Behind the Veil at the EPA Beachhead
Along with Don Benton, State Senator Doug Ericksen appears to have no future with the Environmental Protection Agency—not in DC nor at its Seattle regional office.
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Dear Council Members,
I am writing to request that you delay action on agenda bill ab2012-300.
According to the UNFAO (United Nations Food and Agriculture Organization), small scale chicken slaughter for 500 birds per hour can be accommodated in about 2,500 square feet. The 15,000 square feet limit proposed for adoption in the agricultural zone might accordingly accommodate the slaughter of 3,000 birds per hour. This UNFAO estimate assumes the use of relatively low-capital, traditional methods. Using more automated, modern machinery and methods might double this volume.
It could mean more than 75,000 animals per facility per day. According to the UNFAO, processing these numbers with these methods would use more than a half million gallons of water per day, and introduce over an ounce of combined treatment targets per gallon of wastewater - potentially more than 18 million pounds of waterborne pollution annually for the 3,000 birds per hour the proposed facility limit would enable using traditional methods.
Where is sufficient water supply and treatment capacity available in the agricultural zone? Are there places that could not supply or accept these volumes? Are there soils that cannot sustain lagoons and infiltration? Are there public or community facilities like schools and churches that might not want to be downwind from such facilities? Are there county roads that shouldn't be subjected to truckloads of animals bound for slaughter?
What about the supply of 75,000 or more birds per day? Will they be trucked in? How many agricultural properties might be encouraged to raise feedstocks for these facilities? Will they be spread throughout the agricultural zone or should the best suited districts be identified and designated? Do we want truckloads of animals packed in cages spreading feathers and waste on their way to slaughter becoming a common sight on any county road? Could they be located in the areas that can best support them with water supply, treatment capacity and proximity to adequate transportation?
The slaughter industry is subject to diseconomies that have propelled a massive consolidation and facility expansion trend. In slaughter terms, more is definitely better. The current code proposal may not adequately anticipate the pressure of scale this industry has been experiencing. How will siting a facility affect adjoining properties? To what extent will facilities tend to promulgate, lobby for expansion, consolidate and integrate with local producers? That is the industry's story, yet the findings and conclusions fail to note or respond.
I encourage the council to postpone action on the proposed change until industry trends have been better studied and understood. In particular, the utility of this amendment to poultry production and the concept of “edible rendering” may need considerable additional definition and regulation. We should wait until adequate criteria can be established, optimal areas can be identified and agricultural sub-zones designated to better protect the community from noisome nuisances. We don't allow any kind of housing anyplace in some generalized residential zone. We subdivide and organize residential land use according to each type's requirements, their social consequences and consistent with the public good. We should do the same for agricultural uses.
Additionally, I am unconvinced that there is much reason to extend this permitted use to agricultural areas. It is already allowed in industrial zones. In point of fact, vacant, underutilized industrial land complete with primary water treatment facilities and access to sewer, roads and rail already exists directly adjacent to Whatcom County's principal rendering service. Theoretically, zoning changes should address a shortage of land available for a use type. That is obviously not the case here.
This code exercise commenced upon the realization that Whatcom County's principal slaughter facility was a conditional use and out of compliance. I agree that some level of facility is essential to benefit consumers and producers of quality local meats. But opening the entire agricultural zone to slaughter as a permitted use could result in major changes that this amendment does not adequately anticipate. There are better ways to legitimize a non-compliant facility. The proposed amendment is figuratively like using a meat axe to solve a problem that really needs a scalpel.
It is in the best interests of the county and the public to delay action and consider revising these provisions to allow for the designation of agricultural sub-zones most likely able to support such facilities without creating environmental problems or public nuisance. The county should seriously consider an alternative method of remedying the administrative errors underlying this issue and legitimizing existing federally permitted slaughter facilities.
I believe this delay is highly warranted, especially in view of the applicant's record of repeated health violations, notorious scofflaw permit and tax avoidance, and securities fraud in at least two states.
Media reports on problems associated with the applicant:
Feb 2009 - Article describing applicant's health violations
March 2009 - Article describing applicant's health violations as like a murder scene
April 2009 - Article detailing applicant's illegal restaurant and problems with health department and Liquor control board
Legal complaints and orders related to the applicant:
http://tinyurl.com/bu4lptl - Feb 5, 2004
http://www.dfi.wa.gov/sd/orders/S-04-026-04-TO01.pdf - Jun 11, 2004
http://www.dfi.wa.gov/sd/orders/S-04-026-04-CO01.pdf - Oct 21 2004
http://www.dfi.wa.gov/sd/orders/S-06-216-09-SC01.pdf - Dec 7, 2009
http://www.dfi.wa.gov/sd/orders/S-06-216-10-FO01.pdf - Mar 22, 2010