2 | Background and may include hospitals, aged care facilities, or mental health facilities. APODs have been used in Australia for more than twenty years, and ‘were originally conceived as a more sensitive alternative for vulnerable people with needs that immigration detention centres couldn’t accommodate’.20 However, in recent times ‘a practice has also emerged for hotels to be used as APODs to house people where this does not stem from a specific need of the person being held, but for other reasons, such as relieving overcrowding in other immigration detention facilities’.21 There is no complete list of all previously designated hotel APOD facilities (and the dates during which they were operational),22 nor an indication of the total number of individuals who have been held in APODs since their establishment.23 An interactive map developed by researchers from Macquarie University and UNSW’s Kaldor Centre for International Refugee Law has attempted to identify all known former hotel APODs that have been used across Australia between December 2002 and December 2022.24 The Commission has previously inspected a number of hotel APODs, including one in Brisbane in 2018, and hotel APODs in both Brisbane (Kangaroo Point Central Hotel and Apartments) and Melbourne (Mantra Bell City) in the second half of 2019.25 It is known that there were, as at 31 July 2022, 77 hotels approved as APODs under the Migration Act, with seven in operation.26 These included the Meriton Suites Hotel in Brisbane and the Park Hotel in Melbourne that were the focus of the inspections covered in this report. 10 2.3 Methodology The Commission undertook inspection visits to Brisbane and Melbourne in May and June 2022 for the purpose of examining the use of hotel APODs. The original detention visit requests to ABF encompassed visits to both the Meriton Suites APOD and Quality Inn APOD in Brisbane, and the Park Hotel APOD in Melbourne (Melbourne APOD). The inspection team from the Commission conducted inspections of the physical conditions of detention at the Meriton Suites APOD in Brisbane (Brisbane APOD) but did not physically inspect either the Quality Inn APOD or the Melbourne APOD as both facilities were being used exclusively for COVID-19 quarantine purposes at the relevant times. Before undertaking the inspection visits, all relevant staff at the Commission undertook training in Responding to Refugee-Related Trauma and Distress, delivered by the NSW Service for the Treatment and Rehabilitation of Torture and Trauma Survivors (STARTTS). In both Brisbane and Melbourne, the inspection teams met with representatives from the Department, ABF, and contracted detention services providers, Serco and International Health and Medical Services (IHMS). The inspection teams held interviews with sixteen people who were detained at the Brisbane APOD at the time of the inspection visit, as well as conducting a series of interviews with individuals who had previously been detained in hotel APODs in either Brisbane or Melbourne. Meetings were also held with a