Take Action Today to Support Organic
Farming with the Wild
Send comments to the National Organic Standards Board (NOSB) before Monday November 3,
2008 to let them know that you support biodiversity conservation within organic agriculture.
A natural resource and biodiversity conservation standard is part of the National Organic Program
rule, but organic certification agencies are still not required to address this standard as part
of the accreditation process. See a sample letter in Resources below.
More Information for NOSB Public Comment:
At NOSB’s May 2008 meeting, Wild Farm Alliance (WFA) presented public testimony stating that Audit, Review and Compliance Branch’s (ARC) checklist for evaluating certification agents does not include the elements needed for implementation of the NOP standards related to protection of natural resources and biodiversity. WFA has identified and documented three specific changes to the text of ARC’s checklist, making this update is very simple to implement. Yet, such a change could have far-reaching positive effects on the protection of natural ecosystems in rural areas.
In its testimony last spring, WFA urged the NOSB work to ensure that NOP fully address these standards. As a result, on Tuesday, November 18th, a the NOSB committees on Crops and Compliance, Accreditation & Certification will discuss a paper drafted by NOSB member, Barry Flamm, called “Biodiversity, opportunities to strengthen a core organic principle.” WFA asks that public commentors mention their support of full implementation of the NOP standards for protecting natural resources and biodiversity (§205.200) through revision of the ARC checklist.
Background
In 2005, NOSB unanimously approved the addition of questions to its model “Organic Farm Plan” form that were aimed at addressing NOP regulations on natural resources. NOSB’s strong support for this action reflected the long-held understanding of the organic community that the protection of natural resources and biodiversity is a central tenet of organic production practices. Many certifiers are using this revised Organic Farm Plan, now available through ATTRA’s website, as a template for incorporating questions about natural resources in their systems for assessing crop and livestock farms.
Wild Farm Alliance’s learned this summer that the checklist that ARC uses when auditing certifiers for NOP accreditation does not include prompts to the auditor to verify that a certifier is implementing §205.200. As a result, accreditation auditors do not routinely verify whether certifiers are requiring farmers to provide information in their Organic Farm Plans about efforts to maintain or improve the natural resources of their farms or whether certifiers are looking for evidence of these practices when they perform on-site inspections of farms.
WFA believes it is important for NOP to ensure that all certifiers and operators are judged against the same standards, not only to create an equitable regulatory environment, but also to assure that expectations about the protection of natural resources by organic farmers are fully met. For these reasons, WFA is advocating for NOP to work with ARC to revise the checklist for evaluating certifiers by adding provisions for assessment of NOP standard related to natural resources and biodiversity.
Resources
• For details on the specific changes to ARC's audit checklist recommended by WFA and to see WFA’s testimony from NOSB’s May 2008 meeting: Click Here
• For a quick letter template: Click Here
• To submit your comments, link to the NOSB comment site: Click Here
• To view ATTRA’s Organic Farm Plan: Click Here
The questions related to protecting natural resources and biodiversity are on page 10 & 11.
• For more information about Wild Farm Alliance’s work on biodiversity and organic farming practices: Click Here
From this page you can download copies of WFA’s booklets on Biodiversity Conservation for farmers and certification agencies.