FURTHER REPORT - Planning & Environment Committee 6 May 2025 MCU21/0110

                      ii.   Memorandum of Unitywater engineer.
                      iii. Report by Paul King of MWA Environment dated 7 January 2022.
               c.     Impact on the community
                      Should the proposed material change of use be approved, the likely impact is that it will
                      result in an environmental nuisance at a sensitive place under the Environmental
                      Protection Act 1994 which could result in a prosecution of Unitywater. This will force
                      environmental studies by Unitywater, and likely very expensive modifications to be made
                      the Noosa STP which will ultimately be a cost borne by the rate payers of the Noosa
                      Council through their water bills.
               These concerns were provided to both the applicant and the consulting odour expert who
               advised:
                    It is my opinion that the concerns of Unitywater are validly held and that approval of the
                    development has the potential to result in odour complaints and these may have the
                    potential to result in constraint upon the operations of the STP. However, this must be
                    considered in regard of the odour predictions which do show compliance of the built form of
                    the development with acceptable odour levels (albeit right on the 2.5OU criterion limit). On
                    the basis that the Katestone predictions are accurate, there would be no basis for a valid
                    odour complaint from the accommodation building use to affect the lawful operation of the
                    STP. The Unitywater concerns reinforce my opinion that should Council choose to approve
                    this development that there need to be very specific conditions in respect to odour
                    outcomes.
               Conditions were provided by Council’s consulting odour expert after this advice was provided to
               Council officers.
               Subsequent discussions with Unitywater and Council’s consulting odour expert resulted in
               Unitywater obtaining a third-party review of the application. The report notes that…the scope of
               work is limited to a high-level review of the proposed mitigation measures contained within the
               Provided Documents and recommend further mitigation measures that could be considered by
               council and/or Proponent, which would aid in further reducing the impact risk of the Proposed
               Development encroachment upon the current and future operational and business continuity of
               Noosa STP under normal and unintended or unavoidable odour release conditions.
               The report states that the most effective further mitigation measure, in terms of risk reduction and
               operational and future capital costs to Unitywater and to the community, would be to preserve the
               existing exclusion zone (i.e., separation distance). The report also maintains Unitywater’s position
               that the odour dispersion modelling is not suitable for the prediction of unintended or unavoidable
               odour release events, for example, sewerage network asset breakdown, significant rainfall,
               heatwaves, process upsets, biosolids truck loading events, etc.
               It is also noted that the report identifies that in the scenario that the proposed development is
               approved, the author of the report supports in principle the odour mitigation measures proposed in
               the suggested conditions of Council’s consulting odour expert.
               In addition, Unitywater’s consultant recommends further mitigation measures in the form of:
               •    To the extent that is reasonable, an encumbrance or similar that transfers all responsibility of
                    STP-related odour complaints from Unitywater to the Proponent and is sanctioned by Council
                    and DES. Professional advice from a town planning or environmental law expert should be
                    consulted on this matter. Based on the sentiment in the letter by GH Australia, the Proponent
                    could be willing to enter such an arrangement;
               •    Activated carbon filtration to be installed on all fresh air makeup locations of the air
                    conditioning systems and are regularly maintained to manufacturer specifications; and
               •    To the extent that is reasonable, that the layout of structures is designed to avoid entrapment
                    of odour plumes. TOU are concerned that the northward facing concave layout of
                    accommodation structures is conducive to entrapment of STP odour plumes from the north.




Document Set ID: 22048375
Version: 34,
         32, Version Date: 24/10/2023
                           05/07/2023