Talking Points for Comments (Due March 30, 2017)


Protecting our environment is part of organic agriculture. However, the destruction of high value conservation lands is inadvertently incentivized by the National Organic Program!

  • 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 into production, since this land is allowed to immediately be used for organic production.
  • The Organic Food Production Act of 1990 (OFPA) requires conserving and improving biodiversity as a foundational principle of organic agriculture. Incentivizing the destruction of high value lands disregards these principles.
  • Native ecosystems provide valuable services to all life, including cleaning air and water, preventing flooding, and mitigating climate change by acting as carbon sinks. The conversion of native ecosystems also causes the loss of these valuable services.
  • The lands that fall under the definition for “high value conservation lands” should include: any habitat or potential habitat for vulnerable, threatened, or endangered plants or animals. The list should also include rare ecosystems and areas that provide critical ecosystem services.
  • The destruction of native lands compromises the ability of future generations to meet their own needs. This is a basic tenet of sustainability that the NOP has neglected by allowing this incentive to continue.
  • A new rule, or an amendment to the current rule, should establish an extended waiting period (preferably five years) before organic producers can convert native ecosystems to production. This will end the current perverse incentive.
  • Guidelines should be developed in conjunction with a rule change to assist certifiers in their duties. Certifier education should be prepared to communicate with operators about conserving sensitive or valuable land.
  • Many other ecolabels do not allow the conversion of native ecosystems or other high value conservation land for agricultural production. The organic label should emulate these programs.
  • Organic methods restore land that has been depleted and damaged, returning it to sustainable production through appropriate cropping systems and livestock practices. This should be the gold standard for organic agriculture.

I urge you to consider the enormous negative impact on the environment from the loss of high value lands. Organic agriculture should never contribute to this loss – it goes against the tenets of the law and consumer perceptions.

Please consider the harm to organic integrity when standards are inconsistent and aberrant incentives are allowed to perpetuate.

Thank you for your commitment to this important issue.