My name is Dave Chapman and I am the owner/grower at Long Wind Farm. We grow organic tomatoes in our 2 acre greenhouse in East Thetford, Vermont. We have been certified organic since the Vermont Organic Farmers (VOF) began in 1985. We were one of the original 13 farms certified organic by VOF. There has been tremendous growth of certified organic production worldwide since those small beginnings.

I am doing this because of my deep concern about a failure in the process of maintaining the national organic standards. In 2010 the NOSB (National Organic Standards Board) submitted a recommendation to the NOP (National Organic Program) that hydroponic production NOT be certified as organic. (See below). Until that time the issue of soil-less growing had never been addressed by the NOP, so the the NOP asked the NOSB to come up with a recommendation. The NOSB voted 12 to 1 to prohibit hydroponic production. The recommendations of the NOSB are almost always accepted by the NOP, but in this case the NOP has not acted on the NOSB recommendation, and the NOP continues to allow hydroponic production to be certified as organic. The NOP has not offered any guidance to certifying agencies on this matter.

Presently, the vast majority of the “hydroponic organic” produce sold in this country is grown in either Mexico, Canada, or Holland. ALL THREE OF THESE COUNTRIES PROHIBIT HYDROPONICALLY PRODUCED VEGETABLES TO BE SOLD AS ORGANIC IN THEIR OWN COUNTRIES. Mexico, Canada, Japan, New Zealand, and 24 European countries, (including Holland, England, Germany, Italy, France, and Spain) all prohibit hydroponic vegetable production to be sold as organic in their own countries. The NOSB has formally recommended that the United States join the international community in this common definition of organic produce. The USA is very isolated in the decision to allow “organic hydroponic.”

Hydroponic growing is a soil-less system in which all the nutrients are supplied to the plants through a fertigation system. There is no soil involved. It is the polar opposite of the old organic adage, “Feed the soil, not the plant.” Hydroponic growing is based on the belief, “Feed the plant, not the soil.”

The stated NOP standard emphasizes that organic growing is based on caring for the soil. (See below), but their refusal to prohibit soil-less growing contradicts this.

The link to the NOSB Recommendation to the NOP on soilless production:

NOP Standard on soil:

(a) The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion.

(b) The producer must manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials.

(c) The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.