Objection to A. J. Bush's application to Council to award a Planning Scheme for "Animal Byproducts Rendering & Recycling Plant, Associated Infrastructure and Grazing" Lot 87 on Plan W.311629 and Lot 5 on Plan WD2285 County of Ward, Parish of Bromelton.
We are not opposed in principle to the establishment of a Rendering Plant at the site nominated by A. J. Bush; nor are we opposed to the company itself. Indeed we have found A. J. Bush, through its spokespersons, to be most sincere in its attempts to explain its position, answer concerns and sustain a dialogue with interested community groups and individuals.
We are also impressed with the presentation and content of its Environmental Impact Statement. It is written, for the most part, in layperson's terms and gives a comprehensive assessment of the designated area, and a detailed account of its proposed development and its projected effects.
Nevertheless we believe there are issues to be addressed, which would be far better addressed at this stage when Council has substantial leverage, than later. Council is no doubt aware of how difficult it is to impose new conditions on established industries. Council would also realise that, if A.J. Bush were to become a model for industries of its type, the onus (supported increasingly by legislation) would be on other such industries in this shire to be more mindful of legitimate environmental concerns.
If these issues, outlined below, can be satisfactorily resolved (or, in the case of expensive problems like carriageways, commitments given to address them) the Logan and Albert Conservation Association (LACA) will withdraw this objection.
SITING OF PONDS AND IRRIGATION OF WASTEWATER
The proposed ponds are to be sited on the slope above Sandy Creek.
This area is outside the designated Bromelton Industrial Zone.
Water could, potentially, infiltrate Sandy Creek under certain scenarios (e.g. overflow, leaching, irrigation run off). Up until now it's been spared pollution by industry.
The ponds will be offensive - by sight and conceivably by smell - to residents just across Sandy Creek. This will doubtless deflate the values of their properties.
Dispersal of Wastewater appears uncertain.
Though, according to the E.I.S., wastewater may amount to no more than 25mm per annum over both the adjoining Boystown property and Bush site, there is no definite plan for its dispersal. It may be that, unless this is clarified, Bush employees may opt to dispose of it in the most convenient manner - by pumping it out of the ponds onto the slopes above Sandy Ck. Then it could become a problem - for Sandy Ck.
Recommendations:
- That the aerobic ponds be sited just to the west of the proposed factory structure, in the Swan Ck catchment on what is currently Boystown property. As, unfortunately, Swan Ck is already heavily polluted by AMH operations this will at least avoid the possibility of spreading the problem. Also this would further lessen the visual impact which Bush has otherwise sought to minimise. [E.I.S. p91,2 5.5] Bush has two avenues though which to effect this:
- By requesting the State Government to negotiate the swapping of slopes above Sandy Ck for the slopes to the west of its site. This is possible, if complicated.
- Bush currently has an easement to the Boystown property with generous rights of usage. It may be able to site its ponds by direct agreement; this is a possibility if Boystown is guaranteed use of the water from the ponds.
- A plan of irrigation that avoided the Sandy Ck catchment be sought and approved by council.
TREATMENT & MONITORING OF ODOUR
Non-condensable vapours from the low temperature processing lines will be incinerated, their noxiousness being minimised before they leave the stack. However odours from the working space within the factory, apart from those in the blood batch drying and meal milling areas, will merely be forced up a chimney - the reasoning being that they are relatively inoffensive, and the speed of ejection, together with the height of the chimney and their temperature, will ensure their ready diffusion.
There appears to be no ongoing monitoring of either the odour units on the floor, or the efficacy of this means of disposal.
Detection of faults in the system appears to be dependent on observant employees - noticing either an increase in floor odour or aberrant readings on measuring devices.
This is quite unreliable. Faults could develop gradually or an employee could be negligent.
Vehicles enter and leave raw material delivery areas via automatic doors. It is argued that because the whole building is under negative pressure very little odour will escape during the few minutes each vehicle is negotiating the entrance (perhaps with a trailer).
In busy times, or when there is no obvious scrutiny, the temptation will be to leave the doors open permanently.
Just how effective the negative pressure argument is remains to be seen, and there appears to be no plans to monitor it.
It was admitted in the EIS, and by experts at the 'open night' that, under conditions with a very light breeze, material from the smoke stacks could diffuse slowly, and move in a concentrated body in a direction determined by the prevailing wind and the physical features. This is unavoidable.
If the odour, particularly from the open factory areas, is much greater than anticipated this will compound the discomfort now created by other industries in the area.
Under such conditions it will be very difficult to determine the origin of the smells, and Bush could find itself unfairly accused.
Recommendations:
- Council ensure that a permanent monitoring system, staffed by a Council employee/s, is in place. Reaction to odour is quite subjective, so perhaps Council staff could monitor on a rotational basis - on both the factory floor, local position that catch the prevailing winds. It is assumed that any costs involved in this, or any other necessary action by Council, be met by A. J. Bush.
- Bush agree to an inspection/maintenance program where a designated employee checks equipment, gauges and odours on a regular (daily?) basis; a maintenance log book, subject to irregular Council inspection, be kept by this person.
- Written undertakings be procured by Council that automatic doors remain in use, and Council employee (see 1.) checks for level of escaping odours.
- An extensive study be undertaken, before the factory begins operation, to establish existing background odour levels. With the current proposed timeframe, background odours could be monitored over a full year, and give a substantial and accurate basis for later comparison.
THE IMPACT OF A.J. BUSH-GENERATED VEHICULAR TRAFFIC
Significant numbers of A. J. Bush delivery vehicles will travel through the commercial centre of Beaudesert during the busy afternoon period, each week day.
These will add to congestion around the High School when buses are loading children.
It is highly likely that even though they are sealed vehicles, offensive smells will escape, especially in hot weather. It is certain they will add to the general noise and unpleasantness of the main road.
They will increase the risk of road accidents throughout their route in the shire, and potentially cause traffic snarls from the outskirts of Brisbane.
Verbal assurances have been given that Bromelton House will not be used as an A. J. Bush carriageway. In the event that pressure from the business houses and residents of the inner town force A. J. Bush to forego these assurances:
This road is in no fit state to accommodate large numbers of heavy vehicles. Also the bridge at the Boonah Rd end may not be able to withstand the loads.
Rural residents would have to contend with these vehicles.
Ilbogan Bridge is in a poor condition and the increased traffic will quickly damage it even further. Sandy Ck Road must, of necessity, be used by Bush vehicles.
Both the bridge and Sandy Ck Road will soon require upgrading. At the moment that would mean the Shire ratepayers foot the bills.
Recommendations
Neither the current scenario for A. J. Bush trucks (via the heart of town, and over Ilbogan Bridge) or its alternative (via Bromelton House Rd) appear adequate. But the trucks have to use roads. As the State Government has been instrumental in facilitating (forcing?) the proposed development it has an obligation to provide the necessary transport infrastructure. It is imperative that Council press this obligation. It may be that the old Beaudesert bypass blueprints be resurrected.
If funding (or a commitment to) is not obtained from the State Government prior to an acceptance of the Bush proposal one of the above options may run indefinitely. That would demonstrably detract from the quality of life in this shire.
We believe all agreements entered into by the State Government, Council and A. J. Bush should be spelt out in detail, and penalties stipulated for breach of these agreements. Council should also have the power to shut down the plant if breaches are severe, or consistent enough.
However it is our assessment that none of the problems outlined above are insurmountable. A. J. Bush has been prepared to admit to its past problems, and the justifiable basis of its previously poor image. It has demonstrated its desire to be seen as an honest player, and an asset to the business world of the future.
We trust that Council will be able to achieve a satisfactory resolution of these issues, and any others identified by itself or concerned Shire residents, and Bush can become a model for future development.
Darcy Moore
on behalf of Richard Zoomers, President of LACA
