We in the Aquaponics Association encourage you to align yourselves with the Coalition for Sustainable Organics, which is working with us to fight exclusion of container-grown foods (e.g., aquaponics) from eligibility for organic certification.
Those who exclusively farm the land want aquaponics to be excluded from "organic." They believe that soil is required. They pretend their objection is merely to hydroponics, which they characterize as sterile and non-natural. But the proposed rule changes are not based in science, nor do they consider stewardship of scarce resources or social justice.
The Crops Subcommittee of the National Organic Standards Board (NOSB) is meeting this week and next week to consider recommendations to excluding "soil-less" growing from eligibility under the USDA National Organic Program (NOP). The formal proposal will likely be published in late September.
The USDA is seeking public comments for the fall NOSB meeting. The Aquaponics Association will be working with the Coalition for Sustainable Organics to develop a coherent and detailed set of responses.
Join us to keep aquaponics organic!
So far the Coalition for Sustainable Organics has over 50 growers and concerned citizens who have already submitted comments in support of organics including container production systems, such as aquaponics.
Comments like these remind the USDA and the NOSB that container production systems are sustainable, legitimate and sensible, and that it is important to preserve our systems as part of the organic family. Your voice has power to make a major impact with the people deciding the fate of the industry right now.
If you have commented already and reached out to your network, thank you. If you or your network have not yet submitted comments, please do so this week!
You can submit comments by clicking on the following link and then following the instructions.
Below is editorial content you can adapt as you wish to inform your comment:
Dear National Organic Standards Board (NOSB),
I urge you to continued allowing organic certification for container and greenhouse growing methods. Denying container-based agriculture this important designation will stifle innovation precisely when it is most critical that America improves water stewardship and ability to produce food in urban environments.
Limited Water Resources
Pressure on limited water resources is more severe than ever before. Soil-based agriculture is responsible for the vast majority of fresh water use in America. Soil-based farming consumes as much as 1000% more water than state-of-the-art container-based methods. Meanwhile the majority of Americans live in regions where water is being depleted at unsustainable rates.
In 2013 the National Academy of Sciences indicated that the High Plains aquifer was already depleted by 30%, with depletion expected to approach 70% within 50 years if current practices continue. Natural replenishment of the aquifer would take hundreds of years, with estimates ranging up to 1,300 years. The mid-west states affected by depletion of the High Plains aquifer are home to nearly 70 million Americans.
California currently supplies 50% of the fruits and vegetables consumed in the United States, with agriculture consuming the vast majority of fresh water resources. Yet drought and soil-based agricultural practices have depleted California's fresh water resources by 11 trillion gallons as of 2014, with over 7 trillion gallons of that depleted from California's aquifers. The magnitude of this depletion was quantified by NASA's Gravity Recovery and Climate Experiment (GRACE) satellite mission. Nor is California unique.
In 2014 Scripps Institute of Oceanography published a study showing that the western United States had lost a total of 63 trillion gallons of water since 2003. GPS measurements throughout the west show the loss of water is causing the land to rise up. The pervasive drought conditions threaten millions of acres of farmland and the economy where over 75 million Americans live.
In 2015 NASA documented the shocking depletion of global groundwater resources, finding that 21 of the worlds 37 largest aquifers are experiencing unsustainable depletion. The Atlantic and Gulf Coastal Plains aquifer, supporting over 120 million Americans, is among those where use far outstrips natural rates of recharge.
The Northeastern US, home of many of those passionately advocating withdrawal of organic status for container-grown crops, is not experiencing water stress. Farmers in the Northeast are neighbors to fewer than 60 million individuals, less than 20% of the US population in 2015.
Further, agricultural production in the Northeast only supplies a small percentage of the total food needs of Northeast residents. Cornell University researcher, Christian Peters, documented New York State's food production capacity from 2006 to 2009. New York farmers were able to feed less than 35% of state residents, with New York city residents receiving only 2% of their food needs from farmers in New York state.
Food Deserts and Social Justice
New York City residents only obtain 2% of their food from New York state farmers, according to research performed by Christian Peters at Cornell University. Tourists to New York City see an abundance of small groceries with fresh food. But in 2008 the New York Times publicized that millions of city residents have adeuqate access to fresh food resources. A comprehensive analysis of the entire city demonstrated in 2008 that 750,000 residents lived more than five blocks from a grocery of supermarket. A "Supermarket Need Index" showed significant patches of under-served neighborhoods in Staten Island, the north of Manhattan, the Bronx, and Queens. These under-served neighborhoods correlated strongly with neighborhoods with as many as 25% reporting they had eaten no fruits or vegetables the prior day. The United Hospital Fund demonstrated that the neighborhoods that typically didn't eat fruits and vegetables suffered the highest rates of obesity and diabetes.
New York City graphically demonstrates the health burden imposed on the poor in urban environments. This is America's problem, with over 60% of Americans living in cities and over 80% of Americans living in an "urban" environment.
Urban environments pose significant barriers to organic soil-based farming. Land is rarely available in large enough plots to sustain a profitable soil-based farm. Available plots are often contaminated by urban byproducts that make the land under-productive and inappropriate for safe food production, much less organic food production. It is only through use of container and greenhouse agricultural methods that food production density and safety can be achieved in urban environments.
To categorically deny organic certification to container-based agriculture will further disadvantage the only forms of agriculture appropriate for the neighborhoods where 80% of Americans live. While not every urban farmer will seek organic certification, all container-based agriculture will benefit from the ability of the few to innovate with the approbation of that sector of the public that desires organic food and can afford the time and money associated with avoiding non-organic foods.
The hard-working organic farmer growing crops in the ground deserves a label that conveys the visceral appeal soil-grown crops have for many consumers.
However not every consumer who purchases organic produce and products is primarily motivated by the nostalgia for traditionally-grown crops. Some consumers primarily desire food that is locally grown and free of pesticides and antibiotics. They want food that is sustainable and safe for their loved ones. The precise method by which this food is produced is of secondary importance to them.
Rather than restrict Americans to only those organic crops grown in soil, we suggest that organic labeling be updated to honor soil-grown crops in a separate category from crops grown using container-based methods like aquaponics and hydroponics. This will allow soil-based agriculture to enjoy exclusive access to those who feel passionately about soil-based farming, without denying innovative sustainable agriculture access to those customers who wish "organic" food by whatever method excludes unnatural pesticides, antibiotics, and nutrients.
Sterile Food Production and Other Myths
It appears one objection to container-based agriculture is the belief that soil itself is uniquely capable of supporting soil enrichment and providing plant roots robust microbial environments.
Despite the penchant for hydroponic growers to frequently bleach their systems between crops, studies show hydroponically-grown plants do benefit from significant microbial synergy in the root zone. A unit volume of hydroponic solution contains a similar number of bacteria as the same volume of compost (1 million bacteria per ml in hydroponic solution versus 100,000-10 million bacteria seen in a ml of various composts). Mycorrhizal fungi thrive in hydroponics and aquaponics, serving the same role in water and nutrient absorption for container-grown plants that the do in soil-grown plants. Studies show the presence of beneficial bacteria and funghi in a relatively sterile hydroponic system can increase in a single day to the level of beneficial bacteria seen in compost. Whether plants are grown in soil or solution, they gather around themselves the beneficial bacteria they need to thrive.
While hydroponic nutrient solution may not be used directly to enrich local soils, the bulk of plant material derives from oxygen, and carbon from the air combined with sunshine and water. The plant material that is not sold can be composted to enrich the soils in the vicinity of the hydroponic farm.
In the case of aquaponics, the bulk of required plant nutrients are naturally produced as a result of fish waste within a container-based recirculating system. Aquaponics produces fish emulsion as well as excess plant material, providing for significant enrichment of soils in the vicinity of an aquaponic farm.
Advocates of soil-based agriculture perceive the stewardship they exercise over the soils of their agricultural holdings. By contrast, they do not see the benefit containers provide to soil and biodiversity.
However, it is not so much that containers enrich the soil immediately beneath them, but that containers permit greater production within the same area. Turning this around, this means for the same amount of food produce, more land is freed up for the biodiversity of nature itself.
One final myth that should be addressed is the idea that organic soil-based agriculture does not disturb natural ecosystems. C&A is one of the world's largest retailers of organic cotton apparel, and desired to demonstrate the value of organic cotton production in terms of water footprint. Specifically, they wanted to show that conventional methods of producing cotton created a vast pollution burden compared to organic production. In the draft version of their report, C&A asserted that there was no pollution burden associated with organic cotton production. When the draft report was presented to the Water Footprint Network (formerly a branch of UNESCO), the water footprint scientists corrected the understandable error. Whether fertilizer is synthetic or organic, damaging components of fertilizer leach into local waters at a rate of 10% (for nitrate) and 2% (for phosphorus). The nutrients cause eutrophication in local waters, producing algae blooms, oxygen deprivation, and fish kills. The additional pollution burden associated with pesticides and other chemicals may be 5 times greater than the pollution associated with nutrients, making organic production clearly better than conventional production. But it is not true that soil-based organic production does not harm to natural ecosystems in the vicinity of a farm.
In comparison to the natural nutrient leachate associated with soil production, proper container-based agriculture minimizes or eliminates the leaching of nutrients into the surrounding environment, particularly sensitive water resources. This is a reason that use of aquaponics, for example, is exploding in the Pacific and Asia. Purity of local water resources is of paramount importance to those living on islands. Pacific Rim nations also lack the abundant per capita land resources possessed by the continental United States. The ability to produce significant food resources on limited land resources without contaminating fragile water resources is attractive to people who live in such a constrained environment.
Intent of the Organic Movement
The original intent of the organic movement was to use biology to cycle natural inputs while avoiding prohibited substances.
An attempt to exclude container-based agriculture from the organic umbrella not only hurts container-based agriculture industries, it risks harming the relevance of the organic movement itself.
Edwin Markham penned the famous epigram title "Outwitted":
He drew a circle that shut me out--
Heretic, a rebel, a thing to flout.
But Love and I had the wit to win:
We drew a circle that took him in!
Were the NOSB and NOP to exclude container-based agriculture from inclusion in the organic movement, there would be a perception by some that the move had more to do with protectionism that either science or sustainability.
Further, there is the question of where the exclusionary circle would be drawn. Would traditional soil crops that are transplanted to containers and grown to maturity in greenhouses be considered soil crops or container-grown crops? There are vast numbers of organic farmers that take advantage of such time-honored production techniques. To exclude them from the organic movement would be damaging to the organic infrastructure of farmers and food production businesses that can currently tout the organic label. To include them while excluding other container-based agricultural methods would be patently unfair.
Also worth noting is the number of organic products that are not grown in soil. Seaweed and kelp come to mind. Microgreens and sprouts are not grown in soil. Spirulina is an algae that isn't grown in soil. Would these nutrient rich products be excluded from the organic movement? If not, on what rational basis would it make sense to exclude container-based agricultural products if these water-grown agricultural products are accorded organic status?
For those who have followed the history of the recent USDA Organic Hydroponic and Aquaponic Task Force, it is clear that appropriate processes were not followed. The Task Force was populated by a mix of scientists and long-time organic advocates. However the timeframe the task force had been promised to develop the report was foreshortened. The number of in-person meetings was cut from two to one. The report that was issued did not contain concurrence signatures from all members of the task force, notably omitting scientists specializing in hydroponics and aquaponics.
Rather than developing refined standards for organic container-based agriculture, the issued report relied on opinion and pseudo-science to argue that container-based agriculture should be excluded from eligibility for organic certification. The lack of probity reflected in the report has been shocking to long-time observers of the organic movement. Scientists attempting to advance innovations that can promote sustainable agriculture and urban crop production have been thoroughly disheartened by the unprofessional and unscientific black-balling on the part of those insisting ground-based soil farming must be the basis for organic certification.
Americans have a right to government that governs in the best interest of all. While not everyone will be pleased by the final position taken by government, it is incumbent on the National Organic Program to base its determination regarding container-based agriculture on science and the public benefit. Protectionist cronyism ought not be the basis for changing organic standards in a way that damages public health, prohibits wise stewardship of natural resources, and flies in the face of the original intent of the organic movement.
I urge you to retain container-based agriculture as part of the suite of growing methods considered eligible for organic certification. To do otherwise flies in the face of scientific fact, damages national food security, and panders to a minority that is not affected by water deficits and urban conditions, each affecting over 80% of Americans in their different ways.
Should the matter of organic certification for hydroponics and aquaponics be raised during the fall NOSB meeting, I urge that the recommendation be limited to differentiating organic labeling for soil-based agriculture versus organic labeling for hydroponics, organic labeling for aquaponics, and organic labeling for container-based soil agriculture. In that vein, organic labeling for crops that can't be grown in soil should be identified if labeling is differentiated.
Regards/Sincerely/Very Truly Yours/etc.,