Dear Jim:

Thank you for taking the time to respond to my position paper on organic and wildness. I was hoping it would start a dialog and your critique helps that happen.

I think there are several fundamental misconceptions in your response which I will outline below and perhaps it will move the dialog further along.

First, there is a clear distinction between "organic by neglect" and self-regulating systems. As you know, organic by neglect is a term which grew out of the organic community to describe "organic" operations which simply stopped using unacceptable input materials without taking steps to replace the industrial management practices with ecological ones. This is not what happens in nature. Nature in the wild is a self-regulating system, one that we try to EMULATE in domesticated, human-managed organic systems. This is what Sir Albert Howard had in mind when he outlined his famous "farming in nature's image" summary. His reference to leaving both plants and animals "to protect themselves against disease" is NOT organic by neglect, but a testament to the fact that when natural systems are restored to their original ecological balance, plants and animals have the resources to fend off diseases without human intervention.

When nature's wild areas are sufficiently undisturbed to develop such self-regulating systems, (the goal we are trying to achieve on organic farms) why are such areas not certifiable as organic? By what logic do we certify the copy (the human-managed, domesticated system) and not the original?

I believe that there is also a misconception in your response about the nature of the OFPA. The law was clearly written with domesticated, human-managed systems in mind. So the details of the law understandably are written to describe those systems and the requirements for certification of those systems. But the law also makes provision for wild systems, without spelling out the same detail that it does for domesticated systems. Understandably so since the place of these systems within organic were barely understood at the time the law was written. And apparently still poorly understood today. But by what logic do we insist that the wild systems must fit the language describing the domesticated systems?

The law leaves a similar matter (also not well understood a the time the law was drafted) open with respect to the requirement of "retaining the integrity" of organic food in processing. We have to assume that the law expected that the NOSB would spell out how that should be done. Isn't it reasonable to assume that the law expected the NOSB to do the same thing with regard to how wild production would fit into the law?

Consequently, it seems pointless to try to make every aspect of wild production "fit" every jot and title of the law as you do in your effort to prove that wild production and organic are incompatible. Whether or not they are compatible depends exactly on the "literary explanation" of their similarity which you say you "cannot, and will not, dispute." Crafting rigorous standards for organic production in the wild is the task before us, and the one I am trying to start.

There is a further misconception regarding your interpretation of 100% organic feed for organic livestock. Does an organic producer now "keep records" of every blade of grass a ruminant consumes out on the range, or every insect a chicken eats on pasture? We have to stop deluding ourselves concerning just how much control we have over our little "islands of organic production".

The real estate boundaries of our organic farms are simply not immutable. If a calf breaks out of my pasture during the night and grazes on a neighbor's non-organic field, and then crawls back into my organic pasture to nurse---and I know that one escaped during the night because the fence is torn, but I don't know which one---is my whole herd decertified? (or, more importantly, do I have to tag the calf as conventional just because it broke out even when I CAN identify it?) Does any certifier really demand that? When I move my cows from one pasture to another and they graze some of grass from the ditch along the way, are they disqualified from organic certification because they did not eat 100% organic feed?

The point here is that real organic farms are not under as much control as you imply. We don't control nature and we don't control our farms because they are PART OF NATURE. In his novel, Jurasic Park, Michael Crighton said it well---"Life always escapes, Life always finds a way." That is true on our organic farms as well as wild systems.

So back to certifying wild areas. If there are areas---watersheds, ecosystems, or other bounded areas we can identify---that are largely self-regulated by the natural systems that evolved there, and if such areas are largely uncontaminated by human disruptions, why can't the production from such areas be certified? If they meet all the SYSTEMS requirements of organic farms, by what logic or ethics do we exclude such areas? Isn't doing so just another form of market "protectionism?"

As I said in my paper, there probably aren't many areas left on the planet that qualify, but if there are, or if they are restored, how can we rule them out?

Finally, surely you cannot seriously propose that my paper suggests that "organic be everything for everybody." I think I made it very clear that the requirements for certifying wild areas as organic would be very involved, time consuming and difficult; and that there will be very few places that qualify. How can you equate this process with all the "wild" fish in the Tokyo Fish Market? Just because an animal is captured in the wild does not qualify it as organic. It can only be certified organic if it lives inside a certified organic area, the certification of which has to meet the same stringent requirements (crafted to conform to the additional nuances of wild systems) of the areas we call organic farms.

It is true that "organic is an agricultural production claim." But as Sir Albert Howard understood all too well, nature also "farms", and in his view, at least, did a much better job of it than most of us. So where nature is allowed to "farm" on her own (and this is the model we are trying to emulate on our organic farms) by what prejudice do we deny her the organic label but claim it for ourselves?

One final word about "control." Rachel Carson wrote that "The control of nature is a phrase conceived in arrogance, born of the Neanderthal age of biology and philosophy, when it was supposed that nature exists for the convenience of man." (Silent Spring). Doesn't the same apply when we assume that we have that part of nature called our organic farms under control and precisely audited?

There seems to me to be a similar arrogance here that likewise cannot be defended and that leads us to similar mischief. Besides, I believe it is fundamentally dishonest for us to claim to consumers that our organic farms are fully controlled, guaranteed not to have any unacceptable materials on them or that animals on them never escape. In the last analysis organic farms are "open areas" much like the naturally bounded areas in the wild. "Life always escapes." To believe otherwise is to be deluded and to claim otherwise is dishonest.

I believe this is why the OFPA wisely required regular testing (as it would in wild production) as a check. [A requirement that most of the organic industry (including certifiers) is still resisting] . Be that as it may, to claim that we are insuring "islands of purity" inside a contaminated ecosystem with our organic farms is clearly not a defensible proposition.