OFA Director Testimony to NOSB

April 23, 2020

RE: General Comments to the NOSB via Webinar Testimony

Thank you, members of the NOSB for the opportunity to speak before you today.  My name is Kate Mendenhall, I am the director of the Organic Farmers Association and am also an Iowa organic farmer.  OFA was created to be a strong voice and advocate for certified organic farmers.  We are led and controlled by domestic certified organic farmers and only certified organic farmers determine our policies.

Each year U.S. certified organic farmers are invited to participate in our grassroots policy process and identify their top policy priorities.  Organic farmers have stated that their top 5 policy priority for 2020 are:

  1. NOP Enforcement to Ensure Organic Integrity
  2. Organic Import Fraud
  3. Prohibit Hydroponics in Organic Production
  4. Climate Change
  5. Organic Dairy Standards & Enforcement (Includes Origin of Organic Livestock & Pasture Rule)

For the past three years, organic integrity has been at the top of the list.  Organic farmers built and established the organic label, and now they rely on the National Organic Program and the NOSB to preserve and enforce it.  Without strong regulations and standards enforced equitably across size, region, and commodity, the organic label will wither.  Prohibiting hydroponics has returned to 3rd place on the OFA priority list for the second year in a row.  Farmers nationwide are committed to healthy soil and the crucial role it plays in a healthy organic agro-ecosystem, and even conventional farmers and politicians are beginning to advocate for its important role in mitigating climate change. For organic to underplay the importance of organic soil now would be misguided.

Since the NOP declared just a few years ago that hydroponics is allowed, we have seen a burst of hydroponic operations and enforcement issues that highlight real problems and concerns on this issue.  We cannot have a production system out of compliance with the definition of organic.  We cannot have certifiers creating their own standards to regulate this booming sector, and we cannot undercut a label that farmers have built over the past 40 years.  With the 50th Anniversary of Earth Day celebrated yesterday, we should focus on making sure that certified organic, the gold production standard, is upholding its values, not undercutting them when Mother Earth needs us most.  The NOSB needs to revisit this issue.

Organic Farmers Association supports the NOSB process and agrees with the Crop Subcommittee’s assessment and support for paper-pots as an allowable synthetic and defined planting aid.  One lesson that is clear from COVID-19 is that we need more small to mid-size organic farmers throughout our communities able to meet our local food needs.  Paper pots help small organic farmers and are similar to already-approved inputs.

While Organic Farmers Association does not have a position on biodegradable mulch, I will comment that this policy issue was proposed in our grassroots process, yet it did not receive any farmer support to bring it forward.  With domestic and import fraud still gaining headline space nationwide, a lack of guidance from NOP on 3-year transition equity across growing practices, hydroponic production operating on a per-certifier basis and undermining the very definition of organic, biodegradable mulch seems like a low-priority topic for precious NOSB volunteer time.  Let’s get busy on the issues that are crucial for the organic community, not special interests.

I appreciate all of your dedication to working for the full organic community, for hearing public comment today, and for the farmers especially, who have had to find others to cover their farm-work so they can fully participate in this process over the two-weeks of meetings.