MCU15/0095 & REC15/0022 PM Submission Object- Linda Suter

constituent     of Motor Spirit    we have provided elsewhere in this document                  that clearly shows the
is 1% v/v as legislated in         adverse impacts of emissions and the danger to children from being in
Australia. This is a minor         close proximity    to a service station.
fraction of total chemical
compounds       in Motor Spirit.   The setback distances proposed in this development                 do not come close
With the advent of modern          to meeting best practice either in Australia or overseas.
VR1 systems and fibreglass
underground       tanks the        In Queensland,      the health risk from benzene (and other pollutants)                  is
vapour fraction escaping to        recognized in the Environmental          Protection     (Air) Policy 2008 (EPP). THE
the environment       has          EPP sets exposure         limits   in air to ensure protection         of human       and
reduced to extremely         low   environmental       health    from    those    pollutants.    The EPP objective       for
levels that poses no               benzene is a maximum concentration               of 3 ppb (parts per billion) over a
detrimental     health impacts     1-year period.
to those living in close
proximity     to Petrol            The Applicant has failed to show by reasonable analysis that the levels
Stations.                          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        This is indeed an indictment         on the whole Development         proposal.
some 46m to the boundary
with the school that backs         The Applicant acknowledges           that the refuelling canopy is a mere 46m
onto the sports hall and           to the boundary with the school that backs onto the sports hall and
swimming. There are no             swimming       complex.
classrooms within at least
100-150m of the petrol             The Applicant further acknowledges that classrooms are within                  100-
station. This separation           150m of the petrol station.
distance alone is more than
sufficient to neutralise /         The Applicant then makes yet another idle assertion without                 any
dilute any minor trace             objective evidence or scientific analysis; without            measurement     or date;
benzene particulates        to     without   evidence of the qualifications,        expertise or experience of the
such a degree and to be            person making the assertion; that "This separation distance alone is
undetectable.                      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.




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