To the editor:
It is at once astonishing and horrifying that city council at Saturday’s public hearing may confer a special use permit for a slaughterhouse, not only within the city limits, but within yards of multiple animal care businesses.
The proposed activity, to be conducted on Colvin Street, is completely inconsistent with applicable law and with existing permitted uses. The proposal is not consistent with the city’s industrial classification.
The staff report reveals numerous highly material, substantive inconsistencies. Delivery hours, waste and other key conditions are completely contradictory and grossly incomplete. And the planning commission’s hasty consent disregarded numerous material inconsistencies in the application and related materials. The no-discussion “consent agenda” treatment also disregarded multiple statements of public opposition that were not even noted in the record. In fact, the public videotape of the meeting demonstrates that the planning commission initially attempted to grant the SUP without even conducting a vote.
The SUP is completely inconsistent with existing lawful land uses. The facility site lies within several hundred feet of multiple different animal care facilities and businesses, including one that is directly across the street. Those businesses cannot possibly be expected to operate in the shadow of a slaughter facility.
If city council grants this SUP, then council is effectively shutting those businesses down. Even if those businesses continue to operate, the city has failed to consider potential animal disease vectors presented by the close proximity of an animal storage and slaughter-waste facility to household pet care facilities. The city staff report reflects no research, review or even passive observation of current, proximate, lawful uses of very closely adjacent premises. The documentation reflects no contact with or notice to those premises or their occupants.
For the first time, the city is now considering the industrial zoning classification to include animal slaughter facilities. This determination is unlawful. The industrial classification permits certain animal care facilities (see Zoning Ordinance Sec. 4-1201 et seq.) but does not allow for animal slaughter or related facilities.
In fact, Zoning Ordinance Sec. 4-1204 expressly provides that “Any use which is not a permitted, special or accessory use pursuant to this section 4-1200 is prohibited.” The P&Z consent agenda vote gave no notice of, and was legally insufficient to accomplish, a radical revision to city law of the nature that this SUP application proposes. Under Code of Virginia Title 15.2 Ch. 22 Art. 1 and Art. 7, dramatically modifying legal definitions and uses cannot be accomplished by a mere variance. Instead, a conforming special exception would be required.
The city was required, prior to even considering the conferral of the requested SUP, to deliver multiple forms of formal, advance notice, which the staff report does not reflect, and which are inconsistent with the informal “consent agenda” treatment of the SUP application. Proximate land owners are required to receive contemporaneous advance notice. They did not and have advised city council that they would have opposed the matter before the planning commission if given the opportunity.
The SUP applicant’s commitments, the staff’s report and the recommended SUP conditions are not consistent. The application and the city’s staff report all claim inconsistent live animal delivery and trash removal frequency. The SUP application asks for a 90 minute per day delivery window; the staff report proposes up to 17 hours per day.
The SUP applicant’s binding, written commitments include daily waste collection by a waste hauler with no operations anywhere near Alexandria. The SUP application’s waste disposal commitment sometimes promises collection daily, and on other sheets does not.
The staff report claims that only “typical retail shopping establishment noise [is] to be expected” but then ignores the description of the industrial slaughter process that the SUP applicant sets forth, which incorporates descriptions of mechanized butchering equipment.
The SUP application requests authorization for activities that are patently barbaric, involving days of protracted confinement in a windowless and apparently not temperature-controlled facility while awaiting fully-conscious slaughter, and have invited enmity and have damaged real property valuation and other lawful property uses in other large, densely-populated cities.
The SUP application and staff findings are diametrically inconsistent with existing lawful uses. The proposal upends existing legal requirements and terms that are defined by statute. The analysis conducted by staff and the planning commission are grossly insufficient, as a black-letter legal matter, and the record before council is not legally adequate for the SUP to be granted, whether with or without further conditions.
The application is shocking and should be denied. Concerned Alexandria residents, business people, and voters should contact city council at: www.request.alexandriava. gov/CCC/#tab=Index&ser- vice=CNC_GROUP
-Mark C. Williams, Alexandria
