Organic Comment Fall 2017

If you would like to submit a comment to the NOSB for the Fall 2017 meeting you can use the following message. Please copy it, and go to NOSB Fall Meeting Comment Page to submit it.

Sample Comment:

I strongly urge the NOSB to retain the organic eligibility of aquaponic production.

The organic label is ultimately about empowering consumers to identify products that match their values. Consumers do not prefer organic because it is grown in soil; they prefer it because it is pesticide-free, environmentally sustainable, and relies on natural ecosystems for plant growth. So the question is: do aquaponics and hydroponics (AP/HP) align with what the consumer expects when they purchase organic? The answer is a resounding Yes.

There are several core values that embody “organic” for the consumer, and AP/HP have proven they can align with each. “Organic” is perceived by consumers to mean: 

  • Production without synthetic chemicals. AP/HP do not require synthetic pesticides or fertilizers. Biological control and other organic methods work extremely well in AP/HP.
  • Production that fosters the cycling of resources, ecological balance, and biodiversity conservation. AP/HP can be constructed as closed-loop ecosystems in which only the minimum required water and nutrients are added and with minimal or no discharge. AP/HP have also proven they can produce more food than soil culture per land area, thus saving more of the natural environment from the toll of agriculture and biodiversity loss. Aquaponics uses a biological nutrient source -  fish waste – to grow plants. Organic hydroponics uses natural nutrient sources commonly used in all types of organic farming such as fish emulsion, compost tea, or seaweed.
  • Production that relies on biological ecosystems to support plant health. Organic AP/HP production relies on a robust microflora in the root zone—made of the same types and numbers of bacteria and fungi that thrive in soil. This flora converts nutrients into forms available to plants and maintains plant health by reinforcing naturally-occurring mechanisms of disease resistance—just as in a healthy soil.
  • Production that responds to site-specific conditions by integrating cultural, biological, and mechanical practices. Consumers expect that organic produce has been grown with a healthy human element, where local customs, expertise, and ingenuity can overcome droughts, concrete jungles, and climate changes. AP/HP allow environmentally-sensitive agriculture where growing in soil isn’t possible.

The Organic Label is Critical to the Growth of Sustainable Farming

Not only can AP/HP align with all the criteria of the organic ideal, but they have also proven to be extremely efficient and sustainable. AP/HP can produce more food per land area and with less resources than soil growth. The benefits of AP/HP include: water savings, reduced nutrient use and fertilizer runoff, shorter supply chains, food safety, and space efficiency. 

In an era of climate change, resource depletion, and rapid population growth, the organic price premium is a critical incentive to draw more entrants into this market. If the NOP revokes AP/HP organic eligibility, these industries will not grow as quickly and our environment, health, and economy will suffer.

I recommend that the National Organic Program (NOP) continue to allow organic certification of aquaponic and hydroponic farms that are compliant with USDA organic standards. These farming methods align with the organic mission so strongly that the integrity of the organic label stands much to gain by including them, and much to lose by excluding them. Furthermore, aquaponics and hydroponics are critical to improving the sustainability of our agricultural system, but revoking organic eligibility would move these industries backwards at a time we must foster their growth.


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