Message. Submission to the Gaming Machine Arrangements Review
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- Brendan Joseph
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1 Message From: To: Cc: Sent: Received: Subject: campaigns olgr.gmar jane.garrett 26/02/2016 at 2:44 PM 26/02/2016 at 2:44 PM Submission to the Gaming Machine Arrangements Review A SUBMISSION To the VICTORIAN GOVERNMENT GAMING MACHINE ARRANGEMENTS REVIEW from GEELONG INTERCHURCH SOCIAL JUSTICE NETWORK 1 Introduction The Geelong Interchurch Social Justice Network welcomes the opportunity afforded it by this Review to make a submission on the Victorian Government s current gaming arrangements in general and on the application to the Victorian Commission for Gambling and Liquor Regulation (VCGLR) for the transfer of 29 EGMs from the Barwon Heads Hotel to the Valley Inn, South Geelong. Since this submission reflects our committee s current policy on gambling, it will be helpful to commence with an outline of certain elements of that policy. 2 Definitions Gambling: `a game in which a risk of losing a present finite good is accepted in the hope of obtaining a future greater good' (Catholic Encyclopedia). `the staking of something of value, usually money, on some fact or the outcome of some event, the determination of which is due solely to chance or contingency not predictable with certainty'; includes gaming, betting and lotteries. (New Catholic Encyclopedia). 3 Teaching of church 1. Gambling is not sinful if it serves such genuine recreational purposes of freeing people from an excessive attachment to wealth, providing opportunities for mixing socially with others. 2. Such acts are, however, sinful if - the gambling contract is between unequal parties - it involves fraud or cheating or disproportion between risk and possible gain - the money spent does not prevent the gambler from performing other duties in justice or charity - the gambler does not have the right to
2 gamble with this money because it is needed for the fulfilment of other duties eg. for the support of family - one party to a gambling contract knows the other party has no right to gamble with money wagered - it involves real risk of becoming addictive - it raises the pursuit of riches to the status of an idol. 4 Current concerns In recent years the nature and place of gambling in the Victorian community has changed dramatically. To the existing profusion of various forms of gambling (TAB, on-course bookmaking, lotteries, raffles etc) has been added so called Casino gambling and poker machines. The nature of the gambling associated with these two forms has been called by the Catholic bishops of Victoria `pressure gambling' (1983). The introduction of these two forms of gambling has assigned to gambling a place in our cultural life that is out of all proportion to its previous place. Gambling has been transformed from a largely recreational activity to a major industry and source of government revenue in this State. Moreover, it has been promoted with government sanction through paid advertising as a glamorous recreation and a reliable way of winning money. This committee believes that the Victorian government by the introduction of Casino gambling and poker machines has conferred on gambling a status in our way of life which far exceeds its real value. We believe that the extent and forms of gambling in Victoria should generally be limited to what is necessary to fulfil its recreational purpose. This committee believes that the Victorian government presently places excessive reliance upon gambling as a source of government revenue. Government revenue ought to be raised by measures which exact taxes from citizens according to their individual ability to pay. `Pressure' gambling especially extracts from one section of the community contributions which are beyond their capacity to pay. Such gambling functions, in other words, as a hidden tax on the more vulnerable members of our community. Taxation of this deceptive kind we condemn as cynical and exploitative. This committee believes that the Victorian government presently confers an unwarranted role on gambling in the State's economy. When EGMs were first legalised, and the Casino first licensed, in Victoria this policy decision was defended on the ground that the gambling industry would deliver significant benefits to the State. The following is the assessment of this argument from no less an authority than the Productivity Commission: Typically, these [benefits] had been seen as deriving primarily from the jobs and income associated with the industry. The Commission showed that this was a furphy. Unleashing a previously constrained industry like gambling does not in practice create many new jobs. What it does do is enable people to spend more on gambling and less on other things. (The vocal complaints of retailers whenever new gambling operations set up in their vicinity bear testimony to this at work.) But that also means that the jobs and income created in the gambling industry have a counterpart in jobs and income destroyed in other parts of the economy. Except in depressed areas where unemployment is very high, the gambling industry s new jobs will be some other industry s existing jobs (Banks 2002, p. 5). The economic defence of the huge expansion of this industry does not hold water. This committee believes that by promoting the casino culture the Victorian government encourages recreational organisations to become excessively reliant
3 for fundraising upon poker machines. We regard this policy as particularly pernicious because this `pressure' form of gambling inevitably extracts a disproportionate amount of the total revenue raised from the more vulnerable, and indeed seduces large numbers of other players to spend more than they can afford. This committee believes that the location of poker machine centres in poorer communities is particularly cynical. The `liberal' defence of this policy - that individual adults are all free to decide whether or not to gamble - is undermined by the policy itself: if all were equally free, the greatest potential rewards for marketers would lie in the wealthier suburbs! The location of the large majority of the machines in the poorer suburbs betrays the belief that the poor are more likely than the better off to surrender to the attraction of opportunities to get rich quick. This committee believes that the Victorian government shirks its duty to work for the common good and look after the welfare of all its citizens by effectively denying that any but an addiction-prone minority are adversely affected by gambling. We compare the temptation to gamble to excess to the temptation to drink and drive. One does not need to be an alcoholic to be tempted to drink and drive. Neither does one need to be a gambling addict to be vulnerable to the temptation to gamble to excess. The submission on caps which follows is based on this policy. 5 Submission on the effect and future of regional caps We acknowledge the efforts successive Victorian Government to address the problems related to gambling with the policy of regional caps. However, we believe that the effect of this policy is merely to drive owners of such machines to continually seek out the more vulnerable communities within a region as locations for their machines. This effect, we submit is clear in the current application for the transfer of 29 EGMs from the Barwon Heads Hotel to the Valley Inn in South Geelong. In future, we submit that 5.1 the numbers of machines in the State in general and in Geelong in particular should be drastically reduced because the pokies industry is a hazardous industry : governments classify some industries in law as hazardous because of the particular dangers they pose to the community. Chemical industries are one example of industries posing such special dangers to the community that they have special conditions imposed on them for the protection of the community. These hazards are physical hazards. We are asserting that the gambling industry poses social and health hazards. Professor Linda Hancock, former chair of the Victorian Government s Gambling Research Panel, argues that gambling is a health hazard and that the issue is thus to determine a sustainable level. She quotes Kickbusch to this effect: We need to move from the classic approach to regulating industries that produce ill-health to creating products and services that create health (Kickbusch 2004, p. 7). 5.2 public policy concerning a hazardous industry must, because the industry is hazardous, have as its first priority the protection of the good of the community at large, not, as seems to be the case at present, the balancing of interests of consumers, presumed to be rational choosers, and industry 5.3 this means that the government cannot simply define its role as a steerer of gaming policy, leaving the rowing to the market mediated by a regulator 5.4 nor can the government regard taxes from the industry as a legitimate source of revenue like any other source
4 5.5 government must instead recognise that because the industry is hazardous it has a duty to uphold the public good by protecting the vulnerable from its hazards, and not to depend for a significant proportion of its own revenues upon the losses of its most vulnerable citizens 5.6 government must not evade its responsibility by defining the policy problem in terms of individual pathologies: excesses in gambling can happen to non-addicted citizens just surely as excesses in drinking can affect non-addicted drinkers e.g. drink-driving. 5.7 since the present regional caps policy is ineffective in reducing exposure of citizens to the hazards of the pokies, caps must be further reduced across the State until that exposure is sufficiently reduced: 5.8 the extent of this reduction must be sufficient to restore gambling to the status of a recreational pursuit rather than that of a major industry. It is its present status as a major industry that is the cause of the social and health problems that we now confront. 5.9 we recommend that the present total cap for the State of 27, 500 EGMs be progressively reduced over a period of 3 years to 17, 500. The impact of these reductions on overall gambling losses and particularly of problem gamblers losses should be monitored by truly independent research We recommend that spin rates on all machines be reduced to drastically limit possible losses per hour on every machine if independent research shows that these caps have not reduced significantly gamblers losses, and thus have not restored gambling to the status of a recreational pursuit, we submit that further cuts should be imposed until those ends are achieved individual freedom justifies the permission of gambling to those who wish provided that this permission does not do harm to others. The fact that 43 cents in every dollar still comes from problem gamblers shows that immense harm flows from this permission. Curtailment of that permission by the government in the name of the rest of the community is not only justified but also required in these circumstances. The hazardous nature of this industry does not permit the government to hide behind a regulator whose task is simply to balance so called competing interests. The government must rather stand up and protect the public interest in safeguarding its citizens from a hazardous industry. Conclusion We submit that the application for transfer of 29 EGMs from the Barwon Heads Hotel to the Valley Inn in Fyans Street, South Geelong is a case of machine proprietors seeking out more vulnerable communities as targets for their business. For this reason, the relevant authorities ought to reject this application in virtue of their duty to protect good of the community as whole, and above all, the good of its most vulnerable members. (Dr.) Michael Leahy For and on behalf of The Geelong Interchurch Social Justice Network 26 February, 2016 Banks, Gary (2002). The Productivity Commission's Gambling Inquiry: 3 years on. 12th Annual Conference of the National Association for Gambling Studies, Melbourne, Vic., Productivity Commission, Canberra. Kickbusch, I. (2004), Health and Citizenship: the characteristics of 21st Century Health, IAPO Reception, Geneva. Studies, South Australian Centre for Economic (2005), Study of the Impact of Caps on Electronic Gaming Machines, Adelaide and Flinders Universities, Adelaide.
5 Yours sincerely, Michael Leahy Victoria 3226, Australia This was sent via do^gooder, a campaign platform that enables people to contact you regarding issues they care about. The FROM field of this is campaigns@good. s sent by Michael Leahy who provided this address: In accordance with web protocol FC 3834 ( ) we have included this address in the REPLY-TO field and you should respond to Michael Leahy at that address. To learn more about do^gooder visit
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