Fact Sheet 11

Tips for conducting a social and economic impact assessment (SEIA) of a planning permit, or licence, application for EGMs

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Responding to the relevant TEST

 

If your SEIA is related to an application for a planning permit the test is set out in the Victorian Planning and Environment Act 1987 which states at Clause 60 (A) that before deciding on an application the responsible authority may consider any significant social and economic effects of the use or development for which the application is made. Victorian Planning Provisions Clause 52.28 also provides direction: To ensure the social and economic impacts of the location of gaming machines are considered (Clause 52.28-1).  When an application for approval of premises is considered at VCAT the test remains the Gambling Regulation Act 2003.

 

Recent relevant decisions have considered various aspects of each test and made findings that reflect particular approaches to the Test. For example:

 

The use of the word “net” recognises that there may be both positive and negative impacts on the well-being of the local community and that a balancing process is required...The test does not require the Commission (or, on review, the Tribunal) to be satisfied that there will be a net positive economic and social impact of approval; it is sufficient that the Commission (or, on review, the Tribunal) be satisfied that the net economic and social impact of approval will be either neutral or positive. (Branbeau PL v Victorian Commission for Gambling Regulation, 16 December 2005 – emphasis added)

 

…the Applicant must demonstrate more than the absence of any net community detriment. The Applicant must go beyond a break even situation to demonstrate that the proposal will lead to a net community benefit as required by Clause 11 (VCAT No. 2562/2007, para 39 – emphasis added).

 

The introduction to your assessment should state the test you are assessing and summarise the findings of your assessment in relation to that test. For example:

 

Based on the social impact assessment provided in this report it can OR cannot be shown that the net social impact of the introduction of X EGMs at X venue will have a net detrimental impact on the community (VCGLR Licence Application)

 

Or - the application for X EGMs at X venue will/will not lead to a net community benefit and it can/cannot be determined that the net economic and social impact of approval will/will not be detrimental to the well-being of the community of Maribyrnong (VCAT Planning Permit Application)

 

Support your conclusion with a summary table showing the identified impacts according to the categories of impact you have used in your report.

 

Example of Summary Findings - Social Impact Assessment

Impact Category

Identified Impact

Problem Gambling

NEGATIVE

Economic Benefits to Community

NEGATIVE

Community Facilities

NEGATIVE/NEUTRAL

Entertainment

POSITIVE

Community Health

NEGATIVE

Community Well Being

NEGATIVE

 

Validating the Approach – International Guidelines

 

It is useful to refer to professionally endorsed Guidelines for Impact Assessment when deciding which factors to consider in your SEIA.  Such Guidelines, or Principles, of Impact Assessment can help validate the types of data you include in your assessment. It might be useful to identify the ‘categories of impact’ set out in the Guidelines and match these categories with indicators you are using in your local assessment. The Guidelines will then provide a framework, or rationale, for the inclusion of the data you analyse in your SEIA.

 

 

Guidelines for Impact Assessment can help structure your report into categories of Impact that have specific indicators related to each category.

Social Impact Assessment Category

Indicator Used to Assess Potential Impact of Application

Vulnerability to Problem Gambling

1. Social and Economic Disadvantage

1.1 SEIFA

1.2 Median Household Income

1.3 Unemployment

2. Access to EGMs

2.1. EGM density

2.2. EGM expenditure

2.3. Accessibility of gaming venue (hours, location, relative land uses)

3. Financial Vulnerability

3.1. Housing stress

3.2. Family Structure

3.3. Vulnerability Assessment for Mortgage, Petroleum and Inflation Risks and Expenses (VAMPIRE) Index

Economic Benefits to Community

4. Expenditure and Contributions

4.1. Economic contributions of proposal to community

4.2. Forecast community  losses

5. Local employment

5.1. Employment provided by proposal

5.2. Identified  Labour Force needs

Community Facilities

6. Provision of community facilities

6.1. Facilities audit

6.2. Identified need for community facilities

6.3. Community facilities in proposal

6.4. Policy directions

Entertainment

7. Provision of entertainment and recreation facilities

7.1. Entertainment & recreation audit

7.2. Identified need for entertainment/recreation facilities

7.3. Entertainment offered in proposal

7.4. Policy directions

Community Health

8. Community health

8.1. Co-morbidities: mental illness, depression, anxiety, alcohol and drug dependence and suicide

9. Community connectedness

9.1. Social support

9.2. Volunteering

Community Wellbeing

10. Community wellbeing

10.1. Community values

10.2. Community attitudes to gaming

 

Defining the Community

 

It is important to be clear about who constitutes the ‘community’ in your SEIA.  The test at both VCAT and VCGLR is about the impact of the application on the community of the municipality in which the venue is located – in other words, the community is defined as the local government area overall. A number of limitations with this definition of community have been noted at various hearings.

 

The table below summarises some of these limitations and the level of community, and impact indicators, used in the evidence provided at a number of relevant hearings.

 

Justify the scale of impact considered in your SEIA by referring to existing research about problem gambling, socio-economic disadvantage and/or distances people will travel to access EGMs.

 

Case Example

Evidence Provided to define and measure impact on ‘Community’

Justification for scale of community considered

Edgewater Club Maribyrnong
VCGR decision
VCAT decision

  • Evidence provided by the applicant relied on social and economic indicators for the municipality overall
  • Evidence provided in the Social Impact Assessment (SIA) produced for Council  focused on the socio-economic indicators of residents living within a 1km radius of the proposed venue
  • Given that the application included a transfer of machines within the municipality evidence produced for Council also focused on the socio-economic indicators of residents living within a 1km radius of the other relevant venues in the LGA from where machines would be transferred
  • Levels of socio-economic disadvantage differ greatly across local areas in the municipality
  • Accessibility can be defined as 400mt walking distance – using healthy by design planning guidelines

 

Lakeside Hotel Pakenham
VCGR decision

  • Evidence provided by the applicant relied on social and economic indicators for the municipality overall
  • Evidence provided in the Social Impact Assessment (SIA) produced for Council  also focused on the suburb within which the venue was located
  • Local suburb was designed by private developer as a master planned estate and exhibited specific socio economic characteristics

Romsey Hotel
VCAT decision following Supreme Court Appeal

  • Evidence provided by the applicant relied on social and economic indicators for the municipality overall and for the Romsey township
  • Evidence provided in the Social Impact Assessment (SIA) produced for Council  focused on the socio-economic indicators of the municipality, the Romsey township and adjacent regional areas

Laurimar
VCAT decision

  • Local suburb was designed by private developer as a master planned estate and exhibited specific socio economic characteristics different to other areas of the municipality
  • The urban fringe location of Laurimar was linked to particular indicators of community vulnerability to financial loss, including levels of car dependence and costs associated with travel to work

 

Identifying Potential Social and Economic Impacts

 

It is important to remember that any assessment of the potential social and economic impacts of an application for EGMs needs to consider both the potential POSITIVE and the potential NEGATIVE impacts of the application. For example, given that EGM gaming is a legal recreation activity in Victoria one potentially positive impact on the community might be the contribution to entertainment options in your area.

 

Any assessment of the potential social and economic impact of an application for EGMs must consider both positive and negative impacts.

 

Using existing research

 

There is a vast scope of relevant research related to gambling that can be used to inform the approach taken in your SEIA. Relevant recent research has been used at various hearings to justify:

  • Catchment area considered as relevant to the potential impact assessment (eg. research findings about the distance people might travel to gamble)
  • Social indicators that should be considered to understand the potential impact of the application on the community (eg. any research that identifies the characteristics of a problem gambler or social characteristics that increase the vulnerability of your community to potential financial losses)
  • Identified economic impacts of EGM gaming: any research about the local economic effects of gambling, impact on local economy including divergence of funding from alternate expenditure, and contribution to local employment generation.

For further information see Fact Sheet 14 Relevant Recent Research Related to EGM Applications and Fact Sheet 15 Data Bases Related to EGM Applications.

 

Sources of Data

 

A range of material can be used to provide evidence of the potential social and economic impacts of EGMs. This section summarises key material and provides links to relevant data sets and other resources.

 

Entertainment and Recreation Audits

 

Since EGMs are a legal recreation activity in Victoria a potential impact of new or increased number of EGMS is to change the provision of entertainment and recreation in an area. To assess the potential impact of the proposed EGMs as an entertainment or recreation activity it is useful to understand current entertainment and recreation provision in the area.

A ‘desk top audit’ is an acceptable method of summarising the current provision of recreation and entertainment options in an area. Such an audit can be compiled through an internet search of recreation and entertainment activities in the relevant area (include dining options as the EGM applications often include bistros and dining facilities). Councils may have already completed a recreation audit as part of a Recreation Strategy. An audit should include:

  • Name and address of recreation facility
  • Type of recreation offered
  • Accessibility i.e. opening hours, cost, client target group
  • Distance from proposed venue

An audit can be presented in a table format showing the relevant details of each facility. The table is best supplemented by a map showing the location of the proposed EGM venue and the entertainment facilities included in the audit.

 

Interviews with staff at the recreation facilities, or analysis conducted through local government recreation planning or Recreation Strategies, can be used to supplement the audit with information about the capacity of the facility and the need for more recreation options in the area i.e. EGMs.

 

Community Service Audits

 

Since there are potential social impacts of problem gambling around EGM gaming it is important to understand the capacity of existing community services to respond to potential increases in problem gambling. A useful way for doing this is through an audit of existing services and interviews with service providers.

 

An audit of community services should include (for approach see entertainment and recreation audit, adjacent):

  • Name and address of facility
  • Type of service offered
  • Accessibility i.e. opening hours, cost, client target group
  • Distance from proposed venue

 

Interviews with relevant staff from community services help flesh out the details of the audit and should focus on:

  • Current users of the service, why people come, relevant issues in area
  • Scope of problem gambling in area or indicators of financial stress impacting on households and individuals
  • Anticipated demand for problem gambling services
  • Capacity of organisation to respond to current and anticipated demand for problem gambling services
  • Related organisations and their capacity to respond to problem gambling
  • Examples of community service initiatives that respond to problem gambling
  • Examples of initiatives that have benefited from EGM community contributions (eg. funding of programs or facilities through community benefit scheme etc.)
  • Examples of social and economic impacts of problem gambling in the area

 

 

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