ME_138349545_1

IN THE VICTORIAN CIVIL AND ADMINISTRATIVE TRIBUNAL

FILE NUMBER: P2665-2016

DATE: 13-16, 19 AND 22 JUNE 2017

APPLICATION FOR APPROVAL OF PREMISES FOR GAMING, COMMERCIAL HOTEL, 820 PLENTY ROAD, SOUTH MORANG

AUSTRALIAN LEISURE AND HOSPITALITY GROUP PTY LTD (ALH),

APPLICANT

INSTRUCTED BY MINTER ELLISON, RIALTO TOWERS,

525 COLLINS STREET, MELBOURNE VIC 3000

STATEMENT OF ROSE GABRIELLE SALTMAN

Rose Gabrielle Saltman, of 3 Holt Avenue, Mosman, NSW 2088.

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Contents 1. BACKGROUND ................................................................................................................................. 1

1.1 Qualifications and experience..................................................................................................... 1

1.2 Instructions ................................................................................................................................. 1

1.3 Conflict of Interest ...................................................................................................................... 1

2. SCOPE OF THIS SOCIAL IMPACT ASSESSMENT ................................................................................ 2

3. SITE CONTEXT .................................................................................................................................. 3

4. EXISTING HOTEL OPERATIONS ........................................................................................................ 4

5. PROPOSAL DETAILS ......................................................................................................................... 5

5.1 Package of upgrades ................................................................................................................... 5

5.2 Proposed harm minimisation measures ..................................................................................... 5

6. SOCIO-DEMOGRAPHIC CHARACTERISTICS ...................................................................................... 7

6.1 Catchment or local community of the hotel ............................................................................... 7

6.2 Socio-demographic profile of the local community.................................................................... 8

7. ASSESSMENT OF SOCIAL IMPACT ................................................................................................. 11

7.1 Improved facilities that add to the appeal of the hotel ............................................................ 11

7.2 Increased gaming opportunities for those who enjoy gaming ................................................. 13

7.3 Increased contributions ............................................................................................................ 14

7.4 Possibility of increased incidence and impact of problem gambling on community ............... 15

7.4.1 Problem gambling in the City of Whittlesea ..................................................................... 15

7.4.2 Future problem gamblers arising from the proposal ........................................................ 16

7.5 Community attitude .................................................................................................................. 19

7.5.1 Online community survey ................................................................................................. 20

7.5.2 Individual submissions ...................................................................................................... 20

7.5.3 Council consultation with community organisations ....................................................... 21

7.5.4 Community organisation submissions .............................................................................. 21

7.5.5 Additional consultation ..................................................................................................... 22

7.5.6 Consultation with community organisations .................................................................... 22

7.6 Increase in gambling-related crime and social disturbance ..................................................... 25

7.7 Increased exposure of children to gambling activity ................................................................ 27

8. ASSESSMENT OF NET DETRIMENT OR BENEFIT OF THE APPLICATION ......................................... 29

9. REFERENCES .................................................................................................................................. 30

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1. BACKGROUND

1.1 Qualifications and experience I hold qualifications in the arts, urban planning, social impact, business administration and writing. My curriculum vitae is attached to this Statement as Annexure 1. I have more than 35 years’ experience as an urban planner working in local and state government, and in consulting. I have approximately 25 years’ experience in social planning and impact assessment. I have carried out community needs assessments for brown and greenfield sites, and prepared social impact assessments of retail, retirement housing, student accommodation, leisure and entertainment, transport, education, liquor and gaming applications.

Between 2001 and 2006, I conducted eight Class 21 Social Impact Assessments (SIA) of electronic gaming machine (EGM) proposals for applicants in New South Wales; this was under the then provisions of the Gaming Machines Act 2001 and Gaming Machines Regulation 2002. I have also acted for an objector to a proposal for increased EGMs in Canley Heights, an outer Sydney suburb, in the then Licensing Court of New South Wales. More recently, I have been retained by objectors in relation to the proposed increase of EGMs in Campsie, a middle-ring Sydney suburb; in this regard, I have prepared two reports for submission to the Independent Liquor and Gaming Authority NSW, in 2015 and 2016, and am currently preparing a third.

1.2 Instructions I have been instructed to provide an expert opinion on the social impacts of the proposed upgrade of facilities, including the provision of 40 EGMs, at the Commercial Hotel, 820 Plenty Road, South Morang. I have read and understood Practice Note – PNVCAT2 relating to providing evidence in the Victorian Civil and Administrative Tribunal (Tribunal). I have made all the inquiries that I believe are desirable and appropriate and no matters of significance which I regard as relevant have, to my knowledge, been withheld from the Tribunal.

1.3 Conflict of Interest I do not have any private or business relationship with Australian Leisure and Hospitality Group Pty Ltd (ALH).

1 Clause 33 of the Gaming Machines Regulation 2002 previously required that a Class 2 SIA be prepared in all cases other than removal of a hotelier’s licence and transfer of poker machine entitlements to other premises within one kilometre of the previous premises and where the number of approved EGMs was no more than the number kept in the previous premises http://www.legislation.nsw.gov.au/~/view/regulation/2002/191/historical2006-12-22/part3/div3/sec33 viewed on 2 May 2017.

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2. SCOPE OF THIS SOCIAL IMPACT ASSESSMENT Section 3.3.7(1)(c) of the Gambling Regulation Act 2003 (the Act) provides that the Victorian Commission for Gambling and Liquor Regulation (Commission) must not grant an application for approval of premises as suitable for gaming unless satisfied that the net economic and social impact of approval will not be detrimental to the well-being of the community of the municipal district in which the premises are located. The ‘no net detriment test’ is also the test for the Tribunal. Social impact can be defined as ‘the net effect of any activity on a community and the well-being of individuals and families.’2 In the context of gaming machines, the Court of Appeal defined social impact to mean ‘the impact on the society or community (or some part or parts of it) in which the gaming machines are proposed to be located.’3 In the absence of any guidelines under the Act, it is up to the expert to determine a methodology for assessing the social impacts of gambling. This necessarily results in widely divergent methodologies, an outcome which can be further influenced by the broad nature of some of the concepts encompassed in the ‘no net detriment’ test e.g. ‘well-being’.4 This statement of evidence is concerned mainly with the consideration of social impacts, noting that other experts will be giving evidence on economic impacts and planning matters. In preparing evidence, I have relied on the following:

Observations made on a site visit

Details of the proposal

Background reports prepared on behalf of the applicant and objectors

The views of the community and key stakeholders as expressed in objections and targeted consultations

Relevant literature on gambling

Available data on gambling-related social impacts

Indicators frequently used to assess the risk for problem gambling

Relevant decisions of the Commission and its predecessor, the Victorian Commission for Gambling Regulation; the Tribunal, and the Court of Appeal.

On 27 February 2017, I visited the Commercial Hotel and its immediate surrounds. On the same day, I also visited the following premises in the Whittlesea Local Government Area (LGA):

Excelsior Hotel, 82 Mahoneys Road, Thomastown

Epping Plaza Hotel, Cooper Street, Epping

Plough Hotel, Childs Road, Mill Park

Bundoora Taverner Hotel, 49 Plenty Road, Bundoora

Bridge Inn Hotel, 1425 Plenty Road, Mernda.

2 Centre for Social Impact http://www.csi.edu.au/about-social/ viewed on 10 April 2017. 3 Supreme Court of Victoria Macedon Ranges Shire Council v Romsey Hotel Pty Ltd and Victorian Commission for Gambling Regulation 3703 of 2007, 19 March 2008, paragraph 43. 4 Ibid. paragraph 43.

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3. SITE CONTEXT The Commercial Hotel is located at the intersection of Plenty, McDonalds and Gorge Roads in the suburb of South Morang in Whittlesea LGA. The hotel consists of a double-storey building, whose façade is the only remnant of the original 1890 building. The following facilities are at ground level:

Public bar with pool tables and a dining area that flows onto an outdoor beer garden

Bistro with adjoining children’s play area

Adjoining the public bar, a TAB room that can be used for functions for up to 500 people

A drive-through BWS bottle shop that is linked to the hotel by a covered breezeway. There is also a stand-alone Dan Murphy store at the north-eastern end of the site.

To the west of the site is a former Masters store and, to the south-west, a mixed use bulky goods retailing and office development. To the south is a retail and commercial strip with several convenience shops. To the east, fronting Gorge Road, is recently completed medium density housing; at the time of inspection, more housing was under construction to the rear of that site.

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4. EXISTING HOTEL OPERATIONS The hotel is a local meeting place as well as a venue for entertainment, functions, conferences and the like. The hotel’s current hours of operation are as follows:

Public bar and TAB room: 12pm to 10pm from Sunday to Thursday, 12pm to 1am on Friday and Saturday

Bistro: 11.30am to 3pm and 5.30pm to 9pm every day. Periodically the hotel offers discounted food and entertainment packages e.g. Recycled Melodies, a monthly show accompanied by morning tea or morning tea and lunch. The following events for May-June are listed on the hotel’s website:5

8pm 12 May: Coverboys performing Cover to Cover

8pm 13 May, 8pm: Rod Stewart Tribute Show

8pm 27 May: Tribute to Cold Chisel

10.30-11.30am 31 May: Recycled Melodies – Andrew Portelli: Elvis and friends

8pm 10 June: Bon Jovi Tribute

8pm 24 June: Rewind the 80s

10.30-11.30am 28 June: Recycled Melodies – Col Perkins: John Denver Tribute. Admission to the Coverboys show starts at $35. Entry is free to all other shows. $20 covers a two-course dinner with a glass of wine for the Rod Stewart Tribute Show, while $5 and $15 cover morning tea, and morning tea and lunch respectively for each of the Recycled Melodies shows. The venue manager has advised that performances generally attract about 300 attendees. 6 These will be able to be accommodated in the proposed function space, noting that it can take 320 patrons standing – see Section 5.1. The hotel currently contributes to several sporting clubs, including the South Morang Football Club and the Diamond Valley Eagles. Between June 2014 and February 2016, sponsorships and donations to local organisations amounted to almost $11,000, distributed to the following recipients:

South Morang Football Club: $6,744

Diamond Valley Eagles Basketball Club: $1,619

Heat Netball Club: $887

The Winged Dragon Martial and Healing Arts Club: $766

Rhythm Nation Dance Studio: $500.7 In-kind contributions have included free function room hire and discounted food and beverages for club events.

5 https://www.commercialsouthmorang.com.au/ viewed on 29 April 2017. 6 Personal communication 1 May 2017. 7 Commercial Hotel, South Morang Social and economic impact assessment Urbis May 2016 page 9.

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5. PROPOSAL DETAILS

5.1 Package of upgrades The proposed package of upgrades to the Commercial Hotel includes the following:

Modification to the TAB and bar area to provide an enclosed space for the proposed gaming room

Upgrading the remainder of the TAB and bar area to provide a sports bar

Conversion of the existing BWS bottle shop into a 305m2 function room, with toilets, bar and main entrance opening to the north of the site. This function room will be able to accommodate 200 patrons seated and 320 standing

Conversion of 431m2 of roof space on the northern side of the building, to provide an al fresco bar and beer garden. This will be connected to the ground floor via a lift and staircase. Part of this space will be capable of being used for functions. Capacity of the rooftop beer garden is approximately 150 patrons.

The proposed gaming room’s operating hours are from 10am to 1am on Monday to Saturday, 10am to 11pm on Sunday, and 12 noon to 11pm on Good Friday and ANZAC Day. In all other respects, existing operating hours remain the same. The upgrade will improve existing facilities and provide new ones – beer garden and function room – for local residents’ enjoyment and entertainment. These works will improve the ability of the venue to cater for events and, with the upstairs beer garden, provide a better facility for social gatherings. As part of the proposal, the applicant would contribute the following:

(a) For a period of 10 years from the date of commencement of operation of EGMs at the Premises, contribute an additional $100,000 per annum to be allocated as follows: (i) $40,000 to the Council for problem gambling initiatives; and (ii) $60,000 to be allocated to a committee, made up of two representatives of the

Premises and two representatives from the Council (Committee) for the benefit of local community organisations, and

(b) After the first 10 years of EGM operation, contribute $25,000 per annum to be allocated by the Committee for as long as the EGMs are operating at the Premises.’

The amount of $100,000 per annum was considered to be an appropriate figure, taking into account the level of contributions made by other venues. An advertisement would be placed in the local newspaper asking local community organisations to apply for funding. The Committee would meet on a regular basis to review applications and allocate grants.

5.2 Proposed harm minimisation measures Some of the Applicant’s harm minimisation measurements are embodied in its Responsible Gambling Code of Conduct.8 Some of the key features of this Code include:

Use of a responsible gambling ambassador: former AFL footballer and media identity, David Schwarz, provides employee education and customer awareness about the importance of responsible gambling

Responsible gambling message: a message acknowledging the venue’s responsibility to the highest standards of customer care and responsible gambling, ensuring that customers are

8 November 2016.

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well informed about gambling, and that the venue provides a safe and supportive environment with timely and appropriate assistance and information – will be displayed at the entrance to the gaming room and/or at the cashier’s station in the gaming room and at the Keno sales terminal in any venue where Keno is sold

Responsible gambling information: information will be made available on how to gamble responsibly and make and keep a pre-commitment decision, the chances of winning, availability of support services, payment of winnings policy, prohibition on the provision of credit or lending of money for gambling, and the venue’s self-exclusion program

Pre-commitment strategy: customers who play EGMs are encouraged to participate in the YourPlay program and set a time and loss limit according to their circumstances

Interaction with customers: a nominated Responsible Gambling Officer is always available when the venue is open; this person is required to ensure that any customer asking for information or assistance with problem gambling or self-exclusion is provided with it

Interaction with staff: ALH staff are not allowed to gamble at a venue in which they are employed. David Schwarz is available to staff to discuss any problems they or their family or friends may have with problem gambling

Prohibition on gambling by minors: signs will be displayed at every gaming room entrance banning minors from entering the room. Proof of age will be requested where there is uncertainty

Gambling environment: having regard to the fact that intensive playing of EGMs is a significant risk factor for problem gambling, customers will be encouraged to take regular breaks from gaming machine play.

This Code was recently independently assessed to have complied with the Commission’s best practice for the implementation of Responsible Gambling Codes of Conduct and self-exclusion programs.9

9 PVS Australia Pty Ltd Australian Leisure and Hospitality Group Pty Ltd Responsible Gambling Code of Conduct Review Report 9 November 2016.

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6. SOCIO-DEMOGRAPHIC CHARACTERISTICS

6.1 Catchment or local community of the hotel A premises’ catchment or local community includes those people and groups most likely to benefit or suffer harm from the provision of a gaming venue in those premises. There is evidence to suggest that EGM players seek out venues that are close to home:

The 2003 Victorian Longitudinal Community Attitudes Survey found that the majority of Victorian EGM players did not travel out of their local area to access the machines. More than 57% of players travelled less than 5 kilometres to the venue where they last played machines, and 32.3% travelled less than 2.5 kilometres10

The City of Whittlesea’s Gambling Strategy and Action Plan 2014 to 2024 cited a study by the Department of Justice that ‘found that 53.74% of EGM players travelled no further than 5 kilometres to a gambling venue, indicating that most people do not travel very far to access venues.’ The Strategy also cited research that shows ‘that 90 percent of residents in Metropolitan Melbourne reside within 2.5 kilometres of a gambling venue (club or hotel), and 83 percent of players travel directly from home to a gaming venue’11

A survey of 1,053 bistro patrons at the Commercial Hotel undertaken in January and February 2016 found that about 55% came from the suburbs of South Morang, Doreen and Mill Park12

Surveys of EGM players undertaken in January and February 2016 at the Plough, Excelsior and Bundoora Taverner Hotels, found that more than 50% of players either lived in the suburb in which the venue is located, or in that particular suburb and adjacent suburbs. 13

A benchmark that locates the majority of EGM users within a radius of 2 to 5 kilometres of a venue, has been supported in previous judgments of the Commission.14 Regarding the subject Application, the Commission agreed that the most appropriate catchment for the premises should include the Statistical Area Level 2 (SA2s) of South Morang, Mill Park North and Mill Park South.15 During March and April 2017, Taverner Research (Taverner Surveys) undertook surveys of 202 bistro patrons at the Commercial Hotel and 400 members of the general community. The survey of bistro patrons shows that 54% came from the suburbs of South Morang, Doreen, Mernda and Mill Park.16 This reconfirms the appropriate catchment for the premises as comprising the SA2s of South Morang, Mill Park North and Mill Park South.

10 Centre for Gambling Research, Australian National University Gambling Research Panel Report 6, 2004, page 19. 11 City of Whittlesea, page 32 12 Cited in Urbis, op.cit. page 7. At least 9% of those surveyed lived outside the Whittlesea LGA. 13 Ibid. pages 29-30. 14 For example: Victorian Commission for Gambling Regulation Approval of premises at Bridge Inn Hotel, Mernda, as suitable for gaming with forty (40) gaming machines 30 September 2011, number 13; Victorian Commission for Gambling and Liquor Regulation Application…to vary the number of electronic gaming machines at the approved venue…from forty (40) to sixty (60) gaming machines, 11 November 2014, footnote 7 to number 17. 15 Victorian Commission for Gambling and Liquor Regulation Application by Australian Leisure and Hospitality Group Pty Ltd…for approval of the premises, the Commercial Hotel…as suitable for gaming with forty (40) electronic gaming machines, 8 December 2016, number 36. 16 Taverner Research Commercial Hotel, South Morang Market Research 3 May 2017.

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6.2 Socio-demographic profile of the local community To assess the extent of population in the local community that may be ‘at risk’ of becoming problem gamblers, I have reviewed socio-demographic indicators commonly used by the Commission and others17 to assess such risk. The SA2s of South Morang, Mill Park North and Mill Park South are compared with the City of Whittlesea and, where applicable, Greater Melbourne. Data is sourced from the 2011 Census of Population and Housing unless otherwise stated. At 2011, the population of South Morang was 38,321 compared with 18,236 in Mill Park North, 12,284 in Mill Park South and 3,999,982 in Greater Melbourne. The City of Whittlesea has been subject to rapid population increase, with an annual growth rate of 4-5% in estimated residential population. South Morang is the fastest growing SA2 in Australia, with growth rates of 8% per annum over the last three years. This compares with almost nil growth in Mill Park North, -1% in Mill Park North and 2% in Greater Melbourne over the past three years.18 A socio-demographic profile of the local community is summarised below. Table 1: Socio-demographic profile of local community

Indicator South Morang

Mill Park North

Mill Park South

Whittlesea LGA

Greater Melbourne

Male 49% 49% 49% 50% 49%

Female 51% 51% 51% 50% 51%

Median age 30 36 35 34 36

18-34 28% 24% 27% 26% 26%

65+ 5% 8% 9% 11% 13%

Indigenous population 0.62% 0.65% 0.69% 0.73% 0.45%

Australian born 76% 65% 63% 62% 63%

Speaks English only at home

73% 55% 56% 53% 66%

Couple only households Couple households with children Single parent households

17% 71% 11%

15% 72% 12%

18% 65% 16%

19% 66% 14%

23% 62% 13%

Completed year 12 schooling

56% 53% 52% 49% 57%

Unemployment 2011 December 201619

4% 4.5%

5% 4.8%

6% 6.1%

6% 6.2%

5%

Employed as professionals, technicians and trade workers, clerical or administrative workers

72% 67% 66% 66% 74%

17 See, for example, Victorian Responsible Gambling Foundation Risk factors for problem gambling: environmental, geographic, social, cultural, demographic, socio-economic, family and household May 2015; Sproston, K., Hing, N. & Palankay, C. Prevalence of Gambling and Problem Gambling in New South Wales April 2012. 18 ABS 3218.0 Regional Population Growth Australia. 19 Department of Employment Small Area Labour Markets Australia December Quarter 2016

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Indicator South Morang

Mill Park North

Mill Park South

Whittlesea LGA

Greater Melbourne

Employed as sales workers, machinery operator/driver or labourer

26% 31% 31% 31% 24%

Median weekly household income

$1,643 $1,408 $1,317 $1,275 $1,333

Median weekly rent $350 $301 $300 $300 $300

Median monthly mortgage repayment

$2,113 $1,600 $1,517 $1,863 $1,810

Households in mortgage stress20

13.7% 2.9% 2.6% 6.9% 3.4%

Households in rental stress 4.9% 5.0% 4.1% 5.4% 6.8%

SEIFA Index of relative socio-economic advantage and disadvantage Index of relative socio-economic disadvantage Index of economic resources Index of education and occupation

1056 1063 1090 1000

1016 1030 1042 973

993 1004 1009 970

983 989 1020 955

The Commission accepted that the VAMPIRE Index – a measure that assessed socio-spatial structure of vulnerability from rising transport and housing costs for capital cities in 2011 – as indicative of above levels of mortgage stress in the premises’ catchment and therefore an increased vulnerability of residents to gambling-related harms.21 Twelve months of aggregated data on household stress was provided by Digital Finance Analytics by postcodes in Whittlesea LGA and Greater Melbourne. The data, which is to March 2017, is represented below. ‘Mild stress’ means that households are paying their mortgages, but under duress; ‘severe stress’ means that they cannot and are already in default, or trying to sell. Postcodes in red overlap the local community of the hotel. Table 2: Households stress data by postcodes in Whittlesea and for Greater Melbourne22

20 Housing stress arises when households whose gross income falls in the lowest 40% of the income

distribution are paying more than 30% of their household income to meet housing costs; or the (larger) group of households who have gross incomes below 120% of the median income and who are paying more than 30% of their household income to meet their housing costs. NSW Centre for Affordable Housing http://www.housing.nsw.gov.au/centre-for-affordable-housing/nsw-local-government-housing-kit/glossary-references-and-additional-resources viewed on 1 May 2017. The data on households in rental and mortgage stress has been supplied by Urbis. 21 December 2016, paragraph 115. 22 Digital Finance Analytics 2017, based on 52,000 sample survey to March 2017.

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PC Average of PD23

% Households in Severe Stress

% Households in stress

% Households borrowing

Number of Borrowing Households

3064 1.52% 1.19% 22.62% 63.0% 12,550

3074 1.10% 0.00% 14.29% 24.0% 1,666

3076 1.16% 0.00% 33.33% 48.6% 5,278

3082 1.17% 0.00% 14.71% 42.9% 5,444

3083 1.36% 0.00% 36.84% 35.4% 4,039

3750 1.57% 0.00% 0.00% 46.9% 329

3752 1.62% 0.00% 28.57% 61.4% 5,291

3753 1.55% 0.00% 50.00% 51.4% 233

3754 1.62% 0.00% 39.53% 71.4% 6,544

3757 1.67% 0.00% 66.67% 47.2% 1,558

Melbourne 1.76% 3.78% 18.82% 35.60% 608,651

Low counts in 3750 and 3753 should be treated with caution.

This data shows that no households in the local community are in severe housing stress. Two of the postcodes show higher than Melbourne rates of households in stress (28.57% in 3752 and 39.53% in 3754), while the third, 3082, shows a lower rate (14.71%). The percentage of households borrowing in these two postcodes (61.4% and 71.4%) is also significantly higher than the Melbourne average. Mernda and Doreen (3754) and South Morang (3752) are popular with first-home buyers.24 These buyers are, however, not all necessarily disadvantaged. Note that, for example, the percentage probability of default in these suburbs is lower than the Melbourne average; in Mill Park (3082), it is significantly lower. Overall, the local community of the Commercial Hotel exhibits the characteristics of an advantaged area with a low risk for problem gambling. The exception is in its partial vulnerability to mortgage stress; to the extent that this may be a risk factor, it is concentrated in the newly developing residential areas of South Morang, Mernda and Doreen.

23 Probability of default in the next 12 months. 24 http://www.realestate.com.au/news/firsthome-buyers-swoop-on-south-morang-and-mernda-houses/; viewed on 3 May 2017.

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7. ASSESSMENT OF SOCIAL IMPACT

7.1 Improved facilities that add to the appeal of the hotel In respect of individual components of the proposed package, the Taverner Surveys found:

New rooftop beer garden: 82% of the general community and 92% of patrons supported the introduction of this facility. This was also ranked by 61% of the general community and 67% of patrons, as the facility that would be most used

New function room: 88% of the general community and 94% of patrons supported the introduction of a dedicated performance space

Revamped sports bar: 72% of the general community and 91% of patrons supported improvements to the sports bar.

This shows an overwhelming level of support for the improvement of existing, and addition of new facilities at the hotel. Regarding the introduction of EGMs at the hotel, the surveys found that:

26% of the general community supported EGMs, while 63% opposed and 11% did not know

42% of hotel patrons supported EGMs, 49% opposed and 9% did not know. After it had been explained that the proposed upgrades would only proceed if the EGMs were approved:

45% of the general community indicated that they supported the introduction of EGMs, 52% were opposed and 3% did not know

65% of hotel patrons indicated that they supported the introduction of EGMs, 31% were opposed and 4% did not know.

This shows that while there is still a measure of opposition to the introduction of EGMs, it reduces quite significantly when seen as part of the overall package, in particular, among hotel patrons. A view expressed by some objectors is that the loss of the current 500-person performance space is a negative outcome of the Application. This was also raised in a Social and Economic Impact Assessment of the Application, prepared by Ms Diana Bell on behalf of Whittlesea Council.25 The following factors are relevant here:

The proposed function room will be a dedicated venue for a range of uses, and more flexible than the current performance space which is constrained by having to restrict access to the bar every time a performance is held

Events hosted at the hotel attract do not attract more than 300 patrons – Section 4. The proposed function room will be able to cater to this number. It is worth mentioning here that prior to ALH purchasing the hotel, its performance venue traded until 3am and was known to have caused amenity impacts that required the police to be called out. Since owning the hotel, ALH has reduced the trading hours and made the venue family friendly. Smaller gatherings are more typical of this new focus

There are other venues in the area that can cater for large format entertainment. These include the Plenty Ranges Arts and Convention Centre, less than four kilometres from the hotel, and which has a theatre with seating for 497 persons; and the Epping RSL Club, less than nine kilometres from the hotel which has a function room that can accommodate 450 persons seated.26

25 5 July 2016, page 42. 26 http://www.pracc.com.au/theatre/theatre-hire/ and http://www.eppingclubevents.com.au/ourfacilities viewed on 2 May 2017.

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The loss of an EGM-free venue has been cited by opponents of the Application as a negative outcome because it would remove a ‘safe’ venue for people with gambling addictions. Some ventured that they would avoid the venue. The proposition that people would stay away from the hotel if EGMs were installed was tested in the community and in-venue surveys, which found that 81% of the general community and 84% of patrons would continue to visit the hotel. This demonstrates overwhelmingly that the introduction of EGMs is not viewed as a deterrent to continued patronage of the hotel. The upgrade will add new facilities to the hotel and make its current offer more contemporary. There is widespread support for introduction of the rooftop beer garden, the function space and revamped sports bar. While there is less support for the introduction of EGMs, there is no evidence to support the view that gaming will cause large sectors of the population to cease visiting the hotel. The proposed improvements to the hotel are a social benefit of the proposal that has high weight.

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7.2 Increased gaming opportunities for those who enjoy gaming The benefits of gambling include pleasure and enjoyment, having a hobby or favourite recreational activity, an opportunity to socialise with others, and the thrill of winning.27 A study into the Socio-economic impacts of access to EGMs in Victoria cited evidence that gambling can offer social support to older people due to its social nature in bringing people together, and the subsidised amenities that were available at a venue e.g. cheap meals, for a group of people who might be isolated through no longer being in the workforce.28 In relation to the subject Application, the Commission found that

…granting approval of the Application will better serve the needs of gaming patrons through

providing an additional venue at which they may choose to play EGMs.29 It considered increased gaming opportunities to be a negligible benefit on which it placed a marginal weight. The Taverner Surveys found that 19% (76) of the general community and 28% of patrons (56) reported being EGM players. Of these, 64% (48) of general community players and 88% (49) of patron players respectively indicated that they would play at the Commercial Hotel if EGMs were introduced. Support for the introduction of EGMs among players was:

48% in the general community and 68% among patrons

Greater among those aged under 35. Of the total samples, only 8% of the general community and 4% of patrons indicated that they would use the gaming room more than any other function space in the hotel. The surveys show that the introduction of EGMs at the hotel would be popular with players in the general community as well as among hotel patrons, for whom gambling provides pleasure and enjoyment. The proposal will provide an additional venue at which patrons in the local community can play EGMs. This is a benefit of the Application that has low weight.

27 Productivity Commission Inquiry Report Gambling 2010 Box 6.1, volume 1, 6.3; Livingstone, C, Rintoul, A, Francis, L ‘What is the evidence for harm minimisation measures in gambling venues?’ Evidence Base Issue 2, 2014, pp3-4; Victorian Competition and Efficiency Commission Counting the Cost: Inquiry into the costs of problem gambling 2012, page 1; Victorian Commission for Gambling and Liquor Regulation Economic and Social Impact Submission Gambling Information Kit, page 21, among others. 28 Department of Justice Socio-economic impacts of access to electronic gaming machines in Victoria 2011, page 13. 29 Paragraph 135.

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7.3 Increased contributions The generation of funds from gambling for public and community services is regarded as a benefit.30 In the subject Application, the Commission acknowledged that the proposed contributions were a social benefit of the proposal:

Having regard to the evidence and submissions made with respect to these community contributions that are set out in paragraphs 93 to 100, the Commission considers the community contributions (distributed in accordance with conditions of any approval of this Application) and the impact on local

community organisations to be a social benefit which is given low weight.31 The allocation of $100,000 annually for ten years – see discussion at Section 5.1 – represents a significant increase in the amount of support for local groups and community causes that is presently the case. It is significant that these proposed contributions received wide support from both members of the general community and hotel patrons:

87% of the general community and 96% of hotel patrons supported these contributions

This was the highest level of support shown for any of the component parts of the proposed upgrade package.

Current beneficiaries of the hotel’s contributions are supportive of the proposed package of upgrades and increased contributions – see letter from the South Morang Cricket Club at Annexure 2. The proposed contributions represent a significant increase in the amount of support for local community causes. This is a social benefit of the Application that has high weight.

30 Victorian Competition and Efficiency Commission op.cit. page 1; Department of Justice, op cit., page

12. 31 At paragraph 137.

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7.4 Possibility of increased incidence and impact of problem gambling on community

The potential for gambling harm to be associated with increasing access to EGMs is well documented in the literature.32 The Commission accepted that there was potential for negative social costs through increased access to EGMs at the hotel, and that a proportion of new expenditure on EGMs would be associated with problem gambling. It regarded the possible increased incidence and impact of problem gambling on the community as a social disbenefit of the Application, with a low to moderate weight.33

7.4.1 Problem gambling in the City of Whittlesea Gamblers Help data34 on the number of clients presenting for service in Whittlesea LGA and greater Melbourne between 1 July 2015 and 30 June 2016, shows that:

A total of 249 clients presented for service in Whittlesea LGA

3,503 clients presented for service in Greater Melbourne. At the time that it provided this data, Gamblers Help also advised that these clients:

May not be gambling in Whittlesea, or may not be doing all of their gambling in Whittlesea

However, even if they are not gambling in Whittlesea, they (the numbers) do attest to the presence of many people being at risk of severe gambling harm living in the LGA

The percentage of those people with severe gambling problems who attend formal counselling is consistently estimated to be only around 10-15 per cent of those affected.

Regardless of whether one uses the at-face-value data or inflates it, it is evident that for the year ending 30 June 2016, Whittlesea LGA had a higher percentage of population35 affected by problem gambling than Greater Melbourne, that is, 0.12% versus 0.08% respectively. Gamblers Help data is only available at the LGA level or higher. Using 2011 Census data, the City of Whittlesea Gambling Strategy and Action Plan 2014 to 2024 assessed areas within the LGA according to their populations’ propensity to gamble.36 An extract from Map 4 of the Strategy is included below, showing the location of the Commercial Hotel. Figure 1: propensity to gamble collection districts in the City of Whittlesea

32 See for example Productivity Commission op.cit. Vol 1, 14.1; VRGF op.cit. May 2015; Livingstone et al op cit. 2014 and various others. 33 Paragraphs 138 to 142. 34 Information provided by email on 7 April 2017. 35 Using estimated residential population at 30 June 2016. 36 At page 39.

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From the above, it is evident that while LGA-wide indicators for problem gambling may be higher than the Greater Melbourne average, there are wide spatial variations within the LGA. It is also evident that the area surrounding the Commercial Hotel is characterised by a medium-to-low propensity to gamble. This area, in turn, is surrounded by areas that have predominantly medium or medium-to-low propensities to gamble. This data, therefore, suggests that the population around the Commercial Hotel is less likely to contain problem gamblers or be predisposed to becoming problem gamblers.

7.4.2 Future problem gamblers arising from the proposal The Productivity Commission and others have ascribed certain characteristics to problem gamblers. For example:

The Productivity Commission noted that ‘likelihood of harm rises steeply and continuously with the frequency of EGM gambling and expenditure levels’37

37 Vol, 4.24 2010

Commercial Hotel

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The Victorian Gambling Study found that as gambling frequency (on EGMs) increased from one to three times a month to once a week or more, the proportion of problem gamblers increased from 6% to 17%38

A Study of Gambling and Health in Victoria found that, in 2014, low risk EGM players played once a month, moderate risk players played 86 times a year and problem gamblers played 88 times a year39

The Productivity Commission noted that higher risk gamblers formed a much greater proportion of people playing at night and cited research that showed an over-representation of moderate risk and problem gamblers playing EGMs after midnight.40

Within the Taverner Surveys samples, 19% of the general community (76 persons) and 28% of hotel patrons (56 persons) reported that they played EGMs. The Surveys found that:

Most of the general community – 84% – who play EGMs reported doing so about once a month or less often including 57% who said that they played less than once every three months. A total of 7% (5 persons) said that they played at least once a week

74% of hotel patrons who play EGMs said that they do so about once a month or less frequently. A total of 18% (10 persons) said that they played at least once a week

72% of the general community who play EGMs do so between 7 and 10pm, 16% play between 4 and 7pm, 14% play between 1 to 4pm, and 12% between 10pm and 1am. None reported playing after 1am

57% of hotel patrons who play EGMS do so between 7 and 10pm, 29% play between 1 to 4pm, and 14% between 10pm and 1am. Only 2% reported playing after 1am (one person)

64% of the general community and 88% of patrons said that they would play EGMs at the hotel

The majority of general community EGM players – 81% – said that they would play EGMs at the Commercial Hotel about once a month or less often, including 51% who said that they would play less than once every three months. 6% said they would play EGMS once a week or more often, which is roughly equivalent to the number of EGM players in the general community who currently play at this frequency

A majority of patron players – 71% – said that they would play EGMs at the Commercial Hotel about once a month or less often, including 24% who said that they would play less than once every three months. 20% (11) said that they would play about once a week or more often.

These surveys also found that:

Of the 48 persons among the general community who said that they would play EGMs at the Commercial Hotel, two said that this would increase their playing. One of these currently plays about once a week and the other about once a month.41 The vast majority – 96% – said that they would play at their current frequency

76% of general community players said that they would continue to play EGMs at other venues, while 15% said that they would only play at the Commercial Hotel

Of the 49 patron players who said they would play EGMs at the Commercial Hotel, six said that this would increase their playing. Of these, one plays daily, one plays about once every

38 The Victorian Gambling Study: a longitudinal study of gambling and health in Victoria 2008 – 2012 Victorian Responsible Gambling Foundation July 2014, page 22 39 Study of Gambling and Health in Victoria: Findings from the Victorian Prevalence Study 2014 Victorian Responsible Gambling Foundation 2015, pages 7-8. 40 2010 Vol 1, 30 and 14.29. 41 Taverner Research, personal communication 3 May 2017

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two weeks, two play once a month, one plays once every two to three months, and one plays less than once every three months

The availability of EGMs at the hotel would make 4% (16) of the general community and 5% (10) of hotel patrons who do not currently play EGMs, want to start playing.

It is accepted that the provision of 40 EGMs at the Commercial Hotel carries a risk of creating new problem gamblers within the community. As a proxy for estimating the extent of future problem gambling likely to arise from approving this Application, the Taverner Surveys suggest that the proportion of existing problem gamblers within the local community is small, and that the potential for the Application to result in new problem gamblers, is likely to be equally small. The local community’s generally advantaged socio-demographic profile, the hotel’s responsible service of gambling policies and reduced trading hours, are further buffers against the potential for problem gambling to arise. However, it remains that some within the community are likely to become problem gamblers if the Application were to be approved. This is a social disbenefit of the Application with a low weight.

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7.5 Community attitude The community’s views on a proposal have been acknowledged as a relevant consideration in various decisions of the Commission, the Tribunal and the Supreme Court. In Macedon Ranges Shire Council v Romsey Hotel Pty Ltd, the Supreme Court stated at paragraph 44:

…that if the approval of gaming at particular premises is likely to cause unhappiness or discontent in that community (or any parts of it) that consequence is a ‘social impact of approval’ which will be ‘detrimental to the well-being of the community’…Evidence tending to show a detriment of that kind…must, therefore, be taken into account by the decision-maker in determining whether the statutory ‘no net detriment’ test is satisfied.42

In the above case, the Shire conducted a community survey of Romsey residents – numbered over 4,00043 at the time – with one question: ‘do you support the installation of electronic gaming machines in Romsey?’ The survey had a 69% return rate. Of those who responded, 20% said they supported the installation of EGMs while 79% said they did not.44 Up until the subject Application was heard in November 2016, there had been a generally negative community attitude towards it, by way of submissions from the Council, community organisations and members of the public. The Commission noted that the Applicant had not provided evidence of community support sufficient to offset the volume of community opposition to the Application. It further noted that while there was a sustained and consistent negative community attitude to the Application, it was not comparable to that demonstrated in the Romsey case.45 During 2016, community views on the Application were received as follows:

Through an online community survey administered by Ms Diana Bell on behalf of Whittlesea Council

Through submissions to Whittlesea Council on the Planning Permit Application

Via a focus group organised by Ms Bell with representatives of six community organisations46

In submissions to the Commission from six community organisations, some of whom had also been consulted by Ms Bell.

Issues arising from this feedback are discussed below.

42 Proposal to install 30 EGMs in the Romsey Hotel Macedon Ranges Shire Council v Romsey Hotel Pty Ltd and Victorian Commission for Gambling Regulation, SC 3703 of 2007. See also, for example, application by Laurimar Tavern Pty Ltd for approval of premises Laurimar Tavern, 63 Painted Hills Road, as suitable for gaming with forty (40) gaming machines Victorian Commission for Gambling Regulation 15 March 2010, paragraph 47; Whittlesea City Council v Victorian Commission for Gambling Regulation and George Adams Pty Ltd Victorian Civil and Administrative Tribunal VCAT 534 of 2011, paragraphs 90 and 157. 43 http://www.smh.com.au/national/melbourne-life/towns-historic-gamble-against-pokies-20120206-1r1ms.html viewed on 13 April 2017. 44 http://www.austlii.edu.au/au/cases/vic/VSCA/2008/45.html viewed on 13 April 2017. 45 VCGLR December 2016, paragraphs 144, 147 and 148. 46 July 2016, page 52. The agencies were Kildonan Uniting Care, Plenty Valley Community Health, North East Primary Care Partnership, YMCA Whittlesea, Whittlesea Community Connections, Hume Whittlesea Primary Care Partnership.

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7.5.1 Online community survey This survey formed part of Ms Bell’s Social and Economic Impact Assessment of the Application on behalf of Whittlesea Council.47 It was posted on Council’s website for three weeks in June 2016 and produced 166 valid responses. Limitations of this survey include:

A low response rate

A lack of representativeness: the sample was biased towards women and against young adults. Many of the respondents were remote from the hotel

Survey bias: the questions were set up in such a way as to build negative sentiment. At the point that questions about the application were out, respondents would have already been primed to feel unsympathetic towards the proposal

There was no ‘all or nothing’ question put to respondents

The survey provided incomplete information about the Application, instead directing respondents to a link about the proposal. More than three-quarters of respondents (78%) did not know about the proposal and there is no evidence that satisfied themselves independently of its component parts.

In respect of the last point, the decision of the Victorian Commission for Gambling Regulation on an application for the approval of the Bridge Inn Hotel, Mernda, as suitable for gaming with 40 EGMs, is relevant. At paragraph 40, the Commission said:

In several previous cases we have commented that if surveys do not involve a procedure where the complete proposal which is under consideration by the Commission is put to the respondents to the survey, then the value which the Commission can attribute to the results is reduced….We recognise that there may well be many respondents to a survey who have an overall distaste for egms but who, if faced with the prospect that there will be no new facilities, such as a bistro, in the absence of egms, will indicate a preference that a proposal proceeds even with egms. In our view such respondents may well be taking the view that they will have no personal use for egms but that they will be perfectly willing to take advantage of the other facilities – a reasonable approach in our opinion.48

At page 25 of her Addendum Report49, Ms Bell acknowledged the limitations of online surveys in their ability to reach all sectors of the community. I agree with that view. The survey’s bias against the Application and its very low response rate further compromise its representativeness of community views.

7.5.2 Individual submissions Approximately 120 individual submissions were received by Whittlesea Council and forwarded to the Commission. The overwhelming majority were by way of printed form letters or electronic templates. The main social impact issues raised in individual submissions are summarised below. Table 3: social impact issues raised in individual submissions

47 5 July 2016, pages 52-62. 48 Victorian Commission for Gambling Regulation, 15 July 2009. 49 Addendum to SEIA September 2016.

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Issue Response Loss of a poker-machine free venue See Section 7.1

Increased family violence See Section 7.6

There will be an increase in problem gambling See Section 7.4

Exposure of children to EGMs and gambling See Section 7.7

The community is currently experiencing high levels of harm from EGMs

See Section 7.4

The community is against this development See Section 7.1

The Applicant runs some of the most harmful venues e.g. Plough Hotel

See discussion below.

There will be less room at the hotel for live music and other events

See Section 5.1.

Several submissions, as well as Ms Bell’s report,50 implied that the Plough Hotel would provide the model for the Commercial Hotel post upgrade. There are significant differences between the two premises. The Plough does not have a bistro, a children’s play area, or outdoor dining area, nor does it have a dedicated function space. The front entrance of the hotel leads directly into its gaming room in which there are 100 EGMs; the proposed gaming room in the Commercial Hotel will not be visible to patrons entering the hotel. The population living within 2.5km of the Plough is less advantaged than that living within the same radius of the Commercial Hotel.51 As a part of the subject Application, 10 EGMs are proposed to be transferred from the Plough Hotel. A reduction of EGMs in an area that is less advantaged is a benefit of this Application.

7.5.3 Council consultation with community organisations This consultation provided anecdotal information about families and individuals affected by gambling, including financial problems, mental health issues, relationship breakdowns and a diversion of non-discretionary funds from essential items to the conduct of gaming. Ms Bell’s report did not explicitly set these generalised outcomes in the context of the Application. Limiting factors associated with this consultation include the fact that there was no disclosure of questions asked of participants, nor of any details provided to them about the Application.

7.5.4 Community organisation submissions The following community organisations made submissions to the Commission objecting to the Application for EGMs at the hotel:

Whittlesea Community Connections

Kildonan Child and Family Services

Plenty Valley Community Health Services

Cross Roads, Salvation Army

Brotherhood of St Laurence

Women’s Health in the North. Common themes expressed by these organisations are summarised below. Table 4: Social Impact issues raised in organisations’ submissions

50 July 2016, page 47. 51 See Urbis, May 2016, Chart 3.7, page 31

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Theme Response There will be an impact on family violence rates in the LGA See Section 7.6

The Application, if approved, will result in the loss of the last pub in the area that does not have EGMs

See Section 7.1

Mortgage stress levels in the hotel’s catchment are more than double the Victorian average

See Section 6.2

Increased access to EGMs will exacerbate harm from gambling addiction

See Section 7.4

Proposed community contributions do not provide a benefit and compromise the role of community health services

See Section 7.3

7.5.5 Additional consultation At paragraph 147 of its decision, the Commission noted that

the Applicant did not provide any evidence of community support for the Application. While the Applicant gave evidence that it was not aware of any current patrons of the Premises that would cease attending in the event that the Application was approved, this does not demonstrate a level of community support which can countermand the volume of evidence led by the Council.

The Taverner Surveys carried out on March and April on behalf of the Applicant address this situation. They also provide a balanced view of community opinion on the proposed upgrade package, as well as information on EGM player habits.

7.5.6 Consultation with community organisations The Commission considered that while any increase in gambling related harms was likely to increase demand on existing community support services in the Whittlesea municipality, there was no evidence to suggest that current service providers were unable to meet demand.52 On 28 March 2017, I separately contacted community organisations identified as providing problem gambling services within the City of Whittlesea: see Annexure 3.53 Of the nine organisations listed, two advised that they no longer offered gambling counselling services in the LGA.54 On the same day, I emailed survey questionnaires to the remaining seven organisations on the list and to any that had made a submission to the Commission, asking that they complete and return the questionnaire to me by Wednesday 12 April. The same letter and survey questions were sent to each organisation – see Annexure 4. The purpose of this consultation was to probe organisations’ capacity to service additional demand that might arise from approving the Application, and to seek their input into improving harm minimisation measures. The following organisations were asked to complete a survey questionnaire:

Whittlesea Community Connections

Kildonan Child and Family Services

Gamblers Help North and North West

Plenty Valley Community Health

NEAMI

52 Paragraphs 125-127. 53 This list was provided as Attachment 8 to Whittlesea Council’s Economic and Social Impact Submission 11 October 2016, see point 16. 54 Anglicare Victoria and Victorian Aboriginal Services/Victorian Aboriginal Gambling Awareness Service. Personal communication, 28 March 2017.

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Crossroads, Salvation Army

Victorian Aboriginal Health Service

Brotherhood of St Laurence

Women’s Health in the North. Gamblers Help North and North West and Women’s Health in the North responded to the survey. Their feedback is summarised in the table below. Their responses are at Annexure 5. Table 5: Main findings of community organisations’ feedback

Issue Gamblers Help North and North West

Women’s Health in the North

Gambling counselling service Yes. No.

Gambling counselling service reach

8 LGAs, including Whittlesea LGA

N/A

Percentage of problem gambling clients from Whittlesea LGA as proportion of all clients

Distribution of percentage of clients by LGA not provided. In the year ending June 2016, the service had 249 clients in Whittlesea LGA.55

N/A

Percentage of problem gambling clients from Whittlesea LGA who play EGMs

95%. N/A

Wait times for new problem gamblers or those seeking help on behalf of a problem gambler

The organisation does not have a waiting list; getting an appointment depends on the person’s location and flexibility with time.

N/A

Suggestions on effective gambling harm minimisation measures

Does not consider that there are any.

Mandatory pre-commitment

Maximum $1 bets

Limiting cash out in venues

Changing the machine design to remove features such as losses disguised as wins and deliberately programmed ‘near misses’

Willing to work with the Applicant to improve harm minimisation measures

Yes No

Reasons for not wishing to work with the Applicant to improve harm minimisation measures

N/A Outside the scope of its work.

Alternate ways of channelling community contributions

Will not be involved in any process that determines where such money should be directed.

Does not believe that such contributions are appropriate and will not participate in discussions about how the funds should be distributed.

While a low response rate makes it difficult to comment on capacity issues across the sector, the responses received do highlight some useful points. In respect of harm minimisation suggestions made by Women’s Health in the North, the Applicant advises as follows:

55 This information was provided in a personal communication, 12 April 2017.

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Mandatory pre-commitment: this is not viable or necessarily effective in terms of harm minimisation

Limit maximum bets to $1: as above

Limit cash out in venues: as above

Change the machine design: the Applicant cannot do this as machine design is set by the manufacturer.

A third response was received from the Brotherhood of St Laurence (BSL) more than two weeks after the due date. This is included at Annexure 4. This response does not address the survey questions. It is not dissimilar to the one made to the Commission on 8 September 2016. In respect of issues raised by BSL:

Effect of EGMs on culturally diverse populations: this is less of an issue for the local community of the Commercial Hotel, which has above-LGA rates of Australian-born and population who speak English only at home. The South Morang SA2 – which is where the bulk of population growth is happening – has the highest representation of these populations, which proportions are also well above those of Greater Melbourne

Proximity to local shops will increase convenience gambling: while this may happen, there is no guarantee that it will, and the extent to which it may happen is conjecture

High rates of family violence and link to EGM density: this is addressed at Section 7.6

High levels of mortgage stress: this is addressed at Section 6.2

Proximity of the hotel to early childhood services and primary schools: the South Morang Preschool is 300m on foot from the hotel; there is a park between the preschool and the shops on Gorge Road. The South Morang Primary School is 700m on foot from the hotel. To suggest that EGMs at the hotel pose some risk to the populations of either – from these distances – is not credible. I do not recall having seen a submission on the Application from either of these facilities

Increased exposure of children to EGMs due to existing children’s play area: this is addressed in Section 7.7.

Finally, the Commission noted that

the Applicant did not provide any evidence of community support for the Application. While the Applicant gave evidence that it was not aware of any current patrons of the Premises that would cease attending in the event that the Application was approved, this does not demonstrate a level of community support which can countermand the volume of evidence led by the Council.56

The Taverner Surveys show that there is overwhelming support from within the local community and hotel patrons for the Application. This is sufficient, at least, to countermand the volume of negative sentiment towards the proposal and, as a social impact, has neutral weight.

56 Paragraph 147.

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7.6 Increase in gambling-related crime and social disturbance A number of submissions objecting to the Application implied that the provision of EGMs at the Commercial Hotel could lead to an increase in the crime rate in the local community and in Whittlesea LGA. In particular, community organisations, individual submitters and Council’s SEIA flagged the potential of the proposal to have consequences for rates of family violence. In support of these claims, research was cited which showed that there was a correlation between EGM density and family violence. The Commission agreed that there was no evidence to suggest that the Application would increase the crime rate in the LGA or local area.57 A study by Markham, Doran and Young58 examined the relationship between domestic violence and EGM accessibility in Victoria at the postcode level between 2005 and 2014, using police-recorded domestic violence incidents. While a figure is provided that shows the spatial distribution of postcodes by family violence incidents and EGMs per 10,000, it is difficult to interpret and the section for Melbourne – which is at a more readable scale than the state map – stops short of the postcodes in which the suburbs of South Morang, Doreen and Mernda are located. The key results of this study were that postcodes with no EGMs were associated with:

20% fewer family incidents per 10,000 and

30% fewer domestic violence assaults per 10,000 when compared with postcodes with 75 EGMs per 10,000.59 The authors of the study emphasised that its estimates were associations only, and that any causal inferences that could be made about the relationship between EGM density and domestic violence were limited. They said that while gambling was likely to be a cause and effect of domestic violence, it was likely that the correlation between EGM accessibility and domestic violence resulted partly from the correlation of both these variables with other unobserved variables such as alcohol-outlet density. They further asserted that while one could expect the reduction of accessibility of EGMs or their removal to result in a substantially reduced incidence of domestic violence, a more reasonable interpretation was that only a fraction of the estimated association was attributable to gambling-caused domestic violence. They concluded by saying that further study was required to make sense of the multiple pathways to this association and to estimate the size of potential reductions in the domestic violence incidence rate that might occur if EGM accessibility were reduced.60 The Commission considered that the above average population growth occurring in Whittlesea LGA was likely to be a contributing factor in the overall increase in family violence incidents recorded in Whittlesea.61 This is a reasonable assumption, given that annual growth in the local community of the hotel has been 8% per annum for the past three years.

57 Paragraph 150 58 Markham, F., Doran, B., Young, M. The relationship between electronic gaming machine accessibility and police-recorded domestic violence: a spatio-temporal analysis of 654 postcodes in Victoria, Australia 2005 – 2014 Social Science & Medicine 162 (2016). 59 Ibid. page 110 60 Ibid. page 112 61 Paragraph 156.

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The Commission was not satisfied that the available evidence established a causal link between EGMs and family violence such as would support a finding that an impact of this Application would be an increase on existing levels of family violence.62 Given that it also agreed that the Application would not increase crime rates in the area, it does not follow that it could regard the potential for gambling-related crime and disturbance as a disbenefit of the Application. On the available evidence, it is not possible to say one way or another whether the Application will lead to an increase in family violence. I therefore do not consider this to be a social impact of the proposal.

62 Paragraph 157.

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7.7 Increased exposure of children to gambling activity The plan lodged with the original application shows access to the proposed gaming room and existing bistro from a common entry vestibule as shown below. Figure 2: proposed entry to gaming room (January 2016)

Whittlesea Council’s Social and Economic Impact Assessment queried whether the design of this entry would make the gaming room visible to patrons, including children, entering the venue, noting also that there did not appear to be a door on the gaming room entrance.63 The Commission found that:

The proposed layout of the entrances to the Premises will necessarily require families attending the Premises for the purpose of attending the bistro to pass in close proximity to the entrance to the gaming room which (despite the layout of the entrance and inclusion of the screen) may result in the exposure of children to sights and/or sounds of EGMs in the gaming room. As such, the Commission considers that the increased risk of exposure of children to gaming is a social impact disbenefit of this Application, which it assigns a low weight.64

In response to these concerns, this entrance has been redesigned to create an entry ‘porch’ from which physically separate vestibules are provided to the gaming room and the bistro. This, as well as a door to the gaming room, is shown in the figure below.

63 Bell, D. 5 July 2016 op.cit. page 32, and Addendum Report 9 September 2016, pages 10 and 21. 64 Paragraph 165, 8 December 2016.

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Figure 3: proposed changes to gaming room entry (March 2017)

Key outcomes of changes to the design are:

A partition inside the gaming room entrance off Porch 1 will effectively screen direct sightlines into the gaming room

There will be frosted glass or other opaque treatment to the door and wall of the gaming room as it presents to the entrance off Porch 1.

These changes would make it very difficult – if not impossible – for patrons wishing to use the bistro, to either see the inside of the gaming room or hear activities within it, en route. As children will not be allowed to enter the gaming room, nor see or hear activities from within this space, this issue is resolved. The social impact is neutral.

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8. ASSESSMENT OF NET DETRIMENT OR BENEFIT OF THE APPLICATION

The table below summarises the social impacts of the Application. Table 6: summary of social impacts of the Application

Impact Reference Comment Improved facilities that add to the appeal of the hotel

See Section 7.1 Social benefit, high weight

Increased gaming opportunities for those who enjoy gaming

See Section 7.2 Social benefit, low weight

Increased contributions See Section 7.3 Social benefit, high weight

Increased incidence and impact of problem gambling on community

See Section 7.4 Social disbenefit, low weight

Community attitude See Section 7.5 Neither benefit nor disbenefit

Increase in gambling-related crime

See Section 7.6 Neither benefit nor disbenefit

Increased exposure of children to gambling activity

See Section 7.7 Neither benefit nor disbenefit

Improved facilities and increased contributions are regarded as social benefits of the Application to which a high weight applies. The key social disbenefit of the Application is its potential to increase gambling-related harm. In the light of the local community’s socio-demographic characteristics, and protective factors such as harm minimisation policies and reduced trading hours, this impact is not considered sufficient to warrant refusal of the Application. The proposal will provide a net benefit to the local community.

Rose Saltman 4 May 2017

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9. REFERENCES Australian Bureau of Statistics Census of Population and Housing 2011 Australian Bureau of Statistics Regional Population Growth Australia 3218.0 Australian Leisure and Hospitality Group Pty Ltd Responsible Gambling Code of Conduct November 2016 Bell, D. Social and economic impact assessment: application for approval of premises for gambling suitable for 40 electronic gaming machines (EGMs) at the Commercial Hotel South Morang 5 July 2016 Bell, D. Addendum to SEIA 9 September 2016 Centre for Gambling Research, Australian National University 2003 Victorian Longitudinal Community Attitudes Survey Gambling Research Panel Report 6, 2004 City of Whittlesea Gambling Strategy and Action Plan 2014 to 2024 Department of Employment Small Area Labour Markets Australia December Quarter 2016 Department of Justice Socio-economic impacts of access to electronic gaming machines in Victoria: effects on demand and communities December 2011 Livingstone, C., Rintoul, A., Francis, L. What is the evidence for harm minimisation measures in gambling venues? Evidence Base Issue 2, 2014 Markham, F., Doran, B., Young, M. The relationship between electronic gaming machine accessibility and police-recorded domestic violence: a spatio-temporal analysis of 654 postcodes in Victoria, Australia 2005 – 2014 Social Science & Medicine 162, 2016 Productivity Commission Inquiry Report Gambling Number 50, 26 February 2010 PVS Australia Pty Ltd Australia Leisure and Hospitality Group Pty Ltd Responsible Gambling Code of Conduct Review Report 9 November 2016 Sproston, K., Hing, N. & Palankay, C. Prevalence of Gambling and Problem Gambling in New South Wales April 2012 Supreme Court of Victoria Macedon Ranges Shire Council v Romsey Hotel Pty Ltd and Victorian Commission for Gambling Regulation 3703 of 2007, 19 March 2008 Taverner Research Commercial Hotel, South Morang Market Research 3 May 2017 Urbis Commercial Hotel, South Morang Social and economic impact assessment May 2016 Victorian Civil and Administrative Tribunal Whittlesea City Council v Victorian Commission for Gambling Regulation and George Adams Pty Ltd VCAT 534 of 2011

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Victorian Commission for Gambling Regulation Approval of premises at Bridge Inn Hotel, Mernda, as suitable for gaming with forty (40) gaming machines 30 September 2011 Victorian Commission for Gambling Regulation Application by Laurimar Tavern Pty Ltd under section 3.3.4 of the Act for approval of premises Laurimar Tavern, 63 Painted Hills Road, as suitable for gaming with forty (40) gaming machines 15 March 2010 Victorian Commission for Gambling and Liquor Regulation Application under section 3.4.17(1)(b) of the Gambling Regulation Act 2003, by Benmara Pty Ltd for amendment of its venue operator's licence to vary the number of electronic gaming machines at the approved venue, The Bridge Inn Hotel, 1425 Plenty Road, Mernda, from forty (40) to sixty (60) gaming machines 11 November 2014 Victorian Commission for Gambling and Liquor Regulation Application by Australian and Leisure Hospitality Group Pty Ltd under Section 3.3.4(1) of the Gambling Regulation Act 2003 for approval of the premises, the Commercial Hotel, located at 820 Plenty Road, South Morang, as suitable for gaming with forty (40) electronic gaming machines 8 December 2016 Victorian Competition and Efficiency Commission Counting the cost: Inquiry into the costs of problem gambling 2012 Victorian Responsible Gambling Foundation Risk factors for problem gambling: environmental, geographic, social, cultural, demographic, socio-economic, family and household May 2015 Victorian Responsible Gambling Foundation Study of Gambling and Health in Victoria: Findings from the Victorian Prevalence Study 2014 2015 Victorian for Gambling and Liquor Regulation Economic and Social Impact Submission Gambling Information Kit

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Annexure 1: Curriculum Vitae for Rose Saltman

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rose saltman

Career Summary

September 2002 Formed RM Planning P/L with Michael Wiles 1988– August 2002 Principal of own business, Rose Saltman Urban Planning, Sydney 1985-1988 Department of Housing

Senior Program Officer, Senior Policy Officer Duties: Developed guidelines for and administered programs for community housing; developed and reviewed policy on affordable housing.

1981-1985 Department of Environment and Planning, Sydney Assistant Town Planner Duties: Undertook strategic and statutory planning tasks, including heritage assessments.

1978-1981 Divisional Council of the Cape, Cape Town, South Africa Planning Assistant Duties: Undertook urban research and statutory planning tasks.

Core Skills and Capabilities

Experienced urban and social planner

Creative solutions for complex problems

Able to work with professionals of different disciplines

Effective presentation and report writing skills

Highly motivated

Education

Tertiary education

University of Technology Sydney Master of Arts in Non-fiction Writing (2016)

University of New South Wales Graduate Certificate in Social Impact (2011)

Macquarie University Master of Business Administration (1991)

University of Cape Town Master of City and Regional Planning (1978) Bachelor of Arts (Honours): major in Comparative African Government and Law (1975) Bachelor of Arts: Majors in Sociology, & Comparative African Government & Law (1974)

Phone 61-2-9904 1678 Mobile 0414 243751 E-mail rose@rmplanning.com.au Website: www.rmplanning.com.au

PO Box 887, Neutral Bay, NSW 2089 Australia

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Short courses

Social Return on Investment Training New Economic Foundation, in association with Net Balance (2010)

Australian Property Institute/University of Sydney Associate Professional Certificate in Expert Evidence for the Land and Environment Court (2005)

Awards

Co-recipient of Royal Institute of Chartered Surveyors (RICS) Award for Regeneration of Sydney Olympic Site – September 2000.

Experience

Social Planning & Impact Assessment

Application for grant of packaged liquor licence at 718-722 Military Rd, Mosman: response to objector, for Back Schwartz Vaughan (2016).

Social Impact Assessment of proposed Ellerton Drive Extension, for Queanbeyan City Council (2016).

Socio-economic Assessment of proposed Mona Vale Road Upgrade, for RMS (with SMEC 2015).

Social impact assessment of gaming associated with proposed hotel at Campsie, for Back Schwartz Vaughan Lawyers (2015; additional evidence provided in 2016, ongoing 2017).

Socio-economic Impact Assessment of proposed Princes Highway upgrade - Berry to Bomaderry, for RMS (with AECOM 2013).

Preliminary Socio-Economic Impact Assessment of proposed Pacific Highway upgrade: Narara to Lisarow, for RMS (2012).

Socio-economic Impact Assessment of proposed Princes Highway upgrade - Foxground to Berry, for RMS (with AECOM 2012).

Social Impact Statement for proposed student accommodation at 43 Australia St, Camperdown, for TJAC Boutique Student Living (2012).

Preparation of response to objections to proposed package liquor licence in Cronulla, for Cronulla IGA (2012)

Social Study, Bourke Street Cycleway, for Sydney City Council, with Tre Sorelle (2011).

Social Impact Statement for UTS Concept Plan Application, for University of Technology Sydney (2009).

Social Impact Statement associated with rezoning of school site, for Board of Masada College and North Shore Synagogue (2009).

Preparation of support services report for Seniors Living proposal at Oxford Falls, for Tiffany Developments Pty Ltd (2008).

Social Impact Assessment and Crime Prevention Assessment for Seniors Living Proposal at Kanwal, for Silver Spirit Communities (2008).

Preliminary scoping of social issues for North West Rail Link, for TIDC, with GHD P/L (2008)

Socio-economic Impact Assessment for Victoria Road Upgrade, for RTA, with Wakefield Planning Pty Ltd (2008).

Category B Social Impact Assessments for retail liquor outlets at New Berrima for G&K Hanratty (2007) Kingscliff, for CB Cellars Pty Ltd; at North Albury, for Calijol Pty Ltd, and at Corowa, for Darjilla Pty Ltd, all with Impact Assessments P/L (2008).

Category B Social Impact Assessment for retail liquor outlet at Tea Gardens, for Myall Quays Shopping Village Pty Ltd (2008).

Preparation of Preliminary Social Impact Assessment for upgrade to Victoria Road, for RTA (2007).

Social Impact Assessment for proposed school at Camden, for Quranic Society (2007).

Community Infrastructure Study for Caddens Release Area, for Landcom (2007).

Finalisation of Social Impact Assessment for Third Crossing of Hunter River at Maitland, for RTA (with GHD P/L) 2006.

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Social Impact Assessment Training for Randwick City Council (2006).

Social Impact Assessment of gaming impacts at Newtown Hotel for McHugh Holdings and at Hampton Court Hotel for F&V Nemeth Investments (2005).

Preparation of Social Planning Study for Gosford City Link proposal, for Landcom (2004).

Preparation of Social Impact Assessment of gaming impacts at Wallacia Golf Club, for Penrith Rugby Leagues Club Pty Ltd and at Ravesis Hotel for Ravesis Hotel (2004).

Social research for proposed restaurant, for Bankstown Sports Club (2004).

Social, Leisure and Recreational Study for South Strathfield, for Strathfield Council (2003)

Social Impact Assessment of Panthers Walk leisure/entertainment proposal, for Penrith Leagues Club Pty Ltd (2003).

Social Impact Assessment for proposed extended trading hours at Crown on McCredie Hotel, West Guildford, for Dyldam Developments (2003).

Input into drafting of BASIX – Social Index, for Planning NSW (2003).

Social Impact Assessments of gaming impacts, for hotels at Jerrabomberra (Queanbeyan) and Shellharbour (both for Club Hotels), and Darlinghurst (for McHugh Holdings) (2002)

Social Impact Statement for proposed conversion of hotel to residential apartments at Parramatta, for The Marsim Group P/L (2002).

Review of Community Facilities for Blacktown City Council (with Suter Associates) 2002

Social Impact Assessment of proposed redevelopment of Maroubra Mall shopping centre, for Cartier Group of Companies (2002).

Social Impact Assessment of proposed hotel at Liverpool, as part of DA submission, for Club Hotels Group Pty Ltd (2001).

Human Services and Facilities study for Pipeworks Release Area rezoning, for Blacktown City Council (with JBA Urban Planning Consultants) (2001).

Development Planning & Assessment

Planning reports for public housing sites, for Assets Division, Housing NSW (2009-10)

Assessment of Reviews of Environmental Factors under the BER Program, for the Department of Education and Training (2009-10).

DA/Statement of Environmental Effects for providore at Walsh Bay, for City Living Pty Ltd (2010).

DA/Statement of Environmental Effects for extended trading hours proposal, V Bar, Liverpool Street, Sydney, for V Bar Avillion Hotel Pty Ltd (2007).

Assistance with preparation of Affordable Housing Strategy, for Randwick Council (2007).

Assessment of proposals to demolish boarding houses under SEPP 10, for Department of Planning, with Impact Assessments Pty Ltd (2004 -2007).

DA/Statement of Environmental Effects for alterations and additions to residential flat building in Queenscliff (private client) (2005).

Signage DA/Statement of Environmental Effects for Crown on McCredie Hotel, West Guildford, for Hotel 8888 Pty Ltd (2005).

Assessment of impacts of new Council Local Environmental Plan on public housing assets in Ryde, for Department of Housing (2002).

Prepared DA/Statement of Environmental Effects for apartment proposal in Sutherland Shire, for Moulang P/L (with Phillips Fox) (1999).

Assessed range of DAs requiring Ministerial approval, for Department of Urban Affairs and Planning (1998/1999).

Report on planning mechanisms to facilitate affordable housing in Manly, for Manly Council (1998).

Prepared Development Applications and Statements of Environmental Effects for: Sydney International Regatta Centre, Sydney International Equestrian Centre (value approx. $40 million), Horse Exercise Trail, Easter Show Carnival For the Olympic Co-ordination Authority (1995-1997).

Prepared Local Environmental Study on Backpacker Hostels for Manly Council (1997).

Pro Bono work

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Planning Institute of Australia, NSW branch: member of editorial committee for New Planner (quarterly publication), assistance with membership training and policy for implementation of new planning legislation, survey of member views on publication format and content (2013 - 2016).

DOUTS (University of Technology scuba club): Events coordinator and key fundraiser for scuba club (2010-2015).

United Way: advice on program evaluation techniques (2011).

Presentation skills/experience

Expert witness in the Land and Environment Court, Licensing Court and Supreme Court of NSW. Presentation to AIUS seminar on Social Sustainability Issues for Eastern Sydney (2004).

Computer skills

PC word processing, spreadsheets and graphics applications skills.

Internet applications skills.

Professional affiliations

Corporate member, Planning Institute of Australia.

Personal

Interests: Swimming, scuba diving, travel, cinema, writing.

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Annexure 2: Letter of support from South Morang Cricket Club

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Annexure 3: List of gambling services in the City of Whittlesea

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Annexure 4: Survey instrument and letter to community organisations

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PO Box 887 Neutral Bay NSW 2089 T: 02-9904 1678 ABN: 58 101 604 773

Dear, Re: Proposed upgrade to Commercial Hotel, 820 Plenty Road, South Morang I have been retained by Australian Leisure and Hospitality Group (ALH) to consider the potential social impacts that may arise from the proposed upgrade of facilities at the Commercial Hotel at South Morang. As you may be aware, the upgrade package includes a dedicated function space, roof top bar/beer garden, revamped sports/public bar, and new gaming room with 40 electronic gaming machines (EGMs). The upgrade is contingent on approval of the 40 EGMs. The gaming room’s proposed hours of operation are:

Monday to Saturday: 10am – 1 am

Sunday: 10am – 11pm

Good Friday/ANZAC Day: 12 noon – 11pm. No change is proposed to existing operating hours for the bistro and public bar. As part of this application, a total of 20 EGMs will be relocated from the south of the Whittlesea Local Government Area, spread across the Bundoora Taverner (six), the Plough Hotel (ten) and the Excelsior Hotel (four). I enclose a survey questionnaire for your information. Please let me know how best you would like to provide feedback. I would appreciate it if this could be before Wednesday, 12 April 2017. Thanks in anticipation. Yours faithfully,

Rose Saltman 28 March 2017

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Survey questionnaire

Name of person responding

Role/position

Name of counselling service

Gambling counselling provided Y/N

Other services provided

Geographic area served (suburbs)

Date of response

1. Does your organisation provide gambling counselling or gambling help services in the Whittlesea Local Government Area (LGA)?

Yes

No

If you have answered ‘no’, please go to question 5. 2. If you have answered ‘yes’ to question 1, what percentage, approximately, of all your

problem gambling clients, is made up of clients who live in the Whittlesea LGA? …………………………………………………………………………………………………………………………………………………… 3. Approximately what percentage of your organisation’s Whittlesea LGA clients are electronic

gaming machine (EGM) players? ……………………………………………………………………………………………………………………………………………………. 4. How long would new problem gambling clients, or those seeking help on behalf of a problem

gambler, need to wait for an appointment with your organisation? Please specify as appropriate.

……………………………………………………………………………………………………………………………………………………. 5. In the event that the application for a package of upgrades to the Commercial Hotel,

including 40 poker machines, were to proceed, what would you consider to be effective gambling harm minimisation measures? Please comment.

........…………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

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6. Would you be willing to work with the applicant to improve such harm mitigation measures?

Yes

No

7. If you have answered ‘no’ to question 6, please give reasons. …………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………… 8. As part of the proposal, ALH has previously indicated that it will contribute:

$100,000 annually for 10 years, including $10,000 for an annual charity day, $40,000 to the City of Whittlesea for problem gambling initiatives and $50,000 to a committee for grants to local community and sports groups

At the end of 10 years, $25,000 per annum to local community/sports groups to be allocated via a committee for the term of the operation of the EGMs.

Do you think that there are alternative ways in which these funds can be targeted?

Yes

No

9. If you have answered ‘yes’ to question 8, please discuss. ………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………… Thank you for completing this survey.

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Annexure 5: responses from community organisations

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Gamblers Help North and North West Survey questionnaire

Name of person responding Lara Jackson

Role/position A/Executive Manager

Counselling and Support Services

lara.jackson@bchs.org.au

Name of counselling service Gamblers Help North and North West

Gambling counselling provided Y/N

Yes

Other services provided GHNNW is auspiced by Banyule Community Health Services. BCHS offers a wide suite of community health services with a focus on the Banyule community. Our Gamblers Help Services are broader in reach extending across 8 local government areas.

Geographic area served (suburbs)

Banyule, Nillumbik, Darebin, Whittlesea, Hume, Melton, Brimbank, Maribyrnong

Date of response 3 April 2017

10. Does your organisation provide gambling counselling or gambling help services in the Whittlesea Local Government Area (LGA)?

Yes X

No

If you have answered ‘no’, please go to question 5. 11. If you have answered ‘yes’ to question 1, what percentage, approximately, of all your

problem gambling clients, is made up of clients who live in the Whittlesea LGA? In the 2015-2016 financial year there were 109 financial counselling clients and 216 therapeutic counselling clients from the LGA of Whittlesea.

12. Approximately what percentage of your organisation’s Whittlesea LGA clients are electronic

gaming machine (EGM) players? Approximately 95% of Whittlesea presentations are from people using poker machines.

13. How long would new problem gambling clients, or those seeking help on behalf of a problem

gambler, need to wait for an appointment with your organisation? Please specify as appropriate.

GHWNW does not have a waiting list. The time taken to get an appointment will depend on a persons’ ability to be flexible with time and location. 14. In the event that the application for a package of upgrades to the Commercial Hotel,

including 40 poker machines, were to proceed, what would you consider to be effective gambling harm minimisation measures? Please comment.

Banyule Community Health is not convinced that there are any harm minimisation measures that can counteract the harmful effects of introducing poker machines to the Commercial Hotel. The City

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of Whittlesea is already well supplied with EGMs. People in the area who choose to use the machines have high levels of access such that introducing more will not create a benefit to the community. 15. Would you be willing to work with the applicant to improve such harm mitigation measures?

Yes see below

No

GHNNW delivers the venue support program to all EGM venues in our catchment as per our funding agreement with the Victorian Responsible Gambling Foundation. All venues in the catchment are mandated to participate in the program. 16. If you have answered ‘no’ to question 6, please give reasons. N/A 17. As part of the proposal, ALH has previously indicated that it will contribute:

$100,000 annually for 10 years, including $10,000 for an annual charity day, $40,000 to the City of Whittlesea for problem gambling initiatives and $50,000 to a committee for grants to local community and sports groups

At the end of 10 years, $25,000 per annum to local community/sports groups to be allocated via a committee for the term of the operation of the EGMs.

Do you think that there are alternative ways in which these funds can be targeted?

Yes

No

We anticipate that at least 50% of losses in the venue would come from people experiencing gambling harm and do not believe that such contributions to community in any way counteract the harm caused to those individuals and families affected by that harm. Banyule Community Health Service will not be involved in any process to determine where such money should be directed. 18. If you have answered ‘yes’ to question 8, please discuss. See above.

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Women’s Health in the North Survey questionnaire Completed by: Helen Riseborough Chief Executive Officer Phone: 03 9484 1666 www.whin.org.au

Geographic area served (suburbs) Northern Metropolitan Melbourne: Darebin, Whittlesea, Yarra, Banyule, Nillumbik. Hume, Moreland Date of response 30 March 2017 1. Does your organisation provide gambling counselling or gambling help services in the Whittlesea Local Government Area (LGA)? No If you have answered ‘no’, please go to question 5. 2. If you have answered ‘yes’ to question 1, what percentage, approximately, of all your problem gambling clients, is made up of clients who live in the Whittlesea LGA? 3. Approximately what percentage of your organisation’s Whittlesea LGA clients are electronic gaming machine (EGM) players? 4. How long would new problem gambling clients, or those seeking help on behalf of a problem gambler, need to wait for an appointment with your organisation? Please specify as appropriate. 5. In the event that the application for a package of upgrades to the Commercial Hotel, including 40 poker machines, were to proceed, what would you consider to be effective gambling harm minimisation measures? Please comment. WHIN is a health promotion organisation that bases its work on best available evidence of intervention effectiveness. Effective gambling harm minimisation measures that should be considered include:

Mandatory pre-commitment

Maximum $1 bets

Limiting cash out in venues

Changing the machine design to remove misleading and addictive features in the machines

such as losses disguised as wins and deliberately programmed “near misses”

We note that there are a number of existing “harm minimisation” measures which have been found to be largely ineffective.65 We caution against continued reliance on such measures. 6. Would you be willing to work with the applicant to improve such harm mitigation measures? No 7. If you have answered ‘no’ to question 6, please give reasons. WHIN works primarily with health and community organisations to further our priority areas which include:

65 Livingstone, C, Rintoul, A& Francis, L 2014, 'What is the evidence for harm minimisation measures in

gambling venues?' Evidence Base, issue 2. https://www.responsiblegambling.vic.gov.au/information-

and-resources/research/recent-research/livingstone-c-et-al-2014-what-is-the-evidence-for-harm-

minimisation-measures-in-gambling-venues

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1. Preventing violence against women (this has included significant work on the intersection

between family violence and gambling harm)

2. Women’s sexual and reproductive health and rights

3. Improving women’s health outcomes through gender analysis

Assisting ALH to implement harm minimisation measures falls outside the scope of our work. We are confident that if ALH were interested in effective harm minimisation, they would be able to implement such measures across all their venues in Victoria without our support. 8. As part of the proposal, ALH has previously indicated that it will contribute: $100,000 annually for 10 years, including $10,000 for an annual charity day, $40,000 to the City of Whittlesea for problem gambling initiatives and $50,000 to a committee for grants to local community and sports groups At the end of 10 years, $25,000 per annum to local community/sports groups to be allocated via a committee for the term of the operation of the EGMs. Do you think that there are alternative ways in which these funds can be targeted? The Public Health Association of Australia states: Public health agencies, researchers, health services and sporting organisations should not accept gambling industry funding (funding from the proceeds of gambling)66. As a public health organisation, WHIN does not believe that such contributions from ALH are appropriate. WHIN will not accept any such donations, nor will we participate in discussions about the distribution of such funds. 9. If you have answered ‘yes’ to question 8, please discuss. Thank you for completing this survey.

66 https://www.phaa.net.au/documents/item/1706

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Brotherhood of St Laurence

Brotherhood of St Laurence

Working for an Australia free of poverty

ABN 24 603 467

RM Planning PO Box 887 Neutral Bay NSW 2089 Dear Ms Saltman,

Re: Social Impacts of additional EGM's at the Commercial Hotel, South Morang

I am writing in response to your letter regarding the potential social impacts that may arise from the proposed upgrade of facilities, including the addition of 40 electronic gaming machines (EGMs), at the Commercial Hotel in South Morang. Further to the questions raised in your survey, the Brotherhood of St Laurence (BSL) would like to provide the following response. BSL is an independent organisation with strong community links that has been working to reduce poverty in Australia since the 1930s. We have a proud tradition of working for a fairer and just society at a local, state and national level. Whilst EGMs are viewed as a lawful recreational activity, they are widely considered a public health and wellbeing issue, and are associated with higher levels of gambling related problems than any other gambling forms. As one of the fastest growing municipalities in Australia, a key issue facing the City of Whittlesea community is the .impact of gambling. -In 2016 EGM losses within the municipality increased to over $103M, with the Epping Plaza Hotel continuing to rank as the venue with the highest losses in the State of Victoria.

BSL has a strong presence in the City of Whittlesea, and is the lead organisation in the Epping Community Services Hub (ECSH), enabling a range of organisations to deliver an integrated and collaborative suite of services to a large and diverse community. A significant number of organisations based at ECSH frequently offer services to people who have experienced harm as a result of EGMs, which extends well beyond the person who uses the machine. This harm frequently manifests itself in the form of financial stress, mental and emotional ill-health, social isolation, interpersonal conflict, emotional distress and family violence, which has increased across the municipality by almost 30 percent over the past four years. In addition, the City of Whittlesea is culturally diverse, with a higher than state average of people from non-English speaking backgrounds and substantial newly arrived and refugee communities. There is a significant body of research highlighting that people from some CALD communities are more at risk from engaging in frequent and excessive gambling, and may be particularly vulnerable to EGM harm.

24 April 2017

Rose Saltman

67 Brunswick Street, Fitzroy 3065 Victoria Australia

Telephone: 03 9483 1183

Facsimile: 03 9417 2691

DX 282 Melbourne

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Furthermore, BSL is concerned that the proposed upgrade of facilities at the Commercial Hotel is unsuitable due to the following:

Proximity to local shops which will increase convenience gambling,

High rates of family violence in the area and the link between family violence and EGM density; Particularly high levels of mortgage stress in South Morang and the community harms that follow

mortgage defaults and foreclosures;

Proximity of the hotel to early childhood services and primary schools; and,

Increased exposure of children to EGMs due to an existing children's play area in the venue.

One of BSL's key goals is to strengthen the capacity of communities to become active participants in the social and economic life of Australia. Based on our extensive work within the City of Whittlesea we believe that proceeding with the proposed development will cause significant harm to the local community. As such, BSL respectfully requests that the Australian Leisure and Hospitality Group declines the projected upgrade to the Commercial Hotel facility.

Robert Hudson

Group General Manager

Programs and Policy