1 Introduction and background 2 Applicant’s details and background 2 2 Locality 5 Nature and character of the Locality 6 Who lives and works in the Locality 11 3 Manner of trade 13 Membership agreement 13 The premises 14 Liquor services 18 Proposed trading conditions 18 4 Sections 5 and 46 and Regulation 9A 18 5 Harm or ill-health – section 38(4)(a) 19 At risk groups and sub-communities 19 Social health indicators 22 Strategies to be implemented to minimise harm or ill-health 24 6 Impact on amenity – section 38(4)(b) 25 Nature and character of the local community 25 How the proposed premises will fit into the amenity 25 Outlet density 26 Consultation 26 7 Offence, annoyance, disturbance or inconvenience – section 38(4)(c) 27 8 Tourism, community or cultural matters – section 38(4)(ca) 27 9 Other matters 28 Security and safety 28 Harm minimisation 29 10 Conclusion 29

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Public Interest Assessment WeWork Perth

1 Introduction and background

1.1 This Public Interest Assessment (PIA) supports the application by 152 Saint Georges Terrace Pty Ltd for the unconditional grant of a special facility licence (SFL), for the prescribed purpose of works canteen, in respect of premises situated at levels 32-38 152 St Georges Terrace, Perth to be known as WeWork Perth.

1.2 This PIA addresses all relevant aspects of the public interest in accordance with both the Liquor Control Act 1988 (WA) (Act) and to the extent relevant, the licensing authority’s Public Interest Assessment policy1 (PIA Policy). This PIA also addresses the Liquor Control Regulations 1989 (WA) (Regs).

1.3 This PIA should be read in conjunction with the accompanying Legal Submissions dated 27 September 2019 and the other formalities, supporting material and correspondence to be lodged by the applicant.

1.4 The applicant seeks the grant of the SFL to authorise the supply of liquor at an office canteen type facility currently being established at levels 32-38 152 St Georges Terrace, Perth, to the people who work there and their guests. Full details of the proposal are set out further on in this PIA.

1.5 WeWork Perth is expected to be ready to commence operating in or around September 2019. Determination of the application is, therefore, sought to be expedited.

Applicant’s details and background

1.6 The applicant is an Australian incorporated company. All of the issued capital in the applicant entity is held by WeWork Australia Pty Ltd, which is a wholly owned subsidiary of WeWork Companies Inc, an organisation founded and based in the United States of America (individually and collectively described as WeWork). WeWork’s head office is in New York.

1.7 WeWork provides shared office workspaces and related support services for a variety of small to large businesses, under a membership structure, to co-exist in a professional office setting. Further details of WeWork’s services and facilities are provided elsewhere in this PIA.

1.8 WeWork was founded in 2010 with a primary mission of fostering a community attitude within the workplace. Since then WeWork has built shared workspaces across the globe, including significant expansion recently.2

1 https://www.dlgsc.wa.gov.au/department/publications/publication/public-interest-assessment-policy. Last amended 3 October 2018

2 http://www.nydailynews.com/life-style/real-estate/wework-alternative-working-home-swanky-buildings-nyc-article- 1.1044412?pgno=1#ixzz2e46Iipo5

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1.9 WeWork’s first location was in New York’s Soho district. WeWork has grown significantly since its inception3. WeWork’s membership base has grown globally by over 100% every year since 20144.

1.10 Globally recognised US companies have engaged with WeWork for the provision of carefully designed, serviced office spaces, including JP Morgan, Goldman Sachs Group and the Harvard Corp. As at 1 June 2019, 40% of WeWork’s memberships were with organisations with more than 500 employees (ie enterprise members), double the 20% as at 1 March 20175. WeWork expects enterprise to continue to be its fastest growing membership type6.

1.11 WeWork currently has 802 locations spread over 124 cities, including elsewhere in Australia.7 Most of those premises include a liquor service for the workers there.

1.12 WeWork has just recently entered the Western Australian market.

Welcome to Perth, a beacon of financial and commercial activity on Australia’s West Coast. Here, WeWork’s shared office spaces provide businesses everything they need to succeed. Specialized workspaces keep teams productive; custom art and indoor greenery enhance employee engagement. Professionals in retail, trade, technology, and the arts call this city home—and its geographical location also attracts companies expanding overseas.8

A city rich with natural resources, business in Perth exploded during the nation’s gold rushes. Today, the city is a leader in international trade, boasting an emerging technology scene and thriving arts community. In tune with this evolution, WeWork’s coworking spaces support established companies and startups alike. High-speed internet and friendly onsite staff take care of daily operations; free-flowing coffee and comfortable furniture keep your team happy and refreshed. If you’re looking for flexible agreements and amenity-rich coworking spaces, WeWork’s serviced offices in Perth will deliver.

1.13 The following are examples of two of WeWork’s clients/customers and their WeWork experiences:

3 The We Company. (2019). Page 66 of Form S-1 Registration Statement under the Securities Act of 1933. Retrieved from https://www.sec.gov/Archives/edgar/data/1533523/000119312519220499/d781982ds1.htm#toc781982_10.

4 The We Company. (2019). Page 66 of Form S-1 Registration Statement under the Securities Act of 1933. Retrieved from https://www.sec.gov/Archives/edgar/data/1533523/000119312519220499/d781982ds1.htm#toc781982_10.

5 The We Company. (2019). Page 65 of Form S-1 Registration Statement under the Securities Act of 1933. Retrieved from https://www.sec.gov/Archives/edgar/data/1533523/000119312519220499/d781982ds1.htm#toc781982_10.

6 The We Company. (2019). Page 65 of Form S-1 Registration Statement under the Securities Act of 1933. Retrieved from https://www.sec.gov/Archives/edgar/data/1533523/000119312519220499/d781982ds1.htm#toc781982_10.

7 https://www.wework.com/locations

8 https://www.wework.com/l/perth-- WA?utm_campaign=1740574491&utm_term=69848721322&utm_content=338987759687&utm_source=ads- google&utm_medium=cpc&gclid=EAIaIQobChMI-8LEi4OT5AIVmYRwCh2CSgCdEAAYASAAEgK0VPD_BwE&gclsrc=aw.ds

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Public Interest Assessment WeWork Perth

1.13.1 Standard Chartered Hong Kong, which offers personal and business banking services, attempted to drive different business ventures in the field of digital innovation by investing in start-ups and piloting new business models. These were done in an attempt to improve customers’ banking experiences. The company had the ninth floor in the Standard Chartered Tower in Hong Kong, but it needed an overhaul to inspire creativity and foster collaboration. WeWork created the “eXellerator Lab” for the company which constituted the environment change needed including flexible classrooms, different types of meeting rooms and a large lounge. Liam Gilligan, head of the eXellerator Lab, was impressed with WeWork’s services. He said “the time frame that we asked WeWork to operate to was really tight. Everyone was impressed at the ability to deliver within that.”9 Furthermore, Alex Manson, global head of Standard Charter Venture stated “The eXellerator in Hong Kong lets us bring ideas, skills, and, importantly, individuals—clients, fintech entrepreneurs, colleagues from the bank— together to enable innovation.”10

1.13.2 Pabst Brewing Company, a 175-year-old brewery in the USA, wanted to continue to develop its brand over time. With multiple locations across the United States, the company was looking to avoid the remoteness of some locations and bring a closer sense of community within Pabst. This led WeWork to provide Pabst with a Global Access program enabling Pabst to have access to WeWork’s entre network of workspaces in the US. The rollout started with 11 remote workers in 5 different cities. The results have been outstanding, with WeWork becoming Pabst’s go-to workspace. Ashley Swygert, Vice President of Commercial Strategy and Field Sales at Pabst said “all of the WeWork spaces are super-nice and very inviting. It is awesome to be able to interact with so many different people, which helps me to stay motivated and inspired.”11 Matt Bruhn, general manager of Pabst, states “What we are doing with WeWork is the future of how many businesses our size will look at real estate” and that they will be eager to expand their partnership with WeWork in the future.12

1.14 Perth stands to benefit greatly from the bespoke WeWork model which will enable Western Australian businesses to share office space in a modern professional environment made fit for modern purpose to a very high standard and supported by tailor-made facilities management services. WeWork Perth will offer a superior level of business support, including the opportunity for innovative networking and collaboration between businesses. The proposed liquor service will be a modest and ancillary feature, which will enhance and complete the suite of WeWork services to be

9 https://www.wework.com/ideas/standard-chartered-case-study

10 https://www.wework.com/ideas/standard-chartered-case-study

11 https://www.wework.com/ideas/pabst-brewing-company-case-study

12 https://www.wework.com/ideas/pabst-brewing-company-case-study

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Public Interest Assessment WeWork Perth

made available to the businesses and workers in the premises. It will be an important aspect to the contemporary corporate setting..

1.15 The applicant has consulted with prospective members/workers and obtained evidence in support of its proposed liquor services. That evidence accompanies this PIA.

2 Locality

2.1 Pursuant to the PIA Policy, the area most relevant for consideration in this application is a 2km radius surrounding the site. This area is depicted in the Google Maps image below with the white dot in the centre representing the approximate location of WeWork Perth (Locality).

WeWork Perth

2.2 The Locality is situated within the City of Perth local government area.

2.3 The Locality mainly comprises all or parts of the following suburbs:

2.3.1 Perth

2.3.2 Northbridge

2.3.3 East Perth

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Public Interest Assessment WeWork Perth

2.3.4 West Perth

2.4 Small portions of Highgate and South Perth fall within the 2km radius. They have been excluded from the analysis in this PIA given that they represent only a very small minority of the area and would likely distort a proper assessment of the Locality.

Nature and character of the Locality

2.5 WeWork Perth will be a modern and bespoke facility which will fit neatly into the bustling and burgeoning City described above.

2.6 The Locality is largely defined by the fact that it is within a capital city, comprises the central business district and includes Northbridge, which is the State’s premier entertainment, hospitality and cultural precinct.

2.7 This Locality is very familiar to the licensing authority and its main features are notorious facts. Some of those main features and landmarks include the following, to name just a few:

2.7.1 A large number of high-rise commercial use buildings.

2.7.2 Elizabeth Quay.

2.7.3 Perth Convention and Exhibition Centre.

2.7.4 Perth Arena.

2.7.5 Perth City Link, including Kings Square.

13 https://www.perth.wa.gov.au/future-perth/the-lifestyle-city

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Public Interest Assessment WeWork Perth

2.7.6 Several public transport facilities, including the new Wellington bus station.

2.7.7 State Library of Western Australia.

2.7.8 State Theatre.

2.7.9 Art Gallery of Western Australia.

2.7.10 Western Australian Museum (being redeveloped).

2.8 The Locality is the heart of a bustling modern city and is dominated by the hype and activity of the city workforce, busy city streets and large commercial buildings. The future of Perth, according to the City of Perth, is “vibrant, connected, progressive; a friendly and beautiful place to be.”14 The WeWork Perth proposal is designed to achieve exactly the same things.

2.9 The following information published by the City of Perth highlights key factors that help define the nature and character of the Locality:15

14 https://www.perth.wa.gov.au/future-perth

15 https://www.perth.wa.gov.au/future-perth

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Public Interest Assessment WeWork Perth

2.10 The Locality is a hive of activity and a densely built up area. It is dominated by office towers, large scale developments, hotels, hospitality and entertainment precincts, tourist attractions and a myriad of businesses of varying sizes and types.

2.11 The following summary from the Perth City Snapshot 201616 describes how Perth has changed dramatically over the past couple of decades.

2.12 More recently, Perth has been rapidly maturing into a modern capital city. The following key developments in and around the Locality have been completed in the last few years, to name just a few:

2.12.1 Perth City Link

2.12.2 Hibernian Place, anchored by the five-star Westin Perth hotel.

2.12.3 Redevelopment of 108 St Georges Terrace (Palace Hotel)

2.12.4 State Buildings and COMO The Treasury

2.12.5 Perth Town Hall and the State Library

2.12.6 Elizabeth Quay

2.12.7 Perth Arena

2.12.8 One40William

2.12.9 Brookfield Place

2.12.10 The Ritz Carlton at Elizabeth Quay

16 https://www.perth.wa.gov.au/our-capital-city/story-perth-city/perth-city-snapshot

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Public Interest Assessment WeWork Perth

2.13 WeWork Perth sits neatly and conveniently between the new Perth City Link and Elizabeth Quay, as depicted below17:

Perth City Link

WeWork Perth

Elizabeth Quay

2.14 Perth City Link includes Kings Square, Yagan Square, the underground Busport and Perth Arena. The purpose of this project, managed by the Metropolitan Redevelopment Authority, has been to “reconnect the CBD with Northbridge for the first time in more than 100 years. The area…will become an exciting new destination with housing, shops, restaurants, offices and more.”18

2.15 WeWork Perth is ideally located in being so close to Perth City Link which is virtually “a new inner city neighbourhood”19 in itself. The enormous, multi-faceted site is said to be “Perth’s newest entertainment precinct” and the “new heart of Perth”.20

2.16 An artist’s impression of an aerial view of Perth City Link is pictured below.21

17 https://www.google.com/maps/@-31.9525403,115.8550791,1891m/data=!3m1!1e3

18 https://www.mra.wa.gov.au/projects-and-places/perth-city-link/vision

19 https://www.mra.wa.gov.au/projects-and-places/perth-city-link/vision

20 http://www.abc.net.au/news/2018-03-03/yagan-square-opens-in-perth/9505952

21 https://www.mra.wa.gov.au/projects-and-places/perth-city-link/vision

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Public Interest Assessment WeWork Perth

2.17 The total amount of funding from the Federal, State and local government for Perth City Link is around $1.36 billion. It is expected to attract a total of $4 billion in private investment.22 Indeed, this is reflective of the significance of the site.

2.18 Elizabeth Quay is a “landmark waterfront development [that] reconnects Perth city with the Swan River to create a dynamic new entertainment and leisure precinct, set around a stunning 2.7ha inlet…Elizabeth Quay is at the heart of our plan to revitalise the city centre and enhance Perth’s reputation as one of the most liveable cities in the world. This $2.6 billion project creates a true waterfront precinct and is now part of the physical and cultural fabric of our city”23.

2.19 The businesses operating from WeWork Perth will complement and benefit from the activities occurring in Perth City Link and Elizabeth Quay as well as around the rest of the City of Perth.

2.20 The Locality also has an extensive network of public transport options. The following services are available, all within close walking distance of WeWork Perth and so further confirm that WeWork Perth will be ideally located for its purpose:

2.20.1 Perth Underground train station

2.20.2 Wellington Street underground Busport

2.20.3 Elizabeth Quay train station, ferry and south Busport

2.20.4 Bus services, including the free Central Area Transit, throughout the Locality

22 https://www.mra.wa.gov.au/frequently-asked-questions/questions/how-much-will-perth-city-link-cost/

23 https://www.mra.wa.gov.au/projects-and-places/elizabeth-quay/vision

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Public Interest Assessment WeWork Perth

2.20.5 Numerous taxi ranks throughout the Locality

Who lives and works in the Locality

2.21 The following statistics from the 2016 Census24 can be considered to gain some insight into the nature of the local community in terms of who lives and works in it.

Census category Perth Northbridge West Perth East Perth

People (total number resident) 11,425 1,307 5,608 10,596

Married 29.4% 23.5% 29.7% 37.4%

Never married 58.0% 65.2% 54.4% 49.5%

Born in Australia 34.7% 23.3% 38.2% 30.3%

Country of birth – top England Korea England England response other than (5.4%) (6.8%) (6.3%) (6.7%) Australia

Top three languages spoken Mandarin Mandarin Mandarin Mandarin other than English Cantonese Korean Spanish Korean Italian Cantonese Italian Cantonese

Occupation – top response Professionals Professionals Professionals Professionals (35.3%) (25.7%) (40.0%) (34.0%)

Median weekly personal $949 $867 $1,045 $992 income

Most common dwelling type Flat or Flat or Flat or Flat or apartment apartment apartment apartment (73.9%) (83.6%) (80.0%) (88.8%)

Tenure – top response Rented Rented Rented Rented (61.3%) (61.8%) (63.9%) (60.1%)

Median rent $430 $430 $400 $435

Median mortgage $2,167 $1,997 $2,000 $2,167 repayments

2.22 Based on the above statistics, the average resident in the Locality is:

2.22.1 not married,

2.22.2 an employed professional,

2.22.3 speaks Mandarin, if he/she speaks another language other than English,

24 https://www.abs.gov.au/census

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Public Interest Assessment WeWork Perth

2.22.4 earns a personal income of approximately $963 a week and

2.22.5 rents his/her apartment at $424 a week.

2.23 The 2016 Census data reveals that the estimated number of people working within the City of Perth was then 149,475.25 As referred to earlier in this PIA, the City of Perth currently estimates 134,000 people work in the City. The majority of the workforce is aged between 25 and 44, as shown in the following graph.26

2.24 The employment industries represented in the City of Perth are broken down in the bar graph below.27 Most of the offices and workplaces in the City are in the professional, scientific and technical services industry.

25 http://www.economyprofile.com.au/perth

26 http://www.economyprofile.com.au/perth/workers/work-in/age

27 http://www.economyprofile.com.au/perth/industries#bar-chart

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Public Interest Assessment WeWork Perth

2.25 The average person living and working in the City of Perth would be perfectly suited to working at WeWork Perth and would benefit from the proposed liquor service which is something that is expected in a contemporary office environment.

2.26 Additional details regarding the local community are provided further on in this PIA.

3 Manner of trade

3.1 WeWork Perth will provide shared office workspace and associated facilities management services for a variety of businesses to co-exist in a professional work environment.

3.2 The intention is to create a professional community at the Perth location just as WeWork has done at hundreds of other locations around the world.

3.3 WeWork will support the businesses operating from the Perth premises by managing the office facilities for them, thereby enabling them to concentrate on their core business. A “community team” of WeWork personnel will be stationed at the Perth premises. The manager of that team will fulfil the role of approved manager under the Act.

3.4 Amongst WeWork’s services at the premises will be the provision of refreshment making facilities, including tea, coffee, other non-alcoholic options and liquor for use by the workers and the guests that those workers may receive from time to time.

3.5 WeWork staff in the community team will ensure the premises is maintained to a high standard of cleanliness and stocked with necessary supplies.

3.6 There will be no direct exchange of money for the liquor. The liquor will be provided on a complimentary basis as part of the facilities management services arising from the arrangement that each individual business will have with WeWork to use space in the premises. That arrangement will take the form of a membership agreement.

Membership agreement

3.7 Businesses to operate from WeWork Perth will have to enter into a membership agreement with WeWork.

3.8 The membership agreement will entitle them to use space within the premises based on the terms of the agreement. All members will have to be over the age of 18.

3.9 The types of businesses that WeWork is currently finalising membership agreements with for the 152 St Georges Terrace premises include the following:

3.9.1 Accountants.

3.9.2 Consultants.

3.9.3 Start-ups.

3.9.4 Creative agencies.

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3.9.5 Technology/software companies.

3.9.6 Freelancers.

3.9.7 Advisors.

3.10 The terms of the membership agreement will entitle the member and its staff to utilise a communal lounge area which will include lounge chairs as well as tables and chairs to eat at, tea and coffee making facilities, a kitchenette and a modest supply of liquor.

3.11 The membership agreement will provide for WeWork to provide the services and amenities outlined in this PIA together with other associated things.

3.12 Members will pay membership fees to WeWork for those services.

3.13 Membership is priced and structured as one all-inclusive rate to make things simple for members. Rates for WeWork Perth will start from the following:

3.13.1 For a private office, $910 per month.

3.13.2 For a dedicated desk, $550 per month.

3.13.3 For a hot desk, $450 per month.

3.14 The provision of liquor will not be a specified requirement in the membership agreement and nor will it be an itemised cost, but rather the liquor service will be included as a member service and privilege under the agreement.

3.15 WeWork’s on-site community team will provide some of the services referred to in the membership agreement. That team will generally comprise a manager, receptionist, maintenance person and event co-ordinator.

The premises

3.16 152 St Georges Terrace is the Central Park building, partly pictured in the Google Maps image below.

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Public Interest Assessment WeWork Perth

3.17 The following extracts from the applicant’s floor plans are of levels 32 and 33, including level 33 balcony. Outlined in pink on each image are the common areas which comprise lounge, eating and drinking facilities, kitchenette and refreshment making facilities and toilets. Liquor will be supplied from these common areas.

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Public Interest Assessment WeWork Perth

3.18 Only the common areas, outlined in pink, are sought to be licensed.

3.19 The capacity of each level of the WeWork Perth premises will be as follows:

3.19.1 Level 32 - 210 people

3.19.2 Level 33 - 234 people

3.19.3 Level 34 - 224 people

3.19.4 Level 35 - 264 people

3.19.5 Level 36 - 249 people

3.19.6 Level 37 - 264 people

3.19.7 Level 38 - 249 people

3.20 Most of each level will comprise office working areas including individual offices, meeting rooms, open plan desk areas and copying/printing facilities.

3.21 There will be a front reception desk, depicted below, operated by WeWork. All workers and any visitors will have to pass through the reception to access the rest of the floor.

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Public Interest Assessment WeWork Perth

3.22 Toilets of a standard and volume designed to accommodate the whole of each floor being occupied will be available on each level.

3.23 The following images generally illustrate aspects of the proposed premises:

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Public Interest Assessment WeWork Perth

3.24 The layout, materials, colours and décor are all carefully designed to create an inviting, comfortable and motivating working space with all of the features needed to facilitate creativity and productivity.

3.25 “Any workspace can have a lounge, but ours are decorated with custom murals. Your old office might have had a coffee pot, but ours has a micro-roasted coffee bar and fresh fruit water. We’ve considered every detail so you can focus on your business.”28

Liquor services

3.26 The liquor service proposed will be modest in several respects. Whilst considered to be a very important feature of the premises, the liquor service will be very much ancillary.

3.27 A small selection of unrefrigerated wine and beer on a tap will be available for the workers to access.

3.28 The liquor supplies will only be available during limited hours, namely 2pm-6pm on usual working/business days. At other times the taps will be switched off and liquor supply locked.

3.29 From time to time WeWork will arrange events for the workers at the premises, designed to bring the workers together for social networking and business development purposes. Liquor is proposed to be available at these events.

3.30 A range of non-alcoholic drinks will also be available including tea, coffee, juices, soft drinks and filtered water..

Proposed trading conditions 3.31 The applicant seeks approval for the following to be endorsed on the SFL in terms of special trading conditions:

The licensee is authorised to sell and supply liquor to workers at WeWork Perth, levels 32-38, 152 St Georges Terrace, Perth and their guests, for consumption in the licensed areas, between 2pm and 6pm on usual business days.

4 Sections 5 and 46 and Regulation 9A

4.1 Submissions addressing section 5 and 46 of the Act and Reg 9A are contained throughout this PIA and also in more detail in the applicant’s accompanying Legal Submissions dated 27 September 2019.

28 https://www.wework.com/buildings/45-francis-st--perth--WA

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5 Harm or ill-health – section 38(4)(a)

5.1 The applicant has had regard for the various risk factors and indicators in the Locality contemplated in the PIA Policy. These include “at risk groups and sub-communities”, alcohol-related hospitalisation and crime.

5.2 These matters are addressed in detail in this section of the PIA. Collectively, they reveal there are no stand-out risk factors of the Locality relevant to this particular application, such that there should be any concern surrounding the grant of the proposed SFL.

5.3 The 2016 Census indicates that few people living in Perth fall within a category of persons regarded as “at risk” under the PIA Policy. The majority of people living in Perth are young professionals with a higher than average education and income.29 WeWork Perth is proposed to be used by these very people.

At risk groups and sub-communities

5.4 The table below contains some of the 2016 Census statistics30 that are relevant in assessing the at risk groups and sub-communities living in the Locality. A Locality average has been calculated and compared with the whole of the City of Perth and the rest of the State so as to give context.

At risk group or Perth Locality City of Perth Western subcommunity / relevant average Australia Census category

At risk group: “Children and young people”

Persons aged 14 and 6.9% 5.5% 5.2% 19.2% younger

Persons aged 19 and 9.5% 7.8% 9.3% 25.3% younger

Average age of persons in 32 32 32 36 suburb

At risk group: “Aboriginal people and communities”

Aboriginal and Torres Strait 1.0% 0.75% 0.8% 3.1% Islander people

At risk group: “Families”

Couple family without 67.6% 69.7% 70.0% 38.5% children

29 https://quickstats.censusdata.abs.gov.au/census_services/getproduct/census/2016/quickstat/SSC51149

30 http://www.abs.gov.au/websitedbs/D3310114.nsf/Home/2016%20QuickStats

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At risk group or Perth Locality City of Perth Western subcommunity / relevant average Australia Census category

Couple family with children 21.1% 18.1% 19.3% 45.3%

One parent family 8.1% 8.4% 7.1% 14.5%

Other family 3.2% 3.8% 3.6% 1.7%

At risk group: “Migrant groups from non-English speaking countries”

Australia as country of birth 34.7% 31.6% 29.8% 60.3%

Top three responses as to English English English English ancestry Australian Australian Chinese Australian Chinese Chinese Australian Irish (generally)

English only language 50.8% 47.8% 46.9% 75.2% spoken at home

Households where a non 33.0% 32.8% 35.3% 19.4% English language is spoken

At risk group: “People in low socio-economic areas”

Worked full-time 63.2% 63.1% 62.1% 57.0%

Worked part-time 24.2% 24.2% 23.4% 30.0%

Unemployed 8.2% 8.0% 9.4% 7.8%

Median weekly income – $949 $963 $928 $724 personal

Median weekly income - $2,243 $2,216 $2,291 $1,910 family

Median weekly income - $1,827 $1,798 $1,849 $1,595 household

More than $3000 gross 23.5% 23.7% 25.2% 19.2% weekly income

5.5 The Locality presents as low risk based on the following key positive factors and pursuant to the PIA Policy:

5.5.1 There are fewer children and young people.

5.5.2 There is a low proportion of Aboriginal and Torres Strait Islander people.

5.5.3 The resident population has higher than average income.

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5.6 The PIA Policy suggests that the high prevalence of migrant groups living in a locality is a negative risk factor. That is certainly not the case in this application where there is acknowledged to be evidence of a higher proportion of migrants. The status of the Locality as the State’s capital and an evolving cosmopolitan city means that people of all backgrounds are living in, working in, visiting or passing through it on a daily basis. Those people will not suffer from the WeWork liquor service which will be very limited and confined both physically and operationally. Migrants seeking office space will potentially benefit greatly from the services and facilities to be available at WeWork Perth.

5.7 The PIA Policy also contemplates other at risk groups and sub-communities, as follows, which could not be identified from Census statistics. Further submissions and information in respect of these other at risk groups are provided below:

5.7.1 The Locality is clearly not a “regional, rural [or] remote” community.

5.7.2 The Locality is not known to have “mining communities or communities with a high number of itinerant workers”. However, it is acknowledged there may be some mining or itinerant workers living in the Locality and some mining companies operate offices in the Locality and may acquire membership with WeWork to operate from WeWork Perth.

5.7.3 As to “communities that experience high tourist numbers”, the following information and submissions are provided:

(a) The Locality is widely known to attract large numbers of tourists from far and wide.

(b) Tourism WA recorded an average of 11 million visitors each year between 2016 and 201831, of which 18% visited and stayed overnight in the City of Perth itself32.

(c) As described earlier in this PIA, the Locality is rapidly transforming and modernising. The numerous projects and developments throughout the City are creating services and facilities to support the local population as well as the tourism industry.

(d) There is nothing about the WeWork Perth proposal to suggest that tourists will be put at risk from the SFL. In fact, tourists have virtually no relevance to this application. Unless they are guests of a worker at the premises, they will be unlikely to even know that the WeWork Perth liquor service exists and will not be able to access it.

31 https://www.tourism.wa.gov.au/Publications%20Library/Research%20and%20reports/2018/Domestic%20Visitor %20Profiles%202018/Domestic%20overnight_2018%20Factsheet.pdf at page 3

32 https://www.tourism.wa.gov.au/Publications%20Library/Research%20and%20reports/2018/Tourism%20Region %20Profiles%202018/DP_2018%20Factsheet.pdf at page 7

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5.8 There are no churches, schools, hospitals or day care centres near the proposed licensed premises.

5.9 The WeWork Perth liquor services will not even be visible to anyone other than workers at the premises and any guests of workers. The licensed premises will be confined to within the high rise building.

5.10 Based on the information contained in the sub-paragraphs above, WeWork Perth, once licensed, will have no adverse effect on any person who is part of an at risk group or subcommunity in the Locality.

Social health indicators

5.11 Various factors indicate the social health of the Locality including crime rates and alcohol related hospitalisations which are referred to in the following sub-paragraphs.

5.12 As regards crime, statistics published by WA Police33 have been considered and are graphically presented below. The graph below shows the total number of offences recorded in the suburbs that comprise the majority of the Locality, with the subsequent table following providing a breakdown of those offences. It is important to highlight that this information relates to general offence data only and is not that of proven crimes, alcohol related incidents or anything necessarily relevant to the applicant’s particular manner of liquor service.

5.13 Whilst there has been an increase in offences generally since 2009/10, this should not pose as any obstacle to approval of the application. The increase mainly relates to fraud offences which are not ordinarily attributable to liquor or community harm or ill-health.

33 https://www.police.wa.gov.au/crime/crimestatistics#/

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5.14 For example, in East Perth in 2010/11, there were 66 fraud offences recorded which can be contrasted with the most recent fraud figures of 357 offences. Comparatively Northbridge fraud offences rose from 30 to 817 in the same time period, West Perth 157 to 334 and the suburb of Perth 440 to 2,064.

5.15 Authorities have warned about the dangers of “tap-and-go credit card fraud”34. Relevantly, however, the liquor service proposed in this application will not involve any tap-and-go transactional banking or credit card use. Nor will the general public have access to the service.

5.16 The membership agreement applicable to users of the WeWork Perth premises will incorporate expectations for behaviour. WeWork personnel in the community team on site will also monitor that behaviour to ensure it is safe and lawful. The limited nature of the liquor service to be made available will also help to ensure there is little scope for crime, anti-social behaviour of other adverse consequences from the supply of liquor.

5.17 As to alcohol-related hospitalisations, the 2014 surveillance report prepared by the Drug and Alcohol Office35 contains some useful information. It is believed to be the most recent publication of its kind. The following extract from the report provides statistics regarding the rate of alcohol-related hospitalisations in the City of Perth between 2007 and 2011.

5.18 There was a “significantly higher” rate of alcohol-related hospitalisations in the City of Perth for the reporting period, particularly among males. This information is of little

34 https://www.abc.net.au/news/2018-07-26/tap-and-go-fraud-on-the-rise/10040890

35 ‘Alcohol-related hospitalisations and deaths in Western Australia, Regional Profile: North Metro’. It is understood that at the date of this PIA the 2014 version of the report is the most current, even though it is no longer readily available online. A copy may be provided to the licensing authority if requested.

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relevance to the WeWork proposal given the very limited extent to which liquor will be available and the fact that the general public will not have access.

5.19 Positively, the most recent published data has revealed that “the majority of Australians are still enjoying alcohol responsibly and we are still drinking at 50 year lows”.36

Strategies to be implemented to minimise harm or ill-health

5.20 There are a range of strategies that the applicant will implement which will minimise the potential for harm or ill-health to occur within the Locality as a result of liquor being made available. Those strategies including the following:

5.20.1 Providing member businesses that operate from WeWork Perth with policies and standards applicable to the responsible service and consumption of liquor.

5.20.2 Not promoting the liquor service externally from the WeWork Perth premises.

5.20.3 Creating and maintaining services and facilities which will be of very high quality in all respects.

5.20.4 Adopting and subsequently operating in accordance with a responsible Management Plan and Code of Conduct.

5.20.5 Not promoting alcoholic drinks in a manner likely to result in rapid or excessive consumption.

5.20.6 Thoroughly training staff on all appropriate matters for the proper conduct of business under the SFL including responsible service of liquor.

5.21 In respect to juveniles:

5.21.1 It is important to highlight that juveniles will rarely ever be at the premises and if they are it is likely to be in very small numbers and for very brief periods.

5.21.2 WeWork Perth will be an adult, corporate environment. There will be nothing likely to attract juveniles to the premises.

5.21.3 As stated previously, a requirement of WeWork membership is being over the age of 18.

5.21.4 In any event, strict policies will apply in respect of juveniles.

5.21.5 No liquor will be supplied to juveniles or anyone who is suspected of trying to obtain liquor for a juvenile.

36 https://www.theshout.com.au/news/total-alcohol-consumption-remains-at-50-year-lows/

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5.21.6 People who are suspected of being under the age of 18 will be refused entry at the front reception desk if they cannot prove their adult age with satisfactory identification.

5.21.7 Juveniles will only be permitted if in the company of a responsible adult, or at the premises for business purposes.

6 Impact on amenity – section 38(4)(b)

Nature and character of the local community

6.1 Previous submissions and evidence have been provided earlier on in this PIA that address the nature and character of the community living and working in the Locality.

6.2 The Locality recorded a population of 18,340 at the time of the 2016 Census.37

6.3 In terms of the broader City of Perth, the population is predicted to increase by nearly 40% over the next two decades, almost 2% per annum.

How the proposed premises will fit into the amenity 6.4 WeWork Perth will have no street frontage and not be visible from outside levels 32- 38 in the Central Park building. There will be no external façade visible to the general public and the premises will not be open to the general public as any kind of

37 https://www.abs.gov.au/census

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hospitality destination. For these reasons, WeWork Perth will likely have no impact, or a neutral effect, on the amenity.

6.5 However, WeWork Perth will make a fantastic contribution to the working environments available in Perth with a unique and vibrant alternative office space.

6.6 WeWork Perth will provide an opportunity for businesses to come together physically so as to benefit each other whilst maintaining independence and autonomy operationally.

6.7 The accompanying evidence of support from prospective members/workers at the premises confirms the perceived benefits.

Outlet density 6.8 As the PIA Policy does not apply strictly to SFL applications, the applicant is not required to specify all of the existing licensed premises within a 500 metre radius. To the extent that the issue of outlet density may be considered relevant to this application, the applicant has considered the existing licensed premises in the suburb of Perth.

6.9 There are 254 current licences in the suburb of Perth.38

6.10 No existing licence is capable of catering for the requirements of liquor for workers at WeWork Perth.

6.11 There is no bar facility inside levels 32-38 of the Central Park building dedicated to providing for workers there.

6.12 The WeWork proposal certainly will not duplicate anything else in the area. There is currently no active works canteen SFL in Perth.

6.13 Given the uniqueness of the application and its limited scope, the licensing authority should be able to comfortably conclude that there is no issue as to outlet density in this case.

Consultation

6.14 The applicant has liaised with the City of Perth regarding its proposed operations and sought approvals for the liquor service.

6.15 The applicant has also liaised with existing and prospective members in ascertaining the demand for the proposed liquor service. Evidence to this effect is included in the application papers.

38 https://portal.rgl.wa.gov.au/licencesearch?status=Current&suburb=PERTH&group=Liquor+Premises

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7 Offence, annoyance, disturbance or inconvenience – section 38(4)(c)

7.1 The applicant has considered the impact that the proposed liquor service may have on people who live or work in the vicinity of WeWork Perth and confidently concluded that no adverse impact will result.

7.2 It is not considered that there are any high risk factors associated with the application and none of the people regarded as being “at risk” in respect of the PIA Policy are likely to be affected by the particular nature of limited services proposed. This proposition is supported by the factors relating to the at risk groups and sub communities referred to earlier on in this PIA and the specifics of the business in question.

7.3 Liquor will be an important, but very much ancillary feature of WeWork Perth.

7.4 WeWork has extensive experience in creating and managing shared office facilities that include a liquor component.

7.5 Despite these facts, the applicant has had regard for the need to “combat offence, disturbance or inconvenience”39 that could potentially occur and will do the following:

7.5.1 Limit the hours when liquor will be available.

7.5.2 Maintain premises that are constructed and furnished to a high standard.

7.5.3 Not supply liquor in a manner likely to encourage excessive consumption.

7.5.4 Have and maintain security through the front reception desk.

7.5.5 Closely monitor anyone at the premises when liquor is available.

7.5.6 Ensure staff are thoroughly trained on all facets of the business and stay alert to monitoring people at the premises.

7.6 No high risk factors have arisen in preparing this PIA. The risk element that does exist, as with any licensed premises, is miniscule and will be very well managed in any event.

8 Tourism, community or cultural matters – section 38(4)(ca)

8.1 WeWork Perth, once licensed, will generate considerable community and cultural benefits through making available in WA, for the first time, a serviced work setting which is popular elsewhere around the world.

39 PIA Policy

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8.2 The proposal offers great convenience for businesses and will enable members at WeWork Perth to focus on managing and developing their core business without having to deal with day-to-day facilities management.

8.3 Members at WeWork Perth will enjoy considerable conveniences and potentially save on the time, cost and effort of dealing with many of the obligations and administration usually associated with business premises.

8.4 WeWork will also provide a wonderful corporate community in Perth where the members can collaborate if they so wish and share expertise and connections. A relaxed, corporate environment will be established.

8.5 The proposed liquor service will support these benefits and help to ensure that WeWork Perth meets with the usual and ordinary expectations of modern office consumers.

8.6 As referred to earlier on in this PIA, the City of Perth has experienced significant growth and development in recent years. It is entirely appropriate that new businesses, such as the unique one proposed by WeWork, be supported and encouraged to help ensure that the City continues to evolve as a modern capacity city, comparable with other capital cities around the world. Further in this case is the fact that the WeWork proposal supports and encourages other new businesses by providing services and facilities for them to be become established and operate.

8.7 The WeWork model is consistent with creating a modern, liveable and diverse community.

8.8 Whilst there are some existing versions of shared working spaces in Perth, none is akin to the sophisticated WeWork model.

8.9 Relevantly, the City of Perth is very supportive of such ventures. It has published the following statement:

The City of Perth seeks to support and attract new businesses to the city and is excited to share the range of co-working spaces available with prime CBD, St Georges Terrace addresses.40

8.10 This is corroborated by the accompanying supporting evidence from prospective users of the WeWork services and facilities.

9 Other matters

Security and safety 9.1 The applicant has had regard for matters of safety and security.

9.2 The premises will mainly be accessible to WeWork personnel and members only.

40 https://www.perth.wa.gov.au/live-and-work/businesses/starting-a-business

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9.3 Anyone attending at the premises will need to pass a WeWork managed reception desk where trained staff will be stationed.

9.4 The premises will be securely locked after business hours.

9.5 The liquor will only be available during specified hours.

9.6 A high level of staff training will be adopted which will include how to deal with incidents that are or could potentially become, criminal or unsafe.

9.7 A very high standard of premises will be maintained.

Harm minimisation 9.8 As referred to previously in this PIA and the accompanying Legal Submissions there are various features of the proposal which will contribute towards minimising harm.

9.9 The applicant has prepared plans in accordance with the policy of the Director of Liquor Licensing in relation to harm minimisation.

9.10 Every effort will be made by the applicant to conduct business under the SFL in a manner that minimises the potential for harm or ill-health to occur as a result of the liquor being made available at the premises.

9.11 Various policies, practices and procedures will be implemented to facilitate compliance and to create a place that encourages responsible drinking.

9.12 Staff will be trained thoroughly on matters of harm minimisation and responsible service and members will also be educated accordingly.

9.13 Strict policies will apply in respect of juveniles as referred to earlier in this document.

9.14 There will be close monitoring of drunkenness on the premises which will not be tolerated.

10 Conclusion

10.1 This document thoroughly addresses the PIA Policy with specific reference to the application.

10.2 The applicant has provided a detailed proposal including necessary formalities and a evidence of support and demand from people who are/will become members at WeWork Perth.

10.3 This PIA deals with all factors relevant to the public interest and careful consideration has clearly been given to all relevant public interest factors. As required, the applicant has identified the relevant “at risk groups and subcommunities” and also both positive and negative points involved.

10.4 The large number of positive public interest factors in this case far outweigh the few negatives which, in any event, have been addressed by the applicant in the proposal.

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10.5 Given all relevant considerations the application is not complicated in any way, is in fact innocuous from a harm and ill health perspective and should not attract any controversy.

10.6 Further aspects of the public interest and the legal issues associated with the application are addressed in the accompanying Legal Submissions dated 27 September 2019.

Dated 27 September 2019

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