Monday, 7 December 2009

Productivity Commission Public Hearings

Here is an outline of the submissions I intend to make at the Productivity Commission public hearings next week in Brisbane.

1. Focus on solutions that minimise harm to the problem gambler without affecting the recreational gambler.

I endorse the Productivity Commission’s approach without reservation. I have publicly urged adoption to the media, pokie operators and government. Submissions 2-6 hereof are put to support this focus.

2. Need for Prescriptive legislation

The overwhelming practice is to comply only with the letter of the regulation. Shareholders urged cost efficient measures to be adopted by Woolworths Limited without success.

  • Promotion of Self Exclusion
  • Effective placement of gambling warnings on pokie and in toilets and smoking areas
  • Erection of Car Parks signs warning about leaving children in cars
  • Simultaneous play prohibition

3. An example of lack of consumer information.

Victorian PID disclose RTP differential between 1¢, 2¢ and $1 pokies. Practice encourages far greater expenditure in exchange for longer gambling time.

I referred the Commission to the ALH undertaking on page 7.2 of their draft report about informed consumer choice. Easy to inform gamblers yet little is done.

4. Exposure of Children to gambling

Coles’ acceptance of National Principles vs Woolworths / Clubs NSW refusal. Implementation issues with Coles – e.g. where environments created to get gamblers back in the room and keep coming back. Updated explanation of ‘normalisation’. Kids Club ad and other pokie venue’s direct appeals to children. Emulation of gambling through coin operated games of chance programmed for repeat expenditure.

5. The immediate solution - $1 per button push

To achieve a $120 loss per hour as a result of $1 per button push requires a prescriptive solution. The reality of the spin cycle over which the RTP emerges must be taken more fully into account. The spin cycle also impacts upon “safe mode” alternative schemes of pokie gambling.

6. Consumer Sovereignty - an ideal pre-commitment model

When is it exercised? Given the harm of the product for problem gamblers, it should be exercised twice and no more; firstly, at the time the choice is made to gamble, secondly, at the time the decision to opt out of the default pre-commitment expenditure / time spent gambling levels and access higher expenditure / gambling time.

7. Transparency – Three realities

  • Pokie management agreements in Victoria. While not advocating against the practice, these arrangements exploit taxation concessions and confer effective control on non-licensees. They should be subject to public scrutiny, public approval and market control limitations rather than present secrecy.
  • Success in urging and achieving disclosure of Victoria per venue losses has allowed for better social planning.
  • PokieWatch.org model – open disclosure of environment leads to improved measures. Both regulator & venue operator should post all observations.

Public disclosure of information concerning the programming and operation of the pokies themselves is urged.

8. Pokie Clubs / Mutuals

Is the preferential taxation and regulatory treatment of clubs merited when weighing community benefit against pokie gambling losses? Pokie losses appear to outweigh public benefit. Reduction in pokie gambling harm and more effective taxation may achieve a better result. Analysis in Betty Con Walker’s book on NSW Casino Clubs should be considered. New Victorian legislation lifts need to be a sports club in Victoria to avoid income taxation.

I emailed these submissions to the Commission today.