ag_forestry_chapter_nys_cac_comments-82373801e75aa412.pdf

The document argues that New York's Draft Scoping Plan (DSP) relies too heavily on industry-biased accounting and voluntary measures. It recommends prioritizing forest preservation over harvesting, eliminating forest-based carbon offsets, implementing mandatory methane regulations for large concentrated animal feeding operations (CAFOs), and adopting specific statewide targets for soil health practices.

• The authors argue that the Draft Scoping Plan (DSP) mischaracterizes forest carbon cycling by suggesting that increased forest management activities are necessary to maximize sequestration, whereas leaving forests intact generally provides the maximum climate benefit.
• Harvesting forests reduces their capacity to function as a carbon sink, and the resulting carbon debt takes several decades to recover in northeastern forests.
• The document opposes the use of forest carbon sequestration as offsets for fossil fuel emissions, describing such schemes as scientifically unsound and a way for polluters to avoid direct emission reductions.
• Agriculture accounts for 6% of New York's total greenhouse gas emissions, with 92% of those emissions originating from livestock.
• Livestock management emissions in New York have increased by 44% since 1990, contrasting with other sectors where emissions have decreased.
• The authors assert that the New York State Department of Environmental Conservation (DEC) has the legal authority under the Environmental Conservation Law (ECL) to regulate methane emissions from CAFOs as a form of air pollution.
• The document recommends shifting from end-of-lifecycle methane destruction (like digesters) to upstream reduction strategies, such as dry manure management and transitioning to managed-pasture-based farming.
• To reduce enteric methane, the document suggests accelerating the adoption of feed additives and restricting the nontherapeutic use of antibiotics in livestock.
• The authors propose a long-term strategy to reduce herd sizes by promoting dietary changes to reduce demand for dairy and beef products.
• The document recommends setting specific statewide targets for soil health by 2040, including restoring half of lost soil organic carbon and maintaining year-round cover on at least 75% of cropland.
• To reduce nitrous oxide emissions, the document recommends prohibiting winter manure spreading and implementing a phased-in fertilizer fee for excess use.
• The document argues that biomass harvesting and bioenergy are "false climate solutions" because they reduce the forest's capacity to act as a carbon sink and create additional emissions during processing and transport.

APA

Earthjustice (n.d.). ag_forestry_chapter_nys_cac_comments-82373801e75aa412.pdf. https://earthjustice.org/wp-content/uploads/ag_forestry_chapter_nys_cac_comments.pdf

Chicago

Earthjustice. ag_forestry_chapter_nys_cac_comments-82373801e75aa412.pdf. n.d. https://earthjustice.org/wp-content/uploads/ag_forestry_chapter_nys_cac_comments.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=ag_forestry_chapter_nys_cac_comments-82373801e75aa412.pdf |url=https://earthjustice.org/wp-content/uploads/ag_forestry_chapter_nys_cac_comments.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjusticendagforestrychapternyscaccomments82373801e75aa412pdf, author = {{Earthjustice}}, title = {{ag\_forestry\_chapter\_nys\_cac\_comments-82373801e75aa412.pdf}}, publisher = {Earthjustice}, url = {https://earthjustice.org/wp-content/uploads/ag_forestry_chapter_nys_cac_comments.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }