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Submission on Resource Consent Application (Hastings District Council New Zealand)

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Submission on

Resource Consent Application

(Form 13 Resource Management Act 1991)

o: Chief Executive

C/- Client Services Administrator

Hawke’s Bay Regional Council

Private Bag 6006

NAPIER 4142

Person Making Submission

Full name: _____________________________________________________________________

Postal address: _________________________________________________________________

__________________________________________________________ Post code _________

Property address, if different: ______________________________________________________

Contact person

(if different to above, or if submitter is an organisation): _____________________________

Telephone Number: ___________________________ Cell: ___________________________

E-mail: _______________________________________________________________________

Name of applicant: The Te Mata Mushrooms Company Limited

Consent Number: DP160229A

Location of activity: 174 – 176 Brookvale Road, Havelock North

Consent Activity: To discharge contaminants into the air from a compositing and mushroom growing

operation, and associated activities.

ubmission close Date: Monday 12 June 2017 at 5pm

re you a trade competitor for the purposes of section 308B of the RMA 1991 Yes

 No 

f yes: Are you directly affected by an effect of the proposed activity that adversely effects the

environment and does not relate to, or the effects of trade competition Yes

 No 

I/We support the above application 

I/We oppose the above application



I/We neither support nor oppose the above application



Office Use

Application No: DP160229A

Submission No _______________

Hastings District Council

Private Bag 9002, Hastings

4156

207 Lyndon Road East, Hastings

Asher Davidson, Barrister

(09) 337 0700

027 213 0538

asher@casey.co.nz

✔

The specific parts of the application that my submission relates to are: ______________________

_____________________________________________________________________________

My submission is: (you may attach submission detail to this form)

* Include the reasons for your views _________________________________________________

_____________________________________________________________________________

I seek the following decision from the Hawke’s Bay Regional Council:

* Give precise details, including the parts of the application you wish to have amended and the

general nature of any conditions sought ______________________________________________

_____________________________________________________________________________

See attached submission.

I wish to be heard in support of my submission 

I DO NOT wish to be heard in support of my submission



If others make a similar submission, I will



consider presenting a joint case with them at the hearing

I wish to attend any pre-hearing meeting that may be convened Yes



*I request that Council delegate its functions, powers, and duties required to hear 

and decide the application to 1 or more hearings commissioners who are not

members of the local authority

*Please note that a fee of $3000.00 is required to be lodged with your request, additional costs will be billed to you

Signature of submitter: ______________________________ Date / / 2017

(or person authorised to sign on behalf of submitter)

Please note the person/s making this submission must also serve a copy on the applicant as

soon as reasonably practicable

12 6

✔

Attachment to Submission by Hastings District Council

To: Hawkes Bay Regional Council (HBRC)

Name of submitters: Hastings District Council (HDC)

Regarding: Application by Te Mata Mushroom Company Ltd (TMM) to discharge

contaminants into air from a composting and mushroom growing

operation, and associated activities at 174 – 176 Brookvale Road,

Havelock North (Application).

SUMMARY OF SUBMISSION

1. The Application seeks approval to increase compost production at the Application site from 120

tonnes per week to 500 tonnes per week, an increase of over 300%.

2. This increase is not authorised by TMM’s current land use consent, and a new land use consent

will be required. HDC considers that the Application should be put on hold to allow for the

necessary land use consents to be sought, and that all applications necessary to authorise the

proposal be considered together, in accordance with s 91 Resource Management Act 1991.

3. In its current form, the Application does not adequately assess adverse odour effects of the

increase in compost production. HDC considers there is potential for adverse odour effects to

occur with no provision for their avoidance or mitigation.

4. As a consequence, the grant of consent to the Application in its current form would be contrary

to relevant objectives and policies in the Regional Resource Management Plan.

5. Absent the provision of further information to address HDC’s concerns, outlined in further detail

below, HDC opposes the grant of consent.

LAND USE CONSENTS

6. The Introduction to the Application asserts that, in 2013:

… a resource consent was obtained to increase the scale of the growing facilities by

constructing additional mushroom growing rooms, effectively consenting the entire

operation from a land use perspective.

Application, page 7.

7. The Application further suggests that increased compost production is necessary “to optimise the

growing capacity of the operation i.e. that provided for under Hastings District Council consent

RMA 20130216”.

8. HDC is concerned that the Application suggests that its land use consent RMA 20130216

authorises the proposed increase in compost production on the Application Site. It does not.

TMM’s application for land use consent specified that there was to be no increase in compost

production, stating (emphasis added):

It is important to note that the production capacity of the operation will continue to be

limited DP100128A [air discharge consent] i.e. there will be no change in respect to the

volume of compost authorised to be produced on site.

9. The applicant reiterated that no increase in compost production was proposed in an email stating

(emphasis added):

No additional deliveries of straw or other inputs are envisaged to occur as production levels

are already limited by DP100128A (HBRC air discharge permit).

The purpose of the additional growing rooms is to optimise the current operation, but as the

volume of compost produced will not increase, the proposed buildings are unlikely to result

in an increase in the number of staff on site or the number of car parks required, nor will

they influence any existing loading or delivery patterns.

10. The grant of the land use consent application was premised on compost production levels

remaining the same, which affected HDC’s assessment of relevant matters including odour and

traffic effects. An increase in compost production would require a new land use consent.

11. HDC also notes that the plans provided with the Application are unclear, and there is no certainty

that the physical works proposed are consistent with the current land use consent.

12. HDC considers that the current Application should be heard in conjunction with an application

for the necessary land use consent, to ensure there is a holistic understanding of the nature of

the proposal, and its effects on the environment, and a complementary set of conditions. It

therefore considers that HBRC should determine not to proceed with a hearing at this time, under

s 91 Resource Management Act 1991.

Letter Cameron Drury, Cheal Consultants to Roger Wiffin (then Hastings District Council), 5 August 2013

‘176 Brookvale Road: RMA20130178 – Additional Intensive Rural Production Activities / Buildings’, p4.

Email Cameron Drury to Roger Wiffin, ‘Re RMA20130216 Te Mata Mushrooms’, 31 January 2014.

HDC notes that the area in which composting is to occur is outside the Scheduled Site area.

13. HDC acknowledges that its role as submitter in this hearing means that any hearing of the land

use consent will likely need to be heard by an Independent Commissioner(s).

ADVERSE EFFECTS ON THE ENVIRONMENT

14. The Application is supported by an odour assessment, prepared by Air Quality Professionals. In

order to inform its position of the Application, HDC engaged Tonkin & Taylor to review that

assessment (T&T report). The T&T report is attached as Attachment A.

15. The T&T report indicates some gaps in the assessment which indicate that there may be adverse

odour effects, in particular:

(a) Mitigation to address current odour effects will not be implemented for 8 months (in the

case of transfer of compost from Phase 1 bunkers to Phase 2 tunnel); or until production

reaches 200 tonnes (first and second turning of compost in Phase 1 bunkers and laying out

mixing and breaking bales). This indicates:

(i) Current odour potential will remain high for 8 months (and may increase if the

proposal is that production would increase in the first 8 months);

(ii) Current odour potential will remain Moderate-High / Moderate for an indeterminate

period until production reaches 200 tonnes. Because over this time production will

increase by 66%, these existing levels of odour potential are expected to increase;

(b) If and when production reaches 200 tonnes per week, mitigation measures will be put in

place. That mitigation then allows production to increase to 500 tonnes before the final

mitigation package is required to be implemented. The T&T report anticipates that there

will be increased odour effects over time, particularly associated with a greater quantity of

bales being broken and wetted, and larger volumes of material needing to be transferred

and mixed in Phases 1 and 2.

16. As the trigger for implementation of mitigation relates to production volume, there is potential

for ‘Moderate High’ odour effects to continue indefinitely, if production operates just below the

200 tonne or 500 tonne thresholds.

17. The T&T report notes that the air quality assessment provided with the Application does not

assess the point at which odour effects may become offensive and objectionable, and states:

Given the proximity of sensitive receptors, a Low to Moderate potential for adverse odour

impacts may equate to odour effects that are offensive and objectionable.

18. Based on T&T’s report, HDC considers that the grant of consent to the Application in its current

form would result in offensive and objectionable odours beyond the boundary of the site, for

which adequate mitigation is not provided and which could occur over a long period of time.

ASSESSMENT AGAINST OBJECTIVES AND POLICIES

19. On the strength of the T&T Report’s assessment that the Application may involve offensive and

objectionable odours beyond the boundary of the Application site, HDC considers that there is a

conflict between the Application and the applicable objectives and policies in the Regional

Resource Management Plan, particularly:

(a) Objective 18, which relates to the expansion of existing activities which are tied

operationally to a specific location, and requires “the mitigation of off site impacts or

nuisance effects arising from the location of conflicting land activities adjacent to, or in the

vicinity of, areas required for current or future operational needs”;

(b) Or Objective 16 which requires the avoidance or mitigation of off site impacts or nuisance

effects arising from the location of conflicting land use activities, for future activities;

conditions on resource consents where a discharge of odour to air occurs;

(d) Objective 20, which provides that the use of organic materials from industries processing

primary products “does not result in adverse effects on humans or the environment”

(e) Policy 14, which relates to the establishment and maintenance of separation distances for

the storage, use or disposal of organic material to ensure that there are no offensive or

objectionable odours imposed on neighbouring properties;

(f) Objective 39a, which refers to “A standard of local air quality is maintained that is not

detrimental to human health, amenity values or the life supporting capacity of air”.

(g) Policy 69 which requires the management of effects of activities affecting air quality so that

“There should be no offensive or objectionable odour beyond the boundary of the subject

property”.

20. HDC notes that Objective 18 refers to existing activities being ‘tied operationally’ to the

Application site. HDC notes that other mushroom farms carry out composting operations on

separate sites from where the mushroom farms themselves are located, and this is an alternative

which has not been adequately addressed in the Application. It will be necessary for HBRC to

determine whether Objective 16 or 18 applies.

RELIEF SOUGHT BY HDC

21. For the reasons noted above, HDC seeks that the Application be put on hold and assessed

together with an application for land use consent necessary to authorise the increased compost

production now proposed.

22. HDC also seeks clarification from TMM, prior to the hearing if possible, on those issues raised in

the T&T report, and outlined above. Concerns particularly relate to the assessment and

quantification of adverse odour effects at all relevant stages (first 8 months, near to 200 tonnes

production without mitigation required at 200 tonnes, near to 500 tonnes production without

mitigation required at 500 tonnes, and at 500 tonnes production). HDC considers that this

information should be pre-circulated to submitters as soon as possible, to ensure adequate

opportunity to understand the proposal and comment on it at the hearing.

23. If there is insufficient certainty that an increase in compost production cannot occur without

causing offensive or objectionable odours beyond the boundary of the Application site, then HDC

seeks that:

(a) Consent only be granted for that level of compost production for which the odour effects

can be adequately mitigated; or

(b) Consent be declined.

24. In the event that consent is granted, HDC considers that the consent should be subject to a

condition requiring that there be no offensive or objectionable odour beyond the boundary of

the Application site; and that additional conditions be imposed to ensure appropriate mitigation

of effects, such as:

(a) Preventing any increase in compost production until the initial mitigation works are in place

(noting that it would be inappropriate to allow for an increase in production, and therefore

odour, to occur within the first 8 months before mitigation is implemented);

(b) The possibility of a staged consent, for instance additional production being triggered only

after monitoring and/or an odour assessment establishes that the mitigation works are

operating as forecast.

Attachment A – Tonkin & Taylor Report

Tonkin & Taylor Ltd | 105 Carlton Gore Rd, Newmarket, Auckland 1023, New Zealand

PO Box 5271, Wellesley St, Auckland 1141

+64

355 6000

+64

307 0265

akl

@tonkin

taylor

.co.nz

Job No: 1002348

12 June 2017

Hastings District Council

Private Bag 9002

Hastings

Attention: Neil Taylor

Dear Neil

Review of Te Mata Mushrooms Odour Assessment

1 Introduction

This report sets out a technical review of the consent application by the Te Mata Mushroom

Company (TMM) for an air discharge consent for the existing facility at 174 to 176 Brookvale Rd,

Havelock North. Our report focuses on the technical aspects of the assessment of odour effects.

We have reviewed the following documents:

 Odour Assessment – Te Mata Mushrooms. Air Quality Professionals Pty Ltd. 19 December

2016 (Odour Assessment).

 Application for Resource Consent to Discharge Contaminants into Air. The Te Mata Mushroom

Company. Cheal Consultants Ltd. 20 December 2016 (Consent Application)

 Response to Request for Further Information. Cheal Consultants Ltd. 27 March 2017 (Further

Information).

This report is set out as follows:

 An overview of our findings;

 A review of the methodology used to assess odour effects;

 Comments on the possible impact of increased production on odour emissions; and

 Comments on the proposed odour mitigation measures and timing.

2 Overview

The purpose of the Odour Assessment includes to “assess the potential impact of the proposal to

increase compost production to 500 tonnes per week coinciding with the implementation of odour

mitigation measures”.

The Good Practice Guide (GPG)

states that the purpose of an odour assessment to accompany a

resource consent application is generally to “determine whether the odour is (or will be) offensive

and/or objectionable, and therefore likely to cause adverse effects on the local community.” In New

Ministry for the Environment. 2016. Good Practice Guide for Assessing and Managing Odour. Wellington: Ministry for the

Environment.

Tonkin & Taylor Ltd

Review of Te Mata Mushrooms Odour Assessment

Hastings District Council

June 2017

Job No: 1002348

Zealand, a qualitative approach to assessing odour effects using a FIDOL assessment (rather than the

alternative of a numerical, modelling assessment), is often the most suitable approach.

A FIDOL assessment considers the frequency, intensity, duration, offensiveness/character, and

location of the odour (as this relates to the sensitivity of the receiving environment) and makes an

overall judgement as to whether the effects are (or are likely to be) offensive or objectionable. It is

necessary to consider both chronic and acute effects. Acute effects are situations where a single

exposure, for example to a very strong odour, is sufficient to be considered offensive or

objectionable. Chronic effects can arise from cumulative exposure to a number of odour events

that, taken in isolation, would not individually constitute an offensive or objectionable.

An odour assessment for a change to an existing activity generally considers the current effects of

the activity (which are already known) and compares these with the predicted effects after the

proposed changes. In the case of the TMM application, the proposed changes comprise both

improvements to odour control and an increase in production. The application covers four different

periods of time (scenarios) with different odour characteristics:

a zero to eight months after granting consent (existing level of odour effects);

b additional odour controls eight months after granting consent;

c further odour controls after production reaches 200 tonnes per week; and

d an increase in production from 200 tonnes per week to up to 500 tonnes per week.

The Odour Assessment considers only scenarios (a) (Table 9 of the Odour Assessment) and (d) (Table

10 of the Odour Assessment). The Odour Assessment does not describe the potential for adverse

odour effects if production does not increase beyond 200 tonnes per annum (scenario b), and

further odour controls are not implemented. This is important because the further odour controls

are contingent on is a substantial increase (66%) over the current production limit of 120 tonnes per

annum and the application does not propose any timeframe for this to occur. We understand that

the potential for odour effects during this intervening period will be higher than the “future upgrade

and expanded scenario” (scenario d). These effects need to be characterised as the consent being

sought would authorise this level of emissions indefinitely.

The odour character and sensitivity of the receiving environment are unchanged within each of the

scenarios identified above (although there is the potential for sensitivity of the receiving

environment to increase longer term if further residential housing is developed in the vicinity of the

site). Therefore, we would expect the odour assessment to characterise the change in frequency,

intensity and duration of odours of each subsequent period.

The Odour Assessment identifies the principal sources of odour at the site and rates their relative

potential to cause adverse effects. This rating includes consideration of some aspects of the FIDOL

factors, such as the day of week the activity occurs and, in some cases, the duration of the activity.

However, it is not clear how the relative “potential for adverse odour impacts at sensitive receptors”

of these different sources relates to actual effects on the environment. Therefore, while the

assessment anticipates a relative reduction in the potential for adverse odour impacts over time, the

assessment does not fully characterise the effects of the residual odour or make an overall

judgement as to whether the odours would be offensive or objectionable.

The assessment includes an evaluation of the proposed odour control measures against best

practice and the best practicable option. We understand that some activities cannot be fully

enclosed and vented to an odour control system (such as complete enclosure of the Phase 1 transfer

process). Certain activities will need to be carried out outdoors (such as bale breaking and mixing)

or in partially enclosed areas (e.g. “full enclosure” of Phase 1 transfer). Consequently, the Odour

Assessment acknowledges that odour emissions will not be eliminated. For this reason, we consider

that there needs to be consideration as to the adequacy of separation from sensitive receptors to

Tonkin & Taylor Ltd

Review of Te Mata Mushrooms Odour Assessment

Hastings District Council

June 2017

Job No: 1002348

avoid adverse effects of these residual odours, as well as from unplanned emissions that may occur

from time to time (such as failure of the biofilter or breaking straw bales that have unexpectedly

gone anaerobic).

The Odour Assessment concludes that the relative potential for odour effects from the future

upgraded and expanded site operations is “Low-Moderate”. It does not make any overall

judgement, based on a FIDOL assessment, as to whether the effects would be acceptable or result in

an adverse effect. Given the proximity of sensitive receptors, a Low to Moderate potential for

adverse odour impacts may equate to odour effects that are offensive and objectionable.

3 Odour assessment methodology

3.1 Receiving environment

The Odour Assessment identifies sensitive activities in the area and discusses the increase in

sensitivity of the receiving environment over time as residential housing has moved close to the

western side of the TMM site. The AEE Report identifies that the area on the eastern side of Arataki

Road is a Residential Urban Growth Area (shown in Figure 2.6) under the Hastings District Plan. We

understand that Arataki is not currently intended for development and its status is intended to be

changed to a reserve area. Any decision to rezone this land to residential could reduce the

separation distance to sensitive receptors and increase the sensitivity of the receiving environment.

Although it is not explicitly stated in the Odour Assessment, we understand that it assumes the

sensitivity of the receiving environment does not change over time.

3.2 Use of assessment tools

The Good Practice Guide outlines a range of odour assessment tools. It is not necessary to use all of

these tools, however the GPG suggests the priority that should be given to the various tools

depending on the situation. The selection of appropriate tools for an odour assessment depends on:

 Whether the activity is existing or proposed – in this case the resource consent application is

to authorise modifications to an existing activity (an increase in production); and

 Whether the odour effects are likely to be chronic or acute - in this case both chronic and

effects are possible.

The following table sets out the assessment tools described in the GPG and identifies whether they

have been used in the assessment. Assessment tools that are recommended as a high priority in the

GPG, but have not been used in the assessment are identified in bold/underline and discussed after

the table.

Table 1: Use of recommended odour assessment tools

Assessment tool Priority

Used in Odour

Assessment

Comments

Community consultation High No Neither the Odour Assessment nor the

AEE make any reference to consultation

having been undertaken.

Complaint records High Yes The Odour Assessment uses the review

of recent odour complaints (since

September 2014) to inform the odour

mitigation strategy.

Tonkin & Taylor Ltd

Review of Te Mata Mushrooms Odour Assessment

Hastings District Council

June 2017

Job No: 1002348

Assessment tool Priority

Used in Odour

Assessment

Comments

The AEE sets out a longer history of

odour complaints but does not directly

relate these to effects.

Industry/council

experience

High Yes, indirectly While the Odour Assessment does not

explicitly refer to experiences of the

industry or regional council with other

similar discharges, this is effectively

covered by the discussion of best

practice.

Odour annoyance

survey

High (chronic

effects)

No Odour annoyance surveys are generally

only appropriate where there is

sufficient residential density to generate

statistically significant results. Odour

diaries can be used as an alternative to

an odour annoyance survey.

Meteorology and terrain

assessment

High (to assess

effects of

proposed

changes)

Yes The assessment includes a discussion of

meteorology and terrain as these relate

to dispersion of odours.

Review emission control

systems

Moderate (acute

effects)

Yes The assessment includes an evaluation

of best practice and BPO.

Odour diaries and

weather monitoring

Moderate No Recommended in areas with low

population density (i.e. where odour

survey would be of limited use)

Review of odour

management plan and

contingency procedures,

risk assessment

High (acute

effects)

The Odour Assessment does not

explicitly identify high probability/ low

potential impact and low probability/

high impact events.

Olfactometry and odour

modelling

Low No We do not consider that olfactometry

and odour modelling would be an

appropriate tool for this situation as the

emission sources are difficult to quantify

and, as this is an existing activity, there

are tools that are more appropriate to

evaluate actual effects on the

community.

Table 1 highlights that the assessment does not use any community feedback tools other than

complaints records. However, there are a number of reasons why odour complaints records may

not be a reliable indicator of odour effects, or the level of community concern about odour.

The longer term odour complaints record (p16 of the Consent Application) highlights an increase in

complaints since 2012. The Consent Application attributes this to an increase in residential dwellings

in the vicinity of the site, which we agree is likely given the number of people that may be exposed

to odours have increased. The Odour Assessment also notes a significant increase in complaints in

2015/16 compared to 2014/15 and suggests that may be related to the timing of the Environment

Court hearing for the prosecution of TMM rather than as a direct indication of an increase in odour

emissions from the site. In our experience, an increase in odour complaints can occur around the

time of consent applications or enforcement actions, so this may be the case. However, another

recognised phenomenon is “complaint fatigue” whereby people may initially complain but then

Tonkin & Taylor Ltd

Review of Te Mata Mushrooms Odour Assessment

Hastings District Council

June 2017

Job No: 1002348

stop, or not complain at all, because they consider that it will be ineffective. Complaint fatigue may

(or may not) have been a contributing factor to the relatively low level of complaints prior to

2014/15.

Overall, we consider that the Odour Assessment would have been more complete if it had

incorporated direct feedback from the community on odour effects. This could have been achieved

qualitatively through consultation, or quantitatively by using an odour annoyance survey or odour

diaries. Because these tools have not being used, the odour effects of TMMs current activities are

not fully characterised in terms of the frequency, intensity and duration of odours. As a

consequence, although the Assessment indicates that odour effects will reduce over time, it is

unclear what the actual residual level of odour effects will be at the various stages identified.

Another gap in the odour assessment is a lack of identification of potential breakdowns or other

scenarios that might give rise to abnormal odour emissions, as well as an assessment of the risk of

these occurring and discussion of contingency measures. It is unclear to what extent abnormal

emissions have been the cause of odour complaints compared to normal, ongoing emissions. At a

minimum, we consider there should be a risk assessment be undertaken and contingency measures

identified for inclusions in an odour management plan (if consent is granted).

3.3 Qualitative rating of odour emission sources

The Odour Assessment uses a qualitative rating scale to determine the potential for adverse odour

impacts from each of the various sources. The report states that the rating is based on:

 The degree of unpleasantness of the odour;

 The time of day when the activity is carried out (related to meteorological conditions);

 The author’s observations of odour strength from each source;

 Size and volumetric flow rates of each source;

 Time of day when sources are present (as this relates to meteorology); and

 The author’s experience with the typical rate of downwind dispersion of odours from such

sources.

We consider that this qualitative approach is appropriate to evaluate the relative potential for

effects and that the rating takes into account the appropriate factors. T+T staff have previously

visited the TMM site and the key odour sources identified are consistent with our observations at

the time.

The odour ratings for the pre-2015 situation have been broadly calibrated against the complaints

records, which suggest that complaints were more likely on a Tuesday (when Phase 1 to Phase 2

transfer takes place) or Friday (bunker to bunker transfer), followed by a Monday (bunker to bunker

transfer) or Thursday (bale breaking). This is consistent with these activities being rated as having a

high potential for adverse odour impacts (apart from bale breaking and mixing which is rated as

moderate).

Following a number of improvements in odour control, the current (since early 2016) level of odour

effects is anticipated to be reduced compared to the pre-2015 situation. The Odour Assessment

anticipates that the potential for adverse odour impacts is still high on a Tuesday but would have

reduced somewhat on Mondays and Fridays (from high to moderate-high). Given that it is

approaching mid-2017, there should now be evidence available (such as from community feedback)

to verify this assessment. Ground-truthing of the current scenario would increase confidence in the

findings related to future scenarios.

Tonkin & Taylor Ltd

Review of Te Mata Mushrooms Odour Assessment

Hastings District Council

June 2017

Job No: 1002348

4 Impact of increased production on odour effects

A series of odour control improvements are proposed when production reaches 200 tonnes per

week. The application provides for a further increase in production to up to 500 tonnes per week.

The Odour Assessment considers the ultimate “future, upgraded and expanded” scenario (Table 10

of Odour Assessment), but not the interim scenario of around 200 tonnes per week production. We

consider it likely that there would be a correlation of increasing odour emissions with increasing

production rates, for the following reasons:

 More raw material brought onto the site;

 A greater quantity of bales needing to be broken and wetted;

 More partially composted material present on the site at any one time;

 Larger volumes of material needing to be transferred between bunkers/tunnels; and

 Possibly more finished composted present on the site at any one time.

Consequently, we consider it likely that odour emissions from the site will reduce once production

reaches 200 tonnes per annum and further odour controls are put in place, but then increase over

time as production increases.

Table 2 sets out our comments on the possible impacts on odour of increased production.

Table 2: Odour effects of increased production from 200 to 500 tonnes per week

Effect of increased

production

Odour Assessment Commentary

More raw material stored

on the site

Further Information states that if

additional bunkers are required

these will be of the same standard

as the existing ones.

Not likely to be a significant odour

source provided mixing continues to

be carried out off-site and material is

stored indoors.

Greater quantity of bales

needing to be broken and

wetted

The footprint for bale wetting will be

similar to current dimensions.

May be necessary to minimise the

duration of bale breaking and avoid

early morning period.

We would expect the odour

generation rate to be related to the

volume of straw/ wastewater rather

than just the footprint. On this basis,

we expect odour emissions would

increase with increasing production.

More partially composted

material present on the

site at any one time

Vented air will be treated through a

new biofilter

Odour emissions should not increase

substantially provided the biofilter is

appropriately sized and properly

maintained.

Larger volumes of material

needing to be transferred

between Phase 1

Duration of bunker to bunker

transfers will be no longer than

currently used.

May be necessary to minimise the

duration of bunker to bunker

transfers and avoid early morning

period.

Odour emissions will not change as

production increases.

Bunker to bunker transfers are

currently rated as ‘moderate-high’.

Once the third bunker is built, outdoor

transfer times will reduce and the

rating reduces to ‘low-moderate’.

However, outdoor transfer times will

progressively increase with

production. If the duration of

transfers returns to current levels, it is

unclear why the potential for effects

does not return to “Moderate-High”

levels.

Tonkin & Taylor Ltd

Review of Te Mata Mushrooms Odour Assessment

Hastings District Council

June 2017

Job No: 1002348

Effect of increased

production

Odour Assessment Commentary

Larger volumes of material

needing to be mixed and

placed in Phase 2 tunnels

Not discussed Outdoor transfer times will

progressively increase with

production. Although the Phase 2

material is not as odorous as Phase 1,

we expect that the potential for odour

effects will increase with production.

More finished composted

present on the site at any

one time

Not discussed Not likely to be a significant odour

source if spent compost piles are well-

managed and removed from the site

within 7 days.

5 Mitigation measures

The Odour Assessment identifies the activities with the greatest potential for offsite odour impacts,

in order of importance and excluding activities with a low potential, as being:

1 Transfer of compost from Phase 1 bunkers into Phase 2 tunnel (High)

2 First and second turning of compost in Phase 1 bunkers (Moderate – High)

3 Laying out bales then breaking, mixing and placing into bunker (Moderate)

4 Bale wetting (Low-Moderate)

5 Phase 2 composting (Low-Moderate)

Appendix A outlines our understanding of the proposed mitigation measures and timing of

implementation, as well as the relative potential for adverse odour impacts after each stage of

mitigation.

The timing of the proposed mitigation is such that the second and third highest priority sources, will

not be fully addressed until production exceeds 200 tonnes per week (a 66% increase over the

current production limit of 120 tonnes per week). There will be a partial improvement in odour

emissions from the first and second turning of Phase 1 compost, however the outdoor transfer of

compost from one end of the bunker to the other using a loader will continue. The existing level of

odour emissions from bale wetting/breaking activities, which are assessed as having a Moderate

potential for odour effects, would continue indefinitely if production did not increase beyond 200

tonnes per week. These odour emissions could increase if production increased towards, but did not

exceed, 200 tonnes per week.

Tonkin & Taylor Ltd

Review of Te Mata Mushrooms Odour Assessment

Hastings District Council

June 2017

Job No: 1002348

6 Applicability

This report has been prepared for the exclusive use of our client Hastings District Council, with

respect to the particular brief given to us and it may not be relied upon in other contexts or for any

other purpose, or by any person other than our client, without our prior written agreement.

Tonkin & Taylor Ltd

Environmental and Engineering Consultants

Report prepared by:

..........................................................

Jenny Simpson

Director – Natural Resources

JMS

p:\1002348\issueddocuments\jms120617.draftrpt.docx

Appendix A : Summary of mitigation measures

Activity

Current

odour

potential

Mitigation to be

implemented within 8

months of consent

Odour potential

after 8 months

Mitigation to be

implemented

once production

exceeds 200

tonnes per 7

days

Odour potential after

production exceeds

200 tonnes

Comments

Transfer of compost

from Phase 1 bunkers

into Phase 2 tunnel

High Construct a new

hopper and turning

building. The compost

will be turned inside

the new building

before transfer to the

Phase 2 tunnels

Install a new biofilter to

treat air extracted from

the new building.

Low

First and second

turning of compost in

Phase 1 bunkers

Moderate –

High

Extend the length of

each existing bunker by

10m and construct a

canopy with additional

air extraction (‘full

enclosure’).

Not stated Construct a third

bunker with full

enclosure. This

will avoid the

need to transfer

compost from

one end of the

bunker to the

other using a

loader.

Low-Moderate It is unclear whether the existing

biofilter can accommodate the

additional air flows proposed from

around the new extensions/

canopies on the existing building.

The AEE states that construction of

the additional bunker is only

required to accommodate

production increases. However the

air quality assessment notes that the

additional bunker will avoid the

need to transfer compost outside

from one end of the bunker to the

other - this will minimise loader

travel distances and the duration of

compost exposure outdoors.

Activity

Current

odour

potential

Mitigation to be

implemented within 8

months of consent

Odour potential

after 8 months

Mitigation to be

implemented

once production

exceeds 200

tonnes per 7

days

Odour potential after

production exceeds

200 tonnes

Comments

Laying out bales then

breaking, mixing and

placing into bunker

Moderate Moderate Install bale

breaking machine

Construct a semi-

enclosed bale

blending line

under the eave

attached to the

Phase 1 bunker

with air

extraction

Low-Moderate

Bale wetting Low-

Moderate

Low-Moderate Pre-wet the bales

over an aerated

pad

Bale spiking to

introduce

recycled water

into the centre of

the bales This

reduces the time

that the bales

need to be laid

out for wetting

Low

Phase 2 composting Low-

Moderate

Duct odour emissions

to the new biofilter.

Low The air quality assessment notes

that once production increases

beyond 500 tonnes per week, the

existing Phase 2 tunnels will be

extended and additional tunnels

constructed. We assume this would

increase the volume of air needing

Activity

Current

odour

potential

Mitigation to be

implemented within 8

months of consent

Odour potential

after 8 months

Mitigation to be

implemented

once production

exceeds 200

tonnes per 7

days

Odour potential after

production exceeds

200 tonnes

Comments

to be treated, so this wo

uld need to

be taken into account in the design

of the new biofilter.

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