FORESTER COMMENTS

5/15/15
I feel very strongly that the professional foresters who work with the 480-a program, as well as the landowners who have land enrolled in the program, can offer valuable information and insight to the discussion on potential revisions of the law. I am disappointed that the information we have been provided on this important subject has been so limited to date, and that our input into the process has been minimal. The fact that such major changes to the 480-a program have been proposed and discussed, with very limited involvement or input from the majority of consulting foresters in the state or the landowners enrolled in the program, leaves me to conclude that input from these stakeholders is not desired by the DEC.
– Forester, NY 12540

5/15/15
I would agree that some changes to the current 480-a program are warranted and that certain changes could be beneficial to all parties involved. Changing the program to more of a forest protection program rather than one tied to timber harvesting makes some sense, especially in the Region 3 area with its additional limiting circumstances. However, I do not feel that many of the proposed changes would have the desired positive effects that have been stated by DEC. It is my experience that it requires a significant economic incentive for landowners to be willing to maintain and manage their forest land on a long term basis. I feel that reducing the potential economic benefit as proposed will lead to less forest land being protected and less beneficial forest management being practiced. I could support the idea of having new programs available to landowners (options 1 and 2), but I can’t support the loss of the current 480-a program to current or future enrollees.
– Forester, NY 1254

5/15/15
What would the Time of Harvest option mean to existing 480-a enrollees? Would they be required to complete a timber harvest within 15 years to continue the exemption? What if they had just completed a timber harvest in the recent past, or have harvested in most of their land during their commitment period?
– Forester, NY 12540

5/15/15
Although it is possible that some of the proposed revisions may be beneficial to landowners in certain areas of the state, I don’t believe this would be the case for the majority of landowners in the Region 3 area. This area is likely one of the most difficult areas of the state to conduct economically feasible and beneficial forest management activities. There is a lack of markets for most forest products other than quality sawtimber. There are limited logging contractors interested in purchasing forest products. There are significant permitting issues on many levels, but especially on the town level. Many local towns require a Special Use Permit for timber harvesting and obtaining this permit can be very time consuming and expensive. These permit issues, coupled with other state wide restrictions and permitting required for issues such as endangered species, can make it a long and expensive process to obtain all required permits, making some smaller harvest projects not feasible.
– Forester, NY 12540

5/15/15
Forest Certification Option – This option requires a DEC approved third party certification. Current 480-a enrollees who have already incurred expenses to obtain the 480-a exemption are now forced to expend additional funds to obtain forest certification, and additional ongoing expenses to maintain the certification, while receiving reduced exemption benefits in exchange (70%). This seems especially unfair to recently enrolled properties. Additionally, DEC has admitted that this option is not currently economically feasible to most if not all landowners, so it is really not a viable option.
– Forester, NY 12540

5/15/15
Having this option tied to the time of harvest is also an issue, in my opinion, for smaller acreage properties. Many of the forested properties in the Region 3 area are comprised of substantial young forest areas that have developed on abandoned agricultural land. Many properties have very little mature forest land. Even if a property was able to complete a timber harvest in order to qualify under this option, it would likely be a long time before another harvest would be feasible, likely longer than the 15 year exemption period. In addition, timber harvests on small amounts of acreage (especially in the Region 3 area) are often not economically feasible. There are usually additional expenses involved in harvesting projects in this area due to increased town required permits and other regulatory matters. There are also limited markets for forest products in this region limiting the feasibility of many harvesting opportunities.
– Forester, NY 12540

5/15/15
Time of Harvest Option – More clarification is needed on what land could be included under this option. From my experience, the current 480-a program is only marginally economically desirable to owners with small acreages (50 -75 acres eligible) in the Region 3 and 4 areas. I don’t believe reducing the acreage to 25 acres along with a reduced exemption percentage of 40 % would make this option desirable to many smaller acreage owners. The 40% exemption on larger properties would also not be that beneficial. Current enrollees who switched to this option would see a significant decrease in their annual tax reductions. The proposed changes show that potential penalties under this option would be the same as under the current 480-a program. This level of penalty seems excessive considering the reduced benefits offered by this option.
– Forester, NY 12540

5/15/15
It seems unfair to me that landowners who have signed a commitment with the state to enroll their property in 480-a and have adhered to the responsibilities and requirements of the program, some for over 30 years, would be told now that this contract is no longer valid and they have to change to another program or opt out of the current program. I feel at the very least all current 480-a enrollees should be grandfathered and be able to remain in the current 480-a program. I have done an analysis of how the proposed changes would affect my clients, using a ten percent random sample. The results are a significant loss in economic benefits in all cases and under all options.
– Forester, NY 12540

5/14/15
There have been many changes to the original proposal, that have been now submitted to the Governor to submit to the legislator. No one knows, except the DEC, and a few others what is in the new proposal. The frustrating process has not been a true stakeholder process. The ammended proposal as been by the government for the government. Not healthy for the whole forest managment community. Wish it was handled in a professional manner. They should apologize and develop a task force to change 480-a with all stakeholders, this would also heal the forest community, and maybe people would trust the DEC again.
– Forester, NY 13856

5/12/15
DEC’s proposal requires at least one harvest every 15 years in order to enroll and receive tax relief. If silviculture dictates a regeneration cut the next harvest may be 50 years away. How will landowners get their tax relief in the interim? DEC’s proposal is a disincentive for regenerating forests.
– Forester, NY 13820

5/12/15
It would be harmful to landowners if all existing 480a properties were not grandfathered (as described they need to be 1000 acres or more).
– Forester, NY 12413

5/12/15

The Green Certification Option as shown would not work for the average landowner as costs for auditing/compliance checks from third parties would be in the range of $3000 to $5000.
– Forester, NY 12413

5/12/15

The time of Management Practice Option could aid in giving a tax break to the smaller forested landowner, if current 480a is continued. But this could also harm local taxes bases, especially in heavily forested towns.
– Forester, NY 12413

5/12/15

I’m an older consulting forester and many of 480a clients are older and on fixed incomes. The loss of the 40% would hurt many.
– Forester, NY 12413

5/6/15
I am glad to see the minimum acreage lowered to 25. A welcome change. But this number seems arbitrary. What analysis was done to arrive at 25 acres? Smaller parcels are more prevalent in Southeastern NY, so a lower minimum is crucial, but the number should be well thought out.
– Forester, NY 12508