Statement -- HRBRRD Meeting on Revised Draft Rules
Peter VanAvery, Batchellerville Bridge Action Committee
Northville Central School
August 1, 2007

I'll begin with Rule 6.6 (Registration on Waiting List and Eligibility). This revised draft rule says that a back-lotter can register on the waiting list for a back-lot access permit as long as his property is within one-mile of the lake as the crow flies.

The current rule, by contrast, specifies that a back-lotter qualifies for the waiting list as long as his property is within one mile of the lake on the odometer. The difference? I know someone who lives on Military Road in Edinburg. By car, he is 6 miles from the lake. As the crow flies, however, he falls well within the one-mile limit. How many other back-lotters fall into this category? 100? 1,000? 10,000? The District says it does not know.

What we do know is that some 300 back-lotters already are on that waiting list, some for years. Is it a good idea to swamp that list with an indeterminate number of additional names? I don't think so. Or does the District have a stealth plan to increase the number of back-lot permits at the expense of front-lotters?

The Advisory Committee approved this rule, as is, by consensus. I was a member of that committee at the time, so I deserve my share of the blame. Fortunately, as Executive Director LaFave is fond of pointing out, the draft rules are a work in progress. Accordingly, I want the District to know that I have changed my mind. I urge others to do the same.

Next, a reality check. Many months ago, the Regulating District told us that its new set of rules would be so concise and so clear that we would seldom need to ask for clarification. The District promised a record-setting racehorse; they delivered a lumbering elephant.

Just compare the revised draft rules with the existing rule book, published in 1993.

The 1993 rule book opens with a lean set of definitions -- just 11 in total. The proposed rule book has 54 definitions -- a 500% increase. The definitions now include such everyday words or phrases as "shoreline," "stairs," "Great Sacandaga Lake," "dock," etc.

The rules themselves have more than doubled in number: 48 rules then and 107 rules now. Many are tough reading. There also are 17 pages of appendixes. Clarity and conciseness have been swamped by turgidity and bloat.

At the final public input meeting in 2006, I urged the District to hire a skilled editor to hammer the new rule book into shape. I repeat that recommendation today. The editor's goal should be to reduce the number of pages by at least 30% by reorganizing and condensing the text, by expunging contradictions, and by communicating in simple English.

But before the District hires that editor, it's got more homework to do. Go back over the comments from the public and the recommendations from your own Advisory Committee. This time, try harder -- much harder -- to respond to what people want. The District claims to have accepted 70% of the Committee's inputs. That's just spin. Not all of the rules have equal weight, and the fact is that the District ignored many of the Committee's key recommendations.

Thank you.