NSAC's Blog
Final Guidance on National Organic Program Provides Clarity for Farmers and Certifiers
January 19, 2016
A Missouri Coteau wetland near Bismarck, N.D. Photo credit: USDA
Preservation of natural resources and the promotion of biodiversity and animal welfare are core principals of organic production. In order to support these principals and help farmers and certifiers to comply with organic requirements, the U.S. Department of Agriculture’s National Organic Program (NOP) released its final guidance, Guidance on Biodiversity and Conservation, on Friday, January 15.
NOP regulations state that organic operations must “maintain or improve the natural resources of the operation, including soil and water quality,” as well as “initiate practices to support biodiversity and avoid, to the extent practicable, any activities that would diminish it.” The latest guidance from NOP offers useful examples of conservation activities that organic and transitioning-to-organic producers can use to meet natural resource and biodiversity conservation requirements. It also clarifies the roles of the producer and the certifier in meeting these requirements.
Wild Farm Alliance (WFA), an NSAC member organization, wrote the initial text of the guidance and was instrumental in providing technical expertise to NOP during the drafting process.
“We applaud NOP for clearly stating that certified operations are required to implement measures that support natural resources and biodiversity conservation, not just soil and water quality, which was the problematic misconception from the start,” said Wild Farm Alliance Executive Director Jo Ann Baumgartner. “Soil and water regulations have been addressed consistently by most operations and certifiers in the past, and now with this final guidance, there will be a uniform method for implementation of the natural resources and biodiversity conservation regulations by all.”
In December 2014, NOP published a draft of the guidance document and opened a 60-day public comment period. NSAC submitted a joint comment with the Association of Fish and Wildlife Agencies, Center for Rural Affairs, National Wildlife Federation, and World Wildlife Fund.
In our comments, we recommended that the final guidance:
- Prohibit organic certification for ecologically valuable non-cropland that had been converted to cropland within the previous five years
- Include new language to ensure that producers continue to conserve natural resources on land being converted from the Conservation Reserve Program (CRP)
- Explain how producers can use both the Conservation Stewardship Program (CSP) and Environmental Quality Incentives Program (EQIP) to help them meet NOP conservation requirements
- Clarify how to account for conservation activities that take place on land adjacent to certified land
We are pleased that NOP adopted most of our recommendations to include CSP in the guidance, as well as our recommendation that the final guidance clarify how to deal with land adjacent to certified lands.
Unfortunately, NOP did not accept our recommendations regarding the conversion of natural ecosystems and CRP land. In our comments, we recommended that the new guidance require comprehensive conservation planning for lands being converted from CRP to organic production. Under CRP, farmers sign 10- to 15-year contracts to establish and manage continuous vegetative cover to conserve soil and enhance water quality and wildlife habitat, among other resources.
In its response, NOP stated that while it recognizes the value of conserving expiring CRP land, the “guidance cannot impose regulatory requirements beyond the USDA organic regulations.” See the full text of NOP’s response here. NOP provided no explanation for its decision to reject our recommendation regarding certification for recently converted native prairies, forests, or other natural areas. Both issues will now need to be addressed through a change in the NOP regulations; and as WFA’s Baumgartner notes, that process could take years.
Categories: Conservation, Energy & Environment, Organic