Caboolture Sports Club - Office of Liquor, Gaming and Racing

11 th March 2013
Liquor and Gaming Red Tape Reform
Office of Regulatory Policy
Department of Justice and Attorney-General
Locked Bag 180
CITY EAST QLD 4002
Re: Red tape reduction and other reform proposals for regulation of liquor and
gaming discussion paper
On behalf of the Management Committee of Caboolture Sports Club Incorporated and our members, I
would like to provide this response for consideration in regards to the recently released discussion paper
for Red tape reduction and other reform proposals for regulation of liquor and gaming.
Caboolture Sports Club Incorporated is one of the largest multi-discipline sporting clubs in Queensland,
located in Morayfield approximately forty minutes north of Brisbane. Our club is an entirely not-for-profit
organisation that was first opened in 1997 when six local sporting clubs; Cricket, Football, Touch Football,
Dog Obedience, Softball and Rugby Union combined to form a single incorporated club. Our primary
objectives are to provide a licensed facility to support the social interaction of our members and a reliable
source of funding to assist with the operation of our sporting disciplines.
In this short space of time the Caboolture Sports Club Incorporated has grown to over 40,000 members,
providing employment to 190 people, with an annual payroll in excess of $5 million, and contributing more
than $1 million annually in direct cash and in-kind support to local sport and the community every year.
As a not-for-profit organisation we provide a range of services to members that assist in generating funding
for local sport and community. The Caboolture Sports Club Incorporated operates two licensed clubs; our
primary facility at Station Road in Morayfield, and the former Caboolture Bowls Club, which now trades as
the Centenary Lakes Sports Club & Function Centre.
Combined, our two licensed venues feature 280 electronic gaming machines (EGMs), Keno and TAB
facilities, dining, free live entertainment, and a variety of other services for members and guests. The
Caboolture Sports Club Incorporated also operates six local sporting clubs; Caboolture Sports Football Club,
Caboolture Sports Cricket Club, Caboolture Touch Association, Caboolture Rugby Union Club, Caboolture
Sports Dog Obedience Club and Caboolture Sports Softball Association. These clubs each provide extensive
sporting facilities with over 3,000 junior and senior members participating in sporting activities.
We would like to provide comment on the following areas identified within the discussion paper that are
specific to the operations of Caboolture Sports Club Incorporated.

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 Caboolture Sports Club Incorporated currently has 16 employees trained in the Responsible
Management of Licensed Venues (RMLV) and some 130 staff trained in Responsible Service of Alcohol
(RSA). The administrative requirements to monitor two separate certifications and expiry dates for
employees that need to be trained in both RMLV & RSA is both a costly and onerous task.
The proposal put forward to accept that persons trained in RMLV are automatically trained in RSA is a
common sense reform. Caboolture Sports Club Incorporated also supports that the RMLV training should
incorporate not only RSA, but also Responsible Service of Gaming (RSG) as it would remove the
unnecessary need for clubs to train their employees three times (one for RSA, RSG & RMLV).
It represents significant cost savings (both time and money) for our Club and removes confusion on the
validity of these three courses, each with separate expiry dates.
1.5 Removing 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).
The current regional boundaries within the gaming machine entitlement reallocation scheme place
unnecessary restrictions on Clubs wishing to sell/acquire gaming entitlements. The proposal to remove
these boundaries would provide better opportunities for Clubs looking to buy/sell entitlements across all
regions and provide a more consistent and fair price and market for gaming machine entitlements.
While the rationale for having a regional allocation of entitlements was sound in theory (i.e. to prevent the
concentration of gaming machines in one area), we believe that appropriate regulation is already in place
through the requirement of venues to apply for an increase of gaming machines to Office of Liquor, Gaming
and Racing (OLGR), as well as the requirement for clubs to prepare a Community impact Statement (CIS)
when applying for an additional 20 or more gaming machines.
Instead, the regional boundaries have created a situation where struggling clubs looking to acquire capital
through the sale of entitlements cannot find buyers in their region, while clubs in other regions are unable
to source additional entitlements to support their club’s growth.
The support of this proposal has further implications when considering section 1.8 of the Red Tape
Reduction report to “Reviewing laws relating to additional club premises (greenfield sites and
amalgamations)”. Caboolture Sports Club Incorporated supports the option to accept the proposal to
review laws related to additional club premises to allow Clubs to assist struggling smaller clubs and
establish clubs in greenfield sites. However, in order to establish new clubs, gaming entitlements would
need to be sourced and the current restrictions of the regional boundaries would impose further difficulty

in obtaining gaming machine entitlements for these new community clubs. This
adds further weight to the proposal to remove regional boundaries under the club
gaming machine entitlement reallocation scheme.
1.8 Reviewing 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).
A change to the laws which restrict clubs from taking on additional club premises for the purpose of
establishing greenfield sites or amalgamation to assist struggling clubs is essential for the Queensland
community club industry. Currently there are significant barriers for clubs to establish additional premises,
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.
Caboolture Sports Club Incorporated is one such club that has been affected by the restrictions and gaming
tax arrangements. In 2006, the Club was approached by members of the struggling Caboolture Bowls Club
who faced an imminent closure of their club. The Management Committee of Caboolture Sports Club
Incorporated agreed to purchase the freehold facilities from private owners to ensure the club’s survival
and has since invested significant capital to improve the facilities for members. Today the club trades as
Centenary Lakes Sports Club a home for the Caboolture Lakes Bowls Club and other local sporting and
community groups.
However the laws relating to additional club premises have severely hampered the earning potential and
ability to provide further improvements at Centenary Lakes Sports Club. Firstly the restrictions of a
community club license to only hold a total of 280 gaming machines licenses, regardless of the number of
licensed venues has led to the reduction of gaming facilities and diminished earning potential for Centenary
Lakes Sports Club. In 2011 the Club identified the need to increase the number of gaming machines
Caboolture Sports Club’s primary club to cater for the venue’s growing patronage. To cater for this growth a
successful application to transfer eleven (11) gaming machines from Centenary Lakes Sports Club to
Caboolture Sports Club, to the detriment of our second club. The Caboolture Sports Club Incorporated was
left with no other option to cater for the growth of its primary club than to sacrifice its second venues
earning potential due to the single licence reaching the 280 machine cap.
One of the major factors in the decision to remove the majority of gaming facilities from Centenary Lakes
Sports Club to Caboolture Sports Club (11 of the Club’s 16 gaming machines) was the tax implications of the
single licence rule. The calculation of gaming machine tax allows all club licensees a $9,500 per month taxfree
threshold, with a sliding scale for the rate of tax after this point. However under the current single
licence rule, the Caboolture Sports Club Incorporated was subject to the highest rate of tax on the sixteen
(16) gaming machines at our secondary site. This is despite the fact that there are additional overheads by
operating multiple venues with gaming machines as opposed to one.
If clubs were permitted multiple licences, the effect would be that taxation applies on a per venue basis,
with the tax-free threshold available in respect of each premise under the licence. This change in legislation

would provide opportunity for financially viable clubs to either assist struggling
clubs through amalgamation or to assist with the establishment of community
clubs in greenfield sites.
Removing the rules would also put clubs on a level playing field with hotels in terms of establishing
themselves in Greenfield areas. Hotels are not subject to the single licence rule or the near rule and an
established hotelier is therefore able to obtain new premises anywhere in the State. While hotels are
limited to a maximum of 45 gaming machines per venue, some hotel chains hold more than a hundred
licences and operate thousands of gaming machines.
Allowing clubs to operate additional licences over the 280 gaming machine cap and removing the single
licence rule so that clubs are taxed on a per venue basis is required to assist smaller community and
sporting clubs that are failing as competition, regulation and increased costs result in them becoming nonviable,
and to facilitate the establishment of new community clubs in greenfield sites. Without these
incentives, the community club industry will continue to decline, with the consequent loss of vital and
irreplaceable community infrastructure.
3.1 Reviewing gaming machine maximum bet
The following proposal is supported:
Option 1 – increase maximum bet to $10 on club gaming machines.
The current maximum bet limit of $5 (which has remained unchanged for 18 years) has a significantly
diminished commercial value in today’s dollars, when compared to annual increases in the Consumer Price
Index (CPI). An increased maximum bet limit of $10 not only realigns the diminished value issue, but it
would also allow Queensland clubs to operate on a level playing field with clubs in other states. This is
important for two reasons;
Firstly, it will ensure that Queensland clubs can remain competitive with NSW venues (for example), which
currently have the $10 maximum bet limit. Secondly, it would support the availability of more games from
manufacturers that are currently not available in the Queensland market. Currently gaming manufacturers
have to go through the process of redesigning games to comply with the lower maximum bet of
Queensland, with some games such as 100 line games not available in the Queensland market at all. This
creates a disadvantage for Queensland clubs, particularly those competing in high tourism areas or close to
the Queensland-New South Wales border. The increased cost to the manufacturers to adjust their games
inevitably flows through to an increased cost for Queensland clubs when purchasing new machines.
3.2 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.
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 $250 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 $50 notes and has the lowest specified cash input limit ($100), of all Australian jurisdictions. These
changes will have tangible benefits to the ongoing financial viability of venues and convenience for patrons.
3.3 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.
Since the introduction of a prohibition on gaming and liquor before 10am by the Bligh Government,
Caboolture Sports Club Incorporated has had to significantly reduce a number of services to members that
were previously available. The reduction of these services has been met with much displeasure from
members and no evidence has been provided to support that these changes have had any positive effect
on harm minimisation.
Prior to the introduction of the prohibition on gaming and liquor before 10am, Caboolture Sports Club
provided its range of services to members from 9am during weekdays and 8am on Saturday & Sundays.
During the week, the 9am opening of all the Club’s services including liquor and gaming supported the
opening times of other services such as our cafes, bingo and Ticketek agency. On Sundays a popular buffet
breakfast was available which for many locals had become a weekly family tradition.
However with the services of gaming and liquor not being available until 10am patronage to the Club
during these early hours diminished significantly, resulting in the cancellation of our breakfast and opening
times being pushed back to 10am on weekends. Although the Club still opens from 9am weekdays (Café &
Ticketek only), patronage has reduced significantly. The majority of members who had frequented the Club
during these earlier times were seniors, who enjoyed an early morning visit to the Club that fitted with
their lifestyle and the security of venturing out at this time of day. With more than one-third of Caboolture
Sports Club Incorporated’s 40,000 members comprising of seniors, this is a significant number of members
that have been disadvantaged.
By re-instating the opportunity for Clubs to trade with gaming and liquor prior to 10am, many of these
above mentioned services can be provided once again to members. It also reduces the need for venues
such as bowls clubs, golf clubs or venues with function facilities (such as our second club, Centenary Lakes
Sports Club) to have to apply for special early licenses to operate sporting event and functions, a process
that is currently completed several times a year. It also allows for full services to be available during annual
events with a traditional earlier start such as Mother’s Day, Father’s Day, Easter Sunday Breakfast or
Melbourne Cup.
While Caboolture Sports Club has already installed voluntary pre-commitment technology, we feel that
making it a requirement for obtaining a licence to open early would be to the detriment of the industry.
Many smaller clubs (such as Centenary Lakes Sports Club) would not be able to meet this criteria due to the
significant costs involved with voluntary pre-commitment. It would be unfair to penalise these clubs on the
basis that they cannot afford the technology at the time, but otherwise have a legitimate customer base for

early hours of operation. By forcing venues to take up voluntary pre commitment it
will increase operational costs and red tape which is contrary to the ideal of the red
tape reduction program that has been initiated by the government.
Yours Sincerely,
Kelvin Patch
Secretary Manager
Caboolture Sports Club Incorporated