request that the NOSB define "ORGANIC" certification to include plants grown with natural hydroponics and aquaponics, where these systems can show that they meet or exceed established standards that limit the use of pesticides, herbicides, fungicides, growth hormones and the like.
WE also request that the NOSB fully disclose by which scientific method or other standard that they make this decision.
WE also request that the NOSB consider the following arguments in making their decision:
1. Some states currently allow this type of system to be certified organic.
2. Consumers are concerned solely with the issue of pesticides and additives, not rooting media.
3. Some organically-certified crops are grown in water, such as water chestnuts and cranberries.
4. Some farm-raised fish is certified organic.
5. Organic milk, meat and eggs are certified without mention of soil, as they are animal-based.
6. It is not possible to cheat with aquaponics by using additives, as the fish will be harmed.
7. It is possible to show a nearly closed loop organic system with aquaponics, much more easily than with field-grown methods.
8. Aquaponically-grown vegetables are no different nutritionally than field-grown.
9. The socioeconomic value of adding the USDA organic stamp is significant, as it will enable a new class of small growers and entrepreneurs, both urban and rural, as modeled by Milwaukee's Growing Power (http://www.growingpower.org)
10. A new stream of local food production will not take away market share from US field growers, but will replace a portion of what is imported from tropical countries.
11. Water in a recirculating system must be free of all pollutants and uses a tiny fraction of the amount needed for traditional irrigation.
12. We contend that "soil" per se is not a valid scientific criteria, nor a consumer marketing criteria, when determining what is organic.