CHAPTER 7
JANUARY TO DECEMBER 1995

30 JANUARY 1995 – SOCOG LETTER TO THE PREMIER OF SOUTH AUSTRALIA

By letter dated 30 January 1995, Gary Pemberton, the Executive President of SOCOG, wrote to then Premier Dean Brown, seeking confirmation of the Government’s interest in participating in the 2000 Olympic Soccer Tournament. That letter listed the venues that had been included in the Host City Contract between SOCOG and the International Olympic Committee as:

The letter further stated that SOCOG, in consultation with FIFA and the Australian Soccer Federation, sought confirmation on a number of matters including:

"(a) The desire by your State to participate in the Olympic Games by hosting a number of matches in the Olympic Football competition;

(b) The provision of a venue that is acceptable to SOCOG, FIFA and ASF in all respects including the required minimum seating capacity (a summary of FIFA’s minimum requirements is attached;

(c) The provision of all necessary infrastructure at no cost to SOCOG to ensure the successful conduct of the Olympic competition including but not limited to – training sites, accommodation, security, local transport, medical services, etc;

(d) Cost of capital improvements to venues will not be met by SOCOG as any improvements undertaken represent a long-term investment for the local community and the sport of soccer in particular…"

The letter attached a one page document entitled "Football Stadia Minimum FIFA Requirements" that were stated to be drawn from a range of FIFA publications including regulations and laws of the game, "Technical Requirements and Guidelines for New Stadia June 1991" and "FIFA News".

"Each stadia to have minimum seated capacity 15,000 – no terraces or spectatorstanding areas.

Temporary grandstands and seating permissable [sic] provided strict safety and spectator comfort standards are met – FIFA must approve construction of such temporary stands."

Also attached was a one-page extract from "FIFA News" entitled "Authorisation of Temporary Stands in Stadia". It set out the conditions upon which the FIFA Executive Committee had resolved to permit the use of temporary stands on 27 October 1994.

On 21 February 1995, Premier Dean Brown responded, confirming Adelaide’s selection and advising that a venue would be provided that was acceptable to SOCOG, FIFA and Soccer Australia.

FEBRUARY 1995 - EARLY ESTIMATES OF COST OF HOSTING OLYMPIC SOCCER

On 11 February 1995, Mr Farrugia sent Mr Scott, then Chief Executive of the Office for Recreation, Sport and Racing, a letter about the costs of hosting matches in the 2000 Olympic Soccer Tournament. He estimated those costs as in the order of $349,700 and stated in his letter that he had made no allowance for CPI or travel between Sydney and Adelaide, that they were estimates only and were broadly based on the 1993 World Championships. However, Mr Farrugia’s letter then stated that "[a]s far as the Stadia requirements are concerned, the requirements of FIFA are self-explanatory."

On 16 February 1995, Mr Scott prepared a minute to Minister Oswald about the costs of hosting matches in the 2000 Olympic Soccer Tournament. He stated that he considered Mr Farrugia’s figure to be underestimated. He expressed his view that "a figure in the vicinity of $500,000 would be a more than ample budget for the men’s competition". The basis for Mr Scott’s estimate did not appear in the minute.

On 20 April 1995, the Budget Sub-committee approved the construction of a new eastern grandstand at a cost of $6.5 million to be sourced from the recurrent budget of the Office for Recreation, Sport and Racing.

The Crown Solicitor’s Office opened its first file in relation to the Hindmarsh Stadium redevelopment on 28 April 1995.

Shortly before, Mr George Forbes, Director of Capital Projects in the Office for Recreation, Sport and Racing, had correctly identified that:90

"[t]he term of the lease with the Hindmarsh and Woodville Council needs to be agreed, as a long term commitment will be essential." [emphasis supplied]]

On the same day that the Crown Solicitor’s Office opened its file, a Memorandum of Understanding between the Government and the Soccer Federation was executed.

In the first draft of the Memorandum of Understanding produced by the Crown Solicitor’s Office, two alternative mechanisms were postulated to protect the use of the stadium for soccer.

First, it was proposed that the Government would take a lease of the stadium and sublease it to the Soccer Federation. This was the same concept that had been raised in 1989,91 199092 and 1993.93

The second option was for the Soccer Federation to take a lease from the Council and for the Government to have the first right of refusal to take an assignment of the lease if the Soccer Federation sought to assign the lease during its term.

That concept, included in the Memorandum of Understanding by the Crown Solicitor’s Office after having been briefed for at most 48 hours, became the sole protection given to the Government to ensure the ongoing availability for soccer of the redeveloped Hindmarsh Stadium.

The concept of the Government taking over the lease was raised with the Soccer Federation, although not in writing. The Soccer Federation rejected it because it perceived it as requiring it to give up control of its traditional home. The Federation’s position in that regard had changed since 1989. The Government did not press the point.

28 APRIL 1995 - MEMORANDUM OF UNDERSTANDING WITH THE SOCCER FEDERATION

The April 1995 Memorandum of Understanding was not a binding legal document. It expressly stated in Clause 6.2 that:

"The parties acknowledge that this Memorandum of Understanding is entered into by all of them in good faith on the understanding that both the Minister and SASF are undertaking further feasibility studies regarding the development and finance of the Hindmarsh Developments in the manner contemplated by this Memorandum of Understanding."

The April 1995 Memorandum of Understanding required that the commitment to play matches at Hindmarsh Stadium be given by the NSL Clubs94 to the Soccer Federation in their licence agreements with the Soccer Federation.

The April 1995 Memorandum of Understanding defined the project as the works to be undertaken by the Soccer Federation at Hindmarsh at a maximum cost of $6.5 million and comprising:

• provision of the Soccer Federation’s new office, at that time already built;
• construction of a new eastern grandstand; and
• such other works as the Soccer Federation might propose and the Government accept.

The eastern grandstand was defined by reference to a Site Plan and a Concept Plan that comprised annexures to the April 1995 Memorandum of Understanding. The Site Plan denoted the eastern grandstand as a shaded rectangle on the eastern side of the stadium.  The Concept Plan was a line drawing of a soccer field surrounded by boxed areas designating seats within the triangle-shaped land bounded by Hindmarsh Place and Manton and Holden Streets. On the eastern side the words "new grandstand" were written. The areas designated for the eastern grandstand in the Site Plan and the Concept Plan were different shapes.

The April 1995 Memorandum of Understanding provided that the Soccer Federation and the Government would contribute to the cost of the redevelopment. Both would use their best endeavours to procure a contribution from the Council. The redevelopment would be financed by the Soccer Federation borrowing up to $6.5 million and the Government using "its good offices [to] facilitate"96 obtaining that finance to the extent that was appropriate and legal.

The April 1995 Memorandum of Understanding envisaged that the Soccer Federation would fund its contribution of up to 50 percent of the loan repayments by a $3 levy on all spectators using the new grandstand and $1 for each spectator using the existing western grandstand. The Government would pay any shortfall between the spectator levies and the loan repayments.

Although the Sydney 2000 Olympics was a key motivation for entering into the April 1995 Memorandum of Understanding, they were not referred to.

29 APRIL 1995 – MEMORANDUM OF UNDERSTANDING BETWEEN THE FEDERATION AND THE NSL CLUBS

The day after the April 1995 Memorandum of Understanding was executed, the Soccer Federation met with representatives of the two clubs which had NSL teams, Adelaide City and West Adelaide.  The two NSL Clubs approved the Memorandum of Understanding with the Government in principle except that they refused to be responsible for the $1 levy to be imposed upon spectators using the existing western grandstand.

1 MAY 1995 – COUNCIL OF CLUBS AUTHORISATION OF SOCCER FEDERATION LOAN

An extraordinary meeting of the Council of Clubs of the South Australian Soccer Federation was held on 1 May 1995 to consider the Government’s offer of an eastern grandstand.

The minutes97 record that the Chairman reported that the Government had recently called meetings with the Soccer Federation to discuss the building of a new eastern grandstand:

"…in line with the requirements for South Australia to host a section of the year 2000 Olympics, Soccer Tournament."

The proposal required the Soccer Federation to borrow and service a loan of $6.5 million under Government guarantee.

"It was noted that the Federation was not exposed to any risk and any shortfall in the repayments would be made by the State Government – without limitation.

It was also noted that as part of the Agreement, Government had agreed to include the new Office Administration area as part of the project and therefore the repay [sic] the borrowing’s [sic] of $200,000 to Adelaide City SC."

On 28 April 1995, Mr Oswald signed a submission seeking Cabinet approval of the April 1995 Memorandum of Understanding. The definition of the project included a new eastern grandstand but the size and layout of that grandstand was not defined in the Cabinet submission. Only one criterion was stated in the Cabinet submission by which the content of the project could be discerned and that was the cost of $6.5 million. Mr Oswald has submitted to this Examination that the project was not defined further in the Cabinet submission because it was intended that the content of the project would be the subject of detailed negotiations between the Government and the Soccer Federation within the cost ceiling set by Cabinet of $6.5 million.

On 1 May 1995, Cabinet considered that submission and gave approval for the Minister for Recreation, Sport and Racing, to conduct negotiations within the principles set out in the April 1995 Memorandum of Understanding. Cabinet also endorsed the Office for Recreation, Sport and Racing being given an additional budget appropriation equivalent to the Government’s contribution to the repayments of the $6.5 million loan that the Soccer Federation would take out.

"With the success of the Sydney Olympic 2000 bid Hindmarsh Stadium has been chosen as a venue to host Olympic Soccer fixtures provided the Hindmarsh stadium is upgraded to meet FIFA requirements [sic]. FIFA have indicated that matches can only be played on soccer specific stadiums, ie. Hindmarsh. This upgrading will not only guarantee that Adelaide will host a section of the Olympic Games but will continue to host major international soccer events prior to and after the Olympics."

Mr Oswald has submitted to this Examination that this paragraph in the Cabinet submission was based on "the best advice coming out of the Soccer Federation from its President and others that the upgrade proposal would secure the Olympic matches".

• There had been no commitment from SOCOG to use Hindmarsh Stadium. Certainly Hindmarsh Stadium would not be used if it did not meet the "minimum FIFA requirements" sent to the Premier on 30 January 1995.
• There is no written record of FIFA having stated that Olympic matches could only be played on soccer specific stadia. Indeed, on 30 January 1995, SOCOG had informed the Premier that the other venues proposed included Sydney Olympic Stadium, Sydney Football Stadium, Brisbane Suncorp Stadium, Melbourne Olympic Park and Parramatta Stadium, none of which were soccer specific. Further, the "minimum FIFA requirements" sent to the Premier on 30 January 1995 did not require that the stadium be soccer specific.
• The April 1995 Memorandum of Understanding and the Cabinet submission proposed the construction of a new eastern stand at a cost of $6.5 million. It was implicit in the Cabinet submission that this would meet minimum FIFA requirements for number of seats. A file note made by Mr Scott in November 1994 recorded that the Soccer Federation wanted a new eastern grandstand comprising 6,000 seats at a cost of $6.75 million which would increase the stadium's capacity to 10,000 seated. However, the FIFA minimum stadium requirements received in January 1995 required a minimum capacity of 15,000 seated. No reference was made in the Cabinet submission for the need for temporary seating at a further cost.

The submission also stated that the Soccer Federation was to contribute up to 50 percent of the repayment of the loan of $6.5 million over a 20 year period. That contribution was to be funded by a "premium" on ticket prices. The submission contained an estimate that approximately $300,000 to $400,000 could be achieved in each year. The submission stated:

"While the contribution by the Federation will vary dependent on the number of spectators utilising the Eastern and Western stands the figure proposed is considered to be achievable and reasonable. The figure represents a cost of $13 per spectator occupying the Eastern stand which is $3 in excess of the general admittance cost. This additional cost will provide funds to assist in loan repayments, etc. Similarly the cost per spectator occupying the Western stand will be $14 (an increase of $1) the additional cost of $1 will also contribute toward the repayment of the loan."

That calculation assumed that the new eastern stand would be fully occupied at each of the NSL matches. While the submission described the estimate as "achievable and reasonable", in fact, the Office for Recreation, Sport and Racing had not undertaken any independent or detailed analysis of those expectations.98  In fact, the serious reservations expressed in Mr Ellis’ Review were not taken into account.

The April 1995 Memorandum of Understanding envisaged that the Soccer Federation would fund its contribution to the financing of the project by a $3 levy on all spectators using the new grandstand and $1 for each spectator using the existing grandstand.

The Cabinet submission multiplied those levies by anticipated average attendances at NSL, international and Premier League matches. The anticipated averages involved either substantial increases in average attendances at each match or increases in the number of spectators attending matches choosing to sit in the grandstands. For example, the anticipated average spectators sitting in the new grandstand for NSL matches was 3,000. The average attendances at NSL matches in the preceding four seasons had been as shown below:

The Soccer Federation did not have historical records to show how many of those attending chose to sit in the existing stand but its capacity was 930 or roughly 20 percent of those attending. If attendances remained the same, about 75 percent of spectators would have to choose to pay extra to sit in the grandstands.

Mr Oswald’s view in evidence to this Examination was that when Cabinet approved further negotiations it was on the basis that the budget must be strictly limited to $6.5 million and that an eastern stand together with temporary seating on the northern and southern sides of the ground would be sufficient to secure matches in the 2000 Olympic Soccer Tournament. Mr Oswald has submitted to this Examination that:

"if negotiations failed to produce a project for the $6.5 million then all bets were off and we would have had to withdraw our commitment to the Games."

"Premier Dean Brown today announced a $6.5 million upgrade of Hindmarsh Stadium to bring the venue up to international standard.

Mr Brown said the upgrade was essential to ensure a world-class stadium in preparation for Olympic 2000 preliminary matches which will be played in Adelaide."

On 4 May 1995, an article "$6.5m grandstand for Hindmarsh" was published in The Advertiser.  It stated that:

"The announcement was welcomed by Adelaide City, its NSL counterpart West Adelaide and the SASF, which highlighted further plans for upgrading facilities.

The federation’s Chairman, Mr Charlie Caruso, said his personal aim was to transform the stadium by spending about $30 million to create a stadium for 25,000 seated spectators."

After the April 1995 Memorandum of Understanding had been approved by Cabinet, Mr Scott, the Chief Executive of the Office for Recreation, Sport and Racing, set up four committees, each with representatives from the organisations shown below:

The set up of those committees was defined in a letter dated 18 May 1995 sent to the Soccer Federation by Mr Scott. Although it described the function of each committee, it did not specify how decisions would be made. It stated that the committee structure would "ensure equal representation by both Government and the Federation" [emphasis supplied]

On 20 July 1995, the first meeting of the executive committee for the redevelopment of the Hindmarsh Soccer Stadium was held.

The minutes of that meeting record that it was intended that Department for Building Managementshould have a significant role in the project.99

"Judy Freeman then outlined DBM’s possible role in the project, describing the Department as a risk manager for the Government, assisting the project to meet the desired brief to program as well as to budget.

…

Judy advised that she would prefer DBM to have a significant involvement in this project rather than smaller, advisory role."

"It was agreed that a meeting be scheduled with representatives from Recreation, Sport and Racing, SA Soccer Federation, and Department for Building Management in order to prepare the design brief."

A design brief had been prepared by the Office for Recreation, Sport and Racing by the time of that meeting but it was recognised at the meeting to be inadequate.

• An "executive committee" comprising the Assistant Crown Solicitor100 and the President101 and General Manager102 of the Soccer Federation and the Chief Executive103 and the Director of Capital Projects104 of the Office for Recreation, Sport and Racing.
• A "marketing sub-committee" comprising one representative from the Office for Recreation,Sport and Racing105 and one from the Soccer Federation.106
• A "finance sub-committee" consisting of the Director of Capital Projects of the Office for Recreation, Sport and Racing, the General Manager of the Soccer Federation, the Deputy Chair of Soccer Australia107 and a representative from the Department of Treasury and Finance.108
• A "project design development sub-committee" comprising the Director of Capital Projects of the Office for Recreation, Sport and Racing, the General Manager of the Soccer Federation and two representatives from the Department for Building Management.109

"Michael Scott informed that the Sydney Organising Committee for the Olympic Games would be a valuable resource subsequent to the completion of the design brief."

This statement suggests that the Committee recognised the importance of consulting SOCOG in developing the design brief for the project so as to meet FIFA/SOCOG requirements.

Mr Oswald gave evidence to this Examination that the Soccer Federation sought to use comments about temporary stands made by FIFA as a reason to expand the scope of the development but he had insisted on the project remaining limited to one grandstand within the budget of $6.5 million. He had been asked to approve additional expenditure so that no temporary stands, of the type used during the Grand Prix, would be necessary. Mr Oswald refused. His departmental staff received informal indications from SOCOG that that would be sufficient.

1 SEPTEMBER 1995 - APPOINTMENT OF DEPARTMENT FOR BUILDING MANAGEMENT AS PROJECT MANAGER

On 1 September 1995, the Department for Building Management was appointed as project manager for the Hindmarsh Stadium Redevelopment project. An agreement for the Department’s role in the proposed construction of a new eastern grandstand with undercover seating for 5,000 was recorded in an exchange of letters between the Office for Recreation, Sport and Racing and the Department for Building Management.

4 SEPTEMBER 1995 - DEPARTMENT FOR BUILDING MANAGEMENT PROJECT BRIEF

The Department for Building Management prepared a "consultancy brief" dated 4 September 1995, which described in note form the content of the new eastern grandstand. That brief specified that the seating in the new grandstand should meet FIFA guidelines but it did not mention that the pitch had to be upgraded for the stadium to comply with FIFA guidelines.

20 SEPTEMBER 1995 - TENDER PROCESS FOR APPOINTMENT OF PRIMARY CONSULTANT

By letter dated 20 September 1995, the Soccer Federation invited six firms of architects to make  submissions for the position of primary consultant to provide architectural and engineering services.

The letter was prepared by the Department for Building Management. It included the following:110

"Role of the Department for Building Management

DBM will provide project and cost management services for both consultancy stages of the project.

The DBM role, coordinated by the DBM project manager, will include project overview, support and advice to the project team on Government policy and procedures, facilitation of project approvals and engagements, provision of the tendering service and contract administration as Superintendent’s Representative. Formal submission of the project for planning approval and certification under the Development Act will be by the project manager based on information provided by the primary consultant.

DBM cost management service will include budgeting, costing, progress payments processing and the input of data into the contract reporting system.

DBM will be responsible for the printing of the tender documents and for calling tenders."

The letter inviting tender submissions included the following specification of work:111

"It is intended that consultancy services be procured in two stages.

The initial stage will consist of the following services:-.

• preparation of a comprehensive brief of requirements;
• undertaking of feasibility investigations;
• preparation of preliminary concepts;
• provision of a recommended proposal.

The DBM cost manager will prepare notional estimates and will assess the estimates against the budget.

The remaining stage will consist of primary consultancy services from sketch design through to contract administration."

The requirement of the "feasibility investigations" was not specified in more detail either in that letter or in any later document or instruction to the primary consultant ultimately engaged.

Engagement of the primary consultant beyond the initial design stage was not guaranteed:112

"It should be noted that an engagement as primary consultant for the initial stage may not necessarily indicate continued engagement of the same primary consultant for the remaining stage."

A notional budget for the project, including professional fees, was stated as $6.2 million.  Of the $6.5 million approved by Cabinet in May 1995, $300,000 was for works already undertaken to the Soccer Federation’s office administration facilities.

Tenders were received from six architectural firms. Representatives of the Soccer Federation, the Office for Recreation, Sport and Racing and the Department for Building Management interviewed three short listed architectural firms.

The architectural firms visited the site before making their submissions. In the course of Woods Bagot’s visit, Mr Andrew Ford, the Adelaide principal and a partner of Woods Bagot, made a note which read "Stage I - another $10 mill coming .? masterplan".114  In his evidence to this Examination, Mr Ford said that someone, maybe Mr Jeff Browne, Senior Project Manager in the Department of Building Management, must have made the point to him that the development was part of an ongoing development program. He did not recall anyone suggesting that the Government had already given a commitment to spend that money.

Woods Bagot were very conscious of the fact that the $6.2 million budget covered work which had to fit into the longer term needs for the site. In their tender submission they said:115

"This project offers a number of site challenges. The compact nature of the grounds, the need for continuous operation, the importance of maximising the value of the existing facilities, provision of the new grandstand and ensuring future opportunities are ‘protected’ in the master planning are all critical. Further, the risk to the owners and operators should be minimised.

Strategic master planning is therefore a vital factor in this project. The site opportunities and constraints will be carefully evaluated. Alternative design solutions will be prepared and carefully assessed to ensure that the best solution meets key criteria, including value for money, providing opportunities for future development, the best use of existing facilities and maximising the opportunity to continue operations during construction."

Woods Bagot’s submission also stated:116

"Client Support

Woods Bagot is keen to support SASF and we would like to explore corporate options such as sponsorship and other ways in which we can assist the SASF in achieving its objectives as part of our ongoing relationship." [original emphasis]

After Woods Bagot’s submission was received, the Soccer Federation sent a letter to the Chief Executive of the Office for Recreation, Sport and Racing that contained the following passage:117

"It should be noted that as part of Woods Bagot original submission they offered some form of sponsorship to the Soccer Federation and we advise that we have submitted proposals to this Company and intend to follow up on these."

Woods Bagot were approached by the Chairman of the Soccer Federation seeking confirmation of their sponsorship offer.118

Mr Ford confirmed that Woods Bagot intended to offer sponsorship if Woods Bagot were the successful tenderer. The Chairman of the Soccer Federation, Mr Caruso, then asked how much Woods Bagot were offering and how much would Woods Bagot be prepared to cut off their fees because other tenderers might also be prepared to do the same. Mr Ford objected to sponsorship being part of the tendering process. It was not part of the offer to tender and Mr Ford feared that if the Soccer Federation sought that from them, they would also seek it from other tenderers, leading to a "Dutch auction". Mr Ford informed DBM about his objections and DBM ensured that the integrity of the tender process for the primary consultant was maintained. Ultimately, even though their submission invited it, Woods Bagot did not provide the Soccer Federation with any sponsorship either as part of the tender process for the primary consultant or more generally for the redevelopment project.

Woods Bagot’s tender submission also contained the following passage:119

"Andrew Ford and Peter Hoare have also recently been involved in several preliminary studies of the Hindmarsh Soccer Stadium for SASF in exploring options for new grandstands."

Mr Ford and Mr Peter Hoare of Woods Bagot had informal discussions with Mr Avory about the plans to either redevelop Hindmarsh Stadium or relocate to a new stadium north of the city that were the subject of the 1989 Feasibility Study. Woods Bagot were not paid for their involvement and neither Mr Ford nor Mr Hoare regarded Woods Bagot as retained by the Soccer Federation.

On 30 October 1995, the Department for Building Management was abolished and Services SA established. The employees and functions of the Department were transferred to Services SA.

Woods Bagot were selected as primary consultant because they were the preferred candidate of the Soccer Federation. The Soccer Federation expressed a preference for Woods Bagot, noting that the Soccer Federation would pursue the possibility of sponsorship from Woods Bagot.120  The Office for Recreation, Sport and Racing supported the appointment of Woods Bagot.

Woods Bagot were not the cheapest of the tenderers. Services SA had assessed the cheapest tenderer as having the necessary skills for the project, even if not the same skill level as Woods Bagot. Services SA considered Woods Bagots’ proposal offered the most appropriate level of services for a market competitive fee.

On 8 November 1995, the Soccer Federation sent Woods Bagot a letter formally offering Woods Bagot the contract as primary consultant.122  The scope of the retainer was indicated in the letter’s heading - "Hindmarsh Soccer Stadium New Eastern Grandstand" but not otherwise. That letter stated that it enclosed a formal contract document but it did not. That contract was not sent until 9 January 1996. The contract then sent, defined the scope of Woods Bagot’s retainer by reference to Woods Bagot’s own submission. It was not executed until February 1996.

Woods Bagot did not consider themselves constrained by the previous project definitions. Those project definitions did not precisely state the extent to which compliance with FIFA guidelines was necessary.

During the selection process, by Services SA letter dated 29 September 1995, Woods Bagot had been provided with a copy of FIFA’s "Technical Recommendations for the Construction of New Stadia". During a site visit Woods Bagot were told that a thorough understanding of those requirements was necessary. The extent to which adherence to those standards was necessary was not specified. Woods Bagot were not instructed as to the criteria they were to apply in determining which of the FIFA standards were mandatory and which optional.

During a series of design meetings held from December 1995, Woods Bagot tabled a draft "FIFA Requirements Comparison Schedule" to be built up progressively. The minutes of these meetings record that "Field Size" was a primary issue as "Field and boundary clearances is [sic] currently below FIFA requirements for International matches".123

Between their appointment in November 1995 and March 1996, Woods Bagot developed a series of options for the first stage of the redevelopment. The design process adopted by Woods Bagot involved taking very detailed instructions from the Soccer Federation. Woods Bagot regarded the Soccer Federation as the client.

Woods Bagot’s design philosophy was based on an approach taught to them by an American consultant. That philosophy required an examination with the client of how the specific project being undertaken would fit with the future desires of the client and possible further development of the site.  That philosophy reflected common sense in that duplication and waste would occur if the development had to be demolished or excessively altered when later developments were undertaken. The development might close off options for future development.

When Woods Bagot commenced preparation of their own "Functional Design Brief",124 they defined the project objectives as:125

"Generally, the objective of this project as funded is the design and development of a new eastern grandstand for the Hindmarsh Stadium.

In particular, there is a requirement to achieve the best value for money for the various stakeholders involved. These stakeholders are:-

South Australian Soccer Federation

City of Hindmarsh and Woodville (owners of the site)

Government of South Australia (provider of finance and represented by Office for Recreation, Sport and Racing)

1. The National League Clubs - Adelaide City and West Adelaide (currently located on site in western grandstand)

2. All the Federation clubs

3. Soccer Australia (National body)

Due to the long term implication of this project to the first 3 stakeholders in particular, the agreed methodology is to thoroughly investigate and analyse the current and future needs and objectives of the stakeholders and develop a flexible master plan for the full long term development of the facilities on this site. From this viewpoint, it is intended to determine the most appropriate use of the current available funding to agree a scope and brief for the first stage.

Detailed objectives within the above scenario are:-

• provide the most value for the least cost at all times
• provide the best possible amenity for all of the spectators and other users
• provide as many covered seats as possible
• provide a world class facility to promote soccer and South Australia throughout Australia and internationally
• to add value and financial return to all of the stakeholders
• to optimise the flexibility of the stadium to capitalise on alternative events and uses."

Woods Bagot prepared rough sketch plans of the main playing pitch and the possible locations of the grandstands by reference to that pitch. Woods Bagot formed the opinion that if the pitch was to be enlarged to accommodate the grass surround required by FIFA and there was to be a stand on each side of that pitch with total seating capacity of 20,000, the stadium site would have to be expanded. That would require the closure of Hindmarsh Place near the south western corner of the stadium.  That in turn would necessitate acquisition of the properties fronting Hindmarsh Place that would then have no street access or acquisition of other land from which to provide the street access.

Woods Bagot spoke to the Council about this issue. Coincidentally, the Council had already been considering acquiring a number of the properties adjacent to the stadium site and closing Hindmarsh Place. On 11 December 1995, the Council sent Woods Bagot a plan of the land surrounding the stadium showing certificate of title references, land owned by the Council and land currently for sale.

Woods Bagot’s preliminary sketches identified that if the playing pitch was to be expanded, the stadium site needed to be extended to the south into Hindmarsh Place and east over the land then occupied by the Hindmarsh Bowling Club.

Woods Bagot endeavoured to identify the mix of revenue at the stadium and the effect that different mixes of facilities (eg spectator seating versus corporate boxes) would have on revenue. They were based solely on incomplete historical figures obtained from the Soccer Federation. Their inquiries were not finalised.

Woods Bagot formed the view from the time of their submission that the main grandstand at the Hindmarsh site should be on the western rather than the eastern side. As part of the client briefing.process with the Soccer Federation, they prepared a series of options. Woods Bagot identified a number of options for the future development of grandstands on all four sides of the pitch. The options involved variations in the configuration of the grandstands, such as whether a grandstand would be single or multiple-tiered or would extend over Hindmarsh Place or the Bowling Club. Woods Bagot developed a number of combinations of those options that Woods Bagot considered were feasible. They recorded thirteen of those combinations in a compilation document that compared the different ultimate total capacities. Those capacities ranged between 15,000 and 22,965 seats.

Each combination envisaged that one of the grandstands on either the eastern or the western side of the pitch would be larger than the others. Woods Bagot distilled from the thirteen combinations of different configurations, seven options for the development of the first grandstand, referred to as "Stage 1".

Most of the options were variations on the development of a new eastern stand. The third, Option C, was a redevelopment of the existing western stand. Option G was a new two tier stand on the southern side.

Option C was Woods Bagot’s preferred option. For that option to remain within the $6.2 million budget, it would have only 3,730 seats, not 5,000 as envisaged by the May 1995 Cabinet submission.  To achieve the target of 5,000 seats, it was necessary to extend the western stand to the north and south.

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