Gambling Discussion Paper
Contact: Malcolm Roberts-Palmer
Social Planning and Research Officer
malcolm.roberts-palmer@maribyrnong.vic.gov.au
Maribyrnong City Council
Table of Contents
Introduction...........................................................................................................3
Executive Summary................................................................................................4
1. Gambling in Victoria ...........................................................................................5
1.1 Background .......................................................................................................................5
1.2 Wagering (Racing, and Sports Betting) .............................................................................6
1.3 Lotteries ............................................................................................................................7
1.4 Online Gambling ...............................................................................................................7
1.5 Electronic Gaming Machines ............................................................................................8
2. Gambling in Maribyrnong ................................................................................. 12
2.1 Background .................................................................................................................... 12
2.2 History of losses and numbers of EGMs ........................................................................ 12
2.3 EGM numbers and losses per adult in Maribyrnong ..................................................... 13
2.4 Losses and number of EGMs in venues in Maribyrnong for 2010-11 ........................... 15
2.5 Auction of Maribyrnong EGM licences .......................................................................... 15
2.6 Changes to EGM Caps.................................................................................................... 16
2.7 Edgewater Case ............................................................................................................. 17
3. Braybrook Case Study ...................................................................................... 19
3.1 EGM usage and losses in Braybrook.............................................................................. 19
3.2 SEIFA Index rating .......................................................................................................... 20
3.3 Income ........................................................................................................................... 21
3.4 Housing and car ownership ........................................................................................... 22
3.5 Food Security ................................................................................................................. 23
3.6 Qualifications and occupations ..................................................................................... 23
3.7 Alcohol dependency ...................................................................................................... 24
3.8 Conclusion ..................................................................................................................... 24
4. Options for Managing Electronic Gaming Machines in Maribyrnong ................. 26
4.1 Planning Scheme amendment....................................................................................... 26
4.1 Advocacy........................................................................................................................ 27
4.2 Research ........................................................................................................................ 27
Appendix 1: Regulation of Electronic Gaming Machines in Victoria ....................... 28
Background .......................................................................................................................... 28
Caps on Machine Numbers in Victoria ................................................................................ 29
Community Benefit Statements .......................................................................................... 30
Code of conduct and self exclusion program ...................................................................... 30
Changes to the regulation of Electronic Gaming Machines in Victoria ............................... 30
Appendix 2: Problem gambling in Australia .......................................................... 32
Background .......................................................................................................................... 32
Reasons for problem gambling............................................................................................ 32
Impacts of Problem Gambling ............................................................................................. 35
Government Action on Problem Gambling ......................................................................... 36
Conclusion ........................................................................................................................... 38
Appendix 3: Other Victorian Councils’ Gambling Policies ...................................... 39
Background .......................................................................................................................... 39
Greater Geelong City Council .............................................................................................. 39
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Yarra Ranges Shire Council .................................................................................................. 41
Macedon Ranges Shire Council ........................................................................................... 43
Hume City Council ............................................................................................................... 44
City of Maroondah............................................................................................................... 45
City of Greater Bendigo ....................................................................................................... 46
Moreland City Council ......................................................................................................... 47
Darebin City Council ............................................................................................................ 48
Reference List ...................................................................................................... 49
End Notes ............................................................................................................ 51
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Introduction
The purpose of this discussion paper is to form the basis for the development of a
new a Maribyrnong City Council Gambling Policy.
The paper considers all forms of gambling with particular focus on electronic gaming
machines because they account for a high level of losses in Victoria and have an
ongoing impact on the community, particularly in areas of social and economic
disadvantage.
This paper has a specific focus on the impact of electronic gaming machines in
Maribyrnong and the suburb of Braybrook, which has a high level of social and
economic disadvantage and a high level of losses from gaming machines.
The paper also considers options for the management of EGMs in Maribyrnong
which will form part of the new Gambling Policy.
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Executive Summary
This Executive Summary outlines the key findings contained in each section of this
discussion paper.
1. Gambling in Victoria
 Gambling in Victoria consists of electronic gaming machines (EGMs), the
Crown Casino, Wagering (Racing and Sports Betting), Lotteries and Club Keno.
 EGMs accounted for the highest proportion of losses (51%) and the highest
proportion of taxation revenue in Victoria (57%) in 2009-2010.
2. Gambling in Maribyrnong
 As with the rest of Victoria, EGMs have a significant impact on the
Maribyrnong community.
 Over the last six years Maribyrnong’s total average losses from EGMs have
been $58 million.
 Maribyrnong has twice the level losses per adult compared to number of
licensed EGMs.
 The Edgewater ruling by VCAT will see the placement of 70 existing EGMs at
the Edgewater club site in Maribyrnong.
3. Braybrook Case Study
Braybrook is rated as the following:
 The highest level of losses from EGMs in Maribyrnong. However, it does not
have as many EGMs as other suburbs in Maribyrnong.
 The highest level of losses from EGMs per adult in Maribyrnong.
 Is rated second in Victoria on the SEIFA index of social disadvantage.
 Has the highest level of dependency on income support and the lowest
median income in Maribyrnong.
 Has the highest number of people renting from a government authority and
the highest level of people in rental stress in Maribyrnong.
 This suggests that problem and at risk gamblers in Braybrook are under
significant income and food security stress.
4. Options for managing Electronic Gaming Machines in Maribyrnong
This section outlines the options that can be considered for managing EGMs in
Maribyrnong. The options include:
 Develop a planning scheme amendment for applications for EGMs in new and
existing venues.
 Develop a social impact assessment framework for EGMs with other western
region Councils.
 Continue to lobby the Commonwealth and Victorian Government for
improvements to the management of EGM gambling.
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1. Gambling in Victoria
1.1 Background
Gambling in Victoria consists of electronic gaming machines, the Crown Casino,
Wagering (Racing and Sports Betting), Lotteries and Club Keno.
(Source: Appendix 15, VCGR Annual Report 2009-10)
EGMs outside the Crown Casino accounted for 51% of gambling losses in Victoria in
2009-10. Crown Casino represents 26% of losses. This is based on losses for table
games and EGMs. Crown Casino has 2500 EGMs and 350 table games. Figures are
not available for the breakdown of losses from Crown. Lotteries account for 9% of
total losses. Wagering which includes race track betting and TAB, accounted for 15%
of total losses.
Club Keno accounts for 0.1% of total losses. Club Keno is a game where a player
wagers that chosen numbers will match any of the 20 numbers randomly selected
from a group of 80 numbers via a computer system or a ball drawing device. It is an
electronic form of bingo and is typically played in a clubs, casinos and hotels.
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(Source: Appendix 15, VCGR Annual Report 2009-10)
As with gambling losses in Victoria, the taxation revenue raised from gambling in
Victoria shows that EGMs make up a large proportion of revenue raised. EGMs
account for 57% of gambling taxation revenue in Victoria.
1.2 Wagering (Racing, and Sports Betting)
Wagering in Victoria consists of the following:

On-course bookmakers – licensed by the Victorian Commission for Gambling
Regulation. Bookmakers offer fixed odds and provide wagering products such
as win and place bets.

Corporate bookmakers – Fully incorporated bookmakers who operate over
the telephone and internet, and are often listed companies or subsidiaries of
listed companies.

Totalisators – operated by TABs, totalisators do not offer fixed odds bets. All
bets are placed in a pool, with the winning bets sharing the pool (minus a
percentage take by the operator).

TABs – refers to the bodies that are exclusively licensed to operate
totalisators and to offer off-course retail watering services. TABs in Victoria
also offer sports betting and fixed odds betting on races.

Betting Exchanges – similar to a stock exchange, a betting exchange is a
market placer for punters to trade wagers at different prices and quantities. A
betting exchanges matches punters who are seeking to bet that a particular
outcome will occur.1
The regulation of wagering is undertaken by the Victorian Commission for Gambling
and Racing. Increasingly, Victorian clubs and pubs are seeing the combination of
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EGM gambling with sports betting, which further encourages gambling in these
venues. This increases the atmosphere of gambling in the venue.
1.3 Lotteries
Since July 2008, there are two public lottery licences operating in Victoria, Tattersalls
Sweeps Pty Ltd and Intralot Australia Pty Ltd.

Tattersall’s Sweeps are responsible for Tattslotto, Super 7s Oz Lotto,
Powerball, Super 66, The Pools and Monday, and Wednesday Lotto.

Intralot Australia are responsible for Keno 10/20/70 (Lucky Keno), Pick 5
Heads or Tails, Cross and Match (Lucky Lines), TV Bingo (Lucky Bingo Star),
Pick 3, Instant Lottery Games (Lucky Tix) and Instant Scratchies.2
As with wagering, lotteries are regulated by the VCGR.
1.4 Online Gambling
Online gambling includes the following:

Online wagering - consisting of racing and sports betting

Online gaming - poker, blackjack, baccarat, roulette and virtual EGMs

Lotteries – such as Tattslotto, Ozlotto and Keno3
The physical distinction between different types of gambling disappears in the online
environment. Generally, online gambling involves small but high frequency wagers
similar to venue-based EGMs.4 As with EGMs, this potentially could make online
gambling a highly addictive form of gambling in the future. The other issue of
concern is the use of credit cards for online gambling. This could lead to players
losing track of the amount they have spend, leading to greater losses.
In 2009-2010, online poker accounted for $249 million and online casinos accounted
for $541 million in gambling losses in Australia.5 Statistics are not currently available
for the level of online gambling in Victoria. However, there has been a significant
increase in online gambling advertising, particularly during major sporting events
such as the 2010 AFL Grand Final.
Online Gambling is regulated by the Commonwealth Government through the
Interactive Gambling Act 2001 (IGA). The IGA prohibits the provision of online
gambling services to customers in Australia. However, it does not prohibit access to
online services. In effect, this means that online gambling can still be provided by
overseas companies. Gambling services prohibited under the IGA include:

Online casino games including roulette, blackjack and all forms of online
poker;

Online versions of EGM games; and

Online bingo6
As a result of the ban, online gambling is only subject to overseas taxation. The IGA
does not include a ban online wagering such as TAB Sportsbet.
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The Productivity Commission Inquiry report into online gambling recommended
lifting the ban on the provision of online gambling services in Australia. One of the
main reasons for this recommendation is that it could divert consumers away from
unsafe sites to ones that meet Australian consumer safety standards. However,
lifting the ban could lead to a significant increase in participation in online gambling
in the future. 7
National Broadband Network
The National Broadband Network (NBN) will provide fibre to the premises network
connection for 93% of Australian households. The NBN will allow for download
speeds of up to 1 gigabits per second, which represents a significant increase on
current internet download speeds.8
The development of the NBN could see a significant increase in all forms of online
gambling. The higher download limits will increase the opportunities for longer
playing times and increased losses, particularly by problem gamblers. It is also likely
to impact other sections of the community who are faced with financial or personal
stress, such as mortgage or rental stress.
1.5 Electronic Gaming Machines
Number of EGMs and losses in Victoria
Electronic Gaming Machines (EGMs) have been operating in Victoria since 1991.
Electronic Gaming Machines (EGMs) have been operating in Victoria since 1991.
As of 30 June 2011:

There are 26,778 EGMs in Victoria with total losses of over $2.6 billion for
2010-2011.

The average number of EGMs per 1000 adults was 6.19

The average net losses per adult were $613 and the average losses per
hour were $13

The average number of adults per venue is 8,460
Since 2000, losses from Victorian EGMs have increased by over $4.8 billion.
However, in the same period the number of EGMs operating in Victoria has
decreased by 630. The level of EGMs per adult has also fallen from 7.76 to 6.19 per
1000 adults.9
Comparison with other States and Territories
In comparison with other States and Territories, Victoria has the second highest level
of losses on EGMs after New South Wales.
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(Source: Productivity Commission Gambling Inquiry report p 2.18 Table 2.7. Data includes losses for
casinos)
Despite the high level of losses, Victoria has less EGMs than Queensland, which does
not have a cap. This suggests that there is a higher concentration of losses from
EGMs in Victoria than in Queensland.
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(Source: Productivity Commission Gambling Inquiry report Table 2.11 p 2.26 and VCGR 2011)
Regulation of EGMs in Victoria
The VCGR regulates EGM gambling in Victoria. The Gambling Regulation Act 2003
provides the legislative framework for gambling in Victoria. The Act stipulates that a
maximum of 30,000 EGMs may operate in Victoria. This includes 2,500 in Melbourne
Casino and 26,778 EGMs in clubs and hotels in Victoria. The Act also states that at
least 20% of machines must be situated outside Melbourne and that a maximum of
105 may be permitted within a single venue.
EGM gambling in Victoria is also subject to Local Government regulation. The
Victorian Government introduced amendments to the Victorian Planning Provisions
in 2006 in response to its commitment to improve the input of local councils into the
location of EGMs. A planning permit is now required for all EGMs, replacing the
previous as-of-right provisions for gaming machines if the area covered by the EGMs
was less than 25% of the gross floor area where liquor may be consumed. EGMs
remain prohibited in strip shopping centres (the definition of which may be
contested, as in the Edgewater case) and specified shopping centres with the
exemption for hotels in clubs in strip shopping centres being removed. Further
information on the regulation of EGMs in Victoria is provided in Appendix 1.
EGM losses - Regulation of Player returns
The Gambling Regulation Act 2003 stipulates that the holder of an EGM licence must
ensure that the pay-out table on gaming machines at each venue is set to a
minimum of 87% return to the player of the total amounts wagered each year at that
venue, after deduction of the sum of jackpot special prizes determined as prescribed
and payable during that year.10
In effect what this means is that if a player bets $100 in a year on an EGM they
would receive $87 in return. In practice, it is more likely that the money spent during
an EGM player’s session will be lost, increasing the overall losses incurred by a player
each year.
The legislated level of return from EGMs each year does not take account of EGM
design and the habits of EGM gamblers and the losses incurred at each session of
play. EGMs have the capacity for rapid repetition of games. The rapid repetition
allows for players to continuously place bets on the machines each session, which
are often small bets of a dollar or less.
The Productivity Commission Inquiry Report on Gambling found the level of return
from EGMs is significantly reduced the longer a player is using a machine. Based on
10,000 simulations of an actual EGM games with over a 90% rate of return and with
free features, moving from 1 hour to 16 hours of play reduces the group of people
winning from 30% to 7%.
The report further states that, based on the simulations, the average rate of return
is per hour is $646 per session. This is based on a simulation of one hour of play, for
a 1 cent machine and 5 seconds per paid button push. The average loss increases
with the number of sessions played. For example, 4 sessions incurs an average loss of
$2584 and 16 sessions incurs an average loss of $10,336.11
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This is particularly the case for EGM problem gamblers who are more likely to
continue to play machines in the hope of making a big win and then can lose all or
most of the money they put into the machines in an individual session. However,
they may have some wins during the course of a year, which will encourage them to
gamble more. EGMs are also designed to allow small bets leading problem gamblers
to believe that they are not losing money.
EGM problem gamblers can develop a sense of dislocation, as though they are not
connected to reality. Problem gamblers are also more likely to play EGMs to escape
or tune out from a variety of personal problems. Around 85% of problem gamblers
identified in the 2003 Victorian prevalence survey spend most of their money on
EGMs and 80% for severe problem gamblers.12 Information on the reasons for and
the impact of problem gambling can be found in Appendix 2.
The analysis by the Productivity Commission on the potential rate of return to EGM
players is the reason why this paper refers to EGM ‘losses’ rather than ‘expenditure’,
which is the term used by the Victorian Department of Justice and the VCGR, which
is responsible for the regulation of EGM gambling in Victoria. Based on the evidence
of EGM players experience the term ‘losses’ is a more accurate reflection of the rate
of return for EGM players.
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2. Gambling in Maribyrnong
2.1 Background
As with other municipalities in Victoria, Maribyrnong has access to all forms of
gambling. Statistics are not available for the level of losses from wagering, lotteries
and online gambling in Maribyrnong. However, it is likely that the breakdown of
losses from different forms of gambling in Victoria is similar in Maribyrnong. This
section analyses the level of losses and the number of EGMs in Maribyrnong
compared with other municipalities in the Melbourne region. It also considers the
impact of the deregulation of the EGM market on Maribyrnong.
2.2 History of losses and numbers of EGMs
Since the introduction of EGMs in 1991, Maribyrnong has seen a steady increase in
losses from EGMs from $13 million in 1992-93 to $64 million in 2001-02. Since 200203 the losses have remained steady between $59 million and $56 million.
(Source: City of Greater Dandenong 2010. Not adjusted for inflation)
Over the same period the number of EGMs has increased from 368 in 1992-93 to 463
in 2009-10 under the Victorian cap for EGMs. The following graph demonstrates that
the increase and decrease in EGM numbers in Maribyrnong is more dramatic than
the level of losses in the municipality.
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(Source: City of Greater Dandenong 2010)
Currently, there are 439 EGMs operating in Maribyrnong. However, Maribyrnong is
permitted to have up to 511 EGMs under the regional EGM cap established by the
Victorian Government. It is anticipated that the remaining machines will be
operating once the new Edgewater development is completed and the ownership of
EGM licences becomes clearer following their auction in May 2010.
2.3 EGM numbers and losses per adult in Maribyrnong
Although Maribyrnong’s overall losses from EGMs are not as high as other
municipalities, it does have high ratio of EGMs per 1000 adults. In 2010-11, the
number ratio of 1000 adults per EGM in Maribyrnong is 7.64 which is the eighth
highest ratio in Victoria. The highest ratio is the City of Maroondah which as a ratio
of 9.32 EGMs per adult.13
Maribyrnong also has the third highest losses per adult with $985 for 2010-11
compared to Greater Dandenong which is $1,110 and Brimbank which is $1,004.
However, unlike Dandenong, Maribyrnong has nearly twice the losses per adult
compared to the number of licensed EGMs.14
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Number of EGMs and losses per adult by municipality in
Melbourne 2009
0
100
200
300
400
500
600
700
800
900 1000 1100
Banyule
Bayside
Boroondara
Brimbank
Cardinia
Casey
Darebin
Frankston
Glen Eira
Greater Dandenong
Hobsons Bay
Hume
Kingston
Knox
Manningham
Maribyrnong
Maroondah
Melbourne
Melton
Monash
Moonee Valley
Moreland
Mornington Peninsula
Nillumbik
Port Phillip
Stonnington
Whitehorse
Whittlesea
Wyndham
Yarra
Yarra Ranges
Number of EGMs
Net losses per adult
(Source: VCGR 2010)
This graph suggests that the cap on EGMs in Maribyrnong is not reducing the impact
of losses on the Maribyrnong population, particularly in areas of lower socio
economic background such as Braybrook and Maidstone.
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2.4 Losses and number of EGMs in venues in Maribyrnong for 2010-11
The losses and number of EGMs for each venue for 2010-11 in Maribyrnong are as
follows:
Venue
Anglers Tavern
(closed)
Ashley Hotel
Australian
Croation
Association
Braybrook
Taverner
Club Leeds
Court House
Hotel
Highpoint
Taverner
Powell Hotel
Victoria on Hyde
Hotel
YarravilleFootscray
Bowling Club
Yarraville Club
Yarraville Cricket
Club
Suburb
Maribyrnong
Operator
Tabcorp
EGM No.
0
Losses $
568,427.12
Braybrook
Footscray
Tabcorp
Tabcorp
50
0
11,741,843.22
0
Braybrook
Tattersalls
31
4,878,738.39
Footscray
Footscray
Tattersalls
Tattersalls
30
21
3,656,480.10
3,513,902.33
Maribyrnong
Tabcorp
70
8,370,154.18
Footscray
Yarraville
Tattersalls
Tabcorp
30
24
4,312,194.33
2,647640.51
Yarraville
Tabcorp
29
1,973,936.76
Yarraville
Maidstone
Tattersalls
Tabcorp
78
76
4,094,391.91
10,872,723.04
(Source: VCGR 2011)
The Ashley hotel in Braybrook is the venue with the highest level of losses for 201011 with over $11.7 million, followed by the Yarraville Cricket Club in Maidstone with
over $10.8 million. Overall, Braybrook is has over $16.6 million in EGM losses which
make it the suburb with the highest level of losses from EGMs in Maribyrnong.15
2.5 Auction of Maribyrnong EGM licences
The introduction of the Gambling Regulation Amendment (Licensing) Act 2009 has
lead to the auction of EGM licences in May 2010. This auction has involved the
change in ownership of EGM licences in Maribyrnong, with licences being purchased
by the owners of pubs and clubs in the municipality.
It is uncertain how the ownership of EGM licenses will change in the future and the
impact this will have on the concentration of EGMs and the number of venues in
Maribyrnong. The new ownership system will operate from 2012.
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It is not clear what impact the changes to the ownership of EGM licences will have on
the number of EGMs in different venues. This could potentially see new venues that
do not have EGMs buying entitlements or new venues to be established.
The following table outlines the changes to EGM licence ownership as a result of the
May 2010 auction.
Operator
Venue and Location
Licenses
purchased
Australian
Leisure and
Hospitality
30
50
0
21
0
Bakers Arms
Hotel Pty Ltd
Dominion Hotel
Group
Footscray
Football Club
Footscray
Football Club
Powell Hotel –
Footscray
Ashely Hotel Braybrook
Court House Hotel Footscray
Unclear where these
will be located
Victoria on Hyde –
Yarraville
Club Leeds Footscray
Footscray Football
Club - Footscray
Change in Comments
no. of
EGM
licences
0
31
+31
25
+1
55
+25
40
-8
Moonee Valley
Hospitality
Taverner Hotel
Group
Anglers Tavern Maribyrnong
Braybrook Taverner
- Braybrook
0
-24
52
-49
29
0
78
0
100
+24
Highpoint Taverner Maribyrnong
YarravilleFootscray
Bowling Club
Yarraville Club
Inc
Yarraville
Cricket Club Inc
Yarraville- Footscray
Bowling Club – Inc
Yarraville
Yarraville Club Yarraville
Yarraville Cricket Club
– Maidstone
New to the
municipality
Bulldogs gained
17 machines
overall, but
must lose 11 to
meet VCAT
requirement
No longer own
EGM licenses
Lost 49
machines over
both venues.
Not clear how
EGMs will be
distributed
2.6 Changes to EGM Caps
Another factor that may influence the movement of licences in the deregulated
market, is potential for changes to the EGM cap in the municipality. The Victorian
Government introduced caps on the number of EGMs that can be contained in local
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areas in 2001, which were reviewed in 2006. There are currently caps on the number
of EGMs in 19 regions which are set at 10 EGMs per 1000 people or at the gaming
machine density in the region at the date the cap was imposed, whichever is lower.
Council is concerned that the current number of EGM licences, determined by the
limit of 10 EGM’s per 1000 adults in capped regions, may not take account of future
population growth. The current ratio for EGMs per 1000 adults in Maribyrnong is
8.13, which is below the maximum allowed under the cap.
Maribyrnong will experience significant population growth over the next 10 years,
with our population predicted to increase by over 19,700 people by 2021. Council
wrote to the then Minister for Gaming in November 2010, expressing our concerns
about this issue. The Acting Director of Gaming and Racing in the Department of
Justice, Cate Carr, responded to Council’s correspondence, on behalf of the Minister.
The Director stated that under section 3.2.4A of the Gambling Regulation Act 2003
the VCGR can at its discretion review its determination and alter the maximum
number of EGMs permitted in a region if the current number is no longer
appropriate.
In effect, the deregulated market could lead to EGM licence holders applying to the
VCGR to increase the number of EGMs at their venue, in order to compete
effectively with other licence holders in the municipality. It could also lead to an
increase in the number of EGMs in the municipality and the development of new
EGM venues.
In addition to this, the Gambling Regulation Act 2003 requires the VCGR to review an
EGM cap every five years. If the VCGR decides to modify the cap after the review its
determination it is then published in the Victorian Government Gazette.
Maribyrnong’s EGM cap was established in 2006 and will be reviewed by the VCGR
this year.
2.7 Edgewater Case
In 2008, the Bulldogs Football Club, in partnership with Prizac Investments and
George Adams, put forward a planning proposal to Maribyrnong City Council for the
Edgewater Club. The club is to be located on the Edgewater Estate site in
Maribyrnong, which includes 1000 dwellings. The club will consist of a four storey
building containing a function centre, residential hotel, bistro/café 296 car spaces
and gambling facilities.
As part of the proposal the Bulldogs put forward an application have 70 EGMs
installed. This would be achieved by relocating 81 machines from existing clubs and
permanently removing 11 machines from the Maribyrnong area.
Maribyrnong City Council refused to grant a planning application based on concerns
over the number of EGMs that would located on the site and the impact that this
would have on the local community. The Bulldogs and their partners in the project
then lodged an appeal against council’s ruling in the Victorian Civil Administrative
Tribunal (VCAT).
In the VCAT hearing, Maribyrnong City Council argued that the planning proposal
should not be approved on the grounds that Maribyrnong City has high levels of
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disadvantage and high level of losses from EGMs. The Council further argued that it
was inappropriate to locate the proposal in an activity centre because of the
intensity of uses which breaches the Maribyrnong planning scheme and it have
amenity, traffic and noise impacts.
The VCAT hearing also heard evidence from other sources supporting Maribyrnong’s
position including:

local residents opposed to the development;

planning consultants who specialise in land use management issues;

Metropolis consulting which conducts Maribyrnong’s Annual Community
Survey; and

Dr Charles Livingstone who specialises in problem gambling research at
Monash University.
VCAT ruled that the conditional use of an EGM licence and planning permit for the
Edgewater Club was allowed to proceed because it was in compliance with the
direction made by the Minister for Gaming.
VCAT also ruled that the Maribyrnong Planning Scheme did not indicate what would
constitute an appropriate location for gaming machines and that the Council’s
existing Responsible Gambling Policy had not been incorporated into the planning
scheme.
In addition, VCAT stated that the location of EGMs in a club rather than a hotel may
not encourage easy access to the machines, nor is the venue located in a shopping
strip, although there are shops near by.16
As part of its ruling, VCAT imposed conditions on the proposal which include:

The permit is to be used for a licensed club not a hotel.

The gaming area can only operate between 11 am and 1 am.

The supply of alcohol to members for consumption off the premises must
cease at 11pm on any day.

Patron numbers are limited to 650.

An EGM relocation plan must be submitted and approved by Council.

A patron and access management plan for the gaming area need to be
submitted to and approved by Council.

Smoking management plan must be submitted and approved by Council.17
Following legal advice, Maribyrnong City Council decided against a Supreme Court
challenge to the VCAT decision.18
The Edgewater case has the potential to set a precedent for future development of
venues containing EGMs in Maribyrnong, particularly considering the level of
development that will occur as the population of the municipality increases.
Gambling Discussion Paper
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Maribyrnong City Council
3. Braybrook Case Study
Braybrook consistently has a higher level of disadvantage than any other suburb in
Maribyrnong. It also has the highest level of losses on EGMs in Maribyrnong.
This case study will consider the impact of EGMs in Braybrook and what factors
associated with social disadvantage and qualifications may contribute to these
losses.
3.1 EGM usage and losses in Braybrook
Yarraville has the highest number of EGMs with 131, compared to Braybrook and
Maidstone which have 81 and 76 respectively.
Number of EGMs in Maribyrnong by suburb
140
120
131
100
80
94
81
81
60
76
40
20
0
Braybrook
Footscray
Maidstone
Maribyrnong
Yarraville
(Source: VCGR 2010)
Analysis of the losses from EGMs by postcode in Maribyrnong indicates that
Braybrook has significantly higher losses per adult than other suburbs. Despite the
fact that Yarraville has the highest number of EGMs it has the lowest level of losses
from EGMs per adult.19
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Maribyrnong City Council
Losses on EGMs per adult in Maribyrnong 2008-2009
1600
1,522.78
1400
1200
1042.74
1000
900.69
800
649
586.31
600
481.9
421.88
400
200
0
B
ok
ro
b
y
ra
ay
cr
s
t
oo
F
M
ne
to
s
d
ai
M
i
ar
ng
no
r
by
le
vil
rr a
Ya
M
i
ar
ng
no
r
by
ty
Ci
M
ne
ur
o
b
el
(Source: VCGR 2010)
Overall, Maribyrnong has average losses per adult of 1042.74 compared to the
metropolitan Melbourne which has average losses of $649 per adult.20
Braybrook has the venue with the highest level of losses in Maribyrnong, The Ashley
hotel in Braybrook had over $11.6 million of losses for 2010-11.21
3.2 SEIFA Index rating
The Relative Index of Social Disadvantage (SEIFA) is derived from attributes such as
low income, low educational attainment, high unemployment, jobs in relatively
unskilled occupations and variables that reflect disadvantage rather than measure
specific aspects of disadvantage.
High scores on the Index of Relative Socio-Economic Disadvantage occur when the
area has families on low income and people with little training and in unskilled
occupations. Low scores on the index occur when the area has many low income
families and people with little training and in unskilled occupations.
Braybrook has a SEIFA rating of 760.1 compared to Maidstone and Yarraville which
have ratings of 889.2 and 1022.2 respectively. Braybrook is second most
disadvantaged suburb in Victoria.22
Braybrook also ranks 3rd in Victoria in the index of economic resources, which
provides an indication of access to assets such as higher incomes and home
ownership. Braybrook’s ranking indicates that there is a significant lack of access to
economic resources in the suburb.23
Gambling Discussion Paper
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Maribyrnong City Council
3.3 Income
Braybrook also has the lowest median income of any suburb in Maribyrnong at $569
and the highest proportion of low income households at 36% compared to Footscray
at 30% and Maidstone at 28%.24
Median Income for Maribyrnong
1400
1200
1117
Income in $
1124
1020
967
1000
1079
932
814
785
800
600
1152
713
569
400
200
0
ng
ne
ok
ille
ay
to
cr
ro
sv
no
s
s
r
b
g
t
y
d
n
o
ay
ai
ib
Ki
Fo
Br
M
ar
M
on
dd
e
S
y
ra
sc
t
o
Fo
t
es
W
le
vil
ra
r
Ya
M
i
ar
ng
no
r
by
ty
Ci
rn
te
es
W
on
gi
e
R
M
ne
ur
o
b
el
(Source: ID Atlas based on Census 2006 figures)
29% of Braybrook’s population relies on income support payments which is higher
than any other suburb in Maribyrnong. Income support payments include Newstart
Allowance, the Age Pension, Disability Support Pension and Youth Allowance.
Gambling Discussion Paper
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Maribyrnong City Council
Percentage of Maribyrnong population on income support
benefits by postcode
Yarraville
17%
Braybrook
29%
Maribyrnong
14%
Kingsville,
Maidstone, West
Footscray
20%
Footscray, Seddon
20%
(Source: Centrelink, Commonwealth Government, March 2010)
5% of Braybrook population has a low income card, which suggests higher rate of
working poor than other suburbs in Maribyrnong.25
Both these graphs suggest those people who are using EGMs in Braybrook are
spending a much higher proportion of their income than other suburbs in
Maribyrnong. This in turn could increase the level of income stress and poverty and
impact on health and wellbeing through reductions to food, medical and dental
budgets.
3.4 Housing and car ownership
24.8 % of Braybrook’s population rent from a government authority. This is
significantly higher than any other suburb in Maribyrnong and across Melbourne.
People who rent from a government authority are on a low income or on income
support payments.26
21% of Braybrook households do not own a car. This compares to 17% for
Maribyrnong City and 9% for the Western Region.
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Maribyrnong City Council
Percentage of population renting from a government authority
30
25
24.8
Percentage
20
15
12.1
10
7.9
6.1
5
2.6
2.3
2.3
3.3
1.8
2.7
0.2
Br
ay
br
oo
k
Fo
ot
sc
ra
y
Ki
ng
sv
il le
M
ai
ds
to
ne
M
ar
ib
yr
no
ng
Se
dd
W
on
es
tF
oo
ts
cr
ay
Ya
rra
M
vil
ar
le
ib
yr
no
ng
W
C
es
i ty
te
rn
R
eg
io
n
M
el
bo
ur
ne
0
(Source: ID Atlas based on Census 2006 figures)
19% of Braybrook’s population rent privately and 22% own their own home. This
compares to 26% for Maribyrnong city and 33% for Melbourne Statistical Division.27
Braybrook has the highest proportion of people in rental stress in Maribyrnong at
35%, and the highest level of people in mortgage stress at 20%.28
3.5 Food Security
Maribyrnong City Council’s Annual Community Survey for 2008 found that
respondent households with members who reported that they frequently “play the
pokies” (daily, weekly, or fortnightly) are substantially more likely to report having
often run out of food (8.8%). This was either 6-11 times per year, or every month,
compared to infrequent gamers (1.2%), and non-gamers (1.6%).29
Given the low median income and the high level of welfare dependency, people who
regularly use EGMs in Braybrook are far more likely face ongoing issues with food
security.
3.6 Qualifications and occupations
34% of the Braybrook population have Year 11 or lower qualifications and 9% of
Braybrook residents have university qualifications.30
The number of people in manual occupations such as labourers, machine operators
and drivers is much higher in Braybrook compared to other suburbs in Maribyrnong.
There are also fewer professionals in Braybrook.31
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Maribyrnong City Council
A higher proportion of people who gamble are in low skilled or unskilled
occupations. One explanation of this is boredom associated with these types of
occupations which leads to workers seeking an escape through gambling.
Percentage of occupations in Maribyrnong
35
30
25
20
15
10
5
tF
rra
vi
lle
W
es
ib
yr
no
M
ar
dd
o
e
to
n
ds
M
ai
Ya
oo
ts
cr
ay
Professionals
n
Se
Labourers
ng
Machine Operators, Drivers
lle
Ki
ng
sv
i
ot
sc
ra
y
Fo
Br
ay
br
oo
k
0
(Source: ID Profile, based on Census 2006 figures)
3.7 Alcohol dependency
Maribyrnong has a total of 32 packaged liquor outlets, at a ratio of 1 packaged liquor
outlet per 2,223 people. By comparison, there are 8 packaged liquor outlets (in 6
distinct precincts) within Braybrook. This equates to a ratio of 1 packaged liquor
outlet for every 895 people.32 This suggests that there is a high level of alcohol
dependency in the population in Braybrook. The Department of Justice study on
health related impacts of problem gambling identifies alcohol dependency has been
identified as a significant issue in problem gambling. 33 Both venues with EGMs in
Braybrook have liquor licences.
3.8 Conclusion
Braybrook has high levels of losses from EGMs when compared to other suburbs in
Maribyrnong, although it does not have as many EGMs. This suggests that the level
of losses from EGMs is highly concentrated in Braybrook, which is confirmed by the
level of losses per adult.
Braybrook also has high levels of social and economic disadvantage as indicated by
its SEIFA rating and other factors including lack of qualifications, low income, welfare
dependency and high levels of dependency government housing.
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Maribyrnong City Council
The combination of high levels of losses with significant indicators of social and
economic disadvantage suggest that Braybrook’s population is at risk of high rates of
problem gambling associated with EGMs.
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Maribyrnong City Council
4. Options for Managing Electronic Gaming Machines in
Maribyrnong
4.1 Planning Scheme amendment
Options for a Maribyrnong planning scheme amendment for EGMs include the
following:
Local Policy – Clause 22
A Local Policy would most likely outline permit requirements for applications to
install EGMs in venues in the municipality, in preferred and non-preferred locations
and potentially criteria for venue design. To justify the introduction of a Local Policy
a Reference Document would be prepared that would form the basis of an
amendment to the Maribyrnong Planning Scheme.
A number of other Victorian councils have developed a Local Policy including Hume,
Greater Geelong and Yarra Ranges. These policies have specified the requirements
for EGMs including the appropriate areas and sites. They also specify appropriate
venue design that reduces the impact of EGM gambling. It is likely that the
Maribyrnong Local Policy would take a similar format to these local policies. Further
details of other Councils’ planning scheme amendment policies can be found in
Appendix 3.
Schedules to Clause 52.28 specifying prohibited locations
Schedules to Clause 52.28 of the planning scheme would allow Council to prohibit
the location of EGMs at some sites in the municipality. Changes to these schedules
would likely increase the number of identified shopping complexes, and could also
define the boundaries of strip shopping centres where gaming is currently
prohibited.
Part of the process of undertaking a project to develop a planning scheme policy
would involve creating different scenarios for planning applications for EGMs in
venues to gain a clear understanding of what is required for changes to be made to
the planning scheme. The scenarios would include applications for new venues and
movement of EGMs to existing venues under the cap. The scenarios could also take
account of the changes to density of housing around gambling venues and the
impact this will have on the local community.
Council’s preferred option for the distribution of EGMs in Maribyrnong
Council’s preferred option for the distribution of EGMs in the municipality is the
concentration of machines in existing venues in areas of low disadvantage. This
would help to lower the impact of EGM gambling in areas of high disadvantage such
as Braybrook and Maidstone. It would also reduce the impact of convenience
gambling in the municipality. In order to achieve this, Council would have to regulate
the movement of EGMs in the municipality.
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Maribyrnong City Council
4.1 Advocacy
Lobby government and industry
Council will continue to advocate for better management of EGM gambling in
Maribyrnong through advocacy of the Commonwealth and Victorian Government
and the Victorian EGM gambling industry. This includes contributing submissions to
inquiries and meeting with government and industry representatives. Council will
also continue to contribute to existing networks for responsible gambling such as
Local Government Working Group on Gambling (LGWGOG).
4.2 Research
Research into the management and the social and economic impacts of the gambling
sector activities in Maribyrnong will assist in informing future revision of this policy
and the development of a Council planning scheme policy for EGMs.
This research will consist of analysis of the social and economic impacts of the
gambling sector activities in Maribyrnong, changes in the local market and policy and
regulatory developments in the gambling sector in Victoria and across Australia.
In addition the research will also focus on areas of gambling activities that
Maribyrnong currently does not have detailed information on including EGM design
which influences problem gambling, wagering (Racing and Sports Betting) Lotteries,
Club Keno and online gambling.
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Maribyrnong City Council
Appendix 1: Regulation of Electronic Gaming Machines in
Victoria
Background
In Victoria, gaming is regulated by the Gambling Regulation Act 2003, the Planning
and Environment Act 1987 and the Local Government Act 1989.
The Gambling Regulation Act 2003 provides the legislative framework for gambling
in Victoria. The main objectives of the act are to foster responsible gambling in order
to:

Minimise harm cause by problem gambling.

Accommodate those who gamble without harming themselves or others.

To promote tourism, employment and economic development generally in the
State.
Under the Act the regulation and conduct of EGM gambling in Victoria involves three
levels of control and participation in the industry: EGM gambling venues, gambling
operators and the State Government.
The Act stipulates that a maximum of 30,000 EGMs may operate in Victoria. This
includes 2,500 in Melbourne Casino and 26,682 EGMS in clubs and hotels in Victoria.
The Act also states that at least 20% of machines must be situated outside
Melbourne and that a maximum of 105 may be permitted within a single venue.34
The Victorian Commission for Gambling Regulation (VCGR) which is a statutory
authority in the Department of Justice, conducts inspections of machines, venues
and gambling operations, and maintains a scrutiny of EGM gambling throughout
Victoria.
The Local Government Act 1989 confers powers to local government as the
representative of the local community. The Act states that the primary objective of a
Council is “to endeavour to achieve the best outcomes for the local community
having regard to the long term and cumulative effects of decisions”.
The Planning and Environment Act 1987 establishes a framework for planning the
use, development and protection of land in Victoria. The objectives of planning in
Victoria, stated under section 4(1) of the Planning and Environment Act 1987 include
facilitating strategic decision-making, ensuring that the social and economic effects
of decisions are considered and encouraging the achievement of planning objectives
through proactive planning at the local government level.
The Victorian Planning Provisions are a standard set of provisions prepared by the
Minister for Planning that are included in all planning schemes in Victoria. They
include a suite of standard land use zones, a number of incorporated documents that
are common to all schemes, and the state planning policy framework.
The Victorian Government introduced amendments to the Victorian Planning
Provisions in 2006 in response to its commitment to improve the input of local
councils into the location of EGMs. A planning permit is now required for all EGMs,
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Maribyrnong City Council
replacing the previous as-of-right provisions for gaming machines if the area covered
by the EGMs was less than 25% of the gross floor area where liquor may be
consumed. EGMs remain prohibited in strip shopping centres and specified shopping
centres with the exemption for hotels in clubs in strip shopping centres being
removed.35
These amendments now enable Councils to involve the community more directly,
and to give consideration to the environmental, social and economic effects of new
gaming machines.36 However, applicants can appeal a planning decision made by a
council through the Victorian Civil Administrative Tribunal (VCAT). Maribyrnong City
Council had a decision to refuse a planning application for the Edgewater Club
overturned by VCAT. This decision is explored in more detail in Section 3.5.
Caps on Machine Numbers in Victoria
Background
The Victorian Government introduced caps on the number of EGMs that can be
contained in local areas in 2001, which were reviewed in 2006. There are currently
caps on the number of EGMs in 19 regions which are set at 10 EGMs per 1000 people
or at the gaming machine density in the region at the date the cap was imposed,
whichever is lower.
The boundaries for the capped regions are based on local government areas and
include those areas which are considered most at risk. By 2010 the regional cap of
10 EGMs per 1000 will extend to all uncapped local government areas. Maribyrnong
is one of the areas that have a regional cap established for EGMs.37
Effectiveness of the caps
The aim of these caps is to reduce the number of prevalence of problem gambling by
reducing the number of machines. However, the cap does not take into account
population increases in municipalities across Melbourne. Municipalities in the
Western Region face significant population increases over the next 20 years. This
would significantly effect the calculations for the number of EGMs per 1000 adults
allowed under the cap.
It also appears that the caps have not been effective in reducing the level of losses
from EGMs. In Victoria, between 2006/7 and 2007/8 548 EGMs were removed from
capped areas, while EGM losses to venues situated in those areas rose by $28 million
or 5%. The effect of this reduction in EGM numbers differed little from the uncapped
areas, which, in the same period, experienced a rise of 66 EGMs and an increase of
$41 m in gambling losses, or from the capped areas in the previous year (2005/6) to
2006/7) when the number of EGMs rose by 11 and gambling revenue by $32
million.38
Therefore, substantial reductions in EGM numbers in the capped regions in a period
which corresponds with the introduction of the caps was not accompanied by a
marked changed in gambling losses.
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Maribyrnong City Council
Community Benefit Statements
A Community Benefit Statement requires hotels and clubs which operate EGMs to
provide an indication of what support they are providing to their local community.
The purpose of these statements is to mitigate the impacts of problem gambling on
local communities.
Under section 3.6.6(2) of the Gambling Regulation Act 2003, net gaming revenues
from hotel venues are subject to an additional tax of 8.33% which is paid into a
Community Support Fund.
Under Section 3.6.9 of the Gambling Regulation Act 2003, all hotel and club
operators are required to lodge audited community benefit statement with the
VCGR on an annual basis.
A Ministerial direction issued in 2008 requires clubs to give a clear indication of how
they are providing a community benefit. A club must demonstrate that it has spent
8.33% of its net gaming revenue on activities that benefit the community.39 These
include:

Donations, gifts, sponsorships made to the community;

providing and maintaining sporting facilities;

subsidised goods or services provide to club members and the community;
and

voluntary services provided by club members and staff to the community.40
Code of conduct and self exclusion program
Amendments to the Gambling Regulation Act, enacted in 2007, require gambling
venues to adopt a code of conduct and self-exclusion program, which must be
approved by the VCGR according to the standards and guidelines determined by the
Minster for Gaming and Racing. In May 2008, the Department of Justice released a
discussion paper and Ministerial direction which set out some of the essential
guidelines for a code of conduct and self exclusion scheme. The guidelines must
include information about responsible gambling, the rules of gambling and the
process for an EGM player making a pre-commitment decision. They must also be
written in plain English and displayed in an accessible location in the venue. The code
is also required to guide staff in dealing with customers particularly those people
who are displaying signs of distress associated with gambling problems.
Self exclusion programs already operate in Victoria and in other States, although it is
questionable as how effective they are because of the reluctance of people to self
identify that they have a gambling problem. It has also been found that a substantial
proportion of people who participate in these programs continue gambling.41
Changes to the regulation of Electronic Gaming Machines in Victoria
In April 2008, the State Government announced a new direction for the gaming
industry and gaming licensing after 2012. The Gambling Regulation Amendment
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Maribyrnong City Council
(Licensing) Act 2009 came into effect on 24 June 2009 setting out the legislative
framework for the new venue operator arrangements. From 2012 there will be
separate Venue Operator’s Licences for clubs and hotels, and clubs and pubs will be
able to own and operate gaming machines. This will end the duopoly of TABCORP
and Tatts Group over operating Victoria’s non-casino EGMs.
Under the new arrangements, approved hotels (companies with a VCGR venue
operator’s license) and clubs bid directly for 10-year gaming machine entitlements in
which authorised venues to possess and operate gaming machines.
In May 2010, EGMs were auctioned in 88 geographic areas consisting of
municipalities or parts of municipalities that were subject to two separate caps. The
number of EGMs allowed within each of these 88 areas will be capped as part of the
new ownership regime.
The auction of licences saw a number of companies with a venue operator’s licence
from the VCGR bid online for entitlements for each of the 26,682 EGMs currently in
pubs and clubs. Each entitlement will allow the venue operator to operate an EGM
for 10 years, although the Minister for Gaming has the discretion to extend this by
up to two years.42
The monitoring and regulation of EGMs currently conducted by the VCGR will be
undertaken by an independent organisation. The process of acquiring a venue
operator’s licence and obtaining approval for gambling venues and EGMs by the
VCGR and local council remain similar to the current arrangements.
Existing restrictions on the number of EGMs allowed in each region will still apply as
will the current limit of 105 EGMs per venue. An application must be made to the
VCGR to vary EGM licence conditions. 43
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Maribyrnong City Council
Appendix 2: Problem gambling in Australia
Background
It is estimated that there are between 80,000 to 160,000 people in Australia who
could be classified as problem gamblers and between 230,000 and 350,000 people
are moderate risk who experience lower levels of harm and who may progress to
problem gambling. 44
Over 1% of Victoria’s population can be classified as problem gamblers. Around 85%
of problem gamblers identified in the 2003 Victorian prevalence survey spend most
of their money on EGMs and 80% for severe problem gamblers. 45 The corresponding
figure in the 2008 Victorian Department of Justice survey was 64% of problem
gamblers highest spend activity was EGMs. 46
According to the same survey 91% of problem gamblers and 77% of moderate
gamblers use EGMs.47 It is estimated that problem gamblers account for 40% of the
total losses from EGMs in Australia.48
Reasons for problem gambling
Electronic Gaming Machine design and usage
EGMs have the capacity for rapid repetition of games. The rapid repetition allows for
players to continuously place bets on the machines, which are often small bets of a
dollar or less. EGM users can have the sense of dislocation, as though they are not
connected to reality. Many players acknowledge that they play EGMs to escape or
tune out from a variety of personal situations. 49
There is a misconception by EGM players that the machines operate in cycles of
winning and losing. EGM players may believe they acquire more knowledge if they
play more often. Problem gamblers are also more likely to use the same machine,
because it will bring them luck. They can sometimes have a big win and these wins
act as an incentive for further gambling.50
EGM usage and design can contribute to problem gambling. One of the key factors in
developing an addiction is the repetition of the same actions, which forms a habit.
This habit provides a sense of reassurance associated with the addiction, because it
provides a constant in the person’s life. 51
EGM design and usage can provide a framework for a habit to develop by
encouraging repetition of actions and feelings associated with gambling. The other
factors outlined below further contribute to providing a framework for an addiction
to develop.
Venue design and activities
The venue design and activities can contribute to EGM problem gambling by creating
an environment that increases the sense of escapism. The placement of machines
near other facilities such as toilets, bars or next to eating areas can allow gamblers to
continue with other activities while using the machines. A lack of natural light in a
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Maribyrnong City Council
gambling area can also contribute to the sense of escapism that some gamblers feel
when playing EGMs.
In addition, the placement of ATMs and EFTPOS facilities in prominent places in
gaming venues further increases the risk for problem and moderate gamblers.52
A venue to be developed in the Melbourne suburb of Beaconsfield includes plans for
a soundproof children’s playroom in full view of the venue’s EGMs, so parents can
monitor their children from the gaming room.53
Apart from this, venues also provide other inducements to gamble such as raffles,
free tickets, free alcohol, free food and giveaways. These often encourage people to
stay in a venue for a longer period. Other inducements are linked directly to
gambling include:

awarding gifts to gamblers who reach a certain number of points on their
loyalty cards; and

jackpot nights where the first person who gains a certain number of points on
their loyalty card receives a cash prize, raffle tickets or coupons that can be
converted into credits for EGMs.54
Social activity
Problem and moderate gamblers often view the act of playing the pokies as part of a
social activity. Clubs in particular are an area of social activity in local communities
often because of their association with sport or other community activities. The
highest spend on EGMs in Victoria is for clubs 47% followed by pubs, 31% and the
casino 14%.55
A high spending share by problem gamblers weakens the incentives for venues to
manage problem gamblers because they provide a significant source of revenue. This
is particularly the case for venues such as clubs that rely on revenue collected from
EGMs as an important source of funding for other community activities.
A number of the submissions to the Productivity Commission inquiry into gambling
suggested that EGM revenue was an important resource for local communities and
that reducing or removing this resource would impact on the wider community.56
Venue Location - Convenience
One of the key issues associated with moderate and problem gambling is the
location of the EGMs in local areas. 90% of people living in metropolitan Melbourne
reside within a 2.5 kilometre radius of a club or hotel with EGMs and 55% in non
metropolitan areas. A survey of 8,500 Victorian residents by KPMG found that 32%
of gamblers travelled an average of 2.5 kilometres to a venue and 57% less than 5
kilometres.57
A study by the Department of Justice found that over 53% of EGM players travelled
no more than 5 kilometres. Over 42% of problem gamblers travelled between 2-5
kilometres compared to 46% for moderate gamblers and 41% for low risk gamblers.
Over 12% of problem gamblers were prepared to travel between 6-10 kilometres
and 26% over 10 kilometres.58
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Maribyrnong City Council
Hotels and clubs are often located in or around activity centres or near local
shopping areas. This makes it more likely that people conducting other business in
their local area will engage in gambling.
In States that have fewer venues with EGMs the level of losses are lower. In Western
Australia, EGMs are restricted to the Burswood Casino and the ACT modern gaming
machines are only allowed in clubs. This is referred to as destination gambling.
Destination gambling is less convenient than the community wide model adopted in
other States and Territories. For example, New South Wales and Victoria have the
highest rates of losses for EGMs and they also have the highest concentration of
clubs and hotels, containing EGMs.
A recommendation of the Productivity Commission Inquiry report into gambling was
for a restriction on the location of gambling venues, or the provision of gambling
services, in airports and near schools and shopping centres. 59
External issues
External issues particularly those causing high levels of stress and anxiety are a
significant cause of problem gambling. According to the Victorian Department of
Justice Report Problem Gambling From a Public Health Perspective, which surveyed
15,000 Victorians, problem gamblers identified a number of different external issues
as contributing to their addiction.

32% had experienced a death in the family.

45% had experienced a major illness or injury to themselves or someone
close to them.

20% had experienced problems with work, boss or superiors.

46% reported a major change in their financial situation.

42% reported an increase in number of arguments with someone close to
them.

28% reported a major change in living or work conditions.60
These figures suggest that people who become problem gamblers are seeking an
escape from the affects of external issues through playing EGMs. As previously
stated, the design and layout of EGMs allows players to switch off from their
problems and simply press a button and the hope of winning a large amount of
money which will assist in alleviating their problems.
Type of employment and education background
People who become problem gamblers are more likely to work in low skilled manual
employment. Boredom associated with work is cited in various research as one of
the causes of problem gambling. A number of problem gamblers also have poor
education backgrounds with many not completing Year 12 or not having tertiary
qualifications. Particularly in areas with a high SEIFA index the levels of education are
lower. 61
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Gender
The 2003 Victorian Longitudinal Community Attitudes Survey indicated that
gambling problems are more prevalent among males than females. However, the
representation of women among people with gambling problems has increased in
recent years. The Productivity Commission notes that in 1999 a survey of problem
gambling indicated that just 14% of people with gambling-related problems were
female, while by 2007/8, approximately half of all Victorian Gambler’s Help clients
were women. 62
Impacts of Problem Gambling
Health and Psychological Impacts
Problem gamblers are likely to experience a number of psychological and health
related impacts. Evidence suggests that a high proportion of people presenting for
help with gambling are also dealing with other health or behavioural issues. The
Productivity Commission Inquiry report found that:
 the rate of likely hazardous alcohol use was 5%;
 the risk of depression was 71%; and
 the rate of daily smoking was 5%.63
In addition, there is evidence that problem gambling further exacerbates existing
health and psychological problems with 36% having a severe mental disorder that
contributed to their addiction.
The Department of Justice Study on the Health impacts of gambling further confirms
this trend. In the study of 15,000 respondents they found that:
 46% reported anxiety as a major issue compared with 17.17% of moderate
gamblers.
 43% of problem gamblers smoke between 11-20 cigarettes a day
 25% of problem gamblers – risk alcohol consumption 15-28 drinks per week.
 52% reported depression as a major issue compared with 20.33% for
moderate gamblers.
 21% of problem gamblers were obese
 28% of problem gamblers had a disability.64
Increase in income stress and poverty
As previously mentioned, a high proportion of problem gamblers are already on low
incomes and facing increasing debt problems a reliance on social welfare services
and charities and the potential risk of homelessness.
A key trigger for most people becoming problem gamblers is financial loss which
directly links the economic and social impacts of problem gambling. Uncontrolled
spending of problem gamblers and household financial stress can further affect the
financial security of an individual or their family, impacting on food security and an
ability to pay medical and dental expenses. 65
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In affect, problem gambling combined with income stress can create a downward
spiral that leads to even higher levels of debt, and a greater reliance on income
support and community services.
The highest level of losses from EGMs in Victoria is in areas of social and economic
disadvantage. This includes areas with low incomes, poor education outcomes and
higher unemployment levels. The SEIFA index for social disadvantage shows that
municipalities of Greater Dandenong, Maribyrnong and Brimbank have the highest
levels of disadvantage in Victoria. Greater Dandenong losses amounted to $1,159 per
adult, with Maribyrnong and Brimbank at $1,042 and $995 respectively.66
A study by the Australian Institute of Health and Welfare found that in 2007/8, 2462
people across Australia who had a gambling related issue sought government
assisted accommodation support Supported Accommodation Assistance Program.67
Family and relationship breakdown
Problem gamblers are more likely to face family and relationship breakdown issues
as a result of the pressures of problem gambling. A qualitative research project in
Victoria found that there was a link between family violence and problem gambling.
Family violence increased with the development of gambling problems, and there
was an increased risk of gambling problems with the presence of family violence –
overwhelmingly as women gamble to cope with abuse.68
Crime
Several studies have demonstrated that income generating crimes such as theft,
break and enter and fraud are used by some problem gamblers to support their
addiction.
A 2008 study of all Australian convictions for deception related offences between
1998 and 2007 identified 528 criminal cases in which gambling was a significant
factor. The study found that Victoria has the highest number of criminal cases
relating to gambling at 156, as well as the highest losses to fraud $102.7 million.69
Government Action on Problem Gambling
Commonwealth
The Commonwealth Government funds a range of services for problem gamblers
including emergency relief, supported accommodation assistance Program and
Commonwealth Financial Counselling, and income support payments.70
The Productivity Commission undertook an inquiry into gambling in 2009 and
published a report of its findings in 2010. The report developed a number of
recommendations relating to problem gambling including:

Service Linkages - Establish stronger formal linkages between gambling
counselling services and other health and community services including
developing a one item screening test which is targeted at people presenting
with anxiety, depression, high drug and alcohol use.

Standards - Governments should work together to establish a national
minimum standard of training for problem gambling counsellors.
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
Funding sources - Governments should ensure that existing funding sources
for gambling help services be based on greater contributions from those
gambling forms found to involve greatest social harms.

Improving pre commitment strategies - Pre commitment involves gamblers
being able to determine limits on their access to EGMs at specific venues. The
report suggests improvements to aspects of pre-commitment such as
establishing pre-commitment regimes.

EGM design – Government should require that by 2012, all new EGMs include
the capacity to be played at a maximum intensity of a $1 bet per push button,
with this being activated in 2016. Governments should also restrict to $20 the
amount of cash that a player can insert into a gaming machine note acceptor.

Venue activities – Enhancing staff training requirements to help identify
problem gambler behaviour.

ATM placement in venues - limit cash withdrawals from ATMs to $250 a day
except in casinos, place ATM/EFTPOS facilities a reasonable distance from the
gaming floor visible to the public and venue staff yet not to gamblers from
the gaming floor and place clearly visible warning and help messages on
ATMs.

Accessibility of gaming machines – Drawing on the Queensland approach,
governments should introduce a shutdown period for EGMs in all hotels and
clubs that commences no later than 2am and lasts for at least six hours. 71
The Commonwealth Government has stated that it will work towards implementing
some of the key recommendations of the report including:

Support a national consistent pre-commitment strategy model for EGMs.

Consider options to improve harm minimisation measures for EGMs.

Recommend that the Council of Australian Government’s Select Council on
Gambling Reform includes up to two Ministerial representatives from all
jurisdictions to ensure that both economic and social portfolio’s are
represented.72
Following discussions with the Independent Member for Denison, Andrew Wilkie,
the Commonwealth Government has agreed to implement further reforms of the
Electronic Gaming Machine industry. These reforms include:

Capping ATM withdrawals in gambling venues to $250 per day; and

Introducing pre commitment Smart Card technology on poker machines to
allow gamblers to predetermine how much they gamble.73
Ministerial Council on Gambling
At the Ministerial Council on Gambling meeting in July 2009, Ministers agreed to
develop a national screening tool to help gamblers and service providers identify
risky gambling behaviour before it becomes too entrenched. The screening tool is to
contain questions to help individuals self assess and enable doctors, financial
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counsellors and other support services to be able to identify if a person is at risk of
becoming a problem gambler.
The Ministerial Council also agreed to work together to provide better linkages
between front line Commonwealth and State Based gambling support services, to
better support problem gamblers. 74
Victorian Government
Taking Action on Problem Gambling: A strategy for combating problem gambling in
Victoria (2006) is the State Government’s five year strategy to reduce problem
gambling.
The strategy pledges increased funding for problem gambling services, community
education, improving consumer protection and gambling research and protection for
vulnerable communities. The State Government supports EGM gambling in their
policy as a legitimate activity and considers it to “make an important contribution to
our community and our economy”.
The strategy reviewed the capped regions across Victoria and looked at appropriate
EGM densities. Capped regions are identified areas of vulnerability, where a
maximum number of EGMs is set. The strategy identifies that low socio-economic
areas are more vulnerable to the harms that gambling can cause, and these areas
should be avoided as locations for gaming venues.75
The Victorian Government has also banned ATMs from all Victorian gaming venues
from 2012 as part of new legislation to attempt to encourage responsible gambling.
The new laws will also see pre-commitment capabilities mandated for gaming
machines. The pre-commitment system will give gamblers the option to determine
the amount of time and money they spend on EGMs.76
In addition, the Victorian Government is assisting problem gamblers through the
Victorian Primary Care Partnership Strategy. This strategy aims to improve linkages
between gambling help services and the broader health and care sector.
The Victorian Government has further established a specialist portfolio to service to
work in collaboration with mental health, alcohol and drug services, and family
services to better integrate service responses for problem gamblers.77
Conclusion
A number of factors contribute to the development of EGM problem gambling in the
community. The combination of these factors impacts on the effectiveness of
mitigation strategies that government undertake to reduce problem. Attempts by
Commonwealth and State governments to reduce the impact of EGM problem
gambling on the community have reduced the overall number of problem gamblers.
However, this has not had an impact on losses which has actually increased in
Victoria. This suggests that EGM problem gamblers are continuing to gamble heavily
particularly in areas of high social disadvantage.
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Appendix 3: Other Victorian Councils’ Gambling Policies
Background
Planning Scheme amendments
Under an amendment to the Local Government Act in 2006, Local Government has
greater powers to make planning decisions. Gaming is covered by a specific provision
at Clause 52.28 of the Victorian Planning Scheme. Under this provision, a local
government planning permit is required to install or use EGMs.
The planning permit allows a council discretion to develop land use policies that
compliment the existing planning scheme and integrate with its social policy
objectives with respect to EGMs. A planning policy is a Council’s strongest statutory
control over gaming in the municipality.
Councils, including, Greater Geelong, Yarra Ranges, Macedon Ranges and Hume City
Council, have adopted amendments to their planning scheme policies in relation to
EGMs. Macedon Ranges has also adopted Electronic Gaming Machine (Pokies)
Community policy which is contained the Community Wellbeing theme in its Council
plan.78
The focus of these amendments is on new and existing venues that contain EGMs as
they represent a significant proportion of issues relating to problem gambling. The
aim of the amendments to the council planning scheme is to reduce the risk of
problem gambling in the community particularly in areas of social and economic
disadvantage.
Differential Rates
Moreland City Council is introducing differential council rates for gambling venues
located in the municipality, with the aim of discouraging the proliferation of
gambling venues in the area. The money raised from the higher rates will be for
gambling research to be undertaken by the council. Moreland Council has previously
attempted to introduce this policy last year. However, the regulation was struck out
through a Supreme Court challenge by gambling venues due to an administrative
oversight.79
Other Policies
Darebin City Council has developed a social policy as the basis for action on EGMs in
their area. However, they are also considering options for a planning scheme
amendment.
The following is an outline of the gambling policies of eight different councils in
Victoria.
Greater Geelong City Council
Greater Geelong City Council has adopted an amendment to its planning scheme
policy which is currently before the Minister for Planning for approval. The objectives
of the recommended revised policy outlined in the amendment are:

To avoid the risk of exacerbating problem gambling.
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
To protect the operations and amenity of existing uses surrounding gaming
venues.

To ensure that the area, site and venue characteristics of gaming machines
contribute to net community benefit.
The policy also provides additional requirements for appropriate areas, sites and
venues for EGMs which are as follows.
Appropriate Areas
EGMs should be located in areas:

Where they will contribute to a redistribution of gaming machines away from
disadvantaged areas as defined by the SEIFA index of relative disadvantage.

Where the community has a choice of non gaming entertainment and
recreation activities and established social infrastructure some of which
operate during the times that the proposed gaming machines will operate in
the local area.

Where socio-economic disadvantage is relatively lower.

Where the electronic gaming machine density of the locality and its
catchment is equal to or below the overall municipal average.
Gaming machines should not be located in areas:

Where socio-economic disadvantage is high, as defined by the SEIFA index of
relative disadvantage.

Identified for growth where the density of machines exceeds 10 gaming
machines per 1000 adults in the relevant postcode.
Appropriate Sites
EGMs should be located on sites:

That minimise the likelihood of people passing the venue in the course of
their usual business or every day activities.

Near activity centres, or at a sports or recreation club with a land holding of
more than 2 hectares.

Close to an activity centre that serves more than a local catchment;

At the periphery of the activity centres, outside of the main transport,
shopping, community and civic functions of the centre.
Appropriate Venues
EGMs should be located in venues that:

Promote non gaming activities that increase net community benefit

Offer social, entertainment or recreational opportunities other than gaming
as the primary purpose of the venue.

Have a range of entertainment and leisure options.
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
Promote responsible gaming practices.
EGMs should not be located in venues that:

Have a gaming floor area of more than 25% of the total floor area of the
venue.

Has 24 hour-a-day operation.

Are located within a prohibited area identified in Clause 52.28.
The Geelong City Council policy also includes specific application requirements for
venues proposing to increase their EGM numbers. Some of those requirements
include:

If it is proposed to more EGMs from one part of the municipality to another,
details of the relative social and economic differences between the two
suburbs or small towns.

An explanation of why the EGMs are being transferred.

If relevant, details of existing EGM losses at the venue (over a three year
period prior the application) and a forecast of the anticipated losses at the
venue if the proposal was to be approved.

The relative socio-economic disadvantage of the suburb or neighbourhood
and the broader catchment of the venue in comparison to the Melbourne
average in the SEIFA index.

Details of what gaming and non-gaming entertainment and recreation venues
and social infrastructure exist within 5 kilometres of the venue.

The distance to shopping complexes and strip shopping centres, community
facilities, counselling services and public transport.

Pedestrian counts outside the proposed venue on different days and at a
variety of times.
The amendment policy also provides decision guidelines for the responsible
authority must consider before deciding on an application. These are based on the
above requirements.80
Yarra Ranges Shire Council
Yarra Ranges Shire Council has adopted an amendment to its planning scheme
relating to EGMs. The objectives of the revised policy outlined in the amendment are
as follows:

Minimise opportunities for convenience gaming and the incidence of problem
gambling.

Reduce the adverse health, social and economic impacts of gaming machines.

Ensure that the area, site and venue characteristics of gaming machines
contribute to net community benefit.
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
To protect the amenity of existing uses surrounding venues containing
gaming machines.
As with the Greater Geelong City Council amendment, the policy includes
information about the appropriate areas, sites and venues for EGMs, which are as
follows.
Appropriate Areas
EGMs should be located in areas:

More than 1.5 kilometres from an Australian Bureau of Statistics collection
district within the Shire that is within the most socio-economically
disadvantaged 20% as defined by the SEIFA index of relative disadvantage.
EGMs should not be located:

In residential zones.
Appropriate Sites
EGMs should be located on sites that:

Avoid a concentration of venues in a particular locality.
Are more than 400 metres from:

A shop or outlet predominantly selling food and/or other goods which cater
for day-to-day needs such as supermarkets, milk bars, post offices and
newsagents.

Sensitive community facilities including schools, kindergartens, child care
centres, libraries, medical centres, churches and the offices of public and
private welfare agencies.

A railway station or transport interchange.

Another venue which operates gaming machines.
EGMs should not be located on sites that:

Are in or at the edge of activity centres.
Appropriate Venues
EGMs should be located in venues that:

Provide a range of social, leisure and recreational activities other than gaming
as the primary purpose of the venue. Alternative non-gaming entertainment
and recreation facilities include hotels, clubs, cinemas, restaurants, bars and
indoor recreation facilities operating at the same times as the proposed
gaming venue will operate.

Incorporate effective management and mitigation measures to minimise the
risk of problem gambling.

Have a gaming floor area less than 25% of the total floor area of the venue.

Have access to natural light and allows patron surveillance of outdoor areas.
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
Have clear directional signs to all non-gambling amenities, including toilets
and dining areas, are provided from the gambling areas; physically and
visually separate the venue’s non-gambling activities are from gambling
activities.

Are designed so that amenities for the venue’s non-gambling activities,
including entrances and exits, toilets, automatic teller machines, meeting
spaces and dining areas, can be accessed without entering the gambling area.

Do not operate more than 16 hours per day.
EGMs should not be located in venues that:

Will have a significant adverse amenity impact on the adjoining land uses as a
result of operating hours, traffic, noise, car parking, safety and security.81
As with the Greater Geelong’s proposal, this amendment is awaiting approval by the
Minister for Planning.
Macedon Ranges Shire Council
Macedon Ranges has developed a gambling policy which is part of the Community
Wellbeing theme in the Council Plan for 2010-2013. The policy is based on four main
principles:
1. Playing of pokie machines is a legal activity within the State of Victoria and
many people choose to play.
2. Gambling venues are not to be located in areas of high vulnerability or in
locations central to where people go about their daily activities.
3. Pokie venues have in place responsible gambling and harm minimisation
strategies and activities.
4. Gaming venues need to demonstrate they provide direct benefits to the local
community. Community benefit does not include losses on business
overheads and subsidised goods and services aimed at venues’ members and
customers.
This policy also contains six documents which are required for the assessment of
applications for a permit for a new EGM venue. These documents are:
 Location – whether the venue is located within a shopping strip, close to
shops, in a location central to where people go about their daily activities in
a town with a low SEIFA score, in a town other than a major urban centre.
 Impact Assessment – Demonstrate what impact the additional EGMs will
have on health, social and economic wellbeing of the local community.
 Harm Prevention – Requires applicants to indicate which product safety,
venue host responsibility and harm minimisation strategies will be put in
place and submit a comprehensive code of conduct for their venue.
 Community Advantage – Applicant needs to demonstrate that there are
significant and measurable advantages to the local community as a result of
their venue and the additional machines.
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 Action Based Code of Conduct – Requires the applicant to list the specific
actions undertaken to implement harm prevention and minimisation
practices in the management of EGMs.
 Cover sheet and checklist 82
Macedon Ranges has also adopted an amendment to its planning scheme provisions
to guide the location of new gaming machine venues. The amendment aims to take
account of the link between social disadvantage, problem gambling and accessibility
to gaming venues.83
Clause 52.28 of the Victorian Planning Provision allows municipalities to specify strip
shopping centres and shopping complexes where gaming machines are prohibited.
As the four tests set out in this clause to define what constitutes a strip centre are
considered ambiguous, the amendment to Macedon Ranges planning scheme also
defines the municipality’s strip shopping centres through a series of maps to ensure
that there is clarity as to where gaming machines are prohibited in the municipality.
The application and assessment criteria set out under the Local Planning Policy stems
from recommendations of both the Gaming Policy Framework and the gambling
policy.84
Romsey Case
In addition to these changes, Macedon Ranges opposed the application by the
Romsey Hotel to install 30 new EGMs. The basis of rejecting the application was that
the there was significant community opposition to the installation of the EGMs in the
hotel. The VCGR ruled in the Council’s favour. However, this was then overturned by
the Victorian Civil and Administrative Tribunal (VCAT). Macedon Ranges then
appealed the VCAT decision through the Supreme Court, which overturned the
decision ruling that VCAT did not take account of community opposition to the
proposal.85
The ‘Romsey Case’ has set a precedent for installing new EGMs in clubs and hotels.
However, it may only apply to the installation of EGMs in newer suburbs which do
not have any EGM venues already. It is also dependent on the level of community
opposition. Several growth areas such as Wyndham in Melbourne’s west are
continuing to see applications for new EGM venues as part of activity centres and
other local developments.
Hume City Council
The Hume City Council amendment to the planning scheme policy aims to make
gaming machines reasonably accessible to the community as a form of
entertainment, but not be convenient. It is recognised that whilst gaming is a
legitimate form of recreational activity, for some it leads to adverse consequences
for the gambler and for the community.
The policy objectives include:

to discourage gaming venues in disadvantaged areas;
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
to ensure there are a number of non-gaming entertainment forms available;
and

to reduce the prevalence of convenience gambling and problem gambling.
Gaming venues are planned in Hume as part of the overall range of entertainment
and recreation facilities on offer.
The policy provides a series of location guidelines as to where gaming venues can
best be located where they will cause the least harm to the community. This includes
guidelines regarding their location relative to activity centres, shops, community
facilities and key public transport nodes in relation to non-gaming activities, socioeconomic disadvantaged areas.
Applicant Guidelines
Applicants are required to provide a statement to Council that includes:

information on the gaming profile of the municipality;

an assessment of the community benefits and costs associated with the
proposal;

details of gaming and non-gaming forms of entertainment available in the
local area;

design and layout of premises; and

distances to shops, public transport, community facilities and services.
Applicants are also asked to provide evidence of the need for additional gaming
machines within the municipality broadly and more specifically in the proposed
location. 86
City of Maroondah
This amendment to the planning scheme policy builds on a social policy already in
place within Maroondah and aims to:

minimise detrimental impacts of gaming on the community;

maximise the benefits for the community;

ensure the delivery of net community benefit;

avoid concentration of gaming venues; and

encourage non-gaming activities within gaming premises in Maroondah.
The policy is based on indicators around EGM-to-population ratios, number of
gaming venues and gaming losses per adult.
The policy states new gaming premises should not be located within 400m of
residential and community based uses including schools, kindergarten, child care
centres, libraries, aged care facilities and churches.
Applicants are required to provide extensive research to identify evidence of net
community benefit as an outcome of the applications.
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The required Social and Economic Impact Statement must:

review the gaming profile in the municipality;

identify community benefits of the proposal;

forecast losses;

outline non-gaming uses offered within the premises;

detail design and layout of premises and how they response to council policy;
and

review socio-economic indicators of surrounding population and location in
relation to social, public or community housing and any other identified
impacts.87
City of Greater Bendigo
This policy is based on an understanding that problem gambling affects a small
proportion of gamblers and that by locating gaming venues in locations that are
convenient, but not highly accessible will decrease the incidence of "convenience
gaming".
Policy objectives include:

To discourage new gaming machines in disadvantaged areas.

To ensure the location of gaming machines and design and operation of
facilities minimise opportunities for convenience gaming and the incidence of
problem gambling.

To ensure that gaming machines are located where the community has a
choice of non-gaming entertainment and recreation activities within the
venue or in the local area.

To protect the amenity of existing uses surrounding gaming venues.
The policy directs gaming venues to growth areas and areas of low EGM density;
must be on the periphery of a major activity centre; be considered a destination in
its own right and be located in areas where there is alternative entertainment uses.
These include hotels, clubs, cinemas, restaurants, bars and indoor recreation
facilities operating at the same times as the proposed gaming venue will operate.
Applicants are required to provide a social and economic impact assessment to
Council that includes details of:

the proposed community benefits;

socio-economic disadvantage;

gaming and non-gaming recreation and entertainment;

proposed losses;

gaming profile of the area;

design and layout of venue; and
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
distance to shopping and community areas88
Greater Bendigo has also implemented an amendment to its planning scheme, which
was approved in March 2009 and is based on the recommendations outlined in the
policy. Amendment C110:

Amends the Municipal Strategic Statement at Clause 21.07 and 21010 to
introduce references to EGMs and include the gaming framework as a
reference document.

Introduces a Gaming Policy at Clause 22.28 to guide the location of EGMs in
all other areas within the municipality.

Specifies strip shopping centres and shopping complexes at Clause 5228
where gaming machines are prohibited.

Lists Greater Bendigo Discouraged Gaming Areas as an incorporated
document in the schedule to Clause 81.01.89
Moreland City Council
Responsible Gambling Policy 2005-2008 (extended to 2010)
Moreland City Council have recently reviewed their responsible gambling policy
Goals and objectives of the strategy are to:

Reduce the incidence of problem gambling.

Reduce EGM losses and EGM density.

Achieve more equitable distribution of funds allocation through the
Community Support Fund.

Promoting a healthy, safe and inclusive community with diverse leisure,
participation and learning opportunities.
The policy and action plan aims to:

enhance Council planning control over applications for gaming venues to
include economic and social impact assessments;

develop responsive policy and services to enhance understanding of the
impact of problem gambling on vulnerable communities;

promote partnerships with the service community and gaming venues;

work in partnership with other Councils; and

advocate to State Government for effective responsible gambling measures
to raise awareness of the impact of gambling on the Moreland community.
The policy also advocates the introduction of differential rates for gaming venues in
Moreland. The aim of the differential rates would be to provide a funding resource
for ongoing research into gambling by council.90
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Darebin City Council
Draft Electronic Gaming Machine Policy and Strategic Action Plan
The policy clearly provides Council’s position on EGM gambling, community benefit
and Council as responsible planning authority.
Principles:

Advocacy & Partnership

Health and wellbeing, identifying community needs

Research and understanding

Funding programs and services transparently
Position Statement, EGM Gambling:
The Darebin policy further states that the Council will not condone any activity that
harms the community and therefore, they not support EGM gaming in the
municipality.
Council’s overall goal is to significantly reduce the number of EGMs in the city and
minimise and reduce the negative impacts of gaming on the Darebin community.
Development and promotion of alternatives to gambling through services, programs
and local infrastructure development.
Enhanced planning control:

Develop a robust policy for planning applications.

All gaming applications will be considered by planning committee and social
policy will be involved.

Assessment documentation included in Action Plan.

Make submission of Social and Economic Impact Assessment to VCGR for any
applications made within Darebin.

Council will not support the continuation of EGM gaming machines on
Council owned or managed property or land.
Community Benefit:

Council supports mechanisms that promote greater return of gaming losses
back into the local community to off-set the negative impacts of gambling,
including possible differential rates system, CSF, increased transparency.91
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Reference List
ABC News, Playroom at Pokie Venue Under Fire’ , 28th July 2010
Australian Government, Assistant Treasurer, Senator the Hon Nick Sherry, Joint
Media Release with The Hon Jenny Macklin MP Minister for Families, Housing,
Community Services and Indigenous Affairs and Senator the Hon Stephen Conroy
Minister for Broadband, Communications and the Digital Economy, Productivity
Commission Report into Gambling, 23 June 2010
http://assistant.treasurer.gov.au/DisplayDocs.aspx?doc=pressreleases/2010/138.ht
m&pageID=089&min=njsa&Year=&DocType=0
Australian Institute of Health and Welfare Canberra, Problem gambling among those
seeking homelessness services, November 2009
Centrelink, Australian Government, March 2010
Australian Government, Productivity Commission Report on Gambling February 2010
Brown, Hayden A Review of Gambling-Related Issues, City of Greater Dandenong,
2009
City Greater Bendigo, Gambling Policy Framework – Accessible but not convenient
Prepared by Coombes Consulting, October 2007
Department of Justice, A Study of Gambling in Victoria, Problem Gambling From a
Public Health Perspective, September 2010
Department of Justice, Community Benefit Statements: A new direction Information
Paper, Office of Gaming and Racing, June 2007
Department of Justice Liquor Licensing website statistics 2010.
Department of Justice Media Release Gaming Venues to Become ATM Free Zones, 13
July 2009
Darebin Electronic Gaming Machine Policy and Strategic Action Plan City of Darebin,
2010
Hume City Council, Hume Planning Scheme Clause 22.17 12, March 2009.
Greater Geelong City Council Greater Geelong Planning Scheme Amendment C168
Gaming Policy Panel Report February 2010
Informed Decisions ID Profile, 2010
Informed Decisions ID Atlas, 2010
Macedon Ranges Shire Council Amendment C64 Local Gaming Policy, 2009
Macedon Ranges Shire Council Amendment C64 List of changes to Macedon Ranges
Planning Scheme, Macedon Ranges Shire Council, 2009
Macedon Ranges Shire Council Electronic Gaming Machine (Pokies) Community
Policy 2009
Gambling Discussion Paper
49
Maribyrnong City Council
Macedon Ranges Shire Council Media Release Gaming Machines Refused at Romsey
Hotel 12 November 2009
http://www.mrsc.vic.gov.au/Files/PokiesDecision_RomseyNov09.pdf
Maribyrnong City Council Maribyrnong Annual Community Survey, 2008
Maribyrnong City Council website 2010, Edgewater Gaming Facility Proposal
http://www.maribyrnong.vic.gov.au/Page/Page.asp?Page_Id=4016
Maroondah City Council Gaming Policy and Statement of Practice February 2007
Moreland City Council Draft Responsible Gaming Strategy 2010-2014 June 2010
Moreland City Council Issues Paper – Gaming in the City of Moreland DRAFT for the
development of a Moreland policy position on gaming, May 2010
Kristy Needham Wilkie Wins Pledge to Reform Pokies, theage.com.au, September 3,
2010 http://www.theage.com.au/federal-election/wilkie-wins-pledge-to-reformpokies-20100902-14ro1.html
Victorian Commission for Gambling Regulation (VCGR) City of Maribyrnong Current
Venues 2011
Victorian Commission for Gambling Regulation (VCGR) Metropolitan Melbourne 2010
Victorian Commission for Gambling Regulation (VCGR) Statistical Data Fact Sheet
Electronic Gaming Machines: Statistics for Victoria 30 June 2011
Victorian Civil and Administrative Red Dot Decision Summary Decision Tribunal 15
December 2009
Victorian Auditor-General Taking Action on Problem Gambling Report 28 July 2010
Vitoellone Nicole, Habitus and Social Suffering Culture, Addiction and the Syringe in
Feminism after Bourdieu he Editorial Board of Sociological Review 2004, Blackwell
Publishing
Yarra Ranges Shire Council Yarra Ranges Planning Scheme Amendment C77 Gaming
Policy Panel Report April 2010
Gambling Discussion Paper
50
Maribyrnong City Council
End Notes
Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission, February 2010, p 16.6
2 Victorian Commission for Gambling Regulation Annual Report 2009-2010 Appendix
16.
3 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission, February 2010 p 15.3
4 ibid
5 ibid
6 ibid
7 ibid
8 NBNCo Limited http://www.nbnco.com.au/
9 Victorian Commission for Gambling Regulation (VCGR) Statistical Data Fact Sheet
Electronic Gaming Machines: Statistics for Victoria 30 June 2011
10 Gambling Regulation Act 2003 Victorian Law Today Library, p 335.
11 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission, February 2010 p 11.8
12 Ibid p 47
13 Victorian Commission for Gambling Regulation (VCGR) Metropolitan Melbourne
14 Ibid.
15 Victorian Commission for Gambling Regulation (VCGR) City of Maribyrnong Current
Venues
16 Red Dot Decision Summary Victorian Civil and Administrative Decision Tribunal 15
December 2009.
17 Edgewater Gaming Facility Proposal Maribyrnong City Council website 2010
http://www.maribyrnong.vic.gov.au/Page/Page.asp?Page_Id=4016
18 Ibid.
19 Victorian Commission for Gambling Regulation (VCGR) City of Maribyrnong Current
Venues
20 Victorian Commission for Gambling Regulation (VCGR) Metropolitan Melbourne
21 Victorian Commission for Gambling Regulation (VCGR) City of Maribyrnong Current
Venues
22 ID Profile, Informed Decisions, 2010.
23 Dandenong City Council, 2010.
24 ID Profile, Informed Decisions, 2010.
25 Centrelink Australian Government March 2010.
26 ID Atlas Informed Decision 2010.
27 Ibid.
28 Ibid.
29 Maribyrnong Annual Community Survey, Maribyrnong City Council, 2008, p 74.
30 ID Atlas Informed Decision 2010.
31 Ibid.
32 Analysis made using Department of Justice Liquor Licensing website statistics for
2010.
33 A Study of Gambling in Victoria, Problem Gambling From a Public Health
Perspective, Department of Justice, Victorian Government, September 2009.
1
Gambling Discussion Paper
51
Maribyrnong City Council
34
A Review of Gambling-Related Issues, Hayden Brown, City of Greater Dandenong
2009, p 1.
35 City Greater Bendigo Gambling Policy Framework – Accessible but not convenient
Prepared by Coombes Consulting for City of Greater Bendigo October 2007 p7-8
36 Ibid.
37 Accessibility to Gaming Machines Department of Justice, Victorian Government
2010.
http://www.justice.vic.gov.au/wps/wcm/connect/DOJ+Internet/Home/Gambling+a
nd+Racing/Responsible+Gambling/JUSTICE+-+Accessibility+of+Gaming+Machines
38 A Review of Gambling-Related Issues, Hayden Brown, City of Greater Dandenong
2009, p 36.
39 Community Benefit Statements: A new direction Information Paper, Office of
Gaming and Racing June 2007, p 3.
40 Community Benefit Statements New Ministerial Order 2008 Department of Justice
41 ibid p37
42 ibid p 38-39
43 ibid p 39
44 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission, February 2010 p 47
45 ibid Section 5.26
46 A Study of Gambling in Victoria, Problem Gambling From a Public Health
Perspective p 14
47 Ibid.
48 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission, February 2010 p2
49 ibid p 11.16
50 Ibid.
51 Habitus and Social Suffering. Culture, Addiction and the Syringe Nicole Vitoellone
in Feminism after Bourdieu The Editorial Board of Sociological Review 2004,
Blackwell Publishing.
52 Productivity Commission Inquiry Report into Gambling Volume 1, Australian
Government Productivity Commission Chapter 12 Venue Activities.
53 ‘Playroom at Pokie Venue Under Fire’ ABC News 28 July 2010.
54 Productivity Commission Inquiry Report into Gambling Volume 1, Australian
Government Productivity Commission p 12.45.
55 Ibid.
56 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission.
57 A Review of Gambling-Related Issues, Hayden Brown, City of Greater Dandenong
2009, p 31.
58 A Study of Gambling in Victoria, Problem Gambling From a Public Health
Perspective p 139.
59 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission, February 2010 p 5.25.
60 A Study of Gambling in Victoria, Problem Gambling From a Public Health
Perspective.
Gambling Discussion Paper
52
Maribyrnong City Council
61
A Review of Gambling-Related Issues, Hayden Brown, City of Greater Dandenong
2009.
62 ibid p 21.
63 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission, February 2010 p 7.15.
64 A Study of Gambling in Victoria, Problem Gambling From a Public Health
Perspective.
65 A Study of Gambling in Victoria, Problem Gambling From a Public Health
Perspective.
66 Victorian Commission for Gambling Regulation (VCGR) Statistical Data Fact Sheet
Electronic Gaming Machines: Statistics for Victoria 30 June 2011
67 Problem gambling among those seeking homelessness services, Australian Institute
of Health and Welfare Canberra, November 2009.
68 Exploring the link between family violence and Problem Gambling Community
West July 2007.
69 Taking Action on Problem Gambling Victorian Auditor-General’s Report 28 July
2010 p 5.
70 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission p 7.17.
71 ibid pp 47-66.
72 Productivity Commission Report into Gambling, Assistant Treasurer, Senator the
Hon Nick Sherry, Joint Media Release with The Hon Jenny Macklin MP Minister for
Families, Housing, Community Services and Indigenous Affairs and Senator the Hon
Stephen Conroy Minister for Broadband, Communications and the Digital Economy
23 June 2010
http://assistant.treasurer.gov.au/DisplayDocs.aspx?doc=pressreleases/2010/138.h
tm&pageID=089&min=njsa&Year=&DocType=0
73 Wilkie Wins Pledge to Reform Pokies Kristy Needham, theage.com.au, September
3, 2010 http://www.theage.com.au/federal-election/wilkie-wins-pledge-toreform-pokies-20100902-14ro1.html
74 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission, p 7.17.
75 Taking Action on Problem Gambling: A strategy for combating problem gambling
in Victoria, Department of Justice 2006.
76 ‘Gaming Venues to Become ATM Free Zones’ Department of Justice Media Release
13 July 2009
http://www.justice.vic.gov.au/wps/wcm/connect/DOJ+Internet/Home/About+Us/
Media+Room/News+Archive/JUSTICE+-+Gaming+Venues+to+become+ATMFree+Zones+-+(News)
77 Productivity Commission Inquiry Report into Gambling, Volume 1, Australian
Government Productivity Commission p 7.18 – 7.19.
78 Electronic Gaming Machine (Pokies) Community Policy Macedon Ranges Shire
Council 2009.
79 Issues Paper – Gaming in the City of Moreland DRAFT for the development of a
Moreland policy position on gaming Moreland City Council May 2010 p 2.
Gambling Discussion Paper
53
Maribyrnong City Council
80
Greater Geelong Planning Scheme Amendment C168 Gaming Policy Panel Report
February 2010 p30-35.
81 Yarra Ranges Planning Scheme Amendment C77 Gaming Policy Panel Report Yarra
Ranges Shire Council April 2010 p 19-20.
82 Electronic Gaming Machine (Pokies) Community Policy Macedon Ranges Shire
Council 2009 p 9-12.
83 Amendment C64 Local Gaming Policy Macedon Ranges Shire Council 2009
http://www.mrsc.vic.gov.au/Page/Page.asp?Page_Id=2146&h=1
84 Amendment C64 List of changes to Macedon Ranges Planning Scheme, Macedon
Ranges Shire Council 2009.
85 Gaming Machines Refused at Romsey Hotel Macedon Ranges Shire Council Media
Release 12 November 2009
http://www.mrsc.vic.gov.au/Files/PokiesDecision_RomseyNov09.pdf
86 Hume Planning Scheme Clause 22.1, Hume City Council, 12 March 2009.
87 Gaming Policy and Statement of Practice Maroondah City Council February 2007.
88 City Greater Bendigo Gambling Policy Framework – Accessible but not convenient
Prepared by Coombes Consulting for City of Greater Bendigo October 2007.
89 City of Greater Bendigo ‘Accessible but not Convenient Policy’ City of Greater
Bendigo website http://www.bendigo.vic.gov.au/Page/Page.asp?Page_Id=2452
90 Draft Responsible Gaming Strategy 2010-2014 Moreland City Council June 2010.
91 Darebin Electronic Gaming Machine Policy and Strategic Action Plan City of
Darebin 2010.
Gambling Discussion Paper
54