Grant of a Liquor Store Licence Public Interest Assessment BWS North Ellenbrook
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Grant of a Liquor Store Licence Public Interest Assessment BWS North Ellenbrook 17 September 2020 48501879_1
Contents
ABOUT THIS APPLICATION 5
Part 1 - Background Information 6
A. Premises 6
1 Shopping Centre 6
2 The Proposed Store 6
3 Development Approval 6
B. The Business to be operated at the Proposed Store 7
1 Background of Endeavour Group Limited 7
2 Overview of BWS 7
2.1 BWS Products 9
2.2 Success of the BWS brand 9
2.3 Responsible management 10
Part 2 – Tests to be satisfied 11
A The Public Interest Test and Packaged Liquor Requirements
11
1 What is the 'Public Interest Test'? 11
2 What needs to be satisfied to meet the Public Interest Test? 11
2.1 Primary and secondary objects 11
2.2 Additional factors 12
3 Packaged liquor requirements 12
4 About this PIA 13
B. Locality 15
1 Defining the Locality 15
2 Location of Proposed Store 15
3 Strategic Planning Framework 16
4 Demographics 17
4.1 Current Population and Forecasts 17
4.2 Age Profile 18
4.3 Migrants 18
4.4 Household Composition 18
4.5 Employment 18
4.6 Socio-economic status 18
4.7 Summary 19
5 Sensitive Premises 19
C. Other Licensed Premises in the Locality 21
King & Wood Mallesons PIA - BWS Ellenbrook North 2
48501879_1
1 Licensed Premises 21
1.1 Existing Packaged Liquor Services 21
1.2 Distribution of Existing Premises 24
1.3 Ease of Access to the Existing Premises 25
1.4 Summary 26
D. Consumer Requirement and the Proper Development of the
Industry 27
1 Australian Liquor Market 27
1.1 Changes in the way that we shop 27
1.2 BWS Customers 28
2 Community Survey 28
2.1 The Results 29
E. How does the proposal address the minimisation of harm and
ill health? 32
1 Current Alcohol Consumption Trends in Australia and Western Australia 32
1.1 Australia 32
1.2 Western Australia 34
2 Alcohol Related Harm 35
2.1 Hospitalisation, Mortality and Alcohol Consumption rates 35
2.2 VicHealth Study 36
2.3 Crime Rates 37
2.4 Community Safety 38
3 Harm Minimisation Management 38
3.1 Effective management 38
3.2 Management practices, staff training and RSA 39
3.3 Environmental factors: Crime prevention through
environmental design 40
3.4 Responsible buying 41
3.5 Community education 41
3.6 Community involvement 42
4 Impact on Specific at Risk Groups 42
4.1 At risk groups 42
F. Other Factors 45
1 The amenity, quiet or good order of the Locality - Section 38(4)(B) 45
1.1 Retail Amenity 45
1.2 One-stop shopping 46
1.3 Physical amenity 46
2 Offence, annoyance, disturbance or inconvenience 47
2.1 Trading hours 47
2.2 Traffic 47
2.3 Noise 47
2.4 Security and management 48
3 Tourism, or Community or cultural matters 48
A
King & Wood Mallesons PIA - BWS North Ellenbrook 3
48501879_1
H. CONCLUSION 49
I. FURTHER INFORMATION 51
Annexure A Shopping Centre/Site Plan 52
Annexure B BWS Store Plan 53
Annexure C Statement of Anthony Smith 54
Annexure D Locality Plan 55
Annexure E Sensitive Premises Plan 56
Annexure F Survey Results 57
Annexure G Harm Minimisation Policy 58
Annexure H RSA Policy 59
Annexure I Responsible Buying Charter 60
Annexure J Proportion of One Stop Shoppers 61
King & Wood Mallesons PIA - BWS North Ellenbrook 4
48501879_1
ABOUT THIS APPLICATION
Endeavour Group Limited (Endeavour or the Applicant) is applying for the grant of a
liquor store licence for a new BWS liquor store (Proposed Store) to be located within the
new shopping centre which is to be constructed on land bounded by Maffina Parade,
Devitt Way, Bordeaux Lane and The Broadway in north Ellenbrook, Western Australia
(Shopping Centre).This Public Interest Assessment (PIA) is presented in support of an
application to the Director of Liquor Licensing for the grant of a liquor store licence in
respect of the Proposed Store. Under section 38(2) of the Liquor Control Act 1988 (WA)
(Act), the Applicant must satisfy the Licensing Authority that, on the merits of the
application, it is in the public interest to grant the licence (the 'public interest test'). As
stated in McKinnon v Secretary Department of Treasury:
“The expression ‘in the public interest’ directs attention to that conclusion or
determination which best serves the advancement of the interest or welfare of
the public, society or the nation and its content will depend on each particular set
of circumstances.”1
The Applicant submits that the granting of the liquor licence for the Proposed Store will be
in the public interest and will contribute to the responsible development of the liquor
industry in the locality where the Proposed Store will be located.
The Applicant must also satisfy the licensing authority that local packaged liquor
requirements cannot reasonably be met by the existing packaged liquor outlets in the
locality pursuant to s36B(4) of the Act.
The Applicant submits that it has provided sufficient evidence in this PIA to satisfy this
packaged liquor requirement threshold test.
This PIA is divided into 2 parts:
(a) Part 1 outlines the background of the application and the development of
the Proposed Store; and
(b) Part 2 addresses the elements of the public interest test and
demonstrates that the test is satisfied in respect of the Proposed Store. It
also demonstrates that the local packaged liquor requirements cannot
reasonably be met by existing packaged liquor premises in the locality.
1
(2005) 220 ALR 587, 590
King & Wood Mallesons PIA - BWS Ellenbrook North 5
48501879_1
Part 1 - Background Information
A. Premises
This section of the PIA summarises the plans for the Proposed Store.
1 Shopping Centre
The Shopping Centre will consist of a full-scale Woolworths supermarket
(3,200 sqm) (Supermarket), the Proposed Store (200 sqm) and approximately
10 speciality/commercial tenancies (approximately 1,780 sqm). The Shopping
Centre is expected to open in July 2021. There will be 287 on-grade car parking
spaces available at the Shopping Centre.
A site plan of the Shopping Centre can be found at Annexure A.
The Proposed Store will primarily service residents in The Vines and the northern
parts of Aveley and Ellenbrook.
2 The Proposed Store
The Proposed Store will be approximately 200 sqm in size and hold stock worth
approximately $240,000. The Proposed Store will be in the typical BWS format
and will employ 3 full time staff and 4 permanent part-time/casual staff. A plan of
the Proposed Store is attached at Annexure B.
The Proposed Store will open at the following times:
Monday to Friday 8am – 9pm
Saturday 8am – 5pm
Sunday 11am – 5pm
The Proposed Store will be located adjacent to the Woolworths supermarket to
provide the opportunity for single-trolley grocery and liquor purchases.
3 Development Approval
Development Approval was granted by the City of Swan on 14 April, 2020.
The Proposed Store will form part of a new Shopping Centre that will
include a full-scale Woolworths Supermarket. The Proposed Store will be
adjacent to the Woolworths supermarket in a stand-alone building.
Development Approval has been granted.
King & Wood Mallesons PIA - BWS Ellenbrook North 6
48501879_1
B. The Business to be operated at the Proposed Store
1 Background of Endeavour Group Limited
On 3 & 4 February 2020, Woolworths Group Limited (Woolworths) merged its
drinks and hospitality businesses, Endeavour Drinks and ALH Group Pty Ltd
(ALH), into a single entity within Woolworths known as Endeavour Group Limited.
The merger of Endeavour Drinks and ALH has created Australia’s largest
integrated drinks and hospitality business with sales of approximately $10 billion
and EBITDA12 of $1 billion. Endeavour will have leading market positions, strong
cash flow to fund investments in growth and an attractive and resilient revenue
and earnings profile. It will comprise highly integrated store-based and online
offerings, with over 1,500 BWS and Dan Murphy's retail drinks outlets and 327
ALH hotels. ALH retail drinks outlets currently comprise approximately 35% of
Woolworths Group retail drinks sales with 86 Dan Murphy’s and 512 BWS stores
owned by ALH at the end of March 2019.
Endeavour continues to uphold the strict policies and practices for licensed
premises implemented by Woolworths.
2 Overview of BWS
BWS stores are liquor stores which provide convenience to customers. Part of
the popularity of BWS is the locations of the stores in neighbourhood shopping
centres either as stand-alone stores or adjacent to Woolworths supermarkets.
After Dan Murphy's, BWS is the second most popular store for purchasers of
packaged liquor.3
Figure 1: Market share over time: supermarket liquor stores’ total alcohol retail share of
dollars
As a dominant player in the alcohol retail industry, Endeavour (formerly
Woolworths) has maintained the highest market penetration among alcohol
retailers in Australia. Data released by Roy Morgan in September 2019, revealed
that 60.7% of Australian alcohol buyers purchased from a Woolworths-owned
2 EBITA – Earnings before interest, taxes, and amortization
3 Roy Morgan (20/03/2017) 'The Australian alcohol retail market in review' - accessed at
http://www.rovmorgan.com/findings/7181-liquor-retail-australia-201703201051
King & Wood Mallesons PIA - BWS North Ellenbrook 7
48501879_1
store in an average four-week period.4 37% of these consumers purchase
exclusively from Woolworths stores (now owned by Endeavour).5
Figure 2: Cross visitation of alcohol retail consumers
Source: Roy Morgan Single Source Australia, July 2018 – June 2019, n=6,829. Base: Australians
aged 18+ who had purchased packaged alcohol in the past four weeks.
The BWS customer base appears to be increasing at impressive levels. Over a
period of 12 months leading to September 2018 BWS increased its customer
base by 9.3%.6
Figure 3: Roy Morgan Research
4 Roy Morgan (02/09/2019) ‘Woolworths bottle shops prove must popular’ – accessed at
http://www.roymorgan.com/findings/8114-alcohol-retail-cross-visitation-june-2019-
201908300757
5
Ibid.
6 Roy Morgan (8/11/2018) ‘Supermarkets continue to take alcohol market share from hotel bottle-
shops’ – accessed at http://www.roymorgan.com/findings/7753-supermarkets-continue-to-take-
alcohol-market-share-from-bottle-shops-201811080408
King & Wood Mallesons PIA - BWS North Ellenbrook 8
48501879_1
Recent Roy Morgan research has found that ‘[for] BWS it is the 845,000
Australians aged 35-49 years of age who comprise the largest share of their
customers’.7
2.1 BWS Products
BWS offers a comprehensive range of liquor products, including local and
international beer, wine and spirits. The range is focused on popular brands and
includes brands sold exclusively through Endeavour’s liquor stores. As such, the
Proposed Store will provide local residents with some products that cannot be
supplied by many of the other existing liquor stores in the local area.
Approximately 1,671 products will be available at the store, comprised of the
following:
Table 1: Product Range
Item Number of products
Beer 221
White wine 308
Sparkling wine 111
Red wine 314
Fortified and cask wines 90
Ciders 116
RTD's 146
Glass spirits 285
Snack foods, soft drinks and cigarettes 80
Total 1,671
2.2 Success of the BWS brand
As discussed in the decision of the Supreme Court regarding the application for
Dan Murphy's Bicton, the popularity and success of a brand in other locations
can be assessed and applied to the current application where relevant.8 BWS
has built a strong reputation as both a stand-alone neighbourhood liquor store
and as a co-located liquor and supermarket store. The key drivers of purchase
intention at BWS are:9
(a) Location and access (36%);
(b) Quality (33%); and
(c) Customer service (28%)
A BWS store is usually located at the front of the Woolworths supermarket or
directly adjacent to it. This means the store is convenient to both customers who
only want to purchase packaged liquor, as well as those customers who are
purchasing liquor as part of their grocery shop. It is part of a 'one-stop' shopping
experience allowing consumers to purchase all their weekly food and liquor
purchases in one shop. BWS has built its popularity on the basis of its
convenience and accessibility for customers, with 46% of people indicating that
7 Ibid
8
Woolworths Ltd v Director of Liquor Licensing [2013] WASCA 227.
9
Statement of Anthony Smith at para 4.7
King & Wood Mallesons PIA - BWS North Ellenbrook 9
48501879_1
they purchase packaged liquor as part of their grocery shopping or other
shopping trip.10
Further information about BWS is contained in the statement of Anthony Smith
attached at Annexure C.
2.3 Responsible management
BWS operates under Endeavour’s strict policies and procedures for its licensed
premises. Endeavour implements best practice harm minimisation policies to
assist with management of alcohol in the community. These policies are
discussed in further detail below and include responsible service of alcohol
(RSA) training for staff, educational campaigns and responsible buying
guidelines.
The BWS brand is based on convenience and accessibility. It is a local store
for surrounding residents. BWS stores have been incorporated into
Woolworths’ supermarket offerings to provide a 'one-stop' shopping
experience which has become an essential part of Australian life. BWS is a
comprehensive liquor store which provides a good range of products.
10
ibid at paragraph 4.6
King & Wood Mallesons PIA - BWS North Ellenbrook 10
48501879_1Part 2 – Tests to be satisfied
A The Public Interest Test and Packaged Liquor
Requirements
1 What is the 'Public Interest Test'?
For the application to be approved, the Applicant must satisfy the Director that
granting the application is in the public interest pursuant to s 38(2) of the Act.
While the Act does not define 'public interest', the Department of Local
Government, Sport and Cultural Industries (DLGSC) policy refers to the
Butterworth’s Australian Legal Dictionary as follows:
"an interest in common to the public at large or a significant portion of
the public and which may or may not involve the personal or propriety
rights of individual people."11
A general discretion by reference to the criterion of the 'public interest' is not an
unfettered discretion but will ordinarily be confined by the scope and purpose of
the statute.12
2 What needs to be satisfied to meet the Public Interest Test?
2.1 Primary and secondary objects
In assessing whether the 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.13 The primary and secondary objects of the Act set out in s 5 are:
Primary Objects:
(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.
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; and
(c) to provide a flexible system, with as little formality or technicality as may
be practicable.
11 Department of Local Government, Sport and Cultural Industries (29 May 2019) ‘Public Interest
Assessment policy’ at p1.
12
Woolworths v Director of Liquor Licensing [2013] WASCA 227 at [48]
13
ibid at [49]
King & Wood Mallesons PIA - BWS Ellenbrook North 11
48501879_1(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 licensing authority's obligation to take account of the primary and secondary
objects is not diminished by the unfettered terms of the discretion conferred by
s33 of the Act. That section does not confer upon the Licensing Authority an
unlimited power, but instead that power must be exercised consistently with the
primary and secondary objects.14
2.2 Additional factors
The Licensing Authority is entitled to take into account the factual matters set out
in s 38(4) in determining whether it is satisfied that the granting of the Application
is in the public interest.15 These factual matters are as follows:
(a) the harm or ill-health that might be caused to people, or any group of
people, due to the use of liquor;
(b) the impact on the amenity, quiet or good order of the locality in which the
licensed premises, or proposed licensed premises are to be situated;
(c) whether offence, annoyance, disturbance or inconvenience might be
caused to people who reside or work in the vicinity of the licensed
premises or proposed licensed premises;
(d) any effect the granting of the application might have in relation to
tourism, or community or cultural matters; and
(e) any other prescribed matter.
It should be noted that s 5(2) of the Act is mandatory whereas s 38(4) is
permissive.16
3 Packaged liquor requirements
The Act was amended on 2 November 2019 to incorporate restrictions on the
grant or removal of certain licenses authorising the sale of packaged liquor.
Section 36B(4) provides :
‘The licensing authority must not grant an application to which this section
applies unless satisfied that local packaged liquor requirements cannot
reasonably be met by existing packaged liquor premises in the locality in which
the proposed licensed premises are, or are to be, situated.’
It is submitted that this section provides that the licensing authority must not
grant an application for a liquor store licence if the existing premises selling
packaged liquor in the area from which the customers of the new liquor store
would come are already able to meet the requirements of those customers for
packaged liquor.
In assessing whether the Application meets this local packaged liquor threshold
test, the Licensing Authority is again 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 objects of the Act are mandatory
14 ibid at [53] - [54]
15
ibid at [50]
16
ibid at [49]
King & Wood Mallesons PIA - BWS North Ellenbrook 12
48501879_1relevant considerations which inform both the public interest test under s38(2)
and the assessment to be made under s36B(4).
In the recent decision for BWS Inglewood A775016681 (Inglewood Decision) it
was submitted by the Director of Liquor Licensing that in order to satisfy s36B(4)
of the Act
‘it is necessary for an applicant to adduce relevant probative evidence upon
which the licensing authority can make findings of fact as to:
what the local packaged liquor requirements are; and
what packaged liquor services are currently provided by the existing
packaged liquor premises in the locality’17
The Licensing Authority is then ‘required to make a value judgement as to
whether the local packaged liquor requirements can reasonably be met by the
existing packaged liquor premises in the locality.’ 18
The Director of Liquor Licensing provided further detail at para 36 of the
Inglewood Decision where it was submitted that in making a ‘value judgement’
consideration should be given to the following relevant factors:
the existing packaged liquor services in the locality;
distribution of premises in the locality; and
ease of access to the existing premises.
It was submitted that:
‘this is not an exhaustive list as ultimately the value judgment will be
guided by the facts and circumstances of each case and the evidence
provided by the applicant’19
The Applicant submits that in summary the following factors are relevant in
applying s36B(4)
• The locality of the Proposed Store;
• The requirements of consumers for packaged liquor in the locality; and
• The extent to which existing packaged liquor premises in the locality
meet the requirements of consumers.
4 About this PIA
The role of this PIA is to address each of the objects outlined in the Act with
regard to the specific premises. In order to satisfy the public interest test and the
packaged liquor requirements the Applicant has completed research, engaged
various experts and conducted community consultation, including:
(a) engaging MGA Town Planners to provide planning and demographic
data for the locality;
17 Decision by the Director of Liquor Licensing ‘BWS – Beer Wine Spirits Inglewood’ dated
16/06/2020 at para 14
18
Ibid at para 15
19
Ibid at para 36
King & Wood Mallesons PIA - BWS North Ellenbrook 13
48501879_1(b) undertaking research and analysis of data on alcohol-related harm and
health, alcohol purchasing habits and social issues in the locality;
(c) engaging Painted Dog to design and conduct an on-line community
survey with residents in the locality; and
(d) undertaking a review of other packaged liquor outlets in the locality.
Part 2 of this PIA addresses the requirements of the public interest test and
the new packaged liquor restrictions with reference to the various expert
reports and data collected by Endeavour.
King & Wood Mallesons PIA - BWS North Ellenbrook 14
48501879_1B. Locality
This section of the report defines the locality for the purposes of this PIA.
1 Defining the Locality
The Licensing Authority describes the locality to be the area which is generally
considered to be most impacted if the application is granted.20 In this Application
the Locality is 3km as the Proposed Store is more than 15km from the Perth CBD
but within the Metropolitan Region Scheme administered by the WA Planning
Commission (Locality).
However, depending on the nature of the application, the Licensing Authority
may determine a different locality radius for a specific application, particularly
where the potential impact on a specific sub-community or 'at risk' group is such
that reference to this sub-community should also be made, notwithstanding that
this group may be situated outside the 3km radius of the proposed licensed
premises.
Therefore, the onus is on the Applicant to identify any potential 'at risk' groups
which may travel through or make use of the Proposed Store, or who may be
impacted by the Proposed Store. This may include a group of people not
situated within the boundaries of the town or suburb in which the Proposed Store
will be located.
In the case of this Application the Applicant is satisfied that the 3km radius is
appropriate.
The Locality may be described as outer metropolitan, positioned approximately
23km north east of the Perth CBD. The Locality takes in the suburbs of
Ellenbrook, The Vines, Belhus and Aveley and a small portion of the suburbs of
Bullsbrook (north) and Upper Swan (east).
A plan of the Locality is attached at Annexure D.
2 Location of Proposed Store
The Proposed Store will form part of the soon to be constructed Brook Lane
Shopping Centre. The Shopping Centre and Proposed Store will be located in
the local government municipality of the City of Swan in the northern part of the
suburb of Ellenbrook.
Ellenbrook is a rapidly developing suburb approximately 25kms north east of the
Perth CBD. The subject land is 2.5km north of the Ellenbrook town centre.
Ellenbrook has been master-planned to be a town of several viable
communities.21 The Proposed Store forms part of this growth by providing retail
amenity and employment opportunities in the northern part of Ellenbrook and
beyond.
The Shopping Centre land is generally surrounded by residential land uses to the
east (beyond Devitt Way), north (beyond Bordeaux Lane) and west (beyond the
Broadway).
20 Department of Racing, Gaming and Liquor, 'Public Interest Assessment Pursuant to section 38
of the Liquor Control Act 1988', Attachment 2 - Specification of 'Locality'.
21
City of Swan, Ellenbrook Local Area Plan (September 2017), para 2.1
King & Wood Mallesons PIA - BWS Ellenbrook North 15
48501879_1Public transport services operate along The Broadway and Maffina Parade.
Dedicated pedestrian walkways will be provided to connect the existing pathways
to the Proposed Store and Shopping Centre.
Figure 4: Aerial photograph of the site
3 Strategic Planning Framework
The Western Australian Planning Commission administers State Planning Policy
4.2 - Activity centres for Perth and Peel (State Planning Policy)22.This policy
sets out the strategic distribution of activity centres and a hierarchy meeting
different levels of community need.
Ellenbrook is a secondary centre in the State Planning Policy.23 A secondary
centre is described as performing a ‘important role in the city’s economy, and
provide essential services to their catchments’. It includes supermarkets and
speciality shops.
The land on which the Proposed Store and Shopping Centre will be built is not
specifically mentioned in the State Planning Policy. It is however identified in the
City of Swan Local Commercial and Activity Centres Strategy (2017) (LCACS) as
a neighbourhood centre in the first instance with the potential to be a district
centre in the future. 24
As noted in the LCACS neighbourhood centres are:
‘an integral part of the activity centre hierarchy as they provide the day-to-day
and weekly shopping and other services to their surrounding communities. It is
important that the level of access to neighbourhood centres is maximised as
neighbourhood centres provide a wide-range of essential services. A network of
easily accessible neighbourhood centres supports the broader land use planning
principles outlined by the State Government (e.g reduce car travel).’
The Shopping Centre land is located within the North-East sub-region of the
Perth and Peel @3.5 million framework. The North-East sub-region has a
population expected to grow from 209,000 people in 2011 to over 450,000
22 State Planning Policy - Activity Centres for Perth and Peel (2010) (SPP4.2)
23
Ibid at Table 2
24
City of Swan Local Commercial and Activity Centres Strategy, para 9.2
King & Wood Mallesons PIA - BWS North Ellenbrook 16
48501879_1people by 2050. The North East sub-regional planning framework identifies the
importance of the development of new and existing activity centres into vibrant,
mixed use community hubs to achieve a level of service to cater for the growing
population. The Proposed Store and Shopping Centre meet that objective.25
4 Demographics
The following demographic analysis has been prepared by MGA Town Planners
based on the 2016 Census data.26 The 2011 Census has been used to indicate
recent trends.
4.1 Current Population and Forecasts
Between the 2011 and 2016 census the population in the Locality has increased
annually by an average of 2,808 people. It is therefore projected the population of
the Locality will rise to 43,625 by mid-2020. This is a very significant increase of
138% from 2011.
Table 2: Local Population Change (3km Radius)
Population
2011 2016 2017 2018 2019 2020
18,353 32,393 35,201 38,009 40,817 43,625
According to Forecast ID the population in the suburbs of Ellenbrook/The Vines
and Aveley is expected to increase again to 70,019 by 2036. This is a 116%
increase in population between 2016 and 2036.
Table 3 - ID Population Forecasts - 2016-203627
Location Population 2016 Population 2036
Ellenbrook / The 32,393 70,019
Vines / Aveley
This growth is very significant and the demand for the provision of retail outlets
such as the Proposed Store is set to increase accordingly. These figures are also
in line with the strategic planning for the Locality as discussed above at
paragraph 3.
Table 4 below shows the population in each of the suburbs forming the Locality
at the time of the 2016 Census. It can be seen that Ellenbrook makes up the
majority of the Locality (57.1%), followed by Aveley (27.1%) and The Vines
(15.0%). The Proposed Store is located in the northern part of Ellenbrook.
25Department of Planning, Lands and Heritage (March 2018) ‘North-East Sub-regional Planning
Framework’ at p19
26 MGA Town Planners (July 2020) 'Proposed BWS Liquor Store (BWS North Ellenbrook)’.
27 Table 3, shows the estimated populations by suburbs. The totals for the suburbs are for the
entire suburb areas, and therefore do not reflect the portion of these suburbs in the Locality.
King & Wood Mallesons PIA - BWS North Ellenbrook 17
48501879_1Table 4: Population by Suburb- 2016 Census28
Suburb Population 2016 Portion of Locality
Ellenbrook 18,500 57.1%
Aveley 8,763 27.1%
Belhus 271 0.8%
The Vines 4,859 15.0%
Total Locality 32,393 100%
4.2 Age Profile
The Locality is home to a higher proportion of working aged persons aged 20-29
(33.7%) than throughout the Greater Perth area (29.7%). The proportion of those
aged 60+ in the Locality is much lower than throughout the Greater Perth area
(19.0%) and the State (19.3%).
The data reveals that the population is relatively youthful with a large proportion
of working-aged persons.
4.3 Migrants
The proportion of Australian born persons in the Locality (59.6%) is higher than
the Greater Perth area (57.4%) but slightly lower than the State (60.5%). The
Locality has a lower proportion of persons born in non-English speaking
countries (14.9%) than the Greater Perth area (18.7%). In addition, English
proficiency is high in the Locality, with only 1% of persons in the Locality not
speaking English well or at all, in comparison to 2.3% throughout the Greater
Perth area.
4.4 Household Composition
The Locality is dominated by family households (84.8%). This is higher than the
proportion of family households in the Greater Perth area (73%) and the State
(72.7%).
The proportion of couple families with children in the Locality (52.7%) is higher
than the Greater Perth area at (46.3%) and the State at (45.3%). The proportion
of couples having no children in the Locality (31.1%) is lower than both the
Greater Perth average (37.5%) and the State (38.5%).
4.5 Employment
Unemployment across the Locality (7.6%) is lower than the Greater Perth area
and the State (8.1% and 7.8% respectively).
4.6 Socio-economic status
The index of Relative Socio-Economic Advantage/Disadvantage (IRSAD) for the
Locality is as follows:
28 Table 4, shows the population within each suburb, or portion thereof, contained within the
Locality
King & Wood Mallesons PIA - BWS North Ellenbrook 18
48501879_1Table 5: SEIFA rankings (2016)
Relative Socio-Economic Relative Socio-Economic
Advantage/Disadvantage Advantage/Disadvantage
Suburb rank (National) rank (State-wide)
Ellenbrook 6 4
Aveley 8 8
Belhus 9 9
The Vines 10 10
The IRSAD summarises variables that indicate either relative advantage or
disadvantage. This index ranks areas on a continuum from most disadvantaged
to most advantaged. An area with a high score on this index indicates a relative
lack of disadvantage and greater advantage in general.
All suburbs within the Locality were identified as having SEIFA rankings
exceeding national median rankings, with the suburbs of Aveley, The Vines and
Belhus having notably high rankings.
Individual, household and family incomes in the Locality also exceeded State and
Greater Perth averages. A much higher proportion of dwellings are being
purchased (66.2%) in comparison to Greater Perth (41.9%) reflecting the number
of first home buyers establishing in the Locality and the expansion we are likely
to see in the near future.
4.7 Summary
The Locality is a residential area with a population that is likely to increase very
significantly in coming years. The new Shopping Centre will provide the northern
part of Ellenbrook, the Vines and the northern part of Aveley with much needed
retail amenity to reflect this increase in population. The demand for retail
amenity in the Locality is recognised in the City of Swan Local Commercial and
Activity Centres Strategy.
The Locality is dominated by family households with incomes that are higher than
the Greater Perth and State averages and unemployment rates that are
comparable to the State and national averages. It is a socio-economically
advantaged area that is set to develop significantly in the years to come.
5 Sensitive Premises
The sensitive premises in the area are identified in part 8 of the MGA Town
Planners’ Report.
There are 20 sensitive premises in the Locality. Two of these sensitive premises
are located within 800m of the Proposed Store being a childcare facility and a
high school, however, they will not be visible from the Proposed Store.
The sensitive premises are shown on the map attached at Annexure E.
Generally, the impact of licensed premises on sensitive premises is greater
where the licensed premises is a social facility which provides on-site drinking.
This is due to the potential noise issues and patron behavioural problems which
may impact on the surrounding area. BWS is a packaged liquor store and as
such there will not be any drinking on the premises (other than occasional
tastings if permitted). The Proposed Store will also only operate until 9pm during
King & Wood Mallesons PIA - BWS North Ellenbrook 19
48501879_1the week and 5pm on weekends which will greatly minimise any potential impact
on surrounding premises that might arise from late night trading.
The Proposed Store will be contained within the grounds of the new Shopping
Centre and concealed from surrounding sensitive premises, inhibiting any
potential for those attending the local high school or childcare centre from being
directly exposed to views of the Proposed Store.
The Locality is an advantaged residential area with strong SEIFA rankings
and income profiles. It has a higher number of houses being purchased in
comparison to the Greater Perth area. It is a relatively youthful, working aged
population. There is expected to be a very significant population growth in the
Locality in the coming years which leads to an increased demand for retail
amenity. This demand is recognised in local planning strategies.
There are no sensitive premises within sight of the Proposed Store.
King & Wood Mallesons PIA - BWS North Ellenbrook 20
48501879_1C. Other Licensed Premises in the Locality
1 Licensed Premises
There are 7 existing licensed premises in the Locality capable of selling
packaged liquor to the public.
To satisfy s36B(4) of the Act and the public interest test pursuant to s38(2) of the
Act, the Applicant has prepared an analysis of the 5 licensed premises
predominantly involved in selling packaged liquor in the Locality. The other two
premises (the Vines Resort and Country Club and the Brook Bar and Bistro) are
not packaged liquor stores.
The Applicant has considered the following factors:
the existing packaged liquor services in the Locality;
distribution of premises in the Locality; and
ease of access to the existing premises.
1.1 Existing Packaged Liquor Services
(a) BWS Ellenbrook
BWS Ellenbrook is positioned immediately west of a carpark adjoining
the Woolworths supermarket building in the Ellenbrook Central Shopping
Centre (Ellenbrook Central). The location of the carpark between the
BWS store and the southern shopping centre entry (leading to the
supermarket) assists those shoppers seeking to purchase packaged
liquor in conjunction with groceries, however, given the distance
separation from the supermarket, single trolley expeditions are unlikely
to occur.
It has a total floorspace including storeroom and amenities of
approximately 200 sqm including a 40 sqm cool room. The store is
browse-only, and contains 11 fridges containing pre-mixed drinks and
wine, and fridges adjoining the cool room containing beer and wine.
Figure 5: BWS Ellenbrook
King & Wood Mallesons PIA - BWS North Ellenbrook 21
48501879_1(b) Liquorland Ellenbrook
The Liquorland Store is co-located with a Coles supermarket inside
Ellenbrook Central. The store has a floor area of approximately 180 sqm
including a 40sqm cool room stocking cartons of beer.
The shop floor contains spirit and wine displays, and 16 fridges of wine
and pre-mixed drinks are distributed around two walls.
Figure 6: Liquorland North Ellenbrook
(c) First Choice Liquor Market, Ellenbrook
The First Choice Liquor Market is located approximately 300m east of
Ellenbrook Central on The Promenade, at the corner of Pinaster Avenue.
The premises is within a small complex containing an Aldi supermarket,
Cheesecake Shop, a veterinary clinic and gym. A shared car park
surrounds the complex.
The premises is a large format liquor store having a shop floor area and
cool room being approximately 1,050 sqm and 80 sqm respectively. The
shop floor contains 8 display racks of wine and crates of beer. The walls
contain displays of chilled and non-chilled wine, craft beer, pre-mixed
drinks, and fridges adjoining the cool-room.
Although this store is located opposite to an Aldi supermarket it is unlikely
to facilitate a single trolley expedition given customers will pass by their
parked vehicles when moving between the two stores. The premises is
placed to provide efficient regional access, given it is a destination outlet.
King & Wood Mallesons PIA - BWS North Ellenbrook 22
48501879_1Figure 7: First Choice Liquor Market, Ellenbrook
(d) Aldi Liquor
The Ellenbrook Aldi supermarket is located next to the First Choice
Liquor approximately 300m east of Ellenbrook Central. The supermarket
contains a small liquor display being approximately 35sqm in area, which
is screened from the balance of the shop This arrangement enables
combined grocery and packaged liquor purchases, but the range of
products available is very small and liquor is not chilled.
Figure 8: Aldi
King & Wood Mallesons PIA - BWS North Ellenbrook 23
48501879_1(e) BWS Aveley
BWS Aveley liquor store is located at the corner of Millhouse Road and
Egerton Drive. It is co-located with a Woolworths supermarket. The shop
floor has an area of approximately 210sqm and a cool room of 50sqm.
Two walls contain fridges for wine, beer and pre-mixed drinks, one wall
contains a spirits’ display, and two displays on the main shop floor
contain wine.
Figure 9: BWS Aveley
1.2 Distribution of Existing Premises
The Applicant instructed MGA Town Planners to prepare the following Locality
Map which clearly shows that all the existing packaged liquor stores are located
in the southern periphery of the Locality. There are currently no packaged liquor
stores in the northern part of the Locality.
It is noted that The Vines Resort and Country Club located north of the Proposed
Store is licensed to serve packaged liquor however this capability is not
advertised or promoted as the main focus of the resort is on-site consumption of
liquor and food. The public may only purchase a small range of packaged liquor
between 6am and 12pm, and on Sundays between 12pm and 9pm.
King & Wood Mallesons PIA - BWS North Ellenbrook 24
48501879_1Figure 10:Licensed Premises Locality Map
1.3 Ease of Access to the Existing Premises
The Applicant submits that it is not easy to access the existing packaged liquor
stores from the location of the Proposed Store. The following table shows the
distances by road from the Proposed Store to the existing packaged liquor stores
in the Locality:
Table 6:
Distance from
Proposed
Store
(travelling by
Premises Location Licence Type road)
Liquorland 204 The Liquor Store 3.6 kms
Ellenbrook Promenade,
Ellenbrook
BWS Ellen Stirling Liquor Store 3.5 kms
Ellenbrook Parade, Ellenbrook
First Choice Corner of The Liquor Store 3.3 kms
Liquor Market Promenade and
Pinaster Parade,
Ellenbrook
Aldi Liquor Corner of The Liquor Store 3.2 kms
Ellenbrook, Promenade and
Pinaster Parade,
Ellenbrook
BWS Aveley, 311 Millhouse Liquor Store 1.9 kms
Road, Aveley
King & Wood Mallesons PIA - BWS North Ellenbrook 25
48501879_1It is very clear from this table that the existing packaged liquor stores are a
significant distance from the Proposed Store. Those residing in the proximity of
the Proposed Store do not have a packaged liquor store within walking distance.
The closest store is BWS Aveley just less than 2km from the Proposed Store.
The remaining packaged liquor stores are all located 3-4km from the Proposed
Store by road.
1.4 Summary
The Applicant submits that it has provided probative evidence which allows the
licensing authority to make findings of fact as to what packaged liquor services
are currently provided by the existing packaged liquor premises in the Locality.
The Applicant submits that the facts show that:
There are no packaged liquor stores in proximity to the Proposed Store;
There are no packaged liquor stores in the northern part of Ellenbrook
or the Vines;
The distribution of packaged liquor stores in the Locality is very uneven.
The majority of packaged liquor licences are located in the southern
periphery of the Locality;
Existing packaged liquor stores are not accessible by foot for those
residing in the northern part of Ellenbrook or The Vines;
Existing packaged liquor stores are not easily accessible by road for
those residing in the northern part of Ellenbrook or the Vines. All existing
packaged liquor stores are between 3-4km from the Proposed Store by
road;
All existing packaged liquor stores are co-located near supermarkets;
The Proposed Store and Shopping Centre will provide the residents of
north Ellenbrook and The Vines with the level of retail amenity provided
to residents in the southern part of the Locality.
The Applicant submits that analysis of the existing licensed premises satisfies
s36B(4) by identifying that the local packaged liquor requirements cannot be met
by the existing packaged liquor premises in the Locality.
The Applicant further submits that the Proposed Store satisfies the public interest
test pursuant to s38(2) of the Act. It meets the objective of catering for the
requirements of consumers for liquor and related services, with regard to the
proper development of the liquor industry.
The north Ellenbrook area has a consumer requirement for a packaged
liquor store. There is an uneven distribution of packaged liquor stores in the
Locality. Current liquor store offerings are not easily accessible for those
residing in the northern part of Ellenbrook or The Vines. It is clear that local
packaged liquor requirements cannot be met by the existing stores.
King & Wood Mallesons PIA - BWS North Ellenbrook 26
48501879_1D. Consumer Requirement and the Proper Development
of the Industry
1 Australian Liquor Market
1.1 Changes in the way that we shop
One of the primary objects of the Act is 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.
It is submitted that ensuring that licensed venues keep up with contemporary
standards and consumer requirements is an important element of this objective.
It is well established that
"In contemporary Australian life, one-stop shopping in large suburban
shopping centres is of great importance, especially to working people".29
The Licensing Authority has continued to recognise that the juxtaposition of a
liquor store and a supermarket is a trend in accordance with the proper
development of the liquor industry.30
Roy Morgan Research reported on the factors that both men and women
consider important in purchasing alcohol.31 The top answer was 'good value'.
However, the next most popular answer provides some insight into where people
like to purchase liquor. For both men and women the location of the store 'close
to home' was important. This indicates that consumers value liquor stores which
are conveniently located. Female shoppers strongly indicated that they prefer to
shop at liquor stores which are located where they do their grocery shopping.
This factor was not as important to male shoppers, however it still rated highly in
what male shoppers look for in a liquor store.
Currently, over 60 of Woolworths' supermarkets in Western Australia have a
liquor store associated with them. This is now part of Woolworths' standard
supermarket design. The Australian consumer now expects that alcohol will be
available at the place where they do their grocery shopping.
The Australia Food & Drink Report also indicates that Australian consumers of
alcohol are increasingly favouring quality over quantity.32 The wine sub-sector in
Australia is predicted to experience the most growth in sales through to 2021
driven by the trend towards premium products.33 Beer is still the most widely
consumed alcoholic drink however beer consumption per capita in Australia has
been in decline since 2009 and this trend is set to continue in the coming years.34
The beer industry has seen a halt in sales of economy brands, with growth being
driven by the premium end products. For example, the craft beer sector has
experienced double-digit growth in recent years.35 This was confirmed in a recent
report by The Shout which found that
29 Woolworths Ltd v Director of Liquor Licensing [2013] WASCA 227 at [78];
30 See for example: Decision of the Director of Liquor Licensing A000222902 [2017] at [12];
Liquorland Gateway [LC 07/2017] at 23; Liquorland Secret Harbour [LC 06/2017] at 61;
Decision of the Director of Liquor Licensing A117210155 [2019] at 43(b)(v) .
31
Roy Morgan Research, (2015) 'Shopping for a drop: what Aussies like in their liquor store'
http://www.rovmorgan.com/findines/6093-what-aussies-like-in-their-liquor-stores-201502260413
32 Business Monitor International (2017) 'Australia Food & Drink Report Q1 2018, p16.
33 Ibid, p15.
34
Ibid at p16.
35
Ibid at p17.
King & Wood Mallesons PIA - BWS Ellenbrook North 27
48501879_1‘[t]he major category growth stories have been in premium or imported
beers, and spirits, both of which fit with a longer term trend away from
larger quantities of basic products and towards smaller quantities of
premium products.”
Figure 11
BWS carries a strong range of wines as well as popular beers and craft beers.
BWS caters to demands of the current Australian packaged liquor market for
'one-stop' shopping and quality liquor products.
1.2 BWS Customers
As discussed above, BWS caters to the demand from consumers who desire a
one-stop shopping experience or a convenient local store. The majority (59%) of
BWS customers in WA are female and this increases to 64% in the case of BWS
stores attached to supermarkets.36 Only 5% of BWS customers are between the
ages of 18 - 24 years of age.37 74% of BWS customers are between the ages of
35 - 74 years of age, indicating a more mature customer base.38
Although BWS customers are generally less likely to be premium shoppers39, the
Proposed Store will cater to the needs of both mainstream and premium
shoppers in the locality by providing a good range of mainstream liquor products
and an element of premium wines.
2 Community Survey
The Applicant engaged Painted Dog Research to conduct an online survey with
residents of the Locality. A total of 724 surveys were collected by Painted Dog
Research between 20 April and 4 May 2020. All respondents were screened to
ensure they were 18 years of age or over.
A wide range of age groups were interviewed with the gender divide being well
balanced.
A wide range of household compositions were interviewed however, the most
common were single income/dual income no kids families and young families.
This a fair reflection of the Locality based on the demographics of the area.
36 House of Brand, (2015) 'BWS customers report', p 4-5.
37 Ibid at p 6.
38
Ibid.
39
Ibid at p17.
King & Wood Mallesons PIA - BWS North Ellenbrook 28
48501879_1A summary of the results can be found below and a full copy is attached at
Annexure F.
2.1 The Results
(a) Strong Support
Overall, more than half of surveyed residents (55%) are in support of the
Proposed Store in the Locality. This is more than double the stated level
of opposition to the Proposed Store (25%).
18% have no opinion either way. This means that more than 7 in 10 of
the residents are either in support of the Proposed Store or hold no
opinion either way.
(b) Why is it a good idea?
When the respondents were asked why they would consider purchasing
from the Proposed Store, 59% specifically mentioned they are likely to
purchase from the Proposed Store because it is close to them. This
highlights again that at present there is an uneven distribution of liquor
stores in the Locality and a lack of access to existing liquor stores from
the site of the Proposed Store. Overall improved convenience/location
was the single largest theme of their responses. The ability to one-stop
shop/combine grocery and liquor purchases was another key reason for
being likely to shop at the Proposed Store.
These results indicate that there is a consumer requirement for the
Proposed Store to provide a local, more convenient place to one stop
shop for liquor and groceries.
When asked which of the features of the Proposed Store are most
appealing the following responses ranked in the top three for residents:
Convenience of having a BWS shop near where I live;
Access to competitive pricing and weekly specials;
King & Wood Mallesons PIA - BWS North Ellenbrook 29
48501879_1 Having a broad range of brands, products and styles to choose
from;
Being able to do grocery shopping at the same time / doing it all
in one trip;
The ease of parking; and
Being in a safe environment to shop.
The location of the Proposed Store within the Shopping Centre and co-
located with the Woolworths supermarket is a huge appeal to the
residents highlighting that there is a clear need for such an offering in
north Ellenbrook.
(c) Opposition
Only 25% of respondents indicated that they are opposed to the
Proposed Store.
(d) Any Concerns
When all respondents were asked if they have any concerns regarding
the Proposed Store, the majority had no concerns (54%) with the
Proposed Store. An additional 14% made further positive remarks.
(e) Current shopping trends
The survey results show that Woolworths Aveley (64%) and Coles
Ellenbrook (58%) are the top two places residents currently do their
general supermarket shopping. When asked who their preferred
shopping retailer is, almost two thirds (62%) considered Woolworths to
be their main or most preferred shopping retailer with Coles lagging well
behind at 26% and Aldi at 7%.
These results indicate that the new Woolworths at north Ellenbrook will
be a very welcome addition to those residents.
Of those respondents that have purchased liquor in the last 12 months,
47% have purchased liquor from BWS Aveley.
The combined results in relation to the current supermarket and liquor
purchasing trends of the residents indicate that the co-location of the
Woolworths and the Proposed Store at the Shopping Centre will be very
popular and is a necessary addition to ensure the residents of north
Ellenbrook have access to a one stop shop within a shopping centre.
(f) Proposed Store
Consistent with the overall support for the Proposed Store 3 in 5 (59%)
of the total respondents said they are likely to shop at the Proposed
Store.
Of those that are likely to visit the Proposed Store, 85% indicated that
they would do so as a result of the convenience and location including
the ability to one stop shop.
Of those that are likely to shop at the Proposed Store, 63% live within 1
km of the Proposed Store indicating that there is a need for the
Proposed Store in this part of Ellenbrook.
King & Wood Mallesons PIA - BWS North Ellenbrook 30
48501879_1Those who are likely to use the Proposed Store provided the following comments:
The Proposed Store provides a one-stop shopping experience which does
not currently exist in north Ellenbrook. The community survey results
indicate that there is very strong support for the Proposed Store and the
majority of respondents will use the Proposed Store. One of the key
reasons for support is the proximity of the Proposed Store to where the
respondents live and the ability to one-stop shop.
King & Wood Mallesons PIA - BWS North Ellenbrook 31
48501879_1E. How does the proposal address the minimisation of
harm and ill health?
Harm minimisation is one of the primary objects of the Act. In that regard, it is
important to note a number of established principles.
First, harm minimisation is not a more important or fundamental object than the
primary object of catering for the requirements of consumers of liquor and related
services with regard to the proper development of the liquor industry, the tourism
industry and other hospitality industries in Western Australia. Harm minimisation
is not the primary regulatory object or consideration of the Act.
Secondly, the primary object in s 5(1)(b) of the Act is to "minimise'' harm or ill-
health, not to prevent harm or ill-health. The word "minimise" is consistent with
the need to weigh and balance all relevant considerations.40
Thirdly, it is necessary to determine the likelihood of harm or ill-health occurring,
and to weigh that matter against the other objects which the licensing authority
finds may be promoted by the grant of the application.41
As the Court of Appeal was moved to observe in Woolworths Ltd v Director of
Liquor Licensing at [52]:
"On the proper construction of the Act (in particular, s 5(1), s 5(2), s
16(1), s 16(7), s30A(1), s 33 and s 38(2)), the Commission was obliged
to take into account the public interest in:
(a) catering for the requirements of consumers for liquor and related
services with regard to the proper development of the liquor
industry in the State (s5(1)(c)); and
(b) facilitating the use and development of licensed facilities so as to
reflect the diversity of the requirements of consumers in the
State (s 5(2)(a))".
Fourthly, in order properly to assess matters related to harm minimisation the
licensing authority is required to make findings about the likely degree of harm to
result from the grant of the liquor application in contrast to the existing degree of
harm.42
Fifthly, the licensing authority's findings must be made by a rational evaluation of
the probative evidence on its merits. The licensing authority must act judicially
and apply provisions of the Act to its findings and conclusions of the evidence.43
1 Current Alcohol Consumption Trends in Australia and Western
Australia
It is important to outline current trends in alcohol consumption in Australia and
Western Australia to provide background information on the likelihood of harm or
ill-health occurring.
1.1 Australia
Alcohol consumption in Australia has been on a steady decline for more than 40
years with consumption per capita in 2017-2018 continuing its decade on decade
40 Executive Director of Public Health v Lilly Creek International Pty Ltd (2000) 22 WAR 510 at [20],
41 Executive Director of Public Health v Highmoon Pty Ltd [2002] WASCA 77 at [10].
42
Carnegies Realty Pty Ltd v Director of Liquor Licensing [2015] WASC 208 at [46],
43
Woolworths v Director of Liquor Licensing [2013] WASCA 227 at [55], [59], [62] and [63],
King & Wood Mallesons PIA - BWS North Ellenbrook 32
48501879_1decline as ‘moderate consumption becomes the norm in Australia’.44 Australians
are drinking less alcohol per capita over all.45
It is believed that premiumisation is leading to a “less but better” attitude in
Australia. Also, the increased focus on health and wellness has resulted in
health-conscious consumers opting for low and no-alcohol options as we shift
towards “mindful drinking”. 46
Studies have shown that less than 15% of people in Australia actually drink in a
truly risky and harmful manner, notwithstanding reports about risky drinking
levels in Australia.47
The Australian Institute of Health and Welfare has released the following data
which highlights the decline in risky alcohol behaviour in Australia48:
The majority of Australians aged 14 years and over consume alcohol,
however the proportion of people drinking in excess of lifetime risk
guidelines has been declining and continues to decline.
Data from multiple sources indicate that there has been a decline in the
proportion of Australians exceeding the National Health and Medical
Research Council (HMRC) guidelines for lifetime risk by consuming
more than two standard drinks per day, on average.
The National Drug Strategy Household Survey (NDSHS) 2016 found that
the proportion of people aged 14 and older exceeding lifetime risk
guidelines declined significantly from 19.1% in 2013 (21% in 2001) to
18.0% in 2016.
The National Health Survey49 (NHS) reported that in 2017–18, 16.0% of
adults aged 18 and over exceeded the lifetime risk guideline, a decrease
from 17.3% in 2014-15 and 19.4% in 2011–12 (Table S2.26).
2016 NDSHS findings showed that people aged 14 or older living in
Remote and Very Remote areas of Australia are about 1.5 times more
likely than people living in Major cities to exceed lifetime risk guidelines
(26% compared with 15%) and the single occasion risk guidelines (at
least monthly) (37% compared with 24%) (Figure ALCOHOL4; Tables
S2.12 and S2.13).
2017–18 NHS results showed that adults (aged 18 or older) in Outer
regional and remote areas were 1.7 times as likely to exceed lifetime risk
44 Wine Australia (22 October 2019) ‘Trends in other alcoholic beverages’ accessed at
https://www.wineaustralia.com/news/market-bulletin/issue-179; Australian Bureau of
Statistics(09/09/2019) ‘4307.0.55.001 ‘Apparent Consumption of Alcohol, Australia, 2017-18’
accessed at
https://www.abs.gov.au/ausstats/abs@.nsf/Latestproducts/4307.0.55.001Main%20Features620
17-18?opendocument&tabname=Summary&prodno=4307.0.55.001&issue=2017-
18&num=&view=
45 Business Monitor International (2017) 'Australia Food & Drink Report Q1 2018 at p16.
46
Play Market Research (‘the biggest alcohol trends for 2020’ accessed at
https://www.playmr.com.au/blog/the-biggest-alcohol-trends-for-2020
47 Dr Anne Fox, (January 2015) 'Understanding behaviour in the Australian and New Zealand
night-time economies', p 11.
48 Australian Institute of Health and Welfare ‘Alcohol, tobacco & other drugs in Australia’ (Last
updated January 2020) accessed at https://www.aihw.gov.au/reports/alcohol/alcohol-tobacco-
other-drugs-australia/contentxs/drug-types/alcohol
49 Australian Bureau of Statistics, ‘National Health Survey : First Results, 2017-2018’ accessed at
https://www.abs.gov.au/ausstats/abs@.nsf/mf/4364.0.55.001
King & Wood Mallesons PIA - BWS North Ellenbrook 33
48501879_1You can also read
