Industry's Biggest Threat - Territorial Authority Gambling Venue Policies - Are We Being Heard?

The gaming industry in New Zealand is now one of the most heavily regulated in the world.  The last three years has seen the introduction of a long list of new regulations.  It is unlikely that there will be any further major legislative or regulatory constraints imposed in the near future.  The major restriction which the industry now faces is Territorial Authority Policies which prohibit any new venue with gaming being established or an existing venue with gaming relocating.

Any venue that wishes to relocate or any new venue must obtain Territorial Authority consent.  Whether consent is granted depends on the restrictions contained in the local Territorial Authority Policy.  The majority of policies permit a set number of gaming machines within their district.  However there is an alarming trend for the limit on machine numbers to be reduced severely or for all new venues to be prohibited.

Every three years each Territorial Authority must review its Gambling Venue Policy.  The majority of the policies are currently being reviewed.  The review process enables feedback to be provided on the existing policy, written submissions to be made and an opportunity to speak to Council at a Council hearing.  The consultation process is a valuable process which gives people involved with gaming a real opportunity to influence the policy which will be set for the next three years.

It is unfortunate however that Council hearings are being dominated by well funded and well organised anti-gambling organisations.  Christchurch City Council indicated that it proposed to amend its policy from prohibiting new venues to providing no restrictions whatsoever.  Only a handful of Gaming Trusts made submissions in support of the proposed policy amendment.  Only a very small number of grant recipients made submissions detailing the value and importance of community funding which gaming provides.  In contrast hundreds of submissions were made in opposition to the proposed changes.  The problem gambling organisations not only made a submission themselves but also arranged for personal submissions to me made by their clients and staff.  The problem gambling organisations quoted statistics suggesting that 25% of all people who play gaming machines become problem gamblers.  The prevalence rate of problem gambling is in fact approximately 1.2%.  At the conclusion of the consultation process the Christchurch City Council noted that over 97% of the submissions received opposed removing the restrictions and accordingly voted to return to a policy which prohibits any new venue being established.

The Christchurch experience confirms how important it is for the industry to make submissions to Councils and to provide Councils with accurate statistics on gaming machines numbers and problem gambling prevalence in New Zealand.  The experience also illustrates how important it is for the silent majority to be represented and for grant recipients to communicate to Councils the benefit that gaming provides and thus provide some balance to the submissions which are received.

In order to ensure that gaming and community funding has a future in New Zealand it is critical that the industry is well represented at all Council hearings.  All Gaming Trusts should make written and oral submissions to the Councils where they have machines.  Grant recipients should be made aware of any upcoming consultation process and invited to make a brief submission detailing how gaming funding has assisted their organisation.

As detailed above most Councils are further reducing the number of machines and venues that are permitted in their district.  Such an approach does not however appear justified and reasonable in light of the following:

• Gaming machine numbers have naturally declined by 18.4% in last three years.

• Venue numbers have decreased by over 100 in the last two years.

• The decline in non casino gaming machines has resulted in a decrease in the amount spent on non casino gaming machines but an increased spend on TAB betting, casino betting and lotto, all of which have a lower return to the player and provide a lower percentage of return (if any) to the community.

• A reduction in machine numbers reduces the amount of community funding available.  The restriction reduces casual/recreational play.  Reducing machine numbers does not however reduce the prevalence of problem gambling as a person who is addicted to gambling will simply travel the short distance to the next venue which has gaming machines or use other forms of gambling such as internet gambling.  Despite gaming machine numbers doubling between 1999 and 2003 the prevalence of problem gambling fell during the same period.

• The latest research from Professor Max Abbott indicates that restricting gaming machine numbers has little if any impact on problem gambling prevalence.  This research is supported by the experience from other countries including Australia who have found that a restriction on gaming machine numbers has no corresponding impact on problem gambling.

What is certain is that the further restrictions that the majority of Councils are looking at imposing will reduce the amount of community funding which is available.  The community funding which gaming provides is the lifeblood of thousands of community organisations as traditional forms of fundraising become inadequate to meet the costs of most modern projects.  In order to ensure that community funding continues to be available it is critical that all Gaming Trusts make strong submissions to all the Councils where they have venues and that grant recipients be encouraged to make a submission highlighting the benefit that gaming funding provides and thus give balance to the consultation process.

Jarrod is happy to provide information on the various Territorial Authority Policies that exist and details of the review process.