Bill's workshop

Bill had been meaning to build a new workshop for years. The old one leaked, the floor was mostly dirt, and the power board had been installed by a previous owner who apparently regarded electricity as a matter of faith.

Tom reckoned the old shed was perfectly serviceable, provided you didn't work in it when it rained, blew, or got dark.

Dog had no opinion on the subject. He slept under the bench and considered the place satisfactory.

Anyway, Bill eventually got around to building a new workshop. Nothing extravagant. A decent shed, a concrete floor, room for the tractor and a small office where he could keep the farm records without the mice eating them.

Across Burnett Highway stood a large fertiliser factory, built some five years earlier. It was a complicated affair with pipes, fans, chimneys and a great deal of machinery that nobody in the district quite understood.

The company had explained it all at a public meeting before construction. They said it was environmentally responsible, would create local jobs, and was perfectly situated because there was nobody living close enough to be bothered by it.

They had an eight-hundred-metre buffer, they said.

Tom remembered that part particularly well.

"Eight hundred metres," he'd told Bill afterwards. "That's a bloody big buffer."

"Where is it?" asked Bill.

"Well, some of it's on their place."

"And the rest?"

"On everyone else's, apparently."

Bill had considered this for a moment.

"That's handy. I might put my cattle yards on their land and see how they like it."

But nothing more was said, the factory was built, and life carried on.

Until Bill finished his workshop.

It was a good shed. Tom had helped with the roof, though Bill maintained that Tom's principal contribution had been advice about how he would have done it differently. Dog supervised proceedings from the shade of the ute.

Bill installed a desk, a kettle and a chair in the office, and began spending his mornings there doing accounts and ordering parts.

Three weeks later, a government vehicle arrived.

The inspector was a pleasant young fellow with a clipboard, an instrument case and an expression suggesting he had recently discovered something unfortunate.

He asked Bill how long he'd been working in the shed.

"Three weeks," said Bill.

"Every day?"

"Most days."

"How many hours?"

"Depends how much work I've got."

The inspector looked towards the fertiliser factory.

"Ah," he said.

This was followed by a considerable silence.

Eventually he explained that Bill's workshop was now a sensitive receptor for air-quality purposes.

Bill looked at Tom.

Tom looked at Bill.

Dog scratched himself.

"A what?" asked Bill.

"A sensitive receptor. A place where people are exposed to emissions."

"Been exposed to plenty of things in my time," said Bill. "Mostly Tom's opinions."

The inspector patiently explained that the factory's nitrogen dioxide emissions had been modelled years earlier, before Bill's workshop existed. The model showed concentrations over Bill's property that exceeded the applicable air-quality objective.

"So the pollution's been coming over here all along?" asked Bill.

"According to the modelling, yes."

"And it wasn't a problem before?"

"There wasn't a sensitive receptor at this location."

Bill considered this.

"So the pollution's been here for five years, but it only became a problem when I put up a shed?"

The inspector looked uncomfortable.

"Essentially."

Tom nodded slowly.

"Remarkable stuff, pollution. Knows when you've built an office."

The inspector went away and wrote a report.

The report went to Brisbane, where several people read it and asked for another report.

That report went to the Council, where it was referred to the planning department, the environmental health department and the Council's solicitors.

The factory owners were informed that they might have to restrict operations until they could demonstrate compliance with the air-quality requirements at Bill's workshop.

They were furious.

They had spent millions building the factory. Council had approved it. The State had issued environmental approvals. They had detailed plans, technical reports and a consultant who could produce another report at short notice.

And they had an eight-hundred-metre buffer.

The company director telephoned the Council.

"We were assured there were no sensitive receptors within eight hundred metres!"

"There weren't," said the Council officer.

"Well, there is one now!"

"Yes."

"How did that happen?"

"Somebody built a shed."

The director was speechless.

This was not a condition he had encountered in the business plan.

A fortnight later the factory stopped operating.

The environmental regulator had required the company to demonstrate that it could meet the applicable air-quality requirements at the new workplace. Until that was resolved, the company could not continue operating as before.

The company engaged lawyers.

Council engaged lawyers.

The company's lawyers argued that the factory had been approved first and should therefore be allowed to continue.

Council's lawyers replied that approval did not give the company permanent control over neighbouring properties.

The company's lawyers pointed out that their client had relied on Council's approval when investing millions of dollars.

Council's lawyers began examining the original planning assessment.

The State's lawyers were consulted about the environmental approval.

Bill received a letter asking whether he would consider relocating his office.

He showed it to Tom.

"They want me to move the office."

"Where to?"

"Outside the eight-hundred-metre buffer."

"Where's that?"

"Other side of the paddock."

Tom thought about it.

"So they built a factory on their land, claimed a buffer on yours, and now want you to move your office to keep their factory running?"

"That's about the size of it."

"Seems reasonable," said Tom.

Bill looked at him.

"From their side of the road," Tom added.

The matter eventually reached a special Council meeting.

There were councillors, Council officers, company representatives, consultants, lawyers and a number of people who appeared to have come chiefly to see what happened.

The mayor asked how an approved industrial facility could suddenly find itself unable to operate.

The planning officer explained the difference between existing receptors and possible future receptors.

The environmental consultant explained the modelling.

The company's solicitor explained the financial consequences.

Council's solicitor explained that there were several difficult legal questions.

A councillor asked whether the factory's emissions had increased.

No, said the consultant.

Had the environmental standard changed?

No, said the officer.

Had the factory moved?

No.

Had the workshop been built illegally?

No.

There was a long silence.

"So," said the councillor, "we approved a factory because there was nothing nearby, and now we've got a problem because somebody built something nearby?"

"That's one way of putting it," said the planning officer.

The mayor asked why they hadn't anticipated this possibility.

Nobody volunteered an answer.

Another councillor suggested that perhaps industrial facilities should be located somewhere specifically intended for industrial development.

The room went quiet again.

The planning officer explained that Council did, in fact, have land zoned for industry.

"Well, why didn't they build it there?" asked the councillor.

The company's representative began explaining the advantages of the rural location.

Chief among these was the eight-hundred-metre buffer.

By Christmas the factory was still shut.

The company had commissioned further modelling, Council had received several legal opinions, and the State was considering what additional controls might be necessary before operations could resume.

Bill's workshop remained exactly where he'd built it.

He was sitting in the office one morning when Tom arrived with the newspaper.

"Council's legal bill is up again," said Tom.

"How much?"

Tom told him.

Bill whistled.

"Could've built a fair workshop for that."

"Could've built half an industrial estate," said Tom.

They sat quietly for a while, drinking tea.

Across the highway the factory stood silent, its chimneys rising above the paddocks.

Dog was asleep beneath Bill's desk.

"Funny business, planning," said Tom.

"How's that?"

"Well, they spent all that money proving the factory was far enough away from everybody."

"Yes."

"Then you built a shed."

"Yes."

"And now they've spent even more money proving it isn't."

Bill looked across the road.

"Should've built the factory in an industrial estate."

"Suppose so."

"Would've saved everyone a lot of trouble."

Tom nodded.

"Except the lawyers."

Dog woke, stretched, and wandered outside to relieve himself on the corner of the new workshop.

He was the only one involved in the affair who had never needed a consultant to tell him where the boundaries were.

Both sides of the road matter

Why do we have industrial estates?

Why do councils establish industrial estates rather than simply allowing industries to build wherever land is available? One important reason is long-term compatibility between different land uses.

Industrial activities can generate noise, emissions, traffic and other impacts that make them unsuitable neighbours for homes, farms, schools and businesses. Planning schemes recognise this by identifying land for industrial development and establishing controls to manage potential conflicts with surrounding areas.

Importantly, this isn’t just about what exists today. Industrial facilities may operate for decades, during which surrounding properties can change ownership, develop new businesses or accommodate new buildings and activities.

Industrial zoning provides a framework for managing those relationships over time. It gives industry greater certainty about its operating environment and gives neighbouring landowners greater certainty about what can happen around them.

That certainty matters to councils and environmental regulators too. Their job is considerably easier when potentially incompatible land uses have been considered and managed through the planning system, rather than being left to collide years after development approval.

Which brings us to BYV’s proposed biosolids facility at Glan Devon.

An industrial facility on rural land

BYV proposes to establish a high-impact industrial facility on rural-zoned land beside Burnett Highway, north of Nanango. One of its arguments for choosing this location is separation from surrounding sensitive receptors. BYV has repeatedly referred to an 800-metre separation distance as an advantage of the site. Interestingly that 800m seems to be a self-imposed buffer used to primarily argue the case against siting the operation on existing industrial land.

But there are complications with a buffer or separation distance - especially when it is larger than the property in question. there’s a fundamental difference between having 800 metres of separation from existing neighbours and having an enduring, controlled buffer around an industrial facility.

BYV owns approximately 185 hectares across two adjoining properties. Yet when I plot an 800-metre circle around the approximate location of its proposed processing buildings, the circle extends well beyond that landholding.

It crosses Burnett Highway and encompasses substantial areas of neighbouring rural properties.

The land within that circle is not reserved for industrial buffering. It belongs to other people, who retain the right to seek and undertake development consistent with the planning rules applying to their properties.

BYV may have separation today, but it does not control the land needed to maintain that separation tomorrow.

What BYV’s own modelling shows

The situation becomes more interesting when we examine BYV’s preliminary air-quality modelling.

Its modelling predicts elevated nitrogen dioxide (NO₂) concentrations extending beyond its property boundaries. Overlaying the modelled concentration contours on the cadastral map shows concentrations exceeding Queensland’s current one-hour air-quality objective extending across Burnett Highway.

The model reports a maximum one-hour concentration of 380 µg/m³. Queensland’s current one-hour objective is 164 µg/m³.

I’ve written about some of the problems with the underlying emissions estimates previously. The model is poorly representative of the proposed operation. The testing used polyurethane dust at approximately 70% throughput, with emissions subsequently scaled by a factor of 1.42. That does not establish the emissions variability associated with full-throughput operation using the proposed commercial feedstocks.

So even before resolving the modelling’s limitations, BYV’s own preliminary results identify a potential air-quality conflict extending onto neighbouring land.

And that brings us back to the reason industrial estates exist.

What happens when the neighbour develops?

Imagine that five years after BYV begins operating, the owner of the block across the highway decides to build a workshop and office for their farming business.

They need somewhere to maintain machinery, store equipment, manage their business and accommodate staff. Nothing especially unusual for a rural enterprise. The proposed development must satisfy the applicable planning and building requirements, but it is entirely reasonable to contemplate such a use on rural land.

Now there is a workplace within the area affected by BYV’s modelled NO₂ concentrations. It's a new 'sensitive receptor'

Queensland’s State Code 22 guidance recognises that workplaces, including business offices, can be sensitive receptors for air-quality assessment. It also requires consideration of possible future sensitive receptors, not merely those present when the application is lodged.

The farmer hasn’t moved their property closer to BYV. They haven’t changed the location of the industrial facility or altered its emissions. They have simply developed their own land.

And an area that previously had no identified sensitive receptor may now contain one.

That’s the issue with relying on the existing distribution of sensitive receptors as justification for locating a long-lived industrial operation on rural land. The absence of a receptor today provides no assurance that one will not exist tomorrow.

Whose problem does that become?

Suppose the new workshop is lawfully established, and subsequent air-quality assessment identifies unacceptable exposure to emissions from BYV’s facility.

Who is responsible for resolving the conflict?

The neighbouring landowner may face complications in developing or operating a legitimate rural business. BYV may face requirements to improve emissions controls, restrict throughput or otherwise modify its operation.

Council may find itself dealing with competing development interests, while the State environmental regulator must determine whether the industrial facility can continue operating within its environmental obligations.

What began as a question about the location of a proposed industry becomes an ongoing problem for the landowner, the operator and two levels of government.

And by then the facility may be built, substantial capital invested and commercial contracts established. Resolving the problem could be considerably more difficult than preventing it in the first place.

This is the long-term uncertainty that industrial land-use planning is intended to reduce.

Both sides of the road matter

Burnett Highway is a road, not an environmental boundary. Air emissions don’t stop at the centreline, and the existence of the highway does not constrain future lawful development on the properties across it.

BYV’s proposed rural location may provide separation from existing sensitive receptors, but its own landholding does not encompass the claimed 800-metre buffer. Its preliminary modelling also shows why that distinction matters.

The critical question is whether the proposed industrial facility can continue meeting its environmental obligations as surrounding rural properties develop over the coming decades.

If its continued operation depends on neighbouring land remaining undeveloped, or on future owners avoiding otherwise legitimate activities, that is a fundamental limitation of the proposed location.

It is also a potential long-term problem for Council and the State, who will be left managing the consequences of today’s planning decision.

That’s why we have industrial estates. And that’s why both sides of Burnett Highway matter.

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