NBFC submission 26Oct2015

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).