Field to Market received 120 specific comments from 11 organizations spanning three sectors: growers (56 comments), civil society (34), and agribusiness (30). Each comment was manually extracted from the submitted documents and assigned to a component of the WILD Index and a sentiment. The full, filterable record is available in the comments dashboard.

By sentiment, the comments leaned toward inquiry and critique rather than endorsement: Challenge (36) and Clarity Requested (33) were the most common, followed by Enhancement (27), Support (14), Correction (7), and Rejection (3). By component, comment volume was concentrated in General (50), Cover Crops (13), and Conservation Practices (12), with the remainder distributed across Landscape Diversity (10), Cropland Conversion (9), Pest Management (8), Vegetation Diversity (7), Crop Rotation (5), SNC Management (3), and a handful of single comments on Configuration, Size Ratio, and Tillage.

Comments from different organizations often overlapped or complemented each other, and occasionally contradicted one another. The notes below distill the comments made for the WILD Index generally or for one of its individual components.

Several organizations characterized the WILD Index as an improvement over the HPI, noting that its components are correlated with biodiversity outcomes, that IPM is now featured more fully, and that the data-input burden on growers seems reasonable. Two sectors explicitly endorsed limiting the data burden.

Beyond that, the General comments clustered into a number of recurring, higher-level themes:

1. Practice-based proxy vs. outcomes. Repeated calls to add a ground-truthing or outcome-based element, and to clarify that the practice-based components are proxies for biodiversity that may not support a causal interpretation. Some suggested pairing satellite imagery with ground-truthing to automate data collection.
2. Need for validation analyses. The most frequent request. Organizations wanted sensitivity and scenario analysis across regions, ecosystems, and management scenarios before adoption, to reveal which components may be redundant, overly prominent, under-defined, or negatively interacting. Several suggested a beta release. The index also does not appear to compare a farm’s score against any baseline or control.
3. Transparency of weighting and equations. Requests to document the rationale and effect of the component weights, to expose the equation factors (including the IPM score), and to detail the minimum and maximum of every variable. Some worried that point caps may favor small and medium farms over larger ones with more features than the index can score.
4. Relative or regional scoring. A desire for scores to reflect a farm’s regional potential, and caution against comparing farms across different regions.
5. Clear definitions. Requests for consistent definitions of land covers and key terms such as native, semi-natural, introduced, invasive, noxious, and wetlands, including a finer division of introduced species, since some become invasive and some do not.
6. System-specific gaps. Flooded rice production and other non-upland systems are not well addressed. Commenters also noted the need to account for over-population of browsing wildlife such as deer and rabbits, which can be costly for growers.
7. Scope, claims, and deployment. Requests to state clearly how the metric is intended to be used, to take additional steps if it will support biodiversity claims, and questions about how it will be programmed and deployed.

A few organizations also looked further ahead, suggesting the metric eventually incorporate below-ground biodiversity and account for actions that reduce threats to threatened species present on a farm.

The space around biodiversity measurement is evolving: some programs are practice-based while others push for ground-truthing and outcomes; some are region- or species-specific while others aim for generalities and correlations. Commenters asked Field to Market to cross-map the metric against, or align with, several biodiversity initiatives and frameworks, including TNFD, the Align Framework, SBTN, WBCSD, and the 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 its documentation:

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

• Include summer cover crops

• Consider cover crop termination method

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

• Clarify the following:

  • Define what a multi-species cover crop is

  • Whether winter weeds count as a cover crop

  • What constitutes a sufficient stand of biomass, and whether points should be awarded for planting without a resulting stand

One organization argued that the Cover Crop, Tillage, and Crop Rotation components all appear to award points for providing in-field vegetative cover, and suggested combining them into a single component representing standing vegetation cover in the field area. Doing so could also simplify the index calculation and interpretation. (This suggestion recurs under Tillage and Crop Rotation below.)

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

A related point: conservation practices have a temporal dimension, since establishment and benefit take time to develop, and this temporal component is missing from the WILD Index.

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

Related to water development, one commenter noted that where aquatic environments are created, the index should account for the distance at which certain chemicals (subject to distance restrictions) are applied.

On the technical side, commenters requested clarification of which practices are in the CPPE matrix, which version is used, and what the point scales are. They also asked whether the CPPE could be made state- or region-specific.

Field to Market originally proposed incorporating the Shannon Diversity Index (SHDI) into the index calculation. This component drew the most pointed methodological concerns of any single component, including one of the three outright rejections.

• Concern over the use of SHDI. Several commenters worried the index could be misused or produce contradictory results. For example, developed or urbanizing land can appear to increase landscape diversity. The component needs to handle developed land covers appropriately.

• Penalizing growers for surrounding development. Farmers affected by urban sprawl should not be penalized for a decrease in surrounding landscape biodiversity that is outside their control.

• Low-diversity regions. Regions with naturally low vegetative cover or limited crop rotation (e.g., the Western US) need clearer scoring guidance. Commenters asked how a low baseline landscape diversity is incorporated, and cautioned that a national focus may discount regions that lack landscape diversity even in a natural, undisturbed state.

• Regionalization. A suggestion to make landscape complexity relative to a native landscape, to penalize farms that harbor source populations of invasive/exotic species, and to consider state-level CPPE scores.

• Rejection of the underlying hypothesis. One organization stated that the intermediate-landscape-complexity hypothesis is not an ideal basis on which to build a biodiversity metric.

• Incorporate local data. Because the points are currently practice-based only and do not draw on any locally or regionally specific datasets, one commenter recommended including such data to partially address these concerns.

• Wording. Avoid obtuse terminology such as “simple” landscapes.

Comments on this component focused on how plant species are valued and on documentation:

• Native vs. introduced species. Two organizations questioned the point assignment that favors native species (2 to 3 points) over introduced species (1 point), arguing that some non-invasive introduced species provide biodiversity and pollinator habitat equivalent to natives. They also noted that native species can be difficult to establish, which may allow noxious weeds to take over the intended pollinator area.

• Pests from native plants. The index should account for potential insect pests harbored by native plants.

• Species selection. For practices that involve seeding or planting, one commenter recommended that planning document the rationale for species selection, emphasizing native species from local populations or as advised by a qualified planner with local expertise.

• Documentation. A request for more documentation of the component and the origin of its points.

• Corrections. Why were the CPPE scores shifted so that there are no negative scores? And an error was caught in Table 2, where a Cover Class and Composition is repeated with different point values.

All comments on this component requested clarification:

• How will crop rotation be calculated via the backend algorithm?

• Over what time period should the number of crops grown on a farm be counted? (Table 5 needs a footnote indicating whether it refers to time or space.)

• Do winter weeds count toward the number of crops in a rotation, given their potential biodiversity benefit?

• How is a field handled when the whole field is left in tall residue (e.g., wheat harvested with a stripper header)?

As noted under Cover Crops, one organization suggested that Crop Rotation may overlap with other in-field cover components and could be combined into a single standing-cover component.

Three comments touched on the SNC Management component:

• A broad request for clarity around the component (see the full submission for detail).

• Management flexibility within field borders and vegetative waterways, to control invasive species and noxious weeds, needs to be taken into account.

• Farms should identify any potential human-wildlife conflict that may occur on site and develop strategies that prioritize non-lethal management practices.

This was the only component of the WILD Index that deducts points. The penalty is based on the biodiversity loss expected from the recent conversion of natural lands to production. The comments raised important questions about how to standardize land-conversion history:

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

• 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?

The comments cut both ways: some argued that growers should not be penalized for converting CRP land or for conversions that predate their tenure, while others questioned whether the penalty is steep enough to reflect the high, 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?”; one commenter felt these practices are not necessary for a successful IPM program. Both cautioned against awarding credit for biological products for pest control, on the grounds that their efficacy is unproven, while noting that increasing natural predators relative to pests would be an acceptable form of biological control.

Both also supported making the IPM component more relative to the grower’s locale, since not all IPM practices in the questionnaire are applicable in every cropping system.

A few single comments touched on components not addressed above:

• Tillage. Echoing the Cover Crops suggestion, one commenter proposed combining multiple in-field cover components into a single “Standing Cover” component.

• Configuration. Consideration and documentation of fencing configuration should be included in WILD.

• Size Ratio. It would be helpful if the metric could link to the TNFD-proposed metric of a 10% threshold of area consisting of natural vegetation.