Comments from different organizations often overlapped or complemented each other. Sometimes they contradicted. The top three comment categories were General, Cover Crops, and Conservation Practices. The notes below are an attempt to distill the comments made either for the WILD Index generally or for one of the individual component of the index.

In general, organizations acknowledged the WILD Index is most likely an improvement over the HPI. The components are correlated with biodiversity outcomes, and IPM is now featured more fully. The burden of data input seems reasonable.

Some higher-level themes were noticed, including:

1. Are we sure we can rely on a practice-based index for biodiversity claims?
2. Can we align with other standards?
3. Desire for index to be more relative or regional
4. Need for analyses (sensitivity, scenarios, benchmarks, etc)

We acknowledge that the space around biodiversity measurements is evolving. Some opt for practice-based programs, while others push for groundtruthing and outcomes. Some are more region or species specific, while others aim for generalities and correlations.

Some comments we received on aligning with other biodiversity initiatives/standards mentioned TNFD, Align Framework, SBTN, WBCSD, and Nature Positive Initiative.

The WILD Index and the Fieldprint Platform need to better account for cover crops and their management. Multiple organizations pointed out ways to improve the cover crop component or at least the documentation.

• Recognize winter crops like winter wheat as a source of vegetative cover

• Include summer cover crops

• Should we consider cover crop termination method?

• Add/increase points for winter terminal multi-species that grew for 75 days and produced grain for wildlife.

• Clarify the following:

  • Define what is a multi-species cover crop

  • Do winter weeds count as a cover crop?

  • What constitutes a sufficient stand of biomass?

    • Should or should not get points for planting without results?

One argued that the goal of the Cover Crop, Tillage, and Crop Rotation components seemed to be awarding points for providing in-field vegetation cover. If so, they suggested the possibility of combining these in some way to become a single component that represents standing vegetation cover in the field area. Doing so could also simplify the index calculation and interpretation.

Multiple comments raised the desire for site-specific biodiversity goals, where the practices available are relative to what a grower could achieve at their locaiton. Implementing a conservation practice in a place where it will have little effect should not result in points.

A temporal component of conservation practices suggests that the establishment and benefit of a practice takes time to develop. This temporal component is missing from the WILD Index.

Another issue raised was how many practices are focused on upland crops, and may not adequately represent the unique system that is rice production. For instance, in-season wetting of rice fields is positive for biodiversity, but is not yet listed in the edge-of-field or post-harvest practices.

Related to water development, one commenter pointed out that should aquatic environments be created, there should be accounting for the distance to water some chemical (with distance restrictions) are applied.

On the technical side, we may need to clear up what practices are in our CPPE matrix, and clarify the version used and point scales. Could the CPPE be state/region specific?

We originally proposed the Shannon Index be incorporated into the index calculation.

This was the only component of the WILD Index that deducts points. The penalty is based on the biodiversity loss expected due to the recent conversion of natural lands to production. The comments received raised some important issues around how to standardize land conversion history.

• How will the index handle cropland coming out of the Conservation Reserve Program?

• What if the land was converted to cropland prior to the current grower? Will the current grower still be penalized?

• Does the index account for alfalfa/pasture/fallow being in the rotation? Will the conversion back to an annual crop be penalized?

While some argued that growers should not be penalized for converting CRP land or for conversion prior to their use, some questioned if the land conversion penalty was steep enough to truly reflect the high and long-term cost of conversion.

Few organizations commented on the specifics of the added IPM component. Two that did offered guidance on how the questionnaire should be corrected or improved. For instance, Q4 asks “What practices support your record-keeping habits?” The commentor felt these are not necessary for a successful IPM program. Each also cautioned against including biological products for pest control as their efficacy is unproven. Alternatively, increasing natural predators relative to pests would be an acceptable biological control.

They both support the IPM component being more relative to the locale of the grower, as not all IPM practices in the questionnaire are applicable in all cropping systems. In response, we might say that growers are still likely to achieve sufficient points, but acknowledge that we could provide either more clarity in the calculation method, scenario examples, or a sensitivity analysis around IPM.