MCU21_0154 Objection letter

Close proximity of business activities adjacent to residential properties

Despite the perceived large lot size – 7822m2, the reality is the meat processing and transport of
carcasses is contained within a small available cleared area on the applicants lot with minimal
buffering to neighbouring dwellings on the south/east portion of the land parcel (approx. 50m to
adjoining Lot 61).

The proposed meat processing activities occur as stated 50m from a neighbouring dwelling (Lot 61,
90 Patterson Drive). The transfer of carcasses occurs even closer on an adjoining driveway within
5m of this dwelling.

The Department of Environment and Heritage Protection in Queensland, provide eligibility criteria
and standard conditions for meat processing activities. Under the Environmentally Relevant Activity
(ERA 25), Meat processing at threshold 1a between 1000 tonnes and 5000 tonnes of meat products
in a year requires that the processing site is not within 1000 metres of a residential allotment,
mobile home, caravan or other residential premises. This also includes within that 1000 metre
buffer, any area protected area under the nature Conservation Act 1992. The activity area must also
not be within a category A or B environmentally sensitive area and not within 100m of any
watercourse, wetland or spring. There are also a raft of other conditions and requirements that
must be met before an operation can be considered for approval.

The current application states a processing yield of 200 tonnes of meat per year which is
acknowledged not in the same threshold category. However, this stated yield does not factor in
future growth in production and raises the validity of the operation within such close proximity to a
neighbouring residential premise. The applicant has advised that they seek to diversify their product
offering to the public. The reason for the 1000 metre distance is to minimise impacts on
surrounding residents which supports this activity occurring on a larger rural zoned lot or with
greater land buffering. Is 50 metres acceptable for 200 tonnes of production vs 1000 metres for
1000 tonnes? What guidelines or eligibility criteria are being used by Council to assess what is an
acceptable distance for this change of land use? It is our opinion that 50 metres (despite measures
to mitigate impacts) is a grossly insufficient distance to make this an acceptable homebased activity.

Based on the above logic, it is reasonable to assert that a 200 metre buffer from any dwelling is a
minimum requirement based on the percentage of meat production in relation to threshold 1a of
1000 tonnes / year. Figure 1 (over page) clearly demonstrates there is not clear buffering from any
neighbouring residences.

If the application distance of 50 metres to the nearest residential dwelling is accepted along with the
mitigation measures to make the activity lawful by Council, it opens up this type of activity on any
‘largish’ suburban block in suburbs such as Noosa Banks, Noosa Parklands or Sunshine Beach that
back onto state forest / national park and parkland but have a similar distance buffer / driveway
access arrangements etc to a neighbouring property. It appears that if the meat processing
activities occur within the ‘cover of darkness’ and behind closed doors where you can’t see or smell
it, then all is ok with approving this type of activity in any residential area.