Section 38 - Application for the Conditional Grant of a Liquor Store Licence

Premises Name: Wanneroo Cellars Applicant: Parkview Enterprises Pty Ltd Location: Tenancy 6, 957 Wanneroo Road, Wanneroo WA 6065 Licence Type: Liquor Store Licence

Prepared by:

Office 2, 48 Kishorn Road, Applecross WA 6153 Ph. 08 9316 8699 Fax 08 9316 9699 [email protected] www.hospitalitytotalservices.com.au

This Submission is not to be copied in part or its entirety by any person without prior written consent from Hospitality Total Services (Aus.) Pty Ltd. Failure to do so may result in legal action.

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Table of Contents

1. Introduction 3

2. The Applicant 6

3. Location and Locality 9

4. Venue and Operation 25

5. Legislative Framework – Liquor Control Act 1988 40

6. Public Interest 44

7. Section 38 (4) (a) of the Act – Harm or Ill-health 61

8. Applied Research Section 38 (4) (a) of the Act – Harm or Ill-health 64

9. Community Consultation 73

10. Section 38 (4) (b) of the Act – Impact on Amenity 77

11 Section 38 (4) (c) of the Act – Offence, Annoyance, Disturbance or Inconvenience 91

12. Summary 95

13. Advertising 96

14 Attachments 96

15 Figures 97

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1. Introduction 1.1 Parkview Enterprises Pty Ltd (the Applicant) is seeking approval from the Director of Liquor Licensing at the Department of Local Government, Sport and Cultural Industries of Western Australia, herein referred to as DLGSC (formerly the Department of Racing Gaming and Liquor or DRGL) for the conditional grant of a Liquor Store Licence.

1.2 This application relates to the premises to be known as Wanneroo Cellars, located at Tenancy 6, 957 Wanneroo Road, Wanneroo WA 6065.

1.3 The Liquor Control Act 1988 (the Act) defines a Liquor Store Licence in Section 3 as a licence granted under section 471 which states as follows;

Liquor store licence, effect of (1) Subject to this Act, during permitted hours the licensee of a liquor store licence is authorised to keep open the licensed premises and to sell packaged liquor on and from the premises to any person. (2) The licensee of a liquor store licence is authorised to supply liquor, by way of free sample — (a)for consumption on a part of the licensed premises approved for the purpose by the Director; or (b)for consumption off the premises. [Section 47 amended by No. 12 of 1998 s. 30.] [Heading deleted by No. 73 of 2006 s. 37.]

1.4 Hospitality Total Services (Aus) Pty Ltd (herein referred to HTS) has prepared this Public Interest Assessment (PIA) submission on behalf of the Applicant, addressing the primary and secondary objects of Section 52 and Section 383 and of the Act.

1.5 Section 38 subsection 2 of the Act outlines the matters that the Licensing Authority is to consider when deciding whether or not to grant a licence, stating; “An applicant who makes an application to which this subsection applies must satisfy the licensing authority that granting the application is in the public interest.”

1.6 The PIA Policy4 (last amended 11 January 2017) has been considered whilst preparing this submission and all documentation relating to this application has been submitted in accordance with Section 685 of the Act.

1.7 Mr Arthur Naoum is the Director of Parkview Enterprises Pty Ltd, and has significant experience in the retail liquor market in Western Australia over a period of some 30 years. Mr Naoum has successfully owned and operated liquor stores in the Perth metropolitan area including:  Cottesloe Cellars,  Cellarbrations at Duncraig,  Cellarbrations Morley,  Yokine Cellars, and  Hillary’s Cellars.

1 http://www.austlii.edu.au/au/legis/wa/consol_act/lca1988197/s47.html 2 http://www.austlii.edu.au/au/legis/wa/consol_act/lca1988197/s5.html 3 http://classic.austlii.edu.au/au/legis/wa/consol_act/lca1988197/s38.html 4 http://www.rgl.wa.gov.au/docs/default-source/rgl/publicinterestassessment.pdf?sfvrsn=8 5 http://www.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s68.html

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1.8 The primary consideration of the Applicant is to provide well-managed and controlled premises offering a contemporary range of products, by an independent operator who can cater to the requirements of consumers in the locality.

1.9 Harm Minimisation Strategies have been discussed in detail within this report, (Refer Point 7 - Section 38(4) Harm or Ill -health). Further as a crime prevention consideration, the premises will incorporate substantial CCTV both internally and externally covering all the entry and exit points in accordance with the Director of Liquor Licensing’s Policy on Security at Licensed Premises.

1.10 The experienced Applicant has genuinely considered the potential for undue harm and ill-health that may be caused by the use of alcohol, and will put into place a Harm Minimisation Plan (Attachment 1) to minimise any adverse effects to the locality, should this application be approved.

1.11 Along with the Harm Minimisation Plan and the public interest merits of this application, (subject to approval) the proposed liquor store will;  Provide a safe, local, convenient packaged liquor amenity to complement and create a convenient and independent option at the Retail Shopping Precinct at 957 Wanneroo Road as expected at a Neighbourhood Centre in the locality by consumers across the state.  Operate a liquor store (approx. 263m2) to offer a selection of products to cater to consumers in the locality and appropriate for inclusion in the diverse amenity available.  Provide the option of low-alcohol liquor products (beer, wine and cider) to promote the responsible consumption of liquor.  Offer wine tastings and product knowledge and information.  Provide a retail environment that supports local WA and Australia Producers of liquor, particularly smaller producers that are not stocked by the large retail chains that dominate the packaged liquor market in Australia and WA.  Offer personalised service through product order forms, so that customers can request products not easily available to them.  Provide a contemporary standard of packaged liquor amenity by an independent operator.  Implement and enforce a strict Harm Minimisation Plan in the interest of the public and to minimise any undue harm due to the misuse of liquor.  Aid in the proper development of the liquor industry and have a positive economic impact with the creation of new jobs, increased amenity and superior convenience for local residents and businesses.

1.12 The conditional grant of the Liquor Store Licence for Wanneroo Cellars will cater to the packaged liquor requirements of the residents and visitors to the Wanneroo locality, that wish to patronise an independent Liquor Store. The premises has Planning Approval for the Liquor Store use, issued by local council.

1.13 The proposed Liquor Store will provide an option for consumers travelling north on Wanneroo Road, and for those seeking an alternative to the large, national retail chains that currently dominate the packaged liquor market in the Wanneroo locality.

1.14 The proposed liquor store offer will add to the diversity in the Shopping Precinct that contains a range of commercial and retail amenity to local consumers and those resorting to the locality including (but not limited to):  Shining India,  Subway,  W Noodle and Sushi Restaurant,  Wanneroo Super Deli and Lunch Bar,  The Cheesecake Shop,

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 Party Mix Wanneroo,  Nando’s, and  Jetts Fitness.

1.15 The application is supported by the Consumer Survey results (Attachment 2), undertaken personally by Mr Naoum, who door knocked homes located in close proximity to the proposed Wanneroo Cellars and had the survey completed by local residents who are most likely to be impacted, and those resorting to the Retail Shopping Precinct at 957 Wanneroo Road.

1.16 To demonstrate a consumer requirement for the proposed liquor store, 256 Consumer Surveys were completed by members of the local community with 94.53% supporting the application in the public interest (Attachment 2). The word cloud generated by the consumer survey comments identified the following requirements of local consumers:

1.17 In addition to the Consumer Survey and Letters of Support, the Applicant has also reviewed the City of Wanneroo – Wanneroo Activity Centre Strategy6, with particular attention to Appendix 4 – Economic, Retail and Employment Strategy (Attachment 4) which states: “The Economic, Retail and Employment Strategy (ERE strategy) provides background economic analysis for consideration in the development of the Wanneroo Town Centre Planning Framework (the Framework). The Framework will establish a desired future state for the Wanneroo Town Centre (the Centre) that will guide long- term development for both residential and non-residential1 uses.

Improved place activation The Centre was assessed using the ‘six principles of economic place activation’3. There are opportunities to increase economic activation of the Centre by creating an interspersed network of origins and destinations within the Centre, and increasing the permeability of the Centre to the surrounding residential areas (i.e. increasing walkability). This will encourage visitors to experience other attractive offerings within the Centre and can be further encouraged by introducing an additional anchor tenant(s) in the north of the Centre, ideally with a unique offering that will increase diversity and active use hours within the Centre.

The Centre will inevitably mature as the surrounding population grows, presenting both new development and redevelopment opportunities. The City of Wanneroo (the City) therefore has the opportunity to reshape the Centre by applying the principles of economic activation to help create a centre that has high levels of economic activation and liveability.” The Applicant submits that the proposed Wanneroo Cellars, operated by a responsible Licensee, will meet the requirements of present and future populations, as outlined in the Strategy.

1.18 The landlord engaged an independent planning expert to provide an expert statement about the location of the liquor store (Attachment 15).

6 http://www.wanneroo.wa.gov.au/consultations/359-wanneroo-town-centre-activity-centre-plan-no-90

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1.19 The report from FLYT (commissioned by the Landlord of the Retail Shopping Precinct at 957 Wanneroo Road), states: “Flyt is familiar with the traffic issues at the Wanneroo Town Centre, having completed the transport assessment component of the Wanneroo town centre Activity centre Plan during a 6 month period in 2018. The transport assessment involved a review of public transport, walking, cycling, vehicle access and parking. The subject property is within the boundaries of the Wanneroo town Centre, and was formerly an ANZ bank.”

1.20 The report goes further to state that: “The proposed liquor store at tenancy 6, 957 Wanneroo Road, is more accessible from Wanneroo Road than either of the existing liquor stores in the eastern side of Wanneroo Road. This particularly evident in the weekday afternoon peak period between 3 and 6pm, when the dominant traffic flow direction is northbound, and many vehicles are heading home.

The western side of Wanneroo Road is colloquially the ‘go home side’. During the PM peak, when patrons are heading home, they will be predominantly accessing food, convenience goods and beverages for dinner.

Hasting Street carries a significantly lower volumes of traffic than either Dundebar Road or Conlan Avenue. In addition, vehicles accessing the proposed liquor store would not have to deviate as far away from Wanneroo Road as they would in order to access either of the existing liquor stores.” (Attachment 15).

1.21 The Applicant contends that approval of the application will aid in the proper development of the liquor industry in the state, provide an independent operation that is sorely lacking in the locality, support local producers and provide a convenient, packaged liquor amenity on the west side of Wanneroo Road.

1.22 Along with local producers, the store will also support (via sponsorship and/or donation) local sporting organisations, clubs and community groups with donations and sponsorship. Some of these groups have also provided written support for the Applicant, as a responsible and community minded operator, who supports growth and development in the locality for the benefit of all.

1.23 The liquor store will stock a range of products that are not readily available in the locality, to cater to the contemporary requirements of consumers in the locality, including a range of locally produced liquor products in the public interest.

1.24 The proposed liquor store (subject to approval) will be independently owned and operated; this will permit the Applicant the flexibility to supply a product range that caters to the specific needs of local consumers, supports local WA producers, as well as provide an independent alternative to the national chain liquor stores that monopolise the packaged liquor amenity in the locality (Attachment 3 – Letters of Support).

1.25 The Applicant and their representative undertook an extensive community consultation and liaised with locally elected representatives, residents and businesses, as well as local schools, aged care and health services in the locality, as well as the Liquor Enforcement Unit (LEU) and Mental Health Commission (MHC) to establish the public interest in the conditional grant of the application.

2. The Applicant 2.1 Mr Arthur Naoum is the Director of the Applicant Company Parkview Enterprises Pty Ltd. He is an experienced and reputable Licensee in Western Australia, and has completed the required MLP1 certification, which has been submitted with the other application documents.

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2.2 As stated previously in this PIA submission, Mr Naoum has been operating in the retail packaged liquor industry for more than 30 years, without being issued any known breaches or infringements, due to his responsible and considered style of operation, understanding of the areas in which the store is located, and consultation with the local community.

2.3 The addition of a liquor store located within the retail precinct at 957 Wanneroo Road has been one of the most common requests from local consumers and those persons who utilise the other, complimentary amenity at the Retail Shopping Precinct at 957 Wanneroo Road (Attachment 2).

2.4 Mr Naoum is a respected member in the retail liquor industry and WA business community, and is active in his engagement with local residents, stakeholders and authorities in the locality in which he intends to operate.

2.5 For example, Mr Naoum spent many days door knocking in the residential area immediately adjacent to the proposed Wanneroo Cellars, had local residents complete the Consumer Survey, briefed them about the proposed store, listened to their feedback and answered any questions they had. Please find below an image of the area that Mr Naoum covered to have the Consumer Surveys completed:

Figure 1: Area door knocked for Consumer Surveys (Source: Google Maps)

2.6 During the door knocking exercise, Mr Naoum noted that the most common reasons for supporting the application were:  Distinct dislike for the “chains” i.e. Coles, ALDI and Woolworths;  Strong support for an independent operator in Wanneroo that is currently lacking;  Overwhelming support for the convenience of location for those living on Western side of Wanneroo Road;  Robust support for independent operator who would support small WA Producers;

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 Very supportive of Organic and Preservative Free liquor options not currently, easily available at national chain stores;  Identified lack of choice and options of product range currently available in all categories beer, wine, spirits, cider etc.; and  Importantly, very strong support was voiced for a family owned and operated business to generate employment and provide great customer service.

2.7 Further, the Applicant will ensure that those staff employed to function as an Approved Manager at the proposed liquor store hold the required qualification to function as the Approved Manager7 at the proposed premises.

2.8 As a requirement of their employment at the proposed liquor store, all liquor store staff will be required to obtain – at a minimum - a relevant RSA qualification, a copy of which will be kept on site at all times in a Training Register, in accordance with the Director’s Policy on Mandatory Training8.

2.9 In addition to the RSA and MLP1 training, the Applicant has designed a Staff RSA Handbook (Attachment 5a) for the premises, with specific considerations being given to the locality in which they will be operating (subject to approval).

The Applicant as a Fit and Proper Person to hold a Licence 2.10 Section 33(6) of the Act refers to the creditworthiness, character, convictions, conduct of other businesses and reports or interventions made against an applicant, stating; Where the licensing authority is to determine whether an applicant is a fit and proper person to hold a licence or whether approval should be given to a person seeking to occupy a position of authority in a body corporate that holds a licence, or to approve a natural person as an approved unrestricted manager, an approved restricted manager or a trustee — (a)the creditworthiness of that person; and (aa)the character and reputation of that person; and (b)the number and nature of any convictions of that person for offences in any jurisdiction; and (c)the conduct of that person in respect to other businesses or to matters to which this Act relates; and (d)any report submitted, or intervention made, under section 69,

2.11 The Applicant has demonstrated their creditworthiness, character, conduct of other similar licensed businesses and willingness to engage with relevant stakeholders and authorities in the interest of the proper development of the liquor, hospitality and tourism industry.

2.12 As there is no known local Liquor Accord currently active in the locality, the Applicant is committed to engaging with local Wanneroo Police, the DLGSC, the Liquor Enforcement Unit (LEU), the Chief Health Officer (CHO) and other local stakeholders and ‘At Risk’ groups in the locality, if and when required, and will abide by any relevant conditions imposed by the Licensing Authority in the public interest.

2.13 The Applicant is committed to continue working with and supporting WA local producers by stocking their products and also offering a personalised service to discerning and diverse

7 http://www.rgl.wa.gov.au/docs/default-source/rgl/approved_managers.pdf?sfvrsn=6 8 http://www.rgl.wa.gov.au/docs/default-source/rgl/mandatory_training.pdf?sfvrsn=10

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consumers by sourcing unique products not readily available in the locality in addition to the local wines, beers and ciders that they intend to stock at the proposed store.

2.14 The Applicant wishes to enhance local products with local products prominently displayed, to enhance interaction between staff and consumers on local producers. This can be seen in the floor plan for the proposed premises:

Figure 2: Floor plan

2.15 The Applicant aims to enhance the consumer’s shopping experience by providing diversity, convenience, safety in access and choice; creating an independent, safe and convenient packaged liquor shopping option in the locality.

3. Location and Locality Defined Locality 3.1 The Retail Shopping Precinct at 6/957 Wanneroo Road is within the City of Wanneroo, located in the growing northern suburbs corridor of Perth.

3.2 The Directors Policy on Public Interest Assessments states: “As part of a PIA submission, applicants must provide details regarding the community in the vicinity of the licensed premises (or proposed licensed premises) and any amenity issues in the locality. The term ‘locality’ in this instance refers to the area surrounding the proposed licensed premises. This locality will be the area most likely to be affected by the granting of an application in relation to amenity issues. Generally, the size of the locality will be that which is stipulated in ‘Specification of Locality’ at Attachment 2. However, depending on the nature of the application, the licensing authority may also determine a broader locality.”9

3.3 The 3km radius surrounding the proposed store location makes up the ‘defined locality’ as prescribed by the Director’s PIA Policy, last amended 11 January 2017 is indicated in purple:

9 https://www.dlgsc.wa.gov.au/department/publications/publication/public-interest-assessment-policy

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Figure 3: Defined 3km Locality. (Source: https://www.freemaptools.com/radius-around-point.htm)

3.4 The Applicant submits with respect that the defined locality includes the suburbs of:  Wanneroo,  Ashby,  Sinagra,  Edgewater, and  Hocking.

3.5 For the reasons stated above the term “locality” as referred to within this document shall refer to the delineated area as outlined in Figure 3, and the suburbs as stated in point 3.4.

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Figure 4: The suburb of Wanneroo (Source: Forecast ID)

3.6 The history behind the locality is outlined by the City of Wanneroo:

“The name ‘Wanneroo’ comes from the word ‘Wanna’, meaning digging stick used by Aboriginal women and ‘Roo’ meaning ‘the place of ’. Like the Nyoongar people the new settlers used the natural resources of the ‘lakes districts’ to sustain them and by 1872 there were 60 new families in the area. Check the City of Wanneroo website for a timeline history of Wanneroo.

The area is rich in history and is proud of its heritage, with a number of original buildings and sites with stories to tell.

The City of Wanneroo stretches from Girrawheen and Koondoola in the South, north to Two Rocks and is a thriving, expanding area on the fringe of Metropolitan Perth. With 32kms of coastline and 53% of the area classed as regional reserve, the area has plenty to offer the recreation or leisure visitor

THE REGION Wanneroo is in a perfect location, being only 20 minutes from Perth (at its southernmost tip) and is boarded by the stunning Swan Valley to the East, rural Gingin to the North and the City of Joondalup on our western corner.

Wanneroo is part of the beautiful Sunset Coast which describes the area from Cottesloe up to Two Rocks. Check the Experience Perth website to discover more about the Perth area.

All of these areas offer a multitude of amazing experiences, including;-  Wine tasting in the Swan Valley, along with specialist cheese, coffee, chocolate and nougat outlets.  Hillarys Boat Harbour with AQWA, boat trips to Rottnest and many cafes and restaurants along the boardwalk  Lakeside Joondalup City Shopping Centre, the largest shopping mall in WA

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 Explore the Moore River region, heading north along the Indian Ocean Drive”10

Tourism 3.7 As stated above, the City of Wanneroo is situated in the growing northern corridor of Perth and has a range of historical and natural attractions for intrastate, interstate and international tourists. “The Wanneroo region is home to a number of stunning attractions, offering visitors of all ages many great day-trip options. Located a mere 20 minutes north of Perth on the Sunset Coast, Wanneroo boasts unique landscapes and a variety of activities for all to enjoy.

This area has a number of intriguing historical sites and many of the state’s pristine and accessible nature reserves. You can explore dunes, limestone cliffs and bushland in national and regional parks, along the many beautiful walk trails. There is 32kms of coastline to enjoy, offering unspoilt beaches and a variety of water based experiences and two picturesque marinas.

3.8 Coastal Amenity Located on the Sunset Coast region of Western Australia, the City of Wanneroo is home to a number of stunning beaches: “Wanneroo’s beaches stretch from Claytons beach at Mindarie in the South, up to Two Rocks in the North. A total of 32kms of white sand, natural beach dunes and opportunities to swim, surf, play and fish.

Surfing There are some great surf spots along the coast, some only known to the locals. Mainly around Yanchep, including “Rafts” where the small reef provides right and left breaking waves about 150 days a year and “The Spot”. The Spot is north of Yanchep and is a popular break providing long barreling left hand waves. There is a beach break to the north that provides fast fun for the body boarders too!

Swimming Wanneroo has a number of spectacular beaches, but some are quite remote and can be prone to rips and currents. Always be aware of beach safety, swimming between the flags on a patrolled beach and never swimming alone.

Surf Life Saving Wanneroo has two beaches which are patrolled by Surf Living Clubs. Quinns Beach is patrolled by Quinns Mindarie Surf Lifesaving Club and Yanchep Lagoon is patrolled by Yanchep Surf Lifesaving Club. Check the websites for times and other details.

Fishing Mindarie Marina proves an excellent spot to catch Herring and Tailor. Casting at first light is optimal.”11

3.9 Heritage and History Wanneroo has a rich and colourful history, preserved and showcased at the Wanneroo Regional Museum: “This Museum collects, preserves and showcases, the City of Wanneroo’s rich history and heritage through a range of exciting displays which comprise more than 550 objects and

10 https://discoverwanneroo.com.au/about/about-wanneroo/ 11 https://discoverwanneroo.com.au/about/beaches/

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photographs. Through objects like an Aboriginal buka, an original beach shack, a road roller and shipwreck treasures, the stories associated with our cultural heritage are shared and celebrated. The recollections of local residents interpret the region’s journey from an open land of lakes and a traditional Aboriginal lifestyle, to an isolated community of pioneers and on to its subsequent growth into a thriving centre of industry and a contemporary multicultural society.

The Museum offers an excellent range of educational and public programs particularly suited to Years K to 6 students. The programs address key areas of historical knowledge including early settlers and local history, Aboriginal culture, World War 1 involvement and also offer strong links to the Australian history curriculum.

Public programs include our popular “It’s All About the Past”, which has been designed to introduce little ones aged between 2 and 5 years to the history of Wanneroo in a fun and interactive way. Children can explore different themes throughout the program via craft activities and play.”

The Wanneroo Regional Museum also houses the Wanneroo Community History Centre, with an extensive collection on the history and heritage of Wanneroo, which includes books, pamphlets, photographs, maps, oral history interviews, archive material and newspapers. Along with the Museum, the City of Wanneroo also maintains a number of heritage homes including (but not limited to) Cockman House and Buckingham House12.

3.10 Aboriginal Culture The City celebrates their indigenous history and heritage and acknowledges the traditional custodians of the land. It also notes that: “The City of Wanneroo is located within ‘Noongar Country’, in the south west of Western Australia (stretching from Esperance to Jurien Bay) and contains 14 different language groups. Two Noongar language groups, the Whadjuk and Yued people, lived and shared cultural areas in the northern parts of the City of Wanneroo for traditions and customs. This region was part of Mooro Country, the district of an important Whadjuk Noongar elder and leader Yellagonga.

Water was vital for Yellagonga’s group for their survival and spiritual connections. This made Wanneroo, with the abundant food sourced on the shores of its lakes, an important environment for local Whadjuk Noongar families. They moved around the coastal sand-plain according to the six Noongar seasons, hunting and gathering as they went. Their deep understanding of the land and climate allowed them to live well on animals, fish, insects and plants.

Learn something of the rich culture and history of the Nyoongar people at Wangi Mia Meeting Place at Yanchep National Park. Hear about seasonal movements, language and how knowledge is passed from generation to generation. See tools such as spears and boomerangs. Witness a spear- throwing demonstration. Discover how plants and animals in this environment bear great significance to the Nyoongar people.”

3.11 Wanneroo Gallery “The Wanneroo Gallery is a large, state of the art exhibition space with high specification lighting and climate control and is an ideal venue for exhibitions, conferences and corporate presentations. The City of Wanneroo currently has a world class program of visiting exhibitions displayed in the Gallery across the year and these are free of charge to the public. Operating in conjunction with these exhibitions are education and public programs including school holiday workshops and tours available for students.

12 https://discoverwanneroo.com.au/heritage-homes/

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The City’s Art Collection has 250 artworks including paintings, photographs and small sculptures. An online gallery of the Art Collection has been established to provide the residents of Wanneroo and the general public with an easy way to view artworks that are on display across the city, as well as to see what artists are represented in the collection.”13

3.12 The City of Wanneroo also has a number of other attractions that appeal to tourism visitors to Western Australia including (but not limited to):  Indian Ocean Brewing Company at Mindarie Marina;  Paul Conti Wines: “One of WA’s most reputable and respected boutique, family-owned wineries, with unique underground cellar, renowned stone and jarrah restaurant built in 1982 and award-winning wines.”14  Aida, Kien and Wanneroo Strawberry Farms – where families can go and pick their own strawberries to take home.  Crystal Cave in Yanchep,  Landsdale Animal Farm,  Jumaunga Olive Grove,  Perth Mango Farm,  Wanneroo Botanic Gardens and Mini-Golf,  Yanchep National Park, and  The Ghost House Walk Trail to name just some.

Population Growth 3.13 There has been an increase in the number of people residing in (and around) the Wanneroo locality over recent years, and this growth is forecast to continue as shown in the Population Forecast information regarding the LGA and Suburb below:

Figure 5: Forecast id Information for City of Wanneroo (Source: Forecast id)

13 https://discoverwanneroo.com.au/gallery/ 14 https://discoverwanneroo.com.au/lifestyle-travel/wineries/?region=everywhere&type=wineries&listing=paul-conti- wines

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3.14 This information indicates that the population of the locality is anticipated to increase in the future by 87.52% for the City of Wanneroo15. This is supported by the City of Wanneroo’s Future Structure Plan, which increases residential densities in the area zoned Town Centre, as evidenced by the Wanneroo Town Centre R-Code Plan16.

3.15 The Applicant also understands that the land behind 957 Wanneroo Road, the site of the former Primary School, is also zoned for future residential development. In addition, there is land owned by St Anthony’s Servite School and Ingham (former site of Ingham chicken farm) which has also been re-zoned to allow for higher density residential developments17.

3.16 It has been reported that the proposed Activity Centre Plan includes: “The draft plan, which the council agreed to advertise for consultation at its December meeting, proposes high-density housing and commercial development in a bushland buffer between Ingham’s poultry farm and the civic centre. It proposed increased building heights up to eight storeys and development intensity, as well as introducing medium residential densities of R60 to R100 where the buffer zone lies. According to the December council report, ultimate development would yield 2000 to 3000 dwellings, accommodating up to 6600 people by 2041.”18

3.17 The City of Wanneroo, where the proposed Wanneroo Cellars is to be located, is also forecast to grow at a rate of almost 220% over the next 20 years to 204119:

Figure 6: Forecast population growth for the suburb of Wanneroo (Source: https://forecast.id.com.au/wanneroo/about-forecast-areas/?WebID=340)

3.18 Much of the growth anticipated for the remaining areas in the City of Wanneroo (outside of the suburb of Wanneroo). For example, the northern suburb of Eglinton, (located between Alkimos and Yanchep) is forecast to grow from 4,148 residents in 2019 to 29,208 in 204120.

15 https://forecast.id.com.au/wanneroo 16 http://www.wanneroo.wa.gov.au/downloads/file/497/wanneroo_town_centre_r-code_plan 17 https://www.communitynews.com.au/general/news/plan-endorsed-for-wanneroo-town-centre-redevelopment/ 18 https://www.communitynews.com.au/wanneroo-times/news/consultation-to-close-on-wanneroo-town-centre- plan/ 19 https://forecast.id.com.au/wanneroo/about-forecast-areas/?WebID=340 20 https://forecast.id.com.au/wanneroo/about-forecast-areas?WebID=180

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3.19 The growth in Wanneroo and the suburbs to the north is also evidenced by the transport and road infrastructure being carried out in the area. “The transformation of Wanneroo Road is one step closer with the completion of a 3.2 kilometre dual carriageway between Joondalup Drive and Flynn Drive.

The $31 million project is the first of three Wanneroo Road upgrades worth a combined $146 million to be completed. Two Wanneroo Road interchanges are also currently under construction at Ocean Reef Road and Joondalup Drive.

The widened section is a well-known congestion hotspot creating traffic delays both northbound and southbound for more than 26,000 vehicles each day.

A single carriageway can no longer adequately accommodate increasing traffic levels. New dual lanes for the road will significantly improve congestion and create safer, more efficient journeys.

The project has included intersection upgrades at Golf Links Drive and Carramar Road, along with a Principal Shared Path for cyclists and pedestrians.

Meanwhile, the total project cost has also enabled new noise walls, bus stop facilities, landscaping and U-Turn points to provide access to driveways on Wanneroo Road.

The $31 million project was announced in May 2017 as part of a $2.3 billion package of road and rail infrastructure, and is the first project in the package of works to be completed.

It will help transform Wanneroo Road as a major north-south alternative to Mitchell Freeway, and is one of three upgrades for the strategic route.”21

3.20 Investment in road infrastructure in the growing northern corridor and Wanneroo is not limited to the Wanneroo Road/Flynn Drive intersection. The Wanneroo Road/Ocean Reef Road intersection is also undergoing significant changes to accommodate the large number of residents choosing the Perth northern suburbs as their home: “Construction is off to a great start on the Wanneroo Road and Ocean Reef Road interchange, with progress now visible across a number of the site's work zones.

The project is one of several underway to ease congestion in Perth's busy northern suburbs.

It is one of 17 'Boosting Jobs, Busting Congestion' projects launched by the McGowan Government and fully funded as part of the redirection of funds from the flawed Perth Freight Link project.

Earthworks in the north-east corner are underway for the bridge's north-east loop ramp, which will be one of two loops with traffic signals connecting Wanneroo Road and Ocean Reef Road.

A new access road to Cockman House is almost complete, with only surfacing and kerbs to go. A U- turn facility is also near completion within the median on Wanneroo Road north of Villanova Street, which will improve safety and reduce the risk of right-angle crashes.

Other activities on site have included demolitions, clearing of shoulders and median strips, service relocations, and establishment of traffic management.

21 https://www.mediastatements.wa.gov.au/Pages/McGowan/2019/04/31-million-dollar-Wanneroo-Road- duplication-to-Flynn-Drive-completed.aspx

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Construction of the bridge foundations and substructure will begin in November, enabled by traffic being switched to a temporary roundabout and roads.

Historically, the intersection has been one of the most congested in the metropolitan area. It is also the 11th worst intersection for crashes, with 185 crashes occurring between 2014 and 2018.

The $64.8 million project is jointly funded by the Australian ($51.84 million) and State ($12.96 million) governments.

Construction commenced in March 2019 with completion expected in late 2020.”22

3.21 The Retail Shopping Precinct at 957 Wanneroo Road provides a range of commercial and retail amenity on the west side of Wanneroo road, and is particularly convenient to those consumers travelling home in a northerly direction (Attachment 15). The premises will be located in the area deemed ‘’Wanneroo Town Centre Precinct’’ as evidence in the figure below:

22 https://www.mediastatements.wa.gov.au/Pages/McGowan/2019/07/Construction-taking-shape-at-Wanneroo- Road-congestion-hotspot.aspx

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Figure 7: Wanneroo Town Centre Precincts map (Source: http://www.wanneroo.wa.gov.au/downloads/file/495/wanneroo_town_centre_precincts)

3.22 The Retail Shopping Precinct is identified above in yellow. As can be seen, it is centrally located on the west side of Wanneroo Road, in the Wanneroo Town Centre Precinct.

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3.23 It is the submission of the Applicant that one of the public interest factors to be weighed and balanced in the determination of this application, is the convenience it would provide to those travelling north on Wanneroo Road.

3.24 Currently, those travelling north have three (3) options to purchase packaged liquor in the Wanneroo town Centre Precinct. They must either: a) turn right into Dundebar Road, enter the Wanneroo Central Shopping Centre car park, park their car and traverse the car park to enter the shopping centre, then find and enter the Liquorland store. b) turn right into Dundebar Road, enter the Wanneroo Central Shopping Centre car park, park their car and traverse the car park to enter the shopping centre, then they must also enter the ALDI Wanneroo store, and find the liquor offering, and go through the designated licensed checkout. c) turn right into Dundebar Road, turn right into Conlan Avenue, turn right into the Wanneroo Tavern premises and proceed to the BWS drive through. It should also be noted that the Wanneroo Tavern hosts on-premises consumption of liquor, Lounge Bar, Beer Garden and TAB facilities.

3.25 Further, a consumer travelling north on Wanneroo Road must then repeat all steps in reverse, including turning right again onto Wanneroo Road, to continue their northward journey home.

3.26 This is summarised by the report from FLYT (commissioned by the Landlord of the Retail Shopping Precinct at 957 Wanneroo Road): “Flyt is familiar with the traffic issues at the Wanneroo Town Centre, having completed the transport assessment component of the Wanneroo town centre Activity Centre Plan during a 6 month period in 2018. The transport assessment involved a review of public transport, walking, cycling, vehicle access and parking. The subject property is within the boundaries of the Wanneroo town Centre, and was formerly an ANZ bank.”

3.27 The report goes further to state that: “The proposed liquor store at tenancy 6, 957 Wanneroo Road, is more accessible from Wanneroo Road than either of the existing liquor stores in the eastern side of Wanneroo Road. This is particularly evident in the weekday afternoon peak period between 3 and 6pm, when the dominant traffic flow direction is northbound, and many vehicles are heading home.

The western side of Wanneroo Road is colloquially the ‘go home side’. During the PM peak, when patrons are heading home, they will be predominantly accessing food, convenience goods and beverages for dinner.

Hasting Street carries a significantly lower volumes of traffic than either Dundebar Road or Conlan Avenue. In addition, vehicles accessing the proposed liquor store would not have to deviate as far away from Wanneroo Road as they would in order to access either of the existing liquor stores.” (Attachment 15).

3.28 The addition of an appropriately sized well managed liquor store will complement the current amenity available and provide a convenient packaged liquor offering in line with the requirements of ‘Secondary centres’ as determined by the WA Planning Commission’s State Planning Policy 4.2 – Activity centres for Perth and Peel23.

3.29 ‘Secondary centres’ are the third highest type of Activity Centre denomination in the State, below only ‘Strategic metropolitan centres’ and Perth Capital City. The Applicant notes that as per State Planning Policy 4.2; Secondary centres are defined as (emphasis added):

23 https://www.planning.wa.gov.au/dop_pub_pdf/activity_centres_policy_2.pdf

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Main role/function Secondary centres share similar characteristics with strategic metropolitan centres but serve smaller catchments and offer a more limited range of services, facilities and employment opportunities. They perform an important role in the city’s economy, and provide essential services to their catchments.

Transport connectivity and acessibility Important focus for passenger rail and/or high frequency bus network.

Typical retail types  Department store/s  Discount department store/s  Supermarkets  Speciality shops

Typical office development  Major offices  Professional and business services

Future indicative service population (trade) area24 Up to 150,000 persons

Walkable catchement for residential density target 400m

3.30 Given the amenity available at Retail Shopping Precinct at 957 Wanneroo Road, the Secondary centre designation is appropriate, as is the inclusion of a convenient and diverse packaged liquor offering as proposed at Wanneroo Cellars.

3.31 The inclusion of an independent, packaged Liquor Store will further enhance the amenity available for consumers and bring the amenity in line with the facilities available in other retail precincts in Western Australia. Further, it will meet the requirements of consumers in the locality, as one of the most consistent responses from the Consumer Survey, was for a local operator that was not affiliated with the large retail chains, with 88.66% of respondent indicating they would like to patronise an “Independently owned and operated store (i.e. not by the large National Chains).” (Refer Consumer Surveys).

3.32 The key demographic statistics for the locality in this submission have been sourced from the latest available Australian Bureau of Statistics 2016 Census Data25. The statistics represent the combined population data of those suburbs located within the defined locality (Attachment 7) as identified in point 3.4 of this PIA submission.

Population and Demographic Data 3.33 The defined locality populations as stated in the ABS 2016 Census Data are listed below; Suburbs Population Population Indigenous Australian Speak under 14 yrs Person Born English at Home Wanneroo 12067 2119 190 6903 9866

24 Service population or retail trade areas for (residential-associated) centres are indicative only and often overlap. 25 www.abs.gov.au

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Ashby 2665 556 7 1419 2186 Sinagra 2632 668 39 1456 2025 Edgewater 4507 847 30 2375 3895 Hocking 5916 1488 42 3644 4769 Totals 27787 5678 308 15797 22741 Locality % 20.43% 1.11% 56.85% 81.84%

WA Totals 2474410 476686 75978 1492842 1861041 WA % 19.26% 3.07% 60.33% 75.21% Greater Perth Totals 1943858 370327.00 31214.00 1113277.00 1428821.00 Greater Perth % 19.05% 1.61% 57.27% 73.50% Figure 8: Population Statistics for 'defined' locality (Source: www.abs.gov.au)

Population Demographics 3.34 The Census Data (Attachment 7 – 2016 ABS Census data) reveals that there were 27,787 persons typically resident in the locality on census night.

3.35 There is a lower percentage of residents who identify themselves as Indigenous Persons in the locality (1.11%) than the WA State average (3.07%) and who are deemed an ‘At Risk’ group as identified under the Drug and Alcohol Interagency Framework for Western Australia 2011-201526.

3.36 The statistics for the defined locality also indicate that there is a slightly higher percentage of ‘Population under 14 Years’ in the locality, than in both WA and Greater Perth.

3.37 It also worth noting that there are higher percentages of residents over 55 years in the suburbs of Wanneroo (28.2%), Ashby (27%) and Edgewater (30.8%) compared to the WA State average of 25.4% and the Greater Perth average of 24.8%. This is also reflected in the results of the Consumer Survey, which demonstrate that 29.30% of the respondents were over the age of 55.

3.38 A total of 81.84% of the population indicated that they Speak English at Home, and 56.85% were Australian born. This compares to the WA statistics which reflect 75.21% of the population Speak English only at home, and 60.33% that were Australian born.

3.39 The ABS statistics for the defined locality reflect an area that has a high percentage of couple families with children with above average incomes.

Population Characteristics of the Locality 3.40 Please see below the population demographics relating to age, gender and income; comparing the locality to the relative Western Australian rates; Locality Western Australia Total Population 27787 2474410 % Males 48.3% 50.00% % Females 51.7% 50.00% Median age 35 36 Largest age group 30-34 30-34 Largest age group % 9.3% 7.90%

26 https://www.mhc.wa.gov.au/media/1721/drug-and-alcohol-interagency-strategic-framework-for-western-australia- 2011-15.pdf

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Median Individual Income $760.80 $724.00 Median Household income $1,722.20 $1,595.00 Median Family income $1,970.60 $1,910.00 Figure 9: Demographic data for the locality (Source: www.abs.gov.au)

3.41 The median age of persons typically resident within the locality is 35 years, slightly lower than the Western Australian state average of 36 years.

3.42 According to the statistics available the most populated age bracket within the defined locality are within the 30-34 year age group and represented 9.3% of the population in the locality.

3.43 The median income is higher in the locality than WA across all Individual, Household and Family incomes. Median Individual Income was higher in the locality at $760.80 per week compared to $724.00 for WA, and Median Household Income in the locality was higher at $1722.20 per week compared to $1595.00 for WA. Median Family Income was also higher with the locality having a weekly Median Family Income of $1970.60 compared to WA’s Median of $1910.00 per week.

3.44 Based on these statistics, the locality for the proposed Liquor Store is considered to be a relatively average socio-economic region in Western Australia.

3.45 The locality being designated an average socio-economic region is supported by the SEIFA data for the City of Wanneroo, indicating it has a SEIFA (Index of Relative Socio-economic Disadvantage) score of 1015.0, the same as the same measure for Western Australia. This is significantly higher than the Australian average of 1,001.9.

3.46 Please see below a comparison of the family composition between the locality and Western Australia: Locality Western Australia Couple family without Children 35.86% 38.50% Couple family with children 49.62% 45.30% One parent family 13.28% 14.50% Other family 1.24% 1.70% Figure 10: Family composition statistics for the locality (Source: www.abs.gov.au)

3.47 The locality has more Couple families with children and less Couple families without children than the Western Australian rates. One parent families and other families were recorded at a lower percentage within the locality than that of Western Australia.

Access Information 3.48 Wanneroo Cellars will be conveniently located at the Retail Shopping Precinct at 6/957 Wanneroo Road, that is easily accessible by both car and public transport. Further, as it is not located in the area deemed “Mainstreet”, it is significantly easier to access by those living to the west of Wanneroo Road and those travelling north on Wanneroo Road.

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Figure 11: Map showing area deemed 'Mainstreet' by the City of Wanneroo (Source:http://www.wanneroo.wa.gov.au/downloads/file/494/wanneroo_town_centre_structure_plan_- _part_1_and_2) 3.49 The premises has been designed to meet Australian Standard As 1428.1 – 2009 relating to “Design for Access and Mobility” ensuring that those using mobility devices can easily access the proposed liquor store. This is a significant factor in catering to the requirements of the local community, given the higher than average number of residents aged over 55 years in the suburb of Wanneroo.

Parking 3.50 Parking at the Retail Shopping Precinct at 957 Wanneroo Road is available in the dedicated car park on Wanneroo Road, directly in front of the proposed Wanneroo Cellars. The subject of ease of access to the liquor store was also raised in the Consumer Survey, with 87.50% of respondents indicating it was an issue for them. The parking is provided for patrons use free of charge.

Public Transport 3.51 Both the Joondalup Train Station and the Whitfords Train Station have services from Perth and Butler. These services are timed to co-occur with bus routes disseminating throughout the northern suburbs.

3.52 There is public transport available in the defined locality with bus stops along Wanneroo Road servicing Transperth Bus Routes 389, 467 and 468. These Transperth Bus Routes travel between: 389. Perth Busport to Wanneroo Town Centre. 467. Whitfords Train Station to Joondalup Train Station via Wanneroo Road. 468. Whitfords Train Station to Joondalup Train Station via Wanneroo Road.

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Proposed Wanneroo Cellars Bus stops

Figure 12: Public Transport available from Retail Shopping Precinct at 957 Wanneroo Road (Source: www.abs.gov.au)

Juveniles in the locality 3.53 Unaccompanied juveniles will not be permitted into the store at any time.

3.54 The Applicant understands that under Section 122A of the Liquor Legislation Amendment Act 2015 (WA), it is illegal to supply alcohol to people aged under 18 years in a private home without the consent of the parent or guardian. It is an offence to supply alcohol to people under aged 18 if the parent or guardian giving consent is drunk or otherwise unable to act in a responsible manner. Offenders are liable for a fine of up to $10,000 for each underage drinker involved. The Applicant will ensure signage to this effect is located within the proposed Wanneroo Cellars.

3.55 The Applicant has considered the risk of harm or ill-health to juveniles in the Harm Minimisation Plan (Attachment 1), and has included measures including but not limited to;  Implementing the I.D. under 25 initiative,  Enforcing a policy of no service to persons wearing a school uniform regardless of their ability to provide ID,  Opening hours to be at 9.00am on school days,  Responsible service of alcohol staff training (Attachment 5a),  Spirits located behind POS counter,  Liqueurs, fortified and cask wine will also be located in close proximity to the POS counter,  RTD’s located away from store entrance, and  Limited external advertising visible from Wanneroo Road.

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4. Venue and Operation 4.1 The Applicant intends to safely and responsibly operate an independently owned Liquor Store commensurate with the size and amenity at the Retail Shopping Precinct at 6/957 Wanneroo Road

4.2 The proposed packaged liquor amenity will cater to local residents and businesses, and those who resort to the Retail Shopping Precinct at 957 Wanneroo Road for the complementary facilities available. Wanneroo Cellars will be located within Tenancy 6 of Retail Shopping Precinct at 957 Wanneroo Road as can be seen in the figure below:

Figure 13: Render of the exterior and interior of the proposed Wanneroo Cellars

Proposed Product Range 4.3 The proposed product range at Wanneroo Cellars will be determined by:  Core range of products including (but not limited to) beer, cider, wine and spirits,  Selection of low-alcohol products, for those seeking a low sugar/low alcohol liquor alternative  Strong showing of WA made products supported by the proposed Licensee – They consider supporting local liquor producers to be a very important aspect of the independent business

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model, and understand that local employment (both direct and indirect) opportunities flow from the decision to support local, premium producers,  A range of WA cleanskin wines, and  A range of organic, preservative free, vegan and biodynamic products.

4.4 The extent to which the proposed product range will include products from smaller, boutique WA producers is reflected in the Sample WA Product List (Attachment 8), provided with this PIA submission. The sample products list identify that:  Of the 145 standard wines on the Bottlemart core wine list, 30 (20.7%) are from WA;  Of the 51 Premium wines on the Bottlemart core product list, 17 (33.3%) are from WA; and  The Applicant has also included a list of local WA Producers that, as an independent operator, he has chosen to incorporate in the offering which include: o 188 lines of premium wine products, o 87 lines of craft beer products, o 39 lines of boutique cider products, and o 45 lines of small batch spirit products.

4.5 Subject to approval, the Applicant will also offer consumers membership of a “Wine Club” that will invite members to “Wine Dinners” and “Meet the Winemaker” functions, tastings and other educational events.

Catering to Requirement of Consumers 4.6 Consumers will also have the ability to specially request products (Attachment 5b - Product Request Form) that they are unable to find in other liquor stores in the locality and which may not be available at the proposed Wanneroo Cellars.

4.7 Mr Naoum has over 30 years’ experience offering customer’s superior product knowledge and has a commitment to outstanding customer service. He also has a long and proud history of supporting local WA Producers, as evidenced by the Letters of Support provided with this application.

4.8 The Applicant submits that this is a consumer focussed service they have previously offered at other liquor stores, has been very welcomed in the past when implemented and is designed to meet the contemporary requirements of consumers.

4.9 The proposed product range at Wanneroo Cellars will reflect the profile of the local community, representing a value for money offering, and will provide a convenient, independently operated diverse amenity in the locality.

4.10 The curated selection in a 263m2 display, browse and storage area will allow consumers the opportunity to have a customer focussed, retail liquor experience where they are able to complete their grocery and liquor shopping within the Retail precinct at 957 Wanneroo Road.

4.11 Subject to approval, the Applicant intends to provide a convenient, packaged liquor offering that includes the following products:

Locally produced WA Wines 4.12 It is Mr Naoums’ strong belief, based on his extensive industry experience that the WA wine industry is a substantial employer in Western Australia, and that the benefits to the State in supporting local Producers are both well-known and varied including (but not limited to) creating employment, upskilling opportunities, and strongly supports the tourism industry. Please find below some examples of the WA Produced wines that will be available from the proposed Wanneroo cellars, that are not currently available in the locality:

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Karafilis Organics This is truly a family owned and operated winery in Bridgetown in the Blackwood Valley region of WA. Their wines do not use any animal products, and accordingly are suitable for vegans – a growing section of the community. Further, their use of natural farming techniques and organic operational practices is a tourism drawcard, and they invite people onto their winery to talk to them about the organic nature of their family business: “All our wines are made from hand picked, hand plunged and basket pressed grapes from either our own organically run estate or from neighbouring vineyards in the Blackwood Valley region.

Our wines have been fermented without the use of artificial refrigeration or heating thus reducing our consumption of electricity. Fermentation temperatures of the 2011 Rose and the 2012 Sauvignon Blanc and Rose (18 C) were maintained by careful monitoring and movement of the wine in and out of the winery, taking advantage of the cold frosty nights of this region, and the stable insulated environment of our winery. This year we decided to make a classic, dry style of Sauvignon Blanc, so we fermented it at a cooler temperature (10 C) giving the wine a clean, fresh finish.

To reduce environmental impact and retain full flavour, no wines have been 'cold stabilised' (artificially chilled to -2 C to remove unstable crystalline deposits which some people find aesthetically unpleasant). Some deposit of potassium bitartrate may occur within the bottle and may appear as red crystals in the red wines and coloured 'wine diamonds' in the white and rose wines.

Every year, events are held at the winery including film nights, wine tasting events and star gazing.”27

Sittella Wines Sittella Wines are made locally in Herne Hill, some 20km’s from the proposed Wanneroo Cellars. As a smaller producer in WA, Sittella relies on independent liquor stores like that proposed, to ensure their business viability by supporting their products, provide them with a retail presence and to educate consumers as to the benefits of supporting small, local Producers over the large national chains ‘home brand’’ wines. “Owners Simon and Maaike Berns have the support of an enthusiastic team of professionals to create and produce high quality traditional wine styles, from both their own and contract vineyards throughout the Swan Valley and Margaret River Region and the Deep South.

Nestled among the vines on a gently winding road near the upper reaches of the Swan River lies the Sittella winery & restaurant, a jewel of the historic Swan Valley. In this tranquil setting with valley and vineyard views from the verandah, visitors are invited to enjoy fine food and award winning wines.Take the time-out for a relaxing visit to Sittella Winery in the heart of the picturesque Swan Valley, a leisurely 30 minute drive from Perth City.”28

Being a smaller player on the WA wine scene has not always been easy, and Sittella noted in their letter of support (Attachment 3c) that they are unable to get their product onto the shelves of the large, national liquor chains (including BWS, Liquorland and ALDI in Wanneroo), due to their low supplier pricing and large volume demands. Being as the large national chains store control almost

27 http://www.karafilisorganics.com.au/philosophy.php 28 https://www.sittella.com.au/

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80% of the retail liquor market in Australia, Producers such as Sittella rely on small, independent retailers to stock their products which has a direct impact on Sittella’s business viability.

Pemberley of Pemberton “Pemberley of Pemberton produces a wide range of premium cool climate grapes, wines and gourmet food products. The property was first farmed by the Radomiljac family in the 1970s, and later established as a vineyard in 1995 by Monica and David Radomiljac who, along with the next generation, have worked consistently to refine this farming enterprise to ensure they offer the best produce possible.”

Previously trading as Pemberley Wines, Pemberley of Pemberton is another small, local Producer whose products are not currently available in Wanneroo, due to the buying practices and ‘own label’ products of the large supermarket-based liquor stores. Pemberley Wines routinely win awards at some of Australia’s most prestigious Wine Award shows (i.e. 5 Trophy’s, 2 Gold, 1 Silver and 3 Bronze Medals in 201929), but have no representation in the BWS, Liquorland or Aldi in Wanneroo. As stated in the letter of support (Attachment 3g): “I have known Mr Arthur Naoum personally through various liquor interests for over ten years, trading as both Pemberley Wines and now as Pemberley of Pemberton. During this time Arthur and his team have always shown a passion to support the local WA wine and (growing) liquor industry through representation in his retail liquor outlets. In particular we note Mr Naoum’s willingness to bring products not normally stocked in the larger chain liquor stores to the retail market on his shelves; adding choice for consumers, but also supporting smaller liquor producers find a route to market. This can be difficult for some smaller producers (including ourselves) as they cannot reduce their wholesale price to a level acceptable to the large format liquor stores owned by national and international chains. During the time I have known Arthur I have not had reason to question his integrity, finding him always to be honest and upfront.”

Little Black Dog As a Swan Valley producer who relies on Cellar Door sales, Norm Trandos of Little Black Dog (LBD) sees his family wine estate as a family business bringing premium wine products to consumers, who have value for the hard work and time taken to produce a quality wine product. “Through time, the traditions of the Trandos Family have been passed down and is now being offered to you. Today the vineyard is situated in the beautiful region of Swan Valley, Western Australia. All of our wine is made with handpicked grapes, rich with distinct fruit driven flavours. It is our family’s love affair with food, wine and good company which has brought us to where we are today.” Mr Trandos notes that over the years, his business has been adversely affected by the mass production of inferior wine products, made to look like premium brands through the use of labelling by the big supermarket retailers of liquor (i.e. Coles Woolworths and ALDI).

Harmans Estate As a small Producer located in the South West wine region, Harmans Estate is located in a well- known tourism region.

29 https://www.pemberleyofpemberton.com/about-us

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“Harmans Estate is a cooperative style winery located in the heart of the Margaret River Wine Region. We craft wines for a number of premium producers in the region who do not have their own winery / winemaker. Established in 1999 this facility is one of the most awarded wineries in the region, and operates on a simple theory that great wines come from great vines. Harmans Estate is operated by a young dedicated team of winemakers who are industry leaders in the production of world class wines. Our team is comprised of highly qualified winemakers who are either in the winery or can be found at cellar door. We are one of the few cellar doors in the region that you can actually talk to the winemaker that crafted the wines.”30 The representative for Harmans Estate in Perth notes that: “As a small WA wine Producer, our products are not on the shelves of some of the country’s largest liquor retailers (including Liquorland, BWS and Dan Murphy’s) due to the fact that we cannot supply our premium product at the volume and price required by the large multi-nationals. Accordingly, we have little to no representation in the nationally owned chain stores which saturate the packaged liquor market. Currently, the only avenue to market we have is through our Cellar Door in Margaret River and small, independent retailer such as Mr Naoum who support local producers and premium wine products, and who show that support through market access.”

Fairbrossen Estate The family own and run winery is operated by head winemaker, Mr Matthew Bowness and his family. The philosophy of the winery is based on having ‘minimal intervention’ with the vineyards and winery by using traditional winemaking techniques with organic principles. The boutique winery is conscious of the sustainability of their wine production and utilise environmentally responsible practices in the production of their wine. Fairbrossen Estate use natural dyes on fully recycled paper stocks to make the labels of the wine bottles.

Some of the wine produced at Fairbrossen Estate includes:  NV Little Charlatan “Named after our daughter "Charlotte Ann" who was born in the middle of harvest. This Methode Champenoise wine is made from Cabernet Sauvignon grapes from our Carmel Valley vineyard. Its a true 'charlatan' as despite the variety, it displays finesse, elegance and complexity of traditional premium sparkling wines.”  2017 Rose “Our Rose is produced from Cabernet Sauvignon fruit grown on the Carmel vineyard. 24hr skin contact produces the vibrant colour and red berry characters. A refreshing and crisp wine, perfect for a summers day.”  2017 Harvest White “This Verdelho is produced in a 'classic dry' style and displays lifted tropical notes of passionfruit and lime. Fermentation in stainless steel and refreshing acidity on the palate, this is designed for early consumption.”  NV Nightcap “This is a fortified Shiraz wine made in a liqueur style, and displays flavours and aromas of Christmas pudding and plum jam. High levels of ripeness ensure this is a sweet, yummy wine to be enjoyed at the end of the evening.”31

30 https://www.facebook.com/pg/HarmansEstate/about/?ref=page_internal 31 https://www.fairbrossen.com.au/

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Figure 14: Fairbrossen Wine (Source: Fairbrossen Café and Winery)

WA Cleanskin Wines 4.13 Wanneroo Cellars will also stock a range of cleanskin wines, specifically focussing on WA producers, so as to support local employment, the WA region as a food and wine destination, and to provide some high-quality, value for money options for their patrons, without compromising their values as a retailer.

“There is no doubt that cleanskins (wines sold without a label) can be very good value.

A similar concept to the cleanskin is the buyer's own brand - where a bottleshop actively sources a specific wine, rather than waiting for a winery to approach it. The quality of these wines is usually very good, otherwise the retailer would not take them. And the pricing is usually keen, because the winery has a definite sale for a large volume.”32

4.14 Importantly to the Applicant, cleanskin wine allows them to offer a local, value for money product, without tarnishing the reputation of local brands that produce premium table wines.

Organic/Biodynamic/Dietary Specific Liquor Products 4.15 The popularity of and demand for organic, biodynamic and dietary specific liquor products are growing in Australia. “But according to the most recent figures from the 2014 Australian Organic Market Report, organic wine is on the rise among wine lovers, accounting for 6.9% of the total organic market in Australia, with organic grape production increasing by 120% between 2011 and 2014.”33

4.16 Organic Wine is a wine made from grapes that have been grown without the use of artificial or synthetic chemicals, such as herbicides and pesticides. Organic farmers work with nature, rather than against it, by boosting their vineyard’s biodiversity. They introduce cover crops to provide a habitat for beneficial insects that are the natural enemy of problem species, or have small sheep graze between the vine rows, eating the grass and weeds. This way, the vineyard becomes a self- regulating, natural ecosystem, which is able to combat problems intrinsically and eliminates the need for artificial, and potentially toxic, chemicals.

4.17 The Applicant will stock a range of organic wine products, to cater to the growing market for organic food and beverage options.

32 https://www.smh.com.au/business/how-to-buy-bargain-wine-20060517-gdnjuv.html 33 https://www.theguardian.com/lifeandstyle/australia-food-blog/2015/feb/07/why-you-should-be-drinking-organic- wine-and-where-to-find-it

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4.18 Biodynamic Wine is another style that is becoming more popular (Refer Consumer Surveys) as consumers now have heightened awareness of what they are consuming, where it comes from and how it is made. “Biodynamic wine is made with a set of farming practices that views the farm or vineyard as one solid organism. The ecosystem functions as a whole, with each portion of the farm or vineyard contributing to the next. The idea is to create a self-sustaining system. Natural materials, soils, and composts are used to sustain the vineyard. Chemical fertilizers and pesticides are forbidden for the sake of soil fertility. A range of animals from ducks to horses to sheep live on the soil and fertilize it, creating a rich, fertile environment for the vines to grow in. Biodynamic farming also seeks sustainability, or leaving the land in as good or better shape as they found it for future generations.” 34

4.19 Wanneroo Cellars will include biodynamic wine products in their offering including (as examples) KT Peglidis wines, the Avina range and Stefanio Lubina Primavera.

4.20 Dietary Specific alcohol products are also a growing segment of the liquor market. Alcoholic beverages can contain a number of different ingredients that can cause symptoms of allergy or intolerance. These ingredients in alcoholic beverages may cause symptoms in people who are sensitive to them, and reactions can vary from minor (sneezing) to significant (anaphylactic):  Gluten in wheat, barley, and rye,  Histamine,  Sulfites,  Yeast,  Grapes, and  Corn.

4.21 Gluten free beer, egg free, milk free and fish free wine will be available, allowing those with lactose, gluten and fish allergies to purchase liquor products safely. Further, vegetarian and vegan lifestyle choices will also have options at the proposed Wanneroo cellars in the public interest. For example, the proposed liquor store will carry a range of beer options for Gluten Free consumers.

4.22 Respondents to the Consumer Survey showed an interest in the aforementioned specialty wines.

WA made craft beer and cider 4.23 The proposed liquor store will support local WA craft beer and cider producers by stocking their product and thereby supporting local industry and employment. This will be done by providing a product range that includes pre-packaged craft beer.

4.24 Western Australian craft beer producers have limited market access for their packaged liquor products, and the Applicant is committed to supporting these small, local producers while meeting the requirements of the new, growing, sophisticated beer consumer who prefers a quality over quantity approach to craft beer and consumption.

4.25 The WA/Australian craft beer products to be available at Wanneroo Cellars may include local producers such as:  Eagle Bay Brewing Co (WA),  Wilson Brewing Co (WA),  Boston Brewing Company (WA),  Nail Brewing (WA),  Bush Shack Brewery (WA),  Mash Brewing (WA),

34 https://vinepair.com/articles/biodynamic-wine-explained/

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 Otherside Brewing (WA),  Burleigh Brewing Company (QLD),  Red Bay Brewing (QLD),  Barossa Valley Brewing (SA),  Kaijui Beer (VIC),  Dainton Brewing (VIC),  Hawthorn Brewing (VIC). and  Cheeky Monkey (WA).

Figure 15: Some of the WA Craft Beer to be available at the proposed liquor store

4.26 The initiative to support WA Producers not represented elsewhere in the Wanneroo locality is by design, and is in line with the strategic priorities set out in the Taste 2020 Strategy for food and wine tourism in Western Australia from 2015 to 2020. The Strategy for Food and Wine Tourism was created between Tourism Australia and the Western Australian Government and outlines the tourism strategies to meet the demands of food and wine travellers to Western Australian wineries.

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Figure 16: Taste 2020 - Wineries (Source: Taste 2020)

4.27 The Applicant is dedicated to providing these small local producers representation in the proposed liquor store, subject to approval and promoting tourism to WA wine regions including (but not limited to):  Swan Valley (Swan Districts,  Perth Hills,  Peel,  Geographe,  Blackwood Valley,  Manjimup,  Pemberton,  Great Southern,  Southern Forests,  Margaret River and  Central Western Australia.

4.28 All of the above are recognised wine regions in Western Australia that have a reputation for quality, locally made wine products.

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4.29 The primary reason for this is a commitment to supporting local jobs and the tourism economy in WA through the support of local WA producers. Another reason is to reduce the carbon footprint involved in the shipping of liquor products from interstate or overseas.

4.30 The survey results indicated that local consumers like to support local producers, with a majority of respondents indicating Availability of local WA liquor products as a matter they consider when visiting a Liquor store (Attachment 2 - Consumer Surveys). The Applicant is committed to showcasing Western Australian liquor that is not readily available in the locality.

4.31 The above mentioned, small-scale local WA producers can often find it difficult to gain access to the packaged liquor market, as they produce in volumes that cannot be discounted enough to be appealing to large, multinational liquor retailers owned and operated by Coles, Woolworths and more recently ALDI in WA.

Low Alcohol Products 4.32 The Applicant notes that low and mid strength alcohol products are growing in both quality and demand and this growth has been acknowledged in Nielsen data report as reported by news.com.au: “Lighten up - that's the message Australians are sending to wine companies and brewers as consumption of lower-to-mid-strength-drinks grows. Sales of mid-strength beer and lower-alcohol wines are growing twice as fast as all other wines and beers as consumers make healthier lifestyle choices, Nielsen data researchers report. While low alcohol drinks have had a poor reputation for taste in the past, producers have invested in new methods and technology to create drinks with more freshness and flavour. The results have provided the best of both worlds for consumers who want to enjoy the health and social benefits of lower alcohol drinks, without sacrificing the taste.” (Attachment 12 – Mid strength beer and wine).

4.33 Subject to approval, the Applicant intends to stock a low alcohol wine range such as the McWilliams Balance Low Alcohol Range. McWilliams has a selection of varietals including Brut (sparkling), three vintages of both their Semillon Sauvignon Blanc and Shiraz (08, 09 and 2011), McWilliams’ Balance range is “An Australian first, the McWilliam's Balance range is the only range of wines in Australia and New Zealand to be endorsed by Weight Watchers. Weight Watchers and McWilliam's share a common philosophy of helping consumers easily track and be aware of their intake of both food and wine”.

4.34 The James Halliday Wine Companion now also includes a range of low alcohol wines, recognising this growing segment of the wine market: “2017 The People’s Sessions Sauvignon Blanc (9.5%) shows a citrus personality, bringing passionfruit first forward. A great summer choice in the late afternoon, when easing your way through the gorgeous summer sundown

2018 Lindeman's Early Harvest Crisp Dry White (8.5%) is widely celebrated as a flavoursome bottle, that’s refreshing and waistline friendly. Light is its key element, with exotic fruits including papaya that come after.

2017 Amberly Kiss & Tell Moscato (7%) presents rose petal on the nose, with sweet pear notes on the tongue. A crisp wine, that’s sweet and delicate too.”35

35 https://www.winecompanion.com.au/articles/news/low-alcohol-wines-for-a_lighter-january

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4.35 More research is being done into low alcohol wine, by the Australian Research Council: “The Australian Research Council (ARC) Training Centre for Innovative Wine Production (TC-IWP) was established at The University of Adelaide with support from industry partners and Wine Australia. It linked scientific and industrial expertise, contributions and facilities of two universities, four scientific organisations and six industry partners. The research of the ARC TC-IWP focused on strategies to reduce the alcohol content of wine through an integrated, whole-of-production-chain approach that starts in the vineyard, continues through fermentation and post-fermentation and finishes with wine consumers. The projects involved in the TC-IWP investigated: early harvest and blending regimes, the use of Saccharomyces and non-Saccharomyces yeast strains, the individual or combined addition of commercially available winemaking additives and the effects of reverse osmosis/evaporative perstraction (RO/EP) treatment on wine composition and sensory properties. Research into the alcohol ‘sweet spot’ phenomenon and consumers’ acceptability for lower alcohol wines is also being conducted. ”36

4.36 The Applicant intends to stock a range of low and mid alcohol beer(s) that will include (but not limited to) the following:  Coopers Premium Light 2.9%,  Hahn Super Dry 3.5%,  Pure Blonde 3.5%,  XXXX Gold 3.5%, and  Carlton Mid 3.5%.

Non-alcoholic Products 4.37 Additionally, the Applicant also intends to stock Coopers Ultra Light Birell; an Australian made, non-alcoholic beer created using water, barley (malt) and hops. A minimal quantity of alcohol must be produced to create a good tasting non-alcoholic malt beverage. The alcohol content of Coopers Birell is 0.5% volume, which lies below the 0.5% volume maximum alcohol content specified in the statutes as the definition of "non-alcoholic”.

4.38 A new product to market that is rapidly gaining popularity are a range of non-alcoholic spirits. Please find below some of the options available that are produced in Australia: “A lot of things can go down over Christmas lunch, but for ALTD co-founders and siblings Tim and Jacqui, it was the hatching of an idea that would eventually lead to a new line of alcohol-free spirits. The non-drinkers found they were thirsty for the complex flavours that alcohol-based drinks typically afforded, and so, they made their own. Handmade in their micro-batch distillery, using copper stills and 100 percent Australian native and locally grown botanicals – sourced from Indigenous suppliers where possible – the sugar-free elixirs are available in three unique blends: the signature Green Grocer featuring lemon myrtle, thyme and pepperberry, Silver Princess with strawberry gum, cinnamon and honey myrtle, and Golden Emperor boasting roasted blood oranges, caramelised citrus and cinnamon myrtle. A portion of every bottle sold goes to the Jimmy Little Foundation, which aims to improve health care for Indigenous Australians.”

“Another great Australian brand forging its way in the non-alcoholic space is Altina Drinks, the creators of Zero Proof Craft Cocktails. Reimagining the process traditionally used to produce alcohol, the company creates plant-powered cocktails using botanicals (think flowers, fruit, seeds, bark, roots and stems), herbs and spices. Nature’s pantry allows the creators to produce complex flavours and colours without resorting to artificial additives. CEO and scientist Christina Delay brings a Bachelor of Chemical Biotechnology and a Ph.D. in Plant Biology, while CFO Alan Tse ensures Altina Drinks continues to operate as a successful social enterprise by partnering with organisations

36 https://www.wineaustralia.com/research/search/completed-projects/ua-1304

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working in the alcohol harm reduction space. The co-founders have bottled their most popular alcohol-free cocktail, Light Me Up, which is a refreshing and lightly sparkling drop featuring hints of forestberry, wattleseed, apple and green tea”

4.39 The Applicant has researched the demand for these low and no-alcohol products and notes that they appeal to a diverse range of consumers including (but not limited to):  Abstainers - those choosing not to consume liquor , either permanently, or for set periods like ‘Dry July’,  Moderated drinkers – this market may choose to have more “alcohol-free days”, and non – alcohol options permit them to still socialise and enjoy the ritual of a  Pregnant woman - as above, the no-alcohol options allow this group to enjoy the taste and social aspect of ‘having a drink’, while not consuming any liquor, and  Millennials – this group is more socially aware of the negative impacts of excessive alcohol consumption, and  Health conscious consumers – liquor products generally contain high levels of sugar, so these consumers often seek out healthy alternatives.

4.40 The above is supported by research in Australia that indicates Australian consumers of liquor; “Consumers are increasingly demanding healthier alcohol products, as awareness rises about liquor's negative effects, University of Newcastle senior lecturer Tamara Bucher says. Dr Bucher has published a new paper, titled Production and Marketing of Low-Alcohol Wine. She says low-alcohol wine is "an interesting product idea". "You can get the benefits and reduce the negative side effects," Dr Bucher said. If people replaced regular wine with lower alcohol wine, they would "reduce their kilojoule intake and, in the long-term, their cancer risk". Lower alcohol products are a hot topic.

She believes the trend will soon spread to Australia. "Australia might become a leading producer," she said. She said wine naturally contains many healthy components such as polyphenols and antioxidants. "The polyphenol resveratrol has gained a lot of attention for its anti-aging and disease-fighting properties. "We know moderate wine consumption is associated with better health and reduced mortality from all causes."

Dr Bucher's paper said increased awareness about dietary-related diseases may lead consumers to perceive low-alcohol drinks as a healthier alternative. Research showed some people were motivated to drink low-alcohol beverages for calorie and weight management. Some consider low-alcohol beverages an alternative to standard-strength drinks.”37

4.41 The Applicant submits that they will include non-alcoholic spirits in the public interest, subject to the conditional grant of the liquor store licence to Wanneroo Cellars.

The Proposed Premises 4.42 The proposed Wanneroo Cellars will be located in Tenancy 6 of the Retail Shopping Precinct at 957 Wanneroo Road.

37 https://www.illawarramercury.com.au/story/6273165/low-alcohol-wine-on-the-radar/?cs=3155

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4.43 The Liquor Store will have a single entry for patron access that will be monitored by CCTV at all times that the proposed liquor store is operating.

4.44 The entry to the proposed Liquor Store will be under constant supervision by RSA trained staff, to allow customers the option to access appropriate areas of the centre for their personal shopping requirements, while minimising the risk of impulse purchasing and normalising liquor.

4.45 The liquor store will be staffed at all times by an employee that has attained the Manage Licensed Premises (MLP1) qualification, on top of the required Responsible Service of Alcohol qualification.

4.46 The proposed liquor store comprises approximately 263m² of patron browse area, suitably sized to supplement the Retail Shopping Precinct at 957 Wanneroo Road. The proposed liquor store location is shown below:

Figure 17: Location for proposed Wanneroo Cellars

4.47 The proposed liquor store will consist of;  Independent entry and exit,  Fridges for chilled liquor products,  Cool room for self-service of cartons,  Ambient shelf space,  Harm Minimisation signage within the premises,  Point of Sale Area, and  CCTV coverage throughout.

Manner of Trade

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4.48 The proposed liquor store will be a safe and well-managed store that offers a diverse variety of packaged alcoholic beverages to cater to the contemporary requirements of consumers in the locality.

4.49 Mr Arthur Naoum has spent his 30 years in the retail liquor industry honing his premises to provide safe and comfortable browse style premises, with knowledgeable and well trained staff that deliver outstanding customer service.

4.50 The support of unique and small WA producers is also evidenced by the position of two (2) shelves within the store, located in close proximity to the entrance that will be reserved for WA made liquor products exclusively.

4.51 The proposed liquor store (subject to approval) will offer consumers the safety and convenience of purchasing their alcohol requirements before or after they complete their other shopping needs at the Retail Shopping Precinct at 6/957 Wanneroo Road.

4.52 The Applicant believes that this will be especially relevant for the large number of existing residents who live on the West side of Wanneroo Road, and will also cater to the requirements of the growing number of residents forecast to move into the locality and those who resort to the locality for work or to visit friends.

4.53 The proposed liquor store will adhere to all of the DLGSC’s Policies regarding the sale and supply of liquor for consumption off the premises, as per Section 4738 of the Liquor Control Act 1988.

4.54 The Applicant will also strictly adhere to the Industry Guideline on the Responsible Promotion of Alcohol – Consumption of Liquor on Licenced Premises and the Sale of Packaged Liquor39 The Applicant makes a commitment to not; 1. “Promote and advertise alcoholic drinks that suggest irresponsible or excessive consumption of liquor with emotive titles such as – “laybacks”, “shooters”, “slammers”, “test tubes”, and “blasters”. 2. Promote and advertise alcoholic drinks that by virtue of their design or packaging encourages irresponsible drinking behaviour and are likely to result in rapid intoxication (for example prepackaged shooters or tooth paste style tubes containing alcohol). 3. Display or use promotional or branding material in promoting and advertising alcoholic drinks that by virtue of the design or packaging have a strong appeal to children or adolescents (e.g. “alcopops” or naming of the product and/or design using cartoon-like colouring and images). 4. Display or use promotional, advertising or branding material, which contains children or adults under the age of 25. 5. Display or use advertising material that suggests the consumption or presence of alcoholic drinks may create or contribute to a significant change in mood or environment and accordingly must not depict the consumption or presence of alcoholic drinks as a cause of or contributing to the achievement of personal, business, social, sporting, sexual or other success. 6. Display or use advertising material that depicts any direct association between the consumption of alcoholic drinks and the operation of a motor vehicle, boat or aircraft or the engagement in any sport (including swimming and water sports) or potentially hazardous activity and, accordingly any depiction of the consumption of alcoholic drinks in connection with the above activities must not be represented as having taken place before or during engagement of the activity in question and must in all cases portray safe practices.”

38 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s47.html 39 http://www.rgl.wa.gov.au/docs/default-source/rgl/responsible_promotion_of liquor for consumption _on premises.pdf?sfvrsn=0

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Staff Training 4.55 The staff at the proposed liquor store will all hold RSA certificates and have a copy kept on the premises at all times as per the Director’s Policy on Mandatory Training.

4.56 Staffing levels will be strictly monitored and maintained to ensure a high level of customer service and satisfaction at all times, with additional staff rostered on during peak times.

4.57 Upon employment, staff will be provided with a Staff RSA Handbook (Attachment 5a) and advised that adherence to the policies and procedures within the handbook are prerequisites for employment and must be adhered to at all times.

4.58 Staff will also be provided with additional training in specific products available at the liquor store, with particular regard to the nature of and location of:  Locally produced liquor products from smaller WA Producers,  Low alcohol liquor products (wine, cider and beer), and  High risk products (i.e. spirits) to be located behind the POS counter.

4.59 Staff working at the proposed liquor store will also be trained in basic food and wine/beer matching, so they can assist patrons by making recommendations in line with consumer requirements.

4.60 This training will be delivered by winemakers, brewers and other producers/suppliers to educate the liquor store staff about their products including information relating to flavour profile, complementary and contrasting flavours, vintages and any other relevant product information.

Harm Minimisation 4.61 The proposed Wanneroo Cellars will operate under a strict Harm Minimisation Plan (Attachment 1) at all times. The Harm Minimisation Plan incorporates a Code of Conduct, House Management Policy and Management Plan which provide guidance to both staff and patrons relating to the standards of behaviour expected on the licensed premises.

4.62 The Applicant will support programs, practices and policies that address issues related to the misuse of alcohol, and encourage consumers to make responsible decisions about consuming alcohol – or not consuming it.

4.63 The Applicant aims to provide consumers with as much information as they need to be better informed about the products they are purchasing and ultimately consuming responsibly. This could include product information, pointing out the ABV or other relevant factors.

4.64 The Liquor Store Licence (subject to approval) will permit the Applicant to provide consumers with value for money, locally produced, and low-alcohol products not easily available at the other liquor stores in the defined locality.

4.65 The Applicant respectfully submits that there is no other liquor store in the locality that offers the same support for a range of WA products, is independently owned and operated, has the same dedication to a high standard of customer service, and provides the same level of convenient accessibility, and therefore it would be in the public interest to conditionally grant this application.

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5. Legislative Framework – Liquor Control Act 1988 5.1 The Applicant has considered the relevant sections of the Act in compiling this PIA submission for the proposed Wanneroo Cellars. The legislative framework concerning this application includes, but is not limited to:  The effect of Liquor Store licences (Section 4740),  The powers of the licensing authority when deciding applications (Section 3341),  The primary and secondary objects of the Act (Section 542),  The matters the licensing authority may have regard to in determining whether granting an application is in the public interest (Section 3843 Subsections 2 and 4), and  Documentation to support the application (Section 6844).

5.2 The licence application is in accordance with Section 47 of the Act which states; (1) Subject to this Act, during permitted hours the licensee of a liquor store licence is authorised to keep open the licensed premises and to sell packaged liquor on and from the premises to any person. (2) The licensee of a liquor store licence is authorised to supply liquor, by way of free sample — (a) for consumption on a part of the licensed premises approved for the purpose by the Director; or (b) for consumption off the premises.45

5.3 The powers of the licensing authority when deciding applications are identified in Section 33 of the act that clarify; (1) Subject to this Act, the licensing authority has an absolute discretion to grant or refuse an application under this Act on any ground, or for any reason, that the licensing authority considers in the public interest. (2) An application — (a) may be refused, even if the Applicant meets all the requirements of this Act; or (b) may be granted, even if a valid ground of objection is made out, but is required to be dealt with on its merits, after such inquiry as the licensing authority thinks fit.46

5.4 Section 38 of the Act notes that applications are not to be granted unless they are in the public interest. This PIA addresses the points outlined in subsection 4 in substantial detail regarding; (a) the harm or ill-health that might be caused to people, or any group of people, due to the use of liquor; and (b) the impact on the amenity of the locality in which the licensed premises, or proposed licensed premises are, or are to be, situated; and (c) whether offence, annoyance, disturbance or inconvenience might be caused to people who reside or work in the vicinity of the licensed premises or proposed licensed premises; and (ca) any effect the granting of the application might have in relation to tourism, or community or cultural matters; and (d) any other prescribed matter.47

40 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s47.html 41 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s33.html 42 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s5.html 43 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s38.html 44 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s68.html 45 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s47.html 46 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s33.html 47 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s38.html

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5.5 The primary objects of the Act as set out in Section 5 (1) are: (a) To regulate the sale, supply and consumption of liquor;  The Applicant will ensure that the daily operation of the proposed premises is in accordance with their strict Harm Minimisation Plan.  The Applicant has operated packaged liquor outlets in Western Australia for the past 30 years and has an in depth understanding of the requirements of consumers in the Wanneroo locality, subject to undertaking the Consumer Survey, door knocking exercise.  There will be CCTV coverage throughout the store including, the entrance, exit and delivery area.  The premises will be staffed by RSA trained employees and overseen at all times by a suitably qualified Approved Manager. This requirement of additional training for staff at the proposed liquor store is to ensure that all staff involved in the sale and supply of alcohol have an in-depth understanding of the regulatory and legislative responsibilities of their position and ensures best practise harm minimisation strategies are in place at all times.  Given the size of the proposed liquor store it is anticipated that (generally) the staff member working at the licensed premises will hold the higher qualification of Manage Licensed Premises.  The Applicant will require all staff involved in the sale and supply of alcohol at the proposed liquor store to undergo regular, ongoing, in-house training in responsible service of alcohol and customer service (Attachment 5a).  The inclusion of visual signage that will reflect the Licensing Authority’s strict regulations relating to the purchasing of takeaway packaged liquor.

(b) To minimise harm or ill-health caused to people, or any group of people, due to the use of liquor;  The Applicant is an experienced and mature retail liquor operator, and has extensive experience in successful packaged liquor business management.  The Applicant has a good awareness of the concerns of people and groups in the locality, and is committed to ongoing engagement and communication with local residents and business owners or ‘at risk’ groups who may be affected by the proposed store (subject to approval).  In consideration of feedback during the Community Consultation, the Applicant will accept a self-imposed condition on the licence stating: ‘’Subject to approval, the Applicant will open the premises at 9.00am (instead of the normal 8.00am) on school days’’.  The Applicant will stock a range of low and no-alcohol wine and beer products that will encourage more responsible drinking practices.  The proposed Wanneroo Cellars will not be a discount liquor store or carry cask wine in over 4L casks.  Spirits will be displayed behind the licensed POS.  The premises will have automatic doors installed that register an audible noise when someone enters or exits the store.  The proposed Liquor Store is suitably located within an existing retail precinct at 957 Wanneroo Road, minimising the potential risk of harm or ill health to the juvenile ‘at risk’ group within the locality.  The layout of the proposed liquor store will be consistent with the Design out Crime Planning Guidelines 200648 incorporating CCTV coverage throughout the store with appropriate lighting and secure locking devices.  Combining the robust Harm Minimisation Plan (Attachment 1) with other initiatives and comprehensive training, that also considers the existing consumers who frequent the Retail Shopping Precinct at 6/957 Wanneroo Road, will minimise any risk of harm or ill health.

48 https://www.dplh.wa.gov.au/getmedia/87627346-3ade-4e6a-99f0-31365a215f3c/GD_designing_out_crime

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(c) to cater to the requirements of consumers of liquor and related services, with regard to the proper development of the liquor industry, the tourism industry and hospitality industries in the state;  The door knocking Consumer Survey exercise provided evidence that local consumers in the locality want an independent, locally owned and operated liquor store to provide an alternative to the large chain stores that are the only options currently available in Wanneroo. Hence, the approval of this application will cater to the requirements of consumers in the locality.  The Applicant is committed to the proper development of the local liquor and tourism industries, by supporting the WA producers of beer, cider and wine in the locality, some of which are predominantly available at the Cellar/Brewery Door, and which is supported by the Taste 202049 initiative by the WA State Govt.  The article ‘Who Makes My Wine’ (Attachment 10) demonstrates that Coles and Woolworths devote a large portion of their offering to their own brands at reduced prices. The Applicant will ensure they promote genuine, local WA Producers to support direct and indirect jobs, and food and beverage tourism in WA.  Subject to approval, the new independently owned liquor store will provide direct employment opportunities, support the local WA alcohol industry, create additional, indirect employment opportunities and market access for smaller producers.  The conditional grant of the application for the proposed liquor store will provide patrons the option of purchasing their liquor locally at an independently owned and operated store, as evidenced in the Consumer Survey results.  The Consumer surveys also provide cogent, objective evidence that there are existing consumers in the Wanneroo locality that would patronise the proposed liquor store.

5.6 The secondary objects of the Act as set out in Section 5(2) are:

a) To facilitate the use and development of licenced facilities, including their use and development of live original music, reflecting the diversity of requirements of consumers in the state;  The proposed Wanneroo Cellars will carry a selection of locally produced WA alcohol products (see Venue and Operation) and low-alcohol beer and wine choices that are not readily available in other liquor stores in the locality.  The proposed liquor store will complement the other businesses at 957 Wanneroo Road, and provide a conveniently accessible amenity to consumers who frequent the centre for their other household requirements. This is particularly relevant to those persons living west of Wanneroo Road and is supported by the Consumer Survey results (Attachment 2).  The premises will open at 9.00am on school days, to further minimise any potential harm or ill-health in the locality.  The Consumer Survey provided cogent evidence that a significant percentage of the respondents wanted an independently owned and operated liquor store in Wanneroo. Currently in Wanneroo, the retail liquor offering is monopolised by large supermarket chains operates, with no independent offering. The survey results demonstrate that over 95% of consumers in the locality want an independent, packaged liquor option.  The word cloud generated by the survey collation tool, provided the following key words from the survey respondents:

49https://www.tourism.wa.gov.au/Publications%20Library/About%20Us/Taste_%202020_A_Strategy_for_food_and_ wine_tourism.pdf

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d) To provide adequate controls over the persons directly or indirectly involved in, the sale, disposal and consumption of liquor;  The Approved Manager will be available at all times to respond to the concerns of patrons, local residents and local law enforcement, and to oversee the store’s operation in compliance with all licensing and regulatory requirements.  All employees will undergo the appropriate RSA training from a Nationally Accredited Training Provider, and their qualifications kept in a Training Register on the premises, in accordance with the Director’s Policy on Mandatory Training50 last amended on 12 June 2019.  The Harm Minimisation Plan that incorporates a Code of Conduct, Management Policy and House Management Plan that will be observed by patrons, staff and management at all times (Attachment 1).  Visual signage will be used within the store to remind both patrons and staff of the strict Liquor Licensing requirements in relation to the sale and supply of packaged liquor.  A comprehensive, secure CCTV system will be installed at the proposed liquor store, with cameras covering the entrance and exit along with the delivery area.

e) To provide a flexible system, with as little formality or technicality as may be practicable for the administration of this Act; and  The Applicant via their representative contacted the WA Health Department Chief Health Officer (CHO), the WA Police Liquor Enforcement Unit (LEU) and various ‘at risk groups’ within the locality (Refer point 9 – Community Consultation) of the application and will continue to work with these organisations throughout the application process as required.  The Applicant seeks, with respect, that this application be conditionally approved in the public interest subject to satisfying the requirements of the Liquor Control Act 1988 and at the discretion of the Director of Liquor Licensing having satisfied both the primary and secondary objects of the Act, provided cogent objective evidence that there is a consumer requirement for the proposed premises and addressed all relevant public interest matters.

f) To encourage responsible attitudes and practices towards the promotion, sale, supply, service and consumption of liquor that are consistent with the interests of the community.  The Applicant is committed to ensuring that the operation of the liquor store is responsibly implemented and operated to cater to the contemporary requirements of consumers within the locality.  The proposed Wanneroo Cellars will not be a discount liquor store or carry cask wine in over 4L casks. Spirits will be displayed on shelving behind the POS.  Consumers have indicated that they think a small packaged takeaway liquor offering will be patronised by them, as outlined in the Consumer Survey results.

50 https://www.dlgsc.wa.gov.au/department/publications/publication/mandatory-training-and-training-register-policy

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6. Public Interest 6.1 Based on these researched and considered PIA submissions (including attachments), Parkview Enterprises Pty Ltd respectfully submits that the conditional grant of a Liquor Store Licence for the proposed Wanneroo Cellars would be in the public interest as per Section 38 (4) of the Liquor Control Act 1988, whilst upholding the primary and secondary objects of Section 5 of the Act for the following reasons;  Provide an independent, family owned and operated packaged liquor offering to complement the amenity of the existing Retail Shopping Precinct.  Operate the liquor store to cater to the contemporary requirements of the locality with outstanding customer service and a diverse range of products with no heavy discounting and/or offering cheap, bulk liquor products.  Provide employment options for residents in the locality, including full, part time and casual roles.  Provide ‘Tasting’ opportunities and product knowledge information.  Provide a product list that promotes and supports WA liquor producers including local producers that are not currently represented by the large supermarket chains in the locality.  Offer personalised service through product order forms so consumers can request products they require be made available to them at a convenient location to their shopping.  Include a range of non-alcoholic and low-alcohol liquor products that are growing in popularity and are currently unavailable in the locality.  Provide more competition in the locality, as required by consumers and as demonstrated by the Consumer Survey results.  Implement and enforce a strict Harm Minimisation Plan in the interest of the public and to minimise any potential undue harm due to the use of liquor.

6.2 The Applicant has many years’ experience operating retail liquor stores and understands the evolving requirements of consumers in the area, which has been considered in the proposed offering to be available at the proposed liquor store.

6.3 The Applicant’s reputation as a responsible business owner and operator, extensive engagement directly with local residents during the collection of the Consumer Surveys, community consultation with businesses and organisations that deal with ‘’at risk’’ people and groups of people, strong harm minimisation initiatives designed for the premises and knowledge of the local area offering will ensure that the proposed business operates in the public interest, subject to this application being approved.

6.4 The Applicant aims to provide an independent packaged liquor offering within the Retail Shopping Precinct that will provide the convenience, choice and product offering required by many consumers in the locality, and that is not currently available to them.

6.5 Importantly the independent owner/operator, and convenient and easily accessible location on the western side of Wanneroo Road were two of the most favoured aspects of the application, when the Consumer Survey was conducted in the locality.

6.6 The operation of an independent packaged liquor store amenity will increase employment and training opportunities within the locality, by creating new jobs in the proposed Wanneroo Cellars, and will also benefit the other businesses at 957 Wanneroo Road by increasing the range and diversity of amenity available, as evidenced by the Letters of Support (Attachment 3) provided.

6.7 Further, the proposed Wanneroo Cellars will also provide an alternative liquor retail outlet for the high percentage of residents in the area who would prefer to support an independent store, as

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opposed to those owned and operated by the large national supermarket chains. This is strongly supported by the results of the Consumer Survey (Attachment 2).

6.8 This benefit was demonstrated in the Directors determination for the Conditional Grant of a Liquor Licence, in the Decision A223164 and based on the evidence before the Director, may also be applied to this application; “many members of the local community would find it convenient to purchase their packaged liquor requirements at the applicant’s proposed liquor store, particularly when using other services at the shopping centre.”

6.9 Relevantly; convenience, choice and an independent operator were strong factors within the local community to grant the application in the public interest, with an independent operator conspicuously missing from the current amenity in Wanneroo.

Negative impacts of national supermarket chains – retail liquor 6.10 The difficulties faced by smaller, WA producers due to the predatory pricing practices of the large national chain supermarkets is demonstrated in an article by the Master Grocers Association (Attachment 9 – MGA Article) and which states; “Coles and Woolworths have achieved close to 80% market share and in so doing have killed off small businesses around the country. Did they intend to kill these small competitors by using (or misusing) their huge market power? Commonsense tells us the answer. But the current laws make it almost impossible to prove. The duopoly can drive closer to 100% market share by killing the small amount of competition that remains. That’s why we argue that it’s time now to judge Coles and Woolworths on the effect of their actions rather than what they say is the intent of their actions. Because whatever way you look at it, small businesses and small towns are having the life crushed out of them.”

“The argument runs that with lower supermarket prices people will have more money to spend on other things and therefore possibly rejuvenate a town in other ways. This is fine in theory but we know that in practice Coles and Woolworths will also be seeking to snare that money as well, either through their supermarkets or through other stores which they own. Woolworths, for example, has established a hardware store in the new complex. It will soon open a BWS liquor store and before long perhaps open a petrol station. “

“This is a practice which we call “predatory capacity”: providing a huge amount of supermarket space which can only run at a loss and doing this up to the point that smaller competitors simply give up and go away.

One of the best examples of this is occurring now in a small seaside town called Shearwater, in the North-West of Tasmania. In truth the war for total dominance in the Australian market is being fought out in small towns like Shearwater, so it’s worth taking a closer look.

Shearwater is an idyllic little spot, a quiet town which serves a total population of around 4,300 people all up when you take in surrounding areas.

It’s already well served by a smattering of small shops such as a baker, a butcher, liquor stores, a newsagent and a mid-sized Supa IGA. The population is unlikely to get much bigger over the coming years.

Yet, despite there being absolutely no need, as of April this year a new Woolworths store has opened with 2,000 square metres of space, in a new complex complete with a post office, a chemist, etc and a BWS liquor store to come.

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The council has been aware that local businesses will be damaged as a result and that the town centre may well empty out. As well no less than 2,800 locals signed a petition to oppose it. Yet despite more than half the population being opposed the council approved the development.

The facts sound too bizarre to be true – but they are.”

6.11 The above can also be applied to the retail liquor offering at the big two national chains (Coles and Woolworths), and the Applicant submits that during their doorknocking efforts to gauge local opinion about the proposed Wanneroo Cellars (via the consumer surveys completed) by local residents, having the option to support a small, independent operator was a very relevant and strongly supported aspect of the application.

6.12 In addition to their predatory pricing practices, Coles, Woolworths and now ALDI have also increased production of their ‘own brand’ liquor. This ‘own brand’ liquor has an enormous negative impact on the ability of small, local producers to compete in the retail liquor market, as the supermarket brand liquor appears just like brands you would buy from a local family owned and operated vineyard.

6.13 These products are not labelled as ‘Woolworths Shiraz’ or ‘Coles Lager’ but are branded and marketed like any other Australian wine/beer product. For the average consumer, it is becoming increasingly difficult to tell if a product is ‘own label’ as there is no mention of Coles or Woolworths owning the companies on the bottles. “Private labels reduce potential shelf space for growers who make and market their own wine. These private labels also allow Coles and Woolworths to be ultra-price competitive as they have removed the middle man.

Private-label wines have been attracting the attention of parliamentarians with a parliamentary committee calling for an investigation into whether supermarkets Coles and Woolworths are lining their shelves with private-label wines, squeezing out traditional winemakers.”

6.14 Coles has disclosed that “about 10 to 20 per cent of the wine brands sold by its liquor arm - Liquorland, Vintage Cellars, First Choice and Liquor Market - are private label, and it plans to increase that number”.51

6.15 Of the brands that Coles owned liquor stores offer to consumers, 81 brands are private label52. Many of these brands are also low in price, with private label wine accounting for 35% of all wine sold under $15 a bottle in Australian supermarkets53.

6.16 The negative impact this has had on some local wine producers is evident in the Wines of WA Senate Submission, submitted with the application.

6.17 Subject to approval, Wanneroo Cellars will use their retail space to showcase a selection of products from small producers who are finding it increasingly difficult to attain retail representation in the national chain dominated market. This is supported by the local producers who have provided letters to support the grant of the application in the public interest.

51 https://www.smh.com.au/lifestyle/revealed-the-victorian-winery-behind-aldi-and-coles-awardwinning-5-wine- 20161209-gt7ef2.html 52 https://www.therealreview.com/who-makes-my-wine/ 53 https://www.crackawines.com.au/blogs/wineries/james-busby

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6.18 The negative impact of the duopoly entrance into winemaking on traditional wine producers is further explored in the article Who Makes My Wine (Attachment 10) that states (emphasis added): “Private labels reduce potential shelf space for growers who make and market their own wine. These private labels also allow Coles and Woolworths to be ultra-price competitive as they have removed the middle man. Private-label wines have been attracting the attention of parliamentarians with a parliamentary committee calling for an investigation into whether supermarkets Coles and Woolworths are lining their shelves with private-label wines, squeezing out traditional winemakers. This followed a report from the House agriculture committee released in June 2013 that raised concerns about the dominance of private-label wines and the impact on competition. Across all grocery items the ACCC is conducting a long-running investigation into allegations of bulling and margin squeezing by Coles and Woolworths against their suppliers and farmers.”

6.19 In the context of Taste 2020 – A strategy for food and wine tourism in Western Australia, tourism visitors cannot go to ‘Cow Bombie’, ‘Pensilva Estate’, or ‘Across the Bay’ as those wineries do not exist. They are simply labels and names to make the Coles and Woolworths branded wine appear as if it is a premium product.

6.20 The proliferation of these brands and labels being promoted by Coles and Woolworths to further their own profits offers no benefit to food and wine tourism in WA, and discourages visitation to our famous wine growing regions. By comparison, some of the local products to be stocked by the Applicant (subject to approval) have more limited avenues to market, and struggle to get shelf space at the large chain stores that control such a large percentage of the packaged liquor trade in WA.

6.21 In an article on the Australian Wine Selectors website, winemakers provide their feedback regarding the growing dominance of ‘own brand’ wines in Australia: “Australian winemaker John Cassegrain also feels strongly about being honest with wine-lovers. The expectation from consumers is that they are buying hand-crafted wine from a vineyard estate, but the labelling of ‘home brands’ by the supermarkets is, in effect, cheating. They are not hand-crafted wines, in actual fact, they are manufactured wines, so to me it reeks of misrepresentation.”

“I think wine consumers need to understand what they are buying and where these are made,” agrees Leigh Dryden of Decante This. “There are so many ‘own brands’ out there it has become increasingly hard to tell the authentic from the bogus. Retailers, makers and distributors have nothing to fear of the truth.”

Even more vehement about the issue is Mornington Peninsula winemaker, Garry Crittenden. “Speaking as someone with first hand experience of the way the major supermarkets treat their relations with wine suppliers, I can honestly say it beggars belief that, in the face of continuing opprobrium, they still treat the industry and their customers with an indifference bordering on contempt. But maybe it’s not so surprising when it’s simply part of the embedded culture surrounding supplier relations,” says Garry. Is it asking too much of them that they disclose a particular house wine is just that and the brand is owned by them?”54

6.22 Consumer watchdog CHOICE has also weighed in on supermarket brand wines and stated: “Supermarkets are steadily buying up wine retailers, wine producers and vineyards, and using private labels to squeeze out smaller producers.

54 https://www.wineselectors.com.au/selector-magazine/wine/who-makes-my-wine

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Labels such as Lovers Not Toreadors, Chook Shed and The Fabulist sound like limited-release drops handcrafted by quirky winemakers, but they're actually Coles and Woolworths brands.”55

6.23 Wines of Western Australia also highlighted the difficulties faced by small regional wine producers in their submission to the Senate (Attachment 11 – Wines of Western Australia Senate submission) and which stated: “In pure economic theory terms, market monopoly through the Coles/Woolworths duopoly is the key market failure affecting the Australian grape and wine industry. These two conglomerates account for over 70% of all retail wine sales through various channels they control (WFA Expert Report on the profitability and Dynamics of the Australian Wine Industry Aug 2013). The duopoly’s dominance diminishes available shelf space for genuine producers (through displacement by buyer’s own brand products). A secondary effect is fewer wholesalers (the duopoly act as quasi wholesalers and remove that part of the supply chain) who provide wine producers with access to other retail opportunities. In 2005, Coles and Woolworths had 5% of sales as home/exclusive brands. Today this is estimated at 20-25%. This trend also exists in other retail liquor chains. The ability of the duopoly to dominant the retail market and thus gain excessive market power vis-à-vis wholesalers and producers distorts the economy. This is exacerbated by:  allowing these two retailers to act as wholesalers (dealing direct with producers)  allowing these two retailers to operate as “producers” by owning private labels.”

6.24 The Applicant submits that the positive economic benefit of supporting the local wine industry in WA is significant, particularly in regional areas, where agricultural and farming activities and cellar door sales are strong employers. Adverse effects to local wine producers have a negative impact on regional areas, as stated by Wines of Western Australia in their submission; “The distortion is that an entire industry (e.g. food and beverage) is decimated, many small businesses are precluded from a reasonable opportunity to trade, the public are misled as to the true source and nature of the products offered, and legitimate traditional businesses and skills are lost – e.g. wholesaling, etc… The rewards for any perceived productivity gains are not shared equally by the community, diversity of products is lost, and the regional communities that host the primary farming activities are damaged with losses of jobs and services and ultimately a lower standard of living or ability to re- invest and regenerate.”

6.25 The Applicant strongly supports independent Western Australian suppliers and producers of wine, craft beer and liquor by allowing them retail exposure in an industry that is becoming increasingly difficult for local small businesses to compete in. This is evident through the Letters of Support (Attachment 10) from numerous small Western Australian producers who are appreciative that the proposed independently operated liquor store will have a strong focus on supporting the future of the local industry, WA tourism and the economy.

Tourism Impacts of the Application 6.26 The Applicant submits that supporting smaller, WA Producers such as those outlined above, supports regional food and wine tourism, as outlined in Taste 2020 – A strategy for food and wine tourism in Western Australia56.

6.27 Taste 2020 states (emphasis added): “Culinary tourism is one of the fastest growing sectors of the tourism industry.

55 https://www.choice.com.au/food-and-drink/drinks/alcohol/articles/are-wine-clubs-worth-it 56 https://www.tourism.wa.gov.au/Research-Reports/Other-reports/Pages/Taste_2020_- _A_Strategy_for_Food_and_Wine_Tourism.aspx#/

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With our well-established hospitality, viticulture, agriculture and fishing industries, Western Australia has the potential to be one of the world’s foremost culinary tourism destinations.

Taste 2020 provides the blueprint for Western Australia to cement its reputation as an extraordinary destination to experience delicious gourmet produce, succulent fresh seafood, premium wines and boutique beverages such as craft beer and cider.

Extensive market research and a significant amount of consultation were undertaken to develop this strategy, with consultation sessions in late 2013 stretching from Perth to Kalgoorlie, north to Kununurra and south to Albany.

Determining the fundamentals of this strategy took a tremendous State-wide effort, but the hard work doesn’t stop with the production of this document.

For Taste 2020 to be a success, it will require the continued backing of a range of non-tourism industry sectors and regulatory bodies.

With this ongoing support, the strategy will play a major role in helping increase tourism spend in Western Australia to $12 billion by 2020.

On a regional level, culinary tourism will encourage visitors to travel throughout the State, generating direct economic and social benefits for these communities.”

6.28 The Taste 2020 strategy will be covered in more detail, further in this submission.

6.29 Local residents that were surveyed could see the benefits to the proper development of the Western Australian liquor and tourism industry, from a (proposed) Licensee who supported smaller WA Producers. This is due to the proposed liquor store committing to showcase a range wine, craft beer and liquor from Western Australian producers that are not readily available within the locality. This was noted as one of the important factors in LC 18/2015 at [125]; “Convenience is just one factor to be considered when considering the requirement of consumers for liquor - under the current Act it must be considered having regard to the proper development of the liquor industry, the other objects of the Act and, of course, the public interest.”57

6.30 In addition, the curated range of WA made liquor from small, genuine Producers provides a significant point of difference between the proposed liquor store and other liquor stores within the locality. The location of the liquor offering within a designated Town Centre precinct, along with the experience of the operator are consistent with the grounds of approval in LC 09/2017 [43]; “c) The Applicant is an experienced operator; d) The Applicant is a responsible operator; g) There is a significant diversity between the products sold by ALDI and the BWS store that will operate in the same supermarket complex; j) The location of the licensed area is such that it will be separated from the rest of the supermarket, thus avoiding concerns of normalising liquor;”58

6.31 The proposed Wanneroo Cellars would also increase patronage to the current businesses located at the Retail Shopping Precinct at 957 Wanneroo Road, strengthening the centre’s appeal to the local community and those resorting to the premises due to its convenient location, diverse and complimentary offer.

57 http://www.rgl.wa.gov.au/liquor/director's-decisions/decision-search 58 https://www.liquorcommission.wa.gov.au/decisions

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6.32 The Applicant believes that the proposed liquor store, operating under a Liquor Store licence, will have a positive social and economic impact in facilitating the growth of the hospitality, liquor, tourism and retail industries by increasing the amenity available and providing a one-stop shopping convenience commensurate with the expectations of consumers.

6.33 The Consumer Survey was undertaken by doorknocking residents in close proximity to the proposed liquor store, and at the Retail Shopping Precinct at 957 Wanneroo Road. The intention of the Consumer Survey is to gauge community interest in the proposed liquor store (Attachment 3 – Consumer Surveys). Please find below the results of the Consumer Survey:

Q1. Please tick the box that best describes you; 54.69% indicated I live in Wanneroo*. 29.69% indicated I live in close proximity to the proposed liquor store. 7.42% indicated I travel to or through Wanneroo for work. 3.52% indicated I drive past the retail precinct at 957 Wanneroo Road regularly. 0.78% indicated I would visit the proposed store to purchase the specialty products available there. 2.34% indicated I would visit the proposed store to support an independent operator in the locality. 1.56% indicated Other *At least 85% of the survey respondents lived in Wanneroo (suburb), however some gave different responses to this question. Please refer to the hard copy surveys (Attachment 2a - 2g). All the survey respondents who were doorknocked gave ‘Wanneroo’ as the suburb they lived in at question 14.

Q2. My age group is? 17.58% indicated 18 - 25 31.25% indicated 26 - 40 21.88% indicated 41 - 55 29.30% indicated Over 55

Q3. When choosing a liquor store, what do you look for? (Please tick all applicable). 90.23% indicated Great customer service. 53.52% indicated Knowledge of staff. 21.88% indicated Ability to purchase organic, bio-dynamic and preservative free products. 11.72% indicated Ability to purchase dietary specific products. 67.97% indicated Availability of local WA liquor products. 17.19% indicated Range of low and no-alcohol options including beer, wine and spirits. 87.50% indicated Easy to access liquor store. 82.03% indicated Independently owned and operated (i.e. not by large National chains). 3.13% indicated Other.

Q4. Do you support the application for the proposed, independently owned and operated liquor store within the retail precinct at 6/957 Wanneroo Road Wanneroo WA 6065? 94.14% indicated Yes 3.91% indicated No 1.95% indicated Unsure

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Q5. If you answered YES to question 4, how often might you shop at the proposed Wanneroo Cellars? 59.51% indicated Weekly 29.55% indicated Fortnightly 8.50% indicated Monthly 2.43% indicated Other

Q6. If you answered YES to question 4, what aspects of the proposed Wanneroo Cellars are important to you? (Please tick all applicable) 23.08% indicated Availability of organic, bio-dynamic and preservative free products. 17.80% indicated Availability of dietary specific products. 83.40% indicated Availability of local WA liquor products. 25.51% indicated Range of low and no-alcohol options including beer, wine and spirits. 88.66% indicated Independently owned and operated (i.e. not by large National chains). 12.15% indicated Tasting and education opportunities. 7.69% indicated Availability of WA cleanskin wines. 84.21% indicated Not located within a shopping centre. 2.43% indicated Other (please specify).

Q7. How do you feel about the product range in existing liquor stores in the locality? 26.95% indicated Lack of organic, bio-dynamic and preservative free products. 18.75% indicated Lack of dietary specific products. 72.27% indicated Lack of local WA liquor products. 25.78% indicated Lack of low and no-alcohol products. 88.28% indicated All owned by large national retail chains with standard range. 10.94% indicated Lack of tasting and education opportunities. 12.50% indicated Lack of WA cleanskin wines. 3.91% indicated Other (please specify). “Lack of parking to hard to get to.” “limited choice options”

Q8. Where do you currently purchase your liquor requirements? 43.36% indicated BWS Wanneroo 25.00% indicated Liquorland Wanneroo 12.50% indicated Dan Murphy’s Wanneroo 1.17% indicated Aldi Wanneroo 17.97% indicated Other (please specify).

Q9. Would you appreciate the opportunity to patronise the proposed, independent liquor store given the products to be available and the proposed, easily accessible location? 94.14% indicated Yes 2.73% indicated No 3.13% indicated Unsure

Q10. Do you believe that a new, independently owned liquor store within the retail precinct at 957 Wanneroo Road will cause undue harm or ill-health, disturbance, annoyance, inconvenience or any other adverse impact to the locality? 1.17% indicated Yes

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94.14% indicated No 4.69% indicated Unsure

Q11. When weighing and balancing the positive and negative aspects of granting a liquor licence, the licensing authority must weigh and balance the competing needs of the residents, workers, ‘at risk’ groups and the local community to establish whether or not the application is in the public interest.

Please state whether you believe the application for an independent liquor store at the retail precinct at 957 Wanneroo Road, Wanneroo WA 6065 is in the public interest or not. 94.53% indicated Yes 3.91% indicated No 1.56% indicated Unsure

Any other comments on the proposed liquor store application? Please find below a word cloud comprised of the comments left by the survey respondents:

Figure 18: Word cloud created form comments made by Consumer Survey respondents (Source:https://www.surveymonkey.com/analyze/0bvUm5Tlat_2FUR5USoVxs_2BhV_2FyMlvNcKuQlbNd_2F9 ZL1Y_3D)

6.34 The Applicant submits that the data on the Consumer Survey incontrovertibly demonstrates that:  88.66% of consumers in the locality want the option of a local Independent operator in Wanneroo,  83.40% of consumers in the locality want a liquor store that will support WA Producers, and  84.21% of consumers in the locality do not wish to go into a Shopping Centre to access a liquor offering.

6.35 In addition to the 256 Consumer Surveys conducted, the Applicant received numerous letters of support from local WA producers relating to their limited access to local liquor stores in the locality.

6.36 The Applicant submits that many of these letters relate directly to small, WA Producers ability to sell their products, and to promote food and wine tourism in WA, based on the fact that they are getting less and less representation in the supermarket chain liquor stores, due to Coles,

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Woolworths and ALID making more and more of their ‘’own brand’’ products, and giving those products preference when it comes to retail market access.

6.37 Please find below, excerpts from the Letters of Support below:

“We share Mr Naoum’s vision to cater to the contemporary needs of the public with changes in the alcohol product market such as the growing trend in the need for low-alcohol wine, organic, preservative free and dietary specific alcohol products.

Karafilis Organics is a small, family owned and operated business in the Blackwood Valley. Our family have farmed in the area for many years and understand the need to preserve and nurture healthy soils and create a sustainable lifestyle for their families. This commitment is best seen at vintage when family members, young and old, gather from far and wide to pick, sort, crush and press the grapes. We use minimal amounts of preservative in our wine to ensure the quality of our product. We do not fine our wines with any dairy, egg or fish products leaving them vegan friendly and full of flavour. We run our vineyard and winery organically for the benefit of the earth and our family that live in and around the area.

I fully support the liquor store application to be conditionally granted as it is in the public interest and will aid in the ongoing development of the liquor industry by serving the changing needs of the local consumers of alcohol in the locality. ” Dion Karafilis, Partner, Karafilis Organics

“Truffle Hill Wines currently have no representation in the Wanneroo locality as they are dominated by Woolworths, Coles and ALDI, all of whom make their own wines, and give their ‘’home-brand’’ products’’ priority over small WA producers. Given our past experience with Mr Naoum, and his demonstrated support for small Producers, we believe his offering will be different to that currently available. While there are currently liquor stores in Wanneroo, none of them stock our Truffle Hill Wines range,

I believe the granting of the Liquor Store License would be in the public interest for the tourists, residents and businesses within the Shopping Centre to have the choice to purchase a wide range of alcohol products including international and local WA products which are not always easily available in the Wanneroo locality.” Stuart Hutchison, Licensee, Truffle Hill Wines @ The Truffle & Wine Co.

“As a small WA wine Producer, our products are not on the shelves of some of the country’s largest liquor retailers (including Liquorland, BWS and Dan Murphy’s) due to the fact that we cannot supply our premium product at the volume and price required by the large multi-nationals. Accordingly, we have little to no representation in the nationally owned chain stores which saturate the packaged liquor market. Currently, the only avenue to market we have is through our Cellar Door in Margaret River and small, independent retailer such as Mr Naoum who support local producers and premium wine products, and who show that support through market access.

I believe the granting of the Liquor Store Licence to Parkview Enterprises Pty Ltd would be in the public interest to those resorting to the Wanneroo locality, and provide the added choice to purchase a range of local WA alcohol products that are not currently available in the locality, and in doing so, support the local WA wine industry.” Craig Gurney, Representative, Harmans Estate Wine

“Many of the visitors to our Cellar Door come here after they have tasted our wines, often from local, independent restaurants and liquor stores that support us and our premium wine products.

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This is a very important aspect of our operation, given that some of the large nationally branded stores are now making their own wines and pricing small WA producers out of the retail market. Previously, Mr Naoum has supported Sittella wines by introducing them to the retail liquor market and providing opportunity for tasting and education for some of our lesser known varietals and blends (i.e. Silk). We share his vision to cater to the contemporary requirements of consumers, with local products that support local producers and employment opportunities in Western Australia.

I fully support the liquor store application to be conditionally granted as it is in the public interest and will aid in the ongoing development of the hospitality, liquor and tourism industry by providing local consumers of alcohol in the Wanneroo locality the option to ‘’Buy local’’ and support WA businesses.” Simon Berns and Maaike Berns-Lugten, Proprietors, Sittella Winery

“Our minimal intervention wines are a growing segment of the Australia wine market, with more and more consumers taking interest in where and how their wine is grown and produced, and looking to sample and support low-intervention products.

We understand that the proposed Wanneroo Cellars will carry a diverse range of local WA products, including unique wine product lines not readily available in the Wanneroo locality. We can confirm that Montefalco Vineyard do not currently have any retail representation in the Wanneroo locality.

We fully support Mr Naoum and the application for Wanneroo Cellars to be granted as it will aid in the amenity available to local residents, supports local WA Producers and includes unique products (including our own) that are currently unavailable in Wanneroo.” Indi Lucaroni, Director, Montefalco Vineyard

“As a small WA producer, we are not interested in the massive corporate world of discounting and brand burning, we thus prefer to work with like minded business who can uphold our values of integrity.

I believe the granting of the Liquor Store Licence to Parkview Enterprises Pty Ltd would be in the public interest to those resorting to the Wanneroo locality, and to provide the added choice to purchase a range of local WA products that are not currently available in the locality, and in doing so, support the local WA wine industry.” Greg Garnish, General Manager, Wise Wines

“I have known Mr Arthur Naoum of Parkview Enterprises Pty Ltd for many years, and know him to be a strong supporter of independent labels and WA made products, through his ongoing support for our single vineyard wine products in his WA metropolitan liquor stores.

All of our wines are single vineyard estate. Our vineyard is situated in Western Australia’s oldest wine growing region, The Swan Valley. We fell in love with the history of the region and its solid reputation for its wines. As we live on the vineyard we are in tune with what is going on a daily basis. Our vines are over 30 years old and we employ best practice viticulture techniques such as minimal spraying, organic composting, and canopy management to produce optimal fruit. All the hard work and attention to detail in the vineyard ensures that the fruit for our wines is full of flavour and shows distinct, varietal and regional character. The growing conditions of Swan Valley are ideal for producing premium wine of exceptional character, quality and longevity.

Our experience of Mr Naoum is that he is a responsible and reputable operator, has a thorough knowledge of the packaged liquor industry, effective harm minimisation strategies and strongly supports local producers in his stores. Accordingly, we support the application for a new liquor store

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to be known as Wanneroo Cellars to properly develop the local liquor industry, and to bring convenience and amenity to existing and future residents/visitors to Wanneroo.” Norm Trandos, Managing Director, Little Black Dog Trandos Estates Winery

“I have known Mr Arthur Naoum through various liquor interests for over ten years, trading as both Pemberley Wines and now as Pemberley of Pemberton. During this time Arthur and his team have always shown a passion to support the local WA wine and (growing) liquor industry through representation in his retail liquor outlets.

In particular we note Mr Naoum’s willingness to bring products not normally stocked in the larger chain liquor stores to the retail market on his shelves; adding choice for consumers, but also supporting smaller liquor producers find a route to market. This can be difficult for some smaller producers (including ourselves) as they cannot reduce their wholesale price to a level acceptable to the large format liquor stores owned by national and international chains. During the time I have known Arthur I have not had reason to question his integrity, finding him always to be honest and upfront.

I would urge the Director of Licensing to look favourably on this application, as I believe that it will greatly increase consumer choice in the local area, provide a wider and more diverse product range that what is currently available in the Wanneroo locality.” Monica Radomiljac, Director, Pemberley of Pemberton

6.38 The Applicant believes that the application is in the public interest through its focus on locally produced products. As can be seen in the responses given in the 256 Consumer Surveys (Attachment 2) 64.93% of consumers in the locality currently find there is a gap in the market with respect to the availability of local WA liquor products, supporting WA local producers, ease of access to packaged liquor and independently owned and operated Liquor Stores.

6.39 The Applicant also notes that unlike the large national retailers referred to above, the Applicant’s proposed store does not compete on a ‘low price guarantee’ or offering bottles of wine for as little as $2.69 per bottle like that available from ALDI59. Accordingly, the Applicant submits their offering will be lower-risk than the large chain retailers.

6.40 It is therefore the submission of the Applicant that the approval of the liquor store Licence will economically benefit a number of small producers in WA, and indirectly benefit a greater number of people in the supply and distribution chain.

6.41 The proposed Liquor Store will support and promote WA producers of liquor products, as outlined in this PIA. The plans reflect a special “Local Product Exclusive Stand” at the front of the store, which will further assist to bring these products to the public’s attention.

59 https://www.abc.net.au/news/2018-02-16/local-communities-push-back-against-supermaket-liquor- barns/9401242

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Local WA Product Stand

Entrance/exit

Figure 19: Plans showing dedicated, visible WA Product stands

6.42 The Applicant submits that there will be other WA products available including wine, beer, cider and spirits that will be available throughout the proposed Wanneroo Cellars, however the identified

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stands will ensure that WA made products by small local producers are given a heightened visibility by way of the stands.

6.43 In addition to the support offered by local residents in Wanneroo (Consumer Surveys) and those in the WA liquor industry who are not currently represented in Wanneroo, the Applicant has also received support for local businesses in the Retail Shopping Precinct at 957 Wanneroo Road.

6.44 The following excerpts are from businesses that offer complementary services for those seeking liquor products to purchase for a celebration (i.e. birthday, anniversary etc.), and that believe that consumers would benefit with the inclusion of an independent liquor store in the precinct: “We have spoken to the Applicant with regard to the proposed business model, product offering, RSA and harm minimisation strategies, and are confident that the proposed Wanneroo Cellars is in the public interest.

Party Mix Wanneroo is a family run business offering a wide range of party supplies. From balloons to banners, tableware to light equipment, at Party Mix, you’ll definitely find what you are looking for!

Further, we have asked our customers whether or not they support the application, and the overwhelming answer has been a very strong yes. We note that much of that support is also due to the independence of the operation, not owned by the big three supermarket chains (Coles, Woolworths and ALDI). As a complimentary business, Party Mix Wanneroo hereby request with respect that the application for an independent liquor store be approved in the public interest.” Vishal Dodia, Proprietor, Party Mix Wanneroo

“I believe that the only retail amenity currently missing from the centre is an independently owned and operated bottle shop, and, based on my local retail experience I believe it would provide genuine convenience for my clientele as a complimentary amenity to Wanneroo Deli & Lunch Bar.

Convenience shopping is something many people value, and my customers enjoy the convenience my store offers, with easy access off Wanneroo Road, and no big shopping centre car park to navigate. As the only liquor store on the west side of Wanneroo Road in the area, I believe this will also be valued by my customers and many people who drive home north on Wanneroo Road.

I understand the liquor store is going to stock a range of small batch, unique local WA products not easily available in Wanneroo at existing liquor stores, as they are all owned and operated by the large corporate supermarket/bottle shop companies.

Further, the empty tenancy at Shop 6 is of no benefit to the public, and provides no employment or activation in the area, two initiatives that the City of Wanneroo is aiming to support in the area. I support the liquor store application as it is in the public interest and will aid in the ongoing development of the liquor industry, by serving the needs of the local consumers of alcohol and supporting the local WA liquor industry.” Minh Hien Le, Owner/Operator, Wanneroo Deli and Lunch Bar

“As a business owner who also operates in the retail shopping precinct at 957 Wanneroo Road, I am impacted by the types of shops in this complex, and how they operate. After engaging with the applicant, I wish to provide my strong support for the proposed Wanneroo Cellars, based on the following:  Complimentary business to my The Cheesecake Shop business,  Independent retailer that can tailor their product offering to the needs of consumers,  Support and promotion of local WA and Australian producers of liquor, and

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Provide dietary products similar to our growing demand for dietary specific products.

I am also advised that the liquor store will be selling a range of vegan/preservative free/ biodynamic and organic alcohol products that will be of interest to my customers. The Cheesecake Shop (nationally) has been steadily increasing our supply of dietary specific products including vegan and gluten free cake options, due to public demand. These have been very well received by our customers here in Wanneroo and around Australia/NZ. I believe that a locally operated liquor store that also has a range of vegan and other dietary specific products is required in the area, as the BWS/Liquorland operators do not seem to cater to this demographic which is growing in Wanneroo.” Jack Dodia, Franchise Owner, The Cheesecake Shop Wanneroo

6.45 Along with the retail businesses above, the Medical Centre located in close proximity also offered a letter of support, after being contacted during the Community Consultation. Please find below an excerpt from the letter of support provided by Brookside Medical Centre: “As a medical practice, we are acutely aware of some of the issues that liquor can present and the potential harm that may be caused. We too are located on the west side of Wanneroo Road, and confirm that it is often difficult to cross Wanneroo Road to gain access to the services within the Wanneroo Central Shopping Centre, particularly for those persons travelling north on Wanneroo Road, or that live to the west of Wanneroo Road.

After speaking with Mr Naoum about his proposed liquor store, we consider that the conditional grant of the liquor store licence is in the public interest for a number of reasons. Please find below some of the reasons we support the application:  Much more convenient for those travelling home north on Wanneroo Road,  Much more convenient for those living to the west of Wanneroo Road,  To be operated by an experienced Licensee,  No carrying of 10/15 litre cheap wine casks,  Easy to access with parking out the front of the store,  Independent premises that is not owned by the large national chain stores/liquor barns, and  The proposed stores support for small, local WA producers over home-brand type liquor products sold at very low prices, such as available from ALDI, Dan Murphys etc.

We also very much appreciate Mr Naoums consultation with us before he applies for the liquor store licence. We believe that this shows Mr Naoum to be a responsible and honest operator, who has considered the genuine needs of the community. We note that no other potential Licensees have notified or consulted with us before they applied for their liquor licence.

Based on our patient profile, the changing demographic in Wanneroo, the support for WA producers and the location on the west side of Wanneroo Road, we support the grant of this application in the public interest.” Dr Ashish Khanna, MBBS, Dip Derm, MS, PGDipDiab, MRCGP (UK), FRACGP, Brookside Medical Centre

6.46 In addition, the application has the strong support of local MP the Hon. Ian Goodenough MP (Attachment 3m), who is not only the Federal Member for the seat of Moore (which takes in parts of Wanneroo), but also served for many years as a Councillor at the City of Wanneroo. Mr Goodenough writes: “I am pleased to provide this letters of support for the liquor licence application by Mr Arthur Naoum of Parkview Enterprises Pty Ltd, based on my knowledge of the Wanneroo locality and experience as a former Councillor of the City of Wanneroo.

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I understand Mr Naoum has been operating licensed premises in the Perth metropolitan area for over 30 years, in a responsible manner, and is supportive of the local communities in which his stores operate.

I also understand MR Naoum is a great supporter of local WA boutique wineries and liquor producers, and as such, will bring a different independent approach to the retail liquor amenity to the Wanneroo locality.

Independent operator play an important role in the development of the liquor, hospitality and tourism industries, and would be pleased to provide a verbal reference for Mr Naoum in relation to his application for the conditional grant of a Liquor Store Licence.”

6.47 The Applicant believes that the consumer survey results, the letters of support from some of the many suppliers and producers who are under-represented in the locality, support from those who are local business operators and the strict Harm Minimisation Plan to be in place at all times the licensed premises is open, all demonstrate that the application for a Liquor Store Licence for Wanneroo Cellars is in the public interest, and will aid in the proper development of the local hospitality, tourism and liquor industries, while mitigating and minimising the potential for an undue increase in harm or ill-health in the locality.

Potential Negative Impacts 6.48 The responsible and experienced Applicant recognises that alcohol can be misused and cause harm if not responsibly consumed.

6.49 As a licensed operator committed to the responsible consumption of liquor, the Applicant has considered the Australian Institute of Criminology: Research in Practice SUMMARY PAPER No. 04 December60 which refers to the following regarding the negative social impact of Alcohol related violence in residential locations; “Hotels and nightclubs are the most problematic licensed venues for violence, particularly those with extended or 24 hour trading.”

6.50 To be effective in reducing alcohol-related violence, the research notes that the implications for policy and practice need to give importance to; “The need for a range of partners within the community to work together to set appropriate standards for the consumption of alcohol and set formal and informal controls on the misuse of alcohol and the problem behaviours that result”.

6.51 The Applicant is committed to involvement on a community level, willing to become an active member of the local Liquor Accord, work together with the Police, LEU and CHO (see Legislative Framework – Liquor Control Act 1988) to mitigate and minimise any undue, potential negative risk that may result within the locality.

6.52 The Applicant understands the potential for undue, negative social impacts related to the sale and supply of packaged liquor, which is evident in their Harm Minimisation Plan (Attachment 1) and staff training strategy (Attachment 5a – Staff RSA Handbook) provided to staff upon employment (subject to approval).

6.53 The Applicant accepts that as a retailer of packaged liquor, they have limited control regarding how it is consumed once purchased and taken off the licensed premises, including consumption in the home. Alcohol can play a role in family and domestic violence, and the Applicant who strongly resents domestic violence, notes that the rising rates of family and domestic violence have been attributed to a number of factors including increased reporting, as outlined in the following

60 http://www.aic.gov.au/media_library/publications/rip/rip04/rip04.pdf

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excerpts: “The bottom line is we are seeing more attention to the issue so people are more likely to report,” Women’s Council for Domestic and Family Violence Services WA chief executive Angela Hartwig told The Sunday Times.61

6.54 The Victoria Royal Commission into Family Violence62 noted:

6.55 The Applicant is aware of the role of excessive alcohol consumption in domestic and family violence matters, and notes that any Barring Notice issued by the WA Police will be adhered to.

6.56 Importantly, there is a trend of decreasing rates of Harm Against the Person offences63 in Wanneroo as can be seen in the figure below:

Figure 20: Offences Against the Person in Wanneroo (Source: https://www.police.wa.gov.au/Crime/CrimeStatistics#/start)

6.57 Research has indicated that an increase in the availability of alcohol may have the potential to cause harm and ill health within a locality. As was recognized by the Commissioner in Liquorland (Australia) Pty Ltd v Executive Director of Public Health LC 18/2012 [70] (“Liquorland”): “There is a considerable body of research which demonstrates a correlation between outlet density and harm

61 https://www.perthnow.com.au/news/wa/domestic-violence-reaches-epidemic-levels-in-wa-as-more-cry-for-help- ng-eea3e567dba6fbcda8e929181f9a6889 62 http://www.abc.net.au/news/2016-04-06/fact-file-domestic-violence-statistics/7147938 63 https://www.police.wa.gov.au/Crime/CrimeStatistics#/start

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caused but this needs to be applied with caution to specific locations as much of the data aggregated and general in nature”. The Commission acknowledged that a proliferation of liquor outlets is generally undesirable and is cognisant of the fact that its determination in this instance involves approval of a licence less than 1km away from an existing liquor store. In this respect, the Commission regards the application as very finely balanced. However, given the applicant’s focus on servicing the tourism industry and, its business model, the Commission is of the view that, by a narrow margin, the applicant has established that there is a public interest in the additional grant of a licence.

6.58 In the case of the proposed premises, the liquor store will have a select liquor offering, with a selection of locally produced beverages and harm minimisation policies in place to help minimise any potential, undue harm or ill health within the locality, due to the use of liquor.

7. Section 38 (4) (a) of the Act – Harm or Ill-health 7.1 The information sources considered when completing the PIA as prescribed by the Director of Liquor Licensing include (but not limited to) the following:

Source Reference

WA Police www.police.wa.gov.au

Australian Institute of Criminology www.aic.gov.au

Population Health (WA) www.population.health.wa.gov.au/communicable/immunisation.cfm Local Government Authority www.dlg.wa.gov.au

Department of Racing Gaming & www.rgl.wa.gov.au Liquor Office of Crime Prevention www.wa.gov.au/information-about/community-safety/crime-prevention

Australian Bureau of Statistics www.abs.gov.au

National Drug Strategy www.nationaldrugstrategy.gov.au

Road Safety Commission www.rsc.wa.gov.au

WA Planning Commission www.wapc.wa.gov.au Chief Health Officer http://www.healthinfonet.ecu.edu.au Department of Aboriginal Affairs www.daa.wa.gov.au National Health & Medical Research www.nhmrc.gov.au/your_health/healthy/alcohol/index.htm Council Australian Government Department of Http://health.wa.gov.au Health & Ageing Figure 21: Sources of Information

7.2 It would appear following a comprehensive review of the reports available on the websites as noted above that violence can be attributed to many factors. Of particular note is the excerpt (see below) from Preventing Violence: The State Community Violence Prevention Strategy 2005, A Green Paper Policy Framework for Development (Attachment 13), a collaborative publication with input from the following reference sources:  Department of Justice  Department of Health  Department for Community Development  Department of Education and Training  Office of Road Safety  The Department of Health  Department of Sport and Recreation  The WA Local Government Association  WA Police

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“Much is known about the causes of the crime and the effectiveness of a range of interventions. While continuing to grow on an almost daily basis, this information presents ample opportunity for limited resources to be better targeted to address the causes and to ameliorate emerging harm. There are many theories on what causes violence which could be broadly categorised around “individual” or “community/environmental” factors.

“Individual” theorists say that, given the human history and continuing record of war, persecution and suppression, humans are an inherently violent species. Others point to genetics, hormonal or chemical precursors, biological and mental pathology or learned cognitive/behavioural responses.

“Community/Environmental” theorist suggest poverty or economic circumstances, political environmental (war, racism et cetera), cultural norms and attitudes, role modelling or social learning as root causes of violence.

The research demonstrates:  The nature and outcomes of crime are the result of a complex relationship between a number of factors that relate to the individual, the community and environment, and the specific situation in which crime occurs;  Social and cultural norms play a key role in how the community perceives and responds to crime;  Low socio-economic status and social exclusion are closely linked with criminal behaviour; and  Crime outcomes, together with a range of other conduct and behavioural, social cognitive and health outcomes can be influenced by appropriate intervention in the early years of life, targeting “risk” and “protective” factors.

A growing body of evidence points towards the interaction of a range of factors in shaping behavioural outcomes. While each of the factors described above plays a role, attempts to separate out a single cause that will only address and respond to a small part of the problem. Regardless of the causes, violence is not acceptable, and the available evidence shows that much can be done to prevent it”64

7.3 Further to the above, the Designing out Crime Planning Guidelines65 produced by the Western Australian Planning Commission (2006) were also considered when contemplating the location of the liquor store within the Retail Shopping Precinct at 957 Wanneroo Road, and during the process of compiling this submission.

7.4 The Applicant considers the guidelines to be a successful tool in eliminating crime which may result in undue harm or ill-health to the locality when combined with a robust harm minimisation plan and a commitment to operating a safe, appropriately sized and well managed licensed premises within a retail environment.

7.5 The principle headings for Design out Crime as recognised by environmental design practitioners and educationalists in Australia, which can be considered and developed at a local level, could be based on five design and usage concepts, (Design out Crime Guidelines 2006: page 16):  Surveillance  Access Control  Territorial Reinforcement  Target Hardening (Security Measures); and  Management and Maintenance

65 https://www.dplh.wa.gov.au/getmedia/87627346-3ade-4e6a-99f0-31365a215f3c/GD_designing_out_crime

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7.6 Having considered the above principle design and usage concepts and based on extensive experience as business operators, The Applicant submits the following by way of addressing the above;  Surveillance The proposed Liquor Store will be covered by internal and external CCTV which will include the exit, entry and delivery points. Liquor store staff (subject to approval) will constantly monitor patrons accessing the liquor store.

 Access Control The Applicant will utilise techniques that will deny offenders and reduce their escape opportunities and guide legitimate users through the environment. The small size, location of the proposed liquor store will control access to the proposed liquor store, and the single entry/exit will ensure constant monitoring by the RSA/MLP1 trained staff. The POS will be located toward the front of the store, in front of the spirits to be available. The premises will have automatic doors installed that register an audible noise when someone enters or exits the store.

 Territorial Reinforcement Appropriate signage will identify the Liquor Store including rear entry for deliveries, which will be clearly marked and secured.

 Target Hardening (Security Measures) The single entry/exit point to the proposed liquor store will be secured by a quality locking device and supervised at all times by those working at the proposed Wanneroo Cellars and the CCTV cameras both inside and outside of the licensed premises.

 Management and Maintenance The proposed Wanneroo Cellars will remain at all times in good repair and well maintained. Staff will be trained to identify and report problems immediately to management should they notice any graffiti, broken locks and/or damage to the premises.

7.7 Additional crime reduction measures that have been considered by the Applicant during the design process include the following:

Lighting – having the area in and surrounding the store, including the car parking area, well-lit as it discourages any anti-social behaviour and greatly increases the chance of detection and recognition. Other premises in the Retail Shopping Precinct at 957 Wanneroo Road also trade during later operating hours.

Landscaping – similarly, it is important that sightlines are not obscured creating small areas of potential concealment.

General appearance – if a place has a quality fit out and appears well looked after, people are less likely to loiter or be anti-social.

Entrapment places – it is important not to create areas capable of trapping people such as recessed Automatic Teller Machines or narrow alleyways. None of these elements are incorporated into the plans for Wanneroo Cellars.

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Activity generators – the use of the vacant premises and having a broad range of uses that are available at varied times creates passive surveillance and an image of activity that is unattractive to most criminals.

8. Applied Research Section 38 (4) (a) of the Act – Harm or Ill-health Social Health Indicators “At Risk” Groups 8.1. In preparing this submission, the Applicant has given due consideration to those groups deemed the most “at risk” of alcohol related harm and ill-health under the Drug and Alcohol Interagency Framework for Western Australia 2011 – 201566, as noted in the Directors Policy on Public Interest Assessments67.

8.2. The determined “at risk” groups may include:  Children and young people,  Aboriginal people and communities,  People from regional, rural and remote communities,  Families,  Migrant groups from non-English speaking countries,  People in low socio-economic areas,  Mining communities or communities with a high number of itinerant workers, and/or  Communities that experience high tourist numbers.

8.3. Having considered the above “at risk” groups and reviewed the priorities for each group, the Applicant wishes to confirm a robust and lasting commitment to supporting the local community and community groups, tasked with devising strategies to reduce the effects of alcohol in the defined locality. Please refer to proposed strategies to minimise harm or ill-health, throughout this submission.

8.4. The following is a table that presents the numbers and percentages of “at risk” groups in the locality relevant to the liquor store application as identified above:

Identified Group Locality Risk Factor Western Australia Population aged 14 and under 20.43% Low 19.26% Indigenous Persons 1.11% Low 3.07% Couple families with Children 49.62% Low 45.30% Couple Families without Children 35.86% Low 38.50% Australian Born Residents 56.85% Low 60.33% Speak only English at Home 81.84% Low 75.21% Figure 22: “At risk” groups in the Locality

8.5. The above data (Figure 22) was compiled using statistics available from the Australian Bureau of Statistics68 for the defined locality as reflected in Attachment 7.

8.6. The percentages for each identified group were based on a population of 27,787 in the defined locality and total population of 2,474,410 in Western Australian (Attachment 7 – 2016 ABS Census Data).

66 https://www.mhc.wa.gov.au/media/1721/drug-and-alcohol-interagency-strategic-framework-for-western-australia- 2011-15.pdf 67 http://www.rgl.wa.gov.au/docs/default-source/rgl/publicinterestassessment.pdf?sfvrsn=8 68 Australian Bureau of Statistics- www.abs.gov.au

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8.7. There is a slightly higher percentage of ‘Persons Aged under 14 years’ within the locality compared with the State averages.

8.8. The percentage of Indigenous Persons in the locality is significantly lower than the WA rate.

8.9. The percentage of Speak English only at Home is higher than the State averages and the number of Australian Born residents was lower than both the WA and Greater Perth rates, demonstrating a locality that is not at significant risk of alcohol-related harm above that which is generally accepted in the community.

8.10. The Applicant notes that Wanneroo is not a rural or remote locality, and there is no publicly available data relating to the mental-health status and drug/alcohol use of persons in the locality.

8.11. Conversely, the Applicant notes that the publicly available SEIFA data for Wanneroo has been presented in this submission, and demonstrates that the locality is not socio-economically disadvantaged, with average numbers of ‘at risk’ people or groups of people.

8.12. The locality of proposed liquor store does not include a mining community or have a high number of itinerant workers.

8.13. Retail Shopping Precinct at 957 Wanneroo Road and the surrounding locality do not receive high tourist numbers (as defined by the licensing authority), and mostly service local residents and commuters who travel through the area.

Crime Statistics for the Locality 8.14. The data presented in the tables below, was sourced from the Western Australian Police website (www.police.wa.gov.au) and contain verified criminal offences for the defined locality during the period July 2016 to June 2017 (blue) and July 2017 to June 2018 (red). These statistics have been chosen as they are closest (in time) to the ABS statistics, while still being relevant.

Figure 23: Annual comparison of relevant criminal offences for the locality (Source: www.police.wa.gov.au)

8.15. The verified criminal offences for the defined locality demonstrate a decrease across most of the relevant criminal offences with the exception of Robbery (from 9 to 10), Deprivation of Liberty (from 1 to 3) and Threatening Behaviour (Family), from 17 to 20.

8.16. It is of note that Assault offences, both Family and Non-family, decreased during the relevant timeframes.

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8.17. The Applicant submits that the National Alcohol and Drug Knowledgebase69 indicate that stealing offences are not generally directly associated with alcohol consumption, making up 28% of alcohol- related crime.

8.18. The Applicant notes that these reported incidents do not include data on;  whether or not the incidents were alcohol related, and if so,  what type of Licenced premises the alcohol was sourced from.

8.19. Below is a representation of the verified criminal offences in the defined locality compared to popular WA destinations for the nine (9) year period from 2010/11 to 2018/19:

Figure 24: Comparison graph between the defined Wanneroo, Perth and Fremantle. (Source: www.police.wa.gov.au)

8.20. As can be interpreted from the information contained in the graph above, the trend with respect to relevant criminal offences from 2014/15 appears to be decreasing in Wanneroo, while in Perth the trend is increasing, and in Fremantle there is downwards movement, before a slight increase in the 2017/18 to 2018/19 period.

69 http://nadk.flinders.edu.au/kb/alcohol/crime-violence/alcohol-related-crime/what-are-the-main-types-of-alcohol- related-crime-in-australia/

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8.21. Review of the type of offences committed also provides more detailed information relating to crime in Wanneroo. Please find below, another excerpt from the WA Police website that shows the breakdown of offence categories nine (9) years.

Figure 25: Breakdown of offences over nine year period for Wanneroo (Source: https://www.police.wa.gov.au/Crime/CrimeStatistics#/start)

8.22. The information that can be derived from the statistics available on the WA Police website includes:  Overall offences have declined from the 2010/11 year, with a commensurate increase in population;  Decreases in criminal offences that have declined over the relevant period include: o Sexual offences, o Assault (Non-Family), o Threatening Behaviour (Non-family), o Dwelling Burglary, and o Property damage.  There has been a significant decrease in Drug Offences and Breach Violence Restraining Order; and  While the Applicant notes the increase in Assault and Threatening Behaviour (Family) in the time period covered, there is evidence to suggest higher rates of reporting can be responsible for the uplift in those incidents (Refer point 6 of this PIA submision).

8.23. The Applicant has considered the available statistics and data referred to throughout this PIA submission that relate to the Wanneroo locality and submit that:

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 The Applicant’s experience in operating retail, packaged liquor businesses within the locality of Wanneroo over 35 years,  The strict Harm Minimisation Plan that will be implemented,  The diverse, unique and quality product range of the proposed store,  The CCTV within the proposed Wanneroo Cellars,  Under 25 ID checks,  No cheap, bulk liquor,  The requirement of consumers in the locality for an independently owned and operated liquor store,  The consumer requirement of a local liquor store that support food and wine tourism through their support of small WA producers,  The proposed small size of the liquor store footprint,  The demographic of the local area, and  The Consumer Survey results which indicate that local residents support the conditional grant of the application in the public interest.

Will all aid the Applicant in managing the premises safely so that it will not unduly contribute to alcohol-related harm in the area.

Strategies to minimise harm or ill-health

Operating Hours 8.24. The proposed liquor store will only operate during the hours permitted under Section 98D70 of the Liquor Control Act.

8.25. Further, in consideration of feedback during the Community Consultation, the Applicant will accept a self-imposed condition on the licence stating: ‘’Subject to approval, the Applicant will open the premises at 9.00am (instead of the normal 8.00am) on school days’’.

Harm Minimisation Plan 8.26. As outlined previously in this submission, the Harm Minimisation Plan to be implemented will minimise much of the potential, undue harm or ill-health that may be caused to the community (if any) should this application for a liquor store licence be approved.

8.27. The Harm Minimisation Plan will be provided to all staff upon employment, and staff will be instructed that they must adhere to the requirements of the House Management Policy, Code of Conduct and Management Plan at all times.

8.28. The Applicant will display the Code of Conduct near the front of the licensed premises to ensure it is visible to patrons (subject to approval).

CCTV and Surveillance 8.29. The location of the proposed liquor store will provide an additional level of supervision of patrons resorting to the proposed Wanneroo Cellars (subject to approval).

8.30. There is currently a CCTV system within Retail Shopping Precinct at 957 Wanneroo Road that will continue to operate during all hours the liquor store is open. This will effectively provide CCTV surveillance inside and directly outside of the licensed premises at all times.

70 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s98d.html

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8.31. There will be CCTV within the proposed liquor store that has been designed in line with the Director’s Policy on Safety and Security at Licensed Premises71. RSA trained staff working at the premises will be instructed how to access footage if required by WA Police or any other authorised person.

8.32. The premises will have automatic doors installed that register an audible noise when someone enters or exits the store.

Staff RSA Handbook 8.33. The Applicant will design detailed operational procedures and management practices based on their rights and responsibilities under the Liquor Control Act 1988, and ensure they are implemented at all times the licensed premises is open and operating.

8.34. Staff will be trained in RSA, dealing with juveniles, secondary supply matters, restrictions on drinking at the premises, signage and pricing policy (Attachment 5a).

8.35. The Staff RSA Handbook will contain references to some of the specific measure being implemented by the Applicant to ensure that the premises are operated to a very high standard.

8.36. Matters outlined in the Staff RSA Handbook include (but are not limited to):  Rights and responsibilities of staff,  Dealing with intoxicated customers,  Responsible promotion of liquor,  Knowing our products,  How to conduct Tastings on the premises,  What is a standard drink,  How to identify an intoxicated person,  Dealing with juveniles,  No service to anyone in school uniform,  Secondary Supply – new legislation, and  Other relevant information.

Incident Reports 8.37. The Applicant will record any incidents of violent, threatening or offensive behaviour, as well as incidents of minors attempting to purchase alcohol, suspected secondary supply to minors and refused sale to intoxicated persons.

8.38. Such incidents (if any) will be recorded in the Incident Register, and made available to the relevant authority as and when required in a format approved by the licensing authority, and incorporating the following details as outlined in the Director’s Policy on Incident Register at Licensed Premises72and include: “In order to comply with the requirements of section 116A of the Act and regulation 18EB of the Liquor Control Regulations 1989, licensees must maintain a register of incidents containing the following information: 1. the name of the premises; 2. the address of the licensed premises; 3. details of the incident; 4. the date and time when the incident took place; 5. the location at the premises where the incident took place;

71 http://www.rgl.wa.gov.au/docs/default-source/rgl/safety_and_security_at_licensed_premises.pdf?sfvrsn=0 72 http://www.rgl.wa.gov.au/docs/default-source/rgl/incidents_register.pdf?sfvrsn=10

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6. the full name of any approved manager who was on duty when the incident took place; 7. the full name of each crowd controller and employee of the licensee involved in the incident; and 8. details of any action taken by the licensee, an approved manager or an employee in response to the incident, including any action taken to notify the licensing authority or a member of the WA Police or any other person engaged in providing emergency services.”

8.39. The Applicant also understands that there are significant penalties for not adhering to the requirements of an Incident Register as outlined above that may include: “If a licensee fails to comply with this condition of its licence, the licensing authority may decide to: 1) issue an infringement under section 167 to the licensee and approved manager; 2) require the licensee to show cause why more restrictive conditions should not be imposed on the licence; or 3) lodge a section 95 complaint for disciplinary action against the licensee. Under section 96 of the Act, if such a complaint was upheld by the Liquor Commission, a range of disciplinary action could be imposed including: a reprimand and a fine of up to a maximum of $30,000. However, the penalty sought could also include the suspension of the licence for a specified period of time or the cancellation of the licence.”

Liquor Accord 8.40. As there is currently no Local Liquor Accord that operates in the locality, the Applicant will seek feedback from Liquor Enforcement Unit (LEU) officers, with regard to what steps they can undertake to ensure that they are operating to provide both competition and convenience to local consumers, while ensuring the premises is operated responsibly and in the public interest.

8.41. Should a local Liquor Accord be implemented within the City of Wanneroo, the Applicant is committed to joining that Liquor Accord and active participation in the accord as they are designed to support the community in which they operate by way of: “Liquor accords are a co-operative arrangement aimed at developing safe and well managed environments in and around licensed premises in the local context. Liquor accords may include representatives from licensed premises, businesses, councils, police, government departments and other community organisations.

The intended outcomes of liquor accords include:  reducing of anti-social behavior in and around licensed premises;  reducing alcohol-related violence, ill-health and other harm;  increasing the responsible service of alcohol;  improving licensees and club operators, managers and staff knowledge of legislative obligations;  reducing alcohol-related road trauma;  facilitating and maintaining positive communication between stakeholders;  enhancing community cooperation and understanding of the various roles and resources of government agencies;  enhancing community engagement in various controls and strategies that affect their community; and  improving local amenity through the development of proactive and effective responses to local issues.”73

8.42. The Applicant is committed to cooperating with regulatory authorities involved in the responsible promotion and regulation of the liquor industry to actively reduce any potential undue risk of Harm

73 http://www.rgl.wa.gov.au/liquor/accords

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or Ill-Health from the sale of packaged liquor within the locality, by displaying visual anti drink- driving publications such as the following;

Figure 26: An Example of Anti Drink Driving Visual Promotion (Source: www.rsc.wa.gov.au/Campaigns)

Figure 27: Secondary Supply PSA (Source:https://alcoholthinkagain.com.au/Portals/0/MENT0023_secondarysupply_a3poster_HR_notrims_R.pdf)

Responsible Service and Promotion

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8.39 The Applicant is committed to adhering to the Liquor Industry Guideline on the Responsible Promotion of Liquor, as previously outlined in this submission. The industry guideline seeks to; “This document provides the industry with a framework of practices which are considered acceptable in order to prevent the intoxication and antisocial behaviour of patrons and, in all other aspects, to ensure that the premises are being properly managed. The framework highlights those practices which are discouraged and are not in the public interest.” 74

8.40 The Liquor Control Act 1988 places an obligation on Licensees to sell and supply liquor in a responsible manner. The uses of ‘gimmick’ promotions of cheap or discounted liquor that are likely to encourage irresponsible consumption of alcohol are not acceptable. Any activities to promote products will not include an incentive for patrons to consume liquor more rapidly or in greater amounts than they normally otherwise would.

8.41 The responsible service and promotion of liquor will be undertaken at all times by the Applicant at the premises. Any patron who appears intoxicated will be refused service and asked to leave the store. Any person who looks to be under the age of 25 will be asked to show appropriate photographic ID.

8.42 Staff working at the proposed liquor store will have completed their RSA training, and a copy of their certificate will be retained in the training register. Management will also be required to complete the higher qualification of MLP1 (Management of Licenced Premises).

8.43 It is anticipated that most staff employed at the proposed liquor store (if application is granted) will hold the higher qualification of Manage Licensed Premises (MLP1). This will mean that (generally) the staff working at the proposed liquor store will have a more detailed understanding of the Liquor Control Act 1988, and their rights and responsibilities under that Act. This will be strongly underpinned by the Staff RSA Handbook and on-the-job training.

8.44 Staff will be required to wear uniforms and name badges that will make them easily identifiable to consumers, who can advise and assist them when making their purchases.

8.45 The Applicant will refer to the Alcohol Advertising Review Board (AARB) Code to satisfy set criteria for acceptable alcohol advertising in Australia, and aims to ensure that alcohol advertising:75  is socially responsible,  neither conflicts with nor detracts from the need for responsibility and moderation in liquor merchandising and consumption; and  does not encourage young people to drink.

Visuals to be Displayed 8.46 The following visual signage will be displayed within the proposed premises as a reminder to staff and patrons of their rights and responsibilities under the Act;

74 Responsible Promotion of Liquor - Consumption of Liquor on Licensed Premises and the Sale of Packaged Liquor 75 https://www.alcoholadreview.com.au/about/the-code/

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Figure 28: Example of in-store visuals to be used (Source: https://www.mhc.wa.gov.au/reports-and-resources/resources/licensees-resources/)

9. Community Consultation 9.1 As part of the extensive Community Consultation, the following key stakeholders and community organisations were contacted to discuss the Liquor Store Licence application, and were asked to comment, give feedback, or express their concerns (if any) in relation to the application.

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WA Police Liquor Enforcement Unit (LEU) 9.2 An email brief outlining the details of the application was sent to the LEU and stated the Applicant would appreciate any feedback the LEU could provide. The Applicant respects that the LEU will consider the application in its entirety when advertised and intervene if required. The Applicant notes that any communication with the LEU does not constitute support for this application.

Chief Health Officer (CHO) 9.3 An email brief outlining the details of the application was sent to the Office of the Chief Health Officer of the Mental Health Commission (MHC) at the WA Health Department. The Applicant respects that the CHO will consider the application in its entirety when advertised and intervene if required. The Applicant notes that any correspondence with the Chief Health Officer does not constitute an endorsement of this application.

Notification to local ‘at risk’ groups 9.4 Notification of this proposed application will be provided to Schools, Kindergarten and Childcare Centres, Hospitals and Health Care Facilities, Aged Care, Drug and Alcohol Treatment Centres, Churches and Places of Worship, Short Term Refuge Accommodation and Local Police as well as the WA Liquor Enforcement Unit and the Chief Health Officer of the WA Department of Health.

SCHOOLS East Wanneroo Primary School We called the school and spoke to the receptionist who advised us that the Principal would be the relevant person to discuss the application with. We provided an overview of the application and contact details for the Principal, Mr Bill Dawson, to contact us if he wished to provide any feedback. At the time of lodging the application, there has been no further communication from the East Wanneroo Primary School.

Edgewater Primary School We called the school and were connected to the Manager of Corporate services, Cathy. After being provided with an outline of the proposed liquor store, Cathy stated that she did not believe there would be any negative impact if the application was approved, given the school was located closer to existing liquor stores and had not suffered any negative impact as a result.

Mater Dei College We made contact with the school and were advised to send our notification and request for feedback to the Principal via email. An email was sent outlining the proposed liquor store’s operation, and contact details provided. At the time of submitting the application to the licensing authority, no response has been received from the school.

Hocking Primary School A call was placed to the school and Kylie called us back to discuss the licence application. After providing Kylie with an outline of the proposal, she stated that she would advise the Principal of the nature of the application, and advise if the school had any concerns about the store impacting school attendee’s. At the time of lodging the application, no further communication as received from Hocking Primary School.

St Anthony’s School The Applicant made contact with Principal Marando at St Anthony’s, providing him with an overview of the Wanneroo Cellars proposal. At the conclusion of the call Mr Marando stated that he did not believe that there was any potential for undue harm or ill health to school children, subject to the application being approved in the public interest.

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Wanneroo Primary School Calls were made to the school and at the request of the receptionist, we sent an email overview of the proposed premises to the school, and afforded them the opportunity to provide any comments, questions and/or feedback they believed was relevant to the application. The Principal requested the opportunity to complete a Consumer Survey, on behalf of the school, and noted that the school did not support the application. We called and requested a meeting with the Principal to discuss the matter, however were advised that the Principal was away, and would not have time to meet with the Applicant as she was too busy. The spokesperson expressed concerns that some children at school went to the Wanneroo Lunch Bar, (located next door to the proposed Wanneroo Cellars) to buy their lunch before school. In consideration of this information, the Applicant has amended their opening hours to 9.00am on school days, to further reduce the potential for undue harm or ill- heath.

Wanneroo Secondary College We placed a call to the school and was able to speak with Pauline. After providing Pauline with details of the proposed liquor store including the harm minimisation strategies to be implemented, Pauline stated that there was currently a licensed premises in closer proximity that the one proposed, and that the school did not have any objection to the proposed liquor store going ahead.

KINDERGARTEN AND CHILD CARE Goodstart Early Learning Sinagra We called and spoke to the Centre Manager, who stated that she had no concerns for the children under her care, should the application be approved.

Kids Inn Ashby We were able to speak with the Centre Manager (Jessica) and provided her with details about the application and proposed operation of the premises, subject to approval. Jessica advised that there was a hotel located approximately 100 meters from the facility, and had no issues or concerns regarding the Wanneroo Cellars premises being approved.

Lake Joondalup Early Learning Program We made contact and spoke with the Facility Co-Ordinator Ish. After being provided with an outline of the application and the Applicant’s representative answering her questions, Ish stated that there would be no effect on the program if the application was granted.

Kids Biz Early Learning Centre Wanneroo Contact was made with the centre Manager Hayley, and a discussion took place relating to the proposed premises including operating hours, product range, harm minimisation and more. After that discussion, Hayley declared that she had no concerns about Wanneroo Cellars impacting on the centre and welcomed the idea of more small businesses moving into the area.

HOSPITALS AND HEALTH FACILITIES New Gumnut Medical Centre A call was made to the New Gumnut Medical Centre and we were connected with the Practice Manager Amanda. After being given an overview of the application, including details of the Consumer Survey, Amanda stated that an independent offering was an important option for local residents, and that Gumnut did not have any objection to the approval of the application at this time.

Wanneroo GP Superclinic A call was placed to the clinic and we requested to speak with the Practice Manager, Caroline. We were advised to please send the information via email, so Caroline could review it and provide any

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feedback that may be required. The email was sent, however no response, feedback, comments or concerns were received prior to the application being lodged with the licensing authority. The Applicant remains open to further engagement with the Superclininc (as required) at any time.

Brookfield Medical Centre We called and spoke to Dr Khanna at Brookfield Medical Centre. Dr Khanna had no objection to the application, and welcomed an independent liquor store offering on the west side of Wanneroo Road, and was motivated by our call to provide a letter of support for the application (Refer Attachment 3).

AGED CARE Regents Garden Lake Joondalup We called and spoke to the Clinical Nurse Manager at Regents Garden. On hearing an outline of the proposed offering, the CNM advised us that they had no objection to the application being granted. She also noted that as a local resident, she welcomes an independent retail liquor option in Wanneroo.

Elderbloom Community Nursing Home We made contact with the nursing home and advised them of the reason for our call. The Receptionist advised us that they would wait until the application was advertised and provide any feedback they had at that time. The receptionist who answered our call said that they lived locally and had no objections to the application.

National Lifestyle Villages – Pineview We made contact with Pineview and outlined the reason for our call. We were advised to contact Mr Ian Reid (Premises Manager) directly and left a voicemail on Mr Reid’s phone, explaining the reason for our call, and providing contact details should he have any feedback for the Applicant to consider. No further feedback was received from Mr Reid at the time of submitting the application to the licensing authority.

Jacaranda Lodge Frail Aged Hostel A call was placed and we were able to speak with the Facility Manager Helen. After providing Helen with the details of the proposed premises, and answering her questions with respect to the location of the premises, Helen stated that Jacaranda had no objection to the application being granted.

DRUG AND ALCOHOL TREATMENT CENTRES There are no Drug or Alcohol treatment centres within 3km’s of the proposed Wanneroo Cellars.

CHURCHES AND PLACES OF WORSHIP Crossways Uniting Church We contacted the church, but were unable to leave a message. On review of the church’s website, an email address was found and an email providing an overview of the application was sent, with contact details for any feedback the church may have.

St Peters Anglican Church An email was sent to the church after messages went unanswered. The email outlined details of the application including the experience of the Applicant, size of the proposed store and contact details to provide feedback. At the time of lodging the application with the licensing authority, the Applicant has not received any feedback from St Peters Anglican Church.

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Gospel Baptist Church The Applicant’s representative made contact over the phone with Pastor Larry Nelson, outlining the scope of the application, and discussing the details of the offering. While Pastor Nelson stated that his congregation did not support the consumption of liquor, he declared that he had no objection to the application by Wanneroo Cellars.

Oasis Faith Church We could not make contact with the church over the phone, so an email was sent outlining the nature of the proposed premises and providing contact details should the church wish to provide any feedback, comments or concerns. At the time of lodgement, no communication has been received from the church.

City of Wanneroo The Applicant recently undertook a Change of Use application through the City of Wanneroo and notes that during that process (of some six weeks) the Change of Use application was publicly advertised for two (2) weeks, a report generated and dispensed throughout the City of Wanneroo and that:  No Councillors called in the application (i.e. for further scrutiny),  The report was reviewed by the Planning Co-Ordinator, Planning Manager and Planning Director, and  Was subsequently approved by the City of Wanneroo.

Wanneroo Police The Applicant’s representative called the Wanneroo Police Station and left a message outlining the reason for the call and contact details for the Applicant’s representative. No response was provided at the time of lodging the submission however the Applicant acknowledges that the LEU will consider the application in full when it was lodged with the DLGSC, which may include consultation with local WA Police.

9.5 The notification by the Applicant’s representative involved contacting the ‘at risk’ groups in the locality, providing a written overview (as requested) for organisations to review and record their responses when advised of the intention to lodge the application.

9.6 The Applicant submits that all the ‘at risk’ groups in the locality will also be advised of the application by a Notice of Application during the advertising period, and be able to view the PIA online or in person at the Department of Local Government, Sport and Cultural Industries.

9.7 Advertising will be completed when dates for the specified period are determined by the DLGSC.

9.8 The Applicant will provide a Notice of Application to inform nearby residents and businesses within a 200m radius of the proposed liquor store.

10. Section 38 (4) (b) of the Act – Impact on Amenity 10.1 The Applicant has researched the potential impact of the proposed liquor store on the locality, and notes the increased convenience, choice, diversity and unique products (currently unavailable in Wanneroo) that would be offered by the proposed liquor store, and which would enhance the amenity of the locality

10.2 To get a fuller understanding of what consumers in the locality thought about the current retail liquor available in Wanneroo and the Wanneroo Cellars proposal, Mr Naoum himself doorknocked the area near the proposed Wanneroo Cellars including the area:

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 North of Ariti Avenue,  East of Scenic Drive,  South of Hart Court, and  West of Wanneroo Road.

10.3 Surveys were also collected at the Retail Shopping Precinct at 957 Wanneroo Road, and inserted into the Survey Monkey tool to present the results.

10.4 As previously described in this PIA submission, the response from the local community was overwhelmingly in favour of the grant of the application in the public interest.

10.5 The Applicant submits that the demographic information provided in this submission demonstrates a stable and fast growing locality with average levels of socio-economic disadvantage, on par with that of Western Australia.

10.6 There has also been a plethora of facts to support the Applicants contention that Wanneroo is a growing LGA, and that additional amenity is required to ensure the contemporary requirements of current and future populations are catered to.

10.7 The liquor store will positively impact employment opportunities in the locality.

Traffic Considerations 10.8 There will be additional benefits with respect to ease of access and safety, in having a liquor store located on the west side of Wanneroo Road, for those persons driving north on Wanneroo Road after work, and who may wish to stop and pick up something from a liquor store on their way home.

10.9 Wanneroo Road in Wanneroo is a 44 kilometre arterial highway in the northern suburbs of Perth, linking Joondanna/ Yokine in the south with Wanneroo (Yanchep) in the north.

10.10 Data collected and collated by the Main Roads Dept of Western Australia (Main Roads), demonstrates that the highest volumes of North bound traffic on Wanneroo Road occurs between 2.00pm and 6.00pm Monday to Friday (Attachment 14 – Hourly Volume wr. SOUTH DUNDEBAR).

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Figure 29: Location of traffic marker on Wanneroo Road, south of Dundebar Road (Source: https://trafficmap.mainroads.wa.gov.au/map)

10.11 The data shows that during the period identified above, 5,424 cars (on average) pass the marker that is located almost immediately outside the Retail Shopping Precinct at 957 Wanneroo Road.

10.12 The Applicant submits that it would provide increased convenience and safety for those travelling north on Wanneroo Road to have a small, convenience liquor store with easily accessible parking, on the west side of Wanneroo Road.

10.13 This is supported by the expert report from FLYT (Attachment 15) and also a synopsis of the CLE Town Planners summary (Attachment 16) which states: “From a land use/building use perspective a liquor store (in terms of both product and ‘day to day’ method of purchase of that product) is the type of small scale local retail use that the existing planning framework recognises and encourages in this town centre. Smaller local stores serving predominantly a local catchment, whilst also drawing benefit from an accessible location are exactly the enterprises every town centre seeks to attract, encourage and retain.

They not only contribute to the overall commercial success of these centres but as importantly perform a local service need consolidating the role of these centres as both community & local employment hubs and focal points.

The centre is located on the west side of Wanneroo Road opposite the main shopping mall. It is within what is known as the Wanneroo Road West Precinct of the existing Wanneroo Town Centre Structure Plan, and is designated as “Business’ in that Plan. It has an operational character and form always intended to be different from the main shopping complex.

The Structure Plan recognises the difference between the west side of Wanneroo Road and the larger scale shopping centre on the East side. It is generally recognised that the business activities will be smaller in size and scale, draw heavily from the high exposure and good direct access afforded by the location on Wanneroo Road.

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Amongst other retail activities the Town Centre Structure Plan identifies the use ‘Liquor Store’ as a suitable use in this location as evidenced by the recent City of Wanneroo straight forward approval to the application.

The other factor worth noting is for this Business zoned area which stretches along Wanneroo Road between Shaw Road and Church Street, there is a very generous allocation of parking at a ratio of 7 bays per 100m2 of floorspace. This well exceeds the provision requirement for the east side of Wanneroo Road which is only 5 bays per 100m2. There is always an abundance of very accessible parking spaces to service the Liquor Store in comparison to tenancies on the east side.”

AND

“Quite clearly accessing the liquor stores on the east side of Wanneroo road when heading either south or north on Wanneroo Road is; • more complex with additional turnings to/from Wanneroo Road required; • more reliance on traffic signals for entry egress; • longer vehicle travel paths to carparks servicing the outlets; and • In the case of Coles Liquorland, a much longer pedestrian movement compared to the relatively simple movement options available on the west side of the proposed liquor store.”

10.14 Further, the Wanneroo Town Centre Economic, Retail and Employment Strategy (Attachment 4), by Taylor Burrell Barnett states: “Access Wanneroo Road is a multi-lane, free flowing arterial highway providing access for significant traffic into the Centre. Several intersecting local roads passing east-west across Wanneroo Road feed local traffic to the Centre. The size of Wanneroo road presents a major barrier for local traffic traveling east-west through the Centre, especially for pedestrians. This barrier hinders pedestrian permeability which is problematic for economic activation as it encourages car transport over pedestrian routes. The Centre has consequently evolved to accommodate the needs of car travel over the needs of pedestrians. Reliance on car transport is not conducive to economic activation as the success of brick and mortar retail businesses relies in large part on a steady flow of pedestrian traffic.”

10.15 The above finding by Taylor Burrell Barnett demonstrates that residents who live on the west side of Wanneroo Road are disadvantaged with respect to accessing services on the east side of Wanneroo Road, and are essentially required to use a vehicle to cross Wanneroo Road at Dundebar Road or Conlan Avenue, due to the nature of Wanneroo Road and its permeability issues for pedestrians.

10.16 The report goes further to state (Emphasis added): “Summary of Economic Activation Economic activation within the Centre is constrained by the following factors:  Wanneroo Rd restricts pedestrian access from the west  Parking is dispersed and separates shop frontages from passing traffic  There is a lack of potential for exposure to shop fronts  There’s an imbalance of activity, with no suitable anchor tenant to attract visitors into the Centre’s core from Wanneroo Central”

10.17 The Applicant submits that this is important given: “The Centre is the only Secondary centre in the North West Sub-region that is east of Lake Joondalup, increasing the dependence of the local population. Lake Joondalup is a significant barrier for residents within the Centre Catchment,

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reducing the likelihood that they will access Joondalup Strategic Metropolitan centre for daily or weekly needs. The Centre Catchment population grew significantly between 2006 and 2016, experiencing annual growth rates of approximately 5.9%, significantly higher than the Perth Metropolitan average of 3%. Retail floorspace in the Centre grew at an annual rate of approximately 10% per annum between 2007 and 2015, almost doubling in size. This highlights the importance of the Centre as a retail destination for the rapidly growing surrounding communities.”

10.18 The proposed Wanneroo Cellars is to be located in the area denoted Town Centre by the WA State Planning Policy 4.2.2, and can demonstrably provide a safer, more convenient packaged liquor amenity, subject to approval in the public interest.

Liquor Licences in the Locality 10.19 Please see below a summary of the licensed premises permitted to sell takeaway, packaged alcohol in the defined locality: 6 stores under National chains (Coles, Woolworths and ALDI) o 2 operating under the BWS banner, as part of the Woolworths national chain; o 1 operating under the Dan Murphy’s banner, as part of the Woolworths national chain, o 1 operating out of the ALDI Wanneroo supermarket, and o 1 operating under the Liquorland banner as part of the Coles national chain.

2 independent operators as follows: o 1 operating under a Tavern Licence as The Ashby Bar & Bistro, and o 1 operating as the Edgewater Liquor Store.

10.20 Please find below a summary of the existing liquor outlets in the 3km locality that are permitted to sell and supply takeaway packaged liquor:

BWS Wanneroo and Wyatt Grove (Hocking)  BWS Liquor Stores stock the standard range of wine sold at all BWS outlets throughout WA, including a significant range of Woolworths own ‘private label’ wine products.  While specials may vary from store to store, the product list is standardised and stores hold between 1,200 and 1,500 products lines depending on their size.  BWS stores are approximately 200 to 300m2 and offer ‘Click and Collect’ – allowing customers to shop online and collect in-store for free. This service is available at all Woolworths owned Liquor stores. https://bws.com.au/

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Figure 30: Images of BWS Wanneroo as part of the Wanneroo Tavern (Source: Google maps)

 BWS Wanneroo is co-located with the Wanneroo Tavern which provides a range of on-premises options including dining, accommodation, sports bar, lounge bar and TAB facility. This premises is dominated by a large, double lane drive-thru.

Figure 31: Image of large Drive-Thru at BWS Wanneroo (Source: Google maps)

 BWS Wyatt Grove Shopping Centre is adjacent to the Woolworths supermarket in the shopping centre and is located 4.1km’s away by road.  Primarily caters to those living in the suburb of Hocking, and not those living to the west of Wanneroo Road in Wanneroo, or those travelling north on Wanneroo Road as part of their daily home commute.

Liquorland Wanneroo  Liquorland is one of Australia’s largest alcohol stores, stocking a wide range of local and imported wines, beers, ciders, champagne, spirits and premixed drinks across more than 600 locations nationwide.  Liquorland stores offer a product list of between 1,000 and 1,200 products lines and offerings are generally standard throughout Australia. Some smaller, regional store may hold less product lines.

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 Liquorland stores are approximately 180 – 240m2 and offer free delivery for online orders over $150 and ‘Click and Collect’ services. https://www.liquorland.com.au/  Liquorland is located within the Wanneroo Central Shopping Centre (tenancy 14), opposite the Coles supermarket at the Windan Way entrance. Please see image of Liquorland Wanneroo location within the shopping centre below:

Figure 32: Image of Liquorland Wanneroo shopfront inside Wanneroo central Shopping Centre (Source: https://www.wanneroocentral.com.au/shop-guide#store-listing)

 Being located within a Shopping centre also has an impact on the hours that Liquorland Wanneroo can trade.

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Figure 33: Core Trading Hours of Wanneroo Central Shopping Centre (Source: https://www.wanneroocentral.com.au/find-us/#)

 The Wanneroo Central Shopping Centre website also states that “Majors Open 8.00am – 9.00pm” \however only Coles, Kmart and Kmart Auto are listed as majors on the website.  The Applicant submits that being an independent operator, there will be no restrictions on the hours that they are able to trade, given those hours are in accordance with Section 98D76 of the Act.

ALDI Wanneroo  The liquor offering at ALDI almost entirely made up of ‘’own brand’’ liquor products, with a few known brands.  The liquor offering is contained within the supermarket footprint.  The liquor offering is not chilled, so provides limited convenience to consumers.  Please find below an example of the ALDI liquor offering:

Dan Murphy’s Joondalup  Located at Joondalup Gate Shopping precinct on other side of Lake Joondalup.  Located some 8.2km’s away by car.  Destination Liquor Store that attracts patrons from surrounding areas.  Does not cater to the consumers travelling north on Wanneroo Road or those living on the west side of Wanneroo Road.

The Ashby Bar & Bistro  The Ashby Bar & Bistro has a Cellarbrations Superstore attached, complete with Drive-Thru.  Independent liquor offering located in the suburb of Ashby.  This premises is located on the east side of Wanneroo Road, some 2.8km’s from the proposed Wanneroo Cellars, many blocks from Wanneroo Road.  Please find below a map showing the location of the Ashby Bar & Bistro:

76 http://www8.austlii.edu.au/cgi-bin/viewdoc/au/legis/wa/consol_act/lca1988197/s98d.html

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Figure 34: Map showing distance from Ashby Bar & Bistro to Wanneroo Cellars (Source: Google Maps)

Edgewater Liquor Store  This premises operates under the Liquor Stax Banner and is located within the Edgewater Shopping centre.  The Edgewater Shopping centre appears to be a small neighbourhood centre that is anchored by an IGA supermarket.  Like Dan Murphy’s Joondalup, this premises is located on the west side of Lake Joondalup, and accordingly, is located some 8km’s from the proposed Wanneroo cellars by car or by foot.

10.21 The proposed liquor store will provide a point of difference within the locality through independent ownership and operation, servicing local consumer requirements and provide an appropriately sized convenience style liquor store for the consumers now and in the future.

Impact on Juveniles 10.22 A representative of the Applicant contacted the relevant schools in the area to assess their feedback and address any concerns the schools may have.

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10.23 Many of the schools indicated that they already had a liquor store located closer than the proposed liquor store is intended to be located. The Applicant makes a commitment to collegially engage with local schools, subject to the application being approved and the schools having specific feedback relating to the operation of the proposed Wanneroo Cellars.

10.24 Subject to feedback from a local school, and in consideration of the same, the Applicant has committed to a self-imposed condition on the licence stating: ‘’Subject to approval, the Applicant will open the premises at 9.00am (instead of the normal 8.00am) on school days’’

10.25 As a further Harm Minimisation Strategy, the Applicant will enforce a policy at the premises that prohibits alcohol service to students in uniform regardless of ability to produce relevant ID, to actively reduce the potential risk to juveniles residing in or visiting the locality. Students in school uniform will not be permitted in the proposed liquor store premises.

10.26 The Applicant submits that this will also assist in reducing secondary supply issues around juveniles accessing liquor through older friends and/or siblings. As stated in this submission, there will also be visual signage relating to Secondary Supply laws with respect to juveniles, given the research evidences that many juveniles access liquor from or via their parents77.

10.27 If a staff member is in any doubt as to whether a person is aged under 25 years, the staff member will request that the person provide photographic proof of age.

10.28 The only acceptable proof of age will be:  Current Australian Driver's Licence with a Photograph  A current passport  A current Australian learner’s driver permit with photograph  WA Proof of Age Card  Proof of Age card or equivalent issued in an Australian state or territory  A current WA Photo Card  A current NSW Photo Card  A Photo Card issued by any Australian state or Territory similar to the NSW/WA Photo Card.

10.29 The Applicant will implement the Australian Liquor Stores Association (ALSA) initiatives for ‘’The ID under 25’’ campaign and display of appropriate signage in their commitment to social responsibility and managing potential impact.

77 https://www.aihw.gov.au/reports/alcohol/alcohol-tobacco-other-drugs-australia/contents/priority- populations/young-people

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Figure 35: Example of ID Under 25 Campaign Poster (Source: Australian Liquor Stores Association)

10.30 Other strategies to minimise the potential harm or ill health to juveniles in the locality are addressed in the Staff RSA Handbook (Attachment 5a).

10.31 The Harm Minimisation Plan also addresses the management of juveniles, including, but not limited to, the ID under 25 initiative, Checking ID’s, No service policy to any person wearing a school uniform regardless of their ability to provide ID to further minimise the risk of harm or ill health to Juveniles in the locality (Attachment 1).

Impact on Employment 10.32 The proposed independent liquor store will directly and indirectly increase local employment opportunities in the locality.

10.33 Review of the Economic Profile data for Wanneroo, demonstrates that the City of Wanneroo has 105,754 employed residents:

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Figure 36: Excerpt from Economic Profile (Source: https://economy.id.com.au/wanneroo)

10.34 As can be seen in the figure above, only 50% (approximately) of the total number of workers in Wanneroo are employed locally.

10.35 Further review of the breakdown in Employment by Industry, demonstrates that Retail is a larger employer (by percentage) in the City of Wanneroo at 12.4% than Western Australia at 9.7%, and those statistics have been consistent since 2012/13:

Figure 37: Employment by Industry comparison (Source: https://economy.id.com.au/wanneroo)

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10.36 The statistics presented above also confirm that Retail is the third (3rd) largest employer in the City of Wanneroo, second only to Construction (19.7%) and Education (12.7%).

10.37 The proposed Wanneroo Cellars intends to employ up to 3 to 4 staff on a seven day roster as required to operate the proposed Liquor Store. As with their previous retail operations, the Applicant prefers to employ local people who know the area.

10.38 That Applicant also submits that an as independent operator, their operations also support ancillary employment in Western Australia. Smaller producers are more likely to employ human capital than machinery/automation to pick their vintage, resulting to increased employment opportunities during vintage.

10.39 Further, smaller producers generally use local transport companies to ship their product, and tend to supply to independent liquor stores, restaurants, wine bars and hotels as opposed to the large growers like Berri and Casella, who grow bulk product and sell to various producers to create their wines.

Indirect employment 10.40 Taste 2020 also notes the importance of premium wine products from WA: “While Western Australia currently produces less than 5 per cent of the total wine crush in Australia, the State accounts for approximately 20 per cent of the ultra-premium segment of Australian wine sales. This emphasis on quality is reflected in all other areas of agricultural production. Western Australia is one of the most pest and disease-free agricultural production areas in the world. Strict quarantine requirements and stringent standards in production systems ensure that this safety and quality is maintained for the benefit of local producers and consumers. Western Australia’s vast geographic span provides diverse soils and climates that are suited to a variety of agricultural production. In the Ord River Irrigation Area in the north there are mangoes and other tropical crops, on the coastal sands near Perth market gardens produce vegetables, and from Perth into the south west fruit crops are made into outstanding wines and cider.”78

10.41 The Applicant submits that by supporting local Producers and giving them an avenue to market denied to them by the large national chains stores that make up almost 70% of the retail liquor market in Australia, they are also supporting food and wine tourism in WA: “The Strategy needs to acknowledge the much larger group of visitors to Western Australia who show a general interest in culinary tourism, or who might be considered accidental food and wine tourists – that is, they do not deliberately seek out culinary tourism experiences, but they enjoy them if they happen upon them. These visitors tend to be families with young children, or singles. They are not particularly interested in fine dining, cooking classes, and food and wine specific tours and trails. Instead of engaging with the heritage of the culinary culture, they experience it more incidentally at events, attractions, or as part of an overall tour. Their primary way of experiencing food and wine will be at restaurants and cafés.

While gourmet travellers might engage with more niche culinary experiences, research has shown that no matter where the visitor comes from (intrastate, interstate, or international) and no matter what their level of interest in food and wine tourism (dedicated, interested or accidental), there are some culinary tourism experiences which have universal appeal. Almost everybody wants to be able to eat or drink regional specialties and authentic local produce, and they want to experience this in spectacular surroundings, such as a beach or by the waterfront.”

78https://www.tourism.wa.gov.au/Publications%20Library/About%20Us/Taste_%202020_A_Strategy_for_food_and_ wine_tourism.pdf

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10.42 The proliferation of the large supermarket chains into the liquor retail market in WA is not supportive of smaller producers. As outlined in ‘Uncorked’: “There was shocked surprise all round when an $11 wine won best shiraz at the Margaret River Wine Show back in 2013. But there was one thing wine judges probably didn't realise before awarding the accolade to the 2012 Cow Bombie Shiraz, branded as being owned by a Margaret River winery... it was bottled in the Barossa Valley and is owned by Woolworths - the supermarket retail giant.

To avoid certain wine taxes and further boost their huge profits, Woolworths and Coles create 'wine brands' (such as the Cow Bombie) under cheeky and creative (some say misleading) names.

The wines are difficult to identify, and often undercut well-known brands, small boutique and family wineries and those struggling to find a voice in an ever-increasing crowded market.

Instead of Coles Reserve Chardonnay or Woolworths Bin 666 Cabernet, you have brands like Chateau Louise (Coles) and Augustine Wines (Woolworths) for sale... wines that are actually owned by the supermarket giants themselves.

By developing their own private-label and exclusive wines, Coles and Woolies are now competitors to the very wineries (and consumers) they are meant to serve.

If the big chains need to move a product because it is not selling, or want to replace it for their own means, they slash the wine's price, essentially lowering the winery's brand/reputation at the same time.

Wineries are getting more worried about the power Coles and Woolworths wield and their ability to change the MO of retail wine buying in this country.

The Australian Competition & Consumer Commission's probe into the treatment of suppliers by Coles and Woolworths, both accused of pushing food and grocery manufacturers to the brink of collapse with demands for unsustainably low prices, does not include the wine sector. Yet.”79

10.43 For example, if a local Wanneroo resident purchases and consumes a bottle of Margaret River made wine that they enjoy, they may consider going to that winery on their next holiday in the South West. This is one way independently owned liquor stores support local WA Producers and the WA Tourism industry in a way that the large retail supermarket chains do not.

10.44 The above salient and relevant points are supported by the proposed Wanneroo Cellars’ increased amenity, given their support of local WA producers (Letters of Support – Attachment 3).

10.45 The Applicant also notes that the Consumer Survey results, completed by doorknocking in the Wanneroo locality, demonstrate that a majority of respondents indicated that ‘lack of WA liquor products’ was an issue for them in respect to the product range of the existing liquor stores in the locality (Attachment 2).

10.46 According to the Australia Bureau of Statistics, 2016 Census Data, the employment data for the City of Wanneroo indicates that 56.3% of the population worked full time, 30.0% worked part time, and 8.5% identified as unemployed. The Applicant submits that the unemployment statistics may be influenced buy the higher percentage of persons aged over 55 years in the suburbs of Wanneroo, Ashby and Edgewater.

79 https://www.smh.com.au/entertainment/winestein-uncorked-local-wines-actually-owned-by-woolworths-coles- 20151211-gllhjo.html

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Employment City of Western Australia (people who reported being in the Wanneroo Australia labour force aged 15 years and over) Worked full time 54,825 715,287 (57%) 6,623,065 (56.3%) (57.7%)

Worked part time 29,195 376,590 3,491,503 (30.0%) (30.0%) (30.4%)

Away from work 5,078 (5.2%) 65,857 (5.2%) 569,276 (5.0%)

Unemployed 8,285 (8.5%) 97,966 (7.8%) 787,452 (6.9%)

Figure 38: Employment data for the City of Wanneroo compared to WA and Australia (Source:https://quickstats.censusdata.abs.gov.au/census_services/getproduct/census/2016/quickstat/LGA58760?o pendocument#employment)

11 Section 38 (4) (c) of the Act – Offence, Annoyance, Disturbance or Inconvenience 11.1 The Applicant has a thorough understanding of their rights and responsibility to operate the proposed liquor store as per best practice, and in the best interest of the community in which they operate.

11.2 Based on the consumer surveys (Attachment 3) collected, 85.42% of respondents believed that a new liquor store will not cause undue harm or ill-health, disturbance, annoyance, inconvenience or any other adverse impact to the locality. The results can be seen below:

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Figure 39: Excerpt from collation of Consumer Survey data

11.3 Based on the research and data included in this PIA, there are limited high risk factors associated with this application, however the Applicant proposes to implement the following strategies to “mitigate and minimise offence, disturbance or inconvenience” that potentially may occur:  The moderate size of the proposed licensed premises is commensurate with the size of the Retail Shopping Precinct at 957 Wanneroo Road in which it is located,  The proposed liquor store will not promote cheap discounted bulk quantity items,  Unaccompanied juveniles will not be permitted entry and any person in a school uniform will be refused service, regardless of age and ability to produce photo ID,  The premises will be fitted-out and furnished with quality fittings and fixtures,  The business will be run by mature, experienced and trained staff who will wear appropriate uniforms and name badges,  Will carry a range of local liquor products that are produced in WA and that support small local producers and the food and wine economy in WA,  Liquor products will not be promoted in a way to attract juveniles or encourage excessive consumption,  Low and no-alcohol products to be available,  No cask wine over 4 litres to be available,  Spirits to be located behind the POS counter, and  Staff will be trained to conduct the operation of the proposed Liquor Store in accordance with the Responsible Service of Alcohol (RSA) principles and the Liquor Control Act 1988.

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Code of Conduct 11.4 The proposed Liquor Store’s Code of Conduct will be a vital component of the proposed Harm Minimisation Plan.

11.5 This document will ensure that appropriate behaviour will be observed by patrons, staff and management of the premises. Management and staff will be committed to minimising liquor related harm, and be ever vigilant of their adoption of harm reduction strategies.

11.6 Patrons will be reminded to observe the Code of Conduct at all times whilst on the premises.

Effective and Efficient Service Recovery 11.7 Patrons of the proposed liquor store will be encouraged to discuss complaints, feedback and requests (if any) with the Approved Manager. Further, the Applicant is committed to acting on any feedback related to the premises in an efficient and consultative manner.

11.8 Staff will undergo an initial induction and ongoing training across all relevant aspects of the business, with specific and continued focus on the responsible service of alcohol and harm minimisation.

Training 11.9 Upon employment, staff will be required to read, understand and implement the policies and procedures outlined in the Staff RSA Handbook (Attachment 5a) for the premises.

11.10 Further, most staff working in the liquor store will be required to hold the higher ‘Manage Licensed Premises (MLP1)’ qualification, on top of their RSA certificate (which must also be attained).

11.11 Staff will also receive regular, ongoing training in the following aspects of operation:  How to identify and refuse intoxicated persons,  Checking acceptable photo ID correctly,  Emergency evacuation procedures,  Location, type and how to use the fire extinguishers on site,  Identification of disorderly or anti-social behaviours,  Responsibilities during employment,  Competent level of understanding of the Liquor Control Act 1988,  Minimum dress code for premises, and  RSA qualifications will be required as part of employment.

11.12 Staff will be given a Staff RSA handbook at the onset of their employment, outlining the above noted matters and to ensure that they are aware that they are accountable for their actions. (Attachment 7).

In-store Tasting and Education events 11.13 From time to time, Wanneroo Cellars will host small, local WA Producers to come in and educate our patrons on what they have to offer, providing tasting and education about their products. Wanneroo Cellars will provide a ‘’Tasting Notes’’ form to all consumers who attend (Attachment 5c). Please familiarise yourself with these forms as you may be required to assist at these events.

11.14 Staff will also be trained in how to assist at ‘’Tasting’’ events, and will be familiar with the Tasting Notes document to be used.

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Juveniles 11.15 The following strategies will be implemented by staff when checking the ID of patrons or anyone within the premises appear to be under the age of 25:  ALSA ID 25 Initiative,  Refusal of Service to anyone wearing a School Uniform, and  New Secondary Supply Legislation awareness.

Figure 40: Sample images of acceptable ID (Source: www.rgl.wa.gov.au)

11.16 The above documents are the forms of photographic identification that can be accepted by a Licensee (or their authorised agent) to prove age in circumstances where they suspect a person is a juvenile seeking entry to Licensed premises:  A current Australian driver's licence with a photograph,  A current passport,  A current Australian learner’s driver permit with photograph,  WA Proof of Age Card,  Proof of Age card or equivalent issued in an Australian state or territory,  A current WA Photo Card,  A current NSW Photo Card, and  A Photo Card issued by any Australian state or Territory similar to the NSW/WA Photo Card.

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11.17 The Applicant has also altered the opening time at the premises to 9.00am on school days (only), in consideration of feedback from a local Primary School who has advised that some of the children who attend their school get their lunch at the Wanneroo Lunch Bar before school.

12. Summary 12.1 Hospitality Total Services (Aus) Pty Ltd, on behalf of Parkview Enterprises Pty Ltd hereby submits this Public Interest Assessment to support the conditional grant of a Liquor Store licence for the proposed Wanneroo Cellars to operate at tenancy 6 of the Retail Shopping Precinct at 957 Wanneroo Road.

12.2 A Liquor Store Licence under section 47 of the Liquor Control Act 1988 authorises the sale and supply of liquor for consumption off the Licenced premises (i.e. packaged liquor). All relevant requirements for a Liquor Store application have been complied with and submitted along with this application as per Section 68 of the Liquor Control Act 1988.

12.3 The Applicant has applied to the City of Wanneroo for necessary planning approval, to ensure the new licensed premises complies with local planning guidelines, accepted standards and practices for public amenity and safety. These approvals have been granted and submitted to the licensing authority.

12.4 The Applicant has considered the potential impact on amenity, minimising the potential for undue harm or ill health and the offence, annoyance, disturbance or inconvenience the proposed Liquor Store may have on the local community in this PIA submission.

12.5 The proposed Wanneroo Cellars will not have any undue, negative impact on the local community, due to the location of the premises, independent access within the shopping precinct and strict juvenile management measures in the Harm Minimisation Plan.

12.6 The Applicant has outlined the positive social and economic benefits of the proposed Wanneroo Cellars, and submits that it is open to the decision maker to find that the inclusion of a well- managed, independently operated liquor store will provide superior convenience to consumers in the locality and is in the public interest, based on the following features of the application including:  Mr Arthur Naoum, Director of the Applicant company has over 30 years’ experience operating retail businesses within the locality,  Mr Naoum has completed the required ‘Manage Licensed Premises’ accreditation as a licensee and is an Approved Manager in WA,  The size of the liquor store is moderately sized,  The Liquor Store will be well-lit with an open layout,  The premises will feature automatic doors that emits an audible alarm when opened (for either access or egress),  The proposed licensed premises will be supervised by the Approved Manager and RSA trained staff,  The liquor store is in a separate tenancy from other premises in the Retail Shopping Precinct,  The product list will include a range of WA produced liquor that supports and promotes WA producers and employment in agriculture and the supply chain,  A range of low-alcohol wines will be offered which are not readily available in locality,  The absence of bulk quantities of cheap liquor products,  The conditional grant of the licence will result in additional convenience for consumers in the locality including those living west of Wanneroo Road and those travelling North on Wanneroo Road,

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 The conditional grant of the licence will promote competition, choice and the option of an independent liquor offering in Wanneroo,  The consumer survey results also indicated that a significant majority of survey respondents support the conditional grant of the proposed Liquor Store licence,  The Consumer Survey results also indicated that there was strong public interest considerations in the inclusion of an independent liquor retail offering in the locality that is currently only serviced by the large, retail supermarket operators,  The defined locality is considered average in term of socio-economic disadvantage,  There are no known or compelling harm or ill health statistics that indicate that it would not be in the public interest to conditionally grant the application, and  Limited external advertising and/or promotion of liquor products.

12.7 The proposed Wanneroo Cellars will enhance the amenity available to the local community and provide convenience to the current and future consumers of liquor in the locality. This is a relevant factor as identified in determination A 220573 which stated; “Convenience and one-stop-shopping are legitimate public interest considerations.”

12.8 The Applicant has considered Section 38(2) in regards to the potential negative effects of the proposed liquor store, and will implement a robust Harm Minimisation Plan (Attachment 1) to minimise any potential undue harm or ill-health to the locality.

12.9 The convenience and competition afforded by new premises was also outlined in LC 28/2013; “It is the Commission’s view that the added competition and convenience afforded, especially to residents by the grant of the application is a significant public interest consideration.”

12.10 The Applicant has also considered the Industry Guideline on the Responsible Promotion of Packaged Liquor, and is committed to adhering to the guidelines at all times.

12.11 Hospitality Total Services (Aus) Pty Ltd on behalf of Parkview Enterprises Pty Ltd have considered Section 38 (4) (a, b and c) of the Liquor Control Act 1988 in relation to Harm or Ill-health, Impact on Amenity and the Offence, annoyance, disturbance or inconvenience the proposed Wanneroo Cellars may have on the local community in this comprehensive PIA submission.

13. Advertising 13.1 Advertising will be completed when dates for the specified period are determined by the DLGSC.

13.2 A Notice of Application will be distributed to residents and businesses within a 200m radius.

13.3 A Notice of the Application will be mailed to any local aboriginal community, and regional office of the Department of Indigenous Affairs.

13.4 The Public Interest Assessment Submission will be available for public inspection.

13.5 A Notice of Application will be mailed to schools, hospitals, hospices, aged care facilities, drug and alcohol treatment centres, short term accommodation or refuges for young people, child care centres, churches, local government authority, local police station, situated in the specified locality of the proposed premises.

14 Attachments 1. Harm Minimisation Plan

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2. Consumer Survey Results 3. Letters of Support 4. City of Wanneroo Economic, Retail and Employment Strategy 5. Internal Documents 6. Plans 7. ABS Census Data 2016 8. Sample WA Product List 9. MGA Article 10. Who Makes My Wine? 11. Wines of WA Senate Submissions 12. Mid strength beer and wine 13. Preventing Violence 14. Hourly Traffic Volume counts – Mains Roads WA 15. FLYT Traffic Assessment 16. CLE Report

15 Figures Figure 1: Area door knocked for Consumer Surveys ...... 7 Figure 2: Floor plan ...... 9 Figure 3: Defined 3km Locality...... 10 Figure 4: The suburb of Wanneroo ...... 11 Figure 5: Forecast id Information for City of Wanneroo ...... 14 Figure 6: Forecast population growth for the suburb of Wanneroo ...... 15 Figure 7: Wanneroo Town Centre Precincts map ...... 18 Figure 8: Population Statistics for 'defined' locality ...... 21 Figure 9: Demographic data for the locality ...... 22 Figure 10: Family composition statistics for the locality ...... 22 Figure 11: Map showing area deemed 'Mainstreet' by the City of Wanneroo ...... 23 Figure 12: Public Transport available from Retail Shopping Precinct at 957 Wanneroo Road ...... 24 Figure 13: Render of the front of the proposed Wanneroo Cellars ...... 25 Figure 14: Fairbrossen Wine ...... 30 Figure 15: Some of the WA Craft Beer to be available at the proposed liquor store ...... 32 Figure 16: Taste 2020 - Wineries ...... 33 Figure 17: Location for proposed Wanneroo Cellars ...... 37 Figure 18: Word cloud created form comments made by Consumer Survey respondents ...... 52 Figure 19: Plans showing dedicated, visible WA Product stands ...... 56 Figure 20: Offences Against the Person in Wanneroo ...... 60 Figure 21: Sources of Information ...... 61 Figure 22: “At risk” groups in the Locality ...... 64 Figure 23: Annual comparison of relevant criminal offences for the locality ...... 65 Figure 24: Comparison graph between the defined Wanneroo, Perth and Fremantle...... 66 Figure 25: Breakdown of offences over nine year period for Wanneroo ...... 67 Figure 26: An Example of Anti Drink Driving Visual Promotion...... 71 Figure 27: Secondary Supply PSA ...... 71 Figure 28: Example of in-store visuals to be used ...... 73 Figure 29: Location of traffic marker on Wanneroo Road, south of Dundebar Road ...... 79 Figure 30: Images of BWS Wanneroo as part of the Wanneroo Tavern ...... 82 Figure 31: Image of large Drive-Thru at BWS Wanneroo ...... 82 Figure 32: Image of Liquorland Wanneroo shopfront inside Wanneroo central Shopping Centre ...... 83 Figure 33: Core Trading Hours of Wanneroo Central Shopping Centre ...... 84 Figure 34: Map showing distance from Ashby Bar & Bistro to Wanneroo Cellars ...... 85

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Figure 35: Example of ID Under 25 Campaign Poster ...... 87 Figure 36: Excerpt from Economic Profile ...... 88 Figure 37: Employment by Industry comparison ...... 88 Figure 38: Employment data for the City of Wanneroo compared to WA and Australia ...... 91 Figure 39: Excerpt from collation of Consumer Survey data ...... 92 Figure 40: Sample images of acceptable ID ...... 94

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