inspections and education to a fairly large audience of boaters launching on Lake George.

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This program also requires no legislative or statutory authority to exist, as there is no regulation requiring compliance with the program. If a boater chooses not to engage with a boat launch steward, there is no requirement that he or she has to do so. From LGAs reported experience, the vast majority of boaters who are engaged by stewards do so willingly. With the enhancement of the program as described above, it is possible that the large majority of trailered boat launches on Lake George could go through some level of boat launch steward interaction, consisting of a cursory inspection of the hull and trailer for visible invasives, and receive educational materials on invasive species prevention. With the occasional LGPC Marine Patrol presence at the launch sites, there is an expectation that transient boaters will gain an increased appreciation for this issue, and will respond appropriately by being proactive prior on this issue to launching into Lake George. This effort will hopefully provide for an incremental benefit on AIS prevention for Lake George. 3.3.3 Potential Drawbacks (Cons)

There are two significant limitations to any such voluntary steward type program: 1. The inspection process is cursory, and limited to visual invasive species only. Without a regulation requiring boats to be fully inspected and dry prior to launch, there is no means to verify that the boat is not carrying juvenile invasive species in areas where water could be stored on the boat (bilge, baitwell, motor, ballast tanks, etc). These juveniles which travel on boats in this fashion constitute a high risk, and are the entire purpose for all mandatory boat inspection programs nationwide, primarily west of the 100th Meridian (see 100th Meridian Initiative). The threat of non-visible invasive species has led to multimillion dollar mandatory boat inspection programs in the western U.S. where zebra and quagga mussels are of tremendous concern to those waterbodies and their local lakebased economies. This threat exists for Lake George as well. Reliance on voluntary compliance creates gaps in prevention levels (see Section 3.2.3, Minnesota). 2. Without a requirement that boaters undergo an inspection process, there is no way to centralize a system which interacts with all transient boaters. Under a voluntary program, boaters have no requirement to have been inspected, and can simply go to a launch point of their choosing. That launch point may have no steward in place at the time of launch, leading to a lesser level of interaction between boater and AIS prevention specialist (inspector, steward). 3. Although the voluntary inspection program has been in place since 2008, two new invasive species have been discovered in Lake George. This is evidenced by the discovery of the Asian clam in 2010 and the spiny water flea in 2012, both of which are extremely difficult to detect on a visual inspection. While the pathway of introduction for Asian clam to Lake George is unknown, it is a strong possibility that they came in from an infected boat in its bilge or on a contaminated anchor or rope line. With regard to spiny water flea, that introduction is unknown as well, but this species most likely came in on either an infected boat or on fishing tackle from an infected lake. In either case, a program which does not require the boat and all items on the boat (ropes, anchors, fishing gear) to be clean, drained and dry would not have stopped these threats, whereas a program requiring that standard would likely catch these invaders. 4. In voluntary programs, when a boat is found to be in need of decontamination washing, there may be limited or no availability of a proper decontamination process available. In the unlikely circumstance that one would be (which would require a significant annual

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funding and staffing level throughout the Lake George basin), the lake steward must convince the boater to take the time to go through the process primarily by appealing to the individuals desire to do the right thing. To ask a boater to step out of the launch queue (line) on a voluntary basis and take 20-30 minutes to get his boat decontaminated would not likely see a high participation rate. 3.4 Lake George Alternative 3: Regulatory Self-Certification 3.4.1 Description

A regulatory self-certification program to prevent aquatic invasive species would consist of new regulations requiring boaters to self-certify that they would not launch a boat into Lake George without first having met a set of standards related to AIS prevention, under penalty of law. A program such as this would consist of three key components: 1. Clarification of existing LGPC regulation (potentially requiring NYS Legislative action for fee creation or modification) requiring all boaters on Lake George to certify that their boat is free of invasive species prior to launch into Lake George. 2. Creation of a computer-based training and certification module which individuals would undertake and complete. This test indicates an understanding of the program and AIS prevention methods. This would be coupled with a program which would allow the creation of a self-certification form (hard copy or digital), which would prove that they have complied with the provisions of the program. 3. Enforcement to help ensure compliance with this program among the boating public on Lake George. Many statewide programs rely upon a combination of self-inspection/self-certification inspections and enforcement to limit the transport of AIS. Enforcement takes the form of prohibition on the transport of AIS either within, attached, or entrapped in the watercraft or trailer. There is typically a civil penalty of a fine and, in some cases, it is sizeable. As of 2012 in Warren County, N.Y., there is a maximum $5,000 fine for transporting invasive species. However, it has been noted that this law is very difficult to enforce on a proactive basis, and offenders would only be caught if a violator was pulled over by a Warren County Sheriff for another transgression. To date, no tickets or citations have been issued related to this law. In order to develop a self-certification program at Lake George, the Commission would need to create a regulation that requires boaters to complete a training course by computer and/or complete a Clean, Drained, Dry (C-D-D) inspection form (Minnesota, Colorado, Idaho, and Utah has such a program). All regulatory (rule) modifications to Lake George Park Commission regulations require positive action and majority approval by the LGPC Commissioners following a formal public rulemaking process. If this process were to result in the need for the creation of new fees or modification of existing fees to boaters on Lake George, such action would require the approval of the NYS Legislature and approval by the NYS Governor. There are existing computer based training models which could be adapted for a Lake George AIS self-certification program, both from local sources and from other states, which would save time and money in program development. A program as envisioned to be effective for Lake George would require public awareness and understanding of the concept (proven by passing an online test or similar), and proof of compliance with the program (hard copy or digital document which can be shown to enforcement personnel).

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Upon implementation of such a program, any boat entering Lake George without proof of meeting the C-D-D protocol would be subject to a civil or criminal penalty. Enforcement would occur at any launch point to Lake George, based upon the level of funding afforded to the compliance part of the program. It would be necessary to have a concise implementation regulation that would permit enforcement to intercept a boat prior to its launch into Lake George. To set up a self-certification program will require an outreach program to inform the public on the steps necessary to successfully complete self-certification. Setting up a web-based instruction and testing program plus additional LGPC patrol personnel would be required. Assigning officers to patrol existing boat launches around Lake George could cost approximately $100,000 - $150,000 annually, depending upon level of enforcement. In addition, there would be a one-time cost for setting up the computer program of an estimated $50,000$75,000 plus annual software maintenance costs of approximately $10,000 - $15,000. 3.4.2 Potential Benefits (Pros)

The primary positives of such a proposed regulatory self-certification program are as follows: 1. The cost to develop and administer this program are modest, as compared to a mandatory trailered boat inspection program (est. $175,000 versus est. $650,000 annually for mandatory inspection). 2. It would be easier to administer a self-certification program than a mandatory inspection program, based on staffing, logistics, and other factors. It would be anticipated that this program may have an additional 5-7 staff in implementation, primarily administration / enforcement, versus between 30-40 staff for mandatory inspection program. 3. There would be few or no delays of boaters accessing Lake George, as there would be with a mandatory inspection option. Under this scenario, boaters would go directly to a launch of their choosing without going to a regional inspection station. If an enforcement person is at a launch point, that boater simply shows the enforcement individual his or her self-certification form, and the enforcement individual does compliance check to ensure compliance with the regulations (clean, drained, dry). 3.4.3 Potential Drawbacks (Cons)

A self-certification program for Lake George has two significant structural problems, which primarily relate to public compliance with this program and also its enforcement. These issues are detailed as follows: 1. Public compliance: Self certification programs by their very nature rely considerably on the aspects of public awareness of the program and also the perceived penalty for noncompliance. Making the boating public aware of the new self-certification regulations is a significant task, particularly when enforcement of such a program by its nature would be on an occasional nature at best. An example of this challenge can be seen by the NYS firewood self-certification program to control invasive pest movement throughout New York. NYS has had a self-certification program regarding firewood transport in place since March 2009, much the same as would be proposed for this aquatic invasive species prevention effort. The results of a compliance check station at Lake George off exit 21 in the summer of 2012 yielded less than encouraging results. Following a public

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awareness effort, the NYS DEC held a roadside check of all vehicles and yielded an extremely low compliance rate, as follows: a. Out of 33 vehicles with loose firewood, zero had a self-issued certification form to be in compliance with the program. b. Individuals who stated that they had obtained their firewood from within 50 miles of Lake George were simply issued a verbal warning and were allowed to keep their firewood. c. The individuals who noted that they had obtained firewood from outside the 50 mile radius had their firewood taken and destroyed, and were issued a ticket. 2. Self-certification at a single lake scale (versus a statewide program) has significant enforcement challenges. Unless a boater is in the act of putting a boat into Lake George, they would likely not be out of compliance. Any regulations developed to enact this program would have to be specific regarding exactly when a boater would be out of compliance with this program if the boat and/or trailer did not meet the standard set forth in the regulation. As an example, if a boater was in the launch parking lot and he had some water in the bilge, would he be in violation? Any boater out of compliance could simply note that they had no intention of launching into Lake George. If a ticket were written for being out of compliance, would that ticket be enforced at a local court, with the plaintiff stating that he was simply looking at the launch to see how busy it was? Practical issues such as this go to the core of the program. 3. What happens when a person is found to be in violation of the standard of clean, drained and dry? Would that person not be allowed to launch? Would those people be sent away, possibly from vacation? Would those people simply find another launch where no enforcement personnel were in attendance? Would they simply receive a ticket and then be allowed to launch into Lake George, with potential invasive species on their boat/motor/trailer? The only means to effectively address this issue is to have manned decontamination stations with trained staff at numerous locations around the lake. Once decontamination stations are included in the mix, the cost of the program begins to approach a mandatory inspection program cost, but without the significant benefits of that program. 4. This program would very likely require Legislative and Governor approval to implement to any degree of effectiveness, as it would require an annual funding and staffing which greatly exceeds the LGPC current income stream. The LGPC boat and dock fees are set by the Legislature and approved by the Governor. Without fee increases, this program could be supported by outside (i.e. grant) funding, but non-structural sources of funding such as grants would not likely pass the NYS Regulatory Reform Unit which requires identification of programmatic funding for such program to be approved. Self-Certification would be a viable option if offered on a statewide basis, where boaters would clearly be launching at a lake that was included in the program. Enforcement in that case becomes more definitive, as there is no geographic issue to contend with. In addition, the states which utilize a self-certification program for AIS prevention have decontamination sites available, although travel time to those stations is sometimes considerable, which again leads to challenges with program compliance.

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3.5

Lake George Alternative 4: Regulatory Mandatory Boat Inspections 3.5.1 Description

The Mandatory Inspection and Possible Decontamination Alternative is the inspection, prior to launch, of all motorized boats that are brought by trailer to Lake George. Prior to launch into Lake George, all trailered boats would be required to visit a regional inspection station in the Lake George watershed, and undergo a 7-10 minute invasive species inspection of the vessel and trailer. The standard for boats to pass inspection would be that of the Western states model of clean, drained and dry (CDD), which would work to prevent both visible and non-visible aquatic invasive threats. Inspectors would be authorized by the Commission to enter the interior of boats in order to complete the inspection of all hull compartments. The inspection process would generally be completed in 10 minutes or less. As part of the boat inspection process, boat owners will also be required to drain the bilge and properly dispose of AIS prior to leaving the launch area to prevent Lake George from being a source of AIS to other waterbodies. Should a boat not meet the C-D-D inspection standard, the boat would have to be washed and decontaminated at the inspection station with High Pressure Hot Water (HPHW) prior to launching. There would be no additional charge for this procedure. Hot water washing at a temperature of 140F or higher has proven to be the fastest and most effective means to destroy juvenile stage mollusks known as veligers, or other microscopic life stages of AIS that are part of the invisible spectrum (Comeau, 2011). Boats with ballast tanks and bilges will have to be drained and possibly flushed with HPHW. Once the decontamination process is complete, the boat would be fitted with an inspection tag securing the boat to the trailer. Boats are then permitted to proceed to the marina of choice and launch into Lake George. As long as the boat's inspection tag is secured/connected to the trailer the boat is free to launch. Boats that are leaving Lake George launches will also be fitted with inspection tags. These boats may re-launch into Lake George without being re-inspected as long as the inspection tag is intact. The draft rule provides for civil penalties in the form of specific fines against the boat operator and launch owner for launching boats without the required inspection (see Appendix C). Non-trailered watercraft (canoes, kayaks, paddleboards, etc) would be exempt from inspection. This is based on scientific study which notes that these watercraft are much less likely to harbor invasive species, as they dry quickly and dont have a large number of areas which remain wet and catch aquatic debris. The Lake George Park Commission would hire and train a staff of inspectors and decontamination personnel, and training would be based on the protocol outlined in the 100th Meridian Initiative Pacific State Marine Fisheries Commission (Zook B. and S. Philipps, 2012) and will be defined in procedures set forth in a Commission manual (see Appendix I). This program would begin each year in mid-April after ice-out (at a reduced staffing level), then go through May through September at a full staffing level, then continue into late November or early December again at a reduced staffing level. Five regional inspection stations are envisioned for this program, to be located at high-launch areas which work logistically for this program. Each launch on Lake George would have a means to ensure compliance with the program, through management of each of the launches. Launch attendants would simply be required to

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check to see if the inspection tag is in place, and would not be undertaking any level of inspection for invasive species. The launch attendant would clip the tag (special zip tie), write the vessel number on a standard form, and keep the clipped tag for later collection by LGPC personnel. This process is expected to take less than 30 seconds. 1. NYS Public launches: LGPC personnel 2. Municipal launches: Municipal personnel or MOU 3. Private Marina Launches: Marina personnel 4. Private Association: Association personnel or MOU 5. Homeowner: Registration of launch only allowing homeowner boat to be launched Upon departure from Lake George, the personnel managing the launch sites would require the boat be clean and drained (bilge, bait well, ballast tanks). When complete, those boats would be secured to the trailer with a specialized plunger seal zip tie, which shows that the boat was last in Lake George. Upon return to Lake George, if that seal was still in place, there would be no inspection (or cost) required. Depending upon resources, the LGPC could put in place a frozen boats program in the winter months, whereby boats which have been out in below-freezing temperatures for at least 3 weeks could be certified as invasives-free, and tagged as if they were inspected. This program is in place for the Quabbin Reservoir in Massachusetts and has been successful. This would have the benefit of saving money for boaters on Lake George, reducing inspection lines in early season high-volume launch times, and providing a means to make the overall program more efficient. The cost of conducting such a program would have to be evaluated prior to incorporation. This program, as envisioned, could cost approximately $200,000 to $300,000 initially to get up and running (decontamination units, infrastructure upgrades), plus an annual operational cost of approximately $700,000 per year. Funding for this program could come from a variety of sources, but the most likely sources would be an increase in LGPC boat registration fees (averaging $35 per boater per year), and a $40 once per season boat inspection fee for those boats which require inspection. This alternative is considered the most comprehensive aquatic invasive species prevention program of all alternatives considered. It is also the most costly and logistically detailed. A summary breakdown of the pros and cons is offered below: 3.5.2 Potential Benefits (Pros)

1. Non-Visible Species Prevention: This is the only alternative which addresses these visible and invisible threats in a significant manner. The non-visible aquatic invasive species, including Quagga Mussels, are of grave concern for being introduced to Lake George, and this program has the highest assurance that Quagga and other species which travel in wet areas on a boat (motor, bilge, bait well, ballast) are kept out of the lake. The inspections under this program are considerably more comprehensive than the existing Boat Steward program, with the primary factor of setting a standard for what would pass inspection. The clean, drained, dry protocol ensures that any trailered boat would be free from all invasive species, and if not, the program provides a decontamination to ensure it is invasives free prior to launch into Lake George. 2. High Compliance Levels: A mandatory boat inspection program coupled with decontamination of boats not passing inspection is considered the highest level of protection for Lake George. Once implemented, this program would require 100%

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trailered boats to be inspected for aquatic invasive species, and those inspections would include a means to minimize the threat of both visible and non-visible invasive species. Neither the enhanced voluntary program or a regulatory self-certification program would experience the level of compliance as a mandatory option would, and given that it only takes one infected boat to start a new infestation in the lake, this program merits strong consideration. 3. Best Long-term Economic Protection: Lake George has witnessed the high cost of managing invasive species (Table 1-2), in excess of $6.5 million dollars over the past two decades. There is great concern that new invasive species could not only cost significant additional dollars for management, but will also affect the economy of the surrounding communities (tourism, property values, etc). These economic analyses are described in Chapter 4. A mandatory boat inspection program provides the highest level of protection from new introductions of aquatic invasive species, and also from the short and long-term economic impacts that such introductions could pose. Lake-wide and/or regional infestations of such species as Quagga Mussels, Hydrilla, Brazilian Elodea or many others would have tremendous implications for the future of the lake, particularly if funding to address these species are lacking (which they likely would be, given the current funding limitations for existing invasive species management). 3.5.3 Potential Drawbacks (Cons)

1. Cost: A mandatory boat inspection program would have by far the highest cost of the alternatives identified, more than double or triple that of the other identified options. To provide a program which would not greatly inconvenience boaters coming to Lake George, five regional inspection stations would be operated around the Lake George basin, and to be comprehensive, those sites would require staffing essentially from iceout in April through the end of the year in December. This level of staffing equates to approximately $700,000 per year, plus an initial cost of approximately $300,000. These funds would have to be generated on an annual basis, through a structured funding stream to ensure continual operation of the program. These significant financial resources, as any financial resources, could go towards other Lake George Park Commission programs including additional management of existing invasive species (Asian clam and/or Eurasian watermilfoil). 2. Funding Sources: To implement a mandatory program as envisioned, the most likely structural annual funding stream would require an increase in LGPC boat registration fees. The program as described in Chapter 5 details the various sources of potential funding, but this funding stream is envisioned for almost all possibilities. As noted in the Cons under self-certification, an increase in LGPC fees requires approval by both the NYS Legislature and the Governor. One likely funding scenario envisions a 100% increase to the statutory boat registration fees for boaters on Lake George. For 87% of boaters, this increase averages approximately $35 per year. The remaining 13% of boaters are larger boats which would see larger fee increases based upon the length of their boat. A fee increase of such a high percentage magnitude, while only equating to an average increase of $40, may be politically challenging. Other funding sources are being considered, but are generally secondary to a fee increase. 3. Program Logistics: While great research into boat launch patterns on Lake George have been conducted, this program may offer some challenges to implement in practice. It is estimated that approximately 50-70% of launches into Lake George go through the three largest launches (Norowal Marina in Bolton, Mossy Point DEC launch in Ticonderoga,

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and Rogers Rock DEC Campground in Hague). These sites are envisioned to have regional inspection stations located at them, for the benefit of boaters not having to go out of their way to get to an inspection station. However, the logistics of operating an inspection and decontamination station at busy launches will be challenging. Each site has been reviewed for operational issues, and these can be overcome. However, during high traffic launch times, there could be backing-up of traffic and launch delays if the sites are not staffed properly. These are issues which can be overcome with proper funding and management, but need to be addressed prior to implementation. 4. After-Hours Inspection: This program proposes that only boats that have an intact inspection tag may launch on Lake George during staffed and unstaffed hours (see Section 5.1.4). Boats that lack an intact inspection tag would be subject to the time constraints of the inspection stations (12 hours/day). Boats that arrive at an inspection station outside of the staffed hours would not have an opportunity to gain the proper inspection, and would be legally prohibited from launching. Once the program is implemented with appropriate outreach, it is anticipated that boaters would plan ahead and accommodate their schedules as necessary to attain an inspection and the associated tags to undertake a legal boat launch.

Photo Credit: Lake George Association

3.6

Lake George Alternative 5: Regulatory Mandatory Boat Inspection with AfterHours Self-Certification 3.6.1 Description

The Regulatory Mandatory Boat Inspection with After-Hours Self-Certification Alternative is a blend of the Mandatory Inspection and Decontamination Program with the Self-Certification. The program would operate as described in the Regulatory Mandatory Boat Inspection program described in Alternative 4 above, except that during unstaffed hours at public launches, roughly 8pm to 8am, boaters would be allowed to forego inspection stations and launch their boat provided they have a self-certification form as proof of meeting the C-D-D protocol. Details of

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and adherence with this self-certification would follow the program description described as Regulatory Self-Certification in Alternative 3 above. 3.6.2 Potential Benefits (Pros)

1. Implementing a full mandatory inspection program during the day would provide the greatest protection to the Lake during what are currently the heaviest traffic times at launches. 2. Under the mandatory inspection program, boats that do not have intact inspection tag may not launch during after-hours. Boats that require inspection would be subject to the time constraints of the inspection stations (12 hours/day). A self-certification program during afterhours would alleviate the problem of boaters arriving at launches without an inspection tag during after-hours. 3. Both mandatory inspection and self-certication protocol will serve to educate boaters about C-D_D protocols. 3.6.3 Potential Drawbacks (Cons) By blending mandatory inspection with after-hours self certification many of the benefits of these programs would be compromised. 1. This would represent the most expensive program. Providing a self-certification program for after-hours launching in addition to the Regulatory Mandatory Boat Inspection Alternative would increase the cost of this program. As noted above in Alternative 3, selfcertification would require a one-time cost for setting up the computer program estimated at $50,000-$75,000 plus annual software maintenance costs of approximately $10,000 - $15,000. This exacerbates the existing drawbacks of the Regulatory Mandatory Boat Inspection program, and negates the main benefit of self-certification. 2. The stark contrast in regulatory oversight between daylight and night hours may result in boaters deliberately launching during unstaffed hours. This shift in boater traffic would serve to erode a daytime Regulatory Mandatory Boat Inspection program. Also, this dichotomy in oversight may be negatively viewed as providing unequal treatment of boaters. 3. As with Regulatory Mandatory Inspection and Self-Certification, this program would require a legislative rule making. 3.7 Lake George Alternative 6: Inclusion of Non-Motorized Watercraft 3.7.1 Description

Commission regulations at 6 NYCRR 6465-7.7 currently exempt non-motorized vessels less than 18 in length from the existing requirement for annual boat registrations. Many of the western states AIS prevention programs require an aquatic invasive species decal for all vessels including non-motorized vessels (ie. $5 in Wyoming). It has been proposed that a similar program may be undertaken for Lake George with a $5 decal fee for non-motorized boats less than 18. This program may be implemented by itself, or in concert with any other AIS alternatives described. The registration process would follow the Commissions existing boat registration process whereby an aquatic invasive species boat decal would need to be annually purchased from the Commission or one of its authorized vendors,

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and this decal affixed to the vessel prior to placing the vessel on the waters of Lake George. Boats that are already required to register with the Commission would be exempt from the AIS decal program. 3.7.2 Potential Benefits (Pros) 1. This program would raise awareness of aquatic invasive species, and allow the Commission to educate additional boaters on spread prevention techniques. 2. This program would raise funds dedicated to AIS spread prevention measures. The Commissions Marine Patrol annually conducts a lake wide boat survey. Recent results from this survey indicate the patrol routinely observed approximately 3600 nonmotorized boats (2700 canoes and 900 sailboats) on the water and along the shores of Lake George that would be required to register for an AIS decal. Using these data as a guide, we estimate 5,000 boats may be required to register annually for an AIS decal. Based on a $5 fee, this would raise $25,000 annually. 3.7.3 Potential Drawbacks (Cons) 1. This program would be an increased inconvenience and cost to the boating community, many of whom have multiple small craft that would be required to register. 2. Compared with their motorized counterparts, non-motorized vessels such as kayaks and canoes, which have few moving parts, limited water carrying capacity, are generally inverted for overland transport, and are stored on land (not in the water) between voyages, represent a relatively small risk of AIS transport. As such, the cost/benefit of educating this boating populous pales in comparison to the motorized boating community. 3. The administration of boat registration fees has a cost. Currently, the Commission processes 19,500 boat and dock registrations annually. To cover this workload, the Commission hires two seasonal employees to keep up with demand at a cost of $18,000 annually. The addition of another 5,000 decals would increase the administrative cost of the annual registration program by 25.5% or roughly $4,656. The net value of the AIS decal fee would be offset by the administrative costs associated with this program. The net value of the program would be $20,344. This type of program would create much larger and impactful revenue at a statewide scale.

3.8

Cost Summary of Alternatives

A cost comparison of the alternative programs is presented in Table 3-1 below. The Mandatory Boat Inspection and Decontamination Alternative has the highest costs but also the highest benefits and best meets the goals of the Commission to prevent new invasives from being introduced to Lake George. Table 3-2, Comparison of Alternative Actions, summarizes the differences between the four alternative actions.

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Table 3-1. Summary of Estimated Costs of Alternatives Lake George Alternative Scenarios Estimated Cost No Action No Cost Enhanced Voluntary Compliance $ 85,000 - $100,000 annual Regulatory Self-Certification $50,000 - $75,000 startup $150,000 -300,000 annual Regulatory Mandatory Boat Inspections $200,000-300,000 startup $650,000 $700,000- annual operation Regulatory Mandatory Inspection with $250,000-375,000 startup After-Hours Self-Certification $660,000 $715,000 annual operation Regulatory Non-motorized Boat 5,000 startup Registration Net annual gain of $20,344

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Table 3-2. Comparison of Alternative Actions

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SECTION 4 4.1

ECONOMIC ANALYSIS AND IMPACTS

Introduction

This chapter describes the anticipated economic consequences of each of the alternatives referenced in Chapter 3. The No Action Alternative that would decrease the spending on voluntary boat inspections would likely result in the rapid introduction of new invasive species. The preferred alternative of mandatory inspections is fully described in Chapter 5 and will decrease introduction of AIS to the lowest possible rate. See Appendix E for the description of economic impact assessment methodology and detailed analysis. 4.2 Description of Assessment Area

Lake George is perhaps the most striking lake setting in the eastern United States. Furthermore, the lake and surrounding region is a recreation and tourism destination of regional, if not national significance. The reasons supporting these claims are numerous: The lake water quality the water quality remains at a high level with residents using the lake as a drinking water source. Additionally, the water quality supports numerous wildlife through the provision of habitat for varying plants and animals; The geography of the lake has contributed heavily to the dynamic cross section of fish found in the lake and the beauty of the setting. The lake shore in some areas is surrounded by steep slopes and mountain ranges while other areas provide gentle slope for ease of access; The wider region around the lake finds the Adirondack Mountains to the north and west with abundant lakes, streams, rivers and ponds. When considered in total the region is a tremendous ecological resource with natural landscapes that draw recreationalists and tourists from across the northeastern United States; The built environment is rich with history having providing the setting for significant events in the colonial history of the nation. This built environment of the Adirondacks and Lake George has evolved to provide complementary tourist and recreational attractions that provide approximately $1.1 billion in economic activity supporting approximately 20,000 jobs; and, The location of the region in close proximity to major metropolitan areas including New York City, Boston, Montreal and Philadelphia is easily accessed by multiple forms of transportation and correspondingly receives hundreds of thousands of visitors from across the northeast.

These are just some of the attributes that serve to distinguish the lake and surrounding region from any other are in New York State. The lake itself is approximately 32 miles in length with a north-south orientation extending from Lake George Village in Warren County to Ticonderoga in Essex County. The water area of Lake George covers approximately 27,217 acres. Most AIS are most likely to occur in the littoral zone of the lake. This zone is basically described as the shallow water area extending from the shoreline to a point where water depth is approximately ten (10) meters in depth (Boylen and Kuliopulo, 1981). This area provides favorable conditions (water temperature, water depths, sediments, etc.) for establishment and growth of AIS to occur (see Section 2.9.1). The area of the lake that meets these parameters comprises approximately 8,058 acres or twenty-nine percent (29%) of the overall water coverage area. This area of the Lake is the location where much of the recreational contact with the water occurs as the littoral zone provides areas for

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beaches and swimming, docks, and moorings. This area also serves as the primary habitat for many game fish attracting recreational and sport fishermen or anglers. The area which will be the focus of the economic impact assessment that follows are the 3,130 shoreline properties along Lake George and extending through eight (8) municipalities (the Towns of Dresden, Fort Ann, Putnam, Bolton, Hague, Lake George (inclusive of the Village of Lake George), Queensbury and Ticonderoga) within three (3) counties (Washington, Warren and Essex), see Appendix I. This area was selected since these parcels provide the means for various forms of direct contact with the water (swimming, boat launching and boating, and waterfront views from both perspectives from the shoreline out over the lake and from the lake along the shoreline and beyond). As such, this area will be directly affected by the presence of AIS. Additionally, it is acknowledged that the economic impact of AIS may have implications to upland (off shore) properties. As a practical matter many properties just off the shore have entitlement to some form of water access through deed reference and/or shared use of on shore amenities such as docks, moorings and beaches. The research necessary to quantify these circumstances is beyond the scope of this assessment, but impacts to upland properties with some form of access to the lake shore and associated amenities is a likely scenario that would add to the impacts projected from the following analysis. 4.3 Economic Assessment of Alternative Actions

Based on the understanding of the area most likely impacted by AIS as described above an assessment of economic impact of AIS spread prevention has been performed for each of the alternatives as listed in Chapter 3. The assessment of economic impact related to AIS is an emerging field of study. Therefore, to evaluate the potential economic impacts of AIS a series of studies from across the United States were reviewed. In most instances AIS evaluation have examined the economic impacts associated with impacts to shipping or infrastructure or utilities particularly in the Great Lakes region. However, some of the more recent economic impact analyses seem to focus on case studies relating recreation and tourism and related expenditures made within the local and regional economies. A thorough analysis of prior studies and literature relating to economic impact assessment reveals that economic impact has been evaluated along two general categories: anticipated impacts to waterfront property values, and water-based recreational/tourism activities such as boating, swimming, fishing, etc. As the understanding of AIS introduction to lakes and the associated economic effects to these categorical considerations is relatively in its early stages of development, the assessment performed for this evaluation is reliant upon existing studies of water bodies with similar environs as found in the Lake George region. Specific similar elements of the environs include residential and commercial development of waterfront parcels. Developed qualities of these parcels include attributes that provide a high level of interaction with the waterfront (i.e. beaches, docks, boat houses, building orientation to waterfront views, etc.) and a regional economy with significant tourism, lodging, entertainment, and sport fishing business sectors that are heavily invested in the water body as an attraction/destination for tourists and visitors to the region. In addition to focusing on regions with these similar physical and economic qualities, the methodology employed to perform the assessment of potential economic impact will also rely upon credible studies that conclusively project levels of impact to waterfront property values and the business sectors as referenced above. In most instances the level of impact ranges based on anticipated types and levels of AIS concentration occurring in the water body. Therefore, the projections of impact from the referenced studies will serve as the basis for anticipated economic impacts in the Lake George region.

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The final component of the methodology employed to assess economic impact of AIS involves tempering the anticipated impacts forecast in other lake regions with actual economic data for the Lake George region. A review of recent tourism studies of the region finds that there have been instances where water quality degradation, whether real or perceived, has been correlated with corresponding downtowns in tourism activity and these levels of impact have been within the ranges cited by studies of lake regions elsewhere. The similar levels of economic impact resulting from water quality degradation as noted provide a basis for projecting the economic impact 4.3.1 No Action Alternative

The "No Action" Alternative is a required element of environmental assessment as specified in SEQRA and has to be considered by any project applicant as an available alternative. Therefore, the evaluation of the short and long-term consequences of the No Action Alternative is as follows: The economic impact of the No Action Alternative will be assessed under the scenario that the Commission would suspend current spread much of its proactive prevention effort which is funded through the Environmental Protection Fund (EPF), as described in Alternative 1efforts. Therefore, interception of AIS would be limited to voluntary inspection programs as overseen by local non-profits and lake stewards. However, most of the LGA Steward program is funded by the LGPC through the EPF, so there is likelihood that this program would be greatly reduced in coverage under this scenario. According to research of other voluntary programs in similar circumstances and given the facts as listed above, the risk of AIS introduction and spread is high. Therefore, for the purposes of economic impact assessment it is expected that further AIS introduction are likely to occur. Once AIS are introduced, further research in other lakes with similar characteristics indicates that spread within the water body occurs within a period of years impacting vast areas of the lake bed. It is understood that no AIS prevention program will be 100% effective, as some vectors of spread are beyond our ability to manage. It is also understood that the alternatives evaluated each have varying levels of anticipated protection and success at preventing new AIS into Lake George. The economic evaluation identifies that higher levels of AIS prevention equate to improved long-term economic protection of the Lake George regional economy. In essence, the No Action economic scenario portrays that Lake George would be infected with new AIS at a faster rate than other options, therefore this scenario was used to discuss what the economic consequences of infestations could be, both on a regional and localized scale. It is also understood that not all economic impacts affect the entire region, but specific infestations can have significant impacts upon localized areas. This is clearly demonstrated in the existing Asian clam infestation in the Lake George Village area. If the clam populations reach densities and levels that exhibit millions of dead clams and shells covering the swimming areas (a realistic possibility if management efforts are unsuccessful), the outcome would have significant economic implications for those resorts and ultimately the Village and Town of Lake George. As this infestation spreads, these same consequences would be evidenced in other tourism related areas of the lake. This similar regional impact scenario could be manifested with infestations of species such as Hydrilla, Brazilian elodea, Water chestnut, and many others. Anticipated Impacts to Recreation As described above, studies from similar lake regions in other states were reviewed as a resource for estimating AIS impacts to recreation. The Lake Tahoe Regional Planning Agency

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conducted an assessment of the economic impact of AIS on recreational activities. The assessment titled Lake Tahoe Region Aquatic Invasive Species Management Plan provided estimated ranges of impact based on the form of recreational activity and overall tourist visitation. As with impact to real property valuation, the level of impact is dependent upon the severity of coverage of AIS infestation: Recreational Activity: Beach Activities Swimming Power Boating Canoeing/Kayaking Fishing Anticipated Range of Impact: -10-20% -20-80% -10-30% -20-40% -10-35%

The ranges are particularly relevant to the consideration of recreational and tourism impacts under the No Action Alternative. Assessing impacts within a range is an effective method as allowance will be provided for the variation of AIS coverage based on time elapsed and conditions suitable for AIS to exist and spread. Using the anticipated ranges of impacts to recreational activities as cited in the Lake Tahoe Region Aquatic Invasive Species Management Plan the following additional impacts could be anticipated: A potential for reduction of boating activity. The range of impact as referenced in the Lake Tahoe Region Aquatic Invasive Species Management Plan is not supported by the actual boater registrations as recorded by the LGPC. Since 1994 annual boater registration totals have fluctuated between a high of just over 11,600 registrants in 2002 to a low of over 9,600 in 1995 (a 17% difference), with the most recent year (2011) totaling 10,387. The year-toyear fluctuations demonstrate no discernible correlation with AIS activity in Lake George and appear to be more associated with factors associated with the status of the local and regional economies. Therefore, it is anticipated that under a no action alternative the impact to boater activity would be significantly less than noted difference between the peak year of boater registration and low year. As such it is anticipated that impact to boater registration would likely be at the lower end of the range as cited in the Lake Tahoe Region Aquatic Invasive Species Management Plan or ten percent (10%). Therefore a loss of approximately $3.35 million in related expenditures from reduced boater activity could result. Swimming. The attractiveness of swimming as a recreational activity is highly dependent upon the qualities of the specific beach or area. Therefore, the anticipated impact from AIS will range widely depending upon the specific nature of the AIS and the degree that it diminishes the activity. For example, dense concentrations of Eurasian Watermilfoil (EWM) or Asian clams could severely diminish swimming activities. Therefore, these high-levels of variations result in a relatively wide range of anticipated impact from twenty to as much as eighty percent (20%-80%) in specifically affected areas and dependent upon the extent and type of AIS infestation. and, Fishing. Governmental agencies track fishing activity based on angler days. An angler day is referred to as an occurrence where a person undertakes fishing as an activity. Of all recreational or tourists activities considered AIS has potentially the least impact to fishing. The studies reviewed noted some reductions in fishing activities from AIS. However, instances were cited where fishing activity diminishes during the initial introduction of AIS, but not as severely as other water-based activities and in some cases angler days demonstrated some recovery after the first year or two. The reasons cited for circumstance are that some, limited instances of AIS introduction can improve habitat conditions for certain types of game fish and other game fish exist in habitats beyond the littoral zone

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where most AIS impacts occur. In consideration of these circumstances the anticipated reduction in angler days could result in a reduction of angler days ranging between ten percent (10%) and thirty-five percent (35%) resulting in an annual loss of up to $9.6 million from reduced fishing expenditures. Anticipated Impacts to Tourism and Related Expenditures As the effect of AIS on the local tourism economies is an emerging field of study, there is increasing emphasis on understanding the relationship between AIS and the adverse impacts to water-based recreational activities and the associated effects on tourism and visitation. The Lake Tahoe estimates cited above, although useful are projections. As such they are not based on actual levels of impact observed over time. Therefore, further research was conducted to ascertain a basis for impact based on actual occurrences relating water quality impacts in the Lake George region. Additionally, it should be noted that Lake Tahoe and Lake George exist in different geographic scenarios, and recreational impacts to Lake Tahoe may not necessarily be equated directly to Lake George. This assessment is provided to detail a discussion on the various potential economic impacts from both a qualitative and quantitative means. The importance of Lake George water quality and the public opinion of water quality as an attribute or a detriment, whether perceived or real, are evident within the summary of year-toyear visitor events as presented in Table 8 of the Warren County Tourism White Paper. The table tracks annual visitor events in Warren County from 1994 through 2009. There are notable downturns in total visitor events that can be attributed to recessionary periods and economic fluctuations. However, two notable downturns are noted in the report. The report notes the negative perception in the tourism market relating to the boating accident in 2005 that claimed twenty lives in October of 2005 (Ethan Allen accident), and the negative publicity relating to a sewer line rupturing in 2009 near the public beach at Shepards Park in the Village of Lake George resulting in closure of the beach from early July through August due to negatively impacted water quality. These events resulted in a thirty percent (30%) decline in visitation in 2005 and a decline of over fifteen percent (15%) in 2009, respectively. The negative effect of these events on tourist visitation and the high importance survey responses assigned to water quality and ability to enjoy water-based recreational activities provide insight into the importance of water quality and a basis to conclude that a negative shift in water quality, whether perceived or real, will dramatically affect tourism in the Lake George region. Furthermore, the Warren County Tourism White Paper notes the level of internet usage that is occurring among travelers. The report states that by 2009 nearly seventy percent (70%) of travelers seeking to make reservations were using the Internet1. The conclusion being that tourism is a quickly changing market where perceptions are formed quickly based on readily available and up-to-date information. Negative perceptions of water quality as demonstrated with the event at Shepards Park in 2009 can have an immediate lasting effect on tourism throughout the Lake George region. These findings, combined with the estimates from the Lake Tahoe Management Plan, indicate that tourism visitation can be adversely impacted when water quality conditions are perceived to be degraded. These actual events and associated impacts to visitation, and the estimated ranges of impact to recreational activities as forecast in the Lake Tahoe Management Plan, provide a basis for assessing the potential impact of AIS spread under a No Action Alternative to tourism in the Lake George region.

Warren County Tourism White Paper; ConsultEcon, Inc.; September 2010

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As the ranges cited in the Lake Tahoe Management Plan are based on projections and not actual levels of impact, the lower end of the ranges for impacts to recreational activities cited above will be used as a basis for estimating potential impacts to tourism expenditures in the Lake George region. Furthermore, the justification for projecting the impact to tourism expenditures at the lower end of the cited ranges rests with the notable differences between the characteristics of the tourism economy of Lake Tahoe and the tourism economy of the Lake George region. The Lake George region has a diverse set of destination-style attractions such as amusement parks and themed events such as Americade, that are indications of broadbased appeal across a number of divergent market groups. It is anticipated that the broadbased appeal of the overall tourism experience in Lake George region will insulate, to some degree, the adverse impact associated with AIS infestation. Additionally, the overall geographic setting in the context of a larger regional destination (the Adirondack Park) is an attraction in its own right and will continue to draw interest from visitors from across the northeast and nation. On this basis it is assumed that overall tourism visitation under the No Action Alternative could result in a range of losses between two and ten percent (2%-10%). Using the data from 2009/2010 tourism visitation and expenditures as the baseline the resulting impact within the range cited above is estimated to be as follows: The loss in total annual tourism expenditures is estimated to range between approximately $9.74 million to $48.7 million; The annual loss in the number of visits (visitor events) to the region is estimated to range between approximately 146,600 to 733,000 events; The annual loss in expenditures related to meals is estimated to range between approximately $2.2 million to $10.98 million; The annual loss in expenditures related to shopping is estimated to range between approximately $1.58 million to $7.87 million. It is further estimated that the anticipated loss in shopping expenditures will result in a contraction of retail space by approximately 12,640 square feet to 62,960 square feet; The annual loss in expenditures related to entertainment /attractions is estimated to range between approximately $1.77 million to $8.84 million; The annual loss in expenditures related to transportation is estimated to range between approximately $740,000 to $3.69 million; The annual loss in expenditures relating to lodging is estimated to range between approximately $2.28 million to $11.4 million. It is noteworthy that the average rate of occupancy among Warren County lodging facilities for the period of 2003 through 2009 was just over 53 percent (53.7%)2. The Warren County White Paper notes a concern related to an imbalance between lodging supply and demand. An additional drop in demand associated with reduced visitation and related expenditures would contribute to further imbalance; The annual loss in other expenditures is estimated to range between approximately $1.26 million to $6.32 million; and Tourism-related employment (direct, indirect and induced) is estimated to experience a net loss of approximately 162 to 800 jobs with a corresponding reduction in wages paid ranging from approximately $4.55 million to $22.74 million; Anticipated Impacts to Waterfront Property Values This aspect of the analysis will assess the anticipated impact of the No Action Alternative to real property values along waterfront parcels and the associated effect on real property revenue which are ultimately based on assessed valuation.
2

Warren County Tourism White Paper; ConsultEcon, Inc.; September 2010

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Concentrations of AIS through the littoral zone, under the No Action Alternative will likely vary within a range from moderate to maximum levels (see Section 3.9.3) as the conditions throughout the littoral zone (sediment types, concentrations, rocks, bedrock outcroppings, etc.) are not constant. Correspondingly, the resulting impact to property levels will range as well. Based on the cited research3 the anticipated percentage loss in value for properties along Lake George is estimated to impact property values, on average, at a moderate level (2.39%). The specific level of impact will vary with specific types and levels of concentration of AIS found within the waterfront area. The following tables summarize the range of effect to property valuation (see Table 4-1) and the associated effect to real property tax revenues (see Table 4-2) for each of the municipalities within the study area as defined:

Theeffectofanaquaticinvasivespecies(Eurasianwatermilfoil)onlakefrontpropertyvalues;CongwenZhang andKevinJ.Boyle,DepartmentofAgricultureandAppliedEconomics,VirginiaTechUniversity,2010

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Table 4-1 Lake George Waterfront Parcels: Summary of Impact of No Action Alternative to Waterfront Property Values Lakefront Property Valuation $104,554,046 $631,837,649 $281,132,366 $346,517,788 $508,767,432 $81,775,550 $313,374,460 $96,820,474 $2,364,779,765 Lakefront as a Percent of Total Value 19.00% 35.01% 45.01% 26.65% 13.36% 28.96% 48.50% 33.06% 25.40% Estimated Loss of Value to Lakefront Properties @ 2.39% $2,498,842 $15,100,920 $6,719,064 $8,281,775 $12,159,542 $1,954,436 $7,489,650 $2,314,009 $56,518,236 Net Valuation of Lakefront Property @ 2.39% Reduction $102,055,204 $616,736,729 $274,413,302 $338,236,013 $496,607,890 $79,821,114 $305,884,810 $94,506,465 $2,308,261,529

Total Valuation Municipality: Ticonderoga Bolton Hague Lake George Queensbury Dresden Fort Ann Putnam Total Study Area $550,255,253 $1,804,553,787 $624,601,494 $1,300,108,925 $3,809,141,682 $282,374,019 $646,066,823 $292,897,305 $9,309,999,288

Sources: 2010 Tax Roll: Office of Real Property Services for Essex, Warren and Washington Counties. Data for Local Governments: NYS Office of the Comptroller

Table 4-2 Lake George Waterfront Parcels: Summary of Impact of No Action Alternative to Municipal Real Property Tax Revenue Estimated Percentage Loss Estimated Loss of Estimated Real Total Revenue of Real Property Tax Real Property Tax Property Tax Derived from Revenue @ 2.39% Revenue @ 2.39% from Lakefront Real Property Tax Reduction Reduction Properties Municipality: Ticonderoga Bolton Hague Lake George Queensbury Dresden Fort Ann Putnam Total Study Area =
Sources:

$3,619,477 $1,012,793 $621,659 $2,547,934 $5,056,412 NA $1,771,551 $912,246 $15,542,072

$687,737 $354,614 $279,808 $679,100 $675,359 NA $859,290 $301,553 $3,837,462

$16,437 $8,475 $6,687 $16,230 $16,141 NA $20,537 $7,207 $91,715

0.45% 0.84% 1.08% 0.64% 0.32% NA 1.16% 0.79% 0.59%

2010 Tax Roll: Office of Real Property Services for Essex, Warren and Washington Counties. Data for Local Governments: NYS Office of the Comptroller

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4.3.2

Enhanced Voluntary Compliance

This alternative involves the implementation of initiatives to inform the public, particularly owners of water craft, of the adverse impacts AIS can have on a water body such as Lake George. The premise being that once informed, the public will take proper precautions (washing their boat, draining bilge, self-inspecting for dry conditions, etc.) prior to launching their watercraft. Anticipated Impacts to Recreation and Related Expenditures The research conducted in association with this environmental assessment finds that AIS introduction under the public education alternative, although slowed, does continue under this alternative measure. Therefore, although not as severe as the rate and level of infestation under the no action alternative it is anticipated that some level of contamination will occur and AIS will become established and spread. Under this circumstance, it is expected that the economic impact will be proportionately less. Anticipated Impacts to Tourism and Related Expenditures The research conducted in association with this environmental assessment finds that AIS introduction under the public education alternative, although slowed, does continue under this alternative measure. Therefore, although not as severe as the rate and level of infestation under the no action alternative it is anticipated that some level of contamination will occur and AIS will become established and spread. Under this circumstance, it is expected that the economic impact will be proportionately less. Anticipated Impacts to Waterfront Property Values The research conducted in association with this environmental assessment finds that AIS introduction under the public education alternative although slowed, does continue under this alternative measure. Therefore, although not as severe as the rate and level of infestation under the no action alternative it is anticipated that some level of contamination will occur and AIS will become established and spread. Under this circumstance, it is expected that the economic impact will be proportionately less. 4.3.3 Regulatory Self-Certification

As previously described, many programs in other states researched as part of this assessment rely upon a combination of enforcement and self-inspection or self- certification inspection to limit the transport of AIS. To implement self-inspection, it will be necessary to have the cooperation of the NYS Police, Warren County Sheriff, Washington and Essex County Sheriffs and possibly additional LGPC patrol staff. The prohibition on transport will have to include all matter of biological debris rather than just AIS. It is difficult to enforce AIS rules if a peace officer has to determine that the debris is AIS. Anticipated Impacts to Recreation and Related Expenditures The research conducted in association with this environmental assessment finds that AIS introduction under the self-certification alternative, although slowed, does continue under this alternative measure. Therefore, contamination will continue and AIS will become established and spread. Although the rate of contamination may be lowered it is anticipated that the net impact to recreation will be the same as forecast under the No Action Alternative. Anticipated Impacts to Tourism and Related Expenditures The research conducted in association with this environmental assessment finds that AIS introduction under the self-certification alternative, although slowed, does continue under this
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alternative measure. Therefore, contamination will continue and AIS will become established and spread. Although the rate of contamination may be lowered it is anticipated that the net impact to tourism will be the same as forecast under the No Action Alternative. Anticipated Impacts to Waterfront Property Values The research conducted in association with this environmental assessment finds that AIS introduction under the self-certification alternative, although slowed, does continue under this alternative measure. Therefore, contamination will continue and AIS will become established and spread. Although the rate of contamination may be lowered it is anticipated that the net impact to waterfront property values will be the same as forecast under the No Action Alternative. 4.3.4 Regulatory Mandatory Boat Inspection

This alternative envisions that mandatory inspection procedures will be implemented by LGPC staff and/or by commercial facilities with trained personnel. Area implementation needs to cover the entire lake, yet be cost effective while providing inspections from April-December near the lake and within the basin on a year-round basis. The mandatory inspection process will be implemented by the LGPC. The LGPC and any authorized designees would be authorized under NYS law and LGPC regulations to inspect bilge, sub-deck compartments, bait containers, live wells, watercraft exteriors, trailers and tow vehicles for plant species and biological materials. The regulation would allow for the issuance of tickets and fines if a watercraft, trailer or tow vehicle is found to violate the rules and regulations pursuant to this regulatory initiative. Anticipated Impacts to Recreation and Related Expenditures Research relating to potential impacts to boating is somewhat mixed. A study focused on recreational boating for four (4) water bodies in the State of Colorado (Boyd Lake, Douglas Reservoir, Carter Lake and Horsetooth Reservoir) titled The Affects of Mandatory Boat Inspections on Recreational Boating determined that number of days; length of stay; and type of boater registration (daily or seasonal) were unaffected by mandatory inspections4. Additionally, data regarding boat inspections conducted at Lake Tahoe since the inception of a mandatory boat inspection program in 2009 indicates that there have been no noticeable impacts to the number of boaters seeking to launch at Lake Tahoe. According to the Tahoe Regional Planning Agency (TRPA) that oversees administration of the mandatory boat inspection program, annual boat inspections totaled 14,555 in 2009 the inaugural year of the program; 14,755 in 2010 (+200 over the prior year); 14,905 in 2011(+150 over the prior year and +350 since inception of the mandatory inspection program). Additionally, it is noteworthy that fees associated with boat inspection rose several times throughout the three year period cited. Based on the study as cited above and the actual data compiled by TRPA over a three year tracking period of mandatory boat inspection it is anticipated that implementation and administration of a mandatory boat inspection program will have minimal or no impact to the number of boaters on the Lake. However, it is understood that if the costs of this program borne by boaters becomes too great, it would negatively impact boater use of Lake George.
4

TheAffectsofMandatoryBoatInspectionsonRecreationalBoating;BradWright;UniversityofNorthern Colorado;2009 Page 4 - 10

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Anticipated Impacts to Tourism and Related Expenditures It is understood that a fundamental premise of this alternative method for the prevention of further spreading of AIS is mandatory inspection of all boats prior to launch into Lake George. According to the performance of similar spread prevention programs, where inspection of all boats is mandatory, AIS introduction from the primary vector (transient boats) will be reduced to the greatest extent practicable. However, AIS introductions may not be eliminated. This proposed alternative measure will have a minimal adverse impact on tourism in the Lake George area. Anticipated Impacts to Waterfront Property Values Based on the research performed and the performance of similar AIS spread prevention programs employing mandatory inspections of visiting boats, it is estimated that the introduction of additional AIS from contaminated boats will be minimal. Therefore, less than one percent (1%) of additional AIS coverage from visiting boats is anticipated resulting in a decrease in total assessed value of .33 percent or $7.8 million spread over the 15,056 acres among the shoreline parcels of Lake George for an average of approximately $518 per acre.

Photo Credit: Lake George Association

4.3.5

Regulatory Mandatory Boat Inspection with After-Hours Self-Certification

This alternative blends mandatory inspection procedures with self-certification during unstaffed hours. This program would be implemented by LGPC staff and/or by commercial facilities with trained personnel. Area implementation needs to cover the entire lake, yet be cost effective while providing inspections from April-December near the lake and within the basin on a yearround basis. The mandatory inspection process and self-certification program would be implemented by the LGPC. The LGPC and any authorized designees would be authorized under NYS law and LGPC regulations to inspect bilge, sub-deck compartments, bait containers, live wells, watercraft exteriors, trailers and tow vehicles for plant species and biological materials. The regulations would allow for the issuance of tickets and fines if a watercraft, trailer or tow vehicle is found to
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violate the rules and regulations pursuant to this regulatory initiative, and that pertaining to selfcertification. Anticipated Impacts to Recreation and Related Expenditures As noted in the prior section, it is anticipated that implementation and administration of a mandatory boat inspection program will have minimal or no impact to the number of boaters on the Lake. However, it is understood that if the costs of this program borne by boaters becomes too great, it would negatively impact boater use of Lake George. Regarding ecological integrity, it is anticipated that this blended approach would provide increased protection from AIS during the high traffic launch times, however this would be counteracted by potential changes in boater launch patterns and though slowed, AIS introduction via trailered boats would continue to become established and spread under the administration of an after-hours self-certification program. Anticipated Impacts to Tourism and Related Expenditures A mandatory inspection program will reduce AIS introductions from the primary vector (transient boats) to the greatest extent practicable. However, a concurrent after-hours self-certification program will compromise the protections offered during staff hours. Therefore, contamination will continue and AIS will become established and spread. Although the rate of contamination may be lowered it is anticipated that the net impact to tourism will be the same as forecast under the No Action Alternative. Anticipated Impacts to Waterfront Property Values The research conducted in association with this environmental assessment finds that AIS introduction under the self-certification alternative, although slowed, does continue under this alternative measure. Therefore, contamination will continue and AIS will become established and spread. Although the rate of contamination may be lowered it is anticipated that the net impact to waterfront property values will be the same as forecast under the No Action Alternative. 4.3.6 Inclusion of Non-Motorized Watercraft This alternative involves the implementation of a boat registration fee for all boats currently exempt from annual registration with Commission. The goal of this initiative is raise awareness of AIS transport issues with owners of non-motorized watercraft, and to raise funds that may be utilized for AIS prevention. The premise being that once informed, the public will take proper precautions (ie. C-D-D protocol) prior to launching their watercraft. Anticipated Impacts to Recreation and Related Expenditures The research conducted in association with this environmental assessment finds that AIS introduction under the public education alternative, although slowed, does continue under this alternative measure. Therefore, although not as severe as the rate and level of infestation under the no action alternative it is anticipated that some level of contamination will occur and AIS will become established and spread. Under this circumstance, it is expected that the economic impact will be proportionately less. Anticipated Impacts to Tourism and Related Expenditures The research conducted in association with this environmental assessment finds that AIS introduction under the public education alternative, although slowed, does continue under this alternative measure. Therefore, although not as severe as the rate and level of infestation under the no action alternative it is anticipated that some level of contamination will occur and AIS
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will become established and spread. Under this circumstance, it is expected that the economic impact will be proportionately less. Anticipated Impacts to Waterfront Property Values The research conducted in association with this environmental assessment finds that AIS introduction under the public education alternative although slowed, does continue under this alternative measure. Therefore, although not as severe as the rate and level of infestation under the no action alternative it is anticipated that some level of contamination will occur and AIS will become established and spread. Under this circumstance, it is expected that the economic impact will be proportionately less.

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THE PROPOSED PROJECT (ALTERNATIVE 4)

5.1

Regulatory Mandatory Boat Inspections 5.1.1 Selection of the Preferred Alternative

The Preferred Alternative is the inspection, prior to launch, of all motorized boats that are brought by trailer to Lake George. This alternative has been chosen as the preferred alternative based on the fact that this alternative is seen to be the most effective means available to protect Lake George from new aquatic invasive species. The program described below for the mandatory inspection of all trailered boats ensures, to the highest degree practicable, that both visible and non-visible (juvenile or microscopic) species are kept from entering Lake George from the most prominent vector, trailered boats. No other alternative has the means to provide very high levels of compliance that the mandatory program does, which is critical to the long-term protection for the lake. This important factor, coupled with the ability to prevent juvenile, non-visible species from being introduced to the lake, creates the critical mass that makes this option the best protection for Lake George. The selection of this alternative is founded upon scientific reviews regarding the efficacy of boat inspections, effectiveness of boat washing programs, vectors of transport of aquatic invasive species, experience of similar programs in western states, and the ability to effectively implement such a program. This alternative also provides the best long-term economic protection for the Lake George regional economy. Lake George is heralded for its pristine nature, and impacts from invasive species can cause long-term economic harm to this tremendous resource, from both a tourism and a property values perspective. These pros of the implementation of this AIS prevention program are seen to significantly outweigh the cons, which primarily include cost and logistical challenges. When evaluated, the benefits of this alternative are seen to be considerably greater than the benefits of other identified alternatives. Given that the drawbacks of implementation are not seen as insurmountable, makes this the preferred alternative for AIS prevention for Lake George. 5.1.2 Description of Program

The Preferred Alternative is the inspection, prior to launch, of all motorized boats that are brought by trailer to Lake George. Those boats that do not meet the inspection standard of Clean-Drained-Dry (C-D-D) are required to have their boat decontaminated through a High Pressure Hot Water (HPHW) prior to launch in Lake George. Decontamination will be provided at the inspection stations. The objective will be to prevent the introduction of AIS into Lake George. Non-motorized watercraft will be exempt from inspection. Please note, however that AIS introductions associated with all possible vectors (ie. non-trailered watercraft, aquarium dumps, fishing equipment, etc) are proposed to be the focus of education and outreach efforts, and AIS introduction via these vectors are prohibited in the proposed regulation for this effort. All trailered boats will be required to visit one of the inspection stations that will be available at convenient locations around Lake George. The Commission will train a staff of inspectors who will be stationed at convenient off-lake locations in the Lake George basin to carry out boat

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inspections. Training for inspectors will be based on the protocol outlined in the 100th Meridian Initiative Pacific State Marine Fisheries Commission (Zook B. and S. Philipps, 2012) and will be defined in procedures set forth in a Commission manual (see Appendix I). The Commission manual will include specific instructions with regard to the use of HPHW and the potential hazard to employees of the Commission, the general public and the property which is be decontaminated. Effective decontamination will require constant verification of water temperature, a through review of vessel compartments which may hold invisible AIS threats and

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Figure 5-4: Concept Plan for Rogers Rock Campground

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Figure 5-5: Concept Plan for Mossy Point Boat Launch

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assurance to the boat owner that no damages will occur. The Commission recognizes that every inspection and every vessel decontamination may be different and require an alternative approach however the safety in any operation will be paramount. Inspectors will be employed or authorized by the Commission to enter the interior of boats in order to complete the inspection of all hull compartments. The inspection process will be completed in 10 minutes or less. Equally important to the boat inspecting process, boat owners will also be asked to drain the bilge, and properly dispose of AIS prior to leaving the launch area to prevent Lake George from being a source of AIS to other waterbodies. Should a boat not meet the C-D-D inspection standard, the boat will have to be washed and decontaminated at the inspection station with High Pressure Hot Water (HPHW) prior to launching. There will be no additional charge for this procedure. Hot water washing at a temperature of 140F or higher has proven to be the fastest and most effective means to destroy juvenile stage mollusks known as veligers, or other microscopic life stages of AIS that are part of the invisible spectrum (Comeau, 2011). Boats with ballast tanks and bilges will have to be drained and possibly inspected with a fiber optic scope or flushed with HPHW. Once the hot water washing process is complete, the boat would be fitted with an inspection tag securing the boat to the trailer. Boats are then permitted to proceed to the boat launch of choice and launch into Lake George. As long as the boat's inspection tag is secured/connected to the trailer the boat is free to launch. Boats that are leaving Lake George launches will also be fitted with inspection tags. These boats may re-launch into Lake George without being re-inspected as long as the inspection tag is intact. The draft rule provides for civil penalties in the form of specific fines against the boat operator and launch owner for launching boats without the required inspection (see Appendix C). 5.1.3 Inspection Station Locations

The mandatory inspection process will be implemented by the LGPC. Implementation will be achieved by establishing regional inspection sites that boaters can conveniently access from the Northway (I-87) and along major travel routes in the Lake George region. The system focuses primarily on off-lake locations so as to provide the most consistent level of inspection for all boats. Alternatively, inspection stations could be provided at launch sites through existing marinas. Most marinas on Lake George do not have the physical space to accommodate a boat inspection, however the regulation will include a provision for the voluntary participation of marinas. The Commission assessed the experience of the Lake Tahoe Regional Planning Agency which initially operated inspection stations at marina points on Lake Tahoe. Following several seasons of operation, inspection stations were moved to off-lake locations along major transportation corridors. Operators note that the inspection process has been greatly improved with this change. The inspection program is constrained by budget concerns so the most flexible and efficient program has been sought. A total of five sites will be selected for the inspection stations in the towns of Ticonderoga, Hague, Bolton, Lake George and Queensbury (see Table 5-1, Potential Inspection Station Sites). Based on the data received from the five regional boat inspection sites following the first year of the program, the Commission may elect to change inspection locations and the manner of management.

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Table 5-1. Potential Inspection Station Sites Town Potential Sites Potential Management Lake George Exit 21 Site: Town of Lake George Landfill LGPC/Town of Lake George Bolton Norowal Marina or LGPC/Bolton L.D.C Site on County Route 11 Hague Rogers Rock State Campground LGPC Ticonderoga Mossy Point State Boat Launch LGPC Queensbury Ridge Road/SR 149 Region LGPC or LGPC/Private Marina The Lake George inspection station is proposed for a site located less than one mile from Northway Exit 21 on Transfer Road just off SR 9N (Luzerne Road). This site is already developed and used for snowmobile trail equipment storage, solid waste transfer station, a gravel pit, and recreational fields. In between all these various uses, there is adequate space to accommodate a large inspection facility. The entry road into the site would need to be improved with better shoulders and eventually repaved. The road elevation changes are somewhat abrupt, but large trucks can access the transfer station, therefore, this road is satisfactory. Entry to the site would require a left turn off of Exit 21 and a left turn out onto 9N when leaving the inspection station. The Bolton inspection site is proposed at Norowal Marina where a voluntary pilot inspection program was successfully operated over past summers. This site receives the most launches of all public launches measured by the Lake Steward Program. Although less ideal, there are sites available along County Route 11 that could be substitutes for the Norowal Marina site. This location would potentially capture boats from Exit 24 heading south into Bolton or north into Hague. The Hague inspection site is proposed at the State-owned and NYS DEC operated Rogers Rock State Campground and Boat Launch, which reported the third highest number of launches by the Lake Steward Program. Lake Steward inspections have occurred at this site over the last 6 years, and the Commission operated a pilot boat wash program at Rogers Rock Campground in 2012. Concurrent campground and boat inspection operations at this site present factors that set this site apart from the other launches. Logistical considerations for this site include campground traffic flow, parking, and camper safety. With this in mind the Commission proposes a flexible approach to undertaking boat inspections that would result in Commission inspectors working amongst three locations within the facility to avoid delays to campground operations. A review of the facility indicates that appropriate locations for inspection and certification (tagging) operations include one of three entrance lanes located at the main gate and the existing gravel pull-off adjacent to the recycling center that DEC currently has reserved as a boat wash area. In consideration of traffic flow and experience gleaned from the 2012 pilot boat decontamination program at Rogers Rock, a boat decontamination station is proposed within a parking area adjacent to the boat ramp. Figure 5-4 depicts this proposed decontamination station as well as proposed signage to promote efficient traffic flow. Signage would direct certified boats to proceed to the launch, and those boats requiring further decontamination would be directed to the parking area to stage for this purpose. An alternative inspection station is being considered in the Town of Hague. The site, located on private property immediately west of the Hague Town Launch, was also host to the 2012 pilot boat decontamination program. operated as an inspection station over part of the 2012 summer season. Use of this privately owned site would result in added program costs (rental or lease)

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for use of the land, and would conflict with annual civic activities that occur on these lands several times each summer. The Ticonderoga inspection site is proposed at the State-owned and NYS DEC operated Mossy Point State Boat Launch located along Black Point Road in Ticonderoga. Data collected from the Lake Steward program indicates that Mossy Point is the second busiest public launch on Lake George. Like the Rogers Rock facility, this site was operated as a boat inspection and decontamination station during the Commissions 2012 pilot boat decontamination program. Compared to other launch locations on the lake, Mossy Point offers a wide access road and expansive parking area, which in 2012 proved to be well suited for accommodating an inspection and decontamination program without hampering launch activity. See Figure 5-5 for a depiction of the Mossy Point launch with proposed boat inspection, boat decontamination equipment, a storage container for securing equipment, signage, and boat staging areas. A driving lane providing access to the launch for pre-inspected (tagged) vessels is envisioned to facilitate shorter staging lines and ease of use. During the early season, it is anticipated the Mossy Point launch will be staffed with additional inspection personnel to accommodate the large volume of boats that utilize this launch. This extra staffing at busy sites will allow for more in-service training so that all personnel have solid on-the-ground experience prior to working at other sites. By having extra staff available at launches that normally serve the highest number of boats, staff will have better in-service training experience. The Queensbury inspection site is not yet defined but several sites offer excellent potential for inspection stations to accommodate boaters coming in from Vermont and preparing to launch at marinas in the southeastern region of Lake George. These sites are on Route 149 and Ridge Road. Other locations could be considered and added as necessary. Electronic message signs and other signage would be required along the Northway, Route 9N and Route 149 to clearly show direction to the inspection sites. Inspection stations will need to be open from mid-April (after ice-out) through December 1at multiple locations. The mandatory inspection procedures may be implemented by LGPC staff and/or by commercial facilities with trained personnel. See Figure 5-1, Potential Inspection Station Sites," for suggested locations of the individual inspection stations. Figure 5-2, Concept Site Plan for Boat Inspection Station Design A; and Figure 5-3, Concept Site Plan for Boat Inspection Station Design B, illustrate the spatial needs under two different scenarios. This program is focused on inspecting trailered boats that arrive at Lake George from other waterbodies that may contain AIS. Boats housed or used solely at Lake George or return annually from storage back to Lake George may not be inspected or may only need to be inspected once. 5.1.4 Control of Launch Access Points

In order for the Mandatory Inspection Program to be successful it is essential that all launch points around Lake George be secured. An inventory of boat launches was conducted on Lake George in 2012 (Rapp unpublished 2012) to determine the level of effort the Commission would have to exert to control access at these sites. The report identified 100 sites that could be used as trailered boat launches. The distribution and types of these launches is reported in Table 5-2, "Summary of Launch Sites on Lake George." Figure 2-3, Lake George Boat Launches Sites, illustrates launch point locations throughout the lake.

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Table 5-2. Summary of Launch Sites on Lake George Type of Launch North South Basin Basin State and Municipal 5 2 Commercial Marina with Public Launch 4 13 Motel/Resort 6 24 Private Residential 13 33 Totals 28 72

Totals 7 17 30 46 100

Under this program, all boat launches would have to be registered with the Commission. Only boats that arrive at a launch with the proper inspection tag would be allowed to launch. Boats arriving at a launch with unbroken tags may launch without delay. Those arriving at launches without the proper tags will not be permitted to launch, and will be referred to the closest inspection station. When launch sites are not staffed, they must be closed either through physical barriers or surveillance with signage advising of the legal requirements for launching. Public Boat Launches (NYS DEC, Town, LDC) Public launches would require staffing to check the inspection status of boats prior to launch. An analysis of boat launch numbers on Lake George indicates that more than two thirds of boat launches on Lake George occur at three locations: Mossy Point, Norowal, and Rogers Rock. As such, it is anticipated these sites would require staffing seven days per week, 12 hours per day through the peak and shoulder seasons. This program proposes the Commission hire seasonal staff to cover these hours at the State-owned/invested boat launches (Mossy Point, Rogers Rock Campground, LDCs Norowal Marina, and Million Dollar Beach). To allow boat launching outside of staffed hours, it is proposed that state-owned launches will be improved with passive surveillance to allow boats that are compliant with the inspection program to access and utilize public launches 24 hours a day. One example of a simple surveillance system by which boats could launch outside of staffed hours is a coupled video surveillance and boat-tag drop box system. Individuals who desire to launch a compliant boat, which is one that has been tagged to its trailer by a C-D-D inspector or launch staff upon exiting the lake, could remove the tag from their boat and simply place it in a locked drop box at the launch to demonstrate their compliance. Upon review of launch surveillance video as well as tags recovered from the drop box, Commission staff would be able to discern whether boats launched during unstaffed hours were compliant or illegal. Boats launched illegally would subject the boat owner to a fine. Private Marinas with Boat Launches As noted above, all private marinas with boat launches would need to register those launches with the Commission. Marina permits would be modified to require that marinas to check all boats for an inspection tag prior to launch. Tags will need to be saved and recorded. Launches must be closed when marina staff is unavailable to review these boats for inspection tags. Under a Memorandum of Understanding with the Commission, facilities and boat haulers that provide winterization and/or quick launch services may be authorized to launch specific boats without inspection. These facility operators and haulers would need to establish a clear chain of custody verifying these boats stay in-basin and are not trailered to other waterbodies.

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Motels with Boat Launches As with all other launches, motel-owned launches will be required to register with the Commission, and be secured when staff are unavailable to monitor the launch. Launches may be secured through any variety of means that will be authorized by the Commission in the launch registration process. Home Owners Associations with Boat Launches Boat launches in the ownership of HOAs will need to register with the Commission. Similar to quick launch facilities, HOAs will be required to identify the specific boats that will be launched at the site. The HOA will need to certify that each of these boats is registered to an HOA member, and is not trailered to other waterbodies. If and when a boat does travel to another waterbody, it can only be launched at the HOA launch once it has passed a Commission sanctioned C-D-D inspection and received the appropriate tag. Residential Boat Launches Residential boat launches are those that are owned by individual landowners, and which are not used for commercial purposes. Residential launches are proposed to be regulated under the mandatory inspection program. In order to operate, each Table 5-3. Cleaned-Drain-Dry Standards residential launch would be required to register with the Commission, and identify the specific boats that will be launched at the site. The landowner would need to certify that each of these boats is registered to the landowner, and is not trailered to other waterbodies. If and when a boat does travel to another waterbody, it could only be launched at a residential launch once it has passed a Commission sanctioned C-D-D inspection and received the appropriate tag. 5.1.5 Inspection Procedures

Boats arriving at inspection stations should be in a C-D-D condition. See the standards for C-DD in Table 5-3. Appendix I, Clean-Drained-Dry Protocols and Standards, provides detailed standards recommended from the Uniform Minimum Protocols and Standards for Watercraft Interception Programs for Dreissenid Mussels in the Western United States. In order to meet the drained and dry standards, an entering watercraft would need to have been drained to the fullest extent possible. Please note it is anticipated the C-D-D standard will be considerate of uncontrollable factors such as rain. Trailered boats that encounter a rainstorm en route to an inspection station will not automatically fail the C-D-D inspection. In instances of rain, inspectors will be advised to evaluate each boats risk level and overall cleanliness, and to utilize their best professional judgment. A simple graphic displaying the proposed inspection process is presented in Figure 5-6. The critical part of the inspection is the interview process to determine where the boat has been and its length of time out of the water. If the inspector determines that the boat exterior is clean, the owners are able to quickly and easily answer the questions on past use, and the anchor

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storage areas/equipment is in clean condition, it is most likely the inspector will find the boat represents a low risk. Figure 5-6. Watercraft Inspection Interview Process

5.1.6

Implementation

It is anticipated that regulations may not be entirely in place prior to March 2013, the start of the 2013 season. The current voluntary program is anticipated to continue to be in place in 2013 and in-service training of inspectors and public outreach to boaters could commence in the fall of 2013. Assuming all regulations and funding authorities are approved in mid-2013, mandatory inspections would be fully operational in all locations in 2014. Frozen Boats It is anticipated that the Commission would establish a boat certification option known as frozen boats for the off-season. This is a cold-weather quarantine program that will seal boats to their trailers for a minimum of nine weeks, or a period sufficiently long enough to kill any
Inspection Tag System Photo Credit: Colorado Inspection Protocol

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aquatic invasive species. Boat owners must schedule an inspection at the offices of the LGPC before February 5. Under a reservation system, the inspection and sealing period would take place between January 25 and February 20, at no cost to boat owners. A site at the north end of Lake George would also be available. Inspection Methods In order for the mandatory boat inspection program to be successful AIS controls must minimize inconvenience to lake users. The best means of accomplishing this is for boat owners to effectively complete the recommended C-D-D protocol prior to coming to Lake George. Boats leaving Lake George will be secured to their trailers following a clean and drain inspection. Should a boat return to be re-launched with the boat still secured to the trailer, no re-inspection will be necessary.
Inspection Seals

Watercraft inspection, whether by a lake steward (voluntary) or by vessel inspection control technician (mandatory), occurs with the cooperation of the boat owner. A VICT has the ability to require compliance with applicable rules that require inspection. The critical portion of the inspection is greeting and interviewing the boat owner upon arrival. This interview is used to determine where and when the watercraft was last used. If the watercraft was last used at Lake George, and a quick visual inspection does not detect debris, the process is essentially over. At the same time, new information on invasives can be given to the boater, along with areas of concern. If a boat was last used at Saratoga Lake in the last week and a half, inspection is warranted. A summary of steps of the typical watercraft inspection is provided Table 5-4, Protocol for Watercraft Inspection. It demonstrates the small but significant differences in the program. This table is based on the protocol of the Western Regional Panel found in Appendix I. The fundamental goals of the program are the same, which are to prevent invasives from entering Lake George, enable boaters to be better stewards of the environment, and gain a high level of compliance as quickly as possible. Table 5-4. Protocol for Watercraft Inspections Task Greet the boaters as they enter inspection areas Ask where was the boat last used Fill out form on place of use and home zip codes (inspector) Ask when the boat was last used at the prior location Look for seal securing boat to trailer If boat is secure to trailer it goes to launch Request permission to inspect the boat if no seal is present Inspector may refer to Colorado Inspection Manual that details protocol for individual boats Inspect exterior for debris of any kind such as mud,

Voluntary NA NA

Mandatory

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Task plant, or animal. Look at hull, transducers, hull penetration, and outdrives. Touch boat hull to determine if rough surface is detectable. May need remedial washing. Inspector may use flashlights or mirrors to aid in examination. Request owner to check interior compartments for water, and hold up anchor to shoe that it is clean Request permission to enter boat to inspect hull compartments if any, anchor, well, or other equipment Ask if they are going fishing and if they are if they are using live bait Request to see bait purchase certificate Boaters departing the lake will be asked if they need a seal Boaters will be requested to drain bilge, hull compartments, and remove debris from boat and trailer prior to departure Boaters immediately going to another lake may choose to have their boat decontaminated

Voluntary

Mandatory

Stewards not authorized to enter boats NA

Operation and Timing of Inspection Stations Some inspection stations will be operated from April 1st to November 30th while other sites will be staffed from Memorial Day through Labor Day. It is anticipated that most inspection and washing sites will operate for 12 hours per day, 7 days a week from Memorial Day to Labor Day. Table 5-5 below provides an outline of the likely operational season and hours of operation for each inspection station. Table 5-5. Inspection Station Operations

Staffing and Training An inspection staff of trained inspectors will be assigned to a regional inspection station with a minimum of one additional inspector available to attend the boat wash station. It will be important for most of the staff to be cross-trained to carry out both inspections and washing. It is necessary to have 2-3 inspectors serving a site and to provide an additional inspector on weekends (Friday-Monday). Regional sites may need to be staffed with three or more inspectors for peak weekends. Special inspection services will be made available to fishing tournaments and boat regattas to facilitate these events.

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LGPC staff will train and supervise inspection personnel, retain inspectors and wash station attendants, provide administrative support and year-round program planning. This will require seasonal staff to be hired and trained annually in order to implement the program. Ultimately, the number of inspection stations will be determined by the availability of funding and the amount of revenue generated by fees and/or supported by state or local funds. Adequate staffing to support five sites during the core boating season will be provided by the LGPC and possibly the towns and potential commercial vendors. During the early implementation phase of the inspection program, protocols will require that frequent in-service retraining be available to workers along with weekly review of issues. Recordkeeping will be important and electronic record data collection will be required. Tablet computers will be necessary to collect daily activity reports and weekly summaries and collect fees through credit card readers. 5.1.7 Management

The LGPC will be responsible for project management and plan implementation, annual reporting, and working with the partners including federal, state, county, local governments, and the NGOs. Year-round duties and program responsibilities will be implemented by the LGPC. Program implementation will require finding and developing inspection sites, working with marinas, training personnel, preparing MOUs with marinas and motels, preparing and operating a variable number of sites, scheduling personnel, closing sites down at the end of boating season, and preparing year end reports. A component of boat inspection will fall under the purview of the Boat Patrol officers as it may relate to issuing citations to individuals transporting invasive species or illegally launching boats. Annual lake monitoring and surveillance efforts for AIS will need to be coordinated to aid in data collection. The functions of operating the inspection services is distinct and separate from general oversight of the program, including funding and administration, which will rest with the Executive Director. Given the multiple components, an AIS Program Coordinator will be needed to oversee the multiple functions associated with the inspection program and invasive control efforts. A Program Coordinator will provide focus on the efforts of surveillance, prevention, and response which are all related and need to be fully accomplished in order to meet the program goals. This type of management structure may fit best given the variety of programs that the LGPC is involved with including docks, stormwater management, and other watershed activities. See Figure 5-6, Proposed Administration Chart, There will be key tasks to be completed each month of the year to allow the inspection program to meet its objectives. An outline schedule that follows the state fiscal budget year is presented in Appendix F.

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Figure 5-6. Proposed Administration Chart

5.1.8

LGPC Authorization Process

An authorization by the executive branch of NYS government is required in order to establish the mandatory inspection of watercraft, trailers and tow vehicles. Authorization from the state legislature is required for any increase in registration fees or the establishment of new fees. These actions would then be followed by amending LGPC rules by adding the requirement for mandatory inspections to Section 646, Substantive Regulations. The right to develop new rules for mandatory boat inspections is provided in NYS Environmental Conservation Law (ECL), Section 43-0107 (12 and 14). This law states that a LGPC officer may patrol land, water, and premises along with the ability to enforce laws including the ECL, which allows designated personnel to inspect boats for sealed heads or wastewater tanks in accordance with the ECL and Navigation Law, Section 32-a. ECL Section 43-0107 will need to be modified in order to provide for the mandatory inspection of the exterior and interior of all watercraft by LGPC and/or by individuals trained to complete those inspections. The LGPC and any authorized designees will be authorized under NYS law and LGPC regulations to inspect bilge, sub-deck compartments, bait containers, live wells, watercraft exteriors, trailers and tow vehicles for plant species and biological materials. The regulation will allow for the issuance of tickets and fines if a watercraft, trailer or tow vehicle is found to violate the rules and regulations pursuant to this regulatory initiative. 5.1.9 Cost Estimates

Startup Costs The mandatory boat inspection program will require an initial source of funds for equipment and site development costs. An annual funding program will be needed for wages and supplies. Two estimates were therefore assembled - one for site development and one for wages. The site development costs assume that the property will need minimal improvement: extensive grading will not be required; power and telephone will be available; and most site components will be portable so that if a location is not needed in the future, materials can easily be relocated or removed. Each inspection site will require a temporary canopy, security fencing for the wash unit, wash pad, gravel driveway, parking, and safety lighting. See Figures 5-3 and 5-4 for two alternatives

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for the site plan. See Table 5-7 for a summary of estimated costs related to startup costs for each site. Table 5-7. Inspection Station Site Development Costs Material Base Unit Cost Wash Unit $ 30,000 10x16 canopy $ 850 Secure Facility for Wash Unit $ 2,000 General site preparation $20,000 Subtotal Contingency 20% Base Cost Total

Installation Cost $ 30,000 $ 850 $ 500 $20,000 $51,350 $10,270 $61,620

Costs per inspection site will vary depending on site conditions. Based on estimates in Table 56, total startup costs for all five inspection sites are estimated at just over $300,000. Operational Costs The annual operational cost per inspection site will vary depending on the demand for services at each location and other factors. Based on the assumptions for employee time and length of season laid out in Table 5-8 below, employee costs for all five inspection stations are estimated at approximately $677,000 per year and include the position of an overall program coordinator at approximately $80,000 annually (including benefits). Other annual program expenses related to training and uniforms, signage, etc. are estimated at $50,000. Table 5-8. Cost of Employees Assumption of Estimated Wages Assumption 5 inspection/decontamination sites Season 20-25 weeks (plus shoulder season) Hourly wage $15.00 base Daily staffing 12 hours (peak season) Weekly staff 7 days/week (84 hours per week) Staff per site 2-3 plus 3 additional staff to rotate as needed Overhead 1.4 Total annual operational program costs for all five inspection stations are estimated at $700,000. 5.1.10 Program Funding Options Introduction Projected startup costs for the Mandatory Boat Inspection Program at Lake George are estimated at $300,000. Funds to support the startup of the program have been sought through the Environmental Protection Fund and other sources. The operational costs of the program are projected to be $700,000 per year. Funds to support these operational costs will have to be generated on an annual basis from a consistent source. There is presently no permanent source of funding to address the critical issue of AIS prevention at Lake George. The Commission has limited choices for funding the program from within based upon present revenues. The majority of revenues for Commission activities are

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derived from annual dock and boat fees. Revenues from boat registrations account for approximately 59 percent of total fees collected by the Commission. Over the last 10 years the number of boat registrations has somewhat declined which has resulted in an estimated annual revenue decline from this source of an estimated $67,000 for 2011. Table 5-9, History of LGPC Annual Boat Registrations, illustrates the change in both annual and temporary boat registrations since 1994. At the same time as the Commission has experienced a decline in revenues, annual funds received from the Lake George Park Commission Trust Fund have been dramatically reduced, while costs related to managing all of the Commissions programs including Asian clam and Eurasian milfoil management have substantially increased. Raising boat registration fees is necessary to not only fund the AIS prevention program but to also administer the Commissions mission to protect Lake George. There are, however, imitations to what can be charged for inspection fees before the cost begins to impact the boaters desire to come to Lake George. Conversely, a reduction in the number of available inspection stations may impact the convenience for boaters and may dramatically impact the effectiveness of the program and the ability of the program to meet AIS prevention goals. The budget and revenues take these factors into consideration. All feasible opportunities to create a consistent revenue stream capable of supporting the Preferred Alternative have been evaluated. Although some of these potential funding sources are more feasible than others, all are considered. The possible sources of funding for the mandatory boat inspection program that are part of this analysis include: Increased boat fees; New inspection and decontamination fees; Use of a portion of Warren County sales tax; Use of a portion of the Warren County occupancy tax; Use of a portion of the mortgage recording tax; Use of a portion of gasoline tax; Creation of a Lake George Park Special District; Funds from the NYS General Fund; Dedicated funds from the Environmental Protection Fund; Federal and state grants; and Regular contributions from municipalities, private donations, and non-profit donations. Table 5-9. Year History of LGPC Annual Boat Registrations Total Annual Net Total Boat Difference Temporary Registrations By Year Boat Annual Registrations Only 10,201 3,905 9,672 -529 5,357 9,824 +152 5,093 9,969 +145 5,248 10,418 +449 5,838 11,061 +643 5,944 11,218 +157 5,733 11,437 +219 5,904

Total Boat Registrations

Net Difference By Year Annual & Temp +93 -112 +300 +1,039 +749 -54 +390

1994 1995 1996 1997 1998 1999 2000 2001

14,106 15,029 14,917 15,217 16,256 17,005 16,951 17,341

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Year

Total Annual Boat Registrations

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Source:LGPC/LAGroup

11,607 11,139 10,832 10,713 10,690 10,730 10,576 10,496 10,614 10,387

Net Difference By Year Annual Only +170 -468 -307 -119 -23 +40 -154 -80 +118 -227

Total Temporary Boat Registrations 6,145 5,944 6,027 5,372 5,494 5,728 5,302 5,600 5,786 5,559

Total Boat Registrations

17,752 17,083 16,859 16,085 16,184 16,458 15,878 16,096 16,400 15,946

Net Difference By Year Annual & Temp +411 -669 -224 -774 +99 +373 -580 +218 +304 -454

Potential Funding Through Boat Registration and Inspection Fees The most feasible funding option for the mandatory boat inspection program derives revenues generated from a combination of increased annual boat registration fees and new annual boat inspection/decontamination fees. The preferred fee structure includes all boats on Lake George but puts the greatest burden on trailered boats from outside the region which represent the most direct contributors of AIS to Lake George. In order to estimate the amount of fees that could be generated by an increase in the existing boat fees, a set of assumptions was formulated. The numbers utilized to develop the estimates are derived from Commission revenue data from 2011 annual and temporary boat registrations. Table 5-10, Summary of Annual Revenues Projected from Preferred Funding Option, illustrates how total fees in the amount of $730,000 would be generated. Potential Boat Registration Fees Under this funding option all boat registration fees would increase. Boats that are in the category of Not Equipped for Overnight will on average pay a total fee of $84 per year. This represents an increase of $50. Boats that are in the category of Equipped for Overnight will on average pay a total fee of $177 per year. This represents an increase of $100. Temporary Boat Registrations would also be increased from an average of $10 to $20 per visit. Total annual revenues estimated to be generated from increased boat fees are estimated at $626,000. Potential Inspection Fees This funding option also analyzes the potential revenue that could be generated by creating new boat inspection/decontamination fees. Assumptions for this option are that boats that are singularly based on Lake George will not be subjected to an inspection nor will they pay any inspection fee(s). Boats that are trailered into Lake George will be subject to a C-D-D inspection prior to launching into Lake George unless they have an unbroken inspection tag indicating the boat has not launched at another location. In addition to all applicable boat registration fees, boats that are trailered to the lake that do

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not have a tag will pay an annual inspection fee of $40. This fee will enable these boats to be inspected throughout the year and washed multiple times, if necessary. Table 5-9 summarizes revenues anticipated from inspection/decontamination fees. For the purposes of determining an estimate of future inspection fees, an estimated 2,600 were Lake George Trailered Boats. These figures balance the following factors: the number of boats that are trailered in and pay an annual boat registration fee that are not tracked as a separate group by the Commission and, LGA Lake Steward Program launch data is a good indication of the number of boat launches occurring at the highest use sites. An additional factor of 60 percent assumes the boat launches that are not captured after hours, pre-season and post-season launches, launches carried out at other facilities, and return launches with intact tags that do not require inspection. Total inspection/decontamination fees are estimated at: $104,000. Based on the above assumption, the proposed fee structure will generate the revenue stream required to support the Mandatory Boat Inspection Program. Table 5-10. Summary of Annual Revenues Projected from Preferred Funding Option Proposed Boat Registration Fees Estimated New Fees Generated

Lake George Boat Registrations $550,000 100% fee increase (equates to average of $35/year increase for boats under 25 feet in length, greater for larger boats) Inspections Annual Inspection/Boat Wash Fee 2,600*** pay $40 Total $100,000

$650,000

*Decrease of 700 annual registered boats from current level of 10,387 to LG because of fee increase. ** Slight increase in temporary registrations due to decrease in annual registrations. ***Does not include boats expected to remain in-basin annually, and which do not require inspection. Inspection fee is annual & includes boat washing services; Trailered boats also typically pay Temporary Boat Registrations.

Potential Funding Through Sales Tax Revenues Warren County presently imposes a seven percent tax on all sales. The combined sales and use tax rate equals the state rate of four percent plus the Warren County rate of three percent. Warren Countys sales tax rate is one of only five counties in New York State with rates at seven percent - the lowest in the state. The highest is New York City at 8.875 percent. Six counties have sales tax rates between seven and eight percent and the remaining 50 counties have rates between 8.0 - 8.75 percent. In 2010 Warren County reported annual sales tax revenues of approximately $42.8 million generated from approximately $611.43 million in taxable sales within the County and similarly in 2011 taxable sales of approximately $662.85 generated annual sales tax revenue totaling $46.4 million dollars. The revenue from sales taxes is then shared with the towns within the County through revenue-sharing agreements resulting in distribution of approximately forty six percent

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(46%) of the revenue or $19.7 million in 2010 and $21 million dollars in 2011 among the towns in the County. The remainder of the sales tax revenue (54 percent) is retained by Warren County. Therefore, this range of is representative of upper and lower amounts of revenue that are derived from sales tax. Furthermore, a relatively minor increase in the sales tax rate would keep the rate well within sales tax rates of other counties across the state yet yield a significant financial resource to maintain a principal attribute (Lake George water quality) that fuels taxable sales within the County. Using the range cited above, an increase in sales tax of 0.25 percent for Warren County would generate between $1.53 and $1.65 million dollars of additional sales tax revenue. Under this scenario the County Board of Supervisors can then determine what portion of the additional revenue is assigned to funding implementation of AIS preventative measures. Tourism is a primary business sector of the economy in Warren County and, considering the close association between the lake as a prime attraction and the tourists that visit the area, funding AIS prevention efforts seems to be a logical justification for use of additional sales

tax revenue.
Potential Funding Through the Warren County Occupancy Tax The Warren County Occupancy Tax was created to develop a dedicated fund for regional and local tourism-related spending. Warren County has indicated that these funds are intended to be used to generate tourism spending. Occupancy Tax funds were allocated by the Warren County Board of Supervisors on a one-time only basis to assist with the cost of managing the Asian clam populations in Lake George. It is widely believed that these funds will not be available on a year-to-year or permanent basis. Therefore, it is necessary to consider alternative sources for funding AIS prevention efforts. Potential Funding Through the Mortgage Recording Tax New York State imposes a tax on the recording of a mortgage on real property located within the state. Warren County also imposes a local tax on mortgages that are recorded. This mortgage recording tax rate in Warren County is $1.25 for each $100 of mortgage loans secured. The total revenue from the mortgage recording tax collected by Warren County in 2011 was $1.7million dollars. These funds were distributed to the municipalities in Warren County and are also utilized as revenue to fund county operations and the support of SUNY Adirondack. It is highly unlikely that these funds would be available for purposes other than currently assigned. Potential Funding through the Gasoline Tax In New York State, certain fuel purchasers are able to collect a refund of NYS sales tax paid on fuel purchases. Fuel consumers buying and using fuel to power off-road diesel equipment, agricultural equipment, commercial boats, and snowmobiles, are able to file for a refund of the sales tax on fuel. These funds are generally designated for uses that support highway improvements. A snowmobile operator must file a form with sales receipt with a snowmobile club which then submits the forms and sales receipts to the NYS Department of Taxation. If the club is recognized as an organization that is maintaining trails, it will receive the refund to support that trail maintenance work. Annually, the NYS Department of Taxation is refunding $24,000,000 to these fuel users. To utilize this funding stream for the prevention of AIS would require a change in the tax code to add marina gas purchases or boating clubs or lake management organizations to the list of authorized groups that can obtain the refunds. This would have to be a statewide revenue source which would give all New York lakes with AIS issues access to this fund. Potential Funding Through a Lake George Park Special District

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Another option for generating revenue to fund AIS prevention is the formation of a special district or an improvement district for the purpose of carrying on, performing or financing one or more improvement services intended to benefit the health, welfare, safety or convenience of the inhabitants within such a district. In basic terms a special district has the following features: It is comprised of a defined geographic area and may be within more than one municipality; The district exists to serve as a funding vehicle and operational means by which certain public services are provided to the benefit of district inhabitants; Real property within the district is subject to a special levy or assessment to finance the special improvement which in their circumstance is prevention of AIS in Lake George.

There are several geographic areas that could be considered in the formation of a special district for Lake George. One way would be to base the district boundary on waterfront parcels only. A second option is to extend the boundary of the district to the entire Lake George Park boundary. Both these options are discussed below. Due to the fact that authorization for taxing authority is not part of the Environmental Conservation Law, the formation of a special district may require an entirely new authorization of the Commission. Since the Commission has no current authority to do this, the authority would have to be granted through an act of the State Legislature. Another means of achieving a special district would be establishing it on the county level which would mean Warren, Essex and Washington counties would individually form an improvement district in each of their counties using the Commission boundary. Formation of a special district for Lake George under the scenarios described above would involve three counties (Warren, Washington and Essex), nine municipalities (Lake George, Lake George Village, Queensbury, Bolton, Hague, Fort Ann, Dresden, Putnam, and Ticonderoga) and the Lake George Park Commission. Using existing authority granted to counties, it may be feasible to develop a tax district using the LGPC boundary through a memorandum of understanding. Lake George Park Commission Special District: Waterfront Parcels Only The NYS Legislature formed the Saratoga Lake Protection and Improvement District (SLPID) in 1986. This process could become the model for a Special District for Lake George. However, the LGPC is already a defined district, therefore, much of the district boundary is already established. To support the spread prevention programs, invasive controls, and other activities, a special district that covers the lakefront properties would be the most similar to the Saratoga Lake Protection and Improvement District. Under this scenario, a portion of the Lake George Park boundary (see Figure 1-2) that is made up of lakefront properties or all properties within the Lake George Park would be designated as the special district. Property owners in the proposed district would vote on the formation of the district and a majority of inhabitants would have to approve creation. The legislation by the State would set out the authorities or modify the authority of the existing LGPC to include power to tax. The district authorization may include a tax cap as does the Saratoga Lake Protection and Improvement District legislation. The existing or modified LGPC commissioners would be authorized to prepare an annual budget and make that budget available for public comment. The LGPC commissioner would have sole authority over the annual expenditures and may or may

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not have authority to bond. Changes to the district rules would need consent of the NYS legislature and governor. A special district will take several years to establish, however, it is a consistent source of long-term funding. A special district is capable of generating revenue to support LGPC programs and would allow for aggressive long-term plans to control AIS. The annual revenues are predictable, therefore, multi-year plans to control AIS can be prepared. Additionally, a district would likely eliminate the existing dock fees since real property taxes and a dock fee are two means of assessing fees for nearly the same resource. Elimination of dock fees would diminish the net effect to property owners along the shoreline, however, consideration must be given to the impact to the Commissions budget from elimination dock registration fees revenues. The information below illustrates the amount of revenue that a tax district could generate under a scenario of imposing a tax levy on waterfront parcels only. A special district is not an immediate funding mechanism, but further feasibility review should be conducted to determine a specific rate. Special district funding would support invasive species control, land use planning efforts, portions of boat patrol and general operations of the district. The full value of Lake George waterfront parcels within the special district as described is $2.4 billion based on 2011 real property tax roll from Warren, Washington, and Essex County. The equalization rates vary by county and towns around the lake. If a special district was formed, the applicable method to determine applicable equalization for the entire lake, town, or county in that district would need to be established in district legislation. For the purposes of this evaluation, an average equalization rate of 71% for Bolton, Lake George, and Queensbury was utilized based on the 2011 approved rates. Tax rates are based on $1,000 increments of assessed value. To estimate the potential revenue stream from a special district, it is necessary to convert the estimated value of lakefront parcel by multiplying the full value by the averaged equalization rate. Tax amounts under the scenarios of 0.10 and 0.25 per thousand dollars of assessed value. Alternative Rates Assumptions: A potential tax rate of 0.10/1000 of assessed value would potentially generate a total of $170,400. The average residence on Lake George with an average assessed value of $660,000 would pay an estimated $66 per year. A potential tax rate of 0.25/1000 of assessed value would potentially generate a total of $ 426,000. The average residence on Lake George with an assessed value of $275,000 would pay an estimated $165 per year.

Lake George Park Commission Special District: Entire Lake George Park Taxing all property owners in the district would be a fair approach since the highest taxes will continue to be paid by those owners with the most valuable properties. A million dollar property, whether on the lake or off the lake would be taxed the same. The full value of all parcels from within the Lake George Park is $3.9 billion based on 2011 real property tax roll from Warren, Washington, and Essex County. The equalization rates vary by county and towns around the lake. If a special district was formed, the applicable method to determine applicable equalization for the entire lake, town, or county in that district would need to be established in district legislation. For the purposes of this evaluation, an average equalization rate of 71% for Bolton, Lake

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George, and Queensbury was utilized based on the 2011 approved rates. Tax rates are based on $1,000 increments of assessed value. To estimate the potential revenue stream from a special district, it is necessary to convert the estimated value of lakefront parcel by multiplying the full value by the averaged equalization rate. Tax amounts under the scenarios of 0.10, 0.25 and 0.50 per thousand dollars of assessed value. Alternative Rates Assumptions: A potential tax rate of 0.10/1000 of assessed value would potentially generate a total of $277,000. The average residence within the Lake George Park with an assessed value of $275,000 would pay an estimated $28 per year. A potential tax rate of 0.25/1000 of assessed value would potentially generate a total of $ 692,250. A residence with an assessed value of $275,000 would pay an estimated $69 per year.

Funding through NYS General Fund The General Fund is derived from allocations from income tax revenues received by NYS along with all other resources received including income, sales, and fees. Prior to 1985 the Commission was supported by funds subject to widely varying annual allocations within the state budget. Utilization of these funds is justified due to the fact that Lake George is a valuable resource and generates multiple benefits to all New York State residents. Given current economic climate, however, this source of funding will not be available. Dedicated Funding from the Environmental Protection Fund In 2001, the Department of State created the Lake George Watershed Coalition to prepare a long-term plan to protect lake water quality. The completed Lake George Planning for the Future document addresses lake sedimentation, invasive species, and stormwater runoff. Since then, extensive work has been completed to implement the plan including installation of stormwater management practices, invasive species removal, water quality monitoring, and outreach and education programs. The Lake George Watershed Coalition assures lake issues are addressed in a coordinated manner. Its activities are largely financed through grants from the Environmental Protection Fund Local Waterfront Revitalization Program (EPF LWRP), funds appropriated by each watershed municipality, and the in-kind and donated services of its members. More than twenty-six grants from the EPF LWRP totaling over $2.6 million have been awarded for a variety of planning and construction projects to revitalize waterfronts, increase waterfront access, and strengthen the regions tourism economy. Dedicated annual funding for a portion of the mandatory boat inspection program could potentially be sought through the EPF LWRP. Funding from Federal and State Grants Federal and state grants are available to a limited degree. Grants applications through the NYSDOS Local Waterfront Revitalization Program (LWRP) submitted by the Lake George Watershed Coalition through the Consolidated Funding Application represent the best opportunity for funding. A funding application requesting $850,000 for invasive species management at Lake George was filed in the summer of 2012. To date, no action has been taken on this application. However, state grant programs such as the LWRP are highly competitive programs and are subject to varying appropriations in the state budget. As such, reliance on grant funds for year-to-year AIS prevention efforts is not predictable. Therefore a

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comprehensive long-term budget should be established and a funding plan established to address the AIS management needs on Lake George. Federal grants have never been widely available for Lake George. Environmental education grants through the EPA are possible in small amounts. This is not a long-term or consistent source of funding. However, these funds are appropriate for upfront costs related to implementation of the Mandatory Boat Inspection Program. Funding from Municipal Contributions and Donations Contributions towards the control and eradication of AIS have been made by Warren County and many of the Lake George municipalities. These funds are limited and are subject to wide variation due to the fact that all municipalities are struggling in the current economic climate. This is not a long-term or consistent source of funding. 5.2 Required Administrative Actions

An authorization by the executive branch of NYS government is required In order to establish the mandatory inspection of watercraft, trailers and tow vehicles. Authorization from the state legislature is required for any increase in registration fees or the establishment of new fees. These actions would then be followed by amending LGPC rules by adding the requirement for mandatory inspections to Section 646, Substantive Regulations. The establishment of a mandatory boat inspection and washing program is an expansion of activities that are currently regulated by the Commission. These regulations prohibit any person from launching a vessel into the park without inspecting the vessel and its trailer for marine growth and removing and disposing of such growth before the vessel is discharged into the waters of the park (6 NYCRR 646-1.6 (h)). This effort is intended to create a program which identifies best means to achieve the provisions of this section, including best methods, logistics, costs, and funding. The LGPC and any authorized designees will be authorized under NYS law and LGPC regulations to inspect bilge, sub-deck compartments, bait containers, live wells, watercraft exteriors, trailers and tow vehicles for plant species and biological materials. The regulation will allow for the issuance of tickets and fines if a watercraft, trailer or tow vehicle is found to violate the rules and regulations pursuant to this regulatory initiative. See Appendix D, Draft LGPC Regulation to Require Watercraft Inspections for AIS.

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SECTION 6

POTENTIAL IMPACTS OF THE PREFERRED ALTERNATIVE: REGULATORY MANDATORY BOAT INSPECTIONS

In this section, the potential environmental, economic, and social impacts of the proposed action will be described and evaluated. If needed, specific mitigative measures are provided to reduce impacts of the proposed action. Impact topics focus on the environmental and social factors that would potentially be impacted by the proposed action. The proposed action (preferred alternative) as described in Section 5.0 is the mandatory inspection of boats entering Lake George. If the boat and/or trailer do not meet the standard of C-D-D, then they must be decontaminated by hot water high pressure washing prior to launching into Lake George before receiving an inspection tag. To prevent unauthorized boats from entering the lake, unattended launches will have to be secured. 6.1 Native Aquatic Plant Species

Impacts The mandatory inspection of watercraft will significantly increase the number of aquatic invasive plants intercepted before boats launch into Lake George. This will decrease the need to implement AIS control/management measures that have the potential to negatively impact native species (non-target species). This impact could occur accidently in the pursuit of mechanical, physical, or chemical control of invasive species. Avoiding non-target species damage and reducing the control efforts against AIS is an important benefit of the project. Mitigative Measures No mitigation is required since the anticipated impacts are either beneficial or not significant. 6.2 Water Quality

Impacts Inspecting watercraft prior to launch will have net positive impact on the water quality of Lake George by preventing AIS from being introduced to the lake and causing new ecological impacts or by complicating existing ecological issues including excessive algae growth. Activities at the boat launches will remain the same. The boat wash stations are closed systems that recycle all water utilized in the boat wash process therefore there are no impacts to water quality from these sources. Although not anticipated, the development of wash stations in some locations may involve minor earth grading, paving, and other site development activities. Mitigative Measures A. Site development will use standard practices to manage stormwater and comply with applicable rules. B. Using HPHW minimizes use of chemical disinfectants, which could enter the environment. C. No additional mitigative measures are necessary since impacts are not anticipated to be significant. 6.3 Ecology

Impacts The target of the watercraft inspections are AIS, however, as a part of the outreach process, terrestrial invasive species will be a normal topic covered in discussion with boaters. Inspectors may also be authorized to intercept illegally transported firewood and bait.

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Mitigative Measures No mitigative measures are required since impacts of the project are beneficial or not significant. 6.4 Fisheries

Impacts Interception of AIS will prevent or reduce the introduction of invasive plants and animals to Lake George. These actions will minimize further changes in the lake that could impact fisheries. The inspection process may intercept illegal bait fish, which will prevent the introduction of invasives and the transmission of disease. Mitigative Measures No additional mitigative measures are necessary since impacts are either beneficial or not significant. 6.5 Wetlands

Impacts Development of the regional inspection stations will not involve wetland disturbances other than use of the existing boat launches. Securing and limiting use of the private launches will allow those areas of deep water wetlands to naturally regenerate into a more natural condition. Limiting import of AIS is focused on submerged plant life, however, emergent invasive plants such as purple loosestrife, may also be intercepted thereby creating additional benefits. Mitigative Measures No additional mitigative measures are required since impacts are either beneficial or not significant. 6.6 Public Health and Potable Water Supplies

Impacts To minimize use of potable water, conservation practices will be followed at all the boat wash stations. Preventing the introduction of additional zebra mussels or other AIS will protect the water supply infrastructure from damage by the physical clogging of individual water pipes or changes in water quality. Mitigative Measures No additional mitigative measures are required since impacts are either beneficial or not significant. 6.7 Recreation

Impacts The transient boating public will need to have their boats inspected prior to entering the lake. This will involve both time and fees which will be an inconvenience to the recreationalist. This may cause some temporary shifting in lake use patterns (Wright, 2009). Fees are based on the reasonably anticipated needs of the program and will also aid in funding efforts to limit further spread of the AIS already found in the lake. Inspection sites are located along major travel corridors and in high use areas to minimize travel time and distance in reaching the sites.

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An increase in costs associated with being on Lake George may cause some boaters to avoid Lake George. However, a review of recreational boater behavior at four waterbodies in Colorado since mandatory inspections were implemented, determined that there was not a significant change in the number of days, length of stay, or boat registrations. Also, the Tahoe Regional Planning Agency (TRPA) reported they have seen a 1% increase in the number of boaters coming to the lake each year of the program. At Lake George, the general observation when fees were first initiated on Lake George, a limited number of boaters temporarily did not renew their registrations. Within 2 years, the Commission reports the number of boat registrations fully recovered. Over the last 10 years the number of boat registrations has somewhat declined. Table 5-8, History of LGPC Annual Boat Registrations, illustrates the change in both annual and temporary boat registrations since 1994. Registrations in 2011 are approximately the same as in 1998. An explanation for the decline in the number of LGPC boat registrations is that it reflects the overall decline in New York State Boat Registrations for the same time period (See Table 6-1). However, the LGPC decline was less precipitous than statewide. NYS boat registrations dropped by 8.3% over the last 6 years while LGPC registrations dropped 3% during the same time frame. Table 6-1. Comparison of NYS and LGPC Boat Registrations Year NYS Boat Registrations LGPC Registrations 2005 510,185 10,713 2008 488,167 (-22,018) 10,576 (-137) 2010 467,828 (-20,339) 10,387 (-189) 2005-2010 -42,357 or 8.3% drop -326 or 3% drop Source: LGPC & NYSOPRHP The data demonstrate that boat ownership has been in a decline for years primarily due to the aging populace and general economic conditions that do not support recreational boating as a sport. The 2003 increase in registration fees at Lake George therefore is not seen as a key factor in the decline of Lake George boat registrations. Lake George provides a unique boating experience and will continue to be an affordable choice for boaters despite the inspection fees. The recreational impact from this alternative (reduced boater use of Lake George) could be tied to the ultimate level of increase in boating registration/inspection costs, if this program were imposed solely based upon an increase in LGPC boat registration fees and inspection fees. There are a number of funding scenarios which would lessen the ultimate financial impact to boaters, primarily if outside funding were secured to assist in the cost of the program (NYS General Fund, portion of county sales tax revenue, new taxing district, etc. (see Section 5.1.9)). It is conceivable that if a 100% fee increase were adopted, which would average $35-$40 additional annual cost for the vast majority of boaters on Lake George, that recreational boaters may seek other waters to recreate on which have lesser or no fees. Mitigative Measures The Commission should seek to implement as broad-based funding for the preferred program as possible, to minimize the required fee increase and inspection fees required for program implementation. Transient trailered boater traffic will change under the preferred alternative. Boaters who now go directly to their desired launch point will now be required to visit a regional inspection station prior to launch. If their boat/trailer does not pass inspection, that boater will be required to

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undergo a 20-30 minute decontamination process at the inspection station. These boaters are likely to experience delays from their traditional recreational processes, which may cause irritation among the boating public, particularly those who are required to undergo a decontamination process. To best mitigate inconvenience to boaters regarding these impacts, the regional inspection and decontamination stations should be placed close to primary launch points on Lake George. The current program identifies that the three most highly launched sites on the lake (Norowal Marina in Bolton, Mossy Point in Ticonderoga, and Rogers Rock in Hague) are all anticipated to host these stations, if granted permission. The traffic from these launches constitutes an estimated 60-70% of the launches on Lake George, and having inspection stations at or near these sites will reduce or eliminate out-of-way travel time to an inspection site. The reasoning for the five regional inspection stations is to provide a good balance between keeping costs down as much as possible while offering a level of convenience to boaters that they wont have to travel any excessive distance to get to a station. The other potential impact is long inspection lines at inspection stations due to high volume weekends, holidays, and other similar times. Towards this end, data has been gathered through the LGA Boat Launch Steward program on boater launch times and every launch at the five or six (depending upon year) sites were recorded for time of launch. As a result, there is very good data which outlines when high volume launch times are experienced at the various launch points on Lake George. The scheduling of staff will take into consideration these launch traffic variations in launches around the lake, and the program should be funded and staffed in a way as to minimize waiting times as much as possible. 6.8 Land Use

Impacts The selected sites for the inspection station are in developed areas, are already developed, or committed to commercial uses. This will minimize impacts to adjacent land uses. Mitigative Measures A. Selected locations for inspection stations will comply with local zoning or be located at sites with sufficient separation for adjacent land uses to minimize disturbance. Sites with adequate setbacks and easy access along well served by state or county highways and can accommodate traffic movements of vehicles and trailers will be the preferred locations. B. Stormwater will be managed in accordance with recommended best management practices for marinas and in accordance with local, state, and federal rules. Water conservation practices will be followed. 6.9 Economics

Impacts Inspecting boats for AIS will create approximately 15-17 seasonal positions for 20-25 weeks with hourly wages of $12.00-$15.00. At local participating marinas, additional employees may also be required, which could be a new position or extend seasonal work for some individuals. Data collected from other lakes with inspection programs show that changes in the numbers of boaters using a lake following implementation of an inspection program does not decrease

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significantly (see Recreation, Section 6.7). Following the implementation of the mandatory boat inspection program, changes of boater use on Lake George is anticipated to remain within the annual year to year variability. Mitigative Measures A. Analysis to date shows that by preventing additional AIS contamination of the lake, will avoid potentially large significant impacts to the local economy. B. No additional mitigative measures are required since impacts are either beneficial or not significant. 6.10 Aesthetics

Impacts The proposed boat washing facilities will be laid out in an organized fashion with simple, easily maintained temporary structures or facilities. Most inspection stations will be near or within other developed areas. Mitigative Measures No additional mitigative measures are required since impacts are either beneficial or not significant.

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SECTION 7

PARTICIPATING AGENCIES, ADMINISTRATIVE RECORD, AND REGULATORY IMPACT STATEMENT

7.1

Participating Agencies 7.1.1 Federal Executive Order

In 1999 the federal government by Executive Order 13112 established the Invasive Species Council and required the development of Invasive Species Management Plans by federal, state and regional authorities for the control of invasive species due to the economic threat posed by both aquatic and terrestrial invasive species. Cornell University has estimated the cost associated with the management of invasive species to be in the range of $120 billion in the United States. The 1999, Executive Order 13112 set out six specific actions to be carried out by the federal agencies: (i) Prevent the introduction of invasive species; (ii) Detect and respond rapidly to and control populations of such species in a costeffective and environmentally sound manner; (iii) Monitor invasive species populations accurately and reliably; (iv) Provide for restoration of native species and habitat conditions in ecosystems that have been invaded; (iv) Conduct research on invasive species and develop technologies to prevent introduction and provide for environmentally sound control of invasive species; and (v) Promote public education on invasive species and the means to address them. 7.1.2 Lake George Park Commission Role and Responsibilities for AIS Control

The LGPC is authorized under Environmental Conservation Law (ECL)-ECL-43-0101, to protect, preserve, conserve, and enhance waters of Lake George. Based on this general purpose and its ability to contract for services, the LGPC has been able to work on invasive species control efforts provided that necessary permits are obtained to implement the selected control measures. This general authority is further elaborated upon by ECL-43-0107(8), which states such rules and regulations consistent with this article as it deems necessary to administer this article and to do any and all things necessary or convenient to carry out the purpose and policies of this article to exercise all powers granted by law. These sections clearly allow the LGPC to implement invasive controls and provide a fundamental authority to control invasive species. Another part of the ECL instructs the LGPC to carry out its authorized function to promulgate regulations. The ability to create rules to enforce mandatory inspections of boats would fall under this provision. As a part of the approval process, it is also necessary to assess the potential environmental and regulatory impacts of an action on rural land using the State Environmental Quality Review Act (SEQRA). This GEIS explores topics specifically related to AIS prevention on Lake George plus those normally considered in the SEQRA process. Once the GEIS is completed, a draft regulation will be prepared based on the selected preferred alternative from the GEIS. Procedures to implement a rule are outlined in the following five-step process:

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(1) (2)

(3) (4) (5)

The Commission must prepare a notice of proposed rule-making, which must contain certain information and statements as required by SAPA202, et. seq. The Commission must submit the proposed rule and accompanying statements to the Regulatory Reform Unit (RRU) of the Office of Budget for preapproval prior to publishing the rule in the State Register. Once the rule has been approved by the RRU, the Commission must publish the proposed rule in the State Register. The Commission must hold public hearings on the proposed rule and receive public comment on the rule. The Commission must adopt the rule, file it with the Secretary of State and publish the Notice of Adoption in the State Register.

The proposed draft regulation is presented in Appendix D, Draft LGPC Regulation to Require Watercraft Inspection for AIS. It has been a long-term struggle to improve AIS controls in New York State. Recently, certain crises situations have resulted in significant advancements of AIS control procedures and their implementation, to the point that rapid response is efficiently being accomplished. The NYSDEC has broad oversight of the natural environment; therefore, management of AIS may involve some distinctly different sets of laws and rules as it relates to DEC mandates. The Environmental Conservation Law (ECL Section 9-1705) requires that an invasive species council made up of state agencies be formed and that the council prepare progress reports to the governor and legislature. DEC established the Invasive Species Council in 2008 by Title 17, Section 9 of the Environmental Conservation Law (ECL). The Council was created to address the environmental and economic threats of invasive species through a group comprised of multiple state entities and partners. The New York Invasive Species Council (NYISC) is made up of NYSDEC, Agriculture and Markets, Department of Transportation (DOT), Office of Parks Recreation and Historic Preservation (OPRHP), Department of State (DOS), Thruway Authority (Thruway), Canal Corporation (Canals), and Adirondack Park Agency (APA) representatives. The NYISC issued two reports; one in 2005 and one in 2010 on invasive species in NYS and a concept plan to manage invasive species (NYSISC, 2005 & 2010). The NYSDEC has numerous rules that are involved with the control of AIS including: Article 24Freshwater Wetlands; Article 33, Title 7-Registration of Pesticides; Article 33, Title 9-Pesticides and Certification; Article 17, Title 8-State Pollution Discharge System (SPDES) General Permit; Article 11-Fish and Wildlife, and Article 15, Title 5-Protection of Waters. The NYSDEC participates in and leads certain efforts to control invasive species on a statewide basis as it relates to the above rules. These rules set out various means to protect wetlands, prevent unauthorized discharges, regulate the use of pesticides, assure general water quality protection and control destructive wildlife. Over the last three years the NYSDEC has taken a leadership role in the emergency response to the management of AIS. As an example, using existing statutory power, the NYSDEC has quarantined ponds and controlled the snakehead population under existing authority to control destructive wildlife. The ECL provides clear authority to address issues with destructive wildlife, and up until 2012, the authority to control invasive plant species was deficient. NYSDEC is the landowner or manager of the state boat launches and campgrounds around Lake George and is the steward of the Forest Preserve Land. Therefore, their active participation in this process is critical to advancing the control of AIS in Lake George.

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An example of DECs cooperative arrangements with localities regarding AIS management occurred in 2011 and 2012 when, working with local governments in Cayuga County and the City of Ithaca, DEC implemented emergency control measures to address a large hydrilla infestation on an inlet channel to Cayuga Lake. An additional effort to address the AIS issue on a statewide level was the passage of a bill that amended ECL Section 9-1709, and assigned specific duties to NYSDEC in cooperation with other state agencies including the ability to restrict the sale, purchase, possession, population introduction, importation, transport, and disposal of invasive species (Senate and Assembly Bill S6826A as revised 6/19/12 and sent to the Governors office 7/29/12). The law becomes effective in January 2013. The NYSDEC and NYSDAM must prepare and adopt regulations by September 1, 2013. 7.1.2 APA Role and Statutory Responsibilities Related to AIS Control

The Adirondack Park Agency (APA) was established by the New York State Legislature in 1973 and charged with jurisdiction over development in the Adirondack Park for both private and public lands. As such, two documents were adopted; the Adirondack Park Land Use and Development Plan that regulates private property, and the Adirondack Park State Land Master Plan that guides the use and development of state owned property. The State Land Master Plan is administered by the NYS Department of Environmental Conservation (DEC) via Unit Management Plans that are jointly prepared by the DEC and APA. Additionally, the APA is authorized to administer Article 24, Freshwater Wetlands, which includes special rules and regulations pertaining to land use, shoreline development and Wild, Scenic, and Recreational Rivers. The wetland rules, Part 578, Special Provisions Relating to Freshwater Wetlands include regulations for the use of herbicides in wetland designated areas. Herbicide use in wetlands may be intended to control target nuisance aquatic plants but often times may cause harm to beneficial wetland plant species. These are typically referred to as non-target species. Part 578 also includes provisions for regulating deep water wetlands, such as those that occur underwater in lakes, ponds, and rivers. As such, in order to use herbicides to control aquatic invasive plant species, it is necessary to obtain permits from the APA. Similarly, the APA regulates the use of chemicals to control aquatic invasive wildlife. The APA also maintains regulatory control over the use of mechanical aquatic plant and wildlife control techniques such as suction dredging, benthic matting, and hand harvesting. All of the above techniques have the potential to impact non-target species as well as invasives. Part 575, Shoreline Restrictions of the Adirondack Park Agency Act, includes regulations that restrict construction activities and the placement of structures in shoreline areas. Shoreline area restrictions vary in distance from the mean high water line from 50 to 150 feet depending on the specific Land Use Area as defined by the Adirondack Park Land Use and Development Plan. The APA also administers the Special Provisions Relating to Wild, Scenic, and Recreational Rivers, Part 577. These rules apply to land use and development within such river corridors as defined in Part 577. Lake George is not designated as a Wild, Scenic, or Recreational River. In implementing the above regulatory controls, the overriding consideration of the APA is to evaluate the potential impacts of an action as it relates to protecting the resources of the Park. As such, the APA is required to make statutory findings that an action will not have undue adverse impacts on such resources. Meeting such statutory findings is often difficult in that

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undue adverse impacts are variable and even actions with a low threshold of impact can be construed as adverse. 7.1.3 NYS Agriculture and Markets Role and Statutory Responsibilities Related to AIS Control

Along with the NYSDEC and APA, the New York State Department of Agriculture and Markets (NYS AM) is another agency designated to lead the efforts of the New York State Invasive Species Task Force (NYS ISTF). NYS AM leads such efforts primarily as they relate to the control of many terrestrial (land based) invasive species involving agriculture, including both plants and animals. NYS AM also implements some programs that originate at the federal level through the United States Department of Agriculture (USDA). They include a variety of programs that relate to food quality and food safety. One such program is the USDA Animal Plant Health Inspection Service/Plant Protection and Quarantine (USDA APHIS/PPQ). This program in New York State is referred to as the Cooperative Agricultural Pest Survey (CAPS). The CAPS Program and APHIS are focused on the terrestrial environment and include agriculture, forestry, range management, and the protection of food products. Both CAPS and APHIS implement and maintain monitoring and invasive species control programs for forestry and agricultural products. The visible purple traps (bags) that are hung up in trees are targeted to survey the presence and migration of the Emerald Ash Borer. These are set out and maintained by APHIS (NYSDEC Emerald Ash Borer FAQ, www.dec.ny.gov/animals/45409.html) (NYS AM-Forest Health Invaders www.agriculture.ny.gov/CAPS/forest health.html).

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7.2

Administrative Record

The LGPC Subcommittee on Invasive Species was established by the Commission Board in 2010. The 1st meeting was held on November 5, 2010 at the Bolton Town Hall and 21 meetings of AIS committee have been held. The AIS committee has met at Bolton Landing, Hague, Ticonderoga, and Lake George Village. AIS committee meeting were all open to the public. Meeting dates were: December 3, 2010; December 17, 2010 January 6, 2012; January 20, 2012 February 3, 2012; February 17, 2012 March 2, 2012; March 16, 2012; March 30, 2012 April 13, 2012; April 27, 2012 May 11, 2012; May 25, 2012 June 26, 2012 July 20, 2012 August 3, 2012; August 17, 2012 September 21, 2012 October 5, 2012; October 19, 2012 November 2, 2012 The Request for Professional Services was sent out to firms on November 9, 2011. The contract was signed by the LA Group on July 25, 2012 and by the Commission on July 30, 2012. Work commenced on the project immediately. Three public meetings were held: August 9th, August 29th , and September 27th. The Commission proposed to be SEQR Lead Agency in a Lead Agency Coordination Review letter on September 8, 2012. No challenges to the Lead Agency status were received in the 30 days following the letter. The following municipalities and agencies responded with letters of SEQRA concurrence: Office of General Services; Town of Hague; Town of Bolton; County of Essex; Village of Lake George; Town of Lake George; Town of Putnam. The Commission has received no response from the following municipalities and agencies: Town of Ticonderoga; Town of Fort Ann; NYS OPRHP; Town of Queensbury; County of Washington; NYS APA; NYS Div. of Budget; Town of Dresden; Town of Warrensburg; County of Warren; NYS DOH; and NYS Secretary of State. It is anticipated the Commission will declare the DGEIS complete at its regular meeting. Date of Public Hearing: ____________. Date of Close of Comment: ___________. 7.3 Regulatory Impact Statement

The GEIS contains the necessary information for a regulatory impact statement (RIS) as described in Section 202-a, Regulatory Impact State Administrative Procedures Act. The following section contains the necessary information (letters are the relevant requirement found in Section 202a) for the RIS. (a) Statutory Authority GEIS Section 7, NYS Environmental Conservation Law, Article 43, Section 43-0101. (b) Needs and Benefits-Section 1.4 and Section 4.0

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(c) (d) (e) (f)

Cost Section 5.0 Proposed Project and 5.1.8 Cost Estimates Need for reporting requirements section, Section 5.1.4, 5.1.5, and 5.1.6. Comparison of rule with requirements of rule related to state or federal rules, Section 2.8 and Section 3.1.2 and 3.1.3. Alternatives-Section 3.

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SECTION 8 8.1

GROWTH INDUCING, SECONDARY, AND CUMULATIVE IMPACTS

Introduction

This section presents an evaluation of growth inducing, secondary and cumulative impacts as a result of this project. This analysis is based on the implementation of a mandatory watercraft inspection and remedial washing in order to insure that boats enter clean, Drained and dry. 8.2 Growth Inducing Impacts

Growth inducing impacts of the mandatory inspection program are the consequences of having to provide more services to the boating public which may require more land space or water space to be occupied. The program will need multiple locations for inspection and HPHW cleaning of watercraft, floating devices, and shoreline devices. To implement the program, sites to support the above activities will be for the most part incorporated into existing facilities. This assumes that adequate circulation space, parking, and inspection location will be available. Approximately 1,200sf is necessary to accommodate two tow vehicles and watercraft (12ft x 50ft). A large site to accommodate multiple boats and two inspections stations will need between 0.50.75 acres. The above are primary impacts that are associated with the project. Dedicating 1,200-2,400sf to new uses at existing marinas will displace activities and may create a demand for marina expansion. This demand for new space may cause expansion of existing marinas by acquisition of adjacent property, addition of more offsite storage locations for trailer storage of boats as a form of quick launch, addition of vertical racks for boat storage and possibly docks. Any marina expansion would be subject to local rules and those imposed by the LGPC. Growth of marinas or the boat service industry may require more land however, it also may include additional seasonal employment. Each private facility will respond to demand, for more services based on its physical layout, and existing types of services already in place. Given the constraint on lakefront land due to limited supply, expensive development at existing marinas will likely be replaced with most growth taking place at non-lakefront parcels. Further, given that dockage has always been highly prized, it is assumed that all available dockage space that could be built has been built. Improving dock layout or space allocation may take place however, this type of rearrangement will also be subject to review by the LGPC. Both local businesses and private land owners may also embark on further development of mini marinas which again will be reviewed by the LGPC. The existing process of local land use review will be sufficient to address the possible growth or changes in shorefront facilities. A successful program of invasive species spread will preserve the continued investment in the local and or regional tourism economy. If additional aggressive invasives take hold over a period of years, the negative impact to tourism is estimated as $10,000,000 $48,000,000 (see Section 4.1 for details). Limiting introduction of AIS and preserving water quality will allow the tourism economy to continue to evolve to meet the demands of the traveling public. It is recognized that there will always be changes and contraction and expansion of the tourism industry due to international, national, state, and local conditions along with desires of owners and operators of facilities. Containing and avoiding spread of AIS will allow tourism to gradually

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respond to an owners desires and to business trends that tend to be gradual rather than rapid and catastrophic as would be associated with the wide spread negative impact of AIS. No other growth inducing impacts are identified as a result of the implementation of the preferred alternative. 8.3 Secondary Impacts

A secondary impact occurs as the result of the implementation of a project or action but may not occur immediately. Increase inspection of watercraft will cause recreationalists to examine their expenditure of recreational time and some may not choose to come back to Lake George. In both 1986 at the reformation of the LGPC and again in 2002 when fees were increased, some boaters left the lake to seek less expensive options. The consistent observation has been that most boaters return the following season, and the trend to greater lake usage continues. The short-term decrease in boaters has not lead in the past to long-term changes in boating facilities on the lake. 8.4 Cumulative Impacts

The plan to consider mandatory watercraft inspection is being pursued to address the financial realities being faced by the Commission. Attempting to address an increasing number of AIS without stemming the introduction will result in facing constantly increasing costs. It is critical to examine all phases of AIS control because it is strongly linked to the regional economy. Advancing an approach of continued cooperation among the various partners and establishing a uniform level of data collection will facilitate better decision-making. On an annual basis, the Commission takes in roughly $900,000 and expends most of that revenue on its ongoing lake management program. During some years when excess funds are collected, the unspent boat and dock fees are placed into a Commission trust fund that is administered by the comptrollers office. New revenues are necessary to carry out the proposed new program. Also, a comprehensive examination of all expenditures related to the control of AIS is necessary including the need to consider target species, carefully evaluate existing protocols, establish future expenditures, and identify potential revenue streams. Existing AIS control programs need to have a standardized data collection protocols and reporting format. To understand the status of programs, it is necessary to have data on coverage and density. Coverage area and density number of plant or animals within an area are the factors that make AIS objectionable. Controlling the rate of new introductions of AIS is critical. Reducing the rate of introduction by having mandatory inspections will, in near term be expensive, but once new introductions are reduced to a rate of a new species in 4 or 5 years, savings will result. Prevention of introductions will save money in the long run and gaining control of existing invasives at lower cost will also save money. Current invasive control programs have been limited to expensive mechanical control methods and hand harvesting that is both labor intensive management techniques.

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Requiring boat inspection may cause some individuals to stay away from Lake George or choose to visit the lake less frequently. This would have impacts on tourism and regional economy. Data from other lakes with inspection programs indicate that changes in boat usage after mandatory boat inspections are implemented is minimal or is within the annual variability of year-to-year recreational pursuit changes (see Section 4.3.5). Implementation of an aggressive program to prevent introduction of AIS is an effort to avoid future cumulative and secondary impacts associated with continuous introduction of AIS. The program has been specifically designed to reduced inconvenience to the boating public by having inspection areas near or within high use areas operating for extensive hours for the entire boating season. A provision will be available for offseason inspection and to support fishing tournament or regattas, boat shows, or other on lake activities. The proposed plans, as well as the rule, will allow the Commission to select future technology solutions to aid in boat inspections. Also, it is feasible to install automate keypads or card entry gates to preserve access at year-round state launches.

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SECTION 9

ADVERSE ENVIRONMENTAL IMPACTS WHICH CANNOT BE AVOIDED IF THE PROPOSED PROJECT IS COMPLETED

Certain adverse impacts cannot be avoided with the application of mitigation measures. This extends to some impacts that are unavoidable due to changing desires of boaters and the avoidance of inspections by a limited number of boaters. There are no significant adverse environmental impacts anticipated from implementing the preferred alternative. The potential adverse impacts from this program are primarily recreational, and equate to likely increased cost to boaters on Lake George and inconvenience in having to visit a regional inspection station prior to launch on the lake. There is also likely to occur, in the first year of operation, a number of boaters who are unaware of the new regulations and will travel to their favored launch point without going first to an inspection station. This will result in some frustration among the boating public until all boaters are aware of the new processes. An extensive public outreach campaign will be put in place to inform boaters of the new regulations and processes prior to their travel to Lake George and launch at the lake. These issues and mitigation measures are discussed in Chapter 6.7. Additional vehicle traffic will occur at the regional inspection station, however, traffic is either on a state road or would have been a part of existing bypass traffic (vehicles already going past the site). Traffic impacts will not be significant since inspection stations will operate for 8-12 hours daily and seven days a week at most locations.

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SECTION 10 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF ENVIRONMENTAL RESOURCES


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SECTION 10 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF ENVIRONMENTAL RESOURCES A commitment of resources is irreversible when its primary or secondary impacts limit the future option for a resource. An irretrievable commitment refers to the use or consumption of resources that is neither renewable nor recoverable for later use by future generations. The commitment of resources refers primarily to the use of nonrenewable resources such as fossil fuels, water, labor, and electricity. Expected minor changes resulting from the preferred alternative of mandatory boat inspections could include the commitment of land, physical changes in the environment, effects on human populations, and fiscal changes. The boat inspection/decontamination facilities will be temporary and will not require large permanent development footprints.

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SECTION 11 EFFECT OF THE PROJECT ON THE USE AND CONSERVATION OF ENERGY RESOURCES
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SECTION 11 EFFECT OF THE PROJECT ON THE USE AND CONSERVATION OF ENERGY RESOURCES This project will involve consumption of liquid fuels or propane to power pressure washers and heated water at five boat inspection sites. The amount of fuels to be used by these facilities is expected to not exceed hundreds of gallons. This amount is not significant.

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Appendix A List of References

List of References Aukema, J.E., B. Leung K., Kovacs, C., Chivers, K.O. Britton, J. Englin, S.J. Frankel, R.G. Haight, T.P. Holmes, A.M. Liebhold, D.G. McCullough. and B.V. Holle. 2011. Economic impacts of non-native forest insects in the continental United States. PLOS One, Vol. 6(9)e 24587. Ayers, C.R., Deperno, C.S., Moorman, C.E., and Yelverton, F.H. 2010. Canada goose weed dispersal and nutrient loading in turfgrass systems. Online. Applied Turfgrass Science doi: 10.1094/ATS-2010-0212-02-RS. Boylen, C.W., and A. Kuliopulos.1981. Further studies on the bathymetry of Lake George. Reprinted from: The Lake George Ecosystem. ed. C. Boylen. Lake George Association, Lake George, N.Y. Britton, D.K. and S. Dingman. 2011. Use of Quaternary Ammonium to Control the Spread of Aquatic Invasive Species by Wildland Fire Equipment, Aquatic Invasions, 2011, Vol. 6(2): 169-173. Bunnel, D., B.M. Warner, M.A. Chriscinski, E.F. Roseman. 2011. Planktivory in the changing Lake Huron zooplankton community by bythotrephes consumption exceeds that of Mysis and fish. Freshwater Biology. 56(7) 1281-1296. Colorado Division of Wildlife. 2011. Aquatic Nuisance Species (ANS) Watercraft Decontamination Manual. Comeau S.R.,S. Rainville, W. Baldwin, E., Austin, S., Gerstenberger, C. Cross, and W.H. Worg, 2011. Susceptibility of quagga mussels (Dreissena rostriformis bugensis) to hot-water sprays as a means of watercraft decontamination. Biofouling Vol. 27(3) 267-274. Comeau, S.R., 2011. Colonization and decontamination of quagga mussels in the western United States: monitoring veligers in Lake Mead and field testing in the effects of hotwater spray as a means of watercraft decontamination. UNLV Thesis dissertation/Professional Papers/Capstones/Paper 1008 http://digital commons.library.univ.edu/thesesdissertation/1008. Congwen Z. and K. J. Boyle. 2010. The effect of an aquatic invasive species (Eurasian watermilfoil) on lakefront property values. Department of Agriculture and Applied Economics, Virginia Tech University. http://dx.doi.org/10.1016/j.bbr.2011.03.031. ConsultEcon, Inc. 2010. Warren County tourism white paper. Inter-Departmental Working Paper 2008 Warren County Occupancy Survey and Report. Cooke G.D., E.B. Welch, S.N. Peterson and S.A. Nichols. 2005. Restoration and Management of Lakes and Reservoirs. Third Edition. Taylor Francis Group CRC-Press. Cornell Cooperative Extension. April 2012. Draft Hydrilla Work Plan for Cayuga Inlet. Diana, J and E. LaPorte. 2012. State of the Lake: Aquatic Invasive Species in Lake Huron. http://earthsky.org/earth/state-of-the-lake-aquatic-invasive-species-in-lake-huron.

Dillion, P.S. 1983. Nutrient budgets for Lake George, NY. Lake George Ecosystem Volume III. Lake George Association, Lake George, NY. Ecology and Environment, Inc. 2005 and 2010. New York State Invasive Species Management Strategy. New York State Invasive Species Council. Eichler L.W., J.S. Barkowski, S.M. Shaver and C.W. Boylen. 2002. A Survey of Tributaries to Lake George, New York, for the Presence of Eurasian Watermilfoil. Darrin Fresh Water Institute DFWI Technical Report 02-3) Eichler, L.W. and C. Boylen. 2007. Aquatic Plant Population Assessments as Part of a Program to Eradicate Eurasian Watermilfoil from Selected Sites in Lake George, New York. Darrin Fresh Water Institute DEWI#2007-05. Eichler, L.W. 2010. Annual Report 2009. Darrin Freshwater Institute Aquatic Plant Identification Program. Darrin Freshwater Institute Report 2010. DFWI RPI. Ferritino, R. September 2012. Personal communication. Follow the Money: Wealth Population Are Key Drivers of Invasive Species, http://www.sciencedaily.com, releases/2010/06/10060715134.htm. George, C.1981. The Fishes of Lake George Watershed. In Lake George Ecosystem. Ed. C. Boylen. Lake George Association. Lake George, NY. Green A. and R. Armson. 2005. A Survey about Aquarium Outdoor Pond and Water Garden Issues Results and Technical Report. Technical Report #05-02, Minnesota Center for Survey Research University of Minnesota, Minneapolis Minnesota. Gunderson, J.L. and R.E. Kinnunen. 2004. AIS HAACP Training Curriculum. University of Minnesota. Sea Grant Minnesota. Sea Grant Publication #MNSG-F11 http://www.maine.gov/dep/water/invasives/costs.html Holmes and Associates. 2006. An assessment of recreational use on Lake George Final Report. Human Dimensions Research Unit, Cornell University. Hutchinson, D.R., W.M. Ferebee, H.J. Knebel, R.S. Wold and Y.W. Isachsen. The sedimentary framework of the southern basin of Lake George, N.Y. Lake George Ecosystem, 1981 ed. C.W. Boylen. Lake George Association, Lake George, N.Y. IPANE. 2013. Invasive Plant Atlas of New England. www.eddmaps.org. ISAC, National Invasive Species Council. 2006. Invasive Species Definition Clarification and Guidance White Paper. Jerde CL, MA. Barnes, EK. DeBuysser, A Noveroske W.L. Chadderton and DM Lodge, 2012. Eurasian watermilfoil fitness loss and invasion potential following desiccation during simulated overland transport. Aquatic Invasions. Vol. 7 (1):135-142. King, E. 2012. Interim Report on EWM Control at Lake George. PowerPoint Presentation Adirondack Milfoil Conference.

Kolar, C.S. and Lodge, D.M. (2001) Progress in invasion biology: predicting invaders. Trends Ecol. Evol. 16, 199204. LaFleur, R., E.L. Shuster, and C.W. Boylen. 1994. The hydrologic budget of Lake George, southeastern Adirondack mountains of New York. Northeastern Geology, 1994, vol. 16, (2): 94-108. Long, D.R., L.W. Eichler, D.A. Roberts, T.C. Ryan, D.B. Shafer, J. Schaniger, K.L. Smith, and D. Pope. 1981. The Lake George Monitoring Program for the Year April 1980-April 1981. The Lake George Ecosystem. C. Boylen, editor. Lake George Association, Lake George, NY. Lueng, B., D.M. Lodge, D. Finnoff, J.F. Shogren, M.A. Lewis, and G. Lamberti. 2002. An ounce of prevention or a pound of cure: bioeconomic risk analysis of invasive species. Proc. Biol.Sci. Vol. 7:269(1508):2407-2413). Madsen, J.D. 1994. Invasives and declines of submerged macrophytes in Lake George and other Adirondack lakes. Lake and Reservoir Management. Vol.10:19-23. Madsen J.D. and C.S. Owens. 2000. Factors contributing to the spread of hydrilla in lakes and reservoirs. ERDC TN-APCRP-EA-01. Madsen J.D. and D.H. Smith. 1997. Vegetative spread of Eurasian Watermilfoil colonies. J Aquatic Plant Management 35:63-68 Madsen, J.D., J. A. Bloomfield, L.W. Eichler, C.W. Boylen, J.W. Sutherland. 1991. The decline of native vegetation under dense Eurasian watermilfoil canopies. Journal of Aquatic Plant Management. Vol. 29: 94-99. Menninger H. No Date. The Asian clam Corbicula fluminea: A brief review of the scientific literature. NY Invasive Species Research Institute. Mid-Atlantic Panel of Aquatic Invasive Species. 2009. Rapid response planning for aquatic invasive species: a Maryland example. Maryland Sea Grant College. Publication # UM SG-TS-2009-01 Southeastern Adirondack Mountains of New York. Northeastern Geology, v. 16, no. 2, p. 94-108, 1994. www.mdsg.umd.edu. Mikol G.F. and D.M. Polsinelli. 1985, A morphometric atlas of selected lakes: region 5-Clinton, Essex, Franklin, Fulton, Hamilton, Saratoga, Warren, and Washington counties. Albany, N.Y. Bureau of Water Research, New York State Department of Environmental Conservation. National Park Service. 2012. Mussel infested boat prevented from launching at Lake Powell, Glen Canyon National Park. http://www.nps.gov/glca/parknews/. March 29, 2012. New York State Department of Agriculture and Markets Cooperative Agricultural Pest Study. No date. http://www.agriculture.ny.gov/CAPS/index.html. New York State Department of Environmental Conservation Bureau of Fisheries. 2009. New York Statewide Angler Survey 2007. Report 1:Angler Effort and Expenditures.

New York State Invasive Species Council. 2005 & 2010. Annual Reports. Office of Real Property Services. 2010 Tax Roll: Data for Local Governments: Essex, Warren and Washington Counties. NYS Office of the Comptroller. OKeefe, D. 2012. Survey finds Michigan boaters could do more to prevent the spread of invasive species. Michigan State University Extension. http://msue.awr.edu/news/. ONeill C.R., Jr. and D.B. MacNeill, 1991. The zebra mussel (Dreissena polymorpha) an unwelcome North American Invader. Cornell Cooperative Extension, SeaGrant, State University of New York. Fact Sheet. Nov.1991. Ontario Invading Species. http://www.invadingspecies.com Open For Business Regional Economic Development Council. 2011. A New Vision for the Finger Lakes Economy. Orr, R., A.S. Green and R. Luken. 2005. Focus Group Conference Report and Pathways Ranking Guide. National Invasive Species Council and the Aquatic Nuisance Species Task Force. 2005. https://www.invasivesspecies.info.gov. Pierce, C.L., M.D. Sexton, M.E. Pelham, and J.G. Larscheid. 2001. Short-term variability and long-term change in the composition of the littoral zone fish community in Spirit, Lake, Iowa. American Midland Naturalist. Vol.146 No. 2: 290-299. Rapp, C. 2012. Map of Launch Points on Lake George. LGPC internal data. Rendall J., 2011. Report to the Minnesota Legislature on Aquatic Invasive Species Prevention Measures. Submitted to Environment and Natural Resource Committees of the Minnesota House and Senate. January 28, 2011. Rothlisberger, J.D., W.L. Chadderton, J. McNulty and D.M. Lodge. 2010. Aquatic invasive species transport via trailered boats: what is being moved, who is moving it and what can be done. Fisheries Vol. 35 (3) 121-132. St. George News. May 18, 2011. http://www.stgeorgeutah.com/mews/archive/2011/05/18/twoboats-decontaminated-at-checkpoint-work-continues-to-keep-quagga-mussels-out-ofutah. Sea Grant Michigan. 2004. http://www.seagrant.umn.edu/exotics/spiny Sheldon R.B. and C.W. Boylen. 1977. Maximum depth inhabited by aquatic vascular plants. The American Midland Naturalist 97(1) 248-254. Sheldon, R.B., Ogden, E.C., Davis, J.K., Boylen, C.W. 1976. Field Guide to the Aquatic Plants of Lake George, New York. New York State Museum Department of Education. Bulletin 426. Parker-Stetter, S.L., L/G. Rudstam, P.J. Sullivan and D.M. Warner. 2009. Standard operating procedures for fisheries acoustic surveys in the Great Lakes. Great Lakes Fisheries

Commission. Spec. Pub. 09-01. Sprecher, S.L. and K.D. Getsinger. 2000. Zebra mussel chemical control guide. ERDC/EL TR00-1. USACOE. Environmental Laboratory. State of Utah Department of Natural Resources. 2012 (updated). Decontamination protocol to minimize risk or spread of aquatic invasive species. www.wildelife.utha.gov/mussel/decom. Stynes, D.T. 2011. Economic Benefits to Local Communities from National Park Visitation and Payroll 2010. Natural Resource Report. NPS/NRSS/EQD/NRR-2011/481 Swart, J. and J. A. Bloomfield. 1985. Characteristic of New York State Lakes Gazette of Lakes, Ponds and Reservoirs 2nd Ed. NYSDEC Lake Assessment Unit. Tahoe Environmental Research Center. 2009. Tahoe State of the Lake Report. 2009. http://terc.ucdavis.edu/stateofthelake/StateOfTheLake2012.pdf. Thompson G, T. Thompson and W. Nixon, 2012. Identify options and cost for implementing statewide measures to prevent the spread of aquatic invasive species. MNDNR0012012, Minnesota DNR Division Ecological and Water Resources Invasive Species Program, 500 Lafayette Rd., St. Paul, MN 55155-4032 prepared by Thompson Engineering Co. Tourism Economics. 2010. The economic impact of tourism in New York: Adirondacks Focus. Trent A.D., Kursky and S. Gilmour, 2002. MTDC Portable Vehicle Washer Interim Report. USDA Forest Service Technology Development Program. Missoula, MT. 1E12D75Power Washer. http://fsweb.mtdc.usfs.fed.us. U.S. Army Corps of Engineers. 2009. Lake Tahoe Region Aquatic Invasive Species Management Plan. California-Nevada. US Congress of Office of Technology Assessment, 1993. U.S. Environmental Protection Agency. 2012. Pathways for Invasive Species Introduction. http://water.epa.gov/polwaste/vwd/ballastwater/invasive_species_pathways.cfm. U.S.F.W.S. National Wildlife Refuge System. 2009. Managing invasive plants: concepts, principles, and practices. www.fws.gov/invasives/stafftrainingmodule/planning/plans.html. U.S. Geologic Service. 2001. Non-Indigenous Species Information Bulletin - Asian Clam. http://fl.biology.usgs.gov/corbicula4.pdf. van Leeuwen, C., G. van der Velde, B. van Lith, and M. Klaassen. 2012. Experimental quantification of long distance dispersal potential of aquatic snails in the gut of migratory birds. PloS ONE 7 (3). http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0032292.

Whittier, T.R., P.L. Ringold, A.T. Herlihy, and S.M. Pierson, 2008. A calciumbased invasion risk assessment for zebra and quagga mussels (Dreissena spp). Front. Ecol. Environ. 6, doi 10.1890/070073. Williams, B.K., R.C. Szaro and C.D. Shapiro. 2009. Adaptive Management. The US Department of Interior. Technical Guide. http://www.doi.gov/initiatives/AdaptiveManagement/documents.html Wimbush, J., M. Fisher, J.W. Zarzynski and S.A. Nierwicki-Bauer. 2009. Eradication of colonizing populations of zebra mussel (Dreissena polymorpha) by early detection and SCUBA removal: Lake George. Aquatic Conservation: Marine Freshwater Ecosystems 19:703-713 www.glfc.org/pubs/special pubs/sp09-1.pdf. Wright, B. 2009.The affects of mandatory boat inspections on recreational boating. University of Northern Colorado. Young S.M. 2010. New York Natural Heritage Program Rare Plant Status List. NYDEC Natural Heritage Program. www.dec.nys.gov/docs/fish_marine_pdf/2010. or www.nynhp.org. Zook B. and S. Phillips, 2009 Recommended uniform minimum protocols and standards for watercraft interception programs for Dreissenid Mussels in western United States. UMPSII, Pacific States Marine Fisheries Commission.

Appendix B List of Acronyms

List of Abbreviations and Acronyms AIS AM ANS ANSTF APIPP ARRA BCIP BMP CDD CNYISC DFWI EBM ECL EDRR EPA EPF EWM GEIS HACCP HPHW ISTF LCBP LGPC LGACRRTF MOU NEANS NFWF NGO NHP NHT NISC NRCS NRM NYISRI NYS NYSDAM NYSDEC NYSDOS NYSDOT NYSOPRHP PRISM SEQR TRPA USACE USDA USDOT USFWS USGS Aquatic invasive species Adaptive management Aquatic nuisance species Aquatic Nuisance Species Task Force Adirondack Park Invasive Plant Program American Recovery and Reinvestment Act Biological Control of Invasive Native and Non-Native Plants Best Management Practices Clean Drained Dry Council New York Invasive Species Council Darrin Freshwater Institute Ecosystem-based management Environmental Conservation Law Early Detection/Rapid Response Environmental Protection Agency Environmental Protection Fund Eurasian watermilfoil Generic Environmental Impact Statement Hazard Analysis-Critical Control Point High Pressure Hot Water NYS Invasive Species Task Force Lake Champlain Basin Program Lake George Park Commission Lake George Asian Clam Rapid Response Task Force Memorandum of understanding Northeast Regional Aquatic Nuisance Species Panel National Fish and Wildlife Foundation non-governmental organization Natural Heritage Program Natural Heritage Trust National Invasive Species Council Natural Resources Conservation Service Natural resource management New York Invasive Species Research Institute New York State New York State Department of Agriculture and Markets New York State Department of Environmental Conservation New York State Department of State New York State Department of Transportation Office of Parks, Recreation and Historic Preservation Partnership for Regional Invasive Species Management State Environmental Quality Review Tahoe Regional Planning Agency United States Army Corps of Engineers United States Department of Agriculture United States Department of Transportation United States Fish and Wildlife Service United States Geological Survey

Appendix C Lake George Association Lake Steward Inspections Summary Data 2008-2012

Appendix D Draft LGPC Regulation to Require Watercraft Inspections for AIS

Draft LGPC Regulation to Require Watercraft Inspections for AIS


Draft SUBPART 646-8 Aquatic Invasive Species Regulations for the Lake George Park

Statutory Authority: The Commission shall have power to adopt, amend and repeal, after public hearing according to the provisions of the state administrative procedure act (except in the case of rules and regulations that related to the organization or internal management of the agency), such rules and regulations, consistent with this article, as it deems necessary to administer this article, and to do any and all things necessary or convenient to carry out the purpose and policies of this article and to exercise all powers granted by law. 43-0107(8) Environmental Conservation Law

Section 646-8.1 Purpose and Intent. The purpose of these regulations is to prevent the introduction and spread of aquatic invasive species. Aquatic invasive species (AIS) pose a serious threat to the waters of Lake George and can have a disastrous impact to the ecology and economy of the Lake George Park. This rule is intended outlaw all introductions of invasive species to Lake George, and to provide close management of the primary vector, trailered boats, by providing for the inspection of vessels to ensure that the operator of these vessels have taken steps to prevent the spread of aquatic invasive species.

Section 646-8.2 Applicability All actions that cause the transport and introduction of invasive species in the Lake George Park. All trailered vessels used on Lake George shall be subject to inspection, and if determined necessary, decontamination. This inspection may take place anywhere within the Lake George Park or at any designated location authorized by the Commission.

Section 646-8.3 Definitions The following terms shall have the stated meanings whenever used in this Subpart or in documents referenced or prepared by the commission. Other terms defined in section 645-2.1 of this Title shall have the meanings set forth in that section.

(a) Aquatic invasive species (AIS) means exotic or nonnative aquatic animal or plant species that have been determined by the Lake George Park Commission, the New York State Invasive Species Task Force, or the New York State Department of Environmental Conservation to pose a significant threat to the aquatic resources or water infrastructure of Lake George or New York State.

(b) Decontamination means any method determined by the commission to effectively remove aquatic invasive species from vessels or trailered vessels.

(c) Launch is any boat launch, ramp, hoist or other area on a lakefront lot that is or may be used to allow a trailered vessel to enter Lake George.

(d) Launch operator is the owner of the lakefront lot upon which a launch is located, or the operator of the launch.

(e) For the purpose of this Subpart, trailered vessel means any and all boat or watercraft, with or without a motor, which is towed by another vehicle. The term includes a vessels motor, trailer, compartments, and any other associated equipment or containers that routinely or reasonably could be expected to contain, or come into contact with water. Trailered vessel does not include seaplanes, hand-launched rafts, kayaks, belly boards, float tubes, canoes, row boats, windsurfer boards, sail boards, inner tubes, standup paddleboards or similar devices.

(f) Vessel invasives control technician (VICT) means a person who is certified by the commission to provide services in the form of inspections only, or both inspections and decontamination.

(g) Vessel inspection and invasive control seal (VIICS) means a device, marker or sticker authorized by the commission to verify that vessels have successfully passed inspections and, when required, decontamination.

Section 646-8.4 Prohibitions

(a) No person shall launch or allow or cause to be launched any trailered vessel into the waters of Lake George without an inspection of the trailered vessels, as required by this Subpart.

(b) No person shall transport or introduce aquatic invasive species into the Lake George Park by any means, including but not limited to aquaculture, aquarium dump, animal release, AIS-contaminated trailered boats, non-motorized vessels, docks, construction equipment, fishing equipment, and bait bucket.

(c) No person shall launch a vessel contaminated with aquatic invasive species into the waters of Lake George.

(d) No person shall provide inaccurate or false information to commission personnel or VICT.

(e) No person shall alter or modify any vessel inspection and invasive control seal used by the commission or any VICT

(f) No person shall operate a launch without maintaining launch records as required by this Subpart.

Section 646-8.5 Vessel Inspections, Decontamination and Administration

(a) Prior to launch into the waters of Lake George, all watercraft shall be inspected by a VICT to detect the presence of, and prevent the introduction of, aquatic invasive species. Non-motorized vessels and seaplanes may be subject to inspection prior to entering the waters of Lake George if determined necessary by the commission or any watercraft invasives control technician.

(b) All vessels inspected pursuant to subparagraph 646-8.4(a) shall be subject to decontamination if determined necessary by the commission or any VICT.

(c) All vessels subject to decontamination pursuant to subparagraph 646-8.4(b) shall be permitted to enter the waters of Lake George only if the decontamination is performed and completed by a VICT and the launch or landing, as appropriate, is authorized by a VICT.

(d) Inspections and decontamination performed pursuant to this Subpart shall be subject to a fee related to the costs of performing such services and other vessel inspection program costs.

(e) All launches must be registered with the commission on such form as the commission may prescribe. Launch registration must be completed by the launch operator within 60 days of adoption of this regulation. Launch operators must certify compliance with commission rules and maintain a written record of launches on such forms as the commission may prescribe.

(f) Launch operators shall secure launches in a manner so as to prevent non-inspected trailered vessels from entering the lake.

(g) Any vessel found entering the waters of the Lake George in violation of this subpart shall be removed from those waters immediately.

(h) Any individual who launches a vessel in violation of this subpart may be held responsible for the costs expended by the commission or its designee for response and mitigation of impacts.

(i) Vessel invasives control technicians will be trained and certified annually by the commission. A training fee may be charged to individuals taking the course. The commission will identify the type and hours of training to be completed by VICTs on an annual basis.

Section 646-8.6 Reporting of Aquatic Invasive Species

(a) Identification of an AIS through sampling and monitoring procedures at a location where that species has not been known to exist shall be reported immediately to the commission.

(b) If an AIS is suspected, but the identity is not known, the commission shall be contacted within 48 hours and samples submitted to an approved laboratory for analysis. Section 646-8.7 Phased Implementation These regulations will become effective subject to an implementation schedule prepared by the commission within 30 days of the date of adoption.

Section 646-8.8 Penalties

(a) Penalties shall conform to Environmental Conservation Law Article 71, Title 33 - Enforcement of Article 43 (71-3301-71-3307) and Section 9-1709, Chapter 674 of Laws of NYS, 2007, Subdivision 1 and 2 and Chapter 26 of Laws of NYS, 2008, and as amended.

(b) Any person violating the provisions of this Subpart shall be guilty of a violation punishable by a fine of not less than $100 nor greater than $250 for the first offense. Second and subsequent offenses shall result in the suspension of the vessel's registration to operate on Lake George and a fine of $500. In addition, any person violating this Subpart may be liable for a civil penalty of not more than $5,000.

(c) Allowing entry of a vessel into Lake George in violation of this Subpart shall be subject to a fine of not less than $250 or greater than $500 for the first offense. A second offense may result in a launch operator being required to close off a launch permanently and a fine of $500 per day of violation. In addition, any person violating this Subpart may be liable for a civil penalty of not more than $5,000.

Appendix E Economic Analysis: Methodology and Analysis

Introduction and Description of Assessment Area The water area of Lake George covers approximately 27,217 acres. AIS are most likely to occur in the littoral zone of the lake. This zone is basically described as the shallow water area extending from the shoreline to a point where water depth is approximately ten (10) meters in depth (Boylen and Kuliopulo, 1981). This area provides favorable conditions (water temperature, exposure to sunlight, etc.) for establishment and growth of AIS to occur. The area of the lake that meets these parameters comprises approximately 8,058 acres or twenty-nine percent (29%) of the overall water coverage area. This area of the Lake is the location where much of the recreational contact with the water occurs as the littoral zone provides areas for beaches and swimming, docks, and moorings. This area also serves as the primary habitat for many game fish attracting recreational and sport fishermen or anglers. The area which will be the focus of the economic impact assessment that follows are the 3,130 shoreline properties along Lake George and extending through eight (8) municipalities (the Towns of Dresden, Fort Ann, Putnam, Bolton, Hague, Lake George (inclusive of the Village of Lake George), Queensbury and Ticonderoga) within three (3) counties (Washington, Warren and Essex), see Appendix I. This area was selected since these parcels provide the means for various forms of direct contact with the water (swimming, boat launching and boating, and waterfront views from both perspectives from the shoreline out over the lake and from the lake along the shoreline and beyond). As such, this area will be directly affected by the presence of AIS. Additionally, it is acknowledged that the economic impact of AIS may have implications to upland (off shore) properties. As a practical matter many properties just off the shore have entitlement to some form of water access through deed reference and/or shared use of on shore amenities such as docks, moorings and beaches. The research necessary to quantify these circumstances is beyond the scope of this assessment but impacts to upland properties with some form of access to the lake shore and associated amenities is a likely scenario that would add to the impacts projected from the following analysis. Description of Economic Impact Assessment Methodology The economic impact assessment studied and organized prior reports relating to AIS growth in lakes with similar qualities and recreational value from across the nation. Further studies relating to the tourism economy in the Lake George region were also reviewed as the basis for establishing the economic value of Lake George as an attraction. Parcel values for lakefront land were derived from municipal assessment data as compiled by the Real Property Tax Service for each of the three counties. The review of data and prior reports and studies involved three (3) basic steps: 1. Collect data on: The degree to which water-related recreational activities contribute to the regional economy; The economic performance of tourism within the regional economy; Waterfront property values within the municipalities of the Lake George region; 2. Group expenditures, revenue data and estimated impacts of AIS in similar circumstances and allocate them to two categories of economic consideration: Recreation-based expenditures; and Tourism expenditures; 3. Waterfront land valuation. Estimate economic impacts of alternative mitigation measures as they relate to: Recreation, tourism expenditures and secondarily to employment derived from tourism and associated wages paid and retail expenditures and space, and, waterfront land values; and

4. Estimate the economic impact of alternative mitigation measure as each relates to: Recreation Tourism expenditures secondarily to employment derived from tourism and associated wages paid and retail expenditures and space; Waterfront property values; and Potential economic impacts associated with implementation and administration. Recreational Activities and Associated Expenditures In consideration of the characteristics of Lake George as a water body (high level of water quality, abundant and varied species of fish, setting among a mountainous terrain and aesthetically attractive surroundings), the lake is a recreational attraction of national significance. As such, the primary attractions of the Lake are water-based recreational activities. These include fishing, swimming, boating and sight-seeing. Some data is available regarding the number of swimmers at Lake George during the summer season. However, economic data is not available for expenditures related to swimming. Therefore, expenditures relating to swimming are assumed to be included in overall tourism expenditures. Water-based recreational expenditures from fishing or angler visits are tracked on the basis of angler days. Angler days on Lake George in 2007 totaled 289,011 days1. An angler visit is defined as any part of day spent fishing and the estimates are developed by the NYS Department of Environmental Conservation (DEC). The estimates are developed from a statewide angler survey conducted by mail of 17,000 fishing license holders. The survey is divided into three phases with response rates ranging from nearly forty percent (38%) to approximately fifty percent (49%). Based on the survey responses received the most popular species fished for in Lake George includes Black Bass (small or large mouth), Lake Trout, Yellow Perch, Landlocked Atlantic Salmon, and Northern Pike. Estimated expenditures total $20.06 million for an average expenditure per angler day of $69.40. The US Fish and Wildlife Services 2011 National Survey of Fishing, Hunting and Wildlife-Associated Recreation found that the number of anglers increased by 11 percent per year on average from 2006 to 2011. The most recent data concerning boating and swimming on Lake George was collected in 2005. The study titled Lake George Recreation Study Plan, 2005 estimated that 460,732 total boat use days occurred in 2005 from April through September (counted as boat use during a single day) with nearly seventy percent (69%) being power (motorized) boats. The study went on to estimate that there were 44,177 boats launched (April through September 2005) and 75,835 public beach users. The most popular boating activities included cruising, swimming from the boat while docked or moored and water skiing. Beach use averaged 3,776 users per day during the week and 7,420 per day on weekends2. The 2005 Recreation Study Plan also cited a 2003 Cornell University study for New York Sea Grant that estimated that there were 13,500 boaters with boats registered in New York State who spent $22.5 million in the Lake George area. The average total expenditure per boat was $1,700 or $2,117 in 2012 dollars. A review of recent boat registrations through the Lake George Park Commission finds that the number of registrations has increased to approximately 15,800
New York Statewide Angler Survey 2007 Report 1:Angler Effort and Expenditures; NYS Department of Environmental Conservation Bureau of Fisheries; June 2009 2 Lake George Recreation Study Plan, 2005, An assessment of Recreational Use on Lake George Final Report; Holmes and Associates; Human Dimensions Research Unit, Cornell University; 2006
1

boats in 2011. Therefore, the total annual expenditures attributed to boating total $33.49 million. The research conducted also identified information relating to the sentiments of property owners on Lake George and visitors to the region. A survey of residential dock owners, annual permit holders, temporary permit holders, beach users and commercial dock owners was conducted as part of the study data collection effort associated with the Recreation Study Plan conducted in 2005. Several topics/questions covered in the survey are especially relevant to the consideration of assessing the economic impact of AIS, whether perceived or real, and the associated fluctuations in tourism expenditures resulting from these perceived or real impacts to water quality. For example, in response to a question relating to the high-quality of the environment over eighty-five percent (85.4%) of the overall respondents indicated that clear, clean water was a very important feature of the natural environment. A majority of the respondents (76.5%) indicated that enjoying my favorite water sports is very important (39.8%) or important (36.7%). In terms of the recreation-related issue thought to be the biggest problem on Lake George invasive species like Zebra mussels entering the lake on boats was the overall largest concern (15.7 percent of the respondents indicated this to be the largest issue seven years ago). A more detailed analysis of the responses to this issue found that 70 percent of the lakeshore owners and 58 percent of the annual permit holders identified invasive species as a problem while only 22 percent of temporary permit holders felt that way3. This information is relevant to the importance of water quality and the estimated impact AIS may have on water-based recreational activities and boating. Tourism and Associated Expenditures Areas with attractive lakes and waterfront settings are typically popular with tourists. As such, waterfront areas can make significant contributions to the regional and local economies through tourism visitation (overnight and day-trips) and the associated expenditures for lodging, meals, entertainment, etc. The research conducted for this impact assessment found this to be true with lake regions across the country. For example, the recreational value of the Lake Huron waterfront area was quantified in a study entitled Recreation Profile Beaches: Opportunities for Lake Huron. The study cites a recent survey of US travelers that found over sixty percent (63%) of the respondents indicated theyd like to visit a beach during their vacation in 2012. In 2010 visitors to Michigans Thumb along Lake Huron totaled 1.4 million spending $116 million ($82 per visitor). Furthermore, over fifty percent (54%) of the visitors indicated that the beaches and waterfront were their main reason for their stay. Other activities cited as reason for their stay included walking outdoors, relaxing outdoors, fishing, picnicking and camping. The same, if not more, dynamic impact of tourism exists in the Lake George region. Tourism in the Adirondack region contributes approximately $1.1 billion4 in annual expenditures (lodging, food, shopping, entertainment, transportation, etc.) into the local and regional economy. Warren County alone represents forty-two percent (42%) of the regional tourism economy with $487 million5 in direct tourism spending. Accordingly, Warren County generated over $60 million in state ($30.1 million) and local ($31.6 million) tax revenue (sales and occupancy taxes or commonly referred to as bed taxes) for a combined total of $61.82 million6. Furthermore, traveler spending rose over seven percent (7.2%)7 from 2009 to 2010. However, when one
3 4

Ibid The Economic Impact of Tourism in New York 2010 Calendar Year, Adirondacks Focus: Tourism Economics 5 Ibid 6 Ibid 7 Ibid

considers prior studies preceding the recession of 2008, tourism expenditures have shown to be even more impactful. In 2008 tourism expenditures in Warren County were estimated to be as high as $628 million dollars8. In consideration of the concentration of recreational and destination-style attractions, the vast majority of these expenditures are occurring during the summer months in the Lake George area. In 2009 it was estimated that 7.33 million visitor events occurred in Warren County9 and 93 percent were within the communities of the study area as described above10. Of the total visitor events it is estimated that 3.66 million (50%) were day trips. According to the Warren County Tourism Department, the average tourism party in 2010 consisted of 3.12 persons spending an average of $440.78 per party or $141.28 per person per overnight stay. The breakdown of expenditures for the average overnight stay is as follows: Expenditure Overnight Stays: Meals $ 92.58 (21%) Shopping $ 64.31 (15%) Entertainment/Attractions $ 72.96 (17%) Transportation $ 30.40 (7%) All Other $ 52.53 (12%) Room (one) $128.00 (29%) Total $440.78 Per person for overnight stay = $141.28

The expenditures associated with day trip stays are correspondingly less: Expenditure Day Trips: Meals $ 29.67 (29%) Shopping $ 20.67 (21%) Entertainment/Attractions $ 23.39 (23%) Transportation $ 9.74 (10%) All Other $ 16.84 (17%) Total $100.25 Per person for day trip = $100.25

According to the Warren County Department of Tourism, overnight stays account for over eighty percent (80.7%) of all tourism expenditures and the remaining expenditures (19.3%) are attributed to day trips. Therefore, based on 2010 tourism expenditures as cited above, $393 million are related to overnight stays and $94 million of annual tourism expenditures are related to day trips. In terms of employment, tourism in Warren County generates 8,076 jobs (direct-directly attributed to companies providing goods and services, indirect secondary suppliers/wholesalers providing goods, and induced tertiary as incomes are derived from expenditures made from the prior two levels of impact) with annual wages totaling $227.4 million for an average per capita wage of $28,157 per worker11.

8 9

Inter-Departmental Working Paper 2008 Warren County Occupancy Survey and Report; April 3, 2009 Warren County Tourism White Paper ConsultEcon, Inc.; September 2010 Inter-Departmental Working Paper 2008 Warren County Occupancy Survey and Report; April 3, 2009 11 The Economic Impact of Tourism in New York 2010 Calendar Year, Adirondacks Focus: Tourism Economics
10

The Lake Tahoe Region Aquatic Invasive Species Management Plan also provided estimates for impact to tourism overall. This estimate represents a total impact across the spectrum of activities that constitute water-based recreational activities that are the basis for tourism in the Lake Tahoe area. The Management Plan forecasted a reduction of tourism within a range of 2% to -10% with no AIS prevention measures in place. It is understood that a fundamental premise of the preferred alternative method for the prevention of further spreading AIS is mandatory inspection of all visitor boats prior to launch into Lake George. According to the performance of similar spread prevention programs, where inspection of all visitor boats is mandatory, introduction of new AIS is minimal to not at all. This level of performance ensures that water quality degradation associated with introduction of additional AIS will not be a factor in degradation of water-based tourism activities. Therefore, it appears that the proposed alternative measure will have a minimal adverse impact on tourism in the Lake George area. Waterfront Property Values Eight (8) towns are situated around Lake George with waterfront properties totaling 3,130 parcels. The following table (Table 4-1) summarizes the assessed valuation of these parcels:

Table 4-1. Lake George Waterfront Parcels Summary of Full Valuation Acres Ticonderoga -Residential and Vacant Parcels -Commercial and Rec. and Ent. -Other (Public serv., Consv. etc.) Ticonderoga Total Bolton -Residential and Vacant Parcels -Commercial and Rec. and Ent. -Other (Public serv., Consv. etc.) Bolton Total Hague -Residential and Vacant Parcels -Commercial and Rec. and Ent. -Other (Public serv., Consv. etc.) Hague Total Lake George -Residential and Vacant Parcels -Commercial and Rec. and Ent. -Other (Public serv., Consv. etc.) Lake George Total Queensbury -Residential and Vacant Parcels -Commercial and Rec. and Ent. -Other (Public serv., Consv. etc.) Queensbury Total Dresden -Residential and Vacant Parcels -Commercial and Rec. and Ent. -Other (Public serv., Consv. etc.) Dresden Total Fort Ann -Residential and Vacant Parcels -Commercial and Rec. and Ent. -Other (Public serv., Consv. etc.) Fort Ann Total Putnam -Residential and Vacant Parcels -Commercial and Rec. and Ent. -Other (Public serv., Consv. etc.) Putnam Total Total Study Area = 431.83 2.10 26.73 460.66 Land Assessment $73,106,000 $599,000 $1,885,200 $75,590,200 Improvements $27,894,250 $225,000 $844,596 $28,963,846 Total $101,000,250 $824,000 $2,729,796 $104,554,046

968.84 206.67 4521.72 5697.23

$371,001,549 $45,587,000 $72,561,000 $489,149,549

$109,419,000 $32,121,600 $1,147,500 $142,688,100

$480,420,549 $77,708,600 $73,708,500 $631,837,649

387.23 52.30 1121.86 1561.39

$177,567,679 $9,679,500 $30,124,300 $217,371,479

$54,495,587 $3,407,100 $5,858,200 $63,760,887

$232,063,266 $13,086,600 $35,982,500 $281,132,366

370.66 119.73 197.18 687.57

$169,202,025 $47,107,700 $21,156,700 $237,466,425

$69,264,275 $36,293,088 $3,494,000 $109,051,363

$238,466,300 $83,400,788 $24,650,700 $346,517,788

321.80 31.65 42.87 396.32

$314,478,360 $10,794,600 $1,792,700 $327,065,660

$178,850,872 $2,761,800 $89,100 $181,701,772

$493,329,232 $13,556,400 $1,881,800 $508,767,432

887.03 20.35 1472.40 2379.78

$35,064,250 $441,300 $17,465,200 $52,970,750

$28,509,400 $295,400 $0 $28,804,800

$63,573,650 $736,700 $17,465,200 $81,775,550

262.44 200.32 1299.43 1762.19

$181,697,179 $5,333,200 $52,440,100 $239,470,479

$71,611,781 $2,292,200 $0 $73,903,981

$253,308,960 $7,625,400 $52,440,100 $313,374,460

2069.28 41.50 0.00 2110.78 15,055.92

$61,543,350 $1,913,500 $5,600 $63,462,450 $1,702,546,992

$32,901,324 $456,700 $0 $33,358,024 $662,232,773

$94,444,674 $2,370,200 $5,600 $96,820,474 $2,364,779,765

Source: Real Property Tax Service for Essex, Warren and Washington Counties: 2010 Tax Rolls

Total assessed value of waterfront parcels on Lake George is $2.365 billion ($2,365,000,000). The total valuation is further broken down by land, with a total valuation of $1.703 billion, and improvements (buildings, structures, etc.) at approximately $662.23 million. Table 4-1 also summarizes the breakdown of valuation by basic land uses: Residential and vacant parcels; commercial, recreation and entertainment; and, other (i.e. public services, conservation, etc.). It is evident that the predominance of commercial uses occurs in the Towns of Bolton and Lake George as comparatively higher valuations relating to commercial lodging, dining and marina uses occur within these municipalities. The establishment of the relationship between invasive species and their impact to property valuation was initially presented in studies of invasive species to the terrestrial environment (Aukema, J.E. et al 2011). Further research found prior studies that specifically discussed the impact of AIS on property values of lake shore property owners and associated local governments (Zhang and Boyle, 2010). In gauging the impact of AIS on Lake George waterfront property valuation, the impact is anticipated to vary with the concentration of AIS present in the littoral zone of the waterfront area adjoining the parcel. In reviewing existing research on the effect of AIS on waterfront property values, the 2010 report titled The effect of an aquatic invasive species (Eurasian watermilfoil) on lakefront property values determined that the presence of AIS such as milfoil significantly and substantially (affected) lakefront property values. The report establishes loss of value in relationship to the amount of milfoil coverage present: At lower levels of plant coverage, one percent (1%) or less, loss of value is very slight at .33 percent. However, loss of valuation increases as the presence of AIS increases; At a moderate coverage level (41 to 60 percent) loss of property value is estimated to be approximately 2 percent (2.39%); and, With maximum coverage (81 to 100 percent) resulting in loss of value of approximately 16 percent (16.35%)12.

12

Theeffectofanaquaticinvasivespecies(Eurasianwatermilfoil)onlakefrontpropertyvalues;CongwenZhang andKevinJ.Boyle,DepartmentofAgricultureandAppliedEconomics,VirginiaTechUniversity,2010

Appendix F Proposed Project Implementation Schedule

Proposed Project Implementation Schedule


April Frozen boat inspection process closes. Complete interviews for summer staff. Select summer employees-complete equipment tests. Finalize training schedule, locations. Review final budget-make adjustments. Prepare funding request to Federal Government. Open several regional inspection sites. Open remaining regional inspection sites. Complete training events. Review operations at commercial sites. Attend New York Federation of Lakes annual meeting. Train summer patrols on procedures. Meet with Warren County Sheriff. Review, retrain staff on protocols, complete weekly monthly schedules. Start Invasive Control work. All sites open. Complete weekly monthly schedule. Finalize monitoring surveillance schedules with consultants. Continue invasive control work. Recheck equipment. Respond to issues. Compile weekly reports from sites. Check outreach-is information getting to recreationist community. Discuss progress and needs with federal personnel and elected officials. Respond to issues. Review inspection program. Review monitoring and surveillance. Review AIS control work. Outreach meeting to community groups and NGOs. Progress reports to counties for supervisors meeting. Update weekly monthly schedule. Begin to plan for summer employee departure. Respond to issues. Issue progress report to community and county boards. Attend outreach event of community groups and NGOs. Finalize weekly monthly schedules for summer employee departure-complete employee evaluations. Review monitoring and surveillance efforts. Review monthly reports. Respond to issues. Prepare equipment budget for following year. Prepare personnel budget.

May

June

July

August

September

October

November

December

January

February

March

Assemble summer data. Find, fill gaps in data, flag data issues. Prepare monthly schedule. Review enforcement activities. Begin fall hours. Identify needs and successes in program. Finalize annual report. Complete following year budget. Complete monthly and close down schedule. Meet with marina operators. Schedule equipment repairs. Meet with partners. Present annual reports to the counties and government. Review draft monitoring and surveillance reports. Adjust budget for following year. Prepare grant applications. Prepare funding request to federal agencies. Prepare brief annual report on program for distribution with boating registration material. Complete grant applications. Prepare schedule for following year with training dates, inspection, location modification. Issue request for proposal for control work and monitoring and surveillance efforts. Complete grant applications. Attend northeast aquatic plant society meeting. Meet with partners to review needs, success, and issues from prior year. Order materials for coming year. Advertise for summer employees. Complete grant application. Meet with federal agencies. Update state funded budget. Start frozen boat inspections. Interview summer employee. Recruit from prior successful employees. Adjust budget. Complete frozen boat inspection.

Appendix G Terrestrial and Aquatic Invasive Species

Invasive Species Based on NYS = present in area indicated ? = possibly present

Organism (scientific and common names) PLANTS Cabomba caroliniana Carolina fanwort Callitriche stagnalis pond water starwort Egeria densa Brazilian waterweed Glyceria maxima tall Glyceria Hydrilla verticillata water thyme Hydrocharis morsusranae frogbit Iris pseudacorus yellow iris Ludwigia grandiflora ssp. hexapetala (L. hexapetala) Uruguayan primrose willow Ludwigia peploides ssp. glabrescens floating primrose willow Lythrum salicaria purple loosestrife Marsilea quadrifolia European water fern or pepper wort Myriophyllum aquaticum parrot-feather Myriophyllum heterophyllum broadleaf water-milfoil Myriophyllum spicatum Eurasian water-milfoil Najas minor brittle water nymph Nasturtium officinale watercress Nelumbo nucifera sacred lotus Nymphoides peltata yellow floating heart Phragmites australis common reed grass Potamogeton crispus curly-leaf pondweed Rorippa amphibia water yellowcress Trapa natans water chestnut

Lake George

Lake Champlain

Mohawk River

Hudson River ? ? ?

Adirondacks

Capital Region

Great Lakes

NY State ?

? ? ? ?

? ? ?

? ? ?

?*

Organism (scientific and common names) ANIMALS MOLLUSKS Asian clam Corbicula fluminea New Zealand mudsnail Potamopyrgus ntipodarum Quagga mussel Dreissena bugensis Zebra Mussel Dreissena polymorpha FISH Alewife Alosa pseudoharengus Blueback herring Alosa aestivalis Grass carp Ctenopharyngodon idella Northern Snakehead Fish Channa argus** Round goby Neogobius melanostomus Sea Lamprey Petromyzon marinus Rudd Scardinius erythrophthalmus CRUSTACEANS Water Flea Eubosmina coregoni Fishhook Waterflea Cercopagis pengoi Waterflea Daphnia galeata Bloody red shrimp Hemimysis anomal Spiny Water Flea Bythotrephes longimanus Chinese mitten crab Eriocheir sinensis Rusty Crayfish Orconectesrusticus

Lake George

Lake Champlain

Mohawk River

Hudson River

Adirondacks

Capital Region

Great Lakes

NY State

Champlain Canal

LG

Native Native

Champlain Canal

Finger Lakes

* Water chestnut was once found in Dunham Bay of Lake George, but was eliminated. ** Controlled and/or contained. Source: USGS-NAS Nonindigeneous Aquatic Species; USGS Great Lakes Source Center. www.glsc.usgs.gov http://mas.er.usgs.gov/ EDD Early Detection or Distribution Mapping System The University of Georgia-Center for Invasive Species and Ecosystem Health (www.eddmaps.org/: Last Access Oct. 11, 2012).

Scientific and Common Name Asian clam

(Corbicula fluminea)

Physical Description A small (+/-30 mm), light brown clam with light blue or light purple on the interior of the shell.

Origin Southern Asia west to the eastern Mediterranean ; Africa, except in the Sahara desert; and southeast Asian islands south into central and eastern Australia (Morton 1986).

Habitat The Asian clam is a filter feeder that removes particles from the water column. It can be found at the sediment surface or slightly buried. Its ability to reproduce rapidly, coupled with low tolerance of cold temperatures (230C), can produce wild swings in population sizes from year to year in northern water bodies. Both yellow and brown morphs are simultaneous hermaphrodites and brood their larvae in the inner demibranchs (Qiu et al. 2001). The life span is about one to seven years.

Ecosystem Impact The most prominent effect of the introduction of the Asian clam into the United States has been biofouling, especially of complex power plant and industrial water systems (Isom et al. 1986; Williams and McMahon 1986). It has also been documented to cause problems in irrigation canals and pipes (Prokopovich and Hebert 1965; Devick 1991) and drinking water supplies (Smith et al. 1979). It also alters benthic substrates (Sickel 1986), and competes with native species for limited resources (Devick 1991).

New Zealand mudsnail (Potamopyrgus ntipodarum)

A small (4-5 mm) snail with a narrow, variably colored shell of gray to dark brown with a right-handed coiling of 5-6 whorls

Indigenous o brackish and fresh waters of New Zealand.

Variable substrate within brackish and fresh waters that have calcium > 7ppm, pH >6.9, salinity 0-35ppt, temperature 034C.

Can reach high densities (5k750k/sq meter), that result in decreased densities in native fauna, and may impact fisheries. Also known to foul water supply lines.

NYS Documented Locations Where Species are Established Cayuga Lk, Chenango R, Susquehann a R, Owasco Lk, Chautauqua Lk, Lk Erie Chenango R, Mud Ck, Massapequa Lk, Massapequa Creek, Erie Can, Castle Ck, Ramapo R, Schenevus CK, Unadilla R, Seneca Lk, Tioga River, Carlls R, Nissequogue R, Catatonk Ck, Susquehann a R, Lake George, Champlain Canal, Troublesome Bk., Nissequogue R, Catatonk Ck, St. Lawrence River, Lake Ontario, Lake Erie

Physical Description Origin Dreissena A small (+/- 20 bugensis is mm) mussel (Dreissena bugensis with color indigenous to Andrusov) the Dneiper patterns that vary widely River drainage of Ukraine and having black, cream, or white Pontobands and Caspian rounder in Sea. shape than a zebra Mussel (Claudi and Mackie 1994).

Scientific and Common Name Quagga mussel

Habitat They are not generally found in lakes near shore in shallow water due to wave action. The quagga mussel can inhabit both hard and soft substrates, including sand and mud, down to depths of 160 m and possibly deeper. The maximum density of quagga mussels in Lake Michigan is at 31-50 m (T. Nalepa, pers. comm.) Zebra Mussels generally found within 2 to 7 meters of the water surface but have been attach to rock or gravel substrates, forming broad mats up to 10 to 15 cm in thickness. Zebra Mussels will also attach themselves to vegetation. Colony densities may reach 20,000 per square meter.

Ecosystem Impact Quaggas are prodigious water filterers, removing substantial amounts of phytoplankton and suspended particulate from the water. As such, their impacts are similar to those of the zebra mussel. By removing the phytoplankton, quaggas in turn decrease the food source for zooplankton, therefore altering the food web. Zebra Mussels can dramatically increase water clarity and significantly reduce lake productivity, changing aquatic plant and animal habitat value. Zebra mussels are notorious for their biofouling capabilities by colonizing water supply pipes of hydroelectric and nuclear power plants, public water supply plants, and industrial facilities. They colonize pipes constricting flow, therefore reducing the intake in heat exchangers, condensers, fire fighting equipment, and air conditioning and cooling systems.

NYS Documented Locations Where Species are Established Lake Ontario, Seneca Lk, St. Lawrence R, Cayuga Lk, Lake Erie, Niagara R, Erie Canal, Oneida Lk, Onondaga Lk, Skaneateles Lk, Canandaigua Lk, Oak Orchard Ck, Mohawk R, Keuka Lk,

Zebra Mussel

(Dreissena polymorph a)

A small (+/- 15 mm) They can usually be identified by striping on their shells, although this pattern varies greatly to the point that some shells have little if any noticeable striping.

Zebra Mussels native of the PontoCaspian region of Eastern Europe and western Asia the Black, Caspian and Aral Seas and the Ural River drainage.

Lake Erie, Lk Ontario, Lk Chautauqua, Finger Lakes, Erie Canal, Oak Orchard Ck, Niagara R, Genesee R. Hemlock Lk, Honeoye Lk, Conesus Lk, Silver Lk, Oswego R, Owasco Lk, Otisco Lk, Susquehann a R, Cross Lk, Seneca R, Oneida Lk, Otsego Lk, Eaton Res, Canadarago Lk, Leland Lk, Cazenovia Lk, Goodyear Lk, Hinckley Res, Onondaga Lk, Tompsons Lk, Hudson R, Mohawk R, Ballston Lk, Saratoga Lk, Hedges

Scientific and Common Name

Physical Description

Origin

Habitat

Ecosystem Impact

Alewife

(Alosa pseudoharengus)

The alewife is a small (+/- 40 cm) herring with a dark dorsal side, bluish to greenish, and light sides with horizontal darker stripes.

Atlantic Coast from Red Bay, Labrador, to South Carolina; many landlocked populations (Page and Burr 1991).

The alewife is found in rivers and lakes along the eastern coast of North America, from Newfoundland to South Carolina, and the adults live in coastal marine waters 56 to 110 m (180 to 350 ft) deep. Landlocked populations exist in several Ontario and New York lakes. Since the Welland Canal was built in 1824, the alewife has spread throughout the Great Lakes.

Blueback herring

(Alosa aestivalis)

Blueback herring are (+/40 cm ) long, silvery in color, has a series of scutes (modified scales that are spiny and keeled) along its belly, and is

Atlantic Coast from Cape Breton, Nova Scotia, to the St. Johns River, Florida. Ascends coastal rivers during spawning season (Page

Anadromous; living in marine systems and spawning in deep, swift freshwater with a hard substrate. Migrate to spawning grounds in the spring. Usually spawns later in the

Presence of the alewife could restructure a lake's food web, leaving less food for native species (USEPA 2008). Disappearance of native planktivorous salmonids, such as whitefish, in the Great Lakes has been attributed in part to the introduction of alewife, which reduced zooplankton populations (Crowder and Binkowski 1983; Todd 1986; Page and Laird 1993). Unknown, very likely to find suitable habitat throughout the Great Lakes system. GARP models predict it could find the entire region as suitable habitat, except possibly

NYS Documented Locations Where Species are Established Lk, Battenkill R, Glen Lk, Lk George, Lk Champlain, Black Lk, St. Lawrence R. Schroon Lk, Lk Ontario, St Lawrence R, Lk Erie, Finger Lks, Lk Champlain, Upper Saranac Lk, St Trgis R, Big Moose Lk, Wookhull Lk, Otisco Lk, Otsego Lk, Saratoga Lk, Seneca Lk, Hudson R, Mohawk R, Oswego R, Ballston Lk, Round Lk. Schroon Lk, Lk Ontario, St Lawrence R, Lk Erie, Finger Lks, Lk Champlain, Upper Saranac Lk, St Trgis R, Big Moose Lk, Wookhull Lk, Otisco Lk, Otsego Lk, Saratoga Lk, Seneca Lk, Hudson R, Mohawk R, Oswego R, Ballston Lk, Round Lk.

Lake Ontario, Oswego River, Oneida Lk, Mohawk R (Utica & Albany), Lake Champlain

Scientific and Common Name

Grass carp

(Ctenopharyngodo n idella)

Physical Description characterized by deep bluish green backs. The most distinguishing characteristic of this species is the black to dusky in color of its peritoneum (the lining of the abdominal cavity).. Jenkins and Burkhead (1994); Owens et al. (1998); Page and Burr (1991); Smith (1985); Whitehead (1985). Although grass carp are related to both common carp and goldfish, distinct differences exist both in appearance and feeding habits. Grass carp are 125 cm. lack the barbels and spiny dorsal and anal fin rays characteristic of goldfish and common carp, bearing a closer resemblance to a large creek chub or common shiner. Coloration of the fish ranges from dark grey to golden brown on the back, blending to white on the belly.

Origin and Burr 1991).

Habitat spring than the alewife, when water temperatures are a bit warmer. During spawning, many eggs are deposited over the stream bottom where they stick to gravel, stones, logs, or other objects. Juveniles spend 37 months in freshwater, then migrate to the ocean (Yako et al. 2002).

Ecosystem Impact the deeper waters of Lake Superior (USEPA 2008). If blueback herring became established in Lake Ontario, they could spread to other Great Lakes and impede recovery of depressed populations of indigenous fishes such as cisco and lake trout (Owens et al. 1998). Cold water may prevent its establishment.

NYS Documented Locations Where Species are Established

Typical habitat includes quiet waters, such as lakes, ponds, pools, and backwaters of large rivers, and individuals generally do not travel long distances except for the annual spawning migration (Mitzner 1978; Nixon and Miller 1978; Bain et al. 1990).

Typical habitat includes quiet waters, such as lakes, ponds, pools, and backwaters of large rivers, and individuals generally do not travel long distances except for the annual spawning migration (Mitzner 1978; Nixon and Miller 1978; Bain et al. 1990). Triploid grass carp are a new aquatic vegetation control available to New York pondowners (NYSDEC Website).

Various authors (e.g., Shireman and Smith 1983; Chilton and Muoneke 1992; Bain 1993) have reviewed the literature on grass carp; most also discuss actual and potential impacts caused by the species' introduction. Negative effects involving grass carp included interspecific competition for food with invertebrates (e.g., crayfish) and other fishes, significant changes in the composition of macrophyte, phytoplankton, and invertebrate communities, interference with the reproduction of other fishes, decreases in refugia for other fishes. Chilton and Muoneke (1992) reported that grass carp seem to affect other animal

Lower Hudson R (stocked), upper Susquehann a drainage (stocked), Lake Ontario at Rochester (stocked), Lake Mahopac (established), Belmont Lake (established), Long Island waters (stocked), Barney Road Pond, Clifton Knolls Development , Clifton Park (stocked), Beechwood Road Pond, Clifton Knolls Development , Clifton Park (stocked), Par Del Rio Road Pond, Clifton Knolls Development , Clifton Park (stocked),

Scientific and Common Name

Physical Description

Origin

Habitat

Northern Snakehead Fish

(Channa argus)

Northern Snakehead fish are long, thin fish with a single dorsal fin running the length of the fish. Also has a single long anal fin similar to native species, the bowfin (Amia calva). Overall color is brown with dark blotches. It has a somewhat flattened head with eyes located in a dorsolateral position on the anterior part of the head; anterior nostrils are present and tubular; dorsal and anal fins are elongated, and all fins are supported only by rays (Courtenay and Williams 2004).

The northern snakehead is an invasive fish native to China, Russia and Korea.

stagnant shallow ponds, swamps and slow streams with mud or vegetated substrate, with temperatures ranging from 0 to >30oC.

Ecosystem Impact species by modifying preferred habitat, an indirect effect. However, they also indicated that grass carp may directly influence other animals through either predation or competition when plant food is scarce. These predatory fishes compete with native species for food and habitat. Juveniles eat zooplankton, insect larvae, small crustaceans, and the fry of other fish. As adults they feed mostly on other fishes, with the remainder of their diet comprised of crustaceans, frogs, small reptiles, and sometimes small birds and mammals

NYS Documented Locations Where Species are Established

Two populations of this airbreathing predator have been identified in New York State; one in two connected ponds in Queens, NYC and one in Ridgebury Lake in the Town of Wawayanda, Orange County.

Maximum size exceeds 85 cm (33 inches). Round gobys are +/- 17.8 cm long. Young round gobies are solid slate gray. Older fish are blotched with black and brown and have a white to greenish dorsal

Round goby

(Neogobius melanostomus)

Eurasia including Black Sea, Caspian Sea, and Sea of Azov and tributaries (Miller 1986).

The round goby perches on rocks and other substrates in shallow areas, yet it has also been reported to flourish in a variety of habitat types including open sandy areas and

The numbers of native fish species have declined in areas where the round goby has become abundant (Crossman et al., 1992). This species has been found to prey on darters, other

Tonawanda Ck, Lk Erie, Seneca R, Buffalo R, Niagara R, Mud Ck, Woods Ck, Lk Ontario, St. Lawrence River, Stony Ck (Jefferson

Scientific and Common Name

Physical Description fin with a black spot at the posterior base. This goby is very similar to native sculpins but can be distinguished by the presence of fused pelvic fins (sculpins have two separate fins) (Marsden and Jude 1995; Hubbs et al. 2004).

Origin

Habitat in abundant aquatic macrophytes (Jude and DeBoe 1996; Clapp et al. 2001) .

Sea Lamprey

(Petromyzon marinus)

Sea lamprey is a cartilaginous fish +/- 64 cm without jaws. This species has two close dorsal fins, no paired fins, seven gill openings, and a large round mouth with sharp, curved teeth. (Page and Burr 1991; Jenkins and Burkhead 1994).

Atlantic Coast from Labrador to Gulf of Mexico, Florida; landlocked in Great Lakes and several New York lakes. Also along Atlantic coast of Europe and Mediterranean Sea (Page and Burr 1991).

Rudd

(Scardinius erythrophthalmus)

The rudd is +/48 cm long, somewhat stocky, deepbodied fish with a forked tail, and the mouth is distinct with a

Western Europe to the Caspian and Aral sea basins (Berg 1949; Robins et al. 1991b).

Sea lamprey, like many salmon, are "diadromous". They spend the early stages of their life in streams and rivers. The middle stage of their life is spent in the saltwater of the ocean or in a large freshwater lake. Then they return as breeding adults to spawn in the freshwater streams and rivers, and die shortly after spawning. Sea lamprey in Lake Champlain take about six years to complete this life cycle. Rudd is a benthic cyprinid fish with omnivorous feeding habits and a lifespan of up to 15 years. Nurminen et al. (2003) found the

Ecosystem Impact small fish, and lake trout eggs and fry in laboratory experiments. They also may feed on eggs and fry of sculpins, darters, and logperch (Marsden and Jude, 1995) and have also been found to have a significant overlap in diet preference with many native fish species. They compete with rainbow darters (Etheostoma caeruleum), logperch (Percina caprodes), and northern madtoms (Noturus stigmosus) for small macroinvertebrate s (French - Jude, 2001). Attack and parasitic feeding on other fishes by adult lampreys often results in death of the prey, either directly from the loss of fluids and tissues or indirectly from secondary infection of the wound (Phillips et al. 1982).

NYS Documented Locations Where Species are Established County), Mill Creek (Monroe County), Genesee R, Eighteen Mile Ck, Ellicott Ck, Tonawanda Ck, Onondaga Lk, Seneca R., Johnson Ck (Orleans County) Cayuga Lk, Coles Ck, Tibbits Ck, Erie Canal.

Lk Erie, Lake Champlain

Unknown. In a laboratory setting, Burkhead and Williams (1991) demonstrated that rudd readily hybridize with native golden

Central Park Lake, New York City (Myers 1925); RoeliffJansen Kill portion of the

Scientific and Common Name

Physical Description steeply angled protruding lower lip. The scales are robustly marked, the back is dark greenishbrown, and the sides are brassy yellow tapering to a whitish belly. The pectoral, pelvic, and anal fins are bright reddish-orange, and the dorsal and tail fins are reddish-brown (PA Sea Grant 2003).

Origin

Habitat rudd diet to primarily contain various macrophytes, bryophytes, and filamentous algae along with some animal material and detritus. Rudd was more zooplanktivorous in spring and autumn and less in summer and show a size-dependent diet shift from microcrustaceans while small, to macroinvertebrate s at larger sizes (Garcia-Berthou and MorenoAmich 2000).

Ecosystem Impact shiner, Notemigonus crysoleucas, a primary forage species of many native game fishes. As such, the probability exists that rudd introduced to open waters will hybridize with golden shiner, with unknown consequences to wild populations of the native species. First generation hybrids offspring should show heterosis (or hybrid vigor), but the "genetic pollution" in subsequent generations could prove detrimental due to a variety of factors, for instance spawning behavior and recruitment success, and general loss of fitness (Burkhead and Williams 1991; Courtenay and Williams 1992). It is possible that the presence of E. coregoni and that of Zebra mussel veligers (Dreissena polymorpha) in the zooplankton in Lake Ontario could have aided the establishment of the exotic blueback herring (Alosa aestivalis). E. coregoni also serves as a food item to introduced alewife (A. pseudoharengus) and the introduced spiny waterflea (Bythotrephes longimanus) in the

Water Flea

(Eubosmina coregoni Baird)

The water flea is +/- 0.2 to 0.8 mm Females of this water flea exhibit larger and more variable traits with respect to the carapace and antennules than do males. The females large antennules are located anteriorly and ventrally. The females postabdominal claw is emarginate near the tip and has proximal

Eubosmina coregoni is native to Europe (Haney and Taylor 2003).

The distribution of E. coregoni varies seasonally in the Great Lakes. In Lake Michigan, it occurs in the nearshore region at 510 m from the surface in fall and winter, but more frequently at 20 30 m depth in the height of the summer. In the same lake, it is relatively uniformly distributed horizontally in fall and winter, but in summer it occurs significantly more frequently in water 018 km from

NYS Documented Locations Where Species are Established Hudson River, Copake Lake, Robinson Pond north of Copake, Cascadilla Creek near Ithaca in the Great Lakes basin in the early 1950s (Courtenay et al. 1984, 1986). Lake Ontario and the St. Lawrence River, Chateaugay Lake, and a population found in Oneida Lake, Lake Ontario drainage as well as collections from the Hudson River in Columbia County, Ringneck Marsh in Genesee County, Schroon Lk (Whittier et al. 2000). Lk Ontario, Lk Erie, Ensign Pond, Franklyn Falls, Delta Res, Cross Lk, Otsego Lk, Snyders Lk, Blenheim Gilboa Res,

Scientific and Common Name

Fishhook Waterflea

(Cercopagis pengoi)

Physical Description pecten only, with 35 short spines. That of the male becomes very narrow distally. The anterior sensory bristle of this species is near the end of the rostrum and close to the attachment of the antennules. There is no mucro or the mucro is extremely small. The lateral headpore is close to the attachment of the mandibles but relatively far from the headshield (Deevey and Deevey 1971; Pennak 1989; Dodson and Frey 1991; Lord et al. 2006). Body size from 13 mm in length without tail, 613 mm with tail; tail has three pairs of barbs and a characteristic loop near the end

Origin

Habitat shore than in open water. When it occurs predominantly at the surface in Lake Michigan, E. coregoni is an important food item for such fish species as bloater (Coregonus hoyi) (Gannon 1975, 1976; Evans et al. 1980; Crowder and Crawford 1984).

Ecosystem Impact Great Lakes (Mills et al. 1995; Molloy et al. 1997; Grigorovich et al. 1998).

NYS Documented Locations Where Species are Established

Black, Caspian, Azov, and Aral seas of Europe and Asia (Makarewicz et al. 2001)

Cercopagis pengoi lives in brackish and freshwater lakes. It exhibits diurnal vertical migrations in its native range and feeds on other zooplankton

Waterflea

(Daphnia galeata Sars)

This waterflea is 3.5 mm and has a short and prominent antennae

Daphnia g. galeata is native to the Palearctic region, in

Daphnia g. galeata is a planktonic species that prefers large lakes. However,

Cercopagis pengoi is a consumer of other zooplankton. As such it competes with other planktivores of the Great Lakes, including the alewife (Alosa pseudoharengus) and rainbow smelt (Osmerus mordax) (Bushnoe et al. 2003). Its long spine makes it less palatable to planktivorous fish. For these reasons C. pengoi could have a serious effect on the food supply of planktivores (Bushnoe et al. 2003).. After D. g. galeata was introduced to Lake Erie it rapidly hybridized with native D. g.

Fishhook waterfleas were first discovered in Lake Ontario in 1998, then spread to parts of lakes Michigan, Erie, and the Finger Lakes of New York (Sea Grant Minnesota Website)

Onondoga Lk, Oneida Lk,

Scientific and Common Name

Physical Description mound. Its helmet is narrow, pointed at the top, and somewhat undulating along the margins. The rostrum is blunt and obtuse. The ventral side of the head is convex above the optic vesicle and concave behind it. These features are important to note in order to avoid confusing D. g. galeata with the native North American subspecies, D. g. mendotae (Brooks 1957; Glagolev 1986; Taylor and Hebert 1993). Bloody red shrimp 6 to 13 mm freshwater shrimp can be ivory-yellow in color or translucent, but exhibits pigmented red chromatophore s in the carapax and telson (Janas and Wysocki 2005; Salema and Hietalahti 1993). The intensity of coloration varies with contraction or expansion of the chromatophore s in response to light and temperature conditions; in shaded areas, individuals tend to have a deeper red color (Ketelaars

Origin northern Africa, Europe, and Asia north of the Himalayas (Taylor et al. 1996).

Habitat some populations are found in ponds, relatively lentic rivers, and hyporheic zones, or regions of groundwater recharge. Many populations occur in eutrophic habitats.

Ecosystem Impact mendotae. Hybrid clones are now very common, especially during the summer months in Lake Erie (Taylor and Hebert 1993).

NYS Documented Locations Where Species are Established

Bloody red shrimp

(Hemimysis anomala G.O. Sars)

Hemimysis anomala is native to freshwater margins of the Black Sea, the Azov Sea and the eastern PontoCaspian Sea. It has historically occurred in the lower reaches of the Don, Danube, Dnieper and Dniester rivers.

Most mysid species are found in marine environments, but 3% (25 species) inhabit fresh to brackish water. Hemimysis anomala is a brackish-water mysid able to adapt to freshwater environments (Pienimki and Leppkoski 2004; Jazdzewski et al. 2005). It tolerates salinity concentrations of 019 ppt (Bij de Vaate et al. 2002; Borcherding et al. 2006) and prefers water temperatures of 9 20C. Populations may survive temperatures of 0C over winter, but not without substantial mortality

Ponto-Caspian mysids differ from the North American mysid Mysis relicta, by their adaptation to warmer temperatures (Bondarenko and Yablonskaya 1979). Therefore, H. anomala could become abundant in many areas of the Great Lakes that are currently devoid of mysids. Judging by its impacts in some European reservoirs (Ketelaars et al. 1999), H. anomala may reduce zooplankton biomass and diversity in these areas, with cladocerans, rotifers and ostracods being most affected. H. anomala may

Lake Ontario, Seneca Lake

Scientific and Common Name

Physical Description et al. 1999; Pothoven et al. 2007; Salemaa and Hietalahti 1993). Juveniles are more translucent than adults (Ketelaars et al. 1999).

Origin

Habitat (Borcherding et al. 2006).

Chinese mitten crabs

(Eriocheir sinensis)

Claws equal size with white tips and hair, Carapace (shell) up to 4 inches wide; light brown to olive color, Eight sharp pointed walking legs; no swimming legs

Pacific coast of China and Korea.

These crabs may be found in both freshwater and salt water. They are walking crabs that can emerge from the water to move upstream of barriers and are capable of moving several hundred miles upstream from saltwater. They spend most of their lives in freshwater rivers, migrating to brackish or salt water to reproduce. The young move upstream, sometimes spending 2 - 5 years in freshwater.

Ecosystem Impact compete with, or prey upon, other invertebrate predators, such as Bythotrephes longimanus and Leptodora kindti. Its omnivory may also reduce local phytoplankton if small-sized juvenile mysids are abundant (Ketelaars et al. 1999). Hemimysis feeds rapidly, even at low prey densities, and its fecal pellets may alter the local physico-chemical environment (Ketelaars et al. 1999; Olenin and Leppkoski 1999. These crabs are aggressive and may compete with our popular native blue crab in the Hudson River. Their burrowing habits may threaten stream bank and earthen dam stability and promote erosion and habitat loss (NYSDEC Website)

NYS Documented Locations Where Species are Established

Hudson River near Nyack in 2007. Since then numerous mitten crabs have been collected in the river from near Albany to the mouth at New York Harbor (M. DuFour, pers. comm.)

Appendix H Hazardous Analysis Control Countermeasure Plan (HACCP)

Hazardous Analysis Control Countermeasure Plan


Introduction The Hazardous Analysis Control Countermeasure Plan (HAACP) process is the method that DEC requires to be used to assess invasive species risks. Each plant or animal is assigned an invasive rating that accounts for its biological capability to successfully reproduce in NYS or its ability to spread. The assessment identifies vectors or transport mechanisms that are the original source of invasive species. The focus on AIS transport has traditionally been on movement related to human transport associated with recreational and commercial activities. AIS transport via ship ballast has introduced a large number of non-native species into the United States and to Europe (USEPA, 2012). HACCP is also designed to assess the probability that AIS is transported by animals. Many waterways are connected, therefore, animals are fairly free to move along these interconnected systems as is the case with the Asian carp and Rouffe (USEPA, 2012). The significance of wildlife related transport is very complex and unclear as to the importance of this transport mechanism. The USEPA identifies 20 AIS pathways but doesnt include bird transport (USEPA, 2012). The HACCP process requires related assessments of vector movement, evaluate risk, and the number and frequency of introductions need to be completed in detail for each species. In general terms, the most important factors are in proximity to waterbodies with AIS with high invasive ratings. The National Invasive Species Council Focus Group Conference Report and Pathways Ranking Guide (2005) identifies three major potential pathways for AIS transport and spread: transportation-related, living industry, and miscellaneous. The transportation-related and living industry pathways have 61 different pathways that aid in the movement of AIS. The Guide reports that the AIS transport by ship ballast has introduced a significant number of non-native species into the United States and to Europe (USEPA, 2012). Only one pathway is reported that is associated with the spread of AIS by waterfowl and it is identified as a natural movement pathway (Orr, A.S. Green, and R. Lukens, 2005). The USEPA identifies 20 AIS pathways but does not include bird transport (USEPA, 2012). HACCP Process The HACCP process is shown in Appendix G. Tasks include: Assess the current situation; Find, develop or refine current approaches; Identify the threats; Identify pathways (vectors); Assess the risk (how often do AIS introductions occur, how large are the AIS introductions, and how fast do AIS reproduce); Evaluate the solutions Will the public accept solutions? Is it effective? Does it intercept the vector? Can it be sustained? What will it cost?

Invasive Species HACCP


Invasive Species

Vectors or HACCP Targets

Waste Disposal

Excavation Earthmoving

Vectors / Activity Commercial Exotic Species Trade Boating

Recreational Boating

Wildlife Weather

Identify Potential Hazards Vector Movement Risk Evaluate Risks of Invasive Movement by Vector or Activity

Vector Delivery Large Numbers of Introductions Frequency of Introductions

Hazard Analysis Invasive Species Characteristic High Survivability Flexible Biology (able to live everywhere)

HACCP Risk Hazard Management Critical Control Points Where can the Invasives be Stopped?

Assemble a HACCP

Appendix I Procedures for Clean-Drained- Dry

Source: Uniform Minimum Protocols and Standards for Watercraft Interception Programs for Dreissenid Mussels in the Western United States (UMPS II) An updated version of the original 2009 document

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