2012
Moonee Valley City
Council Electronic
Gaming Machine
Gambling Background
Paper
May
The report was prepared by:
Beverley Kliger
Liss Ralston
Robin Novy
Contents
Executive Summary _________________________________________________________ i
Section One - Electronic Gaming, the Victorian Context_____________________________ 1
1.1 Introduction ________________________________________________________________ 1
1.2 Gaming Regulations __________________________________________________________ 1
1.2.1 Gaming Machine Numbers __________________________________________________________ 2
1.2.2 Gaming Machine Permits ____________________________________________________________ 2
1.2.3 Community Benefit ________________________________________________________________ 2
1.2.4 Changes to EGM Governance and Regulations from August 2012 ____________________________ 3
1.2.5 Other Proposed Changes ____________________________________________________________ 4
1.3 Local Government’s Planning Role ______________________________________________ 4
1.3.1 Determining Permit Applications ______________________________________________________ 5
1.4 Features of the Electronic Gaming Industry _______________________________________ 6
1.4.1 Distance _________________________________________________________________________ 6
1.4.2 Correlation between Social Disadvantage and High Gambling Losses _________________________ 7
1.4.3 Community Benefit ________________________________________________________________ 8
1.4.4 Economic Benefit __________________________________________________________________ 9
1.4.5 Community Perception _____________________________________________________________ 9
1.4.6 A Public Health Issue _______________________________________________________________ 9
1.4.7 Characteristics of People with Gambling-related Problems ________________________________ 11
1.5 Gaming Industry Issues for Consideration _______________________________________ 13
Section Two – Electronic Gaming in Moonee Valley _______________________________ 14
2.1 Electronic Gaming Machine Regional Cap________________________________________ 14
2.2 Analysis of the Municipality __________________________________________________ 15
2.2.1. Propensity to Gamble Index ________________________________________________________ 20
2.3 Municipal Issues for Consideration _____________________________________________ 22
2.4 Features of Electronic Gaming in Moonee Valley’s Local Areas _______________________ 23
2.4.1 Analysis of Monee Valley Gaming Venues ______________________________________________ 25
2.4.2 Patronage of Venues in Moonee Valley and Neighbouring Municipalities ____________________ 27
2.4.3. Moonee Valley Clubs’ Community Contributions _______________________________________ 30
2.5 Local Area Issues for Consideration_____________________________________________ 33
Glossary _____________________________________________________________________ 34
References ___________________________________________________________________ 35
Figures and Tables
Figure 1: EGM Losses by SEIFA Index - Metropolitan Municipalities, 2010-11 ____________________________ 8
Figure 2: Electronic Gaming Venues by Location in Moonee Valley at December 2011 ____________________ 16
Figure 3: Gaming Machines by Local Area as at December 2011 _____________________________________ 17
Figure 4: Gaming Losses Per Annum in Moonee Valley 1992-93 to 2010-2011 __________________________ 17
Figure 5: Net EGM Expenditure Per Month in Moonee Valley July 2010 –November 2011 _________________ 20
Figure 6: City of Moonee Valley Propensity to Gamble Index ________________________________________ 21
Figure 7: Percentage Increase in Gaming Losses Moonee Valley Local Areas 2009-10 to 2010-11 ___________ 23
Figure 8: EGM Losses per Adult by SEIFA Index, Moonee Valley Areas 2010-2011 ________________________ 24
Figure 10: Gaming Losses by Moonee Valley Area 20110-11 ________________________________________ 24
Figure 11: Gaming Losses by Venue per Local Areas, Moonee Valley 2010-2011 _________________________ 25
Figure 12: Locations Within 2 Kilometres of a Gaming Venue within Moonee Valley Municipal Boundary ____ 28
Figure 13: Gaming Venues Within a 2 Kilometre Radius of Monee Valley as at December 2011 ____________ 29
Table 1: Changes to Electronic Gaming Governance and Regulation Structure in 2012 _____________________ 3
Table 2: Electronic Gaming Venues in Moonee Valley as at December 2011 ____________________________ 15
Table 3: Gaming Losses and Density as at June 2011 ______________________________________________ 18
Table 4: Selected Measures for Moonee Valley, Moreland, Maribyrnong and Brimbank ___________________ 18
Table 5: Individual and Household Gaming Losses per Local Area 2010-2011 ___________________________ 23
Table 6: Gaming Losses by Venue and EGM by Moonee Valley areas 2010-2011_________________________ 25
Table 7: Top 10 Gaming Venues in Victoria Ranked by Losses 2009-10 to 2010-11 _______________________ 26
Table 8: Moonee Valley Gaming Venue Losses 2009-10 to 2010-11 ___________________________________ 26
Table 9: Flemington and Moonee Valley Racecourses, Gaming Losses 2010-2011 _______________________ 27
Table 10: Gaming Venues within 2 Kilometres of Moonee Valley's Municipal Boundary ___________________ 30
Table 11: Community Benefit Statements 2010-11, Victoria and Moonee Valley ________________________ 31
Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
Executive Summary
This background paper has been developed to assist the Council to implement its Gaming Position
Paper 2011 and develop a Gaming Policy by taking into account the current distribution and
impact of electronic gaming on the local community and to inform the development a local
gaming policy.
Moonee Valley Council determines planning permits for gaming venues and new electronic
gaming machines. In August 2012, the new licensing regime for electronic gaming machine takes
effect and gaming machines become the responsibility of the venue operators. The existing
gaming operation duopoly (Tabcorp and Tattersalls) will no longer be in operation. From August
2012, venue operators will hold each gaming machine licence for up to 10 years.
The Gambling Regulation Act 2003 enables Councils to make submissions to the Victorian
Commission for Gambling and Liquor Regulation (VCGLR) in relation to the economic and social
impact of the proposal for approval on the well-being of the community. Additionally, recent Victorian and
Civil Administrative Tribunal (VCAT) decisions have indicated that the City of Moonee Valley
(Council) needs to develop a local policy on electronic gaming. The policy should clearly set out
where any new gaming machines may be located within the Moonee Valley area and should
provide evidence for any such spatial preferences.
Research and analysis of the electronic gaming industry in Victoria and Australia indicates that
electronic gaming machines (EGMs):
• are designed to keep people playing
• are typically located in venues that serve alcohol, which, if consumed, can undermine the
player’s judgement
• typically provide limited positive economic impact to players as the odds of ‘winning big’ are
around one in ten million. Furthermore, a player on a one cent machine can lose up to
$310,000 a year playing five times per week for two hour sessions
• are often played by people who are disadvantaged. Furthermore, gaming venues are primarily
located in areas with a high proportion of disadvantaged households
• are widely considered to be a public health issue as they threaten the health of individuals
vulnerable to excessive gambling; potentially impacting not only on such individuals and their
families, but even extending to their employers, colleagues and the wider community.
Additionally, research reveals that problem gamblers and moderate at risk gamblers contribute a
disproportionately high amount to the net gambling income from EGMs received in clubs and
hotels.
Gaming venue operating hours also impact on the level of problem gambling within the
community.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
Moonee Valley gaming regulations
The number of gaming machines that can be located within the Moonee Valley municipality has
been capped at 746 machines. Following the purchase of EGM entitlements under the new
licensing regime commencing in August 2012, there will be a 20 unallocated gaming machine
entitlements. The 20 gaming machine entitlements can be allocated to either:
• a venue with less gaming machine entitlements than its local government planning approval
for gaming machines allows. In this case, the transfer of the entitlements will not involve any
consultation with Council. It is considered to be an ‘arithmetic exercise’ for the VCGLR.
• a venue that seeks to increase its gaming machine entitlements above the number specified in
its planning permit. In this instance, the venue will need to submit applications to:
o Council for a Planning Permit to increase the number of allowable gaming machines at
the venue
o VCGLR for new gaming machine entitlements.
It is timely that Council review planning approvals for gaming machines for all venues except the
Moonee Valley Legends which already has the maximum number of gaming machines (105).
This review will indicate which venues may potentially seek to increase their EGM entitlements
without notification to Council.
Current gaming practice in Moonee Valley
The density of gaming machines and the losses in Moonee Valley are substantially higher than
the average for Victoria, with:
• 8.46 gaming machines per 1000 adults, as compared to the Victorian average of 6.41 per
1000 adults
• losses of $77,097,075 for 2010-2011 which equates to $261 per adult (or 42.5% higher per
adult).
Losses are higher at hotels than clubs, even when the clubs have more gaming machines than
hotels.
Moonee Valley has more gaming machines than Maribyrnong and higher expenditure on gaming
than both Maribyrnong and Moreland, even though Moonee Valley a less disadvantaged
municipality than these neighbouring municipalities. Furthermore, from 2009 to 2011, gaming
losses in Moonee Valley increased at a higher rate than those in Moreland and Maribyrnong.
The areas with the highest propensity to gamble in Moonee Valley are around Airport West,
Avondale Heights and small pockets in Ascot Vale and Flemington.
In 2010-11 there were 17 gaming venues outside of Moonee Valley but within 2 kilometres of a
Moonee Valley municipal boundary. These venues showed total gaming losses of $89,300,720
This is $12,203,645 higher than the total losses in Moonee Valley.
Clubs are entitled to claim as community benefits activities as set out in the March 2008
Ministerial Order. In Moonee Valley clubs claim an extremely high community contribution rate
of 234% of total income (as a percent of net gaming revenue). This is far in excess of the
average community contribution for Victoria (33.7%).
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
The highest claims for community contributions were made for venue operating costs
(181.82%), also far in excess of the state average claim of 24.5%. Moreover, Moonee Valley
clubs made no claims for contributions towards responsible gaming measures.
Gaming by local area in Moonee Valley
To assist with analysis the impact of electronic gaming in Moonee Valley, the municipality has
been dived into three areas: South; Middle and North West. The key features of electronic
gaming in each area for 2010-11 are set out below.
South - Moonee Ponds, Ascot Vale, Flemington, Travancore
•
•
•
•
The highest number of gaming machines (373) and highest losses per area at $31, 204,294.
Also the highest losses per household ($2,100).
Newmarket Tavern showed annual gaming losses of $136,567 in 2010-2011. Losses per
machine were $376 per day; the second highest losses per venue in Moonee Valley.
There is a Moonee Valley gaming venue within 2 kilometres of any location in the area.
The Moonee Valley Legends claimed total community benefit of $45,577,702 against total
EGM revenue of $5,859,741. The community benefit claim included:
o $17,267,233 for prize money and other payments and subsidies
o $3,490,750 for catering and Legends operations
o $1,491,464 for race day advertising and promotions
o $2,417,144 for race day salary and wages
o $17,250,353 for catering, Legends operations and cost of goods sold.
Middle - Aberfeldie, Essendon, Essendon North, Essendon West, Niddrie, Strathmore,
Strathmore Heights
•
•
•
The second highest number of gaming machines (273) and the second highest losses per
household ($1,760) and per local area ($27,128).
The highest growth in annual losses per venue from 2009-2010 to 2010-11 at the
Lincolnshire Arms Hotel which showed an increase in losses of 11.9%.
Only a small area of Strathmore has no Moonee Valley gaming venue within a 2 kilometre
radius.
North West - Airport West, Avondale Heights, Keilor East
•
•
•
•
The lowest Index of Relative Socio-Economic Disadvantage (SEIFA) ranking within
Moonee Valley, and as such the most disadvantaged areas. With only one gaming venue, the
Skyways Taverner, it has the lowest number of EGMs (100).
The highset losses per gaming venue in Moonee Valley, substantially higher than the losses
for all other venues in Moonee Valley. Skyways Taverner showed 2010-11 gaming losses of
$187,345, or $516 per day per machine.
Skyways Taverner showed the 5th highest losses for a venue in Victoria in 2010-11. In 200910 it had the 4th highest losses per venue in Victoria.
Within the North West there is a large area that is more than 2 kilometre from a Moonee
Valley gaming venue.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
Section One - Electronic Gaming, the Victorian Context
1.1 Introduction
In July 2011 Moonee Valley City Council (MVCC) adopted a Gaming Position Paper 1 which has
three objectives:
1. To ensure that the social and economic impacts of gaming are measured to deliver a net
community benefit.
2. To discourage the location of gaming machines in disadvantaged areas.
3. To ensure that the location of gaming machines and the design of gaming premises
minimise the risks associated with exacerbating problem gaming.
The Gaming Position Paper also sets out a range of criteria for MVCC consideration in relation to
planning permits for gaming venues and new electronic gaming machines.
The Moonee Valley Planning Scheme requires policies and strategies directly relating to gaming
to set out:
• the social and economic impacts of the location of gaming machines in Moonee Valley
• the compatibility of electronic gaming machine (EGM) venues with adjoining and nearby
land uses
• the full range of hotel or club facilities or services available to members and patrons
• appropriate locations or premises for gaming based on the above.
This background paper has been developed to assist MVCC to consider the current distribution
and impact of electronic gaming on the local community. In turn, this will inform the
development of an Electronic Gaming Policy and a Local Gaming Planning Policy.
1.2 Gaming Regulations
The Gambling Regulation Act 2003 is the primary legislation governing the regulation and conduct
of gambling in Victoria. Amendments to the Act were introduced in January 2010 and significant
changes to the licensing and governance of gaming machines will occur in August 2012.
The manner in which the EGM industry operates in Victoria will also change in 2012. At that
time, the current gaming operation duopoly, Tabcorp and Tattersalls, will cease to operate and
gaming machines will become the responsibility of venue operators who will hold gaming
machine licences for up to 10 years. This may impact on the location of gaming machines and
type of gaming venues in the municipality.
To operate gaming machines under the new 2012 gaming machine arrangements an operator
must:
• hold a current club or hotel venue operator’s licence
• hold gaming machine entitlements
• have access to approved premises
1
City of Moonee Valley Gaming Position Paper 2011, page 6
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
•
•
•
•
obtain gaming machines and gaming equipment
arrange for the gaming machines to be linked to the monitoring system
employ staff who hold valid Gaming Industry Employee licences
comply with all legislative and regulatory requirements.
Entitlements will revert to the Victorian government if they are not used:
• by 16 February 2013 in the case of entitlements acquired prior to 16 August 2012, or
• within six months of the date they were acquired in the case of entitlements acquired after
16 August 2012.
Entitlement holders have the option to apply for a change to the geographic area or venue
conditions imposed on their entitlement. To apply for an amendment to a condition, a
completed amendment application form must be submitted to the Victorian Commission for
Gambling and Liquor Regulation (VCGLR)2. Entitlements may also be transferred or traded
through a transfer scheme managed by the VCGLR.
1.2.1 Gaming Machine Numbers
Current regulations regarding gaming machine numbers are:
• 30,000 machines in total across Victoria, with 2,500 within the Melbourne Casino
• 27,500 machines evenly divided among clubs and hotels throughout the State3
• 20% of machines in rural locations and 80% in metropolitan locations
• A maximum of 105 machines per venue, with no more than 10 gaming machines per 1,000
adults in any local government area (with the exception of the CBD, Southbank and
Docklands areas)
• Gaming machine caps will be enforced for 20 regions.
1.2.2 Gaming Machine Permits
Venue operators are required to seek permits to operate gaming venues, operate gaming
machines and increase the number of machines within a venue.
To apply for a permit to operate a gaming venue, operators are required to submit a Planning
Permit application (including a liquor license) to their local council. To apply for new gaming
machines or to increase the number of machines within a venue, applications must be submitted
to both the local council and the VCGLR.
Appeals to decisions made by the local council or VCGLR can be made to the Victorian Civil
and Administrative Tribunal (VCAT). Appeals against VCAT determinations can be made to the
Victorian Supreme Court.
1.2.3 Community Benefit
Provisions for the benefit of the community must be made as follows:
• Hotels to contribute 8.33% of profits towards the Community Support Fund
• Clubs to contribute 8.33% of profits towards community benefits. In addition, clubs are
required to submit annual community benefit statements to VCGLR in accordance with the
2
3
Prior to 2012 this was the VCGR (Victorian Commission for Gambling Regulation)
In legislation from 2009
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
March 2008 Ministerial Order.
1.2.4 Changes to EGM Governance and Regulations from August 2012
Changes to the governance and regulations regarding EGMs as at August 2012 are contrasted
against the current system in Table 1.
Table 1: Changes to Electronic Gaming Governance and Regulation Structure in 2012
Current system
As at August 20124
Gaming Machine Operators
Tattersalls and Tabcorp Governance and regulations for operators will include:
hold all gaming machine • A venue operator’s licence entitles the entity to bid to operate a
licences.
gaming machine for up to 10 years with a 2 year extension option.
• No individual or organisation may have an interest in more than
35% of total Victorian hotel gaming machine entitlements, with a
maximum of 105 gaming machines per hotel.
• No individual or organisation may operate more than 420 gaming
machines, with a maximum of 105 gaming machines per club.
• Venue operators have until July 2012 to obtain the required
permits.
Monitoring
VCGLR is an
Intralot will be the sole, independent monitoring licensee.5 Intralot’s
independent, statutory
role will be to:
body within the Victorian • monitor gaming machines and oversee the integrity of gaming
Department of Justice.
machine transactions in venues
Its role is to inspect
• consider and approve EGM licenses
gaming machines, venues, • collect licensing fees from venue operators.
gambling operations and
maintain and scrutinise
EGM gambling
throughout the state.
State Gaming Taxation
Government – receives
40% from Tattersalls
Hotels and 24% from
Tabcorp clubs.
A progressive tax will be paid by operators to the state government.
Tax is calculated on net revenue after payouts per machine per annum
and will be:
• Clubs:
o no tax on the first $32,000 per machine
Venue Operator – pays
o 42.5% tax on income above $32,000 per machine
Tattersalls 26% and • Hotels:
Tabcorp 33%.
o 8.33% tax on the first $32,000 per machine
o 50.83% tax on income above $32,000 per machine.
4
Information about operating a gaming machine business in Victoria from 2012, including the
Business Education Program, State Wide Information Sessions and the Overview of the Victorian
Gaming Industry is available on the Gambling Licences Review website at
www.gamblinglicences.vic.gov.au
5
Cited Age 26.1.12
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
Current system
As at August 20124
Venue Operator Income
Clubs - 33%
Clubs - 57.5% per machine plus $32,000 per machine not taxed
Hotels - 25%
Hotels – 49.83% on income above $32,000.
1.2.5 Changing Regulatory Environment
A Prime Ministerial press release dated 21 January 2012 states that “an evidence-based pathway
to help problem gamblers and their families will gain the necessary support to pass the current
Parliament.” Additionally, the Federal government did not proceed with its intention to introduce
legislation in 2012 which would have:
• require all new poker machines manufactured from 2013 to be capable of supporting precommitment
• impose a $250 withdrawal limit on automated teller machines (ATMs) in gaming venues
• require the cost of play to be displayed on poker machines by 2016
• provide additional counselling support and self-exclusion arrangements
• improve training for staff in EGM venues
In December 2010 6 the Victorian government announced that it would instigate lower
withdrawal limits from ATMs in gaming venues than those proposed by the Federal
Government.
The Victorian Government further proposes to ban all ATMs in venues with gaming machines.
It also recently announced that it would vary the ban to include all cash withdrawal devices that
did not require interaction with venue staff, after indications that a new non-ATM cash device
was being marketed to gaming venues ahead of the ban’s introduction. In addition, the Victorian
Government will be enacting legislation regarding voluntary pre-commitment.
At the time of writing,7 the Federal government had shelved ideas for a national mandatory precommitment scheme8 by the end of 2014, in favour of a year-long trial in the Australian Capital
Territory (ACT). The introduction of $1 maximum bets also appears to be stalled. Also the
Victorian government has announced it will delay the implementation of voluntary precommitment on EGMs to 2016.9
1.3 Local Government’s Planning Role
This section sets out the key aspects of the current and proposed governance and management
of the electronic gaming industry in Victoria; and the socio-economic features of the electronic
gaming industry.
Please note that this analysis is restricted to gambling on EGMs. All references in this paper to
gaming and gambling refer to gambling on EGMs.
6
Minster for Gaming 23 December 2012
January 2012
8
as proposed in the Productivity Commission 2010 report
9
As per VLGA Media Release, 7 February 2012
7
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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1.3.1 Determining Permit Applications
In 2006, the Victorian Government amended all local planning schemes and inserted provisions
in Clause 52-28 regarding Council considerations for determining permit applications for gaming
machines. These considerations are to:
• ensure that gaming machines are situated in appropriate locations and premises
• ensure the social and economic impacts of the location of gaming machines are considered
• prohibit gaming machines in specified shopping complexes and strip shopping centres (as
specified in Clause 52-28-3).
The guidelines for determining an application for gaming machines is set out in Clause 52-28-6.
Before deciding on an application for a planning permit for gaming machines, in addition to the
decision guidelines of Clause 65 councils must consider, as appropriate:
• the State Planning Policy Framework and the Local Planning Policy Framework, including
the Municipal Strategic Statement and local planning policies
• the compatibility of the proposal with adjoining and nearby land uses
• the capability of the site to accommodate the proposal
• whether the gaming premises provide a full range of hotel or club facilities/services to
patrons and members.
However, the Victorian State Planning Policy Framework does not include any reference to
gaming. This means that there is currently no strategic land use framework or guidance to assist
the responsible authorities with their decisions.
1.3.1.1 The Economic and Social Impact of Proposals
The Gambling Regulation Act 2003 enables councils to make submissions to the VCGLR in relation
to the ‘economic and social impact of the proposal for approval on the well-being of the
community.’10 To assist councils, the Act sets out a no detriment test to assess the impact of
electronic gaming on community wellbeing. The test involves reaching a single net measure of
social and economic impact by balancing the likely economic and social impacts of a proposal.
Social impact includes impacts on the community as a whole, not just the views of users of the
venue and people in adjoining properties. Social impact assessments must be determined by wellgrounded research.11
Analysis of a range of VCAT decisions reveals that there are several areas for consideration that
can be applied to the no detriment test, including:
• the test is of the net impact, which requires balancing positive and negative impacts
• the focus must be on the expected impact of the approval, not on existing or average
impacts
• there is a distinction between economic and social impacts, but as there is an overlap it may
be convenient to consider them together
• if the net impact of the test is positive or neutral, the test will be satisfied
10
Victorian Parliament 2003, Gambling Regulation Act 2003 [3.3.6], State Government of Victoria.
Justice Bell, K, 2009, Victorian Civil and Administrative Tribunal, Romsey Hotel Pty. Ltd. V Victorian
Commission for Gambling Regulation & Anor (Occupational and Business Regulation) [2009], [354]
VCAT 2275 (12 November 2009), VCAT.
11
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
•
although the test specifies impact in terms of the relevant municipal district, the impact of
approval on surrounding space is also relevant.12
The VCAT Panel Report granting the Macedon Ranges Planning Scheme Amendment for
Gaming Controls and Policy citied the VCAT decision regarding Beretta’s in Langwarrin (VCAT
74) which found that the lack of a local policy on gaming worked against a local council. In that
case, the Tribunal stated that ‘It goes against the Council that there is no specific local gaming
policy providing any spatial preference for which part of the municipality new EGMs should be
located (sic).’13
Another VCAT decision relating to the Tiger’s Clubhouse in Hopper’s Crossing made clear that
council policies that do not take a considered and objective approach to gaming are not given as
much weight by the VCGLR.14
1.4 Features of the Electronic Gaming Industry
1.4.1 Distance
Metropolitan residents tend to travel short distances to gaming venues. Research shows that 90%
of residents in metropolitan Melbourne reside within 2.5 kilometres of a club or hotel with
EGMs15, and 83% of players travel directly from home to a gaming machine venue.16
The 2009 Department of Justice research into problem gambling found that ‘53.74% of players
travelled no more than 5 km to their preferred pokie venue.’ This finding was aligned with the
2003 Victorian Longitudinal Community Attitudes Survey which found that in metropolitan
areas, travel patterns were localised, with 60% of metropolitan gaming machine players travelling
less than 5 kilometers to a venue and 40% travelling less than 2.5 kilometers.
Evidence suggests that if players were required to travel further to gaming venues there could be
a reduction in the level of problem gambling. For example, the removal of EGMs in South
Carolina in 2000 led to a halving of the number of gamblers anonymous groups within 90 days,
with many remaining support groups reporting a marked decline in attendance.17 However, it is
acknowledged that factors aside from geographical distance also influence gambling behaviour
and these may offset the effect of reduced proximity.18
The 2010 Productivity Commission report suggests that capping the number of gaming
machines in a regional area has led to higher utilisation of the remaining EGMs and has not
12
Justice Morris, S., 2005, Branbeau Pty. Ltd. V Victorian Commission for Gambling Regulation
(Occupational and Business) [2005] VCAT 2606 (16 December 2005). Justice Bell, K. Victorian Civil and
Administrative Tribunal, Romsey Hotel Pty. Ltd. V Victorian Commission for Gambling Regulation &
Anor (Occupational and Business Regulation) [2009], VCAT 2275 (12 November 2009), VCAT.
13
Beretta's Langwarrin Pty Ltd v Frankston CC [2009] VCAT 74 (16 January. 2009)cited in Macedon
Ranges Planning Scheme Amendment C64 Gaming Controls and Policy Panel Report, May 2011
accessed 6 February 2012 http://www.mrsc.vic.gov.au/Files/Macedon_Ranges_C64_Panel_Report.pdf
14
Victorian Local Government Association Supporting Local Governments on Gaming Policy Projects
eBulletin #1: October 2011 www.vlga.org.au
15
Victorian Department of Justice, 2009
16
Department of Justice 2009 page 15
17
Brown Hayden 2009
18
Brown, Hayden, 2009
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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affected the overall spending (losses) in an area.19 The Productivity Commission proposes that
the hours of operation of the gaming venue more significantly affect the losses. It proposed that
regulated shutdowns for gaming rooms in hotels and clubs should be longer than the current
regime and should commence earlier in the evening.
1.4.2 Correlation between Social Disadvantage and High Gambling Losses
The density of EGMs (measured as the number of EGMs per 1,000 adult residents) tends to be
highest among the least affluent localities. For example, the average EGM density in the most
disadvantaged four metropolitan municipalities, as measured by the 2006 Index of Relative
Socio-Economic Disadvantage (SEIFA), was 8.3 machines per 1,000 adults, compared with 2.9
machines for the four most advantaged municipalities.20
Similarly, losses on EGMs are largely sustained by those who can least afford them: those on low
incomes, those in manual employment and the elderly. 21 A study of differences in EGM
gambling losses among various localities in Victoria confirms that the most disadvantaged
communities tend to incur the highest gaming losses.22 In addition, there is a strong association
between higher gambling losses and conditions such as high unemployment rates, high levels of
disadvantage and lower median incomes. It has further been found that higher gambling losses
sustained in some communities largely divert funds from other areas of household expenditure,
resulting in a decline in the standard of living.23 Research shows that gambling losses tend to be
greater among localities where people feel less safe at night, where there are lower levels of
satisfaction with community life and the least extent of community involvement.24
It is estimated that 21.46% of the Victorian public gamble on EGMs.25 In 2009, a segmentation
of the Victorian adult population regarding problem gambling found that 0.70% of Victorian
adults are problem gamblers and 2.36% of Victorian adults are moderate risk gamblers.26 The
research found that the likelihood of problem gambling was significantly higher in medium and
high EGM spending (loss) regions.
Elevated gambling losses have been associated with a greater prevalence of gambling-related
problems. The Productivity Commission’s 1998 national survey concluded that an increase in
gambling losses per adult from $400 to $800 across Australia. This was accompanied by a rise in
the proportion of adults who conceded that they had severe gambling problems, from 0.5% to
nearly 3%.27
A significant proportion of EGM gambling losses is concentrated among a relatively small
proportion of gamblers.28 Although few Victorians gamble on EGMs regularly, in most cases
those who do gamble heavily lose more money than they can afford to lose. It is estimated that
19
Productivity Commission 2010
Brown, Hayden, 2009
21
National Institute of Economic Research, 2000
22
Department of Justice 2009
23
KPMG, 2000; South Australian Centre for Economic Studies, 2005; Justice and International Mission
Unit, 2002
24
Brown, Hayden, 2009
25
Department of Justice 2009 page 13
26
Department of Justice 2009 page 11
27
Productivity Commission Report 1999: 14: S7.8 p. 12
28
McMillan and Marshall, 2004
20
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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57% of gambling losses are incurred by 15% of gamblers.29
Figure 1 shows EGM losses by municipality for the financial year 2010-2011 alongside the
SEIFA Index for the municipality as at 2006. Municipalities have been separated into the
following three SEIFA groups:
• low SEIFA ranking i.e. high disadvantage
• medium SEIFA ranking
• high SEIFA ranking i.e. low disadvantage.
Figure 1: EGM Losses by SEIFA Index - Metropolitan Municipalities, 2010-11
Source: ABS and VCGLR
Figure 1 reveals that Moonee Valley City Council fits into the medium SEIFA index for
Melbourne.
1.4.3 Community Benefit
An analysis of community benefit statements for 2010-11 received from clubs across Victoria
reveals that 26.7% of their collective contribution was for operation of the clubs, 24.5% for
operating costs including employment and 0.9% for fixed assets.30 During the same period, only
6.9% of clubs’ collective contribution was spent on donations, sponsorships, volunteering and
support for the community and 0.0005% on responsible gaming measures and activities. This
indicates the cultivation of an economic dependence on EGM revenue for clubs to maintain and
grow their facilities, services and activities.
It appears that income from EGM gambling is mainly used for the benefit of club members and
growth of the club, as clubs can claim the following as community contributions:
29
30
Doughney and Kelleher, 1999
Data for 2010-2011 is available for each venue and the LGA and the State from the VCGLR website
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
•
•
•
•
employment costs
costs of fixed assets such as furniture and whitegoods
provision of subsidised goods and services
costs of providing and maintaining sporting facilities for use by club members (e.g.
maintaining a racetrack or a football stadium, or redevelopment of the facilities).31
1.4.4 Economic Benefit
It is estimated that within Victoria, some 15,000 people work in clubs and hotels with gambling
machines.32 It is argued that employment in the gaming industry actually diverts expenditure and
jobs from other sectors of employment as expenditure on EGM gambling creates fewer jobs
than those lost from other sectors of the community.33 A 2006 study of Victorian and Western
Australian gambling concluded that 3.2 jobs were created for every million dollars of EGM
gambling expenditure, compared with 8.3 jobs per million from sales of beverages and 20.3 jobs
per million spent on meals and food.34
Working in a gaming venue is also potentially hazardous for employees. A report commissioned
by the Gaming Technologies Association forecast that initially, the removal of gambling
machines from clubs and hotels would result in a decline in employment as jobs would be lost in
the gambling sector. However, the report predicted that in the longer term (unspecified in the
report) employment would rise by approximately 2,100 jobs as people previously employed in
the gambling industry found employment in other sectors.35
Additionally, a 2008 study of employees in hotels, clubs and casinos with EGMs in Queensland
found that some staff had developed gambling problems whilst working in gaming venues. The
study found that responsible gaming training and other responsible gaming measures did not
protect staff from gambling problems.36
1.4.5 Community Perception
A 2004 survey found that electronic gaming was the favoured form of gambling among 84% of
problem gamblers. 37 In line with this, Victorian community surveys reveal persistent and
widespread public apprehension about the level of EGM gambling opportunities and gambling
related harm. They also show broad support for continued reform.38
1.4.6 A Public Health Issue
The report of the 2010 Productivity Commission Inquiry into gambling states that the
31
As set out in the community benefit statements VCGLR data at 2011.
Department of Justice, 2009
33
Brown, Hayden, 2009
34
South Australian Centre for Economic Studies, 2008
35
Centre for International Economics, 2008
36
Hing, N. & Breen, H (2008) How working in a gaming venue can lead to problem gambling: The
experiences of six gaming staff. Journal of Gambling Issues, (21) at www.camh.net/issue21/02hingbreen.htm
37
McMillan and Marshall, 2004
38
Brown, Hayden, 2009
32
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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significant harm resulting from some types of gambling is what distinguishes gambling from
other recreational activities. The Commission referred to an Australian survey which found that
three-quarters of Australian adults thought gambling did more harm than good for the
community, a sentiment unlikely to be ‘replicated for any other legal recreation pursuit.’39
The Department of Justice report states that ‘problem gambling is an important health and
wellbeing issue for the Victorian community.’40 Whilst it has not been possible to definitively
determine the prevalence of problem gambling in Victoria, surveys have estimated between 1%
and 2% of the Victorian population are problem gamblers.41 2009 research for the Department
of Justice considers different forms of gambling and problem gambling from a public health
perspective and found that 91.04% of problem gamblers gamble on EGMs and 77.4% of
moderate at risk gamblers gamble on EGMS.42 The 2010 Productivity Commission report states
that people at moderate risk are important for public health policy as they suffer a higher
likelihood of progression to more serious problems.43
In addition, the 2009 research found that the highest spend activity for problem gamblers was
EGMs. Additionally, EGMs are only located in venues that serve alcohol which can affects
players’ judgement. Mark Griffiths, professor of gambling studies at Nottingham Trent
University asserts “...the combination of gambling and drinking is a heady mix that will
exacerbate problem gambling. You are more likely to be reckless.”44
Community expenditure on EGMs comprises 53% of total money spent in Victorian hotels and
clubs. It was estimated that problem gamblers contributed a disproportionately high amount of
this expenditure in 2005-06.45 The 2010 Productivity Commission report stated that a sizable
proportion of industry and taxation revenue is derived from severe and moderate gamblers,
estimating in 1999 that severe gamblers contributed 33.7% and moderate gamblers 8.7% of
electronic gambling expenditure.46
Studies have revealed that for every person who experiences a problem with gambling there is a
negative impact on family, work and the community. The causes of gambling problems are
complex and involve the interplay between individual factors, the nature of the gambling
experience and the accessibility of gambling opportunities. 47 Problem gamblers compared to
non-gamblers are more likely to experience:
• increased arguments with family and friends leading to relationship breakdown
• a major change in their financial situation such as bankruptcy
• divorce
• legal difficulties
• troubles with work, bosses or superiors that can result in job loss
• committing a crime (gambling is viewed as a common motivation for fraud)
39
Productivity Commission 2010 page xx
Department of Justice 2009 page 16
41
Brown Hayden 2009
42
Department of Justice 2009 page 13
43
Productivity Commission 2010
44
The Telegraph 24 January 2007 Door opened to 24-hour casino gambling United Kingdom
45
Livingstone, C and Wooley R 2007
46
Livingstone, C and Wooley R 2007; Productivity Commission 2010
47
Productivity Commission 2010
40
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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•
•
•
family violence48
homelessness49
depression and/or anxiety – either as a new condition or as an exacerbation of an existing
condition.50
Problem gambling begins with a loss of more money than a person or their household can
afford. The resulting financial hardship can have detrimental ‘ripple’ effects upon personal,
family and social life, leading to personal disturbances, family and marital breakdown, decreased
attendance and productivity at work, deceptive or criminal actions to obtain money and
homelessness.51 Additionally there is a link between problem gambling family violence and elder
abuse as ‘older family members of problem gamblers, especially older women, may be at
increased risk for physical, emotional and financial abuse as the gambler continues to lose
money’.52
1.4.7 Characteristics of People with Gambling-related Problems
The 2009 Department of Justice study into problem gambling found the two main reasons
Victorians gamble are:
1. to win money
2. for general entertainment.53
However, problem gamblers reported social reasons for gambling including to ‘take your mind
off things’ or ‘to relieve stress and boredom.’ Problem gamblers also reported that they were
more likely to gamble out of habit.
Individual gambling behaviour can also be influenced by irrational or superstitious conceptions
about the probability of winning, despite the chance of ‘winning big’ being one in ten million.54
These notions can be fostered by aspects of EGM design, as EGMs are designed to ‘hook’
players into playing by using small rewards and specific design features, or through the manner in
which gambling is presented and advertised. 55 Gambling for quick financial benefit can be a
major factor in problem gambling in culturally and linguistically diverse (CALD) communities
that experience financial hardship and limited employment.56
1.4.7.1 The Definition of Problem Gambling
The 2010 Productivity Commission report outlines that people can have gambling problems
without being seen as a problem gamblers. Furthermore, in the case of EGMs, many people
experience significant harm from EGM gambling but do not fit the problem gambling criteria
48
Community West 2007 Exploring the Links between Family Violence & Problem Gambling Report,
pg 41 citing (McKay, 2002) p.2).
49
Brown, Hayden, 2009, Productivity Commission 2010
50
Department of Justice 2009 page 16, Productivity Commission 2010
51
Brown, Hayden, 2009, Productivity Commission 2010
52
Community West 2007 Exploring the Links between Family Violence & Problem Gambling Report,
pg 41 citing (McKay, 2002) p.2).
53
Department of Justice 2009 page 15
54
Information from EACH February 2009; Productivity Commission 2010
55
Select Committee of the Legislative Council on Gambling Licensing, 2008; Information from
Gambler’s Help Eastern EACH February 2009
56
Centre for culture, ethnicity & health and Victorian Multicultural Gambler’s Help Program 2008
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
and as such are not classified as ‘problem gamblers’. For example, people whose job
performance is profoundly affected by EGM gambling may not be perceived as problem
gamblers. It can also be difficult to gauge the extent of gambling problems in CALD
communities due to the strong religious and social stigma attached to gambling, and previously
adverse experiences under repressive regimes.57
Problem and moderately at risk gamblers tend to be:
• relatively evenly spread between men and women, with approximately half of all Victorian
Gambler’s Help clients in 2007-08 being women.58 However, it appears that the proportion
of female problem gamblers is rising with the spread of local gaming venues59
• typically less educated. Both international and domestic research show that problem
gamblers are more likely to have left school early60
• on lower incomes and employed in less skilled or blue collar occupations61
• experiencing higher rates of personal problems including depression, isolation, heavy
drinking or other drug use.62
The 2010 Productivity Commission report stated that problem gamblers are regular players of
EGMs and that a regular player can lose around $650 an hour. The Commission estimated that a
high intensity player on a “one cent machine” playing for two hour sessions five times a week
can lose around $310,000 a year.63
1.4.7.2 Cultural Effects
Research into problem gambling in new and emerging refugee communities, particularly those
from Liberia, Somalia, Iraq and Sudan, found that these communities have little familiarity with
the Australian gambling system and problem gambling. Yet they are vulnerable to gambling
problems as they are often socially isolated and faced with financial hardship.64 Moreover, the
research found that the lack of knowledge in these communities about support services
combined with a reluctance to use mainstream counselling services made members of these
communities more vulnerable to gambling problems.
It has been found that the longer people are in Australia, the higher the likelihood of developing
gambling problems, even when gambling is prohibited by the gambler’s religion. For instance,
although gambling is prohibited under Islam, the report found that gambling is a culturally and
individually negotiated practice amongst Muslims.65
57
Centre for culture, ethnicity & health and Victorian Multicultural Gambler’s Help Program 2008
Brown, Hayden, 2009
59
Community West 2007
60
McMillen and Marshall, 2004
61
National Institute of Economic and Industry Research, 2000 and KPMG 2000
62
SA Centre for Economic Studies, 2008.
63
2010 Productivity Commission report page xxix
64
Centre for culture, ethnicity & health and Victorian Multicultural Gambler’s Help Program 2008
65
Centre for culture, ethnicity & health and Victorian Multicultural Gambler’s Help Program 2008
58
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
1.5 Gaming Industry Issues for Consideration
Electronic gaming can be characterised as an activity that:
•
is not a benign recreational activity as EGMs are both designed to keep people playing and
are located in venues that serve alcohol which can undermine players’ judgement
•
provides limited positive economic impact to players due to the extremely low odds of
winning and very high odds of losing
•
is primarily located in areas with a high proportion of disadvantaged households and as such
is often carried out by people who are disadvantaged
•
is widely considered to be a public health issue as it threatens the health of vulnerable
individuals such as those suffering isolation, depression or limited income
•
can have a negative impact on individuals, their families, their employers and their
community.
Problem gamblers and moderate at risk gamblers contribute a disproportionately high amount to
the net gambling income of EGMs in clubs and hotels.
Gaming venue operating hours impact on the level of problem gambling.
Councils need to have an objective gaming policy which clearly sets out where any new gaming
machines may be located and should provide evidence for any such spatial preferences.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Section Two – Electronic Gaming in Moonee Valley
2.1 Electronic Gaming Machine Regional Cap
In 2009, a regional cap of 746 gaming machines was established for Region 16, or the City of
Moonee Valley. However, since the cap was applied, the City of Moonee Valley has ceased to
include the suburbs of Kensington and North Melbourne, both of which are now included in
the City of Melbourne. As no gaming venues are located in Kensington and North Melbourne,
the cap for Moonee Valley has been retained at 746 gaming machines66.
The Moonee Valley Regional Cap was set by Ministerial declaration and can only be changed by
Ministerial determination. The cap was implemented as the area was identified as 'high ranking'
on measures of vulnerability to the potential harm caused by large numbers of gaming
machines.67 All capped areas have high levels of both socio-economic disadvantage and EGM
density.
Whilst, the City of Moonee Valley has 746 gaming machines data from the VCGLR indicates
that only 726 gaming machine entitlements were bought for Moonee Valley in 2010 in
preparation for the new licensing regime in 2012. As such, there will be 20 unallocated gaming
machine entitlements from August 2012. The 20 gaming machine entitlements can be allocated
to either:
• a venue with less gaming machine entitlements than its local government planning approval
for gaming machines allows. In this case, the transfer of the entitlements will not involve any
consultation with Council. It is considered to be an ‘arithmetic exercise’ for the VCGLR.68
• a venue that seeks to increase its gaming machine entitlements above the number specified in
its planning permit. In this instance, the venue will need to submit applications to:
o Council for a Planning Permit to increase the number of allowable gaming machines at
the venue
o The VCGLR for new gaming machine entitlements.
66
Advice provided in phone discussion with representative from VCGLR on 13 December 2011and
details on VCGRL web site that these are the entitlements effective for new gaming licensing regime at
th
16 August 2012
67
South Australian Centre For Economic Studies (SACES)2005 Study of Impacts of caps on Gaming
Machines Department of Justice Victoria
68
Advice provided in phone discussion with representative from VCGLR on 13 December 2011
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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2.2 Analysis of the Municipality
To assist with analysis of the municipality, Moonee Valley has been divided into three areas:
North West
Airport West, Avondale Heights, Keilor East,
Middle
Aberfeldie, Essendon, Essendon North, Essendon West,
Niddrie, Strathmore, Strathmore Heights
South
Moonee Ponds, Ascot Vale, Flemington, Travancore
The 11 current gaming venues in Moonee Valley are listed in Table 2 below. Table 2 also sets out
the gaming losses (termed expenditure for 2010/11) for each venue.
Table 2: Electronic Gaming Venues in Moonee Valley as at December 2011
Venue
Address
EGMs
Venue
Type
Expenditure
(2010/11)
100
Hotel
$18,714,501.49
70
Hotel
$9,409,872.94
25
Club
$1,861,914.23
40
Hotel
$4,386,704.18
100
Club
38
Hotel
$5,066,833.48
80
Club
$4,979,023.82
105
Club
$5,879,935.58
70
Hotel
$8,939,978.49
68
Hotel
$9,286,563.84
50
Club
$2,118,792.12
North West
Skyways Taverner
113 Mathews Avenue
Airport West
Middle
Royal Hotel (Essendon)
Keilor East RSL
Cross Keys Hotel
Essendon Football & Community
Sporting Club
Lincolnshire Arms Hotel
873 Mt Alexander Road
Essendon
12-22 Hoffmans Road
Essendon
350 Pascoe Vale Road
Essendon
Napier Street
Essendon
1 Keilor Road
Essendon
$6,452,954.76
South
Junction Tabaret
Moonee Valley Legends
Waterloo Cup Hotel
Newmarket Tavern
North Suburban Sports Club
TOTAL
Source: VCGLR
740 Mt Alexander Road
Moonee Ponds
Mcpherson Street
Moonee Ponds
252 Maribyrnong Road
Moonee Ponds
386 Racecourse Road
Newmarket
622 Mt Alexander Road
Moonee Ponds
746
$77,097,074.93
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Unfortunately it has not been possible to ascertain the number of gaming machines entitlements
per venue as at August 2012, despite requests for information from VCGLR69. As 20 less gaming
machine entitlements have been bought by venues operating in Moonee Valley, the listing of
gaming machines by venue will change in August 2012.
Figure 2 provides a map of electronic gaming venues across Moonee Valley City Council.
Kensington and North Melbourne (in orange) are included in the map as they were previously
within the Moonee Valley City Council. However, no gaming venues are located in these areas.
Figure 2: Electronic Gaming Venues by Location in Moonee Valley at December 2011
Source: VCGLR
The Middle and South areas of Moonee Valley have five gaming venues each, with only one
venue located in the North West. However, Figure 3 reveals that half of the total gaming
machines in Moonee Valley are located in the South. In addition, just under 14% of all Moonee
Valley gaming machines are located in one venue in the North West.
69
The VCGLR listing of entitlements to gaming machines for August 2012 is set out be each individual
entitlement and by the purchaser which includes AHL. Request for the information were made on 29
November 2011 and13 December 2011.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
February 2012
Figure 3: Gaming Machines by Local Area as at December 2011
North West
100
machines
(13.4%)
South
373
machines
(50%)
Middle
273
machines
(36.6%)
Source: VCGLR
Figure 4 shows that gaming losses reached a peak in 2001/2 at $83 million, and that the losses
are even higher when the value of the dollar is adjusted for inflation. Losses appear to be
returning to peak levels in 2011-2012. From July to September 2011, the monthly gaming losses
were higher than the monthly losses for the same period in 2010.
Figure 4: Gaming Losses Per Annum in Moonee Valley 1992-93 to 2010-2011
Source: VCGLR and Hayden Brown of City of Greater Dandenong using VCGLR data
As can been seen in Table 3, the density of gaming machines in Moonee Valley is substantially
higher than the average for Victoria. Losses are also 42.5% higher than the average, currently
sitting at $261 more in losses per adult than the average Victorian rate.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Table 3: Gaming Losses and Density as at June 2011
Estimated loss per capita
(adult)
Density per 1000 adults
Expenditure per EGM
Moonee Valley
$874
8.46
$103,347.29
Victorian average
Source VCGLR
$613
6.41
$99,012.94
Table 4 compares electronic gaming in Moonee Valley with the neighbouring municipalities of
Moreland, Maribyrnong and Brimbank. The comparisons in the table include the density of
gaming machines, expenditure per household, the population of adults and the SEIFA ranking
of each municipality.
Table 4 indicates that whilst Moonee Valley is less disadvantaged than neighbouring
municipalities it has more EGMs than Maribyrnong and higher expenditure on gaming than
both Maribyrnong and Moreland. It is important to note that Brimbank has the second highest
losses per adult and second lowest SEIFA in metropolitan Melbourne. Moonee Valley appears
to fall in the middle range of losses for households and per adult. Yet the losses in Moonee
Valley have increased at a higher rate than for Moreland and Maribyrnong between 2009-10 and
2010 -11.
Table 4: Selected Measures for Moonee Valley, Moreland, Maribyrnong and Brimbank
City / Shire
2011 population (18+) projection
Number of venues
Moonee Valley
Moreland
Maribyrnong
Brimbank
88,201
120,222
57,497
138,779
11
15
10
15
746
765
439
953
$77,097,075
$69,419,770
$56,630,432
$139,385,098
Population (18+) per venue
8,018
8,015
5,750
9,252
Net EGM expenditure per adult
$874
$577
$985
$1,004
EGMs per 1000 (18+)
8.46
6.36
7.64
6.87
$1,647.93
$1,186.39
$2,019.00
$2,236.26
SEIFA advantage/disadvantage rank*
15
22
27
30
Individual expenditure rank*
20
17
12
31
Household expenditure rank*
23
10
29
30
Number of EGMs
Total net expenditure 2010-11
EGM expenditure per household
Total expenditure rank*
% increase in expenditure over previous
year
Sources: ABS, VCGLR
20
17
12
31
2.2%
0.1%
0.8%
3.3%
Figure 5 below maps the Advantage Disadvantage SEIFA ranking across Moonee Valley by
collector districts and unfortunately includes Kensington and North Melbourne that are no
longer in the municipal boundary . Figure 5 reveals that areas in Flemington and Ascot Vale (the
location of high density public housing) and areas in Avondale Heights are vey disadvantaged
with the lowest SEIFA Index. At the same time parts of Essendon North are amongst the most
advantage in metropolitan Melbourne.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Figure 5 Advantage Disadvantage SEIFA Ranking Moonee Valley 2006
Sources ABS
Figure 6 indicates that the monthly expenditure on EGMs is typically around $6.5 million except
for the months of January, February, April and May 2011, the months usually associated with
family holidays. Monthly expenditure on EGMs from July to October 2011 was at the highest
level for the period. However, it must be noted that this monthly analysis is over a short period.
This is the only monthly data now provided by the VCGLR.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Figure 6: Net EGM Expenditure Per Month in Moonee Valley July 2010 –November 2011
$7,000,000
$6,500,000
$6,000,000
$5,500,000
2010
November
October
September
August
July
June
May
April
March
February
January
December
November
October
September
August
July
$5,000,000
2011
VCGLR, 2011
2.2.1. Propensity to Gamble Index
To ascertain the propensity to gamble in Moonee Valley Beverley Kliger & Associates (Bev
Kliger and Liss Ralston) have developed a Propensity to Gamble Index (PGI)©. The PGI has
been developed for all of metropolitan Melbourne. The index is based on the following common
attributes of problem gamblers:
1. less educated than the average adult. Both international research and a Victorian survey show
that problem gamblers are more likely to have left school early70
2. receiving lower incomes and employment in less skilled or blue collar occupations.71
Data has been sourced from the 2006 Australian Bureau of Statistics Census.
Indicator
Schooling
Completed up to a maximum of Year 10 or did not go to school
Income
Individual income falls in the lowest 25% of individual income for
Melbourne
Employment: Semi-skilled Occupations
Sales workers, labourers, machinery operators and drivers
Statutory incomes
In receipt of unemployment benefits or other benefits such as Sole
Parents, Newstart Allowance, Disability Support Pension and Aged
Pension
70
71
Age Range
18 and over
18 and over
18 – 64 years
18 and over
McMillen and Marshall, 2004
National Institute of Economic and Industry Research, 2000 and KPMG 2000
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Figure 7: City of Moonee Valley Propensity to Gamble Index
Figure 7 indicates population pockets within Moonee Valley with a high to very high propensity
to gamble. These pockets are primarily in the North West around Airport West and Avondale
Heights, with small areas in Ascot Vale and Flemington.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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2.3 Municipal Issues for Consideration
Unallocated EGM entitlements at August 2012
Moonee Valley has a cap on the maximum number of gaming machines of that can be located in
the municipality. The cap is set at 746 gaming machines. Following purchase of EGM
entitlements under the new licensing regime commencing in August 2012 there will be 20
unallocated gaming machine entitlements. As the 20 gaming machine entitlements can be
allocated in two ways, one does not require any Council involvement. The allocations can occur
as below:
1. For an existing venue that has less gaming machine entitlements than under its local
government planning approval for gaming machines the transfer of the gaming machine
entitlements will not involve any consultation with Council.
2. For a venue that seeks to increase its gaming machine entitlements above the number it has a
planning permit to operate the venue will need to make applications for the new gaming
machines or an increase the number of gaming machines to:
• Local Council for a Planning Permit
• Victorian Commission for Gambling and Liquor Regulation (VCGLR). for gaming machine
entitlements
It would be timely for Council review planning approvals for gaming machines for all venues
(except the Moonee Valley Legends which already has the maximum number of gaming
machines). This will indicate which venues may seek an increase in gaming machines without
notification to Council.
Density of Gaming Machines and Losses
Density of EGMs and losses are substantially higher in Moonee Valley than the average for
Victoria. In 2010-11:
• losses were $261 (42.5%) higher per adult than the average losses for Victoria
• there were 8.46 gaming machines per 1000 adults, 32% higher than the Victorian average of
6.41 gaming machines per 1000 adults.
Gaming losses appear to be increasing in 2011-2012. From July to September 2011 the
monthly gaming losses were higher than the monthly losses for the same period in 2010.
Moonee Valley has more EGMs than Maribyrnong and higher expenditure on gaming
than both Maribyrnong and Moreland yet is less disadvantaged than these neighbouring
municipalities.
At the same time from 2009-10 to 2010-11 gaming losses in Moonee Valley increased at a higher
rate than Moreland and Maribyrnong.
Propensity to Gamble
Areas with high and very high propensity to gamble in Moonee Valle are in the North West
around Airport West and Avondale Heights, with small pockets in Ascot Vale and Flemington.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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2.4 Features of Electronic Gaming in Moonee Valley’s Local Areas
The gaming losses and density of gaming machines differ across the municipality. Table 5 shows
the relative situation of each local area in terms of losses and gaming machines per adult. The
table reveals that the local areas with the highest numbers of machines per 1000 adults also have
the highest losses per adult and per household. In the South, the losses are 13.4% higher per
adult and 15% higher per household than the Moonee Valley average. 50% of all Moonee Valley
EGMs are also located in the South.
Table 5: Individual and Household Gaming Losses per Local Area 2010-2011
Area
No of EGMs
Losses
Individual
losses
$773
Households
$18,714,501
Population
18+
24,211
12,002
Household
losses
$1,559
North West
100
Middle
273
$27,178,280
32,368
$840
15,367
$1,769
South
373
$31,204,294
31,484
$991
14,858
$2,100
Moonee Valley
746
$77,097,075
88,064
$874
42,227
$1,826
Source: VCGLR, Victorian gaming expenditure data; Population–estimated resident population, June 2011, Department of
Planning and Community Development Population forecasts, and used id logic to allocate population to areas slightly lower
numbers.
The gaming losses for each of the local areas have increased from 2009-10 to 2010-11. In fact,
Figure 8 reveals that the increase in gaming losses in both the Middle and South areas has been
higher than the Melbourne and Moonee Valley averages.
Figure 8: Percentage Increase in Gaming Losses Moonee Valley Local Areas 2009-10 to
2010-11
3%
2.3%
2.3%
2.2%
2%
2.0%
1.7%
1%
0%
North West
Middle
South
Moonee Valley
Melbourne
Source: VCGLR
Whilst Figure 9 shows that the North West has the lowest SEIFA ranking within Moonee Valley
and is the most disadvantaged, it does not have the highest gaming losses by local area. The
highest losses are in the South, which enjoys the high SEIFA rank.
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Figure 9: EGM Losses per Adult by SEIFA Index, Moonee Valley Areas 2010-2011
$1,200
Losses Per Adult
$1,000
South Region
$800
North West
Region
$600
Moonee Valley
LGA
Middle Region
$400
$200
$0
990
1,000
1,010
1,020
1,030 1,040 1,050
SEIFA Index
1,060
1,070
1,080
1,090
Source: VCGLR and ABS
Figure 10 indicates that the highest losses per local area are in the South, where 50% (373) of all
Moonee Valley EGMs are located.
Figure 10: Gaming Losses by Moonee Valley Area 20110-11
North West
Region,
$18,714,501
South Region,
$31,204,294
Middle Region,
$27,178,280
Source: VCGLR
However, the location of gaming losses is affected by the fact that there is only one electronic
gaming venue in the North West. When the losses are analysed by venue as in Figure 11, it is
revealed that the highest losses by venue is in the North West the most disadvantaged area.
Moreover the losses in the North West are linked to only one gaming venue with a 100 EGMS.
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Figure 11: Gaming Losses by Venue per Local Areas, Moonee Valley 2010-2011
South Region,
$6,240,859
Middle Region,
$5,435,656
North West
Region,
$18,714,501
Source: VCGLR
2.4.1 Analysis of Monee Valley Gaming Venues
An analysis of the losses by each venue set out in Table 6 indicates that the losses at the Skyways
Taverner in the North West are substantially higher per EGM than the losses for all for all other
venues in Moonee Valley, with losses per EGM of $187,145 per year and $516 per day per
machine. The next highest losses per machine are at Newmarket Tavern in the South, at
$136,567 per year and $376 per day per machine.
Table 6: Gaming Losses by Venue and EGM by Moonee Valley areas 2010-2011
Suburb
No of
EGM's
Expenditure
2010-11
Expenditure
per machine
Losses
per day
Airport West
100
$18,714,501
$187,145
$516
Cross Keys Hotel
Essendon Football & Community
Sporting Club
Keilor East RSL
Essendon
40
$4,386,704
$109,668
$302
Essendon
100
$6,452,955
$64,530
$178
Essendon
25
$1,861,914
$74,477
$205
Lincolnshire Arms Hotel
Essendon
38
$5,066,833
$133,338
$367
Royal Hotel (Essendon)
Essendon
70
$9,409,873
$134,427
$370
273
$27,178,280
$99,554
$274
Venue
North West
Skyways Taverner
Middle
Middle Total
South
Junction Tabaret
Moonee Ponds
80
$4,979,024
$62,238
$171
Moonee Valley Legends
Moonee Ponds
105
$5,879,936
$55,999
$154
Newmarket
68
$9,286,564
$136,567
$376
North Suburban Sports Club
Moonee Ponds
50
$2,118,792
$42,376
$117
Waterloo Cup Hotel
Moonee Ponds
70
$8,939,978
$127,714
$352
South Total
373
$31,204,294
$83,658
$230
Moonee Valley
746
$77,097,075
$103,347
$285
Newmarket Tavern
Source: VCGLR
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Moreover, when the losses by hotel venue in metropolitan Melbourne are ranked as in Table 7, it
is revealed that the there are only 4 other venues in Victoria that have higher losses than Skyways
Taverner.
Table 7: Top 10 Gaming Venues in Victoria Ranked by Losses 2009-10 to 2010-11
Venue
Suburb
Local Government
No. of
EGM's
Losses
2010/11
Losses
2009/10
1 Year %
change
Epping Plaza Hotel
Epping
City Of Whittlesea
100
$21,019,064
$18,867,109
11.4%
Werribee Plaza Tavern
Werribee
City Of Wyndham
80
$20,633,456
$19,198,073
7.5%
Plough Hotel
Mill Park
City Of Whittlesea
100
$20,239,101
$18,974,503
6.7%
Keysborough Hotel
Keysborough
89
$19,144,975
$18,122,139
5.6%
Skyways Taverner
Airport West
100
$18,714,501
$18,408,686
1.7%
Excelsior Hotel
Thomastown
City Of Greater
Dandenong
City Of Moonee
Valley
City Of Whittlesea
105
$18,632,222
$17,390,512
7.1%
Gladstone Park Hotel
Tullamarine
City Of Hume
86
$18,593,451
$18,105,171
2.7%
Bundoora Taverner
Bundoora
City Of Whittlesea
100
$18,522,787
$18,092,888
2.4%
Seaford Taverner
Seaford
City Of Frankston
105
$18,387,801
$18,049,430
1.9%
Kealba Hotel
East Kealba
City Of Brimbank
86
$17,756,060
$16,553,290
7.3%
Source: VCGLR
Table 8 takes account of the change in expenditure on gaming over the period 2009-10 to 201011. The data reveals that losses have increased for Moonee Valley hotels, with the highest growth
being at the Lincolnshire Arms Hotel (11.9%).
Table 8: Moonee Valley Gaming Venue Losses 2009-10 to 2010-11
Hotel/
Club
EGMs
Losses 2010-11
Losses 2009-10
% change
H
100
$18,714,501
$18,408,686
1.7%
Cross Keys Hotel
H
40
$4,386,704
$4,235,735
3.6%
Essendon Football & Community
Sporting Club
Keilor East RSL
C
100
$6,452,955
$6,766,098
-4.6%
C
25
$1,861,914
$1,865,375
-0.2%
Lincolnshire Arms Hotel
H
38
$5,066,833
$4,527,555
11.9%
Royal Hotel (Essendon)
H
70
$9,409,873
$9,163,321
2.7%
273
$27,178,280
$26,558,086
2.3%
North East
Skyways Taverner
Middle
Middle Total
South
Junction Tabaret
C
80
$4,979,024
$5,232,585
-4.8%
Moonee Valley Legends
C
105
$5,879,936
$5,859,741
0.3%
Newmarket Tavern
H
68
$9,286,564
$8,876,285
4.6%
North Suburban Sports Club
C
50
$2,118,792
$2,310,670
-8.3%
Waterloo Cup Hotel
H
South Total
Moonee Valley
Source: VCGLR 2011
70
$8,939,978
$8,226,961
8.7%
373
746
$31,204,294
$77,097,075
$30,506,242
$75,473,013
2.3%
2.2%
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Moreover, Table 8 shows that the losses are highest at hotels than clubs, even when the clubs
have more gaming machines than hotels. For example, in 2010-11 Essendon Football Club had
100 EGMs and total losses of $6,452,955. Over the same period the Newmarket Tavern with 68
EGMs had losses of $9,286,564.
2.4.2 Patronage of Venues in Moonee Valley and Neighbouring Municipalities
Flemington Racecourse is a popular gaming venue located outside but close to Moonee Valley.
However, the impact of the Flemington Racecourse gaming venue is minimal and gaming losses
there are relatively low as the venue is located within the racecourse grounds and is not easily
accessible to passers-by. Table 9 shows the losses at the Moonee Valley and Flemington
racecourses. The data reveals that the losses annually and per day at Flemington total 53% of
those at Moonee Valley, even though there are only 25 less EGMs at Flemington Racecourse.
Table 9: Flemington and Moonee Valley Racecourses, Gaming Losses 2010-2011
Venue
Flemington
Racecourse
Moonee Valley Race
course (Legends)
LGA
EGMs
Losses
$3,117,545
Losses per
EGM (annual)
$38,969
Losses per day
(overall at venue)
$8,588
Maribyrnong
80
Moonee Valley
105
$5,879,935
$55,999
$16,198
Source: VCGLR
People gamble on EGMs in close proximity to their homes. The City of Moonee Valley Gaming
Policy Paper 2011 proposes using a one kilometre radius for assessing social and economic impacts
of gaming venues outside the municipality.72 However, research indicates that in metropolitan
Melbourne 90% of people reside within 2.5 kilometres of a gaming venue and people travel no
more than 5 kilometres to gaming venues.73 Given this research, Figure 12 maps a 2 kilometre
boundary around each Moonee Valley venue. This analysis reveals a large area of the North West
that is further than 2 kilometres from a gaming venue. However, all parts of the South and
Middle areas fall within 2 kilometres of a Moonee Valley gaming venue, except for the small area
of Strathmore.
72
73
City of Moonee Valley Gaming Position Paper 2011, page 5
Department of Justice 2009
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Figure 12: Locations Within 2 Kilometres of a Gaming Venue within Moonee Valley
Municipal Boundary
Application of a radius of 2 kilometres around the municipal boundary of Moonee Valley
reveals 17 gaming venues, as shown in Figure 13. Furthermore, as indicated in Table 10, the
combined gaming losses from these 17 gaming venues in 2010-2011 was $89,300,720. This is
$12,203,645 more than the combined losses of all Moonee Valley gaming venues for 2010-11.
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Figure 13: Gaming Venues Within a 2 Kilometre Radius of Monee Valley as at December
2011
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Moonee Valley City Council Electronic Gaming Machine Gambling Background Paper
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Table 10: Gaming Venues within 2 Kilometres of Moonee Valley's Municipal Boundary
Venue
Suburb
Local Government
Hotel
/Club
No. of
EGM's
Losses
2010/11
2009/10
86
$17,756,060
$16,553,290
%
change
2009/10
to
2010/11
7.3%
Kealba Hotel
East Kealba
City of Brimbank
H
Anglers Tavern
Maribyrnong
City of Maribyrnong
H
0
$568,427
$714,598
-20.5%
Ashley Hotel
Braybrook
City of Maribyrnong
H
50
$11,741,843
$11,143,966
5.4%
Braybrook Taverner
Braybrook
City of Maribyrnong
H
31
$4,878,738
$5,271,844
-7.5%
Club Leeds
Footscray
City of Maribyrnong
C
30
$3,656,480
$3,290,872
11.1%
Court House Hotel
Footscray
City of Maribyrnong
H
21
$3,513,902
$3,567,170
-1.5%
Highpoint Taverner
Maribyrnong
City of Maribyrnong
H
70
$8,370,154
$8,501,997
-1.6%
Powell Hotel
Footscray
City of Maribyrnong
H
30
$4,312,194
$4,312,568
0.0%
Yarraville Club Cricket Club
Maidstone
City of Maribyrnong
C
76
$10,872,723
$10,102,412
7.6%
Flemington Racecourse
Tabaret
Oasis Oz Hotel
Flemington
City of Melbourne
C
80
$3,117,545
$3,195,416
-2.4%
North Melbourne
City of Melbourne
H
22
$150,204
$621,361
-75.8%
Glenroy RSL
Glenroy
City of Moreland
C
40
$3,757,196
$3,721,691
1.0%
Northcote Park Football Club
Brunswick
City of Moreland
C
85
$4,212,345
$4,093,744
2.9%
Pascoe Vale RSL
Pascoe Vale
City of Moreland
C
47
$2,706,826
$2,584,099
4.7%
Pascoe Vale Taverner Hotel
Pascoe Vale
City of Moreland
H
51
$6,766,303
$6,846,472
-1.2%
Reggio Calabria Club
West Brunswick
City of Moreland
C
34
$1,216,911
$1,367,159
-11.0%
The Brunswick Club
Brunswick
City of Moreland
C
43
$1,702,865
$1,676,866
1.6%
976
$89,300,720
$87,565,527
2.0%
Total within 2kilometers of Moonee Valley's municipal boundary
2.4.3. Moonee Valley Clubs’ Community Contributions
Clubs are required to contribute 8.33% of net gaming revenue to the community. Claims by
clubs for community benefits set out in a Community Benefit Statement (CBS) need to comply
with the Ministerial Order 69 pursuant to the Gambling Regulation Act 200374. The activities and
purposes that constitute community purposes that can be claimed in a CBS are set out in 3
classes:
• Class A - 100% claim for direct community benefit such as donations and voluntary
activates.
• Class B - indirect community benefit claim of equal to the proportion of non-gaming
revenue to the club's total revenue (e.g. revenue 60% from gaming claim only 40%) such
as operating costs (e.g. salaries, on-costs, management, electricity, payment to players and
officials).
• Class C - 100% miscellaneous claim includes activities such as responsible gaming
measures and activity.
Table 11 provides analysis of the contributions made by Moonee Valley clubs for the financial
year 2010-11. The analysis shows the major activities claimed as community contributions by
74
Ministerial Order no. S 69 17 March 2008 pursuant to Section 3.6.9(3) of the Gambling Regulation
Act 2003
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Moonee Valley clubs in their community benefit statements. In summary:
• the clubs in Moonee Valley claim a higher community contribution than the total income
received (as a percent of net gaming revenue), at 234% of income. This is far in excess of
the Victorian average
• the highest claims for community contributions were for operating costs, at 181.82%, again
far in excess of the Victorian average claim of 24.5%
• the Moonee Valley clubs made no claims for contributions to responsible gaming measures
or related activities.
Table 11: Community Benefit Statements 2010-11, Victoria and Moonee Valley 75
Community Benefit Statements Clubs
2010-2011 as at 32.11.2011
2010-2011 Net Gaming Revenue ("NGR")
CLASS
A
CLASS
B
Victoria
Moonee Valley
$891,135,183
$21,292,621
Donations
Sporting activities for Club Members
Subsidy for the provision of goods and services excluding alcohol
1.6%
3.3%
1.3%
2.19%
24.6%
2.67%
Voluntary Services by members or staff to another person in the
community
0.5%
0.45%
Advice, support and services provided by the RSL
0.1%
none
6.9%
0.9%
1.07%
0.03%
0.14%
24.5%
26.69%
30%
22.5%
n/a
n/a
0.7%
181.82%
204.35%
0.0005%
none
Reimburse volunteer expenses
0.02%
0.0086%
CBS preparation and audit
0.03%
0.4%
SUB TOTAL
Capital expenditure
Financing Costs
Retained earnings
Building and plant more than $10,00 not gaming
Operating Costs
SUB TOTAL
Responsible gaming measures and activities
CLASS
C
Percentage of NGR claimed for community purposes
33.74%
234.41%
Source: VCGLR
The three clubs with the highest gaming losses are the Moonee Valley Legends, Essendon
Football Club and the Junction Tabaret. Analysis of the community benefit statements of these
venues for the financial year ended 30 June 2010 is provided below.
Moonee Valley Legends
The total community benefit claim was $45,577,702, while the total revenue (i.e. losses at EGMs)
in the same period was $5,859,741. The community benefit claim includes:
• $28,738 for donations
• $5,042,896 in racecourse preparation and maintenance
• $66,620 for seniors meals
75
Format and categories as per VCGLR listings. Please note that the sub-totals and totals are for all benefits
claimed, not just the ones set out in this table.
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•
•
•
•
•
•
$17,267,233 for prize money and other payments and subsidies
$3,490,750 for catering and Legends operations
$1,637,951 for salaries and wages
$1,491,464 for race day advertising and promotions
$2,417,144 for race day salaries and wages
$1,7250,353 for catering and Legends operations including cost of goods sold.
Essendon Football Club
The total community benefit claim of $2,455,755 included:
• $250,000 for subsidised meals
• $101,856 for philanthropy including a $49,886 donation for the Long Walk Foundation
(indigenous health and education)
• $23,427 for running the Unity Cup with the Australian Police to create social cohesion with
the Muslim community
• $1,530,399 for operating costs including security, light, power and gas and uniforms
• $1,138,061 for wages
• $101,096 for superannuation
• $72,33 for cleaning.
Junction Tabaret
The total community benefit claim of $815,186 included:
• $11,047 for member discounts for meals
• $247,532 for rent
• $406,498 for wages
• $22,573 for management fees
• $1,350 in donations/gifts/sponsorships.
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2.5 Local Area Issues for Consideration
Issues Across the municipality
• Losses are higher at hotels than clubs, even when the clubs have more gaming machines than
hotels.
• In 2010-11 the 17 gaming venues located outside of but within 2 kilometres of the Moonee
Valley municipal boundary had total gaming losses of $89,300,720. This is $12,203,645 more
than the total losses at Moonee Valley gaming venues for 2010-11.
• The clubs in Moonee Valley claim a higher community contribution than the total income
received (as a percent of net gaming revenue) at 234% of income. This is far in excess of the
Victorian average (33.7%).
• The highest claims for community contributions were made for benefits to club members
rather than the broader community with:
o claims for operating costs at 181.82%, far in excess of the state average claim of 24.5%
o no claims for contributions to responsible gaming measures or related activities.
South - Moonee Ponds, Ascot Vale, Flemington, Travancore
• In 2010-11 the South had the highest number of gaming machines (373), the highest losses
per household ($2,100) and highest losses per area ($31, 204 294).
• The Newmarket Tavern showed annual gaming losses in 2010-11 of $136,567, with losses
per machine at $376 per day, the second highest losses per venue in Moonee Valley.
• There is at least one Moonee Valley gaming venue within 2 kilometres of all locations in the
South.
• In 2010-11 the Moonee Valley Legends claimed a total community benefit of $45,577,702
against total gaming revenue of $5,859,741. The community benefit claimed included
$17,267,233 for prize money and other payments and subsidies
Middle - Aberfeldie, Essendon, Essendon North, Essendon West, Niddrie, Strathmore,
Strathmore Heights
• In 2010-11 the Middle had the second highest number of gaming machines (273), losses per
household ($1,760) and losses per local area ($27, 128).
• The Middle had the highest growth in annual losses per venue from 2009-2010 to 2010-11 at
the Lincolnshire Arms Hotel (11.9%).
• Only a small area of Strathmore has no Moonee Valley gaming venue within 2 kilometres.
North West - Airport West, Avondale Heights, Keilor East
• In 2010-11 the North West had only one gaming venue, the Skyways Taverner. As such the
area venue has the lowest number of gaming machines (100), lowest losses per household
($1,559), and losses per local area of $18,714,501.
• The North West had the lowest SEIFA ranking and is the area with the greatest
disadvantage.
• The Skyways Taverner records substantially higher gaming losses per machine than all other
venues in Moonee Valley. In 2010-11, annual gaming losses were $516 per day per machine.
• Skyways Taverner recorded the 5th highest losses per venue in Victoria in 2010-11. In 200910 it recorded the 4th highest loses per venue in Victoria
• Within the North West a large area is further than 2 kilometres from a Moonee Valley
gaming venue.
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Glossary
ABS
Australian Bureau of Statistics
ATM
Automated teller machine
CALD
Culturally and linguistically diverse
EGM
Electronic gaming machine
MVCC
Moonee Valley City Council
PGI
Propensity to gamble index
SEIFA
Index of Relative Socio-Economic Disadvantage
VCAT
Victorian Civil and Administrative Tribunal
VCGLR
Victorian Commission for Gambling and Liquor Regulation
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•
•
•
•
•
•
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February 2012
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