In Council's submissions [the] proposal offers little real benefit to the community of Whittlesea. Council recognises that additional community funding, if distributed appropriately, would be beneficial to the community. Similarly, if major renovation works were undertaken at the subject premises, this could be appreciated by the community. If employment at the Club were to increase, that would be a benefit to the community (provided it is employment related to the gaming machines). However it is strongly submitted that these potential benefits are strongly outweighed by the likely and foreseeable harm to be suffered by the community, in the likely increase in problem gambling flowing from the increase in EGMs.

1. The applicant's counsel made much of the emotional and financial strain suffered by the township as a result of the appalling 2009 bushfires and to the demographic profile which it states demonstrates significant disadvantage when compared with other metropolitan areas. In its written submissions council's view was summarised as follows:

The tribunal must have regard to the vulnerability of the Whittlesea community to suffer increased problem gambling among its residents, Given the findings by the productivity Commission that on average, 40% of gaming expenditure is derived from the 2-3% of adults who are problem gamblers or at risk of problem gambling, there is a high risk that a significant portion of the additional expenditure derived from 10 extra EGMs at the subject premises, will come from problem gamblers. This unacceptable risk is undoubtedly a disbenefit of the proposal.

1. The applicant submits that, notwithstanding the assertions of Mr Quick, there is no evidence to say that the residents in the north of the municipality spend less on EGMs than those in the south and that the level of expenditure per machine is not the same thing as expenditure per adult. He asserts that one cannot simply divide the amount spent on gaming machines in a statistical local area by the number of adults and thus create an end product of expenditure per adult. Such calculation, he submits, ignores that adults can, and often do, expend money on EGMs that are outside the SLA.
2. The applicant further submits that there is no demonstrated need or desire for additional EGMs at the behest of members of the club or residents of the township or surrounding area. Rather, it submits, the club is motivated (at least to some extent) by a desire to fend off competition and that cannot be seen as a social or economic benefit. This view, it is said, is borne out by the club's own gaming counts which do not evince an overwhelming need for more machines. Also it is submitted that although there are periods during the week when more than 70% of the machines are in use, those occasions are limited.
3. Mr Peter Spratt is the senior research officer at the City of Whittlesea and has occupied that position since 2007. He holds impressive credentials in the field of sociology and was responsible for preparation of the Council's Social and Economic Impact Assessment provided to the VCGLR and for the subsequent addendum to that statement prepared in October 2012. These documents were before the Tribunal and Mr Spratt spoke to his report. In his evidence he told the Tribunal that Whittlesea was a rural town, it was not a strong community, it had a low level of high sector jobs, a low level of education and was therefore vulnerable to the effects of economic downtown.
4. Attached to Mr Spratt's statement were a number of letters and expressions of opposition to the proposed increase. It is clear from those letters (and from the signed petition) that there is a level of passionate opposition to gambling per se and to this application in particular. If I understand Mr Spratt's evidence correctly, the community survey (as distinct from the council-initiated telephone survey), was not taken into account but in any event, it might have carried more weight had it not been headed by pejorative statements such as:

"$2.8 million was lost to Pokies (or Electronic Gaming Machines) in 2011/12 at the Bowls Club.

$102 million was lost to Pokies (or Electronic Gaming Machines in the 2011/12 financial year in the City of Whittlesea ALONE"

1. Clearly the survey was not designed to be signed by people in support of the proposal. What the Tribunal does accept however is that there is a level of distaste in the community for any increase in the status quo and indeed, a level of distaste for gambling itself.
2. Mr Spratt also spoke to a survey of community attitudes conducted by telephone in September 2012 in an attempt to gauge community views in relation to the application. In general, his views about the application were summarised succinctly in the last paragraph of his written statement as follows:

Council's key concerns with the proposal are: that the proposal includes no immediate social benefit to the community; that the risk to a vulnerable community of an increase in problem gambling posed by the increase by 10 of the number of EGMs at the venue outweighs the social benefits that might accrue from the proposal; and that the proposed increase to the number of EGMs within the municipality would increase gaming expenditure for a municipality where expenditure is historically among the highest in Victoria.

1. The Tribunal also heard from Mr Ivan Peterson who appeared by telephone. Mr Peterson is the chairman of the Combined Christian Churches of Whittlesea. He expressed the firm view that there were sufficient machines already and that, on his many visits to the club, he had never observed full occupancy of the machines and had never seen a queue of people waiting to play. This of course agrees with the observation of Mr Quick that the utilisation of the machines is only over 70% on three nights of the week, Thursday being the busiest night. Mr Peterson also referred to the devastating effects of the bushfires on the local populace, the resilience of the community and the excellent work performed by the various support agencies.

Mr Geoffrey Aldous, in his fifth year as chairman of the club;

Mr David Baldi, general manager of Mercury Group Victoria;

Ms Jacqueline Hutchison, compliance officer of the Mercury Group;

1. Mr Aldous is in his fifth year as chairman of the club. He told the Tribunal that since the introduction of gaming machines in 1996, the club had evolved from its unsophisticated volunteer nature into a professionally managed hospitality and sporting operation providing employment and career opportunities to the local townsfolk along with first rate sporting opportunities. Along with a history of the club and its activities, he gave the Tribunal a thumbnail sketch of the organisations supported by the 'in kind' provision of facilities for meetings and like events. In his written statement he provided the following information and made the commitment to greater community support. That commitment was:

The Club supports other not-for-profit organisations with in-kind and cash contributions. In 2012 the Club's cash donations and sponsorships amounted to about $22,000.00 With the increased gaming income from the new state gaming tax system and the extra gaming machines, the Club will make a specific allocation of 15% of its surplus to community contribution while it is repaying loans and entitlements and thereafter rising to 30%. On the current forecasts this amounts to approximately $70,000 per annum in the first 5 years and then $150,000 thereafter.

1. Of course this late-in-the-day generosity might seem opportunistic in the circumstances, but it represents a significant outlay in favour of other community and sporting organizations in a town where community activity is what brings residents together and contributes to a healthy and vibrant town. The relevant resolution was carried unanimously at a meeting on 29 October 2012. I note as a matter of interest that Mr Aldous refers to the percentage of 'surplus' whereas the resolution refers to a percentage of 'profits'.
2. Mr Aldous spoke of the expansion plans that had been drawn up in 2008, at the time of the major renovations carried out at that time. Those renovations were financed by a loan which still stands at $800,000.00. It is now apparent that those renovations are inadequate to meet current and future needs and the club planning committee is considering other options for the further development of club facilities. This may involve the acquisition of land although a set of plans was drawn up in November 2011 and is among the options still being considered.
3. Mr Bernard Walker is the general manager of the club and has held the position since November 2010. He prepared cash flow projections for the years 2013 to 2022 and budgeted income and expenditure for the years ended June 2013 to June 2016. They were available to the Tribunal and Mr Walker estimated they were a reasonable forecast of the club's financial performance for the next 9 years. He spoke of the ebb and flow of net gaming revenue attributing decreases to increased competition and resulting loss of market share. It was his view that the club would be able to limit the negative impact on its gaming revenue with the introduction of the extra 10 machines and thus would help stem the loss of market share.
4. He gave evidence of the proposed improvements that would flow from increased revenue and told the Tribunal that the club planning committee was considering the acquisition of adjacent land, relocation to another site in the township or development of a second storey to the existing building. He confirmed what Mr Aldous said, i.e. that the club had a conservative attitude to borrowing and expenditure but was bound to embrace the improvements to provide for future generations of Whittlesea without encumbering them with excessive debt.
5. Both Mr Aldous and Mr Walker were excellent witnesses and their evidence is accepted.
6. Mr Walker informed the Tribunal that the club had joined the Mercury RSG Initiative including Mercury Responsible Gambling Code of Conduct and the ClubsVIC Self Exclusion Program; that all staff employed in the gaming area complete mandatory RSG training as do board members. All told, he presented as a competent and assured manager and on the day of my unannounced visit, the premises and grounds had an air of quiet competence and communal friendliness.
7. Mr David Baldi is the general manager of Mercury Group Victoria Inc. Ms Jacqueline Hutchison is its compliance officer. Mercury is a not-for-profit member-based organisation established under the auspice of ClubsVIC to assist venues navigate the transition to the new venue-based system. There are 46 clubs in the association. It is an independent group that offers a wide range of management services to clubs and gaming hotels. It prepares budgets, reports and plans for a variety of purposes. In his Competitor and Market Analysis Mr Baldi set out his computations that show the club's decline in net gaming revenue during the 2010-11 year compared with the prior year occurring, as it did, at a time when the local government area experienced an increase in net gaming revenue. His conclusions were set out as follows:

It is estimated that the increase of 10 EGMs at the Club's Venue will increase the Club's NGR [net gaming revenue] from between $163,284 and $284,879 and that 50% will be transferred from other venues in the LGA. These figures could also be lower after removal of the ATM in July 2012 and the effect on the Club's revenue is assessed. The expected increased competition in the LGA and particularly the Bridge Inn will affect the Club's revenue as other venues replace old product and introduce new product.

1. Ms Hutchison gave evidence that Mercury's responsible gambling initiative includes self-exclusion protocols and that there are 34 persons self-excluded from the Whittlesea club. She volunteered her opinion that the club exceeds its mandatory responsibilities in delivering responsible gambling and expressed her view, based on her knowledge of the club and its management, that in the event the club's application is successful, its operations would not lead to any increased risk of problem gambling in the region.
2. Mr Rhys Quick is the director of economics and market research at Urbis. Urbis is an international property group providing a range of services including town planning, social research, valuation, economic analysis etc. Mr Quick is an economist. His report dated in December 2011 and an updated version in March 2012 were both before the Commission at first instance; a further updated version prepared in October 2012 was presented to this Tribunal.
3. Mr Quick's short summary was that' having regard to all the information presently available to him, he stands by his earlier view that the proposed addition of 10 EGMs as part of other works proposed will not generate any detrimental impact on the social and economic well-being of the Whittlesea community. In fact his view is to the contrary; that is ,that a positive outcome is likely in both an economic and social sense. His assessment is based on the following:

The provision of gaming will facilitate the continued development of the Whittlesea Bowls Club, providing the growing community with access to enhanced social opportunities and facilities, while generating increased employment opportunities.

This application will enable the Club to reduce debt to be in a better position to increase financial benefits to the local community, including developing a more formal charitable donation structure to local groups. With additional machines, the intention is to increase contributions in the short term to 15% of surplus income after loans. This is expected to amount to $70,000 - $100,000, increasing significantly over the next 4-5 years once debts have been repaid.

There is expected to be a negligible transfer of gaming expenditure from firstly other gaming venues which are concentrated a significant distance away in the south of the municipality, and secondly will have virtually no impact on other businesses in Whittlesea. In fact, there is potential for additional economic activity to be retained in Whittlesea to the benefit of local businesses.

The impact of problem gambling is expected to be negligible also, influenced by -

• The location of the venue removed from area of high activity.
• The strong demographic characteristics of the northern part of the municipality served by the venue.
• The minimal change in accessibility given the venue already offers 40 gaming machines.

1. In chapter 3 of his report he conducted an overview of gaming machines in the City of Whittlesea. According to his enquiries gaming expenditure at the Whittlesea Bowls Club is low relative to other venues in the Whittlesea LGA. Its EGM expenditure is approximately the same as other similarly equipped clubs and, not unnaturally, markedly less than that of the four nominated hotel venues.
2. Mr Quick provided a table at page 35 of his October report headed 'EGM SUMMARY STATISTICS (AS AT 30 JUNE 2012)'. It contained some useful information based on population figures said to have been sourced from the Commission's own website although prepared without the benefit of Bridge Inn estimates. According to the chart, the net expenditure per adult in the City of Whittlesea is above the Melbourne average ($798 compared with $638) whereas expenditure per capita in the Whittlesea North SLA where the club is situated is $262. Both EGM density and EGM expenditure in the Whittlesea North SLA are significantly lower than the Melbourne average. The relevant table follows:

1. In referring to the updated figures supplied by Mr Baldi, which took into account the VCGLR decision to approve 40 EGMs at the Bridge Inn, Mr Quick noted that the club had accepted as a reasonable mid-point an estimated increase in net gaming revenue of $319,000 as a consequence of the extra machines and expressed the following reservation:

96. The Club has now accepted as a reasonable mid-point of the two experts agreed during the VCGLR hearing which was that Net Gaming revenue at the venue is expected to increase by $319,000 in 2012-13 as a result of the 10 additional EGMs. However, 50% of this additional revenue is expected to be transferred from existing gaming venues in the municipality. Gaming expenditure in the City of Whittlesea is therefore expected to increase by just 0.16% of the 2011/12 gaming expenditure for the municipality as a result of this application. Following 2012-13, the venue expects its gaming revenue to decrease due to the impact of the Bridge Inn. The venue hopes to maintain its revenue position in the face of increasing competition with the opening of the Bridge Inn gaming facilities. Without the additional machines, the Club's financial position will undoubtedly be inferior.

1. His view on the impact of the additional EGMs on problem gambling was expressed thus:

The risk of an increase in problem gambling is the major negative social consequence of gaming that needs to be weighed up against the positives of this application. However, I consider the risk of an increase in problem gambling as a direct result of this application to be minimal. This assessment is based on consideration of the risk factors for problem gambling in relation to this application, and is evaluated in the context of a small incremental increase of EGMs in an existing venue.

1. In Branbeau Pty Ltd v VCGR [2005] VCAT 2606 Morris J considered what was meant by what is now called the 'no net detriment' test and the following paragraphs have particular relevance. His Honour was referring to a case for approval of premises but the test is identical in relation to applications for an amendment to increase the number of machines. His Honour said:

44 I now return to the question of the meaning of the test .... that the net economic and social impact of approval will not be detrimental to the well-being of the community of the municipal district in which the premises are located.

45 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.

46 Although there is a distinction between economic impacts and social impacts, there is likely to be such an overlap between the concepts that it will generally be more helpful, and more convenient, to consider these impacts together.

49 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.

50 It is unlikely that the Parliament intended that the Commission (or, on review, the tribunal) conduct a quasi Royal Commission into gaming machines each time it was required to determine whether or not to approve an application of premises as suitable for gaming. Rather Parliament should be taken to have intended that the question be considered in the context of the framework of the Act and the framework of the gaming industry established under the Act. Thus the tribunal ought to consider the test in the context that the operation of up to 27,500 gaming machines in Victoria is lawful, that gambling is a valid activity for Victorians, and that responsible gambling should be fostered, not only to minimise harm caused by problem gambling, but also to accommodate those who gamble without harming themselves or others. Given the statutory framework, it would be illogical for the tribunal to conclude that the net economic and social impact of the approval of premises as suitable for gaming will always be detrimental to the well-being of the community of a municipal district in which the premises are located.

1. In Macedon Ranges Shire Council v Romsey Hotel Pty Ltd and VCGR [2008] VSCA 45 the Court of Appeal considered an application to approve certain premises suitable for gaming. The relevant section under consideration in that case was s 3.3.7 and in particular sub-paragraph (c) which is in like terms to s 3.4.20(c). At paragraphs 42-43 the Court stated:

[The Act] does not specify the matters which the decision-maker must consider in deciding whether this 'no net detriment' test is satisfied. (There is an express requirement to consider any submission made by the responsible authority concerning the economic and social impact of the proposal [3.3.7(3)], but this takes the matter no further). The identification of the matters which the decision-maker is bound to consider is, accordingly, a matter of implication from the subject matter, scope and purpose of the Act.

In the present case the statutory signposts are provided by the test itself. The decision maker must consider:

• The likely economic impacts of approval;
• The likely social impacts of approval; and
• The net effect of those impacts on the well-being of the relevant community

'Social impact' means the impact on the society or community (or some part or parts of it) in which the gaming machines are proposed to be located. The 'well-being' of a community is to be measured (at least) by the extent to which the community is healthy, happy, contented and/or prosperous.

1. The club's witnesses were subjected to robust cross-examination by Mr Rantino who appeared for the applicant council. Similarly, Mr Spratt was questioned at length. The upshot was that, although there were many deficiencies in the evidence, frankly not a lot turns on them. And it is fair to say that evidence of the type adduced tends, of necessity, to be based on supposition, hypothesis, past performance and a modicum of intelligent guesswork. And indeed that is the problem with these cases. In Royal Hotel Benalla v VCGR & Ors [2012] VCAT 1972, Judge Macnamara succinctly summarised that dilemma. At paragraph 135 his Honour stated:

Whilst there is much to be said for a precautionary approach in these gaming matters, the true precautionary approach would be to continue the ban which existed in Victoria until just over 20 years ago upon electronic gaming machines and their predecessors, the mechanical poker machines. Cynics at the time suggested that the exclusion of these machines from Victoria was dictated in the decision-making of some governments, not so much by the desire to protect the community from problem gambling, but rather to entrench the share of the gambling dollar available to, for instance, thoroughbred horse racing...Whatever the virtues of this approach may be, the State has turned aside from it two decades ago. The legislation to which reference has been made requires a balancing of factors. I agree with [counsel] that, in coming to grips with the issue of problem gambling, decision-makers are doing no more than 'stabbing in the dark'. This only goes to show how difficult it is to come by reliable data on these difficult issues. The element of 'stabbing in the dark' is further emphasised by the difficulty in comparing putative benefits and disbenefits against one another. How does one value for instance, the damage to the lives of some problem gamblers as against a community contribution of say $50,000 or the benefit to the local economy of a major renovation. Problem gambling is a phenomenon that cannot be accurately measured and even if it could, its consequences are impalpable and difficult to subject to a purely economic analysis.

1. Mr Spratt in his addendum report gave the following summary:

The community using the Whittlesea Bowls Club is vulnerable to problem gambling, particularly in the context of ongoing trauma following the 2009 bushfires and a relatively low resilience to economic downturn. Unemployment in the City of Whittlesea and in the Whittlesea Bowls Club catchment area is currently increasing at a significantly faster rate than the metropolitan average. There is significantly more community opposition than support for an increase in the number of EGMs at the Club.

1. I have set out that paragraph, not because I have a desire to be critical of Mr Spratt's sincerity or expertise, but because it is an example of the hyperbole and rhetoric that surrounds the vexed question of gambling. Why should one assume that the aftermath of the fires will definitely lead to an inevitable increase in problem gambling? Is it possible that the unemployment statistics in all rural areas are worse than those in the metropolitan area? And, in any event, if the level of unemployment is a response to the general economic downtown, does it necessarily follow that the unemployed will gamble excessively? Would community opposition be the same were profits to be for the benefit of not-for-profit local organisations as distinct from large privately-owned hotels?
2. What has become obvious in considering the evidence is that this review really represents a competition between the threat of problem gambling on the one hand and the possibility of additional community benefit on the other.
3. The council received a number of submissions concerning this application and as indicated earlier, it is clear that there is a real apprehension in sections of the community (particularly the welfare and church groups) that problem gambling is a serious and increasing threat to the social fabric of the community. Indeed, the following passages taken at random show the passion with which these views are held:

Research by the Justice Department suggests 12,000 Victorians contemplate suicide each year and 6,000 contemplate breaking the law because of the problems caused by playing the poker machines.

The identified impacts and costs of problem gambling are multi-dimensional and numerous including higher rates of depression and alcohol consumption, financial stress, financial hardship amongst family members, relationship stress and breakdown, child abuse and neglect, disruption to work, reduction in work performance and potential bankruptcy. The financial losses for Whittlesea in the 2011/12 financial year are estimated at $102,300,000.

1. It is certainly true that $102m is the total EGM expenditure for the City of Whittlesea in the relevant period, that there are 621 EGMs in the City of Whittlesea's nine EGM venues, that the club's share of that annual expenditure is approximately 2.8% of the total but none of that leads to the conclusion that an increase of 10 further machines will give rise to the awful consequences contemplated above. The welfare and church groups speak from their actual involvement in the community and there is no doubt that their views are genuinely held, but to make the leap that an extra 10 machines in a municipal area already ravaged by bushfires will inevitably give rise to the consequences enumerated above is possibly a leap too far. That is not to say that the issue of problem gambling is hypothetical - it is real, albeit as Judge Macnamara said, its consequences are impalpable and not amenable to economic analysis.
2. The Tribunal accepts the largely uncontested evidence of Mr Quick that the EGM density in the Whittlesea local government area will remain below the average EGM density in Victoria in the event the application is granted. It also accepts his opinion that the EGM density and expenditure in the Whittlesea North statistical local area where the club is situated will continue to be lower than density and expenditure in the Whittlesea local government area and Melbourne (see paras 43 and 44).
3. The applicant has submitted that the club's intentions concerning redevelopment and increased community support and benefit are set in indefinite timeframes and speculative and thus of no benefit. Certainly there is a lack of definition about just what additional funds will be available for community distribution. Terms such as surplus and profit are used interchangeably. The evidence before the Tribunal was that if the club made a voluntary reduction in its loan facility, that amount would not be taken into account in assessing the available distribution pool but, if the bank called for a payment of principal on its interest only loan, that would be deducted from the pool. Notwithstanding this lack of precision, the Tribunal accepts that the club's resolution to increase its community assistance package is genuine and accepts that there is no reason to doubt that this will result in an overall increase in funding for many of the municipality's volunteer organisations. The Tribunal also notes the club's long term ambition to increase the pay-out to 30% when all its debts are repaid.
4. The applicant also contends that the uncertainty surrounding the completion of the eventual improvements (which it says might not eventuate until 2016-7) means that the 10 extra machines will be in operation for four years before any community benefit occurs and that these potential benefits are strongly outweighed by the likely increase in problem gambling flowing from the extra machines. Council submits that the proposal thus offers little benefit to the community of Whittlesea. That submission is not accepted and, in any event, it is contradicted by Messrs Aldous and Walker by virtue of the recent resolution to distribute further funds and the contemplated tendering process. The Tribunal does not accept that there needs to be some immediacy about the improvements to enable them to be taken into account. It is satisfied in this instance that the plans are genuinely contemplated.
5. It is true, as Mr Rantino contended, that there is considerable uncertainty about the extent and timing of the club's commitment to extensions, renovations or relocation but the Tribunal accepts the evidence of Messrs Aldous and Walker that the club takes a conservative approach to borrowing and expenditure and intends to await the outcome of this application before proceeding to an actual commitment. Mr Walker told the Tribunal that the club continues to maintain the extensive community asset which it operates on behalf of the community and provide for the community's future needs. He told the Tribunal that, if the application were to be successful, the club would confidently embrace the improvements, be that a move or an upgrade, to provide for the future without encumbering the club with excessive debt. That strikes the Tribunal as a prudent and proper approach.
6. Each of Messrs Aldous and Walker spoke about the in kind assistance the club presently offers to various organisations throughout the municipality and the Tribunal accepts that whatever modifications and improvements may occur, the club will continue this service and be in a position to render even more assistance of that nature.
7. The council seeks to join the advent of the bushfires with an increase in problem gambling due to hardship submitting that 'there is a high risk that a significant portion of the additional expenditure will come from problem gamblers'. Again, this is speculative; the Tribunal has given credence to the self-exclusion policy in place in the club which, to some extent at least, alleviates risk.
8. The Tribunal does not accept the proposition that the absence of a demonstrated need for additional machines is fatal or that there is something negative about the club's desire to fend off competition by seeking further machines. Need is not an express statutory criteria and competitive influences are a factor of modern business activity. Indeed, it was Mr Walker's evidence that the club has lost some market share which, in his view. was due to the superior product selection in local hotel venues. It was his opinion that the club should be able to limit the negative impact of those influences with the additional machines. The Tribunal accepts the evidence that granting the application will widen the choices available to the gaming public and will assist in meeting some of the club's competitive pressures.
9. It is accepted that the club is well run, that its attitude to its responsible gambling obligations is excellent and it provides a pleasant, comfortable and orderly venue for its patrons. From my brief visit, it is not surprising that community groups use the meeting and function space provided to them by the club as part of its in kind contribution to the community. It offers a valuable resource and the possibility of eventual improved accommodation will no doubt be gratefully received by those community groups whose use of the facilities is generously subsidised by the club.
10. The Tribunal accepts that an increase in the number of machines will go some way to increasing revenue thus enhancing the club's ability better to service its commitments.
11. And that brings me to the balancing of the positives and negatives in order to be satisfied whether or not the net economic and social impact of approval will or will not be detrimental to the well-being of the community of the municipal district in which the club is located. I am not persuaded that there is any evidence to indicate that granting this application would be detrimental to other venue operators in the municipality.
12. The major negative impact of any increase in the number of machines is clearly that posed by the threat of compulsive or problem gambling and its impact on the economic and social fabric of the municipality. Against that must be balanced the eventual improvement of the premises, the club's improved ability to service debt for the ultimate benefit of members as a result of increased revenue, the creation of some extra jobs, the continued and possibly extended in kind provision of venue and other assistance and the commitment to increased financial contribution to local community groups.
13. Having regard to my findings and the observations made throughout these reasons' I am satisfied that the net economic and social impact of approving an extra 10 machines at the club will not be detrimental to the wellbeing of the community of the municipal district of Whittlesea. There are a number of benefits to the community which must of course be balanced against the occurrence of problem gambling but I am satisfied the positives far outweigh the negatives.
14. The decision of the Commission made on 30 May 2012 is affirmed.