0A.IEsubmission3A

Introduction

Two months ago, we received several documents from the Sustainable Poultry
Alliance (SPA), which is a network of communities in southeast Queensland affected
by the impacts of meat poultry farming. The SPA has represented community interest
at various forums since 2000, and particularly in the Poultry Industry Roundtable
process conducted from December 2009 to March 2011.

These documents raise legitimate concerns about the reliability of odour modelling,
the reluctance to consider the bioaerosol component of poultry shed dust, the
omission of key research into SEQ poultry shed emissions, and the lack of support
for the draft meat chicken guidelines by the then Department of Environment and
Resource Management (DERM) and the majority of local councils.

These documents led us to contact Mr Ian Eskdale, a very experienced pollution
scientist who was the DERM representative on the Poultry Industry Roundtable
Guidelines Working Group.

SPA and Mr Eskdale have assisted us to compile this submission. See the
accompanying letter to Noosa Council from Mr Eskdale.

We have provided Council with a hard copy of the booklet we received from SPA as
a general reference.

In the Key Issues below, we refer to specific examples by way of separate
attachments.



Key Issues

In summary:

   1. We accept the odour impact modelling has been done generally in
        accordance with current industry practice, with some limiting variations
        (for example, issues related to the use of representative or on-site
        meteorological data)

        Basis for opinion
        The peer reviews commissioned by separate parties have sufficiently
        common comments. Please find attached a copy of the review of the odour
        assessment we commissioned from Katestone Environmental (Attachment 1).

   2.

   3. We do not accept that the odour modelling is a reliable prediction of
        likely odour impact.

        Basis for opinion
        The Guideline: Odour Impact Assessment From Developments has not been
        applied appropriately. Taking the Guideline’s objects, procedures and
        guidance into account, it is reasonable to expect that use of the 2.5 OU