October 9, 1999.

Officer-In-Charge

Public Works Committee

Parliament House

Canberra ACT 2600

Dear Sir/Mme,

We wish to make this submission regarding the CSIRO/University of Queensland (UQ) Joint Building Project, St Lucia, Qld. This project is referred to locally as the proposed Institute for Molecular Biosciences (IMB). Its satellite laboratory, the Natural Sciences Precinct (NSP) is proposed for the neighbouring suburb of Indooroopilly. Members of our group intend to accept your invitation to attend the meeting at UQ on 27 October 1999, to discuss these matters further.

OUR INVOLVEMENT

We formed our committee at a public meeting in April this year, because citizens were concerned about and opposed to the proposed inappropriate placement of these large commercial GMO laboratories within our residential areas, in Brisbane. We have since then become aware of the Biosafety issues involved, as well as other concerns about excessive traffic volumes, overcrowding of residential areas, the risks to the environment of this type of research, as well as other concerns.

OBJECTIONS TO THE NEED FOR IMB AND NSP

• We would dispute that $50 million of taxpayers’ money should be spent on the IMB.
• It has now been 26 years since Boyer and Cohen managed to recombine toad and bacterial DNA.
• It has been 18 years since the CSIRO originally began lobbying successive Federal and State and governments for funding, on the basis that "Australia is missing out on the Biotechnology dollar". How long must we wait before the home-grown Biotechnology dollar is to arrive in Australia? Another 18 years?
• We have seen little evidence that Biotechnology in Australia has delivered on its wild promises to " save babies" and to "feed the world".
• We are doubtful that the Biotechnology and the IMB will be "the Goose that laid the golden egg". The better analogy is that of the Turkey, who, and having eaten three golden eggs, is now old, terminally ill and constipated, but still demands a $50 million funeral.
• Biotechnology in Australia is not "cutting edge". It is in fact an old science, which is now out-of-step with community demands and expectations. Stocks in Biotechnology companies have been plummeting around the world for the last 12 months, as the community has become aware of and rejected genetically modified agricultural products, throughout the world.
• Australia has over 190 Biotechnology companies. A recent conference in Germany determined these were the worst performing Biotechnology companies in the world, with an average annual profit of less than 1%. Deutsche Bank in Germany has been advising its clients throughout the world to divest themselves of Biotechnology investments, because of the poor long-term prospects for the future, and lack of acceptance by the general community.
• If Biotechnology in Australia is truly viable in the open commercial market, then why does the CSIRO need to build laboratories for the use of these well-funded multinational chemical companies ? Surely these companies can afford to build their own laboratories, if the prospects of profitability are truly there.
• We believe that spending $50 million on the IMB is a mistake, as this form of scientific research has had its day. The scientists involved have misread the social and political community in which they live.
• They need to read the newspapers, and listen to the people in the community they live with. They would hear that the public do not want genetically modified agricultural products, and they do not want laboratories with high-risk to community in their residential areas.

OBJECTIONS TO THE ADEQUACY OF IMB AND NSP TO MEET

THIS NEED

1.  
2. LOCATION

• The IBM and NSP are being built in heavily populated areas of St.Lucia and Indooroopilly. The IMB will be seven stories high and will create privacy problems for the low rise detached housing on Carmody Rd and Dell Rd and many other areas in St.Lucia
• The IMB is to be built in the circumferential green buffer zone around UQ, which should remain as open space. On the UQ campus, there are many suitable sites for such a large building e.g. sports fields and large undeveloped car parking areas, old rundown buildings that could be redeveloped.
• Moving the IMB to other open space in the UQ would allow for co-location of IMB and NSP on the one site, with a reasonable green buffer zone surrounding.
• Best practice, however should involve building the IMB and NSP together on the same greenfield sites, as are available at Pinjarra Hills (UQ) and Samford (CSIRO). These campuses already contain significant scientific infrastructure, have better roads, and plenty of room to expand.

1. SIZE

• The Draft City Plan requires that the IMB be consistent in size, form and bulk with neighbouring residential housing. This would limit the IMB to 3 story detached laboratories, with areas of open space between. The building as planned is far too large, and is even inconsistent with the size and bulk of all other buildings within the UQ campus.
• Shadows cast by the building at certain times of the year and at certain times of the day will inconvenience local residents. We understand that shadow drawings have not been executed.
• Reflected traffic noise from front wall of the IMB will create problems for residents across the road.

1. BUILDING SAFETY

• Planning of the IMB has been completed and funding has been arranged, before Environmental Impact Studies, Assessment of Impact studies, Traffic Studies and Risk Management Reports have been completed and publicised.
• Such glaring omissions of normal building practices bring into question the integrity of the builders of the IMB and the NSP.
• We believe the IMB (and the NSP) should be subject to the Integrated Planning Act 1997 (IPA), and should not be fast-tracked to avoid complying with his Act, because it is being built on University land.
• Considering the size of the IMB, and its obvious impact on surrounding areas, it would seem tremendously important that its plans are consistent with building codes for the rest of the State and the rest of Brisbane. To ignore these building codes would be extremely irresponsible of UQ and CSIRO.
• The builders of the IMB have not taken up the opportunity to obtain free consultation with the Brisbane City Council's Assessment of Planning Objectives team, who could have advised on a more environmentally friendly approach to building. Such an assessment has been sought with respect planning of the NSP, by the same builders of the IMB.

4. TRAFFIC

• No traffic studies have been performed, although construction is about to commence. No building of this size would be allowed to be built under the Draft City Plan or Integrated Planning Act 1997(IPA) without extensive traffic studies being performed by independent consultants.
• The UQ Campus has approximately 30,000 students visiting each day, and surely traffic volumes will be affected by the 750 staff to be employed at the IMB.
• Road access to the IMB is inadequate, and consists of the single narrow residential road, Carmody Rd. Streets in this area are already heavily congested, and the IMB will worsen this problem, with increased staff vehicles and large vehicle deliveries via Carmody Rd.

5. PARKING

• The IMB has parking for only 240 of its 750 occupants. This small number of car parks provided are reportedly for exclusive use of CSIRO workers, as UQ does not provide any dedicated parking for its staff.
• We believe it is irresponsible for UQ to continue to provide inadequate parking. This forces the staff and students to park in the surrounding residential areas.
• Some of the funding available for IMB should be set aside for underground car parks, as is normal practice when such large buildings are constructed in Brisbane.

RISKS TO THE COMMUNITY

• As residents, we are strongly against the placement of Biohazard Physical Containment (PC) laboratories (in the case of IMB PC-3 laboratories, involving live mice and rats in GMO experiments) within our residential suburbs.
• We have had problems with the CSIRO Department of Tropical Agriculture at Indooroopilly, who secretly exterminated all the Possums in eastern Indooroopilly last year, after they got in and ate from a petrie dish of GMO’s in their Indooroopilly laboratory. The public were not informed. Dr Elisabeth Heij attempted to cover-up this issue again in the media, in September 1999. We currently have a formal complaint with GMAC over this incident, and are calling for community participation in all Institutional Biosafety Committees (IBC’s).
• We are alarmed, too, that the sister building, the NSP will have PC-3 and PC-4 (high-risk to the community) laboratories, when it is to be built in 2000. Like the IMB, the NSP is to be built directly in a residential suburban area at Indooroopilly. The community will not accept that this is safe, necessary or desirable. We have confirmed the planning of PC-3 and PC-4 laboratories at the NSP by a recent search under The Freedom of Information Act, after we were denied access to virtually all planning documents by Mr Frank van Schagen, CEO of the NSP.
• We believe the public has the right to know about this type of research being conducted in physical containment laboratories. We are concerned that this information concerning high-risk laboratories has been withheld from the community, by the builders of the IMB and NSP.
• Genetic manipulated plant and animal material will be routinely transported from IMB to NSP through our suburban streets. This is

not satisfactory regardless of safety protocols, and is another strong argument for co- location of IMB and NSP on the same greenfield site.

LACK OF PUBLIC CONSULTATION

•  
• As residents of the local area, we believe we have been treated disrespectfully by UQ and CSIRO, by a complete lack of public consultation over the IMB.
•  
• The IMB project was announced in the press around mid-1999, as a fait accompli, without any prior warning to the community or its representatives.
•  
• Community consultation only commenced in September 1999, when a local resident, Mr John Massey, repeatedly insisted on a meeting with UQ staff to discuss the IMB. Since then, a couple of meetings have been held. The level of discussion at these meetings has been such that they have seemed like undergraduate lectures on the benefits of GMO research.
•  
• Planning of the IMB is at such an advanced stage, that it is hard for the community to envisage that its opinions regarding the IMB could have any effect whatsoever on its implementation.
•  
• We can only assume that this is what the UQ and CSIRO have intended all along i.e. they have no concept of their role as members of the community, they are indifferent to the self-image they create in the community, and their level of environmental citizenship is extremely poor.
•  
• The UQ and CSIRO have attempted to fast-track the building of IMB, by withholding important information about the size, the location, and the nature of its research and associated risks, from the community. It is only now, as the residents of St.Lucia and Indooroopilly are becoming aware of the IMB, the true public consultation can start to take place.
•  
• We are told that construction is to commence in December. More time is required to allow more public debate and discussion about IMB and its location, before building should be allowed to commence.

RECOMMENDATIONS

1. We request a three-year moratorium on the commencement of building of the IMB, to allow time for full public discussion and debate. This should apply to all major buildings on UQ campus.
2. All buildings on UQ land and CSIRO land should automatically and compulsorily be legally subject to the Draft City Plan1999, and the Integrated Planning Act 1997. There should be no exemptions, particularly for buildings of these massive dimensions.
3. Biohazard physical containment laboratories (PC-1 to PC-4) should not be allowed in residential areas.
4. Best practice should involve the placement of IMB in a greenfield site, as exists at Pinjarra Hills and Samford, and co-location with its satellite laboratory, the NSP on the same site.
5. If the IMB is to be built at the UQ campus, it should be moved away from residential areas on Carmody Rd, and placed on the north and eastern aspects of the campus, where there are acres of vacant land.
6. The circumferential green buffer zone around the UQ should be preserved, and the IMB should not be allowed to encroach upon this.
7. Parking should be provided for staff and students attending the IMB. Overflow parking from UQ should not be allowed to congest and to lower the amenity of surrounding residential streets.
8. Advance planning and funding of the IMB should not be allowed to proceed without completion and publicising of Environmental Impact Studies, Assessment of Impact Studies, Traffic Studies and Risk Management Reports.
9. The height of buildings in the IMB should be restricted to three stories, to be consistent with detached residential housing across the road.
10. CSIRO and UQ staff must henceforth immediately inform the community if our local possums or fruit bats are contaminated with GMO’s from the laboratories, before they are trapped and killed.
11. Members of the community should be appointed to Institutional Biosafety Committees of the IMB and NSP, to improve their accountability, and to improve communication between the Biosciences and the community.
12. Traffic studies need to be performed and publicised before the IMB is built. If these studies were to show that local district access roads were already carrying in excess of their allowed 10,000 vehicles per day, then this would be further argument for not building the IMB at St.Lucia, but rather moving it to Pinjarra Hills, on the outskirts of Brisbane. We presume this is why traffic studies have not so far been performed.

CONCLUSION

We believe that the CSIRO should not receive $50 million dollars from

the Federal Government, to build this over-sized commercial GMO

laboratory in a residential area. The future of GMO research is

doubtful in the longer-term. There are far safer alternative greenfield

sites on the outskirts of Brisbane, more suited to this kind of research.

Yours sincerely,

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