Goulburn Poultry Processing Mixed Use Development

I fully support this project. It will provide vital economy stimulus for the local community and jobs for locals.
The location is well suited to this type of development.

Please find the Department of Primary Industries comments in the document attached.

On behalf of my organisation, the Anti-Speciesist Action Collective, I cannot condemn this proposal strongly enough.
The proposal to develop this facility fails to meet community expectations on a number of fronts and is actively harmful to the environment, the town and the sentient beings who will face violent deaths in the facility.

As you are surely aware, we face sustained water insecurity in the region, and having grown up in the Southern Tablelands I recall the dire circumstances Goulburn faced during the millennium drought. To construct a facility requiring such substantial water inputs is unconscionable. Further, the ecological impact of the support, and indeed growth, of the chicken industry flies in the face of expert opinion regarding the need to massively reduce, and indeed cease, the production of animal products: https://josephpoore.com/Science%20360%206392%20987%20-%20Accepted%20Manuscript.pdf

Secondly, the "processing" of chickens is pure unnecessary violence. As already stated, the consumption of animal products is wholly unnecessary, and those beings exploited and killed for their flesh and secretions suffer beyond comprehension. I have included a link of an Australian slaughterhouse "processing" chickens: https://vimeo.com/284374463

Thirdly, but relating to the second point, the human impacts of slaughterhouse work is vastly under-appreciated. In regions with slaughterhouse workers, rates of domestic violence, alcoholism , depression and assault are far higher than other towns of equivalent socio-economic and rurality without such facilities: http://www.ptsdjournal.com/posts/the-psychological-damage-of-slaughterhouse-work/

The allure of jobs within the region is no doubt appealing, but this proposal is incredibly short-sighted. To siphon off a valuable resource for a private business will harm the region and the employment prospects of those residing in it.

It is for these reasons above we strongly urge that this proposal be refused.

I am supportive of this project, and have made comments about the need for enabling infrastructure with traffic to be considered.

I write this time because I have detected significant, destructive rumblings related to the amount of water this plant is reported to use, I believe around 14 litres per bird processed.

This I think is one of the issues that will have green vegans flying themselves to the road about. It’s an awful lot of water.

Surely there is scope to use less water. Processes obviously have been worked out in other facilities, however surely design innovation can reduce water consumption, and thereby the amount of waste water needed to be processed. Obviously this will save huge operational costs as well, and may well pay for any extra costs in capital with savings in operating costs. A percentage saved at each step, and perhaps capturing some of the cleanest waste water to recover and treat on site, to use where appropriate, has to be possible. I’m no poultry abattoir designer, but I cannot believe that the amount of 14 litres per bird is set in stone, and that significant savings can’t be made to reduce costs of operation, save water and energy so we can devote that to more industry in future, and lessen the demand on environment can’t be achieved.

I don’t think that the only battle is against green lunatics. Goulburnians lived through the millennium drought, we almost ran out of water and had to have it trucked in. It didn’t quite happen. Now we have the Highlands Source; but still memories are long. We are all water wastage obsessed. There could be significant resistance from ordinary people too.

It is not sustainable, 40% of water in the area is going to be used, and farmers don't have enough now, and the fact it creates more carbon emissions and at rate payers expense we will be stuck funding any extra infrastructure needed through our rates. We dont need this

I wish to express my disapproval of the proposed processing facility at Goulburn. There are many reasons why I object. Primarily, as an animal activist and vegan, my greatest concern is the sheer volume of slaughter of innocent beings.
As an environmentalist, I see only disaster in the making as this processing facility will be using approximately 40% of the Goulburn water supply. It was only 2009 that Goulburn was in severe drought with water restrictions so strict that each household could only use the equivalent of a bath full of water per day. The city was lucky that the drought broke in 2010, however, the odds of another devastating drought are extremely high. The population and growth of Goulburn in the past 10 years has been extensive and when the drought does happen, there will not be enough water for the residents plus this facility.
Also an environmental issue is the sheer volume of waste that the facility will create. As far as I am aware, there is no direct action plan to cope with this. Filth from faeces, blood and unused body parts will create a fess pool of bacteria hosting salmonella, listeria and e-coli, which will undoubtedly lead to the spread of diseases such as diphtheria and others. This same waste will eventually make its way into the city's water supply, causing even further health issues.
Depending where your concerns lay - with the well being of animals, or the well being of humans - this is a development that should NOT be permitted to proceed.
There is no economical benefit when there is no water and disease is rife.
Please do everything in your power to STOP the Goulburn Poultry Processing Development.

I first came to Crookwell in mid 2009. Driving past Pejar Dam was frightening. For such a large water holding structure, there were merely puddles among the cracked, dry earth. I soon learned that Goulburn was suffering the effects of drought to such a capacity that the most severe water restrictions were in place.
The drought eventually broke, Pejar Dam filled, as well as Sooley Dam which is the main water source for Goulburn.
In the 10 years since the drought, it appears the Goulburn Mulwaree council has not only forgotten the dire consequences, but are willing to wager almost half of the city's water supply that there won't be another drought!
With some 99% of the state severely affected by drought, the odds are stacked against them. There WILL be another catastrophic drought. Goulburn has grown exponentially in the past 10 years, so there are even more households depending upon the city's water supply.
To hand over so much water to a poultry processing plant is irresponsible and reckless to say the least!
Then, there is the other end. Where is the waste going to go? According to current information, Goulburn does not have the infrastructure to cope with the mass amount of waste this facility will create. Either the local ratepayers will have to fork out a large amount, through increased land rates, to have the waste facility upgraded, or there will be flow-on effects from bacterial laden waste, including human illness, disease and death.
Finally, I doubt that any concern has been offered in regards to the well-being of the poultry being processed. Counted as units, this facility will mercilessly slaughter a million chickens per week. Knowing the current slaughter process procedures, I am horrified that such a large number of birds are not stunned properly and suffer burns and a slow agonising death in the scalding tanks. Some birds have survived past this stage, only to be beaten to death as they have their feathers mechanically removed.
This poultry processing facility should NOT be approved to be built anywhere in the world, let alone a high populous area which will inevitably be left without a sound water supply, increased local debt and the potential for life-threatening disease. Please ensure that this facility is NOT approved for construction.

I’m Writing to you as a concerned long term resident own the Common St area, I have resided in the area my whole life some 70+ years and own a large portion of land in the area.
I strongly object to the above development application in its current form for a number of reasons.
• Not Consistent with the zone objective
• Not Conducive to current land use
• Impact to current residents Visual, Air Quality, Noise & Excessive Traffic
• Current infrastructure insufficient to support Development

The Current Land Zone B6,RU6,E3 Does not allow for the complete scope of the development only meeting 3 criteria of the Zoning.
As the name suggests the core business of the development is Poultry processing /abattoir which is prohibited in the Current Zoning. This type of facility is prohibited in the land ZONES B6,RU6,E3 for obvious reasons, as they are not compatible to the surrounding area, within the city limits and within close proximity to the town centre.
The Cold storage, Distribution and Child care facility which are permitted are only secondary to the development, and would not exist without the primary development.


The Current land use in the area is predominantly Rural residential. Its currently used for Sheep and Cattle grazing purposes and provides a semi rural lifestyle for the residents in the area, where their families enjoy outdoor recreational activities.
These would be impacted by this development by a number of means.
• The landscape visual outlook, my residence is on an elevated aspect to the site looks over the development. The Rocky Hill War Memorial view would also impacted from a tourist perspective.
• Air Quality as a long term resident and living in the area for 70+ years, and having worked in the Meat Processing Industry, there are unavoidable odours which are a result this type of development. With the local winds, would impact my property and the surrounding areas, possibly the town centre due to its close proximity as well as the local Restaurants to the north. Especially summer in when the Easterly wind prevails.
• Noise the development is proposed to operate 24 hrs -7 days, extra traffic trucks and plant operating would greatly effect the peaceful nature of the area.
• Increased traffic I believe will not only be from the Sydney Road/Common St intersection. But the whole of Common St to the south, and Chiswick St to the West, leading to Hetherington St over Rocky Hill, will be impacted as, the site intends to employ some 200+ People and I believe this would be an alternate route to work, Potentially adding 200+ Vehicles to the already substandard road. Making it near impossible to move stock/vehicles across the increasing busy road safely.

Goulburn Mulwaree Council has had numerous proposals put forward to re zone this land dating back to the 1990s deeming it unsuitable, examples of this are Draft Common St Business park and the Coles distribution centre which was proposed for the site to the south of the current proposal, which was relocated to the Ducks Lane area.

Finally, if permission is granted for this type of development.
What is the future for the area?
What other types of Businesses will wish to develop land adjacent to poultry abattoir.

Regards

This is a travesty in the making on innumerable levels: environmental, civic and animal welfare. Excess water consumption, quality of life issues for area residents, including foul air and traffic, and tortuous suffering on an unspeakable scale for baby chickens, sentient and intelligent beings who like humans, know pain and distress.

I urge you to reconsider this inhumane and ill-fated enterprise.

I strongly object to the Goulburn Poultry Processing Mixed Use Development, Application Number SSD-9143 proposed in the Goulburn Mulwaree Local Government Area.
I do not support this development for the following reasons:
1. WATER
Goulburn’s average daily water usage in 2017 was 8.22ML and growing in 2018 to 8.44ML. As the city grows the daily amount used will increase year on year. This development has foreshadowed a minimum requirement of daily water usage of 2.688ML for this business to operate, which roughly represents one third of the cities current water usage. My concerns for water is threefold.

In recent history Goulburn was subject to severe water restrictions, and even though there have been significant upgrades to address this issue, one has to question the impact of locating a water intensive industry in an area where water will be an on-going issue. The Goulburn Mulwaree Water Use Policy has 3 levels of permanent water conservation measures based on the storage volume. As at 30/09/19 Goulburn’s usable water storage level was 69.4%, placing residents of Goulburn Mulwaree on the ‘Green Level’ with a target daily usage of 270 litres of water per person. This development will mean that a much bigger demand is placed upon the water resources of Goulburn Mulwaree and will certainly increase the risk of future water restrictions.

Should the water storage levels decrease and residents are required to decrease their consumption and continue to ‘Amber Level’ or worse, the ‘Red Level’, will this poultry processing plant be required to reduce their usage, or are they exempt from such restrictions? It would be unfair to the people of Goulburn Mulwaree, in the event of water restrictions, that this business to not have to abide by those same restrictions, regardless of economic impact.

On page 154 of the Statement of Environmental Effects, section 6.6.4 . . .

A 100% efficient tank requires no draw down on mains supply however this can result in an unreasonably large tank unreasonably increasing costs

I do not think it unreasonable for a business using this huge amount of water to be required to provide most, if not all, of the water they need. Without decent continual rainfall, which cannot be guaranteed, this simply cannot be sustained. It is unreasonable for this business to expect the city to cope with losing this amount of water on a daily basis.

I would also expect that this business pay commercial rates for any water they use from the mains supply and not ask the ratepayers to subsidise their water use.

2. WASTE WATER
Council has planned to upgrade the Goulburn Sewerage Treatment Plant to accommodate expansion/growth in the city. This facility will take up most, if not all, of the benefit of this upgrade. I don’t believe that the ratepayers of Goulburn should have to subsidise this development in either building extra capacity or giving this development a concession in usage fees payable. As this development will significantly and immediately increase waste water requirements, this development should do everything to reduce the risk and financial burden to Goulburn Mulwaree residents.

3. LANDUSE
The identity of the zone is B6 Enterprise Corridor, E3 Environmental Management and RU6 Transition under the Goulburn Mulwaree Local Environmental Plan 2009. Intensive livestock agriculture is prohibited in both the E3 and the RU6 zones. Agriculture is prohibited in the B6 zone.

Council is currently processing a Planning Proposal to rezone to IN1 General Industrial. Agriculture is also prohibited under this zone.

I am deeply saddened to hear of this development, as it will be a place of great suffering for millions of chickens. These are beautiful birds who do not deserve such treatment.

As a landholder fronting Common Street, North Goulburn, I object to the project on the following grounds:
Water usage - my concern is that the proposed development is on a very large scale and will therefore require a vast amount of water for operational purposes. This would put pressure on town water supply, particularly in a drought such as we are currently experiencing.
Odours from the proposed business activity - depending on how the wind blows, we already experience unpleasant odours from the Council tip. I believe that a poultry processing plant would also contribute to unpleasant odours in the vicinity.
Noise - such a vast complex comprising 7 buildings together with the associated transport required for - I assume a 24 hours operation - will obviously make the entire area noisier and will impact on existing residents and businesses.

I oppose the project on two grounds:
1. The project will use far too much water for a region that is experiencing a declining rainfall pattern. The proposal uses a 50 year average for precipitation in the region. This is a false reading of the current rainfall pattern, which has declined over the last 20 years, despite the fact that there was a slight improvement on the average for several years prior to the current drought. The 20 year figure is at least 10% lower than the 50 year average and has shown a marked decline as climate change impacts on the region.
Further, the total water requirements of the project would use up to 30% of the total water requirements of the city and this will put further strain on the water infrastructure as climate change puts more pressure on water supply for the region. As the region is within the Sydney catchment it will also put stress on water supply resources for Sydney.

2. The project involves the transport, caging and killing of sentient beings at a time when demand for non animal protein is decreasing in the community. Animal cruelty issues cannot be ruled out at a time when there is an increasing concern within the community for animal welfare and an increase in demand for less cruel methods of sourcing protein.

Added to this is the necessity of feeding chickens and turkeys with vegetable sourced protein in an inefficient delivery method of protein creation for human consumption. When vegetable protein is used to produce animal protein for human consumption the ratio of vegetable to animal protein is as high as 10 kgs of vegetable protein to 1 kg of animal protein when fed to animals.

Re Planning application SSD-9143

To the NSW Government Major Projects Department,

I am writing on behalf of People for the Ethical Treatment of Animals (PETA) with regard to the proposed Goulburn Poultry Processing Mixed Use Development (application number SSD-9143).

Please see the attached submission outlining the concerns of PETA Australia and 8,188 supporting signatories in relation to the proposed facility.

Thank you in advance for reading the submission. We look forward to hearing from you regarding this issue.

Yours faithfully,

PETA Australia

Please see the attachment.

I have attached a PDF document with comments

Please see the attached submission objecting to the project.

The objection prepared by Plan & Co Pty Ltd on behalf of Aviagen Australia is multifaceted. Concerns have been raised regarding inconsistencies identified in the submitted documentation, compliance with aspects of the Biosecurity Regulation 2017, failures to address SEARs and failures to comprehensively consider and describe the potential biosecurity risks that the development poses to Aviagen in Goulburn.

Further to this, it has been identified that the DPE has omitted the specific SEARs recommended by DPI in the SEARs issued to the proponent on 25 July 2018. This failure is considered to have a detrimental impact on ensuring that the potential impacts of the development on Goulburn Agriculture are made clear to the Consent Authority and are appropriately addressed by the proponent within the Environmental Impact Statement.

see attachment 3 page submission

Please see attached

Dear Sir Ma'am
Criticism has been made locally of the extraordinary amount of water the State will need to supply, as a resource to the proponents, for this undertaking to succeed and I agree with this criticism.

Supplying this amount of water to any business at this time in Australia's history, with stresses appearing daily in the ability of infrastructure to cope with supplying sufficient water to support existing populations and industry, most particularly inland Australia, is problematic to say the least.

The coastal fringe has historically much higher rainfall than inland Australia and inland is where this proposed site is located. daily we hear of new towns in NSW, particularly inland, who are facing a dire water shortage.

What is the logic in setting up a business that is heavily reliant on a dwindling and essential resource. No sooner than the plant may become commissioned it may be subject to water restrictions. This in itself may cause the business to fail, leaving debts. As water cutbacks bite what will be the scenario: increased use of sanitizers and detergents; threats to the health of the stock and workers?

The coastal fringe also has the availability of sea water for washing down product and facilities, as is done successfully in the oyster industry.

The nutrient rich runoff could be used as a feed type for fish farming.

Australian consumers are turning away from poultry grown in factories due to a variety of ethical objections and are increasingly less likely to purchase poultry if it is known to be sourced from this type of facility, the free range sector growing.

It's my firm belief that this poultry processing plant would be better located in a coastal location with access to; workforce, water and transport. Port Kembla for example.

There are other options for economic growth in the Goulburn area. Empty nesters relocating to access cheaper housing, Tourism opportunities such as the Goulburn to Crookwell rail trail, and I'm sure plenty of other less risky enterprises.

Thank You for opportunity for submission
Matt Ford