On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide. My posts describing and commenting on the strategies are all available here. This post addresses the Agriculture and Forestry strategy recommendations.
I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker. In this post I will briefly summarize the schedule and implementation components but I provide more details at CLCPA Summary Implementation Requirements. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, summarized some of the meetings and complained that its advocates constantly confuse weather and climate. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Agriculture, Forestry and Other Land Use Emissions
According to Part 496 the 1990 Agriculture, Forestry and Other Land Use (AFOLU) greenhouse gas emissions in 1990 by IPCC in GWP20 totaled 17.13 million metric tons (MMt) of CO2e broken down as 0.05 MMt of CO2, 13.07 MMt of CH4 and 4.01 MMt of N2O. According to the presentation, in the 2018 preliminary draft emissions inventory there were a total of 24 MMt of CO2e. In 1990 emissions from this sector were 4.2% of the state total and in 2018 they were 6.4%.
There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG Emissions by 2050. The emission reduction goals for this advisory panel are a 15% reduction from current levels by 2030 and a reduction of 30% which is a return to 1990 levels by 2050. There is an additional ambition of a 45% reduction by 2050. Unfortunately, the panel estimates that emissions will be 20 MMt of CO2e in 2030 an increase of 3 MMt over 1990 emissions. In 2050 two emission estimates are given that range from no change relative to 1990 to a 4 MMt of CO2e reduction in 2050 that is only a 24% decrease.
Note that the 85% reduction by 2050 target includes a goal to go net-zero. In order to meet that goal this sector is supposed to increase carbon sequestration from the current level of 33 MMt of CO2e to 60 MMt of CO2e. Included in the sequestration goal is for no net loss of forests from 1990 levels. The pa
Agriculture and Forestry Strategies
According to the meeting minutes, the advisory panel proposed the following enabling strategies:
- Agriculture: Agricultural Environmental Management (AEM) planning for climate mitigation/adaptation (“carbon farm planning”), benchmarking and monitoring of GHG mitigation, carbon sequestration and adaptation performance across applicable management areas of farms;
- Avoided Land Conversion, bolstering local agricultural economies, and enhanced local government planning for land conversion;
- Forest Management: expanding funding for peer-reviewed climate and forest carbon research, developing and supporting workforce development and training programs, and developing forest- based outreach, education and marketing techniques;
- Bioeconomy: expanding markets for sustainably-harvested durable wood products; sustainable biomass feedstock action plan for 2050 hard-to-decarbonize products; increasing market access for New York low-carbon products that achieve the climate and social justice goals of the Climate Act; financial and technical assistance for low-carbon product development; bio-based products research, development and demonstration; and net negative carbon dioxide removal.
I am not going to critique these strategies individually because it would take far too long. Instead, I will comment on a few things with an emphasis on inconsistencies and implementation issues. I made comments on the draft strategies and will note whether the panel addressed them.
One of the reasons that I don’t have time to critique the strategies is because the use of jargon would take so long to research. For example, “carbon farm planning” is a new concept to me and the strategy recommendations did not explain what this means in this context. An internet search finds this definition: “Carbon farming combines cutting-edge agricultural practices with the tools of ecological design to build healthy soil and profitable farms and ranches, as well as improving the rate at which carbon dioxide is removed from the atmosphere and converted to plant material and/or soil organic matter.” Frankly trying to unravel what that means in the context of the CLCPA does not appeal.
The alternative manure management strategy is a mystery to me because § 75-0109, (2) (b) states “Include legally enforceable emissions limits, performance standards, or measures or other requirements to control emissions from greenhouse gas emission sources, with the exception of agricultural emissions from livestock.” What is the point of alternative manure management if livestock emissions are exempt? I made the comment and because there is no response to comments document, I have no idea what their rationale was to do this anyway.
I agree that the enabling strategies of avoided forest conversion and avoided agricultural land conversion are important and should be included. However, the CLCPA electric sector targets are going to require enormous amounts of solar and wind energy development. I commented that this factor has to be addressed and it was not mentioned as an issue. If there was a response to comments document then they would have had to explain why this was ignored.
This sector is a relatively small actor relative to total New York GHG emissions but it is notable that the strategies are expected to actually increase 2030 emissions from the 1990 baseline rather than reduce emissions consistent with the CLCPA target of a 40% reduction by 2030. Clearly, this panel recognizes that there are limits to what can be achieved even though the results are disappointing.
There is a big flaw in two of the enabling strategies. There is no recognition or plan to address the extraordinary buildout of wind generation projected by the Analysis Group – 35,200 MW compared to 5,905 MW in the last DPS impact statement that evaluated wind energy cumulative impacts. I extrapolated results from several projects to estimate the potential cumulative impacts and found that if all the wind projects are built on agricultural land, then between 12% and 56% of the agricultural lands will be covered with wind turbines. Of course, it is more likely that wind turbines will be sited on ridge lines but that will affect forest land use. Nonetheless that study also projected 39,262 MW of utility scale solar that will have to go somewhere. The enabling strategies inexplicably do not address these potential impacts in their enabling strategies for avoided forest conversion and avoided agricultural land conversion.