Talking Points for Comments (Due October 11, 2017)

  • I support the addition of language to the organic regulations that will provide protections for sensitive, imperiled, and native ecosystems through removal of the incentive to immediately gain access to the organic market after the destruction of these ecosystems.
  • I support the NOSB’s suggested ten-year prohibition on the conversion of native ecosystems into organic agriculture.
  • Terms found in the organic regulations need to be well-defined to avoid loopholes that would perpetuate the same problems this addition is trying to solve. In particular, the term “native ecosystems” must be defined.
  • Prior land uses can be difficult or impossible to detect, so it’s important that lands are defined by their current characteristics (e.g., native vegetation prevalence). This will make the new standard easier to enforce and avoid unneeded confusion.
  • 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 lands.
  • I support the comments of The Cornucopia Institute and their ally, the Wild Farm Alliance, on this issue and hope you will take their suggestions seriously.

I am pleased that the NOSB is acting on this issue and considering the enormous negative impact on the environment from the loss of high-value ecosystems. Organic agriculture should never contribute to this loss—it goes against the tenets of the law and consumer perceptions.

Thank you for your commitment to this important issue.