Thursday, 22 January 2009

Will the 2nd Submission get censored too?

Making submissions to government inquiries on pokies regulation is off topic for the PokieAct.org goal of making pokie places kid free. It is made even more off topic by government or industry declining to place the issue on the agenda for discussion.

Nevertheless, I have decided to work within the system, provide the best suggestions I can come up with on other pokie related matters and hope that this positive input will raise the stature of PokieAct.org so that industry and government will, eventually, act on excluding children from pokie places.

While you can read my second submission by clicking here, here is a summary of what I put forward.
  1. I stated my concerns about the censorship of my previous submission but concluded that it would not assist best practice regulation of pokies by arguing about the Department of Justice's actions at length.
  2. The 35% cap on ownership should apply not only to pubs but also to clubs.
  3. The draft bill was confusing as it seemed to allow for easy avoidance of the cap. It alaso reserved final determination of this matter to a process that excluded public input.
  4. Management agreements should be taken into account in detrmining the 35% cap. In support, I reproduced the determination of the Victorian Gaming Authority and their conclusion about:
    "the increasing trend of clubs with gaming licenses being seen as attractive investment vehicles for private investors"
  5. Management arrangements should be on the public register.
  6. The government should be applauded for adopting a process whereby bidders for future pokie enitilements will be pre-qualified .
  7. Under the heading of Local Imapct Assessments, I referred to other submissions which called upon the government to provide more certainty in the process of applying for pokie entitlements. While the provision of information was a positive step, the government has not gone far enough to provide applicants and local government a common base of information.
Adoption of suggestion 7 will go a long way in avoiding expensive adversary proceedings relating to these new entitlements. The most recent decision of the VCGR regarding Club Edgewater in the City of Footscray, released on Christmas Eve, totalled over 130 pages, took weeks to hear, involved expensive consultants, and is being appealed is an example of what could be avoided.

Now... let's see what bits of what I said above; that the Department of Justice determine that the public should not see.

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