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Draft Guidance 

Natural Resources and Biodiversity Conservation

for Certified Organic Operations

1. Purpose and Scope

The general natural resources and biodiversity conservation requirement of the U.S. Department 

of Agriculture (USDA) organic regulations at 7 C.F.R. § 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 C.F.R. § 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. Background

The conservation of natural resources and biodiversity is a tenet of organic production. For 

instance, native vegetation interspersed throughout a certified organic operation provides food, 

cover, and corridors for beneficial organisms, slows water down for erosion control and 

groundwater recharge, and filters pollution. Using practices that attract or introduce beneficial 

insects, provide habitat for predatory 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 (OSPs); 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.

3. Policy and Procedures

Role of Certified Organic Operations

• Certified organic operations and applicants for certification must develop and submit an 

OSP to a certifier. (7 C.F.R. § 205.201)

• In the OSP, the operation must address how it will conserve biodiversity by 

“maintain[ing] or improve[ing] natural resources, including soil and water quality,” as 

required by § 205.200 of the regulations. 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).

• Certified operations can 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 NRCS activities (e.g., conservation 

planning, or the Environmental Quality Incentives Program (EQIP)):

o The operation can reference Appendix A to identify which practices may be 

supported through NRCS as part of its conservation programs. 

1 NOSB Recommendation on Biodiversity Conservation. May 2009. Available on the NOP Web site, 

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5078051.

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o The operation may reference or provide evidence of a conservation plan 

developed in conjunction with NRCS instead of developing a separate OSP 

section for natural resources, provided that the conservation plan addresses all the 

requirements of 7 C.F.R. § 205.200 and other applicable portions of the USDA 

organic regulations. 

• The operation can also describe in its OSP the practices implemented to maintain or 

improve natural resources or biodiversity on a portion of land that is adjacent to the 

certified land, if this practice is likely to benefit 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 or, if applicable, NRCS conservation plan 

addresses the operation’s monitoring plan and practices to support natural resources and 

biodiversity, pursuant to § 205.200 of the regulations.

• Certifiers can refer to Appendix A for examples of practices that may support compliance 

with 7 C.F.R. § 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 C.F.R. § 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 

ensure that inspectors observe the conservation practices put in place, 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 land that 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 C.F.R. § 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 C.F.R. § 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 and handling.

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Role of Inspectors

• Inspectors must be qualified to assess compliance with 7 C.F.R. § 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 practices and monitoring approach that support the general 

natural resources conservation and biodiversity requirement, as described by the 

operation in its OSP. Inspectors may also confirm that any practices planned by NRCS 

are effectively implemented to support the USDA organic regulations.

• 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. 

4. 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.

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 General.

7 C.F.R. § 205.202 Land requirements.

7 C.F.R. § 205.203 Soil fertility and crop nutrient management practice standard.

7 C.F.R. § 205.205 Crop rotation practice standard.

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7 C.F.R. § 205.206 Crop pest, weed, and disease management practice standard.

7 C.F.R. § 205.207 Wild-crop harvesting practice standard.

7 C.F.R. § 205.238 Livestock health care practice standard.

7 C.F.R. § 205.239 Livestock living conditions.

7 C.F.R. § 205.240 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.

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Appendix A

Examples of Practices that May Maintain or Improve Natural Resources and Biodiversity

Topics

NRCS 

Assistance 

May Be 

Available2

Examples of Practices3

Examples Relevant to All Types of Organic Certification

Soil 

Composition



Adding organic matter to the soil to increase the diversity of 

soil organisms and to improve nutrient cycling, competitive 

exclusion of pathogens, long-term storage of soil carbon, and 

adaption to extreme climatic conditions. 



Conserving and restoring woodlands, prairies, riparian habitats 

and wetland areas, which sequester carbon in soils and aid in 

cycling soil nutrients.

Soil Stability 

and Water 

Quality



Creating, conserving, and restoring vegetative covers 

(woodlands, prairies, riparian habitat, and wetland areas) that 

control erosion and filter nutrient, pesticide, and pathogen 

pollutants.



Using no-till or permanent cover, conservation tillage, 

terracing, contour farming, micro-irrigation, windbreaks, cover 

crops; no conversion of Highly Erodible Land or wetlands.

4

Water 

Quantity

 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.



Woodlands, riparian habitat, and wetland areas that act as 

sponges to hold water for long periods are conserved and 

restored as part of a healthy water cycling process.

 Using managed systems to “bank” soil moisture if fields are 

drained using tiles.

Wildlife 

Benefits 

Maintaining or improving diverse mixtures of plants to provide 

food, habitat, or shelter for pollinators, insects, spiders and

other arthropods, bats, and raptors.

2 NRCS financial assistance programs 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. 

3 While NRCS publishes national Conservation Practice Standards (http://1.usa.gov/1n8fcHG), each State has its own technical 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). 4 The Farm Service Agency and NRCS Fact Sheet on Highly Erodible Land Conservation and Wetland Conservation Compliance 

(http://1.usa.gov/1xH45sT) defines highly erodible land and wetlands and provides information on the regulations that apply to each type of land.

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Native 

Species and 

Natural 

Areas of the 

Operation



Conserving high-value conservation areas that have 

outstanding biodiversity importance, or mitigating/restoring 

these areas elsewhere on the farm.



Conserving and restoring wildlife and native plant communities 

specific to the site (woodlands, prairies, riparian habitat, and 

wetland areas).

 Documenting rare, threatened, and endangered terrestrial and 

aquatic plants and animals, and taking steps to protect them.5

 Conserving wildlife corridors and large blocks of habitat that 

reduce fragmentation.

 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.6

Invasive 

Plants and 

Animals

 Closely monitoring invasive plants 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

Soil Stability 

and Water 

Quality

 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 runoff sediment before it 

leaves the farm.

Co-existing 

with Wildlife



Taking mitigation 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.

Supporting 

Wildlife

Strategically using mowing, tilling, and harvesting methods to 

preserve sites where wildlife raise their young. 

5 The NatureServe database( www.natureserve.org/explorer/) and the U.S. Fish and Wildlife Service database (http://endangered.fws.gov/ 

wildlife.html#Species) provide information on the conservation status of area plants and animals. 6 The NRCS PLANTS database (http://plants.usda.gov) provides information on native plants in each county of the U.S.

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Crop 

Diversity

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

Soil Stability 

and

Water 

Quality

 Managing the frequency, intensity, and timing of grazing and 

forage harvests to protect soil and water quality.

 Controlling access to sensitive riparian areas and wetlands as 

much as possible.

Wildlife  Composing pasture plantings of diverse species and managing 

them to support livestock and native species.

Co-existing 

with Wildlife

Using non-lethal predator control before lethal methods (e.g.,

guard animals, grazing large and small animals together, 

grazing when predation is low, or housing vulnerable animals 

overnight).



Encouraging diverse native landscapes that support natural 

prey for carnivorous animals to reduce the carnivores’ 

predation of livestock.

 Using wildlife-friendly fencing as much as possible.

Livestock 

Diversity

Raising a variety of livestock, including heirlooms, or several 

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

Soil Stability 

and Water 

Quality

Using practices for wild harvest that maintain or improve soil 

stability.

Using practices for wild harvest that maintain or improve water 

quality.

Native 

Species and 

Natural 

Areas of the 

Operation

Maintaining the sustainability of harvested native plants and 

animals and associated species when determining the quantity 

and timing of the wild harvest.

Examples Specific to Handling Operations

Air and 

Water 

Quality

Operations that use dust collection systems have up-to-date 

permits for their operation.

 Using constructed wetlands to improve wastewater quality. 

When necessary, processing wastewater using secondary or 

tertiary treatment prior to flowing through the wetland.

Wildlife 

Benefits  Locating raptor perches around packing sheds and processing facilities to control rodents without using toxins. 

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Co-existing 

with Wildlife

Avoiding harm to wildlife from processing waste. 

Strategically placing lighting around buildings to lessen the 

need for insectocutors (e.g., placing light fixtures away from 

vents, windows, or doors).

Removing habitat and food sources from directly adjoining 

areas where pests could enter the facility, to decrease the need 

to destroy pest insects, birds or mammals.

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