Dear Council Members,

Sorry I didn't have time to write something shorter.

It's time for the county to quit misleading the public about this slaughter business.  It has become altogether too confusing and this ordinance probably cannot be fixed. Staff has literally made legislative sausage of this issue.

First, it was for "small-scale agricultural slaughterhouses."  No one knew what this meant as it was a made-up term unique to the ordinance.  We figured it was about slaughtering animals, not agriculture, though the net effect might be the same.  First they were this size, then that size, with no analysis of what is needed.  When the public became concerned about the notorious pollution from large scale poultry slaughter, poultry was eliminated.  Now it's back.

First there was no restriction on where animals originated, then a local quota was included.  Now it's gone again.  Animals may come from anywhere. Increasingly popular horse slaughter has not even been mentioned, nor have hogs, sheep and goats, to name a few.

When the public remained concerned about a district-wide amendment for widespread slaughter, the name was changed to "packinghouses."  Now both slaughterhouses and packinghouses are proposed, not only in AG but also in three other zoning districts.  The ordinance purports to limit the number of facilities, knowing this is nigh impossible, especially without prior environmental study.  Anticipating the limit will be found unconstitutional and struck down if challenged, it is clear the ordinance is intended to approve widespread slaughter.

The name change bit of smoke and mirrors was introduced by a planning commissioner with a personal stake in the feed and slaughter businesses.  He proffered a federal 'small-scale' packinghouse definition allowing up to 50 million live pound kill annually.  Despite the conflict of interest, it was readily adopted.  It's not the small-scale or quality consumers want and it's not about packing.  It's about wholesale, widespread slaughter.

It's time to come clean. All along, everyone has been saying this was about small-scale slaughter and premium local meat products. That's just not true. There's a reason folks want small-scale and premium product: they don't want the health, social and environmental risks of factory farms and large-scale slaughter. They don't want GMO feed, antibiotics, abusive treatment of animals or food-borne diseases associated with the industry.

The proposed ordinance is not about small-scale or local or premium product.  This ordinance is about grinding up roughly 15,000 dairy culls produced each year from Whatcom County's roughly 50,000 head dairy herd.  Aging cows raised on GMO feed are not what consumers are after in supporting slaughter for premium local product.  That's why consideration of standards known necessary to support premium brands has been steadfastly avoided. 

Whatcom also produces "hobby farm" animals. These may be non-GMO, grass fed and raised without regular antibiotics, treated well and good candidates to meet the ostensible purpose of the ordinance. But they are few in comparison, and it's not clear we can handle a lot more. Whatcom County waterways and aquifers are already ubiquitously over-polluted with nitrates. Nevertheless, no attempt has been made to quantify what effect a proliferation of widespread slaughter could have.

Fifty million live pound kill is about 40,000 head of cattle.  After the dairy grinders and hobby animals, each so-called small-scale packinghouse facility will still be needing 25,000 more animals to meet their annual limit.  That's just one packinghouse under the federal definition introduced by the commissioner.  Then there are the slaughterhouses now reintroduced to the ordinance.  Rezoning four complete county zoning districts for an unspecified number of water-intensive operations producing vast quantities of hazardous byproducts is not prudent.  Where will we get the animals?  Where will we get the water?  Where will we process the waste? The ordinance proposes slaughter can locate within 150 feet of homes and other businesses.  The county has given far more concern and consideration to locating marijuana businesses.  With slaughter, virtually all potential problems have been ignored:

- Ubiquitous nitrate pollution suggests we already have too many animals. 
- A single three to five thousand square foot slaughterhouse can easily accommodate Whatcom County's current production. 
- Many slaughter facilities are unnecessary, undesirable and problematic. 
- Slaughter can harm crops and property values. 
- Most locavore demand can be met more cost-effectively under existing custom processing regulations.
- Premium meats come from grass fed steer, not worn out dairy cows.
- Butcher and sausage shops make premium products, not slaughterhouses and packinghouses.

Skagit and Snohomish counties already have small shops producing premium local product. They don't slaughter anything. They make arrangements with high-standard producers, get quality animals to a USDA facility and bring back inspected wholes or halves to produce prime cuts and value added products.  Folks from Whatcom drive down to get it.  Packinghouses and slaughterhouses approved in four zoning districts will not accomplish this goal.  A proliferation of widespread slaughter will directly impede achieving quality goals because small operations will be consolidated by larger ones. This is a thirty year accelerating trend in the industry and precisely why we do not have access to reliable local slaughter services today.

A slaughterhouse is a good idea.  It would improve dairies' return on the disposal of their grinders.  It would help local butcher shops and sausage houses get quality local meat from quality animals raised according to high standards.  It would help prevent mobile slaughter workarounds from causing environmental harm. 

The ordinance's stated aims cannot be accomplished by more and more slaughterhouses.  Quality local product will be produced by small butcher and sausage shops working smartly to process quality animals either under custom regulations or with USDA meat inspected and slaughtered offsite.  The difficulty of running a private small-scale slaughter cannot be described better than by the story of Whatcom's sole remaining, struggling, USDA shop.

I hope it won't seem rude if I find it astounding that among the many citations referenced by staff in their study promoting widespread local slaughter, not one incorporates the public record of slaughter when prohibited from the AG zone in the 1990s.  I encourage council to review that record before taking action, lest history repeat itself - in spades. 

Slaughter is the first, prime example of an incompatible use that necessitated the invention of land-use regulation.  Long ago, authorities realized slaughter must be moved outside the city walls.  Immediately, they also concluded it should not be too far removed from regular inspection.  We don't have the resources to adequately monitor and regulate an unspecified number of facilities in multiple zoning districts.  Neither does anyone else in the over-compartmentalized and uncoordinated multi-jurisdictional regulatory framework. 

If there is a public need for reliable local slaughter and we know the market won't provide adequate service, then a more public utility approach should be taken.  Only one slaughter facility is needed, but better provisions for small-scale accessory butcher and specialty meat shops may be needed.  Local shops that can make the premium locavore products don't need to, and can't afford to, provide slaughter facilities.  Bottom line: It's too expensive.  Further, we don't want to encourage it.  The waste is too extreme and difficult to process.  Slaughter needs expensive high-end treatment and process control.  Expecting every small shop to invest and maintain these systems is unrealistic.

The ordinance is confusing because of too many changing terms, locations, procedures and specifications. The ordinance is disingenuous because it says small-scale, local and quality but is designed for large-scale slaughter of low-quality product.  The ordinance is dangerous because it opens a large part of the county to the industrial slaughter industry. It is doubly dangerous because, in the non-project GMA policy phase, it has systematically failed to adequately contemplate the potentially ballooning impacts likely to occur in the permitting and project phase.  We need a Total Maximum Daily Loading framework for understanding how many more animals we can afford to produce without causing environmental harm.  We cannot afford unplanned service extensions to address problems intentionally unforseen.

This ordinance is not what Whatcom County needs.  If it must be adopted, Agricultural and Light Industrial zones should be excluded.  But we don't need this ordinance. What we need is a consortium of producers, retailers and consumers to assess needs, study feasibility, set standards, find the best location for the optimally sized facility and round up enough public support that it doesn't immediately fail under a mountain of debt service and get consolidated by larger operations.  We need to encourage small-scale butcher and sausage shops, not slaughterhouses and packinghouses.  Widespread slaughter is not needed.  Quality local product is wanted.

Please do not approve this ordinance. Let's take a more rational approach.

Thank you,