0A.IEsubmission3A

   DAFF scientists in a peer reviewed journal article discuss the health
   implications of fine particulate dust and state that the dust emissions from
   poultry sheds can remain suspended in the atmosphere for periods of time
   and travel large distances from their sources (Attachment 10, page 552).

   The DERM representative on the Working Group raised the importance of the
   dust emissions and prepared a comparative risk assessment that concluded
   dust emissions were potentially a greater impact than odour emissions.
   (Attachments 11 and 12).

   The actual impact of dust emissions from SEQ poultry farms is evidenced by
   three separate professional opinions for three different situations
   (Attachments 14, 15).



6. We contend that despite being described as industry best practice, the
   proposed development does not include any extraordinary emission
   control measures, and is likely to emit large volumes of untreated
   emissions that cannot be managed to an acceptable level once the
   facility is operational

   Basis of opinion
   The net outcome of the fore-mentioned items is that there is little that can be
   done once a facility is operational.

   This reality is reflected by the overwhelming consensus from local
   government representatives on the Working Group that the current practice
   for determining separation distances was inadequate. The local government
   representatives recommended that separation distances should be measured
   from property boundary of the development. This is evidenced by local
   government submissions and the Local Government Association of
   Queensland motion at its annual conference (Attachment 16).


7. We contend that the DAFF meat chicken guideline does not reflect the
   scientific knowledge, the experience and exercise of local government
   regulation of poultry farms. The guideline reinforces the misinformation
   and perpetuates the impacts on the community. This has given rise to
   four Ministerial Forums since 2000.

   Basis of opinion
   DERM and several councils did not support the draft meat chicken guidelines
   (Attachment 16A).

   A summary of concerns about the Conduct of the guidelines working group is
   provided at Attachment 17.