Biodiversity conservation was initially ignored in the National Organic Program (NOP) regulations when they were first published back in 2002. We've changed that.
NOSB protects native ecosystems!
With WFA in the lead, we successfully encouraged the National Organic Standards Board (NOSB) to pass a recommendation to the National Organic Program (NOP) to create a new rule that protects Native Ecosystems at their April 2018 meeting (new additions to the NOP rule are in bold):
Add to §205.2 Definitions
Native Ecosystems: Native ecosystems can be recognized in the field as retaining both dominant and characteristic plant species as described by established classifications of natural vegetation. These will tend to be on lands that have not been previously cultivated, cleared, drained or otherwise irrevocably altered. However, they could include areas that have recovered expected plant species composition and structure.
Add to §205.200 General
- 205.200 The producer or handler of a production or handling operation intending to sell, label, or represent agricultural products as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s))” must comply with the applicable provisions of this subpart. Production practices implemented in accordance with this subpart must maintain or improve the natural resources of the operation, including soil and water quality.
(a) A site supporting a native ecosystem cannot be certified for organic production as provided for under this regulation for a period of 10 years from the date of conversion.
Prior to the NOSB recommendation, we worked closely with NatureServe, a NGO built by The Nature Conservancy that provides the scientific information and tools needed for effective conservation action. Because many of the larger organic advocacy organizations looked to us for messaging and advice, we published two Issue Briefs describing our concerns, arguments and actions supporters could take to move this issue forward. We and our partners generated more than 500 public comments for the April 2018 meeting, and submitted our own written comments with 33 endorsing organizations.
We continued to assist organic certifiers with updating their organic system plans so that they better align with the NOP Natural Resources and Biodiversity Conservation Guidance. So fa, we've made recommendations to certifiers who collectively inspect more than 75% (20,000) US organic farmers.
Over the last year, we've assisted organic US-based certifiers who inspect over half of the organic farms in the country with updating their Organic System Plans (OSPs), in order to help them comply with the NOP Natural Resources and Biodiversity Conservation Guidance. We've also conducted 5 organic inspector trainings with them on biodiversity guidance.
In order to understand the current status of compliance with the NOP Guidance, we assessed these certifiers' Organic System Plans (farm questionnaires). Click here to download the OSP report and read our recommendations.
WFA is working to eliminate the incentive to convert Native Ecosystems/High Conservation Value Areas to organic production. We encouraged the National Organic Standards Board (NOSB) to publish a Discussion Document on this subject for their April 2017 meeting. Over 450 public comments weighed in on this issue, with WFA in the lead. Click Here to Learn More.
To help the NOSB and others in the organic community better understand how the different parts of a High Conservation Value Areas (HCVA) definition would be applied, we published this pictograph: High Conservation Value Areas (HCVA): Scenarios for Disincentivizing Conversion, Incentives for Protection, and Using Non-HCVA Immediately.
In September 2017, the NOSB released a proposed rule change using the term "Native Ecosystems." WFA and our partners submitted 350 comments on how to improve the language by defining native ecosystems and fixing a loophole. Click Here to Learn More.
The NOP publishes the Guidance!
Click here to to read the final NOP Natural Resources and Biodiversity Conservation Guidance.
The NOP explained its thinking about the final Guidance by also publishing its responses to comments submitted to them regarding the draft Guidance. One of the most important sections states: "Several commenters pointed out that this guidance needs to be very clear about NOP’s expectations for producers to implement conservation practices above those that are required by the other sections of the standards, notably §205.203(b), requiring crop rotations, cover crops, and the application of plant and animal materials, and §205.203(c), requiring producers to maintain or improve soil organic matter content without causing contamination of crops, soil or water. Some comments suggested the guidance should clarify that in order to maintain or improve all the natural resources as defined under §205.2, including soil, water, wetlands, woodlands, and wildlife, and conserve biodiversity, a comprehensive approach to natural resource management is necessary and goes beyond maintaining soil or water quality. In response, we updated this section of the guidance to include reference to § 205.2, the definition of Natural Resources of the Operation. Certified operations are required to implement measures that support natural resource conservation and biodiversity in addition to maintaining soil or water quality."
Click here to understand the NOP's thinking on the Guidance by reading their Responses to Comments.
Click here to read WFA's summary analysis of the final Guidance.
The NOP also updated their Organic System Plan for crops, with NCAT's help, to be streamlined. See pages 4-5 for the Natural Resources of the Operation and Biodiversity Conservation Management section. Read the new plan here: NOP Streamlined OSP for Crop Production.
WFA publishes How to Conserve Biodiversity on the Farm: Actions to Take on a Continuum from Simple to Complex, a publication for all farmers and for certifiers.
After many years of hard work, WFA had another success. In 2015, the NOP released a draft of the Natural Resources Conservation Guidance. While we were happy it was out, we submitted suggested improvements.
Click here to see the NOP's Draft of the Natural Resources Conservation Guidance.
Wild Farm Alliance and International Organic Inspectors Association (IOIA) collaborated on surveys and interviews of over 50 inspectors and certification reviewers, as part of a joint project to integrate biodiversity and natural resources conservation as a fundamental principle in organic inspections.
According to those who responded, an average of only about 60% of organic farmers understand biodiversity conservation as part of compliance for their certification. While 79% of those who responded said biodiversity conservation is integrated into the organic inspection and/or certification review process, only 55% integrate it as foundational principle of organic agriculture. All respondents reported a basic understanding of biodiversity conservation, and 40% of those rated themselves as having a deep understanding. 94% would like more about non-compliances and how NRCS and other conservation programs work.
Read more about the Surveys and interviews of over 50 inspectors and certification reviewers.
Another breakthrough--The NOP includes the natural resources §205.200 in several of their Accreditation Checklists they use to accredit organic certifiers. Many organic certifiers who were denying this was in the regulations have now changed their stance to supporting it!
WFA and partners submitted a summary cover letter and Draft Biodiversity Conservation Guidance for consideration of the National Organic Program (NOP) to adopt into their Handbook.
In order to help organic farmers include biodiversity into their Organic System Plans and to assist certifiers in addressing verification, we created a compliance assessment document. A quick one-page overview examines the most problematic biodiversity issues, while the rest of the document provides a slate of beneficial practices that comply with the rule.
The ice starts melting this year. Once the NOSB saw WFA's above compliance document, they took a fervent stance recommending that the National Organic Program (NOP) comprehensively address biodiversity conservation, from farmers and certifiers to the NOP itself.
WFA brings attention to the organic world that biodiversity conservation is part of the National Organic Program (NOP) regulations. We began by working with a broad base of organic experts across the country to create a set of biodiversity inspection questions that the National Organic Standards Board (NOSB) then adopted into their model farm plan.
We also published Biodiversity Conservation guides for organic farmers and certifiers. The guides lay out a range of farm management possibilities for a variety of situations that maintain and enhance biodiversity at the farm level and contribute to biodiversity conservation outside of farm borders at the regional or watershed level.
Learn more about the first biodiversity conservation additions into the NOSB's Organic System Plan Template.
Download WFA's Biodiversity Conservation Guides.
We are pleased to see the progress of the organic regulations protecting biodiversity; however, there is more to do. Here are the top issues we are continuing to work on:
- Provide more training for the certifiers and their inspectors.
- Support the full development and implementation of biodiversity conservation in the Organic System Plan (OSP) by organic farmers, ranchers, wild crop harvesters, and handlers.
- Work with US based certifiers to update their OSPs to incorporate more biodiversity conservation questions.
- Eliminate the incentive to convert unplowed native habitat to organic crop production due to the three-year waiting period for land which has had pesticides applied. Read More