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Comments: Ten Mile Enterprises Abattoir, Scottsdale

Comments regarding the proposed Scottsdale Pork Abattoir, Ten Mile Enterprises, Daniel Unwin (Application No. 51/2020)

To the General Manager,
We write in objection to the construction of the proposed abattoir by Ten Mile Enterprises and seek clarification on a specific operational matter. Our concerns and objections are as follows.

1. Environmental Impact Statement for Abattoir (p.3) states volume of slaughter to be 120 pigs per day, operating five days per week. The Wastewater Reuse Feasibility Assessment (App. B, p. iv) states volume of slaughter to be 100 pigs per day with an additional capacity for a further 50 pigs per day, 6 days per week. Clarification is required as regards the proposed operational days and the volume of slaughter as there is a significant difference between 600 pigs per week and a potential 1000 per week and the associated impacts.

2. Two active Wedge-tailed Eagle nests have been identified north east of the site within 800 m of the construction platform. Wedge-tailed Eagles are listed as endangered and will not nest in areas with an increased human population or activity. The species are known to be shy nesters and will potentially desert nests if exposed to the elevated levels of disturbance associated with construction and development. Once the facility is established the noise levels associated with the operation of the slaughterhouse, including increased volume of large vehicles transporting pigs to slaughter or collecting the product and the 2 to 4 tons of waste matter per day (to be collected by Western Tiers Proteins for rendering) will potentially jeopardise continued usage of the nesting sites. The construction of the facility will also occur during the height of the Wedge-tailed Eagle breeding season posing a potential disruption to the courtship displays, laying and nesting of the birds who will utilise the afore-mentioned nesting sites. The sudden disturbance in the area relating to construction and ongoing operations may result in an endangered species being prevented from breeding. The rights of these birds to maintain existing nesting sites and engage in breeding undisturbed must be given precedence over the proposed project.

3. The Great Forester River runs along the northern boundary of the property. This river is a known habitat for the threatened Duck-billed Platypus and the endangered Tasmanian Giant Freshwater Crayfish. Both species have been negatively affected by habitat degradation caused by industry including animal agriculture. The Freshwater Lobster Recovery Plan of 2006/2010 identified the Great Forester River as containing good habitat quality and good populations of this unique species, and the Tasmania Platypus Management Plan listed agricultural threats to platypuses including fecal contamination resulting in degraded aquatic habitats. The development application lists various strategies designed to minimise the impacts of run off on animal and plant species, however the risk of runoff especially during construction is considered apparent. Given the status and the fragility of these species any and all developments that elevate potential risks must be considered unacceptable for the area irrespective of the theoretical mitigation plans.

4. A key component of the proposal is the perceived higher welfare standards to be incorporated into the facility design and welfare outcomes associated with shorter travel distances. However there appears to be a significant flaw as regards travel distances as the facility will also be utilised by pig producers across the state. Whilst those pigs killed for Scottsdale Pork will no longer be subjected to hours-long journeys to slaughter, hundreds more per week from other businesses will now be subjected to extensive travel times. The establishment of this facility does not prevent the compromising of animal welfare via travel times, it merely relocates the destination.

5. According to the Centres for Disease Control and Prevention 6 in every 10 known infectious diseases affecting humans are spread through contact with non-human animals, and 3 in every 4 new or emerging infectious diseases in humans come from contact with non-human animals. The potentially catastrophic impacts on the human community by zoonotic diseases is currently demonstrated by the ongoing covid-19 pandemic. This is compounded by the recent discovery of a new strain of influenza amongst pigs farmed for their flesh in China that has spread to humans and has been recognised by researchers as having the potential to cause another pandemic. The construction of a new pig slaughterhouse in Tasmania expands the opportunity for producers to breed more pigs for slaughter thus increasing herd numbers and the potential for disease outbreaks to occur that could pose a significant threat to public health and safety. In the current climate it would be irresponsible of any government body to approve of a plan with these associated risks.

6. Finally we must question the fundamental ethics of constructing a new facility dedicated to the killing of sentient beings in Tasmania. According to figures taken from the Australian Bureau of Statistics, Australia slaughters well in excess of 600 million non-human land animals every year. This violence is often hidden behind claims of better welfare standards. The development application by Ten Mile Enterprises appeals to notions of improved standards of slaughter in an attempt to humane-wash an industry that by necessity relies upon the infliction of violence against unwilling victims. As Dinesh Wadiwel (The War Against Animals) states:
“The scale by which we kill and harm animals would seem to confirm that our relationship with animals is combative or at least focused upon producing harm and death.”
This project will only serve to increase the capacity for producers in the state to kill animals, and as such stands as a sad indictment on our dysfunctional relationship with all animals.

We thank you for your consideration of our comments in opposition to the proposed Ten Mile Enterprises project.

Animal Liberation Tasmania