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Meat Axe or Scalpel?

By On
• In Whatcom County,

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

June 2010 - Controversial split with investors

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

Thank you,

Tip Johnson

Related Links

About Tip Johnson

Writer • Member since Jan 11, 2008

Tip Johnson is a longtime citizen interest advocate with a record of public achievement projects for good government and the environment. A lifelong student of government, Tip served two terms [...]

Comments by Readers

Tip Johnson

Nov 03, 2012

Lest anyone get off on the wrong track, I am neither vegetarian or an animal rights activist.  I like the idea of sustainable local facilities for quality local, and hopefully organic, meats.

For the record, I appreciate and do not oppose the the plans discussed in the following links:

BBJ Article re: North Cascade Meats

North Cascade Meats Website

Here’s their Business Plan

That said, the code amendment as proposed appears to me to expose Whatcom County to some very grave dangers.


Wendy Harris

Nov 03, 2012

Thanks, Tip.  Your comments help underscore how poorly analyzed this proposal is.  The County’s “one type fits all kinds of slaughter” approach fails to consider differences in processing needs for cows vs. poultry vs. pigs. vs. sheep vs. mink.


Doug Karlberg

Nov 05, 2012


I luv ya like a brother, but I simply do not understand what you are trying to suggest with your example data about chicken processing.

According to your numbers this hypothetical chicken nugget facility would need over 27,000,000 chickens a year, and would use so much water that the Nooksack would flow backwards from the sea. Hence the term “Chicken of the Sea”

Your chicken example ain’t going to happen at this cattle butchering facility proposed, so I wonder what the real agenda is.

What “could” happen in the future is entirely speculative, as one could peculate anyone doing horrible things in the future. Speculation is not factual. What is factual is the application for a small butchering facility.

The Keizer application is a great example, where they are only using 800 gallons of water per day, and putting out approximately the same in waste. Almost every single piece of the animal is turned into a commercially valuable product, and the waste stream is loaded into a tank truck and processed properly. This waste stream is not laden with heavy metals, pesticides, or carcinogens. For the most part the waste steam is so benign that we often put this composted material back on our gardens and feed our families from it.

I know right about now you are considering flipping e the bird, but wait a minute. I give all the credit to the environmental community for the changes in how food processing plants recycle virtually every once of their relatively benign waste stream into products that we use daily.

My problem is that even when they change some in the environmental community forget how to acknowledge this monumental change that has gone on. This simple acknowledgement goes along ways to endearing future cooperation between the environmental community and industry. An industry which feeds us everyday, reliably and safely.

Some would like to use the argument that this is industrial usage and as such is different than agricultural usage, but this misses the obvious point, which is that this butchering facility provides a market for agricultural products, without which agriculture could not exist. Processing of agricultural products is intimately connected. This is not a shoe factory that can be placed anywhere.

Local food, and especially niche markets of food more wholesome than the truly industrial food processing, is valued by residents of our county, and this facility has the potential to provide this while reducing the carbon footprint of shipping the cows hundreds of miles in diesel burning truck. We cannot have it both ways.

What does bother m though is that niche food processing and marketing does have the potential to increase employment in Whatcom County, and instead of promoting this, we are we are picking this proposal to death, and I don’t see where any of the objections cannot, and have not been adequately dealt with in the past.

Let the USDA, FDA, EPA, and DOE do their job, they are experts. Require that the applicant follow the rules and keep the odors down, and deal with their waste stream properly, and truck it to an approved disposal facility if necessary if there is a septic field issue.

I would not recommend that the County gets into the “business plans” of any land use applicants, nor would I like to see our County use land use regulations to assist any hidden agendas. Anything which would suggest arbitrary rules, or rules which are different for one similar business to another similar business, are just exposing the taxpayer needlessly to legal liability.

Any suggestion that a business locating in Whatcom County is some how responsible for the bad actions of others, needs to be directly and clearly connected to the applicant. I don’t see a single fact based issue that has not been adequately regulated in the past by the County, and I don’t see why this applicant cannot be regulated likewise. I see no overwhelming reason to single this applicant out.

We need to be seen in Whatcom County as being open for business (and jobs), fair to all applicants regardless of whether we like them or not, as long as it is legal, no hidden agendas, and not be arbitrary when considering their proposals.

By the way, it looks like this fella has had some mistakes in the past, who hasn’t, but none of them are convictions for food safety or pollution. I like Dave’s Killer bread, and he went to prison for a long time. Redemption is possible, if given the opportunity.

In the grand scheme of things, the largest polluter in Whatcom County is us. Human sewage and road oil pollution are our largest waste streams we have to deal with. Lake Whatcom is not getting better. Maybe these problems would be a better place to prioritize energy, if we want to make a significant difference.

Attacking a small butchering facility, is truly biting the hand that feeds you, and does not exactly put out a welcome mat for job creators in the broader Whatcom County.

County Hearing Commissioner John Lesow in a previous article on NW Citizen took me to task for not coming to a bunch of hearings on this matter. I guess if you do not attend you are somehow not informed. While I have not attended a bunch of these boring meetings, I have been to a slaughter house, I have seen a Mobile Slaughtering Unit with my own eyes, I have raised cows for slaughter, and I manage and operate a seafood processing facility which processed 500,000 lbs. this last summer and passed a FDA inspection, and have had to become quite familiar with HAACP rules and regulations, which is probably more first hand knowledge than some of the experts have that are making the decisions at government level. I will bet that if Mr. Lesow tried to admonish a appellate court for their not being there at the district court level to hear the evidence first hand, that Appellate Judges point out the error of his logic.

Mr. Lesow somehow equates slaughterhouses with abortion clinics and how people would rather work in an abortion clinic. (nice analogy counselor)

Mr. Lesow bemoans that we only are attracting slaughter house and coal jobs. When people are out of work, especially for long time, they will take anything that is offered. Can you blame them? If we create jobs, this desperation resides.

Whatcom County needs more jobs in total. Increasing the total number of jobs tends to raise the wages of everyone. To increase jobs we need to be more welcoming, within reason, and less petty. The pettiness creates a bad reputation for potential job creators.

Zoning is just artificial lines drawn by people, and unless Moses has signed the drawings then I think the wisdom of these artificial lines should be challenged when it looks like they do not serve our needs. A butchering facility, properly regulated serves our needs for food. Placing a butchering facility near the farm, is common sense. What is next for our nationally recognized cluster of food production in Whatcom County, regulating cottage jam canning businesses.

With 15% of Whatcom County residents living under the Federal Poverty level, each of these potentially twenty jobs would bring twenty people out of poverty. Mr. Lesow has a good jobs, and thinks that this proposal will result in the “mongelization” of Whatcom County. One butcher shop will do this? How about those 27,000,000 chickens coming here by train?

Why is that Whatcom County has such a high level of poverty and low wages when compared to other counties?

Good question, but maybe there is a clue, when it takes this much debate to open a small butchering facility next to a cattle farm.

We all believe in protecting our environment, but we have made huge progress, and even protecting the environment can be taken to extremes. This is a good example of the extreme.

Last, Mr. Lesow chides me on my sophomoric humor. I do this intentionally, as I know that all of these people involved have good intentions, and this is a friendly debate about policy.

I use the humor to bring us all back to a chuckle together.

So in this spirit, Tip, the chickens have come home to rest, and you can now flip me the bird.


Tip Johnson

Nov 05, 2012

Flip you the bird, Bro?  Heck, I largely agree with you, but I think there may be a burr under your saddle and you have taken off on a stampede.

Perhaps you missed the part where I said I don’t oppose the actual proposal AND I think we need adequate facilities to help local farmers produce quality local meats.

But the Council is painting with too broad a brush.  All I ask is that they consider identifying areas best suited to support such activities. What’s wrong with that?

I even agree that zoning is often more of a problem than the solution, but it does do a good job of keeping rendering plants and schools apart.  Why couldn’t it do a good job of keeping slaughter houses and rendering plants together and both away from churches and schools?

I’ll repeat:  I think small scale slaughter for quality local meats is good.  We could even encourage super high standards and promote a Whatcom brand - even with chickens if we think ahead.  But the ordinance as written is so full of holes, that someone like Tyson could come to exploit cheap land and spur a major, unintended transformation of a lot of county land.  What’s so good about that?

Essentially, as I requested, the County needs to slow down and take a closer look.  I didn’t make up those chicken numbers.  Read the document.  The county is trying too simple an approach to a complicated market.  They need a more sophisticated and nuanced ordinance.

And I never suggested getting involved with anyone’s business plan.  Let’s just not create an opportunity for business that is known to be socially and environmentally destructive, a risk to public health and a constant nuisance to the good people living in the county.

BTW, as a junior high and high school student, a common summer job was running into the sheds, grabbing handfuls of worn out layers and stuffing them into Campbell soup trucks.  It was a God-awful mess and literally a terrible horror. 


Doug Karlberg

Nov 05, 2012

No problemo Tip,

I know that you did not make up the numbers.

Stand alone rendering plants are not the same size scope, or process when a butchering facility “renders” its waste. Unfortunately it is an emotionally charged word, and one has to discern the true nature of what is being proposed, and the indiscriminate use of the word without factual context can inflame people.

Here is the definition.

Rendering is a process that converts waste animal tissue into stable, value-added materials. Rendering can refer to any processing of animal products into more useful materials, or more narrowly to the rendering of whole animal fatty tissue into purified fats like lard or tallow. Rendering can be carried out on an industrial, farm, or kitchen scale.

What we are talking about is farm scale in nature and not industrial in nature. This is also true of the butchering facility.

The best place for a cattle butchering facility is close to the farm. Small scale rendering close to the butchering operation ensure the least odor, and the freshest products.

I accept some odors from farms, as a price I am more than willing to pay for my food.

Whatcom County is having some good paying jobs dangled in front of its nose by the coal proponents and it is attractive to some, because these jobs are needed and relatively high paying jobs. Whatcom County has a long history of low paying jobs, which mostly a function of poor economic development by government, and a heavy reliance on (clean) retail and hospitality. Agriculture now pays higher wages than many of the retail jobs. At least this “dirty” industry feeds us.

I did not know that this butchering facility was going to be placed next to schools and churches. I guess I missed this in the application.

There is hardly an industry that has not had a bad environmental record to change in today’s environment, and most have done a good job of changing. I like to purchase my meat from the small butchering facilities, and I have not seen any socially destructive goings on there.

Dangerous ground to see one place in business with permits, and another who cannot get permits for the exact same business, under the same conditions. Lawyers love this stuff, and taxpayers pay the price for selective regulation and selective enforcement, especially if the ground for this picking winners and losers is arbitrary and capricious.

Well my fine feathered friend, enough squawking for now.


Tip Johnson

Nov 05, 2012

One more squawk. 

If the County intends to implement a policy of creating a lot of nice slaughter jobs and business revenue from a new slaughter industry in Whatcom County, then this is the ordinance for you.  Great, maybe we can wash off the coal dust with blood before we go deposit checks from our new jobs in the bank.

The way the ordinance is written has the potential to completely change the rural character of Whatcom County. 

If someone decides they can build a chicken slaughter line or two or three or however many, then the ordinance requires that of the the 27, 54, 80 or however many million birds are needed, half will have to be raised in Whatcom County.

Let’s say some big company with a history of shipping frozen chickens to Russia decided they could amass a huge real estate empire building coops and slaughters and fill ships with birds grown right here in Whatcom County.  Hey, that’s business, but is it the business we want Whatcom County known for?

It’s potentially a lot of birds, applied throughout the Agricultural zone, a lot of new buildings and a lot of impacts.  Sure, it’s probably good for the economy in the short term until others’ real estate values are considered.

As written, the ordinance does nothing to insure facilities are farm-based and small scale.  It opens the door to exploitation of our economic tractability and could wreak vast changes to people’s way of life.

That at least deserves some community consultation.  I don’t see any of that in the public record.


John Lesow

Nov 06, 2012


your final—and previous—comments are well considered and shed additional light on a difficult subject; one that has garnered a lot of attention from a County government that is trying to strike a balance between supporting Ag and maintaining some semblance of quality of life for County residents. 

Doug, I appreciate your empirical experience, but fish processing and slaughtering on Ag are two separate subjects and the ramifications are different.  That is why attending these “boring” meetings is necessary to get a handle on the issue.  Personally, I don’t find these meetings boring, and I have attended over 200 during my 8 years on the Planning Commission.  They never cease to fascinate me, and I will miss them when my term is up next month.

As far as your Appellate vs. District Court argument is concerned, I fail to grasp your logic or admit to any errors in mine.  Besides, yours is a straw man argument and misses the point of Ms. Harris’ original article.  The present proposal before Council fails to recognize the complications of rendering and slaughter on the same site, as well as use of a scarce resource (water) for an industrial activity.  Plus the problems of waste disposal without the benefit of a sanitary sewer.  She makes a good case that the proposal should not be passed in it’s present form. 

Abortion clinics and slaughterhouses are both legal, so if your expressed concern is for “jobs” why differentiate the two?  Casinos are legal, so why not locate them on Ag land and give the farmer, the prospective employees and the economy in general a boost?  Drinking establishments on Ag provide good jobs for County residents.  The Northwood Casino is a convenient example.

The fact is that the proposal under consideration will amount to an upzone from Ag to Industrial throughout the County.  Will ag land be taxed at a higher value due to the presence of a slaughterhouse?  Will Rural lands be next?  One of the deficiencies of the County Comp Plan is that it fails to make the distinction between activities that are “rural” and what amounts to “exurban”.

Whatcom County is being mongrelized from bad land use decisions. We have been in violation of the Growth Management Act for years and continue to be. I have not lived here as long as you and Tip, but I do recall talking to the late Sharon Roy about the abundance of fish and in the streams and waterways around the county when she was growing up.  And the robust oyster farms in the bays when they were not contaminated like they are today.  You can’t lay all the blame on road runoff and failing septics.  Agricultural practices, past and present, have degraded our waterways, too.  Allowing industrial uses on Ag land will accelerate this degradation.

I enjoy a good joke, but the comments directed towards Ms. Harris, particularly the characterization as another ivory tower intellectual, were more denigrating than funny and detracted from what I considered a responsible viewpoint on a potentially irresponsible proposal.  One that Council will likely endorse, despite the unintended consequences of allowing slaughter and rendering on Ag as a permitted use, one that is not allowed in neighboring counties.


Tip Johnson

Nov 08, 2012

Mr. Lesow,

I expect you may be the only one with the will to plow all the way through this.  I have it all on tape and it is a rich lode to mine.  I am sure we will be in touch.  This single sleeping issue could be the undoing of many a political career!

The most telling comment I received from a county council member was, “Oh come on, there used to be slaughterhouses and rendering plants all over the county.”  Later in the conversation, they admitted that the county also used to be filled with chicken farms.

Seriously, do they have any idea why that’s not true today?  There is a reason slaughter and rendering are restricted to the industrial zone…actually, very many reasons.  Mainly, they are offensive.  There are reasons factory chicken farms have consolidated into areas with adequate facilities.  There are reasons slaughter facilities get larger and larger. The Council is so intent, they are insensitive to these facts.

The Council admitted they had never even considered chicken production in their valiant effort to make the entire county accessible to an applicant with a history of scofflaw behavior hoping to scam local farmers with the promise of adding value to the slaughter business by rendering conventional wastes into edible products.  I have his spreadsheet if anyone is interested.  The whole benefit of the business plan is based on the supposed value of rendering animal waste into food.  It could be dog food.  Council members discussed but refrained from adding a qualification that such products be strictly for human consumption.  Council members were instead concerned that it might be too easy for neighbors to complain about a farmer or their so-called ancillary agricultural uses.  They joked about how it might even smell good, “Like a Barbecue”, suggested both Mann and Crawford. 

At literally the last minute, Brenner did raise the chicken question, mentioning my recent submittals.  She was completely ignored.  Crawford advised that she could vote against the measure, which she did. Mann admitted that, as of Wednesday, he had not read correspondence delivered to the Council on Sunday, and opined as how he wasn’t worried about it.  He said the County would deal with it if it became a problem.  To her credit, Brenner rightly advised that it would be too late by that time.  Yet, she still supports a less restrictive ordinance.

One key to the County measure is that the meaning of the term “ancillary” is not the same as generally used in the code.  Usually, an ancillary use is secondary to the primary use of a specific property, so a property would need to be raising animals to have a slaughterhouse.  Not so under the newly framed proposal. The council has decided that for the purposes of this code, “ancillary” will mean related to any use in the Agricultural zone.  But it gets even better for the slaughter industry!

Other policies are designed to prevent non-Ag uses from displacing agricultural uses. Council probed staff in depth to assure themselves that as long as no agricultural use was present, then none could be deemed displaced, thus triggering policies that might inhibit the building of slaughterhouses.  Thus, farmers can bulldoze their berries, or leave fields fallow to show that no agricultural use is present before applying to build slaughterhouse facilities on any agricultural land.  Brilliant!

After an hour and a half of the most inane, irrational and poorly informed discussion imaginable, they voted 4-2 in favor of moving the measure ahead.  4-2?  Should that give us hope?  No!  Brenner and Knudsen both opposed, objecting that the measure was too restrictive, even as it opens the entire AG zone to industry.  Brenner and Knudsen repeatedly stressed that it should be an outright permitted use, not an accessory use even under the zone-wide definition.  Also, they objected to the idea that any non-farming neighbor might be able to complain that such an operation affected the use and enjoyment of their property.

I predict, if the Council prevails, that taxes on Ag land will have to be raised to Industrial rates after residential properties lose half their value.  Where does the Council think their tax base resides?  Farms all get a super-hefty agricultural discount.  It’s the “gentlemen farmers”, the estates, the Fincas if you will, the single family homes and even double-wides that really pay the freight.  Does anyone really believe these properties will be bought and sold at the same rates with the specter of slaughterhouses and rendering plants next door?  No one even has to build one.

It’s absurd, yet it surges ahead, virtually every Council member in favor of either this or a less restrictive measure. This is the kind of issue that can really make some rain.  Who does the Council think will rise to their defense?  Not even most farmers will want a rendering facility or slaughterhouse next door.

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