• To the National Organic Standards Board,

    The current federal regulations require careful stewardship of the soil as a prerequisite for the granting of organic certification to farmers.

    The mantra for pioneering organic farmers, and those who truly uphold the spirit of organics, is: feed the soil not the plant. Nutritionally superior food, and superior taste, requires careful stewardship of a diverse and healthy microbiome in the soil.

    1. The National Organic Standards Board (NOSB) should adopt, as European Union regulators have, a requirement for organic plants to be grown in the soil, not in water or containers filled with inert substrates and then fertilized with a liquid solution (oftentimes conventional hydrolyzed soy meal).
    2. Like the European Union, a few products can be exempted that do not depend on liquid fertility such as plants grown and sold in containers (ornamentals and seedlings), sprouts, microgreens, fodder, mushrooms, and honey.
    3. Without authorization the USDA’s National Organic Program has erroneously allowed certification of hydroponic and container growing that does not comply to the spirit and letter of the organic law. Like the European Union, these illegal operations should be phased out in a strict adherence to soil-based standards and maintained going forward.
    4. We do not support the current hydroponics “compromise” being considered by the NOSB. Trying to tweak growing in some percentage of soil, or soil-like substances, in containers housed in industrial-scale factory conditions, is a recipe for widespread cheating. The U.S. should embrace strict, enforceable international standards, prohibiting hydroponic/container growing, by adopting the European Union regulations.

    Respectfully yours,

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