OSA submitted comments this week to the Oregon Department of Agriculture in opposition to its proposed rule to expand canola production in the Willamette Valley, putting at risk the genetic integrity of commercial specialty crop seed projects, businesses, and on-farm breeding, including organic.
There a number of reasons we do not support the Oregon Department of Agriculture’s proposal. Canola exclusion zones were established as a result of community discussions and research, and ultimately honored known risks identified by community members who understood the potential impacts, including economic risks spanning the region and the broader international seed community.
Because the risks are well documented – canola easily cross-pollinates with crop relatives (opens PDF) – we believe it is inappropriate to allow these plantings.
The Willamette Valley is one of the most appropriate and valuable areas in the world for producing specialty seed, including brassicas. The national and international seed industries are invested in this region, and rely on the responsible management of plant genetics in seed production areas to ensure the integrity of their products. Farmers also rely on the genetic integrity of seed produced in this region to meet the demand of their customers, as well as their agronomic and regulatory needs, especially those certified under the National Organic Program.
We are particularly concerned about the following pieces of the proposal:
– The proposed new boundaries allow canola production where 16% of known specialty seed producers operate, and up to 1.7 million acres where specialty seed could potentially be grown.
– The proposed rule does not establish isolation zones to protect brassica seed operations in the area of the Willamette Valley that is opened to canola.
– The proposed rule requires all brassica growers, fresh market broccoli growers, as well as canola growers and specialty seed growers, to mark their plantings on a map. This map is owned and operated by a private organization, over which the ODA holds no authority. This is a voluntary system, and there are no consequences for canola and brassica growers who do not mark their plantings on the map.
– Brassica growers, including organic growers, must treat their seed with a fungicide. Such treatment is not permitted under the National Organic Program. This would make it impossible for certified growers in this protected area to raise organic brassica crops. Furthermore, this barrier limits the expansion of the organic seed sector, which is essential to the success of the broader organic food industry – now a $30 billion industry that experiences growth each year. Given the increased demand for organic seed (and current limitations in supply), seed production decisions cannot impair the growth and integrity of the organic seed trade. Our own analysis shows the urgent need to expand organic seed acreage and improvement, especially in specialty crop seed (see State of Organic Seed).
For all these reasons we strongly oppose the proposed permanent rule that would expand canola production in the Willamette Valley.