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page_range: [245, 253]
breadcrumb: ["Appendix E: Submissions & Feedback", "22. Tillamook County Creamery Association"]
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    - "../../.extracted/pages/page-0250.txt"
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---

# 22. Tillamook County Creamery Association

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## TL;DR  *(generated · confidence: high)*

Tillamook County Creamery Association, an Oregon dairy processor, submits that Oregon faces three critical regulatory barriers: (1) regulatory incoherence across agencies in eastern Oregon's integrated agricultural system; (2) agricultural overtime rules scheduled to drop from 48 hours (2025) to 40 hours (2027), which cap worker hours and increase biosecurity risk; and (3) the Recycling Modernization Act penalizing FDA-mandated food packaging. On workforce, Tillamook identifies a rural livability gap—childcare scarcity and high housing costs—not skills shortage. On economic tools, Oregon's incentives are passive tax-relief programs; the state cannot make real-time competitive custom offers like Illinois's Decatur experience demonstrated.

**Key points** *(each cites a PDF page)*:

- Tillamook's Boardman facility anchors an integrated eastern Oregon system (food processors, port, irrigated farmland) supporting thousands of jobs; regulatory coherence across agencies is critical to retention and investment. ([p. 245](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=245))
- Agricultural overtime threshold dropped to 48 hours in 2025 with path to 40 hours in 2027; TCCA recommends 55 hours per week as practical threshold where workers earn meaningful overtime without artificial hour-caps. ([p. 246](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=246))
- Recycling Modernization Act penalizes food packaging required by FDA food safety regulations; DEQ denied exemptions; TCCA recommends separate fee category, published methodology, and independent audit. ([p. 246](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=246))
- Tillamook County documented as "childcare desert" with fewer than 3 regulated childcare slots per child needing care; childcare workers among lowest-paid skilled professions; operating at structural loss without subsidy. ([p. 248](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=248))
- Prevailing wage policy unintended consequence: 72-unit rural workforce housing project triggered prevailing wage requirements by accepting state financing, adding $2 to $3 million in labor costs. ([p. 249](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=249))
- Yamhill County Project Oasis model: 100-slot childcare facility backed by corporate-sponsored employee slots and family scholarships serving families between public assistance eligibility thresholds. ([p. 250](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=250))
- Clatsop County grant program to prevent childcare closures achieved 17 percent increase in children served in first six months; county currently accommodates only 8 percent of infants and toddlers. ([p. 250](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=250))
- Cost competitiveness: it is cheaper for Tillamook to manufacture cheese elsewhere and ship to Oregon than produce domestically; cost stack includes agricultural overtime, carbon-policy energy costs, CAT on supplier invoices, and contracted milk supply. ([p. 251](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=251))
- Oregon's economic development tools are passive (rural enterprise zones, tax abatement, loan programs); state lacks ability to make proactive, custom offers when capital decisions are on the table. ([p. 251](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=251))
- Decatur, Illinois regional EDC model: custom incentive package, monthly calls for more than two years, property acquisition support, and ongoing engagement on plant optimization and master planning. ([p. 247](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=247))

Amounts: $2 to $3 million · 17 percent increase in children served · 8 percent · 100-slot · 72-unit · Dates/FTE: March 31, 2026 · 2025 · 2027 · 2-3 years · Programs: Recycling Modernization Act · EPR program · ecomodulation · Circular Action Alliance · Middle Income Revolving Loan Fund · Employment Related Day Care program · Parties: Tillamook County Creamery Association · Trevor Beltz · Oregon Prosperity Council · DEQ

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> **Source:** PDF [pp. 245-253](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=245) · raw: [245](../../.extracted/pages/page-0245.txt) · [246](../../.extracted/pages/page-0246.txt) · [247](../../.extracted/pages/page-0247.txt) · [248](../../.extracted/pages/page-0248.txt) · [249](../../.extracted/pages/page-0249.txt) · [250](../../.extracted/pages/page-0250.txt) · [251](../../.extracted/pages/page-0251.txt) · [252](../../.extracted/pages/page-0252.txt) · [253](../../.extracted/pages/page-0253.txt)

Breadcrumb: Appendix E: Submissions & Feedback > 22. Tillamook County Creamery Association

---
Oregon Prosperity Council – Input Submission
Tillamook County Creamery Association
Contact: Trevor Beltz, Manager of Gov. Rel. & Pub. Aff.
tbeltz@tillamook.com
March 31, 2026
Oregon Prosperity Council Survey Responses
Business Climate
1. What challenge would you like addressed? What is the biggest barrier or friction
point?
We have three concrete barriers with direct financial or operational consequences for
Tillamook and our farmer-owners.
Regulatory coherence and the eastern Oregon agricultural economy. Tillamook's Boardman
facility is part of an integrated regional system: food processors, port infrastructure, and
irrigated farmland that forms the economic backbone of eastern Oregon. Wastewater from
processing is treated and applied to farmland, and the port sustains itself through industrial
user fees. Thousands of jobs depend on these parts working together. We raise this not to
litigate any regulatory decision, but because the Council should understand what is at stake
when policies made in isolation by different agencies interact with a system this
interconnected. The governor has been clear that retaining businesses and supporting
agricultural investment are priorities, which we appreciate. We also think the Council is well-
positioned to ask whether the state's regulatory posture is aligned with that goal in practice,
not just in stated intent.
Farmworker overtime rules that harm the workers they are meant to protect. Oregon's
agricultural overtime law creates a counterproductive outcome. Farmers cap worker hours to
avoid overtime liability. Workers seeking more hours take them at multiple farms, increasing
biosecurity risk and reducing individual earnings. The law was written to protect workers. In
practice it limits their earning potential and introduces disease risk to dairy herds. Oregon
dropped to a 48-hour threshold in 2025, with a path to 40 hours in 2027. There have been no
winners.
The Recycling Modernization Act's treatment of federally mandated food packaging.
Tillamook is a registered participant in Oregon's EPR program and is paying fees in good

standing. Oregon's program includes ecomodulation, but the structure assumes producers
can redesign their packaging to earn credits. For food manufacturers whose packaging is
constrained by FDA food safety regulation, that assumption does not hold. DEQ has already
denied exemption requests for food-contact packaging, citing that federal regulation does
not preclude state compliance. We are not arguing that it does. We are arguing that
penalizing packaging decisions made in service of federal food safety requirements is a
design flaw the Legislature should correct. The fee methodology also remains confidential,
which is not a defensible way to run a public regulatory program.
2. What solution or specific change would you recommend?
On regulatory coherence: the Council should include an explicit call for cross-agency
alignment on economic development goals, particularly in regions where agricultural
economies are most exposed to cumulative regulatory impact. Oregon should be able to
articulate a coherent posture toward the businesses it says it wants to retain.
On farmworker overtime: raise the agricultural overtime threshold to 55 hours per week. Our
farmer-owners identify this as the practical point where workers earn meaningful overtime
without triggering artificial hour caps.
On the RMA: create a separate fee category for packaging required to meet FDA food safety
standards, with a lower base rate and phase-in timeline. Require the Circular Action Alliance
to publish its fee methodology and accept independent audit. Establish meaningful
ecomodulation credit for companies actively investing in sustainable alternatives, including
where those alternatives are not yet deployable at scale.
3. What would success look like in 2-3 years?
Oregon operates with a published cross-agency framework for economic development.
Regional economies are not left navigating conflicting agency mandates without recourse.
The agricultural overtime threshold is adjusted and farmworkers are earning more hours at
single operations. The RMA includes a transparent, auditable fee structure with a separate
category for food manufacturers with federally mandated packaging.
4. Who has to act?

The Governor's office, to direct cross-agency review of regulatory posture in agricultural
regions. The Legislature, to adjust the overtime threshold and reform RMA governance. DEQ
and ODA jointly, to develop a published framework on agricultural wastewater jurisdiction.
5. Which existing state programs do you want to see continue?
ODA is a strong and collaborative partner and we want to see that relationship and its
resources preserved. Oregon's food processor property tax exemption for qualified machinery
and equipment is a meaningful tool that directly benefits dairy processing operations and
should be maintained. Rural enterprise zones provide property tax relief that makes capital
investment in rural communities more viable; Oregon's rural enterprise zones are worth
protecting and expanding. These programs work. The gap is not in what exists but in what is
missing: a competitive, real-time investment incentive that lets Oregon show up when a
capital decision is actually on the table.
6. What promising models or best practices have you seen in other states?
When Tillamook began exploring operations in Decatur, Illinois, the regional economic
development corporation quickly became a trusted partner and led the effort with a clear
philosophy: they would find a way to solve any problem, and they were not going to lose this
opportunity. The incentive package they built was custom, designed around our specific
priorities rather than a standard offer. When our needs evolved after the initial package was
finalized, they modified it. They made sure we were aware of every available incentive at
every level of government and helped us navigate all of it. When we needed to create a
controlled campus around the facility, they used their local connections to help us acquire
surrounding properties, vacated city streets, fenced the perimeter, and razed existing
buildings to make it possible.
The team committed to monthly calls for more than two years, with a standing mission to
remove any obstacle that surfaced. That commitment was tested repeatedly, and they
delivered every time. Those calls continue today, having evolved into ongoing collaboration
on plant optimization, future capital projects, and master planning. The EDC director remains
our single point of contact for everything Decatur, and multiple functions within Tillamook
now engage with her directly. That is what it looks like when a state decides it wants to
compete for investment.
Workforce

1. What challenge would you like addressed? What is the biggest barrier or friction
point?
In rural Oregon the primary workforce challenge is a livability gap, not a skills gap. Tillamook
County is a documented childcare desert: there are fewer than three regulated childcare
slots available for every child who needs one. Housing is equally constrained. When we recruit
workers from outside the county, we are asking them to move somewhere they cannot find
housing or childcare. For families where both parents work, that is not a livable offer.
The problem runs deeper than access. Childcare is among the lowest-paid skilled
professions in the country. Finding qualified providers who can sustain a living wage in a rural,
high-cost community like Tillamook is its own challenge. Oregon's licensing and certification
requirements add cost and credential burden that further limits who enters the profession.
Rural childcare often operates at a structural loss indefinitely without subsidy. The market
alone will not solve this, and programs designed for the Portland metro do not address why a
skilled worker declines a job in Tillamook or Boardman.
Separately, we are seeing professional employees choose Vancouver, Washington over
Portland in response to Oregon's income tax burden, accumulated local taxes in Multnomah
County, and cost of living. Oregon is losing talent at both ends.
2. What solution or specific change would you recommend?
Treat rural childcare infrastructure as an economic development investment, not a social
services line item. Solving this in rural Oregon will not look the same as solving it in the
Willamette Valley. The state should support flexible, community-designed models rather than
imposing urban-scaled licensing frameworks on rural providers.
TCCA commissioned a county-wide childcare study and has been engaged in building a
plan alongside Adventist Health, Hampton Lumber, and Tillamook Bay Community College.
That work identified four interconnected needs: ongoing subsidies to cover the gap between
what state ERDC funding pays and what families can actually afford; scholarships for
vulnerable families not eligible for other public support; stability grants and business
coaching for existing licensed providers to keep them operating; and new program
development, including the microcenter model enabled by recent state legislation, which
reduces barriers to entry for new childcare entrepreneurs. Workforce development for

childcare workers themselves, including apprenticeship pathways, is also needed to grow the
pipeline of qualified providers willing to work in rural communities.
In an ideal world, childcare hours would also reflect the reality of manufacturing and frontline
worker schedules. Solutions that only work 8 to 5 do not serve our plant workforce, which
operates 24/7.
On housing: Oregon's prevailing wage law requires contractors to pay area-standard wages
on projects that receive public funding — a policy designed to ensure taxpayer dollars
support quality jobs. The intent is reasonable. The problem is that BOLI's interpretation of what
triggers the requirement has expanded well beyond clearly public projects. When private
developers apply for state financing programs to fill funding gaps, the act of accepting that
public money now triggers prevailing wage requirements for the entire project, including
portions funded entirely with private dollars. In Tillamook County, a 72-unit workforce housing
development applied for Middle Income Revolving Loan Fund support to help close a
financing gap. That application triggered prevailing wage requirements the developers did
not anticipate, adding $2 to $3 million in labor costs and creating a larger funding gap than
the one they were trying to solve. The tool meant to help make the project viable made it
harder to build. Oregon cannot solve its rural workforce housing shortage while a well-
intentioned wage policy functions as an unpredictable tax on the public financing programs
designed to spur that housing. Prevailing wage exemptions or alternative compliance
pathways for smaller residential projects in rural workforce shortage counties should be part
of this Council's recommendations.
3. What would success look like in 2-3 years?
Tillamook County has measurable licensed childcare capacity with hours that serve
manufacturing and frontline workers. Employers can recruit workers with children without
childcare being a disqualifying factor. At least one rural workforce housing project has been
completed. The state has adopted an employer-provided childcare tax credit that draws
private capital into rural childcare supply.
4. Who has to act?
The Legislature, on prevailing wage reform and employer childcare tax credits. The Governor's
office, to designate rural childcare as an economic development priority and direct Business
Oregon to fund it accordingly. Employers, including Tillamook: we are on county task forces,

have funded a planning study, and will stay engaged. The state should create the structure;
the private sector will meet it.
5. Which existing state programs do you want to see continue?
Oregon's Employment Related Day Care program provides the baseline childcare subsidy
that rural families depend on. The Oregon Shared Services Alliance for childcare, recently
extended to Tillamook, Clatsop, and Columbia counties, is a meaningful step toward
stabilizing existing providers through business coaching and shared administrative support.
Both programs should be preserved and expanded. That said, neither is sufficient on its own
to move Tillamook County from a childcare desert to functional capacity. The gap between
what these programs provide and what the community needs is precisely what we are
asking this Council to help address.
6. What promising models or best practices have you seen in other states?
The Yamhill County model is worth noting. A traded-sector manufacturer facing workforce
losses due to childcare shortages partnered with the regional EDC, local government, and
private funders to create Project Oasis — a 100-slot childcare facility backed by corporate-
sponsored employee slots and family scholarships that serve families who fall between
public assistance eligibility thresholds. The model was built around employer need, not a
government program framework.
In Clatsop County, a coalition led by county commissioners and local hospital systems
created a grant program to prevent childcare closures, increase slots, and expand family
financial assistance. In the first six months, the county saw a 17 percent increase in children
served. For context, Clatsop can currently accommodate only 8 percent of its infants and
toddlers — a situation directly comparable to Tillamook's.
We funded a 2023 county childcare study that pointed toward the same solutions: subsidies
to close the gap between what state assistance pays and what care actually costs,
scholarships for families who fall through eligibility cracks, stability grants for existing
providers, and new program development including the microcenter model.
The lesson across all three is consistent: the model works when the funding is there and falls
apart when it runs out. Both Yamhill and Clatsop are already chasing grants to replace
expiring dollars, which is exactly the problem. These examples demonstrate what is possible

when resources are behind them. The missing piece is not the model. It is the commitment to
sustain it.
Tools for Growth
1. What challenge would you like addressed? What is the biggest barrier or friction
point?
Oregon's economic development tools exist, but they are not built for competitive, real-time
investment decisions. The state has rural enterprise zones, property tax abatements, and loan
programs — instruments structured for after-the-fact tax relief rather than active deal-
making. What Oregon does not have is the ability to make a proactive, custom offer when a
capital decision is actually on the table and the conversation is moving at the speed of
business.
The cost of operating in Oregon is the underlying pressure. It costs Tillamook less to
manufacture cheese in another state, package it, and ship it back to Oregon than to make it
here. That is a supply chain reality, not a negotiating position. The cost stack that drives it is
specific: agricultural overtime rules that are among the most restrictive in the country and
scheduled to tighten further; energy costs rising as a result of state carbon policy; CAT costs
embedded in every supplier invoice even where Tillamook is exempt as a cooperative;
property taxes on business equipment; and a milk supply that has contracted significantly as
Oregon farms have closed under financial pressure. These costs compound, and they do so
against states that have none of them.
This matters not because Tillamook is leaving, but because our farmers are here, our workers
are here, and our heritage is here. The question is whether Oregon will be a place where the
dairy agricultural ecosystem can sustain and attract investment over the next generation.
Can suppliers site here? Can larger farms exist to supply us? Can the next generation of farm
families see a viable future in Oregon?
Oregon's land use system presents a separate constraint. The Exclusive Farm Use designation
applies uniformly regardless of actual productivity or proximity to infrastructure. Routine farm
maintenance — a culvert repair, a drainage project — requires sign-off from an alphabet of
state and federal agencies because the regulatory framework was not designed to
distinguish between irreplaceable farmland and marginal land. TCCA has a formal
commitment to no net loss of farmland in Tillamook County and we stand by it. But the

current system does not make that distinction, and that bluntness is costing rural
communities the flexibility they need to grow.
2. What solution or specific change would you recommend?
Oregon should develop a competitive rural investment incentive with the flexibility and
capitalization to function as a real deal-closing tool. Other states have demonstrated that
proactive, discretionary cash-based incentives — structured to move at the pace of a
business decision and customized to a company's specific priorities — are effective at
retaining and recruiting investment. Oregon's existing toolkit is built primarily around tax
abatement and loan programs. Those have value, but they are passive instruments. What is
missing is the ability to show up at the table with something competitive when the decision is
actually being made.
On land use: we support the creation of a task force to develop a tiered classification system
within the Exclusive Farm Use designation, distinguishing genuinely high-productivity land
that must be protected, marginal land that could support rural housing or processing
development, and land appropriate for conversion in exchange for conservation of higher-
value farmland. This is not a call to open Oregon's farmland. It is a call to apply protection
where it matters most and create flexibility where the current system is too blunt to serve
rural communities well.
3. What would success look like in 2-3 years?
Oregon has a competitive rural investment incentive and has used it to retain or attract at
least one significant food or agricultural processing operation that would otherwise have
gone elsewhere. The EFU tiered classification task force has produced recommendations the
Legislature has acted on. Routine farm permits for low-risk projects move through a single
coordinated process rather than requiring sign-off from multiple agencies.
4. Who has to act?
The Legislature and Governor's office, to create and capitalize a rural investment incentive. A
governor-appointed task force to conduct the EFU tiered classification review with
agricultural stakeholders at the table. Business Oregon, to reorient a portion of its rural
capacity toward agricultural and food processing sectors rather than concentrating on
technology recruitment.

5. Which existing state programs do you want to see continue?
Oregon's rural enterprise zones and property tax abatement programs provide meaningful
relief that makes capital investment in rural communities more viable. The food processor
property tax exemption for qualified machinery and equipment directly benefits dairy
processing operations and should be maintained. These programs are worth protecting. The
gap is not that Oregon lacks tools entirely. It is that the existing toolkit is not structured to
compete with states that deploy more active, flexible incentives when investment decisions
are on the table.
6. What promising models or best practices have you seen in other states?
See the Decatur, Illinois experience described under Business Climate. That experience
illustrates the contrast precisely. What made the difference was not the size of an incentive
check; it was the posture: a team with a mandate to compete for the investment, the
flexibility to build a custom solution around our priorities, and a commitment to stay engaged
long after the initial deal was done. Oregon has economic development tools. What the
Decatur experience revealed is the gap between having tools and having a posture. That is
what this Council should address.

---

Parent: [Appendix E: Submissions & Feedback](./INDEX.md) · PDF: [pp. 245-253](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=245)