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

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BRC SUBMISSIONS ON RED TAPE REDUCTION PROPOSALS 1,1 Removing the regulatow approval for approved managers of low risk venues BRC supports Option I - accept the proposal (remove requirement that certain tow risk venues retain approved managers). This proposal should be extended to include low risk venues. Low risk venues will still need a suitably qualified manager to manage the sale and service of alcohol; however it is suggested low risk venues 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) BRC supports Option I - accept the proposal (accept that persons trained in RMLV are trained in RSA). 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). :I.4 Re-examining liquor trading hours, lock-outs and drink safe precincts BRC supports maintaining the status quo, with an end to the current moratorium on applications j:or post-midnight trading outside o, f 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 BRC supports Option ~ = accept the proposal (remove the regional boundaries inherent to the club reallocatlon 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 (ClS) when applying for an additional 20 or more gaming machines, so community and social costs are already considered before a dub 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 BRC supports removing the "high risk" glassing provisions while retaining the discretion for the chiej ~ executive to place conditions on licences regarding the removal oJ: regular 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) BRC supports Option i - 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. 1.9 Reducing State-imposed event costs BRC supports Option 1 - accept the proposal (review requirements for major events). The current requirements by OLGR to complete event management plans etc. are onerous and costly. For example, BRC is compelled to provide seven (7) such plans for any racecourse crowd over 5,000 persons. BRC recommends that a single event management plan setting out different crowd levels be submitted on an annual basis. 2.:1 Streamlining gaming administration provisions BRC supports Option 1 - accept the proposal (streamline 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
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