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Prepared by Lavan on behalf of the applicant Ref: Jessica Patterson [email protected] T: (08) 9288 6946 www.lavan.com.au © Lavan 2019
COSTCO WHOLESALE AUSTRALIA PTY LTD applicant for the conditional grant of a liquor store licence
COSTCO WHOLESALE
Dunreath Drive, Redcliffe/Perth Airport
(near Perth Airport Domestic Terminals 3 and 4)
PUBLIC INTEREST ASSESSMENT
DOC 04
Public Interest Assessment
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Table of Contents
1 Introduction 2
Brief overview 2
2 Applicant’s details and background 4
Costco in Australia 11
Membership 13
3 Intended manner of trade 16
Proposed licensed premises 19
4 Harm minimisation 21
5 Locality 24
City of Belmont 26
Perth Airport 27
6 Section 5 30
7 Harm or ill-health – section 38(4)(a) 30
At risk groups and sub-communities 30
Social health indicators 35 Strategies to be implemented to minimise harm or ill-health 38
8 Impact on amenity, quiet or good order – section 38(4)(b) 40
Nature and character of the local community 40
Outlet density 42
9 Offence, annoyance, disturbance or inconvenience – section 38(4)(c) 46
10 Tourism, community or cultural matters – section 38(4)(ca) 47
Catchment 48
11 Consultation 48
12 Conclusion 49
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1 Introduction
1.1 This Public Interest Assessment (PIA) supports an application by Costco Wholesale
Australia Pty Ltd (ACN 104 012 893) (Costco).
1.2 Costco seeks the conditional grant of a liquor store licence in respect of a section of
premises being established at Dunreath Drive, Redcliffe/Perth Airport, near the Perth
Airport Domestic Terminals 3 and 4 (Costco Site), to be known as Costco
Wholesale.
1.3 This PIA addresses all relevant aspects of the public interest in accordance with both
the Liquor Control Act 1988 (WA) (Act) and the licensing authority’s Public Interest
Assessment policy1 (PIA Policy).
1.4 This PIA is part of the Applicant’s Case and should be read in conjunction with the
other parts and supporting material, all of which are itemised in the document titled
Index of Material Before the Director and Applicant’s Case (Index).
1.5 Where this PIA states “DOC” followed by a number (eg “DOC 1”), it references
material listed in the tables contained within the Index, which material forms the
majority of the Applicant’s Case.2
Brief overview
1.6 Costco is a remarkable, global organisation which offers an enormous, unequalled
range of consumable products and services. The company currently operates 782
stores around the world, including 11 in the eastern states of Australia. Most include
a liquor section.
1.7 An essential and unique feature of Costco’s operations is that its products and
services are only available to its members. Only people who are paid-up Costco
members may shop in a Costco store.
1.8 It is a most exciting and important development in the Western Australian market that
Costco will soon be featured.
1.9 Costco is in the process of establishing its first operation in Western Australia at the
Costco Site which is scheduled to open in March 2020 at a cost of around $55 million.
There will be an impressive 14,000m2 of building area comprising a huge retail
warehouse, optical centre, hearing aid centre and tyre centre as well as a petrol
station.
1 Effective 11 March 2010 and last amended 3 October 2018:
https://www.dlgsc.wa.gov.au/department/publications/publication/public-interest-assessment-policy
2 Supporting material referred to in this document not produced by or for the applicant has been obtained from public sources
under licence. Where relevant, personal information within the supporting material has been blacked out for privacy reasons.
Full copies of some of the source material accompany this PIA and are listed in the Index. Other material not so listed in the
Index can be made available in full if required and has only been left out of the Index to lessen the burden of paper on the
licensing authority.
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1.10 The following images of existing Costco warehouses are indicative of what is
currently under construction at the Costco Site:
1.11 A section of approximately 350m2 of the warehouse is intended for packaged liquor.
This will be a discrete, sectioned-off area with its own dedicated checkout. Below is
an image taken from within the liquor section at the Costco warehouse in Marsden
Park, New South Wales:
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1.12 Full particulars of the proposed liquor service are set out further on in this PIA.
1.13 The applicant engaged expert market research firm, Patterson Research Group
(PRG)3, to undertake surveys of the local community living within 3km of the Costco
Site and also existing Costco members who live in Western Australia. 595 people
participated in the survey exercise. An overwhelming majority of them expressed
clear support for the licence application and an intention to shop at the new Costco
warehouse liquor section. A detailed report has been prepared by the Patterson
Research Group and is included in the Applicant’s Case (DOC 11) (PRG Report).
2 Applicant’s details and background
2.1 Costco originated in the United States of America in the 1970s. One of the first sites
is pictured below.
3 PRG is a full service market research and consulting firm based in Western Australia with over 25 years of experience in
extensive quantitative and qualitative market research. https://www.marketresearch.com.au/ (There is no relation between
PRG and Jessica Patterson who is noted as the reference and contact person on the cover of this PIA.)
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2.2 Costco’s history is neatly summarised in the following extract from its website:4
The company's first location, opened in 1976 under the Price Club name, was in a
converted airplane hangar on Morena Boulevard in San Diego, USA. Originally serving
only small businesses, the company found it could achieve far greater buying clout by
also serving a selected audience of non-business members. With that change, the
growth of the warehouse club industry was off and running. In 1983, the first Costco
warehouse location was opened in Seattle. Costco became the first company ever to
grow from zero to $3 billion in sales in less than six years. When Costco and Price Club
merged in 1993, the combined company, operating under the name PriceCostco, had
206 locations generating $16 billion in annual sales.
Our operating philosophy has been simple. Keep costs down and pass the savings on to
our members. Our large membership base and tremendous buying power, combined
with our never-ending quest for efficiency, result in the best possible prices for our
members. Since resuming the Costco name in 1997, the company has grown worldwide
with total sales in recent fiscal years exceeding $64 billion.
Costco has transformed the retail world. When entrepreneur Sol Price introduced a
groundbreaking retail concept in San Diego, California. Price Club was the world's first
membership warehouse club, a place where efficient buying and operating practices
gave members access to unmatched savings.
At first, Price Club was limited exclusively to business members, who could purchase a
wide range of supplies and wholesale items. Jim Sinegal, the executive vice-president of
merchandising, distribution and marketing, was instrumental in fine-tuning the
merchandise and marketing strategies, helping to turn Price Club into a success story
that changed the face of retailing worldwide.
Seven years later, Jim Sinegal channeled his expertise into co-founding Costco
Wholesale with Jeff Brotman, and together they opened the first warehouse in Seattle,
Washington in 1983.
Over the next decade, both Price Club and Costco Wholesale continued to innovate and
grow, and in 1993, the two mega-retailers merged, creating a gifted leadership team that
soon made Costco the world's most successful warehouse club.
2.3 For the year ended August 2018, worldwide Costco sales were US$138b and the
number of employees exceeded 240,000.
2.4 The following are images of early stores in the United States. As can be seen when
comparing the modern images depicted further on in this PIA, the general style of
warehouse has not changed much over the decades.
4 https://www.costco.com.au/aboutcostco
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2.5 From its humble beginnings in the 1970s, Costco is now a multi-billion dollar global
retailer and has become a household name across the world. Costco now operates
782 warehouses worldwide as follows:
2.5.1 531 locations in 44 states in the United States of America and Puerto Rico.
2.5.2 100 locations in nine Canadian provinces.
2.5.3 39 locations in Mexico.
2.5.4 29 locations in the United Kingdom.
2.5.5 26 locations in Japan.
2.5.6 15 locations in Korea.
2.5.7 13 locations in Taiwan.
2.5.8 11 locations in Australia - in Queensland, New South Wales, Canberra,
Victoria and South Australia.
2.5.9 Locations in Spain, Ireland, France and China.
2.6 Relevantly, 62% of existing Costco members based in Western Australia who
participated in the research conducted by PRG have shopped in a Costco warehouse
situated overseas.5 Clearly Costco’s catchment has global reach.
2.7 Costco employs over 240,000 full and part-time people around the world and
generated an annual revenue of $138.4 billion for the 2017/18 financial year.
2.8 Of the 782 Costco stores, most include a packaged take-away liquor service. 8 of the
11 stores in Australia currently offer liquor.
5 DOC 11 at page 40
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2.9 Costco is “dedicated to bringing [its] members the best possible prices on quality
brand-name merchandise”6. Brand names available include the following, just to
name a few:
2.9.1 Calvin Klein
2.9.2 JAG
2.9.3 Levi Strauss & Co
2.9.4 Puma
2.9.5 Adidas
2.9.6 Sony
2.9.7 Samsung
2.9.8 Panasonic
2.9.9 Apple
2.9.10 DeWalt
2.10 Costco also offers a range of its own branded products under the label, Kirkland
Signature, available exclusively to Costco.
2.11 There is an extensive range of products under the Kirkland Signature brand across
the following categories
2.11.1 Liquor
2.11.2 Clothing
2.11.3 Luggage
2.11.4 Grocery
2.11.5 Health and beauty
2.11.6 Organic
6 https://www.costco.com.au/aboutcostco
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2.11.7 Home and kitchen
2.11.8 Baby
2.11.9 Hardware
2.11.10 Pet food and supplies
2.11.11 Office
2.11.12 Fuel
2.12 Costco’s warehouses present one of the largest and most exclusive product and
services selections available under a single roof anywhere in the world. The Costco
retailing concept is bespoke and unlike any other mixed retail facility such as
traditional department stores or supermarkets in Australia.
2.13 The extensive selection of merchandise at a Costco warehouse includes, amongst
many other things, fresh groceries, deli platters, books, toys, electronics, jewellery,
tools, auto accessories and homewares. Costco also provides services including
optical, tyre replacement and wheel alignment, hearing-aids, adjoining self-service
fuel kiosks and cafe. Collectively, the goods and services offered at Costco create a
most advanced one-stop-shopping experience.
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2.14 High value items are often available at Costco for reduced prices, including for
example, diamond rings and hearing aids at significant savings compared to usual
retail prices. Costco has a unique ability to source specialty high-end items and to on-
sell them to members at exceptionally good value prices. This is a key characteristic
of the Costco offering.
2.15 “Costco is known for carrying top quality national and regional brands, with 100%
satisfaction guaranteed, at prices consistently below traditional wholesale or retail
outlets.”7
2.16 Costco’s offer entails a no-frills concept to ensure it minimises costs to maintain a
very high level of value-for-money pricing. Products are displayed in a simple, bulk
format, with many kept in their original pallet. There are no change-rooms to try on
clothing and the shelving is basic warehouse racking.
2.17 According to Craig Jelinek, the Company's President, CEO and Director:
Costco is able to offer lower prices and better values by eliminating virtually all the frills
and costs historically associated with conventional wholesalers and retailers, including
salespeople, fancy buildings, delivery, billing and accounts receivable. We run a tight
operation with extremely low overhead which enables us to pass on dramatic savings to
our members.8
2.18 Costco is a cash-and-carry only operation and so currently does not offer delivery,
other than in limited circumstances for bulk purchases by businesses.
7 http://investor.costco.com/corporate-profile-2
8 Mark Peterson, Sustainable Enterprise: A Macromarketing Approach (Sage Publications, 2012) at 119
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Costco in Australia
2.19 Australia welcomed its first Costco warehouse on 17 August 2009, in Melbourne, on
the fringe of the central business district. The second opened in Sydney’s western
suburbs.9
2.20 Costco currently operates four warehouses in Victoria, three in New South Wales, two
in Queensland, one in South Australia and one in Canberra. Costco opened its first
Australian distribution headquarters in Western Sydney in July 2019 at a cost of over
$100 million. The massive facility is around the size of 17 football fields.
2.21 Costco’s warehouses range in size from approximately 7,000m2 to 20,000m2, with the
average size being around 13,500m2.
2.22 Pictured below are examples of the exteriors of Costco warehouses elsewhere in
Australia which resemble generally what is being constructed at the Costco Site:
Auburn, New South Wales
Majura Park, near Canberra Airport, Australian Capital Territory
9 https://www.smh.com.au/business/costco-readies-first-australian-outlets-20090721-drmq.html
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North Lakes, Queensland
2.23 The following image depicts the general layout and appearance of the interior of a
Costco warehouse:
2.24 Products are packaged, displayed and sold in bulk quantities in a bare-bones depot
atmosphere, with many displayed on the original shipping pallets as can be seen in
the image above and below. Members' purchases are packed into old, empty product
boxes. Plastic bags are not provided.
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2.25 The Australian operating entity, Costco
Wholesale Australia Pty Ltd, which is the
applicant for the liquor store licence, has three
directors. Two live in the United States. The
third, Mr Patrick Noone, lives in New South
Wales. He is pictured to the right.
2.26 Mr Noone started his retail career with
Woolworths Supermarkets in 1978 in Melbourne as a Trainee Manager. He
progressed through several positions with Woolworths and then, after moving to
Canada in 1985, Mr Noone worked with Loblaw’s (a Canadian supermarket chain)
before helping to launch the Membership Warehouse concept in Canada in 1991,
working with the Price Club group in Vancouver. After Price Club merged with Costco
in 1993, Mr Noone went on to manage several Costco Warehouses in Vancouver,
eventually being promoted to Regional Operations Manager in 2003 and Vice
President in Western Canada in 2005. Mr Noone commenced as Country Manager
for Costco Australia in 2006. Clearly Mr Noone has considerable retail experience
and that includes liquor. Many of the stores Mr Noone has been associated with have
included a liquor service. He is also intimately familiar with Costco’s operations after
28 years with the organisation. He is ideally placed to manage and oversee the
establishment of Costco’s new WA warehouse and this application.
2.27 Mr Noone said that “Perth Airport is the obvious place for us to invest given its
proximity to the CBD, the great transport links, and the way it is growing into a
consumer-focused retail hub.”10
Membership
2.28 Costco’s products and services are only available to be purchased by Costco
members. The member-based structure of Costco’s operation is a fundamental
feature which also distinguishes Costco from most other retailers.
2.29 Membership is only available to people over the age of 18 and businesses.
10 Caleb Triscari, Costco unveils West Australian expansion plans: Will it crush the Competition? (26 February 2018) Smart
Company https://www.smartcompany.com.au/industries/retail/costco-reveals-plans-to-set-up-shop-in-perth/
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2.30 There are two categories of membership:
2.30.1 Business membership is the original and basic category with a current
annual fee of $55. Business members are entitled to make two separate
transactions at the register, one for the business itself and one for personal
shopping.
2.30.2 Gold star membership is currently $60 per year and is available to
individuals to join and shop at wholesale prices.
2.31 Costco members have access to Costco’s products and services exclusively, which
includes Costco’s own branded items. They also receive a copy of the Costco
Connection, described as a “lifestyle magazine for Costco members”. A sample copy
has been included in the Applicant’s Case and is listed in the Index as DOC 13. The
magazine contains information about Costco products and services, recipes, health
and wellness articles and other content.
2.32 Costco members also receive catalogues and coupons, such as the Father’s Day
edition included in the Applicant’s Case (DOC 14).
2.33 Costco can boast a staggering 51 million paid memberships and 94 million
cardholders worldwide (approx.). That includes over one million cardholders in
Australia. Currently approximately 1,600 existing members live in Western Australia
despite the fact that no store yet operates in WA.
2.34 A free supplementary household membership card is available to a primary
cardholder’s spouse, de facto partner or immediate family member living at the same
address who is over 18 years of age. Household cardholders are required to prove
that they live at the same address as the primary cardholder.
2.35 Members are issued with a membership card which they must produce at the point of
sale, in order to make a purchase.
2.36 Membership is checked both at the entry to the warehouse and when completing a
purchase when Costco customers must produce their membership card to initiate a
purchase. Costco also trains its front-of-house staff to double check payment
receipts, upon exiting a warehouse, as both security and customer service measures
to ensure compliance with membership requirements and that all of the shopper’s
items are properly accounted for.
2.37 Many Costco members are so passionate about their membership and their love of
Costco’s products and services that they have created a website
(www.Ilovecostco.com) where they post their comments, information about good
shopper deals and photos of the bargains they found at Costco.
2.38 On Instagram #costcodeals (which is mainly relating to US stores) there are many
positive contributions from members.
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2.39 #costcoaustralia has more than 1,000+ posts/contributions on Instagram revealing
Costco’s popularity.11
2.40 There are several Costco fan pages on Facebook in Australia. Almost one for each
store, as follows:
2.40.1 Costco Australia – currently 1,900 subscribers.12
2.40.2 QLD Costco geeks – currently 35,500 subscribers.13
2.40.3 Costco Casula (fan page) – currently 12,168 subscribers.14
2.40.4 Costco Marsden Park (fan page) – currently 10,200 subscribers.15
2.40.5 Costco Melbourne customers – currently 4,600 subscribers.16
2.40.6 QLD Costco geeks Bundamba – currently 15,000 subscribers.17
2.40.7 Costco Community Adelaide – currently 11,000 subscribers.18
2.41 There are also community-based Facebook pages regarding Costco products and
services including, for example, “Costco meal ideas for busy moms” which has 9,700
subscribers.19
2.42 None of the social media platforms referred to in the preceding few paragraphs is
actually operated or even sponsored by Costco. They have been established and are
managed by consumers quite independently of Costco and are, therefore, persuasive
and totally both independent and objective evidence of Costco’s popularity in the
market place amongst shoppers.
2.43 Costco has identified that its warehouses traditionally have a local catchment of a
people living within a radius of approximately 45 minutes drive, although as stated
earlier on in this PIA, the PRG Report contains evidence of Costco having global
11 As at 15 July 2019
12 https://www.facebook.com/groups/918818238133534/?ref=share
13 https://www.facebook.com/groups/seqcostcogeeks/?ref=share
14 https://www.facebook.com/Costco-Casula-Fan-Page-257139844323968/
15 https://www.facebook.com/groups/1673782022929935/?ref=share
16 https://www.facebook.com/groups/128386554179485/?ref=share
17 https://www.facebook.com/groups/qldcostcogeeksbundamba/?ref=share
18 https://www.facebook.com/costcoadelaide/
19 https://www.facebook.com/groups/1166720656695514/?ref=share
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catchments. In relation to the Costco Site in particular, having regard for an average
driving speed of 80km per hour, the catchment will be a radius of approximately
60km. That radius is nearly as far north as Yanchep and south to Rockingham.
2.44 The existing Western Australian membership base comprises 1,655 people living
across a broad spectrum of the State, mainly in the Perth metropolitan area. Included
in the Applicant’s Case is a redacted20 copy of the list of those members (DOC 15)
which shows their home suburbs or towns. Members in that list live as far away as
Kununurra, Christmas Island, Ravensthorpe and Kalgoorlie.
2.45 It is abundantly clear from the fact that Costco already enjoys so many members in
Western Australia, well before any Costco warehouse exists here, that what Costco
has to offer the public is in high demand.
2.46 Further, the expert market research of non-members living within 3km of the Costco
Site revealed a “high proportion (89%) reporting that they are ‘at least quite likely’
(including a ‘very likely’ figure of 64%) to seek membership and shop in the new
Costco store when it opens”21.
2.47 It seems, therefore, based on the number of existing WA cardholders and response to
the market research that on or around opening of the new warehouse at the Costco
Site there will be at least 2,000 members. Based on Costco’s own internal measures
and past experience, it expects more than 10,000 membership cards to be issued
when the new store opens at the Costco Site.
3 Intended manner of trade
3.1 Costco proposes virtually the same liquor service that is available at its eastern states
stores to be incorporated into its new WA warehouse at the Costco Site, whereby
there will be a designated display/browse area with unrefrigerated beer, wine and
spirits.
3.2 The applicant seeks approval for the standard permitted trading hours under section
98 of the Act relevant to liquor store licences, namely 8.00am to 10.00pm Monday to
Saturday and 10.00am to 10.00pm on Sunday22. However, actual opening times will
also be subject to the trading hours of the warehouse which are likely to be around
the following:
Monday - Friday 10.00am to 8.30pm
Saturday 9.30am to 6.30pm
Sunday 10.00am to 6.00pm
20 Redacted to protect privacy
21 DOC 11 at page 27
22 Subject to variations in accordance with the Act for Good Friday, ANZAC Day and Christmas Day.
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3.3 Generally, less than 300 SKUs will be stocked at the new warehouse liquor section
and mostly displayed from their original shipping pallets in a simple depot style layout.
3.4 The liquor range will comprise approximately 60% wine, 35% spirits and 5% beer. It
will mostly comprise known, branded products but also some of Costco’s own private
label wines which are the subject of a partnership between Costco and winemakers.
3.5 The branded products will include specialty, super premium and collectable items
from time to time, such as, for example, Costco has offered a rare Macallan single
malt Scotch from 1948 for $26,999.99 a bottle, as depicted below on display. Only a
few hundred were ever made.
3.6 Two other examples are depicted below, including a Costco branded product:
3.7 The prospect of accessing Costco’s discounted limited edition liquor items at the
Costco Site was very well received by participants in the PRG market research.
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78.5% of participants across both surveys combined expressed high interest in the
products23.
3.8 Costco’s own Kirkland Signature brand of wines (pictured below) include a wide
range of different varietals. “These are extremely high quality wines made by
excellent wineries exclusively for Costco. In fact, many times these are almost
identical to wines sold under the wineries original label”24, at a significant discount.
3.9 Costco is the largest wine retailer in the United States, selling more than a billion
dollars of wine a year in the US.25
3.10 Costco’s wine range has become so popular that consumers have created a blog
dedicated to information about Costco’s wines with independent reviews26. The blog
was started “for fun because we love to find awesome wines at great prices from
Costco. And we’ve since learned there are a lot of people just like us out there”27.
3.11 Included in the Applicant’s Case is a draft stocklist (DOC 16).
3.12 From time to time, tastings will be provided for members and also food and liquor
matching information. This may include a liquor producer attending in-store to talk
about particular products and to educate members.
3.13 Pricing will be competitive and provide a high level of value-for-money with many
premium standard items at lower than average prices. Generally, wines will start from
approximately $9/10 per bottle.
23 DOC 11 at pages 8 and 9
24 https://www.reversewinesnob.com/search/label/costco/
25 https://pilcrow.squarespace.com/stories/costco and https://www.buzzfeed.com/hannahloewentheil/xx-secrets-for-buying-
wine-and-liquor-at-costco
26 https://costcowineblog.com/
27 https://costcowineblog.com/
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3.14 Gift hampers, including liquor and food, will be offered on occasion, particularly
around special seasons or events, such as Christmas, Mother’s Day and Father’s
Day.
3.15 Costco sources its liquor range from within Australia and also overseas, through local
and international distributors as well as individual producers.
3.16 Advertising and promotion of liquor will be very limited compared to most liquor
retailers. Members will be emailed a catalogue on a fortnightly basis which will
occasionally contain details about liquor products available and specials. The Costco
website will also contain information regarding liquor items.
Proposed licensed premises
3.17 The liquor section of approximately 350m2 will be physically separated from the rest
of the warehouse, although contained within the same footprint, under the same roof.
3.18 The liquor area will be very clearly physically delineated with pallet racking and
fencing around the perimeter. It will have its own dedicated checkout within the
licensed area.
3.19 There will be one entry/exit point, near the checkout, accessed from inside the
warehouse. Members will need to walk past staff manning the front entrance of the
warehouse and then past the liquor checkout point, in order to access the liquor
display/browse area, all while under the watchful eye of well-trained Costco staff. The
staff member stationed at the licensed checkout will be qualified as an approved
manager.
3.20 The images below of the liquor section at Costco’s Marsden Park warehouse in New
South Wales are indicative of what will be established at the Costco Site.
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3.21 The licensed area will be a simple rectangular configuration with a basic, user-friendly
layout with high perimeter shelving and one central row of internal shelving. The
images above depict these features.
3.22 The following is an extract from the floor plan (DOC 6), reduced in size and showing
the proposed licensed area shaded in yellow:
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3.23 The warehouse will be supported by a large number of parking bays available to
Costco members immediately adjacent to the building as depicted in the extract from
the site plan (DOC 5) below:
4 Harm minimisation
4.1 Costco is acutely aware of the need to minimise the potential harmful effects from the
sale and supply of liquor.
4.2 Costco has also familiarised itself with the licensing authority’s Harm Minimisation
Policy last amended 19 December 2018 and developed a set of appropriate policy
documents for the proposed licensed operation (DOC 9).
4.3 The are many low risk features of the proposed liquor service, including the following,
which will help ensure potential harm in this case is minimised:
4.3.1 The fact that customers must be members.
4.3.2 As stated previously, members must be over 18 years of age.
4.3.3 Shoppers of liquor will be subjected to a three-level identity check in order
to be able to purchase liquor:
(a) upon seeking membership,
(b) when entering the main warehouse proper and
(c) when making a purchase of liquor in the licensed area.
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4.3.4 The bright and simple open-plan layout of the licensed area will facilitate
good staff surveillance and deter problem behaviour through the absence of
places to hide.
4.3.5 The lack of refrigerated products to help avoid impulse buying and drinking.
4.3.6 The dedicated licensed checkout.
4.3.7 The lack of immediate or direct egress from the liquor area outside into the
public domain. The design and layout forces customers to first enter the
warehouse and walk past the watchful eye of trained entry and checkout
staff.
4.3.8 The lack of signage external to the warehouse advertising discounted liquor
products. There will also be no prominent external advertising of liquor
products and their prices external to the warehouse.
4.3.9 There will be no refrigerated ready-to-drink items which can entice impulse
buying and drinking.
4.3.10 Energy drinks will not be stocked in the licensed area.
4.3.11 There will be no products or promotions designed to entice juveniles.
4.3.12 The fact that Costco is a very experienced and reputable retailer of liquor.
4.4 Costco has successfully implemented these measures at its many licensed
warehouses and proven, through an excellent trading history, that its model certainly
does minimise harm.
4.5 The PRG research found that 87% of existing Costco members who live in WA and
who have seen the liquor section in a Costco warehouse considered that liquor
section to be well managed. Only 1% disagreed.28
4.6 What is proposed at the Costco Site has already been tried and tested.
4.7 The design and position of the licensed area will enable a high level of control and
surveillance through clear visibility by staff. A well trained and qualified staff member
will be stationed at the licensed checkout at all times, monitoring the area constantly.
CCTV will also operate in and around the licensed area.
4.8 The absence of refrigerated liquor items reduces the likelihood and motivation of
members purchasing liquor to drink it immediately or at an unauthorised location in
the vicinity of the Costco store. This clearly reduces the likelihood of customers
making impulsive or irresponsible purchases.
4.9 Low and mid-strength products will be available.
28 DOC 11 at page 42
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4.10 Costco will ensure all staff who work in the liquor section are properly trained as to
their responsibilities under the Act and are suitably qualified, with at least one staff
member in the liquor section being qualified as an approved manager under the Act.
All cashiers and managers will undergo responsible service of liquor training.
4.11 It is relevant to note that notwithstanding that liquor has been sold in Costco
warehouses in New South Wales, for example, for years, there has been a “decrease
in daily alcohol use [which] occurred between 2011 (9.8%) and 2015 (7.5%).”29
Further, “[i]n 2014...[t]he proportion of high school students who drank alcohol in the
last 12 months decreased substantially between 2005 (63.5%) and 2014 (43.7%).”30
The graph below shows the frequency in which people in New South Wales consume
liquor and indicates that liquor is not consumed at high daily levels. Costco liquor
services have operated in NSW during the period referred to in the graph below. 31
4.12 “The proportion of people [in NSW] who reported drinking at levels that put them at
long-term risk of harm fell from 31.4% to 25.9% between 2006 and 2015—a reduction
of 5.5%.”32
29 http://www.health.nsw.gov.au/hsnsw/Publications/chief-health-officers-report-2016.pdf at page 6
30 http://www.health.nsw.gov.au/hsnsw/Publications/chief-health-officers-report-2016.pdf at page 6
31 http://www.health.nsw.gov.au/hsnsw/Publications/chief-health-officers-report-2016.pdf at page 6
32 http://www.health.nsw.gov.au/hsnsw/Publications/chief-health-officers-report-2016.pdf at page 8
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4.13 Every effort will be made by Costco to conduct business under the licence at the
Costco Site in a manner that minimises the potential for harm or ill-health to occur as
a result of the supply of liquor.
4.14 Costco is a reputable, public corporate citizen which operates pursuant to several
high standards and policies. It is in Costco’s best interests to ensure that the liquor
service is compliant, does not cause harm and meets consumer requirements.
4.15 As to juveniles:
4.15.1 Costco is very conscious that juveniles will likely be in the warehouse from
time to time and that they cannot be supplied with any liquor.
4.15.2 Importantly however, any juveniles will almost always be with a responsible
adult because people under the age of 18 cannot obtain membership to
Costco and therefore, cannot make any purchases there.
4.15.3 In any event, the layout of the liquor area and security systems in place will
enable constant surveillance of any juveniles. No liquor will be sold or
supplied to juveniles or anyone who is suspected of trying to obtain liquor
for a juvenile.
4.15.4 Costco has a strict policy of not selling or supplying liquor to anyone who is
suspected of being likely to give it to a juvenile.
5 Locality
5.1 Pursuant to the PIA Policy, the defined locality for this application is a 2km radius
area surrounding the proposed licensed area at the Costco Site (Locality).
5.2 The 2km radius comprises all or parts of the following suburbs:
5.2.1 Perth Airport (the suburb)
5.2.2 Redcliffe
5.2.3 Cloverdale
5.2.4 Belmont
5.2.5 Ascot
5.2.6 Ashfield
5.2.7 Bayswater
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5.3 Perth Airport (the suburb) recorded a tiny population of only 28 people in the 2016
Census.33 Information on these residents is not readily available and of little
relevance given the tiny sample size and, therefore, not referred to in this PIA.
However, other aspects of Perth Airport - the suburb, the precinct and the
infrastructure - are very relevant to consideration of the Locality and have been
addressed in this PIA.
5.4 The suburb of Bayswater represents only a very small portion of the 2km radius area
and so any statistics from that suburb would skew a proper assessment of the
Locality in accordance with the PIA Policy and have, therefore, been excluded in this
PIA.
5.5 Mainly the suburbs of Perth Airport, Redcliffe, Cloverdale, Belmont and Ascot have
been considered, which comprise the area outlined in black in the Google Maps
image below:
5.6 Whilst Costco has comprehensively assessed the Locality in accordance with the PIA
Policy, it is highly relevant that Costco’s catchment will actually comprise a
significantly wider area. As referred to elsewhere in this PIA, Costco’s warehouses
traditionally draw shoppers from a radius of approximately 45 minutes’ drive in terms
of local custom, but even further afield as members can live hundreds and thousands
of kilometres away.
33 https://quickstats.censusdata.abs.gov.au/census_services/getproduct/census/2016/quickstat/SSC51219?opendocument
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5.7 The Costco Site is situated within the City of Belmont, however, it is subject to the
jurisdiction of Perth Airport Pty Ltd and federal laws.
City of Belmont
5.8 The City of Belmont covers an area of 3,965.2 ha and is located in the inner eastern
suburbs of Greater Perth. It is situated about 8 kms east of Perth's CBD. The City of
Belmont is bounded by the City of Bayswater and the Town of Bassendean in the
north, the City of Swan in the east, the City of Kalamunda and the City of Canning in
the south and the Town of Victoria Park in the west.34
5.9 The City of Belmont has a long and significant history in the Perth metropolitan area,
primarily as a result of Perth Airport.
5.10 There was rapid post-war growth in the area. In 1947 the population was 5,700 and
just six years later it had grown to 16,700. Many new homes were constructed, often
by the State Housing Commission. To assist with growth, in 1950 three new suburbs
were created, namely Kewdale, Cloverdale and Newburn. In the 1950s and 1960s
there was an upsurge in the construction of industrial buildings.35
5.11 Now an enormous local government area, the City of Belmont is home to
approximately 41,510 residents.36 The City’s development plan forecasts a
considerable increase in the population of around 50% by 2041.37
5.12 The City of Belmont’s Development Area 6 (outlined further below) is projected to
considerably increase its population over the coming years.
5.13 Many high-density property developments have emerged in the area, mainly in
Rivervale but also Belmont and Ascot. Large scale developments such as The
Springs have been developing in Rivervale for several years now and are expected to
continue until completion in the mid-2020s. From the later part of the 2020s, the
establishment of the "Development Area 6 Vision" will contribute much dwelling
supply to the Redcliffe-Perth Airport area in the form of medium/high density
dwellings and along with business and commercial development of the Belmont
Business Park in the same period.38 The increased population will benefit greatly
from the multi-faceted Costco warehouse nearby.
5.14 Redcliffe-Perth Airport is projected to benefit the most in the City of Belmont from the
fastest population growth (+148.71%) expected as a result of the development of the
34 https://forecast.id.com.au/belmont/drivers-of-population-change
35http://www.belmont.wa.gov.au/CouncillorPortal/CouncillorMinuteAndMeeting/Minutes%20and%20Agendas%20Documents/
Tabled%20Attachment%201%20Item%2010.1%20refers%20-%20Magazine%20Style%20Publications.pdf
36 https://profile.id.com.au/belmont
37 https://forecast.id.com.au/belmont
38http://www.belmont.wa.gov.au/Services/Planning/Documents/DA6%20Vision%20Plan%20and%20Implemention%20Strateg
y.pdf
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area. Costco is within the developing area. The population growth is illustrated
through the Census data contained in the table below.39
5.15 The introduction of the Costco warehouse is entirely consistent with the growth and
development of the City of Belmont, Development Area 6 and Perth Airport. It will
make a magnificent contribution to the ongoing evolution of the area. Its location is
perfect in this regard.
Perth Airport
5.16 Half of the Locality is composed of the 2,105 hectare airport estate being the suburb
of Perth Airport, situated 12 kms from Perth CBD.
5.17 The Federal Airports Corporation was formed in 1988, as a self-funding commercial
entity, to manage Australia’s largest and busiest civilian airports, including Perth. In
1992 it compulsorily acquired land for the long-term development of Perth Airport.
5.18 In 1997 the control of Perth Airport was transferred to Westralia Airports Corporation
under a 50-year (plus 49-year option) leasehold as part of the first phase in the
privatisation of Australian airports.
5.19 The Perth Airport estate has been subject to significant investments in both aviation
and non-aviation related development since 2008.
5.20 As the lease holder and operator of the Perth Airport estate, Perth Airport Pty Ltd, a
wholly owned subsidiary of Perth Airport Development Group Pty Ltd is required to
develop a master plan every five years under the Airports Act 1996 (Cth). The high-
level plan is a blueprint for future development, covering a planning period of 20 years
and incorporating an environment strategy and ground transport plan.
5.21 The Perth Airport Master Plan of 2014 was approved by the then Deputy Prime
Minister and Minister for Infrastructure and Regional Development, the Hon Warren
Truss on 9 January 2015. In June 2017, the then Minister for Infrastructure and
Transport, The Hon. Darren Chester MP, approved Master Plan 2014 Minor Variation.
The Minor Variation is provided as addendum to and should be read in conjunction
with, the approved Master Plan 2014.40
5.22 Part of the Perth Airport Master Plan 2014 is Development Area 6 which relates to an
area bounded by Tonkin Highway, Great Eastern Highway, Coolgardie Avenue,
Redcliffe Road, Fauntleroy Avenue and the airport precinct. The Development Area 6
includes the establishment of infrastructure and streetscapes that will integrate the
area with itself and its surrounds. A regeneration has been designed to allow people
to enjoy safe and inviting movement by foot, bicycle, rail, bus and car, through a
39 http://www.abs.gov.au/websitedbs/D3310114.nsf/Home/2016%20QuickStats
40 A copy of the Master Plan has not been included in the Applicant’s Case but can be provided if required
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pedestrian-friendly environment.41 The vision for this area is illustrated by the image
below which also shows its relative location to Costco.42
5.23 Considerable residential development and some commercial content will be in close
proximity to the Costco warehouse.
5.24 The intention behind Development Area 6 is to create an “Urban Village in a
Landscaped Setting. Envisage a new ‘pocket’ of urban life at the foothills of the
Darling Scarp, walking distances to the Swan River, Airport West Train Station and on
the door step of the consolidated Perth Airport which is one of Perth’s largest mixed
employment hubs. It is a place for all ages, incomes, lifestyles and families with a mix
of spaces for relaxation and enjoyment for the entire community, encompassed by a
variety of activity opportunities’.43
41 http://www.belmont.wa.gov.au/Services/Planning/Pages/Development-Area-6.aspx
42http://www.belmont.wa.gov.au/Services/Planning/Documents/DA6%20Vision%20Plan%20and%20Implemention%20Strateg
y.pdf
43 Extract of the ‘Vision Plan and Strategy Development Area 6’:
http://www.belmont.wa.gov.au/Services/Planning/Documents/DA6%20Vision%20Plan%20and%20Implemention%20Strategy.
Costco
site
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5.25 There will be a mix of apartments and townhouses designed to ensure high standards
of liveability and neighbourliness. The pedestrian-oriented, child-friendly design of
the street environments will help to create an enduring ambience for the
neighbourhood as a true village lifestyle. Residents in this area will live in mixed
developments between 3 and 13 storeys. These various aspects are generally
indicated in the image below.44
5.26 The Costco services and facilities will provide excellent support to the Development
Area 6 community and complement the role and function of Development Area 6
perfectly, with essential provisions that will be required by the enormous influx of
residents into the Locality.
44 Extract of the ‘Vision Plan and Strategy Development Area 6’
http://www.belmont.wa.gov.au/Services/Planning/Documents/DA6%20Vision%20Plan%20and%20Implemention%20Strategy.
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6 Section 5
6.1 Costco has had regard for the matters outlined in section 5 of the Act and other
relevant provisions.
6.2 Comprehensive submissions addressing section 5 matters and other relevant
sections in the Act are contained throughout this PIA and also in more detail in the
accompanying Legal Submissions (DOC 10).
7 Harm or ill-health – section 38(4)(a)
7.1 The applicant has considered the various risk factors and indicators of the Locality
that are contemplated in the PIA Policy. These include at risk groups and sub-
communities, the incidence of alcohol-related hospital presentations and crime.
7.2 Evidence and submissions in relation to these matters are addressed in detail in this
section of the PIA. Collectively, they reveal no stand-out risk factors of the Locality
such that there should be any concern surrounding the grant of the licence.
7.3 Furthermore, any potential negative impact of the licence should be considered in
light of the many low risk features of the Costco proposal and the minimal potential for
any adverse impacts on the Locality. There are many great benefits to be realised
from the granting of the licence to Costco, as described throughout this PIA. These
matters are addressed in more detail elsewhere in this PIA and the Legal
Submissions (DOC 10).
At risk groups and sub-communities
7.4 With reference to the 2016 Census statistics45, the applicant has studied the groups
and sub-communities in the Locality which are described as “at risk” in the PIA Policy.
7.5 The table below contains statistics for the suburb of Redcliffe, the City of Belmont, the
Locality average46 and Western Australia in respect of at risk groups referred to in the
PIA Policy. The different columns of statistics for different areas provide useful
context in order for the Locality to be analysed.
Census category Redcliffe City of
Belmont
Locality
average
Western
Australia
At risk group or sub community: “Children and young people”
Persons aged 14 and younger 17.9% 16.1% 16.0% 19.2%
45 https://www.abs.gov.au/websitedbs/D3310114.nsf/home/census
46 The statistics for the five main suburbs comprising the Locality have been combined into a Locality average in order to
examine the Locality as a whole.
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Census category Redcliffe City of
Belmont
Locality
average
Western
Australia
Persons aged 19 and younger 22.5% 20.6% 20.8% 25.3%
Average age of persons in
suburb
37 34 37 36
At risk group or sub community: “Aboriginal people and communities”
Aboriginal and Torres Strait
Islander people
3.1% 2.5% 2.5% 3.1%
At risk group or sub community: “Families”
Couple family without children 36.1% 41.7% 41.6% 38.5%
Couple family with children 42.7% 38.6% 38.6% 45.3%
One parent family 17.7% 16.4% 16.8% 14.5%
Other family 3.5% 3.3% 3.1% 1.7%
At risk group or sub community: “Migrant groups from non-English speaking countries”
Australia as country of birth 54.3% 49.1% 52.4% 60.3%
Top three responses as to
ancestry
English
Australian
Irish
English
Australian
Irish
English
Australian
Irish
English
Australian
Irish
English only language spoken
at home
66.3% 60.3% 65.4% 75.2%
Households where a non
English language is spoken
23.6% 29.3% 25.4% 19.4%
At risk group or sub community: “People in low socio-economic areas”
Worked full-time 59.5% 59.3% 59.8% 57.0%
Worked part-time 25.7% 27.0% 26.7% 30.4%
Unemployed 9.3% 8.8% 8.3% 7.8%
Median weekly income –
personal
$724 $722 $749 $724
Median weekly income - family $1,775 $1,725 $1,822 $1,910
Median weekly income -
household
$1,449 $1,431 $1,522 $1,595
Household income more than
$3,000 gross weekly income
13.4% 15.0% 16.6% 19.2%
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7.6 The information in the table above indicates the following key factors for the Locality,
in accordance with the PIA Policy, which reveal positive to neutral risk:
7.6.1 The number of children aged below 19 years of age in the Locality is lower
than the State average. The median age in the Locality is similar to the
State average.
7.6.2 There is a lower proportion of Aboriginal and Torres Strait Islander persons
living in the Locality compared to the State average.
7.6.3 There is a lower proportion of families with children in the Locality
compared to the State average, although the proportion of one parent
families in the Locality is slightly higher to that of the State.
7.6.4 Income levels are relatively similar.
7.7 Further in terms of the socio-economic status of the Locality, the SEIFA47 provides
additional information. The table below shows the deciles (out of 10) for each of the
Locality suburbs on the 2016 Index of Relative Socio-economic Advantage and
Disadvantage records48. Data for Perth Airport the suburb is not available,
presumably because of insufficient residents.
Suburb SEIFA decile within WA
Redcliffe 3
Belmont 4
Ascot 9
Cloverdale 2
City of Belmont 6
7.8 It is acknowledged that much of the Locality experiences low SEIFA ranking,
however, this should not cause concern for the licensing authority in the
determination of the application, or inhibit approval. This proposition is based on the
following important facts which point to a low risk assessment:
7.8.1 The Costco warehouse will cater for a much wider catchment than the
Locality.
7.8.2 The Costco Site is entirely commercial and separated from residences.
7.8.3 The low risk features of the liquor business model proposed.
47 Socio-Economic Indexes for Areas,
http://www.abs.gov.au/AUSSTATS/[email protected]/DetailsPage/2033.0.55.0012016?OpenDocument
48 http://stat.data.abs.gov.au/Index.aspx?DataSetCode=SEIFA_SSC#.
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7.9 The following sub-paragraphs provide information as to other “at risk groups and sub
communities” contemplated in the PIA Policy that could not be quantified by Census
data:
7.9.1 As to people from “regional, rural and remote communities” – the City of
Belmont forms part of the metropolitan area and cannot, therefore, be
considered to be a rural or remote community. However, Costco already
has members living in regional Western Australia (DOC 15) and will provide
those and other regional members with products and services unparalleled
to what they would ordinarily access in their local home towns.
7.9.2 As to people from “mining communities or communities with a high number
of itinerant workers” – the Locality is not a mining community and nor is it
known to attract large groups of itinerant workers although it is
acknowledged that some itinerant workers may exist in the Locality.
7.9.3 As to “communities that experience high tourist numbers” – thousands of
tourists travel through Perth Airport every day. For the financial year
2018/19, there were 9,531,355 domestic passengers through Perth Airport,
being an average of 26,113 people per day and 131,955 flights (either in or
out).49 Clearly many of those passengers would be tourists.
7.10 The Costco Site is bounded by a major freeway, airport services/infrastructure and
the retail factory outlet precinct (known as DFO) and so there is no sensitive place
nearby. The Google Maps image below illustrates this:
49 https://www.perthairport.com.au/Home/corporate/about-us/airport-statistics
Costco Site
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7.11 No alcoholics anonymous facility has been identified anywhere near the Costco Site.
There is some distance to the nearest school, church, etc. Those facilities within the
Locality are listed in the table below:
Name Address
Schools Redcliffe Primary School 62 Kanowna Avenue East, Redcliffe
St Maria Goretti's Catholic School 64 Morrison Street, Redcliffe
Belmont Primary School 213 Great Eastern Highway, Belmont
Belmont City College 106 Fisher Street, Belmont
Belmont Primary School 410 Sydenham Street, Cloverdale
Cloverdale Primary School 180 Fisher Street, Cloverdale
Notre Dame Catholic Primary School 360 Daly Street, Cloverdale
St Augustine's Catholic Primary School 34 Gladstone Road, Rivervale
Ashfield Primary School 65 Margaret Street, Ashfield
Youth centre The Base Belmont 275 Abernethy Road, Cloverdale
Churches Saint Anne's Catholic Church 13 Hehir Street, Belmont
World Mission Society Church of God 8 Hehir Street, Belmont
Perth Alliance Church - English 6/41 Belmont Avenue, Belmont
Nations Church Belmont 240 Epsom Avenue, Belmont
The Church of Jesus Christ of Latter-
day Saints
267 Hardey Road, Cloverdale
Notre Dame Parish 345 Wright Street, Cloverdale
Girls' Brigade Western Australia 2/407 Great Eastern Highway,
Redcliffe
All Saints Anglican Church 300 Belgravia Street, Cloverdale
Christian & Missionary Alliance Of
Australia
324 Belmont Avenue, Cloverdale
Deeper Life Bible Church 275 Abernethy Road, Cloverdale
Day-care
centres
Today's Child Family Day Care 10 Walsh Avenue, Redcliffe
Ngala Early Learning and Development
Service
7 George Wiencke Drive, Perth
Airport
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Name Address
Mulberry Tree Redcliffe Primary School, 62
Kanowna Avenue E, Redcliffe
Jellybeans Child Care Belmont 95 Daly Street, Belmont
Cloverdale Child Care Centre 50 Pearl Road, Cloverdale
Social health indicators
7.12 With regard to crime, the following graphs illustrate general offence data published by
WA Police50 in relation to the Locality.
50 https://www.police.wa.gov.au/Crime/CrimeStatistics#/start
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7.13 It is important to highlight that the data referred to above only shows generally that
some level of crime is occurring in the Locality. The applicant does indeed
acknowledge that fact. However, the data is not that of proven crimes and nor has
any of it been identified as being alcohol related or associated with retail packaged
liquor businesses.
7.14 Whilst the existence of crime in the Locality is acknowledged, it is relevant to highlight
that the Redcliffe-Perth Airport recorded rates at the lower end of the spectrum for the
Locality.
7.15 The following graph provides a further 10-year snapshot summary of Perth Airport
offence rate which shows, positively, a sharp decline from 2015/16 to 2016/17.51
7.16 The applicant’s safety and security measures referred to further on in this PIA will
ensure the risk of any crime associated with the premises is minimised. The
applicant is a most experienced retailer with well-developed systems and procedures
to minimise crime associated with its business activities. In addition to the particular
crime prevention measures to be adopted, the likelihood of the liquor service
contributing to alcohol related crime is reduced by the fact that the Costco warehouse
will be a destination outlet, not on any usual daily route to or from people’s homes
and so impulse or irresponsible buying of liquor from the warehouse will be extremely
unlikely.
7.17 Further in terms of crime prevention:
7.17.1 There will be a simple and open layout of the liquor area, capable of easy
monitoring by staff.
7.17.2 There will be constant staff surveillance achieved by a staff member being
stationed at the licensed checkout at all times.
51 https://www.abc.net.au/news/2018-02-17/crime-data-for-every-perth-suburb-revealed-by-wa-police/9447642
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7.17.3 Wide aisles will be built, facilitating heightened staff surveillance.
7.17.4 The membership system dictates that there will be a prior screening
process.
7.17.5 There will be no walk-in cool room, which is ordinarily hidden from staff
view, providing cover and convenience for would-be criminals; and
7.17.6 A high quality, modern CCTV surveillance will operate throughout the
warehouse, including the proposed licensed area.
7.18 The Department of Health’s Drug and Alcohol Office Surveillance Report 2014
provides some useful information as to alcohol-related hospitalisations. Although now
a few years old, this evidence is believed to be the most recent of its kind published
by the Department of Health. The extract below from the report contains statistics in
respect of the southern Statistical Local Area in the City and reveals that it had
“significantly lower” incidents compared with the corresponding State population
between 2007 and 2011.52
7.19 According to the following table from the City of Belmont’s most recent Health and
Wellbeing Profile, dated May 2016 (copy included in the Index (DOC 17)), there are
fewer people living in the City of Belmont who drink at risky levels compared to both
the South Metropolitan Health Service and the State of WA.53
52 Alcohol-related hospitalisations and deaths in Western Australia, Regional Profile: South Metro’ at page 13. As at the date
of this PIA, the 2014 report is understood to be the most current version although a copy is no longer available online and so
no website link has been provided. However, a copy may be provided to the licensing authority if requested.
53 http://www.belmont.wa.gov.au/Services/CommunityConsultationSurveys/Documents/City%20of%20Belmont%20LGA
%20May2016.PDF and DOC 17 at page 11
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7.20 Costco’s liquor section is most unlikely to contribute to harm or ill-health in the
Locality due to a combination of factors, including the harm minimising strategies
detailed earlier on in this PIA, the fact that the Costco liquor service will be a
destination store for an enormous catchment of many kilometres and the fact that
liquor will be but one type of product together with a huge range of other non-liquor
products to be offered within an enormous retail warehouse. The liquor will be
ancillary, not the main feature. The Costco liquor model does not have a history of
causing problems in other communities where it operates.
Strategies to be implemented to minimise harm or ill-health
7.21 The issue of harm minimisation has been addressed in some detail earlier on in this
PIA. As required, Costco has further considered the minimisation of harm in
developing strategies designed to achieve that goal.
7.22 Costco has been granted liquor store licences in eight of its warehouses in the
eastern states of Australia and therefore, has already developed and successfully
implemented multiple strategies.
7.23 One of the main strategies has been to establish and maintain the low risk Costco
model that is detailed in this PIA.
7.24 Placing a heavy emphasis on staff training and management is another key strategy
to ensuring policies and practices are implemented and laws are complied with.
Costco is a market leader in terms of staff training and personal development. Its
impressive approach in this regard is detailed in the following sub-paragraphs.
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7.24.1 The following is Costco’s published vision for its employees:54
Rewarding careers are built at Costco. We pride ourselves on promoting
from within and giving all employees equal opportunities for advancement.
7.24.2 The applicant invests considerable time, effort and resources into staff.
This proposition is supported by the following extract from Costco’s
recruitment magazine:55
If you like a fast-paced environment where you can interact positively in a
team atmosphere and give customers a great shopping experience while
having a lot of fun – Costco could be the place for you. We pride ourselves
on our safe working environment and have safety policies in place to protect
every employee. We’re committed to providing a workplace that is free from
any form of harassment, where everyone is treated fairly and equally, and
everyone has the opportunity to be successful.
Costco has been rapidly expanding since we opened our first warehouse in
1976, and we’re still going strong, opening warehouses in new and
established markets all over the globe. This is an exciting place to be, and
there are many career opportunities available for those who are willing to
seize them. Our goal is to promote our supervisory and management
positions from within the company as much as possible. In fact, the majority
of our U.S. warehouse managers started as hourly employees
7.25 Costco’s investment in staff is further confirmed by the fact that it often promotes from
within its ranks.
7.26 Every Costco staff member is required to undertake detailed internal training and an
induction programme, which will certainly apply for staff at the proposed premises.
This involves education on a wide variety of facets of the business and includes liquor
product knowledge.
7.27 The applicant will ensure all staff at Costco are properly trained as to their
responsibilities under the Act. All cashiers and managers will receive responsible
service of liquor training. They will also be educated as to the licensing authority’s
policies, matters of safety and all other laws and regulations applicable to the proper
conduct of the business.
7.28 The issue of juveniles is a key element of harm minimisation and has been addressed
in some detail earlier on in this PIA.
7.29 Staff will wear casual attire and a badge with the company logo, their name and the
year they started working at Costco. Years of service as an employee at Costco is
something of real pride for Costco and staff.
54 https://www.costco.com.au/careers
55 https://cdn.costco.com.au/cmsstorage/media/costco/media/pdf/todayrecruiting_australia.pdf at 21
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7.30 Another harm minimising element to the Costco proposal is the focus on quality of
product. The applicant invests enormously in providing members with high quality,
mostly branded and well-known, products, that offer genuine value-for-money:56
With the emphasis always on quality, you will find our selection of wine, spirits and beer
includes the brand names you know well. In addition to our standard range of wine, we
have many fine wines available for purchase. We carry both top-selling beer and lager
as well as selected regional favourites.
8 Impact on amenity, quiet or good order – section 38(4)(b)
8.1 The Costco warehouse will be a purpose-built, modern facility designed to fit within
the local amenity and be an essential part of City of Belmont’s Development Area 6.
8.2 In terms of the impact of the liquor area on the amenity, it is important to reiterate that
it will not have any external frontage, façade or signage. It will be contained well
within the Costco warehouse footprint. The licensed area will not operate as a stand-
alone liquor store.
8.3 The liquor section will have no real capacity to impact on the streetscape or external
amenity whatsoever. Moreover, the Costco warehouse will be part of a distinctly
commercial precinct.
8.4 Costco’s liquor section is, therefore, most unlikely to lessen the quiet or good order of
the Locality in any way.
8.5 Despite the lack of amenity impact, Costco’s liquor proposal will make a noticeable
contribution towards the services and facilities in the developing area and the whole
of WA.
Nature and character of the local community
8.6 The nature and character of the Locality is dominated by the operations of Perth
Airport, the related services and infrastructure around it and the enormous workforce.
Perth Airport is a major employment centre within the Perth metropolitan area,
supporting more than 17,800 jobs including 12,570 full-time aviation employees and
contributing an estimated $2.61 billion to Gross Regional Product (GRP). These figures
are projected to increase to more than 42,000 jobs and a GRP contribution of $7.04
billion by 2034.57
8.7 As stated earlier on in this PIA, only a tiny number of people live in the suburb of
Perth Airport and there are no houses close to the Costco Site.
8.8 The table below contains some statistics from the 2016 Census regarding various
characteristics of the people living in the Locality, which have been compared with the
56 https://www.costco.com.au/food
57 https://www.perthairport.com.au/Home/corporate/about-us/faqs
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Redcliffe-Perth Airport suburb, the City of Belmont, the average of the five main
suburbs that comprise the Locality and the State average so as to put the information
into context.58
58 http://www.abs.gov.au/websitedbs/D3310114.nsf/Home/2016%20QuickStats
Census category Redcliffe City of
Belmont
Locality
average
Western
Australia
Median age 37 34 37 36
Married 40.7% 41.1% 42.1% 48.8%
Never married 38.5% 40.8% 39.0% 35.2%
Language (other than English)
– top response
Mandarin Mandarin Mandarin Mandarin
Occupation (top response) Technicians
and trades
workers
(16.8%)
Professionals
(19%)
Technicians
and trades
workers
(% unknown)
Professionals
(20.5%)
Professionals (%) 16.3% 19.0% 17.8% 20.5%
Industry of employment (top
response)
Iron ore
mining
(3.3%)
Cafés and
restaurants
(3.2%)
Hospitals
(except
psychiatric
hospitals)
(3.4%)
Hospitals
(3.6%)
Worked full-time 59.5% 59.3% 59.8% 57.0%
Worked part-time 25.7% 27.0% 26.7% 30.4%
Median weekly personal
income
$724 $722 $749 $724
Dwelling structure (top
response)
Separate
House
(77.3%)
Separate
House
(67.2%)
Separate
House
(76.1%)
Separate
House
(79.1%)
House owned outright 21.5% 23.6% 25.9% 28.5%
Home owned with a mortgage 37.8% 31.3% 34.3% 39.7%
Median mortgage repayments $1,950 $1,950 $2,000 $1,993
Renting 36.8% 41.1% 36.1% 28.3%
Median rent $350 $350 $365 $347
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8.9 The average person living in the Locality can be described as follows based on the
above statistics:
8.9.1 Aged 37.
8.9.2 Married.
8.9.3 Working fulltime as a technician or in trade in a hospital.
8.9.4 Earning more per week (at a personal level) than the average person in the
State.
8.10 Other observations based on the above statistics include the following:
8.10.1 Of those residents that speak a language other than English, most of them
speak Mandarin.
8.10.2 The most common form of tenure in the Locality is to own a home with a
mortgage.
8.10.3 A third of the Locality is renting which is slightly higher than the State
average.
Outlet density
8.11 Pursuant to the PIA Policy’s requirements, the applicant has identified all of the
licensed premises within the Locality, based on records published by the licensing
authority.59 These are listed in the table below.
No. Licence Type Premises Name Premises Address
1 Liquor Store Cellarbrations At Belmont 248 Epsom Avenue, Belmont
2 Liquor Store Liquor Barons @ Redcliffe 433 Great Eastern Highway, Redcliffe
3 Liquor Store BWS - Beer Wine Spirits
Belmont
144 Epsom Ave, Belmont
4 Hotel International On The Water
Hotel
1-13 Epsom Avenue, Ascot
5 Hotel Comfort Inn Bel Eyre Perth 285 Great Eastern Highway, Belmont
6 Tavern Belvidere's Bar & Bistro
Bottleshop
40 Belvidere Street, Belmont
7 Tavern Redcliffe Tavern 431 Great Eastern Highway, Redcliffe
59 https://portal.rgl.wa.gov.au/forms/fr/search/findalicence/new
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No. Licence Type Premises Name Premises Address
8 Hotel Restricted Sanno Marracoonda Perth
Airport Hotel
373 Great Eastern Highway, Redcliffe
9 Club Belmont R.S.L Club Inc Belmont Memorial Hall 22 Leake St,
Belmont
10 Club Restricted Ascot Cricket Club Inc Middleton Park Middleton Road,
Cloverdale
11 Restaurant Indian Twist 345 Great Eastern Highway, Redcliffe
12 Restaurant Haymarket Shop Fb006, Dfo Perth Airport Dunreath
Drive, Perth Airport
13 Restaurant Mad Mex DFO Fb007, Dfo Perth, Site 5 Airport West
Precinct, Dunreath Drive, Perth Airport
14 Special Facility Perth Duty Free By Dufry 1.C.51, Level 1 2 George Wiencke Drive,
Perth Airport
15 Special Facility Emirates Emirates Lounge Perth International
Airport, Perth Airport
16 Special Facility Gibson & Giles (T3) Level 1 Perth Airport Terminal 3 7 Miller
Road, Perth Airport
17 Special Facility Gian Carlo 6 Miller Road, Perth Airport
18 Special Facility Two Brews Qantas Domestic Airport Perth Airport,
Redcliffe
19 Special Facility Local Food Store Qantas Domestic Airport Perth Airport,
Redcliffe
20 Special Facility Singapore Airlines Silverkris
Lounge
1st Floor Perth International Terminal,
Redcliffe
21 Special Facility Qantas Business Lounge -
Perth International Airport
Perth International Airport Horrie Miller
Drive, Perth Airport
22 Special Facility Virgin Australia Perth
Lounge
Level 1, Terminal 1 383 Horrie-Miller
Drive, Perth Airport
23 Special Facility Four Alls Brew House Terminal Wa T2 2 Sugarbird Lady Road,
Perth Airport
24 Special Facility The Coffee Club Perth
Airport - Domestic Terminal
Wg.C.2 - Terminal 2 40 Sugarbird Lady
Rd, Perth Airport
25 Special Facility VARA Lounge Rg.L.19, Terminal 2 40 Sugarbird Lady
Road Perth Domestic Airport, Perth
Airport
26 Special Facility Guzman Y Gomez And
Harvest
1st Floor, Terminal 1 Horrie Miller Drive
Perth International Airport, Perth Airport
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No. Licence Type Premises Name Premises Address
27 Special Facility Macchinetta Terminal 1 Site 1.C.63, Perth Airport
Horrie Miller Dr, Perth Airport
28 Special Facility 6000 Acres Terminal 1 Horrie Miller Drive, Perth
Airport
29 Special Facility Haymarket Cafe Level 2 Terminal 1 (Airside), Perth Airport
Horrie Miller Drive, Perth Airport
30 Special Facility Long Neck Public House Terminal 1 1.C.205 Domestic Pier 2
George Wiencke Dr, Perth Airport
31 Special Facility Long Neck Public House Terminal 1, Tenancy 1.C.67 Horrie Miller
Drive, Perth Airport
32 Special Facility Toby's Estate Site 1.C.210, Terminal 1, Virgin Pier
Sugarbird Lady Road, Perth Airport
33 Special Facility Loco Poco Bar Level 2 Terminal 1 (Airside), Perth Airport
Horrie Miller Drive, Perth Airport
34 Special Facility Hudsons Coffee Site Dg.C.13, Ground Floor, Terminal 3,
Brearley Avenue, Perth Airport
35 Special Facility Hudsons Coffee Site G.C.61 Terminal 1, Domestic Pier,
Horrie Miller Drive, Perth Airport
36 Special Facility The Crafty Swan Kitchen &
Bar
Site G.C.80 Terminal 1 International,
Horrie Miller Drive, Perth Airport
37 Special Facility Hudsons Coffee Site 1.C.58 First Floor, Terminal 1
International, Horrie Miller Drive, Perth
Airport
38 Special Facility Amelia Duty Free Unit H/D1.C.27, Perth Airport, Terminal 3
Arrivals George Wenke Drive, Perth
Airport
39 Special Facility Perth International Transit
Lounge
Qantas T3 Transit Lounge, Terminal 3 2
George Wiencke Drive, Perth Airport
40 Special Facility Mumbai Rocks DFO Perth, Site 5 Airport West Precinct,
Dunreath Drive, Perth Airport
41 Special Facility Wine Selectors Qantas T4 Domestic Terminal Airport
Drive, Perth Airport
42 Special Facility Qantas Domestic Lounges Qantas T4 Domestic Terminal Airport
Drive, Perth Airport
43 Wholesaler's GHPL Distribution Centre 136 Horrie Miller Dr, Perth Airport
44 Wholesaler's Liquor Plus 2 Horrie Miller Drive, Perth Airport
45 Wholesaler's Q Catering Ltd Perth International Airport Horrie Miller
Dr, Perth Airport
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No. Licence Type Premises Name Premises Address
46 Wholesaler's Daiwa Food Corporation
(WA) Pty Ltd
Unit 3/58 Tarlton Crescent, Perth Airport
8.12 The different licence classes identified in the list above provide some indication of the
services those premises provide.
8.13 Out of the 46 premises in the Locality:
8.13.1 29 are special facility licences, accounting for 63.0% of the outlet density.
All of these licences are located within the Perth Airport itself and clearly
designed and intended to only cater for airline passengers and their guests.
8.13.2 There are four wholesalers, which are generally only permitted to sell and
supply liquor to other licence holders. The wholesalers would not have any
capacity to sell to the vast majority of Costco members at all, let alone to
the extent that Costco will be able to.
8.13.3 The club licence can only sell packaged liquor to its club members.
8.13.4 The tavern restricted, restaurant and club restricted licences have no ability
to sell packaged liquor.
8.14 The most relevant licensed premises to consider are those that are permitted to sell
packaged liquor to the general public, namely the three liquor stores, the hotel and
two taverns. Their locations are indicated on the following Google Map:
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8.15 The particulars of existing premises with the capacity to sell packaged liquor (other
than to lodgers or duty free) have been closely compared with the proposal for Costco
in a table included in the Applicant’s Case, listed at DOC 18 in the Index. The
information in the table very clearly indicates that the Costco liquor service will be
distinctly different.
8.16 The Costco liquor proposal is totally unlike any packaged liquor outlet in the Locality,
or indeed in Western Australia.
8.17 Relevantly, “amongst WA members who ever buy alcohol, 90% report that they
cannot think of another liquor retail offer in Perth similar to the proposed Costco
model”.60 This evidence is from people with direct familiarity with Costco’s liquor
service and also local knowledge of existing packaged liquor outlets.
9 Offence, annoyance, disturbance or inconvenience – section
38(4)(c)
9.1 Costco has carefully considered the impact that may be caused to people who reside
or work in the vicinity of the proposed licensed premises in terms of how and in what
circumstance the sale of liquor at Costco could potentially cause those people
offence, annoyance, disturbance or inconvenience.
9.2 Importantly, there will actually be no residents within close vicinity of the licensed
area. Firstly, the liquor section will be situated well inside the Costco warehouse and
secondly, the Costco warehouse will be some distance from houses.
9.3 The vicinity of the Costco site comprises commercial, light industrial, showroom, retail
and warehouse uses, as well as the airport itself.
9.4 It is not considered that there are any high risk factors associated with this
application, for the various reasons referred to throughout this PIA. Despite that
conclusion, the applicant is aware of the potential for adverse effects from any sale
and supply of liquor into the community and therefore, proposes to implement the
following strategies to “combat offence, disturbance or inconvenience”61 that could
potentially occur:
9.4.1 Managing delivery times and methods in such a way as to minimise
potential disturbances.
9.4.2 Implementing tried, tested and proven operational policies for overall
management and conduct of business.
9.4.3 Maintaining a high standard of premises in terms of cleanliness, tidiness
and overall quality, to indicate to patrons the operator’s professional
approach to management of the business.
60 DOC 11 at page 7
61 PIA Policy
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9.4.4 Employing only mature and skilled people. The staff will be trained to be
able to exhibit a high level of stock knowledge. These features will add an
element of responsibility to the functioning and image of the liquor business.
9.5 No high risk factors associated with the Costco liquor proposal in this case have
arisen in preparing this PIA. The small risk factor that does exist, as with any
licensed premises, will be closely monitored and carefully managed.
9.6 The PRG Report (DOC 11) reveals no concerns to be addressed.
10 Tourism, community or cultural matters – section 38(4)(ca)
10.1 The new Costco warehouse is projected to generate many benefits.
10.2 Clearly the store will attract people from all over the metropolitan area and regional
Western Australia. The fact that there are already around 1,600 members living in
Western Australia without a Costco outlet indicates that those people currently travel
to the eastern states or overseas to visit a Costco store. They will benefit greatly from
not having to travel so far.
10.3 The community as a whole will enjoy Costco’s unique style of operation which is
obviously very popular elsewhere in the world. Products, prices and volumes not
available elsewhere in Western Australia will become available for the first time in this
State with the introduction of the Costco warehouse.
10.4 The establishment of the new Costco facility will generate around 475 jobs of various
types, from construction through to trading.
10.5 The extensive expert research by PRG (DOC 11) has revealed enormous support for
the Costco liquor proposal by the public and that the hundreds of people surveyed
consider they will benefit in several ways.
10.6 In the PRG 3km locality survey:
81% of alcohol buyers (88% of regular buyers) report that should the proposed Costco
Redcliffe store have a liquor section, they would be likely to also purchase their
packaged liquor requirements if shopping for groceries there by becoming Costco
members.62
10.7 In the PRG survey of existing WA members:
84% of members who ever buy packaged alcohol, and 87% of the more regular
buyers indicated that they would shop for their packaged liquor requirements in the
Costco liquor section when shopping there for other (groceries or other household
needs) goods.63
62 DOC 11 at page 7
63 DOC 11 at page 7
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10.8 The Costco proposal stands to create an extraordinary one-stop-shopping opportunity
for the public. Members will be able to purchase, for example, fruit and vegetables,
power towels, clothes, jewellery, homewares, sporting equipment, a hearing aid,
glasses, tyre replacement and a bottle wine all at the same time at the same place.
Both surveys conducted by PRG found a very high requirement for convenience
shopping and that the proposed Costco one-stop combination would be much more
convenient for them64. Added to the one-stop convenience will be that of bulk buying
with the benefit of Costco’s bulk, warehouse style product offering.
10.9 The location of the Costco Site will be most convenient in terms of easy access off
the freeway, parking and the ability for some to readily connect with a flight out of
Perth. “Convenient location” was regarded highly by participants in the PRG
surveys.65
Catchment
10.10 As addressed earlier on in this PIA, the Costco warehouse is expected to have a
regular local catchment of approximately 60km radius/45 minutes. This area
comprises hundreds of thousands of residents living, across most of the metropolitan
area and into regional WA.
10.11 It is anticipated that the liquor service will attract a wide range of member shoppers,
both businesses and individuals.
10.12 Adjacent to Costco’s Costco Site is that of the new “DFO” which is the State’s only
factory outlet retail site with more than 100 stores. It opened in October 2018 has
was/is expected to draw considerable patronage.66 Within the first three weeks of its
opening, 240,000 people visited the DFO.67
11 Consultation
11.1 As referred to throughout this PIA, the applicant has consulted extensively with the
public so as to address issues arising from the PIA Policy and to ascertain demand
for its proposal. The local resident community living within 3km of the Costco Site
and also the existing Costco membership base in WA were surveyed.
11.2 Expertly conducted market research was conducted in July 2019 (DOC 11).
11.3 The evidence reveals a very high demand for and likely usage of, the proposed
Costco liquor service.
64 DOC 11 at pages 25 and 47
65 DOC 11 at pages 8 and 9
66 https://www.perthairport.com.au/Home/corporate/articles/2018/09/06/03/07/dfo-perth-opens-october-3
67 https://www.communitynews.com.au/eastern-reporter/lifestyle/dfo-perth-attracts-the-crowds-two-months-on/
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11.4 The main features of the proposal were found to appeal highly to people surveyed.68
11.5 Importantly, the public expressed a very clear lack of concern in terms of the
proposed liquor service causing offence, inconvenience, annoyance, disturbance, ill-
health or harm. Only a handful of people indicated anything other than having no
concern of experiencing such things.69
11.6 The expert researcher provided the following useful summary of conclusions as
follows in the PRG Report:
In our assessment, both surveys have shown that the great majority of the locality and
the current WA Costco membership is looking forward to the opening of the Costco store
to be created at the Redcliffe store. They have indicated that in a large measure they
intend to shop at the new store. The locality survey showed that a great many local
residents plan to secure a Costco membership to avail themselves of the potential
saving across a wide range of consumer goods, including their packaged liquor
requirements.
More than nine in ten of local resident respondents (96%) report that they will at least try
the Costco store when it opens. To do so they will secure Costco membership.
The free form comment section of the survey reveals the underlying positive expectation
of the arrival of the Costco store in Redcliffe. Expressions of positive attitudes towards
the prospect of a Costco store, complete with a licence for a sectioned off packaged
liquor section, being established in Redcliffe far outweighed the very small number of
comments expressing doubt
or concern at the development.
In our assessment the local community and the current Costco membership are both
awaiting the arrival of the new store with some sense of anticipation of the full range of
the discounts that will be available to Costco members. That includes a very high
proportion that intend to conduct their shopping for their packaged liquor requirements in
the new Costco warehouse superstore.70
12 Conclusion
12.1 Costco has provided a detailed and fully researched proposal which includes all of the
necessary formalities as well as a large volume of supporting information and
evidence from the community, all of which is highly favourable to the grant of the
liquor store licence.
12.2 The particulars of the Costco proposal have been comprehensively set out and
evaluated with reference to all relevant aspects of the PIA Policy.
12.3 Costco has identified and addressed both positive and negative points associated
with the Locality and the application generally. Of the few small risks that exist in this
68 DOC 11 at pages 8 - 11
69 DOC 11 at pages 12 and 13
70 DOC 11 at page 15
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case, several valuable risk minimising measures have been proposed. On the other
hand, there is evidence of many highly positive factors associated with the proposal.
12.4 On the whole, there are no stand-out risk factors of significance and the Locality’s risk
assessment can be considered average/normal, although the Costco Site itself and
its immediate surrounds could be assessed as low risk.
12.5 The Costco liquor service will be a very important feature of the Costco warehouse
and provide an important, internationally renowned and valued service to members
living all around Western Australia and visiting the State.
12.6 The public interest and other legal issues in this case have been addressed further in
the applicant’s detailed Legal Submissions (DOC 10).
Dated 18 September 2019
________________________________
Lavan
Lawyers for Costco Reference: Jessica Patterson
T: (08) 9288 6946
www.lavan.com.au
