Women Speak Tasmania

Safety, Privacy and Dignity Concerns – All-gender Toilets and Changerooms at the Community Recreation Hub – Letter to Nick Duigan

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Letter sent to Minister for Sport Nick Duigan on 30.03.26

Dear Minister Duigan,

Re: Safety, privacy and dignity concerns – All-gender toilets and changerooms at the Northern Suburbs Community Recreation Hub, Mowbray

I write on behalf of Women Speak Tasmania regarding the recently opened Northern Suburbs Community Recreation Hub in Mowbray. We commend the Tasmanian Government for its significant investment in this $62 million community sporting and recreation facility, which will serve families, children, sports teams and the broader northern Launceston community.

We are concerned, however, that the Hub has been designed with all toilets and changerooms as fully gender-neutral, with no single-sex options provided for women, men, or disabled users. The facility features individual, self-contained single-occupant cubicles, yet the complete removal of sex-based segregation removes an important safeguard in a high-use recreational environment.

We note that the National Construction Code 2025 introduces an optional Deemed-to-Satisfy pathway for all-gender sanitary facilities. It does not require buildings to eliminate separate male and female provision. The code continues to allow — and in most cases expects — single-sex facilities, with all-gender options permitted only as a limited voluntary substitution.

Evidence from comparable leisure and sports settings, particularly in the United Kingdom, shows that single-sex provision remains the safer and more dignified option for women and girls:

  • A 2017–2018 Freedom of Information analysis recorded 134 complaints of sexual assaults, voyeurism or harassment in changing rooms at pools and leisure centres. Approximately 90% (120 cases) occurred in unisex or mixed-sex facilities, compared with only 14 in single-sex spaces.
  • The December 2025 Women’s Rights Network FOI report documented 16 rapes, 80 sexual assaults and 65 voyeurism incidents across 257 leisure centres, with the large majority occurring in mixed-sex changing areas.

In a busy venue such as the Northern Hub — serving netball courts, multi-purpose sports, indoor climbing, community events and after-school programs — women and girls report feeling less comfortable challenging suspicious behaviour or emerging from a cubicle to find someone of the opposite sex waiting. Providing single-sex cubicles alongside all-gender options would give everyone a genuine choice without excluding any group.

We therefore respectfully request that you, as the Minister for Sport, direct or support a review of the current all-gender-only policy at the Hub. We ask that a reasonable proportion of the cubicles be designated as single-sex (female-only and male-only) so that women and girls have access to safe, private facilities.

We also recommend transparent, ongoing monitoring and public reporting of any voyeurism, sexual incidents or privacy complaints at the facility.

We have written to Launceston City Council on the same matter and would welcome the opportunity to meet with you or your office to discuss practical solutions that balance inclusion with the safety, privacy and dignity of all users.

Thank you for your attention to this important community issue. We look forward to your response.

Yours sincerely,

Dr. Elizabeth Caballero

Retired General Practitioner

Women Speak Tasmania

References 

Follow-up email sent to Minister for Sport Nick Duigan on 13.04.26

Dear Minister Duigan,

I am writing to follow up on my previous correspondence regarding the design of the Northern Suburbs Community Recreation Hub in Mowbray, in particular the absence of any single-sex toilets or changerooms.

To date, I have not received a response.

Given that this is a significant, publicly funded community facility used by families, schools, and children, I am concerned that this matter has not been acknowledged.

I have since received a response from the office of Michael Ferguson, which confirms that the decision to implement exclusively all-gender facilities was a design choice, not a requirement of the National Construction Code.

This raises a straightforward policy question: why were female-only and male-only facilities not retained alongside all-gender options?

I would appreciate a response addressing:

  • Who approved the removal of single-sex facilities in this project
  • What safeguarding or risk assessment informed this design decision
  • Whether the Government will consider a review to ensure sex-based provision is available

I would also welcome the opportunity to meet with you or your office to discuss this matter further.

Given the level of public interest and the importance of this issue to families in the community, I would appreciate a response at your earliest convenience.

Kind regards,

Dr. Elizabeth Caballero

Retired General Practitioner

President | Women Speak Tasmania

This follows an email exchange with Michael McGregor, Senior Adviser to Minister Duigan, following our phone discussion on 15 April 2026

Letter from Minister for Sport, Nick Duigan, on 22.04.26

Follow-up email sent to Minister for Sport Nick Duigan on 25.04.26

Dear Minister Duigan,

Thank you for your letter of 22 April regarding the Northern Suburbs Community Recreation Hub and for outlining the CPTED principles underpinning the facility’s design.

I appreciate the Department’s focus on passive surveillance, visibility, and the reduction of concealed spaces as important safety measures within public facilities.

However, my central concern remains unresolved: why were female-only and male-only facilities not retained alongside all-gender options?

Architectural visibility and passive surveillance are not equivalent to sex-based safeguarding, and they address different dimensions of safety.

While CPTED principles aim to reduce opportunities for misconduct through environmental design, they do not fully address the separate considerations of privacy, dignity, psychological safety, and the importance of clear social boundaries in intimate spaces such as toilets and changerooms.

Indeed, CPTED literature itself frequently refers to concepts such as territorial reinforcement, defensible space, user confidence, and perceived safety. People generally feel safer where behavioural expectations and social boundaries are clear and easily understood.

For many women and girls, female-only spaces provide those clear social and psychological boundaries. This is particularly relevant in sporting and recreational environments used by schools, families, and children.

For this reason, it remains unclear why the adoption of CPTED principles required the removal of female-only facilities rather than allowing both approaches to coexist.

I also note that my earlier correspondence did not receive a direct response regarding:

  • who approved the removal of sex-based facilities;
  • whether any formal safeguarding assessment regarding women and girls was undertaken;
  • whether female sporting groups or community users were consulted;
  • and whether the Government would consider reviewing the current arrangement over time.

Additionally, I note advice from your office that Stage 3 of the Hub may include gender-specific facilities due to the scale and crowd capacity of the development. This appears to acknowledge that sex-specific provision continues to serve an important function in some public settings, and I would appreciate clarification as to why a different approach was adopted for the existing facility.

I appreciate your engagement on this matter and would welcome further clarification on the outstanding questions above.

Kind regards,

Dr. Elizabeth Caballero

Retired General Practitioner

President | Women Speak Tasmania

Second follow-up email sent to Minister for Sport Nick Duigan on 03.05.26

Dear Minister Duigan,

I am following up on my correspondence of 25 April, which I understand has not yet received a response.

In addition, I wish to seek clarification regarding statements made in your correspondence concerning the Northern Suburbs Community Recreation Hub.

In a letter sent to a local mother, you stated:

“Within the gymnastics area of the Hub, there are designated male and female change rooms…”

Following this statement, I revisited the facility on the 1st May to confirm the current arrangement. However, I was unable to identify designated male and female change rooms within the gymnastics area.

Could you please clarify:

  • whether designated male and female change rooms currently exist within the gymnastics section of the Hub;
  • where these facilities are located;
  • whether the facility layout has changed since opening;
  • or whether the statement referred to another arrangement.

This point is significant because the existence of sex-specific facilities has formed part of the public reassurance being provided to concerned parents and community members regarding privacy and safeguarding arrangements.

I would also appreciate a response to the outstanding questions raised in my previous correspondence of 25 April regarding:

  • approval of the removal of sex-based facilities;
  • safeguarding assessments;
  • consultation with female sporting groups;
  • and any future review of the current arrangement.

Given the ongoing public discussion surrounding these facilities, accurate public information is important.

Kind regards,

Dr. Elizabeth Caballero

Retired General Practitioner

President | Women Speak Tasmania

Letter from Minister for Sport, Nick Duigan, on 18.05.26