Agriculture and Forestry Roundtable: Hosted by Environmental Advocates NY, along with Catskill Mountain Keeper, Earthjustice, Northeast Organic Farming Association, and NY Renews, April 21, 2022
My comments on the Agriculture and Forestry Recommendations for the Draft Scoping Plan
Together we face a climate emergency.
The members of NOFA-NY passed a resolution in February calling upon the state and federal governments to declare a national Climate Emergency to communicate the urgency of the climate crisis.
The CLCPA process gives us the opportunity to take strong actions in the hope that it is not too late.
I hope that as many of you as possible will join NOFA-NY and our allies in commenting on the Ag and Forestry recommendations in the Scoping plan. https://nofany.org/advocacy-new-yorks-climate-act/ The Ag and Forestry panel recommendations are very cautious and emphasize making small tweaks to existing systems of industrial-scale farming, with the rationalization is that you can do more to reduce GHG emissions through small improvements to big field crop and processing vegetable farms and the largest livestock farms than by making longer term changes.
Instead, we can take this opportunity to initiate the transformation of NYS agriculture to strengthen the economic, social and environmental viability of family-scale farming and increase social justice and racial equity.
The plan should call for legislation for investments in certified organic and agroecological farms with the goal to convert 25% of NY farmland to organic by 2030 through massively scaled-up technical assistance programs, tax subsidies, and grant funding. The Climate Justice Working Group recommends funding and programs for farms to transition to organic systems and also recommends a tax on fertilizers that could fund this transition. Please note that synthetic nitrogen fertilizers are derived from natural gas and the Scoping Plan does not count the emissions from out of state production of these fertilizers or the nitrous oxide that results from spreading them.
Research shows that organic farming reduces energy use by at least 30% through avoidance of synthetic nitrogen fertilizers, and also increases soil carbon levels, soil stability and fertility, on-farm biodiversity, and crop resilience. By design, organic agriculture builds resilience into the system of food production.
The CLCPA includes a strong mandate for permanence. However, in biological systems the only permanent thing is change.
When farms are going out of business, practices like adding covers and flares to manure pits are no more or less permanent than increasing the use of cover crops and composting. In 2009, there were 5,475 dairy farms in NYS; in 2019, that number had dropped to 3,893 dairy farms. (New York State Dairy Statistics). Not poor farming, but the failing economics of milk pricing are driving smaller dairies out of business and pressuring larger dairies to get even larger.
To ensure that improvements to soil health endure for the foreseeable future and that public investments will be worthwhile, the farmers of this state need to join with all land managers in a culture of soil care with public recognition and support for the many ecosystem services soil health provides: increased soil carbon, reduced net greenhouse gas emissions, improved water quality and water use conservation, improved crop yields, nutrient density and shelf-life, and greater farm resilience in the face of the accelerating climate emergency. A culture of soil care means that farmers, their customers, and our policy makers value soil as a paramount resource.
Along with a goal for converting to organic farming, the plan should set statewide soil health goals to track progress, increase accountability, and ensure the permanence of soil-sequestered carbon.
All agriculture and forestry projects that receive public funding must be required to qualify by using soil health practices as defined in Article 11-B, Agriculture & Markets (AGM) Chapter 69.
The plan must address the many inequities and barriers to success in farming that result from the systemic racism that pervades our society. Just as biodiversity is essential to soil health, social diversity is essential to a healthy and thriving food system.
In Commissioner Richard Ball’s letter introducing the 2021 Diversity and Racial Equity Working Group Report, he underscored the NYS Department of Agriculture’s commitment to building a “stronger, more resilient, and more equitable agricultural community in New York State.” This plan must do more to enable NYSDAM to actualize this commitment. Amust be. M must be
Climate justice and racial justice are mutually reinforcing – to reduce GHG emissions in ag NYS must turn more of the land over to native American, Black and other farmers of color. Agroecological systems originated in indigenous cultures. Current NYS organic and agroecological farmers combine these systems with the latest social and technological innovations to bring greater health to both the farmers and workers who produce food and the eaters who benefit from fresh, local, nutrient-dense food grown in healthy soils.
To make it economically feasible for organic and agroecological farms to survive in the highly concentrated marketplace where farmers are usually price takers, NYS must implement a Payment for Ecosystems Service program that provides income to farmers who regenerate soil while producing food, fiber, building materials, and medicine. A payments program would compensate farmers for the many interrelated and essential ecosystem services that their farms provide and that result in positive outcomes for the climate. There is no agreement yet on how to measure, monitor and verify increases in soil carbon. To ensure more than minimal performance of incentivized practices, we recommend payments to farmers based on outcomes: lower temperatures that result from soil that is covered instead of bare, minimizing leaching of minerals into waterways, reducing odors, cleaner air, the agritourism value of the beauty of a diverse working landscape. Cleaner water, air and increased tourism are all verifiable. The degree of soil coverage can be measured from satellite images. Diversifying a farm’s landscape makes a big difference in ecosystem services. Trees/windbreaks/ponds etc. reduce temperatures, slow winds, filter/infiltrate water, and mitigate climate extremes. Increasing cover cropping and double cropping has a big impact on soil carbon but also on crop yields and quality.
And finally, it is time to end public funding for the liquid manure handling systems that make really large CAFOs possible. In 2017 out of over 4600 dairy farms in New York, only 561 farms had herd sizes over 200 milk cows and only 142 farms had herd sizes over 1000 milk cows. Just 12% of New York dairies account for nearly 70% of New York’s dairy cow population and are responsible for the vast majority of associated methane emissions from both enteric fermentation and manure management. (United States Department of Agriculture, National Agricultural Statistics Service. Census of Agriculture New York, 2017).
As defined by EPA, a CAFO has more than 1000 animal units – over 700 cows. More than half of the methane from cows in CAFOs is generated in the anaerobic manure systems that the Draft Scoping Plan promotes as a climate solution. A disproportionate share of the money for soil conservation in NYS has been used in building liquid manure systems. Even small dairy farms are encouraged to build anaerobic pits.
As the Climate Justice Working Group identifies in their 2021 response to the draft scoping plan, there are much better alternatives to this type of manure storage and handling. We join their call to “Fund transformative practices upstream of manure storage and towards practices that smaller producers can adopt.”
Manure from pastured cows generates less than 2% of the methane from anaerobic liquid manure and ‘dry’ aerobically managed manure only generates about 7% as much methane as anaerobic liquid manure.
The investments that result from the CLCPA scoping plan should accelerate the conversion of NYS to a localized food production/distribution system grounded in family-scale farms.
The wins pile upon one another when we improve food security, reduce GHG emissions, increase climate resilience, improve food quality, strengthen the state’s rural economy, increase farming opportunities by enabling new farmers and particularly farmers of color, to gain access to the resources needed to farm, and protect farmland all in one set of policies. Let us learn from the food chain disasters of the Covid-19 crisis and not simply add good practices to the bad existing system. That will not result in long term solutions that meet the ambitious and socially just goals of the CLCPA.
 “Impose a fee on fertilizers that funds a transition to organic farming. This would meaningfully reduce GHGs and protect precious public waterways and private water wells from runoff “ B- 15
 Peter H. Lehner & Nathan A. Rosenberg, Farming for Our Future: The Science, Law and Policy of Climate-Neutral Agriculture. Environmental Law Institute, 2021, pp. 73 – 7.
 In Farming for Our Future, Lehner and Rosenberg point out that “[C]AFO manure management systems produce much more methane than pasture-based livestock operations. When manure is left as a solid (as naturally happens on grazing lands and pasturelands), it typically decomposes aerobically and produces little to no methane. However, when it is stored or handled in a system that creates an anaerobic environment, such as a lagoon, it releases large amounts of methane. Storage in uncovered lagoons can result in methane conversion rates over 100 times as high as those in pasture and range.” They go on to write that, “Digesters reduce methane emissions when compared to unregulated liquid manure management systems, but liquid manure management systems have the highest per-head methane emission rates among all methods of manure management […] It is not only the most expensive method for reducing manure emissions, but it is also among the least effective” (p. 99, emphasis added, with research citations provided in-text).