New York’s Climate Act

The New York State Climate Action Council Draft Scoping Plan for implementing the Climate Leadership and Community Protection Act provides a pathway for reaching NY’s ambitious, necessary climate goals. Input from the organic farming community is needed to ensure that the final plan is strong and equitable. The following 6 points were developed by members of NOFA-NY’s policy committee and detail some of the ways we believe agriculture sections of the plan must be strengthened.

We encourage you to incorporate these points into your public comments on the CAC’s draft scoping plan. Throughout April and May, New York’s Climate Action Council will hold 10 public hearings to gather input from the public on the Draft Scoping Plan. Written comments can also be submitted through June 10, 2022.

NOFA-NY’s Key Points on Agriculture in the Draft Scoping Plan

Invest in certified organic and agroecological farms that build soil carbon, increase resilience to extreme weather, and reduce erosion, run-off, and nitrous oxide emissions. 

  • Include a mitigation strategy in the Agriculture and Forestry Sector to convert 25% of NY farmland to organic by 2030 through massively scaled-up technical assistance programs, tax subsidies, and grant funding.  
  • Call for the establishment of a comprehensive soil health program that nurtures a culture of soil care among farmers, their neighbors, and their customers with sustained support from public policy.  
  • Include, in AF12, a requirement that agriculture and forestry projects that receive public funding use soil health practices as defined in Agriculture & Markets (AGM) CHAPTER 69, ARTICLE 11-B, § 151-l
  • Set statewide soil health goals to track progress, increase accountability, and ensure the permanence of soil-sequestered carbon.
  • Discourage the use of synthetic nitrogen fertilizers. The prohibition of synthetic fertilizers in organic production reduces a significant agricultural source of nitrous oxide as well as energy use. According to the EPA, nitrous oxide emissions from soils comprise 50.4% of all domestic agricultural emissions.
  • Include out-of-state production of synthetic nitrogen fertilizers in the greenhouse gas inventory of NY farms.

Address inequities in our farming and food systems including systemic racism, to build a “stronger, more resilient, and more equitable agricultural community in New York State.” (Quote from Commissioner of Agriculture, Richard Ball’s letter introducing the 2021 Diversity and Racial Equity Working Group Report (PDF).)

  • Include a mitigation strategy in Climate-Focused Bioeconomy to create programs and target funding to enable access to land, capital, and farming resources for underserved groups including BIPOC, women, LGBTQIA+, low-income, veterans, beginning farmers, and undocumented farmworkers.  
  • Ensure that at least 40% of all funds expended by the state under this plan are invested in underserved communities.
  • Ensure that members of all underserved communities are able to participate in the design and implementation of all new initiatives. 

Protect and restore our soil resources, and strengthen urban and rural economies, by providing income to those who regenerate soil while producing food, fiber, building materials, and medicine. 

With community involvement, design and implement a Payment for Ecosystems Services (PES) Program that rewards farmers for the many interrelated and essential ecosystem services that their farms provide.

Replace much of the language in AF9 and AF10 with language calling for an end to public investments in technologies, including expensive cover and flare systems and biodigesters, that enable the accelerating concentration of livestock farms, known as Concentrated Animal Feeding Operations (CAFOs).  

  • Regulate and hold accountable the small number of very large NY dairies whose manure storage systems produce the majority of agricultural GHG emissions, while also polluting wetlands and waterways. 
  • Fund transformative practices that work upstream of manure storage, and prioritize practices that smaller producers can adopt.
  • Ensure that Climate Resilient Farming Program funds are directed towards reducing both enteric and manure sources of agricultural methane emissions, and utilize these funds to build climate resiliency rather than entrenching current manure management practices that rely on liquid systems of manure handling and storage.

In NY, CAFOs are regulated by the NYS Department of Environmental Conservation. According to the USDA, 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.

Prioritize preserving farmland and forests through smart growth strategies that provide the maximum climate benefit, over strategies designed to profit the forestry industry like those contained in strategy AF20.

Include a mitigation strategy that reforms state policies and programs to ensure that institutional procurement programs prioritize local economies, animal welfare, environmental sustainability, nutrition, and a valued workforce in alignment with the Good Food Purchasing Program (GFPP) standards.


Tips for Commenting on the Climate Action Council’s Draft Scoping Plan

Between now and June, New York’s Climate Action Council is seeking feedback on their Draft Scoping Plan. Your feedback will affect the Final Scoping Plan, due January 2023, which will ultimately guide the implementation of the nation-leading climate goals set forth under the Climate Leadership and Community Protection Act.

You can comment orally and/or submit longer written comments. See the sections below for guidance.

There are 6 upcoming opportunities to testify at an in-person hearing hosted by the Climate Action Council: 

  • (past) Tuesday, April 5, 2022 , 4:00 PM , Bronx   
  • (past) Wednesday, April 6, 2022 , 4:00 PM , Brookhaven   
  • Tuesday, April 12, 2022 , 4:00 PM , Binghamton   
  • Thursday, April 14, 2022 , 4:00 PM, Albany   
  • Tuesday, April 26, 2022, 4:00 PM, Syracuse   
  • Wednesday, April 27, 2022, 3:30 PM , Buffalo
  • Tuesday, May 3, 2022 , 4:00 PM, Brooklyn
  • Tuesday, May 10, 2022, 4:00 PM, Tupper Lake   

To testify at one of these hearings: 

  1. Review details for the meeting you’ve selected here. 
  2. Pre-register here. Pre-registration is encouraged. Priority in seating and speaking will be given to those who pre-register.
  3. Draft your testimony! You’ll have 2 minutes to speak so having what you want to say written down can help you make sure you get all of your key points in.
  4. First, tell the CAC who you are and why you’re here today!
  5. Then, provide your feedback. The scoping plan is hundreds of pages long but you’ll need to narrow your talking points down to just a few that really matter to you. Please use NOFA-NY’s key points for inspiration. The NY Renews coalition also offers overarching and sector-specific talking points here
  6. Finally, submit your comments in writing. There are no length limits on written comments so add in any language that you were unable to include orally and submit your written comments by June 10, 2022, through this online form, by emailing scopingplan@nyserda.ny.gov, or by mail: Attention: Draft Scoping Plan Comments, NYSERDA, 17 Columbia Circle, Albany, NY 12203-6399 

In May there are two opportunities to testify virtually using WebEx: 

  • Saturday, May 7, 2022, 10:00 AM
  • Wednesday, May 11, 2022 , 4:00 PM   

To testify at one of these hearings: 

  1. Review details for the meeting you’ve selected here. 
  2. Pre-register here. Priority speaking will be given to those who pre-register.
  3. Draft your testimony! You’ll have 2 minutes to speak so having what you want to say written down can help you make sure you get all of your key points in.
  4. Start by telling the CAC who you are and why you’re here today!
  5. Then, provide your feedback. The scoping plan is hundreds of pages long but you’ll need to narrow your talking points down to just a few that really matter to you. Please use NOFA-NY’s key points (above) for inspiration. The NY Renews coalition also offers overarching and sector-specific talking points here
  6. Finally, submit your comments in writing. There are no length limits on written comments so add in any language that you were unable to include orally and submit your written comments by June 10, 2022, through this online form, by emailing scopingplan@nyserda.ny.gov, or by mail: Attention: Draft Scoping Plan Comments, NYSERDA, 17 Columbia Circle, Albany, NY 12203-6399

There are no length limits on written comments. You may submit all of your comments at once or submit a series of sector-specific comments. Please use NOFA-NY’s key points (above) for inspiration. The NY Renews coalition also offers overarching and sector-specific talking points here

Written comments are accepted through June 10, 2022, through this online form, by emailing scopingplan@nyserda.ny.gov, or by mail:

Attention: Draft Scoping Plan Comments, NYSERDA, 1

7 Columbia Circle,

Albany, NY 12203-6399

Please note that the language on this page may evolve over time as we work with our partners to refine and add more specificity to our recommendations.


NY Renews Coalition Resources

NOFA-NY is a member of the NY Renews, a coalition of 300+ groups advocating for good jobs and climate justice in NY. The coalition has developed sector-specific recommendations for the Scoping Plan and offers webinars and tools for supporting your engagement in our climate future.