Consider Coordinating EQIP Activities with the National Organic Program:
Comments of the Organic Trade Association to
Request for Public Comments,
Federal Register, Vol. 70, No. 55, Wednesday, March 23, 2005, pp. 14578-9
Associate Policy Director
June 5, 2005
The Organic Trade Association (OTA) thanks NRCS for this opportunity to comment. OTA, with 1600 members, is the sole membership association representing all sectors of the organic trade in the U.S.
OTA has had a Memorandum of Understanding with NRCS since 2001 regarding cooperation on areas common to organic production and natural resource conservation. We would like to take this opportunity to thank NRCS for its excellent work in addressing organic matters on its web site at: http://soils.usda.gov/sqi/soil_quality/land_management/organic.html.
OTA is particularly interested in having NRCS note, in its communications regarding EQIP, the off-site benefits to the environment provided by organic agriculture, especially reduction of non-point source pollution, such as nutrients of low solubility and persistent (rather than easily biodegradable) pesticides.
Under 7 CFR 205, establishing the National Organic Program (NOP) and regulating organic production and processing, organic producers are required to maintain or improve the quality of natural resources in a variety of contexts:
§205.2 Terms Defined.
Pasture: Land used for livestock grazing that is managed to provide feed value and maintain or improve soil, water, and vegetative resources.
Production practices implemented in accordance with this subpart must maintain or improve the natural resources of the operation, including soil and water quality.
§205.203 Soil fertility and crop nutrient management practice standard.
(a) The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion.
(d) A producer may manage crop nutrients and soil fertility to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances by applying….
§205.205 Crop rotation practice standard.
The producer must implement a crop rotation including but not limited to sod, cover crops, green manure crops, and catch crops that provide the following functions that are applicable to the operation:
(a) Maintain or improve soil organic matter content;….
In addition, organic producers are limited to biological and cultural pest control and prohibited from using persistent, non-biodegradable, synthetic pesticides.
OTA notes that NRCS has identified national measures that can help EQIP achieve its national priorities and statutory requirements more efficiently, including addressing multiple resource concerns and applying 60 percent of available EQIP financial assistance to livestock-related conservation practices. OTA urges NRCS to work with the National Organic Standards Board, which advises USDA on the implementation of the NOP, and has drafted a recommendation to require producers of organic ruminants to adhere to NRCS Conservation Practice Standard 528, Prescribed Grazing. This is a welcome step toward integrating organic practices with other USDA programs. OTA will continue to encourage such efforts from the organic perspective and hopes NRCS will work with NOP to find more avenues of cooperation.
The experience of the NRCS office in Minnesota, under State Conservationist William Hunt, in working with organic producers and those making the transition to organic production has been excellent, and OTA urges NRCS to consider promoting that program as an example of outreach to potentially eligible farmers. While other states made earlier attempts to integrate the transition to organic production with the EQIP program, Minnesota has to OTA’s knowledge produced the most effective program and policies.
OTA urges NRCS to consider outreach to both certified organic producers and those considering the transition to organic production, and to work with existing programs and bodies to promote NRCS EQIP priorities, while explicitly recognizing in its EQIP program the environmental benefits organic agriculture can contribute.
Thank you very much for your consideration.