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Sam Welsch

OneCert, Inc., May 4, 2009





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.”


Organic agriculture was founded on the principle of improving soil fertility by promoting a more active biology in the soil.


This improved organic matter in the soil provides the basis for healthier and more nutritious plants.


In contrast, chemical farming and hydroponics focus on providing nutrients to plants rather than building organic matter in the soil.


The California liquid fertilizer scandal of January 2009 is a recent example of too heavy a reliance on fertility inputs instead of building organic matter in the soil.


As the discussion document states, properly designed compost has all the desirable components of soil and should be considered soil.


I request that the NOSB adopt the discussion document as an NOSB recommendation. In addition, I ask that the NOP immediately remove from its web site the answer “yes” to the question, “Can hydroponic operations be certified?”


Finally, I request that the NOP notify all those using soil-less systems that their system does not comply with OFPA or the NOP Rule.

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