Mr Roger Arwas
Executive Director, Small Business Victoria
Department of Economic Development, Job, transport and Resources
GPO Box 4509
MELBOURNE VIC 3001
e: [email protected]
Dear Mr Arwas,
RE: Response to Regulatory Impact Statement for Victoria’s proposed two new
public holidays
The Australian Hotels Association (Victoria) welcomes the opportunity to respond to
the Regulatory Impact Statement related to the Government’s proposed declaration
of Easter Sunday and Grand Final Eve as public holidays.
1. AUSTRALIAN HOTELS ASSOCIATION (VICTORIA)
The overarching objective of the Australian Hotels Association (Victoria) is to
effectively contribute to the establishment and maintenance of an economic and
social environment that fosters the business success of members and Victorian pubs
and hotels generally.
AHA (Vic) strives to be the pre-eminent Victorian hospitality industry association
representing the rights and interests of its members to State, Federal and Local
government, other relevant parties and the community. AHA (Vic) provides industry
leadership, lobbies on members’ behalf and promotes best practice in hotel
management, with a commitment to effective communication with members.
Tourism Accommodation Australia (Victoria), a division of AHA (Vic), actively
contributes to the development and growth of tourism and tourism-related
industries.
Within the diverse Victorian hospitality industry, AHA (Vic) and TAA (Vic),
membership incorporates CBD, metropolitan, regional and rural hotels and pubs,
accommodation hotels, resorts and similar businesses.
The ongoing strategic objectives of AHA (Vic) are to:
 Protect, promote and advance the interests and rights of members;
 Uphold and promote the quality, integrity and reputation of the hotel industry;
 Provide timely, effective, relevant and value adding services to members, and
 Develop and maintain value-adding partnerships with key industry stakeholders to
the benefit of members and such partners.
2. PWC REGULATORY IMPACT STATEMENT
AHA (Vic) is satisfied that the RIS objectively addresses the impact of the proposed
additional public holidays.
Key metrics identified in PWC’s “Regulatory Impact Statement on proposed new
public holidays in Victoria” include:

The proposed public holidays would provide an estimated additional 1.5
million days off work across Victoria annually;

The lost production (economic cost) from the new public holidays is
estimated to be between $717 million and $898 million annually;

There is potential to increase tourism expenditure in regional Victoria during
a new long weekend (Grand Final weekend) by between $17 million and $51
million annually;

Studies indicate that complementary sports-related event could potentially
contribute between $7 million and $49 million annually to the Victorian
economy, and

Increased wage payments of between $252 million and $286 million annually
due to penalty rates payments to those who work on the public holidays.
PWC concludes that:
“Overall the estimated costs of the new public holidays outweighs the quantified
benefits; however there is potential for wider benefits to accrue to families and
the broader community associated with co-ordinated leisure time”
Upon the declaration of Easter Sunday and Grand Final Eve as public holidays,
Victoria will have the highest number of public holidays of any Australian State or
Territory per table 1 next page.
TABLE 1: Current Hospitality Industry (General) Award wage rates
3. IMPACT ON VICTORIA’S PUB AND ACCOMMODATION HOTEL SECTOR
Whilst the PWC presents a Victorian industry-wide perspective of the impact of the
proposed Easter Sunday and Grand Final Day public holiday, there are particular
impacts on Victoria’s hospitality industry that require highlighting.
Employees within the Victorian pub and accommodation hotel sector are covered by
the Hospitality Industry (General) Award, with the following wage rates and penalty
rates applying:
The 275% penalty rate applying on public holidays is a cost burden on relevant
hospitality businesses that results in operators reducing staffing levels and/ or service
offerings on such days.
A survey of 100 AHA (Vic) members regarding their response to the declaration of
Easter Sunday 2015 as a public holiday reveals the following:
(a) Particular issues related to the proposed Grand Final Eve Public Holiday
Historically Grand Final Eve has been a “big day” for both Victoria’s pubs and
accommodation hotels and in fact the community at-large.
The combination of the CBD, metropolitan, provincial and regional general workforce
and city & town visitors, including families etc. attending the Grand Final Parade
through the CBD of Melbourne, creates a critical mass of participants- not only of
community members joining in the event, but people from all walks of life across all
areas of Victoria join together in a unique community celebration.
The working CBD and metropolitan and regional businesses & retail precincts are
integral to that celebration.
To remove over 400,000 workers from CBD Melbourne and commensurate numbers
across metropolitan, provincial and regional cities and towns will see CBD Melbourne
and other business precincts across the State as “ghost towns”, particularly up to
about 12 noon.
In CBD Melbourne the re-routing of the Grand Final Parade away from the Swanston
Street & Collins Street will exacerbate this situation.
Many hospitality businesses, including pubs, located in the office precincts of CBD
Melbourne already choose not to trade on public holidays. Such closures are
anticipated to also occur on a Grand Final Eve public holiday.
The decision to declare Grand Final Eve a public holiday is predicated on a significant
increase in families etc. choosing to visit regional areas of Victoria over the new long
weekend, with resultant increases in economic activity in those communities.
However, such a proposition fails to appreciate that the Victoria 2nd school term
concludes on Monday 4 October 2015. It is most unlikely that families will take or
extend holiday arrangements in the last weekend of three week school holidays (19
September – 4 October 2015).
Unlike arrangements in respect of Melbourne Cup Day, there are no opportunities to
re-assign the proposed Grand Final Eve public holiday to alternate days in country
Victoria as applies in respect of regional cup days.
Country league finals are played in advance of Grand Final Eve on a Saturday, with
minimal if any economic advantage accruing to the hosting town on the eve before
the Grand Final game.
4. CONCLUSION
AHA (Vic) is satisfied that the PWC “Regulatory Impact Statement on the proposed
new public holidays in Victoria” well identified the impact of the proposal on the
Victorian economy and community.
The costs considerably outweigh the economic benefits, and particularly so when the
perceived economic benefits are identified as “potential” at best.
The direct costs to Victoria’s pub and accommodation sector of the additional public
holidays are significant, particularly having regard to 275% penalty rate applying to
casual workers on public holidays. Many hospitality businesses will choose to close or
reduce service on the public holidays. A significant number of casual employees who
are available and want to work will not be rostered for the day.
In regard to the proposed Grand Final Eve public holiday, there are a range of
qualitative factors and issues beyond the quantitative analysis of the PWC RIS that
may well conspire against the Governments aspiration to grow the Grand Final Eve
celebrations including:

lack of critical mass of workers in the CBD, metropolitan and regional retail
and business precincts;

families opting not to visit regional Victoria on the last weekend of the school
term holidays, and

no focus for regional activities as a consequence of no local football on the
Saturday of the AFL Grand Final.
Yours sincerely,
Brian Kearney
Chief Executive Officer
Australian Hotels Association (Victoria)