MCU15/0095 & REC15/0022 PM Submission Object- Clint Smith

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.
VRl systems and fibreglass
underground tanks the          In Queensland, the heaith 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   l-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
lOO-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.




                                                                                                          25