Dear members of the NOSB,
I am an organic farmer for the last 37 years. I am certified organic since before the USDA got involved. I have been growing organic tomatoes in greenhouses (in the soil) for the last 33 years. I also served as a member of the USDA Hydroponic Task Force. As such I have spent considerable time discussing and studying this issue. I apologize for being so longwinded as I offer a long testimony in an effort to share some of what I have learned, especially with the newer members of the NOSB who might have missed earlier discussions.
The question of healthy soil as the foundation of organic standards has become an international issue. These decisions made by the NOP will affect the organic movement throughout the world, due to bilateral trade agreements. If the US permits hydroponic, the rest of the world will probably not be able to hold true to their current standards. At the moment, the EU (with the exception of three Scandinavian member states) does not allow hydroponic production to be certified. Nor do they permit crops to be grown to maturity in containers. Their basic standard is that organic means grown in the ground.
The current debate in the US is immensely important in deciding the future of the organic movement in the world. On the one hand, the organic community has a strong belief that organic means a system of farming based on maintaining and improving the fertility of the soil. On the other hand, a hungry hydroponic industry believes that the organic seal should be theirs if they can feed with approved organic fertilizers and avoid prohibited pesticides. This debate has been further confused by the insistence of some lobbyists and producers that their production systems are “container grown” rather than “hydroponic”.
I believe that the current NOSB discussion document does an excellent job of addressing this issue. A very clear definition is given of what “hydroponic” means. It clarifies that “hydroponic” includes growing in “recalcitrant” materials such as coco coir. There has been confusion on the part of some about the difference between growing in a fertilized water solution as a “substrate”, and growing in a recalcitrant substrate such as coco coir, which is then fertilized with a nutrient solution. I can tell you that in the conventional world of greenhouse vegetable production there is no such distinction. Virtually ALL of the over thirty thousand acres of conventional hydroponically produced tomatoes, peppers, and cucumbers in the world are grown in coco coir or rockwool. The choice of which substrate is to be used is a fairly minor question. As my old Dutch consultant Servaas would say, “I don’t care if you grow on a stack of newspapers!” The substrate was not the important thing. Growers have also experimented widely with peat and perlite as substrates, but rockwool and coco coir have become the standards.
What makes something hydroponic in the real world outside of this organic debate is how the fertility is supplied to the plant. If the fertility is mainly supplied as a liquid feed rather than through the complex interactions of a living soil, then it is hydroponic. If the liquid fertility is removed and the plant gets hungry or dies, then it is dependent on the liquid feed for it’s fertility, and it is being grown hydroponically. Some conventional farming is so dependent on constant fertigation that it is also hydroponic.
There is a lot of talk about “adding biology” as a means of distinguishing “organic” hydroponic from conventional hydroponic. But some conventional growers are also adding cultured microbes in an effort to improve their crop’s performance. And some certified organic hydro growers are NOT adding microbes, and still getting good production results. The clearest example of this is the Driscoll’s operation featured in the case study (offered by member Amy Lamendella from CCOF) in the Hydroponic Task Force Report. A version of this case study is featured in both the soil and the hydro parts of the final report. The case study was remarkable as it was the only example of a hydroponic grower willing to share their specific fertility practices with the Task Force. Otherwise we were only presented with long lists of approved fertilizers, and told that the hydro producers used fertilizers found “somewhere” on that list.
The Driscoll’s case study originally described a berry operation that neither added compost nor compost tea to the containers filled with coco coir/peat substrate. All of the fertility was provided through liquid feeding of micronized fish, and the microbial activity of the substrate came as a result of colonization from the air. We took this as clear proof that “adding biology” was not a requirement for making the “organically approved” fertilizers plant available, especially in the case of fertilizers such as hydrolyzed soy protein (16-0-0) and micronized fish that we believe are commonly used in “organic” hydro to provide the needed nitrogen for the crops.
While no doubt the addition of compost tea to a microbial dessert such as coco coir is a beneficial practice, it certainly should not qualify the growing process for the organic seal. It is interesting that coco coir has become popular with conventional hydroponic growers exactly because it is so resistant to microbial activity and biodegradation. But in nature there are no “sterile” environments. There are microbes everywhere. Every conventional hydroponic substrate has some biological activity, as does every conventional field soil. Conventional hydroponics are not growing in a “sterile” environment.
But organic farming is meant to embrace and enhance the microbial diversity and intensity in the soil. This is primarily done through increasing the soil organic matter as both a food source and a means of properly cycling the water and oxygen around the roots. The organic matter is provided through recycling animal manures and decomposed plant wastes. The other major food source of the microbial life is It is accomplished through maintaining healthy plants growing as a part of the soil ecosystem. These plants will provide the sugars needed to feed the soil life through their root exudates. These exudates are the result of the photosynthesis of the plant. In order to thrive, plants have evolved to feed the soil. And the soil has evolved to feed the plant. These different parts of the soil ecosystem need each other to prosper. This coevolution is the basis of organic agriculture.
There is a legitimate question of whether relying on a healthy soil to provide plant nutrition makes a difference in the nutrition of the harvested food. Relying on a healthy soil means relying on the active biology and ecology of that soil, with all the insects and animals, as well as the bacteria and fungi. There is considerable evidence that the activity of the soil life contributes to a substantially different result in terms of nutrition, but this is not a simple subject.
Our health comes from the soil, through the plants. Having healthy soil means having healthy biology that can release the soil minerals in the proper amounts, and put them into a form that the plants can take up. Then the plants can utilize those minerals to help to make proteins and biomolecules such as antioxidants and polyphenolics that are very important to the health of all animals. It’s necessary for that connection to be made with living soil, because we need at least 33 minerals (some in a very trace amount) to make these biomolecules, and to thus be healthy. For example, some of the antioxidants such as ergothioneine that are taken up from living soil are important in cell wall integrity, which protects the DNA in our cells from exposure to chemicals and atmospheric radiation. There are antioxidants that are formed by microbes in the soil. There are antioxidants that are made by properly fed plants. And there are anitoxidants that we can make in our bodies as well.
A healthy soil makes nutrients, proteins, and anitoxidants available to plants in the right ratios, quantities, and even molecular shapes for optimal plant health. This, in turn, leads to the plant being able to manufacture its own antioxidants that will confer health benefits on the animals that eat them.
The beauty of the organic system is that we don’t need to fully understand these processes to benefit from them. These systems coevolved over hundreds of millions of year to serve each other. We turn away from this complex ecosystem at our peril. These are the foundational principles of organic farming. It was never intended that organic should mean JUST the avoidance of biocides. The ability to stop using pesticides was supposed to be the result of the improved nutrition of a plant growing in a healthy soil, EVEN IF WE DON’T FULLY UNDERSTAND ALL THE MECHANISMS BY WHICH THAT HAPPENS. Without a doubt, a hydroponically produced vegetable or fruit will be different nutritionally from one grown in a healthy soil. Exactly how is uncertain.
When people make the choice to buy organic food, they are hoping to gain these benefits, without necessarily having an advanced degree in soil microbiology. It is true that many people are only thinking that they want to eat food that is unsprayed by pesticides. That is a good place to start! Of course, not all organic food is unsprayed. And it was clear in our conversations with hydro growers on the task force that the cultivation of hydroponic vegetables on their operations was in no way immune to insect attacks and subsequent pesticide applications.
In 2010, the NOSB overwhelmingly recommended that hydroponic be banned in organic certification. The NOP opposed that recommendation. This was the first time in history that the NOP opposed an NOSB recommendation. In the 2016 fall meeting, the NOSB once again voted overwhelmingly to affirm the principle that hydroponic production should not qualify for organic certification. They limited this statement to plants grown in a water substrate and fed with a nutrient solution. Their affirmation of a basic principle was clear. They left for us to decide where on that slippery slope of container growing does it pass from “hydroponic” to “soil grown”.
If we rule out hydroponic production as not qualifying for certification, can we permit soil-based production in containers?
I see a few serious problems that must be dealt with in approving container growing. “Container growing” becomes an easy way to hide hydroponic production. Some hydroponic producers will claim, “We’re not hydroponic. We’re container-grown.” Remembering all those thousands of acres of conventional hydroponic production that takes place in containers, this becomes a questionable statement. Do they mean that these crops rely on the fertility of the soil to feed themselves, and would continue to prosper if liquid feeding were stopped? This casual misrepresentation of the truth should not be permitted by the NOP if they want to retain the trust of the organic base.
So if we can accept that hydroponic is not part of organic, can we have “container grown” that actually qualifies for organic certification? Such a system would require much larger soil volumes than are needed in hydroponic production. It would also require high levels of healthy soil and compost with real biological activity in order to digest and make available the nutrients in the mineral fraction of the soil.
I am concerned that no matter how much soil is required, some hydroponic growers will still turn to liquid feeding of plant available fertilizers in order to produce high yields of vegetables and berries, regardless of the nutritional consequences. It is a way of growing that they know and believe in. They would be running hydroponic operations in a soil substrate. So there would also need to be a limitation on the % of fertility that can be applied as a liquid feed.
It is my personal opinion to require that all certified organic production of mature crops take place in the ground.
But I think it is POSSIBLE to grow organically in a container. Probably 90% of the benefits of organic production could take place in a large enough container. There are unintended consequences in inverting and removing so much soil from the land, and I think there should be requirements that the soil is returned to the same land it has been removed from. But the biggest challenge is to limit the liquid feed so that it doesn’t become a de facto hydroponic production unit. I would extend the same limitations on % of liquid feed to production in the field. This is done in England by the Soil Association. The IFOAM recommendation is no more than 25% of the total fertility can be applied as fertigation.
The overall approach in the EU is that any imported nutrients (liquid or otherwise) can only be used when all other means have failed. Thus using imported liquid feeds could not form the basis of the fertility.
In the British Soil Association standards, they allow liquid feeds that are made on the farm (so they are organic and form part of the overall fertility management of the organic farm). Purchased liquid feeds can only be used in the following circumstances:
With our approval, you may use commercial fertilizers and liquid feeds suitable for organic use to treat severe deficiencies. You will need to tell us the ingredients and the nutrient analysis before we can approve them.
So liquid inputs must never form a regular part of the fertility management. If growers are regularly encountering ‘severe deficiencies’ they would be required to adjust their production system.
Clearly, insisting that container growing be based on the actual principles of organic agriculture is not a simple task. That is why the EU countries have chosen a simple solution. Organic must be grown in the ground.
Finally, I urge the NOSB to take seriously the task that has been laid upon you, and to act QUICKLY. This debate has gone on for 7 years already. A year ago a letter calling for a moratorium on certifying any new hydro production was presented to the NOSB, the NOP, the AMS, and Secretary Vilsack.
This letter was signed by National Organic Coalition, NOFA VT, NOFA NY, NOFA NH, NOFA MA, NOFA NJ, NOFA CT, NOFA RI, MOFGA, Center For Food Safety, Beyond Pesticides, Food & Water Watch, NODPA, OCA, OSGATA, Cornucopia Institute, Food Democracy Now!, Carbon Underground, Agrarian Elders, Forrest and Frances Lattner Foundation, Biodynamic Association, Demeter Association, OCIA, Deep Root Growers Cooperative, New England Farmers’ Union, Soil Association, Organic Growers Alliance, French National Organic Farmers Federation, Bionext, Biohuis, Nautilus Organic (Dutch Organic Growers Association-Holland), BDEKO (Federation of Biodynamic and Organic Farmers-Holland), AIAB (Associazione Italiana per l'Agricoltura Biologica- Italy), BOLW (Bund Ökologische Lebensmittelwirtschaft e.V.), Study Network of Organic Greenhouse Growers of the Dutch Federation of Agriculture and Horticulture (Holland), and CAPE (Cooperative pour l'Agriculture de Proximite Ecologique- Canada).
It was also signed by former NOSB members Michael Sligh, Fred Kirschenmann, Joan Gussow, Dave Carter, Jim Riddle, Goldie Caughlan, Hubert Karreman, Jeff Moyer, Joe Smillie, Kevin Englebert, Barry Flamm, Jay Feldman, Nick Maravell, Jennifer Taylor, and Colehour Bondera.
It was also signed by organic farmers and supporters Eliot Coleman, David Miskell, Dru Rivers, Margit Kaltenekker, Anaïs Beddard, Pete Johnson, Stuart Hill, Elizabeth Henderson, Ed Maltby, Terry Shistar, Bob Scowcroft, Tom Beddard, Bart Hall, Bill Duesing, Enid Wonnacott, Jack Kittredge, Julie Rawson, Ronnie Cummins, Lisa Bunin, Jim Gerritsen, Megan Gerritsen, Alan Schofield, Steve Gilman, Tom Newmark, Patty Lovera, Paul Hawken, Karl Hammer, Will Allen, Liana Hoodes, Tom Page, Frank Morton, Clara Coleman, Zoe Bradbury, Amigo Bob Cantisano, Jack Algiere, Dan Pullman, Will Brinton, Will Raap, Barbara Damrosch, William :Liebhardt, Fred Jobin-Lawler, Thea Maria Carlson, Robert Karp, Stephan Schneider, Daphne Amory, Gregory Georgaklis, Peter Littell, Terry Brett, Jim Fullmer, Larry Phelan, Jean-Paul Courtens, Jim Crawford, Jake Guest, Betsy Hitt, Gloria Decater, Stephan Decater, Carly Delsignore, Andrea Hazzard, Zachary Wolfe, Tom Willey, and Bavo van den Idsert.
This letter was soon followed by similar moratorium letters from Senator Patrick Leahy, Senator Bernie Sanders, and Congressman Peter Welch.
I have included this lengthy list to make clear that the organic community, including farmers, eaters, academics, and policy makers are all quite concerned about this issue. The moratorium letter was an appeal to repair this glaring failure in the organic standards. A spokesperson for the hydroponic industry recently claimed “organic” hydro sales of a billion dollars a year. It turns out I have been too conservative in my estimates. Bear in mind that most of these sales are from a tiny number of companies. Almost all of the certified organic production began AFTER the 2010 recommendation calling to ban hydroponics from organic. They certainly knew that they were skating on thin ice when they started their operations. Despite recent warnings from the NOP that the future of hydroponic is uncertain, new applications are booming. And now they are complaining that the rules are being changed! What rules?
I should mention the Rally In The Valley that took place in Vermont last October. Senator Leahy, US Representatives Peter Welch and Chellie Pingree, and hundreds of farmers and eaters came together to express their support for keeping the organic standards strong around this issue. It was the biggest farmer protest ever against the corporate attack on real organic in the USDA. That small gathering of 250 precipitated stories in the NY Times, National Geographic, NPR, and the Boston Globe. The videos of the rally have gotten over 50,000 views. I regret that the NOSB was not permitted to hear Senator Leahy’s words during testimony at the St. Louis meeting, but you can watch the entire hour long video at keepthesoilinorganic.org. This movement isn’t going away. In fact, it is just getting started.
And, as with the “organic” egg industry, few beyond the hydro producers and their lobbyists and certifiers believe these products should actually be certified organic in the first place. The pro-hydroponic comments already submitted to the NOSB in the last month are almost entirely coming from that small group with a direct economic stake in “organic” hydroponics. There is no consumer outcry for hydroponics. There is little proud advertising of being hydroponic on their packaging or websites. The lobbyists are quick to defend “container growing, but seem loathe to mention the “H” word.
The story is quite different for those defending soil as the basis of organic. The core of informed organic consumers who have propelled the organic label to become the powerhouse it is today have strong feelings when they learn about this invisible issue. So far, most of them have been unaware that they are buying hydroponic vegetables and berries. When they find out, they aren’t going to be pleased. What does it say about the hydroponic strategy that its goal is to keep consumers unaware of what they are buying? And the organic farmers who are speaking up come from all kinds of farms, and are not limited to those in direct competition with hydroponic production.
I will say again, that if I wanted to make a lot of money off of the organic label, I would be the champion of hydroponics. Hydroponics isn’t that difficult compared to soil growing. That is why it is so popular. And I believe that my yields would go up, and I would make more money!. But I don’t do that, because I believe it would be fraud.
There has been a lot of talk about a “circular firing squad” in connection with these discussions. It would appear that some would prefer that those who disagree would sit quietly by while they are redefining organic. I would counter by saying that to remain silent is to acquiesce to the destruction of something precious. And by speaking up we are only trying to protect that which we have worked so hard to create. By all means, let them lay down their rifles, stop calling us names, and help us to promote real organic.
Another question in the discussion document was the creation of a separate label. I highly support this, so long as it isn’t called “organic”. Let there be a PVP with the USDA to promote Bioponic. Let them proudly advertise their use of “allowed fertilizers” and “allowed pesticides” and superior nutrition through hydroponics, container growing, and “adding biology”. They can still offer their desired products to a hungry country at an affordable price.
To allow this failure of the NOP to protect and serve the organic community is to invite its demise. Without strong action, “certified organic” is in danger of becoming irrelevant. The very reason that the NOP was created was to protect the integrity and consistency of the organic standards. It is failing.
The core community of the organic movement is not going to change it’s beliefs because the NOP attempts to redefine organic. Just as the hydroponic invasion of organic is only building, so is the opposition to it. We are facing a battle that will perhaps divide the label forever. If we don’t change course soon, many people will leave the organic seal as their North Star, and find another gathering place to continue building the soil movement. That is already happening, as “Regenerative” and the “Healthy Soil” movements take up the banner to create a new agriculture. The organic seal SHOULD be leading the movement for real soil regeneration. The world is in dire need of our united efforts to transform how food is grown. It is clear to me that climate change is heavily influenced by how we farm. Perhaps the only way forward is to change farming on a worldwide level to protect and nurture healthy soil.
I urge you to take action quickly, and return “USDA Certified Organic” to its former place as a meaningful leader in a world movement for regenerative organic agriculture.
Thanks for your interest,
Long Wind Farm