BUFFER DISTANCES FOR INDUSTRIAL RESIDUAL AIR EMISSIONS

BRUCE McCLURE General Manager CMPA comments on recently released draft guidelines for recommended separation distances for industrial residual emissions.

IN October 2012 the Environment Protection Authority Victoria (EPA), released a draft guide to separation distances intended to provide protection from residual odour and dust emitted by industry.

The document is called “Recommended separation distances for industrial residual air emissions”.The following comments are actual extracts from the guidelines document.

INTRODUCTION

This Guideline provides advice on recommended separation distances for odour and dust emitting industries from sensitive land uses. It is written for responsible authorities, industry, developers and the community to be used during strategic land use planning and during the assessment of planning permit applications.

This Guideline aims to support the effective management and allocation of land uses to:

• Protect public well-being and amenity
• Protect existing industry from encroachment by sensitive uses
• Prevent land adjacent to industry from being under utilised.

This Guideline replaces EPA Publication Recommended Buffer Distances for Industrial Residual Air Emissions (AQ2/86) 1990. In the past, the terms ‘buffer’ and ‘separation distance’ have been used interchangeably.

This document uses the term ‘separation distance’ to mean the space between industrial land uses and sensitive land uses.

PURPOSE OF GUIDELINE

The purpose of this Guideline is to specify adequate separation distances between industrial land uses and sensitive land. To achieve this purpose, this Guideline aims to:

• Provide clear direction on land uses which require separation
• Inform and support strategic land use planning decisions and the consideration of planning permit applications
• Prevent the encroachment of new sensitive land uses into existing industrial land uses
• Prevent the encroachment of new or expanded industrial land uses into existing sensitive land uses
• Identify compatible land uses that can be established within a separation distance area.

LEGAL STATUS OF GUIDELINE

This Guideline includes a summary of relevant requirements in the Environment Protection Act 1970. The technical details in this Guideline are suggested measures for meeting these requirements.

SCOPE OF GUIDELINE

This Guideline applies only to off -site residual odour and dust emissions from industries which have the potential to impact on well-being and amenity. Noise, vibration, and hazardous air emissions have not been considered in the development of the recommended separation distances outlined in this Guideline.

Decision makers and applicants should review all relevant regulations, policy and guidance to ensure that other land use separation issues, including noise, vibration and hazardous air emissions, have been appropriately taken into account.

For a copy of the actual report please refer to the EPA website and do a search for “Recommended separation distances for industrial residual air emissions”.

The CMPA prepared comments on the draft guidelines and submitted them to the EPA. The following are the CMPA’s comments. We will keep members advised on the outcome from the EPA on this important issue.

With respect to the draft document now under consideration, the CMPA would like to raise the following issues as provided by members:

1. That Work Authorities have a limited life, a minimal footprint and whose final end use can revert to sensitive land use.
2. The right to challenge the proposed separation distances as a result of site specific operational and environmental conditions is allowed as long as it is supported with scientific evidence.
3. That the interface land use area as identified in the compatible land uses gives examples to be encouraged but it may be appropriate for some of those industries listed in the recommended separation distance schedule to also be encouraged as there is presently clear examples of this outcome being successfully managed.
4. That the separation distances recommended had been used by the DPI in the past to minimise the potential impact on the well-being and amenities to sensitive land use pertaining to noise and vibration and could be considered in the scope of the guideline.
5. That the reference of respiratory silica within the recommended separation distances attached to applicable Work Authorities requires scientific studies to be provided identifying this as an issue by the EPA. This is required as material recovery, asphalt plants, unsealed roads, recycling and concrete businesses may also be implicated.
6. That the activity boundary for a Work Authority should be identified from its work plan and measured from its extraction limits and the footprint identifying the processing plant, stockpile and overburden areas.
7. That the separation distance between the activity boundary should be measured from the dwelling closest to the sensitive land use boundary as this is the method having been implemented by the DPI in the past. To apply it from the sensitive land use boundary will result in a financial restriction of entry to the market of all but the very largest operators. This will inevitably result in an increase to the carbon footprint of the industry due to cartage and escalation in the price of the materials being processed.

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