Dear County Council Members,

I believe the slaughterhouse/packinghouse/slaughterhouse&packinghouse ordinance has gone from a bad premise to completely off the rails.  It pretends to offer what it can't provide - quality local meat products.

There are reasons Whatcom County has only one small USDA slaughterhouse - because we can't support more.  The structural problem is that slaughter is only wanted at certain times. 

Dairies want slaughter in the early summer for their culls. Our federally inspected slaughter is too small to handle 15,000 grinders, so these are trucked elsewhere.  Anyway, being GMO-fed, they won't meet the consumer standards for quality the ordinance pretends to promote. 

Hobby farmers want slaughter in the fall so they can avoid winter feeding and so the animals don't muck up their pastures.  Many of these animals are processed under exempt rules, allocated in quarters and halves to specific customers.  They don't need federal inspection. These wise consumers have long been enjoying quality local meat products - and saving money.  The ordinance is supposed to help local consumers and producers, but it is really written for the dairies.

The Ferry Brothers had to import most of their animals to keep operating and took a very mainstream approach.  They demonstrate the other reason it won't work.  The industry won't let it.  The story of this business is one of consolidation and market control.  Iowa beef took Ferry Brothers down as soon as they became successful.  They convinced retailers not to buy the product.  No multiple number of small or large slaughterhouses will survive if they can rely only on the Co-op or subscriptions for retail sales.

Anyway, it's hard to conceive of a rationale for wanting widespread slaughter.  First, the business is intrinsically marginal so policy makers must assume that every possible corner will be cut.  This has proven true not only with the one local UDSA slaughter but ubiquitously throughout the industry.  It means they must be carefully monitored.

The process is extremely noisome, filled with disturbing sights, sounds and bio-hazardous wastes and public health risks.  Who will monitor the waste handling and disposal procedures?  Our current staffing levels were unable to timely detect the hijacking of domestic water for the kill floor, the failure of the approved septic due to the additional water, or the disposal of spongiform encephalitis risks in digesters for eventual application on farmland.  Framing code that encourages widespread slaughter throughout three entire zoning districts without funding adequate regulatory staff is asking for problems.

Slaughterhouses are too expensive to let sit idle.  It is the nature of this capital intensive, marginal business to constantly require more and more animals.  Whatcom County aquifers are already overburdened with nitrates.  How many more animals can we support without further adverse impacts to water quality?  How much feed can we raise?  WIll we import GMO feed?  Is that what consumers want?  The consumer base contemplated want quality product and environmental integrity.  Widespread slaughter misses that mark.

Quality local product is already accomplished in Skagit and Snohomish counties in small shops that fit the pictures painted by the ordinance's flowery words and testimony of proponents. These shops don't slaughter anything.  They work with local producers to raise animals according to high standards, assist in getting it to a federally inspected facility, then bring it to their butchershop to make premium cuts and value-added products.  There is no way the public would ever pay the astronomical costs that a USDA inspector and HAACP requirements would add to these premium prices. 

What we need is one decent slaughterhouse and more butchershops.  Consumers want prime cuts of fine meat and delicious bacon, jerky and sausages, etc.  Widespread slaughter is unnecessary, undesirable and counter-productive.  Other communities addressing the problem of inadequate access have taken a very different approach.  They assess need, size an optimal facility, look for the best location, and assemble a consortium of producers, consumers, retailers and sometimes operators to adopt high standards that can command a premium price.  Then, with this comprehensive public utility approach, they seek public support in terms of friendly investors and federally-guaranteed, tax-exempt, low-interest, industrial development bonds - to prevent the operation from drowning in debt service at the start.

It is unwise to allow slaughterhouses and packinghouses to locate within a few yards of existing homes and businesses and to hang the threat of one suddenly appearing next door throughout three entire zoning districts.  Please say no to widespread slaughter and find the best place to put the one we need.

Thank you

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