ResponsetoApplicantReport

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1. Total vehicle trips including details of size of vehicles, purpose of
trip, time of trip and number of trips per day.

Top Forestry Rd traffic volume and dust
• Current traffic estimates of around 200 vehicles/are based on no publicly
available statistics.

• Recent traffic counts by local residents puts the daily traffic at around 75
movements per day.

• Dust from multi-wheeled heavy vehicles is much greater than for four-wheeled
traffic.

• Therefore broiler farm traffic will increase road dust by an amount greater than
even 25%.

Operational vehicle trips
Appendix A indicates a maximum of 204 vehicle movements per batch cycle.
This figure does not include vehicle numbers for:
a) litter removal if required (MWA estimates 12 semi-trailers);
b) fuel deliveries;
c) increased integrated avocado production with a 33% orchard expansion.


Conclusion
If these basic anomalies in the traffic data provided by the applicant are any
indication, then the overall quality of the response, and indeed the traffic studies
to date, shows a complete lack of credibility within a framework of changing
plans that make it near impossible to determine what in fact would happen with
traffic issues should this application be approved.

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2. Feasibility of requirements to provide to seal to 50m in front of
affected properties on Top Forestry Road or to enter into an
Infrastructure Agreement with Council.

Road Works
• Conditional clause requested by applicant for him to pay 50% of cost of work
(bitumen and rock walls) does not include an applicant contribution to annual
maintenance of proposed works.

• Report says proposed works are conceptual only and subject to detailed survey,
but does not say by whom and whether the survey would be subject to council
approval.

• It may not be within the authority of the SCRC to agree to this condition of
approval without consulting the new Noosa Council.

Proposed bitumen work
• Bitumen width of 6 metres is below state specifications for new works.

• With no road base preparation, end product is not durable and will wash after
limited use and especially in the wet season.

• With no drainage works indicated, bitumen will alter road drainage degrading
road surface, edges and slopes of all properties adjacent to road.

• The impact of vehicle movements between bitumen and dirt sections will
degrade road.


Conclusion
Proposed roadworks are basic and unsatisfactory. There is no plan for a proper
road upgrade to legal standards for a safe carriageway, rather the proposed
works will result in a deteriorating gravel road with band-aid bitumen strips that
will quickly crumble away.

Proposed works do not address road safety and functionality issues on rest of
haul route.

Proposed works will compromise road functionality and safety, be ineffective for
dust reduction, and since it is unnecessary for present traffic volume and vehicle
types, should not have to be a subsidy by ratepayers to the applicant.

This action will leave the new Noosa Council with a huge annual repair and
maintenance bill.

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3. Composting and stockpiling methodology including data on
management of emissions during these processes.
Management of Emissions
• The response offers a review of its MWA noise, dust and odour assessment,
however odour modelling should not be applied to noise and dust emissions.

• The applicant has not provided an on-site noise assessment, and refers to litter
spread as the only on-site dust source.

• None of the applicant’s reports consider emission impacts on the on-site
dwelling.

The unworkable condition
The applicant requests the inclusion of a condition of approval that would
exempt dwellings on certain lots (built or as yet un-built) from odour guidelines
subject to complex habitation guidelines.

It may well not be within council’s authority to agree to this condition as
operational compliance is the responsibility of DAFF and questions of covenants
are complex legal matters best not adjudicated by council.

Compost turning machine
Example cited by Seymour Rural Equipment Pty Ltd does not work well as a
plastic sheet lifting and lowering operation (Sales Manager pers comm). There is
no evidence the PH Equipment product would work with plastic sheeting that
will need to be tightly secured on the windy ridge tops.

Prevailing winds
Winds on the ridges of West Cooroy are regularly above 10km/h from various
directions, therefore there would be great difficulty combining the necessity to
turn the compost with the requirement not to operate on many days.

Litter spreading
• This new version of the litter spreading regime is totally untested and the
composting time suggested (4 to 5 weeks), is only to suit operational purposes.
This would result in odiferous un-composted material being regularly spread
around the farm.

• Dampening of litter during high wind events would only exacerbate odour.

• Also, there is no allowance made for the differing compost times that cooler
winter weather would entail.

Odour
• The new model does not take into account odour characteristics from different
operational sources.

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• Suggesting the new model has lower figures than council’s PEL and previous
MWA model needs to be further investigated thoroughly for veracity.

Litter disposal off site
• The proposal to remove litter off site when there is excessive odour is a
prescription that could see many extra road trips that ensure odour being further
distributed within the area far from the farm.

Noise
• A thorough noise impact study has still not been presented to Council.

Conclusion
Proposed composting methodology remains basic and unsatisfactory. There is no
plan for treating and disposing of wastes and no compliance monitoring plan for
operations.

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4. Water quality management particularly addressing potential
impacts from use of shed waste and composting material for
fertilising the orchard and any associated run off.

Comments by Peter Edmiston, Bio Track Pty Ltd

The effect on runoff water quality can be estimated as:

Loading (kg nutrient)/year    x   export proportion in runoff = kg nutrient/year
in runoff

There is 1030 m3 with a density of ~0.9 = 900,000 kg compost

If the compost has 2% nitrogen (need to measure this to confirm the value) then
the N load is 18000 kg/year. (Published range (attached) is 2.4-4.2% N so the
total nitrogen load may be up to double this value).
The disposal area is 38 ha so the average loading rate is 473 kg/ha/y and 4 times
this rate if applied to 25% of the disposal area.


Sugar cane farms use a lot of nitrogen (300-400 kg/ha/y). The rule of thumb is
1/3 is lost (drainage, runoff, volatilisation). Sugar cane has a high biomass
growth per year with a lot of crop either exported as green cane or burnt with the
stems used for sugar. Avocado crop removal is modest by comparison.

Therefore a loss of 1/3 for fertilised avocados on sloping ground in a high
rainfall area is reasonable.

The third can be partitioned into drainage losses, runoff and volatilisation.

Assuming the soils are not saturated for very long and the N release is gradual
then volatilisation losses will be modest, 20% would be an upper estimate.
Depending on the slope, placement and rainfall intensity runoff losses will be in
the range of 40% to 60% with the remaining lost as deep drainage.

So:

0.33 lost x 0.6 x 0.8 runoff x 18,000= 2850 kg/y runoff loss & 1900 kg/y drainage
loss
0.33 lost x 0.4 x 0.8 runoff x 18,000= 1900 kg/y runoff loss & 2850 kg/y drainage
loss

The drainage loss is to the groundwater. This forms base flow to local waterways.

The application area is thought to be 38 ha and the runoff losses are estimated to
be in the range of 93 to 62 kg N/ha/y with deep drainage losses in the same
range.

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Typical export rates for nutrient export are listed below. Market gardens are the
highest exporter at 26 kg N/ha/y. The estimates of nutrient loss from the
disposal area are significantly higher than those reported for market gardens and
much higher than those reported for other land uses.

I have attached a couple of references.

The Western Australian paper is of less importance. It is a modelling exercise not
a measurement process. The rate of export for the Leschernault catchment was
about 1.8 kg N/ha/y and the stream water quality was not acceptable. I am
guessing there are other factors apart from the loading rate contributing to water
quality problems in the Leschernault catchment.

Conclusion
There will be a significant reduction is storm water quality and or deep drainage
nutrient concentrations associated with the proposed nutrient loading rates
within the disposal area.

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5. Feasibility on reduction of size and number of sheds.

Comment
Applicant’s response (via attached Inghams Enterprises Pty Ltd letter) that this is
not possible due to financial unviability of a smaller operation means that the
over-sized development proposed should be rejected on the grounds of scale.