“Over the last two years the NOSB has received public comment describing loss of high value conservation and fragile ecosystem acreage when farmers transition to organic production,” in part because when lands are converted from a wild, “non-productive” state the three-year transition period for organic certification may be eliminated, the regulatory advisory committee writes in a discussion paper prepared for its semi-annual meeting in Denver this week.
This “unintended consequence” of the three-year transition requirement, “has negative impacts on biodiversity and, in the longer term, on economies,” and as such goes against the conservation of natural resources and biodiversity, which is a primary tenet of organic production, NOSB argues.
NOSB is proposing changes to the organic regulations to discourage conversion of native land to organic farms, by adding to the land requirements two clauses. One would require producers to actively monitor and, where possible, improve plant and animal biodiversity on the farm and not convert native ecosystems or high value conservation lands to agriculture use in the future.
The second would require that producers have not converted native ecosystems or high value conservation lands to agricultural production in the last five years.
At the meeting this week, NOSB also will ask stakeholders to provide more details on the conversion of high value lands and fragile ecosystems, consider how to define high value conservation land and fragile ecosystems, look for ways to better protect these lands under USDA organic certification and brainstorm other incentives or disincentives to prevent such conversion.
Diverging paths to success
The Cornucopia Institute and the Organic Trade Association both support NOSB’s intention, but believe different tactics are appropriate.
Noting that it is “disturbing” that organic regulations “actually encourage the immediate conversion of native lands to organic crop production because doing so eliminates the three-year transition period required when converting from conventional cropland,” The Cornucopia Institute agrees with the idea to prohibit eligibility of converted native lands for five years “at a minimum.”
OTA also supports NOSB’s efforts to eliminate the incentive to convert native ecosystems to organic production, but suggests doing so “is extremely challenging” as the transition period is rooted in law and regulations.
“We cannot require additional time for transition under any circumstance without an act of Congress to amend the Organic Foods Production Act and the USDA engaging in notice and comment rulemaking to amend the organic regulations,” OTA explains in comments to the NOSB Certification, Accreditation and Compliance Subcommittee.
Obviously, drafting a guidance would be a faster option, but it would not hold the same weight and enforceability as a law or regulation, it adds.
Encourage conversion of conventional farm land
With this in mind, OTA suggests NOSB take a different approach to discourage native land conversion by making it easier to convert existing conventional farm land.
“The incentive to convert native lands to organic production is due largely to the financial burden producers shoulder when they decide to convert their farms to organic,” OTA says in comments. “We encourage CACS also to consider ways that USDA could better support farmers through transition and increase the incentive to convert currently farmed land, rather than native land, to organic.”
For example, it suggests aligning organic farming practices with those eligible for financial support from NRCS through its Conservation Stewardship Program.
“Small steps to support farmers transitioning land from conventional production to organic can go a long way in reducing the incentive to convert natural ecosystems,” OTA concludes.