Public Interest Assessment

CRAZY BANG PTY LTD Application for a grant of a liquor store licence

______Public Interest Assessment

______

HanGaWee Market Innaloo Shop 1118 Westfield Innaloo Shopping Centre

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Contents 1 INTRODUCTION ...... 3 1.1 Background ...... 3 1.2 Brief overview of the proposal ...... 4 1.3 Applicant’s Details ...... 6 2 LOCALITY ...... 8 3 THE PROPOSED STORE ...... 11 3.1 Location of the Proposed Store ...... 11 3.2 The current operation of the Proposed Store ...... 13 3.3 Theme and Décor ...... 14 3.4 Target Client Base ...... 14 3.5 Proposed Manner of Trade ...... 15 3.6 Proposed list of the Korean liquor products ...... 19 3.7 Proposed trading conditions ...... 22 4 HARM OR ILL-HEALTH – SECTION 38(4)(a) ...... 23 4.1 At Risk Groups and Sub-communities within the Locality ...... 23 4.2 Social Health Indicator ...... 26 4.2 Harm Minimisation Strategies ...... 31 4.3 Security and Safety ...... 35 5 PUBLIC CONSULTATION & CONSUMER EVIDENCE ...... 35 5.1 Survey and Questionnaires ...... 36 5.2 Petition ...... 41 5.3 Form LLD/18 Submission in Support of this Application ...... 41 5.4 Consultation with Korean Liquor Suppliers ...... 45 6 OBJECTS OF THE ACT & PUBLIC INTEREST BENEFITS ...... 45 6.1 Primary Objects of the Liquor Control Act...... 45 6.2 Secondary Objects of the Liquor Control Act ...... 46 6.3 Public Interest Benefits and Consideration ...... 47 7 IMPACT ON AMENITY – SECTION 38(4)(b) ...... 48 7.1 Nature and Character of the Locality ...... 48 7.2 How the Proposed Store will fit into the Amenity ...... 50 7.3 Traffic and Access ...... 51 7.4 Public Transport ...... 52

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

7.5 Parking ...... 52 7.6 Streetscape and Atmosphere ...... 52 7.7 Noise, Anti-social behaviour and Security ...... 53 7.8 Security and Safety ...... 54 7.9 Outlet density ...... 55 8 OFFENCE, ANNOYANCE, DISTURBANCE, OR INCONVENIENCE – SECTION 38(4)(c) ...... 57 8.1 No high-risk factor ...... 57 8.3 Further measures...... 61 9 TOURISM, COMMUNITY OR CULTURAL MATTERS – SECTION 38(4)(ca) ...... 62 10 SECTION 36B ...... 63 11 CONCLUSION ...... 64 12 DECLARATION ...... 65

1 INTRODUCTION

1.1 Background

Crazy Bang Pty Ltd (ACN 617 748 491) (“the Applicant”) is applying for a grant of a liquor store licence (“the Application”) in respect of the existing Korean specialty grocery store, trading as HanGaWee Market Innaloo (“the Proposed Store”) situated

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

at Shop 1118, Westfield Innaloo Shopping Centre (“the Centre”), Ellen Stirling Boulevard, Innaloo in the State of Western Australia.

This Public Interest Assessment (“the PIA”) is made in support of the Application and addresses all relevant aspects of the public interest in accordance with both the Liquor Control Act 1988 (WA) (“the Act”) and the Director of Liquor Licensing (“the Licensing Authority”)’s Public Interest Assessment policy (“the PIA Policy”). This PIA also briefly addresses the Licensing Authority’s Outlet Density – Packaged Liquor Premises policy1 relating to section 36B of the Act.

This PIA is part of the Application and should be read in conjunction with the other parts and supporting material, all of which is itemised in the accompanying document titled ‘Index of Lodgment Documents’ and is lodged with the Licensing Authority including: -

(a) Report on the Existing Packaged Liquor Premises in the Locality attached to the Statutory Declarations of the Applicant’s solicitors;

(b) Petition signed by 751 residents of the local and wider community for the licensing authority to authorise the Applicant to sell a very specific and unique product range of the Korean liquor products for sale;

(d) 109 LLD 18 Forms - Submissions in support of this Application; and

(e) Letters of Confirmation by Korean liquor suppliers (KFBW Pty Ltd and Yoosung WA Pty Ltd).

1.2 Brief overview of the proposal

The Proposed Store is a part of the Korean specialty grocery store chain known as ‘HanGaWee Market’, currently being operated in the four locations of Northbridge, Westfield Carousel Shopping Centre, Westfield Innaloo Shopping Centre (the Proposed Store), and Westfield Booragoon Shopping Centre under the directorship of Ms Yumi Park and Mr Libae Bang. HanGaWee Market stores have built a reputation in the local and wider community as a reliable and trustworthy retailer of traditional and novelty Korean food and beverage products.

The Proposed Store commenced its operation in 2020, catering to the growing demand of the local and wider community for Korean novelty and traditional foods and beverages. This demand is comprised of both residents and visitors of the City of Stirling who wish to enjoy the Korean culture and to explore the diversity of Korean products.

1 Department of Local Government, Sport and Cultural Industries, Outlet Density - Packaged Liquor premises (Webpage, 25 February 2021) .

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The Proposed Store’s popularity within the local and wider community rests in its customer-centric culture. The Applicant constantly reviews its product ranges based on feedbacks and suggestions it receives from its customer base.

After countless requests and feedback from its customers for the sale of the Korean liquor products at the Proposed Store, the Applicant now wishes to further improve its quality of service to the local and wider community by providing a very specific and unique Korean liquor product range that is not readily available in the Locality for sale. This is the basis for this Application.

In essence, the Applicant’s proposal is to establish a niche-type liquor store: -

(a) offering a one-stop-shopping experience for its customers seeking a full component of Korean food and beverages;

(b) offering a very specific and unique product range of Korean liquor products only to meet the identified consumer requirements for Korean liquor products that are not readily available in the Locality;

(i) comprising of a dedicated single refrigerator exclusively for liquor products only and a cashier working space in addition to the dedicated Point of Sale for liquor sales only; and

(ii) delineated and separated from the remainder of the Proposed Store by way of a physical barrier and signage; and

(d) maintaining the Applicant’s primary focus on traditional and novelty Korean food products.

The compelling evidence from the public in support of this Application is comprised of many personal statements and remarks from its customers made over several months about the positive benefits which can flow from the grant of this Application. The positive benefits include, but not limited to: -

(a) a desire to enrich cultural diversity in Australia;

(b) a desire to cater to the specific needs of the strong Asian community in the local and wider community;

(c) a desire to have a wide range of choices in Korean liquor products that is not readily available in the locality in which the Proposed Store is situated;

(d) a desire not to travel unnecessary long distances to purchase Korean liquor products, but to be able to purchase them within the locality; and

(e) the convenience of having a one-stop Korean food and beverage shopping experience at a convenient location.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

In addition to the large number of petitioners and submissions in support of this Applicant, the Applicant also conducted a questionnaire survey during the period between February 2021 and May 2021, receiving 361 participants’ responses. The survey clearly reveals that a strong demand and consumer requirement, for what is a specific and unique product range of Korean liquor products, is not currently met by the existing packaged liquor premises in the locality in which the Proposed Store is situated. The details of the survey will be discussed more in depth in this PIA.

The Applicant’s proposal and specialisation in Korean liquor products are entirely novel, unique, and distinguishable from any other existing packaged liquor premises in the locality in which the Proposed Store is situated.

In all circumstances, the Applicant submits that the grant of the application is in the public interest and that by the granting of such licence: -

(a) there will be very minimal to no harm or ill-health that will be caused to people, or any group of people, in the locality due to the sale of liquor at the Proposed Store;

(b) there will be very minimal to no detrimental impact on the amenity of the locality; and

(c) there will be very minimal to no offence, annoyance, disturbance, or inconvenience caused to people who reside or work in the vicinity of the Proposed Store.

1.3 Applicant’s Details

(a) Application

The Applicant is applying for a grant of a liquor store licence at the Proposed Store.

(b) Applicant’s name

Crazy Bang Pty Ltd (ACN 617 748 491).

The Applicant is currently trading as HanGaWee Market Innaloo.

(d) Address of Premises

The Proposed Store is located inside the Centre situated at 388 Scarborough Breach Road, Innaloo in the State of Western Australia. The Centre is within the

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

City of Stirling and is in the metropolitan area for the purposes of the Act.

Location Plan of the Proposed Store within the Centre

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

2 LOCALITY

The term ‘locality’ is defined, for the purposes of assessing the public interest and impact on amenity, as the area surrounding the proposed licensed premises and most likely be affected by the granting of an application in relation to amenity issues.2

According to the PIA Policy, the locality of the Proposed Store is, prima facie, the surrounding area within a 2-kilometre radius from the Proposed Store (“the Locality”), depicted with a circle on the map as illustrated below.3

Map of the Locality

The Locality wholly or partially includes the following suburbs:

(a) Innaloo;

(b) Woodlands;

2 Department of Local Government, Sport and Cultural Industries, Public Interest Assessment Policy (“PIA Policy”) (Website, 16 April 2020) . 3 PIA Policy.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(d) Osborne Park;

(e) Stirling;

(f) Churchlands;

(g) Herdsman; and

(h) Wembley Downs.

For the purpose of assessing the Locality’s risk, the suburbs of Herdsman and Wembley Downs will be excluded from the Locality as the 2-kilometre radius only covers a corner of the oval of Hale School at Wembley Downs and Herdsman is a nature reserve with no record of any local residents according to the 2016 Census.4 The Locality is entirely within the City of Stirling local government area and is a central part of the Perth metropolitan region.

The Proposed Store and its Locality is entirely within the City of Stirling and located in the inner central part of the Perth metropolitan region. The City of Stirling Strategic Community Plan 2018 – 2028 stipulates that: -

“the City of Stirling will be a place where people choose to live, work, visit and invest. We will have safe and thriving neighbourhoods with a range of housing, employment, and recreational opportunities. We will engage with our diverse community to help shape our future into the City of Stirling– City of Choice.”5

The City of Stirling is located approximately 8 kilometres north of Perth and covers a total land area of just over 100 km2. It is the largest local government authority in the State of Western Australia in terms of population, consisting of approximately 227,000 residents spread across over 30 suburbs.6

4 Australian Bureau of Statistics, 2016 Census Community Profile – Herdsman (Community) (Webpage, 23 October 2017) . 5 City of Stirling, People with Disability – Access and Inclusion Plan 2021-2025 (Webpage, 2021) . 6 City of Stirling, Local Planning Strategy – Part Two (Webpage, 2021) .

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The City of Stirling depicted as outlined. Source: Maps.Stirling.wa.gov.au

The City of Stirling dates back to 1871 with early Asian and European migrants playing an important part in its story. These migrants overcame the challenges of moving and living in a new country and went on to set up successful ventures such as market gardens and other commercial enterprises in their suburbs.7 The City of Stirling is a place of cultural diversity as about 45% of its residents are born overseas. There is strong multi-cultural diversity within the City of Stirling which includes people born in over 35 countries other than Australia.8 All these history and heritage contribute to the colour and personality of the City of Stirling, nurturing and enriching the lives of its residents. The building of the Mitchell Freeway to Karrinyup Road in 1983-84 facilitated

7 City of Stirling, Community History (Webpage, 2021) . 8 City of Stirling, Local Planning Strategy – Part Two (Webpage, 2021) .

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

the growth of Stirling as a regional hub, and the bus/train interchange (Joondalup line) was completed in 1992.

Aerial Photograph of the Stirling City Centre

3 THE PROPOSED STORE

3.1 Location of the Proposed Store

The Proposed Store is situated within the Centre, at the corner of Scarborough Beach Road and Ellen Stirling Boulevard. This location is now part of Stirling City Centre which is approximately 1 km from the Stirling Train Station.

The Centre is currently home to some of Australia’s most well-known retailers including Coles, Woolworths, Big W, Spudshed, Target, and Kmart with a gross lettable area of 47,374 m2 and 2,395 car parking spaces, making it one of the largest shopping centres in the State of Western Australia. There are 161 retailers in the Centre with 7.6 million annual customer visits and a total annual retail sale of $331 million.9 The Stirling City Centre and the neighbouring Herdsman Glendalough area is the largest business precinct outside of Perth CBD and currently employs 40,000 people.

9 Scentre Group, Westfield Innaloo (Webpage, 2021) .

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Map of the Centre

This main retail centre was originally constructed in 1967 and has since undergone numerous expansions over the years. On 28 July 2015, the Metro North-West Joint Development Assessment Panel (JDAP) approved a development that was the most substantial expansion to date. A further amendment to the development application was supported by JDAP on 30 January 2018. The area contained within the approved retail centre located just north of Scarborough Beach Road at the Centre includes expansion over 100,000 m2 Net Lettable Area (NLA). The development approval also includes: -

(a) a new town square adjacent to Oswald Street with restaurants and other hospitality and commercial uses on the ground floor;

(b) entertainment, recreation, and cinema precinct on the upper level/s;

(d) major external road works with new pedestrian and cycling facilities within the locality and surrounding area.

In addition to the retail uses, the Stirling City Centre also includes: -

(a) Stirling bus and rail interchange;

(b) Osborne Park Hospital;

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(d) A portion of the Osborne Park industrial area.

The Stirling City Centre covers a diverse range of land uses and is fragmented by the Mitchell Freeway and other major regional roads.

3.2 The current operation of the Proposed Store

(a) Current operation

The Proposed Store offers Korean food products and beverages for sale and started its operation in July 2020 with approximately 152 m2 of floor plan.

The Applicant strives to improve its service level by constantly reviewing and implementing feedbacks it received from its customer base. The Applicant seeks to add value to its service by meeting the numerous requests from its growing customer base to sell Korean alcoholic beverages.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(b) Services and Facilities of the Proposed Store

The Proposed Store will provide a niche-type liquor service that will complement and add value to its existing range of Korean food products and beverages. This concept of specialising in Korean alcoholic beverages is unique and distinguishable from any other existing packaged liquor premises in the vicinity. In addition, the Proposed Store, being the only Korean specialty grocery store in the Centre as well as within the Locality, will present a convenient one-stop shopping experience to all its customers. Almost all of HanGaWee Market’s exclusive Korean food products and beverages are sourced and imported from overseas suppliers.

The Proposed Store features a main retail area primarily for non-alcoholic Korean food and beverage products and a secondary space measuring 4.07 m2 located at the right of the entrance for alcoholic beverages display and storage. This designated area will have its own POS service counter and refrigeration unit specifically for alcoholic beverages. The non-alcoholic food products and beverages area will be completely segregated from the discrete and designated alcoholic beverages area. The sale of alcoholic beverages will strictly be complementary to the primary business of selling mainly Korean consumable products.

3.3 Theme and Décor

The Proposed Store’s target customer base is primarily people of Asian descent, particularly people of Korean heritage. The layout and ambience of the shop are modelled after a typical Korean supermarket in South Korea such that its customers can feel and get that familiar atmosphere when doing their shopping at the Proposed Store.

Its theme is similar and consistent with all the other grocery stores and the layout is designed to enhance shopping convenience, such that shopping trolleys can be easily navigated and signages are clearly visible.

The Proposed Store features an aesthetically pleasant and bright shopping environment. The non-alcoholic products displayed in the Proposed Store will be clearly and completely separated from the small, discrete, and delineated space where liquor products are proposed to be sold.

3.4 Target Client Base

The Proposed Store will provide a niche-type liquor service that will complement and add value to its existing range of Korean food products and beverages. This is to cater to the growing demand from the local and wider communities for Korean alcoholic

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

beverages, owing in part to the popularity of the K-Pop phenomenon that is happening around the world. The local community would comprise of people living and working in the Locality whereas the wider community would include people visiting the Locality.

Although the current customer base comprises primarily of people of Korean heritage, the Applicant aspires to expand the Korean culture to the community through the introduction of a wider and more complete range of traditional and conventional Korean food and beverage products.

3.5 Proposed Manner of Trade

The Proposed Store is expected to draw most of its customers from suburbs north of the Swan River, particularly those from Innaloo, Woodlands, Doubleview, Osbourne Park, Stirling, and Churchlands, with a small portion of from Wembley Downs and Herdsman.

In this context, the Applicant is seeking to add value to its services to the local and wider community to meet the growing demand for Korean liquor products.

The licensed premises is defined as the area outlined in blue on the plan below.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The following is the Applicant’s proposed manner of trade with regard to the Proposed Store: -

(a) Trading hours

The Applicant is seeking the full trading hours as permitted under s 98D - Liquor Store Licence of the Act. However, actual trading hours are confined to Westfield Innaloo Shopping Centre’s prescribed trading hours, as listed below: -

Day Hours

Monday to Wednesday 9:00 AM – 8:00 PM

Thursday 9:00 AM – 9:00 PM

Friday 9:00 AM – 8:00 PM

Saturday 9:00 AM – 5:00 PM

Sunday 11:00 AM – 5:00 PM

Further to the limitation of the Proposed Store’s trading hours as aligned with the Centre’s trading hours, on the grant of the liquor store licence, the Applicant will not sell nor supply any alcohol: -

(i) outside the timeframe of 12:00 to 10:00 pm on ANZAC Day; and

(ii) on Good Friday and Christmas Day.

As the Proposed Store has no external entrance, the Proposed Store will be unable to open at times the Centre is not trading.

(b) Intended Manner of Trade

The Applicant seeks to add value to its services to the local and wider community to meet the growing demand for Korean liquor products. However, given that the Applicant’s primary business focus is a Korean specialty grocery store, the Applicant is committed to maintaining its primary focus on Korean grocery and non-alcoholic beverage products, with the sale of liquor products being a secondary function.

The following safe and effective manner of trade will be implemented to reflect the Applicant’s bona fide and commitment to its proposal and to effectively operate its business: -

(i) Korean Liquor Products only

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

To maintain the Applicant’s primary focus on Korean grocery and non- alcoholic beverage products, the Proposed Store is intended to sell Korean liquor products that only contain less than 20% alcohol per volume. The Applicant has no intention to diversify its alcohol products beyond the Proposed Liquor Products List (the List) as specified in paragraph 3.6 of this PIA.

(ii) Ancillary to the purchase of food products

The sale of liquor at the Proposed Store will be ancillary to the purchase of any food products from the Proposed Store. The Proposed Store will display signage reflecting this manner of trade. The Applicant has no intention of making the sale of alcohol the primary focus of its operation.

The liquor products for sale will be stocked and displayed exclusively in the dedicated single refrigerator behind the cashier, reflecting the Applicant’s primary focus to remain a grocery store.

(iii) Delineation of the proposed licensed area

The proposed licensed area within the Proposed Store will be delineated and separated from the remainder of the Proposed Store by way of a physical barrier and signage so that the liquor products would always be delineated from other grocery items. This will enable the proposed licensed area to be completely separate and distinct venues that are able to operate independently of any other venue.

The sale of liquor products within the small licence area is intended to complement the present suite of non-alcoholic Korean novelty and traditional products that are currently being sold by the Proposed Store, so as to cater to the local and wider community’s growing demand for Korean novelty and traditional foods and beverages.

The proposed licensed area has been bounded by solid back and end panels of approximately 1-meter height, to physically segregate the proposed licensed area from the remainder of the Proposed Store as shown in the photo: -

(iv) Dedicated Point of Sale for liquor sales only

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The dedicated Point of Sale only for liquor sales has been installed in the proposed licensed area and can only be used for customers who are purchasing liquor products. This dedicated Point of Sale will not be used for customers who are not purchasing liquor products.

Furthermore, customers will have to go through the cashier first to purchase alcoholic beverages by requesting for specific liquor products.

(v) Dedicated single refrigerator

The liquor products will be separately kept in a dedicated single refrigerator located behind the dedicated Point of Sale for liquor sales only, and sale of liquor products will be processed through the dedicated Point of Sale for liquor sales only so that liquor products cannot be mixed or mingled with grocery and non-alcoholic beverage items within the Proposed Store. The Applicant has already installed the single refrigerator as shown in the photo: -

(vi) Advertising of liquor products

The Applicant does not intend to promote or advertise alcohol. Advertising of liquor products will be limited to product price only at the dedicated Point of Sale, and there is to be no promotion of alcohol on the external façade of the premises, including: -

(A) any signage indicating alcohol is sold at the premises; and

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(B) any pictorial or written promotion of alcohol products.

It will ensure that liquor products are not promoted within the context of the Applicant’s Korean specialty grocery store.

(vii) Security Cameras

As part of security measures to minimise and deter crime and anti-social behaviour, a total of 12 security cameras have been installed on the Proposed Store, covering all areas of the Proposed Store as shown in the Security Camera Floor Plan below. The operation of the security cameras is consistent with the minimum requirements for CCTV surveillance systems as detailed in the Director’s Safety and Security at Licensed Premises policy.

Security Camera locations at the Proposed Store

3.6 Proposed list of the Korean liquor products

For the purposes of meeting the growing demand for Korean liquor products and providing convenience for customers seeking the full complement of Korean food and

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

beverages, the Applicant proposes to only offer the following range of Korean liquor products: -

Product Images Brands Descriptions

Korean Soju products

Chum Churum Original Soju (360ml / 17%) The first original soju that provides the smoothest soju to date. Lotte

Soju Soonhari Flavoured Soju (360ml / 12%)

An assortment of fun and exciting flavours, together with a lower alcohol content than other brands, made it became an instant sensation.

Chamisul Original Soju (360ml / 17%) Brewed with a 7-step refinement process using active bamboo charcoal so only the fresh clean finish Hitejinro

remains. Soju Soonhari Flavoured Soju (360ml / 13%)

Contains a lower alcohol content and delivers a smoother and more enjoyable drink.

C1 Blue Soju (360ml /18%) Daesun Originated from the largest distillery in Busan and Soju received the Grand Prize at the 2015 Korea Liquor

Award. Made with natural bedrock water from Mount

Samgak-san, giving it a clean aftertaste.

Bek Se Ju Herbal Soju (375ml / 12%) Kook A Korean glutinous rice-based fermented alcoholic Soon beverage flavoured with a variety of herbs, ginseng Dang most prominent among them. The name comes from the legend that the herbs in baekseju will result in an

individual living up to 100 years old.

Korean rice wine products

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Makgeolli Rice Wine Original (750ml / 6%) The native and authentic Korean rice wine from the number 1 rice wine brand in Korea. It is made from a

mixture of wheat and rice, which gives it a milky, off- Kook white colour and sweetness. Soon Rice Wine Assorted Flavours (750ml / 4%) Dang Rice Blended with different fruit extracts, abundant with Wine amino acid and dietary fibre with a clean and smooth taste and fragrance.

Makgeolli Rice Wine Original (1000ml / 6%) Uses newly harvested local rice and is brewed through a special method known as the “Raw Rice

Fermentation”. This results in higher amino acid and dietary fibre content paired with a softer, lighter, and BHD Rice smother palate. Wine Corn Flavoured Draft Rice Wine (750ml / 6%) Corn flavoured non-pasteurised raw rice wine with

refreshing naturally occurring carbonation. Taktail Green Plum Rice Wine (375ml / 7%) Rice wine cocktail combined with natural fruit juice.

Korean fruit wine products

Seoljungmae Plum Wine (375ml / 14%) The Korean plum wine is sweet, refreshing, and best served chilled. Bohae Fruit Bokbunjajoo Raspberry Wine (375ml / 14%)

Rice This award-winning Korean fruit wine is made from Wine high-quality, locally grown raspberries. A rich palate matches the wine’s luscious and fragrant flavour profile which gives it an exceptional taste and bouquet. It is made with crystal clear water from a subterranean aquifer.

Mae Hwa Soo Plum (300ml / 14%) Mae Hwa Soo is a refined plum wine made from the green plum extract in a special freeze filtration system. Jinro This results in a clean and smooth liquor with a very Fruit subtle sweetness and light plum flavour that is not too

overbearing.

Korean Beer products

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Hite Pale Lager (330ml / 4.3%) Hite With 80 years of brewing experience, this traditional Pale Lager delivers a smooth and original taste of beer down the throat.

Cass Fresh Lager (330ml / 4.5%) Oriental Cass Fresh is one of South Korea’s best-selling Brewery brands of beer. Cass is a pale-golden lager that Co delivers a refreshing and crisp taste.

Kloud Beer (330ml / 5%) A 100% Malt Premium Beer. A South Korean Beer brewed according to the German Purity Law. The beer Kloud has a denser flavour with a foamy texture hence the name Kloud.

3.7 Proposed trading conditions

The Applicant has carefully prepared the following proposed conditions with the intentions to enable the Applicant as licensee, to fulfill the proposed manner of trade, meet community expectations and manage risks while also adhering to both the primary and secondary objectives of the Act which are discussed in paragraph 6 of this Application. Should the Licensing Authority consider it to be appropriate, the Applicant would be agreeable to an endorsement of the following conditions on the liquor store licence: -

(a) Liquor must be sold ancillary to the purchase of food products from the Proposed Store. Signage reflecting this condition must be displayed.

(b) Only authentic Korean liquor products containing less than 20% alcohol per volume are be stocked and sold under the licence.

(d) There is to be a dedicated Point of Sale in the licensed area for liquor sales only which cannot be used by customers who are not purchasing liquor products.

(e) The display of liquor is to be limited to a single refrigerator located behind the point of sale dedicated for the sale of liquor.

(f) The licensed area within the Proposed Store is to be delineated and separated from the remainder of the Proposed Store by way of a physical barrier and signage.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(g) The light inside the single dedicated refrigerator containing the Korean liquor products will be turned off when the Proposed Store is operating outside of the permitted trading hours for a liquor store.

4 HARM OR ILL-HEALTH – SECTION 38(4)(a)

4.1 At Risk Groups and Sub-communities within the Locality

The Applicant has considered the various risk factors and indicators which include the “at-risk groups or sub-communities”, alcohol-related hospitalisation, crime, and other social health indicators, as contemplated in the PIA policy.10

The table below contains the 2016 Census statistics that are relevant in assessing “at- risk” groups or sub-communities. The table evaluates the suburb of Innaloo as well as the suburbs in the surrounding Locality11 within 2-kilometre of the Proposed Store which also includes the suburbs of Stirling, Osborne Park, Doubleview, Churchlands, and Woodlands, the City of Stirling, and the State of Western Australia. The statistical data pertaining to the aforementioned areas are displayed alongside each other, to give the information some context and insight when compared and contrasted together.

Census Category Innaloo City of Locality State Risk Factor Stirling Average Average Assessment

Children and young people

Persons aged 14 and 11.8% 16.9% 14.4% 19.2% Low risk younger

Persons aged 19 and 15.0% 21.9% 19.3% 25.3% Low risk younger

Aboriginal people and communities

Aboriginal and Torres 1.2% 1.1% 1.0% 3.1% Low risk Strait Islander people

Families

10 PIA Policy. 11 Referred to as the Locality Average, which is calculated using the average of the statistics of in the Locality.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Couple family without 49.6% 40.7% 42.0% 38.5% Low risk children

Couple family with 30.2% 42.8% 40.9% 45.3% Low risk children

One parent family 16.9% 14.2% 14.7% 14.5% Low risk

Other family 3.2% 2.3% 2.4% 1.7% Slightly higher risk

Migrants from non-English speaking countries

Australia as country of 56.3% 55.4% 57.0% 60.3% - birth

Top three responses English English English English - as to ancestry Australian Australian Australian Australian Irish Irish Irish Irish

English only language 73.6% 66.3% 70.7% 75.2% Low risk spoken at home

Households where a 19.6% 28.7% 24.3% 19.4% Slightly non-English language higher risk is spoken

People in low socioeconomic areas

Worked full-time 63.3% 57.0% 58.6% 57.0% Little to no risk

Worked part-time 25.3% 31.3% 30.3% 30.0% Little to no risk

Unemployed 6.3% 7.3% 6.6% 7.8% Little to no risk

Median weekly income $926 $766 $848 $724 Little to no – personal risk

Median weekly income $2,177 $2,001 $2,189 $1,910 Little to no – family risk

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Median weekly income $1,640 $1,563 $1,855 $1,595 Little to no – household risk

Percentage of 21.3% 20.9% 23.7% 19.2% Little to no households with more risk than $3,000 gross weekly income

List of at-risk groups and sub-communities within the Locality

The statistics above have revealed several pertinent factors in relation to the “at-risk” groups or sub-communities” identified in the PIA Policy: -

(a) The Locality has a lower percentage of children aged between 0-14 years and those between 15 and 19 years of age compared to Western Australia’s percentage. Categorically, these two “at-risk” groups are at a low risk of suffering harm.

(b) The proportion of Aboriginal and Torres Strait Islander people in the Locality is much less than Western Australia’s average, making the risk of suffering harm or ill-health for this group a significantly low risk.

(c) The Locality has similar percentages of nuclear and single-parent families with Western Australia’s average, again, it is very unlikely that these categories will have a higher risk of suffering harm.

(d) Higher socio-economic standing with the average incomes and employment being better than the State’s average.

(e) There is no significantly higher percentage of migrant groups from any particular non-English speaking countries than Western Australia’s average in the Locality, putting this group at no higher risk of suffering harm than the others.

As for other “at-risk” groups or sub-communities mentioned in the PIA policy that is not contemplated by the census: -

(a) With regard to the category, “people from regional, rural and remote communities” the Locality is well within the metropolitan area, about 9 km north from the Perth CBD, and therefore no regional, rural, or remote communities fall within the Locality. However, the Applicant acknowledged that people from regional, rural and remote communities may visit or relocate to the Locality from time to time.

(b) “Mining communities or communities with a high number of itinerant workers” is not relevant as there are no mining communities or communities with a high number of itinerant workers found or known to be in the Locality.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(c) Although the Centre has been listed as one of the tourism offerings within the City of Stirling, the Locality itself is not known as an attraction for tourists. The City’s tourism attractions are mainly its natural sites such as Scarborough Beach. It is taken those tourists would likely visit the Locality from time to time, however, the relevant community, in this case, does not experience high tourist numbers.

Overall, the Locality does not have significant populations or groups that would be considered “at-risk”. The data suggests that the community is relatively mature and affluent with a diverse population. The Applicant submits that the data analysed and presented above summarises that the Application can be taken as not having a detrimental effect or produce a higher than the anticipated risk of harm to any “at-risk groups and sub-communities” within the Locality.

4.2 Social Health Indicator

The following sub-paragraphs analyse the various factors that are relevant to the consideration of social health indicators for the Locality: -

(a) SEIFA Score

The City of Stirling has a Socio-Economic Indexes for Areas (SEIFA) score of 1028.12 SEIFA is a measure of the relative level of socio-economic disadvantage and/or advantage based on social and economic Census information. Across Australia’s local government areas, SEIFA scores range from 188 (most disadvantaged) to 1186 (least disadvantaged). A high SEIFA score indicates a relatively lower level of disadvantage in terms of socio-economic factors.13

SUBURBS SEIFA SCORE (2016)

Innaloo 1036

Doubleview 1061

Stirling 1072

Woodlands 1082

Osborne Park 990

Churchlands 1095

Wembley Downs 1112

Locality Average 1068

City of Stirling 1028

12 Australian Bureau of Statistics 2016 Census of Population and Housing 13 Australian Bureau of Statistics 2016 Census of Population and Housing

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

City of Canning 1023 SEIFA Scores of suburbs within the Locality

The Locality has an average SEIFA score of 1068 which is higher than that of the City of Stirling. The City of Stirling ranks highly with an Index of Relative Socio- Economic Disadvantage (ISRD) score of 1028 and is within the 9th decile of all Local Government Areas in Australia, ranking it within the least disadvantaged Local Government Areas.14 As such, it is highly likely that the Locality’s higher SEIFA score would fall within a high percentile amongst the suburbs in Australia.

Furthermore, the City of Stirling’s SEIFA score is slightly higher than that of the City of Canning, a Local Government Area with a similar major shopping precinct and industrial area.

(b) Property Profile

Data from the Real Estate Institute of Western Australia shows that the property markets in Innaloo and the Locality are positive, with properties in the Locality enjoying much higher median house prices than average in the Perth Metropolitan region.15

Chart of property prices in Innaloo

14 Australian Bureau of Statistics, 2033.0.55.001 Socio-Economic Indexes for Australia (SEIFA), 2016 15 https://reiwa.com.au/suburb/innaloo/

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

SUBURBS MEDIAN HOUSE PRICE

Doubleview $716,825

Innaloo $550,000

Stirling $750,000

Woodlands $912,500

Osborne Park $535,000

Churchlands $1,331,000

Wembley Downs $975,000

Perth Metropolitan Area $500,000

Locality Average $824,332 List of median house prices of suburbs within the Locality

The high SEIFA ISRD score and the positive property values of the Locality illustrate an affluent area with little disadvantage and positive socio-economic factors.

Rates of alcohol-related hospitalisations can help indicate the social health of the area. The Department of Health’s Drug and Alcohol Office Surveillance Report 2011 provides key information for these rates. This document is the most recent publicly accessible published information. The extracts below contain statistics of alcohol-related hospitalisations in the City of Stirling (Central) between 2005-2009.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Data for alcohol-related hospitalisations in the City of Stirling

The data suggests that the rate and age-specific rate of alcohol-related hospitalisations was higher amongst males. The Proposed Store’s business model means that alcohol cannot be sold by itself and can only be sold ancillary to the purchase of grocery. This barrier of access to alcohol means that the Proposed Store is very unlikely to contribute to this situation. In addition to this, the Proposed Store promotes healthy consumption and enjoyment of foods and alcohol.

(d) Alcohol Related Crimes

Crime statistics can help provide clarification of an area’s social health. The following offence statistics for Innaloo and the surrounding suburbs within the Locality were obtained from the data published on the WA Police website.16

It must be highlighted that the statistics provided are of Police offence records only and not proven crimes. Additionally, these crimes are grouped into broad categories without specification on which offences were alcohol-related or associated with licensed premises. However, it can be presumed that some of the statistics would most likely involve alcohol-related crimes.

16 https://www.police.wa.gov.au/Crime/CrimeStatistics#/

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Total offences per year for each suburb within the Locality

It is acknowledged that there is a higher rate of crimes in Innaloo in comparison to the rest of the Locality. This can be attributed to the composition of the Locality, where major shopping centres are mostly concentrated in Innaloo. The trend is mirrored in other localities where major shopping precincts are concentrated in a particular suburb. The following graph shows a higher concentration of crime in Booragoon which hosts the Garden City shopping centre than the surrounding suburbs; Applecross and Mount Pleasant.17

Comparison of offences per year for Booragoon, Mount Pleasant and Applecross

17 https://www.police.wa.gov.au/Crime/CrimeStatistics#/

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The crime rates, such as those categorised as “stealing” under the WA Police Crime Statistics, will be higher in Innaloo when compared to the surrounding suburbs in the Locality which are mainly residential areas because of the presence of the Centre.

Reasons why alcohol related crimes data cannot be obtained

Alcohol related crimes data is difficult to be obtained due to the lack of a nationally cohesive recording system for recording how alcohol is related to crimes.18 Further, only a fraction of all crimes committed in Australia is reported to the police. Additionally, the reporting rates for offences most frequently assumed to be alcohol-related are low.19

4.2 Harm Minimisation Strategies

Having regard to the demographics of the Locality, it is unlikely that the presence of the Proposed Store would have an adverse impact on the health and well-being of the Locality. In any case, the Applicant will have comprehensive strategies in place to mitigate the risk of harm.

The Applicant is dedicated to ensuring that its reputation, as a reliable and honest retailer of traditional and novelty Korean food and liquor products in the local and wider communities, continues to be built on operating in a responsible manner to facilitate compliance.

Two of the primary objectives of the Act are to: -

(a) Regulate the sale, supply and consumption of liquor; and

(b) To minimise harm or ill-health caused to people, or any group of people, due to the use of liquor.

The directors of the Applicant are very experienced at managing risks and minimising harm and ill-health at licensed premises. Both directors have successfully completed an approved course in the Management of Licensed Premises (52065 Course in Liquor Licensing, marked as Annexures “7” and “8”) and both are Unrestricted Approved Managers as well (Annexures “6”). If this Application is approved, the directors have mandated that all supervisory staff and those engaging in the sale and supply of liquor must complete an approved course of training in the Responsible Service of Liquor (RSA) as required under the Director’s policy – “Mandatory Training and Training Register”. Additionally, the conduct of daily business of the Proposed Store will be managed and supervised by an approved manager.

18 Australian Institute of Criminology, ‘Towards national measures of alcohol-related crime’ (Research Report 2018) 12 at page 2 19 Ibid at page 1

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Using the benefit of its extensive and long experience in the operations of the Korean specialty grocery stores, the Applicant has developed effective harm minimisation policies to ensure that the Proposed Store will comply with these objectives of the Act. These policies have been designed specifically for a minimart-type grocery store associated with the sale of niche-type liquor products, like the Proposed Store.

There are various policies, practices, procedures, and strategies that the Applicant will or have implemented which will minimise alcohol related harm and ill-health as much as possible. The Applicant has prepared the following strategies to conduct business under the licence in a manner that minimises adverse impact on the Locality and wider community, while also ensuring that consumers can conveniently purchase a unique range of Korean liquor products in a safe and secure environment: -

(a) Mitigating the risk of impulse purchasing of alcohol products

The Applicant acknowledges that there may be harm and ill-health concerns regarding the exposure of alcohol with grocery items, impulse purchasing and associated consumption.

As outlined in paragraphs 3.5 and 3.7, the Applicant will implement effective strategies to minimise harm and ill-health. The strategies include, but are not limited to the following: -

(i) There is to be a dedicated Point of Sale for liquor sales only in the proposed licensed area which will not be used by customers who are not purchasing liquor products.

(ii) The licensed area is limited to a single refrigerator located behind the dedicated Point of Sale for liquor sales. This will minimise the exposure of alcohol products to customers and allow the cashiers to keep an on eye on anyone in the Proposed Store. The alcohol products will only be accessible by the staff, and customers are only able to reach through the staff by asking for a specific liquor item to purchase.

(iii) Liquor products are kept separately in a dedicated single refrigerator which will not be used to stock any non-alcoholic beverage so that so that liquor products cannot be mixed with grocery or non-alcoholic beverage items within the Proposed Store.

(iv) The licence area of 4.07 m2 is to be clearly delineated and separated from the remainder of the Proposed Store by way of a physical barrier and signage so that the liquor products would always be delineated from the grocery items. This measure is consistent with the Director’s Standards of Licensed Premises policy, which states that the licensed premises must be completely separate and distinct venues that are able to operate independently of any other venue.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The above positive harm minimisation measures are intended to reduce the visibility, availability, and ease of access to liquor products within the Proposed Store which will reduce the possibility of any impulse purchasing of alcohol products. It will also ensure that alcohol products are not promoted within the context of a grocery store.

Furthermore, the physical and visual separation of liquor products from grocery items will minimise the risk of harm to the community arising from the co-location of liquor with non-alcoholic products in the grocery store.

(b) Ancillary function of the Proposed Store

It is acknowledged that the sale of alcohol from a grocery store may lead the Applicant’s primary business focus on grocery items to become influenced by its secondary function, and consequently, this may potentially lead to increased consumption and harm.

As outlined in paragraph 3.7 of this Application, the Applicant voluntarily seeks the imposition of the following special conditions on the licence to minimise the potential risk of increased consumption and harm and in maintaining the sale of alcohol as an ancillary function of the Proposed Store: -

(i) Liquor sales are to be restricted to Korean liquor products only with less than 20% alcohol per volume; and

(ii) Liquor products are to be sold ancillary to the purchase of food products from the proposed Store.

The placement of those conditions above will support the Proposed Store to maintain a specific focus on the Korean specialty grocery items with the sale of a specific and unique range of Korean liquor products being a secondary function only. The restriction of liquor for the sale at the proposed store within specialised categories will also contribute to minimising harm.

These conditions are consistent with the objects of the Act in restricting the amount of packaged liquor products available within the Locality, thus reducing any potential harm and ill-health.

Again, the Applicant has no intention to deviate from the intended manner of trade nor to diversify its range of alcohol products beyond the list of Korean alcoholic beverages as specified in paragraph 3.6 of this PIA.

As stated above, the Applicant does not intend to promote or advertise alcohol. Advertising of liquor products is limited to product price only at the dedicated Point of Sale for the sale of liquor, and there is to be no promotion of alcohol on the external façade of the premises, including: -

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(i) any signage indicating alcohol is sold at the premises; and

(ii) any pictorial or written promotion of alcohol products.

This will also have the effect of reducing the possibility of any impulse purchasing and associated consumption of alcohol. In addition to this, the staff will not promote liquor products so as to prevent inducing customers into making an impulse purchase.

(d) House Policies, Management Plan, and Code of Conduct

The Applicant has had regard to the objects of the Act in the development of its House Policy, Management Plan, and Code of Conduct for the Proposed Store. These documents are enclosed and marked as Annexure “5”. The Applicant is committed to minimising harm and ill health to its patrons and the wider community from the sale of liquor by: -

(i) adopting responsible practices in the sale of liquor as per section 2.1 of the Management Plan;

(ii) discouraging and eliminating any disorderly and inappropriate behaviour by persons on or near the premises.

The responsible practices in the sale of liquor set out in the Management Plan include, but are not limited to: -

(iii) requiring the management and team members of the Proposed Store to undertake the induction training, an approved course in responsible service of alcohol (RSA) and to complete regular on-going and a prescribed training register under the Director’s Mandatory Training Policy will be kept at the Proposed Store at all times (Management Plan, section 4);

(iv) preventing the sale of liquor to juveniles (House Policy; Code of Conduct). ID 25 Policy checks are routinely carried out (Management Plan, section 2.1(c) and 4.4). Not only will liquor not be sold or supplied to juveniles, but it also will not be sold or supplied to anyone who is suspected of trying to obtain liquor for a juvenile. The Applicant will have a strict policy of refusing entry to anyone who cannot prove their adult age with satisfactory identification;

(v) refusing to sell liquor to any person who appears to be intoxicated (Management Plan, section 6.4);

(vi) refusing to serve anyone who intends to drink liquor in a public place or supply alcohol to a drunk person (Management Plan, sections 2.1(f) and 6.4);

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(vii) ensuring patrons and team members have ready access to information and training materials in relation to the responsible service of liquor;

(viii) reporting street drinking in the vicinity of the Proposed Store to Police (Management Plan, section 2.1(d));

(ix) complying with all laws and regulations in relation to the sale and consumption of liquor products (House Policy); and

(x) an approved manger will be on site at all times, and it is the duty of that approved manager to reinforce its staff’s alcohol management knowledge through constant reminders and checklists.

(e) Staff Development and training

All supervisors and staff engaging in the sale and supply of liquor will be required to undergo an accredited course in the Responsible Service of Alcohol (RSA) and be trained on matters of harm minimisation and other matters of compliance.

The Applicant is committed to making every effort to conduct business under the licence in a manner that minimises the potential for harm or ill-health to occur as a result of the sale of liquor at the Proposed Store. As referred to previously in this PIA, there are various features of the proposal which will contribute towards minimising harm. Should the licensing authority consider appropriate the Applicant would be agreeable to the above harm minimisation strategies being endorsed on the Applicant’s proposed liquor store licence.

4.3 Security and Safety

In addition to its harm minimisation policies and strategies as outlined above, the Proposed Liquor will have security measures as specified in paragraph 7.8. These measures are specifically designed to minimise any prospect of the Proposed Store contributing to alcohol-related harm in the community.

5 PUBLIC CONSULTATION & CONSUMER EVIDENCE

The Applicant has consulted extensively with the local and wider community, with the aim of assessing consumer requirements and public interest assessment for the grant of this Application. The compelling evidence from the public in support of this Application is comprised of the following: -

(a) Survey and questionnaires;

(b) Petition;

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(d) Letters of Confirmation by the two exclusive Korean liquor suppliers.

5.1 Survey and Questionnaires

The Applicant conducted a survey and questionnaire exercise during the period between February 2021 and May 2021, capturing 361 participants’ responses to the specific questionnaires. The surveys are enclosed and marked as Annexures “14.1” to “14.7”.

The median age of the respondents is 36 years old. One respondent did not disclose her age. The breakdown of the age groups is shown below: -

Age Group No. of % respondents (rounded) Age Group of Respondents 2% 18 – 29 years old 128 36% 1%

30 – 39 years old 100 28% 9%

40 – 49 years old 87 24% 36% 24% 50 – 59 years old 34 9%

60 – 69 years old 8 2% 28% 70 – 79 years old 3 1%

Did not disclose 1 0% 18 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 Total responses 361 100%

Age groups of respondents to surveys and questionnaires

When conducting the survey and questionnaires, all respondents were given and asked to refer to the Locality map and the list of the Korean liquor products as shown in Annexure 14.1.

The result of the survey and questionnaires are summarised below: -

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(a) Question 1 – How often do you shop at HanGaWee Market Innaloo?

Occasionally

22% Monthly 18% 28% Fortnightly

Weekly 30% Daily 2% 0% Did not answer

0% Never

All of the 361 respondents have shopped at the Proposed Store, with 28% shopping weekly and 2% on a daily basis. The majority of the respondents (30%) visited the Proposed Store occasionally with 22% shopping fortnightly and 18% on a monthly basis.

(b) Question 2 – Do you purchase any Korean alcoholic beverages? If yes, how often do you purchase?

Occasionally

Monthly 22% 16% Fortnightly 19% Weekly 41% Daily

1% Did not answer

1% Never 0% All but 1 of the 361 respondents have purchased some form of Korean alcoholic beverages before, with the majority of them (41%) purchasing Korean liquor occasionally. Two (1%) of the respondents bought Korean liquor daily, 70 (19%) made their purchases on a weekly basis and 78 (22%) made their purchases on a monthly basis.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

80%

70% 60%

50% 40%

30%

% of % Respondents of 20%

10%

0% 1.1 1.2 1.3 1.4 2.1 2.2 3.1 3.2 4.1 4.2 4.3 Beverage ID

More than 70% of the respondents usually purchased the Makgeolli rice wines. Makgeolli rice wines (assorted flavours) and the Seoljungmae plum wines were identified as the most popular Korean alcoholic beverages on the List by the respondents.

(d) Question 4 – Are you satisfied with the current availability and range of Korean liquor products supplied by existing liquor stores within the locality? (within a 2 km radius of the Centre.)

Did not answer

90%

Yes, there are plenty of liquor stores that provide a diverse range of Korean liquor products

No, there should be more 5% liquor stores that supply a 5% broad and unique range of Korean liquor products.

The majority (90%) of the respondents are not satisfied with the current availability and range of Korean liquor products supplied by existing liquor stores within the Locality.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(e) Question 5 – What Korean liquor products do you find difficult to purchase and not readily available within the locality?

80% 70% 60% 50% 40% 30% 20% % of Respondents of % 10% 0% 1.1 1.2 1.3 1.4 2.1 2.2 3.1 3.2 4.1 4.2 4.3 Beverage ID

All of the respondents reported difficulty in buying the Korean liquor products from the List given within the Locality. The majority (73%) of them citing difficulty in procuring the Makgeolli rice wines and the Seoljungmae plum wines (beverage ID 2.1, 2.2, and 3.1).

Makgeolli Rice Wines (Beverage ID 2.1 & 2.2) Seoljungmae Plum Wines (Beverage ID 3.1)

(f) Question 6 – Where do you usually purchase Korean alcoholic beverages?

5% Morley 10% 9% Perth CBD 27% Willetton

47% Carousel

Others: 2% Did not answer

Almost half of the respondents (47%) purchased their Korean alcoholic beverages from the Perth CBD, 27% getting them from Westfield Carousel, and the remainder acquiring them from Willetton and Morley.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(g) Question 7 – HanGaWee Market Innaloo intends to sell a broad range of unique Korean alcoholic beverages only. Would you support the sale of Korean alcoholic beverages on the premises of HanGaWee Market Innaloo?

99% Yes

Did not answer

0% 1%

Almost all of the respondents (99%) supported the sale of Korean alcoholic beverages at the Proposed Store.

(h) Question 8 – What is your reason for the previous answer?

Cater to the specific needs of the strong Asian community in the local and broader community. Opportunity to purchase liquor that is culturally diverse to what you are usually used to. No longer need to travel unnecessary distances to purchase Korean liquor products. Not satisfied with the Korean liquor products currently available in existing liquor stores within the locality. My favourite Korean liquor product(s) not currently available within the locality.

Shopping at a convenient location

One stop shopping experience

0% 10% 20% 30% 40% 50% 60% 70% 80% % of Respondents The main reasons why the respondents supported the sale of Korean alcoholic beverages at the Proposed Store are: -

(i) their favourite Korean liquor products are not available within the Locality;

(ii) convenient location for shopping; and

(iii) one-stop shopping experience.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

5.2 Petition

A petition in support of the sale of Korean alcoholic beverages at the Proposed Store was conducted from February to May 2021. The petition is enclosed and marked as Annexure “15”.

The petitioners, mostly residents of the Locality, petitioned the Director of Liquor Licensing for the grant of the liquor store licence to the Applicant so that they can have a wide range of Korean alcoholic beverages that are readily available in their surrounding localities. The rise in popularity of K-pop, Korean dramas, and movies around the globe has given rise to an increase in awareness of Korean culture in Western Australia as well. This is evident as there has been a surge in demand for Korean food products and beverages in the Perth area.

These petitioners believe that that as Korean culture has been highlighted in mainstream and social media, cultural diversity in Australia has strengthened and expanded. Many people wish to embrace the Korean culture and explore it further by trying a wide range of Korean food products and beverages, particularly Korean alcoholic beverages that are featured prominently in the Korean culture.

Many of these petitioners feel that the existing liquor stores in the Locality provide either none or a very limited range of Korean liquor products. They want to be able to purchase a broad and unique range of Korean alcoholic beverages within their localities. By the end of the petition period, a total of 751 signatures were obtained from people of all walks of life, both from within the Locality as well as visitors to the Locality.

5.3 Form LLD/18 Submission in Support of this Application

The above questionnaires were distributed together with Form LLD/18 (Submissions in Support or Opposition of an Application) as part of the requirement by the Department of Local Government, Sport and Cultural Industries (s 72A of the Liquor Control Act 1988) with regard to a liquor store licence application. A total of 109 LLD/18 forms were collected by the Applicant and all 109 respondents supported this Application. These Submissions are enclosed, marked as Annexures “16.1” to “16.2” and numbered from 1 to 109. Some comments extracted from the respondents of these forms are as follows: -

(a) CK (No. 15)

… I am a customer at HanGaWee Market Innaloo and have no relations with them. I have been requested by them to complete this form. There is, indeed, no option to purchase traditional Korean alcoholic beverages such as Makgeolli rice wine, Korean plum wine, and Korean beer such as Cass in Innaloo and the surrounding suburbs.

I am supporting this application as I find this lack of availability frustrating and not aligned to the Australian multicultural philosophy. Let HanGaWee Market Innaloo have the right to sell their traditional alcoholic beverages.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(b) PM (No. 20)

…. I very much enjoy Asian culture and often enjoy Asian food and drinks with friends. Unfortunately, it is very difficult to find Asian alcohol in Perth that is not sold from a restaurant. In the past, I had to drive into the city or even further south just to buy things like soju and other Korean alcohol. By having it sold at Innaloo it will make it a lot more accessible not only for me but for other people like myself that live north of the river.

…. all Korean rice wines like Kook Soon Dang and BHD Rice wine are my favourite.

It is difficult to find these brands and products in Australia. So, I really want to be able to buy rice wine easily. It is especially hard to find near Westfield Innaloo where I buy groceries after work. If HanGaWee Market Innaloo were able to sell these products, it would make it much easier for me. I support the application for HanGaWee Market Innaloo because: -

 It will make it easier for me to buy the things I want without having to travel far, and

 I would be able to buy all the types of Korean Rice Wine that I want to buy.

(d) KJ (No. 24)

….. for customer convenience, I would very much like to buy Korean liquor like the traditional rice wine or soju at this store along with my groceries. No other store I know of sells the traditional Korean liquor that I want.

I support this application because: -

 There is no other store near me that sells the traditional Korean liquor that I want, and

 The store is close to my house so I would not have to travel far to get the type of liquor I want.

(e) MS (No. 8)

…. I live in Innaloo. I do not know the applicant personally, but I often shop there. I want to try lots of Korean snacks and I love Korean food and liquor such as Soju, Korean fruit wine, and rice wine. But the local or nearby liquor shops don’t sell any making this shop the perfect place to buy dailies and Korean liquor.

I support their application because: -

 I will be able to enjoy Korean liquor without having to travel far, and

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

 I will be able to buy the Korean liquor products that I want such as Korean rice wine and plum wine

(f) JK (No. 5)

….. I lived in Churchlands. I am not related to the Applicant. I always shopped at Westfield Innaloo as HanGaWee Market is the only Asian grocer there. I find there are no Korean alcoholic beverages being sold in the vicinity where I normally would do my shopping. The liquor I wanted is the traditional Korean alcohol such as Makgeolli rice wine and Korean plum wine.

I support this application as I can buy my favourite Korean alcohol at HanGaWee Market Innaloo. I would be really pleased if this becomes a reality as Australia is a multicultural country as I should be able to get my favourite alcoholic beverages.

(g) MC (No. 7)

I live in North Perth. I would like to state that I have no relationship with the applicant, and I always do my shopping in Westfield Innaloo because HanGaWee Market Innaloo is the only Korean specialty shop there. If HanGaWee Market sells Makgeolli rice wine, I would love to buy it since it is my favourite Korean liquor. But given there are no stores or liquor shops around my area that sell the type of liquor I wanted; HanGaWee Market Innaloo should sell them. I strongly support their application because I can buy my favourite Korean alcoholic beverages in my locality. I don’t have to travel all the way south of the river to make my purchases.

Whilst most respondents commented about the lack of availability of Korean alcoholic beverages in the locality, some submissions supported the application because of the convenience it can offers. Some of the comments are as follows: -

(h) TG (No. 4)

….. I live in Leederville. I go to this store, HanGaWee Market Innaloo a lot to buy Asian groceries and it would be really convenient to be able to get Asian liquor specialties like Korean rice wine and plum wine. I do not know the applicant on a personal basis.

I support HanGaWee Market Innaloo’s application because: -

 I would be able to buy Korean rice wine,

 It would be more convenient for me to get my groceries and Korean liquor in the same spot, and

 I would not have to travel elsewhere to buy Korean rice wine and plum wine.

(i) MM (No. 3)

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

I live in Perth. I do not have any personal relations with the applicant. I visit Westfield Innaloo every week because it is a very convenient place to shop. However, there is no place to buy Korean alcoholic beverages like rice wine and plum wine in the shopping centre. I feel like this is an inconvenience for me when I visit Westfield Innaloo. If they opened a liquor store sold the Korean alcoholic beverages I wanted, I would not have to travel far to get them.

I entirely support HanGaWee Market Innaloo’s application for a liquor licence because: -

 It would be convenient for me to be able to buy Korean liquor that I want during my weekly visits, and

 I would not have to travel far to get these Korean liquors.

(j) AS (No. 2)

… I live in East Perth. I have no personal relations with the applicant. I support this application because I won’t have to go all the way to Cannington to get specific Korean alcoholic beverages like plum wine. At the same time, it would be an amazing one-stop-shop.

(k) LW (No. 1)

… I live in Scarborough. I do not know the applicant personally. I like Korean wine especially plum wine. But I can’t find it anywhere near where I live and shop often. I can’t wait to buy it from this store as it would be very convenient.

I support this application for the following reasons: -

 I wouldn’t have to travel far to get the Korean plum wine, and

 It would be more convenient for me to be able to buy Korean wines where I shop often.

(l) EP (No. 6)

…. I live in Subiaco near Innaloo Shopping centre, and I usually do my shopping at this shopping centre.

I support this application because: -

 As we love Korean rice wine, we would be able to get it at the shopping centre when we get our other groceries, and

 We wouldn’t have to travel far in order to get the Korean rice wine we want.

On the whole, the survey/questionnaire respondents have revealed and substantiated that there is a strong local requirement for Korean alcoholic beverages, especially

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Korean rice and plum wines. The responses further revealed that the requirement for Korean alcoholic beverages is not currently being fulfilled or met by existing packaged liquor premises in the Locality and there is a strong level of support for the Proposed Store to stock and sell Korean alcoholic beverages.

5.4 Consultation with Korean Liquor Suppliers

The Applicant has consulted with the two exclusive Korean liquor suppliers in Perth to gauge the extent of the distributorships of Korean liquor in the Locality. All of the two suppliers consulted confirmed that they are not distributing any Korean liquor products to any liquor merchant in the Locality. Enclosed with this submission are their correspondences which are marked as Annexures “17” and “18”.

6 OBJECTS OF THE ACT & PUBLIC INTEREST BENEFITS

6.1 Primary Objects of the Liquor Control Act

In assessing whether this Application is in the public interest, the Licensing Authority is bound to take into account the primary objects of the Act, and to the extent that they are not inconsistent with those primary objects, the secondary objects. The primary objects of the Act set out in section 5 are: -

(a) to regulate the sale, supply, and consumption of liquor;

(b) to minimise harm or ill-health caused to people, or any group of people, due to the use of liquor; and

(c) to cater for the requirements of consumers for liquor and related services, with regard to the proper development of the liquor industry, the tourism industry, and other hospitality industries in the State.

The Applicant addresses these primary objectives throughout this application in the manner set out below: -

(a) To regulate the sale, supply, and consumption of liquor:

The Applicant will enact specific policies, in regard to both operational and harm minimisation aspects, to ensure that the grant of the Application complies with this object.

Any licence issued on grant of this Application will be subject to conditions imposed by the Licensing Authority which will ensure that liquor is sold a responsible and regulated manner.

(b) To minimise harm or ill-health caused to people, or any group of people, due to the use of liquor:

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The available data indicates relatively low levels of alcohol-related harm in the Locality. In summary, the conclusion is that the Store is unlikely to contribute to alcohol-related harm or ill-health or additionally impact sensitive premises or at- risk groups within the Locality.

The Applicant will implement comprehensive and tested harm minimisation policies in place at the Proposed Store to minimise any potential negative impact that the Proposed Store may have on the local community.

(c) To cater for the requirements of consumers for liquor and related services, with regard to the proper development of the liquor industry, the tourism industry and other hospitality industries in the State:

The Proposed Store is located within a designated Secondary Activity Centre. The evidence from the surveys and community feedback shows that there is an expectation that a specialty Korean grocery store within such a large Centre will have in stock specialty Korean liquor products. The same evidence shows that consumers and stakeholders in the Locality strongly support the grant of the Application.

In conclusion, the Applicant submits that the additional diversity in the range of Korean products available for sale will have a positive impact on the proper development of the liquor and tourism industries.

6.2 Secondary Objects of the Liquor Control Act

Along with the primary objects, the Licensing Authority must also have regard to the secondary objects of the Act, which are: -

(a) to facilitate the use and development of licensed facilities, including their use and development for the performance of live original music, reflecting the diversity of the requirements of consumers in the State;

(b) to provide adequate controls over the sale, disposal, and consumption of liquor;

(d) 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 addresses these secondary objectives throughout this application in the following manner: -

(a) To facilitate the use and development of licensed facilities, including their use and development for the performance of live original music, reflecting the diversity of the requirements of consumers in the State:

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The Applicant acknowledges that consumers have diverse requirements for specialty Korean liquor products. Some consumers prefer to browse extensively and purchase some or all of their requirements at large packaged liquor outlets. However, other consumers have a requirement to purchase some or all of their liquor in small volumes in conjunction with other goods and services, such as groceries. Approving this Application will facilitate the development of licensed facilities that meet the requirement of the latter category of consumers.

(b) To provide adequate controls over the sale, disposal, and consumption of liquor:

The Applicant is an experienced licensee and will have extensive and tested harm minimisation policies in place at the Proposed Store to minimise any potential impact. Additionally, the Store will have site-specific security measures designed to ensure that the Proposed Store sells specialty Korean liquor products in a responsible manner. These policies, together with any conditions the Licensing Authority sees fit to place on the licence, will provide enhanced control over the sale of specialty Korean liquor products at the Proposed Store.

Not applicable.

(d) 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:

All liquor product advertising in and associated with the Proposed Store will comply with the advertising policies outlined within this document. The Proposed Store will not encourage irresponsible drinking. Further, the location of the Store within the Centre means that it will have no visibility to persons passing by the Centre, and there will be no promotion of alcoholic products on the external façade of the Proposed Store.

6.3 Public Interest Benefits and Consideration

(a) To meet existing demand

Given the established trading history of HanGaWee Market Innaloo, its proposed operation under the proposed liquor store licence is not a novelty and is justified by the existing demand for a good range of Korean alcoholic beverages in the Locality, consistent with the culture and tradition of the Korean culture.

(b) One-stop shopping and convenience

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The Proposed Store is not a liquor store per se, but a specialty Korean grocery store catering to the requirement of the community for Korean food products and beverages in line with the practices of the Korean culture. Additionally, the sale of Korean alcoholic beverages would only be complementary to the purchases of other Korean food products.

In modern life, one-stop shopping is an important and widely desired convenience for many people, including the customers of the Proposed Store who resides within the Locality. This Application is entirely consistent with meeting that desire.

With its role as a unique Korean specialty shop in the Centre, the Applicant submits that, with the grant of the proposed liquor store licence, it will be able to achieve the objects of the Act in accordance with the public interest. HanGaWee Market Innaloo will strive to meet the requirements and expectations of its customer base that are curious or fond of Korean food products and beverages, irrespective of whether they are tourists, residents, or visitors to the Locality.

Customers will be able to feel the familiar atmosphere found only in a typical Korean grocery shop in South Korea with a similar layout, ambience, products, and services. As such, HanGaWee Market Innaloo will draw noticeable tourism, social, recreational, cultural, and economic benefits to the community.

7 IMPACT ON AMENITY – SECTION 38(4)(b)

7.1 Nature and Character of the Locality

The Locality has been defined and outlined in paragraph 2 above. Generally, the City of Stirling is a well-established commercial and residential precinct with tremendous potential for growth. It has a wide array of facilities such as quality schools, well- equipped modern hospitals, efficient transport networks, and one of the largest shopping complexes in the state. As mentioned earlier the City of Stirling is multicultural in nature and has a population of 210,208 as recorded in 2016. This number is estimated to grow to 278,230 (32%) by 2026, an anticipated increase of over 60,000 people.20 The population of the SA2 (Statistical Area 2) region of Innaloo-Doubleview in 2016 was 16,559 and this number is forecasted to increase to 20,485 in 2026, at a rate of about 24% (see table below). However, for the SA2 region of Stirling-Osborne Park, the percentage increase is forecasted to be about 4% and for the region of Wembley Downs- Churchlands-Woodlands, the rate of increase is forecasted to be about 12%. For the

20https://www.stirling.wa.gov.au/your-city/documents-and-publications/planning-and-building/urban-planning/local-planning- strategy-part-two

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

three SA2 regions, the forecasted increase in population in 2026 is 6,146. The Locality, on the whole, is looking at an average increase rate of approximately 13.3%.

SA2 Region 2016 (Actual) 21 2026 Increase (%) (Forecasted) 22

Innaloo-Doubleview 16,559 20,485 3,926 (24%)

Stirling-Osborne Park 13,748 14,275 527 (4%)

Wembley Downs -Churchlands- 13,952 15,645 1,693 (12%) Woodlands

City of Stirling (local government 210,208 278,230 68,022 (32%) area) Projected Population by Statistical Area 2 (SA2)

Statistics in the table have been obtained from the 2016 Census.23

Census Category Locality Average24

Population 37,983 (male 49%, female 51%)

Median Age 37

Married 48%

Australia as country of birth 57%

Worked full-time 59%

Worked part-time 30%

Unemployed 7%

Top occupation Professionals

Top industry of employment Hospitals (except psychiatric hospitals)

21https://quickstats.censusdata.abs.gov.au/census_services/getproduct/census/2016/quickstat/505021088?opendocument/ 22https://www.dplh.wa.gov.au/information-and-services/land-supply-and-demography/western-australia-tomorrow-population- forecasts (Population Report No.11). 23 https://quickstats.censusdata.abs.gov.au/census_services/getproduct/census/2016/quickstat/505021088 24 Locality average covers the suburbs of Innaloo, Stirling, Osborne Park, Doubleview, Woodlands and Churchlands based on 2016 Census.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Median weekly income - personal $849

Median weekly income - household $1,855

Most common dwelling structure Separate house

Median monthly mortgage $2,245

Median weekly rent $390

Average motor vehicles per dwelling 1.8 2016 Census data

Based on the above statistics, the average person who lives in the Locality would most likely be a female aged 37, not married, and works in the health care industry (hospital) with a median household income of $1,855 per week. She is most likely to live in her own separate house that she shares with another person and has her own car.

7.2 How the Proposed Store will fit into the Amenity

The Proposed Store is located inside the Centre which has a gross lettable area of 47,374 m2 and 2,395 car parking spaces. There are 161 retailers in there with 7.6 million annual customer visits and a total annual retail sale of $331 million. The Centre is currently undertaking a major redevelopment of the Centre which would eventually become Westfield Stirling after the redevelopment exercise.

The net lettable area of Westfield Stirling would be 109,000 m2 which would make it one of the largest shopping centres in Western Australia. The new development would

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

include 285 specialty retail stores and Perth’s largest rooftop dining and leisure precinct, serviced by over 4,000 car parking bays. The cost of this redevelopment is estimated to be about $450 million.25

Keeping in line with the transformation that is currently ongoing at the Centre, the Proposed Store will most likely have a positive impact on the amenity of the Locality. It is well known to the community as a trustworthy and responsible Korean specialty store and is a part of the safe and comfortable environment of the Centre. This adds to the convenience and comfort of the shoppers as well as for tourists coming into the locality. In terms of physical appearance, the theme of the Premises is consistent with almost all the grocery stores and retail outlets in the Centre. Operationally, the Premises is designed to provide a clean, warm and casual setting for its customers to do their purchases.

7.3 Traffic and Access

The Centre is located on Ellen Stirling Boulevard, between Oswald Street and Scarborough Beach Road. Currently, there are 4 entrances available to the public when entering the Shopping Centre:

(a) Coles: Entry via Ellen Stirling Boulevard

(b) Woolworths: Entry via Oswald Street

(d) Target: Entry via Oswald Street

25 https://www.scentregroup.com/our-portfolio/centres/westfield-stirling/aipp

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The Proposed Store is one of the 161 retail outlets in the Centre and is highly unlikely to have any adverse impact on local traffic.

7.4 Public Transport

The Stirling Train Station is located 1.3 kilometres northeast of the Centre. From the Stirling Train Station, the high-frequency bus service, Circle Route operates to Westfield Innaloo. Route 999 operates from Stirling Station (Stand 4) to the Centre and Route 998 operates back. Route 412 also operates between Stirling Station and the Centre. The bus trip between Stirling Station and the Centre takes 3 minutes. There is a taxi rank and rideshare area conveniently located off Ellen Stirling Boulevard as well as another taxi rank located outside of Queen of Everything retail outlet.

7.5 Parking

The Centre currently has 2,395 car parking spaces. This number is expected to exceed 4,000 after the major development is completed. Additionally, there are 1042 parking bays available at the Stirling train station as well as a taxi rank.

7.6 Streetscape and Atmosphere

The Centre currently is undergoing a major development exercise to transform the entire shopping precinct. After the redevelopment exercise, the Centre would be renamed as ‘Westfield Stirling’. Westfield Stirling will exhibit a more new, modern, and vibrant version of the old Westfield Innaloo. This will no doubt improve the streetscape and atmosphere of the area as depicted by the artist impressions below.

The Proposed Store will add to the multicultural nature of the Locality and provide the community with a wider selection of food products and beverages. It will also provide the community with an opportunity to know, learn and embrace another culture, Korean culture. All these improvements and opportunities will enliven the streetscape and atmosphere of the area.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

7.7 Noise, Anti-social behaviour and Security

The Proposed Store is located inside the Centre. Its range of Korean alcohol beverages is predominantly used in conjunction with recreational, cultural and cooking activities.

The Centre will not permit on-site drinking, operates during normal business trading hours and operate pursuant to numerous harm-minimisation strategies. As such, its potential impact on the level of noise and anti-social activities in the Locality would be nil or minimal. In short, the Proposed Store will not create noise or anti-social behaviour that will detrimentally affect the Locality’s amenity.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

7.8 Security and Safety

The Proposed Store has carefully had regard to the location security and safety of the Proposed Store, both within the Centre and its location within the Locality, in planning security measures for the Store. The concepts of Crime Prevention through Environmental Design (CPTED) have been implemented in designing the Proposed Store to reduce, prevent or deter the occurrence of crime and improve the quality of life for consumers.

The following security measures are intended to mitigate the risk of any increased anti- social behaviour and harm: -

(a) Liquor products are kept in a single dedicated refrigerator located behind the dedicated Point of Sale for liquor sale. Liquor products will only be accessible by the staff and customers will be required to consult the staff if they wish to purchase any liquor product. This will mitigate the risk of the Proposed Store appealing to persons at-risk of alcohol-related harm and eliminate alcohol theft.

(b) There is no secondary entrance to the Proposed Store from outside the Centre.

(d) The Proposed Store has an open design concept, utilising glass partitions that provide high visibility and exposures to the high volume of traffic within the Centre, resulting in passive surveillance of the Proposed Store.

(e) A total of 12 CCTV cameras have been installed on the Proposed Store, covering all areas of the Proposed Store as shown in the Security Camera Floor Plan. All staff will be trained and regularly required to refresh their skills on isolating portions of CCTV recordings should an incident ever occur. This will ensure that any identified critical section of a CCTV recording will not be overwritten. The operation of the security cameras is consistent with the minimum requirements for CCTV surveillance systems as detailed in the Director’s Safety and Security at Licensed Premises policy.

(f) All staff will be adequately trained in conflict resolution and de-escalation techniques to deal with any conflicts that may arise as to not cause a disturbance.

(g) Detailed records of any incidents or complaints concerning the Proposed Store will be made and maintained as per its Management Plan.

These security measures are specifically designed to minimise any prospect of the Proposed Store contributing to alcohol-related harm in the community. Additionally, the Proposed Store will have the benefit from the Centre security, including on-site security personnel and CCTV.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

7.9 Outlet density

The Applicant has carefully considered and inspected all of the existing packaged liquor premises in the Locality as presented in the table below, based on records from the Licensing Authority. However, several existing packaged liquor premises do not sell nor supply packaged liquor.

Road distance Map License No. License Premise Name Premise Address from No. Type Proposed Store (km)

Liquor Store

6030002873 LIQ-Liquor Liquorland Oswald Street, Innaloo Within the Store Innaloo – WA 6018 Centre 1 Oswald Street

6030004333 LIQ-Liquor BWS – Beer Westfield Innaloo Within the Store Wine Spirits Shopping Centre, Ellen Centre 2 Innaloo Stirling Boulevard Innaloo WA 6018

3 6030120742 LIQ-Liquor Stirling Cellars Units 5 & 6, 51 Cedric 2.3km Store (Bottlemart) Street Stirling WA 6021

6030131095 LIQ-Liquor WA Cellar Door 257 Scarborough Beach 2.3km Store Doubleview Road Doubleview WA 4 6018

6032109579 LIQ-Liquor Innaloo Shop 7 Morris Place 17 Store Specialty Liquor Shopping Centre 27 5 2.6km Morris Place Innaloo WA (Cellarbrations) 6018

6032120354 LIQ-Liquor ALDI Innaloo26 Shop M2001 Westfield No store 18 Store Stirling, 46 Oswald Street, built 6 cnr Ellen Stirling currently Boulevard Innaloo WA 6018

7 6032127223 LIQ-Liquor Dan Murphy's 401 Scarborough Beach 800m 19 Store Innaloo Road Innaloo WA 6018

Tavern

26 ALDI Innaloo does not currently operate at Innaloo.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

6020024695 LIQ-Tavern Op’s Tavern 444 Scarborough Beach 1.5km Road Osborne Park WA 8 6017

6020129578 LIQ-Tavern The Saint 2 Morris Road Innaloo 2.2km George Hotel WA 6018 9 (BWS The Saint Drive Thru)

6382087553 LIQ-Tavern Tassels Place Lot 222 1 Sunray Drive 800m 16 Restricted Bar & Bistro Innaloo WA 6018 10

6382141062 LIQ- The Cooksley*27 2 Morris Place Innaloo 2.4km 20 Tavern WA 6018 11 Restricted

Special Facility

6090097055 LIQ-Special Event Cinemas 57 Liege Street 1.2km Facility Woodlands WA 6018 12 Licence

6090150368 LIQ-Special Crafted Events 288 Hale Road 2.4km Facility WA* Woodlands WA 6018 13 Licence

6092104376 LIQ-Special Temptations Unit 12/50 Howe Street 1.9km 17 Facility Catering Osborne Park WA 6017 14 Licence

15 6092136806 LIQ-Special Portside Warehouse E 73 Walters 19 Facility Boulders Drive Osborne Park WA 2.6km Licence Osborne Park 6017

6092141206 LIQ-Special The Football Unit 6/97 Hector Street 20 Facility Centre West Osborne Park WA 16 2.7km Licence 6017

6092158169 LIQ-Special Rawsters Unit 407, 396 20 Facility Scarborough Beach Road 17 2.2km Licence Osbourne Park WA 6017

With reference to the information and evidence provided in the Section 36B Submission and the Report, the following are the key differences between existing packaged liquor premises and the Proposed Store and the Public benefits: -

27 The Cooksley’s is currently under construction/renovation.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

(d) The exclusive product range.

(e) The range and focus on a specific and unique range of Korean liquor products.

(f) The Proposed Store will not be a large volume, price-based business.

(g) The Proposed Store operates first and foremost as a Korean specialty grocery store, specialising in Korean grocery and other Korean novelty products.

(h) The sale of Korean alcoholic beverages would only be complementary to the purchases of other Korean food products.

(i) Though ancillary to its main grocery store purpose, the Proposed Store will have an exclusive range of Korean liquor products.

(j) Consumers will have a wide range of choices in Korean liquor products that is not readily available in the Locality.

(k) Consumers will be able to enjoy Korean culture and to explore the diversity of Korean food and alcoholic beverages.

(l) As referred to in the 36B Submission, there is compelling evidence that the consumer requirements, for what is a very specific and unique product range proposed by the Applicant, are not currently being met by existing packaged liquor premises in the Locality.

(m) The contemporary expectation of the availability of one-stop shopping (Korean grocery items with Korean liquor) at shopping centres has long been regarded as a notorious fact. This co-location reduces unnecessary consumer trips and hence energy consumption, traffic congestion, and vehicle emissions and saves time for consumers.

8 OFFENCE, ANNOYANCE, DISTURBANCE, OR INCONVENIENCE – SECTION 38(4)(c)

8.1 No high-risk factor

The Applicant has considered the impact that the operation of the Proposed Store may cause on people who live and work in the vicinity of the licensed premises. This PIA has addressed all potential risk factors associated with the Proposed Store and has also considered a number of measures to counteract those potential risks.

The information in the PIA does not reveal any high-risk factors in this regard. The consumer survey questionnaires do not reveal any issue associated with the Proposed Store.

8.2 Nearby Facilities

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

The Applicant endeavoured to identify all nearby facilities and sensitive premises located within the Locality. These facilities and premises (as set out in the tables below) are situated within the 2-km radius of Westfield Innaloo Shopping Centre and will be notified in accordance with the Director’s advertising directions. In the event, that any of these facilities or premises have been omitted unintentionally, the Applicant would be appreciative if the Department can furnish details of them so that they could be included in the notification exercise.

Schools and Educational Institutions

No. Name Location Distance from Proposed Store 1 St Dominic’s Primary 95 Beatrice St, Innaloo WA 6108 1.2 km School 2 Woodlands Primary 7 Bentwood Ave, Woodlands 6018 1.4 km School 3 Holy Rosary School 35 Williamstown, Doubleview WA 1.4 km 6018 4 Doubleview Primary 273 Flamborough St, Doubleview 2.0 km School WA 6018 5 Yuluma Primary 21 Ambrose St, Innaloo WA 6108 1.4 km School 6 International School of 193 St Brigids Terrace, Doubleview 2.1 km Western Australia WA 6018 7 Hale School 160 Hale Rd, Wembley Downs WA 2.2 km 6019 8 Churchlands Senior 21 Lucca St, Churchlands WA 2.1 km High School 6018

There are several schools located within the locality of the Proposed Store. However, it is submitted that none of the above-listed schools are situated so close to the Centre as to require any special consideration. The International School of Western Australia is included despite being outside of the locality as it is located within the same reserve as Doubleview Primary School.

Hospital(s)

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

No. Name Location Distance from Proposed Store 1 Osbourne Park Hospital Osborne Pl, Stirling WA 6021 1.77 km

Aged Care Facilities

No. Name Location Distance from Proposed Store 1 Aegis Shawford 8 Twyford Pl, Innaloo WA 6018 0.4 km 2 Aged and Community 16/25 Walters Dr, Osborne Park 1.15 km Services Australia WA 6017 3 Silver Chain 6 Sundercombe St, Osborne Park 1.2 km WA 6017 4 Regis Woodlands 10 Sabina St, Woodlands WA 1.49 km 6018 5 Bethane Geneff 39 Hertha Rd, Innaloo WA 6018 1.16 km 6 Brightwater Birralee 155 Odin Rd, Innaloo WA 6018 1.58 km Innaloo

Churches/Places of Worship

No. Name Location Distance from Proposed Store 1 St Dominic’s Church 19 Phillips Grove, Innaloo WA 1.04 km 6018 2 Living Faith Community 2 Grant St, Innaloo WA 6018 0.97 km Church Innaloo 3 Our Lady of the Rosary 17 Angelico St, Woodlands 1.51 km Catholic Church WA 6018 4 Community of Christ 48 Lombardy St & Elmwood 1.7 km Ave, Woodlands WA 6018 5 Grace City Church 8/386 Scarborough Beach Rd, 2 km Osborne Park WA 6017

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

6 Church of Jesus Christ of 71 Princess Rd, Doubleview 1.49 km Latter Day Saints WA 6018 7 Local Community Church Churchlands senior high 2 km school, Lucca St, Churchlands WA 6018

Child Care Centre

No. Name Location Distance from Proposed Store 1 Climb Pre-Kindergarten 15 Odin Rd, Innaloo WA 6018 0.46 km 2 Cuddly Bear Day Care 273 Ewen St, Woodlands WA 0.57 km Centre 6028 3 Woodlands Child Care 40 Liege St, Woodlands WA 0.45 km and Learning Centre 6018 4 Mulberry Tree Child Care 240 Scarborough Beach Rd, 1.7 km Doubleview WA 6019 5 Joe Camilleri Day Centre 25 Cedric St, Stirling WA 6021 1.62 km 6 Yuluma OSHClub 21 Ambrose St, Innaloo WA 1.5 km 6018

Local Government Authority

No. Name Location Distance from Proposed Store 1 City of Stirling Local 25 Cedric St, Stirling WA 1.57km Government Office 6021

Short term accommodation or refuges for young people

Within the Locality, there are no identifiable short term accommodation or refuges for young people.

Police Stations

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

There are no identifiable police station(s) within the Locality. The nearest located police station is the Scarborough Police Station located at 92 Scarborough Beach Road, Scarborough WA 6019 which is approximately 3.3 km away.

Regional Office of the Department of Indigenous Affairs

There are no identifiable Regional Office of the Department of Indigenous Affairs within the Locality. The Regional Office of the Department of Indigenous Affairs at Education Department, 151 Royal St, East Perth WA 6004 is outside the Locality.

Drug and alcohol treatment centres

There are no identifiable drug and alcohol treatment centres within the Locality.

While some of these facilities are located close to the Proposed Store, it is submitted that given the manner of trade of the store and the affluent nature of the Locality, there will be a minimal negative impact on these facilities. Nevertheless, these facilities will be consulted during the course of the Application.

8.3 Further measures

As per paragraphs 4 and 7 above, the Applicant proposes to implement the following measures to mitigate any potential for offence, annoyance, disturbance, or inconvenience, to reflect the Applicant’s dedication to protecting the amenity and good character of the Locality: -

(a) A total of 12 security cameras have been installed on the premises, covering all areas of the Proposed Store.

(b) The Applicant will have a staff training and development policy and procedure in place to ensure that all staff of the Proposed Store are regularly and adequately trained in conflict resolution and de-escalation techniques to deal with any conflicts that may arise.

(d) On a regular basis, approved managers of the Proposed Store will liaise with the Centre’s management and neighbours regarding the conduct of business at the Proposed Store to ensure there is no issue.

(e) The Proposed Store will not offer onsite liquor consumption (including tastings) and will not engage in any offensive, noisy or intrusive promotion.

(f) Deliveries of alcohol stock by a supplier will take place during the day to a designated loading area, which is fully enclosed and located at the Centre.

(g) All packaging and waste will be disposed of by the Applicant in a controlled and responsible manner and in compliance with all local government and other laws.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Furthermore, given that the Proposed Store is situated within the Centre and has no external entrance, the Proposed Store can be more easily managed. The Proposed Store will also have the benefit of security provided by the Centre. Similarly, it is unlikely that parking will create problems for those working or living nearby given there is a large on-site car park.

Accordingly, it is unlikely that the sale of niche-type liquor products will cause undue offence, annoyance, disturbance, or inconvenience to people who live and work in the vicinity of the Centre and to the wider community. In any event, the abovementioned strategies together with the Applicant’s House Policy, Management Plan, and Code of Conduct will sufficiently mitigate any potential offence, annoyance, disturbance, or inconvenience as much as possible.

9 TOURISM, COMMUNITY OR CULTURAL MATTERS – SECTION 38(4)(ca)

The grant of the Applicant’s liquor licence application will initiate a new supply chain for the import, supply, and delivery of the niche range of Korean alcoholic beverages. Consequently, there will be employment benefits to the community due to an increased need for particular roles within the Locality such as: -

(a) procurement and shipping executives;

(b) warehouse workers;

(d) drivers.

These benefits will be replicated as the Applicant has plans to open a few more similar stores across Western Australia.

Availability of Korean alcoholic beverages and groceries will increase awareness about Korean culture and enhance social interactions across the local community. This will allow for a greater sense of cohesion and harmony to be instilled among members of the community.

The flow of tourists to the Centre cannot be discounted due to the proximity of Innaloo and the City of Stirling to the Perth CBD. Tourism WA ranks the City of Stirling ranked 3rd for a number of interstate visitors and 4th for international visitors when compared to WA’s other local authorities.28

Estimated Domestic Visitors Numbers Percentage

28https://www.stirling.wa.gov.au/your-city/documents-and-publications/planning-and-building/urban-planning/local-planning- strategy-part-two

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

Visiting friends & relatives 92,300 54%

Holiday 39,000 23%

Other 41,700 24% Estimated Domestic Visitors

Estimated International Numbers Percentage Visitors

Visiting friends & relatives 27,600 57%

Holiday 14,300 29%

Business 2,900 6%

Other 5,200 11% Estimated International Visitors

Estimated overnight visitation to Stirling by purpose, Year Ending December 2014/15/16 (3-year average)

The predominant reason for tourists visiting the City of Stirling is visiting friends and relatives. Tourist numbers peak in the summer months due to ideal beach conditions and a warmer climate. The Centre has been listed as one of the tourism offerings within the City of Stirling.

On 9th April 2021, the Applicant’s lawyers, J & Co Lawyers consulted with the City of Stirling concerning this Application with regards to sections 39 & 40 of the Liquor Control Act 1988 (WA). The issuance of the s 39 certificate on 28 May 2021 confirms the purpose intended for the Proposed Store is appropriate and compliant with the local town planning laws of the City of Stirling.

Likewise, the issuance of s 40 certificate on 28 May 2021 confirms that the Proposed Store complies with the Health (Miscellaneous Provisions) Act 1911 (WA), the Food Act 2008 (WA), the Local Government Act 1995 (WA), the Building Act 2011 (WA), and any written laws applying to the sewerage or drainage of the premises. Enclosed and marked Annexure “13” are copies of the Applicant’s sections 39 & 40 certificates.

10 SECTION 36B

Section 36B of the Act deals with packaged liquor, sold, and supplied for takeaway purposes for consumption off the premises, and it also deals with premises authorised, or proposed to be authorised, to sell and supply packaged liquor.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

A “packaged liquor premises” for the purposes of section 36B is29: -

(a) a hotel license without restrictions;

(b) a tavern license;

(d) a special facility license of a prescribed type.

Therefore, section 36B applies to this present Application.

No issue arises in respect of section 36B(3) of the Act in this case. The Proposed Store will not comprise a retail area that is of the prescribed size. Therefore, the Application is eligible to be heard and determined.

Further and more detailed submissions addressing section 36B of the Act are contained in the Applicant’s 36B Submission and the Report on the Existing Packaged Liquor Premises within the Locality.

11 CONCLUSION

This document thoroughly addresses the key aspects of the PIA Policy, with specific references to the particulars of the Application.

This PIA provides careful and detailed considerations to all the public interest factors. As required by the policy, the Applicant has identified the relevant at-risk groups and has addressed any potential impacts on the Locality.

The Applicant provides a detailed proposal with all the necessary formalities with a substantive volume of evidence from the various sections of the community.

A large number of positive public interest factors presented outweigh the negatives factors which, in any event, have been carefully scrutinised and addressed by the Applicant in the proposal with careful considerations on mitigating any potential negative impacts on the Locality.

For the reasons set out in this PIA and the Section 36B Submissions, the Applicant submits that it is in the public interest for the Application to be granted and that the existing packaged liquor outlets in the Locality cannot reasonably meet local packaged liquor requirements.

29 Sections 36B(1) and (2) of the Act.

Public Interest Assessment Crazy Bang Pty Ltd Public Interest Assessment

12 DECLARATION

I declare that the contents of this document and attachments are true, correct, and complete and that I have made all reasonable inquiries to obtain the information required.

I acknowledge that under section 159 of the Liquor Control Act 1988, it is an offence to provide false, misleading, or incomplete information in this document.

DATED: 29 June 2021

______J & Co Lawyers Lawyers for the Applicant