MCU15/0095 & REC15/0022 PM Submission Object - Kass Livesey

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 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    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
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 neutraiise /    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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