Fletcher Street, Byron Bay 2481

In the rejection letter for the Taree ALDI licence application ILGA stated:

"in the Authority’s view there will be adverse consequences from introducing a new discount retailer into a community with prevailing high levels of alcohol related crime”

and

"In the Authority’s view any downward pressure on prices at the discount or cheaper end of the retail packaged liquor market will, as contended by Police, further enable problem drinkers (who the Authority is satisfied will be of limited means) to acquire liquor in greater quantities and greater frequencies than may otherwise be the case.”

ALDI states in their own CIS;

"ALDI acknowledges that many of the concerns expressed by those opposing the application have validity. For example, rates of alcohol-related assault remain high in Byron Bay, despite a discernible recent downward trend.”

and

"Simply put, these statistics do give rise to some concern and would give pause for thought to any liquor regulator or any responsible liquor provider, such as ALDI."

Byron Bay ALDI Application vs Rejected Applications for ALDI Packaged Liquor Licences in Toormina and Liverpool

From - Rejected Application for Packaged Liquor Licence Aldi- Toormina - Page 8
“the Authority cannot ignore the substantial concerns raised by the RMS data. While RMS do not provide data on the relationship between consumption of packaged liquor (as distinct from on premises liquor) and drink driving in the LGA, the Authority considers it likely that the consumption of both on premises and off premises liquor is likely to contribute to this problem, particularly among financially constrained persons who cannot afford to drink in licensed venues. The relative over exposure of the broader community to this adverse alcohol related impact is a further factor that militates against the grant of the Application, especially in a regional area where public transport options may be relatively limited, tempting locals to drink and drive.”

Byron Bay has significantly higher rates of drink driving that the Coffs Harbour LGA, it also has considerably lower average income, levels and as a regional area has very little in the way of public transport options.

From - Rejected Application for Packaged Liquor Licence Aldi- Toormina - Page 8
“The Authority is satisfied that should the Application be granted, the licenced ALDI liquor store will represent one more source of retail packaged liquor in the local and broader communities. The licensed business is more likely than not, over time, to contribute to the prevailing issues of alcohol related violence and anti- social conduct in those communities.”

If the ALDI licence right in the heart of the Byron CBD (where almost all of the alcohol related problems occur) is approved, then ILGA will have no credible ability to reject a similar application from Woolworths on Jonson St, Spar in Suffolk Park, The Handimarket on Lawson St, IGA in Sunrise. This application represents possibly a huge increase in the number of bottleshops in Byron Bay

From - Rejected Application for Packaged Liquor Licence Aldi- Toormina - Page 10
“Nevertheless, the Applicant's busy staff will not, in the Authority's view be in a position to meaningfully monitor or respond to abuse of packaged liquor other than at the point of sale or in the immediate vicinity of the premises.”

The ALDI Supermarket in Byron Bay has severely limited visibility to the outside of the shop, and where the staff sit at the checkouts, they have their backs to the entrance and outside of the shop. They will in no way be able to monitor for secondary supply or other abuses away from the checkout. They also do not have the staff to respond in any case.

From - Rejected Application for a Packaged Liquor Licence ALDI Liverpool Central - Page 13
“The Authority is satisfied that if the Application was granted, this ALDI supermarket, along with the other incumbent local packaged liquor outlets in Liverpool would contribute to the prevailing alcohol related adverse impacts, particularly alcohol related domestic violence, occurring in this very disadvantaged local community.”

Byron Bay has considerably higher rates of alcohol related domestic violence (209 vs 114 per 100k pop.), has much lower avg personal income and higher rates of unemployment than the Liverpool LGA.

From - Rejected Application for a Packaged Liquor Licence ALDI Liverpool Central - Page 13
“Drinking take away liquor is generally much cheaper than drinking liquor on licensed premises and the Authority is satisfied that ALDI's product range and competitive pricing will be attractive to disadvantaged persons in the local community who already shop at this ALDI supermarket for its competitively priced groceries.”

Byron Bay has much lower avg personal income and higher rates of unemployment than the Liverpool LGA.

From - Rejected Application for a Packaged Liquor Licence ALDI Liverpool Central - Page 14
“The Premises is also located in a high density hotspot for alcohol related assault generally. “

The proposed location for the Byron Bay ALDI is exactly in the center of the Byron LGA hotspot for alcohol related assault at MUCH, MUCH higher rates than the Liverpool LGA (597 vs 74 per 100k pop.)

From - Rejected Application for a Packaged Liquor Licence ALDI Liverpool Central - Page 14
“There would be one more take away liquor outlet than would otherwise be the case in the Liverpool CBD at which problem drinkers of very limited means would likely seek out low priced liquor, either directly by adults who abuse liquor in the home or by secondary supply in the case of minors “

Byron Bay has considerably higher rates of alcohol related domestic violence (209 vs 114 per 100k pop.), alcohol related assault (597 vs 74 per 100k pop.) and has much lower avg personal income and higher rates of unemployment than the Liverpool LGA.

From - Rejected Application for a Packaged Liquor Licence ALDI Liverpool Central - Page 14
“Among the spectrum of price points that will be catered for by the new ALDI liquor business, numerous discount liquor lines would be on offer and those lines would be attractive and accessible to problem drinkers of very limited means.
The Authority is satisfied that if licensed, the Premises would operate over time as one more source of supply of liquor to pre-fuelling adults and another source of secondary supply of liquor to minors, both of which have been identified as matters of concern to the LAC- observations that the Authority considers to be credible. “

Byron Bay has very high rates of alcohol related assault (597 vs 74 per 100k pop.), and most of these assaults occur on the streets where pre-fuelling is a major concern. Byron Bay has very high numbers of young people so secondary supply is also of major concern. Byron Bay would have significantly higher numbers of drinkers of limited means as Byron LGA has has much lower avg personal income and higher rates of unemployment than the Liverpool LGA.

Why, when these other ALDI applications have been rejected by ILGA in areas of far less concern, is this licence being even considered in Byron Bay?

Yours Sincerely
Kaye Pearson

Could there be a worse location to approve a new prepackaged liquor licence? Especially one that primarily sells a limited range of only very, very cheap alcohol.

The proposed site for the Byron Bay ALDI bottleshop is:

30M from Byron Bay Centerlink, the busiest on the north coast.

30M from Railway Park, the main CBD location for homeless people to gather and drink in public.

In the dead center of the Byron LGA hotspot for alcohol related assault at MUCH, MUCH higher rates than almost any other hotspot in the state (597 vs 158 per 100k pop. for the LGA)

In the dead center of the Byron Bay Alcohol Free Zone, instituted by Byron Shire Council “to deter the consumption of alcoholic substances in public places”

They will open at 8AM on Saturdays an hour earlier than any other bottleshop in Byron.

Byron Bay LGA already has:

DUI rate four times the state average (has been No 1 LAC in NSW for DUI for many years)

Incidents of Alcohol Related Non Domestic Assault four times the the state average (597 vs 158 per 100k pop.)?

Incidents of Alcohol Related Domestic Assault 50% higher than the state average (209 vs 132 per 100k pop.)

Assault Police double the state average (63 vs 34 per 100k pop.)

Liquor offences four times the state average (755 vs 179 per 100k pop.)

Disorderly Conduct offences five times the state average. (1537 vs 312 per 100k pop.)

Number of liquor licences double the state average (220 vs 150 per 100k pop.)

To grant this licence would be grossly negligent.

Luis Granada

Byron Bay ALDI Application vs Rejected Application for an ALDI Packaged Liquor Licences in Taree.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 8
“Taree and Foster, has been identified by Police as one of the most under resourced Commands in New South Wales, with one of the highest “workload per officer” rates in the State. “

Byron Bay LAC has THE “highest workload per officer” in the State.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 8
“An Alcohol Free Zone (“AFZ”) borders nearby the rear of the Premises”

The proposed ALDI site is in the very center of the Byron Bay Alcohol Free Zone.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 9
Police note the Applicant’s proposal that it will not sell refrigerated liquor to minimise the potential for public consumption after purchase. Police submit that: ?“The sale of non-refrigerated alcohol may not necessarily prevent immediate consumption, particularly when the persons responsible for the street drinking and anti-social behaviour in the Taree CBD frequently consume warm cask wine and beer after gathering for several hours in the identified hot spots.

One of the most significant areas that homeless congregate to drink in the Byron Bay CBD is Railway Park which is 30 meters from the proposed ALDI site.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 10
“Police submit: ?“The number of ‘lines sold’ is irrelevant while ever sales are based on demand. It is anticipated that certain products in high demand, due to low cost combined with matching or greater volume, will be catered for by the proposed store. As a result, the vulnerable and disadvantaged will have greater access to higher volumes of alcohol, inevitably leading to increased consumption and further abuse.”

The local liquor accord has removed 4L casks from their shelves in an effort to reduce the economic availability of alcohol to the “vulnerable and disadvantaged” to reduce alcohol related harm. ALDI not only stocks them, they sell them very cheaply. This will undermine the good work done by the local liquor accord.?

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 11
“overall density of licensed premises, ABS population and OLGR licensing data from the OLGR Social Profile Report indicates that there were 224 liquor licences per 100,000 persons in the Taree LGA, higher than the NSW average of 220 “

Byron Bay has almost double Taree LGA’s density of liquor licences (351 vs 224 per 100,000 head of population)?

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 13
“Police identify noise complaints, malicious damage, anti-social behaviour and large scale public disorder incidents as matters arising from the abuse of alcohol that are “quite obvious” to Police and the community.”

Byron Bay has almost triple Taree LGA’s incidence of Disorderly Conduct (1537 vs 479 per 100,000 population) and Byron Bay’s “large scale public disorder” often makes the national and international news!

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 14
‘Police contend that in this local environment: ?“Increased access to discounted alcohol may well challenge existing intervention processes and over turn some positive results seen over the years. Moreover, intervention and prevention of alcohol abuse in residential/private premises remains the most difficult of challenges faced by police and the community.”
?The local liquor accord has made a concerted effort to reduce alcohol related harm, and to date their actions have had reasonable success reducing such. ALDI even comments on the “recent downward trend” in their CIS.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 16
“Police expect the proposed Aldi store to market and sell products at competitive prices based on local demand. Therefore, stocking a smaller “range” of products, as frequently referred to throughout the CIS, will be of no positive consequence. Customers, particularly the vulnerable and disadvantaged will have access to greater quantities of alcohol (including bulk buying); a situation that is likely to encourage further abuse, and have an overall adverse impact on crime, emergency services, and the health and safety of the community.”

The local liquor accord has removed 4L casks from their shelves in an effort to reduce the economic availability of alcohol to the “vulnerable and disadvantaged” to reduce alcohol related harm. ALDI not only stocks them, they sell them very cheaply. This will undermine the good work done by the local liquor accord, and have an overall adverse impact on crime, emergency services, and the health and safety of the community.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 27
“Aldi makes no secret of its willingness and ability to offer consumers discount prices. For example, in the Authority’s letter to Aldi dated 30 November 2011, the Authority noted that Aldi offers its own brand Storm Brewing Co Premium Light (low alcohol beer) at $19.99 per carton and its own brand Schloss Pils German Beer (full strength beer) at $29.99 per carton.”

An ALDI licence will see a massive reduction in the real world price of the cheapest, regular price of a carton of beer or bottle of wine in Byron Bay (by 30-50%). By far and away the worst outcome is the ALDI 4L casks for $8.99 ($2.24 per LITRE of wine) compared to the existing bottleshops 2L casks for $12.99 ($6.50 per litre of wine). This means that the cheapest way to get drunk, drops to almost ONE THIRD of the current cost! This is exactly the reason that the local liquor accord included as part of its terms, an undertaking to not sell ANY casks larger than 2L.?

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 27
“the Authority is satisfied that, if this additional packaged liquor licence is granted Aldi will introduce numerous new liquor lines at a location in the centre of Taree and at least some of those new lines will be very attractive and accessible to low income customers.

An ALDI licence will see a massive reduction in the real world price of the cheapest, regular price of a carton of beer or bottle of wine in Byron Bay (by 30-50%).

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 27
“in the Authority’s view there will be adverse consequences from introducing a new discount retailer into a community with prevailing high levels of alcohol related crime and disturbance and socio demographic indicia that correlate with an increased risk of that population experiencing adverse impacts from the supply of alcohol. “

Byron Bay has much higher levels of “community with prevailing high levels of alcohol related crime and disturbance” than Taree LGA?

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 28
"58. The Authority is not satisfied that a new Aldi liquor outlet will not bring additional competitive pressure to bear with regard to the pricing of discount packaged liquor lines among local retailers - as rival established packaged liquor businesses compete to attract takeaway liquor customers from this very competitive new arrival, offering new lines of home brand liquor in addition to “seasonal specials” on established brands.
59. The Authority is not satisfied that the new discount liquor lines that the Applicant is likely to offer, in this location, will not be a significant attraction to problem drinkers of limited means who already suffer from acute and chronic alcohol abuse and who suffer or perpetrate alcohol related harm in the local and broader community.
58. However, the Authority cannot be satisfied, on the material before it, that the arrival of:
a new packaged liquor outlet with all the purchasing power of a major supermarket chain that is likely to offer dozens of new home brand liquor product lines at very competitive prices will not bring with it some further, downward pressure on the prices of liquor at lower price points and enable problem drinkers of limited means in these local and broader communities to purchase alcohol in greater quantities and frequencies than might otherwise be the case. "

By far and away the worst outcome is the ALDI 4L casks for $8.99 ($2.24 per LITRE of wine) compared to the existing bottleshops 2L casks for $12.99 ($6.50 per litre of wine). This means that the cheapest way to get drunk, drops to almost ONE THIRD of the current cost! This is exactly the reason that the local liquor accord included as part of its terms, an undertaking to not sell ANY casks larger than 2L.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 29
“By this, the Authority understands Police to mean those who currently abuse alcohol and are from socioeconomically disadvantaged groups. Of particular concern to the Authority are street drinkers and underage drinkers.”

Byron Bay has a significant problem with street drinking which is why Byron Shire Council created the Alcohol Free Zone in the CBD of Byron Bay. The ALDI store is in the very center of this zone. Byron Bay has a well documented problem with underaged drinking.?

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 29
“In the Authority’s view any downward pressure on prices at the discount or cheaper end of the retail packaged liquor market will, as contended by Police, further enable problem drinkers (who the Authority is satisfied will be of limited means) to acquire liquor in greater quantities and greater frequencies than may otherwise be the case. “?

An ALDI licence will see a massive reduction in the real world price of the cheapest, regular price of a carton of beer or bottle of wine in Byron Bay (by 30-50%).

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 31
“The Authority accepts, as contended by the Applicant, that the Premises is not located in any currently declared AFZ. The Authority further accepts the Applicant’s contention that the location of the Premises is not one that is currently identified by Police as a place for the occurrence of public drinking.”?

Byron Bay has a significant problem with street drinking which is why Byron Shire Council created the Alcohol Free Zone in the CBD of Byron Bay. The ALDI store is in the very center of this zone. Byron Bay has a well documented problem with underaged drinking.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 31
"84. Given all that is known about Taree’s recent history of public drinking and juvenile drinking, and the very disadvantaged socio economic status of the population within Taree, the Authority is not satisfied that licensing the Premises will not draw problem drinkers seeking cheap liquor to this location. ?
85. Public drinking and public intoxication are a source of nuisance, disturbance and intimidation to the local community. The Authority is not satisfied that these problems will not become an incident of the operation of this new liquor outlet, constituting a nuisance to patrons shopping at the Aldi supermarket and others in the vicinity of the Premises"

One of the most significant areas that homeless congregate to drink in the Byron Bay CBD is Railway Park which is 30 meters from the proposed ALDI site. The Centerlink office is 30M in the other direction. Byron Bay has almost triple Taree LGA’s incidence of Disorderly Conduct (1537 vs 479 per 100,000 population)

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 32
"92. However, the Authority is satisfied that at least some of the street drinkers and/or underage drinkers in Taree will choose to source discount liquor from the Aldi store once new packaged liquor lines, particularly the lower priced lines, become available. "

One of the most significant areas that homeless congregate to drink in the Byron Bay CBD is Railway Park which is 30 meters from the proposed ALDI site. The Centerlink office is 30M in the other direction. Byron Bay has almost triple Taree LGA’s incidence of Disorderly Conduct (1537 vs 479 per 100,000 population). An ALDI licence will see a massive reduction in the real world price of the cheapest, regular price of a carton of beer or bottle of wine in Byron Bay (by 30-50%).

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 33
“a licensing decision that either worsens or contributes towards the maintenance of the current unacceptably high rates of domestic violence in the local and broader community would, in the Authority’s view, represent an adverse impact upon the local and broader community.“

It is impossible to say that a new licence in this location would not “worsen or contribute towards the maintenance of the current unacceptably high rates of domestic violence in the local and broader community” of Byron Bay with it statistics considerably worse than Taree LGA.

From - Rejected Application for packaged liquor licence – Aldi Taree - Page 34
“the Authority is nevertheless satisfied that any downward competitive pressure on the prices of discount packaged liquor available in Taree - whether temporary or confined to particular product lines - will be adverse to the extent that it enables those problem drinkers in the local and broader communities who are financially constrained to acquire cheap liquor in even greater quantities or frequencies than may otherwise be the case.” ?

An ALDI licence will see a massive reduction in the real world price of the cheapest, regular price of a carton of beer or bottle of wine in Byron Bay (by 30-50%). In a town with considerably worse statistics than Taree LGA and a lower per capita average income.

To approve this licence would be very harmful.

The ALDI application for a liquor licence in my opinion is a bad idea for Byron Bay. Aldi stores only carry a small range of the cheapest of the cheap alcohol. It is located directly under the Byron Bay Nomads backpackers, that accommodates large numbers of "financial constrained" young people, that are the most at risk from a development like this.
As a mother of teenage boys,I have serious concerns about secondary supply of alcohol to under 18’s. Local teenagers know that backpackers will buy alcohol for them as they are unaware of Australia’s liquor laws. Alcohol is the most commonly used and most damaging drug among young people. We live in a town that is saturated with alcohol. To add yet liquor licence in a town where there is already an alcohol outlet, pub and nightclub venue on every corner just seems ridiculous to me.

The ALDI supermarket is also located 25M away from Railway Park where many of Byron Bay’s homeless and people with mental and/or social issues congregate and start drinking from when the bottleshops open. How is it that ALDI will open to sell super cheap 4L casks, an hour earlier than the existing bottleshops do? The hospital and local police are already under pressure with alcohol related injuries and/or episodes.

How will ALDI’s super-fast checkout process work during schoolies when every second customer will be 18 years old +/- a year, looking to buy alcohol, especially in a store where there is no visibility to outside so that staff are alerted to secondary supply?

Byron Bay does not need another liquor outlet.

Sincerely

Liette Snow