1. Why does anyone need government approval to grow their own food?
I also do not believe in Salvation through Legislation. I am an adult, or supposed to be, and am responsible for my safety, success or failure. I do not need the government to write laws to protect me from myself.
2. Why is this even an issue?
According to the City of Tucson, last year the number of animal complaints about "small farm animals" was around .003% of complaints received by the City and County Animal Control.
Better yet, why has the City devoted 5 years to this when there are much more pressing issues like fixing our roads which are in worse condition than some war torn, 3rd World Countries, worrying about our declining water supply as they are preparing to approve a toilet to tap initiative next year and a myriad of other issues plaguing our city.
3. The Animal Units in the Proposal.
The way the authors came up with the Animal Units (AU) in the proposal is a hodgepodge from various sources. It took the BLM/EPA pasture grazing standard of 2 Animal Units per 1000 sq. feet and applied it to the allowed AU per residence. But instead of continuing to follow the BLM/EPA AU equivalents in the table to the right. They contrived their own AU equivalents (found below) with this explanation: "The new rules were developed by the city with significant input from the Food Bank, the Extension Service (Collegte of Ag) , the College of Public Health, and many local people who are knowledgeable. They are not perfect"
Also the AU are cumulative, meaning that if you have 3.3 acres or more you get 48 AU to divide anyway you see fit. You can 48 hens, which do not require 3.3 acres. You can have 2 miniature dairy goats, because they need companionship, but you can not have an intact male to get your doe pregnant to produce the dairy (seems like a whole other problem right there!) and 38 hens or 2 miniature goats, 2 turkeys (one for Thanksgiving and Christmas) and 30 hens.
But what if, you have hens and are selling the eggs at the local Farmer's Market and it's year 3. You have your 48 hens but need to get replacement pullets which won't lay until 6 months. Do I have to cull my entire current flock? Do those pullets count toward my 48 AU? That is going to depend on the Animal COntrol Officer when they arrive at your place to do an inspection.
How does the Animal Control Officer even get involved? Well, a nasty neighbor can turn you in or you could have a noise complaint brought against you. The penalties for violating this are pretty steep too- $1500 and/or 6 months in jail.
4. Other issues I have with the proposal.
There are also provisions to request a Variance (which require permits, fees and red tape) to get a Setback Relief from the proposal or to increase the number of allowable number of animals or to get your property rezoned.
I will continue to voice my concerns when the Proposal is presented to Mayor and Council. If you live in Tucson, I urge you to read the City's Urban Ag Proposal and get involved!