Hydroponics - What's the Big Deal?
This article first appeared in the November 2015 NODPA News and was written by Ed Malby, Executive Director of the Northeast Organic Dairy Producers Alliance. Reprinted with permission.
For most of us hydroponic production is not organic production, similar to the fact that
confinement dairy operation where cows don’t graze grass is not organic either. The National
Organic Standards Board (NOSB) agreed with that in 2010 when they made the following
recommendation about hydroponics: “Observing the framework of organic farming based on
its foundation of sound management of soil biology and ecology, it becomes clear that systems
of crop production that eliminate soil from the system, such as hydroponics or aeroponics,
cannot be considered as examples of acceptable organic farming practices. Hydroponics, the
production of plants in nutrient rich solutions or moist inert material, or aeroponics, a
variation in which plant roots are suspended in air and continually misted with nutrient
solution, have their place in production agriculture, but certainly cannot be classified as
certified organic growing methods due to their exclusion of the soil-plant ecology intrinsic to
organic farming systems and USDA/NOP regulations governing them.” As is very common with
the NOP and NOSB this recommendation followed seven years of deliberations, discussions and
public comment and was specific in detail about what could be grown in soilless mediums and
what certifiers should look for in making decisions around what inputs could be used. The
NOSB also agreed that some soilless crop production methods do in fact “foster cycling of
resources, promote ecological balance, and conserve biodiversity,” as defined in the Organic
Rule. Examples of such systems include transplants that are eventually planted in soil, or a
system of aquaponics that employs microbial decomposition of fish waste and cycles nutrients
from fish through plants. Other systems may include cycling of nutrients using worms or
composting.
Unfortunately, the NOP did nothing with this recommendation and we now have a situation
where some domestic and foreign hydroponic operations are being certified organic and
increasing in scale to directly affect the viability of the market for organic producers who grow
their produce in soil. While some certifiers accept the use of hydroponic solutions using only
approved materials as organic, other certifiers believe the maintenance of ecological balance
and biodiversity in the soil is essential to a truly organic system of production. Those certifiers
believe that hydroponic systems, with their dependence on outside inputs, a highly controlled
system which relies upon large volumes of outside energy for lighting and nutrient
dissemination through the system, does not meet the letter or spirit of the OFPA.
Dave Chapman, an organic producer from Vermont has stated very clearly the effect that
hydroponics has had on the marketplace: “The NOP is still embracing hydroponic growing as
fully certifiable. Hydroponic “organic” sales now easily exceed $50,000,000 a year in the US.
Perhaps the number is much higher, but there is no way to know for sure. It is almost
impossible to go into a supermarket in the US that offers organic produce, and not find
“organic” hydroponic tomatoes on the shelf in the place of soil grown real organic. It might be
different in California, but in my travels throughout the East coast, and into the South and
Southwest, this is what I have seen. In almost all cases, the cheaper hydroponic produce has
pushed off most of the soil grown organic produce. It has gotten to the point where most real
organic growers are forced to market their organic tomatoes and peppers in farmers markets,
road side stands, and CSAs. The supermarkets have been taken over by the hydroponic growers
from Mexico, Canada, and Holland. They are selling produce to us that could not be certified in
their own countries.”
In response to increased concern and pressure from many groups to declare a moratorium on
certifying any hydroponic operations, and request for “NOP Instruction to Certifiers” that leads
to Rulemaking based on the NOSB 2010 recommendations, the NOP created a Hydroponic and
Aquaponic Task Force in September 2015. The stated intention of the Taskforce is to “explore
hydroponic and aquaponic production practices and their alignment with USDA organic
regulations.” Miles McEvoy, head of the NOP, has said several times that he hopes that the task
force will be able to clarify the language of the 2010 NOSB recommendation banning
hydroponic, which he said was too unclear for him to make a rule on. At the NOSB meeting in
October 2015 he stated that: “The task force will provide a report to the NOSB on current
hydroponic and aquaponic production methods used in organic production, and whether these
practices align with OFPA and the USDA organic regulations.” The NOP has not publicly
specified what it believes is unclear about the NOSB’s 2010 recommendation, thus requiring
the creation of the Task Force.
The task force was originally limited to people with at least 3 years of experience in
“hydroponic organic” growing. The NOP later responded to a public outcry and complaints,
and opened the task force to all interested people. According to Dave Chapman, “A number of
highly qualified volunteers with lots of experience in organic farming were not selected for the
task force, including organic greenhouse growers David Miskell from Vermont and Ken Kimes
from California. About two thirds of the task force members are experienced in hydroponic
production, and have little experience with real organic farming.” The National Organic
Coalition (NOC) also commented on the make-up of the committee: “Furthermore, while we
appreciate that the NOP chose to appoint NOC’s recommended candidates to the Hydroponics
Task Force, the overall make-up of the Task Force is such that the majority of those appointed
actually disagree with the NOSB recommendation (i.e. believe that hydroponics should be
allowed to be certified). Unfortunately, this is likely the result of the original Federal Register
notice, which clearly restricted membership on the Task Force to people with at least three
years’ experience in “organic hydroponic.” Though the NOP did lift this restriction after public
outcry, the result is a group that is stacked in opposition to the NOSB’s recommendation.”
We are now entering very familiar territory in the Rulemaking process. The NOP is following a
pattern that has been used in the past to slow down decision-making under the guise of
analyzing the current situation. With the Access to Pasture we had exactly the same process
that delayed any decision and allowed large scale dairies to establish themselves as
economically necessary for the organic dairy industry. If the Taskforce follows its stated
mandate and goes back to square one to examine the current situation and assess the economic
impact of not certifying hydroponic operations, we will be looking at many years before the
Taskforce reports back to the NOSB. The NOSB would have to discuss the Taskforce
recommendations and recommend rulemaking to the NOP. The rulemaking would then have to
fit into the work plan of the NOP and the availability of slots in the USDA allocation for
rulemaking on the Federal Register. We are looking at many years of the status-quo and the
rapid expansion of domestic and especially foreign organic hydroponic operations.
The NOP could choose to have a two track course and instruct certifiers as to which soilless
systems may be certified, and which do not meet the criteria and are not eligible for organic
certification. The instruction should include clear criteria that follow the NOSB 2010
recommendation, and adhere to the definition of organic production presented in the Rule.
The NOP could and should instruct the Taskforce to only clarify what the NOP will need to get
to rulemaking rather than a complete re-examination of the hydroponic industry and get a
recommendation to the NOSB by Spring 2016. The NOSB could then have a recommendation
open for comment and possibly have a final recommendation for the NOP by the Fall meeting in
2016.
The integrity of organic production is an essential part of the marketing of product using the
USDA organic seal, especially for those that sell commodities on the wholesale market. The NOP
was created to ensure ethical and consistent marketing in organic farming. The whole purpose
of the National Organic Program was to prevent misleading labeling and inconsistency of
organic certification that we are now seeing with hydroponics. People are buying “organic”
tomatoes and peppers with no idea that the produce is hydroponic. Many people don’t even
know what hydroponic means. The websites of the businesses and organizations that are
organic champions celebrate the soil. Statements are commonly made such as “Organic
Growing, it begins with the soil”, and “Organic farmers understand that what you put into the
soil has a profound impact on what you get out of it”. But the reality of what is offered in the
stores is quite different.
The Big Deal is that without the belief of consumers in the integrity of organic, there is no
future for organic certification. Dave Chapman has responded to the challenge of making the
process work and his comments to the NOSB meeting in Stowe Vermont this October give a
clear path for action by the NOP, as did the protest by organic farmers outside the NOSB
meeting on the first day of the NOSB.
Dave Chapman comments to the NOSB:
"The time has come to come to a conclusion on the issue of hydroponics in organic. Like
the Emperor’s new clothes, the NOP position relies on our continuing silence in order to
avoid ridicule. The 2010 NOSB recommendation is completely clear in saying that
hydroponic production has no place in organic certification. Soilless growing is simply
not in keeping with the basic principles of organic farming. I believe that the task force
is an attempt to avoid rather than to act on the recommendation. I believe that most of
the people in this room agree with the NOSB recommendation.
"Most of the organic farmers in America agree with that recommendation. IFOAM, The
National Organic Coalition, Cornucopia, The Organic Trade Association, the Agrarian
Elders, the OSGTA, and the Vermont Organic Farmers have all issued statements in
support of that recommendation. Five hundred organic farmers and over one thousand
organic consumers have signed petitions that support that recommendation. The
standards of 23 of the 27 member states of the EU, Japan, New Zealand, and Mexico
support that recommendation.
"So who opposes the 2010 recommendation? The NOP…. and the hydroponic growers.
Was it ever intended that the NOP would redefine the principles of organic farming? No!
They are only meant to be the referees, ensuring that the organic standards are
enforced and kept safe from corrupting economic interests. That is the entire reason
that the NOP was created by Congress. To protect the farmers AND the consumers from
unethical marketing, from tricking people into buying something they didn’t mean to
buy. And now the NOP is becoming EXACTLY what they were created to protect us from.
Let us stop settling for Certified SORT OF Organic.
"I have three proposals for the NOP:
1. Create an immediate moratorium on certifying hydroponic production, until
2. Act QUICKLY to create a rule that will ban hydroponic growing from organic
3. Connect the hydroponic growers to the USDA Process Verified Program, sothat they can create a label that will honestly offer what they grow to the American people. Let them be proud of how they grow, and not hide it behind the organic label. Then let the people make their choices.
"I call on Miles (McEvoy), the NOSB, Senator Leahy, and all of you to push the issue to a
speedy conclusion, keeping the organic standards strong and true.”