Development application MCU21 0154

The Assessment Manager
Noosa Council
PO Box 141
Tewantin QLD 4565

Development Application MCU21/0154
82 Patterson Drive Tinbeerwah

Introduction

The application for a change of material use to allow a small home-based meat processing business at the above address suggests the business has been in operation for some time without a council permit and they are now seeking approval after the fact.

According to the application deer are harvested and the meat and by-products are currently sold at local markets and directly to restaurants.

Unfortunately, the application does not state for how long the business has been operating but the implication is that it was prior to the incorporation of Australian Wild Game Harvesters in July 2021 and the temporary accreditation certificate from Safe Food which expires on 31/12/21.

In order to receive the accreditation it is a requirement from Safe Food that written confirmation is received from local council that the operator is permitted to undertake the proposed activities on the site. Clearly this requirement has not been met.

We note that the application states that a “refrigerated trailer is packed for delivery on Saturday and Sunday” although we are not advised whether the trailer is accredited with the QLD Government as a Transporter.

Despite the fact that the business appears to be currently in operation the question remains as to whether it is appropriate to be located in a rural residential area.

The Noosa Plan 2020

The introduction to the Noosa Plan states:

“The Noosa Plan 2020 strives to protect the look and feel of Noosa while providing a blueprint to shape the shires growth over the next 20 years.”

In our view the proposed application is inconsistent with the guidelines and objectives of the Noosa Plan and fails to comply with the above objective.

Under the Rural Residential Zone Code:

6.8 4.2
2(c) Non residential activities are limited to small activities that are compatible with and do not impact on the rural residential character and amenity of the zone.

2(d) Home based businesses are facilitated where the nature,
scale and intensity of the activity is compatible with the low density rural residential character and amenity of the surrounding locality.

It is very difficult to argue that transporting up to 5 deer carcasses in an open vehicle through residential streets meets this criteria and we question whether the potential production of 200 tonnes of venison meets the definition of “small scale activities”.

Table 6.8.4.3 then outlines the Criteria for Assessment.

Acceptable Outcomes:
AO2 (a) Distance of 100m is provided between sensitive land use and land within a rural zone and
(b) has a property greater than 4 hectares.

The application clearly fails on both criteria with the shed located close to the boundary and the property size at 0.78 hectares being much smaller than that required.

AO6.1 Structures containing animal wash:
Not within !00m of (a) boundary
(b) existing dwelling
(c) boundary conservation zone.

Again, the application fails to meet the relevant criteria. The shed is approximately 10 meters from the dwelling house and approximately 50 meters away from the dwelling at 90 Patterson Drive.

The application acknowledges that parts of the subject site are identified as being a Koala Habitat. I

t is considered that a meat processing facility adjacent to an area likely to contain a threatened specie such as a koala is likely to attract feral animals which will pose a threat to their continued existence within the area.

Other Issues

The application of the proposed “small scale meat processing” use falls under the Medium Impact Industry Threshold #12 with production less than 200 tonnes per annum.

Under the Department of Environment and Heritage Protection a meat processing facility of 1000 tonnes of meat products per annum is not to be located within 1000 meters of a dwelling.

It is reasonable to assume therefore that a producer of 200 tonnes per annum which is equivalent to one fifth of the production should not be within 200 meters of a dwelling (i.e. one fifth of 1000 meters). In this case the building is located within 50 meters of the neighbor’s residence.

Other issues arise with the entrance driveway within close proximity to 90 Patterson Drive.

Considering all the issues above it is very difficult to agree with the application which states:

“As such, the proposed small-scale meat processing operation has a nil impact upon the existing residential use and the surrounding properties”

Conclusion

In conclusion the proposed meat processing facility does not meet the criteria outlined in the Noosa Plan.

Whilst it may technically fall within the definition of a small scale processing plant (ie less than 1000 tonnes pa), it is difficult to see how processing up to 200 tonnes per annum, plus an intention to expand the business into other meat products, can fall within the definition of a “small home-based business “as envisaged by Noosa Council when the Noosa Plan was drafted.

Transporting fresh deer carcasses in an open vehicle possibly with blood still visible will be upsetting and distressful for many adults and young children alike. This, together with the processing plant itself will attract feral animals, including wild dogs, to the area which may pose a risk to other livestock.

It is disappointing that the applicant has chosen to conduct the activity prior to gaining approval. However, this is not a home-based business suitable for a rural residential area. The property is far too small and in close proximity to other dwellings and sensitive environmental land.

There are many questions that remain unaswered including the method by which water is contained after washing the interior of the meat processing plant and how the vehicle itself is washed and cleaned without water runoff into the water course nearby.

In my view the applicant has failed to abide by the council guidelines  and approval for the operation of a meat processing plant should under no circumstances be granted.

To do so creates a dangerous precedent.

Keith Ince
6 Wallaby Lane
Tinbeerwah

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