NOSB Testimony April 20 & 22, 2021

April 20, 2021

Patty Lovera, Policy Director

RE: General Comments to the NOSB via Webinar Testimony

My name is Patty Lovera, and I am the policy director for the Organic Farmers Association. OFA is led by domestic certified organic farmers and only certified organic farmers determine our policies.

Today I will talk about several topics covered in our written comments and on Thursday, OFA’s director Kate Mendenhall will also comment on other issues.

Paper Based Crop Planting Aids

The issue of paper pots is on the agenda for the NOSB because this is a tool that is critical to the many small farms that depend on this product.

Therefore, we appreciate the Board’s efforts to address this need and clarify the status of paper on the national list. OFA supports this proposal and definition change.

Ammonia Extract

OFA included a general question on ammonia extract (not specifying the source) on our 2021 policy priorities survey of certified organic farmers. The majority of those who answered said they would not use ammonia extract if it were available, and we got some written comments with concerns about feeding the soil vs. feeding the plant that reflect the discussion on compatibility with organic principles that the board addresses in its discussion document.

But it was not unanimous. So, we urge the board to consider a more formal process for gathering farmer input on their current practices.

And we want to raise that there were some comments in the vein of “never say never…”. We think this makes the context for this debate critically important – we are hearing from many producers about worrying price trends, especially in row crops, as we continue to look for more enforcement to stop fraud. This combined with rising land prices has created economic pressure for increased yields. And we think that is driving the type of comment like “never say never” when thinking about something like ammonia extract. That is not an excuse to approve a material if it does not meet the principles of organic production. But it is something we need to think about as an organic community – we need to find a place to have conversations about these bigger economic trends impacting organic producers, or we will continue to have these very difficult decisions about specific inputs while never addressing why many producers are driven to seek out higher yields.

Discussion Document – Supporting the Work of the NOSB

It is vital that the NOSB be fully representative of the organic community, including certified organic farmers. But it is a very demanding job to ask of volunteers, who are also handling demanding jobs like farming.

We think it is appropriate to consider measures like research assistance – but we believe there should be some guidelines established. We listed several in our written comments, but wanted to highlight two today:

  • Need for a conflict-of-interest process – it is important to establish a process to identify potential conflicts due to other employment or research funding that could pose a conflict.
  • Individual board members should create the workplan for the topics their research assistant works on and be able to specify what type of research is needed.

Beyond the questions posed in the discussion document for this meeting, we urge the NOP to consider mechanisms to help farmers on the board cover costs they incur for participating in the meetings, such as the cost of hired help for their farm while they are performing board duties.

Thank you.


April 22, 2021

Kate Mendenhall, Executive Director

RE: General Comments to the NOSB via Webinar Testimony

Thank you, NOSB members for the opportunity to speak before you today.  Welcome new members.  My name is Kate Mendenhall, I am the Executive Director of the Organic Farmers Association.  OFA was created to be a strong national voice and advocate for domestic certified organic farmers.

In addition to leading OFA, I also own and operate a small diversified organic farm in my Iowa hometown.  I grew up in small-town Iowa during the 1980s farm crisis, and by the time I graduated high school, only a couple peers were still living on their family farms and small rural towns across the state were boarded up.  Now in some cases there is merely a billboard showing  a photo of the town that used to be, where now immense corn and soy fields take its place.

I left thinking there must be a better way for family farmers to make a living, to better care for the earth, and to keep our rural communities thriving and  I found it in organic agriculture.  Organic farming grew as an alternative to the industrial conventional model.  It is based on principles of nature that not only care for the earth and climate but also our surrounding communities.  I point this out because as organic has grown at record-breaking speed over the last two decades especially, we must not lose the spark that started it all.

Corporatization, consolidation, battles over price, sexy technologies with high lobbying dollars pose severe risk to the principles of organic farming –both ecological and cultural.  We must keep organic principles and values front and center at every decision for the evolution of the label.

To do this we need real leadership and enforcement from the NOP.  The 2019 NOP memo on container growing and transition left more questions than it answered.  The NOP asked certifiers to prove there was inconsistency in interpretation of greenhouse transition, which NOC, OFA, and ACA presented in the fall.  The NOP must provide clarity, pass long-outdated rulemaking like OOL, OLPP, and SOE, and stop allowing certifiers from certifying production systems lacking national standards.  We must work hard to clarify and enforce standards that maintain the principle of organic farming at heart.  As we drag our feet, family farms suffer, and big industrial farms push their way through until they’re too big to fail.  We cannot allow organic farming to follow the footsteps of industrial agriculture.

Organic farmers continue to highly prioritize soil and do not agree with organic hydroponic .  Already family farms are being outcompeted in the market from hydroponic farms that are literally watering down organic standards.  I was taught that when you make a mistake, you need to go back and fix it.  This is something the organic community must continue to fight for.  Already hydroponic organic  has become the wild west of organic certification.  Greenhouses are certifier shopping, the NOP is pressuring certifiers to certify a production system they do not have standards for, and the NOP refuses to provide clarity when certifiers need a unifying decision upholding OFPA.

The nitty gritty issues of the NOSB and NOP cannot be looked at through a microscope without seeing the holistic picture of this organic program farmers built and are desperately fighting to hold on to.