EPA Separation Distances
DR ELIZABETH GIBSON, General Manager of the CMPA.
The CMPA made a submission to the draft EPA Separation Distance Guideline (December 2022) publication number 1949. This Guideline is intended to replace the EPA Recommended Separation Distances for Industrial Residual Air Emissions – March 2013 Guideline1518:
Purpose of the draft Guideline
“The guideline provides recommended minimum separation distances between odour- or dust-emitting industrial land uses and sensitive land uses.
The guideline aims to:
• provide clear direction on which land uses require separation;
• inform and support strategic land use planning decisions and the consideration of planning permit applications;
• prevent new sensitive land uses from impacting on existing industrial land uses;
• prevent new or expanded industrial land uses from impacting on existing sensitive land uses;
• identify compatible land uses that can be established within a separation distance area.”
CMPA Submission
That:
• For quarrying without blasting the previous separation distance applies: 250 m (as opposed to the proposed 500 m) which remains consistent with the separation distance for “Mine for other minerals”, 250 m.
• Construction and demolition waste and “mine for other minerals” may contain RCSD.
• Compliance with the proposed guideline constitutes compliance with the EP Act and the General Environmental Duty.
• The rational “based on recent experience” needs to be expanded: EPA to provide the specific “examples”. If the “recent experience” is from non-compliant sites, this is a compliance issue. It is not a reason to change the separation distances. Also, no mention is made of wet processing sites and how they are to be treated.
• The document (table 4) appears to be confused as to what is an extractive industry and if it includes a quarry. The table must clarify if quarrying is an
extractive industry, i.e. Mining and extractive industry separation distances marked with an asterisk are minimum distances and should not be varied.
Note that CMPA will commence developing separate environmental nuisance dust and environmental respirable crystalline silica dust (RCSD) management guidelines and templates in 2023.
Questions posed by EPA
Q1. Does the proposed guideline include enough information and guidance to support land use and development decisions where industry separation distances apply? Please explain.
No, because
“Mine for other minerals – crushing, screening, stockpiling and conveying of other minerals” retains the 250 m recommended separation distance from the previous guideline (2013) yet quarrying without blasting is increased to 500 m (previously 250 m) with no justification or evidence of case studies.
Q2. Is the proposed guideline clear, useable and relevant?
How could it be improved?
No, because:
• Compliance with the proposed guideline does not constitute compliance with the EP Act 2017 and the General Environmental Duty as stated on p.8 of the guideline.
• RCSD in recycled construction and demolition waste needs to be recognised.
Q3. How will the proposed changes in the guideline affect you or your organisation?
As an industry association for quarries there will be a profound impact on Members with respect to the increased buffer for quarrying without blasting to 500 m which was previously 250 m.
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