16, 2005: Ruth and Denny Noel have agriculture degrees
from Texas A & M, but no degree--except perhaps one in
regulatory bureaucracy--could have prepared them for building
an on-farm poultry processing facility and commercial kitchen.
As Ruth described it at the Texas Organic Farming and Gardening
Association's 4th annual conference, building the facilities
for their fledgling grass-fed poultry business required a
lot of sweat equity and do-it-yourself ingenuity. Then came
the hard part -- breaking through the red tape of state and
local government regulations that keeps so many small farmers
Ultimately, the Noels built a state-certified meat processing
facility and commercial kitchen for less than $10,000. In
less than two years, they were processing up to 800 broilers
a month, and had created such a strong demand at farmers markets
and restaurants that they couldn't keep up with it. Indeed,
interest in what they accomplished was so strong and the maze
of licensing and code requirements so confusing that Ruth
has nearly completed a how-to book to save others from the
headaches they experienced.
"We couldn't believe what we accomplished," she
says. "We had no one to guide us and there are so many
farmers who want to do this but there is so much government
intervention. What we found out is that anybody really can
do it and it doesn't have to cost a fortune."
Gradual diversification; then going
Twelve years ago, the Noels bought 23 acres about an hour
south of Austin. Despite the credentials to call themselves
"Aggies," the Texas A & M graduates had no farming
experience. Ruth's childhood passion for outdoors and taking
care of small creatures only intensified after college. Denny,
who worked in the industrial equipment industry, was a handyman
eager to apply his carpentry skills to creating their dream
-- Tesoro Tierra Farms.
They built their house and barn mostly by themselves, and
gradually added livestock -- grass-fed cattle, hogs, chickens
and goats -- primarily for themselves and their friends. Three
years ago, despite having two young children to home school,
they decided to incorporate and create a full-time pastured
poultry business. Having an on-farm processing facility would
allow them to cut out the middleman and sell directly to farmers
markets and restaurants at premium retail prices. A commercial
kitchen would allow them to expand their markets by selling
roasted birds, as well.
"It took off faster than we ever
expected . . . When everything suddenly kicks in and you
can start doing all this stuff, it can be overwhelming."
"It took off faster than we ever expected, especially
after Denny lost his job -- that was something we hadn't figured
into the plan," she says. "When everything suddenly
kicks in and you can start doing all this stuff, it can be
Putting most of their eggs in the processing basket was a
big risk, but they were determined to make that basket as
cheaply as possible. There was just one problem. They knew
no one who owned a state-certified production facility, much
less a small, do-it-yourself kind. And the advice they received
from state and local inspection officials could be confusing
"When we first started, everyone was so vague because
no one was doing what we were doing and no one wanted to be
liable," Ruth explains. "We heard everything. Some
said you couldn't do a processing facility even if you were
processing for someone else because that was considered customer
processing. Others said we could only sell on-farm and not
at farmers markets."
Fortunately, they met a state meat inspector who helped them
map out the shortest route through the regulatory maze. "He
saw the need for a small local facility and really led us
through all the different steps and procedures -- what to
say on the paperwork, who was responsible for what and in
what order," she explains. "You've got to understand
the different jurisdictions and the retail food hierarchy
and you have to break it down."
As they quickly learned, a processing facility required one
set of permits while a commercial kitchen required another
set. Which ones you need depend on what county you live in
and where you do business.
In Texas, the state's meat safety assurance division oversees
meat processing facilities. Most commercial chicken processing
facilities are high-output operations that must follow strict
safety standards and a rigorous inspection process. Small,
community-based processing facilities have become few and
far between; too much competition and too many regulatory
hoops discourage most small farmers from trying. And yet,
as the Noels learned, there are exemptions that make it feasible.
Facilities with less than 10,000 birds a year, for example,
aren't required to have on-site inspectors to check each bird.
The Noels also learned that they could get exemptions for
handling effluent and waste by draining water back into the
pastures and composting chicken remains rather than rendering
"You've got to understand the
different jurisdictions and the retail food hierarchy
and you have to break it down."
Meeting certification and inspection standards for both the
slaughtering facility and the kitchen were just half the battle.
Individual inspectors interpreted each jurisdiction's requirements
differently. For example, one inspector told them it was against
the law for a farmer to sell meat at a farmers market in his
"I told him I was already doing it, and he said I must
be doing it under the table," Ruth recalls. "I called
his office the next day and another inspector answered and
confirmed that I could sell it. I don't know if he was new
or just didn't know, but I was so mad I decided I needed to
build a commercial kitchen, too."
A commercial kitchen, however, would require them to pursue
another set of permits that relate to manufactured foods and
Adding to the confusion, inspectors seemed to be arbitrary
about what they focused on. Because they were selling at two
different places in Austin, they were required to have duplicate
permits. "The inspector yelled at me right in front of
my customers," Ruth recalls. "He didn't check the
temperature of my coolers or anything. He just wanted to see
that piece of paper."
Selling the dressed chickens in surrounding counties was
just as confusing. Because the Noels' county has no health
department, they had to get a permit through the state. In
nearby Travis County, the county's food licensing permit covered
the city of Austin as well. But that wasn't the case two counties
over, which Ruth learned the hard way when they tried to sell
at a farmers market in the tourist town of Wimberly.
Building up the system -- from chicks to
Based on their research and local customer preference, the
Noels stayed away from heritage breeds (too many people believed
their meat was tough, Ruth noted). Instead, they chose the
fast-growing White Cornish Cross broilers, the industry standard
meat bird that averages about 3.5 pounds by seven weeks.
They also selected the grass-fed model, using a mobile coop
system popularized by Joel Salatin in his 1993 book, Pastured
Poultry Profits. Denny built the mobile coops himself
out of rebar instead of plastic pipes. The sturdiness allowed
him to build them larger and withstand the daily rotations
in the pastures. To accommodate the hot summers of central
Texas, he built them taller than typical designs for the North,
wrapping the hoops in chicken wire and covering the tops with
plastic. Plastic skirts on the sides could be lowered during
bad weather while an 80 percent shade cloth covering the roof
protected them during the hot season.
Each of the seven hoop houses could hold up to 150 full-grown
chickens, which resulted in a peak stocking rate of about
one square foot per bird at full maturity. A brooder trailer
wrapped in metal and outfitted with a ramp was a big labor-saver
for raising the chicks until they were big enough to transfer
to the mobile coops at about three weeks.
The birds were rotated on about four acres of pasture planted
in a mixture of bahia and Bermuda grass. In late fall they
also planted winter rye. The hoops, which measured 20 feet
long and 12 feet wide, were attached with skids instead of
wheels. Once a day, they were moved with a tractor another
20 feet so the chickens had access to fresh grass daily. Each
section of grass fully recovers in about three to four weeks
during the growing season, and their cattle feed on the lush
grass that comes up through the chicken manure. The coops
aren't returned to the same area for at least three months.
The Noels supplemented their birds with feed rations twice
a day. They switched from an expensive national brand and
made their own ration after Ruth got help from a nutritionist
and found she could purchase the same essential minerals locally
and much cheaper.
"We went round and round on the feed ration but at $35
for 60 pounds of supplement, we had to find something more
economical," she says.
Ruth designed the 12 by 16 foot processing facility on her
home computer, and Denny went to work building -- a cement
foundation with proper drainage, metal roof, and wooden frame.
State codes required separate rooms for slaughter and cleaning.
They were constantly looking for ways to cut costs—from
small items, such as using orange highway markers as killing
cones, to converting a washing machine into a plucker and
buying a sink from Habitat for Humanity. Ventilation and lighting
requirements were easy to meet (they installed window-unit
air-conditioning but no heating.) Although in retrospect the
facility was too small, it was built for under $3,000, equipment
Keeping track of all the sanitation steps required an elaborate
checklist -- from sterilizing knives (they used standard restaurant
ones) to cleaning drainage mats. Workers couldn't eat or smoke
in the facility and had to wear head covers and smocks.
"The killing room is unpleasant, blood and mess everywhere,"
she said. "But it worked remarkably well."
Disposing of innards, legs, feathers and other unused parts
requires expensive rendering facilities at big commercial
processing plants. Here, they simply carried offal buckets
out to large, fenced-in compost piles and mixed them with
moldy hay. The state also approved their system for draining
processing water into a nearby pasture.
Hitting their stride, then a bad spell…
At the peak of their business, the Noels were processing
800 chickens a month. Their main customers were restaurants
and farmers markets in Austin, where they were charging up
to $2.50 a pound. They were so busy that they never had time
to start roasting the chickens in their kitchen. "We
took the birds to the farmers markets and it worked incredibly
well," she says. "The demand was greater than we
could keep up with."
Unfortunately, so was the work.
After getting hit with a wave of bad luck, the Noels decided
to scale back late last year. Ruth's father, who lives with
them, fell ill and had to be hospitalized. Denny needed surgery
for a double hernia. A death in the family and multiple bouts
of flu were enough to force them to stop and consider their
options. For the first time, their farming business had broken
even (annual sales included about 6,000 broilers, 4,000 dozen
eggs, 100 turkeys, and 40 head of cattle) but the pressures
of farming and caring for family weren't sustainable.
"We took the birds to the farmers
markets and it worked incredibly well. The demand was
greater than we could keep up with."
"Our biggest mistake is we didn't have enough operating
capital," Ruth says. "We really needed at least
one full-time employee."
Neither she nor her husband regrets their attempts to battle
government bureaucracy. Just proving that a small farmer can
raise, kill, and sell broilers themselves -- and do it legally
-- was a major accomplishment in itself. "Anybody can
do it," Ruth says. "People say the government won't
let them, but I came to realize that the government isn't
Steve Bridges, president of the Texas Organic Farmers and
Gardeners Association, invited Ruth to speak at the TOFGA
conference this year because the Noels showed that this gap
in local poultry production could be filled.
"Their ability to get this processing facility built
and licensed was remarkable and something we wanted to share,"
This month, the Noels have put their farm up for lease and
are moving to nearby San Marcos to regroup and simplify their
lives. "We'll be getting back to farming when our kids
are older and the timing is right. This isn't over. We love
farming too much."