Rydges at the Wharf, Port Adelaide - Proposed relocation of liquor & gaming licences
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Rydges at the Wharf, Port Adelaide Proposed relocation of liquor & gaming licences Supplementary benefit report to the Community Impact Assessment Prepared for CK Property Group 25 July 2021
Deep End Services Deep End Services is an economic research and property consulting firm based in Melbourne. It provides a range of services to local and international retailers, property owners and developers including due diligence and market scoping studies, store benchmarking and network planning, site analysis and sales forecasting, market assessments for a variety of land uses, and highest and best use studies. Contact Deep End Services Pty Ltd Suite 304 9-11 Claremont Street South Yarra VIC 3141 T +61 3 8825 5888 F +61 3 9826 5331 deependservices.com.au Enquiries about this report should be directed to: Chris Abery Director chris.abery@deependservices.com.au John Deane Senior Associate john.deane@deependservices.com.au Document Name Rydges Port Adelaide liquor & gaming licences benefit report - 25 July 2021 25.07.21 Disclaimer This report has been prepared by Deep End Services Pty Ltd solely for use by the party to whom it is addressed. Accordingly, any changes to this report will only be notified to that party. Deep End Services Pty Ltd, its employees and agents accept no responsibility or liability for any loss or damage which may arise from the use or reliance on this report or any information contained therein by any other party and gives no guarantees or warranties as to the accuracy or completeness of the information contained in this report. This report contains forecasts of future events that are based on numerous sources of information as referenced in the text and supporting material. It is not always possible to verify that this information is accurate or complete. It should be noted that information inputs and the factors influencing the findings in this report may change hence Deep End Services Pty Ltd cannot accept responsibility for reliance upon such findings beyond six months from the date of this report. Beyond that date, a review of the findings contained in this report may be necessary. This report should be read in its entirety, as reference to part only may be misleading.
Contents 1 Introduction 1 1.1 Transfer of liquor & gaming machine licences 1 1.2 Community Impact Assessments 2 1.3 Report purpose 2 2 Project description 4 2.1 Location 4 2.1.1 Port Adelaide 4 2.1.2 Subject site 7 2.2 Proposed Hotel 10 2.2.1 Proposed hotel and amenities 10 2.2.2 Rydges Hotels 14 2.3 Licensed premises 14 2.3.1 Liquor 14 2.3.2 Gaming 18 2.4 Locality overview 20 2.5 Dwelling approvals 22 3 Accommodation market 23 3.1 Accommodation supply 23 3.2 Patronage characteristics 25 3.3 Demand drivers 29 3.3.1 Metro visitor and accommodation data 29 3.3.2 Osborne defence contracts 30 3.3.3 Other sources of demand 32 3.3.4 Room demand 32 4 Benefits 34 4.1 Market commentary 34 4.2 Liquor licence relocation 34 4.3 Gaming licence relocation 35 4.4 Employment 36 4.4.1 Construction 36 4.4.2 On-going operations 37 4.4.3 Value of new employment 37 4.5 Wages & salaries 38 4.6 Hotel guest spending 39 4.7 Travel time savings 40 4.8 Other spin-off benefits 40 4.9 Net benefits of liquor & gaming licences relocation 40 5 Conclusions 42 Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
Tables + Figures Table 1—Port Adelaide commercial area licensed premises 15 Table 2—Demographics. 2016 Census 21 Table 3—Pirate Life patronage distribution 27 Table 4—Hotel guest spending 39 Figure 1—Regional context 6 Figure 2—Local context 9 Figure 3—Aerial view looking south 10 Figure 4—Rydges at the Wharf building perspective and elevations 11 Figure 5—Rydges at the Wharf proposed ground level licensed areas 12 Figure 6— Hotel and Retail liquor licences in the Port Adelaide commercial centre 16 Figure 7—Hotel and Retail liquor licences in the 2km Locality 17 Figure 8—Nearby Hotel licences 18 Figure 9— Hotel licences & Gaming Machine Entitlements in the 2km locality 19 Figure 10—Dwelling approvals in ‘locality’ 22 Figure 11—Accommodation supply 24 Figure 12—Quest Apartment Hotel Port Adelaide 25 Figure 13—Quest Port Adelaide patronage (Jan 2018- Dec 2019) 26 Figure 14—Pirate Life Port Adelaide 27 Figure 15—Pirate Life Brewing patronage (Mar 2019- April 2021) 28 Figure 16—Adelaide domestic & international visitors 29 Figure 17—Port Adelaide Enfield domestic & international visitors 30 Figure 18—Submarine build timeline 31 Figure 19—Potential market segment patronage 32 Figure 20—Unemployment trends 38 Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
1 Introduction 1.1 Transfer of CK Property Group (the applicant) has been granted Development Plan Consent by liquor & gaming the State Commission Assessment Panel (SCAP) for a 185-room residential hotel machine licences (proposed hotel) with associated restaurant, bar, lounge and conference facilities at Lot 2-7 McLaren Parade, Port Adelaide (subject site). The applicant has entered into an agreement with Event Hospitality and Entertainment (EVT) to operate a Rydges branded-hotel on the subject site – to be known as Rydges at the Wharf, Port Adelaide. To enable the operation of food and beverage services and a gaming room within the proposed hotel, the applicant has conditionally purchased the rights to the General & Hotel Licence and the Gaming Machine Licence of the former Port Dock Brewery Hotel at 10 Todd Street, Port Adelaide. The former Port Dock Brewery Hotel is located approximately 180 metres by direct line from the subject site. It closed in 2018 with the General & Hotel Licence and the Gaming Machine Licence currently suspended. The applicant is seeking approval to: • Remove and transfer the General & Hotel Licence from the Port Dock Brewery Hotel to the proposed Rydges at the Wharf; and • Remove and transfer the Gaming Machine Licence from the Port Dock Brewery Hotel to the proposed Rydges at the Wharf. The Port Dock Brewery licence allows up to 40 gaming machines and is endorsed with 15 gaming machine entitlements. The applicant will look to acquire an additional 15 gaming machine entitlements to operate up to 30 gaming machines at the proposed hotel. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
2 1.2 Community Under the Liquor Licencing Act 1997 (the Act), an application for removal of a Impact General & Hotel Licence is a ‘designated application’. The licensing authority may Assessments only grant a designated application if it is satisfied that the granting of the application is in the community interest. A designated application and the licensing authority’s considerations of community interest require the preparation of a Community Impact Assessment (CIA) by the applicant. Under the Act, the matters of community interest that the licensing authority will have regard to are: a. the harm that may be caused (whether to a community as a whole or a group within a community) due to the excessive or inappropriate consumption of liquor; and b. the cultural, recreational, employment or tourism impacts; and c. the social impact in, and the impact to the amenity of, the locality of the premises or proposed premises; and d. the nature of the business conducted or to be conducted under the licence. The application to remove and transfer the Gaming Machine Licence has been assessed by the Commissioner for Gaming as a ‘designated application’. Under the Act, a designated application may only be granted if the Commissioner is satisfied that it is in the community interest to do so. In making a determination, the Commissioner will have regard to: a. the harm that may be caused by gambling, whether to a community as a whole or a group within a community; and b. the cultural, recreational, employment or tourism impacts; and c. the social impact in, and the impact to the amenity of, the locality of the premises or proposed premises; and d. any other prescribed matter. To inform the Commissioner’s decision, a designated application must include a Community Impact Assessment, to be provided by the applicant. Ekistics Planning and Design Pty Ltd has been engaged to prepare a combined CIA for the liquor licence and gaming machine licence applications. 1.3 Report To supplement and inform the CIA, Deep End Services has been engaged to prepare purpose an economic benefit statement, the purposes of which are to profile the key demand drivers, likely operating characteristics of the Rydges at the Wharf Hotel, identify its likely catchment characteristics and sources of patronage and its likely economic and employment benefits. The report sets out the benefits that would accrue to the community from the granting of the applications to relocate the liquor and gaming machine licences. The report finds that the proposed relocation of the General & Hotel Licence from the Port Dock Hotel to the proposed Rydges at the Wharf will result in significant Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
3 tourism, employment and other economic benefits to Port Adelaide and the wider regional economy with few, if any, negative impacts on the ‘locality’. Based on the matters considered in this report, the granting of the licence relocation is firmly and positively in the community interest. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
4 Project description 2.1 Location 2.1.1 Port Adelaide Port Adelaide is an important commercial area and valued heritage precinct, recognised for its well-preserved 19th century public buildings, pubs, shops and warehouses. For much of its history, Port Adelaide was the second largest commercial centre in Adelaide and until the 1930’s the inner harbour was the primary docking point for ships carrying goods and migrants. Port Adelaide’s shipping function declined when new wharves were built on the outer harbour in the 1920s and 30s and later, the rise of containerisation and larger ships. The decline of Port Adelaide from the 1960’s also coincided with the development and growth of regional shopping centres like Arndale (1963) and West Lakes (1974). Port Adelaide’s important buildings and streetscapes were recognised in 1982 when a large section was declared a State Heritage Area however the major renewal projects in Port Adelaide began from about 2010 with a series of developments and announcements including: • The opening of the Techport naval construction yards at Osborne in 2010 to facilitate the Navy’s $8 billion Air Warfare Destroyer Program. • Construction of the Quest serviced apartment hotel in 2015/16. • Starfish Developments and Cedar Woods successfully tendering for the 23-ha waterfront redevelopment (Fletchers Slip) in 2016. • The announcement by the Federal Government in 2016 that a French consortium (DCNS) had successfully tendered for the $50 billion construction of 12 submarines to be built at Osborne. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
5 • A six-level (6,500 sqm) office building in Nile Street, constructed in 2018 and occupied by the Department of Transport & Infrastructure with 500 staff. • The relocation of Pirate Life Breweries from Hindmarsh to a refurbished warehouse on Barlow Street Port Adelaide in 2019. • The first residents moving into Starfish’s Dock One development with a future capacity of 650 homes. • The redevelopment of Port Adelaide Plaza in 2020. • Development approval issued for the Rydges Hotel in 2020. Figure 1 outlines the regional context of Port Adelaide and its designation (zoning) as an Urban Activity Centre under the new Planning & Design Code. Port Adelaide is connected to the Adelaide CBD by Port Road and to northern areas of the city by Port Expressway. Adelaide Airport is just 12 km south with the tourist and leisure area of Glenelg Beach 16 km south. The Port Adelaide commercial area is located on the lower reach of the Port Adelaide River which flows north through the inner and outer harbours and south to the canal estates of West Lakes. The centre covers a wide area reflecting the scale of former maritime and commercial land use around the port with warehouses, public buildings, hotels and commercial premises along Commercial Road and St Vincent Street and through the area’s narrow side streets. Port Adelaide’s retail core has shifted west of Commercial Road where the recently upgraded Kmart, Coles and ALDI-anchored Port Adelaide Plaza lies to the south and Port Mall Shopping Centre with Foodland to the north. The large general industrial areas of Gillman and Wingfield extend east of Port Adelaide with a workforce of approximately 30,000 people. The population of Port Adelaide, its adjoining suburbs and the Le Fevre Peninsula to its north was approximately 53,000 in 2020 – a level that has remained relatively stable throughout the 2000s. The Port Adelaide Enfield local government area (LGA) had a daytime workforce of 63,000 people at the 2016 Census with about 6,400 jobs in and around the Port Adelaide centre. The three largest industries of employment in the Port Adelaide Enfield LGA in 2016 were: • Manufacturing – 19% of all jobs (Adelaide average 8%) • Retail Trade – 12% (Adelaide average 12%) • Transport, Postal & Warehousing – 10% (Adelaide average 4%). While manufacturing was the largest industry of employment in the Port Adelaide Enfield LGA in 2016, its share of total jobs in that area fell from 27% in 2011 to 19% in 2016. Notwithstanding these shifts, the manufacturing base of the City of Port Adelaide Enfield is important and now pivoting to the opportunities from a renewed Defence Naval Shipbuilding industry. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
6 Figure 1—Regional context Source: PlanSA, Planning & Design Code (Phase 3); MapInfo Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
7 One of the most significant sites in the region is the Osborne Naval Shipyard, Australia’s largest shipbuilding yard and the chosen location for the future submarine and frigate program. With an investment of more than $90 billion, the program will sustain thousands of jobs on-site for decades and be a key driver of commercial and residential development in Port Adelaide. At the same time, through Renewal SA’s urban renewal project, ‘Our Port’, the South Australian government is taking actions to transform Port Adelaide from its former shipping and industrial role to a contemporary mixed use urban area. The initiatives to progressively regenerate Port Adelaide were initially identified within the Port Adelaide Precinct Plan (2014). Port Adelaide is described as Australia’s last major undeveloped port waterfront, boasting more than 4 km of public waterfront promenade and overwater development potential. Its redevelopment would follow the successful transformation of historic port areas in other major cities, including Darling Harbour and Barangaroo (Sydney), Docklands (Melbourne), Honeysuckle (Newcastle) and Fremantle (Perth). Over the next 10-20 years, the approved planning framework with the support of government and developer initiatives could see 2,000 to 4,000 new dwellings constructed in Port Adelaide for 4,000 to 8,000 people. 2.1.2 Subject site The subject site is 2,643 sqm of prime waterfront land with a direct frontage to McLaren Wharf and expansive northerly views across the Port Adelaide River and inner harbour. The site is strategically significant and critical to the successful and ongoing renewal of the Port Adelaide waterfront. The Port Adelaide Precinct Plan envisages the McLaren Wharf precinct as a significant gateway, leading people to the Port River with tourism, cafés, markets and shops. Figure 2 shows the subject site in the context of its extensive harbour views looking north up the main channel and across to future residential and commercial areas on the north bank. The subject site ‘bookends’ the main thoroughfare (Commercial Road) and is close to the intimate streets and lanes of the old commercial area behind the dock with historic pubs, commercial buildings, museums and warehouses. A range of important attractions and places of interest are within walking distance of the subject site, including: • Historic Port Adelaide lighthouse • Fisherman’s Wharf Market • SA Maritime Museum • Historic City of Adelaide clipper ship • National Railway Museum • Hart’s Mill • SA Aviation Museum Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
8 • Five operating heritage hotels within three blocks. • Pirate Life Brewing venue. • Port River Dolphin Cruises departing from McLaren Wharf beside the subject site. Port Adelaide’s retail and hospitality strip extends along Commercial Road where a number of heritage hotels are located and restaurants have established close to the subject site. The major renewal areas on Port Adelaide River close to the subject site are: • Newport Quays – a completed medium density housing development on the west bank of the south arm of the river. • Fletcher’s Slip - a proposed 14 ha waterfront mixed-use precinct by Cedar Woods on the north bank of the harbour with 500 wharf-side apartments and terraces with marina berths. Fletcher’s Slip will revitalise an underutilised area of former warehouses which has laid vacant for many years. • Cruikshank’s Corner - a proposed retail and tourism-oriented development beside Fletcher’s Slip. • Dock One - a 4 ha waterfront site at the east end of the inner harbour through to St Vincent Street and Wauwa Street where Starfish Developments have commenced 750 townhouses and apartments with future bars and restaurants on a dockside piazza. • MH Hotel - The former Marine and Harbours building is proposed to be converted to a 100-room hotel by Lancemore with a rooftop bar, restaurant and conference facilities. • Port Approach South - a proposed business park by Starfish Developments with light industrial, commercial and office uses on the north bank bounded by Port River Expressway. • Port Approach North - the 12-ha former Incitec Pivot site north of Port River Expressway is identified under the Port Adelaide Precinct Plan as an area “…to transition into a commercial and/or light industrial precinct, providing a buffer between residential activities to the south and industrial activities to the north.” • Just south of the Port Adelaide commercial area, a site cleared of former industrial buildings is proposed for 100 dwellings, known as Montpelier and Atelier. These recent, current and proposed developments in and around Port Adelaide, in addition to the existing attractions, will contribute to the repositioning and renewal of the area, substantially increasing the local population, changing the demographic profile and drawing in more visitors and business travellers. The proposed Rydges Hotel is a major element of the renewal story. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
9 Figure 2—Local context Source: Deep End Services; Nearmap Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
10 Figure 3—Aerial view looking south Source: Nearmap 2.2 Proposed 2.2.1 Proposed hotel and amenities Hotel CK Group was granted Development Plan Consent in 2020 by SCAP for construction of a 6-level, mid-scale 185-room hotel with a 4.5-star rating. The hotel will operate under the Rydges branding, to be known as Rydges at the Wharf. A perspective and building elevations from the development application are shown in Figure 4. Rydges at the Wharf is premised on the corporate market with a specific focus on the defence sector and the expected demand from contractors based at, or visiting, the Osborne Naval Shipyard where French company, Naval Group will build the Attack Class Submarines and BAE Systems the Hunter Class Navy Frigates. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
11 Figure 4—Rydges at the Wharf building perspective and elevations Source: CK Group The main elements of the hotel use are: • A ground level (corresponding to the proposed licensed area) with the publicly accessible areas being an arrival and reception area (166 sqm), lobby lounge (81 sqm), restaurant (159 sqm) and gaming area (129 sqm). Service and back-of- house areas include a bar, kitchen, pump room, storage, offices and administration areas. The hotel will operate with 24-hour reception and 24-hour room service. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
12 • A flexible large function and ballroom space (358 sqm), pre-function area (183 sqm) and smaller meeting rooms (53 sqm) on Level 1. The function space will be the largest of its type in Port Adelaide with a capacity for 250 delegates. • 185 hotel rooms over part of Level 1 and all of levels 2-5. • On-site parking in open bays and car stackers for 31 cars. The accommodation will be the first and only 4.5 star-rated venue outside central Adelaide and Glenelg and the only hotel in Port Adelaide with 24-hour reception and in-house restaurant and bar facilities. Rooms will provide a mix of King, Queen or single beds and 28 of the 185 rooms will offer kitchenette-style facilities for defence-related contractors on extended stays. The ground level plan with licensed areas is shown in Figure 5. Figure 5—Rydges at the Wharf proposed ground level licensed areas Source: CK Property, Brown Falconer Relevant aspects of the proposed ground level licensed areas are: • The bar areas will have an expansive outlook across the river and be designed and furnished in a classic but modern style befitting a 4.5-star hotel. The ambience of the public lounge and bar area will be conducive to the business traveller and conference guest and will contrast with the public lounge and bar areas of the surrounding hotels. • The restaurant will have a French-inspired theme and will take its name from the adjoining Black Diamond Square – a public plaza around the historic lighthouse on the adjoining waterfront land. The menu and furnishings of the restaurant will appeal to the anticipated business traveller associated with the French Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
13 consortium appointed to build the Navy’s submarines. A terraced area will also offer alfresco dining. • The gaming room is designed for 30 gaming machines or 10 less than the 40 gaming machines licensed to the Port Dock Brewery Hotel. The transfer and relocation of the Port Dock licence to Rydges effectively removes 10 potential gaming machines from the area. • The proposed licence cap of 30 gaming machines is no more than the entitlements held by the larger licensed gaming venues in the area including Birkenhead Tavern (34 EGMs), Port Anchor Tavern (33), Newmarket Hotel (33) and Portland Hotel (32). Aspects of the location, layout and design of the proposed gaming room that will contribute to harm minimisation include: • The gaming room location in the north-west corner of the building is the furthest point from the public arrival and lobby area. The gaming room is not visible nor directly accessible to guests or visitors moving between the lobby and the upper accommodation or function room levels. • From within the hotel building, the gaming room can only be accessed by walking through the lobby lounge and the restaurant. • The door between the gaming room and restaurant is a motion-activated sliding door with fixtures inside the gaming room to prevent sight lines to the gaming area. • The door between the restaurant and gaming room aligns with a walkway against the dividing wall between the restaurant and back of house areas. There will be no restaurant patrons sitting in this area with a direct view into the gaming room or lobby area when the entry door opens. • The gaming room has no dedicated, internally accessed smoking area. All smokers will need to leave the premises. • The gaming room has a narrow aspect out to McLaren Wharf where signage will be limited, in keeping with the style and high aesthetics of the building. Pedestrian volumes on the public walkway are, in any event, generally low. • The very low levels of local road traffic have no visibility to the gaming room given its northern orientation over Port Adelaide River. • The gaming room has an external exit / entry to McLaren Wharf with motion- activated doors and an internal air lock with separate entry doors restricting external sight lines into the gaming area. • Screens, landscaping, awnings and other shade structures on the north side of the building will restrict oblique sight lines from McLaren Wharf to the gaming room entry. • Tinted glazing will prevent any external observation of the gaming area. • The vacant site on the west side of Rydges at the Wharf will be developed in the future restricting public sight lines from Black Diamond Square to any potential signage opportunities on the west wall of the hotel. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
14 2.2.2 Rydges Hotels EVT is a publicly listed entertainment, hospitality and leisure company operating in Australia, New Zealand and Germany with total assets exceeding $2 billion. In Australia, EVT is the fourth-largest hotel operator. The company has two major divisions: • Entertainment – operating Event Cinemas in Australia and New Zealand, the State Theatre in Sydney, Moonlight Cinemas across Australia and Cinestar Cinemas in Germany. • Hotels & Resorts – operating 76 hotels and resorts across Australia and New Zealand under three brands - Rydges, QT, Atura and Thredbo Alpine Resort. Rydges is the company’s largest subsidiary, with 54x4-star and 4.5-star hotels. EVT operates four hotels in Adelaide: • Rydges Adelaide. The 98-room 4-star hotel with a conference centre, restaurant and bar is in the vibrant south-west quarter of Adelaide’s CBD. • Atura Adelaide Airport. Opened in 2018, the 165-room 4-star hotel has a business centre, function and event spaces and restaurant. • Oval Hotel (North Adelaide). The 135-room 4-star hotel opened in September 2020. It is integrated with the eastern stand of the Adelaide Oval, offering function and dining facilities. • Rydges Pit Lane Hotel (Tailem Bend). The 100-room 4-star hotel opened in 2018 overlooking the Bend Motorsport Park racing circuit. EVT own and operate a number of hotels in Australia with full liquor and gaming licences including Rydges Parramatta, Rydges Mackay, Rydges Sydney Central, Thredbo Alpine Hotel and the Grand View Hotel (Cleveland, Qld). 2.3 Licensed 2.3.1 Liquor premises Port Adelaide is served by a range of licensed premises, mainly heritage hotels operating with General & Hotel licences. A total of 19 active and four inactive licensed premises are identified within the prescribed locality - a 2 km radius from the subject site. The viability of traditional pubs in Port Adelaide has come under growing pressure over many years with the loss or relocation of port-related industries and employment, the high density of licensed premises with a similar ‘pub’ offering and rising compliance and operating costs including maintenance on buildings up to 180 years old. More recently, Private Life Brewing has transformed the local hospitality market with its contemporary warehouse-style venue offering boutique beers and meals in spacious indoor and outdoor areas. As many as 6 hotels were recently for sale in Port Adelaide. A summary of the licensed liquor and gaming establishments in the Port Adelaide commercial area is set out in Table 1. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
15 Table 1—Port Adelaide commercial area licensed premises LIQUOR GAMING Licence Liquor Machines Entitlements Entitlements Premises name Address Operation Gaming status type Status approved Owned Held Port Anchor 15 Church Place Pub & gaming HOTEL Current Current 40 33 33 The Lighthouse Wharf Hotel 1 Commercial Rd Pub & gaming HOTEL Current Current 40 15 15 Portland Hotel 286 Commercial Rd Pub & gaming HOTEL Current Current 40 33 33 First Commercial Inn 29 Commercial Rd Pub & gaming HOTEL Current Current 10 10 10 Newmarket Hotel 132 Commercial Rd Pub & gaming HOTEL Current Current 40 32 32 Total operating 170 123 123 The British Hotel 13 North Parade Pub HOTEL Current Current 40 - - Railway Hotel 247 St. Vincent St Pub HOTEL Current Surrendered - - - Port Admiral Hotel 55 Commercial Rd Pub HOTEL Current Surrendered - - - Pirate Life Brewing 1-15 Baker St Brewery / pub HOTEL Current - - - - Royal Arms Hotel (Bamyan Hotel) 275 St Vincent St Afghan Restaurant HOTEL Current Current 14 - - Golden Port Tavern (Globe Hotel) 144 St. Vincent St Closed for redev't. HOTEL Current Current 12 - - Docklands Hotel (Colac Hotel) 1 Santo Pde Closed (prop. redev't) HOTEL Current Current 10 - - Port Dock Brewery Hotel 10 Todd St Closed HOTEL Suspended Suspended 40 15 15 Dockside Tavern 4 McLaren Pde Closed HOTEL Revoked Revoked - - - Liquorland Port Canal Centre Bottle shop RETAIL Current Source: SA Consumer & Business Services Of the 13 existing General & Hotel licences in the Port Adelaide commercial area: • 9 are currently operating as pub or brewery venues. • The Bamyan Hotel or former Royal Arms Hotel has ceased operating as a hotel and is now an Afghan restaurant with upstairs accommodation. • The Golden Port Tavern (or Globe Hotel) is closed for redevelopment and the Docklands Hotel (or Colac Hotel) is closed with a pending development application for alterations and the addition of two breweries. • The Port Dock Brewery Hotel is closed with a suspended licence. The closed Dockside Tavern & Port Dock Brewery Hotel, the former Dockside Tavern (revoked licence) and the former Royal Arms Hotel (now an Afghan restaurant) are all clustered in the Port Adelaide centre where the density of hotels was high and the loss of port-related jobs from warehousing and other uses over the years has been more acute. The former Port Dock Brewery Hotel – from where the General & Hotel Licence is proposed to be relocated to the subject site – closed in late 2018. It is understood the property is subject to a sale process (without the liquor and gaming licences). The distribution of Hotel and Retail liquor licences in the Port Adelaide centre and more widely in the 2km locality is shown in Figure 6 and Figure 7. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
16 Figure 6— Hotel and Retail liquor licences in the Port Adelaide commercial centre Source: SA Government, Consumer and Business Services; Nearmap; MapInfo Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
17 Figure 7—Hotel and Retail liquor licences in the 2km Locality Source: SA Government, Consumer and Business Services; Nearmap; MapInfo Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
18 Figure 8—Nearby Hotel licences Source: Deep End Services 2.3.2 Gaming The distribution of licensed hotels in the 2km locality, including those with gaming machine entitlements (GME), is mapped in Figure 9. In the 2km locality there are 20 active General and Hotel licences where 12 have gaming licences with a total of 314 GMEs. The Port Dock Brewery Hotel is the only suspended hotel licence. It is licensed for 40 gaming machines and holds 15 GMEs. The effective supply including the Port Dock Brewery is therefore 329 GMEs. In the Port Adelaide commercial centre (north of Grand Junction Road through to the Port River), there are 12 active General and Hotel licences (refer Table 1) where: • Five hotels have gaming operations with 170 approved machines and 123 GMEs. • Four of the 12 hotels have licences for 76 gaming machines but hold no GMEs. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
19 • Two of the 12 hotels have surrendered their gaming licences. Therefore, 50% of the 12 hotels in the Port Adelaide commercial centre have either surrendered their gaming licences or hold no GMEs attached to their gaming licences. The availability of gaming machines has almost certainly reduced in central Port Adelaide over a number of years – possibly related to the general demise of the traditional pub market. Figure 9— Hotel licences & Gaming Machine Entitlements in the 2km locality Source: SA Government, Consumer and Business Services; Nearmap; MapInfo Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
20 Figure 9 shows that: • Only two of the 7 nearest hotels (within 400 metres) to the subject site have GMEs. The Lighthouse Wharf Hotel and the First Commercial Inn have just 25 machines combined or 8% of all GMEs within the 2km locality. The density of existing EGMs relative to the number of licensed hotels close to the site is quite low. • The 15 suspended GMEs at the Port Dock Brewery Hotel brings the number of GMEs within the riverside commercial and tourist area to 40 GMEs or just 12% of all GMEs within the 2km locality. • Six of the eight largest gaming venues (32-40 EGMs) in the locality are outside the core commercial area of the Port Adelaide centre. These are primarily catering to a residential market. 2.4 Locality As prescribed under the CIA guidelines, the locality of a licensed premises in the overview Adelaide Metropolitan Area is an area within a 2 km radius of the relevant premises. While the licensed premises mapping is presented for a 2km radius and the demographic profiling is presented for the same area, there are (as shown in Section 3.2) patronage characteristics of the proposed hotel which suggest its customer base will be largely drawn from interstate and overseas. Table 2 presents a summary of the housing and demographic characteristics of the 2 km ‘locality’ compared to the Adelaide metropolitan area. The data is sourced from the 2016 Census. The distinguishing characteristics are: • Similar proportions of residents in the age cohorts up to 49 years but a larger proportion aged 50-64 years (24%) than the Adelaide average (19%). The cohort bulge may be due to older families where the children have left home but also the effects of middle-aged singles and older couples moving to new apartments and townhouses. There is no corresponding spike in the 65+ age group. • The older age structure is borne out in the high proportion of ‘lone person’ households and a smaller average household size (2.14 persons). • Lower levels of tertiary education and more people employed in manufacturing and other blue-collar occupations. • Personal income levels -4% below the Adelaide average. • A higher proportion of Australian-born residents. • A higher proportion of rented dwellings and medium density housing. • A SEIFA index of 933 against an Adelaide average score of 983. • While unemployment was slightly above the Adelaide average in 2016, the workforce participation levels (people working as a % of residents aged 18-65) were high, suggesting a relatively older workforce. The profile reveals a slightly older area with below average income levels but not one of high social or economic disadvantage. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
21 Table 2— Demographic characteristic Port Adelaide Demographics. (2016 Census) 2 km radius Adelaide 2016 Census Persons and dwellings Source: Australian Total private dwellings 8,181 562,089 Bureau of Statistics - % unoccupied 10% 8% Average household size 2.14 2.46 Economic indicators Participation rate (2) 61% 59% Unemployment rate (2) 8.5% 7.7% White collar workers 45% 49% Bachelor degree or higher 16% 21% SEIFA 933 983 Age group 0-9 10% 12% 10-19 11% 12% 20-34 20% 21% 35-49 21% 20% 50-64 24% 19% 65+ 15% 17% Average age 40.7 39.8 Annual individual income $104,200 5% 7% Total 100% 100% Average individual income $42,649 $44,252 Variation from Adelaide average -4% - Country of birth Australia 81% 72% England 6% 7% New Zealand 1% 1% Scotland 1% 1% Other 11% 20% Occupied private dwelling tenure Fully owned 25% 32% Being purchased 36% 38% Rented 38% 30% Dwelling type Separate house 63% 75% Townhouse/semi-detached 26% 17% Apartment 10% 8% Household composition Couples with children 21% 30% Couples without children 24% 26% One parent family 15% 12% Lone person 37% 28% Group 4% 4% Motor vehicles per dwelling None 12% 8% One 45% 38% Two 32% 37% Three or more 11% 17% Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
22 2.5 Dwelling While not reflected as yet in population growth, dwelling approvals within a 2 km approvals radius of the proposed site increased substantially in 2019/20 - 182 new dwellings approved compared to a long-term average of 62 per annum in the previous eight years (refer Figure 10). This is a precursor to the further and ongoing regeneration of Port Adelaide. Figure 10— 200 Dwelling approvals 180 Residential building approvals in ‘locality’ 160 Source: Australian 140 Bureau of Statistics 120 100 80 60 40 20 0 Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
23 Accommodation market 3.1 Short-term accommodation venues in central Adelaide, the inner west and inner Accommodation north-west are shown in Figure 11. It is particularly evident that Port Adelaide lacks supply the quality of the proposed Rydges at the Wharf Hotel with only a boutique hotel (Largs Pier Hotel) or serviced apartments (Quest) available in the area. Elsewhere, the nearest 4-star (or higher) accommodation with comparable facilities are the Atura Adelaide Airport (EVT Group), Lakes Resort Hotel at West Lakes and a range of options in the Adelaide CBD, 14 km from Port Adelaide. A cluster of short-term accommodation facilities at Glenelg serves the holiday and leisure market and is less relevant to Port Adelaide and the defence contract market. Rydges at the Wharf will be a significant point of difference to Quest Port Adelaide which has limited on site amenities and to other boutique accommodation and existing licensed venues in Port Adelaide. There are no accommodation venues in Port Adelaide with conference facilities and in-house bar and dining. Defence force personnel, other business travellers and the expected growth in the leisure market as Port Adelaide regenerates will increase demand for more and better-quality venues, similar to the Rydges brand and offering. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
24 Figure 11—Accommodation supply Source: Deep End Services; SA Government, CBS Liquor & Gaming; MapInfo Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
25 3.2 Patronage The only existing comparable short-term accommodation facility in Port Adelaide is characteristics the 104-room Quest Apartment Hotel, located on the waterfront 200 metres west of the subject site. Built in 2016, Quest provides a good 4-star serviced apartment product with a small gym, guest laundry, valet dry cleaning services and a range of studio, one and two- bedroom apartments with kitchenette facilities. Quest has a small conference room for up to 55 people in theatre-style seating but has no in-house dining, catering or bar facilities for residents. This limits the venue’s potential as a conference and meeting venue. Quest is clearly meeting a strong need and underlying demand for corporate and leisure market accommodation in Port Adelaide. It is thought to be operating at 92%+ occupancy with most of the weekday business generated from defence and associated government sectors. Figure 12—Quest Apartment Hotel Port Adelaide Source: Quest To gain insights on existing visitations and help determine the geographic spread of Quest patrons – which is relevant to the distribution of guests at the future Rydges Hotel - a spatial dataset known as ‘VISTA’ was acquired and analysed from Ubermedia. This dataset provides the approximate ‘home’ geolocation of smartphone and tablet devices detected in a defined area over a given period. In this case, the defined area was the Quest apartment building during the pre-COVID period (2018 and 2019 calendar years). Summarised in Figure 13, the ‘phone tap’ data shows the approximate home origin of Quest visitors (whose mobile phones or tablets emit a captured GPS signal) in the overnight hours. The overnight hours were selected to help separate overnight guests from day-time staff or visitors. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
26 Figure 13 shows that guests originate from a wide area - with 40% from South Australia, 55% from other Australian states and territories and 5% from overseas. About 5% of Quest Port Adelaide’s guests originate from the 2km locality. The broad geographic customer base for Quest is a strong indicator to the likely source of guests at Rydges. Indeed, with the higher quality accommodation and in- house service offering by Rydges at the Wharf and the increase in building activity and contractor involvement at Osborne, the interstate and overseas proportion of hotel guests at Rydges should be much higher than Quest. For a large full-service accommodation hotel, it shows that the licence effects, if any, will be spread across a wide area and broad customer base. In this case, the 2km locality is likely to generate very few in-house guests and contribute only a small proportion to restaurant and bar custom. Figure 13—Quest Port Adelaide patronage (Jan 2018- Dec 2019) Source: Deep End Services; UberMedia Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
27 The relocation of the Pirate Life brewery to a refurbished wool store in Port Adelaide has, on the other hand, generated a metropolitan-wide catchment showing that people from across Adelaide will travel to Port Adelaide for a unique hospitality experience. The success of this venue which can accommodate up to 400 patrons on a weekend underlines Port Adelaide’s potential to appeal to a wider market. Opened in March 2019 in the refurbished 1930s Dalgety wool store (600 metres south of the subject site), Pirate Life is a 5,000-litre on-site brewery kit, 20 metre bar, indoor seating and outdoor beer-garden facilities. Figure 14—Pirate Life Port Adelaide Source: Deep End Services; Pirate Life Phone and tablet device data for the approximate home address of the visitor, from its opening in March 2019 to April 2021, is shown in Figure 15. The broad source of visitors is shown in Table 3. Table 3—Pirate Life Region % Distribution patronage distribution Adelaide 87% Source: Deep End Rest of South Australia 4% Services; Ubermedia Interstate 8% International 1% Total 100% In contrast to Quest, Pirate Life’s patronage is dispersed widely and evenly across the Adelaide metropolitan area, reflecting its broad appeal, particularly on weekends. It is clear that patronage extend well beyond the 2 km locality. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
28 Figure 15—Pirate Life Brewing patronage (Mar 2019- April 2021) Source: Deep End Services; UberMedia Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
29 Patronage location data for the Quest Hotel and Pirate Life showing that 95% and 91% of patrons respectively originate from outside the 2km locality highlights the broad but different appeal of both venues and the relatively small contribution that the 2km locality makes to their customer base. As an accommodation venue, Quest (like Rydges) is catering to the intrastate, interstate and overseas visitor market while Pirate Life’s customer base is broadly across the Adelaide metropolitan area. 3.3 Demand 3.3.1 Metro visitor and accommodation data drivers Tourism and visitor data is published by Tourism Research Australia (TRA) through its national Visitor Survey for geographic areas and larger tourism regions. Data is available for South Australia at Statistical Area 2 (SA2) geography which can be aggregated to metropolitan Adelaide. In 2019, prior to COVID-19 and the introduction of international and intermittent state travel restrictions, Adelaide received an estimated 4.147 million domestic and international (overnight) visitors. Around 89% of all visitors were domestic. Figure 16 shows a four-year trend in overnight visitors. During this period, domestic visitors increased strongly, by 9% per annum, or by 865,000 between 2016 and 2019, including a sharp increase in 2019. Annual international visitors also increased, but at a more modest 4% per annum, reaching 448,000 in 2019. Figure 16—Adelaide domestic & Domestic overnight International international visitors 5,000 4,000 Visitors p.a. ('000) Source: Tourism Research Australia 3,000 2,000 1,000 0 2016 2017 2018 2019 Visitor data for the Port Adelaide Enfield LGA (Figure 17) shows consistent levels in three of the four years from 2016 to 2019. The 30% fall in 2017 is inconsistent with the metropolitan trend and could be a sampling or survey error. International visitations are low, indicating the likely lack of marketing of tourist attractions, the industrial character of large areas of the Council area and the absence of quality accommodation. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
30 Figure 17—Port Adelaide Enfield Domestic International 200 domestic & international visitors 150 Visitors p.a. ('000) Source: Tourism Research Australia 100 50 0 2016 2017 2018 2019 Data on visitor nights from TRA indicates that domestic travellers to Adelaide stayed an average of 3.2 nights between 2016 and 2019 while international visitors (excluding students) stayed an average of 14 nights. International holidaying and business travellers tended to stay for shorter periods, averaging 6 to 7 nights while those visiting relatives and friends stayed longer, averaging 21 nights. 3.3.2 Osborne defence contracts The long-term program of infrastructure upgrades and naval ship building at Osborne is a primary driver of the Rydges Hotel proposal. The Federal Government’s Naval Shipbuilding Plan released in May 2017 has the goal of regenerating the Royal Australian Nay with a continuous shipbuilding program providing certainty to local ship builders and investment and employment generation over the coming decades. The $90 billion plan, largely focussed on the Osborne Naval Shipyards 7 km north of Port Adelaide, will realise the construction of 12 Attack Class submarines, a fleet of nine Hunter class anti-submarine warfare frigates and two Arafura Class Offshore Patrol Vessels. The Osborne Shipyards will be the principal construction yard for the submarines and frigates with the Henderson Maritime Precinct in Western Australia hosting the construction of minor naval vessels. The Osborne Naval Shipyard currently consists of: • Osborne North: high-tech submarine construction and maintenance facilities for the submarines and frigates from 2023. • Osborne South: Australia’s largest naval shipbuilding hub incorporating a critical mass of world class warship design and construction skills. It is the most advanced and modern shipbuilding facility in Australia once upgrades are completed to accommodate the frigate program. It is the current site for the Offshore Patrol Vessel program and the now completed Air Warfare Destroyer program. • Common user shipbuilding facilities: including a 213-metre wharf, runway, dry berth, transfer system and the largest ship lift in the southern hemisphere. • A commercial and education precinct, including the Naval Shipbuilding College. • Navy Headquarters South Australia, Ship Build Program Office and technical laboratories. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
31 • Easy access to the national transport network, including road, rail and deep-sea port. Since 2017, infrastructure upgrades at Osborne South have progressed to support the delivery of the Frigate Program with early works for the future submarine construction yard at Osborne North. The first two of the 12 Arafura Class Offshore Patrol Vessels (OPV) are under construction at Osborne by BAE Systems Maritime Australia (formerly ASC Shipbuilding). Construction of the remaining 10 OPVs will shift to Henderson in 2022 when the Hunter Class Frigate Program ramps up at Osborne. The Hunter class frigate program is underway. It will create more than 5,000 jobs on site and across the wider Australian defence supply chain over the life of the program. The frigates are being built by BAE Systems and are expected to enter service in the late 2020s. Over 500 Australian companies including 100 in South Australia are pre-qualified to be part of the Hunter class supply chain. The French company, Naval Group, was selected in 2015/16 as the preferred builder of the submarines with a $50 billion contract signed in September 2019. In March 2021, Naval Group committed to spend over 60% of the contract value in Australia and on 26 May 2021 sought $100 million of local tools and equipment to fit out the new shipyard. The first submarine is expected to start construction in 2023 and be finished in the early 2030’s. The construction time frame will see the last of the new submarines finished in the early 2050’s. Naval Group’s project time frame is summarised in Figure 18. Figure 18— Submarine build timeline Source: Naval News Naval Group will bring a range of specialist engineers, IT, building and defence- systems specialists and contractors to Australia through the life of the project. The Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
32 company is likely to seek a long-term partnership with an accommodation provider to house its highly specialised workforce and contractors in a high standard of accommodation, close to the naval yards. Naval Group has recently established a $25 million office in the former TAFE SA campus in Port Adelaide for up to 350 employees - part of a 5,000 strong workforce to be generated for the entire program. In addition to the construction cost, there will be an estimated $145 billion in support and maintenance costs over the lifetime of the attack subs, until 2080. A large part of this expenditure will be centred around Port Adelaide and will generate long-term accommodation demand from an extensive supply chain. 3.3.3 Other sources of demand In addition to the defence sector, Rydges at the Wharf will be attractive to other market sectors. In consultation with Rydges management, the likely breakdown of hotel guests was estimated and is presented in Figure 19. About 80% of guests will be business travellers (70%) or those attending conferences and events (10%). This market includes business travellers associated with the large industrial and commercial areas of north-west Adelaide. The leisure and holiday market and ‘visiting friends and relatives’ is estimated at 17%. This includes intra-state and inter-state visitors to major sporting events and cultural attractions in Adelaide who elect to stay outside the central area. Figure 19—Potential Visiting Other market segment friends & 3% patronage Leisure & relatives holidays incl 5% sporting Source: Rydges events 12% Business In-house travellers conferences/ 70% meeting events 10% 3.3.4 Room demand An independent assessment of demand growth and potential supply of accommodation by AHS Advisory in February 2020 for CK Property Group found the wider Port Adelaide region would have a demand for an additional 370 hotel Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
33 rooms by 2022. The assessment was based on an assumed 80% room occupancy rate, similar to historic levels in Adelaide. The 185-room Rydges at the Wharf would account for about 50% of the assessed demand. AHS also concluded that Port Adelaide is “…a future market where underlying demand growth is expected to support increases in market supply.” With Rydges and the proposed 100-room hotel within the Dock One development (MH by Lancemore) there would still be a supply deficiency of at least 85 rooms in Port Adelaide. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
34 Benefits 4.1 Market Despite the positive research supporting the need for more rooms in Port Adelaide commentary and Rydges’ commitment to an approved and licensed development, the hotel / accommodation sector generally across Adelaide and other capital cities continues to suffer from the COVID-19 effects of reduced international and domestic tourism and a collapse in the business and corporate market. A sustained recovery in these markets is not expected until 2023, at the earliest. Confidence in the sector is low and project finance is difficult to obtain. During 2020, hotel room occupancy rates in the major capital cities averaged about 40%, or less than half the levels of 2019. Compounding the low occupancy level has been a drop in average daily room rates by as much as 60%, reaching their lowest levels in recently recorded history (Source: STR). The low occupancy rates have been partly supported by the hotel quarantine program. Without it, occupancy levels would be another 5-12% lower. Occupancy rates will come under further pressure in 2021 with new supply coming online in most major capital cities, including central Adelaide. 4.2 Liquor licence The need and demand for the proposed hotel is well-established by the independent relocation AHS report and the contractual commitment from EVT to partner with CK Property. The very high occupancy of the Quest Hotel, already underpinned by government, defence and related contractor personnel, shows a strong need for new rooms and guest services. This is particularly the case as the submarine and frigate construction program ramps up from 2022 or 2023. The branding and reputation of Rydges and its superior in-house services should result in strong occupancy rates. The provision of in-house bar and dining services Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
35 alleviates the need for hotel guests to seek meal options in Port Adelaide at various times of the day and night and in all forms of weather. Irrespective of the area, some hotel guests will have safety and security concerns about travelling alone outside the hotel in an unknown area to obtain meals. The provision of in-house dining and bar services is an expectation in world-class hotels and especially those of a 4.5-star rating. Lounge, restaurant and bar services will also attract other (non-defence) business and leisure travellers to stay in Port Adelaide, drawing guests from a broader area. The hotel’s conference and function facilities will provide a significant point of difference to other short-term accommodation facilities in north-west Adelaide. The liquor licence is critical to the hotel’s operation in terms of: • Supporting a high-quality in-house restaurant. • Providing an in-room service to guests. • Attracting conferences, meetings and business forums. • Hosting special events such as weddings, ceremonies and cultural and sporting group functions. The removal of the liquor licence to the subject site is essential to the viability of the hotel operation as it enables the complete range of services to be offered which are synonymous with the Rydges brand and its operations. The project viability and the prospect of obtaining development finance will be significantly enhanced with the transfer and relocation of the liquor licence. The hotel design has no provision for a bottle shop or dedicated area for the sales of packaged liquor for consumption off the premises. There is no current intention to sell packaged liquor from the future premises. For those dining in the restaurant and using the licensed liquor service with meals, Rydges management estimate the likely mix of restaurant patrons will be: • 80% hotel guests • 15% local businesses / workforce • 5% residents Therefore, while the up-scale restaurant presents an option for residents of the ‘locality’ to access a fine dining venue, the hotel operator anticipates most of the business will be hotel guests, including many from overseas or interstate. In these terms, the social impact of the day-to-day operation of the liquor licence on the 2km locality is minimal against the significant benefits of guaranteeing the operation of the hotel and the project’s viability and funding. 4.3 Gaming The transfer and relocation of the gaming licence from the nearby (closed) Port Dock licence relocation Brewery Hotel to Rydges at the Wharf will also support the viability of the hotel in what is a difficult short to medium-term outlook for the hospitality industry, given the likely extended effects of the current pandemic on international travel movements. Port Adelaide Deep End Services Proposed relocation of liquor & gaming licences—25 July 2021
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