Several IGA stores have made submissions on the draft report with similar (and sometimes identical) requests. They include:

• I Abdulla (owner Port Kennedy SUPA IGA)
• R Allen (Director and part owner, Mt Martha Supa IGA)
• Childers IGA
• IGA Cashmere
• IGA Walloon
• IGA X-Press Alexandra Hills
• IGA X-Press Kangaroo Point
• Nick's Supa IGA
• Noonans IGA Express/BP Ashgrove
• Prince supermarkets
• Slaughter T (IGA Springfield Lakes)
• Supa IGA Maryborough
• Supa IGA Pialba
• Surf Beach IGA
• Westbury's Mundingburra IGA

Concerned that small business owners don't operate on 'same playing field' as majors and that 'increasing market power and dominance of the 2 chains is putting at risk robust competition, consumer choice and retail diversity'.

• Support effects test for s 46 (misuse of market power) but original wording in s 46 to remain unchanged to capture 'anti-competitive behaviours, irrespective of whether they substantially lessen competition' such as predatory pricing, capacity and anti-competitive price discrimination.
• On state planning and zoning, disagree with principle that more floor space and more entrants = more competition because deep pocket businesses will 'crowd out family owned businesses' and reduce consumer choice.
• On access to justice, claim 'cost prohibitive for an independent supermarket or liquor store owner to file an action with the Federal Court seeking relief from anticompetitive behaviours ...' - argues for 'no cost orders' and a mandatory enforceable Supermarket and Liquor store Code of Conduct.
• Opposed to deregulation of trading hours, claiming survival of small businesses 'depends on being able to trade on those extended hours without' competition from the major chains.

Claims local supermarkets are the 'hub of the community' and claims 'market power and dominance of the 2 chains is putting at risk robust competition, consumer choice and retail diversity'.

• Support effects test for s 46 (Misuse of Market Power) but want original wording of s 46 to remain unchanged.
• On state planning and zoning, disagree with principle that more floor space and more entrants = more competition because deep pocket businesses will 'crowd out family owned businesses' and reduce consumer choice.
• On access to justice, claim 'cost prohibitive for an independent supermarket or liquor store owner to bring an action with the Federal Court seeking relief from anticompetitive behaviours ...' - argues for 'no cost orders' and a mandatory enforceable Supermarket and Liquor store Code of Conduct.

Claims competition must be on level playing field and that Coles and Woolworths have power to crush independents to the point they won't be able to compete; claims there is no 'equal' playing field. Opposed to deregulation of trading hours, claiming it could force them out of business.

Claims entry of Woolworths and Coles into Liquor and Hardware industries has produced unfairness by reducing the number of those stores owned by private individuals. Wants rules and regulations to ensure survival of small business and guarantee 'fair competition'.

"Have your say"
Concerned about a future landscape made up of big retail outlets and limited diversity. Growth of Coles and Woolworths cases independents to suffer - particular concern expressed about further deregulation of trading hours.

"Have your say"
Claims any policy that would increase market share and trading hours would be detrimental to small retail business and all independent Australian retailers. Strongly oppose changes to current legislation.

Claims its retail store is the 'hub of the community' and that the increasing 'market power and dominance of the two major chains is putting at risk real competition and consumer choice'.

• Support effects test for s 46 (Misuse of Market Power) but want original wording of s 46 to remain unchanged.
• On state planning and zoning, disagree with principle that more floor space and more entrants = more competition because chains with most capital resources will 'crowd out family owned businesses' and reduce consumer choice.
• Request current restrictions on trading hours be retained.

Concerned about deregulation of trading hours - will decrease their sales and reduce competitions as more independents shut down.

"Have your say"
Concerned that changing trading hours will negatively impact on small and medium retail businesses.

"Have your say" submission by owner and manager of IGA X-press and Pharmacy in Stafford, Brisbane
Opposes change to retail trading hours for Coles and Woolworths.

Claim survival in market dominated by Coles and Woolworths depends on:

• trading hours (concerned removing this advantage would further reduce market share and make some stores economically unviable)
• serving smaller catchments (claims Coles and Woolworths are prepared to open large stores that are 'demonstrably uneconomic with the goal or eliminating local competition' and claims this is a misuse of market power)
• supporting smaller suppliers and growers (claims they are typically local and precluded from supplying national chains and would go out of business if duopoly gains more share)
• community support (only possible where business successful)

"Have your say"
Claims being 'strangled by the big duopoly in Coles and Woolworths' - claims not a level playing field - cannot compete (no specific recommendations discussed)

"Have your say"
Opposed to deregulation of trading hours - losing exclusive trade periods will make small business financially unsustainable.

"Have your say"
Argues legislation and management needs to address the benefit to the entire process and that lower consumer prices is 'not a valid test on its own'.

Claims 'increasing market power and dominance of the two puts at risk robust competition and retail diversity'.

• Support effects test for s 46 (misuse of market power) which will protect competition and consumer choice by deterring big business from 'crowding out' and desroying small business. However, would like original wording in s 46 to remain unchanged to capture 'anti-competitive behaviours, irrespective of whether they substantially lessen competition' such as predatory pricing, capacity and anti-competitive price discrimination.
• On state planning and zoning, disagree with principle that more floor space and more entrants = more competition because deep pocket businesses will 'crowd out family owned businesses' and reduce consumer choice.
• On access to justice, claim cost of misuse of market power actions is too high - argues for 'no cost orders' and a mandatory enforceable Supermarket and Liquor store Code of Conduct.

Notes that in Townsville over last 12 years independent retailers have reduced from 11 supermarkets to six - claims this is based on:

• increase of allowable trading hours for Coles and Woolworths (and concerned further increase would further reduce prevalence of IGA outlets)
• 'Unfair practice of Land Banking and developer relationships'
• Local developers gaining interest from independents for leasing and then providing duopoly 'with the counter option to increase their original offer'
• 'Unfair trading offers through current liquor licencing restrictions'
• 'Unfair trading offers through petrol products'

Argues for a 'means test' on all proposed grocery retail developments and their effects on competitors and wider shopping community - also suggests establishment of 'a store per capita'. Argues for amendment to liquor licencing legislation to allow independents to apply for a liquor licence.