The Mangrove Mountain community has been joined by its state MP, animal liberation and environmental groups in opposing an intensive cattle feedlot development that could be permitted under current local planning rules.
By Jacquelene Pearson
Before you dish up your next meal of grain fed beef, consider how that beef may have been ‘farmed’. The realities of intensive cattle production have been exposed by a development application for a 400-head intensive feedlot at Hershon and Ironbark Roads, Mangrove Mountain.
Over 200 submissions had been lodged with the Central Coast Council at the time of writing (May 30) in relation to the proposal. If approved, two parallel, open-sided cattle feedlot sheds could be built on a sloping rural block. Each of the 400 head of cattle would be confined to a 6.5 square metre pen.
This proposal complies with the current Central Coast Consolidated Local Environmental Plan, with consent, and the proponent argues it is the best possible use for the land.
Manure would be scraped and stored for no longer than two days in a nominated area of the feedlot pens, according to a revised statement of environmental effects (SEE) submitted in support of the proposal.
“On a weekly basis (and “as required”) a bobcat will scrape the concreted area and compacted earthen/clay faced pens, where the manure collects, to the end of each shed and temporarily stockpiled in a bunded bunker.
“A tipper truck will collect the manure/bedding material from the bunker and will transport it offsite for further processing and use.
“The owners of the subject site have confirmed that manure/bedding by products will be supplied to “Better grow” (a Borg Company) who adds value to otherwise discarded materials, i.e., repurpose waste into fertiliser products.
“Feed will be delivered daily to the feedlot, directly unloaded into a nominated area of the feedlot shed and distributed directly to feed pens for consumption by the cattle,” the SEE explains.”
The undulating nature of this 20.08-hectare site means earthworks would be required to create a flat surface for the construction of the feedlot sheds. Estimated earthworks depths would be up to two metres cut and five metres fill.
The geotechnical study submitted with the application recommends cut maximums of one metre. Other documents state truck movements in and out of the site will equal about one every second day which appears to contradict the above statement that food will be delivered daily.
Ground and surface water management are always hot topics on the plateau. The Mountains community has lived through the illegal landfill saga and the Newcastle Disease disposal pits so their concerns about ground and surface water contamination are understandable.
The proponent states categorically that this property is not in the water catchment area.
The SEE tells us a “dam situated near the northern boundary, within the eastern portion of the site, is fed by a pond and three intermittent first order watercourses. Each watercourse comprises a narrow gully whilst the central one extends upslope.
“Development limitations of this Landscape are reported to include very high erosion hazard, localised permanent waterlogging, high run-on and localised low wet bearing strength,” the SEE states.
There are no bores on the property but approximately 22 registered bores are charted within a six square kilometre search area centred on the site. The three closest bores are located on an adjoining property immediately west of the Site. The nearest bore is located approximately 600m from the proposed development.
“Water for the development will be sourced from both harvesting of roof water and from a leased groundwater (bore) entitlement (Water Access License (WAL) No. 5841- mega-litre (ML) share component).”
An “in- principle” Letter of Support accompanies the application. A local farmer has agreed to lease to the owners of the subject site his entire 8ML water allowance under his Water Access Licence.
The total Water Availability of the site, according to documents submitted in support of the DA is 12.5ML and the water demands of the cattle feedlot have been calculated at 8.03ML per annum so it appears the developer has access to adequate water.
The proponent argues that the design of the feedlot will minimise risks to ground and surface water.
This is about meat
The primary objective of the development is to establish an AUS-MEAT Accredited cattle feedlot operation, allowing cattle reared and sold from the feedlot to obtain premium market prices for grain fed cattle.
As per the “Beef cattle feedlots: design and construction” document produced by Meat and Livestock Australia (August 2016)- Watts, P.J , Keane, O.B, Luttrell,R.W, Stafford,.S and Janke,S, stocking densities in the range of 2.5 square metres and six square metres per head are recommended for fully covered pens.
The design of the proposed feedlots in this DA are, therefore, compliant with the average industry range.
Cattle will be fed for an average of 80 days (60-100 days) at the feedlot. Cattle will weigh approximately 400kg (average 12-18 months of age) upon entering the feedlot and 550-600kg upon exit.
That’s an average weight gain of 2.1kg per day and means up to 1600 cattle will pass through the feedlot per year.
No specific breed or size of cattle is preferred rather the breed and size will be dependent upon market prices and availability.
The feedlot is expected to operate at an average occupancy of 80 percent allowing for variation in cattle purchases and pen cleaning requirements. Cattle produced at the feedlot will be transported for processing at Scone Abattoir which supplies meat products directly to Coles Australia.
The owner will use bunk feeders provisioned with grain pellets, hay and other food products including expired bakery food including bread, corn, flour) on a daily basis.
Each pen will be fitted with water troughs with a pressurised float valve system. The system will be provisioned by a series of water tanks (300,000 litres per shed).
Water will be pumped, as required, from the water tanks into the troughs to satisfy the drinking requirements of the cattle.
The base of the pens will consist of an impermeable layer of clay, overlain by a 150mm compacted earthen layer then covered by a clay face up to 50mm in depth.
Each feed bunk will include a 3m wide concrete apron to ensure the integrity of the floor/ base during extended occupation by cattle during feeding.
Bedding materials will be placed within the pens to improve animal comfort and absorb manure moisture. Bedding material will be sawdust, straw and/or rice hulls and will be set at a depth of approximately 200mm.
Mortality rates are expected to be low. In the event of a mass mortality the NSW EPA would be contacted and appropriate arrangements made for disposal to either landfill or “on farm” burial, as directed.
The application doesn’t include a “hospital pen” so if cattle fall ill, they would be isolated in a cattle holding yard for treatment and the transferred to the paddock to finish convalescing before being returned to the pens.
For design purposes, the NSW Department of Primary Industries recommends feedlot cattle consume, on average, 30% of their liveweight per day. Assuming an average of 400kg per head, each animal would consume approximately 12kg of ration each day which equals 4.8 tonnes of feed per day or approximately 1,752 tonnes a year.
“It should be noted however that it is unlikely that the feedlot would be operating at capacity for the duration of the year. It is considered reasonable that the feedlot looks to store approximately two weeks of ration to ensure feed is always available. On farm store will therefore be in the order of (say) 67 tonnes of grain/pellets and hay for when the feedlot is operating at maximum capacity.”
Animal Liberation Australia are campaigning against the DA. They say all intensive animal agriculture systems, including cattle feedlots, are cruel and unnatural.
“Individual cows are treated like commodities, as the industry prioritises high volume production and profit, ignoring animal welfare, well-being and sentience.
“Additionally, factory farms pose significant risks to the environment, biodiversity, and local community, and public health.
“Feedlots are cramped, fenced areas, where cattle are grain-fed until they are ready for slaughter. Within these pens their movements are restricted and they are unable to exercise or graze as they naturally would.
“They are also frequently found knee-deep in their own faeces and mud.
“As shade is not mandatory, they are often given no shelter or refuge from the elements.
“Living in these cramped, filthy conditions subjects the cattle to immense stress and sickness, with common painful conditions including footrot, botulism, respiratory disease and liver abscesses,” according to AL.
Why the neighbours object
A group of residents has been campaigning against the development. One neighbour told The Point he had recently purchased a property 200 metres away from the proposed feedlot.
“We would be heavily impacted by all the conservative modelling that shows the dust, the odour and the noise, road movements, all the environmental things you can think of,” he said.
“We had absolutely no idea that this thing could happen. There were five blocks that were subdivided.
“In RU1 the minimum lot size is 50 acres so, as well as the combination of all the impacts we will suffer, the neighbouring land is Conservation (C2) land owned by the local Aboriginal land council.
“We’ve sat down with the land council and they are putting in a submission. We know that they are against it.”
The National Park is around 600 metres away, the neighbour said. “The national park is nearby but that doesn’t mean to say that the land council’s land isn’t equally important as it is essentially privately owned national park.
“A major concern for the community is how close it is to the Aboriginal heritage. We are aware of carvings, there is every type of heritage you can think of on the adjoining land and the critically endangered sandstone hanging swamps on the boundary which are designated as protected and endangered.
“They give the cattle as much food as possible to get them as big as possible as fast as possible, between 80 and 150 days per cycle.
“The guidelines for feedlots are that they should be at least 1km away but there are 31 homes within a kilometre of this. They provided some conservative modelling of PM2.5 and PM10 dust and it greatly impacts a lot of the area.
“The noise components are the daily truck movements. They will be trucking in feed every day and they will be supposedly removing urine and manure every second day and there is obviously the loading and unloading of the cattle which is going to be fairly frequent as well.
“The metal construction means they will bash and crash and it will be very loud.
“The residents that normally live in the area have said that the roads are narrow and there are lots of blind corners. Iron Bark Creek has a road crossing and it floods.”
Neighbours are concerned about the impact of the development on the health of Popran Creek which flows into Mangrove Creek and the Hawkesbury River via Glenworth Valley. “We have had over 1600 signatures on change.org. We have had a community meeting at Mangrove Hall and we have had 60 people there.”
The community has started a Facebook group called The Mangrove Mountain Feedlot Objectors.
Whilst the number of objections will mean the DA is referred to the Local Planning Panel the relatively low number of cattle (up to 400) excludes the EPA from taking an interest in the project.
“The EPA only get involved if it is over 1000 I believe,” the neighbour said.
“Normally feed lots are in very remote locations on 1000 acres and are flat so they can contain impacts but this site is on a steep slope. They have containment areas but I am concerned they will overflow and run into the neighbour’s dam.
“Where they are planning to put it has already been designated as a water course. We have spoken to cattle operators who have knowledge in feedlots and it is not a commercially viable operation if they are going to comply with all regulations.
“Cattle prices have dropped and all the management requirements will cost a lot of money so the people who are in the space say they cannot see how it will be commercially viable.
“In their plan they are supposedly going to truck all the manure, dead animals etc. They are supposedly going to buy their cattle from the Scone and Hunter area, bring them down here and fatten them up and then truck them back to Scone.
“We know even with piggeries, egg farms and meat chicken farms, people aren’t buying the land up here for those operations because it is not viable anymore.
“Even if they got the land for free just the operational running costs of it are expensive.”
Local member offers support
Last Saturday, Member for Gosford, Liesl Tesch, joined community members at the Mangrove Mountain Hall to hear concerns regarding the development, and provide technological support for those who required computer facilities to make their submissions.
“The community has come together united in opposition against the proposed feedlot development in Ironbark Creek,” Ms Tesch said.
“Opposers to the development say the development is unsustainable and unsuitable for the local community.”
Ms Tesch said that her attendance at the community forum provided great insight into what the residents think.
“I heard community concerns with the proposed development and their unanimous objection.
“Residents will have until June 6 to make submissions to Council, and I would encourage community members voice their significant concerns.”
John Dickinson, owner of the adjoining lot, encouraged residents to write submissions.
“On behalf of the community it was fantastic to see Liesl there on Saturday listening to kitchen table objections to this feedlot.
“It is essential that the community comes together and that these objections are put to Council.”
The Mangrove Mountain Computer Club also opened to support community members to make their submissions online to Central Coast Council, whilst the CWA also supplied scones and tea to keep hunger at bay.
“The potential impacts on the natural, receiving environment have been considered and considered negligible,” according to the SEE.
Several high priority Groundwater Dependent Ecosystems (GDEs) have been identified by state government mapping in the Water Sharing Plan (WSP) for the Kulnura Mangrove Mountain Groundwater Sources. These GDEs are listed in Schedule 5 of the WSP and include wetlands, heath scrub and woodland areas.
A document produced in support of the DA said a review of available published information and data, and the results of several site inspections (and walkovers) reveal that no GDEs are known, or were observed on the Site, or in the immediate area surrounding the Site. This appears to have overlooked nearby Sandstone Hanging Swamps that have been mapped in the area.
Animal Liberation takes a divergent view to that put forward in support of the DA. “These factory farm environments pose significant environmental and biodiversity risks, and can impact public health.
“Intensive feedlots produce large amounts of waste, which can pollute surrounding soil, creeks and other water sources. This occurs due to runoff from the farm and inadequate animal effluent management systems.
“This is particularly problematic as the proposed site is close to the Popran National Park, risking important local biodiversity.
“Having animals live in confined conditions among their waste also creates breeding grounds for diseases.”
The SEE describes the property as degraded by decades of previous agricultural use but maps submitted with the DA show the site’s proximity to C2 Conservation land including vulnerable Sandstone Hanging Swamps.
There are no bushfire protection requirements, according to the SEE, even though the land is categorised as bushfire prone.
What happens next?
The feedlot has been designed and will be constructed and managed in accordance with the standards described in The National Guidelines for Beef Cattle Feedlots in Australia 3rd Edition (Meat & Livestock Australia, June 2012).
According to the proponent, “The Guidelines provide detailed guidance on the set-up and operation of cattle feedlots including procedures and guidelines covering: environmental protection and community amenity, including recommended separation distances for feedlot pens, pen clean-out requirements, and clean-up of spilled or spoiled feed to prevent odour generation or pest infestation; feeding system management; biosecurity and animal health; and supply chain management.
“This process involves securing Council’s consent, constructing the facility, and then securing the necessary accreditation of the facility to sell cattle as grain fed cattle which includes an AUS-MEAT accreditation number,” documents submitted in support of the DA explain.
The development proposal is considered Local Development and Integrated Development under Part 4 of the Environmental Planning and Assessment Act, 1979. The proposal therefore requires development consent from the Central Coast Council (CCC) as the determining authority along with General Terms of Approval from both Water NSW (water licensing) and the Natural Resources Access Regulator (NRAR) (Controlled Activity Approval- due to the presence of “blue line” first order water courses).
The high number of submissions means the DA will be determined by the Local Planning Panel and Central Coast Council will provide an assessment report and a recommendation to grant consent or refuse the proposal.
The development is not considered Designated Development as the proposal does not exceed the maximum capacity threshold of 1,000 head. Cattle feedlots that do not exceed 1,000 head of cattle do not require an Environment Protection Licence (EPL) under the POEO Act 1997.
The proposal therefore does not require any additional approvals or licences.
The proposed development is considered compatible with the objectives of the site’s RU1 – Primary Production zone, and permissible, with development consent, under the provisions of the Central Coast Local Environmental Plan 2022 (CCLEP).
“”The use of the land for a more intensive form of primary production, which contains a development footprint, is considered to be an orderly and economic use of the subject site,” according to the application.
“Although feedlots are a relatively new land use to the area, generally, it stands to reason the use of underutilised and available primary production lands upholds the intended use and typical character typically associated with the locality, more broadly, and is of an appropriate size to respond positively to potential impacts upon the natural environment.
“The design and site arrangement is considered consistent with the existing and established pattern of development in the locality and meets the objectives outlined of the Act and hence is in the public interest.
“We submit that the proposed development of the subject site has taken into consideration the intention of the [Local Government] Act which ensures a development that has no identifiable impact upon the natural environment or amenity of the surrounding area and therefore must be considered in the public’s best interest.
“The watercourses and groundwater in the vicinity of the property will be protected through the placement of two bioretention basins and filters, the covered (roofed) cattle feedlot pens, specifically placed and treated flooring to ensure impermeability along with good management practices, including fully contained effluent and manure disposal methods- direct load and transport offsite. Appropriate buffers and erosion and sedimentation controls are proposed to ensure adequate separation to streams,” the application argues.
“The Central Coast Council supports the use of land for cattle feedlots within zone RU1 – Primary Production under the Central Coast Local Environmental Plan 2022,” the application says.
However, the community, Animal Liberation Australia, the Community Environment Network, even the local state MP, don’t seem convinced.
“The proposed site is in close proximity to Aboriginal cultural heritage receptors of particular significance and pose a range of visual, noise, and odour amenity issues for the surrounding neighbours,” Animal Liberation argues.
“In summary, the DA lacks planning merit and the Applicant has failed to identify, respond to and address all risks and impacts and cumulative risks and impacts, and has failed to adequately demonstrate how they would monitor, avoid, minimise, mitigate and manage these risks and impacts.
The Applicant’s 12 separate DA documents for DA/4247/2022 can be viewed on CCC’s planning eportal under Applications on Exhibition. You can support and follow the local community’s opposition at Mangrove Mountain Feedlot Objectors and add your name to support their petition.
Residents are able to make submissions at https://eservices.centralcoast.nsw.gov.au/ePathway/Production/Web/GeneralEnquiry/EnquiryDetailView.aspx?Id=1452859