June 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 from trying.
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 whole
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 overwhelming."
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 and contradictory.
"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
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 them.
"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 county.
"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
A commercial kitchen, however, would require them to pursue another
set of permits that relate to manufactured foods and retail sales.
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 drumsticks
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
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,"
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
"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 the enemy."
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," he says.
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."