Biden's 'Made In America' Plan Is Bullying Homeowners Off Their Land to Build a Taxpayer-Subsidized Chip Plant

Michelle Nuzzo-Kelly remembers feeling somewhat bewildered the first time someone called and offered to buy her house out of the blue.

She recalls putting the agent on speaker so he could hear the hammering going on in the background. "That's the sound of a brand new roof being installed," she told him. It was a $10,000 expense—hardly the sort of thing you'd do if you planned to move. That was in September 2020.

But the calls kept coming. Letters followed. They included offers—the first was "a slap in the face," says Nuzzo-Kelly—and it wasn't long before she got fed up with it. "I said, 'stop calling me. My home is not for sale. There's no for-sale sign on my property.'"

Neighbors got the same requests, all at the same time. It wasn't long before she and other residents of Burnet Road, a dead-end strip of asphalt about 10 miles north of Syracuse, New York, were able to piece together a bit of what was happening.

Their homes were adjacent to a chunk of semi-wooded county-owned land, the White Pine Commerce Park, that had for years been proposed as an industrial site. Now, Onondaga County was hoping to enlarge the parcel to make it more attractive to a potential developer.

The county was coming for her home. 

A month after the calls started, Nuzzo-Kelly and several of her neighbors attended a public meeting where the rest of the pieces fell into place. That's where they learned that, a year earlier, Onondaga County had been negotiating with the Taiwan Semiconductor Manufacturing Company (TSMC), the world's largest maker of computer chips, to build a new fabrication plant—a "fab"—at White Pine. But the TSMC picked a site in Arizona instead, and now County Executive Ryan McMahon was determined not to be spurned again.

"This type of project would have been an amazing project, thousands of jobs, construction jobs, years of work for the trades, thousands of permanent jobs," McMahon reportedly said at that meeting. "We're on the map."

Nuzzo-Kelly came away feeling quite differently. She was shocked to learn that the county had in effect been shopping her home around to prospective developers for more than a year before she knew anything about it. "This was all done secretly behind all of our backs," she tells Reason. "It was just completely shady right from the start."

For more than two years since that initial meeting, she and her neighbors in Clay, New York, have been caught in the middle of an economic development scheme that stretches from Onondaga County all the way to the White House. Last month, that effort culminated in the announcement that Micron, one of the world's largest computer chip manufacturers, would build a factory in Clay. It's a project that draws together President Joe Biden's campaign-ready blather about luring high-tech manufacturing jobs to America with the promise of government handouts, Senate Majority Leader Chuck Schumer's (D–N.Y.) determination to bring some of those heavily-subsidized jobs to his home state, and the calculated ambition of star-struck local officials who seem to wish they were holding office somewhere else.

"On my watch, 'Made in America'…isn't just a slogan. It's a reality," Biden said on October 27 during a speech in Syracuse celebrating the project. "Today's announcement is the latest example of my economic plan at work."

But that economic policy has a dark side. If the alignment of government subsidies and political star power couldn't force the residents of Burnet Road from their homes, the county had the ultimate trump card. It has the power of eminent domain, which the county's industrial development board voted to authorize over a year ago.

The offers to buy Nuzzo-Kelly's home were never really just offers. They were demands backed by a threat to use government power to force her to sell.

"These are our homes," she remembers thinking. "How can somebody come in and threaten to take something that is ours when we don't want to go?"

The Plot

In the days after that October 2020 meeting with county officials, the residents of Burnet Road geared up for a fight. They formed a Facebook group, built a website, started organizing petitions, and sought local media coverage and legal help.

Among those who got involved was Britta Serog, who had grown up at the tail end of Burnet Road and then moved back a decade ago to help her ailing parents. Serog had deep roots here—a grove of towering pine trees behind her house was planted there by her father when she was just a girl. Serog says it is one of her earliest memories. Her parents' ashes are now buried in the front garden.

"This is where I felt the most settled and now I feel the most unsettled here," she says. After planning to have a quiet retirement here and building a hobby woodworking studio into a barn on the property, she plans to stay to the bitter end.

Paul Richer, a co-owner of the Hot House Brewing in nearby Cicerco, New York, was another leader of the resistance. Richer's roots on Burnet Road go even deeper than Serog's. He and his wife, Robin, now live in the charming kit-home bungalow that his parents built in 1954. Next door is the house that his grandfather built in the 1930s. Robin was born just down the road, and the two met when they were teenagers, when Paul was a hired hand on Robin's father's farm. "I was the farm boy who fell in love with the girl next door," he says.

They raised two daughters here on Burnet Road, in a different home near the top of the street by the intersection with the highway, and then moved back to this house once the kids were grown and Paul's parents had passed away. They seem to know the history of every single property and family up and down this mile-long stretch of asphalt.

"It was devastating," Richer says, recalling the letter that he received during the holiday season in 2019 from the real estate company the county had been hired to acquire the homes on Burnet Road. He and Robin had a lot of work done in anticipation of growing old in the house—like putting in a renovated, more easily navigable bathroom, for example.

In light of all that, the offer from the county "was not fair," Richer says. How could it be? The assessed value of their acre of land and nearly-70-year-old house wouldn't capture the true, and subjective, value of this place to Paul and Robin.

So they stayed, defiantly continuing to grow a vegetable garden—when I visited in early October, their kitchen was full of baskets of freshly picked tomatoes from more than a dozen plants, which Paul was preparing to can—and maintaining the yard while the county-owned homes on the street grow more numerous and more unkempt.

The neighborhood wasn't giving up easily, but Onondaga County has had powerful allies in high places.

Due to supply chain issues largely caused by the COVID-19 pandemic and the separate problem of escalating tensions between China and Taiwan, top officials in both political parties have fixated on the idea of bringing more computer chip manufacturing into the United States.

Schumer, the top Democrat in the Senate, has been a leading advocate for the campaign, insisting that an expanded American industrial policy for computer chips is both a national security issue and an economic development scheme. During a visit to Syracuse in April 2021, Schumer told reporters that three of the world's leading semiconductor companies were interested in the White Pine site near Clay. "Each one said we were seriously being considered," he said.

A month later, Schumer sweetened the pot. As he reintroduced a proposal to throw more than $50 billion in new corporate welfare at chipmakers in May 2021, Schumer promised that the package would be a "historic investment in the nation's semiconductor industry that will strength [sic] national security and create jobs across Upstate New York."

That proposal eventually became part of the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act, which passed Congress with broad bipartisan support this year.

"Because of the new law I signed and Chuck designed and delivered, we're turning things way around—around in a very big way," Biden said in his October 27 speech in Syracuse, a campaign-style event where he boasted about creating thousands of new factory jobs.

County officials have seemed awed by the possibilities. "It's nuts," McMahon, a Republican, told a local television station in September. "You're talking to CEOs of companies that you watch on CNBC and then you're taking a call from them."

"We have the electric and gas resources to support a project that would be transformative for the next 30 years," Robert Petrovich, director of the Onondaga County Industrial Development Agency (OCIDA), which is handling the process of buying out the Burnet Road homeowners, told a local paper in August 2021. "We become a different community. We become Austin, Texas, something like that."

And if you believe that the only thing standing in the way of turning the outskirts of Syracuse, New York, into the next Austin are some stubborn homeowners and their pesky property rights, well, the next step is clear.

On August 24, 2021, the OCIDA voted 5–0 to use its eminent domain powers against the residents of Burnet Road who refused to sell their land.

Even though there are still some holdouts, the semiconductor project is beginning to materialize. In October, state and local officials held a press conference to announce that Micron, the world's fourth-largest semiconductor manufacturer, had agreed to build a fab at the White Pine Commerce Park.

The White House issued a statement calling the announcement "another win for America." Later in October, Biden took a trip to Syracuse to celebrate the Micron project in person. He called it "one of the most significant investments in American history."

"This is our Erie Canal moment," Schumer declared, comparing the construction of a single computer chip factory to the construction of the statewide waterway that in the mid-1800s helped transform upstate New York into an economic powerhouse.

"Everyone in this community will benefit," Schumer said. "Everyone."

Well, maybe not everyone.

Shadows of Kelo

What's happening now to the residents of Burnet Road looks a lot like the early stages of the U.S. Supreme Court's most famous case involving eminent domain.

That story began when city officials in New London, Connecticut—another down-on-its-luck postindustrial city that believed a renaissance could be created with the application of government power—tried to seize property in the Fort Trumbull neighborhood.  The plan was to turn the land over to a private developer who would build a new corporate headquarters for Pfizer, a major pharmaceutical company. Susette Kelo and some of her neighbors refused to sell. They took the fight all the way to the Supreme Court.

They lost. 

"In short, the Kelo decision is one of the most reviled opinions that the Supreme Court has ever handed down," says Bob Belden, an attorney with the Institute for Justice (I.J.), the libertarian law firm that made a name for itself by defending Susette Kelo's little pink house. The 5–4 ruling, according to Belden, "basically says as long as a government is creative enough to come up with a public use or a public purpose, it can take a private person's property and hand it over to another private person."

Eminent domain is, of course, literally permitted by the Constitution. That is, governments have the power to take property, as long as the sellers are given just compensation, for public purposes like the construction of new roads or the flooding of valleys to form reservoirs.

But there is a marked difference between public uses and what happened in New London—and what may soon happen in Clay—where the government seized private land to turn it over to a private developer. Like in Clay, the Pfizer project in New London was supposed to bring a windfall of new jobs and tax revenue to a fiscally beleaguered city, and local officials were willing to do whatever it took to make it happen.

Writing for the majority in the 5–4 decision in Kelo v. City of New London, then-Justice John Paul Stevens argued that courts are not well-positioned to evaluate the "diverse and always evolving needs of a society" and refused to engage in "empirical debates over the wisdom of takings." Constitutionally, it was good enough that the city of New London had "a carefully considered development plan," Stevens wrote, that had passed the muster of various boards and commissions before the eminent domain actions had been approved. 

But the idea that the political system, rather than the judicial system, is the proper check on authorities' power to seize property for private development projects runs into immediate practical problems. If all it takes, in effect, is a majority of your neighbors voting to take your land, do your property rights meaningfully exist at all?

"If such 'economic development' takings are for a 'public use,' any taking is, and the court has erased the Public Use Clause from our constitution," wrote Justice Clarence Thomas in his powerful dissent to the Kelo majority. A "vague promise of new jobs and increased tax revenue," Thomas wrote, is not sufficient to consider a project to be for "public use," which he said should be restricted to situations in which the government actually used or gave the public the legal right to use the land in question.

"Any property may now be taken for the benefit of another private party, but the fallout from this decision will not be random," warned then-Justice Sandra Day O'Connor in her own dissenting opinion. "The beneficiaries are likely to be those citizens with disproportionate influence and power in the political process, including large corporations and development firms."

Kelo lost in court and lost her house. But New London lost, too. Plans to redevelop the Trumbull Hill neighborhood fell apart before the ground was broken for the new Pfizer headquarters. For nearly 20 years, the area has been a blighted, empty monument to a failed political scheme. This year, city officials approved plans to use the land for new housing and a new $30 million community center–right in the heart of the community that the city once destroyed.

But the case succeeded in bringing widespread attention to what seemed like an unfair use of state power. In the years after the Kelo ruling, most states rewrote their eminent domain laws to curtail similar takings for private purposes. President George W. Bush signed an executive order in 2006 limiting the federal government's use of eminent domain to situations "benefiting the general public and not merely for the purpose of advancing the economic interest of private parties" that received the land.

Some of those reforms were more robust than others. Notably, however, New York is one of the few states that did not change its laws post-Kelo. That means it is one of the few places where eminent domain can be used as part of what is blatantly a private development scheme.

Eminent domain proceedings aren't happening yet. The vote last year by the OCIDA didn't start the legal process to seize the properties but is probably better thought of as an official warning to Burnet Road's holdouts: Take the deal we offer, or else escalation is coming. The OCIDA did not respond to Reason's requests for an interview. 

When it comes, it will happen quickly. New York law allows the targets of an eminent domain action just 10 days to respond after the legal process kicks off. Belden says that I.J. is monitoring what's going on in Clay and plans to intervene if the county initiates eminent domain. For now, though, it's just a waiting game.

"We've been in this limbo for over a year," says Serog, who speculates that the county was rattling the sword of eminent domain in the hopes of clearing out Burnet Road without having to actually go to court. Without, that is, the risk of turning this situation into the next Kelo case.

O'Connor's warning about how the process could be used against those with relatively less political power seems prescient.

"A lot of people have sold because of the threat of eminent domain. It's very difficult to fight," says Serog. "They feel they don't have any choice."

"It's not a fair negotiation," says Belden. He recalls that during the Kelo oral arguments, the city of New London pointed out that many of Kelo's neighbors had voluntarily sold their homes to the city, drawing laughter from the justices and onlookers in the courtroom. "I mean, everybody knows that once you put this threat out there, you're no longer operating on an equal plane."

For Richer, changing New York's eminent domain policies is part of his motivation for continuing to fight.

"I mean, I've got kids, grandkids. Is something like this going to happen to them down the road?" Richer says. "I don't want them to have to go through the stress that we're going through."

The Next Foxconn?

The final stage of the showdown over Burnet Road seems to be approaching quickly.

The October 4 announcement that Micron was coming to Clay was chock full of the usual grandioseness that accompanies such events. The company is promising a massive chip production facility covering more than 2.4 million square feet—the size of about 40 football fields—creating more than 9,000 jobs in Onondaga County and contributing to over 50,000 jobs statewide.

For McMahon, the county executive, the announcement validates his ambitions. "This is a project that many people felt we weren't worthy of, but at the end of the day the greatest memory technology company in the world chose Onondaga County," he said in a statement.  "We will make sure that every neighborhood in every corner of the County feels part of this historic and transformational project."

"The future of New York is now beyond imagining," Democratic Gov. Kathy Hochul declared at the press conference, calling the Micron deal "the result of an exclusive, almost-never-happens collaboration between the private sector, businesses, labor, our local elected leaders, [and] the state."

But this sort of thing actually happens all the time. Even in New York.

In 2010, for example, the state poured $470 million in subsidies into a deal with then–tech giant Yahoo, which planned to build a data and call center near Buffalo. When the deal was announced, Schumer was on hand to declare it a game-changing moment for the state—just like he's done with the Micron deal.

"This opening says to high-tech companies throughout the world: 'Look at Western New York, see what stuff we have, and you will come here,'" he said.

Five years later, the project had created 200 jobs at a cost of about $2.4 million per job. By 2018, one of the developers was in prison for corruption connected to the deal.

Similarly, a solar energy project near Buffalo that received $750 million in subsidies from the state ended up creating just 700 jobs—a fraction of the 3,000 that then-Gov. Andrew Cuomo had promised when the giveaway was announced. Those subsidies flowed through Empire State Development, the same state entity that is overseeing the giveaway to Micron.

Those are hardly outliers. A 2017 investigation by ProPublica, Columbia University's journalism school, and the Albany-based Investigative Post combed through 16,000 subsidy deals worth billions handed out between 2011–2014 under the oversight of Cuomo. The results were damning.

"The state's substantial investment in the Upstate economy has not yet generated many jobs," the investigation found, adding that Cuomo's "economic development programs suffer from a lack of transparency and objective analysis to determine their effectiveness." The report also found that "the state does an inadequate job of vetting subsidy recipients to determine their history of compliance with federal and state regulators and that some companies have used their influence to tap into a multitude of subsidy programs and place executives on decision-making bodies that help determine how tax breaks and other forms of assistance are awarded."

The Micron project comes with support from the federal government, which might lend a veneer of additional legitimacy to the effort. But recent history suggests that federal support is no guarantee that high-profile industrial policy efforts will succeed. Indeed, the Micron project has parallels not only with the infamous Kelo case, but with what happened on the outskirts of Milwaukee, Wisconsin, a few years ago.

With the help of eminent domain, state and local officials were able to cobble together a parcel of land in Mount Pleasent, Wisconsin, that was sold to Foxconn, which manufactures components for Apple's iPhones and promised to invest $10 billion in Wisconsin. In addition to the land, state officials led by then-Gov. Scott Walker gave Foxconn one of the most lucrative corporate welfare packages in American history.  

Wisconsin's Legislative Fiscal Bureau, a number-crunching agency similar to the federal Congressional Budget Office, calculated that it would take until 2043 for Wisconsin to recoup the $3 billion handout, and even if all 13,000 promised jobs went to Wisconsinites, the tab would be more than $230,000 per job created.

But that didn't stop the politicians from celebrating. Then-President Donald Trump jetted to Wisconsin for a ground-breaking photo-op with Walker, and declared that the Foxconn plant would be nothing less than "the eighth wonder of the world."

Fast forward to April 2021. That's when Foxconn told the state that its revised plans for the Mount Pleasant facility would see the company invest about $672 million (instead of $10 billion) and employ about 1,400 workers when completed—a fraction of what was once promised.

The Foxconn project should be a reminder not to judge the effectiveness of economic development schemes by the press releases issued in the days after a construction project is announced. A semiconductor fab is not built in a day.

Unfortunately, the passage of the federal CHIPS Act—which effectively tries to copy Walker's strategy in luring Foxconn to Wisconsin, but does so on a national level—might encourage states to make more bad deals, warns Pat Garofalo, a policy analyst at the left-leaning Center for American Progress and author of The Billionaire Boondoggle, a book criticizing corporate welfare.

The CHIPS Act has kicked off a "Semiconductor Doom Loop," Garofalo warned in a June post on his Substack newsletter, Boondoggle, in which states are now incentivized to compete even more aggressively against one another to land federally subsidized tech manufacturing facilities. Those economic development schemes have always been a "race to the bottom" but are now being pursued with greater speed and fewer safeguards, he argues.

The federal government's pandemic stimulus programs are helping spur the spending binge. Kentucky, Michigan, and Tennessee have used federal funds distributed to the states as part of the American Rescue Plan to subsidize factories for electric vehicles and batteries, for example. 

But it isn't clear that all that new spending will advance the goal of boosting American high-tech manufacturing jobs. "The federal government's half-baked plan is goading states into a destructive subsidy competition of their own," Garofalo wrote in Boondoggle in June, "which will result in even more money thrown into a system that already failed."

Meanwhile, governments are flooding these projects with money as computer chip manufacturers are reporting record revenues. The New York Times reported last year that equity investors have "plowed more than $12 billion into 407 chip-related companies" during 2020, which is more than double what they invested in 2019. Revenue for global chip manufacturers was up 10 percent in 2020, despite a pandemic-induced slowdown in demand, the Times reported, and NXP Semiconductors, which makes chips for automobiles and industrial equipment, saw revenue climb by 27 percent. Those numbers don't suggest an industry in dire need of government aid.

Concerns about America's share of global semiconductor manufacturing are similarly misplaced. Much of the justification for these massive new subsidy programs is wrapped up in the idea of national security—that America is somehow at risk if our leaders don't ensure that semiconductors are made here. One oft-repeated talking point highlights how America's share of global semiconductor manufacturing has fallen from 37 percent in 1990 to just 12 percent last year.

But where the chips are made doesn't matter much. According to the Semiconductor Industry Association, a trade group, American-based firms still control 47 percent of the global share of the semiconductor industry—far more than companies based anywhere else.  "It is true that America has slipped to a 12 percent market share in semiconductor manufacturing, but it doesn't follow that firms need government help not to slip further," wrote T.J. Rodgers, CEO of Cypress Semiconductor Corporation and a former chairman of the Semiconductor Industry Association, in The Wall Street Journal last year, as the debate over the CHIPS Act heated up in Congress.

Back on Burnet Road, Richer, the local brewery co-owner, wonders about the effectiveness of using public funds to lure companies like Micron to upstate New York, where the tax and regulatory environment has been driving big companies away for years.

"All these big manufacturers left the state because it's just too expensive to do business here," he says. "I just feel that if a big company does come in here, how long are they going to stay? You know, when their benefits package expires and they have to start paying taxes, are they going to stay or …move out of state?"

That's a question that the officials involved should be asking, too. Just days after plans for the new fabrication plant near Syracuse were announced, Micron CEO Sanjay Mehrotra told Axios that "continued tax credits are needed for sustained investment" and hinted at the company's plans to scale back its investments if the market takes a turn.

In the Pines

A few days before Micron announced its plans to build in Onondaga County, Nuzzo-Kelly locked the front door of her house on Burnet Road for the last time.

"I left there in tears," she says during a phone interview. "Eventually, they're going to bulldoze the homes, and it'll be like Burnet Road never existed."

Despite having been one of the main organizers of the "Save Burnet Road" effort, Nuzzo-Kelly eventually (and reluctantly) struck a deal with the county to sell her home and moved to Baldwinsville, about 30 minutes away. She and her husband have spent the past few months packing up the house on Burnet Road and shuffling their lives into the new home. Though she is not at liberty to discuss the terms of the sale due to a nondisclosure agreement signed as part of the deal, Nuzzo-Kelly says she's happy with the end result—and happy that she decided to sell before the hammer of eminent domain came down—even if the way it all happened still makes her mad.

"It could have been handled much differently," she says. "They came in with the attitude of 'we're going to take it one way or the other, so you might as well make this easy for both of us.'"

"The county has forced people out of their houses," Richer says, bluntly. Even without specifically invoking eminent domain, it's clear to him that most people on the road "didn't move by choice. They had no intention of moving."

That group now includes Richer and his wife, too. In October, a few weeks after the Micron project was announced to much fanfare, Richer and his wife bowed to the pressure and accepted an offer to sell their home.

"This beautiful rural area will undergo many major changes. None of which I want to be a part of," Richer told Reason via email shortly after making the decision to sell. A confidentiality clause in the contract he signed with the country limits what he can say about the deal's terms, but Richer says emotions are running raw for both he and his wife. "There has been anger, tears, and just about every imaginable emotion you can think of. I really don't want to leave, but again, where we live now will not be the same. There is such an emotional attachment to this place. I am feeling a sense of loss, but need to move forward and make the best of it."

It's hard to fault the residents who took the county's offer and moved away. The Micron project is still fraught with legal questions and economic uncertainty, but fighting it means standing up to politicians in Onondaga County, Albany, and Washington, D.C., all of whom have lined up behind the project.

And it means knowing that even if you succeed in saving your own home, much of the damage has already been done.

"It is sad. It is very sad. There was a real good community here," says Serog. Even if the county were to give up, there's no way to get that back. Burnet Road is now a ghost town, dotted with obviously empty and abandoned homes. The siding has been stripped off of some, garage doors and lighting fixtures are missing from others. More than a few have piles of garbage in the front yards—old furniture, drywall, and other detritus not valuable enough to move or steal. Most yards are overgrown with weeds. The empty houses along the road have attracted looters, which has prompted Serog to install some security cameras on her property and only added to the feelings of insecurity. 

In a speech after winning the Nobel Prize for economics in 1974, F.A. Hayek advised policy makers "not to shape the results as the craftsman shapes his handiwork, but rather to cultivate a growth by providing the appropriate environment, in the manner in which the gardener does this for his plants."

To carry the metaphor forward, the garden of upstate New York has gone fallow. But rather than cultivating growth across the whole area—say, by cutting taxes, reducing regulations, or engaging in other behaviors like states where economic growth is happening—Onondaga County, with help from Schumer and Biden, is dumping a bunch of fertilizer in one spot, hoping to get a single sprout to grow, and promising a bountiful harvest. Even if they weren't taking a bunch of private property in the process, this would be an ill-advised strategy to cure the region's economic woes.

What's happening on Burnet Road is the most visible, vicious portion of the costs of industrial policy. It is the result of deliberate decisions made by policymakers in Onondaga County, in Albany, and in Washington, D.C., to prioritize the interests of a massive, wealthy corporation over the property rights of the people who already live there. Wrapping it in the trappings of national economic security should not obscure that basic reality.

This is, as Biden put it on October 23, the White House's economic plan at work.

Serog gazes through the gloaming of an early October evening at the grove of pine trees that could soon be bulldozed by Onondaga County. If she's forced out, she says, "I'll survive. It'll be a lot of work."

In the meantime, she will keep her plans to upgrade a nearby rental property on hold. Planned renovations to her own house and the barn that she's converted into a woodworking studio will have to wait, too. But she's still working hard on the garden, ready to harvest this year's supply of sweet potatoes and saffron, waiting on the gourds and the last few berries from her thicket. Out back, the trees are pressed in a bit too close together, huddled up like protesters behind a barricade, ready for a fight they probably can't win.

"I don't think it's fair. I don't think this is a good law that forces people to move out," says Serog. "Taking somebody's private land and giving it to another private company. Is that the government's place? I don't think so."

Camera by Qinling Li; edited by Danielle Thompson; additional graphics by Isaac Reese; audio production by Ian Keyser.

Music Credits:  "Waiting" by Laurel Violet via Artlist; "Line" by Oak and Cherry via Artlist; "Cosm" by Amulets via Artlist; "Reverence" by Oliver Michael via Artlist; "Subdivide" by Stanley Gurvich via Artlist; "Woodland" by Laurel Violet via Artlist; "Unsettled" by Matt Stewart-Evans via Artlist; "Future Forests" by Ben McElroy via Artlist; "Sun Up" by Laurel Violet via Artlist.

Photo Credits:  Mark Wilson/CNP / Polaris/Newscom; SMG/ZUMA Press/Newscom; Wang Ying / Xinhua News Agency/Newscom; Mike Groll/ Office of Governor Kathy Hochul; Tom Williams/CQ Roll Call/Newscom; CNP/AdMedia/SIPA/Newscom; Tom Williams/CQ Roll Call/Newscom; Ron Sachs—Pool via CNP/CNP / Polaris/Newscom; Institute for Justice.