Talking Points for Comments (Due October 11, 2017)
There is nothing wrong with hydroponic growing, it simply isn’t an organic system and growers should seek their own label.
Farmers that work to increase soil organic matter and fertility are placed at an economic disadvantage to hydroponic/container growers that continuously fertilize with liquid nutrients.
Cover crops capture carbon and nitrogen from the atmosphere into the soil. Organic matter in combination with soil bacteria and fungi help make nutrients from the soil available to plants. These regenerative systems are the foundation of organic agriculture.
Healthy soil should, legally, be the primary source of fertility for organic crops, not the continuous feeding of liquid fertilizers, in many cases derived from conventional soybean production.
The “Keep the Soil in Organic” movement has strong support from many of the pioneers who founded the organic farming movement and organizations representing over 2.2 million organic stakeholders. Organic farmer and Hydroponic Task Force member Dave Chapman stated that, if the certification of hydroponics is not discontinued, “Between hydroponics and animal welfare, we will have lost organic as a word describing our way of farming.”
The Organic Food Production Act of 1990 (OFPA) requires maintaining and improving soil fertility as the foundation of organic agriculture.
The biological diversity and complexity in a soil system cannot be replicated in water and a liquid fertilizer solution to produce the environmental benefits and nutrient dense food organic consumers expect.
The NOSB’s 2010 formal recommendations on the “Production Standard for Terrestrial Plants in Containers and Enclosures (Greenhouses)” specifically states that “hydroponics and aeroponic systems are prohibited.” The NOP’s decision to continue to allow organic certification of hydroponic systems is in violation of their legal responsibility to follow OFPA.
OFPA “assure(s) consumers that organically produced products meet a consistent standard.” The 2010 NOSB recommendations are consistent with international standards. In 24 EU countries, Canada, and Mexico, it is illegal to hydroponically produce crops as “organic.”
Container production systems are hydroponic systems because they depend on liquid nutrients for fertility.
Recommendations from the International Federation of Organic Agriculture Movements (IFOAM) and the Expert Group for Technical Advice on Organic Production (EGTOP) prohibit organic certification of hydroponics, and limit container growing to the sale of annual seedlings.
I urge you to consider the enormous negative impact on U.S. farmers from imported hydroponic fruits and vegetables flooding U.S. markets — especially given the fact that hydroponic produce cannot legally be labeled organic in the countries of origin.
Please consider the harm to organic integrity when standards are inconsistent and the founders of the organic movement disagree with USDA policy makers.
Thank you for your commitment to this important issue.