Case Dismissed: The Appeal Tribunal has Spoken

The Ontario Ministry of Agriculture Appeal Tribunal has refused to hear Small Flockers' appeal of the Small Flock Exemption Regulation as it is judged to be "frivolous, vexatious, and made in bad faith."

The Tribunal has consistently complained about lack of powers and jurisdiction for finding liability against Chicken Farmers of Ontario, and similar issues that were requested as relief for Small Flockers.  In response to the Tribunal's alleged limitations, both Versions 3 and 4 of our appeal had those contentious issues removed.  For some unknown reason, the Tribunal got hung up on Version 2, and would consider neither Versions 3 nor 4. 

In addition, I supplied the Tribunal with over 23 different legal precedents that supported the contentious relief that I requested from the oppressive and unconstitutional parts of the Small Flock Regulation; including a number of Supreme Court rulings that directly supported our case.

The other Respondent parties refuted neither our legal arguments, nor the case law presented, nor offered case law in support of the Respondent's position.  In spite of that, the Tribunal is silent about all of the case law presented except one, and then decided against us in what appears to be a contradiction of the case law.

How that can occur is a mystery to me, but that's where we are at.

The Tribunal mentioned in their decision that there was significant animosity between Small Flockers and CFO.  It seems that the Tribunal felt that this was one more reason not to allow the appeal, for they discussed it in this decision, as well as the previous two decision; obviously sufficiently important to bear repeating three times.  Does the Tribunal expect that if litigants are not the best of friends, they shouldn't be allowed access to the Tribunal?  I find this very strange.

The Tribunal said that I acted in bad faith because I had a "personal political manifesto".  That was the accusation made against me by CFO, but I don't remember agreeing to that accusation, so it seems the Tribunal leaped to assume CFO's accusation was true; no evidence required.  It appears that the Tribunal wants and expects me to be a cold fish, a dis-interested party, with no stake in the outcome.  To me, that doesn't make any sense whatsoever.  If fact, Section 16.(4).(c) of MAFRAA says that one of the reasons that the Tribunal can dismiss an appeal is that "the appellant has not a sufficient interest in the subject-matter of the appeal".  So the Tribunal dismisses my appeal because I'm too interested, but can dismiss my appeal because I have insufficient interest.  Appellants must need to be like Goldilocks, not too much, not too little, just the right amount of interest.  Sounds pretty arbitrary to me.

I asked in writing before the Tribunal got started, and was assured by the Tribunal's Administrator that the Tribunal would provide full written reasons for their decision.   At the very start of the hearing, I asked again, and the Tribunal Panel themselves again reassured me that they would be providing full written reasons for their decision. In spite of these assurances, the Tribunal's decision is scant on the reasons for their decision.  My budding understanding of court proceedings, based on what I've been told and read, is that the court's decision should speak to all of the arguments presented by both sides, clearly state whether the Tribunal agrees or disagrees with those arguments, and the reasons why.  For virtually all of my reasons and arguments presented, it seems the Tribunal ignored them, like they were never made.  The Tribunal's decision mentions just one of my arguments, but even there, it offers no reasons why it was dismissed.  With incomplete reasons, it is difficult to impossible to appeal the Tribunal's decision, as there is nothing to appeal.  There is no record kept of what was said during the appeal, so we can't even go there to fill the holes in the Tribunal's records.  Unfortunately, it doesn't seem that I got what I was promised.  The Tribunal seems like it's trying to hide in a fog of ambiguity they have purposefully created.

To see for yourself, here is the Tribunal's decision to dismiss our appeal before it gets started.

So you can see for yourself what the Tribunal is referring to, here are my arguments for allowing our appeal to go forward:

Appellant's Answer to Tribunal's Allegation and Threat to Dismiss our Appeal 
10 pages, 171 kB, Adobe Acrobat X pdf file

Appellant's Submission Brief (case law, statutes, regulations, documents, and 375 signatures on Petitions requesting the Tribunal to allow appeal to proceed to full hearing), 27.35 MB, 1,085 pages, Adobe Acrobat X pdf file.  (It a BIG file, so it takes a few minutes to download.  Be patient)

Here is CFO's submission to Tribunal in response to my Answer

Unlike our answer, CFO presented no facts, no legal references, no case law that supports their position.  All CFO did was issue 5 pages of rhetoric.

It appears that CFO's rhetoric is pretty powerful stuff, as it trumps a number of Supreme Court of Canada cases that supported our position.

I understand that I can ask the Tribunal for re-consideration of their decision.  My estimate of success is I'd have better luck buying a 6-4-9 ticket.

I can also ask the Minister of Agriculture to intercede.  Assessment of success?  I have no idea.  What are your thoughts?

If neither of these work, I can ask the ON Superior Court for a Judicial Review.  However, that puts me at risk for having costs awarded against me, perhaps risking thousands of dollars to pay for CFO's lawyers if I lose. Pretty risky step.

What do you think Small Flockers should do?

Connecticut Can, Why not Ontario?

Small flock poultry farmers in Connecticut ("CT") USA can now do on-farm slaughter and sell these birds at retail sales, such as farmer's markets, household consumers, restaurants, hotels, and boarding houses.

Somehow, the US system evolved so that there are neither State nor Federal inspected poultry processing plants in Connecticut.  That sad fact has hindered all Connecticut poultry farmers, both big and small, for some time, because the CT poultry was not an "approved food source".  That meant individuals could purchase their poultry meats for home consumption, but you couldn't sell them at retail, and they couldn't be used in restaurants and other food service establishments.

The Connecticut Public Act 10-103 "AN ACT CONCERNING FARMS, FOOD AND JOBS".  Now isn't that a novel twist.  Politicians who actually understand that local food production helps farms, and creates jobs.

Further on in the announcement, the Connecticut government states, "More and more consumers are demanding foods they perceive as more sustainable and local."  It is clearly evident again, that Connecticut politicians and bureaucrats are listening to their people.  Why or why do we have so many deaf and dumb politicians in Canada?  In Canada, they can't hear (or don't want to hear) what the people are saying, and they refuse to speak up on behalf of Canadians.

This Connecticut law includes "... livestock food products, including meat, milk, cheese and other dairy products..." and just about all other farm products of Connecticut, and baked goods derived from those Connecticut products.

For example, canning of farm produce can be done on-farm without public health inspection, provided the farmer has passed a safe food handling and/or safe food processing course, the farm house water used is fit to drink, the canning area is restricted during the canning process, and each container is labelled "Not prepared in a government inspected kitchen".

Small flock poultry operations are defined as farms that raise up to 5,000 turkey or 20,000 poultry of all species per year.  That certainly contrasts with Ontario, as well as every other province & territory in Canada where the mighty #ChickenMafia have a death grip on the throats of every Canadian; buy from the #ChickenMafia or die!

In Connecticut, if a small flock farmer wants to slaughter his own birds on-farm, then the Connecticut Department of Agriculture will inspect the on-farm slaughter facilities to the "Poultry Products Inspection Act ["PPIA"] and any applicable provision of the Code of Federal Regulations, including, but not limited to, any health, sanitary and safety related provision."

The Connecticut notice  states that:

"Participating facilities must have an approved plan for the disposal of liquid waste and an approved plan for the disposal of offal. The processor must have an approved water supply and test the water supply every six months, or, if operated seasonally, test the water supply no more than 30 days prior to the date processing starts. (Required water testing is not applicable to municipal water supplies.) Participants also must have an approved site bio-security protocol and have a written system of product labeling and record keeping facilitating product tracking and trace-back to the slaughter/process facility."

Seems like reasonable requirements to avoid complaints from neighbours, and from creating a food health hazard.

If you pass the State inspection, and you meet the exemptions from continuous USDA inspections during slaughter (per PPIA) , then your slaughter operation "shall be designated as approved food sources for household consumers, restaurants, hotels, and boarding houses."

That "approved food source" designation means no hassles from Public Health Inspectors who happen to see some of these products downstream in the food chain (eg. store shelves, restaurants, etc.).

The Connecticut note also states:

"The inspection follows the requirements of the PPIA, including an audit of the HACCP system and an evaluation of the sanitation, sanitary practices, food-handling equipment design and construction, handling of animals, record-keeping, and water supply."

OK, so you're a farmer raising poultry, and slaughtered your own birds for decades.  However, you're not familiar with government documents, or never heard of HACCP?

Again, no problem!  Connecticut has got you covered.  The State Ag Extension Office offers a safe poultry slaughter course to assist producers with designing and implementing a Hazard Analysis Critical Control Point (HACCP) system. A HACCP system is required under the PPIA and the Connecticut Small Poultry Processor Inspection Program.

Just to be sure that all State bureaucrats fully understand, the notice states: "Sales of poultry directly to the final consumer at the farm or at a farmer’s market via order are not affected by this program. Those producers who market directly to the final consumer are able to continue this practice."

What if a Connecticut farmer is too small or can't afford to run his own slaughter operation?

No problem!  Connecticut has thought of everything.

Connecticut is funding the designing and building a mobile poultry processing plant on wheels (ie. a highway transport trailer specially converted to a poultry abattoir) by the Connecticut Poultry Association ("CPA").  The CPA will identify two sites, one at the East and one at the West of Connecticut, where this mobile slaughter plant can be parked, and hooked up to local electrical and water supply.  The farmers bring their birds to this mobile site, the birds are processed, and the farmers return home with their birds ready for sale at their farm gate, Farmer's Markets, or at retail.

No fuss, no muss.

Even under-serviced areas and remote farms can get easily serviced by a poultry abattoir in CT.

Figure1:  Comparison of Connecticut USA to Ontario Canada

Is there a fair comparison between Connecticut and Ontario?  Let's see.

Ontario is about 64 times bigger on sq. km. basis that Connecticut ("CT"), and the dimensions are about 10.9 times greater on a geometric average of length and width.

On population, Ontario is 3.6 times bigger than CT.  However, population density of CT is 20.4 times bigger than ON.

With two mobile abattoir sites strategically located in CT, the farthest a farmer would have to drive would be 70 km., which seems reasonable.

Assuming the same sq. km per mobile site for Ontario, we would need 128 mobile site locations scattered throughout Ontario.

Assuming that the mobile abattoir crew would do all birds at a site in one day, a second day to clean up, and a third day on the road to travel to the next site & set up there, that is a 3 day cycle per site.

If farmers are doing the typical quota-based 6.5 poultry grow cycles per year, they will need the mobile abattoir to come by their area for each of those poultry grow cycles.  Therefore there are 6.5 cycles per year x 128 sites x 3 days/site= 2,496 days of work to be done in all of Ontario.  Assuming 350 work days per year for each mobile abattoir, we would therefore need 7 mobile abattoirs trailers for serving all of Ontario.

On a population basis, CT has one mobile abattoir for every 1.8 million people.  For a similar ratio, ON would need 7 mobile abattoirs to serve our 12.8 million population in Ontario.  Interesting that we get the same answer, no matter which way we calculate it!

So 7 mobile abattoirs for Ontario will do the trick.

Well, Premier Wynne, how soon do we get the Ontario Meat Regs. modified so it matches CT's new law?

When will OMAF's RED Rural Economic Development cheque for the 7 abattoir trailers be presented to newly formed regional CO-Op's who will be offered first opportunity to run these 7 mobile abattoirs?

How about putting out a RED Request for Proposals where any group can apply for a defined geographical region based on Census Divisions ("CD") and population with those chosen CD's which totals at least 5,000 sq. km. that they would service.

I suggest the following deal between OMAF and these 7 Co-Ops to be formed for managing the 7 abattoir trailers:

• OMAF will pay for the trailer plus some startup funding and personnel training for each regional trailer and all of the 18 or so sites that each trailer will service.
   
• In return, OMAF will get a share of the top-line gross revenue per bird processed until OMAF's costs are re-paid.
   
• After that, the Co-op that runs each trailer is on their own.
   
• If the Co-OP goes bankrupt, or fail to serve the area as promised, the trailer gets returned to OMAF, and a new RED Request for Proposal is advertised for that same CD district.

OMAF helps it get started, but it isn't a hand-out.

It's giving the farmers and the people of Ontario a temporary hand up.

I have already contacted the CT Poultry Association, asking for info on their mobile abattoir design.  I'll send you a copy when I get it, Premier Wynne.  Anything to help, eh?

*  *  *

P.S. A dip of the chicken wing to Dave & Brenda Linton who forwarded me the link to this interesting news item about the new law in Connecticut.  Thanks

We welcome all similar news items, rumors that need debunking, accolades, complaints, questions, etc. We're not proud, we'll take everything we can get.

Is it Tribunal Time?

I think it's time to go to the Tribunal for our complaint against Chicken Farmers of Ontario.

It was June 10, 2013 that I posted about our green light to proceed to the Tribunal (see Getting Ready: OMAF Tribunal Appeal).

Small Flockers believe that CFO has been mis-directed, incompetent, negligent, exceeded its authority, acted in bad faith, colluded, in conflict of interest, and deserving of a lump of coal from Santa Claus.

I have been slowly collecting the necessary points for our claims, evidence, and case law.  It is intended that most, if not all, of the 166 postings on this Blog will be included in our filings with the Tribunal as evidence in the appeal.  It is intended for us to request written answers from CFO for all of the issues that we have covered here.  During the hearing, it is assumed that CFO personnel will be available to defend their written answers and reply to all of the issues that we have raised on this Blog.

In Figure 1 is a map of the Supply Management system for chicken in Ontario.  We have used this as one of the tools to help build our case for the Tribunal.  Complicated, eh?  The more complicated it is, the more the eyeballs of citizens glaze over, and the #ChickenMafia is left alone to do as it pleases.  It a very standard ploy in systemic oppression.

Based on this map, I have most areas covered in my investigations and analysis of Supply Management for chicken in Ontario, and the rest of Canada.

Figure 1:  Map of the Supply Management Bureaucracy for Ontario

It should be an interesting Tribunal hearing.  I wonder how far the Commissioners will allow me to proceed?

No matter how they decide, if we are given a fair, just, and impartial hearing, and we get to present all of our evidence, and ask all of our questions, then we have done the best we can.

One thing that we didn't receive was a Whistleblower Insider from the #ChickenMafia.  I would have hoped that one of 1,114 members of the #ChickenMafia might have stepped forward, unable to stomach any more of the wrong-headed nonsense of CFO and Supply Management.

Nobody stepped forward.  What could that mean?

I think this Blog has repeatedly proven that there are significant problems in paradise.

Therefore, I can only assume that all the members of the #ChickenMafia are experiencing one or more of the following:

1. They are brain dead, as all thinking is done for them by the CFO Board;
2. Too busy with their selfish endeavors to concern themselves with the consequences they create for others;
3. Frozen in fear at what would be done to them if they broke rank and became a Whistleblower;
4. Apathetic and defeated blobs of primordial ooze that has insufficient backbone to oppose anybody, least of all fellow members of the #ChickenMafia, nor the all powerful CFO;
5. Up to their eyeballs in debt and other consequences, hoping that the whole system hangs together so they can continue to exist, rather than be swept away in the tide of change that they fear may soon arrive.

If a #ChickenMafia Whistleblower wants to step forward with some insider info, we're all ears.  You will be respected for your difficult decision, and your confidentiality will be protected.  Even if you just wanted to talk, or wanted to find out some info about Small Flockers, give us a call, or send us an email.  We have few secrets.  I would enjoy speaking with you.

If there is a lawyer, paralegal, or other talented person who is willing to assist our cause and the Tribunal, now is a great time to step forward.  You can volunteer anything from 15 minutes of your time, money, or suggestions.  We take anything, and will recognize and appreciate everything.

Getting Ready: OMAF Tribunal Appeal

Now that Ontario's FPMC (Farm Products Marketing Commission) has refused to intercede on the behalf of Small Flockers against Chicken Farmers of Ontario ("CFO"), our next course of action is to Ontario Ministry of Agriculture Appeals Tribunal ("OMAF Tribunal").

I sent an email to the Tribunal, asking a number of questions about this important next step.

I got a very nice response from them, very helpful, they answered each question in a straight forward manner.  I was impressed.  Well done to OMAF's Gloria Marco-borys and/or her team!

If the Tribunal operates as well as this initial response, there is hope for us yet.

My questions and OMAF's answers are here.

Meat Regulations Gone Wild

A few weeks ago, I received notice that OMAF (Ontario Ministry of Agriculture) was requesting feedback on some proposed changes to the Meat Regulations.  OMAF was putting on a road show where they were going to present the issues, and seek feedback from stakeholders and the public in general.

I couldn't believe my eyes.  I read the email again.  I immediately checked the OMAF website.  Sure enough, it was true.  They were even coming to hold a public meeting near me, just 300 km one-way for me to drive.  I figured it would be worth the $400 travel cost to meet these OMAF people face-to-face and hear what they had to say.  I immediately reserved myself a seat at the Sudbury meeting on May 7th, 2013 at 3:00 PM.

The Meat Regulations is one of the thorns sticking into my side as a Small Flocker.  Small Flocker's aren't the only ones.  Sustain Ontario has well documented other small businesses who have been closed, or made less profitable, or less competitive by regulations gone wild.  For example, read about Forsyth Farms and the $10,000 worth of meat pies that were thrown out because they were being sold wholesale instead of farm gate.  It isn't just an Ontario issue.  Governments across Canada, and around the world have regulation gone wild, same or worse than Ontario.

For example, I've heard that the EU has 35 different regulations that must be followed by any farmer who dares grow a carrot and try to sell it to a consumer.  Obviously, the EU feels growing carrots are often related to terrorism, and needs to be carefully controlled and monitored by the government.

I figured that none of the local media would know anything about this meeting, and it might be useful to have them there.  I tried to inform the local radio stations and newspapers about this meeting.   I tried to explain to the press why this meeting was important.

I attended the May 7th meeting in Sudbury.  Note that I am writing this Blog posting on May 12th.  After attending the Meat Regulation meeting, I thought I'd better calm down for 5 days, and gain some perspective before writing.  It would be better to write what I think and know, rather than what I felt.

I arrived 1.5 hrs early for the meeting, hoping to get some private two-way conversations with the OMAF people.  As I sat in the parking lot, I used my cell phone to re-call all of the local media and encourage them to come.   As I left a message on another voice mail about the OMAF meeting, I noticed a white mini-van enter the parking lot, with the Ontario insignia on the door; it was them.  I returned my attention to my phone message.  It seemed that I had started too late, and they were too busy with other priorities, so none of the press came.  Therefore, I may be one of the only places where you can get a first-hand account about these public meetings.

Inside at the meeting, OMAF has representatives from the whole chain of command.  I lost count of the OMAF people after 12.  There were so many OMAF people there, I wondered if they had left somebody behind to answer the phones while everybody else was at their roadshow.

I had a number of really good conversations with the OMAF people before the official meeting start.  I felt good about how they listened, then posed possible issues that might arise, to which I responded.

For the official meeting, OMAF started by explaining that the Meat Regulations had been in place since 2005, and a number of issues had been raised over the years.  OMAF felt there was a need to clarify and simplify the regulations.  OMAF also felt that the regulations had gone further than what is now seen as necessary, forcing too many businesses and products to become ensnared by the Meat Regulations.  They had a first draft for the proposed new regs, but still had some outstanding issues to be resolved, and wanted feedback before they went any further.

OMAF currently has 134 slaughter plants, and 350 stand-alone meat plants who are licensed in Ontario.  They would have had many, many more if OMAF had followed their crazy Meat Regs. to the letter of the law.  When they realized their mistake, the Minister set a new policy where OMAF decided that they wouldn't enforce that part of the regs, and wouldn't issue a license.  If they hadn't back tracked,  OMAF would have crushed the Ontario economy and the meat industry even worse than they do today.  I assume it wasn't easy for OMAF to partially admit its mistakes, so my thanks to OMAF for taking this difficult but necessary step for the good of Ontario.

As a representative for Small Flockers, I was ready to share my advice with them.  After 1.5 years of waiting,suffering their constant denial that any problems existed, and their stonewalling, OMAF was interested in making it better. Better late than never, I guess.  I took a sip of water and a deep breath to calm myself.

For some reason, OMAF felt a need to differentiate between meat products and food products.  To my understanding, both of these could be equally unsafe, regardless how much meat they contained.  OMAF wanted to retain responsibility for any products that contained 25% or more meat.  I asked why.

OMAF explained that they checked the US food database, and most products that they considered to be meat products had more than 25% meat, but most foods (ie. non-meat products were lass than that.  For example, most lasagna trays were 18% meat, so they would be under Health Dept. inspection, not OMAF.

So I asked OMAF, "What about somebody who wants to make a corned beef on rye sandwich, you know the really good ones with the corn beef piled high in the middle.  With two thin pieces of rye bread, I bet that would be more than 25% meat.  Are you telling me that OMAF wants you to have a Stand Alone Meat Plant License to make corned beef sandwiches that are sold in vending trucks, vending machines, and corner stores?  OMAF listened, acknowledged my comment, and wrote it down.  I may have just saved some poor schmuck from having his sandwich shop destroyed by the weight of government regulations.  This issue didn't help Small Flockers, but we all have to work together on this one.  Hopefully, our turn will soon come, and somebody else will step up to support Small Flockers too.

I also said that whether it's 25% or 18% or 95% meat, its seems somewhat arbitrary.  The main hazard is between farm and food.  If meat wants to cross the frontier between farm and food, that is where OMAF and the Meat Regulations need to focus their efforts.  Once farm meat is judged OK to be used as food, then whether it's meat or mayonnaise, it's all food.  All foods need to be handled properly, but the % meat in the food is a useless distinction.  OMAF scribbled some some in their binders.

OMAF mentioned that they wanted to reduce the number of people forced to have a meat plant license.  That's when the fireworks started.  Ken Hayden, in a neighbouring town to me, mentioned that OMAFRA told him in 2005 that his butcher shop would need a new Stand-Alone Meat Plant License.  Ken sold his house so that he could invest the $70,000 into modifications to his butcher shop so he could stay in business under the new Meat Regulations in 2005.  Here he is 7 years later, and OMAF is planning on changing the rules again, allowing anybody to directly compete against him, but their spared from having to make the same investment as what Ken was forced to make back in 2005.  That means Ken is at a cost disadvantage, and will be for some time into the future.  Was OMAF going to compensate him?  Three or fore OMAF people looked at each other, then they all turned to face Ken, and simultaneously said, "No".  Ken got upset, but he controlled himself very well.  No shots were fired.

A lady hooked into the meeting by conference call mentioned that when the new regs came out in 2005, many others closed their businesses, as they didn't have the money or the desire to invest it into their business.  She was one of the few who went forward, made the investment, and got the meat plant license.  She wanted to know if OMAF was going to compensate her.  "No", said OMAF.  There was silence on the other end of the phone line.

OMAF explained that making hamburger was seen by them as Class I (Low Risk), but making sausages was Class II (High Risk).  I couldn't let that one go by.  I asked OMAF on what basis they had decided what was high risk or low risk.  OMAF explained that smoking, and sausages, and marinating, and other similar special processes were considered as higher risk.  Ken, the butcher said he felt that anybody doing these special processes needed a meat plant license, just like him.  I said there are Red Seal Chefs who have studied for at least 4 years, who can chef anywhere in the world with their training, that these chefs would be prevented from making sausages or marinating in their restaurant or similar food establishment then selling some of their finest wares to customers to take home with them, or selling them wholesale?  It isn't just butchers and stand-alone meat plants who have the necessary skills and process areas to make safe foods, I said.  If it's safe to serve this as food in a restaurant, it's likely safe for you to buy it and take it home with you.  Look at the number of people poisoned by plain old hamburger, but you call it a low risk Class I process.  I question your risk assessments, I said.  OMAF scribbled some more into their binder.

OMAF mentioned that when they were developing their regulations, they considered the probability of occurrence, and severity of the impact on the public from the various risks.  I spoke up that those two factors are very important, but their is an equally important factor that also must be considered:   Detectability.  Some problems are easily spotted before the trap has been sprung, or can be seen as soon as they occur.  People can then respond readily to these risks.  However, there are some risks that cannot be easily seen until it's too late.  That is the reason I believe, OMAF needs to consider all three factors in their risk assessments.  I mentioned that all three of these were industry standard in FMEA (Failure Mode Effect Analysis) Risk Assessments.  OMAF took lots of notes.

At the end, I asked to come up to the front so I could make some additional comments to the whole group, as well as those on the conference call, so that OMAF wouldn't have  to repeat and paraphrase what I had said for the benefit of those on the remote link.  I told the group that 7.5% of Canadians can't afford the food they need for their families, that food bank usage is up 40% in the last 5 years, and that we are charged 3 times more for chicken in Canada than our American neighbours to the South.  Some of that can be blamed on the crazy Meat Regulations.  I said that Canada is in last place for exporting chicken by the OECD countries, our major trading partners and equivalents.  Canada has just 1.42% of that chicken export market.  We could produce 5 times as much chicken as we produce today if we had just 50% market share of these 7 OECD nations.  That could be done, but Ontario's current Meat Regulations are holding us back.  Currently, Ontario can't feed itself for chicken, for we have to import 35.6 million kg. of chicken each year, in part from Ontario's crazy regulations.

I suggested that Ontario's meat plants need to focus on feeding the people of Ontario, so that the Federal meat plants can focus on exporting Canadian food to feed the world.  To do that, Ontario's Meat Regulation needs to be significantly adjusted now so as to better prepare for this necessary future.

I told OMAF that Justice Haines had warned them about all of these problems and more.  OMAF had taken Justice Haines' advice in some areas, but ignored it in others.  Where OMAF ignored the advice, we suffer the consequences today.  For example, I said Justice Haines recommended OMAF to develop Food Safety Objectives.  I have asked to receive a copy of them.  As far as I know, they still don't exist, 8 years later.  To me, that isn't acceptable.  OMAF needs to do better.

The meeting went on and on, but I won't bore you with all the details.  In the end, I was impressed with the willingness of all the OMAF people to listen to their stakeholders.  I was impressed with the experience and skills of all the OMAF personnel who came to the meeting.  I thanked all OMAF people publicly for taking the time out of their busy days, and making the effort to drive all the way from Toronto to listen to our concerns at this Northern Ontario outpost.

I'm 59 this year.   This is probably the last, best hope of getting this Meat Regulation squared away during my lifetime.  I'm aiming to make it so.  We have until June 3, 2013 to put our comments forward.  You can see OMAF's Meat Regulation proposals here.

You can sign the Small Flocker petition here

You can call your MPP and tell them what you think.

I'm trying to make it better.  Small Flockers need your help.  We can't do it without public support.  Will you set aside your personal priorities for 5 minutes to help yourself, help your neighbours, help everybody in Canada get better, more efffective regulations for their meat supply?

Please say yes.

Ontario's Abattoirs

I created a Google fusion table and map, available here:   https://www.google.com/fusiontables/DataSource?docid=1xf2Da0uX2g7_-UFHlD6iZppX_oBShoFmKgL6Ue0

The above link takes you to a Google Fusion Table that I created from OMAFRA's website, mapping OMAF's data showing all Ontario licensed abattoirs.  Well done to OMAF for providing public access to these data in a form that can be readily analyzed.  Many thanks to Google for providing free use for the mapping of this public data.

Map of OMAF data for Ontario licensed abattoirs

After clicking on the above Google link, your browser window will show you OMAFRA's Excel spreadsheet data as I uploaded it into a Google Fusion Table.  Starting from the top left of your screen, the third line from the top, click:  Visualize --> Map and you get this:

There is another list of Federally inspected abattoirs in Ontario, but that data isn't easily available.  I have requested this data from CFIA, but it hasn't arrived yet.

It should be noted that some of these abattoirs do not do custom processing of poultry (ie. they only slaughter for themselves, and will not do poultry that belongs to other individuals).  That is the case for Burt's Farms abattoir on Manitoulin Island, where I happen to live.  In 2011-2012, OMAF helped to build a community abattoir in Providence Bay at a price somewhere near $2 million, but this abattoir decided not to process poultry.

Should OMAF require a comprehensive needs assessment be done before agreeing to fund community abattoirs? Did that occur in my case, and others?  If yes, why and I left stranded?

For me, the closest poultry abattoir that does custom processing for chicken farmers is in Sudbury, 300 km away (1-way distance).  I would have to drive there with my birds, and return will a cooler full of meat to sell at my farm gate.  Driving that distance would add about $3.00 per pound to the cost of my small farm chicken, doubling the retail price I'd have to charge.

It would appear that Southern Ontario is well covered with abattoirs, but there are many holes in Bracebridge/Bancroft/Haliburtin/Perth area, and even worse in Northern Ontario and the Hudson-James Bay area.

Does the Ontario government believe there is nobody living in these under-serviced areas, or that they are all vegetarians?

As far as I know, all of these abattoirs are privately owned and operated, so the government must act indirectly.

Could the government not help facilitate and encourage local farmers and/or citizens to find a solution that could work for them?  Need we rely on trucks, trains, and planes to bring food to the people from elsewhere?

Will OMAF help these under-serviced areas with portable abattoirs?

Will OMAF encourage and assist a reasonable solution for meat processing in remote communities without driving our provincial deficit into outer space?

Only time will tell.