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NBFC submission 26Oct2015
Attached to the e-mail MCU12/0184 - Submission - Julia Walkden.
Comments on MWA Late submission on modelling results for dwelling at 185 Top Forestry Road MCU12/0184 Noise and Air Quality Impact Assessment - Proposed Poultry Growing Sheds, Ridgewood (MWA Environmental, 9 October 2015) 1. MWA: The predicted 99.5th percentile 1 hour average odour concentration at the dwelling at 185 Top Forestry Road is 2.47 Odour Units. This is compliant with the 2.5 Odour Unit 99.5th percentile 1 hour average odour guideline (page 1, para 5). Comment: The odour impact report (9 Oct 2015) based on the Guideline (Odour Impact Assessment from Developments) is presented in a ‘pass’ (or ‘complying’) context, whereas the guideline is not a pass or fail test. Particularly offensive odours are not suitable for 2.5 OU criterion. The assessment ‘test’ under the EP Act is “environmental nuisance”, not specifically the 2.5 OU criterion the proponent uses. (Refer: Critique of the document “Guideline: Odour Impact Assessment from Developments - Attachment 2A of Critique of the Chicken Meat Industry Science: Dust and Odour in relation to proposed broiler farm at Ridgewood. MCU12/0184 - NBFC Submission 4 March 2015) 2. MWA: The odour emission rate estimation method applied in accordance with the Best Practice Guidance for the Poultry Industry – Plume Dispersion Modelling and Meteorological Processing (PAE Holmes for DEEDI, May 2011) is based upon an emission ‘K Factor’ (scaling factor) of 2.2 (page 2, para 1). Comment: The ‘best practice’ chicken farms (relied upon for MWA’s ‘K Factor’ of 2.2) are built on slopes of less than 10%, with sheds that are oriented side-by-side, and the tunnel ventilating fans all facing the same direction, whereas the proponent’s chicken sheds would be located in a valley, on various ridges, all venting in various directions, some into other sheds - this is not considered best practice. Despite being described as industry best practice, the proposed development does not include any extraordinary emission control measures, so is likely to emit large volumes of untreated emissions that cannot be managed to an acceptable level once the facility is operational. 3. MWA: Recent odour sampling results from South East Queensland poultry sheds operating at a lower stocking density, as proposed for the Ridgewood development, have demonstrated that average ‘K Factors’ in the order of 1.7 are being achieved. If this contemporary odour emission rate basis is considered then the predicted 99.5th percentile 1 hour average odour concentration at the 185 Top Forestry Road dwelling would be 1.9 Odour Units (page 2, para 2). Comment: Using average ‘K Factors’ based on sampling from various SE Queensland chicken sheds operating under markedly different conditions, to calculate a predicted 99.5th percentile 1 hour average odour concentration of 1.9 Odour Units, is nonsense. 4. MWA: Aside from the inclusion of the additional discrete receptor no other changes were made to the odour modelling described in the Noise and Air Quality Impact Assessment (31 July 2014) (page 1, para 4).
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Comment: Since site-specific meteorological monitoring data has not been collected at the site, the modelling results have not been validated against meteorological observations. Given the relative complexity of the terrain of the subject site and surrounds, it is not clear that the meteorological modelling is a reliable representation of dispersion meteorology in the area surrounding the site. (Katestone Environmental Review — Odour Assessment of Proposed Poultry Farm, February 2015, page 2) Conclusions: 1. Since the Odour Assessment provided by MWA was undertaken without site-specific topographic and meteorological data, the MWA odour assessments (July 2015 and October 2015 are unlikely to be reliable predictions of odour impacts in the area. 2. Since the proposal is unlikely to operate as a ‘best practice’ meat chicken growing facility, the Odour Assessment provided by MWA modelled using a ‘K Factor’ taken from an average of ‘best practice’ sheds is unlikely to be a reliable prediction of odour impact in the area. 3. Despite being described as industry best practice, the proposed development does not include any extraordinary emission control measures, and is likely to emit large volumes of untreated emissions that cannot be managed to an acceptable level once the facility is operational. Therefore, we request that development application MCU12/0184 be refused. Submitted by Julia Walkden For No Broiler Farm Cooroy (NBFC) 423 Old Ceylon Road Cooroy QLD 4563 26 October 2015 Tel: 5442 6776