3000 chickens for Ontario's Small Flockers

As startling as it may sound, Chicken Farmers of Ontario ("CFO") just posted on their website (as of late yesterday Jul 28, 2015) the Artisan Chicken Program, where Small Flockers in Ontario will be able to raise between 600 to 3,000 chickens per year for select target markets such as retail customers, restaurants, or local farmer markets.  Small Flock Exemption for 1 to 300 birds per year will be re-labeled as Family Food program and continue as before.

"Play fair, be prepared for others to play dirty, and don't let
them drag you into the mud."   Richard Branson, (1950 - ),
English businessman and investor. He is best known as the
founder of Virgin Group, which comprises more
than 400 companies

First, let us count our blessings and give thanks.  I have already sent an email to Michael Edmonds, CFO's Director of Communications and Government Relations, saying:

"Thank-you for bringing this program for all of Ontario's small flock poultry farmers, and the people of Ontario who want and need safe, nutritious, affordable, and locally produced chicken."

You can email or phone Michael too:   Email Michael   Phone: (289).288.4223

I and SFPFC has been lobbying on behalf of Small Flockers and all Canadians for 3 years, others have been at it for far longer. We sought, in addition to other pleas for relief, for raising our Small Flocker exemption from 300 to 2,000 birds per year, but we ended up getting 3,000 birds per year. 

How's that for results!

Small Flockers who are happy in their personal niche sub-300 birds per year can stay there, undisturbed.  Perfect!

CFO passed CFO By-law 212-2015 for Artisanal Chicken as of July 28, 2015.
 
CFO Applications for Artisan Chicken forms must be submitted prior to Friday September 4, 2015. 
Applications will be considered in the order in which they are received, until the allocation available in any year is reached.

That means first come, first served.  I informed all SFPFC members of the good news at Tuesday July 28, 2015 at 7:52 PM, then I started filling out my application form for 3,000 birds, which I submitted to CFO at 9:44 PM Tuesday.  Fair is fair.

Get your application submitted ASAP.  Snooze, you lose.

CFO said, "The available allocation for Artisan Chicken will be 5% of the previous year’s growth."  When they say "growth", do they mean the total allocated quota received from Chicken Farmers of Canada ("CFC")?  If not, does that mean that if Ontario's chicken consumption enters 0% growth for some year for whatever reason, the Artisan Chicken Program will come to an end the next year?  That doesn't seem fair, nor reasonable.  I wonder what CFO really meant to say?

Applications will be processed and initial premises inspections conducted between September 2015 and November 2015. There is no set number of farmers that will accepted into the new program.  Successful applicants will be informed in early December 2015.

CFO said, "Chicken grown under this Policy is not to be marketed for home consumption."

Elsewhere, CFO said,

"The chicken grown under the Artisanal Chicken program and Local Niche Markets program will be counted against Ontario’s national allocation as set out by Chicken Farmers of Canada. Chicken grown under the Family Food program (previously the Small Flock Program) is exempt from the national allocation system as it is intended for home consumption and not considered commercial product."

It seems CFO has now defined (or always defined) that small flock farm gate chicken sales are not "commercial".  Good to know, all yea Small Flockers.  That CFC-CFO definition may come in handy down the road.

CFO said, "Artisanal chicken marketed under this program must be marketed at a price not less than the Minimum Live Price determined under Ontario Regulation 402"  The current minimum live price is $1.563/kg for a 2 kg bird.  Assuming 0.68 kg eviscerated per kg of live weight, that is equivalent to $2.30/kg of eviscerated meat ($5.06/lb.).

CFO said, "CFO has established an Annual Production Licence Fee of 20¢ per quality chick placed. CFO and CFC fees and levies are also payable at 3.6¢ and 1.2¢ per chick respectively. These are payable when the license is issued."

The total is $0.248 per chick placed.  Assuming a 5% chick mortality, the chick placing fee becomes $0.26 per live bird sent to slaughter, or $0.13/kg live, or $0.19/kg of eviscerated meat.  Assuming 1.5% of all birds slaughtered are condemned (unfit for food), that fee becomes $0.194/kg ( $0.427/lb) of eviscerated meat that can be sold.

CFO said, "Overproduction above 5% will result in a financial penalty of $1.00 /bird and impact consideration of future licences."

CFO also said they have plans for a "Local Niche Markets Program.  This program offers interested farmers the opportunity to support those larger niche or regional markets of 6,000 chickens or more per year. This is an application and quota based program.  More details on this program will be announced at a later date."

I found it very interesting that the CFO By-law calls for an "Artisanal Chicken Abattoir".

Obviously, there are many more questions that must be found, expressed to CFO, and that must be answered eventually.

There are some SM quota people who are organic, and who do pastured poultry.  We now have, or will get the express, included right to pastured poultry too; if not now, then soon.  It may take some more "discussions".  I plan to, and hope CFO will be willing to work co-operatively with us.

For some Small Flockers contemplating what to do, the added bureaucracy, paperwork, arbitrary and conflicting and contradictory and ambiguous statements and requirements by CFO under Artisanal Chicken may cause bewilderment, stress, and fear.  The "interesting" requirements of CFO's fine print include:

• On-Farm Food Safety Assurance Program ("OFFSAP") compliance (including HACCP, risk management, and biosecurity);
• On-farm audits, planned and surprise
   
• Animal Care Program compliance;
   
• Farm Worker Safety Program compliance
• CFO's Infectious Poultry Disease Isolation Policy compliance
• CFO's Digital Communication and Transactions Regulation compliance
• Licence Fees, Levies, Service Charges and Penalties Regulation compliance
• Artisanal chicken farmers will be active partners in growing the Artisanal Chicken Business Community by funding community development  and program related costs [SFPFC: more overhead costs]
   
•  Produce birds with a reference weight of 2.225 kilogram live weight [SFPFC:   it is unclear what happens if our Artisanal customers want different weights of birds than CFO's "reference weight"]
• CFO may take similar action against every other artisanal chicken business community partner(s)who has been a party with an artisanal chicken farmer to any growing and marketing of artisanal chicken contrary to this Policy [SFPFC:   guilt by association, how far will the witch hunt go?]

Perhaps SFPFC can play a role to develop templates that will fit most Small Flockers who apply under Artisanal Chicken.  This could be done on a cost shared basis for SFPFC members, saving everybody time & money.

We have until 2016 to get all our ducks in a row.

We can do it if we all work together.

Ontario Small Flock Chicken Appeal Re-launched

The decision has been made.  I will be re-filing my appeal of CFO's small flock regulation to the Ministry of Agriculture Appeals Tribunal.

When I received the ruling from the Tribunal on my appeal, I immediately sent a copy of the ruling to the various agriculture publications and reporters.  Among others, Susan Mann of Better Farming did an interview of me, and wrote an article on the appeal and the Tribunal's decision.

Since that time, there has been a lively debate on BF's website about the issues; making it the most lively issue on BF's website.

That prompted me to make the following posting on BF today, announcing my decision:

Eighteen days have passed since BF's posted this article on May 22, 2014.  In that time interval, a total of 81 comments have been made by numerous people.

My original appeal to the Ontario Ministry of Agriculture Appeals Tribunal presented evidence on all of the wrongful acts of Chicken Farmers of Ontario ("CFO") and the chicken Supply Management system overall.  While that comprehensive appeal was rejected by the Tribunal, the Tribunal invited me to re-file my appeal on the limited grounds of the 300 bird small flock exemption Regulation.

I have monitored all the comments made here, and attempted to respond, question, or defend the principles behind the appeal I filed with the Tribunal, complaining against the alleged illegal, negligent, and mis-guided actions of Chicken Farmers of Ontario ("CFO").

After the ruling of the Tribunal was released, I asked for opinions on what should be done next (if anything).  I received nothing but encouragement to continue.  In spite of this encouragement, I do not look forward to another appeal, for I see it as sticking my head into the gaping jaws of a hungry lion.

Some comments made here were off topic, but most expressing worthy opinions on this important issue.

The debates held here have assisted me in considering and preparing the necessary arguments and reasons as to whether a renewed appeal should be made.

In my opinion, there have been no arguments presented here that have persuaded me to change or abandon my principles and logic behind the original appeal.

I thank everybody for your input, and for providing me the ability to defend, practice, and hone my skills and persuasive arguments.

In spite of my reluctance and reservations, I believe that re-filing my appeal must be done for the greater good of all.

I therefore hereby announce that I will be re-filing my appeal within the 60 days allowed by the Tribunal.  I have already started re-drafting the Notice of Appeal this weekend.  When the draft is ready, I will post it on SFPFC's Blog for review and comments before the final version is submitted to the Tribunal.

Glenn Black
Small Flock Poultry Farmers of Canada ("SFPFC")

Top Priorities for Small Flockers

I was contacted by a reporter who needed me to summarize all that I have written, "Just give me your top three issues", they said.

I thought about it, I reviewed the titles of all my posts, then I had to re-read some of the posts themselves, as the titles didn't fully describe the content.

I thought some more, then decided on the top three priorities.  I'd appreciate some feedback from the Small Flock members on my preliminary answer for our top 3 priorities:

1. Affordable, safe, nutritious, high quality, sustainable, and locally produced foods for Canadians.
   
   Small Flockers are most concerned about poultry meats and eggs for the above priority.
   
   We have concerns about the affordability, safety, nutrient levels, sustainability, and centralization of the mega chicken factory version by quota-bearing Supply Management; our beliefs being collaborated by voluminous research and critical incidents.
   
   In spite of the drawbacks of the "officially approved" system, Canadians are treated as incompetent wards of the government, stripped of our rights to produce and consume food as we know best, and as we choose.
   
   In the above stated priority, we have placed affordability first for a reason.  If it isn't affordable, none of the other factors matter.  Safety and risk are on a broad continuum, so if it is slightly higher risk but much more affordable, some people may want to consciously take that risk, for no food is 100% safe.
   
   If someone feels consciously forced to buy unsafe food due to the unaffordability of safer food, the government should focus its efforts on improving affordability so that everybody has a reasonable choice.  The less safe food will naturally disappear from the marketplace when safer, better, more affordable options appear.
   
   The SM system is a government created monopoly that is supposed to be operated and maintained in the best interest of the public; but this rarely or never occurs.  In reality, the SM system is operated in the best interest of the select few (ie. 0.01% of Ontario's population), and against the greater good of the public (ie. the 99.99% of Ontario).
   
   The current Supply Management ("SM") system is operated with mis-management, lack of due diligence, secrecy, cronyism, and so as to exceed the legislated and delegated authority of the various agencies.  The SM legislation is beyond the powers of the Federal and/or Provincial governments, and contrary to international treaties.
   
   
   
   
2. Everyone is allowed to raise up to 2,000 meat chickens per year.
   
   Chicken Farmers of Ontario ("CFO") has stated that the 300 bird limit was chosen arbitrarily, they planned on it being highly restrictive, and agree that this limit is insufficient for producing chicken at affordable, competitive prices.  However, CFO feels no need to allow alternative, competitive systems to exist which might be in competition with their chicken monopoly.  This 300 limit takes away the farmer's right to feed their family, supply food to their local community, and earn a reasonable living.
   
   
   
   
3. Everyone is allowed to self-inspect and farm-slaughter up to 300 poultry birds per year, then sell them at their farm gate, provided they supply full disclosure to the prospective customers.  OMAF can issue a special license that exceeds these limits under special circumstances; or in remote, under-serviced areas.
   
   There are numerous under-serviced areas in Ontario today, with no hope of getting a commercially viable, local, provincially licensed slaughter plant.  We believe that a properly trained farmer can produce eviscerated poultry carcasses that are equal or better than the high speed, automated processing factories.  With full disclosure, there is no fraud, nor an imbalance of power between the buyer and seller.  Private individuals should not be stripped of their right to choose their own foods.
   
   By limiting the farm slaughter to just 300 birds, the magnitude of the total risk of farm slaughter is contained.
   
   If a farmer feels a need for marketing more than 300 birds per year, Small Flock Poultry Farmers of Canada believe that it becomes viable above that 300 limit for the farmer to transport their flock to a Provincially-licensed abattoir, and therefore should do so.  If it still isn't viable above the 300 bird slaughter limit, the burden of proof is on the farmer, and if their case has merit, OMAF can issue a special license to the farmer with the necessary conditions.
   
   In remote areas (ie. James Bay coast, remote mine sites and work camps, etc.), we suggest that the government can issue special permits to extends these limits (2,000 and 300) further.
   
   If this proposal is still seen as too risky for some unknown reason, the local Health Unit can inspect the farm slaughter process on an as-needed basis, for local Health Inspectors exist in all jurisdictions.

Brave New World

What would Ontario's chicken world look like if the mill stone was removed from around the neck of Small Flockers?

Would it all end with the bankruptcy and ruin of every commercial, quota-bearing chicken farmer?  Would people in Ontario starve due to a lack of chicken?  Would the sun rise the next morning?  Just how bad could it get?

Using our infamous HHI (yes, again), I did the present case, and some future scenarios.  Let's take a look.

Today    There are about 13,000 Small Flock Poultry Farmers in Ontario.  The average small flocker raises 69 birds per year.  Here is the total market share (quota + small flockers) for Ontario:



We can see that the Small Flockers add little to nothing; neither to the market share, nor to the HHI scores.

Case II:  Small Flockers raise 300 birds each for sale  They will raise some birds for themselves, but everybody suddenly becomes totally committed to local food production and raise the new maximum (ie. 300 meat birds per farmer).  Here is what we would get:

 

Now the %HHI increases from 0.01% to 0.18%; better but still insignificant.  The mega giant quota holders still dominate the scene.

Case III: Small Flockers raise 2,000 birds each for farm gate sale   IN this scenario, we have the following results:



Now we're talking!  Finally, Small Flockers have a significant presence in the Ontario chicken market.  Small Flockers are about the same as 5 of the other size categories for quota farmers.  The %HHI for the mega farmers is reduced from 63.84% to 58.92%.  The overall HHI score is reduced to 83.9% of its former value.  Nobody dies.  The world doesn't come to an end.

Can't we all just get along, recognize and appreciate the unique roles that each of us can contribute to the greater good of the public?