This letter is addressed to anyone who is considering buying a block of land in, or lives or works in proximity to, the Iluka subdivision known as "Birrigan".
In addition to the biodiversity richness of this 20 hectares abutting the World Heritage Littoral Rainforest, and it forming an intrinsic wildlife corridor from the World Heritage area to Bundjalung National Park, the site possesses a past and a future, both of which need to be considered carefully.
Put simply BUYER BEWARE!
The site was sandmined in the early 70s. Note "Old mineral sandmining sites can sometimes emit low levels of radiation ioncompatible with full time occupation of a site." (Guidance and Licensing of Mineral Sand Mining that Generates Radioactive residues" June 2009) (North Coast Voices 2016).
When the site was rezoned from recreational to residential use, Clarence Valley Council recorded that there was ".....insufficient evidence to determine whether the land is contaminated". However, a thorough search of Clarence Valley Council records reveals NO attempt by CVC to test this land to determine, if indeed, it is contaminated by radiation.
During the D/A process, due to residents' concerns, and after attempts by the developer to obfuscate the possibility of radiation contamination on site, they eventually enlisted, Earth Systems to conduct radiation testing of the site.
What ensued was a "conventional surface radiation field survey" which, by their own admission, can only "detect radiation to a shallow depth in soil, 300mm or less".(12 inches).
They continue; "However, mineral sand mining, and particularly processing via concentration has the potential to create materials that may be elevated in radiation activity." They quote ARPANSA, the Australian Radiation Protection and Nuclear Safety Agency 2008.
"If this material is buried at depth in the project area, it is LIKELY the field meters used for this survey would NOT pick up sufficient radio nuclide emissions to detect this deeper material." (Earth Systems 2016).
Please note that on the now "Birrigan" land release, mineral sand mining took place to a depth of 3.65m (12 feet) below the ground surface. (Iluka Museum records).
Please note also that the Dept. Environment and Climate Change, in the case of development proposals, themselves recommend depth testing to be conducted. (DECC website).
In spite of conducting only surface radiation testing, admitting to the limits of their methodology, but nevertheless finding 7 logged data points at radiation levels of interest,(0.12 to 0.15 millisieverts), Earth Systems reported that the site is under ARPANSA recommended guideline values for public radiation exposure( 1ms/year), and concluded that development is safe.
We question that conclusion.
In Iluka, "rutile and zircon were targeted in the form of heavy metal concentrate with the magnetic components of ilmenite and a little of the monazite removed and returned to the tailings". (Iluka museum records)
The processing of mineral sands for ilmenite and rutile is known to produce thorium and uranium, which produce gamma radiation, the most dangerous form of radiation. They both give off radon gas, which in turn releases radioactive particles when it decays, causing damage to lung tissue, which can lead to lung cancer (https://www.resourcesandgeoscience.nsw.gov.au/)
Radon is recognised as second only to cigarette smoking in causing lung cancer in U.S.A. (MSKCC.org)
Because it is a gas, once disturbed by the proposed earthworks, it would rise.
Radon gas is known to accumulate in homes, and although it may take years for problems to appear, when it is inhaled, is when radioactive particles can be trapped in lung tissue.
Radon Gas detection requires a specialised device. Earth Systems merely consulted ARPANSA's Radon Map of Australia, noted that acceptable levels of radon gas are detected in Iluka generally, but did NOT undertake any additional Radon Gas monitoring on site.
Due to concerns raised by residents, the body given responsibility of development consent, the Northern Joint Regional Planning Panel, made a condition of consent that a "peer review" of Earth Systems' radiation contamination testing be made.
However, instead of accredited site auditors being engaged to independently review the report to ensure consistency with EPA ( Environmental Protection Agency) guidelines, a company in the employ of the developer, Cardno Engineering, were enlisted, and simply quoted verbatim the original report, but note, did include the limitations of only conducting surface radiation testing.
Under Occupational Health and Safety considerations, the proponent claimed that if any sub soil or excavation materials on site were found to be elevated in levels of radioactivity, the materials would be assessed and disposed in accordance with EPA guidelines.
But this begs the question, if the testing for radioactive contamination was supposed to be peer reviewed in accordance with EPA guidelines and wasn't, what confidence should we have that ACTUAL potentially radioactive sub soil and excavation materials would be subject to EPA guidelines?
Who would monitor compliance? The same government department who approved the D/A?
This, in spite of the land being classified as Critical Koala Habitat where sightings of koalas including mother and Joey, 400 plus specimens of the Endangered Ecological Community Coastal Cypress Pine, 8 bird and bat species of Outstanding Universal Value to the World Heritage Rainforest, a stand of the Critically Endangered rainforest tree Scented Achronychia, (75 percent of flora species on site are rainforest species), threatened Squirrel Glider, the stunning black and gold Regent Bowerbird among a suite of over 80 bird species, including two protected under International Migratory Bird Treaty, and myriad other vertebrate species, reptiles and mammals, have been recorded and atlassed!
The site could continue to genetically and spatially augment the Critically Endangered Littoral Rainforest within the World Heritage area, and given the intense pressure that human activity and Climate Change is exerting on wildlife and rainforest in Australia and worldwide, this would be more than desirable.
Climate Change is the present and the future.
In this light please now consider the following "Buyer Beware" points.
Iluka Road is vulnerable to tidal inundation. It currently gets inundated by the North Arm of the Clarence River at Freshwater, near the Esk Bridge, when there is heavy rain, and effects are amplified if the rain event coincides with high tides.
Predictions are for East Coast Lows to decrease, but to increase in intensity as the climate warms, causing more cyclonic like weather.(coastadapt.com.au)
SES and insurance companies are planning for this to happen, and calculating premiums around this.
The coastadapt website used by government departments and insurance companies to predict sea level rise, predicts that the Clarence River will see a sea rise of 14 to 15 cm. By 2030.
It predicts that in estuaries this will lead to " reduced drainage and prolonged inundation of low lying coastal areas."
This will see Iluka Rd. inundated more often or even permanently.
Insurance costs in flood inundated areas are predicted to rise as this happens.
A La Nina summer in 20/21 may give us some idea.
Because of this climate modelling, the Local Government Association recommends NO development in Category 2 Coastal Areas. ( This category being not immediately on the seashore). The Iluka development falls into Category 2.
Bushfire Considerations
Iluka is in a designated Bushfire Zone.(RFS N.S.W.
Bushfire Prone Land). This was adopted on March 1st 2020.
This means that House and Contents Insurance costs will rise, if they haven't already.
The cost of building has also risen due to compliance requirements.(google AS 2959 requirements for 2020.)
In conclusion, while the letter writers respectfully acknowledge the land owners, Birrigangargle Land Council, and recognise their social, economic and housing needs, and rights, which they seek to fulfil in part through sale of this land, we ask, at what cost?
Thank you,
Sincerely, L.Hally and G.Barto, Iluka residents.
