The Whatcom County Council is doing for pot what they should have done for slaughter.  Amazingly, they have the juice to minutely regulate the growing of plants, but insisted on a laissez faire approach to slaughterhouses.

Under new rules contemplated by the County Council, a marijuana business will have to be at least 300 feet from an existing home.  The council recently adopted rules allowing slaughterhouses as close as 150 feet from existing residences.  In areas with eight or more residences, marijuana businesses will have to be at least 1,000 feet away.  The setback for slaughterhouses remains 150 feet regardless of the number of homes.  Marijuana businesses will have to be at least 1,000 feet from community centers, religious institutions, schools and daycares.  Slaughterhouses can be 500 feet from a school, but the rules are silent on the distance from other facilities where people or youth congregate.

This may be as rational as zoning gets north of the Chuckanuts, whether due to parochial isolation or the waterfront's missing 500 tons of mercury no one will talk about.  We may never know, but it seems that our county's legislative body can distinguish between more or less suitable areas for a given activity or use.  That's a good sign, but one we didn't see when they forced through a blanket industrial upzone allowing an unlimited number of slaughterhouses anywhere on 88,000 acres of agricultural land.

Now, setbacks and environmental concerns are out the window.  The slaughter of poultry will soon occur any place you can park a truck, whether there are homes, schools, churches or day-cares.

Continuing to prove that the Herald is about a good story rather than information, Ralph Schwartz published a piece about mobile chicken slaughter based on a March 3rd press release from Sera Hartman at the Northwest Agriculture Business Center. 

The release promotes the coming arrival of a mobile slaughter facility this spring and offers, "Pastured poultry has long been recognized as a viable enterprise for diversified family farms…With the closing of the last remaining northwest Washington custom processor in October last year, local poultry businesses not already possessing their own processing facility are faced with either building a licensed facility and obtaining costly product liability insurance, or shutting down operations altogether."

Ralph, bless his soul, wrote me to ask, "Based on your research on the environmental impacts of slaughter facilities, what can you say about these mobile units? To your knowledge, do they pose a environmental/health problem or do they handle waste water, offal, etc. safely?"

In a classic pullout approach, Ralph quotes me thus: ""It all has potential to go in the water, and these are the limits we don't have a handle on," Johnson wrote in an email to The Bellingham Herald."

The article does address a real need producers have for facilities, and underscores the growing demand consumers are expressing for better product.  What is left out is any realistic discussion of the environmental consequences and whether a mobile work-around is better than the community working together to put the appropriate facilities in the best possible place.  Mobile slaughter will dispose of blood and offal on and in the ground.  It will encourage greater animal production which will increase nitrogen and phosphorus loads on pasture lands.  With a mobile unit, who will know whether these wastes are disposed in critical areas, wetlands, near wellheads or on aquifer recharge areas?  Will there be a threshold for loading, as we have established for the municipal watershed? 

A mobile facility will help farmers continue raising poultry and that's good for them.  But a mobile facility will make answering environmental questions and controlling impacts more difficult than at a stationary facility.  Eventually, the county may need to consider slaughter, whether mobile or not, with the same energy they have found for marijuana, in order to protect our water quality and the public health.

Here are my complete remarks to Ralph:

Mobile units are an economically rational solution to a lack of slaughter facilities.  They can be operated safely but are not without their problems.  North Cascades Meat Cooperative intends to employ such a facility, but possibly leave it in a single location.  That could be problematic.  We need to ask how much the land can absorb.  Eventually, mobile units may prove uneconomical.

According to the Northwest Agricultural Business Center, "Each farm must provide on-farm composting for offal…potable water, a receiving area for waste water (a suitable pasture or other well drained area that will not pollute a water supply or stream)…"

"At this time it is estimated that a producer with 150 birds to process per batch including, for this example, 90 miles round trip travel, cutting-up, packaging and custom labeling all product will be paying approx. $3.60 per bird.  Clearly fewer birds would cost incrementally more and a greater number of birds would cost less per processed package."

A report by the Economic Research Service of the USDA entitled "Slaughter and Processing Options and Issues for Locally Sourced Meat" admits that "biosecurity issues may also pose a risk" with mobile units, and concludes that "Although MSUs may provide an opportunity for producers marketing locally sourced meat products, their small scale can also compromise the cost-effectiveness of the slaughter process, since more inputs are required per animal relative to larger fixed slaughter plants. Given the current slaughter capacity and the number of units in operation now, the extent to which MSUs can facilitate growth in local markets may be marginal in the short term."

This underscores the essential problem with the industry.  It is marginal at every turn.  Economic forces drive producers to maximize production and provide ample incentive for cutting costs at every opportunity.  This can lead to over application of manure wastes, improper composting of offal, improper disposal of regulated wastes, bad reporting and the like.  This is a matter of record with Whatcom County's only USDA facility.

A crucial issue is how much nitrogen, phosphorus and offal can we put in or on the land without damaging ground or surface water quality.  For Lake Whatcom we have completed a TMDL study to benchmark the loads we impose on the environment.  Our rainy climate produces abundant waterways.  These also have limits that we have not scientifically explored.  Exceeding them will affect water quality, animal health, habitat, endangered species, etc.

According to Pew Research, each 100 birds will produce 8 cubic feet of manure per year.  That's over 1,600 cubic feet of nitrogen and phosphate rich waste per year for each producer generating their exempt limit, and doesn't include offal or feathers.  Feathers are notoriously difficult to compost.  One disadvantage of mobile units is that they are not generally equipped to consolidate these wastes and get them to a rendering plant.  Waste streams produce some revenue in larger facilities.  Users of mobile units will not benefit from these offsets.

In an article entitled "An egg industry perspective" (Poultry Digest, Jan. 1990), D. Bell observes, "The amount of animal wastes produced in the U.S. is staggering. In chickens, for example, the daily production of wastes is essentially equal to the amount of feed used. This means for every truckload of feed that is brought onto the farm, a similar load of waste must be removed."  Alternatively, it may instead be left in the pasture by the birds or applied to land as fertilizer.  Over application of manure fertilizer has already polluted many aquifers in Whatcom County with too many nitrates.  The pollution problem extends beyond manure and offal to antibiotics, heavy metals, chemicals and concern over GMO feedstocks.  There are also pathogenic vectors of concern, including diseases, bacteria, parasites, pathogen cysts, and viruses.

In "Animal Waste Pollution in America: An Emerging National Problem", a staff report prepared for Senator Tom Harken and the  U.S. Senate Committee on Agriculture in December of 1997, "Poisoned well water is a major problem on..the Eastern Shore of Maryland, Delaware, and Virginia, which slaughters over 600 million chickens a year, resulting in an annual 3.2 billion pounds of raw waste, 13.8 million pounds of phosphorous, and 48.2 million pounds of nitrogen."

We may not slaughter near that many chickens, and raising pastured poultry certainly seems nicer than factory farms, but we can't escape that in pastured stocks, manure is going on the ground.  With mobile units, blood is going on the ground and offal in the ground.  Presumably, waste from the chicken houses will go on crops or for compost.  It all has potential to go in the water and these are the limits we don't have a handle on.  Ironically, there is a better chance of stricter control in a factory setting. 

But there's the rub.  Consumers want better and safer product than the factories are able to produce.  They want not only better product, but a more conscious methodology.  That was a key piece missing from the slaughter ordinance last year: Adopting the highest quality standards for feeding, husbanding and processing the animals not only assures quality product, it is critical to limiting environmental damage.  Generally, we do not have and cannot supply sufficient staff to adequately monitor many dispersed operations.

Slaughter was the originating cause of land use regulation.  No sooner had government understood that slaughter must move "outside the walls" of the city, then it also realized it must also not be too remote for frequent inspection.

In the end, we would likely be better off taking a public health approach, forming a consortium of producers, buyers. sellers, consumers and operators,  adopting high quality standards, assessing local need, finding the best location and planning an adequate facility. Low-interest, tax-free, federally-guaranteed industrial development bonds could help defray the enormous start-up costs.  Simply connecting such a facility to publicly owned water supply and wastewater treatment would solve at least 80% of the potential problems.