Tell USDA to Support Stronger Conservation of Biodiversity in Organic Agriculture!
Comments due in ten days-Submit yours today!
Help us make sure the National Organic Program gets its biodiversity conservation guidance right! Currently, there is a loophole for allowing thousands of acres of native prairie, old growth forest or other natural ecosystems to be converted to agriculture and organically certified the next day. Worse - the NOP unintentionally incentivizes this practice by requiring lands to be free from pesticides for three years. NOP’s three-year waiting period for transitioning to organic production serves a critical purpose and it should be retained. But land that has not been plowed or previously planted is an easy target for those looking to quickly overcome NOP’s three-year waiting period, and that needs to change.
Biodiversity conservation was included in the first publication of the National Organic Program (NOP) regulations back in 2002. Farmers, ranchers, handlers, and wild crop harvesters must maintain or improve their soil, water, wetlands, woodlands, and wildlife, and conserve biodiversity.
The National Organic Program is accepting public comment on the Draft Guidance: Natural Resources and Biodiversity Conservation for Certified Organic Operations until Friday, February 27th, 2015. Submit your comments on the Natural Resources and Biodiversity Conservation Guidance: Docket Number-AMS-NOP-14-0062 or sign onto Wild Farm Alliance and Partners' comment letter. To read the letter in full, click here.
Read our summary analysis and recommendations on Wild Farm Alliance's website. Here's a snapshot of what is covered:
- Recommend that natural ecosystems should not be converted into organic production.
- Recommend that operators of CRP lands (Conservation Reserve Program) leaving the federal program and now requesting organic certification must consider the best agricultural use alternatives and have a comprehensive conservation plan.
- Recommend that biodiversity conservation Is listed or described in the Farm Plan; otherwise, it could be ignored.
- Recommend that the Title of the Guidance is as follows: Natural Resources and Biodiversity Conservation for ACAs (Accredited Certifying Agents), Certified Organic Operations, and Applicants for Organic Certification, instead of just for Certified Organic Operations.
- Recommend that the Guidance's Background section be modified to incorporate biodiversity into the evaluation process used by the USDA for accreditation of organic certifiers and the USDA's audit of accredited organic certifiers.
- Recommend conditions on how conservation benefits of adjacent land can be counted.
- Recommend clearing up possible misunderstandings of ecological words and terms.
- Recommend that more examples of climate mitigation and adaption are given.
Thank you for your commitment to organic agriculture!
Wild Farm Alliance