Keep the Central OR Protected District in Place: Submit Comments to ODA

What is going on?

The ODA has released a draft proposal to dissolve the rules surrounding the Central Oregon Protected District (COPD). This is one of 3 protected districts in the state, and all protect specialty brassica seed production by placing additional growing limitations on canola/rapeseed production. There are no limits or additional restrictions on canola production anywhere else in the state. You have heard a lot from us about the Willamette Valley Protected District and we have similar concerns for this area, and for the implications of this sudden movement by the department on the rest of the protected districts.

The ODA is claiming that they need to do away with these rules because of a community request, and because they do not have the authority to regulate cross contamination concerns, only pest and disease prevention. We know that this is not true from the establishment of the protected districts and rules in place protecting certain grass seed varieties from cross contamination. Oregon Administrative Rule 603-052-0860, Brassicaceae Production Districts and Rapeseed Control areas, draws authority from ORS 570.405 (ODA may establish control areas and 570.450 Rapeseed control areas), which includes disease, pests, and other conditions that may constitute a menace. Cross contamination can be considered a menace. Indeed, four other production areas in Oregon (603-052-1030, 603-052-1040, 603-052-1050, 603-052-1060) also have regulations drawing authority from ORS 570.405 that specifically state that they are designated control areas because production of a crop “would set a potential threat of contamination to currently established grass seed production in the area.”

We also know that the community is in no way unified on this topic. When a FoFF representative attended the most recent meeting in Madras, they reported that the farmers in attendance did not want protections to cease, many outright opposed the dissolution of the district, and many others requested more time and a locally-appropriate process to bring people together to find a fitting solution. Although one or two farmers who wish to grow more canola may oppose the district’s existence, the community does not want it dissolved.

Is this related to the Willamette Valley Protected District?

Many of FoFF’s supporters may only be familiar with the concerns of the brassica seed producers in the Willamette Valley through our decades of work on the WVPD. Although these protected districts are in different parts of the state and have different industry conditions, the policy surrounding them is inextricably linked. What happens with this district will inform the ongoing statewide discussion on brassica seed protections. We urge the Department of Agriculture to pause all efforts on changing individual district rules until we can conclude the statewide conversation started in the working groups last summer. Action now would undo all the good faith efforts put forward and would bring us farther from a united solution.

Also there are many lessons we can learn from the COPD. The main seed crop in the COPD is carrots (which is not a brassica). Carrot seed cannot be grown in the valley because of the proliferation of the wild weedy plant Queen Anne’s Lace (QAL). We can learn from this how quickly wild stock from the native QAL has become a problem for the genetics of carrot seed and has pushed the industry out of the Willamette Valley as a result. This is the same threat that canola poses to brassica seed crops. Because canola can interbreed with native brassica plants present in the valley, its potential to become a weed is clear and will force out brassica producers in a matter of seasons if left unregulated. More info on the harms of canola and documentation of scientific studies showing this can be found in this fact sheet.

We have also heard concerns about pesticide use in canola production being incompatible with the need for pollinators in the carrot seed life cycle. Because canola is both fall planted (over winter) crop and a spring planted crop, and that it is usually grown in large acreages of monoculture with heavy reliance on chemical pesticides, that means that the spraying of canola poses a threat to the pollinators needed to produce viable seed crops for the carrot seed farmers. The life cycles of the plants coincide such that the growth stage where chemical pesticide application is appropriate in conventional systems for spring planted canola is the same window of time when pollination is so crucial for carrot seed farmers. Massive pesticide use during this period will reduce pollinator populations and endanger the seed yields for carrot seed farmers. Carrot seed farmers have raised these concerns in public meetings and ODA has chosen not to respect their concerns.

The dissolution of this district will have tangible, negative impacts on seed growers in Central Oregon, does not have community support, and sets a dangerous precedent in the midst of a productive statewide conversation. ODA should halt this action and let the legislature direct policy on this issue.


Comment period open until June 28

We are asking all Deschutes, Crook, and Jefferson County residents, and seed producers from across the state to submit comments to ODA asking them to halt this effort and abandon their attempt to dissolve the COPD. In order to submit comments you need to email your letter (word doc, PDF, or email body) to​​ by 5:00pm on June 28, 2024.

Talking points:

  • At both COPD community meetings, the issue of cross contamination was raised and the agency said that they can’t do anything about cross contamination. However, that doesn’t mean that the issue should be ignored. And the same statute that the agency derives authority from for the protected district is used to mitigate cross contamination conflicts in the grass seed industry. 
  • There is not consensus in the COPD about repealing the COPD. Some seed growers are open to allowing some canola with safeguards in place, but not a full-scale repeal of the COPD. 
  • Carrot seed production is an important industry and seed growers are concerned that spring-planted canola will impact seed production via loss of pollinator activity. 
  • If the agency believes that their only approaches are no rule or the current rule, absent legislative action, they should press pause before setting new policy to prevent impacts on the other three protected districts in Oregon, which are home to critical seed production. 
  • We also need vegetable seeds in the future, not just canola.

Comment Template:

Dear Sunny Summers and ODA:

My name is NAME and I live in NAME OF COMMUNITY AND WHETHER IT IS IN THE COPD. I am connected to specialty seed production as “A SEED FARMER, A FARMER WHO USES OREGON GROWN VEG SEED, A HOME GARDENER USING OREGON GROWN VEG SEED, A CONSUMER OF VEGETABLES GROWN FROM SPECIALTY SEED” I urge you to abandon this attempt to dissolve the Central Oregon Protected District and pause all rulemaking related to Brassica Protected Districts until the statewide conversation can be concluded.

It is not responsible to change the landscape when so many advocates, lawmakers, and the governor’s office are working to find a solution to this crucial issue. We need to take thoughtful steps to protect the specialty seed industry and preserve our ability to grow seeds to produce food here in Oregon. The community of the COPD has told you this is not the answer at the community meetings, representatives of the specialty seed industry have asked you to stop this action, and proceeding with this proposal would have disastrous effects on the current conversation. The COPD also protects Central Oregon Seed growers of all types by preventing the damage of pollinator populations crucial to carrot seed production and by limiting canola to prevent cross pollination with seed crops and native weeds. 

[Add personal context about why this issue is important to your farm]

Now is not the time for unilateral decisions. Do not repeal the Central Oregon Protected District.


Thank you,




Public Hearing 6/26/24 at 9:00am

There is also a public hearing from 9:00 to 10:30 on Wednesday June 26. You can make comments at the public meeting verbally as well.

MEETING URL: Click here to join the meeting


Meeting ID: 263 025 637 589

Passcode: ajVodi

Dial-in by phone: +1 503-446-4951,,557326254#​