Every concern here comes from a named source

This paper cannot prove harm will occur under the proposed model. No one can — it hasn't operated at this scale, at this site. The burden this record establishes is not to disprove a forecast. It is that the government has not published the evidence that would let this community, or an independent reviewer, check that forecast at all Community review §3.

Five documented risk factors run through this record: absconding is frequent (153 events in the one year with a published breakdown — seven times the next-highest WA facility — against Frankland Centre's own count of under 5 in the same document, though nothing published shows how the rest splits by patient type); failures cluster specifically at transitions between security levels; release and diagnostic judgements have gone wrong, once fatally; some leave models depend entirely on the patient's own medication compliance with no external check; and the CLMI Act 2023 now pushes toward community access on a legislated timetable, not just clinical discretion Community review §3.

None of this was unforeseen. On 29 November 1990 — before the current secure unit even existed — Colin Barnett, then newly elected to the Legislative Assembly and later Premier of Western Australia from 2008 to 2017, told the House that Graylands already had a documented history of absconding patients causing serious harm off-site, and that moving offenders down through security tiers carried a risk that could not be engineered away, with further offences against civil patients, residents, or children inevitable, not hypothetical, without a physical buffer at the point of first transition. No buffer was built, then or since — and the specific failure mode he described recurred in 2004, 2010, 2012, twice in 2014, and 2015. This already happened once, in detail — read exactly what was warned and what happened next →

The clearest documented outcome: Graylands diagnosed Jesse de Beaux with drug-induced psychosis; a court-appointed psychiatrist later found that wrong. He absconded two days after leaving Graylands' care and killed a Munster woman he had never met Community review §3.1. The clearest documented mechanism: David Lockyer Harman's security downgrade granted him day release conditional on returning to Graylands nightly and, in between, on his own self-enforced medication compliance — with no external check described anywhere in the public record Community review §3.1.

This isn't a uniquely local pattern, and the government's likely response — review it if something goes wrong — has already been tried elsewhere and hasn't worked. In February 2026, two patients escaped Sydney's Cumberland Hospital within a day of each other; three people died in the following fortnight, and Premier Chris Minns ordered an urgent review. Six months later, NSW Health's own data confirms at least 14 further absconding incidents, and the state's shadow mental health minister says the review "did not result in a major reduction" Community review §3.5. 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 in 2013, 2015, and October 2025 Community review, Annex A.2.

WA has its own precedent, and it cuts the same way. Bennett Brook Disability Justice Centre had two residents escape in 2015; government acted only after a third escape in 2016, funding a $640,000 security upgrade and an independent review. Even that hasn't settled it — the Mental Health Advocacy Service's own 2024–25 report, tabled in Parliament this year, still records the centre as "under-utilised," the same finding made in 2020. Two official records, five years apart, describing a confidence problem that funded security upgrades never fully resolved Community review, Annex A.5. No comparable security-failure disclosure, funded response, or site-suitability review has been identified for Graylands — a facility more than ten times Bennett Brook's size, with a longer documented history, now being expanded.

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 §3.6. The population directly adjacent isn't a single undifferentiated "school community" either: John XXIII College's own Mary Ward Primary and Secondary programs support students with physical and intellectual disabilities on the same unfenced campus John XXIII College, Inclusive Education, and the Claremont Therapeutic Riding Centre — serving over 150 riders a week, many with disabilities — is being relocated to a site directly opposite as part of the same works ACNC, Claremont Therapeutic Riding Centre. None of this makes an incident more likely — but it changes what's at stake if one happens: some Mary Ward students may have a reduced capacity to recognise or respond to a threat, and some CTRC participants cannot rapidly evacuate. No published assessment weighs that. The same catchment already shares transport infrastructure with the campus — school students and any patient on approved community leave would use the same local bus routes and train stations — and no published document sets out where that leave may occur or which routes are involved.

Read the full safety case — five risk factors, the documented log, and how comparable facilities elsewhere have fared →

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 A.4. 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.

This isn't the first time proximity between this site and its surroundings has been professionally examined — just the first time it hasn't been. In 1983, professional planning consultants produced a report mapping the relationship between the proposed John XXIII College site and the Graylands hospital buildings beside it Feilman Planning Consultants, 1983, via Mikus, 2013, p.70. That exercise addressed a general psychiatric hospital about a third its later size, under a legal framework with no resemblance to the CLMI Act, more than forty years before this expansion. Nothing published shows an equivalent exercise has been carried out for the 176-bed forensic campus now proposed for the same land. See the fuller history of this site →

What's actually being built gives some sense of scale, at least. WA's only current forensic mental health unit, Frankland Centre, operates as a single secure compound of roughly 1.4–1.6 hectares, around two football pitches. The government's own environmental consultant states directly that the two new compounds Stage 1 adds will disturb 3.54 hectares between them — close to five football pitches, buildings, courtyards, secure perimeters and buffer zones combined. One secure compound, growing to three. See the full working →

That silence continues on the public record — though it isn't for lack of anyone looking. In January 2025, as part of the Project Definition Plan, the government contracted a dedicated security consultant, Security Consulting Group Pty Ltd, for $64,152, specifically for "Project Definition Plan Phase — Security Services" Tenders WA, FINW0623724. What that work examined, what it concluded, and whether it ever revisited this site against the correctional co-location model used interstate, has not been published. Commissioning security work and disclosing what it found are different things — so far, only the first has happened.

Parliament tested this directly in September 2026, asking what the campus's current security protocols are, how they're adapting during construction, and what permanent upgrades the finished campus will carry. The answer: Graylands is an authorised hospital, authorisation requires meeting stringent standards, and the expanded campus will continue to meet them WA Parliament, QoN 3094, 15 Sep 2026. None of the three things asked — current protocols, construction-period arrangements, permanent upgrades — was actually described. A direct parliamentary question is about as formal an opportunity to disclose this as exists, and it produced the same answer as everything before it.

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 §5.1.

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.

Asked directly in September 2026, the government said community access for this cohort remains "largely consistent with" the pre-2023 regime WA Parliament, QoN 3087, 15 Sep 2026 — not in dispute, and consistent with what's said above. The same answer also claims demand modelling accounted for the new law, but that's a claim with no way to check it from outside government, so it isn't one worth resting an argument on. What the answer does not do, and is the only part of it that actually matters here, is confirm this site was ever reassessed against the CLMI Act's community-access model, rather than folded into statewide bed numbers Community review §5.1.

The government's own current mental health strategy, released April 2026, commits to continued monitoring of service demand specifically following the CLMI Act's enactment, and names the Graylands Reconfiguration Program as part of that ongoing focus MHAOD Strategy 2026–2031. A commitment to monitor is not a published result — well over a year after the Act took effect, none of that monitoring has been made public.

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.

That's not a technicality. New South Wales requires an independent Social Impact Assessment by law for state significant projects of this scale, prepared by a suitably qualified expert against a published guideline NSW Government, Social Impact Assessment Guideline. Western Australia has no equivalent requirement — and more than three years after Infrastructure WA flagged the assessment as incomplete, no social impact assessment for this project has been published at all.

The government committed $218.9 million approximately three weeks later — and its own Budget Papers show exactly what state the business case was in at that moment. The 2023–24 Budget states plainly that the $218.9 million was "provisioned" for Stage 1 "over 2023‑24 to 2026‑27" while "a business case for first stage works is under development for future Government consideration" WA Budget Papers 2023–24, Budget Paper No.2, Part 5, item 34.1. A contract to actually develop that business case and finalise costings was then awarded to Ernst & Young on 28 June 2023, two months later again Tenders WA, DoH202311853. So in the government's own documents: an independent reviewer says the case is inadequate; three weeks later the money is provisioned regardless, while the Budget Papers themselves say the business case is still being written; two months after that, someone is actually contracted to write it. That is a sharper, more precise problem than a silent three-week gap — it is money committed on a case the government's own paperwork says did not yet exist Community review §6.2.

The government's own current mental health strategy commits its infrastructure and service-planning agencies to "transparent and accountable communication with other commissioning agencies, peak bodies, services and communities," underpinned by a Commissioning Framework built around needs assessment and evidence rather than decisions made first and explained later MHAOD Strategy 2026–2031. Provisioning $218.9 million for a business case the Budget Papers themselves describe as not yet developed is hard to reconcile with either commitment.

The site's own history sharpens the question further. In December 2014, the government announced Graylands would close, describing a significant parcel of the land at the time as prime real estate it intended to sell. By 2021 that position had reversed entirely: the site was retained and forensic services expanded on it instead. No published document explains what changed between those two decisions, or how the land was valued in either. That reversal is the clearest illustration of what this whole section is asking for — not proof that the current decision is wrong, but confirmation that it was ever properly re-tested against the one before it.

Parliament put the direct question in September 2026: on what basis did the Minister make the investment decision, given Infrastructure WA's finding? The answer described planning "over more than a decade" and the Taskforce's 2021 recommendation to expand forensic services on the site — it did not name what was relied on to bridge IWA's own finding, and did not mention that finding at all WA Parliament, QoN 3090, 15 Sep 2026. The same day, a companion question asked whether a Project Definition Plan exists for this project and, if so, when it was created and where it's available — the answer described the general Treasury framework for Project Definition Plans and the funding allocated to the riding-centre relocation, without confirming this project's PDP exists, when it was made, or where it can be seen WA Parliament, QoN 3091, 15 Sep 2026. Both questions gave the government a direct, formal opportunity to close this gap. Neither answer did.

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 B.

That direction wasn't a recent turn. An independent academic history of the site records the hospital's own scale collapsing over decades: from more than 1,500 beds and 394 acres in 1960 to roughly 200 beds and 25 acres by 2013 — a reduction happening while the state's population roughly tripled Mikus, 2013, pp.74–75. Whatever changed in 2023, it wasn't a sudden new idea meeting an otherwise-stable institution — it was a fifty-year trend running the other way. See the fuller history of this site →

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 §8.1.

This hasn't changed. OMID's project fact sheet, first dated August 2026 and reissued in September 2026, asks the direct question "What consultation has been undertaken?" and answers only that the Taskforce consulted health and mental health experts, supported by a Lived Experience Advisory Group and a Clinical Advisory Group — the same clinical-only answer, unchanged between both editions, restated as the official position months after Stage 1 was funded and after this campaign wrote to every responsible Minister OMID, Graylands Campus Project Fact Sheet, Sep 2026.

The September 2026 edition goes further, adding a question that answers itself: "What consultation is required for the expansion of forensic mental health beds at Graylands?" The government's own answer sets the threshold in writing: consultation is mandatory only for the internal clinical, design and lived-experience input required to authorise a hospital under the Chief Psychiatrist's Standards; public consultation is something that "may occur" — not something the project commits to — through an unrelated process such as a development application; community engagement is raised only in relation to managing disruption once construction is under way, not whether the site, the model, or the security arrangements belong here OMID, Graylands Campus Project Fact Sheet, Sep 2026.

That directly contradicts the standard the government has separately set for itself. The same government's own current mental health strategy, released five months earlier, states that infrastructure planning of this kind requires "robust stakeholder consultation" including "the broader community," and names consultation on "location, site planning, construction and refurbishment design" as a five-year priority — naming the Graylands Reconfiguration Program directly as one of the projects it applies to MHAOD Strategy 2026–2031. One arm of government has committed to consulting the broader community on location and site planning. The delivery agency running this specific project has now published, in writing, a threshold for "required" consultation that excludes exactly that. This isn't an absence this campaign is pointing to — it's two parts of the same government on record with incompatible standards for what this project owes the people living beside it.

There's a second thread worth pulling on the same point. In September 2023 the government commissioned a "site feature plan for submission with the DA" to support the Graylands masterplan and architectural planning Tenders WA, FINW0813723 — a development application was, at that point, part of the plan. Three years later, the fact sheet above still describes a DA only as a hypothetical route to public input. Has one been lodged? If not, is one still coming, has the pathway changed, and will the public still get the advertising and comment period a DA would provide? See FOI Application 01, Planning pathway →

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 §8.2. The only recorded contact with the City of Nedlands was an EPBC notification that received no specific response.

The government's own contract-disclosure record adds a further, independent data point. Of the 28 Graylands-tagged contracts published on Tenders WA between October 2022 and August 2026 — spanning architecture, engineering, cost management, workforce strategy and business case development — not one is for community, resident or school engagement full contract register →. $8,958,992 has been contracted for planning and advisory work on this project; none of it for finding out what the neighbourhood thinks.

Graylands is listed on the WA State Register of Heritage Places (No. 13630), with structures dating to the early twentieth century. It also carries a separate City of Nedlands Heritage List classification, Category B, which the listing itself describes as requiring "a more detailed Heritage Assessment/Impact Statement... before approval given for any major redevelopment" State Heritage Office, inHerit database. Infrastructure WA specifically flagged that heritage refurbishment costs were not adequately assessed in the business case Infrastructure WA, Mar 2023, and no separate, published Heritage Assessment or Impact Statement of the kind the site's own listing calls for has been identified for this redevelopment. See the fuller history of this site →

On the buildings themselves, heritage looks settled. The Stage 1 buildings sit outside the heritage boundary, and on a 28.9-hectare campus where the whole development area is 4.6 hectares, there is ample room to build without touching a single heritage structure. The only recorded overlap is marginal: the government's environmental consultant found that the disturbance area — which extends past the buildings to take in the security perimeter zones — clips the mapped heritage boundary, putting up to four trees inside it at risk RPS, Environmental Impact Summary, 1 Sep 2025, p.29. Four trees is not a reason to stop a hospital.

What that report is useful for is something else entirely. Its advice on those four trees was that a Heritage Impact Statement "may need to be submitted to the relevant Local Government Association (City of Nedlands) as part of a future GCP Development Application submission." That is the government's own consultant, in September 2025, treating a development application as the expected pathway — the same pathway OMID's September 2026 fact sheet still describes as merely something that "may occur," and the single most time-critical open question in this campaign. See FOI Application 01, Planning pathway →

On the vegetation and black cockatoo assessment, the work appears to have been done properly. 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." Behind it sits a tree-by-tree survey: 114 trees measured individually on the main site, 97 on the riding centre site, each assessed against the Commonwealth's own black cockatoo referral guidelines, with a patch of tuart tested against the threatened ecological community criteria and reasonably excluded for lack of native understorey RPS, Environmental Impact Summary, 1 Sep 2025. The referral records permanent clearing of about 1.19 hectares of foraging habitat and 69 potential nesting trees, with a confirmed Carnaby's roost approximately 180 metres away — figures that reconcile against the underlying consultant reports. The referral process is closed and is not a channel for further public comment.

One question about that referral does remain open. It 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. A thorough survey of one stage is not the same as an assessment of the whole program, and nothing published shows the later stages have been assessed at all.

The strongest environmental question is the one the referral never touched: the site sits inside the Subiaco Wastewater Treatment Plant's statutory odour buffer, in which the City of Nedlands' own planning scheme says no "sensitive land use" — hospitals expressly included — is to be located. Infrastructure WA flagged this as an unresolved issue in 2023; we can't find evidence it's been publicly resolved since. Full statutory analysis, sources and what we've asked to see: The odour buffer question →

WA's own psychiatrists don't propose meeting forensic mental health demand with one large secure campus. The Royal Australian and New Zealand College of Psychiatrists calls for an "integrated, tiered" system spanning court and police liaison, prison in-reach, therapeutic and sub-acute custodial care, secure hospital care, rehabilitation, step-up/step-down services, supported accommodation, and specialist community teams — with low-risk forensic patients able to access general hospital beds across the state, not only a single dedicated campus RANZCP WA, Justice and Mental Health Roundtable Communiqué, Jul 2026. Graylands, expanded to 176 beds under one roof, is the opposite of that model. RANZCP says so directly: the redeveloped campus "will not deliver the number of beds sufficient for future needs and proportionate to population growth," and calls for delivery milestones to be published — something that hasn't happened for this project.

This is where the site-selection date matters most. Graylands was chosen in 2021 on transport and accessibility grounds, for a facility operating under the old indefinite-detention law. The Criminal Law (Mental Impairment) Act 2023 replaced that with fixed limiting terms and a statutory reintegration pathway — precisely the kind of stepped, distributed model RANZCP describes, where patients move through community-facing stages rather than remaining in one secure campus. No published document shows the Graylands concentration was ever re-tested against a tiered, CLMI-era model, or against RANZCP's own view of what current demand actually requires.

The community isn't asking for less forensic mental health capacity. It's asking what statewide service model was tested before this scale of expansion was concentrated at this site, what alternative distribution of beds and services was considered, and why a single 176-bed campus — bordered by homes and five schools — is the answer, when the professional body that would staff it says the answer looks different.