public interest assessment - dlgsc
TRANSCRIPT
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
ALDI FOODS PTY LIMITED applicant for the conditional grant
of a liquor store licence
ALDI KARRINYUP Karrinyup Shopping Centre
200 Karrinyup Road, Karrinyup
PUBLIC INTEREST ASSESSMENT
DOC 01
Public Interest Assessment
ALDI Karrinyup
3459-2006-0941_1162785, v.2 © Lavan 2019
Table of Contents
1 Introduction 2
2 Overview of proposal 3 Consultation 6
Community demand 7
3 Applicant’s details and background 8
ALDI supermarkets 15
ALDI pricing and promotion 17
4 ALDI liquor model 19 The premises 21
Stock range 23
ALDI Exclusive Products 25
Low risk features of the proposal 27
5 Locality 28
Nature and character of local community 30
Karrinyup Shopping Centre 32
6 Section 5 37
7 Harm or ill-health – section 38(4)(a) 37
At risk groups and sub-communities 37
Social health indicators 40
Minimising harm and ill-health 43
8 Impact on amenity, quiet or good order – section 38(4)(b) 50
Outlet density 51
9 Offence, annoyance, disturbance or inconvenience – section 38(4)(c) 59
10 Tourism, community or cultural matters – section 38(4)(ca) 60
11 Other matters 62
Patronage 62 Security and crime prevention 63
12 Conclusion 66
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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 the Karrinyup Shopping Centre, 200 Karrinyup Road, Karrinyup. If
granted, the licence will trade as ALDI Karrinyup.
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 applications involved a site in
Karrinyup is a 2km 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 the
following 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 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 Karrinyup 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/
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____________________________________________________________________________
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 middle 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 41 stores operating throughout this State, with
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/
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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 and checkout section of only
approximately 35m2 within the ALDI Karrinyup 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 ALDI 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.
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.
8 This is addressed in detail in the applicant’s accompanying Legal Submissions (DOC 7).
9 https://www.aldi.com.au/fileadmin/fm-dam/Products/Groceries/Liquor/WA_Launch/ALDI_Media_Release_-
_WA_Liquor_Launch_1_.pdf
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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
following screenshots show the announcement on the ALDI Australia Facebook
page11 and the 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.
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. A fully copy of the post can be provided to the licensing authority
if required.
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2.14 Pictured below is a 3D aerial image indicative of the area proposed to be licensed in
respect of the liquor display/browse and checkout area.
2.15 This display/browse space is square and the displays themselves will form a basic U
shape as clearly seen in the image above. This design enables convenience and a
high level of surveillance of the area. The display/browse area will also comfortably
accommodate shoppers with their trolleys for added convenience.
2.16 The checkout closest to the liquor display/browse area is proposed to be licensed for
the purposes of the liquor transactions. Staff operating at this checkout will be able to
monitor all patron activity in this area.
2.17 The very small size and layout of the liquor display/browse area clearly confirms that
the liquor section is a complementary service to the supermarket and will help ensure
the area is well-controlled and supervised.
2.18 Additional details of the ALDI liquor offering are provided further on in this PIA.
Consultation
2.19 As part of its thorough preparation of this application, the applicant consulted
extensively with relevant authorities and the local community. In doing so, the
proposed liquor service has been explained and feedback sought.
2.20 The following consultation has been undertaken:
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2.20.1 In 2013 a representative from the applicant company met with officers from
the Racing, Gaming & Liquor arm of the Department of Local Government,
Sport and Cultural Industries (as it is now known) and notified the
Department in July 2015 that applications for liquor store licences would
soon be lodged. The applicant has subsequently liaised with the
Department in respect of modifications.
2.20.2 Representatives from ALDI and Lavan met with Police officers in the Liquor
Enforcement Unit on 31 July 2015.
2.20.3 Representatives from ALDI and Lavan met with the Chief Health Officer on
31 July 2015 and again with representatives from the Chief Health Officer’s
office on 12 March 2019.
2.20.4 An information and promotional flyer was distributed to households within
the Locality. A copy of that flyer is included in the Applicant’s Case (Pages 29
and 30 of DOC 8).
2.21 As referred to in the next section and also throughout this PIA, the applicant also
consulted extensively with the community through the market survey conducted by
PRG. The findings from the survey are contained in the expert’s report (DOC 8) and
show overwhelming support for the proposal and demand for the liquor service.
Community demand
2.22 The market research found that an estimated 96% of people surveyed would at least
try the ALDI store when it opened in Karrinyup.13
2.23 The market research reveals demand from the local community for the ALDI liquor
service. “[N]early eight in ten (79%) respondents who ever buy packaged alcohol
indicated that if shopping in an ALDI store which contained a liquor section, they
would purchase their take-away liquor requirements in that store. This proportion was
heightened to 83% amongst respondents who buy packaged alcohol at least once a
month.”14
2.24 The ALDI liquor display/browse area being confined within its supermarket footprint
was found to be of at least moderate appeal by 93% of respondents who are
packaged liquor buyers.15
2.25 The following extract from the PRG report (DOC 8) also supports the proposition that
the ALDI liquor concept certainly has the potential to change and enhance the
shopping behaviours of the local community:16
13 PRG report (DOC 8) at page 5
14 PRG report (DOC 8) at page 5
15 PRG report (DOC 8) at page 16
16 PRG report (DOC 8) at page 5
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The packaged alcohol purchasing pattern for this locality shows that currently the most
common pattern of buying packaged liquor is on a special shopping trip to a “walk in and
browse” store. 43% report doing all or most of their packaged liquor purchasing on a
special trip to a “walk in and browse” store, compared to 33% who shop for their
packaged liquor requirements in connection with their grocery shopping.
The finding that a further 30% report buying their packaged liquor requirements on about
half their liquor shopping occasions (creating a net of 63% who report that they do so on
at least half their grocery shopping behaviours) suggests an emerging behaviour pattern
of purchasing alcohol in conjunction with grocery shopping, though still with more
potential to expand further.
It was not surprising to find that the option of being able to buy their packaged liquor
requirements from a liquor section within the grocery store would be seen as more
convenient.
2.26 The Karrinyup community members have the opportunity to enjoy the full range of
ALDI’s offering, including its liquor service. The ALDI retailing concept is enormously
popular with shoppers all around Australia and in other countries.
2.27 Further in terms of ALDI’s popularity within the general community, in response to the
initial refusal of the ALDI Harrisdale liquor store licence application at first instance in
June 2016, a massive 8,637 people took it upon themselves to participate in an
Internet survey conducted by Nine News Perth (DOC 18) which asked: “Do you think
ALDI should be banned from selling alcohol because it’s too cheap?” Within just two
days 86% of those who participated answered “no”. This represents a staggering
7,428 people. Relevantly, the survey was conducted without any involvement from
the applicant. It was completely unsolicited.
____________________________________________________________________________
3 Applicant’s details and background
3.1 ALDI operates more than 11,000 stores across 19 countries.
3.2 The company has become a world-leading supermarket operator since it was
founded in 1913 in Germany as a family business. The following provides some
detail about the history of the organisation.17
The first foundation stone was laid in 1913 with the opening of a small food store in the
German town of Essen. It didn't take long for this little 'service store' to become a
popular place to shop.
During the '40s, an expansion program was created and more ALDI stores were
opened. In 1954, a celebration was held for the opening of the 50th store in Germany.
By 1960 ALDI had grown to a network of over 300 stores between the Ruhr Valley and
Aachen. The prosperous family business was then divided into two independent
companies: ALDI Süd - to service the South, and ALDI Nord - for the North.
17 https://corporate.aldi.com.au/en/about-aldi/aldi-history/
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'Self-service' was still a relatively new retail structure in the '60s and ALDI became the
first company in Germany to adopt this new retail concept. While customers were still
able to take advantage of the same high quality products as before, they could now
purchase them at much more competitive prices.
In 1983, ALDI Süd started chilled distribution depots and sold fresh products such as
cheese, yoghurt and sausages. Frozen products came in 1998 and were closely
followed by fresh meat. ALDI, to this day, continues to keep up with the ever-evolving
taste of the modern consumer.
3.3 ALDI’s published mission is to provide the public with “incredibly high quality at
impossibly low prices.”18 This is achieved through a highly sophisticated business
model involving a very focused selection of products and advanced levels of
systemisation and organisation designed for optimum efficiency and product control.
ALDI is dedicated to maintaining consistency in its philosophy of incredibly high
quality at impossibly low prices.
3.4 ALDI is a responsible and sophisticated corporate citizen and operates pursuant to
very high standards and key performance indicators, which include the following
published principles:19
ALDI works to ensure customers quality products at the best price. Our responsibility to
customers is intrinsically linked to the health and nutrition of all our products, and we are
constantly reviewing our range to improve its nutritional content.
We have a number of initiatives that go above and beyond mandated legal
requirements. These include:
• Providing clear product information, including easy to read nutritional and allergen labelling
• Maximising the positive nutritional benefits of our products through dialogue with independent bodies
• Minimising any potential harmful impacts of our products
• Meeting or exceeding nationally recognized standards for health and safety
3.5 Included in the Applicant’s Case is a copy of the ALDI Corporate Responsibility Policy
(DOC 12) and other ALDI published policies in respect of consumers, resources,
suppliers, operations and community (DOC 13). These policies, together with other
information in this PIA, collectively illustrate the applicant’s very high standards and
superior level of corporate responsibility.
3.6 ALDI has published the following statements in its Smarter Shopping brochure (DOC
17):
We are exacting in our pursuit of quality and work closely with all our suppliers to deliver
products that meet stringent international standards for quality, nutrition and taste. Every
single product that appears on ALDI’s shelves has been sampled, tested and signed off
by senior management before it is added to our range.
18 https://www.aldi.com.au/en/about-aldi/customer-information/
19 https://corporate.aldi.com.au/en/corporate-responsibility/consumers/
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Once it is in our stores, the rigour does not stop there. Each and every product that
appears on our shelves is tested a number of times throughout the year to ensure it still
meets the strict specifications we set at the very beginning.
3.7 ALDI’s corporate responsibility principles also apply to its partners and suppliers. For
example:
3.7.1 ALDI encouraged Australian suppliers to support and work with a range of
international ethical sourcing groups. The following was reported in
September 2017:20
Aldi has asked Australian suppliers to sign up to a range of international ethical
sourcing groups and start auditing their own supply chain and manufacturing
systems.
…an Aldi spokesperson said Aldi’s corporate responsibility principles guide Aldi
through its day-to-day actions and it is important it partners closely with its suppliers
to achieve high standards.
“In addition to requiring high social standards throughout the supply chain, we also
aim to: source raw materials responsibly, lessen our impact on the environment,
support Australian businesses and give back to the communities we operate in, and
help make healthy choices affordable for our customers,” Aldi’s spokesperson said.
3.7.2 ALDI announced in October 2017 that it will help support the delivery of the
New South Wales Government’s sustainability initiative, dubbed Return and
Earn Container Deposit Scheme. The initiative aims to halve the number of
bottles and cans thrown away in parks, beaches and waterways. In a
statement, ALDI said it was “committed” to supporting and “participating in
the largest litter reduction initiative in NSW.”21
3.7.3 Most recently, ALDI announced its goal to “reduce the amount of plastic
packaging by 25 per cent by 2025 through a number of steps, including
replacing the packaging of fresh produce to more sustainable alternatives
and phasing out unnecessary single-use plastics by the end of next year”22.
The company will work with its business partners to identify ways and
innovate solutions to reduce their reliance on plastics.
3.8 ALDI operates pursuant to a highly-evolved corporate structure (DOC 11) and very
sophisticated hierarchy whereby staff at each level are entrusted with a high degree
of responsibility and are provided with extensive and comprehensive training and
support.
3.9 ALDI’s pursuit of excellence and quality in all things is evident in the many accolades
it has won in Australia. The following paragraphs describe some of its awards just
within the past few years.
20 http://www.ausfoodnews.com.au/2017/09/11/aldi-tightens-supplier-corporate-social-responsibility-standards.html
21 https://www.insideretail.com.au/blog/2017/10/10/woolworths-and-aldi-sign-up-to-can-scheme/
22 https://www.heraldsun.com.au/business/companies/aldi-announces-plastic-bag-ban-support-will-phase-out-singleuse-
plastic-by-2020/news-story/0737f2d3da9e6547efee0a28eda09803
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3.9.1 ALDI was named the 2016 Retailer of the Year by the Australian Retail
Association.23 In awarding ALDI this prestigious title, the Australian Retail
Association noted that a key factor behind the organisation being selected
was its strong track record for creating innovative staff programs, investing
heavily in its staff with above-industry standard pay and staff development
opportunities. ALDI won the award “in recognition of its growth, influence
and market leading policies, which have seen the supermarket chain
significantly challenge the majors in its category and beyond with the
implementation of innovative sales approaches.”24
3.9.2 ALDI was also nominated Roy Morgan Research Supermarket of the Year
2016. This is the fourth time since the customer satisfaction-based awards
were first established in 2011 that ALDI has claimed this title.25
3.9.3 ALDI won several awards in BrandSpark International’s 2017 Best New
Products Awards, “taking out the top prize in 16 different categories,
including household cleaning, skin-care and fabric softener.”26
3.10 ALDI’s momentum in achievements has not stopped. Just last year alone the
company was recognised for its popularity and success in the market place:
3.10.1 In July 2018 it was announced that ALDI was voted as “the most trusted
brand” in Australia in a Roy Morgan Research survey.27 It was reported
that the success of this global retailer in the Australian market “has been
built not only on discount prices but also a reputation for reliability and
meeting the needs of consumers.” Roy Morgan Research highlighted that
important drivers of trust “include reliability, customer focus, knowledgeable
staff, ease of contact and previous good experiences with the company, in
addition to other key performance indicators.” This accolade is a testament
to ALSI’s high level of corporate social responsibility and dedication to its
customers.
3.10.2 ALDI recently rated at the top of Canstar Blue’s 2019 customer satisfaction
ratings for supermarkets, again.28
23 http://www.smartcompany.com.au/industries/retail/73746-aldi-crowned-australias-retailer-year-embarks-major-expansion-
100-new-stores/
24 https://www.retail.org.au/mediacentre/australias-top-retailers-crowned-at-2016-eftpos-ara-australian-retail-awards/
25 https://www.aldi.com.au/en/groceries/awards/roy-morgan-supermarket-of-the-year-2016/. Roy Morgan Research is
Australia’s best known and longest established market research company, https://www.roymorgan.com/about
26 http://www.ausfoodnews.com.au/2017/02/20/products-of-the-year-awards-for-2017-announced.html
27 https://www.roymorgan.com/findings/7653-aldi-most-trusted-brand-in-australia-201807060755
28 https://www.canstarblue.com.au/stores-services/supermarkets/. Canstar is Australia and New Zealand’s premier research
and expert ratings agency: http://www.canstarblue.com.au/about-canstar-blue/
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3.10.3 In October 2018, ALDI was crowned 2018 Retail Employer of the Year at
the Australian Retailers Association awards. “To be in the running, [ALDI]
had to demonstrate a strong track record across a range of areas, including
staff education, training and development, internal communication,
community support programs and Corporate Social Responsibility”.29 The
Association remarked that “ALDI have proven to be “fierce contenders” with
29 https://www.aldiunpacked.com.au/Article/October-2018/ALDI-crowned-Retail-Employer-of-the-Year
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a strong commitment to diversity, non-discrimination and support to all
employees.”30 The Association even considered ALDI to be “pioneers in
the retail sector”.31
3.11 More specifically, ALDI is also an award-winning retail liquor supplier. ALDI was
named Liquor Store of the Year 2017 at the Roy Morgan Research Customer
Satisfaction Awards.32
3.12 These awards by Roy Morgan Research recognise companies across a range of
industries that go the extra mile to please clients and customers. These awards are
“the benchmark by which customer satisfaction is measured in Australia, New
Zealand and Indonesia. Reliable, accurate and totally objective, the Australian
awards reflect the experiences of some 50,000 consumers, as aggregated in [Roy
Morgan’s] Single Source survey over 12 months.”33 There can be no question as to
the credibility of these awards and certainly no doubt that ALDI customers are
immensely satisfied with the liquor service ALDI provides.
3.13 Jason Bowyer gave the following remarks on this achievement of ALDI’s:34
At ALDI Australia, we are delighted to win the Roy Morgan Customer Satisfaction Award
for Liquor Store of the Year 2017. We believe that all our products, from our award-
winning $19.99 Monsigny Brut Champagne to our red and white wines, deliver
exceptional value, quality and consistency. It’s great to see our customers across
Australia agree.
Our success is based on the close relationships we have with our suppliers, who all
share our passion for awesome quality. Aldi partners with some of the best producers
and winemakers both in Australia and internationally, which means we can deliver
exceptional quality, value and consistency to our customers. Our partnerships with our
suppliers are focused on a desire to see the customer win with great-tasting wines at
unbeatable prices.
3.14 The title of Liquor Store of the Year 2017 follows many individual product awards that
ALDI has received locally and internationally over the years. “It recognises the
30 https://insidefmcg.com.au/2018/10/19/aldi-awarded-ara-employer-of-the-year/
31 https://insidefmcg.com.au/2018/10/19/aldi-awarded-ara-employer-of-the-year/
32 https://www.aldi.com.au/en/groceries/awards/roy-morgan-liquor-store-of-the-year-2017/
33 http://www.roymorgan.com/findings/7505-roy-morgan-announces-winners-of-the-2017-customer-satisfaction-awards-
201802201125
34 https://www.theshout.com.au/news/aldi-wins-roy-morgan-liquor-store-year/
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unique value ALDI can offer [its] customers with [its] tightly focused range,
unwavering passion for quality and longstanding relationships with local and
international suppliers.”35
3.15 ALDI certainly enjoys many accolades for its exclusive product range (DOCS 15 and 16).
The following are but few examples of ALDI’s acclaimed liquor products and awards
won over the past several years:
3.15.1 In 2014: “The Sydney International Wine Competition found a $6.99
Cabernet Sauvignon from South East Australia and a $9.99 Semillon,
blended specifically for the Aldi discount supermarket chain, to be in its top
100. And Aldi’s $4.99 Spanish Tempranillo snagged a Blue Gold award —
the equivalent of a silver medal.”36
3.15.2 In 2015: “The Sydney International Wine Competition has deemed Aldi’s
discounted wine offerings among the best of the best”.37
3.15.3 In 2016: ALDI’s Prosecco “was voted as the ‘Best Value Buy’ in Winestates
Annual Edition 2016” and “based on the frequency by which it was out of
stock during the summer months, has been a strong performing item for
Aldi”.38
3.15.4 In May 2017: “The $8 Aldi Côtes de Provence Rosé has taken out an
amazing silver medal at the International Wine Challenge – an event
dubbed ‘The Oscars of the wine Industry’, according to The Sun UK. The
award-winning drop was competing against bottles three times its price,
even beating a vintage version of the drop, which retails for over $30”39.
3.15.5 In June 2017: ALDI’s Highland Black Eight-Year-Old Scotch Whiskey
received a Double Gold prize in the Melbourne International Spirits
Competition. This product “beat some rivals valued three times more in
price”.40
3.15.6 In July 2017: ALDI’s Oliver Cromwell London Dry Gin won a gold medal at
the International Spirits and Wine Competition and was named one of the
best gins in the world.
35 https://www.aldiunpacked.com.au/Article/May-2018/Lifting-the-lid-on-ALDI’s-liquor-story
36 http://www.news.com.au/lifestyle/food/drink/six-of-aldis-cheap-wines-judged-among-best-at-sydney-international-wine-
competition/news-story/eb163e6f8d5e9b85a5522a8d1b622d50
37 Australian National Retailer, February 2015 at page 16: http://en.calameo.com/read/0003734959f4c8982c4bc
38 ALSA – IRI State of the Industry Report, March 2017 (DOC 10) at page 62
39 http://www.elle.com.au/culture/aldi-rose-is-one-of-the-best-wines-in-the-world-13255 and
http://fortune.com/2017/05/30/best-rose-wine-challenge-aldi/
40 http://www.news.com.au/lifestyle/food/drink/35-aldi-whisky-takes-out-top-prize-for-being-a-phenomenal-drop/news-
story/14ca83dce732c7f46232a283eff29110
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3.15.7 In August and November 2017: ALDI’s $6.99 bottle of One Road South
Australian Heathcoate Shiraz 2015 won the Double Gold award at the 2017
Melbourne International Wine Competition and the Gold medal at the Great
Australian Shiraz Challenge.
3.15.8 In October 2018: ALDI’s Blackstone Paddock Limited Release Chardonnay
2017 took home two awards at the 2018 Wine Show of Western Australia.41
This wine retails for just $14.99 and is exclusive to ALDI. Even at its price
point, this Chardonnay “beat a hot field of WA chardonnays that included
other more famous gold medal winners such as Vasse Felix Heytesbury,
Flametree SRS Wallcliffe, Xanadu Stevens Road and Deep Woods Estate
SV in winning the best chardonnay and best white wine of the show.”42
3.16 The various accolades described above, which are only a few examples, “[paint] Aldi
in a positive light and [they reinforce] the fact they’re offering quality products at a
value price.”43
3.17 ALDI has clearly enjoyed great success across various aspects of its organisation,
including liquor. In another online article published this year, Jason Bowyer briefly
explains some of the company’s strategies and its plans to maintain success:44
“Quality and value have always been the main focus for us. When you are focused on
the customer, it’s easier to produce wines they will like and will also perform strongly in
the show circuit. Everything we do is designed with one purpose in mind: to provide the
highest quality products at the best possible prices.
…
“We constantly look for innovation, studying consumer trends and looking domestically
and abroad for new varietals and styles. Rosé is certainly the hot topic at the moment
and we will be focusing on this category, bringing a range of styles and regions to our
customers. Early in 2019 we will launch a Soave (a dry Italian white wine) under our
Corte Carista brand.”
As well as Rosé, Aldi is looking to focus on the growing popularity of sparkling wine
which Bowyer believes is driven by customers’ desire for “aspirational products” and
“affordable luxury”. He sees these approaches as “undeniably different” and knows that
looking ahead, he relishes the challenge of taking things another step further.
ALDI supermarkets
3.18 ALDI supermarkets generally comprise a total footprint of around 2,000m2. Some are
located at shopping centres (such as at Karrinyup), while others are free-standing.
41 https://insidefmcg.com.au/2018/10/10/aldis-15-chardonnay-bags-wa-wine-award/
42 https://thewest.com.au/lifestyle/drink/aldi-chardonnay-is-best-white-wine-in-state-ng-b88983629z
43 http://www.smartcompany.com.au/industries/retail/aldi-wins-two-awards-alcohol-whats-unassuming-underdog-right/
44 https://www.theshout.com.au/national-liquor-news/aldi-puts-trust-in-affordable-luxury/
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3.19 Consistent with other ALDI stores, the Karrinyup store will comprise the following
different parts or areas, listed in order of size in terms of the approximate portion of
the total area:
3.19.1 Main public retail area (non liquor) – grocery and other supermarket items.
3.19.2 Storage.
3.19.3 Loading dock/delivery area.
3.19.4 Entrance and trolley bay.
3.19.5 Checkout.
3.19.6 Office and staff facilities.
3.19.7 Liquor display and browse area (proposed).
3.20 ALDI stores are bright and pleasant shopping environments. The following images
depict the stylish and clean appearance that can be found at the ALDI Karrinyup
store:
3.21 ALDI operates a generic store modelling concept. The size, layout, colour, product
location and stock range of each ALDI store are almost always the same. Minor
differences may occur from time to time at some stores owing to land formation, town
planning requirements or other unique particulars of the site. For example, the
entrance door may be positioned a few metres away from its usual position at a
particular location.
3.22 The standardisation of store layouts engenders familiarity for customers, enhances
shopping comfort, efficiency and convenience. It also enables customers to rely on
consistency of style, standard and overall offer. Importantly, these are key features of
the applicant’s successful superior efficiency model of operation which benefits
customers enormously and is clearly popular with shoppers.
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3.23 ALDI supermarkets contain only around 1,350 core product lines. There are limited
brand options within each different product line. For example, ALDI may offer only
two or three different brands of plain flour, rather than five or more as is commonly
stocked at most supermarkets. This enables ALDI to operate from a smaller and
more user-friendly footprint and with a more exclusive and carefully selected range.
3.24 Many of ALDI’s products are exclusive versions of mainstream big-brand name items
which are manufactured according to ALDI’s strict specifications to ensure quality and
value for money. Expressi Coffee is one of the most popular examples. The
Expressi Coffee capsule machine and coffee capsules were category winners in the
2017 Product of the Year awards.45 ALDI’s Smarter Shopping corporate brochure
(DOC 17) provides further details of ALDI’s exclusive products.
3.25 ALDI’s liquor range also includes exclusive products that can only be purchased in its
stores. The ALDI liquor offer is explained in further detail later in this PIA.
3.26 “The majority of ALDI’s exclusive brands are sourced from Australian suppliers and
we only source products from overseas when we can’t find the product, quality,
efficiency or innovation we seek, here in Australia.”46
3.27 63% of ALDI shoppers surveyed in the eastern states have said that they buy more of
the ALDI exclusive products than well-known branded products.47
3.28 ALDI supermarkets offer a wide range of quality products including fresh food,
packaged food, other consumables and various household and personal items. In
addition, every Wednesday and Saturday “special buys” are promoted by ALDI which
are specialty short-term product lines that are usually non grocery items. Flat screen
televisions, furniture, clothing, appliances, BBQs, tools, gardening equipment,
vacuums and toys are just some examples. These have proven extremely popular in
the eastern states. Some are repeated occasionally, such as ALDI’s now well-known
annual line of ski gear popular in the eastern states which customers queue for each
year.48
3.29 Included in the Applicant’s Case are copies of pages from various “special buys”
catalogues, by way of examples (DOC 21). A very large and diverse range of products
can be seen to be on offer, including the popular clothing line by Colette Dinnigan,
Dyson vacuum cleaners and a six burner BBQ.
ALDI pricing and promotion
3.30 ALDI prides itself on consistently competitive pricing across all of its product lines and
providing customers with exceptional value for money. The company’s ability to
achieve such low prices for quality products stems from its highly sophisticated
45 http://www.ausfoodnews.com.au/2017/02/20/products-of-the-year-awards-for-2017-announced.html
46 https://www.aldi.com.au/en/about-aldi/australian-made/
47 http://www.roymorgan.com.au/findings/6242-home-brand-products-have-way-to-go-with-grocery-buyers-201505202311
48 http://www.weekendnotes.com/aldi-snow-gear-sale/
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business model which focuses on operational efficiency. With reference to a 2015
online article, the following are but a few examples of aspects of ALDI’s in-store
operations which heighten productivity and reduce waste:49
3.30.1 “One of the most visible examples is trolleys. To get one you must insert a
gold coin, which is refunded when you return it. That way Aldi doesn’t have
to pay anyone to hang out in carparks retrieving scattered trolleys.”
3.30.2 Products in ALDI stores are displayed on re-usable crates, designed
specifically for ALDI. The crates fit systematically in the ALDI warehouse,
delivery trucks and supermarkets. For example, ALDI’s multi purpose
beverage trays “can go from the factory to the truck to the supermarket floor
without being unpacked. It can store 1.25L bottles or 2L bottles. You
spend less on shelf stackers if you don’t need to stack shelves.”
3.30.3 ALDI’s products “have multiple barcodes or enormous barcodes…so the
checkout person needn’t fumble and fuss to scan them.”
3.31 ALDI’s business is highly systemised and disciplined. ALDI’s shelving, storage
methods, displays, product placement and other logistical aspects are designed to
coordinate with each other to achieve optimum operational efficiencies for stocking
products and store management. As a result ALDI is able to reduce operating costs
and provide better services and facilities for its customers.
3.32 ALDI does not operate by the regular retailing method of rotating discounts each day
or week. Rather, prices are maintained at a consistently low level. This means that
customers know what to expect when shopping at an ALDI store. It also reduces
costs and resources associated with the logistics of managing specials which involves
external promotion, advertising on site, changing ticket prices, reconfiguring product
placement, adjusting till systems and other processes. ALDI does not incur all of
these costs, thereby enhancing its operating efficiency.
3.33 Consistent pricing is also indicative of consistent quality. ALDI does not downgrade
its products through heavy discounting. The applicant is driven by quality. In this
regard in terms of liquor especially, ALDI’s products very much represent value-for-
money. High quality award winning liquor items are provided at prices accessible to
most people.
3.34 ALDI’s policies and practices clearly achieve the goal of managing costs for the
benefit of customers, whilst maintaining quality. ALDI was one of the two best
performers in 2017 for gaining share in the total grocery market, up 0.8% points to
12.1%.50 Indeed “[ALDI’s] influence is growing”51 over the consumer market with its
expansion in Australia.
49 http://thenewdaily.com.au/money/finance-news/2015/05/24/secret-aldis-super-low-prices/
50 http://www.roymorgan.com/findings/7537-woolworths-increases-lead-in-$100b-plus-grocery-war-201803230113
51 http://www.ausfoodnews.com.au/2016/10/05/aldi-supermarket-shoppers-are-the-most-satisfied.html
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3.35 The Australian Liquor Stores Association noted in its March 2017 report that
Australian “shoppers have migrated towards the value messaging of Aldi”.52
3.36 Canstar Blue also made the following statement about ALDI:53
While ALDI doesn’t have the same number of stores as Coles and Woolworths, it’s
fighting back against the duopoly with often lower prices, with its own brands offering
real competition against major brands stacked by other supermarkets. ALDI also
offers something different with its ‘Special Buys’, one-off or seasonal products
ranging from specialty foods to snow gear to luxury skin cream.
3.37 At the opening of ALDI’s distribution centre in Jandakot in May 2016, former MLA Mr
Joe Francis noted that one of the biggest benefits of ALDI was going to come from
the downward pressure on prices that would be applied to the major supermarkets.54
His statement has clearly been confirmed by the evidence provided above.
3.38 ALDI’s approach to business is neatly encapsulated in its “Good Different” slogan,
which was launched in early 2017. Mr Thomas Daunt, one of the applicant company
directors, explained this campaign as follows: 55
ALDI Australia is unapologetically different –
and that’s a good thing for shoppers. We are
proud of our differences and we stand by
them wholeheartedly, as they are what allows
us to bring unbeatable value to our
customers, maintain strong relationships with
our suppliers and support our staff every day.
3.39 In many aspects, ALDI is distinctly different from alternative supermarket concepts.
Its range of products and services offer outstanding points of difference that have won
high favour with the public. The business model has huge popularity elsewhere in the
country and is proving just as popular in this State. ALDI attracts its own loyal and
faithful patrons who become regular repeat customers relying on ALDI’s consistency
of product, service and value for money.
4 ALDI liquor model
4.1 The ALDI liquor model has been carefully designed to complement the supermarket
and to provide adult shoppers with the dual benefit of ALDI’s liquor product range and
superior convenience of accessing those products whilst doing other household
shopping.
4.2 The ALDI liquor section proposed at Karrinyup has been designed based on the
eastern states model originally, which has been replicated in WA and proven to
52 ALSA – IRI State of the Industry Report, March 2017 (DOC 10) at page 14
53 https://www.canstarblue.com.au/stores-services/supermarkets/
54 http://www.watoday.com.au/wa-news/supermarket-giant-aldi-opens-60m-distribution-centre-in-jandakot-20160518-
goxuro.html
55 https://insidefmcg.com.au/2017/05/15/aldis-good-different-campaign/
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operate extremely successfully. The approximate 35m2 display/browse and checkout
area is a very modest liquor outlet by usual industry standards, but highly valuable to
customers. The particular liquor stock range itself and also as combined with the
supermarket offer, represents a significant evolution in liquor retailing in Western
Australia.
4.3 This liquor model has been developed based on ALDI’s many years of extensive
supermarket and packaged liquor retailing experience in Australia and overseas.
ALDI has been operating liquor services within supermarkets in Australia for more
than 15 years. The model has been extensively tried and tested in New South Wales,
Victoria and the Australian Capital Territory. In each jurisdiction it has proven to be
very successful and low risk. The ALDI business model and liquor area design and
layout operate with great success, are very popular with the public and have not
caused any undue issues with local governments, police or health authorities at over
300 locations in Australia.
4.4 The unique proposal, unrivalled in this State and having attracted considerable
custom in other locations, will provide the Karrinyup community with something
capable of catering superbly for the diversity of modern consumer requirements.
4.5 The Karrinyup liquor service will operate during the same hours as the supermarket,
subject to permitted trading hours under the Act,56 which the applicant seeks approval
for. If the supermarket were to operate outside of the approved licensed trading
hours, the liquor display/browse area would be clearly closed off to customers.
4.6 There are many aspects to the ALDI liquor model which differ from virtually all other
packaged liquor outlets. The following key unique aspects of this model, which will
apply at Karrinyup should the application be approved, are highlighted:
4.6.1 Combination of the ALDI Karrinyp liquor service with the ALDI supermarket.
A one-stop-ALDI shopping convenience.
4.6.2 One transaction convenience.
4.6.3 ALDI exclusive product range.
4.6.4 Its small size and location within the supermarket.
4.6.5 Absence of refrigeration.
4.6.6 Absence of external presence of the liquor section.
4.6.7 The particular level of surveillance of the display/browse area which can be
seen and monitored by staff at all times in its entirety.
4.6.8 Combined beneficial effects of the features listed above which are
supplemented by the overall manner of trade and harm minimisation
features identified.
56 Namely 8am to 10pm Monday to Saturday and 10am to 10pm on Sunday, with variations for ANZAC Day, Good Friday,
Christmas Day
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The premises
4.7 The layout of the ALDI Karrinyup supermarket is pictured below. It shows the
proposed liquor display/browse and checkout area outlined in the bold red line. This
is clearly a tiny proportion of the overall supermarket footprint.
4.8 The following artist illustrations show the proposed sectioned-off licensed area which
is to be established at ALDI Karrinyup.
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4.9 The image on the right is indicative
of how the proposed display area
will appear from within the U-
shaped space. Uncluttered and
uncomplicated, easily accessed,
light and bright.
4.10 The photographs below show other depictions of the proposed display/browse area.
4.11 It is obvious from the above images that the position, layout and small size of the
liquor display/browse section enable very clear and uninterrupted visibility of and
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supervision into this area. This assists with security, surveillance, management and
control by staff.
4.12 Thoroughly trained and suitably qualified staff members over the age of 18 will be
positioned at the nearby licensed checkout at all times, where they will be able to see
directly into the liquor area, unobstructed. Such constant and close surveillance is
rarely achievable at most other liquor stores due to their size, location of the aisles
and walk-in cool rooms. Further details of the applicant’s well developed risk
management measures, which include a heavy emphasis on staff training, are set out
elsewhere in this PIA.
4.13 The liquor area will be entirely confined
within the ALDI supermarket and have no
access or visibility from outside of the ALDI
supermarket.
4.14 Some signage external to the licensed
premises may be displayed which is modest
and states simply that there is “liquor
available in store”, but such signage will not
contain images of liquor products, references
to particular liquor products or prices of liquor
products. An example of this innocuous kind
of external signage that may be displayed is
shown to the right.
4.15 There will be no cool room or other refrigeration in the liquor area. All products will be
stocked and sold at room temperature. This unique feature further confirms the
intention that the liquor service is genuinely designed to complement the supermarket
and provide a one-stop-ALDI shop. Importantly also, the absence of refrigerated
liquor significantly reduces the risks associated with liquor sold and supplied from the
ALDI store. The lack of refrigeration will dissuade customers from buying on impulse
with a view to consuming the liquor close by or in some other irresponsible manner.
4.16 In addition to the liquor display/browse area and the adjacent checkout, the
supermarket office is also proposed to be licensed solely for the purpose of storing
licensing-related documents including the approved plans, harm minimisation policy
documents and incident register. The applicant also intends to store liquor in the
back-of-house storage area of the ALDI Karrinyup supermarket and also at the
applicant’s distribution centre situated within the Jandakot Airport commercial
precinct. No sale or supply will take place from the storage facilities.
Stock range
4.17 The ALDI range of liquor products comprises a modest selection of wines, beers,
spirits, ciders and liqueurs. The in-store range will contain a carefully selected value
for money range of approximately 95 items, many of which are award-winning.
Included in the Applicant’s Case is ALDI’s current core stock range as well as its
impressive list of awards won in respect of its liquor products (DOC 15).
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4.18 The range will vary from time to time as new products become available, in response
to customer requirements and when occasional specialty items are offered.
Generally, the ALDI liquor service will include the following:
4.18.1 60 different wines – red, white, sparkling and fortified.
4.18.2 16 different beers – full, medium and light strength.
4.18.3 15 different spirits – bourbon, brandy, gin, scotch, vodka and liqueurs.
4.18.4 4 different ciders.
4.19 ALDI’s award winning and “food-friendly” wines represent excellent value for money
for consumers and ensure that “affordable wines can still deliver the goods”.57
4.20 Included in the Applicant’s Case is a copy of pages of an ALDI catalogue showing
liquor items (DOC 22). It is a relatively modest, yet stylish and elegant advertisement
depicting quality products, including some mainstream items and some products
exclusive to ALDI. The advertisement contains product information for each item,
clearly demonstrating the quality and value-for-money propositions regarding the
ALDI range and the fact the range is indeed carefully selected and responsibly
promoted.
4.21 Within the liquor range available in any given week is a selection of new and different
liquor items which change from week to week, similar to the “special buys” offer
referred to earlier on the PIA. Approximately eight different products per week are
made available to customers until the stocks are depleted and then new ones are
brought in for customers so the product selection remains fresh and vibrant.
4.22 The applicant’s product range also includes Western Australian produced wines.
ALDI has partnered with various wine makers from the Margaret River region to
develop a selection of exclusive ALDI Margaret River region products (DOC 16). Those
items include the following by way of example:
4.22.1 Miles from Nowhere Margaret River Semillon Sauvignon Blanc 2013
4.22.2 A.C. Byrne & Co Margaret River Chardonnay 2013
4.22.3 Vinatero Margaret River Chardonnay 2012
4.22.4 Blackstone Paddock Premium Margaret River Cabernet Sauvignon 2010
4.22.5 Robert Oatley Margaret River Cabernet Sauvignon 2011
4.22.6 A.C. Byrne & Co Margaret River Shiraz 2012
4.23 ALDI’s liquor range is determined following a rigorous process of elimination trialling
and testing of products, then identifying those that offer the very best value for money
which necessitates excellent quality. The optimum range is provided to customers.
57 http://www.foodwinetravel.com.au/wine/wine-features/aldi-wine/
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Therefore, a smaller quantity of products is stocked than may be found at most other
liquor stores. The ALDI range is much more discerning and refined than most other
liquor outlets. This ensures, as referred to previously, value for money and great
convenience.
ALDI Exclusive Products
4.24 One of the most unique aspects of the ALDI liquor offering is the fact that it includes
an exclusive range of products (DOC 15), made-to-order for ALDI stores that are not
available at any other packaged liquor outlet.
4.25 The majority of ALDI’s range is unique and exclusive to ALDI. Shoppers simply
cannot access those items at any other outlet.
4.26 Many of these ALDI exclusive products have been awarded medals at prestigious
competitions where they are judged against much more expensive products. For
example, at the 2016 Sydney International Wine Competition, the following three
ALDI exclusive products (pictured below) won the competition’s highest award, the
coveted Blue-Gold Medal:58
South Point Estate 2015 Rose
($4.99)
Tudor Central Victorian 2014
Shiraz ($12.99)
Blackstone Paddock “The Player”
Barossa 2014 Shiraz ($14.99)
4.27 As a result of ALDI’s success at the event, the founder of the Sydney International
Wine Competition, Mr Warren Mason, was full of praise for Jason Bowyer, remarking
that he was “…probably better than anyone in terms of thinking of his market, given
he’s able to offer wines at $10 a bottle or less” and adding that “he has obviously got
his technique and approach right.”59
4.28 In order to become an ALDI exclusive product, the producer enters into an
arrangement with ALDI whereby it is agreed that particular brand of product will not
be distributed or provided to any other retailer. This means that ALDI exclusive
products cannot be obtained anywhere other than at an ALDI store.
58 https://www.top100wines.com/currentyear/award_categories.asp
59 http://www.news.com.au/lifestyle/food/drink/supermarket-chain-aldi-has-come-up-trumps-with-its-cheap-wines-a-winner-at-
sydney-international/news-story/a85c3072573f72e202198eda928835ae
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4.29 The ALDI exclusive products differ significantly from the Woolworths and Coles
private-label liquor ranges. Woolworths and Coles generally purchase wineries,
where possible and these products then become what are known as private-label
wines. The issue with this approach, in terms of the proper development of the liquor
industry, has been well explained by David Prestipino in his article ‘Winestein
Uncorked: ‘Local’ WA wines actually owned by Woolworths, Coles’ where he
describes the duopoly’s approach as follows:60
To avoid certain wine taxes and further boost their huge profits, Woolworths and Coles
create ‘wine brands’ (such as the Cow Bombie) under cheeky and creative (some say
misleading) names.
The wines are difficult to identify, and often undercut well-known brands, small boutique
and family wineries and those struggling to find a voice in an ever-increasing crowded
market.
Instead of Coles Reserve Chardonnay or Woolworths Bin 666 Cabernet, you have
brands like Chateau Louise (Coles) and Augustine Wines (Woolworths) for sale…wines
that are actually owned by the supermarket giants themselves.
By Developing their own private-label and exclusive wines, Coles and Woolies are now
competitors to the very wineries (and consumers) they are meant to serve.
Why should this worry wine drinkers? Because not only are we losing diversity and
competition as the duopoly increases its share of the wine market, but the relationship
hurts independent merchants across the country, who are forced to close.
If the big chains need to move a product because it is not selling, or want to replace it for
their own means, they slash the wine’s price, essentially lowering the winery’s
brand/reputation at the same time.
4.30 ALDI’s approach is different because it does not own the wineries that produce the
ALDI exclusive products and therefore, those wineries are capable of producing other
wines under a different brand to sell to other packaged liquor retailers. Further, whilst
those producers will be required to produce a product to ALDI’s standards and
specifications they will, nonetheless, give input and advice as the independent wine
maker into developing the products. The ALDI model does not, therefore, have the
same deleterious effect on the development of the liquor industry by removing
independent wine makers from the market but rather makes a valuable contribution to
it by providing independent wine makers with another channel to sell their product.
4.31 Given that the majority of ALDI’s liquor range comprises ALDI exclusive products, it
means that the ALDI offering, overall, is unique to ALDI and simply cannot be
replicated by any other liquor outlet. For the same reason, ALDI liquor services
cannot be said to duplicate any existing operations.
4.32 In this regard, ALDI’s manner of trade has similarities to the specialist cleanskin wine
store concept that first came to light in the early 2000s. Whilst some cleanskin wines
are offered at the major liquor stores, the cleanskin stores specialise in the product.
In the same manner, while ALDI does stock some products that are provided at the
60 http://www.watoday.com.au/entertainment/your-perth/winestein-uncorked-local-wines-actually-owned-by-woolworths-coles-
20151211-gllhjo.html
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major liquor stores, ALDI stores specialise in their own ALDI exclusive products which
have been extremely popular with consumers.
4.33 In this way, ALDI liquor services provide an almost entirely different range of products
from the major liquor stores and therefore, the ALDI exclusive products provide a
significant point of difference between the two offerings. The local community will
benefit greatly from having convenient access to this special service for the first time.
4.34 The local community has expressed great interest, through the market research, in
purchasing the ALDI exclusive products:61
…just over half (55%) of the packaged alcohol buyer sample would find the unique
range of products to be of high appeal to them. Note that the more frequent buyers (1+
per month) may be slightly more attracted to this unique feature, with 58% rating it as
“extremely” (28%) or “very” (30%) appealing.
A further 26% of all buyers, and similar figure of 27% for more frequent alcohol buyers,
rated this aspect as being moderately appealing, resulting in a total of 82% of all, and
85% of more frequent, buyers who found some appeal in this aspect of the proposed
ALDI packaged liquor offer.
Low risk features of the proposal
4.35 The ALDI liquor model clearly presents with a number of low risk elements, all of
which have been proven to be successful in many of its stores in other locations.
4.36 To summarise and reiterate, the following are the key harm and risk minimising
features of the ALDI Karrinyup liquor proposal:
4.36.1 Its small size.
4.36.2 The bright, open-plan layout.
4.36.3 The absence of refrigeration to help avoid impulse buying and impulse
drinking.
4.36.4 The limited stock range and volume.
4.36.5 The absence of an online delivery service.
4.36.6 The absence of bulk quantities of cheap mainstream products.
4.36.7 Its location/position confined within the supermarket footprint, under the
close supervision of the supermarket and its staff. ALDI staff will have a
clear line of sight into the liquor display/browse area at all times.
4.36.8 The lack of immediate or direct egress from the liquor area outside into the
public domain. The design and layout forces customers to enter the
supermarket and walk past the watchful eye of trained checkout staff.
61 PRG report (DOC 8) at page 22
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4.36.9 The lack of signage external to the store advertising discounted liquor
products.
4.36.10 The highly experienced and reputable operator.
4.36.11 The high level of staff training.
4.37 Importantly also, there will be none of the following:
4.37.1 Products, advertising or promotional materials designed to entice juveniles.
4.37.2 Prominent external advertising of liquor products and their prices.
4.37.3 Large volumes of cheap bulk products displayed.
4.37.4 Volumes of items refrigerated and ready-to-drink.
4.37.5 Energy drinks stocked in the liquor display/browsing area.
____________________________________________________________________________
5 Locality
5.1 As referred to earlier in this PIA, the Locality is an area of 2km radius surrounding the
application site. The image below from the DES report (DOC 9) illustrates this area and
plots the approximate locations of other major supermarkets in the vicinity.
5.2 The 2km radius area comprises the following four main suburbs:
5.2.1 Karrinyup 5.2.2 Gwelup
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5.2.3 Doubleview 5.2.4 Trigg
5.3 Small portions of Innaloo, Scarborough and North Beach fall within the 2km radius.
They have been excluded from the Locality analysis given that they represent only a
small minority of the area and would distort the assessment is included.
5.4 The Locality recorded a population of 25,020 at the 2016 Census.
Karrinyup Gwelup Doubleview Trigg Locality
2016 Census
population
9,283 4,539 8,404 2,794 25,020
5.5 The City of Stirling (City) is the local government authority for the Locality. It is the
largest by population in Western Australia. “The City is mainly urban, with over
96,000 private dwellings counted in the 2016 Census. It also has 1,780 hectares of
open space for reserves, parks, natural conservation areas and special purpose
lands, including over 600 hectares of natural bushland, 26 wetland sites and 6.5
kilometres of coastal dunes and beaches.”62
5.6 The four Locality suburbs and the City have been carefully studied and analysed in
the preparation of this PIA.63
5.7 Further in understanding the area to be impacted by the ALDI Karrinyup liquor
service, the DES report (DOC 9) contemplates the store’s likely trade area, being “a
spatially defined region around a store or shopping centre which usually accounts for
a large proportion of customers or sales”64. The report states as follows:
The trade area for ALDI Karrinyup will be influenced by:
• The drawing power of Karrinyup as a regional shopping centre.
• The spatial development pattern of Perth’s north coastal suburbs including
areas of bushland, reserves and golf courses.
• Its location on a strong east-west road with connections to other arterials.
• The location of other existing or proposed ALDI stores at Warwick and
Innaloo.
• ALDI’s low prices and unique weekly specials which attract shoppers from
further away than (say) Coles or Woolworths in the same location.
62 https://www.communityprofile.com.au/stirling
63 Some statistical information is only be available in respect of the City of Stirling. The DES report (DOC 9) also provides
data in respect of the different trade areas.
64 At page 10
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5.8 The image to the right
from the DES report (DOC
9) shows a primary
catchment (orange
outline) which mainly
comprises Karrinyup, as
well as portions of Trigg,
Gwelup and
Doubleview.65
5.9 Depending on the type of
information available or
research undertaken, the
Locality has been studied
and analysed in the
context of the main
suburbs referred to
above, the primary trade
area as well as the City.66
Nature and character of local community
5.10 The DES report (DOC 9) describes Karrinyup as “affluent” and highlights the Locality as
“an area of established and older families with high education and income levels and
white collar occupations. Unemployment rates are low and there is little public
housing in the area”.67
5.11 To gain some insight into the nature and character of the Locality, the table below
provides some statistics from the 2016 Census that relate to the demographic and
lifestyle characteristics of people living in the Locality.
Census category Karrinyup City of
Stirling
Locality
Average
Western
Australia
Median age 39 36 39 36
Married 53.6% 46.4% 54.5% 48.8%
Never married 31.2% 36.9% 31.3% 35.2%
65 At page 9
66 For example, some statistics may only be available in respect of the City of Stirling. The DES report (DOC 9) also provides
data in respect of the different trade areas.
67 DOC 9 at page 25
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Language (other than
English) – top
response
Italian Italian Italian
(generally)
Mandarin
Occupation (top
response)
Professionals
(32%)
Professionals
(26.7%)
Professionals
(32.4%)
Professionals
(20.5%)
Worked full-time 56.1% 57.0% 56.2% 57.0%
Worked part-time 33.8% 31.3% 33.6% 30.4%
Median weekly
personal income
$828 $766 $924 $724
Dwelling structure (top
response)
Separate
house
(84.3%)
Separate
house
(55.0%)
Separate
house
(80.3%)
Separate
house
(79.1%)
House owned outright 36.4% 29.6% 35.0% 31%
House owned with a
mortgage
39.1% 34.3% 40.0% 39.7%
Median mortgage
repayments
$2,462 $1,998 $2,485 $1,993
Renting 20.6% 32.6% 20.2% 28.3%
Median rent $420 $350 $451 $347
5.12 The average person living in the Locality can be described as follows based on the
above statistics:
5.12.1 Aged 38.
5.12.2 Married.
5.12.3 Working full-time as a professional.
5.12.4 Earning almost $200 more than the average State income.
5.13 Other observations based on the above statistics include the following:
5.13.1 Of those residents that speak a language other than English, most of them
speak Italian.
5.13.2 The most common form of tenure in the Locality is to own a home with a
mortgage. Median mortgage payments of houses in the area are well
above the State average, reflecting a high-value property market.
5.13.3 Only 20.2% of residents within the Locality are renting which is significantly
lower than the State average.
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5.14 To support some of the 2016 Census data, the following extracts from the DES report
(DOC 9) illustrate the nature and character of the primary trade area of the ALDI
Karrinyup store:68
• Detached houses account for just two-thirds of all dwellings, compared to 77%
across Perth. Dwelling densities are higher in the western part of the primary in
the beachside suburbs. This influences the higher proportion of
townhouses/semi-detached dwellings in the primary (29% of vs Perth 16%).
• 31% of dwellings are fully owned, marginally higher than the Perth average (29%).
A similar 31% of dwellings are rented (Perth 28%).
• The area has a slightly older population profile than the Perth average, with a
lower proportion of residents under 20 years old.
• This is an affluent area with average individual incomes 26% above the Perth
average and household incomes 18% higher.
• The proportion of white collar workers is much higher than the Perth average
(60% vs Perth 48%) as is the proportion with a tertiary qualification (32% vs 23%).
The profile of the primary trade area is one of long-established families with older children.
This is generally an affluent area, where adults are well-educated in white collar occupations.
Townhouses/semi-detached dwellings are focussed along the coastal area.
5.15 The addition of the ALDI liquor offering at its new Karrinyup supermarket will
contribute in a unique way to the choice and diversity in the Locality for the benefit of
the local consumer community. It is entirely appropriate that the Locality be able to
enjoy and access the valuable ALDI liquor service, just as ALDI shoppers in many
other locations can.
Karrinyup Shopping Centre
5.16 Karrinyup Shopping Centre opened in 1973, “at a time of rapid urban development of
Perth’s middle and northern suburbs”69. It is a “vibrant regional shopping centre
located north of Perth…in close proximity to some of Western Australia’s finest
beaches and coastal strip suburbs”70.
5.17 The regional status of the Karrinyup Shopping Centre arises from its large size, with a
gross lettable area of around 57,000m2 and 3,300 car bays.71 The following image
depicts a current aerial view of the Shopping Centre site.
68 At page 15
69 DES report (DOC 9) at page 6
70 https://www.ampcapital.com/au/en/assets/shopping-centres/karrinyup
71 https://www.ampcapital.com/au/en/assets/shopping-centres/karrinyup
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5.18 Since its opening, two phases of small extensions were made in the 1980s with a
major extension in 1996, increasing it to its current size. Karrinyup Shopping Centre
is described as “Perth’s premier retail venue north of the river”72 and currently boasts
approximately 268 specialty stores and Myer, David Jones, Woolworths and Big W as
its current major tenants.
5.19 The prominence of Karrinyup Shopping Centre is also attributed to its strategic
location on Karrinyup Road. Traffic data reveals that over 30,000 vehicles travel
along this arterial route (west of Huntriss Avenue) per day, alongside the ALDI
Karrinyup site.73 Bus services operating along Karrinyup Road extend to the suburbs
of Warwick, Stirling and Scarborough and to the Warwick and Stirling railway
stations.74
5.20 The retail, entertainment and dining offering will be expanded and diversified
significantly with the $800 million redevelopment that is currently taking place at
Karrinyup Shopping Centre. Construction commenced in November 2018 and is
expected to be completed at the end of 2021. This major project will introduce a suite
of upgrades to the centre, including the following:75
5.20.1 Large-format international retailers.
5.20.2 High quality fashion retailers.
72 https://www.ampcapital.com/au/en/assets/shopping-centres/karrinyup
73 Metropolitan Traffic Digest 2013/14 – 2018/19
(https://reportingcentreresources.mainroads.wa.gov.au/public/data/xrc4111/AAWT/traffic_digest.207.pdf) at page 26
74 DES report (DOC 9) at page 7
75 https://www.karrinyupcentre.com.au/development
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5.20.3 New separate precincts for alfresco dining, fresh food and entertainment.
5.20.4 External landscaped community space with a kids’ play area.
5.20.5 94 high-end residential apartments in the eastern side of the development.
5.21 The following is a snapshot of the vision behind the Karrinyup Shopping Centre
redevelopment:76
Already much-loved and highly successful, Karrinyup has a loyal shopping community who
are ready to see their centre evolve. The vision for the development is to respond to the
feedback and insights of our customers and the community by delivering a landmark
destination with the highest-quality retail and lifestyle offering that merges both the physical
and digital world to create a more customised and seamless shopping experience.
5.22 Artists’ impressions of the redeveloped Centre are provided below:77
76 https://www.karrinyupcentre.com.au/development
77 https://www.karrinyupcentre.com.au/development/artist-impressions-floorplans
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5.23 The design and aesthetics of the redeveloped shopping centre are inspired by the
coastal aspects of Karrinyup and the Locality, as described in the following extract:78
Our creative designers and architects have taken inspiration from all of the things that make
Karrinyup special – our unique location between the city and the sea, our love of Western
Australia’s relaxed beach culture and our local coastal environment. The design of our new
fashion loop takes inspiration from the water, in the shape of the ceilings and skylights which
take advantage of our bountiful natural light. Inspired by our local beaches like Trigg,
Scarborough and North Beach, natural timbers are featured throughout to bring the feeling of
the relaxed, coastal lifestyle we love right into the heart of Karrinyup.
5.24 ALDI Karrinyup is expected to open mid 2021. The floor plan below identifies the
location of the new supermarket.79 That area is currently occupied by a parking deck
and freestanding KFC and Hungry Jacks stores. These will soon be demolished to
make way for ALDI. There will be escalators and travelators providing shoppers with
easy and direct access from the new basement and roof-top parking levels to the
supermarket.
78 https://www.karrinyupcentre.com.au/development/artist-impressions-floorplans
79 https://www.karrinyupcentre.com.au/development/artist-impressions-floorplans
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5.25 The addition of ALDI to Karrinyup Shopping Centre is an important component of the
redevelopment. The new ALDI store will form part of a new fresh food precinct which
will also include existing tenant, Woolworths and a new Coles supermarket. This
expanded offering will increase the choice and competition considerably, for the
benefit of consumers. As reported:80
AMP Capital’s Divisional Development Manager – WA, Scott Nugent said that the fresh food
precinct will provide customers with greater variety.
“The new fresh food precinct will offer customers a diverse foodie experience, with
supermarkets, local growers and special events. With abundant natural light and a village-
style atmosphere, the precinct will be our customers’ go-to for fresh produce and healthy food
options.”
“Attracting Coles and ALDI, along with other exciting retailers and specialty stores, shows that
there’s great interest and growth in the area. The completed centre will offer customers a
more vibrant and convenient shopping experience,” said Mr Nugent.
…
Set to be come a vital hub for customers, the fresh food precinct will remain bustling as the
centre transitions from day to night, seamlessly connecting with outdoor dining and
entertainment options.
5.26 The significant capital investment into the redevelopment of Karrinyup Shopping
Centre signifies the confidence of the owner and others in the growth of the Locality.
The ALDI store will be ideally positioned in a prominent location at the site, facing
Karrinyup Road.
___________________________________________________________________________
80 https://perthleasing.ampcapitalretail.com.au/amp-capital-announces-coles-and-aldi-as-part-of-karrinyup-development/
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6 Section 5
6.1 In accordance with the Act and the PIA Policy, the applicant has had regard for the
matters outlined in section 5 of the Act.
6.2 Comprehensive submissions addressing section 5 matters are contained throughout
this PIA and also in more detail in the applicant’s Legal Submissions (DOC 7).
____________________________________________________________________________
7 Harm or ill-health – section 38(4)(a)
7.1 The applicant has considered the various risk factors and indicators of the Locality
that are contemplated in the PIA Policy. These include “at risk groups and sub-
communities”, the incidence of alcohol-related hospital presentations and crime.81
7.2 Evidence and submissions in relation to these matters are addressed in detail in this
section of the PIA. Collectively, they reveal no stand-out risk factors of the Locality
such that there should be any concern surrounding the grant of the licence. In fact,
many low risk indicators are clearly apparent in this case.
7.3 Any potential negative impact of the licence should be considered in light of the low
risk features of the ALDI liquor model, which are described throughout this PIA. This
proposition is supported by the Liquor Commission’s finding in relation to the
application for ALDI Harrisdale82:
There is nothing to suggest that the granting of the licence will result in an increase in
harm and ill-health. The small size of the proposed premises, the nature of its operation
and the limited number of products are significant factors in reaching this conclusion.
At risk groups and sub-communities
7.4 With reference to the 2016 Census statistics83, the applicant has studied the at risk
groups and sub-communities in the Locality, as referred to in the PIA Policy and set
out in the following table and sub-paragraphs.
7.5 The following table shows a comparison between the statistics for Karrinyup itself, the
Locality average84, the City of Stirling and Western Australia in respect of some of
those groups. The comparison provides context for the Locality to be analysed and
properly considered.
81 PIA Policy
82 ALDI Foods Pty Ltd v Director of Liquor Licensing LC 09/2017 (ALDI Harrisdale) [38(b)]
83 http://www.abs.gov.au/websitedbs/D3310114.nsf/Home/2016%20QuickStats
84 The Locality Average is calculated by adding the relevant statistical data for each of the three key suburbs (Karrinyup,
Gwelup and Doubleview) and dividing the total by three.
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Census category Karrinyup Locality
Average
City of
Stirling
Western
Australia
At risk group: “Children and young people”
Persons aged 14 and younger 21.5% 20.2% 16.9% 19.2%
Persons aged 19 and younger 28.2% 26.6% 22.0% 25.3%
Average age of persons in
suburb
39 39 36 36
At risk group: “Aboriginal people and communities”
Aboriginal and Torres Strait
Islander people
0.6% 0.7% 1.1% 3.1%
At risk group: “Families”
Couple family without children 35.8% 37.5% 40.7% 38.5%
Couple family with children 51.5% 51.2% 42.8% 45.3%
One parent family 11.2% 10.0% 14.2% 14.5%
Other family 1.4% 1.4% 2.3% 1.7%
At risk group: “Migrant groups from non-English speaking countries”
Australia as country of birth 68.0% 68.9% 55.3% 60.3%
Top three responses as to
ancestry
English
Australian
Irish
English
Australian
Irish
(generally)
English
Australian
Irish
English
Australian
Irish
English only language spoken
at home
83.5% 83.8% 66.3% 75.2%
Households where a non
English language is spoken
15.7% 15.3% 28.7% 19.4%
At risk group: “People in low socio-economic areas”
Worked full-time 56.1% 56.2% 57.0% 57.0%
Worked part-time 33.8% 33.6% 31.3% 30.0%
Unemployed 5.4% 5.6% 7.3% 7.8%
Median weekly income –
personal
828 $924 $766 $724
Median weekly income –
family
$2,463 $2,586 $2,001 $1,910
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Census category Karrinyup Locality
Average
City of
Stirling
Western
Australia
Median weekly income –
household
$2,102 $2,159 $1,563 $1,595
Earning more than $3000
gross weekly income
33.3% 34.3% 20.9% 19.2%
7.6 The information above reveals the following positive risk assessment factors of the
Locality, in accordance with the PIA Policy:
7.6.1 The Locality population is quite mature given the higher median age,
notwithstanding that there is a large proportion of families with children.
7.6.2 There is a very small Aboriginal and Torres Strait Islander population.
7.6.3 Although the exact non-English speaking population could not be identified,
the statistics in respect of languages and ancestry suggest that the Locality
is not overwhelmed or dominated by non-English speaking migrants.
7.6.4 The majority of the Locality is gainfully employed and earning substantially
above the State average income levels. This information indicates a very
socio-economically advantaged area, as is supported by other information
elsewhere in this PIA.
7.7 Further in terms of socio-economic status, each of the suburbs score a 10 out of 10
decile on the SEIFA85 Index of Relative Socio-economic Advantage and
Disadvantage. This means that the suburbs that form the Locality can be considered
as being amongst the most advantaged suburbs in the State.
7.8 The following sub-paragraphs provide information as to other at risk groups
contemplated in the PIA Policy that cannot be quantified by Census data:
7.8.1 As to “people from regional, rural and remote communities” – the Locality is
well within the metropolitan area and is only approximately 15 minutes from
the Perth CBD. It cannot, therefore, be considered to be a rural or remote
community.
7.8.2 As to “mining communities or communities with a high number of itinerant
workers” – the Locality is not a mining community nor is it known to attract
large groups of itinerant workers. It was not possible to identify actual
numbers of itinerant workers, although it is presumed that some would exist
in the area.
7.8.3 As to “communities that experience high tourist numbers” – the suburb of
Karrinyup is not a known tourist destination within the State. The coastal
85 Socio-Economic Indexes For Areas
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areas of the Locality can be presumed to attract some visitors. Some
tourists would no doubt visit the Shopping Centre from time to time,
although it is not considered a tourist destination per se and tourist numbers
were not available for the Shopping Centre.
7.9 It is clear that the Locality presents almost no risk factors from the information above.
Any negative issues are negligible at best and are not unusual or particularly adverse
in terms of at risk groups and sub-communities. The Karrinyup Locality should not be
denied the opportunity to benefit from ALDI’s high quality, value-for-money offering
that is very popular elsewhere. The community is entitled to enjoy all that ALDI has to
offer, including liquor.
Social health indicators
7.10 The following table contains offence data published by WA Police86 in respect of the
individual suburbs within the Locality between the financial years of 2009/10 and
2017/18. Importantly, this publicly available data does not distinguish which offences,
if any, are alcohol-related or which resulted in proven crimes. It can, therefore, only
serve as a broad and general indicator of crime in the Locality.
2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18
Karrinyup 1,117 572 615 634 793 874 705 652 715
Gwelup 125 134 199 208 169 197 146 183 264
Doubleview 460 506 577 596 636 967 650 699 748
Locality
total 1,702 1,212 1,391 1,438 1,598 2,038 1,501 1,534 1,727
7.11 The data above is illustrated in the following graph:
86 https://www.police.wa.gov.au/Crime/CrimeStatistics#/start
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7.12 The red dotted line through the Locality total data represents the trend in offences in
the Locality over the time period analysed. It is acknowledged that crime is
increasing, although a further examination of the crime data shows that this is largely
due to a greater number of reports of “fraud and related offences” since 2015/16. For
example, between 2015/16 and 2017/18:
7.12.1 There was a 137% increase in those offences reported in Karrinyup.87
7.12.2 There was an 886% increase in those offences reported in Gwelup.88
7.12.3 There was a 246% increase in those offences reported in Doubleview.89
7.13 The graph also shows a noticeable increase in offences from 2013/14 to 2014/15,
which could largely be due to a similar trend in Doubleview. An analysis of the crime
statistics for Doubleview reveals that the only type of offence showing a spike was
“fraud and related offences”, which increased from 23 to 428 (1,760%90) within that
period.
7.14 It is observed that Karrinyup and Doubleview have a higher number of offences over
the time period analysed compared to Gwelup. This is most likely attributed to the
fact that Karrinyup and Doubleview have both had larger population sizes than
Gwelup.91
7.15 From the above analysis, there is nothing to suggest that the Locality experiences a
concerning level of crime relevant to the ALDI proposal. The applicant will
nevertheless implement its tried and tested safety and security measures at ALDI
Karrinyup, just as it does with all its other stores. These measures are addressed
elsewhere in this PIA and will ensure the risk of any crime associated with the
premises is minimised. In addition to those measures, the likelihood of the liquor
service contributing to alcohol related crime is reduced by the following mitigating
factors:
7.15.1 Small nature of the liquor proposal.
7.15.2 Simple and open layout of the liquor area.
7.15.3 Close staff surveillance achieved by the simple and open layout.
7.15.4 Location within the confined safety of the supermarket building.
87 [(116-49) ÷ 49] x 100
88 [(69-7) ÷ 7] x 100
89 [(97-28) ÷ 28] x 100
90 [(428-23) ÷ 23] x 100
91 The 2016 Census records the population as follows: Karrinyup = 9,283 people; Doubleview = 8,404 people; Gwelup =
4,539 people. Records from other Census years also show that Karrinyup and Doubleview have had larger population sizes
than Gwelup.
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7.15.5 Lack of external frontage.
7.15.6 Location of the liquor area adjacent to the checkout and therefore, under
constant close staff surveillance and supervision.
7.15.7 Absence of refrigeration, which removes the opportunity for impulsive
desires to steal liquor for immediate consumption.
7.15.8 Lack of a walk-in cool room, which is ordinarily hidden from staff view,
providing cover and convenience for would-be criminals.
7.15.9 Installation of CCTV surveillance throughout the supermarket, including the
proposed licensed area.
7.16 The Department of Health’s Drug and Alcohol Office Surveillance Report 2014
provides some useful information as to alcohol-related hospitalisations. The extract
below from the report contains statistics in respect of the relevant statistical local area
in the City and reveals that it experiences similar rates of alcohol-related
hospitalisations compared with the corresponding State population between 2007 and
2011.92 This has a neutral effect on the risk profile of the Locality from an alcohol-
related harm and ill-health perspective.
7.17 The evidence above suggests that the level of alcohol-related ill-health in the Locality
is, on balance, average. The ALDI liquor service as proposed at Karrinyup is most
unlikely to contribute to the moderate rate of alcohol-related ill-health in the Locality.
To reiterate, the low risk proposal involves a careful selection of less than 100
different products to be sold from a tiny section of the supermarket. Other harm
minimising strategies are detailed in the next sub-section of this PIA.
92 ‘Alcohol-related hospitalisations and deaths in Western Australia, Regional Profile: North Metro’ at page 20. As at the date
of this PIA, the 2014 report is understood to be the most current version although a copy is no longer available online and so
no website link has been provided. However, a copy may be provided to the licensing authority if requested.
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Minimising harm and ill-health
7.18 The applicant company is a highly experienced and sophisticated operator when it
comes to retailing liquor products. The licensing authority in New South Wales has
found ALDI to be a good operator in granting around 150 licences to it. Even though
some licence applications have been refused, the overwhelming majority have been
approved.
7.19 Harm minimisation from the sale and supply of liquor is very familiar to ALDI and at
the height of operational policies. ALDI has been successfully implementing
measures that minimise harm and ill-health at its large number of existing liquor
outlets for many years. Its liquor store model has been much tried and tested and
proven to be entirely positive.
7.20 Included in the Applicant’s Case are various operational policy documents (DOC 6 and
13) which the applicant has developed with the benefit of extensive experience. The
practises and procedures in those documents will be implemented to facilitate
compliance and to create a business that both endorses and encourages responsible
drinking.
7.21 One of the main strategies is to establish and maintain the low risk ALDI liquor model
that is detailed in this PIA. In particular, the licensed area will be relatively very small
with no refrigerated products. The licensing authority in New South Wales has found
that “the small scale of the proposed licensed area is a mitigating factor”.93
7.22 The design and position of the licensed area will enable a heightened level of visibility
by staff and control. The lack of refrigeration reduces the likelihood and motivation of
customers purchasing liquor to drink immediately outside or within the vicinity of the
store or at any nearby open public spaces. This specifically reduces the likelihood of
customers making impulsive or irresponsible purchases.
7.23 In terms of the liquor items themselves:
7.23.1 The carefully selected range of liquor stock will include only a small number
of cask wines and pre-mixed spirit drinks which are commonly known to be
higher risk items.
7.23.2 Products will not be labelled or promoted with emotive titles that could
potentially encourage rapid or excessive consumption.
7.23.3 Low and mid-strength products will be available at the store.
7.23.4 Establishing the liquor area amongst food and groceries promotes
responsible consumption of liquor which is a well established principle of
harm minimisation.
93 ALDI Vincentia dated 4 April 2016 [119] - https://www.liquorandgaming.justice.nsw.gov.au/Documents/ilga/decisions-of-
interest/Decision-ALDI_Vincentia-Application-PLL-Granted-040416.pdf
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7.24 ALDI has also factored advertising and promotion into its harm minimisation
strategies. Flamboyant and highly suggestive advertising posters, encouraging rapid,
excessive or juvenile drinking will not be displayed. Nor does ALDI advertise discount
liquor prices for certain periods as such “sales” may encourage customers to
purchase more liquor than they otherwise would have for fear of missing out on the
special.
7.25 Placing a heavy emphasis on staff training and management is another key strategy
to ensuring policies and practices are implemented and laws are complied with. ALDI
is a market leader in terms of staff training and development. Its impressive approach
in this regard is detailed in the following sub-paragraphs.
7.25.1 ALDI was recognised for its efforts in this area of its operations when it was
named as the Retailer of the Year for 2016 and 2018 by the Australian
Retail Association. Its continuing investment in its staff with above industry
pay rates, development opportunities and its supportive approach to staff
were cited as being highly influential.94 The company explains further on
this point:95
The emphasis we place on training and continuous improvement is one of
the reasons that people really value working at ALDI. The ALDI Academy
team work predominantly in the people space including recruitment,
performance and learning and development across all areas of ALDI
Australia. Whether it’s leadership training for our management teams,
training our warehouse staff in receiving procedures or providing
operational equipment training for the people running our stores, the team
collaborate with subject matter experts inside and outside the business to
develop solutions that allow our people to thrive in any role.
7.25.2 The West Australian newspaper reported that ALDI is “luring university
graduates with what could be the highest graduate salaries on offer in WA”,
which was said to be “[t]rying to get hold of the best people at management
level”.96 ALDI has a strong drive for quality personnel accompanied by high
standards and expectations for staff. These attitudes and policies
contribute to a heightened level of risk management through the whole
organisation.
7.25.3 The applicant invests considerable time, effort and resources into staff. In a
2016 media article, ALDI’s induction and ongoing training regime was
discussed in the following terms:97
94 http://www.smartcompany.com.au/industries/retail/73746-aldi-crowned-australias-retailer-year-embarks-major-expansion-
100-new-stores/
95 https://www.aldiunpacked.com.au/Article/October-2018/ALDI-crowned-Retail-Employer-of-the-Year
96 https://thewest.com.au/news/wa/aldis-cash-lure-for-graduates-ng-b88428485z
97 http://www.hcamag.com/hr-news/how-aldi-staff-learn-it-link-it-live-it-222306.aspx
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On first joining the company, all new employees receive comprehensive
induction training’, the spokesperson said. Aldi also strives towards fostering
career development.
We offer various educational and training initiatives including traineeships, a
diploma of management for store and warehouse staff, and coaching and
leadership training for management.’
Newly hired employees will also be given access to the Aldi Academy
website during on-boarding – a platform which provides information about
Aldi as well as learning pathways tailored to each specific role.
This learning pathway has been custom designed to teach, guide and
support new employees throughout their journey at Aldi, giving them all of
the necessary skills to complete their role.
7.25.4 Every ALDI staff member is required to undertake detailed internal training
and an induction programme, which will certainly apply for staff at the ALDI
Karrinyup store. This involves education on a wide variety of facets of the
business and includes liquor product knowledge. To help ensure high
standards are achieved at all times, all ALDI staff are employed on a
permanent basis.
7.25.5 The applicant will ensure all staff at the ALDI Karrinyup store are properly
trained as to their responsibilities under the Act, the licensing authority’s
policies, matters of safety and all other laws and regulations applicable to
the proper conduct of the business.
7.25.6 The store will be adequately staffed at all times with appropriately trained
and knowledgeable people. In addition to having sufficient numbers of
approved managers at all times, other part-time and full-time staff will also
be employed. In particular, at least one approved manager will be at the
store at all times.
7.25.7 All staff wear a smart uniform bearing the company logo, as pictured
below.98 Their presentation is considered by the applicant to be important
both in terms of upholding its image and also in terms of portraying a
professional and responsible approach to the business.
98 https://www.aldicareers.com.au/Careers
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7.25.8 Notably, 73% of the survey respondents considered ALDI’s strong RSA
policy, which is a fundamental aspect of the ALDI approach to liquor
retailing, as a “highly appealing attribute”.99
7.26 Another harm minimising element of the ALDI model is the focus on quality of product
and value-for-money propositions and not just price. The applicant invests
enormously in providing customers with high quality products that offer genuine
value-for-money. Many of its liquor items have been awarded accordingly. This
approach is entirely consistent with consumer trends, summarised as follows:100
Australia’s near $17 billion retail liquor market grew by 3.3% in 2016, which amounted to
$546 million. Although consumers are opting for both premium and value priced liquor
products across categories, value growth (+ 3.3%) again outpaced volume growth (+
1.5%). It signals a retail liquor industry that has adapted to consumer’s changing
drinking habits, needs and preferences with added value products and in-store
merchandising. It is also evidence of “choice premiumisation” as more drinkers opt for
quality over quantity, and a superior taste experience rather than just the lowest price.
7.27 In respect of the issue of juveniles, very strict policies will apply. ALDI is very aware
of the fact that juveniles will be in the supermarket from time to time, some of whom
may be unaccompanied.
7.27.1 The store layout and security systems will facilitate and ensure a constant
and high degree of surveillance over the liquor area and checkout to
safeguard the proper management of juveniles. ALDI has successfully
managed this issue at its existing stores elsewhere in Western Australia.
7.27.2 No liquor will be sold or supplied to juveniles or anyone who is suspected of
trying to obtain liquor for a juvenile. The applicant will participate in the “ID
Under 25” policy. The licensee and its staff will go beyond the requirement
to ask customers suspected of being under the age of 18 to prove their age
and in fact ask all customers suspected of being under the age of 25 for
age verification.
7.27.3 The applicant will operate under a strict policy, which will be taught to and
perpetuated with its staff, whereby liquor is not sold or supplied to anyone
whom it is suspected might give the liquor to a juvenile, including guardians
and parents.
7.27.4 Juveniles observed to be loitering near the liquor area will be asked to
move on and no juveniles will be permitted in the licensed area unless
accompanied by a responsible adult.
7.27.5 Lollies or other items commonly known to attract the attention of juveniles
will not be stocked in the liquor display/browse area.
99 PRG report (DOC 8) at page 6
100 ALSA-IRI State of the Industry Report, March 2017 (DOC 10) at page 5
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7.27.6 The liquor area will be subject to a high level of surveillance and security
from the relevant checkout.
7.27.7 Unaccompanied juveniles who may be in the supermarket from time to time
will be directed to a non-licensed checkout to make their purchase.
7.28 A clear example to confirm ALDI’s high standards in its liquor service is when the
company came under scrutiny from the public for the strictness of its approach to
liquor and juveniles. Some stores in New South Wales have refused service to adults
because staff have witnessed a juvenile touching the liquor items, even where they
have touched the items simply to stop them from falling over in a trolley.101
7.29 It is relevant that adult consumers have felt comfortable shopping in an ALDI liquor
area with their children as clearly depicted in the images below taken recently at one
of the busy operating ALDI stores in WA with a liquor section.102
101 http://www.news.com.au/finance/business/retail/aldis-strict-underage-alcohol-policing-leaves-shoppers-high-and-dry/news-
story/c7beaa2c4b8e1f0345b3545c98c7789c
102 Personal details have been blacked out for privacy reasons. Full images available to the licensing authority if required.
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7.30 As was presented by the applicant to the State Government in South Australia (DO 20),
ALDI has made careful and calculated decisions in respect of its liquor proposal
based on considerable research, experience and expert advice. The information has
“guided [ALDI’s] attitudes regarding the sale of alcohol in supermarkets” and has
revealed the following:103
7.30.1 “There is no evidence linking increased availability of alcohol and increased
consumption. Consumption of alcohol per capita has been declining over
the past decade in Australia despite an increase in the number of outlets of
sale [Australian Bureau of Statistics. (n.d.). Apparent Consumption of Alcohol. Retrieved January
14, 2016, from http://www.abs.gov.au/ausstats/[email protected]/Lookup/4307.0.55.001main
features32010-11]”.
7.30.2 “Restricted sale of alcohol in supermarkets can have a positive social effect
by ensuring alcohol is viewed as a complement to food”.
7.30.3 “Safe consumption initiatives can assist alcohol retailers in ensuring harm is
minimized to at-risk groups”.
7.31 The paper submitted by ALDI to the South Australian Government (DOC 20) also
relevantly contained the following:104
According to published research, there is no link between the number of liquor outlets
and the size of the liquor market. ABS statistics show that, since 2008, per capita
consumption of alcohol has reduced from 10.75 litres (2008) to 9.71 litres (2014), a
national reduction of approximately 10% over that period. [Australian Bureau of Statistics.
(n.d.). Apparent Consumption of Alcohol. Retrieved January 14, 2016, from
http://www.abs.gov.au/ausstats/[email protected]/Lookup/4307.0.55.001main features32010-11].
At the same time, the number of bottleshop licenses in Australia has increased from
5315 to 6421. [Australian Liquor Stores Association]
7.32 With this intelligent background ALDI has developed a liquor model that is both
responsible and required by consumers.
7.33 In New South Wales, notwithstanding that alcohol is sold in grocery stores and that
has been occurring for many years, including at hundreds of ALDI stores, there has
been a “decrease in daily alcohol use [which] occurred between 2011 (9.8%) and
2015 (7.5%).”105 Further, “[i]n 2014, about two-thirds of high school students (65.1%)
reported ever having an alcoholic drink. The proportion of high school students who
drank alcohol in the last 12 months decreased substantially between 2005 (63.5%)
and 2014 (43.7%).”106
103 At pages 3 and 13
104 At pages 3 and 13
105 http://www.health.nsw.gov.au/hsnsw/Publications/chief-health-officers-report-2016.pdf at page 6
106 http://www.health.nsw.gov.au/hsnsw/Publications/chief-health-officers-report-2016.pdf at page 6
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7.34 The graph below shows the frequency in which people in New South Wales consume
liquor and indicates that liquor is not consumed at high daily levels. ALDI liquor
services have operated in NSW during the period referred to in the graph below. 107
7.35 “The proportion of people [in NSW] who reported drinking at levels that put them at
long-term risk of harm fell from 31.4% to 25.9% between 2006 and 2015—a reduction
of 5.5%.”108
7.36 ALDI’s experience in the eastern states in relation to ALDI’s more than 300 liquor
licences and the trend of the authorities to continue to grant ALDI licences confirms
that the ALDI model does not cause noticeable harm and ill-health.109 Even though
the licensing authorities in the eastern states have refused some ALDI applications
over many years, they have clearly found ALDI to be an organisation worthy of
107 http://www.health.nsw.gov.au/hsnsw/Publications/chief-health-officers-report-2016.pdf at page 6
108 http://www.health.nsw.gov.au/hsnsw/Publications/chief-health-officers-report-2016.pdf at page 8
109 As stated earlier in this document, it is acknowledged that a small number of licence applications have been refused.
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holding a licence on hundreds of occasions, including more than 150 times in New
South Wales where it has been found that “the small scale of the proposed licensed
area is a mitigating factor”.110
7.37 Relevantly also, the most recent published data has revealed that “the majority of
Australians are still enjoying alcohol responsibly and we are still drinking at 50 year
lows”.111
7.38 Every effort will be made by the applicant to conduct business under the Karrinyup
licence in a manner that minimises the potential for harm or ill-health to occur as a
result of the liquor store licence operating.
7.39 The applicant is an upstanding corporate citizen which operates pursuant to several
high level standards and policies. ALDI has a considerable presence in the public
domain, which it proposes to grow in Western Australia. It is in ALDI’s interests to
ensure that the liquor service at ALDI Karrinyup is successful in all respects, including
genuinely minimising harm.
____________________________________________________________________________
8 Impact on amenity, quiet or good order – section 38(4)(b)
8.1 Karrinyup Shopping Centre is the commercial hub for the suburb of Karrinyup and the
wider Locality.112 As referred to earlier in this PIA, Karrinyup Shopping Centre is
prominently situated on the very busy Karrinyup Road. The DES report (DOC 9)
comments as follows:113
Karrinyup Road dissects the suburb (east-west) extending west over Marmion Avenue to the
beachside areas of Trigg and east to the Mitchell Freeway and beyond where it becomes
Morley Drive, continuing through to the Swan Valley. At its western end near Marmion Drive,
Karrinyup Road carries abut (sic) 24,000 vehicles per day, increasing to 34,000 on its eastern
sections closer to Mitchell Freeway.
8.2 The new ALDI supermarket will be a purpose built and modern facility that is
designed to complement the local amenity. The redevelopment of the shopping
centre overall will improve the amenity within the Locality immeasurably, as its façade
goes through a makeover and the services and facilities are increased and
diversified.
8.3 Below is another artist sketch of what the impressive Karrinyup Shopping Centre will
look like after redevelopment:114
110 ALDI Vincentia dated 4 April 2016 [119]
111 https://www.theshout.com.au/news/total-alcohol-consumption-remains-at-50-year-lows/
112 https://www.stirling.wa.gov.au/your-city/about-stirling/suburbs/karrinyup
113 At page 3
114 https://www.karrinyupcentre.com.au/development
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8.4 ALDI Karrinyup will be a welcome addition to the new fresh food precinct. In this
regard, “Karrinyup [Shopping Centre] will grow from one to three supermarkets,
generating a significant increase in food & grocery shoppers. Many of these will look
for and expect packaged liquor products to purchase as part of their regular grocery
buying patterns.”115
8.5 Despite its relatively tiny licensed display/browse and checkout area of only
approximately 35m2, the ALDI Karrinyup liquor proposal will make a big and valuable
contribution towards the services and facilities in the area.
8.6 In terms of the impact of the liquor display/browse area on the amenity, it is important
to reiterate that it will not have any external frontage, façade or overt signage. It will
be contained inside the ALDI supermarket footprint. Further on this point, the
intended manner of trade is for the liquor service to complement the grocery and
household offering in the supermarket. The premises will not operate as a stand-
alone liquor outlet and therefore, there will be no impact on the streetscape or
external amenity whatsoever.
8.7 The ALDI supermarket will be operating amongst many other shops and businesses
at the enormous commercial site. The ALDI Karrinyup supermarket and if approved,
its liquor section is, therefore, most unlikely to lessen the quiet or good order of the
Locality in any way. Given the fact that the Shopping Centre has operated at the
same location for many decades, the coming and going of delivery trucks and general
activity generated by the Shopping Centre should pose no issues from a quiet or
good order perspective.
Outlet density
8.8 The density of other licensed facilities is relevant to the analysis of the amenity of the
surrounding area. Pursuant to the PIA Policy’s requirements, the applicant has
identified all of the licensed premises within the Locality, based on records published
by the licensing authority.116 These are listed in the table below.117
115 DES report (DOC 9) at page 24
116 https://portal.rgl.wa.gov.au/forms/fr/search/findalicence/new
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No. Licence Type Premises Name Premises Address
1 Liquor Store BWS - Beer Wine Spirits Karrinyup Shopping Centre,
Karrinyup Road, Karrinyup
2 Liquor Store Liquorland Gwelup Gwelup Shopping Centre, corner
North Beach Road & Wishard
Street, Gwelup
3 Liquor Store Innaloo Speciality Liquor Shop 7, Morris Place Shopping
Centre 27 Morris Place, Innaloo
4 Liquor Store Scarborough Cellars 166A Scarborough Beach Road,
Scarborough
5 Tavern The Saint George Hotel 2 Morris Road, Innaloo
6 Club Lake Karrinyup Country Club North Beach Road, Karrinyup
7 Club Croatian House Hrvatski Dom
Inc
Lot 2 Wishart Street, Gwelup
8 Club Innaloo Sportsmens Club Inc Birdwood Street, Innaloo
9 Club Scarborough Sports &
Community Club Inc
75 Deanmore Road, Scarborough
10 Club Restricted Scarborough Amateur Football
Club
Millington Reserve, Elliott Road,
Karrinyup
11 Club Restricted West Stirling Baseball Club Inc Millington Reserve, Elliot Road,
Karrinyup
12 Club Restricted Karrinyup Cricket Club Inc Karrinyup Reserve, Huntress
Road, Karrinyup
13 Club Restricted Stirling City Toscany
(Panthers) Soccer Club Inc
Langley Crescent, Innaloo
14 Club Restricted Northern Districts Social Club Abbett Park, Deanmore Road,
Scarborough
15 Restaurant Cafe 34 Shop G34, Karrinyup Shopping
Centre, 200 Karrinyup Road,
Karrinyup
16 Restaurant Al Fornetto Cafe Ristorante
Pizzeria Perth
199 Scarborough Beach Road,
Doubleview
17 Restaurant Little Sisto 145 Sackville Terrace, Doubleview
117 The premises listed in the table are identified as being in the Locality, based on the approximate straight-line distance from
the proposed ALDI Karrinyup store as calculated by Google Maps.
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No. Licence Type Premises Name Premises Address
18 Restaurant Cafe Relish 193C Scarborough Beach Road,
Doubleview
19 Special Facility
Licence
Gleneagles Bar & Reception
Centre
Hamersley Golf Course, 102
Marmion Avenue, Karrinyup
20 Wholesaler's Palinda Wines Pty Ltd 39 Maynard Way, Karrinyup
21 Wholesaler's Westons Australia Pty Ltd 92b Newborough Street,
Karrinyup
22 Wholesaler's Wine Warehouse 21 Willowbank Entrance, Gwelup
8.9 The different classes of licence identified in the table above provide generally some
indication of the different services. A comparison of ALDI Karrinyup with all of the
other licensed premises in the Locality is included with the Applicant’s Case (DOC 9).
8.10 Interestingly, out of the 22 licences in the Locality, nine are club or club restricted
licences. That represents almost half (40.9%) of the Locality’s outlet density.
8.11 There are three wholesaler’s licences, all of which appear to be operating out of
residential homes.118
8.12 The most relevant licensed premises to consider are those that are permitted to sell
packaged liquor to the general public. In this case, based on research by the
applicant and DES, those premises are the four retail liquor stores and The Saint
George Hotel which operates with a BWS browse/drive-thru bottle shop.
8.13 Only one of the liquor stores, BWS, is situated in the Karrinyup Shopping Centre. All
the others are quite some distance from the proposed ALDI Karrinyup and generally
along the Locality perimeter. This is illustrated in the following map from the DES
report (DOC 9) which plots the approximate locations of these five premises.119
118 As per Google searches of the listed addresses of those licensed premises
119 At page 21
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8.14 “For many years, BWS has been the only choice for grocery shoppers to purchase
liquor at the Shopping Centre. For residents living close to the Centre there are also
few alternatives.”120
8.15 The DES report (DOC 9) comments as follows on the packaged liquor outlets:121
The 2km locality has a population of 24,177 people (2018). With just 5 operating liquor
stores in retail premises or attached to taverns, the effective density of all licences is one
licence for every 4,835 people. This is a significantly lower density and provision than
the average across metropolitan Perth of one liquor store, hotel and tavern licence for
every 2,974 people.
BWS Karrinyup is the only licence which is close to the site of the application.
Woolworths is the only supermarket in Karrinyup and BWS (located beside Woolworths)
is the only liquor store within 2km of the centre. On this basis, there is little choice for
residents of the locality close to Karrinyup for shoppers visiting the centre.
The granting of a conditional licence to ALDI at Karrinyup would raise the rate of
provision to one licence for every 4,030 people within the 2km locality, a rate still much
120 DES report (DOC 9) at page 24
121 At page 23
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lower than the Perth average. This reflects the under provision of packaged liquor
options for residents in the locality.
8.16 Whilst the ALDI and BWS outlets will be in the same shopping centre, this fact should
not impede the grant of the ALDI licence. Even within the confines of the Shopping
Centre facility, ALDI Karrinyup and the BWS store will be in separate sections and a
considerable distance from each other. This is situation is clearly shown in the
following image:122
8.17 The regional status and size of Karrinyup Shopping Centre is a relevant consideration
in assessing outlet density in respect of this application.
8.17.1 The Shopping Centre reported over 6 million visitors per annum prior to the
redevelopment.123 This is likely to increase significantly after the works
have been completed, when the Centre will double in size.
8.17.2 “As a regional shopping centre, Karrinyup will draw customer (sic) from a
region far wider than the 2km locality.”124
8.17.3 The current provision of only one liquor store in such a large shopping
centre is submitted to be insufficient even now, to adequately cater for the
packaged liquor requirements of consumers, let alone when the Shopping
Centre has doubled. This is supported by the market research findings
122 DES report (DOC 9) at page 7
123 DES report (DOC 9) at pages 6 and 23
124 DES report (DOC 9) at page 23
BWS
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referred to in subsequent paragraphs, as well as the following remark in the
DES report (DOC 9):125
… In most regional shopping centres in excess of 100,000 sqm, most
product and service categories are duplicated through competing retailers
to provide choice and offer convenience as some shoppers (such as
grocery buyers) only shop certain sections of the centre. The provision of
another liquor licence can be easily supported by the market and indeed
enhances the choice and convenience of shoppers shopping in or near
ALDI in the new food precinct. The licence will strengthen AMP’s aim of
developing a convenient local shopping node by grouping ALDI, Coles and
a range of high quality food shops together.
8.17.4 “[T]he effect on choice, value and a differentiated product range for the high
volume and frequency of shoppers at the Karrinyup Shopping Centre is
positive.”126
8.18 Moreover, ALDI Karrinyup and BWS Karrinyup will be distinctly different from the
other. This proposition is supported by the Liquor Commission’s finding in the ALDI
Harrisdale decision that there “is a significant diversity between the products sold by
ALDI and the BWS store…”127.
8.19 It is reiterated that the ALDI Karrinyup liquor service will be unique and almost entirely
unlike the existing services in the Locality. What is proposed is a modest liquor range
comprising largely of award winning and value-for-money products, through a modern
one-stop-shop concept that has the potential to offer an unrivalled level of
convenience for shoppers. The following are key additional distinguishing features of
the ALDI liquor proposal:
8.19.1 The majority of ALDI’s products are exclusive and not available at any of
the other liquor outlets.
8.19.2 The display/browse and checkout section in the ALDI Karrinyup
supermarket will only comprise approximately 35m2, significantly smaller
than many of the other packaged liquor outlets. The bespoke ALDI liquor
service will be an ancillary but highly valuable component of its overall
service.
8.19.3 There will be no refrigerated liquor products at ALDI Karrinyup. This is a
harm minimising factor of the ALDI liquor service and speaks to its genuine
intention to complement its household and grocery offering.
8.19.4 None of the other packaged liquor outlets can offer one-stop-shopping
convenience to ALDI shoppers in the same way that ALDI Karrinyup will if
the licence application were to be granted.
125 At page 25
126 DES report (DOC 9) at page 23
127 [43(g)]
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8.20 Indeed, ALDI Karrinyup will be unlike any of the other operations in the Locality. The
ALDI Karrinyup liquor section will be situated within the free-standing supermarket
which will, in effect, be self sufficient in that it will provide customers with a very
comprehensive one-stop-shop opportunity within the one retail footprint. Fresh food,
other groceries, a wide range of household and garden products and liquor will be
available from the one place, with easy access and on-site parking. Furthermore, it is
these very attributes of the ALDI Karrinyup liquor proposal that are highly demanded
by the community, as highlighted in the following findings in the PRG report (DOC 8):
8.20.1 “Competitive pricing, convenient location and on-site parking are the most
appealing attributes, with just under three-quarters (70%) rated the notion of
being within a supermarket highly.”128 This is illustrated in the graph below.
8.20.2 “…the ALDI attributes of value, award winning products and the ability to
buy groceries and liquor requirements in the one store are liked by a
significant majority of packaged liquor buyers. Note also that just under
three-quarters of respondents (74%) liked the notion of a sectioned-off
liquor section…”129. This is illustrated in the following graph.
128 Page 6
129 Page 7
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8.20.3 “Nearly eight out of ten (79%) of those who currently buy packaged liquor,
and just over eight out of ten (83%) of those who buy at least once a month,
report that they would be likely to purchase their packaged liquor
requirements from the ALDI liquor section if shopping in the proposed
Karrinyup ALDI store. The main motivations for this appear to be the
greater convenience and the good value promise of the ALDI approach to
retailing.”130
8.21 It is a highly compelling factor that a representative sample of the public have
expressed a clear desire for the proposed liquor service. As addressed earlier on in
this PIA, this application has the potential to alter the shopping habits of the
community by greatly improving and enhancing the level of convenience, choice and
quality in offering. This is supported by the following extract from the PRG report (DOC
8):131
Whilst 63% of respondents buy their packaged liquor requirements “at least half the
time” when also shopping for household groceries, one third (33%) do so “most or all of
the time”. The 30% who do so “about half the time” could be a function of lack of
opportunity. The question about the potential for greater convenience overleaf
suggests that the limiting factor is lack of opportunity rather than lack of
preference. The most preferred option at present is that of a specific “walk in and
browse” trip to a liquor store, currently favoured by 43% of respondents “most or all of
the time” and 70% “at least half of the shopping occasions.”
Note also, the small proportion (11%) making most of their packaged liquor purchases in
a drive through bottle shop. Indeed 76% of packaged alcohol buyers report that they
rarely or never use a drive through bottle shop, suggesting that little of the shopping
for packaged alcohol in this region is a spur of the moment decision or simply not
a preferred or a convenient option.
…
Four out of five (80%) respondents who buy take-away liquor report that they would find
it more convenient to make these purchases if their grocery store included a take-away
liquor section within the store itself…
The suggestion is that whilst the dominant shopping pattern is currently tilted towards a
special trip to a “walk in and browse” store over the choice to shop in conjunction with
the household grocery shopping, there is a likelihood that shopping in conjunction
with the weekly grocery shop would become even more common if their grocery
store also had a licenced (sic) packaged liquor section. In short, increased
availability of such options would lead to a change in the way that many consumers
shop for their packaged alcohol requirements.
(Emphasis added)
130 Page 9
131 Pages 17 and 18
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8.22 The addition of the ALDI Karrinyup liquor service in this Locality is also consistent
with industry growth and development. Further in this regard, it is relevant to consider
the following finding by the Liquor Commission in ALDI Harrisdale:132
The granting of a licence for the selling of packaged liquor in a floor space of 24 square
metres would not result in a proliferation of liquor stores within the locality or a
proliferation of liquor within the locality. To the contrary, given the nature of products to
be sold by the applicant it will add to the diversity of products on offer and allow greater
choice for consumers of liquor, thus being consistent with the primary object set out in
section 5(1)(c) of the Act.
8.23 This issue of outlet density is also addressed in the accompanying Legal Submissions
(DOC 7).
8.24 It is submitted that the licensing authority should be able to easily find that evidence
collectively demonstrates that the granting the ALDI Karrinyup licence is certainly in
the public interest.
____________________________________________________________________________
9 Offence, annoyance, disturbance or inconvenience – section
38(4)(c)
9.1 ALDI has carefully considered the impact that may be caused to people who reside or
work in the vicinity of the proposed licensed premises in terms of how and in what
circumstance the sale and supply of liquor could potentially cause those people
offence, annoyance, disturbance or inconvenience.
9.2 It is not considered that there are any high risk factors associated with the ALDI
application, for the various reasons referred to throughout this PIA. Despite that
conclusion, the applicant is aware of the potential for adverse effects from any sale
and supply of liquor and hence proposes to implement the following strategies to
“combat offence, disturbance or inconvenience”133 that could potentially occur:
9.2.1 Maintaining a manner of trade which is low risk and low impact.
9.2.2 Managing delivery times and methods in such a way as to minimise
potential disturbance to neighbours. The potential of this is highly unlikely
given that Karrinyup Shopping Centre has been operating since the 1970’s
and surrounding residents are well accustomed to the comings and goings
of vehicles associated with the operations of the Centre.
9.2.3 Implementing tried, tested and proven operational policies for overall
management and conduct of business.
9.2.4 Monitoring closely unaccompanied juveniles. Controversial liquor products
and promotions designed to be attractive to juveniles will not be stocked.
132 [42]
133 PIA Policy
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9.2.5 Maintaining a high standard of premises in terms of cleanliness, tidiness
and overall quality, to indicate to patrons the operator’s professional
approach to management of the business.
9.2.6 Employing only mature and skilled people to run the operation, all of whom
will be presented in professional uniform. The staff will all be trained to be
able to exhibit a high level of stock knowledge. These features will add an
element of responsibility to the functioning and image of the business.
9.3 ALDI’s high level of staff training will ensure that staff at ALDI Karrinyup will
consistently enforce and uphold the licensee’s policies and philosophies for a
compliant business which focuses on integrating with the local community. The
applicant values its excellent reputation as an upstanding corporate citizen and
employees will be trained to uphold reputation and share in ALDI’s core values.
9.4 The overwhelming majority of respondents in the applicant’s market research (DOC 8)
indicated that they do not consider the ALDI liquor service will cause them personal
harm, ill-health, offence, disturbance, annoyance, inconvenience or offence. It was
revealed that “at least nine out of ten respondents indicated that they would not
experience the particular potential negative effects of the liquor licence” as illustrated
in the following graph.134
9.5 No high risk factors associated with the liquor store proposal in this case have arisen
in preparing this PIA. The small risk factor that does exist, as with any licensed
premises, will be closely monitored and carefully managed in any event.
____________________________________________________________________________
10 Tourism, community or cultural matters – section 38(4)(ca)
10.1 The local community stands to benefit enormously from the introduction of the ALDI
liquor service at the ALDI supermarket. The public will enjoy the well-known ALDI
134 DOC 8 at page 8
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liquor products and services in their area, which have been enjoyed by other
Australians elsewhere in the country for many years and are starting to be enjoyed in
WA.
10.2 The opening of ALDI stores in Western Australia has been met with great enthusiasm
by customers from across the metropolitan area. When the first ALDI stores in WA
started trading in June 2016, members of the public queued up for hours before the
stores opened, as seen in the photographs below.135
10.3 In the first six months of trade in Western Australia, more than 3.2 million customers
were served at ALDI stores.136 By way of a further example of ALDI’s popularity, the
ALDI Cloverdale store transacted a staggering 156,338 customers in just 69 days of
trading, which is an average of 2,266 customers per day.137
135 http://www.watoday.com.au/wa-news/keen-shoppers-brave-cold-for-opening-of-perth-aldi-stores-20160607-gpe297.html
136 https://www.businessnews.com.au/article/Aldi-flags-14-more-WA-stores-in-2017
137 DOC 19
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10.4 In terms of employment benefits, within around six months of opening, ALDI had
employed almost 500 people in its WA stores. Its long term plan to open up to 70
stores in this State would lead to 1,200 jobs being created.138
10.5 Further in terms of community benefits139:
The Australian retail liquor sector generated sales of nearly $17 billion in 20161 and an
estimated $5.1 billion collected from indirect alcohol taxes and GST revenues2. Retail
liquor provides a broad range of flexible employment with more than 47,800 people
directly employed across Australia. In total, the 6,451 packaged liquor licences (PLL)4
underpin an industry generating employment of 165,800 Australians when also factoring
in the additional indirect jobs5.
The retail liquor sector is proactively committed to responsibly enabling the safe and
social enjoyment of alcohol beverages, by providing a wide choice of premium
beverages at competitive prices, for people to share with friends and family in the safety
of their homes. The sector collaboratively tackles alcohol misuse and discourages
underage/secondary supply of alcohol beverages by adopting many voluntary (and
effective) measures…
____________________________________________________________________________
11 Other matters
Patronage
11.1 ALDI anticipates it will build up and maintain a large and regular customer base,
comprised mainly of people living in the Locality. This is supported by the trade area
information and following findings in the DES report:140
Karrinyup is an affluent area with a low provision of liquor stores. The socio-economic indices
for the locality and the broader catchment beyond 2km are favourable. The data points to an
area of established and older families with high education and income levels and white collar
occupations. Unemployment rates are low and there is little public housing in the area.
…
The small offering targets in-store grocery buyers with a strong emphasis on convenience,
quality and value. It will be an important and valuable addition to the overall product mix
available to ALDI customers and centre visitors.
11.2 Other results of the applicant’s market research show that the proposed liquor service
at ALDI Karrinyup is highly likely to be enormously popular as well. “Nearly four out
of five (79%) respondents who ever buy take-away alcohol indicated that if they were
shopping in the proposed ALDI Karrinyup store they would be at least “quite likely” to
also buy their packaged liquor requirements in the liquor section. …more frequent
138 http://www.perthnow.com.au/news/western-australia/aldi-to-open-14-more-stores-in-wa-in-2017/news-
story/0de29965fcd9712852ab9b2919908286
139 ALSA-IRI State of the Industry Report, March 2017, at page 4 (DOC 10)
140 DOC 9 at page 25
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buyers of take-away alcohol (at least once a month) showed heightened interest
(83%) in buying from the ALDI liquor section.”141
11.3 In this regard, it is highlighted that the licensing authority is entitled to take into
account the popularity of similar services provided at other locations when assessing
whether the proposed services will be in the public interest at this particular
location.142
11.4 The proposed liquor service will principally cater for all of the reasonable liquor
shopping needs of ALDI supermarket customers. The liquor store is designed to
provide premium shopping convenience in terms of the following:143
11.4.1 One-stop-shopping.
11.4.2 One-transaction-shopping.
11.4.3 One-stop-ALDI-shopping.
11.4.4 One-trolley-shopping.
Security and crime prevention
11.5 ALDI’s considerable retailing experience, including selling liquor products, has
provided the organisation with the ability to manage security well such that crime
associated with ALDI stores is kept very low.
11.6 The quality of the premises, both inside and outside, and the standard of supervision
by staff will help make the public feel welcome and safe but any would-be criminals or
disorderly persons uncomfortable.
11.7 Crime prevention through environmental design is contemplated by the PIA Policy
and the applicant has had regard to this issue. Importantly, the liquor store will have
no external access as it will be entirely confined and secured within the ALDI
supermarket.
11.8 As has already been made clear, the following will apply at the ALDI Karrinyup store:
11.8.1 Security cameras both inside the premises and outside around the exterior,
further details of which are provided below. This includes CCTV over the
licensed area.
11.8.2 Secure locking systems for after hours.
11.8.3 A high level of staff training which includes how to deal with incidents that
are or could potentially become criminal or unsafe.
141 DOC 8) at page 23
142 Woolworths Ltd v Director of Liquor Licensing [2013] WASCA 227 at [77]
143 This aspect is addressed in the detail in the accompanying Legal Submissions (DOC 7)
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11.8.4 Maintaining a rigid enforcement of harm minimisation principles and
policies. These will include, for example the “ID Under 25” policy, staff
training, participation in the local liquor accord, notifying police of potential
criminal behaviour and keeping in contact with police.
11.8.5 Clear and obvious signage. The new premises will be bright, modern and
attractive.
11.8.6 Limited public access and egress via one point only, from within the
supermarket under the constant vigil of the cashiers. This will ensure a
high level of staff surveillance from inside the store and will also inhibit
would-be criminals by restricting the ease of a ‘get-away’.
11.9 The applicant’s responsible approach to its business and desire and proven capacity
to provide a service that is popular with the local community will help ensure an
approach to management that invokes safety, convenience and no crime.
11.10 The design for the new store ensures the licensee will have the ability to maintain
adequate controls over the licensed operation by being able to properly monitor the
whole premises whilst simultaneously operating the business in a manner which
meets the requirements of the public.
11.11 Included in the Applicant’s Case is a copy of the applicant’s confidential Security
Layout plan, illustrating the general position and fit-out of the items described above
(DOC 14 - private and confidential).
11.12 An advanced security and surveillance system will be installed, based on the model
which has been successfully operating in the eastern states. The applicant’s
advanced system includes the following features:
11.12.1 An Access Control System as follows:
(a) 24 hour entry system to the store including interface with the
security system.
(b) A tamper switch will be applied to set off the alarm in the event of
unauthorised removal of the panel front covers.
11.12.2 CCTV system – 24 hour surveillance of the licensed area and entry and
exits to the store, which will include the following:
(a) 11 active cameras will provide 24 hour surveillance with the digital
video recorder.
(b) Two full body cameras located within the licensed area, one
facing the checkout and another one facing the liquor shelf.
(c) The digital video recorder will be configured for motion detection
to allow efficient review of any incidents.
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(d) An appropriately sized hard disk will be installed to allow images
to be retained on the digital video recorder for at least two weeks
without greatly compromising recording quality.
(e) The CCTV flat panel monitor will be located in the office to
provide real time monitoring to the store staff of the retail floor
including the licensed area. This will include a play-back function.
11.12.3 The security system equipment will include the following:
(a) Passive Infra-Red Motion Detectors.
(b) Break glass detectors.
(c) Magnetic reed switches.
(d) Vibration detector.
(e) External strobe and siren.
(f) Security flashing lights and horns.
11.12.4 A back to base monitoring system which will raise a security alarm if the
security system is armed and there is a breach. The back to base alarm will
then send a patrol as well as notifying the manager, which will also activate
an external strobe light and external siren.
11.13 The design and installation of the electronic security, access control and audible
system shall comply with the requirements of all relevant standards and codes
including but not limited to the following:
11.13.1 Australian Standards AS/NZS 3000.
11.13.2 State Service and Installation Rules.
11.13.3 Building Code of Australia.
11.13.4 Local and other authority services and installation rules.
11.13.5 Australian Communications Authority.
11.13.6 Work Cover Authority.
11.13.7 Other relevant Australian standards.
11.14 Of real significance is the fact that the ALDI liquor area design and layout facilitates
an advanced level of security and surveillance. The store’s design will make it
extremely difficult for juveniles, drunk people or would-be thieves to gain access to
the liquor area and go undetected. This will be achieved by virtue of the following
factors:
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11.14.1 Customers will be required to walk well into the supermarket footprint under
clear view of a combination of various cameras, staff monitoring them and
other customers observing.
11.14.2 Customers will be required to walk through the manned and monitored
checkouts in order to exit the store. There will be no quick get-away option.
11.14.3 The simple small layout of the liquor area will also ensure that it is not in
any way attractive for juveniles, drunk people or would-be criminals nor a
temptation for impulse procurement.
11.15 This ALDI concept has proven to be successful in other states and locally in
maintaining harm minimisation and risk management.
12 Conclusion
12.1 ALDI has provided a detailed proposal which includes all of the necessary formalities
as well as a large volume of supporting information and evidence from the
community, all of which is highly supportive of the grant of the liquor store licence for
a very small floor area in the Karrinyup store.
12.2 The particulars of the ALDI Karrinyup liquor licence application have been
comprehensively set out and evaluated with reference to all relevant aspects of the
PIA Policy. In particular, this PIA addresses the following key points:
12.2.1 All aspects of the public interest factors in full measure.
12.2.2 Relevant at risk groups.
12.2.3 Both positive and negative elements associated with the Locality and the
application generally.
12.3 Of the few small risks that exist in this case, several valuable risk minimising
measures have been proposed. On the other hand, the very many positive factors
have a great deal of weight.
12.4 The ALDI Karrinyup supermarket, with a liquor service, will provide an important and
valued service to the community. The evidence and findings in the DES report (DOC 9)
and the PRG report (DOC 8) that have been cited in this PIA support this proposition.
12.5 It is submitted that the grant of the ALDI Karrinyup application will cater for the
requirements of modern consumers. As detailed throughout this PIA, the public has
expressed overwhelming support for the ALDI liquor service at its Karrinyup
supermarket.144
144 PRG report (DOC 8)
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12.6 Further aspects of the public interest and the legal issues associated with the
application are addressed in the applicant’s detailed Legal Submissions (DOC 7).
Dated 19 September 2019
________________________________
Lavan
Lawyers for the applicant
Reference: Jessica Patterson
T: (08) 9288 6946
www.lavan.com.au