MCU15/0095 & REC15/0022 PM Submission Object - Jenelle Wilson

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.
VRI 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    I-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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