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

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     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 Spiril.   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 reasonabie 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-lS0m      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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