NoiseAssessment Report - ProposedExtractive Industry - Rocky Gully Road. Coominya Appendix F: Responses to Council Peer Review This Appendix is provided in response to issues raised in a peer review commissioned by Council of the assessmentas presented above (conducted by RB Acoustics Pty Ltd). The specific issues raised are reproduced below. Responses to these issues are presented in the following Sections. 1. The assessment of noise impact should be conductedagainst the 38dBA limit only. The derivation of the 46dBA and 41dBA limits by NMS is based on flawed logic. 2. The layout of activities is poorly documented. In addition, in contrast to hard rock quarries which usually conduct crushingand screeningactivities using fixed plant, it is apparent that the proposed sand andgravel processing activitieswill be conducted using a mobileplant. As a result, the operator will be able to move the major noise generating plant and equipment to anywhereon the site in response to processing needs. It appears that NMS have assumed that the mobileprocessing plant will be located solely in the centre of the designatedOperational Areas. While this might be a reasonable initial assumption, it does not allow the full impact of noiseemissionto be assessed.Specifically, if the plant were to operateat points much closer to the residences than assumed by NMS, higher noise levels will be generated. Compliance with the 38dBA noise level limit may bejeopardised as a result. 3. Based on measurement I have conducted on similar plant selections as those identifiedby NMS, the overall aggregated source soundpower level adopted by NMS may be 2-3dBA lower than that which is likely to occur in practice. This apparentunderstatement of the source sound power levels may be due in part to the methodology adopted by NMS to determine the soundpower levels. The understatement means that the actual noise levels may be 2-3dBA higher than predicted. (It is recognisedthat NMS have assumed conservatively that all noisesources will operatesimultaneously. Even though simultaneousoperation is unlikely to occur during normal operating conditions, it is prudent to ensure that at times of high demand for product - le when it may be necessary to operate all noise sources at the same time - that this scenario is examinedas the likely worst-case.) 4. NMShave considered noiseemissionunder calm wind conditions only. Higher noise levels will be encounteredunder downwind conditions. It is expectedthat the background noise levels and, hence, the relevantnoise level limits will increase correspondinglyunder downwind conditions. The increasein the noise level limit may be comparable to the increasein the downwind conditions, but NMS have not examined this inter-relationship or providedany valid justificationfor not considering downwind propagation in the noise modelling. 5. From an inspection ofthe noise contourplots showing the extent of noise emission with the 4.Sm high barriers in place, it appearsthat in each instancethe barrier has been placed only 3S-40mfrom the source of noise being assessed. For an operatingsand and gravel extraction facility, this is considered to be an impractically short separation distance. It is unlikely that extractive activities can be carriedout consistently and efficientlyat such short distances. Naturally, as the distance of separation increases beyond the 3S-40m point, the effectiveness of the barrier will be reduced. Consequently, the 9dBA reduction identified by NMS to be required is very unlikely to be achieved in practice. This will clearly jeopardise compliance with the 38dBA noise level limit. Furthermore, if the actual source soundpower levels are higherthan thoseassumed by NMS (as noted above at item 3), compliance with the 38dBA limit will befurther jeopardised. 6. It is noted that it is proposed that two OperationalAreas will to be established. For some reason, when assessingthe impactfrom extraction being conductedat the NW and SE extent of the site, NMShave chosen to adopt the furtherdistant of the two Operational Areas whensiting the processing facility within the noise model. This action runs counter to expectations of efficient operationof thefacilitywhereby the distance between the extractionand processing areas would be expectedto be minimised rather than maximised. The assumptionadopted by NMS also has the net effect of arbitrarilyminimising the degree of noiseemission to the NW and SE residences and, hence, showing lower emitted noise levels than would be expected otherwise. 7. A dredge is proposed to be used during for extraction during "wet years", but no acoustical assessment of the noise from dredging activities has been conductedor presented. 8. It is not uncommon for somesand andgravel operations to choose to extract materialusing a bulldozer to rip the materialrather than use and excavator to dig up the material. The level of noise generated by ripping of high-strength material in particular is higher than that generated by excavators. " NoiseMeasurement ServicesPty Ltd Report3773R5 31"October2019 52
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Appendix F - Somerset · Noise Assessment Report-Proposed Extractive Industry-Rocky Gully Road, Coominya F.3 Issue 3. Source measurementswere taken of actual machinery to be used
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This Appendix is provided in response to issues raised in a peer review commissioned by Council of the
assessmentas presentedabove (conductedby RB Acoustics Pty Ltd). The specific issues raised are reproduced
below. Responsesto these issuesare presented in the followingSections.
1. The assessment ofnoise impact should be conductedagainstthe 38dBA limit only. The derivation of the46dBA and 41dBA limits by NMS is basedon flawed logic.
2. The layoutofactivities is poorly documented. In addition,in contrast to hard rock quarrieswhich usuallyconduct crushingandscreeningactivities using fixed plant, it is apparentthat theproposedsand andgravelprocessingactivitieswill be conductedusing a mobileplant. As a result, the operatorwill be able to movethe majornoise generatingplantandequipment to anywhereon thesite in response to processing needs. Itappears that NMS have assumedthat the mobileprocessingplant will be locatedsolely in the centreof thedesignatedOperationalAreas. While this might be a reasonable initialassumption,it does not allow the fullimpact ofnoiseemissionto be assessed.Specifically,if the plantwere to operateat pointsmuchclosertothe residencesthan assumed by NMS,higher noise levels will be generated.Compliancewith the 38dBA
noise level limit may bejeopardised as a result.
3. Based on measurementI have conducted on similar plant selections as those identifiedby NMS, the overallaggregatedsource soundpower leveladoptedby NMS maybe 2-3dBA lower than that which is likely tooccurin practice. This apparentunderstatementof the source soundpower levelsmay be due in part to themethodology adoptedby NMS to determine the soundpower levels. The understatement means that theactual noise levels may be 2-3dBAhigher than predicted. (It is recognisedthat NMShaveassumedconservatively that all noisesources willoperatesimultaneously.Even though simultaneousoperation is
unlikely to occurduring normal operating conditions,it is prudentto ensurethat at times ofhigh demandforproduct- le when it may be necessaryto operate all noise sourcesat the same time - that this scenariois examinedas the likely worst-case.)
4. NMShave considerednoiseemissionunder calm wind conditionsonly. Higher noise levels will be
encounteredunderdownwind conditions.It is expectedthat the backgroundnoise levels and, hence, therelevantnoise level limits will increasecorrespondinglyunderdownwind conditions.The increasein thenoise level limit maybe comparableto the increasein the downwind conditions,but NMShavenotexamined this inter-relationship orprovidedany valid justificationfornotconsidering downwindpropagation in the noise modelling.
5. From an inspectionofthenoise contourplots showingthe extentofnoise emission with the 4.Sm highbarriers in place, it appearsthat in each instancethe barrierhas been placed only 3S-40mfrom the source
ofnoise being assessed.For an operatingsandand gravel extractionfacility, this is consideredto be animpractically short separationdistance. It is unlikely that extractiveactivities can be carriedout consistentlyand efficientlyat such short distances. Naturally, as the distanceofseparation increasesbeyondthe 3S-40m
point, the effectivenessof the barrier will be reduced. Consequently, the 9dBA reduction identifiedby NMS
to be requiredis very unlikely to be achieved in practice. This willclearlyjeopardisecompliancewith the38dBA noise level limit. Furthermore, if the actual sourcesoundpower levelsare higherthan thoseassumedby NMS(asnoted aboveat item 3), compliance with the 38dBA limit willbefurtherjeopardised.
6. It is noted that it is proposed that two OperationalAreas will to be established. For some reason, when
assessingthe impactfrom extraction being conductedat the NWand SE extent of the site, NMShave
chosen to adopt thefurtherdistantof the twoOperationalAreas whensiting theprocessingfacilitywithinthe noise model. This action runs counterto expectations ofefficientoperationof thefacilitywhereby thedistancebetween the extractionandprocessingareas wouldbe expectedto be minimisedrather thanmaximised.The assumptionadoptedby NMSalso has the net effect ofarbitrarilyminimising the degree ofnoiseemissionto the NWandSE residences and, hence, showing loweremitted noise levels than wouldbe
expected otherwise.
7. A dredge is proposedto be usedduringforextractionduring "wet years",but no acousticalassessment ofthe noisefrom dredgingactivitieshasbeen conductedor presented.
8. It is not uncommonforsomesand andgraveloperations to choose to extractmaterialusing a bulldozer torip the materialratherthan use and excavatorto dig up the material. The level ofnoisegeneratedby
ripping ofhigh-strength materialin particularis higherthan that generated by excavators. "
We understandfrom previouscommunicationwith DEHP that our methodology used to determine criteria is in
accordance with the Guideline - Planning for Noise Control. This Guideline is an appropriate guidance
document for assessment of proposed environmentally relevant activities (and presumably the basis for the
Approval issued by the DES). While Council may require assessment to additional criteria (and apply noise
restrictionsin addition to those imposed by the DES),the assertion that pj]]y the 38 dB(A)criterion should be
considered is unsupportable. It is unclear what 'flawed logic' is claimed in relation to calculationof the
PlanningNoise Levels and ComponentLevels, and no argumenthas been made to furtherconsiderthis issue.
Notwithstanding the above it is reiterated that the 38 dB(A) criterion is referred to in the report, in that it
represents the 'background creep' Leq criteria contained within the Environmental Protection (Noise)Policy
2008. This is the controlling design consideration in our report, on the basis that it is the most onerous
available and we consider ¡Lil criteria must be met for the development to be approved by the various
regulatorybodies. This detail may have been missed in the Acoustics RB review.
It is noted that the 2008 policy has been repealed, and the current Environmental Protection (Noise)Policy
2029 has explicitly removed the absolute value criteria for backgroundcreep. This notwithstanding,Council
has indicted that the 2008 policy is still relevant to its decision making processes, and additional assessment
has therefore been conducted to this 38 dB(A)daytime criterion. Resourceextraction is not proposedduring
the eveningor night periods.
It should however be noted that 'background creep' criteria refer to the LAeq,adj,Tdescriptor, representing
equivalent levels over the relevant time period (in this case, the 7am to 6pm daytime period during which
extraction activities are proposed). This descriptor is substantivelydifferent than the LAeqJhrdeSCriptor applied
to ComponentLevels under the Planningfor Noise Control Guideline. The modellingscenarios presented in the
body of this Report (and also adopted in the additionalassessment conductedbelow) represent continuous
activity during 'peak' periods of full activity. While this is a reasonableworst-·case assumptionfor assessment
to 1.AeadhrCriteria, it will substantiveiy overstate LAeg,..-s,. leveis, as no allowance is made for periods of
inactivity or reducedactivity for any of the modelled sources. Even during days of peak resource extraction,
individual sources (i.e.excavators,front end loaders)will operatesomewhat intermittentlythroughoutthe day,
and while Ihr of continuous activity is likely from each source (and concurrentactivity plausible),continuous
activity over an 11hr period without pause from any source is a patently unrealistic assumption. Nonetheless,
this methodology has been retained to provide a highly conservative estimate of potential impacts upon
backgroundlevels in the locale.
F.2 Issue 2.
The precise layout of extractive and processing activities will necessarilyvary over time, as extraction willfundamentally affect natural ground levels. Assessment has therefore been conducted under worst-case
scenarios, which do not include any screeningaround the operational areas (although stockpileswill provide
screeningto varyingdegreesthroughoutthe lifespanof the development). While mobile processingplant may
be used on site, it is understood that processing activity is not proposed outside of the operational areas as
assessed. Noise impactsfrom mobileplant closerto sensitive receivershas therefore not been modelled.
The locatingof processingactivitiesin the calculationscenarioswas not arbitrary, and reflected the proposed
stagingof extractiveoperations.This notwithstanding-·and to provide additional clarity·-·extractionhas been
assessedassumingprocessingat either of the two operational areas. These additional scenariosare presented
in Appendix G.
F.7 Issue 7.
Dredging activity is not proposedat this stage, and would only occur in response to significant changes to the
site (i.e.,significant flood events or atypical rainfall). This notwithstanding, potential dredge activity has been
included in the additional environmental noise calculations presented in Appendix G, which predicts
compliancewith criteria at all receiversduringthe daytimeperiod. Due to the topographyof the site, dredging
activitywould only occurat thesouth-eastand south-westextractionareas.
F.8 Issue 8.
Bulldozer extraction (i.e. 'ripping') was not proposed as part of the original developmentdesign, and was
therefore not assessed. It has been subsequently assessed that such activity could occur at the northern
extractionarea, although this would depend on the specific materials found during extraction, and excavator
extraction is expected as a general rule. To assess potential noise impacts from 'ripping' activities - should
they occur - bulldozers have been assessed in the additional environmental noise calculations presented in
Appendix G. Compliancewith criteria at all receivers is predictedduring the daytime period, subject to the
provision of 4.5m bunds or earth walls. It is understood that 'rlpping' activity will not occur at the southern
extractiveareas, due to constituentmaterials presentat theseareas.
F.9 Discussion
In response to the issues raised as part of the peer review process commissioned by Council, additional
environmental noise calculationshave been conducted,and are presented in Appendix G. Results from these
additional calculationsare presented in Tables F1- F8 below. As discussedin Section F.1, assessment has been
conducted to 'backgroundcreep' daytime criteria.
It is noted that marginal (up to 2 dB(A))exceedances are forecast under 'no bund' scenarios, which is whollydue to the arbitrary increase to sound power levels as discussed in Section F.3. Nonetheless,it is concluded
that ·-- subject to the recommended provision of acoustic bunds/earthwalls where applicable --· emissionsare
forecast to meet the daytime background creepcriteria under a highlyconservativeworst-casescenario.
Additional noise calculations have been conducted generally in accordance with the assumptions and
methodologyas presented in Appendix B. Sound power levels for the additional noise sources considered -namely, bulldozer 'ripping' activity and dredgingactivity- have been calculated from measurements previously
undertakenby NMS of comparable activity, and are presented in Table G1 below. Additionally,sound power
levels for excavator activity (with a gratuitousconservativeadjustmentas discussed in Section F.3) are shown.
Table G1: SoundPower Levels, in dB(Z), L.q. Includesadjustment for impulsiveness.