title: Amendment C110gpla - Gaming Policy and Clause 52.28 Schedule council: golden-plains state: vic category: amendment classification: MINOR status: draft last_compiled: 2026-05-30 source_docs:
- Council Meeting Agenda 25 November 2025.pdf
Amendment C110gpla - Gaming Policy and Clause 52.28 Schedule
Amendment C110gpla is a Shire-wide policy-control amendment that would add gaming harm minimisation directions into the Golden Plains Planning Scheme rather than rezone land or alter growth-area boundaries. (Source: Council Meeting Agenda 25 November 2025.pdf, p.19) Its practical effect is to make the location, design, operation and assessment information for electronic gaming machine venues a clearer planning issue, with particular attention to convenience gambling, vulnerable communities, growth areas, residential settings and local amenity. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19-20)
Background
Council officers presented Amendment C110gpla to the 25 November 2025 Council meeting with a recommendation that Council authorise preparation and exhibition under section 20(2) of the Planning and Environment Act 1987. (Source: Council Meeting Agenda 25 November 2025.pdf, p.19) The amendment was described as implementing the Golden Plains Shire Gambling Harm Minimisation Policy adopted by Council on 23 September 2025. (Source: Council Meeting Agenda 25 November 2025.pdf, p.19)
The stated policy problem is that gambling is lawful but electronic gaming machine use is treated as a public health issue with effects on individuals, families and the broader community. (Source: Council Meeting Agenda 25 November 2025.pdf, p.19) The officer report cites 2023-2024 Victorian EGM losses of 3.03 billion, equivalent to an average of 6.2 million per venue, 115,000 per machine and 581 per adult. (Source: Council Meeting Agenda 25 November 2025.pdf, p.19)
The amendment applies to the entire municipality of Golden Plains Shire. (Source: Council Meeting Agenda 25 November 2025.pdf, p.22) It would insert a new Clause 02.03-10 on gaming and replace the Schedule to Clause 52.28 Gaming. (Source: Council Meeting Agenda 25 November 2025.pdf, p.28)
Analysis
Statutory Mechanism
The amendment uses two planning scheme levers. (Source: Council Meeting Agenda 25 November 2025.pdf, p.28) First, it inserts a new strategic direction at Clause 02.03-10 so gaming harm minimisation becomes part of the Municipal Planning Strategy. (Source: Council Meeting Agenda 25 November 2025.pdf, p.39) Second, it replaces the Schedule to Clause 52.28 so permit assessment for gaming machines receives localised objectives, prohibited shopping locations, siting criteria, venue criteria, application requirements and decision guidelines. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-43)
The new Clause 02.03-10 states that Council recognises gambling and EGM use as a public health issue affecting individuals, families and the broader community. (Source: Council Meeting Agenda 25 November 2025.pdf, p.39) It also states that research links social disadvantage, problem gambling and proximity to gaming venues, and that EGMs should not be convenient in a way that encourages spontaneous rather than pre-determined gambling decisions. (Source: Council Meeting Agenda 25 November 2025.pdf, p.39)
The mechanism is therefore not a ban on all gaming activity across the municipality. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-43) It is a locational and assessment framework that narrows where gaming machines are preferred, expands the information an applicant must provide, and gives the responsible authority more explicit grounds to assess harm, amenity, vulnerability and net community impact. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-43)
Locational Control and Convenience Gambling
The amended Clause 52.28 schedule would set objectives to minimise gambling-related harm, minimise convenience gambling, discourage new gaming venues in growth areas until communities are sufficiently established, manage concentrations away from vulnerable communities, ensure gaming is not the primary venue use, and discourage gaming premises in predominantly residential locations. (Source: Council Meeting Agenda 25 November 2025.pdf, p.40)
The schedule would prohibit gaming machines in one named shopping complex, Bannockburn Central, on land generally bounded by Victor Street, McPhillips Road and Burns Street. (Source: Council Meeting Agenda 25 November 2025.pdf, p.40) It would also prohibit gaming machines in all strip shopping centres covered by the planning scheme, with named strip shopping centre localities including Bannockburn Shopping Locality, Sussex Street in Linton, and Brooke Street in Smythesdale. (Source: Council Meeting Agenda 25 November 2025.pdf, p.40)
The proposed location criteria are designed to separate gaming from ordinary daily movement patterns. (Source: Council Meeting Agenda 25 November 2025.pdf, p.40) Gaming venues and machines should be on sites that minimise the likelihood of people passing the venue during usual business or everyday activities, and should be where the community has convenient access to non-gaming entertainment, leisure, social and recreational uses operating at the same time. (Source: Council Meeting Agenda 25 November 2025.pdf, p.40)
The 400 metre test is one of the amendment’s most operational controls. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-41) Proposed gaming venues should be at least 400 metres from areas of relative socio-economic disadvantage, defined by reference to Victorian SEIFA Index of Relative Disadvantage collection districts, and from residential or community-based uses including schools, kindergartens, childcare centres, libraries, aged care facilities and churches. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-41)
Growth Area Implications
The amendment is minor in land-supply terms because it does not rezone land, create new growth fronts or change housing yield assumptions. (Source: Council Meeting Agenda 25 November 2025.pdf, p.26) Its importance for growth areas is behavioural and sequencing-based: it discourages new gaming venues from establishing in growth areas until new communities are sufficiently established and uncertainties about adjoining uses, sensitive uses and social and economic impacts can be understood. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.23, 40-41)
This means a proposed gaming venue in a newly developing area would face a higher planning burden before the social profile and built form of the area are settled. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.23, 41-42) The amendment links this caution to the risk that future residents in growth areas may be more susceptible to gambling harm through housing stress and car ownership pressures. (Source: Council Meeting Agenda 25 November 2025.pdf, p.24)
The amendment does not identify specific growth-area boundaries or list which Golden Plains growth areas are affected. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19-43) That leaves an analytical gap for applying the policy to individual settlements such as Bannockburn, Smythesdale, Linton or other growth locations. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-41)
Venue Form, Operation and Assessment Burden
The venue criteria would favour premises where gaming is only one component of a broader social, leisure and recreational offer. (Source: Council Meeting Agenda 25 November 2025.pdf, p.41) Proposed gaming venues should physically and visually separate gaming activities from non-gaming activities, promote harm minimisation practices beyond minimum standards, operate hours consistent with the site context, avoid amenity impacts from traffic, patrons, car parking and safety, and keep the gaming floor area to 25 percent or less of the venue’s total net floor area. (Source: Council Meeting Agenda 25 November 2025.pdf, p.41)
The schedule would also prefer community, sports or recreation clubs operating on landholdings larger than 4 hectares. (Source: Council Meeting Agenda 25 November 2025.pdf, p.41) This criterion shifts the planning assessment away from small, highly convenient premises and toward larger venues where gaming is embedded within a wider community, sport or recreation function. (Source: Council Meeting Agenda 25 November 2025.pdf, p.41)
The application requirements are extensive compared with the previous schedule, which had no local requirements specified. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-42) Applicants would need to describe the local area, measure distances to shops, community facilities, affordable housing, counselling services and public transport, identify existing and proposed gambling and non-gambling entertainment within 5 kilometres, map a 400 metre walking catchment, and provide pedestrian counts outside the proposed venue on different days and at different times. (Source: Council Meeting Agenda 25 November 2025.pdf, p.41)
Applicants would also need to provide venue design and operation details, including operating hours, licensed alcohol areas, layout plans, EGM locations, responsible gambling practices, machine transfers, changes to machine density per 1,000 adults, three-year expenditure forecasts, and municipal and venue-level expenditure effects per machine and per adult. (Source: Council Meeting Agenda 25 November 2025.pdf, p.42)
A social and economic impact assessment would be required from a suitably qualified person. (Source: Council Meeting Agenda 25 November 2025.pdf, p.42) That assessment would need to address the municipality and patron catchment’s demographic and socio-economic profile, SEIFA disadvantage data, projected patron catchment, community benefits, net community impact, impacts on vulnerable groups within 400 metres walking distance, mitigation measures and potential local economic contribution. (Source: Council Meeting Agenda 25 November 2025.pdf, p.42)
Decision Pathway and Risk Allocation
The decision guidelines would require the responsible authority to consider whether a proposal increases gambling-related harm or creates a net detriment to local wellbeing. (Source: Council Meeting Agenda 25 November 2025.pdf, p.42) They would also require consideration of socio-economic disadvantage, vulnerable communities, exposure to gaming opportunities during day-to-day activities, availability of non-gaming recreation choices, amenity impacts, traffic, parking, noise, hours of operation, safety, local character, tourism and cultural assets. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.42-43)
The practical risk transfer is from Council having to infer local gaming impacts from general policy to applicants having to provide structured local evidence. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.41-42) Council’s explanatory report states that the amendment is expected to reduce responsible-authority resource and administrative costs by clarifying information requirements for EGM permit assessment. (Source: Council Meeting Agenda 25 November 2025.pdf, p.27)
The amendment has no stated financial management impact in the officer report. (Source: Council Meeting Agenda 25 November 2025.pdf, p.20) It is also described as not expected to affect climate change, bushfire risk, the transport system, or Yarra River land. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.24-25, 27)
Policy Alignment
The officer report links the amendment to Community Vision 2040, the Council Plan, the Municipal Public Health and Wellbeing Plan 2025-2029, the Gambling Harm Minimisation Policy 2025, the Victorian Public Health and Wellbeing Act 2008, the Victorian Commission for Gambling and Liquor Regulation Act 2011 and the Gambling Regulation Act 2003. (Source: Council Meeting Agenda 25 November 2025.pdf, p.20)
The explanatory report states that the amendment is consistent with Planning Policy Framework clauses on structure planning, urban design, healthy neighbourhoods, rural-area design, business and out-of-centre development. (Source: Council Meeting Agenda 25 November 2025.pdf, p.25) The explanatory report also states that the amendment is not related to delivery of housing targets in the Planning Policy Framework. (Source: Council Meeting Agenda 25 November 2025.pdf, p.26)
Agency engagement occurred through preparation of the Gambling Harm Minimisation Policy 2025, including DTP Planning and Land Services, the Victorian Local Governance Association, VicHealth, the Department of Health, and the Department of Families, Fairness and Housing. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.26-27) Preliminary DTP Planning and Land Services views were sought before exhibition and were incorporated into matters including regional walkable distances from proposed sites and landholding requirements for community, sports and recreation clubs. (Source: Council Meeting Agenda 25 November 2025.pdf, p.27)
Current Status
As at the 25 November 2025 agenda, the amendment was before Council for authorisation to prepare and exhibit. (Source: Council Meeting Agenda 25 November 2025.pdf, p.19) The agenda recommendation was to authorise preparation and exhibition of the amendment under section 20(2) of the Planning and Environment Act 1987. (Source: Council Meeting Agenda 25 November 2025.pdf, p.19)
The exhibited documents were not yet complete in two procedural respects: the explanatory report included placeholder text for the submissions due date and placeholder text for directions hearing and panel hearing dates. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.21-22) The next procedural step identified in the officer report was community engagement during the exhibition period. (Source: Council Meeting Agenda 25 November 2025.pdf, p.20)
Dependencies
- Blocks: The amendment would not block housing delivery or land rezoning because the explanatory report states it is not related to Planning Policy Framework housing target delivery. (Source: Council Meeting Agenda 25 November 2025.pdf, p.26)
- Blocked by: The amendment is dependent on Council authorising preparation and exhibition and then completing the statutory amendment process. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19-20)
- Informed by: The amendment is informed by the Golden Plains Shire Gambling Harm Minimisation Policy adopted on 23 September 2025 and by preliminary DTP Planning and Land Services input before exhibition. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19, 27)
- Implements: The amendment implements the Gambling Harm Minimisation Policy by inserting Clause 02.03-10 and replacing the Schedule to Clause 52.28. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19, 28)
- Conflicts with: The source document does not identify a direct conflict with another local policy, but the amendment creates a more restrictive assessment setting for gaming venues in growth areas, residential contexts, shopping complexes and strip shopping centres. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-43)
Cross-Jurisdictional Links
The source document records state-agency involvement through DTP Planning and Land Services and health-related agencies during development of the Gambling Harm Minimisation Policy. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.26-27) The source document does not identify an adjacent-council dependency, shared infrastructure dependency or regional servicing trigger for this amendment. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19-43)
Gaps in This Analysis
The source set contains only the 25 November 2025 Council agenda and its attached amendment material. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19-43) The adopted Golden Plains Shire Gambling Harm Minimisation Policy 2025 is referenced as the policy basis for the amendment, but it is not available as a separate source document in this manifest. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19, 22)
The source document does not include public submissions, an adopted Council resolution after the agenda item, authorisation correspondence, exhibition dates, panel dates, a panel report, an adoption report or an approval notice. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.19-22) Because those documents are missing, this page cannot assess community objections, agency conditions, post-exhibition changes, panel findings, final gazettal wording or whether the proposed 400 metre, 25 percent floor-area and 4 hectare landholding tests changed after exhibition. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.40-43)
The extracted text path for the agenda omits most attachment text because the amendment attachments are image-rendered in the PDF, so the detailed ordinance analysis relies on the visible attachment pages in the same source PDF rather than machine-readable extracted text. (Source: Council Meeting Agenda 25 November 2025.pdf, pp.21-43)