We're Hoppin Mad. Are You Hoppin Mad.

Federal Register
Vol. 72, No. 93
Tuesday, May 15, 2007

From Chris O’Brien’s Beer Activist blog
(subtitled “drink beer, save the world”)
RE: Docket No. AMS-TM-07-0032; TM-07-05
March 16, 2007
To the Review Board,
Please let this letter serve as a registration AGAINST the petitioned addition of Hops to the National List (Section 205.606)
To summarize:
•    Organic beer should not be classified as “organic” without the use of certified organic hops
•    Adding hops to the National List (Section 205.606) would irreparably damage the reputation and credibility and integrity of the organic brewing industry
•    Adding hops to the National List (Section 205.606) would diminish consumer confidence in the organic certification model
•    Adding hops to the National List (Section 205.606) would dismantle the organic hop farming industry in the United States, making organic U.S. brewers completely reliant upon imported organic hops
•    Organic hop varieties are currently available to brewers of all scales but not at the prices that producers and brokers would prefer. For example, As of May 21, 2007- the day of this submission Freshops had inventory of 5 varieties of organic hops and the ability to source 3 other varieties.
•    Organic hops are available in multiple varieties sufficient for production of 90% of beer currently made in the United States
•    Quality of organic hops is variable as in every other agricultural product and susceptible to fluctuations in price and availability as are organic malted barley and organic wheat, the primary non-water ingredients in organic beer
•    Hops generally constitute less than 5% of a beer’s total volume but account for at least 50% of the flavor profile- beer is not beer without hops and organic beer is not organic beer without organic hops
•    Adding hops to the National List (section 205.606) would make the U.S. organic breweries uncompetitive in the international beer marketplace as overseas brewers continue to develop new styles of award winning and highly successful organic beer including but not limited to Coopers (Australia) and Samuel Smith (U.K.)
•    Adding hops to the National List offers an unfair competitive advantage to macro-breweries, specifically, Anheuser Busch. As the oldest continuously bottled and first certified organic beer to be bottled in the United States, Lakefront Brewery has been able to source and brew with certified organic hops for the entire production run since its first batch of Lakefront Organic ESB 12 years ago. Our commitment to the organic industry and organic farming is strong and genuine and we consider Anheuser Busch’s (among others) lobbying attempts to add hops to the National List a threat to organic certification at best and intentionally misleading to consumers at worst. To change the rules midstream to suit the shortsighted demands of a single, powerful entity can only damage the credibility of the Program.
In response to the items submitted on behalf of other breweries, we respectfully and strongly disagree with the conclusions reached in questions 1, 2, 4, 5a and 5e of Category 4 of the NOSB Evaluation Criteria for Substances added to the National List. (section 205.606).
Regarding Questions 1 and 2:
Although not all varieties of hops are currently grown organically, many styles and types of beer can be brewed with organic hops that are commercially available. Most of the organic hops available are for lager beers which means that over 90% of the beer consumed in the United States can be made from the styles of organic hops that are available.
Craft brewers typically make specific styles of beer that may require a specific variety of hop. Although not every variety of hop is available organically yet, it would be unreasonable to propose that all varieties of the dozens of varieties of hops must be grown before they can be called organic. Organic brewers are experiencing increased demand for their product and there will be a much greater incentive for organic growers to grow more organic barley and hops in the United States, which will not only help the U.S. agricultural industry, but also help to reduce the amount of oil consumed in transportation of organic hops from other countries.
100% organic beer offers not just the environmentally conscious consumer a better alternative, but also provides many benefits beyond including:
•    fewer harmful substances introduced into the environment and food system
•    producing beer with organic hops and grains supports a domestic farm system and enhances soil fertility
•    growing organic hops will increase species diversity and sustainability
•    conserves water and produces fewer greenhouse gases
•    increases choices and options of different varieties and styles of beer for consumers
•    strengthens the U.S. organic agricultural industry, making organic U.S. farmers competitive with organic hop farmers in New Zealand and Germany and conventional hop growers in China
•    better tasting beer, truer to the recipes and styles of beer developed centuries before inorganic farming
Regarding Questions 4 and 5a:
Currently, most of the hops in the United States are grown in the Pacific Northwest. However, there are many areas of the country that have successfully grown hops in the past such as Wisconsin and New York. If organic hops are grown and have historically been grown in these disparate regions, clearly any plagues by pests or fungal diseases will not affect the crop in the Pacific Northwest or vice versa. Historically, hops for brewing have been cultivated in New England since the early 1600’s and in the Midwest since the 1800’s.
Wisconsin’s Sauk County alone produced over 1.2 million pounds of hops between the years of 1867 and 1869, all without the “benefit” of modern pesticides and inorganic fertilizers.* (Jerrold F. Hilton, Hops: The Essence of Beer 1994)
As far as the difficulty of producing hops organically versus conventional methods due to pests and disease, there are established organic methods of dealing with those problems specifically geared toward hop production. The ATTRA National Sustainable Agriculture Information Service is one of many resources, references and publications for organic hop growers. There is hardly a crop grown in the United States that is not susceptible to insect or fungal diseases. The organic farmer has always found a way to deal with these problems and grow their crops successfully.
It is factually and historically incorrect to imply that hops traveling long distances are easily contaminated. Hops grown in Europe, New Zealand and China are constantly shipped to brewers in the United States without any contamination problems. Our brewery has used hops from New Zealand for a dozen years and they have never experienced any contamination problems.
At this time, we are working with the Michael Fields Agricultural Institute of Wisconsin as well as other organic farmers in Wisconsin to redevelop organic hop cultivation in the upper Midwest. The Michael Fields Institute is devoted to developing agricultural techniques to sustain the land and its resources and to cultivate the ecological, social, economic and spiritual vitality of food and farming systems through education, research, policy and market development. Successful organic hop production in other countries, including Germany and England is done on small, high yield intensive plots among multiple, independent farmers and the model being put forth by large macro-breweries is mainly geared toward a commercial, large scale style of production owned by a single individual or commercial entity not necessarily suited to organic style production in the first place.
The market and model for organic cultivation of hops exists.  Why destroy it? Breweries producing genuine organic beers should be doubling their efforts to developing organic hop resources before they try to change the rules to suit their shortsighted and narrow view of what constitutes organic production.
Regarding Question 5e:
Concerning the comment about “regulatory challenges,” we do not know of an industry in the United States that does not have “regulatory challenges.” The report submitted by Peak Brewing Co. does not state what these challenges are, and we would have to assume that these are just normal business challenges and should not play a part in this report.
We were certified organic in May of 1996 and since that time, we have used 100% organic hops in all of our organic beers and barleywine. If we can do it, we think Anheuser Busch, the world’s largest beer producer with virtually unlimited resources should be able to follow our example. Our experience in the industry supports this belief and our business confirms that the addition would irreparably harm the hard-earned credibility of the standard and diminish the trust that consumers have in the USDA Organic seal. We feel that the inclusion of hops as a category of “non-organically produced agricultural products allowed as ingredients in products labeled organic” is a cynical and short-sighted mistake and would set the organic industry and standards back instead of advancing them.
In summary, as the oldest United States brewery to bottle a certified organic beer and the first to bottle a certified organic beer under its own label, Lakefront Brewery, Inc. does not support the proposal to add hops to the National List (Section 205.606) and believes that it would be harmful to the many industries supported and sustained by organic beer in the United States.
Please contact us with any questions or additional information.
Russell J. Klisch, President
Lakefront Brewery, Inc.
Milwaukee, WI