Gallopers Sports Club - Office of Liquor, Gaming and Racing

Gallopers 

SPORTS CLUB 

11 March 2013 

Liquor and Gaming Red Tape Reform 

Office of Regulatory Policy 

Department of Justice and Attorney-General 

Locked Bag 180 

CITY EAST O.LD 4002 

By Email: redtapereform@justice.qld.gov.au 

Dear Sir/Madam, 

Re: Liquor and Gaming Red Tape Reform 

I am writing in regard to the Government discussion paper regarding liquor and gaming red tape 

reform and other reform proposals for the regulation of liquor and gaming. Gallopers Sports Club 

has no objection for this submission to be open for public scrutiny. 

Please note that a separate submission has been made by Gallopers Sports Club parent entity, 

Brisbane Racing club. 

Support for reforms 

Gallopers Sports Club supports the Government intention to ensure Queensland’s gaming 

industry remains the cleanest in the world and also its commitment to cutting red tape that 

unnecessarily adds to business costs. Gallopers Sports Club supports the development of a 

vibrant entertainment and tourism industry. Gallopers Sports Club understands its 

contribution towards employment, leisure and the local community. For example, the 

economic impact ofAAMI Stradbroke Day 2012 is set out below: 

3,440 visitors from interstate 

645 visitors from overseas 

23,814 visitor nights were generated 

Brisbane Racing Club Ltd 

TradingAs Gallopers Sports Club 

Cnr Nudgee & Lancaster Roads, Ascot 

PO Box 817 Hamilton Central QLD 4007 

Telephone: 07 32681841 

f,’ax: 07 3868 2269 

EmaiI: info@galloperssportsclub,com.au /IBN: 80133 679 786 

galloperssportselub.eom.au I ACA: 133 679 786 

Home of fl~e Hamilton Bowls Club 

and Queensland Boolunakers Club


SPORTS CLUB 

$10.32m spending in Queensland 

600 casual staff 

90 full time staff 

76 horses from interstate and overseas 

The sport of thoroughbred horse racing is under pressure in Queensland from competition 

interstate and overseas. More flexible regulation of both the liquor and gaming industries is critical 

to the improvement of horse racing in Queensland. 

Background 

Gallopers Sports Club core activity is wholly owned by Brisbane Racing Club Ltd. Gallopers Sports 

club operated 91 Gaming Entitlements. It is the home of the Hamilton Bowls Club and maintains 

two bowling greens for the bowls club. 

Objectives 

The objective of Gallopers Sports Club is the encouragement, promotion and development of 

thoroughbred horse racing and other incidental related purposes, and to carry on any other activity 

which directly or indirectly enhances or furthers the interests of thoroughbred horse racing. 

Data 

Number of members 9,200 

Number of full time employees 3 

Number of part time employees 30 

Community Support 

Please note the figures below represent the joint contributions from Brisbane Racing Club and 

Gallopers Sports Club. 

Non 

Item Cash Cash Total 

Per Annum 

Cash donation to bowling club 75,000 75,000 


’lYadingAs Gallopers Sports Clnb 

Cnr Nudgce & Lancaster Roads, Ascot 


Telephone: 07 32681841 

Fax: 07 3868 2269 

Emaih info@gallope~sportsclub,com.au 

galloperssportselnb.eom.au 

ABN: 80133 679 786 

ACA5133 679 786 

Home of the H,’unil ton Bowls Clnb 

and Qneensland Bool~anakers Clnb


SPORTS CLUB 

Maintenance of bowling greens 50,000 50,000 

Provision of bus to bowling club 5,000 5,000 

Provision of free use of greens for community bowling 5,000 5,000 

Maintenance of equestrian/community sports field 50,000 50,000 

Depreciation of equestrian/community sports field 58,000 58,000 

Equestrian/community sports field for use by community 25,000 25,000 

Sponsorship/donations - bowling club 7,500 7,500 

Sponsorship/donations - general community/charities/schools 25,000 25,000 

Maintenance of local school/club sports fields e.g. Brothers RFC 50,000 50,000 

Winter carnival school art competition 5,000 5,000 

Provision of new shed to Scouts Qld - rent free 50,000 50,000 

Refurbishing Hamilton Scout hall for community use 100,000 100,000 

Charlie Pratt leukaemia fundraiser 2,000 18,000 20,000 

Kristy Banks Fundraiser 10,000 10,000 

Autism "Inside Origin" Fundraiser 2,000 2,000 

Ronald McDonald House 1,000 2,000 

Steve Kernohan Fundraiser 4,500 4,500 

Brighton Roosters Rugby Club 1,110 1,110 

SUBMISSIONS ON RED TAPE REDUCTION PROPOSALS 

1.1 Removing the regulatory approval for approved managers of low risk venues 

Gallopers Sports Club supports Option 1 - accept the proposal (remove requirement that certain low 

risk venues retain approved managers). 

This proposal should be extended to include low risk venues. Low riskvenues will still need a 

suitably qualified manager to manage the sale and service of alcohol; however it is suggested low 

riskvenues should not be required to complete the application for regulatory approval of the 

approved manager.This is beneficial, as removing this application requirement means that low risk 

venues would not be required to pay the application fee and would not need to complete the 

associated paperwork. 

1.2 Persons trained in Responsible Management of Licensed Venues (RMLV) taken to be trained in 

Responsible Service of Alcohol (RSA) 

Gallopers Sports Club supports Option 1 - accept the proposal (accept that persons trained in RML V 

are trained in RSA). 


Tradh~gAs Gallopers Sports Club 



Telephone: 07 32681841 

l:a.v: 07 3868 2269 

Email: info@galloperssportsclub.com.au 

gallopersspor tselub.eom.au 

ABN: 80133 679 786 

ACN: 133 679 786 

Home of the Hmnilton Bowls Club 

and Queensland Boolunakers Club


SPORTS CLUB 

This is a commonsense approach to consolidate two courses with overlapping contents into a single 

course (with one expiry date). It represents significant cost savings (time and money) for the 

industry, as clubs will not be required to train their employees twice (one for RSA and one for 

RMLV). For employees, the proposal removes confusion on the validity of the two courses (as 

currently one may expire before the other). 

1.4 Re-examining liquor trading hours, lock-outs and drink safe precincts 

Gallopers Sports Club supports maintaining the status quo, with an end to the current moratorium 

on applications for post-midnight trading outside of entertainment precincts. 

The lifting of the moratorium on applications for late night trading (12 am to 5 am) will remove 

unnecessary regulation and also promote industry growth and innovation.Community clubs need 

regulatory flexibility to trade in the night economy in response to a range of factors, including the 

changing nature of society, demographic make-up of patrons and increased competition. Unless 

clubs are allowed to adjust trading hours in response to these and other circumstances, there is a 

risk they may become irrelevant, as patrons may go elsewhere for their recreation. The moratorium 

is a regressive measure that is incompatible with free market enterprise and community need. 

1.5 Remove regional boundaries under the club gaming machine entitlement reallocation scheme 

Gallopers Sports Club supports Option 1 - accept the proposal (remove the regional boundaries 

inherent to the club reallocation scheme). 

The rationale for establishing regional allocation of entitlements is sound in theory (i.e. to prevent 

the concentration of gaming machines in one area) but it is not practical as it does not facilitate 

demand and supply because buyers and sellers are often located in different regions. The effect is a 

situation where there are sellers but no buyers and vice versa, which creates profound business 

uncertainty. 

It is also important to note that community clubs are already required to prepare a Community 

Impact Statement (CIS) when applying for an additional 20 or more gaming machines, so community 

and social costs are already considered before a club is eligible to seek additional entitlements; 

meaning regional allocations provide additional and unnecessary barriers to clubs with gaming. The 

scheme is market based but the regional allocation of entitlements is contrary to market based 

principles which should determine demand and supply. 

1.6 Amending the "high risk" glassing classification 

Gallopers Sports Club supports removing the "high risk" glassing provisions while retaining the 

discretion for the chief executive to place conditions on licences regarding the removal of regular 




P0 Box 817 Hamilton Central QLD 4007 

Telephone: 07 32681841 

Fax: 07 3868 2269 

Emaih info@gallope~sl~ortsclub.com.au 


ABN: 80133 679 786 

A C.,’\: 133 679 786 


and Qneeusland Bool,anakers Club


SPORTS CLUB 

glass. 

The current laws on venue classification are arbitrary, as a single glassing incident or an 

unacceptable level of violence during a 12 month period (that may take place despite the best 

efforts of the venue to prevent it) places a venue in the "high risk" category. There is little or no 

avenue for redress and this has unreasonable commercial consequences for venues, including 

negative impacts on their reputation and insurance. The reform proposal recognises the efforts put 

in by venues to prevent the glassing or violent incident. OLGR already has the authority to place 

additional conditions on licensees. 

1.8 Review laws relating to additional club premises (greenfield sites and amalgamations) 

Gaflopers Sports Club supports Option 1 - accept the proposal (review laws related to additional club 

premises). 

This proposal will facilitate the establishment of new community clubs in greenfield sites by 

removing significant barriers, in particular the cap of 280 gaming machines, irrespective of the 

number of club venues and higher taxes due to the combined revenue of club venues under 

amalgamation. Removing these barriers will put community clubs on a level playing field with 

hotels, which are not restricted by such barriers when establishing venues in a new site. Without 

these incentives, the community clubs industry will continue to decline, with the consequent loss of 

vital and irreplaceable community infrastructure. 

2.1 Streamlining gaming administration provisions 

Gaflopers Sports Club supports Option 1 - accept the proposal (streamfine gaming administration 

provisions into one Act). 

Consolidation of the gaming laws is a practical solution because duplication across the gaming Acts 

is resulting in inefficiencies, inconsistencies and confusion for venues. A single gaming 

administration law will consolidate the common administrative matters, such as licensing, 

compliance and appeals, that are currently contained in seven gaming laws in one law for general 

administration of gaming (i.e. Gaming Administration Act). Specific provisions relating to a particular 

industry can then be placed in their respective laws.The separation of the administrative and 

licensing functions will therefore greatly assist venues to understand and implement the regulatory 

framework and reduce the regulatory burden on the industry. 

2.2 Ceasing involvement of liquor inspectors in fire safety regulation 

Gallopers Sports Club supports Option 1 - accept the proposal (remove fire safety provisions under 

the Liquor Act). 





Telephone: 07 32681841 

1;’ax: 07 3868 2269 

Dnail: info@galloperssportschlb.com.au 


ABN: 80133 679 786 

ACN.. 133 679 786 

Home of file Hmnilton Bowls Club 

and Queensland Bool,anakers Club


SPORTS CLUB 

Fire safety issues are best placed under the respective fire safety laws, rather than in the Liquor Act, 

because the former provides a framework for minimum fire safety standards. The Liquor Act only 

duplicates the requirements, which results in confusion on what the exact requirements are for 

licensed premises in regards to fire safety.It is important to note that most other interstate 

regulators are not involved in regulating fire safety in licensed premises because this is a specialised 

area of operation. 

2.3 Reviewing liquor and gaming subordinate legislation 

Gallopers Sports Club supports that a review be undertaken with respect to expiring fiquor and 

gaming subordinate legislation. Because a review is required by the SIA, no options are put forth but 

input into the review is sought. 

Subordinate legislation provides clarity and specific detail on many aspects of the principal Acts. 

Therefore, the industry must be given appropriate time and opportunity to provide comprehensive 

input into liquor and gaming subordinate regulations to ensure they remain contemporary and 

relevant. This is a comprehensive review on its own and requires a separate submission. It is 

reiterated that no regulation should expire or be repealed without an appropriate level of 

consultation with the industry. 

2.4 Reviewing the disciplinary provision under the Liquor Act 

Gallopers Sports Club supports a review of 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. 

There should be no ground to take disciplinary action against a venue in relation to events that 

could not have been foreseen and therefore could not have been prevented by the licensee. In 

other words, venues should only be accountable for what is within their reasonable powers. The 

laws must focus on whether a licensee has met its obligations of responsible service, rather than on 

events that are beyond the control of a licensee. 

2.5 Noise controls over liquor licensed premises 

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. 

Noise control is a contentious matter and any review must recognise first occupancy rights (i.e. the 

venue was there first before the residents). In addition, the nature of activity should determine the 



Cnr Nndgee & Lancaster Roads, Ascot 


Telephone: 07 32681841 

Fax: 07 3868 2269 

Emaih info@galloperssportsclub,com.au 


~’U~¢\r: 80133 679 786 

A(h\: 133 679 786 

Home of fl~e Hmnilton Bowls Club 

and Queensland Boolanakers Club


SPORTS CLUB 

noise level; hence, some activities such as live music demand greater decibel limits. This should be 

on a case by case basis and not based on any arbitrary limits. The bottom-line should be an explicit 

recognition that licensed venues are public spaces and need to be able to offer exciting and 

engaging entertainment for the benefit of their patrons. 

2.6 Providing local governments with a greater say in licensing decisions 

Gallopers Sports Club supports Option 2 - reject the proposal (do not provide local government with 

a greater say in licensing decisions). 

The involvement of local government should be extremely limited. There is argument to say that 

one exception is for local government to be the regulatory body for noise issues. 

3.2 Reviewing gaming machine maximum bet 

Gaflopers Sports Club supports Option 1 - increase maximum bet to $10 on club and hotel gaming 

machines. 

Increasing the maximum bet to 510 is strongly recommended and necessary in view of the annual 

increases in the Consumer Price Index (CPI) and that there has not been an increase to the 

maximum bet limit since 1995. Hence, the current maximum bet limit of 55 (which has remained 

unchanged for 18 years) has a significantly diminished commercial value in today’s dollars. 

This is in contrast to other gambling offers that have no max bet limits (e.g. horse racing, keno, 

lotteries, etc) and online (internet based) poker machine / game offers, where the maximum bet 

limits are significantly higher in comparison and are unregulated.An increased maximum bet limit of 

510 not only realigns the diminished value issue, but it also provides greater convenience for 

’professional’ recreational players and Queensland clubs will also become competitive with QId 

casinos and NSW venues (for example), which currently have the 510 maximum bet limit. 

3.3 Reviewing cash input restrictions on gaming machines 

Gallopers Sports Club supports Option 1 - lifting the prohibition to allow the use of any Australian 

banknote in all Queensland gaming machines, and increase the cash input fimit at clubs and hotels. 

Lifting the prohibition to allow the use of any Australian banknote in all Queensland gaming 

machines, and increasing the cash input limit to at least 5250 would increase player convenience, 

reduce the current cash handling expenses and place venues on par with gaming venues in New 

South Wales and Victoria. Of all the Eastern states, Queensland is the only jurisdiction that does not 

allow the use of 550 notes and has the lowest specified cash input limit of all Australian 

jurisdictions. These changes will have tangible benefits to the ongoing financial viability of venues. 

Brisbane Racing Club Ltd Telephone: 07 32681841 

TradingAs Gallopers Sports Club Fax: 07 3868 2269 

Cnr Nudgee 8¢ Lancaster Roads, Ascot Email: info@galloperssl)ortsclub.coln.au A~N: 80133 67O 7s~, 

Home of the H,’unil ton Bowls Club 

P O Box 817 Hamilton Central QLD 4007 galloperssportsclub.co~n.au I ,~1(,~5133 679 786 and Queensland Boolunakers Club


SPORTS CLUB 

3.4 Reviewing hours of operation 

Gallopers Sports Club supports Option 1 - lifting the prohibition on gaming before lOam for those 

clubs that can demonstrate community need and have adopted voluntary pre-commitment. 

By way of example, Gallopers Sports Club (Home of the Hamilton Bowls Club) has a predominantly 

older bowls membership base who often start their competitions early. Clubs with bowling facilities, 

such as Gallopers Sports Club, present a special case because many of their elderly players who rely 

upon their family members and friends to drop them at the club on their way to work and hence, 

they are often seen queuing at the entrance of clubs prior to opening. Gallopers Sports Club also 

offers corporate breakfasts, host community and charity events (e.g. community breakfasts) and 

organize bingo for their older clientele. 

Gallopers Sports Club is also close to Australia Trade Coast where many workers are shift workers 

and appreciate early opening times. Accordingly, for shift workers their ’dinner’ is effectively their 

breakfast and they want to enjoy a few drinks to end their worldng ’day’. Community clubs 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. 

3.5 Moratorium on extended liquor trading hours 

Gallopers Sports Club supports Option 3 - Aflow 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. 

The rationale for extended tradng hours is on the basis we now live in a 24/7 economy. Australians 

expect availability to most things due to convenience and proven need. There is growing evidence 

that more and more people are worldng non-traditional hours in recognition of the convenience 

that comes with it (e.g. to avoid peak-time transport congestion, to fit in with family commitments 

etc.). 

3.6 Restrictive trading on days of cultural significance 

Gallopers Sports Club supports removing the trading hour restrictions to allow normal trading on 

Anzac Day 

Observance of days of national, religious or cultural significance is a matter for the individual. The 

individual may choose to observe these days or may decide to engage in some other activity. 

Racecourses provide a wonderful opportunity for people to gather and celebrate Anzac Day in a 





Telephone: 07 32681841 

Fax: 07 3868 2269 

Email: info@gallope~spor tsclub.com.au 

gallopersspor tsclub.com.au 

,4BN: 80133 679 786 

AQ\5133 679 786 


and Queensland Boolonakers Club


SPORTS CLUB 

truly Australian manner, i.e. a day at the races. 

Conclusion 

We commend the initiative of Government to reduce red tape and also inviting stakeholder 

submissions on how to do so. Please call with any questions. 

Yo u rs faithfully, 

SCOTT STEELE 

GENERAL MANAGER 


’lYading As Gallopers Sports Club 



Telephone: 07 32681841 

Fax: 07 3868 2269 

Email: info@gallope~sportsclub.com.au 

galloperssportselub.eom.au 

ABN: 80 t33 679 786 

AC~\: 133 679 786 

Home of the H,’unil ton Bowls Club 

and Queeusland Boolunakers Club

Gallopers Sports Club - Office of Liquor, Gaming and Racing

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