18 Pindari Road, Lesmurdie WA 6076 Holmes.Enviro@iinet.net.au www.holmesenviro.com.au
13th March 2013
Holmes Environmental Pty Ltd ABN 20 688 071 053 ACN 143 154 456 ph 08 9291 9284 mob 0428 244 822
Mr Kim Taylor General Manager
Environmental Protection Authority Locked Bag 33 Cloisters Square Perth WA 6850
Dear Kim
EPA Guidance No.3 – Separation Distances
About three years ago, subject to Crown Law advice, DEC scrapped the policy of allowing the movement of mobile plants, previously categorised as mobile premises, to be relocated subject to LGA approval. The consequence is that now each time a mobile plant is temporarily located, a full works approval assessment and licensing regime is required – even for a two-week stay.
As a second consequence, the EPA No.3 Guidance Statement is now used as an assessment criteria for each of these applications where Statement No.3 is a show stopper. Insofar as Appendix 1 deals with mobile plants, it does not distinguish between a full-sized, permanently located plant and a small mobile machine. Hence the DEC does not take into account that there is a difference between any of the large metro quarries and a 40 tph crushing & screening plant nor any difference between a full-sized asphalt factory and a 35 tph mobile plant. The same applies for other mobile operations.
Clearly for a small plant likely to be operating in a regional area for not more than a few weeks or else operating on an intermittent basis, this makes absolutely no sense at all. I have experienced considerable difficulty in attempting to locate an asphalt plant in some remote areas, having site after site rejected where there were perhaps one or two residences located within the 1km buffer zone. As an example, local businesses offered sites, but these were rejected by the DEC. Eventually we found a site at a distance from town where ownership was vested in the LGA – who then took eight months to provide approval for use of an abandoned gravel pit! This is the sort of gob- smacking red tape that makes life more difficult and more expensive for those living in regional areas.
My recommendation is that the Guideline No.3 be revised not to include mobile plants. In this eventuality, the DEC could then assess applications on the basis of mitigation of standard criteria.
In regards to full-sized asphalt plants, the No.3 Guidance Statement also creates a severe problem for DEC assessing officers who have admitted as much to me. It is my guess that the Guidance was based on primitive plants that would belch smoke and fumes unless properly managed. I recall when at the Kwinana office some years back, we had to write operating conditions into the licence of a now primitive asphalt plant that was causing odour problems for local businesses. Smoke and fumes would belch each time the pot was loaded! Times have changed and modern asphalt plants now include digital control and monitoring systems and have advanced bag-house design.
The problem for fixed-location plants is that it is now virtually impossible to locate an asphalt plant in any industrial area in Perth where the 1km separation distance would allow except for the Kwinana heavy industrial area. Clearly, the reasonable answer here would be for the assessment to be based on stack-test criteria and odour assessment. Aspects of the No.3 Guidance Statement have fallen seriously behind the times and are now in the ranks of useless red tape that does nothing more than hinder development where technology is now way ahead of EPA policy.
I would be happy to hear your thoughts on this matter.
Kind regards
Rob Holmes
