Action Alert: Protect Our Native Ecosystems with a New Rule in the National Organic Program

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The National Organic Program’s (NOP) three-year waiting period for land to be free of prohibited substances unintentionally incentivizes producers to convert native ecosystems since this land is instantly ready for organic production. While organic agriculture is an ecological management system that promotes and enhances biodiversity, it offers no environmental protections prior to certification. 

Your action today can help the NOP catch up with the rest of the organic and environmental ecolabels of the world!

We are thrilled the NOSB is tackling this issue, but adding a new rule is a big deal.

While we are getting closer to what is needed, the recommended rule language requires some adjustment; otherwise the intent the Board is seeking will not be addressed.


It is critical that the proposed NOP rule change clearly states the intent – To incentivize the transition to organic production of farms that have had prohibited materials applied, while minimizing the loss of lands with important habitats from conversion. These lands will be necessary to support declining and rare species today and a hundred years from now, when there be much less available due to increased human populations and climate change. 

This month, the NOSB released their public docket for the upcoming meeting and in it is a proposed rule change.

Talking Points for Comments to the NOSB (Due October 11th)

NOSB should make the following changes to their proposed language, ensuring the new rule truly protects our Native Ecosystems! 

  • Don’t narrow the scope of Native Ecosystem protection to land that has never been cultivated or grazed because that will make the rule almost meaningless. In regions of the world where livestock can be raised, there is very little land left that hasn’t been grazed. Many areas that have been grazed or cultivated a 50-100 years ago have recovered today. Delete “grazed or cultivated.” Prior agricultural land uses can be difficult or impossible to detect, and the inclusion of these words will lead to confusion and disagreement. The standard should rely on readily observed vegetation types in the field.
  • Define “Native Ecosystems” in a way that an assessment can be made on species present. For areas on land, natural and semi-natural vegetation types are assessed. Future NOP Guidance should elaborate on commonly used tools that use plants to classify and describe an ecosystem type.
  • “Conversion” should not be tied to “crop or livestock production.” Whether the conversion of a Native Ecosystem was directly because of agriculture or some other reason such as development, the time period between conversion and certification should still apply.
  • Delete “crop or livestock” and just say “organic production.” While conversion will predominately be to crops and livestock production, this rule should not omit other types of operations.

Instructions: Post your comments online today—deadline October 11, 2017.

  1. Go to the comment form at
  2. Write directly in the window provided, cut and paste your comments into the provided space, or attach a separate document. More detailed bullet points, which you can customize and paste into the website, found above.
  3. You can submit comments online until 11:59 p.m. (Eastern Time) on October 11, 2017 at the above link.
  4. If you are an organic farmer, or are involved in the organic industry, please be sure to mention that! Comments from organic consumers are vitally important as well, especially if you tell regulators why you care. 



Don't forget to tell us you submitted your comments with the form below.  

Thank you! 


Click here for more background on this issue.

This critical issue will save countless wildlife and native plants, and preserve the integrity of organic agriculture - Your comment will make a difference!

The NOSB has published a Discussion Document (pages 1-5) asking the public for comments on their current rule change recommendation language. They will review and discuss public comments at their Fall October 2017 meeting. Help the NOSB update the language they use to truly protect native ecosystems. 

Comments are due Wednesday, October 11th.