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source_pdf: oregon-prosperity-council-report-june-2026.pdf
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page_range: [313, 320]
breadcrumb: ["Appendix E: Submissions & Feedback", "33. Oregon Association of Nurseries"]
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  pdf: "https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=313"
  raw_pages:
    - "../../.extracted/pages/page-0313.txt"
    - "../../.extracted/pages/page-0314.txt"
    - "../../.extracted/pages/page-0315.txt"
    - "../../.extracted/pages/page-0316.txt"
    - "../../.extracted/pages/page-0317.txt"
    - "../../.extracted/pages/page-0318.txt"
    - "../../.extracted/pages/page-0319.txt"
    - "../../.extracted/pages/page-0320.txt"
---

# 33. Oregon Association of Nurseries

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

The Oregon Association of Nurseries (representing a $1.3 billion industry, 74% exported) submitted recommendations to improve state competitiveness: align agricultural labor/overtime standards with neighboring states, comprehensively review Oregon's tax code, eliminate CAT on green goods, reform SB 1507's federal tax disconnect, invest in workforce development through higher education and fully funded high school CTE, support small agricultural businesses through land-use policy, replace Oregon's Climate Protection Program with a market-based alternative, and modernize the Recycling Modernization Act.

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

- Nursery and greenhouse industry valued at $1.3 billion annually with 74% of sales exported outside Oregon ([p. 313](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=313))
- OAN proposes freezing agricultural overtime at 48 hours with 56-hour threshold for 12-week peak season ([p. 314](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=314))
- OAN recommends state collaboration with agricultural operations on temporary worker programs (H2A/H2B) ([p. 314](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=314))
- Oregon ranked 28th in CNBC's states for business with "F" rating for business-friendliness ([p. 315](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=315))
- Oregon's effective business tax burden increased 33% (2019-2023); corporate tax ranks 49th nationally ([p. 315](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=315))
- Oregon ranked 45th in manufacturing growth (June 2023-2024) and lost 6,000 residents (2022-2023) ([p. 315](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=315))
- SB 1507 federal tax disconnect problematic for small business depreciation; OAN recommends reconsidering accelerated depreciation ([p. 316](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=316))
- OAN recommends eliminating Commercial Activities Tax (CAT) on green goods and retooling Business Oregon ([p. 316](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=316))
- OAN advocates state investment in Oregon State University, community colleges, and fully funded high school CTE programs ([p. 316](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=316))
- OAN opposes current Recycling Modernization Act/EPR as costly and inconsistent; developing alternative model policy nationally ([p. 317](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=317))

Amounts: $1.3 billion · 74% · 28th · F · 45th · 6,000 residents · 33% · 49th · Dates/FTE: May 7, 2026 · 2024 · June 2023 to June 2024 · 2019 · Programs: SB 1507 · Agricultural overtime law · Manufacturing overtime laws · Commercial Activities Tax · CAT · H2A · Parties: Oregon Association of Nurseries · Governor Kotek · Oregon Business & Industry · CNBC

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> **Source:** PDF [pp. 313-320](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=313) · raw: [313](../../.extracted/pages/page-0313.txt) · [314](../../.extracted/pages/page-0314.txt) · [315](../../.extracted/pages/page-0315.txt) · [316](../../.extracted/pages/page-0316.txt) · [317](../../.extracted/pages/page-0317.txt) · [318](../../.extracted/pages/page-0318.txt) · [319](../../.extracted/pages/page-0319.txt) · [320](../../.extracted/pages/page-0320.txt)

Breadcrumb: Appendix E: Submissions & Feedback > 33. Oregon Association of Nurseries

---
May 7, 2026
To: Members of Governor Kotek’s Prosperity Council
From: The Oregon Association of Nurseries
Subject: Recommendations
The Nursery and Greenhouse industry is the largest sector of agriculture which
produces and ships environmentally beneficial green goods
and competes on a national and international level.
Background: The nursery and greenhouse industry is Oregon's leading agricultural
commodity, valued at over $1.3 billion annually. Critically, we are a traded sector: 74% of
our sales flow to customers outside Oregon, making this commodity essential to the state's
trade profile and economic resilience. Nursery association members represent wholesale
plant growers, Christmas tree growers, retailers, and greenhouse operators. Our members
are located throughout the state, with our largest nursery growing operations found in
Clackamas, Marion, Washington, Yamhill, and Multnomah Counties.
It is our distinct pleasure and responsibility to provide measurable and impactful
recommendations to the Prosperity Council. The OAN has followed closely the progress
and dedication that the council has as its mission to change the very course of the Oregon
economy. For that work, we laud you and your efforts.
In an effort to be concise, the association would like to provide some top line
recommendations – of which we are more than happy to provide detail as the council
would desire.
29751 SW TOWN CENTER LOOP, WEST, WILSONVILLE, OR 97070
1

Oregon is at a crossroads and the key takeaway from our comments is that unless a change
occurs in Oregon’s business climate through a number of policy choices, the state will not
achieve a predictable, manageable and competitive ability.
We are grateful for your time and attention to our comments below.
Oregon must align our labor standards, and overtime rules
with our neighboring states, or competitive states.
➢ The implementation of the Agricultural overtime law is having a negative effect
industry wide. Growers compete on a national level with states at the federal
minimum wage, further hampering market growth.
➢ Colorado recently changed its agricultural overtime law to recognize that the
industry has peak seasons that are driven by weather, product type, and labor
costs. Colorado changed its peak season to 56 hours a week.
➢ California, who phased in its Ag OT law (much like Oregon) is finding that workers
are making less with reductions of hours to the 40 hour threshold and productivity
of growers has been reduced.
➢ The OAN recognizes that a number of factors go into remaining competitive –
including regulatory costs, transportation costs to get product to market, and
labor.
➢ OAN is part of an agricultural coalition that recommends freezing agricultural
overtime to a 48 hour threshold and allow a 12-week 56 hour OT threshold for peak
season labor needs. This solution would go a long way to stabilizing employee
hours Oregon’s growing loss of market and competiveness.
➢ The Prosperity Council should also review and examine the total compensation
costs to Oregon agriculture by recognizing state mandated policies – minimum
wage, paid family leave, regulatory costs, etc.) to reconcile the true cost per hour
of an employee and compare it to other states.
➢ Ultimately the OAN supports OBI’s recommendation on overtime: Repeal
agricultural and manufacturing overtime laws, which place artificial constraints on
workers’ earning capacity and employers’ ability to meet production demand
fluctuations, particularly those tied to harvesting crops or other seasonally specific
demands
➢ The OAN recommends that the council work reduce barriers by state agencies and
collaborate with agricultural operations and their efforts applying for temporary
workers (H2A and H2B) to assist in an ever-increasing worker shortage in Oregon.
29751 SW TOWN CENTER LOOP, WEST, WILSONVILLE, OR 97070
2

➢ A wholesale review and consultation with agriculture on OSHA heat rules, worker
protection standards, and farm housing rules.
A Comprehensive view of Oregon’s tax code is needed
There has been substantial work done by Oregon Business & Industry on the subject of
Oregon’s competitiveness and need to do a comprehensive review of the state’s tax code.
OAN would point out a few comments found in the OBI Competitiveness Agenda and
provide links to the source material in their competitiveness scorecard.
➢ Oregon in 2024 slipped seven places, to 28th, in CNBC’s annual America’s Top
States for Business ranking. CNBC gave Oregon an “F” for business-friendliness,
with only New York and New Jersey faring worse.
➢ From June 2023 to June 2024, Oregon ranked only 45th nationally in manufacturing
growth, according to OBI’s 2024 report on the condition of Oregon’s manufacturing
sector.
➢ Oregon’s effective state business tax burden soared 33% between 2019 and 2023,
according to a 2024 report conducted for OBI by consulting firm EY. Oregon’s
corporate tax ranking, at 49th, now tops only Delaware’s in the nonpartisan Tax
Foundation’s 2025 State Tax Competitiveness Index.
➢ Oregon lost 6,000 residents between 2022 and 2023, according to a report released
recently by the Common Sense Institute Oregon. This trend exacerbates the
workforce challenges facing existing businesses and discourages further
investment here.
Resources:
OBI Competitiveness Report - OBI Releases Oregon Competitiveness Agenda - Oregon
Business & Industry
OBI Prosperity Council Memo - OBI-Prosperity-Council-Recommendations-4.2.2026.pdf
OBI Scorecard - The Oregon Scorecard - Oregon Business & Industry
Small Business is agriculture, and it needs support
Oregon agriculture’s profile is that of small businesses, family farms, and generational
commitment to growing and shipping quality green goods throughout the country and
internationally.
29751 SW TOWN CENTER LOOP, WEST, WILSONVILLE, OR 97070
3

➢ Senate bill 1507 disconnecting from the federal tax code has been problematic both
in terms of cost classified small business shares and accelerated depreciation.
Especially for assets in Oregon, another look at accelerated depreciation might help
businesses invest in things like agricultural equipment.
➢ Elimination of the Commercial Activities Tax on green goods would go a long way in
reducing supply chain costs.
➢ While common sense land use is needed in Oregon, we urge caution to recognize
that agricultural lands are essential businesses without walls. Long-term structural
planning needs to be advanced that simultaneously protects Oregon’s natural
working lands while also providing stable growth for housing and economic
development. There is a model with an OAN led Urban-Rural Reserves passed by
the Oregon legislature over a decade ago. This bill was never intended to be “the
answer” but a model policy for the state to update its land use planning.
➢ Business Oregon needs to be retooled and given an updated mission to evaluate
Oregon’s tax code, economic development support for Oregon’s small business
community. Reform needs to be meaningful and work toward achievable targets.
The solution is not just one thing, rather many small improvements that – when
coordinated – render big results.
Building blocks for a future workforce:
Investment and connection to 4-year and community colleges and funding for CTE
➢ A core conduit to success in agriculture is the investment in our land grant
university (Oregon State University) and our community colleges. The OAN has built
bridges with these institutions to create a pipeline of a workforce, increased
research to resolve emerging issues facing the industry, and to grow awareness of
the very connection between our institutions of higher learning and business.
➢ Partnerships to build training programs and education requires a quantum leap of
support by the state.
➢ A critical building block, before higher education, is getting kids engaged in
agriculture at the High School level. It is the first step to building our workforce and
fully funded CTE programs by the state is an appropriate step.
Oregon is missing the mark on climate
➢ OAN joins OBI in its desire to replace Oregon’s unique Climate Protection Program
with a market-based program that allows for legislative oversight and linkage with
other states, invests related revenue in prioritized state policies related to GHG
29751 SW TOWN CENTER LOOP, WEST, WILSONVILLE, OR 97070
4

reduction (e.g., wildfire mitigation, transportation congestion relief, industrial
equipment upgrades) and avoids duplicative or overlapping regulation of GHGs.
➢ OAN has been a long-standing critic of Oregon’s Recycling Modernization Act.
While examination of how to properly take plastic out of the waste stream is good
policy, the manner in which EPR has been implemented is not only costly, but
inconsistent with how other states are regulated. This law needs to be modernized
to ensure it is constitutional, fair and transparent to regulated entities and
consumers; to align costs with outcomes; and to align systems and costs with other
programs. The OAN is leading a national conversation with the nursery and
greenhouse industry and is working to develop a model policy. We view the council
as a partner on this issue and will advise on our progress.
➢ Green goods, produced by the nursery and greenhouse industry, sequester carbon
and have been selectively held out of balanced climate policy and how agriculture
can mitigate climate change. There is emerging science on quantifying the benefits
of green goods and recognition, research and investment in this area is encouraged.
As the largest sector of agriculture, a true traded sector commodity that brings over a
billion dollars back to state each year, the Prosperity Council has an opportunity to make a
difference on the future of our economy. Agriculture is the backbone of our state, and it is
hurting. We cannot urge you enough to support the family farm. The above
recommendations would go a long way towards bolstering the continued success of this
economic driver and ensuring that family farms thrive for many generations to come.
29751 SW TOWN CENTER LOOP, WEST, WILSONVILLE, OR 97070
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Parent: [Appendix E: Submissions & Feedback](./INDEX.md) · PDF: [pp. 313-320](https://www.oregon.gov/gov/Documents/Oregon%20Prosperity%20Council%20Report_June%202026.pdf#page=313)
