Real Organic Project Debates OTA

Last weekend I debated Jo Mirenda from the Organic Trade Association on the most basic of questions:

“Is the USDA National Organic Program Doing its Job (protecting the values of traditional organic agriculture and meeting consumer expectations)?”

I said no.

It was a strange debate because Jo seemed to agree with me, with the caveat that the proposed changes OTA hopes to implement will transform the NOP and save the day.

I think that it was clear to all of us in the room that the USDA is failing in protecting the values of traditional organic agriculture.

My comments begin at the 10-minute mark.

We did not discuss HOW we lost the NOP, which would have probably led to a heated debate. And perhaps at this point, the bigger question is what will we do now? If we still care about the values of traditional organic agriculture, what do we do when the gatekeeper is not protecting the community?

Jo Mirenda of the Organic Trade Association debates Dave Chapman of the Real Organic Project at the NOFA Summer Conference at Hampshire College on August 10, 2019. Moderated by Jack Kittredge publisher of the Natural Farmer.

Jo Mirenda of the Organic Trade Association debates Dave Chapman of Real Organic Project at the NOFA Summer Conference at Hampshire College, August 10, 2019.

For me, the answer is that we must come together and find a new way. If we can’t trust the USDA to serve and protect, then we must learn to serve ourselves, to protect ourselves. We need an add-on label to be able to find the real organic food we want to buy in the stores. That is a good start. But coming together and learning about the biology, economics, ecology, nutrition, history, politics, and climate implications of all this is critically important. The food system is not just a conversation for farmers and merchants anymore.

Split photo with aerial view of an indoor chicken CAFO (Concentrated Animal Feeding Operation) above and of certified organic chickens grazing on vegetated pasture below at Coyote Creek Farm in Texas.

Above: aerial view of an indoor chicken CAFO (Concentrated Animal Feeding Operation), like those earning USDA organic labels. Below: certified organic chickens grazing on vegetated pasture below at Coyote Creek Farm in Texas.

The food system is the key to our survival, both as individuals and as a species. If we can’t positively transform how we grow food and how we treat the earth, we are toast. Climate crisis demands that we change on a global level. This is an overwhelming task, and we mostly go numb. We disassociate. We check out.

Approaching this existential crisis from the doorway of organic farming is a way to start. We can access our desire to be healthy, to care for the land around us. That makes sense in our gut. Literally. The marvelous thing is that the same agricultural system that produces the most nutritious food also produces a livable climate. And once we start getting together, we can easily include the issues of social justice, labor fairness, and food access that cry for change.

All of this is why the Real Organic Project exists. Please join us. Please support us.

Many thanks,


Revisionist History Post Script

I am adding a long PS to this letter. Two months before the debate, one of the leaders of the Organic Trade Association (OTA) sent out a public letter to over 80 organic leaders around the world. It suggested we were telling lies about the OTA’s actions in the hydroponic battle. I had hoped that Jo and I would have a chance to address this public complaint during the debate, so I could answer these disturbing allegations. But the opportunity never presented itself. We were, after all, debating the role of the National Organic Program, not that of the OTA. Also, I was hesitant to take this on with Jo, as she was not part of OTA during that turbulent period, and has not made any such public accusation against the Real Organic Project.

The OTA campaign in favor of hydroponics was waged over several years. The campaign consisted of publicly supporting the 2010 NOSB recommendation while simultaneously rejecting their definition of hydroponics in that same recommendation. It left the NOSB hopelessly confused. As such, it was a very effective strategy.

OTA claimed that the term hydroponics only applied to “plants floating in water.” The OTA “War Of The Words” went on to insist that the definition of hydroponics should be limited to plants fertilized by “sterile” liquid feeds. This would effectively mean there is NO hydroponic production, because there are no sterile liquid feeds used in the real world. All liquid fertilizers contain microbes. Again, it is almost unbelievable that such suggestions were offered or taken seriously.

Hydroponics are now certified as organic on a large scale. NOT a settled issue.
At this point the NOSB was so confused they didn’t know which way was up. When they failed to pass the proposal clarifying the limits on hydroponics in 2017, they made the worst decision in their history. The NOP took this as an opportunity for the wholesale adoption of any hydroponic production using allowed inputs.

There is a final note on this discussion. Francis Thicke wrote a response to the OTA’s accusation. Francis was the chair of the NOSB Crops Subcommittee during the Jacksonville meeting. He has also served as a program leader for the USDA, the current chair of the Real Organic Project Standards Board, the former chair of the Organic Farmers Association Policy Committee, and a lifelong organic farmer. Unsolicited by me, he sent the following response. I reprint it with his permission:

“It is good that we are having this public discussion to help clear the air on OTA’s position on hydroponics/container growing. I must say, however, just as I was dismayed by the deception of some of the opponents of the NOSB hydroponics proposal in Jacksonville, I cannot be silent now when I see a revisionist history of it.

“As Chair of the NOSB Crops Subcommittee for the Jacksonville meeting, and the primary author of the CS hydroponics proposal, I want to first point out that from the perspective of the seven NOSB members who voted for the proposal, the hydroponics proposal was a major compromise from the 2010 NOSB recommendation, which would have required a soil-based system. I believe that most of us would have preferred a proposal in line with the EU, which would have prohibited hydroponic and container growing, with a few minor exceptions.

“First, let’s clarify the 2010 NOSB recommendation. It states: “…systems of crop production that eliminate soil from the system, such as hydroponics or aeroponics, cannot be considered as examples of acceptable organic farming practices” and “…the exclusion of soil from organic production of normally terrestrial, vascular plants violates the intent of the regulations.” So, if OTA supports the 2010 NOSB recommendation, it would be logical to assume that OTA does not support container growing without soil. Is that correct?

“At the Jacksonville meeting, Nate Lewis, then Farm Policy Advisor for the OTA, made public comments on behalf of OTA. If anyone should have known OTA’s position on hydroponics, it would have been Nate. After his comments, I asked Nate a question to try to get clarity on the ongoing equivocal position OTA had been taking on hydroponics. I asked Nate if he would call a container system with 100% liquid feed hydroponic, regardless of the substrate. Nate first responded with a strawman argument (the transcripts called it “strongman”) completely unrelated to hydroponics. I asked the same question of him again, and he replied “I don’t really want to answer, I mean, I’m sorry. What are you trying to get at? I don’t really…” I asked him a third time, and he replied “I don’t know.”

“It was a very simple question, and I was stunned that OTA’s Farm Policy Advisor refused to answer it.

“So, this is an opportunity for you to clarify for the organic community what OTA’s position on hydroponics really is. Can you please answer for us the question I posed to Nate: Is a container system with 100% liquid feeding—regardless of the substrate—hydroponic? To make the question even more straightforward, assume that the system in question uses coconut coir as a substrate, with no soil or compost being used. Would you call that system hydroponic? This is not a hypothetical question; this question pertains to production systems that are today operating as certified organic by OTA members.”

Francis Thicke

Who controls the National Organic Program? Who controls the OTA?

If there has been a tragic misunderstanding or a real change of heart on the OTA position, it can be quickly repaired.

The leadership of the Organic Trade Association has repeatedly claimed that they are opposed to the certification of hydroponic produce in organic. They claim that they have always supported the 2010 NOSB recommendation.

Wonderful! We are all on the same side. And together we should be impossible to stop.

So let the organic trade join the organic movement. I know that many organic processors DO support us. Let us be done with these divisions.

I invite OTA to call for the rejection of hydroponics in organic, as defined by the 2010 NOSB recommendation. If they act on this, they will lose a few members, but they will gain so much more. We will all gain so much more.

Or let’s have another debate to clear the air. I would welcome the chance to debate OTA’s leadership on the role of the OTA in the current NOP hydroponic mess. Perhaps we could arrange this at the NOFA VT Winter Conference? See you there!

The slides that I showed in the NOFA debate included images of Driscoll’s, Wholesum Harvest, and Aurora Dairy. Aurora is the largest CAFO organic dairy in America, and the subject of a Washington Post expose. Driscoll’s and Wholesum Harvest are the largest hydroponic “certified organic” producers in the world. They are all members in good standing who continue to support the Organic Trade Association.

Let the OTA part from these companies that are doing so much damage to organic. Rejoin the Real Organic Project, the Organic Farmers Association, the Regenerative Organic Alliance, the Organic Consumers Association, the National Organic Coalition, Cornucopia Institute, IFOAM International, thousands of organic farmers and millions of organic consumers in a united effort to protect organic. Not everyone on this list loves each other, but we all agree on what organic means on a basic level. Together we can reclaim the National Organic Program.