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Brisbane Racing Club (PDF 305 K) - Office of Liquor, Gaming and ...

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BRC SUBMISSIONS ON RED TAPE REDUCTION PROPOSALS<br />

1,1 Removing the regulatow approval for approved managers <strong>of</strong> low risk venues<br />

BRC supports Option I - accept the proposal (remove requirement that certain tow risk venues retain<br />

approved managers).<br />

This proposal should be extended to include low risk venues. Low risk venues will still need a<br />

suitably qualified manager to manage the sale <strong>and</strong> service <strong>of</strong> alcohol; however it is suggested low<br />

risk venues should not be required to complete the application for regulatory approval <strong>of</strong> the<br />

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

venues would not be required to pay the application fee <strong>and</strong> would not need to complete the<br />

associated paperwork.<br />

1,2 Persons trained in Responsible Management <strong>of</strong> Licensed Venues (RMLV) taken to be trained in<br />

Responsible Service <strong>of</strong> Alcohol (RSA)<br />

BRC supports Option I - accept the proposal (accept that persons trained in RMLV are trained in<br />

RSA).<br />

This is a commonsense approach to consolidate two courses with overlapping contents into a single<br />

course (with one expiry date). It represents significant cost savings (time <strong>and</strong> money) for the<br />

industry, as clubs will not be required to train their employees twice (one for RSA <strong>and</strong> one for<br />

RMLV). For employees, the proposal removes confusion on the validity <strong>of</strong> the two courses (as<br />

currently one may expire before the other).<br />

:I.4 Re-examining liquor trading hours, lock-outs <strong>and</strong> drink safe precincts<br />

BRC supports maintaining the status quo, with an end to the current moratorium on applications j:or<br />

post-midnight trading outside o, f entertainment precincts.<br />

The lifting <strong>of</strong> the moratorium on applications for late night trading (12 am to 5 am) will remove<br />

unnecessary regulation <strong>and</strong> also promote industry growth <strong>and</strong> innovation. Community clubs need<br />

regulatory flexibility to trade in the night economy in response to a range <strong>of</strong> factors, including the<br />

changing nature <strong>of</strong> society, demographic make-up <strong>of</strong> patrons <strong>and</strong> increased competition. Unless<br />

clubs are allowed to adjust trading hours in response to these <strong>and</strong> other circumstances, there is a<br />

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

is a regressive measure that is incompatible with free market enterprise <strong>and</strong> community need.<br />

1.5 Remove regional boundaries under the club gaming machine entitlement reallocation scheme<br />

BRC supports Option ~ = accept the proposal (remove the regional boundaries inherent to the club<br />

reallocatlon scheme).<br />

The rationale for establishing regional allocation <strong>of</strong> entitlements is sound in theory (i.e. to prevent<br />

the concentration <strong>of</strong> gaming machines in one area) but it is not practical as it does not facilitate<br />

dem<strong>and</strong> <strong>and</strong> supply because buyers <strong>and</strong> sellers are <strong>of</strong>ten located in different regions. The effect is a<br />

situation where there are sellers but no buyers <strong>and</strong> vice versa, which creates pr<strong>of</strong>ound business<br />

uncertainty.<br />

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

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