Kedron Wavell Services Club - Office of Liquor, Gaming and Racing ...

Queensland Government
Red tape reduction and other reform proposals
for regulation of liquor and gaming
Discussion Paper
Submission by Kedron-Wavell Services Club
15th March 2013
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Introduction
Kedron-Wavell Services Club is delighted to respond to the State Government’s Red tape
reduction and other reform proposals for regulation of liquor and gaming Discussion Paper.
This submission has been written for the benefit of our members and community and we therefore
give permission for this document to be viewed in the public domain.
Background on Kedron-Wavell Services Club
Kedron-Wavell Services Club Inc. (“KWSC”) is a not-for-profit community club established over 40
years ago. It currently employs 220 staff including management, administration and operational
staff and is responsible for indirectly creating work for thousands of other people through
associated industries.
Club facilities include:
• Entertainment including live concerts, daytime shows, free movies, free live music and
family entertainment
• Prize winning promotions and gambling including bingo, daily promotions, membership
draws, Keno, TAB and 280 gaming machines
• Functions and events including eight function areas with seating for between 16 and 500
people which are used regularly by the community for events ranging from corporate
meetings to weddings
• Dining including a buffet restaurant, a la carte restaurant and newly renovated café style
dining facility
• Two additional bar areas plus a bottle shop are also available for patrons relaxation and
convenience.
As home to a returned services club, Kedron-Wavell respects various traditions and anniversaries
as they occur. For example, as a mark of respect to comrades in arms the Club lights are turned
out at 7.00pm every night and the RSL Ode is recited to all in attendance. During the Ode, all in
the Club are expected to stand in silence and face the Club’s symbol of the eternal flame. No
other activity continues in the Club during the reciting of the Ode.
The Club injects $25 million into the State economy annually and in conjunction with the Kedron-
Wavell RSL Sub-Branch (“KW RSL Sub-Branch”), is responsible for delivering approximately
15,000 volunteer hours to the community each year.
KWSC and the KW RSL Sub-Branch provide a range of facilities for all ages from Kids Club
activities to senior craft classes culminating in visitations to the Kedron-Wavell precinct of
approximately three quarters of a million people per year.
As a not-for-profit organisation, every dollar generated by KWSC is invested back into the
community or used to enhance service and facilities for members. Each year KWSC’s voluntarily
contribution averages $1.5 million in cash and in-kind donations.
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KWSC prides itself on not only donating to nation and state-wide charities, but more importantly,
supporting those local organisations at the grass roots. Every year, the Club supports a variety of
locally-based groups, community events and fundraising initiatives in one or more of the following
ways:
• In-kind Support
• Community Projects
• Sponsorship
• Cash Donations
• Support to organisations applying for community benefit funds
• Welfare assistance to members of the local community
• Sponsorship of junior and senior sport at all levels of competition
• Work experience and educational tours for schools
• Professional assistance to regional and community projects and industry support
• Frequent donation of prizes to surrounding schools and sporting organisations
• Administration assistance
The Club frequently donates prizes, provides free room hire, or offers assistance to organisations
or individuals coordinating fundraising events at KWSC. The Club provides administrative support,
catering, and use of facilities at a discounted rate or free of charge.
In 2012 Kedron-Wavell supported its community with $100,000 each allocated in $1,000, $2,500
and $5,000 Community Investment Grants, allowing as many organisations as possible to benefit.
Over 50 organisations were fund recipients including Geebung Special School, Be Uplifted,
Chermside & Districts Historical Society and the Nundah Community Enterprise Co-Operative.
With many private organisations facing the pressure of a global economic downturn, community
sponsorship is difficult for many local groups to attract and retain. In many situations the support
provided by Kedron-Wavell is integral to keeping them operating.
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Response to specific points raised in the Red tape reduction and
other reform proposals for regulation of liquor and gaming
Discussion Paper
1.2 Persons trained in Responsible Management of Licensed Venues (RMLV) taken to be
trained in Responsible Service of Alcohol (RSA)
The following proposal is supported:
Option 1 – accept the proposal (accept that persons trained in RMLV are trained in RSA).
The Kedron-Wavell Services Club has developed a Risk Assessed Management Plan (RAMP)
to provide leadership in all aspects of Club service and management and ensure that its
members and guests are provided with a safe environment. Kedron-Wavell Services Club
has carefully developed these guidelines in accordance with Queensland liquor licensing
legislation and consulted widely to develop guidelines to assist its management and staff in
understanding their roles and responsibilities in the workplace. The RAMP informs patrons
how staff are trained in ensuring the responsible service of alcohol and that staff training
on matters of patron care is a priority for the Club.
All Kedron-Wavell Services Club operational employees are trained in the responsible
service of alcohol (RSA). The Club also embraces staff development programs which see
staff careers grow and staff elevated from service areas to management, whilst still being
required to work in service areas from time to time.
The Club supports a consolidation of RSA training with the Responsible Management of a
Licensed Venue (RMLV) training into a single course with one expiry date and renewal
procedure.
This support would be reliant on the consolidation having no impact on the quality of the
training and therefore not compromise the high standards of Kedron-Wavell Services Club.
The Club supports a consolidation based on reducing duplication and related costs such as
applications fees and lost work hours through repeat and unnecessary training. Such
streamlining also has benefits for employees who will experience more clarity regarding
their training registration status.
1.3 Re-examining liquor trading hours, lock-outs and drink safe precincts.
The Club does not have a detached bottle shop; therefore this change does not apply to
us.
1.4 Re-examining liquor trading hours, lock-outs and drink safe precincts
The following proposal is supported:
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Maintain the status quo, with an end to the current moratorium on applications for post-midnight
trading outside of entertainment precincts.
Located in the outer suburbs of Brisbane, Kedron-Wavell Services Club offers a
geographical choice in where people can drink and socialise. The large majority of its
patrons drink responsibly and incidents of anti-social behaviour are very rare.
The lifting of the moratorium on applications for late night trading will increase options for
how the Club services its patrons and remove the unnecessary time consuming regulation.
The demographics of the Kedron-Wavell catchment are changing. Proximity to the airport
has increased opportunities for fly-in fly-out workers to live locally, a rise in apartment
development has increased the number of professionals in the area, and an expanding
hospital has grown the number of local shift workers. Community clubs need regulatory
flexibility to respond to this change and provide a modern service for members and guests.
Drink safe precincts (DSPs) and lockouts encourage shared responsibility whereby the
obligations of the licensee are complemented by the responsibilities of the individual.
Overall, these measures appear sound and are delivering the intended outcome through
reported improved safety.
1.5 Remove regional boundaries under the club gaming machine entitlement
reallocation scheme
The following proposal is supported:
Option 1 – accept the proposal (remove the regional boundaries inherent to the club reallocation
scheme).
Kedron-Wavell Services Club supports the removal of the three Queensland regional
boundaries currently defining where clubs can buy and sell their gaming machine
entitlements. The removal will allow clubs to more widely trade gaming machine
entitlements, whilst still adhering to their community and member responsibilities.
Requirements, such as the Community Impact Statement (CIS), needed when applying for
an additional 20 or more gaming machines, already consider the community and social
costs of increased gaming machines.
1.6 Amending the “high risk” glassing classification
The following proposal is supported:
Remove the “high risk” glassing provisions while retaining the discretion for the chief executive to
place conditions on licences regarding the removal of regular glass.
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Current venue classification laws are arbitrary and effectively state that a single glassing
incident or one unacceptable level of violence, during a 12 month period can place a venue
in the “high risk” category - regardless of the processes that venue had in place to prevent
it happening.
The large majority of Kedron-Wavell Services Club members are over 45 years of age and
drink responsibly, yet the Club has itself faced the very real threat of a high risk
classification. Recently one misreported action had the potential to cost the Club
thousands of dollars causing the replacement of regular glass containers, increased
insurance and a tarnished reputation. This cost would have had a major effect on the
service and facilities provided to members and visitors.
The current legislation provides little scope for fully investigating allegations and provides
little avenue for reconsideration.
By adhering to existing industry regulations and implementing its own strict staff training
and acceptable behavior policies, Kedron-Wavell Services Club is actively preventing
incidents of anti-social behaviour.
The Club supports the removal of the high risk glassing provisions.
1.7 Reviewing online liquor sales.
The Club is not involved in online sales; therefore this does not directly apply to us.
1.8 Review laws relating to additional club premises (greenfield sites and
amalgamations)
The following proposal is supported:
Option 1 – accept the proposal (review laws related to additional club premises).
Existing legislation prevents Kedron-Wavell Service Club from supporting smaller clubs in
the area despite it possibly having the means to do so either through funds, a sharing of
facilities or expertise.
With a catchment extending many miles in all directions, a possible recipient of Kedron-
Wavell’s support may also not qualify as being ‘near’ which is an existing legislation
requirement.
Kedron-Wavell Services Club is a community based not-for-profit organisation whose
culture is built on servicing the community. Clubs are a vital part of community
infrastructure and smaller venues are at risk of decline without support or reliable long
term community infrastructure.
Laws relating to additional club premises such as caps on gaming machines irrespective of
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the number of club venues, and higher taxes from combined revenue of amalgamated
clubs, make it difficult for larger clubs to help smaller venues. Removal of such barriers will
help facilitate the establishment of new community clubs in greenfield sites and to securely
assist smaller clubs.
Removing these barriers will also put community clubs on a level playing field with hotels,
which are not restricted by such barriers when establishing venues in a new site.
1.9 Reducing State-imposed event costs
The following proposal is supported:
Option 1 – accept the proposal (review requirements for major events).
As a community focused Club, Kedron-Wavell is supportive of community events some of
which may need to be held away from the Club itself, such as at a local sporting venue or
community park. The current requirements by the Office of Liquor, Gaming and Racing,
such as event management plans six weeks in advance of the event, planning meetings
and consultation logs, take our staff away from their formal duties. This not only adds to
the cost of supporting the event, but can prevent staff from normal member servicing
activity at Kedron-Wavell Services Club.
By reducing these onerous requirements, and subsequently reducing the costs to support
or host events away from the Club premises, Kedron-Wavell Services Club will be able to
support more events, which themselves have flow on advantages for the community.
1.10 Providing for the licensing of second-hand dealers of gaming machines
The following proposal is supported:
Option 1 – accept the proposal (provide for the licensing of second-hand dealers).
Kedron-Wavell Services Club supports the licensing of small businesses wishing to trade
exclusively in second-hand gaming machines. Licensing dealers will help increase the
transparency of this business activity ensuring a fair environment for clubs to trade in and
helping protect the revenues and assets of the clubs.
2.1 Streamlining gaming administration provisions
The following proposal is supported:
Option 1 – accept the proposal (streamline gaming administration provisions into one Act).
The operations of Kedron-Wavell Services Club are governed by several different Acts. The
process of applying and ensuring conformity to all requirements is a cost to the Club, not
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only in application and renewal fees but also in staff time which would be better spent
servicing our members.
Consolidation of the gaming laws is a practical solution which will help reduce time and
costs. It also helps reduce the potential for inefficiencies, inconsistencies and possible
confusion.
Kedron-Wavell Services Club supports a single gaming administration law which
consolidates the common administrative matters, such as licensing, compliance and
appeals, and which contains provisions for specific issues relating to particular industries.
2.2 Ceasing involvement of liquor inspectors in fire safety regulation
The following proposal is supported:
Option 1 – accept the proposal (remove fire safety provisions under the Liquor Act).
The safety of Kedron-Wavell’s patrons and staff is paramount and the Club has extensive
processes in place to ensure the systems, equipment and training are maintained to
protect patrons should an unforeseen incident occur. The Club is confident in its systems
and supports the need for checks by relevant regulatory authorities.
However, checks by two regulatory authorities, the Office of Liquor, Gaming and Racing
and the Queensland Fire and Rescue Service, represent duplication and incur unnecessary
staff time.
Kedron-Wavell believes regulations regarding fire safety issues are best placed under the
respective fire safety laws, which provide a framework for fire safety standards. Regulating
fire safety is a specialist area that is capably managed by the Fire and Rescue Service.
2.3 Reviewing liquor and gaming subordinate legislation
The following proposal is supported:
It is proposed that a review be undertaken with respect to expiring liquor and gaming subordinate
legislation. Because a review is required by the SIA, no options are put forth but input into the
review is sought.
Kedron-Wavell Services Club is impacted by managing the eight liquor and gaming Acts
due to expire on September 1, 2013. The Club supports a review to ensure the regulation
remains “contemporary, effective, efficient and user-friendly”. To ensure responses best
reflect member needs, Kedron-Wavell would require appropriate time and opportunity to
provide comprehensive input into the liquor and gaming subordinate regulations.
The Club believes this comprehensive review requires a separate submission.
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2.4 Reviewing the disciplinary provision under the Liquor Act
The following proposal is supported:
It is proposed to review section 137 of the Liquor Act to determine whether a legislative
amendment or other step is required to clarify the intent of the disciplinary action provision. Input
into the review is requested from industry and the public. Because a review is proposed, no
options are put forth.
Kedron-Wavell Services Club works hard to fulfill its obligations to provide and maintain a
safe environment. The Club accepts responsibility for what is within its power to manage
and is prepared to be judged on how well it meets that responsibility.
Regulation that takes disciplinary action against a club because of what could not be
foreseen represents a major risk to the viability of that club. There should be no ground to
take disciplinary action against a venue in relation to events that could not have been
foreseen or prevented.
2.5 Noise controls over liquor licensed premises
The following proposal is supported:
It is proposed that noise restrictions under the Liquor Act and the enforcement of noise
restrictions be reviewed. Because a review is proposed, no options are put forth.
Kedron-Wavell Services Club is located in a suburban area of Brisbane bordered by mostly
commercial and supporting facilities with some housing. More recently the area has seen
an increase in residential apartment dwellings. The Club is respectful of all its neighbours
whilst also providing the service and facilities for which it was built, and under which
members were attracted.
As a public facility, Kedron-Wavell aims to offer exciting and engaging entertainment for its
members. It has also invested in a range of entertainment facilities which provide a
valuable source of revenue to fund member benefits. This revenue helps keep the Club
sustainable and able to continue to support so many community groups who use the
facility for fund raising and community events.
The Club recognises that noise control is a contentious matter and suggests that any
review recognise first occupancy rights when the venue existed before a residential area
was developed. All licensed facilities are in different locations and offer different styles of
entertainment. Allowable noise levels should be judged on a case-by-case basis and not be
based on arbitrary limits.
2.6 Providing local governments with a greater say in licensing decisions
The following proposal is supported:
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Option 2 – reject the proposal (do not provide local government with a greater say in licensing
decisions).
This proposal is detrimental to the long-term interests of the liquor and gaming industry.
This is because local governments often do not have the foresight of a statewide regulator
and may be easily persuaded by a few vocal groups or individuals with vested interests in
the local community.
The current provisions in the laws offer local government an adequate level of consultation
and this should not be increased.
3.2 Reviewing gaming machine maximum bet
The following proposal is supported:
Option 1 – increase maximum bet to $10 on club and hotel gaming machines.
Kedron-Wavell Services Club supports increasing the maximum gaming machine bet from
$5 to $10 recognising that the existing limit was set 18 years ago when the value of $5
was significantly lower.
Patrons using the gaming machines face restrictions not placed on other gambling offers
such as horse racing and lotteries. Visitors to NSW clubs also experience the higher betting
limits. Consistency across all areas will help clubs like Kedron-Wavell better meet the
expectations and interests of all members and visitors.
3.3 Reviewing cash input restrictions on gaming machines
The following proposal is supported:
Option 1 – lift the prohibition to allow the use of any Australian banknote in all Queensland
gaming machines, and increase the cash input limit at clubs and hotels.
Allowing players to use any Australian banknote in a gaming machine will not only be more
convenient for them, but will reduce the costs of cash handling incurred by clubs such as
Kedron-Wavell. Many ATM machines issue $50 and $100 notes before offering smaller
notes. As patrons visit the Club these notes have to be changed incurring costs and staff
time which could be spent better servicing patrons.
Of all the eastern states, Queensland is the only jurisdiction that does not allow the use of
$50 notes and it has the lowest specified cash input limit of all Australian jurisdictions.
Consistency across all states will help clubs meet the expectations of members and
visitors.
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3.4 Reviewing hours of operation
The following proposal is supported:
Option 2 – Lift the prohibition on gaming before 10am for those clubs and hotels that can
demonstrate community need and have adopted voluntary pre-commitment.
Kedron-Wavell Services Club is located in a very diverse community. It is close to the
airport attracting a fly-in fly-out workforce, it has a growing hospital with increased shift
workers and increased apartment living has attracted a more diverse range of professional
workers. For these and other reasons, many residents in the Kedron-Wavell catchment do
not work traditional hours. For many, the early hours in the day are technically “after
work” hours and are a time for an after work drink and relaxation.
Kedron-Wavell members and visitors live in a 24/7 economy and expect availability to
most things due to convenience and proven need. Community clubs need to respond to
these trends by acting as social outlets and meeting places, which are safe, familiar and
friendly, and offer the suite of services that people desire when they need them.
Kedron-Wavell is dedicated to serving its members and local communities by providing a
modern and competitive offering. Like most community clubs, most Kedron-Wavell patrons
consume alcohol responsibly and gamble responsibly.
Lifting the prohibition on gaming before 10am would allow Kedron-Wavell to better meet
the changing needs of its patrons whilst also growing a range of other complimentary
services such as increased meal offerings and events.
3.5 Moratorium on extended liquor trading hours
The following proposal is supported:
Option 3 – Allow the moratorium to end and consider a strategy to transform the night time
economy to encourage a broader range of locations and a broader range of consumers.
Located in the outer suburbs of Brisbane, Kedron-Wavell Services Club offers a
geographical choice in where people can drink and socialise. The large majority of its
patrons drink responsibly and incidents of violence are very rare.
The moratorium was put in place as a temporary measure based on incidents in areas far
from many community clubs. Although geographically distanced from Fortitude Valley and
Surfers Paradise (recognised as areas of concern) the moratorium has prevented
community clubs from applying for extended trading on a permanent basis.
There is a community need for extended trading hours in view of the changing social
trends and population characteristics. The demographics of the Kedron-Wavell catchment
are changing and now include greater fly-in fly-out workforces, more shift workers and
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more young professionals. Forcing this clientele to go elsewhere for evening entertainment
is an inconvenience for members.
The intended purpose of the moratorium is now well and truly met through ongoing
reforms and it should be lifted so that applications for late night trading are once again
considered on merit.
3.6 Restrictive trading on days of cultural significance
The following proposal is supported:
Option 1 – remove the trading hour restrictions to allow normal trading on Anzac Day, Good
Friday and Christmas Day.
As a Returned Services Club, Kedron-Wavell already offers its members extended services
and access on Anzac Day. This is possibly the most significant day of the year for the Club
and it highlights the value of the extended trading hours.
The value of these days to Returned Services Club like Kedron-Wavell must be protected
from any unintended consequences of extending trading to all licensed venues.
Kedron-Wavell supports clubs opening on days of significance based on their members’ and
local community needs.
Signed on for and on behalf of
KEDRON-WAVELL SERVICES CLUB INC.
Lyndon Broome
Secretary/Manager
15 th March, 2013.
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