Amending the zoning of 88,000 acres of agricultural  land to allow slaughterhouses as a permitted use ignores the entire history of  land use regulation.  A wholesale industrialization of AG lands for this use could generate adverse impacts to human health, land, air, water, wildlife, property values, the tax base, and the social fabric and character of our rural lands. It could devastate investments in homes and render farm crops unsalable. The severity of impacts associated with slaughter are easily researched through readily available reports on the industry.  The county is intentionally ignoring these. The law requires a comprehensive review of all potential impacts, but not one has yet been considered. The Growth  Management Hearings Board requires environmental review at the outset of zoning amendments, routinely ruling that review must not be  delayed until project permitting.  The county is ignoring the GMHB, too - once again.

Zoning is a police power and should be subject to standards. The county should find that there is a shortage of lands for the use designation being sought, assess the need for such lands, and identify the lands most suited, or unsuited for the use.  There must be a public purpose served.  There is plenty of land available for slaughter in industrial areas that have  adequate services and need not interfere with residential and agricultural uses.  The county is ignoring this.

This measure has been the  story of attempting to legitimize illegal slaughter facilities that the county has also systematically ignored.  To avoid disclosing locations, the entire zone must be amended.  The county's failure to competently regulate these facilities should undermine the public's confidence that a larger number will be better  managed.  Even as most recently amended, the measure could inflict radical harm on the community, yet the council seems intent upon adopting it and is determined to do so without environmental review.  If a proper environmental review were conducted, this measure would not be under consideration.  The last time this was done, slaughter became a prohibited use in the AG district. The county is ignoring this.

Finally, the scale of facility needed is easily determined. Other communities have already pioneered methods and means to fulfill this need, address environmental concerns, meet community standards  and maintain high quality products, a premium brand, thus maximizing value to  producers and consumers alike. This usually amounts to one facility less than 10,000 square feet for one, two or three counties.  Instead, the county has wanted an unlimited number of unlimited size.  They recently, begrudgingly entertained a staff proposal to limit it to three, but immediately increased the number and the size of the kill floors. Industry trends strongly indicate that over-liberalized zoning will invite large facilities which will consolidate smaller operations, driving quality and value to the lowest bar.  This defeats the stated purpose of this county effort.   The county has ignored this, too.

Together, it is bad government,  literally ignorant public policy and an extreme, unnecessary risk to the  community.  Please advise the Whatcom County Council that a liberalized slaughtering policy is not in the public's interest.