www.public-place.com.au

PACKAGED LIQUOR OUTLET

- 592-694 HIGH STREET,

EPPING

Prepared for Kaufland Australia Pty Ltd

November 2018

ii

Contents

1 INTRODUCTION ............................................................................................................................. 4

2 CUMULATIVE IMPACTS .................................................................................................................. 5

2.1 INTRODUCTION.............................................................................................................................. 5

2.2 PACKAGED LIQUOR OUTLETS AND AMENITY ........................................................................................ 5

2.3 THE PROPOSED STORE .................................................................................................................... 7

2.4 FLOOR SPACE ................................................................................................................................ 8

3 ALCOHOL AND BROADER SOCIAL ISSUES ..................................................................................... 10

3.1 INTRODUCTION............................................................................................................................ 10

3.2 ACCESSIBILITY AND HEAVY DRINKING ............................................................................................... 10

3.3 THE PROPOSED STORE .................................................................................................................. 13

3.4 LARGE FORMAT STORES ................................................................................................................ 14

4 CONCLUSIONS ............................................................................................................................. 15

5 REFERENCES ................................................................................................................................ 16

3

Facts, matters and assumptions

Following receipt of written instructions from Planning and Property Partners on behalf

of Kaufland Australia Pty Ltd on 16 November 2018, I determined that I could be of

greatest assistance to the Kaufland Stores in Victoria Advisory Committee, if I provided

a report outlining my views regarding Council’s submission to the Committee that:

The bottle shop component of the proposal should not be approved until such time as

a Cumulative Impact Assessment and a Social and Economic Impact Analysis have

been prepared and assessed.

In any event, the bottle shop should be no greater than 200 sq.m in floor space.

Declaration

I have made all the inquiries that I believe are desirable and appropriate and no matters

of significance which I regard as relevant have to my knowledge been withheld from the

Panel.

4

1 Introduction

This report has been prepared to assist the Kaufland Stores in Victoria Advisory

Committee (the Committee) when considering an application for planning approval for a

packaged liquor outlet at 592-694 High Street, Epping.

The City of Whittlesea has indicated in its short form submission to the Committee that:

The bottle shop component of the proposal should not be approved until such time as

a Cumulative Impact Assessment and a Social and Economic Impact Analysis have

been prepared and assessed.

In any event, the bottle shop should be no greater than 200sqm in floor space.

This report assesses the potential cumulative and social impacts associated with the

proposed outlet, and ultimately the Council’s submissions.

5

2 Cumulative Impacts

2.1 Introduction

Alcohol and licensed premises impact both positively and negatively upon communities

in a multifaceted way. However, in the context of a cumulative impact assessment,

relevant considerations are limited to the decision guidelines of Clause 52.27 of the

Whittlesea Planning Scheme. The decision guidelines of Clause 52.27 state that the

responsible authority must consider the impact of the sale or consumption of liquor

permitted under a liquor licence, hours of operation and number of patrons, on the

amenity of the surrounding area. Also, the guidelines state that the cumulative impact of

any existing licensed premises and the proposed licenced premises on the amenity of

the surrounding area, must be considered.

Practice Note 61 (March 2011) provides guidance in relation to the assessment of an

application under Clause 52.27. The practice note indicates that the ‘surrounding area’

should be considered to be the area within approximately 500 metres of the proposal

site, with a particular focus on the area within 100 metres being appropriate. Neither of

Clause 52.27 or Practice Note 61 refer to broader issues relating to the accessibility of

alcohol in the community generally.

2.2 Packaged Liquor Outlets and Amenity

The potential for packaged liquor outlets to generate unwanted amenity impacts in their

immediate environs has been the subject of extensive debate in VCAT and VCGLR

hearings in Victoria, and I have participated in a number of these. The debate has in

large part focussed on the implications of several published research studies

undertaken in Victoria (for example Livingston 2008), which report statistical

associations between the number of packaged liquor outlets in an area (the outlet

density) and alcohol related violence. The findings of these studies have prompted

commentary such as the following:

It is worth considering whether packaged liquor outlets provide a place for

people to meet and entertain themselves in suburban areas where fewer on-

premise and hotel establishments are available (Livingston 2008).

An explanation of this type suggests that surrounding a packaged liquor outlet is a

localised zone of elevated risk of alcohol related violence (and potentially other

disorderly behaviours), which arises due to the congregation of drinkers in the

immediate vicinity of the outlet.

6

Before accepting this potential explanation, it is important to note that the analysis

conducted as part of the Victorian based research (and indeed most density based

studies)1 did not include alcohol sales volume by outlet as a control variable. The

importance of this omission is made evident by research conducted by Liang and

Chikritzhs (2011) in Western Australia. The researchers in this case had the benefit of

access to data on alcohol sales volumes from packaged liquor outlets, finding:

If sales volume by outlet was excluded from their statistical model, then an

association between outlet density and violence was apparent.

However, if sales volume by outlet was included in their statistical model, no

significant relationship between the density of packaged liquor outlets and violence

was found.

That is, counts of packaged liquor outlets act as a proxy for alcohol sales in statistical

models which seek to link outlet numbers and indicators of negative amenity impacts.

The above reflects the fact that, unlike the alcoholic beverages sold within pubs, cafes,

nightclubs, etc. packaged liquor is not usually consumed in the immediate vicinity of the

point of sale or necessarily immediately following the purchase. That is, in the vast

majority of cases, the area surrounding a packaged liquor outlet is not negatively

affected by alcohol related amenity impacts as a direct result of the physical presence of

the outlet.

Consistent with the published research, the author has previously conducted/overseen

qualitative research in the form of interviews with traders and local police to determine

whether negative amenity impacts are experienced in close proximity to packaged liquor

outlets in suburban Melbourne and in regional Victoria. The information collected

suggests that alcohol purchased from packaged liquor outlets is typically consumed

away from the premises. Specifically, those interviewed had not observed packaged

liquor outlet customers using the outlets as places to meet for social/entertainment

purposes, or drinking in close proximity to the outlets. As a result, any harms resulting

from consumption of packaged liquor purchased from these stores would be dispersed

throughout the community and not concentrated in the immediate vicinity of the outlets.

The above considered, as a general rule, packaged liquor outlets are very low risk form

of licensed premises in the context of Clause 52.27.

1 As Liang and Chikritzhs (2011) state: With only a few exceptions the outlet density and violence literature is dominated by studies, which are restricted to measuring outlet density by counting numbers of outlets and then converting them to a rate (e.g. per resident, per unit geographical area, per road miles) while excluding measures that actually quantify alcohol sales made by these outlets.

7

Notwithstanding the above, if a packaged liquor outlet is located within an entertainment

precinct, then the outlet may potentially exacerbate amenity impacts associated with the

presence of patrons of on-premises venues in the precinct, particularly later into the

evening.

2.3 The Proposed Store

The proposed packaged liquor outlet would be located within a proposed supermarket,

situated within the Epping Homemaker Centre (see Figure 2-1). There is currently one

licensed premises located within the Epping Homemaker Centre, the Taj on High Indian

restaurant.

To the west on the opposite side of High Street is the Pacific Epping shopping centre,

which includes a large carpark facing High Street. On the western side of the shopping

centre is a dinning and entertainment precinct which accommodates several licensed

premises, including restaurants and the Epping Plaza Hotel. There are three packaged

liquor outlets located within the Pacific Epping shopping centre (Liquorland, BWS and

Aldi) and the Epping Plaza Hotel is also licensed to sell packaged liquor. A fifth

packaged liquor outlet (Dan Murphy’s) is located on High Street within the shopping

centre carpark.

Approximately 500 metres to the north along High Street near the corner of Coulstock

Street is the Epping Hotel (includes a drive through bottle shop), a handful of small

restaurants and the Epping Squash & Fitness Centre.

Licensed premises to the east are separated from the site by the rail line and not

considered relevant to this assessment.

The presence of these existing venues means that the proposal site is technically within

a 500 metre cluster of licensed premises, as defined by Practice Note 61. However, in

practice there is little if any connection between the proposal site and the entertainment

precinct to the west, which is located on the other side of the shopping centre. To

access the entertainment precinct from the proposal site, a pedestrian would need to

walk over 400 metres and cross High Street and two large carparks, before travelling

through, or even around the shopping centre. While making this journey the pedestrian

would walk past/near the existing packed liquor outlets within the shopping centre.

Similarly, the Epping Hotel and the proposal site are not well connected. This venue is

located approximately 500 metres to the north and is separated from the proposal site

8

by major pedestrian barriers, including High Street and Cooper Street. In any case, the

venue has its own drive through bottle shop.

The author visited the subject site on the evening of 16 November 2018. On this

evening there was virtually no pedestrian traffic on the eastern side of High Street near

the subject site. Likewise there was no sign that patrons of venues in the entertainment

precinct to the west travel on foot to the east across High Street. The above considered,

the risk of unwanted interactions between the proposed outlet and the patrons of on-

premises venues to the west and north is negligible.

Given the above, the proposed packaged liquor outlet and its environs would not

become a place where people congregate to consume alcohol. As a result, the area in

and around the outlet would not be negatively affected by alcohol related amenity

impacts as a direct result of the physical presence of the outlet.

2.4 Floor Space

The Council has indicated in its submission that the proposed packaged liquor outlet

should be no greater than 200 sq.m in floor space.

As discussed above, the proposal as it stands would not generate localised alcohol

related amenity impacts. Moreover, to the author’s knowledge, there is no published

research which indicates that larger or smaller packaged liquor outlets (in terms of floor

area) are more or less likely to generate localised amenity impacts. Nor is there, in the

authors opinion, any reason to expect that reducing the size of the proposed outlet

would have any benefit in terms of mitigating potential localised amenity impacts.

9

Figure 2-1: Licensed Premises in Close Proximity to the Proposal Site

10

3 Alcohol and Broader Social Issues

3.1 Introduction

The City of Whittlesea has suggested that the likely social impacts of the proposed

packaged liquor outlet should be assessed, and I therefore discuss these below.

Alcohol consumption is a common and accepted part of life in Australia. To illustrate, in

2011-12, 82.4% of Australians aged 18 years and over had consumed alcohol in the

past year. A further 7.5% had consumed alcohol 12 or more months ago (ABS 2012).

Alcohol is consumed in religious and cultural ceremonies, social and business functions,

and in conjunction with celebrations and recreational activities. For many Australians,

‘having a drink’ is synonymous with relaxation, socialisation and good times. Moreover,

licensed premises are popular venues for entertainment and an important location for

socialising, particularly among young people.

However, at times excessive consumption of alcohol may be associated with negative

health impacts for drinkers and/or antisocial behaviour and violence, which can affect

drinkers and non-drinkers. While estimates of the annual cost to the Australian

community from alcohol-related harm vary widely (for example Crampton et.al 2011

provide an estimate of $3.8 billion, whereas CoA 2008 provide an estimate of $15

billion), there can be no doubt that the costs are significant.

For the proposed packaged liquor outlet to influence the extent/character of alcohol

related harm experienced within the community there must be a causal mechanism(s)

linking the operation of the outlet and one or more of the following:

When and where alcohol is consumed.

The circumstances under which alcohol is consumed.

The extent to which alcohol is consumed in excess.

The first two points have been addressed under the heading cumulative impacts. This

section addresses the issue of whether the proposed packaged liquor outlet would alter

the extent to which alcohol is consumed in excess within the community.

3.2 Accessibility and Heavy Drinking

It would be unsurprising if there is a relationship between the number and distribution of

packaged liquor outlets in an area and the consumption of alcohol. This is because

development of new outlets reduces the average distance people have to travel to

11

access a store (i.e. physical availability is increased). It is also possible that as new

outlets appear in an area the intensity of competitive pricing practices may increase,

enhancing the relative buying power of consumers (i.e. economic availability is

increased). However, as Livingstone et. al. (2007) and Marsden and Jacobs (2005)

suggest, in areas where there are many existing opportunities to buy alcohol, and where

price competition is already high, a new outlet may have less impact on the full cost of

alcohol (market price plus convenience costs) than in area with few outlets and little

competition (see Figure 3-1).

Figure 3-1 – Theorised Relationship between liquor outlets numbers and alcohol sales

(Source: Marsden and Jacobs 2005).

12

Below, the likely impact of the proposed outlet in terms of increasing access to

packaged liquor/triggering increases in heavy drinking is discussed in the context of a

study conducted in Melbourne by Kavanagh et al. (2011). The study investigated the

extent of frequent drinking and heavy drinking (short term and long term) among

Melbourne residents2 with differing levels of access to packaged liquor. The study

found:

No relationship between the distance between a person’s residence and their closest

packaged liquor outlet and frequent or heavy drinking (short or long term). For

example, it was found that people who live more than 1.2 kilometres from their

nearest packaged liquor outlet were not more likely to consume alcohol frequently or

drink heavily than those who live closer to an outlet (including those whose closet

outlet is within 400 metres).

No significant association between the price of a commonly stocked basket of

beverages in the closest store to a person’s residence and frequent or heavy drinking

(short or long term).

No significant association between the range of products stocked in the store closest

to a person’s residence and frequent or heavy drinking (short or long term).

A significant association between packaged liquor outlet density (measured as the

the number of stores within a one-kilometre road network distance of a

respondent’s home) and short term heavy drinking (at least weekly and at least

monthly) and a relatively strong association between density and frequent drinking

and heavy drinking (long term).

That is, the study found that heavy drinking is associated with outlet density but not with

more direct measures of individuals’ degree of access to packaged liquor, such as

proximity, price and product range. It is notable that similar results have been found by

other researchers who have simultaneously investigated measures of proximity and

density (for example, see Pollack et al. 2005 and Scribner et. al 2000). The above

considered, the relationship between the accessibility of packaged liquor (physical

and/or economic) and frequent/heavy drinking is characterised by two way causality:

On the one hand, increased accessibility stimulates demand.

On the other hand, a population that already includes frequent and/or heavy drinkers

will be typified by greater sales volumes encouraging greater supply of liquor outlets.

2 2,334 adults aged 18–75 years from 49 census collector districts in metropolitan Melbourne.

13

The relative influences of supply and demand side factors in any setting will depend on

the existing level of accessibility and the nature of the host communities, with demand

side influences becoming more dominant as accessibility rises. In the Melbourne

context, and consistent with the findings of the Kavanagh study, Livingstone (2012)

states:

Given Melbourne‘s already high level of alcohol availability, increases in off-

premise outlet numbers would be expected to reduce the convenience cost

of alcohol purchases by relatively small amounts and would thus be unlikely

to greatly affect population level drinking (Livingstone 2012).

The above considered, while it is reasonable to expect large differences in physical

and/or economic accessibility of packaged liquor to influence rates of frequent/heavy

drinking in a community, the actual differences which exist in metropolitan Melbourne

are relatively small and typically not sufficient to influence frequent/heavy drinking rates.

The fact that heavy drinkers have been found to be less sensitive to prices changes

than the general population likely contributes to/re-enforces the above.3

3.3 The Proposed Store

There are three packaged liquor outlets located within the Pacific Epping shopping

centre (Liquorland, BWS and Aldi) and the Epping Plaza Hotel is licensed to sell

packaged liquor. A fifth packaged liquor outlet (Dan Murphy’s) is located on High Street

within the shopping centre carpark (see Figure 3-2).

To the north approximately 500 metres along High Street, the Epping Hotel includes a

drive through bottle shop.

The above considered, packaged liquor is currently readily accessible to the Epping

community. While the proposed outlet would increase access, the change would be

small and not sufficient to stimulate a material increase in excessive alcohol

consumption.

3 For example Wagenaar et al. (2009) conducted a review of 112 studies examining measures of beverage

price levels and self-reported drinking. Simple means of reported elasticity were -0.46 for beer, -0.69 for

wine and -0.80 for spirits. The researchers also found that the mean reported elasticity for heavy drinking

was -0.28.

14

Figure 3-2: Packaged Liquor Outlets within 5 Kilometres of the Subject Site

3.4 Large Format Stores

There is no necessary relationship between the floor area of a packaged liquor outlet

and sales volume or pricing strategy. As a result, limiting the floor area of the outlet as

suggested by the Council would not influence rates of excessive alcohol consumption in

the broader community.

15

4 Conclusions

The proposed packaged liquor outlet and its environs would not become a place where

people congregate to consume alcohol. As a result, the area in and around the outlet

would not be negatively affected by alcohol related amenity impacts as a direct result of

the physical presence of the outlet.

The proposed packaged liquor outlet would alter the accessibility of packaged liquor by

a relatively small amount and this change would be insufficient to stimulate a material

increase in harmful alcohol consumption.

The proposed packaged liquor outlet would be located within a supermarket. Inclusion

of a packaged outlet within the supermarket would enable those completing their routine

grocery shopping and the like, to purchase packaged liquor at the same time, with

obvious benefits in terms of convenience for shoppers.

The City of Whittlesea’s request that information on potential cumulative and social

impacts be presented as part of the development proposal is reasonable. The

information presented herein fulfils that requirement.

Limiting the floor space of the proposed packaged liquor to no greater than 200 sq.m.

would not be an effective strategy for mitigating potential cumulative or social impacts

associated with the outlet (which would be negligible in any case).

16

5 References

ABS (2012) 4364.0.55.001 - Australian Health Survey: First Results, 2011-12.

Commonwealth of Australia (2008) Technical Report No 3: Preventing alcohol-related harm in

Australia: a window of opportunity, Prepared for the National Preventative Health Taskforce by

the Alcohol Working Group.

Crampton, E, Burgess, M and Taylor, B (2011), ‘The Cost of Cost Studies’, Prepared for

presentation at the Annual Meeting of the New Zealand Association of Economists, 2011,

Wellington.

Kavanagh and Krnjacki (2011) Accessibility to alcohol outlets and alcohol consumption Findings

from VicLANES. Victorian Health Promotion Foundation (VicHealth), Carlton, Australia.

Liang and Chikritzhs (2011) Revealing the link between licensed outlets and violence: Counting

venues versus measuring alcohol availability, Drug and Alcohol Review (September 2011), 30,

524–535.

Livingston (2012) The effects of changes in the availability of alcohol on consumption and health

and social problems, School of Population Health, University of Melbourne.

Livingston (2008) A Longitudinal Analysis of Alcohol Outlet Density and Assault, Alcohol Clin Exp

Res, Vol 32, No 6, 2008: pp 1074–1079.

Livingston M, Chikritzhs T and Room R. (2007): Changing the Density of Alcohol outlets to

reduce alcohol related problems, Drug and Alchohol Review, 26: 557-566.

Marsden Jacob Associates (2005) Identifying a framework for regulation in packaged liquor

retailing - Report by Marsden Jacob Associates for the National Competition Council.

Pollack C., Cubbin C., and D.,Winkleby M.(2005) Neighbourhood deprivation and alcohol

consumption: does the availability of alcohol play a role? Int J Epidemiol 2005; 34: 772–80.

Scribner R., Cohen D., Fisher W. (2000) Evidence of a structural effect for alcohol outlet density:

a multilevel analysis. Alcohol Clin Exp Res; 24: 188–95.

Wagenaar; Salois Komro (2009) `Effects of beverage alcohol price and tax levels on drinking: a

meta-analysis of 1003 estimates from 112 studies’. Addiction (Abingdon, England) 2009;104(2):

179-90.