Oregon Tilth submitted comments to the National Organic Program (NOP) Draft Guidance 5020 on Natural Resources and Biodiversity Conservation for Certified Operations.

Oregon Tilth strongly believes that natural resource and biodiversity conservation are foundational concepts of organic agriculture, and this is clearly reflected in the language of this draft guidance. We think that this guidance document will assist all organic operators, certifiers and inspectors to effectively implement and assess compliance with the natural resources and biodiversity conservation standard. Our review of the draft guidance revealed several areas where we believe the NOP can improve the clarity and impact of this guidance, which will result in more consistent, efficient and effective implementation by all.