A BIG opportunity: midnight this Friday night 2nd October is the deadline for submissions to the Federal Government's Department for the Environment re the MotoGP.
The important thing is that everyone possible registers an objection, so a very simple statement is very useful.
Hi all,
In order of effort, here are the options.
A simple submission, such as the following, is very useful:
"This submission objects to the Adelaide Circuit Redevelopment Project. There are likely to be significant impacts on Matters of National Environmental Significance and these have not been appropriately assessed. The Adelaide Circuit Redevelopment Project should be comprehensively assessed as a Controlled Action".
You make the submission through the EPBC public portal.
Fill in your details, and once you are logged in you will need to go to "OPEN FOR COMMENT" at the top of the page, and then find Adelaide Circuit Redevelopment (ACR) Project EPBC 2026/10637, it's 17th on the list. It might look tricky but it's easy to do.
NOTE THAT YOU CAN SIMPLY ATTACH YOUR SUBMISSION!
or
A more complete submission.
Melissa Ballantyne's instructions on the Park Lands Association's site are excellent - click on the yellow band at the top of the page.
Remember you do not need to comment on everything, just making a few points will do.
The list of points Melissa offers are good to work from.
And these are the Stenhouse (heritage impacts) and Succession (biodiversity) reports that are referred to if you want more information.
In that case, Stenhouse is long, but a good starting point is to go to its Table 4 because it lists the criteria that have to be addressed and is the core of the report.
Note that under Stenhouse the proposed action does not include the race event, set up and demobilisation activities which will go on for months each year. These should be included, it's a remarkable deficiency.
It is also worth asking the Commonwealth to consider cumulative effects. The Park Lands are threatened with death by a thousand cuts. There are three forms of pressure on the broader 'City in a Park' structure: the horizontal motorsport corridor in the eastern Park Lands; commercial and infrastructure changes around the North Adelaide Golf Course; and the vertical development represented by Walker Tower 2 at Festival Plaza. These projects are not necessarily one legal action, but their combined effect should not be ignored when assessing the integrity of the National Heritage place as an integrated urban design.
If you make a copy of your submission you are also encouraged to send it to the Australian Heritage Council whose chair is the Hon. Bob Carr,
and
the Minister for the Environment, Murray Watt
Other framing of issues is as below:
The project would permanently alter a National Heritage-listed landscape whose significance depends on the relationship between Adelaide's urban grid and its surrounding Park Lands. This submission argues that the project should be assessed on its full physical, environmental, heritage and cumulative impacts, rather than on a narrow representation of the track footprint.
1. Scale and permanence of the physical intervention
The proposed circuit is described as a 4.13 km high-speed motorcycle and motorsport circuit with approximately 3.97 hectares of permanent asphalt and associated hard infrastructure, together with substantial safety run-off areas, gravel traps, under-surface works and other engineering requirements. This submission argues that modern FIM motorcycle-safety requirements make the project materially different from earlier street racing that could be accommodated more closely within existing road corridors. The resulting lateral expansion into parkland would permanently introduce an industrial road-and-safety environment into areas that are currently open public landscape.
A major concern is tree and vegetation loss. This submission identifies approximately 399 mature canopy trees as potentially affected, including significant trees, and argues that the loss is not simply the removal of individual trees but fragmentation of historic avenues, canopy, habitat and the landscape structure of the Park Lands. It also argues that replacing mature trees with new plantings elsewhere cannot immediately reproduce their heritage, ecological and microclimatic functions.
2. National Heritage values and cumulative impact
This submission's principal heritage argument is that the Park Lands and City Layout are significant as an integrated urban design: a planned city surrounded by a continuous public green belt. It argues that permanent asphalt, safety infrastructure, tree clearance and recurring exclusion of the public would fragment that relationship and therefore affect the heritage values of the listed place.
3. Biodiversity and environmental concerns
This submission identifies several matters requiring independent assessment under the EPBC Act. It states that the Vulnerable Grey-headed Flying-fox occurs in the project area, with targeted surveys recording 1,219 individuals and the project area approximately 700 metres from the Botanic Park breeding camp. It also identifies Grey Box Grassy Woodlands and Derived Native Grasslands and raises concerns about the adequacy and timing of surveys. The submission further raises potential impacts on the Chequered Copper Butterfly and other threatened species.
This submission argues that high-intensity racing noise, lighting, construction activity, tree removal, hard surfaces and repeated event occupation should be assessed together rather than as isolated impacts. It invokes the precautionary principle where the available information is incomplete or uncertainty remains about potentially serious or irreversible impacts.
4. Transport, public access and health
This submission argues that the circuit and associated event infrastructure would impose substantial temporary disruption on the metropolitan road network. It draws on traffic information from existing Adelaide motorsport closures and argues that the larger and longer disruption proposed for the new circuit could produce significant delays on eastern, western, northern and southern approaches to the CBD, including freight routes.
It estimates substantial losses through travel-time delays and excess fuel consumption over the multi-week construction, event and dismantling period. The submission also raises public-health concerns associated with motorsport noise and traffic-related emissions, particularly because major hospital precincts are located close to the proposed circuit. It argues that these effects require transparent modelling rather than reliance on assumptions or comparisons with shorter existing race closures.
6. Consultation, information and procedural concerns
A central procedural concern is the timing of consultation. This submission argues that key decisions and commitments—including the circuit configuration, hosting arrangements and public expenditure—were made before meaningful public consultation. It therefore asks the Commonwealth to examine whether the consultation process gave the community and relevant institutions a genuineopportunity to influence the proposal.
This submission also identifies information it says requires independent verification, including the full FIM safety envelope, tree numbers, permanent and temporary ground disturbance, construction and occupation periods, traffic impacts, economic and visitor projections, and the timing of irreversible works. It argues that the Commonwealth should test these matters against the underlying engineering and environmental information rather than relying solely on simplified public-facing material.
7. Economic case and alternative venue
This submission questions whether locating the event within the Park Lands is necessary when The Bend Motorsport Park at Tailem Bend is an established motorsport facility. It argues that a purpose-built regional venue could accommodate high-speed motorsport without permanently modifying a National Heritage-listed urban landscape.
It also questions the economic assumptions underpinning the Adelaide project, particularly the public capital contribution, the treatment of tourism benefits, and the costs imposed on motorists, freight operators, businesses and the public through congestion and temporary loss of access. This submission therefore asks that the Commonwealth examine both the claimed benefits and the full opportunity and external costs of the proposal.
Important limitations in the Stenhouse Heritage self-assessment report.
While the report acknowledges that the project will cause changes to vegetation, views and vistas, circulation patterns, landscape character and the introduction of additional pavement and infrastructure, it concludes that these impacts are not significant when considered against the National Heritage place as a whole. Critically, the assessment places considerable weight on the relatively small percentage of the approximately 1,000-hectare listed area directly affected. It does not treat the park as an integrated whole.
It also notes that the assessment expressly excludes temporary event infrastructure and operational activities associated with MotoGP from the proposed action, despite acknowledging that the redevelopment is required to enable MotoGP to occur in Adelaide. The assessment consequently does not provide a comprehensive evaluation of the combined permanent, temporary and recurring impacts associated with the project.
Stenhouse itself records the National Heritage value that the Park Lands are “fundamental to the character and ambience of the city”, and that they have outstanding social value.
Here is ecologist Ben Taylor's outstanding submission.
STANDING OUR GROUND. HOLDING THE LINE with John Schumann & the Vagabond Crew at the Gov was a full house - an excellent result, a big thank you to John Schumann and the musicians!
And finally, the photo above is Dr Jennifer Bonham speaking at the very successful Unley Roadshow last Saturday.
Good luck with this exercise and thank you,
Rob,
Robert Farnan
Convenor | Save Festival Plaza Alliance
O435007799
Savefestivalplaza@gmail.com
savefestivalplaza.net
Ed and Janette's legal challenge GoFundMe in relation to Possum Park (court's decision handed down this Thursday October at 2pm)
Our account, thank you.
805 007 CUSCAL
00331035 Save Festival Plaza Alliance Robert Fa