MCU15/0095 & REC15/0022 PM Submission Object - Petition

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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 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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