ARMSTRONG CREEK EAST PRECINCT STRUCTURE PLAN ADVISORY COMMITTEE HEARING BALOG BROILER FARM. 84 Groves Road, Connewarre

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ARMSTRONG CREEK EAST PRECINCT STRUCTURE PLAN ADVISORY COMMITTEE HEARING BALOG BROILER FARM 84 Groves Road, Connewarre Land: Lot 2, Lodged Plan LP 210971 Part Crown Allotment 2 Section 4A Parish of Connewarre, County of Grant Consultant/ Expert Witness: Ian Farran M.Eng.Sci. Grad. Dips. Agribusiness, Electronic Computing Agricultural Engineering Consultant Agribiz Engineering 5 Montrose Place Highton 3216 Mob: 0427 345883 Ph. (03) 5229 0492 Fax (03) 5229 7566 e-mail: farran@vic.chariot.net.au January 2010 last saved 2/02/10 1

1. INTRODUCTION A Planning Permit was issued 10 march 2004 for the expansion of the broiler farm at 84 Groves Road, Connewarre. The farm is situated to the east of Barwon Heads Road (approximately 4.25 kilometres south west of Marshall). Prior to 2004 the broiler farm consisted of 4 broiler sheds 3 sheds with 33,000 birds each and 1 shed with 50,000 birds, therefore an existing total bird capacity of about 149,000 birds. The planning application in March 2002 was for an additional broiler shed 130m x 20m, with a capacity to shelter 50,000 chickens. The total farm capacity is now about 199,000 birds. The farm is under contract to Turi Foods Pty Ltd (formerly Bartters (which was formerly Steggles Ltd.), a major chicken meat processor in Australia with a processing plant in Geelong. The planning application for the establishment of the additional broiler shed was finally determined by the requirements of the Environment Protection Authority for assessment of odour impact and what remedial activities could be undertaken should the expansion impact on the amenity of the neighbouring properties. Considerable odour modelling was undertaken on behalf of the applicant as part of an Environmental Risk Assessment. The Greater Geelong Planning Scheme has been amended with the effect of rezoning the Armstrong Creek Area as an Urban Growth Zone, this includes the property of A. & I. Balog and their broiler farm operations. This rezoning means that residential development could occur up to the western boundary of the Balog property and potentially the residents amenity in the Residential Zone will be impacted by the existing broiler farm operations. I have been instructed to review the odour modelling previously carried out, in the context of the possibility of development for residential purposes of land within 1000 metres of the Balog s broiler operations (or property) in accordance with the Precinct Structure Plan. In reviewing the odour modelling, the main issues are the odour emissions used in the model and what criteria the model outputs are to be assessed against. last saved 2/02/10 2

2. SCHEDULE Name of Operator : Location of Farm : A. & I. Balog 84 Groves Road Connewarre 84 Groves Road Connewarre Land Description (Crown Allotment or Numbers) : Lot 2, Lodged Plan LP 210971 Part Crown Allotment 2 Section 4A of Connewarre, County of Grant Number and size of Existing Broiler Sheds : 3 No. 122.4 x 13m 2 No. 130 x 20m Total Bird Capacity : 199,000 Number of silos : 12 Distance to nearest Neighbouring Houses in each direction from Sheds (whichever is closest): 490m house to the North West 1500m house to the South East 1200m house to the South Distance to proposed residential developments: Western boundary: 80 metres Harkness Land: 480 metres approx Source of Water Supply : Town water with adequate capacity Road Access is from : Existing access from Groves Road. Number of Feed Trucks per week (average) : 2-3 trucks per week Number of trucks removing litter and manure at end / start of batch (every 9 weeks) : 8-9 trucks per batch last saved 2/02/10 3

3. ELEMENTS OF PROPOSAL Appendix 1 sets out the relevant planning elements used in the Victorian Code for Broiler Farms 2001 that was contained in the Planning Application submitted to the City of Greater Geelong.. 4. ODOUR MODELLING 4.1 Odour Emissions (Broilers) Odour is generated as a number of complex processes. Therefore, it is recommended that odour emissions at specific farms be characterised using site specific measurements based on the Australian Standard, for the measurement of odours. The modelling is based on the chickens age varying from day old to 56 days over 5.5 batches each year, for this situation a method outlined in Pacific Air & Environment (2002)RIRDC (2002) has been used. Statistical analysis of available data have indicated that the relationship between ambient temperature and (OER) is best explained by a power law, expressed as: OER MAX =0.38 T 2.4 Where: OER MAX = maximum odour emission Rate (ou/s/1000birds) (CEN odour units) T = ambient temperature ( o C) The temperature is taken from hourly weather data which is representative of the area an existing Geelong meteorology file. Emissions at any point in the batch cycle can then be estimated using the following equation: OER t = OER MAX x f Where: OER t = odour emission rate at particular stage (ou/s/1000birds) in the batch cycle OER MAX = maximum odour emission rate (ou/s/1000birds) Based on CEN odour units. f= fraction of emissions at particular stage in the batch cycle The fraction of emissions at any point in cycle (f) can be estimated using the information in the following Table Assumed odour Generation Profile as Function of Batch Age Day of Growth Cycle Proportion of Maximum OER (f) 0 17 0.15 17 24 0.42 24-29 0.68 29 34 0.94 34- end of batch 1 last saved 2/02/10 4

Ausplume modelling can then be used to determine whether these emissions lead to acceptable impacts at sensitive receptors such as nearby rural houses, or in this case residential development zones. When the planning application including odour modelling for the expansion of this farm in 2003 was assessed by the EPA a request was made that the modelling also be done using EPA supplied odour emission data for weeks 4 7 in the production cycle as a constant source (data provided is shown in Appendix 2) an average emission rate of 1176 OU/sec/1000 birds placed was used in the modelling. 4.2 Odour Assessment Criteria In attempts to quantify the odour levels that provide reasonable protection against community odour annoyance, various regulatory authorities in Australia and elsewhere have developed numerical criteria for the evaluation of odour impacts. However, no widely accepted criteria have yet been, developed for the assessment of odour impacts. This reflects the difficulties of odour sampling, measurement and modelling, combined with the lack of suitable data on odour levels associated with annoyance and complaints. Assessment criteria have changed substantially over the past decade, in response to changes in the understanding of odour nuisance and odour quantification. The Victorian EPA Air Quality odour criteria as set out in the Broiler Code (2001) is 5 OU, 3 minute averaging, 99.9% non exceedance at a sensitive receptor where an Environmental Risk Assessment is required.. On July 1 2002 the Victorian EPA adoped the Australian Standard for Odour Measurement (CEN odour units) which produces a different odour unit definition compared to the the B2 odour unit used by the EPA Victoria up until then. Comparisons between B2 and CEN odour units suggest that 1 B2 odour unit was equivalent to 2 CEN odour units. The recently released Victorian Code for Broiler Farms (Sept 2009) continues to use a criteria of 5 OU 99.9 percentile, 3 minute averaging for sensitive uses in accordance with the State Environment Protection Policy (Air Quality Management) No. S 240 Friday 21 December 2001 part of the EPA Act (1970) Schedule A when an Environmental Risk Assessment is required. 19. For industries involving intensive animal husbandry, an integrated set of criteria may be applied to ensure beneficial uses are protected. The set of criteria should include: Location in an area with a low density of sensitive land uses. That is, premises must be located in a rural zone; The location is consistent with integrated land use planning considerations such as the long term future of the surrounding land and the likely use of the intervening land between the proposal and sensitive uses; Works designed in accordance with a set of industry performance standards approved by the relevant authorities; last saved 2/02/10 5

operations conducted in accordance with an environmental management plan (EMP) approved by the relevant authorities; and completion of a risk assessment that includes modelling of emissions showing that the predicted maximum odour levels modelled accordance with Schedule C do not exceed five times the odour detection threshold (3-minute averaging time, 99.9 percentile) at and beyond the property boundary. 18. Emissions of mixed odorous substances, such as those from sewage treatment farms, rendering plants and intensive animal industries may be offensive and therefore need to be minimised and controlled to ensure that the beneficial uses of the environment are protected. General odour is defined in SEPP (AQM) as an unclassified air quality indicator of local amenity and aesthetic enjoyment of the air environment. The design criteria for new sources of general odour is the odour detection threshold (1 odour unit) and should be applied at and beyond the boundary of a premises. VICTORIAN CODE FOR BROILER FARMING DEFINITIONS: SENSITIVE USE also known as sensitive land use A use that involves the presence of people, causing the use to be sensitive to amenity considerations such as odour, dust and noise. Sensitive uses (also referred in other documents as sensitive land uses) include a dwelling, a dependant persons unit, a residential building, a hospital, a school, a day care centre, a caravan park and other uses involving the presence of people for an extended period. Sensitive use does not include recreational areas such as parks and sporting facilities. VICTORIAN RESIDENTIAL ZONE Any zone classed as residential under Clause 32 of the Victoria Planning Provisions. For example, as of 2009, this includes Residential 1 Zone, Residential 2 Zone, Residential 3 Zone, Low Density Residential Zone, Mixed Use Zone, Township Zone. responsible authority The municipal (local) council, unless the planning scheme specifies otherwise. Appendix 1 in the Victorian Code for Broiler Farms, Summary of Setback Measures to Meet the Code s Objectives and Standards Table 2 gives a minimum setback requirement from the nearest external edge of any broiler farm shed, or litter stockpile/ compost pile (relevant approved measure in this Code in brackets) of 1000 metres for a Residential Zone. It would appear there are two criteria that the modelling should be assessed against: The Victorian Code for Broiler Farms which requires a 1000 metre separation from broiler shed to residential zone. last saved 2/02/10 6

The SEPP (AQM) general odour concentration criteria of 1 OU 3 minute averaging 99.9 percentile at the boundary of the residential zone. Using the Ausplume model version 5.4 (Note: The only significant difference between AUSPLUME version 6 and the previous version (version 5.4) is an improved ability to predict the ground level impact of emissions from stacks more than 100 metres tall.. Not relevant to this application. Appendix 3 shows the model text file runs. The following separation distances have been determined for the Geelong Region using local meteorology data and based on an hourly odour emission rate as explained above which is also factored for age on the basis shown in the table above. The Ausplume plots are attached. At the EPA request at the time of the Planning Application assessment another set of modelling runs have been conducted for a constant odour emission of 1176 OU/sec/1000 birds placed. The following odour modeling has been carried out on this proposed expansion of the broiler farm based on 3 minute averaging. 1.) Full Development 199,000 chickens modeling based on age and temperature as above. Separation Buffer metres Boundary Buffer meters 199,000 bird broiler farm Code 2001 200,000 bird broiler farm Code 2009 550 472 220 100 99.5 Percentile 10 OU 410 99.9 Percentile 5 OU 750 1000 99.9 Percentile 1 OU >2000 Metres Odour units Separation 99.9 99.5 98 Nearest houses 1 516 14.5 4 0.8 2 579 11.3 3 0.7 3 601 10.8 2.6 0.5 4 909 4.5 1 0.1 5 1186 3.2 0.6 0.1 last saved 2/02/10 7

2. Full Development 200,000 chickens modeling based on EPA data constant emission as above. Separation Buffer metres Boundary Buffer meters 200,000 bird broiler farm code 550 220 99.5 Percentile 10 OU 1250 99.9 Percentile 5 OU 3500 approx 99.9 Percentile 1 OU >5000 Metres Odour units Separation 99.9 99.5 98 Nearest houses 1 516 113 37 9 2 579 99 29 7.4 3 601 103 31 4.9 4 909 59 13 1.2 5 1186 40 11 0.96 The 2001 Code and a number of VCAT decisions prior to the Code release were based on separation distances established by Ausplume modeling to a criteria of 5 OU 99.5 percentile 3 minute averaging, using a temperature and age of bird relationship (different to the relationship used in my modeling) developed by Tim Pollock at Egis Consulting at the time. (CRC November 2003). The modeling output for the temperature and age emission rates above shows it meeting the 5 OU 99.5 percentile criteria. The 2009 Code uses a formula to determine the required minimum separation distance and which is based on the proposed farm capacity and the requirements set out in the Classification of broiler farms section of this Code. Separation distances provide sufficient space to minimize the risk of offensive odour and dust emissions under both routine and abnormal (or upset) conditions adversely impacting the amenity of existing sensitive uses. The greater the separation distance and the boundary setback, the lower the probability of offensive odour and dust adversely impacting the surrounding community. A broiler farm is classified as Class B if all of the following apply: the farm capacity is less than or equal to 400,000 birds the development can meet the minimum separation distance requirement (as defined by Formula 1) but this distance is not fully contained within the broiler farm boundary. last saved 2/02/10 8

The separation distance for a Class A or Class B broiler farm must be at least 250m or as otherwise calculated in accordance with the following formula (whichever is larger): D = 27 x N0.54 D = Separation Distance (metres) N = farm capacity /1000 0.54 is an exponential factor that is applied to N. The formula is applicable to farms up to or equal to 400,000 birds 5. CONCLUSION The Balog Broiler Farm meets the separation criteria 472 metres for the point of odour discharge (not the sheds) of the tunnel fans to the nearest house established by the 2009 Victorian Code for Broiler Farms. The Code and the SEPP (AQM) recognise a different odour separation distance is required for a sensitive use (rural house) and a more intensive Residential Zone. The review and analysis of the odour dispersion modelling is that the residential zone development will need to be about 2000 metres from the broiler farm to meet the SEPP (AQM) criteria of 1 OU, 3 minute averaging 99.9 percentile for the odour emissions based on temperature and age of chickens, or much greater than 5000 metres based on the EPA constant average emissions data of 1176 OU/sec/1000 birds placed. In my opinion the EPA approach required in the planning process and carried on here does not pass the reality check, in that the modelling outputs bear no resemblance to the required separation distances in the Codes. The 2000 metres set back is well in excess of the 1000 metres required by the Victorian Code for Broiler Farms separation to a residential zone. So at a minimum there should be a 1000 metre separation between broiler sheds and the boundary of the residential zone. If the EPA Act 1970 is to be complied with the proponents of the residential zone may need to satisfy the Environment Risk Assessment requirements of the SEPP (AQM) in relation to the existing broiler farm. last saved 2/02/10 9

6. REFERENCES VICTORIAN CODE FOR BROILER FARMS IST EDITION SEPT 2001 2 ND EDITION SEPT 2009 STATE ENVIRONMENT PROTECTION POLICY (AIR QUALITY MANAGEMENT) EPA VICTORIA 2001 RURAL INDUSTRIES RESEARCH & DEVELOPMENT CORPORATION (2002) Environmental Database for the Intensive Meat Chicken Industry. Compiled by Pacific Air & Environment. CRC (2003) Australian Poultry CRC Review of Modelling, Emission Measurement and Treatment Of Odour and Dust Emissions from Broiler Farms. Report Nov 2003 last saved 2/02/10 10

7. APPENDIX 1 PART OF PLANNING APPLICATION FOR FARM EXPANSION IN 2002-2004 7.1 Element 1 LOCATION AND SIZE 7.1.1 Objectives E1 O1 To ensure that the location, size, development and operation of a broiler farm does not have unacceptable impacts on: the health and amenity of residents on the property itself, on neighbouring properties and in the surrounding area, having regard to odours, dust, noise, waste waters, litter and other emissions or discharges to the environment; natural environmental and ecological systems and habitats, having regard to drainage patterns, areas liable to flooding, the location of catchment areas, streamlines, and local vegetation and wildlife; the efficiency and biosecurity of farms the visual quality of the landscape road capacity and safety, including the uses and values of recreational routes the ability to maintain high-quality agricultural land in soil-based production. 7.1.2 Criteria E1 C1 E1 C2 E1 C3 The siting and site coverage of broiler farm sheds (and, where proposed, litter storage areas) provide appropriate boundary buffer, separation distance and setbacks from dwellings on the site, road frontages, side and rear boundaries, sensitive land uses on neighbouring properties, residential zones, Low Density Residential zones, Rural Living zones, watercourses and water bodies. The location of broiler farms recognises the need to minimise the transmission of disease between poultry farms. Adequate setbacks are provided to allow for landscaping and screening of broiler farm sheds, other buildings and storage areas on the property. 7.1.3 Best Practice Guidelines E1 G1 Sheds are to be located on the development site to achieve the boundary buffer, separation distance and setback requirements. The potential for future sensitive land uses and farm expansion, and the prevailing meteorological conditions and local topographical features, have been taken into account in determining these requirements. last saved 2/02/10 11

For practical purposes the new shed will be placed to the south of the existing sheds, using the existing access roads and services. The proposed Broiler shed and associated earthworks are located and designed so that stormwater drainage will be transferred to the east of the new building and collected in a dam excavated to provide the soil material to elevate the building foundations. E1 G2 The minimum and actual setback requirements from the nearest wall of any farm shed are: from a watercourse or water body: sufficient to ensure that there is no run-off to surface waters. Required Distance Actual Distance (metres) (metres) 30 375 from proposed shed from a residential zone*: 1000 Approx. 4000 from a Low Density Residential Zone 750 Approx. 4000 or Rural Living Zone* from a dwelling on the broiler farm property: 100 250 from proposed shed 75 from existing shed 180 from fans from a road: 100 500 from proposed shed 300 from existing shed from a side or rear boundary 50 125 from existing sheds. [* a zone included in the Victoria Planning Provisions] E1 G3 The distance between sheds on different poultry farms meets the requirements of the Broiler Industry Biosecurity Code currently being developed. Until this Code is finalised, the following separation distances apply: between an existing broiler farm and any alternative form of intensive poultry farming between a new broiler farm and any alternative form of intensive poultry farming between a commercial broiler farm and a broiler breeder farm: Required Distance Actual Distance (metres) (metres) 500 Greater than 1km a minimum of 1,000 metres two to five kilometres N/A Note: Some of the guidelines for Element 5 (Waste Management), such as guidelines E5 G8 and E5 G17, are also concerned with issues of facility location. last saved 2/02/10 12

7.2 Element 2 DESIGN AND CONSTRUCTION 7.2.1 Objectives E2 O1 To design and construct broiler sheds to minimise off-site impacts and promote the economic and operational efficiency of broiler farms. 7.2.2 Criteria E2 C1 E2 C2 The development is integrated into the landscape, and utilises site topography, existing vegetation and the strategic planting of trees and other vegetation (see Element 7). The design and layout of the broiler farm provide for: the orderly management of feed the efficient placement and collection of birds the efficient placement of fresh litter the collection, handling and treatment of all wastes the minimisation of off-site impacts on neighbouring land uses adequate landscaping of the site the use of external cladding materials which are non-reflective and finished in neutral colours that blend with the surrounding landscape the maintenance and appropriate use of the balance of the site not directly used for broiler farming (the development of a whole farm plan is encouraged). E2 C3 The layout provides an optimal design in response to the site and local environmental conditions and features. Factors taken into account include the following: existing access and internal roads existing vegetation and areas of significant or valuable habitat existing dam(s) watercourses, drainage lines and water bodies slopes and other topographic features, including drainage considerations existing buildings local meteorological conditions such as wind patterns (direction and speed) and atmospheric stability views into the site existing site services (for example, the location of water mains and electricity supply) boundaries and easements the siting of litter stockpiles. last saved 2/02/10 13

7.2.3 Best Practice Guidelines 7.2.3.1 Design and construction E2 G1 E2 G2 The orientation of broiler sheds complements the characteristics of the development site (for example, the topography, meteorology and other natural features of the site, and the layout of nearby roads). The design and construction of broiler sheds and associated works meet technical and environmental standards which minimise the potential for offensive odours and unacceptable levels of dust and noise beyond the property boundaries, and facilitate the cleaning and maintenance of collection areas. The proposed shed is of the latest proven design using computer controlled ventilation, water and weight monitoring systems, similar to that constructed in 1999. The original three sheds have been converted from natural ventilation to tunnel ventilation with the exhaust fans to the east of the buildings away from neighbouring houses. 7.3 Element 5 WASTE MANAGEMENT 7.3.1 Objectives E5 O1 To manage wastes from broiler farm operations to minimise odour and dust generation and prevent pollution of surface water, ground water or land. 7.3.2 Criteria E5 C1 E5 C2 E5 C3 Broiler farm operations meet the requirements of the State Environment Protection Policy (Waters of Victoria), State Environment Protection Policy (Groundwaters of Victoria) and State Environment Protection Policy (Prevention and Management of Contamination of Land) (currently being developed). Management and disposal systems for waste litter and dead birds are designed and operated so that odour generation and the likelihood of disease transmission are minimised. Broiler farm operations and management practices will comply with the Guideline for Manure Management being developed by DNRE. Best Practice Guidelines 7.3.2.1 Removal of litter E5 G1 E5 G2 Waste litter is transported from the farm in covered tip truck vehicles to avoid spillage and dust emissions. Spillages of litter will be cleaned up immediately to minimise the likelihood of stormwater contamination. last saved 2/02/10 14

E5 G3 E5 G4 E5 G5 Litter will not be contaminated with dead birds. Litter is cleaned out after each batch, it is removed from each shed immediately after the removal of birds wherever possible (except where adverse environmental conditions prevail see guideline E5 G5), directly loaded onto trucks and taken off-site for processing, reuse or disposal. Litter removal is not undertaken at times when environmental factors (for example, wind and temperature) increase the likelihood of offensive off-site odour or dust impacts. last saved 2/02/10 15

7.3.2.2 On-farm litter management (short-term stockpiling) E5 G7 E5 G8 This will not be practiced on this farm, the manure and litter will be removed offsite. 7.3.2.3 On-farm litter use E5 G10 This will not be practiced on this farm 7.3.2.4 Dead bird management and disposal E5 G13 The volume of material to be handled warrants the use of the freezer already on site and a weekly pick up of dead birds by an industrial collection system. 7.3.2.5 Waste disposal E5 G17 No solid or liquid farm effluent or waste is disposed of within 800 metres of any potable water supply take-off controlled by a statutory authority, within 200 metres of any watercourse supplying potable water, or within 100 metres of any surface waters, in accordance with the State Environment Protection Policy (Waters of Victoria) last saved 2/02/10 16

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8. APPENDIX 2 ODOUR EMISSIONS DATA PROVIDED BY EPA last saved 2/02/10 18

9. APPENDIX 3 AUSPLUME MODELLING 9.1 Modelling using variable emissions input last saved 2/02/10 19

9.2 Modelling using constant odour emissions supplied by EPA last saved 2/02/10 20