Dayton Liquor Store - Department of Local Government, Sport ...

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Dayton Liquor Store - Department of Local Government, Sport ...
p:      (08) 6278 2788
 f:      (08) 6278 2988
 e:      phil@canford.com.au
 mob: 0417 976 009
 postal: PO Box 389
       Guildford WA 6935

             Dayton Liquor Store
                               36 Repton Street, Dayton

           Application for a Liquor Store Licence
                  Section 38 Submissions
                Public Interest Assessment

                                                October 2019

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Dayton Liquor Store - Department of Local Government, Sport ...
Contents

1      Introduction......................................................................... 3

2.     The Locality......................................................................... 7

3.     Demographics of the Locality ................................................... 16

4.     Outlet Density ..................................................................... 20

5.     Population Growth in the locality .............................................. 23

6.     Proposed Style of Operation .................................................... 32

7.     Traffic Volumes and Public Transport ......................................... 34

8.     Background and Experience of the Applicant ................................. 37

9.     Risk Assessment with respect to Harm and Ill Health ....................... 38

10.    A Report on the amenity of the Locality ...................................... 42

11.    Section 38(4)(c) - Offence, Annoyance, Disturbance or Inconvenience... 43

12.    Section 5(1)(a) of the Liquor Control Act (1988) ............................. 44

13.    Section 5(1)(b) of the Liquor Control Act (1988) ............................. 45

14.    Section 5(1)(c) of the Liquor Control Act (1988) ............................. 46

15.    Section 5(2)(a)(d)(e)(f) of the Liquor Control Act (1988) ................... 47

16.    Objective Public Interest Evidence............................................. 48

17.    Conclusion ......................................................................... 50

Attachments ............................................................................... 52

                                        Canford Hospitality Consultants Pty Ltd | Introduction   Page 2 of 53
Dayton Liquor Store - Department of Local Government, Sport ...
1    Introduction
1.1. Dayton Liquor Store Pty Ltd is applying to the Licensing Authority for the grant
     of a liquor store licence for premises located at 36 Repton Street, Dayton.
1.2. The proposed name of the liquor store is Dayton Liquor Store and it will be
     situated in the new Dayton Commercial Centre (DCC). The DCC development of
     approximately 2,000m2 is due to open in September 2020, and will include;
     1.2.1. A new IGA Supermarket of 1,000m2;
     1.2.2. The proposed Dayton Liquor store and drive through facility (should this
            application be successful);
     1.2.3. A chemist and medical centre
     1.2.4. Café and specialty shops.
1.3. The proposal is for a liquor store of 282m2 with a 165m2 drive through facility
     attached to it. The premises will be located near the new Dayton IGA
     supermarket offering local residents the convenience of a full-service
     supermarket, a cafe and a quality packaged liquor offer in close proximity to
     each other.
1.4. According to the November 2017 Urbis Retail Sustainability Assessment Report
     (Attachment 1);
     1.4.1. “In order to assess the need, demand and impact of the proposed
            convenience retail node within the Dayton Commercial Centre a
            catchment area covering Dayton and part of Bennett Springs has been
            utilised for the assessment”
1.5. Page 25 of that report states;
     1.5.1. “Currently, the more than 4,000 residents, which is expected to reach
            around 7,600 within the next five years, have no access to retail shops
            and services locally. The nearest retail centre is located in Caversham.
            There are few areas in Perth where residents have such limited access
            to shops servicing everyday retail needs”
     1.5.2. “The 2,000 sq.m of PLUC 5 shop/retail floorspace would capture only a
            modest share of available retail expenditure generated by catchment
            area residents. In the long term 95% of catchment area expenditure will
            still be available to support other existing and planned activity centres
            in the relevant region (e.g. Dayton, West Swan, Brabham and
            Caversham)”.
1.6. As the proposed liquor store is to be located within close proximity to the IGA
     Supermarket, shopping for liquor can be conveniently done as part of the
     normal weekly shopping excursion and will not require a separate trip or stop.
1.7. These submissions are designed to address the public interest requirements as
     set out in Section 38 of the Liquor Control Act 1988.
1.8. These submissions have been drafted by Canford Hospitality Consultants Pty Ltd
     (Canford) in consultation with Stanley Horsman, a representative of the
     applicant company and references to the applicant or the applicant’s opinion
     relate to Mr. Horsman.

                              Canford Hospitality Consultants Pty Ltd | Introduction   Page 3 of 53
Dayton Liquor Store - Department of Local Government, Sport ...
1.9. Section 38(2) of the Act sets out the matters to be taken into account by the
     Licensing Authority in deciding whether or not to grant a Liquor Store Licence.
     Specifically, it states:
     1.9.1. “An applicant who makes an application to which this subsection
            applies must satisfy the licensing authority that granting the
            application is in the public interest”
1.10. Section 38(4) of the Liquor Control Act states the licensing authority may have
      regard to the following matters when considering an application for a liquor
      licence;
     1.10.1. “Without limiting subsection (2), the matters the licensing authority
             may have regard to in determining whether granting an application is
             in the public interest include —
             1.10.1.1. “the harm or ill-health that might be caused to people, or
                       any group of people, due to the use of liquor; and
             1.10.1.2. whether the amenity, quiet or good order of the locality in
                       which the licensed premises or proposed licensed premises
                       are, or are to be, situated might in some manner be lessened;
                       and
             1.10.1.3. whether offence, annoyance, disturbance or inconvenience
                       might be caused to people who reside or work in the vicinity
                       of the licensed premises or proposed licensed premises; and
             1.10.1.4. any effect the granting of the application might have in
                       relation to tourism, or community or cultural matters; and
             1.10.1.5. any other prescribed matter”.
1.11. The objects of the Act are expressed at s.5 of the Act, which states that the
      primary objects of the Act are –
     1.11.1. “to regulate the sale, supply and consumption of liquor; and
     1.11.2. to minimise harm or ill-health caused to people, or any group of
             people, due to the use of liquor, and
     1.11.3. to cater for the requirements of consumers for liquor and related
             services, with regard to the proper development of the liquor industry,
             the tourism industry and other hospitality industries in the State”.
1.12. Section 5 of the Act also includes the following Secondary Objects;
     1.12.1. “In carrying out its functions under this Act, the licensing authority
             shall have regard to the primary objects of this Act and also to the
             following secondary objects-
         1.12.1.1. “To facilitate the use and development of licensed facilities,
                   including their use and development for the performance of live
                   original music, reflecting the diversity of the requirements of
                   consumers in the State;
         1.12.1.2. To provide adequate controls over, and over the persons directly
                   or indirectly involved in, the sale, disposal and consumption of
                   liquor;

                             Canford Hospitality Consultants Pty Ltd | Introduction   Page 4 of 53
Dayton Liquor Store - Department of Local Government, Sport ...
1.12.1.3. To provide a flexible system, with as little formality or
                    technicality as may be practicable, for the administration of this
                    Act, and
          1.12.1.4. to encourage responsible attitudes and practices towards the
                    promotion, sale, supply, service and consumption of liquor that
                    are consistent with the interests of the community”.
1.13. Consequently, the applicant will consider all the new provisions in these
      submissions.
1.14. Further Section 5(3) states “If, in carrying out any function under this Act, the
      licensing authority considers that there is any inconsistency between the
      primary objects referred to in subsection (1) and the secondary objects
      referred to in subsection (2), the primary objects take precedence”.
1.15. The Director General provides advice to applicants for a liquor licence on the
      Department of Local Government, Sport and Cultural Industries website
      (http://www.rgl.wa.gov.au/). In a note on the website, the Director made the
      following comments;
     1.15.1. “The proliferation of liquor outlets is not in the public interest. To
             increase the number of licensed premises without any real and
             demonstrable consumer requirement, would represent proliferation
             without justification.”
     1.15.2. “The licensing authority must also weigh and balance the requirements
             of consumers against the object of minimising harm or ill-health caused
             to people, or any group of people due to the use of liquor.”
     1.15.3. “For an applicant to discharge its onus under section 38(2), it must
             address both positive and negative impacts that the grant of the
             application will have on the local community.”
     1.15.4. “This means applicants must adduce sufficient evidence to
             demonstrate the positive aspects of their application, including that
             the proposed licence will cater for the requirements for consumers for
             liquor and related services. The Liquor Commission has determined
             that failing to do this means “...the granting of licences under the Act
             would become arbitrary and not in accordance with the objects of the
             Act.” (LC 32/2010:Element WA Pty Ltd)”
1.16. According to a media release by the Premier’s office “Cheers to WA: Everyone’s
      a winner under State’s new liquor laws” dated 14th August 2018, Premier Mark
      McGowan pertaining to the Liquor Control Act Amendment Bill 2018, stated;
     1.16.1. “The new changes coming into effect this weekend strike the right
             balance between community health and safety while encouraging a
             more tourism-friendly hospitality culture”.
     1.16.2. “Tourism is a key economic driver for WA and plays a vital role in our
             plan to diversify the State's economy and create new jobs”.
1.17. In the same media release, Minister Paul Papalia is quoted as saying;
     1.17.1. “The passing of this legislation represents the most significant liquor
             reforms for the State in over a decade and delivers on our
             Government's plan for jobs by supporting opportunities for business
             growth and driving visitation to our wonderful State”.
                              Canford Hospitality Consultants Pty Ltd | Introduction   Page 5 of 53
Dayton Liquor Store - Department of Local Government, Sport ...
1.17.2. “It is time to modernise the hospitality and tourism industries, and
             these laws strike a good balance between the responsible consumption
             of liquor together with the tourism and employment benefits of a
             dynamic and prosperous hospitality industry”.
     1.17.3. “These reforms will mean venues that deliver cultural and tourism
             value will have a better chance of obtaining a suitable liquor licence”.
     1.17.4. “By cutting red tape we are supporting exciting local businesses,
             creating more jobs and moving towards a tourism-friendly hospitality
             industry”.
1.18. The licensing authority regulates the sale, and supply of alcohol. They seek to
      strike a balance between catering for the requirements for liquor and liquor
      related services whilst minimising the potential for harm and ill-health to the
      community through the abuse of alcohol. So the framework exists for the
      granting of new liquor licences in appropriate circumstances.
1.19. The applicant has also considered the outlet density of the location and it will
      be shown in these submissions how this application is in keeping with the
      primary objects of the Act and does not constitute a proliferation of liquor
      licences in this locality.
1.20. The applicant has also considered the demographics of the locality and will also
      demonstrate in other sections of these submissions the proposed liquor store is
      well planned to provide these important packaged liquor services with very
      little potential for increased harm or ill health.

                              Canford Hospitality Consultants Pty Ltd | Introduction   Page 6 of 53
Dayton Liquor Store - Department of Local Government, Sport ...
2. The Locality
2.1. The proposed premises will be located at 36 Repton Street, in the Dayton
     suburb, within the new Dayton Commercial Centre (DCC).
2.2. In defining the “locality” affected by the application, guidance has been
     provided by “Public Interest Assessment – A Policy of the Director of Liquor
     Licensing”.
2.3. The Director’s policy states that:
     2.3.1. “As part of a PIA submission, applicants must provide details regarding
            the community in the vicinity of the licensed premises (or proposed
            licensed premises) and any amenity issues in the locality.
     2.3.2. The term “locality” in this instance refers to the area surrounding the
            proposed licensed premises. This locality will be the area most likely to
            be affected by the granting of an application in relation to amenity
            issues.
     2.3.3. However, in terms of potential harm or ill-health impacts on the
            community an applicant may need to consider a wider geographical area
            depending on the intended nature of the business”.
2.4. In this document the locality definition for Dayton is stated as a 3km radius of
     the subject premises.
2.5. The following map, as taken from the Nearmap website shows the location of
     the proposed premises. Additionally, the map also illustrates the area
     encompassed by the 3km radius.

                            The subject
                            premises

                              Canford Hospitality Consultants Pty Ltd | The Locality   Page 7 of 53
Dayton Liquor Store - Department of Local Government, Sport ...
2.6. To assist in further defining the locality it will be useful to examine the
     following factors;
     2.6.1. The physical location of the subject premises;
     2.6.2. The presence of natural or human made boundaries that effectively
            separate one local community from another; and
     2.6.3. The community most likely to be impacted by the grant of this
            application.
2.7. The physical location of the subject premises;
     2.7.1. As previously mentioned in paragraph 2.1 above, the subject premises
            will be part of the new Dayton Commercial Centre which will be located
            on Repton Road in the suburb of Dayton.
     2.7.2. The proposed Dayton Liquor Store will be surrounded by the following
            businesses;
           2.7.2.1. An IGA Supermarket;
           2.7.2.2. Café;
           2.7.2.3. Specialty shops;
           2.7.2.4. A Medical Centre;
           2.7.2.5. Community facilities; and
           2.7.2.6. A chemist.
     2.7.3. Attachment 2 contains the ‘Traffic Impact Assessment’ dated April 2019
            prepared by Transcore. The report states;
           2.7.3.1. “The subject site currently consists of a number of rural /
                    residential properties and vacant rural land as shown in Figure
                    2.
           2.7.3.2. Other properties to the north and west are currently also low
                    density rural / residential properties. Residential subdivision
                    development has already progressed in other nearby areas,
                    particularly south of Cranleigh Street and east of Lord Street,
                    as can be seen in Figure 2”.

                             Canford Hospitality Consultants Pty Ltd | The Locality   Page 8 of 53
Dayton Liquor Store - Department of Local Government, Sport ...
Figure 2.- Existing land use in the surrounding area

The subject
premises

                        Canford Hospitality Consultants Pty Ltd | The Locality   Page 9 of 53
Dayton Liquor Store - Department of Local Government, Sport ...
2.7.4. Furthermore, page 3 of the November 2017 Urbis Retail Sustainability
       Assessment Report (Attachment 1- see paragraph 1.4 above) states;
      2.7.4.1. “A Concept Plan has been prepared to illustrate the vision for
               the future development of the structure plan area (refer
               Figure 1.1) for the Dayton Commercial Centre”
                           Figure 1.1 Concept Plan

2.7.5. According to the November 2017 Urbis ‘Retail Sustainability Assessment’
       report as drafted for the Dayton Commercial Centre (attachment 1);
      2.7.5.1. “The subject site is located within the West Swan (East)
               District Structure Plan (DSP) area which is currently under
               development and forms part of the broader Swan Urban
               Growth Corridor Subregional Structure Plan (SUGCSSP). The
               DCC is centrally located within the SUGCSSP area.
                        Canford Hospitality Consultants Pty Ltd | The Locality   Page 10 of 53
2.7.5.2. The DCC site has direct frontage and visibility to Lord Street
                     which is a key existing north-south road in Dayton. The site also
                     has frontage to the future New Lord Street alignment which
                     will introduce an alternative and the main north-south arterial
                     road in the region. New Lord Street is scheduled for completion
                     in 2018 and will extend north from the Reid Highway to
                     Gnangara Road in Ellenbrook, merging with the existing Lord
                     Street alignment in its middle section”.
     2.7.6. Below is the site plan as included in that document which shows the
            convenient location of the new Dayton Commercial Centre within the
            West Swan East District Structure Plan;

2.8. In September 2019, the applicant placed a sign on the proposed location to gain
     the attention of the local community and ask them if they wished to complete
     a witness questionnaire to contact Canford for further information.
2.9. Below is a picture of this signage as displayed on the site;
                              Canford Hospitality Consultants Pty Ltd | The Locality   Page 11 of 53
2.10. Furthermore, the applicant also approached locals and visitors in the area and
      showed them a copy of the witness pack. See section 16 and attachment 3.
2.11. As a result of this process, fifty-one completed witness questionnaires were
      collected.
2.12. In the questionnaire, witnesses were asked, if they lived or worked close to
      Dayton, to describe the nature of the locality and surrounding area.
     2.12.1. Shannon Stone of Ellenbrook said, “Great community, lack of shops
             available”;
     2.12.2. Sheryl Jenkin of Ballajura said, “New growing area lots of houses but
             no shops”;
     2.12.3. Stephanie Dyson of Landsdale said, “No local shops in the area”;
     2.12.4. Elsa Silva of Brabham said, “Great community needs shops”;
     2.12.5. Jacinta Eyre of Aveley said, “Live locally, no local shops”;
     2.12.6. Gurvinder Pal Singh, who lives in Dayton said, “Dayton is very nice
             suburb and private”;
     2.12.7. Manpreest Singh of Brabham said, “Lovely place, good neighbours”.
2.13. Further details of the objective evidence can be found in the later “Objective
      Public Interest Evidence” section.
2.14. The presence of natural or human made boundaries that effectively separate
      one local community from another.

                              Canford Hospitality Consultants Pty Ltd | The Locality   Page 12 of 53
2.14.1. According to the November 2017 Urbis Retail Sustainability Assessment
             report;
             2.14.1.1. “the proposed DCC will be bounded by Cranleigh Street to the
                       south, Lord Street to the east, new (future) Lord Street to
                       the west and the extension of Harrow Street to the north
                       (currently unnamed and unconstructed)”
             2.14.1.2. “The subject site is located to take advantage of the excellent
                       visibility to passing trade while also providing a buffer
                       between the highway and adjacent residential areas”.
2.15. The community most likely to be impacted by the grant of this application;
     2.15.1. The proposed liquor store is targeted at local residents, other people
             who work in, visit, shop, or otherwise resort to the locality.
     2.15.2. There will be a catchment of residential properties to the immediate
             east of the subject premises. This community will account for a large
             portion of the customer base for the proposed DCC and is expected to
             do likewise for the proposed liquor store.
     2.15.3. It is expected that the population in the suburb of Dayton will continue
             to grow, as the Urbis Sustainability Assessment report further states;
             2.15.3.1. “It is estimated that over 1,000 dwellings have been
                       constructed in Dayton and this number is expected to
                       increase considerably in the short term with many large
                       subdivisions approved and under construction”.
     2.15.4. The applicant will discuss the ‘Population Growth in the locality’ in
             more detail in section 5 below.
2.16. Demographics of the locality:
     2.16.1. In terms of the relevant locality for the demographic study, the
             applicant has established that the following suburbs fall within the 3km
             radius, either in whole or in part.
             2.16.1.1. Dayton;
             2.16.1.2. Brabham;
             2.16.1.3. Bennet Springs;
             2.16.1.4. West Swan;
             2.16.1.5. Caversham;
             2.16.1.6. Beechboro;
             2.16.1.7. Whiteman; and
             2.16.1.8. Herne Hill.
     2.16.2. The following suburbs were found to have very small portions within
             the 3km locality definition, and have therefore excluded from the
             demographic study;
             2.16.2.1. Whiteman; and
             2.16.2.2. Herne Hill.

                             Canford Hospitality Consultants Pty Ltd | The Locality   Page 13 of 53
2.16.3. Therefore, the remainder of the suburbs, which are shown below, will
             be used by the applicant as being representative of the locality for the
             purposes of the demographic study in these submissions.
             2.16.3.1. Dayton;
             2.16.3.2. Brabham;
             2.16.3.3. Bennet Springs;
             2.16.3.4. West Swan;
             2.16.3.5. Caversham; and
             2.16.3.6. Beechboro.
     2.16.4. The maps below, as taken from the Australian Bureau of Statistics
             website, show the extent of these two suburbs.

            Dayton                       Brabham                      Bennet Springs

          West Swan                    Beechboro                         Caversham

2.17. Outlet density:
     2.17.1. In terms of outlet density, the following quote has been taken from the
             Director’s policy on Public Interest Assessments, last amended on 3rd
             October 2018;
             2.17.1.1. “Applicants will also need to provide: outlet density
                       information that includes: If the applicant intends to sell
                       packaged liquor, the location of all existing licensed
                       premises within the locality”.

                             Canford Hospitality Consultants Pty Ltd | The Locality    Page 14 of 53
2.17.2. For the purpose of the outlet density study the applicant has considered
        all licensed premises within a 3km radius of the subject premises.

                        Canford Hospitality Consultants Pty Ltd | The Locality   Page 15 of 53
3. Demographics of the Locality
3.1. The potential impact of this proposed licence on the community within the
     specified locality is something that any applicant must consider and is
     considered here by this applicant.
3.2. In “The Western Australian Alcohol and Drug Interagency Strategy 2018-2022”
     the priority groups of concern are as follows;
     3.2.1. Aboriginal people and communities.
     3.2.2. Children and young people.
     3.2.3. People with co-occurring problems
     3.2.4. People in rural and remote areas including fly-in, fly-out and drive-in,
            drive-out workers;
     3.2.5. Families, including alcohol and other drug using parents and significant
            others;
     3.2.6. Those interacting with the justice and corrections systems.
     3.2.7. Other target groups of concern include:
             3.2.7.1.    Older adults:
             3.2.7.2.    Culturally and linguistically diverse communities, people
                         identifying as lesbian, gay, bisexual, transgender or intersex;
                         and
             3.2.7.3.    Homeless people.
3.3. The applicant will consider all nine groups above for which data is readily
     available. The following groups were unable to be considered however, as data
     is not available for them;
     3.3.1. people with co-occurring problems;
     3.3.2. Families, including alcohol and other drug using parents and significant
            others (see paragraphs 3.4 & 3.5 below);
     3.3.3. Those interacting with the justice and corrections systems;
     3.3.4. Culturally and linguistically diverse communities, people identifying as
            lesbian, gay, bisexual, transgender or intersex; and
     3.3.5. Homeless people.
3.4. Clarification has previously been sought from the Drug and Alcohol Office
     regarding the definition of the term “family”.
3.5. The Drug and Alcohol Office replied that “a specific definition of family is not
     provided in the Strategy document. There are a number of reasons for this,
     including:
     3.5.1. “Recognition of the cultural diversity in Western Australia and that the
            definition of family can be different for different cultures.
     3.5.2. Recognition that the impact of an individual’s drug and alcohol use is
            not always confined to a household or what has in the past been
            defined as the ‘immediate family’ – it can impact more broadly on
            family members who are external to a household. For example,

                 Canford Hospitality Consultants Pty Ltd | Demographics of the Locality   Page 16 of 53
Grandparents, Aunts and Uncles are commonly reported to be
             impacted upon.
     3.5.3. Recognition that not all families are biologically related but can still
            be impacted on by a person’s drug or alcohol use – for example step
            children/guardians.”
3.6. With such a broad definition, it is impossible for the applicant to identify or
     quantify this priority population group in the locality.
3.7. For the purpose of this demographic study, the applicant has selected relevant
     Census topics from the Australian Bureau of Statistics (ABS) website
     (www.abs.gov.au) to provide an indication of the prevalence of each of the
     priority population groups within the locality and compared them with the same
     information for the State (Western Australia).
3.8. As mentioned in paragraph 2.16.3 above, for the purposes of the demographic
     study, the applicant will be considering the 2016 census data relating to Dayton,
     Brabham, West Swan, Caversham, Bennett Springs and Beechboro suburbs.
     These suburbs will be taken to be representative of the locality in this section.

                 Canford Hospitality Consultants Pty Ltd | Demographics of the Locality   Page 17 of 53
3.9. The selected ABS 2016 Census data is shown in the table below.

      ABS Census 2016                        Locality    Western Australia

      Total Persons                           26,689              2,474,410

      Aboriginal and Torres Strait
      Islander People                            2.8%                   3.1%

      Age
      Median age                                   33                     36

      Age
      Persons aged between 15 and                5.8%                   6.1%
      19

      Age
      Persons aged over 65                       7.2%                 14.0%

      Country of Birth
      Australia                                53.5%                  60.3%

      Language
      English only spoken at home              58.9%                  75.2%

      Employment
      Worked Full-time                         59.1%                    57.0

      Occupation
      Mining                                     3.5%                   6.2%

      Median Weekly incomes
      Family                                  $1,813                 $1,910

      Family composition
      One parent family                        14.6%                  14.5%

      Tenure type
      Rented                                   18.2%                  28.3%

      Tenure type
      State or territory housing                 3.0%                   3.5%
      authority

      Rent weekly payments
      Median Rent                               $377                   $347

                    Canford Hospitality Consultants Pty Ltd | Demographics of the Locality   Page 18 of 53
Rent weekly payments
      Households where rent
      payments are less than 30% of
                                             93.1%                  90.3%
      household income

      Mortgage monthly
      repayments
                                            $1,987                 $1,993
      Median mortgage repayments

3.10. The purpose of considering the demographic data for the locality is to establish
      whether the priority population groups identified in paragraphs 3.2 and 3.3
      above are over or underrepresented in the locality.
3.11. Aboriginal people and communities;
     3.11.1. The table above indicates that in 2016 the percentage of aboriginal
             people in the locality was lower at 2.8% compared with the figure for
             the State at 3.1%;
     3.11.2. Conclusion – This priority group is underrepresented in the locality.
3.12. Children and young people;
     3.12.1. The average figure for persons aged between 15 and 19 in the locality
             was lower at 5.8%, when compared to the State figure at 6.1%.
     3.12.2. Conclusion – This priority group is underrepresented in the locality.
3.13. People from rural and remote areas including fly-in, fly-out and drive-in, drive-
      out workers;
     3.13.1. In 2016, ‘People working in the Mining industry’ average figure in the
             locality was lower at 3.0% than WA as a whole at 6.2%.
     3.13.2. Conclusion – This priority group is underrepresented in the locality.
3.14. Older people;
     3.14.1. In 2016, the average figure for the population aged over 65 was much
             lower at 7.2% when compared to the average WA figure at 14.0%.
     3.14.2. Conclusion – This priority group is underrepresented in the locality.
3.15. The following data is also significant in respect of the demographic make-up of
      the locality:
     3.15.1. People in full time work is higher than the WA figure.
     3.15.2. The number of people in state housing is very low.
     3.15.3. The median figure for rent was higher than the State figure.
     3.15.4. Fewer people live in rental accommodation.
     3.15.5. For 93.1% of households in the locality, rent repayments were less than
             30% of household income, whereas the WA figure was 90.3%, showing
             the locality has low figures for rent stress.
     3.15.6. Conclusion – The locality has a below average representation of the
             measurable priority groups and the socio-economic data is strong,
             and the population appears to be relatively affluent and stable.
                  Canford Hospitality Consultants Pty Ltd | Demographics of the Locality   Page 19 of 53
4. Outlet Density
4.1. The proposed Dayton Liquor Store will be located at the proposed Dayton
     Commercial Centre on Repton Street in the Dayton suburb.
4.2. As stated in paragraph 2.17.2 above, if the applicant intends to sell packaged
     liquor, it is required to consider all existing licensed premises within the locality
     of the planned premises, in this case a 3km radius.
4.3. In August 2019, the applicant identified the following suburbs which fall in
     whole or in part within the locality (3km radius);
        4.3.1. Dayton;
        4.3.2. Brabham;
        4.3.3. Bennett Springs;
        4.3.4. West Swan;
        4.3.5. Caversham;
        4.3.6. Beechboro;
        4.3.7. Whiteman; and
        4.3.8. Herne Hill.
4.4. Then, in August 2019, the applicant searched the website of the Department of
     Local Government, Sport and Cultural Industries, for all licensed premises
     within those suburbs. Attachment 4 shows a list of the existing licensed
     premises.
4.5. The applicant eliminated any premises which may not trade in a manner similar
     to a liquor store.
4.6. Subsequently, the applicant eliminated any premises from that list which fall
     outside the 3km radius, and this resulted in the following premises which may
     trade in a manner similar to a liquor store and are located in the locality.
       RGL Ref        Licence type       Premises           Licensee            Premises
                                         name               name                address
       6020131517     LIQ-Tavern         Lavender           Pascal Henri        LOT 6
                                         Bistro and         Gouionnet           Cranleigh St
                                         Boutique                               WEST SWAN
                                                                                WA 6055
       603200220215   LIQ-Liquor         Liquorland         Liquorland          Unit 4/175
                      Store              Caversham          (Australia)         Suffolk Street
                                                            Pty Ltd             CAVERSHAM
                                                                                WA 6055
4.7.     As the crow flies both premises are within the 3km locality. By road the
         Liquorland Caversham liquor store is 2.8km from the subject site, and the
         Lavender Bistro is 3.2km away.
4.8.     The applicant advises the Lavender Bistro and Boutique does not have a
         dedicated packaged liquor facility. Therefore, this licensed premises has not
         been considered further in this study, and the only licensed premises which

                              Canford Hospitality Consultants Pty Ltd | Outlet Density     Page 20 of 53
may trade in a similar manner to the proposed Dayton Liquor Store in the
       locality is Liquorland Caversham.
4.9.   In that respect, question 4 of the witness questionnaire asked;
       4.9.1. “Liquorland Caversham is the only licensed packaged (take-away)
              liquor outlet in the locality (Dayton & Brabham).
             Where do you currently buy your packaged / take-away liquor from?”
4.10. The applicant notes that only 3 of 32 questionnaire respondents answered:
      “Liquorland Caversham”. This confirms that 90% of questionnaire respondents
      choose not to shop the only packaged liquor outlet in the locality.
4.11. However, below are some comments from the three witnesses who do shop at
      Liquorland Caversham;
       4.11.1. Ryan Demasi of West Swan said he shops for his packaged liquor
             requirements at “Liquorland Caversham”, but when asked why he
             currently shops there, he said “Currently the closest outlet to home”.
             When asked if that outlet was suitably located for his needs he said,
             “No, would prefer a closer outlet”.
       4.11.2. Glen Richards of Dayton said he shops for his packaged liquor
             requirements at “Liquorland Caversham”, but when asked why he
             currently shops his packaged liquor at that outlet he said, “Cheapest
             and closest”.
       4.11.3. Selma McPolin who lives in Dayton said, “Caversham Liquorland,
             Beechboro Liquorland” but when asked why she currently shops at
             those outlets she said, “closest to us”.
4.12. When asked, whether they would be likely to be a customer of the proposed
      new Dayton liquor store;
       4.12.1. Selma McPolin said, “Yes, its (sic) close and if they have what I want”.
       4.12.2. Ryan Demasi said, “Yes, close to home. Good variety of drinks”
       4.12.3. Glen Richards said, “Possibly depending on price”;
4.13. The proposed packaged liquor service will include a range of products from
      local microbreweries, boutique wineries, and local spirit distillers. Two thirds
      of respondents indicated they were interested in purchasing locally produced
      liquor products.
4.14. To further support the above, questionnaire respondents were asked to
      consider the proposed ‘Swan Valley Produce List’ (attachment 5), which is a
      sample list of some local boutique liquor products which will be featured, and
      to state what they believed was different about this proposed liquor store
      compared to Liquorland Caversham;
       4.14.1. Sheryl Jenkin said, “The proposed store is more like a boutique
               liquor store promoting/ supporting local produce of the
               neighbouring valley” (emphasis added);
       4.14.2. Shannon Stone of Ellenbrook said, “Distance for residence to travel.
               Supporting local supplier” (emphasis added);
       4.14.3. Jacinta Eyre said, “Would have nice local wines & beers”;

                            Canford Hospitality Consultants Pty Ltd | Outlet Density   Page 21 of 53
4.14.4. Karen Harley of Aveley said, “Will be close to my new residence.
              Greater range of Swan Valley wines” (emphasis added);
      4.14.5. Ryan Demasi of West Swan said, “Closer. More variety” (emphasis
              added);
      4.14.6. Stephanie Dyson said, “Local wines and beers”;
      4.14.7. Kylie Pate said, “Not as much local produce”;
      4.14.8. David Campbell said, “Good beer”;
      4.14.9. Wendy McLeish said, “No local produce”;
      4.14.10. Benjamin Campbell said, “Locale (sic) alcohol”.
4.15. In summary, it is open for the licensing authority to conclude the applicant’s
      witness evidence shows respondents would be interested in a packaged liquor
      outlet located closer to their homes which featured locally made liquor
      products.
4.16. When questionnaire respondents were asked, where they currently buy their
      packaged/ take-away liquor from;
     4.16.1. Karen Harley said, “First Choice Liquor Ellenbrook”, but when asked
             why she currently shops at that outlet she said, “Closest to home at the
             moment. I am planning on buying in Dayton and would love a liquor
             outlet closer to home”. When asked her opinion about the standard of
             premises, atmosphere and service at her chosen outlets, she said “Okay
             just not all products are always available”. Then, when Karen was
             asked if the product range at that outlet was suitable for her purposes,
             she said, “Its (sic) okay would like a wider range of the Swan Valley
             wines”.
    4.16.2. Harsinman Kaur who lives in Dayton said she currently shops for her
            packaged liquor in “Midland”, but when asked if Midland was suitably
            located for her needs, she said “No”.
    4.16.3. Manpreet Singh of Brabham said she currently shops his/her packaged
            liquor in “Ellenbrook” but when asked why he/she currently shops in
            that suburb she said, “Only close option”. Also, when she was asked if
            that suburb was suitably located for his/her needs, he/she said “No,
            but no choice”.
    4.16.4. Elsa Silva of Brabham said, “Liquorland + First Choice in Ellenbrook”
            but when asked if those outlets were suitably located for her needs,
            she said, “No, not close enough”.
    4.16.5. Vikar, who lives in Dayton said he/she currently shops for her packaged
            liquor in, “Midland”, but when asked if that suburb was suitably located
            for his/her needs, he/she said, “No too far away”.
    4.16.6. Maxime Whittick of Brabham who lives in Dayton said she currently
            shops for her packaged liquor in, “Caversham” but when asked if that
            suburb was suitably located for her needs she said, “Not really, closer
            would be better”.

                           Canford Hospitality Consultants Pty Ltd | Outlet Density   Page 22 of 53
5. Population Growth in the locality
5.1. According to table 4.8 of the September 2017 City of Swan ‘Local Commercial
     Activity Centres Strategy’ background report (Attachment 6), the Urban Growth
     Corridor Local Planning area’ comprises the following suburbs;
     5.1.1. Brabham;
     5.1.2. Dayton;
     5.1.3. Bennett Springs; and
     5.1.4. Caversham.
5.2. Page 58 of that report states;
     5.2.1. “Urban Growth Corridor Local Planning Area
             5.2.1.1. The Urban Growth Corridor Local Planning Area is expected to
                     accommodate significant greenfield residential development
                     over the next 15 years. As a result, the population is forecast
                     to grow from approximately 6,190 persons in 2015 to 31,250
                     persons in 2031, representing an average annual growth rate of
                     10.6% per annum (source: id consulting)”
     5.2.2. “Meeting retail demand:
             5.2.2.1. It is important that retail provision in the Urban Growth
                     Corridor is sufficient to meet the retail and other needs of the
                     rapidly growing resident population in the region.
             5.2.2.2. Flexibility will need to be provided to ensure the development
                     of activity centres meets the needs of the community as it
                     evolves and develops”.
5.3. To further support the above, page 10 of the November 2017 Urbis Retail
     Sustainability Assessment Report (Attachment 1 see paragraph 1.4 above)
     states;
     5.3.1. “The definition of a catchment area for a retail development is based
            on a range of factors including the role of the activity centre, the range
            and appeal of shops/services provided in the subject development, the
            location, quality and relative offer of competing centres/precincts,
            road and public transport accessibility, and physical and geographical
            barriers.
     5.3.2. In order to assess the need, demand and impact of the proposed
            convenience retail node within the Dayton Commercial Centre a
            catchment area covering Dayton and part of Bennett Springs has been
            utilised for the assessment”.
     5.3.3. “The local resident catchment area that is expected to be served by the
            proposed DCC is illustrated in Map 2.1.”
     5.3.4. “the catchment area population is expected to broadly double within
            the next 5 years to approximately 7,600 people by 2022”.

             Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 23 of 53
Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 24 of 53
5.4. Page 12 of that report includes table 2.1 which shows the forecast resident
     population in the Dayton Catchment Area from 2017 to 2037. See below for
     further illustration;

            Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 25 of 53
5.5. Shown below are two aerial images taken from the Nearmap website for 15th
     June 2014, and 17th July 2019, respectively. These maps clearly show the steady
     expansion of residences in the Dayton and Brabham suburbs;
                                     15th June 2014

                The subject
                 premises

                                     17th July 2019

                The subject
                 premises

             Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 26 of 53
2014

2019

       Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 27 of 53
2014

   The subject
    premises

2019

                 The subject
                  premises

                      Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 28 of 53
2014

2019

       Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 29 of 53
5.6. Furthermore, the following two maps as sourced from the Local Commercial
     Activity Centres Strategy’ document show jobs growth in the locality lags behind
     the population growth.

   Source: ABS Census 2011, Destination Zone; MapInfo; Bing Maps

             Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 30 of 53
Source: ABS Regional Population Growth, Cat. 3218.0; MapInfo; Bing Maps
5.7. This is not unusual in urban growth corridors. Residential development
     commonly precedes commercial centres.
5.8. Conclusion: The Dayton suburb and the locality more broadly have
     experienced strong growth in population in recent years, and it is
     forecasted to continue to at least 2037.

            Canford Hospitality Consultants Pty Ltd | Population Growth in the locality   Page 31 of 53
6. Proposed Style of Operation
6.1. As mentioned in paragraph 1.2 above, the proposed liquor store and drive
     through will be part of the new 2,000m2 Dayton Commercial Centre.
6.2. The proposal is for a liquor store of 282sqm and a two-lane drive through of
     165sqm.
6.3. For the convenience of the local community the proposed liquor store will
     feature mainstream liquor products, including;
     6.3.1. A range of WA red, white and sparkling wines,
     6.3.2. Australian and international spirits,
     6.3.3. Mainstream and boutique beers and ciders,
     6.3.4. Ready to drink lines,
     6.3.5. Australian and international wines and champagne, and
     6.3.6. Liqueurs, cognacs, and fortified wines.
6.4. The proposed packaged liquor service will include a range of products from
     local microbreweries, boutique wineries, and local spirit distillers that are not
     readily available at the group owned liquor store in the locality.
6.5. The proposed stock list will be continually evolving as the applicant responds
     to the demands of the local community. The concept is to be agile and nimble,
     and to carry small batch liquor products, especially from WA, according to the
     level of demand. This is something chain liquor stores find especially hard to
     do. Attachment 5 is a sample list of the boutique local liquor products which
     will be featured. Whilst the applicant does not guarantee to stock all of these
     items all of the time, it will stock as many of them as are in demand locally.
6.6. The applicant is seeking the flexibility afforded by the standard trading hours
     in the Liquor Control Act to allow it to respond to the demands of the local
     community in respect of when they would like to shop for their liquor
     requirements.
6.7. The applicant intends to operate the normal trading hours stipulated in Section
     98 of the Liquor Control Act 1988, which are as follows;
     6.7.1. Monday to Saturday from 8am to 10pm;
     6.7.2. Sundays from 10am to 10pm.
6.8. Once the proposed liquor store licence be granted (if granted), the new Dayton
     IGA Supermarket will probably trade longer hours to match the proposed liquor
     store trading hours.
6.9. An approved manager will be in the liquor store during all trading hours
     managing the day to day operations under the liquor licence.
6.10. The Urbis ‘Sustainability Assessment Report’ underlines the appropriateness of
      the drive through component of the proposal, saying;
      6.10.1. “The locational attributes of the subject site satisfy the
              requirements for a car oriented commercial precinct reflecting:

                  Canford Hospitality Consultants Pty Ltd | Proposed Style of Operation   Page 32 of 53
6.10.1.1. The site has a central location in the SUGCSSP and will be
                      conveniently accessible to the resident population on both
                      sides of New Lord Street.
            6.10.1.2. New Lord Street will function as the main arterial road linking
                      Ellenbrook with the Reid Highway and suburbs to the south.
                      This road is expected to carry good volumes of vehicle traffic
                      (35,000 vehicles per day by 2031) and provide high levels of
                      exposure for the range of uses within the precinct. Lord
                      Street, whilst a secondary road in the future, is also expected
                      to carry significant levels of vehicle traffic (9,500 movements
                      per day by 2031).
            6.10.1.3. New Lord Street, in conjunction with Lord Street, will also
                      connect with a number of east-west roads, facilitating access
                      to the site from Dayton and Bennett Springs”.
6.11. Public health and safety posters will be displayed prominently, along with
      responsible service of alcohol messages.

                 Canford Hospitality Consultants Pty Ltd | Proposed Style of Operation   Page 33 of 53
7. Traffic Volumes and Public Transport
7.1. The proposed liquor store will be part of the proposed DCC which will be
     bounded by Cranleigh Street to the south, Lord Street to the east, new (future)
     Lord Street to the west and the extension of Harrow Street to the north
     (currently unnamed and unconstructed).
7.2. According          to          the           Metronet             website
     (https://www.metronet.wa.gov.au/projects/morley-ellenbrook-line);
     7.2.1. “The Morley-Ellenbrook Line is a new 21km rail line that will travel from
            Ellenbrook’s growing town centre, down the western side of New Lord
            Street, through land north of Marshall Road and down the middle of
            Tonkin Highway, connecting at Bayswater Station on the Midland Line.
     7.2.2. Stations will be built in Ellenbrook, Whiteman Park, Malaga, Noranda
            and Morley with a station planned at Bennett Springs East, as population
            levels increase and development progresses in the area.
     7.2.3. Confirming the route and station locations for this line is a result of
            analysing more than 100 potential options to improve transport
            outcomes for Perth’s north-eastern corridor”
7.3. The new Whiteman Park station is to be 1.2km away and the Bennett Springs
     East Station will be 1.8km away from the proposed liquor store, these stations
     will be linked to the DCC by new bus services – see below.
7.4. Attachment 2 of these submissions includes a copy of the ‘Traffic Impact
     Assessment’ dated April 2019 and prepared by Transcore. The subject of that
     report was the DCC and stated as follows;
     7.4.1. “Public Transport
             7.4.1.1. The site is currently served by existing bus routes 955 and 956
                      operating along Lord Street adjacent to the site as shown in
                      Figure 4. These routes run from Ellenbrook to Morley bus
                      station and Bassendean train station. Together they provide
                      four services per hour each way on weekdays, reducing to a
                      half hourly service during late evening periods and on
                      weekends and public holidays. The closest bus stops are
                      located just south of Cranleigh Street and either side of the
                      Repton Street intersection.

          Canford Hospitality Consultants Pty Ltd | Traffic Volumes and Public Transport   Page 34 of 53
7.4.2. “Under the previous planning for the Ellenbrook Bus Rapid Transit Way
            there was proposed to be a number of local feeder bus services through
            the Dayton and Brabham areas, including a local bus route along the
            existing Lord Street alignment adjacent to the subject site and
            connecting to bus stations at Dayton and Brabham. It is anticipated that
            a similar local feeder bus service will be provided along the existing Lord
            Street alignment adjacent to this site to access the future railway
            stations when the rail alignment and station locations are finalised. This
            will provide the appropriate public transport access for the proposed
            commercial precinct as well”.
7.5. Furthermore, on page 26 of the Traffic Impact Assessment it was concluded;
     7.5.1. “Traffic generation has been assessed and the proposed commercial
            precinct is anticipated to attract two-way total traffic flows of
            approximately 14,500 vehicles per day on weekdays. However,
            approximately 6,400vpd of this traffic will be passing trade, which
            means those vehicles will already be passing the site on the surrounding

         Canford Hospitality Consultants Pty Ltd | Traffic Volumes and Public Transport   Page 35 of 53
road network (not new traffic on the surrounding roads) and will turn
      off to visit the site.
7.5.2. The proposed commercial precinct structure plan will include a
       comprehensive network of footpaths and shared paths providing
       pedestrian access within the structure plan area and connection to the
       planned dual use paths on the western side of existing Lord Street.
7.5.3. Existing bus routes already have bus stops on Lord Street adjacent to the
       structure plan area and new feeder bus services for the State
       Government’s future Metronet railway line to Ellenbrook are anticipated
       to continue to provide public transport access for this structure plan area
       in the future”.

    Canford Hospitality Consultants Pty Ltd | Traffic Volumes and Public Transport   Page 36 of 53
8. Background and Experience of the Applicant
8.1. Stanley Horsman is the sole director of the applicant company, Dayton Liquor
     Store Pty Ltd.
8.2. Stanley has engaged Canford Hospitality Consultants services, to assist him with
     an application for a liquor store licence for this premises.
8.3. Stanley will employ an experienced liquor store manager, who will be required
     to:
     8.3.1. Undertake the following approved courses;
             8.3.1.1. “Provide Responsible Service of Alcohol (SITHFAB002)
                      (nationally accredited);
             8.3.1.2. Course in Management of Licensed Premises (MLPLCA401A).
     8.3.2. Demonstrate significant experience in the liquor trade and wide
            knowledge in local wine, beer and spirits;
     8.3.3. Be in charge of the day to day operations of the licensed premises;
     8.3.4. Identify customer requirements and deliver the product which meets
            their needs;
     8.3.5. Be responsible for the liquor store’s inventory;
     8.3.6. manage ordering, stocktakes, receive liquor orders and check against
            purchase orders for accuracy;
     8.3.7. Ensure a safe environment for customers and staff; and
     8.3.8. Ensure store presentation standards are met.

                                  Proposed Dayton Liquor Store

     Canford Hospitality Consultants Pty Ltd | Background and Experience of the Applicant   Page 37 of 53
9. Risk Assessment with respect to Harm and Ill Health
  9.1. Section 38(4)(a) of the Liquor Control Act (1988) asks the applicant to consider
       “the harm or ill-health that might be caused to people, or any group of people,
       due to the use of liquor.”
  9.2. The demographics of the locality have been discussed in some detail in section
       3 of these submissions and concluded this is a stable and affluent locality with
       a below average representation of all the priority groups identified.
  9.3. In any case a liquor store licence does not have the same potential for harm or
       ill health as some other licence types do. In a decision (LC 21/2009) confirming
       the Wine Box Nedlands liquor store licence, the Liquor Commission at 4.11, on
       page 13 of that decision noted;
         9.3.1. “It is the Commission’s view that a liquor store licence, as part of the
                Nedlands IGA grocery outlet, is very much at the passive end of liquor
                licence approvals and in particular, is unlikely to have any bearing
                on.... liquor consumption practices”.
  9.4. According to the Federal Government’s Snapshot entitled Australia’s Health
       2018;
         9.4.1. “most Australians drink alcohol at levels that cause few harmful
                effects”. (Page 204)
         9.4.2. “As well, fewer Australians are drinking at levels that contribute to
                alcohol-related harm over a lifetime. However, about 26% of people
                drink more than is recommended on a single occasion, and they do this
                at least once each month. Younger people show more promising trends
                when it comes to alcohol—fewer people aged 12–17 are drinking and a
                greater proportion are abstaining from drinking altogether.” (Page
                165, emphasis added)
         9.4.3. “The NDSHS data reveal several changes in drinking patterns compared
                with those for 2013, including that:
                    9.4.3.1. people are drinking less often—daily and weekly drinking
                             rates have declined
                    9.4.3.2. fewer young people aged 12–17 are drinking alcohol and the
                             proportion abstaining from alcohol has increased
                    9.4.3.3. people aged 14–24 are delaying starting to drink—the average
                             age at which they first tried alcohol has increased
                    9.4.3.4. fewer people are exceeding the lifetime risk guideline (Table
                             4.6.1).” (Page 204)

Canford Hospitality Consultants Pty Ltd | Risk Assessment with respect to Harm and Ill Health   Page 38 of 53
9.5. The Snapshot, in a section titled “Alcohol-related incidents and harm” also
       states;
         9.5.1. Excessive consumption of alcohol increases the risk of people putting
                themselves and others at risk of harm (AIHW 2017). The NDSHS showed
                that, in 2016 almost 1 in 6 (17%) recent drinkers aged 14 and over put
                themselves or others at risk of harm while under the influence of
                alcohol in the previous 12 months—significantly down from 21% in 2013.
                In 2016, the most likely risky activity undertaken while under the
                influence of alcohol was driving a motor vehicle (9.9% of recent
                drinkers). Overall, more than 1 in 5 (22%) Australians had been a victim
                of an alcohol-related incident in 2016—down from 26% in 2013.
                Between 2013 and 2016, verbal abuse (22% and 19%, respectively),
                being put in fear (13% and 11%) and physical abuse (8.7% and 7.3%) all
                declined.” (Page 206, emphasis added)
  9.6.    In October 2019, the applicant sought to investigate the incidence of alcohol
          related offences within the locality, and other nearby towns as recorded by
          the WA police. However, no statistics were available on the WA Police website
          in relation to alcohol related crime for any towns in WA.
  9.7.    Therefore, the applicant was unable to properly consider the current level of
          harm or ill-health that might be caused to people, or any group of people in
          the locality, due to the use of liquor.
  9.8.    The applicant then considered the crime statistics in the locality and WA.
          Attachment 7 includes the crime data for those suburbs and WA. Using these
          figures, the applicant calculated the number of offences per 1,000 population
          in 2015-16 in the locality, being the year of the last Census.
  9.9.    The following method was used to obtain the number of offences per 1,000 of
          population in 2016;
                          Number of reported offences in 2015-16 x 1,000
                                       Population in 2016
  9.10. As a result of the above calculation the locality had a below average crime
        rate (84 offences per 1,000 population) compared to WA as a whole (119
        offences).
  9.11. When questionnaire respondents were asked if they believed any people, or
        groups of people in the locality, would be at risk of increased and undue harm
        should this liquor licence be granted;

Canford Hospitality Consultants Pty Ltd | Risk Assessment with respect to Harm and Ill Health   Page 39 of 53
9.11.1. Jacinta Eyre said, “No, I don’t believe anyone would be at risk”;
          9.11.2. Shannon Stone said, “No risk, advocate responsible drinking”.
          9.11.3. Gurvinder Singh said, “Dayton locaility (sic) is pure private estate
                  and small estate. I havent found and (sic) trouble yet”;
  9.12. The following factors will mitigate the potential for the proposed liquor store
        to add materially to the harm and ill-health currently experienced in the
        locality due to the use of liquor;
          9.12.1. The store will be designed with clear lines of sight to all customer
                  areas.
          9.12.2. The interior and exterior of the store will be brightly lit.
          9.12.3. Generally, the layout of the liquor store has been planned to avoid
                  blind spots.
          9.12.4. The point of sale and service counter is strategically positioned to
                  allow easy monitoring of the whole liquor store.
          9.12.5. Bottles of wine and spirits with a high value will be kept in locked
                  cabinets, with access only by staff upon specific request.
          9.12.6. An approved manager will be in the liquor store during all trading
                  hours managing the day to day operations.
          9.12.7. The applicant has advised that Closed Circuit TV (CCTV) will be
                  installed at the proposed liquor store, which will be able to retain
                  images for twenty-eight (28) days in accordance with the Director’s
                  policy.
  9.13. Staff will be trained to adopt the following additional strategies;
          9.13.1. The store shelving, and the stock on those shelves will be kept at a
                  low level so as not to impede lines of sight across the browse area.
                  Therefore, staff can very easily monitor customer activity, thus
                  deterring would be thieves from trying to conceal a bottle.
          9.13.2. The best way to deter theft is to watch customers and would-be
                  thieves.
          9.13.3. Staff will be trained to approach customers if they look suspicious
                  and offer to assist them. Even if they decline the assistance, staff are
                  to stay with them, and engage them in conversation and eye contact.
                  If they are not genuine customers, they will soon leave.
          9.13.4. There will be a bell behind the service counter. As staff will often be
                  occupied in the back of the store unpacking stock etc., this bell is to
                  alert that staff member that a group of people have entered the store
                  or are about to enter. The staff member at the back is to immediately
                  stop what they are doing, and return to the shop floor, there must be
                  no delay.
          9.13.5. The liquor store is to be equipped with many CCTV cameras.
                  However, these are not simply to record activity, they are a deterrent
                  to crime. Viewing screens are positioned behind the service counter
                  where staff can easily monitor them, and thereby monitor activity in

Canford Hospitality Consultants Pty Ltd | Risk Assessment with respect to Harm and Ill Health   Page 40 of 53
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