3 | Key observations and concerns Hotels are intended as short-term accommodation options. They are not designed to be used for lengthy periods of detention, and are not appropriate for this purpose.43 For this reason, the Commission reiterates its previous conclusion that hotel APODs should only be used in exceptional circumstances and for the shortest possible time. They should not be used as long-term places of detention under any circumstances. In drawing this conclusion, the Commission acknowledges the challenges involved with finding appropriate low-security accommodation for the significant number of vulnerable people who were transferred to Australia at short notice as part of the Medevac cohort, as well as the significant impact of the COVID-19 pandemic. The use of hotel APODs in Brisbane and Melbourne may have originally been intended as a short-term measure, and it would not have been known initially how long people would be detained at these locations. However, while these challenges are recognised, they do not detract from the conclusion that hotel APODs are not suitable for use as places of detention for lengthy periods of time. Hotels should only be used as Alternative Places of Detention in exceptional circumstances and for the shortest possible time. RECOMMENDATION 1: The Department should ensure that hotels are only used as Alternative Places of Detention in exceptional circumstances and for the shortest possible time. 20 3.2 Physical conditions of detention (a) Accommodation While the structure and layout of each hotel APOD facility is different, the key similarity is that they are functioning hotels. This is reflected in the physical conditions of the accommodation itself, which were reasonable in the facilities that were inspected. Indeed, the Brisbane APOD continues to function simultaneously as a hotel that is open to the public, with only specific floors being used for the purposes of detention. At the time of writing, a standard one-bedroom apartment at the Brisbane APOD could be booked online from approximately $160 per night. The particular challenges posed by dual-use facilities was highlighted by the fire that occurred at the Melbourne APOD on 23 December 2021, which caused significant damage to the property. Individuals who were detained at the Melbourne APOD at the time described how everybody else (including hotel staff and travellers returning to Australia who were subject to COVID-19 pandemicrelated hotel quarantine) was evacuated from the hotel, but detainees were only evacuated to Level 1 and were not escorted from the building itself. This was despite it being reported that a number of detainees were asthmatic, and that one detainee subsequently ended up being hospitalised for smoke inhalation. The Commonwealth Ombudsman has previously observed following a visit to the Melbourne APOD that ‘knowledge of correct emergency evacuation procedures was lacking’. The Commission concurs in the recommendation made by the Commonwealth Ombudsman that the Department ‘should ensure appropriate emergency