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ESFPA E-News
Volume 3 - Issue 24
July 14, 2022
DEC Publishes 480-A Regulatory Amendments
In the July 13th State Register DEC published proposed regulatory amendments to the 480-A Forest Tax Law program (6 NYCRR Part 199). See pages 8 (14 in the PDF) – 10 (16 in the PDF) for the text of the regulation. Additional regulatory documents on the rule can be found here and the press release.
The proposed changes include:
- Extending the period an approved forest management plan would cover from 15 years to 20 years and requiring fewer plan updates;
- Providing more flexibility to enrolled landowners to complete forestry treatments by changing the work schedule from year-by-year deadlines to a 10-year work window;
- Strengthening forest sustainability requirements on enrolled lands, such as explicitly banning high grading and requiring efforts to establish adequate forest regeneration. High grading involves removing most of the commercially valuable trees at the expense of future growth and future financial return, often leaving a forest in poor condition; and
- Establishing a training requirement for consulting foresters working with Forest Tax Law clients to help set clear expectations and standardize Forest Tax Law administration across the state.
The proposed changes would go into effect on March 1, 2023.
DEC is holding two virtual public comment hearings on Sept. 13, and will be accepting public comments through Sept. 19. The public is encouraged to submit comments in writing to: NYSDEC Private Lands and Forest Utilization Section, Bureau of Forest Resource Management 625 Broadway, Albany, NY 12233-7254 or by email to: bslmregs@dec.ny.gov. The virtual public comment hearings will be held on Sept. 13, at 1 p.m. and 6 p.m. For more information about the new and revised regulations, as well as how to participate in the public comment hearings, visit DEC's website.
ESFPA will be compiling comments on the proposed rule as well as testifying but we also encourage individuals to comment and testify. There are some provisions of the rule we have seen before in draft form and some new proposals. We also have concerns over some of the terminology used and lack of clarity in some of the proposal. If you have any questions or would like to share comments, please do not hesitate to contact us.
Climate Action Council Meets
The Climate Action Council (CAC) met on Monday, July 11th for the first time since the ending of the draft Scoping Plan public comment period on July 1st. You can review the slide deck and recording of the meeting here.
In regards to public comments, over 35,000 comments were received on the draft Scoping Plan. Over 25,000 of those comments were “form filings” meaning that comments were sent in following a provided form email request.
ESFPA comments were submitted on June 29th and can be found here.
The CAC plans to have a summary of all comments received for their August meeting.
Other topics of the July 11th CAC meeting included:
- Update of the public review of the draft Disadvantaged Communities Barriers and Opportunities Report which can be found here.
- Discussion of the proposed criteria for the designation of Disadvantaged Communities, which are currently out for public comment. The CAC has extended the comment period to August 5th.
- There were presentations from labor representatives on workforce related issues of the recommendations in the draft Scoping Plan. Labor has several concerns with the impact recommendations will have on existing fossil fuel-based sectors and manufacturing in general. Several comments reflect some of the same concerns we raised in our comments.
- Report outs on the three Subgroups that are meeting through the summer:
- Alternative Fuels – looking at the role of alternative fuels in the Scoping Plan, including a lot on biofuels across the economy.
- Gas Transition – looking at how far will the Scoping Plan go in transitioning away from fossil based natural gas and what, if any role, for renewable natural gas.
- Economywide Policy – looking at policies relating to financing implementation of the Scoping Plan through a cap and trade, carbon pricing or other economywide mechanisms.
ENGO and EJ Climate Scoping Plan Comments
Earlier this week we received comments submitted by 58 Environmental Non-Governmental Organizations (ENGOs) and Environmental Justice (EJ) groups. We are providing a copy of the comments submitted by that coalition. The document covers all major sections of the draft Scoping Plan, and while we are still reviewing the document, it reiterates a number of positions and recommendations already presented that the recent public hearings. In their summary, they argue for several broad principles, including the achievement of “environmental justice” (i.e., emission reductions and “green” investments in disadvantaged communities), full electrification and elimination of fossil fuels, and rejection of “false solutions” including biofuels and continued use of wood for energy across sectors. While the document is 174 pages long, within the first 28 pages you can read their overall comments and then their comments on the Agricultural & Forestry recommendations.
The comments take a very pro-forestation position on forests and are extremely critical of the wood products industry and recommendations in the draft Scoping Plan that would encourage more use of wood products in addressing climate change.
We thought these comments would be useful to ESFPA members in understanding other viewpoints being shared with the Climate Action Council. This shows the challenges we will have going forward and certainly presents some challenges for those responding to comments and the deliberations of the Climate Action Council going forward.
House Farm Bill Panel Highlights Wood Products
On Wednesday, the House Agriculture Subcommittee on Conservation and Forestry held a hearing focused on potential forestry related provisions for the 2023 farm bill reauthorization and placed an unmistakable spotlight on the crucial role of wood products to prevent wildfires, capture atmospheric carbon and grow the economy. Rep. Abigail Spanberger (D-VA) presided over the meeting and focused her remarks on the dual economic and environmental benefits of wood buildings. Rep. GT Thompson (R-PA) built on the theme by pointing out that the farm bill should promote the storage of “even more carbon through forest products.” Other support for wood products included robust statements from Reps. Doug LaMalfa (R-CA), Annie Kuster (D-NH), and Trent Kelly (R-MS).
Doug Reed from Green Diamond was an industry representative representing NAFO and testified before the subcommittee. Doug’s testimony focused on NAFO’s top priorities in the farm bill: investments to improve forest carbon data, increasing data on wood buildings, and expanding education on the use of wood. He also mentioned the partnership some NAFO members are developing with the Forest Service to provide private resources, including people, equipment, and knowledge of local terrain and conditions, to fight fire in areas across ownerships.
Rite Hite of American Forest Foundation also testified before the Committee. Rita’s comments focused on the priorities of family forest owners across America.
The following links provide more information about the hearing and will allow you to watch it live or on replay at your convenience:
Real American Hardwood Coalition Launches Website
The Real American Hardwood Coalition (RAHC), a domestic, industry-wide promotion initiative for Real American Hardwood™ products, has launched a website designed to inspire and educate consumers.
“The website takes visitors on a digital journey to learn how and why they should choose Real American Hardwood flooring, cabinetry, millwork, furniture, and other goods for their homes,” says Michael Martin, president and CEO of the National Wood Flooring Association. “Today’s consumers are overwhelmed with product choices and often believe they’re buying natural and renewable hardwood products, when in fact, they’re buying look-alikes such as vinyl and plastic that are manufactured from non-renewable resources. Now, the industry has an informative tool that’s setting the record straight and separating fact from fiction—backed by research and science.”
Designed by CANVAS United—a high-profile agency known for its exceptional creativity, impressive project portfolio, and extensive experience in promoting commodity and agricultural goods—the website educates consumers on the advantages and benefits of Real American Hardwood products in ways that make emotional connections. Interactive site modules engage consumers and compare the appearance, durability, value, home health, and environmental attributes of real wood products to faux, wood-look alternatives. The site also serves as a hub for project inspiration, maintenance tips, and environmental facts, and explores how hardwood is influencing lifestyles and culture in the modern world.
“Our industry has a rich history and compelling stories to tell,” says Dean Alanko, vice president of sales and marketing, Allegheny Wood Products. “The website spotlights the generational, family business that make up our industry. I’m proud of how the website tells these stories and presents information that can make a difference in consumers’ lives and benefit all industry stakeholders.”
AFF Family Forest Carbon Program
We have reported in the past that the American Forest Foundation and The Nature Conservancy will be introducing their Family Forest Carbon Program in New York this year. This week we heard that they will introduce this first in the eastern Hudson Valley in Duchess, Columbia and Rensselaer Counties. Here is a link to this program as it is being rolled out in Eastern MA. Stay tuned for its eventual roll out in NY.
Log-A-Load for Kids Fund Drive Begins at Boonville
For 25 years, New York State Log-A-Load for Kids has participated in a nationwide program to support Children’s Miracle Network Hospitals, and the NYS Committee (i.e. the Mowrey Family) is once again reaching out to the forestry community for support.
One way to participate is at the 2022 NYS Woodsmen’s Field Days. There will be many events going on, including fund drives and raffles. The Committee is looking for donations of goods, services, or loads of firewood to be raffled off at the Woodsmen’s Field Days as well as time at any of the booths.
Any and all items donated are greatly appreciated and help raise thousands of dollars for children in need. Promotional items with company logos are popular and make excellent game prizes. Monetary donations will be used either for the purchase of supplies or will go directly to your local CMN Hospital.
In celebration of New York Log-A-Load for Kids’ 25th anniversary, we are also asking our donors to please consider an additional 25% contribution. We’d like to make this a big year!
Every donation makes a difference. If you are interested in donating or volunteering, please contact Gabriella Ferrera at gabriella@esfpa.org or Eileen Mowrey at emowrey12@gmail.com .
