DOC 01 ALDI FOODS PTY LIMITED applicant for the conditional grant of a liquor store licence ALDI WHITFORD CITY Westfield Whitford City Shopping Centre Marmion Avenue, Hillarys PUBLIC INTEREST ASSESSMENT Prepared by Lavan on behalf of ALDI Foods Pty Limited Ref: Jessica Patterson [email protected] T: (08) 9288 6946 www.lavan.com.au © Lavan 2019 Public Interest Assessment ALDI Whitford City Table of Contents 1 Introduction 2 2 Overview of proposal 3 Consultation 7 Community demand 8 3 Applicant’s details and background 9 ALDI supermarkets 16 ALDI pricing and promotion 18 4 ALDI liquor model 20 The premises 22 Stock range 24 ALDI Exclusive Products 25 Low risk features of the proposal 28 5 Locality 29 Nature and character of local community 31 Westfield Whitford City Shopping Centre 33 6 Section 5 38 7 Harm or ill-health – section 38(4)(a) 39 At risk groups and sub-communities 39 Social health indicators 42 Minimising harm and ill-health 45 8 Impact on amenity, quiet or good order – section 38(4)(b) 53 Outlet density 53 9 Offence, annoyance, disturbance or inconvenience – section 38(4)(c) 63 10 Tourism, community or cultural matters – section 38(4)(ca) 65 11 Other matters 67 Patronage 67 Security and crime prevention 67 12 Conclusion 70 3462-4413-8765_1163023, v.3 © Lavan 2019 Public Interest Assessment ALDI Whitford City 1 Introduction 1.1 ALDI Foods Pty Limited (ACN 086 210 139) seeks the conditional grant of a liquor store licence to operate from a small space within the new ALDI supermarket that will be constructed at Westfield Whitford City Shopping Centre, Marmion Avenue, Hillarys. If granted, the licence will trade as ALDI Whitford City. 1.2 This detailed Public Interest Assessment (PIA) supports the application and addresses all relevant aspects of the public interest in accordance with both the Liquor Control Act 1988 (WA) (Act) and the licensing authority’s Public Interest Assessment policy1 (PIA Policy). 1.3 Pursuant to the PIA Policy, the standard Locality for Hillarys is a 3km radius area surrounding the proposed site (Locality). 1.4 This PIA is part of the Applicant’s Case and should be read in conjunction with the other parts, all of which are itemised in the document titled Index of Material Before the Director and Applicant’s Case (Index). Where this PIA cites particular documents with “DOC” followed by a number (eg “(DOC 1)”), it references material in the Applicant’s Case by way of its listing in the tables contained within the Index.2 1.5 In particular, referred to throughout this PIA are two detailed reports prepared by experts that the applicant engaged in respect of this application (DOCS 8 and 9). 1.5.1 Patterson Research Group3 (PRG) surveyed people living in the Locality to assess their attitudes toward the ALDI liquor proposal. This research was done in June 2019 through a series of expertly prepared questions that were put to a representative sample of residents. 1.5.2 Deep End Services4 (DES) has provided expert in-depth analysis of the Locality, including a detailed analysis of demographics, planning policies and strategies, trade catchment and density of licensed premises. 1.6 The findings in the reports prepared by these two experts supplement the applicant’s own research and submissions in this PIA. Collectively, the documents provide a significant volume of evidence to support the Applicant’s Case for the grant of the ALDI Whitford City licence. ____________________________________________________________________________ 1 https://www.dlgsc.wa.gov.au/department/publications/publication/public-interest-assessment-policy. Last amended 3 October 2018 2 Supporting material referred to in this document not produced by or for the applicant has been obtained from public sources under licence. Where relevant, personal information within the supporting material has been redacted for privacy reasons. Full copies of some of the source material accompany this PIA and are listed in the Index. Other material not so listed in the Index can be made available in full if required and has only been left out of the Index to lessen the burden of paper on the licensing authority. 3 https://www.marketresearch.com.au/about_us/overview.phtml 4 http://deependservices.com.au/index.php/about-us/ 3462-4413-8765_1163023, v.3 © Lavan 2019 2 Public Interest Assessment ALDI Whitford City 2 Overview of proposal 2.1 This application is made by a highly sophisticated and experienced packaged liquor operator, which enjoys extensive supermarket and liquor retailing experience within Western Australia, elsewhere here in Australia and overseas. 2.2 ALDI has been operating in Australia since 2001 when the first ALDI store opened in Sydney. There are now over 580 stores throughout Australia, including approximately 520 stores in the eastern states. Around 330 of those stores in the eastern states include a liquor component. 2.3 The company is in the midst of a $700 million expansion into other states in Australia, with approximately 70 stores to open in Western Australia and up to 50 stores in South Australia in total. 2.4 ALDI opened its first four supermarkets in Western Australia on 8 June 2016. By the end of 2016, ALDI had opened 19 stores in total and served approximately 3.2 million WA shoppers.5 There are currently 43 supermarkets operating throughout this State, with several more expected to open this year. 2.5 ALDI is one of the largest and most popular retailers in the world. Some customers are such passionate and dedicated fans of ALDI’s wide range of household and consumable products that they have developed their own name, “ALDIholics”. There is a customer-driven Facebook page named, ALDIholics, with its own logo depicted to the right,6 devoted to information for ALDI lovers. 2.6 Further in terms of social media, ALDI boasts strong following and popularity, as shown in the screenshots below.7 These mediums are the modern day voice of the public and significant representations of community sentiment. 5 http://www.perthnow.com.au/news/western-australia/aldi-to-open-14-more-stores-in-wa-in-2017/news- story/0de29965fcd9712852ab9b2919908286 6 https://www.facebook.com/ALDIholics/ 7 https://www.facebook.com/ALDI.Australia/ and https://www.facebook.com/ALDI.Australia/app/116943498446376/ 3462-4413-8765_1163023, v.3 © Lavan 2019 3 Public Interest Assessment ALDI Whitford City 2.7 The emergence of the ALDI retailing concept into Western Australia, following the company’s significant popularity in the eastern states, has been and continues to be exciting and highly anticipated from the general public’s perspective. 2.8 The proposal is for a small liquor display/browse section of only approximately 30m2 within the ALDI Whitford City supermarket. A carefully selected and exclusive range of unrefrigerated liquor is proposed to be available in a discrete and clearly designated licensed area within the supermarket. 2.9 This liquor model is entirely unique to ALDI. Its various features referred to throughout this PIA, make for a bespoke manner of trade. The boutique type of liquor service is designed specifically to complement and accompany the diverse and attractive ALDI supermarket services and facilities. This creates a true one-stop- shopping8 convenience for customers, which is a key feature of the ALDI offering. 2.10 The ALDI liquor service was first made available in WA at the end of August 2017 in five of its supermarkets. A total of 35 ALDI supermarkets have been approved to sell liquor in WA, 26 of which are currently operating with the liquor service. 8 This is addressed in detail in the applicant’s accompanying Legal Submissions (DOC 7). 3462-4413-8765_1163023, v.3 © Lavan 2019 4 Public Interest Assessment ALDI Whitford City 2.11 The ALDI liquor offering is described as follows by ALDI Australia’s Wine and Sparkling Buyer, Mr Jason Bowyer:9 Like our grocery offer, ALDI’s liquor range is focused, ensuring that we offer great value and exceptional quality. Since establishing in WA more than a year ago, customers have spoken loudly about their desire for us to bring our popular liquor offering to the West. ALDI partners with a number of high calibre international and Australian wine suppliers, who each share our passion for quality. We have built strong relationships with these suppliers, who are committed to ensuring that our wine products offer great value at their respective price points. 2.12 In recognition of the launch of the ALDI liquor service in WA, renowned wine expert Ray Jordan was invited to sample six of the wines in ALDI’s WA stores. Mr Jordan remarked that one of the wines in particular, being a $7 bottle of One Road South Australian Heathcoate Shiraz 2015 (pictured to the right), was “damn good”.10 That Shiraz has also won several other awards, including Double Gold & Best Value Shiraz of the Year at the 2017 Melbourne International Wine Competition. This Shiraz is just one example of ALDI’s many high quality, value-for-money, award winning liquor products. 2.13 The debut of the ALDI liquor service in WA was widely embraced by the public. The announcement on the ALDI Australia Facebook page11 (pictured below on the left) received a swarm of favourable reactions. Many of the comments revolved around members of the public wanting the liquor service at their local ALDI supermarkets. Some examples are provided below.12 There is clearly a significant demand for the ALDI liquor service throughout WA. This anticipated demand has since translated into significant patronage and sales at the ALDI liquor stores that have begun trading. 9 https://www.aldi.com.au/fileadmin/fm-dam/Products/Groceries/Liquor/WA_Launch/ALDI_Media_Release_- _WA_Liquor_Launch_1_.pdf 10 http://www.perthnow.com.au/news/western-australia/aldi-will-start-selling-alcohol-in-perth-stores-from-today/news- story/c59014afc215ba475dd1265a0e89eb4c 11 https://www.facebook.com/ALDI.Australia/posts/1716136855110475 12 Personal details have been redacted for privacy reasons.