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FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _August 17, 2005________

Subject: __NOSB Organic System Plan revisions to address better natural resources of the operation_ 

Chair: ____Jim Riddle______________________________________ 

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ________ 

Guidance Statement: ________ 

Other: ___X_____ 

Statement of the Recommendation (including Recount of Vote):

The NOSB recommends that the attached version of Section D – Natural Resources replace the current NOSB 

Organic System Plan, Section D. 

Board vote – August 16, 2005 

13 yes, 0 no, 1 absent 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

Rationale provided in text of recommendation below. 

Response by the NOP:

Updated 2/25/05 
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National Organic Standards Board 

Crops Committee Recommendation for 

Modification of the Organic System Plan 

Adopted by the National Organic Standards Board 

August 16, 2005 

Introduction 

The National Organic Standards Board (NOSB) created a model Organic System Plan (OSP) as 

guidance for implementation of the regulations (The Rule) of the National Organic Program 

(NOP). The Natural Resource section of the OSP has been modified to help implement the 

existing biodiversity regulations in The Rule. 

Background: 

The NOP rule definition of organic production includes conserving biodiversity and the preamble 

of the rule explicitly states, "The use of 'conserve' establishes that the producer must initiate 

practices to support biodiversity and avoid, to the extent practicable, any activities that would 

diminish it." In another section, the rule states, "Production practices...must maintain or 

improve the natural resources of the operation, including soil, water, wetlands, woodlands and 

wildlife." 

The Independent Organic Inspectors Association first called attention to the fact that biodiversity 

educational materials and criteria were needed for their inspector trainings and requested that 

the Wild Farm Alliance (WFA) assist them with this effort. Through support of the Organic 

Farming Research Foundation and others, WFA formed a broad-base of organic farmers, 

certifiers and conservationists (see initial list below) to develop biodiversity criteria and 

supporting guides for farmers, inspectors, and certifiers. 

At the NOSB’s fall 2004 meeting, WFA requested that the Board approve biodiversity criteria 

into their model Organic System Plan. The request was sent to the Crops Committee and over 

the winter revisions were made. The Board then unanimously agreed to approve draft text on 

biodiversity conservation at their spring 2005 meeting. Further refinement occurred with 

assistance from the National Center for Appropriate Technology (NCAT) (see second list 

below). 

Many certifiers have adopted the NOSB’s model OSP form, even though it is not required for 

accreditation. The existence and use of the model forms helps bring consistency to inspection, 

certification, and accreditation processes. Approval of the biodiversity amendment to the 

NOSB’s model OSP will provide transparent and predictable guidance to farmers, inspectors, 

certifiers, and accreditation auditors. 

List of Initial Collaborators: 

Harriet Behar, organic inspector, farmer, and educator; Stacey Carlson, Marin County 

Agricultural Commissioner; Scott Exo, Director, Food Alliance; Sean Feder, Inspections 

Operations Director, California Certified Organic Farmers; Phil Foster, Foster Ranch; 

Tim Franklin, Applegate River Watershed Council, and Yale Creek Ranch; Tom Gardali, Senior 

Biologist, Point Reyes Bird Observatory Conservation Science; Pete Gonzalves, Director of 

Oregon Tilth; Randy Gray, Wildlife Biologist, NRCS; Jessica Hamburger, Consultant; Dan Kent, 

Director, Salmon-Safe; Jim Riddle, Endowed Chair, University of Minnesota and Vice Chair of 

National Organic Standards Board; Margaret Scoles, Director, Independent Organic Inspectors 
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Association; Becky Weed, Thirteen Mile Lamb and Wool Company; Sarah Vickerman, Director 

of West Coast Office of Defenders of Wildlife; Jo Ann Baumgartner, Director of Wild Farm 

Alliance; Laura Smith, Associate of Wild Farm Alliance. 

List of NCAT’s Stakeholder Team: 

Lisa Cone, Waterfall Hollow Farm; John Foster, Quality Assurance International; Jim Riddle, 

Organic Independents & NOSB; Joyce Ford, Organic Independents; Diane Collins, Midwest 

Organic Services Assoc.; Cissy Bowman, Indiana Certified Organic; Brenda Book, Washington 

State Dept. of Ag.; Katherine Withey, Washington State Dept. of Ag.; Kelly Shea, Horizon 

Organic; Liana Hoodes, Nat’l. Campaign for Sust. Ag.; Jo Ann Baumgartner, Wild Farm Alliance; 

Pam Riesgraf, Organic Valley; Kathy Turner-Clifft, Doubletree Ranch LLC; Lisa McCrory, 

NOFA-VT; Ann Wells, Springpond Holistic Animal Health; Keith Jones, NOP; Barbara Robinson, 

NOP; Mark Bradley, NOP; Holly Born, NCAT; Paul Williams, NCAT; Nancy Matheson, NCAT; 

Lance Gegner, NCAT; Mark Keating, NCAT; Ann Baier, NCAT; George Kuepper 

Recommendation: 

The NOSB recommends that the attached version of Section D – Natural Resources replace the 

current NOSB Organic System Plan, Section D. 

NOSB vote: 

Yes: 13 

No: 0 

Abstain: 0 

Absent: 1
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D. NATURAL RESOURCES: 

NOP Rule 205.2 defines Organic Production as a production system managed in accordance with the Act and its regulations to respond to sitespecific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and 

conserve biodiversity. NOP Rule 205.200 and 205.203(a) requires that production practices maintain or improve natural resources (soil and 

water quality, wetlands, woodlands and wildlife) of the operation. 

BIODIVERSITY MANAGEMENT 

Whole Farm Biodiversity Considerations: 

Does your field map include features such as hedgerows, woodlands, wetlands, riparian zones, and special habitats? 

yes no

List native plants present, and/or wildlife seen moving through farm: (note priority species) _________________________ 

_____________________________________________________________________________________________________________ 

What steps do you take to plan/provide for biodiversity conservation? 

understand farm’s location within watershed ascertain what native plants and animals existed on the land before it was a farm learn 

about regional natural areas and conservation priorities work with neighbors/others to enhance biodiversity (connectivity, restoration, etc.) 

other* describe/explain: 

How do you manage water for the needs of crops/livestock, native species and riparian ecosystems? 

 plant regionally appropriate crops  conserve water manage water for priority species  retain/restore vegetated riparian 

buffers/wetlands protect/improve natural hydrology/ecological function of riparian area other* 

Uncultivated Area Biodiversity:

What actions do you take to provide habitat for pollinators, insect predators, birds and bats? 

 bird/bat/bee boxes hedgerows/windbreaks maintain/provide natural roosting/nesting/foraging sites other* 

How are you restoring and/or protecting natural areas? 

manage for native plants/wildlife specific to the site  preserve/restore wildlife corridors establish legal conservation areas 

native habitats not converted to farmland since certification  other* 

List problem invasives: _______________________________________________________________________________________ 

What actions do you take to control invasive plant/animal species, especially those threatening natural areas? 

learn about invasives use weed- and pest-free seed/planting stock/soil amendments/mulches monitor for new introductions and control 

immediately suppress invasives using organic methods other* 

Cropland Area Biodiversity:

How do you conserve and provide habitat for wildlife? 

companion planting/intercropping crop diversity wildlife-friendly fences manage fallow fields for wildlife other* 

Do you schedule farm practices to benefit wildlife? 

 avoid nests during breeding season stagger mowing/tilling practices plan fields to leave food/cover for wildlife other* 

Biodiversity When Livestock are Involved:

How do you protect riparian areas and sensitive habitats? 

 fence without impacting wildlife control sensitive area access prevent bank erosion animals fed away from water other* 

What are you doing to improve your pasture or rangeland? 

prevent overgrazing reseed trampled/eroded areas plant native pasture active grazing management system prescribed burning 

 other* 

What wildlife-friendly management practices do you use? 

guard animals grazing scheduled when predation pressure low livestock spend night in protected area circumstances of livestock 

death documented other* 

list problems with predators or other wildlife:_________________________________________________________________________ 

Have you assessed the farm for biodiversity problems and greatest opportunities, and developed goals an a timeline 

for biodiversity conservation? yes no describe/explain:

How do you monitor farm biodiversity? 

 visually species counts other*

Wild Harvest Enterprises Biodiversity: 

How do you maintain or improve the sustainability of the harvested species? 

 harvest from stable populations minimize disruption of priority species/sensitive habitats avoid erosion allow re-establishment 

monitor wild crop sustainability other* 

*If you check other, please explain 

___________________________________________________ 

Add the following boxes under the Natural Resources: Water Use: What practices are used to protect water quality? 

sediment basin compost/fertilizer stored away from water