Grant of Liquor Store Licence Public Interest Assessment BWS Midvale
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Grant of Liquor Store Licence Public Interest Assessment BWS Midvale 27 October 2020 47695454_7
Contents
ABOUT THIS APPLICATION 1
Part 1 - Background Information 2
A. Premises 2
1 The Midvale Shopping Centre 2
2 The Proposed Store 2
3 Development Approval 2
B. The Business to be operated at the Proposed Store 3
1 Background of Endeavour Group Limited 3
2 Overview of BWS 3
2.1 BWS Products 5
2.2 Success of the BWS brand 5
2.3 Responsible management 6
Part 2 – Tests to be satisfied 7
A The Public Interest Test and Packaged Liquor
Requirements 7
1 What is the 'Public Interest Test'? 7
2 What needs to be satisfied to meet the Public Interest Test? 7
2.1 Primary and secondary objects 7
2.2 Additional factors 8
3 Packaged liquor requirements 8
4 About this PIA 9
B. Locality 11
1 Defining the Locality 11
2 Location of Proposed Store 11
3 Farrall Road Structure Plan – Movida Estate 12
4 Strategic Planning Framework 13
5 Demographics 13
5.1 Current Population and Forecasts 13
5.2 Age Profile 14
5.3 Migrants 15
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5.4 Household Composition 15
5.5 Employment 15
5.6 Socio-economic status 15
5.7 Summary 16
6 Sensitive Premises 17
C. Other Licensed Premises in the Locality 18
1 Licensed Premises 18
1.1 Existing Packaged Liquor Services 18
1.2 Distribution of Existing Premises 25
1.3 Ease of Access to the Existing Premises 26
1.4 Summary 28
D. Consumer Requirement and the Proper Development of
the Industry 29
1 Australian Liquor Market 29
1.1 Changes in the way that we shop 29
1.2 BWS Customers 30
2 Community Survey 30
2.1 The Results 31
E. How does the proposal address the minimisation of harm
and ill health? 35
1 Current Alcohol Consumption Trends in Australia and Western Australia 35
1.1 Australia 36
1.2 Western Australia 37
2 Alcohol Related Harm 38
2.1 Hospitalisation, Mortality and Alcohol Consumption rates 38
2.2 VicHealth Study 39
2.3 Crime Rates 40
2.4 Community Safety 41
3 Harm Minimisation Management 41
3.1 Effective management 41
3.2 Management practices, staff training and RSA 42
3.3 Environmental factors: Crime prevention through
environmental design 43
3.4 Responsible buying 43
3.5 Community education 44
3.6 Community involvement 44
4 Impact on Specific at Risk Groups 45
4.1 At risk groups 45
F. Other Factors 47
1 The amenity, quiet or good order of the Locality – Section 38(4)(b) 47
1.1 Retail Amenity 47
1.2 Quiet and good order 47
1.3 One-stop shopping 47
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1.4 Physical amenity 48
2 Offence, annoyance, disturbance or inconvenience 49
2.1 Trading hours 49
2.2 Traffic 49
2.3 Noise 49
2.4 Security and management 49
3 Tourism, or Community or cultural matters 49
H. CONCLUSION 51
I. FURTHER INFORMATION 53
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ABOUT THIS APPLICATION
Endeavour Group Limited (Endeavour or the Applicant) is applying for the grant of a
liquor store licence for a new BWS liquor store (Proposed Store) to be located within the
new Midvale Shopping Centre (Shopping Centre), which is to be constructed at 227
Morrison Road, Midvale, Western Australia.
This Public Interest Assessment (PIA) is presented in support of an application to the
Director of Liquor Licensing for the grant of a liquor store licence in respect of the
Proposed Store.
Under section 38(2) of the Liquor Control Act 1988 (WA) (Act), the Applicant must satisfy
the Licensing Authority that, on the merits of the application, it is in the public interest to
grant the licence (the 'public interest test'). As stated in McKinnon v Secretary
Department of Treasury:
“The expression ‘in the public interest’ directs attention to that conclusion or
determination which best serves the advancement of the interest or welfare of
the public, society or the nation and its content will depend on each particular set
of circumstances.” 1
The Applicant submits that the granting of the liquor licence for the Proposed Store will be
in the public interest and will contribute to the responsible development of the liquor
industry in the locality where the Proposed Store will be located.
The Applicant must also satisfy the licensing authority that local packaged liquor
requirements cannot reasonably be met by the existing packaged liquor outlets in the
locality pursuant to s36B(4) of the Act.
The Applicant submits that it has provided sufficient evidence in this PIA to satisfy the
packaged liquor requirement threshold test.
This PIA is divided into 2 parts:
(a) Part 1 outlines the background of the application and the development of
the Proposed Store; and
(b) Part 2 addresses the elements of the public interest test and
demonstrates that the test is satisfied in respect of the Proposed Store. It
also demonstrates that the local packaged liquor requirements cannot
reasonably be met by existing packaged liquor premises in the locality.
1 (2005) 220 ALR 587, 590
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Part 1 - Background Information
A. Premises
This section of the PIA summarises the plans for the Proposed Store.
1 The Midvale Shopping Centre
The Midvale Shopping Centre will consist of a full-scale Woolworths supermarket
(4,000 sqm) (Supermarket), the Proposed Store (170 sqm) and approximately
15 specialty/commercial tenancies. The Shopping Centre, including the
Supermarket, is expected to open in November 2021. There will be 316 on-grade
car parking spaces available at the Shopping Centre.
A site plan of the Shopping Centre can be found at Annexure A.
The Proposed Store will primarily service residents within the suburb of Midvale.
2 The Proposed Store
The Proposed Store will be approximately 170 sqm in size and hold stock worth
approximately $240,000. The Proposed Store will be in the typical BW S format
and will employ 3 full time staff and 5 permanent part-time/casual staff. A plan of
the Proposed Store is attached at Annexure B.
The Proposed Store will open at the following times:
Monday to Friday 8am – 9pm
Saturday 8am – 5pm
Sunday 11am – 5pm
The Proposed Store will be located adjacent to the Woolworths supermarket to
provide the opportunity for single-trolley grocery and liquor purchases.
3 Development Approval
Development Approval was granted by the City of Swan on 3 August 2020.
The Proposed Store will form part of a new neighbourhood shopping centre
that will include a full-scale Woolworths supermarket. The Proposed Store
will be adjacent to the Woolworths supermarket. Development Approval has
been granted.
King & Wood Mallesons PIA – BWS Midvale 2
47695454_7 27 October 2020
B. The Business to be operated at the
Proposed Store
1 Background of Endeavour Group Limited
On 3 & 4 February 2020, Woolworths Group Limited (Woolworths) merged its
drinks and hospitality businesses, Endeavour Drinks and ALH Group Pty Ltd
(ALH), into a single entity within Woolworths known as Endeavour Group Limited.
The merger of Endeavour Drinks and ALH has created Australia’s largest
integrated drinks and hospitality business with sales of approximately $10 billion
and EBITDA12 of $1 billion. Endeavour will have leading market positions, strong
cash flow to fund investments in growth and an attractive and resilient revenue
and earnings profile. It will comprise highly integrated store-based and online
offerings, with over 1,500 BWS and Dan Murphy's retail drinks outlets and 327
ALH hotels. ALH retail drinks outlets currently comprise approximately 35% of
Woolworths Group retail drinks sales with 86 Dan Murphy’s and 512 BWS stores
owned by ALH at the end of March 2019.
Endeavour continues to uphold the strict policies and practices for licensed
premises implemented by Woolworths.
2 Overview of BWS
BWS stores are liquor stores which provide convenience to customers. Part of
the popularity of BWS is the locations of the stores in neighbourhood shopping
centres either as stand-alone stores or adjacent to Woolworths supermarkets.
After Dan Murphy's, BWS is the second most popular store for purchasers of
packaged liquor.3
Figure 1: Market share over time: supermarket liquor stores’ total alcohol retail share of
dollars
2 EBITA – Earnings before interest, taxes, and amortization
3 Roy Morgan (20/03/2017) 'The Australian alcohol retail market in review' - accessed at
http://www.rovmorgan.com/findings/7181-liquor-retail-australia-201703201051
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As a dominant player in the alcohol retail industry, Endeavour (formerly
Woolworths) has maintained the highest market penetration among alcohol
retailers in Australia. Data released by Roy Morgan in September 2019, revealed
that 60.7% of Australian alcohol buyers purchased from a Woolworths-owned
store in an average four-week period.4 37% of these consumers purchase
exclusively from Woolworths stores (now owned by Endeavour).5
Figure 2: Cross visitation of alcohol retail consumers
Morgan Single Source Australia, July 2018 – June 2019, n=6,829. Base: Australians aged 18+ who
had purchased packaged alcohol in the past four weeks.
The BWS customer base appears to be increasing at impressive levels. Over a
period of 12 months leading to September 2018 BWS increased its customer
base by 9.3%.6
Figure 3:
4
Roy Morgan (02/09/2019) ‘Woolworths bottle shops prove must popular’ – accessed at
http://www.roymorgan.com/findings/8114-alcohol-retail-cross-visitation-june-2019-
201908300757
5 Ibid.
6
Roy Morgan (8/11/2018) ‘Supermarkets continue to take alcohol market share from hotel bottle-
shops’ – accessed at http://www.roymorgan.com/findings/7753-supermarkets-continue-to-take-
alcohol-market-share-from-bottle-shops-201811080408
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Recent Roy Morgan research has found that ‘[for] BWS it is the 845,000
Australians aged 35-49 years of age who comprise the largest share of their
customers’7
2.1 BWS Products
BWS offers a comprehensive range of liquor products, including local and
international beer, wine and spirits. The range is focused on popular brands and
includes brands sold exclusively through Endeavour’s liquor stores. As such, the
Proposed Store will provide local residents with some products that cannot be
supplied by many of the other existing liquor stores in the local area.
Approximately 1,671 products will be available at the store, comprised of the
following:
Item Number of products
Beer 221
White wine 308
Sparkling wine 111
Red wine 314
Fortified and cask wines 90
Ciders 116
RTD's 146
Glass spirits 285
Snack foods, soft drinks and cigarettes 80
Total 1,671
2.2 Success of the BWS brand
As discussed in the decision of the Supreme Court regarding the application for
Dan Murphy's Bicton, the popularity and success of a brand in other locations
can be assessed and applied to the current application where relevant.8 BWS
has built a strong reputation as both a stand-alone neighbourhood liquor store
and as a co-located liquor and supermarket store. The key drivers of purchase
intention at BWS are:9
(a) Location and access (36%);
(b) Quality (33%); and
(c) Customer service (28%)
A BWS store is usually located at the front of the Woolworths supermarket or
directly adjacent to it. This means the store is convenient to both customers who
only want to purchase packaged liquor, as well as those customers who are
purchasing liquor as part of their grocery shop. It is part of a 'one-stop' shopping
experience allowing consumers to purchase all their weekly food and liquor
purchases in one shop. BWS has built its popularity on the basis of its’
convenience for customers, with 46% of people indicating that they purchase
packaged liquor as part of their grocery shopping or other shopping trip.10
7
Ibid
8
Woolworths Ltd v Director of Liquor Licensing [2013] WASCA 227.
9
Statement of Anthony Smith at para 4.7(b)
10 ibid at paragraph 4.6
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Further information about BWS is contained in the statement of Anthony Smith
attached at Annexure C.
2.3 Responsible management
BWS operates under Endeavour’s strict policies and procedures for its licensed
premises. Endeavour implements best practice harm minimisation policies to
assist with management of alcohol in the community. These policies are
discussed in further detail below and include responsible service of alcohol
(RSA) training for staff, educational campaigns and responsible buying
guidelines.
The BW S brand is based on convenience. BW S stores have been incorporated
into Woolworths’ supermarket offerings to provide a 'one-stop' shopping
experience which has become an essential part of Australian life. BW S is a
comprehensive liquor store which provides a good range of products.
King & Wood Mallesons PIA – BWS Midvale 6
47695454_7 27 October 2020Part 2 – Tests to be satisfied
A The Public Interest Test and Packaged
Liquor Requirements
1 What is the 'Public Interest Test'?
For the application to be approved, the Applicant must satisfy the Director that
granting the application is in the public interest pursuant to s 38(2) of the Act.
While the Act does not define 'public interest', the Department of Local
Government, Sport and Cultural Industries (DLGSC) policy refers to the
Butterworth’s Australian Legal Dictionary as follows:
"an interest in common to the public at large or a significant portion of the
public and which may or may not involve the personal or propriety rights
of individual people."11
A general discretion by reference to the criterion of the 'public interest' is not an
unfettered discretion but will ordinarily be confined by the scope and purpose of
the statute.12
2 What needs to be satisfied to meet the Public Interest
Test?
2.1 Primary and secondary objects
In assessing whether the Application is in the public interest, the Licensing
Authority is bound to take into account the primary objects of the Act, and to the
extent that they are not inconsistent with those primary objects, the secondary
objects.13 The primary and secondary objects of the Act set out in s 5 are:
Primary Objects:
(a) to regulate the sale, supply and consumption of liquor;
(b) to minimise harm or ill-health caused to people, or any group of people,
due t the use of liquor; and
(c) to cater for the requirements of consumers for liquor and related
services, with regard to the proper development of the liquor industry,
the tourism industry and other hospitality industries in the State.
Along with the primary objects, the Licensing Authority must also have regard to
the secondary objects of the Act, which are:
(a) to facilitate the use and development of licensed facilities, including their
use and development for the performance of live original music,
reflecting the diversity of the requirements of consumers in the State;
11 Department of Local Government, Sport and Cultural Industries (29 May 2019) ‘Public Interest
Assessment policy’ at p1.
12
Woolworths v Director of Liquor Licensing [2013] WASCA 227 at [48]
13 ibid at [49]
King & Wood Mallesons PIA – BWS Midvale 7
47695454_7 27 October 2020(b) to provide adequate controls over the sale, disposal and consumption of
liquor;
(c) to provide a flexible system, with as little formality or technicality as may
be practicable;
(d) to encourage responsible attitudes and practices towards the promotion,
sale, supply, service and consumption of liquor that are consistent with
the interests of the community.
The licensing authority's obligation to take account of the primary and secondary
object is not diminished by the unfettered terms of the discretion conferred by
s33 of the Act. That section does not confer upon the Licensing Authority an
unlimited power, but instead that power must be exercised consistently with the
primary and secondary objects.14
2.2 Additional factors
The Licensing Authority is entitled to take into account the factual matters set out
in s 38(4) in determining whether it is satisfied that the granting of the Application
is in the public interest.15 These factual matters are as follows:
(a) the harm or ill-health that might be caused to people, or any group of
people, due to the use of liquor;
(b) the impact on the amenity, quiet or good order of the locality in which the
licensed premises, or proposed licensed premises are to be situated;
(c) whether offence, annoyance, disturbance or inconvenience might be
caused to people who reside or work in the vicinity of the licensed
premises or proposed licensed premises;
(d) any effect the granting of the application might have in relation to
tourism, or community or cultural matters; and
(e) any other prescribed matter.
It should be noted that s 5(2) of the Act is mandatory whereas s 38(4) is
permissive.16
3 Packaged liquor requirements
The Act was amended on 2 November 2019 to incorporate restrictions on the
grant or removal of certain licences authorising the sale of packaged liquor.
Section 36B(4) provides :
The licensing authority must not grant an application to which this section applies
unless satisfied that local packaged liquor requirements cannot reasonably be
met by existing packaged liquor premises in the locality in which the proposed
licensed premises are, or are to be, situated.
It is submitted that this section provides that the licensing authority must not
grant an application for a liquor store licence if the existing premises selling
packaged liquor in the area from which the customers of the new liquor store
14
ibid at [53] - [54]
15
ibid at [50]
16 ibid at [49]
King & Wood Mallesons PIA – BWS Midvale 8
47695454_7 27 October 2020would come are already able to meet the requirements of those customers for
packaged liquor.
In assessing whether the Application meets the local packaged liquor threshold
test, the Licensing Authority is again bound to take into account the primary
objects of the Act, and to the extent that they are not inconsistent with those
primary objects, the secondary objects. The objects of the Act are mandatory
relevant considerations which inform both the public interest test under s38(2)
and the assessment to be made under s36B(4).
In the recent decision for BWS Inglewood A775016681 (Inglewood Decision) it
was submitted by the Director of Liquor Licensing that in order to satisfy s36B(4)
of the Act
‘it is necessary for an applicant to adduce relevant probative evidence upon
which the licensing authority can make findings of fact as to:
what the local packaged liquor requirements are; and
what packaged liquor services are currently provided by the existing
packaged liquor premises in the locality’
The Licensing Authority is then ‘required to make a value judgement as to
whether the local packaged liquor requirements can reasonably be met by the
existing packaged liquor premises in the locality.’
The Director of Liquor Licensing provided further detail at para 36 of the
Inglewood Decision where it was submitted that in making a ‘value judgement’
consideration should be given to the following relevant factors:
the existing packaged liquor services in the locality;
distribution of premises in the locality; and
ease of access to the existing premises.
It was submitted that:
‘this is not an exhaustive list as ultimately the value judgment will be guided by
the facts and circumstances of each case and the evidence provided by the
applicant’.
The Applicant submits that in summary the following factors are relevant in
applying s36B(4):
The locality of the Proposed Store;
The requirements of consumers for packaged liquor in the locality; and
The extent to which existing packaged liquor premises in the locality
meet the requirements of consumers.
4 About this PIA
The role of this PIA is to address each of the objects outlined in the Act with
regard to the specific premises. In order to satisfy the public interest test the
Applicant has completed research, engaged various experts and conducted
community consultation, including:
(a) engaging MGA Town Planners to provide planning and demographic
data for the locality;
(b) undertaking research and analysis of data on alcohol-related harm and
health, alcohol purchasing habits and social issues in the locality;
King & Wood Mallesons PIA – BWS Midvale 9
47695454_7 27 October 2020(c) engaging Painted Dog to design and conduct an on-line community
survey with residents in the locality; and
(d) undertaking a review of other packaged liquor outlets in the locality.
Part 2 of this PIA addresses the requirements of the public interest
test and the new packaged liquor restrictions with reference to the
various expert reports and data collected by Endeavour.
King & Wood Mallesons PIA – BWS Midvale 10
47695454_7 27 October 2020B. Locality
This section of the report defines the locality for the purposes of this PIA.
1 Defining the Locality
The Licensing Authority describes the locality to be the area which is generally
considered to be most impacted if the application is granted. 17 In this Application
the Locality is 3km as the Proposed Store is more than 15km outside of the Perth
CBD, but within the Metropolitan Region Scheme administered by the WA
Planning Commission (Locality).
However, depending on the nature of the application, the Licensing Authority
may determine a different locality radius for a specific application, particularly
where the potential impact on a specific sub-community or 'at risk' group is such
that reference to this sub-community should also be made, notwithstanding that
this group may be situated outside the 3km radius of the proposed licensed
premises.
Therefore, the onus is on the Applicant to identify any potential 'at risk' groups
which may travel through or make use of the Proposed Store, or who may be
impacted by the Proposed Store. This may include a group of people not
situated within the boundaries of the town or suburb in which the Proposed Store
will be located.
In the case of this Application the Applicant is satisfied that the 3km radius is
appropriate.
The Locality may be described as outer-metropolitan, positioned approximately
19km north east of Perth CBD. The Locality takes in the suburbs of Midland,
Midvale, Bellevue, Koongamia, Stratton and portions of Middle Swan, Jane
Brook, Greenmount and Swan View.
A plan of the Locality is attached at Annexure D.
2 Location of Proposed Store
The Proposed Store will form part of the soon to be constructed Midvale
Shopping Centre. The Shopping Centre and the Proposed Store will be located
in the local government municipality of the City of Swan in the centre of the
suburb of Midvale.
Midvale is a rapidly developing suburb located approximately 19kms north east
of the Perth CBD.
The Shopping Centre land is zoned ‘Urban’ under the Metropolitan Region
Scheme. It is generally surrounded by low and medium density residential area,
along with a large portion of land which is currently being developed into a
residential estate (discussed in more detail below at paragraph 3).
Public transport is easily accessible within the Locality, with 5 bus services
passing along Morrison Road immediately south of the Proposed Store.
Dedicated pedestrian walkways will also be provided to facilitate safe access
around the Shopping Centre and through the car park.
17 Department of Racing, Gaming and Liquor, 'Public Interest Assessment Pursuant to section 38
of the Liquor Control Act 1988', Attachment 2 - Specification of 'Locality'.
King & Wood Mallesons PIA – BWS Midvale 11
47695454_7 27 October 20203 Farrall Road Structure Plan – Movida Estate
The subject land is immediately adjacent to the Farrall Road Structure Plan Area,
which is currently being developed by Peet and Co into a residential estate.
Coined the ‘Movida Estate’, the development will increase housing options within
the suburb of Midvale, with an estimated yield of between 1,200 to 1,300
dwellings. The development will provide a range of housing types which will
appeal to a variety of demographics. The figure below depicts the location of the
Proposed Store (labelled Midvale Neighbourhood Centre Investigation Area), in
relation to the Farrall Road Structure Plan area.
Figure 4: Farrall Road Structure Plan Area
Assuming a usual household occupancy rate of 2.4 persons per dwelling, the
Movida Estate will see an influx of approximately 3,000 persons into the suburb
of Midvale. This increased population will contribute to the economic and capital
growth already experienced within the suburb and will increase demand for retail
amenities. The Proposed Store and accompanying Supermarket are intended to
satisfy this demand by providing residents with conveniently located amenities.
King & Wood Mallesons PIA – BWS Midvale 12
47695454_7 27 October 2020The residential development will also be accompanied by a new and upgraded
local street network, which will ensure the safe and efficient flow of traffic,
pedestrians and cyclists around the site and to the Shopping Centre.18
4 Strategic Planning Framework
The Western Australian Planning Commission administers State Planning Policy
4.2 - Activity centres for Perth and Peel (State Planning Policy). This policy sets
out the strategic distribution of activity centres and a hierarchy meeting different
levels of community need.
The Midvale Shopping Centre is classified as a neighbourhood activity centre
under the State Planning Policy. Neighbourhood activity centres are described
as:
‘an integral part of the activity centre hierarchy as they provide the day-to-day
and weekly shopping and other services to their surrounding communities. It is
important that the level of access to neighbourhood centres is maximised as
neighbourhood centres provide a wide-range of essential services. A network of
easily accessible neighbourhood centres supports the broader land use planning
principles outlined by the State Government (e.g. reduce car travel).’
The land on which the Proposed Store and Shopping Centre will be built is not
specifically mentioned in the State Planning Policy. However, Midvale is
identified in the City of Swan Local Commercial and Activity Centres Strategy
(2017) (LCAS) as an area that is ‘not currently well served by full-line
supermarket facilities or attractive, well-designed neighborhood centres’.19 The
Proposed Store and Shopping Centre will satisfy this consumer requirement for
improved retail amenity in Midvale. The need for the Shopping Centre and the
Proposed Store is now even greater given the imminent completion of the
Movida Estate.
The subject land is located within the North-East sub-region of the Perth and
Peel @3.5 million framework. The North-East sub-region has a population
expected to grow from 209,000 people in 2011 to over 450,000 people by 2050.
The North East Sub-Regional Planning Framework identifies the importance of
the development of new and existing activity centres into vibrant, mixed use
community hubs to achieve a level of service to cater for the growing population.
The Proposed Store and Shopping Centre meet that objective.20
5 Demographics
The following demographic analysis has been prepared by MGA Town Planners
based on the 2016 Census data.21 The 2011 Census has been used to indicate
recent trends.
5.1 Current Population and Forecasts
Between the 2011 and 2016 census the population in the Locality has increased
steadily however it is expected to increase significantly in the coming year(s) as a
result of the aforementioned Movida Estate.
18 Ordinary Meeting of Council, Proposed Local Structure Plan No. 42 – Lots 102 and 427 Farrall
Road, Stratton and Lot 50 (No.53) Farrall Road, Midvale (20 January 2016) at p4.
19 City of Swan Local Commercial and Activity Centres Strategy at p 17
20 Department of Planning, Lands and Heritage (March 2018) ‘North-East Sub-regional Planning
Framework’ at p19
21 MGA Town Planners (August 2020) 'Proposed BWS Liquor Store’
King & Wood Mallesons PIA – BWS Midvale 13
47695454_7 27 October 2020According to Forecast ID the population in the suburbs of Midvale, Stratton and
Jane Brook is expected to increase from 9,912 (in 2016) to 14,519 by 2031. This
is a 46.5% increase in population between 2016 and 2031.
Table 1: ID Population Forecasts – 2016-203122
Location Population 2016 Population 2031
Midvale – Stratton – 9,912 14,519
Jane brook
Strong population growth projections, in conjunction with the anticipated
population growth associated with the development of the Farrall Road Structure
Plan Area, will increase the demand for the provision of retail outlets such as the
Proposed Store. These figures are also in line with the strategic planning for the
Locality as discussed above at paragraph 4.
Table 2 below shows the population in each of the suburbs forming the Locality
at the time of the 2016 Census. It can be seen that Swan View makes up the
majority of the Locality (26.20%), followed by Midland (23.63%). Following the
development of the Movida Estate and the influx of residents, it is likely that
Midvale will make up a much larger portion of the Locality.
Table 2: Population by Suburb – 2016 Census23
Suburb Population 2016 Portion of Locality (%)
Swan View 6,626 26.20%
Midland 5,975 23.63%
Stratton 3,319 13.12%
Middle Swan 2,328 9.21%
Greenmount 1,800 7.12%
Bellevue 1,526 6.03%
Midvale 1,480 5.85%
Jane Brook 1,247 4.93%
Koongamia 989 3.91%
5.2 Age Profile
The socio-demographic profile of the Locality's population at 2016 shows that the
Locality is home to a lower proportion of minors (18.5%) compared to the Greater
Perth area (19.1%) and the State (19.3%). In addition, there is a lower proportion
of those aged 15-19 in the Locality (5.8%) compared to the Greater Perth area
(6.2%) and the State (6.1%).
22
Table 1, shows the Forecast ID Population Projects for a cluster of suburbs. The totals for the
suburbs are for the entire suburb areas, and therefore do not reflect the portion of these
suburbs in the Locality (accessed at: https://forecast.id.com.au/swan )
23 MGA Town Planners (August 2020) 'Proposed BWS Liquor Store (BWS Midvale), Table 2,
shows the population within each suburb, or portion thereof, contained within the Locality
King & Wood Mallesons PIA – BWS Midvale 14
47695454_7 27 October 2020The proportion of those aged 20-39 in the Locality (29.6%) is similar to the
proportion throughout the Greater Perth area (29.7%) and the State (28.8%).
There is a higher proportion of people aged 60 and over (21%) in the Locality in
comparison to the Greater Perth area (18.9%).
The data reveals that the population is relatively aged.
5.3 Migrants
The proportion of Australian born persons in the Locality (64.4%) is higher than
that of the Greater Perth area (57.4%) and the State (60.5%). The Locality has a
lower proportion of persons born in non-English speaking countries (17.1%) than
the Greater Perth area (18.7%). In addition, English proficiency is high in the
Locality, with only 1.7% of persons in the Locality not speaking English well or at
all, in comparison to 2.3% throughout the Greater Perth area.
5.4 Household Composition
The Locality is dominated by single-person households (30.2%). This is higher
than the proportion of single-person households in the Greater Perth area
(23.0%) and the State (23.6).
The proportion of family households in the Locality (65.6%) is lower than the
Greater Perth area (73.0%) and the State (72.7%).
The proportion of couple families with children in the Locality (39.2%) is lower
than the Greater Perth area (46.3%) and the State (45.3%). The proportion of
couples having no children in the Locality (34.7%) is lower than both the Greater
Perth average (37.5%) and the State (38.5%).
The proportion of couple families with children in the Locality is expected to
increase alongside the completion of the Movida Estate, as the dwellings within
the estate will primarily attract this demographic.
5.5 Employment
Unemployment across the Locality (7.4%) is lower than the Greater Perth area
and the State (8.1% and 7.8%, respectively).
In addition, employment in the mining industry within the Locality (3.9%) is lower
than the Greater Perth area (4.6%).
5.6 Socio-economic status
The index of Relative Socio-Economic Advantage/Disadvantage (IRSAD) for the
Locality is as follows:
Table 3: SEIFA rankings
Relative Socio-Economic
Suburb Advantage/Disadvantage rank (National)
Jane Brook 8
Greenmount 7
Swan View 4
King & Wood Mallesons PIA – BWS Midvale 15
47695454_7 27 October 2020Relative Socio-Economic
Suburb Advantage/Disadvantage rank (National)
Bellevue 2
Stratton 2
Koongamia 1
Midvale 1
Middle Swan 2
Midland 1
The IRSAD summarises variables that indicate either relative advantage or
disadvantage. This index ranks areas on a continuum from most disadvantaged
to most advantaged. An area with a high score on this index has a relatively high
incidence of advantage and a relatively low incidence of disadvantage.
The suburbs of Jane Brook and Greenmount were identified as having SEIFA
rankings exceeding national median rankings. Residents in these suburbs are
expected to be among the most frequent visitors of the Proposed Store, given
that they are east of Roe Highway and in close proximity to the store.
Furthermore, residents in the eastern portion of the Locality represent 61% of the
Locality’s population, suggesting that residents most likely to visit the Proposed
Store fall within the higher-ranking suburbs.
It is anticipated that SEIFA rankings of other suburbs within the Locality will
dramatically improve in the near future as a result of redevelopment initiatives.
The development of the Movida Estate in the Farrall Road Structure Plan area is
one such initiative that will improve SEIFA rankings within the Locality especially
Midvale, given that the new dwellings will be populated by first-home owners with
incomes sufficient to service a mortgage and raise a family.
The lower SEIFA rankings can be attributed to the age profile and household
composition of the Locality. As stated above, the proportion of those aged 60
plus (21.2%) in the Locality is higher than the proportion throughout Greater
Perth (18.9%) which would contribute to the lower incomes observed. Persons in
this age group are also more likely to have paid off mortgages. In addition, lower
income levels can be attributed to the significantly higher proportion of lone-
person households within the Locality (30.2%) as compared to the Greater Perth
area (23.0%). This rationale is justified given that the rate of unemployment
within the Locality (7.4%) is lower than the Greater Perth area (8.1%).
5.7 Summary
The Locality is in a residential area with a population that is likely to increase
significantly in coming years. The Proposed Store is at the heart of the Locality
and will provide much needed retail amenity to the incoming residents of the
Movida Estate, along with existing local residents. The demand for retail amenity
in the Locality is recognized in the City of Swan Local Commercial and Activity
Centres Strategy.
In line with planned development initiatives, it is likely that the socio-economic
status of the Locality will significantly improve in the years to come.
King & Wood Mallesons PIA – BWS Midvale 16
47695454_7 27 October 20206 Sensitive Premises
The sensitive premises in the area are identified in part 8 of the MGA Town
Planners’ Report.
There are 30 sensitive premises in the Locality. However, there are no sensitive
premises within 800m of the Proposed Store. As such, it is unlikely that the
Proposed Store will have any significant impact on the sensitive premises within
the Locality.
The sensitive premises are shown on the map attached at Annexure E.
Generally, the impact of licensed premises on sensitive premises is greater
where the licensed premises is a social facility which provides on-site drinking.
This is due to the potential noise issues and patron behavioural problems which
may impact on the surrounding area. BWS is a packaged liquor store and as
such there will not be any drinking on the premises (other than occasional
tastings if permitted). The Proposed Store will also only operate until 9pm during
the week and 5pm on weekends which will greatly minimise any potential impact
on surrounding premises that might arise from late night trading.
The Locality is an emerging residential area which is the subject
of a substantial development initiative. The planned Movida
Estate will result in an influx of employed residents which will
improve the socio-economic status of the Locality.
There is expected to be very significant population growth in the
Locality in the coming years which will lead to increased demand
for retail amenity. This demand is recognised in local planning
strategies.
There are no sensitive premises within sight of the Proposed
Store.
King & Wood Mallesons PIA – BWS Midvale 17
47695454_7 27 October 2020C. Other Licensed Premises in the Locality
1 Licensed Premises
There are 12 existing licensed premises in the Locality capable of selling
packaged liquor to the public.
To satisfy s36B(4) of the Act and the public interest test pursuant to s38(2) of the
Act, the Applicant has prepared an analysis of the 12 licensed premises
predominantly involved in selling packaged liquor in the Locality.
The Applicant has considered the following factors:
the existing packaged liquor services in the Locality;
distribution of premises in the Locality; and
ease of access to the existing premises.
1.1 Existing Packaged Liquor Services
(a) BWS Midland CentrePoint
BWS Midland Centrepoint adjoins the southern edge of the Woolworths
supermarket contained within the Centrepoint Midland Shopping Centre
(Centrepoint). Centrepoint forms part of the Midland city centre. The
store is 40m from the entry to the mall and access to the store is
restricted to entry from the supermarket checkout area.
The store has a floor area of approximately 200m² with a cool room of
approximately 50m². The store includes eleven fridges containing wine,
cider and craft beer. There is an open fridge approximately 5 metres long
containing pre-mixed drinks. The floor display contains wine, spirits and
liqueurs at one side of the store, and two display racks of wine in the
centre of store.
Figure 5 BWS Midland Centrepoint
King & Wood Mallesons PIA – BWS Midvale 18
47695454_7 27 October 2020(b) Grand Central Hotel Liquor Store
The Grand Central Hotel drive - through liquor store is located at the
corner of Great Eastern Highway and Helena Street, Midland. Entry is
taken from the southern side of the store only and vehicles exit to the
north.
The shop area is approximately 70m². At the time of inspection the store
was only accepting orders from the cash register area.
The drive - through liquor store is not co – located with a supermarket
and therefore does not complement grocery shopping expeditions.
Figure 6 Grand Central Hotel Liquor Store
(c) Dan Murphy’s Midland
Dan Murphy’s Midland is located at 295 Great Eastern Highway. It
features a large range of products with a focus on wine. The shop floor
has an area of approximately 750m², inclusive of a cool room being
55m². There are ten fridges adjoining the cool room containing a range
of craft, international and popular beers. An open fridge with cider, pre –
mixed drinks and wine (10 metres long) adjoins one side of the store.
The main shop floor contains non - chilled cask wine, ciders, beer, pre –
mixed drinks, wine and spirits.
King & Wood Mallesons PIA – BWS Midvale 19
47695454_7 27 October 2020Figure 7 Dan Murphy’s Midland
(d) First Choice Liquor Market Midland
First Choice Liquor Market Midland (First Choice) is located at 273
Great Eastern Highway. The store is browse – only, featuring a range of
wine, along with spirits and popular beers.
The store measures approximately 900m², with a 50m² cool room. There
are twelve fridges containing sparking/wine and 6 fridges with cider and
pre – mixed drinks adjoining the cool room. The shop floor and wall
displays contain pre – mixed drinks, cider, wine, spirits and cartons of
beer. The rear wall contains cask wine, old rare wine and sparkling wine.
There is also an open fridge (7 metres long) containing chilled craft beer.
It does not adjoin a supermarket, and therefore does not facilitate
combined grocery and liquor shopping expeditions.
Figure 8 First Choice Liquor Market Midland
King & Wood Mallesons PIA – BWS Midvale 20
47695454_7 27 October 2020(e) BWS Midland Gate
BWS Midland Gate is positioned inside the internal mall area of the
Midland Gate shopping centre, adjacent to the Woolworths supermarket
checkout area. The store has two entry points, one from within the
supermarket shop floor area and the other from the checkout area. The
location of the BWS store adjacent to the supermarket enables
combined grocery and liquor purchases.
The premises has approximately 170m² of floor area and a cool room of
40m². There are eight fridges containing beer and cider fronting the cool
room. Two other fridges contain soft drink and wine. An open fridge
contains wine and pre-mixed drinks and the floor display contains racks
of wine.
Figure 9 BWS Midland Gate
(f) Liquorland Midland
Liquorland Midland is positioned inside the internal mall area of the
Midland Gate shopping centre, adjoining the Coles supermarket
checkout area. The store is co-located with the supermarket to enable
combined grocery and liquor purchases. Customers may enter from the
internal mall area, or from the checkout area of the supermarket. These
two access / egress points directly align with each other.
The premises has approximately 150m² of floor area, and a 30m² cool
room. A side wall display contains spirits, fortified wine and cask wines,
as well as an open fridge containing sparkling wine, wine, pre-mixed
drinks and cider. The opposite side wall display contains wine and the
floor display includes wine and beer. The cool room is located at the rear
of the shop and has eight fridges at its frontage predominantly containing
beer.
King & Wood Mallesons PIA – BWS Midvale 21
47695454_7 27 October 2020Figure 10 Liquorland Midland
(g) Darling Range Thirsty Camel
Darling Range Thirsty Camel drive - through liquor store is located at 57
Great Eastern Highway, opposite the intersection with Farrall Road.
The premises has a floor area of approximately 150m², with a 50m² cool
room that is not accessible. There are sixteen fridges adjoining the cool
room containing sparkling wine, wine, beer, cider and pre – mixed drinks,
and the shop floor contains wine and cartons of beer.
The store does not adjoin a supermarket and does not facilitate
combined grocery and liquor shopping. Given the location of the store, it
primarily services commuters on Great Eastern Highway.
Figure 11 Darling Range Thirsty Camel
(h) Liquorland Stratton
Liquorland Stratton is located in the Stratton Park neighbourhood activity
centre at the northern side of the Locality. It primarily services residents
in Stratton and Jane Brook. Liquorland Stratton is not co-located with a
supermarket.
King & Wood Mallesons PIA – BWS Midvale 22
47695454_7 27 October 2020The store has a floor area of approximately 200m², with a 40m² cool
room. There are 12 fridges adjoining the cool room containing pre-mixed
drinks, cider, craft beer, international and popular beer. Another two
fridges contain sparkling/chilled wine. The wall displays contain cask
wine, fortified wines, spirits and red wine, and the shop floor contains
wine and beer.
Figure 12 Liquorland Stratton
(i) Clayton Cellars Bottlemart
Clayton Cellars Bottlemart is a browse - only store located at the south
eastern edge of the Locality, within a small local activity centre at the
corner of Kalara Road and Jinda Road, Koongamia. It primarily services
residents in Koongamia.
The store is not co-located with a supermarket.
The store has a floor area of approximately 100m², with a 20m² cool
room. There are 6 fridges adjoining the cool room containing beer, and 1
fridge containing pre-mixed drinks. Another eight fridges in the store
contain wine and pre – mixed drinks. The shop floor display contains
wine and beer.
Figure 13 Clayton Cellars Bottlemart
King & Wood Mallesons PIA – BWS Midvale 23
47695454_7 27 October 2020(j) Bucks Off Liquor
Bucks Off Liquor drive – through liquor store is located at 305 Morrison
Road, Swan View, at the corner of Myles Road. It forms part of the
Darling Ridge neighbourhood activity centre.
The store predominantly services residents in Swan View to the north
and south of Morrison Road who wish to access the amenities of the
Darling Ridge activity centre.
The store has a floor area of approximately 150m². The cool room is not
accessible and is estimated to be 50m². There are eight fridges adjoining
the cool room containing pre-mixed drinks and beer. Another eleven
fridges contain pre-mixed drinks, wine, cider and sparkling wine. The
floor display contains beer, and spirits are displayed behind the counter.
Figure 14 Bucks Off Liquor
(k) Liquorland Swan View
Liquorland Swan View is located at 309 Morrison Road, Swan View,
within the Darling Ridge neighbourhood activity centre. Liquorland Swan
View primarily services local residents in the suburb of Swan View to the
north and south of Morrison Road.
The premises has a floor area of approximately 240m², with a 25m² cool
room. There are nine fridges containing pre – mixed drinks, beer and
cider that front the cool room. Another three fridges in the store contain
wine and pre-mixed drinks. The wall displays contain wine and spirits,
and the shop floor display contains cartons of beer.
The store has an IGA within walking distance.
King & Wood Mallesons PIA – BWS Midvale 24
47695454_7 27 October 2020Figure 15 Liquorland Swan View
(l) Greenmount Liquor Store
Greenmount liquor store is a stand – alone premises located on Old York
Road in the suburb of Greenmount. The premises are far removed from
major commuter routes and are not co-located with a supermarket.
The premises has a shop floor area of approximately 220m², with a 16m²
cool room. There are six fridges adjoining the cool room containing wine
and sparkling wine. Another seven fridges in the store contain beer, pre-
mixed drinks, cider and wine. The shop floor and wall displays contain
wine and spirits.
Figure 16 Greenmount Liquor Store
1.2 Distribution of Existing Premises
The Applicant instructed MGA Town Planners to prepare the following Locality
Map which clearly shows that the majority of the licensed premises are located in
the western periphery of the Locality. The concentration of licensed premises in
this area is a result of Midland serving as a Strategic Metropolitan Area, being a
primary location for employment and commercial activity.
The other licensed premises are predominantly distributed across the boundaries
of the Locality. Darling Range Thirsty Camel, Greenmount Liquor Store and
Clayton Cellars Bottlemart are far removed from commuter roads and are
intended to service residents within the immediate vicinity.
King & Wood Mallesons PIA – BWS Midvale 25
47695454_7 27 October 2020Only two licensed premises, Bucks-Off Liquor and Liquorland Swan View, are
located within the central portion of the Locality. Both premises are located within
the Darling Ridge Shopping Centre in Swan View. The suburbs of Midvale and
Swan View are separated by a railway line making access between the two
suburbs difficult. Neither of these liquor stores are co-located with a large-scale
supermarket.
Liquorland Stratton is located within the northern portion of the Locality. It would
be difficult for current and future residents of Midvale and the new Movida Estate
to access this store for the reasons set out below.
Figure 17: Licensed Premises Locality Map
1.3 Ease of Access to the Existing Premises
The Applicant submits that existing liquor stores are not easily accessible for
current residents of Midvale nor the future residents of the Movida Estate on
Farrall Road. The following table shows the distances by road from the Proposed
Store to the existing packaged liquor stores in the Locality.
Table 4: Distances to Existing Liquor Stores24
Distance from Proposed
Store to Existing Stores
(travelling by road)
Premises Location (kilometres)
Bucks – Off Liquor 305 Morrison Road, 1
Store Swan View
24 All distance measurements were taken from GoogleMaps using the address of the Proposed
Store (being 227 Morrison Road, Midvale) as the point of origin.
King & Wood Mallesons PIA – BWS Midvale 26
47695454_7 27 October 2020Distance from Proposed
Store to Existing Stores
(travelling by road)
Premises Location (kilometres)
Liquorland Swan Shop 7, Corner of 1.2
View Weld Road and
Morrison Road
Darling Range 57a Great Eastern 1.3
Thirsty Camel Highway, Bellevue
Liquorland Stratton Shop 2 Stratton Park 2.9
Shopping Centre,
Corner of O’Connor
Road and Farrall
Road, Stratton
Clayton Cellars 21 Jinda Road, 3.2
Bottlemart Koongamia
BWS Midland Gate 274 Great Eastern 3.5
Shopping Centre Highway, Midland
Liquorland Midland 274 Great Eastern 3.8
Gate Shopping Highway, Midland
Centre
Greenmount Liquor 47 Old York Road, 4.1
Store Greenmount
First Choice Liquor 273 Great Eastern 4.1
Market Midland Highway, Midland
Dan Murphy’s 295 Great Eastern 4.1
Midland Highway, Midland
BWS Centrepoint 309 Great Eastern 4.2
Shopping Centre Highway, Midland
Grand Central Hotel 36 Helena Street, 4.8
Liquor Store Midland
As aforementioned, it is noted that access from Midvale to the two closest
competing premises (being Liquorland Swan View and Bucks-Off Liquor Store) is
restricted by a railway line that divides the suburbs of Midvale and Swan View.
The table demonstrates that the majority of the existing packaged liquor stores
are a significant distance from the Proposed Store. There are currently no
packaged liquor stores in Midvale. The residents of Midvale and of Movida Estate
do not have a local packaged liquor store. There is a consumer requirement for
the Proposed Store to improve access to retail amenity in Midvale especially
given the current developments in the area.
King & Wood Mallesons PIA – BWS Midvale 27
47695454_7 27 October 20201.4 Summary
The Applicant submits that it has provided probative evidence which allows the
licensing authority to make findings of fact as to what packaged liquor services
are currently provided by the existing packaged liquor premises in the Locality.
The Applicant submits that the facts show that:
the majority of packaged liquor stores within the Locality are not in close
proximity to the Proposed Store;
access to the closest competing premises is heavily restricted by a
railway line which divides the suburb of Midvale and Swan View;
the distribution of packaged liquor stores in the Locality is very uneven.
The majority of packaged liquor licences are located in the western
periphery of the Locality;
existing packaged liquor stores are not accessible by foot for those
residing in Midvale or Movida Estate;
there are no full-scale supermarkets east of Roe Highway in the Locality
co-located with a liquor store to enable combined single-trolley grocery
and packaged liquor purchases; and
the Proposed Store and Shopping Centre will provide the existing and
future residents of Midvale with the level of retail amenity provided to
residents in the western part of the Locality.
The Applicant submits that analysis of the existing licensed premises satisfies
s36B(4) by identifying that the local packaged liquor requirements cannot be met
by the existing packaged liquor premises in the Locality.
The Applicant further submits that the Proposed Store satisfies the public interest
test pursuant to s 38(2) of the Act. It meets the objective of catering for the
requirements of consumers for liquor and related services, with regard to the
proper development of the liquor industry.
There are currently no packaged liquor stores in Midvale. There is an
uneven distribution of packaged liquor stores in the Locality. Current liquor
store offerings are not easily accessible for those residing in the central
portion of the Locality. It is clear that local packaged liquor requirements
cannot be met by the existing stores.
King & Wood Mallesons PIA – BWS Midvale 28
47695454_7 27 October 2020D. Consumer Requirement and the Proper
Development of the Industry
1 Australian Liquor Market
1.1 Changes in the way that we shop
One of the primary objects of the Act is to cater for the requirements of
consumers for liquor and related services, with regard to the proper development
of the liquor industry, the tourism industry and other hospitality industries in the
State.
It is submitted that ensuring that licensed venues keep up with contemporary
standards and consumer requirements is an important element of this objective.
It is well established that
"In contemporary Australian life, one-stop shopping in large suburban
shopping centres is of great importance, especially to working people".25
The Licensing Authority has continued to recognise that the juxtaposition of a
liquor store and a supermarket is a trend in accordance with the proper
development of the liquor industry.26
Roy Morgan Research reported on the factors that both men and women
consider important in purchasing alcohol.27 The top answer was 'good value'.
However, the next most popular answer provides some insight into where people
like to purchase liquor. For both men and women the location of the store 'close
to home' was important. This indicates that consumers value liquor stores which
are conveniently located. Female shoppers strongly indicated that they prefer to
shop at liquor stores which are located where they do their grocery shopping.
This factor was not as important to male shoppers, however it still rated highly in
what male shoppers look for in a liquor store.
Currently, over 60 of Woolworths' supermarkets in Western Australia have a
liquor store associated with them. This is now part of Woolworths' standard
supermarket design. The Australian consumer now expects that alcohol will be
available at the place where they do their grocery shopping.
The Australia Food & Drink Report also indicates that Australian consumers of
alcohol are increasingly favouring quality over quantity.28 The wine sub-sector in
Australia is predicted to experience the most growth in sales through to 2021
driven by the trend towards premium products.29 Beer is still the most widely
consumed alcoholic drink however beer consumption per capita in Australia has
been in decline since 2009 and this trend is set to continue in the coming years.30
The beer industry has seen a halt in sales of economy brands, with growth being
driven by the premium end products. For example, the craft beer sector has
25 Woolworths Ltd v Director of Liquor Licensing [2013] WASCA 227 at [78];
26 See for example: Decision of the Director of Liquor Licensing A000222902 [2017] at [12];
Liquorland Gateway [LC 07/2017] at 23; Liquorland Secret Harbour [LC 06/2017] at 61
27 Roy Morgan Research, (2015) 'Shopping for a drop: what Aussies like in their liquor store'
http://www.rovmorgan.com/findines/6093-what-aussies-like-in-their-liquor-stores-201502260413
28
Business Monitor International (2017) 'Australia Food & Drink Report Q1 2018, p16.
29
Ibid, p15.
30 Ibid at p16.
King & Wood Mallesons PIA – BWS Midvale 29
47695454_7 27 October 2020experienced double-digit growth in recent years.31 This was confirmed in a recent
report by The Shout which found that
‘[t]he major category growth stories have been in premium or imported
beers, and spirits, both of which fit with a longer term trend away from
larger quantities of basic products and towards smaller quantities of
premium products.”
Figure 18
BWS carries a strong range of wines as well as popular beers and craft beers.
BWS caters to demands of the current Australian packaged liquor market for
'one-stop' shopping and quality liquor products.
1.2 BWS Customers
As discussed above, BWS caters to the demand from consumers who desire a
one-stop shopping experience or a convenient local store. The majority (59%) of
BWS customers in WA are female and this increases to 64% in the case of BWS
stores attached to supermarkets.32 Only 5% of BWS customers are between the
ages of 18 - 24 years of age.33 74% of BWS customers are between the ages of
35 - 74 years of age, indicating a more mature customer base.34
Although BWS customers are generally less likely to be premium shoppers35, the
Proposed Store will cater to the needs of both mainstream and premium
shoppers in the locality by providing a good range of mainstream liquor products
and an element of premium wines.
2 Community Survey
The Applicant engaged Painted Dog Research to conduct an online survey with
residents of the Locality. A total of 532 surveys were collected by Painted Dog
Research between 15 July and 29 July 2020. All respondents were screened to
ensure they were 18 years of age or over.
31 Ibid at p17.
32
House of Brand, (2015) 'BWS customers report', p 4-5.
33
Ibid at p 6.
34
Ibid.
35 Ibid at p17.
King & Wood Mallesons PIA – BWS Midvale 30
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