 Good morning everybody. It is Thursday morning. And we have members and guests from rural Vermont, along with members from the ag agency as well as this is a joint committee. And the Senate Ag committee. So it's great to see so many of you on zoom. It's been working quite well. You know, no different has been to the last two years except for now and the House committee is also in Montpelier. And I'd like to have our, this is in regard the whole meeting is in regards to on farm slaughter. And so Carolyn would, would you like to introduce your members that are in the room and then I'll introduce ours and we'll get started with the meeting. Okay, well, thanks Bobby. I really appreciate everybody being here today with this hot topic that is a concern for all of us in the room. We have representative Tom Bach and Chester representative Terry Norris from showroom. And I'm Carolyn Partridge from the town of Wyndham. Heather supernaught is stuck in the mud in Barnard. She has a little tile. And I think some of our other members, John O'Brien, Ricky strong and Henry curl, as well as Rodney Graham are going to be kind of dribbling in as they make it over the icy roads. I've heard that they're terrible. So, and anyway, we're pleased to be here today. And Bobby, thanks so much for giving us an opportunity to introduce ourselves. Yeah, thank you Caroline. And we have Brian, Senator Brian column work from Rotland in the room. Senator Corey parent in the room, Anthony Polina. He's on the opposite end of a mud road. And so he is an end but on zoom. And Chris Pearson should be joining us in a moment or two. And I'm Senator Bobby star from Troy. We also have Linda Lehman who works for both committees with us as well as Michael. Oh, Drady our chief legislative council person with us. And I don't know if we also have on zoom. Julie Bobear. And I think is Steve with us. And Steve Collier from the agency of that. And to start with, we have one question for the ad agency. And Steve, I don't know if you want to answer the question. Or if Julie does, but the one question is, has anything changed with the on farm slaughter rules and regulations in the last couple of years. Good morning, Senator star Steve Collier from the agency of the on farm slaughter and thank you for having us. The short answer is no. It hasn't changed. He'll hear. Now we know that the rules in the reds have not changed in the propaganda that some of us have been hearing. I would say is propaganda. Michael, did you have anything? Do you mean from FSIS? Yes, or the Ag agents. Oh, okay. I don't have anything. I think basically what you're saying is that there's no official opinion on the change of interpretation from FSIS. Yes. So you don't know of any. Yeah. I have not seen anything official. Yeah. So folks, I don't know if. So I'm wanting to get that on the table early on. So that we don't run astray of what we're trying to achieve. Yeah. So that is clarity and a clear direction for you folks that do on farm slaughter. And, you know, let's try to use that time positive. And if you have suggestions that would help you and we can achieve that, you know, we just want to be able to allow you folks to function in a, you know, easy, peaceful, humane way to supply beat to our people of Vermont. So Caroline, would you like to lead off and introduce your guests as we, as you want to call on them? Thank you so much. Thank you. So good morning, both committees and every, everyone joining us here today. I'm Caroline Gordon, legislative director with rule of Vermont. I will not walk through our lineup in this very moment. I'm happy to pass the mic as we go. I kind of wanted to just set the stage today with presenting a sign on letter that we submitted to the committees today. And I'm happy to share with you what we've been doing for the last month since we heard what we receive as new policies from our state agency of agriculture. So I'm just taking a minute to read that here to set the stage. We received to that letter over 152 signatures. And when I'm done, I'll pass it on to our legislative intern, Elena Roig, who will read for you some written testimonials on this letter. Dear legislators, a community of small scale farmers who struggle to find nearby meat processing facilities that meet their needs and who decided it would be best for the animals to be slaughtered on the farm where they were raised, need your support. On from slaughter is being penalized with new restrictions that the Vermont agency of agriculture, food and markets announced January 6th, 2022 as coming from the superseding federal agency, the Food Safety Inspection Service FSIS. These new restrictions now require every livestock owner who purchased the animal from a farmer for its slaughter on the farm to be at least present during the act of slaughter, if not engaging also in the slaughter themselves. In testimony, BAFM staff further stated that farmers who organize on from slaughter would not be allowed to hire itinerant slaughterers on behalf of the owners of the livestock they raise. Finally, BAFM penalizes those who demand local meat and direct relationship to their farmer by stating in testimony to the House Agriculture and Forestry Committee that the agency would understand the owners and not farmers need to be the ones to transport the carcass off the farm and to the butcher. Sincerely, would you have the skill, vehicle and machinery to transport a quarter of a cow? We have not seen any of these restrictions in writing coming from FSIS in guidance, nor can we find related provisions in state or federal law. Rue Vermont members of the agricultural community have successfully advocated for over a decade to improve Vermont state law through the democratic process just to find these laws not implemented, supported or yet even promoted by our state agency. In consequence, many practitioners remain confused about the legalities of on-farm slaughter and rather continue to operate under the radar. We are grateful for the legislators of the Senate Committee on Agriculture Support and reaching out to FSIS via letter from January 31st, 2022 stating, there's no reference in the FSIS guidance to a requirement that all owners be physically present at the site of the slaughter. And frankly, we do not know if this requirement is documented anywhere. Signatories kindly ask legislators to consider the urgency that farmers face now that spring is here and a new generation of livestock sold for being slaughtered on the farm where they were raised is being born without the confidence that BAFM will not enforce against their practice without sufficient legal basis. These farmers might lose their good standing with the agency and thus access to any future state support for their agricultural practices. After the legislature allowed for multiple owners per animal slaughter in 2019, repealed the sunset of 6VSA section 3311A and increased the allowances for on-farm slaughter in 2021 to now 10 cattle, 30 swine or 80 sheep or goats, we now ask to repeal the registration and reporting requirements for farmers who organize on-farm slaughter in 6VSA section 3311A subsection C2 and 8. While we desire BAFM to promote on-farm slaughter in Vermont, this measure appears urgently needed to protect practitioners now. So with that, we're here today to share what is the status quo of on-farm slaughter and how these new policies penalize practitioners. I want to add that we question it being in the discretion of the administration of the law to render the same impractical or sheer unrealizable. To add another layer of complexity, I also want to bring to the committee's attention that farmers have extreme difficulty to find insurance companies that support them, given the confusion and irregularities around this issue. And with that, I pass it on to Elena. Thank you, Caroline, and good morning, everyone. My name is Elena Royk. I'm the legislative intern with rural Vermont. And like Caroline said, we distributed that sign-on letter and in that sign-on letter, we gave folks a space to provide a testimonial on how restrictions to on-farm slaughter impact them personally. So when I compiled this document that we've shared with you, when I compiled it yesterday, there were just under 100 written testimonials provided that amounted to about nine pages as of this morning that has grown to over 100 testimonials. So I just wanted to share that it was about a 60-40 split of farmers to 40% of the signatories were farmers, 60% were anybody who kind of didn't identify themselves in that type of way. So consumers and the like. So I just wanted to share a few of these testimonies with you just to kind of give some of these perspectives, give you guys the opportunity to hear some additional perspectives. So from an anonymous farmer, as a new and growing livestock farm, we would like to be able to confidently offer on-farm slaughter as an option to consumers. The logistical challenges and marketing slash consumer education needed with the current changes essentially mean that on-farm slaughter would be very difficult to incorporate as a viable business option, leaving us to struggle to find slaughter dates, stress our animals with transportation, and lose the flexibility and control that on-farm slaughter allows over the process. From another anonymous farmer, we exclusively use on-farm slaughter to process our animals. We would have to stop producing meat for our customers. Another anonymous farmer, we raise and process many animals on-farm. This would greatly impact our ability to remain in the process. From another farmer, our pork has always been humanely slaughtered on-farm and transported cleanly by our butcher back to his facility for custom cutting. Our customers have no desire to be part of the slaughter process and are not equipped to transport whole hogs from the farm to a butcher shop for cutting and wrapping. For this reason, we have decided after 17 years of producing pasture raised organically fed pork to our farmers. Our customers are devastated. They either cannot get pork from any of the other operations we have referred them to or are choosing not to because they value the stress-free option of on-farm slaughter for the animals. From another farmer, as a farmer directly helping feed our community, it is very challenging to secure USDA slaughter dates if not impossible in many cases. This year we were able to only find 80% of the slaughter spots we need and will be required to truck animals two hours to the slaughterhouse. We also have many community members who seek out meat from on-farm slaughtered animals for both animal welfare and affordability reasons, and we would like to be able to support their needs and wishes. From direct experience, I can say confidently that on-farm slaughter can provide the highest animal welfare value and food safety. I also don't believe legislation should be used to make any choices. From a farmer in Derby, I currently sell half and whole beef animals to individuals as well as for home use. Depending on availability, I use both a slaughterhouse or on-farm slaughter. I can never get enough space at one of the slaughter facilities I use, so having this flexibility means that I can better serve my customers and can use several different cutting facilities that don't offer slaughter. We currently use on-farm slaughter to provide meat to our family and shareholders. Local slaughterhouses are full. We can't get on their list. The animals that we slaughter are far less stressed because there is no transport. Animals that are not used to transport get highly stressed when transported, and then they're stressed at the slaughterhouse facility. Our animals are not stressed ever in this way. If we can't do on-farm slaughter, we would stop raising sheep. We would wrap it up with a testimonial from a custom butcher. I am trained as a butcher and have worked exclusively in small shops that specialize in ethical butchery. I have seen firsthand the care that small farmers and individual homesteaders take with their animals, and I'm also intimately familiar with the cost and burden of having to transport livestock to a slaughter facility, especially for small farmers. Vermont has an incredible history of reverence with quality meat. On-farm slaughter is an important part of that care and reverence, not to mention that it increases the quality of the meat that we consume. Less travel means a calmer animal, which means less adrenaline and cortisol release, which in turn results in higher quality meat. With a looming climate crisis, it is important that Vermont continues to lead the way in cherishing practices that divest from reliance on national agro business and instead invest in local care and practices. That's why we're here today. We're going to talk a little bit about the millennials that we received in our sign-on letter. Like I said, there were well over 100 as of this morning, and I appreciate the time to get to share some of those with you. Thank you. Thank you, Elena. And you know, it's a joint effort of rural Vermont and NOFA of Vermont to organize these small farm action days. Hello, everyone. I'd like to just thank everybody at the outset for their time today. It's always great to get a chance to meet with both committees, bring farmers voices directly into the conversation. As Karen mentioned, this is the second of our sort of joint small farm action day series that we put on with rural Vermont. And we look forward to seeing everybody get in April for the final. When Maddie Kempner, our policy director is going to talk about this. My name is Bill Kavanaugh. I'm a farm business advisor with NOFA Vermont. Before coming to NOFA, I worked for over a decade in the meat industry. I do still work part-time as a custom butcher as well as I teach the meat cutting classes at Vermont Tech. I look at this from a lot of perspectives, but I am wearing my NOFA hat today. I want to say at the outset, I've worked really closely with the Vermont community partners in ensuring reliable safe meat is available to all Vermonters. That said, the inspection team is beholden to sort of implement the letter of the law and to maintain equal to status in regards to federal meat regulations. So there's kind of a tension there. So we really strongly support whatever can be done legislatively to support Vermont's farm slaughter. In my work, I'm really fortunate to work very closely with businesses in Vermont's meat sector across the entire spectrum of scale. I work with farmers all the way up to the largest slaughter and processing facilities in the state. I see firsthand that farm slaughter is hugely important not just for farmers who sell their meat that way, and it is hugely important for them, but also for the entire meat supply chain as a whole. I don't think I need to tell anybody here today that there's a pretty major bottleneck that exists in slaughter and processing here in Vermont. There are plenty of people really hard to find a way to sell their meat without having to go to a commercial slaughterhouse. Without a viable option to sell farm slaughtered and custom-butchered meat, these farms will be forced into the queue at Vermont's slaughterhouses which will further exacerbate a tenuous situation. Farms that don't even engage in farm slaughter will lose slaughter spots that have increased weight times, and those farms that do practice farm slaughter could affect their business. There's a knock-on effect when we restrict the ability to slaughter on farm and sell that meat, not just for those particular farms who are affected, but for the entire supply chain. That's the effect on farmers. For consumers of locally produced meat, they're going to lose out as well. One of the traditions that we hold so dear in Vermont is being able to know your farmer and be able to go through a large commercial facility. In Vermont, commercial slaughter facilities do a great job, and there are many consumers who that's how they purchase their meat, but many don't. They want to sort of be able to know their farmer directly, know the animal directly, and know that it didn't have the stress of a transport or having to go through a large commercial facility. So we feel that with diminished market share and consumers of locally raised meat, we'll have less options. Again, sort of that knock-on effect on consumers of, you know, they were able to sort of purchase more locally and with a farmer that they know well, and now they're into a much larger sort of retail environment. So it's our position that without reliable access to on-farm slaughter as an option, small farmers are going to see increased market share. So we really encourage whatever can be done from the legislator's end up to and including, you know, repealing the registration reporting requirements for on-farm slaughter, but that's it. I just wanted to give my perspective, and I appreciate everybody's time. Thank you so much. Thank you, Bill. Yeah, much appreciated, Bill. We want to hear from Mary Lake, who's been with us in testimony many, many times over the decade. Mary, we're excited to hear from you today as well. Hi, I'm really happy to be here. I've been in the meat industry for about 12 years now and started out at a USDA plant. And gathered a lot, gathered my skills there and a lot of knowledge about how we can make efficiencies and inefficiencies and how we can make our Vermont ag community and meat production better and what we can do for that. So what I do now after leaving the inspected plant is I have been doing on-farm slaughter as an itinerant for the past few years and I've built a business doing this in accordance with the allowances and the regulations and have shared and encouraged many struggling farms to use on-farm slaughter to stay in the meat business. With that bottleneck that we talked about and COVID causing many shortages, many slaughterhouses are full and some are not taking sheep and goats at all. I think a lot of you know I also work pretty closely with the Vermont sheep and goat association and I'm a lamb producer myself so I really focused on the impact of all of this on sheep and goats. So what we're seeing now is just like kind of decreasing capacity at slaughterhouses in an increase in demand for meat so the increased demand for local meat kind of stems from COVID and for this trend to continue meat producers really need processing options like OFS on-farm slaughter and what makes on-farm slaughter viable is the relationship that the farmer has with the consumers or the animal owners and the relationship that the farmer has with the itinerant slaughterer. So farmers hire me or hire itinerant slaughterers to come to the farm and perform the act of slaughter and the itinerant slaughterers have skills that have taken a lot of time and experience to acquire and the skills make on-farm slaughter safer and efficient and therefore really viable. So the system is working really well for the most part for farmers and consumers and their animals and new policies would impact the system negatively by creating inefficiencies with the profit margins being so slim that could really lead to a weekend agricultural system in the loss of some small farms. I've had many farmers tell me well as a sheepherd and as a itinerant slaughterer if we didn't have you we wouldn't be able to have a sheep farm and so when policy seems to get threatened I get really nervous and for my own business but also for the 300 plus farms that I go to for shearing and some of those also deal on-farm slaughter. So some of the benefits of working with an itinerant slaughterer are that the farmer gets to see the slaughter it would be super efficient to have or inefficient to have the owners all there seeing it and it wouldn't be as beneficial to them but having but organizing everything with the farmer has a lot of benefits that that help make their farms more efficient and more knowledgeable about what they're creating. So if you think about when a farmer gets to see the slaughter or be a part of the slaughter they are being like scientists and there's like all these little tips that we look at or all these signs that we look at and things that we measure to know how our animals are doing and to know how to move forward with our own farm practices and on-farm slaughter helps a lot with that especially when you have an itinerant slaughterer there who kind of sees lots of animals from all over every day and I just fear that new policies would really lead to farmers not being able to create the best food possible for their communities we would really see a loss and that's what I'm most afraid of. Thank you Mary Mary did you say you cover 300 farms or did you go to 300 farms or did I hear that wrong? Not for on-farm slaughter so my farm business is mostly shearing and the on-farm slaughter aspect of my business has grown a lot in the past couple of years so when I'm out shearing you know these are all sheep farms we are also talking about their animals and their farm management and what they do for slaughter and what they do for meat production so even if I'm not doing on-farm slaughter for them we're talking about other options and who their local like to slaughter would be and on-farm slaughter has been such a great option for sheep and goat producers I don't know exactly how many farms I go to for on-farm slaughter but it's not 300 it's more like 100 or less Thank you Mary and now we want to hear from a sheep farmer who is practicing on-farm slaughter so we have Kirk Patterson here with us today from Shincracker Icelandic sheep farm in Harckland for a month Hi that's who I am although it's Peter's son Mary by the way I really appreciated hearing from because she is an angel for sheep farmers all over the state without her I don't know if the industry would survive anyway we sell about a dozen to 15 lamb shares a year they're registered purebred Icelandic sheep our customers come back every year and they know exactly how our process works we sell them the lamb it's theirs from the start and we raise it for them as their agent we make sure that they have fresh water good beautiful Vermont grass to eat they get veterinary care when they need it they're protected from predators and parasites as best we can and then we hire on behalf of the owner of the farm he's a different slaughterer who is very experienced and he even insists on killing the sheep out of the sight of the other sheep so that they're not stressed out in any way he then we transport for the owner the lambs to a clean butcher shop where they are cut up wrapped labeled shrink wrapped labeled and hard frozen and then we bring them back to the farm put them in our freezer and the owner comes and picks up his or her sheep the best lamb they've ever eaten is what they all say without an exception and I can tell you that the methods that we use are used on our behalf and on the owner's behalf are humane it's not one of these big operations where the calves or the lambs are bunched up together and raised for muscle mass it's clean because we're right there making sure that it's clean and the butcher shops that we have used have been very clean produces safe food for the people who buy it and frankly it's financially necessary to raise sheep I'm to quote my father-in-law late father-in-law the object in raising sheep is not to make money it's to lose the least amount of money you have to so the margin as Mary said are very slim and it's someone told me the other day that he plays music at the Harpoon Brewery to support his sheep habit and that's pretty much the way it is it's worked so well for a number of years and as I've dug through pounds and pounds of materials on the subject my question is who gains by the changes that are in the wind certainly big egg is not going to be affected by whether or not small farmers in Vermont use on farm slaughter they are land buyers are getting safe clean food that's really cared for people who worry about animals are seeing meat produced in the most humane way and enable small farmers to exist with or without profit and I just don't understand what the driving force is for any of these suggested changes none of them have any logical sense and thank you for listening to me rant thank you sir how many years have you been doing this eight sir thank you any problems problems what kind of problems sir I guess you haven't had any so that's good well no raising big sheep is an honor yeah thank you Caroline awesome yeah thanks Kurt and we also have Brandon bless from bread and butter farm with us today to speak to the issue hi everyone my name is Brandon bless and I'm an animal manager I've been in butter farm in Vermont thanks I'd really just like to a lot of the points that we already made so I was just picking up where Kurt left off there I think what is the benefit and what is the sense of when they know I'm slaughtering this way I understand food safety is a principal matter but as we're describing this year Caroline consumers are Brandon there's a little bit disturbing noise wind and such in your microphone any chance you can protect your phone a little better yeah is that better much better yeah I just picking up where Kurt left off there I think that I really distressed that point of what's the benefit here and I think back to Bobby star your original comment of let's speak positively and creatively I think the positive and creative approach is how do we do on farm slaughter as well as we possibly can for the farm community we're in the consumer community that this is a real demand that we experience on our farm and we cannot serve or satisfy because of the way that the current legislation and regulation is particularly being a quote-unquote higher profile farm it's really hard to fly under the radar as many other farms do and I think a lot of potential changes or limitations in the regulation and or legislation of slaughter is just going to return us to where we kind of began which is a lot of it going on just totally unregulated and under the radar which you know I guess there's pros and cons to that but yeah just to Kurt's point that I just don't see the benefit of further limiting or stressing this community that is already under quite a lot of stress when I say this community and sort of combining the on farm slot or offering farmer community as well as you know really master cast people like Mary you know this is a really hard time for everyone and even just getting slaughter spots with USDA facility is pretty much impossible right now so to just take something that is kind of the best thing that we have on the table to take that off the table or to further limit that I think is exactly the wrong direction does not a positive approach that Bobby Star let us with there I also want to just pick up on a couple other points so I think just back to Caroline in the beginning you know this has been quite a journey and I think what I've seen in my limited time being involved is positive progression and positive movement it's been for me as a farmer excruciating slow but it's been positive and I think this is I'm identifying this as a huge step backwards what we're talking about today and I think that that again that trajectory it just doesn't make sense there's not a logic to it or rationale in my mind I think I can understand sort of the federal that Bill picked up on sort of the federal versus state push and pull there and needing to reconcile that so I'd be really eager to see and participate in a really positive proactive approach that engages the federal government and policy on that level so that we can move into a better and more positive place while right here right now we take a stand to actually protect our itinerant slaughter and former and consumer community and I think you know if consumers are making these conscious choices about their own food and their food safety and where their food is coming from I don't see a need or rationale for regulation or legislation to stand between you know it's a really short chain from that animal to that consumer in this case so we don't see a need to stand in the way there I like Bill's point also about how do we maybe make the current legislation a little bit more approachable and easy and easy for others to engage and anything that we can do here and now to sort of at least even if it's minor work to sort of soften what the legislation or regulation is doing within the community so Bill pointed out sort of the registration requirements and either removing or softening those or I've said in the past if there's a way to just make that a lot easier for farmers to engage with it's not always the easiest process to register and report I think that's all I have thanks Thank you Brandon Yeah good to hear from you and then I'm not sure we have also a couple of customers I found from slaughter lined up here and next on my list would be Connie Gunter and I'm not sure of who we have on the display here as Daphne might be actually the tile for Connie so Connie are you on the call here just testing and if not then we just you know if Connie joins as we go then let me know otherwise we'll move on to Ali Berlo Hello Good morning My name is Ali Berlo thank you I want to say first of all thank you for your discussion I live in Putney on the unceded lands of the Abenaki people which is a matter of historical record and I consider myself extremely lucky to be a neighbor to a small sheep farm boondoggle farm where Katie Wolf raises a flock of fin sheep a heritage breed I'm here today to testify and to state unequivocally that I support the repeal of the registration and report requirements for farmers who practice on farm slaughter I'm here to bear witness that me and my family would be adversely affected if on farm slaughter were to become unavailable to Vermont farmers please allow me the time to say why thank you I'm an eater who has actively supported small medium size family farms and fisheries since the early 2000s I'm a writer I've written about food and food systems for close to 20 years via public radio community radio and magazines I founded a sustainable ag non-profit island grown initiative I have authored two books published by story publishing on these issues and experiences the food activist handbook in 2015 and in 2013 the mobile poultry slaughterhouse building a humane chicken processing unit to strengthen your local food system to which my friend Temple Granden wrote the forward I also have a master of food and agriculture law and policy from Vermont law school class of 2020 let me be clear I'm not a farmer nor will I become a farmer I consider myself an advocate for food sovereignty and food access I consider my health and well-being inextricably linked to the economic health and well-being of small and mid-sized farmers in Vermont in my opinion unfarmed slaughter here in Vermont provides access to safe humane clean traceable size appropriate infrastructure that meets small families needs that is otherwise unavailable to these farmers because of limited access to brick and mortar slaughterhouses which is one of the consequences of the national and international corporate consolidation of livestock and meat production and as COVID has proven and continues to do so in the breakdown of food supply chains local and regional brick and mortar slaughterhouses are booked to capacity for months and sometimes years and often miles away creating yet another barrier to farmers long expensive and stressful travel as has been stated clearly by farmers here the transportation of livestock causes stress on live animals and results in a diminished quality of both life and death and the number of people who are involved in the development of end product itinerant slaughters like Mary Lake are highly skilled professionals they do jobs that frankly most of us do not want to do nor do we know how to do if you've been to a slaughter you probably experienced some level of discomfort and a reckoning if you're a farmer or a witness or participated in an accident it is important to make sure that your life is calm prevails humans and animals are safe livestock are treated humanely and with dignity the farm is quiet ready and prepared it has potable water access to hot water and refrigeration appropriate composting at the ready and a safe setup for the itinerant slaughter all these things are important it's quite a logistical feat for a farmer to raise both animals and provide a safe environment in which to slaughter them however, if owners the citizen eaters of animal shares for unfarmed slaughter are required to organize unfarmed slaughter events and are also required to be present for unfarmed slaughter days what was calm preparedness immediately transforms into unnecessary chaotic logistical nightmare with so many more moving parts and more human beings who are probably mostly untrained than necessary and most importantly it sets up an illogical double standard that goes against a farm safety biosecurity, liability animal and food safety and data protection for the private customer moreover people these regular customers slash eaters like me be required to witness and participate in slaughter and processing activities to take days off from work school or their families one, two, possibly three days in a row depending on the number of animals what about traffic boondoggle farm, my neighbor we live up a pretty decent hill and off a dead-end dirt road which most vehicles are not suited for what about parking bathrooms, shoes people tracking unknown biological materials people bring dogs to farms even though it's a really bad idea and what about proper refrigeration and transportation I repeat this is burdensome and nonsensical reckless and unsubstantiated in my opinion however the benefits of unfarmed slaughter are that it provides the shortest food chain supply possible resulting in the most transparency possible this is safety contained during covid we all experienced and continue to experience a breakdown of big ag meat supply chains big as temple granden will say is fragile if we've learned anything from covid's rampage through our international and national supply chains is that local and regional supply chains are nimble and responsive they are much more transparent and hence arguably safer the new restrictions from the Vermont agency of agriculture food and markets threaten farmers livelihoods and way of life they also threaten me the eater's choice and right to purchase the food they want here's a cautionary statement when you turn a blind eye to unfarmed slaughter and or make punitive or burdensome requirements upon the farmer I argue that you the legislators are perpetuating and supporting an unfarmed meat system please do not look away because the topic of slaughter isn't of itself challenging punitive requirements for farmers and their customers also threatens in my opinion Vermont's very own public outward facing persona and trusted brand of Vermont made or Vermont grown because when you take away or threaten the small and mid-sized farmers of Vermont's ability to do business there's no more there there the same lurid brand as these farmers are threatened and continue to be frankly betrayed by an agency that purportedly is there to support them as they have been burdened with regulations and interpretations of said regulations that have no basis in reality that this brand this Vermont brand is left as a hollowed out shell a greenwashing PR campaign for corporations and their lobbyists like Unilever, Tyson, Cargill So I asked, as an eater, why is there this relationship of intimidation, of deaf ear, of burdensome and random requirements, determined to penalize eaters and farmers between the agency and the people? It seems to me this relationship is damaged and fractured and an imbalance of power yielded, unsubstantiated. However, if and when you the state work with transparency, with a real and true understanding of what small and mid-sized Vermont farmers and itinerant slaughterers do and the issues they face on the ground when it comes to raising, slaughtering, and processing livestock, then together, the Vermont Agency of Agriculture, Food, and Markets, including its bureaucrats, and all the eaters, including all the farmers, can work towards a common, scaled, reasonable goals and outcomes. In closing, I reiterate, I'm here to testify and to state unequivocally that I support the repeal of the registration and report requirements for slaughter. I'm here to bear witness that me, my family, and the state of Vermont and the Vermont farmers would be adversely affected if on farm slaughter were to become unavailable. Thank you. Thank you, Allie. Caroline? Yeah, thank you, Allie. That was really powerful. And we're almost through with our list and agenda for the event. We have two more Vermont family members, so to speak. Celine DeSousses is a farm business planner for the Center for Agricultural Economy, but for full disclosure, Celine is also a Vermont board member, and we're excited to hear from you today, Celine. Thanks, Caroline. Yeah, I work, my name is Celine. I work as a farm business planner for the Center for Agricultural Economy over in Hardwick, so maybe also adding a perspective from some more northern, northeastern farms. So a large portion of my clients are dairy farms under 100 cows, both conventional and organic. And I see on farm slaughter as an essential piece in the puzzle of farm profitability, farm community, and a real local food system where real locals, especially up here, can consume local meat. On farm slaughter is an option that many farmers choose to procure to procure local meat that they themselves can afford to eat, which is becoming harder and harder. I don't know if you guys know what the beef price is now, but I've had a lot of my clients be like, I don't think we can afford to eat our beef anymore. You know, if it would be processed through USDA, the prices are high, and it's just kind of a tough time. It's a good time for selling, but a tough time for eating it yourselves. So on farm slaughter is a way to procure meat that the farmers can afford to eat to provide an affordable purchasing option for their neighbors and for their employees to buy meat off the hook and stock their freezers. Most of the farms that I work with are the scale of dairy that is quickly disappearing from the landscape because it is incredibly difficult with conventional or organic prices to cashflow a farm with 50 cows or even 100 cows. It's hard to do. I see the finances every day and I know that it's very tight. So the ones that are still making it and exist and still exist have to be very creative, honestly. And maybe they don't cashflow on paper, but they make it work in other ways. And one of the ways is on farm slaughter. On farm slaughter is one of the ways that makes these farms work because it provides an alternative income stream. It provides a way to decrease their own family living expenses, which is big. You know, most of these farmers are not taking, they're not on payroll. So the only money they have to live is what's left over at the end of the year. They're not getting paid a salary. So they're able to decrease their own living expenses by utilizing their own farm source food. And it's a way to decrease overall cash output to processing, which is expensive. On farm slaughter additionally provides an option that takes much less of the farmer time in terms of loading and transporting animals, not to mention the difficulty of scheduling USDA slaughter slots within a busy farming schedule with very, very limited labor. You know, these farmers are milking, you know, taking care of animals, haying, doing the books, they're already incredibly diversified. So to add more roles, you know, anything to streamline this process is helpful to them and helpful to their bottom line. Any further restrictions on farm, on farm slaughter legislation would negatively impact these farms that already have the odds stacked very much against them. And I have also worked with one, I worked with a couple itinerant slaughters up here, but one more extensively. And I have a couple fun numbers for you. So he has his client list is massive. So he works with well over 100 small and homestead scale farms, but also over 40 CSFO or larger farms just last year. And that's like this is just a like I'm sure there's more that's kind of like what I have written down. And so last season, he processed around 500 large animals that would have required USDA slaughter slots otherwise. So that's, that's a massive impact in itself. So just based on that scale of farms, that should show you the importance of this work in our farming community, the importance in state in on farm slaughters impact on state meat processing infrastructure, and overall it has an incredible and massive impact on our overall working landscape. So thank you. Thank you so much. And you have one more. Right. We want to wrap it up with our policy director, Graham, and I just move from now, take it away. Good morning, Graham. Buddy, thank you committee. And I also want to say really thank you to everybody who's kind of testified before me today, those who are farming livestock from farm slaughter, those offering slaughter and processing services and those supporting those doing those that work like Celine here. I think it's important to say that these are essential tasks and relationships related to food security, food sovereignty, cultural preservation. We hear from a number of folks practicing halal slaughter who need this allowance, farm and small business viability and climate change resilience. We've talked today about how this work is being threatened now by FSIS and the agency of agriculture. And I intend to suggest to you some immediate steps, proactive steps we can take to halt such interpretations and enforcement, which will cause widespread, substantial and imminent harm. And I seek today to communicate to you and put for the record some of this widespread and imminent harm, which is being threatened, which we will seek through lawsuit to to cease and desist to the state of Vermont refuses to do so. So the ongoing release of new interpretations, their ambiguity and contradictory nature with no sign dated written documentation justifying any of it is not tenable. It is not equitable. And it's not just for the people being regulated. And it will cause significant damaging impacts. The most recent FSIS memo, which hasn't actually been talked about today goes even more extreme than we've heard from VAFM. Two of the notes say that the personal use exemption requires all owners to be individuals who are involved in the raising of the animal. And the second thing, which is I think deeply troubling is that there is no provision in the statute or regulations allowing the use of third party itinerant slaughters under the personal use exemption. So make no mistake, itinerant slaughters operate under the personal use exemption and custom processors, farms and consumers rely upon them and have for generations. So what what would this mean? So I spoke with a couple of custom processors this last week and some itinerant slaughters. So I recently spoke with a custom processor. There are about 40 custom packing plants in the state registered in the state, at least 15 to 20. I think they have to have to look at list myself are, you know, somewhat similar to this one. This this facility processes 15 to 20 beef a week during the busy season and 20 or more pigs on that's in the fall mostly. This individual processed over 200,000 pounds of cut meat last year and about the same the year before. They do not take animals from people who do it themselves, except a few special cases. So this whole thing about owners, you need to participate in the slaughter and not being allowed to hire itinerant slaughters custom processors mostly will only work with itinerant slaughters. They provide them almost all of their business. This is an undercount this person suggested. He said that it's so much easier if the farmer calls him to help arrange than the itinerant slaughter can call to arrange the drop off as well. He talked about how much easier it is if the itinerant slaughter can deliver the carcass already can be there already communicating and keep them on the schedule. They said that more itinerant slaughters are asking their clients to deliver to me to the processor and this is becoming more challenging from the time perspective but also a contamination perspective. So, you know, this specific directive we know that it doesn't actually relate well to food safety in and of itself. So let's say if there were only 15 custom processors doing this number of cattle and pigs again that doesn't even consider the lamb and goat and other animals which we know are harder to find spaces for at USDA inspected processors but also many custom processing facilities and also certainly a number of itinerant slaughters I spoke into don't actually process lamb or goat anymore. But this would be over three million pounds. So I extracted these numbers to 15 facilities. There'll be over three million pounds of processed meat more than 7,800 pigs annually, 7,800 cattle annually and that's based at 10 pigs a week for facility or 10 cattle a week for facility. Those are just estimates. I'm not saying they're necessarily right but that's just to give you some idea of the overall numbers based on that one business and even if they're not necessarily accurate based on seasonality the overall poundage is an annual number that that person was tracking. So I didn't have to extract anything from a seasonal perspective there. And as Celine and others were saying it is highly likely that most of this meat stays extremely local feeding local people who need that affordable meat. This process just said that most all of this business is through itinerant slaughters. So we can estimate that most all these animals in this process meat is reliant upon those folks. So we do not know the total number of itinerant slaughters in Vermont. So we can't necessarily estimate the extent of the harm done by these interpretations being offered. But one I spoke to this last week and Celine just offered some numbers that are well beyond what I'm suggesting here. I believe this person only slaughters on weekends. He said his numbers are down and he slaughtered 250 pigs in 100 cattle maybe last year and again there's no sheep, goat, alpacas anything else included in this person's repertoire. He does not understand how itinerant slaughters or custom processors would stay in business if these interpretations were accepted. So I am also a farmer. I raise grass fed beef cattle. I have had itinerant slaughters on my farms or farms I have managed for pigs, cattle and poultry. As a beef farmer I can speak to how requiring myself or an owner of the animal once I sell to them live to slaughter that steer on farm without the help of a trained professional would absolutely not be in the interest of food safety or general farm safety or a personal well-being. These are very large animals. This is a very skilled craft. That's not to suggest that people shouldn't be able to and encouraged to study and practice slaughter themselves but it is to say that requiring people who otherwise do not have the skills or interest but who want to raise livestock to feed themselves or others does not make any sense. I will also say that I use a USDA inspected processor slaughterhouse and I was called the day prior to six of my beef being shipped last year to say that they couldn't take them. It took three weeks for me to get five of them in and it took months to get that last one in. So I do not understand how these facilities are in a position to take on thousands of more animals leaving slaughter every year especially if they're not even taking sheep and goats, many of them. So another thing that Roland has been doing has been offering educational courses to the community partnering with Mary Lake and other farms, bringing farmers to DOC this to be able to learn about it and we won't even actually be able to offer these educational courses in the community anymore if farmers aren't allowed to hire their partner and slaughterers under the personal use exemption. So their community members won't even be allowed to learn about this in person. So when we talk about essential skills we have to also talk about the cultural preservation of them and the need for them to be distributed and dispersed throughout our communities in order to do so. So I think lastly I would say these interpretations do not protect food safety or food security they threaten and compromise both from acquiring owners to participate in the slaughter and to not hire our tenor slaughterers or requiring them to transport carcassists themselves. If you talk with custom processors, our tenor slaughterers or farmers are owners you will understand this. This will also exacerbate problems and eliminate opportunities cited in Vermont's strategic agricultural plan as Kurt says who gains. During the pandemic nearly one-third of Vermonters faced food insecurity. Current USDA slaughter and processing facilities and state inspected slaughter facilities cannot meet the current demand. They are very hard to access for smaller producers and particular producers of small luminance and they certainly cannot meet this increased demand where tenor and slaughterers and custom processors no longer able to operate. This will result in immediate and direct harm to farms, tenor and slaughterers, custom processors and all Vermonters who rely on the meat business and other things provided for by these people. So rural Vermont is encouraging the state of Vermont, these committees, the attorney general's office, the federal delegation to do everything in their power to challenge FSIS to justify their new interpretations of the law and prevent the imminent and widespread harm that would be caused where this interpretation to be implemented. And remember this is not just in Vermont this is all across the country FSIS interpretations are relevant. If the immediate in the immediate and more controllable moment we cannot require farmers to register for a practice with an agency which refuses to follow the law in relationship to the practice and which has threatened to enforce these FSIS interpretations which testimony today has shown will cause imminent harm. The Vermont agency of agriculture is a partner in its oversight of the facilities they have authority over. But they are overstepping their authority here and they have let it be known that they are willing to be complicit to this harm even though it is beholden even though they are beholden to enforcing Vermont law and they are not willing to step up to defend Vermont's law and Vermont's residents businesses and food security either. I'll do that to be AFM. We need their support here and the farmers and custom processors 19 or enslaughters need their support here and standing out for the law that they are obligated to be implementing. Thank you. I believe that's all I have to offer today. Thank you so much, Graham. And dear committees, before we really wrap it up, I also want to give Katie Wolf a chance to offer some of her reflections of the event. Katie has been taking out of her busy schedule time this morning to support one of her customers, Ali Berlow, who you had the opportunity listening to her her passionate testimony just a few minutes ago. So Katie, if you have anything to add for us today, so from Boondago Farm, then we'd be excited to hear a couple words from you as well. I'm sure. Thank you, Caroline. And thank you everyone for granting time for these testimonies and for everyone who is testifying here. I concur with much of what has been said, so I don't want to repeat it, but maybe only add a couple of things from my own perspective. I've been raising sheep and goats for about 10 years and took animals to a slaughterhouse once and then found Mary Lake and have been working with Mary ever since. I can't express fully the value added to the Vermont community of having this practice of on-farm slaughter. I have probably 30 customers that share lambs that are slaughtered on my farm and many of them do come and visit and are curious about the process and learning more about this aspect of the food system and Vermont farming. So there's just a huge benefit, I think, to the community. I, as a farmer, as Mary alluded to, have learned so much about rotational grazing, about the health of my animals, from being there and seeing the animals essentially opened up in front of me on behalf of my customers. It's been a tremendous educational experience for me that I have been able to share with other aspiring farmers and without that opportunity, it all happens behind closed doors and we are further disconnected from not just our food system but also the welfare of our animals and of the land here in Vermont. My customers would not come, many of them, to the farm to do this as others have alluded to and finally there are just two other points. Part of putting together some semblance of financial sustainability for a small sheep and goat farmer for me is the processing of their hides and when you use a slaughterhouse you can't always be sure that you're going to get your hides in a timely fashion to get them salted and cured and preserved so that they can in fact be tanned. It's a it's a major revenue stream for me. When we practice on farm slaughter I'm able to take the hide as soon as Mary removes it, salt it immediately and it becomes again a value-added thing that I'm able to offer to customers and to create a revenue stream and I know a lot of small sheep farmers in Vermont use this as well. Finally, I just want to point out my own confusion about the inconsistencies of the recent modification made when the law was sunsetting and the number of animals was increased from the allowance for personal use exemption was increased from 40 small ruminants to 80. That act seemed to me to be a demonstration of support of this practice but the subsequent requirements that those customers be present as others have elaborated on seems really inconsistent with that increase. I don't understand how any one farm could use no matter how large your family is 80 sheep in the course of a year for your own personal use and nor could or does it make sense for 80 farmers to come 80 customers to come to the farm. So it just it seems to me like there there's an effort in this legislation to possibly increase food security and safety which as others have described it doesn't really work that way but the the laws being changed it doesn't achieve that goal so I'm confused as to what we are trying to achieve. If it's food safety and security there are other ways to to achieve that. If it's restricting small farms as many others have said to what end is that and you know I'd be happy to describe further how the process works but I think others have made it clear and I'm appreciative that this is being considered. I can say absolutely that if these restrictions were enforced I would not be able to continue doing what I'm doing. I already cover my costs and and really don't pay myself to do this work. It's it's more of a community service and a it's a way of life for many small farms and it takes a lot and every bit to cobble together any semblance of financial sustainability. So thank you for considering writing the legislation so that it actually works. Thank you. Thank you Katie. We we have about 10 minutes left before we have to go and visit the house on on hiring new judges or or sustaining new judges. So as Steve Collier now he answered the very the very first question of the morning was to Steven in regards to has the law changed in the last few years and I think he said no if I still remember right. So Steven's got his hand up and I'd like to he sat through and listened to the whole issue and he's the attorney at the agency of that. So Steven you have your hand up and so we'll call on you to see what you have to say. Well thank you Senator Starr. I very much appreciate that. I'd like to thank everyone for all sharing all of their thoughts. I'd like to try to clarify a few things if I can. First is we do support on farm slaughter. We very much support the viability of small farms. This is not that issue at all that there is a very important legal issue which I'd like you to think about because I'm worried about where this is all going in terms of trying to challenge the current law because the current law all of the arguments you make are persuasive. They're all persuasive policy arguments but I just want to explain the legal framework a little bit and that is that federal law dictates meat sales in this country. It's as you all know we have our agency has a cooperative agreement with the federal government so that we can also administer a state inspected program. Our program has to be equal to the federal program or we can't have it and I think one thing that maybe confuses this issue and why there's so much misinformation about it is everybody characterizes this as on farm slaughter. On farm slaughter does not exist in federal law. There is something and on top of that itinerant slaughters do not exist in federal law. There is a personal use exemption which is a very old statute poorly written and talks it's in the singular and it talks about men only because that's how statutes were written at that time. I don't know exactly when it was adopted but it's probably over a hundred years ago and it allows farmers to slaughter their own animals and keep those animals within the household that's all it does. It just allows people who raise their animals to slaughter them and eat them and they can also share those with their non-paying guests and employees so it's a household exemption. That's the law. FSIS has extended in my opinion the interpretation of that law through guidance which does allow for people to buy an animal from a farmer and slaughter it and I think it allows for multiple people to do that. About in 2013 before the itinerant slaughterer statute in Vermont law was passed we also Kathy McNamara from our meat inspection division was in contact with Phil Durfler who's from USDA and he wrote a letter saying that we could have this itinerant slaughterer provision in state law that he thought it was consistent with federal law the personal use exemption but when everyone makes all of these very strong policy arguments about not wanting the individual owners who buy the animal to be involved in the slaughter we understand that we know that people don't want to be involved in slaughter we know people don't want to be on the farm but when you do that you're writing the personal out of the personal exemption the whole exemption is for people to be able to raise animals and slaughter them there is nothing in that exemption for farmers to be able to raise animals slaughter them and sell the meat that's actually indirect contra contradiction of federal law which requires that when you sell meat it has to be inspected now there are many viable paths in my opinion one is right now and this is what I'm worried about is I'm worried we're going to push USDA to get rid of getting rid of the itinerant slaughter they don't like it there's nothing in federal law that allows it we have one letter from 2013 that says we can do it we want to continue doing it but I am concerned that if we push too hard on this issue and USDA is looking at its statute and looking at its need to be consistent around the country that it's going to backtrack off that and the reason I'm concerned is that guidance memo which I don't know who put out in the public but we never have received that from FSIS that's not something they've communicated to us the information we have from FSIS is that we can continue with the itinerant slaughter program until we hear otherwise that's what we're going to do so just keep in mind when you when all these policy arguments are terrific but look at the law look at the regulation there is nothing about on farm slaughter there is nothing about itinerant slaughterers there is just a personal use exemption so what I think about is the law and our requirement to maintain equality with the federal law we are we are doing that right now people can still absolutely in Vermont hire an itinerant slaughterer they can still absolutely do that there is a requirement and this gets back to the personal that the individuals the owners of the animal actually be involved in the slaughter none of us like it no it's not that we want this it's what the law requires and what FSIS is requiring so yes there is a requirement that if you are going to slaughter your own animal you have some involvement you have to be present that's the best we could get out of FSIS you don't have to you don't have to be involved in the in the slaughter itself there is some reason for that the reason I think the reason there is a personal use exemption is so that you are assuming the risk of what you eat when you take the owner out of that act you no longer know how the slaughter was performed you no longer know whether there was adulteration you don't know anything about it so you're no longer an owner slaughtering your own animal you're a person buying meat and so that is the the issue so that's one thing is people can just be there and I know that's unpleasant people don't want to be there whether or not they have to watch it I don't know whether that's the law or not FSIS said they have to be present I think I personally think that if an owner is there inspects the site knows what it's like can evaluate whether or not it's clean and then doesn't want to watch the actual slaughter that that probably suffices because you're at least there you know what happened you can talk to the itinerant slaughter you have some information about the conditions that it occurred and I think you can probably still fit within the personal use exemption that way another option is this is I mean what FSIS thinks is this is custom slaughter when you have somebody who is slaughtering an animal you can do that for them and you can deliver it to the owner you just can't deliver it to people who are not the owners so another option is that itinerant slaughters I know this is expensive but either the farms who raise the the beef could be a custom slaughter or the or any of the animals or an itinerant slaughter could potentially be a custom slaughter there is another method and we are trying to work on that I think Julie has registered Julie Bovair our division chief I think she's registered 14 more custom slaughters in the last year if I remember that number correctly can I ask a follow-up question student just because in the sake of time before you start with the custom slaughter issue we're just really not the issue here today just a follow-up question we're really missing in all these agency communications some substantial statements about the legality or in legality of our state law so I have two questions the first one is our is Vermont Agency of Agriculture administering state law or federal law or both and the second question would be in administering our state law what is a substantiated statement from the agency about the legality or in legality of what we do have in state law and if you think what we have in state law what we've passed over the last decade and advocacy which is what our producers are orienting themselves after they are the most the most the more specific law is what we are governed by that is our state law and that's what producer orient themselves after if the Vermont Agency of Agriculture thinks what we haven't state law and including the institution of itinerant slaughters is is substantially contrary to federal law how can answer that question how can state agency of agriculture last year support and promote and even suggest the repeal of the sunset on the law why wouldn't you let its sunset if you think what we have in state law is contrary to federal law that's the question so I just want to finish what I was saying so the third thing that we can do is change the federal law the federal law right now is written by congress as you know the regulation uses the same language as in the federal law that if that law is changed then the contours for the personal use exemption can can change the fourth thing you can do and people make these judgments all the day is violate the law none of us want that we don't we want everyone to be operating within the contours we don't write the laws we are required to enforce them back to caroline's question that one of the things that's so troubling about this is there are viable paths but misinformation keeps getting sort of pumped out there to taint the ability to construe what the viable paths are we will work with anyone who wants to work with us to make it as clear as possible exactly what is allowed and what's not allowed under the personal use exemption or the custom use exemption or if somebody wants to go to clarify the misinformation you keep referring to because that's a pretty offensive statement given all this information you've been you've been putting out there with no signed dated documentation and the enforcement you're threatening well graham I I don't know what enforcement we're threatening and I don't know what the memo that I think you're referring to was something that was shared with the congressional delegation it's not something that we put out there it's not something we've even received officially that's the best we have right now is it it's not well we're not following that so if that's the best we have I mean we are not relying on that memo because we have a relationship with FSIS we have communicated with FSIS we talked to them last spring and against this fall and again this last fall in an effort to try to expand the existing allowances under the personal exemption that the initial request was can we do a csa like animal share herd program and so we talked to them about that and they said no but we'll keep talking to you and so then we started talking about the personal exemption and we were asking if it's really necessary for individual owners who buy an animal to be present because we were hoping it wouldn't be necessary they said this is the law we do require you to be there and they also raised the issue of the itinerant slaughter and said you know we don't even think you can do this and we reminded them of the letter that they shared with us in 2013 from their deputy administrator saying that we can so back to Carolyn's question we think right now Vermont law is compatible with federal law which is the key we believe that their itinerant slaughter law that was passed back in 2013 and has been amended somewhat since then is in compliance with federal law but our only reliance on that is a memo from FSIS that they sent to us back in 2013 there's nothing in my opinion whatsoever in the federal statute or in the federal regulation that says anything about itinerant slaughters that suggests that anybody can hire someone else to do the slaughter it's all about personal use so we keep trying to push the boundaries of what personal use is essentially we're trying to write personal out of it and I understand that for all of the great policy arguments that everyone said but we don't get to interpret that we don't get to apply it we get to communicate with the feds and they determine whether we're doing it right or not so all we're trying to do is make sure that we comply with federal law or if somebody wants to change federal law you know that's a great option but that's not something that that we can do so I know I've talked a long time sorry I just I wish that anyone who wants to know how to do this lawfully would just call us because there are lawful ways there are ways that we can't allow we don't get to decide what those ways are we only get to tell you what they are so that we can work with you to make sure you can stay within the framework none of us wants to limit any farmer from doing anything but we do want to make sure that people are doing it lawfully because we don't want to have to enforce we don't want to have to take any action we just want to make sure understand people understand what they can and can't do and then we hope people will choose to to stay within what they can do because we don't ever want to have to tell someone what you did is wrong but sometimes we have to so thank you all for for listening thank you Steve and as I started the meeting off you know we've been we've been running on I call it propaganda stories that people have have told us that aren't exactly accurate and and that's what we found out and that you know yesterday we went through the law our rules and our regs found out they hadn't been changed or there's no process in the works to change them and you know that's why we wanted to have this meeting with all you folks to kind of clear the air a little bit and try to figure out if we can alter our Vermont law that would be allowable so that it would make it one one issue that is not in our rules or regs or our law is that to allow you folks to hire an agent to work on your behalf uh to get the animal slaughtered we that is not in our rules or regs and we've been thinking about ways of trying to incorporate that so that if you didn't want to be there you could hire an agent and it seems like that would make the most sense because then the agent could arrange the our tenor slaughter and the butcher that's going to cut the meat up for you because you can't have that sitting around for two weeks waiting for a butcher and a freezer ready to put the meat in so but you know we've got a ways to go and we're going to be around here for another five or six weeks so I think we would you know we'll be able to talk to you folks and others in regards to that issue but we federal law will supersede state law any day of the week in regards to food safety and and especially meat and and you know we can push the law but we don't want to cross the line and get into uh totally against the law so that's where we are the bell is ringing on our end uh but I want to ask any of the committee members do you have any questions or anything you'd like to add no carol bobby bobby well i have carol it um i would just like to um say and this comes from somebody who has been raising um sheep for 45 years excuse me i would like to learn more about what this would mean to you know and i'm a strong supporter of uh on farm slaughter but i would like to know what it would mean to us if we were to lose our equal to status and i don't think we can handle that today but this is something i would like to be um hearing about from steve and julie in the coming days so um i think that's really important for all of us to understand and with that i want to thank you for coming today and to i think this has been really helpful to uh understand the situation so thank you yeah well thanks a lot to all of you for your time this morning and and hey call the agency and push them on what you'd like to do and see if there's a way that that they work out something with you if if not get to us and we can you know we write the law so but i told you what we were thinking about and working on so we'll leave it at that and um thank you again very much for your