Why Is the Biodiversity Rule for USDA Organic Certification Not Being Enforced?

Linley Dixon February 1, 2018

According to the National Organic Program, organic practices "foster cycling of resources, promote ecological balance and conserve biodiversity."

Regard­less of whether a farm is cer­ti­fied organ­ic or not, when you step on a real organ­ic farm, you know it. How? Bio­di­ver­si­ty. While sur­pris­ing to many, bio­di­ver­si­ty is not an eso­teric, incal­cu­la­ble qual­i­ty. In fact, it is rel­a­tive­ly easy to quan­ti­fy. And by law, cer­ti­fiers should be doing just that. Bio­di­ver­si­ty can be mea­sured in the soil, on the ground, or even in the air.

Lack of enforce­ment of the require­ment to con­serve bio­di­ver­si­ty on organ­ic farms is among the biggest fail­ures of USDA’s Nation­al Organ­ic Program.

The USDA reg­u­la­tions state that organ­ic pro­duc­tion responds to site-spe­cif­ic con­di­tions by inte­grat­ing cul­tur­al, bio­log­i­cal, and mechan­i­cal prac­tices that fos­ter cycling of resources, pro­mote eco­log­i­cal bal­ance, and con­serve biodiversity.”

If there is reg­u­la­to­ry lan­guage that man­dates bio­di­ver­si­ty on organ­ic farms, why are there so many cer­ti­fied organ­ic indus­tri­al mono­cul­ture oper­a­tions that so clear­ly vio­late this requirement?

The rea­son is that cer­ti­fiers cur­rent­ly attempt to qual­i­ta­tive­ly describe bio­di­ver­si­ty on the farm, rather than actu­al­ly quan­ti­ta­tive­ly mea­sur­ing it.

Organ­ic cer­ti­fiers should be trained to quan­ti­fy indi­ca­tors of farm bio­di­ver­si­ty. Lab analy­ses of soil sam­ples and plant sur­veys are just two meth­ods that can be used to mea­sure the vari­ety and rel­a­tive abun­dance of dif­fer­ent kinds of organ­isms in a farm ecosystem.

As a grad­u­ate stu­dent, I mea­sured the lev­els of plant bio­di­ver­si­ty on organ­ic farms to bet­ter under­stand how toma­to dis­eases spread. Species rich­ness (a sim­ple total count of species) and species even­ness (rel­a­tive abun­dance of each species) were record­ed across tran­sects. For diver­si­ty mea­sure­ments to be high, a plot must have had both rich­ness and evenness.

For exam­ple, if there were many dif­fer­ent plant species on the farm (high species rich­ness), but those species were all found in a nar­row hedgerow next to a hun­dred acres of toma­to mono­cul­ture (low species even­ness), the bio­di­ver­si­ty mea­sure­ment on the farm would be low.

Among the 200 cer­ti­fied organ­ic farms inspect­ed, most farms had very high plant bio­di­ver­si­ty levels.

On bio­di­verse farms, one tran­sect might pass through sev­er­al dis­tinct ecosys­tems: a toma­to plot, var­i­ous crop plants, cov­er crops, weeds, pas­tures, or even woods. How­ev­er, not all bio­di­verse farms are small. Even on some of the big­ger farms, acres of a sin­gle crop may have had cov­er crops between rows or sur­round­ing pas­ture, mead­ows, or forests with many dif­fer­ent species.

At the time of my study, in 2000, few­er cor­po­rate grow­ers had obtained organ­ic cer­ti­fi­ca­tion, but the push to co-opt the label had begun. It was painful­ly obvi­ous that indus­tri­al oper­a­tions weren’t real organ­ic farms (regard­less of all the paper­work that was checked by the cer­ti­fi­er dur­ing their inspection).

Cer­ti­fied organ­ic mono­cul­ture oper­a­tions clear­ly did not ful­fill the bio­di­ver­si­ty require­ments of the Organ­ic Foods Pro­duc­tion Act. Tran­sects across indus­tri­al-scale farms in dif­fer­ent direc­tions would turn up most­ly one plant — roma toma­toes, for example.

In large mono­cul­tures, dis­eases spread more rapid­ly and severe­ly. Not sur­pris­ing­ly, mono­cul­ture toma­to pro­duc­tion neces­si­tates week­ly pro­phy­lac­tic sprays of cop­per for dis­ease con­trol through­out the season.

Though the organ­ic cer­ti­fi­ca­tion require­ment for on-farm bio­di­ver­si­ty is not well-enforced, it eas­i­ly could be with some basic cer­ti­fi­er train­ing on how to mea­sure plant biodiversity.

Regard­less of the numer­ous pos­si­ble meth­ods to obtain real on-farm bio­di­ver­si­ty mea­sure­ments, the cur­rent qual­i­ta­tive descrip­tions can be applied too loose­ly and are clear­ly inad­e­quate. Con­verse­ly, it is hard to argue with numbers.

A bet­ter under­stand­ing of how sci­en­tists rou­tine­ly mea­sure bio­di­ver­si­ty is need­ed by all organ­ic stake­hold­ers to ensure the envi­ron­men­tal health of organ­ic farm ecosys­tems. The Nation­al Organ­ic Stan­dards Board should address the need for cer­ti­fiers to quan­ti­ta­tive­ly mea­sure bio­di­ver­si­ty on the farm to uphold the bio­di­ver­si­ty require­ments in the law.

(“Mea­sur­ing Bio­di­ver­si­ty on Organ­ic Farms: Legal­ly Man­dat­ed, But Ignored“ was orig­i­nal­ly pub­lished in the win­ter issue of The Cor­nu­copia Insti­tute’s quar­ter­ly newslet­ter and is repost­ed on Rur­al Amer­i­ca In These Times in accor­dance with their shar­ing policy.)

Lin­ley Dixon is Farm and Food Pol­i­cy Ana­lyst at The Cor­nu­copia Insti­tute. She owns a veg­etable farm (mar­ket­ing through a CSA, farm to school, and at farm­ers mar­kets) in Duran­go, Colo., with her hus­band and 4‑year-old daugh­ter. Pri­or to farm­ing, she spent 15 years study­ing the impact of farm diver­si­ty on plant dis­ease lev­els. She holds a Ph.D. in Plant Pathol­o­gy from the Uni­ver­si­ty of Flori­da and a Master’s in Plant and Soil Sci­ence through West Vir­ginia University’s Organ­ic Farm Project.
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