The Hon Tanya Plibersek MP
Minister for the Environment and Water
Dear Minister Plibersek,
Re: Adelaide Park Lands and City Layout
We write to you on behalf of the Australian Institute of Architects, which represents over 900 members in South Australia and over 13,500 members nationally.
We ask you to take immediate action to protect the Adelaide Park Lands. We believe the various developments proposed by the SA Government will significantly impact the heritage values of the Adelaide Park Lands and City Layout.
Most concerning are the new SA Police Mounted Operations Unit, currently proposed for Park 21 West[1], and the new Women’s and Children’s Hospital to be built on the site of Thebarton Police Barracks.
As noted in the National Heritage Listing for the Adelaide Parklands and City Layout:
“The Adelaide Park Lands and City Layout is rare as the most complete example of nineteenth century colonial planning where planning and survey were undertaken prior to settlement.”
The value of the Park Lands is also noted as a “[reflection of] the early theories and ideas of the Garden City movement of an urban area set in publicly accessible open space with plantings, gardens, designed areas and open bushland.”[2]
On this basis, any developments which alienate areas of the Park Lands that were once publicly accessible, open, and green can be seen as having a significant impact on a National Heritage place, requiring approval under section 15B of the EPBC Act.
New Women’s and Children’s Hospital (nWCH)
The proposed site identified in the New Women’s and Children’s Hospital Bill 2022[3] will permanently alienate approximately 30,000m2 of Park Lands. There will be a permanent impact on the adjacent Park Lands due to the scale and monolithic form of the proposed development. Additionally, the proposed access to green space from the nWCH4 represents the potential for further alienation as this will be challenging in relation to current health protocols without securely fencing an area of the Park Lands adjacent to the hospital and preventing public access.
In addition to the immediate loss of Park Land, there will be a medium-term impact on the adjacent Park Lands from the location of construction compounds during the build. This impact may extend beyond the proposed six-year construction period due to delays in construction or as a result of Government failing to remediate the construction compound for an extended period. This occurred in other areas of the Park Lands used in relation to construction of the new Royal Adelaide Hospital (nRAH). A media release from the Government refers to the intention to return “[m]ore than 30,000 square metres of land surrounding the hospital site […] currently blocked-off or dilapidated sites.”[4] Some of these are the result of the nRAH construction.
Finally, the nWCH development presents an ongoing threat to the Park Lands. Any future additions to the nWCH will require further alienation of Park Lands. The Site Review Report notes that an additional 16,450m2 of hospital accommodation will be required by 2041[5], a mere 10 years after the nWCH is proposed to open[6].
SA Police Mounted Operations Unit
The New Women’s and Children’s Hospital Bill 2022 also included a provision allowing any area of Park Lands to be selected for the relocation of the SA Police Mounted Horse Unit. This has now been realised as an announcement of an 8-hectare development in the south Park Lands. To date, this area of the Park Lands has remained open green active and passive recreation space. The proposed barracks represents a disturbing precedent for additional development in this area of the Park Lands.
World Heritage Bid
Compromising the heritage values of the Park Lands as noted in the National Heritage Register also represents a threat to a bid for World Heritage listing being prepared by the City of Adelaide in partnership with the Adelaide Hills Council. This bid has in-principle support from the SA Government[7]. World Heritage Listing has the potential to offer tangible benefits in the form of increased tourism and international recognition.
Sites proposed for World Heritage Listing need to be recognised and protected locally if the bid is to have any realistic chance of success. This reflects the expectation that local authorities will protect and maintain world heritage sites.
The proposed actions by recent South Australian governments in using the Park Lands as a ‘free’ land bank to conceal the actual cost of government developments will place the World Heritage listing bid for the Adelaide City Layout and Adelaide Hills at significant risk. Furthermore, the recommendation from the SA Heritage Council to list the Park Lands as a State Heritage Area has been sitting in limbo since 2018. These actions (or lack thereof) directly counter the in-principle support for the World Heritage bid.
The value of green space
Beyond their value as a heritage site, the Park Lands are a vital resource for South Australians. As our urban population grows and the density of urban development increases, the need for publicly accessible green space also becomes greater. Research demonstrates that access to green space improves people’s mental and physical health[8]. Green space also enables an active lifestyle, in turn promoting wellness and building community. Culturally, green space is important to the Kaurna people, the traditional custodians of the Adelaide Plains, and other Aboriginal people located in Adelaide. Finally, green space is vital in addressing climate change, assisting with mitigation of urban heat, stormwater management and supporting biodiversity.
Next steps
The Institute is committed to heritage conservation and the effective management of heritage places by all levels of government for the benefit of the community. While our primary focus is understanding and preservation of built heritage, the value of cultural landscapes, such as the Adelaide Park Lands, is also of great interest.
We would like to understand better what you, as Minister, the AHC and DCCEEW will do to intervene to protect National Heritage-listed sites like the Park Lands. It is certainly our hope that action can be taken prior to the commencement of demolishment or construction, rather than after this has occurred.
Yours sincerely
Shannon Battisson FRAIA
National President
Australian Institute of Architects
Chris Morley RAIA
SA Chapter President
Australian Institute of Architects
CC: The Hon Ted Beillieu
Chair, Australian Heritage Council
[1] https://www.abc.net.au/news/2023-03-12/sapol-wants-mounted-operations-unit-relocated-to-mirnu-wirra/102085842
[2] https://www.environment.gov.au/cgi-bin/ahdb/search.pl?mode=place_detail;place_id=105758
[3] https://www.legislation.sa.gov.au/__legislation/lz/b/current/new%20womens%20and%20childrens%20hospital%20bill%202022/unofficial%20royal%20arms/new%20childrens%20hospital%20bill%202022.un.pdf
[4] https://www.premier.sa.gov.au/media-releases/news-items/new-womens-and-childrens-hospital-legislation-passes-parliament
[5] Page 24, https://cdn.wchn.sa.gov.au/downloads/nWCH/Public-Review-Group-Report.pdf
[6] Page 10, https://cdn.wchn.sa.gov.au/downloads/nWCH/20230119-Site-Review-FAQs-FINAL.pdf
[7] https://www.cityofadelaide.com.au/media-centre/adelaides-world-heritage-bid-one-step-closer/
[8] e.g. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5663018/
