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Dave gave this verbal testimony at the Spring 2017 NOSB meeting in Denver.

Barry served on the NOSB when the 2010 recommendation banning hydroponics passed.

Dr. Flamm has served as Chair of the NOSB. He was a founding farmer of the Montana Organic Association. He is currently on the board of the Cornucopia Institute.

Stuart is an organic pioneer who taught soil zoology at McGill University.

Stuart has been a teacher to many in the organic movement. His perspective as a respected soil scientist is matched by his creative thinking on the meaning of "Deep Organics" for all of us.

Lisa in the Director of Organic Advocay. She was previously the Organic Food Policy Director for the Center For Food Safety.

Lisa has been instrumental in many actions taken to keep the National Organic Program responsive to the organic community. She presented this written testimony in March 2017 to the NOSB, in response to a call for discussion on the issue of hydroponics in the organic standards.

Dave submitted this written testimony in preparation for the Denver discussion on hydronic and soil in certification

This testimony tries to address the many questions raised by the Crops Subcommittee in advance of the creation of a new recommendation.

Bart is a long time leader in the organic movement. He has been active in OCIA since its inception. He has also been a long time certifier. He currently farms vegetables in Kansas with his wife, Margit Kaltenekker Hall.

As a professional agronomist whose first two degrees were in geology and geo-chemistry before moving on to soil science and agronomy, I must register my vigorous opposition to any certification as "organic" of hydroponic operations.

During the course of my career I have inspected over 800,000 acres for organic certification, in seven different countries and working in three different languages. I also spent a decade operating some 15,000 square feet of ornamental flower greenhouses and consequently am thoroughly familiar with fertilization regimes in such circumstances.

Organic Soilless Crop Production; Recommendation to NOP – Decision Making Historical Process Based on Memory – Jeff Moyer, NOSB member 2006-2011, Past Board Chair, Vice Chair, Crops Committee Member, Livestock Committee Member The decision of whether or not to approve soilless mixes or hydroponic production practices under USDA NOP organic certification has been a long thoughtful process culminating in the 2010 NOSB recommendation to the NOP to not approve the practices. There were three main p

The decision of whether or not to approve soilless mixes or hydroponic production practices under USDA NOP organic certification has been a long thoughtful process culminating in the 2010 NOSB recommendation to the NOP to not approve the practices.

There were three main points that continually emerged during the long crops committee discussions and debates on the subject:

Joe was Vice President of QAI. He also served as President and board member of the Organic Trade Association. He began his career as an organic farmer.

The foundation of organic agriculture is soil ecology, not compliant inputs. While I think that hydroponics, using CFR7205 allowed materials, is a valuable production method especially in an urban setting it is not organic. I support the moratorium until the final, hopefully correct, decision is made. 

Regulation Officer at BIONEXT and IFOAM EU council member

Setting soil and soil quality as the basis of your production system makes you responsible for what you do with this resource. This limitation, as some would call it, leads to innovation. It leads to in-depth knowledge of how the soil works, innovation in machinery, and in water giving strategies.

Kevin Engelbert is the co-owner/operator of Engelbert Farms, the first certified organic dairy farm in the U.S., certified since 1984. He farms about 1,800 acres with his wife Lisa. He recently completed a five-year term on the USDA’s National Organic Standards Board (NOSB).

One thing I’ve learned from being on the NOSB is that money always wins.  Always.  Have a backup plan so that when the NOP makes aquaponics / hydroponics officially approved you will be ready – I would suggest demanding that crops produced with those methods be labeled as such.

American farmer, agricultural researcher and educator, and author of The New Organic Grower

No soil? Plants and soil have been evolving together since plants began. Countless bacteria and fungi interact with plant roots, organic residues, and soil minerals to create the conditions for plant growth. Now we are informed that some USDA bureaucrat has decided soil is unnecessary for properly grown organic food. Is he kidding? I have been farming organically for 48 years. A plant not grown in soil, with all its miraculous and unknown nutritive processes, is not worth eating!

Professor, Organic Crop Specialist, and staff at Maine Organic Farmers and Gardeners Association

Organic Hydroponic Crops? Not in My Opinion. Many books have been written about organic farming and gardening, but this art and science basically comes down to seeing organic growers as soil stewards – not just users – who are devoted to building and maintaining soil fertility (mineral content) and structure rather than feeding plants from a bag of minerals each season. We have come to realize that soil is actually a system full of life and nutrients. Thousands of species live together, eating and dying and recycling minerals among themselves. The organic grower introduces crops to this system and tries to interfere with it as little as possible.

Former Director of Research at the Rodale Research Center, and former Director of the Sustainable Agriculture Research and Education Program at the Univeristy of California, Davis

I have worked with organic agriculture since 1981 at the Rodale Research Center. Organic soil management  is a complex issue and involves complexity in the soil. Hydroponics does not even come close to organic soil management. It is a chemical based approach that has no place in organic agriculture. All the soil interactions that make organic organic are missing. It is even more chemical intensive than conventional industrial agriculture. If that idea is accepted as organic then organic  certification is almost a worthless concept. It bankrupts the idea and the science behind what organic agriculture is.

Certification Administrator, Vermont Organic Farmers

The original organic farmers and gardeners saw that the use of chemical fertilizer was diminishing soil fertility, which resulted in malnourished plants. The founders of the organic movement recognized that the soil was more than just a structure to hold up plants. Rather, they looked at soil as a critical component of the health of the plant. If they created a “healthy” soil full of microbes, minerals and nutrients, they theorized that the plants grown in this soil would be healthier both in fighting off diseases and pests and by providing more nutrients to the humans and animals that ate them. At the time this idea that the soil was a living ecosystem was revolutionary, as the common practice for growing crops was based on feeding the plant through synthetic fertilizers.

Organic Farmer, and Editor of The Natural Farmer

I am concerned that the NOP is allowing imported produce, grown in hydroponic systems that do not have such an ecology, to be sold in the US as organic. The NOP needs to accept the 2010 NOSB recommendations and affirm the standards that most countries have already adopted which exclude such hydroponic production from being considered organic.

Green Mountain College, with over 23 years of experience in ecological agriculture education

Scientific work shows the interconnectedness of healthy plants to healthy soils, and especially to soil microbial communities. Soil microbes live inside the cortex of roots. Plant exudates simulate and feed microbial communities in their rhizospheres. Plants can take up antibiotic produced by soil microbes and use them in their defense systems. There is even research that shows released corn bore moths chose corn plants grown in soil with poor organic matter management (statically significant) over those grown in soil with well managed organic matter in a randomized block design in a greenhouse. Soil organic matter management an healthy soil is the foundation of an organic farmer’s pest management system.

Organic Farming Advisor, and Found of Ecological Farming Conference

It is essential that the National Organic Program recognize the overwhelming majority vote by the NOSB with regards to the requirement of growing organic crops in soils, and not under hydroponic conditions. The most basic principles of organic agriculture require the natural interaction of plant roots with organic matter, humus, biological activity and the macro and micro nutrients that are found in the soil. Hydroponics are an artificial environment that provides solely soluble nutrients, and creates plants that are often in stress, requiring applications of insecticides and fungicides due to this environmental stress.

Full Belly Farm, one of the oldest and most respected organic farms in America

Our mandate in organic agriculture has always been to leave the SOIL better than the way we found it. This guiding directive fashions our farm practices to foster plant health and productivity through regenerative fertility in a biologically dynamic soil. We recognize and commit our role to keeping the "fire stoked", to not only sustaining, but enriching an extensive and complex community of soil dwelling species. We recognize the intregal relationship between of soil health with plant health. Soil is the de facto foundation of certified organic farming. A soil-less system by definition has none of these concerns, and so by definition is incongruent with the basis of organic agriculture.

Organic Farmer, Killdeer Farm, Norwich, VT

That hydroponic growing can be certified is a major contradiction in that it cuts out the very heart of what orgnic means: feeding the soil to feed the plant. Please, pay attention to us and the NOSB!

Woods End Soil Labs, and Faculty Associate at the University of Maine

For those of us who have worked so hard to get the Soil Health movement off the ground, we know its about good and better soil. Imagine a proposal to take the soil back out of it, and go back to only nutrients! That's what many of us  think is at stake with the proposals afoot to allow "organic hydroponics" for imported crops.

OneCert, Inc.

I agree with the NOSB Crops Committee’s discussion document that soil-less systems such as hydroponics or aeroponics cannot be classified as certified organic growing methods. To comply with OFPA, management of organic matter in soil is essential. Section 6513(b)(1) requires certified organic farms to manage fertility “primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.”