Iris Capital application to install new gaming machines, Alice Springs

The NT Council of Social Service (NTCOSS) is the peak body for the non-profit social service sector in
the Northern Territory (NT). Our members comprise community service providers, professional
associations, and advocacy organisations. Over 30% of NTCOSS members are Aboriginal community
controlled organisations. NTCOSS provides independent and informed policy development, advice,
advocacy, and representation about issues facing the community services sector; is a voice for and
with Territorians affected by poverty and inequality; and plays a key coordinating and leadership role
for non-profit social services across the NT. NTCOSS has offices in Darwin and Alice Springs, and is well
connected with the Alice Springs community and community service providers. In Alice Springs alone,
our membership includes over 35 organisations, including organisations that provide support to
individuals, families and communities affected by problem gambling.
NTCOSS wishes to express its objection to the applications made the Iris Capital Group to increase the
number of electronic gaming machines in Alice Springs by an additional 60 machines across the
following venues:
• Todd Tavern – additional 10 gaming machines)
• Gap View Hotel – additional 10 gaming machines
• Diplomat Hotel (Uncles Tavern) – 20 new gaming machines
• Mercure Resort – 20 new gaming machines
In addition to providing this submission, NTCOSS acknowledges and recommends submissions in
relation to Iris Capital’s applications by member organisations including the Central Australian
Aboriginal Congress (Congress), Tangentyere Council, and Children’s Ground.
Despite a large number of organisations in Alice Springs that work with people who are impacted by
gambling, NTCOSS notes that the community impact analysis process consulted with few community
service providers and did not consult with key Aboriginal community controlled organisations,
including Tangentyere Council. NTCOSS is also concerned that Congress, the major provider for
Aboriginal health in Central Australia, was only consulted as part of the community impact analysis for
one out of the four applications. Of those organisations contacted, none of the respondents supported
Iris Capital’s applications for additional gaming machines in Alice Springs.
NTCOSS broadly recognises that gambling is a legal leisure pursuit in the NT and that the gaming
industry is a sector that contributes to the economy. However, studies show that problem gambling

is increasing in the NT and the costs of this are significant.1
Further, problem gambling
disproportionately occurs on gaming machines, and people who live closer to gaming machine venues
are more likely to be ‘problem gamblers’2
. Any consideration of applications to increase the number
of gambling machines must consider the distribution and availability of these machines in local
NTCOSS and members are concerned about the growing social, emotional, psychological, and financial
impacts of gambling for individuals, families, and communities. It is estimated that for every person
with a gambling problem, six people around them are directly impacted by their gambling, such as
family members, friends, and employers/employees; for ‘moderate-risk’ gamblers up to three others
are impacted; and ‘low-risk’ gamblers up to one other person is impacted.4
According to the 2018 Northern Territory Gambling Prevalence and Wellbeing Survey Report, the NT
‘has the highest rates of problem gambling, moderate and low risk problem gambling compared with
the most recent estimates from other Australian jurisdictions’.5 A significant number of Alice Springs
residents (13.6%) are classified as ‘problem gamblers’, and Alice Springs demonstrated ‘large increases
in problem gambling’ between 2015 and 2018.
Studies show that the social costs of gambling are significant, ‘including adverse financial impacts,
emotional and psychological costs, relationship and family impacts, and productivity loss and work
impacts’.7 The above research by Menzies School of Health Research found that in 2018 ‘around 8%
or 14,500 NT adults indicated that they had been negatively affected by someone else’s gambling’,
and that people identified gaming machines as the type of gambling ‘the other person was doing when
they were negatively affected’. The study found that Aboriginal and Torres Strait Islander respondents
were ‘significantly more likely to be harmed and significantly more likely to gamble on EGM’ (gaming
8 Despite the impact of problem gambling, studies show that a ‘very small proportion’ of
people access support for gambling-related issues, with only 1.5% of Territorians seeking assistance.9
NTCOSS and members note with concern that Alice Springs, which has high levels of poverty and
disproportionately high living costs, already has 510 gaming machines. This equates to one machine

per 37 adults10
, which is more than three times the national average, and will increase to one machine
per 33 adults if the Iris Capital applications are successful.
An additional 60 gaming machines across four locations in Alice Springs will make gaming machines
significantly more accessible in the town. Two of the venues (the Todd Tavern and the Diplomat Hotel)
are in the CBD and within walking distance to banks, shopping centres, multiple child care centres,
and a school; another of the venues (the Gap View Resort) is in close proximity to a supermarket,
youth drop-in centre, pre-school and childcare and (noting the lack of consultation with Aboriginal
community controlled organisations) in close proximity to a Town Camp; and another (Mercure Hotel)
is in close proximity to a supermarket, school, pre-school and a Town Camp. Both the Mercure Hotel
and the Diplomat Hotel are in close proximity to venues with gaming machines. All venues are in close
proximity to residential areas.
As above, the proximity of residential areas to gaming machine venues does impact on people’s
gambling behaviours, with implications for ‘problem gamblers’. There is much research to support
this, but NTCOSS draws the Director’s attention to the following quote from the Victorian Responsible
Gambling Foundation study: ‘if the location of gambling venues in close proximity to people’s homes
induces gambling at unsafe levels, then there is a public health and economic argument for
governments to reduce accessibility. Our findings suggest that the close proximity of gambling venues
to home increases financial hardship and mental health problems, particularly for socioeconomically
vulnerable populations.’11
With the current number of gaming machines available in various locations across Alice Springs, the
demonstrated harm caused by gaming machines to individual gamblers and their networks, and the
particular impact on people from lower socio-economic backgrounds and other populations
experiencing disadvantage, any addition of machines to the Alice Springs community is unwarranted.
NTCOSS recommends that the Director rejects all Iris Capital’s applications for new gaming machines
at the Diplomat Hotel; the Todd Tavern; the Gap View Resort; and the Mercure Resort.
If you wish to discuss this application further, please contact

Yours sincerely,
Sarah Holder

Policy Manager
NT Council of Social Service