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Jen Drysdale submission 17 Dec 15
Attached to the e-mail MCU15/0095 & REC15/0022 PM Submission Object - Jennifer Drysdale.
constituent of Motor Spirit is 1% v/v as legislated in Australia. This is a minor fraction of total chemical compounds in Motor Spirit. With the advent of modern VR1 systems and fibreglass underground tanks the vapour fraction escaping to the environment has reduced to extremely low levels that poses no detrimental health impacts to those living in close proximity to Petrol Stations. we have provided elsewhere in this document that clearly shows the adverse impacts of emissions and the danger to children from being in close proximity to a service station. The setback distances proposed in this development do not come close to meeting best practice either in Australia or overseas. In Queensland, the health risk from benzene (and other pollutants) is recognized in the Environmental Protection (Air) Policy 2008 (EPP). THE EPP sets exposure limits in air to ensure protection of human and environmental health from those pollutants. The EPP objective for benzene is a maximum concentration of 3 ppb (parts per billion) over a 1-year period. The Applicant has failed to show by reasonable analysis that the levels of exposure, particularly to young children in the adjacent School, will not harm their health. The Precautionary Principle demands that, particularly in relation to young children, we address possible risks where scientific understanding is yet incomplete in a way that is not harmful. In the absence of scientific consensus that the Development is not harmful, the burden of proof that it is not harmful falls on the Developer and the Property Owner. 2. The refuelling canopy is some 46m to the boundary with the school that backs onto the sports hall and swimming. There are no classrooms within at least 100-150m of the petrol station. This separation distance alone is more than sufficient to neutralise / dilute any minor trace benzene particulates to such a degree and to be undetectable. This is indeed an indictment on the whole Development proposal. The Applicant acknowledges that the refuelling canopy isa mere 46m to the boundary with the school that backs onto the sports hall and swimming complex. The Applicant further acknowledges that classrooms are within 100- 150m of the petrol station. The Applicant then makes yet another idle assertion without any objective evidence or scientific analysis; without measurement or date; without evidence of the qualifications, expertise or experience of the person making the assertion; that “This separation distance alone is more than sufficient to neutralise / dilute any minor trace benzene particulates to such a degree and to be undetectable.” This assertion is no more than an unsubstantiated opinion and insufficient grounds on which to approve the Development given that the setback distances proposed in this development do not come close to meeting best practice either here, in Australia, or overseas. 25
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