The next stage of the $3.2 billion hospital project rests with Federal Environment Minister Tanya Plibersek, after a DASH Architects heritage report found several issues that could adversely affect the listed park lands long term.

DASH Architects found the plan should be scrutinised under the national Environment Protection Biodiversity Conservation Act (EPBC) that protects the park lands.

Its findings prompted the state government to lodge a report with Plibersek’s department last month, with which also highlighted that the project area likely provided habitat for the grey-headed flying fox, listed as vulnerable nationally under the EPBC Act, on site – but that it was unlikely to be impacted.

Plibersek will now receive advice from the Climate Change, Energy, Environment and Water Department about whether the hospital plan’s intrusion on Adelaide’s listed park lands triggers a “controlled action”.

“The department is currently looking at the Adelaide Women and Children’s Hospital (WCH) proposal to see whether it needs to be assessed under national environment law,” a department spokesperson said, following a 10-day opportunity for public comment on the state report.

“If it does need approval, it will be subjected to a thorough environmental assessment that will include another opportunity for public comment.”

DASH Architects said the planned new hospital and carpark were “significantly larger in scale and height” than the existing state heritage-listed Thebarton Police Barracks which are set for demolition, with “greater visual prominence” that will risk the “openness” of the existing protected parklands.

It considered the new hospital could also have a long-term impact on Colonel William Light’s Adelaide plan and its “encircling park lands”.

Despite the existing landscape character of the area being “generally poor” the new hospital building and loading bay “will preclude the rejuvenation” of the area in a way that is more consistent with its national heritage values, the report said.

The findings forced the SA Health and Wellbeing Department to lodge plans with the federal Environment Department last month, with its own assessments refuting the claims.

“Approximately 5.65 ha of the disturbance footprint is the site of the proposed action (excluding construction service areas and road upgrades). Of this, less than half is in the National Heritage Listed Adelaide Park Lands and City Layout,” the submission led by new WCH project director Brendan Hewitt said.

“However, the new Women’s and Children’s Hospital Act 2022 introduces legislation that ‘switches’ off this zoning in this location for the purpose of the development of the new Women’s and Children’s Hospital”.

The state government said landscaping and pedestrian linkages would “mitigate this potential impact” and open areas previously closed to the public, while encroachment on the park lands was “minimal”.

There are also 113 trees at the target site that meet the criteria for being protected under state legislation, including 42 significant trees with circumference larger than 3m and 71 regulated trees with circumference over 2m.

The SA Health report also noted that threatened species were likely to be in the area – “This includes the State Vulnerable Yellow-tailed Black Cockatoo… which was observed flying over the Project Area during the field survey, the State Rare Common Brushtail Possum… and the State Rare Peregrine Falcon.

Plans released by the State Government for the new Women’s and Children’s Hospital.

Adelaide’s park lands were listed as a National Heritage Place in 2008 and is “regarded throughout Australia and the world as a masterwork of urban design”, according to the DASH Architects report.

The report said that under the state government’s self-assessment of its project that referral under EPBC Act guidelines “in relation to potential ‘significant impacts’ to the National Heritage values of the Adelaide Park Lands and City Layout is necessary and recommended”.

It found:

• The hospital building and car park are inconsistent with open, low scaled landscaped attributes of the place;
• The impacts of the park lands are long-term impacts;
• The hospital building and car park are inconsistent with open, low scaled landscaped attributes of the place;
• The hospital and carpark building have the potential to impact on the legibility of the 1837 plan and encircling park lands, and;
• The construction of the 10-storey hospital building and the seven storey (above ground) carpark within the encircling parklands will likely result in long-term impacts to the legibility of Colonel William Light’s 1837 Adelaide Plan.

Among submissions to the lodged report, the Adelaide Park Lands Association shared its concerns about the plan affecting the National Heritage values of the park lands – telling its members that “the Federal Government is only now catching up” on the state government’s “advanced” plans

The planned car park alone would destroy 5ha of Park 27 (Kate Cocks Park) adjoining Gaol Road, which contains an olive grove and sheoak trees, it said.

“Ms Plibersek’s Department is belatedly examining the State Government’s proposed new Women’s and Children’s Hospital,” the association said on its website.

“Her Federal Department has a role because the proposed hospital would be built over a large swathe of your National Heritage-listed Park Lands, including this grove of about 50 ancient olives and sheoak trees.

Among other submissions, the Australian branch of the “International Council on Monuments and Sites” said an alternative location for the WCH should be found “that does not significantly impact both National Heritage and State heritage values”.

A government spokesperson said “this is not a new step”, saying those overseeing the new Women’s and Children’s Hospital project made its submissions to the Department of Climate Change, Energy, the Environment and Water in July.

“The design of the new hospital will be an improvement to the park lands, and will return more than 30,000 sqm of land surrounding the hospital site to open green space,” she said.

“The barracks site is currently inaccessible behind razor wire, and surrounded by inaccessible and dilapidated areas of the park lands that will be upgraded and made accessible.

“The Federal Government is considering the submission in accordance with the Environment Protection and Biodiversity Conservation Act and we look forward to the outcome soon.”