MCU12/0184 & ERA12/0087 Objection R Ritchie

Page 2

 Introduction
 Ridgewood is a quiet rural area, with scenic valleys, steep ridges and winding roads. The
 Applicant proposes to construct eight large chicken sheds along the ridges on his
 property, which is located in a largely rural residential district. The topography of the
 surrounding valleys and hillsides will assist the transmission of the noise, odour and dust
 from the chicken sheds to the neighbouring properties.

 The rural road leading to the property is unsealed, winding and narrow, and cannot be
 improved to a standard that would allow school buses, garbage trucks, residents and
 cyclist to safely share the road with 19-metre B-double trucks and semi-trailers.

 The MWA Noise and Air Quality Impact Assessment concludes that the potential impacts
 of noise, odour and dust can be minimised through best-practice emissions management
 and reasonable and relevant conditions. The L&R Traffic Engineering Report (31.07.2014)
 concludes that the low vehicle intensity of the poultry operations would have limited
 impacts.

 However, these conclusions are questionable because of the reports' many omissions and
 inaccuracies as outlined in this submission. The development proposal has the potential to
 exceed noise, odour and dust regulatory criteria, plus the site access and road safety and
 maintenance issues are insurmountable. It will not be possible to apply reasonable and
 relevant conditions to minimise these impacts.

 Further, there is the strong possibility that financial, practical and environmental
 constraints will preclude the implementation of recommended measures to minimise
 harm and nuisance.




  This submission covers the following topics:
  1. Noise, Odour and Dust Assessments .
. 2. Traffic Issues




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MCU12/0184                        Noise, Odour and Dust Assessments
Contents

1.3 Surrounding Land Uses               3

1.4 Proposed Development                4

2.0 Noise Impact Assessment             4

3.0 Odour Impact Assessment             5

4.0 Dust Impact Assessment              6

5.0 Top Forestry Road Dust              6

6.0 Conclusion                          6



1.3 Surrounding Land Uses
Land uses surrounding the site are predominantly rural residential, rather than
agricultural. In fact, of the 28 identified receptors, at most three are involved in rural
pursuits. The rest are best described as rural lifestyle blocks.

Many of the closest properties to the northeast are not heavily vegetated and wiII be
directly affected by noise, odour and dust. Many other properties, with residences set just
tens of metres from Top Forestry Road, wiII also be greatly affected by the dust generated
by heavy vehicle traffic.

Paragraph 3 states' /IIini/llu/ll setback distance between tile proposed poultry sl/eds and a
surrounding residence is approxi/llately 850 /IIetres'.

Based on aerial imagery data, the following points are noted:
• Nearest residences (136 and 146 Top Forestry Road) are 270 and 380 metres from the
nearest proposed shed.
• 111 Top Forestry Road is 780 metres from nearest proposed shed.

Section 1.3 also states 'Tile /IIajorihj of SlllTollllding dwellings are elevated above tile level of tile
proposed poultry slleds, witll intervening gullies'.
• The residence located at 50 Top Forestry Road is on the same contour (approximately
170 m) as many of the proposed sheds. This property is approximately 1km north east of
the nearest shed. This contour (between the residence and the sheds) appears to be
uninterrupted and may allow migration of noise and/ or odour.

• It is worth noting that the' gullies' mentioned are in fact used for hobby farming,
domestic food production, recreation and land conservation. MW A fails to assess these
land uses when considering the effects of pollution on surrounding properties.

Paragraph 4: Figure 3 does not reference the residences located at 136 and 146 Top
Forestry Road, which are 270 and 380 metres from the nearest proposed shed. There is also
no consideration of adjacent freehold lots that do not currently have residential land use,
specifically 124, 172 and 224 Top Forestry Road. These locations may become subject to
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sensitive land uses in the future and the modelling has not considered noise, odour and
dust impacts on these land parcels.

The final paragraph states: 'For the purposes of this asseSSlllellt twenhj-eigllt (28) of the
surrounding residences llave been identified as Rl to R28 as SIUJ7:Vll
                                                                     on Figure 3'.

At least 12 more nearby properties have not been included in the assessment as potential
receptors.

• Since the proposal includes the use of many nearby properties for the amelioration of
noise, dust and odour, these landowners are being denied their natural rights to build
sheds or associated property infrastructure on large sections of their land due to the close
proximity to the sheds. In addition, they would not be able to have unrestricted access to
work on and enjoy the parts of their property subject to the effects of the pollution.

• Many more district residents are effectively being expected to remain enclosed indoors
at various times of the day.


1.4 Proposed Development
Paragraph 1: 'It is proposed to construct poultry growing sheds 011 the subject site as a two-stage
deve/oplllellt. Stage 1 will cOlllprisefive sheds (Shed 1 to Shed 5), with the further three sheds (Slled
6 to Slled 8) to be collstructed as Stage 2 of the deve/0plllwt'.

The SCC Ordinary Meeting Updated Report (12 December 2013) states: 'The Queenslalld
Farllling Manager of Ingllallls has provided writtell confirlllation that most new facilities llave a
capacity of 240,000 birds and that a capacity of less than 200,000 may not be viable. As a result, the
applicmlt does not consider it feasible to reduce the 11Ilmberof sheds 011 the site'.
• Therefore the proposed two-stage development will not be viable, since the number of
birds at anyone time (in five sheds) would only be approximately 144,000.

Page 3, paragraph 2: 'TIle locations of tIle proposed poultry sheds on the subject site are shown on
Figure 4'.
Since the sheds must be aligned with the various ridgelines, possible placement of the
sheds is severely restricted. Figure 4 shows ventilation fans pointing in the direction of
several sensitive receptors and, in some cases, directly at the back of nearby chicken sheds,
as with 4,5 - 6, and 7 - 8. The Queensland Guidelines - Meat Chicken Farms (page 20 - A3)
states: 'Fans on tWIIIe/-ventilated sheds SllOUldbe located on the wd of ti,e shed tllat is furthest
frolll sellsitive lmld uses to lIIinimise the impacts of odour'.


2.0 Noise Impact Assessment
2.1
• Figure 5 shows the location of the noise data logger used to determine current ambient
noise levels. The data logger would have been influenced by noise from two dwellings
(136 and 146), the avocado operation and the shared access road. This data may not be
representative of lower ambient noise levels in the surrounding area. Noise from the
ongoing avocado industry has not been considered.

•     The 8-day period in Feb 2012 is not a significant time frame



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2.3.1
• Table 3 refers to forklift loading at the eastern end of sheds, whereas entries to the
sheds face many different directions - see Figure 4. An eastern entry will be impossible for
several sheds.

The forklifts will be a continuous source of noise during catchout periods.

Table 3 fails to mention noise generated by pneumatic feed systems.

Table 3 fails to mention noise generated by litter delivery, litter removal, shed cleaning,
and loading spent litter onto trucks to be removed from the site.

2.3.4
• Traffic projections should not be averaged. Since there would be several days of the
year in which 24 heavy vehicle trips occur in one day, the noise from this traffic should be
considered as an entity .

• Noise generated by heavy vehicles (with air brakes, reversing alarms, piercing horns,
and many huge tyres) cannot be considered the same level as noise as that from ordinary
vehicles.

•   On-site traffic noise has not been considered.


3.0 Odour Impact Assessment
3.1.1
• The assessment is not based on site-specific meteorological data. Wind inputs are
based on data from Tewantin and Nambour and predictions based on comparisons with
long-term average conditions at Tewantin, about 20 km away. Odour calculations can be
inaccurate without site-specific data.

• It is widely accepted that modelling results are dependent on the inputs of the model.
Without verifying (in detail) the inputs used, it is difficult to determine the accuracy of the
model results. We request that Council complete a rigorous assessment of the models,
prior to considering the recommendations of this report.

3.3.3
• Odour generated from the catchout times, removal and loading the trucks with the
spent litter, and shed cleaning has not been considered.

• The odour modelling (Attachment 7 - Figure AI) shows that the odour emissions
would extend beyond the property boundary of the site. Whilst the model does not show
the plume extending into locations of existing dwellings, it does show that nuisance
impacts would extend into the associated properties.

It is also likely that this would result in nuisance complaints being lodged to Council.
Council would be well aware of the likely costs associated with the management of
resultant complaints and execution of compliance actions.

• The Environmental Protection Act 1994, defines odour as a contaminant and therefore
nuisance odour needs to be dealt with under provisions of the EP Act.

• Considering the odour modelling results (Attachment 7 - Figure AI), it would not be
feasible to place conditions that prohibit odour, noise and dust nuisance beyond the

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boundary of the proposal property. If this proposal is approved, it is considered that the
neighbouring residents (and subsequently Council) will suffer the impacts of this
proposed development for years to come.


4.0 Dust Impact Assessment
4.3.3
• Extraction fans point directly at several sensitive receptors. The QlIeenslmld GlIidelines -
Meat ChickCll Farms (page 20 - A3) states: 'FailS on tll1l1/el-velltilated sheds shollid be located all
tile elld of the shed that is f"rtllest from sellsitive lalld IIses to millimise the impacts of odollr'.

Since dust is generated along with odour, fan location is crucial to minimise the impacts of
dust on sensitive receptors.

• Rainwater collected from roofs of homes in the area surrounding the proposal is
presently stored for domestic use. Residents are greatly concerned about toxic shed dust
from the sheds polluting their drinking water.

As stated in 3.1.1, modelling results are dependent on the inputs of the model. The inputs
for this modelling are not site-specific, they are based on averages of data from distant
locations, one near the coast and one to the southeast. Without site-specific data, it is
impossible to verify the accuracy of the modelling.


5.0 Top Forestry Road Dust
• Traffic cannot be averaged over days for this assessment. Twenty-six vehicle trips a
day (24 of these being heavy vehicles) will raise significant quantities of dust, year round.

• Many houses are located close to Top Forestry Road and within a kilometre of the
proposed development. Rainwater is collected from the roofs of these buildings for
domestic use. Residents are greatly concerned that the increased dust from traffic and
cartage of spent litter and chickens will pollute their drinking water.

• Heavy vehicles cannot be considered the same as ordinary vehicles. A B-double has 28
large tyres and is many times heavier, depending on the load.

• H&R traffic data collected in March 2014 includes readings for just one week,
although data was collected for two weeks. Why was this information excluded?

•    Traffic data for one week is not a significant range.

•    Dust from the constant traffic on internal unsealed roads has not been considered.


6.0 Conclusion
The new information indicates that the proposed development has the potential to exceed
noise, odour and dust regulatory criteria, and to raise insurmountable site access and road
safety issues. It will not be possible to apply reasonable and relevant conditions to
minimise these impacts, therefore this application must be refused.




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MCU12/0184                   Traffic Issues
Contents

1.0 Introduction                                                   8

2.0 TER limitations, anomalies and omissions                       8
      2.1 Limitations                                              8
      2.2 Anomalies and omissions                                  8

3.0 Road condition and function                                    9
      3.1 Top Forestry Rd                                          9
       3.2 Haul route roads                                        9
       3.2.1 Crystal St/Maple St roundabout                        9
       3.2.2 Crystal St                                           10
       3.2.3 Old Ceylon Rd                                        10
       3.2.3 Old Ceylon Rd/Cooroy-Belli Creek Rd intersection     10
       3.2.4 Cooroy-Belli Creek Rd                                10

4.0 Proposed mitigation   works - Top Forestry Rd                 10
      4.1 Section 1                                               10
      4.2 Section 2                                               10
      4.3 Section 3                                               10

5.0 Impacts
       5.1 Road condition and function                            11
       5.1.1 Traffic volumes - Top Forestry Rd                    11
       5.1.2 Road works and maintenance costs - Top Forestry Rd   11
       5.1.3 Interactions with haul route road users              11
       5.2 Residents' amenity                                     11
       5.2.1 Health risks                                         12
       5.2.2 Loss of amenity costs                                12

6.0 Conclusions                                                   12




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1.0 Introduction
The L&R Traffic Engineering Report (31.07.2014) concludes that the low vehicle intensity
of the poultry operations would have limited impacts on the local road network given its
present volumes and high standard of construction and surface condition, with only
minor works required on Top Forestry Rd.

This conclusion is questionable because of the report's omissions, anomalies and
limitations.

Given the actual road conditions and usage, the haul route roads are unsuitable for the
regular heavy vehicle traffic the poultry operation would generate. The volume, types and
schedules of these vehicles would have significant negative impacts on:
• road condition and function
• road safety
• residents' amenity
• property values.


2.0 TER limitations, anomalies and omissions
2.1 Limitations - the report does not take into consideration:
a) The 7 days survey data is not representative of traffic volumes and road users on Top
Forestry Rd.

b) The 80kph speed limit on Top Forestry Rd, Old Ceylon Rd and the Cooroy-Belli Creek
Rd from NO.129.

c) The vehicle accident history of the haul route roads from Top Forestry Rd to the Bmce
Hwy.

d) Present road condition and usage of the haul route.

e) The route for the shed waste removal trucks.

f) The Qld DTMR recommended 8 metres minimum unsealed road width for
Multi-Combination Vehicle use.

g) The Qld DTMR operational restriction on MCVs from obstructing the path of other
vehicles.

h) Heavy vehicles cause more noise, dust, odour and road damage than other vehicle
types.

i) Impacts on residents living beside the entire haul route.

2.2 Anomalies and omissions
a) The survey cameras were in place March 7-21, but only data from March 12-18 was
used.

b) The survey data does not distinguish between light and heavy truck use on Top
Forestry Rd.

c) People walking along Top Forestry Rd were not surveyed; only those crossing it and
King Parrot Lane.

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d) The report does not consider the usual volume reductions during public and school
holidays.

e) The report omits vehicle numbers for:
• the poultry operation's permanent and casual staff.
• Week 5 loss collection.
• Water deliveries - the operation's water needs wiII exceed stored supply during
extended dry periods.

f) Contradictory totals are given for vehicle volumes. For example:
Balch cycle lolal vehicles          App C                 Fig. 4.2
                                    244                   254

Balch cycle lolal heavy vehicles    App C lolals          MVC + AV + Rigid lruck lolals
                                    226                   210

Bird pick-up lolal heavy vehicles   App C lolals column   App C AV column
                                    108 trips/54lrucks    94 Irips/47 lrucks

g) Loading duration for a bird pick-up truck is given as 60 minutes (p 12) and 40 minutes
(App C).


3.0 Road condition and function
3.1 Top Forestry Rd
Top Forestry Rd is an 80kph, narrow unsealed road with unformed shoulders and poor
sightlines. It normally is graded once a year, and deteriorates quickly after heavy rain. The
only regular heavy vehicles are the Council rubbish trucks.

Its primary function is residential property access. Of the 31 properties accessed via Top
Forestry Rd, 27 are residential and have no alternative access. The only commercially
productive agricultural property is the applicant's avocado farm.

The road provides access to West Cooroy State Forest which has not been logged in more
tI1an 5 years and is now managed by Queensland Parks & Wildlife Service. Council
promotes the area as a bird-watching location (No 9 on Noosa Bird Trail Map) and a
mountain biking destination. Other recreational users include hikers and horse riders.

The report considers the road surface to be of a high standard with no potholing or
rutting. Before the April inspection, the road was graded twice in 2013 followed by a brief
wet season with local rainfall for Jan through Mar being 60% less than 2012. The road was
graded in July 2014 with no significant rainfall behveen the first and second inspections.
The report does not consider the degradation effects of heavy vehicle volumes, speed,
weight and articulation on the road surface compared to its current light vehicle usage.

The report claims intermittent road widening occurred during the July grading. While
roadside grass was scraped from the edges, there was no structural widening.


3.2 Haul Route Roads
Structural aspects of the haul route roads limit their suitability for the operation's heavy
vehicle traffic.

3.2.1 The Crystal St/Maple St roundabout and adjacent centre islands are not designed
for heavy vehicle encroachment; neither is the centre island outside the Noosa Christian

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College. Pedestrians, including students, use these structures when crossing Maple St and
to access nearby bus stops.

3.2.2 Crystal St limitations include a blind curve, many vehicles parked kerbside and a
busy intersection at Myall St opposite the Cooroy Golf Course.

3.2.3 Old Ceylon Rd has a 6.2m sealed road width and insufficient vertical clearance
between the unsealed shoulders and overhead trees. State road guidelines recommend a
35m lane width for MCV use of two lane sealed roads.

The Old Ceylon Rd/Cooroy-BeIIi Creek Rd intersection has a degraded surface, poor
sightlines and a Give Way sign. Given the 80kph speed limit on the Belli Creek Rd and the
sweep path of a heavy vehicle, trucks turning left into and right out of Old Ceylon Rd
increase the potential for accidents and the obstruction of other vehicles.

3.2.4 The Cooroy-BeIli Creek Rd beyond No. 129 is part of an established cyclist training
and event route with a minimum sealed road width, narrow shoulders, poor sightlines,
unmarked concealed entrances and an 80kph speed limit. The interaction of heavy trucks
with cyclists raises road safety concerns given the 2014 bicyclist road rules, which require
a 15m clearance when overtaking cyclists on 60+kph roads, while permitting drivers to
cross unbroken centre lines, and cyclists to ride two abreast.

4.0 Proposed mitigation works - Top Forestry Rd
The proposed minor mitigation works are inadequate and inappropriate. They do not
effectively address Top Forestry Rd's limitations to carry increased volumes of heavy
vehicle traffic. The works would increase road maintenance frequency and costs. The
proposed works, signage and vegetation removal would compromise the road's visual
amenity. Vegetation clearance also would destabilise road edges and increase the dust
spread range.
The works are based on an ARRB suggested minimum carriageway width of 55m. The
Qld DTMR classifies a 19m/50T B-Double as a Multi-Combination Vehicle. MCV route
guidelines recommend a minimum 8m width for unsealed roads (pI4). The standard
width of a prime mover is 2.9m (25m cab + 200mm each side for wing mirrors). The
combined width of two on-coming B-Doubles/ AVs would be 5.8m with no clearance
between vehicles. A minimum 55m road width does not address the safety risks
associated with the passage of on-coming heavy trucks, especially as the road shoulders
are unstable or non-existent. Nor does it mitigate the risks for other drivers.

4.1 Section 1 No mitigation works are proposed, however the narrowest part just before
King Parrot Lane is edged by large trees and a steep bank that has subsided twice in the
last 4 years.

4.2 Section 2 Widening parts of Section 2 would require the removal of large, mature
native trees on both sides of the road and the stabilisation of road edges and a subsiding
bank. L&R states that the 670m-long Section 2 has road widths of 5.0m - 5Am, but
recommends that only a 350m length be widened to 55m.

4.3 Section 3 The installation of a 45m wide, 236m-long, one-way system in Section 3 for
the benefit of the poultry operation would inconvenience other road users and impede
normal traffic flow. This system raises safety concerns given the road's long-term,
customary 2 lane use.

The alternative road widening proposal at chainage 1100m "involves significant slope and

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embankment stability work" (Appendix D). Both proposals impose road works and
maintenance costs on ratepayers.

No mitigation works are proposed for the junction of the site access road and Top Forestry
Rd. Trucks are required to drive forward when entering and exiting the access road,
however drivers would be unable to see approaching outbound vehicles.

The collection of the carcass bins would compromise road safety and obstruct traffic if, as
stated previously, the collection trucks wiII not be entering the site. The location of the
carcass bins relative to the school bus stop is also of concern.


5.0 Impacts
5.1 Road condition and function
5.1.1 Traffic volumes - Top Forestry Rd

The operation's forecasted vehicle numbers would generate the following % volume
increases:
29.5% minimum daily traffic
21.5% maximum daily traffic
8.3% maximum weekly traffic
15% maximum weekly truck traffic.

The survey recorded zero truck movements from 0:00am - 6:00am. A projected 9 heavy
truck trips for this period would occur during bird pick-ups.

It is disingenuous to say that a 25% peak volume increase due to seasonal agricultural
variations is not unusual for unsealed rural roads (MWA p27), when the only seasonal
variation on Top Forestry Rd is related to the applicant's avocado production which is
accounted for already.

5.1.2 Road works and maintenance costs - Top Forestry Rd
The poultry operation would increase the frequency and costs of road maintenance, while
the structural mitigation works would impose additional costs on ratepayers.

5.1.3 Interactions with haul route road users
Introducing heavy vehicle traffic to the haul route roads would increase road safety risks
for motorists, pedestrians and cyclists.

The interaction of heavy trucks with school buses and rubbish trucks that stop and start
frequently poses considerable safety risks. There are many sections on the route where
rubbish trucks and buses cannot pull off the road when stopping, and overtaking is not
possible.

During a live bird pick-up, there would be significant interaction with the 7-9am school
and commuter traffic (buses and cars) and pedestrians on the haul route, especially at the
Maple 5t/ Crystal 5t roundabout and on Myall 5t. On alternate Monday mornings there
also are 2 rubbish collections.

5.2 Residents' Amenity
MWA (p 27) claims that a peak volume of 26 vehicles per day represents a minor
unreasonable nuisance potential on Top Forestry Rd without considering that 24 of those
26 vehicles are heavy trucks. An ambient road dust assessment was not undertaken.


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The operation's vehicle volumes, types, loads and schedules would have significant
negative amenity impacts on residents adjacent to the entire haul route. The use of average
volumes and the claim there is no operational traffic on 30/63 days/ cycle does not
mitigate the negative impacts of night traffic and maximum vehicle days, especially as the
calendar days of these events change each batch cycle. Also, the report does not take into
account that:
• road surface and a heavy vehicle's weight and speed determine the amount and range
of noise, dust and vibration.
• the nature of the noises and odours generated by the operation's vehicle types and
loads are more intrusive than other sources.
• the bird pick-up time span would exceed 10 hours if more than 10 trucks are required.

5.2.1 Health risks - dust, noise odour and vibration
Health risks arising from the operation's heavy vehicle traffic include:
• respiratory illnesses associated with air-borne contaminants from road dust, vehicle
fumes and load contents (i.e. carcasses and manure).
• contamination of domestic water supplies as there is no reticulated water supply to
Top Forestry Rd.
• sleep deprivation during bird pick-ups with up to 3 truck trips/hour starting at
02:30am.

5.2.2 Loss of amenity costs
The physical, psychological and financial well-being of residents along the haul route
would be compromised for the applicant's financial gain. Increased costs imposed on
residents by the operation's vehicle traffic include:
• heath care
• property and water supply maintenance.

Residents also would face the negative financial implications of decreased property values
and saleability.


6.0 Conclusions
None of the applicant's Traffic Engineering Reports have considered the entire haul route,
including its:
• structural limitations
• customary use by pedestrians, cyclists and tourists.

The poultry operation's vehicle traffic would impose unacceptable risks and costs on haul
route road users and residents. Significant negative impacts include:
• increased road safety risks
• increased road works and maintenance costs
• residents' loss of amenity.

The conclusions and recommendations of the L&R Traffic Engineering Report are
questionable. Its omissions, anomalies and limitations indicate the operation's vehicle
traffic and its impacts have been underestimated. Further, should the poultry operations
require vehicles larger than the designated 19m / 50 tonnes B-double, then Council would
have to consider the need for a route assessment and approval.




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