Dear Friend,

Today we would like to feature a letter we received from one of our real organic farmers about his choice to drop USDA certification, despite continuing to farm organically. We have featured Todd Ulizio for his work in co-founding The Farmers’ Stand, a locally run grocery store that carries local and organic products.

This week, Todd shared with us an exchange with his certifier (the Montana Department of Agriculture) along with a reply from Doug Crabtree, a fellow Montana real organic farmer.

Todd and Rebecca Ulizio of Two Bear Farm
 Co-founders of The Farmers’ Stand in Whitefish Montana

Letter from Todd:

Hi Linley and Dave,

Given our past discussions, I wanted to let you know that I formally surrendered by organic certification to the Montana Dept. of Ag for the 2023 season. I did so with mixed feelings, and it was not an easy decision. I am saddened that something I believe in so much is in the hands of a federal agency that seems to excel at violating trust. In the end, I need a break from the USDA for a year. And this may prove to be a bad choice, and I may be back, so let’s just consider it an experiment.   I’ve forwarded the letter that I wrote to the current organic administrator, as well as Doug Crabtree (who is a ROP member), Real Organic farmer, and former head of the organic program with the state, just to share what I said and to keep you in the loop. If you are interested, you should read that first. The response I received from the Montana Dept. of Ag was exactly the type of shoulder shrug I expected. What I would have liked to hear from her was recognition that there are issues with the NOP, and that she sees them, and hears me.  But maybe she doesn’t feel that way.


Todd’s letter to the Montana Department of Agriculture:

Back in 2016, I gave a presentation at the annual Montana Organic Association (MOA) conference with the head of the Montana Department of Agriculture and Doug Crabtree in Kalispell on transitioning to organic certification. We all stood in front of the audience and said that while the organic label is ultimately a marketing tool, it means far more than just being free of synthetic herbicides and chemicals. It’s a set of whole farm standards that address soil and ecosystem health. Fast forward to today, and this is no longer the case.

The NOPs decision to allow and certify hydroponic operations (going against NOSB recommendation in doing so), violates the trust of the organic movement, it directly harms soil-based fruit and vegetable growers, and it undermines the integrity of the label. When I go to fill out my Organic Producer Plan, I recognize that all those areas for crop rotations, weed management, habitat, etc. would be non-applicable to a hydroponic operation, which provide no ecosystem services. So then what is required to be organic? Can I leave half the application blank? Or does this simply set a double standard where soil-based farmers need to reach a high bar, but hydroponics can get the same certification by achieving a lower bar?

At the end of the day, this not only harms small soil-based farms, but it violates consumer trust and it degrades the nutritional reputation of organic food (if you accept that hydroponic food is nutritionally less dense than soil grown food). What needed to happen is the creation of a separate hydro-organic label. But even the hydro industry knew that this would be too transparent for consumers, and consumers would choose soil-based. So the NOP caved to the industry in the name of creating a “bigger tent” for organics. They violated the trust of the movement in order to favor the industry. Go ask strawberry and blueberry growers in California and Florida how this has affected them. This change in policy creates a real risk to our business, and it goes against our values.

I have been a part of the Real Organic Project, as I know Doug is as well, which is fighting for enforcing certification based on the letter and intent of the original organic legislation. Even this large group with arguments based in reason and fact seems to have no effect on the USDA and its pro-industry approach. One only need to look at the history of farming in this country to see that the USDA tends to favor industry over individual farmers. So, while abandoning 50 years of the organic movement is difficult to consider, staying in a relationship with the USDA that undermines my business (and costs me money to do so) and violates my trust seems even more unpalatable. As a community-based farm that has built trust with our customers and sells directly to them, we never needed the label for marketing. We chose to support it because it stood for values and integrity that we believed in. After 15 years of USDA organic certification, we are choosing to surrender our certification for 2023 as an act of protest. I recognize that in the halls of government, this may result in little more than a shrug of the shoulders, but here on our farm, integrity still matters to us.

Thank you for your time,

Todd Ulizio
Two Bear Farm
Whitefish, MT

Response from the Montana Department of Agriculture:

Thank you Rebecca and Todd for your complete, detailed and powerful explanation.

We wish you the best for your future business endeavors.


Response from Doug Crabtree:

Thank you for including me in your communication.

First of all, I share your bewilderment at the unfortunate series of illogical decisions that have led us to organic certification of hydroponic plant production facilities. It is a travesty! If our markets did not require (NOP) certification, we might consider a similar protest to yours.

In addition to the absurd certification of hydroponic plant factories, we also continue to certify far too many farms that utterly lack crop diversity. I (still) note that there are more acres of wheat certified in Montana than all other crops, combined. We continue to certify farms that routinely practice fallow, which is actually the second most common “crop” certified in our state. These facts are further evidence that the standards for rotation, diversity and soil health are routinely ignored. I am not sure if a wheat-fallow farm is more or less damaging than a hydroponic factory. But, neither have any place in organic, as I define and believe in it.

Finally (maybe should be first), on my list of concern/complaints is that the organic market is growing ever-more to resemble the utterly corrupt and exploitive commodity market that plagues the majority of agriculture. I have always insisted that organic is a community- more than simply a certification or a market. While I hold to that belief, I observe more and more certified entities that neither value nor participate in the community that I am part of.

That said, I must argue that despite deep disappointment with a few aspects of organic certification, I still believe that it is the best vehicle to bring market support to healthier and more sane farming systems. We will continue to certify our operation, while also working “within the beast” to improve standards and practice. Most importantly, we will continue to model practices that adhere to the letter of standards AND to the spirit of the organic movement.

While I understand- even respect- your decision to surrender organic certification, I am deeply disappointed. The loss of farms like yours and farmers like you from the certified community is a great loss to all of us.  I suspect that you will not suffer significantly, as your markets are local and direct. But, it is farms like yours that consumers envision when they choose to purchase organic food- even flour, rye whiskey or pea protein that started on our farm. As you rightly observe, the unfortunate decision and policies that we decry benefit a few in the short run, but- rightly- threaten consumer trust in the organic label. Without that trust, there is no market, no need for certification, no organic, and no reward for sanity in agriculture.

Continue to treat the earth and each other with love and respect. I wish you well!

Doug Crabtree
Vilicus Farm

Hi Linley and Dave,

Thanks again for all the work that went into the recent symposium!

After the Symposium, I received a call from both Bob Quinn and Robin Kelson (AERO Montana) asking me what I thought the path forward was. I know Bob has plenty of experience fighting directly against the industry, and he likes to say all he ever ends up with is a bloody nose. I told him my goal was to focus on my direct community. We opened a grocery store / market named The Farmers’ Stand two years ago, to support local ag and to build a new system from the ground up.  Bob came to visit us when we were remodeling the space, and he loved the idea. Now that we’re 2 years in and it’s thriving, Bob feels like it’s a great, tangible approach that any community could replicate (although every community is unique). I mention it because I think a lot of people are struggling with what the path forward is. And I think the community-based approach offers some real opportunities for real change that maybe the national/global arena does not. And maybe that can be a newsletter topic one day as well.  



The Farmers’ Stand in Whitefish, Montana
A farmer-owned grocery store
Produce cooler at The Farmers’ Stand

Thanks to Todd for keeping the Real Organic Project in the loop. His email leaves me wondering…

Organic farmers set out to create an alternative to chemical agriculture and to the system that such Big Ag is a part of. Initially, one positive result of the USDA Organic seal was the support it brought for the survival of family farms and communities. Unfortunately, the industrialization and consolidation that has occurred in chemical agriculture is now coming to USDA Organic as well.

Will the Real Organic Project be enough to hold on to all the gains we have made as a community by creating USDA Organic? Our executive board member, Paul Muller has reminded us time and again. The farmers will not succeed if the “eaters” don’t come with us. So, if you live in NorthWest Montana, support The Farmers’ Stand and if you live elsewhere we can help you find farmers like Todd and Rebecca. We can only do this together.

Yours in the dirt,

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