Native ecosystems and soil-less growing methods

National Organic Standards Board (NOSB)
USDA-AMS-NOP
1400 Independence Ave., SW
Room 2648-S, Mail Stop 0268

Washington, DC 20250-0268
ID: AMS-NOP-17-0024-0001

October 11, 2017

Dear National Organic Standards Board Members:

We appreciate the opportunity to comment on issues before the organic community. PCC Community Markets is a certified organic retailer with $277 million in annual sales. On behalf of our 56,000+ consumer member-owners, we respectfully submit the following remarks.

To the Compliance, Accreditation & Certification Subcommittee
Re: Eliminating incentive to convert native ecosystems to organic production

To the Crops Committee
Re: Aeroponics/Hydroponics/Aquaponics/Container growing

I. Compliance, Accreditation & Certification Subcommittee
We are very pleased that the National Organic Standards Board (NOSB) is proposing new regulations that would protect native ecosystems from being converted to organic production.

We understand the three-year waiting period for land to be certified free of prohibited substances has incentivized, unintentionally, the conversion of undeveloped, native ecosystems into organic farms. While we want organics to increase its share of the market, growth must be sustainable and support integrity of the label.

We understand the proposed rule would protect only native ecosystems that never have been grazed or cultivated. We share concerns expressed by the Wild Farm Alliance (WFA) and agree with its recommendations:

• Broaden the scope of native ecosystem protection beyond land that never has been cultivated or grazed. Delete “grazed or cultivated.” Prior agricultural land uses can be difficult or impossible to detect and limiting the scope to “grazed or cultivated” land would render the rule weak and almost meaningless.
• Define Native Ecosystems. The term “native ecosystems” must be defined in the regulations. Without clearly defining the type of land that the rule seeks to protect, confusion and loopholes are likely. A broad definition that accounts for the presence of native species present, should be the basis for assessments to classify and describe types of ecosystems.
• “Conversion” should not be tied to “crop or livestock production.” Any activity that destroys the character of “native ecosystems,” as defined above, should count as “conversion.” Under the proposal, if conversion is not directly for crop or livestock production, it would not be a factor in certification. We believe any activity that destroys “native ecosystems” as defined above should count as “conversion.”
• Delete “crop or livestock” and say “organic production.” While the conversion of native ecosystems largely will be to crops or livestock, the rule should not ignore or omit other types of production. Also, regardless of whether a native ecosystem is converted directly because of agriculture or some other reason such as development, the time period between conversion and certification still should apply.
• We support WFA’s recommended language: “A site supporting a native ecosystem cannot be certified for organic production as provided for under this regulation for a period of 10 years from the date of conversion.”

As human overpopulation and climate change further pressure imperiled ecosystems, these recommendations would encourage organic producers to invest in converting conventionally farmed land to organic production.

II. Crops Subcommittee,
Proposal: Aeroponics/Hydroponics/Aquaponics/Container growing

As a certified organic retailer, PCC sells hydroponically grown tomatoes and cucumbers as part of our mix, yet we wholly support NOSB’s suggested language to amend §205.105 so aeroponics, aquaponics and hydroponics are prohibited methods of production. Soil-less systems may be innovative and productive but they do not meet the letter or spirit of OFPA.

Organic consumers demand transparency and full disclosure in labeling how a food is produced. Labeling hydroponically grown foods should be no exception. Anything short of full and forthright transparency inhibits the consumer’s right to an informed choice and is misleading.

We disagree with NOP’s allowance for hydroponic systems to be certified — without specific rules or standards — and believe NOP is violating its legal responsibility to follow OFPA. OFPA §6513 (b) (1) states plainly that, “An organic plan shall contain provisions designed to foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.”

We support NOSB’s 2010 formal vote to prohibit organic certification of hydroponic and aeroponic agriculture.

We support NOSB’s fall 2016 resolution that “the foundation of organic agriculture is based upon a systems approach to producing food in the natural environment, which respects the complex dynamic interaction between soil, water, air, sunlight, plants and animals needed to produce a thriving agro-ecosystem.” We agree with the NOSB resolution that “the heart of the organic philosophy is the belief that our responsibilities of good stewardship go beyond production of healthy foods, and include protection of natural resources, biodiversity and the ecosystem services upon which we all depend…”

Growing healthy food arguably cannot be done in a vacuum and does little, if anything, for sustainability or protection or improvement of resources. Growing food with artificial lights in a building, with little or no fresh air or sunlight, and non-soil substitutes does not enhance biodiversity, biological cycles, soil biological activity, or ecosystems and, therefore, do not align with organic principles.

We urge you to consider the material negative impacts on U.S. organic farmers from imported hydroponic fruits and vegetables flooding domestic markets — especially since hydroponic produce legally cannot be labeled organic in their countries of origin. Recommendations from the International Federation of Organic Agriculture Movements and the Expert Group for Technical Advice on Organic Production prohibit organic certification of hydroponics and limit container growing to the sale of annual seedlings.

At the very least, transparency and full label disclosure is key.

Respectfully yours,

Trudy Bialic
Director, Public Affairs & Quality Standards