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Close Regulatory Loopholes that Incentivize the
Conversion of Wild Land to Organics
Comment by October 11 to the National Organic Standards Board

Though organic agriculture promotes and enhances biodiversity, organic regulations do not explicitly protect sensitive native ecosystems from being converted into organic production—in fact, they incentivize it!

Irrigation on an “organic” dairy in Texas

Burning down the rainforest to plant “organic” soybeans, or irrigating the Southwestern desert, often paving the way for factory-farm “organic” dairy production, needs to stop. These pristine lands have never had agrichemicals applied, so they can immediately be certified organic.

The National Organic Standards Board (NOSB) has proposed new regulations that will provide protections for these ecosystems by removing this incentive. This move is both needed and overdue; these additions to the organic regulations are important to prevent more valuable wild ecosystems from being turned into agricultural land.

However, Cornucopia’s allies at the Wild Farm Alliance (WFA) find that the NOSB’s proposed regulatory language contains material loopholes and needs to be strengthened. Otherwise, native ecosystems will continue to be at risk. Analysts at The Cornucopia Institute concur.

It’s imperative this regulatory language, for the protection of native ecosystems, is clear, concise, and well-defined—your voice is needed now to assure that organic standards truly protect the environment.

Organic producers and their certifiers need a clear regulatory background to support transitioning the right land into organic production.

Tell the NOSB to support clear language in the organic regulations to eliminate any incentive to convert native ecosystems to organic production.

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. Sample bullet points, which you can customize and paste into the website, can be found here.
  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.
  5. To learn more about these issues:

Please tell the USDA that you support The Cornucopia Institute’s comments on the NOSB’s regulatory addition to protect high-value lands threatened by conversion to agricultural use.

The following are the major concerns of Cornucopia’s allies, scientists, researchers, and policy analysts when it comes to protecting native ecosystems from destruction by agriculture:

  • The Organic Food Production Act of 1990 (OFPA) established that organic producers must conserve biodiversity and avoid any activities that would diminish it.
  • Sensitive ecosystems are being lost to organic agriculture at an alarming rate. A change in the rule, as suggested by the NOSB’s regulatory addition, to disincentivize conversion of native ecosystems into organic production is needed immediately to stem this loss.
  • Consumers assume that when they are buying organic products they are more environmentally friendly and sustainable—and this perverse incentive results in the loss of biodiversity and long-term sustainability.

Post your comments today—due in Washington by October 11, 2017.

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