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Who Owns Organic?

Who Owns Organic?



I was in a debate last week hosted by the Ohio Ecological Food and Farm Association (OEFFA).  It was an exchange of ideas about the certification of hydroponic as organic. We debated the following resolution:

 “The future of certified organic production will include hydroponics.” 

Speaking in support of this resolution was Kelly Damewood, the CEO of CCOF (California Certified Organic Farmers). I was opposed.

I will limit this letter to what I said. Kelly has asked that I not quote her, concerned that her comments might be taken out of context. I will respect her wishes, so you will have to watch the full debate when OEFFA makes it available to hear both sides.

What is organic farming?


For me, this was not a complicated question. When I looked at the historical foundations of organic, it was ALWAYS based on the idea of “Feed the SOIL, not the plant.”

What does that mean? It sounds interesting, but…what does it mean?

“Feeding the soil” means feeding the living things in the soil. Healthy soil is teeming with life, with countless invisible bacteria and fungi. There can be billions of bacteria in a single gram of soil. There can be 24,000 kilometers of mycorrhizal fungal hyphae in a cubic meter of healthy soil. Those hyphae could go halfway around the earth if strung together. Plus vast numbers of soil animals (worms, springtails, moles and voles, arthropods such as nematodes, anthropods such as mites and spiders). It is dizzying.

Like us, all these living things need to eat, and they thrive off of the products of photosynthesis made by plants converting sunshine into food. Plants are Nature’s solar collectors. The life in the soil gives minerals to the plants in exchange for the sugars. Plants are a necessary part of a healthy soil. No plants; no life. Plants provide the organic matter and photosynthates that feed that life in the soil.

Organic farming, put simply, is returning organic matter to the soil so that the life in the soil cycles nutrients back to the crop. Highly soluble fertilizers kill much of the life in the soil, whereas organic matter feeds it.


That is organic farming. “Feed the soil, not the plant.” Feed the life in the soil, and the life in the soil will feed the plant, and it can feed a plant better than any chemist. There are 40,000 known secondary plant metabolites. Who knows the proper ratios? Who knows the proper compounds to become truly available to the plant or to the animal? No one. The results of a healthy living soil are superior nutrition for the plant, for the animal, for the human. The results include vastly less soil erosion, vastly better water retention, less drought, less flooding, less pollution in the rivers, better carbon sequestration, and a more resilient, reliable agricultural system. 

And, oh yes, the plants will be less sickly and less attractive to insects. So there will be less need for spraying poisons on our food, and on our farmers. Less cancer. Less destruction of biodiversity.

And, oh yes, the food will taste better too.

So that is organic farming at its best.

What is “conventional chemical” farming?


It is based on the principle of “Feed the PLANT, not the soil.”

It is simple. The soil is not considered to be important for feeding the plant. The farmer feeds the plant by applying processed fertilizers that have been treated to be “plant available.” They feed what they think is a proper diet for maximum plant growth in the shortest time possible. The simplified nutrition and the monocultures create greater pest and disease problems. The farmer deals with pests by spraying chemicals to kill the pests and other chemicals to kill the diseases. 

What is hydroponic production?


Hydroponics is most simply defined as providing the plant’s nutrition with a liquid solution. The nutrition for the plant is contained in the liquid. The plant gets little to no nutrition from whatever material (substrate) its roots are in. The nutrition is all added as a liquid fertilizer.

Some hydroponics have the roots resting in a water bath. Sometimes in a “pond” and sometimes in a tube of water.

Some hydroponics have roots dangling in the air where they are sprayed with a nutrient-rich mist. This is called “aeroponics.”

Driscoll's organic hydroponic berry production has greatly expanded from the 1,000 plus acres reported in 2016.

Some hydroponics have the roots sitting in containers or bags of “substrate.” In this kind of hydro, the substrate can be many materials, but the most common are shredded coconut husks (called “coco coir”). 

Growers use different systems based on the crop they are growing. Most hydro greens are grown in water baths or aeroponics. Most tomatoes, peppers, and berries are grown in containers of bags filled with coir.

So the basic principle of ALL hydroponics is… “Feed the PLANT, Not the Soil.”

Hydroponic tomatoes grow in white plastic square pots inside a green house. On the ground is a rail system between rows.


THAT is why we don't think that hydroponics can be called organic. It is a DIFFERENT system. It has a different understanding of how to grow a productive crop, of what is important in nutrition, even of how we encourage health in human bodies, animals, or plants.

Does it matter? To whom?

Well, according to the hydroponic industry, as represented by lobbyist Lee Frankel, “hydro sales certified as organic” exceeded $1 billion in 2017. 

What are the results?

  1. Consumers who think they are buying food from a farmer growing in healthy soils are defrauded.
  2. If organic advocates are right and the nutrition of food grown in healthy soil is superior, those same people are getting nutritionally inferior food while paying for something else.
  3. The real organic farmers who are displaced by that billion dollars of sales go out of business. The thought that the “organic tent” just gets bigger is not accurate. Some of those sales are new sales that come as a result of “cheaper” food (think Walmart), but some of them are the result of soil farmers being pushed out of the marketplace.
  4. The land that gets pushed out of organic production is no longer being farmed organically.

Kale plants are fertilized by a living mulch, a nitrogen-fixing cover crop, a foundational organic practice.

We learned in the debate that CCOF now estimates that they certify close to an 5000 acres of hydro/container acreage. I appreciated CCOF's transparency. 

At the same time, we learned that out of 4,000 CCOF certified organic producers, only 94 are hydroponic/container. Former USDA program director Miles McEvoy once agreed that far less than 1% of certified organic operations are hydroponic.

What this means is that a VERY small number of hydro producers are now deciding the standards for the National Organic Program. They just have too much money to stop.

There is no other reason that hydroponic is accepted as organic by the USDA.

When I served on the USDA Hydroponic Organic Taskforce, we learned that Driscoll’s (the biggest organic berry vendor in the world) was also the biggest “hydroponic organic” producer in the world with over a thousand acres of hydroponic berries being certified at that time.

Now their acreage is far greater.


Suddenly we understood why we were losing this fight. There was just too much money involved.

So who will protect organic?

The organic movement started with Albert and Louise Howard. They based their agricultural philosophy on the traditional farming methods of India and Southeast Asia. Their work was carried on by Eve Balfour in England and J.I.Rodale in America. 

In 1980 the USDA worked with Eliot Coleman to produce their first report on Organic Farming. And they got it: “Soil is the Source of Life.” and “Feed the Soil, Not the Plant.” 

This was continued by all the regional organizations that supported organic farming. We all agreed that the foundation of organic was to “Feed the Soil, Not the Plant.” 

This definition of organic has been supported by the law, when Congress passed the Organic Food Production Act (known as OFPA).

It was reaffirmed by the 2010 NOSB recommendation to prohibit hydroponics in organic certification.

It has since been embraced by the Organic Farmers Association and the National Organic Coalition.

In 2017 a petition calling on the USDA to prohibit hydroponics in organic certification got over 100,000 signatures in three weeks. This petition was presented to the USDA (and got no response).

Hydro Blueberries in Florida. The future of USDA Organic?

In 2014, the USDA’s  National Organic Program made its first-ever announcement that it was embracing hydroponics. Before this, there had never been a stated policy. This announcement was in direct opposition to the 2010 NOSB recommendation (which the NOP had promised to act on). 

To this day the USDA has not set out actual standards for hydroponic production. The problem with this is seen by the USDA permitting the use of glyphosate (RoundUp) on land used for hydro production immediately prior to certification. This practice was finally banned after the Real Organic Project mounted a public campaign opposing this in 2019.

The USDA STILL allows the use of prohibited pesticides in hydro greenhouses immediately prior to organic certification. They have refused countless times to even answer questions about this allowance.

The hydroponic invasion is leading to the serious undermining of the organic brand.

Please don't shoot the messenger!

This erosion of public trust has led to the growing popularity of the “Regenerative” brand, which faces even greater problems than the organic brand. 

Customer doubts about organic have been blamed on the organic movement for daring to speak up about the eroding standards.


As  people who care are seeking a path forward, there are four choices

  1. Remain silent and accept a corporate redefinition of “certified organic.”
  2. Fight for reform of the USDA.
  3. Create a new word for organic. Something like “Agroecological.”
  4. Create a Real Organic add-on label to represent the original meaning of organic.

At the Real Organic Project, we still fight for reform, but we have chosen not to wait for government approval. We are pushing for a label that people can trust today.


The OEFFA debate had a vote at the beginning and at the end to see if people’s minds had been changed.

The results of the vote

“Proposition- The future of certified organic production will include hydroponics.” 

In the beginning:
Agree – 17%
Disagree – 47%
Undecided – 37%

At the end of the debate:
Agree- 12%
Disagree – 77%
Undecided – 11%

This outcome confirmed my basic belief that hydroponics can only survive in the organic label with smoke and mirrors. Any actual examination of the facts leads to a simple conclusion. Hydroponics has no place being called organic. Along with CAFOs, its future inclusion will damage or destroy the real meaning of the word organic.

Let’s not let that happen. Join 1000 Real Fans today and help us build organic into a transformative force in the American food system.

See you at the MOSES Conference this week.

Many thanks,
Dave and Linley

Jo Mirenda, Jack Kittredge, and Dave Chapman at the ROP vs OTA debate at 2019 NOFA Summer Conference

Real Organic Project Debates OTA

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.