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Pdf 325.9 Kb This is the response of the Australian Hotels and Hospitality Association Inc to the Productivity Commission's issues paper on Australia's gambling industries. This response addresses most of the questions raised by the Commission in the issues paper and generally follows the format of the issues paper. For ease of referral, there is a detailed list of the questions addressed in the response paper included as the contents pages of this paper. Also included with this response paper is a copy of the oral address made by the officers of the Association to the Productivity Commission during the hearings in Melbourne. We are grateful to the Commission for the opportunity to lodge this submission. We are available to answer any queries that any person may have in respect hereto. Please contact myself or Margaret Kearney at our Malvern office at any time. ALAN GILES CHIEF EXECUTIVE OFFICER I CONTENTS Chapter 1 1 THE NATURE AND DEFINITION OF GAMBLING 1 ? What constitutes gambling?............................................................................... 1 1. GAMING 1 2. BETTING AND WAGERING 1 3. SPECULATION 1 ? What should the Commission include as gambling in its inquiry?.................... 2 ? What are the characteristics of gambling that call for community or government action that is different to that for other activities?..................... 3 Chapter 2 6 THE INSTITUTIONAL CONTEXT – REGULATION 6 ? What are the detailed regulations applying in each state? What are their rationales? ........................................................................................... 6 CASINO 6 ELECTRONIC GAMING MACHINES 6 INTRODUCTION OF GAMING MACHINES 7 MORATORIUM 7 GAMING OPERATORS 8 LICENSED VENUE OPERATORS 9 OTHER LICENSEES UNDER THE GAMING MACHINE CONTROL ACT 10 50:50 RULE - TATTERSALLS AND TABCORP 10 80:20 RULE 10 50:50 RULE - CLUBS AND HOTELS 10 II RESTRICTED AND UNRESTRICTED AREAS 11 ♦ Restricted area 11 ♦ Unrestricted area 12 MAXIMUM NUMBERS OF MACHINES AT ANY ONE VENUE 12 TOWN PLANNING 12 FINANCIAL AND BANKING RECORDS 13 RETURNS TO PLAYERS 13 THE BREAK UP OF THE GAMING DOLLAR 14 ? Do the regulations achieve their intended outcomes?...................................... 14 ? What are the lessons for policy from the arrangements that exist in [the Victorian] jurisdiction, and has any government implemented a preferred regime?..................................................................... 18 ? Are current regulations governing gambling appropriate? What changes should be made and how should they be introduced?........................ 19 ? How should regulations be administered? ....................................................... 20 ? What are the compliance burdens associated with the existing regulations?...................................................................................................... 20 ? Would there be gains from harmonising regulations across Australian jurisdictions or across different gambling types? ........................... 21 ? What is the appropriate role for government, if any, in the promotion and advertising of gambling? ......................................................... 21 ? Is information disclosure adequate, and if not, what is the appropriate nature and extent of disclosure?................................................... 21 ? How effective are regulatory controls and oversight mechanisms at dealing with risks [of criminal activity]?...................................................... 22 TAXATION 22 ? To what extent are [the stated] arguments a valid basis for higher taxes on gambling? To what extent do the regulatory and taxation regimes interact?.............................................................................................. 22 ? What is the appropriate way of determining the right level and form of gambling taxes? .................................................................................. 23 III ? Should different forms of gambling be taxed differently? ............................... 24 ? What is the impact of gambling taxation on gamblers?................................... 24 ? Should part of the revenue for gambling be earmarked for particular purposes, and if so, for what purposes?........................................... 24 ? Is the current process of distributing earmarked funds appropriate and effective? Are the mechanisms suitably open, well-understood and subject to accountability requirements? Are they an improvement on normal government budget processes?.................................. 26 Chapter 3 27 WHO GAMBLES AND WHY?27 ? What research and information in this area is most instructive?..................... 27 ? What additional research would be warranted?............................................... 27 Chapter 4 28 BENEFITS AND COSTS TO INDIVIDUALS 28 ? What is the nature and extent of the benefits that individuals receive from gambling?.................................................................................... 28 ? How do such benefits differ between different groups (for example, among people of different ages, gender, income ethnicity)? ........................................................................................................ 29 COSTS TO INDIVIDUALS 29 ? What is problem gambling? ............................................................................. 29 ? How big a problem is [problem gambling]? How many Australians are problem gamblers? ................................................................. 31 ? How enduring is the problem for an affected gambler? What are the costs and other impacts for the problem gambler?..................................... 32 ? How many others are affected by problem gambling? What are the effects on the problem gambler’s family or the community more generally?................................................................................................ 33 ? How should we go about measuring these costs in a meaningful way and are there useful existing estimates in Australia or overseas? .......................................................................................................... 33 IV ? What are the appropriate methods for determining the numbers of problem gamblers, and their social impacts? Is the South Oaks Gambling Screen from the USA a useful instrument for identifying problem gambling in Australia? .................................................... 34 ? What is the nature of the problems affecting people at different points along this continuum [of severity of problem gambling]?..................... 34 ? What is the nature of people’s transitions from one state of problem gambling to another? Is it possible to identify those on the path to chronic and severe problem gambling from those who are not? ............................................................................................................ 34 ? What is the nature of each specific [gambling related] problem and how can it be measured?........................................................................... 34 ? What are the behaviours of problem gamblers (in terms of frequency of play, typical expenditure, motivations, type of play, social interactions with others?)....................................................................... 35 ? To what extent do people with a gambling problem suffer from deeper underlying problems, of which gambling is only a symptom? To what extent is problem gambling associated with other problems?................................................................................................ 37 ? How much of total expenditure on gambling is accounted for by people with gambling problems?...................................................................... 37 ? Does problem gambling affect some groups more than others? What is the evidence of this?............................................................................ 37 ? Is it more difficult to detect or treat problem gambling within particular groups? What implications would any differences between groups of problem gamblers have for the design or implementation of policies aimed at the prevention or management of problem gambling? ................................................................ 38 ? What is the evidence that some forms of gambling are more addictive than others? ...................................................................................... 38 ? Are there features of gambling technology which are designed specifically to encourage high levels of gambling?.......................................... 39 ? What is the nature and extent of behaviour [which intensifies problem gambling]?......................................................................................... 39 ? To what extent [is there pressure on venues to maximise turnover to ensure continued tenure of machines]?....................................................... 40 V ? Are there consumer issues which may produce costs for individuals - for example pressure selling, misleading advertising or other practices?............................................................................................ 40 DEALING WITH PROBLEM GAMBLING 40 ? The Victorian self exclusion program for pubs and clubs? ............................. 41 ? Codes of Practice.............................................................................................. 42 ? Are there aspects of the codes of practice which should be in regulation?......................................................................................................
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