Jen Drysdale submission 17 Dec 15

precautionary principle and consider the possible risks to make a decision that is not in any way 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. Neither has satisfied that burden of proof.

Emissions from petrol stations are widely acknowledged to contain compounds harmful to health,
including, toluene, xylenes; and benzene which is a known health risk and carcinogen. Exposure to
emissions from petrol stations has been shown to be associated with increased risks of childhood

leukaemia, independent of other risk factors.°

A Spanish study published in the US Journal of Environmental Management in December 2010’ shows
that emissions from evaporated petrol or fuel, generally when petrol is being transferred or has been
spilt, contaminates the surrounding area with volatile materials, including the carcinogen benzene. This
means that the atmosphere in the immediate vicinity of service stations can be contaminated up to 50
metres away. The study recommends that a minimum distance of 50 metres should be maintained
between petrol stations and housing, and 100 metres for "especially vulnerable" facilities such as
hospitals, health centres, schools and old people's homes.

In 2014, Dr lan Francis Musgrave , Lecturer in Pharmacology, University of Adelaide, referred to the
Spanish Study stating that the radius of significant levels of hydrocarbons of concern was of the order of
approximately 75m from the station. For example the levels of benzene at 75 meters were 4 pg/m3,
which is 25% of the EPA yearly exposure limit of 16 ug/m?.

Professor Lidia Morawska at QUT has been conducting studies in Brisbane into the health effects of
exposure of children to airborne nano and ultrafine particles (UFP) emitted from motor vehicles. Owing
to their small size, UFPs are able to penetrate deep into the lungs, where they may cause adverse
respiratory, pulmonary and cardiovascular health effects. Her studies show that the impact is significant
and visible. In addition to the emissions from vehicles in the service station, the proposed Development
will generate more traffic in and around the School. These emission sources are in such close proximity
to the school that they pose and unacceptable increased health risk to this vulnerable population group
of school students.

The Western Australian Environmental Protection Authority (WAEPA) in its policy document, Guideline
for the Assessment of Environmental Factors, recommended separation distances for Industrial Residual
Air Emissions of 200 meters between a service station operating 24 hours a day and a school.
“Separation distance” is defined to be the shortest distance between the boundary of the service station
and the School.

The subject Property directly adjoins the School’s 14m toddler outdoor pool and the 25m outdoor pool
used by all age groups. The fuel bowsers on the proposed development are dangerously close to the
Pool facilities being no more than an estimated 30 meters from the outdoor toddler pool. The pool
facilities, apart from constant school use, are utilised all year round by the School’s associated Swim

° see e.g. C Steffen et al 2004 — “Acute childhood leukaemia and environmental exposure to potential sources of
benzene and other hydrocarbons; a case-control study” and many other similar studies showing adverse effects
particularly on young growing bodies.

’ Terrés et al