0A.IEsubmission3A

   criterion will result in an underestimation of odour (Attachment 2).

   A submission to the Poultry Roundtable Guidelines Working Group by the
   Scenic Rim Regional Council representative refers to numerous examples
   where odour modelling had poorly quantified actual on-ground odour
   emissions and dispersion patterns (Attachment 3).

   The Working Group correspondence raises numerous issues with the
   modelling approach; particularly lack of validation of odour modelling results
   with actual performance in the field, use of the so-called “K factor” (see
   Attachment 3A which discusses the lack of scientific rigour in the K Factor),
   and appropriate odour assessment criterion (Attachment 4).


4. We contend that large volumes of untreated odour will be emitted, given
   the proposal does not include any extraordinary emission control
   measures, and there are, in practice, no cost-effective measures to
   mitigate impacts to an acceptable level.

   Basis for opinion
   DAFF scientists have published in a peer review science journal stating that
   SEQ poultry farm emissions are the highest recorded emissions in the
   literature (Attachment 5, see page 550, Discussion).

   The requirement to ventilate the sheds to ensure bird safety results in huge
   emission rates – “A typical broiler shed may have a maximum ventilation rate
   of 130 m³/s (which would remove the air from a container the size of an
   Olympic-sized swimming pool in about eight seconds!)”. These huge
   emission rates inhibit the ability to control odour emissions (see Attachment 6,
   page 24).

   The lack of practical cost-effective measures for controlling odour (and dust)
   is detailed further in Attachment 7 (DAFF presentation to growers) and
   Attachment 8 (RDRDC report on control technologies).

   There are a number of operational poultry farms with unresolved odour and
   dust problems in SEQ – for example, Scenic Rim Regional Council, Logan
   City Council, Moreton Bay Regional Council, Somerset Regional Council.


5. We contend that dust emissions are seriously misunderstood and
   underestimated

   Basis of opinion
   The harmful nature of poultry shed dust is well documented in the scientific
   literature. A good publication to explain poultry dust is the Statement of
   evidence – Respiratory hazards of poultry dust (Attachment 9).