By Gordon Merrick, OFRF Policy & Programs Director
At OFRF, we believe conservation programs should work for every farmer, especially those using organic practices to build soil health, protect biodiversity, and enhance climate resilience. That is why we have submitted detailed public comments to the USDA Natural Resources Conservation Service (NRCS) in response to its proposed revisions to key Conservation Practice Standards (CPSs).
These standards form the backbone of how NRCS financial and technical assistance programs operate. When they don’t reflect the realities of organic production systems, organic farmers are often left behind.
Alongside the National Organic Coalition (NOC), we’re working to change that.
Our comments focus on ensuring that NRCS guidance, definitions, and planning tools meaningfully incorporate organic production systems, an area where the agency has made strides, but where key gaps remain. Our recommendations include:
- Explicit references to USDA National Organic Program (NOP) regulations in all revised practice standards.
- Restoration and expansion of organic-specific ecological strategies within CPS 595 – Pest Management Conservation System.
- Stronger support for composting and on-farm nutrient cycling in CPS 359 – Waste Treatment Lagoon and CPS 633 – Waste Recycling.
- Recognition of the unique ways organic farmers rely on functional ecosystems for pest control, pollination, and resilience to extreme weather events in CPS 645 – Wildlife Habitat and CPS 472 – Access Control.
- We have also urged NRCS to cite its own technical guidance for organic systems, Technical Note 12, and to streamline how Organic System Plans can integrate with conservation planning efforts.
These aren’t abstract policy ideas; they’re grounded in what organic farmers have told us they need to make these programs work on their farms.
We Need Your Voice
NRCS is accepting public comments through July 30th, 2025, on these proposed changes.
If you’re a researcher, farmer, technical service provider, or eater who wants to see conservation programs better serve organic operations, this is your moment, and we encourage you to submit your own comments.
That’s why we’re partnering with NOC to provide an easy-to-use grassroots comment platform that walks you through the process of submitting a personalized comment. Whether you’re new to commenting on the Federal Register or a seasoned voice, your perspective matters.
The more the Agency hears directly from the organic community, the stronger our case becomes for improving access and applicability for NRCS programming on organic operations. If you have expertise in topics related to conservation and organic agriculture, we’d love to hear from you and get connected!
Thank you for helping us make conservation work for everyone,
Gordon

