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Air Quality and Plume Rise
Assessment Report
Document no: IA335900-JAC-BDC-AI-RPT-001
Revision: A
Stockland Corporation Development Pty Limited
Master Planning and Approval Services for Brooklyn Data Centre
20 May 2026
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Air Quality and Plume Rise Assessment Report
Client name: Stockland Corporation Development Pty Limited
Project name: Master Planning and Approval Services for Brooklyn Data Centre
Client reference: [Client reference] Project no: IA355900
Document no: IA335900-JAC-BDC-AI-RPT-001 Project manager: Nishita Bhansali
Revision: A Prepared by: Luke Spencer
Date: 20 May 2026 File name: Air Quality and Plume Rise
Assessment
Report_Brooklyn_Rev_A.docx
Document status: Planning
Document history and status
Revision Date Description Author Checked Reviewed Approved
A 20/05/2026 Planning Approval LS TF NB CS
Submission
Distribution of copies
Revision Issue approved Date issued Issued to Comments
A 20/05/2026 20/05/2026 SCDL Planning Approval Submission
Jacobs Group (Australia) Pty Ltd
Level 4, 12 Stewart Avenue T +61 2 4979 2600
Newcastle West, NSW 2302 F +61 2 4979 2666
PO Box 2147
www.jacobs.com
Dangar, NSW 2309
Australia
© Copyright 2026 Jacobs Group (Australia) Pty Ltd. All rights reserved. The content and information contained in this document
are the property of the Jacobs group of companies (“Jacobs Group”). Publication, distribution, or reproduction of this document in
whole or in part without the written permission of Jacobs Group constitutes an infringement of copyright. Jacobs, the Jacobs logo,
and all other Jacobs Group trademarks are the property of Jacobs Group.
NOTICE: This document has been prepared exclusively for the use and benefit of Jacobs Group client. Jacobs Group accepts no
liability or responsibility for any use or reliance upon this document by any third party.
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Air Quality and Plume Rise Assessment Report
Executive summary
Overview
This report has been prepared by Jacobs Group (Australia) Pty Ltd (Jacobs) on behalf of Stockland
Development Pty Ltd (Stockland) in support of the planning permit application relating to the land at 413
Francis St Brooklyn (the Site). This application seeks approval for the use and development of the land for a
data centre (the Project). This report provides an overview of the key features of the Project, including the key
air quality and plume rise-related matters, establishes relevant criteria for the assessment, identifies and
characterises key features of the existing environment, assesses the potential for air quality and plume rise
impacts in-line with relevant VIC Environment Protection Authority (VIC EPA) and the Civil Aviation Safety
Authority (CASA) assessment requirements, and provides relevant recommendations for minimising impacts
consistent with the General Environmental Duty (GED).
The assessment determined that emissions to air during construction are not expected to present an issues,
and would be able to be controlled or otherwise effectively managed. Regarding emissions to air during
routine testing and maintenance of back-up emergency diesel generators, concentrations at surrounding
sensitive receptors were generally predicted to remain below applicable air quality objective values.
Exceedances were predicted during emergency partial and full main power outage scenarios. However, these
events are expected to be very unlikely. Consistent with the General Environmental Duty (GED), control
measures for reducing emissions from diesel generators were reviewed. However, it is noted that these
technologies are less suitable when units are used in an intermittent, emergency back-up capacity. Noting
these factors, no specific controls were recommended.
The assessment also determined that the Project could meet CASA plume rise requirements for surrounding
prescribed airspace.
A more detailed summary of each element of the assessment including the key matters assessed, impact
assessment approaches, relevant features of the existing environment and a more detailed account of the
assessment outcomes are provided in the following subsections.
Key air quality and plume rise-related matters
A review of key details of the Project and its setting identified the following matters as the key elements for
the assessment:
 Air quality impacts during construction: Nuisance dust was identified as the key air quality risk during
construction, with other identified risks including exhaust emissions from construction plant, traffic and
equipment and odours or airborne hazards arising from the handling of potentially contaminated
materials and groundwater (if encountered).
 Air quality impacts during operations: Exhaust emissions (primarily nitrogen dioxide [NO ], fine
2
particulate matter [PM ], carbon monoxide [CO] and volatile organic compounds [VOCs]) from the use
2.5
of back-up emergency generators was identified as the key operational air quality risk. Impacts were
considered from routine testing and maintenance of the generators, as well as for their use during partial
or full mains power outages.
 Plume rise impacts during operations: Aviation authorities have determined that plumes of air above
certain vertical velocities can in some circumstances, pose a risk to aviation operations. The Project site is
located within 15 kilometres of two Certified Aerodrome (i.e., aerodrome authorised by CASA under
subpart 139.B of the Civil Aviation Safety Regulations [CASR] to operate with specific safety standards,
typically required for aerodromes with terminal instrument flight procedures), and hence the need to
assess the potential for impacts to aviation operations from vertical plumes from the proposed
developments was identified.
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Air Quality and Plume Rise Assessment Report
Impact assessment approaches
Different assessment methods were applied to assess the potential for impacts from each of the key risks
identified above. Consistent with VIC EPA’s ‘Publication 1943: Guidance for assessing nuisance dust’, a
qualitative risk-based assessment approach was used to assess the potential for nuisance dust impacts during
construction. A similar approach risk-based approach was applied to assess the potential for other air quality-
related impacts during construction. Based on the outcomes of the assessment (detailed below), suitable
mitigation and management measures were developed.
Regarding operations, VIC EPA’s approved regulatory air dispersion model, AEROMOD, was used to predict
resulting changes in air quality resulting from different routine and emergency diesel generator operations at
the Project site. The model was set-up with reference to guidance presented in the relevant VIC EPA
Publications, and impacts were assessed against criteria developed from the Environment Reference Standard
(ERS) and Publication 1961.2 ‘Guideline for assessing and minimising air pollution in Victoria’, (VIC EPA,
2025a). Based on the assessment outcomes, review of control options was also completed consistent with the
requirements of the general environmental duty (GED) under the Environment Protection Act 2017.
Finally, a screening level plume rise assessment was undertaken to evaluate whether vertical plumes from the
Project could affect aircraft operations in surrounding prescribed airspace. This was completed using ‘The Air
Pollution Model’ (TAPM) developed by the CSIRO. The model was configured using the latest available
guidance from CASA.
Key features of the existing environment
As part of the assessment, key features of the existing environment were identified including surrounding
sensitive receptors, meteorology, other local sources of emissions to air, background air quality and
prescribed airspace requirements.
The following findings were made in relation to the existing environment:
 The nearest sensitive receptors were around 0.3 kilometres from the site.
 Prevailing annual local meteorological conditions were winds blowing from the north and south most
often, with winds from the west also common.
 Other existing nearby sources of emissions to air were identified, which generally comprised of industry.
Key emissions to air from these industries included CO, NO , particulate matter (including PM and
x 10
PM ), heavy metals, sulfur dioxide (SO ) and total and speciated VOCs.
2.5 2
 Background air quality concentrations around the site were recorded as generally meeting the ERS air
quality objective values, with the exception of 24-hour averaged PM , which were occasionally measured
2.5
above these limits in 2020, 2021 and 2024 of the five years (2020 to 2024) considered for the
assessment.
 The site was confirmed as being within 15 kilometres of a Certified Aerodrome. Approximately 133
meters were determined as being available to the lowest prescribed airspace layer (being the OLS) at the
approximate location of the Project.
Assessment of impacts, recommendations and conclusions
 Construction air quality:
- Using the assessment methodology detailed in Publication 1943, ‘medium’ potential unmitigated
nuisance dust impacts were determined for the Brooklyn site.
- Suitable mitigation and management measures were developed in-line with Publication 1834.2, the
GED and other relevant guidance. With these measures, it is expected that nuisance dust would be
able to be effectively managed such that impacts during construction would be considered very
unlikely.
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Air Quality and Plume Rise Assessment Report
- Impacts from other emissions to air identified during construction are considered unlikely, with
suitable control measures recommended for inclusion into the Project Construction Environmental
Management Plan (CEMP).
 Operational air quality:
- For NO and PM , compliance against ERS air quality objective values at surrounding sensitive
x 2.5
receptors was generally achieved during generator routine testing and maintenance and emergency
operations. The only exception was for PM in 2021 and 2024 where the assessment predicted the
2.5
potential for one additional day in the year where concentrations exceeded the 25 µg/m3 air quality
objective value at the most-affected representative sensitive receptor.
- Exceedances were determined during emergency operations. Such events are considered to be very
unlikely owing to the redundancy in power supplies to site. It is noted that emissions to air from these
types of operations may be exempt under the Environment Protection Regulations 2021 (VIC EPA,
2021a), but there is still the need to review potential controls to minimise impacts consistent with the
requirements of the GED under the Environment Protection Act 2017. Available controls were
reviewed, although it was determined that they would be unlikely to meet the threshold as being
reasonable and feasible, noting the expected frequency of these events would be extremely low, and
that the efficacy of such controls are limited for generators that are used in a back-up capacity. As
such, no emission controls were recommended for the back-up generator units.
- For CO and speciated VOCs under all operational scenarios (i.e., routine testing and maintenance and
emergency operations), compliance was achieved against relevant ERS and Publication 1961.2 air
quality objective values at surrounding sensitive receptors.
 Operational plume rise:
- A plume rise screening assessment was completed using TAPM. Potential impacts were evaluated by
reviewing the height at which vertical velocities from key sources fell below CASA’s 4.3 m/s critical
plume velocity (CPV), and comparing this against relevant prescribed airspace requirements for the
affected Certified Aerodrome. Results were evaluated against the most stringent 4.3 m/s CPV at the
lower (i.e., most conservative) protected airspace layer from the surrounding Certified Aerodrome.
- Using this approach, it was determined that the vertical velocities from the back-up generators would
fall below CASA’s 4.3 m/s CPV well below the lowest protected airspace requirements relevant at the
site. Still, in-line with from ‘Advisory Circular AC 139.E-02 V1.0 Plume Rise Assessments’ (CASA,
2023), a 1247 form (including associated meteorological data) has been prepared and submitted to
CASA for their review.
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Contents
Executive summary ............................................................................................................................................................... iii
Acronyms and abbreviations ............................................................................................................................................... ix
1. Introduction .................................................................................................................................................................. 1
1.1 Background ......................................................................................................................................................................... 1
1.2 Purpose ................................................................................................................................................................................ 1
1.3 Structure .............................................................................................................................................................................. 2
2. Overview of Project ..................................................................................................................................................... 3
2.1 Overview ............................................................................................................................................................................... 3
2.2 Project description and summary .............................................................................................................................. 3
2.3 Project location ................................................................................................................................................................. 4
2.4 Summary of key aspects relevant to this assessment ....................................................................................... 5
3. Legislation, policy and guidelines ........................................................................................................................... 7
3.1 Overview ............................................................................................................................................................................... 7
3.2 Air quality ............................................................................................................................................................................ 7
3.2.1 Environment Protection Act 2017 ................................................................................................................ 7
3.2.2 Environment Protection Regulations 2021 .............................................................................................. 7
3.2.3 National Environment Protection Measure for Ambient Air Quality .............................................. 8
3.2.4 Environment Reference Standard ................................................................................................................ 8
3.2.5 EPA Publication 1961.2 .................................................................................................................................... 9
3.2.6 Other relevant EPA Publications ................................................................................................................ 10
3.3 CASA plume rise guidance......................................................................................................................................... 11
4. Assessment methods ............................................................................................................................................... 12
4.1 Overview ............................................................................................................................................................................ 12
4.2 Air quality ......................................................................................................................................................................... 12
4.2.1 Existing environment ...................................................................................................................................... 12
4.2.2 Impact assessment approach ...................................................................................................................... 13
4.3 Plume rise assessment ................................................................................................................................................ 21
5. Existing conditions .................................................................................................................................................... 23
5.1 Surrounding sensitive land uses .............................................................................................................................. 23
5.2 Other local sources of emissions to air ................................................................................................................. 24
5.3 Background air quality ................................................................................................................................................ 26
5.3.1 Overview .............................................................................................................................................................. 26
5.3.2 Nitrogen dioxide (NO ) and Ozone (O ) .................................................................................................. 26
2 3
5.3.3 Carbon monoxide (CO) .................................................................................................................................. 27
5.3.4 Particulate matter (PM ) ............................................................................................................................. 28
2.5
5.4 Protected airspace requirements ............................................................................................................................ 30
5.4.1 RAAF Base Point Cook .................................................................................................................................... 30
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5.4.2 Essendon Fields ................................................................................................................................................ 30
5.4.3 Summary ............................................................................................................................................................. 30
6. Air quality impact assessment ............................................................................................................................... 31
6.1 Construction .................................................................................................................................................................... 31
6.1.1 Nuisance dust review ...................................................................................................................................... 31
6.1.2 Other air quality impacts during construction ...................................................................................... 33
6.2 Operations ........................................................................................................................................................................ 34
6.2.1 Nitrogen dioxide (NO ) .................................................................................................................................. 34
2
6.2.2 Carbon monoxide (CO) .................................................................................................................................. 36
6.2.3 Particulate matter ............................................................................................................................................ 36
6.2.4 VOCs ...................................................................................................................................................................... 38
7. Plume rise screening assessment ......................................................................................................................... 40
8. Conclusion .................................................................................................................................................................. 42
9. References .................................................................................................................................................................. 43
Appendices
Appendix A. Generator stack inputs ................................................................................................................................. 44
Appendix B. AERMET annual and seasonal wind roses ............................................................................................... 48
Appendix C. Nuisance dust assessment Publication 1943 guidance ....................................................................... 53
Appendix D. Selected operational ground-level concentration plots ..................................................................... 56
Tables
Table 3-1. NEPM AAQ maximum concentration standards ...................................................................................................... 8
Table 3-2. ERS air quality objectives .................................................................................................................................................. 9
Table 3-3. Air pollutant assessment criteria for speciated VOCs (EPA, 2025) .................................................................. 9
Table 3-4. Other VIC EPA Publications relevant to the assessment .................................................................................... 10
Table 4-1. Inputs used to characterise features of existing environment ........................................................................ 12
Table 4-2. Construction dust impact ratings (Source: EPA, 2025b) ................................................................................... 13
Table 4-3. Exhaust emissions and/or odours/airborne hazards impact assessment ratings ................................... 14
Table 4-4. AERMAP set-up details ................................................................................................................................................... 16
Table 4-5. TAPM set-up details ......................................................................................................................................................... 17
Table 4-6. AERMET set-up details .................................................................................................................................................... 17
Table 4-7. AERMOD set-up details ................................................................................................................................................... 20
Table 4-8. TAPM set-up details for plume rise screening review ......................................................................................... 22
Table 4-9. Back-up diesel generator initial maximum and average final rise heights of the individual plumes
(m AGL) and calculated buoyancy enhancement factor (N ) ................................................................................................ 22
E
Table 5-1. Nearby representative sensitive receptors around Brooklyn site ................................................................... 24
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Table 5-2: Nearby facilities around the Brooklyn site where NPI emissions to air were reported in 2023/24.. 24
Table 5-3. Locations with active VIC EPA operating licence around the Brooklyn site ............................................... 25
Table 5-4. Local background PM statistics over the 2020 to 2024 monitoring period .......................................... 30
2.5
Table 6-1. Construction dust hazard potential ratings ............................................................................................................ 32
Table 6-2. Construction dust exposure pathway effectiveness ratings ............................................................................. 32
Table 6-3. Receiving environment nuisance dust sensitivity ratings .................................................................................. 32
Table 6-4. Unmitigated nuisance dust impact ratings, construction .................................................................................. 33
Table 6-5. 1-hour averaged 99.9th percentile NO results, Brooklyn ................................................................................. 35
2
Table 6-6. Brooklyn site NO GED controls review ..................................................................................................................... 36
x
Table 6-7. Rolling 8-hour averaged 100th percentile CO results, Brooklyn .................................................................... 36
Table 6-8. 24-hour averaged 100th percentile PM results, Brooklyn ............................................................................ 37
2.5
Table 6-9. Additional review of 24-hour averaged 100th percentile PM results for scenario 1, Brooklyn ...... 37
2.5
Table 6-10. 1-hour averaged 99.9th percentile benzene results, Brooklyn ..................................................................... 39
Table 6-11. 30-minute averaged 99.9th percentile formaldehyde results, Brooklyn .................................................. 39
Table 7-1: Estimated height above ground level at which plume vertical velocity falls below CASA’s 4.3 m/s
CPV, Brooklyn back-up generators ................................................................................................................................................... 40
Figures
Figure 2-1. Brooklyn data centre proposed layout ....................................................................................................................... 4
Figure 2-2. Aerial perspective of proposed Brooklyn data centre from south .................................................................. 4
Figure 2-3. Project location .................................................................................................................................................................... 5
Figure 4-1. Source arrangement, proposed Brooklyn data centre ...................................................................................... 15
Figure 4-2. AERMET 2020 to 2024 annual and seasonal wind roses for Brooklyn site .............................................. 18
Figure 4-3. 2020 to 2024 annual and seasonal wind roses from BoM Laverton (RAAF Williams) ........................ 19
Figure 5-1. Surrounding land uses and receptors, Brooklyn ................................................................................................. 23
Figure 5-2. Time-series of adopted 1-hour NO and O background concentrations (EPA, 2020 to 2024) ..... 27
2 3
Figure 5-3. Time-series of adopted rolling 8-hour averaged CO background concentrations (EPA, 2020 to
2024)............................................................................................................................................................................................................ 28
Figure 5-4. Time-series of adopted 24-hour averaged PM background concentrations (EPA, 2020 to 2024)
2.5
........................................................................................................................................................................................................................ 29
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Acronyms and abbreviations
Acronym Definition
AERMOD American Meteorological Society/Environmental Protection Agency Regulatory Model
APAC Air pollutant assessment criteria
ARP Aerodrome reference point
AWS Automatic weather station
BoM Bureau of Meteorology
CASA Civil Aviation Safety Authority
CASR Civil Aviation Safety Regulations
CEMP Construction Environmental Management Plan
CSIRO Commonwealth Scientific and Industrial Research Organisation
CO Carbon monoxide
CPV Critical plume velocity
DCCEEW Department of Climate Change, Energy, the Environment and Water (Commonwealth)
DEM Digital elevation model
ERS Environmental Reference Standard
GED General Environmental Duty
GLC Ground-level concentration
Jacobs Jacobs Group (Australia) Pty Ltd
MW Megawatt
NEPM AAQ National Environment Protection Measure for Ambient Air Quality
NO Nitrogen dioxide
2
NO Oxides of nitrogen
x
NPI National Pollutant Inventory
O Ozone
3
OLM Ozone limiting method
OLS Obstacle limitation surface
PANS-OPS Procedures for air navigation services – aircraft operations
ppb Parts per billion
ppm Parts per million
PM Particulate matter
PM Particulate matter with an equivalent aerodynamic diameter less than 2.5 microns
2.5
PM Particulate matter with an equivalent aerodynamic diameter less than 10 microns
10
SRTM Shuttle Radar Topography Mission
IA335900-JAC-BDC-AI-RPT-001 ix
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Air Quality and Plume Rise Assessment Report
Stockland Stockland Corporation Limited
TAPM The Air Pollution Model
USGS United States Geological Survey
VIC Victoria
VIC EPA Victorian Environment Protection Authority
VOC Volatile organic compound
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Air Quality and Plume Rise Assessment Report
1. Introduction
1.1 Background
Stockland Development Pty Limited (Stockland) is planning to develop a new data centre land at 413 Francis
St Brooklyn (the Site). This application seeks approval for the Stage 1 portion of the land use and
development (shown in Figure 1-1 below) for a data centre (the Project). Further details of the Project are
provided below in Section 2.
Jacobs Group (Australia) Pty Ltd (Jacobs) has been engaged to assist with the planning permit application for
the Project. This report assesses potential operational air quality impacts and plume rise impacts for the
planned development and describes how the development would meet relevant air quality-related planning
and approvals requirements. This report forms part of the documents to inform the associated planning
permit application.
Figure 1-1. Project site and staging plan
1.2 Purpose
The purpose of this report is to assess the potential operational air quality and plume rise impacts associated
with the Project, and describe how the development would meet relevant air quality-related planning and
approvals requirements. The specific objectives of the assessment are to:
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Air Quality and Plume Rise Assessment Report
 Identify local air quality and aviation values and the nature and proximity of potentially sensitive
receptors
 Provide an assessment of the likely impact of the Project on air quality and aviation values to inform
approvals under relevant policy and legislation
 Provide recommendations to mitigate or otherwise effectively manage impacts where appropriate.
1.3 Structure
The report is structured as follows:
 Introduction (this section) which provides background details for the Project and outlines the purpose
and structure of the assessment
 Project description (Section 2), where key details relevant to the assessment are explained
 Legislation, policy, guidelines and adopted assessment criteria (Section 3) which lists the legislative,
policy, guideline and other documents relevant to the assessment, and establishes the assessment
criteria
 Methodology (Section 4) where the approaches applied to assess potential impacts associated with the
Project is explained
 Existing conditions (Section 5) which identifies key features of the existing environment as relevant to
the assessment including details of surrounding sensitive receptors, existing local sources of emissions
to air, prevailing local meteorology, and relevant prescribed airspace requirements.
 Impact assessment (Section 6 and Section 7), where impacts during the construction and operation of
the Project, including potential plume rise impacts are evaluated
 Summary and recommendations (Section 8) where the objectives, methods, outcomes and
recommendations of the assessment are presented.
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Air Quality and Plume Rise Assessment Report
2. Overview of Project
2.1 Overview
This section of the report provides a brief overview of the Project and summarises the key aspects relevant to
this assessment.
2.2 Project description and summary
The Project seeks the staged use and development of a two-storey data centre (250MVA ultimate power
capacity) pursuant to the Industrial 1 & 3 Zones. To facilitate these works, the existing warehouse buildings
and associated hard stand/car parking area are to be removed. Early works approval will be sought to
undertake bulk earthworks across the Site, including the preparation of leveling of the Site to allow AusNet to
deliver the substation (utility installation). It is noted that substation area will be subject to separate planning
approvals and the use and development associated with the substation will be subject to a separate approval
prepared by AusNet.
This application meets the relevant eligibility criteria to be considered under the Development Facilitation
Program where the Minister for Planning will be the Responsible Authority pursuant to Clause 53.22 of the
Planning Scheme.
In particular, the Project seeks permission for the staged delivery of two, two-storey data centre buildings,
generally comprising the following buildings and works:
 Bulk earthworks for site preparation and leveling (early works approval sought);
 Construction of two-storey data centre buildings with a building height of 18.3 metres, with an additional
7.2 metres of building services for plant and chiller equipment (combined maximum height of circa 25.5
metres);
 The buildings comprise a total gross floor area of circa 75,000 square metres across the two storey data
halls and ancillary offices, with additional associated major plant open structures (housing generators
and chillers);
 Vehicle ingress and egress is proposed centrally along the Site’s frontage to Francis St, with circa 110 car
parking spaces provided at the frontage of the two data centre buildings;
 Removal of some vegetation to accommodate the functional parameters of the proposed data centre and
substation development;
 Additional landscaping provided in the front setback of the building, scattered throughout the Site and to
the office entry of each building, providing an improved landscape response; and
 Provision of required utilities, including diesel generator back up power system, associated fuel storage
systems, fire pump and associated water tanks.
The proposed data centre seeks to provide much needed AI integration, data, content and cloud services to
address the emerging demand for cloud computing services.
The Project’s design has been shaped by technical assessments and stakeholder feedback, ensuring a
balanced approach to development. The Project seeks to provide a strategic response to the existing and
emerging character through provision of an improved built form and landscape response.
An indicative layout for the site is displayed below in Figure 2-1 with a depiction of the facility shown in
Figure 2-2.
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Figure 2-1. Brooklyn data centre proposed layout
Figure 2-2. Aerial perspective of proposed Brooklyn data centre from west
2.3 Project location
The new Brooklyn data centre would be located at 413 Francis Street, Brooklyn. The regional context of the
Project is displayed below in Figure 2-3.
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Figure 2-3. Project location
2.4 Summary of key aspects relevant to this assessment
There is the potential for air quality-related impacts from the Project during construction and operations.
During construction, the primary air quality risk is expected to be dust. The term dust refers to particulate
matter in the form of total suspended particulates (TSP), deposited dust, particulate matter with equivalent
aerodynamic diameter of 10 microns or less (PM ), and finer particulate matter with equivalent aerodynamic
10
diameter of 2.5 microns or less (PM ). The Environment Reference Standard (ERS) (refer to Section 3.2.4
2.5
below) establishes assessment indicators for PM and PM with an objective of protecting human health.
10 2.5
Any air quality impacts during construction would be temporary, and are expected to be able to be controlled
with the effective implementation of suitable mitigation and management measures. An assessment of
potential air quality impacts during construction and how these would be effectively managed has been
undertaken, consistent with Victorian Environment Protection Authority (VIC EPA) assessment requirements.
As well as dust, other key air quality-related risks during construction include exhaust emissions from the
combustion of fossil fuels in construction plant and equipment. The primary pollutants associated with plant
exhaust emissions include carbon monoxide (CO), oxides of nitrogen (NO ) including nitrogen dioxide (NO ),
x 2
particulate matter (PM and PM ), volatile organic compounds (VOCs) and sulphur dioxide (SO )
10 2.5 2
(depending on fuel sulphur content). Finally, odours and airborne hazardous materials arising from
uncovered contaminated materials represent another air quality related risk. These other air quality risks
during construction beyond nuisance dust have been considered qualitatively, with measures developed to
mitigate or otherwise effectively manage any potential impacts.
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During operations from the key air quality-related risk was identified as being exhaust emissions from the
testing and use of the emergency back-up generators. The site will have 112 Caterpillar ‘CT175_20, Engine
EM1366’ 3 megawatt (MW) diesel emergency back-up generators to maintain power supply in the highly
unlikely event of a grid outage. Two additional 1 MW back-up generators would also be in-place for the two
administration buildings.
Key air pollutants associated with exhaust emissions from generators include particulate matter
(predominantly PM ), NO , CO and hydrocarbons, including VOCs. For diesel generators, the key speciated
2.5 x
VOCs include:
 Acetaldehyde
 Benzene
 Formaldehyde
 Toluene
 Xylene.
Potential impacts from these pollutants were assessed quantitatively, in-line with VIC EPA’s guidance.
Aviation authorities have established that wind gusts with vertical velocity exceeding 4.3 metres per second
(m/s) may cause damage to an aircraft airframe or otherwise upset an aircraft flying at low levels. Where the
vertical velocity of exhaust plumes from a facility exceeds the critical plume velocity (CPV) of 4.3 m/s at an
aerodrome Obstacle Limitation Surface (OLS) or another protection airspace layer (e.g., procedures for air
navigation services – aircraft operations [PANS-OPS]), or otherwise at 110 metres above ground level
anywhere else or within 15 km of a Certified Aerodrome, the Civil Aviation Safety Authority (CASA) has
identified the need for further assessment. The Project is located within 15 km of two Certified Aerodrome
(RAAF Base Point Cook and Essendon Fields). Hence, the need to assess potential impacts of plume rise on
aviation operations was identified.
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3. Legislation, policy and guidelines
3.1 Overview
There are several statutes, policies and guidelines applicable to the matters considered in this assessment.
These include:
 Environment Protection Act 2017
 Environment Protection Regulations 2021
 Commonwealth National Environment Protection Measure for Ambient Air Quality NEPM (AAQ)
 Environment Reference Standard (ERS)
 Environment Protection Authority Publications (primarily 1961.2, 1957 and 1943)
 ‘Advisory Circular AC 139.E-02 V1.0 Plume Rise Assessments’, (CASA, 2023)
 ‘CAAP 89Z-1(0) Guidelines for plume rise assessments’ (CASA, 2003).
Requirements relevant to the Project for each of these documents are outlined below in Section 3.2 and
Section 3.3.
3.2 Air quality
3.2.1 Environment Protection Act 2017
The Environment Protection Act 2017 is a risk-based approach to preventing environmental harm and
includes a general environmental duty (GED). The GED requires people to take reasonably practicable steps
to eliminate, or otherwise reduce risks of harm to human health or the environment from pollution and waste.
Doing what is reasonably practicable means putting in proportionate controls to mitigate or minimise the risk
of harm. The GED requires identification of all risks and implementation of effective control measures so far
as reasonably practicable. This guides the approach to managing impacts on air quality and associated
environments during the Project, and was considered as part of this review.
3.2.2 Environment Protection Regulations 2021
The Environment Protection Regulations 2021 (VIC EPA, 2021a) are a subordinate instrument of the
Environment Protection Act and cover a broad suite of topics including contaminated land, the new
framework for permissions, waste management and environmental management (including air and noise) as
well as administrative matters relating to offences, fees and transitional arrangements.
Part 5 (Environmental Management) of the Regulations addresses matters including air. Part 5.2 – Air
(Regulations 103 to 112) specifies obligations on manufacturers and suppliers in relation to air pollution,
including in relation to the National Pollutant Inventory and specifies obligations in relation to Class 3
substances (listed in Schedule 4). Part 5.6 prescribes standards, limits, testing requirements and offences
relating to vehicle noise and air emissions.
Schedule 1 of the regulations lists ‘prescribed activities’ which require a VIC EPA operating licence. The two
activities of note in relation to the Project are:
 L01 (General discharges or emissions to the atmosphere)
 K01 (Power generation).
Part 3.5, Clause 39 (b) (i) exempts projects from the requirements of L01 for ‘standby’ engines. Regarding
requirement K01, the need for regulation is triggered when electrical power is generated from the
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consumption of a fuel at a “rated capacity of at least 5 MW of electrical power”. This would need to be
confirmed with the VIC EPA, noting that the individual generator units are less than 5 MW, but their collective
output exceeds this value when they are required to be used.
3.2.3 National Environment Protection Measure for Ambient Air Quality
National ambient air quality standards are specified in the current National Environment Protection Measure
for Ambient Air Quality, with the latest update gazetted in 2021 (the “NEPM(AAQ)”). The currently gazetted
NEPM(AAQ) concentration standards are listed in Table 3-1 for the indicators relevant to the Project.
Table 3-1. NEPM AAQ maximum concentration standards
Environmental Averaging period NEPM(AAQ) maximum NEPM(AAQ) permissible
indicator (air pollutant) concentration standard3 exceedances1
Particles as PM 1 day 50 µg/m3 None4
10
1 year 25 µg/m3 None
Particles as PM 1 day 25 µg/m3 None4
2.5
1 year 8 µg/m3 None
NO 1 hour 80 ppb None
2
1 year 15 ppb None
CO 8 hours2 9.0 ppm (9000 ppb) None
SO 1 hour 100 ppb None
2
75 ppb (from 2025)
1 day 20 ppb None
Odour N/A An air environment that is free N/A
from offensive odours from
commercial, industrial, trade and
domestic activities
1 Maximum allowable exceedances of concentration standard in one calendar year.
2 Rolling 8-hour average based on 1-hour averages.
3 Mass concentrations for particles in NEPM(AAQ) are referenced to gas conditions of 0C, 101.3 kPa
4 Excludes exceptional events which are defined in the NEPM(AAQ) as a fire or dust occurrence directly related to bushfire,
jurisdiction authorised hazard reduction burning or continental scale windblown dust.
It is noted that the NEPM(AAQ) concentration standards only become criteria once adopted into policy by
each State and Territory.
3.2.4 Environment Reference Standard
The ERS (Victoria Government 2021) is a subordinate instrument made under the Environment Protection
Act. The ERS was gazetted on 26 May 2021. The ERS identifies environmental values for Victoria in the areas
of air quality, noise, water and contaminated land; and defines indicators and objectives to measure those
values.
The ERS supports the protection of the environment from pollution and waste by providing a benchmark to
assess and report on environmental conditions in the whole or any part of Victoria. The ERS does not set out
enforceable compliance limits; rather, risks of harm to human health and the environment from pollution and
waste must be minimised as far as reasonably practicable, in accordance with the GED. The ERS works
alongside the GED.
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Although it is not a compliance standard and does not set compliance limits (EPA, 2021b), the ERS must be
considered by responsible authorities when making planning decisions. The ERS air quality objectives relevant
to the Project have been reproduced below in Table 3-2.
Table 3-2. ERS air quality objectives
Environmental indicator Averaging period ERS maximum ERS permissible
(air pollutant) concentration exceedances1
objective3
Particles as PM 1 day 50 µg/m3 None
10
1 year 20 µg/m3 None
Particles as PM 1 day 25 µg/m3 None
2.5
1 year 8 µg/m3 None
NO 1 hour 80 ppb 1 day/year
2
1 year 15 ppb None
CO 8 hours2 9.0 ppm (9000 ppb) 1 day/year
SO 1 hour 75 ppb 1 day/year
2
1 day 20 ppb 1 day/year
1 Maximum allowable exceedances of concentration standard in one calendar year.
2 Rolling 8-hour average based on 1-hour averages.
3 Mass concentrations for particles in ERS are referenced to gas conditions of 0C, 101.3 kPa
3.2.5 EPA Publication 1961.2
Publication 1961.2 ‘Guideline for assessing and minimising air pollution in Victoria’, (VIC EPA, 2025a)
provides a framework to assess and control risks associated with air pollution in the form of a technical
guideline for air quality practitioners and specialists. The guideline provides a tiered approach to the
assessment of risks from air pollution, with three levels of assessment in order of increasing complexity that
define the role of atmospheric dispersion modelling and monitoring intended by EPA Victoria within the
Environment Protection Act and GED framework.
As well as providing guidance for air quality modelling and assessment, Publication 1961.2 also provides air
pollutant assessment criteria (APAC) for assessing developments that could result in emissions to air in
Victoria. Publication 1961.2 adopts the same APAC values as the ERS objective values for the pollutants listed
above in Table 3-2. It also provides the following APAC values for the following speciated VOCs relevant to
the Project:
Table 3-3. Air pollutant assessment criteria for speciated VOCs (EPA, 2025)
Pollutant Basis of design criteria Averaging time Design criteria
Acetaldehyde Health 1-hour 470 µg/m3
Benzene Health 1-hour 580 µg/m3
Formaldehyde Health 30-minutes 100 µg/m3
Toluene Health 1-hour 7,600 µg/m3
Xylene Health 1-hour 22,000 µg/m3
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These APAC values from Publication 1961.2 were adopted to evaluate air quality outcomes, with the relevant
guidance for undertaking and presenting the assessment process, outcomes and recommendations also
incorporated.
3.2.6 Other relevant EPA Publications
In addition to Publication 1961.2 (VIC EPA, 2025a), the following VIC EPA publications also contain guidance
relevant for the assessment:
 Publication 1943 ‘Guidance for assessing nuisance dust’, (VIC EPA, 2025b)
 Publication 1957 ‘Guide to air pollution modelling’, (VIC EPA, 2023).
Applicable guidance from these publications is summarised below in Table 3-4.
Table 3-4. Other VIC EPA Publications relevant to the assessment
Publication Relevant guidance and how applied in the assessment
1957 Publication 1957 (VIC EPA, 2023) provides guidance for Air Pollution Impact Assessments
required by VIC EPA for licence approvals and other regulatory purposes within the state. The
publication provides guidance for practitioners who are involved in conducting air dispersion
modelling of discharges to air in Victoria.
The publication lists AERMOD as the VIC EPA’s approved regulatory air dispersion model and
details key settings and processes to be applied when the tool is used for air quality impact
assessments in Victoria.
Consistent with Publication 1957, AERMOD and the associated meteorological processor
AERMET were used to assess operational emissions to air associated with the Project, with the
recommended settings also applied as appropriate.
1943 Publication 1943 (VIC EPA, 2025b) provides a framework to assess risks from nuisance dust.
This framework is consistent with the overarching provisions of the GED to ‘eliminate or
minimise the risks posed by hazards to prevent harm’. The framework assesses the risk posted
by nuisance dust by considering three elements:
 Step 1: The hazard potential of dust sources. This is evaluated based on the size, nature of
activities, type of emissions generated and level of control.
 Step 2: The exposure pathway between the source and receiving environment. The
framework considers the separation distance, orientation, and intervening terrain and land
uses features between the activity or project and the surrounding receivers.
 Step 3: The sensitivity of the receiving environment. This aspect considers the historical
context of air quality-related issues experienced by people in the receiving environment, as
well as the overall land use across this setting.
The methodology presented in Publication 1943 was applied to assess the potential for
nuisance dust risks during construction, including the development of suitable mitigation and
management measures.
Guidance was also drawn from the following publications for managing dust and other emissions to air during
construction:
 Publication 1834.2 ‘Civil construction, building and demolition guide’, (EPA, 2025c)
 Publication 1730 ‘Solid storage and handling guidelines’, (EPA, 2019a)
 Publication 1894 ’Managing soil disturbance: guidance sheet’, (EPA, September 2020a)
 Publication 1895 ‘Managing stockpiles: guidance sheet’, (EPA, July 2019b)
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 Publication 1897 ‘Managing truck and other vehicle movement: guidance sheet’, (EPA, September
2020b).
3.3 CASA plume rise guidance
The publications listed above (CASA, 2003 and 2023) provide the process for assessing plume rise impacts.
The current process is outlined in ‘Advisory Circular AC 139.E-02 V1.0 Plume Rise Assessments’, (CASA,
2023). The key steps now involve:
1. Proponent completing an initial assessment of plume exit velocities and potential effects.
2. If exit velocities exceed 4.3 m/s, submission of Form 1247 to CASA, as well as any aerodrome operators
within 15 kilometres of the proposed facility.
3. CASA will use the information provided in the submitted Form 1247 to conduct a preliminary assessment
using their screening tool. If the outputs of the screening assessment indicate that plume velocities would
not infringe a flight protection surface (i.e., OLS, PANS-OPS) at a velocity exceeding 4.3 m/s, no further
assessment is deemed as being required.
4. If CASA’s screening assessment indicates that plume velocities may infringe a flight protection surface,
subsequent more detailed assessment may be completed using the Exhaust Plume Analyser (EPA)
software. Other factors (including outcomes from stakeholder consultation) would be considered in
CASA’s review of risks to aviation safety from plume effects of the proposed development.
This report presents the process and outcomes of steps 1 and 2 of the current CASA assessment process.
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4. Assessment methods
4.1 Overview
This section of the report describes the approaches applied to assess potential operational air quality and
plume rise impacts associated with the Project. The method applied in relation to air quality is presented in
Section 4.2, and the approach for reviewing plume rise is summarised in Section 4.3.
4.2 Air quality
4.2.1 Existing environment
Key features of the existing environment as relevant to air quality include:
 Surrounding sensitive receptors
 Land use and topography
 Local meteorology
 Other local sources of emissions to air
 Background air quality
 Protected airspace requirements.
Table 4-1 below describes how each of these aspects of the existing environment around the Project were
characterised:
Table 4-1. Inputs used to characterise features of existing environment
Feature Source
Surrounding land Surrounding land use and nearby sensitive receptors were identified using recent aerial imagery
uses and sensitive available from MetroMap, supplemented with land use information from VIC Plan (Victoria's
receptors Planning Policy Framework & Victoria Planning Provisions). Land uses and surrounding
sensitive receptors around the Project are identified below inSection 5.1
Topography Elevations around the Project were generated data from the United States Geological Survey
(USGS) one-second (30 m resolution) Shuttle Radar Topography Mission (SRTM). Noting that
this is an input to AERMOD, further details of this element of the existing environment are
provided in Section 4.2.2.4.
Local meteorology Data collected from the nearby automatic weather station (AWS) operated by the
Commonwealth Bureau of Meteorology (BoM) at RAAF Williams (Laverton) were used with
prognostic data generated using the CSIRO’s TAPM to understand local meteorological
conditions around the Project.
Local meteorology is an input for AERMET. As such, local meteorology around the Project
applied in the assessment is also described below inSection 4.2.2.4.
Other local sources Surrounding existing sources of emissions to air around the Project were identified using
of emissions to air information from the Commonwealth Department of Climate Change, Energy, the Environment
and Water (DCCEEW’s) National Pollutant Inventory (2023/24 reporting year) database and
VIC EPA’s Operating Licence Register for prescribed activities defined in Schedule 1 of the
Environment Protection Regulations 2021. Further details of these existing nearby sources of
emissions to air are provided in Section 5.2.
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Background air Background air quality conditions around the Project were determined from monitoring data
quality collected at nearby and otherwise representative stations operated by the VIC EPA. Details of
the stations and data used are provided below in Section 5.3.
Protected airspace The Project site is located within the prescribed airspace of RAAF Base Point Cook and
requirements Essendon Fields Certified Aerodrome. Specific aviation restrictions (e.g., OLS and PANS-OPS)
are published by the aerodrome operators. Further details of the restrictions that apply around
the aerodrome are provided below in Section 5.4.
4.2.2 Impact assessment approach
4.2.2.1 Construction
The overall method for the construction air quality impact assessment included:
 Identifying key issues (as described in Section 2.4) to be addressed in the impact assessment
 Potential air quality impacts from the Project were determined in a manner generally consistent with
Publication 1961. Consistent with this guidance, a Level 1 assessment methodology was applied.
 Construction nuisance dust impacts were assessed using the methodology detailed in Publication 1943
(refer to Appendix C) where a risk score is calculated that takes into account source, pathway and
receptor attributes that contribute to the magnitude of dust impact risk. Initial unmitigated impact ratings
were determined as summarised below in Table 4-2. It is noted that the scoring, ratings and descriptions
in Table 4-2 are reproduced from Publication 1943.
Table 4-2. Construction dust impact ratings (Source: EPA, 2025b)
Score Impact rating Description
32-36 Very high Dust impact almost certain. Nuisance dust impacts will occur. Any interventions
to reduce impacts in either the source, pathway or receiving environment are
unlikely to be practical so effective mitigation is doubtful.
27-31 High Dust impacts highly likely to occur. Significant nuisance dust to occur, and
impacts are highly likely. There may be some interventions that can be applied to
reduce the impacts, but it is likely that significant re-engineering
or redesign will be required.
22-26 Medium Dust impacts likely. Some nuisance dust impacts to occur and without
careful and considered application of mitigation measures it is likely to cause
impacts. The focus should be what can be done to break the
source-pathway-receiving environment chain.
17-21 Moderate Dust impacts only likely to occur on rare occasions. Although there may be some
residual nuisance dust impacts, it is possible it can be practically and effectively
managed.
12-16 Low Dust impacts are not likely and any would be minimal.
 To address the initial, unmitigated impacts determined, mitigation and management measures were
developed with reference to relevant guidance from Publication 1834.1, (VIC EPA, 2025c), Publication
1730, (VIC EPA, 2019a), Publication 1894, (VIC EPA, 2020a), Publication 1895, (VIC EPA, July 2019b)
and Publication 1897, (VIC EPA, 2020b).
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 Other air quality-related impacts were qualitatively assessed consistent with Publication 1961.2 Level 1
requirements. Potential impacts associated with these matters were identified with reference to the
ratings developed for the assessment below in Table 4-3. Based on these outcomes, mitigation and
management measures were recommended, consistent with the requirements of the GED, and residual
construction air quality impacts were determined.
Table 4-3. Exhaust emissions and/or odours/airborne hazards impact assessment ratings
Impact rating Comment
Very high Exhaust emissions and/or odours/airborne hazards and/or non-construction dust impacts almost
certain. Interventions to reduce impacts in either the source, pathway or receiving environment
are unlikely to be practical so effective mitigation is doubtful.
High Exhaust emissions and/or odours/airborne hazards and/or non-construction dust impacts highly
likely to occur. Significant impacts to occur, and impacts are highly likely. There may be some
interventions that can be applied to reduce the impacts, but it is likely that significant re-
engineering or redesign will be required.
Medium Exhaust emissions and/or odours/airborne hazards and/or non-construction dust impacts likely.
Some impacts to occur and without careful and considered application of mitigation measures it
is likely to cause impacts. The focus should be what can be done to break the source-pathway-
receiving environment chain.
Moderate Exhaust emissions and/or odours/airborne hazards and/or non-construction dust impacts only
likely to occur on rare occasions. Although there may be some residual impacts, it is possible it
can be practically and effectively managed.
Low Exhaust emissions and/or odours/airborne hazards and/or non-construction dust impacts are not
likely and are expected to be minimal.
Negligible Exhaust emissions and/or odours/airborne hazards and/or non-construction dust impacts are
extremely unlikely to occur.
4.2.2.2 Operations
Potential air quality impacts from emergency generator use (including routine testing and maintenance, as
well as emergency operations) were quantitatively assessed using air dispersion modelling. Modelling was
undertaken using the VIC EPA’s approved regulatory model, AERMOD. The key steps in the assessment
methodology, including the inputs and processes applied are outlined in the following subsections.
4.2.2.3 Emissions inventory
Emissions were developed and assessed for the following testing and maintenance, and emergency
operational scenarios:
 Scenario 1, testing and maintenance: 2 units in operation, modelled as generator sources ‘1A’ and ‘1B’.
 Scenarios 2 and 3, emergency operations:
- One building (i.e., 56 units in operation, i.e. partial power supply outage)
- Two buildings (i.e., all 112 3 MW units in operation, i.e. full power supply outage). It is noted that this
is conservative, with up to 96 3 MW generator units expected to be required for a full mains outage.
Scenarios 2 and 3 are considered to be very unlikely owing to the redundancy in power supplies to site. Still
both have been considered consistent with assessment requirements.
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The approximate locations of each generator stack are displayed below in Figure 4-1 with each location
representing two generator unit stacks. The source parameters applied in the model (geometric, stack
parameters and emission rates) are listed in Appendix A.
Figure 4-1. Source arrangement, proposed Brooklyn data centre
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4.2.2.4 Modelling and assessment
Overview
Consistent with Publication 1957 the VIC EPA’s approved regulatory dispersion model AERMOD (American
Meteorological Society/Environmental Protection Agency Regulatory Model) was used to assess potential
operational air quality impacts from the Project. Details regarding the inputs and set-up applied in the three
key modules (AERMAP, AERMET and AERMOD) are provided in the following sub-sections.
AERMAP terrain set-up
AERMAP is the terrain preprocessor for the AERMOD modelling system. It incorporates terrain effects into air
the model by calculating terrain elevations and hill heights for each receptor and source location. AERMAP
uses digital elevation data to determine the elevation and the critical hill height scale, which influences plume
rise and dispersion in complex terrain. By providing this terrain information, AERMAP ensures that AERMOD
can accurately simulate how topography affects pollutant transport and concentration patterns.
Section 5 of Publication 1957 describes the VIC EPA’s key considerations for configuring AERMAP. For the
assessment, AERMAP was set-up in a manner consistent with these requirements, with the United States
Geological Survey (USGS) one-second (30 m resolution) Shuttle Radar Topography Mission (SRTM) used to
develop the digital elevation model (DEM) around the Project. Set-up details applied for the Project are
summarised in Table 4-4 below.
Table 4-4. AERMAP set-up details
Project site 1-second Region DEM applied
SRTM file used
Southwest corner (m) Northeast corner (m)
X Y X Y
Brooklyn S38_E144_1arc_ 306000 5807000 316000 5817000
v3
The DEMs were applied to all sources, buildings and receptors (details provided below) in the respective
models prepared for both sites.
AERMET meteorological set-up
AERMOD requires meteorological data that accurately represents atmospheric conditions at and around the
Project site. AERMOD requires that these data are pre-processed using AERMET. AERMET converts raw
surface and upper-air data into the specific parameters AERMOD needs, such as wind speed and direction,
temperature, turbulence characteristics, and mixing heights. This processing ensures that the dispersion
model accounts for boundary layer dynamics and stability, which are critical for predicting pollutant transport
and dispersion under realistic conditions.
AERMET was set-up in general accordance with the guidance from Publication 1957, with the process applied
as summarised below:
 Surface observation data was obtained from the Bureau of Meteorology (BoM) RAAF Williams (Laverton)
automatic weather station (AWS) No. 087031 located approximately 9 km to the south east of the
Project site for the calendar years 2020 to 2024 inclusive (i.e., five continuous years consistent with
Section 4.1 of Publication 1957). Data from this AWS was selected noting its proximity to the site, as well
as it being a similar distance from the coast as the Project site, and with the terrain between RAAF
Williams (Laverton) and the Project site being generally flat with no significant intervening features.
 The CSIRO’s prognostic model TAPM (The Air Pollution Model) was set up and run as summarised in
Table 4-5. ‘Nudging’ was applied using observation data from the RAAF Laverton AWS.
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Table 4-5. TAPM set-up details
Model input Value
TAPM version 4.0.5
Number of grids (spacing) 4 (10 km, 3 km, 1 km and 0.3 km)
Number of grid points (x y  z) 41  41  25
Simulation period January 2020 to December 2024 inclusive with one spin-up day applied
Terrain information AUSLIG 9 second DEM database
Land use and sea surface TAPM default databases
temperature
Centre of analysis 37o50.0’S, 144o48.5’E
Local data assimilation Yes, model nudged using surface observation data from BoM RAAF Williams
(Laverton) AWS. Observations configured as follows:
Radius of influence = 3 km. Number of vertical levels for assimilation = 3. Quality
factor = 1
 Meteorological data outputs from TAPM were extracted for the Project location and processed for use as
on-site surface observation data in AERMET.
 Detailed set-up details for AERMOD are summarised below in Table 4-6.
Table 4-6. AERMET set-up details
Model input Value
AERMET version Latest USEPA AERMET version 24142 with data input via Lakes Environmental
AERMET View software
Mode Surface data from on-site stations only as extracted from TAPM
Modelling period Five years (1 January 2020 to 31 December 2024 inclusive)
AERSURFACE surface parameters 12 sectors processed using AERSURFACE utility version 20060, with land use
defined using NLCD92 Land Cover Classes interpreted from aerial photography
using “Land Use Creator” module in AERMET View. Average moisture, with
settings varying by season and month
Other parameters Processing Stable Boundary Layer (SBL) using Bulk Richardson Numer enabled,
threshold wind speed set at 0.5 m/s, low-wind surface friction velocity
adjustment enabled
 AERMET was used to develop hourly meteorological conditions at the sites for 2020 to 2024 inclusive.
Annual and seasonal wind roses from the AERMET outputs for each calendar year are displayed in
Appendix B. Consolidated wind roses (i.e. merging the outputs from all five years at the site) providing a
summary of the modelled conditions are also displayed in Figure 4-2. For comparison, measured values
from BoM RAAF Williams (Laverton) AWS for 2020 to 2024 are also displayed in Figure 4-3.
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Figure 4-2. AERMET 2020 to 2024 annual and seasonal wind roses for Brooklyn site
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Figure 4-3. 2020 to 2024 annual and seasonal wind roses from BoM Laverton (RAAF Williams)
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AERMOD dispersion modelling set-up
AERMOD is VIC EPA’s approved regulatory model for air quality impact assessment. AERMOD is a
steady‑state atmospheric dispersion modelling system that utilises Gaussian plume dispersion concepts for
horizontal spreading and Non‑Gaussian approaches for vertical dispersion, accounting for boundary‑layer
turbulence. Table 4-7 describes how the model were configured for the assessment. This set-up is generally
consistent with the guidance presented in Publication 1957.
Table 4-7. AERMOD set-up details
Model input Value
AERMOD version AERMOD.EXE (v 24142 64-bit)
Control pathway
Dispersion options Default regulatory options, ‘Urban’ dispersion co-efficient
Pollutants NO , particulate matter, CO and hydrocarbons
2
Averaging periods and NO : 1-hour (99.9th), Annual
2
percentiles PM: 24-hour (100th), Annual
CO: Rolling 8-hour (100th)
Hydrocarbons: 1-hour and 30-minutes (99.9th)
NO to NO conversion Ozone Limiting Method using hourly averaged Ozone (O ) from VIC EPA Footscray
x 2 3
supplemented with data from VIC EPA Alphington (for data gaps)
Terrain options ‘Elevated’ with elevations assigned to all receptors.
Extents applied (Brooklyn):
Southwest corner: 316000, 5807000
Northeast corner: 306000, 5817000
Mesh size: 100
Assessment period 2020 to 2024 inclusive
Source pathway
Sources Refer to Section 4.2.2.3 above and Appendix A
Building downwash calculation On-site building footprints (in blue) and heights added and downwash effects
considered using BPIP/BPIP Prime algorithm as detailed below. Both buildings were
set at a height of approximately 24.5 m above finished ground level. Other existing
buildings at the site would be removed and were not included.
Background concentrations Hourly background concentrations applied for each pollutant listed above (including
O ) as described below in Section 5.3.
3
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Indicative population of the 100,000
urban area
Receptor pathway
Gridded receptors Applied via uniform cartesian grid over the same extents as the ‘Terrain options’
above at a spacing of 50 m.
Discrete receptors Discrete receptors applied at the nearest sensitive receptors in each direction as
described below in Section 5.1.
Meteorology pathway
Surface and profile 2020 to 2024 surface (.SFC) and profile (.PFL) files generated using AERMET
meteorological inputs described above with the base height of the surface station anemometer set at the
site ground level above mean sea level.
Output pathway
Output settings 9th highest hourly, 1st height results for rolling 8-hour and daily 24-hour predicted
concentrations at each gridded and discrete sensitive receptor.
Post-processing and evaluation
Potential impacts were evaluated by comparing the cumulative (i.e., background plus Project contribution)
modelling results at sensitive receptors with the ERS and other relevant air quality objectives outlined in
Section 3.2. Results have been presented in the relevant tabulated and graphical contour plot formats (refer
to Appendix D), as described in Publication 1957.
4.3 Plume rise assessment
The site is located within 15 km of Certified Aerodrome. Certified Aerodrome have prescribed airspace that
needs to be kept free from obstacles and effects that could affect aircraft operations. To assess against these
requirements, a screening assessment was initially completed in accordance with CASA’s most recent, explicit
TAPM (The Air Pollution Model) plume rise assessment set-up guidance. This methodology is presented in
‘CAAP 89Z-1(0) Guidelines for plume rise assessments’ (CASA, 2003) and included:
 Modelling using TAPM version 2.0 or higher using multiple years of continuous meteorological data
modelled. Consistent with this requirement and more recent advice from CASA, 2022 to 2024 were
considered for this assessment.
 Horizontal displacement of the plume centreline evaluated as a function of height
 Plume spread about the centreline evaluated as a function of height
 Consideration of “average” and “peak” vertical plume velocities for each height
 Wind speed evaluated as a function of height
 Predicting the probability of vertical velocity exceeding the CASA critical plume velocities (CPVs) being
exceeded.
Further model set-up details for the plume rise screening review are provided below in Table 4-8.
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Table 4-8. TAPM set-up details for plume rise screening review
Model input Value
TAPM version 4.0.5
Number of grids (spacing) 3 (30 km, 10 km, 3 km)
Number of grid points (x y  z) 25  25  25
Simulation period Jan 2022 to Dec 2024 inclusive
Terrain information AUSLIG 9 second DEM data
Centre of analysis 37o50.0’S, 144o47.5’E
Local data assimilation None
Mode Meteorology and pollution mode
For emissions from multiple stacks there is the possibility that merged, overlapping hot plumes may interact
with one another, resulting in a single, higher buoyancy plume. This process is referred to as buoyancy
enhancement.
The buoyancy enhancement factor (N ) is defined (Hibberd et al, 2005) as follows:
E
n  S 
N 
Equation 1 E  1 S  
Where n is the number of stacks and S is a dimensionless separation factor, defined as:
3

n 1.s
2
Equation 2 S  6  
 1 
 n3.z 
Where Δs is the stack separation and Δz is the rise of an individual plume. This approach is relevant to stack
emissions of similar physical and emission characteristics, as is the case for the Project. TAPM was initially run
without buoyancy enhancement. From these runs, the buoyancy enhancement results in Table 4-9 were
determined. This confirmed that buoyancy enhancement required consideration. Using equations 1 and 2
above, TAPM was re-run with the calculated N values applied to account for the buoyance enhancement
E
effects resulting from the generator stacks being similar and located in close proximity to each other.
Table 4-9. Back-up diesel generator initial maximum and average final rise heights of the individual
plumes (m AGL) and calculated buoyancy enhancement factor (N )
E
Parameter Results, Brooklyn (2022, 2023 and 2024)
Average plume rise height (m AGL) 76, 72 and 75
Maximum plume rise height (m AGL) 350, 394 and 393
Buoyancy enhancement factor (N ) 5.5, 6.2 and 6.2 (Average 6.0)
E
Results from the plume rise screening assessment were evaluated by reviewing the results against CASA’s
primary CPV (4.3 m/s) at the level of the most stringent applicable protected airspace layer (described in
further detail below in Section 5.4).
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5. Existing conditions
5.1 Surrounding sensitive land uses
VIC EPA Publication 1961.2 defines sensitive land uses as including “land use where it is plausible for humans
to be exposed over durations greater than 24 hours, such as residential premises, education and childcare
facilities, nursing homes, retirement villages, hospitals”. It is noted that the ERS air quality objectives apply to
all locations across Victoria, including less sensitive land uses (e.g., commercial and industrial) that are not
covered under the definition from Publication 1961.2 above.
The nearest sensitive land uses in relation to the proposed Brooklyn data centre are displayed in Figure 5-1
below.
Figure 5-1. Surrounding land uses and receptors, Brooklyn
The details of the nine nearby representative sensitive receptors around the site displayed on Figure 5-1 are
also summarised below in Table 5-1.
With reference to the ERS, Figure 5-1 shows that other industrial land uses outside the Publication 1961.2
sensitive land uses definition are located immediately adjacent to the Project site.
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Table 5-1. Nearby representative sensitive receptors around Brooklyn site
Receptor ID Type Easting (UTM MGA Northing (UTM Elevation (m)
Zone 55) (m) MGA Zone 55) (m)
1 Residential 310725 5812259 24
2 Residential 310691 5812038 22
3 Residential 310671 5811901 26
4 Residential 311004 5811402 24
5 Residential 311400 5811251 23
6 Residential 311838 5812251 16
7 Residential 311892 5812692 22
8 Residential 311643 5813926 29
9 Residential 309137 5813829 29
5.2 Other local sources of emissions to air
As outlined in Section 4.2.1, other existing sources of emissions to air around the Project location were
identified from a review of 1) nearby facilities that triggered applicable thresholds and reported to the
Commonwealth Department of Climate Change, Energy, the Environment and Water (DCCEEW’s) NPI
database in 2023/24, and 2) surrounding sites with an active operating licence issued by the VIC EPA. These
locations around the Project are summarised below in Table 5-2 (NPI-triggered facilities) and Table 5-3
(locations with active VIC EPA operating licence). For sites that triggered NPI reporting thresholds and also
hold an active VIC EPA operating licence, these locations have not been reproduced in Table 5-3.
As these table demonstrate, there are several industrial facilities around the Project that would contribute to
existing local air quality conditions.
Table 5-2: Nearby facilities around the Brooklyn site where NPI emissions to air were reported in 2023/24
Facility name Registered Business Address Main activities Emissions to air
name reported in
2023/24
Opal Fibre Packaging OPAL PACKAGING 512-520 GEELONG Manufacturing of CO, NO , PM ,
x 10
Brooklyn AUSTRALIA PTY LTD RD Brooklyn cardboard boxes and PM , SO , PAHs,
2.5 2
packaging material VOCs (total)
from recycled paper
Brooklyn JBS AUSTRALIA PTY 30 INDUSTRY PARK Red Meat Processing Metals, VOCs
LIMITED DR Brooklyn (abattoir) (total and
speciated), CO,
NO , PM , PM ,
x 10 2.5
SO ,TEQ, PAHs
2
Veolia Brooklyn VEOLIA 15 MCDONALD RD Liquid & solid Mercury, sulfuric
ENVIRONMENTAL Brooklyn prescribed waste acid, zinc and
SERVICES treatment. compounds
(AUSTRALIA) PTY LTD
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Allegion Door and ALLEGION 42 EXPORT DR Manufacturer of Locks Zinc and
Access Systems - (AUSTRALIA) PTY LTD Brooklyn (Doors and Access compounds
Brooklyn Systems)
CARGILL CARGILL PROCESSING 425 SOMERVILLE RD Oilseed Processing Metals, VOCs
PROCESSING LIMITED Footscray West Plant - crushing (total and
LIMITED canola to produce speciated), CO,
vegetable oil and high NO , PM , PM ,
x 10 2.5
protein meal for SO ,TEQ, PAHs,
2
stockfeed. mercury
Table 5-3. Locations with active VIC EPA operating licence around the Brooklyn site
Operating licence No. Activity site Permission holder Air quality discharge
requirements
OL000000788 680 Geelong Road AUSTRALIAN TALLOW No licenced air discharge
Brooklyn PRODUCERS PTY. LTD. points or limits
OL000212257 457 Somerville Rd BLACK RUBBER PTY LTD No licenced air discharge
Brooklyn points or limits
OL000011972 84 - 92 Jones Rd Brooklyn WESTERN LAND No licenced air discharge
RECLAMATION PTY LTD points or limits
OL000011628 27 - 35 McDonald Rd TANK SERVICES No licenced air discharge
Brooklyn AUSTRALIA PTY LTD points or limits
OL000300095 44 McDonald Road SIMS GROUP AUSTRALIA No licenced air discharge
Brooklyn HOLDINGS LIMITED points or limits
OL000300052 125 Bunting Road RESOURCECO PTY LTD No licenced air discharge
Brooklyn points or limits
OL000069025 174 Old Geelong Rd EDL LFG (VIC) PTY LTD CO, 205 tonnes per year
Brooklyn (t/y)
OL000300079 473 Somerville Road, DELTA RECYCLING PTY No licenced air discharge
Brooklyn LTD points or limits
OL000300058 174 Old Geelong Road CLEANAWAY SOLID WASTE No licenced air discharge
Brooklyn PTY LTD points or limits
OL000000694 21 Paw Paw Rd Brooklyn CHEMPROD NOMINEES Points 1 and 2:
PROPRIETARY LIMITED SO , 7.5 grams per minute
2
(g/min)
Sulfur trioxide (SO ), 0.9
3
g/min
Point 1 only:
Alumina hydrate, 8 g/min
OL000068908 74 Old Geelong Rd APA VTS AUSTRALIA CO, 250 g/min
Brooklyn (OPERATIONS) PTY LTD NO as NO , 475 g/min
x 2
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5.3 Background air quality
5.3.1 Overview
The VIC EPA operates an ambient air quality monitoring network throughout the state. The stations that
measure the required pollutants over the period of assessment (2020 to 2024) that are nearest and most
representative of conditions around the Project site include:
 Brooklyn station: Located 400 m to the southwest of the site in a residential area adjacent to industry.
The station has been in operation since late 2009. Only Particulate matter as PM is measured at the
2.5
station.
 Footscray station: Located around 2.3 km to the northeast of the site in a residential area adjacent to
industry and key transport corridors. Pollutants including NO , CO, PM and O are measured at the
2 2.5 3
station.
 Alphington station: Located further away, approximately 16 km to the northeast of the Brooklyn site.
The station was operational over the entire period of review (2020 to 2024 inclusive), with pollutants
including NO , CO, PM and O measured. The station provides a representative alternative for
2 2.5 3
background conditions when data from the two closer stations are not available.
Background air quality data for sensitive receptors around the site were initially adopted from Footscray. Any
data gaps in the Footscray monitoring data were supplemented using data from Alphington. Any residual
gaps were filled using the 70th percentile value of the measured data applied from Footscray and Alphington
stations. Data were not used from the Brooklyn station owing to the limited pollutants measured and there
being some issues with data completeness.
The background data developed for the assessment using this approach are summarised by pollutant below
in Section 5.3.2 (NO and O ), Section 5.3.3 (CO) and Section 5.3.4 (PM ).
2 3 2.5
5.3.2 Nitrogen dioxide (NO ) and Ozone (O )
2 3
As described in Section 4.2.2.4, the OLM method was used to convert results for NO to NO . Figure 5-2
x 2
displays a time series of the hourly background NO and O concentrations that were applied in the
2 3
assessment
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Figure 5-2. Time-series of adopted 1-hour NO and O background concentrations (EPA, 2020 to 2024)
2 3
5.3.3 Carbon monoxide (CO)
Figure 5-3 shows a time series plot of the rolling 8-hour averaged COconcentrations applied in the
assessment using data collected from the VIC EPA’s Footscray and Alphington stations from 2020 to 2024.
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Figure 5-3. Time-series of adopted rolling 8-hour averaged CO background concentrations (EPA, 2020 to
2024)
The highest rolling 8-hour averaged COconcentration recorded over the five year period was 2,700 ppb
which is well below the 9,000 ppb (10,300 µg/m3) objective from the ERS and Publication 1961.2.
5.3.4 Particulate matter (PM )
2.5
A time series of the 24-hour averaged PM concentrations applied in the assessment using data from
2.5
Footscray and Alphington stations is shown below in Figure 5-4.
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Figure 5-4. Time-series of adopted 24-hour averaged PM background concentrations (EPA, 2020 to
2.5
2024)
As Figure 5-4 shows, there were several instance from 2020 to 2024 where daily averaged PM
2.5
concentrations exceeded 25 µg/m3:
 13 days in 2020
 3 days in 2021
 6 days in 2024.
Key statistics for PM over the monitoring period are summarised below in Table 5-4.
2.5
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Table 5-4. Local background PM statistics over the 2020 to 2024 monitoring period
2.5
Year Annual average Maximum 24-hour 70th percentile Highest 24-hour
(µg/m3) average (µg/m3) 24-hour average concentration
(µg/m3) below criterion
(µg/m3)
2020 10 200 8 23.3
2021 7 33 8 23.5
2022 6 23 7 23
2023 7 23 8 23
2024 7 29 8 23.5
The statistics in Table 5-4 are presented, noting that the 24-hour averaged criteria from the ERS and
Publication 1961.2 applies to the maximum cumulative daily PM concentration. 70th percentile and the
2.5
next highest 24-hour averaged concentration in the 2020 to 2024 period below the 25 µg/m3 criteria are
listed so that the test can be applied whether the Project could result in any additional exceedances of this
criterion at surrounding sensitive receptors.
5.4 Protected airspace requirements
5.4.1 RAAF Base Point Cook
The Brooklyn data centre site is located approximately 15 km northeast of RAAF Base Point Cook Certified
Aerodrome. RAAF Base Point Cook has an OLS and PANS-OPS. At the approximate location of the proposal, it
is understood that the OLS is the lower of the PANS-OPS and OLS (i.e., more stringent), being a minimum of
150 m above ground level referenced to the aerodrome reference point (ARP). The height of the ARP at
RAAF Base Point Cook is 4 m and the approximate base elevation for the new data centre at Brooklyn is
around 31 m. As such, the height available to the OLS around the new Brooklyn data centre would be
approximately 123 m.
5.4.2 Essendon Fields
The Brooklyn data centre site is also located within 15 km of Essendon Fields Certified Aerodrome. Current
OLS and PANS-OPS for the airport are published in ‘Essendon Airport Master Plan 2013’, (Essendon Airport
Pty Ltd, 2014). It is understood that this plan is to be updated, although this is scheduled to commence in
quarter three of 2026. Current advice from the aerodrome operator is that the 2013 Master Plan remains in
effect. The Project is also located in the ’outer horizontal surface’ for the OLS. At the approximate location of
the new data centre the OLS is lower than the PANS-OPS, being 228.5 m high, referenced to the Essendon
Fields Aerodrome ARP (86 m). As noted above the approximate ground elevation at the Project is around 31
m. As such the available height above ground level at the new Brooklyn data centre would be around 197.5
m.
5.4.3 Summary
Based on the information presented in Section 5.4.1 and Section 5.4.2 it was determined that the OLS
around RAAF Base Point Cook would be the most stringent nearby prescribed airspace layer. As such, impacts
were evaluated against this requirement.
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6. Air quality impact assessment
6.1 Construction
6.1.1 Nuisance dust review
6.1.1.1 Overview
Publication 1943 provides a framework for assessing nuisance dust impacts. This framework is consistent with
the overarching provisions of the GED to ‘eliminate or minimise the risks posed by hazards to prevent harm’.
The framework assesses the risk posted by nuisance dust by considering three elements:
 Step 1: The hazard potential of dust sources. This is evaluated based on the size, nature of activities, type
of emissions generated and level of control.
 Step 2: The exposure pathway between the source and receiving environment. The framework considers
the separation distance, orientation, and intervening terrain and land uses features between the activity
or project and the surrounding receivers.
 Step 3: The sensitivity of the receiving environment. This aspect considers the historical context of air
quality-related issues experienced by people in the receiving environment, as well as the overall land use
across this setting.
As displayed below in Figure 6-1 these outcomes from Steps 1, 2 and 3 are combined to determine the
overall risk of dust impacts from an activity or project (Step 4), with the final outcome being any residual
impacts once planned mitigation and management measures are applied.
Figure 6-1. Nuisance dust risk assessment framework (Source: EPA, 2025b)
The process and outcomes applied for steps 1 to 4 are presented in the following subsections.
6.1.1.2 Step 1: Hazard potential of dust sources
Step 1 of the Publication 1943 nuisance dust assessment method involves evaluating the potential for an
activity or source to generate nuisance dust emissions, as well as the characteristics of the dust emissions. The
method considers the size of the potential dust emission sources, nature of activities to be undertaken, the
type of dust emissions (relating to the material type), and the ease of control of emissions. Based on Project
size, the expected extent of earthworks and demolition of existing structures required, and the expected
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activities during construction and using the guidance from Publication 1943 (reproduced in Appendix C) the
following construction dust hazard potential ratings were determined:
Table 6-1. Construction dust hazard potential ratings
Project Score
Size of dust Activities being Type of dust Level of control Total
emitting undertaken emission
source
Brooklyn site 2 2 2 2 8
6.1.1.3 Step 2: Exposure pathway effectiveness
Step 2 of the Publication 1943 nuisance dust assessment method considers the effectiveness of the dust
transmission pathway from the source to the receiving environment. The factors evaluated in determining the
dust transmission pathway effectiveness are detailed in Appendix C. Using this guidance and current limited
information available for the Project, the dust exposure pathway effectiveness ratings listed in Table 6-2
below were estimated.
Table 6-2. Construction dust exposure pathway effectiveness ratings
Project Score
Distance Orientation of Terrain Intervening land Total
receivers relative use
to prevailing
wind direction
Brooklyn site 2 1# 2 2 7
# Based on wind roses developed for the assessment and the location of the nearest representative sensitive receptors in-relation to the
site
6.1.1.4 Step 3: Receiving environment sensitivity
Step 3 the EPA’s nuisance dust assessment framework considers the context (historical and land use) within
which an activity or project is to be completed. Guidance for characterising these aspects for an assessment
has been reproduced in Appendix C. Using this guidance and current limited information available for the
Project, the following nuisance dust receiving environment sensitivity ratings were estimated:
Table 6-3. Receiving environment nuisance dust sensitivity ratings
Project Score
Historical Context Land use Total
Brooklyn site 4 4 8
6.1.1.5 Step 4: Unmitigated impact assessment
Consistent with Figure 6-1, Step 4 involves the combination of the values for hazard potential (Step 1),
pathway effectiveness (Step 2) and receiving environment sensitivity (Step 3) to determine the overall
potential for impacts (in the absence of mitigation). Guidance from Publication 1943 for Step 4 was
reproduced above in Table 4-2.
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Based on the hazard potential (Step 1), pathway effectiveness (Step 2) and receiving environment sensitivity
(Step 3) ratings determined above, Table 6-4 lists the overall potential unmitigated nuisance dust ratings
determined for the Project.
Table 6-4. Unmitigated nuisance dust impact ratings, construction
Project Score Unmitigated
impact rating
Receiving Pathway Hazard potential Total and
environment effectiveness rating
sensitivity
Brooklyn site 8 7 8 23
Medium, dust
impacts likely
if not properly
managed
6.1.1.6 Dust management measures during construction
Based on the outcomes in Table 6-4 above, the need for management of nuisance dust during construction
was determined. Consistent with the Publication 1834.2, the GED and other relevant guidance, the following
measures are recommended for inclusion in the Construction Environmental Management Plan (CEMP):
 Watering of exposed and disturbed areas. This will minimise the level of dust generated from Project
exposed and disturbed areas, such that associated residual impacts would be minimised.
 Modifying the intensity of activities based on observed dust levels and local meteorological conditions.
This would identify adverse ambient air quality and meteorological conditions so that activities can be
scaled back or suspended accordingly (i.e., avoid or minimise). This would reduce the potential for any
residual impacts when ambient conditions are already degraded.
 Covering of loads and removing loose materials/debris before vehicles exit the site. This would minimise
dust associated with the transport of construction materials.
 Minimising the extent of disturbed and exposed areas and stockpiles. This would limit dust arising from
wind erosion.
 Covering or stabilising long-term stockpiles. Again, this would limit the extent of dust resulting from wind
erosion effects at these areas.
 Positioning any dusty activities such as concrete batching and materials stockpiles as far as practicable
from surrounding receptors to minimise the potential for impacts.
 Identifying appropriate site speed limits. Dust generated from traffic traveling along unsealed roads is
less at lower speeds, minimising the potential for impacts.
 Revegetating or sealing finished areas as soon as possible. Revegetated and sealed areas are less
susceptible to wind erosion, minimising the potential for impacts.
 Maintain minimum setback distances of at least 100m to sensitive receptors from temporary concrete
batch plants consistent with guidance presented in EPA’s ‘Publication 1949: Separation distance
guidelines’ (EPA, 2024) (if required). This will minimise the potential for impacts from emissions to air
arising from concrete batching activities
 Regular review of controls so that they remain suitable.
6.1.2 Other air quality impacts during construction
As noted in Section 2.4, other potential emissions to air during construction identified included exhaust
emissions from the combustion of fossil fuels in construction plant and equipment, odours and airborne
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hazardous materials arising from uncovered contaminated materials. Based on the assessment ratings
developed in Table 4-3 it was determined that unmitigated impacts at surrounding sensitive receptors from
both these sources would be ‘low’. This determination was made based on the low likelihood of these types
of emissions to air being generated to an extent that any impacts would be expected. With the application of
the appropriate control measures detailed above and below via the CEMP, it is expected that residual impacts
associated with these types of emissions during construction would be ‘negligible’:
 Conducting routine servicing and maintenance of equipment. This will make sure that they continue
operating in a proper and efficient manner. This is expected to reduce (i.e., minimise) emissions from
abnormal operations.
 Switching off all vehicles, plant and equipment when not in-use for extended periods. This avoids
unnecessary exhaust-related emissions by removing the emissions source.
 Applying odour supressing agents to materials as necessary should any contaminated or hazardous
materials be uncovered during the works, to mitigated and associated effects.
 Adhering to relevant requirements for removal and disposal of contaminated and hazardous materials
listed in the applicable health and safety legislature and regulations so that any emissions are avoided or
otherwise minimised, and effects are effectively mitigated.
6.2 Operations
This section presents and discusses the outcomes of the operational air quality assessments completed for
the Project. The results presented were determined quantitatively using the EPA-approved AERMOD
dispersion model as described above in Section 4.2.2. Results are presented by pollutant in the subsections
below as follows:
 Nitrogen dioxide (NO ), Section 6.2.1
2
 Carbon monoxide (CO), Section 6.2.2
 Particulate matter as PM , Section 6.2.3
2.5
 VOCs, Section 6.2.4.
Results are presented in tabulated form at the surrounding representative receptor locations identified in
Section 5.1. Ground-level concentration contour plots are also provided for selected results in Appendix D.
6.2.1 Nitrogen dioxide (NO )
2
1-hour averaged 99.9th percentile cumulative ground level concentrations of NO predicted at the nearest
2
sensitive receptors (i.e., those identified in Section 5.1) around the Project site are summarised below in
Table 6-5. These results represent the total contribution from the Project, as well as existing background
concentrations, with the OLM method applied to convert NO to NO as outlined in Section 4.2.2. The results
x 2
in Table 6-5 are highly conservative, noting that:
 Scenarios would only occur for a small number of hours each year, however impacts were assessed for all
hours. This has been done to determine the potential maximum (in this case 99.9th percentile) impacts
but it assumes a reasonably worst-case combination of meteorological and background conditions
occurring concurrent with these short-term and in the case of scenarios 2 and 3, very infrequent and
unlikely operations.
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Table 6-5. 1-hour averaged 99.9th percentile NO results, Brooklyn
2
Sensitive Predicted NO cumulative concentrations (µg/m3) Air
2
receptor quality
Scenario 1: Routine testing Scenario 2:56 units operating Scenario 3: 112 units
objective
and maintenance (emergency, partial power operating (emergency, full
(µg/m3)
outage) power outage)
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0202 1202 2202 3202 4202 0202 1202 2202 3202 4202 0202 1202 2202 3202 4202
1 92 73 70 65 62 690 682 695 605 644 833 828 843 790 801 150
2 92 73 69 65 62 575 597 598 561 558 784 781 816 757 767
3 93 73 68 66 62 561 577 590 576 576 863 917 909 890 919
4 96 75 69 71 63 483 476 470 487 468 938 932 912 946 921
5 98 75 70 68 68 473 453 458 465 462 884 859 879 866 858
6 92 76 75 73 72 541 537 572 559 572 761 734 762 740 740
7 92 75 70 66 64 421 416 426 400 408 699 710 659 694 697
8 94 73 67 66 62 192 179 197 197 197 355 349 359 373 369
9 92 73 67 66 62 157 130 165 145 153 285 235 283 256 267
As Table 6-5 shows, during routine generator testing (scenario 1), 99.9th cumulative 1-hour averaged NO
2
concentrations were predicted to remain below the 150 µg/m3 air quality objective value.
Exceedances were predicted for scenarios 2 and 3, noting the conservative assumptions outlined above. Still,
consistent with the intent of the GED, namely to “minimise risks as far as reasonably practicable” even when
the frequency of such risks is very low, the efficacy of different options were reviewed to reduce resulting
concentrations at surrounding sensitive receptors during emergency operations:
 Exhaust stack adjustments: Exhaust heights are set as part of the overall design, but there could be some
flexibility insofar as the exhaust diameter to increase exit velocities. The worst-case combination (i.e.,
scenario 3, 2023 meteorology and background conditions) was re-run with a smaller diameter (reduced
from 0.8 to 0.7), increasing the stack velocity from around 23 to 31 m/s. It is noted that AERMOD does
not consider enhanced buoyancy of multiple plumes which may under-estimate the effectiveness of this
option. This option achieved a reduction in GLC at the most affected sensitive receptor of around 4%
(approximately 38 µg/m3). it was determined that this approach would only be effective in conjunction
with other controls, and was not explicitly recommended.
 Generator control approaches: Various potential control options for the proposed generator units exist
including derating (i.e., reducing output), temperature adjustments, use of fuel additives, engine
modifications such as exhaust gas recirculation (EGS), and other reduction technologies like selective
catalytic reduction (SCR). Table 7 of ‘National Pollutant Inventory Emission Estimation Technique Manual
for Combustion Engines (Version 3.0)’, (Department of the Environment, Water, Heritage and the Arts
[DEWHA], 2008) provides guidance regarding the efficacy of NO reduction control approaches for large
x
diesel engines.
Cumulative 99.9thpercentile, 1-hour averaged NO ground level concentrations at the most-affected
2
sensitive receptor for scenario 3 with 2023 meteorology based on the application of different control
approaches are summarised below in Table 6-6. The 50% and 90% control options are based on
guidance from DEWHA, 2008 with the application of EGR and SCR respectively.
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Table 6-6. Brooklyn site NO GED controls review
x
Control option Cumulative 99.9th percentile 1-hour Air quality
averaged NO concentration at most- objective
2
affected representative receptor (µg/m3) (µg/m3)
50% reduction in NO emissions (e.g., EGR) 456 150
x
90% reduction in NO emissions (e.g., SCR) 91
x
Technologies like SCR are more effective in generator units that are operated continuously which would not
be the case for the Project. Noting the very low expected frequency and short-term nature of scenario 2 and 3
emergency use events, these controls have been reviewed consistent with the GED, but are not explicitly
recommended.
6.2.2 Carbon monoxide (CO)
Rolling 8-hour averaged 100th percentile cumulative ground level CO concentrations determined at the
nearest sensitive receptors around the Project are listed in Table 6-7 .
Table 6-7. Rolling 8-hour averaged 100th percentile CO results, Brooklyn
Sensitive Predicted CO cumulative concentrations (mg/m3) Air
receptor quality
Scenario 1: Routine testing Scenario 2:56 units operating Scenario 3: 112 units
objective
and maintenance (emergency, partial power operating (emergency, full
(mg/m3)
outage) power outage)
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0202 1202 2202 3202 4202 0202 1202 2202 3202 4202 0202 1202 2202 3202 4202
1 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.0 0.8 1.3 3.1 1.4 1.1 0.9 1.6 10.3
2 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.1 0.9 1.2 3.1 1.4 1.2 1.1 1.3
3 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.2 0.9 1.2 3.1 1.4 1.3 1.2 1.2
4 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.1 0.9 1.2 3.1 1.4 1.1 1.0 1.2
5 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.0 0.9 1.2 3.1 1.4 1.0 0.9 1.2
6 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.0 0.8 1.2 3.1 1.5 1.0 0.8 1.2
7 3.1 1.4 1.0 0.8 1.2 3.1 1.5 1.0 0.8 1.2 3.1 1.5 1.0 0.8 1.3
8 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.0 0.8 1.3
9 3.1 1.4 1.0 0.8 1.2 3.1 1.4 1.0 0.9 1.3 3.1 1.4 1.0 0.9 1.3
As Table 6-7 shows, cumulative CO concentrations were determined to remain below the rolling 8-hour
99.9th percentile ERS air quality objective at the nearest most-affected sensitive receptors around the Project
sites during routine testing and maintenance, as well as during emergency operations.
6.2.3 Particulate matter
Cumulative 100th percentile 24-hour averaged ground level PM concentrations determined at the nearest
2.5
sensitive receptors around Brooklyn are listed below in Table 6-8. In addition to the factors of conservatism
described for the NO modelling, the result also assumes operation for a full 24 hours. In reality routine
x
testing and maintenance events would be in the order of several hours.
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Air Quality and Plume Rise Assessment Report
Table 6-8. 24-hour averaged 100th percentile PM results, Brooklyn
2.5
Sensitive Predicted PM cumulative concentrations (µg/m3) Air
2.5
receptor quality
Scenario 1: Routine testing Scenario 2:56 units operating Scenario 3: 112 units
objective
and maintenance (emergency, partial power operating (emergency, full
(µg/m3)
outage) power outage)
IA335900-JAC-BDC-AI-RPT-001 37
0202 1202 2202 3202 4202 0202 1202 2202 3202 4202 0202 1202 2202 3202 4202
1 200 33 23 23 29 213 44 50 39 47 230 74 79 61 89 25
2 200 33 23 23 29 202 42 44 43 41 214 64 74 67 70
3 200 33 23 23 29 201 47 48 54 47 204 68 73 81 63
4 200 33 23 23 29 207 49 36 41 42 217 94 74 82 81
5 200 33 23 23 29 204 38 32 31 49 207 50 54 52 74
6 200 33 23 23 29 206 34 35 32 37 212 46 56 57 45
7 200 33 23 23 29 202 34 24 23 31 205 36 36 31 39
8 200 33 23 23 29 202 34 24 23 31 203 34 24 23 33
9 200 33 23 23 29 201 34 24 23 33 202 34 25 24 37
As displayed in Table 6-8, during routine generator testing (scenario 1), maximum cumulative 24-hour
averaged PM concentrations were predicted to be exceed the 25 µg/m3 air quality objective value for
2.5
background and meteorological conditions in 2020, 2021 and 2024. As outlined in Section 5.3.4, there were
several days in these years where existing background levels were measured above 25 µg/m3. The
assessment approach is conservative whereby worst-case background air quality and meteorological
conditions have been applied at the time of testing. Again, in reality, testing would occur monthly with each
event being completed over the course of several hours. For the three years where exceedances were
predicted, additional analysis was completed to understand the relative contribution from the Project, and
whether routine generator testing could result in additional instances of the air quality objective value. This
analysis is presented in Table 6-9 below.
Table 6-9. Additional review of 24-hour averaged 100th percentile PM results for scenario 1, Brooklyn
2.5
Year Days with PM Maximum Project Highest 24-hour Will routine
2.5
concentration 24-hour PM concentration testing result in
2.5
above 25 µg/m3 contribution at below criterion additional days of
most-affected (µg/m3) exceedance at a
sensitive receptor surrounding
representative
sensitive receptor?
2020 13 1.5 23.3 No
2021 3 1.6 23.5 Yes, the maximum
Project contribution
would result in an
additional
exceedance. The 2nd
highest contribution
from the Project was
1.4 µg/m3. This
===== PAGE 48 =====
Air Quality and Plume Rise Assessment Report
would not result in
an additional
exceedance.
2024 6 1.7 23.5 Yes, the maximum
Project contribution
would result in an
additional
exceedance. The 2nd
highest contribution
from the Project was
1.3 µg/m3. This
would not result in
an additional
exceedance.
As Table 6-9 shows, even with the conservative assumptions detailed above, it was determined that routine
testing would not result in any additional days of exceedance at any of the identified representative sensitive
receptors. The exceptions were for 2021 and 2024 where a single potential additional exceedance per year
was predicted.
Regarding scenarios 2 and 3 (partial and full power outages) the results in Table 6-8 are also affected by
elevated local background PM concentrations over the period of assessment. Again, the outcomes
2.5
presented are highly conversative, with worst-case background air quality and meteorological conditions
applied at the time that emergency operations would be required, and emissions from these activities
considered for all hours (i.e., in reality, 24-hour concentrations would be lower for events less than 24 hours
duration where the emission rates before and after the event are zero).
As discussed above for NO , noting the very low likelihood of emergency operation events, the limited
2
effectiveness of many control approaches when generators are used in a back-up capacity, and that these
types of such operations may be exempt from requiring a permission, no specific controls are recommended.
6.2.4 VOCs
As identified in Section 2.4 the key speciated VOCs relevant for diesel generators include acetaldehyde,
benzene, formaldehyde, toluene and xylene. A review of the emission rates determined for each species (see
Appendix A) and their applicable APACs from Publication 1961.2 (listed in Table 3-3) identified that
benzene and formaldehyde had the highest emission rate compared with their respective objective values. As
such, these substances identified as the key speciated VOCs, understanding that if compliance for these two
was met, this would also be the case for acetaldehyde, toluene and xylene.
Resulting 99.9th percentile, 1-hour averaged ground level concentrations of benzene and formaldehyde at
the nearest surrounding sensitive receptors were predicted around the Project. The results from this
assessment are summarised as follows in the tables below:
 Benzene, Table 6-10
 Formaldehyde, Table 6-11.
As these tables show, resulting concentrations at sensitive receptors around the site were predicted to remain
below the relevant design criteria from Publication 1961.2 for all three operational assessment scenarios.
IA335900-JAC-BDC-AI-RPT-001 38
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Air Quality and Plume Rise Assessment Report
Table 6-10. 1-hour averaged 99.9th percentile benzene results, Brooklyn
Sensitive Predicted benzene concentrations (µg/m3) Air
receptor quality
Scenario 1: Routine testing Scenario 2:56 units operating Scenario 3: 112 units
objective
and maintenance (emergency, partial power operating (emergency, full
(µg/m3)
outage) power outage)
IA335900-JAC-BDC-AI-RPT-001 39
0202 1202 2202 3202 4202 0202 1202 2202 3202 4202 0202 1202 2202 3202 4202
1 3E-3 2E-3 3E-3 2E-3 3E-3 1E-1 1E-1 1E-1 9E-2 1E-1 1E-1 1E-1 1E-1 1E-1 1E-1 580
2 2E-3 3E-3 3E-3 2E-3 2E-3 9E-2 9E-2 9E-2 9E-2 9E-2 1E-1 1E-1 1E-1 1E-1 1E-1
3 2E-3 3E-3 3E-3 3E-3 3E-3 9E-2 9E-2 9E-2 9E-2 9E-2 1E-1 1E-1 1E-1 1E-1 1E-1
4 4E-3 4E-3 4E-3 4E-3 4E-3 7E-2 7E-2 7E-2 7E-2 7E-2 1E-1 1E-1 1E-1 1E-1 1E-1
5 4E-3 4E-3 4E-3 4E-3 4E-3 7E-2 7E-2 7E-2 7E-2 7E-2 1E-1 1E-1 1E-1 1E-1 1E-1
6 5E-3 5E-3 5E-3 5E-3 5E-3 8E-2 8E-2 9E-2 9E-2 9E-2 1E-1 1E-1 1E-1 1E-1 1E-1
7 4E-3 4E-3 4E-3 4E-3 4E-3 6E-2 6E-2 6E-2 6E-2 6E-2 1E-1 1E-1 1E-1 1E-1 1E-1
8 1E-3 1E-4 1E-3 1E-4 1E-3 3E-2 3E-2 2E-2 3E-2 3E-2 5E-2 5E-2 6E-2 6E-2 6E-2
9 8E-4 6E-4 8E-4 7E-4 7E-4 2E-2 2E-2 2E-2 2E-2 2E-2 4E-2 3E-2 4E-2 4E-2 4E-2
Table 6-11. 30-minute averaged 99.9th percentile formaldehyde results, Brooklyn
Sensitive Predicted formaldehyde concentrations (µg/m3) Air
receptor quality
Scenario 1: Routine testing Scenario 2:56 units operating Scenario 3: 112 units
objective
and maintenance (emergency, partial power operating (emergency, full
(µg/m3)
outage) power outage)
0202 1202 2202 3202 4202 0202 1202 2202 3202 4202 0202 1202 2202 3202 4202
1 3E-4 3E-4 3E-4 3E-4 3E-4 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2 2E-2 1E-2 1E-2 100
2 2E-4 3E-4 3E-4 2E-4 2E-4 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2
3 3E-4 4E-4 4E-4 3E-4 3E-4 1E-2 1E-2 1E-2 1E-2 1E-2 2E-2 2E-2 2E-2 2E-2 2E-2
4 4E-4 4E-4 4E-4 4E-4 4E-4 8E-3 8E-3 8E-3 8E-3 8E-3 2E-2 2E-2 2E-2 2E-2 2E-2
5 5E-4 4E-4 5E-4 5E-4 5E-4 8E-3 8E-3 8E-3 8E-3 8E-3 2E-2 2E-2 2E-2 2E-2 2E-2
6 6E-4 5E-4 6E-4 6E-4 5E-4 1E-2 1E-3 1E-3 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2
7 4E-4 5E-4 5E-4 5E-4 5E-4 7E-3 7E-3 7E-3 7E-3 7E-3 1E-2 1E-2 1E-2 1E-2 1E-2
8 2E-4 1E-4 2E-4 1E-4 2E-4 3E-3 3E-3 3E-3 3E-3 3E-3 6E-3 6E-3 6E-3 6E-3 7E-3
9 9E-5 7E-5 9E-5 8E-5 8E-5 2E-3 2E-3 2E-3 2E-3 2E-3 5E-3 4E-3 5E-3 4E-3 4E-3
===== PAGE 50 =====
Air Quality and Plume Rise Assessment Report
7. Plume rise screening assessment
Results for the back-up diesel generators for 2022 to 2024 meteorology with buoyancy enhancement effects
applied (described above in Section 4.3) for the Project are summarised below in Table 7-1.
Table 7-1: Estimated height above ground level at which plume vertical velocity falls below CASA’s 4.3 m/s
CPV, Brooklyn back-up generators
Percentage exceedance Height at which plume vertical velocity falls Available height (m AGL) for
below 4.3 m/s (m AGL) vertical velocity to fall below
CPV from OLS
2022 2023 2024
0% 38 37 37 123
0.05% 36 36 37
0.10% 36 36 36
0.20% 36 36 36
0.30% 35 35 36
0.50% 35 35 35
1% 34 34 34
2% 34 34 34
3% 33 33 33
4% 33 33 33
5% 33 33 33
6% 33 33 33
7% 33 33 33
8% 33 33 33
9% 33 33 33
10% 33 33 33
20% 32 32 32
30% 32 32 32
40% 32 32 32
50% 32 32 32
60% 32 32 32
70% 32 32 32
80% 32 32 32
90% 31 31 31
100% 31 31 31
As Table 7-1 shows, vertical velocities from the 3 MW back-up generators were predicted to fall below CASA’s
primary and secondary CPVs well below the lowest protected airspace requirements. Still, in-line with step 3
of the plume rise assessment methodology from ‘Advisory Circular AC 139.E-02 V1.0 Plume Rise
Assessments’ (CASA, 2023), a 1247 form (including associated meteorological data) has been submitted to
IA335900-JAC-BDC-AI-RPT-001 40
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Air Quality and Plume Rise Assessment Report
CASA for their review. Other sources not considered in this screening review (e.g., chiller exhaust) were
included in the information supplied to CASA.
IA335900-JAC-BDC-AI-RPT-001 41
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Air Quality and Plume Rise Assessment Report
8. Conclusion
An air quality and plume rise assessment has been completed for a new data centre proposed at Brooklyn,
VIC. The assessment determined the following outcomes and requirements with regard to the three key risks
identified:
 Construction air quality:
- Using the assessment methodology detailed in Publication 1943, ‘medium’ potential unmitigated
nuisance dust impacts were determined for the Brooklyn site.
- Suitable mitigation and management measures were developed in-line with Publication 1834.2, the
GED and other relevant guidance. With these measures, it is expected that nuisance dust would be
able to be effectively managed such that impacts during construction would be considered very
unlikely.
 Operational air quality:
- For NO and PM , compliance against ERS air quality objective values at surrounding sensitive
x 2.5
receptors (other otherwise no additional potential instances of exceedances when background
conditions were already elevated, except for PM in 2021 and 2024 where one potential additional
2.5
day of exceedance was predicted) was generally determined during generator routine testing and
maintenance and emergency operations. Justifiable exceedances were determined during emergency
operations. It is noted that emissions to air from these types of operations may be exempt, but there
is still the need to review potential controls to minimise impacts consistent with the requirements of
the GED. Such controls were reviewed, although it was determined that they would be unlikely to
meet the threshold as being reasonable and feasible, noting the expected frequency of these events
would be extremely low, and that the efficacy of such controls are limited for generators that are
used in a back-up capacity.
- For all operational scenarios (i.e., routine testing and maintenance and emergency operations)
compliance was determined against relevant ERS and Publication 1961.2 air quality objective values
at surrounding sensitive receptors for CO and speciated VOCs.
 Operational plume rise:
- A plume rise screening assessment was completed using TAPM. Results were evaluated against the
most stringent 4.3 m/s CPV at the lower (i.e., most conservative) prescribed airspace layer at the
nearest Certified Aerodrome.
- Using this approach, it was determined that the vertical velocities from the back-up generators would
fall below CASA’s 4.3 m/s CPV well below the lowest protected airspace requirements relevant at the
site. Consistent with ‘Advisory Circular AC 139.E-02 V1.0 Plume Rise Assessments’ (CASA, 2023), a
1247 form (including associated meteorological data) has been submitted to CASA for their review.
IA335900-JAC-BDC-AI-RPT-001 42
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Air Quality and Plume Rise Assessment Report
9. References
 Caterpillar, 2025. ‘Performance Data[EM1366] Change Level:08’
 Civil Aviation Safety Authority, 2003. ‘CAAP 89Z-1(0) Guidelines for plume rise assessments’
 Civil Aviation Safety Authority, 2023. ‘Advisory Circular AC 139.E-02 V1.0 Plume Rise Assessments’
 Department of the Environment, Water, Heritage and the Arts, 2008. ‘National Pollutant Inventory
Emission Estimation Technique Manual for Combustion Engines (Version 3.0)’
 Essendon Airport Pty Ltd, 2014. ‘Essendon Airport Master Plan 2013’
 United States Environment Protection Authority, 2005. ‘Conversion Factors for Hydrocarbon Emission
Components, EPAA420-R-05-015 NR-002c’
 Victorian Environment Protection Authority, 2019a. ‘Publication 1730 Solid storage and handling
guidelines’
 Victorian Environment Protection Authority, 2019b. ‘Publication 1895 Managing stockpiles: guidance
sheet’
 Victorian Environment Protection Authority, 2020a. ‘Publication 1894 Managing soil disturbance:
guidance sheet’
 Victorian Environment Protection Authority, 2020b. ‘Publication 1897 Managing truck and other vehicle
movement: guidance sheet’
 Victorian Environment Protection Authority, 2023. ‘Publication 1957 Guide to air pollution modelling’
 Victorian Environment Protection Authority, 2025a. ‘Publication 1961.2 Guideline for assessing and
minimising air pollution in Victoria’
 Victorian Environment Protection Authority, 2025b. ‘Publication 1943 Guidance for assessing nuisance
dust’
 Victorian Environment Protection Authority, 2025c. ‘Publication 1834.2 ‘Civil construction, building and
demolition guide’
IA335900-JAC-BDC-AI-RPT-001 43
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Air Quality and Plume Rise Assessment Report
Appendix A. Generator stack inputs
Brooklyn generators geometric, exit velocity and exit temperature inputs
Stack ID Stack co-ordinates (MGA UTM Stack Stack Base Exit Exit temp
Zone 55 m) height diameter elevation velocity (C)
(m AGL) (m) (m AHD) (m/s)
X co-ordinate Y co-
ordinate
G1A 310905.40 5811978.03 25.5 0.8 21.9 23.4 460.7
G1B 310905.88 5811980.63 25.5 0.8 21.9 23.4 460.7
G2A 310905.93 5811982.45 25.5 0.8 21.9 23.4 460.7
G2B 310906.41 5811985.19 25.5 0.8 21.9 23.4 460.7
G3A 310907.47 5811994.89 25.5 0.8 21.9 23.4 460.7
G3B 310908.00 5811997.77 25.5 0.8 21.9 23.4 460.7
G4A 310908.24 5811999.02 25.5 0.8 21.9 23.4 460.7
G4B 310908.57 5812002.24 25.5 0.8 21.9 23.4 460.7
G5A 310909.74 5812011.63 25.5 0.8 21.9 23.4 460.7
G5B 310910.42 5812014.61 25.5 0.8 21.9 23.4 460.7
G6A 310910.18 5812016.04 25.5 0.8 21.9 23.4 460.7
G6B 310910.87 5812019.03 25.5 0.8 21.9 23.4 460.7
G7A 310903.80 5811969.52 25.5 0.8 21.9 23.4 460.7
G7B 310904.28 5811972.49 25.5 0.8 21.9 23.4 460.7
G8A 310914.00 5812036.95 25.5 0.8 21.9 23.4 460.7
G8B 310914.57 5812039.76 25.5 0.8 21.9 23.4 460.7
G9A 310914.68 5812041.36 25.5 0.8 21.9 23.4 460.7
G9B 310915.18 5812044.53 25.5 0.8 21.9 23.4 460.7
G10A 310916.24 5812053.69 25.5 0.8 21.9 23.4 460.7
G10B 310916.70 5812057.03 25.5 0.8 21.9 23.4 460.7
G11A 310916.93 5812058.21 25.5 0.8 21.9 23.4 460.7
G11B 310917.54 5812061.38 25.5 0.8 21.9 23.4 460.7
G12A 310918.91 5812070.43 25.5 0.8 21.9 23.4 460.7
G12B 310919.57 5812073.53 25.5 0.8 21.9 23.4 460.7
G13A 310919.72 5812075.03 25.5 0.8 21.9 23.4 460.7
G13B 310920.37 5812077.87 25.5 0.8 21.9 23.4 460.7
G14A 310921.01 5812083.47 25.5 0.8 21.9 23.4 460.7
G14B 310921.51 5812086.60 25.5 0.8 21.9 23.4 460.7
G15A 310928.59 5812135.76 25.5 0.8 20.1 23.4 460.7
G15B 310929.23 5812138.88 25.5 0.8 20.1 23.4 460.7
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Air Quality and Plume Rise Assessment Report
G16A 310929.88 5812144.12 25.5 0.8 20.1 23.4 460.7
G16B 310930.55 5812147.24 25.5 0.8 20.1 23.4 460.7
G17A 310930.66 5812148.73 25.5 0.8 20.1 23.4 460.7
G17B 310931.19 5812151.70 25.5 0.8 20.1 23.4 460.7
G18A 310932.41 5812161.10 25.5 0.8 20.1 23.4 460.7
G18B 310932.97 5812164.18 25.5 0.8 20.1 23.4 460.7
G19A 310933.16 5812165.35 25.5 0.8 20.1 23.4 460.7
G19B 310933.59 5812168.59 25.5 0.8 20.1 23.4 460.7
G20A 310934.91 5812177.84 25.5 0.8 20.1 23.4 460.7
G20B 310935.41 5812180.83 25.5 0.8 20.1 23.4 460.7
G21A 310935.83 5812182.44 25.5 0.8 20.1 23.4 460.7
G21B 310936.24 5812185.26 25.5 0.8 20.1 23.4 460.7
G22A 310938.82 5812203.22 25.5 0.8 20.1 23.4 460.7
G22B 310939.37 5812206.29 25.5 0.8 20.1 23.4 460.7
G23A 310939.31 5812207.62 25.5 0.8 20.1 23.4 460.7
G23B 310939.82 5812210.84 25.5 0.8 20.1 23.4 460.7
G24A 310941.22 5812220.01 25.5 0.8 20.1 23.4 460.7
G24B 310941.88 5812223.11 25.5 0.8 20.1 23.4 460.7
G25A 310941.97 5812224.75 25.5 0.8 20.1 23.4 460.7
G25B 310942.25 5812227.75 25.5 0.8 20.1 23.4 460.7
G26A 310943.64 5812236.91 25.5 0.8 20.1 23.4 460.7
G26B 310944.30 5812239.77 25.5 0.8 20.1 23.4 460.7
G27A 310944.51 5812241.38 25.5 0.8 20.1 23.4 460.7
G27B 310945.07 5812244.35 25.5 0.8 20.1 23.4 460.7
G28A 310945.67 5812249.87 25.5 0.8 20.1 23.4 460.7
G28B 310946.15 5812252.75 25.5 0.8 20.1 23.4 460.7
G29A 311067.24 5811945.70 25.5 0.8 21.9 23.4 460.7
G29B 311067.59 5811947.85 25.5 0.8 21.9 23.4 460.7
G30A 311068.56 5811954.14 25.5 0.8 21.9 23.4 460.7
G30B 311068.76 5811956.12 25.5 0.8 21.9 23.4 460.7
G31A 311069.04 5811958.68 25.5 0.8 21.9 23.4 460.7
G31B 311069.46 5811960.68 25.5 0.8 21.9 23.4 460.7
G32A 311071.09 5811970.94 25.5 0.8 21.9 23.4 460.7
G32B 311071.40 5811973.23 25.5 0.8 21.9 23.4 460.7
G33A 311071.66 5811975.36 25.5 0.8 21.9 23.4 460.7
G33B 311072.12 5811977.73 25.5 0.8 21.9 23.4 460.7
G34A 311073.34 5811987.40 25.5 0.8 21.9 23.4 460.7
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Air Quality and Plume Rise Assessment Report
G34B 311073.80 5811990.26 25.5 0.8 21.9 23.4 460.7
G35A 311074.12 5811991.91 25.5 0.8 21.9 23.4 460.7
G35B 311074.47 5811994.67 25.5 0.8 21.9 23.4 460.7
G36A 311077.33 5812012.84 25.5 0.8 21.9 23.4 460.7
G36B 311077.63 5812015.38 25.5 0.8 21.9 23.4 460.7
G37A 311077.94 5812017.63 25.5 0.8 21.9 23.4 460.7
G37B 311078.19 5812019.97 25.5 0.8 21.9 23.4 460.7
G38A 311080.06 5812029.55 25.5 0.8 21.9 23.4 460.7
G38B 311080.29 5812032.47 25.5 0.8 21.9 23.4 460.7
G39A 311080.52 5812033.96 25.5 0.8 21.9 23.4 460.7
G39B 311080.82 5812036.85 25.5 0.8 21.9 23.4 460.7
G40A 311082.46 5812046.42 25.5 0.8 21.9 23.4 460.7
G40B 311082.72 5812049.08 25.5 0.8 21.9 23.4 460.7
G41A 311082.98 5812051.08 25.5 0.8 21.9 23.4 460.7
G41B 311083.30 5812053.68 25.5 0.8 21.9 23.4 460.7
G42A 311084.26 5812059.15 25.5 0.8 21.9 23.4 460.7
G42B 311084.58 5812062.00 25.5 0.8 21.9 23.4 460.7
G43A 311092.07 5812111.69 25.5 0.8 20.4 23.4 460.7
G43B 311092.42 5812114.55 25.5 0.8 20.1 23.4 460.7
G44A 311093.29 5812120.07 25.5 0.8 20.1 23.4 460.7
G44B 311093.66 5812122.90 25.5 0.8 20.1 23.4 460.7
G45A 311094.03 5812124.50 25.5 0.8 20.1 23.4 460.7
G45B 311094.22 5812127.29 25.5 0.8 20.1 23.4 460.7
G46A 311095.89 5812136.48 25.5 0.8 20.1 23.4 460.7
G46B 311096.15 5812139.82 25.5 0.8 20.1 23.4 460.7
G47A 311096.43 5812141.21 25.5 0.8 20.1 23.4 460.7
G47B 311096.84 5812144.15 25.5 0.8 20.1 23.4 460.7
G48A 311098.37 5812153.47 25.5 0.8 20.1 23.4 460.7
G48B 311098.66 5812156.50 25.5 0.8 20.1 23.4 460.7
G49A 311098.99 5812158.25 25.5 0.8 20.1 23.4 460.7
G49B 311099.25 5812161.02 25.5 0.8 20.1 23.4 460.7
G50A 311102.12 5812179.08 25.5 0.8 20.1 23.4 460.7
G50B 311102.31 5812181.84 25.5 0.8 20.1 23.4 460.7
G51A 311102.75 5812183.62 25.5 0.8 20.1 23.4 460.7
G51B 311102.88 5812186.31 25.5 0.8 20.1 23.4 460.7
G52A 311104.54 5812195.92 25.5 0.8 20.1 23.4 460.7
G52B 311104.72 5812198.58 25.5 0.8 20.1 23.4 460.7
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G53A 311105.33 5812200.43 25.5 0.8 20.1 23.4 460.7
G53B 311105.42 5812203.09 25.5 0.8 20.1 23.4 460.7
G54A 311107.23 5812212.69 25.5 0.8 20.1 23.4 460.7
G54B 311107.28 5812215.43 25.5 0.8 20.1 23.4 460.7
G55A 311107.57 5812217.36 25.5 0.8 20.1 23.4 460.7
G55B 311107.63 5812219.75 25.5 0.8 20.1 23.4 460.7
G56A 311108.91 5812225.48 25.5 0.8 20.1 23.4 460.7
G56B 311109.19 5812228.31 25.5 0.8 20.1 23.4 460.7
Stack emission rates (Source: Caterpillar, 2025)
Pollutant Emission rate (g/s) Emission rate Emission rate (g/s)
PM 0.13 NO as NO 6.3
x 2
PM 0.13 CO 0.68
10
PM * 0.127 Hydrocarbons 0.015
2.5
* PM2.5emission rate derived from the ratio of PM10 to PM2.5emission rates (around 1 : 0.976) for large (>450 kW) diesel engines from
Table 43 of ‘National Pollutant Inventory Emission Estimation Technique Manual for Combustion Engines (Version 3.0)’, (Department of
the Environment, Water, Heritage and the Arts [DEWHA], 2008)
Speciated VOC estimated emission rates
Pollutant Ratio to VOCs Emission rate (g/s)
Hydrocarbons 1 : 1.053* 0.015
Total VOCs 1 : 1 0.016
Acetaldehyde 0.00032 : 1# 4.98E-06
Benzene 0.01 : 1# 1.58E-04
Formaldehyde 0.001 : 1# 1.58E-05
Toluene 0.00354 : 1# 5.59E-05
Xylene 0.00246 : 1# 3.89E-05
* Total hydrocarbons to total VOCs ratio adopted from ‘Conversion Factors for Hydrocarbon Emission Components, EPAA420-R-05-015
NR-002c’, (United States Environment Protection Authority, 2005)
# Speciated VOCemission rates derived from the ratio of speciated VOC to Total VOCemission rates for large (>450 kW) diesel engines
from Table 43 of ‘National Pollutant Inventory Emission Estimation Technique Manual for Combustion Engines (Version 3.0)’,
(Department of the Environment, Water, Heritage and the Arts, 2008)
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Appendix B. AERMET annual and seasonal wind roses
2024
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2023
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2022
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2021
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2020
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Appendix C. Nuisance dust assessment Publication 1943 guidance
Step 1 Source hazard potential
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Step 2 Exposure pathway effectiveness
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Step 3 Receiving environment sensitivity
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Appendix D. Selected operational ground-level concentration
plots
99.9th percentile, 1-hour averaged cumulative NO (µg/m3) for scenario 1 (routine testing and
2
maintenance) for 2024 year of assessment
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99.9th percentile, 1-hour averaged cumulative NO (µg/m3) for scenario 3 (full outage) for 2024 year of
2
assessment
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100th percentile, 24-hour averaged PM (µg/m3) contribution for scenario 1 (routine testing and
2.5
maintenance) for 2024 year of assessment
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100th percentile, 24-hour averaged PM (µg/m3) contribution for scenario 3 (full outage) for 2024 year of
2.5
assessment
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