Frank Morton is a plant breeder and founder of Wild Garden Seed in Oregon.

Below is Frank Morton's testimony to ODA regarding canola. 

Regarding the Introduction of Canola to the Willamette Valley
Testimony of Frank Morton/Wild Garden Seed, November 29, 2018

My name is Frank Morton, I reside at 25235 Aurora Lane, Philomath, OR 97370

My wife Karen and I started our specialty organic seed company 25 years ago. We had no idea at the time that we were fortunate enough to have done so in one of the world’s finest seed growing regions, with the climate and natural resources to produce the highest quality seeds of a large number of vegetables, herbs, and flowers. It wasn’t until we became members of the Willamette Valley Specialty Seed Association that I really grasped Oregon’s place in the world as a first-class place to grow the most valuable of all agricultural crops—pure seed for planting.

The rapeseed control districts created to buffer inherent conflicts between oilseed growers and specialty seed growers has worked well for their purpose for more than three decades, during which time Oregon has developed a reputation for the quality, purity, and reliability of its seed production. Along the border with Idaho, restriction of rapeseed production in Oregon protects specialty seed producers inside Idaho. In central Oregon, rapeseed restrictions protect the region’s carrot seed producers from persistent oilseed volunteers in agricultural fields whose seeds cannot be separated from the carrot seed crop.

Now in the Willamette Valley there has been some change of heart regarding our specialty seed industry, apparently some loss of appreciation for how unique this valley is in the world, and a sense that we can allow some losses around the edges, and even take some risks to the heart of the Valley without having a negative effect on what is special about this place. There must now be an idea that we have enough room set aside already for specialty seeds, and we should be able to pack in a canola oil industry as well, with only a little compromise to what has kept this place so special in the world of quality seeds. This is a road paved with good intentions, perhaps, but it will lead to a world of conflict without end. We can see this already, 12 years into this ongoing conflict, that there will be no peace between those who have everything to lose in this coexistence, and those with nothing to lose.

This is the heart of the problem with coexistence between quality seed growers, and growers who crush oil from seed. All the incentive to prevent cross pollination, roadside dispersal, volunteers blooming in fields and fencerows, and fastidious control of pests and disease falls to the growers of seed for planting. There is no economic harm or harm to reputation for the oilseed grower to be cross pollinated or disease infected by neighboring crops or feral crops along the state right of way. Oilseed producers cannot be required to care about these things that are of critical importance to specialty seed growers—indeed, they cannot presently even be compelled to pin an isolation map provided by the WVSSA for the purpose of avoiding cross pollination. Unless the state creates legislation requiring that all brassica growers register and pin their locations on a public map, there is not a realistic scenario to prevent ongoing conflicts. ODA will need to create such a system just for the purpose of trying to foster coexistence between canola and specialty seed growers, something never done before, a pinning system that does not exist, requiring funding that isn’t likely to be forthcoming, for an industry with a farmgate value no one will brag about. Or, we can return to the protected district model that worked well for thirty-odd years, and still works in two Oregon rapeseed control districts.

Like many who have testified on this topic repeatedly over the years, I’m exhausted with repeating what has been said many times before. I nearly did not write this, nearly did not show up to testify, because I feel that the issue is now politicized, that a decision has already been made on some level beyond agricultural reasoning that oilseed canola will be grown in the Willamette Valley, no matter what, and that our special place in the world of quality seed is a part of Oregon’s history, not its future. This makes me very sad, not unlike a clear cut of old growth, seeing something pass away that can’t be returned in my lifetime. Those before us protected it, we are set to let it pass away. For cheap.

But, since I’m here, allow me to list my complaints:

I’m one of very few dedicated organic seed growers in the WVSSA membership. I supply organic growers on every scale directly through my catalog and website in the US, Canada, UK, Europe, Africa, Australia, New Zealand, and the Pacific Rim. I also supply seed catalog companies in many of these locations, especially catalogs that supply organic growers. Last year we sold seeds in 41 countries. Despite feeling somewhat significant in my worldly impact, I see that my farm is outside the arbitrary “blue line” that I sense must be where all the important seed producers are thought to live and prosper. I’m west of the Willamette, a mile south of Philomath, right beside one of the most significant organic produce farms in the state (Gathering Together Farm, with 65 acres of production). ODA might be forgiven for leaving us out of the protected area, since most organic farms are on marginal lands, and marginal lands are being given over to be the canola ghettos of the Oregon seed industry… but I’m a little surprised WVSSA wouldn’t have pointed me out, as I’m often cited by the organization as their organic token. So, let me be pointed and say that I think I’m as important as my friends at Universal Seed over yonder near Salem, and I think I deserve to have my priority pinning rights as respected as anyone who pays dues and pinning fees to WVSSA. But it looks like ODA intends to take this pinning priority that I’ve maintained for 12 years and do something different as regards pinning outside the blue box… but I have no idea what. I’m not feeling the safety of equal protection under the proposed changes. But I feel sleazy asking you to gerrymander your blue line just to include me, when I know there are other organic growers outside that blue line who don’t even know that seed crops might fit well in their production systems, and that they are in a world class seed growing region. The blue line not only threatens my future as a seedsman, it precludes many other futures that could have been. This is the tragedy of letting our specialty seed growing region erode around the edges. We won’t get that opportunity back to preserve what we now have.

The topic of herbicide resistant GE canola seems to be avoided whenever it comes up. Canola proponents cast the topic aside and insist they won’t be using GE canola. Why not? What will stop anyone from using GE canola? Not the law of the land. ODA states that is within their current authority to appoint advisory boards that can set the boundaries of control areas and “the type of rapeseed species and varieties which may be produced…” So, in theory these boards could prohibit GE varieties, but in reality, there’s no reason to expect that. When GE canola is allowed in the Willamette Valley, organic brassica seed will require genetic testing before it will be accepted by buyers. This is already the case for organic beets and swiss chard grown in the Valley, due to risks from GE sugar beet. When I have to add a $300 GMO test to my $200 pathology test (for Phoma and Xanthomonas), I will have a $500 cost added to every brassica seed lot I grow. My current catalog contains 37 varieties of brassica, so the impact will be significant.

The decision to reverse ODA policy re canola growing in the Valley grew out of the State’s poorly conceived renewable fuels policy. Part of the flawed implementation of this plan included encouraging and subsidizing the production of biofuel canola in the Willamette Valley, which included building a canola oil pressing facility at Rickreal. This investment in a canola pressing plant within a rapeseed control area would seem nonsensical, except the investors had some apparent belief that the control district would be abolished in short order. As we see this did not turn out to be the case, thanks to the commitment of the specialty seed industry to their homeland. But the crushing plant was built in any case, and ever sense, there has been an undercurrent of commitment from the state to see that plant put to use for canola growers. The plant itself keeps arising as something to be supplied with Willamette Valley canola. This is a perverse economic incentive, to somehow make the Valley pay for a poor investment, by undercutting a thriving industry (specialty seeds) with an industry that has been propped up by subsidies from its inception. The Willamette Valley will never be fueled by homegrown biodiesel, and so more recently canola proponents have hailed the plant as a food grade oil facility. Seems to me this poor investment has become a millstone around the State’s neck, and all this flailing about canola and specialty seeds is just an artifact of some grand plan gone askew…and it needs 50,000 acres of local canola to save face, for someone.

Undoing the Willamette Valley rapeseed control district has created new inequities under ODA rules. Currently seed growers in central Oregon enjoy the protection of their control district, and the specialty seed growers there aren’t suffering the conflicts created by the State’s illconceived decision to undo the WV control district. Along the border with Idaho, Idaho specialty seed growers are enjoying the protections afforded by Oregon’s eastern rapeseed control district. I understand that the State of Oregon provided this rapeseed control district at the request of Idaho’s seed industry, which was a considerate thing to do, more than 30 years ago. I’m not feeling equal protection under the rules, here.

A common justification for introduction of canola to the Willamette is the need for broadleaf rotation options for wheat and grass seed growers, something to break pest and disease cycles. There are a lot of options in this regard that wouldn’t threaten the specialty seed industry with disease, pest, and contamination issues. How about legumes as nitrogen fixing cover crops? Clover, vetch, sweetclover for example? These create value by fixing nitrogen that benefits subsequent cash crops, possibly creating more value than the $380/ acre that canola yields. Flax is a historic crop in the Valley, and while the infrastructure for linen production has disappeared, edible and industrial oilseed flax seem like alternatives. For the more entrepreneurial, oilseed poppies are another fall seeded broadleaf crop. The choice of canola as the rotational crop is fraught with conflicts, as we see. There is a good reason the rapeseed control districts were established in the first place, and we should reconsider the wisdom of undoing them.

Finally, basing future ODA decisions re canola in the WV on the OSU Coexistence Study is a selfblinding endeavor. The OSU study was intended to find a way toward coexistence between canola and specialty seed, not to determine the best ag policy for protecting the future of Willamette Valley agriculture. The study ignores the possibility that coexistence of oilseed and specialty seed brassica isn’t good policy. The experience of France and Denmark in this kind of coexistence was that the specialty seed industry faded away and those regions became commodity canola production zones. The OSU study did not really study or comment on these failed attempts at coexistence. The possibility that the Protected district policy is the best policy was given no attention. You don’t find what you don’t look for, so there is no possibility that the OSU study would have concluded that coexistence will always be fraught with conflict and gradual deterioration of the specialty seed sector. The only conclusion really drawn from the study is that large plantings of canola are no more threatening to specialty seeds than large scale plantings of radish or turnip, something I find easy to agree with. I suggest we curtail oversized, under-tended, plots of these commodity scale seed productions within the protected district, rather than opening up the protected district to another commodity brassica, which increases the threat to specialty seed production into the future, and Oregon’s future as a world class place to grow quality seed for planting.

Thank you for considering these comments.

Frank Morton