An Open Letter to Dr Beth Cookson, the Australian Chief Veterinary Officer and The Hon Julie Collins MP, Minister for Agriculture

19 March 2025

Prevention of disease outbreaks does not begin at the farm gate, it begins on the farm with healthy production models. 

Repeated outbreaks of avian flu are caused by raising too many birds with too little genetic diversity in too little space. Nothing in nature looks like industrial livestock production – nature doesn’t have monocultures of just one species trapped in unhealthy environments. Instead, biodiversity and ecological balances help regulate regular occurrences of low pathogenicity avian influenza (LPAI), which is normal and rarely deadly in the wild. 

Did COVID teach us nothing? Clearly ‘social distancing’ is one tool in an arsenal against the spread of disease, and must be applied to livestock production.

The novel strains of high pathogenicity avian influenza (HPAI) are born of intensive livestock production, a model that evolutionary epidemiologist Rob Wallace calls ‘food for flu’ – because ‘raising vast monocultures removes immunogenetic firebreaks that in more diverse populations cut off transmission booms’. While avian flu circulates regularly in wild bird populations, most birds are asymptomatic, and highly pathogenic strains in wild populations alone are exceedingly rare. 

Governments tell us that ‘free-range’ models are risky, because industrial poultry have contact with wild birds. However, they do not critically analyse what is legally called ‘free range’ – giant sheds surrounded by bare dirt where poultry ‘have access’ to go outdoors, but in fact, most rarely do. They are packed into sheds and some venture outdoors into the immediate surrounds, where wild birds can infect them. They subsequently carry the virus into the shed, where most birds are suffering respiratory illnesses already (such as those noted by the National Biosecurity Committee to increase vulnerability to avian flu: infectious bronchitis virus and infectious laryngotracheitis virus). This immuno-compromised state makes them the perfect breeding ground for more flu. The vast numbers of confined birds also makes them a hotbed for mutations of more novel varieties, with real risks that the next deadly pandemic could start in a chicken shed.

Contrast this with genuine pastured poultry systems, in which birds are on grass in healthy pastures, and do not suffer chronic respiratory distress. The healthy environment is a form of protection from a low pathogenicity avian influenza (LPAI) developing into an HPAI, just as it is in the wild. There is ample evidence that the most thorough response to the increasing threat of avian influenza (and a host of other diseases) would be a complete overhaul of the production systems from which they emerge. 

It is not only the public health threat that changing production models would address, but substantially improved animal welfare outcomes which can be achieved by raising animals on pasture in the open air. 

The current crisis of access to abattoirs in Australia is related. 

Industry consolidation and increasing vertical integration, driven by a profit-driven myopia on export, is leaving Australia more vulnerable to incursions of exotic animal diseases, or the possible origins of the next novel influenza. If small- and medium-scale farms have nowhere to slaughter their animals, only the sheds and feedlots will remain. Current egg shortages that have seen Australia importing eggs will become the norm if strong action is not taken to protect the remaining diversity of pastured livestock farming models and local slaughter facilities controlled by farmer cooperatives. 

So long as governments fail to take a systems approach that acknowledges the complex interactions between species in ecosystems, the Pandemic Age will continue to evolve. 

Sincerely,

The AFSA National Committee

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Note: This letter has also been sent to the following State Ministers for Agriculture and State Chief Veterinary Officers:

• NSW Minister for Agriculture – Tara Moriarty
• NSW Chief Veterinary Officer – Jo Coombe
• QLD Minister for Primary Industries – Tony Perrett
• QLD Chief Veterinary Officer – Allison Crook
• WA Minister for Agriculture and Food, Forestry, and Small Business – Jackie Jarvis
• WA Chief Veterinary Officer – Michelle Rodan
• TAS Minister for Primary Industries and Water – Jane Howlett
• TAS Chief Veterinary Officer – Kevin de Witte
• SA Minister for Primary Industries and Regional Development – Clare Scriven
• SA Chief Veterinary Officer – Elise Spark

We encourage AFSA members to follow up engaging directly with their state and local government contacts on this issue. If you want to talk to AFSA about effective government outreach, get in touch.