USDA’s National Organic Program guidance on biodiveristy and conservation for organic production and certification.
United States Department of Agriculture
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Guidance
Natural Resources and Biodiversity Conservation
Links Update: August 31, 2018
1.
Purpose and Scope
The general natural resources and biodiversity conservation requirement of the U.S. Department
of Agriculture (USDA) organic regulations at 7 CFR § 205.200 requires operations to “maintain
or improve the natural resources of the operation, including soil and water quality.” Section
205.2 of the regulations defines “natural resources of the operation” as the “physical,
hydrological, and biological features of a production operation, including soil, water, wetlands,
woodlands, and wildlife.” [Emphasis added.] “Organic production” is defined as a “production
system that is managed to respond to site-specific conditions by integrating cultural, biological
and mechanical practices that foster cycling of resources, promote ecological balance, and
conserve biodiversity.” [Emphasis added.]
The preamble to the final rule establishing the NOP explained, “[t]he use of ‘conserve’ [in the
definition of organic production] establishes that the producer must initiate practices to support
biodiversity and avoid, to the extent practicable, any activities that would diminish it.
Compliance with the requirement to conserve biodiversity requires that a producer incorporate
practices in his or her organic system plan that are beneficial to biodiversity on his or her
operation.” (76 FR 80563)
Given the broad scope of these definitions, “maintain[ing] or improve[ing] natural resources in
organic production” necessarily encompasses a range of conservation principles, including, but
not limited to: protecting riparian areas; supporting native species and habitat; minimizing
invasive species; maintaining air quality; promoting crop diversity and plant condition; and
improving soil condition. This guidance provides examples of production practices that support
these conservation principles and demonstrate compliance with 7 CFR § 205.200.
This guidance also clarifies: 1) the certified organic operator’s responsibility to select, carry out,
and record production practices that “maintain or improve the natural resources of the
operation;” 2) the accredited certifying agent’s (certifier) responsibility to verify operator
compliance with this requirement; and 3) how domestic organic operations that participate in a
USDA Natural Resources Conservation Service (NRCS) program and the National Organic
Program (NOP) can reduce their paperwork burdens.
This guidance applies to all certifiers, certified organic operations, and new applicants for
certification.
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2.
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Background
The conservation of natural resources and biodiversity is a primary tenet of organic production.
For instance, native vegetation interspersed throughout a certified organic operation provides
food, cover, and corridors for beneficial organisms such as pollinators, slows water down for
erosion control and groundwater recharge, and filters pollution. Using practices that attract or
introduce beneficial insects, provide habitat for birds and mammals, and provide conditions that
increase soil biotic diversity serve to supply vital ecological services to organic production
systems. Advantages to certified organic operations that implement these types of production
practices include: 1) decreased dependence on outside fertility inputs; 2) reduced pest
management costs; 3) more reliable sources of clean water; and 4) better pollination.
The National Organic Standards Board (NOSB), a federal advisory committee that advises the
USDA on organic issues, has made multiple recommendations related to natural resources
conservation and biodiversity. The May 2009 NOSB recommendation asked the NOP to
establish: 1) consistent discussion and review of biodiversity protection and enhancement in all
certified operations’ organic system plans; 2) increased education and information for certified
operations, inspectors, and certifiers; 3) uniformity of inspection and certification procedures
with regard to how certified operations implement the biodiversity standards; 4) incorporation of
biodiversity standards into the procedures for accreditation and certifier audits; and 5) use of
materials evaluation criteria that foster consideration of biodiversity conservation when adding
or deleting materials from the National List of Allowed and Prohibited Substances. 1 This
guidance addresses the first three components of the recommendation. Its purpose is to give
operators and certifiers examples of activities that would fulfill natural resource and biodiversity
conservation requirements.
3.
Policy and Procedures
Role of Certified Organic Operations
•
•
Certified organic operations and applicants for certification must develop and submit an
organic system plan (OSP) to a certifier. (7 CFR § 205.201)
In the OSP, the operation must describe or list activities (plans, practices and
enhancements) that explain how it will comprehensively conserve biodiversity by
maintaining or improving all natural resources, including soil, water, wetlands,
woodlands, and wildlife, as required by § 205.200 of the regulations and per the § 205.2
definition of Natural resources of the operation. In many cases, the certifier will provide
the operation with an OSP template with a designated section for the operation to
describe its activities and its biodiversity monitoring approach (e.g., visual assessment of
soil erosion, species counts for biodiversity, or testing for water quality).
1
NOSB Recommendation on Biodiversity Conservation. May 2009. Available on the NOP Web site,
http://www.ams.usda.gov/sites/default/files/media/NOP%20Final%20Rec%20Biodiversity.pdf.
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•
•
•
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Certified operations may reference Appendix A to understand the types of production
practices that could be used to support natural resources conservation and biodiversity.
For certified operations that also participate in USDA Natural Resources Conservation
Service (NRCS) activities (e.g., conservation planning, Conservation Stewardship
Program (CSP), or the Environmental Quality Incentives Program (EQIP), etc.):
o The operation can reference Appendix A to identify which practices may be
supported through NRCS as part of its conservation programs.
o The operation may refer to a current conservation plan and/or contract developed
in conjunction with NRCS 2 or other conservation agency or non-governmental
organization as part of their OSP, to meet the requirements of 7 CFR. § 205.200.
For split operations or for operations that have non-certified portions of their property,
the operation can also describe in its OSP the practices implemented to maintain or
improve natural resources or biodiversity on a portion of their land that is not certified
but is adjacent to the certified land, if this practice directly benefits the certified land.
o For example, an operation may install grassed waterways or riparian strips at
locations adjacent to its certified crops. When successfully implemented and
maintained, these features would support the operation’s overall water and soil
quality. The operation could include a description of these activities in its OSP.
The operation must implement and maintain the planned production practices as
described in its OSP and maintain any records (e.g., activity logs for mowing, pest
monitoring, limits on livestock access to waterways, reseeding areas, grazing rotations;
water or soil testing results; visual observations; or conservation maps) that would
support a certifier’s ability to verify compliance.
Role of Certifiers
•
•
•
•
Certifiers must ensure that an operation’s OSP describes or lists practices that explain the
operation’s monitoring plan and practices to comprehensively support natural resources
and biodiversity conservation, pursuant to § 205.200 of the regulations.
Certifiers can refer to Appendix A for examples of activities (plans, practices, and
enhancements) that may support compliance with 7 CFR § 205.200.
A certified operation’s monitoring plan could include the frequency of monitoring, the
types of observations or testing the operation plans to conduct, and the method of
documentation.
Certifiers must verify compliance with 7 CFR § 205.200 by ensuring that certified
organic operations are implementing their planned production practices to conserve
natural resources and biodiversity. As part of the onsite inspection, certifiers should
2
Organic crop and livestock producers who are located in the United States and its territories and who are planning to transition land to organic
production may be eligible for technical and financial assistance through NRCS to develop and implement plans for addressing natural resource
concerns. One option is to work with an NRCS’s certified outside vendor or Technical Service Provider (TSP), to complete a Conservation
Activity Plan (CAP) 138. To reduce paperwork, the National Organic Program (NOP) developed Resource Inventory Supplements as a
companion to the CAP 138 Resource Inventory (Section 1). Instead of completing a full separate organic system plan (OSP) for their certifier,
organic producers who are approved for and complete a CAP 138 may submit to their certifiers the CAP 138 Resource Inventory section together
with the necessary Resource Inventory Supplement(s). When submitted together, these documents contain all the required components of a
complete OSP. For more information visit: http://www.ams.usda.gov/sites/default/files/media/2616.pdf
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ensure that inspectors observe the conservation practices implemented, or review records
that support implementation of conservation practices.
If a certified operation is implementing practices to conserve natural resources or
biodiversity on a portion of its land that is not covered under its organic certification but
is adjacent to the certified land, and this practice directly benefits the certified land, then
the inspector and certifier may consider such practices in the assessment of whether a
producer meets the requirements.
Pursuant to 7 CFR § 205.504, certifiers should ensure that inspectors are sufficiently
qualified to effectively assess compliance with the general natural resources conservation
and biodiversity requirement at 7 CFR § 205.200. Qualifications may include, but are not
limited to, the inspector’s knowledge, training, and experience observing and assessing
conservation activities and monitoring in organic production.
Role of Inspectors
•
•
•
4.
Inspectors must be qualified to assess compliance with 7 CFR § 205.200. More
specifically, inspectors must be able to recognize and evaluate areas where: 1) natural
resources and biodiversity are already conserved; 2) conservation projects are planned;
and 3) improvement is needed.
During the onsite inspection, inspectors must verify the accuracy and implementation of
the operation’s production activities (plans, activities and enhancements) and monitoring
approach that support the general natural resources conservation and biodiversity
requirement, as described by the operation in its OSP. Inspectors may also review
implementation of the operation’s production activities in relation to CAP 138
documentation submitted in place of a traditional OSP.
During the onsite inspection, inspectors may note exceptions to the conservation
requirement such as extreme climatic conditions, or damage to the ecosystem beyond the
control of the operation. The inspector should communicate this information to the
certifier for consideration as part of its review and certification decision.
References
USDA Organic Regulations (7 C.F.R. Part 205)
7 C.F.R. § 205.2 Terms Defined.
Crop rotation. The practice of alternating the annual crops grown on a specific field in a
planned pattern or sequence in successive crop years so that crops of the same species or
family are not grown repeatedly without interruption on the same field. Perennial
cropping systems employ means such as alley cropping, intercropping, and hedgerows to
introduce biological diversity in lieu of crop rotation.
Natural resources of the operation. The physical, hydrological, and biological features of
a production operation, including soil, water, wetlands, woodlands, and wildlife.
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Organic production. A production system that is managed to respond to site-specific
conditions by integrating cultural, biological, and mechanical practices that foster cycling
of resources, promote ecological balance, and conserve biodiversity.
Pasture. Land used for livestock grazing that is managed to provide feed value and
maintain or improve soil, water, and vegetative sources.
Soil and water quality. Observable indicators of the physical, chemical, or biological
condition of soil and water, including the presence of environmental contaminants.
7 C.F.R. § 205.200
7 C.F.R. § 205.202
7 C.F.R. § 205.203
7 C.F.R. § 205.205
7 C.F.R. § 205.206
7 C.F.R. § 205.207
7 C.F.R. § 205.238
7 C.F.R. § 205.239
7 C.F.R. § 205.240
General.
Land requirements.
Soil fertility and crop nutrient management practice standard.
Crop rotation practice standard.
Crop pest, weed, and disease management practice standard.
Wild-crop harvesting practice standard.
Livestock health care practice standard.
Livestock living conditions.
Pasture practice standard.
NOSB Recommendations
Joint Crops & Compliance, Accreditation, and Certification Committee, NOSB
Recommendation, “Implementation of Biodiversity Conservation in Organic Agriculture
Systems,” May 2009.
Other Laws and Regulations
Endangered Species Act of 1973, 16 U.S.C. § 1531 et seq.
Approved on January 15, 2016
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Appendix A
Examples of Activities (Plans, Practices, and Enhancements) that May Maintain or Improve
Natural Resources and Biodiversity
Throughout the U.S. and the world, topography, climate, soils, and biodiversity vary widely. The
following examples outline beneficial activities within certain ecological contexts that organic
operations may use to maintain or improve biodiversity in their operations. This is not an
exhaustive list. There are many other activities in varied ecological settings that operations can
use to reach the same compliance goal.
Topics
NRCS
Assistance
May Be
Available 3
Examples of Activities 4
Examples Relevant to All Types of Organic Certification
Soil
Composition
Soil Stability
and Water
Quality
Adding organic matter through the diversity of crops and
inputs, to the soil to increase the diversity of soil organisms and
to improve nutrient cycling, competitive exclusion of plant
pathogens, long-term storage of soil carbon, and adaption to
extreme climatic conditions and water holding capacity.
Conserving and restoring forests, shrublands, woodlands,
grasslands, riparian area 5 and wetland areas, which sequester
carbon in soils and aid in cycling soil nutrients.
Creating, conserving, and restoring vegetative covers (forests,
shrublands, woodlands, grasslands, riparian areas, and wetland
areas) that control erosion and filter nutrient, pesticide, and
pathogen pollutants. Minimizing disturbances, maximizing
diversity, living roots and cover.
Using no-till or permanent cover, conservation tillage,
terracing, contour farming, micro-irrigation, windbreaks, cover
crops, grass waterways and soil health practices.
3
NRCS assistance options are listed at http://1.usa.gov/1kwzgz0. NRCS staff and technical service providers may reference this chart as part of
conservation planning for organic producers.
4 While NRCS publishes national Conservation Practice Standards (http://1.usa.gov/1n8fcHG), each State has its own technical standards and
specifications, which can be accessed electronically through the NRCS Field Office Technical Guide (http://efotg.sc.egov.usda.gov/) or by
contacting your local USDA Service Center (http://1.usa.gov/1kwzgz0).
5
Riparian areas are plant communities contiguous to and affected by surface and subsurface hydrologic features of perennial or intermittent lotic
and lentic [moving and standing] water bodies (rivers, streams, lakes, or drainage ways). Riparian areas have one or both of the following
characteristics: 1) distinctly different vegetative species than adjacent areas, and 2) species similar to adjacent areas but exhibiting more vigorous
or robust growth forms. Riparian areas are usually transitional between wetland and upland. Definition from USFWS. A System for Mapping
Riparian Areas In The Western United States. Nov 2009.
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Water
Quantity
Wildlife
Benefits
Native
Species and
Natural
Areas of the
Operation
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For lands coming into production for the first time or returning
to production (e.g. Conservation Reserve Program (CRP) lands
leaving the federal program and requesting organic
certification), a new conservation plan can examine and
implement a range of alternative practices to enhance the
natural resources of the land.
Using water conservation techniques that save water for crops,
livestock, wildlife, and riparian ecosystems.
Choosing crops and other plants that are appropriate for the
climate and landscape with water conservation in mind.
Using suitable irrigation systems and schedules and
monitoring them for water conservation.
Conserving or restoring forests, shrublands, woodlands,
grasslands, riparian habitat, and wetland areas that absorb and
hold water for long periods as part of a healthy water cycling
process.
Using managed systems to “bank” soil moisture if fields are
drained using tiles.
Maintaining or improving diverse mixtures of plants to provide
food, habitat, or shelter for pollinators, insects, spiders and
other beneficial organisms such as arthropods, bats, and
raptors.
Conserving high conservation value 6 areas that have
outstanding biodiversity 7 importance, or mitigating/restoring
these areas elsewhere on the farm.
Conserving and restoring wildlife and native plant communities
specific to the site (forests, shrublands, woodlands, grasslands,
riparian habitat, and wetland areas).
Documenting rare, threatened, and endangered terrestrial and
aquatic plants and animals 8 and ecologically at risk
ecosystems 9 and taking steps to protect them.
Conserving wildlife corridors and large blocks of habitat that
reduce fragmentation.
6
High conservation value area has a biological, ecological, social or cultural value of outstanding significance or critical importance. Definition
from HCV Resource Network. https://www.hcvnetwork.org/
7
Biodiversity, or biological diversity, is the diversity of life existing at three levels: genetic, species, and ecosystem. Therefore, biological
diversity (biodiversity) includes variety in all forms of life, from bacteria and fungi to grasses, ferns, trees, insects, and mammals. It
encompasses the diversity found at all levels of organization, from genetic differences between individuals and populations (groups of related
individuals) to the types of natural communities (groups of interacting species) found in a particular area. Biodiversity also includes the full range
of natural processes upon which life depends, such as nutrient cycling, carbon and nitrogen fixation, predation, symbiosis and natural succession.
Definition from the May 2009 NOSB recommendation.
8
The NatureServe database (http://explorer.natureserve.org/) and the U.S. Fish and Wildlife Service database provide information on the
conservation status of area plants and animals in the U.S. and Canada, and the IUCN Red List of Threatened Species and Key Biodiversity Areas,
as indicated in the IBAT for Business Tool (https://portals.iucn.org/library/efiles/documents/2014-004.pdf) provides information on the
conservation status of plants, animals, and areas internationally.
9
The NatureServe webpages (http://explorer.natureserve.org/servlet/NatureServe#) and (http://explorer.natureserve.org/granks.htm) provide tools
for defining “at risk” ecosystems, and learning about ecosystems in general (http://explorer.natureserve.org/index.htm), but do not have a function
to track locations of “at risk” ecosystems. The best available conservation tracking tools are for those for tracking species.
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Invasive
Plants and
Animals
Soil Stability
and Water
Quality
Co-existing
with Wildlife
Supporting
Wildlife
Crop
Diversity
Soil Stability
and
Water
Quality
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Making improvements to streams, lakes, and rivers, enhancing
habitat for fish and other aquatic species.
Allowing degraded riparian areas, prairies, and wetlands to be
recolonized through natural processes.
Actively restoring degraded land to its native habitat using
species adapted to and historically present in the area. 10
Closely monitoring invasive plants 11 12 and animals threatening
natural areas.
Controlling invasive species before they spread.
Avoiding seed, planting stock, soil amendments, and mulches
that may import weed seeds and other pests.
Examples Specific to Crop Operations
Using nutrient budgets to protect water quality by managing
crop nutrients.
Designing grassed waterways, filter strips, terraces, and other
non-crop vegetation, and managing them to help control
erosion and filter pollutants before they reach water bodies.
Using stream crossings, brush mattresses, and other engineered
features to prevent erosion where year-round or intermittent
water flows.
Using sediment basins to capture eroded or disturbed soil
before it leaves the farm.
Taking measures to minimize total habitat loss on adjacent land
when wildlife is restricted from entering the production area.
Designing and using management strategies as much as
possible to repel, rather than destroy, intended and unintended
species.
Using strategic mowing, tilling, and harvesting methods to
preserve sites where wildlife raise their young.
Growing a variety of crop types, heirloom crops, or several
genetic strains of the same crop.
Growing locally-adapted seed varieties or those suited to sitespecific conditions.
Examples Specific to Livestock Operations
Managing the frequency, intensity, and timing of grazing and
forage harvests to protect soil and water quality. Manure
management including storage and feedlot runoff.
Controlling access to sensitive riparian areas and wetlands as
much as possible.
The NRCS PLANTS database (http://plants.usda.gov) provides information on native plants in each county of the U.S.
Invasive plants and animals are non-native (or alien) to the ecosystem under consideration and whose introduction causes or is likely to cause
economic or environmental harm or harm to human health. Invasive species can be plants, animals, and other organisms (e.g., microbes). Human
actions are the primary means of invasive species introductions. Definition from the National Invasive Species Information Center
www.invasivespeciesinfo.gov/
12
The National Invasive Species Information Center website (http://www.invasivespeciesinfo.gov/) provides information on invasive species in
each state of the U.S., and the Global Invasive Species Database (www.issg.org/) provides information on invasive species internationally.
10
11
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Wildlife
Co-existing
with Wildlife
Livestock
Diversity
Soil Stability
and Water
Quality
Native
Species and
Natural
Areas of the
Operation
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Composing pasture plantings of diverse species and managing
them to support livestock and native species.
Using non-lethal predator control before lethal methods (e.g.,
guard animals, grazing large and small animals together,
grazing when predation is low, wildlife escape ramps, or
housing vulnerable animals overnight).
Encouraging diverse native landscapes that support natural
prey for carnivorous animals to reduce their predation of
livestock.
Using wildlife-friendly fencing.
Raising a variety of livestock, including heirloom breeds, or
different breeds of the same livestock.
Preserving locally-adapted livestock breeds, or raising those
well suited to site-specific conditions.
Examples Specific to Wild Harvest Operations
Using practices for wild harvest that maintain or improve soil
stability.
Using practices for wild harvest that maintain or improve water
quality.
Maintaining the sustainability of harvested native plants and
animals and associated species when determining the quantity
and timing of the wild harvest.
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