Every concern here comes from a named source

Every part of the Taskforce's planning — the 136-bed figure, the security classification model, the site design — was conceived under the old Criminal Law (Mentally Impaired Accused) Act 1996, which held patients on indefinite orders requiring the Attorney-General's personal approval to release Community review §3.1.

The Criminal Law (Mental Impairment) Act 2023 replaced that model entirely. All custody orders now require an end date. Courts can order patients to live in the community under supervision instead of detention. Safe community reintegration is now an explicit statutory purpose, not an aspiration CLMI Act 2023. It received Royal Assent on 13 April 2023 — the same month as the $218.9M funding commitment.

Whether the Taskforce's bed-count projections and community interface risk assessment were formally updated for the new law has not been publicly confirmed. The government has not released updated demand projections, security classification mix, or a community access model reflecting the new framework Community review §3.4.

In March 2023, Infrastructure WA — the State's statutory independent infrastructure advisory body — found the business case Infrastructure WA, Mar 2023 contained "insufficient information on which to base an investment decision," citing six specific gaps: an undefined scope and cost, heritage refurbishment costs not properly assessed, an unresolved wastewater-plant odour buffer affecting over 55% of the site, poorly managed project interdependencies, an incomplete social impact assessment, and an environmental assessment that didn't identify all potential risks.

The government committed $218.9 million approximately three weeks later. No document explaining what changed in those three weeks — or how the six gaps were resolved — has been publicly released Community review §4.2.

WA's own ten-year Mental Health Plan (2015–2025) described the Graylands model as a "Victorian era asylum model" — language pointing to replacement, not expansion. The 2019 State Budget allocated $3 million specifically for planning and decommissioning studies of the site Community review, Annex A.

In Parliament on 17 May 2023, the Minister for Health described the same Taskforce as recommending both "decommissioning and replacing" the general psychiatric function and "retaining and expanding" the forensic function — presenting two opposite conclusions as one continuous plan Hansard, 17 May 2023. The bed count itself has also moved: the Minister cited 53 new beds in that same statement; current material describes 40 (32+8). No public document explains when or why the direction changed, or who made that call.

The Taskforce consulted clinical professionals, mental health consumers and carers, and senior public servants — an internal clinical consultation about the best service model, not an engagement with the people living next to the facility Community review §6.1.

After reviewing every publicly available document — the Mental Health Commission's Taskforce page, the NMHS Graylands page, the IWA assessment, government media statements, and the EPBC referral — no evidence was found of consultation with residential neighbours, direct notification of any of the four nearby schools, public information sessions in Mount Claremont, or a resident advisory mechanism of any kind Community review §6.2. The only recorded contact with the City of Nedlands was an EPBC notification that received no specific response.

Graylands is listed on the WA State Register of Heritage Places (No. 13630), with structures dating to the early twentieth century. Infrastructure WA specifically flagged that heritage refurbishment costs were not adequately assessed in the business case Infrastructure WA, Mar 2023.

EPBC Referral 2025-10271, covering the Stage 1 footprint and the relocation of the Claremont Therapeutic Riding Centre, was lodged 5 September 2025 and decided 14 November 2025 as "not a controlled action." The referral found two threatened species — the Endangered Carnaby's Black Cockatoo and the Vulnerable Forest Red-tailed Black Cockatoo — likely to occur in the action area, with a confirmed Carnaby's roost approximately 180 metres away. It records permanent clearing of about 1.19 hectares of foraging habitat and 69 potential nesting trees EPBC Referral 2025-10271. This referral process is closed; it is not a channel for further public comment.

The referral describes itself as "Stage 1" of a larger program, yet answers "no" to the form's own question about whether it is part of a staged development — the answer that confines the assessed impact to 1.19 hectares rather than the cumulative footprint of the full 136-bed campus EPBC Referral 2025-10271.

In June 2014, a Frankland Centre patient absconded during a clinical transition between security levels. His absence wasn't realised for about a week. The community and nearby schools were not notified. The then-Opposition mental health spokesperson called it "an outrage" — he is now a senior Minister in the Cook Cabinet Community review §8.1. No public protocol confirms a mandatory community notification system has since been established, twelve years on.

This isn't a uniquely local pattern. Victoria's Thomas Embling Hospital operates under considerably more structure than anything disclosed for Graylands — judicial oversight, graduated leave escalation — and patients on approved leave have still failed to return on the public record in 2013, 2015, and October 2025 Community review §8.3. In February 2026, two patients escaped Sydney's Cumberland Hospital within a day of each other; three people were killed in the following fortnight Community review §8.4. Reporting describes both as involuntary mental health patients; this paper does not claim forensic-order status specifically.

No published community notification protocol, no disclosed boundaries for supervised community access, and no independent leave oversight body have been identified for Graylands Community review §8.5.

Infrastructure WA specifically found the social impact assessment for this project incomplete. No independent analysis of the effect on residential values, marketability, or buyer demand is publicly available Infrastructure WA, Mar 2023. This isn't a claim that values will fall — it's that no evidence-based answer exists in the public domain, for a project that materially changes the character of a residential suburb.

If an independent assessment did find a material effect, a further question follows: what compensation, acquisition, or redress mechanism would be available to affected homeowners? Community review §9.3 That question can't be answered until the assessment exists.

Infrastructure WA's own report states that twenty sites were assessed in early 2021 "based on accessibility, central location and close proximity to public transport" Infrastructure WA, Mar 2023 — criteria suited to a general clinic, not a maximum-security facility for people held under criminal justice orders. None of the twenty were assessed against community safety, school proximity, or security risk.

Two other Australian states answered this differently: NSW's Forensic Hospital sits inside the Long Bay Correctional Complex; Victoria's Ravenhall forensic service is co-located with Ravenhall Correctional Centre Community review, Annex E. Whether WA's own correctional precincts at Hakea and Casuarina, 22km away in Canning Vale, were ever compared on security grounds has not been disclosed.