Using these guiding principles, we developed the following set of recommendations:
- Assist organic farmers in benefiting from nature,
- Ensure organic production supports natural ecosystems, and
- Protect organic integrity.
Summary of Conservation Issues in the Draft Natural Resources and Biodiversity Guidance
To see WFA and Partners Comment Letter, which explains these issues in more detail, click here.
Recommend a Critical Change: This Guidance Should State the Obvious. — Organic farmers are expected to comprehensively conserve biodiversity, and to maintain or improve all the natural resources defined under §205.2, including soil, water, wetlands, woodlands and wildlife. Explicitly making this statement ensures that farmers and certifiers understand it is not enough to just maintain soil or water quality, while neglecting the other components of biodiversity and natural resources. Too often, organic farms and their certifiers have only addressed conservation piecemeal, and this has to change. NOP text already in the preamble to the rule ensures that comprehensively addressing biodiversity would not put a burden on the producer: “The use of ‘conserve’ establishes that the producer must initiate practices to support biodiversity and avoid, to the extent practicable, any activities that would diminish it.”
Recommend that Natural Ecosystems Should Not Be Converted into Organic Production. — The NOP should prohibit operations from converting new land for agricultural production. The most productive lands have already been converted years ago. At this point in human history, only privately owned land that is marginal, highly erodible, rocky, and prone to flooding has not been altered by agriculture. NOP requires that, in order to transition to organic certification, lands must be free from pesticides for three years. Unfortunately, despite often being highly erodible, 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.
The NOP should have barriers that discourage the conversion of intact, biodiverse ecosystems to agricultural cropland within five years from the date of application for certification. Under the NOP, established diverse ecosystems such as, but not limited to, forests, woodlands, shrublands, grasslands, riparian habitats, or wetland areas should not be subjected to clearing, burning, draining, cultivating, or otherwise irrevocably altering these landscapes. Alternatively, this restriction does not include harvested wild crops or production systems that sustain the diversity and abundance found in these ecosystems, such as mechanical collection of native seeds or low impact grazing.
In addition, organic certification must not convert ecologically at risk ecosystems to organic agricultural production. At risk ecosystems are those that are at risk of extinction due to rarity and/or declines, including vulnerable, imperiled, critically imperiled, and possibly or presumed eliminated. These highly valuable and at risk ecosystems should not be converted for agricultural use under the NOP’s credible environmental label.
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. — Since continual improvement is a tenet of organic agriculture, land subject to the CRP requires special consideration with regard to organic certification procedures. If the farm is considering bringing parcels designated as CRP back to agricultural production, a comprehensive conservation plan should be drafted that examines all the alternatives, keeping as many environmental benefits as possible.
While there is no contractual agreement to conserve sensitive areas after CRP has expired, the organic program is voluntary, and so an operator can choose to apply for organic certification or not. By requiring special procedures for CRP land, the difference between the need for biodiversity conservation is balanced with the recognition that environmental stewardship would be better addressed by organic than conventional agriculture.
Recommend that Biodiversity Conservation Is Listed or Described in the Farm Plan, Otherwise It Could Be Ignored. — Certifiers should list or describe (as opposed to address) a range of activities that can maintain or improve conservation of natural resources and biodiversity in their farm plan template in order to elicit more detailed responses from farmers about these aspects of their management. In turn, certifiers can used this increased level of detail during the inspection process. If farmers are only required to “address” conservation, they may not adequately document required activities.
Recommend that the Title of the Guidance to Include ACAs, Operations, and Applicants of Operations, Instead of Just Certified Operations. — This guidance covers issues relevant to Accredited Certifying Agents (ACAs), Certified Operations, and Applicants for Organic Certification. While the notice in the Federal Register makes it clear that this guidance is for all the above parties, the actual draft guidance only mentions Certified Operations. The final guidance needs to include all these parties.
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. — Emphasize the role of the NOP’s Accreditation Division in ensuring that certifiers are implementing the biodiversity standards through clear documentation of NOP standards on biodiversity within the agency’s audit checklists. Because it has been only 2+ years since the natural resources standard was added to the NOP auditing checklists, there may be many certifiers who have not gone through the re-accreditation process and are unfamiliar with these additions. These checklists hold certifiers accountable.
Recommend Conditions on How Conservation Benefits of Adjacent Land Can Be Counted. — If an operation is to obtain credit for activities on adjacent land, four criteria must be satisfied: 1) the operation must be active in implementing the activities; 2) the certified land must receive direct benefit from the conservation activities on the adjacent land; 3) the adjacent land must be accessible for announced and unannounced certification inspections; and 4) the adjacent land must not be negatively impacted by the certified land.
Recommend Clearing Up Possible Misunderstandings of Ecological Words and Terms. — Since the NOP did not include definitions of riparian habitat, High Conservation Value Areas, biodiversity and invasive species in the policy, these definitions should be incorporated in the examples of Appendix A as footnotes in order to facilitate a common understanding of NOP’s interpretation of standards related to biodiversity and conserving natural resources. Footnotes should also be used to provide information on national and international rare species, and at risk ecosystems.
Recommend that More Examples of Climate Mitigation and Adaption Are Given. — Add further examples in Appendix A, including a) conserve and restore natural communities to improve stability, resilience, storage of carbon, and adaption to extreme climatic conditions; b) use nutrient budgets to reduce greenhouse gases; c) promote crop and livestock diversity to help operations adapt to extreme weather events; and d) manage the frequency, intensity, and timing of grazing to optimize carbon storage.